# CAPITAL CITY SECURITIES, LLC X-17A-5 (2023-03-06) — Broker-dealer annual report

- Company: CAPITAL CITY SECURITIES, LLC
- Form: X-17A-5
- Filed: 2023-03-06
- Period: 2021-12-30
- Accession: 0001420522-23-000003
- CIK: 1420522
- File #: 8-67771
- Type: Broker-dealer
- Material weakness: No
- Auditor: HHH CPA Group
- Auditor location: Columbus, OH
- Contact: Todd Crawford
- Phone: 6144853108
- Email: tecrawford@capitalcitypartners.com
- Website: capitalcitypartners.com
- Signed by: Todd Crawford (President)

Original filing: https://www.sec.gov/Archives/edgar/data/1420522/000142052223000003/2021.pdf

---

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

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

| OMB Number: 3235-0123     |  |
|---------------------------|--|
| Expires: Oct. 31, 2023    |  |
| Estimated average burden  |  |
| hours per response:<br>12 |  |
| SEC FILE NUMBER           |  |

## **ANNUAL REPORTS FORM X-17A-5 PART III**

**SEC FILE NUMBER** 8-67771

**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                                                                                                                                                                                                               | 01/01/21                                                   | AND ENDING                                   |                               | 12/31/21                           |  |  |
|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------|----------------------------------------------|-------------------------------|------------------------------------|--|--|
|                                                                                                                                                                                                                                               | MM/DD/YY                                                   |                                              | MM/DD/YY                      |                                    |  |  |
|                                                                                                                                                                                                                                               | A.<br>REGISTRANT IDENTIFICATION                            |                                              |                               |                                    |  |  |
| Capital<br>NAME OF FIRM:                                                                                                                                                                                                                      | City<br>Securities,<br>LLC                                 |                                              |                               |                                    |  |  |
| TYPE OF REGISTRANT (check all applicable boxes):                                                                                                                                                                                              |                                                            |                                              |                               |                                    |  |  |
| ®<br>Security-based<br>Broker-dealer<br>Check here if respondent is also an OTC derivatives dealer                                                                                                                                            | Major<br>swap dealer<br>security-based<br>swap participant |                                              |                               |                                    |  |  |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS:(Do                                                                                                                                                                                                    | not                                                        | use a P.O. box no.)                          |                               |                                    |  |  |
|                                                                                                                                                                                                                                               | 3789<br>Attucks                                            | Drive                                        |                               |                                    |  |  |
|                                                                                                                                                                                                                                               | (No. and<br>Street)                                        |                                              |                               |                                    |  |  |
| Powell                                                                                                                                                                                                                                        | Ohio                                                       |                                              |                               | 43065                              |  |  |
| (City)                                                                                                                                                                                                                                        | (State)                                                    |                                              |                               | (Zip Code)                         |  |  |
| PERSON TO CONTACT WITH REGARD TO THIS FILING                                                                                                                                                                                                  | (614)<br>485-3108                                          |                                              |                               | tecrawford@capitalcitypartners.com |  |  |
| Todd<br>Crawford<br>(Name)                                                                                                                                                                                                                    | (Area Code -Telephone                                      | Number)                                      | (Email Address)               |                                    |  |  |
|                                                                                                                                                                                                                                               | B.<br>ACCOUNTANT IDENTIFICATION                            |                                              |                               |                                    |  |  |
| INDEPENDENT PUBLIC ACCOUNTANT whose reports                                                                                                                                                                                                   | HHH<br>CPA                                                 | in<br>this<br>are contained<br>Group,<br>LLC | filing*                       |                                    |  |  |
| (Name -if                                                                                                                                                                                                                                     | individual,<br>state last,                                 | first,and<br>middle name)                    |                               |                                    |  |  |
| Old<br>1250<br>Henderson<br>Road                                                                                                                                                                                                              | Columbus                                                   |                                              | Ohio                          | 43220                              |  |  |
| (Address)                                                                                                                                                                                                                                     | (City)                                                     |                                              | (State)                       | (Zip Code)                         |  |  |
| 12/21/2010                                                                                                                                                                                                                                    |                                                            |                                              | 5344                          |                                    |  |  |
| (Pate of Registration with PCAOB)(if applicable)                                                                                                                                                                                              |                                                            |                                              | (PCAOB Registration Number,if | applicable)                        |  |  |
|                                                                                                                                                                                                                                               | FOR OFFICIAL USE ONLY                                      |                                              |                               |                                    |  |  |
| * Claims for exemption from the requirement that the annual reports be covered by the reports of an independent public<br>accountant must be supported by a statement of facts and circumstances relied on as the basis of the exemption. See |                                                            |                                              |                               | 17                                 |  |  |

CFR 240.17a-5(e)(l)(ii),if applicable.

**Persons who are to respond to the collection of information contained in this form are notrequired to respond unless the form displays a currently valid OMB control number.**

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

#### **OATH OR AFFIRMATION**

| Todd<br>Crawford<br>i ,<br>financial report pertaining to<br>the<br>firm<br>of                                       | that,<br>,<br>swear (or affirm)<br>to<br>the best<br>of my knowledge<br>Capital<br>City<br>Securities,<br>LLC                     | and belief,<br>the<br>,<br>as of                             |
|----------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------|
| ,<br>r<br>30<br>Depefnber<br>2 022 ,is<br>rcX<br>*<br>partner,officer,director,or<br>equivalent person,<br>customer. | and correct.<br>true<br>I<br>further<br>swear (or affirm)<br>that<br>may be,<br>as the case<br>has any proprietary interest<br>in | neither the company nor any<br>any account classified solely |
| as that<br>of a<br>Notary Publi                                                                                      | Signature:<br>MELANIE J. HART<br>Notary Public. State of Ohio<br>My Comm. Expires 06/16/2023<br>Title:<br>.J)                     |                                                              |

#### **This filing\*\* contains (check all applicable boxes):**

- [X (a) Statement of financial condition.
- B (b) Notes to consolidated statement of financial condition.
- K (c) Statement of income (loss) or,if there is other comprehensive income in the period(s) presented, <sup>a</sup> statement of comprehensive income (as defined in § 210.1-02 of Regulation S-X).
- ffi (d) Statement of cash flows.

*\**

- &! (e) Statement of changes in stockholders' or partners' or sole proprietor's equity.
- E (f) Statement of changes in liabilities subordinated to claims of creditors.
- <sup>39</sup> (g) Notes to consolidated financial statements.
- S3 (h) Computation of net capital under <sup>17</sup> CFR 240.15c3-lor <sup>17</sup> CFR 240.18a-l, as applicable.
- (i) Computation of tangible net worth under <sup>17</sup> CFR 240.18a-2.
- (j) Computation for determination of customer reserve requirements pursuant to Exhibit <sup>A</sup> to 17 CFR 240.15c3-3.
- (k) Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.15c3-3 or Exhibit <sup>A</sup> to <sup>17</sup> CFR 240.18a-4, as applicable.
- (I) Computation for Determination of PAB Requirements under Exhibit <sup>A</sup> to § 240.15c3-3.
- (m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3.
- (n) Information relating to possession or control requirements for security-based swap customers under 17 CFR 240.15c3-3(p)(2) or <sup>17</sup> 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 <sup>17</sup> CFR 240.15c3-l,17 CFR 240.18a-l, or <sup>17</sup> CFR 240.18a-2, as applicable,and the reserve requirements under <sup>17</sup> CFR 240.15c3-3 or <sup>17</sup> CFR 240.18a-4, as applicable,if material differences exist, or <sup>a</sup> statement that no material differences exist.
- (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition.
- (S (q) Oath or affirmation in accordance with <sup>17</sup> CFR 240.17a-5,17 CFR 240.17a-12,or <sup>17</sup> CFR 240.18a-7,as applicable.
- (r) Compliance report in accordance with <sup>17</sup> CFR 240.17a-5 or <sup>17</sup> CFR 240.18a-7, as applicable.
- El (s) Exemption report in accordance with <sup>17</sup> CFR 240.17a-5 or <sup>17</sup> CFR 240.18a-7, as applicable.
- (t) Independent public accountant's report based on an examination of the statement of financial condition.
- G5 (u) Independent public accountant's report based on an examination of the financial report or financial statements under 17 CFR 240.17a-5, <sup>17</sup> CFR 240.18a-7, or <sup>17</sup> CFR 240.17a-12, as applicable.
- (v) Independent public accountant's report based on an examination of certain statements in the compliance report under 17 CFR 240.17a-5 or <sup>17</sup> CFR 240.18a-7, as applicable.
- 38 (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.
- <sup>33</sup> (x) Supplemental reports on applying agreed-upon procedures,in accordance with <sup>17</sup> CFR 240.15c3-le or <sup>17</sup> CFR 240.17a-12, as applicable.
- Bf (y) Report describing any material inadequacies found to exist or found to have existed since the date of the previous audit,or <sup>a</sup> statement that no material inadequacies exist,under <sup>17</sup> CFR 240.17a-12(k). \_ r/ "T 0 (z) Other: / *\*
- rs.yf
- *\*\*To request confidential treatment of certain portions of this filing***,** *see <sup>17</sup> CFR 240.17a-5(e)(3) or <sup>17</sup> CFR 240.18a-7(d)(2), as applicable.*

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

### **CAPITAL CITY SECURITIES, LLC**

### **FINANCIAL STATEMENTS**

**DECEMBER 31, 2021 AND 2020**

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

**Nick DiBartolomeo, CPA Brian Schneider. CPA**

MHHHffW

![](_page_3_Picture_1.jpeg)

**Rick Dumas, CPA James Peters, CPA**

### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Board of Directors of Capital City Securities, LLC Powell, Ohio

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

We have audited the accompanying statements of financial condition of Capital City Securities, LLC (an Ohio limited liability corporation) as of December 31, 2021 and 2020, and the related statements of operations, changes in member's equity and cash flows for the years then ended, and the related notes and schedules (collectively referred to as the financial statements). In our opinion, the financial statements present fairly, in all material respects, the financial position of Capital City Securities, LLC as of December 31, 2021 and 2020, and the results of its operations and its cash flows for the years 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 Capital City Securities, LLC's management. Our responsibility is to express an opinion on Capital City Securities, 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 Capital City Securities, 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 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.

<sup>1250</sup> Old Henderson Road. Columbus, OH <sup>43220</sup> | Phone: (614) 451-4644 | Fax: (614) 451-3818 | www hhhepagroup com

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

### **Supplemental Information**

The schedule of Computation of Net Capital Under Rule 15c3-l of the Securities and Exchange Commission, Schedule of Aggregate Indebtedness, Reconciliation with Company's Computation of Net Capital as Included in Part IIA of Form X-17A-5 , and Statement on Exemption from Computation of Reserve Requirement and Information for Possession or Control Requirements Under Rule 15c3-3 of The Securities and Exchange Commission have been subjected to audit procedures performed in conjunction with the audit of Capital City Securities, LLC's financial statements. The supplemental information is the responsibility of Capital City Securities, LLC's management. Our audit procedures included determining whether the supplemental information reconciles to the financial statements or the underlying accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the supplemental information. In forming our opinion on the supplemental information, we evaluated whether the supplemental information, including its form and content, is presented in conformity with 17 C.F.R. §240.17a-5. In our opinion, the Computation of Net Capital Under Rule 15c3-l of the Securities and Exchange Commission, Schedule of Aggregate Indebtedness, Reconciliation with Company's Computation of Net Capital as Included in Part IIA of Form X-17A-5, and Statement on Exemption from Computation of Reserve Requirement and Information for Possession or Control Requirements Under Rule 15c3-3 of The Securities and Exchange Commission are fairly stated, in all material respects, in relation to the financial statements as a whole.

*HfiH ess?* HHH CPA Group, LLC *t - Lcr*

We have served as Capital City Securities, LLC"s auditor since 2011. Columbus, Ohio March 31, 2022

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

### **Capital City Securities, LLC STATEMENTS OF FINANCIAL CONDITION**

#### **December 31, 2021 and 2020**

|                                                          | 2021          | 2020          |
|----------------------------------------------------------|---------------|---------------|
| ASSETS                                                   |               |               |
| Cash                                                     | \$<br>32.082  | \$<br>94,876  |
| Restricted cash and equivalents                          | 50,000        | 50,000        |
| Total Cash                                               | 82.082        | 144,876       |
| Fees Receivable                                          | 54,654        | 6,644         |
| Receivable from broker-dealers and clearing organization | 14,597        |               |
| Accounts receivable -<br>related party                   | 151,549       | 37,935        |
| Accounts receivable -<br>employees                       | 16,168        |               |
| Other Assets                                             | 12,953        | 13,595        |
| Total Current Assets                                     | 332,003       | 203,050       |
| Long Term Assets                                         |               |               |
|                                                          | \$<br>332,003 | \$<br>203,050 |
| LIABILITIES AND MEMBERS' EQUITY                          |               |               |
| Accounts Payable                                         | \$<br>45,442  | \$<br>96,394  |
| Commission Payable                                       | 66,707        | 12,976        |
| Other Liabilities                                        | 686           | 906           |
| Total Current Liabilities                                | 112,835       | 110,276       |
| Long Term Liabilities                                    |               |               |
| Total Liabilities                                        | 112,835       | 110,276       |
| Members'<br>Equity:                                      |               |               |
| Contributed Capital                                      | 205.000       | 205,000       |
| Retained Earnings                                        | 14,168        | (112,226)     |
| Total Members'Equity                                     | 219,168       | 92,774        |
|                                                          | \$<br>332,003 | \$<br>203.050 |

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

## **STATEMENTS OF OPERATIONS FOR THE YEARS ENDED DECEMBER 31, 2021 AND 2020**

|                                                                                                                                                          | 2021 |                                                                   | 2020                                                               |
|----------------------------------------------------------------------------------------------------------------------------------------------------------|------|-------------------------------------------------------------------|--------------------------------------------------------------------|
| :<br>Revenues                                                                                                                                            |      |                                                                   |                                                                    |
| Commissions<br>Income<br>Other                                                                                                                           | \$   | 890,752<br>40,600                                                 | \$<br>604,718<br>38,239                                            |
| Total<br>Revenues                                                                                                                                        |      | 931,352                                                           | 642,957                                                            |
| :<br>Expenses                                                                                                                                            |      |                                                                   |                                                                    |
| Commissions<br>Clearing<br>House<br>Charges<br>Licenses,<br>Dues<br>Subscriptions<br>and<br>Fees<br>Professional<br>Insurance<br>Rent<br>Office<br>Other |      | 586,350<br>93,697<br>9,804<br>60,993<br>35,354<br>7,185<br>11,575 | 341,924<br>97,876<br>62,108<br>60,872<br>19,178<br>4,890<br>14,168 |
| Total<br>Expenses                                                                                                                                        |      | 804,958                                                           | 601,016                                                            |
| Income<br>Net                                                                                                                                            | \$   | 126,394                                                           | \$<br>41,941                                                       |

See accompanying notes to financial statements

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

### **Capital City Securities, LLC STATEMENTS OF CASH FLOWS**

### **For the Years Ended December 31, 2021 and 2020**

|                                                                                                                                                                                                               | 2021 |                                                      | 2020 |                                         |
|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------|------------------------------------------------------|------|-----------------------------------------|
|                                                                                                                                                                                                               |      |                                                      |      |                                         |
| Cash flows from Operating Activities:<br>Net Income<br>Adjustments to reconcile Net Income to<br>Net Cash<br>operating activities:<br>provided by                                                             | \$   | 126,394                                              | \$   | 41,941                                  |
| :<br>(Increase)<br>Decrease in<br>Fees Receivable<br>Receivable from broker-dealers and clearing organization<br>Accounts Receivable -<br>related party<br>Accounts Receivable -<br>employees<br>Other Assets |      | (48,010)<br>(14,597)<br>(113,614)<br>(16,168)<br>642 |      | 44.292<br>29.365<br>(19,113)<br>(2,083) |
| :<br>Decrease in<br>(Increase)<br>Accounts Payable<br>Payable<br>Commission<br>Other Liabilities                                                                                                              |      | (50,952)<br>53,731<br>(220)                          |      | 51,680<br>(58,023)<br>906               |
| Total<br>Adjustments                                                                                                                                                                                          |      | (189,188)                                            |      | 47,024                                  |
| Net<br>Cash Provided<br>by (Used<br>in)<br>Operating Activities                                                                                                                                               |      | (62,794)                                             |      | 88,965                                  |
| Investing Activities:<br>Cash flows from                                                                                                                                                                      |      |                                                      |      |                                         |
| Financing Activities:<br>Cash flows from<br>Contributions<br>Distributions                                                                                                                                    |      |                                                      |      | 539                                     |
| Net<br>Cash Provided by Financing Activities                                                                                                                                                                  |      |                                                      |      | 539                                     |
| Increase (Decrease)<br>in<br>Cash<br>Net                                                                                                                                                                      |      | (62.794)                                             |      | 89,504                                  |
| Cash and Restricted Cash at beginning of period                                                                                                                                                               |      | 94.876                                               |      | 5,372                                   |
| Cash<br>at end<br>of period<br>Cash<br>and Restricted                                                                                                                                                         | \$   | 32,082                                               | \$   | 94,876                                  |
| Supplemental Disclosures:<br>Interest Paid                                                                                                                                                                    | \$   |                                                      | \$   |                                         |
| Taxes<br>Paid<br>Income                                                                                                                                                                                       | \$   |                                                      | \$   |                                         |

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

### **Capital City Securities, LLC STATEMENTS OF CHANGES IN MEMBERS' EQUITY**

### **For the Years Ended December 31, 2021 and 2020**

|                                 | 2021 |           | 2020 |           |  |
|---------------------------------|------|-----------|------|-----------|--|
| Contributed Capital :           |      |           |      |           |  |
| Balance at<br>Beginning of Year | \$   | 205.000   | \$   | 205,000   |  |
| Contributions                   |      |           |      |           |  |
| Balance at End of Year          | \$   | 205.000   | \$   | 205,000   |  |
| Retained Earnings:              |      |           |      |           |  |
| Balance at<br>Beginning of Year | \$   | (112,226) | \$   | (154,706) |  |
| Net<br>Income                   |      | 126,394   |      | 41,941    |  |
| Contributions                   |      |           |      | 539       |  |
| Distributions                   |      |           |      |           |  |
| Balance at End of<br>Year       | \$   | 14,168    | \$   | (112,226) |  |
| Total Members'<br>Equity        | \$   | 219,168   | \$   | 92,774    |  |

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

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

### Note <sup>1</sup> - Summary of Significant Accounting Policies

### A. Organization

Capital City Securities, LLC (the Company) was formed as a limited liability company in the State of Ohio in August 2006. The Company has been operating as a broker-dealer registered with the Securities and Exchange Commission (SEC) and the State of Ohio Securities Division since May 29, 2008; it is a member of the Financial Industry Regulatory Authority, Inc. (FINRA).

The Company operates pursuant to Exchange Act Rule 15c3-3(k)(2)(ii), clearing transactions on a fully disclosed basis through its clearing firm, RBC Capital Markets Corporation ("RBC"), and on an application-way basis with registered investment companies, insurance and annuity providers, and other product offerings. Customer accounts held directly at a product issuer for which the Company is listed as the broker-dealer of record. The Company does not hold customer funds or safeguard customer securities.

As of December 31, 2021, the Company is licensed in 22 states, including Alaska, Arizona, California, Colorado, Florida, Hawaii, Illinois, Indiana, Iowa, Kentucky, Massachusetts, Michigan, Maryland, New York, North Carolina, New Jersey, Ohio, Pennsylvania, South Carolina, Texas, Nevada and Virginia.

#### Management's Estimates B.

The preparation of financial statements in conformity with generally accepted accounting principles requires management to make estimates and assumptions that affect reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements, and the reported amounts of revenue and expenses during the reporting period. Actual results could differ from those estimates.

#### Cash and Restricted Cash Equivalents C.

The Company maintains cash balances at one bank, one money market account and on deposit with FINRA. The cash balance in the bank was under the federally insured limit of \$250,000 as of December 31, 2021. For purposes of the statement of cash flows, the Company considers all cash in checking accounts, money market accounts and held at FINRA to be cash equivalents.

Restricted cash equivalents represent amounts on deposit at financial institutions that are legally restricted due to contract terms with RBC. Included in the statements of financial condition is a restricted cash deposit for margin requirements at RBC in the amount of \$50,000.

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

### Note 1- Summary of Significant Accounting Policies-

#### D. Concentration of Credit Risk

Financial instruments that potentially subject the Company to significant concentrations of credit risk consist principally of cash and commissions receivable. The Company places its cash with high credit quality financial institutions, which at times may be in excess of FDIC insurance limits. The Company's receivables represent commissions from completed securities trades and monies owed it from licensed securities representatives for charges incurred at the firm. All customer transactions are cleared through another broker-dealer on a fully disclosed basis.

#### Advertising Costs E.

Advertising costs are expensed when incurred. Advertising costs were \$301 and \$297 in 2021 and 2020, respectively. Advertising is included in other expenses.

### F. Securities Transactions and Revenue Recognition

Securities transactions, commissions and related clearing expenses are reported on a trade date basis. The change in the resulting difference between cost and market is included in net trading profits in the statement of income. The Company's activities are transacted on either a cash or margin basis. Margin transactions are subject to various regulatory and internal margin requirements and are collateralized by cash and securities in the Company's accounts.

Commission expense is also recorded on a trade-date basis as security transactions occur.

### G. Receivables

I

Accounts receivable -related party are stated at the amount billed. Registered representative affiliation fees, commission charge backs and other costs that are the responsibility of registered representatives are offset against amounts owed to registered representatives for their commission payables. If the balance of the debits owed to the Company exceed the amount owed to the registered representative, the net balance owed to the Company is recorded as a receivable.

The receivable from broker-dealers and clearing organization is the net amount owed from RBC to the Company for dealer activity. The receivable is recorded net of any related liabilities to the clearing firm on the accompanying statement of financial condition.

Management individually reviews all receivable balances that exceed 30 days from the invoice date and based on an assessment of various factors, estimates the portion, if any, of the balance that will not be collected. In the opinion of management, all receivables are considered collectible and no allowance was necessary at December 31, 2021 and 2020.

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

## Note 1- Summary of Sienificant Accounting Policies-:

### H. Government and Other Regulations

The Company's business is subject to significant regulation by various governmental agencies and self-regulatory organizations. Such regulation includes, among other things, periodic examinations by these regulatory bodies to determine whether the Company is conducting and reporting its operations in accordance with the requirements of these organizations. As a registered broker-dealer, the Company is subject to the SEC's Net Capital Rule 15c3-l which requires that the Company maintains a minimum net capital, as defined [see note 3],

### Note 2— Reserve Requirements

The Company is not obligated to report under SEC Rule 15c3—3 since it does not maintain customer accounts or hold securities. All customer transactions are cleared through another broker—dealer on <sup>a</sup> fully disclosed basis. Therefore, the Company does not have a reserve requirement nor does it have any information relating to the possession or control requirement under Rule 15c3—3.

## Note 3— Net Capital Requirements (Schedules <sup>1</sup> and II)

Under SEC Rule 15c3—1, the Company is required to maintain net capital of not less than the greater of 6.67% of total aggregate indebtedness liabilities, exclusive of subordinated debt, for the year ended December 31, 2021, \$7,526, or \$5,000. At December 31, 2021 the Company's net capital as defined by SEC Rule 15c3—1 was \$30,972 in excess of the minimum net capital required.

In addition to the minimum net capital provision. SEC Rule 15c3—1 requires that the Company maintain a ratio of aggregate indebtness, as defined, to capital, of not more than 15 to 1. At December 31, 2021 the ratio was 2.91 to 1.

### Note 4 — Related Party Transactions

Capital City Securities, LLC is one of four subsidiaries of the parent company Capital City Partners, Inc. (CCP). Certain expenses are incurred by CCP, which then bills the four subsidiaries based on direct consumption. The expenses relating to these transactions are wages, insurance, rent, utilities, and office expenses. These services accounted **for \$ 1 4 ,7 9 5** in 2021 and \$15,268 in 2020, respectively.

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

### Note 5— Income Taxes

i

The Company is recognized as <sup>a</sup> "pass—through entity" under the Internal Revenue Code and pays no federal and state taxes. The parent company is taxed individually on the Company's taxable income.

The Company recognizes and disclosures uncertain tax positions in accordance with accounting principles generally accepted in the United States of America. As of and during the year ended December 31, 2021, the Company did not have a liability for unrecognized tax benefits. The Company is no longer subject to examination by federal and state taxing authorities for returns filed prior to 2017.

### Note 6 - Recent Accounting Pronouncement

The Company adopts all applicable, new accounting pronouncements as of the specified effective dates.

In February 2016, the Financial Accounting Standards Board ("FASB") issued ASU No. 2016-02, Leases, as a new Accounting Standards Codification Topic 842 ("ASC Topic 842"), which wall supersede nearly all existing revenue recognition guidance under GAAP. Under the new provisions, all lessees will report a right-of-use asset and a liability for the obligation to make payments for all leases with the exception of those leases with a term of 12 months or less. All other leases will fall into one of two categories:

- Financing leases, similar to capital leases, will require the recognition of an asset and liability, measured at the present value of the lease payments.
	- o Interest on the liability wall be recognized separately from amortization of the asset,
	- o Principal repayments will be classified as financing outflows and payments of interest as operating outflows on the statement of cash flows.
- Operating leases will also require the recognition of an asset and liability measured at the present value of the lease payments.
	- o A single lease cost, consisting of interest on the obligation and amortization of the asset, calculated such that the amortization of the asset will increase as the interest amount decreases resulting in a straight-line recognition of lease expense,
	- o All cash outflows will be classified as operating on the statement of cash flows.
- The standard is effective for us for annual periods beginning January 1, 2020. We adopted ASC Topic 842 as of January <sup>1</sup> , 2020. An assessment to determine the impacts of the new accounting standard has been performed. Based on our assessment, the adoption of ASC Topic 842 did not have a material impact on our financial statements.
- Other accounting standards that have been issued or proposed by the FASB or other standards-setting bodies that do not require adoption until a future date are not expected to have a material impact on our financial statements upon adoption.

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

# Note <sup>7</sup> -COVID-19

During March 2020, the state and federal government issued stay at home and social distancing recommendations to combat the COV1D-19 global pandemic. As a result, numerous local businesses were closed and employees were laid off. The Organization has made operational modifications to comply with the above recommendations, but continues to offer its services as of the audit report date. There has been a restructuring of meetings and customer interactions as result of these regulations. The Organization believes it has enough capital reserves to withstand the effects of the pandemic through the following 12 months from the report dale. We are unable to project what other effects this pandemic will have beyond the subsequent 12 month from the date of the audit report, but management has no plans to cease operations.

### Note 8 — Litigation

On September 21, 2020 the firm agreed to an Acceptance of Letter of Acceptance, Waiver, and Consent (AWC) with FINRA. Capital City Securities, LLC, CRD No. 146001, Matter No. 2015048347902 Respondent also consents to the imposition of the following sanctions:

1. Censure, and

2. An order to pay restitution in the amount of \$53,174.51.

Respondent made the required restitution payments. Therefore the Matter is settled. The details for the cause of the AWC are as follows:

Between August <sup>2015</sup> and June <sup>2016</sup> (the "Relevant Trading Period,, )J Capital City failed to establish and maintain a supervisory system, and failed to establish, maintain and enforce written supervisory procedures, that were reasonably designed to achieve compliance with FINRA's suitability rules. Specifically, the firm used a third-party automated trade surveillance application to supervise and review registered representative trading recommendations and strategies yet did not rc-configure, modify, or alter that surveillance tool to monitor unique trading strategies like that of registered representative CK. Second, with respect to CK., the firm bifurcated responsibility for supervising his equity and options recommendations by product, even where those recommendations impacted the same customer account as part of a singular, active trading strategy. As a result, individual supervisors were unable to identify patterns and evaluate the trading strategy employed by CK, who effected quantitatively unsuitable transactions in five customer accounts over which he had discretionary trading authority. CK's trading in these customer accounts generated cost-to-cquity ratios and turnover rates ranging from 19.7% to 31.7o/o and 8.2 to 12.7, respectively. Through this conduct, Capital City violated FINRA Rules 3110 and 2010.

In addition, between July 30, 2015 and August 10, 2015, Capital City failed to conduct a reasonable due diligence review of a private placement by registered representative JM, in violation of FINRA Rules 3110 and 201'A. Finally, between July 22,2015 and August 24,2016, Capital City failed to preserve and maintain certain books and records required by Section 17(a) of the Securities Exchange Act of 1934 ("the Exchange Act") and Rule 17a-4 promulgated thereunder ("SEA Rule 17a-4"). Specifically, Capital City failed to preserve and maintain over 200 of JM's business-related electronic communications conducted through his personal email address. As a result, the firm violated Section 17(a) of the Exchange Act, Rule 17a-4 thereunder, and FINRA Rules 4511 and 201**,**0**.**

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

#### Note 9 -Subsequent Events

Management has reviewed all events subsequent to December 31, 2021, up to the date of audit repor<sup>t</sup> (March <sup>31</sup>, 2022) and has not encountered any subsequent events that affect the current financial statements or that require additional disclosure.

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

### **SUPPLEMENTARY INFORMATION**

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

### CAPITAL CITY SECURITIES, LLC As of December 31, <sup>2021</sup>

Schedule I Computation of Net Capital Under Rule 15c3 1 of the Securities and Exchange Commission

| Total ownership<br>equity<br>qualified                                              |           |    |           |  |
|-------------------------------------------------------------------------------------|-----------|----|-----------|--|
| for<br>net<br>capital                                                               |           | \$ | 219,168   |  |
| Increase (Decrease)                                                                 |           |    |           |  |
| Non-allowable assets                                                                |           |    |           |  |
| Accounts receivable -related<br>party                                               | 151,549   |    |           |  |
| Accounts receivable -<br>employee                                                   | 16,168    |    |           |  |
| Other<br>assets                                                                     | 12,953    |    | (180,670) |  |
|                                                                                     |           |    |           |  |
| Haircuts on<br>securities                                                           |           |    |           |  |
| Audited<br>Net Capital                                                              |           | \$ | 38,498    |  |
| 6 2/3%<br>of<br>Aggregate Indebtedness                                              |           |    | 7,526     |  |
| -<br>Greater of \$5,000<br>or 6 2/3%<br>Minimum<br>of<br>Net<br>Capital Requirement |           |    |           |  |
| Aggregate Indebtedness                                                              |           |    | 7,526     |  |
|                                                                                     |           |    |           |  |
| Excess Net Capital                                                                  |           |    | 30,972    |  |
| greater of<br>120% of<br>the<br>Minimum<br>Net<br>capital less<br>the<br>Net        |           |    |           |  |
| Capital Requirement (\$6,000),or<br>10% of<br>Indebtedness (\$11,284)               | Aggregate |    | 27,214    |  |
|                                                                                     |           | \$ |           |  |

i

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

### CAPITAL CITY SECURITIES, LLC As of December 31, <sup>2021</sup>

### Schedule II Schedule of Aggregate Indebtedness

| aggregate indebtedness:<br>Computation<br>of            |               |
|---------------------------------------------------------|---------------|
| Accounts payable                                        | \$<br>45,442  |
| Commissions payable                                     | 66,707        |
| Other liabilities                                       | 686           |
|                                                         | \$<br>112,835 |
| Ratio of<br>aggregate indebtedness to<br>capital<br>net | 1<br>2.91to   |

Schedule III

Reconciliation with Company's Computation of Net Capital as Included in Part IIA of Form X-17A-5

| Total ownership equity | qualified                              |         |               |
|------------------------|----------------------------------------|---------|---------------|
| for<br>net             | capital                                |         | \$<br>219,168 |
| Increase (Decrease)    |                                        |         |               |
|                        | Non-allowable assets                   |         |               |
|                        | Accounts receivable -related<br>party  | 151,549 |               |
|                        | -<br>Accounts receivable<br>employee   | 16,168  |               |
|                        | Other assets                           | 12,953  | (180,670)     |
| Haircuts on            | securities                             |         |               |
|                        | Audited Net Capital                    |         | 38,498        |
|                        | Unaudited Net Capital per Focus Report |         | 39,185        |
|                        | Difference                             |         | \$<br>687     |

The difference is due to an unsecured liability that was adjusted after the FOCUS report filing.

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

### **Statement on Exemption from Computation of Reserve Requirement and Information for Possession or Control Requirements Under Rule 15c3-3 of The Securities and Exchange Commission**

In accordance with the exemptive provision of SEC Rule 15c3-3, specifically exemption k(2)(ii), the Company is exempt from computation of a reserve requirement and the information relation to the possession or control requirements.

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

### **SEC Rule 15c3-3 Exemption Report**

Board of Directors Capital City Securities, LLC

Capital City Securities, LLC (the Company) is <sup>a</sup> registered broker-dealer subject to Rule <sup>17</sup>a-<sup>5</sup> promulgated by the Securities and Exchange Commission (17 CFR 240.17a-5- "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by <sup>17</sup> CFR 240.17a-5(d)(l) and (4). To the best of its knowledge the Company states the following:

The Company is exempt from Rule 17 CFR 15c3-3 under provision (k)(2)(ii) of Rule 15c3-3 of the Securities Exchange Act of 1934. The Company met the identified exemption provision identified above throughout the most recent fiscal year ended December 31, 2020, without exception.

Capital City Securities, LLC

I, Todd Crawford swear (or affirm ) that, to my best knowledge and belief, this Exemption Report is true and correct.

Todd Crawford President

**March 30, 2022**

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

Nick DiBartolomeo, CPA Brian Schneider, CPA

![](_page_21_Picture_1.jpeg)

Rick Dumas, CPA James Peters, CPA

### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Board of Directors of Capital City Securities, LLC Powell, Ohio

We have reviewed management's statements, included in the accompanying SEC Rule 15c3-3 Exemption Report, in which (1) Capital City Securities, LLC identified the following provisions of 17 C.F.R. §15c3-3(k) under which Capital City Securities, LLC claimed an exemption from 17 C.F.R. §240.15c3-3: (2) (ii) (the "exemption provisions' ) and (2) Capital City Securities, LLC stated that Capital City Securities, LLC met the identified exemption provisions throughout the most recent fiscal year without exception. Capital City Securities, LLC's management is responsible for compliance with the exemption provisions and its statements.

Our review was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included inquiries and other required procedures to obtain evidence about Capital City Securities, LLC's compliance with the exemption provisions. <sup>A</sup> review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, we do not express such an opinion.

Based on our review, we are not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based on the provisions set forth in paragraph (k) (2) (ii) ) of Rule 15c3-3 under the Securities Exchange Act of 1934.

*HHH C/0 Li - Cr*

HHH CPA Group, LLC Columbus, Ohio March 31, 2022

<sup>1250</sup> Old Henderson Road, Columbus. OH <sup>43220</sup> Phone (614) 451-4644 | Fax (614) 451-3818 | www hhhcpagroup.com

{22}------------------------------------------------

**Nick DiBartolomco. CPA Brian Schneider, CPA**

![](_page_22_Picture_1.jpeg)

**Rick Dumas, CPA**

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

To the Board of Directors of Capita] City Securities, LLC Powell, Ohio

We have performed the procedures included in Rule 17a-5(e) (4) under the Securities Exchange Act of 1934 and in the Securities Investor Protection Corporation (SIPC) Series 600 Rules, which are enumerated below and were agreed to by Capital City Securities, LLC and the SIPC, solely to assist you and SIPC in evaluating Capital City Securities, LLC's compliance with the applicable instructions of the General Assessment Reconciliation (Form SIPC-7) for the year ended December 31, 2021. Capital City Securities, 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 this report. Consequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose. The procedures we performed and our findings are as follows:

- Compared the listed assessment payments in Form SIPC-7 with respective cash disbursement records entries, noting no differences; 1**)**
- Compared the Total Revenue amount reported on the Annual Audited Report Form X-17A-5 Part III for the year ended December 31, 2021 with the Total Revenue amount reported in Form SIPC-7 for the year ended December 31, 2021, noting no differences; 2**)**
- Compared any adjustments reported in Form SIPC-7 with supporting schedules and working papers, noting no differences; **3)**
- Recalculated the arithmetical accuracy of the calculations reflected in Form SIPC-7 and in the related schedules and working papers supporting the adjustments, noting no differences; and **4)**
- Compared the amount of any overpayment applied to the current assessment with the Form SIPC-7 on which it was originally computed, noting no differences. **5)**

1250 Old Henderson Road, Columbus, OH 43220 | Phone: (614) 451-4644 | Fax: (614) 451-3818 | www.hhhcpagroup.com

{23}------------------------------------------------

We were not engaged to and did not conduct an examination or review, the objective of which would be the expression of an opinion or conclusion, respectively, on Capital City Securities, LLC's compliance with the applicable instructions of the Form SIPC-7 for the year ended December 31, 2021. 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 Capital City Securities, LLC and the SIPC and is not intended to be and should not be used by anyone other than these specified parties.

*fifth c-Sfl* Clo-

HHH CPA Group, LLC Columbus, Ohio March 31, 2022

{24}------------------------------------------------

| (36-REV 12/18) |  |
|----------------|--|

#### **SECURITIES INVESTOR PROTECTION CORPORATION Mail Code: 8967 P.O. Box 7247 Philadelphia, PA 19170-0001 SIPC-7 SIPC-7**

### **General Assessment Reconciliation**

(36-REV 12/18)

12**/**31/2021 For the fiscal year ended

(Read carefully the instructions in your Working Copy before completing this Form)

### **TO BE FILED BY ALL SIPC MEMBERS WITH FISCAL YEAR ENDINGS**

1. Name of Member, address, Designated Examining Authority, <sup>1934</sup> Act registration no. and month in which fiscal year ends for purposes of the audit requirement of SEC Rule 17a- 5:

|    |    | 67771                                                                                    | FINRA                                                                                          | DEC |  | Note:                         |          | If any of the information shown on the<br>mailing label requires correction, please e-mail |  |
|----|----|------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------|-----|--|-------------------------------|----------|--------------------------------------------------------------------------------------------|--|
|    |    |                                                                                          | Capital<br>City<br>Securities,<br>LLC                                                          |     |  | indicate on the form filed.   |          | any corrections to form@sipc.org and<br>so                                                 |  |
|    |    |                                                                                          | 3789<br>Drive<br>Attucks<br>43065-6080<br>OH<br>Powell,                                        |     |  | contact respecting this form. |          | Name and telephone number of person to                                                     |  |
|    |    |                                                                                          |                                                                                                |     |  | Todd                          | Crawford | 485-3108<br>(614)                                                                          |  |
| 2. |    |                                                                                          | A. General Assessment (item 2e from page 2)                                                    |     |  |                               | \$       | 263.94                                                                                     |  |
|    | B. | 9/1/2021                                                                                 | Less payment made with SIPC-6 filed (exclude interest)                                         |     |  |                               |          | 204.96                                                                                     |  |
|    |    | Date Paid                                                                                |                                                                                                |     |  |                               |          |                                                                                            |  |
|    | c. | Less prior overpayment applied                                                           |                                                                                                |     |  |                               |          | 0.00                                                                                       |  |
|    | D. |                                                                                          | Assessment balance due or ( overpayment )                                                      |     |  |                               |          | 0.00                                                                                       |  |
|    | E. |                                                                                          | l<br>91<br>Interest computed on late payment (see instruction E) for_<br>days at 20% per annum |     |  |                               |          | 0.68                                                                                       |  |
|    | F. | ^<br>Total assessment balance and interest due (or overpayment carried forward)          |                                                                                                |     |  | \$                            | 59.66    |                                                                                            |  |
|    | G. | PAYMENT:<br>V<br>the box<br>Check mailed to P.O. Box)<br>Total (must be same as F above) | i<br>1<br> <br>Funds Wired<br>AC                                                               |     |  |                               |          |                                                                                            |  |
|    | H. | Overpayment carried forward                                                              |                                                                                                | \$( |  |                               |          |                                                                                            |  |
|    |    | 3. Subsidiaries                                                                          | (S) and predecessors (P ) included in this form ( give name and 1934 Act registration number): |     |  |                               |          |                                                                                            |  |
|    |    |                                                                                          |                                                                                                |     |  |                               |          |                                                                                            |  |

| The SIPC member submitting this form and the                                          | Securities,                                                          |
|---------------------------------------------------------------------------------------|----------------------------------------------------------------------|
| person by whom it is executed represent thereby                                       | Capital                                                              |
| that all information contained herein is true,                                        | City                                                                 |
| correct                                                                               | LLC                                                                  |
| and complete.                                                                         | (Name of Corporation, Partnership or other organ                     |
| March<br>Dated the 22<br>22<br>, 2 0<br>day of                                        | ''<br>'<br>AtlhoriTicurei<br>nature)<br>*<br>—^<br>reside<br>(Title) |
|                                                                                       |                                                                      |
| This form and the assessment payment is due 60 days after the end of the fiscal year. | Retain the Working Copy of this form                                 |
| for a period of not less than 6 years, the                                            | latest 2 years in an easily accessible place.                        |

Calculations Documentation Forward Copy UJ 0

Exceptions:

**<33** Disposition of exceptions:

{25}------------------------------------------------

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

Amounts for the fiscal period beginning \_ 1/1/2021 and ending" 1201 \* 021

| tem No.<br>a.<br>Total revenue (FOCUS Line 12/Part IIA Line 9 ( Code 4030)                                                                                                                                                                                                                                                                                                                    | Eliminate cents<br>\$ 939,802 |
|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------|
| b. Additions:                                                                                                                                                                                                                                                                                                                                                                                 |                               |
| (1) Total revenues from the securities business of subsidiaries (except foreign subsidiaries) and<br>predecessors not included above.                                                                                                                                                                                                                                                         | 0                             |
| ( 2) Net loss from principal transactions in securities in trading accounts.                                                                                                                                                                                                                                                                                                                  | 0                             |
| (3) Net loss from principal transactions in commodities in trading accounts.                                                                                                                                                                                                                                                                                                                  | 0                             |
| ( 4) Interest and dividend expense deducted in determining item 2a.                                                                                                                                                                                                                                                                                                                           | 0                             |
| (5) Net loss from management of or participation in the underwriting or distribution of securities.                                                                                                                                                                                                                                                                                           | 0                             |
| (6) Expenses other than advertising, printing,<br>registration tees and legal fees deducted in determining net<br>profit from management of or participation in underwriting or distribution of securities.                                                                                                                                                                                   | 0                             |
| ( 7) Net loss from securities in investment accounts.                                                                                                                                                                                                                                                                                                                                         | 0                             |
| Total additions                                                                                                                                                                                                                                                                                                                                                                               | 0                             |
| Deductions:<br>( 1) Revenues from the distribution of shares of a registered open end investment company or unit<br>investment trust, from the sale of variable annuities, from the business of insurance, from<br>investment<br>advisory services rendered to registered investment companies or insurance company separate<br>accounts, and from transactions in security futures products. | 649,444                       |
| (2) Revenues from commodity transactions.                                                                                                                                                                                                                                                                                                                                                     | 0                             |
| (3) Commissions, floor brokerage and clearance paid to other SIPC members in connection with<br>securities transactions.                                                                                                                                                                                                                                                                      | 66,732                        |
| ( 4) Reimbursements for postage in connection with proxy solicitation.                                                                                                                                                                                                                                                                                                                        | 0                             |
| securities in investment accounts.<br>(5) Net gain from                                                                                                                                                                                                                                                                                                                                       | 0                             |
| (6) 100% of commissions and markups earned from transactions in (i)<br>certificates of deposit and<br>(ii) Treasury<br>bills, bankers acceptances or commercial paper that mature nine months or less<br>from issuance date.                                                                                                                                                                  | 0                             |
| (7) Direct expenses of printing advertising and legal fees incurred in connection with other revenue<br>related to the securities business (revenue defined by Section 16(9)(L) of the Act).                                                                                                                                                                                                  | 0                             |
| (8) Other revenue not related either directly or indirectly to the securities business.<br>(See Instruction C):                                                                                                                                                                                                                                                                               |                               |
|                                                                                                                                                                                                                                                                                                                                                                                               | 47,666                        |
| (Deductions in excess of \$100,000 require documentation)                                                                                                                                                                                                                                                                                                                                     |                               |
| (9) (i)<br>Total interest and dividend expense (FOCUS Line 22/PART IIA Line 13,<br>Code 4075 plus line 2b(4) above) but not in excess<br>of total interest and dividend income.<br>\$.                                                                                                                                                                                                        |                               |
| (ii)<br>40% of margin interest earned on customers securities<br>accounts (40% of FOCUS line 5, Code 3960).<br>\$.                                                                                                                                                                                                                                                                            |                               |
| Enter the greater of line (i)<br>or (ii)                                                                                                                                                                                                                                                                                                                                                      |                               |
| Total deductions                                                                                                                                                                                                                                                                                                                                                                              | 763,842<br>175,960            |
| SIPC Net Operating Revenues                                                                                                                                                                                                                                                                                                                                                                   | \$<br>,263.94                 |
| .0015<br>General Assessment @                                                                                                                                                                                                                                                                                                                                                                 |                               |

(to page 1, line 2. A.)


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