# ACCESSALPHA WORLDWIDE LLC X-17A-5 (2026-02-13) — Broker-dealer annual report

- Company: ACCESSALPHA WORLDWIDE LLC
- Form: X-17A-5
- Filed: 2026-02-13
- Period: 2025-12-31
- Accession: 0001378144-26-000003
- CIK: 1378144
- File #: 8-67446
- Type: Broker-dealer
- Material weakness: No
- Auditor: FGMK, LLC
- Auditor location: Chicago, IL
- Contact: Brian Lenart
- Phone: 708-624-1982
- Signed by: Robert LeClercq (President, Chief Financial Officer)

Original filing: https://www.sec.gov/Archives/edgar/data/1378144/000137814426000003/Public2025.pdf

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|                                                  | (Name - if individual, state last, first, and middle name) |         |                                            |
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| 333 W. Wacker Drive, 6th Floor                   | Chicago                                                    |         | 60606                                      |
| (Address)                                        | (City)                                                     | (State) | (Zip Code)                                 |
| 12/17/2009                                       |                                                            | 3968    |                                            |
| (Date of Registration with PCAOB)(if applicable) |                                                            |         | (PCAOB Registration Number, if applicable) |
|                                                  | FOR OFFICIAL USE ONLY                                      |         |                                            |
|                                                  |                                                            |         |                                            |

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| Robert LeClercq                                                       | swear (or affirm) that, to the best of my knowledge and belief, the                                                                 |
|-----------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------|
| tinancial report pertaining to the firm of AccessAlpha Worldwide, LLC | as of                                                                                                                               |
| 12/31                                                                 | , 2 025 , is true and correct. I further swear (or affirm) that neither the company nor any                                         |
|                                                                       | partner, officer, director, or equivalent person, as the case may be, has any proprietary interest in any account classified solely |
| as that of a customer.                                                | Signature:<br>Title:<br>Dropidont Ohiof Einsnaigl Officer                                                                           |

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![](_page_2_Picture_0.jpeg)

#### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**

To the Management of Accessalpha Worldwide, LLC

#### *Opinion on the Financial Statements*

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

#### *Basis for Opinion*

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

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

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

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

The supplementary information presented in Schedules I, II and III has been subjected to audit procedures performed in conjunction with the audit of the Company's financial statements. The supplementary information is the responsibility of the Company's management. Our audit procedures included determining whether the supplementary 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 supplementary information. In forming our opinion on the supplementary information, we evaluated whether the supplementary information, including its form and content, is presented in conformity with 17 C.F.R. §240.17a-5. In our opinion, the supplementary information presented in Schedules I, II and III is fairly stated, in all material respects, in relation to the financial statements as a whole.

We have served as the Company's auditor since 2015.

Chicago, Illinois February 11, 2026

#### FGMK, LLC

333 W. Wacker Drive, 6th Floor | Chicago, IL 60606 2801 Lakeside Drive, 3rd Floor | Bannockburn, IL 60015 17W110 22nd Street, Suite 350 | Oakbrook Terrace, IL 60181 Bannockburn | Chicago | Cleveland | Denver Dubuque | Indianapolis | Oakbrook Terrace Orange County | Santa Fe | Sarasota

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# FINANCIAL STATEMENTS AND REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

DECEMBER 31, 2025

Filed as a Public Document Pursuant to Rule 17a-5(d) of the Securities Exchange Act of 1934 \*\*\*PUBLIC DOCUMENT\*\*\*

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# **TABLE OF CONTENTS**

# **DECEMBER 31, 2025**

|   | Letter of Oath or Affirmation                                                                                                                |          |
|---|----------------------------------------------------------------------------------------------------------------------------------------------|----------|
|   | Report of Independent Registered Public Accounting Firm                                                                                      |          |
|   |                                                                                                                                              | PAGE     |
|   | FINANCIAL STATEMENTS                                                                                                                         |          |
|   | Statement of Financial<br>Condition3                                                                                                         |          |
|   | Statement of Operations<br>                                                                                                                  | 4        |
|   | Statement of Changes in Members'<br>Equity………………………………………………………. 5                                                                           |          |
|   | Statement of Cash Flows……………………………………………………………………………6                                                                                        |          |
|   | Notes to the Financial Statements………………………………….…………………….……… 7 -                                                                              | 9        |
|   | SUPPLEMENTARY INFORMATION REQUIRED BY RULE 17a-5 UNDER THE<br>SECURITIES EXCHANGE ACT OF 1934                                                |          |
| I | Computation of Regulatory Net Capital and Aggregate Indebtedness under Rule 15c3-1<br>of the Securities and Exchange Commission (Schedule I) | 10       |
|   | II Computation for Determination of Reserve Requirements under Rule 15c-3-3<br>of the Securities and Exchange Commission (Schedule II)       | 11       |
|   | III Information Relating to Possession or Control Requirements under Rule 15c3-3<br>of the Securities and Exchange Commission (Schedule III) | 11       |
|   | EXEMPTION REPORT AS REQUIRED BY RULE 17a-5 UNDER THE<br>SECURITIES EXCHANGE ACT OF 1934                                                      |          |
|   | Report of Independent Registered Public Accounting Firm<br>Exemption Report                                                                  | 12<br>13 |

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#### Statement of Financial Condition

### December 31, 2025

### ASSETS

| ASSETS                            |              |
|-----------------------------------|--------------|
| Cash                              | \$<br>12,539 |
| Prepaid expenses and other assets | 24,924       |
| TOTAL ASSETS                      | \$<br>37,463 |
| LIABILITIES AND MEMBERS' EQUITY   |              |

| LIABILITIES                           | \$<br>0      |
|---------------------------------------|--------------|
| MEMBERS' EQUITY                       | 37,463       |
| TOTAL LIABILITIES AND MEMBERS' EQUITY | \$<br>37,463 |

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#### Statement of Operations

#### For the Year Ended December 31, 2025

#### REVENUES FROM CONTRACTS WITH CUSTOMERS

5

| Introductory fees                     | \$<br>188,629  |
|---------------------------------------|----------------|
| Consulting fees                       | 79,967         |
|                                       | 268,596        |
|                                       |                |
| EXPENSES                              |                |
| Partner compensation and office wages | 92,125         |
| Insurance and bonds                   | 79,271         |
| Professional fees                     | 40,690         |
| Travel                                | 23,955         |
| State Income Taxes                    | 16,885         |
| Occupancy                             | 8,290          |
| Other expenses                        |                |
|                                       | 27,202         |
|                                       | 288,418        |
|                                       |                |
| Net loss                              | \$<br>(19,822) |

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Statement of Changes in Members' Equity For the Year Ended December 31, 2025

| Balance – January 1, 2025   | \$<br>57,285 |
|-----------------------------|--------------|
| Net loss                    | (19,822)     |
| Balance – December 31, 2025 | \$<br>37,463 |

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#### Statement of Cash Flows

#### For the Year Ended December 31, 2025

| CASH FLOWS FROM OPERATING ACTIVITIES:<br>Net loss<br>Adjustment to reconcile net loss to net cash<br>Used in operating activities:<br>(Increase) decrease in operating assets: |         | \$<br>(19,822) |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------|----------------|
| Prepaid expenses and other assets<br>Total adjustments                                                                                                                         | (3,921) | (3,921)        |
| Net cash used in operating activities                                                                                                                                          |         | (23,743)       |
| Net decrease in cash                                                                                                                                                           |         | (23,743)       |
| Cash, beginning of year                                                                                                                                                        |         | 36,282         |
| Cash, end of year                                                                                                                                                              |         | \$<br>12,539   |

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## **ACCESSALPHA WORLDWIDE LLC NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2025**

## **NOTE 1 – ORGANIZATION AND NATURE OF BUSINESS**

AccessAlpha Worldwide LLC (the "Company") is a broker-dealer registered with the Securities and Exchange Commission ("SEC") and with the Financial Industry Regulatory Authority, Inc. ("FINRA"). The Company was formed on July 20, 2006 as a Delaware limited liability company. The Company operates as a partnership.

The Company's revenue is derived from two major sources: Introductory Fees – compensation earned in exchange for making qualified introduction to prospective institutional investors; and Consulting Fees – compensation earned pursuant to market research or development of marketing materials or presentation messages.

The Company does not hold any securities or funds of its customers.

# **NOTE 2 – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES**

## Cash

The Company considers all investment instruments purchased with a maturity of three months or less to be cash equivalents. The Company, in the normal course of business, maintains a checking account with a banking institution. Bank balances did not exceed Federal Deposit Insurance Corporation's insurance limits at December 31, 2025.

## Securities

As a non-carrying, non-clearing dealer, the Company does not receive or hold customer funds or safe keep customer securities.

### Revenue Recognition

Revenue from contracts with customers includes introductory fees and consulting fees. The recognition and measurement of revenue is based on the assessment of individual contract terms. Significant judgment is required to determine whether performance obligations are satisfied at a point in time or over time; how to allocate transaction prices where multiple performance obligations are identified; when to recognize revenue based on the appropriate measure of the Company's progress under the contract; and whether constraints on variable consideration should be applied to uncertain future events.

The Company's principal sources of revenue are derived from introductory fees and consulting fees, as more fully described below, as well as reimbursed expenses from customers.

**Introductory fees**. The Company makes introductions to institutional investors on behalf of its customers. Each time an investor makes an investment with one of the Company's customers, the Company charges an introductory fee. The Company may receive an introductory fee paid by the customer up front, over time, or a combination thereof. The Company believes that its performance obligation is the sale of fund offerings to investors and as such this is fulfilled on the contract date at a point in time. Any fixed and certain amounts are recognized on the contract date and variable amounts are recognized to the extent it is probable that a significant revenue reversal will not occur once the uncertainty is resolved. For variable amounts, as the uncertainty is dependent on the value of the investments at future points in time as well as the length of time the investor remains in the investment, both of which are highly susceptible to factors outside the Company's influence, the Company does not believe that it can overcome this constraint until the market value of the investment and the investor activities are known, which are usually quarterly.

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## **ACCESSALPHA WORLDWIDE LLC NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2025**

**Consulting fees**. The Company assists its customers with creation of marketing materials and product development, among other project work. Each time the Company begins this consulting service, the Company charges a consulting fee. The Company will receive a consulting fee paid by the customer up front, over time, or a combination thereof. The Company believes that its performance obligation is the initiation of said consulting project and is satisfied as these projects are completed. Any fixed and certain amounts are recognized on the contract date and variable amounts are recognized to the extent it is probable that a significant revenue reversal will not occur once the uncertainty is resolved. For variable amounts, as the uncertainty is dependent on subsequent activities at future points in time, which is highly susceptible to factors outside the Company's influence, the Company does not believe that it can overcome this constraint until the future activities are known, which is stated in individual contracts.

## Basis of Accounting and Income Taxes

The Company prepares its financial statements using the accrual method of accounting in conformity with accounting principles generally accepted in the United States of America while using the cash method of accounting for income tax purposes. Differences are generally applicable to accounts receivable, accrued expenses, accounts payable and depreciation/amortization expense (depreciation and amortization, for income tax purposes, are computed using IRS guidelines). The Company elected to report its income and expenses as a partnership. Accordingly, the Company does not incur any federal income tax for either book or tax purposes. The net income or net loss is reported by the Company's members pursuant to their specific ownership percentage. The Company is responsible for the computed Illinois replacement tax, if any. The Company elected to record and pay state income taxes based on the Company's taxable income that were previously the sole responsibility of the members. The Company may make a distribution in 2026 in connection with the members' respective income tax liabilities incurred for 2025 as a result of the Company's partnership income tax status.

#### Use of Estimates and Assumptions

The preparation of financial statements in conformity with accounting principles generally accepted in the United States of America requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts or revenues and expenses during the reporting period. Actual results could differ from those estimates. The Company's significant estimates include its allowance for doubtful accounts.

## Leases

The Company recognizes and measures its leases in accordance with FASB ASC 842, *Leases*. The Company determines if an arrangement is a lease, or contains a lease, at inception of a contract and when the terms of an existing contract are changed. The Company has elected, for all underlying classes of assets, to not recognize right of use assets and lease liabilities for short-term leases that have a lease term of 12 months or less at lease commencement, and do not include an option to purchase the underlying asset that the Company is reasonably certain to exercise. The Company recognizes lease costs associated with its short-term leases on a straight-line basis over the lease term. The Company is a lessee in a month to month operating lease for office space.

## *NOTE 3 – SEGMENT INFORMATION*

The Company is engaged in a single line of business as a securities broker-dealer, which is comprised of receiving compensation for identifying potential investors for its client's various private offerings. The Company has identified its President as the chief operating decision maker ("CODM"), who uses net income or net loss 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 5), 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 distributions. The Company's operations constitute a single operating segment and therefore,

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## **ACCESSALPHA WORLDWIDE LLC NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2025**

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 company derived 56 percent of its total revenues from a single external customer in 2025.

## **NOTE 4 – CONCENTRATION OF RISK**

Concentration of Business Risk – due to the size of the Company, AccessAlpha Worldwide LLC concentrates its business to a small number of customers. The terms and length of rendered service and relationship largely depends on the operational projects of the customer. During 2025, 99% of the Company's revenue was derived from three customers. Due to the nature of the industry, revenues received from customers is typically non-recurring. The ongoing operation of the Company is economically dependent on its ability to enter into contracts with new customers.

## **NOTE 5 – NET CAPITAL REQUIREMENTS**

The Company is subject to the Securities Exchange Act of 1934 (the "Act") uniform net capital rule, which requires the maintenance of minimum \$5,000 net capital (as defined) or 6 2/3 percent of "aggregate indebtedness", whichever is greater, and requires that the ratio of aggregated indebtedness to net capital not to exceed 15 to 1 as these terms are defined. At December 31, 2025, the Company had net capital of \$12,539 of which \$7,539 was in excess of its required net capital of \$5,000. At December 31, 2025, the Company's aggregate indebtedness to net capital ratio was 0. The minimum capital requirements may effectively restrict the withdrawal of members' equity.

### **NOTE 6 – MEMBERS' EQUITY**

The Company operates under a restated and amended operating agreement effective December 31, 2016. Under the restated agreement, Class A units represent a membership interest in the Company, including any and all benefits to which a Member may be entitled to under the agreement and the obligations of a Member under the agreement.

## **NOTE 7 – INDEMNIFICATIONS**

In the normal course of business, the Company enters into contracts and agreements that contain a variety of representations and warranties and which provide general indemnifications. The Company's maximum exposure under these arrangements is unknown as this would involve future claims that may be made against the company that have not yet occurred. The Company believes that it is unlikely it will have to make material payments under these arrangements and has not recorded any contingent liability in the financial statements for these indemnifications.

#### **NOTE 8 – SUBSEQUENT EVENTS**

The Company has evaluated all subsequent events through the date the financial statements were available for issue and is not aware of any material subsequent events occurring during this period.

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| ACCESSALPHA WORLDWIDE LLC                                                                                                                                 | Schedule I   |
|-----------------------------------------------------------------------------------------------------------------------------------------------------------|--------------|
| Computation of Regulatory Net Capital and Aggregate Indebtedness UnderRule 15c3-1 of<br>the Securities and Exchange Commission<br>As of December 31, 2025 |              |
| NET CAPITAL                                                                                                                                               |              |
| Members' equity                                                                                                                                           | 37,463       |
| Deductions<br>Nonallowable assets<br>Prepaid expenses and other assets<br>24,924                                                                          |              |
|                                                                                                                                                           | (24,924)     |
| Net Capital                                                                                                                                               | \$<br>12,539 |
| AGGREGATED INDEBTEDNESS                                                                                                                                   |              |
| Total A.I. liabilities                                                                                                                                    | \$<br>0      |
| Aggregate Indebtedness                                                                                                                                    | \$<br>0      |
| COMPUTATION OF BASIC NET CAPITAL REQUIREMENT<br>Minimum net capital required (6 2/3% of total aggregate<br>indebtedness or \$5,000, whichever is greater) |              |
|                                                                                                                                                           | \$<br>5,000  |
| EXCESS NET CAPITAL                                                                                                                                        | \$<br>7,539  |
| RATIO OF AGGREGATE INDEBTEDNESS TO NET CAPITAL                                                                                                            | 0            |
|                                                                                                                                                           |              |

There were no material differences between the preceding computation and the Company's corresponding unaudited FOCUS report, Part II of Form X-17A-5 as of December 31, 2025.

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## **Computation for Determination of Reserve Requirements Under Rule 15c3-3 of the Securities and Exchange Commission December 31, 2025 Schedule II**

AccessAlpha Worldwide LLC is claiming an exemption 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 receiving compensation for identifying potential investors for its client's various private offerings, 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) of Rule 15c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company); (2) did 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.

**Information Relating to Possession or Control Requirements Under Rule 15c3-3 of the Securities and Exchange Commission December 31, 2025 Schedule III**

AccessAlpha Worldwide LLC is claiming an exemption 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 receiving compensation for identifying potential investors for its client's various private offerings, 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) of Rule 15c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company); (2) did 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.

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#### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**

To the Management of Accessalpha Worldwide, LLC

We have reviewed management's statements, included in the accompanying Rule 15c3-3 Exemption Report pursuant to SEC Rule 17a-5, in which (1) Accessalpha Worldwide, LLC (the "Company") did not claim an exemption under paragraph (k) of 17 C.F.R. §240.15c3-3, and (2) the Company is filing this Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 because the Company limits its business activities exclusively to receiving compensation for identifying potential investors for its client's various private offerings. In addition, the Company did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of Rule 15c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company; did not carry accounts of or for customers; and did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception.

Accessalpha Worldwide, 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) ("PCAOB") and, accordingly, included inquiries and other required procedures to obtain evidence about Accessalpha Worldwide, 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 the Company's business activities contemplated by Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5, and related SEC Staff Frequently Asked Questions.

Chicago, Illinois February 11, 2026

#### FGMK, LLC

333 W. Wacker Drive, 6th Floor | Chicago, IL 60606 2801 Lakeside Drive, 3rd Floor | Bannockburn, IL 60015 17W110 22nd Street, Suite 350 | Oakbrook Terrace, IL 60181 Bannockburn | Chicago | Cleveland | Denver Dubuque | Indianapolis | Oakbrook Terrace Orange County | Santa Fe | Sarasota

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## **AccessAlpha Worldwide LLC**

# **EXEMPTION REPORT INFORMATION RELATING TO THE POSSESSION OF CONTROL REQUIREMENTS UNDER RULE 15C3-3 OF THE SECURITIES AND EXCHANGE COMMISSION**

## **DECEMBER 31, 2025**

AccessAlpha Worldwide LLC 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. l 7a-5(d)(l) and (4). To the best of its knowledge and belief, the Company states the following:

(1) The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240.15c3-3;

(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 receiving compensation for identifying potential investors for its client's various private offerings, 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) of Rule 15c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company); (2) did 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.

By: \_

Robert R. LeClercq President, Chief Financial Officer

Date: February 9, 2026


Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.
