# STATE STREET GLOBAL ADVISORS FUNDS DISTRIBUTORS, LLC X-17A-5 (2026-02-26) — Broker-dealer annual report - Company: STATE STREET GLOBAL ADVISORS FUNDS DISTRIBUTORS, LLC - Form: X-17A-5 - Filed: 2026-02-26 - Period: 2025-12-31 - Accession: 0000885750-26-000002 - CIK: 885750 - File #: 8-44744 - Type: Broker-dealer - Material weakness: No - Auditor: Ernst & Young LLP - Auditor location: Boston, MA - Contact: Editha Tenorio - Phone: 617-664-4509 - Email: evtenorio@statestreet.com - Website: statestreet.com - Signed by: Editha Tenorio (Chief Financial Officer) Original filing: https://www.sec.gov/Archives/edgar/data/885750/000088575026000002/2025ssgafdbs.pdf --- {0}------------------------------------------------ S T A T E M E N T O F F I N A N C I A L C O N D I T I O N State Street Global Advisors Funds Distributors, LLC (a wholly-owned subsidiary of State Street Global Advisors, Inc.) December 31, 2025 With Report of Independent Registered Public Accounting Firm (Confidential Pursuant to SEC Rule 17a-5(e)(3)) {1}------------------------------------------------ | Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934 | FACING PAGE | | | | | |---------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------|-----------------------------------------|--------------------------------------------|--|--| | | | 12/31/25 | | | | | FILING FOR THE PERIOD BEGINNING 01/01/25 | MM/DD/YY | AND ENDING | MM/DD/YY | | | | | A. REGISTRANT IDENTIFICATION | | | | | | NAME OF FIRM: State Street Global Advisors Funds Distributors, LLC | | | | | | | TYPE OF REGISTRANT (check all applicable boxes):
Broker-dealer
Check here if respondent is also an OTC derivatives dealer | _ Security-based swap dealer | _ Major security-based swap participant | | | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) | | | | | | | ONE CONGRESS STREET | | | | | | | | (No. and Street) | | | | | | BOSTON | | MASSACHUSETTS 02114 | | | | | (City) | (State) | | (Zip Code) | | | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | | | | DITHA TENORIO | 617-664-4509 | | evtenorio@statestreet.com | | | | (Name) | (Area Code - Telephone Number) | | (Email Address) | | | | B. ACCOUNTANT IDENTIFICATION | | | | | | | INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing * | | | | | | | Ernst & Young LLP | | | | | | | | (Name - if individual, state last, first, and middle name) | | | | | | 200 Clarendon St | Boston | MA | 02116 | | | | (Address) | (City) | (State) | (Zip Code) | | | | 10/20/2003 | | 42 | | | | | (Date of Registration with PCAOB)(if applicable) | | | (PCAOB Registration Number, if applicable) | | | | | FOR OFFICIAL USE ONLY | | | | | | * Claims for exemption from the requirement that the annual reports of an independent public | | | | | | {2}------------------------------------------------ - - - - - - - - - - - - - - - - - - - - - - - - - - - {3}------------------------------------------------ # State Street Global Advisors Funds Distributors, LLC (a wholly-owned subsidiary of State Street Global Advisors, Inc.) # Contents | State Street Global Advisors Funds Distributors, LLC
(a wholly-owned subsidiary of State Street Global Advisors, Inc.)
Statement of Financial Condition
December 31, 2025
Contents
Facing Page and Oath or Affirmation
Statement of Financial Condition | | |---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------| | | | | | | | | | | | | | | | | | | | | Report of Independent Registered Public Accounting Firm……………………………………… 1 | | | 2
Notes to Statement of Financial Condition3 | | | | {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) #### Report of Independent Registered Public Accounting Firm To the Board of Managers and Equity Owners of State Street Global Advisors Funds Distributors, LLC #### Opinion on the Financial Statement We have audited the accompanying statement of financial condition of State Street Global Advisors Funds Distributors, LLC (the Company) as of December 31, 2025, and the related notes (the our opinion, the financial statement presents fairly, in all material respects, the financial position of the Company at December 31, 2025, in conformity with U.S. generally accepted accounting principles. #### Basis for Opinion 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 statement is 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 statement, 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 statement. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall financial statement presentation. We believe that our audit provides a reasonable basis for our opinion. 1992. {5}------------------------------------------------ # State Street Global Advisors Funds Distributors, LLC (a wholly-owned subsidiary of State Street Global Advisors, Inc.) # Statement of Financial Condition # December 31, 2025 | (a wholly-owned subsidiary of State Street Global Advisors, Inc.) | | |-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------| | Statement of Financial Condition | | | December 31, 2025 | | | Assets
Cash and cash equivalents
Receivable from affiliates | \$
166,476,911
23,857,396 | | Distribution, marketing and 12b-1/shareholder servicing
accruals/receivables
Other assets | 73,604,675
2,662,995 | | Total assets | \$
266,601,977 | | Liabilities and member's equity
Liabilities: | | | Payable to affiliates
Accrued tax liability
Distribution, marketing and 12b-1/shareholder servicing accruals/payables
Deferred revenue
Other accrued expenses and liabilities | \$
29,367,907
10,521,354
13,468,137
206,506
190,928 | | Total liabilities | 53,754,832 | | Member's equity
Total liabilities and member's equity | \$
212,847,145
266,601,977 | {6}------------------------------------------------ # Global Advisors Funds Distributors, LLC (a wholly-owned subsidiary of State Street Global Advisors, Inc.) Notes to Statement of Financial Condition December 31, 2025 # 1. Organization and Description of Business State Street Global Advisors Funds Distributors, LLC (the Company), a Delaware single-member limited liability company, is a wholly-owned subsidiary of State Street Global Advisors, Inc. (SSGA Inc.). SSGA, Inc. is a wholly-owned subsidiary of State Street Corporation (the Parent). The Company was incorporated on April 21, 1999. The Company is a limited purpose broker-dealer registered with the U.S. Securities Exchange Commission (SEC) and Financial Industry Regulatory Authority (FINRA) and is a member of the Securities Investor Protection Corporation and National Securities Clearing Corporation. The Company is authorized to engage in the following types of business: (i) mutual fund underwriter or sponsor and (ii) private placement of securities. As part of its underwriter and sponsor activities the Company supports the State Street Investment Management (State Street IM, formerly named State Street Global Advisors or SSGA) businesses by providing U.S. mutual fund and ETF distribution and marketing services. In connection with such services, the Company also provides shareholder servicing to U.S. mutual funds. In addition, as part of its private placement activities, the Company may privately offer State Street IM advised funds. ## 2. Summary of Significant Accounting Policies The Financial Statements have been prepared in accordance with accounting principles generally accepted in the United States (U.S. GAAP). Events occurring subsequent to the date of the Financial Statements were evaluated through February 26, 2026, the date the Financial Statements were issued. ## Use of Estimates The preparation of the Financial Statements in conformity with U.S. GAAP requires management to make estimates and assumptions in the application of certain of our significant accounting policies that may materially affect the reported amounts of assets, liabilities, equity, revenue, and expenses. Actual results could differ from those estimates. {7}------------------------------------------------ # 2. Summary of Significant Accounting Policies (continued) # Cash and Cash Equivalents Cash and cash equivalents represent cash on deposit with a financial institution and highly liquid investments in money market mutual funds. The Company has no restricted cash as of December 31, 2025. Condition are described in further detail in Note 10 to the Financial Statements. All outstanding ## Receivable from and Payable to Affiliates The receivables from and payables to affiliates reflected in the Company's Statement of Financial balances are intended to be cash settled and are appropriately classified as receivables and payables. #### Allowance for Credit Losses The Company recognizes an allowance for credit losses in accordance with ASC 326, Financial Instruments – Credit Losses (ASC 326). ASC 326 requires recognition of expected credit losses for certain financial assets and off-balance sheet commitments, including trade and other receivables, loans and commitments and other financial assets held at amortized cost at the reporting date, to be measured based on historical experience, current conditions, and reasonable and supportable forecasts. The ASC 326 credit loss was de minimis to the Financial Statements as of December 31, 2025. The Company had no subordinated liability contracts throughout the year ended or as of December ## Subordinated Liabilities 31, 2025. ## Income Taxes The operations of the Company are included with those of the Parent in filing the consolidated federal income tax return and certain unitary state returns. The Parent allocates income tax expense to the Company based upon its contribution to the consolidated income tax return filings. The Company reimburses the Parent for the expense recognized based upon its tax-sharing agreement. The Company's tax-sharing agreement is in accordance with ASC 740, Income Taxes. ## Tax Uncertainty In accordance with relevant accounting guidance, an entity is permitted to recognize the benefit of uncertain tax positions only where the position is "more likely than not" to be sustained in the event of examination by tax authorities based on the technical merits of the position. The maximum tax benefit recognized is limited to the amount that is greater than 50% likely to be realized upon ultimate settlement. {8}------------------------------------------------ # 2. Summary of Significant Accounting Policies (continued) ## Recent Accounting Developments We adopted ASU 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures, prospectively for the annual reporting period ending December 31, 2025. The standard aims to improve transparency and comparability of income tax disclosures primarily by requiring consistent and expanded disclosures related to the reconciliation of the statutory and effective tax rate and disaggregated disclosure of income taxes paid by jurisdiction. #### 3. Segment Reporting The Company has one reportable segment as a limited purpose broker-dealer which provides services as described in Note 1. The Chief Operating Decision Maker (CODM) is the Board of Managers. Net income is used by the CODM to assess the Company's performance and deciding how to allocate resources, invest profits, retain excess net capital, or to pay its parent a dividend. Additionally, the CODM uses excess net capital (see Note 9), 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, because the CODM manages the business activities using information of the Company as a whole. 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. #### 4. Income Taxes Pursuant to an intercompany tax-sharing agreement with the Parent, the Company accrues federal and state tax expense, which is also paid to or received from the Parent. As of December 31, 2025, the Company has a net deferred tax liability of \$25,236 which consists of the following items: | Deferred tax assets:
Prepaid expenses | \$
67,618 | |------------------------------------------|----------------| | Deferred tax liabilities: | | | Deferred revenue | (92,854) | | Net deferred tax liability | \$
(25,236) | As of December 31, 2025, the Company has identified no uncertain tax positions. If there were uncertain tax positions, it is the Company's policy to record associated interest and penalties as a component of income tax expense. The earliest year open to examination is 2018. {9}------------------------------------------------ ## 5. Fair Value of Financial Instruments Fair value is defined as the exchange price that would be received for an asset or paid to transfer a liability (an exit price) in the principal or most advantageous market for the asset or liability in an orderly transaction between market participants on the measurement date. Financial assets and liabilities carried at fair value on a recurring basis are categorized based upon a prescribed three-level valuation hierarchy that prioritizes the inputs used to measure fair value. The three levels of inputs used to measure fair value are as follows: Level 1 – Financial assets and liabilities whose values are based on unadjusted quoted prices for identical assets or liabilities in an active market. Examples of Level 1 financial instruments include active exchange-traded equity securities and certain U.S. government securities. At December 31, 2025, there were no financial instruments classified in Level 1. Level 2 – Financial assets and liabilities whose values are based on quoted prices for similar assets and liabilities in active markets, and inputs that are observable for the asset or liability, either directly or indirectly, for substantially the full term of the asset or liability. Level 2 financial instruments include money market mutual funds. Level 3 – Financial assets and liabilities whose values are based on prices or valuation techniques that require inputs that are both unobservable in the market and significant to the overall fair value measurement. These inputs reflect management's judgment about the assumptions that a market participant would use in pricing the asset or liability, and are based on the best available information, some of which is internally developed. At December 31, 2025, there were no financial instruments classified in Level 3. This hierarchy requires the Company to use observable market data, when available, and to minimize the use of unobservable inputs when determining fair value. The inputs or methodology used to value an investment are not necessarily an indication of the risk associated with investing in those securities. The following table presents information about the Company's financial assets carried at fair value in the Statement of Financial Condition as of December 31, 2025: | | Quoted
Market
Prices in
Active
Markets
(Level 1) | | Pricing
Methods with
Significant
Observable
Market Inputs
(Level 2) | Pricing Methods
with Significant
Unobservable
Market Inputs
(Level 3) | Total Net
Carrying Value
in
Statement of
Financial
Condition | | |-------------------------------------|-----------------------------------------------------------------|---|------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------|-----------------------------------------------------------------------------|--| | Assets
Money market mutual funds | \$ | – | \$ 159,205,144 | \$
– | \$ 159,205,144 | | | Total assets carried at fair value | \$ | – | \$ 159,205,144 | \$
– | \$ 159,205,144 | | {10}------------------------------------------------ # 5. Fair Value of Financial Instruments (continued) There were no financial liabilities carried at fair value in the Statement of Financial Condition as of December 31, 2025. There were no transfers of financial assets between levels during the year ended December 31, 2025. The fair value of highly liquid, short-term assets and liabilities, including cash, receivables, payables, and accrued expenses approximates their carrying value given that they are short term in nature or bear interest at current market rates. # 6. Contingencies In the normal course of business, the Company receives requests from regulators for information and is subject to regulatory examinations. These examinations may result in fines or penalties. The Company does not expect the outcome of any pending examinations to have a material impact to the financial position, operations, or regulatory capital of the Company. # 7. Concentration Risk A significant portion of the Company's revenues is derived from payments received from SSGA Funds Management, Inc. (SSGA FM, an affiliated entity), World Gold Trust Services, LLC (WGTS) and PDR Services, LLC (PDR) for distribution and/or marketing services performed by the Company in respect to funds sponsored by each of SSGA FM, WGTS and PDR. These revenues could be adversely affected by any number of market events, such as price volatility, new entrants into the market space, or economic conditions. # 8. Liquidity Risk Management The Company holds a significant portion of its assets in cash and short-term highly liquid money market instruments. As of December 31, 2025, total cash held was \$7 million and money market instruments were \$159 million which represents 62% of total assets. These assets are represented in Cash and cash equivalents on the Statement of Financial Condition. The Company monitors its available Cash and cash equivalents to ensure sufficient liquidity to meet operating needs. # 9. Regulatory Capital Requirements As a registered broker-dealer, the Company is subject to the net capital requirements of the SEC's Uniform Net Capital Rule under Rule 15c3-1 of the Securities Exchange Act of 1934, as amended (Exchange Act). The Company follows the basic method of computing regulatory net capital requirements provided for in Rule 15c3-1. Under the basic method, the Company must maintain net capital equal to the greater of 6-2/3% of aggregate indebtedness, as defined, or \$25,000, whichever is greater. The minimum required net capital as of December 31, 2025 was \$3,581,974 under the aggregated indebtedness method. At December 31, 2025, the Company's net capital was \$109,537,976 which was \$105,956,002 in excess of the minimum required net capital under Rule 15c3-1. {11}------------------------------------------------ 9. Regulatory Capital Requirements (continued) to certain notification and other provisions of Rule 15c3-1 and other regulatory bodies. Advances to affiliates, dividend payments, distributions and other equity withdrawals are subject The Company has claimed an exemption from Rule 15c3-3 of the SEC Exchange Act under paragraphs (k)(2)(i) of that rule for the period January 1, 2025 through December 31, 2025 and therefore is not required to make a reserve requirement computation. 10. Related Party Transactions The Company enters into transactions in the ordinary course of business with affiliated entities of the Parent, including State Street Global Advisors Trust Company (SSGA TC), State Street Bank and Trust (SSBT), SSGA FM, State Street Global Advisors Limited (SSGA Ltd), State Street Global Advisors Europe Limited (SSGAEL) and State Street Global Markets, LLC (SSGM). ## Cash and Cash Equivalents Included in cash and cash equivalents in the Statement of Financial Condition is cash of \$7.3 million which is held on deposit at SSBT, and cash equivalents of \$159.2 million which is invested in a money market mutual fund, managed by an affiliate, SSGA FM. # Distribution, Marketing and Shareholder Servicing The Company distributes and/or markets funds sponsored by SSGA FM, SSGA Ltd and SSGAEL. SSGA FM, SSGA Ltd and SSGAEL have agreed to reimburse the Company for distribution and marketing expenses incurred by the Company in connection with its distribution and marketing activities relating to such funds. At December 31, 2025, \$23.9 million was a receivable from SSGA FM, and included in the receivable from affiliates in the Statement of Financial Condition. Distribution and marketing expenses associated with certain third party sponsored ETFs that are not reimbursed by the Sponsor of such ETFs are paid to the Company by SSGA TC who serves as Trustee for such ETFs. The Company earns 12b-1 and/or shareholder servicing fees for services provided to certain classes of registered mutual funds sponsored by SSGA FM. At December 31, 2025, the receivable from the mutual funds was \$8.7 million and included in the distribution, marketing and 12b-1/shareholder servicing accruals/receivables in the Statement of Financial Condition. Of the costs associated with 12b-1/shareholder servicing during the year ended December 31, 2025, the Company owes SSGM, SSBT and certain of its affiliates \$1.1 million as of December 31, 2025, and included in payable to affiliates in the Statement of Financial Condition. There were no private placements during the year ended December 31, 2025. {12}------------------------------------------------ # 10. Related Party Transactions (continued) # Capital Distribution In November 2025, pursuant to a resolution of the Company's Board of Managers and with prior written notice to FINRA in accordance with Rule 15c3-1, the Company made a capital distribution to its parent SSGA Inc., decreasing its equity in 2025 by \$37,000,000. ## Expense Allocation The Parent and its affiliates pay all costs related to the Company's personnel, including coverage under the Parent's benefit plans. The Parent and its affiliates also provide legal, accounting, audit, data processing, marketing, other administrative support, use of office space and equipment to the Company pursuant to agreements, as amended, between the Company and certain affiliates. Under the terms of the agreements, the Company reimburses the Parent and its affiliates for all costs incurred by the Parent and its affiliates. amount payable to the Parent is \$10.5 million reflected on the Statement of Financial Condition. At December 31, 2025, \$28.3 million of these costs were payable by the Company to affiliates of the Parent, and included in payable to affiliates on the Statement of Financial Condition. #### Income Taxes The Company paid income tax expenses to the Parent as part of an intercompany tax-sharing agreement during the year ended December 31, 2025. At December 31, 2025, the remaining {13}------------------------------------------------ ![](_page_13_Picture_0.jpeg) State Street Global Advisors Funds Distributors February 2 , 202 State Street Global Advisors Funds Distributors, LLC Exemption Report State Street Global Advisors Funds Distributors LLC (the "Company") is a registered brokerdealer 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 claimed an exemption from 17 C.F.R. § 240.15c3-3 under the following (2) The Company met the identified exemption provisions in 17 C.F.R. § 240.15c3-3(k) true and correct. \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ Editha Tenorio Date provisions of 17 C.F.R. § 240.15c3-3 (k) (2)(i). throughout the most recent fiscal year without exception. I, Editha Tenorio, affirm that, to the best of my knowledge and belief, this Exemption Report is Chief Financial Officer {14}------------------------------------------------ ![](_page_14_Picture_0.jpeg) #### Report of Independent Registered Public Accounting Firm The Board of Managers and Management State Street Global Advisors Funds Distributors, LLC We have reviewed management's statements, included in the accompanying State Street Global Advisors Funds Distributors, LLC Exemption Report, in which (1) State Street Global Advisors Funds Distributors, LLC (the Company) identified the following provision of 17 C.F.R. § 15c3-3(k) under which the Company claimed an exemption from 17 C.F.R. § 240.15c3-3(k) (2)(i) (the "exemption provision") and (2) the Company stated that it met the identified exemption provision in 17 C.F.R. § 240.15c3-3 (k) throughout the most recent fiscal year ended December 31, 2025 without exception. Management is responsible for compliance with the exemption provision 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 the on provision. 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. statements referred to above for them to be fairly stated, in all material respects, based on the provision set forth in paragraph (k)(2)(i) of Rule 15c3-3 under the Securities Exchange Act of 1934. This report is intended solely for the information and use of the Board of Managers, management, the SEC, Financial Industry Regulatory Authority, other regulatory agencies that rely on Rule 17a-5 under the Securities Exchange Act of 1934 in their regulation of registered brokers and dealers, and other recipients specified by Rule 17a-5(d)(6) and is not intended to be and should not be used by anyone other than these specified parties. {15}------------------------------------------------ ![](_page_15_Picture_0.jpeg) ## Report of Independent Registered Public Accounting Firm on Applying Agreed-Upon Procedures To the Board of Managers and Management State Street Global Advisors Funds Distributors, LLC We have performed the procedures included in Rule 17a-5(e)(4) under the Securities Exchange Act of 1934 and in the Securities Investor Protection Corporation (SIPC) Series 600 Rules, which are enumerated below on the accompanying General Assessment Reconciliation (Form SIPC-7) for the year ended December 31, 2025. Management of State Street Global Advisors Funds Distributors, LLC (Company) is responsible for its Form SIPC-7 and for its compliance with the applicable instructions on Form SIPC-7. Management of the Company has agreed to and acknowledged that the procedures performed are compliance with the applicable instructions on Form SIPC-7 for the year ended December 31, 2025. Additionally, SIPC has agreed to and acknowledged that the procedures performed are appropriate for their intended purpose. This report may not be suitable for any other purpose. The procedures performed may not address all the items of interest to a user of this report and may not meet the needs of all users of this report and, as such, users are responsible for determining whether the procedures performed are appropriate for their purposes. The sufficiency of these procedures is solely the responsibility of those parties specified in this report. Consequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose. The procedures we performed and the associated findings are as follows: - 1. Compared the listed assessment payments in Form SIPC-7 with respective cash disbursement records entries No findings were found as a result of applying the procedure. - 2. Compared the total revenue amounts reported on the annual audited report Form X-17A-5 Part III for the fiscal year ended December 31, 2025 with the total revenue amounts reported in Form SIPC-7 for the year-ended December 31, 2025. No findings were found as a result of applying the procedure. - 3. Compared any adjustments reported in Form SIPC-7 with supporting schedules and working papers provided to us by representatives of the Company. No findings were found as a result of applying the procedure. - 4. Recalculated the arithmetical accuracy of the calculations reflected in Form SIPC-7 and in the related schedules and working papers supporting the adjustments. No findings were found as a result of applying the procedure. {16}------------------------------------------------ We were engaged by the Company to perform this agreed-upon procedures engagement and conducted our engagement in accordance with attestation standards established by the American Institute of Certified Public Accountants and in accordance with the standards of the Public Company Accounting Oversight Board (United States). An agreed-upon procedures engagement involves the practitioner performing specific procedures that the engaging party has agreed to and acknowledged to be appropriate for the purpose of the engagement and reporting on findings based on the procedures performed. We were not engaged to, and did not conduct an examination or a review engagement, the objective of which would be the expression of an opinion or conclusion, -7 and for its compliance with the applicable instructions on Form SIPC-7 for the year ended December 31, 2025. Accordingly, we do not express such an opinion or conclusion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you. We are required to be independent of the Company and to meet our other ethical responsibilities in As agreed, and in accordance with guidance from SIPC, for purposes of performing procedures 1 and 4 above, differences of \$1 or less will not be reported in our findings. For purposes of performing procedures 2 and 3 above, differences of \$25 or less will not be reported in our findings. accordance with the relevant ethical requirements related to our agreed-upon procedures engagement. This report is intended solely for the information and use of the Company and SIPC and is not intended to be, and should not be, used by anyone other than these specified parties. Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.