# POLAR INVESTMENT COUNSEL, INC. X-17A-5 (2026-07-07) — Broker-dealer annual report

- Company: POLAR INVESTMENT COUNSEL, INC.
- Form: X-17A-5
- Filed: 2026-07-07
- Period: 2025-06-30
- Accession: 0001035342-26-000006
- CIK: 1035342
- File #: 8-50039
- Type: Broker-dealer
- Material weakness: No
- Auditor: Ohab and Company
- Auditor location: Maitland, FL
- Contact: Sherry Abbott
- Phone: 218-681-7344
- Email: pam@ohabco.com
- Website: ohabco.com
- Signed by: Michael Jordan (President-CEO)

Original filing: https://www.sec.gov/Archives/edgar/data/1035342/000103534226000006/polaric2025audit.pdf

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

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Expires: Nov. 30, 2026

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

FACING PAGE

| FILING FOR THE PERIOD BEGINNING                                                                                                                                                                         | MM/DD/YY                                                   | AND ENDING |         |                 | MM/DD/YY                                   |
|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------|------------|---------|-----------------|--------------------------------------------|
| A. REGISTRANT IDENTIFICATION                                                                                                                                                                            |                                                            |            |         |                 |                                            |
| NAME OF FIRM:                                                                                                                                                                                           |                                                            |            |         |                 |                                            |
| TYPE OF REGISTRANT (check all applicable boxes):<br>Broker-dealer<br>O Security-based swap dealer   Major security-based swap participant<br>Check here if respondent is also an OTC derivatives dealer |                                                            |            |         |                 |                                            |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.)                                                                                                                                     |                                                            |            |         |                 |                                            |
|                                                                                                                                                                                                         | (No. and Street)                                           |            |         |                 |                                            |
| (City)                                                                                                                                                                                                  | (State)                                                    |            | 561     |                 | (Zip Code)                                 |
| PERSON TO CONTACT WITH REGARD TO THIS FILING                                                                                                                                                            |                                                            |            |         |                 |                                            |
| (Name)                                                                                                                                                                                                  | (Area Code - Telephone Number)                             |            |         | (Email Address) | CHARDON ( O Ini V So                       |
|                                                                                                                                                                                                         | B. ACCOUNTANT IDENTIFICATION                               |            |         |                 |                                            |
| INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*                                                                                                                               |                                                            |            |         |                 |                                            |
|                                                                                                                                                                                                         | (Name - if individual, state last, first, and middle name) |            |         |                 |                                            |
| (Address)                                                                                                                                                                                               | (City)                                                     |            | (State) |                 | (Zip Code)                                 |
| (Date of Registration with PCAOB)(if applicable)                                                                                                                                                        | FOR OFFICIAL USE ONLY                                      |            |         |                 | (PCAOB Registration Number, if applicable) |
|                                                                                                                                                                                                         |                                                            |            |         |                 |                                            |

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 valld OMB control number.

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#### OATH OR AFFIRMATION

|                                              | swear (or affirm) that, to the best of my knowledge and belief, the                                                                 |
|----------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------|
| financial report pertaining to the firm of . | Your Invostmont (Dunnel)<br>as of                                                                                                   |
|                                              | J , 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: Prostbent- CRD |  |

#### 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 in the period(s) presented, a statement of comprehensive income (as defined in § 210.1-02 of Regulation S-X).
- O (d) Statement of cash flows.

no do

- (e) Statement of changes in stockholders' or partners' or sole proprietor's equity.
- (f) Statement of changes in liabilities subordinated to claims of creditors.
- O (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.
- O (i) Computation of tangible net worth under 17 CFR 240.18a-2.
- 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 8 to 1 CFR 240.15c3-3 or Exhibit A to 17 CFR 240.18a-4, as applicable.
- [1) Computation for Determination of PAB Requirements under Exhibit A to § 240.15c3-3.
- I (m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3.
- [ (n) Information relating to possession or control requirements for security-based swap customers under 17 CFR 240.15c3-3(p)(2) or 17 CFR 240.18a-4, as applicable.
- (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capital or tangible net ম্ worth under 17 CFR 240.18-1, 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. .
- (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 240.17a-5 or 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 240.17a-12, as applicable.
- (y) Report describing any material inadequacies found to have existed since the date of the previous audit, or ਕ a statement that no material inadequacies exist, under 17 CFR 240.17a-12(k).
- O (z) Other:
- \*\* To request confidential treatment of chis filing, see 17 CFR 240.170-5(e)(3) or 17 CFR 240.18c-7(d)(2), as applicable.

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FINANCIAL STATEMENTS AND SUPPLEMENTARY INFORMATION

JUNE 30, 2025

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### CONTENTS

|                                                                                                                  | Page  |
|------------------------------------------------------------------------------------------------------------------|-------|
| REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM                                                          |       |
| FINANCIAL STATEMENTS                                                                                             |       |
| Statement of Financial Condition                                                                                 | 1     |
| Statement of Operations                                                                                          | 2     |
| Statement of Changes in Stockholder's Equity                                                                     | 3     |
| Statement of Cash Flows                                                                                          | 4     |
| NOTES TO FINANCIAL STATEMENTS                                                                                    | 5-8   |
| SUPPLEMENTARY INFORMATION                                                                                        |       |
| Schedule I, Computation of Net Capital Under Rule 15c3-1                                                         | 9     |
| Schedule II, Computation for Determination of Reserve Requirements<br>Under Rule 15c3-3 (exemption)              | 10    |
| Schedule III, Information for Possession or Control Requirements Under<br>Rule 15c3-3 (exemption)                | 11    |
| Schedule IV, Reconciliation of FOCUS Report (iiA) as of June 30, 2025<br>To Supplemental Schedule of Net Capital | 12    |
| REVIEW REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM                                                   | 13-16 |

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![](_page_5_Picture_0.jpeg)

100 E. Sybelia Ave. Suite 130 Maitland, FL 32751

Certified Public Accountants Email: pam@ohabco.com

Telephone 407-740-7311 Fax 407-740-6441

#### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Stockholder of Polar Investment Counsel, Inc.

#### Opinion on the Financial Statement

We have audited the accompanying statement of financial condition of Polar Investment Counsel, Inc. as of June 30, 2025 and the related notes (collectively referred to as the "financial statement"). In our opinion, the financial statement presents fairly, in all material respects, the financial position of Polar Investment Counsel, Inc. as of June 30, 2025 in conformity with accounting principles generally accepted in the United States of America.

#### Basis for Opinion

This financial statement is the responsibility of Polar Investment Counsel, Inc.'s management. Our responsibility is to express an opinion on Polar Investment Counsel, Inc.'s financial statement 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 Polar Investment Counsel, Inc. in accordance with the U.S. federal securities laws and the applicable rules and requlations of the Securities and Exchange Commission and the PCAOB.

We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statement is free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statement, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audit also included evaluating 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.

ORDA and Corpory. It

We have served as Polar Investment Counsel, Inc.'s auditor since 2025.

Maitland, Florida September 26, 2025

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### STATEMENT OF FINANCIAL CONDITION JUNE 30, 2025

#### ASSETS

| Cash and Cash Equivalents<br>Clearing Deposit<br>Accounts Receivables<br>Due from Clearing Broker                                              | ക്ക<br>5,218<br>ക്ക<br>100,130<br>\$<br>600<br>14,846 |
|------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------|
| TOTAL ASSETS                                                                                                                                   | 120,794                                               |
| LIABILITIES AND STOCKHOLDER'S EQUITY                                                                                                           |                                                       |
| LIABILITIES<br>Due to Glacier Group Inc. (related third party)<br>Commissions Payable                                                          | ತಿ<br>16,000<br>ಳಿ<br>4,470                           |
| Total Liabilities                                                                                                                              | S<br>20,470                                           |
| STOCKHOLDER'S EQUITY<br>Common Stock, No Par Value, 9,000 Shares Authorized,<br>100 Shares Issued and Oustanding<br>Additional Paid in Capital | ಕಿ<br>25,000<br>ക<br>67,384                           |
| Retained Earnings                                                                                                                              | ತಿ<br>7,940                                           |
| Total Stockholder's Equity                                                                                                                     | S<br>100,324                                          |
| TOTAL LIARILITIES AND STOCKHOLDER'S FOUITY                                                                                                     | S<br>120 794                                          |

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## STATEMENT OF OPERATIONS FOR THE YEAR ENDED JUNE 30, 2025

| REVENUE                       |               |
|-------------------------------|---------------|
| Clearing Commissions          | S<br>324,410  |
| Clearing Mutal Fund           | 19,245        |
| Clearing Mutal Fund 12B1      | 57,000        |
| Mutual Fund                   | 5,705         |
| Mutual Fund 12B1              | 30,354        |
| Alternative Commission Trails | 11,382        |
| Annuity Trails                | 1,453         |
| Other Limited Partnerships    | 23,903        |
| Interest Rebate               | 19,402        |
| Other                         | 11,193        |
| Total Revenue                 | 504,046       |
| EXPENSES                      |               |
| Commissions                   | 213,595       |
| Management Fee                | 228,200       |
| Clearing Charges              | 62,199        |
| Other Expenses                | 1,335         |
| Total Expenses                | 505,329       |
| NET INCOME                    | ಕಿ<br>(1,283) |

### See notes to financial statements

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### STATEMENT OF CHANGES IN STOCKHOLDER'S EQUITY FOR THE YEAR ENDED JUNE 30, 2025

|                             | Common<br>Stock |        | Additional<br>Paid in<br>Capital |        | Retained<br>Earnings |         | Total<br>Stockholder's<br>Equity |         |
|-----------------------------|-----------------|--------|----------------------------------|--------|----------------------|---------|----------------------------------|---------|
| Balance - Beginning of Year | မာ              | 25,000 | ಳಿ                               | 67,384 | မာ                   | 9,223   | မှာ                              | 101,607 |
| Net Income                  |                 |        |                                  |        |                      | (1,283) | ಕಿ                               | (1,283) |
| Balance - End of Year       | ଞ୍ଚଳ            | 25,000 | റ                                | 67.384 | ട്                   | 7,940   | မခ                               | 100.324 |

See notes to financial statements

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### STATEMENT OF CASH FLOWS FOR THE YEAR ENDED JUNE 30, 2025

| Cash Flows from Operating Activities:         |   |          |
|-----------------------------------------------|---|----------|
| Net Income                                    | છ | (1,283)  |
| Adjustments to Reconcile Net Loss to Net Cash |   |          |
| Provided by Operating Activities:             |   |          |
| (Increase) Decrease in Assets:                |   |          |
| Receivables from Broker/Dealers               |   | 16,976   |
| Increase (Decrease) in Liabilities:           |   |          |
| Payable to Parent                             |   | 500      |
| Commisions Payable                            |   | (18,440) |
| Net Cash Provided by Operating Activities     |   | (2,247)  |
| Net Increase in Cash and Cash Equivalents     |   | (2,247)  |
| Cash and Cash Equivalents, Beginning of Year  |   | 7,465    |
| Cash and Cash Equivalents, End of Year        |   | 5.218    |
|                                               |   |          |
| Supplemental Disclosure:                      |   |          |

| Cash paid for interest | \$0   |
|------------------------|-------|
| Cash paid for taxes    | \$0 . |
|                        | SO    |

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### NOTES TO FINANCIAL STATEMENTS FOR THE YEAR ENDED JUNE 30, 2025

#### NOTE 1 - SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

- A. Summary of Significant Accounting Policies The Company was incorporated in the state of Wisconsin in May 1995. The Company is a wholly-owned subsidiary of Glacier Groups, Inc. The Company is registered with the Securities and Exchange Commission and the Commodities Futures Trading Commission and is a member of the Financial Industry Regulatory Authority (FINRA), the National Futures Association, and the Securities Investor Protection (SIPC). The Company's principal business activity is the sale of securities. Operations began in July 1997. In January 2011, the Parent Company reincorporated in the state of Wyoming.
- B. Cash and Cash Equivalents The Company considers all highly liquid investments with original maturities of three months or less to be cash equivalents.
- C. Due from Clearing Broker and Accounts Receivables Accounts receivables are stated at the amount management expects to collect from outstanding balances. An allowance for doubtful accounts has not been established as of June 30, 2025. Based upon management's analysis of outstanding accounts receivable as of June 30, 2025 and the Company's past collection experience, an allowance is not considered necessary by management.
- D. Concentrations of Risk The Company maintains its cash in accounts with federally insured banks. At times, the balances in these accounts may be in excess of the federally insured limit of \$250,000. The Company believes that there is no significant risk with respect to these deposits.

The Company is engaged in various brokerage activities in which counterparties primarily include brokerdealers, banks, and other financial institutions. In the event counterparties do not fulfill their obligations, the Company may be exposed to risk. The Company's management feels the risk at this time is minimal and they review the credit standing of their counterparties on a regular basis.

- E. Use of Estimates The preparation of financial statements in conformity with accounting principles generally accepted in the United States of America requires management to make estimates and assumptions that affect the 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 revenues and expenses during the reporting period. Actual results could differ from those estimates.
- F. Income Taxes Deferred tax assets and liabilities are recognized for future tax consequences attributable to differences between the financial statement carrying amounts of existing assets and liabilities and their respective tax bases. Deferred tax assets, including tax loss and credit carryforwards, and liabilities are measured using enacted tax rates expected to apply to taxable income in the years which those temporary differences are expected to be recovered or settled. The effect of a change in tax rates on deferred tax assets and liabilities is recognized in the period that includes the enactment date. Deferred income tax expense represents the change during the period in the deferred tax assets and deferred tax liabilities. Deferred tax assets are reduced by a valuation allowance when, in the opinion of management, it is more likely than not that some portion or all of the deferred tax assets will not be realized. There are no deferred tax assets or liabilities recorded at June 30, 2025 for Polar Investment Counsel, Inc.

The Company files a consolidated federal income tax return with its Parent Company Glacier Groups, Inc. Management is of the view that there are no significant tax positions that may be challenged. Tax years ending June 30, 2021 through June 30, 2025 are open for examination by the IRS.

G. Subsequent Events - Management has evaluated subsequent events through the date which the financial statements were available to be issued, and has determined that there are no additional items that require disclosure or recognition.

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#### NOTES TO FINANCIAL STATEMENTS FOR THE YEAR ENDED JUNE 30, 2025

H. Recognition of Revenue - The Company records revenue under the provisions of ASC 606, Revenue from Contracts with Customers. Under this standard, recognition of revenue occurs when a customer obtains control of promised services or goods in an amount that reflects the consideration to which the entity 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 contacts.

#### Commissions:

This is applicable to clearing firm commissions and direct held commissions. The Company buys and sells securities on behalf of its customers. Each time a customer enters a buy or sell transaction, the Company charges a commissions and related clearing expenses are recorded on the trade date (the date that the Company fulfills the trade order by finding and contracting with a counterparty and confirms the trade with the customer). The Company believes that the performance obligation is satisfied on the trade date because that is when the underlying financial instrument or purchaser is identified. The pricing is agreed upon and the risks and rewards of ownership of the securities have been transferred to/from the customer.

#### Mutual Fund and 12b1 fees and trails:

This is applicable to mutual funds and trails and direct held trails.

Mutual fund and direct fund companies have entered into agreements with the Company to distribute/sell its shares to investors. The Company may receive distribution fees paid by the funds upfront, over time, upon the investor's exit from the fund (that is, a contingent deferred sales charge), or as a combination thereof. The Company believes its performance obligation is the sale of securities to investors and as such this is fulfilled on the trade date. Any fixed amounts are recognized on the trade date and variable amounts are recognized to the extent it is probable that a significant revenue reversal will not occur once the uncertainty is resolved. For variable amounts. as the uncertainty is dependent on the value of the shares at future points in time as well as the length of time the investor remains in the fund, both of which are highly susceptible to factors outside the Company's influence, the Company does not believe that it can overcome this constraint until the market value of the fund and the investor activities are known. which are usually quarterly or monthly.

#### Interest Rebate Income:

Interest rebate income is interest earned on cash held in customer accounts with the Clearing Firms. The Company recognizes the income monthly which is when the Company believes its performance obligation has been contractually satisfied in all material respects.

#### NOTE 2 -- OFF BALANCE-SHEET RISK AND CLEARING AGREEMENT

The Company's customers may enter into various transactions involving derivatives and other off-balancesheet financial instruments. These financial instruments include futures contracts, exchange traded options, to-be-announced securities (TBA's) and securities purchased and sold on a when-issued basis (when-issued securities). These derivative financial instruments are used to meet the needs of customers and are, therefore, subject to varying degrees of market and credit risk. In addition, the Company's customers may sell securities that they do not currently own and will therefore be obligated to purchase such securities at a future date. Since the Company enters into the aforementions solely for the benefit of its customers, the Company does not bear any of the credit or market risk of those customers, with the exception of the risk to the Company should its customers fail to honor their obligations related to these derivative and other off-balance sheet financial instruments, as mentioned below.

To facilitate securities transactions, including the aforementioned transactions, on behalf of its customers, the Company has entered into an agreement with another broker/dealer (Clearing Broker/Dealer) whereby

{12}------------------------------------------------

#### NOTES TO FINANCIAL STATEMENTS FOR THE YEAR ENDED JUNE 30, 2025

the Company forwards (introduces) customer securities transactions to the Clearing Broker/Dealer, fully disclosing the customer name and other information. The processing and, if applicable, any financing pertaining to the introduced transactions are performed by the Clearing Broker/Dealer. The customer account is therefore maintained and recorded in the books and records of the Clearing Broker/Dealer. As part of the terms of the agreement between the Company and Clearing Broker/Dealer, the Company is held responsible for any losses arising when the customers introduced by the Clearing Broker/Dealer fail to meet their contractual commitments pertaining to the purchase, sale and possible financing of securities transactions and other financial instruments. The Company may therefore be exposed to off-balance-sheet risk in the event the customer is unable to fulfill its contracted obligations and it is necessary for the Clearing Broker/Dealer to purchase or sell securities or other financial instruments at a loss. The Company's exposure to risk would consist of the loss realized and any additional expenses incurred pertaining to the transaction or other customer activity.

The aforementioned agreement may be terminated by either party with 45 days of prior notification. The Company is required to maintain a \$100,000 deposit with the Clearing Broker/Dealer to assure its performance under the agreement.

#### NOTE 3 - RELATED PARTY TRANSACTIONS

As mentioned in Note 1, the Company is a wholly-owned subsidiary of Glacier Groups, Inc. (Parent). The Company files consolidated income tax returns with the Parent.

The Parent pays substantially all overhead and operating expenses on behalf of the Company other than commission expense and clearing and execution charges. Pursuant to a written agreement, the Company remburses the Parent for these expenses through a management fee. The expenses paid by the Parent for the year ended June 30, 2025 are as follows:

| Compensation and Related Benefits | \$ 107,985 |
|-----------------------------------|------------|
| Professional Fees                 | 25,700     |
| Оссирапсу                         | 15,461     |
| Communications                    | 19,187     |
| Regulatory Fees                   | 18.450     |
| Insurance                         | 8.198      |
| Other                             | 33,219     |
| Total                             | \$228,200  |

#### NOTE 4 - INCOME TAXES

The Company filed a consolidated tax return with Glacier Groups, Inc. The consolidated Company has net operating loss carvovers to future vears of approximately \$224.000 for both federal and state purposes. No deferred asset has been recorded on Polar Investment Counsel, Inc. since the majority of carryovers relate to the Parent Company. Pursuant to the expense sharing agreement, included in the parent are amounts for income taxes if necessary.

#### NOTE 5 - NET CAPITAL REQUIREMENTS

The Company is subject to the SEC 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 the net capital, both as defined, shall not exceed 15 to 1 (and the rule also provides that equity capital may not be withdrawn

{13}------------------------------------------------

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{14}------------------------------------------------

### SCHEDULE I, COMPUTATION OF NET CAPITAL UNDER RULE 15c3-1 JUNE 30, 2025

|                                                                                                                                                                 |   | 2025                               |
|-----------------------------------------------------------------------------------------------------------------------------------------------------------------|---|------------------------------------|
| STOCKHOLDER'S EQUITY at End of Year                                                                                                                             | S | 100,324                            |
| DEDUCTIONS:<br>Receivables from Broker/Dealers                                                                                                                  |   | 24                                 |
| NET CAPITAL BEFORE HAIRCUTS ON SECURITIES POSITIONS                                                                                                             |   | 100,300                            |
| HAIRCUTS ON SECURITIES                                                                                                                                          |   | 2,003                              |
| NET CAPITAL, End of Year                                                                                                                                        |   | 98,297                             |
| REQUIRED CAPITAL<br>Basic Capital Requirement:<br>Liabilities<br>Required Percent<br>Basic Capital Requirement<br>Minimum Capital Required (per CFTC rule 1.17) | S | 20,470<br>6.67%<br>1,365<br>45,000 |
| Excess Capital                                                                                                                                                  | S | 53,297                             |
| COMPUTATION OF AGGREGATE INDEBTEDNESS TO NET CAPITOL RATIO<br>Indebtedness<br>Net Capital<br>Percent of Debt to Net Capital                                     | S | 20,470<br>98,297<br>20.82%         |

There is no material difference between the computation of net capital presented above and the computation of net capital reported in the Company's Form X-17A-5 filed as of June 30, 2025

{15}------------------------------------------------

## SCHEDULE II, COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS UNDER RULE 15c3-3 (EXEMPTION) JUNE 30, 2025

The Company is exempt under (k)(2)(ii) of SEA Rule 15c3-3 for the activities through the clearing firm.

With respect to the Computation for Determination of Reserve Requirements under Rule I 5c3-3, the Company does not claim an exemption under paragraph (k) of SEA Rule I 5c3-3 pertaining to certain other business activities that the Company performs in reliance upon Footnote 74 of the SEC Release No. 34-70073. The Company does not hold customer funds or securities

{16}------------------------------------------------

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{17}------------------------------------------------

### RECONCILIATION OF FOCUS REPORT PART (IIA) AS OF JUNE 30, 2025 TO AUDITED FINANCIAL STATEMENTS AS OF JUNE 30, 2025

|                               |   | Balance Per<br>Focus Report on<br>30-Jun-25 |   | Adustments<br>Credit<br>Debit |    |  |      | Balance Per<br>Audited Financial<br>Statements at<br>30-Jun-25 |  |
|-------------------------------|---|---------------------------------------------|---|-------------------------------|----|--|------|----------------------------------------------------------------|--|
| Total Assets                  | S | 120,794                                     | S | I                             | S  |  | S    | 120,794                                                        |  |
| Less:                         |   |                                             |   |                               |    |  |      |                                                                |  |
| Total Liabilites<br>Net Worth |   | 20,470<br>100,324                           |   |                               |    |  |      | 20,470<br>100,324                                              |  |
| Less:                         |   |                                             |   |                               |    |  |      |                                                                |  |
| Non-Allowable Assets          |   | 24                                          |   |                               |    |  |      | 24                                                             |  |
| Tentative Net Capital         |   | 100,300                                     |   |                               |    |  | ക്ക  | 100,300                                                        |  |
| Less:                         |   |                                             |   |                               |    |  |      |                                                                |  |
| Securities Haircuts           |   | 2,003                                       |   |                               |    |  |      | 2,003                                                          |  |
| Net Capital                   | ക | 98,297                                      | S |                               | ತಿ |  | ಕ್ಕಾ | 98,297                                                         |  |

{18}------------------------------------------------

![](_page_18_Picture_0.jpeg)

100 E. Sybelia Ave. Suite 130 Maitland. FL 32751

Certified Public Accountants Email: pam(@ohabco.com

Telephone 407-740-7311 Fax 407-740-6441

## REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM ON APPLYING AGREED-UPON PROCEDURES

Board of Directors of Polar Investment Counsel, Inc.

We have performed the procedures included in Rule 17a-5(e)(4) under the Securities Exchange Act of 1934 and in the Securities Investor Protection (SIPC) Series 600 Rules, which are enumerated below on the accompanying General Assessment Reconciliation (Form SIPC-7) for the year ended June 30, 2025. Management of Polar Investment Counsel, Inc. (the Company) is responsible for its Form SIPC-7 and for its compliance with the applicable instructions on Form SIPC-7.

Management of the Company has agreed to and acknowledged that the procedures performed are appropriate to meet the intended purpose of assisting you and SIPC in evaluating the Company's compliance with the applicable instructions on Form SIPC-7 for the year ended June 30, 2025 Additionally, SIPC has agreed to and acknowledged that the procedures performed are appropriate for their intended purpose. This report may not be suitable for any other purpose. The procedures performed may not address all the items of interest to a user of this report and may not meet the needs of all users of this report and, as such, users are responsible for determining whether the procedures performed are appropriate for their purposes. The sufficiency of these procedures is solely the responsibility of those parties specified in this report. Consequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose. The procedures we performed and our associated findings are as follows:

- 1) Compared the listed assessment payments in Form SIPC-7 with respective cash disbursement records entries, noting no differences;
- 2) Compared the Total Revenue amounts reported on the Annual Audited Report Form X-17A-5 Part III for the year ended June 30, 2025 with the Total Revenue amount reported in Form SIPC-7 for the year ended June 30, 2025, noting no differences;
- 3) Compared any adjustments reported in Form SIPC-7 with supporting schedules and working papers, noting no differences:
- 4) Recalculated the arithmetical accuracy of the calculations reflected in Form SIPC-7 and in the related schedules and working papers supporting the adjustments, noting no differences; and
- 5) Compared the amount of any overpayment applied to the current assessment with the Form SIPC-7 on which it was originally computed, noting no differences.

We were engaged by the Company to perform this agreed-upon procedures engagement and conducted our engagement in accordance with attestation standards established by the AICPA and in accordance with the standards of the Public Company Accounting Oversight Board (United States). We were not engaged to and did not conduct an examination or a review engagement, the objective of which would be the expression of an opinion or conclusion, respectively, on the Company's Form SIPC-7 and for its compliance with the applicable instructions on Form SIPC-7 for the year ended June 30, 2025 Accordingly, we do not express such an opinion or conclusion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you.

We are required to be independent of the Company and to meet our other ethical responsibilities in accordance with the relevant ethical requirements related to our agreed-upon procedures engagement.

This report is intended solely for the information and use of the Company and SIPC and is not intended to be and should not be used by anyone other than these specified parties.

ohall and logg. M

Maitland, Florida

September 26, 2025

{19}------------------------------------------------

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{20}------------------------------------------------

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100 E. Sybelia Ave. Suite 130 Maitland, FL 32751

Certified Public Accountants Email: pam(@ohabco.com

Telephone 407-740-7311 Fax 407-740-6441

#### REPORT ON INTERNAL CONTROL REQUIRED BY CFTC REGULATION 1.16

To the Stockholder Polar Investment Counsel, Inc.

In planning and performing our audit of the financial statements of Polar Investment Counsel, Inc. (the "Company") as of and for the year ended June 30, 2025, in accordance with auditing standards generally accepted in the United States of America, we considered the Company's internal control over financial reporting ("internal control") as a basis for designing our auditing procedures that are appropriate in the circumstances for the purpose of expressing our opinion on the financial statements, but not for the purpose of expressing an opinion on the effectiveness of the Company's internal control. Accordingly, we do not express an opinion on the effectiveness of the Company's internal control.

Also, as required by Regulation 1.16 of the Commodity Futures Trading Commission ("CFTC"), we have made a study of the practices and procedures followed by the Company, including consideration of control activities for safeguarding customer and firm assets. This study included tests of such practices and procedures that we considered relevant to the objectives stated in Regulation 1.16 in making the periodic computations of minimum financial requirements pursuant to regulation 1.17.

The management of the Company is responsible for establishing internal control and the practices and procedures referred to in the preceding paragraph. In fulfilling this responsibility, estimates and judgments by management are required to assess the expected benefits and related costs of controls, and of the practices and procedures referred to in the preceding paragraph, and to assess whether those practices and procedures can be expected to achieve the CFTC's previously mentioned objectives. Two of the objectives of internal control and the practices and procedures are to provide management with reasonable but not absolute assurance that assets for which the Company has responsibility are safeguarded against loss from unauthorized use or disposition, and that transactions are executed in accordance with management's authorization and recorded properly to permit the preparation of financial statements in conformity with generally accepted accounting principles. Regulation 1.16(d)(2) lists additional objectives and procedures listed in the preceding paragraph.

Because of inherent limitations in internal control and the practices and procedures referred to above, error or fraud may occur and not be detected. Also, projection of them to future periods is subject to the risk that they may become inadequate because of changes in conditions or that the effectiveness of their design and operation may deteriorate.

A deficiency in internal control exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis. A significant deficiency is a control deficiency, or combination of control deficiencies, that adversely affects the entity's ability to initiate, authorize, record, process, or report financial data reliably in accordance with generally accepted accounting principles such that there is more than a remote likelihood that a misstatement of the entity's financial statements that is more than inconsequential will not be prevented or detected by the entity's internal control.

{21}------------------------------------------------

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{22}------------------------------------------------

# POLAR INVESTMENT COUNSEL INC Exemption Report

POLAR INVESTMENT COUNSEL INC (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)(1) and (4). To the best of its knowledge and belief, the COMPANY states the following:

- (1) The COMPANY claimed (an)exemption from 17 C.F.R. § 240.15c3-3 under the following provisions of 17 C.F.R. §240.15c3-3 (k)(2)(ii)
- (2) The COMPANY met the identified exemption provisions in 17 C.F.R. §240.15c3-3 (k)(2)(ii) throughout the most recent fiscal year without exception.

(3) The COMPANY is also filing this Exemption Report because the COMPANY'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 are limited to: effecting securities transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the COMPANY; and 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 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) (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.

I, MICHAEL JORDAN , affirm that, to my best knowledge and belief, this Exemption Report is true and correct.

Title: PRESIDENT CEO 9-24-25


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