# DAVINCI CAPITAL MANAGEMENT, INC. X-17A-5 (2021-04-12) — Broker-dealer annual report
- Company: DAVINCI CAPITAL MANAGEMENT, INC.
- Form: X-17A-5
- Filed: 2021-04-12
- Period: 2020-12-31
- Accession: 0001079306-21-000002
- CIK: 1079306
- File #: 8-51580
- Material weakness: No
- Auditor: Ohab and Company, P.A.
- Auditor location: Maitland, FL
- Contact: Deborah Sims-McSweeney
- Phone: 6175496598
- Signed by: James J. McSweeney (President)
Original filing: https://www.sec.gov/Archives/edgar/data/1079306/000107930621000002/davinciaudit.pdf
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#### UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549
OMB APPROVAL OMB Number: 3235-0123 Expires: October 31, 2023 Estimated average burden hours per response. . . . . . . . . . . 12.00
## ANNUAL AUDITED REPORT FORM X-17A-5 PART III
| SEC FILE NUMBER | |
|-----------------|--|
| 8-51580 | |
FACING PAGE Information Required of Brokers and Dealers Pursuant to Section 17 of the Securities Exchange Act of 1934 and Rule 17a-5 Thereunder
| REPORT FOR THE PERIOD BEGINNING | 1/1/2020 | AND ENDING | | 12/31/2020 | |
|--------------------------------------------------------------------------|---------------------------------------------------------------------|------------|-------------------|--------------------------------|--|
| | MM/DD/YY | | | MM/DD/YY | |
| | A. REGISTRANT IDENTIFICATION | | | | |
| NAME OF BROKER-DEALER: | Da Vinci Capital Management, Inc. | | OFFICIAL USE ONLY | | |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.) | | | | FIRM I.D. NO. | |
| 801 Cambridge Street | | | | | |
| | (No. and Street) | | | | |
| Cambridge | MA | | 02141 | | |
| (City) | (State) | | (Zip Code) | | |
| NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT | | | | | |
| James J. McSweeney | | | (617) 354-3222 | | |
| | | | | (Area Code - Telephone Number) | |
| | B. ACCOUNTANT IDENTIFICATION | | | | |
| INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained on this Report* | | | | | |
| Ohab & Company, P.A. | | | | | |
| | (Name - if individual, state last, first, middle name) | | | | |
| 100 E Sybelia Avenue, Suite 130 | Maitland | | FL | 32751 | |
| (Address) | (City) | | (State) | (Zip Code) | |
| CHECK ONE: | | | | | |
| Certified Public Accountant
X | | | | | |
| Public Accountant | | | | | |
| | 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 must be supported by a statement of facts and circumstances relied on as the basis for the exemption. See 240.17a-5(e)(2).
Potential persons who are to respond to the collection of information contained in this form are not required to respond SEC 1410 (06-02)
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#### OATH OR AFFIRMATION
| ﺎ, | James J. McSweeney
100 million and the state of the states of the states of the states of the states of the states of the states of the states of the states of the states of the states of the s | , swear (or affirm) that, to the best of | |
|-----|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------|--------------------------------------------------|
| | my knowledge and belief, the accompanying financial statements and supporting schedules pertaining to the firm of | | |
| | DaVinci Capital Management, Inc. | as a manager and some a comments as | |
| of | December 31, 2020 | , are true and correct. I further swear (or affirm) | |
| | that neither the company nor any partner, principal officer, or director has any proprietary interest in any account | | |
| | classified solely as that of a customer, except as follows: | | |
| | | | |
| | | | |
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| | | | |
| | | Signature | |
| | | | |
| | | President | |
| | | Title | |
| | | | |
| | | JAMES F. TOOHEY, JR.
Notary Public | |
| | Notary Public | ONWEALTH OF MASSACHUSETTS | |
| | | My Commission Expires
March 19 20' | |
| | This report** contains (check all applicable boxes): | | |
| (a) | Facing page. | | |
| | (b) Statement of Financial Condition. | | |
| | (c) Statement of Income (Loss) or, if there is other comprehensive in the period(s) presented, a Statement | | |
| | of Comprehensive Income (as defined in §210.1-02 of Regulation S-X). | | T : TOOHEY, |
| | (d) Statement of Changes in Financial Condition | | Notary Public |
| | (e) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietor's Capit | | WEALTH OF MASSACHUSETT:
My Commission Expires |
| | (f) Statement of Changes in Liabilities Subordinated to Claims of General Creditors. | | March 19, 2021 |
| (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 for Brokers and Dealers Under Rule 1563-3. | | |
| | (i) A Reconciliation, including appropriate explanation 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 Statements of Financial Condition with respect to methods of | | |
| | consolidation. | | |
| (1) | An Oath or Affirmation. | | |
| | (m) A copy of the SIPC Supplemental Report. | | |
| (n) | Exemption Report | | |
| | | | |
| | | | |
\*\*
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### DAVINCI CAPITAL MANAGEMENT, INC.
#### FINANCIAL STATEMENTS AND SUPPLEMENTARY INFORMATION
YEAR ENDED DECEMBER 31, 2020
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### TABLE OF CONTENTS
Page No.
1 REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM FINANCIAL STATEMENTS 2 Statement of Financial Condition Statement of Operations 3 Statement of Comprehensive Income 4 5 Statement of Changes in Stockholder's Equity Statement of Cash Flows 6 Notes to Financial Statements 7 - 15 SUPPLEMENTAL SCHEDULE Schedule I - Computation of Net Capital Pursuant to Uniform Net Capital Rule 15c3-1 16 Schedule II - Computation for Determination of Reserve Requirements And Information Relating to Possession or Control Requirements under 17 Rule 15c3-3 of the Securities and Exchange Commission
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100 E. Sybelia Ave. Suite 130 Maitland, FL 32751
Certified Public Accountants Email: pam @ohabco.com
Telephone 407-740-7311 Fax 407-740-6441
#### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
To the Board of Directors and Stockholder's of Davinci Capital Management, Inc.
#### Opinion on the Financial Statements
We have audited the accompanying statement of financial condition of Davinci Capital Management, Inc. as of December 31, 2020, the related statements of operations, changes in stockholder's equity, and cash flows for the year then ended, and the related notes and schedules (collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of Davinci Capital Management, Inc. as of December 31, 2020, and the results of its cash flows for the year then ended in conformity with accounting principles generally accepted in the United States of America.
#### Basis for Opinion
These financial statements are the responsibility of Davinci Capital Management, Our responsibility is to express an opinion on Davinci Capital Management, Inc.'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 Davinci Capital Management, Inc. In accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.
We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion.
#### Auditor's Report on Supplemental Information
The Schedules I and II have been subjected to audit procedures performed in conjunction with the audit of Davinci Capital Management, Inc.'s financial statements. The supplemental information is the responsibility of Davinci Capital Management, Inc.'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 information 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 Schedules I and II are fairly stated, in all material respects, in relation to the financial statements as a whole.
ORal and Company, AP
We have served as Davinci Capital Management, Inc.'s auditor since 2017.
Maitland, Florida
April 8, 2021
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### DAVINCI CAPITAL MANAGEMENT, INC. STATEMENT OF FINANCIAL CONDITION DECEMBER 31, 2020
#### ASSETS
| Cash
Receivables
Deposits with clearing organization
Prepaid expenses
Marketable securities | ಕಿ | 73,471
144,328
25,643
235
119,466 |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----|-----------------------------------------------------|
| | S | 363,143 |
| LIABILITIES AND STOCKHOLDER'S EQUITY | | |
| Accounts payable and accrued expenses
Due to related party | S | 105,699
82,765 |
| | | 188,464 |
| Stockholder's equity:
Common stock, no par value,
Authorized 10,000 class A voting shares and
10,000 class B non-voting shares;
issued and outstanding 900 class A shares
Additional paid-in capital
Accumulated deficit
Accumulated other comprehensive income | | 18,000
862,606
(799,443)
93,516
174,679 |
| | ಕಾ | 363,143 |
See notes to financial statements
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### DAVINCI CAPITAL MANAGEMENT, INC. STATEMENT OF OPERATIONS YEAR ENDED DECEMBER 31, 2020
| Revenues: | | |
|---------------------------------------------------|---|---------|
| Advisory fees | S | 394.575 |
| Insurance products and 12b-1 fees and concessions | | 546,968 |
| Commissions clearing | | 49,313 |
| Interest and dividend income | | 2,222 |
| | | |
| | | 993,078 |
| Operating expenses: | | |
| Commissions | | 620,065 |
| Payroll | | 183.378 |
| Clearing charges | | 40,166 |
| Professional fees | | 38,916 |
| Regulatory expenses | | 38,099 |
| Office rent | | 30,000 |
| Dues and subscriptions | | 7,549 |
| Computer expenses | | 6,439 |
| Office expense | | 6,372 |
| I Itilities | | 3,551 |
| Equipment rental | | 3.512 |
| Insurance | | 3,317 |
| Maintenance agreement | | 2,240 |
| Taxes - other | | 501 |
| | | 984,105 |
| | | |
| Net income | S | 8,973 |
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### DAVINCI CAPITAL MANAGEMENT, INC. STATEMENT OF COMPREHENSIVE INCOME YEAR ENDED DECEMBER 31, 2020
| Net income | S | 8,973 |
|--------------------------------|---|--------|
| Other comprehensive income: | | |
| Unrealized gain on investments | | 23,076 |
| Comprehensive income (loss) | | 32,049 |
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#### DAVINCI CAPITAL MANAGEMENT, INC. STATEMENT OF CHANGES IN STOCKHOLDER'S EQUITY YEAR ENDED DECEMBER 31, 2020
| | | Class A | Additional | | Accumulated
Other | |
|-----------------------------------------------------|--------|------------------------|--------------------|------------------------|-------------------------|-------------|
| | Shares | Common Stock
Amount | Paid-In
Capital | Accumulated
Deficit | Comprehensive
Income | Total |
| Balance, January 1, 2020 | 900 | \$ 18,000 | 808,606
ಲ್ಲಿ | ಳಿ
(808,416) | S
70,440 | 88,630
A |
| Net income | | | | 8,973 | | 8,973 |
| Capital contributions | | | 54,000 | | | 54,000 |
| Unrealized holding gain on
marketable securities | | | | | 23,076 | 23,076 |
| Balance, December 31, 2020 | 900 | \$ 18,000 | ಕಾ
862,606 | A
(799,443) | S
93,516 | \$ 174,679 |
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### DAVINCI CAPITAL MANAGEMENT, INC. STATEMENT OF CASH FLOWS YEAR ENDED DECEMBER 31, 2020
| Cash flows from operating activities: | | |
|-----------------------------------------------|-----|----------|
| Net income | S | 8,973 |
| Adjustments to reconcile net loss to net cash | | |
| used in operating activities: | | |
| Changes in operating assets and liabilities: | | |
| Receivables | | (23,433) |
| Deposits with clearing organization | | (36) |
| Prepaid expenses | | (113) |
| Accounts payable and accrued expenses | | (51,999) |
| Due to related party | | 15,552 |
| Net cash used in operating activities | | (51,056) |
| Cash flows from financing activities: | | |
| Capital contribution | | 54,000 |
| Net cash provided by financing activities | | 54,000 |
| | | |
| Net increase in cash during the year | | 2.944 |
| Cash, beginning of year | | 70,527 |
| Cash, end of year | ಿಕ | 73,471 |
| Supplemental cash flow information: | | |
| Cash paid during the year for: | | |
| Interest | ಕಿ | |
| Corporate taxes | ಕಿತ | 456 |
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### DAVINCI CAPITAL MANAGEMENT, INC. NOTES TO FINANCIAL STATEMENTS DECEMBER 31, 2020
#### Note 1 Organization and nature of business
DaVinci Capital Management, Inc. (the "Company") was incorporated in December 1998 and is a Delaware Corporation that is wholly owned by Airgead LLC ("Airgead LLC"). The Company operates as a broker-dealer and registered investment advisor in the New England area. The Company does business on a fully disclosed basis and, therefore, does not hold or maintain any customer accounts. The Company is a registered broker under the Securities Exchange Act of 1934 and is a member of the Financial Industry Regulatory Authority ("FINRA") and the Securities Investor Protection Corporation ("SIPC").
#### Note 2 Summary of significant accounting policies
#### Revenue recognition
The Company records revenue under the provisions of ASC 606, Revenue from Contracts with Customers. Under this standard, recognition of revenue occurs when a customer obtains control of promised services or goods in an amount that reflects the consideration to which the entity expects to receive in exchange for those goods or services. In addition, the standard requires disclosure of the nature, amount, timing and uncertainty of revenue and cash flows arising from customer contacts.
Revenue from contracts with customers includes commission from the sale of variable annuity and mutual fund products. The Company recognizes revenue on these products once received with an estimate booked representing outstanding commissions and fees due.
Commissions and related clearing expenses are recorded on a trade-date basis.
Investment advisory fees are recognized as earned on a pro rata basis over the term of the contract.
### Receivables from broker-dealers and clearing organizations
Receivables from broker-dealers and clearing organizations consist of commissions due under normal trade terms. The Company provides an allowance for doubtful collections which is based on a review of outstanding receivables, historical collection information, and existing economic conditions. At December 31, 2020 there was no reserve for uncollectible receivables.
### Marketable securities
The Company accounts for its marketable securities at fair value, as the Company has categorized them as available-for-sale securities. Accordingly, unrealized holding gains and losses are excluded from earnings and reported in other comprehensive income, which is a separate component of stockholder's equity. Realized gains or losses are computed based on specific identification of securities that are sold and are included in earnings.
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### DAVINCI CAPITAL MANAGEMENT, INC. NOTES TO FINANCIAL STATEMENTS DECEMBER 31, 2020
#### Note 2
#### Property and equipment
Property and equipment is stated at cost. Depreciation and amortization are calculated on the straight-line method over the estimated useful lives of the related assets. Normal repair and maintenance costs are expensed as incurred.
### Income taxes
The Company accounts for income taxes using an asset and liability approach. The difference between the financial statement and tax basis of assets and liabilities is determined annually. Deferred income tax assets and liabilities are computed for those differences that have future tax consequences using the currently enacted tax laws and rates that apply to the periods in which they are expected to affect taxable income.
Valuation allowances are established, if necessary, to reduce the deferred tax asset to the amount that will more likely than not be realized. Income tax expense or benefit from income taxes is the current tax payable or refundable for the period plus or minus the net change in the deferred tax assets or liabilities.
#### Income tax positions
The Financial Accounting Standards Board ("FASB") issued a standard that clarifies the accounting and recognition of income tax positions taken or expected to be taken in the Company's income tax returns. The Company has analyzed tax positions taken for filing with the Internal Revenue Service and all state jurisdictions where it operates. The Company believes that income tax positions will be sustained upon examination and does not anticipate any adjustments that would result in a material adverse effect on the Company's financial condition, results of operations or cash flows. Accordingly the Company has not recorded any reserves or related accruals for interest and penalties for uncertain income tax positions. If the Company incurs interest or penalties as a result of unrecognized tax positions the policy is to classify interest accrued with interest expense and penalties thereon with operating expenses. The Company is subject to routine audits by taxing jurisdictions; however, there are currently no audits for any tax periods in progress. The Company's federal and state income tax returns are generally open for examination for the past three years.
### Use of estimates
Management uses estimates and assumptions in preparing financial statements. Those estimates and assumptions affect the reported amounts of assets and liabilities, the disclosure of contingent assets and liabilities, and the reported revenues and expenses. Actual results could differ from these estimates.
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### DAVINCI CAPITAL MANAGEMENT, INC. NOTES TO FINANCIAL STATEMENTS (CONTINUED) DECEMBER 31, 2020
#### Note 6 Commissions and fees
Commissions and fees includes life insurance commissions, mutual fund, 12b-1 and investment advisory fees. The recognition and measurement of revenue is based on the assessment of individual contract terms. Significant judgment is required to determine whether performance obligations are satisfied at a point in time or over time; how to allocate transaction prices where multiple performance obligations are identified; when to recognize revenue based on the appropriate measure of the Company's progress under the contract; and whether constraints on variable consideration should be applied due to uncertain future events.
#### Commissions
Life insurance and variable annuities: The Company receives commissions for selling life insurance and variable annuities to its customers. The Company identifies contracts with customers and the performance obligation in these contracts. The Company recognizes revenue upon completion of the performance obligations, at the transaction price stipulated in each contract.
Distribution fees: The Company enters into arrangements with managed accounts or other pooled investment vehicles (funds) to distribute shares to investors. The Company may receive distribution fees paid by the fund up front, over time, upon the investor's exit from the fund (that is, a contingent deferred sales charge), or as a combination thereof. Any fixed amounts are recognized on the trade date and variable amounts are recognized to the extent it is probable that a significant revenue reversal will not occur once the uncertainty is resolved. For variable amounts, as the uncertainty is dependent on the value of the shares at future points in time as well as the length of time the investor remains in the fund, both of which are highly susceptible to factors outside the Company's influence, the Company does not believe that it can overcome this constrain until the market value of the fund and the investor activities are known, which are usually monthly or quarterly. Distribution fees recognized in the current period are primarily related to performance obligations that have been satisfied in prior periods.
#### Asset Management
Investment advisory fees: the company provides investment advisory services on a daily basis. The Company believes the performance obligation for providing advisory services is satisfied over time because the customer is receiving and consuming the benefits as they are provided by the Company. Fee arrangements are based on a percentage applied to the customer's assets under management. Fees are received quarterly and are recognized as revenue on a pro rata basis over the quarter as they relate specifically to the services provided in that period, which are distinct from the services provided in other periods.
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{18}------------------------------------------------
### DAVINCI CAPITAL MANAGEMENT, INC. NOTES TO FINANCIAL STATEMENTS (CONTINUED) DECEMBER 31, 2020
#### Note 11 Related party transactions
Airgead LLC's majority shareholder controls Comprehensive Insurance Providers ("CIP"). The Company leased its office space from CIP Real Estate, LLC whose majority member also controls CIP. Lease expense was \$30,000 for the year ended December 31, 2020. Further details regarding this lease are provided in Note 12.
The Company has entered into an expense sharing agreement with CIP. Under the agreement, a portion of salaries and related expenses, communications and technology that are determined to be attributable to activities of the Company are allocated to the Company. During the year ended December 31, 2020, the Company recorded \$187,062 of the aforementioned expenses. During 2020, CIP forgave \$50,000 of amounts due to them under this agreement. As of December 31, 2020, the Company has an outstanding payable in the amount of \$82,765 to CIP, for amounts owed under the expense sharing agreement.
#### Note 12 Leases-related party
The Company recognizes and measures its leases in accordance with FASB ASC 842. Leases. The Company is a lessee in a noncancelable lease for office space. The Company determines if an arrangement is a lease, or contains a lease, at inception of a contract and when the terms of an existing contract are changed. The Company recognizes a lease liability and a right of use (ROU) asset at the commencement date of the lease liability is initially and subsequently recognized based on the present value of its future lease payments. Variable payments are included in the future lease payments when those variable payments depend on an index or a rate. The discount rate is the implicit rate if it is readily determinable or otherwise the Company uses its incremental borrowing rate. The implicit rate of the lease is the libor rate, which was 3% at inception. The ROU asset is subsequently measured throughout the lease term at the amount of the remeasured lease liability (i.e., present value of the remaining lease payments), plus unamortized initial direct costs, plus (minus) any prepaid (accrued) lease payments, less the unamortized balance of lease incentives received, and any impairment recognized. Lease cost for the lease payments is recognized on a straightline basis over the lease term.
The Company has elected, for all underlying classes of assets, to not recognize ROU assets and lease liabilities for short-term leases that have a lease term of 12 months or less at lease commencement, and do not include an option to purchase the underlying asset that the Company is reasonably certain to exercise. The Company recognizes lease cost associated with short-term leases on a straight -line basis over the lease term
This lease expired on December 31, 2020 and the Company did not renew it. The total lease cost for the year ended December 31, 2020 was \$30,000. The Company is now a tenant-atwill.
{19}------------------------------------------------
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{20}------------------------------------------------
### Schedule I
| DAVINCI CAPITAL MANAGEMENT, INC. |
|----------------------------------------|
| COMPUTATION OF NET CAPITAL PURSUANT TO |
| UNIFORM NET CAPITAL RULE 15c3-1 |
| DECEMBER 31, 2020 |
| Net capital | | | |
|-----------------------------------------------------|--------|------|---------|
| Stockholder's equity | | ಲ್ಲಾ | 174,679 |
| Deductions and charges: | | | |
| Nonallowable assets: | | | |
| Receivables | 42,373 | | |
| Prepaid expenses | 235 | | 42.608 |
| Net capital before haircuts on securities positions | | | 132,071 |
| Haircuts on securities: | | | |
| Trading and investing securities | 18,495 | | |
| Undue concentration | 5.983 | | 24.478 |
| Net capital | | ಲ್ಲಿ | 107,593 |
| Aggregate indebtedness | | S | 188,464 |
| Computation of basic net capital requirement | | | |
| Minimum net capital required | | | 12,564 |
| Minimum dollar net capital required | | | 5,000 |
| Net capital requirement | | | 12,564 |
| Excess net capital | | ಕಾ | 95,029 |
| Net capital less 10% of aggregate indebtedness | | ಕಿತ | 88,747 |
| Percentage of aggregate indebtedness to net capital | | | 175% |
There were no differences between the computation on Schedule I and that filed by the firm on Part IIA of Form X17A-5 for December 31, 2020.
{21}------------------------------------------------
## Schedule II
### DAVINCI CAPITAL MANAGEMENT, INC. COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS AND INFORMATION RELATED TO POSESSION AND CONTROL REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION DECEMBER 31, 2020
The Company is exempt from Rule 15c3-3 pursuant to the provision of subparagraph (k)(2)(i).
{22}------------------------------------------------
100 E. Sybelia Ave. Suite 130 Maitland, FL 32751
Certified Public Accountants Email: pam(aohabco.com
Telephone 407-740-7311 Fax 407-740-6441
#### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
To the Board of Directors and Stockholder's of Davinci Capital Management, Inc.
We have reviewed management's statements, included in the accompanying Exemption Report, in which (1) Davinci Capital Management, Inc. identified the following provisions of 17 C.F.R. §15c3-3(k) under which Davinci Capital Management, Inc. claimed an exemption from 17 C.F.R. §240.15c3-3: (2)(ii) and the Non-Covered Firm Provision, and (2) Davinci Capital Management, Inc. stated that Davinci Capital Management, Inc. met the identified exemption provisions throughout the most recent fiscal year without exception. Davinci Capital Management, Inc. Davinci Capital Management is responsible for compliance with the exemption provisions and its statements.
Our review was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included inquiries and other required procedures to obtain evidence about Davinci Capital Management, Inc.'s compliance with the exemption provisions. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, we do not express such an opinion.
Based on our review, we are not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based on the provisions set forth in paragraph (k)(2)(ii) of Rule 15c3-3 under the Securities Exchange Act of 1934 and the Non-Covered Firm Provision.
Maitland, Florida April 8, 2021
{23}------------------------------------------------
### DaVinci Capital Management, Inc.'s Exemption Report
DaVinci Capital Management, Inc. (the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C.F.R. §240.17a-5, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R. § 240.17a-5(d)(1) and (4). To the best of its knowledge and belief, the Company states the following:
- (1) The Company claimed [an]exemption from 17 C.F.R. § 240.15c3-3 under the following provisions of 17 C.F.R. §240.15c3-3 (k)(2)(ii)
- (2) The Company met the identified exemption provisions in 17 C.F.R. §240.15c3-3 (k) throughout the most recent fiscal year without exception.
- (3) The Company is also filing this Exemption Report because the Company's other business activities contemplated by Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 are limited to: effecting securities transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company; participating in distributions of securities (other than firm commitment underwritings) in accordance with the requirements of paragraphs (a) or (b)(2) of Rule 15c2-4; and/or, and the Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, (other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of Rule 15c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company); (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception.
DaVinci Capital Management, Inc
I, James McSweeney, syear (or affirm) that, to my best knowledge and belief, this Exemption Report is true and correct.
President
March 29, 2021
Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.