# HEITMAN SECURITIES LLC X-17A-5 (2026-03-23) — Broker-dealer annual report - Company: HEITMAN SECURITIES LLC - Form: X-17A-5 - Filed: 2026-03-23 - Period: 2025-12-31 - Accession: 0000717551-26-000004 - CIK: 717551 - File #: 8-29393 - Type: Broker-dealer - Material weakness: Yes - Auditor: Deloitte - Auditor location: Chicago, IL - Contact: Carolyn Hoehn - Phone: 3124250292 - Email: christensen@heitman.com - Website: heitman.com - Signed by: Thomas D. McCarthy (Managing Director) Original filing: https://www.sec.gov/Archives/edgar/data/717551/000071755126000004/HSL2025AnnualReport.pdf --- {0}------------------------------------------------ # Heitman Securities LLC Financial Statements and Supplementary Schedules Pursuant to Rule 17a-5 of the Securities and Exchange Commission (With Report of Independent Registered Public Accounting Firm Thereon) December 31, 2025 ### Discover what makes us different. ©2025 Heitman LLC. All rights reserved. {1}------------------------------------------------ UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 OMB APPROVAL OMB Number: 3235-0123 Expires: Nov. 30, 2026 Estimated average burden hours per response: 12 SEC FILE NUMBER 8-A013620-J ### ANNUAL REPORTS FORM X-17A-5 PART III FACING PAGE Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934 AND ENDING 12/31/25 filing for the period beginning 01/01/25 MM/DD/YY MM/DD/YY A. REGISTRANT IDENTIFICATION ## NAME OF FIRM: HEITMAN SECURITIES LLC TYPE OF REGISTRANT (check all applicable boxes): | Broker-dealer | | Security-based swap dealer | | Major security-based swap participant □ Check here if respondent is also an OTC derivatives dealer ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) # 110 NORTH WACKER DRIVE - SUITE 4000 | | (No. and Street) | | | |-----------------------------------------------------------------------------------------------|------------------------------------------------------------|-----------------|--------------------------------------------| | CHICAGO | | | 60606 | | (City) | (State) | | (Zip Code) | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | | LAWRENCE J. CHRISTENSEN | 312-251-4827 | | Lawrence. Christensen@heitman.com | | (Name) | (Area Code - Telephone Number) | (Email Address) | | | | B. ACCOUNTANT IDENTIFICATION | | | | DELOITTE & TOUCHE LLP | (Name - if individual, state last, first, and middle name) | | | | 111 SOUTH WACKER DRIVE CHICAGO | | | 60606 | | (Address) | (City) | (State) | (Zip Code) | | (Date of Registration with PCAOB)(if applicable) | | | (PCAOB Registration Number, if applicable) | | | FOR OFFICIAL USE ONLY | | | | . I hame tor over the requirement that the appual ranges by the reported on incomprent public | | | | Clams for exemption from the requirement that the annual 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. {2}------------------------------------------------ #### OATH OR AFFIRMATION I THOMAS D. MCCARTHY \_, swear (or affirm) that, to the best of my knowledge and belief, the financial report pertaining to the firm of HEITMAN SECURITIES LLC as of 12/31 , 2025 is true and correct. I further 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 as that of a customer. Title: MANAGING DIRECTOR #### This filing \*\* contains (check all applicable boxes): - a) Statement of financial condition. - [ (b) Notes to consolidated statement of financial condition. - | (c) Statement of income (loss) or, if there is other comprehensive income in the period(s) presented, a statement of comprehensive income (as defined in § 210.1-02 of Regulation S-X). - = (d) Statement of cash flows. - [e) Statement of changes in stockholders' or partners' or sole proprietor's equity. - [ (f) Statement of changes in liabilities subordinated to claims of creditors. - = (g) Notes to consolidated financial statements. - (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-1, as applicable. - [ (i) Computation of tangible net worth under 17 CFR 240.18a-2. - [] Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3. - [ [k] 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. - [1) Computation for Determination of PAB Requirements under Exhibit A to § 240.15c3-3. - [ (m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3. - [n] Information relating to possession or control requirements for security-based swap customers under 17 CFR 240.15c3-3(p)(2) or 17 CFR 240.18a-4, as applicable. - [ (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capible net worth under 17 CFR 240.15c3-1, 17 CFR 240.18a-1, or 17 CFR 240.18a-2, as applicable, and the reserve requirements under 17 CFR 240.15c3-3 or 17 CFR 240.18a-4, as applicable, if material differences exist, or a statement that no material differences exist. - □ (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition. - [q] Oath or affirmation in accordance with 17 CFR 240.17a-5, 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable. - [r] Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - [s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - [ (t) Independent public accountant's report based on an examination of the statement of financial condition. - | |u) Independent public accountant's report based on an examination of the financial statements under 17 CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable. - [ {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. - @ (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. - | |x) Supplemental reports on applying agreed upon procedures, in accordance with 17 CFR 240.17a-12, as applicable. - | (y) Report describing any material inadequacies 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). - [ (z) 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(d)(2), as applicable. {3}------------------------------------------------ ## Table of Contents | Report of Independent Registered Public Accounting Firm | | |---------------------------------------------------------|--| | Financial Statements | | | Notes to Financial Statements | | | Supplementary Schedules | | #### Disclaimer Although the witten materials contained here prepared from sources and data presumed by Heitman makes no resertation or waranty, express or implied, with respect to their acuracy, timeliness. You are additionally informed that any information contained herein is always subject to change without notice. Finally, any statements contained herein that are "forvise are not historical facts but rather are based on expectations, estimates, projections and opinions of Heitman inknown risks, uncertainties and other factors. Actual events or results may differ materially from those refected or ontemplated in such statements and start and responsibility on liability for any loss or damage that may be incurred by any party who relies on the written materials contained herein. #### Confidentiality Notice The information contained herein is confidential and shall not be copied, in whole or in part, without the express written consent of Heitman, which may be withheld in Heitman's sole and absolute discretion. {4}------------------------------------------------ #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Member of Heitman Securities LLC #### Opinion on the Financial Statements We have audited the accompanying statement of financial condition of Heitman Securities LLC (the Company ) as of December 31, 2025, 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 the Company as of December 31, 2025, 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 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 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. #### Report on Supplemental Schedules The accompanying supplemental schedules I, II, and III have been subjected to audit procedures performed in conjunction with the audit of the Company s financial statements. The supplemental schedules are the responsibility of the Company 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. In forming our opinion on the supplemental schedules, we evaluated whether the supplemental schedules, including their form and content, are presented in compliance with Rule 17a-5 under the Securities Exchange Act of 1934. In our opinion, such schedules are fairly stated, in all material respects, in relation to the financial statements as a whole. February 25, 2026 We have served as the Company s auditor since 2018. {5}------------------------------------------------ ### Financial Statements #### Statement of Financial Condition, December 31, 2025 | Assets | | | |---------------------------------------|------|---------| | Cash and cash equivalents | ക്ക | 365,153 | | Placement fee receivables | | 32,066 | | Dividend receivable | | 243 | | Investment in stock | | 87,417 | | Other assets | | 7,347 | | Total assets | ಕ್ಕಾ | 492,226 | | | | | | Liabilities and Member's Equity | | | | Accounts payable | ಿಕ | 35,000 | | Due to Parent | | 312,292 | | Member's equity | | 144,934 | | Total liabilities and member's equity | ക | 492,226 | {6}------------------------------------------------ #### Statement of Operations, Year ended December 31, 2025 | Revenue: | | | |----------------------------------------|------|----------| | Placement fees | ക്ക | 47,967 | | Unrealized gain on investment in stock | | 17,838 | | Dividend income | | 945 | | Interest income | | 2,996 | | Total revenue | | 69,746 | | Expenses: | | | | Audit fees | | 36,626 | | Annual license fees | | 3,395 | | Corporate allocation | | 61,000 | | State income taxes | | 800 | | Other | | 6,336 | | Total expenses | | 108,157 | | Net loss | ಕ್ಕಿ | (38,411) | {7}------------------------------------------------ #### Statement of Changes in Member's Equity, Year ended December 31, 2025 | Balance - January 1, 2025 | 183.345 | |-----------------------------|----------| | Net loss | (38.411) | | Balance - December 31, 2025 | 144.934 | {8}------------------------------------------------ #### Statement of Cash Flows, Year ended December 31, 2025 | Cash flows provided by operating activities: | | | |---------------------------------------------------------------------------------|-----|----------| | Net loss | ಿಕಿ | (38,411) | | Adjustments to reconcile net loss to net cash provided by operating activities: | | | | Increase in Due to Parent | | 62.870 | | Decrease in placement fee receivables | | 52,033 | | Increase in investment in stock | | (17,838) | | Increase in dividend receivable | | (27) | | Increase in other assets | | (2,544) | | Increase in accounts payable | | 19,564 | | Net cash provided by operating activities | | 75,647 | | Net increase in cash and cash equivalents | | 75,647 | | Cash and cash equivalents at beginning of year | | 289,506 | | Cash and cash equivalents at end of year | ಕಿ | 365,153 | | Supplemental disclosure of income taxes paid:
State income taxes | ಿಕಿ | 800 | {9}------------------------------------------------ ### Notes to Financial Statements #### 1. Summary of Significant Accounting Policies #### (A) ORGANIZATION Heitman Securities LLC (the Company) is a wholly owned subsidiary of Heitman Financial Services LLC (HFSL), which is a wholly owned subsidiary of Heitman LLC (HLC or the Parent), a limited liability company with two members of HLLC are KE I LLC and KE 2 LLC, limited liability companies consisting of employees of HLLC. The Company is a registered broker-dealer with the Securities and a member of the Financial Industry Regulatory Authority. The Company earns fees from affiliates for services it provides as a placement agent with respect to marketing interests in limited partnerships and similar vehicles sponsored by such affiliates. #### (B) USE OF ESTIMATES The preparation of financial statements in conformity with U.S. generally accepted accounting principles requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosures of contingent assets and liablities at the date of the financial statements and the reported amounts of revenues and expenses of the reporting period. Actual results could differ from those estimates. #### (C) CASH AND CASH EQUIVALENTS The Company considers all highly liquid investments with original maturities of three months or less, including \$340,153 in a money market fund. The money market fund is considered to use a level 1 input on the fair value hierarchy. #### (D) REVENUE RECOGNITION Revenue includes fees from affiliates of the Parent for services it provides as a placement agent with respect to marketing limited partnerships and similar vehicles sponsored by such affiliates of the Parent. Revenue is recognized as the performance obligations are satisfied under reasonable, estimated terms. On an annual basis, management reassesses the astimates, and if necessary, management will adjust the service period to appropriately reflect the length of performance obligations. During the year ended December 31, 2025, management reasses the service period related to two contracts and determined that the period over which revenue is recognized to more accurately reflect the length of the performance obligations. This resulted in a cumulative-effect adjustment fee receivable and placement fee revenue by \$13,924. Management believes the adjusted service periods best reflect the remaining performance obligations for the two contracts. As of December 31, 2025, \$142,935 of placement fee revenue on existing contracts has vet to be earned and will be recognized in future periods, which includes \$16,667 related to a limited partnership that paused revenue recognition during 2023 due to a pause in marketing services. The marketing services remained paused during 2025. Dividend income is recorded on the ex-date. #### (E) RECENT ACCOUNTING PRONOUNCEMENTS The Company evaluated recently issued acounting standards or pronouncements and determined such standards or pronouncements are either not relevant to the Company or not expected to have a material effect on the Company's financial statements. #### 2. Income Taxes The Company is a single member limited liability company. No provision for income taxes is made in the accompanying financial statements since the Company is treated as a disregarded entity for federal income tax purposes. In certain instances, the Company may be subject to certain state and local taxes which are not material to the financial statements. HFSL, the sole member of the Company, is also a disregarded entity for federal income the members of HLLC, a partnership, would be responsible for recording the Company's income tax returns. The Company had no unrecognized tax benefits as of or during the year ended December 31, 2025. {10}------------------------------------------------ The Company is registered with the State of California and has paid the required yearly tax payment of \$800 to the corresponding Franchise Tax Board. For the year ended December 31, 2025, the Company had state income of \$800, which is included in the statement of operations. #### 3. Rule 15c3-3 The Company is relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. §240.17a-5 because the Company linits its business activity exclusively to: (1) effecting securities on a subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and (2) participating in distributions of securities (other than firm commitment underwritings) in accordance with the requirements of paragraphs (a) or (b)(2) of Rule 15c2-4, and 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 and/or funds received and promptly transmitted for effecting transactions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company); (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. #### 4. Net Capital Requirements The Company is subject to the Securities and Exchange Commission's Uniform Net Capital Rule 15c3-1) and is required to maintain minimum net capital equivalent to \$5,000 or 6%% of aggregate indebtedness, whichever is greater, as these terms are defined. Rule 15c3-1 restricts a broker-dealer from engaging in any securities transactions when its aggregate indebtedness exceeds 15 times its net capital as those terms are defined by Rule 15c3-1. Net capital and aggregate indebtedness change from day to day. At December 31, 2025, the Company had net capital of \$85,362, which was \$62,209 in excess of its required capital of \$23,153. The Company had aggregate indebtedness of \$347,292 and ratio of aggregate indebtnedness to net capital of 4.07 at December 31, 2025. #### 5. Investment in Stock As of December 31, 2025, the Company had an investment of 900 common stock in NASDAQ, Inc. The Company believes that the carrying amount of its financial instruments is a reasonable estimate of fair value as it is based upon closing prices of the underlying shares of stock. Pursuant to Financial Accounting Standard Codification ("ASC") 820, Fair Value Measurements, the Company values stock using market quotations that are considered to be Linputs are defined as unadjusted quoted prices in active markets for identical assets or liabilities accessible to the measurement date. Additionally, pursuant to ASC 940, Financial Services – Broker and losses that are composed of both realized and unrealized gains and losses shall be presented net in the statement of operations. #### 6. Transactions with Affiliates #### (A) DUE TO PARENT The Company had a balance due to HLLC of \$249,422 as of December 31, 2024 for costs incurred by the Company but paid by HLLC. During 2025, an additional \$62,870 in costs were incurred, resulting in a balance due to HLLC of \$312,292 as of December 31, 2025. This balance is reflected as Due to Parent in the accompanying statement of financial condition. The Parent has agreed to provide financial support to the Company, as needed, to satisfy all liabilities and future obligations of the Company until at least June 30, 2027. #### (B) PLACEMENT FEE RECEIVABLES As referenced in the Revenue Recognition Footnote 1(d), Revenue includes for services it provides as a placement agent with respect to marketing limited partnerships and similar vehicles sponsored by such affliates. The Company had a placement fee receivable balance of \$84,099 as of December 31, 2024. During 2025, the Company earned an additional \$47,967 in placement fee reved \$100,000 in cash payments, resulting in a placement fee receivable balance of \$32,066 as of December 31, 2025. This balance is refected as Placement fee receivables in the accompanying statement of financial condition. {11}------------------------------------------------ #### (C) CORPORATE ALLOCATION In addition to specific operating expenses incurred by the Company and charged directly to operations, certain compensation and ocupancy costs are incurred in common for the Company by HLC. Pursuant to an agreement with HLC, the Company was allocated \$61,000 in costs during 2025: | Overhead costs: | | | |---------------------------------------------|-------|--------| | Wages and related expenses | ਰਿੱ | 10,000 | | Professional fees | | 5,950 | | Telephone | | 160 | | Office supplies | | 90 | | Equipment rental and repairs | | 3.470 | | Insurance and taxes | | 540 | | Postage and freight | | 40 | | Miscellaneous other | | 10,820 | | Rent | | 2,940 | | Depreciation and amortization | | 990 | | Total overhead allocated | | 35,000 | | Compliance activities | | 17,000 | | Anti Money Laundering compliance activities | | 9,000 | | Total annual charges | ਦਿੱਤੇ | 61,000 | These costs are considered noninterest-bearing bans that are repayable on demand but in no event later than December 31, 2026, and are part of the Due to Parent balance on the statement of financial condition. In the opinion of management, the aforementioned corporate allocation is believed to be reasonable, however, the allocated costs are not necessarily indicative of the expenses the Company may have incurred on its own account. #### 7. Segment Reporting The Company is engaged in a single line of business as a securities broker-dealer, which is the limited partnerships and similar vehicles sponsored by such affiliates of the Parent. The Company has identified its Board of Managers as the chief operating decision maker ("CODM"), who uses net income (loss) to evaluate the results of the business and to manage the Company. Additionally, the CODM uses excess net capital (see Note 4), which is not a measure of profit and loss, to make operational decisions while maintaining capital adequacy. The Company's operating segment and therefore, a single reportable segment, because the CODM manages the business activities using information of the CODM is reqularly provided with only the consolidated expenses as noted on the face of the statement of operations, and no other significant segment expenses are regularly provided to the CODM. The acounting policies used to measure the profit and loss of the segment are the same as those described in the summary of significant accounting policies (see Note 1). The measure of segment assets is reported on the statement of financial condition as total assets. For the year ended December 31, 2025, the Company did not have any depreciation expense, capital expenditures or significant non-cash activities. For the year ended December 31, 2025, the Company had \$6,336 in other expenses on the statement of operations, which include organization membership dues, publication subscriptions, and bank fees. #### 8. Commitments and Contingencies In the ordinary course of business, there are various claims and lawsuits brought by or against the Company. As of the year, there were no such claims or lawsuits brought by or against the Company. #### 9. Subsequent Events Subsequent to December 31, 2025 and through February 25, 2026, the date through which management events and on which date the financial statements were available to be issued, the Company did not identify any subsequent events. {12}------------------------------------------------ ## Supplementary Schedules ### Schedule I – Computation of Net Capital and Aggregate Indebtedness under Rule 15c3-1 of the Securities and Exchange Commission, December 31, 2025 | Total member's equity
Less nonallowable assets | ત્ત્વ | 144,934
39,656 | |------------------------------------------------------------------------------------------------------------------------------------------------|-------|-------------------| | Net capital before haircuts | | 105.278 | | Haircuts on exempt securities (cash equivalents) | | 6.803 | | Haircuts on other securities | | 13,113 | | Net capital | | 85,362 | | Net capital required (the greater of \$5,000 or 6%% of aggregate indebtedness) | | 23,153 | | Excess net capital | ക്ക | 62,209 | | Aggregate indebtedness | ക്ക | 347,292 | | Ratio of aggregate indebtedness to net capital | | 4.07 | | There are no material differences between the preceding computation and
the Company's corresponding unaudited part II of Form X-17A-5 as of | | | December 31, 2025, which was filed on February 24, 2026. See accompanying report of independent registered public accounting firm. {13}------------------------------------------------ #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Member of Heitman Securities LLC We have reviewed management s statements, included in the accompanying Exemption Report (the Exemption Report ), in which Heitman Securities LLC (the Company ) stated that the Company did not claim an exemption under paragraph (k) of 17 C.F.R. § 240.15c3-3 and the Company is filing the Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 ("Footnote 74") because the Company limited its business activities exclusively to: (1) effecting securities transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company; and (2) participating in distributions of securities (other than firm commitment underwritings) in accordance with the requirements of paragraphs (a) or (b)(2) of Rule 15c2-4, and the Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers; (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3), throughout the year ended December 31, 2025, without exception. The Company s management is responsible for its compliance with the eligibility requirements to file an Exemption Report in reliance on Footnote 74 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 reliance on Footnote 74. 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 Footnote 74. February 25, 2026 {14}------------------------------------------------ ### Schedule II - Computation for Determination of Customer Reserve Requirements and PAB Accounts Reserve Requirements under Rule 15c3-3 of the Securities and Exchange Commission, December 31, 2025 The Company is 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 activity exclusively to: (1) effecting securities transactions via subscription way basis where the funds are payable to the issuer or its agent and (2) participating in distributions of securities (other than firm commitment underwritings) in accordance with the requirements of paragraphs (a) or (b)(2) of Rule 15c2-4, and 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 and/or funds received and promptly transmitted for effecting transactions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company); (2) did not carry accounts of or for customers; and (3) did not carry PAB acounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception. {15}------------------------------------------------ #### Schedule III - Information Related to Possession or Control Requirements under Rule 15c3-3 of the Securities and Exchange Commission, December 31, 2025 The Company is 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 activity exclusively to: (1) effecting securities transactions way basis where the funds are payable to the issuer or its agent and (2) participating in distributions of securities (other than firm commitment underwritings) in accordance with the requirements of paragraphs (a) or (b)(2) of Rule 15c2-4, and 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 15c2ived and promptly transmitted for effecting transactions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company); (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. Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.