# LASALLE INVESTMENT MANAGEMENT DISTRIBUTORS, LLC X-17A-5 (2026-02-27) — Broker-dealer annual report - Company: LASALLE INVESTMENT MANAGEMENT DISTRIBUTORS, LLC - Form: X-17A-5 - Filed: 2026-02-27 - Period: 2025-12-31 - Accession: 0001518365-26-000001 - CIK: 1518365 - File #: 8-68856 - Type: Broker-dealer - Material weakness: No - Auditor: KPMG, LLP - Auditor location: New York, NY - Contact: Kristina Meyer - Phone: 312-897-4039 - Email: estee@dorfman-finop.com - Website: dorfman-finop.com - Signed by: Kristina Meyer (President) Original filing: https://www.sec.gov/Archives/edgar/data/1518365/000151836526000001/2025annualaudit.pdf --- {0}------------------------------------------------ | | UNITED STATES | | OMB APPROVAL | | | | |--------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------|----------------|-------------------------------------------------------------------------------------------------------|--|--|--| | SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549 | | | OMB Number: 3235-0123
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8-68856 | | | | | | FORM X-17A-5 | | | | | | | | PART IIШ | | | | | | | Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934 | FACING PAGE | | | | | | | FILING FOR THE PERIOD BEGINNING 01/01/2025 | | | AND ENDING 12/31/2025 | | | | | | MM/DD/YY | | MM/DD/YY | | | | | | A. REGISTRANT IDENTIFICATION | | | | | | | NAME OF FIRM: LaSalle Investment Management Distributors, LLC | | | | | | | | TYPE OF REGISTRANT (check all applicable boxes):
Broker-dealer ☐ Security-based swap dealer
Check here if respondent is also an OTC derivatives dealer | | | Major security-based swap participant | | | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) | | | | | | | | 333 West Wacker Drive, Suite 2300 | | | | | | | | | (No. and Street) | | | | | | | Chicago | IL | | 60606 | | | | | (City) | (State) | | (Zip Code) | | | | | | | | | | | | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | | | | | Estee Dorfman | (781)780-7069 | | estee@dorfman-finop.com | | | | | (Name) | (Area Code - Telephone Number) | | (Email Address) | | | | | | B. ACCOUNTANT IDENTIFICATION | | | | | | | INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing* | | | | | | | | KPMG, LLP | | | | | | | | | (Name - if individual, state last, first, and middle name) | | | | | | | Two Manhattan West | New York | NY | 10001 | | | | | (Address)
10/20/2003 | (City) | (State)
185 | (Zip Code) | | | | | (Date of Registration with PCAOB)(if applicable) | | | (PCAOB Registration Number, if applicable) | | | | | | FOR OFFICIAL USE ONLY | | | | | | | | | | | | | | CFR 240.17a-5(e)(1)(ii), if applicable. Persons who are to respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB control number. {1}------------------------------------------------ - - - - - - - - - - - - - - - - - - - - - - - - - - - {2}------------------------------------------------ Financial Statements and Schedules December 31, 2025 (With Report of Independent Registered Public Accounting Firm) {3}------------------------------------------------ #### **Table of Contents** | | Page | |------------------------------------------------------------------------------------------------------------------------------------------|------| | Report of Independent Registered Public Accounting Firm | 3 | | Financial Statements: | | | Statement of Financial Condition as of December 31, 2025 | 4 | | Statement of Operations and Other Comprehensive Income for the Year ended
December 31, 2025 | 5 | | Statement of Member's Equity for the Year ended December 31, 2025 | 6 | | Statement of Cash Flows for the Year ended December 31, 2025 | 7 | | Notes to Financial Statements | 8 | | Supplemental Schedules: | | | Schedule I - Computation of Net Capital Under Rule 15c3-1 of the Securities and
Exchange Commission | 14 | | Schedule II - Computation for Determination of Customer Reserve Requirements and
PAB Reserve Requirements under Rule 15c3-3 | 15 | | Schedule III - Information Relating to Possession or Control Requirements under Rule
15c3-3 of the Securities and Exchange Commission | 16 | {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) KPMG LLP Suite 3400 312 Walnut Street Cincinnati, OH 45202 #### **Report of Independent Registered Public Accounting Firm** To the Member and Management LaSalle Investment Management Distributors, LLC: #### *Opinion on the Financial Statements* We have audited the accompanying statement of financial condition of LaSalle Investment Management Distributors, LLC (the Company) as of December 31, 2025, the related statements of operations and other comprehensive income, member's equity, and cash flows for the year then ended, and the related notes (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 U.S. generally accepted accounting principles. #### *Basis for Opinion* These financial statements are the responsibility of the Company's management. Our responsibility is to express an opinion on these 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. 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. #### *Accompanying Supplemental Information* The supplemental information contained 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 supplemental information is the 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 supplemental information contained in Schedules I, II, and III is fairly stated, in all material respects, in relation to the financial statements as a whole. ![](_page_4_Picture_11.jpeg) We have served as the Company's auditor since 2012. Cincinnati, Ohio February 26, 2026 {5}------------------------------------------------ #### Statement of Financial Condition #### December 31, 2025 | Assets | | | | | |-------------------------------------------------|----|------------|--|--| | Cash | \$ | 9,829,043 | | | | Due from related party | | 6,071,517 | | | | Prepaid expenses | | 325,263 | | | | Total assets | \$ | 16,225,823 | | | | Liabilities and Member's Equity | | | | | | Liabilities: | | | | | | Accounts payable | \$ | 3,551,918 | | | | Due to Parent Company | | 220,915 | | | | Accrued expenses | | 1,478,376 | | | | Employee commissions payable | | 396,119 | | | | Total liabilities | | 5,647,328 | | | | Equity: | | | | | | Member's equity | | 10,576,372 | | | | Accumulated other comprehensive income | | 2,123 | | | | Total equity | | 10,578,495 | | | | Total liabilities and member's equity | \$ | 16,225,823 | | | | | | | | | | See accompanying notes to financial statements. | | | | | {6}------------------------------------------------ | Revenue: | | | | | |-----------------------------------------|----|------------|--|--| | Commission and dealer manager fees | | 12,237,708 | | | | Private placement | | 16,354,966 | | | | Reimbursable revenue | | 7,896,891 | | | | Interest income | \$ | 42,185 | | | | Total revenue | \$ | 36,531,750 | | | | | | | | | | Expenses: | | | | | | Selling expense | \$ | 21,965,390 | | | | Travel and entertainment expense | | 3,540,514 | | | | Employee commissions expense | | 4,315,987 | | | | Business license and professional fees | | 2,351,635 | | | | Promotional expense | | 720,088 | | | | Legal expense | | 1,031,158 | | | | Audit expense | | 215,510 | | | | Other expense | | 607,724 | | | | Total expenses | | 34,748,006 | | | | Net income | \$ | 1,783,744 | | | | Other comprehensive income: | | | | | | Foreign currency translation adjustment | | 978 | | | | Total other comprehensive income | | 978 | | | | Total comprehensive income | \$ | 1,784,722 | | | Statement of Operations and Other Comprehensive Income Year ended December 31, 2025 See accompanying notes to financial statements. {7}------------------------------------------------ #### Statement of Member's Equity #### Year ended December 31, 2025 | | Member units | Accumulated Other
Comprehensive Income | Member's equity | Total equity | |----------------------------------|--------------|-------------------------------------------|------------------|------------------| | Balances at December 31,
2024 | 500 | \$
1,145 | \$
9,792,628 | \$
9,793,773 | | Net income | — | — | 1,783,744 | 1,783,744 | | Distribution | — | | (1,000,000) \$ | (1,000,000) | | Other comprehensive
income | — | 978 | — | 978 | | Balances at December 31,
2025 | 500 | \$
2,123 | \$
10,576,372 | \$
10,578,495 | See accompanying notes to financial statements. {8}------------------------------------------------ #### Statement of Cash Flows #### Year ended December 31, 2025 | Cash flows from operating activities: | | |------------------------------------------------------------------------|-------------------| | Net income | \$
1,783,744 | | Reconciliation of net income to net cash from operating
activities: | | | Effects of changes in operating assets and liabilities: | | | Decrease in prepaid expenses | 126,794 | | Increase in due from related party | (918,600) | | Decrease in employee commissions payable | (25,349) | | Increase in accounts payable | 540,040 | | Increase in accrued expenses | 99,062 | | Decrease in due to Parent Company | (306,170) | | Net cash provided by operating activities | \$
1,299,521 | | Cash flows used by financing activities: | | | Increase in capital distributions | (1,000,000) | | Net cash provided by financing activities | \$
(1,000,000) | | | | | Net increase in cash | 299,521 | | Effect of exchange rates | 978 | | Beginning cash balance | 9,528,544 | | Ending cash balance | \$
9,829,043 | See accompanying notes to financial statements. {9}------------------------------------------------ # **(1) Organization** LaSalle Investment Management Distributors, LLC (the Company or LIMD), a subsidiary of LaSalle Investment Management, Inc. (Parent Company and Member) was formed in the state of Delaware on March 10, 2011. The Company was formed to conduct transactions as a broker-dealer to provide investment management, asset management or similar services to the Parent Company or its affiliates. The Company is the Dealer Manager for the public and private offerings of JLL Income Property Trust, Inc. (JLLIPT), an affiliate of the Parent Company. The Company is registered with the Securities and Exchange Commission (the SEC), Financial Industry Regulatory Authority (the FINRA), and various states. On December 20, 2011, the Company's FINRA membership was approved. The Company does not claim an exemption under paragraph (k) of 17 C.F.R § 240.15c3-3. The Company is relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R § 240.17a-5 because the Company limits its business activities exclusively to: (1) acting as a wholesaler and/or placement agent with respect to public non-listed REITs and the private placement of securities, including Delaware Statutory Trusts and other like-kind exchanges pursuant to Section 1031 of the Internal Revenue Code and the Company (1) did not directly or indirectly receive, hold or otherwise owe funds or securities for or to customers; (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. On March 3, 2015, JLLIPT began a private offering of up to \$350,000,000 of Class D shares of common stock. On October 7, 2025, JLLIPT began a continuous private offering of four new classes of common stock: Class S, Class D, Class Z, and Class I common stock. The offering is exempt from registration under the Securities Act pursuant to Rule 506(b) of Regulation D. In connection with the new offering, JLLIPT (i) renamed the existing Class D common stock as Class N common stock, (ii) renamed Class D OP Units as Class N OP Units, Class A OP Units as Class S OP Units, Class A-I OP Units as Class D OP Units, Class M OP Units as Class Z OP Units, and Class M-I OP Units as Class I OP Units; and (iii) updated the DST Program so that Class S OP Units, Class D OP Units, Class Z OP Units and Class I OP Units may be issued in exchange for DST interests and that subsequently Class S shares, Class D shares, Class Z shares and Class I shares may be issued in exchange for such OP Units. On June 6, 2025, the SEC declared JLLIPT's fourth follow-on Registration Statement (the Fourth Extended Public Offering") effective (Commission File No. 333-256823) to offer up to \$1,500,000,000 in shares of which \$1,200,000,000 of shares offered in the primary offering and up to \$300,000,000 in shares offered pursuant to the distribution reinvestment plan. On October 16, 2019, JLLIPT initiated the Delaware Statutory Trust Program (DST Program), and on August 6, 2024, increased the private offering up to a total of \$3,000,000. Historically and for the foreseeable future, the Company is highly dependent on the Parent Company to fund any operating losses. As of December 31, 2025, the Company was obligated to the Parent and its affiliate organizations for expenses recorded on the books and records of the Company totaling \$220,915. The Parent will not require the repayment of these expenses that the Parent or its affiliates may provide to the Company during 2026, until subsequent to February 28, 2027 as evidenced in writing by the Parent Company. {10}------------------------------------------------ # **(2) Summary of Significant Accounting Policies** # *(a) Cash* Cash includes only cash in bank accounts. ## *(b) Prepaid Expenses* Prepaid expenses represent payments made for services to be received in future periods. These items are recorded as assets on the balance sheet at the time of payment and are subsequently recognized as expenses in the statement of operations as the underlying services are consumed or the benefits are realized. ## *(c) Use of Estimates* The preparation of financial statements in conformity with U.S. generally accepted accounting principles 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 of revenue and expenses during the reporting period. Actual results could differ from those estimates. ## *(d) Limitation on Withdrawal of Equity Capital* It is the SEC's policy to require written notice two business days prior to any equity withdrawals that exceed \$500,000 and, on a net basis, exceed 30% of the Company's excess net capital, in any 30-day period. The Company made a \$1,000,000 equity distribution in 2025. ## (e) *Revenue Recognition* Upon adoption of FASB ASC 606, *Revenue from Contracts with Customers*, the Company identified revenue from contracts with customers, which includes sales commissions, dealer manager fees, placement fees, and reimbursable revenue. The recognition and measurement of revenue is based on the assessment of individual contract terms. See Note 3, Revenue Recognition, for revenue recognition disclosures required by FASB ASC 606. ## (f) *Employee Commissions Expense* In connection with the marketing of investment programs, employees of the Parent Company who are registered representatives of the Company may receive compensation based on the third-party investment in the related investment program. ## (g) *Foreign Exchange* The Company utilizes the U.S. dollar as the functional currency, except for the Canadian bank account, which use the Canadian dollar as the functional currency. When preparing financial statements, assets and liabilities of foreign entities are translated at the exchange rates at the statement of financial condition date, while revenue and expense items are translated at average rates for the period. Revenue and expense amounts of significant transactions are translated at the rate in effect as of the date of the transactions. Foreign currency translation adjustments are recorded in accumulated other comprehensive income. {11}------------------------------------------------ ## **(3) Revenue Recognition** Revenue earned during the year ended December 31, 2025 under the agreement with JLLIPT (the client) includes the following: | | Year ended December 31, 2025 | | |----------------------|------------------------------|------------| | Commissions | \$ | 453,849 | | Dealer manager fees | | 11,783,859 | | Private placement | | 16,354,966 | | Reimbursable revenue | | 7,896,891 | | Total revenue | \$ | 36,489,565 | Sales commissions are based upon a percentage of third-party investment in the related investment program. The Company recognizes the upfront sales commissions for JLLIPT Class A, A-I, S, D and N common stock on a trade date basis when the services are performed and the amount the Company is entitled to is known. JLLIPT pays upfront selling commissions per the dealer agreement. LIMD's performance obligation is wholly satisfied on the date an investor purchases shares of JLLIPT common stock or beneficial interests in the DST Program. The upfront sales commissions on the DST Program are included in private placement in the Company's statement of operations and other comprehensive income. LaSalle Investment Management Distributors, LLC serves as the dealer manager for the DST Program. JLLIPT's taxable REIT subsidiary, which is a wholly owned subsidiary of its operating partnership, will pay the dealer manager upfront selling commissions, upfront dealer manager fees and private placement fees of up to 5.0%, 1.0% and 1.0%, respectively, of the gross purchase price per unit of beneficial interest sold in the DST Program. All upfront selling commissions and upfront dealer manager fees are reallowed to participating broker-dealers and are recognized in the same manner as the selling fees detailed above. Dealer manager fees accrue daily in an amount equal to 1/365th of the stated class-specific fee based on the net asset value for each outstanding share of common stock or operating partnership. The Company accounts for dealer manager fees which are satisfied at a point in time (trade date) but are paid over time as variable fees, as they are dependent upon net asset values of JLLIPT and investor activities in periods after the trade date. The Company receives an investor servicing fee of up to 0.25% of the initial equity investment in the DST Program. Due to this constraint, the Company recognizes dealer manager fees when the net asset value of JLLIPT is known. Consequently, dealer manager fees recognized in the current period primarily relate to performance obligations that were satisfied in prior periods. The Company believes that the performance obligation is satisfied on the date the investor purchases shares of JLLIPT common stock or the beneficial interest in the DST. The transaction price is determined by the agreement between the Company and JLLIPT as disclosed in the JLLIPT prospectus. LIMD's performance obligation is satisfied on the date the investor purchases shares of JLLIPT common stock, operating partnership units, or the beneficial interest in the DST. The transaction price is determined by the agreement between the Company and JLLIPT as disclosed in the JLLIPT prospectus. The dealer manager fees are included in commission and dealer manager fees, and the investor servicing fees are included in private placement in the Company's statement of operations and other comprehensive income. {12}------------------------------------------------ The Company incurs certain costs in connection with its performance obligation to distribution services which it receives reimbursement from JLLIPT based on the Dealer Manager Agreement. Such costs are included in selling, travel and entertainment, business licenses and fees, legal, audit, promotional, and other expenses in the Company's statement of operations and other comprehensive income. The Company controls the services before they are transferred to JLLIPT and acts in the capacity of a principal. LIMD's performance obligation is wholly satisfied on the date the goods or services are exchanged. Reimbursement for these costs are generally paid monthly and is presented on a gross basis in reimbursable revenue in the Company's statement of operations and other comprehensive income. ## **(4) Income Taxes** The Company is a limited liability company which is treated for federal and state income tax purposes as a disregarded entity and is not subject to income taxes. Accordingly, the accompanying financial statements contain no provision for income taxes. The Company had no uncertain tax positions which would require the Company to record a tax exposure liability as of December 31, 2025. The Company does not have a tax-sharing agreement with the Parent Company and no payments have been made between the Company and its Parent Company for tax reimbursements. The Company has evaluated the net difference between the tax bases and reported amounts of its assets and liabilities. Management has determined that these differences are not material to the consolidated financial statements. Accordingly, the adoption of ASC 740-10-50-16, did not have a material effect on the Company's financial position, results of operations, or cash flows. #### **(5) Net Capital Requirement** As a registered broker-dealer, the Company is subject to the SEC Uniform Net Capital Rule 15c3-1, which requires the Company to maintain minimum net capital and maintain an allowable ratio of aggregate indebtedness to net capital of 6 2/3%. At December 31, 2025, the Company had net capital and net capital requirements of \$7,151,036 and \$376,488, respectively. At December 31, 2025, the Company's ratio of aggregate indebtedness to net capital was approximately 0.79 to 1. ## **(6) Limited Liability Company Agreement** Pursuant to the terms of the Amended and Restated LLC Agreement, LaSalle Investment Management, Inc. is the sole member of the Company and contributes to the management of the operations of the Company. The Company shall terminate on December 31, 2111, unless terminated earlier as provided in the LLC Agreement. Except as provided in the Delaware Limited Liability Company Act, a member shall not be personally liable for any debt, obligation, or liability of the Company solely by reason of being a member of a limited liability company. {13}------------------------------------------------ ## **(7) Concentration of Credit Risk and Commitments and Contingencies** The Company's financial instruments that are exposed to concentrations of credit risk consist primarily of cash. The Company places its cash with financial institutions in amounts that at times exceed the Federal Deposit Insurance Corporation insurance limit of \$250,000. The Company has not experienced any losses in such accounts and does not believe it is exposed to any significant credit risk on cash. The Company is subject to certain legal proceedings and claims arising out of the conduct of its business. In accordance with ASC 450, Contingencies, a reserve for estimated losses is recorded when the amount is probable and can be reasonably estimated. The Company does not believe that any pending legal proceedings will have a material impact on the Company's financial condition or results of operations. All revenue streams, excluding interest income generated from cash deposits, are derived exclusively from contractual arrangements and business transactions with Jones Lang LaSalle Income Property Trust, Inc. (JLLIPT), representing a material concentration risk given the company's complete reliance on this single counterparty for substantially all operating revenues. #### **(8) Segment Reporting** The Company operates as a single reportable segment, providing transaction, private placement, and investment advisory services. The Company has identified a group of individuals, comprised of the President, Principal Operating Officer, and Financial and Operations Principal (FinOp) as the chief operating decision maker, who uses net income for purposes of allocating resources and evaluating financial performance. Based on these factors, the Company has determined that it operates as a single operating and reportable segment. 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 segment revenue and significant expenses for the year ended December 31, 2025 agree to the statement of operations and other comprehensive income. ## **(9) Transactions with Related Parties** The Company and its Parent Company maintain an expense sharing agreement (the Agreement), whereby the Parent Company provided certain services at no cost to the Company. Services under the Agreement include certain compensation and occupancy costs, including lease of office space, the use of furnishings, as well as the information technology infrastructure, with the Parent Company and were approximately \$16,125,807 during 2025. The Company recorded expenses for which it is directly liable, such as business license, employee commission expense, and professional fees, in its statement of operations and other comprehensive income. Expenses are incurred by LIMD but paid by the Parent to the independent third parties. LIMD recognized such expenses across all expense types through the statement of operations and other comprehensive income and recorded a due to Parent liability until payment to the Parent was made. For the year ended December 31, 2025, the Parent Company paid expenses for a total of \$11,968,830. As of December 31, 2025, the Company recorded due to the Parent of \$220,915. JLLIPT has engaged the Company as a dealer manager for the issuance and sale to the public for certain classes of JLLIPT common stock and interests in the DST Program. Pursuant to the arrangement, the Company also managed relationships with participating broker-dealers and provided assistance in connection with compliance matters relating to marketing the JLLIPT offering. {14}------------------------------------------------ The Company earned selling commissions on Class A and S shares of up to 3.0% of the net asset value per Class A and Class S share, respectively, on the date of purchase. The Company received a dealer manager fee that accrued daily in an amount equal to 1/365th of 0.85% of the net asset value per share for Class A shares, Class S shares, and Class S OP Units. The Company received a dealer manager fee that accrued daily in an amount equal to 1/365th of 0.30% of the net asset value for each Class M share and Class Z share. The Company earned selling commissions on Class A-I and D shares of up to 1.5% of the net asset value per Class A-I share and Class D share, respectively, on the date of purchase. In addition, the Company received a dealer manager fee that accrued daily in an amount equal to 1/365th of 0.30% of the net asset value for each Class A-I shares, Class D shares and Class D OP Units. No selling commissions or dealer manager fees are received in connection with the sale of any Class M-I shares, Class I shares, or Class I OP Units. The Company earned selling commissions on Class N shares of up to 1.0% of the net asset value per Class N share on the date of purchase. No dealer manager fees are earned on Class N shares. The Company earned selling commissions of up to 5.0%, dealer manager fees of up to 1.0% and placement fees of 1.0% on the sales of interests in the DST Program on the date of purchase. In addition, the Company received an investor servicing fee of up to 0.25% of the initial equity investment in the DST Program. The Company recorded total revenue of \$12,237,708 from JLLIPT for the year ended December 31, 2025, which is included in commission and dealer manager fees in the statement of operations and other comprehensive income. As of December 31, 2025, the Company recorded due from JLLIPT for \$4,342,777. Pursuant to this participating broker-dealer arrangement, the Company engaged third-party participating broker-dealers to sell JLLIPT common stock. Payments of selling commissions and dealer manager fees are made by the Company to participating broker-dealers after receipt of funds from JLLIPT. The Company recorded total selling expense of \$21,965,390 for the year ended December 31, 2025. As of December 31, 2025, the Company recorded accounts payable, related to these selling expenses, of \$3,551,918. The Company recorded total private placement revenue of \$16,354,966 from JLLIPT for the year ended December 31, 2025. Pursuant to the Company's arrangement with JLLIPT, the Company was reimbursed for expenses incurred related to JLLIPT offerings. LIMD paid for such expenses to independent third parties and recorded reimbursable revenue and a due from related party for the amounts. For the year ended December 31, 2025, the Company recorded reimbursable revenue of \$7,896,891. As of December 31, 2025, the Company recorded due from JLLIPT of \$1,631,810. Additionally, LIMD is reimbursed for expenses paid related to JLLIPT fund costs paid in conjunction with other offering costs to independent third parties. These costs are not recorded on the statement of operations and other comprehensive income as they are not the responsibility of LIMD. As of December 31, 2025, the Company recorded due from JLLIPT of \$96,930. ## **(10) Subsequent Events** Subsequent to December 31, 2025 and through February 26, 2026 the date through which management evaluated subsequent events and on which date the financial statements were available to be issued, the Company did not identify any subsequent events. **\*\*\*\*\*** {15}------------------------------------------------ Computation of Net Capital Under Rule 15c3-1 of the Securities and Exchange Commission | December 31, 2025 | | | |-------------------------------------------------------------------------------------------|----|------------| | Total equity qualified for net capital | \$ | 10,578,495 | | Deductions/charges: | | | | Non-allowable assets: | | | | Due from related party | | 3,100,404 | | Prepaid expenses | | 325,263 | | Total non-allowable assets | | 3,425,667 | | Net capital before haircuts on securities positions | | 7,152,828 | | Haircuts on securities | | 1,792 | | Net capital | | 7,151,036 | | Aggregate indebtedness | | | | Items included in statement of financial condition | | | | Accrued expenses | | 1,478,376 | | Employee commissions payable | | 396,119 | | Accounts payable | | 3,551,918 | | Due to Parent Company | | 220,915 | | Total aggregate indebtedness | | 5,647,328 | | Ratio: Aggregate indebtedness to net capital | | 0.79 to 1 | | Computation of basic net capital requirement | | | | Minimum net capital required (the greater of 6 2/3% aggregate
indebtedness or \$5,000) | | 376,488 | | Net capital in excess of minimum requirement | \$ | 6,774,548 | This schedule does not differ materially from the computation of net capital under Rule 15c3-1 as of December 31, 2025 filed on January 26, 2026 by LaSalle Investment Management Distributors, LLC (the Company) in its Form X-17A-5. See accompanying report of independent registered public accounting firm. {16}------------------------------------------------ Computation for Determination of Customer Reserve Requirements and PAB Reserve Requirements under Rule 15c3-3 December 31, 2025 The Company does not claim an exemption under paragraph (k) of 17 C.F.R § 240.15c3-3. The Company is relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R § 240.17a-5 because the Company limits its business activities exclusively to: (1) acting as a wholesaler and/or placement agent with respect to public non-listed REITs and the private placement of securities, including Delaware Statutory Trusts and other like-kind exchanges pursuant to Section 1031 of the Internal Revenue Code and the Company (1) did not directly or indirectly receive, hold or otherwise owe funds or securities for or to customers; (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. See accompanying report of independent registered public accounting firm. {17}------------------------------------------------ Information Relating to Possession or Control Requirements under Rule 15c3-3 of the Securities and Exchange Commission December 31, 2025 The Company does not claim an exemption under paragraph (k) of 17 C.F.R § 240.15c3-3. The Company is relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R § 240.17a-5 because the Company limits its business activities exclusively to: (1) acting as a wholesaler and/or placement agent with respect to public non-listed REITs and the private placement of securities, including Delaware Statutory Trusts and other like-kind exchanges pursuant to Section 1031 of the Internal Revenue Code and the Company (1) did not directly or indirectly receive, hold or otherwise owe funds or securities for or to customers; (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. See accompanying report of independent registered public accounting firm. {18}------------------------------------------------ ![](_page_18_Picture_0.jpeg) KPMG LLP Suite 3400 312 Walnut Street Cincinnati, OH 45202 #### **Report of Independent Registered Public Accounting Firm** To the Member and Management LaSalle Investment Management Distributors, LLC: We have reviewed management's statements, included in the accompanying LaSalle Investment Management Distributors, LLC Exemption Report (the Exemption Report), in which (1) LaSalle Investment Management Distributors, LLC (the Company) did not claim an exemption under paragraph (k) of 17 C.F.R. § 240.15c3-3 and (2) is filing the Exemption Report pursuant to footnote 74 of SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 because the Company limits its business activities exclusively to: acting as a wholesaler and/or placement agent with respect to public non-listed REITs and the private placement of securities, including Delaware Statutory Trusts and other like-kind exchanges pursuant to Section 1031 of the Internal Revenue Code, and the Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers; (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3) (together, the exemption provisions). We have also reviewed management's statements, included in the Exemption Report, in which the Company stated that it met the identified exemption provisions throughout the year ended December 31, 2025 without exception*.* The Company's management is responsible for compliance with the exemption provisions and its statements. Our review was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included inquiries and other required procedures to obtain evidence about the Company'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, pursuant to footnote 74 of SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5. ![](_page_18_Picture_7.jpeg) Cincinnati, Ohio February 26, 2026 {19}------------------------------------------------ # LaSalle Investment Management Distributors, LLC Exemption Report LaSalle Investment Management Distributors, LLC (the "Company") is a registered brokerdealer 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 does 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: acting as a wholesaler and/or placement agent with respect to public non-listed REITs and the private placement of securities, including Delaware Statutory Trusts and other like-kind exchanges pursuant to Section 1031 of the Internal Revenue Code and the Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers; (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. LaSalle Investment Management Distributors, LLC I, Kristina Meyer, affirm that, to my best knowledge and belief, this Exemption Report is true and correct. my Kristina Meyer Feh. 24. 2026 Date CEO Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.