# CLEARSIGHT CAPITAL ADVISORS, INC. X-17A-5 (2020-02-11) — Broker-dealer annual report
- Company: CLEARSIGHT CAPITAL ADVISORS, INC.
- Form: X-17A-5
- Filed: 2020-02-11
- Period: 2019-12-31
- Accession: 0001533963-20-000001
- CIK: 1533963
- File #: 8-68998
- Material weakness: No
- Auditor: Rubio CPA PC
- Auditor location: Atlanta, GA
- Contact: Joel Kallett
- Phone: 703-672-3101
- Signed by: Joel Kallett (CEO)
Original filing: https://www.sec.gov/Archives/edgar/data/1533963/000153396320000001/Clraudit.pdf
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UNITED STATES SECURJTIESAND EXCHANGE COMMISSION Washington, D.C. 20549
OMB APPROVAL OMB Number: 3235-0123 Expires: August 31, 2020 Estimated average burden hours per response .... . . 12.00
## **ANNUAL AUDITED REPORT FORM X-17A-5 PART Ill**
SEC FILE NUMBER 8-68998
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 01/01/19
AND ENDING 12/31/19
--------------------- | | --------------------- | |
|--------------------------------------------------------------------------|------------------------------------------------------------------------------------------|---------------------------------------------------------------------|-----------------------|--------------------------------|
| | | MM/OONY | | MM/00/YY |
| | | A. REGISTRANT IDENTIFICATION | | |
| NAME OF BROKER-DEALER: CLEARSIGHT CAPITAL ADVISORS, INC. | | | | OFFICIAL USE ONLY |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.) | | | | FIRM 1.0. NO. |
| 1650 TYSONS BLVD., SUITE 710 | | | | |
| | | (No. and Street) | | |
| MCLEAN | | VA | | 22102 |
| (City) | | (State) | | (Zip Code) |
| NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT | | | | |
| JOEL KALLETT | | | | (703) 672-3101 |
| | | | | (Area Code - Telephone Number) |
| | | B. ACCOUNTANT IDENTIFICATION | | |
| INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report* | | | | |
| RUBIO CPA PC | | | | |
| | | (Name- if individual, state las!, first, middle name) | | |
| 2727 Paces Ferry Rd SE, Suite 2-1680 Atlanta | | | GA | 30339 |
| (Address) | | (City) | (State) | (Zip Code) |
| CHECK ONE: | | | | |
| l.f I
Certified Public Accountant | | | | |
| Public Accountant | | | | |
| B | | 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 240.17a-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 141 0 (06-02)
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#### **OATH OR AFFIRMATION**
I, JOEL KALLEn , swear (or affirm) that, to the best of
my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of CLEARSIGHT CAPITAL ADVISORS, INC. ------------------------------------------------------------------------------------------- 'as
#### of DECEMBER 31 are true and correct. I further swear (or affirm) that
neither the company nor any partner, proprietor, principal officer or director has any proprietary interest in any account classified solely as that of a customer, except as follows:
*\*\*For conditions of confidential treatment of certain portions of this filing, see section 240.17a-5(e)(3).*
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# **CLEARSIGHT CAPITAL ADVISORS, INC.**
Financial Statements For the Year Ended December 31 , 2019 With Report of Independent Registered Public Accounting Firm
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# **RUBIO CPA, PC** CERTIFIED PUBLIC ACCOUNTANTS
2727 Paces Ferry Road SE Building 2, Suite 1680 Atlanta, GA 30339 Office: 770 690-8995 Fax: 770 838-7123
#### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**
To the Stockholder of Clearsight Capital Advisors, Inc.
#### Opinion on the Financial Statements
We have audited the accompanying statement of financial condition ofCiearsight Capital Advisors, Inc. (the '·Company") as of December 31, 2019, the related statements of operations, changes in stockholder'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, 2019, and the results of its operations and its cash flows for the year then ended in confo rmity 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 reg.ulations 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 en·or or haud. 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 effectiveness of the Company's internal control over financial reporting. Accordingly, we expr,ess 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 proced!ures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audit also included evaluating the accounting pdnciples 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 of our opinion.
#### Supplemental Information
The information contained in Schedules I, II and Ill has been subjected to audit procedures performed in conjunction with the audit of the Company's financial statements. The supplemental information is the responsibility of the Company's management. Our audit procedures included determinin~ whether t~e information in Schedules I, li and Ill reconciles to the financial statements or the underlymg accountmg and other records, as applicable, and performing procedures to test the completeness and accuracy of the
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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 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 20 II.
February I 0, 2020 Atlanta, Georgia
~dl(l'c-
Rubio CPA, PC
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#### Clearsight Capital Advisors, Inc. Statement of Financial Condition December 31 , 2019
#### Assets
| Cash | \$
3,452,124 |
|--------------------------------------------|-----------------|
| Prepaid expenses and other assets | 10,443 |
| Total Assets | \$
3,462,567 |
| Liabilities and Stockholder's Equity | |
| Liabilities | |
| Accounts payable | \$
3,218 |
| Due to parent | 1,172,000 |
| Total Liabilities | 1,175,218 |
| | |
| Stockholder's Equity | 2,287,349 |
| | |
| Total Liabilities and Stockholder's Equity | \$
3,462,567 |
| | |
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#### Clearsight Capital Advisors, Inc. Statement of Operations For the Year Ended December 31 ,2019
| Revenues | |
|-------------------------------|-----------------|
| Investment banking | \$
3,620,000 |
| Total revenues | 3,620,000 |
| Expenses | |
| Compensation and benefits | 1 ,975,171 |
| Technology and communications | 101,273 |
| Occupancy | 64,963 |
| Professional services | 40,387 |
| Licenses and registration | 14,897 |
| Other expenses | 21 ,655 |
| Total expenses | 2,218,346 |
| Net Income | 1,401 654
\$ |
| | |
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#### Clearsight Capital Advisors, Inc. Statement of Changes in Stockholder's Equity For the Year Ended December 31,2019
| | Total | |
|----------------------------|-----------------|--|
| Balance, Jlanuary 1, 2019 | \$
1,375,695 | |
| Net income | 1,401 ,654 | |
| Distributions | (490,000) | |
| Balance, December 31, 2019 | \$
2,287,349 | |
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#### Clearsight Capital Advisors, Inc. Statement of Cash Flows For the Year Ended December 31,2019
| Cash flows from operating activities: | |
|-------------------------------------------------------------------------|------------------|
| Net income | \$
1,401 ,654 |
| Adjustments to reconcile net income to net cash provided by operations: | |
| Change in prepaid expenses and other assets | (718) |
| Change in accounts payable | (4,863) |
| Change in due to pare11t | 388,107 |
| Net cash provided by operating activities: | 1,784,180 |
| Cash flows from financing activities: | |
| Distributions | (490,000) |
| Net cash used by financing activities: | (490,000) |
| Net increase in cash: | 1,294,180 |
| Cash Balance: | |
| Beginning of year | 2,157,944 |
| End of year | \$
3,452,124 |
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#### **CLEARSIGHT CAPITAL ADVISORS, INC. NOTES TO FINANCIAL STATEMENTS December31 , 2019**
#### **NOTE 1 -SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES**
Organization and Description of Business: Clearsight Capital Advisors, Inc. (the "Company"), a Delaware corporation, was organized in September 2011 and became a broker-dealer in May 2012. 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's primary business is investment banking services and it operates under the provisions of paragraph (k)(2)(i) of Rule 15c3-3 of the Securities Exchange Act of 1934. The Company operates from offices located in Mclean, Virginia, and its customers are located throughout the United States.
The Company is wholly-owned by Clearsight Advisors, Inc. ("Parent" or "Stockholder").
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 operation, and cash flows.
Cash: The Company maintains its bank account in a high credit quality institution. Balances at times may exceed federally insured limits.
Income Taxes: The Company has elected S corporation status for income tax reporting purposes. Income or losses of the Company flow through to the Stockholder and no income taxes are recorded 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.
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.
Accounts Receivable: Accounts receivable are non-interest bearing uncollateralized obligations receivable in accordance with the te~rms agreed upon with each customer.
The carrying amount of accounts receivable is reduced by a valuation allowance that reflects management's best estimate of the amounts that will not be collected. Management individually reviews all delinquent accounts receivable balances and, based on an assessment of current credit worthiness, estimates the portion, if any, of the balance that will not be collected. Generally, customer receivables are believed to be fully collectible.
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### **CLEARSIGHT CAPITAL ADVISORS, INC. NOTES TO FINANCIAL STATEMENTS December31 , 2019**
#### **NOTE 1-SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)**
Date of Management's Review: Subsequent events were evaluated through the date the financial statements were issued.
Revenue Recognition: Fees are g:enerally recognized when earned and realized or realizable, when persuasive evidence of an arrangement exists, delivery has occurred, or services have been rendered, the price is fixed and determinable, and collectability is reasonably assured.
Revenue from Contracts with Customers Standard (ASU 2014-09) core principle is that an entity should recognize revenue when it transfers promised goods or services to customers in an amount that reflects the consideration to which the entity expects to be entitled in exchange for those goods or services. ASU 2014-09 prescribes a five-step process to accomplish this core principle, including:
- Identification of the contract with the customer;
- Identification of the performance obligation(s) under the contract;
- Determination of transaction price;
- Allocation of the transaction price to the identified performance obligation(s); and
- Recognition *ot* revenue as (orr when) an entity satisfies the identified performance obligation(s).
The Company recognizes revenue upon completion of a success fee-based transaction as this satisfies the only performance obligation identified in accordance with this standard.
#### **NOTE 2-NET CAPITAL**
The Company is subject to SEC Uniform Net Capital Rule (SEC 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 percentage of aggregate indebtedness to net capital that shall not exceed 1500%. At December 31, 2019, the Company had net capital of \$2,276,906 which was \$2,198,558 in excess of its required net capital of \$78,348 and its percentage of aggregate indebtedness to net capital was 51 .61%.
#### **NOTE 3-RELATED PARTY TRANSACTIONS**
The Company has an expense sharing agreement with its Parent. Under the terms of this agreement, the Company pays the Parent for personnel services, occupancy and other administrative costs provided to the Company. The amount expensed under the arrangement for the year ended December 31 , 2019 was approximately \$2,151 ,650. The balance due to the Parent on the accompanying statement of financial condition arose from this services agreement.
Financial position and results of operation could differ from the amounts in the accompanying financial statements if this arrangement did not exist.
#### **NOTE 4-CONCENTRATION**
All of the Company's revenue earned during 2019 was from three customers.
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#### **CLEARSIGHT CAPITAL ADVISORS, INC. NOTES TO FINANCIAL STATEMENTS December31 , 2019**
#### **NOTE 5- CONTINGENCIES**
The Company is subject to litigation in the normal course of business. The Company has no litigation in progress at December 31 , 2019.
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### Clearsight Capital Advisors, Inc. Schedule I Computation of Net Capital Pursuant to Rule 15c3-1 Of The Securities and Exchange Commission Act Of 1934 As of December 31 , 2019
| Net Capital: | |
|------------------------------------------------------------|-----------------|
| Total stockholder's equity | \$
2,287,349 |
| Less: | |
| Prepaid expenses and other assets | 10,443 |
| | 10,443 |
| Net capital before haircuts | 2,276,906 |
| Less haircuts | |
| Net capital | 2,276,906 |
| Minimum net capital required (greater of \$5,000 or 6 2/3% | 78,348 |
| of aggregate indebtedness) | |
| Excess net capital | \$
2,198,558 |
| | |
| Aggregate indebtedness | \$
1,175,218 |
| | |
| Percentage of aggregate indebtedness to net capital | 51
.61% |
| | |
Reconciliation with Company's computation of net capital included in Part IIA of Form X-17A-5 as of December 31,2019.
There was no significant difference between net capital in the FOCUS Part IIA form and the computation above.
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#### Clearsight Capital Advisors, Inc.
#### Schedule II COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION AS OF DECEMBER 31 , 2019
The Company is exempt from the provisions of Rule 15c3-3 under the Securities Exchange Act of 1934, pursuant to paragraph (k)(2)(i) of the rule.
### Schedule Ill INFORMATION RELATING TO THE POSSESSION OR CONTROL REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION AS OF DECEMBER 31 , 2019
The Company is exempt from the provisions of Rule 15c3-3 under the Securities Exchange Act of 1934, pursuant to paragraph (k)(2)(i) of the rule.
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EXEMPTION REPORT SEA RULE 17a-5(d)(4)
February 3, 2020
RUBIO CPA, PC 272 Paces Ferry Rd. SE Building 2, Suite 1680 Atlanta, GA 30339
To Whom it May Concern:
The below information is designed to meet the Exemption Report criteria pursuant to SEA Rule 17a-5(d)(4):
Clearsight Capital Advisors, Inc. is a broker/dealer registered with the SEC and FINRA. Pursuant to paragraph k(2)(i) of SEA Rule 15c3-3, the Company is claiming an exemption from SEA Rule 15c3-3 for the fiscal year ended December 31 , 2019.
The Company has met the identified exemption provisions throughout the most recent fiscal year without exception.
The above statement is true and correct to the best of my and the Company's knowledge.
S igned: W ~
Name : Jo7~ allett
Title: CEO
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**RUBIO CPA, PC** CERTIFIED PUBLIC ACCOUNTANTS 2727 Paces Ferry Road SE
Building 2, Suite 1680 Atlanta, GA 30339 Office: 770 690-8995 Fax: 770 838-7123
#### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**
To the Stockholder of Clearsight Capital Advisors, Inc.
We have reviewed management's statements, included in the accompanying Broker Dealers Annual Exemption Repon in which (I) Clearsight Capital Advisors., Inc. identified the following provisions of 17 C.F .R. § I Sc3-3(k) under which Clearsight Capital Advisors, Inc. claimed an exemption from 17 C.F.R. § 240.15c3-3: (k)(2)(i) (the ·'exemption provisions''); and, (2) Clearsight Capital Advisors, lnc. stated that Clcarsight Capital Advisors, Inc. met the identified exemption provisions throughout the most recent fiscal year without exception. Clearsight Capital Advisors, Inc.'s management is responsible for compliance with the exemption provisions and its statements.
Our review was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included inquiries and other required procedures to obtain evidence about Clearsight Capital Advisors, Inc.'s compliance with the exemption provisions. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, we do not express such an opinion.
Based on our review, we are not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based on the provisions set forth in paragraph (k)(2)(i), of Rule 15c3-3 under the Securities Exchange Act of 1934.
February I 0, 2020 Atlanta, GA
Rubio CPA, PC
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# RUBIO CPA, PC CERTIFIED PUBLIC ACCOUNTANTS 2727 Paces Ferry Road SE
Building 2, Suite 1680 Atlanta, GA 30339 Office: 770 690-8995 Fax: 770 838-7123
#### INDEPENDENT ACCOUNTANT' S REPORT ON APPLYING AGREED-UPON PROCEDURES RELATED TO AN ENTITY'S SIPC ASSESSMENT RECONCILIATION
To the Stockholder of Clearsight Capital Adv isors, Inc.
We have performed the procedures included in Rule 17a-5(e)(4) under the Securities Exchange Act of 1934 and in the Securities Investor Protection Corporation (SI PC) Series 600 Rules, which are enumerated below and were agreed to by Clearsight Capital Advisors, Inc. and the SIPC, solely to assist you and SIPC in evaluating Clearsight Capital Advisors, Inc.'s compliance with the applicable instructions of the General Assessment Reconci I iation (Form SIPC-7) for the year ended December 3 I, 2019. Clearsight Capital Advisors, Inc.'s management is responsible for its Form SIPC-7 and for its compliance with those requirements. This agreed-upon procedures engagement was conducted in accorda nce with standards establ ished by the Public Company Accounting Oversight Board (United States) and i11 accordance with attestation standards established by the Ame rican Institute of Certified Public Accountants. The sufficiency of these procedures is solely the responsibility of those parties specified in this report. Consequently, we make no representation regarding the suffi ciency of the procedures described below either for the purpose for wh ich 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 dis bursement . records entries, noting no differences;
- 2) Compared the Total Revenue amount reported on the Annual Audited Report Form X- 17 A-5 Part Ill for the year ended December 31,20 19 with the Total Revenue amount reported in Form SIPC-7 for the year ended December 31, 20 19, noting no d ifferences;
- 3) Compared any adjustments reported in Form SIPC-7 with supporting schedules and working pape rs, noting no differences;
- 4) Recalculated the arithmetical accuracy of the calculations refl ected in Form SIPC-7 and in the related schedules and working papers supporting the adjustments, 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 Clearsight Capital Advisors, Inc.'s campi iance with the applicable instructions of the Form SIPC-7 for the year ended December 3 1, 2019. Accordingly, we do riot express such an opinion or conclusion. Had we perfonned additional procedures, other matters might have come to our attention that would have been reported to you.
This report is intended solely for the mnformation and use of Clearsight Capital Advisors, Inc. and the SIPC and is not intended to be and should not be used by anyone other than these specified parties.
February I 0, 2020 Atlanta, GA
~ c""'~ ~ t:--
Rubio CPA, PC
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| SIPC-7 | |
|----------------|--|
| (36·REV 12/18) | |
SECURITIES INVESTOR PROTECTION CORPORATION P.O. Box 92185 Washington, D.C. 20090-2185 202-371·8300
#### General Assessment Reconciliation
**SIPC-7** (36-REV 12/18)
For the fiscal year ended ~!~~/1 ----
(Read carefully the instructions in your Working Copy before completing this Form)
#### TO BE FILED BY ALL SIPC MEMBERS WITH FISCAL YEAR ENDI NGS
1. Name of Member, address, Designated Examiming Authority, 1934 Act registration no. and month in which fiscal year ends for purposes of the audit requirement of SEC Rule 17a·5:
| lo68998
CLEARSIGHT CAPITAL ADVISORS, INC
1650 TYSONS BLVD, SUITE 220 | | | Note: If any of the information shown on the
mailing label requires correction, please e-mail
any corrections lo form@sipc.org and so
indicate on the form filled. | |
|----------------------------------------------------------------------------------------------------------------------|---------------------|----|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|
| MCLEAN, VA 22102 | | | Name and telephone number of person to
contact respecting this form. | |
| L | _j | | Rick Alvarez 770-263-7300 | |
| 2. A. General Assessment (item 2e from page 2) | | | | |
| B. Less payment made with SIPC-6 filed (exclude interest)
7/25/19 | | | ( 5,430 | |
| Date Paid | | | | |
| C. Less prior overpayment applied | | | | |
| D. Assessment balance due or (overpayment) | | | 0 | |
| E. Interest computed on late payment (see instruction E) for ______ days at 20% per annum | | | 0 | |
| F. Total assessment balance and interest due (or overpayment carried forward) | | | | |
| G. PAYMENT: --J the box
Check mailed to P.O. Box D Funds Wiired D
AcHD
0
Total (must be same as F above) | \$ ________________ | __ | | |
| \$( 0
H. Overpayment carried forward | | | | |
| 3. Subsidiaries (S) and predecessors (P) includ ed in th is form (give name and 1934 Act registration number): | | | | |
| The SIPC member submitting this form and the
person by whom il is executed represent thereby
that all information contained herein is true, correct | CLEARSIGHT CAPITAL ADVISORS, INC | | |
|-----------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------|--|--|
| and complete. | | | |
| Dated the l"?. day of 3M«~1 , 20 zd . | | | |
| | | | |
| for a period of not less than 6 years, the latest 2 years In an easi ly accessible place. | This form and the assessment payment is due 60 days after the end of the fiscal year. Retain the Working Copy of thi s form | | |
| LLI
31:
LLI | c:::: Dates: | Postmarked | Recei ved | Reviewed | |
|-------------------|------------------|---------------------------------|-----------|---------------|--------------|
| > | LLI Calculations | | | Documentation | Forward Copy |
| c:::: | (.;I Exceptions: | | | | |
| a | | Cl) Dispositio n of exceptions: | | | |
{18}------------------------------------------------
#### **DETERMINATION OF "SIPC NET OPERATING REVENUES" AND GENERAL ASSESSMENT**
| | | | ___
Amounts for the fiscal period
beginning :1.:; 11;.: 11:.;:9;__
__
_ |
|--------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------|-------------------------------------------------------------------------------------|
| | | | and ending 1 zl 3.u.1, 19.____
_ |
| Item No. | 2a. Total revenue (FOCUS Line 12/Part IIA Line 9, Code 4030) | | Eliminate cents
\$3.620,000 |
| 2b. Additions: | (1) Total revenues from the securities business of subsidiaries (except foreign subsidiaries) and
predecessors not included above. | | |
| | {2) Net loss from principal transactions in securities in trading accounts. | | |
| | (3) Net loss from principal transactions in commodities in trading accounts. | | |
| | (4) Interest and dividend expense deducted in determining 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 and legal fees deducted in determining net
profit from management of or participation in underwriting or distribution of securities. | | |
| | (7) Net loss from securities in investment accounts. | | |
| | Tot.al additions | | 0 |
| 2c. Deductions: | (1) Revenues from the distribution of shares of a registered open end investment company or unit
investment trust, from the sale of variable annuities, from the business of insurance, from investment
advisory services rendered to registered investment companies or insurance company separate
accounts , and from transactions in security futures products. | | |
| | (2) Revenues from commodity transactions. | | |
| | (3) Commissions, floor brokerag1e and clearance paid to other SIPC members in connection with
securities transactions. | | |
| | (4) Reimbursements for postage in connection with proxy solicitation. | | |
| | (5) Net gain from securities in investment accounts. | | |
| | (6) 100% of commissions and markups earned from transactions in (i) certificates of deposit and
(ii) Treasury bills, bankers acceptances or commercial paper that mature nine months or less
from issuance date. | | |
| | (7) Direct extpenses of printing advertising and legal fees incurred in connection with other revenue
related to the securities business (revenue defined by Section 16(9)(L) of the Act). | | |
| | (B) Other revenue not related ei ther directly or indirectly to the securities business.
(See Instruction C): | | |
| | (Deductions in excess of \$100,000 require documentation) | | |
| | {9) (i) Total interest and dividend expense (FOCUS Line 22/PART IIA Line 13,
Code 4075 plus line 2b(4) above) but not in excess
of total interest and dividend income. | ·---~~~~~--- | |
| | (ii) 40% of margin interest earned on customers securities
accounts (40% of FOCUS line 5, Code 3960). | \$ ________________ ___ | |
| | Enter the greater of line (i) or (ii) | | 0 |
| | Total deductions | | 0 |
| | 2d. Sl PC Net Operating Revenues | | \$3,620,000 |
| 2e. General Assessment @ .0015 | | \$5,430 | |
| | | | (to page 1, line 2.A.) |
Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.