# WALTER GREENBLATT & ASSOCIATES, LLC X-17A-5 (2026-02-27) — Broker-dealer annual report - Company: WALTER GREENBLATT & ASSOCIATES, LLC - Form: X-17A-5 - Filed: 2026-02-27 - Period: 2025-12-31 - Accession: 0001267806-26-000001 - CIK: 1267806 - File #: 8-66211 - Type: Broker-dealer - Material weakness: No - Auditor: Nawrocki Smith LP - Auditor location: Hauppauge, NY - Contact: David Brant - Phone: 4022151352 - Email: david.brant@acaglobal.com - Website: acaglobal.com - Signed by: Walter Greenblatt (CEO) Original filing: https://www.sec.gov/Archives/edgar/data/1267806/000126780626000001/fullfs25.pdf --- {0}------------------------------------------------ #### **UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549** 0MB APPROVAL 0 MB Number: 3235-0123 Expires: Nov 30, 2026 Estimated average burden hours per response: 12 # **ANNUAL REPORTS FORM X-17 A-5 PART Ill** | SEC FILE NUMBER | | |-----------------|--| 8-66211 **FACING PAGE Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934** FILING FOR THE PERIOD BEGINNING \_\_\_ 1 \_ 11\_ 12\_ 0 \_ 2 \_ 5 \_\_\_ AND ENDING \_\_\_ 12 \_ 1 \_ 3 \_ 11\_ 2 \_ 02\_ 5 \_\_ \_ MM/DD/VY MM/DD/VY **A. REGISTRANT IDENTIFICATION** NAME OF FIRM: Walter Greenblatt & Associates, LLC TYPE OF REGISTRANT (check all applicable boxes): ~ Broker-dealer D Security-based swap dealer D Major security-based swap participant □ Check here if respondent is also an OTC derivatives dealer ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) 325 St. Marks Avenue Brooklyn (City) (No. and Street) **NY** (State) PERSON TO CONTACT WITH REGARD TO THIS FILING 11238 (Zip Code) David Brant (402) 215-1352 david.brant@acaglobal.com (Name) (Area Code -Telephone Number) (Email Address) **B. ACCOUNTANT IDENTIFICATION** INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing \* Nawrocki Smith LLP 100 Motor Parkway #580 (Address) 03/04/2009 (Name - if individual, state last, first, and middle name) Hauppauge (City) 3370 **FOR OFFICIAL USE ONLY NY** (State) 11788 (Zip Code) \* 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 exemption. See 17 CFR 240.17a-S(e)(l)(ii), if applicable. **Persons who are to respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid 0MB control number.** {1}------------------------------------------------ #### **OATH OR AFFIRMATION** 1 1...:...;.~.::..\_\_.:...,\_ Walter Greenblatt \_\_\_\_\_\_\_\_\_\_\_\_\_\_ ----:~ swear (or affirm) that, to the best of my knowledge and belief, the financial report pertaining to the firm of Walter Greeblatt & Associates, LLC , as of December 31 , 2 025 \_, 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. s;gnatuce~ (:~ Title: CEO and Managing Director Notary Public #### **This filing\*\* contains (check all applicable boxes):** - IZI (a) Statement of financial condition . - D (b) Notes to consolidated statement of financial condition. - IZI (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). - IZI (d) Statement of cash flows. - i2I (e) Statement of changes in stockholders' or partners' or sole proprietor's equity. - □ (f) Statement of changes in liabilities subordinated to claims of creditors. - i2I (g) Notes to consolidated financial statements. - **121**(h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-1, as applicable. - □ (i) Computation of tangible net worth under 17 CFR 240.18a-2. - IZI (j) 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 B to 17 CFR 240.15c3-3 or Exhibit A to 17 CFR 240.18a-4, as applicable. - D (I) Computation for Determination of PAB Requirements under Exhibit A to§ 240.15c3-3. - IZI (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. - IZI (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 . - IZI (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. - i2I (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. - IZI (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-5 or 17 CFR 240.18a-7, as applicable. - IZI (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 240.15c3-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). □ (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}------------------------------------------------ # WALTER GREENBLATT & ASSOCIATES, LLC # FINANCIAL STATEMENTS AND SUPPLEMENTAL INFORMATION TOGETHER WITH REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTANT # AS OF AND FOR THE YEAR ENDED DECEMBER 31 , 2025 {3}------------------------------------------------ # WALTER GREENBLATT & ASSOCIATES, LLC FINANCIAL STATEMENTS FOR THE YEAR ENDED DECEMBER 31, 2025 # TABLE OF CONTENTS | Report oflndependent Registered Public Accounting Firm 2 | | |------------------------------------------------------------------------------------|--| | Statement of financial condition 3 | | | Statement of operations 4 | | | Statement of changes in member's equity 5 | | | Statement of cash flows 6 | | | Notes to financial statements 7-11 | | | Supplemental schedules 13-14 | | | Report oflndependent Registered Public Accounting Firm on the exemption report 15 | | | Exemption statement regarding SEC Rule 15c3-3 16 | | {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) #### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** To the Member of Walter Greenblatt & Associates, LLC: #### **Opinion on the Financial Statements** We have audited the accompanying statement of financial condition of Walter Greenblatt & Associates, LLC (the "Company") as of December 31 , 2025, the related statements of operations, changes in member's equity, and cash flows for the year ended December 31 , 2025, 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 Walter Greenblatt & Associates, LLC 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 U.S. Securities and Exchange Commission ("SEC") 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 Schedules I and II have 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. §240.17a-5. In our opinion, the supplemental information is fairly stated, in all material respects, in relation to the financial statements as a whole. We have served as Walter Greenblatt & Associates, LLC's auditor since 2020. Hauppauge, New York February 27, 2026 {5}------------------------------------------------ # WALTER GREENBLATT & ASSOCIATES, LLC STATEMENT OF FINANCIAL CONDITION AS OF DECEMBER 31 , 2025 #### ASSETS | Assets: | | |------------------------------------------|------------| | Cash | \$ 82,532 | | Prepaid expenses | 20,565 | | Total current assets | 103,097 | | Fixed assets | 3,481 | | Investment in Illuminare Biotechnologies | 555 | | Total assets | \$ 107 133 | #### LIABILITIES AND MEMBER'S EQUITY | Liabilities: | | |---------------------------------------|------------| | Accounts payable and accrued expenses | \$ 59,102 | | Deferred revenue | 4,500 | | Total liabilities | 63,602 | | Member's equity | 43,531 | | Total liabilities and member's equity | \$ 107 133 | {6}------------------------------------------------ ## WALTER GREENBLATT & ASSOCIATES, LLC STATEMENT OF OPERATIONS YEAR ENDED DECEMBER 31 , 2025 | Revenue | | |--------------------------|-------------| | Commissions | \$174,079 | | Consulting Services | 70,500 | | Other Income | 8,950 | | Total Revenue | \$253,529 | | Operating expenses: | | | Professional fees | 80,846 | | Independent contractors | 79,353 | | Officer salaries | 45,068 | | Dues and subscriptions | 33,472 | | Travel and entertainment | 19,156 | | Regulatory fees | 7,029 | | Payroll taxes | 3,763 | | Depreciation | 994 | | Other expenses | 24,071 | | | | | Total operating expenses | \$293,751 | | Net loss | \$ (40 223) | {7}------------------------------------------------ #### WALTER GREENBLATT & ASSOCIATES, LLC STATEMENT OF CHANGES IN MEMBER'S EQUITY YEAR ENDED DECEMBER 31 , 2025 | Member's equity as ofJanuary 1, 2025 | \$ 11
,542 | |---------------------------------------------|---------------| | Net loss | (40,223) | | Member contributions | 72,212 | | Member's equity as of December 31
, 2025 | \$ 43 531 | {8}------------------------------------------------ ### WALTER GREENBLATT & ASSOCIATES, LLC STATEMENT OF CASH FLOWS YEAR ENDED DECEMBER 31 , 2025 | Cash flows from operating activities:
Net loss | \$(40,223) | |--------------------------------------------------------------------------------------------------------------------------|---------------------------| | Adjustments to reconcile net loss to
net cash used in operating activities | | | Changes in operating assets and liabilities
Depreciation
Prepaid expenses
Accounts payable and accrued expenses | 994
(7,174)
(2,028) | | Net cash used in operating activities | (48,431) | | Cash flows used in investing activities
Fixed assets | -0- | | Net cash used in investing activities | -0- | | Cash flows from financing activities
Member contributions
Net cash provided by financing activities | 72,212
72,212 | | | | | Net increase in cash | 23,781 | | Cash at beginning of year | 58,751 | | Cash at end of year | \$ 82 532 | {9}------------------------------------------------ # 1. Nature of Company and Summary of Significant Accounting Policies ### Business Description Walter Greenblatt & Associates, LLC (the "Company") offers business consulting and investment banking services to public and private, middle market and early stage companies in the biotech and healthcare related sectors. Consulting services include business plan development, strategic planning and market research and valuation. ### Method of Accounting The financial statements have been prepared on the accrual basis of accounting in accordance with accounting principals generally accepted in the United States of America ("GAAP"). # Use of Estimates The preparation of the financial statements, in conformity with GAAP, 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. Estimates also affect the reported amounts of revenue and expenses during the reporting period. Actual results could differ from those estimates. #### Income Taxes The Company complies with the Financial Accounting Standards Board ("F ASB") Accounting Standards Codification ("ASC) Topic 740, Income Taxes. The Company, with the consent of its shareholder, elected to be taxed under Subchapter S, of the Internal Revenue Code for federal income tax purposes. Under the provisions of Subchapter S, the Corporation does not pay federal corporate income taxes on its taxable income. Corporate income or loss of any tax credits earned are included in the shareholders' individual income tax returns. #### Investments The investment in Illuminare Biotechnologies is recorded at cost. {10}------------------------------------------------ #### Revenue Recognition The Company follows FASB ASC Topic 606, Revenue from Contracts with Customers. The revenue recognition guidance requires that an entity recognize revenue to depict the transfer of promised goods or services to customers in an amount that reflects the consideration to which the entity expects to be entitled in exchange for those goods or services. The guidance requires an entity to follow a five step model to (a) identify the contract(s) with a customer, (b) identify the performance obligations in the contract, ( c) determine the transaction price, ( d) allocate the transaction price to the performance obligations in the contract, and ( e) recognize revenue when ( or as) the entity satisfies a performance obligation. The Company recognizes consulting services revenue monthly. There are no performance obligations associated with consulting service contracts. The Company earns commissions for investment banking services. All performance obligations are completed prior to receiving funds from investment banking clients. Revenue is recognized when investment banking transactions are fully funded. #### Subsequent Events F ASB ASC Topic 855, Subsequent Events sets forth general accounting and disclosure requirements for events that occur subsequent to the Statement of Financial Condition date but before the Company's financial statements are issued. The Company has evaluated events through the date of Report of Independent registered Public Accounting Firm Report which the financial statements were available to be issued, and have determined there were no material subsequent events to be disclosed. {11}------------------------------------------------ # 2. Net Capital As a broker dealer, the Company is subject to the U.S. Securities and Exchange Commission's regulations and operating guidelines, which require the Company to maintain a specified amount of net capital, as defined, and a ratio of aggregate indebtedness to net capital as derived, not exceeding 15 to 1. The Company's net capital, computed under Rule 15c3-1 , was \$18,930 at December 31 , 2025, which exceeded the required net capital of \$5,000 by \$13,930. The ratio of aggregate indebtedness to net capital at December 31 , 2025 was 3.36 to 1. #### 3. Revenue from Contracts with Customers ### Significant Judgments Revenue from contracts with customers includes commission income and fees from investment banking and asset management services. The recognition and measurement of revenue is based on the assessment of individual contract terms. Significant judgment is required to determine whether performance obligations are satisfied at a point in time or over time, and when to recognize revenue based on the appropriate measure of the Company's progress under the contract. #### Disaggregated Revenue from Contracts with Customers The following table presents revenue by major source: | Revenue from contracts with customers: | | |----------------------------------------|------------| | Commissions on capital raised | \$ 174,079 | | Management consulting services | 70 500 | | Total revenue from contracts | \$244,579 | #### Contract assets and liabilities Contract assets or liabilities exist when revenue is recognized over time. The Company does not have any contract assets or liabilities at December 31 , 2025 . {12}------------------------------------------------ ### Performance obligation Commissions on capital raised: The Company raises investment capital from investors for its clients. Each time an investor invests in one of the Company's clients, the Company charges a commission. Commissions are billed on the date that the client receives the investment funding and relevant documents. The Company believes that the performance obligation is satisfied on that date because that is when the investment is logged by the client company and the investor becomes an owner of the security sold. Management Consulting Services: The Company provides management consulting services on a monthly basis to certain clients. The services primarily consist of taking the role of acting CFO and related services including, but not limited to, bookkeeping, purchasing and strategic advising on financial matters. Revenue is recognized as services are provided. #### Costs to Obtain or Fulfill a Contract with a Customer The Company has recorded certain costs incurred to obtain revenue contracts with its customers, including syndication costs for clients where capital raising has been syndicated. These costs are expensed immediately as there are no performance obligations created for future events. 4. Segment Information The Company conducts business as a single operating segment. The accounting policies of the segment are the same as those described in Note 1. The key measure of segment profit or loss that the Chief Operating Decision Maker ("CODM") uses to assess performance is the Company's net income, as reported on the Statement of Operations. All revenue and expense categories on the Statement of Operations are significant and there are no other significant segment revenue and expenses that would require disclosure. Assets provided to the CODM are consistent with those reported on the Statement of Financial Condition. #### 5. Related Parties The Company provided monthly management services for Illuminare Biotechnologies, Inc. The Company owns a minority interest in the voting stock of Illuminare Biotechnologies, Inc. During 2025, the Company received \$55,594 from Illuminare Biotechnologies for its services. The Company provides monthly management services for Thylacine Bio Inc. The principal owner of the Company, Walter Greenblatt, is the Chief Financial Officer for Thylacine Bio. During 2025, the Company received \$7,350 from Thylacine Bio for its services. {13}------------------------------------------------ #### 6. Warrants Upon each commissionable security sale, the Company earns warrants to purchase the same security that was sold in the transaction. The amount of warrants earned is determined according to a schedule outlined in the engagement agreement with the client. At the time the warrants are issued to the Company, they are immediately assigned to its principal. These warrants at December 31 , 2025 do not have any value assigned to them. The Company did not earn any warrants in 2025. #### 7. Going Concern The Company's produce a net loss of \$40,223 for the year ending December 31 , 2025. The sole owner of the Company has the financial ability and willingness to contribute additional capital to continue as a going concern. In February 2026, the Company close a deal with earned revenue that exceeded 2025 operating expenses. #### 8. Commitments and Contingencies The Company is exposed to various asserted and unasserted potential claims encountered in the normal course of business. In the opinion of management, the resolution of these matters will not have a material effect on the Company's financial position or results of operations. {14}------------------------------------------------ # WALTER GREENBLATT & ASSOCIATES, LLC SUPPLEMENTAL SCHEDULES FOR THE YEAR ENDED DECEMBER 31 , 2025 {15}------------------------------------------------ # SCHEDULE I #### WALTER GREENBLATT & ASSOCIATES, LLC #### COMPUTATION OF AGGREGATE INDEBTEDNESS AND NET CAPITAL PURSUANT TO RULE 15c3-1 #### AS OF DECEMBER 31 , 2025 | Total member's equity from statement of financial condition | \$ 43,531 | |------------------------------------------------------------------------------------------------------------------------------------------------|----------------------| | Total capital and allowable liabilities | 43,531 | | Total nonallowable assets from statement of financial condition | 24 601 | | Net capital before haircuts on securities positions | 18,930 | | Net capital | 18 930
\$ | | Aggregate indebtedness:
Total A.I. liabilities from statement of financial condition
Percentage of aggregate indebtedness to net capital | 63,602
\$
336% | | Computation of basic net capital requirement:
Minimum net capital required (6.67% of A.I.) | \$
4 240 | | Minimum dollar net capital requirement of reporting broker or dealer | 5 000
\$ | | Net capital requirement | 5 000
\$ | | Excess net capital | \$ 13 930 | There are no material differences between the computation of net capital presented above and the computation of net capital reported in the Company's unaudited Form X-17 A-5 filed as of December 31 , 2025. See Report oflndependent Registered Public Accounting Firm {16}------------------------------------------------ # SCHEDULE II #### WALTER GREENBLATT & ASSOCIATES, LLC ### COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS AND INFORMATION RELATED TO POSSESSION AND CONTROL REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION #### DECEMBER 31 , 2025 The Company is not claiming an exemption from SEA Rule 15c3-3, in reliance on footnote 74 to SEC Release 34-70073 and as discussed in Q&A 8 of the related FAQ issued by SEC staff In order to avail itself of this option, the Company has represented that it does not, and will not, hold customer funds or securities. {17}------------------------------------------------ ![](_page_17_Picture_0.jpeg) #### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** To the Member of Walter Greenblatt & Associates, LLC: We have reviewed management's statements, included in the accompanying Rule 15c3-3 Exemption Report pursuant to SEC Rule 17a-5, in which (1) Walter Greenblatt & Associates, LLC (the "Company") did not claim an exemption under paragraph (k) of 17 C.F.R. §240.15c3-3, and (2) the Company is filing this Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 because the Company limits its business activities exclusively to mergers and acquisitions and private placements of securities. In addition, the Company 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), did not carry accounts of or for customers and did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception. The Company's management is responsible for compliance with the provisions contemplated by Footnote 74 of SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 and related SEC Staff Frequently Asked Questions and its statements. Our review was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and , accordingly, included inquiries and other required procedures to obtain evidence about 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 the Company's business activities contemplated by Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5, and related SEC Staff Frequently Asked Questions. Hauppauge, New York February 27, 2026 {18}------------------------------------------------ #### WALTER GREENBLATT & ASSOCIATES, LLC #### EXEMPTION REPORT ## DECEMBER 31 , 2025 Walter Greenblatt & Associates, LLC (the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C.F.R. §240. 17a-5, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R. §240.17a-5( d)(I) and (4). To the best of its knowledge and belief, the Company states the following: - (1) The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240. 15c3-3, and - (2) The Company is filing this Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240. l 7a-5 because the Company limits its business activities exclusively to mergers and acquisitions and private placements of securities, 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) ofRule l 5c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company); (2) did not carry accounts of or for customers; and did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception. I, Walter Greenblatt,, swear (or affirm) that, to my best knowledge and belief, this Exemption Report is true and correct. Date: February 27, 2026 Walter Geenblatt CEO Walter Greenblatt & Associates, LLC Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.