# ALPS PORTFOLIO SOLUTIONS DISTRIBUTOR, INC. X-17A-5 (2026-03-02) — Broker-dealer annual report

- Company: ALPS PORTFOLIO SOLUTIONS DISTRIBUTOR, INC.
- Form: X-17A-5
- Filed: 2026-03-02
- Period: 2025-12-31
- Accession: 0001403614-26-000002
- CIK: 1403614
- File #: 8-67659
- Type: Broker-dealer
- Material weakness: No
- Auditor: FORVIS MAZARS, LLP
- Auditor location: Denver, CO
- Contact: Eric Parsons
- Phone: 720.917.0727
- Email: eric.parsons@sscinc.com
- Website: sscinc.com
- Signed by: Eric Parsons (Controller and FINOP)

Original filing: https://www.sec.gov/Archives/edgar/data/1403614/000140361426000002/2025_APSD_audit_public.pdf

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# **ALPS Portfolio Solutions Distributor, Inc.**

**Statement of Financial Condition December 31, 2025**

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ALPS Portfolio Solutions Distributor, Inc.

# 01/01/25 12/31/25

8-67659

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| 1290<br>Broadway,<br>Suite<br>1000                         |         |
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| Denver<br>Colorado                                         | 80203   |
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| Eric<br>Parsons<br>303.623.2577<br>eric.parsons@sscinc.com |         |
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| FORVIS<br>MAZARS,<br>LLP                                   |         |
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| 1801<br>California<br>Street<br>Denver<br>CO               | 80202   |
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| 10/16/2003<br>686                                          |         |
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| Eric Parsons |       | swear (or affirm) that, to the best of my knowledge and belief, the                   |       |
|--------------|-------|---------------------------------------------------------------------------------------|-------|
|              |       | financial report pertaining to the firm of ALPS Portfolio Solutions Distributor, Inc. | as of |
| December 31  | ว 025 | is true and carroot furthar quaar or affirm that nathar the company nor any           |       |

Eric Parsons ALPS Portfolio Solutions Distributor, Inc. December 31 <sup>025</sup> Controller and FINOP

| Signature: 6 - | Cur tassons |
|----------------|-------------|
|                |             |

| Title:               |  |
|----------------------|--|
| Controller and FINOP |  |

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# **ALPS Portfolio Solutions Distributor, Inc. Table of Contents December 31, 2025**

| Report of Independent Registered Public Accounting Firm  | Page<br>1 |  |
|----------------------------------------------------------|-----------|--|
| Financial Statement:<br>Statement of Financial Condition | 2         |  |
| Notes to the Financial Statement                         | 3         |  |

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![](_page_4_Picture_1.jpeg)

# Report of Independent Registered Public Accounting Firm

Board of Directors and Stockholder ALPS Portfolio Solutions Distributor, Inc. Denver, Colorado

### Opinion on the Financial Statement

We have audited the accompanying statement of financial condition of ALPS Portfolio Solutions Distributor, Inc. (the "Company") as of December 31, 2025, including the related notes (collectively referred to as the "financial statement"). In our opinion, the financial statement presents fairly, in all material respects, the financial position of the Company as of December 31, 2025, in conformity with accounting principles generally accepted in the United States of America.

# Basis for Opinion

This financial statement is the responsibility of the Company's management. Our responsibility is to express an opinion on the Company's financial statement 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 statement is free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statement, 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 statement. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall financial statement presentation. We believe that our audit provides a reasonable basis for our opinion.

We have served as the Company's auditor since 2020.

Denver, Colorado March 2, 2026

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# **ALPS Portfolio Solutions Distributor, Inc. Statement of Financial Condition (Confidential treatment requested) December 31, 2019**

| Assets                                                                                |                 |
|---------------------------------------------------------------------------------------|-----------------|
| Cash and cash equivalents                                                             | \$<br>2,019,760 |
| Accounts receivable                                                                   | 873             |
| Receivable from SS&C GIDS                                                             | 15,963          |
| Prepaid expenses, deposits and other assets                                           | 98,907          |
| Total assets                                                                          | \$<br>2,135,503 |
| Liabilities and Stockholder's Equity                                                  |                 |
| Accounts payable and accrued expenses                                                 | \$<br>58,592    |
| Payable to financial intermediaries                                                   | 287,015         |
| Total liabilities                                                                     | 345,607         |
| Stockholder's Equity                                                                  |                 |
| Common stock, \$0 par, 100,000 shares authorized, 1,000 shares issued and outstanding | -               |
| Paid-in capital                                                                       | 1,595,314       |
| Retained earnings                                                                     | 194,582         |
| Total stockholder's equity                                                            | 1,789,896       |
| Total liabilities and stockholder's equity                                            | \$<br>2,135,503 |

The accompanying notes are an integral part of these financial statements.

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### **1. Description of Business and Basis for Presentation**

ALPS Portfolio Solutions Distributor, Inc. ("we", "our", "us", the "Company" or "APSD") is a whollyowned subsidiary of ALPS Holdings, Inc. ("AHI"). AHI is a wholly-owned subsidiary of SS&C GIDS, Inc. ("SS&C GIDS"), which is a wholly-owned subsidiary of SS&C Technologies Holdings, Inc. ("SS&C"). APSD is a registered broker-dealer with the Securities and Exchange Commission and a member of the Financial Industry Regulatory Authority ("FINRA") and the Securities Investor Protection Corporation ("SIPC").

The Company is engaged in a single line of business as a securities broker-dealer. We perform various services related to the funds we distribute, which include: supervising and maintaining licenses of brokerdealer staff, reviewing and approving marketing materials, acting as legal underwriter/distributor of mutual funds, facilitating 12b-1 plans, executing broker/dealer selling agreements, performing due diligence on financial intermediaries, and administering the firm and regulatory element for registered representatives.

The Company has identified its President as the chief operating decision maker ("CODM"), who uses net income to evaluate the results of the business, predominately in the forecasting process, to manage the Company. Additionally, the CODM uses excess net capital (see Note 6), which is not a measure of profit and loss, to make operational decisions while maintaining capital adequacy, such as whether to reinvest profits or pay dividends. The Company's operations constitute a single operating segment and therefore, a single reportable segment, because the CODM manages the business activities using information of the Company as a whole. The accounting policies used to measure the profit and loss of the segment are the same as those described in the summary of significant accounting policies (see Note 2).

We operate under the provisions of paragraph (k)(1) of Rule 15c3-3 of the Securities Exchange Act of 1934 and, accordingly, we claim exemption from the remaining provisions of that Rule.

### **2. Summary of Significant Accounting Policies**

### **Use of estimates**

The preparation of the financial statement 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 Statement of Financial Condition. Actual results could differ from those estimates.

### **Cash and cash equivalents**

Cash represents cash held at financial institutions. Cash accounts are in FDIC insured accounts that are insured up to \$250,000. The Company's cash balances are greater than the insured amount.

Short-term liquid investments with an original maturity of 90 days or less are considered cash equivalents. Due to the short-term nature of these investments, carrying value approximates market value.

### **Accounts receivable**

Accounts receivable are stated at the amount billed to fund clients. We provide an allowance for bad debt, which is based upon a review of outstanding receivables, historical collection information and existing economic conditions. Delinquent receivables may be written off based on specific circumstances of the fund clients. Accounts receivable, net resulting from contracts with customers were \$873 and \$21,818 at December 31, 2025 and 2024, respectively.

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### **Payable to financial intermediaries**

Payable to financial intermediaries represent pass-through fees received by the Company from customers but have not yet been remitted to the respective financial intermediaries.

### **Income taxes**

APSD is included within the consolidated federal income tax return of SS&C. We compute income tax expense and income taxes payable to SS&C under an intercompany tax allocation policy which approximates the separate return method. The tax sharing policy provides for compensation for tax benefits of losses and credits to the extent utilized by other members in the consolidated tax return. Deferred income tax effects of transactions reported in different periods for financial reporting purposes are recorded under the liability method. This method gives consideration to the future tax consequences of deferred income or expense items and immediately recognizes changes in income tax laws upon enactment. We recognize interest and penalties accrued related to unrecognized tax benefits, if any, in income tax expense.

From time to time, we may enter into transactions for which the tax treatment under the Internal Revenue Code or applicable state tax laws is uncertain. In these instances, we provide federal and/or state income taxes on such transactions, together with related interest, net of income tax benefit, and any applicable penalties.

### **Fair value of financial instruments**

Fair value is defined as the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date. Various valuation inputs are used to determine fair value according to a three-level hierarchy. Such inputs are defined broadly as follows:

- Level 1 Unadjusted quoted prices in active markets for identical instruments that the reporting entity has the ability to access at the measurement date.
- Level 2 Prices or valuations based on other significant observable inputs (including quoted prices for similar securities, interest rates, etc.) for the instruments.
- Level 3 Prices or valuations based on significant unobservable inputs (including the entity's own assumptions in determining fair value) for the instruments.

The Company had no assets or liabilities measured on a recurring basis during the year or at December 31, 2025 which were deemed Level 1, Level 2 or Level 3, other than a Level 1 money market mutual fund of \$1,682,745 that is classified as cash and cash equivalents in the Statement of Financial Condition.

Substantially all of the Company's financial assets and liabilities are carried at fair value or at amounts which, because of their short-term nature, approximate fair value.

### **Subsequent events**

The Company has performed an evaluation of subsequent events through March 2, 2026, which is the date the financial statement was issued. We do not have any material undisclosed reportable subsequent events.

### **3. Income Taxes**

Deferred tax assets and liabilities are determined based on the differences between the financial statement and tax basis of assets and liabilities as measured by the enacted tax rates which will be in effect when these differences reverse. Deferred tax expense (benefit) is generally the result of changes in the assets or liabilities for deferred taxes. There were no deferred tax assets or liabilities at December 31, 2025.

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Various state and local income tax returns of the SS&C consolidated group are under examination by taxing authorities. We do not believe that the outcome of any examination will have a material impact on our financial statements.

### **4. Related Party Transactions**

APSD and ALPS Fund Services, Inc. ("AFS"), have entered into an expense allocation agreement, which calls for AFS to pay various overhead and operating expenses of APSD which were allocated by AHI and subsidiaries and APSD agrees to reimburse SS&C GIDS for such costs paid on its behalf, including amounts paid to AFS. APSD records expenses in amounts determined according to a systematic allocation, applied on a consistent basis in accordance with the expense allocation agreement. For the year ended December 31, 2025, the allocation was determined based on our percentage of revenue to the total consolidated revenue of AHI and subsidiaries. No amounts were payable at December 31, 2025.

APSD is the distributor for various funds that wholly owned subsidiaries of AHI advise and actively distribute.

The Company has a Cash Management and Credit Agreement with SS&C GIDS whereby certain cash collections and payments are made by SS&C GIDS on behalf of the Company. At December 31, 2025, we had a receivable from SS&C GIDS of \$15,963 which represents a net balance as the result of cash received from revenue and cash paid for expenses by SS&C GIDS. These amounts are settled periodically throughout the year.

### **5. Significant Estimates and Concentrations**

Accounting principles generally accepted in the United States of America require disclosure of certain significant estimates and current vulnerabilities due to certain concentrations. Those matters include the following:

### **Credit risk**

Cash balances which exceed Federal Deposit Insurance Corporation insurance coverage limits subject us to a concentration of credit risk.

### **Current economic conditions**

Economic and financial market conditions could adversely affect the results of operations in future periods. Instability in the financial markets may significantly impact the volume of future sales, which could have an adverse impact on our future operating results.

In addition, given the volatility of economic conditions, the values of assets and liabilities recorded in the financial statements could change rapidly, resulting in material future adjustments in allowances for accounts receivable that could negatively impact our ability to maintain sufficient liquidity.

### **Other contingencies**

We are involved in other legal and regulatory proceedings arising in the normal course of our business. While the ultimate outcome of these proceedings cannot be predicted with certainty, it is the opinion of management, after consultation with legal counsel, that the final outcome in such proceedings, in the aggregate, would not have a material adverse effect on our Statement of Financial Condition.

### **Indemnifications**

In the normal course of business, we enter into contracts that contain a variety of representations and warranties which provide general indemnifications. Our maximum exposure under these arrangements is

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unknown as the contracts refer to potential claims that have not yet occurred. However, management expects the risk of loss to be remote.

### **6. Net Capital Requirements**

We are subject to the Securities and Exchange Commission Uniform Net Capital Rule (Rule 15c3-1), which requires the maintenance of a minimum net capital requirement. We have elected the alternative net capital method. This method establishes a minimum net capital requirement of the greater of \$250,000 or 2% of aggregate debits, pursuant to Rule 15c3-3. At December 31, 2025, we had net capital of \$1,640,498, which was \$1,390,498 in excess of our required net capital of \$250,000.

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### **GENERAL ASSESSMENT FORM**

For the fiscal year ended \_\_\_\_\_\_\_\_\_\_ 12/31/2025

|   | Determination of "SIPC NET Operating Revenues" and General Assessment for:<br>MEMBER NAME<br>ALPS PORTFOLIO SOLUTIONS DISTRIBUTOR INC<br>1/1/2025<br>For the fiscal period beginning ______________ and ending ____________                                                                                                                                                | SEC No.<br>8-67659<br>12/31/2025    |                                     |
|---|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------|-------------------------------------|
| 1 | Total Revenue (FOCUS Report – Statement of Income (Loss) – Code 4030)                                                                                                                                                                                                                                                                                                      |                                     | \$ 311,124.00<br>__________________ |
| 2 | Additions:                                                                                                                                                                                                                                                                                                                                                                 |                                     |                                     |
|   | a Total<br>revenues<br>from<br>the<br>securities<br>business<br>of<br>subsidiaries<br>(except<br>foreign<br>subsidiaries)<br>and<br>predecessors<br>not<br>included<br>above.                                                                                                                                                                                              | __________________                  |                                     |
|   | b Net<br>loss<br>from<br>principal<br>transactions<br>in<br>securities<br>in<br>trading<br>accounts.                                                                                                                                                                                                                                                                       | __________________                  |                                     |
|   | c Net<br>loss<br>from<br>principal<br>transactions<br>in<br>commodities<br>in<br>trading<br>accounts.                                                                                                                                                                                                                                                                      | __________________                  |                                     |
|   | d Interest<br>and<br>dividend<br>expense<br>deducted<br>in<br>determining<br>item<br>1.                                                                                                                                                                                                                                                                                    | __________________                  |                                     |
|   | e Net<br>loss<br>from<br>management<br>of<br>or<br>participation<br>in<br>the<br>underwriting<br>or<br>distribution<br>of<br>securities.                                                                                                                                                                                                                                   | __________________                  |                                     |
|   | f Expenses<br>other<br>than<br>advertising,<br>printing,<br>registration<br>fees<br>and<br>legal<br>fees<br>deducted in determining net profit management of or participation in<br>underwriting or distribution of securities.                                                                                                                                            | __________________                  |                                     |
|   | g Net loss from securities in investment accounts.                                                                                                                                                                                                                                                                                                                         | __________________                  |                                     |
|   | h Add lines 2a through 2g. This is your total additions.                                                                                                                                                                                                                                                                                                                   |                                     | \$ 0.00<br>__________________       |
| 3 | Add lines 1 and 2h                                                                                                                                                                                                                                                                                                                                                         |                                     | \$ 311,124.00<br>__________________ |
| 4 | Deductions:                                                                                                                                                                                                                                                                                                                                                                |                                     |                                     |
|   | a Revenues from the distribution of shares of a registered open end investment<br>company or unit investment trust, from the sale of variable annuities, from the<br>business of insurance, from investment advisory services rendered to<br>registered investment companies or insurance company separate accounts<br>and from transactions in security futures products. | \$ 216,402.00<br>__________________ |                                     |
|   | b Revenues from commodity transactions.                                                                                                                                                                                                                                                                                                                                    | __________________                  |                                     |
|   | c Commissions, floor brokerage and clearance paid to other SIPC members<br>in connection with securities transactions.                                                                                                                                                                                                                                                     | __________________                  |                                     |
|   | d Reimbursements for postage in connection with proxy solicitations.                                                                                                                                                                                                                                                                                                       | __________________                  |                                     |
|   | e Net gain from securities in investment accounts.                                                                                                                                                                                                                                                                                                                         | __________________                  |                                     |
|   | f 100% commissions and markups earned from transactions in (I) certificates<br>of deposit and (ii) Treasury bills, bankers acceptances or commercial paper<br>that<br>mature nine months or less from issuance date.                                                                                                                                                       | __________________                  |                                     |
|   | g Direct expenses of printing, advertising, and legal fees incurred in connection<br>with other revenue related to the securities business (revenue defined by<br>Section 16(9)(L) of the Act).                                                                                                                                                                            | __________________                  |                                     |
|   | h Other revenue not related either directly or indirectly to the securities business.<br>Deductions in excess of \$100,000 require documentation                                                                                                                                                                                                                           | __________________                  |                                     |
| 5 | a Total interest and dividend expense (FOCUS Report - Statement<br>of Income (Loss) -<br>Code 4075 plus line 2d above) but<br>not<br>in excess of total interest and dividend income<br>__________________                                                                                                                                                                 |                                     |                                     |
|   | b 40% of margin interest earned on customers securities accounts<br>(40% of FOCUS Report - Statement of Income (Loss)<br>-<br>Code 3960)<br>__________________                                                                                                                                                                                                             |                                     |                                     |
|   | c Enter the greater of line 5a or 5b                                                                                                                                                                                                                                                                                                                                       | \$ 0.00<br>__________________       |                                     |
| 6 | Add lines 4a through 4h and 5c. This is your total deductions.                                                                                                                                                                                                                                                                                                             |                                     | \$ 216,402.00<br>__________________ |

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| SIPC-7<br>37 REV 0722 | SECURITIES INVESTOR PROTECTION CORPORATION                                                                                                                                                                                                                                                                                              | SIPC-7<br>37 REV 0722              |
|-----------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------|
|                       | GENERAL ASSESSMENT FORM                                                                                                                                                                                                                                                                                                                 |                                    |
|                       | 12/31/2025<br>For the fiscal year ended __________                                                                                                                                                                                                                                                                                      |                                    |
| 7                     | Subtract line 6 from line 3. This is your SIPC Net Operating Revenues.                                                                                                                                                                                                                                                                  | \$ 94,722.00<br>__________________ |
| 8                     | Multiply line 7 by .0015. This is your General Assessment.                                                                                                                                                                                                                                                                              | \$ 142.00<br>__________________    |
| 9                     | Current overpayment/credit balance, if any                                                                                                                                                                                                                                                                                              | \$ 0.00<br>__________________      |
| 10                    | \$ 70.00<br>2025<br>__________________<br>General assessment from last filed<br>_____<br>SIPC-6 or 6A                                                                                                                                                                                                                                   |                                    |
|                       | \$ 0.00<br>2025<br>__________________<br>11 a Overpayment(s) applied on all _____ SIPC-6 and 6A(s)<br>\$ 0.00<br>b Any other overpayments applied<br>__________________<br>\$ 70.00<br>2025<br>c All payments applied for _____ SIPC-6 and 6A(s)<br>__________________<br>\$ 70.00<br>__________________<br>d Add lines 11a through 11c |                                    |
| 12                    | LESSER of line 10 or 11d.                                                                                                                                                                                                                                                                                                               | \$ 70.00<br>__________________     |
|                       | \$ 142.00<br>__________________<br>13 a Amount from line 8<br>\$ 0.00<br>b Amount from line 9<br>__________________<br>\$ 70.00<br>c Amount from line 12<br>__________________                                                                                                                                                          |                                    |
|                       | d Subtract lines 13b and 13c from 13a. This is your assessment balance due.                                                                                                                                                                                                                                                             | \$ 72.00<br>__________________     |
| 14                    | 0<br>Interest (see instructions) for ______ days late at 20% per annum                                                                                                                                                                                                                                                                  | \$ 0.00<br>__________________      |
| 15                    | Amount you owe SIPC. Add lines 13d and 14.                                                                                                                                                                                                                                                                                              | \$ 72.00                           |
| 16                    | Overpayment/credit carried forward (if applicable)                                                                                                                                                                                                                                                                                      | \$ 0.00<br>__________________      |
| SEC No.<br>8-67659    | Designated Examining Authority<br>FYE<br>Month<br>DEA: FINRA<br>2025<br>Dec<br>MEMBER NAME                                                                                                                                                                                                                                              |                                    |
|                       | ALPS PORTFOLIO SOLUTIONS DISTRIBUTOR INC<br>MAILING ADDRESS<br>1290 BROADWAY STE 1000                                                                                                                                                                                                                                                   |                                    |

 Subsidiaries (S) and predecessors (P) included in the form (give name and SEC number)

DENVER, CO 80203 UNITED STATES

 By checking this box, you certify that you have the authority of the SIPC member to sign this form; that all information in this form is true and complete; and that on behalf of the SIPC member, you are authorized, and do hereby consent, to the storage and handling by SIPC of the data in accordance with SIPC's Privacy Policy ✔

| ALPS PORTFOLIO SOLUTIONS DISTRIBUTOR INC<br>______________________________________________________ | Eric Parsons<br>_______________________________            |  |
|----------------------------------------------------------------------------------------------------|------------------------------------------------------------|--|
| (Name of SIPC Member)                                                                              | (Authorized Signatory)                                     |  |
| 2/18/2026<br>______________________________________________________                                | eric.parsons@sscinc.com<br>_______________________________ |  |
| (Date)                                                                                             | (e-mail address)                                           |  |
|                                                                                                    |                                                            |  |

Completion of the "Authorized Signatory" line will be deemed a signature.

*This form and the assessment payment are due 60 days after the end of the fiscal year.* 

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# Independent Registered Public Accounting Firm's Agreed-Upon Procedures Report on General Assessment Reconciliation (Form SIPC-7)

Board of Directors and Stockholder ALPS Portfolio Solutions Distributor, Inc. Denver, Colorado

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 ALPS Portfolio Solutions Distributor, Inc. (the "Company") is responsible for its Form SIPC-7 and for its compliance with the applicable instructions on Form SIPC-7.

Management of the Company has agreed to and acknowledged that the procedures are appropriate to meet the intended purpose of assisting you and SIPC in evaluating the Company's compliance with the applicable instructions on Form SIPC-7 for the year ended December 31, 2025. In addition, SIPC has agreed to and acknowledged that the procedures performed are appropriate for their intended purpose. 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 sufficiency 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, noting no differences;
- 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 noting no differences; and
- 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.

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We were engaged by the Company to perform this agreed-upon procedures engagement and conducted our engagement in accordance with attestation standards established by the AICPA and in accordance with the standards of the Public Company Accounting Oversight Board (United States). We were not engaged to, and did not conduct an examination or a review engagement, the objective of which would be the expression of an opinion or conclusion, respectively, on the Company's Form SIPC-7 and for its compliance with the applicable instructions on Form SIPC-7 for the year ended December 31, 2025. Accordingly, we do not express such an opinion or conclusion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you.

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

This report is intended solely for the information and use of the Company, and the SIPC and is not intended to be and should not be used by anyone other than these specified parties.

Denver, Colorado March 2, 2026


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