# COMMONWEALTH PHARMA SECURITIES LLC X-17A-5 (2026-05-01) — Broker-dealer annual report - Company: COMMONWEALTH PHARMA SECURITIES LLC - Form: X-17A-5 - Filed: 2026-05-01 - Period: 2025-12-31 - Accession: 0001177436-26-000004 - CIK: 1177436 - File #: 8-65456 - Type: Broker-dealer - Material weakness: No - Auditor: Morris & Morris PC - Auditor location: Needham, MA - Contact: Peter Flynn - Phone: 6173670099 - Email: flynn@peterflynnesq.com - Website: peterflynnesq.com - Signed by: Peter Flynn (Chief Financial Officer) Original filing: https://www.sec.gov/Archives/edgar/data/1177436/000117743626000004/cps1.pdf --- {0}------------------------------------------------ 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-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934** FILING FOR THE PERIOD BEGINNING **O 1/01/2025** MM/DD/YY AND ENDING **12/31/2025** MM/DD/YY **A. REGISTRANT IDENTIFICATION** NAME oF FIRM: Commonwealth Pharma Securities, LLC TYPE OF REGISTRANT (check all applicable boxes): ~ Broker-dealer 0 Security-based swap dealer 0 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.) 2016 Ocean St | | (No. and Street) | | |------------|------------------|------------| | Marshfield | MA | 02050 | | (City) | (State) | (Zip Code) | PERSON TO CONTACT W ITH REGARD TO THIS FILING | Peter F. Flynn | 617 -367 -0099 | Flynn@peterflynnesq.com | |----------------|--------------------------------|-------------------------| | (Name) | (Area Code - Telephone Number) | (Email Address) | ### **B. ACCOUNTANT IDENTIFICATION** INDEPENDENT PUBLIC ACCOUNTANT w hose reports are contained in this fil ing\* Morris & Morris, P.C. | | (Name - if individual, state last, first, and middle name) | | | |--------------------------------------------------|------------------------------------------------------------|--------------------|--------------------------------------------| | 32 Kearney Road | | Needham Heights MA | 02494 | | (Address) | (City) | (State) | (Zip Code) | | 01/06/2010 | | 4066 | | | (Date of Registration with PCAOB)(if applicable) | | | (PCAOB Registration Number, if applicable) | | | FOR OFFICIAL USE ONLY | | | • Claims for exemption from the requirement that the annual reports 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 the exempt ion. 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 currently valid 0MB control number. ### 0MB APPROVAL 0MB Number: 3235-0123 Expires: Nov. 30, 2026 Estimated average burden hours per response: 12 SEC FILE NUMBER {1}------------------------------------------------ ### **OATH OR AFFIRMATION** | swear (or affirm) that, to the best of my knowledge and belief, the
I, Peter Flynn | | |---------------------------------------------------------------------------------------|--| |---------------------------------------------------------------------------------------|--| financial report pertaining to the firm of Commonwealth Pharma Securities, 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. | ignature: | | |-----------|--| | itle: | | ### **This filing\*\* contains (chec~ all applicable boxes):** - **iii** (a) Statement offinancial condition. - D (b) Notes to consolidated statement of financial condition. - **iii** (c) Statement of income (loss) or, if there is other comprehensive income in the period(s) presented, a statement of comprehensive income (as defined in § 210.1-02 of Regulation S-X). - **iii** (d) Statement of cash flows. - **iii** (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. - □ (g) Notes to consolidated financial statements. - **iii** (h) Computation of net capital under 17 CFR 240.1Sc3-1 or 17 CFR 240.18a-1, as applicable. - D (i) Computation of tangible net worth under 17 CFR 240.18a-2. - D (j) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.1Sc3-3. - □ (k) Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.1Sc3-3 or Exhibit A to 17 CFR 240.18a-4, as applicable. - □ (I) Computation for Determination of PAB Requirements under Exhibit A to§ 240.15c3-3. - □ (m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3. - D (n) Information relating to possession or control requirements for security-based swap customers under 17 CFR 240.1Sc3-3(p)(2) or 17 CFR 240.18a-4, as applicable. - **iii** (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capital or tangible net worth under 17 CFR 240.1Sc3-1, 17 CFR 240.18a-1, or 17 CFR 240.18a-2, as applicable, and the reserve requirements under 17 CFR 240.1Sc3-3 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. - **iii** (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. - D (r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - **iii** (s) Exemption report in accordance with 17 CFR 240.17a-S 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. - **iii** (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 240.18a-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-S or 17 CFR 240.18a-7, as applicable. - **iii** (w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-S or 17 CFR 240.18a-7, as applicable. - D (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-le or 17 CFR 240.17a-12, as applicable. - D (y) 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(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. {2}------------------------------------------------ ![](_page_2_Picture_0.jpeg) ### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM ON APPL YING AGREED UPON PROCEDURES** January 29, 2026 ### **TO THE DIRECTORS AND EQUITY OWNERS OF COMMONWEALTH PHARMA SECURITIES, LLC** 20 16 Ocean Street Marshfield, MA 02050 We have performed the procedures included in Rule l 7a-5(e)(4) under the Securities Exchange Act of 1934 and in the Securities Investor Protection Corporation (SIPC) Series 600 Rules, which are enumerated below, and were agreed to by Commonwealth Pharma Securities, LLC (Company) and the SIPC, solely to assist you and the SIPC in evaluating the Company' s compliance with the applicable instructions of the General Assessment Reconciliation (Form SIPC-7) for the year ended December 31, 2025. Management of the Company is responsible for its Form SIPC-7 and for its compliance with those requirements. This agreed-upon procedures engagement was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and in accordance with attestation standards established by the American Institute of Certified Public Accountants. 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. - I . Compared the listed assessment payments in Form SIPC-7 with respective cash disbursement records entries in the Company's accounting records, noting no differences; - 2. Compared the Total Revenue amounts reported on the Annual Audited Report Form X-17 A-5 Part **111** for the year ended December 3 I, 2025, w ith the Total Revenue amounts reported in Form SIPC-7 for the year ended December 31, 2025, noting no difference; - 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 32 Kearney Road • l\"eedham Heights, ~L\ 02494 • (781) 455-6900 • Fax (781) 455-6902 ![](_page_2_Picture_10.jpeg) The CPA. Never Underestimate the Value."' {3}------------------------------------------------ ![](_page_3_Picture_0.jpeg) # **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM ON APPL YING AGREED UPON PROCEDURES** (Continued) ## **TO THE DIRECTORS AND EQUITY OWNERS OF COMMONWEALTH PHARMA SECURITIES, LLC** January 29, 2026 Page 2 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 not engaged to, and did not conduct an examination or a review, the objective of which would be the expression ofan opinion or conclusion, respectively, on the Company"s compliance with the appl icable instructions of the Form SIPC-7 for the year ended December 3 1, 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. This report is intended solely for the information and use of the Company and the SIPC and is not intended to be and should not be used by anyone other than these specified parties. Certified Public Accountants ![](_page_3_Picture_9.jpeg) The CPA. Never Underestimate the Value.'~ {4}------------------------------------------------ ### FINANCIAL STATEMENTS AND SUPPLEMENTARY INFORMATION Year Ended December 31, 2025 {5}------------------------------------------------ # **TABLE OF CONTENTS** | REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM | 1-2 | |---------------------------------------------------------|------| | FINANCIAL STATEMENTS | | | 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 | | SUPPLEMENTAL SCHEDULES | | | Computation of Net Capital Pursuant to Uniform Net Capital Rule I 5c3-
I | 11 | |--------------------------------------------------------------------------------------------|----| | Report of Independent Registered Public Accounting Firm on Exemption
Under Rule I 5c3-3 | 12 | | Exemption under Rule I 5c3-3 | 13 | {6}------------------------------------------------ ![](_page_6_Picture_0.jpeg) ### **Report oflndependent Registered Public Accounting Firm** January 29, 2026 ### **TO THE DIRECTORS AND EQUITY OWNERS OF COMMONWEAL TH PHARMA SECURITIES, LLC** 20 16 Ocean Street Marshfield, MA 02050 ### *Opinion on the Financial Statements* We have audited the accompany ing statement of financial condition of Commonwealth Pharma Securities, LLC (the "Company") as of December 3 1, 2025, the related statements of operations, changes in member's equity, and cash flows for the year then ended, and the related notes (col lectively 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 year then ended, in conformity with accounting principles generally accepted in the United States of America. ### *Basis/or 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. 32 Kearney Road • :-S:eedham Heights, i\1A 02494 • (781) 455-6900 • Fax (781) 455-6902 ![](_page_6_Picture_10.jpeg) The CPA. Never Underestimate the Value."' {7}------------------------------------------------ ![](_page_7_Picture_0.jpeg) # **Report oflndependent Registered Public Accounting Firm (Continued)** ### **TO THE DIRECTORS AND EQUITY OWNERS OF COMMONWEALTH PHARMA SECURITIES, LLC** January 29, 2026 Page 2 ### *Supplemental Information* The information contained in The Computation of Net Capital Under Rule 15c 3-1 ofthe Securities and Exchange Commission ("Supplemental Information") has been subjected to audit procedures performed in conjunction with the audit of the Company's financial statements. The Supplemental Information is the responsibility of the Company's management. Our audit procedures included determining whether the Supplemental Information reconciles to the financial statements or the underlying accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the Supplemental Information. In forming our opinion on the Supplemental Information, we evaluated whether the Supplemental Information, including its form and content is presented in conformity with 17 C.F.R. § 240. I 7a-5. In our opinion, the Computation of Net Capital Under Rule I 5c3-1 of the Securities and Exchange Commission is fairly stated, in all material respects, in relation to the financial statements taken as a whole. Morris & Morris, P.C. Certified Public Accountants We have served as the Company's auditor since 2016. Needham Heights, MA 02494 ![](_page_7_Picture_7.jpeg) The CPA. Never Underestimate the Value.SM {8}------------------------------------------------ # **STATEMENT OF FINANCIAL CONDITION December 31, 2025** ### **ASSETS** | Cash | \$
46,086 | |---------------------------------------|--------------| | Prepaid expenses | 469 | | Total Assets | 46,555
\$ | | LIABILITIES AND MEMBER'S EQUITY | | | Accrued expenses | \$
6,000 | | Total Liabilities | 6,000 | | Member's Equity | | | Member contributions | 118,830 | | Accumulated deficit | (78,275) | | Total Member's Equity | 40,555 | | Total Liabilities and Member's Equity | 46,555
\$ | {9}------------------------------------------------ # **STATEMENT OF OPERATIONS Year Ended December 31, 2025** | Revenues: | | |------------------------|----------------| | | \$
0 | | Operating expenses: | | | Commissions | 12,700 | | Professional fees-CCO | 15,000 | | Professional Fee-Audit | 6,000 | | Archiving | 1,534 | | SIPC Assessment | 31 | | Bank fees | 35 | | Fidelity bond | 1,030 | | Filing fees | 1,475 | | Total Expenses | 37,805 | | Net Loss | \$
(37,805) | | | | **See accompanying independent registered public accounting firm's report and notes to financial statements - 4** - {10}------------------------------------------------ # **STATEMENT OF CHANGES IN MEMBER'S EQUITY Year Ended December 31, 2025** | | Member
Contributions | Accumulated
Defict | Total | |----------------------------|-------------------------|-----------------------|----------| | Balance, January 1, 2025 | \$
118,830 \$ | (40,470) \$ | 78,360 | | Net loss | | (37,805) | (37,805) | | Balance, December 31, 2025 | \$
118,830 \$ | (78,275) \$ | 40,555 | See Accompanying Independent Registered Public Accounting Firm's Report And Notes to Financial Statements -5- {11}------------------------------------------------ # **STATEMENT OF CASH FLOWS January 1, 2025 to December 31, 2025** | Cash flows from operating activities: | | |----------------------------------------------|----------------| | Net loss | \$
(37,805) | | Changes in operating assets and liabilities: | | | Accounts receivable | 21 ,000 | | Prepaid expenses | (364) | | Net cash provided by operating activities | (17, 169) | | Cash flows from financing activities: | | | Net cash provided by financing activities | | | Net decrease in cash | (17,169) | | Cash, beginning of year | 63,255 | | Cash, end of year | \$
46,086 | **See Accompanying Independent Registered Public Accounting Firm's Report and Notes to Financial Statements** {12}------------------------------------------------ # **NOTES TO FINANCIAL STATEMENTS December 31, 2025** #### Note 1 **Organization and nature of business** Commonwealth Pharma Securities, LLC (the "Company") was formed in December 2002 and is a Delaware limited liability company. The Company acts as an agent for the issuer of corporate securities for private placements per membership agreement with the Financial Industry Regulatory Authority ("FfNRA"). The Company is a registered broker under the Securities Exchange Act of 1934 and is a member of FIN RA and Securities Investor Protection Corp ("SIPC). #### Note 2 **Summary of significant accounting policies** ### **Method of Accounting** The Financial Statements have been prepared in conformity with accounting principles generally accepted in the United States of America, as established by the Financial Accounting Standards Board (FASB) and issued in the FASB Accounting Standards codification (the "Codification"), utilizing the accrual basis method of accounting. ### **Revenue recognition** The Company recognizes revenue upon completion of private placement of corporate securities. Fees are charged based upon an agreed upon percentage of the proceeds of the transaction. The Company did not incur costs to obtain revenue contracts with its customers. In the event that it did incur these costs, it would amortize the costs to expense over the time period that the services are expected to be provided to the customers. Revenue from contracts with its customers includes fees from placements. The recognition and measurement of revenue is based on the assessment of individual contract terms. In some circumstances, significant judgement is required to determine whether performance obligations are satisfied at a point in time or over time; how to allocate transaction prices where multiple performance obligations are identified; when to recognize revenue based on the appropriate measure of the Company's progress under the contract; and whether constraints on variable consideration should be applied due to uncertain future events. All of the Company' s revenues were derived from placement fees. ### **Income taxes** The sole member of the Company has elected to have the Company taxed as a singlemember LLC. Accordingly, the Company is not subject to federal or state income taxes. A ll taxable income/loss and tax credits are reflected on the income tax returns of the member. {13}------------------------------------------------ # **NOTES TO FINANCIAL STATEMENTS (CONTINUED) December 31, 2025** #### Note 2 **Summary of significant accounting policies (continued)** ### **Income tax positions** The Financial Accounting Standards Board ("F ASB") has issued a standard that clarifies the accounting and recognition of income tax positions taken or expected to be taken in the Company's income tax returns. The Company has analyzed tax positions taken for filing with the Internal Revenue Service and all state jurisdictions where it operates. The Company believes that the income tax positions will be sustained upon examination and does not anticipate any adjustments that would result in a material adverse affect on the Company's financial condition, results of operations or cash flows. Accordingly, the Company has not recorded any reserves or related accruals for interest and penalties for uncertain income tax positions. If the Company incurs interest or penalties as a result of unrecognized tax positions the policy is to classify interest accrued with interest expense and penalties thereon with operating expenses. The Company is subject to routine audits by taxing jurisdictions; however, there are currently no audits for any tax periods in progress. ### **Fair value of financial instruments** The carrying amounts of financial instruments, including cash, prepaid expenses, and accrued expenses approximate fair value due to the short-term nature of these assets and liabilities. ### **Use of estimates** Management uses estimates and assumptions in preparing financial statements. Those estimates and assumptions affect the reported amounts of assets and liabilities, the disclosure of contingent assets and liabi lities, and the reported revenues and expenses. Actual results could differ from these estimates. ### **Recent Accounting Pronouncements** In November 2023, the FASB issued ASC Update No. 2023-07, Segment Reporting (Topic 280): Improvements to Reportable Segment Disclosures. Update No. 2023-07 requires companies to disclose segment data based on how management makes decisions about allocating resources to segments and evaluating performance. The Company conducts its business activities and reports financial results as a single reportable segment. Using the management approach, qualitative and quantitative criteria establ ished by ASC 280, the Company is considered to be a single reportable segment. The CCO/CFO of the Company serves as Chief Operating Decision Maker, which makes decisions about allocating resources and assessing performance in a manner consistent with the way the Company operates its business and presents their financial results. The significant expenses of the segment are reported in the accompanying statement of operations of this report {14}------------------------------------------------ ## **NOTES TO FINANCIAL STATEMENTS (CONTINUED) December 31, 2025** #### Note 3 **Net capital requirements** The Company is subject to the Securities and Exchange Commission Uniform Net Capital Rule (Rule 15c3- I), which requires the maintenance of a minimum net capital balance and requires that the Company 's aggregate indebtedness to net capital, as defined, shall not exceed 15 to I . At December 3 1, 2025 the Company' s net capital was \$40,086, which was \$35,086 in excess of its required net capital of \$5,000. The Company's aggregate indebtedness to net capital was 0.15 to I. #### Note 4 **Related party transactions** The Company is under **l** 00% common ownership with Apeiron Partners LLC ("Apeiron"). The Company has a management agreement w ith Apeiron, whereby Apeiron assumes and pays expenses related to the day-to-day operations of the Company. In exchange, the Company is obligated to pay Apeiron a fee equal to the costs incurred by Apeiron plus an additional amount, which will reflect the time and effort of Apeiron based upon an allocation of time spent by Apeiron employees. No payments were paid to Apeiron under this agreement during 2025. #### Note 5 **Concentrations of credit risk** The Company maintains its cash at financial institutions in bank deposits which may exceed federally insured limits. The Company has not experienced any losses in such accounts. The Company believes it is not exposed to any significant risk with respect to cash. {15}------------------------------------------------ ### **NOTES TO FINANCIAL STATEMENTS (CONTINUED) December 31, 2025** #### Note 6 **Statement of Cash Flows** For the year ended December 31 , 2025, the Company did not have any significant noncash investing or financing activities. #### Note 7 **Subsequent Events** The Company has evaluated subsequent events through January 29, 2026, which is the date the financial statements were available to be issued and has determined that there are no additional disclosures required. {16}------------------------------------------------ # **COMPUTATION OF NET CAPITAL PURSUANT TO UNIFORM NET CAPITAL RULE 15c3-1 Year Ended December 31, 2025** | Capital | | |-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------| | Member contributions | \$
11 8,830 | | Accumulated deficit | (78,275) | | | 40,555 | | | | | Deductions and charges: | | | Nonallowable assets: | | | Prepaid expenses | (469) | | Net capital | \$
40,086 | | Aggregate indebtedness | | | Accrued expenses | \$
6,000 | | | | | Computation of basic net capital requirement | | | Minimum net capital required | \$
400 | | Minimum dollar net capital required | 5,000 | | Net capital requirement | 5,000 | | | | | Excess net capital | \$
35,086 | | Net capital less 120% of minimum | | | dollar net capital required | \$
34,086 | | Ratio of aggregate indebtedness to net capital | 0.15to I | | Reconciliation with Company's computation (included | | | in Part II of Form 17a-5, as of December 31, 2025 | | | | | | Net Capital, as reported in Company's part II (unaudited) Focus report | \$
40,086 | | Net capital per above | \$
40,086 | | | ======== | | No material differences exist between the audited computation of net Capital
and the unaudited net capital as reported in the Company's FOCUS
report for the year ended December 31, 2025 | | **-11** - {17}------------------------------------------------ ![](_page_17_Picture_0.jpeg) ### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM ON EXEMPTION REPORT** January 29, 2026 ### **TO THE DIRECTORS AND EQUITY OWNERS OF COMMONWEALTH PHARMA SECURITIES, LLC** 2016 Ocean Street Marshfield, MA 02050 We have reviewed management's statement, included in the accompany ing Rule I5c3-3 Exemption Repo1t pursuant to SEC Rule l 7a-5, in which ( I) Commonwealth Pharma Securities, LLC did not claim an exemption under paragraph (k) of 17 C.F.R. §240 I 5c3-3, and (2) Commonwealth Pharma Securities, LLC is filing this Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. §240. J 7a-5 because the Company limits its business activities exclusively to ( I) proprietary trading: (2) 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; (3) receiving transaction-based compensation for identifying potential merger and acquisition opportunities for clients, referring securities transactions to other broker-dealers, or providing technology or platform services; ( 4) participating in distributions of securities (other than firm commitment underwritings) in accordance with the requirements of paragraphs (a) or (6)(2) of Rule I5c2-4; and/or (5) engaging solely in activities permitted for capital acquisition brokers ("CAB") as defined in FlNRA's CAB rules and approved for membership in FINRA as a CAB. In addition. Commonwealth Pharma Securities, LLC (I) did not directly or indirectly receive, hold. or otherwise 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 I 5c3-3) througholll the most recent fiscal year ended December 31. 2025, without exception. Commonwealth Phanna 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 Publ ic Company Accounting Oversight Board (United States) and, accordingly, included inquiries and other required procedures to obtain evidence about the Company's compliance with the exemption provisions. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, we do not express such an opinion. Based on our review, we are not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based upon Commonwealth Pharma Securities, LLC's business activities contemplated by Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. the conditions set forth in Footnote 74 of the SEC Release No. 34-70073 §240. I 7a-5, and related SEC Staff Frequently Asked Questions. Certified Public Accountants 32 Kearney Road • Needham Heights, l\1A 02494 • (781) 455-6900 • Fax (781) 455-6902 ![](_page_17_Picture_10.jpeg) The CPA. Never Underestimate the Value.'M {18}------------------------------------------------ # Commonwealth Phanna Securities LLC's Exemption Report Cornmonw1.:alth Pharma 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. 5240.17a-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: - (I) The Company does not claim an exemption under paragraph (k) of 17 C.F.R. SS 240. 15c3-3.and - (2) The Company is filing this Exemption Report relying on Footnote 74 oftl1e SEC Release No. 34-70073 adopting <1mendments to 17 C.F.R. 240. l 7a-5 because the Company limits its business activities exclusively to (include all that apply. for example.): (1 ) proprietary trading; (2) effecting securities transactions via subscriptions on n subscription way basis where the funds are payable to the issuer or its agent and not to the Company; (3) receiving transaction-based compensation for identiCying potential merger and acquisition opportunities for clients, referring securities transactions to other broker-dealers. or providing technology or platform services; ( 4) participating in distributions of securities (other than firm commitment undenvritings) in accordance with the requirements of paragraphs (a) or (b )(2) of Rule l 5c2-4; and/or (5) engaging solely in activities permitted for capital acquisition brokers ("CAB") as defined in FINRA's CAB rules and approved for membership in FlNRA as a CAB. and the Company (I ) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, (other than money or other consideration rece.ived and promptly transmitted in compliance with parngraph (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 nol carry accounts of or for customers: and (3) did not carry PAB accounts (as defined in Rule I 5c3-3) throughout the most recent fiscal year without exception. Commonwealth Pharma Securities, LLC L Peter Flynn, swear (or affirm) that. to my best knowledge and belie( this Exemption Report is true and correct. oy. ?)L ,,. ~ "= ~:----- n . -./..\_ r ;--' ---r-- *c..-2"~* Ti Lie: ChicfComplia~ffice December 31, 2025 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.