# EQUAPATH CAPITAL, LLC X-17A-5 (2023-03-31) — Broker-dealer annual report - Company: EQUAPATH CAPITAL, LLC - Form: X-17A-5 - Filed: 2023-03-31 - Period: 2022-12-31 - Accession: 0001854893-23-000002 - CIK: 1854893 - File #: 8-70693 - Type: Broker-dealer - Material weakness: No - Auditor: TPS THAYER LLC - Auditor location: SUGARLAND, TX - Contact: ROBERT RUBIN - Phone: 786-331-3391 - Email: rrubin@equapath.com - Website: equapath.com - Signed by: ROBERT RUBIN (CEO) Original filing: https://www.sec.gov/Archives/edgar/data/1854893/000185489323000002/equapath22.pdf --- {0}------------------------------------------------ | UNITED STATES | | | | | |------------------------------------|--|--|--|--| | SECURITIES AND EXCHANGE COMMISSION | | | | | | Washington, D.C. 20549 | | | | | # **ANNUAL REPORTS FORM X-17A-5 PART** Ill | 0MB Number: 3235-0123 | | |--------------------------|--| | Expires: Oc 31, 2023 | | | Estimated average burden | | | hours per response: 12 | | | | | | SEC FILE NUMBER | | | 8-70693 | | | | | OMB APPROVAL **FACING PAGE Information Required Pursuant to** Rules 17a-5, **17a-12,** and **18a-7** under **the Securities Exchange Act of 1934** nueror mersao» sew **01/01/22 m**sons **12/81/22** MM/DD/YY **A. REGISTRANT IDENTIFICATION** was or re«. Equapath Capital, LLC MM/DD/YY TYPE OF REGISTRANT (check all applicable boxes): E Broker-dealer [ Security-based swap dealer [ Check here if respondent is also an OTC derivatives dealer \_] Major security-based swap participant ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) 8899 NW 18th Terrace, Suite 102 (No. and Street) Doral (City) PERSON TO CONTACT WITH REGARD TO THIS FILING FL (State) 33172 [Zip Code) Robert Rubin (Name) 786-331-3391 (Area Code - Telephone Number) **B. ACCOUNTANT IDENTIFICATION** rrubin@equapath.com (Email Address) INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing TPS Thayer LLC 1600 Hwy 6, Ste. 100 (Address) 07/14/2020 Sugarland (Cry) TX (State) 6706 77478 (Zip Code) (Name - if individual, state last, first, and middle name] (Date of Registration with PCAOB)(f applicable) **FOR OFFICIAL USE ONLY** (PCAOB Registration Number, if applicable) Claims for exemption from the requirement that the annual reports be covered by the reports of an independent public accountant must be supported by a statement of facts and circumstances relied on as the basis of the exemption. See 17 CFR 240.17a-5(e)(1)(ii), if applicable. Persons who are to respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB control number. {1}------------------------------------------------ | OATH OR AFFIRMATION | | | | |-----------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------|--|--| | I, Robert Rubin | swear (or affirm) that, to the best of my knowledge and belief, the | | | | financial report pertaining to the firm of Equapath Capital, L.c | ,as of | | | | 12/31 | 20@, is true and correct. 1further swear (or affirm) that neither the company nor any | | | | | partner, officer, director, or equivalent person, as the case may be, has any proprietary interest in any account classified solely | | | | f | | | | | | | | | | | | | | | | | | | | n du | Title: | | | | Coke | CEO | | | | | | | | | I
Notary Public | | | | | | | | | | This filing contains (check all applicable boxes): | | | | | a (a) Statement of financial condition. | | | | | (b) Notes to consolidated statement of financial condition. | | | | | | ii (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 5 210.1-02 of Regulation S-X). | | | | | a (d) Statement of cash flows. | | | | | iii (e) Statement of changes in stockholders' or partners' or sole proprietor's equity. | | | | | D (f) Statement of changes in liabilities subordinated to claims of creditors. | | | | | ii (g) Notes to consolidated financial statements. | | | | | a (h) Computation of net capital under 17 CFR 240.15c3-1 0r 17 CFR 240.18a-1, as applicable. | | | | | D {i) Computation of tangible net worth under 17 CFR 240.18a-2. | | | | | | D (j) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3. | | | | | D (kl Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.15c3-3 or | | | | Exhibit A to 17 CFR 240.18a-4, as applicable. | | | | | D (I) Computation for Determination of PAB Requirements under Exhibit A to \$ 240.15c3-3. | | | | | D (m) Information relating to possession or control requirements for customers under 17 CFR 240.1503-3. | | | | | D (n) Information relating to possession or control requirements for security-based swap customers under 17 CFR | | | | | 240.15c3-3(p)(2) 0r 17 CFR 240.18a-4, as applicable. | | | | | | □ (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capital or tangible net | | | | | worth under 17 CFR 240.15c3-1, 17CFR 240.18a-1, or 17 CFR 240.18a-2, as applicable, and the reserve requirements under 17 | | | | | CFR 240.15c3-3 0r 17 CFR 240.18a-4, as applicable, if material differences exist, or a statement that no material differences | | | | exist. | | | | | D (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition. | | | | | | a (q) Oath or affirmation in accordance with 17 CFR 240.17a-5, 17 CFR 240.17a-12, 0r 17 CFR 240.18a-7, as applicable. | | | | E (r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. | | | | | iii (s) Exemption report in accordance with 17 CFR 240.17a-5 0r 17 CFR 240.18a-7, as applicable. | | | | | | D (t) Independent public accountant's report based on an examination of the statement of financial condition. | | | | | | | | ii (u) Independent public accountant's report based on an examination of the financial report or financial statements under 17 CFR 240.17a-5, 17 CFR 240.18a-7, 0r 17 CFR 240.17a-12, as applicable. D (v) Independent public accountant's report based on an examination of certain statements in the compliance report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. a (w) Independent public accountant's report based on a review *of* the exemption report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. D (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-le or 17 CFR 240.17a-12, as applicable. D (y) Report describing any material inadequacies found to exist or found to have existed since the date of the previous audit, or a statement that no material inadequacies exist, under 17 CFR 240.17a-12(k). □ (2) Other: \_ *To request confidential treatment of certain portions of this filing, see 17 CFR 240.17a-5(e)(3) or 17 CFR 240.18a-7()(2), as applicable.* {2}------------------------------------------------ ### **EQUAPATH CAPITAL, LLC** ### **FINANCIAL STATEMENTS AND SUPPLEMENTAL SCHEDULES** With Report of Independent Registered Public Accounting Firm For the Year Ended December 31, 2022 {3}------------------------------------------------ ### **TABLE OF CONTENTS** For the Year Ended December 31, 2022 | REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM | | |--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------| | FINANCIAL STATEMENTS | | | Statement of Financial Condition
| 2 | | Statement of Income

| 3 | | Statement of Changes in Member's Equity | 4 | | Statement of Cash Flows






| 5 | | NOTES TO THE FINANCIAL STATEMENTS | 6-11 | | SUPPLEMENTAL SCHEDULES | | | Schedule 1: Computation of Net Capital under Rule l 5c3-l of the Securities
and Exchange Commission | 12 | | Schedule II: Computation of Determination of Reserve Requirements for Brokers
and Dealers Pursuant to Rule 15c3-3 under the Securities and
Exchange Commission.

. | 13 | | Schedule ill: Information Relating to the Possession or Control Requirements | | | under the Securities and Exchange Commission Rule l 5c3-3 | 14 | {4}------------------------------------------------ ### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM Director and Member Equapath Capital, LLC 8899 **NW** 18" Terrace, Suite 102 Doral, FL 33172 #### Opinion on The Financial Statements We have audited the accompanying statement of financial condition ofEquapath Capital, LLC (the "Company") as of December 3 1, 2022, and the related statements of income, changes in member's equity, and cash flows for the year then ended, December 3 1 , 2022, and the related notes (collectively referred to as financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Company as of December 3 1, 2022, and the results of its operations and its cash flows for the year ended December 31, 2022, in accordance with accounting principles generally accepted in the United States of America. #### Basis for Opinion These financial statements are the responsibility of the Company's management. Our responsibility is to express an opinion on the Company's financial statements based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB") and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. We cond ucted our audit in accordance with 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 from material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risk 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 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 Supplementary Information The accompanying supplemental schedules have been subjected to the auditing procedures performed in conjunction with the audit of Pal mas Securities, LLC.'s financial statements. The supplemental schedules are the responsibility of Palmas Securities, LLC.'s management. Our audit procedures included determining whether the supplemental schedules reconcile 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 schedules. Tn forming our opinion on the supplemental schedules, we evaluated whether the supplemental schedules, including their fonn and content, is presented in confonnity with 17 C.F.R. §240. I7a-5. Tn our opinion, the supplemental schedules are fairly stated, in all material respects, in relation to the financial statements as a whole. *7P 7ape 44C* TPS Thayer LLC We have served as Equapath Capital, LLC's. auditor since 202 J. Sugar Land, TX March 3 J, 2023 {5}------------------------------------------------ # **STATEMENT OF FINANCIAL CONDITION** As of December 31, 2022 | ASSETS | | | |---------------------------------------------------------------|----|----------| | Cash | S | 56,070 | | Prepaid Expenses | | 2,838 | | Related Party Receivable | | 16,500 | | Accounts Receivable | | 5,000 | | TOTAL ASSETS | \$ | 80,408 | | LIABILITIES | | | | | | | | Account payables and accrued liabilities
TOTAL LIABILITIES | \$ | 60
60 | | COMMITMENTS AND CONTINGENCIES | | | | MEMBER'S EQUITY | \$ | 80,348 | {6}------------------------------------------------ ### **STATEMENT OF INCOME** For the Year Ended December 31, 2022 | REVENUES | | |------------------------------------|---------------| | Private placement fees | \$
327,000 | | TOTAL REVENUES | \$
327,000 | | EXPENSES | | | Professional Fees | 18,268 | | Regulatory Fees | 5,707 | | Technology, Data, & Communications | 2 ,132 | | Occupancy and lease of equipment | 7,250 | | Other Expenses | 651 | | TOT AL EXPENSES | \$
34,008 | | NET INCOME | \$ | | | 292,992 | {7}------------------------------------------------ # **STATEMENT OF CHANGES IN MEMBER'S EQUITY** For the Year Ended December 31, 2022 | | | TOTAL | |------------------------------|---|-----------| | BALANCE AT JANUARY 1, 2022 | | 38,356 | | Di stri buti on s | | (251,000) | | Net Income | | 292,992 | | BALANCE AT DECEMBER 31, 2022 | s | 80,348 | {8}------------------------------------------------ ### **STATEMENT OF CASH FLOWS** For the Year Ended December 31, 2022 | CASH FLOWS FROM OPERATING ACTIVITIES | | |---------------------------------------------------------|---------------| | Net Income | \$
292,992 | | Changes in operating assets and liabilities: | | | Accounts Receivable | (5,000) | | Related Party Receivable | (21,900) | | Prepaid Expenses | (1,898) | | Accounts Payable, Accrued Expenses, & Other Liabilities | (1,034) | | Net Cash Provided by Operating Activities | \$
263,160 | | CASH FLOWS FROM FINANCING ACTIVITIES | | | Distributions | (251,000) | | Net Cash Used in Financing Activities | \$ [251,000) | | NET INCREASE TN CASH | \$
12,160 | | CASH BALANCE AT JANUARY 1, 2022 | \$
43,910 | | CASH BALANCE AT DECEMBER 31, 2022 | \$
56,070 | {9}------------------------------------------------ # **NOTES TO THE FINANCIAL STATEMENTS** For the Year Ended December 3 1, 2022 ### **1. Organization and Nature of Business** Equapath Capital, LLC (the Company) was organized as a Florida Limited Liability Company in March 2021 and became a registered broker-dealer with the Securities and Exchange Commission (SEC) and member Financial Industry Regulatory Authority (FINRA) in August 2021. The Company is under direct ownership of Mr. Robert Rubin. The Company's current business is the structuring and sales of private placement securities. ### **2. Significant Accounting and Reporting Policies** ### **Basis of Presentation** The accompanying financial statements have been prepared on the accrual basis of accounting in accordance with accounting principles generally accepted in the United States (GAAP). ### **Use of Estimates** The preparation of financial statements in conformity with accounting principles generally accepted in the United States of America requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenue and expenses during the reporting period. Actual results could differ from those estimates. ### **Cash and Cash Equivalents** The Company maintains its cash in bank deposit account(s) which, at times, may exceed federally insured limits. The Company monitors the bank account(s) and does not expect to incur any losses from such account(s). The Company has defined cash and cash equivalents as highly liquid investments with original maturities of less than ninety days that are not held-for-sale in the ordinary course of business. The recorded value of such instruments approximates their fair value. At December 31, 2022, the Company had no cash equivalents. ### **Accounts Receivable** The Company considers accounts receivable to be fully collectable; accordingly, no allowance for doubtful accounts is required. If amounts become uncollectable, they will be charged to operations when that determination is made. {10}------------------------------------------------ # **NOTES TO THE FINANCIAL STATEMENTS** For the Year Ended December 31, 2022 ### **2. Significant Accounting and Reporting Policies - Continued** ### **Revenue** The Company recognizes *Revenue from Contracts with Customers* in accordance with ("ASC Topic 606"). This revenue recognition guidance 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. Additionally, the guidance requires the Company to follow a five step model to a) identify the contract with the customer, b) identify the performance obligations in the contract, e) determine the transaction price, d) allocate the transaction price to the performance obligations in the contract, and e) recognize revenue when (or as) the Company satisfies a performance obligation. Private securities placement include success fees that are owed to the Company on a private placement transactions. The amount of the fee is stipulated in the Company's engagement contract with the client and is generally calculated as a percentage of the relevant transaction or as a fixed fee. Success fees are recognized when the relevent private placement transaction is closed, when all performance obligations to the client have been completed ### **Income Taxes** The Company is a single member limited liability company that is treated as a disregarded entity for income tax purposes as all income or loss flows through to the member. Therefore, no income tax expense or liability is recorded in the accompanying financial statements. have been completed ### **Fair Value of Financial Instruments** FASB ASC 820 defines fair value, established a framework for measuring fair value, and establishes a fair value hierarchy which prioritizes the inputs to valuation techniques. Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date. A fair value measurement assumes that the transactions to sell the asset or transfer the liability occurs in the principal market for the asset or liability or, in the absence of a principal market, the most advantageous market. Valuation techniques that are consistent with the market, income or cost approach, as specified by F ASB ASC 820, are used to measure fair value. {11}------------------------------------------------ # **NOTES TO THE FINANCIAL STATEMENTS** For the Year Ended December 31, 2022 #### **2. Significant Accounting and Reporting Policies - Continued** The fair value hierarchy prioritizes the inputs to valuation techniques used to measure fair value into three broad Levels: > Level 1 - inputs to the valuation methodology are quoted prices (unadjusted) for identical assets or liabilities in active markets. Level 2- inputs to the valuation methodology included quoted prices for similar assets and liabilities in active markets, and inputs that are observable for the asset or liability, either directly or indirectly, for substantially the full term of the financial instrument. Level 3- inputs to the valuation methodology are unobservable and significant to the fair value measurement. Certain financial instruments are carried at cost on the balance sheet, which approximates fair value due to their short term, highly liquid nature. These instruments include cash, accounts receivables, related party receivable and accounts payable. ### **Current Expected Credit Losses** In June 2016, the FASB issued ASU No. 2016-13 (Topic 326) *Measurement of Credit Losses on Financial Instruments,* which significantly changed the way entities recognize and record credit losses on financial instruments such as loans, loan commitments, and other financial assets. The CECL model requires measurement of expected credit losses for financial assets measured at amortized cost, net investments in leases, and off-balance sheet credit exposures based on historical experience, current conditions, and reasonable and supportable forecasts over the remaining contractual life of the financial assets. The Company regularly reviews its accounts receivable for any bad debts based on the nature and contractual life or expected life of the financial assets, the Company's collection experience, and customer worthiness. At December 3 1 , 2022, the Company had \$27,000 net receivables, and there is no allowance for credit losses as of December 31, 2022. {12}------------------------------------------------ # **NOTES TO THE FINANCIAL STATEMENTS** For the Year Ended December 31, 2022 ### **3. Related Parties** The Company is an affiliate with 3N Outdoor Media (Affiliate). In connection to this relationship, the Company and the Affiliate have executed an expense sharing agreement whereby the Company receives a monthly allocation of expenses incurred by the Affiliate on its behalf. During 2022, the Company recorded expenses under this agreement totaling \$7,250. Included in the the total is a provision for rent. The Company recorded rent totaling \$6,200 related to the shared expense with the Affiliate. Rent is on a month-to-month basis. The Company, had a related party receivable of \$22,000 from revenue earned with 3N Outdoor Media (Affiliate) as of December 31, 2022. The Company also had a payable of\$5,500 with the same Affiliate, related to their expense share agreement, shown as a net receivable of \$16,500 on the statement of financial condition. ### **4. Regulatory Requirements** ### **Net Capital Requirements** The Company is subject to the SEC's Uniform Net Capital Rule (SEC Rule 15c3-1) of the Securities Exchange Act of 1934 which requires maintenance of minimum net capital. Under the Rule, the Company is required to maintain minimum net capital, as defined, equal to the greater of \$5,000 or 62/3% of aggregate indebtedness. The ratio of aggregated indebtedness to net capital cannot exceed 1500% or 1 5 :1 as an established broker dealer. At December 31, 2022, the Company had net capital of \$50,510 which was \$45,510 in excess of its required net capital and the ratio of aggregate indebtedness to net capital was I 1.01 %. ### **Reserve Requirements** The Company does not claim an exemption from SEC Rule 15c3-3, in reliance on footnote 74 to SEC Release 34-70073, as discussed in Q&A 8 of the related FAQ issued by SEC staff. The Company I) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, 2) did not carry accounts of customers of or for customers, and 3) did not carry proprietary broker accounts (PAB accounts) (as defined in Rule 15c3-3) throughout the year ended December 31, 2022, without exception. {13}------------------------------------------------ ### **NOTES TO THE FINANCIAL STATEMENTS** For the Year Ended December 31, 2022 #### **4. Regulatory Requirements - continued** #### **Possession and Control Requirements** The Company does not claim an exemption from SEC Rule I Sc3-3, in reliance on footnote 74 to SEC Release 34-70073, as discussed in Q&A 8 of the related FAQ issued by SEC staff. The Company D) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, 2) did not carry accounts of customers of or for customers, and 3) did not carry proprietary broker accounts (PAB accounts) (as defined in Rule 15c3-3) throughout the year ended December 31, 2022, without exception. #### **5. Accounts Receivable** As of December 31, 2022 the Company had accounts receivable of \$5,000, due from one customer. The Company has no allowance for bad debt as they believe the amount is collectable. #### **6. Prepaid Expenses** As of December 3 1, 2022 the Company had prepaid expenses of \$2,838, noted below: | 774 | |------------------| | 1,720 | | 344 | | \$
2,838
z | | \$ | #### **7. Professional Fees** During the year ended December 3 1, 2022, the Company recorded professional fees of \$18.268 as follows: | Consulting | \$
17,3
1
8 | |------------|----------------------| | Accounting | 950 | | | \$
18,268 | #### **8. Member's Equity** During the year ended December 31, 2022, the Company made distributions to the member of \$251,000 in cash. #### **9. Subordinated Liabilities** The Company had no liabilities subordinated to the claims of general creditors as of the beginning of 2022, end of 2022, and during 2022. {14}------------------------------------------------ # **NOTES TO THE FINANCIAL STATEMENTS** For the Year Ended December 31, 2022 ### **10. Commitments and Contingencies** The Company does not have any commitments or contingencies, including arbitration or other litigation claims that may result in a loss or a future obligation. #### **11. Subsequent Events** Management has evaluated all events or transactions that occurred after December 3 1, 2022, through March 31, 2023 the date of the issued financial statements. During this period, there were no material recognizable subsequent events that required recording or disclosures in the December 31, 2022, financial statements. {15}------------------------------------------------ # **SUPPLEMENTAL INFORMATION** # **Equapath Capital, LLC SCHEDULE** I **Computation of Net Capital under Rule 15c3-1 of the Securities and Exchange Commissions** For the Year Ended December 31, 2022 | COMPUTATION OF NET CAPITAL | | |------------------------------------------------------------------|----------------| | TOT AL MEMBER'S EQUITY | \$
80,348 | | LESS: | | | Non-A1lowable Assets | | | Prepaid Expenses | \$
(2,838) | | Accounts Receivable | \$
(27,000) | | Total Non-Allowable Assets | \$
(29,838) | | Other Operational Deductions or Charges | | | TENTATIVE NET CAPITAL | \$
50,510 | | HAIRCUTS ON SECURITIES | \$ | | NET CAPITAL | \$
50,510 | | Minimum dollar net capital requirement ofreporting broker dealer | \$
5,000 | | EXCESS NET CAPITAL | \$
45,510 | | TOTAL AGGREGATE INDEBTEDNESS | \$
5,560 | | MINIMUM NET CAPITAL BASED ON Al | \$
371 | | PERCENTAGE OF NET CAPITAL TO AI | 11.01% | There are no material differences between net capital in Part IIA of Form X-17 A-5 and net capital above. {16}------------------------------------------------ # **SUPPLEMENTAL INFORMATION** ## **Equapath Capital, LLC** # **SCHEDULE II** ### **Computation for Determination of Reserve Requirements for Brokers and Dealers Pursuant to Rule 15c3-3 under the Securities and Exchange Act of 1934** For the Year Ended December 31, 2022 The Company does not claim an exemption from SEC Rule 15c3-3, in reliance on footnote 74 to SEC Release 34-70073, as discussed in Q&A 8 of the related FAQ issued by SEC staff. The Company I) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, 2) did not carry accounts of customers of or for customers, and 3) did not carry PAB accounts (as defined in Rule 15c3-3) throughout the period ending December 31, 2022, without exception. {17}------------------------------------------------ # **SUPPLEMENTAL INFORMATION** # **Equapath Capital, LLC** # **SCHEDULE III** **Information Relating to the Possession or Control Requirements under the Securities and Exchange Commission Rule 15c3-3** For the Year Ended December 3 1, 2022 The Company does not claim an exemption from SEC Rule 15c3-3, in reliance on footnote 74 to SEC Release 34-70073, as discussed in Q&A 8 of the related FAQ issued by SEC staff. The Company I) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, 2) did not carry accounts of customers of or for customers, and 3) did not carry PAB accounts (as defined in Rule **1**5c3-3) throughout the period ending December 31, 2022, without exception. {18}------------------------------------------------ ![](_page_18_Picture_0.jpeg) ### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM Director and Member Equapath Capital, LLC We have reviewed management's statements, included in the accompanying Rule 15c3-3 Exemption Report pursuant to SEC Rule 17a-5, in which Equapath Capital, LLC (the Company): - 1) did not claim an exemption under paragraph (k) of 17 CF.R. \$240.15c3-3, and - 2) is filing this Exemption Report relying on Footnote 74 of the SEC Release No. 34- 70073 adopting amendments to 17 C.F.R. § 240.17a-5 because the Company limits its business activities exclusively to private placements, mergers and acquisitions advisory services, fairness opinions, and commission sharing for business referred to other broker-dealers in accordance with the requirements of paragraphs (a) or (b)(2) of Rule 15c2-4. In addition, the Company 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 l 5c2-4 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 the Company; did not carry accounts of or for customers; and did not carry proprietary accounts for broker dealers (PAB accounts) (as defined in Rule 15c3-3) throughout the most recent fiscal period without exception. The Company's management is responsible for compliance with the exemption provisions and its statements. Our review was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included inquiries and other required procedures to obtain evidence about the Company's compliance with the exemption provisions. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, we do not express such an opinion. Based on our review, we are not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based upon the Company's business activities contemplated by Footnote 74 of the SEC Release No. 34- 70073 adopting amendments to 17 C.F.R. § 240.17a-5, and related SEC Staff Frequently Asked Questions. *7P 7hue 44C* TPS Thayer, LLC Sugar Land, Texas March 31, 2023 www.tpscpas.com 1600 Highway 6, Suite 100 [ Sugar Land, TX 77478 I T: 281.552.8430 I F. 281.552.8431 {19}------------------------------------------------ ![](_page_19_Picture_0.jpeg) ### **Exemption Report** **Equapath Capital,** 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 CF.R. \$240.17a-5(d)1) and (4). To the best of its knowledge and belief: the Company states the foJlowing: - (1) The Company does not claim an exemption under paragraph (k) of 17C.F.R. \$ 240. 15c3-3, and - (2) The Company is filing this Exemption Report relying on Footnote 74 of SEC Release No. 34-70073 and as discussed in Q&A 8 of the related FAQ issued by SEC staff. The Company has no obligation under SEC Rule 15c3-3 because business activities are limited exclusively to the structuring and sales of private placement securities and the Company does not directly or indirectly receive, hold or otherwise owe funds or securities for or to customers; does not carry accounts of or for customers; and does not carry PAB **accounts,** and - (3) The Company had no exceptions to the provision identified above throughout the most recent fiscal year. I. Robert D. Rubin, swear ( or affirm) that, to my best knowledge and belief, this, Exemption Report is true and correct. **By: Robert D. Rabin** Title: President I CEO March **21, 2023** Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.