# RCX CAPITAL GROUP, LLC X-17A-5 (2020-03-17) — Broker-dealer annual report

- Company: RCX CAPITAL GROUP, LLC
- Form: X-17A-5
- Filed: 2020-03-17
- Period: 2019-12-31
- Accession: 0001145068-20-000001
- CIK: 1145068
- File #: 8-53416
- Material weakness: No
- Auditor: McBee & Co.
- Auditor location: Dallas, TX
- Contact: Jean-Louis Guinchard
- Phone: 858-232-5887
- Website: mcbecco.com
- Signed by: Jean-Louis Guinchard (President)

Original filing: https://www.sec.gov/Archives/edgar/data/1145068/000114506820000001/rcxaudit.pdf

---

{0}------------------------------------------------

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

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

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

| SEC FILE NUMBER |
|-----------------|
| S-53416         |

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 01/01/2019                                                                                               | ~~~~~~~~~~~                                            |         | AND ENDING 12/31/2019          |  |
|------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------|---------|--------------------------------|--|
|                                                                                                                                          | MM/ DD/YY                                              |         | MM/DD/VY                       |  |
|                                                                                                                                          | A. REGISTRANT IDENTIFICATION                           |         |                                |  |
| NAME of BROKER-DEALER: ACX Capital Group, LLC                                                                                            |                                                        |         | OFFICIAL USE ONLY              |  |
| ADDRESS Of PRINCIPAL PLACE Of BUSINESS: (Do not use P.O. Box No.)                                                                        |                                                        |         | FIRM l.D. NO.                  |  |
| 2002 Timberloch Place, Suite 200                                                                                                         |                                                        |         |                                |  |
|                                                                                                                                          | (No. and Street)                                       |         |                                |  |
| The Woodlands                                                                                                                            | Texas                                                  |         | 77381                          |  |
| (City)                                                                                                                                   | (State)                                                |         | (Zip Code)                     |  |
| NAME AND TELEPHONE NUMBER OF PERSON TO CONT ACT IN REGARD TO THIS REPORT<br>Joan-Louis Gulnchard                                         |                                                        |         | 858-232-5887                   |  |
|                                                                                                                                          |                                                        |         | (Area Code - Telephone Number) |  |
|                                                                                                                                          | B. ACCOUNT ANT IDENTIFICATION                          |         |                                |  |
| INDEPENDENT PUBLIC ACCOUNT ANT whose opinion is contained in this Report*                                                                |                                                        |         |                                |  |
| McBee & Co.                                                                                                                              |                                                        |         |                                |  |
|                                                                                                                                          | (Name - if iudividual, state last, first, middle uame) |         |                                |  |
| 718 Paulus Avenue                                                                                                                        | Dallas                                                 | Texas   | 75214                          |  |
| (Address)                                                                                                                                | (C i1y)                                                | (S1a1e) | (Zip Code)                     |  |
| CHECK ONE:                                                                                                                               |                                                        |         |                                |  |
| It/ l<br>Ccrti tied Pub I ic Accountant<br>B<br>Public Accountant<br>Accountant not resident in United States or any of its possessions. |                                                        |         |                                |  |
|                                                                                                                                          | FOR OFFICIAL USE ONLY                                  |         |                                |  |
|                                                                                                                                          |                                                        |         |                                |  |

*•claims for exemption from the requirement that the annual report be covered by the opinion of an independent public accountant must be supported by a statement of facts and circumstances relied on as the basis for the exemption. See Section 240. l 7a-5(e)(2)* 

> Potential persons who are to respond to the collection of Information contained In this form are not required to respond unless the form dis plays a currently valid OMB control number .

SEC 1410 (06-02)

•

{1}------------------------------------------------

#### OATH OR AFFIRMATION

| I, Jean-Louis Guinchard                                                                                                                          | , swear (or affirm) that, to the best of                                                                                        |      |
|--------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------|------|
| RCX Capital Group, LLC                                                                                                                           | my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of                 | , as |
| of December 31                                                                                                                                   | 20 19<br>are true and correct. I further swear (or affirm) that                                                                 |      |
| . . _ - classified ~olely as that of a customer, except as follows:                                                                              | neither the company nor any partner, proprietor, principal officer or director has any proprietary interest in any account      |      |
| -<br>. -·                                                                                                                                        |                                                                                                                                 |      |
| -. -<br>. -~~_                                                                                                                                   |                                                                                                                                 |      |
|                                                                                                                                                  |                                                                                                                                 |      |
|                                                                                                                                                  |                                                                                                                                 |      |
|                                                                                                                                                  |                                                                                                                                 |      |
|                                                                                                                                                  |                                                                                                                                 |      |
|                                                                                                                                                  |                                                                                                                                 |      |
|                                                                                                                                                  | Title                                                                                                                           |      |
|                                                                                                                                                  |                                                                                                                                 |      |
|                                                                                                                                                  |                                                                                                                                 |      |
|                                                                                                                                                  |                                                                                                                                 |      |
| This report** contains (check all applicable boxes):                                                                                             | Lynda Derenzis<br>Notary Pub! ic-Con neetleut                                                                                   |      |
| 0 (a) Facing Page.                                                                                                                               | My Commission Expires                                                                                                           |      |
| (b) Statement of Financial Condition.<br>v'                                                                                                      | November30. 2024                                                                                                                |      |
| I<br>(c) Statement of Income (Loss).                                                                                                             |                                                                                                                                 |      |
| ( d) Statement of Changes in Financial Condition.<br>(e) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors' Capital. |                                                                                                                                 |      |
| (f) Statement of Changes in Liabilities Subordinated to Claims of Creditors .                                                                    |                                                                                                                                 |      |
| (g) Computation of Net Capital.<br>.t                                                                                                            |                                                                                                                                 |      |
| (h) Computation for Determination of Reserve Requirements Pursuant to Rule l 5c3-3 .<br>.f                                                       |                                                                                                                                 |      |
| (i) Information Relating to the Possession or Control Requirements Under Rule l 5c3-3 .<br>'f'<br>0 (j)                                          | A Reconciliation, including appropriate explanation of the Computation of Net Capital Under Rule l 5c3-l and the                |      |
|                                                                                                                                                  | Computation for Determination of the Reserve Requirements Under Exhibit A of Rule l 5c3-3.                                      |      |
| consolidation.                                                                                                                                   | 0 (k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of           |      |
| (l) An Oath or Affirmation.<br>,                                                                                                                 |                                                                                                                                 |      |
| (m) A copy of the SIPC Supplemental Report.<br>~                                                                                                 |                                                                                                                                 |      |
|                                                                                                                                                  | (n) A report describing any material inadequacies found to exist or found to have existed since the date of the previous audit. |      |
| **For conditions of confidential treatment of certain portions of this filing, see section 240.                                                  | 17a-5(e)(3).                                                                                                                    |      |

{2}------------------------------------------------

![](_page_2_Picture_0.jpeg)

**A** d, -tl :"1: l CC'art~1·.1 ti nn Cc~t **1 ltL.: ... i I** bh· **:\ (t:: 1 u** irtt~

#### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**

#### **To the Members of RCX Capital Group, LLC**

#### **Opinion on the Financial Statements**

We have audited the accompanying statement of financial condition of RCX Capital Group, LLC as of December 31, 2019, the related statements of operations, changes in members' equity (deficit), changes in liabilities subordinated to claims of general creditors, and cash flows for the year then ended, and the related notes (collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of RCX Capital Group, LLC as of December 31, 2019, 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 RCX Capital Group, LLC's management. Our responsibility is to express an opinion on RCX Capital Group, 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 RCX Capital Group, LLC 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 ri sks . 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 th e 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 supplemental information contained in Schedule I, Computation of Net Capital Requirements Pursuant to Rule 15c3-1 and Schedule II, Computation for Determination of the Reserve Requirements and Information Rel ating to Possession or Control Requirements for Brokers and Dealers Pursuant to SEC Rule 15c3-3 has been subjected to audit procedures performed in conjunction with the audit of RCX Capital Group, LLC' s financial statements. The supplemental information is the responsibility of RCX Capital Group, LLC's management. Our audit procedu res 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 supplemental information contained in Schedule I, Computation of Net Capital Requirements Pursuant to Rule 15c3-1 and Schedule II, Computation for Determination of the Reserve Requirements and Information Relating to Possession or Control Requirements For Brokers and Dealers Pursuant to SEC Rule 15c3-3 is fairly stated, in all material respects, in relation to the fin ancial statements as a whole.

\ r-~( **I**  */* ~W"- .. ,• ..-·~ *;""l\_\_.* ' ~ ~

·. McBee & Co., PC We have served as RCX Capital Group, LLC' s auditor si nce 2018. Dallas, Texas March 14, 2020

718 PcHilu <sup>~</sup>I\ venue • <11!11~ , Te rl~ 75214 • (pit) 211!.1523.3500 • www.mcbecco.com Dallas I Keller/Southlake

{3}------------------------------------------------

# RCX Capital Group, LLC Statement of Financial Condition December 31, 2019

#### Assets

| Cash                    | \$<br>169,948    |
|-------------------------|------------------|
| Accounts Receivable     | 372,934          |
| Employee Advances       | 166,667          |
| Intercompany Receivable | I I 1,6<br>11    |
| Commission Draw         | 245,000          |
| Prepaid expenses        | 37,296           |
| Prepaid income tax      | 5,790            |
| Total assets            | \$<br>I, 109,246 |

#### Liabilities and Members' Equity (Deficit)

#### Liabilities

| Accounts payable and accrued expenses                               | \$<br>195,360  |
|---------------------------------------------------------------------|----------------|
| Liabilities subordinated to the claims of genera<br>l cred<br>itors | 1,4<br>11 ,911 |
| Total liabilities                                                   | 1,607.27<br>1  |

#### Members' eq uity (deficit)

| Me111be1·s' et1u ity (deficit)                  | (498,025)        |
|-------------------------------------------------|------------------|
| Total members' equity (deficit)                 | ( 498,025)       |
| Total liabilities and members' equity (deficit) | \$<br>J' 109,246 |

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

{4}------------------------------------------------

## **RCX Capital Group, LLC Sfatement of Operations For the Year Ended December 31, 2019**

| Revenues                                      |                 |
|-----------------------------------------------|-----------------|
| Fee based income                              | \$<br>4,680,296 |
| Other income                                  | 1,464           |
| Total revenues                                | 4,681,760       |
| Expenses                                      |                 |
| Emp<br>loyee compensation and benefits        | 1,262,720       |
| Commissions                                   | 2,50 l ,596     |
| Occupancy                                     | 46,066          |
| Professional fees                             | 321 ,464        |
| Interest expense                              | 13, 116         |
| Other operati<br>ng expenses                  | 179, 136        |
| Insurance                                     | 43,74<br>1      |
| Total expenses                                | 4,367,839       |
| Net income (loss) before income tax provision | 3<br>13,92<br>1 |
| Income tax provision                          | 3,006           |
| Net income (loss)                             | \$<br>310,915   |

*The accompanying notes are an integral part ofthese jlnancial statements.* 

{5}------------------------------------------------

# **RCX Capital Group, LLC Statement of Changes in Members' Equity (Deficit) For the Year Ended December 31, 2019**

|                              | Members'<br>Equity (Deficit) |  |  |
|------------------------------|------------------------------|--|--|
| Balance at December 31, 2018 | \$<br>(861<br>,690)          |  |  |
| Members' contributions       | 202, 750                     |  |  |
| Members' distributions       | ( 150,000)                   |  |  |
| Net income (loss)            | 3<br>10,91<br>5              |  |  |
| Balance at December 31, 2019 | \$<br>( 498,025)             |  |  |

*The accompany ing notes are an integral part of these fin ancial statements.* 

{6}------------------------------------------------

RCX Capital Group, LLC Statement of Changes in Liabilities Subordinated To the Claims of General Creditors For the Year Ended December 31, 2019

|                                  | Total                    |  |  |
|----------------------------------|--------------------------|--|--|
| Balance at December 31, 2018     | \$<br>1,398,795          |  |  |
| Accounts Receivable              |                          |  |  |
| In crease:                       |                          |  |  |
| Accrual of Interest              | 13.<br>11 6              |  |  |
| Balance at December 31<br>, 2019 | \$<br>1,4<br>11 ,9<br>11 |  |  |

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

{7}------------------------------------------------

# **RCX Capital Group, LLC Statement of Cash Flows For the Year Ended December 31, 2019**

| Cash flow from opergting nctivities:                   |                 |               |
|--------------------------------------------------------|-----------------|---------------|
| Net income (loss)                                      |                 | \$<br>310,915 |
| Adjustments to reconcile net income (loss) to net      |                 |               |
| cash provided by (used in) operating activities:       |                 |               |
| Capitalized interest on subordin ated loan             | \$<br>13 , l !6 |               |
| (Increase) decrease in assets:                         |                 |               |
| Account receivable, net                                | (372,934)       |               |
| lntercompany receivables                               | ( I 11 ,6 11)   |               |
| Commission Draw                                        | (60,000)        |               |
| Prepaid expenses                                       | (20,546)        |               |
| Increase (decrease) in liabilities:                    |                 |               |
| Accounts payable and accrued expenses                  | 133,340         |               |
| Total adjustments                                      |                 | (4 18,635)    |
| Net cash provided by (used in) operating activities    |                 | (I 07,720)    |
| Net cash provided by (used in) in investing activities |                 |               |
| Cash flow from financing activities:                   |                 |               |
| Member contributions                                   | 202,750         |               |
| Net cash provided by (used in) financing activities    |                 | 202,750       |
|                                                        |                 |               |
| Net increase (decrease) in cash                        |                 | 95,030        |
| Cash at beginning of year                              |                 | 74,9 18       |
| Cash at end of year                                    |                 | \$<br>169,948 |
| Supplemental disclosure of cash flow information:      |                 |               |
| Cash paid during the year for:                         |                 |               |
| Income taxes                                           | \$<br>3,006     |               |
| Non-cash investing and financing activities:           |                 |               |
| Distribution of investment                             | \$<br>150,000   |               |

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

{8}------------------------------------------------

{9}------------------------------------------------

## **Note 1: GENERAL AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES**

## *()rganizotinn*

RCX Capita l Group, LLC (the "Company") was incorporated in the State of Ca lifo rnia in September 2000 as Burl and East, LLC. On May 29, 2001 , the Company changed its name to Sil ver Portal Capital, LLC. On January **<sup>11</sup> ,** 2018, the Company changed its name aga in to RCX Capital Group, LLC. The Company began doin g busin ess on October 18, 200 I, as a broker-dea ler regislered with the Securi ties and Exchange Commission (SEC). The Company is a member of the Financial Industry Regulatory Authority ("FINRA"), and the Securiti es Investor Protecti on Corporation ("S!PC").

The Company's primary business is prov iding investment banking, investment advisory and private capital ra ising services fo r compani es in the real estate industry.

Under its membership agreement with FINRA and pursuant to Rul e I 5c3-3(k)(2)(i), the Company does not execute or clear securiti es transactions for customers. Acco rdingly, th e Company is exempt fro m the requirement of Rul e l Sc-3-3 under the Securities Exchange Act of 1934 pertaining to the possession or contro l of customer assets and reserve requirements.

## *Summary ofSignijlcant Accounting Policies*

The presentati on of fin ancial statements in confo rmity with acco unti ng principl es ge nerally accepted in the United States of Ameri ca requires management to make estimates and ass umpti ons that affect th e reported amounts of assets and li abilities and disc losure of contingent assets and li abilities at the date of the financial statements and the reported amounts of revenue and expenses during th e reporting peri od. Actual results could diffe r from those estimates.

For purposes of the Statement of Cash Flows, the Company has defin ed cash equi va lents as highly liquid investments, with ori ginal maturities of less than three months, which are not held fo r sa le in th e ordinary course of busi ness.

Cash consists of deposits with banks and all hi ghly liquid in vestments, with maturiti es of three months or less, that are not segregated and deposited for regulatory purposes.

The Company recognizes its Advisory fees when earned, usually after completi on of the assignment or upon invoicing of non-refund able retain ers or fee payments, in accord ance with written terms of its engagement agreements.

The Company enters into agreements with customers to prov ide th e services defi ned in each contract. Generally, the Company rece ives placement and success fees as compensation fo r servi ces rendered. Some other services include investment advisory services for structuring investments.

{10}------------------------------------------------

## Note 1: GENERAL AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (continued)

The compensation structures of the placement and success fees are defin ed in the contracts and are generally paid to the Company fo r successfull y closing a transaction. The Company satisfies its perfo rmance obligations upon consummating the transaction defined in the contracts. These perfo rmance obligati ons are typica lly fac ilitatin g capital raises fo r th e cli ent or closin g a defi ned transaction. These fees are generally variable and the estimate of vari abl e consideration is typica lly constrained in accordance with paragraphs 606-1 0-32-1 I th rough 32-1 3 of (AS U) No. 20 14-09 because the uncertainty assoc iated with the vari able considerati on. Specifica lly, th e amount of considerati on is highly susceptible to factors outside the entity's influence can take an extended period of time, price concessions co uld occur and there is a large number and broad range of possible outcomes. Revenue is recognized from the satisfacti on of th e perfo rmance obligati on based on the amount the Company has a right to in voice and th at amount directl y corresponds with the value to the customer of the perfo rmance completed to date.

The Company, with the consent of its Members, has elected to be a Ca lifo rnia Limited Liability Company. For tax purposes the Company is treated like a partnership, therefore in li eu of business income taxes, the Members are taxed on th e Company's taxable in come. Accordingly, no provision or liability for Federal Income Taxes is included in these fin ancial statements. The Company is subj ect to State Taxes.

## Note 2: INCOME TAXES

As discussed in the Summary of Significant Acco un ting Poli cies (Note I), th e Company operates as a limited liability company treated as a partnership fo r tax purposes. As such, the Company is subj ect to a limited liability company gross receipts tax, with a minimum franchise tax.

## Note 3: SUBORDINATED LIABILITIES

The li ability subordinated to the claims of general creditors consists of a subordinated loan agreement of \$ 1,3 11 ,63 5, which bears an interest rate of I% per annum, and the related accrued interest paya ble of\$ I 00,276. In addition, the subordinated loan can be automatica lly extended yearly. The expirati on date of the subsidized Joan is June 18, 2020. Interest expense for this subordinated loan was \$ 13, 11 6 fo r the year endin g December 3 1, 20 19.

The subordinated borrowings are covered by agreements approved by FIN RA and are thus available in computing net capital under th e Securiti es and Exchange Commission's unifo rm net capital rul e. To the extent that such borrowings are required fo r th e Company's continued compli ance with minimum net capital requirements, the borrowings may not be repa id . The parties to th e agreement have elected to have all eligible accrued interest on the loan treated as additional subordinated capital. The balance due shown on th e Statement of Financia l Condition includes all interest accrued since the inception of the loan.

{11}------------------------------------------------

## **Note 3: SUBORDINATED LIABILITIES (continued)**

The Scheduled Maturity Date hereof in each year, without further action by either the Lender or Broker/Dealer, shall be extended an additional year unless on or before the day thirteen months preceding the Scheduled Maturity Date then in effect. the Lender shall notify the Broker/Dealer in writing, with a written copy to FINRA, that such Schedul ed Maturity Date shall not be extended. By incorporating this provision, the parti es represent th at: (a) the Lender will retain an ownership interest in the Broker/Dealer during the extended maturity period(s); and (b) the Broker/Dealer shall notify FINRA if any change in ownership status occurs that results in the Lender retaining no ownership interest in th e Broker/Dealer. The lender has the right, but not the obligation to, in conce1i with the Company, to convert the subordinated loan to an eq uity interest in the Company.

## **Note 4: COMMITMENT AND CONTINGENCIES**

*Contingencies* 

The Company had no commitments, no contingent liabilities and had not been named as a defendant in any lawsuit at December 3 I, 2019 or during th e yea r then ended .

## *Guarantees*

I

FASB ASC 460, Guarantees, requires the Company to disc lose information about its obligations uncler certain guarantee arrangements. F ASB ASC 460 defi nes guarantees as contracts and indemnification agreements that contingently require a guarantor to make payments to the guaranteed party based on changes in an underlyin g factor (such as an interest or foreig n exchange rate, security or commodity pri ce, an index or th e occurrence or nonoccurrence of a specifi ed event) related to an asset, liability or equity security of a guaranteed party. This guidance also defines guarantees as contracts that contingently require the guarantor to make payments to the guaranteed party based on another entity's fai lure to perform under an agreement as well as indirect guarantees of indebtedness of others.

The Company has issued no guarantees at December 3 1, 20 19 or during the year then ended.

### **Note 5: CONCENTRATION OF RISKS**

The Company's financial in struments that are subj ect to concentrations of credit risk primarily consist of cash. The Company places its cash with a hi gh credit quality in stitu tion. At times, such cash may be in excess of FDIC insurance limits. The Company believes that it is not exposed to any signifi cant risk related to cash.

{12}------------------------------------------------

#### **Note 5: CONCENTRATION OF RISKS (continued)**

The Company is subject to the risks generally incident to the ownership of, nnd in vestm ent in, real property. Severa l factors may adversely affect the economic performance and value of the properties and projects the Company offers to in vestors. These factors include, among others: changes in the national, regional, and local economi c climate; loca l conditions such as an oversupply of similar properties or a reduction in demand for the properties or projects; the fluctuation in occupancy rates associated with the properties; and government regulations including financing, environmental usage and tax laws, regulations and insurance. A signifi cant portion of the commissions paid by the Company for the period ending ecember <sup>~</sup>1, 2019 are to two independent third parti es.

#### **Note 6: RECENTLY ISSUED ACCOUNTING STANDARDS**

The Financial Accounting Standards Board (the "FASB") has estab lished the Accounting Standards Codification ("Cod ifi cation" or "ASC") as the authoritative source of genera ll y accepted accounting principles ("GAAP") recognized by the F ASB. The princi ples embodied in the Codification are to be applied by nongovernmental entities in the preparation of financial statements in accordance with GAAP in the United States. New accounting pronouncements are incorporated into the ASC through the issuance of Accounting Standards Updates ("ASUs".)

Accounting standards that have been recently issued or proposed by th e FASB or other standardssetting bodies, are not expected to have a material impact on the Company's fin anci al position, results of operation, or cash fl ows

### **Note 7: NET CAPITAL REQUIREMENTS**

The Company is subject to the Securities and Exchange Commission Uniform Net Capital Rule (SEC Rule 15c3-l), which requires the mai ntenance of minimum net capital and requires that the ratio of aggregate indebtedness to net capital, both as defined, shall not exceed 15 to I. Rule I 5c3 l also prov ides that equity capital may not be withdrawn or cash dividends paid if the resu lting net capital ratio would exceed I 0 to 1. Net capital and aggregate indebtedness change day to day, but on December 31, 20 19, the Company had net capital of \$ 166,862 whi ch was \$ 153,838 in excess of its required net capital of \$13,024; and the Company's ratio of aggregate indebtedness (\$195,360) to net capital was 1.1 7 to 1, which is less than the 15 to I maximum allowed.

### **Note 8: RELATED PARTY TRANSACTIONS**

The Company has a rel ated party relationship whi ch accounts for \$2.609,038 of commissions and receivables due in the amount of \$372,934 fo r the period ending December 31 , 20 19.

{13}------------------------------------------------

#### **Note 9: SUBSEQUENT EVENTS**

The Company performed an evaluation of events that have occurred subsequent to December 31 , 2019, and through March 14, 2020, the date of the filing of this report. There have been no material subsequent events that occurred during such period that would require disclosure in this report or would be required to be recognize in the financial statements as of December 31 , 2019.

{14}------------------------------------------------

## **RCX Capital Group, LLC Schedule** I - **Computation of Net Capital Requirements Pursuant to Rule 15c3-1 As of December 31, 2019**

| Computation of net capital                                                                  |                      |                 |
|---------------------------------------------------------------------------------------------|----------------------|-----------------|
| Total members' equity (deficit)                                                             |                      | \$<br>(498,025) |
| Add: Additions to capital<br>Subordinated liabilities allowable for net capital computation |                      | l ,4 11 ,9 1 l  |
| Total equity & allo' Commission Draw                                                        |                      | 9 13,886        |
| Less: Non-allowable assets                                                                  |                      |                 |
| Prepaid expense                                                                             | \$<br>(37,296)       |                 |
| Prepaid income tax                                                                          | \$<br>(5 ,790)       |                 |
| Empl<br>oyee advances, non allowable                                                        | \$<br>( I 66,667)    |                 |
| Acco<br>unts receivab<br>les, non allowable                                                 | \$<br>( 180,659)     |                 |
| lntercompany receivable, non all<br>owable                                                  | \$<br>( I I 1,6 1 I) |                 |
| Commission draw, non allowable                                                              | \$<br>(245,000)      |                 |
| Total non-allowable assets                                                                  |                      | (747,024)       |
| Net capital                                                                                 |                      | I 66,862        |
| Computation of net capital requirements                                                     |                      |                 |
| Minimum net capital requirements                                                            |                      |                 |
| 6 2/3 percent of net aggregate indebtedness                                                 | \$<br>13 ,024        |                 |
| Minimum doll<br>ar net capital req<br>uired                                                 | \$<br>5,000          |                 |
| Net capital required (greater of above)                                                     |                      | ( 13 ,024)      |
| Excess net capital                                                                          |                      | \$<br>153,838   |
| Aggregate indebtedness                                                                      |                      | \$<br>I 95,360  |
| Ratio of aggregate indebtedness to net capital                                              |                      | I. I 7 : I      |

## Reconciliation with Company's computation (included in Part **11** of Form X- I 7 A-5)

There was no materi al difference between the net capti al computation shown here and the net capital computati on shown on the Company's unaudited Form X-1 7 A-5 repo rt elated Decembe r 3 I, 20 19 other than the increase in members' defic it with a correspo nding decrease in total nonallowabl e assets of \$ 150,000, resulting in no change to net capita l.

*See report of indep endent registered public accounting firm* 

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

## RCX Capital Group, LLC Schedule II - Computation for Determination of the Reserve Requirements and Information Relating to Possession or Control Requirements For Brokei-s and Dealers Pursuant to SEC Rule 15c3-3 As of December 31, 2019

RCX Capital Group, LLC is exempt from the provision of Rule 15c3-3 under paragraph (k)(2)(i) in that the Company carri es no accounts, does not hold funds or securities for, or owe money or securities to customers. Accordingly, there are no items to report under the requirements of this Rul e.

*The accompanying notes are an integral part of thesejinancial statements.* 

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

![](_page_16_Picture_0.jpeg)

**A 1'1 11t··:-;.::·k"1!1 '1 .1I** ('C'i~ 11.J Cl <sup>r</sup> **C t::ti lte ... : 1-'u'°:..i.1i.;:** :. '\. lt1 11. .e **...** 

## **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**

#### **To the Members of RCX Capital Group, LLC**

We have reviewed managemirnt's statements, included in the accomp;mying Exemption Report, in which (1) RCX Capital Group, LLC identified the following provisions of 17 C.F.R. §15c3-3(k) under which RCX Capital Group, LLC claimed an exemption from 17 C.F.R. §240.15c3-3: (2}(i) (the "exemption provisions") and (2) RCX Capital Group, LLC stated that RCX Capital Group, LLC met the identified exemption provisions throughout the most recent fiscal year, December 31, 2019, without exception. RCX Capital Group, LLC's management is responsible for compliance with th e exemption provi sions 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 RCX Capital Group, 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 15c3-3 under the Securities Exchange Act of 1934.

, \_..) *t.* / .• '.Iv , \ <sup>j</sup>.. -)

McBee & Co., PC Dallas, Texas March 14, 2020

718 Paulus Avenue • Dallas, Texas 7521'1 • (ph) 21'1.823.3500 • www.mcbccco.com Dallas I Keller/Southlake

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

![](_page_17_Picture_0.jpeg)

# **RCX Capital Group, LLC's Exemption Report**

RCX Capital Group, LLC, (the "Company" ) is a regi stered broker-dea ler subject to Rule 17a-5 promulgated by the Securities and Exchange Commi ss ion (17 C.F .R. §240.17a-5, " Reports to be made by certain brokers and dealers"). Thi s 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 Comp any states th e following:

- 1. RCX Capital Group, LLC, claimed an exemption 17 C.F .R. § 240.15c3-3 under the followin g provisions of 17 C.F.R. § 240.15c3-3 (k)(2)(i) for the fiscal year end ed Decembe r 31, 2019.
- 2. RCX Capital Group, LLC, met the identified exemption provi sions in 17 C.F.R. § 240.15c3- 3(k)(2)(i) throughout the most recent fiscal year of January 1, 2019 to December 31, 2019, without exception .

RCX Capital Group, LLC

I, Jean-Louis Guincha rd, affirm that, to my best knowledge and belief, this Exe mption Report is true and correct.

J/ -Louis Guinchard, Presid /

February 24, 2020

RCX Capital Group, LLC 2002 Timberloch Place, Suite 200 Tt1 e Woodlands , TX 77380 (858) 232-5887 0 \'J\ 'l\v. **rcxcH 01taJorol 111.:com** 

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

![](_page_18_Picture_0.jpeg)

**A Pr1:"1 ll':::..::i0:u .I c, tp<tr.:tli<'if'i**  C~ rti frl J t? <sup>h</sup>**. .: :\<J..:cour** ~:-.

# **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM ON APPLYING AGREED-UPON PROCEDURES**

#### **To the Members of RCX Capital Group, LLC**

We have performed the procedures included in Rule 17a-S(e)(4) under the Securities Exchange Act of 1934 and in the Securities Investor Protection Corporation (SIPC) Seri es 600 Rules, which are enumerated below and were agreed to by RCX Capital Group, LLC and the SIPC, solely to assist you and SIPC in evaluating RCX Capital Group, LLC's compliance with the applicable instructions of the General Assessment Reconciliation (Form SIPC-7) for the year ended December 31, 2019. RCX Capital Group, LLC' s management is responsible for its Form SIPC-7 and for its compliance with those requirements . This agreed-upon procedures engagement was conducted in accordance with standards established by the Public Company Accounting Oversight Board (United States) and in accordance with attestation standards established by the American Institute of Certified Public Accountants. The sufficiency of these procedures is solely the responsibility of those parties specified in thi s report. Con sequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose. The procedures we performed and our findings are as follows:

- 1) Compared the listed assessment payments in Form SIPC-7 with respective ca sh disbursem ent records entries, noting no differences;
- 2) Compared the Total Revenue amount reported on the Annual Audited Report Form X-17A-5 Part Ill for the year ended December 31, 2019 with the Total Revenue amount reported in Form SIPC-7 for the year ended December 31, 2019, noting no differences;
- 3) Compared any adjustments reported in Form SIPC-7 with supporting schedules and working papers, noting no differences; and
- 4) Recalculated the arithm etical accuracy of th e calculations reflected in Form SIPC-7 and in th e related sch edules and working papers supporting the adjustments, noting no differences.

We were not engaged to and did not conduct an examination or review, the obj ective of which would be th e express ion of an opinion or conclusion, respectively, on RCX Capital Group, LLC' s compliance with th e applicable instruction s of th e Form SIPC-7 for the year ended December 31, 2019. Accordingly, we do not express such an opinion or conclusion . Had we performed additional procedures, other matters might have come to our attention that would have been reported to you .

This report is intended solely for the information and use of RCX Capital Group, LLC and the SIPC and is not intended to be and should not be used by anyone other than these specified parties.

' ,/ t\ --- . **I \\_...J** <sup>~</sup> .J \ j *r* 

McBee & Co., PC Dallas, Texas March 14, 2020

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

| SECURITIES INVESTOR PROTECTION CORPORATION<br>P .0. Box 92185 Washington, D.C. 20090-2185<br>SIPC-7<br>202-371-8300<br>General Assessment Reconciliation<br>(36 -REV 12/18)                                             | SIPC-7<br>(36 -REV 12/18)                                                                                                                                                      |  |
|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|
| For tho fiscal year ended 12131/2019                                                                                                                                                                                    |                                                                                                                                                                                |  |
| (Read carelully lhe instruclions in your Worki1g Copy belore com pletin g this Form)<br>TO BE FILED BY ALL SIPC .MEMBERS WITH FISCAL YEAR ENDINGS                                                                       |                                                                                                                                                                                |  |
| 1. Name of Member, address, Designaled !;xamining Authority , 1934 Acl registration no . and month in which fiscal yea r en ds for<br>purpo~ell of the audil requiremenl ol oECI Rule 17a·5:                            |                                                                                                                                                                                |  |
| I<br>12"1~DAP00220<br>53416<br>ANRA<br>DEC<br>RClC CAPITAL GROUP U.C                                                                                                                                                    | Note: If any of the information shown on the<br>mailing label requires correction, please e- mail<br>any corrections to form@si pc .org and so<br>indicate on the form fil ed. |  |
| 2002 TIMBERLOCH PL STE 200<br>TiiEWOODlJINOO. TXm80-1182                                                                                                                                                                | Name and telephone number of person to<br>contact respecting th is form .                                                                                                      |  |
| L                                                                                                                                                                                                                       | __J Kristy Johnson (281) 367-0380                                                                                                                                              |  |
|                                                                                                                                                                                                                         |                                                                                                                                                                                |  |
| 2. A. General Assessment (item 2e from page 2)                                                                                                                                                                          | \$ 7,021                                                                                                                                                                       |  |
| B. Less payment made with SIPC-6 filed (exclude Interest)                                                                                                                                                               | ( 1 716                                                                                                                                                                        |  |
|                                                                                                                                                                                                                         |                                                                                                                                                                                |  |
| Date Paid                                                                                                                                                                                                               |                                                                                                                                                                                |  |
| C. Less prior overpayment applied                                                                                                                                                                                       |                                                                                                                                                                                |  |
| D. Assessment balance due or (overpayment)                                                                                                                                                                              | 5,305                                                                                                                                                                          |  |
| Interest computed on late payment (see instruction E) for ___ ___ days at 20% per annum<br>E.                                                                                                                           |                                                                                                                                                                                |  |
| F. Total assessment balance and interest due (or overpayment carried forward)                                                                                                                                           | \$ 5,305                                                                                                                                                                       |  |
| G. PAYMENT:<br>-.J the box<br>Check malled to P.O. Box 0<br>Funds Wired O<br>ACH U \$ 5,305<br>Total (must be same as F above)                                                                                          | ---~~~~~~-~                                                                                                                                                                    |  |
| \$(<br>H. Overpayment carried forward                                                                                                                                                                                   | _______<br>_                                                                                                                                                                   |  |
| 3. Subsidiaries (S) and predecessors (P) included in this !arm (give name and 1934 Act registration number) :                                                                                                           |                                                                                                                                                                                |  |
| The SIPC member submitting this lorrn and the<br>person by whom it is executed represent thereby<br>that all information contained herein is true, correct<br>and complete .<br>·                                       |                                                                                                                                                                                |  |
| 2~<br>Dated the .£Lt day of R:Jrua,'(f                                                                                                                                                                                  |                                                                                                                                                                                |  |
|                                                                                                                                                                                                                         | !Tille)                                                                                                                                                                        |  |
| This form and the assessment payment is due 60 days after the end of the fiscal year. Retain the Working Copy of this torm<br>for a period of not less than 6 years, the latest 2 years In an easily accessible place . |                                                                                                                                                                                |  |
| ~ Dates :<br>Postmarked<br>Received<br>Reviewed                                                                                                                                                                         |                                                                                                                                                                                |  |
| > Calculations ___ _<br><br>Documentation ___ _                                                                                                                                                                         | Forward Copy----                                                                                                                                                               |  |
| <br>cc<br>~ Exceptions :                                                                                                                                                                                                |                                                                                                                                                                                |  |
| a                                                                                                                                                                                                                       |                                                                                                                                                                                |  |
| en Disposition of exceptions:<br>1                                                                                                                                                                                      |                                                                                                                                                                                |  |

{20}------------------------------------------------

## **DETERMINATION OF "SIPC NET OPERATING REVENUES" AND GENERAL ASSESSMENT**

Amount s tor the fiscal period beginn ing **1/1/2019**  and ending **12131/2019** 

| Item No.<br>2a . Tolal revenue (FOCUS Line 12/Part llA Linc 9, Code 4030)                                                                                                                                                                                                                                                                                                                         | Eliminate cents<br>\$ 4,681,760 |
|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------|
|                                                                                                                                                                                                                                                                                                                                                                                                   |                                 |
| 2b. Addition5:<br>( 1) Total revenues lrom the secu rities business al subsidiaries (except loreign subsidiaries) and<br>predecessors not included above .                                                                                                                                                                                                                                        |                                 |
| (2) Net loss lrom principal transactions in securities in trading accou nt s.                                                                                                                                                                                                                                                                                                                     |                                 |
| (3) Net loss lrom principal transactions in commodilies in trading accounts.                                                                                                                                                                                                                                                                                                                      |                                 |
| (4) Interest and dividend expense deducted in determining item 2a.                                                                                                                                                                                                                                                                                                                                |                                 |
| (5) Net loss lrom management of or participation in th e underwriting or dislribution of securities .                                                                                                                                                                                                                                                                                             |                                 |
| (6)' Exf)l!rrstrs other !llan advertising, printing, registration fees and legal fees deducted in determining net<br>profit from management of or participation in underwriting or distribution of securities.                                                                                                                                                                                    |                                 |
| (7) Ne! loss lrom securities in investment accounts.                                                                                                                                                                                                                                                                                                                                              |                                 |
| Total additions                                                                                                                                                                                                                                                                                                                                                                                   |                                 |
| 2c , Ded uctions:<br>(1) Revenues from the distribution of shares of a registered open end investment company or unit<br>investment !rust. lrom the sale ol variable annuities. from the business of insurance, from investment<br>advisory services rendered to registered investmenl companies or insurance company separate<br>accounts, and from tran sactions in secu rity futures products. |                                 |
| (2) Revenues from commodity tran sactions.                                                                                                                                                                                                                                                                                                                                                        |                                 |
| (3) Commissions, floor brokerage and clearance paid to olher SIPC member s in connection with<br>securities transactions.                                                                                                                                                                                                                                                                         |                                 |
| (4) Reimbursements for postage in connection with proxy solicitalion .                                                                                                                                                                                                                                                                                                                            |                                 |
| (5) Net gain from securities in investment accounts.                                                                                                                                                                                                                                                                                                                                              |                                 |
| (6) 100% ol commissions and markups earned from transactions in (i) cert ificales of deposit and<br>(ii) Treasury bills, bankers acceptances or commercia l paper that mature nine months or less<br>from issuance date.                                                                                                                                                                          |                                 |
| (7) Direct expenses ol printing advertising and legal tees incurred in connection with other revenue<br>related to the securities bu sines s (revenue defined by Section 16(9)(L) of the Act).                                                                                                                                                                                                    |                                 |
| (6) Other revenue nol related either directly or indirectly to the securities business .<br>(See Instruction C):                                                                                                                                                                                                                                                                                  |                                 |
| _____ _<br>. Reifi!b~rsed exp~<br>n_s es                                                                                                                                                                                                                                                                                                                                                          | 829                             |
| (Deductions in excess of \$100,000 require documentation)                                                                                                                                                                                                                                                                                                                                         |                                 |
| (9) (i) Total interest and dividend expense (FOCUS Line 22/PART !IA Line 13,<br>__________<br>Code 4075 plus line 2b(4) above) but not in excess<br>ol total interest and dividend income.<br>_<br>\$.                                                                                                                                                                                            |                                 |
| (ii) 40% ol margi n interest earned or. customers securities<br>_________<br>accounts (40% of FOCUS line 5, Code 3960).<br>\$,<br>_                                                                                                                                                                                                                                                               |                                 |
| Enter th e greater of line (i) or (ii)                                                                                                                                                                                                                                                                                                                                                            |                                 |
| Total deduclions                                                                                                                                                                                                                                                                                                                                                                                  | 829                             |
| 2d. SIPC Net Operating Rev enues                                                                                                                                                                                                                                                                                                                                                                  | \$ 4,680,931                    |
| 2e. General Assess ment@ .0015                                                                                                                                                                                                                                                                                                                                                                    | \$ 7,021                        |
|                                                                                                                                                                                                                                                                                                                                                                                                   | (to page 1, line 2.A.)          |

{21}------------------------------------------------

**RCX CAPITAL GROUP LLC**  2002 TIMBERl\_OCH PL STE 200 SPFllNG . TX 71'380-1182 **204 1**  16 .. ?.4/1220 4-iJ i ACX C:APIT/l.L GROUP. LLC

# Gl ., **i :iooo 2 g 7-l'l \ruQJC:[.** <sup>~</sup>**Hm**


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