# DEMPSEY LORD SMITH, LLC X-17A-5 (2025-04-01) — Broker-dealer annual report

- Company: DEMPSEY LORD SMITH, LLC
- Form: X-17A-5
- Filed: 2025-04-01
- Period: 2024-12-31
- Accession: 0001380213-25-000001
- CIK: 1380213
- File #: 8-67469
- Type: Broker-dealer
- Material weakness: No
- Auditor: Rubio CPA, PC
- Auditor location: Atlanta, GA
- Contact: Jerry E Dempsey
- Phone: 7062389575
- Signed by: Jerry E Dempsey, Jr (CEO)

Original filing: https://www.sec.gov/Archives/edgar/data/1380213/000138021325000001/dempseylordsmithllc2024.pdf

---

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

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

> **ANNUAL REPORTS FORM X-17A-S**

| 0MB APPROVAL             |  |
|--------------------------|--|
| 0MB Number: 3235-0123    |  |
| Expires: Nov. 30, 2026   |  |
| Estimated average burden |  |
| hours per response: 12   |  |
|                          |  |

SEC FILE NUMBER 8-67469

# **PART Ill**

**FACING PAGE** 

Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934

FILING FOR THE PERIOD BEGINNING **0 1/01 /24**  MM/ DD/YY AND ENDING 12131124 MM/DD/YY

**A. REGISTRANT IDENTIFICATION** 

NAME oF FIRM: Dempsey Lord Smith, LLC

TYPE OF REGISTRANT (check all applicable boxes):

~ Broker-dealer O Security-based swap dealer D Major security-based swap participant ::J Check here if respondent is also an OTC derivatives dealer

ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.)

### 901 North Broad Street, Suite 400

|                                              | (No. and Street)               |                              |  |
|----------------------------------------------|--------------------------------|------------------------------|--|
| Rome                                         | GA                             | 30161                        |  |
| (City)                                       | (State)                        | (Zip Code)                   |  |
| PERSON TO CONTACT WITH REGARD TO THIS FILING |                                |                              |  |
| Jerry E. Dempsey                             | (706) 238 -<br>9575            | jerry .dempsey@dem psey. com |  |
| (Name)                                       | (Area Code - Telephone Number) | (Email Address)              |  |
|                                              | B. ACCOUNTANT IDENTIFICATION   |                              |  |
|                                              |                                |                              |  |

INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this fi ling\*

## RUBIO CPA, PC

|                                              | (Name - if individual, state last, first, and middle name) |         |                                             |
|----------------------------------------------|------------------------------------------------------------|---------|---------------------------------------------|
| 3500 Lenox Rd., Suite 1500 Atlanta           |                                                            | GA      | 30326                                       |
| (Address)                                    | (City)                                                     | (State) | (Zip Code)                                  |
| 05/05/09                                     |                                                            | 3514    |                                             |
| T"<br>ofRegl~,atkm with PCAOBII• appllcabl•I |                                                            |         | IPCAOB Regl>UaUoo N,mbe<, If applicable I I |
|                                              | FOR OFFICIAL USE ONLY                                      |         |                                             |

• Claims for exemption from t he requirement that the annual reports be covered by the reports of an independent public accountant must be supported by a statement of facts and circumstances relied on as the basis of the exemption. See 17 CFR 240.17a-S(e)(l)(ii), if applicable.

Persons who are to respond to the collection of Information contained In this form are not required to respond unless the form displays a currently valid 0MB control number.

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

#### **OATH OR AFFIRMATION**

I, Jerry E. Dempsey swear (or affirm) that, to the best of my knowledge and belief, the financial report pertaining to the firm of Dempsey Lord Smith, LLC as of December 31 2~ is true and correct. I further swear (or affirm) that neither the company nor any

partner, officer, director, or equivalent person, as the case may be, has any proprietary interest in any account classified solely as that of a customer.

#### This filing\*\* **contains (check all applicable boxesl:**

- **!I!!!!** (a) Statement of financial condition.
- (b) Notes to consolidated statement of financial condition.
- **!I!!!!** (c) Statement of income (loss) or, if there is other comprehensive income in the period(s) presented, a statement of comprehensive income (as defined in§ 210.1-02 of Regulation **S-X).**
- **!I!!!!** (d) Statement of cash flows.
- **!I!!!!** (e) Statement of changes in stockholders' or partners' or sole proprietor's equity.
- (f) Statement of changes in liabilities subordinated to claims of creditors.
- ~ (g) Notes to consolidated financial statements.
- ~ (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-1, as applicable.
- :::J (i) Computation of tangible net worth under 17 CFR 240.18a-2.
- :::J U) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3.
- ::J (k) Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.15c3-3 or Exhibit A to 17 CFR 240.18a-4, as applicable.
- ::J (I) Computation for Determination of PAB Requirements under Exhibit A to§ 240.15c3-3.
- ::J (m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3.
- ::J (n) Information relating to possession or control requirements for security-based swap customers under 17 CFR 240.15c3-3(p)(2) or 17 CFR 240.18a-4, as applicable.
- ~ (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capital or tangible net worth under 17 CFR 240.1Sc3-l, 17 CFR 240.18a-1, or 17 CFR 240.18a-2, as applicable, and the reserve requirements under 17 CFR 240.1Sc3-3 or 17 CFR 240.18a-4, as applicable, if material differences exist, or a statement that no material differences exist.
- D (p) Summary of financial data for subsidiaries not consolidated in t he statement of financial condition.
- ~ (q) Oath or affirmation in accordance with 17 CFR 240.17a-S, 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applica ble.
- 0 (r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- ~ (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- D (t) Independent public accountant' s report based on an examination of the statement of financial condition.
- ~ (u) independent public accountant's report based on an examination of the financial report or financial statements under 17 CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable.
- :::J (v) independent public accountant's report based on an examination of certain statements in the compliance report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- **!!l** (w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-le or 17 CFR 240.17a-12, as applicable.
- (y) Report describing any material inadequacies found to exist or found to have existed since the date of the previous audit, or a statement that no material inadequacies exist, under 17 CFR 240.17a-12(k). (z) Other:------- - ------ --------- ---- - - - --- ------
- 
- "'"To request confidential treatment of certain portions of this filing, see 17 CFR 240.17a-5{e)(3) or 17 CFR 240.18a-7(d}(2), as applicable.

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

DEMPSEY LORD SMITH, LLC Financial Statements For the Year Ended December 31, 2024 With Report of Independent Registered Public Accounting Firm

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

Suite 1500 Atlanta, GA 30326 770-690-8995

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

To the Members of Dempsey Lord Smith, LLC

Opinion on the Financial Statements

W c have audited the accompanying statement of financial condition of Dempsey Lord Smith, LLC (the "Company") as of December 31, 2024, the related statements of operations, changes in members' equity, 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 the Company as of December 31, 2024, 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.

### 8asis for Opinion

These financial statements are the responsibility of the Company's management. Our responsibility is to express an opinion on the Company's financial statements based on our audit. We are a public accounting finn 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. The Company is not required to have, nor were we engaged to perform, an audit of its internal control over financial rep011ing. As part of our audit we are required to obtain an understanding of internal control over financial reporting but not for the purpose of expressing an opinion on the effectiveness of the Company's internal control over financial reporting. Accordingly, we express no such opinion.

Our audit included performing procedures to assess the risks of material misstatement to 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.

### Supplemental Information

The information contained in Schedules I, **JI** and Ill has been subjected to audit procedures performed in conjunction with the audit of the Company's financial statements. The supplemental information is the responsibility of the Company's management. Our audit procedures included determining whether the information in Schedules I, II and Ill 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 accompanying schedules. In fom1ing our opinion on the accompanying schedules, we evaluated whether the supplemental infonnation, including its fonn and content, is presented

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

in confonnity with 17 C.F.R. §240.17a-5. In our opinion, the aforementioned supplemental information is fairly stated, in all material respects, in relation to the financial statements as a whole.

We have served as the Company's auditor since 2005.

April l, 2025 Atlanta, Georgia

Rubio CPA. PC

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

### **DEMPSEY LORD SMITH, LLC STATEMENT OF FINANCIAL CONDITION DECEMBER 31, 2024**

### ASSETS

| Cash                                   | \$<br>264,844 |
|----------------------------------------|---------------|
| Commissions receivable                 | 865,133       |
| Due from clearing broker               | 442,436       |
| Office furniture and equipment, net of |               |
| accumulated depreciation of \$153,147  | 7,218         |
| Due from stockholder                   | 50,000        |
| Due from advisors                      | 48,000        |
| Deposit with clearing broker           | 50,000        |
| Prepaid expenses                       | 98 310        |

| Total Assets | \$ | 1.825.941 |
|--------------|----|-----------|
|--------------|----|-----------|

### LIABILITIES AND MEMBERS' EQUITY

| LIABILITIES                           |                 |
|---------------------------------------|-----------------|
| Accounts payable                      | \$<br>70,493    |
| Accrued commissions                   | 844,722         |
| Other accrued expenses                | 425 579         |
| Total Liabilities                     | 1340794         |
| MEMBERS' EQUITY                       | 485 147         |
| Total Liabilities and Members' Equity | \$<br>1,825.941 |

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

### **DEMPSEY LORD SMITH, LLC STATEMENT OF OPERATIONS**  For the Year Ended December 31, 2024

| REVENUES                           |                 |
|------------------------------------|-----------------|
| Commissions                        | \$<br>6,707,851 |
| Mutual fund fees                   | 2,315,353       |
| Advisory                           | 6,286,757       |
| Interest                           | 9,039           |
| Other                              | 322,000         |
| Total revenues                     | 15,641,000      |
| EXPENSES                           |                 |
| Commissions                        | 11,495,674      |
| Guaranteed payments to partners    | 391,000         |
| Employee compensation and benefits | 583,380         |
| Clearing and execution charges     | 399,295         |
| Communications                     | 18,021          |
| Occupancy and equipment            | 192,300         |
| Other expenses                     | 2,635,044       |
| Total expenses                     | 15 714 714      |
| NET LOSS                           | (73,714)<br>\$  |

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

### **DEMPSEY LORD SMITH, LLC STATEMENT OF CASH FLOWS**  For the Year Ended December 31, 2024

### CASH FLOWS FROM OPERATING ACTIVITIES:

Net Loss

\$ (73,714)

Adjustments to reconcile net loss to net cash used by operations:

| Depreciation                                        | 3,500         |
|-----------------------------------------------------|---------------|
| Increase in commissions receivable                  | (755,117)     |
| Increase in due from clearing broker                | (171,119)     |
| Increase in prepaid expenses                        | (8,202)       |
| Increase in receivables from stockholder & advisors | (98,000)      |
| Decrease in commission advances                     | 32,984        |
| Decrease in accounts payable                        | (32,731)      |
| Decrease in accrued commissions                     | (245,909)     |
| Decrease in other accrued expenses                  | (421,788)     |
| NET CASH USED BY OPERATING ACTIVITIES               | (1,770,095)   |
| CASH FLOWS FROM FINANCING ACTIVITIES:               |               |
| Distribution to member                              | (50,001)      |
| Contribution from member                            | 100 000       |
| NET CASH PROVIDED BY FINANCING ACTIVIIES            | 49 999        |
| NET DECREASE IN CASH                                | (1,720,096)   |
| CASH BALANCE:                                       |               |
| Beginning of year                                   | 1,984,940     |
| End of year                                         | \$<br>264,844 |

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

### **DEMPSEY LORD SMITH, LLC STATEMENT OF CHANGES IN MEMBERS' EQUITY**  For the Year Ended December 31, 2024

| Balance, December 31, 2023 | \$<br>508,861 |
|----------------------------|---------------|
| Net Loss                   | (73,714)      |
| Contribution from member   | 100,000       |
| Distribution to member     | (50,000)      |
|                            |               |

Balance, December 31, 2024

\$ 485,147

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

### NOTE A-SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

Organization and Description of Business: Dempsey Lord Smith, LLC (the "Company"), a Georgia Limited Liability Company organized in April 2006, is a securities broker-dealer registered with the Securities and Exchange Commission ("SEC") and the Financial Industry Regulatory Authority ("FINRA"). As a limited liability company, the members' liability is limited to their investment.

The Company operates as a "general securities" and "managing" broker-dealer executing trades for institutional and retail customers. The Company does not carry customer accounts or perform custodial functions relating to customer securities. Customers of the Company are introduced to a carrying broker-dealer (clearance agent) on a fully disclosed basis. The Company's customers are located throughout the United States.

Cash: The Company maintains its cash deposits in high credit quality financial institutions. Balances at times may exceed federally insured limits.

Office Furniture and Equipment: Office furniture and equipment is recorded at cost. Depreciation is provided by use of straight-line methods over the estimated useful lives of the respective assets.

Income Taxes: The Company is taxed as a partnership. Therefore the income or losses of the Company flow through to its members and no income taxes are recorded **in** the accompanying financial statements.

The Company has adopted the provisions of FASB Accounting Standards Codification 740-10 ("ASC 740-10"), Accounting for Uncertainty **in** Income Taxes. Under ASC 740-10, the Company is required to evaluate each of its tax positions to determine if they are more likely than not to be sustained if the taxing authority examines the respective position. A tax position includes an entity's status, including its status as a pass-through partnership, and the decision not to file a tax return. The Company has evaluated each of its tax positions and has determined that no provision or liability for income taxes is necessary.

Estimates: Management uses estimates and assumptions in preparing financial statements in accordance with generally accepted accounting principles. Those estimates and assumptions affect the reported amounts of assets, liabilities, revenues and expenses. Actual results could vary from the estimates that were assumed in preparing the financial statements.

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

### NOTE A-SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

Date of Management's Review - Subsequent events were evaluated through the date the financial statements were issued.

Revenue Recognition: Revenue from contracts with customers includes comm1ss1on and concession income and fees from private placements and advisory services. The recognition and measurement of revenue is based on the assessment of individual contract terms. Significant judgement is required to determine whether performance obligations are satisfied at a point in time or over time; how to allocate transaction prices where multiple performance obligations are identified; when to recognize revenue based on the appropriate measure of the Company's progress under the contract; whether revenue should be presented gross or net of certain costs; and whether constraints on variable consideration should be applied due to uncertain future events.

The Company buys and sells securities on behalf of customers. Each time a customer enters into a buy or sell transaction, the Company charges a commission. Commissions and related clearing expenses are recorded on the trade date (the date the Company fills the trade order by finding and contracting with a counterparty and confirms the trade with the customer). The Company believes that the performance obligation is satisfied on the trade date because that is when the underlying financial instrument or purchaser is identified, the pricing is agreed upon and the risks and rewards of ownership of the securities have been transferred to/from the customer.

Mutual funds or pooled investments vehicles ( collectively, "funds") have entered into agreements with the Company to distribute/sell their shares to investors. The Company may receive distribution fees paid by the funds upfront, over time, upon the investor's exit from the fund (that is, a contingent deferred sales charge), or as a combination thereof. The Company believes its performance obligation is the sale of securities to investors and as such this is fulfilled on the trade date. Any fixed amounts are recognized on the trade date and variable amounts are recognized to the extent it is probable that a significant revenue reversal will not occur once the uncertainty is resolved. For variable amounts, as the uncertainty is dependent on the value of the shares at future points in time as well as the length of time the investor remains in the fund, both of which are highly susceptible to factors outside the Company's influence, the Company does not believe that it can overcome this constraint until the market value of the fund and the investor activities are known, which are usually quarterly or monthly.

The Company provides investment advisory services on a daily basis. The Company believes the performance obligation for providing advisory services is satisfied over time because the customer is receiving and consuming benefits as they are provided by the Company. Advisory fee arrangements are based on a percentage applied to the customer's assets under management. Fees are received quarterly or monthly and are recognized as revenue in the period in which performance obligations are satisfied.

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

### NOTE A-SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

The Company recognizes commissions from private placements upon the sale of each interest in an offering as this satisfies the only performance obligation identified by the Company.

Product education classes are hosted by the Company for which the presenters of the classes are assessed fees. The Company recognizes revenue from the receipt of such fees upon the occurrence of the product education classes. Revenues from presenters of product education classes hosted by the Company are reflected as other revenues in the accompanying statement of operations.

Commissions Receivable: Commissions receivable are uncollateralized obligations receivable under normal trade terms. The carrying amount of commissions receivable may be reduced by an allowance that reflects management's best estimate of the amounts that will not be collected. Management reviews all commissions receivable balances and based on an assessment of the Company's collection experience, customer credit worthiness, and current economic trends, estimates the portion, if any, of the balance that will not be collected. Management believes that the commissions receivable recorded at December 31, 2024 are fully collectable and are therefore stated without an allowance for credit losses.

### NOTE B -NET CAP IT AL

The Company, as a registered broker dealer, is subject to the Securities and Exchange Commission Uniform Net Capital Rule (Rule 15c3-1), which requires the maintenance of minimum net capital and requires that the ratio of aggregate indebtedness to net capital, both as defined, shall not exceed 15 to 1. At December 31, 2024, the Company had net capital of \$99,076 which was \$9,690 in excess of its required net capital of \$89,386 and its ratio of aggregate indebtedness to net capital was 13.53 to 1.00.

### NOTE C - OFF BALANCE SHEET RISK

In the normal course of business, the Company's customers execute securities transactions through the Company. These activities may expose the Company to off balance sheet risk in the event the customer or other broker is unable to fulfill its contracted obligations and the Company has to purchase or sell the financial instrument underlying the contract at a loss.

# NOTE D-CLEARANCE AGREEMENT

The Company has an agreement with a clearing broker to execute and clear, on a fully disclosed basis, customer accounts of the Company. In accordance with this agreement, the Company is required to maintain a deposit in cash or securities. The Company's clearing agreement requires

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

# NOTE D-CLEARANCE AGREEMENT (CONTINUED)

that a minimum balance of \$50,000 be maintained on deposit with the clearing broker and that minimum net capital of \$150,000 be maintained. The due from its clearing broker at December 31, 2024 consists of commissions receivable and funds held in various accounts. The due from clearing broker is considered fully collectible at December 31, 2024 and no allowance is required.

At December 31, 2024, net capital is \$99,076, which is \$50,924 below required net capital pursuant to the clearing agreement of \$150,000. Management believes that the net capital deficit pursuant to the clearing agreement ceased to exist circa January 3, 2025 when certain non-allowable accounts receivable was collected.

### NOTE E - LEASES AND RELATED PAR TY TRANSACTIONS

The Company leases three office premises locations on a month-to-month basis from its members or entities controlled by its members.

For the year ended December 31, 2024, rent expense under these related party premises leases was \$192,300.

Financial position and results of operations could differ from the amounts in the accompanying financial statements if these related party transactions did not exist.

### NOTE F - CONTINGENT LIABILITIES

The Company is subject to litigation and customer claims in the normal course of business. At December 31, 2024, the Company is engaged in defending claims with customers. The Company has accrued \$352,400 for these matters that is included in other accrued expenses in the statement of financial condition.

In several of the matters in progress during 2024, the Company was defendant in claims arising from sales of investments in a fund that invested in life insurance policies. The fund has filed for bankruptcy court protection. Investors and regulators allege, among other things, that the fund is a Ponzi scheme. The Company believes that there may be additional claims in the future that cannot be estimated at this time, arising from approximately \$4. 5 million of sales of the fund. The amount of claims that may arise could have a material adverse effect on the Company's financial position.

The Company's Members have represented that they intend to make capital contributions as needed to ensure the Company's survival through at least one year subsequent to the date of the report of the independent accounting firm.

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

### NOTE F - CONTINGENT LIABILITIES (CONTINUED)

The Company's financial statements for the year ended December 31, 2023 contained a goingconcern disclosure. No such disclosure is necessary at December 31, 2024 due to the progress made in settling customer claims during the year ended December 31, 2024 as well as the representation of the Members discussed in the paragraph above.

### NOTE G - CONCENTRATIONS

At December 31, 2024, the Company had two customers that accounted for approximately 51 % of commissions receivable.

### NOTE H - SEGMENT REPORTING

The Company offers several classes of services, including retail brokerage of securities, retailing mutual funds and insurance on a subscription way basis, referring investors to funds, and providing investment advisory services. The Company has identified its CEO as the chief operating decision maker ("CODM"), who uses net income to evaluate the results of the business, predominantly in the forecasting process, to manage the Company.

Additionally, the CODM uses excess net capital (see Note B), which is not a measure of profit and loss, to make operations decisions while maintaining capital adequacy, such as whether to reinvest profits or pay distributions. The Company's operations constitute a single operating segment and therefore, a single reportable segment, because the CODM manages the business activities using information of the Company as a whole. The accounting policies used to measure the profit and loss of the segment are the same as those described in the summary of significant accounting policies.

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

### SUPPLEMENTAL INFORMATION

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

### **SCHEDULE** I **DEMPSEY LORD SMITH, LLC**

### **COMPUTATION OF NET CAPITAL UNDER RULE 15c3-1 OF THE SECURITIES AND EXCHANGE COMMISSION ACT OF 1934 AS OF DECEMBER 31, 2024**

### NET CAPITAL:

| Total members' equity                               | \$ 485,147            |
|-----------------------------------------------------|-----------------------|
| Less non-allowable assets:                          |                       |
| Commissions receivable, non-allowable, net          | (182,543)             |
| Office furniture and equipment                      | (7,218)               |
| Prepaid expenses                                    | (98,310)              |
| Receivables due from stockholder & advisors         | (98,000)<br>(386,071) |
| Net capital before haircuts                         | 99,076                |
| Less haircuts                                       |                       |
| Net capital                                         | 99,076                |
| Minimum net capital required                        | 89,386                |
| Excess net capital                                  | \$9.690               |
| Aggregate indebtedness                              | \$1,340,794           |
| Minimum net capital based on aggregate indebtedness | \$<br>89,386          |
| Ratio of aggregate indebtedness to net capital      | 13.53 to 1.00         |

### RECONCILIATION WITH COMPANY'S COMPUTATION OF NET CAPITAL INCLUDED IN PART IIA OF FORM X-17 A-5 AS OF DECEMBER 31, 2024

There is no significant difference between net capital as reported in Part IIA of Form X-17a-5, as amended, and net capital as reported above.

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

### **DEMPSEY LORD SMITH, LLC**

### SCHEDULE II COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION AS OF DECEMBER 31, 2024

The Company is exempt from the provisions of Rule 15c3-3 under the Securities Exchange Act of 1934, pursuant to paragraph (k)(2)(ii) of the rule.

With respect to the Computation for Determination of Reserve Requirements under Rule 15c3-3, the Company also does not claim an exemption from Rule 15c3-3 pertaining to certain other business activities that the Company performs in reliance upon Footnote 74 of the SEC Release No. 34-70073. The Company does not hold customer funds or securities.

### SCHEDULE III

### INFORMATION RELATING TO THE POSSESSION OR CONTROL REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION AS OF DECEMBER 31, 2024

The Company is exempt from the provisions of Rule 15c3-3 under the Securities Exchange Act of 1934, pursuant to paragraph (k)(2)(ii) of the rule.

With respect to the Information Relating to the Possession or Control Requirements under Rule 15c3-3, the Company also does not claim an exemption from Rule 15c3-3 pertaining to certain other business activities that the Company performs in reliance upon Footnote 74 of the SEC Release No. 34-70073. The Company does not hold customer funds or securities.

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

**RUBIO CPA, PC**  CERTIFIED PUBLIC ACCOUNTANTS 3500 Lenox Road NE

Suite 1500 Atlanta, GA 30326 770-690-8995

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

To the Members of Dempsey Lord Smith, LLC

We have reviewed management's statements included in the accompanying Broker Dealers Annual Exemption Report in which ( 1) Dempsey Lord Smith, LLC identified the following provisions of 17 C.F .R. § l 5c3-3(k) under which Dempsey Lord Smith, LLC claimed an exemption from 17 C.F.R. § 240.15c3-3: (k)(2)(ii) (the "exemption provisions"); and, (2) Dempsey Lord Smith, LLC stated that Dempsey Lord Smith, LLC met the identified exemption provisions throughout the most recent fiscal year without exception. Dempsey Lord Smith, LLC's management is responsible for compliance with the exemption provisions and its statements.

Dempsey Lord Smith, LLC also filed its Exemption Report as a Non-Covered Finn relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240. l 7a-5 because Dempsey Lord Smith, LLC limits its other business activities to effecting securities transactions via subscriptions on a subscription way where the funds are payable to the issuer or its agent and not to Dempsey Lord Smith, LLC and Dempsey Lord Smith, LLC (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers ( other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of Rule 15c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to Dempsey Lord Smith, LLC); (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception.

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 Dempsey Lord Smith, 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)(ii), of Rule l 5c3-3 under the Securities Exchange Act of 1934 as well as in Footnote 74 of SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5.

April 1, 2025 Atlanta , GA

Rubio CPA, PC

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

![](_page_18_Picture_0.jpeg)

### **DEMPSEY LORD SMITH, LLC'S EXEMPTION REPORT**

Dempsey Lord Smith, LLC (the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Secw-ities 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)(l) and (4). To the best of its knowledge and belief, the Company states the following:

I. The Company claimed an exemption from the provisions of Rule 15c3-3 under the Securities and Exchange Act of 1934, pw-suant to paragraph (k)(2)(ii) of the Rule.

2. The Company met the identified exemption provisions throughout the most recent fiscal year ended December 31, 2024, without exception.

3. The Company is also filing this Exemption Repo1t because the Company's other business activities contemplated by Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. §240. l 7a-5 are limited effecting securities transactions via subscliptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company and the Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers ( other than money or other consideration received and promptly transmitted in compliance with paragraphs (a) or (b)(2) of *Rule* 15c2-4 and/or funds received and promptly transmitted for effecting transactions via subscliptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company); (2) did not carry accounts of or for customers; and (3) did not cany P *AB* accounts ( as defined in Rule 15c3-3) throughout the most recent fiscal year ended December 31, 2024, witl1out exception.

0


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