# CAPITAL RESEARCH BROKERAGE SERVICES, LLC X-17A-5 (2026-02-09) — Broker-dealer annual report

- Company: CAPITAL RESEARCH BROKERAGE SERVICES, LLC
- Form: X-17A-5
- Filed: 2026-02-09
- Period: 2025-12-31
- Accession: 0001012055-26-000001
- CIK: 1012055
- File #: 8-49213
- Type: Broker-dealer
- Material weakness: No
- Auditor: DCPA
- Auditor location: Century City, CA
- Contact: Felicity Goldstone
- Phone: 6268441440
- Email: jodell@arroyoinvestmentgroup.com
- Website: arroyoinvestmentgroup.com
- Signed by: John Odell (Principal)

Original filing: https://www.sec.gov/Archives/edgar/data/1012055/000101205526000001/crbsauditfile1.pdf

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**Capital Research Brokerage Services, LLC Report Pursuant to Rule 17a-5(d) Financial Statements For the Year Ended December 31, 2025**

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

| ANNUAL REPORTS |  |  |  |
|----------------|--|--|--|
| FORM X-17A-5   |  |  |  |
| PART III       |  |  |  |

SEC FILE NUMBER 8-49213

FACING PAGE

Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934

FILING FOR THE PERIOD BEGINNING 01/01/25

MM/DD/YY

\_AND ENDING\_12/31/25 MM/DD/YY

A. REGISTRANT IDENTIFICATION

NAME OF FIRM: CAPITAL RESEARCH BROKERAGE SERVICES, LLC

TYPE OF REGISTRANT (check all applicable boxes):

@ Broker-dealer □ Check here if respondent is also an OTC derivatives dealer

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

# 15 S. RAYMOND AVENUE SUITE 200

|                                                                                   | (No. and Street)                                           |                                            |                                  |
|-----------------------------------------------------------------------------------|------------------------------------------------------------|--------------------------------------------|----------------------------------|
| PASADENA,                                                                         | CA                                                         |                                            | 91105                            |
| (City)                                                                            | (State)                                                    |                                            | (Zip Code)                       |
| PERSON TO CONTACT WITH REGARD TO THIS FILING                                      |                                                            |                                            |                                  |
| John P. Odell                                                                     | 626-844-1440                                               |                                            | jodell@arroyoinvestmentgroup.com |
| (Name)                                                                            | (Area Code - Telephone Number)                             | (Email Address)                            |                                  |
|                                                                                   | B. ACCOUNTANT IDENTIFICATION                               |                                            |                                  |
| INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*<br>DCPA | (Name - if individual, state last, first, and middle name) |                                            |                                  |
| 2121 Avenue of the Stars #800 Century City                                        |                                                            | California 90067                           |                                  |
| (Address)                                                                         | (City)                                                     | (State)                                    | (Zip Code)                       |
| 9/15/2020                                                                         |                                                            | 6567                                       |                                  |
| (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 accountant must be supported by a statement of facts and circumstances relied on as the basis of the exemption. See 17 CFR 240.17a-5(e)(1)(ii), if applicable.

Persons who are to respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB control number.

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#### OATH OR AFFIRMATION

| John P. Odell |                        |  |                                                                                                                                     |            | swear (or affirm) that, to the best of my knowledge and belief, the |  |       |
|---------------|------------------------|--|-------------------------------------------------------------------------------------------------------------------------------------|------------|---------------------------------------------------------------------|--|-------|
|               |                        |  | financial report pertaining to the firm of CAPITAL RESEARCH BROKERAGE SERVICES, LLC                                                 |            |                                                                     |  | as of |
| 12/31         |                        |  | , 2 025 __ 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: |                                                                     |  |       |
|               |                        |  |                                                                                                                                     |            |                                                                     |  |       |

Title:

vincipal

Notary Public

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

- (a) Statement of financial condition.
- | (b) Notes to consolidated statement of financial condition.
- (c) Statement of income (loss) or, if there is other comprehensive income in the period(s) presented, a statement of comprehensive income (as defined in § 210.1-02 of Regulation S-X).
- (d) Statement of cash flows.
- (e) Statement of changes in stockholders' or partners' or sole proprietor's equity.
- □ (f) Statement of changes in liabilities subordinated to claims of creditors.
- = (g) Notes to consolidated financial statements.
- @ (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-1, as applicable.
- [ (i) Computation of tangible net worth under 17 CFR 240.18a-2.
- (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.
- (o) Reconciliations, including 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-2, or 17 CFR 240.18a-2, as applicable, and the reserve requirements under 17 CFR 240.15c3-3 or 17 CFR 240.18a-4, as applicable, if material differences exist, or a statement that no material differences exist.
- □ (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition.
- = (q) Oath or affirmation in accordance with 17 CFR 240.17a-5, 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable.
- □ (r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- | (s) Exemption report in accordance with 17 CFR 240.18a-7, as applicable.
- □ (t) Independent public accountant's report based on an examination of the statement of financial condition.
- (u) Independent public accountant's report based on an examination of the financial statements under 17 CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable.
- □ (v) Independent public accountant's report based on an examination of certain statements in the compliance report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- (w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- □ (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-1e or 17 CFR 240.17a-12, as applicable.
- □ (y) Report describing any material inadequacies found to have existed since the date of the previous audit, or a statement that no material inadequacies exist, under 17 CFR 240.17a-12(k).
- □ (z) Other:
- \*\*To request confidential treatment of certain portions of this filing, see 17 CFR 240.17a-5(d)(2), as applicable.

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

DCPA

To Those Charged with Governance and the Member of Capital Research Brokerage Services, LLC:

#### **Opinion on the Financial Statements**

We have audited the accompanying statement of financial condition of Capital Research Brokerage Services, LLC (the "Company") as of December 31, 2025, the related statements of income, changes in member's equity, and cash flows for the year then ended, and the related notes (collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Company as of December 31, 2025, and the results of its operations and its cash flows for the year then ended, in conformity with accounting principles generally accepted in the United States.

#### **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.

#### **Supplemental Information**

The information contained in Schedules I and II ("Supplemental Information") has been subjected to audit procedures performed in conjunction with the audit of the Company's financial statements. The Supplemental Information is the responsibility of the Company'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, Schedules I and II are fairly stated, in all material respects, in relation to the financial statements taken as a whole.

 **DCPA**

DCPA We have served as the Company's auditor since 2022. Century City, California January 12, 2026

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# **Capital Research Brokerage Services, LLC Statement of Financial Condition December 31, 2025**

#### **Assets**

| Cash                                  | \$<br>13,118 |
|---------------------------------------|--------------|
| Prepaid expense                       | 2,381        |
| Total assets                          | \$<br>15,499 |
| Liabilities and Member's Equity       |              |
| Liabilities                           |              |
| Total liabilities                     | \$<br>-      |
| Member's equity                       |              |
| Member's equity                       | 15,499       |
| Total member's equity                 | 15,499       |
| Total liabilities and member's equity | \$<br>15,499 |

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# **For the Year Ended December 31, 2025 Statement of Income Capital Research Brokerage Services, LLC**

#### **Revenues**

| Commissions income                            | \$<br>115,521 |
|-----------------------------------------------|---------------|
| Total revenues                                | 115,521       |
| Expenses                                      |               |
| Occupancy - related parties                   | 24,200        |
| Regulatory Fees                               | 4,912         |
| Administrative expenses - related parties     | 33,000        |
| Other operating expenses                      | 14,523        |
| Total expenses                                | 76,635        |
| Net income (loss) before income tax provision | 38,886        |
| Income tax                                    | 800           |
| Net income (loss)                             | \$<br>38,086  |

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# **Capital Research Brokerage Services, LLC Statement of Changes in Member's Equity For the Year Ended December 31, 2025**

|                              | Member's<br>Equity |  |
|------------------------------|--------------------|--|
| Balance at December 31, 2024 | \$<br>42,413       |  |
| Net income (loss)            | 38,086             |  |
| Member Distribution          | (65,000)           |  |
| Balance at December 31, 2025 | \$<br>15,499       |  |

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# **For the Year Ended December 31, 2025 Statement of Cash Flows Capital Research Brokerage Services, LLC**

| Cash flow from operating activities:                   |                |              |
|--------------------------------------------------------|----------------|--------------|
| Net income (loss)                                      |                | \$<br>38,086 |
| Adjustments to reconcile net income (loss) to net      |                |              |
| cash provided by (used in) operating activities:       |                |              |
| (Increase) decrease in:                                |                |              |
| (Decrease) increase in:                                |                |              |
| Total adjustments                                      |                | -            |
| Net cash provided by (used in) operating activities    |                | 38,086       |
| Net cash provided by (used in) in investing activities |                |              |
| Cash flow used in financing activities:                |                |              |
| Capital distributions                                  | \$<br>(65,000) |              |
| Net cash provided by (used in) financing activities    |                | (65,000)     |
| Net increase (decrease) in cash                        |                | (26,914)     |
| Cash at December 31, 2024                              |                | 40,032       |
| Cash at December 31, 2025                              |                | \$<br>13,118 |
| Supplemental disclosure of cash flow information:      |                |              |
| Cash paid during the year for:                         |                |              |
| Interest                                               | \$<br>-        |              |
| Income taxes                                           | \$<br>800      |              |

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### **Note 1: GENERAL AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES**

### *General*

Capital Research Brokerage Services, LLC (the "Company") was organized as a California Limited Liability Company ("LLC") on November 12, 1997. In May 2000, the Company acquired The Oakwood Group of Michigan, LLC., a broker/dealer organized on February 14, 1996, in the State of North Carolina as a Limited Liability Company. The surviving company maintained the broker/dealer under the name Capital Research Brokerage Services, LLC. The Company is a registered broker/dealer under the Securities and Exchange Act of 1934 ("SEC"), the Financial Industry Regulatory Authority ("FINRA"), and Municipal Securities Rulemaking Board ("MRSB").

The Company is affiliated through common ownership with Arroyo Investment Group ("AIG") and Capital Research & Consulting, LLC ("CRC")

The Company is engaged in business as a securities broker-dealer, that provides several classes of services, including mutual fund retailer, mutual fund distributor, broker or dealer selling variable life insurance or annuities, and sale of Section 529 plans.

### *Summary of Significant Accounting Policies*

The presentation 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 the financial statements and the reported amounts of revenue and expenses during the reporting period. Actual results could differ from those estimates.

The Company, with the consent of its Member, has elected to be a California Limited Liability Company. For tax purposes the Company is treated like a partnership; therefore, in lieu of business income taxes, the Member is taxed on the Company's taxable income. Accordingly, no provision or liability for Federal Income Taxes is included in these financial statements.

The Company utilizes certain fully depreciated fixed assets, consisting of office furniture and office equipment with original cost amounting to approximately \$12,000 and \$5,000, respectively.

The Company earns Commissions income from the sale of mutual fund shares to customers, as well as associated ongoing 12b-1 fees. The Company recognizes the commission revenue from mutual fund sales as of the trade date. The Company recognizes mutual fund 12b-1 fees in the period received, which corresponds to the Company's performance of its ongoing marketing obligations and the satisfaction of variable consideration constraints. These constraints include market value fluctuations, customer investment decisions, and mutual fund fee policies.

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### **Note 2: INCOME TAXES**

As discussed in Note 1, the Company has elected to be a California Limited Liability Company and, as a consequence, no provision for Federal Income Taxes is included in these financial statements. However, the company is subject to a limited liability company gross receipts tax, with a minimum franchise tax. As of December 31, 2025, the income tax provision consists of the following:

| Franchise tax      | \$<br>800 |
|--------------------|-----------|
| Gross receipts tax | -         |
| Total income tax   | \$<br>800 |

# **Note 3: RELATED PARTY TRANSACTIONS**

On April 29, 2004, the Company entered into a "shared expense" agreement in complying with FINRA and SEC rules and regulations. The agreement is between the Company, Arroyo and CRC. Under the agreement, the Company maintains its operations utilizing the office space and staff of another company, and will record monthly fees for facilities, administration, advisory services, and other fees. For the year ended December 31, 2025, a total amount of \$57,200 was paid to these affiliates as shown on the Statement of Income under Occupancy and Administrative expenses. The Company records the shared expenses monthly as billed.

It is possible that the terms of certain of the related party transactions are not the same as those that would result for transactions among wholly unrelated parties.

### **Note 4: RECENTLY ISSUED ACCOUNTING STANDARDS**

The Financial Accounting Standards Board (the "FASB") has established the Accounting Standards Codification ("Codification" or "ASC") as the authoritative source of generally accepted accounting principles ("GAAP") recognized by the FASB. The principles embodied in the Codification are to be applied by nongovernmental entities in the preparation of financial statements in accordance with GAAP in the United States. New accounting pronouncements are incorporated into the ASC through the issuance of Accounting Standards Updates ("ASUs")

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# **Note 4: RECENTLY ISSUED ACCOUNTING STANDARDS (Continued)**

For the year ending December 31, 2025, various ASUs issued by the FASB were either newly issued or had effective implementation dates that would require their provisions to be reflected in the financial statements for the year then ended. The Company has either evaluated or is currently evaluating the implications, if any, of each of these pronouncements and the possible impact they may have on the Company's financial statements. In most cases, management has determined that the pronouncement has either limited or no application to the Company and, in all cases, implementation would not have a material impact on the financial statements taken as a whole.

### **Note 5: NET CAPITAL REQUIREMENTS**

The Company is subject to the Securities and Exchange Commission Uniform Net Capital Rule (SEC rule 15c3-1), 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. Rule 15c3-1 also provides that equity capital may not be withdrawn or cash dividends paid if the resulting net capital ratio would exceed 10 to 1. Net capital and aggregate indebtedness change day to day, but on December 31, 2025, the Company had net capital of \$13,118 which was \$8,118 in excess of its required net capital of \$5,000; and the Company's ratio of aggregate indebtedness (\$0) to net capital was 0 to 1, which is less than the 15 to 1 maximum allowed.

#### **Note 6: COMMITMENTS AND CONTINGENCIES**

The Company had no commitments, no contingent liabilities and had not been named as defendant in any lawsuit at December 31, 2025 or during the year then ended.

#### **Note 7: GUARANTEES**

FASB ASC 460, Guarantees, requires the Company to disclose information about its obligations under certain guarantee arrangements. FASB ASC 460 defines guarantees as contracts and indemnification agreements that contingently require a guarantor to make payments to the guaranteed party based on changes in an underlying factor (such as an interest or foreign exchange rate, security or commodity price, an index or the occurrence or nonoccurrence of a specified event) related to an asset, liability or equity security of a guaranteed party. This guidance also defines guarantees as contracts that contingently require the guarantor to make payments to the guaranteed party based on another entity's failure to perform under an agreement as well as indirect guarantees of indebtedness of others.

The Company has issued no guarantees at December 31, 2025 or during the year then ended.

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### **Note 8: SUBSEQUENT EVENTS**

The Company has evaluated events subsequent to the statement of financial condition date for items requiring recording or disclosure in the financial statements. The evaluation was performed through the date the financial statements were available to be issued. Based upon this review, the Company has determined that there were no events which took place that would have a material impact on its financial statements.

### **Note 9: SEGMENT REPORTING**

The Company follows Accounting Standards Update 2023-07 - Segment Reporting (Topic 280): Improvements to Reportable Segment Disclosures ("ASU 2023-07") , which expands reportable segment information by requiring companies to disclose, on an annual and interim basis, significant reportable segment expenses that are regularly provided to the Chief Operating Decision Maker ("CODM") and included within each reported measure of a segment's profit or loss. ASU 2023-07 also requires disclosure of the title and position of the individual identified as the CODM and an explanation of how the CODM makes decisions about allocating resources to segments and evaluating performance.

The Company conducts its business activities and reports financial results as a single reportable brokerage services segment. The CODM title and position is the CEO who makes decisions about allocating resources and assessing performance in a manner consistent with the way the Company operates its business and presents their financial results. The nature of business and accounting policies of the brokerage services segment are the same as described in the description of business and summary of significant accounting policies notes.

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## **Capital Research Brokerage Services, LLC Schedule I - Computation of Net Capital Requirements Pursuant to SEC Rule 15c3-1 As of December 31, 2025**

#### **Computation of net capital**

| Member's equity                                                             | \$<br>15,499 |              |
|-----------------------------------------------------------------------------|--------------|--------------|
| Total member's equity                                                       |              | \$<br>15,499 |
| Less: Non-allowable assets<br>Prepaid expense                               | (2,381)      |              |
| Total non-allowable assets                                                  |              | (2,381)      |
| Net Capital                                                                 |              | 13,118       |
| Computation of net capital requirements<br>Minimum net capital requirements |              |              |
| 6 2/3 percent of net aggregate indebtedness                                 | \$<br>-      |              |
| Minimum dollar net capital required                                         | \$<br>5,000  |              |
| Net capital required (greater of above)                                     |              | (5,000)      |
| Excess Net Capital                                                          |              | \$<br>8,118  |
| Ratio of aggregate indebtedness to net capital                              |              | 0:01         |

There was no material difference between Net Capital computation shown here and the net capital computation shown on the Company's most recently filed Form X-17A-5 Part IIA report dated December 31, 2025.

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# **Capital Research Brokerage Services, LLC Schedule II - Computation for Determination of the Reserve Requirements and Information Relating to Possession or Control Requirements For Brokers and Dealers Pursuant to SEC Rule 15c3-3 As of December 31, 2025**

The Computation for determination of the reserve requirements and information relating to possession or control Requirements for brokers and dealers is not applicable to the Company, as the Company is not subject to the provisions of Rule 15c3-3 as the Company does not, and will not, hold customer funds or securities, and that its business activities are, and will remain as direct mutual fund, annuities, and the sale of 529 plans. Accordingly, there are no items to report under the requirements of this Rule.

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**Capital Research Brokerage Services, LLC Report on Exemption Provisions Pursuant to Provisions of 17 C.F.R. § 15c3-3(k) For the Year Ended December 31, 2025**

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

DCPA

To Those Charged with Governance and the Member of Capital Research Brokerage Services, LLC:

We have reviewed management's statements, included in the accompanying Exemption Report, in which (1) Capital Research Brokerage Services, LLC does not claim an exemption under paragraph (k) of 17 C.F.R. § 240. 15c3-3, and (2) Capital Research Brokerage Services, LLC's other business activities contemplated by Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 ("Non-Covered Firm") but limited to (1) sale of 529 plans; and (2) mutual fund retailer; and (3) other sale of variable insurance or annuities and that the Company did not identify any exceptions to this assertion throughout the year ended December 31, 2025. Capital Research Brokerage Services, LLC's management is responsible for compliance with the exemption provisions, and the provisions of 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 Capital Research Brokerage Services, 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 provisions set forth in the Non-Covered Firm provision.

**DCPA**

DCPA

Century City, California January 12, 2026

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Capital Research Brokerage Services LLC 15 S Raymond Ave, #200 Pasadena, CA 91105

> Telephone 626 844 1440 Facsimile 626 440 1319

#### Capital Research Brokerage Services, LLC Exemption Report For the Year Ended December 31, 2025

Capital Research Brokerage Services, LLC ("the Company"), is a registered broker-dealer subject to Rule 17a -5 promulgated by the Securities and Exchange Commission (17 C.F.R. Section 240.17a -5, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R. Section 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 exclusively to (1) sale of 529 plans; and (2) mutual fund retailer; and (3) other sale of variable insurance or annuities. The Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of Rule 15c2-4; (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception.

Capital Research Brokerage Services, LLC

I, John P. Odell, swear (or affirm) that, to my best knowledge and belief, this Exemption Report is true

and correct. By: Title:


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