# SABLE CAPITAL LLC X-17A-5 (2020-02-14) — Broker-dealer annual report

- Company: SABLE CAPITAL LLC
- Form: X-17A-5
- Filed: 2020-02-14
- Period: 2019-12-31
- Accession: 0001144505-20-000001
- CIK: 1144505
- File #: 8-53400
- Material weakness: No
- Auditor: Goldman and Company
- Auditor location: Marietta, GA
- Contact: Curtis Weeks
- Phone: 678-679-8642
- Signed by: Jonathan Curley (CEO, Chief Compliance Officer)

Original filing: https://www.sec.gov/Archives/edgar/data/1144505/000114450520000001/sable.pdf

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UNITEDSTATES SECURITIESANDEXCHANGECOMMlSSION Washington, D.C. 20549

OMB APPROVAL OMB Number: 3235-0123 Expires: August 31, 2020 Estimated average burden hours per response 12.00

SEC FILE NUMBER

S-534QQ

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

#### 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> S<sup>e</sup>cu<sup>r</sup>iti<sup>e</sup>s Ex<sup>c</sup>hange Act of 1934 and Rule 17<sup>a</sup>-5 Th<sup>e</sup>reu<sup>n</sup>d<sup>e</sup><sup>r</sup>

| REPORT FOR THE PERIOD BEGINNING                                                                         | 01/01/2019                                             | AND ENDING | 12/31/2019                     |
|---------------------------------------------------------------------------------------------------------|--------------------------------------------------------|------------|--------------------------------|
|                                                                                                         | MMfDD!YY                                               |            | MM/DD!YY                       |
|                                                                                                         | A. REGISTRANT IDENTIFICATION                           |            |                                |
| Sable<br>NAME OF BROKER-DEALER:                                                                         | LLC<br>Capital                                         |            | OFFICIAL USE ONLY              |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.)                                       |                                                        |            | FIRM I.D. NO.                  |
| Ave,<br>2820<br>Selwyn<br>Suite<br>375                                                                  |                                                        |            |                                |
|                                                                                                         | (No. and Street)                                       |            |                                |
|                                                                                                         |                                                        |            | 28209                          |
| (City)                                                                                                  | (State)                                                |            | (Zip Code)                     |
| NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT<br>Curtis Weeks<br>678-679-8642 |                                                        |            |                                |
|                                                                                                         |                                                        |            | (Arca Code - Telephone Number) |
|                                                                                                         | B. ACCOUNTANT IDENTIFICATION                           |            |                                |
| INDEPEl\TDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report"                              |                                                        |            |                                |
| Goldman<br>and<br>Company                                                                               |                                                        |            |                                |
|                                                                                                         | (Name - if individual. state last. first, middle name) |            |                                |
| 3535<br>Roswell<br>Rd                                                                                   | Mariette                                               | GA         | 30062                          |
| (Address)                                                                                               | (City)                                                 | (State)    | (Zip Code)                     |
| CHECK ONE:                                                                                              |                                                        |            |                                |
| l/"<br>!certified Public<br>Accountant                                                                  |                                                        |            |                                |
| Public Accountant                                                                                       |                                                        |            |                                |
| B<br>Accountant not resident in United States or any of its possessions.                                |                                                        |            |                                |
|                                                                                                         | FOR OFFICIAL USE ONLY                                  |            |                                |
|                                                                                                         |                                                        |            |                                |

*"Clalms for exemption from th<sup>e</sup>requirement that the annual report be covered by th<sup>e</sup>opinion of an independent public accountan<sup>t</sup> <sup>m</sup>ust b<sup>e</sup>supported by a statement of facts and circumstances relied on as the basis for the exemption. See Section 240.J7<sup>a</sup>-5(e){2)* 

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

SEC 1410 (06-02)

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#### **OATH OR AFFIRMATION**

| 1, Jonathan Curley    |                                                                                                                 | , swear ( or affirm) that, to the best of              |
|-----------------------|-----------------------------------------------------------------------------------------------------------------|--------------------------------------------------------|
| Sable Capital LLC     | my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of | ��������������������������������������������, as       |
| of December 31 , 2019 |                                                                                                                 | are true and correct. I further swear (or affirm) that |
|                       |                                                                                                                 |                                                        |

<sup>n</sup><sup>e</sup>ith<sup>e</sup>r th<sup>e</sup>compa<sup>n</sup>y <sup>n</sup>or any partner, proprietor, principal officer or director has any proprietary interest i<sup>n</sup>any accoun<sup>t</sup> <sup>c</sup>lassified solely as that of a customer, except as foll<sup>o</sup>ws:

Signatur<sup>e</sup> *ee,z<sup>&</sup>gt;* I *&.* <sup>T</sup>�<sup>i</sup>tl<sup>e</sup> *<sup>l</sup>*���

Thi<sup>s</sup>report\*\* contains (ch<sup>e</sup>ck all applicable b<sup>o</sup>xes):

- 0 (a) Facing Page.
- *,<sup>1</sup>*(b) Statement of Financial Condition.
- *,<sup>I</sup>*(c) Statement oflncom<sup>e</sup>(Loss).
- *,<sup>1</sup>*(d) Statement of Changes in Financial Condition.
- *,<sup>1</sup>*(e) Statement of Changes in Stockhold<sup>e</sup>rs' Equity or Partners' or Sole Proprietors' Capital.
- (f) Statement of Changes in Liabiliti<sup>e</sup>s Subordinated to Claims of Cr<sup>e</sup>ditors.
- *or* (g) Computation of Net Capital.
- *or* (h) Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3.
- *,<sup>1</sup>*(i) Information Relating to the Possession or Control Requirements Und<sup>e</sup>r Rule l 5c3-3.
- **O** G) <sup>A</sup>Reconciliation, including appropriate explanation <sup>o</sup>f the Computation <sup>o</sup>fNet Capital Und<sup>e</sup>r Rule l 5c3- l and th<sup>e</sup> <sup>C</sup>omputation for Determination of the Reserve Requirements Und<sup>e</sup>r Exhibit A of Rule 15c3-3.

**0** (k) A Reconciliation between th<sup>e</sup>audited and unaudited Statements of Financial Condition with respect to methods o<sup>f</sup> <sup>c</sup>onsolidation.

- 0 (I) An Oath or Affirmation.
- 

<sup>0</sup>(m) A copy <sup>o</sup>f the SIPC Suppl<sup>e</sup>mental Report. 0 (n) A report d<sup>e</sup>scribing any <sup>m</sup>aterial inad<sup>e</sup>quaci<sup>e</sup>s found to exist or fou<sup>n</sup>d to h<sup>a</sup>ve existed since the date of th<sup>e</sup>previous audit.

\*\* *For conditions of confidential treatment of certai<sup>n</sup>portions <sup>o</sup>f this filing, see section 240. I 7<sup>a</sup>-5 (e)(3).* 

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FINANCIAL STATEMENTS WITH REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM AND ACCOMPANYING INFORMATION

**DECEMBER 31, 2019** 

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# **TABLE** OF CONTENTS

| Report of Independent Registered Public Accounting Firm<br>I                                                                                                                         |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Financial Statements                                                                                                                                                                 |
| Statement of Financial Condition<br>2                                                                                                                                                |
| Statement of Operations<br>3                                                                                                                                                         |
| Statement of Changes in Member's Equity<br>4                                                                                                                                         |
| Statement of Cash Flows<br>5                                                                                                                                                         |
| Notes to Financial Statements<br>6                                                                                                                                                   |
| Supplemental Schedules                                                                                                                                                               |
| -<br>Computation of Net Capital under Rule 15c3-1 of the<br>Schedule I<br>Securities and Exchange Commission<br>9                                                                    |
| Schedule II - Computation for Determination of Reserve R<br>equirement for<br>Brokers and Dealers Pursuant to Rule 15c3-3 under the Securities and<br>Exchange Act of<br>1934<br>l O |
| Schedule Ill - Informat<br>ion Relating to the Possession or Control<br>Requirements under the Securities and Exchange Commission Rule 15c3-3<br>Rule 15c3-3<br>11                   |
| Report oflndependent Registered Public Accounting Firm on<br>Exemption Report<br>12                                                                                                  |
| 13<br>Exemption Report                                                                                                                                                               |

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#### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

Sable Capital, LLC >-

### Opinion on the Financial Statements Z

To the Members of E · We have audited the accompanying statement of financial condition of Sable Capital, LLC as of December 31, <( 2019, the related statements of operations, changes in member's equity and cash flows for the year ended CL December 31, 2019 and the related notes and schedules 1, 2 and 3 (collectively referred to as the "financialu � statements"). In our opinion, the financial statements present fairly, in all material respects, the financial O position of Sable Capital, LLC as of December 31, 2019, and the results of its operations and its cash flows for the period then ended in conformity with accounting principles generally accepted in the United States of America. > o�

### Basis for Opinion

These financial statements are the responsibility of Sable Capital, LLC's management. Our responsibility is to express an opinion on Sable Capital, LLC'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 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, 2, and 3 have been subjected to audit procedures performed in conjunction with the audit of Sable Capital, LLC's financial statements. The supplemental information is the responsibility of Sable Capital, 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 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.l 7a-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 15, 2020

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# **Statement of Financial Condition**

December 31, 2019

#### ASSETS

| Cash and cash equivalents<br>Accounts receivable<br>Prepaid expenses and other assets | \$<br>26,267<br>24,994<br>6,412 |
|---------------------------------------------------------------------------------------|---------------------------------|
| TOTAL ASSETS                                                                          | \$<br>57,673                    |
| LIABILITIES AND MEMBER'S EQUITY                                                       |                                 |
| Liabilities<br>Accounts payable                                                       | \$<br>7,340                     |
| Total Liabilities                                                                     | 7,340                           |
| Member's Equity                                                                       | 50,333                          |
| TOTAL LIABILITIES AND MEMBER'S EQUITY                                                 | \$<br>57,673                    |

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# **Statement of Operations**

Year ended December 31, 2019

| Revenues:         |                |
|-------------------|----------------|
| Other Income      | \$<br>25,014   |
|                   |                |
| Expenses:         |                |
| Registration fees | 9,639          |
| Consulting        | 50,671         |
| Professional fees | 11,369         |
| Rent              | 7,200          |
| Insurance         | 1,155          |
| Miscellaneous     | 506            |
| Total Expenses    | 80,539         |
| NET LOSS          | \$<br>(55,525) |

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# **Statement of Changes in Member's Equity**

Year ended December 31, 2019

|                              | Total<br>Member's<br>Equity |
|------------------------------|-----------------------------|
| Balance at December 31, 2018 | 50,658<br>\$                |
| Capital contributions        | 55,200                      |
| Net loss                     | (55,525)                    |
| Balance at December 31, 2019 | 50,333<br>\$                |

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# **Statement of Cash Flows**

Year ended December 31, 2019

| Cash flows from operating activities:                 |                |
|-------------------------------------------------------|----------------|
| Net loss                                              | \$<br>(55,525) |
| Adjustments to reconcile net loss to net cash used in |                |
| operating activities:                                 |                |
| Increase in operating assets:                         |                |
| Other assets                                          | (291)          |
| Accounts receivable                                   | (24,994)       |
| Decrease in operating liabilities:                    |                |
| Accounts payable                                      | (2,751)        |
| Net cash used in operating activities                 | (83,561)       |
| Cash flows from financing activities:                 |                |
| Capital contributions                                 | 55,200         |
| Net cash provided by financing activities             | 55,200         |
| DECREASE IN CASH AND CASH EQUIVALENTS                 | (28,361)       |
| Cash and cash equivalents, beginning of year          | 54,628         |
| Cash and cash equivalents, end of year                | \$<br>26,267   |

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### Note A - Summary of Organization, Operations, and Significant Accounting and Reporting Policies

# Nature of Operations

Sable Capital, LLC ("Sable" or "the Company"), a Delaware limited liability company, is a registered broker-dealer with the Securities and Exchange Commission ("SEC") and is a member of the Financial Industry Regulatory Authority ("FINRA"). Sable primarily operates as a broker-dealer offering investment banking services and as an underwriter of interstate and intrastate offerings and Direct Participation Program offerings. Sable does not hold cash or securities for its customers. The firm operates from the state of Missouri.

The financial statements do not contain a statement of changes in liabilities subordinated to claims of general creditors as required by Rule 17a-5 of the SEC, as no such liabilities existed at December 31, 2019 or during the year then ended.

# Use of Estimates in Financial Statement Preparation

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 purposes of reporting cash flows, the Company considers all highly liquid debt instruments purchased with a maturity of three months or less to be cash equivalents. The Company's cash and cash equivalents are on deposit with a major domestic financial institution. At times, bank deposits may be in excess of federally insured limits.

## Recognition of Revenues

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.

Revenue is measured based on a consideration specified in a contract with a customer. The Company recognizes revenue when it satisfies a performance obligation by transferring control over goods or service to a customer. Services approved within the scope of ASC 606 include investment banking activities. The Company is approved to provide advisory services/corporate finance activity including mergers and acquisitions, reorganizations, tender offers, leveraged buyouts, fundraising activity and the pricing of securities to be issued.

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### **Note A - Summary of Organization, Operations, and Significant Accounting and Reporting Policies** *(continued)*

For 2019, the Company only had revenue from reimbursement of expenses from its registered representatives.

#### **Income Taxes**

The Company is formed as a single member limited liability company and as such, its operations are included in the Parent Company's tax returns. Earnings and losses of the Company are included in the personal income tax returns of the Parent Company's members. Accordingly, the financial statements do not include a provision for income taxes.

The Company has addressed the provisions of ASC 740-10, *Accounting for Income Taxes.* In that regard, the Company has evaluated its tax positions, expiring statutes of limitations, audits, proposed settlements, changes in tax law and new authoritative rulings and believes that no provision for income taxes is necessary at this time to cover any uncertain tax positions.

#### **Prepaid FINRA Fee**

As a member ofFINRA, the Company is charged annual registration fees. These fees are paid in advance and amortized monthly.

### **Subsequent Events**

The Company has evaluated subsequent events through February 15, 2020, the date the financial statements were issued. It was concluded there were no events or transactions occurring during this period that required recognition or disclosure in the financial statements.

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

### **Note B - Related Party Transactions**

The Company has entered into an expense sharing agreement with its related party for various rent, technology, and other miscellaneous expenditures commensurate with its operations. The term of the expense sharing agreement is monthly until cancelled by either party. The amount payable to the member as of December 31, 2019 for the aforementioned expenses, and included in accounts payable on the statement of financial condition, was \$1,400. Expenses recorded on the Statement of Operations for the year are detailed as follows:

| Rent       | \$<br>7,200 |
|------------|-------------|
| Technology | ,200<br>1   |
|            | \$<br>8.400 |

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### **Note B - Related Party Transactions** *(continued)*

During the year, the member made \$55,200 in capital contributions to Sable of which \$11,200 is debt forgiveness by its related parties.

#### **Note C - Net Capital Requirements**

The Company is subject to the Securities and Exchange Commission's ("SEC's") Uniform Net Capital Rule (SEC Rule 15c3- l) of the Securities Exchange Act of 1934, which requires maintenance of minimum Net Capital. Under the Rule, the Company is required to maintain minimum Net Capital, as defined, equal to the greater of \$5,000 or 6 2/3% of aggregate indebtedness and the ratio of aggregate indebtedness to Net Capital cannot exceed 15 to 1.

At December 31, 2019, the Company had Net Capital of\$18,928 which was \$13,928 in excess of its required Net Capital of \$5,000. The Company's ratio of aggregate indebtedness to Net Capital was 0.39 to 1 at December 31, 2019.

The Company is exempt from the provisions of SEC Rule 15c3-3 under the Securities Exchange Act of 1934, in that the Company's activities are limited to those set forth in the conditions for exemption appearing in paragraph (k)(2)(i) of the Rule.

#### **Note D - Contingencies**

The securities industry is subject to extensive regulation under federal, state, and applicable international laws. Sable is also subject to periodic regulatory audits and inspections. Compliance and trading problems that are reported to regulators, such as the SEC, FINRA, and/or the FDIC by dissatisfied customers or others are investigated by such regulator and may, if pursued, result in formal claims being filed against Sable by the customer or disciplinary action being taken against Sable by the regulator that could have a material impact on the Company's financial position, results of its operations, or cash flows. At December 31, 2019, management is not aware of any regulatory issues and there were no amounts levied against the Company as a result of regulatory assessments for the year then ended.

#### **Note E - Concentrations**

The Company had revenue from I source in 2019.

# **Note F-Basis of Accounting**

These financial statements are prepared on the accrual basis of accounting in accordance with accounting principals generally accepted in the United States.

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Supplemental Schedules

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### **Sable Capital, LLC**

### **Schedule I - Computation of Net Capital under Rule 15c3- 1 of the Securities and Exchange Commission**

#### COMPUTATION OF NET CAPITAL Total member's equity Deductions: Non-allowable assets: Accounts receivable Other assets Net capital before haircuts Haircuts: Total haircuts NET CAPITAL \$ \$ 50,333 24,994 6,411 18,928 18,928 COMPUTATION OF AGGREGATE INDEBTEDNESS Items included in the statement of financial condition: Accounts payable, accrued expenses, and other liabilities Total aggregate indebtedness COMPUTATION OF BASIC NET CAPITAL REQUIREMENT Minimum net capital required Excess net capital Ratio of aggregate indebtedness to net capital 7,340 \$ 7,340 \$ 5,000 \$ 13,928 0.39 to 1

#### **December 31, 2019**

There is no difference in the above computation and the Company's net capital as reported in the Company's Part *IJA* (unaudited) FOCUS report as of December 31, 2019.

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# **Sable Capital, LLC**

# **Schedule II - Computation for Determination of Reserve Requirements for Brokers and Dealers Pursuant to Rule 15c3-3 under the Securities and Exchange Act of 1934**

The Company qualifies under the exemption provision of Rule 15c3-3 under the Securities Exchange Act of 1934, pursuant to paragraph (k)(2)(i) of the Rule and does not hold customers' monies or securities.

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# **Sable Capital, LLC**

# **Schedule** Ill - **Information Relating to the Possession or Control Requirements under the Securities and Exchange Commission Rule 15c3-3**

The Company is exempt from the provisions of Rule l 5c3-3 under the Securities Exchange Act of 1934, pursuant to paragraph (k)(2)(i) of the Rule and does not hold customers' monies or securities.

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#### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

### To the Members of Sable Capital, LLC

We have reviewed management's statements, included in the accompanying Sable Capital, LLC's �--- z Annual Exemption Report, in which (1) Sable Capital, LLC identified the following provisions of 17 < C.F.R. § 15c3-3(k) under which Sable Capital, LLC claimed an exemption from 17 C.F .R. 0... §240.15c3-3: k(2)(i) (the "exemption provisions") and (2) Sable Capital, LLC stated that Sableu � Capital, LLC met the identified exemption provisions throughout the most recent fiscal year without O exception. Sable Capital, LLC's management is responsible for compliance with the exemption u

provisions and its statements. ; � <sup>o</sup>� uIJ 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 Sable Capital, LLC'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)(i) of Rule l 5c3-3 under the Securities Exchange Act of 1934.

Goldman & Company, CPA's, P.C. Marietta, GA February 15, 2020

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# **SABLE CAPITAL**  Member FINRA/SIPC

### EXEMPTION REPORT YEAR ENDED DECEMBER 31, 2019

Sable LLC (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 §15c3-3 under the following provisions of 17 C.F.R §240.15c3-3: (k)(2)(i)

and

2. The Company met the identified exemption provisions in 17 C.F.R §240.15c3-3 (k)(2)(i) throughout the most recent fiscal year ended December 31, 2019 without exception.

I affirm that, to the best of my knowledge and belief, this Exemption Report is true and correct.

| By:             |
|-----------------|
| Title:          |
| (<br>Date:<br>( |


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