# MCM SECURITIES LLC X-17A-5 (2026-02-25) — Broker-dealer annual report - Company: MCM SECURITIES LLC - Form: X-17A-5 - Filed: 2026-02-25 - Period: 2025-12-31 - Accession: 0001019951-26-000001 - CIK: 1019951 - File #: 8-49496 - Type: Broker-dealer - Material weakness: No - Auditor: FROST, PLLC - Auditor location: Little Rock, AR - Contact: Nancy Robinson - Phone: 518-687-7300 - Email: jpeterson@mcmsecurities.com - Website: mcmsecurities.com - Signed by: John A. Peterson (Cheif Executive Officer) Original filing: https://www.sec.gov/Archives/edgar/data/1019951/000101995126000001/test.pdf --- {0}------------------------------------------------ ## December 31, 2025 Financial Statements And Supplementary Information **With** Report of Independent Registered Public Accounting Firm {1}------------------------------------------------ | | 0MB APPROVAL | | | | |------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------|-----------|-------------------------------------------------|--| | UNITED STATES
SECURITIES AND EXCHANGE COMMISSION | | | 0MB Number: 3235-0123
Expires: Nov. 30, 2026 | | | | Washington, D.C. 20S49 | | Estimated average burden | | | | | | hours per response: 12 | | | | ANNUAL REPORTS | | SEC Fl LE NUMBER | | | | FORM X-17A-S | | 8-49496 | | | | PART Ill | | | | | | | | | | | | FACING PAGE
Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934 | | | | | | | | AND ENDING 12/31/2025 | | | FILING FOR THE PERIOD BEGINNING O 1/01/2025 | MM/0D/YY | | MM/DD/VY | | | | | | | | | | A. REGISTRANT IDENTIFICATION | | | | | NAME oF FIRM: MCM Securities LLC | | | | | | | | | | | | TYPE OF REGISTRANT (check all applicable boxes):
l:!:l Broker-dealer | □ Security-based swap dealer | | □ Major security-based swap participant | | | 0 Check here if respondent is also an OTC derivatives dealer | | | | | | | | | | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) | | | | | | 300 Jordan Road | | | | | | | {No. and Street) | | | | | TROY | NY | | 12180 | | | (City) | (State) | | (Zip Code) | | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | | | John A. Peterson | (518) 687-7300 | | jpeterson@mcmsecurities.com | | | {Name) | {Area Code -Telephone Number) | | (Email Address) | | | | B. ACCOUNTANT IDENTIFICATION | | | | | | | | | | | INDEPENDENT PUBLICACCOUNTANTwhose reports are contained in this filing* | | | | | | Frost, PLLC | | | | | | | (Name - if individual, state last, first, and middle name) | | | | | 425 Capitol Avenue - | Suite 3300 Little Rock | | AR
72201 | | | (Address) | (City) | (State) | (Zip Code) | | | 12/21/2010 | | 5348 | | | | | | {PCAOB , | I
. N,mbo,, ;1 •PPU"bl•I | | | | FOR OFFICIAL USE ONLY | | | | | | | | | | | • Claims for exemption from the requirement that the annual reports be covered by the reports of an independent public | | | | | accountant must be supported by a statement offacts and circumstances relied on as the basis of the exemption. See 17 CFR 240.17a-S(e)(l)(ii), if applicable. **Persons who are to respond to the collection of information contained in this form are not required to respond unless the form displays a currendy valid 0MB control number.** {2}------------------------------------------------ #### **OATH OR AFFIRMATION** | I, John A. Peterson | | | swear (or affirm} that, to the best of my knowledge and belief, the | | | |---------------------|--|--------------------------------------------|---------------------------------------------------------------------|--------------------|-----------------------------------------------------------------------------------| | | | financial report pertaining to the firm of | | MCM Securilies LLC | as of | | 12/31 | | | | 2~ | is true and correct. I further swear (or affirm) that neither the company nor any | partner, officer, director, or equivalent person, as the case may be, has any proprietary interest in any account classified solely as that of a customer. /4 =:2t1. '6\_,~ Notary Public #### **This filing•• contains (check all applicable boxes):** No. 01 SC6158003 - - Ii (b) Notes to consolidated statement of financial condition. Commission Expires December 18, 20\_ - **ii** (c) Statement of income (loss) or, if there is other comprehensive income in the period(sl presented, a statement of comprehensive income (as defined in§ 210.1-02 of Regulation S-X). - **ii** (d) Statement of cash flows. - **ii** (el Statement of changes in stockholders' or partners' or sole proprietor's equity. - □ (f} Statement of changes in liabilities subordinated to claims of creditors. - Ii (gl Notes to consolidated financial statements. - **ii** (hl 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. - □ (kl Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 24-0.1Sc3-3 or Exhibit **A** to 17 CFR 240.lSa-4, as applicable. - D (I) Computation for Determination of PAB Requirements under Exhibit A to§ 240.15c3-3. - □ (ml Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3. - D (nl Information relating to possession or control requirements for security-based swap customers under 17 CFR 240.1Sc3-3(p)(2l 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-1, or 17 CFR 240.18a-2, as applicable, and the reserve requirements under 17 CFR 240.15c3-3 or 17 CFR 240.18a-4, as applicable, if material differences exist, or a statement that no material differences exist. - □ (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition. - Ii (q) Oath or affirmation in accordance with 17 CFR 240.17a-5, 17 CFR 240.17a-12, or 17 CFR 24-0.18a-7, as applicable. - □ (r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - **ii!!** (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - **ii** (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 report or financial statements under 17 CFR 240.17a-5, 17 CFR 240.lBa-7, or 17 CFR 240.17a-12, as applicable. - □ (vl 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.lSa-7, as applicable. - **ii** (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. - D (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-1e or 17 CFR 240.17a-12, as applicable. - D (yl Report describing any material inadequacies found to exist or found to have existed since the date of the previous audit, or a statement that no material inadequacies exist, under 17 CFR 240.17a-12(kl. □ (z) Other: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ \_ - - \*\*To request confidential treatment of certain portions of this filing, see 17 CFR 240.17a-5{e){3} or 17 CFR 240.18a-7(d)(2), as applicable. """'" Title: Cf-- *a* ~ Chief Executive Officer KAREN A. SCHLEDERER Notary Public, State of New York **ii** (a) Statement of financial condition. Qualified in Rensselaer County *f}.J,o* {3}------------------------------------------------ # **Table of Contents** | Financial Statements | |-----------------------------------------------------------------------------------------------------------| | Report oflndependent Registered Public Accounting Firm 1-2 | | Statement of Financial Condition 3 | | Statement of Operations 4 | | Statement of Changes in Member's Equity 5 | | Statement of Cash Flows 6 | | Notes to Financial Statements 7-10 | | Supplementary Information | | Computation of Net Capital Requirement Under Rule 15c3-l of the
Securities and Exchange Commission 11 | | Report of Independent Registered Public Accounting Firm 12 | | Exemption Report 13 | {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) # **Report of Independent Registered Public Accounting Firm** The Member MCM Securities LLC Troy, New York # **Opinion on the Financial Statements** We have audited the accompanying statement of financial condition of MCM Securities LLC as of December 31, 2025, and the related statements of operations, 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 MCM Securities LLC at December 31 , 2025, and the results of its operations and its cash flows for the year then ended in conformity with accounting principles generally accepted in the United States of America. # **Basis for Opinion** These financial statements are the responsibility of MCM Securities LLC's management. Our responsibility is to express an opinion on MCM Securities LLC'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 MCM Securities LLC 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 witq 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 our audit provides a reasonable basis for our opinion. {5}------------------------------------------------ ## **Supplemental Information** The supplemental information on page I I has been subjected to audit procedures performed in conjunction with the audit of MCM Securities LLC's financial statements. The supplemental information is the responsibility of MCM Securities LLC'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 Securities Exchange Act of I 934 Rule I 7a-5. In our opinion, the supplemental information is fairly stated, in all material respects, in relation to the financial statements as a whole. Independent Registered Public Accounting Firm We have served as MCM Securities LLC's auditor since 2012. Little Rock, Arkansas February 24, 2026 {6}------------------------------------------------ #### Statement of Financial Condition #### As of December 31, 2025 | Cash
Deposit on account
Prepaid expenses | \$
61,654
2,850
8,117 | |--------------------------------------------------------------------------|--------------------------------| | Total assets | \$
72,621 | | Liabilities and Member's Equity | | | Liabilities
Accounts payable
Accrued expenses
Total liabilities | \$
141
18,280
18,421 | | Member's equity | 54,200 | | Total liabilities and member's equity | \$
72,621 | {7}------------------------------------------------ ## Statement of Operations #### For The Year Ended December 31, 2025 | Revenues | | |------------------------------------------------|---------------| | Commission income | \$
188,000 | | Net revenues | 188,000 | | Operating expenses | | | Salary and benefits | 44,868 | | Professional fees | 95,368 | | Office supplies and expenses | 1,406 | | Regulatory fees and expenses | 6,506 | | IT Communications | 1,833 | | Broker/dealer expense | 4,037 | | Broker commissions/Sales rebates and discounts | 24,372 | | Occupancy expense | 15,409 | | Insurance | 891 | | Miscellaneous taxes, licenses and permits | 920 | | Total operating expenses | 195,610 | | Net loss | \$
(7,610) | {8}------------------------------------------------ #### Statement of Changes in Member's Equity #### For The Year Ended December 31, 2025 | Balance -
January I, 2025 | \$
48,810 | |--------------------------------|--------------| | Contributions from member | 68,000 | | Distributions to member | (55,000) | | Net loss | (7,610) | | | | | Balance -
December 31, 2025 | \$
54,200 | {9}------------------------------------------------ ## Statement of Cash Flows #### For The Year Ended December 31, 2025 | Cash flows from operating activities | | |-----------------------------------------------|---------------| | Net loss | \$
(7,610) | | Adjustments to reconcile net loss to net cash | | | used by operating activities | | | Prepaid expenses | (1,217) | | Accounts payable and accrued expenses | (7,093) | | Net cash used by operating activities | (15,920) | | Cash flows from financing activities | | | Contributions from member | 68,000 | | Distributions to member | (55,000) | | Net cash provided by financing activities | 13,000 | | Net decrease in cash | (2,920) | | beginning of year
Cash - | 64,574 | | end of year
Cash - | \$
61,654 | {10}------------------------------------------------ #### **Notes to Financial Statements** ## **As of December 31, 2025** ## **l. Nature of Operations** MCM Securities LLC (the "Company") was organized in September 1996 as a Delaware Limited Liability Corporation, is a broker/dealer registered with the Securities and Exchange Commission ("SEC") and is a member of the Financial Industry Regulatory Authority. The Company's sole member is Millennium Credit Markets, LLC (the "Parent"). The Company shall continue in existence through December 2050, or until terminated by the member. The Parent will make capital contributions as needed to enable the Company to meet its obligations and its regulatory capital requirements. ## 2. **Summary of Significant Accounting Policies** a. **Business activities** - The Company's business activities during 2025 consisted of the following: selling private placements of securities, real estate syndicator or providing financial advice to issuers of private placements. **b. Income taxes-** The Company is included in the federal income tax returns filed by its sole member, the Parent. The Company is not a tax paying entity and distributes its pro rata share of income, losses and tax credits to the Parent as provided in the operating agreement. The Company's policy with respect to evaluating uncertain tax positions is based upon whether management believes it is more likely than not the uncertain tax positions will be sustained upon review by the taxing authorities, then the Company shall initially and subsequently measure the largest amount of tax benefit that is greater than 50% likely of being realized upon settlement with a taxing authority that has full knowledge of all relevant information. The tax positions must meet the more-likely-thannot recognition threshold with consideration given to the amounts and probabilities of the outcomes that could be realized upon settlement using the facts, circumstances and information at the reporting date. The Company will reflect only the portion of the tax benefit that will be sustained upon resolution of the position and applicable interest on the portion of the tax benefit not recognized. Based upon management's assessment, there are no uncertain tax positions expected to have a material impact on the Company's financial statements. The income tax position taken by the Company for any years open under the various statutes of limitations is that it continues to be exempt from income taxes by virtue of its pass-through entity status. Management believes this tax position meets the more-likely-than-not threshold and, accordingly, the tax benefit of this income tax position (no income tax expense or liability) has been recognized for the years ended on or before December 31, 2025. The Parent is no longer subject to U.S. federal and state examinations by tax authorities for years before 2022. The Parent's federal and state tax returns are not currently under examination. The Parent recognizes interest and penalties related to unrecognized tax benefits in income tax expense. During the year ended December 31, 2025, the Parent did not recognize any interest or penalties. The Parent did not have any interest or penalties accrued at December 31, 2025. {11}------------------------------------------------ #### **Notes to Financial Statements** #### **As of December 31, 2025** #### 2. **Summary of Significant Accounting Policies (cont.)** c. **Use of estimates** - The preparation of financial statements in accordance 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, liabilities, revenues and expenses, and disclosures about contingent assets and liabilities. The estimates and assumptions used in the accompanying financial statements are based upon management's evaluation of the relevant facts and circumstances as of the date of the financial statements. However, actual results may differ from the estimates and assumptions used in the accompanying financial statements. d. **Revenue recognition** - The Company accounts for revenue under the provisions of ASC Topic 606. The guidance requires the Company to recognize revenue to depict the transfer of goods or services to a customer at an amount that reflects the consideration it expects to receive in exchange for those goods or services. In addition, the standard requires disclosure of the nature, amount, timing and uncertainty of revenue and cash flows arising from customer contracts. In general, the Company applies the following steps when recognizing revenue from contracts with customers: (i) identify the contract, (ii) identify the performance obligations, (iii) determine the transaction price, (iv) allocate the transaction price to the performance obligations and (v) recognize revenue when a performance obligation is satisfied. Management has determined that in years where comm1ss1on revenue is settled, it will be recognized at a point in time when the related transaction is completed, as the performance obligation is to successfully broker all or a portion of a specific transaction. #### 3. **Related Party Transactions** In accordance with an expense support agreement, as amended April 2015 and May 2022, the Parent allocates certain expenses to the Company, including but not limited to salaries and general operating expenses. Such expenses include all costs that the Company derived direct or indirect benefit for which the Company would be responsible if another entity had not agreed to pay these expenses. The Parent incurs certain costs related to both the Parent and the Company. Shared expenses, such as salary, office supplies, rent and other expenses are recorded as incurred in amounts determined according to a reasonable allocation, applied on a consistent basis. The allocation is derived as an attempt to equate the proportional cost of a service or product to the proportional use of or benefit derived from the service or product. All expenses, with the exception of certain professional fees, broker filing fees, broker commission fees, licenses and permits, are based on allocations from the Parent (this amounted to \$61,277 during 2025). In the event the Company incurred expenses on behalf of the Parent, those expenses would be reimbursed by the Parent. Substantially all current, prior and futures revenues earned by the Company are derived from transactions controlled by a related party. The related party, indirectly through a series of limited liability companies, owns a majority of the Parent. {12}------------------------------------------------ ## **Notes to Financial Statements** # **As of December 31, 2025** ### 4. **Net Capital Requirements** The Company is subject to the SEC Uniform Net Capital Rule ("SEC Rule 15c3-l "), which requires the maintenance of minimum net capital at the greater of 6 2/3% of aggregate indebtedness or \$5,000. SEC Rule 15c3-1 also restricts the payments of dividends in certain cases. At December 31, 2025, the Company had net capital, as defined, of \$43,233, which was \$38,233 in excess ofits minimum required net capital of \$5,000. The Company's ratio of aggregate indebtedness to net capital was .43 to 1.00 at December 31, 2025. ## 5. **Concentrations of Credit Risk** The Company maintains it cash balance at one financial institution, which is insured by the Federal Deposit Insurance Corporation ("FDIC") up to \$250,000. At various times throughout the year, such balance may exceed insured amounts. The exposure to the Company is solely dependent upon daily bank balances and the strength of the financial institution. The Company has not incurred any losses on this account. #### 6. **Segment Reporting** The Company has a single reportable segment: private placements of securities. The private placements of securities segment provides equity to sponsors of real estate investment projects. The private placements of securities segment derives revenues from commissions. The accounting policies of the private placements of securities segment are the same as those described in the summary of significant accounting policies. The Company's chief operating decision maker ("CODM") is the Chief Executive Officer. The CODM assess performance for the private placement of securities segment and decides how to allocate resources based on net loss that also is reported on the statement of operations as net loss. The measure of segment assets is reported on the statement of financial condition as total assets. The CODM uses net loss to evaluate income generated from segment assets (return on assets) in deciding the reinvest profits into the private placements of securities segment or into other parts of the Company, such as to pay distributions. The Company does not have intra-entity sales or transfers. Additionally, the CODM uses excess net capital (see Note 4), 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 distributions. The Company's operations constitute a single operating segment and; therefore, a single reporting segment, because the CODM manages the business activities using information of the Company as a whole. The Company operates in a single reportable segment; therefore, all financial information, including revenues, expenses, and assets, is included in the accompanying financial statements. {13}------------------------------------------------ #### **Notes to Financial Statements** # **As of December 31, 2025** ### 7. **Contingencies** From time to time, the Company is party to certain claims and legal actions arising in the ordinary course of business. In some cases, plaintiffs are seeking compensatory and punitive damages. It is the opinion of management that the ultimate disposition of these matters will not have a material adverse effect on the Company's financial condition or results of operations. The Company accrues certain claims and legal actions when it is probable and reasonably estimable. #### 8. **Subsequent Events** The Company evaluated all other events and transactions subsequent to its December 31, 2025 statement of financial condition date and determined there were no significant events to report through February 24, 2026, which is the date the Company issued its financial statements. {14}------------------------------------------------ # Computation of Net Capital Requirement Under Rule 15c3-1 of the Securities and Exchange Commission # As of December 31, 2025 | Aggregate indebtedness | \$
18,421 | |----------------------------------------------------------------------------------------------------------------------|--------------| | Minimum required net capital | \$
5,000 | | Net capital | | | Member's equity | \$
54,200 | | Deductions: | | | Prepaid expenses and deposit on account | 10,967 | | Net capital | \$
43,233 | | Minimum required net capital required to be maintained (the greater
of 1/15 of aggregate indebtedness or \$5,000) | 5,000 | | Net capital in excess of requirement | \$
38,233 | | Ratio: aggregate indebtedness to net capital | .43 to 1.00 | | There are no material differences between this computation and the | | | computation included in the unaudited FOCUS Part II as of December 31, 2025. | | \* Prepaid expenses and deposit on account are identified on the Company's computation of net capital as nonallowable assets on Part II of the unaudited FOCUS report. See report of independent registered public accounting firm. {15}------------------------------------------------ ![](_page_15_Picture_0.jpeg) # **Report oflndependent Registered Public Accounting Firm** The Member MCM Securities LLC Troy, New York We have reviewed management's statements, included in the accompanying Exemption Report, in which MCM Securities LLC stated that MCM Securities LLC (I) does not claim an exemption under paragraph (k) of Securities Exchange Act of 1934 ("SEA") Rule l 5c3-3 (the "exemption provisions") and (2) is filing the Exemption Report relying on Footnote 74 of the Securities and Exchange Commission Release No. 34-70073 adopting amendments to SEA Rule 17a-5 ("Footnote 74") because MCM Securities LLC limits its business activities exclusively to selling private placements of securities and mergers and acquisitions advisory services, and MCM Securities LLC (a) 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 SEA Rule l 5c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to MCM Securities LLC); (b) did not carry accounts of or for customers; and (c) did not carry PAB accounts (as defined in SEA Rule 15c3-3) throughout the most recent fiscal year without exception. MCM Securities LLC's management is responsible for compliance with the exemption provisions 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 MCM Securities LLC's compliance with the statements within the Exemption Report. 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 Footnote 74. Independent Registered Public Accounting Firm Little Rock, Arkansas February 24, 2026 > Little Rock, Arkansas I Fayetteville, Arkansas I Raleigh, North Carolina Scottsdale, Arizona I Yuma, Arizona I Naples, Florida I **www.frostpllc.com** {16}------------------------------------------------ # **Exemption Report** MCM Securities LLC (the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C.F.R. §240.17a-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)(l) and (4). To the best of its knowledge and belief, the Company states the following: - (1) The Company does not claim an exemption under paragraph (k) of 17 CFR 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 CFR 240. l 7a-5 because the Company limits is business activities exclusively to selling private placements of securities and mergers and acquisitions advisory services, and the Company (a) 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 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company); (b) did not carry accounts of or for customers; and (c) did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception. I, John A. Peterson, swear ( or affirm) that, to my best knowledge and belief, this Exemption Report is true and correct. Title: Senior Managing Director February 24, 2026 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.