# B.B. GRAHAM & COMPANY, INC. X-17A-5 (2026-03-03) — Broker-dealer annual report

- Company: B.B. GRAHAM & COMPANY, INC.
- Form: X-17A-5
- Filed: 2026-03-03
- Period: 2025-12-31
- Accession: 0001019317-26-000003
- CIK: 1019317
- File #: 8-49477
- Type: Broker-dealer
- Material weakness: No
- Auditor: Garcia, Albert
- Auditor location: Newhall, CA
- Contact: Douglas Callen
- Phone: 7146285200
- Email: bgraham@bbgraham.com
- Website: bbgraham.com
- Signed by: Bruce Graham (President & CEO)

Original filing: https://www.sec.gov/Archives/edgar/data/1019317/000101931726000003/public2025auditOptim.pdf

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

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

| ONIO APPROVAL                                      |
|----------------------------------------------------|
| ONB Number: 3235-0123                              |
| Expites: Nov. 30, 2026<br>Estimated average burden |
| ficurs per response: 12                            |
|                                                    |
| STATE KE BE LEADER                                 |

| 1988 - 15 - 15 - 1<br>8-49477 |
|-------------------------------|
| Sunda A. June of              |

F

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 1/1/25                                                                                          |                                                            | AND ENDING 12/31/25                      |                                                   |
|---------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------|------------------------------------------|---------------------------------------------------|
|                                                                                                                                 | MM/DD/YY                                                   |                                          | MM/DD/YY                                          |
|                                                                                                                                 | A. REGISTRANT IDENTIFICATION                               |                                          |                                                   |
| NAME OF FIRM: B.B. Graham & Company, Inc.                                                                                       |                                                            |                                          |                                                   |
| TYPE OF REGISTRANT (check all applicable boxes):<br>Broker-dealer<br>Check Here if respondent is also an OTL gerivatives dealer | O Security-based swap dealer                               | [] Major security-based swap participant |                                                   |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.)<br>1700 W. Katella Ave.                                     |                                                            |                                          |                                                   |
|                                                                                                                                 | (No. and Street)                                           |                                          |                                                   |
| Orange                                                                                                                          | CA                                                         |                                          | 92867                                             |
| (City)                                                                                                                          | (State)                                                    |                                          | (Zip Code)                                        |
| PERSON TO CONTACT WITH REGARD TO THIS FILING                                                                                    |                                                            |                                          |                                                   |
| Bruce Edwin Graham                                                                                                              | (714) 628-5200                                             |                                          | bgraham@bbgraham.com                              |
| (Name)                                                                                                                          | (Area Code- Telephone Number)                              | (Email Address)                          |                                                   |
|                                                                                                                                 | B. ACCOUNTANT IDENTIFICATION                               |                                          |                                                   |
| INDEPENDENT PUBLICACCOUNTANT whose reports are contained in this filing"<br>Dylan Floyd Accounting & Consulting                 | (Name - if individual, state last, first, and middle name) |                                          |                                                   |
| Albert Garcia                                                                                                                   |                                                            |                                          |                                                   |
| (Address)                                                                                                                       | (City)                                                     | (State)                                  | (Zip Code)                                        |
| 20909 Judah Lane                                                                                                                | Newhall                                                    | CA                                       | 91312                                             |
| (Bate of Registration with PCADB) if applicable)                                                                                | 1316                                                       |                                          | (PCAOB Registration Number, if applicable) 6 2 35 |
|                                                                                                                                 | FOR OFFICIAL USE ONLY                                      |                                          |                                                   |

CHI 200.174.5 (EN(1)(), If anythatle
Pensons who are to respond to the collection of Antines Control of the Torm are not required to respond gries the form
disclays a current

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#### QATH OR AFFIRMATION

| Bruca Edwin Granam                                                                                                             |        | sweat (or altirm) that, to the best of my knowledge and belief, the               |       |
|--------------------------------------------------------------------------------------------------------------------------------|--------|-----------------------------------------------------------------------------------|-------|
| financial report pertaining to the firm of B.B. Graham & Company, inc.                                                         |        |                                                                                   | as of |
| December 3                                                                                                                     | 19.025 | is true and correct: I further swear (or affirm) that neitheathe );ompany nor any |       |
| partner, officer, director, or equivalent person, as the case may the any proprietery proresy in any account classified solaly |        |                                                                                   |       |
| as that of a customer.                                                                                                         |        |                                                                                   |       |
|                                                                                                                                |        |                                                                                   |       |

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Signature: Title: President/GEC

This filing "\* contains (check all applicable boxes);

- @ (a) Statement of financial condition.
- [b] Notes to consolidated statement of financial condition.
- a of 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).
- Statement of cash flows
- [e] Statement of changes in stockholders or partners' or sole proprietor's equilty.
- O (f) Statement of changes in liabilities subordinated to claims of creditors,
- In (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.
- [1] Computation of tannible networth under 17 CFR 240.185-2.
- @ {} Computation for determination of customer requirements pursuant to Exhibit A to 17 CFR 200.15c3-3.
- O (k) Computation for deterning based swap reserve requirements pursuant to Extifitits to 17 CFR 240.15c3-3 or Exhibit A to 17 CFR 240,18a-4, as applicable.
- 11) Computation for Determination of PAB Requirements under Exhibit Axo § 240,15c3-3.
- Information relating to possession or control requirements for customers under 17 CFR 240.1557-3.
- 1 (n) Information relating to possession or control requirements for security thated swap customers under: 17 CFR 240:15:3-3(p)(2) or 17 CFR 240.18a-4, as applicable.
- To Recomdilations, including appropriate explanations, of the FOCUS Report with computation of net capital on the capital on the wordt under 17/CFR. 240.183 1, 17 CFR. 240.18-2, as applicable, and the reserve requirements under 17 CFR 240150330 17.0 R 240 188-4, as applicable, it material differences exist, or a statement that no material differences exist.
- [p] Summary of financial data for subsidiaties not considirated in the statement of financial condition.
- To) Cath or affirmation in accordance with 17 CFR 240.17a-5, 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable.
- 1 (c) Complance report in accordance with: 17 GPR 240, 172-5 or 17 CFR 240, 18a-7, as applicable.
- Is Isl Enemption report in accordance with 17 CER 240, 17 CFR 240, 18a-7, as applicable.
- O it independent public accountant sveport based on an examination of the statement of financial condition.
- (q) findependent public accountent'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,
- 1 Will of the sendentants teport based on an examination of certains statements in the compliance report under 27 CHR 240.17a-5 dr 17 CFR 240.1Ea-7, as applicable.
- In Interendent publicaccountant's report based on a teview of the exemption report under 17 CFR 240.172-5 or 17 CER 240.18a-7 as applicable.
- St (8) Supplemental reports on applying agreed upon procedures, in accordance with 17 LER 240 1503-12, as anolicable.
- O for hepot desoftling any material inadequacies fround 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).
- E (z) Other:

<sup>&</sup>quot;To request to bildential trentment of certain portions of this filing, see 17 CFR240120-5lef(3) or 17 CFR 240.180-740(2), as applicable.

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B.B. Graham & Company, Inc.

Report Pursuant to Rule 17a-5 (d)

Financial Statements

For the Year Ended December 31, 2025

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#### DylanFloyd Accounting & Consulting

### Report of Independent Registered Public Accounting Firm

To the Board of Directors and Shareholders B.B. Graham & Company Inc.

#### Opinion on the Financial Statements

I have audited the accompanying statement of financial condition of B.B. Graham & Company Inc. as of December 31, 2025, the related statements of income, changes in shareholders' equity, and cash flows for the 2025 then ended, and the related notes and schedules. In my opinion, the financial statements present fairly, in all material respects, the financial position of B.B. Graham & Company Inc. as of December 31, 2025 and the results of its operations and its cash flows for the 2025 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 B.B. Graham & Company Inc. My responsibility is to express an opinion on B.B. Graham & Company Inc. financial statements based on my audit. I am a public accounting firm registered with the Public Company Accounting Oversight Board (PCAOB) and are required to be independent with respect to B.B. Graham & Company inc. in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCACB.

I conducted my audit in accordance with the standards of the PCAOB. Those standards require that I 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. My audit included performing procedures to assess the risks of material misstatement of the financial statements, whether que 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. My 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. I believe that my audit provides a reasonable basis for my opinion.

#### Auditor's Report on Supplemental Information

The supplemental information consist of schedule !... & III has been subjected to audit procedures performed in conjunction with the audit B.B. Graham & Company Inc.'s financial statements. The supplemental information is the responsibility of B.B. Graham & Company Inc.'s management. My audit procedures included determining whether the supplemental information reconciles to the financial statements or the underlying and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the supplemental information. In forming my opinion on the supplemental information, I evaluated whether the supplemental information, including its form and content, is presented in conformity with 17 C.F.R. §240.174-5. In my opinion, the supplemental in fairly stated, in all material respects, in relation to the financial statements as a whole.

DylanFlayd Accounting & Consulting

Newhall, California February 25, 2026

I have served as the Company's auditor since 2021.

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# BB Graham & Company, Inc. Statement of Financial Condition December 31, 2025

#### Assets

| Cash                                                         |         |   |              |
|--------------------------------------------------------------|---------|---|--------------|
| Checking and savings                                         |         | 6 | 147,121      |
| Money market                                                 |         |   | 1,133,272    |
| Total cash                                                   |         |   | 1,280,393    |
| Clearing broker deposit                                      |         |   | 50,000       |
| Commissions receivable                                       |         |   | 446,792      |
| Other receivable - allowable                                 |         |   | 4,392        |
| Other receivable - non allowable                             |         |   | 972          |
| Prepaid expenses                                             |         |   | 38,988       |
| Office equipment net of accumulated depreciation of \$15,336 |         |   |              |
| Total Assets                                                 |         |   | \$ 1,821,537 |
| Liabilities and Shareholder's Equity                         |         |   |              |
| Liabilities                                                  |         |   |              |
| Accrued expenses                                             |         | S | 31,475       |
| Commissions payable                                          |         |   | 531,275      |
| Credit card payable                                          |         |   | 10,756       |
| Deferred income correspondent fees                           |         |   | 324,678      |
| Due to secondary broker                                      |         |   |              |
| Salary and payroll taxes payable                             |         |   | 159,725      |
| Total Liabilities                                            |         |   | 1,057,909    |
| Shareholder's Equity                                         |         |   |              |
| ಕೆ<br>Common stock \$1 par value, 100,000 shares             | 100     |   |              |
| authorized and issued; 11,000 shares outstanding)            |         |   |              |
| Paid-in capital                                              | 151,900 |   |              |
| Retained earnings                                            | 611,628 |   | 763,628      |
| Total Liabilities and Shareholder's Equity                   |         |   | \$ 1,821,537 |

See accompanying notes to financial statements

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## B.B. Graham & Company, Inc. Notes to Financial Statements December 31, 2025

#### Note 1 - Organization and Nature of Business

B.B. Graham & Company, Inc. (the "Company") has been approved as a registered broker-dealer with the Securities and Exchange Commission under SEC Rule 15(b) as of August 8, 1996. The Company was incorporated in June 1996, and its membership in the NASD was approved May 1997. The NASD and NYSE Member Regulation consolidated in 2007 to form the Financial Industry Regulatory Agency ("FINRA"). The Company entered into an agreement with a clearing broker whereby the Company does not carry customer accounts. The Company introduces and forwards, as a broker, all transactions and accounts of customers to the clearing broker who carries such accounts on a fully disclosed basis. The Company forwards all funds and securities received in connection with its activities as a broker or dealer directly to the clearing broker and does not hold funds or securities for or owe funds or securities to customers.

Certain brokers (secondary clearing) clear their transactions through the Company and its clearing broker.

The Company has offices in California, Florida, Illinois, Oregon, Kansas, Maryland, Minnesota, Nebraska, Nevada, Oklahoma, Pennsylvania, and Texas.

#### Note 2 - Significant Accounting Policies

Basis of Presentation - The Company conducts business on a fully disclosed basis. The Company does not hold customer funds and/or securities. The Company currently conducts several types of business as a securities broker-dealer, including:

- Broker retailing corporate securities
- Selling group participant in best efforts underwritings
- Mutual fund retailer on an application basis
- U.S. Government securities broker
- Municipal securities broker
- Broker selling variable life insurance or annuities
- Broker selling oil and gas interest
- Put and call broker
- Broker selling tax shelters or limited partnerships in the secondary market
- Private placements of securities
	- Selling collateralized mortgages obligations
		- o Broker involved in networking, kiosks or similar arrangements with a bank, savings bank, or association or credit union

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# **B.B. Graham** & **Company,Inc. Notes• to Financial Statements Decem her 31, 2025**

# **Note 2** - **Sigoificant Accounting Policies** ( **continued)**

**Use of Estimates** - The preparation of financial statements in confonnity with a.c;:counting principles generally accepted. in the United States of America requires management to make estimates and asSUII1ptions that affect the reporteqamounts of assets andliabilities and disclosure.of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenµes and expenses during the reporting period. Actual results cotild·.differ from those estimates.

# Revenues -Adoptionof ASC Topic: 606 Revenue from Contracts with Customers

On January 1, 2021, the Cornpany adopted ASC TOpic 606, *Revenue from Contracts with Customers* ("Topic 606'') using the modified retrospective method applied to those contracts which were not completed as of January l, 2021. Results of reporting periods beginning after January 1, ·2021 are presented under Topic 606, while prior period amounts are not adjusted and continue to be reported in accordance with our historic accounting under Topic 605.

There was no impact to retained earnings as ofJan:uary l; 202l, or to revenue for the year ended December 31,.2023, after adopting Topic 606, as revenue recognition and timing oftevenue did riot change as a result ofimplemen:ting Topic 606. • • •• • • •

**Revenue recogniti0:n** -'- Revenues are recognized when control of the promised services is transferred to customers, in an amount that reflects the consideration the Company expects to be entitled to in exchange for those services. Revenues ateanaly:ted to determine whether the. Company is the principal (i.e. reportsrevenues on a gross basis) or agent (i.e; reports revenues on a net basis) in the contract. Prin-cipal or agent designations depend primarily on the control an entity has over the product Cir servke before control is transferred to a customer. The indicators of which· party exercises control include primaryresponsibility over perfonnance obligations, inventory risk before the good or service is transferred and discretion in establishing the price.

Based upon the income reported, the comm:issions earned from the sale of mutual funds and inves:tment company shares represent the major portion of the business and are recognized as earned. Securities trades are reported as of trade date.

**Leases** - in February 2016,theFASB issued ASU2016-02, "Leases" thatretjuires for leases longer than one year, a lessee to recognize in the statementoffinancial condition a right,ofuse asset, representing the right to use the underlying asset for the lease tenn; and a lease liability, representing the liability to make lease payments. The accouilting update also- requires that for finance leases, a lessee recognize interest expense Cin the lease liability, separately from the. amortization of the right~of-use asset in the statements of earnings, while for pperating leases, such amounts should be recognized as a combined expense. In addition, this accounting update requires expanded disclosures about the nature and· tenns of lease agreements. The accounting update is effective for fiscal years beginning after December 15, 2018 (January 1, 2021 for the Company) underamodified retrospective approach and early adoption is permitted. The Company has . reviewed the new standard and does not expect it to have a material impact to the statement of financial condition or its net capital. • • •• •

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# B.B. Graham & Company, Inc. Notes to Financial Statements December 31, 2025

#### Note 2 -Significant Accounting Policies (continued)

Income Taxes - Toe amount of current and deferred taxes payable or refundable is recognized as of the date of the financial statements, utilizing currently enacted tax 1aws and rates. Deferred tax expenses or benefits are recognized in the fmancial statements for the changes in deferred tax liabilities or assets between years.

The accounting principles generally accepted in the United States of America provide accounting and disclosure guidance about positions taken by an organiz.ation in its tax returns that might be uncertain. Management has considered its tax positions and believes that all of the positions taken by the Company in its Federal and State organization tax returns are more likely than not to be sustained upon examination. The Company is subject to examinations by U.S. Federal and State tax authorities from 2022 to the present, generally for three years after they are filed.

Depreciation - Depreciation is calculated on the accelerated method over estimated economic lives. Leasehold improvements are amortized over the lesser of the economic useful life of the improvement or the term of the lease. Property and equipment are carried at cost.

Statement of Changes in Financial Condition - Toe Company has defined cash equivalents as highly liquid investments, Vt'l.th original maturities ofless than three months that are not held for sale in the ordinary course of business.

#### Note 3 - Fair Value

Uilless otherwise indicated, the fair values of all reported assets and liabilities that represent financial instruments (none- of which are held for trading purposes) approximate the carrying values of such a.mounts.

#### Note 4 -Receivable From and Payable to Broker~Dealers and Clearing Organizations

Amounts receivable from and payable to broker-dealers and clearing organizations at December 31, 2025, consist of the following:

|                                         | Receivable | Payable |
|-----------------------------------------|------------|---------|
| Fees and commissions receivable/payable | \$446,792  | \$<br>0 |

#### **Note 5** - **Related Party**

The Company's sole shareholder purchased an office building and entered into a rent agreement to rent part of the building to the Company at \$270,000 annually. For the year 2025 the rent paid to the sole shareholder was \$270,000. In addition, the Company paid to the sole owner \$18,000 during the year for separate storage space. Also in 2025, the Company was reimbursed by the affiliate for its portion of the E & 0 insurance premiums, totaling \$15,081.

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# B.B. Graham & Company, Inc. Notes to Financial Statements December 31, 2025

### Note 6 - Concentration of Credit Risk

The Company is engaged in various trading and brokerage activities in which counter-paties primarily include broker-dealers, banks, and other financial institutions. In the event counterparties do not fulfill their obligations, the Company may be exposed to risk. The risk of default depends on the creditworthiness of the counter-party or issuer of the instrument. It is the Company's policy to review, as necessary, the credit standing of each counter-party.

## Note 7 - Commitments, contingencies or guarantees.

The Company has no commitments, no contingent, no guarantees that might result in a loss or future obligations. Contingencies could arise in the normal course of business, and the Company could be subject to lawsuits or arbitrations related to its activities The Company seeks to minimize any risks associated with its activities and the activities of any hcensed representatives through policies, procedures, and supervision. While the Company has exposure to risks in its normal course of business, there are no material unrecorded or undisclosed commitments or contingencies, and the Company is not involved in or aware of any pending litigation or arbitration as of December 31, 2025. Also, as of December 31 2025, here are no customer accounts having any debit balances which present any significant risks nor was management aware of any other significant or material exposure with any other transaction conducted with any other party ..

## Note 8 - Litigation

The firm currently has two separate arbitration matters pending.

Matter 1 (Harp): The primary claim is for expungement of the individual's FINRA record. Expungement is basically a non-monetary remedy and would not normally create a material dollar exposure to the Firm. In addition, the Firm has filed a counterclaim against Harp seeking reimbursement of amounts the Firm previously paid to seitle a prior GWG matter. Accordingly, this matter represents a potential recovery to the Firm rather than monetary exposure.

Matter 2 (Olson): This arbitration was initiated by the Firm to seek reimbursement from Olson for a GWG-related settlement the Firm previously paid on behalf of one of his chents. As with the Ham matter, the Firm is the party seeking recovery, and there is no expected monetary exposure to the Firm in the event of an unfavorable outcome.

Both arbitrations are currently in discovery with hearings scheduled at various umes in 2026. Management and counsel believe the Finn has strong positions and will continue to pursue recovery while defending the matters as appropriate.

## Note 9 - Net Capital Requirements

The Company is subject to the Securities and Exchange Commission Uniform Net Capital Rule (SEC rule 5c3-1) 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. Net capital and aggregate indebtedness change day by day, but on December 31, 2025, the Company had net capital of \$699,911 which was \$650,956 in excess of its required net capital requirement of \$48,955. The Company's aggregate indebtedness of \$734,323 to net capital was 1.05 to 1.

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# B.B. Graham & Company, Inc. Notes to Financial Statements December 31, 2025

#### Note 10 - Provision for Income Taxes

The Company files its Federal tax return on the cash basis. The provision for income taxes for the year consists of the following:

| Federal | \$ 27,000 |
|---------|-----------|
| State   | \$ 13.800 |
|         | \$ 40.800 |

#### Note 11 - Deposit - Clearing Organization

The Company has an agreement with a clearing broker which requires a minimum deposit of \$50,000. The clearing broker deposit at December 31, 2025 was \$50,000.

#### Note 12 - Exemption from the SEC Rule 15c3-3

The Company is a "non-covered" firm pursuant to Footnote 74 to SEC Release 34-70073 and is therefore not subject to SEA Rule 15c3-3 for the most recent fiscal year ended December 31, 2025. The Company represents that it has not held customer funds or securities, did not carry accounts of or for customers and did not carry broker-dealer proprietary accounts as defined in Exchange Act rule 15c3-3

#### Note 13 - Leases

The Company rents office space and storage space from a related party on a month to month basis. For 2025, rent expense was \$270,000, all of which was paid to a related party (see Note 5).

#### Note 14 - Single Reportable Segment

The Company is engaged in a single line of business as a securities broker-dealer, which is comprised of several classes of services as listed in Note 2 above. The Company has identified its CEO/FINOP as the chief operating decision maker ("CODM"), who uses net income to evaluate the results of the business, predominantly in the forecasting process, to manage the Company. Additionally, the CODM uses excess net capital, which is not a measure of profit and loss, to make operational decisions while maintaining capital adequacy, such as whether to reinvest profits or pay dividends. The Company's operations constitute a single operating segment and therefore, a single reportable segment, because the CODM manages the business activities using information of the Company as a whole. 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. The Company derived 9.5% of its total revenues from a single external customer in 2025.

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## **B.B. Graham** & **Company, Inc. Notes** to **Financial Statements December 31, 2025**

## **Note 15** - **Subsequent Events**

Management has reviewed the results· of operations for the period of titne from its year end December 31; 2025 through February 25, 2026; the date the financial statements were available to be issued and has determined thatno adjustments are necessary tothe amountsreportedinthe accompanying financial statements nor have any subsequentevents occurred, the nature of which would require disclosure. See also Note 8,Litigation. ••

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## B.B. Graham & Company, Inc. Schedule II - Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3 As of Decemher 31, 2025

A computation of reserve requirement is not applicable to BB Graham & Company, Inc. as the Company qualifies for exemption under Rule 15c3-3 (k) (2) (ii) and the Company has no reserve deposit obligations under SEC 15c3-3(e) because it is a "non-covered" firm pursuant to foothote 74 to SEC Release 34-70073 and therefore is not subject to the Rule.

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# **B.B. Graham** & **Company,Inc. Schedule JlI** - **Information** Relating' to Possessionor **Control Requirements under Rule l5c3-3**  • **As ofDecember 31f 2025.**

lrtfortnation relating to possession or control requirements is not applicable to RB. Graham & Company, Inc. as the Company qualifi.cs fofexemption under Rule 15c3-'3 (k) (2) {ii) and the Company has no possession.pr- control obligations under SEC 15c3-3(b) beci3.use it is a."honcovered'' firm pursuant to footnote 74 to SEC Release 34-7007) and therefore is not subject to the Rule

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