# PCA CAPITAL SECURITIES, LLC X-17A-5 (2026-03-06) — Broker-dealer annual report - Company: PCA CAPITAL SECURITIES, LLC - Form: X-17A-5 - Filed: 2026-03-06 - Period: 2025-12-31 - Accession: 0001300496-26-000003 - CIK: 1300496 - File #: 8-66614 - Type: Broker-dealer - Material weakness: No - Auditor: Citrin Cooperman & Company - Auditor location: New York, NY - Contact: STEVE THOMPSON - Phone: 7328280202 - Email: sthompson@greensteinassociates.mm - Website: greensteinassociates.mm - Signed by: Gina Laversa (President) Original filing: https://www.sec.gov/Archives/edgar/data/1300496/000130049626000003/pca2025confidential_1.pdf --- {0}------------------------------------------------ # **REPORT ON AUDIT OF FINANCIAL STATEMENTS AND SUPPLEMENTAL INFORMATION AND REVIEW REPORT** #### **DECEMBER 31, 2025** *These financialstatements and schedules are deemed confidential pursuant to Subparagraph (e)(3) of rule 17a-5 of the Securities Exchange Commission* {1}------------------------------------------------ #### UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C.20549 OMB Number:3235{123 Expires: Nov. 30, 2026 Estimated average burden # ANNUAL REPORTS FORM X-17A-5 PART III | OMB Number:3235{123 | | |--------------------------|--| | Expires: Nov. 30, 2026 | | | Estimated average burden | | | hours per response: 1? | | | SEC FILE NUMBER | | | 8-66614 | | | | | FACING PAGE lnformation Required Pursuant to Rules \7a-5, L7a-t.Z, and L8a-7 under the Securities Exchange Act of 1934 FTLTNG FoR rHE pERroD BEGtNNtNc 0110112025 AND ENDING 1213112025 MM/DD/YY A. REGISTRANT IDENTIFICATION MM/DD/YY NAME OF FIRM: PCA TYPE OF REGISTRANT (check all applicable boxes): E Check lrere if respondent is also an oTC derivatives dealer E Broker-dealer n Security-based swap dealer [l Major security-based swap participant ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P'O. box no') # 900 Walt Whitman Rd., Suite 309 | | (No. and Street) | | | | | | |--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------|------------------------------------|------------|--|-------|--| | Melville | | | New York | | 11747 | | | (City) | (State) | | (Zip Code) | | | | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | | | | | Stephen Thompson | 732-828-0202 | sthompson@greensteinassociates.com | | | | | | (Name) | (Area Code - Telephone Nurtrber) | (Email Address) | | | | | | | B. ACCOUNTANT IDENTIFICATION | | | | | | | Citrin Cooperman & Company, LLP | (Narne - if individual, state last, first, and nriddle name) | | | | | | | Plaza
50 Rockefeller | New York | NY | 1 0020 | | | | | (Address) | | (State) | (Zip Code) | | | | | November 2,2005 | | 2468 | | | | | | (Date of | | | | | | | | | | | | | | | | * Claims for exemption from the requirement that the annual reports be covered by the reports of an independent public
accountantmustbesupportedbyastatementoffactsandcircumstancesreliedonastlrebasisoftheexemption. | | | See17 | | | | CFR 240.17a-5(e)(tXii), 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 s currently valid OMB control number. {2}------------------------------------------------ #### OATH OR AFFIRMATION Gina Laversa swear (or affirm) that, to the best of my knowledge and belief, the financial report pertaining to the firm of PCACapitalSecurities,LLC as of 12131 .zL, is true and correct. I further swear (or affirm) that neither the company nor any partner, officer, director, or equivalent person, as the case may be, has any proprietary interest in any account classified solely as that of a customer. | | Signature: \ \na \arenas | | |---------------------|--------------------------|--| | Title:
President | | | #### This filing\*\* contains (check all applicable boxes): - E (a) Statement of financial condition. - D (b) Notes to consolidated statement of financial condition. - E (c) Statenrent of incorne (loss) or, if there is other conrprehensive income in the period(s) presented, a statement of - comprehensive incotne (as defined in \$ 210.1-02 of Regulation S-X). - E (d) Statement of cash flows. - E (e) Staternent of changes in stockholders' or partners' or sole proprietor's equity. - n (f) Statement of changes in liabilities subordinated to claims of creditors. - E (g) Notes to coi-rsoiidatecl financial statements. - E (h) Computation of net capital under 17 CFR 240.15c3 -7 or 77 CFR 240.18a-1, as applicable. - tl (i) Computation of tangible net worth under 17 CFR 240.18a-2. - n fi) Computation for determination of custorner reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3. - tl (k) Computation for determination of security-based swap reserye requiretnents pursuant to Exhibit B to 17 CFR 240.15c3-3 or Exhibit A to 17 CFR 240.18a-4, as applicable. - tl (l) Cornputation for Deternrination of PAB Requirements under Exhibit A to 5 240.15c3-3. - n (m) lnformation relating to possession or control recluiremerrts for customers utrder 17 CFR 240.15c3-3. - tl (n) tnformation relating to possession or control requirements for security-based swap customers under 17 CFR 240.15c3-3(pl{2) or 17 CFR 240.18a-4, as applicable. - E (o) Reconciliations, inclucling appro;:riate explanations, of ttre FOCUS Report with contputation of net capital or tangible net worth under 17 CFR 24O.15c3-1,17 CFR 240.18a-1, or 17 CFR 24O.LBa-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 ntaterial differences exist. - tr (p) Summary of financial data for subsicliaries not consolidated in the statement of financial condition. - E (q) Oath or affirmation in accordance with 17 CFR 24A.\7a-5,17 CFR 24O.17a-12, or 17 CFR 24o.t8a--1, as applicable. - tl (r) Compliance report in accordance with 17 CFR24O.17a-5 or 17 CFR 240.18a-7, as applicable. - E (s) Exemption report in accordance with 17 CFR 24O.17a-5 or 17 CFR 240.1-8a-7, as applicable. - n (t) lndependent public accourrtant's report based orr an examirration of tlre statement of financial condition. - E (u) lndependent public accountant's report based on a n exarnination of the financial repoft or financial statetnetrts under 17 CFR 240.17a-5, 17 CFR 24O.18a-7 , or 17 CFR 24O.L7a-72, as applicable. - n (v) lndependent public accountant's report hasecl on an examirration of certain statements in the compliance report under 17 CFR 240.17a-5 or L7 CFR 240.18a-7, as applicable. - E (w) lndependent 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. - tl (x) Supplernental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-1e or 17 CFR 24O.17a-72, as applicable. - D (y) Report clescribing any material inadequacies found to exist or fourrcl to have existed since the date of tlre previous audit, or a statement that no material inaclequacies exist, under 17 CFR 24O.17 a-L2(kl. - n (z)other: - \*\*To request confidentiol treotment of ceftoin portions of this filing, see 17 Cf R 2aO.17o-5(e)(3) or 17 CFR 240.78a-7(d)(2), os opplicoble. {3}------------------------------------------------ ## **CONTENTS** # **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** 1 - 2 ### **AUDITED FINANCIAL STATEMENTS** | Statement
of
Financial
Condition | 3 | |-----------------------------------------------------------------------------|-------------| | Statement
of
Operations
and
Changes
in
Members'
Equity | 4 | | Statement
of
Cash
Flows | 5 | | Notes
to
the
Financial
Statements | 6
-
9 | ### **SUPPLEMENTAL INFORMATION** | Schedule I -
Computation
of
Net
Capital
under
SEC
Uniform
Net
Capital
Rule
15c3-1 | 10 | |----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----| | Schedule II -
Computation
for
Determination
of
Reserve
Requirements
and
Information for Possession or Control Requirements Pursuant
to
Rule
15c3-3
of
the
Securities
and
Exchange Commission | 11 | | REVIEW
REPORT
OF
INDEPENDENT
REGISTERED
PUBLIC
ACCOUNTING
FIRM | 12 | | Exemption
Report | 13 | {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) # REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Managing Members PCA Capital Securities, LLC ### Opinion on the Financial Statements We have audited the accompanying statement of financial condition of PCA Capital Securities, LLC as of December 31, 2025, and the related statements of operations and changes in members' 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 PCA Capital Securities, 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 PCA Capital Securities, LLC's management. Our responsibility is to express an opinion on PCA Capital Securities, LLC's financial statements based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) ("PCAOB") and are required to be independent with respect to PCA Capital Securities, LLC in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. We conducted our audit in accordance 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. {5}------------------------------------------------ ![](_page_5_Picture_0.jpeg) #### Auditor's Report on Supplemental Information The supplemental information contained in Schedules I and II has been subjected to audit procedures performed in conjunction with the audit of PCA Capital Securities, LLC's financial statements. The supplemental information is the responsibility of PCA Capital Securities, LLC's management. Our audit procedures included determining whether the supplemental information reconciles to the financial statements or the underlying accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the supplemental information. In forming our opinion on the supplemental information, we evaluated whether the supplemental information, including its form and content, is presented in conformity with 17 C.F.R. §240.17a–5. In our opinion, the supplemental information contained in Schedules I and II is fairly stated, in all material respects, in relation to the financial statements as a whole. We have served as PCA Capital Securities, LLC's auditor since 2023. New York, New York February 27, 2026 {6}------------------------------------------------ # **STATEMENT OF FINANCIAL CONDITION** ## **DECEMBER 31, 2025** | ASSETS | | |------------------------------------------|-----------------| | Cash | \$
110,052 | | Fees receivable | 1,257,930 | | Total Assets | \$
1,367,982 | | | | | LIABILITIES
AND
MEMBERS'
EQUITY | | | LIABILITIES
Accrued expenses | \$
26,557 | | MEMBERS' EQUITY | \$
1,341,425 | | Total Liabilities and Members' Equity | \$
1,367,982 | These financial statements and schedules are deemed confidential pursuant to subparagraph (e)(3) of Rule 17a-5 of the Securities Exchange Commission. {7}------------------------------------------------ # **STATEMENT OF OPERATIONS AND CHANGES IN MEMBERS' EQUITY FOR** # **THE YEAR ENDED DECEMBER 31, 2025** | REVENUES | | |------------------------------------------|-----------------| | Fee income | \$
1,257,930 | | EXPENSES | | | Professional fees | 43,780 | | Registration fees and operating expenses | 4,289 | | | | | Total Expenses | 48,069 | | | | | Net Income | 1,209,861 | | | | | Members' Equity –
January 1, 2025 | 131,564 | | | | | Members' Equity –
December 31, 2025 | \$
1,341,425 | These financial statements and schedules are deemed confidential pursuant to subparagraph (e)(3) of Rule 17a-5 of the Securities Exchange Commission. {8}------------------------------------------------ #### **STATEMENT OF CASH FLOWS** #### **FOR THE YEAR ENDED DECEMBER 31, 2025** #### **CASH FLOWS FROM OPERATING ACTIVITIES** | Net income | \$
1,209,861 | |----------------------------------------------------------------------------------|-----------------| | Adjustments to reconcile net income
to net cash used by operating activities: | | | Changes in operating assets and liabilities: | | | (Increase) in fees receivable | (1,257,930) | | (Decrease) in accrued expenses | (918) | | Net Cash (Used) by Operating Activities | (48,987) | | Cash -
January 1, 2025 | 159,039 | | Cash -
December 31, 2025 | \$
110,052 | These financial statements and schedules are deemed confidential pursuant to subparagraph (e)(3) of Rule 17a-5 of the Securities Exchange Commission. {9}------------------------------------------------ ### **NOTES TO THE FINANCIAL STATEMENTS** ### **DECEMBER 31, 2025** #### **1. ORGANIZATION AND NATURE OF BUSINESS** PCA Capital Securities, LLC (the "Company"), formed in the State of Delaware on June 30, 2004, is a broker-dealer registered with the Securities and Exchange Commission (the "SEC") and is a member of the Financial Industry Regulatory Authority ("FINRA"). The Company operates primarily as an agent that assists issuers in executing Equity Private Placements for which it earns fees. The members share profits and losses equally and each member's liability is limited. The Company continues until such time as it is terminated. #### **2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES** #### **a) Basis of Presentation** The Company's financial statements have been prepared in accordance with accounting principles generally accepted in the United States of America ("U.S. GAAP"). #### **b) Use of Estimates** The preparation of financial statements in conformity with US GAAP requires management to make estimates and assumptions that effect certain reported amounts and disclosures. Accordingly, actual results could differ from those estimates. #### **c) Revenue Recognition** The Company accounts for revenue in accordance with ASC 606, Revenue from Contracts with Customers ("ASC 606"), using the modified retrospective adoption method. Under ASC 606, revenues are recognized when control of the promised goods or services is transferred to the customer in an amount that reflects the consideration the Company expects to be entitled to in exchange for transferring those goods or services. Revenue is recognized based on the following five-step model: - · Identification of the contract with a customer - · Identification of the performance obligations in the contract - · Determination of the transaction price - · Allocation of the transaction price to the performance obligations in the contract - · Recognition of revenue when, or as, the Company satisfies a performance obligation #### **Fee Income** The Company's principal source of revenue is derived from referral fees earned for introducing investors to funds. Each distinct service listed on the agreements with asset managers is considered a performance obligation. The fees earned are allocated to each These financial statements and schedules are deemed confidential pursuant to subparagraph (e)(3) of Rule 17a-5 of the Securities Exchange Commission. {10}------------------------------------------------ ### **NOTES TO THE FINANCIAL STATEMENTS** #### **DECEMBER 31, 2025** distinct performance obligations and revenue is recognized when performance obligations are met. The Company's key performance obligation is met when the underlying information from the respective asset managers is received and authenticated. The Company is generally deemed to control the services; accordingly, it presents the revenues gross of the associated third-party costs. The Company evaluates its incremental contract costs related to revenue to determine if such costs are period costs or are capitalized costs. The Company's revenues are earned and recorded at a point in time. There is no set payment terms for the outstanding fees receivable from the related party. The timing between completion of the performance obligation and payment is typically not significant. There is no expected loss of collection, given the affiliated fund has already received the cash. #### **d) Income Taxes** No provision has been made for Federal or New York State ("NYS") income tax since the Company is treated like a partnership under the Internal Revenue Code and NYS Partnership tax law whereby its income will be taxed directly to its members. ASC Topic 740 clarifies the accounting for income taxes by prescribing a "more likely than not" recognition threshold that a tax position is required to meet before being recognized in, the financial statements. In addition, the guidance clarifies the measurement of uncertain tax positions, classification of interest and penalties, and requires additional disclosures on tax reserves. In accordance with ASC 740, *Income Taxes*, the Company is required to disclose unrecognized tax benefits resulting from uncertain tax positions. At December 31, 2025, the Company did not have any unrecognized tax benefits or liabilities. The Company operates in the United States and in state and local jurisdictions. There are presently no ongoing income tax examinations. #### **e) Broker Dealer – Single Reportable Segment** The Company is engaged in a single line of business as a securities broker-dealer, which is comprised of private placement of investments. The company has identified its President, Gina LaVersa, as the chief operating decision maker ("CODM"), who uses net income to evaluate the results of the business, predominantly in the forecasting process, to manage the Company. Additionally, the CODM uses excess net capital (see note 4), which is not a measure of profit and loss, to make operational decisions while maintaining capital adequacy, such as whether to reinvest profits or pay dividends. The Company's operations constitute a single operating segment and therefore, a single reportable segment, because the CODM manages the business activities using information of the Company as a whole. The accounting policies used to measure the profit and loss of the segment are the same as those described in the summary of significant accounting policies. The measurement of segment These financial statements and schedules are deemed confidential pursuant to subparagraph (e)(3) of Rule 17a-5 of the Securities Exchange Commission. {11}------------------------------------------------ #### **NOTES TO THE FINANCIAL STATEMENTS** #### **DECEMBER 31, 2025** assets is reported on the statement of financial condition as total assets. The segment revenue and significant expenses are included in the Company's Statement of Operations. #### **3. CONCENTRATION OF CREDIT RISK** The Company maintains cash in bank accounts which, at times, may exceed federally insured limits. The Company has not experienced any losses in such accounts and believes it is not exposed to any significant credit risk. #### **4. NET CAPITAL REQUIREMENTS** The Company is subject to the Securities and Exchange Commission Uniform Net Capital Rule (Rule 15c3-1), which requires the maintenance of minimum net capital and also requires that the ratio of aggregate indebtedness to net capital, both as defined, shall not exceed 15 to 1. At December 31, 2025, the Company had net capital of \$83,495,which was \$78,495 in excess of its required net capital of \$5,000. The Company's net capital ratio was 0.32 to 1. #### **5. RISKS AND UNCERTAINTIES** There are various direct and indirect risks that could impact the Company, such as a potential global economic slowdown, increase in interest rates, inflationary pressures, geopolitical situations, supply chain disruptions, and more. It is also impossible to predict the effect these will have on longer-term industrial output, potential changes in supply and demand, and its impact on the Company's liquidity, credit, customers, vendors, and counterparties. To help minimize the uncertainty of these items, management continues to explore how best to operate in this environment. #### **6. RELATED PARTY TRANSACTIONS** During the year ended December 31, 2025, the Company recorded \$1,257,930 of Fee Income from a fund that is managed by an affiliate of the Company. As of December 31, 2025 total receivables from the related party totaled \$1,257,930. The opening balance at December 31, 2024 was zero. These financial statements and schedules are deemed confidential pursuant to subparagraph (e)(3) of Rule 17a-5 of the Securities Exchange Commission. {12}------------------------------------------------ #### **NOTES TO THE FINANCIAL STATEMENTS** #### **DECEMBER 31, 2025** #### **7. SUBSEQUENT EVENTS** The Company has evaluated and noted no events or transactions that have occurred through February 27, 2026, the date the financial statements were available to be issued, that would require recognition or disclosure in the financial statements. {13}------------------------------------------------ **SUPPLEMENTAL INFORMATION** These financial statements and schedules are deemed confidential pursuant to subparagraph (e)(3) of Rule 17a-5 of the Securities Exchange Commission {14}------------------------------------------------ # **SCHEDULE I** ### **PCA CAPITAL SECURITIES, LLC** ### **COMPUTATION OF NET CAPITAL UNDER SEC UNIFORM NET CAPITAL RULE 15c3-1** ### **DECEMBER 31, 2025** | NET CAPITAL | | |------------------------------------------------|-----------------| | Total members' equity as of December 31, 2025 | \$
1,341,425 | | DEDUCTIONS AND/OR CHARGES | | | Fees receivable | 1,257,930 | | Net Capital | \$
83,495 | | MINIMUM NET CAPITAL REQUIRED (GREATER OF | | | 6 2/3% OF A.I. OR \$5,000) | \$
5,000 | | EXCESS NET CAPITAL | \$
78,495 | | TOTAL AGGREGATE INDEBTEDNESS | \$
26,557 | | RATIO OF AGGREGATE INDEBTEDNESS TO NET CAPITAL | 0.32:1 | There were no material differences between the audited Computation of Net Capital included above and the corresponding schedule included in the Company's unaudited December 31, 2025 Part IIA FOCUS filing. These financial statements and schedules are deemed confidential pursuant to subparagraph (e)(3) of Rule 17a-5 of the Securities Exchange Commission. {15}------------------------------------------------ ## **SCHEDULE II** #### **PCACAPITALSECURITIES,LLC** # **COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS AND INFORMATION FOR POSSESSION OR CONTROL REQUIREMENTS PURSUANT TO RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION** #### **DECEMBER 31, 2025** The Company limits its business activities pursuant to footnote 74 to SEC Release 34- 70073, and as discussed in Q & A 8 of the related FAQ issued by SEC staff. Accordingly, there are no items to report under the requirements of this rule. These financial statements and schedules are deemed confidential pursuant to subparagraph (e)(3) of Rule 17a-5 of the Securities Exchange commission. {16}------------------------------------------------ ![](_page_16_Picture_0.jpeg) # REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Managing Members PCA Capital Securities, LLC We have reviewed management's statements, included in the accompanying Exemption Report pursuant to SEC Rule 17a-5, in which (1) PCA Capital Securities, LLC did not claim an exemption under paragraph (k) of 17 C.F.R. §240.15c3-3, and (2) PCA Capital 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. § 240.17a-5 because PCA Capital Securities, LLC limits its business activities exclusively to private placements of investments. In addition, PCA Capital Securities, LLC did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers; and 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. PCA Capital Securities, LLC'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 PCA Capital Securities, LLC'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 PCA Capital Securities, LLC'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. New York, New York February 27, 2026 {17}------------------------------------------------ #### PCA CAPITAL SECURTTIES, LLC EXEMPTION REPORT PCA Capital Securities. LLC (thc "C)ompanr,") is a registered brokor-dealer subiect to rulo l7a-5 promulgatod br thc Securities and Exchange Cornrnission (17 C.F.R. \$240.17a-5. "Roports to bc nradc b1'cofiain brokers artd doalcrs"). This Ercmption Rcport was prepared as required b.v- 17 Cl F R. \$240.l7a--5(d) (l) ancl (a) To the best of its knorvledge and bclief. the Cornpany,states thc tbllorving: - ( 1) 'llo Companl' docs not claim an exemption undcr paragraph (k) of 17 C.F.R. s\240. l5c3- 3. and - (2) Thc Contpanf is filirrg this Exomption Rcport rclling on Footnoto 74 of SECI Roloasc No. 3"1-7007i adopting anrcndrncnts to I 7 C. F-. R. 240 I 7a-,i bocatrso tho Ciornpanl, I nrits its busiucss uctivitios to private placements of iuvostnrcnts; aucl thc flornltanl, (l) did not directly' or indirectlv receive. hold, or othonvise olr o funds or securities for or to customers. (2) did uot carrv- accorults of or for customcrs: and (3) did not canl PAB accounts (as defined in Rulc l5c3-3) throughout tho most rocont fiscal r,car r,rithout exception. PCA Capital Securities, LLC I- Gina LaVcrsa, s\voarthat. to tho bcst of rnv knoulodgc and bclicf. tl-ris Exemption Roport is trLlc Presi Februan 27.2026 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.