# HUNNICUTT & CO. LLC X-17A-5 (2026-03-30) — Broker-dealer annual report

- Company: HUNNICUTT & CO. LLC
- Form: X-17A-5
- Filed: 2026-03-30
- Period: 2025-12-31
- Accession: 0000819594-26-000003
- CIK: 819594
- File #: 8-38327
- Type: Broker-dealer
- Material weakness: No
- Auditor: Holt Patterson LLC
- Auditor location: Chesterfield, MO
- Contact: Mark T Manzo
- Phone: 2015191905
- Email: mmanzo@moppartners.com
- Website: moppartners.com
- Signed by: William Hunnicutt (Managing member President)

Original filing: https://www.sec.gov/Archives/edgar/data/819594/000081959426000003/2025hunncuted.pdf

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# **Hunnicutt & Co., LLC**

## **(SEC I.D. No. 8-38327)**

FINANCIAL STATEMENTS AND

SUPPLEMENTAL SCHEDULES

FOR THE YEAR ENDED DECEMBER 31, 2025

AND

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

AND

REVIEW REPORT REGARDING EXEMPTION PROVISIONS

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**UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549** 

0MB APPROVAL 0MB Number: 3235-0123 Expires: Nov. 30, 2026 Estimated average burden hours per response: 12

# **ANNUAL REPORTS FORM X-17A-5 PART Ill**

| SEC FILE NUMBER |
|-----------------|
| 8-38327         |

**FACING PAGE** 

**Information Required Pursuant to Rules 17a-5, 17a-12, and lSa-7 under the Securities Exchange Act of 1934** 

| FILING FOR THE PERIOD BEGINNING O 1/01 /25 | AND ENDING 12/31 /25 |
|--------------------------------------------|----------------------|
|--------------------------------------------|----------------------|

MM/DD/YY

MM/DD/YY

**A. REGISTRANT IDENTIFICATION** 

# NAME OF FIRM: HUNNICUTT & CO., LLC

TYPE OF REGISTRANT {check all applicable boxes):

C!J Broker-dealer □ Security-based swap dealer □ Check here if respondent is also an OTC derivatives dealer □ Major security-based swap participant

ADDRESS OF PRINCIPAL PLACE OF BUSINESS: {Do not use a P.O. box no.)

# 110 E. 59th STREET, 22ND FLOOR

| (No. and Street)                                                                                   |                                                            |                        |                 |  |  |  |
|----------------------------------------------------------------------------------------------------|------------------------------------------------------------|------------------------|-----------------|--|--|--|
| NEW YORK                                                                                           | NY                                                         |                        | 10022           |  |  |  |
| (City)                                                                                             | (State)                                                    |                        | (Zip Code)      |  |  |  |
| PERSON TO CONTACT WITH REGARD TO THIS FILING                                                       |                                                            |                        |                 |  |  |  |
| Mark T Manzo                                                                                       | (201) 519-1905                                             | mmanzo@moppartners.com |                 |  |  |  |
| (Name)                                                                                             | (Area Code - Telephone Number)                             |                        | (Email Address) |  |  |  |
|                                                                                                    | B. ACCOUNTANT IDENTIFICATION                               |                        |                 |  |  |  |
| INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*<br>Holt & Patterson, LLC | (Name - if individual, state last, first, and middle name) |                        |                 |  |  |  |
| 260 Chesterfield Blvd                                                                              | Chesterfield                                               | MO                     | 63005           |  |  |  |
| (Address)                                                                                          | (City)                                                     | (State)                | (Zip Code)      |  |  |  |
| 02/24/2009                                                                                         |                                                            | 3372                   |                 |  |  |  |
|                                                                                                    |                                                            |                        |                 |  |  |  |
|                                                                                                    | FOR OFFICIAL USE ONLY                                      |                        |                 |  |  |  |
|                                                                                                    |                                                            |                        |                 |  |  |  |

\* Claims for exemption from the requirement that the annual reports be covered by the reports of an independent public accountant must be supported by a statement of facts and circumstances relied on as the basis of the exempt ion. See 17 CFR 240.17a-S(e)(l)(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 0MB control number.** 

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#### OATH OR **AFFIRMATION**

I , William Hunnicutt **swear (or affirm) that, to the best of my knowledge and belief, the financial report pertaining to the** firm of HUNNICUTT & co., LLC **as of** 

December 31 2� **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.** 

**Signature: W� 11�** 

Title: Managing Memeber/President

#### **This filing•• contains (check all applicable boxes):**

- Iii (a) Statement of financial condition.
- □ (b) Notes to consolidated statement of financial condition.
- Iii (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).
- Iii (d) Statement of cash flows.
- Iii (e) Statement of changes in stockholders' or partners' or sole proprietor's equity.
- □ (f) Statement of changes in liabilities subordinated to claims of creditors.
- Iii (g) Notes to consolidated financial statements.
- Iii (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.
- □ (j) 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.
- □ (I) 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.
- Iii ( o) Reconciliations, including appropriate exp la nations, of the FOCUS Report with computation of net capita I or tangible 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.
- Iii (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.
- Iii (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.
- Iii ( u) Independent public accountant's report based on an examination of the financial report or financial statements under 17 CFR 240.17a-5, 17 CFR 240.18a-7, 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.
- Iii (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 240.15c3-1e or 17 CFR 240.17a-12, as applicable.
- □ (y) Report describing any material inadequacies found to exist or found to have existed since the date of the previous audit, or a statement that no material inadequacies exist, under 17 CFR 240.17a-12(k). □ (z) other: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ \_
- 
- *\*\*To request confidential treatment of certain portions of this filing, see 17 CFR 240.17a-5(e}(3} or 17 CFR 24O.1Ba-7(d}(2), as applicable.*

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#### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**

**To the Management and Member of Hunnicutt & Co., LLC** 

**Opinion on the Financial Statements** 

**We have audited the accompanying statement of financial condition of Hunnicutt & Co., LLC (the "Company") as of December 31, 202S, the related statements of income, changes in member's equity, and cash flows for the year then ended, and the related notes and supplementary information (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.** 

#### **Auditor's Report on Supplementary Information**

**The supplementary Schedule I -Computation of Net Capital Under Rule 1Sc3-1 of the Securities and Exchange Commission has been subjected to audit procedures performed in conjunction with the audit of the Company's financial statements. The supplementary information is the responsibility of the Company's management. Our audit procedures included determining whether the supplementary 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 supplementary information. In forming our opinion on the supplementary information, we evaluated whether the supplementary information, including its form and content, is presented in conformity with 17 C.F.R. §240.17a-5. In our opinion, the supplementary information is fairly stated, in all material respects, in relation to the financial statements as a whole.** 

��\_,.\_�.l).J:\_\_, \_,

**Holt & Patterson, LLC Chesterfield, MO** 

**We have served as the Company's auditor since 2023.** 

**March 30, 2026** 

**260 CHESTERFl!LD INDUSTRIAL BIVO.** 

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### **HUNNICUTT & CO., LLC STATEMENT OF FINANCIAL CONDITION DECEMBER 31, 2025**

#### **ASSETS**

| Cash and cash equivalents | \$<br>11,688 |
|---------------------------|--------------|
| Prepaid expenses          | 3,910        |
| Due from member           | 31,288       |
|                           |              |
| TOT AL ASSETS             | \$<br>46,886 |

#### **LIABILITIES AND MEMBER'S EQUITY**

#### LIABILITIES

| Accounts payable and accrued expenses | \$<br>11,008 |
|---------------------------------------|--------------|
| Total Liabilities                     | 11,008       |
| MEMBER'S EQUITY                       | 35,878       |
| TOTAL LIABILITIES AND MEMBER'S EQUITY | \$<br>46,886 |

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#### **HUNNICUTT & CO., LLC STATEMENT OF INCOME FOR THE YEAR ENDED DECEMBER 31, 2025**

#### **REVENUES**

| 1,221 |
|-------|
| 614   |
| 1,524 |
| \$    |

#### **EXPENSES**

| Lease expenses                   | 35,551          |
|----------------------------------|-----------------|
| Accounting and professional fees | 24,543          |
| Advertising and marketing        | 1,100           |
| Regulatory fees                  | 2,188           |
| Travel and entertainment         | 13,406          |
| Insurance                        | 12,772          |
| Meals                            | 5,868           |
| Office supplies and postage      | 6,975           |
| Dues and subscriptions           | 6,896           |
| Other expenses                   | 1,507           |
| Communications                   | 1,713           |
| TOTAL EXPENSES                   | 112,519         |
|                                  |                 |
| NET LOSS                         | (109,160)<br>\$ |

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### **HUNNICUTT & CO., LLC STATEMENT OF CHANGES IN MEMBER'S EQUITY FOR THE YEAR ENDED DECEMBER 31, 2025**

| Balance, January 1, 2025   | \$<br>19,038 |
|----------------------------|--------------|
| Net Income (loss)          | (109,160)    |
| Member's contributions     | 126,000      |
| Balance, December 31, 2025 | \$<br>35,878 |

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### **HUNNTICUTT CO,. LLC STATEMENT OF CASH FLOWS FOR THE YEAR ENDED DECEMBER 31, 2025**

| Cash Flows from Operations:                       |                 |
|---------------------------------------------------|-----------------|
| Net income (loss)                                 | \$<br>(109,160) |
| Adjustments to reconcile net                      |                 |
| income (loss) to net cash used                    |                 |
| by operating activities                           |                 |
| Decrease in prepaid expenses                      | 1,242           |
| Increase in due from member                       | (31,288)        |
| Decrease in accounts payable and accrued expenses | (1,359)         |
| NET CASH USED BY OPERATING ACTIVITIES             | (140,565)       |
| Cash flows from investing activities              |                 |
| Cash flows from Financing activities              |                 |
| Member contributions                              | 126,000         |
| Net decrease in Cash and cash equivalents         | (14,565)        |
| Cash and cash equivalents, beginning of the year  | 26,253          |
| Cash and cash equivalents, end of the year        | \$<br>11,688    |

#### **Supplemental Disclosures**

There was no cash paid for either interest or taxes during the year.

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# **1. ORGANIZATION AND NATURE OF BUSINESS**

Hunnicutt & Co., LLC (the "Company"), is a registered broker-dealer in securities transactions under the provisions of the Securities and Exchange Commission Act of 1934 and is a member of the Financial Industry Regulatory Authority lnc.("FINRA") and the Securities Investor Protection Corporation.

# **2. SIGNIFICANT ACCOUNTING POLICIES**

# **ACCRUAL BASIS OF ACCOUNITNG**

The Company's financial statements are prepared using accrual method of accounting in accordance with accounting principles generally accepted in the U.S. ("GAAP"). The Company's year-end is December 31.

### **INCOME TAXES**

The Company is a limited liability Company taxed as a partnership and the accompanying financial statements do not include a provision for federal or state income taxes. The Company is responsible for local unincorporated business tax on income, which is calculated at the statutory rate. The Company determined that there are no uncertain tax positions that require financial statement recognition.

### **USE OF ESTIMATES**

The preparation of financial statements in conformity with generally accepted accounting principles requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities at the date of the financial statements and the reported amounts of revenue and expenses during the reported period. Actual results could differ from those estimates.

### **REVENUE RECOGNITION**

Fee Income:

The Company records its fees as they are earned based on the services provided, or in case of success fees, upon successful completion of the services of consummation of the related transaction.

The revenue recognition guidance requires that an entity recognize revenue to depict the transfer of promised goods or services to customers in an amount that reflects the

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# **2. SIGNIFICANT ACCOUNTING POLICIES (CONITINUED)**

### **REVENUE RECOGNITION (CONTINUED)**

**consideration to which the entity expects to be entitled in exchange for those goods or services. The guidance requires an entity to follow a five step model to (a) identify the contract(s) with a customer, (b) identify the performance obligations in the contract, (c) determine the transaction price, (d) allocate the transaction price to the performance obligations in the contract, and (e) recognize revenue when (or as) the entity satisfies a performance obligation.** 

**In determining the transaction price, an entity may include variable consideration only to the extent that it is probable that a significant reversal in the amount of cumulative revenue recognized would not occur when the uncertainty associated with the variable consideration is resolved.** 

**For the year ending December 31, 2025, the Company recorded \$1,524 in legacy fees.** 

**Dividend Income:** 

**For the year ending December 31, 2025, the Company recorded dividends of \$614 from investments in a money market fund held in its brokerage account.** 

**Other Income:** 

**For the year ending December 31, 2025, the Company recorded \$1,221 for reimbursement of 2024 FINRA GIA fees.** 

# **3. NET CAPITAL REQUIREMENTS**

**The Company is a member of FINRA and subject to the Securities and Exchange Commission's Uniform Net Capital Rule (SEC Rule 15c3-1), which requires the maintenance of minimum net capital of \$5,000 and requires that the ratio of aggregate indebtedness to net capital, both as defined, shall not exceed 15 to 1. At December 31, 2025, the Company had net capital of \$623 which was \$(4,377) below its calculated minimum net capital requirement.** 

**The Company's net capital fell below its minimum net capital requirement during the period December 24, 2025, through January 19, 2026, when funds were inadvertently transferred out of its brokerage account. FINRA and the SEC were notified by the Company. When the funds were returned to the brokerage account on January 20, 2026.** 

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# **3. NET CAPITAL REQUIREMENTS (CONTINUED)**

the Company was in compliance with the net capital rule and has remained in compliance since that date.

The Company does not have any possession of or control of customer funds or securities and therefore, claims an exemption from Rule 15c3-3.

# **4. LEASE**

During 2025, the Company entered into a lease agreement for 12 months which expires on September 30, 2026, with a monthly payment of \$3,150. The lease is short-term in nature and is not subject to the guidance of ASC 842 lease accounting standard.

# **5. SUBSEQUENT EVENTS**

The Company has evaluated subsequent events through March 30, 2026, the date on which these financial statements were available to be issued. The Company did not identify any material subsequent events requiring adjustments to or disclosure in its fi na ncia I statements.

# **6. COMMITMENTS, CONTINGENCIES AND GUARANTEES**

As of December 31, 2025, the Company did not have any commitments, contingencies of guarantees that might result in a loss or future obligation that would have required the Company to include such liability/obligation in its 2025 Annual Report.

# **7. CONCENTRATIONS**

The Company maintains all of its cash in financial institutions, which at times may exceed federally insured limits. The Company has not experienced any losses in such accounts and believes it is not subject to any significant credit risk on cash.

# **8. GOING CONCERN**

Accounting Standards Update 2014-15 requires that management evaluate conditions or events that might raise substantial doubt about the Company's ability to continue as a going concern. Management has evaluated the Company's conditions and has determined that unless the Company generates enough revenue or continues to be funded by its member, there is substantial doubt about the Company's ability to continue

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# **8. GOING CONCERN (CONTINUED)**

as a going concern. The Management has committed to contribute additional capital as needed to support the Company's continuing operations.

# **9. SEGMENT REPORTING**

The Company has one reportable segment as a securities broker-dealer, which is comprised of several classes of services, including private placement of securities and introducing investors to funds. 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 (see Note 3), which is not a measure of profit and loss, to make operational decisions while maintaining capital adequacy. 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.

The Company derived 45% of total revenues earned during the year ended December 31, 2025, from two customers.

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SUPPLEMENTARY INFORMATION PURSUANT TO RULE 17a-S OF THE SECURITIES EXCHANGE ACT OF 1934

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# **HUNNICUTT & CO., LLC Schedule I COMPUTATION OF NET CAPITAL UNDER RULE 15c3-1 OF THE SECURITIES AND EXCHANGE COMMISSION DECEMBER 31, 2025**

| Net Capital:                                                            |    |         |  |
|-------------------------------------------------------------------------|----|---------|--|
| Total member's equity                                                   | \$ | 35,878  |  |
| Deduction and/or charges:                                               |    |         |  |
| Non-allowable assets: Prepaid expenses                                  |    | 3,910   |  |
| Due from Member                                                         |    | 31,288  |  |
|                                                                         |    | 35,198  |  |
| Net capital before haircuts on securities positions                     |    | 680     |  |
| Haircuts on securities positions                                        |    | (57)    |  |
| Net Capital                                                             |    | 623     |  |
|                                                                         |    |         |  |
| AGGREGATE INDEBTEDNESS:                                                 |    |         |  |
| Items included in the statement of financial condition:                 |    |         |  |
| Accounts payable and accrued expenses                                   | \$ | 11,008  |  |
|                                                                         |    |         |  |
| COMPUTATION OF BASIC NETCAPITAL REQUIREMENT:                            |    |         |  |
| Minimum net capital required (6 2/3%) of aggregate indebtedness         | \$ | 734     |  |
|                                                                         |    |         |  |
| Minimum net capital required                                            | \$ | 5,000   |  |
| Excess Net Capital                                                      | \$ | (4,377) |  |
|                                                                         |    |         |  |
| Net capital less greater of 10% of total Al or 120% of min. net capital | \$ | (5,377) |  |
| Percentage of aggregate indebtedness to net capital is                  |    | 1767%   |  |
|                                                                         |    |         |  |

The above computation as of December 31, 2025 agrees with the net capital in the Company's amended Part IIA FOCUS report filed on March 30, 2026

See Report of Independent Public Accounting Firm

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#### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**

**To the Management and Member of Hunnicutt & Co., LLC** 

**We have reviewed management's statements, included in the accompanying Rule 1Sc3-3 Exemption Report pursuant to SEC Ruel 17a-5, in which (1) Hunnicutt & Co., LLC (the Company) did not claim an exemption under paragraph (k) of 17 C.F.R. § 240.1Sc3-3, 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 private placement and investment advisory services. In addition, the Company did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of Rule 1Sc2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company; did not carry accounts of or for customers; and {3) did not carry PAB accounts (as defined in Rule 1Sc3-3) throughout the most recent fiscal year without exception.** 

**Hunnicutt & Co., 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 Hunnicutt & Co., 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 on 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-S, and related SEC Staff Frequently Asked Questions.** 

�

**Holt & Patterson, LLC Chesterfield, MO** 

**March 30, 2026** 

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### "Exemption Report"

March 30, 2026

Hunnicutt & Co., LLC is a registered broker-dealer subject to Rule 1 ?a-5 promulgated by the Securities and Exchange Commission (1 7C.F.R. 240.1 ?a-5,"Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R. 240.1 7a-5(d)(1) and (4).

Hunnicutt & Co. , 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. 1 7a-5, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17

C.F.R. §240.1 7a-5(d)(l) 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. 1 5c3-3,
- (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. § 240.1 7a-5 because the Company limits its business activities exclusively to private placement and investment advisory services.
- (3) 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 did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception.

I, William Hunnicutt swear ( or affirm) that, to my best knowledge and belief, this Exemption Report is true and correct.

By: *W�/1�* 

Title: Managing Partner

Hunnicutt & Co., LLC


Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.
