# POLARIS PRIVATE PLACEMENTS, LLC X-17A-5 (2021-03-03) — Broker-dealer annual report
- Company: POLARIS PRIVATE PLACEMENTS, LLC
- Form: X-17A-5
- Filed: 2021-03-03
- Period: 2020-12-31
- Accession: 0001515119-21-000006
- CIK: 1701383
- File #: 8-69922
- Material weakness: No
- Auditor: Rubio CPA, PC
- Auditor location: Atlanta, GA
- Contact: Anthony Diamos
- Phone: 4045366984
- Signed by: John Pernell (Chief Executive Officer)
Original filing: https://www.sec.gov/Archives/edgar/data/1701383/000151511921000006/PolarisAnnualAuditReport.pdf
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UNITEDSTATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549
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# ANNUAL AUDITED REPORT FORM X-17A-5 PART III
SEC FILE NUMBER 8-69922
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 | | MM/DD/YY | |
| | A. REGISTRANT IDENTIFICATION | | | |
| NAME OF BROKER-DEALER: Polaris Private Placements, LLC | | | OFFICIAL USE ONLY | |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.) | | FIRM I.D. NO. | | |
| | 735 Johnnie Dodds Blvd, Ste 105 | | | |
| | (No. and Street) | | | |
| Mt. Pleasant | SC | | 29464 | |
| (City) | (State) | | (Zip Code) | |
| NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT
Anthony Diamos | | | (404) 536-6984 | |
| | B. ACCOUNTANT IDENTIFICATION | | (Area Code - Telephone Number) | |
| | | | | |
| INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report* | | | | |
| | Rubio CPA, PC | | | |
| | (Name - if individual, state last, first, middle name) | | | |
| 2727 Paces Ferry Rd, Bldg 2, Ste 1680 Atlanta | | Georgia | 303339 | |
| (Address) | (City) | (State) | (Zip Code) | |
| CHECK ONE: | | | | |
| Certified Public Accountant | | | | |
| Public Accountant | | | | |
| Accountant not resident in United States or any of its possessions. | | | | |
| FOR OFFICIAL USE ONLY | | | | |
| | | | | |
| | | | | |
| to laims for rearning from the the annual renoved by the opinion of an independent mindependent minis accounter | | | | |
"Clains for exemption from the requirement that the annual report be covered by the opinion of an independent f must be supported by a statement of facts and circumstances relied on as the basis for the exemption. See Section 240.17a-5(e)(2)
> Potential 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.
SEC 1410 (11-05)
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#### OATH OR AFFIRMATION
| John Pernell | swear (or affirm) swear (or affirm) that, to the best of |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of
Polaris Private Placements, LLC | . as |
| December 31
of | . But a mand correct. I further swear (or affirm) that |
| classified solely as that of a customer, except as follows: | neither the company nor any partner, principal officer or director has any proprietary interest in any account |
| | Signature |
| Notary Public
This report ** contains (check all applicable boxes):
V (a) Facing Page.
(b) Statement of Financial Condition.
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. | minut
Chief Executive Officer
Title
1)=C.
2025
(c) Statement of Income (Loss) or, if there is other comprehensite the the one in the period(s) presented, a Statement |
| (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.
Computation for Determination of the Reserve Requirements Under Exhibit A of Rule 15c3-3.
consolidation. | (i) A Reconciliation, including appropriate explanation of Net Capital Under Rule 15c3-1 and the
(k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of |
| (1) An Oath or Affirmation.
(m) A copy of the SIPC Supplemental Report.
** For conditions of confidential treatment of certain portions of this filing, see section 240.17a-5(e)(3). | (n) A report describing any material inadequacies found to exist or found to have existed since the date of the previous audit. |
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FINANCIAL STATEMENTS FOR THE YEAR ENDED DECEMBER 31, 2020 WITH REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
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### **CONTENTS**
Report of Independent Registered Public Accounting Firm
Statement of Financial Condition
Statement of Operations
Statement of Changes in Member's Equity
Statement of Cash Flows
Notes to Financial Statements
Supplementary Information
| Schedule I: | Computation of Net Capital Pursuant to Uniform Net Capital Rule 15c3-1 of the
Securities and Exchange Commission as of December 31, 2020 |
|---------------|-------------------------------------------------------------------------------------------------------------------------------------------------------|
| Schedule II: | Computation for Determination of Reserve Requirements Under Rule 15c3-3 of
the Securities and Exchange Commission as of December 31, 2020 |
| Schedule III: | Information Relating to the Possession or Control Requirements Under Rule
15c3-3 of the Securities and Exchange Commission as of December 31, 2020 |
Report of Independent Registered Public Accounting Firm on the Company's Exemption Report
Polaris Private Placements, LLC Exemption Report
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# RUBIO CPA, PC
CERTIFIED PUBLIC ACCOUNTANTS
2727 Paces Ferry Road SE Building 2, Suite 1680 Atlanta, GA 30339 Office: 770690-8995 Fax: 770 838-7123
#### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
To the Member of Polaris Private Placements, LLC
#### Opinion on the Financial Statements
We have audited the accompanying statement of financial condition of Polaris Pircate Placements, LLC (the "Company") as of December 31, 2020, the related statements of operations, 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, 2020, 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
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. The Company is not required to have, nor were we engaged to perform, an audit of its internal control over financial reporting. As part of our audit we are required to obtain an understanding of internal control over financial reporting but not for the purpose of expressing an opinion on the Company's internal control over financial reporting. Accordingly, we express no such opinion.
Our audit included performing procedures to assess the risks of material misstatement to the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion.
#### Supplemental Information
The information contained in Schedules I, II and III has been subjected to audit procedures performed in conjunction with the audit of the Company's financial statements. The supplemental information is the Company's management. Our audit procedures included determining whether the information in Schedules I, II and III 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 the accompanying schedules. In forming our opinion on the accompanying schedules, we evaluated whether the supplemental information, including its form and content, is presented
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in conformity with 17 C.F.R. §240.17a-5. In our opinion, the aforementioned supplemental information is fairly stated, in all material respects, in relation to the financial statements as a whole.
We have served as the Company's auditor since 2019.
February 26, 2021 Atlanta, Georgia
CAR
Rubio CPA, PC
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#### **POLARIS PRIVATE PLACEMENTS, LLC STATEMENT OF FINANCIAL CONDITION DECEMBER 31, 2020**
| ASSETS | |
|---------------------------------------|-------------|
| Cash | \$
8,777 |
| | |
| Total Assets | \$
8,777 |
| LIABILITIES AND MEMBER'S EQUITY | |
| LIABILITIES | |
| Due to related party | \$
456 |
| Total Liabilities | 456 |
| MEMBER'S EQUITY | 8,321 |
| Total liabilities and member's equity | \$
8,777 |
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### **POLARIS PRIVATE PLACEMENTS, LLC STATEMENT OF OPERATIONS FOR THE YEAR ENDED DECEMBER 31, 2020**
| REVENUE | |
|---------------------------------------------|----------------|
| Forgiveness of indebtedness - Related party | \$
3,493 |
| Total revenue | \$
3,493 |
| EXPENSES | |
| Professional fees | 17,650 |
| Other | 1,888 |
| Occupancy | 1,200 |
| Technology and communications | 623 |
| Total expenses | \$
21,361 |
| NET LOSS | \$
(17,868) |
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#### **POLARIS PRIVATE PLACEMENTS, LLC STATEMENT OF CHANGES IN MEMBER'S EQUITY FOR THE YEAR ENDED DECEMBER 31, 2020**
| BALANCE, December 31, 2019, as previously reported | | 8,978 |
|----------------------------------------------------|----|----------|
| Adjustment to reflect expense in prior year | | (1,289) |
| BALANCE, December 31, 2019, as previously reported | | 7,689 |
| Contributions | | 18,500 |
| Net Loss | | (17,868) |
| BALANCE, December 31, 2020 | \$ | 8,321 |
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### **POLARIS PRIVATE PLACEMENTS, LLC STATEMENT OF CASH FLOWS FOR THE YEAR ENDED DECEMBER 31, 2020**
#### **CASH FLOWS FROM OPERATING ACTIVITIES:**
| Net Loss | \$
(17,868) |
|-------------------------------------------------------|----------------|
| Items which do not impact cash: | |
| Adjustment to reflect expense in prior year | (1,289) |
| Adjustments to reconcile net loss to net cash used by | |
| operating activities: | |
| Decrease in due to related party | (1,670) |
| NET CASH USED BY OPERATING ACTIVITIES | \$
(20,827) |
| CASH FLOWS FROM FINANCING ACTIVITIES: | |
| Contributions | 18,500 |
| NET CASH PROVIDED BY FINANCING ACTIVITIES | \$
18,500 |
| NET DECREASE IN CASH | (2,327) |
| CASH, at beginning of year | \$
11,104 |
| CASH, at end of year | \$
8,777 |
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# *NOTE 1 - ORGANIZATION AND SIGNIFICANT ACCOUNTING POLICIES*
#### *Organization and business*
Polaris Private Placements, LLC (the "Company") is a securities broker-dealer registered with the Securities and Exchange Commission (SEC) and a member of the Financial Industry Regulatory Authority (FINRA). The Company is a South Carolina limited liability company organized in September 2016 and became a broker-dealer in July 2018. As a limited liability company, the member's liability is limited to its investment.
#### *Accounting Policies*
The Company follows Generally Accepted Accounting Principles (GAAP), as established by the Financial Accounting Standards Board (the FASB), to ensure consistent reporting of financial condition, results of operations, and cash flows.
#### *Cash*
The Company maintains its bank accounts at a high credit quality financial institution. Balances at times may exceed federally insured limits.
#### *Revenue Recognition*
The Company has yet to generate any revenue from customers. The Company's revenue will primarily be commissions and fees generated from private placements and sale of limited partnerships in primary distributions.
The recognition and measurement of revenue is based on the assessment of individual contract terms. Significant judgment is required to determine whether performance obligations are satisfied at a point in time or over time; how to allocate transaction prices where multiple performance obligations are identified; when to recognize revenue based on appropriate measure of the Company's progress under the contract; whether revenue should be presented gross or net of certain costs; and whether constraints on variable consideration should be applied due to uncertain future events.
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# *NOTE 1 - ORGANIZATION AND SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)*
#### *Estimates*
Management uses estimates and assumptions in preparing financial statements in accordance with generally accepted accounting principles. Those estimates and assumptions affect the reported amounts of assets, liabilities, revenues and expenses. Actual results could vary from the estimates that were assumed in preparing the financial statements.
#### *Income Taxes*
The Company is a single-member limited liability company and is considered a disregarded entity for federal income tax reporting purposes. Accordingly, the Company does not file a separate income tax return. The income or losses of the Company flow through to and are taxable to the Member. Therefore, no income taxes are reflected in the accompanying 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, including its status as a pass-through entity, 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.
# *NOTE 2 - NET CAPITAL REQUIREMENTS*
The Company is subject to SEC Uniform Net Capital Rule 15c3-1, which requires the maintenance of a minimum net capital, as defined, equal to the greater of \$5,000 or 6 2/3% of aggregate indebtedness as well as a ratio of aggregate indebtedness to net capital that shall not exceed 15 to 1. At December 31, 2020, the Company had net capital of \$8,321, which was \$3,321 in excess of its required minimum net capital of \$5,000. The Company's ratio of aggregate indebtedness to net capital was 0.05 to 1.
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### *NOTE 3 - SUBSEQUENT EVENTS*
The Company has performed an evaluation of subsequent events through the date the financial statements were issued. The evaluation did not result in any subsequent events that required disclosures and/or adjustments.
# *NOTE 4 - CONTINGENCIES*
The Company is subject to litigation in the normal course of business. The Company has no litigation in progress at December 31, 2020.
As a registered broker-dealer, the Company is required to maintain a fidelity bond policy with minimum coverage amounts. Fidelity bond coverage had lapsed on December 31, 2020, but was reinstated effective February 8, 2021. The Company believes that there was no activity during the period without coverage that would cause a loss to the Company.
# *NOTE 5 - RELATED PARTY TRANSACTIONS*
The Company leases office space under a month-to-month agreement from a sister company. Rent expense pursuant to the lease was \$1,200.
Separately, under an informal arrangement, the sister company provides technology and communication services to the Company based upon estimated usage by the Company. The amount expensed by the Company during 2020 pursuant to this arrangement was approximately \$623.
In July and September 2020, the sister company forgave amounts owed to it from current and prior years under both the lease agreement and the informal arrangement in the amount of approximately \$3,493. This amount has been included in forgiveness of indebtedness revenue on the accompanying statement of operations.
The amount due to related party on the accompanying statement of financial condition arises from both the lease agreement and the informal arrangement.
Financial position and results of operations would differ from the amounts in the accompanying financial statements if these related party transactions did not exist.
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# *NOTE 6 - NET LOSS*
The Company incurred a loss for 2020 and was dependent on its Member for capital contributions for working capital and net capital. The Company's Member has represented that it has the means and intention to provide capital contributions as needed to ensure the Company's survival through at least one year subsequent to the date of the report of the independent registered public accounting firm.
Management expects the Company to continue as a going concern and the accompanying financial statements have been prepared on a going-concern basis without adjustments for realization in the event that the Company ceases to continue as a going concern.
# *NOTE 7 - ECONOMIC RISKS*
In March 2020, the World Health Organization (WHO) declared COVID-19 a global pandemic. This pandemic event has resulted in significant business disruption and uncertainty in both global and U.S. markets. While the Company believes that it is in an appropriate position to sustain the potential short-term effects of these world-wide events, the direct and long-term impact to the Company and its financial statements is undetermined at this time.
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# **SUPPLEMENTARY INFORMATION**
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# **Schedule I Computation of Net Capital Pursuant to Rule 15c3-1 of the Securities and Exchange Commission As of December 31, 2020**
| NET CAPITAL | |
|-----------------------------------------------------|-------------|
| Member's equity | \$
8,321 |
| Total non-allowable assets | \$
- |
| NET CAPITAL | \$
8,321 |
| Minimum net capital required (greater of 6-2/3 % of | |
| aggregate indebtedness or \$5,000) | \$
5,000 |
| Excess net capital | \$
3,321 |
| AGGREGATE INDEBTEDNESS: | \$
456 |
| RATIO OF AGGREGATE INDEBTEDNESS TO NET CAPITAL: | .05 to 1 |
Reconciliation with the Company's computation of net capital included in Part IIA of Form X-17A-5 as of December 31, 2020 and net capital as computed above.
There are no material differences between the above computation of net capital and the corresponding computation reported in Form X-17A-5 Part IIA.
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#### **SCHEDULE II**
#### **COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION AS OF DECEMBER 31, 2020**
The Company does not claim exemption from SEA Rule 15c3-3, in reliance on Footnote 74 of the 2013 Release. The Company does not hold customer funds or securities.
#### **SCHEDULE III**
#### **INFORMATION RELATING TO THE POSSESSION OR CONTROL REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION AS OF DECEMBER 31, 2020**
The Company does not claim exemption from SEA Rule 15c3-3, in reliance on Footnote 74 of the 2013 Release. The Company does not hold customer funds or securities.
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