# CTL SECURITIES LLC X-17A-5 (2025-02-18) — Broker-dealer annual report

- Company: CTL SECURITIES LLC
- Form: X-17A-5
- Filed: 2025-02-18
- Period: 2024-12-31
- Accession: 0001435252-25-000003
- CIK: 1435252
- File #: 8-67900
- Type: Broker-dealer
- Material weakness: No
- Auditor: Goldman & Company, CPAs P.C.
- Auditor location: Marietta, GA
- Contact: Jeffrey Heller
- Phone: 973-669-4744
- Email: jphellercpa@comcast.net
- Signed by: Michael Kraus (President)

Original filing: https://www.sec.gov/Archives/edgar/data/1435252/000143525225000003/ctlaudit242.pdf

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|                                                                                                                                         | UNITED STATES<br>SECURITIES AND EXCHANGE COMMISSION<br>Washington, D.C. 20549                                                                                                                |                                                                                                                                                                                                                                                                                                                                                                                    | 0MB APPROVAL<br>0MB Number: 3235-0123<br>E~pires: Nov. 30, 2026<br>Estimated average burden<br>hours per response: 12 |  |  |
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|                                                                                                                                         | ANNUAL REPORTS                                                                                                                                                                               |                                                                                                                                                                                                                                                                                                                                                                                    | SEC FILE NUMBER                                                                                                       |  |  |
|                                                                                                                                         |                                                                                                                                                                                              | FORM X-17A-S                                                                                                                                                                                                                                                                                                                                                                       | 8-67900                                                                                                               |  |  |
|                                                                                                                                         |                                                                                                                                                                                              | PART Ill                                                                                                                                                                                                                                                                                                                                                                           |                                                                                                                       |  |  |
| FACING PAGE<br>Information Require Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934                 |                                                                                                                                                                                              |                                                                                                                                                                                                                                                                                                                                                                                    |                                                                                                                       |  |  |
| FILING FOR THE PERIOID BEGINNING                                                                                                        | O 1 /O 1124                                                                                                                                                                                  | AND ENDING _                                                                                                                                                                                                                                                                                                                                                                       | ___<br>1_<br>2<br>3_<br>1<br>_12<br>4<br>_1_<br>_<br>_                                                                |  |  |
|                                                                                                                                         |                                                                                                                                                                                              | MM/DD/YY                                                                                                                                                                                                                                                                                                                                                                           | MM/DD/YY                                                                                                              |  |  |
|                                                                                                                                         | I                                                                                                                                                                                            | A. REGISTRANT IDENTIFICATION                                                                                                                                                                                                                                                                                                                                                       |                                                                                                                       |  |  |
|                                                                                                                                         | NAME oF FIRM: CT~ Securities LLC                                                                                                                                                             |                                                                                                                                                                                                                                                                                                                                                                                    |                                                                                                                       |  |  |
| l:!J Broker-dealer                                                                                                                      | TYPE OF REGISTRANT check all applicable boxes):<br>D Security-based swap dealer<br>D Major security-based swap participant<br>D Check here if res po ,dent is also an OTC derivatives dealer |                                                                                                                                                                                                                                                                                                                                                                                    |                                                                                                                       |  |  |
|                                                                                                                                         | ADDRESS OF PRINCIPJ L PLACE OF BUSINESS: (Do not use a P.O. box no.)                                                                                                                         |                                                                                                                                                                                                                                                                                                                                                                                    |                                                                                                                       |  |  |
| 521 Fifth Ave., 17th Floor                                                                                                              |                                                                                                                                                                                              |                                                                                                                                                                                                                                                                                                                                                                                    |                                                                                                                       |  |  |
|                                                                                                                                         |                                                                                                                                                                                              | (No. and Street)                                                                                                                                                                                                                                                                                                                                                                   |                                                                                                                       |  |  |
| New York                                                                                                                                |                                                                                                                                                                                              | NY                                                                                                                                                                                                                                                                                                                                                                                 | '10175-1799                                                                                                           |  |  |
|                                                                                                                                         | (. ity)<br>PERSON TO CONTACT WITH REGARD TO THIS FILING                                                                                                                                      | (State)                                                                                                                                                                                                                                                                                                                                                                            | (Zip Code)                                                                                                            |  |  |
| {Name)                                                                                                                                  |                                                                                                                                                                                              | {Area Code -Telephone Number)                                                                                                                                                                                                                                                                                                                                                      | {Email Address)                                                                                                       |  |  |
|                                                                                                                                         |                                                                                                                                                                                              |                                                                                                                                                                                                                                                                                                                                                                                    |                                                                                                                       |  |  |
| B. ACCOUNTANT IDENTIFICATION<br>INDEPENDENT PUBLl3' CCOUNTANTwhose ,epo,ts a,e contained in this/Hing•<br>Goldman & Colmpany, CPAs P.C. |                                                                                                                                                                                              |                                                                                                                                                                                                                                                                                                                                                                                    |                                                                                                                       |  |  |
|                                                                                                                                         | I                                                                                                                                                                                            | {Name- if individual, state last, first, and middle name)                                                                                                                                                                                                                                                                                                                          |                                                                                                                       |  |  |
| 3535 Roswell r·• Ste 32                                                                                                                 |                                                                                                                                                                                              | Marietta                                                                                                                                                                                                                                                                                                                                                                           | GA<br>30062                                                                                                           |  |  |
| (Address)                                                                                                                               | (City)                                                                                                                                                                                       |                                                                                                                                                                                                                                                                                                                                                                                    | (State)<br>(Zip Code)                                                                                                 |  |  |
| T'                                                                                                                                      |                                                                                                                                                                                              |                                                                                                                                                                                                                                                                                                                                                                                    |                                                                                                                       |  |  |
|                                                                                                                                         | of Regist,ation with rOBllif appllc,ble) FOR OFFICIAL USE ONLY                                                                                                                               |                                                                                                                                                                                                                                                                                                                                                                                    | (PCAOB '"''"'""'" Nomb~. if applicable I I                                                                            |  |  |
| CFR 240.17a-S{e){l){ii), 1{ applicable.<br>do,plays a '"'"""' ,al/d r                                                                   | • ,onuol n,mbe,.                                                                                                                                                                             | • Claims for exemption fror the requirement that the annual reports be covered by the reports of an independent public<br>accountant must be supP,orted by a statement offacts and circumstances relied on as the basis of the exemption. See 17<br>Persons who are to respon~ to the collection of information contained In this form are not required to respond unless the form |                                                                                                                       |  |  |

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#### OATH OR AFFIRMATION

|       | I, Michael Kraus                                      | swear (or affirm) that, to the best of my knowledge and belief, the                                                         |  |  |
|-------|-------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------|--|--|
|       |                                                       | financial report pertaining tb the firm of CTL Securities<br>as of                                                          |  |  |
| 12/31 |                                                       | 2~<br>I<br>,<br>is true and correct. I further swear (or affirm) that neither the company nor any                           |  |  |
|       | partner, officer, director, or e                      | 1 uivalent person, as the case may be, has any proprietary interest in any account classified solely                        |  |  |
|       | as that of a customer.                                |                                                                                                                             |  |  |
|       |                                                       |                                                                                                                             |  |  |
|       |                                                       |                                                                                                                             |  |  |
|       | .\                                                    |                                                                                                                             |  |  |
|       |                                                       | Title:                                                                                                                      |  |  |
|       |                                                       |                                                                                                                             |  |  |
|       |                                                       | J-f ' y ) ?--s                                                                                                              |  |  |
|       | Notary Puhl(/                                         | I                                                                                                                           |  |  |
|       |                                                       | ~<br>~<br>-<br>RORY K MCGUINNESS<br>Notary Public, State of Connecticut                                                     |  |  |
|       | This filing** contains I check all applicable boxes): | My Commission Expires Mar. 31 , 2028                                                                                        |  |  |
| I!!   | (a) Statement of financial tlondition.                |                                                                                                                             |  |  |
|       |                                                       | D (b) Notes to consolidated ~tatement of financial condition.                                                               |  |  |
|       |                                                       | !!I (c) Statement of income (l<ilss) or, if there is other comprehensive income in the period(s) presented, a statement 0f  |  |  |
|       |                                                       | comprehensive income (a~ defined in§ 210.1-02 of Regulation S-X).                                                           |  |  |
|       | !!I (d) Statement of cash flowf.                      |                                                                                                                             |  |  |
|       |                                                       | !! (e) Statement of changes ir stockholders' or partners' or sole proprietor's equity.                                      |  |  |
|       |                                                       | D (f) Statement of changes i~ liabilities subordinated to claims of creditors.                                              |  |  |
|       | !!I (g) Notes to consolidated rynancial statements.   |                                                                                                                             |  |  |
|       | ii (h) Computation of net caP,ital under 17           | CFR 240.1Sc3-1 or 17 CFR 240.18a-1, as applicable.                                                                          |  |  |
| D     |                                                       | (i) Computation of tangibl~ net worth under 17 CFR 240.18a-2.                                                               |  |  |
|       |                                                       | !!I (j) Computation for deter°lination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3.         |  |  |
| D     |                                                       | (k) Computation for deterTination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.15c3-3 or |  |  |
|       | Exhibit A to 17 CFR 240.lSa-4, as applicable.         |                                                                                                                             |  |  |
|       |                                                       | D (I) Computation for Deterrhination of PAB Requirements under Exhibit A to § 240.15c3-3.                                   |  |  |
|       |                                                       | ~ (m) Information relating tb possession or control requirements for customers under 17 CFR 240.1Sc3-3.                     |  |  |
| D     |                                                       | (n) Information relating t~ possession or control requirements for security-based swap customers under 17 CFR               |  |  |
|       | 240.1Sc3-3(p)(2) or 17 CF1240.18a-4, as applicable.   |                                                                                                                             |  |  |
| D     |                                                       | (o) Reconciliations, includiTg appropriate explanations, of the FOCUS Report with computation of net capital ortanglble net |  |  |
|       |                                                       | worth under 17 CFR 240.lrc3-1, 17 CFR 240.lSa-1, or 17 CFR 240.lSa-2, as applicable, and the reserve requirements under 17  |  |  |
|       | CFR 240.1Sc3-3 or 17 CFR                              | 40.lSa-4, as applicable, if material differences exist, or a statement that no material differences                         |  |  |
|       | exist.                                                |                                                                                                                             |  |  |
| D     |                                                       | (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition.                    |  |  |
|       |                                                       | !!I (q) Oath or affirmation in iccordance with 17 CFR 240.17a-5, 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable.     |  |  |
|       |                                                       | D (r) Compliance report in accordance with 17 CFR 240.17a-S or 17 CFR 240.18a-7, as applicable.                             |  |  |
|       |                                                       | ~ (s) Exemption report in ac+rdance with 17 CFR 240.17a-5 or 17 CFR 240.lBa-7, as applicable.                               |  |  |

- **!!I** (t) Independent public acc0untant's report based on an examination of the statement of financial condition.
- iii! (u) Independent public accr,untant's report based on an examination of the financial report or financial statements under 17 CFR 240.l 7a-5, 17 CFR 240j18a-7, or 17 CFR 240.l 7a-12, as applicable.
- iii! (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 2f0.18a-7, as applicable.
- **!!I** (w) Independent public a~ountant's report based on a review of the exemption report under 17 CFR 240.17a-5 or 17 CFR 240.lBa-7, as applicab e.
- ~ (x) Supplemental reports o applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-le or 17 CFR 240.17a-12, as applicable.
- D (y) Report describing any aterial inadequacies found to exist or found to have existed since the date of the previous audit, or a statement that no materlal inadequacies exist, under 17 CFR 240.17a-12(k). D (z) Other: \_\_\_\_\_ ·1---- - ------- ------------------
- 

<sup>\*\*</sup>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.

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(A LIMITED LIABILITY COMPANY)

FINANCIAL STATEMENTS FOR THE YEAR ENDED DECEMBER 31, 2024 AND REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

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(A LIMITED LIABILITY COMPANY)

## **Table of Contents**

| Report of Independent Registered Public Accounting Firm       .                                                 |    |  |
|-----------------------------------------------------------------------------------------------------------------|----|--|
| Financial Statements                                                                                            |    |  |
| Statement of Financial Condition      .                                                                         | 2  |  |
| Statement of Operations        .                                                                                | 3  |  |
| Statement of Changes in Member's Equity       .                                                                 | 4  |  |
| Statement of Cash Flows  .                                                                                      | 5  |  |
| Notes to Financial Statements   .                                                                               | 6  |  |
| Supplementary Schedule I - Computation of Net Capital.                                                          | 9  |  |
| Supplementary Schedules II and Ill.       .                                                                     | 10 |  |
| Independent Accountant's Report on Exemption      .                                                             | 11 |  |
| Exemption Report                                                                                                | 12 |  |
| Independent Accountants' Report on Applying Agreed-Upon Procedures<br>Related to SIPC Assessment Reconciliation | 13 |  |
| SIPC General Assessment Reconciliation Form SIPC-7                                                              | 14 |  |

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## REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Member of CTL Securities, LLC

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

We have audited the accompanying statement of financial condition of CTL Securities, LLC as of December 31, 2024, the related statements of operations, changes in member's equity and cash flows fora <sup>2</sup>the year ended December 31, 2024 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 0 position of CTL Securities, LLC as of December 31, 2024, and the results of its operations and its cash U flows for the year then ended, in conformity with accounting principles generally accepted in the Uni tea » • States of America. **0** o,:j

#### **Basis for Opinion**

These financial statements are the responsibility of CTL Securities, LLC 's management. Our D[J responsibility is to express an opinion on CTL 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 the company in accordance with the U.S Federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion.

#### **Auditor's Report on Supplemental Information**

The Schedule's I- Computation of Net Capital Under SEC Rule 15c3-l, Schedule II-Computation for Determination of Reserve Requirements Pursuant to SEC Rule 15c3-3 (exemption) and Schedule III Information Relating to Possession or Control Requirements Pursuant to SEC Rule 15c3-3 (exemption) have been subjected to audit procedures performed in conjunction with the audit of CTL Securities, LLC 's financial statements. The supplemental information is the responsibility of CTL 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. §240.1 ?a-5. In our opinion, the schedule's I, 11. and III are fairly stated, in all material respects, in relation to the financial statements as a whole.

We have served as the Company's auditor since 2015.

Goldman & Company, CPA's, P.C. Marietta, Georgia February 13, 2025

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#### (A LIMITED LIABILITY COMPANY)

#### **STATEMENT** OF **FINANCIAL CONDITION**  DECEMBER **31, 2024**

#### **ASSETS**

| ASSETS:                   |     |         |
|---------------------------|-----|---------|
| Cash and cash equivalents | \$  | 97,897  |
| Accounts receivable       | \$  | 50,000  |
| Prepaid expenses          |     | 15,236  |
| TOTAL ASSETS              | I\$ | 163,133 |

## **LIABILITIES AND MEMBER'S EQUITY**

| LIABILITIES:<br>Accounts payable      | \$  | 4,650   |
|---------------------------------------|-----|---------|
| Total Liabilities                     | I\$ | 4,650   |
| MEMBER'S EQUITY                       |     | 158,483 |
| TOTAL LIABILITIES AND MEMBER'S EQUITY | I\$ | 163,133 |

The accompanying notes are an integral part of these financial statements. 2

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(A LIMITED LIABILITY COMPANY)

### **STATEMENT OF OPERATIONS FOR THE YEAR ENDED DECEMBER 31 2024** '

| REVENUE:<br>Commissions-Underwriting | \$<br>1,376,248 |
|--------------------------------------|-----------------|
| Total revenue                        | I<br>1,376,248  |
| OPERATING EXPENSES:                  |                 |
| Commissions                          | 1,135,000       |
| Consulting                           | 41,438          |
| Regulatory                           | 17,320          |
| Professional fees                    | 24,388          |
| Office expenses                      | 30,000          |
| Insurance                            | 1,786           |
| Other expenses                       | 836             |
| Total expenses                       | I<br>1,250,768  |
| NET INCOME                           | I\$<br>125,480  |

The accompanying notes are an integral part of these financial statements. 3

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(A LIMITED LIABILITY COMPANY)

| STATEMENT OF CHANGES IN MEMBER'S EQUITY<br>FOR THE YEAR ENDED DECEMBER 31, 2024 |     |         |
|---------------------------------------------------------------------------------|-----|---------|
| MEMBER'S EQUITY, JANUARY 1                                                      | \$  | 33,003  |
| Net income                                                                      |     | 125,480 |
| MEMBER'S EQUITY, DECEMBER 31                                                    | I\$ | 158,483 |
|                                                                                 |     |         |

The accompanying notes are an integral part of these financial statements. 4

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{A LIMITED LIABILITY COMPANY)

#### STATEMENT OF CASH FLOWS FOR THE YEAR ENDED DECEMBER 31, 2024

| OPERATING ACTIVITIES:                                                                |     |          |
|--------------------------------------------------------------------------------------|-----|----------|
| Net income                                                                           | \$  | 125,480  |
| Adjustments to reconcile net income to net cash<br>provided by operating activities: |     |          |
| Increase in prepaid filing fee                                                       |     | (366)    |
| Increase in accounts receivable                                                      |     | (50,000) |
| Net cash provided by operating activities                                            | I   | 75,114   |
| NET DECREASE IN CASH AND CASH EQUIVALENTS                                            | I   | 75,114   |
| CASH AND CASH EQUIVALENTS AT BEGINNING OF YEAR                                       |     | 22,783   |
| CASH AND CASH EQUIVALENTS AT END OF YEAR                                             | I\$ | 97,897   |
|                                                                                      |     |          |

The accompanying notes are an integral part or these financial statements. 5

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(A LIMITED LIABILITY COMPANY)

NOTES TO FINANCIAL STATEMENTS DECEMBER 31 , 2024

#### 1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

#### Organization and Nature of Business

CTL Securities. LLC (the Company) is a broker-dealer registered with the Securities and Exchange Commission (SEC) and a member of the Financial Industry Regulatory Authority, Inc. (FINRA). The Company is **a** Delaware single member limited liability company (LLC). with one class of membership.The Company is a wholly owned subsidiary of CTL Capital, LLC(the "Parent" and sole member). The Company operates from New York.

The Company places credit tenant loans, which are originated by CTL Capital, LLC, in private placement transactions to institutional investors.

Since the Company is a limited liability company, the member is not liable for the debts, obligations, or liabilities of the Company, whether arising in contract, tort or otherwise, unless the member has signed a specific guarantee.

#### Basis of Presentation

The Company maintains its books and records on the accrual basis of accounting for financial reporting purposes, which is in accordance with U.S. generally accepted accounting principles and is required by the SEC and FINRA.

#### Income Taxes

The Company is a limited liability company for income tax reporting purposes, and as such, is not subject to income tax. Accordingly, no provision for income taxes is provided in the financial statements.

The Company has adopted the provisions of FASB Accounting Standards Codification 740-10, Accounting for Uncertainty in Income Taxes. Under FASB 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 and the decision not to file a return. The Company has evaluated each of its **tax** positions and has determined that it has no uncertain tax positions for which a provision or liability for income taxes is necessary.

#### Estimates

The presentation of financial statements in conformity with U.S. generally accepted accounting principles requires management to make estimates and 6

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assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates.

#### Revenue Recognition

On January 1, 2018, the Company adopted ASU 2014-09 Revenue from Contracts with Customers, and all subsequent amendments to the ASU (collectively, "ASC 606"), which creates a single framework for recognizing revenue from contracts with customers that fall within its scope.

Revenue is recognized based on a consideration specified in a contract with a customer. The Company recognizes revenue when it satisfies a performance obligation by transferring control over goods or service to a customer. Services within the scope of ASC 606 include underwriting income on a best effort basis. If the securities for which the Company cannot obtain a purchase commitment it will not be purchased by the Company.

#### Concentrations

The Company maintains its cash in bank deposit accounts, which at times, may exceed federally insured limits. The Company has not experienced any losses in such accounts and believes it is not exposed to any significant credit risk for cash. The Company had one customer that represented approximately 69% of revenue.

#### **2. RELATED PARTY TRANSACTION AND CONCENTRATIONS**

For the year ended December 31, 2024, 91.3% of the Company's revenue was referred from its member, CTL Capital, LLC.

The Company shares certain administrative expenses and the cost of an annual industry conference with its member, CTL Capital, LLC. A portion of these costs is allocated to the Company. Allocated expenses during the year ended December 31, 2024 were \$30,000 and are reflected as office expenses on the accompanying Statement of Operations for the year ended December 31, 2024. The expense sharing agreement was last revised effective January 1 and November 1, 2023; its term is month to month.

#### **3. COMMITMENTS AND CONTINGENCIES**

The Company has evaluated commitments and contingencies in accordance with Accounting Standards Codification 450, Contingencies (ASC 450) and Accounting Standards Codification 440, Commitments (ASC 440). Management has determined that no significant commitments and contingencies exist as of December 31, 2024.

#### **4. NET CAPITAL REQUIREMENTS**

The Company is subject to the Securities and Exchange Commission Uniform Net Capital Rule (SEC Rule 15c3-1). which requires the maintenance of minimum net capital and requires that the ratio of aggregate indebtedness to net capital, both as defined, shall not exceed 15 to 1. At December 31, 2024, the Company had net capital of \$93,247 which was \$88,247 in excess of its required net capital of \$5,000. The Company's percentage of aggregate indebtedness to net capital was 4.99%.

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#### **5. SUBSEQUENT EVENTS**

The Company evaluated subsequent events through February 13, 2025, the date its financial statements were available to be issued. The Company did not identify any material subsequent events requiring adjustment to or disclosure in its financial statements.

#### **6. REVENUES FROM CONTRACTS WITH CUSTOMERS**

Commissions are determined on a case by case basis according to the terms negotiated by management and are recognized at the time the placement is completed and sold to investors, and the income is reasonably determinable, and the performance obligations are satisfied under the contracts with its customers. There was no accounts receivable as of December 31, 2023.

#### **7. CASH & CASH EQUIVALENTS**

Cash and cash equivalents includes cash and highly liquid instruments with original maturities of less than 90 days.

#### **8. NEW ACCOUNTING STANDARDS**

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

#### **9. SINGLE REPORTABLE SEGMENT**

The Company is engaged in a single line of business as a securities broker-dealer, which is comprised of several classes of services, including investment banking and investment advisory. The Company has identified its President 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 4), which is not a measure of profit and loss, to make operational decisions while maintaining capital adequacy, such as whether to reinvest profits or pay dividends. 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. The accounting policies used to measure the profit and loss of the are the same as those described in the summary of significant accounting policies. The Company derived 67% of its revenues from a single external customer in 2024.

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(A LIMITED LIABILITY COMPANY)

#### SCHEDULE I

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

| TOTAL MEMBER'S EQUITY QUALIFIED FOR NET                   | I\$         |
|-----------------------------------------------------------|-------------|
| CAPITAL                                                   | 158,483     |
| DEDUCTIONS AND/OR CHARGES:                                | (15,236)    |
| Non-allowable asset - prepaid filing fee                  | (50,000)    |
| Non-allowable asset - accounts receivable                 | 93,247      |
| NET CAPITAL                                               | I           |
| AGGREGATE INDEBTEDNESS                                    | 4,650       |
| Accounts payable                                          | I           |
| COMPUTATION OF BASIC NET CAPITAL REQUIREMENT -            | I           |
| Minimum net capital required                              | 5,000       |
| Excess net capital                                        | I<br>88,247 |
| Net Capital in excess of the greater of: 10% of aggregate | I\$         |
| indebtedness or 120% of minimum capital requirements.     | 87,247      |
| Percentage of aggregate indebtedness to net capital       | I<br>4.99%  |
|                                                           |             |

There is no material difference in the above computation and the Company's net capital as reported in the Company's Part IIA (unaudited) amended FOCUS report as of December 31 , 2024.

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(A LIMITED LIABILITY COMPANY)

#### DECEMBER 31, 2024

#### SCHEDULE II

#### COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION

The Company does not claim an exemption from SEA Rule 15c3-3, in reliance on footnote 74 to SEC Release 34-70073, and as discussed in Q&A 8 of the related FAQ issued by SEC staff. The Company does not (1) directly or indirectly receive, hold, or otherwise owe fudns or securities for or to customers, (2)does not carry accounts of or for customers and (3) does not carry PAB accounts.

#### SCHEDULE Ill

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

The Company does not claim an exemption from SEA Rule 15c3-3, in reliance on footnote 74 to SEC Release 34-70073, and as discussed in Q&A 8 of the relaled FAQ issued by SEC staff. The Company does not (1) directly or indirectly receive, hold. or otherwise owe fudns or securities for or to customers, (2)does not carry accounts of or for customers and (3) does not carry PAB accounts.

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# REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM Ct?

To CTL the Securities, Member of LLC

We have reviewed management's statements, included in the accompanying Rule 15c3-3 Z Exemption Report pursuant to SEC Rule 17a-5, in which (1) CTL Securities, LLC(the Company) did -< not claim an exemption under paragraph (k) of 17 C.F.R. §240.15c3-3, and (2) the Company is filing a.. this Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 **adoptingu**  amendments to 17 C.F.R. § 240.17a-5 because the Company limits its business activities 2 exclusively to include participating in distributions of securities (other than firm commitment 0 underwritings) in accordance with the requirements of paragraphs (a) or (b)(2) of Rule 15c2-4: u

In addition, the Company did not directly or indirectly receive, hold, or otherwise owe funds or > <sup>~</sup>securities for or to customers, other than money or other consideration received and promptly **0**  transmitted in compliance with paragraph {a) or (b){2) of Rule 15c2-4 and/or funds received and ~ promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company; did not carry accounts of or DfJ for customers; and did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception.

CTL 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 CTL Securities, 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 upon the Company's business activities contemplated by Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5, and related SEC Staff Frequently Asked Questions.

Goldman & Company, CPA's, P.C. Marietta, Georgia February 13, 2025

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## **CTL Securities LLC**

## CTL Securities LLC Exemption Report

CTL Securities, LLC (the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C.F.R. §240. I 7a-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)(I) and (4). To the best of its knowledge and belief, the Company states the following:- \_

(I) The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240. I 5c3-3, and

(2) The Company is filing this Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240. I 7a-5 because the Company limits .its business activities exclusively to: (I) patticipating in distributions of securities (other than firm commitment underwritings) in accordance with the requirements of paragraphs (a) or (b)(2) of Rule 15c2-4; and the Company (I) did not directly or indirectly receive, hold, or otherwise owe funds or securitjes 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 ,,vay basis where the funds are payable to the issuer or ~ts agent and not to the Company); (2) did not carry accounts of or for customers; and (3) did not carrv PAS accounts (as defined 'in• Rule l 5c3-3) throughout the most recent fiscal yea/

## CTL Securities LLC

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

Title: • President

Date: 1/7/2025

521 Fifth Ave 17'" Floor New York, NY 10110

Tel: (212) 792-7884 Fax: (732) 224-1 348

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## REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM ON APPL YING AGREED-UPON PROCEDURES

CTL To the Securities, Member of LLC

We have performed the procedures included in Rule 17a-5(e)(4) under the Securities Exchange Act of 1934 Z and in the Securities Investor Protection Corporation (SIPC) Series 600 Rules, which are enumerated below < on the accompanying General Assessment Reconciliation **(Amended** Form SIPC-7) for the year ended 0.. December 31, 2024. Management of CTL Securities, LLC (the Company) is responsible for its **Amended u** <sup>~</sup>Form SIPC-7 and for its compliance with the applicable instructions on Form SIPC-7. <sup>O</sup>

Management of the Company has agreed to and acknowledged that the procedures performed are appropriate U to meet the intended purpose of assisting you and SIPC in evaluating the Company's compliance with the ; <sup>~</sup> applicable instructions on Form SIPC-7 for the year ended December 31, 2024. Additionally, SIPC has **0**  agreed to and acknowledged that the procedures performed are appropriate for their intended purpose. This report may not be suitable for any other purpose. The procedures performed may not address all the items of oc:1 interest to a user of this report and may not meet the needs of all users of this report and, as such, users are responsible for determining whether the procedures performed are appropriate for their purposes. The '00 sufficiency of these procedures is solely the responsibility of those parties specified in this report. Consequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose. The procedures we performed and our associated findings are as follows:

- l) Compared the listed assessment payments in its Amended Form SIPC-7 with respective cash disbursement records entries, noting no differences;
- 2) Compared the Total Revenue amounts reported on the Annual Audited Report Form X-17 A-5 Part III for the year ended December 31, 2024 with the Total Revenue amount reported in its Amended Form SIPC-7 for the year ended December 31, 2024, noting no differences;
- 3) Compared any adjustments reported in its Amended Form SIPC-7 with supporting schedules and working papers, noting no differences;
- 4) Recalculated the arithmetical accuracy of the calculations reflected in its Amended Form SIPC-7 and in the related schedules and working papers supporting the adjustments, noting no differences; and
- 5) Compared the amount of any overpayment applied to the current assessment with the amended Form SIPC-7 on which it was originally computed, noting no differences.

We were engaged by the Company to perform this agreed-upon procedures engagement and conducted our engagement in accordance with attestation standards established by the AICPA and in accordance with the standards of the Public Company Accounting Oversight Board (United States). We were not engaged to and did not conduct an examination or a review engagement, the objective of which would be the expression ofan opinion or conclusion, respectively, on the Company's Form amended SIPC-7 and for its compliance with the applicable instructions on Form SIPC-7 for the year ended December 31, 2024. Accordingly, we do not express such an opinion or conclusion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you.

We are required to be independent of the Company and to meet our other ethical responsibilities in accordance with the relevant ethical requirements related to our agreed-upon procedures engagement.

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

*JI LI.-J'f-{o'o/' J C//1* .r ~ (\_\_

Goldman & Company, CPA's, P.C. Marietta, Georgia February 13, 2025

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## SECURITIES INVESTOR PROTECTION CORPORATION

SIPC-7A 37 REV0722

## **AMENDED GENERAL ASSESSMENT FORM**

For the fiscal year ended 12/31/2024

|        | Determination of "SIPC NET Operating Revenues" and General Assessment for:<br>MEMBER NAME<br>SEC No.<br>CTL SECURITIES LLC<br>8-67900                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                            |
|--------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------|
|        | __ and ending<br>For the fiscal period beginning __<br>12/31/2024<br>1_/_1 /_2_02_4                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |                            |
| 1<br>2 | Total Revenue (FOCUS Report-<br>Statement of Income (Loss) -<br>Code 4030)<br>Additions:                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | \$ 1,376,248.00            |
|        | a Total revenues from the securities business of subsidiaries (except foreign<br>subsidiaries) and predecessors not included above.<br>b Net loss from principal transactions in securities in trading accounts.<br>c Net loss from principal transactions in commodities in trading accounts.<br>d Interest and dividend expense deducted in determining item 1.<br>e Net loss from management of or participation in the underwriting or<br>distribution of securities.<br>f Expenses other than advertising, printing, registration fees and legal fees<br>deducted in determining net profit management of or participation in<br>underwriting or distribution of securities.<br>g Net loss from securities in investment accounts.<br>h Add lines 2a through 2g. This is your total additions.                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | \$ 0.00                    |
| 3      | Add lines 1 and 2h                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | \$ 1,376,248.00            |
| 4      | Deductions:<br>a Revenues from the distribution of shares of a registered open end investment<br>company or unit investment trust, from the sale of variable annuities, from the<br>business of insurance, from investment advisory services rendered to<br>registered investment companies or insurance company separate accounts<br>and from transactions in security futures products.<br>b Revenues from commodity transactions.<br>c Commissions, floor brokerage and clearance paid to other SIPC members<br>in connection with securities transactions.<br>d Reimbursements for postage in connection with proxy solicitations.<br>e Net gain from securities in investment accounts.<br>f 100% commissions and markups earned from transactions in (I) certificates<br>of deposit and (ii) Treasury bills, bankers acceptances or commercial paper<br>that mature nine months or less from issuance date.<br>g Direct expenses of printing, advertising, and legal fees incurred in connection<br>with other revenue related to the securities business (revenue defined by<br>Section 16(9)(L) of the Act).<br>h Other revenue not related either directly or indirectly to the securities business.<br>Deductions in excess of\$100,000 require documentation |                            |
| 5      | a Total interest and dividend expense (FOCUS Report -<br>Statement<br>of Income (Loss) -<br>Code 4075 plus line 2d above) but<br>not in excess of total interest and dividend income<br>b 40% of margin interest earned on customers securities accounts                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                            |
|        | (40% of FOCUS Report -<br>Statement of Income (Loss) -<br>Code 3960)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | \$ 0.00                    |
|        | c Enter the greater of line Sa or Sb                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |                            |
| 6<br>7 | Add lines 4a through 4h and 5c. This is your total deductions.<br>Subtract line 6 from line 3. This is your SIPC Net Operating Revenues.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | \$ 0.00<br>\$ 1,376,248.00 |

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## SECURITIES INVESTOR PROTECTION CORPORATION

SIPC-7A 37 REV0722

## **AMENDED GENERAL ASSESSMENT FORM**

For the fiscal year ended 12/31/2024

| 8                    |                         |                                 | Multiply line 7 by .0015. This is your General Assessment.                                                                                                                                                                                                    |                                                              |              | \$2,064.00 |
|----------------------|-------------------------|---------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------|--------------|------------|
| 9                    |                         |                                 | Current overpayment/credit balance, if any                                                                                                                                                                                                                    |                                                              |              | \$ 0.00    |
| 10                   |                         |                                 | General assessment from last filed 2024 SIPC-7 or 7 A                                                                                                                                                                                                         |                                                              | \$1,989.00   |            |
|                      |                         | f Add lines 11a through 11e     | 11 a Overpayment(s) applied on all 2024 SIPC-6 and 6A(s)<br>b Overpayment(s) applied on all 2024 SIPC-7 and 7A(s)<br>c Any other overpayments applied<br>d All payments applied for 2024 SIPC-6 and 6A(s)<br>e All payments applied for 2024 SIPC-7 and 7A(s) | \$ 0.00<br>\$ 0.00<br>\$ 0.00<br>\$ 223.00<br>\$1<br>,766.00 | \$1,989.00   |            |
| 12                   |                         | LESSER of line 10 or 11f.       |                                                                                                                                                                                                                                                               |                                                              |              | \$1,989.00 |
|                      | 13 a Amount from line 8 |                                 |                                                                                                                                                                                                                                                               |                                                              | \$2,064.00   |            |
| b Amount from line 9 |                         |                                 |                                                                                                                                                                                                                                                               | \$ 0.00                                                      |              |            |
|                      |                         | c Amountfrom line 12            |                                                                                                                                                                                                                                                               |                                                              | \$1,989.00   |            |
|                      |                         |                                 | d Subtract lines 13b and 13c from 13a. This is your assessment balance due.                                                                                                                                                                                   |                                                              |              | \$ 75.00   |
| 14                   |                         | Interest (see instructions) for | O<br>days late at 20% per annum                                                                                                                                                                                                                               |                                                              |              | \$ 0.00    |
| 15                   |                         |                                 | !Amount you owe SIPC.Add lines 13d and 14.                                                                                                                                                                                                                    |                                                              |              | \$ 75.0~   |
| 16                   |                         |                                 | Overpayment/credit carried forward (if applicable)                                                                                                                                                                                                            |                                                              |              | \$ 0.00    |
|                      | SEC No.<br>8-67900      |                                 | Designated Examining Authority<br>DEA: FINRA                                                                                                                                                                                                                  | FYE<br>2024                                                  | Month<br>Dec |            |
|                      |                         | MEMBER NAME<br>MAILING ADDRESS  | CTL SECURITIES LLC<br>521 FIFTH AVE 17TH FLR<br>NEW YORK, NY 10175-1799<br>UNITED STATES                                                                                                                                                                      |                                                              |              |            |

Subsidiaries (S) and predecessors (P) included in the form (give name and SEC number)

[Z] By checking this box, you certify that you have the authority of the SIPC member to sign this form; that all information in this form is true and complete; and that on behalf of the SIPC member, you are authorized, and do hereby consent, to the storage and handling by SIPC of the data in accordance with SIPC's Privacy Policy

| CTL SECURITIES LLC    | Jeffrey Heller          |
|-----------------------|-------------------------|
| (Name of SIPC Member) | (Authorized Signatory)  |
| 2/5/2025              | jphellercpa@comcast.net |
| (Date)                | (e-mail address)        |

Completion of the "Authorized Signatory" line will be deemed a signature.

**This form and the assessment payment are due 60 days after the end of the fiscal year.**


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