# TULLY & HOLLAND, INCORPORATED X-17A-5 (2026-06-18) — Broker-dealer annual report - Company: TULLY & HOLLAND, INCORPORATED - Form: X-17A-5 - Filed: 2026-06-18 - Period: 2026-03-31 - Accession: 0000885331-26-000003 - CIK: 885331 - File #: 8-44691 - Type: Broker-dealer - Material weakness: No - Auditor: Miller Wachman - Auditor location: Boston, MA - Contact: Timothy W. Tully - Phone: 617-320-6816 - Email: y@tullyan0hollan0.com - Website: tullyan0hollan0.com - Signed by: Timothy W. Tully (President) Original filing: https://www.sec.gov/Archives/edgar/data/885331/000088533126000003/tullyhollandfy20261.pdf --- {0}------------------------------------------------ **UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington,** D.C. **20549** 0MB Number: 3235-0123 Expires: Nov. 30, 2026 Estimated average burden hours per response: 12 # **ANNUAL REPORTS FORM X-17A-5 PART** Ill | | SEC FllE NUMBER | |--|-----------------| | Information Required Pursuant to Rules 17a-5, 17a-12, and lBa-7 under the Securities Exchange Act of 1934 | FACING PAGE | | | | | |-------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------|-----------------------------------------|-------------------------------------------|--|--| | FILING FOR THE PERIOD BEGINNING 04/Q 1 /25
AND ENDING 03/31 /26 | | | | | | | | MM/DD/YY | | | | | | | A. REGISTRANT IDENTIFICATION | | | | | | NAMEOFFIRM: TULLY AND HOLLAND INCORPORATED | | | | | | | TYPE OF REGISTRANT (check all applicable boxes):
0 Broker-dealer
D Check here if respondent is also an OTC derivatives dealer | D Security-based swap dealer | 0 Major security-based swap participant | | | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) | | | | | | | 501 BOYLSTON STREET, 10TH FLOOR | | | | | | | | (No. and Street) | | | | | | BOSTON | MA | | | | | | (City) | (State) | | 02116
(Zip Code( | | | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | | | | TIMOTHY TULLY | (781 ) 239-2900
TTULL Y@TULLYAN0HOLLAN0.COM | | | | | | (Name) | (Area Code -Telephone Number) | (Email Address) | | | | | | B. ACCOUNTANT IDENTIFICATION | | | | | | INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing•
MILLER WACHMAN LLP | | | | | | | | (Name - ir individual, state last, first, and middle name) | | | | | | 100 CAMBRIDGE STREET, SUITE 1302 BOSTON | | MA | 02114 | | | | (Address) | (City) | (State) | (Zip Code) | | | | 11/22/2003 | | 566 | | | | | (Date or Re11.istration with PCAOB)fif aoolicablel | | | (PCAOB Registration Number if applicable) | | | | | 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 exemption. See 17 CFR 240.17a-5(e)(l)(ii), if applicable. Persons who re to respond to the collection of lnfOf'm tlon contained in this form re not required to respond unle11 the form displays a currently Ud 0MB control number. {1}------------------------------------------------ #### OATH OR AFFIRMATION I, TIMOTHY TULLY swear (or affirm) that, to the best of my knowledae and belief, the financial report pertaining to the firm of TULL y AND HOLLAND INCORPORATED as of 03/31 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. ![](_page_1_Picture_3.jpeg) **Sign,tu,e** ~ J,-¼ Title: PRESIDENT This flllng•• **contains (check al applicable boxes):** - **l!!i** (a) Statement of financial condition. - **l!!i** (b) Notes to consolidated statement of financial condition. - **l!!i** {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). - I!!! (d) Statement of cash flows. - I!!! (e) Statement of changes in stockholders' or partners' or sole proprietor's equity. - □ (f) Statement of changes in liabilities subordinated to claims of creditors. - I!!! (g) Notes to consolidated financial stltements. - I!!! (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. - **!iii** (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. - D (1) Computation for Determination of PAB Requirements under Exhibit A to§ 240.15c3-3. - **l!!i** (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, induding appropriate explanations, of the FOCUS Report with computation of net capital 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. - D (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.lBa-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. - **!iii** (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. - **!iii** (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). D (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. {2}------------------------------------------------ ## TULLY AND HOLLAND IN CORPORA TED ## FINANCIAL STATEMENTS ## MARCH 31, 2026 {3}------------------------------------------------ ![](_page_3_Picture_0.jpeg) # REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Shareholder of Tully and Holland Incorporated ## **Opinion on the Financial Statements** We have audited the accompanying statement of financial condition of Tully and Holland Incorporated as of March 31, 2026, the related statements of operations, changes in shareholder'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 Tully and Holland Incorporated as of March 31, 2026, 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 Tully and Holland Incorporated's management. Our responsibility is to express an opinion on Tully and Holland Incorporated'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 Tully and Holland Incorporated 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 Supplemental Information** The computation of aggregate indebtedness and net capital pursuant to SEC Rule l 5c3-l (Schedule I) and computation for determination of reserve and information relating to possession and control requirements for broker dealers under Rule 15c3-3 of the Securities and Exchange Commission (Schedule II) has been subjected to audit procedures performed in conjunction with the audit of Tully and Holland Incorporated's financial statements. The supplemental information is the responsibility of Tully and Holland Incorporated's management. Our audit procedures included determining whether the supplemental {4}------------------------------------------------ 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 computation of aggregate indebtedness and net capital pursuant to SEC Rule l 5c3-1 and computation for determination of reserve and information relating to possession and control requirements for broker dealers under Rule l 5c3-3 of the Securities and Exchange Commission is fairly stated, in all material respects, in relation to the financial statements as a whole. *~M>tr, IJ.I)* Miller Wachman, LLP We have served as Tully and Holland Incorporated's auditor since 2026. Boston, Massachusetts May 26, 2026 {5}------------------------------------------------ # **TULLY AND HOLLAND IN CORPORA TED STATEMENT OF FINANCIAL CONDITION March 31, 2026** ## **ASSETS** | Cash | \$ | 815,604 | |-----------------------------------------------------------|----|------------------------| | Accounts receivable -
non customers
Other assets | | 5,103
___
20,028 | | | \$ | 840,735 | | LIABILITIES AND STOCKHOLDER'S EQUITY | | | | Liabilities: | | | | Accounts payable, accrued expenses, and other liabilities | \$ | 14,279 | | Stockholder's equity: | | | | Common stock, \$.01 par value, 1,000 shares authorized, | | | | 300 shares issued and outstanding | | 3 | | Additional paid-in capital | | 389,198 | | Retained earnings | | 536,072 | | Less 200 shares of common stock in treasury, at cost | | (98,817) | | Total stockholder's equity | | 826,456 | | | \$ | 840,735 | The accompanying notes are an integral part of these financial statements. {6}------------------------------------------------ #### **TULLY AND HOLLAND INCORPORATED STATEMENT OF OPERATIONS For the year ended March 31, 2026** | Revenues: | | |------------------------------------|--------------| | Advisory fees | S 1,735,000 | | Interest income | 5,408 | | | 1,740,408 | | | | | | | | Expenses: | | | Employee compensation and benefits | 544,233 | | Officers compensation and benefits | 177,264 | | Communications and data processing | 33,736 | | Occupancy | 81,623 | | Insurance | 15,477 | | Payroll Taxes | 51,430 | | Professional Fees | 94,385 | | Profit Sharing | 91,268 | | Travel and entertainment | 22,303 | | Other expenses | 87,439 | | | 1,199,158 | | Income before income taxes | 541,250 | | Provision for income taxes | 57,500 | | Net Income | s
483,750 | The accompanying notes are an integral part of these financial statements. {7}------------------------------------------------ # **TULLY AND HOLLAND IN CORPORA TED STATEMENT OF CHANGES IN SHAREHOLDER'S EQUITY For the year ended March 31, 2026** | | | Common
Stock | Additional
Paid-In
Capital | Retained
Earnings | Treasury
Stock | Total
Stockholder's
Equity | | |-------------------------|----|-----------------|----------------------------------|----------------------|-------------------|----------------------------------|---------| | Balance, April 1, 2025 | \$ | 3 | \$ 389,198 | \$
52,322 | \$ (98,817) | \$ | 342,706 | | Net Income | | | - | 483,750 | - | | 483,750 | | Balance, March 31, 2026 | \$ | 3 | \$ 389,198 | \$
536,072 | \$ (98,817) | \$ | 826,456 | The accompanying notes are an integral part of these financial statements {8}------------------------------------------------ # **TULLY AND HOLLAND INCORPORATED ST A TEMENT OF CASH FLOWS For the** year **ended March 31, 2026** | Cash flows provided by operating activities: | | |----------------------------------------------------|---------------| | Net Income | \$
483,750 | | Adjustments to reconcile net income to | | | net cash provided by operating activities: | | | (Increase) Decrease in operating assets: | | | Decrease in accounts receivable -
non customers | 7,354 | | Decrease in other assets | l, 181 | | Increase (Decrease) in operating liabilities: | | | Increase in accounts payable and accrued expenses | 13,059 | | Net cash provided by operating activities | 505,344 | | | | | Cash at March 31, 2025 | 310,260 | | Cash at March 31, 2026 | \$
815,604 | | | | | | | | Supplemental disclosures of cash flow information: | | | Cash paid during the year for: | | | Income taxes | \$
57,500 | {9}------------------------------------------------ # **TULLY AND HOLLAND INCORPORATED NOTES TO FINANCIAL STATEMENTS MARCH 31, 2026** # **NOTE 1- SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES** ## **Organization and Nature of Business** The Company is a broker-dealer registered with the Securities and Exchange Commission (SEC) and is a member of the Financial Industry Regulatory Authority, Inc. (FINRA). ## **Advisory Fees** The Company provides advisory services on mergers and acquts1t1ons (M&A). Revenue is recognized in accordance with ASC Topic 606, *Revenue from Contracts with Customers,* using its 5-step recognition criteria process. Revenue for advisory arrangements is generally recognized at the point in time that performance under the arrangement is completed (the closing date of the transaction) or the contract is cancelled. However, for certain contracts, revenue is recognized over time for advisory arrangements in which the performance obligations are simultaneously provided by the Company and consumed by the customer. In some circumstances, significant judgment is needed to determine the timing and measure the progress appropriate for revenue recognition under a specific contract. Retainers and other fees received from customers prior to recognizing revenue are reflected as contract liabilities. Performance obligations for retainers are considered separate and distinct from those related to success fees, as the benefits received from those performance obligations contain stand-alone value. ## **Accounts Receivable- Non Customers** Management closely monitors outstanding accounts receivable, and charges off to expense all balances that are determined to be uncollectable. ## **Property and Equipment** Property and equipment are recorded at cost. Maintenance and repairs are charged to expense as incurred. Major improvements to property and equipment are capitalized. Depreciation 1s computed using the accelerated method over the estimated useful lives of the assets. ## **Income Taxes** The Company, with the consent of its sole shareholder, has made an election under Subchapter S of the Internal Revenue Code, not to be subject to federal income taxes at the corporate level. Pursuant to this election, the income or loss of the Company is included in the taxable income of the individual stockholder. Consequently, the statement of income contains no provision for federal income taxes. The Company's tax years subject to examination by regulatory authorities are from December 31 , 2022 and after. The Company is liable for Massachusetts excise taxes. Accordingly, this tax has been included in the accompanying financial statements. {10}------------------------------------------------ # **TULLY AND HOLLAND INCORPORATED NOTES TO FINANCIAL STATEMENTS, CONTINUED MARCH 31, 2026** # **NOTE 1- SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (continued)** ## **Statement of Cash Flows** For purposes of the statement of cash flows, the Company has defined cash equivalents as highly liquid investment, with original maturities of less than ninety days that are not held for sale in the ordinary course of business. ## **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 amounts reported in these financial statements and accompanying notes. Actual results could differ from these estimates. # **NOTE 2- PROPERTY AND EQUIPMENT** Major classifications of property and equipment are as follows: | Computer equipment | \$
76,086 | |-----------------------------------|--------------| | Furniture, fixtures and equipment | 113,485 | | | I 89,571 | | Less: Accumulated depreciation | 189.571 | | | \$ | Depreciation expense for the year ended March 31, 2026 was \$0. # **NOTE 3- NET CAPITAL** The Company is subject to the Securities and Exchange Commission Uniform Net Capital Rule (SEC Rule l 5c3• l ), which requires the maintenance of minimum net capital and requires that the ratio of aggregate indebtedness to net capital, both as defined, shall not exceed 15 to 1. At March 31, 2026 the Company had net capital of \$801,326 which was \$796,326 in excess of its required net capital of \$5,000. The Company's ratio of aggregate indebtedness to net capital was .0178 to 1. {11}------------------------------------------------ ## **TULLY AND HOLLAND INCORPORATED NOTES TO FINANCIAL ST A TEMENTS, CONTINUED MARCH 31, 2026** #### **NOTE4- OPERA TING LEASE** The Company conducts its operations from offices that were leased at \$6,802 per month. Occupancy expense for the year ended March 3 1, 2026 was \$81,623. The lease tenninated in September 2025. The Company signed a new short-term lease for its office in September 2025. The Company has elected, for all underlying classes of assets, not to recognize ROU assets & lease liabilities for short-term leases that have a lease term of 12 months or less at lease commencement. # **NOTE 5- OFF- BALANCE SHEET RISK AND CONCENTRATION OF CREDIT RISK** The Company at times maintains cash in bank accounts in excess of the established limit insured by the Federal Deposit Insurance Corporation (FDIC). # **NOTE 6- RELATED PARTY TRANSACTIONS** The Company reimburses the shareholder for automobile expenses at a rate of \$1,350 per month. The reimbursement totaled \$16,200 for the year ended March 31, 2026. # **NOTE 7- EMPLOYEE BENEFIT PLANS** The Company has an incentive savings plan covering all eligible employees. The Company may contribute to the plan an amount designated by management of the Company to the extent permissible under the Internal Revenue Code. For the year ended March 31, 2026, the Company contributed \$91,268 to the plan. # **NOTE 8- COMMITMENTS AND CONTINGENCIES** As of March 31, 2026, there were no material contingencies or guarantees that require disclosure. {12}------------------------------------------------ # **TULLY AND HOLLAND INCORPORATED NOTES TO FINANCIAL STATEMENTS, CONTINUED MARCH 31, 2026** #### **NOTE 9- 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, including advisory services on merger and acquisitions for clients. The accounting policies for fees are the same as those described in the summary of significant accounting policies. The chief operating decision maker assesses performance for the agency fee segment and decides how to allocate resources based on net income that is reported on the income statement. The measurement of segment assets is reported on the balance sheet as total assets. The chief operating decision maker uses net income to evaluate income generated from segment assets (return on assets) in deciding whether to reinvest profits into the agency fee segment or into other parts of the entity. The chief operating decision maker also uses net income in competitive analysis by benchmarking competitors. The Company derives revenue primarily from North America. The Company's chief operating decision maker is the managing member. # **NOTEl0- SUBSEQUENT EVENTS** Management has evaluated subsequent events through May 26, 2026 the date on which the financial statements were available to be issued. There were no subsequent events that require adjustment or disclosure in the financial statements. {13}------------------------------------------------ ## TULLY AND HOLLAND INCORPORATED ### SUPPLEMENTARY SCHEDULES MARCH 31, 2026 {14}------------------------------------------------ #### **SCHEDULE I** # **TULLY AND HOLLAND IN CORPORA TED COMPUTATION OF AGGREGATE INDEBTEDNESS AND NET CAPITAL PURSUANT TO RULE 15c3-1 MARCH 31, 2026** | Aggregate indebtedness: | | |--------------------------------------------------------------------------------------------------------|-------------------| | Accounts payable and accrued expenses | \$
14,279 | | Stockholder's equity: | | | Common stock | \$
3 | | Additional paid-in capital | 389,198 | | Retained earnings | \$
536,072 | | Treasury stock | (98,817) | | | 826,456 | | | | | Adjustments to stockholder's equity: | | | Accounts receivable -
non customers(net) | \$
(5,103) | | Property and equipment | | | Other assets | (20,028) | | Net capital, as defined | \$
801
,325 | | Net capital requirement | \$
5,000 | | Net capital in excess of requirement | \$
796,325 | | Ratio of aggregate indebtedness to net capital | .0178 to I | | Reconciliation with Company's computation included in
Part IIA ofFonn 17a-5(a) as of March 31, 2026 | | | as reported in Company's (unaudited) focus report | \$
801,326 | | Net audit adjustments | | | Decrease in non-allowable assets | | | Net Capital per above | \$
801,326 | See Report of Independent Registered Public Accounting Firm {15}------------------------------------------------ ## **SCHEDULE** II ## **TULLY AND HOLLAND IN CORPORA TED** ## **COMPUTATION FOR DETERMINATION OF RESERVE AND INFORMATION RELATED TO POSSESSION OR CONTROL REQUIREMENTS FOR BROKER/DEALERS UNDER RULE 15c3-3 OF THE SECURITIES EXCHANGE ACT OF 1934** ### **MARCH 31, 2026** Tully and Holland Incorporated is exempt from the reserve requirements of Rule 15c3-3 as its transactions are limited, such that they do not handle customer funds or securities, accordingly, the computation for determination of reserve requirements pursuant to Rule 15c3-3 and information relating to the possession or control requirement pursuant to Rule 15c3-3 are not applicable. {16}------------------------------------------------ ![](_page_16_Picture_0.jpeg) # REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Shareholder of Tully and Holland Incorporated We have reviewed management's statements, included in the accompanying Exemption Report in which Tully and Holland Incorporated (the" Company") identified it was filing the exemption report solely to be in compliance with 17 C.F.R. § 240. l 7a-5 (d)(l) and (4). Tully and Holland, Incorporated 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. l 7a-5 because the Company limits its business activities exclusively to fees earned from advisory services including mergers and acquisitions, restructuring, valuation and capital raising services for clients 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 identified in Rule l 5c3-3 throughout the most recent fiscal year. Tully and Holland lncorporated's management is responsible for compliance with 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 Tully and Holland Incorporated's compliance with the provisions of 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 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. l 7a-5, and related SEC Staff Frequently Asked Questions. *~tu.H,LLP* Miller Wachman, LLP Boston, Massachusetts May 26, 2026 {17}------------------------------------------------ ### **TULLY AND HOLLAND IN CORPORA TED** ## **EXEMPTION REPORT PURSUANT TO RULE 15c3-3 OF THE SECURITIES EXCHANGE COMMISSION** #### **MARCH 31, 2026** Tully and Holland Incorporated (the "Company") is a registered broker-dealer subject to Rule **l** 7a-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)(I) 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. **l** 5c3- 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 fees earned from advisory services including mergers and acquisitions, restructuring, valuation and capital raising services for clients 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 1 Sc-3) throughout the most recent fiscal year. I, Timothy Tully, affirm that, to the best of my knowledge and belief, this Exemption Report is true and correct without exception. Timothy W. Tully President Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.