# SPIRE SECURITIES, LLC X-17A-5 (2026-03-03) — Broker-dealer annual report - Company: SPIRE SECURITIES, LLC - Form: X-17A-5 - Filed: 2026-03-03 - Period: 2025-12-31 - Accession: 0001399108-26-000004 - CIK: 1399108 - File #: 8-67635 - Type: Broker-dealer - Material weakness: No - Auditor: Sanville & Company LLC - Auditor location: Dallas, TX - Contact: Ryan Dietz - Phone: 7036576073 - Email: ryan.dietz@spireip.com - Website: spireip.com - Signed by: Robert Lord (Chief Operations Officer) Original filing: https://www.sec.gov/Archives/edgar/data/1399108/000139910826000004/EDGAR2025SS17a5PartIII.pdf --- {0}------------------------------------------------ | ANNUAL REPORTS | |----------------| | FORM X-17A-5 | | PART III | | OMB APPROVAL | | |--------------------------|--| | OMB Number: 3235-0123 | | | Expires: Nov. 30, 2026 | | | Estimated average burden | | | nours per response: 12 | | | | | | | | 8-67635 | | |-----------------------------------|-----------------------|---------|------------| | | | | | | | | | | | | 01/01/2025 | | 12/31/2025 | | | | | | | | | | | | | Spire Securities, LLC | | | | ■ | | | | | 7901 Jones Branch Dr. / Suite 800 | | | | | | | | | | McLean | VA | | 22102 | | | | | | | Ryan Dietz | 703-657-6073 | ryan.dietz@spireip.com | |------------|--------------|------------------------| | | | | # Sanville & Company LLC | 325 North Saint Paul Street | Dallas | TX | 75201 | |-----------------------------|--------|-----|-------| | | | | | | 09.18.2003 | | 169 | | | | | | | | | | | | | | | | | {1}------------------------------------------------ #### OATH OR AFFIRMATION | Robert Lord | swear (or affirm) that, to the best of my knowledge and belief, the | | |-----------------------------------------------------------------|---------------------------------------------------------------------|-------| | financial report pertaining to the firm of Spire Securities LLC | | as of | | December 31 | 2 025 | | | | | | partner, officer, director, or equivalent person, as the case may proprietary interest in any account classified soley as that of a customer. | | Signed by: | | |--------------------------|-----------------------|-----------| | | Signature: BOB FORD | 2/26/2026 | | | | | | Title: | | | | Chief Operations Officer | | | # 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 stockholders' 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 240.18a-1, as applicable. - [ (i) Computation of tangible net worth under 17 CFR 240.18a-2. - [j) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3. - | | |k | Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.15c3-3 or Exhibit A to 17 CFR 240.18a-4, as applicable. - [1) 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. - [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. - | | Oath or affirmation in accordance with 17 CFR 240.17a-5, 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable. - [r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - |s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - | (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 statements under 17 CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable. - | (v) Independent public accountant's report based on an examination of certain statements in the compliance report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | CFR 240.18a-7, as applicable. - | |x| Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.17a-12, as applicable. - □ (y) Report describing any material inadequacies found to have existed since the date of the previous audit, or a statement that no material inadequacies exist, under 17 CFR 240.17a-12(k). - □ (z) Other: - \*\* To request confidential treatment of certain portions of this filing, see 17 CFR 240.17a-5(e)(3) or 17 CFR 240.180-7(d)(2), as applicable. {2}------------------------------------------------ Financial Statements and Supplementary Financial Information # SPIRE SECURITIES, LLC McLean, Virginia December 31, 2025 {3}------------------------------------------------ #### CONTENTS | FINANCIAL STATEMENTS
Report of Independent Registered Public Accounting Firm
Statement of Financial Condition
Statement of Operations
Statement of Member's Equity
Statement of Cash Flows
Notes to Financial Statements
OTHER FINANCIAL INFORMATION
Schedule I - Computation of Net Capital | Page | |----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------| | | | | | 1 | | | 3 | | | 4 | | | 5 | | | 6 | | | 7-10 | | | | | | 11-12 | | Schedule II - Computation for Determination of Reserve Requirements | 13 | |------------------------------------------------------------------------------|----| | Schedule III- Information Relating to the Possession or Control Requirements | 13 | | Report of independent Registered Public Accounting Firm | 14 | | Exemption Report | 15 | {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) # Report of Independent Registered Public Accounting Firm To the Member and Those Charged With Governance Spire Securities, LLC # Opinion on the Financial Statements We have audited the accompanying statement of financial condition of Spire Securities, LLC (the Company) as of December 31, 2025, the related statements of operations, changes in member's equity, and cash flows for the year then ended, and the related notes to the financial statements (collectively, 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 then ended, in conformity with accounting principles generally accepted in the United States of America. # Basis for Opinion These financial statements are the responsibility of the Company's management. Our responsibility is to express an opinion on the Company's financial statements based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to the Company in accordance with 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 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. # Supplemental Information The supplementary information contained in Schedule I, Computation of Net Capital Under SEC Rule 15c3-1, Schedule II, Computation for Determination of Reserve Requirements Under SEC Rule 15c3-3, and Schedule III, Information Relating to the Possession or Control Requirements Under SEC Rule 15c3-3 has been subjected to audit procedures performed in conjunction with the audit of the Company's financial statements. The supplemental information is the > 325 North Saint Paul Street Suite 3100 Dallas, Texas 75201 214.738.1998 {5}------------------------------------------------ responsibility of the Company's management. Our audit procedures included determining whether the supplemental information reconciles to the financial statements or the underlying accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the supplemental information. In forming our opinion on the supplemental information, we evaluated whether the supplemental information, including its form and content, is presented in conformity with 17 C.F.R. § 240.17a-5. In our opinion, the supplementary information contained in Schedule I, Computation of Net Capital Under SEC Rule 15c3-1, Schedule II, Computation for Determination of Reserve Requirements Under SEC Rule 15c3-3, and Schedule III, Information Relating to the Possession or Control Requirements Under SEC Rule 15c3-3 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 2024. Sanville & Company, LLC Dallas, Texas February 24, 2026 {6}------------------------------------------------ #### STATEMENT OF FINANCIAL CONDITION #### SPIRE SECURITIES, LLC | | | 12/31/2025 | |--------------------------------------------------------------------------------------------------------------------|----------------------|---------------------------------------------| | | ASSETS | | | CURRENT ASSETS
Cash and cash equivalents
Commissions receivable
Deposit held by FINRA
Prepaid expenses | | \$
547,465
323,800
60,731
3,344 | | | TOTAL CURRENT ASSETS | 935,340 | | OTHER ASSETS
Deposit held by clearing organization | | 175,000 | | | | \$ 1,110,340 | #### LIABILITIES AND MEMBER'S EQUITY | CURRENT LIABILITES
Accounts payable | | \$
28,396 | |----------------------------------------|---------------------------|--------------| | Commissions payable | | 225,960 | | | TOTAL CURRENT LIABILITIES | 254,356 | | MEMBER'S EQUITY | | 855,984 | | | | \$ 1,110,340 | {7}------------------------------------------------ #### STATEMENT OF #### OPERATIONS #### SPIRE SECURITIES, LLC | | | For Year Ended
December 31, 2025 | | |----------------------------------|-------------------------|-------------------------------------|--| | INCOME | | | | | Commissions | | \$
8,317,391 | | | Fee income | | 357,738 | | | Distribution fees | | 19,802 | | | Other income | | 60,000 | | | Concession and commission income | | 8,754,931 | | | | | | | | EXPENSES | | | | | Commission expense | | 7,053,246 | | | Management fees | | 1,737,768 | | | Operating expense | | 315,542 | | | | | 9,106,556 | | | | OPERATING INCOME (LOSS) | (351,625) | | | | | | | | | | | | | NON-OPERATING INCOME | | | | | Interest income | | \$
23,498 | | | Interest expense | | 0 | | | | | 23,498 | | | | | | | | | | | | | | NET INCOME (LOSS) | | | \$(328,127) {8}------------------------------------------------ ### STATEMENT OF MEMBER'S EQUITY ### SPIRE SECURITIES, LLC | | Member's Equity | |-------------------------------------------------------|-----------------| | BALANCE, DECEMBER 31, 2024 | \$1,184,111 | | Net income(loss) for the year ended December 31, 2025 | (328,127) | | Add: member investments | 300,000 | | Less: distributions to member | (300,000) | | BALANCE, DECEMBER 31, 2025 | \$855,984 | {9}------------------------------------------------ #### STATEMENT OF CASH FLOWS #### SPIRE SECURITIES, LLC #### FOR THE YEAR ENDING DECEMBER 31, 2025 | CASH FLOWS FROM OPERATING ACTIVITIES
Net income(loss)
Effects of change in operating accounts and accruals: | \$ | (328,127) | |-------------------------------------------------------------------------------------------------------------------|----|---------------------| | Commissions and clearing receivable | | 51,808 | | Contingent loss | | (20,000) | | Prepaid expenses | | 3,730 | | Accounts payable | ( | 105,193) | | NET CASH PROVIDED BY OPERATING ACTIVITIES | | (397,782) | | CASH FLOWS FROM FINANCING ACTIVITIES
Member's distribution
Member's investment | ( | 300,000)
300,000 | | NET INCREASE (DECREASE) IN CASH | | (397,782) | | Cash, beginning of the year | | 945,247 | | CASH, END OF YEAR | \$ | 547,465 | | Supplemental disclosures of cash flow information:
Cash paid for
interest | | \$0 | | Cash paid for income taxes | | \$0 | | | | | {10}------------------------------------------------ #### SPIRE SECURITIES, LLC #### December 31, 2025 #### NOTE A - SIGNIFICANT ACCOUNTING POLICIES Spire Securities, LLC (the Company), a wholly owned subsidiary of Spire Investment Partners, LLC (the Parent), is a securities brokerage firm providing securities brokerage and trading services to both individuals and institutional entities and also provides regulatory oversight to registered representatives for their investment advisory services. The Company does not have custody of client accounts or hold securities. Securities are held by third parties, and transactions are cleared through clearing organizations and their direct placement partners. The Company qualifies under Rule 15c3-3(k)(2)(ii) from the Securities and Exchange Commission Customer Protection Rule (Rule 15c3-3). Accordingly, the supplemental schedule of Information Relating to Possession or Control Requirements for Brokers and Dealers Pursuant to Rule 15c3-3 is not applicable. The Company uses accrual basis accounting for financial statement purposes, recognizing income when earned and expenses when incurred. A consolidated income tax return is filed with the Parent. Cash, as used in the accompanying financial statements, includes currency on hand, demand deposits with financial institutions and short-term,highly liquid investments purchased with a maturity of three months or less. The preparation of financial statements in conformity with generally accepted accounting principles requires management to make estimates and assumptions that affect the reported amount of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates. The Company receives commissions for the sale of variable annuity policies, insurance policies, mutual funds, and other financial products to customers. There are trail commissions earned on these policies, funds, and products sold to customers for the period of time that the customer remains in or keeps the policy, fund, or product. The Company records these trail commission revenues, based on the trade date of each periodic trail commission, as they are remitted to the Company from the corresponding entity. It does not accrue the entire potential revenue because the time period in which the customer remains in the fund or keeps the annuity or insurance policy represents an unresolved contingency. In addition, the Company also receives commission revenue and incurs related clearing expenses for individual purchases and sales of securities on behalf of certain customers. These revenues and expenses are recorded on the trade date. On the trade date, the Company believes that the performance obligation is satisfied because the underlying purchaser has been identified, the pricing agreed upon and the risks and rewards of ownership transferred. Total commission revenue for the year ended December 31, 2025, was \$8,317,392. Contract assets are recognized as receivables from the corresponding annuity, insurance, or fund company on the accompanying statement of financial condition. The Company recorded contract assets of \$382,191 and \$437,539 at January 1, 2025 and December 31, 2025 respectively. {11}------------------------------------------------ #### SPIRE SECURITIES, LLC #### December 31, 2025 No provision for income taxes has been provided in these statements, as the Parent, by agreement, is responsible for any tax liability of the consolidated group. The Parent has elected, under the Internal Revenue Code, to be taxed as a partnership. Accordingly, no provision has been made for Federal and State income taxes on income recognized. #### NOTE B - INCOME TAXES Statements of Financial Accounting Standards require companies to disclose unrecognized tax benefits and liabilities. The Company operates as a Limited Liability Company (LLC) and is not subject to Federal income taxes. However, with limited exceptions the tax records of the Company generally remain open for three years for federal income tax examination and four years for state income tax examination. Management has evaluated the effect of the guidance and all other tax positions that could have a significant effect on the financial statements and determined that the Company had no uncertain tax positions at December 31, 2025 that required disclosure or recognition. #### NOTE C - CLEARING BROKERS The Company has a clearing agreement with National Financial Services, LLC (NFS) as a clearing agent. Either party may terminate the agreement with 90 days written notice, NFS requires the Company to maintain net capital of \$250,000 and an escrow deposit of \$75,000, subject to change at the discretion of NFS. The Company also has a clearing agreement with Pershing, LLC (Pershing) as a clearing agent. The agreement remains in effect unless either party terminates the agreement with 90 days written notice . Pershing requires the Company to maintain net capital of \$250,000 and an escrow deposit of \$100,000, subject to change at the discretion of Pershing. #### NOTE D - RELATED PARTY TRANSACTIONS Spire Wealth Management, LLC, a sister company, is paid management fees for providing all management services to the Company. The set rate per month is determined at the beginning of each year based on estimated use of management services, as set forth in the Expense Sharing Agreement between Spire Securities, LLC and Spire Wealth Management, LLC. Additionally, the Company is paid a set RIA override fee for the services it provides in overseeing the activities of its sister company RIA, Spire Wealth Management, LLC. As a result of these transactions and short-term loans between these related entities, Spire Wealth Management, LLC owed the Company \$0 as of December 31, 2025. {12}------------------------------------------------ #### SPIRE SECURITIES, LLC December 31, 2025 Spire Securities, LLC and Spire Wealth Management, LLC are wholly owned subsidiaries of Spire Investment Partners, LLC. #### NOTE E - OFFICE LEASE The Company occupies space that is leased by the sister company. The company makes a fixed monthly payment, based upon estimated use at the beginning of the fiscal year, for office services. The rent component of office services expense for the years ended December 31, 2025, was \$155,856. #### NOTE F - NET CAPITAL REQUIREMENTS The Company is subject to the Securities and Exchange Commission Uniform Net Capital Rule (Rule l5c3-l), which requires the maintenance of minimum net capital and requires that the ratio of aggregate indebtedness to net capital, both as defined, shall not exceed 10 to 1. Rule 15c3-1 further requires all brokers not generally carrying customers ' accounts to maintain net capital of not less than \$100,000 or one-fifteenth of the Company' s aggregate indebtedness, whichever is greater. At December 31, 2025, the Company's aggregate indebtedness to net capital ratio was 0.3716 to 1 and the Company had net capital of \$693,944, which was \$593,944 in excess of its required net capital of \$100,000 #### NOTE G - CONCENTRATIONS OF CREDIT RISK Financial instruments that potentially subject the Company to concentrations of credit risk consist of the receivable from clearing organization and cash and cash equivalents. The Company grants credit terms in the normal course of business to its clearing brokers for payment of commissions for customer trades. As part of its ongoing procedures, the Company monitors the credit worthiness of its clearing broker. The Company maintains cash in bank deposit accounts that, at times, may exceed federally insured limits. The Company has not experienced any losses in such accounts. Management believes the Company is not exposed to any significant risk related to cash. #### NOTE H - FAIR VALUE MEASUREMENTS Unless disclosed otherwise, the Company estimates that the fair value of all financial and non-financial instruments at December 31, 2025 does not differ materially from the aggregate carrying values recorded in the accompanying statement of financial condition. The estimated fair value amounts have {13}------------------------------------------------ # SPIRE SECURITIES, LLC # December 31, 2025 been determined by the Company using available market information and appropriate valuation methodologies. Considerable judgment is necessarily required in interpreting market data to develop the estimates of fair value, and, accordingly, the estimates are not necessarily indicative of the amounts that the Company could realize in a current market exchange. ### NOTE I - CONTINGENT LIABILITIES The Company has no commitments, contingencies, or guarantees as of December 31, 2025. # NOTE J - SUBSEQUENT EVENTS Management evaluated all events and transactions that occurred after December 31, 2024, through February 25, 2026 the date we issued these financial statements. # NOTE K – SEGMENT REPORTING The Accounting Standards Update (ASU) 2023-07 issued by the Financial Accounting Standards Board (FASB) introduced enhancements to segment reporting requirements for public entities, including broker-dealers. The update aimed to improve the transparency and usefulness of financial disclosures for investors and other stakeholders. ASU 2023-07 disclosure requirements are effective for fiscal years starting after December 15, 2024. The chief operating decision maker is the President of the Company and determined that no additional disclosures are required as the Company has only one reportable segment. {14}------------------------------------------------ #### SUPPLEMENTARY FINANCIAL INFORMATION #### SPIRE SECURITIES, LLC ### MCLEAN, VIRGINIA December 31, 2025 {15}------------------------------------------------ #### SCHEDULE I # SPIRE SECURITIES, LLC COMPUTATION OF NET CAPITAL UNDER RULE 15C3-1 OF THE SECURITIES AND EXCHANGE COMMISSION AS OF DECEMBER 31, 2025 #### **COMPUTATION OF NET CAPITAL** | Total member's equity qualified for net capital | | | \$
855,985 | |----------------------------------------------------|----|--------|---------------| | Deductions and/or charges
Non-allowable assets: | | | | | Concession receivable in excess of the payable | \$ | 97,966 | | | Deposit held by FINRA | | 60,731 | | | Prepaid expenses | | 3,344 | 162,041 | | Net capital | | | \$
693,944 | | AGGREGATE INDEBTEDNESS | | | | | Items included in statement of financial condition | | | | | Accounts payable | | | \$
28,303 | | Commissions payable | | | 225,960 | | Total aggregate indebtedness | | | \$ 254,263 | {16}------------------------------------------------ ### SCHEDULE I (CONTINUED) # SPIRE SECURITIES, LLC COMPUTATION OF NET CAPITAL UNDER RULE 15C3-1 OF THE SECURITIES AND EXCHANGE COMMISSION AS OF DECEMBER 31, 2025 # **COMPUTATION OF BASIC NET CAPITAL REQUIREMENT** | Minimum net capital required (6 2/3% of total
aggregate indebtedness) | \$
16,951 | |-------------------------------------------------------------------------------|--------------| | Minimum dollar net capital requirement of
reporting broker or dealer | \$ 100,000 | | Net capital requirement (greater of above two
minimum requirement amounts) | \$ 100,000 | | Net capital in excess of required minimum | \$ 593,944 | | Ratio: Aggregate indebtedness to net capital | 0.40 to 1 | # **RECONCILIATION WITH COMPANY'S COMPUTATION** There were no material differences in the computation of net capital under Rule 15c3-1 from the Company's computation in its unaudited Focus IIA Report. {17}------------------------------------------------ #### SCHEDULE II #### COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS #### December 31, 2025 The Company is exempt from the Securities Exchange Commission ("SEC") Rule 105c3-3 pursuant to both the exemptive provisions of sub-paragraph (k)(2)(ii) and is considered a "Non-Covered Firm" from 15c3-3 by relying on footnote 74 to SEC Release 34-70073 and therefore, is not required to maintain a "Special Reserve Bank Account for the Exclusive Benefit of Customers" #### SCHEDULE III #### INFORMATION RELATING TO THE POSSESSION OR CONTROL REQUIREMENTS #### December 31, 2025 The Company is exempt from the Securities Exchange Commission ("SEC") Rule 105c3-3 pursuant to both the exemptive provisions of sub-paragraph (k)(2)(ii) and is considered a "Non-Covered Firm" from 15c3-3 by relying on footnote 74 to SEC Release 34-70073 and therefore, is not required to maintain a "Special Reserve Bank Account for the Exclusive Benefit of Customers" {18}------------------------------------------------ ![](_page_18_Picture_0.jpeg) ### Report of Independent Registered Public Accounting Firm To the Member and Those Charged With Governance Spire Securities, LLC We have reviewed the accompanying Exemption Report of Spire Securities, LLC (the Company) as of and for the fiscal year ended December 31, 2025, in which management asserts that: 1. Pursuant to paragraph (k)(2)(ii) of 17 C.F.R. § 240.15c3-3, the Company claimed an exemption from 17 C.F.R. § 240.15c3-3 throughout the fiscal year ended December 31, 2025; 2. The Company limited its securities business activities throughout the fiscal year ended December 31, 2025 to: (1) acting as a mutual fund retailer (2) broker or dealer selling variable life insurance or annuities (3) broker or dealer selling tax shelters or limited partnerships in primary distributions (4) private placements (5) engaging in merger and acquisition activities in the private market place; and 3. Throughout the fiscal year ended December 31, 2025, the Company: (i) did not receive, hold, or owe funds or securities for or to customers (except amounts received and promptly transmitted in accordance with 17 C.F.R. § 240.15c2-4(a) or (b)(2)); (ii) did not cary accounts of or for customers; and (iii) did not carry proprietary accounts of other broker-dealers (as defined in 17 C.F.R. § 240.15c3-3). Management of the Company is responsible for the assertions in the Exemption Report and for compliance with the applicable requirements. We conducted our review in accordance with attestation standards established by the Public Company Accounting Oversight Board (United States). A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's assertions. Accordingly, we do not express such an opinion. Based on our review, nothing came to our attention that caused us to believe that management's assertions referred to above are not fairly stated, in all material respects, based on the criteria set forth in paragraph (k)(2)(ii) of Rule 15c3-3 under the Securities Exchange Act of 1934. Sanville & Company, LLC Dallas, Texas February 24, 2026 325 North Saint Paul Street Suite 3100 Dallas, Texas 75201 214.738.1998 {19}------------------------------------------------ # Spire Securities, LLC Exemption Report Spire Securities, LLC (the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C.F.R. §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)(1) and (4). To the best of its knowledge and belief, the Company states the following: - (1) The Company claimed an exemption from 17 C.F.R. §240.15c3-3 under the following provisions of 17 C.F.R. §240.15c3-3(k)(2)(ii). - (2) The Company met the identified exemption provisions in 17 C.F.R. §240.15c3-3(k) throughout the most recent fiscal year without exception. - (3) The Company is considered "Non-Covered Firm" exempt from 17 C.F.R. §240.15c3-3 and is filing an Exemption Report relying on footnote 74 to SEC Release 34-70073, and as discussed in Q&A 8 of the related FAQ issued by the SEC staff. The Company limits its business activities exclusively to: (1) acting as a mutual fund retailer (2) broker or dealer selling variable life insurance or annuities (3) broker or dealer selling tax shelters or limited partnerships in primary distributions (4) private placements (5) engaging in merger and acquisition activities in the private market place. - (4) 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; (2) did not cary 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. I, Robert Lord, swear (or affirm) that, to my best knowledge and belief, this exemption report is true and correct. Regards, Robert Lord, Chief Operations Officer Date of Report: February 6, 2026 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.