# ASHTON STEWART & CO., INC. X-17A-5 (2023-03-29) — Broker-dealer annual report - Company: ASHTON STEWART & CO., INC. - Form: X-17A-5 - Filed: 2023-03-29 - Period: 2022-12-31 - Accession: 0001137879-23-000001 - CIK: 1137879 - File #: 8-53239 - Type: Broker-dealer - Material weakness: No - Auditor: Goldman & Company, CPA's, PC - Auditor location: Marietta, GA - Contact: Ana R Carter - Phone: 813-442-1645 - Email: ana@cartanaconsulting.com - Website: cartanaconsulting.com - Signed by: Ana R Carter (FINOP) Original filing: https://www.sec.gov/Archives/edgar/data/1137879/000113787923000001/asco22.pdf --- {0}------------------------------------------------ #### **UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549** 0MB APPROVAL 0MB Number: 3235-0123 Expires: Oct. 31, 2023 Estimated average burden hours per response: 12 # **ANNUAL REPORTS FORM X-17A-5 PART** Ill | hours per response: 12 | | |------------------------|--| | SEC FILE NUMBER | | | 8-53239 | | # **FACING PAGE Information Required Pursuant to Rules 17a-S, 17a-12, and 18a-7 under the Securities Exchange Act of 1934** FILING FOR THE PERIOD BEGINNING \_\_\_ 0\_1/\_0\_1\_/2\_2 \_\_\_ AND ENDING \_\_\_ 12\_/\_3\_1/\_2\_2 \_\_ \_ MM/DD/YY MM/DD/VY **A. REGISTRANT IDENTIFICATION** NAME OF FIRM: \_\_\_\_ A\_s\_h\_to\_n\_S\_te\_w\_a\_rt\_&\_C\_o\_.\_, \_ln\_c\_. --------------- TYPE OF REGISTRANT (check all applicable boxes): 0 Broker-dealer D Security-based swap dealer □ Major security-based swap participant D Check here if respondent is also an OTC derivatives dealer ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) 1395 Brickell Ave,m Suite 800 {No. and Street} Miami FL (City) (State) PERSON TO CONTACT WITH REGARD TO THIS FILING 33131 (Zip Code) Ana R. Carter 813-442-1645 ana@cartanaconsulting.com (Name) (Area Code - Telephone Number) (Email Address) **B. ACCOUNTANT IDENTIFICATION** INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing\* Goldman & Company, CPA's, P.C. (Name - if individual, state last, first, and middle name) 3535 Roswell Rd., Ste 32 Marietta GA (Address) (City) (State) 06/25/2009 l" of'"'"'""'" with PCAOB)(if appliQble) **FOR OFFICIAL USE ONLY** 1952 30062 (Zip Code) \* Claims for exemption from the requirement that the annual reports be covered by t h e reports of an independent public accountant must be supported by a statement of facts and circumstances relied on as the basis of the exemption. See 17 CFR 240.17a-5(e)(l){ii), if applicable. Persons who are to respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid 0MB control number. {1}------------------------------------------------ #### **OATH OR AFFIRMATION** | I, | Ana R. Carter | | , swear (or affirm) that, to the best of my knowledge and belief, the | | |----|--------------------------------------------|----|-----------------------------------------------------------------------------------|-------| | | financial report pertaining to the firm of | | Ashton Stewart & Co., Inc. | as of | | | December 31 | 2~ | is true and correct. I further swear (or affirm) that neither the company nor any | | partner, officer, director, or equivalent person, as the case may be, has any proprietary interest in any account classified solely as that of a customer. ,,,11\\lll *llt/111* ,,,,,, ?, \: SA *A • 1111111 ~'- '<'~.... ~ .•. ':>"' -i,0 ·• **\J '** ,, ~ ~ , .. ,\$', ?··. ~ :: ...J \_:{: ·<.J>.l'\Y t,· .. *&.* ~ jj 1 =a: *:* o O ,-v : (!) :: \_j ::: i :U ~--• v' ; CI:~ ~ • ;:\_ lfl *• .*.7 p l.)~ ~ ... 0 2 :..( *L!'J... tY/.u,,f;:,\_* . ·':f '.'I,<:)/ &' 2 .. N~o-ta-r~y-P~u~o=,i~c~- ~--=~~~~% *1~·-.. 9.~.-.'?-~~·~..,\_ .*. / *1111 1*Yo co0~ ,,,,, *11111* I// 11 I\ I\ 1111\\ Signature: *~ Q\_Qk* Title: **FINOP** #### **This filing\*\* contains (check all applicable boxes):** - 0 (a) Statement of financial condition. - D (b) Notes to consolidated statement of financial condition. - **0** (c) Statement of income {loss) or, if there is other comprehensive income in the period(s) presented, a statement of comprehensive income (as defined in§ 210.1-02 of Regulation S-X). - 0 {d) Statement of cash flows. - 0 (e) Statement of changes in stockholders' or partners' or sole proprietor's equity. - D (f) Statement of changes in liabilities subordinated to claims of creditors. - 0 (g) Notes to consolidated financial statements. - 0 {h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-1, as applicable. - D (i) Computation of tangible net worth under 17 CFR 240.18a-2. - 0 (j} Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3. - D (kl Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.15c3-3 or Exhibit A to 17 CFR 240.18a-4, as applicable. - D (I) Computation for Determination of PAB Requirements under Exhibit A to § 240.15c3-3. - 0 (m) Information relating to possession or control requirements for customers under 17 CFR 240.1Sc3-3. - D (n) Information relating to possession or control requirements for security-based swap customers under 17 CFR 240.15c3-3(p)(2) or 17 CFR 240.18a-4, as applicable. - D (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capital or tangible net worth under 17 CFR 240.15c3-1, 17 CFR 240.18a-l, or 17 CFR 240.18a-2, as applicable, and the reserve requirements under 17 CFR 240.15c3-3 or 17 CFR 240.18a-4, as applicable, if material differences exist, or a statement that no material differences exist. - D (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition. - 0 (q) Oath or affirmation in accordance with 17 CFR 240.17a-S, 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable. - D (r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - 0 (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - D (t) Independent public accountant's report based on an examination of the statement of financial condition. - 0 (u) Independent public accountant's report based on an examination of the financial report or financial statements under 17 CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable. - D (v) Independent public accountant's report based on an examination of certain statements in the compliance report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - 0 (w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - 0 (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-le or 17 CFR 240.17a-12, as applicable. - 0 (y) Report describing any material inadequacies found to exist or found to have existed since the date of the previous audit, or a statement that no material inadequacies exist, under 17 CFR 240.17a-12(k). D(z) Other:--- - - - ---- - --- --- - - --------------------- - - *\*\*To request confidential treatment of certain portions of this filing, see 17 CFR 240.17a-5(e)(3) or 17 CFR 240.18a-7(d)(2), as applicable.* {2}------------------------------------------------ #### REPORT PURSUANT TO RULE 17a-5 ASHTON STEWART & CO., INC. FINANCIAL STATEMENTS AND REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM AS OF AND FOR THE YEAR ENDED DECEMBER 31, 2022 {3}------------------------------------------------ ## Ashton Stewart & Co., Inc. Table of Contents Page | Report of Independent Registered Public Accounting Firm | 1 | | |-------------------------------------------------------------------------------------------------------------------|-----|--| | Statement of Financial Condition | 2 | | | Statement of Operations | 3 | | | Statement of Changes in Stockholder's Equity | 4 | | | Statement of Cash Flows | 5 | | | Notes to Financial Statements | 6-9 | | | SUPPLEMENTAL INFORMATION | | | | Schedule I – Computation of Net Capital Under Rule 15c3-1
Of the Securities and Exchange Commission | 10 | | | Schedule II & III. Management Statement from Exemption 15c3-3 | 11 | | | Review Report Of The Independent Registered Accounting Firm Of
Firm's 17a-5(d)(4) Exemption Report | 12 | | | Exemption Report Of Ashton Stewart & Co., Inc. Pursuant To
Securities And Exchange Commission Rule 17a-5(d)(4) | 13 | | | | | | {4}------------------------------------------------ #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Shareholder of Ashton Stewart & Co., Inc. #### Opinion on the Financial Statements We have audited the accompanying statement of financial condition of Ashton Stewart & Co., Inc as of December 31, 2022 the year then ended and the related notes and schedules I, II and III nancial statements present fairly, in all material respects, the financial position of Ashton Stewart & Co., Inc as of December 31, 2022, and the results of its operations and its cash flows for the year then ended in conformity with accounting principles generally accepted in the United States of America. #### Basis for Opinion These financial statements are the responsibility of Ashton Stewart & Co., Inc's management. Our inancial 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 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-I, Schedule II-Computation for Determination of Reserve Requirements Pursuant to SEC Rule 15c3-3 (exemption) and Schedule III-Information Relating to Possession or Control Requirements Pursuant to SEC Rule 15c3-3 (exemption) have 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 schedule's I, II. and III 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. .C. Marietta, Georgia March 28, 2023 {5}------------------------------------------------ ## Ashton Stewart & Co., Inc. Statement of Financial Condition December 31, 2022 #### ASSETS | Ashton Stewart & Co., Inc.
Statement of Financial Condition
December 31, 2022 | | |------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------| | ASSETS | | | Cash and Cash Equivalents | \$
53,868 | | Due from Officer | 19,500 | | Prepaid Expenses
Investment | 12,158
3,591 | | | | | Total assets | \$
89,117 | | LIABILITIES AND STOCKHOLDER'S EQUITY | | | Liabilities | 5,165 | | STOCKHOLDER'S EQUITY:
Preferred stock, 20,000,000 undesignated shares authorized
no shares issued and outstanding
Common stock, \$.001 par value, 80,000,000 shares | | | authorized, 8,500,000 shares issued and outstanding | 8,500 | | Additional paid-in capital | 305,376 | | Accumulated (deficit) | (229,924) | | Total Stockholder's Equity | 83,952 | | Total Liabilities and Stockholder's Equity | \$
89,117 | {6}------------------------------------------------ ## Statement of Operations For The Year Ended December 31, 2022 Ashton Stewart & Co., Inc. | Ashton Stewart & Co., Inc.
Statement of Operations
For The Year Ended December 31, 2022 | | |-----------------------------------------------------------------------------------------------|-----------------| | | | | REVENUES: | | | Investment Banking & M&A Consulting | \$
1,447,836 | | Affiliation and Compliance Fees | 216,033 | | Total revenues | 1,663,869 | | EXPENSES: | | | Consulting Fees, Commissions, Payroll | 1,592,720 | | Technology Costs | 10,845 | | Regulatory fees | 13,286 | | Travel & Enteriment | 52,754 | | Other operating | 71,250 | | Total expenses | 1,740,855 | | INCOME BEFORE PROVISION FOR INCOME TAXES | (76,986) | | Provision for income taxes | - | | NET LOSS | \$
(76,986) | | | | {7}------------------------------------------------ #### Ashton Stewart & Co., Inc. Statement of Changes in Stockholder's Equity For the Year Ended December 31, 2022 | Ashton Stewart & Co., Inc.
Statement of Changes in Stockholder's Equity
For the Year Ended December 31, 2022
Additional
Common Stock
Paid in
Accumulated | | | | | | |----------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------|--------|---------|-----------|-------| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | Shares | Amount | Capital | (Deficit) | Total | | Balance, December 31, 2021
8,500,000
\$
8,500
\$
305,436
\$
(152,938)
\$
160,998 | | | | | | | Distribution
(60)
(60)
Net Loss
(76,986)
(76,986) | | | | | | {8}------------------------------------------------ ## Ashton Stewart & Co., Inc. Statement of Cash Flows For The Year Ended December 31, 2022 | Ashton Stewart & Co., Inc. | | | |------------------------------------------------|----------------|--| | Statement of Cash Flows | | | | For The Year Ended December 31, 2022 | | | | | | | | OPERATING ACTIVITIES | | | | Net Loss | \$
(76,986) | | | Adjustments to reconcile net loss to net cash | | | | Used in operating activities: | | | | Accounts receivable | 1,500 | | | Due from officer | (19,500) | | | Prepaid expenses | (12,158) | | | Accounts payable | 5,165 | | | Net cash used by operating activities | (101,979) | | | | | | | FINANCING ACTIVITIES | | | | Distributed capital | (60) | | | Net used by financing activities | (60) | | | | | | | NET DECREASE IN CASH AND CASH EQUIVALENTS | (102,039) | | | CASH AND CASH EQUIVALENTS AT BEGINNING OF YEAR | 155,907 | | | CASH AND CASH EQUIVALENTS AT END OF YEAR | \$
53,868 | | {9}------------------------------------------------ ## Organization Note 1 – Organization and Summary of Significant Accounting Policies Ashton Stewart & Co., Inc. (the Company), formerly MAS Capital Securities, Inc. and Vantage Securities, Inc., was incorporated as MAS Trade.net, Inc., on September 27, 1999, in the State of Indiana. On October 29, 2001, the Company changed its name to MAS Capital Securities, Inc. During November 2002, the Company's sole shareholder entered into an agreement to sell all of the issued and outstanding shares of the Company to Vantage Advisor Group, LLC (VAG or LLC). The name was then changed to Vantage Securities, Inc. During 2010, in an effort to rebrand the firm to more adequately reflect its investment banking line of business the name was changed to Ashton Stewart & Co., Inc. During 2015 the shares of the Company were sold. The Company will continue to operate under the new ownership. The new ownership has injected capital into the Company and will continue to do so to ensure the Company meets regulatory requirements. The Company is a broker-dealer registered with the Securities and Exchange Commission (SEC) and is a member of the Financial Regulatory Authority (FINRA). ## Revenue Recognition On January 1, 2018, the Company adopted ASU 2014-09 Revenue from Contracts with Customers and all subsequent amendments to the ASU (collectively, "ASC 606"), which creates a single framework for recognizing revenue from contracts with customers that fall within its scope. a. Investment banking M&A advisory fees Refer to Revenue Recognition Note: Revenue from Contracts with Customers for further discussion on the Company's accounting policies for revenue sources within the scope of ASC 606. #### Investment Banking, Merger and Acquisition (M&A) Services: These services include agreements to provide advisory services to customers for which they charge the customers fees. The Company provides advisory services/corporate finance activity including mergers and acquisitions, reorganizations, tender offers, leveraged buyouts, fundraising activity and the pricing of securities to be issued. #### Affiliation and Compliance Services: The services include amounts billed under agreements with its registered reps for the services the Firm provides that include supervision, due diligence and review of possible transactions, this amount was \$160,820 for 2022 and is included in Affiliation and Compliance Fees on the statement of operations. {10}------------------------------------------------ ## Registered Representative Reimbursement: These services are reimbursed expenses from the Company's registered representatives. The Company receives reimbursements from its registered representatives for specific costs, this amount was \$55,213 for 2022 and is included in Affiliation and Compliance Fees on the statement of operations. #### Income Taxes The Company follows FASB ASC 740-10 for recording the provision for income taxes. Deferred tax assets and liabilities are computed based upon the difference between the financial statement and income tax basis of assets and liabilities using the enacted marginal tax rate applicable when the related asset or liability is expected to be realized or settled. Deferred income tax expenses or benefits are based on the changes in the asset or liability each period. If available evidence suggests that it is more likely than not that some portion or all of the deferred tax assets will not be realized, a valuation allowance is required to reduce the deferred tax assets to the amount that is more likely than not to be realized. Future changes in such valuation allowance are included in the provision for deferred income taxes in the period of change. The Company has no uncertain tax positions at December 31, 2022. Deferred taxes are classified depending on the assets and liabilities to which they relate. #### 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 significantly from those estimates. #### Related Party Transactions The Company has an agreement with a related party in which the Company provides consulting services and registered reps to the related party. The consulting fees are \$11,000 per month and \$400 per month per registered representative. The agreement began in 2019 and was amended in February of 2021. The agreement was for 12 months and has continued to renew annually. The amounts received for these services are \$132,000 and \$19,200, respectively, in 2022. #### Cash and Cash Equivalents The Company considers all liquid investments with original maturities of three months or less to be cash equivalents. The Company had no cash equivalents as of December 31, 2022. {11}------------------------------------------------ ## Cash and Cash Equivalents (continued) The Company maintains its cash balances in one financial institution, which at times, may exceed federally insured limits. The Company has not experienced any losses in such accounts and believes it is not subject to significant credit risk related to cash. #### 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. The Company is evaluating new accounting standards and will implement as required. #### Note 2 – Income Taxes The Company has unused Federal Income Tax operating loss carry forwards related to our operations of approximately \$201,489 which expire between 2027 and 2033. The Company has not recorded a tax provision or tax payable as it chooses to apply the current provision to the deferred tax asset. The deferred tax asset has been written off as the Company believes the utilization of the asset is not probable. #### Note 3 – 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, both as defined, shall not exceed 15 to 1. At December 31, 2022, the Company had net capital of \$48,703, which was \$43,703, in excess of its required net capital of \$5,000. The Company's percentage of aggregative indebtedness to net capital was 10.61%. #### Note 4 – Subsequent Events Subsequent events have been evaluated through March 28, 2023, which is the date the financial statements were issued. The Company has determined that there are no material subsequent events requiring adjustment to or disclosure in its financial statements. #### Note 5 – Commitments and Contingencies The Company leases a virtual office on an annual contract for \$1,812 per year. {12}------------------------------------------------ #### Note 6 – Fair Value of Investments Fair Value: The Company classifies its investment assets in accordance with Financial Accounting Standards Board (FASB) Accounting Standards Codification (ASC) 820, Fair Value Measurements. FASB ASC 820 establishes a hierarchy of inputs to fair value measurements as follows: All of the Company's investments are gold bonds and are considered Level 3 - Level 1 Quoted prices in active markets for identical assets or liabilities. - Level 2 Inputs that derived principally from or corroborated by observable market data. - Level 3 Inputs that are unobservable and significant to the overall fair value measurement. investments. The Company purchased 2 ounces of gold through a gold bond for \$3,591 the bond maturing and the gold is carried at cost. There is no material income on this investment for 2022. Securities Owned are carried at fair value in accordance with FASB ASC 820, fair value measurements. Realized gains and losses on disposition are based on the net proceeds and the adjusted book value of the securities sold, using the specific identification method. Unrealized gains and losses on marketable securities are based on the difference between cost basis and fair value of each security. #### Note 7 – Concentrations Revenue from investment banking and consulting came from 3 clients in 2022. #### Note 8 – Accounts Receivable The Company had no accounts receivable at December 31, 2022 or 2021. #### Note 9 – Going Concern The Company has sustained recurring losses and negative cash flows from operations over the past year. The Company's owner is committed to keeping the Company operating for the next 12 to 24 months via capital contributions, if necessary. Therefore, it will be able to meet its commitments and net capital requirements for that time period. {13}------------------------------------------------ ## December 31, 2022 Ashton Stewart & Co., Inc. Schedule I - Computation Of Net Capital Under Rule 15c3-1 Of The Securities And Exchange Commission | Ashton Stewart & Co., Inc.
Schedule I - Computation Of Net Capital Under Rule 15c3-1 | | |-----------------------------------------------------------------------------------------|--------------| | Of The Securities And Exchange Commission
December 31, 2022 | | | Stockholder's Equity per Statement of Financial Condition | \$
83,952 | | Less: Nonallowable assets | 35,249 | | Net capital | \$
48,703 | | Aggregate indebtedness - items included in financial statements | \$
5,165 | | Basic net capital requirement (\$5,000 minimum) | \$
5,000 | | Excess net capital | \$
43,703 | | Precent aggregate indebtedness to net capital | 10.61% | calculation of net capital as reflected on the Form 17a-5, Part IIA, as amended There were no differences between the above calculation and the Company's {14}------------------------------------------------ ## Ashton Stewart & Co., Inc. Schedules II & III - Computation for Determination of Reserve Requirements and Information Relating to the Possession and Control Requirements Under Rule 15c3-3 December 31, 2022 ## SCHEDULE II #### COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION The Firm does not claim an exemption under paragraph (k) of 17 C.F.R. § 240.15c3-3; and the Firm is filing this Exemption Report in reliance on Footnote 74 to SEC Release 34-70073 and as discussed in Q&A 8 of the related FAQ issued by SEC staff. The Firm has no obligation under SEC Rule 15c3-3 because it does not directly or indirectly receive, hold or otherwise owe funds or securities for or to customers; does not carry accounts of or for customers; and does not carry PAB accounts. #### SCHEDULE III #### INFORMATION RELATING TO THE POSSESSION OR CONTROL REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION The Firm does not claim an exemption under paragraph (k) of 17 C.F.R. § 240.15c3-3; and the Firm is filing this Exemption Report in reliance on Footnote 74 to SEC Release 34-70073 and as discussed in Q&A 8 of the related FAQ issued by SEC staff. The Firm has no obligation under SEC Rule 15c3-3 because it does not directly or indirectly receive, hold or otherwise owe funds or securities for or to customers; does not carry accounts of or for customers; and does not carry PAB accounts. {15}------------------------------------------------ #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Stockholder of Ashton Stewart & Co., Inc. We have reviewed management's statements, included in the accompanying Rule 15c3-3 Exemption Report pursuant to SEC Rule 17a-5, in which (1) Ashton Stewart & Co., Inc.(the Company) did not claim an exemption under paragraph (k) of 17 C.F.R. §240.15c3-3, and (2) the Company is filing this Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 because the Company limits its business activities exclusively to include receiving transaction-based compensation for identifying potential merger and acquisition opportunities, private placement of securities and investment banking for clients. In addition, the Company 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; did not carry accounts of or for customers; and did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception. Ashton Stewart & Co., Inc. tion 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 Ashton Stewart & Co., Inc. 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 templated by Footnote 74 of the SEC Release No. 34- 70073 adopting amendments to 17 C.F.R. § 240.17a-5, and related SEC Staff Frequently Asked Questions. Goldman & Company, Marietta, Georgia March 28, 2023 {16}------------------------------------------------ # **Ashton Stewart** & **Co., Inc.** #### **EXEMPTION REPORT** Ashton Stewart & Co., Inc. ("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: - (1) The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240.15c3-3, and - (2) The Company is filing this Exemption Report relying on Footnote 74 of the SEC Release No. 34- 70073 adopting amendments to 17 C.F.R. § 240.17a-5 because the Company limits its business activities exclusively to 1) 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; (2) receiving transaction-based compensation for identifying potential merger and acquisition opportunities for clients, referring securities transactions to other broker-dealers, or providing technology or platform services; (3) 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 the company (1) did not directly or indirectly receive, hold or otherwise owe funds or securities for or to customers; (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent year without exception. The Firm had no exceptions to the provision identified above throughout the most recent fiscal year. I, Ana R. Carter, swear (or affirm) that, to my best knowledge and belief, this Exemption Report is true and correct. Authorized Signature CFO & FINOP Title February 6, 2023 Date {17}------------------------------------------------ #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM ON APPLYING AGREED-UPON PROCEDURES To the Shareholder and Management of Ashton Stewart & Co, Inc. Carolina Financial Securities, LLC We have performed the procedures included in Rule 17a-5(e)(4) under the Securities Exchange Act of 1934 and in the Securities Investor Protection Corporation (SIPC) Series 600 Rules, which are enumerated below on the accompanying General Assessment Reconciliation (Form SIPC-7) for the year ended December 31, 2022. Management of Ashton Stewart & Co Inc. (the Company) is responsible for its Form SIPC-7 and for its compliance with the applicable instructions on Form SIPC-7. Management of the Company has agreed to and acknowledged that the procedures performed are appropriate to meet the intended purpose of assisting you and SIPC in evaluating the Compa ce with the applicable instructions on Form SIPC-7 for the year ended December 31, 2022. Additionally, SIPC has agreed to and acknowledged that the procedures performed are appropriate for their intended purpose. This report may not be suitable for any other purpose. The procedures performed may not address all the items of interest to a user of this report and may not meet the needs of all users of this report and, as such, users are responsible for determining whether the procedures performed are appropriate for their purposes. 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 associated findings are as follows: - 1) Compared the listed assessment payments in Form SIPC-7 with respective cash disbursement, 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, 2022 with the Total Revenue amount reported in Form SIPC-7 for the year ended December 31, 2022, 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 (if any) applied to the current assessment with the Form SIPC-7 on which it was originally computed, noting no differences. We were engaged by the Company to perform this agreed-upon procedures engagement and conducted our engagement in accordance with attestation standards established by the AICPA and in accordance with the standards of the Public Company Accounting Oversight Board (United States). We were not engaged to and did not conduct an examination or a review engagement, the objective of which would be the expression of an C-7 and for its compliance with the applicable instructions on Form SIPC-7 for the year ended December 31, 2022. 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. We are required to be independent of the Company and to meet our other ethical responsibilities in accordance with the relevant ethical requirements related to our agreed-upon procedures engagement. This report is intended solely for the information and use of Ashton Stewart & Co, Inc. and the SIPC and is not intended to be and should not be used by anyone other than these specified parties. Gol P.C. Marietta, Georgia March 28, 2023 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.