# ESL INVESTMENT SERVICES, LLC X-17A-5 (2026-02-24) — Broker-dealer annual report

- Company: ESL INVESTMENT SERVICES, LLC
- Form: X-17A-5
- Filed: 2026-02-24
- Period: 2025-12-31
- Accession: 0001347881-26-000002
- CIK: 1347881
- File #: 8-67195
- Type: Broker-dealer
- Material weakness: No
- Auditor: Baker Tilly US,LLP
- Auditor location: Portland, OR
- Contact: Pascal Roche
- Phone: 2127514422
- Email: proche@dfppartners.com
- Website: dfppartners.com
- Signed by: Leo Lacobelli (President)

Original filing: https://www.sec.gov/Archives/edgar/data/1347881/000134788126000002/isllc.pdf

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| SECURITIES AND EXCHANGE COMMISSION<br>Washington, D.C. 20549<br>UNITED STATES                                                                                                                                                                                                                                                                                                                                                 | hours per response: 12<br>Estimated average burden<br>Expires:<br>0MB Number: 3235--0123<br>0MB APPROVAL<br>Nov.<br>30, 2026 |
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| ANNUAL REPORTS<br>FORM X-17A-5<br>PART<br>Ill                                                                                                                                                                                                                                                                                                                                                                                 | SEC FILE NUMBER<br>8-67195                                                                                                   |
| FILING FOR THE PERIOD BEGINNING<br>Information Required Pursuant to Rules 17a-5, 17a-12, and lSa-7 under the Securities Exchange Act of 1934<br>0 1/01<br>FACING PAGE<br>/25<br>MM/DD/YY<br>AND ENDING 12/31 f                                                                                                                                                                                                                | MM/DD/YY<br>25                                                                                                               |
| A. REGISTRANT IDENTIFICATION                                                                                                                                                                                                                                                                                                                                                                                                  |                                                                                                                              |
| NAME oF FIRM: ESL Investment Services, LLC                                                                                                                                                                                                                                                                                                                                                                                    |                                                                                                                              |
| TYPE OF REGISTRANT (check all applicable boxes):<br>0 Broker-dealer<br>D Check here if respondent is also an OTC derivatives dealer<br>D Security-based swap dealer<br>□ Major security-based swap participant                                                                                                                                                                                                                |                                                                                                                              |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.)<br>225 Chestnut St,                                                                                                                                                                                                                                                                                                                                       |                                                                                                                              |
| (No. and Street)                                                                                                                                                                                                                                                                                                                                                                                                              |                                                                                                                              |
| Rochester<br>NY                                                                                                                                                                                                                                                                                                                                                                                                               | 14604                                                                                                                        |
| (City)<br>(State)                                                                                                                                                                                                                                                                                                                                                                                                             | (Zip Code)                                                                                                                   |
| PERSON TO CONTACT WITH REGARD TO THIS FILING                                                                                                                                                                                                                                                                                                                                                                                  |                                                                                                                              |
| Pascal Roche<br>212-751-4422                                                                                                                                                                                                                                                                                                                                                                                                  | proche@dfppartners.com                                                                                                       |
| (Name)<br>(Area Code -<br>Telephone Number)                                                                                                                                                                                                                                                                                                                                                                                   | (Email Address)                                                                                                              |
| B. ACCOUNTANT IDENTIFICATION                                                                                                                                                                                                                                                                                                                                                                                                  |                                                                                                                              |
| INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*<br>Baker Tilly US, LLP                                                                                                                                                                                                                                                                                                                              |                                                                                                                              |
| 805 SW Broadway, Suite 1200<br>(Name -<br>if individual, state last, first, and middle name)<br>Portland<br>OR                                                                                                                                                                                                                                                                                                                | 97205                                                                                                                        |
| (Address)<br>(City)<br>659<br>(State)                                                                                                                                                                                                                                                                                                                                                                                         | (Zip Code)                                                                                                                   |
| FOR OFFICIAL USE ONLY                                                                                                                                                                                                                                                                                                                                                                                                         |                                                                                                                              |
| Persons who are to respond to the collection of information contained in this form are not required to respond unless the form<br>* Claims for exemption from the requirement that the annual reports be covered by the reports of an independent public<br>CFR 240.17a-5(e)(1)(ii), if applicable.<br>accountant must be supported by a statement of facts and circumstances relied on as the basis of the exemption. See 17 |                                                                                                                              |
| displays a currently valid 0MB control number.                                                                                                                                                                                                                                                                                                                                                                                |                                                                                                                              |

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#### OATH OR AFFIRMATION

I, Leo Iacobelli swear (or affirm) that, to the best of my knowledge and belief, the financial report pertaining to the firm of ESL Investment Services, LLC as of 12/31 \_\_\_ \_, 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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# **This filing\*\* contains (check all applicable boxes):**

- ~ (a} Statement of financial condition.
- □ (b) Notes to consolidated statement of financial condition.
- ~ (c) Statement of income (loss} or, if there is other comprehensive income in the period(s) presented, a statement of
- comprehensive income (as defined in § 210.1-02 of Regulation S-X).
- ~ (d} Statement of cash flows.
- ~ (e) Statement of changes in stockholders1 or partners' or sole proprietor's equity.
- □ (f} Statement of changes in liabilities subordinated to claims of creditors.
- ~ (g) Notes to consolidated financial statements.
- ~ (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.lBa-1, as applicable.
- □ (i) Computation of tangible net worth under 17 CFR 240.18a-2.
- □ 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 240.18a-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 240.15c3-3{p}(2) or 17 CFR 240.18a-4, as applicable.
- ~ (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capital or tangible net 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. □ (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition.
- 
- ~ (q) Oath or affirmation in accordance with 17 CFR 2.40.17a-5, 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable. □ (r} Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- ~ (s} Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- D (t) Independent public accountant's report based on an examination of the statement of financial condition.
- ~ ( u} Independent public accountant's report based on an examination of the financial report or financial statements under 17
- CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable.
- D M Independent public accountant's report based on an examination of certain statements in the compliance report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- ~ (w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- ~ (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-1e or 17 CFR 240.17a-12, as applicable.
- □ (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.

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## **ESL INVESTMENT SERVICES, LLC (A Wholly Owned Subsidiary of ESL Federal Credit Union)**

**Financial Statements and Supplemental Information December 31, 2025** 

**Together with Report of Independent Registered Public Accounting Firm** 

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### **Table of Contents**

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# **Report of Independent Registered Public Accounting Firm**

ESL Investment Services, LLC The Members and the CUSO Oversight Committee

# **Opinion on the Financial Statements**

Services, LLC (the Company) as of December 31, 2025 We have audited the accompanying consolidated statement of financial condition of ESL Investment *,* the related consolidated statements of operations changes in member's equity, and cash flows for the year then ended, and the related accounting principles generally accepted in the United States of America. 2025, and the results of its operations and its cash flows for the year then ended, in conformity with present fairly, in all material respects, the financial position of the Company as of December 31, notes (collectively, referred to as the financial statements). In our opinion, the financial statements

#### **Basis for Opinion**

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

Company's internal control over financial reporting. Accordingly, we express no such opinion. financial reporting but not for the purpose of expressing an opinion on the effectiveness of the reporting. As part of our audit, we are required to obtain an understanding of internal control over required to have, nor were we engaged to perform, an audit of its internal control over financial statements are free of material misstatement, whether due to error or fraud. The Company is not that we plan and perform the audit to obtain reasonable assurance about whether the financial We conducted our audit in accordance with the standards of the PCAOB. Those standards require

financial statements. We believe that our audit provides a reasonable basis for our opinion. significant estimates made by management, as well as evaluating the overall presentation of the the financial statements. Our audit also included evaluating the accounting principles used and procedures included examining, on a test basis, evidence regarding the amounts and disclosures in statements, whether due to error or fraud, and performing procedures to respond to those risks. Such Our audit included performing procedures to assess the risks of material misstatement of the financial

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# **Opinion on the Supplementary Information**

Indebtedness is fairly stated in all material respects in relation to the financial statements as a whole. 17 C.F.R. §240.17a-5. In our opinion, the information in Computation of Net Capital and Aggregate and Aggregate Indebtedness, including its form and content, is presented in conformity with and Aggregate Indebtedness, we evaluated whether the information in Computation of Net Capital and Aggregate Indebtedness. In forming our opinion on the information in Computation of Net Capital to test the completeness and accuracy of the information presented in Computation of Net Capital statements or the underlying accounting and other records, as applicable, and performing procedures the information in Computation of Net Capital and Aggregate Indebtedness reconciles to the financial the responsibility of the Company's management. Our audit procedures include determining whether financial statements. The information in Computation of Net Capital and Aggregate Indebtedness is been subjected to audit procedures performed in conjunction with the audit of the Company's The supplementary information in the Computation of Net Capital and Aggregate Indebtedness has

Portland, O regon February 20, 2026

We have served as the Company's auditor since 2017.

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| December 31, 2025<br>Consolidated Statement of Financial Condition<br>(A Wholly Owned Subsidiary of ESL Federal Credit Union)<br>ESL Investment Services, LLC |                                             |  |
|---------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------|--|
| ASSETS                                                                                                                                                        |                                             |  |
| Securities owned, at fair value<br>Cash and Cash equivalents                                                                                                  | 7,969,341<br>292,191                        |  |
| Other assets                                                                                                                                                  | 1,968,326                                   |  |
| Property and equipment, net<br>Operating lease - right-of-use asset, net<br>Other intangible assets, net<br>Goodwill                                          | 3,963,585<br>2,309,223<br>719,688<br>44,627 |  |
| Total assets                                                                                                                                                  | \$<br>17,266,981                            |  |
| LIABILITIES AND MEMBER'S EQUITY                                                                                                                               |                                             |  |
| LIABILITIES:<br>Operating lease - liability<br>Accounts payable and accrued expenses                                                                          | \$<br>2,853,196<br>765,234                  |  |
| Total liabilities                                                                                                                                             | 3,618,430                                   |  |
| COMMITMENTS (Note 5)                                                                                                                                          |                                             |  |
| MEMBER'S EQUITY<br>Total member's equity                                                                                                                      | 13,648,551                                  |  |
| Total liabilities and member's equity                                                                                                                         | \$<br>17,266,981                            |  |
|                                                                                                                                                               |                                             |  |
|                                                                                                                                                               |                                             |  |

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| ESL Investment Services, LLC                            |
|---------------------------------------------------------|
| (A Wholly Owned Subsidiary of ESL Federal Credit Union) |
| Consolidated Statement of Operations                    |
| Year ended December 31, 2025                            |

| NET INCOME<br>8,579,355 | Total operating expenses<br>19,422,686 | Marketing and promotion<br>Occupancy<br>142,652<br>461,249 | General and administrative<br>Depreciation and amortization<br>533,169<br>502,380 | OPERATING EXPENSES:<br>Origination and servicing<br>Professional and outside services<br>Salaries, commissions, and benefits<br>15,091,477<br>1,171,240<br>1,520,519 | Total revenues<br>28,002,041 | Other income<br>Gain on securities owned<br>Advisory income<br>5,439,359<br>7,462,569<br>494,393 | REVENUES:<br>Commission and fee revenue<br>\$<br>14,605,720 |
|-------------------------|----------------------------------------|------------------------------------------------------------|-----------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------|--------------------------------------------------------------------------------------------------|-------------------------------------------------------------|
|-------------------------|----------------------------------------|------------------------------------------------------------|-----------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------|--------------------------------------------------------------------------------------------------|-------------------------------------------------------------|

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#### **Year ended December 31, 2025 Consolidated Statement of Changes in Member's Equity (A Wholly Owned Subsidiary of ESL Federal Credit Union) ESL Investment Services, LLC**

|                                | Accumulated<br>Earnings | Capital         | Total            |
|--------------------------------|-------------------------|-----------------|------------------|
| BALANCE, JANUARY 1, 2025       | \$<br>54,677,710        | \$<br>1,500,000 | \$<br>56,177,710 |
| Net income                     | 8,579,355               | -               | 8,579,355        |
| In-Kind transfer of securities | (44,108,514)            | -               | (44,108,514)     |
| Cash distribution              | (7,000,000)             | -               | (7,000,000)      |
| BALANCE, DECEMBER 31, 2025     | \$<br>12,148,551        | \$<br>1,500,000 | \$<br>13,648,551 |

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| Year ended December 31, 2025<br>Consolidated Statement of Cash Flows<br>(A Wholly Owned Subsidiary of ESL Federal Credit Union)<br>ESL Investment Services, LLC |                                     |
|-----------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------|
|                                                                                                                                                                 |                                     |
| CASH FLOWS FROM OPERATING ACTIVITIES:<br>Adjustments to reconcile net income to net cash<br>Net income                                                          | ,579,355                            |
| Net unrealized (gain) on investments<br>from operating activities:                                                                                              | (4,905,248)                         |
| Amortization of acquired intangibles<br>Depreciation expense                                                                                                    | 480,310<br>22,070                   |
| Net change in assets and liabilities:<br>Amortization of right-of-use asset<br>Increase in securities owned, at fair value                                      | (1,796,616)<br>184,075              |
| Decrease in accounts payable and accrued expenses<br>Decrease in lease liability<br>Increase in other assets                                                    | (157,901)<br>(188,602)<br>(177,278) |
| Net cash provided by operating activities                                                                                                                       | 2,040,165                           |
| CASH FLOWS FROM INVESTING ACTIVITIES;<br>Purchase of property, plant & equipment                                                                                | (16,670)                            |
| Net cash used in investing activities                                                                                                                           | (16,670)                            |
| CASH FLOWS FROM FINANCING ACTIVITIES;<br>Cash distribution                                                                                                      | (7,000,000)                         |
| Net cash used in financing activities                                                                                                                           | (7,000,000)                         |
| Cash and cash equivalents at beginning of the year<br>Decrease in cash and cash equivalents                                                                     | 12,945,846<br>(4,976,505)           |
| Cash and cash equivalents at end of the year                                                                                                                    | <br>7,969,341                       |
| SCHEDULE OF NONCASH FINANCING ACTIVITIES<br>In-Kind transfer of securities                                                                                      | (44,108,514)                        |
|                                                                                                                                                                 |                                     |

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#### **Note 1 – The Organization**

ESL Investment Services, LLC (the "Company") is a limi ted-purpose securities broker-dealer, registered with the Securities and Exchange Commission pursuant to the Securities Exchange Act of 1934. The subsidiary of ESL Federal Credit Union (the "Credit Company is a wholly owned subsidiary of ESL HoldCo, LLC ("HoldCo"). HoldCo is a wholly owned Union"). The Company was originally incorporated in 1996 with operations beginning on January 1, 1997. The Company was established by the Credit Union to provide investment management, financial planning, and insurance solutions primarily to Credit Union members in the Rochester, New York area.

The consolidated financial statements of the Com pany include the accounts of its wholly owned subsidiary Cooper/Haims Advisors, LLC ("CHA"), a registered investment advisor located in Victor, New York providing investment advisory, financial planning, and tax services to high-net-worth clients.

The Company does not claim an exemption under paragraph (k) of 17 C.F.R. §240.15c3-3 and 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-5 (Footnote 74). The Company limits its business activities to receiving transactionbased referral fees and trades securities for its own account. The Company does not accept customer funds and will not have possession of any customer funds or securities in connection with our activities and therefore the Company is not required to prepare the determination of reserve requirements for brokers or dealers.

#### **Note 2 – Summary of Sign ificant Accounting Policies**

#### **Basis of Accounting**

The consolidated financial statements of the Company have been prepared in conformity with accounting principles generally accepted in the United States of America (U.S. GAAP).

#### **Basis of Consolidation**

The accompanying consolidated financial statements include the accounts of the Company, and its wholly owned subsidiary, CHA. All the intercompany balances and transactions have been eliminated in consolidation.

### **Cash and Cash Equivalents**

Cash and cash equivalents include deposits with the Credit Union, and other highly liquid investments with original maturities of less than three months, that are not held for sale in the ordinary course of business. Balances with these financial institutions exceeded federally insured limits on December 31, 2025. The Company has not experienced any losses related to cash and cash equivalents and believes it is not exposed to any significant credit risk with respect to these balances.

#### **Securities Owned**

are recorded on the trade date and determined using the specific identification method. value, with unrealized gains and losses included in earnings. Gains and losses on the sale of securities The Company has classified its investments as trading securities. Trading securities are recorded at fair

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## **Note 2 – Summary of Significan t Accounting Policies (continued)**

#### **Investment Risk**

The Company invests in various types of investment securities. Investment securities are exposed to will occur in the near term and that such change co investment securities, it is at least reasonably possible that changes in the values of investment securities various risks, such as interest rate, market, and credit risk. Due to the level of risk associated with certain uld affect the amounts reported in the accompanying financial statements.

#### **Fair Value Measurement**

U.S. GAAP establishes a fair value hierarchy for valuat ion inputs that gives the highest priority to quoted prices in active markets for identical assets or liabilities and the lowest priority to unobservable inputs, as follows:

- x **Level 1 Inputs** – Unadjusted quoted prices in active markets for identical assets or liabilities that are accessible at the measurement date.
- x **Level 2 Inputs** – Inputs other than quoted prices that are observable for the asset or liability, either markets, quoted prices for identical or similar assets directly or indirectly. These might include quoted prices for similar assets or liabilities in active or liabilities in markets that are not active, inputs other than quoted prices that are observable for the asset or liability (such as interest rates, corroborated by market data by correlation or other means. volatilities, prepayment speeds, credit risks, etc.) or inputs that are derived principally from or
- x **Level 3 Inputs** – Unobservable inputs for determining the fair values of assets or liabilities that reflect an entity's own assumptions about the assumptions that market participants would use in pricing the assets or liabilities.

The availability of observable inputs can vary from security to security and is affected by a wide variety of factors, including, for example, the type of security, the liquidity of markets, and other characteristics particular to the security. To the extent that valuation is based on models or inputs that are less observable or unobservable in the market, the determination of fair value requires more judgement. Accordingly, the degree of judgement exercised in determining fair value is greatest for instruments categorized in Level 3.

measurement falls in its entirety is determined based on cases, for disclosure purposes, the level in the fair value hierarchy within which the fair value The inputs used to measure fair value may fall into different levels of the fair value hierarchy. In such the lowest level input that is significant to the fair value measurement in its entirety.

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## **Note 2 – Summary of Significan t Accounting Policies (continued)**

#### **Property and Equipment**

years using the straight-line method. Leasehold im Property and equipment are stated at cost and depreciated over useful lives ranging from three to ten provements are amortized using the straight-line method over the period of the lease or the estimated life of the property, whichever is shorter.

# **Goodwill and Other Intangible Assets, net**

Goodwill represents the cost in excess of fair va lue of net assets acquired (including identifiable intangibles) in transactions accounted for as business combinations. Goodwill is tested annually for impairment and more frequently if circumstances exist that indicate it is more-likely-than-not that the fair internal projections of future cash flows and operating plans. value is below the carrying value. The annual impairment test is based on various assumptions and

Other intangible assets include premium paid for ac quisition of customer list and other intangibles. estimated economic benefits received. Intangibles other than goodwill, which are determined to have finite lives, are amortized based on the

#### **Revenue Recognition**

Revenues are recognized when control of the promised services is transferred to customers, in an amount that reflects the consideration the Company expects to be entitled to in exchange for those services.

## *Commission and Fee Revenue*

Commission revenue relates primarily to the sale of mu tual funds, annuities, life insurance, and other unaffiliated entity and a registered clearing brok security products. These products are offered to customers through LPL Financial ("LPL"), an er-dealer, which compensates the Company for each sale based upon a contractual commission schedule. Fee revenue is earned in the form of management fees assessed on managed accounts offered through LPL's advisory platform.

products is accrued monthly to properly record the Commission revenue from the sale of mutual funds, annuities, life insurance, and other security revenues in the month they are earned. The fee revenue assessed on managed accounts is earned in the form of management fees and is recorded in the month in which the service is being performed.

performance obligation as the referral is made, howev to a third-party broker and that third-party securities broker. The Company has satisfied its Commissions and fees arise from transactions between a consumer that the Company has referred er the revenue is subject to variable constraints until a transaction occurs. As transactions between those two parties occur, the Company receives a portion of the revenues generated by the third-party securities broker as the variable constraint has been lifted.

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## **Note 2 – Summary of Significan t Accounting Policies (continued)**

#### *Advisory Fees*

The Company provides investment advisory services on an ongoing basis. The Company believes the performance obligation for providing advisory services is satisfied over time because the on a percentage applied to the customer's assets customer is receiving and consuming the benefits as they are provided. Fee arrangements are based under management. Fees are received quarterly and are recognized as revenue at that point in time as they relate specifically to the services provided in that period, which are distinct from the services provided in other periods.

#### *Trading Profits*

Trading profits include investment income, realized gains and losses from trading activities and unrealized gains and losses on securities owned by the Company.

economy and its impact on financial markets. The economic conditions which affect the Company's revenue are related to overall trends in the

#### **Classification**

The activities of the Company generally do not invo lve a business cycle since the realization of assets and the liquidation of liabilities are usually dependent on the underlying circumstances of the Company's customers. Accordingly, the classification of current assets and current liabilities is not considered appropriate and has been omitted from the statements of financial condition.

#### **Income Taxes**

The Company elected to be taxed as a Limited Liability Corporation ("LLC"), which provides that the LLC passes on all income and expenses to its sole member, HoldCo, to be taxed at the member level. HoldCo passes on all income and expenses to its sole member, the Credit Union. The Credit Union is a federally chartered credit union with the National Credit Union Administration, and as such, is not subject to taxes under state or federal laws.

#### **Contract Balances**

there is an unconditional right to payment, accordin The Company's timing of revenue recognition may differ from the timing of customer payments. When g to the terms of the contract, the Company records a receivable. For contracts with unsatisfied performance obligations, the Company records deferred revenue until the performance obligations are satisfied. Contracts with no outstanding performance obligations are recognized as revenue.

Statement of Financial Condition. At different points December 31, 2025 and 2024, respectively. The Company includes such balances in other assets in the The Company had receivables related to contracts from customers of \$1,841,095 and \$1,598,696 at during the year, the Company has deferred revenue related to unrecognized engagement fees where the performance obligations have not yet been satisfied. There were no balances of deferred revenue as of December 31, 2025 and 2024.

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## **Note 2 – Summary of Significan t Accounting Policies (continued)**

## **Allowances for Credit Losses**

The allowance for credit losses is based on the Comp any's expectation of the collectability of revenue from contracts with customers, including fees receivable utilizing the current expected credit loss framework. The Company considers factors such as historical experience, credit quality, age of balances, and current and future economic conditions that may affect the Company's expectation of the collectability associated with fees receivable is not significant in determining the allowance for credit losses. The Company's expectation is that the credit risk until they are 90 days past due on the contractual arrangement and expectation of collection in accordance with industry standards. Management does not believe that an allowance is required as of December 31, 2025.

#### **Leases**

Operating lease right-of-use assets and liabilities are recorded at the lease commencement date based on the present value of the lease payments to be made over the lease term using an estimated incremental borrowing rate. The Company expenses rent monthly on a straight-line basis, as a reduction to the right-of-use asset. Rent expense is included in occupancy expenses in the accompanying consolidated statement of operations (Note 5).

#### **Statement of Cash Flows**

For purposes of the statement of cash flows, the Comp any has defined cash equivalents as highly liquid investments, with original maturities of less than three months, that are not held-for-sale in the ordinary course of business.

#### **Estimates**

accompanying notes. Actual results could differ from those estimates. estimates and assumptions that affect the amounts reported in the financial statements and the The preparation of financial statements in conformity with U.S. GAAP requires management to make

#### **Advertising Costs**

totaled \$142,652 in 2025 and is included in the Advertising costs are expensed as incurred by the Company. The Company's advertising expense marketing and promotion expense in the accompanying statement of income.

#### **Segment Reporting**

The Company operates a Limited-Purpose Broker De aler and Registered Investment Advisor. The clients. The Limited-Purpose Broker Dealer se Company structures the operating segments according to its clients and the services provided to those gment provides investment management, financial services to high-net-worth clients. Registered Investment Advisor segment provides investment advisory, financial planning, and tax planning, and insurance solutions primarily to Credit Union members in Rochester, New York area. The Revenues and expenses are attributed to the two segments based on which segment services the client. As of December 31, 2025, the Company has determined that both operating decision maker evaluates performance and allocates resources (Note 11). segments are reportable. We have disclosed the segment information consistent with the way our chief

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## **Note 3 – Property and Equipment**

Property and equipment as of December 31, 2025, consisted of the following:

|        | Less: Accumulated depreciation | Construction in Progress<br>Software<br>Computer equipment<br>Leasehold improvements |
|--------|--------------------------------|--------------------------------------------------------------------------------------|
| \$     |                                | \$                                                                                   |
| 44,627 | (369,347)                      | 413,974<br>195,455<br>164,907<br>16,670<br>36,942                                    |

Depreciation expense totaled \$22,070 for the year ended December 31, 2025.

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# **Note 4 – Goodwill and Other Intangible Assets**

The goodwill of \$2,309,223 represents the future ec onomic benefit expected to be recognized from combining the operations of the Company and CHA, including expected synergies and operating achieve as an exempt organization vis-à-vis market efficiencies. Additionally, the goodwill represents the incremental cash flows that the Company will participant (for fair value purposes, assumed to be tax-paying entities) over the course of its ownership of CHA.

Intangible assets as of December 31 , 2025, consisted of the following:

|                                        | Carrying Value                        |             | Period (in years)<br>Amortization<br>Weighted |
|----------------------------------------|---------------------------------------|-------------|-----------------------------------------------|
| Customer lists in place                | \$                                    | 6,408,900   | 9                                             |
| Trademarks                             |                                       | 424,400     | 2                                             |
| Non-compete agreements                 |                                       | 575,500     | 0                                             |
| Purchased Services                     |                                       | 70,000      | 0                                             |
|                                        |                                       | 7,478,800   |                                               |
| Less: Accumulated amortization         |                                       | (3,515,215) |                                               |
|                                        | \$                                    | 3,963,585   |                                               |
| Amortization expense totaled \$480,310 | for the year ended December 31, 2025. |             |                                               |
|                                        |                                       |             |                                               |

Estimated amortization expense for the years ended December 31, are as follows:

| Thereafter | 2030    | 2029    | 2028    | 2027    | 2026    |
|------------|---------|---------|---------|---------|---------|
|            |         |         |         |         | \$      |
| 1,734,447  | 427,260 | 427,260 | 427,260 | 467,048 | 480,310 |

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

#### **Note 5 – Commitments**

#### **Leases**

The Company leases office space under non-cancelab le leases. The leases are all classified as operating primarily due to the amount of time such spaces are occupied relative to the underlying asset's The third-party operating leases contain renewal op useful lives. Additional space for the Company's activities is obtained from the Credit Union (see Note 7). tions and provisions requiring the Company to pay property taxes and operating expenses over base period amounts, most of which are not included in the measurement of the right-of-use assets as they are not considered reasonably certain of estimable value. The third-party leases also contain escalation clauses calling for rental payments to be adjusted for increases in price indices.

The Company's operating lease costs for the year ended December 31, 2025, totaled \$231,521.

Future minimum rental commitments under the non-cancelable operating leases are as follows for each of the years ending December 31:

| 2026                                                                  | \$<br>228,609 |
|-----------------------------------------------------------------------|---------------|
| 2027                                                                  | 215,930       |
| 2028                                                                  | 220,248       |
| 2029                                                                  | 130,277       |
| 2030                                                                  | -             |
| Total lease payments                                                  | 795,064       |
| Less: present value discount at December 31, 2025                     | 29,830        |
| Total present value of lease liability at December 31, 2025           | \$<br>765,234 |
| Lease term and discount rate as of December 31, 2025, are as follows: |               |
| Weighted-average remaining lease term (years)                         | 3.52          |

Weighted-average discount rate 2.22%

Cash flow supplemental information for the year ended December 31, 2025, is as follows:

| Right-of-use assets obtained in exchange for lease obligations | Operating cash flows paid for operating leases<br>\$ | Cash paid for amounts included in the measurement of lease liab<br>ility |
|----------------------------------------------------------------|------------------------------------------------------|--------------------------------------------------------------------------|
|                                                                | 236,048                                              |                                                                          |

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

### **Note 6 – Employee Benefits**

## **Defined Contribution Retirement Plan**

The Credit Union also sponsors a defined contribution plan that covers substantially all of its and the Company's employees who meet certain age requirements. The Credit Union matches 100% of the first year and were employed through December 31 2.5% non-elective lump-sum contribution to eligible participants who have worked 1,000 hours in that 1% and 50% of the next 5% of participant contributions. In addition, the Credit Union makes an annual st. The non-elective contribution is subject to a 2-year cliff vesting schedule. The Credit Union allocates a portion of the annual expense to the Company based on relative compensation levels.

For the year ended December 31, 2025, the Company recognized defined contribution plan costs of \$675,440.

# **Post-Retirement Insurance Benefit Plan**

Union benefit plan. The Credit Union allocates a po The Company provides certain medical and healthcare benefits to qualifying retirees under the Credit rtion of the annual expense of the plan to the insurance income of \$15,120, in conjunction with this plan. Company based on headcount. For the year ended December 31, 2025, the Company recognized

The income related to these benefits is included in salaries, commissions, and benefits on the statement of operations.

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

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

Services, LLC ("Trust"), another wholly owned subsidiary The Company generates revenue through purchased services from the Credit Union and ESL Trust of the Credit Union. The services provided are under the agreements set forth between the parties and pricing is determined based on arm's length negotiations. Revenue generated from these transactions is recognized in accordance with the Company's revenue recognition policy (see Note 2).

As of December 31, 2025, the Company has recognized other income of \$393,650 derived from services purchased from this relationship.

The Company's investment portfolio is managed by Trust. Under this arrangement, Trust executes Company that, as of December 31, 2025, had a fair transactions in compliance with its standard policies and procedures. Trust managed investments for the market value of \$292,191. Trust managed cash equivalents that had a balance of \$8,691 as of December 31, 2025. For the year ended December 31, 2025, the Company recognized investment management expense of \$66,909 from this relationship with professional and outside services.

Pursuant to agreements between th e parties, the Company is charged for certain expense allocations, including professional and administrative services provided by the Credit Union. During the year ended following: December 31, 2025, related-party costs associated with such expense allocations consisted of the

| 188,904       | Occupancy                         |
|---------------|-----------------------------------|
| 140,172       | Marketing and promotion           |
| \$<br>973,152 | Professional and outside services |
|               |                                   |

1,302,228 \$

The Company's qualifying personnel are covered under defined-benefit, other benefits, medical, dental, allocates a portion of expense under these pl disability, and workers' compensation insurance plans sponsored by the Credit Union. The Credit Union ans to the Company based on headcount and compensation. For the year ended December 31, 2025, the Company was allocated costs of \$575,451. The expense related to these benefits is included in salaries, commissions, and benefits on the statement

of income.

During the year ended December 31, 2025, the Company made capital distributions totaling \$51,108,514. This total consisted of two distributions, including (i) \$7,000,000 in cash and (ii) an in-kind transfer of equity securities with a fair value of \$44,108,514. Both were distributed from accumulated earnings to the Company's parent, HoldCo, and are disclosed accordingly in the statement of changes in ownership equity.

At December 31, 2025, the Company had cash balanc es with the Credit Union in the amount of \$6,582,766.

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

# **Note 8 – Fair Value of Financial Instruments**

# **Financial Instruments Recorded at Fair Value on a Recurring Basis**

The Company's securities owned are measured at fair value on a recurring basis utilizing the following input levels at December 31, 2025:

|                                 | Level 1       | Level 2 | Level 3 |   | Total         |
|---------------------------------|---------------|---------|---------|---|---------------|
| Mutual Funds and ETFs<br>Equity |               |         |         |   |               |
| Domestic                        | \$<br>222,692 | \$<br>- | \$      | - | \$<br>222,692 |
| International                   | 49,788        | -       |         | - | 49,788        |
| Fixed Income<br>Domestic        | 19,711        | -       |         | - | 19,711        |
|                                 | \$<br>292,191 | \$<br>- | \$      | - | \$<br>292,191 |
|                                 |               |         |         |   |               |

Fair values for securities owned are based on quoted market prices.

# **Note 9 – Off-Balance Sheet Risk and Concentration of Credit Risk**

other broker-dealer carries all the accounts of th As discussed in Note 2, the Company's customers' securities transactions are executed by LPL. This e customers of the Company and is responsible for execution, collection of payment of funds, and receipt and delivery of securities relative to customer transactions.

## **Note 10 – Net Capital Requirements**

15c3-1), which requires the maintenance of a minimum am The Company is subject to the Securities and Exchange Commission Uniform Net Capital Rule (Rule ount of net capital and requires that the ratio of aggregate indebtedness to net capital, both as defined, shall not exceed 15 to 1. Rule 15c3-1 also provides that equity capital may not be withdrawn or cash dividends paid if the resulting net ratio would exceed 10 to 1. At December 31, 2025, the Company had net capital of \$841,897 which was \$732,510 in excess of its required net capital of \$109,387. Required net capital is computed as the greater of \$100,000 or 6 2/3% of aggregate indebtedness. The Company's ratio of aggregate indebtedness to net capital ratio was 1.95 to 1.

 

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

## **Note 11 – Segment Reporting**

chief operating decision maker, based upon informati The Company's segments are determined by the Director of Wealth Management, who is the designated on provided about the clients served and services offered. They are also distinguished by the level of information provided to the chief operating decision maker, who uses such information to review the performance of the various components of the business. The chief operating decision maker assesses the financial performance of the Company's business expenses and net income. The chief operating decision components and in determining the allocation of resources by evaluating revenue streams, significant maker uses revenue streams to evaluate services pricing compensation levels for certain employees.

back to the accompanying statem Intercompany balances and transactions between segments are eliminated and figures presented tie ents. For the year ended December 31, 2025, this includes a \$2,000,000 equity distribution from CHA to ESL Investment Services.

Accounting policies for segments are the same as those described in Note 1. Transactions among segments are made at fair value. Information reported internally for performance assessment by the chief operating decision maker follows, inclusive of reconciliation of significant segments totals to the financial statement:

| REVENUES:                                     | ESL Investment Services, LLC | Cooper/Haims Advisors, LLC |
|-----------------------------------------------|------------------------------|----------------------------|
| Advisory income<br>Commission and fee revenue | \$<br>14,605,721<br>505,329  | \$<br>6,957,240<br>-       |
| Other income<br>Gain on securities owned      | 5,439,358<br>168,473         | 325,920<br>-               |
| Total revenues                                | 20,718,881                   | 7,283,160                  |
| OPERATING EXPENSES:                           |                              |                            |
| Salaries and benefits                         | 4,708,401                    | 3,859,444                  |
| Commissions                                   | 5,428,900                    | 1,094,732                  |
| Professional and outside services             | 859,664                      | 660,855                    |
| Origination and servicing                     | 1,139,145                    | 32,095                     |
| Depreciation and amortization                 | 60,744                       | 441,636                    |
| General and administrative                    | 362,085                      | 171,084                    |
| Occupancy                                     | 236,187                      | 225,062                    |
| Marketing and promotion                       | 126,156                      | 16,496                     |
| Total operating expenses                      | 12,921,282                   | 6,501,404                  |
| NET INCOME                                    | 7,797,599                    | 781,756                    |
| TOTAL ASSETS, December 31, 2025               | 12,114,196                   | 5,152,785                  |
| BEGINNING MEMBER'S EQUITY, January 1, 2025    | 53,722,791                   | 2,454,919                  |
| EQUITY CONTRIBUTION                           | 2,000,000                    | -                          |
| EQUITY DISTRIBUTION                           | (51,108,514)                 | (2,000,000)                |
| ENDING MEMBER'S EQUITY, December 31, 2025     | \$<br>12,411,876             | \$<br>1,236,675            |

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

### **Note 12 – Subsequent Events**

6XEVHTXHQWHYHQWV have been evaluated through February , 2026. No events have been identified February

WKDWrequire disclosure.

{23}------------------------------------------------

# **Supplementary Information**

{24}------------------------------------------------

| December 31, 2025<br>Pursuant to Rule 15c3-1<br>Computation of Net Capital and Aggregate Indebtedness<br>(A Wholly Owned Subsidiary of ESL Federal Credit Union)<br>ESL Investment Services, LLC |                      |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------|
|                                                                                                                                                                                                  |                      |
| Total member's equity from statement of financial condition                                                                                                                                      | \$<br>13,648,551     |
| Other allowable credits<br>Liabilities of subsidiary, net                                                                                                                                        | 1,257,931            |
| Less non-allowable assets, including those of consolidated subsidiary:<br>Cash held at parent, net of routine expenses                                                                           | 5,486,633            |
| Other assets<br>Securities owned                                                                                                                                                                 | 1,968,326<br>292,191 |
| Goodwill                                                                                                                                                                                         | 2,309,223            |
| Property and equipment, net<br>Other intangible assets, net                                                                                                                                      | 3,963,585<br>44,627  |
| Total non-allowable assets                                                                                                                                                                       | 14,064,585           |
| Net capital                                                                                                                                                                                      | \$<br>841,897        |
| Aggregate indebtedness (excludes balances from consolidated subsidiary)                                                                                                                          |                      |
| Accounts payable and accrued expenses                                                                                                                                                            | \$<br>1,640,810      |
| Computation of basic net capital requirements<br>Minimum net capital (greater of \$100,000 or 6 2/3% of<br>aggregate indebtedness)                                                               | \$<br>109,387        |
| Net capital in excess of minimum requirements                                                                                                                                                    | \$<br>732,510        |
| Ratio of aggregate indebtedness to net capital                                                                                                                                                   | 1.95 to 1            |
| unaudited Part II of Form X-17A-5 as of December 31, 2025.<br>There are no material differences between the preceding computation and the Company's corresponding                                |                      |

There are no material differences between the preceding computation and the Company's corresponding

{25}------------------------------------------------

![](_page_25_Picture_0.jpeg)

#### **ESL Investment Services LLC's Exemption Report**

ESL Investment Services, 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)(2) 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. §240.1Sc3-3, 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: (1) referring securities transactions to another broker-dealer; and (2) proprietary trading of securities for its own account; 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 15c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company); (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception.

ESL Investment Services, LLC

I, Leo Iacobelli, swear (or affirm) that, to my best knowledge and belief, this exemption report is true and correct.

By: Leo Iacobelli Title: President & COO February 20, 2026

225 Chestnut Street• Rochester, New York 14604 • 585.339.4475 • 800.814.5884

Securities and advisory services are offered through LPL Financial (LPL), a registered investment advisor and broker-dealer (member FINRA/SIPC). Insurance products may be offered lhrough LPL or its licensed affiliates or ESL Investment Services, LLC. ESL Investment Services, LLC, member FINRA/SIPC, provides referrals to LPL and its affiliates. Neither ESL Investment Services, LLC, a subsdiary of ESL Federal Credit Union, nor ESL Federal Credit Union are affiliated with LPL or its affiliates. ESL Federal Credit Union is not registered as a broker-dealer or investment advisor. Products and services are offered lhrough LPL or its affiliates by LPL registered representatives doing business as ESL Investment Services. Representatives are dually registered with ESL Investment Services, LLC and LPL and may also be employees of ESL Federal Credit Union . Securities and insurance offered through LPL or its affiliates are:

| Not Insured by NCUA<br>or Any Other Government<br>Agency | Not Credit Union Guaranteed | Not Credit Union Deposits or<br>Obligations | May Lose Value |
|----------------------------------------------------------|-----------------------------|---------------------------------------------|----------------|
|                                                          |                             |                                             |                |

{26}------------------------------------------------

![](_page_26_Picture_0.jpeg)

# **Report of Independent Registered Public Accounting Firm**

ESL Investment Services, LLC The Members and the CUSO Oversight Committee

Exemption Report (the exemption report), in which: We have reviewed management's statements, included in the accompanying ESL Investment Services, LLC's

- 1. ESL Investment Services, LLC, does not claim an exemption under paragraph (k) of 17 C.F.R. §240.15c3-3; and
- 2. ESL Investment Services, LLC, states ESL Investment Services, LLC, is filing the exemption report relying (Footnote 74) because, throughout the mo on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. §240.17a-5 st recent fiscal year, without exception:
- transactions to another broker-dealer, and (2) proprietary trading of securities for its own account, and ESL Investment Services, LLC, limits its business activities exclusively to (1) referring securities
- accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3). funds are payable to the issuer or its agent and not to ESL Investment Services, LLC; (2) did not carry promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the transmitted in compliance with paragraph (a) or (b)(2) of Rule 15c2-4 and/or funds received and securities for or to customers, other than money or other consideration received and promptly ESL Investment Services, LLC (1) did not directly or indirectly receive, hold, or otherwise owe funds or

ESL Investment Services, LLC's management is responsible for compliance with the provisions of Footnote 74 and its statements.

Our review was conducted in accordance with the standards of the Public Company Accounting Oversight Board Accordingly, we do not express such an opinion. than an examination, the objective of which is the expression of an opinion on management's statements. Investment Services, LLC's compliance with the provisions of Footnote 74. A review is substantially less in scope (United States) and, accordingly, included inquiries and other required procedures to obtain evidence about ESL

Based on our review, we are not aware of any material modifications that should be made to management's Footnote 74 of SEC Release No. 34-70073. statements referred to above for them to be fairly stated, in all material respects, based on the provisions of

Portlan d, Oregon February 20, 2026

{27}------------------------------------------------

![](_page_27_Picture_0.jpeg)

#### **Report of Independent Registered Public Accounting Firm**

The Members of the CUSO Oversight Committee ESL Investment Services, LLC

We have performed the procedures included in Rule 17a-5(e)(4) under the Securities Exchange Act of 1934 and in the Securities Investor Protection Corporation (SIPC) Series 600 Rules, which are enumerated below on the accompanying General Assessment Reconciliation (Form SIPC-7) for the year ended December 31, 2025. Management of ESL Investment Services, LLC, is responsible for its Form SIPC-7 and for its compliance with the applicable instructions on Form SIPC-7.

Management of the ESL Investment Services, LLC, has agreed to and acknowledged that the procedures performed are appropriate to meet the intended purpose of assisting ESL Investment Services, LLC, and SIPC in evaluating the Company's compliance with the applicable instructions on Form SIPC-7 for the year ended December 31, 2025. Additionally, SIPC has agreed to and acknowledged that the procedures performed are appropriate to meet their purposes. This report may not be suitable for any other purpose. The procedures performed may not address all the items of interest to a user of this report and may not meet the needs of all users of this report and, as such, users are responsible for determining whether the procedures performed are appropriate for their purposes. The sufficiency of these procedures is solely the responsibility of those parties specified in this report. Consequently, we make no representation regarding the appropriateness of the procedures described below either for the purpose for which this report has been requested or for any other purpose.

The procedures we performed and our findings are as follows:

- 1. Compared the listed assessment payments in Form SIPC-7 with respective cash disbursement records entries noting no differences*.*
- 2. Compared the Total Revenue amounts reported on the Annual Audited Report Form X-17A-5 Part III for the year ended December 31, 2025, with the Total Revenue amounts reported in Form SIPC-7 for the year ended December 31, 2025. The Total Revenue amounts reported on the Annual Audited Report Form X-17A-5 Part III was \$28,002,041 which did not agree to the Total Revenue amounts reported on Form SIPC-7 of \$21,640,810. The amounts reported on Form SIPC-7 do not include gross revenues of the Cooper-Haims subsidiary (Cooper-Haims), and instead includes net income of Cooper-Haims.
- 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 in procedure 3 above, noting no differences*.*

Baker Tilly Advisory Group, LP and Baker Tilly US, LLP, trading as Baker Tilly, are members of the global network of Baker Tilly International Ltd ., the members of which are separate and independent legal entities. Baker Tilly US, LLP is a licensed CPA firm that provides assurance services to its clients. Baker Tilly Advisory Group, LP and its subsidiary entities provide tax and consulting services to their clients and are not licensed CPA firms.

{28}------------------------------------------------

5. Compared the amount of any overpayment applied to the current assessment with the Form SIPC-7 on which it was originally computed noting no differences.

We were engaged by ESL Investment Services, LLC, to perform this agreed-upon procedures Public Company Accounting Oversight Board (Unit the American Institute of Certified Public Accountants and in accordance with the standards of the engagement and conducted our engagement in accordance with attestation standards established by ed States). An agreed-upon procedures conclusion, respectively, on the ESL Investment Se examination or a review engagement, the objective of which would be the expression of an opinion or findings based on the procedures performed. We were not engaged to and did not conduct an acknowledged to be appropriate for the intended purpose of the engagement and reporting on engagement involves performing specific procedures that the engaging party has agreed to and rvices, LLC's Form SIPC-7 and for its compliance matters might have come to our attention that would have been reported to you. we do not express such an opinion or conclusion. Had we performed additional procedures, other with the applicable instructions on Form SIPC-7 for the year ended December 31, 2025. Accordingly,

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

This report is intended solely for the information a nd use of ESL Investment Services, LLC, and SIPC and is not intended to be, and should not be, used by anyone other than these specified parties.

February 20, 2026 Portland, Oregon

{29}------------------------------------------------

| <br>! ;:1<br>.29   	'  %                              | <br><br>%.01 !2<')                                                  | <br><br><br>                                  | <br>5:.;1.01   14                                            |                                                                                      | <br><br>" % )   (%  ) 4                                     | <br>6 )   4                         | <br>( ) % %%!   4  | <br>! %     ) )) '!)4<br>\$!) ,                                                                                      | !!   5  !                              | <br><br>% )   (%  ) 4                 | <br>) !6 "  !-)  )4<br>3'<br><br>!( "7                | <br>!-)<br><br><br>%<br>)4<br>% "% | <br><br><br>!<br>!(! !         | <br><br><br><br><br><br>%<br>%<br>' '<br>' ' | <br>)-!1<br><br>( )<br>!<br>%<br>                  | !! , | ( ) . 	' / %                           |                                                       | <br>                                |                                     |
|---------------------------------------------------------|----------------------------------------------------------------------|-----------------------------------------------|--------------------------------------------------------------|--------------------------------------------------------------------------------------|-------------------------------------------------------------|-------------------------------------|--------------------|----------------------------------------------------------------------------------------------------------------------|----------------------------------------|---------------------------------------|-------------------------------------------------------|------------------------------------|--------------------------------|----------------------------------------------|----------------------------------------------------|------|----------------------------------------|-------------------------------------------------------|-------------------------------------|-------------------------------------|
| 29  %"    !  )% ) )<br>% .01<br><br>################## | ! !(! ! 3'  . 	'  %<br>L 3  !!(! ! %<br>G-(1-)<br>################## | ( )  !  !   !   )<br><br><br><br><br><br>-) 4 | 6  ( ) !   ) -)  .( ) ! ! -<br>\$ 3'   '  "7 !( "7  ! "   )! | %)   %    % )  !4<br>!'  ! .1 ) -7 - 8 '   %% ''<br>59 %%   ! %8)'  ! %     .<br>1 | %-)%   '"    6 '3  4                                        | %% 7  -8"  !   '!<br>%%-            |                    | "!  (%  %'    )  %'  ' )<br>-)    ) 7 %  (%  !( (  !!<br>%'   )   (%  )7 %    (-  )7 %<br>( ) %  !-)     "! '  !  (% |                                        | !!     )"  "4   )<br>4                | !!)!  !%  "  ' % "%    ''<br>'  "7<br>"<br>!<br>"<br> | <br><br>''<br>) !6 "<br>           | 3'<br>!!)!<br>!%  "<br>%<br>54 | <br><br>)<br>%%!<br>! "<br>! "<br>) 4<br>) 4 | '!<br>)<br>-)<br>)!!<br><br>-(4<br>)-!<br>.3'<br>" |      | % .01 / ! 21                         | '! -"  " ##############  !  ! "##########<br>1/1/2025 | ESL INVESTMENT SERVICES LLC<br><br> | \$%   &<br><br>' " 	( )*  ! +  %  , |
|                                                         |                                                                      | ##################                            | ##################                                           | ##################                                                                   | ##################<br>##################<br>\$ 5,447,601.00 | ##################<br>\$ 875,902.00 | ################## | ##################<br>\$ 3,927,096.00                                                                                |                                        | ##################                    | ##################                                    | ##################                 | ##################             | ##################<br>##################     | ##################<br>\$ 7,423,332.00              |      |                                        | 12/31/2025<br>##                                      | <br>8-67195<br><br>                 |                                     |
|                                                         |                                                                      |                                               |                                                              |                                                                                      |                                                             |                                     |                    |                                                                                                                      | ##################<br>\$ 29,064,142.00 | ##################<br>\$ 7,423,332.00 |                                                       |                                    |                                |                                              |                                                    |      | ##################<br>\$ 21,640,810.00 |                                                       |                                     |                                     |

{30}------------------------------------------------

| <br> |
|------|
|      |

|                                   |                                                                                                 |                 |                               |                              |                                   |                                    |                                    |                               |                                    |                                    |                                         |                                                                | ,                                  | +                             | )                                  | "                                      |  |
|-----------------------------------|-------------------------------------------------------------------------------------------------|-----------------|-------------------------------|------------------------------|-----------------------------------|------------------------------------|------------------------------------|-------------------------------|------------------------------------|------------------------------------|-----------------------------------------|----------------------------------------------------------------|------------------------------------|-------------------------------|------------------------------------|----------------------------------------|--|
|                                   | <br><br><br><br>                                                                                | 8-67195<br><br> |                               |                              |                                   |                                    | <br>%)  %   5                      | <br>%)  %   ;                 | %)  %   ?                          | <br>                               | <br><br>!!   55 )" 55<br>'%  ''!  ##### | <br>('%  ''!                                                   |                                    |                               |                                    |                                        |  |
| )-! .1  ! '! .1  )!!   % ."( %  ! | UNITED STATES<br>ROCHESTER, NY 14604-2424<br>225 CHESTNUT STREET<br>ESL INVESTMENT SERVICES LLC | DEA: FINRA<br>  | ('% >! ! 6! . ''-1            | *! -! . #\$%4 !!   5!  ! 524 | .  ) 1  ###### !    9 '  )%<br>0 | )-   5-  ! 5 % 54   )*  !          |                                    |                               |                                    | 5  55!4                           | 2025                                    | ('% .1 ''!   #####<br>2025                                     | +  %  %  !                         | ) ('% >!- 7                   | =)'    - 45<4   )' *             | )-  : %   4   )#\$%  &' (!            |  |
|                                   |                                                                                                 | <br>            |                               |                              |                                   |                                    |                                    |                               |                                    |                                    | :  ! :.1                                | :  ! :.1                                                       | #####<br>2025<br><br>:  :          |                               |                                    |                                        |  |
| )%-1                              |                                                                                                 |                 |                               |                              |                                   | 4                                  |                                    |                               |                                    |                                    | ##################<br>\$ 13,130.00      | ##################<br>##################<br>\$ 0.00<br>\$ 0.00 |                                    |                               | 4                                  | 4                                      |  |
|                                   |                                                                                                 | 2025<br><br>    |                               |                              |                                   |                                    |                                    |                               |                                    |                                    |                                         |                                                                |                                    |                               |                                    |                                        |  |
|                                   |                                                                                                 | <br>Dec<br>     |                               |                              |                                   |                                    | ##################<br>\$ 13,130.00 | ##################<br>\$ 0.00 | ##################<br>\$ 28,220.00 |                                    | ##################<br>\$ 13,130.00      |                                                                | ##################<br>\$ 13,130.00 |                               |                                    |                                        |  |
|                                   |                                                                                                 |                 | ##################<br>\$ 0.00 | \$ 15,090.00                 | ##################<br>\$ 0.00     | ##################<br>\$ 15,090.00 |                                    |                               |                                    | ##################<br>\$ 13,130.00 |                                         |                                                                |                                    | ##################<br>\$ 0.00 | ##################<br>\$ 28,220.00 | ##################<br>\$ 18,813,543.00 |  |

|  | %' D)B!" D 6-!%!" )4 | .\$1   | ######################################################<br>2/20/2026 | .%<br>=%-1 | ######################################################<br>ESL INVESTMENT SERVICES LLC | ✔<br>!  !  6<br>%%-7 )  )B!7  ! ! -   7   "  !  ! " -<br>%A    %   %  )  ! %'A  !   -<br>@ 8 "  -37 )   ) (  )<br>C ( |
|--|----------------------|--------|---------------------------------------------------------------------|------------|---------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------|
|  |                      | .% !!1 | ###############################<br>proche@dfppartners.com           | .)B! " 1   | ###############################<br>Pascal Roche                                       | %%-  "<br><br>                                                                                                        |


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