# PULLMAN SECURITIES, LLC X-17A-5 (2020-02-26) — Broker-dealer annual report
- Company: PULLMAN SECURITIES, LLC
- Form: X-17A-5
- Filed: 2020-02-26
- Period: 2019-12-31
- Accession: 0001068597-20-000001
- CIK: 1068597
- File #: 8-51234
- Material weakness: No
- Auditor: Thayer ONeal Certified Public Accountants
- Auditor location: Sugar Land, TX
- Contact: David Pullman
- Phone: 3102880558
- Signed by: David Pullman, CEO (CEO)
Original filing: https://www.sec.gov/Archives/edgar/data/1068597/000106859720000001/PSFP.pdf
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# **Pullman Securities, LLC**
# SEC No. 8-51234
## FINANCIAL STATEMENTS AND SUPPLEMENTAL SCHEDULE FOR THE YEAR ENDED DECEMBER 31, 2019
AND
## REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
AND
REVIEW REPORT REGARDING EXEMPTION PROVISIONS
These financial statements and schedules are deemed CONFIDENTIAL pursuant to subparagraph (e)(3) of Rule 17a-5 of the Securities and Exchange Commission.
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"PUBLIC"
UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549
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SEC FILE NUMBER
8-51234
## ANNUAL AUDITED REPORT FORM X-17A-5 PART III
#### FACING PAGE
Information Required of Brokers and Dealers Pursuant to Section 17 of the Securities Exchange Act of 1934 and Rule 17a-5 Thereunder
| MM/DD/YY
A. REGISTRANT IDENTIFICATION | | MM/DD/YY | | |
|------------------------------------------|-----------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|--|
| | | | | |
| | | | | |
| | | OFFICIAL USE ONLY | | |
| Pullman Securities, LLC | | | | |
| | | FIRM ID. NO. | | |
| | | | | |
| | | | | |
| | | 90069 | | |
| | | (Zip Code) | | |
| | | | | |
| (310) 288-0558
David Pullman | | | | |
| | | (Area Code - Telephone No.) | | |
| | | | | |
| | | | | |
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| | | | | |
| | | | | |
| | Texas
(State) | 77478
(Zip Code) | | |
| | | | | |
| | | | | |
| | | | | |
| | | | | |
| | | | | |
| | | | | |
| | (No. and Street)
(State)
Sugar Land
(City) | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.)
NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT
B. ACCOUNTANT IDENTIFICATION
INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report*
(Name - if individual, state last, first, middle name)
Accountant not resident in United States or any of its possessions.
FOR OFFICIAL USE ONLY | | |
\* Claims for exemption from the requirement hat the amual report of an independent public accountant must be supported by a statement of facts and circumstances relied on as the basis for the exemption. See section 240.17a-5(e)(2).
SEC 1410 (06-02)
Potential persons who are to respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB control number.
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#### OATH OR AFFIRMATION
I, David Pullman, CEO, swear (or affirm) that, to the best of my knowledge and belief the accompanying financial statements and supporting schedules pertaining to the firm of Pullman Securities, LLC (Company), as of December 31, 2019, 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:
Notary Public
This report contains (check all applicable boxes):
- Facing page. (x) (a)
- Statement of Financial Condition. (x) (b)
- (c) Statement of Income (Loss). ()
- () (d) Statement of Changes in Financial Condition.
- () (e) Statement of Changes in Partners' Capital.
- (f) Statement of Changes in Liabilities Subordinated to Claims of Creditors. () Notes to Financial Statements. (x)
- (g) Computation of Net Capital. ()
- (h) Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3. ()
- (i) Information Relating to the Possession or Control Requirements Under () Rule 15c3-3.
- (j) A Reconciliation, including appropriate explanation of the Computation of Net () Capital Under Rule 15c3-1 and the Computation for Determination of the Reserve Requirements Under Exhibit A of Rule 15c3-3.
- (k) A Reconciliation between the audited and unaudited Statements of Financial () Condition with respect to methods of consolidation.
- (1) An Oath or Affirmation. (x)
- (m) A copy of the SIPC Supplemental Report. ()
- (n) A report describing any material inadequacies found to exist or found to have () existed since the date of the previous audit.
- (o) Review report on managements' assertion letter regarding (k)(2)(i). (x)
- (p) Management's assertion letter regarding (k)(2)(i). (x)
David Pullman, CEO
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#### CALIFORNIA ALL-PURPOSE ACKNOWLEDGMENT
#### CIVIL CODE § 1189
KENDIA BERETTER COLORARIA COLOCAL CARTER COLORIES COLORIES COLORIES COLORIES CONSULTION COLORIES CONSULTION COLORIES CONSULTION COLORIES CONSULTION COLORIES CONSULTION COLORI
A notary public or other officer completing this certificate verifies only the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document.
| State of California | | | | |
|---------------------|------------|----------------------|-------------------------------------------|--|
| County of | | | | |
| 1,2020 V
On | before me, | ASHINI | | |
| Date | | | Here Insert Name and Title of the Officer | |
| personally appeared | | | LMAN | |
| | | Name(s) of Signer(s) | | |
who proved to me on the basis of satisfactory evidence to be the person(\$) whose name(\$( is/are sybscribed to the within instrument and acknowledged to me that he/she/they executed the same in his her/their authorized capacity(ies), and that by fils/her/their signature(s) on the instrument the person(e), or the entity upon behalf of which the person(s) acted, executed the instrument.
I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct.
WITNESS my hand and official seal.
Signature Signature of Notary Public
Place Notary Seal Above
OPTIONAL
Though this section is optional, completing this information can deter alteration of the document or fraudulent reattachment of this form to an unintended document.
| Title or Type of Document: Ammon Andy + Repub Document Date: 1, 11,2020 | |
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| Signer's Name: James and Career State | |
| C Corporate Officer - Title(s): | |
| Partner - _ Limited General | |
| Individual
Attorney in Fact | |
| Guardian or Conservator | |
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| Signer Is Representing: | |
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TO CALL CALLER ©2014 National Notary Association · www.NationalNotary.org · 1-800-US NOTARY (1-800-876-6827) · Item #5907
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## REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
Director and Shareholder Pullman Securities, LLC 9250 Robin Drive Los Angeles, CA 90069
Opinion on The Financial Statements
We have audited the accompanying balance sheet of Pullman Securities, LLC (the "Company") as of December 31, 2019, and the related notes (collectively referred to as "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Company as of December 31, 2019, in conformity with accounting principles generally accepted in the United States of America.
#### Basis for Opinion
These financial statements are the responsibility of the Company's management. Our responsibility is to express an opinion on the Company's 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 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 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 from material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risk 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 assessing 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.
THAYER O'NEAL COMPANY, LLC
We have served as Pullman Securities, LLC's auditor since 2019
Sugar Land, TX February 26, 2020
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#### **PULLMAN SECURITIES, LLC**
# Statement of Financial Condition
December 31, 2019
Assets
| Cash
Prepaid Expense | \$
32,393
1,486 |
|---------------------------------------|-----------------------|
| Total Assets | \$
33,879 |
| Liabilities and Member's Equity | |
| Accounts payable and accrued expenses | \$
1,650 |
| Member's Equity | 32,229 |
| Total Liabilities and Member's Equity | \$
33,879 |
See notes to the financial statements and report of independent registered public accounting firm.
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#### Note 1 - Organization and Nature of Business
Pullman Securities, LLC (the "Company") is a Limited Liability Company organized under the laws of the State of Delaware on July 22, 1998.
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). The Company does not clear securities transactions or carry customers' accounts on a fully disclosed basis. Accordingly, the Company operates under the provisions of Paragraph (k)(2)(i) of Rule 15c3-3 of the Securities and Exchange Act of 1934 and is exempt from the remaining provisions of that rule.
The Company conducts a consulting business and intends to engage in private placement of non-registered securities with institutional accounts.
#### Note 2 - Summary of Significant Accounting Policies
#### Income Taxes
The Company is a Single Member Limited Liability Company which has elected to be taxed as a sole proprietor. Therefore, no provisions for federal or state taxes are made by the Company. Members of a Limited Liability Company are individually taxed on their pro-rata share of the Company's earnings.
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## Note 2 - Summary of Significant Accounting Policies (cont'd.)
The Company's federal, state and local tax returns are subject to possible examination by the taxing authorities until expiration of the related statutes of limitations on those tax returns. In general, the federal and state income tax returns have a three year statute of limitations. The Company would recognize accrued interest and penalties associated with uncertain tax positions, if any, as part of the income tax provision.
#### Use of Estimates
The preparation of financial statements in conformity with generally accepted accounting principles requires management to make estimates and assumptions that affect reported amounts and disclosures. Accordingly, actual results could differ from those estimates.
## Cash Balances
The Company considers cash balances maintained with the bank to be cash; such balances are fully insured.
## Note 3 – Related Party Transactions
The Company had 100% of its consulting income from a related entity, Structured Asset Sales, LLC ("SAS") for the year ended December 31, 2019. In addition, the Company had a \$1200 payable from the related entity. The related entity is owned by the Member.
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### Note 4 - Net Capital Requirement
As a registered broker-dealer and member of FINRA, the Company is subject to the SEC's Uniform Net Capital Rule 15c3-1 (the "Rule"), which requires that net capital, as defined, be at least the greater of \$5,000 or 6.667% of aggregate indebtedness, as defined. The Rule prohibits the Company from distributing equity capital or paying cash dividends if its resulting net capital is less than one-tenth of aggregate indebtedness or 120% of the minimum dollar amount required, whichever is greater.
Net capital and aggregate indebtedness change from day to day, but at December 31, 2019, the Company had net capital of \$30,743 which exceeded its requirement of \$5,000 by \$25,743 Aggregate indebtedness was \$1,650. The Company's net capital ratio was 5.37 to 1 of net capital to aggregate indebtedness.
#### Note 5 – Fair Value
Effective January 1, 2008, the Company adopted Statement of Financial Accounting Standards ("SFAS") ASC 820 "Fair Value Measurements and Disclosures," for assets and liabilities measured at fair value on a recurring basis. The adoption of ASC 820 had no effect on the Company's financial statements. ASC 820 accomplishes the following key objectives:
Defines fair value as 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;
Establishes a three-level hierarchy (the "Valuation Hierarchy") for fair value measurements;
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Note 5 – Fair Value (cont'd.)
Requires consideration of the Company's creditworthiness when valuing liabilities; and
Expands disclosures about instruments measured at fair value.
The Valuation Hierarchy is based upon the transparency of inputs to the valuation of an asset or liability as of the measurement date. A financial instrument's categorization within the Valuation Hierarchy is based upon the lowest level of input that is significant to the fair value measurement. The three levels of the Valuation Hierarchy and the distribution of the Company's financial assets within it are as follows:
Level 1 – inputs to the valuation methodology are quoted prices (unadjusted) for identical assets or liabilities in active markets.
Level 2 – inputs to the valuation methodology included quoted prices for similar assets and liabilities in active markets, and inputs that are observable for the asset or liability, either directly or indirectly, for substantially the full term of the financial instrument.
Level 3 – inputs to the valuation methodology are unobservable and significant to the fair value measurement.
Certain financial instruments are carried at cost on the balance sheet, which approximates fair value due to their shortterm, highly liquid nature. These instruments include cash and accounts payable.
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Note 6 – Revenue Recognition
For the year ended December 31, 2019, the Company's revenues were derived from consulting income.
Effective January 1, 2018 the Company adopted ASC Topic 606, Revenue from Contracts with Customers ("ASC Topic 606"). The new revenue recognition guidance requires that an entity recognize revenue to depict the transfer of promised goods or services to customers in an amount that reflects the consideration to which the entity expects to be entitled in exchange for those goods or services. The guidance requires an entity to follow a five step model to (a) identify the contract(s) with a customer, (b)identify the performance obligations in the contract, (c)determine the transaction price, (d) allocate the transaction price to the performance obligations in the contract, and (e)recognize the revenue when (or as) the entity satisfies a performance obligation. The Company has evaluated the new guidance and the adoption is not expected to have a significant impact on the Company's financial statements and a cumulative effect adjustment under the modified retrospective method of adoption will not be necessary.
### Note 7 – Subsequent Events
These financial statements were approved by management and available for issuance on February 26, 2020. Subsequent events have been evaluated through this date.
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## **Pullman Securities, LLC**
Information Relating to the Possession or Control Requirements Under SEC Rule 15c3-3
As of December 31, 2019
The Company claims exemption from the requirements of SEC Rule 15c3-3, under Section k(2)(i) of the Rule.
A computation for determination of reserve requirements pursuant to Rule 15c3-3 required by Rule 17a-5(d)(3) and information relating to possession or control of securities as required by Rule 15c3-3 and Rule 17a-5(d)(3) of the SEC were both omitted as the Company does not clear securities transactions or carry customers accounts on a fully disclosed basis and thus qualified under the Section k(2)(i) exemption from the requirements of SEC Rule 15c3-3.
The Company was in compliance with the conditions of the exemptive provisions of SEC Rule 15c3-3 at December 31, 2019.
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## Report of Independent Registered Public Accounting Firm Exemption Review Report Pursuant to 15c3-3(k)(2)(i)
David Pullman Pullman Securities, LLC 9250 Robin Drive Los Angeles, CA 90069
Dear David Pullman:
We have reviewed management's statements, included in the accompanying Exemption Report, in which Pullman Securities, LLC identified the following provisions of 17 C.F.R. §15c3-3(k) under which Pullman Securities, LLC claimed an exemption from 17 C.F.R. §15c3-3(k)(2)(i) and Pullman Securities, LLC stated that Pullman Securities, LLC met the identified exemption provisions throughout the most recent fiscal year without exception. Pullman Securities, LLC 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 Pullman Securities, LLC compliance with the exemption provisions. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on managements 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)(i) of Rule 15c3-3 under the Securities Exchange Act of 1934.
THAYER O'NEAL COMPANY, LLC
Sugar Land, TX February 26, 2020
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# Pullman Securities, LLC
# 9250 Robin Dr.
# Los Angeles, CA 90069-1126
#### Assertions Regarding Exemption Provisions
Pullman Securities, LLC operates pursuant to paragraph (k)(2)(i) of SEC Rule 15c3-3 under which the Company claims an exemption from SEC Rule 15c3-3. The Company is exempt from the reserve requirements of Rule 15c3-3 as its transactions are limited, such that it does not handle customer funds or securities. Accordingly, the computation for determination of reserve requirements pursuant to Rule 15c3-3 and information relating to the possession or control requirement pursuant to Rule 15c3-3 are not applicable.
The Company has met the identified exemption provisions throughout the year the period of January 1, 2019 through December 31, 2019 without exception.
David Pullman, Chairman and CEO
January 13, 2020
Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.