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SUI Group Holdings Ltd. SUIG US Equity

Financials · CIK 1425355 · FY ends Dec 31
$1.03
+0.01 (+0.98%)
USD · as of 2026-08-27 · marketstack

SUI Group Holdings Ltd. (Nasdaq: SUIG), an SEC filer in Finance Services, closed at $1.03, +1.0%, on 2026-08-27, with a market cap of $79M, a return on equity of -280.8% and a net margin of -6825.0%. Institutional ownership, earnings history and filed financials are on the tabs below.

SUIG · 10-K · period ended 2020-12-31

← all SUIG documents
filed 2021-03-10 · EDGAR original ↗

Our rendering of the filing — original pagination and typography are not reproduced, and tables are reduced to their short label cells (the figures live on FA). Nothing is summarized: every line below is the filing's own text.

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10-K

1

tm211205d1_10k.htm

FORM 10-K

UNITED STATES SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

FORM 10-K

(Mark

One)

For the fiscal year ended December 31, 2020 or

For the transition period from ______________________

to ______________________

Commission File Number 814-00991

MILL CITY

VENTURES III, LTD.

(Exact name of registrant as specified in

its charter)

(State of incorporation) (I.R.S. Employer Identification No.)

(Address of principal executive offices) (Zip Code)

Former name, former address and former fiscal

year, if changed since last report

Registrant’s telephone number, including

area code: (952) 479-1923

Securities registered pursuant to Section 12(b) of

the Act:

Title of Each Class Name of Each Exchange on which Registered

None

Securities registered pursuant to Section 12(g) of

the Act:

Common stock, $0.001 par value per share

Indicate

by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act. Yes

̈ No x

Indicate

by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the

Act. Yes ̈ No x

Indicate

by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of

the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was

required to file such reports), and (2) has been subject to the filing requirements for the past 90 days. x

Yes ̈ No

Indicate

by check mark whether the registrant has submitted electronically and posted on its corporate website, if any, every

Interactive Data File required to be submitted and posted pursuant to Rule 405 of Regulation S-T (§232.405 of this

chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit and post such

files). x Yes ̈ No

Indicate

by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non accelerated filer, or a

smaller reporting company. See definition of “large accelerated filer,” “accelerated filer,”

“non accelerated filer,” and “smaller reporting company” in Rule 12b-2 of the Exchange Act.

(Check one)

Indicate

by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Act).

̈ Yes x No

The aggregate

market value of the voting stock held by persons other than officers, directors and more than 5% shareholders of the registrant

as of June 30, 2020 was approximately $1,512,115 based on the closing sales price of $0.60 per share as reported on the OTCPK.

As of March 10, 2021, there were 10,785,913 shares of the registrant’s common stock, $0.001 par value, outstanding.

DOCUMENTS INCORPORATED IN PART BY REFERENCE

None.

Mill City Ventures III, Ltd.

Form 10-K

Table of Contents

Page

PART I

Item 1. Business 1

Item 1A. Risk Factors 2

Item 2. Properties 3

Item 3. Legal Proceedings 3

PART II 4

ITEM 8 FINANCIAL STATEMENTS AND SUPPLEMENTARY DATA 9

ITEM 9A CONTROLS AND PROCEDURES 28

ITEM 10 DIRECTORS, EXECUTIVE OFFICERS AND CORPORATE GOVERNANCE 30

ITEM 11 EXECUTIVE AND DIRECTOR COMPENSATION 33

ITEM 14 PRINCIPAL ACCOUNTANT FEES AND SERVICES 35

ITEM 15 EXHIBITS AND FINANCIAL STATEMENT SCHEDULES 36

SIGNATURES 37

PART I

ITEM 1

BUSINESS

Overview

Mill City

Ventures III, Ltd, (the “Company” or “we”), is a Minnesota corporation that was incorporated in January 2006.

From our inception until December 13, 2012, we were a development-stage company focused on promoting and placing a proprietary

poker game online and into casinos and entertainment facilities nationwide. In 2013, we elected to become a business development

company (“BDC”) under the Investment Company Act of 1940 (the “19440 Act”). We operated as a BDC until

we withdrew our BDC election by filing a Form N-54C with SEC on December 27, 2019. Presently, we are engaged in the business

of providing short-term specialty finance on an opportunistic basis. Nevertheless, we manage our investments to ensure that no

more than 40% of our total assets consist of investment securities so as to avoid the regulatory requirements of the 1940 Act.

Business

as a BDC

As a BDC,

we primarily focused on investing in or lending to private and small-capitalization public companies and making managerial assistance

available to such companies. Our investments included stock of or membership interests (typically referred to as units) in private

companies, small-cap public company stocks, and promissory notes. In some cases the stock or membership interests we acquired was

preferred stock or units, and in other cases the stock or membership interests acquired was common stock or units. In connection

with our investments in promissory notes, we also obtained warrants to purchase common stock.

Revenues

from our operations as a BDC relate to the earnings we received from our portfolio investmenst.

Our

2020 Portfolio

At

December 31, 2020, we held investments in eight portfolio companies, which had an aggregate amortized cost of $4,968,576 and

a fair value of $6,667,897. At December 31, 2019, we held investments in eight eligible portfolio investments, which

had an aggregate amortized cost of $1,976,370 and a fair value of $1,740,897. Our portfolio investments at December 31, 2020

were as follows:

1

Dispositions of Investments

In 2019, we disposed of a substantial

portion of the investments we had earlier made as a BDC. These dispositions were effected by management in an orderly fashion,

at prices management believed to be fair, and at times management believed to advantageous. In all, we disposed of $9,110,237 in

investments (measured at fair value) in 2019.

Management

Currently,

Mr. Douglas M. Polinsky, the Chief Executive Officer and Chairman of our Board of Directors, and Joseph A. Geraci, II,

our Chief Financial Officer and a director of the Company, serve as our senior management team.

Strategic

Direction

As of

the time of this filing, we remain a public reporting company and file periodic reports with the SEC. Since the withdrawal of our

BDC election, we have focused our business on the provision of short-term specialty financing to small business, small-cap public

companies and high-net-worth individuals. We structure these investments carefully so as to avoid them, to the extent possible,

from being characterized as “investment securities” under federal securities laws. In this regard, we generally seek

to provide financing solutions that mature in nine months or less. Because of the short-term nature of our investments, and our

ability to manage the due-diligence process swiftly and efficiently, our finance solutions typically involve high rates of interest

and premiums, as well as other terms advantageous to us. In addition, to avoid becoming subject to the regulatory requirements

of the 1940 Act, we monitor our investment holdings as a whole to ensure that investments and other holdings which may be considered

“investment securities” do not comprise more than 40% of our total assets.

Pending

the consummation of investments, we intend to keep the majority of our assets in cash, cash equivalents such as money-market investments,

U.S. government securities or high quality debt securities maturing in one year or less from the time of investment.

ITEM 1A

RISK FACTORS

You should

consider the following risk factors, in addition to the other information presented or incorporated by reference into this Annual

Report on Form 10-K, in evaluating our business and any investment decision relating to our securities.

Risks

Related to our Business

We

have little operating history upon which to evaluate our business.

We only

recently – within the past 13 months - withdrew our election to be treated as a BDC under the 1940 Act, and during that same

short span of time have refocused our business on providing short-term specialty finance to private businesses, small-cap public

companies and high-net-worth individuals. The financial results included in this report relate to our business operations as a

BDC during 2019 (a business in which we are no longer engaged) and our new short-term specialty finance business operations during

2020. Given that our current business has been developed and pursued over the prior 13 months, and the comparative prior-year financials

included in this report reflect the results of operations for a different business, investors have little means to evaluate the

likelihood of our future success.

We

may need to raise additional capital in the near future to fund operations, and such capital may not be available to us in sufficient

amounts or on acceptable terms.

For the

time being, management believes that our current cash is sufficient to continue operations for the foreseeable future, and has

no potential or actual plans to seek additional financing. Nevertheless, various future developments may cause us to seek or require

additional financing.

Additional

financing could be sought from a number of sources, including but not limited to additional sales of equity or debt securities,

or loans from banks, other financial institutions or affiliates of the Company. We cannot, however, be certain that any such financing

will be available on terms favorable or acceptable to us if at all. If additional funds are raised by the issuance of our equity

securities, such as through the issuance of stock, convertible securities, or the issuance and exercise of warrants, then the ownership

interest of our existing shareholders will be diluted. If additional funds are raised by the issuance of debt or other equity instruments,

we may become subject to certain operational limitations, and such securities may have rights senior to the rights of our common

shareholders. If adequate funds are not available on acceptable terms, we may be unable to consummate acquisitions or investments

desired by our management and board.

2

Our

ability to identify and consummate investment opportunities, and any need we may have for additional capital, will almost certainly

be affected by general economic conditions.

General

economic conditions will almost certainly impact our ability to (i) identify and pursue and consummate investment opportunities,

and (ii) if necessary, seek and obtain additional financing on terms acceptable or favorable to us, if at all. Therefore,

a deterioration in general economic conditions may slow the development of our business.

We

are highly dependent on the services provided by certain executives and key personnel.

Our success

depends in significant part upon the continued service of our senior management personnel. In particular, the Company is materially

dependent upon the services of Douglas M. Polinsky, our Chief Executive Officer and Chairman, and Joseph A. Geraci, II, our

Chief Financial Officer and a director of the Company. Although we currently have employment agreements with these individuals,

these agreements will not necessarily prevent the departure of these executives, whether due to death, disability, retirement or

otherwise. Any loss of services provided by these executives would likely have a material and adverse effect on our operations

and ability to execute our business plans.

Our

articles of incorporation grant our board of directors the power to designate and issue additional shares and classes of common

and preferred stock.

Our authorized

capital consists of 250,000,000 shares of capital stock. Pursuant to authority granted by our articles of incorporation, our board

of directors, without any action by our shareholders, may designate and issue shares in such classes or series (including other

classes or series of preferred stock) as it deems appropriate, and may establish the rights, preferences and privileges of such

shares, including dividends, liquidation and voting rights. The rights of holders of new classes or series of stock that may be

so designated and issued could be superior to the rights of holders of our common shares. The designation and issuance of shares

of capital stock having preferential rights could adversely affect other rights appurtenant to shares of our common stock. Furthermore,

any issuances of additional stock—common or preferred—will dilute the ownership interest of then-current holders of

our capital stock and may dilute our book value per share.

Our

stock is thinly traded, which may make it difficult to sell shares of our common stock.

Our common

stock is thinly traded and may remain thinly traded for the foreseeable future. A low trading volume will generally make it difficult

for our shareholders to sell their shares as and when they choose. Furthermore, low trading volumes are generally understood to

depress market prices. As a result, our shareholders may not always be able to resell shares of our common stock publicly at the

time and prices that they feel are fair or appropriate.

We

may not pay dividends on our common stock.

We may

not pay cash dividends on our common stock and have only a limited history of paying dividends. Accordingly, investors in our common

stock may only obtain a return on their investment, if any, upon a subsequent sale of their shares.

ITEM 2

PROPERTIES

The Company

is subject to two operating leases for office space expiring March 31, 2022. These leases do not have significant lease escalations,

holidays, concessions, leasehold improvements, or other build-out clauses. Further, the leases do not contain contingent rent provisions.

The leases do not include options to renew.

ITEM 3

LEGAL PROCEEDINGS

None.

3

PART II

ITEM 5

MARKET FOR REGISTRANT’S COMMON EQUITY, RELATED SHAREHOLDER MATTERS AND ISSUER PURCHASES OF EQUITY SECURITIES

Market

Information

Our common

stock is listed for trading on the OTCQB under the symbol “MCVT”. The transfer agent and registrar for our common stock

is Pacific Stock Transfer Company, 6725 Via Austi Parkway, Suite 300, Las Vegas, NV 89119. The following table sets forth

the high and low bid prices for our common stock as reported by the OTCPK in 2019 through September, and the OTCQB from October through

present. These quotations reflect inter-dealer prices, without retail mark-up, markdown, or commission, and may not represent actual

transactions. Trading in our common stock during the period represented was infrequent, exemplified by low trading volume and many

days during which no trades occurred.

Market Price Market Price

(High/Low) (High/Low)

Holders

As of

the date of this filing, we had approximately 253 holders of record of our common stock.

Dividends

On

February 15, 2019, our Board of Directors declared a cash dividend of $0.05 per share to our shareholders of record

as of March 8, 2019. The dividend was paid on March 15, 2019.

On

December 8, 2020, our Board of Directors declared a cash dividend of $0.05 per share to our shareholders of record

as of December 21, 2020. The dividend was paid on January 4, 2021.

Securities

Authorized for Issuance Under Equity Compensation Plans

As

of December 31, 2020, we had no outstanding options, warrants or other rights to purchase any equity securities of the

Company

under any equity compensation plan or “individual compensation arrangement,” as defined in Item 201 of Regulation S-K.

Furthermore, as of the date of this filing, we are not a party to any equity compensation plan, nor are we obligated under any

“individual compensation arrangement” to issue any options, warrants, rights or other securities. We are not required

by applicable state law or the listing standards of any self-regulatory agency (e.g., the OTCQX, NASD, AMEX or NYSE) to obtain the

approval of our security holders prior to issuing any such compensatory options, warrants or other rights to purchase securities

of the Company.

4

In August 2020,

the Compensation Committee approved, and the Company issued, 50,000 shares of restricted stock to each of Mr. Douglas M. Polinsky

and Joseph A. Geraci, II. The shares vest upon the one-year anniversary of their issuance and until such time are subject

to forfeiture.

Recent Sales of Unregistered Securities

None.

Recent Purchases of Securities

During

the course of 2020, the Company engaged in the following repurchases of its common stock, all of which were consummated in private

transactions:

ITEM 7

MANAGEMENT’S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF OPERATIONS

Our Management’s

Discussion and Analysis of Financial Condition and Results of Operations set forth below should be read in conjunction with our

audited financial statements, and notes thereto, filed together with this Form 10-K.

Cautionary

Note Regarding Forward-Looking Statements

Some of

the statements made in this section of our report are forward-looking statements. These forward-looking statements generally relate

to and are based upon our current plans, expectations, assumptions and projections about future events. Our management currently

believes that the various plans, expectations, and assumptions reflected in or suggested by these forward-looking statements are

reasonable. Nevertheless, all forward-looking statements involve risks and uncertainties and our actual actions or future results

may be materially different from the plans, objectives or expectations, or our assumptions and projections underlying our present

plans, objectives and expectations, which are expressed in this report. An example of specific factors that might cause our actual

results to differ from our current expectations include but are not limited to:

• The risks surrounding the new types of financing solutions we provide.

The foregoing list is not exhaustive, and

readers are urged to read carefully and consider the risk factors described elsewhere in this report. In light of the foregoing,

prospective investors are cautioned that the forward-looking statements included in this filing may ultimately prove to be inaccurate—even

materially inaccurate. Because of the significant uncertainties inherent in such forward-looking statements, the inclusion of such

information should not be regarded as a representation or warranty by the Company or any other person that our objectives, plans,

expectations or projections that are contained in this filing will be achieved in any specified time frame, if ever.

5

Results of Operations

For the Year Ended December 31,

Investment Income:

Operating Expenses:

For the year ended December 31, 2020, we earned

$44,026 in interest payments from one investment— DBR Enclave US Investors, LLC;— an aggregate of $993,795 from

six promissory note investments; an aggregate of $26,994 in bank interest on cash balances and note receivable; an aggregate

of $217,360 in origination fees; and an aggregate of $15,462 in dividend payments from four

investments—Manning & Napier, Inc., Educational Development Corp., Manhattan Bridge Capital, Inc.;

and Windstream Holdings, Inc.

For the year ended December 31, 2019, we earned

$78,264 in interest payments from one eligible portfolio company— DBR Enclave US Investors, LLC — an additional

$33,925 in bank interest on cash balances and note receivable; an aggregate of $46,293 in dividend payments from five

eligible portfolio companies—Manning & Napier, Inc., Simulations Plus, Inc., Tessco

Technologies, Inc., Educational Development Corp., and Taitron Components, Inc.; and $3,180 in dividends received

from non-eligible portfolio companies.

As the

table above indicates, we incurred operating expenses aggregating $735,790 for the year ended December 31, 2020, and $834,430

for the year ended December 31, 2019. A discussion of the various components of our operating expenses for these periods is

set forth below.

General Operating Expenses. Our

general operating expenses were $83,447 for the year ended December 31, 2020 and $111,757 for the year ended December 31,

2019. The decrease in the current period is primarily related to expenses incurred in 2019 for an off-site board meeting as well

as a decrease in our office lease premiums for the year 2020.

Legal and Accounting Expenses.

Our legal and accounting expenses were $175,612 for the year ended December 31, 2020 and $209,897 for the year ended December 31,

2019. The decrease in the current period is primarily related to costs we incurred during 2019 related to the process of planning

for, seeking, and obtaining authority for, the withdrawal of our BDC election.

Executive Management Compensation.

Our executive management compensation was $301,494 for the year ended December 31, 2020 and $340,003 for the year ended December 31,

2019. The decrease in the current period is primarily related to a one-time bonus payment made during the year 2019.

For the

year ended December 31, 2020 our net investment gain was $561,847. For the year ended December 31, 2019, our net investment

loss was $672,768. The increased net investment gain during 2020 was primarily the result of higher interest income earned during

2020 from the short-term specialty finance solutions we provided in the form of short-term promissory notes bearing higher rates

of interest and return, including related origination fees, than we were able to obtain when operating as a BDC.

6

Financial

Condition

For the

year ended December 31, 2020, we had an increase in net assets of $1,572,354. This increase in net assets was primarily due

to the appreciation of our portfolio holdings. Our net assets decreased by $1,210,356 for the year ended December 31, 2019,

primarily due to our payment of a dividend during 2019.

Liquidity

and Capital Resources

Summary

cash flow data is as follows:

Cash flows provided (used) by:

We are

not a party to any credit facilities or other sources of liquidity, and we have no present plans to become party to any credit

facility. As a result, our $5,440,579 of cash at the end fiscal 2020 and our $8,066,656 of cash at the end of fiscal 2019 constituted

our sole source of liquidity. Management believes cash on hand is sufficient to fund our anticipated operational and financing

activities through fiscal 2021.

Capital

Expenditures

We did

not have any material commitments for capital expenditures in fiscal 2020 and we do not anticipate any such capital expenditures

for fiscal 2021.

Off-Balance

Sheet Arrangements

We do

not have any off-balance sheet arrangements, nor are we a party to any contract or other obligation not included on its balance

sheet that has, or is reasonably likely to have, a current or future effect on our financial condition.

Critical

Accounting Policies

Critical

accounting policies are policies that are both most important to the portrayal of the Company’s financial condition and results,

and that require management’s most difficult, subjective or complex judgments, often as a result of the need to make estimates

about the effect of matters that are inherently uncertain. Our critical accounting policies relate to investment valuation and

interest and dividend income as an investment company.

Investment Valuation

Investment

transactions are recorded on the trade date. Realized gains or losses are measured by the difference between the net proceeds from

the repayment or sale and the amortized cost basis of the investment without regard to unrealized gains or losses previously recognized,

and include investments charged off during the period, net of recoveries. Unrealized gains or losses primarily reflect the change

in investment values, including the reversal of previously recorded unrealized gains or losses when gains or losses are realized.

Investments

for which market quotations are readily available are typically valued at such market quotations. In order to validate market

quotations, we look at a number of factors to determine if the quotations are representative of fair value, including the

source and nature of the quotations. Debt and equity securities that are not publicly traded or whose market prices are not

readily available are valued at fair value as determined in good faith by our Board of Directors or, during our time as BDC,

by the Valuation Committee of our Board of Directors, based on, among other things, the input of our executive management,

Audit Committee and independent third party valuation expert that may be engaged by management to assist in the valuation of

our portfolio investments. Valuation determinations are in all cases made in conformity with the written valuation policies

and procedures respecting the valuation of Company investments.

7

Use

of Estimates

Our financial

statements are prepared in accordance with accounting principles generally accepted in the United States of America, or GAAP. The

application of GAAP requires that we make estimates that affect our 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. We base our estimates on historical experience and on various other assumptions that we believe to be reasonable

under the circumstances. We evaluate our estimates and assumptions on an ongoing basis. Our actual results may differ significantly

from these estimates.

8

ITEM 8

FINANCIAL STATEMENTS AND SUPPLEMENTARY DATA

Item Page

Reports of Independent Registered Public Accounting Firm 10

Statements of Cash Flows — Years ended December 31, 2020 December 31, 2019 15

Notes to Financial Statements 18

9

REPORT OF INDEPENDENT REGISTERED PUBLIC

ACCOUNTING FIRM

To the Board of Directors and

Shareholders’ of Mill City Ventures III, Ltd.

Opinion on the Financial Statements

We have audited the accompanying balance

sheets of Mill City Ventures III, Ltd. (the Company) as of December 31, 2020 and 2019, including the investment schedules

and the related statements of operations, shareholders’ equity, and cash flows for each of the years in the two-year period

ended December 31, 2020 and 2019, and the related notes (collectively referred to as the financial statements). In our opinion,

the financial statements present fairly, in all material respects, the financial position of the Company as of December 31,

2020 and 2019, and the results of its operations and its cash flows for the years then ended, in conformity with accounting principles

generally accepted in the United States of America.

Basis for Opinion

These financial statements are the responsibility

of the Company’s management. Our responsibility is to express an opinion on the Company’s financial statements based

on our audits. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB)

and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable

rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audits in accordance with

the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether

the financial statements are free of material misstatement, whether due to error or fraud. The Company is not required to have,

nor were we engaged to perform, an audit of its internal control over financial reporting. As part of our audits, we are required

to obtain an understanding of internal control over financial reporting but not for the purpose of expressing an opinion on the

effectiveness of the Company’s internal control over financial reporting. Accordingly, we express no such opinion.

Our audits 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 audits 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 audits provide a

reasonable basis for our opinion.

Emphasis of Matter – Investment

Valuation

As explained in Note 7 to the financial

statements, the accompanying financial statements include investments valued at $3,367,897 and $834,200 for 2020 and 2019, respectively,

whose fair values have been estimated by the valuation committee and management in absence of readily determinable fair values.

Such estimates are based on financial and other information provided by management in absence of readily determinable fair values.

Such estimates are based on financial and other information provided by management of its portfolio companies and pertinent market

and industry data. These investments are valued in accordance with FASB ASC 820, “Fair Value Measurement”, which requires

the Company to assume that the portfolio investments are sold in a principal market to market participants. The Company has considered

its principal market as the market in which the Company exits its portfolio investments with the greatest volume and level of activity.

ASC 820 specifies a hierarchy of valuation techniques based on whether the inputs to these valuation techniques are observable

or unobservable. The investments are valued based on unobservable inputs as of December 31, 2020 and 2019 of $3,367,897 and

$834,200, respectively. Because such valuations, and particularly valuations of private investments and private companies, are

inherently uncertain, they may fluctuate significantly over short periods of time. These determinations of fair value could differ

materially from the values that would have been utilized had a ready market for these investments existed.

Critical Audit Matters

The critical audit matters communicated

below are matters arising from the current period audit of the financial statements that were communicated or required to be communicated

to the audit committee and that: (1) relate to accounts or disclosures that are material to the financial statements and (2) involved

our especially, subjective, or complex judgements. The communication of critical audit matters does not alter in any way our opinion

on the financial statements, taken as a whole, and we are not, by communicating the critical audit matters below, providing separate

opinions on the critical audit matters or on the accounts or disclosures to which they relate.

10

Valuation of investments which utilize

significant unobservable inputs

Boulay PLLP

We have served as the Company’s auditor

since 2019

Minneapolis, Minnesota

March 10, 2021

11

Mill City

Ventures III, Ltd.

Balance

Sheets

ASSETS

Receivable for sale of investments 19,313 —

Interest and dividend receivables 65,911 6,500

Property and equipment, net — 2,071

LIABILITIES

Accrued tax expense 13,722 —

Long-term deferred taxes 258,000 —

Commitments and Contingencies

SHAREHOLDERS EQUITY (NET ASSETS)

Net Asset Value Per Common Share $ 1.08 $ 0.91

The accompanying notes are an integral part

of these financial statements.

12

Mill City

Ventures III, Ltd.

Statements

of Operations

Year Ended

Investment Income

Operating Expenses

Depreciation and amortization 2,071 2,574

Realized and Unrealized Gain (Loss) on Investments

Net Realized and Unrealized Gain (Loss) on Investments 1,940,124 15,782

Provision for Income Taxes 288,401 —

Net Increase (Decrease) in Net Assets Resulting from Operations per share:

Basic and diluted $ 0.20 $ (0.06 )

The accompanying

notes are an integral part of these financial statements.

13

Mill City Ventures III, Ltd.

Statements of Shareholders’ Equity

For

the years ended December 31, 2020 and 2019

Net realized gain on investment transactions — — — — 5,330 — 5,330

Net realized gain on investment transactions — — — — 3,252,620 — 3,252,620

Depreciation in value of investments — — — — — (3,236,838 ) (3,236,838 )

The accompanying notes are an integral part

of these financial statements.

14

Mill

City Ventures III, Ltd.

Statements of Cash Flows

Year Ended

Cash flows from operating activities:

Proceeds from sales of investments sold short — 30,119

Stock-based compensation 61,000 —

Depreciation & amortization expense 2,071 2,574

Deferred income taxes 271,722 —

Changes in operating assets and liabilities:

Prepaid expenses and other assets 5,197 32,299

Payable for investment purchase —

Accounts payable and other liabilities (10,993 ) (28,677 )

Net cash provided (used) in operating activities (2,463,157 ) 7,653,905

Cash flows from financing activities:

Payments for repurchase of common stock (162,920 ) —

Payments for common stock dividend — (553,370 )

Supplemental disclosure of cash flow information:

Non-cash financing activities:

Dividend to common stock shareholders $ 539,296 $ —

The accompanying notes are an integral part

of these financial statements.

15

Mill City Ventures III, Ltd.

Investment Schedule

As of December 31, 2020

Investment / Industry Cost Fair Value Percentage of Net Assets

Short-Term Non-banking Loans

Real Estate - 15% secured loans

Common Stock

Consumer

Preferred Stock

Warrants

Other Equity

16

Investment Schedule

As of December 31,

2019

Equity Investments

Advertising

Consumer

Financial

Healthcare

Information Technology

Leisure & Hospitality

Oil & Gas

Publishing

(2) Interest is presented on a per annum basis.

(8) Investment is not an income-producing investment.

The accompanying notes are an integral part

of these financial statements.

17

NOTE

1 — ORGANIZATION

In this

report, we generally refer to Mill City Ventures III, Ltd. in the first person “we.” On occasion, we refer to

our company in the third person as “Mill City Ventures” or the “Company.” The Company follows accounting

and reporting guidance in Accounting Standards (“ASC”) 946.

We were

incorporated in Minnesota in January 2006. Until December 13, 2012, we were a development-stage company that focused on

promoting and placing a proprietary poker game online and into casinos and entertainment facilities nationwide. In 2013, we elected

to become a business development company (“BDC”) under the 1940 Act. We operated as a BDC until we withdrew our BDC

election on December 27, 2019. As of the time of this filing, we remain a public reporting company that files periodic reports

with the SEC. We offer short-term specialty finance solutions primarily to private businesses, small-cap public companies and high-net-worth

individuals. To avoid regulation under the 1940 Act, we generally seek to structure our investments so they do not constitute “investment

securities” for purposes of federal securities law, and we monitor our investments as a whole to ensure that no more than

40% of our total assets may consist of investment securities.

Because

we operated as a BDC or investment company from 2013 through December 27, 2019, the 2019 financial statements in this report

reflect our operations as a BDC subject to the 1940 Act including our December 31, 2019 balance sheet. During that time, we

were primarily focused on investing in or lending to privately held and small capitalization publicly traded U.S. companies, and

making managerial assistance available to such companies. A majority of our investments by dollar amount were structured as purchases

of preferred or common stock or loans evidenced by promissory notes that may have been convertible into stock by their terms or

that may have been accompanied by the issuance to us of warrants or similar rights to purchase stock. Our investment objective

is to generate income and capital appreciation that ultimately became realized gains.

NOTE

2 — SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

Use

of estimates: The preparation of financial statements in conformity with GAAP requires management and our independent

board members 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, as well as the reported amounts of expenses during

the reporting period. Actual results could differ from those estimates. For more information, see the “Valuation of portfolio

investments” caption below, and “Note 7 – Fair Value of Financial Instruments” below. The Company presents

its financial statements as an investment company following accounting and reporting guidance in ASC 946.

Cash

deposits: We maintain our cash balances in financial institutions and with regulated financial investment brokers.

Cash on deposit in excess of FDIC and similar coverage is subject to the usual banking risk of funds in excess of those limits.

Valuation

of portfolio investments: We carry our investments in accordance with ASC Topic 820, Fair Value Measurements

and Disclosures (“ASC 820”), issued by the Financial Accounting Standards Board (“FASB”), which

defines fair value, establishes a framework for measuring fair value, and requires disclosures about fair value measurements.

Fair value is generally based on quoted market prices provided by independent pricing services, broker or dealer quotations,

or alternative price sources. In the absence of quoted market prices, broker or dealer quotations, or alternative price

sources, investments are measured at fair value as determined by our Board of Directors or, during our time as BDC, by the

Valuation Committee of our Board of Directors, based on, among other things, the input of our executive management, the Audit

Committee of our Board of Directors, and any independent third-party valuation experts that may be engaged by management to

assist in the valuation of our portfolio investments, but in all cases consistent with our written valuation policies and

procedures.

Due to

the inherent uncertainties of valuation, certain estimated fair values may differ significantly from the values that would have

been realized had a ready market for these investments existed, and these differences could be material. In addition, such investments

are generally less liquid than publicly traded securities. If we were required to liquidate a portfolio investment in a forced

or liquidation sale, we could realize significantly less than the value at which we have recorded it.

Accounting guidance establishes a hierarchal

disclosure framework that prioritizes and ranks the level of market price observability of inputs used in measuring investments

at fair value. Observable inputs must be used when available. Observable inputs are inputs that market participants would use in

valuing the asset or liability based on market data obtained from independent sources. Unobservable inputs are inputs that reflect

our assumptions about the factors market participants would use in valuing the asset or liability based upon the best information

available. Assets and liabilities measured at fair value are to be categorized into one of the three hierarchy levels based on

Source: SEC EDGAR (public domain) · 10-K for the period ended 2020-12-31, filed 2021-03-10 · accession 0001104659-21-034228

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