# HAMILTON CLARK SUSTAINABLE CAPITAL, INC. X-17A-5 (2024-03-29) — Broker-dealer annual report

- Company: HAMILTON CLARK SUSTAINABLE CAPITAL, INC.
- Form: X-17A-5
- Filed: 2024-03-29
- Period: 2023-12-31
- Accession: 0000860034-24-000001
- 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: 202-461-2252
- 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/860034/000086003424000001/2023audithamilton-.pdf

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|                                                                                                                                                                                    | UNITED STATES<br>SECURITIES AND EXCHANGE<br>COMMISSION<br>Washington, D.C. 20549 |                                                       |                                                                                                               |  |  |  |
|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------|-------------------------------------------------------|---------------------------------------------------------------------------------------------------------------|--|--|--|
|                                                                                                                                                                                    |                                                                                  | Estimated average burden<br>hours per response:<br>12 |                                                                                                               |  |  |  |
|                                                                                                                                                                                    | ANNUAL<br>REPORTS                                                                |                                                       | SEC FILE NUMBER                                                                                               |  |  |  |
|                                                                                                                                                                                    | FORM<br>X-17A-5                                                                  |                                                       | 8-42236                                                                                                       |  |  |  |
|                                                                                                                                                                                    | PART<br>III                                                                      |                                                       |                                                                                                               |  |  |  |
|                                                                                                                                                                                    | FACING PAGE                                                                      |                                                       |                                                                                                               |  |  |  |
| Information Required Pursuant                                                                                                                                                      | to Rules 17a-5, 17a-12,and 18a-7                                                 |                                                       | under the Securities Exchange Act<br>of 1934                                                                  |  |  |  |
| FILING FOR THE PERIOD BEGINNING                                                                                                                                                    | 01/01/2023                                                                       |                                                       | AND ENDING 12/31/2023                                                                                         |  |  |  |
|                                                                                                                                                                                    | MM/DD/YY                                                                         |                                                       | MM/DD/YY                                                                                                      |  |  |  |
|                                                                                                                                                                                    | A. REGISTRANT IDENTIFICATION                                                     |                                                       |                                                                                                               |  |  |  |
| Hamilton<br>NAME OF FIRM:                                                                                                                                                          | Clark<br>Sustainable                                                             | Capital                                               | Inc<br>,                                                                                                      |  |  |  |
| TYPE OF REGISTRANT<br>(check all applicable<br>E Broker-dealer<br>Check here if respondent is also an OTC derivatives                                                              | boxes):<br>Security-based swap dealer<br>dealer                                  | Major security-based swap                             | participant                                                                                                   |  |  |  |
| ADDRESS OF PRINCIPAL PLACE                                                                                                                                                         | OF BUSINESS: (Do not<br>use a P.O. box no.)                                      |                                                       |                                                                                                               |  |  |  |
| 1701<br>Pennsylvania                                                                                                                                                               | Avenue<br>NW<br>STE                                                              | 200                                                   |                                                                                                               |  |  |  |
|                                                                                                                                                                                    | ,<br>(No. and Street)                                                            |                                                       |                                                                                                               |  |  |  |
| Washington                                                                                                                                                                         |                                                                                  |                                                       |                                                                                                               |  |  |  |
|                                                                                                                                                                                    | DC                                                                               |                                                       | 20006                                                                                                         |  |  |  |
| (City)                                                                                                                                                                             | (State)                                                                          |                                                       | (Zip Code)                                                                                                    |  |  |  |
| PERSON TO CONTACT WITH                                                                                                                                                             | REGARD TO THIS FILING                                                            |                                                       |                                                                                                               |  |  |  |
| John<br>J<br>McKenna                                                                                                                                                               | 202-461-2252                                                                     |                                                       | john.mckenna@hamiltonclark.com                                                                                |  |  |  |
| (Name)                                                                                                                                                                             | (Area Code -Telephone Number)<br>(Email Address)                                 |                                                       |                                                                                                               |  |  |  |
|                                                                                                                                                                                    | B. ACCOUNTANT IDENTIFICATION                                                     |                                                       |                                                                                                               |  |  |  |
| INDEPENDENT PUBLIC ACCOUNTANT                                                                                                                                                      | whose reports are contained                                                      | in this filing*                                       |                                                                                                               |  |  |  |
| Turner<br>Stone<br>&<br>,                                                                                                                                                          | Company<br>L<br>L<br>P<br>,                                                      |                                                       |                                                                                                               |  |  |  |
|                                                                                                                                                                                    | (Name-if individual, state last,first, and middle                                | name)                                                 |                                                                                                               |  |  |  |
| 12700 Park<br>Central<br>Drive,<br>STE                                                                                                                                             | Dallas<br>1400                                                                   | TX                                                    | 75251                                                                                                         |  |  |  |
| (Address)                                                                                                                                                                          | (City)                                                                           | (State)                                               | (Zip Code)                                                                                                    |  |  |  |
| 09/29/2003                                                                                                                                                                         |                                                                                  | 76                                                    |                                                                                                               |  |  |  |
| (Date of Registration with PCAOB)(if applicable)                                                                                                                                   |                                                                                  |                                                       | (PCAOB Registration Number,if applicable)                                                                     |  |  |  |
|                                                                                                                                                                                    | FOR OFFICIAL USE ONLY                                                            |                                                       |                                                                                                               |  |  |  |
| *<br>Claims for exemption from the requirement that the annual<br>accountant must be supported by a statement of facts and circumstances<br>CFR 240.17a-5(e)(l)(li),if applicable. |                                                                                  |                                                       | reports be covered by the reports of an independent public<br>relied on as the basis of the exemption. See 17 |  |  |  |

**Persons who are to respond to the collection of information contained in this form are not required to respond unless the form displays <sup>a</sup> currently valid OMB control number.**

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#### **OATH OR AFFIRMATION**

| <br>( | John J. McKenna                                                                                                                                                                          |                                                                              |                                                                           |  |  |  |  |
|-------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------|---------------------------------------------------------------------------|--|--|--|--|
|       | , swear (or affirm) that,to<br>the best of my knowledge<br>and belief,the<br>financial report pertaining<br>to the firm of Hamilton ClarkSustainable<br>Capital.Inc.<br>12/31<br>, as of |                                                                              |                                                                           |  |  |  |  |
|       | ,22023<br>,is true and correct. Ifurther<br>swear (or affirm) that<br>neither the company nor<br>any                                                                                     |                                                                              |                                                                           |  |  |  |  |
|       | officer,director,or<br>partner<br>,<br>as that<br>of                                                                                                                                     | equivalent person,as<br>the case may be,has                                  | any proprietary interest in<br>any account classified solely              |  |  |  |  |
|       | a customer.                                                                                                                                                                              |                                                                              |                                                                           |  |  |  |  |
|       | District                                                                                                                                                                                 | of Columbia:<br>SS                                                           |                                                                           |  |  |  |  |
|       |                                                                                                                                                                                          |                                                                              | Signature:                                                                |  |  |  |  |
|       | Sworn<br>to and                                                                                                                                                                          | subscribed<br>before<br>me on                                                |                                                                           |  |  |  |  |
|       | the<br>A<br>day                                                                                                                                                                          | }<br>of<br>\><br>*t<br>_                                                     | {<br>/<br>Title:<br>[ I                                                   |  |  |  |  |
| -     | UL                                                                                                                                                                                       |                                                                              | President ant/Chief Compliance Officer                                    |  |  |  |  |
|       | Neftary<br>Public<br>Notary Public's                                                                                                                                                     |                                                                              | \**<br>'*                                                                 |  |  |  |  |
|       | My Commission                                                                                                                                                                            | Signature<br>C<br>Expires<br>/1U / X 4                                       | (<br>i<br>•>1-9<br>-                                                      |  |  |  |  |
|       | This filing**<br>contains (check all applicable boxisjl                                                                                                                                  | ~                                                                            | t<br>Si                                                                   |  |  |  |  |
| S     | (a) Statement of financial<br>condition.                                                                                                                                                 |                                                                              |                                                                           |  |  |  |  |
|       | (b) Notes to consolidated                                                                                                                                                                | statement of financial condition.                                            |                                                                           |  |  |  |  |
| B     | (c) Statement of income                                                                                                                                                                  | (loss) or,if there is other<br>comprehensive income in the period(s)         | presented,a stateme                                                       |  |  |  |  |
| B     | comprehensive income (as defined                                                                                                                                                         | in § 210.1-02 of Regulation S-X).                                            |                                                                           |  |  |  |  |
| B     | (d) Statement of cash flows.                                                                                                                                                             |                                                                              |                                                                           |  |  |  |  |
|       | (e) Statement of changes in<br>stockholders'                                                                                                                                             | or partners'or sole proprietor's equity.                                     |                                                                           |  |  |  |  |
| B     | (f) Statement of changes in<br>(g) Notes to consolidated financial                                                                                                                       | liabilities subordinated to claims<br>of creditors.                          |                                                                           |  |  |  |  |
| H     | (h) Computation of net capital under                                                                                                                                                     | statements.                                                                  |                                                                           |  |  |  |  |
|       | (I) Computation of tangible                                                                                                                                                              | 17 CFR 240.15c3-lor 17 CFR 240.18a-l,as<br>net worth under 17 CFR 240.18a-2. | applicable.                                                               |  |  |  |  |
|       | (j) Computation for determination                                                                                                                                                        |                                                                              |                                                                           |  |  |  |  |
|       | (k) Computation for determination                                                                                                                                                        | of customer reserve requirements pursuant<br>of security-based swap reserve  | to Exhibit A to 17 CFR 240.15c3-3.                                        |  |  |  |  |
|       | Exhibit A to 17 CFR 240.18a-4,as                                                                                                                                                         | applicable.                                                                  | requirements pursuant to Exhibit B to 17<br>CFR 240.15c3-3 or             |  |  |  |  |
|       | (I) Computation for Determination                                                                                                                                                        | of PAB Requirements under Exhibit                                            | A to § 240.15c3-3.                                                        |  |  |  |  |
| B     | (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.                                                               |                                                                           |  |  |  |  |
| B     | (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<br>17                                      |  |  |  |  |
|       | CFR 240.15c3-3 or 17 CFR 240.18a-4,as<br>exist.                                                                                                                                          | applicable,if material differences exist,or                                  | a statement that no material differences                                  |  |  |  |  |
|       | (p) Summary of financial data                                                                                                                                                            | for subsidiaries not consolidated                                            |                                                                           |  |  |  |  |
| B     | (q) Oath or affirmation in accordance                                                                                                                                                    | with 17 CFR 240.17a-5,17                                                     | in the statement of financial condition.                                  |  |  |  |  |
|       | (r) Compliance report in accordance                                                                                                                                                      | with 17 CFR 240.17a-5 or 17 CFR 240.18a-7,as                                 | CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable.<br>applicable.        |  |  |  |  |
| B     | (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.                                                   |  |  |  |  |
| 8     | (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<br>17                                      |  |  |  |  |
| B     | CFR 240.17a-5 or 17 CFR 240.18a-7,as                                                                                                                                                     | applicable.                                                                  |                                                                           |  |  |  |  |
|       | (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<br>as applicable.                                                                                                                       |                                                                              | procedures,in accordance with 17 CFR 240.15c3-le<br>or 17 CFR 240.17a-12, |  |  |  |  |
|       | (y) Report describing any material                                                                                                                                                       | inadequacies found to exist or found                                         |                                                                           |  |  |  |  |
|       | a statement that no material inadequacies exist,under                                                                                                                                    | 17CFR 240.17a-12(k).                                                         | to have existed since the date of the previous<br>audit,or                |  |  |  |  |
|       | (z) Other:                                                                                                                                                                               |                                                                              |                                                                           |  |  |  |  |
|       | **To request confidential                                                                                                                                                                |                                                                              |                                                                           |  |  |  |  |
|       | treatment of<br>applicable.                                                                                                                                                              | certain portions of                                                          | this filing, see 17 CFR 240.17a-5(e)(3) or<br>17 CFR 240.18a-7(d)(2), as  |  |  |  |  |
|       |                                                                                                                                                                                          |                                                                              |                                                                           |  |  |  |  |

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Hamilton Clark Sustainable Capital, Inc.

Financial Statements

And

Report of Independent Registered Public Accounting Firm

For the Year Ended December 31, 2023

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### TABLE OF CONTENTS

| REPORT<br>INDEPENDENT<br>REGISTERED<br>OF<br>PUBLIC ACCOUNTING<br>FIRM<br>I |
|-----------------------------------------------------------------------------|
| STATEMENT<br>OF<br>FINANCIAL CONDITION<br>3                                 |
| 4<br>STATEMENT<br>OF<br>INCOME                                              |
| STOCKHOLDER'S<br>STATEMENT<br>OF<br>EQUITY<br>5                             |
| STATEMENT<br>OF<br>CASH FLOWS<br>6                                          |
| 7-11<br>TO<br>FINANCIAL STATEMENTS<br>NOTES                                 |
| SUPPLEMENTAL<br>INFORMATION<br>12                                           |
| SCHEDULE<br>13<br>I                                                         |
| REPORT OF<br>INDEPENDENT<br>REGISTERED<br>PUBLIC ACCOUNTING<br>FIRM<br>14   |
| EXEMPTION REPORT<br>15                                                      |

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![](_page_4_Picture_0.jpeg)

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## **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, 2023, and the related statements of income and stockholder's equity and cash flows for the year then ended, and the related notes(collectively referred to asthe "financialstatements"). 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, 2023, 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 orfraud. Our audit included performing proceduresto assessthe 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.

Turner,Stone & Company, L.L.P. Accountants and Consultants <sup>12700</sup> Park Central Drive,Suite <sup>1400</sup> Dallas,Texas <sup>75251</sup> Telephone972-239-1660/Facsimile:972-219-1665 Toll Free:877-853-4195 Web site:tumerstone.com

![](_page_4_Picture_10.jpeg)

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#### *Supplemental Information*

The supplemental information contained on Schedule 1 has been subjected to audit procedures performed in conjunction with the audit of Hamilton Clark Sustainable Capital, Inc.'s financial statements. Schedule <sup>I</sup> is the responsibility of Hamilton Clark Sustainable Capital, Inc. 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 1, including its form and content, is presented in conformity with 17 C.F.R. §240.17a-5. In our opinion, Schedule <sup>I</sup> is fairly stated, in all material respects, in relation to the financial statements as a whole.

*" Jumtr.* \$ *Qmfmy.*

We have served as Hamilton Clark Sustainable Capital, Inc.'s auditorsince 2019.

Dallas, Texas March 29, 2024

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# HAMILTON CLARK SUSTAINABLE CAPITAL, INC. STATEMENT OF FINANCIAL CONDITION **DECEMBER 31, 2023**

### Assets

Current assets:

| Cash                                                                                               | 229,595<br>\$ |
|----------------------------------------------------------------------------------------------------|---------------|
| receivable,<br>\$52,500<br>Accounts<br>of<br>accounts<br>of<br>net<br>allowance<br>for<br>doubtful | 192,302       |
| Brokerage<br>account                                                                               | 1,002         |
| Prepaid<br>expense                                                                                 | 49,644        |
| Deposits                                                                                           | 568           |
| assets<br>Total<br>current                                                                         | 473,111       |
| cost:<br>equipment,<br>Furniture,<br>at<br>fixtures<br>and                                         |               |
| and<br>equipment<br>Furniture                                                                      | 13,825        |
| Less<br>depreciation<br>and<br>accumulated<br>ammortization                                        | (11,094)      |
| furniture,<br>equipment,<br>Total<br>and<br>fixtures<br>net                                        | 2,731         |
| Intangible assets,<br>at<br>net book value:                                                        |               |
| Capitalized<br>website<br>design                                                                   | 6,350         |
| Less<br>amortization                                                                               | (6350)        |
| design,<br>Total<br>capitalized<br>website<br>net                                                  |               |
| assets<br>Total                                                                                    | 475,842<br>S  |
| Stockholder's<br>Equity<br>Liabilities and                                                         |               |
| liabilities:<br>Current                                                                            |               |
| accrued<br>expenses<br>Accounts<br>payable<br>and                                                  | \$<br>191,400 |
| Deferred<br>revenue<br>and<br>expense<br>related                                                   | 6,125         |
| tax<br>Federal<br>income<br>payable                                                                | 4,115         |
| Deferred<br>tax<br>liability                                                                       | 559           |
| Total current liabilities                                                                          | 202,199       |
| Stockholder's<br>:<br>equity                                                                       |               |
| shares;<br>(\$0.01<br>value,<br>3,000<br>3,000<br>stock<br>par<br>Common<br>authorized<br>issued   | 1             |
| 31,<br>as<br>2023)<br>and<br>shares<br>of<br>December<br>outstanding                               |               |
| paid-in<br>capital<br>Additional                                                                   | 324,704       |
| Accumulated<br>deficit                                                                             | (51,062)      |
| Totalstockholder's<br>equity                                                                       | 273,643       |
| stockholder's<br>Total<br>liabilities and<br>equity                                                | \$<br>475,842 |

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### **HAMILTON C LARK SUSTAINABLE CAPITAL. INC. STATEMENT OF INCOME FOR THE YEAR ENDED DECEMBER 31, 2023**

| Revenues                                                          |                 |
|-------------------------------------------------------------------|-----------------|
| success<br>fees<br>and<br>Advisory                                | \$<br>3,849,973 |
| expenses<br>Reimbursed                                            | 157,075         |
| Total<br>revenues                                                 | 4,007,048       |
|                                                                   |                 |
| expenses:<br>Costs<br>and                                         |                 |
| Travel<br>and<br>entertainment                                    | 50,909          |
| and<br>Salaries<br>benefits                                       | 823,369         |
| fees<br>Independent<br>contractors                                | 2,594,130       |
| General<br>and<br>administrative                                  | 196,515         |
| fees<br>Legal<br>professional<br>and                              | 320,233         |
| and<br>expense<br>Depreciation<br>amortization                    | 3,046           |
| asset<br>Loss<br>disposal<br>of<br>on                             | 1,377           |
| Property<br>tax<br>expense                                        | 1 ,650          |
| Total<br>costs<br>and<br>expenses                                 | 3,991,229       |
| Net<br>operating<br>profit                                        | 15,819          |
| Other<br>(expense)<br>income                                      |                 |
| Interest<br>income                                                | 2               |
| Total<br>other<br>income                                          | 2               |
| before<br>provision (benefit)<br>Income<br>for<br>income<br>taxes | 15,821          |
| for<br>taxes<br>Provision<br>(benefit)<br>income                  |                 |
| expense,<br>Federal<br>tax<br>current<br>income                   | 2,714           |
| benefit,<br>deferred<br>Federal<br>tax<br>income                  | (343)           |
| State<br>tax<br>expense                                           | 5,323           |
| Total<br>for<br>taxes<br>provison<br>income                       | 7,694           |
| Net<br>income                                                     | \$<br>8,127     |

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# **HAMILTON CLARK SUSTAINABLE CAPITAL, INC. STATEMENT OF STOCKHOLDER'S EQUITY DECEMBER 31, 2023**

|                                          | Shares | Pat<br>Value |   | Additional<br>Paid<br>in<br>Capital |         | Accumulated<br>Deficit |          | Total |         |
|------------------------------------------|--------|--------------|---|-------------------------------------|---------|------------------------|----------|-------|---------|
| 31,<br>Balance<br>at<br>December<br>2022 | 3,000  | \$           | 1 | \$                                  | 324,704 | \$                     | (59,189) | \$    | 265,516 |
| Net<br>income                            |        |              |   |                                     |         |                        | 8,127    |       | 8,127   |
| 31,<br>at<br>December<br>Balance<br>2023 | 3,000  | S            | 1 | S                                   | 324,704 | \$                     | (51,062) | \$    | 273,643 |

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## **HAMILTON Cl .ARK SUSTAINABLE CAPITAL, INC. STATEM ENT OF CASH FLOWS FOR THE YEAR ENDED DECEMBER 31, 2023**

| OPERATING<br>ACTIVITIES                                      |               |
|--------------------------------------------------------------|---------------|
| Net<br>income                                                | \$<br>8,127   |
| Adjustments<br>to<br>reconcile<br>net<br>income              |               |
| by operations:<br>to<br>net<br>cash<br>provided              |               |
| expense<br>Depreciation<br>and<br>amortization               | 3,046         |
| asset<br>Loss<br>on<br>disposal<br>of                        | 1,377         |
| for<br>expense<br>Provision<br>bad<br>debt                   | 52,500        |
| Deferred<br>tax<br>benefit                                   | (343)         |
| Assets<br>Changes<br>in Operating<br>and<br>Liabilities      |               |
| Accounts<br>receivable                                       | (116,793)     |
| Stock                                                        | 240,785       |
| Brokerage<br>account                                         | ( 1 ,002)     |
| Prepaid<br>expense                                           | (9,181)       |
| Accounts<br>and<br>accrued<br>expenses<br>payable            | 109,415       |
| Tax<br>payable                                               | (4,614)       |
| Commissions<br>payable                                       | (216,706)     |
| Deferred<br>revenue<br>and<br>expense<br>related             | 6,125         |
| cash<br>Net<br>by Operating<br>Activities<br>provided        | 72,736        |
| ACTIVITIES<br>INVESTING                                      |               |
| furniture,<br>Purchase<br>of<br>and<br>fixtures<br>equipment | (2,649)       |
| cash<br>used<br>Net<br>in Investing<br>Activities            | ( 2,649)      |
| FINANCING<br>ACTIVITIES                                      |               |
| cash<br>Net<br>increase                                      | 70,087        |
| Cash<br>at<br>of<br>year<br>beginning                        | 159,508       |
| Cash<br>at<br>end<br>of<br>year                              | \$<br>229,595 |
| cash<br>of<br>Supplemental<br>disclosure<br>flow information |               |
| Interest<br>paid                                             | \$            |
| tax<br>Income<br>paid                                        | \$<br>7,328   |

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# <sup>1</sup>**.** 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 (U.S. GAAP) 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 primarily in one financial institution. At December 31, 2023, the Federal Deposit Insurance Corporation (FDIC) provided insurance coverage of up to \$250,000, per depositor, per institution. At December 31, 2023, 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, 2023, there was \$52,500 of allowance for doubtful accounts.

### Furniture,fixtures and equipment

Furniture,fixtures and equipment are stated at cost less accumulated depreciation.Depreciation offurniture, fixtures and equipment is being provided using the straight-line method for financial reporting purposes over estimated useful lives of five to seven years.

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### Revenue recognition

The Company recognizes revenues in accordance with Financial Accounting Standards Board (FASB) Accounting Standards Codification (ASC) Topic 606, Revenue from Contracts with Customers. Under this guidance, the Company recognizes revenue from sales when performance obligations under the terms of a contract with a customer are satisfied by analyzing exchanges with its customers using a five-step approach (1) identify the contract(s) with a customer; (2) identify the performance obligation in the contracts); (3) determine the transaction price; (4) allocate the transaction price to the performance obligation(s) in the contracts); and (5) recognize the revenue when (or as) the Company satisfies a performance obligation. Such revenue is recorded at the amount of consideration expected to be received in exchange forthe transfer of goods and services to its customers.

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. The Company earns consulting fees (comprised of advisory services and success fees as further described in the following paragraphs). The Company's contracts typically do not have multiple performance obligations or any variable consideration.

#### *Advisory Services Income*

The Company earns fees and commissions in connection with the placement and advisory services it provides (\$2,045,957 during 2023) and recognizes revenue when the Company has completed its contractual obligations and collection is reasonably assured.

#### *Success Fee Income*

Revenue isrecognized 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-andacquisition and financial restructuring advisory services. Success Fees from securities related transactions (\$1,804,016 during 2023) are recognized when earned under the respective agreements.

#### Deferred revenue

In 2023 the Company reviewed its policies for revenue recognition. In discussions with the managing directors, it was determined that invoices were prepared in advance of the services provided in accordance within the terms of the engagement agreements. As such, the Company started to record the income on a weekly basis to match the performance of the services.

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#### Client concentrations

For the year ended December 31, 2023, the Company had the following customers with respect to its revenue concentrations as well as accounts receivable concentrations as of December 31, 2023.

|            |          | Accounts   |
|------------|----------|------------|
|            | Revenues | Receivable |
| Customer 1 | 45%      | *          |
| Customer 2 | *        | 35%        |
| Customer 3 | *        | 10%        |
| Customer 4 | *        | 50%        |

**" amounts less than 10%**

#### 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 ASC 740, *Accounting for Income Taxes.* The Company uses the liability method of accounting for income taxes that requires the recognition of deferred tax assets and liabilitiesfor the expected future tax consequences of eventsthat have been recognized in the Company'sfinancial 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 assetsto amountsthat are not likely to be realized. As of December 31, 2023, a valuation allowance was not necessary or recorded.

#### Fair value of financial instruments

In accordance with the reporting requirements of the (FASB) (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, 2023, 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 liabilities still held during the year ended December 31, 2023. The estimated fair value of cash, accounts receivable and accounts payable approximate their canying amounts due to the nature and short maturity of these instruments.

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#### Fair value measurements

ASC Topic 820, *Fair Value Measurement,* defines fair value, establishes a framework for measuring fair value in accordance with U.S. GAAP, 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, as inputs, 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.

The three levels of the fair value hierarchy under FASB ASC 820 are described below:

Level 1 - Inputs to the valuation methodology are unadjusted quoted prices for identical assets or liabilities in active markets that the Plan has the ability to access.

## Level 2 - Inputs to the valuation methodology include:

- 1) Quoted pricesfor similar assets or liabilities in active markets
- 2) Quoted pricesfor identical orsimilar assets or liabilities in inactive markets
- 3) Inputs other than quoted prices that are observable for the asset or liability
- 4) Inputs that are derived principally from, or corroborated by, observable market data by correlation or other means

If the asset or liability has a specified (contractual) term, the Level 2 input must be observable for substantially the full term of the asset or liability.

Level 3 - Inputs to the valuation methodology are unobservable and significant to the fair value measurement.

### Recent accounting pronouncements

During the year ended December 31, 2023 and through March 29, 2024, 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.

In December 2023, the FASB issued Accounting Standards Update 2023-09, Income Taxes (Topic 740), to enhance transparency and decision usefulness of income tax disclosures.The pronouncement is effective for fiscal years beginning after December 15, 2024, and management does not expect a material impact to our disclosures as a result of adoption.

### 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, 2023, up until the issuance of the financial statements, which occurred on March 29, 2024 and noted no items requiring an adjustment to or disclose in the accompanying financial statements and notes to the financial statements.

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# **<sup>2</sup>.** INCOME TAXES:

The Company had \$559 of deferred tax liabilities as of December 31, 2023 related to temporary differences in depreciation of furniture,fixtures and equipmentfor financial reporting and federal income tax reporting purposes. The Company's effective tax rate for the year ended December 31, 2023 exceeded the expected tax rate due to certain nondeductible business expenses for federal income tax reporting purposes.

# 3. COMMITMENTS AND CONTINGENCIES:

The Company is party to an operating lease for their corporate office on a month-to-month basis. For the year ended December 31, 2023 rent expense was \$6,511.

# 4. NET CAPITAL REQUIREMENTS:

The Company is subject to the SEC 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 <sup>1</sup> (and the rule ofthe "applicable" exchange also providesthat equity capital may not be withdrawn or cash dividends paid if the resulting net capital ratio would exceed 10 to 1). At December 31, 2023, the Company was in compliance with \$196,074 of aggregate indebtedness and net capital of \$149,899.

# 5. 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.

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### SUPPLEMENTAL INFORMATION

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# HAMILTON CLARK SUSTAINABLE CAPITAL.INC. SCHEDULE I DECEMBER 31, 2023

| requirement,<br>of:<br>Net<br>capital<br>greater<br>the                                 |                       | S  | 13,072  |
|-----------------------------------------------------------------------------------------|-----------------------|----|---------|
| 1/15%<br>of<br>aggregate<br>indebtedness<br>Minimum dollar requirement                  | \$<br>13,072<br>5,000 |    |         |
| Net<br>capital                                                                          |                       |    | 149,899 |
| Excess<br>capital<br>net                                                                |                       | \$ | 136,827 |
| Aggregate<br>indebtedness                                                               |                       |    | 196,074 |
| of<br>net<br>Ratio<br>aggregate<br>indebtedness<br>to<br>capital                        |                       |    | 130.80% |
| of<br>to<br>debt/equity<br>Ratio<br>subordinated<br>indebtedness<br>total               |                       |    |         |
| Net<br>greater<br>10%<br>capital<br>less<br>of<br>of<br>aggregate<br>or<br>indebtedness |                       |    |         |
| 120%<br>of<br>required<br>net<br>capital                                                |                       |    | 130,292 |
|                                                                                         |                       |    |         |
| assets<br>Total                                                                         |                       | \$ | 475,842 |
| Less:Total<br>liabilities                                                               |                       |    | 202,199 |
| Less:<br>Deferred<br>revenue                                                            |                       |    | 6,125   |
| Aggregate<br>Indebtedness                                                               |                       |    | 196,074 |
| Net<br>worth                                                                            |                       |    | 273,643 |
| and/or<br>from<br>charges<br>to<br>worth<br>Deductions<br>net                           |                       |    |         |
| assets<br>Total<br>non-allowable                                                        | \$<br>123,744         |    |         |
| Other<br>deductions<br>or<br>charges                                                    |                       |    |         |
| Excess<br>Fidelity Bond<br>Deductible                                                   |                       |    |         |
| worth<br>Total<br>deductions<br>from<br>net                                             |                       |    | 123,744 |
| Net<br>capital<br>before<br>on<br>securities<br>haircuts<br>positions                   |                       |    | 149,899 |
| Haircuts<br>on<br>certificates<br>of<br>and<br>deposit                                  |                       |    |         |
| commercial<br>paper                                                                     |                       |    |         |
| Other<br>Securities                                                                     |                       |    |         |
| concentrations<br>Undue                                                                 |                       |    |         |
| Total<br>haircuts<br>of<br>securities                                                   |                       |    |         |
| Net<br>capital                                                                          |                       | \$ | 149,899 |

There are no material differences between the amounts presented above and the amounts reported on the Company's FOCUS report as of December 31, 2023.

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*Your Vision Our Focus*

![](_page_17_Picture_1.jpeg)

#### Report of Independent Registered Public Accounting Firm on Review of Statement of Exemption of Broker Dealer

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 SustainableCapital, Inc. does not claim an exemption under paragraph (k) of <sup>17</sup> C.F.R. §15c3-3 and (2) Hamilton Clark Sustainable Capital, Inc. is filing an 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. Hamilton Clark Sustainable Capital, Inc.'s 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 isthe 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'sstatements referred to above for them to be fairly stated, in all material respects, based on the provisions set forth in Rule 15c3-3 under the Securities Exchange Act of 1934 and Footnote 74 of the SEC Release No. 34-70073.

*Justus. JJfctu- \$ JJwifrwfr.*

Dallas, Texas March 29, 2024

> Turner, Stone & Company, L.L.P. Accountants and Consultants **12700** ParkCcottal **<sup>I</sup> )ri \ c, Suite 1400** Dallas,Texas 75251 Telephone:972-239-1660/Facsimile: 972-239-1665 Toll Free: 877-853-4195 Web site:tumerstone.com

![](_page_17_Picture_10.jpeg)

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## **Hamilton Clark Sustainable Capital, Inc.** <sup>1701</sup> Pennsylvania Avenue NW,Suite <sup>200</sup> / Washington, DC <sup>20006</sup> 202-461-2252

## Hamilton Clark Sustainable Capital, Inc. Assertions

Hamilton Clark SustainableCapital,Inc. (the "Company")is <sup>a</sup> registered broker-dealersubject to Rule <sup>17</sup>a-<sup>5</sup> promulgated by the Securities and Exchange Commission (<sup>17</sup> <sup>C</sup>.F.R. §240.17<sup>a</sup>-5, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by <sup>17</sup> <sup>C</sup>.F.R. § 240.17<sup>a</sup>-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 <sup>17</sup> <sup>C</sup>.F.R. § 240.15c3-3, and is filing an Exemption Report relying on footnote <sup>74</sup> to SEC Release <sup>34</sup>-70073, and as discussed in <sup>Q</sup>&<sup>A</sup> <sup>8</sup> of the related FAQ issued by the SEC staff. The Company limits its business activities exclusively to: (1) private <sup>p</sup>lacement of securities; and (2) investment banking and advisory services including the private <sup>p</sup>lacement of debt and equity securities.

(2) The Company isfiling this Exemption Report relying on Footnote <sup>74</sup> of the SEC Release No. <sup>34</sup>-<sup>70073</sup> adopting amendmentsto <sup>17</sup>C.F.R. §240.17<sup>a</sup>-<sup>5</sup> because the Company limitsits business activities exclusively to: (1) receiving advisory and transaction-based compensation for institutional private <sup>p</sup>lacement 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 <sup>15</sup>c3-3) throughout the most recent fiscal year without exception.

### Hamilton Clark Sustainable Capital, Inc.

<sup>I</sup>,John <sup>J</sup>. McKenna,swear (or affirm) that,to my best knowledge and belief,this Exemption Report is true and correct.

President anty Chief Compliance Officer John <sup>J</sup>.

January 24, 2024


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