# EQUILIBRIUM CAPITAL SERVICES, LLC X-17A-5 (2025-02-26) — Broker-dealer annual report - Company: EQUILIBRIUM CAPITAL SERVICES, LLC - Form: X-17A-5 - Filed: 2025-02-26 - Period: 2024-12-31 - Accession: 0001503999-25-000001 - CIK: 1503999 - File #: 8-68722 - Type: Broker-dealer - Material weakness: No - Auditor: Moss Adams LLP - Auditor location: Dallas, TX - Contact: Celeste Moye - Phone: 4156720559 - Email: celestecpa@comcast.net - Signed by: Theodore Holt (CEO and CCO) Original filing: https://www.sec.gov/Archives/edgar/data/1503999/000150399925000001/Equilibrium2024Audit.pdf --- {0}------------------------------------------------ ## UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 OMB APPROVAL OMB Number: 3235-0123 Expires: Nov. 30, 2026 Estimated average burden hours per response: 12 SEC FILE NUMBER 8-68722 ### ANNUAL REPORTS FORM X-17A-5 PART III FACING PAGE Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934 | | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | | AND ENDING 12/31/24 | | |--|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|---------------------|--| |--|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|---------------------|--| MM/DD/YY MM/DD/YY A. REGISTRANT IDENTIFICATION # NAME OF FIRM: Equilibrium Capital Services, LLC TYPE OF REGISTRANT (check all applicable boxes): E Broker-dealer [ Check here if respondent is also an OTC derivatives dealer ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) # 411 NW Park Ave, Suite 401 | | (No. and Street) | | | |---------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------|-----------------|--------------------------------------------| | Portland | Oregon | | 97209 | | (City) | (State) | | (Zip Code) | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | | Celeste Moye | 415-672-0559 | | celestecpa@comcast.net | | (Name) | (Area Code - Telephone Number) | (Email Address) | | | | | | | | | B. ACCOUNTANT IDENTIFICATION
INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing* | | | | Moss Adams LLP | (Name - if individual, state last, first, and middle name) | | | | 14555 Dallas Pkwy, Suite 300 Dallas | | Texas | 75254 | | | (City) | (State) | (Zip Code) | | 10/16/2003 | | 659 | | | (Address)
(Date of Registration with PCAOB)(if applicable) | | | (PCAOB Registration Number, if applicable) | Claims for exemption from the requirement that the annual reports of an independent public accountant must be supported by a statement of facts and circumstances relied on as the basis of the exemption. See 17 CFR 240.17a-5(e)(1)(ii), if applicable. Persons who are to respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB control number. {1}------------------------------------------------ #### OATH OR AFFIRMATION l, Theoclove. Holt financial report pertaining to the firm of English Services. (LC). Seconder partner, officer, director, or equivalent person, as the case may be, has any proprietary interest in any account classified solely as that of a customer. State of : Oregon County: Multnomah ![](_page_1_Picture_3.jpeg) | Signature: | | |-----------------------|--| | Title:
CFO and CCO | | Notary Public #### This filing\*\* contains (check all applicable boxes): - (a) Statement of financial condition. - [ (b) Notes to consolidated statement of financial condition. - | comprehensive income (as defined in § 210.1-02 of Regulation S-X). - (d) Statement of cash flows. - = (e) Statement of changes in stockholders' or partners' or sole proprietor's equity. - □ (f) Statement of changes in liabilities subordinated to claims of creditors. - = (g) Notes to consolidated financial statements. - (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-1, as applicable. - [ (i) Computation of tangible net worth under 17 CFR 240.18a-2. - | (j) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3. - □ (k) Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.15c3-3 or Exhibit A to 17 CFR 240.18a-4, as applicable. - O (I) Computation for Determination of PAB Requirements under Exhibit A to § 240.15c3-3. - (m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3. - 口 (n) Information relating to possession or control requirements for security-based swap customers under 17 CFR 240.15c3-3(p)(2) or 17 CFR 240.18a-4, as applicable. - (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capital or tangible net worth under 17 CFR 240.15c3-1, 17 CFR 240.18a-1, or 17 CFR 240.18a-2, as applicable, and the reserve requirements under 17 CFR 240.15c3-3 or 17 CFR 240.18a-4, as applicable, if material differences exist, or a statement that no material differences exist. - | (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition. - | |q) Oath or affirmation in accordance with 17 CFR 240.17a-5, 17 CFR 240.18a-7, as applicable. - | (r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - □ (t) Independent public accountant's report based on an examination of the statement of financial condition. - (u) Independent public accountant's report based on an examination of the financial statements under 17 CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable. - □ (v) Independent public accountant's report based on an examination of certain statements in the compliance report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - | |w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - □ (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-1e or 17 CFR 240.17a-12, as applicable. - പ (y) Report describing any material inadequacies found to have existed since the date of the previous audit, or a statement that no material inadequacies exist, under 17 CFR 240.17a-12(k). - □ (z) Other: \_\_\_ - \*\*To request confidential treatment of certain portions of this filing, see 17 CFR 240.170-5(e)(3) or 17 CFR 240.18c-7(d)(2), os applicable. {2}------------------------------------------------ #### Equilibrium Capital Services, LLC Report Pursuant to Rule 17a-5(d) For the Year Ended December 31, 2024 {3}------------------------------------------------ | Table
of
Contents | | |--------------------------------------------------------------------------------------------------------------------|----| | Report of Independent Registered Accounting Firm | 1 | | Financial Statements | | | Statement of Financial Condition | 2 | | Statement of Income | 3 | | Statement of Changes in Member's Equity | 4 | | Statement of Cash Flows | 5 | | Notes to Financial Statements | 6 | | Supplementary Information | | | Schedule I – Computation of Net Capital under Rule 15c3-1 | | | of the Securities and Exchange Commission | 9 | | Schedule II – Computation for Determination of the Reserve Requirements | | | and Information Relating to Possession or Control Requirements | | | for Brokers and Dealers under Rule 15C3-3 of the Securities and Exchange Commission | 10 | | Exemption Report | | | Report of Independent Registered Public Accounting Firm on Equilibrium Capital Services, LLC's
Exemption Report | 11 | | Equilibrium Capital Services, LLC's Exemption Report | 12 | {4}------------------------------------------------ # Report of Independent Registered Public Accounting Firm To the Member Equilibrium Capital Services, LLC #### Opinion on the Financial Statements We have audited the accompanying statement of financial condition of Equilibrium Capital Services, LLC (the Company) as of December 31, 2024, the related statements of income, changes in member's equity, and cash flows for the year then ended, and the related notes (collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Company as of December 31, 2024, and the results of its operations and its cash flows for the year then ended, in conformity with accounting principles generally accepted in the United States of America. #### Basis for Opinion MOSSADAMS These financial statements are the responsibility of the Company's management. Our responsibility is to express an opinion on the Company's financial statements based on our audit. We are a public accounting 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 to 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. #### Opinion on the Supplementary Information The supplementary information in Schedules I and II has been subjected to audit procedures performed in conjunction with the audit of the Company's financial statements. The information in Schedules I and II is the responsibility of the Company's management. Our audit procedures include determining whether the information in Schedules I and II reconciles to the financial statements or the underlying and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in Schedules I and II. In forming our opinion on the information in Schedules I and II, we evaluated whether the information in Schedules I and II, including its form and content is presented in conformity with 17 C.F.R. §240.17a-5. In our opinion, the information in Schedules I and II is fairly stated in all material respects in relation to the financial statements as a whole. Dallas, Texas February 25, 2025 We have served as the Company's auditor since 2018. {5}------------------------------------------------ #### ASSETS | Statement of Financial Condition
December 31, 2024 | | |-------------------------------------------------------|------------------------| | ASSETS | | | Cash
Prepaid expense | \$
782,441
1,719 | | Total assets | \$
784,160 | | LIABILITIES AND MEMBER'S EQUITY | | | Liabilities | | | Accounts payable and accrued expenses | \$
3,099 | | Payable to related party, net | 3,152 | | Total liabilities | 6,251 | | Member's equity | 777,909 | | Total liabilities and member's equity | \$
784,160 | {6}------------------------------------------------ #### REVENUES | Statement of Income | | | |------------------------------------|----|---------| | | | | | REVENUES | | | | Intercompany advisory services | \$ | 504,000 | | Interest income | | 32,399 | | Total revenues | | 536,399 | | EXPENSES | | | | Employee compensation and benefits | | 314,621 | | Occupancy | | 55,073 | | Professional fees | | 67,348 | | Regulatory expenses | | 14,405 | | Other operating expenses | | 383 | | Total expenses | | 451,830 | | Net income | \$ | 84,569 | {7}------------------------------------------------ | | Member's Equity | | |------------------------------|-----------------|--| | Balance at December 31, 2023 | \$
1,093,340 | | | Member's distributions | (400,000) | | | Net income | 84,569 | | | Balance at December 31, 2024 | \$
777,909 | | {8}------------------------------------------------ #### CASH FLOW FROM OPERATING ACTIVITIES | Statement of Cash Flows | | |---------------------------------------------------------|---------------| | | | | CASH FLOW FROM OPERATING ACTIVITIES | | | Net income | \$
84,569 | | Adjustments to reconcile net income to net cash used in | | | operating activities: | | | (Increase) Decrease in assets: | | | Prepaid expense | 10,162 | | Increase (Decrease) in liabilities: | | | Accounts payable and accrued expenses | (645) | | Payable to related party, net | (2,768) | | Net cash provided by operating activities | 91,318 | | CASH FLOW FROM FINANCING ACTIVITIES | | | Member's distributions | (400,000) | | Net cash used in financing activities | (400,000) | | NET CHANGE IN CASH | (308,682) | | Cash at beginning of year | 1,091,123 | | Cash at end of year | \$
782,441 | {9}------------------------------------------------ #### 1. GENERAL AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES #### Organization Equilibrium Capital Services, LLC (the "Company") was organized in the State of Oregon on October 1, 2010. The Company is a registered broker-dealer in securities under the Securities and Exchange Act of 1934, a member of the Financial Industry Regulatory Authority ("FINRA"), and a member of the Securities Investor Protection Corporation ("SIPC"). The Company is a wholly-owned subsidiary of Equilibrium Capital Group, LLC (the "Member"). The Company is engaged in business as a securities broker-dealer that provides several classes of services, including private placements, merger and acquisitions advisory services, and broker selling tax shelters or limited partnerships. For the year ended December 31, 2024, the Company's income was derived primarily from advisory services revenue performed in connection with capital raising for the Member and its affiliated funds and vehicles. Under its membership agreement with FINRA and relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5, the Company (1) does not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, (2) does not and will not carry accounts of or for customers, and (3) does not and will not carry PAB accounts. Other than fixed fee merger and acquisition advisory services provided to the Member, the Company limits its business activities exclusively to effecting securities transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company. #### Summary of Significant Accounting Policies Basis of Presentation – The accompanying financial statements are presented in conformity with accounting principles generally accepted in the United States of America ("U.S. GAAP"). Use of Estimates – The preparation of financial statements in conformity with accounting principles generally accepted in the United States of America 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 revenue and expenses during the reporting period. Actual results could differ from those estimates. Revenue Recognition – The Company charges fees in accordance with terms stipulated in its engagement contracts. Fees are recognized as earned and per the fee schedule stipulated in the Member's or client's engagement contracts. For the year ended December 31, 2024, the Company's only revenue producing contracts were with its Member – see Note 3. The Company performs services for its customers on an ongoing basis; accordingly the Company satisfies its performance obligations each month and thus recognizes its service fee on a monthly basis. The timing of the Company's revenue recognition may differ from the timing of payment by the Company's customers. The Company records a receivable when revenue is recognized prior to payment and has an unconditional right to payment. Alternatively, when payment precedes the provision of the related services, the Company records deferred revenue until the performance obligations are satisfied. The Company did not have any receivables from contracts with customers or deferred revenue as of December 31, 2024. Economic conditions that may affect the Company's performance primarily include the general economic and market conditions in the United States, specifically in the agriculture infrastructure, wastewater, energy facilities, and permanent crops industries. {10}------------------------------------------------ Equilibrium Capital Services, LLC Cash – The Company considers all highly liquid investments with a remaining maturity of three months or less when purchased to be cash equivalents. The Company maintains the majority of its cash balance on deposit with one Federal Deposit Insurance Corporation ("FDIC") insured financial institution. At times, these deposits may be in excess of federally insured limits. Commitments and Contingencies – The Company may become involved in various legal matters and regulatory inquiries or examinations in the ordinary course of business. The Company is not aware of any material contingencies relating to such matters that would require accrual or disclosure in the financial statements or their notes as of December 31, 2024. The Company does not have any guarantees or other commitments as of December 31, 2024. Guarantees – Financial Accounting Standards Board ("FASB") Accounting Standards Codification ("ASC") 460, Guarantees, requires the Company to disclose information about its obligations under certain guarantee arrangements. FASB ASC 460 defines guarantees as contracts and indemnification agreements that contingently require a guarantor to make payments to the guaranteed party based on changes in an underlying factor (such as an interest or foreign exchange rate, security or commodity price, an index or the occurrence or nonoccurrence of a specified event) related to an asset, liability, or equity security of a guaranteed party. This guidance also defines guarantees as contracts that contingently require the guarantor to make payments to the guaranteed party based on another entity's failure to perform under an agreement as well as indirect guarantees of indebtedness of others. The Company has issued no guarantees at December 31, 2024, or during the year then ended. #### 2. INCOME TAXES The operations of the Company are included in the consolidated federal and state income tax return filed by the Member. The Company is treated as a disregarded entity for federal income tax purposes, in accordance with single member limited liability company rules. All tax effects of the Company's income or loss are passed through to the Member. Therefore, no provision or liability for Federal or State Income Taxes is included in these financial statements. #### 3. RELATED-PARTY TRANSACTIONS The Company is engaged by its Member to perform capital raising activities for the Member and its affiliated funds and vehicles whereby the Member pays a monthly fee to the Company in consideration for these services. These services include, but are not limited to, reviewing and planning financing needs, performing due diligence, and executing on certain capital raising transactions as defined in the agreement. For the year ended December 31, 2024, advisory services earned by the Company with respect to this engagement with its Member totaled \$504,000. The Company has an expense sharing agreement with its Member whereby the Company pays a monthly reimbursement in consideration for certain expenses paid on the Company's behalf. These expenses include personnel, rent, and other administrative services. For the year ended December 31, 2024, expenses incurred by the Company with respect to the expense sharing agreement with its Member totaled \$369,694. It is possible that the terms of certain related party transactions are not the same as those that would result for transactions among wholly unrelated parties. {11}------------------------------------------------ #### 4. SEGMENT REPORTING The Company is engaged in a single line of business as a securities broker-dealer, which is comprised of several classes of services, including private placements, merger and acquisitions advisory services, and broker selling tax shelters or limited partnerships. The Company has identified two individuals to jointly serve as the Chief Operating Decision Maker ("CODM"): the Chief Executive Officer, who also serves as the Chief Compliance Officer, and the Financial and Operations Principal. The CODM 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 5), 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 as a whole. The accounting policies used to measure the profit and loss of the segment are the same as those described in the summary of significant accounting policies. The measure of segment assets is reported on the statement of financial condition as total assets, and segment revenues and expenses is reported on the statement of income as total revenues and expenses. #### 5. 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. Rule 15c3-1 also provides that equity capital may not be withdrawn, or cash dividends paid if the resulting net capital ratio would exceed 10 to 1. Net capital and aggregate indebtedness change day to day, but on December 31, 2024, the Company had net capital of \$776,190 which was \$771,190 more than its required net capital of \$5,000. The Company's ratio of aggregate indebtedness (of \$6,251) to net capital was 0.01 to 1. #### 6. SUBSEQUENT EVENTS The Company has reviewed events that have occurred after December 31, 2024 through February 25, 2025, the date the financial statements were available to be issued. During this period, no subsequent events occurred that require recognition or disclosure in the financial statements. {12}------------------------------------------------ # Equilibrium Capital Services, LLC Schedule I – Computation of Net Capital under Rule 15c3-1 of the Securities and Exchange Commission As of December 31, 2024 #### Computation of net capital | of the Securities and Exchange Commission
As of December 31, 2024 | | | | | |----------------------------------------------------------------------|---------------|----|----------|--| | Computation of net capital | | | | | | Member's equity | | \$ | 777,909 | | | Less: Non-allowable assets | | | | | | Prepaid expenses | \$
(1,719) | | | | | Total non-allowable assets | | | (1,719) | | | Net capital | | | 776,190 | | | Computation of net capital requirements | | | | | | Minimum net capital requirements | | | | | | 6 2/3 percent of net aggregate indebtedness | 417 | | | | | Minimum net capital required | 417 | | | | | Minimum dollar net capital required | 5,000 | | | | | Net capital required (greater of above) | | | (5,000) | | | Excess net capital | | \$ | 771,190 | | | Aggregate indebtedness | | \$ | 6,251 | | | Ratio of aggregate indebtedness to net capital | | | 0.01 : 1 | | Note: There are no material differences between the preceding computation and the Company's corresponding unaudited Part II of Form X-17A-5 as of December 31, 2024. {13}------------------------------------------------ #### Equilibrium Capital Services, LLC Schedule II – Computation for Determination of the Reserve Requirements and Information Relating to Possession or Control Requirements for Brokers and Dealers under Rule 15C3-3 of the Securities and Exchange Commission As of December 31, 2024 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"). The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240. 15c3-3, and the Company is relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 because the Company limits its business activities exclusively to effecting securities transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company. Therefore the Company is not required to present the Computation for Determination of the Reserve Requirements and Information Relating to Possession or Control Requirements for Brokers and Dealers under Rule 15c3-3 of the Securities and Exchange Commission. {14}------------------------------------------------ #### Equilibrium Capital Services, LLC Report of Independent Registered Public Accounting Firm on Equilibrium Capital Services, LLC's Exemption Report For the Year Ended December 31, 2024 {15}------------------------------------------------ ![](_page_15_Picture_0.jpeg) # Report of Independent Registered Public Accounting Firm To the Member Equilibrium Capital Services, LLC We have reviewed management's statements, included in the accompanying Equilibrium Capital Services, LLC's (the Company) Exemption Report (the exemption report), in which: - 1. The Company does not claim an exemption under paragraph (k) of 17 C.F.R. §240.15c3-3; and - 2. The Company states the Company is filing the exemption report relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. §240.17a-5 (Footnote 74) because, throughout the most recent fiscal year, without exception: - · The Company limits its business activities exclusively to effecting securities transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company, and - · The Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, other than 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; (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3). The Company's management is responsible for compliance with the provisions of Footnote 74 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 the Company's compliance with the provisions of Footnote 74. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, we do not express such an opinion. Based on our review, we are not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based on the provisions of Footnote 74 of SEC Release No. 34-70073. Dallas, Texas February 25, 2025 {16}------------------------------------------------ # Exemption Report as contemplated by footnote 74 of SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 and related SEC Staff Frequently Asked Questions #### Equilibrium Capital Services, LLC's Exemption Report Equilibrium Capital Services, 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 following: (1) The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240. 15c3-3, 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. § 240.17a-5 because the Company limits its business activities exclusively to effecting securities transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company; and the Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, (other than 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); (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year, without exception. Equilibrium Capital Services, LLC I, Theodore Holt swear (or affirm) that, to my best knowledge and belief, this Exemption Report is Title: Chief Compliance Officer, Equilibrium Capital Services, LLC true and correct. By: 2/25/2025 Date Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.