# FIRST CRAFT SECURITIES, LLC X-17A-5 (2020-02-05) — Broker-dealer annual report

- Company: FIRST CRAFT SECURITIES, LLC
- Form: X-17A-5
- Filed: 2020-02-05
- Period: 2019-12-31
- Accession: 0001534667-20-000001
- CIK: 1534667
- File #: 8-69006
- Material weakness: No
- Auditor: AJSH & Co LLP
- Auditor location: New Delhi, K7
- Contact: Daniel Conway
- Phone: 818-272-8890
- Signed by: Daniel Conway (Managing Partner)

Original filing: https://www.sec.gov/Archives/edgar/data/1534667/000153466720000001/newfaudit.pdf

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**UNITEDSTATES SECURITIESANDEXCHANGECOMMISSION Washington, D.C. 20549** 

### **ANNUAL AUDITED REPORT FORM X-17A-5 PART Ill**

| Expires: | August 31, 2020           |  |  |
|----------|---------------------------|--|--|
|          | Estimated average burden  |  |  |
|          | hours per resoonse  12.00 |  |  |
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SEC FILE NUMBER e- 69006

0MB APPROVAL 0MB Number: 3235-0123

**FACING PAGE** 

**Information Required of Brokers and Dealers Pursuant to Section 17 of the Securities Exchange Act of 1934 and Rule l 7a-5 Thereunder** 

| REPORT FOR THE PERIOD BEGINNING                                                                      | __________<br>01/01/19                                              | AND ENDING | _________<br>12/31/19<br>_     |
|------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------|------------|--------------------------------|
|                                                                                                      | MM/DD/YY                                                            |            | MM/DD/VY                       |
|                                                                                                      | A. REGISTRANT IDENTIFICATION                                        |            |                                |
| NAME OF BROKER-DEALER: First Craft Securities, LLC                                                   |                                                                     |            | OFFICIAL USE ONLY              |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.)<br>16133 Ventura Blvd., Suite 1080 |                                                                     |            | FIRM 1.0. NO.                  |
| Encino                                                                                               | (No and Street)<br>CA                                               |            | 91436                          |
| (City)                                                                                               | (State)                                                             |            | (Zip Code)                     |
| NAME AND TELEPHONE NUMBER OF PERSON TO CONT ACT IN REGARD TO THIS REPORT<br>Daniel Conway            |                                                                     |            | 818-272-8890                   |
|                                                                                                      | B. ACCOUNT ANT IDENTIFICATION                                       |            | (Arca Code - Telephone Number) |
| INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report•<br>AJSH & Co LLP            | ( Name - if 1ndi1'1dual stale las/, flrsr. middle name)             |            |                                |
| C-7 /227, Sector-?                                                                                   | Rohini, New Delhi-110085                                            |            | India                          |
| (Address)                                                                                            | (City)                                                              | (Statcl    | (Zip Code)                     |
| CHECK ONE:<br>certified Public Accountant<br>~Public Accountant                                      |                                                                     |            |                                |
|                                                                                                      | Accountant not resident in United States or any of its possessions. |            |                                |
|                                                                                                      | FOR OFFICIAL USE ONLY                                               |            |                                |
|                                                                                                      |                                                                     |            |                                |
|                                                                                                      |                                                                     |            |                                |

*\*Claims for exemption ji·om 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 2-IO. I 7a-5(e)(2)* 

SEC 1410 (11-05)

**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 valld 0MB control number.** 

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#### **OATH OR AFFIRMATION**

| 1, Daniel Conway                                                                                                               | , swear (or affirm) that, to the best of                                                                                                                                             |
|--------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| ------------------<br>First Craft Securities, LLC                                                                              | my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of<br>--------------------                                              |
| ------<br>of December 31                                                                                                       | -<br>, as<br>20 19                                                                                                                                                                   |
|                                                                                                                                | are true and correct. I further swear (or affirm) that<br>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:                                                                    |                                                                                                                                                                                      |
|                                                                                                                                |                                                                                                                                                                                      |
| None.                                                                                                                          |                                                                                                                                                                                      |
|                                                                                                                                |                                                                                                                                                                                      |
|                                                                                                                                |                                                                                                                                                                                      |
|                                                                                                                                |                                                                                                                                                                                      |
|                                                                                                                                |                                                                                                                                                                                      |
|                                                                                                                                |                                                                                                                                                                                      |
|                                                                                                                                | Managing Partner                                                                                                                                                                     |
|                                                                                                                                | Title                                                                                                                                                                                |
| See attachment.                                                                                                                |                                                                                                                                                                                      |
| Notary Public                                                                                                                  |                                                                                                                                                                                      |
| This report•• contains (check all applicable boxes):                                                                           |                                                                                                                                                                                      |
| 0 (a) Facing Page.                                                                                                             |                                                                                                                                                                                      |
| ~ (b) Statement of Financial Condition.                                                                                        |                                                                                                                                                                                      |
|                                                                                                                                | [a (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).<br>(d) Statement of Changes in Financial Condition.<br>., |                                                                                                                                                                                      |
| (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 I 5c3-3.                                            |                                                                                                                                                                                      |
| (i) Information Relating to the Possession or Control Requirements Under Rule 15c3-3.<br>~                                     | 0 (j) A Reconciliation, including appropriate explanation of the Computation ofNet Capital Under Rule 15c3-1 and the                                                                 |
| Computation for Determination of the Reserve Requirements Under Exhibit A of Rule I 5c3-3.                                     |                                                                                                                                                                                      |
|                                                                                                                                | 0 (k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of                                                                |
| consolidation.                                                                                                                 |                                                                                                                                                                                      |
| (I) An Oath or Affirmation.                                                                                                    |                                                                                                                                                                                      |
| (m) A copy of the SIPC Supplemental Report.                                                                                    |                                                                                                                                                                                      |
| ~                                                                                                                              | (n) 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 2-I0. / 7a-5(e)(3).                |                                                                                                                                                                                      |

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# **CALIFORNIA JURAT WITH AFFIANT STATEMENT** GOVERNMENT CODE § 8202 ~ u **~e=~oAJ BeOl8l! 80d.8P+ifl811il~.\_.!8l\$1** s EE 9W

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to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document.

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proved to me on the basis of satisfactory evidence to be the person(gj who appeared before me.

Place Notary Seo/ and/or Stomp Above

**MARIA** VALLE

< Los Angeles County <sup>~</sup> <sup>i</sup>Commission# 2173941 <sup>~</sup>**l .** *4 4* • **<sup>4</sup> Ml :oT"]; tx~rea5 gei 2J** ,}~<sup>2</sup>

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| • _____ _<br>Signature ---~/,_/4,~'--/<br>:-{- _____ |  |
|------------------------------------------------------|--|
| Signature of Notary Public                           |  |

**,-----------------OPTIONAL -----------------,** 

Signature of Document Signer No. 1 Signature of Document Signer No. 2 (if any)

A notary public or other officer completing this certificate verifies only the identity of the individual who signed the document

Completing this information con deter alteration of the document or fraudulent reattachment of this form to on unintended document.

| Description of Attached Document  |                                                                                 |                                    |                |
|-----------------------------------|---------------------------------------------------------------------------------|------------------------------------|----------------|
| Title or Type of Document: ____   | _Q~cct~\,,~-OC~_f'trf  -~-                                                      | ~1f_lV'l_o._,f_l o_'1 ____________ | _              |
| Document Date: ----~i>ec.         | 1 ~-'.G-·VV'l --i?c~~-C->_l_,2:>_'D_\_'1 ____ Number of Pages: ___ -;L ______ _ |                                    |                |
| Signer(s) Other Than Named Above: | ___________                                                                     | ,                                  | _________<br>_ |

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# First Craft Securities, LLC

Annual Audit Report

December 31, 2019

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## **First Craft Securities, LLC December 31, 2019**

### **Table of Contents**

| Report of Independent Registered Public Accounting Firm                                                                  | 1-2 |  |
|--------------------------------------------------------------------------------------------------------------------------|-----|--|
| Financial Statements:                                                                                                    |     |  |
| Statement of Financial Condition                                                                                         | 3   |  |
| Statement of Operations                                                                                                  | 4   |  |
| Statement of Changes in Member's Equity                                                                                  | 5   |  |
| Statement of Cash Flows                                                                                                  | 6   |  |
| Notes to the Financial Statements                                                                                        | 7-9 |  |
| Supplemental Information:                                                                                                | 10  |  |
| Schedule I:                                                                                                              | 11  |  |
| Computation of Net Capital Under Rule 15c3-1<br>of the Securities and Exchange Commission                                |     |  |
| Reconciliation with Company's Net Capital Computation                                                                    |     |  |
| Schedule II:                                                                                                             |     |  |
| Computation to Determination of Reserve Requirements<br>Under Rule 1Sc3-3 of the Securities and Exchange Commission      |     |  |
| Information Relating to Possession or Control Requirements<br>Under Rule lSc-3 of the Securities and Exchange Commission |     |  |
| Report of the Independent Registered Public Accounting Firm on<br>Exemption report                                       | 13  |  |
| SEA 15c3-3 Exemption Report                                                                                              | 14  |  |
| Report of Independent Registered Public Accounting Firm on Applying<br>Agreed-Upon Procedures                            | 15  |  |

SIPC7

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![](_page_5_Picture_0.jpeg)

#### Report of the Independent Registered Public Accounting Firm

To the Members of First Craft Securities, LLC

#### Opinion on **the Financial statements**

We have audited the accompanying statement of financial condition of First Craft Securities, LLC (the "Company") as of December 31, 2019, and the related statements of operations, changes ln 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, 2019, and the results of its operations and its cash flows for the year then ended, in conformity with accounting principles generalfy accepted m 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 fmancial statements based on our audit. We are a publ c 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 m 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 bel eve that our audit provide a reasonable basis for our opinion.

#### **Supplementary Information**

The supplementary information contained in Schedule I • Computation of Net Capital pursuant to Uniform Net Capital Rule 15c3-1 of Securities and Exchange Commission has been subjected to audit procedures performed in conjunction with the audit of Company's financial statements. The supplemental information is the responsibility of the Company'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.

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![](_page_5_Picture_12.jpeg)

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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 CFR § 240.17a-5. ln our opinion, the supplemental information Is fairly stated, in all material respects, in relation to the financial statements **as a** whole.

**AJSH& CollP** 

We have served as the-Company's Auditor since 2018.

New Delhi, India February 03, 2020

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### **First Craft Securities, LLC**

### **Statement of Financial Condition December 31, 2019**

| Assets                                |                 |  |
|---------------------------------------|-----------------|--|
| Cash and cash equivalents             | \$<br>1,183,480 |  |
| Prepaid expense                       | \$<br>1,286     |  |
| Total Assets                          | \$<br>1,184,766 |  |
|                                       |                 |  |
| Liabilities and Member's Equity       |                 |  |
| Liabilities                           |                 |  |
| Accounts Payable                      | \$<br>6,611     |  |
| Accrued Payroll Expenses              | \$<br>319       |  |
|                                       |                 |  |
| Total Liabilities                     | \$<br>6,930     |  |
| Member's Equity                       | \$<br>1,177,836 |  |
| Total Liabilities and Member's Equity | \$<br>1,184,766 |  |

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### **First Craft Securities, LLC**

### **Statement of Operations For the Year Ended December 31, 2019**

| Revenue                  |                 |
|--------------------------|-----------------|
| Investment banking fees  | \$<br>1,307,107 |
| Total Revenue            | \$<br>1,307,107 |
| Expenses                 |                 |
| Commission expense       | \$<br>249,829   |
| Payroll expenses         | \$<br>95,186    |
| Accounting fees          | \$<br>5,500     |
| Taxes and licenses       | \$<br>6,550     |
| Regulatory fees          | \$<br>4,715     |
| Other operating expenses | \$<br>1,976     |
| Total Expenses           | \$<br>363,756   |
| Net Income               | \$<br>943,351   |

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# **First Craft Securities, LLC Statement of Changes in Member's Equity For the Year Ended December 31, 2019**

| December 31, 2019 | \$<br>1,177,836 |
|-------------------|-----------------|
| Withdrawals       | \$<br>(329,913) |
| Net income        | \$<br>943,351   |
| December 31, 2018 | \$<br>564,398   |

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# First Craft Securities, LLC Statement of Cash Flows For the Year Ended December 31, 2019

| Cash Flows from Operating Activities                                   |    |           |  |
|------------------------------------------------------------------------|----|-----------|--|
| Net income                                                             | \$ | 943,351   |  |
| Adjustments to reconcile net income<br>to net cash used in activities: |    |           |  |
| (Increase) decrease in:                                                |    |           |  |
| Prepaid expense                                                        | \$ | 346       |  |
| Increase (decrease) in:                                                |    |           |  |
| Accounts payable                                                       | \$ | 745       |  |
| Accrued Payroll Expenses                                               | \$ | 319       |  |
| Net Cash from Operating Activities                                     | s  | 944,761   |  |
| Cash Flows from Financing Activities                                   |    |           |  |
| Withdrawals                                                            | \$ | (329,913) |  |
| Net Cash from Financing Activities                                     | \$ | (329,913) |  |
| Net Increase In Cash and Cash Equivalents                              | s  | 614,848   |  |
| Cash and cash equivalents at beginning of year                         | \$ | 568,632   |  |
| Cash and Cash Equivalents at End of Vear                               | \$ | 1,183,480 |  |

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### **First Craft Securities, LLC Notes to the Financial Statements December 31, 2019**

#### **1. Organization**

First Craft Securities, LLC (the "Company") was organized as a Delaware limited liability company on May 13, 2011, and was registered with the Securities and Exchange Commission as a securities broker dealer on February 21, 2013. The Company is owned by its sole member, Craft Partners, LLC (the "Member") and operates in Encino, California. The Company provides financial advisory and related services.

#### **2. Significant Accounting Policies**

#### **Basis of presentation**

The summary of significant accounting policies presented below is designed to assist in understanding the Company's financial statements. These accounting policies conform to accounting principles generally accepted in the United States of America. ("GAAP") in all material respects, and have been consistently applied in preparing the accompanying financial statements.

#### **Cash and Cash Equivalents**

The Company considers all demand deposits held in banks and certain highly liquid investments with original maturities of three months or less, other than those held for sale in the ordinary course of business, to be cash equivalents.

#### **Revenue**

The revenue recognition guidance of ASC Topic 606, Revenue from Contracts with Customers, requires that an entity recognize revenue to depict the transfer of 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. The guidance requires an entity to follow a five-step model to (a) identify the contract(s) with a customer, (b) identify the performance obligations in the contract, (c) determine the transaction price, (d) allocate the transaction price to the performance obligations in the contract, and (e) recognize revenue when (or as) the entity satisfies a performance obligation. In determining the transaction price, an

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entity may include variable consideration only to the extent that it is probable that a significant reversal in the amount of cumulative revenue recognized would not occur when the uncertainty associated with the variable consideration is resolved. 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.

Investment banking fees are earned from providing financial advisory services to clients. Revenue is recognized when earned either by fee contract or the success of a predetermined specified event and collection is reasonably determinable.

#### **Use of Estimates**

The preparation of financial statements in accordance 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 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 and may have an impact on future periods.

#### **Fair Value of Financial Instruments**

Unless otherwise indicated, the fair values of all reported assets and liabilities that represent financial instruments (none of which are held for trading purposes) approximate the carrying values of such amounts.

#### **Income Taxes**

The Company is a single member limited liability company and is treated as a disregarded entity for tax purposes. In lieu of income taxes, the Company passes 100% of its taxable income and expenses to its sole member. Therefore, no provision or liability for federal or state income taxes is included in these financial statements. The Company is however, subject to annual California and Delaware LLC taxes.

#### **3. Recently Issued Accounting Pronouncements**

There were no new accounting pronouncements during the year ended December 31, 2019 that we believe would have a material impact on our financial position or results of operations.

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#### **4. Net Capital Requirements**

The Company is subject to the Securities and Exchange Commission's uniform net capital Rule 15c3-1 of Securities and Exchange Act, which requires the Company to maintain, at all times, a minimum net capital equal to or greater than \$5,000 and a ratio of aggregate indebtedness to net capital not exceeding 15 to 1, both as defined. At December 31, 2019, the Company's net capital was \$1,176,550 which exceeded the requirement by \$1,171,550. Aggregate indebtedness at December 31, 2019 totaled \$6,930. The Company's percentage of aggregate indebtedness to net capital was 0.6%.

#### **5. Risk Concentration**

For the year ended December 31, 2019, approximately 72% of the Company revenue was earned from two clients. The Company's cash consists of cash held at one financial institution where the balance of the account may exceed government insurance limits during the year.

#### **6. Related Party Transactions**

Pursuant to a management expense sharing agreement, effective January 1, 2019, between the Member and the Company, Member pays overhead expenses of the Company including rent, office equipment and supplies, insurance, salaries and expenses of the directors, subscriptions and other administrative and overhead expenses. The Company is not obligated to reimburse Member. The Company's results of operations and financial position could differ significantly from those that would have been obtained if the entities were autonomous.

#### **7. Subsequent Events**

There were no subsequent events through February 03, 2020, the date which the financial statements were issued.

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#### **SUPPLEMENTAL INFORMATION**

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# **First Craft Securities, LLC Schedule** I

### **Computation of Net Capital Under Rule 15c3-1 As of December 31, 2019**

| Net Capital                                                                                                        |                 |
|--------------------------------------------------------------------------------------------------------------------|-----------------|
| Total member's equity                                                                                              | \$<br>1,177,836 |
| Less: Non-allowable assets:                                                                                        |                 |
| Prepaid expense                                                                                                    | 1,286           |
| Net Capital                                                                                                        | \$<br>1,176,550 |
| Net minimum capital requirement of 6 2/3% of aggregate<br>indebtedness of \$6,930 or \$5,000, whichever is greater | 5,000           |
| Excess Net Capital                                                                                                 | \$<br>1,171,550 |
|                                                                                                                    |                 |

### **Reconciliation with Company's Net Capital Computation (Included in Part** II **of Form X-17A-5 as of December 31, 2019)**

There were no material differences noted in the Company's net capital computation at December 31, 2019.

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# **First Craft Securities, LLC Schedule** II

# **Computation for Determination of Reserve Requirements Under Rule 15c3-3 of the Securities and Exchange Commission For the Year Ended December 31, 2019**

An exemption from Rule 15c3-3 is claimed, based on section (k)(2)(i). All transactions are processed in accordance with Rule 15c3-l(a)(2).

# **Information Relating to Possession or Control Requirements Under Rule 15c3-3 of the Securities and Exchange Commission For the Year Ended December 31, 2019**

An exemption from Rule 15c3-3 is claimed, based on section (k)(2)(i). The Company did not maintain possession or control of any customer funds or securities.

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C-7/227, Sectnr-7, Rohlni New Dclhi-110085 +9111 45596689 Web : www.ajsh.in E-mail : lnfo(ti:ajsh.in

Report of Independent Registered Public Accounting Firm

To the Members of **First Craft Securities,** LLC

We have reviewed management's statements, included in the accompanying First Croft Securities, LLC's Exemption Report, In whk h (1) First Craft Securities, LLC identified the following provisions of 17 C.F.R. §15c3·3(kl under which the Company claimed an exemption from 17 C.F.R. §240.lSc:3·3: fk)(2)(i) (the "exemption provisions") ahd 12) the Company stated that they met the Identified exemption provisions thcoughout the most recent fiscal year without exception. The Company's management is responsible for compliance with the exemption provlslons 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 e,cemption provisions. **A review** Is substantlatly less in scope than an examlnation, the objective of which is the expression of an opinion on management<sup>1</sup> 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 he fairly stated, in all material respects, basl?d on the provisions set forth in paragraph (k)(2)(1) of Rule 15c3-3 under the Securnies Exchange Act of 1934.

~6\~~:

**AJSH** & Co LLP

New Delhi, India February 03, 2020

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FIRST CRAFT SECURITIES, LLC

### **SEA 15c3-3 Exemption Report**

I, Daniel S. Conway, managing partner of First Craft Securities, LLC (the "Company") represent the following:

- 1. The Company claims the k(2)(i) exemption from 17 C.F.R. §240.1Sc3-3;
- 2. The Company met the identified exemption provisions in 17 C.F.R. §240.15c3-3(k) throughout the most recent fiscal year as of December 31, 2018 without exception; and
- 3. There were no exceptions during the most recent fiscal year in meeting the identified exemption provisions in 17 C.F.R. §240.15c3-3(k).

I affirm that, to the best of my knowledge and belief, the Exemption Report is true and correct. The Company does not handle cash or securities on behalf of customers.

Respectfully submitted,

Daniel S. Conway February 03, 2020

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**Independent** Accountants' Agreed-Upon Procedures Report on Schedule of Assessment and Payment

To the Members of **First Craft Securities,** LLC

In accordance with Rule 17a•S(e)(4) under the Securities Exchange Act of 1934 and SIPC Serles 600 Rules, we have performed the procedures enumerated below with respect to the accompanying General Assessment Reconciliation (Form SIPC-7) to the Securities Investor Protection Corporation ("SIPC") for the year ended December 31, 2019, which were agreed to by First Craft Securities, LLC (the "Company"), and SIPC, solely to assist you and SIPC In evaluating the Company's compliance with the applicable instructions of Form SIPC• 7 for the year ended December 31, 2019. The Company's management is responsible for its compliance with those requirements. This agreed-upon procedures engagement was conducted In accordance with the standards established by the Public Company Accounting Oversight Board (Unites States). The sufficiency of these procedures is solely the responsibility of those parties specified ln this report. Consequently, we make no representation regardlng 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:

- 1. Compared the listed assessment payment in Form SIPC-7 with respective cash disbursement rewrd entries, noting no material differences;
- 2. Compared the amounts reported on the annual audited report Form X•17A·S Part Ill for the year ended December 31, 2019, as applicable, with the amounts reported In Form S1PC· 7 for the year ended December 31, 2019, noting no material differences;
- 3. Compared any adjustments reported in Form SIPC-7 with supporting schedules and working papers, noting no material differences;
- 4. Recalculated the arlthmetlcal accuracy of the calculations reflected in Form SIPC-7 and in the rel.ited schedules and working papers supporting the adjustments, noting no material differences; and
- S. Compared the amount of any overpayment applied to the current assessment with the Form SIPC-7 on which it was originally computed noting no material differences.

We were not **engaged** to, and did not conduct an examination, the objective of which would be the expression of an opinion on compliance with the applicable instructions of Form SIPC-7. Accordingly, we do not express such an opinion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you.

This report ls intended solely for the Information and use of the specified parties listed nbovc and i~ not intended to be ,md should not be used by anyone other than these specified parties..

~~~b7

**AJSH&ColLP New** Deihl, lndla February 03, 2020

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|                                                 |                                                                                         |                                                             | SECURITIES INVESTOR PROTECTION CORPORATION                                                                                                        |                                                                                                              |
|-------------------------------------------------|-----------------------------------------------------------------------------------------|-------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------|
| SIPC-7                                          |                                                                                         | P.O. Box 92185 Washinglon, 0 C. 20090-2185<br>202-3 71-8300 |                                                                                                                                                   | SIPC-7                                                                                                       |
| (36·REV 1211B)                                  |                                                                                         | General Assessment Reconciliation                           |                                                                                                                                                   | (36•REV 12r1a1                                                                                               |
|                                                 |                                                                                         | Fo, the fiscal yu, anded _____<br>12/31/19                  | _                                                                                                                                                 |                                                                                                              |
|                                                 |                                                                                         |                                                             | (Rud c11e1uu, lhe lnstt~llons In ycur \'lorklllil Copy balore com;if1Uno tllis. Fein]<br>TO BE FILED BY ALL SIPC MEMBERS WITH FISCAL YEAR ENDINGS |                                                                                                              |
| 1. Name ol<br>Member                            | add<br>ignated<br>mining<br>Des<br>Exa<br>res&.                                         | Authority                                                   | , 1934 Acl reg!slralion no and monlh In whlc:h llscal yoar onds for                                                                               |                                                                                                              |
| ll<br>ol<br>the aud<br>purposes                 | req<br>ulrem<br>of SEC R<br>ule<br>en1                                                  | 17a•5<br>:                                                  |                                                                                                                                                   | 0 ►                                                                                                          |
| I                                               | First Craft Securities, LLC                                                             |                                                             | 7                                                                                                                                                 | 0<br>U<br>Note II any cl the Information shown on the<br>mailing label requires co11eclion. please e-m3il c, |
|                                                 | 16133 Ventura Blvd., Suite 1080                                                         |                                                             | any correction\$ to lorm@lsipc org a.od so                                                                                                        | z                                                                                                            |
|                                                 | Encino, CA 91436                                                                        |                                                             | indicate on lhe lorm filed                                                                                                                        |                                                                                                              |
|                                                 |                                                                                         |                                                             | Nome and telephone number of person 10                                                                                                            |                                                                                                              |
| L                                               |                                                                                         |                                                             | c:onlact respectlng I tiis torm.<br>_J                                                                                                            |                                                                                                              |
|                                                 |                                                                                         |                                                             |                                                                                                                                                   |                                                                                                              |
|                                                 |                                                                                         |                                                             |                                                                                                                                                   |                                                                                                              |
|                                                 | l. A. General Assessment (llem 2& from page 2)                                          |                                                             | s 1,961                                                                                                                                           |                                                                                                              |
|                                                 | B. Less payment made with SIPC 6 filed (exclude lnlerestj                               |                                                             | I 1,160                                                                                                                                           |                                                                                                              |
| 7/15/19                                         |                                                                                         |                                                             |                                                                                                                                                   |                                                                                                              |
| Dale Pald<br>C. leGs p1ior ove,pa.yment applied |                                                                                         |                                                             |                                                                                                                                                   |                                                                                                              |
|                                                 |                                                                                         |                                                             | 801                                                                                                                                               |                                                                                                              |
|                                                 | 0. Assassr.ient balance due or (overpayment)                                            |                                                             |                                                                                                                                                   |                                                                                                              |
|                                                 | E. Interest computed on late payment (sae mstruct1on E) lor                             | __                                                          | dars at 20% per a11num                                                                                                                            |                                                                                                              |
|                                                 | F. Total asr.essmeot balance and inlerest due {or overpayment carried lorwnrd)          |                                                             | 801                                                                                                                                               |                                                                                                              |
|                                                 | ✓ !he box                                                                               |                                                             |                                                                                                                                                   |                                                                                                              |
| G. PAYUENT:                                     | Check malled lo P.O. Box0 Funds Wired<br>Total (must be same 81 F above)                | □ ACH O 801<br>\$.                                          | _                                                                                                                                                 |                                                                                                              |
|                                                 |                                                                                         | \$(                                                         | _________<br>_                                                                                                                                    |                                                                                                              |
| H. Overpayment carried forward                  |                                                                                         |                                                             | _______                                                                                                                                           |                                                                                                              |
|                                                 |                                                                                         |                                                             | 3. Subsidiaries (5) and predecessors (P) included in this form !give name and 1934 Act registration number I.                                     |                                                                                                              |
|                                                 |                                                                                         |                                                             |                                                                                                                                                   |                                                                                                              |
|                                                 |                                                                                         |                                                             |                                                                                                                                                   |                                                                                                              |
|                                                 | The SIPC member &ubmiltlng this form and tho                                            |                                                             |                                                                                                                                                   |                                                                                                              |
|                                                 | person by whom It Is executed represent thereby                                         |                                                             |                                                                                                                                                   |                                                                                                              |
|                                                 | that all lnlormallon c:onla.ined herein Is true, Ct>rrect                               |                                                             |                                                                                                                                                   |                                                                                                              |
|                                                 |                                                                                         |                                                             |                                                                                                                                                   |                                                                                                              |
| and complate.<br>Dated the 8                    | 20 .20_<br>day 01 January                                                               |                                                             |                                                                                                                                                   |                                                                                                              |
|                                                 |                                                                                         |                                                             | ,,  ,                                                                                                                                             |                                                                                                              |
|                                                 | for• period of not leas than 6 years, the lalest 2 years In an easily acceaslble place. |                                                             | This form and tht 111usment payment Is due 6-0 days alter the end ol lhe llscal year. Relaln lhe Working Copy of this form                        |                                                                                                              |
|                                                 |                                                                                         |                                                             |                                                                                                                                                   |                                                                                                              |
|                                                 |                                                                                         |                                                             |                                                                                                                                                   |                                                                                                              |
| Postmarked                                      | Ree11ived                                                                               | ReVlewttd                                                   |                                                                                                                                                   |                                                                                                              |
| ffi Dates:<br>31:<br>> Calculalions __<br>u.,   | _                                                                                       | Documentation                                               | _                                                                                                                                                 | Forward Copy<br>_                                                                                            |
| LU<br>a:<br>u<br>Excep11ons:                    |                                                                                         | __                                                          |                                                                                                                                                   | ___                                                                                                          |

{21}------------------------------------------------

#### DETERMINATION OF "SIPC NET OPERATING REVENUES" AND GENERAL ASSESSMENT

Amounts lor the llscal period beginning ....., <sup>11111</sup> .,,....•e=,---- and endf1111\_1.:.12.:i@11.:tLl0.11:9 \_\_ \_

| Htm No.                                                                                                                                                                                                                                                                                                                                                                                                       |                       | Ellmln11te cents<br>\$ 1,307,107    |
|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------|-------------------------------------|
| 2a. Tolal man:ia (FOCUS Line 12/Part IIA line 9 Code 4030)                                                                                                                                                                                                                                                                                                                                                    |                       |                                     |
| 2b. Addithms:<br>(1) Tola! te"ttnues lrom the secultles business ol subsidiaries (e,ctpt l011ion subiid arin) and<br>predecessors not iocluded above.                                                                                                                                                                                                                                                         |                       |                                     |
| (2) Net loss lrorn principal t,anuctions in stt11ritlas In tr2dlng aetounts                                                                                                                                                                                                                                                                                                                                   |                       |                                     |
| (3) Net loss lrcrn prlnclpal 111nsac1io1n In can.;111dltl!s In lrading accounts                                                                                                                                                                                                                                                                                                                               |                       |                                     |
| (4) Interest and dividend erptnse deducted In del1rirJ.,i11g Item 2 •.                                                                                                                                                                                                                                                                                                                                        |                       |                                     |
| (5) Hel toss llom 111anagamIn1 of or partlclpatton In the undtmiling er dlstrlbut on ol securltes.                                                                                                                                                                                                                                                                                                            |                       |                                     |
| (6) EX?Gnsas other llnri ad1erlising, printing, reglslralloo lees and leqal IHIS d6ducted In detarmin,r.g 11ft<br>PfOHt lrom mlll4gem1111 of 'Of participation in onderwrltlng 01 d strlb!Jllon ol SKDrltles                                                                                                                                                                                                  |                       |                                     |
| {7) Hel Ion lr01:1 seculities In lnwestiilenl accounts.                                                                                                                                                                                                                                                                                                                                                       |                       |                                     |
| T 0131 additions                                                                                                                                                                                                                                                                                                                                                                                              |                       |                                     |
| 2c. Deductions·<br>(1 ► Rnenues lu11:1 lhe c!lstrlbutlon of slmu ol a registered Optfl end Investment compan,- or unit<br>i:ive;lnitAI trust lroa Ille sale ol varla!llt 1nnullles, born tilt basln s\$ of i:lsaraace lro1111:irast:-:ienl<br>ad,iiorr nnicu rendered to registered lmeslment car.ipaales or Insurance co111pa:1y .separate<br>accounts, and fraci tranuctlans In security lut1:1es produr.ts |                       |                                     |
| (2t Rntnuts lrora commoditr tr1nsacllons.                                                                                                                                                                                                                                                                                                                                                                     |                       |                                     |
| (3) C0r.11nissloM, floor t1okera9e and clmance pild to other SIPC rutn:!lers in connection with<br>stetirl!les transactiDni.                                                                                                                                                                                                                                                                                  |                       |                                     |
| <•J Rel::lbursemenls for posta;t in cormecllon wf:11 pr'ary sollcltallon                                                                                                                                                                                                                                                                                                                                      |                       |                                     |
| 151 Net gain from securities In ln,ut.i:tnl aCC011nts.                                                                                                                                                                                                                                                                                                                                                        |                       |                                     |
| (6) 100,, ol com:ruul0u a11d 11111tu;,s earned 1to111 traasacUo.is l:l (rJ c&rtilicales ot deposit ;ind<br>(iii Treasury blils, banttrs acceptances or c0mmerclal paper 11111 cialure nl:it IIIO!llhs 01 less<br>lrom lsstJance date.                                                                                                                                                                         |                       |                                     |
| (7) Direct erpense.s ol prl.,thrg ad'lertisillg and legal ltts 1ncu11ed in cCMect~n wltll other rnenaa<br>related to \ht securities tuslne55 (mer.ut delfned bf Stclion 16(9t(L) al the Act).                                                                                                                                                                                                                 |                       |                                     |
| 18) Olber revenue not rvlated either directly Of Indirectly 10 the saeuriUts busin&Si<br>(Se& IM:m~ C):                                                                                                                                                                                                                                                                                                       |                       |                                     |
| (Oeduclions in ucess of S t00,000 rtq?.rlre docur11111t1Uon)                                                                                                                                                                                                                                                                                                                                                  |                       |                                     |
| {9) (i) Total iRlerest and dMttnd 11penst (FOCUS Line 22/PART IIA Line 13,<br>Code ~075 pl&:a Ont 2b(4) abou) but nol l:1 ercess<br>ol total inltrtsl and dividend lnco:a.                                                                                                                                                                                                                                    | _________<br>_<br>\$, |                                     |
| {Ii) 40% ol margin inl1r1st earned on customers securllles<br>ICCl)OAls (4K of FOCUS line 5, Code 3960).                                                                                                                                                                                                                                                                                                      | _________<br>_<br>\$, |                                     |
| Enter the greater ol lina (I) or (ii)                                                                                                                                                                                                                                                                                                                                                                         |                       |                                     |
| i olal dtductlon!                                                                                                                                                                                                                                                                                                                                                                                             |                       | ________                            |
| 2d. SIPC Net Operating Roenues                                                                                                                                                                                                                                                                                                                                                                                |                       | 1,307,107<br>_<br>\$,<br>s ________ |
| 21. Geaeral Assessment I@ .0015                                                                                                                                                                                                                                                                                                                                                                               |                       | _<br>1,961                          |
|                                                                                                                                                                                                                                                                                                                                                                                                               |                       | (to page 1 line 2 A I               |

2


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