# HAMILTON CLARK SUSTAINABLE CAPITAL, INC. X-17A-5 (2023-03-02) — Broker-dealer annual report - Company: HAMILTON CLARK SUSTAINABLE CAPITAL, INC. - Form: X-17A-5 - Filed: 2023-03-02 - Period: 2022-12-31 - Accession: 0000860034-23-000001 - CIK: 860034 - File #: 8-42236 - Type: Broker-dealer - Material weakness: No - Auditor: Turner, Stone & Company, L.L.P. - Auditor location: Dallas, TX - Contact: John J. McKenna - Phone: 202-481-2252 - Email: john.mckenna@hamiltonclark.com - Website: hamiltonclark.com - Signed by: John J. McKenna (President and Chief Compliance Officer) Original filing: https://www.sec.gov/Archives/edgar/data/860034/000086003423000001/2022audithamilton-.pdf --- {0}------------------------------------------------ | UNITED STATES | |------------------------------------| | SECURITIES AND EXCHANGE COMMISSION | | Washington, D.C. 20549 | # **ANNUAL REPORTS FORM X-17A-5 PART III** | QMS APPROVAL | | |--------------------------|----| | 0MB Number: 3235-0123 | | | Expires: Oct. 31, 2023 | | | Estimated average burden | | | hours per response: | 12 | | SEC FILE NUMBER | | |-----------------|--| | 8-42236 | | #### **FACING PAGE** **Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934** **FILING FOR THE PERIOD BEGINNING** AND END|NG 12/31/2022 **MM/DD/YY MM/DD/YY** ## **A. REGISTRANT IDENTIFICATION** name OF firm Hamilton Clark Sustainable Capital, Inc. **TYPE OF REGISTRANT (check all applicable boxes):** **X Broker-dealer Security-based swap dealer Major security-based swap participant Check here if respondent is also an OTC derivatives dealer** **ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.)** 1701 Pennsylvania Avenue NW, STE 200 | 20006
(Zip Code)
john.mckenna@hamiltonclark.com
Number)
(Email Address) | |----------------------------------------------------------------------------------------------------| | | | | | | | | | | | B. ACCOUNTANT IDENTIFICATION | | individual, state last, first, and middle name) | | 75251
TX | | (State)
(Zip Code) | | 76 | | (PCAOB Registration Number, If applicable) | | INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*
FOR OFFICIAL USE ONLY | **•Claims for exemption from the requirement that the annual reports be covered by the reports of an independent public accountant must be supported by a statement of facts and circumstances relied on as the basis of the exemption. See 17 CFR 240.17a-5(e)(l)(ii), if applicable.** **Persons who are torespond to the collection of information contained In this form are not required to respond unless the form displays a currently valid 0MB control number.** {1}------------------------------------------------ #### **OATH OR AFFIRMATION** | | ,
J°hn
J.
McKenna
swear (or affirm)
that,
to
the best
of my knowledge
and belief, the | | |----|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--| | | financial report
pertaining to
Hamilton
the firm
,
Clark
Sustainable
Capital,
Inc.
of
,
as of
2 022,js
and correct. Ifurther
—0ecembei^31
true
swear (or affirm)
that
neither the company nor
any | | | | partner, officer,
director, or
equivalent person, as
the case
may be, has any proprietary
interest in
any account classified
solely | | | | as that
of a.j^stomer. | | | | | | | | of
Columbia:
Patriot
SS
Signature: | | | | m
to
m*
and
subscribed
r
before
meonTlt,e: | | | | ej^_dayof
Presid
Chief
Compliance
Officer
6-14-24 | | | | | | | | | | | | r
cv-
3ry
Signature
6 AM A | | | | This flflrtr*
irfs (ch^ck | | | | (a) Statement of financial condition. | | | | (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. | | | X | (e) Statement of changes in
stockholders' or partners' or sole proprietor's equity. | | | | (f) Statement
of changes in liabilities
subordinated to
claims of creditors. | | | KI | (g) Notes to
consolidated financial statements. | | | X | (h) Computation of net capital under 17
CFR 240.15C3-1or 17
CFR 240.18a-l, as applicable. | | | | (i) Computation of tangible net worth under
17 CFR 240.18a-2. | | | | reserve requirements pursuant to
Exhibit A to
(j) Computation for determination of customer
17 CFR 240.15c3-3. | | | | (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 § 240.15c3-3. | | | 81 | (m) Information relating to
possession or control requirements for customers under 17
CFR 240.15c3-3. | | | | (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. | | | 81 | (o) Reconciliations, including appropriate explanations, of
the FOCUS Report with computation of
net capital or tangible net | | | | worth under 17 CFR 240.15c3-l, 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 240.18a-4, as applicable, if material
differences exist, or a statement that no material differences | | | | exist. | | | | (p) Summary of financial data for subsidiaries not consolidated in the
statement of financial condition. | | | X | (q) Oath or affirmation in accordance
with 17 CFR 240.17a-5, 17 CFR 24O.17a-12, or 17 CFR 240.18a-7, as applicable. | | | | (r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. | | | X | (s) Exemption report in accordance
with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. | | | | (t) Independent
public accountant's report based on an examination of the statement of financial condition. | | | X | (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. | | | XI | (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. | | | | (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.1Sc3-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). | | | | (z) Other: | | {2}------------------------------------------------ **Hamilton Clark Sustainable Capital, Inc.** **Financial Statements and** **Report of Independent Registered Public Accounting Firm** **For the Year Ended December 31, 2022** {3}------------------------------------------------ ## **TABLE OF CONTENTS** | OF
INDEPENDENT
ACCOUNTING
REPORT
REGISTERED
PUBLIC
FIRM
1 | |---------------------------------------------------------------------------------| | 3
STATEMENT
OF
FINANCIAL
CONDITION | | STATEMENT
OF
OPERATIONS
4 | | STATEMENT
OF
STOCKHOLDER'S
EQUITY
5 | | OF
6
STATEMENT
CASH
FLOWS | | NOTES
TO
FINANCIAL
STATEMENTS
7-10 | | SCHEDULE
I
1 1 | | REPORT
OF
INDEPENDENT
REGISTERED
PUBLIC
ACCOUNTING
FIRM
12 | | EXEMPTION
REPORT
13 | {4}------------------------------------------------ *Your Vision Our Focus* ![](_page_4_Picture_1.jpeg) ## Report of Independent Registered Public Accounting Firm To the Stockholder of Hamilton Clark Sustainable Capital, Inc. #### *Opinion on the Financial Statements* We have audited the accompanying statement of financial condition of Hamilton Clark Sustainable Capital, Inc, as of December 31, 2022, and the related statements of operations, stockholder's equity and cash flows for the year then ended, and the related notes (collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of Hamilton Clark Sustainable Capital, Inc.as of December 31, 2022, and the results of its operations and its cash flows for the year then ended in conformity with accounting principles generally accepted in the United States of America. #### *Basis for Opinion* These financial statements are the responsibility of the entity's management. Our responsibility is to express an opinion on these financial statements based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) ("PCAOB") and are required to be independent with respect to Hamilton Clark Sustainable Capital, Inc. in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion. #### *Supplemental Information* The supplemental information contained on Schedule I has been subjected to audit procedures performed in conjunction with the audit of Hamilton Clark Sustainable Capital, Inc's financial statements. Schedule I is the responsibility of Hamilton Clark Sustainable Capital, Inc.'s management. Our audit procedures included determining whether Schedule I reconciles to the financial statements or the underlying accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in Schedule I. In forming our opinion on Schedule I. we evaluated whether Schedule I, including its form and content, is presented in conformity with 17 C.F.R. §240.17a-5. In our opinion, Schedule I is fairly stated, in all material respects, in relation to the financial statements as a whole. LL.P We have served as Hamilton Clark Sustainable Capital, Inc.'s auditor since 2019. Dallas, Texas March 1, 2023 > Turner, Stone & Company, LLP Accountants and Consultants 12"00 Park Central Drive. Suite 1400 Dallas.Texas "5251 Telephone:9"2-239-1660/Facstmile: 972-239-1665 Toll Free: 8""-853-4195 Web site: tumerstone.com ![](_page_4_Picture_15.jpeg) {5}------------------------------------------------ # **HAMILTON CLARK SUSTAINABLE CAPITAL, INC. STATEMENT OF FINANCIAL CONDITION DECEMBER 31, 2022** ## Assets Current assets: | Cash | \$
159,508 | |---------------------------------------------------------------|---------------| | Accounts
receivable | 128,009 | | Stock | 240,785 | | Prepaid
expense | 40,463 | | Deposits | 568 | | assets
current
Total | \$
569,333 | | and
at
cost:
Furniture,
fixtures
equipment, | | | and
Furniture,
fixtures
equipment | 13,295 | | Website
Capitalized
Design | 6,350 | | Less
accumulated
depreciation
and
ammortization | (15,140) | | furniture,
Total
fixtures
and
equipment,
net | 4,505 | | assets
Total | \$
573,838 | | Equity
and
Stockholder's
Liabilities | | | Current
liabilities: | | | accrued
expenses
Accounts
payable
and | \$
91,616 | | Commission
payable | 216,706 | | Total
current
liabilities | 308,322 | | equity
Stockholder's | | | shares
Stock,
\$.01
par
value,
3,000
Common | 1 | | capital
Additional
paid-in | 324,704 | | Accumulated
deficit | (59,189) | | Total
stockholder's
equity | 265,516 | | Total
and
stockholder's
equity
liabilities | \$
573,838 | {6}------------------------------------------------ # **HAMILTON CLARK SUSTAINABLE CAPITAL, INC. STATEMENT OF OPERATIONS FOR THE YEAR ENDED DECEMBER 31, 2022** | Revenues | | |-----------------------------------------------------------------------------|-----------------| | success
fees
and
Advisory | \$
2,695,111 | | expense
Reimbursed | 175,192 | | Total
revenues | \$
2,870,303 | | | | | Costs
expenses:
and | | | Travel
and
entertainment | \$
41,364 | | Salaries
and
benefits | 210,493 | | fees
contractors
Independent | 2,317,548 | | and
General
administrative | 138,913 | | fees
Legal
and
professional | 1 12,323 | | and
Depreciation
expense
amortization | 2,586 | | Property
tax
expense | 1,659 | | Total
costs
and
expenses | \$
2,824,886 | | Net
taxes
operating
before
for
income
profit
provision | \$
45,417 | | taxes
Provision
for
income | | | Federal
expense
tax | 8,862 | | State
expense
tax | 14,367 | | Total
for
taxes
provison
income | \$
23,229 | | Net
Income | \$
22,188 | {7}------------------------------------------------ # **HAMILTON CLARK SUSTAINABLE CAPITAL, INC. STATEMENT OF STOCKHOLDER'S EQUITY DECEMBER 31, 2022** | | Shares | Par
Value | | Additional
Paid
in
Capital | Accumulated
Deficit | | Total | | | |-----------------------------------------------------------|--------|--------------|---|-------------------------------------|------------------------|----|--------------------|----|-------------------| | Balance
at
December
31,
2021
Net
Income | 100 | \$ | 1 | \$ | 324,704 | \$ | (81,377)
22,188 | \$ | 243,328
22,188 | | 31,
Balance
at
December
2022 | 100 | \$ | 1 | \$ | 324,704 | \$ | (59,189) | \$ | 265,516 | {8}------------------------------------------------ # **HAMILTON CLARK SUSTAINABLE CAPITAL, INC. STATEMENT OF CASH FLOWS FOR THE YEAR ENDED DECEMBER 31, 2022** | OPERATING
ACTIVITIES | | |-----------------------------------------------------------------|---------------| | Net
income | \$
22,189 | | to
Adjustments
reconcile
net
income | | | cash
operations:
to
net
provided
by | | | expense
Depreciation
and
amortization | 822 | | Changes
in Operating
Assets
and
Liabilities | | | Accounts
receivable | 12,418 | | Stock | (240,785) | | Prepaid
expense | (5,250) | | Accounts
payable | (104,789) | | Commissions
payable | 216,706 | | cash
in Operating
Net
used
Activities | (98,689) | | ACTIVITIES
INVESTING | | | Capitalized
website
design | 1,764 | | Purchase
of
furniture,
fixtures
and
equipment | ( 1J2O4) | | cash
Net
Investing
Activities
provided
by | 560 | | FINANCING
ACTIVITIES | - | | cash
decrease
Net | (98,129) | | Cash
at
of
year
beginning | 257,637 | | at
year
Cash
end
of | \$
159,508 | | cash
Supplemental
disclosure
of
flow
information | | | Inerest
paid | \$ | | Income
tax
paid | \$
44,965 | | | | {9}------------------------------------------------ ## **1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES:** ## Business and operations Hamilton Clark Sustainable Capital, Inc. (formerly Hamilton Clark Securities Company) (the Company) was incorporated in Delaware on January 24, 1990. In June 2014, an amendment was approved to change the name of the Company to Hamilton Clark Sustainable Capital, Inc. The Company is a broker-dealer registered with the Securities and Exchange Commission (SEC) and is a member of the Financial Industry Regulatory Authority (FINRA). Effective February 14, 1996, the National Association of Securities Dealers(NASD), now FINRA, granted the Company's request to reduce its minimum net capital requirement from \$50,000 to \$5,000, which effectively limited the Company's operations to the distribution of private placements of debt and equity securities to institutional and other accredited investors and mergers and acquisitions. #### Management estimates The preparation of financial statements in conformity with U.S. generally accepted accounting principles requires management 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 financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates. ## Cash and cash flows For purposes of the statement of cash flows, cash includes demand deposits, time deposits, certificates of deposit and short-term liquid investments with original maturities of three months or less when purchased. The Company maintains deposits in a financial institution. At December 31, 2022, the Federal Deposit Insurance Corporation (FDIC) provided insurance coverage of up to \$250,000, per depositor, per institution. At December 31, 2022, there is no uninsured cash. ## Accounts Receivable Receivables consist of uncollateralized customer obligations due under normal trade terms. Payments on trade receivables are applied to the earliest unpaid invoices. Management reviews trade receivables periodically and reduces the carrying amount by a valuation allowance that reflects management's best estimate of the amount that may or may not be collectible. As of December 31, 2022, there was no allowance for doubtful accounts. #### Furniture, fixtures and equipment Furniture, fixtures and equipment are stated at cost less accumulated depreciation. Depreciation of furniture, fixtures and equipment being provided using the straight-line method for financial reporting purposes over estimated useful lives of five to seven years and using accelerated methods for tax reporting purposes. {10}------------------------------------------------ ### Revenue recognition In 2018 the Company adopted ASU No. 2014-09, Revenue from Contracts with Customers (Topic 606). Revenue from contracts with customers includes fees from investment banking services. The recognition and measurement of revenue is based on the assessment of individual contract terms. Significant judgment is required to determine whether performance obligations are satisfied at a point in time or over time; how to allocate transaction prices where multiple performance obligations are identified; when to recognize revenue based on the appropriate measure of the Company's progress under the contract; and whether constraints on variable consideration should be applied due to uncertain future events. ### Advisory Services Income The Company earns fees and commissions in connection with the placement and advisory services it provides and recognizes revenue when the Company has completed its contractual obligations and collection is reasonably assured. ## Success Fee Income Revenue is recognized when securities transactions are closed, securities are exchanged and all elements of contractual fulfillment are met. Success Fee revenues include fees earned from providing merger-and-acquisition and financial restructuring advisory services. Success Fees from securities related transactions are recognized when earned under the respective agreements. The Company earned a commission which was paid with securities in lieu of cash and the transaction was recorded at the time of closing. The related commission payable due to the registered representatives was recorded simultaneously as per their independent contractor agreement. The Income, expense, Commissions Receivable and Commissions Payable were recorded at the market value as of December 31, 2022. #### Client concentrations For the year ended December 31, 2022, theCompany had the following customers with respect to itsrevenues: | | | Accounts | |---------------|-------|------------| | | Sales | Receivable | | Customer1 | 17% | * | | Customer
2 | 11% | | | Customer
3 | 7% | * | | Customer
4 | 6% | * | | Customer
5 | 6% | * | | Customer
6 | 5% | * | {11}------------------------------------------------ #### Fair value of financial instruments In accordance with the reporting requirements of the Financial Accounting Standards Board (FASB) Accounting Standards Codification (ASC) Topic 825, *Financial Instruments,* the Company calculates the fair value of its assets and liabilities which qualify as financial instruments under this standard and includes this additional information in the notes to the financial statements when the fair value is different than the carrying value of those financial instruments. The Company does not have any assets or liabilities measured at fair value on a recurring or a non-recurring basis, consequently, the Company did not have any fair value adjustments for assets and liabilities measured at fair value at December 31, 2022, nor gains or losses reported in the statement of operations and member's capital that are attributable to the change in unrealized gains or losses relating to those assets and liabilitiesstill held during the year ended December 31, 2022. #### Fair value measurements ASC Topic 820, *Fair Value Measurement,* defines fair value, establishes a framework for measuring fair value in accordance with generally accepted accounting principles, and requires certain disclosures about fair value measurements. In general, fair values of financial instruments are based upon quoted market prices, where available. If such quoted market prices are not available, fair value is based upon internally developed models that primarily use, asinputs, observable market-based parameters. Valuation adjustments may be made to ensure that financial instruments are recorded at fair value. These adjustments may include amounts to reflect counterparty credit quality and the customer's creditworthiness, among other things, as well as unobservable parameters. Any such valuation adjustments are applied consistently over time. ## Recent accounting pronouncements During the year ended December 31, 2022 and through March 1, 2023, there were several new accounting pronouncements issued by the FASB. Each of these pronouncements, as applicable, has been or will be adopted by the Company. Management does not believe the adoption of any of these accounting pronouncements has had or will have a material impact on the Company's financial statements. ## Subsequent events In preparing the financial statements, the Company has reviewed, as determined necessary by the Company's management, events that have occurred after December 31, 2022, up until the issuance of the financial statements, which occurred on March 1, 2023. The securities referenced in Note 1 were sold on January 4, 2023 for \$238,676 (net of all fees). {12}------------------------------------------------ ## **2. INCOME TAXES:** The Company files its income tax return on a separate company basis. The Company records its federal and state tax liabilities in accordance with FASB Accounting Standards Codification Topic 740-10, "Accounting for Income Taxes". The Company uses the liability method of accounting for income taxes that requires the recognition of deferred tax assets and liabilities for the expected future tax consequences of events that have been recognized in the Company's financial statements. In estimating future tax consequences, all expected future events are considered other than enactment of changes in the tax law or rates. The Company provides a valuation allowance, if necessary, to reduce deferred tax assets to amounts that are not likely to be realized. ## **3. NET CAPITAL REQUIREMENTS:** The Company is subject to the Securities and Exchange Commission Uniform Net Capital Rule (SEC Rule 15c3-l), which requires the maintenance of minimum net capital and requires that the ratio of aggregate indebtedness to net capital, both as defined, shall not exceed 15 to 1 (and the rule of the "applicable" exchange also provides that equity capital may not be withdrawn or cash dividends paid if the resulting net capital ratio would exceed 10 to 1). At December 31, 2022, the Company was in compliance with \$308,321 of aggregate indebtedness and net capital of \$96,480. ## **4. RULE 15c3-3 EXEMPTION:** 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: (1) receiving transaction-based compensation for identifying potential merger and acquisition opportunities for clients, 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 PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception. {13}------------------------------------------------ # **HAMILTON CLARK SUSTAINABLE CAPITAL, INC. SCHEDULE I DECEMBER 31, 2022** | Net
capital
greater
of:
requirement,
the | | \$
20,555 | |-----------------------------------------------------------------------------------------|--------------|---------------| | of
aggregate
indebtedness
1/15% | \$
20,555 | | | requirement
Minimum
dollar | 5,000 | | | Net
capital | | 96,480 | | Excess
capital
net | | \$
75,925 | | Aggregate
indebtedness | | 308,321 | | of
aggregate
Ratio
indebtedness
to
net
capital | | 319.57% | | of
Ratio
subordinated
indebtedness
to
debt/equity
total | | | | | | | | Net
greater
of
of
or
capital
less
aggregate
indebtedness
10% | | | | of
net
capital
120%
required | | 65,648 | | | | | | assets
Total | | \$
573,838 | | Less:
total
liabilities | | 308,321 | | Net
worth | | 265,517 | | | | | | Deductions
from
and/or
charges
to
net
worth | | | | assets
Total
non-allowable | \$
99,295 | | | or
charges
Other
deductions | | | | Excess
Bond
Deductible
Fidelity | - | | | Total
from
net
worth
deductions | | 99,295 | | Net
capital
before
haircuts
on
securities
positions | | 166,222 | | certificates
Haircuts
of
deposit
and
on | | | | commercial
paper | - | | | U.S.
and
Canadian
government
obligations | - | | | Other
Securities | 36,118 | | | concentrations
Undue | 33,624 | | | | | | | Total
of
securities
haircuts | | 69,742.00 | | Net
capital | | \$
96,480 | There are no material differences between the amounts presented above and the amounts reported on the Company's FOCUS report as of December 31, 2022. {14}------------------------------------------------ *Your Vision Our Focus* ![](_page_14_Picture_1.jpeg) ## Report of Independent Registered Public Accounting Firm To the Stockholder of Hamilton Clark Sustainable Capital, Inc. We have reviewed management's statements, included in the accompanying Hamilton Clark Sustainable Capital, Inc. Exemption Report, in which (1) Hamilton Clark Sustainable Capital, Inc. does not claim an exemption under 17 C.F.R. §240.15c3-3 and Hamilton Clark Sustainable Capital, Inc. is filing an Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073, and as discussed in Q&A 8 of the related FAQ issued by the SEC staff. The Company limits its business activities exclusively to the private placement of debt and equity securities. (2) The Company is filing its 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: (1) receiving advisory and transaction-based compensation for institutional private placement and identifying potential merger and acquisition opportunities for clients and the Company, (2) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, (3) did not carry accounts of or for customers; and (4) did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception. Hamilton Clark Sustainable Capital, Inc. management is responsible for compliance with the exemption provisions and its statements. Our review was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included inquiries and other required procedures to obtain evidence about Hamilton Clark Sustainable Capital, Inc.'s compliance with the exemption provisions. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, we do not express such an opinion. Based on our review, we are not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based on the provisions set forth in paragraph (k) 17 C.F.R. §240. FN 74 of Rule 15c3-3 under the Securities Exchange Act of 1934. Dallas, Texas March 1, 2023 > Turner, Stone & Company, L L P Accountants and Consultants 12"00 Park Central Drive, Suite 1400 Dallas, Texas "5251 Telephone:9~2-239-1660/Facsimile: 9"2-239-1665 Toll Free: 8"-853-4195 Web site: tiunerstone.com ![](_page_14_Picture_10.jpeg) {15}------------------------------------------------ # **Hamilton Clark Sustainable Capital, Inc. 1701Pennsylvania Avenue NW, Suite 200 / Washington, DC 20006 202-461-2252** ## **Hamilton Clark Sustainable Capital, Inc. Assertions** **Hamilton Clark Sustainable Capital, Inc.** (the "Company") is a registered broker-dealersubject 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. § 240.1 7a-5(d)(l) and (4). To the best of its knowledge and belief, the Company states the following: (1) The Company is considered "Non-Covered Firm" exempt from 17 C.F.R. § 240.15c3-3, and is filing an Exemption Report relying on footnote 74 to SEC Release 34-70073. and as discussed in Q&A 8 of the related FAQ issued by the SEC staff. The Company limits its business activities exclusively to: (1) private placement of securities; and (2) investment banking and advisory services including the private placement of debt and equity securities. (2) The Company is filing this Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17C.F.R. § 240.17a-5 because the Company limits its business activities exclusively to: (1) receiving advisory and transaction-based compensation for institutional private placement and identifying potential merger and acquisition opportunities for clients, 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 PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception. #### **Hamilton Clark Sustainable Capital, Inc.** I,John J. McKenna,swear (or affirm) that, to my best knowledge and belief, this Exemption Report is true and correct. January 10, 2023 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.