# CHURCHILL STATESIDE SECURITIES, LLC X-17A-5 (2021-03-01) — Broker-dealer annual report - Company: CHURCHILL STATESIDE SECURITIES, LLC - Form: X-17A-5 - Filed: 2021-03-01 - Period: 2020-12-31 - Accession: 0001496738-21-000005 - CIK: 1496738 - File #: 8-68652 - Material weakness: No - Auditor: GOLDMAN AND COMPANY, CPAS, P.C. - Auditor location: MARIETTA, GA - Contact: WILLIAM J. MICHALAK - Phone: 404-250-4190 - Signed by: WILLIAM J. MICHALAK (CCO) Original filing: https://www.sec.gov/Archives/edgar/data/1496738/000149673821000005/css2020audit.pdf --- {0}------------------------------------------------ UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 ANNUAL AUDITED REPORT FORM X-17A-5 PARTIII OMB APPROVAL OMB Number: 3235-0123 Expires: October 31, 2023 Estimated average burden hours per resoonse ...... 12.00 SEC FILE NUMBER 8- FACING PAGE Information Required of Brokers and Dealers Pursuant to Section 17 of the Securities Exchange Act of 1934 and Rule 17a-5 Thereunder REPORT FOR THE PERIOD BEGINNING 01/01/2020 AND ENDING 12/31/2020 MM/DD/YY A. REGISTRANT IDENTIFICATION NAME or BROKER-DEALER: Churchill Stateside Securities, LLC ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.) 2325 Lakeview Pkwy, STE 225 (No. and Street) MM/DD/YY OFFICIAL USE ONLY FIRM 1.0. NO. 30009 (City) (State} (Zip Code) NAME AND TELEPHONE NUMBER OF PERSON TO CONT ACT IN REGARD TO THIS REPORT (Arca Code - Telephone Number) B. ACCOUNT ANT IDENTIFICATION INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report" golman and Company, CPAs, P .C. (Name - *if individual. state Iast. first, middle name)* 3535 Roswell Rd., #32 (Address) Marietta (City) GA 30062 (State) (Zip Code) CHECK ONE: jll'jcertified Public Accountant B Public Accountant Accountant not resident in United States or any of its possessions. FOR OFFICIAL USE ONLY *"Claims for exemption from the requirement that the annual report be covered by the opinion of an independent public accountant must be supported by a statement of facts and circumstances relied on as the basis for the exemption. See Section 240.l 7a-5(e)(l)* > Potential persons who are to respond to the collectlon of Information contained In this form are not required to respond unless the form displays a currently valid OMB control number. SEC 1410 (11-05) {1}------------------------------------------------ # OATH OR AFFIRMATION | William J. Michalak | , swear (or affirm) that, to the best of | |-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------| | my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of
Churchill Stateside Securities, LLC | | | of Churchill Stateside Securities, LLC
2020 are true and correct. I further swear (or affirm) that | | | neither the company nor any partner, principal officer or director has any proprietary interest in any account | | | classified solely as that of a customer, except as follows: | | | | | | | | | | | | | | | | | | | | | rgnature | | | | | | Title | | | | | | Notary Public | | | 2020-2021 | | | This report ** contains (check all applicable boxes): | | | (a) Facing Page.
(b) Statement of Financial Condition. | | | Annummannu
(c) Statement of Income (Loss) or, if there is other comprehensive income in the period(s) presented, a Statement | | | of Comprehensive Income (as defined in §210.1-02 of Regulation S-X). | | | (d) Statement of Changes in Financial Condition. | | | (e) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors' Capital.
(f) Statement of Changes in Liabilities Subordinated to Claims of Creditors. | | | (g) Computation of Net Capital. | | | (h) Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3. | | | (i) Information Relating to the Possession or Control Requirements Under Rule 15c3-3. | | | (i) A Reconciliation, including appropriate explanation of Net Capital Under Rule 15c3-1 and the
Computation for Determination of the Reserve Requirements Under Exhibit A of Rule 15c3-3. | | | (k) A Reconciliation between the audited Statements of Financial Condition with respect to methods of | | | consolidation. | | | (I) An Oath or Affirmation. | | | (m) A copy of the SIPC Supplemental Report.
(1) A report describing any material inadequacies found to exist or found to have existed since the date of the previous audit. | | | | | | ** For conditions of confidential treatment of certain portions of this filing, see section 240.17a-5(e)(3). | | {2}------------------------------------------------ FINA N CIAL S T A T E M E N TS F OR T HE YEAR E N D ED D E C E M B ER 31, 2 0 20 A ND R E P O RT OF IN D E P E N D E NT R E GIS T E R ED P U BLIC A C C O U N TING FIRM {3}------------------------------------------------ # **CHURCHILL STATESIDE SECURITIES, LLC** (A LIMITED LIABILITY COMPANY) | f
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rm | 16 | {4}------------------------------------------------ #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM #### To the Members of Churchill Stateside Securities LLC E>- Opinion on the Financial Statements Z We have audited the accompanying statement of financial condition of Churchill Stateside Securities LLC as < of December 31, 2020, the related statements of operations, changes in member's equity and cash flows for the 0.... year then ended and the related notes and schedules i, 2 and 3 (collectively referred to as the "financialu � statements"). In our opinion, the financial statements present fairly, in all material respects, the financial O position of Churchill Stateside Securities LLC as of December 31, 2020, and the results of its operations and #### Basis for Opinion its cash flows for the year then ended in conformity with accounting principles generally accepted in the � UUnited States of America. *P*o� ufJ These financial statements are the responsibility of Churchill Stateside Securities LLC 's management. Our responsibility is to express an opinion on Churchill Stateside 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 I 5c3- l, Schedule 2-Computation for Determination of Reserve Requirements Pursuant to SEC Rule 15c3-3 (exemption) and Schedule 3 lnformation 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 Churchill Stateside Securities LLC's financial statements. The supplemental information is the responsibility of Churchill Stateside 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 schedule's 1, 2. and 3 are fairly stated, in all material respects, in relation to the financial statements as a whole. We have served as the Company's auditor since 20 I 5. Goldman & Company, CPA's, P.C. Marietta, Georgia February 28, 2021 {5}------------------------------------------------ # STATEMENT OF FINANCIAL CONDITION DECEMBER 31, 2020 # ASSETS | C
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29 | | | | | {9}------------------------------------------------ ### NOTES TO FINANCIAL STATEMENTS DECEMBER 31, 2020 #### 1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES #### Organization and Nature of Business Churchill Stateside Securities, LLC, a Georgia limited liability company (the "Company"), is registered as a broker-dealer with the Securities and Exchange Commission (the "SEC") and is a member of the Financial Industry Regulatory Authority, Inc. ("FINRA"). The Company received its approval for membership on January 28, 2011. The Company received approval as a Municipal Advisor from the SEC on October 30 2018. The Company primarily engages in the private placement of syndicated tax credits to accredited investors. Additionally, the Company underwrites Tax-Exempt Bond issues. The tax credits are syndicated by Churchill Stateside Group, LLC ("CSG"), who owns the Company along with Stateside Capital, LLC f'SC"). CSG owns Churchill Mortgage Investment LLC ("CMI''). CMI is the mortgage lender on some transactions where the Company is the Bond Underwriter or Municipal Advisor. Since the Company Is a limited liability company, the members are not liable for the debts, obligations, or liabilities of the Company, whether arising in contract, tort or otherwise, unless the members have signed a specific guarantee. Basis of Accounting 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. Estimates The presentation of financial statements in conformity with U.S. generally accepted accounting principles requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates. Cash and Cash Equivalents The Company defines cash equivalents as highly liquid investments with original maturities of less than ninety days that are not held for sale in the ordinary course of business. #### Income Taxes The Company is an LLC taxed as a partnership 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. {10}------------------------------------------------ #### 1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES - continued The Company has adopted the provisions of FASB Accounting Standards Codification 740-10, Accounting for Uncertainty in Income Taxes. Under FASB ASC 740-10, 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. 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. Leases The Company recognizes and measures its leases in accordance with FASB ASC 842, *Leases .* The Company is a lessee in a noncancellable operating leases, for office space, The Company determines if an arrangement is a lease, or contains a lease, at inception of a contract and when the terms of an existing contract are changed. The Company recognizes a lease liability and a right of use (ROU) asset at the commencement date of the lease. The lease liability is initially and subsequently recognized as the present value of its future lease payments. The discount rate used for the present value is the implicit rate if it is readily determinable or otherwise the Company uses its incremental borrowing rate. The implicit rates of our leases are not readily determinable and accordingly, we use our incremental borrowing rate based on the information available at the commencement date for all leases. The Company's incremental borrowing rate for a lease is the rate of rate of interest it would have to pay on a collateralized basis to borrow an amount equal to the lease payments under similar terms and in a similar economic environment. The ROU asset is subsequently measured throughout the lease term at the amount of the remeasured lease liability (i.e., present value of the remaining lease payments), plus unamortized initial direct costs, plus (minus) any prepaid (accrued) lease payments, less the unamortized balance of lease incentives received, and any impairment recognized. Lease cost for lease payments is recognized on a straight-line basis over the lease term. The Company has elected, for all underlying classes of assets, to not recognize ROU assets and lease liabilities for short-term leases that have a lease term of 12 months or less at lease commencement, and do not include an option to purchase the underlying asset that the Company is reasonably certain to exercise. We recognize lease cost associated with our short-term leases on a straight-line basis over the lease term. Other information related to leases as of December 31, 2020: The average discount rate is the assumed marginal borrowing rate of 5% and the weighted average remaining lease term for operating leases is 9 months. 7 {11}------------------------------------------------ ### 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") using the modified retrospective method of adoption. ASC 606 created a single framework for recognizing revenue from contracts with customers that falls within its scope. Under ASC 606, revenue is recognized upon satisfaction of performance obligations by transferring control of goods or services to a customer. The adoption of ASC 606 did not result in any changes to beginning retained earnings for the year ended December 31, 2020 or net income for the preceding year-end. Services within the scope of ASU 606 include: a: Investment Brokerage b: Underwriting Income Investment Banking, Merger and Acquisition (M&A) Services: These services include agreements to provide advisory services to customers for which they charge the customers fees. The Company provides advisory services/corporate finance activity including mergers and acquisitions, reorganizations, tender offers, leveraged buyouts, fundraising activity and the pricing of securities to be issued. The agreement contains nonrefundable retainer fees or success fees, which may be fixed or represent a percentage of value that the customer receives if and when the corporate finance activity is completed ("success fees"). In some cases, there is also an "announcement fee" that is calculated on the date that a transaction is announced based on the price included in the underlying sale agreement. The retainer fees, announcement fee, or other milestone fees reduce any success fee subsequently invoiced and received upon the completion of the corporate finance activity. The Company has evaluated its nonrefundable retainer payments, to ensure its fee relates to the transfer of a good or service, as a distinct performance obligation, in exchange for the retainer. If a promised good or service is not distinct, the Company combines that good or service with other promised goods or services until it identifies a bundle of goods or services that is distinct. In some cases, that would result in the broker-dealer accounting for all the services promised in a contract as a single performance obligation and the retainer revenue is classified as deferred revenue on the Statement of Financial Condition. There was no deferred revenue as of December 31, 2020. #### Concentration of Credit Risk 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. All of the Company's private placement of investments to accredited investors are of syndicated credits that are 100% generated by CSG. All of the Company's bond underwriting has been on transactions where CMI has been the lender and CMI holds the primary relationship with the sponsor. Therefore, all of the Company's revenues are on transactions where CSG or CM! have generated an underlying transaction. #### New Accounting Standards The Company is monitoring and evaluating new accounting standards and will implement all applicable standards as required. {12}------------------------------------------------ ### 2. NET CAPITAL REQUIREMENTS The Company is subject to the SEC 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, 2020, the Company had net capital of \$846, 196 which was \$746,196 in excess of its required net capital of \$100,000. The Company's percentage of aggregate indebtedness to net capital was 61%. #### 3. RELATED PARTY TRANSACTIONS The Company has an expense sharing agreement with CSG, a related party, for operating expenses and management services. All of the Company's revenues for the year ended December 31, 2020 were earned from the sale of financial products developed by CSG. The amount paid to CSG for management services is \$114,600 for 2020. this is recorded in professional fees on the statement of operations. The Company was allocated \$38, 136 for operating expense costs by CSG in 2020, these expenses are recorded in their respective categories on the Statement of Operations. The Company had financing transactions with CSG the Company lending \$268,664, net of the amounts charged to the Company under the Expense Sharing Agreement, to CSG in 2020. CSG owes the Company \$634,910 as of December 31, 2020. ### 4. COMMITMENTS AND CONTINGENCIES The Company has entered into a lease that contains free rent periods or periods in which rent is abated. The total amount of rent expense is being charged to rent expense on the straight line method over the term of the lease. The diferrence between rent expense and rent paid is credited as Deferred Rent Obligations on the Statement of Financial Condition. The future rent obligation is: | 20
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.7 | | | | | There are no material differences in the above capital calculation and the companies calculation of net capital as reflected on the unaudited amended form 17a-5, part IIA. {15}------------------------------------------------ # CHURCHILL STATESIDE SECURITIES, LLC (A LIMITED LIABILITY COMPANY) DECEMBER 31, 2020 ### SCHEDULE II # COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS UNDER RULE 15c3·3 OF THE SECURITIES AND EXCHANGE COMMISSION The Company is exempt from the provisions of Rule 15c3-3 under the Securities Exchange Act of 1934 pursuant to paragraph (k)(2)(i) and (k)(2)(ii) of the rule. SCHEDULE Ill # INFORMATION RELATING TO THE POSSESSION OR CONTROL REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION The Company is exempt from the provisions of Rule 15c3-3 under the Securities Exchange Act of 1934 pursuant to paragraph (k)(2)(i) and (k)(2)(ii) of the rule. {16}------------------------------------------------ ### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Members of E · Churchill Stateside Securities, LLC >- We have reviewed management's statements, included in the accompanying Churchill Stateside � Securities, LLC' s Annual Exemption Report, in which ( l) Churchill Stateside Securities, LLC identified the following provisions of 17 C.F.R. § l 5c3-3(k) under which Churchill Stateside c, Securities, LLC claimed an exemption from 17 C.F.R. §240.15c3-3: (kX2Xi) and (ii) (theu � "exemption provisions") and (2) Churchill Stateside Securities, LLC stated that Churchill Stateside O Securities, LLC met the identified exemption provisions throughout the most recent fiscal year u without exception. Churchill Stateside Securities, LLC's management is responsible for compliance; IC with the exemption provisions and its statements. Our review was conducted in accordance with the standards of the Public Company Accounting 0 � Oversight Board (United States) and, accordingly, included inquiries and other required procedures to obtain evidence about Churchill Stateside Securities, LLC's compliance with the exemption provisions. A review is substantially Jess in scope than an examination, the objective of which is the DD · 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)(2Xi) and (ii) of Rule l 5c3-3 under the Securities Exchange Act of 1934. Goldman & Company, CPA's, P.C. Marietta, Georgia February 28, 2021 3535 Roswell Road · Suile 32 · Marietta. GA 30062 · 770.499.8558 · Fax 770.4,25.3683 {17}------------------------------------------------ ![](_page_17_Picture_0.jpeg) #### EXEMPTION REPORT #### YEAR ENDED DECEMBER 31, 2020 Churchill Stateside 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 §240.17a-5. "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R §240.17a-5(d)(1) and (4). To the best of Its knowledge and belief, the Company states the fallowing: 1. The Company claimed an exemption from 17 C F.R §15c3-3 under the following provisions of 17 C.F.R §240.15c3-3: (k){2)(1) and 17 C.F� §240.15c3-3: (k)(2)(11), and: 2. The Company met the identified exemption provisions In 17 C.F .R §240.15c3-3 (k)(2XI) and 17 C.F.R §240.15c3-3: (k){2)(1i) throughout the most recent fiscal year ended December 31, 2020 without exception. I affirm that, to the best of my knowledge and belief, this Exemption Report Is true and correct. By: Trtle: CEO, CCO Date:. \_---"r\_,\_/\_;2\_.,,,.... t, /\_)\_tJ.......\_�...\_\_J \_ � *)* {18}------------------------------------------------ ### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM ON APPL YING AGREED-UPON PROCEDURES ### To the Members of Churchill Stateside Securities LLC We have performed the procedures included in Rule 17a-5(eX4) under the Securities Exchange Act :;E of 1934 and in the Securities Investor Protection Corporation (SIPC) Series 600 Rules, which are o enumerated below and were agreed to by Churchill Stateside Securities LLC and the SIPC, solely U • rd to assist you and SIPC in evaluating Churchill Stateside Securities LLC's compliance with the •-• -•'11111 applicable instructions of the General Assessment Reconciliation (Fonn SIPC-7) for the year ended *0--J* December 31, 2020. Churchill Stateside 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 O A v m e e rs ri i can ght B In o s a ti r t d ute (U o n f it C ed ert S ifi ta e t d es) Pu a b n li d c in Ac a c c o c u o n rd tan an ts ce . Th wit e h su att ffi e c sta ie t n io cy n o st f a t n h d e a s r e ds pr e oc st e ab du li r s e h s ed is b s y ole th ly eDfJ 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: - I) Compared the listed assessment payments in 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-17A-5 Part Ill for the year ended December 31, 2020 with the Total Revenue amount reported in Form SIPC-7 for the year ended December 31, 2020, noting no differences; - 3) Compared any adjustments reported in Form SIPC-7 with supporting schedules and working papers, noting no differences; - 4) 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 - 5) 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. 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 Churchill Stateside Securities LLC's compliance with the applicable instructions of the Form SIPC-7 for the year ended December 31, 2020. 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 Churchill Stateside Securities LLC and the SIPC and is not intended to be and should not be used by anyone other than these specified parties. JL/...vr�J*C/.lf',;ic.\_\_* Goldman & Company, CPA's, P.C. Marietta, Georgia February 28, 2021 3535 Roswell Road · Suite 32 · Marietta, GA 30062 · 770.499.8558 · Fax 770.425.3683 {19}------------------------------------------------ | SIPC-7 | SECURITIES INVESTOR PROTECTION CORPORATION | P.O. Box 92185 Washington, D.C. 20090-2185 | | SIPE | |----------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------| | 202-371-8300
General Assessment Reconciliation
(36-REV 12/18) | | | | (36-REV 12/18) | | | (Read carelully the instructions in your Working Copy before completing this Form)
TO BE FILED BY ALL SIPC MEMBERS WITH FISCAL YEAR ENDINGS
1. Name of Membar, address, Designated Examining Authority, 1934 Act registration no. and month in which liscal year ends for
purposes of the audit requirement of SEC Rule 17a-5: | For the fiscal year ended 12/31/2020 | | | | Churchill Stateside Securities LLC
2325 Lakeview Pkwy Ste 225
Alpharetta GA 30009-7945 | | | Nole: If any of the information shown on the
mailing label requires correction, please e-mail
any corrections to form@sipc.org and so
indicate on the form filed. | 1
0
Co
1
n | | SEC# 8-68652 CRD# 154603 | | Name and telephone number of person lo
contact respecting this form. | OB | | | | | | William Crapps 404-579-0747 = | | | | | | | | | | 2. A. General Assessment (item 2e from page 2) | | 3318 | | | | B. Less payment made with SIPC-6 liled (exclude Interest) | | 2526 | | | | Dale Paid | | | | | | C. Lass prior overpayment applied | | | | | | D. Assessment balance due or (overpayment) | | | | | | E. Interest computed on late payment (see instruction E) lor__________________________________________________________________________________________________________________ | | | | | | F. Total assossment balance and interest due (or overpayment carried lorward) | | 2792 | | | | G. PAYMENT: V the box
Check mailed to P.O. Box Funds Wired __
Total (must be same as F above) | ACH I | | | | | H. Overpayment carried forward | ਡ ( | | | | | 3. Subsidiaries (S) and prodecessors (P) included in this lorm (give name and 1934 Act registration number): | | | | | | | | | | | and complete. | The SIPC member submilting this lorm and the
person by whom it is executed represent thereby
that all information conlained herein is true, correct | CHURCHILLE | JTPTESIDE DECARITIES
(Name of Corporation Partership or Sthes cigania al maj | | Dated the 26 day of Fabruary , 20 21 . | CHURCHILL JTATESIDE DECORDITIES | | |-----------------------------------------------------------|--| | ( Name of Colbor sitos Partes ship or ather croany at a a | | | | | | (Aulho 12ed Signalura) | | | | | | 17 11:01 | | This form and the assessment payment is due 60 days after the end of the Ilscal year. Relain the Working Copy of this form lor a period of not less than 6 years, the latest 2 years in an easily accessible place. | | The Postmark
Postmarked | Received | Reviewed | | |--|-------------------------------|----------|------------------|--------------| | | | | Documentation __ | Forward Copy | | | | | | | | | on Disposition of exceptions: | | | | | | | | | | {20}------------------------------------------------ ## DETERMINATION OF "SIPC NET OPERATING REVENUES" AND GENERAL ASSESSMENT Amounts for the fiscal period | | peginning virus220
and ending 12/31/2020 | |----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------| | llem No.
2a. Total revenue (FOCUS Line 12 Part IIA Line 9, Code 4030) | Eliminate cents
s3546233 | | 2b. Additions
(1) Total revenues from the securities business of subsidiaries (except foreign subsidiaries) and
predecessors not included abova. | | | (2) Nel loss from principal transactions in securities in trading accounts. | | | (3) Nel loss from principal transactions in commodities in trading accounts. | | | (4) Interest and dividend expense deducted in delermining item 2a. | | | (5) Net loss from management of or participation in the underwriting or distribution of securities. | | | (6) Expenses other than advertising, printing, registration fees deducted in determining net
profit from management of or participation in underwrilling or distribution of securities. | | | (7) Net loss from securities in investment accounts. | | | Tolal additions | | | 2c. Deductions
(1) Revenues Irom the distribution of shares of a registered open and investment company of unit
investment trust, from the sale of variable annuities, from the business of insurance, from investment
advisory services rendared to registered investment companies or insurance company separate
accounts, and from transactions in security futures products. | | | (2) Revenues from commodily Itansactions. | | | (3) Commissions, floor brokerage and c earance paid to other SIPC members in connection with
securities transaclions. | | | (4) Reimbursements for postage in connection with proxy solicitation. | | | (5) Net gain from securities in investment accounts. | 1269 | | (6) 100% of commissions and markups earned from fransactions in (i) corlificales of deposit and
(ii) Treasury bills, bankers acceplances or commercial paper that mature nine months of less
Trom issuance date. | | | (7) Direct expenses of printing advertising and legal lees incurred in connection with other revenue
related to the securities business (revenue delined by Section 16(9){L) of the Acl). | | | (B) Other revenue not related either directly or indirectly lo the securities business.
(See Instruction C): | | | (Deductions in excess of \$100,000 require documentation) | | | (9) (i) Total inlerest and dividend expense (FOCUS Line 22/PART IIA Line 13,
Code 4075 plus line 2b(4) above) but nol in excess
of lotal interest and dividend income. | | | (ii) 40% of margin interest earned on customers securities
accounts (40% of FOCUS line 5, Code 3960). | | | Enter the graater of line (i) or (ii) | | | Total deductions | 1269 | | 2d. SIPC Nel Operating Revenues | 3544 964 | | 28. General Assossment @ .0015 | 5318 | | | (to page 1, line 2.A.) | {21}------------------------------------------------ # SIPC-7 Instructions This form is to be liled by all members of the Securities Investor Protection whose liscal years end in 2011 and annually thereatler. The lorm together with the payment is due no later the end of the fiscal year, or alter membership termination. Amounts reported herein must be readly reconcilable with the member's records and the Securities and Exchange Commission Rule 17a-5 report filed. Questions pertaining to this form should be directed to SIPC via e-mail at form@sipc.org or by lelephoning 202-371-8300. A. For the purposes of this form, the term "SIPC Net Operating Revenues" shall mean gross revenues from the securities business as defined in or pursuant to the applicable sections of the Securities Investor Protection Act of 1970 ("Act") and Article 6 of SIPC's bylaws (see page 4), less item 2c(9) on page 2. B. Gross revenues of subsidiaries, except foreign subsidiaties, are required to be included in SIPC Net Operating Revenues on a consolidated basis except for a subsidiary liling separately as explained hereinalter. If a subsidiary was required to file a Rule 17a-5 annual audited statement of income separately and is also a SIPC member, then such subsidiary must itself file SIPG-7, pay the assessment, and should not be consolidated in your SIPC -7. SIPC Net Operating Revenues of a predecessor member which are not included in item 2a, were not reported separately and the SIPC assessments were not paid thereon by such predecessor, shali be included in item 2b(1). - C. Your General Assessment should be compuled as follows; (1) Line 2a For the applicable period enter total revenue based upon amounts reported in your Rule 17a-5 Annual Audited Statement of Income prepared in conformily with generally accepted accounting principles applicable to securities brokers and dealers. or if exempted from that rule, use X-17A-5 (FOCUS Report) Line 12, Code 4030. - (2) Adjustments The purpose of the adjustments on page 2 is to determine SIPC Net Operating Revenues. - (a) Additions Lines 2b(1) through 2b(7) assure that assessable income and gain items of SIPC Nel Operating Revenues are totaled, unreduced by any losses (e.g., il a net loss was incurred for the period from all transactions in trading account securities, that net loss does not reduce other assessable revenues). Thus, line 2b(4) would include all short dividend and interest payments including those incurred in reverse conversion accounts, rebates on stock loan positions and repo interest which have been netted in determining line 2(a). - (b) Deductions Line 2c(1) through line 2c(9) are either provided for in the statue, as in deduction 2c(1), or are allowed to arrive at an assessment base consisting of net operating revenues from the securities business. For example, line 2c(9) allows for a deduction of either the total of interest and dividend expense (nol to exceed interest and dividend income), as reported on FOCUS line 22/PART IIA line 13 (Code 4075), plus line 2b(4) or 40% of interest earned on customers securities accounts (40% of FOCUS Line 5 Code 3960). Be certain to complete both line (i) and (ii), entering the greater of the two in the far right column. Dividends paid to shareholders are not considered "Expense" and thus are not to be included in the deduction. Likewise, interest and dividends paid to partners pursuant to the partnership agreements would also not be deducted. If the amount reported on line 2c (8) aggregates to \$100,000 or greater, supporting documentation must accompany the form that identifies these deductions. Examples of support information include; contractual agreements, prospectuses, and limited partnership documentation - (i) Determine your SIPC Net Operating Revenues, item 2d, by adding to item 2a, the total of item 2b, and deducting the total of item 2c. - (ii) Multiply SIPC Net Operating Revenues by the applicable rate. Enter the resulting amount in item 2e and on line 2A of page 1. - (iii) Enter on line 28 the assessment due as reflected on the SIPC-6 previously filed. - (iv) Subtract line 2B and 2C from line 2A and enter the difference on line 2D. This is the balance due for the period. - (v) Enter interest computed on late payment (if applicable) on line 2E. - (vi) Enter the lotal due on line 2F and the payment of the amount due on line 2G. - (vil) Enter overpayment carried forward (if any) on line 2H. D. Any SIPC member which is also a bank (as delined in the Securities Exchange Act of 1934) may exclude from SIPC Net Operaling Revenues dividends and interest received on securities in its investment accounts to the extent that it can demonstrate to SIPC's satisfaction that such securities are held, and such dividends and interest are received, solely in connection with its operations as a bank and not in connection with its operations as a broker, dealer or member of a national securities exchange. Any member who excludes from SIPC Nel Operating Revenues any dividends or interest pursuant to the preceding sentence shall file with this form a supplementary statement setting forth the amount so excluded and proof of its entitlement to such exclusion. E. Interest on Assessments. If all or any part of assessment payable under Section 4 of the Act has not been posimarked within 15 days after the due date thereol, the member shall pay, in addition to the amount of the assessment, interest at the rate of 20% per annum on the unpaid portion of the assessment for each day il has been overdue. F. Securities and Exchange Commission Rule 17a-5(e) (4) requires those who are not exempted from the audit requirement of the rule and whose gross revenues are in excess of \$500,000 to file a supplemental independent public accountants report covering this SIPC-7 no later than 60 days after their fiscal year ends. Mail this completed form to SIPC together with a check for the amount due, made payable to SIPC, using the enclosed return PO BOX envelope, pay via ACH Debit Authorization through SIPC's ACH system at www.sipc.org/for-members/assessments or wire the payment lo: On the wire identify the name of the firm and its SEC Registration 8-4 and label it as "for assessment." Please lax a copy of the assessment form to (202)-223-1679 or e-mail a copy to form@sipc.org on the same day as the wire. {22}------------------------------------------------ # From Section 16(9) of the Act: The term •gross revenues from the securities business· means lhe sum ol (but without duphcatlon)- (AJ commissions earned In conneclion with transactions in securities elfecled lor customers as agent (nel ol commissions paid to olher brokers and dealers in connection wilh such transactions) and markups willl respect 10 purchases or sales of securities as principal; (Bl charges lor executing or clearing transactions In securities for other brokers and deaters- (C) the net realized gain, II any, lrom principal transactions in securities In trading accounts; (D) the net prolil, ii any, lrom l�e management ol or participation In the underwriting or d1slribullon ol secunues. (E) interest earned on customers' securities accounts; (FJ lees lor Investment advisory services (except when rendered to one or more registered investment companies or Insurance company separate accounts) or account supervision with respect to securities; (G) lees lor lhe solicitation of proxies with respect to, or tenders or exchanges ol, securities; (H) income lrom service charges or other surcharges with respect lo securities; (I) except as otherwise provided by rule ol lhe Commission, dividends and Interest received on securities in inveslmenl aecounts of the broker or dealer; (JJ fees in connecllon with put, call, and olher options transactions In securities; (Kl commissions earned lor transactions in (i) certillcales of deposit, and (ii) Treasury bills, bankers acceplances, or commerclai paper which have a malurity al lhe time of Issuance ot not exceeding nine months, exclusive ol days or grace, or any renewal lhereol, lhe maturlly or which Is likewise llmiled, except lhal SIPC shall by bylaw Include In the aggregate al gross revenues only an appropriate percentage al such commissions based on SIPC's loss experience wllh respect lo such instruments over al least lhe preceding live years; and (l) lees and other Income from such olher calegories of the securilies business as SIPC shall provide by bylaw. Such term includes revenues earned by a broker or dealer in connection with a transaction in the portlollo margining account ol a customer carried as securilies accounts pursuanl lo a porllolio margining program approved by the Commission. Such lerm does nol Include revenues received by a broker or dealer In connecllon wllh the dislribullon ol shares ol a registered open end invest· menl company or unit investment trust or revenues derived by a broker or dealer from lhe sales ol variable annuities, the buslness of Insurance, or lransactions In security lutures producls. ### From Section 16(14) ol the Act: The term •securily" means any note, stock, treasury slock, bond, debenture, evidence of Indebtedness, any collateral trust certllicate, preorganlzalion cerlillcale or subscription, lranslerabte share, voling trust certllicale, certlllcale ol deposil, cerlllicate of deposil lor a security, or any securily lulure as Iha! term is delined In section 78c(a)(55)(A) of this tille, any lnvestmenl conlracl or cerlilicate of lnleresl or participation In any profit-sharing agreement or in any oil, gas or mineral royally or lease (ii such Investment contraet or lnleresl is the subject of a reglstralion slalemenl with the Commission pursuant to the provisions ol the Securities Act of 1933 {15 U.S.C. 77a el seq.I), any put, call, straddle, option, or privilege on any securily, or group or index of securllies (including any Interest therein or based on the value thereof), or any put, call, straddle, option, or privilege entered Into on a national securities exchange relating lo foreign currency, any certlllcate of Interest or participation in, temporary or Interim cerllllcata lor, receipt for, guarantee of, or warrant or right to subscribe to or purchase or sell any ol the foregoing, and any other Instrument commonly known as a securlty. Except as specifically provided above, Iha term •securily" doss net include any currency, or any commodily or related contract or futures centraet, or any warrant or right to subscribe to or purchase or sell any ol the foregoing. # From SIPC Bylaw Article 6(Assessments): Section 1 (f): The term •gross revenues from lhe securities business· Includes the revenues in the delinltion of gross revenues lrom the securities business set lorth in the applicable sections ol the Act. #### Section 3: For purpose al this article: (a) The term •securities In lrading accounts" shall mean securities held tor sale In lhe ordinary course of business and not identilied as having been held lor inveslment. (b) The term •securities in investment acccunts" shall mean securities that are clearly identilied as having been acquired for invest· ment In accordance wllh provisions of the Infernal Revenue Code applicable to dealers in securities. (c) The term "lees and other income lrom such other categories ol lhe securities business· shall mean all revenue related either dlreclly or indirectly to the securilles business except revenue included in Seclion 16(9)(A)·(L) and revenue specifically excepted in Sec lion 4 (c)(3)(Cl(llem 2c( 1 ), page 2). Nol• It lllt HIDs-.S al UHl.lllltal .. 11r1d 1111 Ihle 21 01 SIPC·7 ls g,u1o111hn 112 al I� al •grau 11W1aGu lro1111ht 11curitln bus 0111· H h�nd allow, y1111 ••Y 1ubm 11 •I c11cu 111r� a1,g • t� lbl S'PC 7 111111 la SIPC 1nd pay ln1 ...-.1111 11111111•1, ubJatl la 11, ••bf'°"' Euei,no11g A•lhar IJ and bf SIPC **Stec Fnolnfna 1nznnrt1tn·** | AS
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=p | 4 | FIHRA F naod1l ln11u11,, Regulator, .IMIIOlilf NYSE ,.,,a Inc NASDAQ OW: PHU s:PC Steutillts l11rtS1a1 P1011c114a Co1p0,1t,011 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.