# FINTRUST BROKERAGE SERVICES, LLC X-17A-5 (2021-02-24) — Broker-dealer annual report

- Company: FINTRUST BROKERAGE SERVICES, LLC
- Form: X-17A-5
- Filed: 2021-02-24
- Period: 2020-12-31
- Accession: 0001020141-21-000002
- CIK: 1020141
- File #: 8-49514
- Material weakness: No
- Auditor: GOLDMAN & COMPANY CPAS PC
- Auditor location: MARIETTA, GA
- Contact: ALLEN GILLESPIE
- Phone: 864-288-2849
- Signed by: ALLEN GILLESPIE (PRINCIPAL)

Original filing: https://www.sec.gov/Archives/edgar/data/1020141/000102014121000002/fintrust2020audit.pdf

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

# **ANNUAL AUDITED REPORT FORM X-17 A·5 PART Ill**

OMB APPROVAL OMB Numbar: 3235·0123 Expires: August31,2020 Estimated average burde<sup>n</sup> hours oer response •.••.• 12.00

> SEC FILE NUMBER 8-49514

FACING PAGE

Information Requir<sup>e</sup>d of Brok<sup>e</sup>rs and Deal<sup>e</sup>rs Pursuant to Section 17 of th<sup>e</sup> Secu<sup>r</sup>iti<sup>e</sup>s Ex<sup>c</sup>hange Act of 1934 and Rule 17<sup>a</sup>-S Th<sup>e</sup>reund<sup>e</sup><sup>r</sup>

| REPORT FOR THE PERIOD BEGINNING 1                                                         | /1<br>/2020<br>AND ENDING �12/�3�1<br>/2�02�0<br>�����              |                  |                                 |
|-------------------------------------------------------------------------------------------|---------------------------------------------------------------------|------------------|---------------------------------|
|                                                                                           | MM/DDIYY                                                            |                  | MM/DD/YY                        |
|                                                                                           | A. REGISTRANT IDENTIFICATION                                        |                  |                                 |
| NAME OF BROKER-DEALER: FINTRUST                                                           | BROKERAGE                                                           | SERVICES!<br>LLC | OFFICIAL USE ONLY               |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box. No.)                        |                                                                     | FIRMI.D.NO.      |                                 |
| 124<br>VERDAE<br>BL.VD,<br>SUITE                                                          | 504                                                                 |                  |                                 |
|                                                                                           | (No. and Street)                                                    |                  |                                 |
| GREENVILLE                                                                                | SC                                                                  |                  | 29607                           |
| (City)                                                                                    | (Slate)                                                             |                  | (Zip Code)                      |
| NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT<br>All.EN GUESPIE |                                                                     |                  | 864·288·2849                    |
|                                                                                           |                                                                     |                  | {Area Code - Telephone N'umbcr) |
|                                                                                           | B.ACCOUNTANTIDENTIFICATION                                          |                  |                                 |
| INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report*                  |                                                                     |                  |                                 |
| GOLDMAN<br>&<br>COMPANY                                                                   | CPAS<br>PC                                                          |                  |                                 |
|                                                                                           | (Name -ifindlvid11al. slate last, first. mldclle mrmr,)             |                  |                                 |
| ROSWELL<br>3535<br>RD                                                                     | MARIETTA                                                            | GA               | 30062                           |
| (Address)                                                                                 | (Ciry)                                                              | (Stato)          | (Zip Code)                      |
| CHECK ONE:                                                                                |                                                                     |                  |                                 |
| Cerlified Public<br>Accountant                                                            |                                                                     |                  |                                 |
| Public Accountant                                                                         |                                                                     |                  |                                 |
| B                                                                                         | Accountant not resident in United States or any of its possessions. |                  |                                 |
|                                                                                           | FOR OFFICIAL USE ONLY                                               |                  |                                 |
|                                                                                           |                                                                     |                  |                                 |
|                                                                                           |                                                                     |                  |                                 |

*\*Claims for exemption from the requirement that the annual report be covered by the opinion of an independent public accountan<sup>t</sup> <sup>m</sup>ust be supported by a statement of facts mid circumstances relied on as the basis fol' the exemption. See Section 240.17<sup>a</sup>-5(e)(2)* 

> Potential persons who are to respond to the collectlon of information contained In this form are not required to respond <sup>u</sup>nless the rerm displays a currently valid OMB control number.

SEC 1410 {06-02)

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### OATH OR AFFmMATION

|             | I, ALLEN GILLESPIE<br>, swear (or affirm) that, to the best of                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |  |  |  |  |
|-------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|--|--|--|
| FINTR ��    | my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of<br>US�<br>T B�<br>RO�<br>KE�<br>RA�<br>GE �<br>S�<br>ER�<br>VIC�<br>ES�<br>, L�<br>LC ����������������������������·                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |  |  |  |  |
| �           | as<br>of DECEMBER 31<br>2020<br>are true and correct. I further swear ( or affirm.) that                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |  |  |  |  |
|             | neither the company nor any partner, proprietor, principal officer or director has any proprietary interest in any account                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |  |  |  |  |
|             | classified solely as that of a customer, except as follows:                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |  |  |  |  |
|             |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |  |  |  |  |
|             | PRINCIPAL                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |  |  |  |  |
|             | Title                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |  |  |  |  |
| D<br>0<br>§ | t6<br>AAuL<br>�<br>�<br>ublic<br>Notary P<br>This report"* contains (check all applicable boxes):<br>(a) Facing Page.<br>(b) Statement of Financial Condition.<br>(c) Statement of Income (Loss).<br>(d) Statement of Changes in Financial Condition.<br>(e) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors' Capital.<br>(f) Statement of Changes in Liabilities Subordinated to Claims of Creditors.<br>(g) Computation of Net Capital.<br>(h) Computation for Determination of Reserve Requirements Pursuant to Rule l 5c3-3.<br>(i) Information Relating to the Possession or Control Requirements Under Rule l Sc3-3.<br>G) A Reconciliation, including appropriate<br>explanation of the Computation ofNet Capital Under Rule 15c3-l and the<br>Computation for Determination of the Reserve Requirements Under Exhibit A of Rule 15c3-3.<br>(k.) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of<br>consolidation.<br>(I} An Oath or Affirmation.<br>(m) A copy of the SIPC Supplemental Report.<br>(n) A report describing any material inadequacies found to exist or found to have existed since the date of the previous audit. |  |  |  |  |
|             | ••For conditions of confidential treatment of certain portions of this filing, see section 240.17a-5(e)(3).                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |  |  |  |  |
|             |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |  |  |  |  |

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(A LIMITED LIABILITY COMPANY)

FINANCIAL STATEMENTS FOR THE YEAR ENDED DECEMBER 31, 2020 AND REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

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(A LIMITED LIABILITY COMPANY)

### **Table of Contents**

| Independent Registered Auditor's Report<br>1 ·                                                               |
|--------------------------------------------------------------------------------------------------------------|
| Financial Statements                                                                                         |
| Statement of Financial Condition<br>2                                                                        |
| Statement of Operations<br>3                                                                                 |
| Statement of Changes in Member's Equity<br>4                                                                 |
| Statement of Changes in Subordinated Liabilities<br>5                                                        |
| Statement of Cash Flows<br>6                                                                                 |
| Notes to Financial Statements<br>7                                                                           |
| Supplementary Schedule I - Computation of Net Capital<br>1 O                                                 |
| Supplementary Schedules II and Ill.<br>11                                                                    |
| Independent Accountant's Report on Exemption<br>12                                                           |
| 13<br>Exemption Report                                                                                       |
| Independent Accountant's Report on Agreed Upon<br>Procedures Related to SIPC Assessment Reconciliation<br>14 |
| SIPC General Assessment Reconciliation Form SIPC-7<br>15                                                     |

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### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Member of Fintrust Brokerage Services, LLC

### Opinion on the Financial Statements

E�. We have audited the accompanying statement of financial condition ofFintrust Brokerage Services, LLC as of <sup>&</sup>lt; December 31, 2020 the related statements of operations, changes in member's equity, statement of changes in £l.. subordinated liabilities, cash flows for the year then ended, and the related notes and schedules 1, 2 and 3u � (collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in O all material respects, the financial position of Fintrust Brokerage Services, LLC as of December 31, 2020, 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. <sup>P</sup> Basis for Opinion O oij

These financial statements are the responsibility of Fintrust Brokerage Services, LLC 's management. Our responsibility is to express an opinion on Fintrust Brokerage Services, LLC's financial statements based on our ufJ 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 the company 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.

# Auditor's Report on Supplemental Information

The Schedule's 1- Computation of Net Capital Under SEC Rule 15c3-l, Schedule 2-Computation for Determination of Reserve Requirements Pursuant to SEC Rule 15c3-3 (exemption) and Schedule 3- Information Relating to Possession or Control Requirements Pursuant to SEC Rule 1Sc3-3 (exemption) have been subjected to audit procedures performed in conjunction with the audit of Fintrust Brokerage Services, LLC's financial statements. The supplemental information is the responsibility ofFintrust Brokerage Services, LLC's management. Our audit procedures included determining whether the supplemental information 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 in formation presented in the supplemental information, In forming our opinion on the supplemental information, we evaluated whether the supplemental information, including its form and content, is presented in conformity with 17 C.F.R. §240.17a-5. In our opinion, the schedule's 1, 2. and 3 are fairly stated, in all material respects, in relation to the financial statements as a whole.

We have served as the Company's auditor since 2015.

Goldman & Company, CPA's, P.C. Marietta, Georgia February 25, 2021

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(A LIMITED LIABILITY COMPANY)

### STATEMENT OF FINANCIAL CONDITION DECEMBER 31, 2020

### **ASSETS**

| ASSETS:                         |     |         |
|---------------------------------|-----|---------|
| Cash and cash equivalents       | \$  | 155,451 |
| Deposit with clearing broker    |     | 75,000  |
| Receivable with clearing broker |     | 25,219  |
| Investment                      |     | 40,000  |
| NFS Account Balances            |     | 3,465   |
| Accounts receivable             |     | 10,000  |
| Due from parent                 |     | 506,181 |
| Prepaid expenses                |     | 13,633  |
| CRD Deposit                     |     | 157     |
| Total assets                    | I   | 829,107 |
|                                 |     |         |
| TOTAL                           | I\$ | 829,107 |
|                                 |     |         |

### **LIABILITIES AND MEMBER'S EQUITY**

| LIABILITIES                                                |                  |
|------------------------------------------------------------|------------------|
| Due to clearing broker                                     | 17,619           |
| Payroll payable<br>Subordinated loan - secured demand note | 19,439<br>40,000 |
|                                                            |                  |
| Total liabilities                                          | 77,058<br>I      |
| MEMBER'S EQUITY                                            | 752,049<br>I     |
| TOTAL                                                      | I\$<br>829,107   |
|                                                            |                  |

The accompanying notes are an integral part of these financial statements.

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(A LIMITED LIABILITY COMPANY)

### STATEMENT OF OPERATIONS FOR THE YEAR ENDED DECEMBER 31, 2020

| COMMISSION AND FEE REVENUE               | \$<br>1,534,332<br>I |
|------------------------------------------|----------------------|
| OPERATING EXPENSES:                      |                      |
| Compensation and benefits                | 835,735              |
| Rent                                     | 56,852               |
| Regulatory licensing and compliance fees | 27,667               |
| Legal and professional fees              | 92,185               |
| Travel                                   | 6,230                |
| Computer and technology                  | 78,315               |
| Meals and entertainment                  | 136                  |
| Telephone                                | 6,209                |
| Taxes and licenses                       | 5,416                |
| Insurance                                | 11,757               |
| Clearing expense                         | 142,896              |
| Depreciation                             | 709                  |
| Other                                    | 110,222              |
|                                          |                      |
| Total expenses                           | I\$<br>1,374,329     |
|                                          |                      |
| NET INCOME                               | I\$<br>160,003       |
|                                          |                      |

The accompanying notes are an integral part of these financial sta'ements. 3

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(A LIMITED LIABILITY COMPANY)

### STATEMENT OF CHANGES IN MEMBER'S EQUITY FOR THE YEAR ENDED DECEMBER 31, 2020

| MEMBER'S EQUITY, JANUARY 1   | \$  | 592,046 |
|------------------------------|-----|---------|
| Member's Contributions       |     | 0       |
| Member's Distributions       |     | 0       |
| Net Income                   |     | 160,003 |
| MEMBER'S EQUITY, DECEMBER 31 | I\$ | 752,049 |
|                              |     |         |

The accompanying notes are an integral part of these financial statements.

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(A LIMITED LIABILITY COMPANY)

### STATEMENT OF CHANGES IN LIABILITIES SUBORDINATED TO CLAIMS OF GENERAL CREDITORS FOR THE YEAR ENDED DECEMBER 31, 2020

| SUBORDINATED LOANS, JANUARY 1   | \$  | 40,000 |
|---------------------------------|-----|--------|
| SUBORDINATED LOANS, DECEMBER 31 | I\$ | 40,000 |
|                                 |     |        |

The accompanying notes are an integral part of these financial statements. 5

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(A LIMITED LIABILITY COMPANY)

### STATEMENT OF CASH FLOWS FOR THE YEAR ENDED DECEMBER 31, 2020

| OPERATING ACTIVITIES:<br>Net profit                                             | \$  | 160,003   |
|---------------------------------------------------------------------------------|-----|-----------|
| Adjustments to reconcile net income to net cash<br>used by operating activities |     |           |
| Increase in accounts payable and accrued expenses                               |     | (584)     |
| Decrease in clearing broker receivable                                          |     | (4,280)   |
| Increase in due from parent                                                     |     | (146,046) |
| Decrease in prepaid expenses                                                    |     | 205       |
| Increase in payroll payable                                                     |     | (36,645)  |
| Decrease in clearing broker accounts                                            |     | 7,127     |
| Net cash used by operating activities                                           | I   | (20,220)  |
| NET DECREASE IN CASH AND CASH EQUIVALENTS                                       | I   | (20,220)  |
| CASH AND CASH EQUIVALENTS AT BEGINNING OF YEAR                                  |     | 175,671   |
| CASH AND CASH EQUIVALENTS AT END OF YEAR                                        | I\$ | 155,451   |

The accompanying notes are an Integral part of these financial statements.

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NOTES TO FINANCIAL STATEMENTS DECEMBER 31, 2020

### **1. ORGANIZATION AND NATURE OF BUSINESS**

FinTrust Brokerage Services, LLC, a South Carolina limited liability company, is a registered broker-dealer in securities with the Securities and Exchange Commission {the "SEC") and is a member of various exchanges and the Financial Industry Regulatory Authority, Inc. ("FINRA"). The Company received its approval for membership on January 2, 1997.

Since the Company is a limited liability company, the member is not liable for the debts, obligations, or liabilities of the Company, whether arising in contract, tort or otherwise, unless the member has signed a specific guarantee.

### **2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES**

### Basis of Accounting

The Company maintains its books and records on the accrual basis of accounting for financial reporting purposes, which is in accordance with U.S. generally accepted accounting principles and is required by the SEC and FINRA.

### Use of Estimates

The preparation of financial statements in conformity with accounting principles generally accepted in the United States of America 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 Equivalents

For the purposes of the statement of cash flows, the Company defines cash equivalents as highly liquid investments with original maturity dates of less than ninety days that are not held for sale in the ordinary course of business.

### Revenue from Contracts with Customers

### *Significant Judgements*

Revenue from contracts with customers includes commission income and fees from commissions. The recognition and measurement of revenue is based on the assessment of individual contract terms. Significant judgement 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; whether revenue should be presented gross or net of certain costs; and whether constraints on variable consideration should be applied due to uncertain future events.

Mutual Funds or pooled investment vehicles (collectively, "funds") have entered into agreements with the Company to distribute/sell its shares to investors. Fees are paid up front and over time ( 12b-1 fees) on the basis of a contractual rate applied to the monthly or quarterly market value of the fund (that is, net asset value [NAV]), the fund may also pay, upon investor exit from the fund (that is, a contingent deferred sales charge [CDSC]), or as a combination thereof. Revenue is recognized monthly as services are provided.

### *Brokerage Commissions*

The Company buys and sells securities on behalf of its customers. Each time a customer enters into a buy or sell transaction, the Company charges a commission. Commissions and related clearing expenses are recorded on the trade date (the date that the Company fills the trade order by finding and contracting with a counterparty and confirms the trade with the customer). The Company believes that the performance obligation is satisfied on the trade date because that is when the underlying financial instrument or purchaser is identified, the pricing is agreed upon and the risks and rewards of ownership of the securities have been transferred to/from the customer.

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### Income Taxes

The Company is a limited liability company taxed as a partnership for income tax reporting purposes and as such, is not subject to income tax. Accordingly, no provision for income taxes is provided in the financial statements. The members report the Company's taxable income or loss on their respective tax returns. The Company has adopted provisions of ASC 740-10, Accounting for Uncertainty in Income Taxes. Under ASC 7 40-10 the Company is required to evaluate all of Its tax positions to determine if they are more likely than not to be sustained upon examination. A tax position includes the entity's status. The Company believes it has no uncertain positions.

### Advertising Costs

Advertfsing costs, if any, are charged to expenses as incurred. For the year ended December 31, 2020, the Company incurred \$895 of advertising costs.

### Fair Value

FASB ASC 820 defines fair value, establishes a framework for measuring fair value and establishes a fair value hierarchy that prioritizes the inputs to valuation techniques. Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date. A fair value measurement assumes that the transaction to sell the asset or transfer the liability occurs in the principal market for the asset or liability or, in the absence of a principal market, the most advantageous market. Valuation techniques that are consistent with the market, income or cost approach, as specified by FASB ASC 820, are used to measure fair value. The fair value hierarchy prioritizes the inputs to valuation techniques used to measure fair value into three broad levels:

- Level 1 Inputs are unadjusted quoted prices in active markets for identical assets or liabilities the Company has the ability to access.
- Level 2 Inputs are inputs (other than quoted prices included in level 1) that are observable for the assets or liability, either directly or indirectly.
- Level 3 Unobservable inputs for the asset or liability and rely on management's own assumptions that market participants would use in pricing the asset or liability. (The unobservable inputs should be developed based on the best information available in the circumstances and may include the Company's own data.)

### Accounts Receivable and Receivable from Clearing Broker

The company has evaluated its Account receivable and Receivable from Clearing Broker and determined that no valuation allowance is needed as all Accounts Receivable is deemed collectable. Accounts Receivable is an estimate of trails from Annuities and 529 plans. The Accounts Receivable from Clearing Broker is primarily 12b-1 fees earned in December 2020 less clearing brokerfees.

The Company is evaluating new accounting standards and will implement as required.

### 3. **GUARANTEES**

In the normal course of its business, the Company indemnifies and guarantees certain service providers, such as clearing and custody agents, trustees and administrators, against specified potential losses in connection with their acting as an agent of, or providing services to, the Company or its affiliates. The Company also indemnifies some clients against potential losses incurred in the event specified third-party service providers, including sub-custodians and third-party brokers, improperly executed transactions. The maximum potential amount of future payments that the Company could be required to make under these indemnifications cannot be estimated. However, the Company believes that it is unlikely it will have to make material payments under these arrangements and has not recorded any contingent liability in the financial statements for these indemnifications. For the year ended December 31, 2020 the Company experienced no material net losses as result of the indemnity.

### **4. NET CAPITAL REQUIREMENTS**

The Company is subject to the SEC Uniform Net Capital Rule (SEC Rule 15c3-1}, which requires the maintenance of minimum net capital and requires that the ratio of aggregate indebtedness to net capital, as defined, shall not exceed 15 to 1. At December 31, 2020, the Company had net capital of \$259,457, which

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was \$209,457 in excess of its required net capital of \$50,000. The Company's percentage of aggregate indebtedness to net capital was 14.28% at December 31, 2020.

### **5. COMMITMENTS AND CONTINGENCIES**

The Company has evaluated commitments and contingencies in accordance with Accounting Standards Codification 450, *Contingencies* (ASC 450} and Accounting Standards Codification 440, *Commitments* (ASC 440}. Management has determined that no significant commitments and contingencies exist as of December 31, 2020.

### **6. RELATED PARTY TRANSACTIONS**

The Company has an expense sharing agreement with its member. Under the agreement, the Company pays its member a monthly fee for the use of office facilities, including furniture and equipment, and other administrative services. The sharing rates are based on relative revenue as adjusted for certain types of revenue that require less administrative and personnel expense. The amount totaled \$235,875 in 2020 which is included within various operating expense line items on the accompanying Statement of Operations. The Company processes all payroll and related taxes for employees who are shared with the member. Using the same rates, the member's share of this expense totaled \$3,252,706 for the year. In addition, the Company charges an affiliate for costs of trading including related office expenses which totaled \$100,512 and is included in revenue on the accompanying financial statements. As of December 31, 2020, the Company has recorded a receivable from its member related to these transactions for \$506, 181.

### **7. SUBSEQUENT EVENTS**

The Company evaluated subsequent events through February 25, 2021, the date its financial statements were issued. The Company did not identify any material subsequent events requiring adjustment to or disclosure in its financial statements.

### **8. INVESTMENT DISCLOSURE**

Following table presents the Company's fair value hierarchy for those assets measured at fair value, discounted as noted below, on a recurring basis as of December 31, 2020: Fair Value Measurement on a Recurring Basis As of December 31, 2020:

|                      | Level 1   | Level2 | Level3 | Total     |
|----------------------|-----------|--------|--------|-----------|
| Securities Owned:    |           |        |        |           |
| Equities-Trading FMV | \$71,926  | - 0-   | -0-    | \$71,926  |
| Collateral Amount    | - �40,000 | - 0-   | -0-    | - i4o,ooo |
| Excess Collateral    | \$31,926  | - 0-   | -0-    | \$31,926  |

The investment is used as collateral by the firm to secure the note referenced in #9 below. The company discounts this investment as required by NASD Notice 02-32 dated July 15, 2002, and SEA 15c3-1 d (Appendix D) by at least 30%.

### **9. SECURED DEMAND NOTE**

The Company entered into a secured demand note agreement with Mr. Allen Gillespie for \$40,000, a related party, on January 31, 2014 with an initial termination date of January 31, 2015. The agreement has been renewed through January 31, 2022. There has been no interest paid to date as interest does not accrue with this agreement. This demand note is secured by the investment referenced in note 8.

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(A LIMITED LIABILITY COMPANY)

### COMPUTATION OF NET CAPITAL UNDER RULE 15c3-1 OF THE SECURITIES AND EXCHANGE COMMISSION AS OF DECEMBER 31, 2020

|                                                                      | SCHEDULE I<br>I |
|----------------------------------------------------------------------|-----------------|
| TOTAL MEMBER'S EQUITY QUALIFIED FOR NET                              |                 |
| CAPITAL                                                              | \$<br>752,049   |
| ADDITIONS                                                            | I               |
| Subordinated loans                                                   | 40,000          |
| DEDUCTIONS AND/OR CHARGES:                                           |                 |
| Blockage                                                             | (2,620)         |
| Non-allowable assets:                                                |                 |
| Accounts receivable                                                  | (10,000)        |
| Due from parent                                                      | (506, 181)      |
| CRD Deposit                                                          | (157)           |
| Prepaid expenses                                                     | (13,633)        |
| Haircuts                                                             | (1)             |
| NET CAPITAL                                                          | I\$<br>259,457  |
|                                                                      |                 |
| AGGREGATE INDEBTEDNESS                                               |                 |
| Due to clearing broker                                               | 17,619          |
| Payroll payable                                                      | 19,439          |
| Total aggregate indebtedness                                         | I\$<br>37,058   |
| COMPUTATION OF BASIC NET CAPITAL REQUIREMENT·                        |                 |
| Minimum net capital required                                         | I\$             |
|                                                                      | 50,000          |
| Excess net capital                                                   |                 |
|                                                                      | 209,457<br>I    |
| Net capital in excess of the greater of: 10% of aggregate            |                 |
| indebtedness or 120% of minimum net capital                          | 199,457         |
|                                                                      | I               |
| Percentage of aggregate indebtedness to net capital                  | 14.28%          |
|                                                                      | I               |
|                                                                      |                 |
| RECONCILIATION WITH THE COMPANY'S COMPUTATION (INCLUDED              |                 |
| IN PART fl OF FORM X·17A·5 AS OF DECEMBER 31, 2020)                  |                 |
|                                                                      |                 |
|                                                                      |                 |
| There is not material difference in net capital as reported in the I |                 |
| compani's Part II (unaudited) FOCUS report                           |                 |
|                                                                      |                 |
|                                                                      |                 |
|                                                                      |                 |

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DECEMBER 31, 2020

### SCHEDULE II

### COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS UNDER RULE 15C3- 3 OF THE SECURITIES AND EXCHANGE COMMISSION

The Company is exempt from the provisions of Rule 15c3-3 under the Security Exchange Act of 1934 pursuant to paragraph (k)(2)(ii) of the rule. All customer securities transactions are cleared through another broker-dealer on a fully disclosed basis.

### SCHEDULE Ill

## INFORMATION RELATING TO THE POSSESSION OR CONTROL REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION

The Company is exempt from the provisions of Rule 15c3-3 under the Security Exchange Act of 1934 pursuant to paragraph (k)(2)(ii) of the rule. The Company did not maintain possession or control of any customer funds or securities.

{15}------------------------------------------------

### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

# FinTrust Brokerage Services, LLC >-

TotheMemberof E · We have reviewed management's statements, included in the accompanying FinTrust Brokerage ! Services, LLC's Annual Exemption Report, in which (1) FinTrust Brokerage Services, LLC identified the following provisions of 17 C.F.R. §15c3-3(k) under which FinTrust Brokerage 0.. Services, LLC claimed an exemption from 17 C.F.R. §240.15c3-3: (k)(2)(ii) (the provisions") and (2) FinTrust Brokerage Services, LLC stated that FinTrust Brokerage Services, O LLC met the identified exemption provisions throughout the most recent fiscal year without U exception. FinTrust Brokerage Services, LLC'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 0 oe:i· Oversight Board (United States) and, accordingly, included inquiries and other required procedures

to obtain evidence about FinTrust Brokerage Services, LLC's compliance with the exemption ufJ 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)(2)(ii) of Rule l5c3-3 under the Securities Exchange Act of 1934.

Goldman & Company, CPA's, P.C. Marietta, Georgia February 25, 2021

{16}------------------------------------------------

# FI N TRUST� --- BROKERAGE SERVICES---- ·

### EXEMPTION REPORT

FlnTrust Brokerage Services, LLC ("Company") is a registered broker-dealer subject to SEC Rule 17a·5 ("Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by Rule 17a-5(d}(1) and (4). To the best of its knowledge and belief, the Company states the following:

Throughout the fiscal year ended December 31, 2019, the Company claimed an exemption to SEC Rule 15c3-3 pursuant to paragraph (k)(2)(ii) ("identified exemption provision").

The Company has met the identified exemption provision throughout the most recent fiscal year without exception.

*aa/hJ* 

Allen R. GillespiJ Chief Compliance Officer January 28, 2021

124 Verdae Boulevard, Suite 504 I Greenville, SC 29607 Phone: 864.288.2849 I www.fintrustadvisors.com

Investment advisory services offered through Fin Trust Capital Advisors, LLC. Securities offered through Fin Trust Brokerage Services, LLC. Member FINRA & SIPC

{17}------------------------------------------------

### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING·FIRM ON APPL YING AGREED-UPON PROCEDURES

## To the Member of FinTrust Brokerage Services, LLC

We have performed the procedures included in Rule 17a-5( e )( 4) under the Securities Exchange Act u *<sup>2</sup> .* of 1934 and in the Securities Investor Protection Corporation (SIPC) Series 600 Rules, which are . enumerated below and were agreed to by FinTrust Brokerage Services, LLC and the SIPC, solely to O assist you and SIPC in evaluating FinTrust Brokerage Services, LLC's compliance with the applicable instructions of the General Assessment Reconciliation (Form SIPC-7) for the year ended' D SI e P c C em - 7 b an er d 31 fo , r 20 it 2 s 0 c . o F m in p T lian rus c t e B w ro ith ker th ag o e se S r e e rv qu ic ir es em , L en L ts C . 's Th m is an a a gr ge e m ed e n u t po is n r p es ro po ce n d si u b r l e e s fo en r g i a t g s e F m o e rm . �· was conducted in accordance with standards established by the Public Company Accounting Oversight Board (United States) and in accordance with attestation standards established by the ufJ American Institute of Certified Public Accountants. The sufficiency of these procedures is solely the responsibility of those parties specified in this report. Consequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose. The procedures we performed and our findings are as follows:

- 1) Compared the listed assessment payments in Form SIPC- 7 with respective cash disbursement records entries, noting no differences;
- 2) Compared the Total Revenue amounts reported on the Annual Audited Report Form X-17A-5 Part III for the year ended December 31, 2020 with the Total Revenue amount reported in Form SIPC- 7 for the year ended December 31, 2020, noting no differences;
- 3) Compared any adjustments reported in Form SIPC-7 with supporting schedules and working papers, noting no differences;
- 4) Recalculated the arithmetical accuracy of the calculations reflected in Form SIPC- 7 and in the related schedules and working papers supporting the adjustments, noting no differences; and
- 5) Compared the amount of any overpayment applied to the current assessment with the Form SIPC-7 on which it was originally computed, noting no differences.

We were not engaged to and did not conduct an examination or review, the objective of which would be the expression of an opinion or conclusion, respectively, on FinTrust Brokerage Services, LLC's compliance with the applicable instructions of the Form SIPC- 7 for the year ended December 31, 2020. Accordingly, we do not express such an opinion or conclusion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you.

This report is intended solely for the information and use of Fin Trust Brokerage Services, LLC and the SIPC and is not intended to be and should not be used by anyone other than these specified parties.

*J/L!*�*rto7':; d4s*�*c\_* 

Goldman & Company, CPA's, P.C. Marietta, Georgia February 25, 2021

{18}------------------------------------------------

|                                               | SIPC-7<br>(36-REV 12/18)<br>1. Name of Member, address, Designated Examining Authority, 1934 Act registration no. and month in which fiscal year ends for<br>purposes of the audit requirement of SEC Rule 17a·5:<br>CRD 41608<br>I SEC 8-49514                                                                                                                                                                                                     | SECURITIES INVESTOR PROTECTION CORPORATION<br>P .0. Box 92185 Washington, D.C. 20090-2185<br>202-371-8300<br>General Assessment Reconciliation<br>For the fiscal year ended 12/31/2020<br>(Read carefully the Instructions In your Working Copy before completing this Form)<br>TO BE FILED BY ALL SIPC MEMBERS WITH FISCAL YEAR ENDINGS | Note: If any of the information shown on the<br>mailing label requires correction, please e-mail                                                                                  | SIPC-7<br>{36-REV 12/18) |
|-----------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------|
|                                               | FINRA<br>December<br>FinTrust Brokerage Services, LLC<br>124 Verdae Blvd, Suite 504<br>L<br>I Greenville, SC 29607                                                                                                                                                                                                                                                                                                                                  | _J                                                                                                                                                                                                                                                                                                                                       | any corrections to form@sipc.org and so<br>indicate on the form flied.<br>Name and telephone number of person to<br>contact respecting this form.<br>Allen Gillespie 864-288-2849 |                          |
|                                               | 2. A. General Assessment (item 2e from page 2)<br>8. Less payment made with SIPC-6 filed (exclude interest)<br>7/29/2020<br>Date Paid                                                                                                                                                                                                                                                                                                               |                                                                                                                                                                                                                                                                                                                                          | \$808.86<br>( 449.50                                                                                                                                                              |                          |
|                                               | C. Less prior overpayment applied<br>0. Assessment balance due or (overpayment)<br>E. Interest computed on late payment (see instruction EJ for<br>F. Total assessment balance and interest due (or overpayment carried forward)<br>G. PAYMENT:<br>V the box<br>Check malled to P.O. Box[ZJ Funds Wired<br>Total<br>(must be same as F above)<br>H. Overpayment carried forward                                                                     | __<br>days at 20% per annum<br>0<br>0<br>ACH<br>.36<br>\$ 359<br>,<br>\$(                                                                                                                                                                                                                                                                | 359.36<br>_<br>_                                                                                                                                                                  |                          |
|                                               | 3. Subsidiaries {S) and predecessors (P) included in this form (give name and 1934 Act registration number);                                                                                                                                                                                                                                                                                                                                        |                                                                                                                                                                                                                                                                                                                                          |                                                                                                                                                                                   |                          |
|                                               | The SIPC member submitting this form and the<br>person by whom It ls executed represent thereby<br>that all information contained herein is true, correct<br>and complete.<br>, 203.!_.<br>Dated the 26<br>day of January<br>This form and the assessment payment Is due 60 days after the end of the fiscal year. Retain the Working Copy of this form<br>for a period of not less than 6 years, the latest 2 years In an easily accessible place. | Fintrust Brokerage Services<br>�<br>T .,r                                                                                                                                                                                                                                                                                                | {Aulhorl2ed Signature)<br>�-.c ,'�v-._, {<br>{Tltle)                                                                                                                              |                          |
| ffi Dates:<br>;=<br>LI.I ><br>LI.I<br>a:<br>� | Postmarked<br>Received<br>_<br>Calculations<br>c.:, Exceptions:<br>en Disposition of exceptions:                                                                                                                                                                                                                                                                                                                                                    | Reviewed<br>_<br>Documentation                                                                                                                                                                                                                                                                                                           |                                                                                                                                                                                   | _<br>Forward Copy        |

{19}------------------------------------------------

### **DETERMINATION OF "SIPC NET OPERATING REVENUES" AND GENERAL ASSESSMENT**  Amounts for the fiscal period

|                                                                                                                                                                                                                                                                                                                                                                                               | _<br>beginning -=-=1<br>1;.; 21.::. 1 02 ;.;;2;.;;. o<br>and ending l2i3112Q?Q |
|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------|
| Item No.<br>2a. Total revenue (FOCUS Line 12/Parl IIA Line 9, Code 4030)                                                                                                                                                                                                                                                                                                                      | Eflmlnate cents<br>\$ 1,534,332.34                                             |
| 2b. Additions:<br>[1) Total revenues from the securities business or subs!dlaries (except foreign subsidiaries) and<br>predecessors not included above.                                                                                                                                                                                                                                       |                                                                                |
| (2) Net loss from principal transactions in securities in trading accounts.                                                                                                                                                                                                                                                                                                                   |                                                                                |
| (3) Net loss from principal transactions in commodities in trading accounts.                                                                                                                                                                                                                                                                                                                  |                                                                                |
| (4) Interest and dividend expense deducted in determining item 2a.                                                                                                                                                                                                                                                                                                                            |                                                                                |
| (5) Net loss from management of or participation in the underwriting or distribution of securities.                                                                                                                                                                                                                                                                                           |                                                                                |
| (6) Expenses other than advertising. printing, registration fees and legal lees deducted in determining net<br>profit from management of or participation In underwriting or distribution of securities.                                                                                                                                                                                      |                                                                                |
| (7) Net loss from securities in lnveslment accounts.                                                                                                                                                                                                                                                                                                                                          |                                                                                |
| Total additions                                                                                                                                                                                                                                                                                                                                                                               |                                                                                |
| 2c. Deductions:<br>(1) Revenues from the distribution of shares of a registered open end investment company or unit<br>investment trust, from the sale of variable annuities, from the business of insurance, from Investment<br>advisory services rendered to registered investment companies or insurance company separate<br>accounts, and from transactions in security futures products. | 866,953.75                                                                     |
| (2) Revenues from commodity transactions.                                                                                                                                                                                                                                                                                                                                                     |                                                                                |
| {3) Commissions, floor brokerage and clearance paid 10 other SIPC members in connection with<br>securities transactions.                                                                                                                                                                                                                                                                      | 127,364.57                                                                     |
| (4) Reimburssments for postage in connection with proxy solicitation.                                                                                                                                                                                                                                                                                                                         |                                                                                |
| (5) Net gain from securities in investment accounts.                                                                                                                                                                                                                                                                                                                                          |                                                                                |
| (6) 100% of commissions and markups earned from transactions in (i) certificates of deposit and<br>(ii) Treasury bills, bankers acceptances or commercial paper that mature nine months or less<br>lrom issuance date.                                                                                                                                                                        | 772.97                                                                         |
| (7) Direct expenses of printing advertising and legal lees incurred in connection with other revenue<br>related to the securities business (revenue defined by Section 16(9){L} of the Act).                                                                                                                                                                                                  |                                                                                |
| (8) Other revenue not related either directly or indirectly to the securities business.<br>(See Instruction C):                                                                                                                                                                                                                                                                               |                                                                                |
| (Deductions in excess of \$100,000 require documentation)                                                                                                                                                                                                                                                                                                                                     |                                                                                |
| (9) (i) Total Interest and dividend expense (FOCUS Line 22/PART IIA Line 13,<br>_<br>Code 4075 plus line 2b(4) above) but not in excess<br>of total interest and dividend income.<br>\$                                                                                                                                                                                                       |                                                                                |
| _<br>(ii) 40% of margin interest earned on customers securllles<br>accounts j40% of FOCUS line 5, Code 3960).<br>\$                                                                                                                                                                                                                                                                           |                                                                                |
| Enter lhe greater of line {i) or (Ii)                                                                                                                                                                                                                                                                                                                                                         |                                                                                |
| Total deduclions                                                                                                                                                                                                                                                                                                                                                                              | 995,091.29                                                                     |
| 2d. SIPC Net Operating Revenues                                                                                                                                                                                                                                                                                                                                                               | \$ 539,241.05                                                                  |
| 2e. General Assessment@.00<br>15                                                                                                                                                                                                                                                                                                                                                              | 808.86<br>\$                                                                   |


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