# GOLF HOST SECURITIES, INC. X-17A-5 (2024-04-08) — Broker-dealer annual report

- Company: GOLF HOST SECURITIES, INC.
- Form: X-17A-5
- Filed: 2024-04-08
- Period: 2023-12-31
- Accession: 0000042431-24-000002
- CIK: 42431
- File #: 8-18181
- Type: Broker-dealer
- Material weakness: No
- Auditor: None
- Auditor location: Palm Harbor, FL
- Contact: Debra Nobile
- Phone: 727-942-5210
- Signed by: Debra Nobile (President)

Original filing: https://www.sec.gov/Archives/edgar/data/42431/000004243124000002/sec2023full-.pdf

---

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## **Salamander lnnisbrook Securities Balance Sheet (in USO)**

| Reporting Book:           | ACCRUAL      |
|---------------------------|--------------|
| As of Date:               | 12/31/2023   |
| Location:                 | INNISSEC     |
|                           | Pe~od Ending |
|                           | 12/31/2023   |
|                           |              |
| Assets                    |              |
| Current Assets            |              |
| Cash and Cash Equivalents | 678,103      |
| Accounts Receivable, Net  |              |
| Prepaid Expenses          | 418          |
| lntercompany Receivable   |              |
| Total Current Assets      | 678,521      |
| Fixed Assets, Net         |              |
| Fixed Assets              | 8,063        |
| Accumulated Depreciation  | 8,063        |
| Total Fixed Assets, Net   | 0            |
|                           |              |
| Total Assets              | 678,521      |
|                           |              |
| Liabilities and Equity    |              |
| Current Liabilities       |              |
| Accounts Payable          |              |
| Accrued Liabilities       | 5,397        |
| lntercompany Payable      | 26,404       |
| Total Current Liabilities | 31,801       |
| Stockholders Equity       |              |
| Retained Earnings         | 646,720      |
| Total Member's Equity     | 646,720      |
|                           |              |

**678,521** 

**Total Liabilities and Equity** 

{1}------------------------------------------------

Exemption Report January 1, 2023 through December 31, 2023.

Golf Host Securities "(the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C.F .R. §240.17a-5, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R. §240.17a-5(d)(1) and (4 ). To the best of its knowledge and belief, the Company states the following:

(1) The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240. 15c3-3, and

(2) The Company is filing this Exemption Report relying on Footnote 74 of the SEC Release No.34- 70073 adopting amendments to 17 C.F.R. § 240.17a-5 because the Company limits its business activities exclusively to participating in distributions of securities (other than firm commitment underwritings) in accordance with the requirements of paragraphs (a) or (b)(2) of Rule 15c2-4; and the Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers; (2) did not carry accounts of or for customers; and (3) did not carry PAS accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception."

I, NAME OF SIGNATOR, swear (or affirm) that, to my best knowledge and belief, this Exemption Report is true and correct.

/S/ Debbie J. Nobile.

President, Golf Host Securities

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**UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549** 

0MB APPROVAL 0MB Number: 3235-0123 Expires; Nov. 30, 2026 Estimated average burden hours per response: 12

SEC FILE NUMBER

# **ANNUAL REPORTS FORM X-17A-5 PART** Ill

**FACING PAGE** 

| o 1/o,/2o<br>23<br>FILING FOR THE PERIOD BEGINNING                                                                                                                    |                                                        |            |  |  |
|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------|------------|--|--|
| ~ MM/DD/YY                                                                                                                                                            | AND ENDING ____,_/-=,Z;f---' /3~/-,,/4-=-2_0_2_.3""'-- |            |  |  |
|                                                                                                                                                                       |                                                        | MM/DD/YY   |  |  |
| A. REGISTRANT IDENTIFICATION                                                                                                                                          |                                                        |            |  |  |
| 00LF<br>Ho~r<br>Se:cu1c.1<br>NAME 0FF1RM:                                                                                                                             | 11£5 ,J;NC-<br>,                                       |            |  |  |
| TYPE OF REGISTRANT (check all applicable boxes):<br>D Security-based swap dealer<br>[II Broker-dealer<br>D Check here if respondent is also an OTC derivatives dealer | D Major security-based swap participant                |            |  |  |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.)                                                                                                   |                                                        |            |  |  |
| H-wy Jq)/<br>31.; 75D<br>[)S<br>(No. and Street)                                                                                                                      |                                                        |            |  |  |
| fL                                                                                                                                                                    |                                                        |            |  |  |
| (State)                                                                                                                                                               |                                                        | (Zip Code) |  |  |
| PERSON TO CONTACT WITH REGARD TO THIS FILING                                                                                                                          |                                                        |            |  |  |
| bebm Nob1<br>7z7,.ql./2.<br>-6'210<br>-JG-                                                                                                                            |                                                        |            |  |  |
| (Name)<br>(Area Code - Telephone Number)                                                                                                                              | (Email Address)                                        |            |  |  |
| B. ACCOUNTANT IDENTIFICATION                                                                                                                                          |                                                        |            |  |  |
| INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*<br>N/ft<br>(Name - if individual, state last, first, and middle name)                       |                                                        |            |  |  |
|                                                                                                                                                                       |                                                        |            |  |  |
| l"<br>(Address)<br>(City)                                                                                                                                             | (State)                                                | (Zip Code) |  |  |
| of Regi>tratloo with PCAOB J{O appiicabieJ                                                                                                                            | {PCAOB Regi>tratloo Nombec, if applicabieJ             | I          |  |  |
| FOR OFFICIAL USE ONLY                                                                                                                                                 |                                                        |            |  |  |
|                                                                                                                                                                       |                                                        |            |  |  |
| * Claims for exemption from the requirement that the annual reports be covered by the reports of an independent public                                                |                                                        |            |  |  |

CFR 240.17a-S(e)(l)(ii), if applicable. **Persons who are to respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid 0MB control number.** 

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Titlen. **d** . 1., *v res* **)(Je.01** 

## **This filing\*\* contains (check all applicable boxes):**

- (a) Statement of financial condition.
- D (b) Notes to consolidated statement of financial condition.
- (c) Statement of income (loss) or, if there is other comprehensive income in the period(s) presented, a statement of comprehensive income (as defined in§ 210.1-02 of Regulation S-X).
- (d) Statement of cash flows.
- 0 (e) Statement of changes in stockholders' or partners' or sole proprietor's equity.
- C {f) Statement of changes in liabilities subordinated to claims of creditors.
- D (g) Notes to consolidated financial statements.
- C (h) Computation of net capital under 17 CFR 240.1Sc3-1 or 17 CFR 240.18a-1, as applicable.
- ::J (i) Computation of tangible net worth under 17 CFR 240.18a-2.
- u U) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3.
- u (k) Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.15c3-3 or Exhibit A to 17 CFR 240.18a-4, as applicable.
- ~ (I) Computation for Determination of PAB Requirements under Exhibit A to § 240.1Sc3-3.
- C (m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3.
- D {n) Information relating to possession or control requirements for security-based swap customers under 17 CFR 240.15c3-3(p){2) or 17 CFR 240.18a-4, as applicable.
- 0 (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capital or tangible net worth under 17 CFR 240.1Sc3-1, 17 CFR 240.18a-l, or 17 CFR 240.18a-2, as applicable, and the reserve requirements under 17 CFR 240.15c3-3 or 17 CFR 240.lSa-4, as applicable, if material differences exist, or a statement that no material differences exist.
- D (p) Summary of financial data for subsidiaries not consolidated in the statement offinancial condition.
- D (q) Oath or affirmation in accordance with 17 CFR 240.17a-5, 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable.
- D (r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- D (s) Exemption report in accordance with 17 CFR 240.17a-S or 17 CFR 240.18a-7, as applicable.
- D (t) Independent public accountant's report based on an examination of the statement of financial condition.
- D (u) Independent public accountant's report based on an examination of the financial report or financial statements under 17 CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable.
- □ (v) Independent public accountant's report based on an examination of certain statements in the compliance report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- D (w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- D (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-le or 17 CFR 240.17a-12, as applicable.
- □ (y) Report describing any material inadequacies found to exist or found to have existed since the date of the previous audit, or a statement that no material inadequacies exist, under 17 CFR 240.17a-12(k). D (z) Other: \_\_\_\_ \_\_\_ \_\_\_ \_ \_ \_ \_ \_ \_ \_\_\_\_ \_\_\_ \_\_\_\_ \_ \_ \_ \_ \_\_\_ \_ \_ \_
- 
- \*\*To request confidential treatment of certain portions of this filing, see 17 CFR 240.17a-5(e)(3} or 17 CFR 240.18a-7(d}(2), as applicable.

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#### **GOLF HOST SECURITIES NOTES TO CONSOLIDATED FINANCIAL STATEMENTS December 31, 2023**

#### **1. Nature of Business**

Golf Host Securities, Inc (the "Company") is owned by Salamander Innisbrook Securities, LLC. Salamander Innisbrook, LLC, owns and operates the Innisbrook Resort and Golf Club (the "Resort") and Salamander Innisbrook Securities, LLC.

#### **2. Summary of Significant Accounting Policies**

*Statements of Cash Flows* - For purposes of the statements of cash flows, we consider all liquid investments purchased with an original maturity of three months or less to be cash equivalents.

In November 2016, the Financial Accounting Standards Board ("F ASB") issued Accounting Standards Update ("ASU") No. 2016-18, "Statement of Cash Flows" which requires that amounts generally described as restricted cash and restricted cash equivalents be included with cash and cash equivalents when reconciling the beginning-ofperiod and end-of-period total amounts shown on the statement of cash flows. As a result, changes in restricted cash are required to be classified as either operating activities, investing activities, or financing activities depending on the nature of the activities that gave rise to the restrictions.

*Revenues, Deferred Revenue and Accounts Receivable* - Revenues are derived from commissions on real estate transactions. All revenues net of any sales and other taxes collected are recognized as products are delivered or services are performed. The Company collected approximately \$428,000 in commissions during the year ending December 31, 2023.

A performance obligation is a promise in a contract to transfer a distinct good or service to the customer and is the unit of account under the new revenue recognition standard. The transaction price is allocated to each distinct performance obligation and recognized as revenue when, or as, the performance obligation is satisfied. The majority of our revenue is transactional and the contracts performance obligation is generally satisfied at the time of the transaction.

*Use of Estimates* - The preparation of consolidated financial statements in conformity with U.S. GAAP requires us to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the consolidated financial statements and the reported amounts of revenues and expenses during the reporting period. Estimates that are critical to the accompanying consolidated financial statements include our beliefs that all of our long-lived assets. Estimates and assumptions are reviewed periodically and the effects ofrevisions are reflected in the periods they are determined to be necessary. It is at least reasonably possible that our estimates could change in the near term with respect to these matters.

*Concentrations of Credit Risk* - Financial instruments that potentially subject us to concentrations of credit risk consist principally of cash and accounts receivable. Cash consists of bank deposits; no losses have been experienced in such accounts.

We used the following methods and assumptions in estimating the fair values of our financial instruments:

Accounts receivable and accounts payable: Due to their short-term nature, the carrying amounts reported on the accompanying consolidated balance sheets for these accounts approximate their fair values.

*Liquidity* - Our consolidated financial statements are prepared using accounting principles generally accepted in the United States of America, which contemplate the realization of assets and liquidation of liabilities in the normal course of business. We believe that our cash on hand and additional cash generated from operations will be adequate to meet our operating and capital obligations for the next twelve months.

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*Property, Buildings and Equipment, net-* Property, buildings and equipment are stated at cost less accumulated depreciation and amortization. We capitalize any asset purchase of \$1,000 or more with an estimated useful life of at least three years. Depreciation and amortization are recorded using the straight-line basis over the shorter of the estimated useful lives of the assets, or if applicable, the lease terms. Estimated useful lives are generally as follows:

| Category                                | Average Lives<br>(in Years) |
|-----------------------------------------|-----------------------------|
| Buildings  .                            | 40                          |
| Land improvements  .                    | 20                          |
| Machinery and equipment  .              | 3 to 7                      |
| Assets recorded under finance leases  . | 3 to 4                      |

Costs of maintenance and repairs of property and equipment used in operations are charged to expense as incurred, while renewals and betterments are capitalized. When property and equipment are replaced, retired or otherwise disposed of, the costs are deducted from the asset and accumulated depreciation accounts. Gains or losses on sales or retirements of equipment are recorded in operating income.

*Impairment of Long-Lived Assets* - We regularly review long-lived assets for impairment by comparing the carrying values of the assets with their estimated future undiscounted cash flows. If it is determined that an impairment loss has occurred, the loss is recognized during that period. Any impairment loss would be calculated as the difference between asset carrying values and fair value as determined by prices of similar items and other valuation techniques, giving consideration to recent operating performance and pricing trends. There were no impairment losses for the year ended December 3 I , 2023.

*Loss Contingencies* - We estimate loss contingencies in accordance with FASB ASC 450-20, *Loss Contingencies,*  which states that a loss contingency shall be accrued by a charge to income if both of the following conditions are met: (a) information available before the consolidated financial statements are issued or are available to be issued indicates that it is probable that a liability had been incurred at the date of the consolidated financial statements and (b) the amount of loss can be reasonably estimated.

#### **3. Property, Buildings and Equipment**

Depreciation and amortization expense was \$0 for the year ended December 31, 2023.

#### **4. Commitments and Contingencies**

The Company is exempt from the provisions of Rule I 5c3-3 under the Securities Exchange Act of 1934 pursuant to Footnote 74 of SEC Release No. 34-70073. The Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers; (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule l 5c3-3) throughout the most recent fiscal year without exception.

#### **5. Retirement Plan**

We sponsor a defined contribution retirement plan, which provides retirement benefits for all eligible employees. Employees must fulfill a 90-day se1vice requirement to be eligible to participate in this plan. We match one half of the first 6% of the contributions of each employee. These expenses are included within Payroll Tax and Employee Benefits.

#### **6. Other Related Party Transactions**

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At December 31, 2023, we owed our affiliates approximately \$26,000. At December 31, 2023, our affiliates did not owe us. The differences between these amounts and the balances of the due to affiliates in our consolidated balance sheets arise from various affiliate receivables; none of which are significant., The affiliate receivables and payables are unsecured, non-interest bearing and are due on demand.

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#### **Salamander lnnisbrook Securities Cash Flow Statement (in USO)**

| Reporting Book: | ACCRUAL    |
|-----------------|------------|
| As of Date:     | 12/31/2023 |
| Location:       | INNISSEC   |
|                 |            |

|                                                                             | Year Ending  |
|-----------------------------------------------------------------------------|--------------|
|                                                                             | 12/31/2023   |
| Cash Flows from Operating Activities:                                       |              |
| Net Income (Loss)                                                           | (131,741.77) |
| Adjustments to reconcile net loss to net cash used in operating activities: |              |
| Depreciation                                                                | 0.00         |
| Amortization                                                                | 0.00         |
| Stock-based Compensation                                                    | 0.00         |
| Changes in Operating Assets and Liabilities:                                |              |
| Changes in Net Accounts Receivable                                          |              |
| Changes in Accounts Receivable                                              | 0.00         |
| Changes in Allowance for Doubtful Accounts                                  | 0.00         |
| Change in Inventory                                                         | 0.00         |
| Changes in Prepaid Expenses and Other Assets                                | (59.67)      |
| Changes to Accounts Payable                                                 | (70.51)      |
| Changes to Sales and Used Tax Payable                                       | 0.00         |
| Changes to Accrued Liabilites and Other Liabilities                         | 0.00         |
| Changes to Accrued Income Taxes Liabilities                                 | 0.00         |
| Changes to Deferred Income                                                  | 0.00         |
| Changes to Deferred Revenue                                                 | 0.00         |
| Changes to lntercompany                                                     |              |
| Changes to lntercompany Receivable                                          | 13,658.56    |
| Changes to lntercompany Payable                                             | (20,298.78)  |
| Net cash provided by operating Activities                                   | (138,512.17) |
| Cash Flows from Investing Activities                                        |              |
| Capital Expenditures                                                        | 0.00         |
| Net sales (purchases) of ST investements                                    | 0.00         |
| Purchase of long term investments and other assets                          | 0.00         |
| Investment in Subsidiary                                                    | 0.00         |
| Net cash provided by investing activities                                   | 0.00         |
| Cash Flows from Financing Activities                                        |              |
| Changes in Debt Proceeds                                                    | 0.00         |
| Changes in Capital Stock                                                    | 0.00         |
| Net cash provided by financing activities                                   | 0.00         |
| Net increase {decrease) in cash                                             | (138,512.17) |
| Cash - Beginning of Period                                                  | 816,615.36   |
| Cash - End of Period                                                        | 678,103.19   |

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## **Salamander lnnisbrook Securities**

| Cash Flow Statement (in USD) |            |  |
|------------------------------|------------|--|
| Reporting Book:              | ACCRUAL    |  |
| As of Date:                  | 12/31/2023 |  |
| Location:                    | INNISSEC   |  |

|                                                                             | Year Ending  |
|-----------------------------------------------------------------------------|--------------|
|                                                                             | 12/31/2023   |
| Cash Flows from Operating Activities:                                       |              |
| Net Income (Loss)                                                           | (131,741.77) |
| Adjustments to reconcile net loss to net cash used in operating activities: |              |
| Depreciation                                                                | 0.00         |
| Amortization                                                                | 0.00         |
| Stock-based Compensation                                                    | 0.00         |
| Changes in Operating Assets and Liabilities:                                |              |
| Changes in Net Accounts Receivable                                          |              |
| Changes in Accounts Receivable                                              | 0.00         |
| Changes in Allowance for Doubtful Accounts                                  | 0.00         |
| Change in Inventory                                                         | 0.00         |
| Changes in Prepaid Expenses and Other Assets                                | (59.67)      |
| Changes to Accounts Payable                                                 | (70.51)      |
| Changes to Sales and Used Tax Payable                                       | 0.00         |
| Changes to Accrued Liabilites and Other Liabilities                         | 0.00         |
| Changes to Accrued Income Taxes Liabilities                                 | 0.00         |
| Changes to Deferred Income                                                  | 0.00         |
| Changes to Deferred Revenue                                                 | 0.00         |
| Changes to lntercompany                                                     |              |
| Changes to lntercompany Receivable                                          | 13,658.56    |
| Changes to lntercompany Payable                                             | (20,298.78)  |
| Net cash provided by operating Activities                                   | (138,512.17) |
| Cash Flows from Investing Activities                                        |              |
| Capital Expenditures                                                        | 0.00         |
| Net sales (purchases) of ST investements                                    | 0.00         |
| Purchase of long term investments and other assets                          | 0.00         |
| Investment in Subsidiary                                                    | 0.00         |
| Net cash provided by investing activities                                   | 0.00         |
| Cash Flows from Financing Activities                                        |              |
| Changes in Debt Proceeds                                                    | 0.00         |
| Changes in Capital Stock                                                    | 0.00         |
| Net cash provided by financing activities                                   | 0.00         |
| Net increase (decrease) in cash                                             | (138,512.17) |
| Cash - Beginning of Period                                                  | 816,615.36   |
| Cash - End of Period                                                        | 678,103.19   |

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#### **GOLF HOST SECURITIES, INC. Computation of Net Capital 31-Dec-23**

| Total Owners Equity                                                                  | \$<br>646,720 |
|--------------------------------------------------------------------------------------|---------------|
| Deduct Ownership Equity Non-allowable                                                |               |
| Total Owners Equity qualified for Net Capital                                        | 646,720       |
| Deductions and/or charges:<br>Total non-allowable assets<br>Other deductions/charges |               |
| Net Capital before Haircuts<br>Less: Haircuts on Securities                          | 646,720       |
| Total Net Capital                                                                    | \$<br>646,720 |

{10}------------------------------------------------

#### **GOLF HOST SECURITIES, INC. Computation of Net Capital 31-Dec-23**

| Total Net Capital                                                                    | \$<br>646,720 |
|--------------------------------------------------------------------------------------|---------------|
| Less: Haircuts on Securities                                                         |               |
| Net Capital before Haircuts                                                          | 646,720       |
| Deductions and/or charges:<br>Total non-allowable assets<br>Other deductions/charges |               |
| Total Owners Equity qualified for Net Capital                                        | 646,720       |
| Deduct Ownership Equity Non-allowable                                                |               |
| Total Owners Equity                                                                  | \$<br>646,720 |

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# **Salamander lnnisbrook Securities PL\_lnnis Other Entities (in USO) As of December 31 , 2023**  Reporting Book:

As of Date: Location:

| Location:               | INNISSEC           |  |
|-------------------------|--------------------|--|
|                         | INNISSEC           |  |
|                         | 01/01/2023 Through |  |
|                         | 12/31/2023         |  |
|                         |                    |  |
| Profit (Loss)           |                    |  |
| Revenue                 |                    |  |
| Commissions Other       | 427,769.88         |  |
| Revenue                 | 427,769.88         |  |
| Payroll and Benefits    |                    |  |
| Management Salaries     | 174,515.50         |  |
| Pyrl Tax & Emp Benefits | 42,941.29          |  |
| Payroll and Benefits    | 217,456.79         |  |
| Other Expense           |                    |  |
| Audit & Tax             | 26,449.50          |  |
| Bank Charges            | 60.00              |  |
| Commissions             | 74,117.78          |  |
| Contract Labor          | 0.00               |  |
| Dues & Subscriptions    | 4,954.34           |  |
| Licenses & Permits      | 898.07             |  |
| Media                   | 6,922.18           |  |
| Miscellaneous           | 2,600.33           |  |
| Office Supplies         | 3,751 .22          |  |
| Postage & Courier       | 123.16             |  |
| Printing & Stationary   | 276.01             |  |
| Professional Fees       | 6,818.00           |  |
| Public Relations        | 1,037.41           |  |
| Telephone               | 403.57             |  |
| Travel Expense          | 370.72             |  |
| Other Expense           | 128,782.29         |  |
| Fixed Expense           |                    |  |
| Rent & Fixed            | 7,000.08           |  |
| Insurance Liability     | 656.33             |  |
| Depreciation Expense    | 0.00               |  |
| Income Tax              | 205,616.16         |  |
| Fixed Expense           | 213,272.57         |  |
| Profit(Loss)            | (1 31,741 .77)     |  |
|                         |                    |  |

ACCRUAL 12/31/2023

IA.CREATED\_ON: 03/27/2023 2:49 PM EDT

{12}------------------------------------------------

### **Note Regarding Forms Checked But Not Included in order to Upload this Report to Gateway:**

Golf Host Securities, Inc. has an exemption from Annual Audit from the SEC (see letter included in uploads) therefore some of the forms "checked" may not be included (such as Independent Public Accountant's Report, Statement of Changes in Stockholder's or Partner's or Sold Proprietor's Equity, etc.), but in order for the Gateway system to accept our Annual Report, we had to check the boxes.

{13}------------------------------------------------

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M~. ~i.c:::ha~4 :r.,,. 1-J(in A~•istan~ Treasure~ Ca1t **Hast:11 <sup>1</sup>**Xna. PQst **O~tica** Drawe~ 10aa ~~rpon· Bpr1nsQ, ~la~id~ 34~aa-icao . **1:>a~tt !b:'. Aldn:** •·

''l'llia ia 1n **'. 2:e1pona&** ;ta your• 0 AUgust **·J:z.,.·** ·l,9B7 ··l.etT:e~ wharain y0u requested. a raviaw ot tha Divla1.on ·of .Market Regul.llt:ion's (t:he "Oi.v.iaian") v;S.eTJ that: an axampt.icn :'rom. t'iling a.lid.itad 2'nnua1. .. :financ:ials, as roql.l.i.rad by ·pa.rir.g-raph (d) ot RUlQ 17aMs *ot* the soouriUas and axchango Act of 19l4 - --(-b.'.,a-1tAct"r.(-H- -e-.F.R.-i-2·4-0.-l;?a-S-)-,- wa-s- unavai-l-a:ll-l."11- t-o- Go-l:t Hosts Saaurit:les, · Inc. · ("Securitiestt).

J: unclu~tan4 'the pe:tin'ant tac~s to be aa i0110ws *i* Golt Hosts, :rnc:. ("Golt' Roa-t:..a") is tho paren-t; OQQUJY' ot bc:,th Gal.t Host Besarta, :r:na. (":Rascn:t-s") .a.nd. **Sacn.u:ietaa. llosoi:-t:a** ·owns ~nci cper~tea :tnnisb:r:r:10k. Resort . a.nc1 ·: Go1~ CJ.ul> in ':11:pon springs, ~loridll ("Inn.iab::0ok"J and 'r~l!la.ron %nn ; Golt Cl.Ub in our!lngo, Col-oi:a4o ("':t'allUIUon"). . ,S•aurities is a reg-1.stered brokar-cleal.cn:. *:* Sac:ntritia.!1 • act:a **as a** b;-oko:r: (aqant) ~or Xnnisbr~ok and ~a=arrcn in s0lioitin~ subacrip~ians J\_fa~ **sacu.:::it:ias. As** of 1ehruary 20, 19S7, Innisb=-~olc **W:!s-··** ma~gad with and into Tamarron. on March l., 1988, Sol.:e Ho-,ts Securities, ::tne. tiled. its audi'l:ed report ot .financ:iial at:.atomant:s, a.a raguirad by paraqra.ph. (d) *ot* R"Qle l 7a.-5, ·ror tha Qa.lendar yea.r ending Oec:embe= ·:31, 1987 .•

Sac:uri't:ie.s is requlrad, pursuant; to tha proviaions· ot :pa'l:'l:lCJraph (d) at a\Jl& l.7a-s, ta ~il.a **a** ca~i..tiad -umual. report o~ tinancial st~t::ainants on a calendar 0r tiscll.l yaat" hll.=si:s. Su.ch report • muae be as o:J! t.ha **sa.~"-** :fi~ad O=' detcu:'?llin11. bl.a data a"ch yea:i::- unlasQ a change is approved l::ly th~ Ca~i:a:sicin. SecU.2:'.U~J.os chose, Cac::al!l\bar 3l. as its audit **data;** thera:ora, .Sac~~ities was required to prepare a certieiea annual report as of Decetnber Jl, l~87.

Aocefvecl Go!f Ho

/~\ \ ~· 1 MAR 3 0 1988 ' ,. **,J** 

{14}------------------------------------------------

- .• . \_ ' .. ,.-.

..

2

In light or SecQ:rlt.1.e-s having filed its audited annual report tor the 199·7 c~landar ye.ar, securiti·a~ no longet' naeds ~xol'Gptive **:-o1J.Qt:** ti:-0,11 that rsc:r..iireraent. • With ragarcts to the requirer!lent th2't S•c:urit:ies· **·tile** c:artitiad til'\2mi:ials in uaa, ii\$ would **a.ppeu;;-** thi!lt due to . the 1:11,rgar ot l'nnisbl!'oak and 'l'a~arrcn, Saou'l:itias' l:iusinass is now l.iizaited to l!l.eting **a3** ~ ~roker (i!lgent) ~or a sLngle issuer.

Page l00ofl01


Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.
