# SPEYSIDE ADVISORS, LLC X-17A-5 (2021-03-01) — Broker-dealer annual report - Company: SPEYSIDE ADVISORS, LLC - Form: X-17A-5 - Filed: 2021-03-01 - Period: 2020-12-31 - Accession: 0001717927-21-000001 - CIK: 1717927 - File #: 8-70023 - Material weakness: No - Auditor: McBee & Co., P.C. - Auditor location: Dallas, TX - Contact: Daniel Gillett - Phone: 214-228-8732 - Website: mcbeeco.com - Signed by: Daniel Gillett (Sole Member) Original filing: https://www.sec.gov/Archives/edgar/data/1717927/000171792721000001/speyside2020audit.pdf --- {0}------------------------------------------------ UNITEDSTATES SECURITIESANDEXCHANGECOMMISSION Washington, D.C. 20549 OMB APPROVAL 0MB Number 3235-0123 Expires: October 31,2023 Estimated average burden ### hoursperresponse. 12.00 **ANNUAL AUDITED REPORT FORM X-17A-5 PART III** **SEC FILE NUMBER a-290234** 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 | 01/01/20 | AND ENDING | 12/31/20 | | |----------------------------------------------------------------------------|--------------------------------------------------------------------------|-------------------|-----------------------------------|--| | | MM/DD/YY | | MM/DD/YY | | | | A.
IDENTIFICATION
REGISTRANT | | | | | Advisors,
NAME OF BROKER-DEALER:Speyside
LLC | | OFFICIAL USE ONLY | | | | Box No.)
ADDRESS OF PRINCIPAL PLACE OF BUSINESS:
not use P.O.
(Do | | | FIRM I .D. NO. | | | Ave.,
1910
Pacific | 5060
Ste | | | | | | (No.
and Street) | | | | | Dallas | Texas | | 75201 | | | (City) | (State) | | (Zip Code) | | | Daniel Gillett | NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT | | 214-228-8732 | | | | | | (Area Code -
Telephone Number) | | | | B.
ACCOUNTANT | IDENTIFICATION | | | | | INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report* | | | | | Co.,
McBee
PC
& | | | | | | | (Name -if
individual, state last, first, middle name ) | | | | | 718
Paulus | Dallas | Texas | 75209 | | | (Address) | (City) | (State) | (Zip Code) | | | ONE:
CHECK | | | | | | /
Certified Public Accountant | | | | | | Public Accountant | | | | | | Accountant not resident in United | States
or any of | its possessions. | | | | | OFFICIAL
USE
FOR | 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 offacts 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 containedinthis form arenotrequiredto respond SEC 1410 (11-05) unless the formdisplays a currently validOMB controlnumber.** {1}------------------------------------------------ #### **OATH OR AFFIRMATION** | Daniel
Gillett
I, | swear (or affirm) that,
,
to the best of | |-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Advisors,
LLC
Speyside | my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of
,
as | | 31
0f
December | ,
,
0
are true and correct.
I further swear (or
affirm) that
20 | | proprietor,
neither the company nor any partner,
as that of a customer,
classified solely | ^
has any proprietary interest in any account
principal officer or director
except as follows: | | | /
2
/7
3
Signature | | | Sole
Member | | 1/
Notary Public
applicable boxes):
**
contains (check all
This report
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Financial Condition.
(b)
Statement of
7\
Income (Loss) or,
(c) Statement
of
if there
of Comprehensive Income (as
defined in
Financial Condition.
(d) Statement of Changes in
Changes in Stockholders'
(e) Statement of
__ (f)
Statement of Changes in
Net Capital.
(g) Computation
of
(h)
£
Computation for Determination of
(i) Information
Relating to the Possession or Control
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§210.1-02
Equity or Partners' or Sole Proprietors' Capital.
Claims of Creditors.
Liabilities Subordinated to
Reserve Requirements Pursuant to Rule 15c3-3.
Rule 15c3-3.
Requirements Under | | ZJ (j)
A Reconciliation,
including appropriate explanation of the | Net Capital Under Rule 15c3-l
Computation of
and the
Computation for Determination of the Reserve Requirements Under Exhibit A of Rule 15c3-3. | |
(k ) A Reconciliation between the audited and unaudited Statements of | Financial Condition with respect to methods of | | consolidation. | | | Oath or Affirmation.
(l) An
§
the SIPC Supplemental Report.
(m) A copy of
(n) A
report describing any material inadequaciesfound | the date of the previous audit.
to exist or found
to have existed since | *\*\*For conditions of confidential treatment of certain portions of this filing, see section 240.17a-5(e)(3).* {2}------------------------------------------------ **SPEYSIDE ADVISORS, LLC REPORT PURSUANT TO RULE I 7a-5(d) YEAR ENDED DECEMBER 31, 2020** {3}------------------------------------------------ #### **SPEYSIDE ADVISORS, LLC** #### CONTENTS | REPORT
OF
INDEPENDENT
REGISTERED
PUBLIC
ACCOUNTING
FIRM | | 1 | |---------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------|------| | STATEMENTS
FINANCIAL | | | | of
Statement
financial
condition | | 2 | | of
Statement
operations | | 3 | | member's
of
Statement
changes
equity
in | | 4 | | of
Statement
cash
flows | | 5 | | Notes
to
financial
statements | | 6-8 | | Supporting
Schedules | | | | I:
Schedule | 15c3-l
Computation
of
Capital
Under
Rule
Net
of
the
Securities
and
Exchange
Commission | 9-10 | | Schedule
II: | Computation
for
of
Determination
Reserve
15c3-3
Requirements
Under
of
the
Securities
Rule
and
Exchange
Commission | 1 1 | | OF
REPORT
INDEPENDENT
MANAGEMENT'S
ON | REGISTERED
ACCOUNTING
PUBLIC
FIRM
EXEMPTION
REPORT | 12 | | BROKER-DEALER
ANNUAL
EXEMPTION
REPORT | | 13 | {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) A Professional Corporation Certified Public Accountants #### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** ### **To the Managing Member of Speyside Advisors, LLC** #### **Opinion on the Financial Statements** We have audited the accompanying statement of financial condition of Speyside Advisors, LLC as of December 31, 2020, the related statements of operations, changes in member's equity, and cash flows for the year then ended, and the related notes (collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of Speyside Advisors, LLC as of December 31, 2020, and the results of its operations and its cash flows for the year then ended in conformity with accounting principles generally accepted in the United States of America. #### **Basis for Opinion** These financial statements are the responsibility of Speyside Advisors, LLC's management. Our responsibility is to express an opinion on Speyside Advisors, LLC's financial statements based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) ("PCAOB") and are required to be independent with respect to Speyside Advisors, LLC in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion. #### **Auditor's Report on Supplemental Information** The supplemental information contained in Schedule I, Computation of Net Capital Under Rule 15c3-lof the Securities and Exchange Commission and Schedule II, Computation for Determination of Reserve Requirements Under Rule 15c3-3 of the Securities and Exchange Commission has been subjected to audit procedures performed in conjunction with the audit of Speyside Advisors, LLC's financial statements. The supplemental information is the responsibility of Speyside Advisors, LLC's management. Our audit procedures included determining whether the supplemental information reconciles to the financial statements or the underlying accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the supplemental information. In forming our opinion on the supplemental information, we evaluated whether the supplemental information, including its form and content,is presented in conformity with 17 C.F.R. §240.17a-5. In our opinion, the supplemental information contained in Schedule I, Computation of Net Capital Under Rule 15c3-lof the Securities and Exchange Commission and Schedule II, Computation for Determination of Reserve Requirements Under Rule 15c3-3 of the Securities and Exchange Commission is fairly stated, in all material respects,in relation to the financial statements as a whole. *'ll) .* **McBee & Co., PC** We have served as Speyside Advisors, LLC's auditor since 2017. Dallas, Texas February 24, 2021 718 Paulus Avenue • Dallas, Texas 75214 • (ph) 214.823.3500 • www.mcbeeco.com **Dallas | Keller/Southlake** {5}------------------------------------------------ ### **SPEYSIDE ADVISORS, LLC STATEMENT OF FINANCIAL CONDITION AS OF DECEMBER 31, 2020** ### **Assets** | equivalents
Cash
and
cash
Accounts
receivable
Prepaid
expenses | \$
228,167
51,821
1,385 | |-------------------------------------------------------------------------------------|----------------------------------| | Total
Assets | \$
281,373 | | Liabilities
Member's
and
Equity | | | Liabilities
Accounts
accrued
expenses
payable
and | \$
202,750 | | Total
Liabilities | 202,750 | | Member's
Equity | 78,623 | | Member's
Liabilities
Total
and
Equity | \$
281,373 | {6}------------------------------------------------ ### **SPEYSIDE ADVISORS, LLC STATEMENT OF OPERATIONS FOR THE YEAR ENDED DECEMBER 31, 2020** | Revenues | | | | |----------------------------------------------|----|------------|--| | Consulting
income | | 1,435,032 | | | Dividend
and
interest
income | | | | | Revenues
Total | | 1,435,032 | | | Expenses | | | | | representative
compensation
Registered | | 1,238,915 | | | expenses
Regulatory
fees
and | | 4,132 | | | fees
Professional | | 156,659 | | | Occupancy | | 11,171 | | | Other
expenses | | 24,099 | | | Total
Expenses | | 1 ,434,976 | | | for
before
taxes
Gain
provision | | 56 | | | for
state
tax
Provision
income | | | | | Net
Income | \$ | 56 | | {7}------------------------------------------------ ### **SPEYSIDE ADVISORS, LLC STATEMENT OF CHANGES IN MEMBER'S EQUITY FOR THE YEAR ENDED DECEMBER 31, 2020** | Balances
at
2019
December
31, | \$78,567 | |-------------------------------------------|----------| | Member's
contributions | | | Net
income | 56 | | at
Balances
2020
December
31, | \$78,623 | {8}------------------------------------------------ ### **SPEYSIDE ADVISORS, LLC STATEMENT OF CASH FLOWS FOR THE YEAR ENDED DECEMBER 31, 2020** | Cash
flows
provided
for)
operating
activities:
by
(used | | |-------------------------------------------------------------------------------------------------------------------------------------|---------------| | Net
income | \$
56 | | to
to
Adjustments
reconcile
net
income
net
cash
provided
by
activities:
for
operating
(used) | | | Changes
assets
and
liabilities
in | | | Increase
accounts
receivable
in | (31,402) | | Decrease
other
assets
in | 301 | | Increase
account
payable
and
accrued
expenses
in | 202,750 | | Net
cash
provided
by
operating
activities | 171,705 | | Net
increase
cash
and
cash
equivalents
in | 171,705 | | and
of
year
Cash
cash
equivalents
at
beginning | 56,462 | | Cash
cash
equivalents
at
end
of
year
and | \$
228,167 | {9}------------------------------------------------ ## **SPEYSIDE ADVISORS, LLC NOTES TO FINANCIAL STATEMENTS** ### **DECEMBER 31, 2020** ## **NOTE 1 -Organization and Nature of Business** Speyside Advisors, LLC (the "Company"), was formed on May II, 2017. The Company is a broker-dealer registered with the Securities and Exchange Commission ("SEC") and is a member of the Financial Industry Regulatory Authority. The Company operates as a Texas Limited Liability Company ("LLC" ). Its member has limited personal liability for the obligations or debts of the entity. The Company commenced its broker-dealer operations on January 18, 2019 and shall continue unless terminated in accordance with its operating agreement. The Company is engaged in providing advisory services involving private placement and mergers and acquisitions for its clients. It is intended that all offerings will be exempt from registration under the provisions of either Regulation D or Rule 144A. The Company is considered a Non-Covered Finn exempt from 17 C.F.R. § 240.15c3-3 relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17-5. Upon commencing operations, the Company adopted the accounting standard for revenue for contracts with customers. The Company provides advisory services on mergers and acquisitions (M&A). Revenue for advisory arrangements is generally recognized at the point in time that performance under the arrangement is completed (the closing date of the transaction) or the contract is cancelled. However, for certain contracts, revenue is recognized over time for advisory arrangements in which the performance obligations are simultaneously provided by the Company and consumed by the customer. In some circumstances, significant judgment is needed to determine the timing and measure of progress appropriate for revenue recognition under a specific contract. Retainers and other fees received from customers prior to recognizing revenue are reflected as contract liabilities. At December 31, 2020, there are no recognized contract liabilities. ### Cash and Cash Equivalents The Company considers all highly liquid investments with a maturity of three months or less when purchased to be cash equivalents. At December 31, 2020, the Company had no such investments. The Company maintains is operating cash at a financial institution. At times, the amount on deposit at this institution may exceed amounts covered by insurance provided by the U.S. Federal Deposit Insurance Corporation ("FDIC"). The Company has not experienced any losses related to amount in excess of FDIC limits. ### Revenue Recognition The Company provides advisory services on mergers and acquisitions. Advisory fees represent 100% of revenue earned by the Company. Revenue for advisory arrangements is generally recognized at the point in time that performance under the arrangement is completed (the closing date of the transaction). However, for certain contracts, revenue is recognized over time for advisory arrangements in which the performance obligations are simultaneously provided by the Company and consumed by the customer. Retainers and other fees received from customers prior to recognizing revenue are reflected as deferred revenue. {10}------------------------------------------------ ### **SPEYSIDE ADVISORS, LLC** ### **NOTES TO FINANCIAL STATEMENTS** ### **DECEMBER 31, 2020** # **NOTE 1 -Organization and Nature of Business (Cont.)** The Company's financial statements are presented in conformity with accounting principles generally accepted in the United States of America ("U.S. GAAP"). The Financial Accounting Standards Board ("FASB") Accounting Standards Codification (the Codification) is the single source of U.S. GAAP. The preparation of financial statements in conformity with U.S. GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosures of contingent assets and liabilities at the date of the financial statements and the reported amounts of income and expenses during the reporting period. Actual results could differ from those estimates. The Company's net income will be taxed at the member level rather than at the corporate level for federal income tax purposes. The Company is subject to state income taxes. Any potential interest and penalty associated with a tax contingency,should one arise, would be included as a component of income tax expense in the period in which the assessment arises. The Company's federal and state income tax returns are subject to examination over various statutes of limitations generally ranging from three to five years. # **NOTE 2 -Net Capital Requirements** Pursuant to the net capital provisions of Rule 15c3-1 of the Securities and Exchange Act of 1934, the Company is required to maintain a minimum net capital, as defined under such provisions. Net capital and the related net capital ratio may fluctuate on a daily basis. At December 31, 2020, the Company had net capital of \$68,946 and net capital requirements of \$13,517. The Company's ratio of aggregate indebtedness to net capital was 2.90 to 1 .The Securities and Exchange Commission permits a ratio of no greater than 15 to 1 . # **NOTE 3 -Possession or Control Requirements** The Company holds no customer funds or securities. The Company is considered "Non-Covered Finn" exempt from 17 C.F.R. § 240.15c3-3 and is filing an Exemption Report relying on footnote 74 to SEC Release 34-70073, and as discussed in Q&A 8 of the related FAQ issued by the SEC staff. The Company limits its business activities exclusively to private placement of securities, including direct participation programs and merger and acquisition advisory services. ## **NOTE 4 -Concentration Risk** The Company may at various times during the year have cash balances in excess of federally insured limits. The Company believes that it is not exposed to any significant risk related to cash. # **NOTE 5 -Related Party Transactions** The Company and various entities arc under common control and the existence of that control creates operating results and financial position significantly different than if the companies were autonomous. {11}------------------------------------------------ ### **SPEYSIDE ADVISORS, LLC** ### **NOTES TO FINANCIAL STATEMENTS** ### **DECEMBER 31, 2020** ## **NOTE 6 -Liabilities Subordinated to Claims of General Creditor** During the year ended December 31, 2020, there were no subordinated liabilities to the claims of general creditors. Accordingly, a statement of changes in liabilities subordinated to claims of general creditors has not been included in these financial statements. # **NOTE 7 - Recent Accounting Pronouncements** Recently issued accounting standards that have been issued or proposed by the FASB or other standardssetting bodies are not expected to have a material impact on the Company's Financial position or results of operations. The Company plans to adopt any new standards in accordance with the standards. # **NOTE 8 -SIPC Supplemental Reporting** The Company is subject to the filing of the SIPC Supplemental Report as net operating revenues are more than \$500,000. # **NOTE 9 -Commitments and Contingencies** The Company had no commitments or contingencies that were required to be accrued or disclosed. ## **NOTE 10 -Subsequent Events** Subsequent events have been evaluated for potential recognition and disclosure through February 24, 2021, which represents the date the financial statements were available for issuance. {12}------------------------------------------------ ### **Supplemental Information** **Pursuant to Rule 17a-5** **of the Securities Exchange Act of 1934** **as of** **December 31, 2020** {13}------------------------------------------------ ### **Schedule I** ### **SPEYSIDE ADVISORS, LLC Computation of Net Capital Under Rule 15c3-l of the Securities and Exchange Commission As of December 31, 2020** | Computation
of
Capital
Net | | | |-----------------------------------------------------------------------|----|----------| | Total
member
for
capital
qualified
net
capital | \$ | 78,623 | | and/or
Deductions
charges | | | | assets:
Non-allowable | | | | Accounts
receivable | | (51,821) | | Other
assets | | ( 1,385) | | Other
deductions
charges
or | | 43,529 | | capital
before
haircuts
on
securities
positions
Net | | (9,677) | | Net
Capital | \$ | 68,946 | | Aggregate
indebtedness | | | | condition:
of
Items
included
statement
financial
in | | | | Accounts
payable
accrued
expenses
and | | 202,750 | | indebtedness
Total
aggregate | S | 202,750 | See accompanying report of independent registered public accounting firm. {14}------------------------------------------------ ### **Schedule I (continued)** ### **SPEYSIDE ADVISORS, LLC Computation of Net Capital Under Rule 15c3-l of the Securities and Exchange Commission As of December 31, 2020** ### **Computation of Basic Net Capital Requirement** | capital
Minimum
net
required | | |-------------------------------------------------------------------------------------------------|----------------| | (6
2/3%
of
indebtedness)
aggregate | \$
13,517 | | dollar
Capital
Requirement
of
Reporting
Minimum
Net | | | or
Broker
Dealer | \$
5,000 | | Capital
Requirement
Minimum
Net | \$
13,517 | | Net
Capital
Excess
of
Requirement
in
Minimum | \$
55,429 | | 10%
capital
greater
of
capital
less
greater
of
of
Net
less
net | | | or
aggregate
indebtedness
120%
of
capital
minimum
net | \$
48,671 | | of
Ratio
Aggregate
Indebtedness
to
Net
Capital | 2.9
to
1 | | | | No material differences existed between the audited computation of net capital pursuant to Rule 15c3-1 as of December 31, 2020 and the corresponding unaudited filing of part IIA of the FOCUS Report/Form X-17A-5 filed by Speyside Advisors, LLC See accompanying report of independent registered public accounting finn. {15}------------------------------------------------ #### **Schedule II** ### **SPEYSIDE ADVISORS, LLC Computation for Determination of Reserve Requirements Under Rule 15c3-3 of the Securities and Exchange Commission As of December 31, 2020** #### **EXEMPTIVE PROVISIONS** The Company is considered "Non-Covercd Firm" exempt from 17 C.F.R. § 240.15c3-3 and is filing an Exemption Report relying on footnote 74 to SEC Release 34-70073, and as discussed in Q&A 8 of the related FAQ issued by the SEC staff. The Company limits its business activities exclusively to private placement of securities, including direct participation programs and merger and acquisition advisory services. See accompanying report of independent registered public accounting firm. {16}------------------------------------------------ Report of Independent Registered Public Accounting Firm On Management's Exemption Report Required by SEC Rule 17a-5 Year Ended December 31, 2020 {17}------------------------------------------------ ![](_page_17_Picture_0.jpeg) A Profession.!I Corporation **Certified Public Accountants** ### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** ### **To the Managing Member of Speyside Advisors, LLC** We have reviewed management's statements, included in the accompanying Exemption Report, in which (1) Speyside Advisors, LLC does not claim an exemption under paragraph (k) of 17 C.F.R. §240.15c3-3, and (2) Speyside Advisors, LLC is filing the Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 as a Non-Covered Firm as it limits its business activities exclusively to private placement of securities, including direct participation programs, and merger and acquisition advisory services, and Speyside Advisors, LLC (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, (other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of Rule 15c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to Speyside Advisors, LLC; (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year, December 31, 2020, without exception. Speyside Advisors, LLC's management is responsible for compliance with the Non-Covered Firm Provision 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 Speyside Advisors, LLC's compliance with the Non-Covered Firm Provision. 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 Non-Covered Firm Provision. McBee & Co.,PC Dallas, Texas February 24, 2021 {18}------------------------------------------------ ![](_page_18_Picture_0.jpeg) #### **BROKER-DEALER ANNUAL EXEMPTION REPORT** #### **DECEMBER 31, 2020** Speyside Advisors, LLC, (the company) is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C.F.R. §240.17a-5, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R. §240.17a-5(d)(1) and (4). To the best of its knowledge and belief the Company states the following: (1) The Company is considered "Non-Covered Firm" exempt from 17 C.F.R. § 240.15c3-3 and is filing an Exemption Report relying on footnote 74 to SEC Release 34-70073, and as discussed in Q&A 8 of the related FAQ issued by the SEC staff. The Company limits its business activities exclusively to private placement of securities, including direct participation programs basis and merger and acquisition advisory services. (2) The Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of Rule 15c2-4; (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3), throughout the most recent fiscal year without exception. **I, Daniel Gillett, swear (or affirm) that, to my best knowledge and belief, this Exemption Report is true and correct.** By: .Daniel Giljett Sole Member , 2021 **Speyside Adt isors, I.LC • 19I0 Pacific Avenue, Suite 5060. Dallas. TX 75201 Member IINRA/SIPC** Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.