# PALICO LLC X-17A-5 (2026-05-13) — Broker-dealer annual report - Company: PALICO LLC - Form: X-17A-5 - Filed: 2026-05-13 - Period: 2025-12-31 - Accession: 0000757054-26-000004 - CIK: 757054 - File #: 8-32983 - Type: Broker-dealer - Material weakness: No - Auditor: Katz Sapper & Miller LLP - Auditor location: New York, NY - Contact: Kenneth Boyar - Phone: 9176960316 - Email: ken.boyar@palico.com - Website: palico.com - Signed by: Kenneth Boyar (FINOP) Original filing: https://www.sec.gov/Archives/edgar/data/757054/000075705426000004/financialstmtwoath2025.pdf --- {0}------------------------------------------------ | 8-32983 | | |---------|--| | 01/01/25
12/31/25 | | | | | | |----------------------------------|--------------------------------------|------|-------|--|--| | | | | | | | | | | | | | | | Palico LLC | | | | | | | ■ | | | | | | | | | | | | | | 126 East 56th Street, Suite 1200 | | | | | | | | | | | | | | New York | New York
10022 | | | | | | | | | | | | | | | | | | | | Kenneth Boyar | 917-696-0316
ken.boyar@palico.com | | | | | | | | | | | | | | | | | | | | Katz Sapper & Miller, LLP | | | | | | | | | | | | | | 488 Madison Avenue | New York | NY | 10022 | | | | November 13, 2006 | | 2804 | | | | | | | | | | | | | | | | | | {1}------------------------------------------------ | Kenneth Boyar | | |---------------|--| | Palico LLC | | December 31 025 | Signature: | Kenneth Boyar | |------------|---------------| | - | | FINOP - - - - - - - - - - - - - - - - - - - - - - - - - - - {2}------------------------------------------------ ![](_page_2_Picture_0.jpeg) *Report of Independent Registered Public Accounting Firm* To the Member of Palico LLC # *Opinion on the Financial Statements* We have audited the accompanying statement of financial condition of Palico LLC as of December 31, 2025, and the related statements of operations, changes in member's equity and cash flows for the year then ended, and the related notes and schedules (collectively referred to as the financial statements). In our opinion, the financial statements present fairly, in all material respects, the financial position of Palico LLC 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 Palico LLC's management. Our responsibility is to express an opinion on Palico LLC's financial statements based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to Palico LLC in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion. 1 {3}------------------------------------------------ # *Auditor's Report on Supplemental Information* The accompanying information contained in the Schedules of Computation of Net Capital Under SEC Rule 15c3-1, Computation for Determination of Reserve Requirements Under Rule 15c3-3 of the Securities and Exchange Commission, and Information Relating to Possession or Control Requirements Under Rule 15c3-3 of the Securities and Exchange Commission (Exemption) have been subjected to audit procedures performed in conjunction with the audit of Palico LLC's financial statements. The supplemental information is the responsibility of Palico LLC's management. Our audit procedures included determining whether the supplemental information reconciles to the financial statements or the underlying accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the supplemental information. In forming our opinion on the supplemental information, we evaluated whether the supplemental information, including its form and content, is presented in conformity with 17 C.F.R. §240.17a-5. In our opinion, the supplemental information contained in the Schedules of Computation of Net Capital Under SEC Rule 15c3-1, Computation for Determination of Reserve Requirements Under Rule 15c3-3 of the Securities and Exchange Commission, and Information Relating to Possession or Control Requirements Under Rule 15c3-3 of the Securities Exchange Commission (Exemption) are fairly stated, in all material respects, in relation to the financial statements as a whole. We have served as Palico LLC's auditor since 2014. reive New York, New York March 25, 2026 {4}------------------------------------------------ # (A LIMITED LIABILITY COMPANY) # FINANCIAL STATEMENTS DECEMBER 31, 2025 {5}------------------------------------------------ #### (A LIMITED LIABILITY COMPANY) # TABLE OF CONTENTS | | PAGE | |---------------------------------------------------------|--------| | REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM | 1 - 2 | | FINANCIAL STATEMENTS: | | | STATEMENT OF FINANCIAL CONDITION | 3 | | STATEMENT OF OPERATIONS | 4 | | STATEMENT OF CHANGES IN MEMBER'S EQUITY | 5 | | STATEMENT OF CASH FLOWS | 6 | | NOTES TO FINANCIAL STATEMENTS | 7 - 12 | | SUPPLEMENTARY SCHEDULES: | | | COMPUTATION OF NET CAPITAL UNDER SEC RULE 15c3-1 | 13 | | COMPUTATION FOR DETERMINATION OF RESERVE | 14 | | REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES | | | AND EXCHANGE COMMISSION | | | INFORMATION RELATING TO POSSESSION OR CONTROL | | | REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES | | | AND EXCHANGE COMMISSION (EXEMPTION) | | | REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM | | | ON EXEMPTION REPORT | | | EXEMPTION REPORT | | {6}------------------------------------------------ #### STATEMENT OF FINANCIAL CONDITION #### DECEMBER 31, 2025 #### *ASSETS* | Current Assets: | | |---------------------------------------|---------------| | Cash | \$
57,797 | | Accounts Receivable | 16,659 | | Due from Parent | 71,122 | | Total Current Assets | 145,578 | | | | | Total Assets | \$
145,578 | | LIABILITIES AND MEMBER'S EQUITY | | | Current Liabilities: | | | Accounts Payable and Accrued Expenses | \$
35,574 | | Total Current Liabilities | 35,574 | | Member's Equity: | | | Member's Equity | 110,004 | |-----------------------|---------| | Total Member's Equity | 110,004 | | | | | Total Liabilities and Member's Equity | \$
145,578 | |---------------------------------------|---------------| The accompanying notes are an integral part of the financial statements. {7}------------------------------------------------ #### STATEMENT OF OPERATIONS #### FOR THE YEAR ENDED DECEMBER 31, 2025 | Revenue from Commissions | \$
210,406 | |-----------------------------------|---------------| | Total Revenues | \$
210,406 | | Operating Expenses: | | | Regulatory and Consulting Expense | \$
86,067 | | Payroll | 15,000 | | Professional Fees | 24,598 | | Payroll Taxes | 1,470 | | Computer and Internet | 3,359 | | Insurance | 707 | | Bank Charges | 680 | | Office Expenses | 2,855 | | Total Operating Expenses | 134,736 | | Other Income (Expense) | | | Interest Income | 1,122 | | Net Income | \$
76,792 | The accompanying notes are an integral part of the financial statements. {8}------------------------------------------------ #### STATEMENT OF CHANGES IN MEMBER'S EQUITY #### FOR THE YEAR ENDED DECEMBER 31, 2025 | | Member's
Equity | |------------------------------|--------------------| | Balance at January 1, 2025 | \$
33,212 | | Net Income | 76,792 | | Balance at December 31, 2025 | \$
110,004 | {9}------------------------------------------------ #### STATEMENT OF CASH FLOWS #### FOR THE YEAR ENDED DECEMBER 31, 2025 | Cash Flows From Operating Activities: | | |-------------------------------------------------|--------------| | Net Income | \$
76,792 | | Adjustments To Reconcile Net Income To Net Cash | | | Provided by Operating Activities: | | | (Increase) Decrease in Current Assets | | | Accounts Receivable | 3,941 | | Prepaid Expenses | 101 | | Increase or (Decrease) in Current Liabilities: | | | Accounts Payable and Accrued Expenses | 13,073 | | Net Cash Provided by Operating Activities | 93,907 | | Cash Flows From Investing Activities: | | | Due from Parent (Borrowings) | (71,122) | | Net Cash Used by Investing Activities | (71,122) | | Net Increase in Cash | 22,785 | | Cash at Beginning of Year | 35,012 | | Cash at End of Year | \$
57,797 | {10}------------------------------------------------ #### NOTES TO FINANCIAL STATEMENTS # DECEMBER 31, 2025 # *NOTE 1 – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES* #### *A) Nature of Business* Palico LLC ("The Company") was established in January 2001 and operates a platform that provides to its clients a listing of private and secondary placement offerings (the "Platform"). The Platform is utilized by Investors to initiate contact with a Sponsor who can then provide the Investor with additional information regarding the Sponsor as well as information about specific investment opportunities. The Platform does not function as a placement agent or finder. The Company's revenues are generated from subscription fees charged for becoming a user of the Platform and success fees from secondary private placement transactions. In June 2024, the Company applied and was granted permission by FINRA to operate as an Alternative Trading System (ATS), see Note C. The Company is a broker-dealer registered with the Securities and Exchange Commission, a member of the Financial Industry Regulatory Authority ("FINRA") as well as the Securities Investor Protection Corporation ("SIPC"). # *B) Basis of Accounting* The Company's financial statements are prepared in accordance with accounting principles generally accepted in the United States of America. # *C) Revenue Recognition / Deferred Revenue* The Company may receive subscription fees from its clients. The revenue arising from fees received in advance of subscription services rendered are deferred until the services are transferred to the client. Revenue is essentially recognized over the period in which information is available to the subscribers. No subscription fees were earned in 2025. The Platform, in its capacity as an ATS, offers a comprehensive suite of features for both sellers and buyers in the secondary private placement market. The Platform ensures a seamless and efficient transaction process for all parties. The Company's performance obligations are met, and the success fee revenue is recognized when the transaction is complete, denoted by the executed sale and purchase agreements or similar closing documents. Generally, 100% of the success fee is paid when invoiced. The Company has been granted a license agreement to use the Platform by Palico SAS (Parent), at no cost to the Company. Any other cost associated with the Platform is minimum and expensed when incurred. See Note J. Revenue from three clients comprised 93% of total revenue for 2025. {11}------------------------------------------------ #### NOTES TO FINANCIAL STATEMENTS #### DECEMBER 31, 2025 #### *NOTE 1 – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES - (continued)* #### D) *Recently Adopted Accounting Standards* In December 2023, the FASB issued Accounting Standards Update (ASU) No. 2023-09 I*ncome Taxes (Topic 740)*: *Improvements to Income Tax Disclosures* (ASU 2023-09). ASU 2023-09 requires additional annual disclosures including further disaggregation of information in the rate reconciliation, additional information for reconciling items meeting quantitative threshold, further disaggregation of income taxes paid and other required disclosures. The Company adopted ASU-2023-09 for the annual period beginning January 1, 2025. #### *E) Regulatory Requirements* #### *Broker-Dealer-* The Company is registered as a broker-dealer and, accordingly, is subject to the net capital rules of the Securities and Exchange Commission (SEC), and FINRA. Under these rules, the Company is required to maintain a minimum of Net Capital, as defined under SEC Rule 15c3-1. #### *Accounts Receivable-* Accounts Receivable are uncollateralized customer obligations generally requiring payment under normal trade terms pursuant to the dates included in the invoice and do not bear interest. Accounts receivable are recorded at invoiced amounts, reduced by an allowance for credit losses, if any. The allowance is determined by using historical loss information by aging category adjusted for current economic conditions and reasonable and supportable forecasts. No allowance for credit losses was necessary at December 31, 2025. #### *F) Broker-Dealer Single Reportable Segment* In accordance with FASB ASC Topic 280, *Segment Reporting*, the Company is engaged in a single line of business as a securities broker-dealer, which is comprised of several classes of services. The Company has identified its President as the chief operating decision maker ("CODM"), who uses net income to evaluate the results of the business, predominantly in the forecasting process, to manage the Company. Additionally, the CODM uses excess net capital, which is not a measure of profit and loss, to make operational decisions while maintaining capital adequacy, such as whether to reinvest profits or pay dividends. The Company's operations constitute a single operating segment and therefore, a single reportable segment, because the CODM manages the business activities using information of the Company as a whole. {12}------------------------------------------------ # NOTES TO FINANCIAL STATEMENTS # DECEMBER 31, 2025 # *NOTE 1 – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES - (continued)* #### *F) Broker-Dealer Single Reportable Segment (continued)* The accounting policies used to measure the profit and loss of the segment are the same as those described in the summary of significant accounting policies. # *G) 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 financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates. #### *H) Income Taxes* The Company was formed as a single member LLC however, it has elected to be treated as a corporation for federal and state income tax purposes. The Company follows the provision of FASB ASC 740-10-50-8. The provision for income taxes represents the amount of federal, state, and local income taxes which are currently reportable to the respective tax authorities and is measured by applying statutory rates to the Company's taxable income as reported in its tax returns. The Company has adopted the provision of FASB ASC Topic 740, Income Taxes, which prescribes a recognition threshold and measurement attribute for financial statement recognition and measurement of tax position taken or expected to be taken in a tax return. For those benefits to be recognized, a tax position must be more-likely-than-not to be sustained upon examination by taxing authorities. For the period ended December 31, 2025, the Company has no material uncertain tax positions to be accounted for in the financial statements under the new rules. The Company recognizes interest and penalties, if any, related to unrecognized tax benefits in interest expense. Deferred tax assets and liabilities are recognized based upon the difference between the financial statement carrying amounts of existing assets and liabilities and their respective tax bases. They are measured using enacted rates in the years in which those temporary differences are expected to reverse. The Company's deferred tax asset arises from net operating losses. {13}------------------------------------------------ # NOTES TO FINANCIAL STATEMENTS # DECEMBER 31, 2025 # *NOTE 1 – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES - (continued)* #### *H) Income Taxes (continued)* The Company has deductions available for tax return reporting purposes, net operating losses that total \$1,957,783 as of December 31, 2025. The deferred tax asset, available from these net operating losses, expires over the next 20 years beginning with the year ending December 31, 2029 and is based upon the Company's future taxable income. However, the portion of these losses created from years beginning January 1, 2018 can be carried forward indefinitely. Due to the uncertainties relating to the realization of the deferred tax asset (based on generating sufficient taxable income prior to the expiration of loss carry forwards and other temporary differences), management believes that the deferred tax asset may not be realized. Thus, the deferred tax asset has been offset by an equivalent valuation allowance at December 31, 2025. The Company is subject to routine audits by taxing jurisdiction; however, there are currently no audits for any tax periods in progress. Management believes it is no longer subject to income tax examinations for the years prior to 2022. As of December 31, 2025, the Company remains subject to examinations in the New York State and New York City tax jurisdictions for tax years 2022- 2024. # *I) Subsequent Event* The Company has performed an evaluation of subsequent events through March 25, 2026, which is the date the financial statements were available to be issued, noting no events which affect the financial statements as of December 31, 2025. See Note 3. # *J) Liquidity* The Company is both an investor-relationship building network connecting general partners, limited partners and placement agents, as well as an ATS. Under this updated model, Palico SAS (Parent) operates the platform fully. For the year ended December 31, 2025, the revenue has allowed the Company to meet its business obligations. In prior years, the Company also received capital contributions made by its Parent. This Parent has the intent and ability to continue making contributions if needed. {14}------------------------------------------------ #### NOTES TO FINANCIAL STATEMENTS #### DECEMBER 31, 2025 #### *NOTE 2 – CONCENTRATIONS OF CREDIT RISK* . All of the Company's cash is maintained in a single bank. The Company has exposure to credit risk to the extent its cash exceeds the amounts covered by federal deposit insurance. For the year ended December 31, 2025, the amounts covered by federal deposit insurance is \$250,000. As of December 31, 2025, there were no uninsured amounts. #### *NOTE 3 – RELATED PARTY TRANSACTIONS* The Company and the Parent, entered into a revolving credit agreement (Agreement), effective July 1, 202 whereby both parties agree that from time to time they shall lend to each other sums of money on a revolving basis as requested and accepted under the terms specified in the Agreement. The interest rate shall be agreed to by the borrower and the lender at the effective date of the borrowings and principal and interest is due on demand with no stated maturity date. As of December 31, 2025, the amount of \$70,000 is due from the Parent company in addition to accrued interest at the rate of 5% per annum, equal to \$1,122. Certain operating expenses incurred by the Parent during 2025 benefited both the Parent and the Company, including salaries and benefits of personnel, professional fees, and cost associated with the platform. These costs are recorded by the Parent and have not been allocated to the Company. Accordingly, the Company has not recorded any related expenses or payables in connection with these costs. The Parent, beginning in 2026 intends to implement a management fee arrangement for these shared services to more closely align operating costs between the Company and the Parent. #### *NOTE 4 – DEFERRED TAXES* The deferred tax asset and the related offsetting valuation at December 31, 2025 is comprised of the following: Deferred: | Federal Corporation Tax | \$ 411,134 | |-------------------------------------------------|------------| | New York State Franchise Tax | 127,256 | | New York City Corporation Income Tax
156,623 | | | | 695,013 | | Less Valuation Allowance | (695,013) | | Deferred Tax Asset | \$
-0- | {15}------------------------------------------------ # NOTES TO FINANCIAL STATEMENTS # DECEMBER 31, 2025 # *NOTE 5 – PROVISION (BENEFIT) FOR INCOME TAXES* The Provision (Benefit) for Income Taxes consists of the following: Current: | | Federal
New York State | \$
0
0 | |-----------|--------------------------------------|--------------| | | New York City | 0 | | | Total | 0 | | Deferred: | | | | | Federal Corporation Tax | 6,165 | | | New York State Franchise Tax | 5,003 | | | New York City Corporation Income Tax | 6,158 | | | | 27,325 | | | 'HFUHDVHin Valuation Allowance | 27,325 | Total Deferred -\_\_\_ # *NOTE 6 – NET CAPITAL REQUIREMENTS* The Company is subject to the Securities and Exchange Commission Uniform Net Capital Rule (Rule 15c3-1) which requires the maintenance of minimum net capital and requires the ratio of aggregate indebtedness to net capital, both as defined, shall not exceed 15 to 1. As of December 31, 2025, the minimum net capital was defined as the greater of \$5,000 or 6-2/3% of the aggregate indebtedness. As of December 31, 2025, the Company had net capital of \$22,223 which was \$17,223 in excess of its required net capital of \$5,000. The Company's net capital ratio was 1.60 to 1. {16}------------------------------------------------ # SUPPLEMENTARY SCHEDULES # DECEMBER 31, 2025 {17}------------------------------------------------ #### COMPUTATION OF NET CAPITAL UNDER SEC RULE 15c3-1 #### DECEMBER 31, 2025 | Net capital | | |---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------| | Total member's equity | \$
110,004 | | Deduct: member's equity not allowable for net capital | - | | Total member's equity qualifies for net capital | 110,004 | | Add: subordinated borrowings allowable in computation of net capital | - | | Total capital and allowable subordinated liabilities | 110,004 | | Deductions and/or changes: | | | Non-allowable assets: | | | Accounts Receivable | 16,659 | | Due from Parent | 71,122 | | Total deductions and/or changes: | 87,781 | | Net capital before haircuts on securities positions
Haircuts on securities | 22,223
- | | Net capital | \$
22,223 | | Aggregate indebtedness
Items included in statement of financial condition:
Account payable, accrued liabilities, accrued expenses
and other items included in statement of financial condition | \$
35,574 | | Total aggregate indebtedness | \$
35,574 | | Minimum net capital required | \$
5,000 | | Excess net capital | \$
17,223 | | Excess net capital of the greater of 10 percent of total aggregate indebtedness | \$
16,223 | | Or 120 percent of minimum net capital required | | | Ratio of aggregate indebtedness to net capital | 1.60 to 1 | | Reconciliation with Company's computation of (included in
Part II of Form X-17A-5 as of December 31, 2025)
Net capital, as reported in Company's Part II (un-audited) | | | FOCUS report
Net audit adjustments resulting in increased capital | \$
22,223 | | Net capital per above | \$
22,223 | See report of independent registered public accounting firm. {18}------------------------------------------------ # COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION AS OF DECEMBER 31, 2025 The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240. 15c3-3 and is relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5. # INFORMATION RELATING TO POSSESSION OR CONTROL REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION (EXEMPTION) The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240. 15c3-3 and is relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5. {19}------------------------------------------------ ![](_page_19_Picture_0.jpeg) *Report of Independent Registered Public Accounting Firm On Exemption Report* To the Member of Palico LLC We have reviewed management's statements, included in the accompanying Palico LLC Rule 15c3-3 Exemption Report pursuant to SEC Rule 17a-5, in which (1) Palico LLC (the Company) did not claim an exemption under paragraph (k) of 17 C.F.R.§ 240.15c3-3, and (2) the Company 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 receiving subscriptionbased income from a web-based platform (the "Platform") whereby Limited and General Partners can build relationships with Fund Managers, as well as commissions from secondary private placement transactions executed via the Platform. In addition, The Company did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers nor did the Company carry accounts of or for customers. In accordance with the SEC FAQ update of July 1, 2020, the Company is further relying on Footnote 74 as it does not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception. Palico LLC's management is responsible for compliance with the provisions contemplated by Footnote 74 of SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 and related SEC Staff Frequently Asked Questions 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 Palico LLC'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. reive New York, New York March 25, 2026 {20}------------------------------------------------ # **126 East 56th Street- Suite 1200 New York, NY 10022** # **Palico LLC Exemption Report** Palico LLC (the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C.F.R. §240.17a-5, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R. §240.17a-5(d)(1) and (4). To the best of its knowledge and belief, the Company states the following: - (1) The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240. 15c3-3, and - (2) The Company 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 to receiving subscription-based income from a web-based platform (the "Platform") whereby Limited and General Partners can build relationships with Fund Managers, as well as commissions from secondary private placement transactions executed via the Platform. The Company did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers nor did the Company carry accounts of or for customers. - (3) In accordance with the SEC FAQ update of July 1, 2020, the Company is further relying on Footnote 74 as it does not carry PAB accounts (as defined in Rule 15c3- 3) throughout the most recent fiscal year without exception. Palico LLC I, Kenneth Boyar, swear that, to my best knowledge and belief, this Exemption Report is true and correct. Kenneth Boyar Title: FINOP March 25, 2026 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.