# KALORAMA CAPITAL, LLC X-17A-5 (2026-03-20) — Broker-dealer annual report

- Company: KALORAMA CAPITAL, LLC
- Form: X-17A-5
- Filed: 2026-03-20
- Period: 2025-12-31
- Accession: 0001115903-26-000003
- CIK: 1115903
- File #: 8-52617
- Type: Broker-dealer
- Material weakness: No
- Auditor: Mercurius & Associates LLP
- Auditor location: Delhi, K7
- Contact: Elizabeth Avery
- Phone: 202-262-5469
- Email: eavery@kaloramacapital.com
- Website: kaloramacapital.com
- Signed by: Elizabeth Avery (Managing Director/Chief Compliance Officer)

Original filing: https://www.sec.gov/Archives/edgar/data/1115903/000111590326000003/edgarkaloramaannualreport.pdf

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

### **ANNUAL REPORTS FORM X-17A-5 PART** Ill

**FACING PAGE** 

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

| FILING FOR THE PERIOD BEGINNING O 1/01/2025 |  | AND ENDING 12/31/2025 |  |
|---------------------------------------------|--|-----------------------|--|
|                                             |  |                       |  |

MM/ DD/VY

**A. REGISTRANT IDENTIFICATION** 

# NAME oF FIRM: Kalorama Capital, LLC

TYPE OF REGISTRANT (check all applicable boxes):

<sup>~</sup>Broker-dealer D Security-based swap dealer D Major security-based swap participant D Check here if respondent is also an OTC derivatives dealer

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

# 1718 22nd ST NW

|                                                                                                                                           | (No. and Street)                                           |                                              |                            |  |
|-------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------|----------------------------------------------|----------------------------|--|
| Washington                                                                                                                                | DC                                                         |                                              | 20008<br>(Zip Code)        |  |
| (City)                                                                                                                                    | (State)                                                    |                                              |                            |  |
| PERSON TO CONTACT WITH REGARD TO THIS FILING                                                                                              |                                                            |                                              |                            |  |
| Elizabeth Avery                                                                                                                           | 202-262-5469                                               |                                              | eavery@kaloramacapital.com |  |
| (Name)                                                                                                                                    | (Area Code - Telephone Number)                             |                                              | (Email Address)            |  |
|                                                                                                                                           | B. ACCOUNTANT IDENTIFICATION                               |                                              |                            |  |
| INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*<br>Mercurius & Associates LLP (formerly known as AJSH & Co LLP) |                                                            |                                              |                            |  |
|                                                                                                                                           | (Name - if individual, state last, first, and middle name) |                                              |                            |  |
| A-94/8 Wazipur Industrial Area Main Ring Road                                                                                             | Delhi                                                      | India                                        | 11002                      |  |
| (Address)                                                                                                                                 | (City)                                                     | (State)                                      | (Zip Code)                 |  |
| PCAOB-02/10/2009<br>l"                                                                                                                    |                                                            | #3223                                        |                            |  |
| of R,g;straUoa w;th PCAOB)(;f appUcableJ                                                                                                  |                                                            | IPCAOB R,g;,rtraUoa N" mbe,, ;f appikabie) 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 of facts and circumstances relied on as the basis of t he exemption. See 17 CFR 240.17a-S(e)(1)(ii), if applicable.

Persons who are to respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid 0MB control number.

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MM/DD/VY

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#### OATH OR AFFIRMATION

| I, Elizabeth Avery                                               | swear (or affirm) that, t o the best of my knowledge and belief, the |  |
|------------------------------------------------------------------|----------------------------------------------------------------------|--|
| financial report pertaining to the firm of Kalorama Capital, 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.

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- 
- D (b) Notes to consolidated statement of financial condition. -;,,; •;--•~;,~~,,,
- **Q'** (c) Statement of income (loss) or, if there is other comprehensive income in the period(s) presented, **l~~-"'**  comprehensive income (as defined in§ 210.1-02 of Regulation **S-X).**
- **1,21** (d) Statement of cash flows.
- **(A** (e) Statement of changes in stockholders' or partners' or sole proprietor's equity.
- D (f) Statement of changes in liabilities subordinated to claims of creditors.
- **<sup>121</sup>' (g)** Notes to consolidated financial statements.
- 12' {h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.l Ba-1, as applicable.
- D (i) Computation of tangible net worth under 17 CFR 240.lBa-2.
- D 0) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3.
- D (k) Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.15c3-3 or Exhibit A to 17 CFR 240.18J-4, els c1µplicdble.
- D (1) Computation for Determination of PAB Requirements under Exhibit A to§ 240.1Sc3-3.
- D {m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3.
- D (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.
- **0,** (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.
- D (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition.
- ca' (q) Oath or affirmation in accordance with 17 CFR 240.17a-S, 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable.
- D (r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- (21" (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- D (t) Independent public accountant's report based on an examination of the statement of financial condition.
- IZf (u) Independent public accountant's report based on an examination of the financial report or financial statements under 17 CFR 240.17a-S, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable.
- D {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.
- l2f (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 (y) Report describing any material inadequacies tound to exist or found to have existed since the date ot t he previous audit, or a statement that no material inadequacies exist, under 17 CFR 240.17a-12(k). D (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.

<sup>~</sup>' .. ,· ~ ··. -~ <sup>~</sup> ... , , -~ ,\ . -- .. -~,·· \_,\."' ~- ... I?~,;. <sup>~</sup>'- --.; ..,. ~ ~=== **This filing• • contains (check all applicable boxes):** : ; \•j i ~ - <sup>i</sup>c: :- :<., ... ,.. .-l • <sup>I</sup> , ~ ~ (a) Statement of financial condition. ~ ",,~ ••.. .. .-' <sup>¼</sup>

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**MERCURIUS** & **ASSOCIATES LLP** 

+91 11 **4559 6689** 

**info@masllp.com** 

**www.masllp.com** 

Report of the Independent Registered Public Accounting Firm

To the Members of Kalorama Capital, LLC

#### Opinion on the Financial Statements

We have audited the accompanying statement of financial condition of Kalorama Capital, LLC (the "Company") as of December 31, 2025, and the related statement 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 the Company as of December 31, 2025, and the results of its operations and its cash flows for the year then ended, in conformity with accounting principles generally accepted in the United States of America.

#### **Basis** for Opinion

These financial statements are the responsibility of the Company's management. Our responsibility is to express an opinion on the Company's financial statements based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) ("PCAOB") and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion.

#### **Auditor's Report on Supplemental Information**

The supplemental information contained in the Schedule I (Computation of net capital requirement in pursuance to rule 1'.iCJ-1), Schedule II (Computation for determination of reserve re4uirer11e11l pursuant to Exhibit A to 17 CFR 240. 15c3-3) and Schedule Ill (Information relating to processing or control requirements under rule 15c3-3} has been subjected to audit procedures performed in conjunction with the audit of Company's financial statements. The supplemental information is the responsibility of the Company's management. Our audit procedures included determining whether the supplemental information reconciles to the financial statements or the underlying accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the supplemental information.

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<sup>~</sup>**f/1** wn,' v-<- *L* fl 1,> 0,,i ,;;;< LL-P

**Mercurius & Associates LLP** 

We have served as the company's auditor since 2021

New Delhi, India February 27, 2026

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### **Kalorama Capital, LLC**

Report of Independent Registered Public Accounting Firm and Financial Statements December 31, 2025

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# Kalorama Capital, LLC Statement of Financial Condition December 31, 2025

### **Table of Contents**

| Report of Independent Registered Public Accounting Firm                                     |    |
|---------------------------------------------------------------------------------------------|----|
| Statement ofFinanciaJ Condition                                                             | 3  |
| Statement of Operations                                                                     | 4  |
| Statement of Changes in Member's Equity                                                     | 5  |
| Statement of Cash Flows                                                                     | 6  |
| Notes to the Financial Statements                                                           | 7  |
| Supplemental Schedule:                                                                      |    |
| Computation of Net Capital Pursuant to SEC Rule l 5c3-l (Schedule I)                        | 10 |
| Computation for determination of reserve requirement pursuant to Rule 15c3-3 (Schedule II)  | 11 |
| Information relating to processing or control requirements under Rule 15c3-3 (Schedule Ill) | 12 |

#### **Assets**

| Current Assets            |              |
|---------------------------|--------------|
| Cash and cash equivalents | \$<br>18,081 |
| Total current assets      | 18,081       |
| Equipment, net            | 101          |
| Total assets              | \$<br>18,182 |

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# Kalorama Capital, LLC Statement of Financial Condition December 31, 2025

#### **Liabilities and member's equity**

| Current liabilities                   |              |
|---------------------------------------|--------------|
| Accrued expenses                      | \$<br>450    |
| Due to member (Related Party)         | 736          |
| Total current liabilities             | 1,186        |
| Member's equity                       | 16,996       |
| Total liabilities and member's equity | \$<br>18,182 |

See Notes to Financial Statements.

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# Kalorama Capital, LLC Statement of Operations Year Ended December 31, 2025

| Revenue                              |                |
|--------------------------------------|----------------|
| Income                               | \$<br>13,187   |
| Expenses                             |                |
| Dues and subscriptions               | 837            |
| Management fees                      | 12,000         |
| Regulatory dues and assessments      | 3,402          |
| Accounting and professional services | 13,473         |
| Communications                       | 912            |
| Office supplies and expenses         | 1,561          |
| Depreciation                         | 11             |
| Bank charges                         | so             |
|                                      |                |
| Total expenses                       | 32,246         |
| Net income                           | \$<br>(19,059) |

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# Kalorama Capital, LLC Statement of Changes in Member's Equity Year Ended December 31, 2025

| Balance at December 31, 2024     | \$<br>60,816 |
|----------------------------------|--------------|
| Net income                       | (19,059)     |
| Member's Distribution            | (24,761)     |
| Balance at December 31<br>, 2025 | \$<br>16,996 |

See Notes to Financial Statements.

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### Kalorama Capital, LLC

Statement of Cash Flows

#### Year Ended December 31, 20 25

| Cash flows from operating activities                              |              |
|-------------------------------------------------------------------|--------------|
| Receipts from customers                                           | \$<br>38,187 |
| Payments to vendors                                               | (32,274)     |
| Net cash provided by operating activities                         | 5,913        |
| Cash flows from f i n a n c i n g activities<br>Payment to member | (24,761)     |
| Net decrease in cash                                              | (18,848)     |
| Cash at beginning of year                                         | 36,929       |
| Cash at end of year                                               | \$<br>18,081 |

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#### **Kalorama Capital, LLC Notes to the Consolidated Financial Statements December 31, 2025**

### **Note 1-Nature of Business and Summary of Significant Accounting Policies**

Kalorama Capital, LLC ("the Company") is a broker-dealer registered with the Securities and Exchange Commission and is a member of the Financial Industry Regulatory Authority.

The accounts of the Company are maintained, and the financial statements are prepared on the accrual basis of accounting in accordance with accounting principles generally accepted in the United States ("US GAAP"). The accounting and reporting policies of the Company conform to general practices within the brokerage industry.

Cash was held in a checking account. For purposes of the statement of cash flows, the Company considers all highly liquid instruments with original maturities of three months or less to be cash equivalents.

The preparation of financial statements in conformity with US GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities at the date of the financial statements. Actual results could differ from the estimates made in preparation of the financial statements.

Revenues are recognized when the promised goods or services are delivered to customers, in an amount that is based on the consideration the Company expects to receive in exchange for those goods or services when such amounts are not probable of significant reversal. These policies reflect the adoption of ASC 606 *Revenue from Contracts with Customers,* as of January 1, 2018. The Company adopted *Revenues from Contracts with Customers* using the modified retrospective method, prior period amounts were not restated. The Company did not record any adjustments as a result of adopting this accounting policy.

Equipment consists of computer equipment and is stated at cost less accumulated depreciation. Depreciation is recorded using the straight-line method over the estimated useful life of the asset.

#### **FASB ASU 2023-07, Segment Reporting (Topic 280): Improvements to Reportable Segment Disclosures**

The F ASB issued ASU 2023-07 on November 27, 2023, which is intended to improve reportable segment disclosure requirements. Under previous guidance, while entities were required to disclose segment revenue and measure of profit or loss, there has been limited disclosure around the reporting of segment expenses. In addition to enhanced disclosures about significant segment expenses, the amendments enhance interim disclosure requirements, clarify circumstances in which an entity can disclose multiple segment measures of profit or loss, provide new segment disclosure requirements for entities with a single reportable segment, and contain other disclosure requirements.

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#### **Kalorama Capital, LLC Notes to the Consolidated Financial Statements December 31, 2025**

The purpose of the amendments is to enable investors to better understand an entity's overall performance and assess potential future cash flows. ASU 2023-07 is effective for fiscal years beginning after December 15, 2023, and interim periods within fiscal years beginning after December 15, 2024. The Company has adopted the requirements of the expanded segment disclosures as of December 31, 2025.

#### **Note 2 - Income Taxes**

The Company is organized as a single member Limited Liability Company and is, therefore, considered a disregarded entity for Federal and state income tax purposes. The sole member is taxed on the Company's taxable income. Accordi.ngly, no provision for Federal income taxes is included in the financial statements.

#### **Note 3** - **Equipment**

As of December 31, 2025, the Company's equipment consisted ofa computer that it purchased for \$1,748, net of accumulated depreciation of \$1,647. The Company is depreciating the computer over five years. During the year ended December 31 , 2025, depreciation expense was \$11.

#### **Note 4 - Revenue and Commissions**

During the year ended December 31, 2025, total revenue was \$13,187. Consulting fees are recognized as advice is provided to the client, based on the estimated progress of work and when revenues are not probable of a significant reversal. Success fees are recognized when all contingencies to the amount expected to be received have been satisfied and are not probable of a significant reversal.

Commissions expenses represent agreed upon payments to a consultant related to success fees recognized during the year ended December 31, 2025.

#### **Note 5 - Segment Reporting**

The Company is engaged in a single line of business as a broker-dealer as an Investment Banking Consultant covering Private Markets, which is comprised of one class of services, including capital raises/related services. The Company has identified its Managing Director/Chief Compliance Officer as the chief operating decision maker ("CODM") who uses net income to evaluate the results of the business and to manage the Company. Addjtionally, the CODM uses excess net capital (see NOTE 6), which is not a measure of profit and loss, to make operational decisions while maintaining capital adequacy. The Company's operations constitute a single operating segment and therefore, a single reportable segment, because the CODM manages the business activibes using information of the Company as a whole.

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### **Kalorama Capital, LLC Notes to the Consolidated Financial Statements December 31, 2025**

The accounting policies used to measure the profit and loss segment are the same as those described in the summary of significant accounting principles (NOTE 1). The Company revenue derived from two customers is more than I 0% of total revenue earned during the year ended December 31, 2025. The significant expense of the segment are reported on the accompanying income statement of this report.

#### **Note 6 - Net Capital Requirements**

As a broker-dealer, the Company is subject to the Securities and Exchange Commission Uniform Net Capital Rule (Rule 15c3-l ), 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. As of December 31 , 2025, the Company had net capital of \$16,895 which was \$11 ,895 in excess of its required minimum net capital of \$5,000.

#### **Note 7 - Related Party Transactions**

During the year ended December 31 , 2025, related party transactions as to the Company's sole member, totaled, for financial reporting purposes, \$40,172.91, comprised of management fees, member's distribution and reimbursed expenses. As to the foregoing, during the year ended December 31 , 2025, payments were made to the sole member totaling \$39,437.02, leaving a balance of \$735.89 payable.

#### **Note 8 - Subsequent Events**

Management has evaluated events through February27, 2026, the date on which the financial statements were available to be issued.

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### Kalorama Capital, LLC

# Computation of Net Capital Pursuant to SEC Rule 15c3-1 Year Ended December 31, 2025

| Member's equity from statement of financial condition:                                                                                             | \$<br>16,996 |
|----------------------------------------------------------------------------------------------------------------------------------------------------|--------------|
| Deductions:                                                                                                                                        |              |
| Non-allowable asset: equipment                                                                                                                     | (1 OJ)       |
| Net capital                                                                                                                                        | \$<br>16,895 |
| Minimum net capital required                                                                                                                       | \$<br>5,000  |
| Net capital in excess of minimum requirements                                                                                                      | \$<br>11,895 |
| The following is a reconciliation of the preceding computation of net capital to the<br>Company's corresponding unaudited Part II of Form X-17A-5: |              |
| Net capital from the preceding schedule:                                                                                                           | \$<br>16,895 |
| Reclassification of equipment to non-allowable assets                                                                                              | 101          |
| Net capital per unaudited Form X-17 A-5                                                                                                            | \$<br>16,996 |

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### Schedule II Kalorama Capital ,LLC Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3 As of December 2025

The Company does not claim an exemption under paragraph (k) of 17 C.F.R. 240. 15c3-3. The Company is a Non-Covered firm that relies on Footnote 74 of the SEC Release No. 34-70073. The Company did not, nor will handle customer cash or securities during the year ended December 31 , 2025. The Company does not have nor ever had any customer accounts.

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### Schedule ill Kalorama Capital .LLC Infonnation Relating to Processing or Control Requirements under Rule 15c3-3 As of December 2025

The Company does not claim an exemption under paragraph (k) of 17 C.F.R. 240. 15c3-3. The Company is a Non-Covered firm that relies on Footnote 74 of the SEC Release No. 34-70073. The Company <lid not, nor will handle customer cash or securities during the year ended December 31, 2025. The Company does not bave nor ever had any customer accounts.

(Remainder of this page left intentionally blank)

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**MERCURIUS** & **ASSOCIATES LLP**  +91 11 **'4559 6689 info@mosllp.com www.mosllp.c.om** 

#### Report of Independent Registered Public Accounting Firm

#### To the Members of Kalorama Capital, LLC

We have reviewed management's statement, included in the accompanying Kalorama Capital, LLC's Exemption Report, in which:

(1) Kalorama Capital, LLC (the "Company") does not claim an exemption under paragraph (k) of 17 C.F.R. §240.15c3-3 and

(2) The Company stated that it is filing the Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R.§240.17a-S because the company limits its business activities exclusively to receiving consulting and referral fees derived from private placement, and the Company 1) did not directly or indirectly receive, hold, or ot herwise owe funds or securities for or to customers 2) did not carry accounts of, or for, customers; and 3) did not carry PAB accounts (as defined in Rule 1Sc3-3) throughout the most recent fiscal year ended December 31, 2025 without exception.

The Company's management is responsible for the statements and for compliance with the provisions of Footnote 74 of the SEC Release No.34-70073 adopting amendments to 17 C.F.R. §240.17a-5 throughout the year ended December 31, 2025.

Our review was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included inquiries and other required procedures to obtain evidence about the Company's compliance with the provisions of Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R.§240.17a-S. 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 SEC Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5.

H Vl ~ .,\_\_,\_ *L* ft 16(4} J;J. (\_ *U* 

**Mercurius** & **Associates LLP** 

New Delhi, India February 27, 2026

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#### **MEMBER: FINRA AND SIPC**

### **171 8 22ND STREET NW**

### **WASHINGTON, DC 20008**

**EA VERY@KALORAMACAPITAL.COM** 

**TEL: 202•262•5469** 

### **KALORAMA CAPITAL EXEMPTION REPORT PURSUANT TO SEC RULE 17a-5**

**Kalorama Capital** (the "Firm") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C.F.R. sec. 240.17a-5, "Reports to be made by certain brokers and dealers"} This Exemption Report was prepared as required by 17 C.F.R. sec.240.17a-S(d)(1} and **(4).** To the best of its knowledge and belief, the Firm states the following:

- (1) The Firm does not claim an exemption under paragraph (k) of 17 C.F.R. sec.240.15c3-3;
- (2} The Firm is filing this Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. sec. 240.17a-5 because the Firm limits its business activities exclusively to receiving consulting and referral fees derived from private placements, and the Firm
	- (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

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where the funds are payable to the issuer or its agent and not to the Firm);

(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, 2025, without exception.

Kalorama Capital

I, Elizabeth Avery, swear or (affirm) that, to my best knowledge and belief, this Exemption Report is true and correct.

**By: &~~**  E::: thAvery

Founder/Managing Director

**Dated: February 26, 2026**


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