# LEXINGTON PARK CAPITAL MARKETS, LLC X-17A-5 (2026-03-30) — Broker-dealer annual report

- Company: LEXINGTON PARK CAPITAL MARKETS, LLC
- Form: X-17A-5
- Filed: 2026-03-30
- Period: 2025-12-31
- Accession: 0001527310-26-000002
- CIK: 1527310
- File #: 8-68925
- Type: Broker-dealer
- Material weakness: No
- Auditor: Rubio CPA, PC
- Auditor location: Atlanta, GA
- Contact: Jon Nixon
- Phone: 917-703-1704
- Email: rdas@lexparkgroup.com
- Website: lexparkgroup.com
- Signed by: Rajib Das (CEO)

Original filing: https://www.sec.gov/Archives/edgar/data/1527310/000152731026000002/LexingtonPark868925.pdf

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UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549

| ANNUAL REPORTS |
|----------------|
| FORM X-17A-5   |
| PART III       |

OMB APPROVAL OMB Number: 3235-0123 Expires: Nov. 30, 2026 Estimated average burden hours per response: 12

SEC FILE NUMBER 8-68925

FACING PAGE Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934

FILING FOR THE PERIOD BEGINNING 01/01/25

MM/DD/YY

MM/DD/YY

12/31/25

A. REGISTRANT IDENTIFICATION

NAME OF FIRM: Lexington Park Capital Markets, LLC

TYPE OF REGISTRANT (check allapplicable boxes):

Broker-dealer ☐ Security-based swap dealer Major security-based swap participant Check here if respondent is also an OTC derivatives dealer

AND ENDING

ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use <sup>a</sup> P.O. box no.)

# 390 N Orange Ave, Suite 1875

|                                                                                            |  | (No. and Street)              |                 |                       |  |  |  |  |  |  |
|--------------------------------------------------------------------------------------------|--|-------------------------------|-----------------|-----------------------|--|--|--|--|--|--|
| Orlando                                                                                    |  | FL                            |                 | 32801                 |  |  |  |  |  |  |
| (City)                                                                                     |  | (State)                       |                 | (Zip Code)            |  |  |  |  |  |  |
| PERSON TO CONTACT WITH REGARD TO THIS FILING                                               |  |                               |                 |                       |  |  |  |  |  |  |
| Rajib Das                                                                                  |  | (917) 446-3186                |                 | rdas@lexparkgroup.com |  |  |  |  |  |  |
| (Name)                                                                                     |  | (Area Code -Telephone Number) |                 | (Email Address)       |  |  |  |  |  |  |
| B. ACCOUNTANT IDENTIFICATION                                                               |  |                               |                 |                       |  |  |  |  |  |  |
| INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*<br>RUBIO CPA, PC |  |                               |                 |                       |  |  |  |  |  |  |
| (Name- if individual, state last, first, and middle name)                                  |  |                               |                 |                       |  |  |  |  |  |  |
| 3500 Lenox Road NE, Suite 1500                                                             |  | Atlanta                       | GA              | 30326                 |  |  |  |  |  |  |
| (Address)<br>05/05/09                                                                      |  | (City)                        | (State)<br>3514 | (Zip Code)            |  |  |  |  |  |  |

(Date of Registration with PCAOB)(if applicable) (PCAOB Registration Number, if applicable) FOR OFFICIAL USE ONLY

\*Claims for exemption from the requirement that the annual reports be covered by the reports of an independent public accountant must be supported by <sup>a</sup> statement offacts and circumstances relied on as the basis of the exemption. See 17 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.

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### OATH OR AFFIRMATION

| 1, Rajib Das                                                                   | _ swear (or affirm) that, to the best of my knowledge and belief, the                    |
|--------------------------------------------------------------------------------|------------------------------------------------------------------------------------------|
| financial report pertaining to the firm of Lexington Park Capital Markets, LLC | as of                                                                                    |
| December 31                                                                    | _2.025 is true and correct. I further swear (or affirm) that neither the company nor any |
|                                                                                |                                                                                          |

partner, officer, director, or equivalent person, as the case may be, has any proprietary interest in any account classified solely as that of <sup>a</sup> customer.

Title: CEO

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, <sup>a</sup> 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 <sup>17</sup> CFR 240.15c3-1 or <sup>17</sup> CFR 240.18a-1, as applicable.
- (i) Computation of tangible net worth under <sup>17</sup> CFR 240.18a-2.
- (j) Computation for determination of customer reserve requirements pursuant to Exhibit <sup>A</sup> to <sup>17</sup> CFR 240.15c3-3.
- (k) Computation for determination of security-based swap reserve requirements pursuant to Exhibit <sup>B</sup> to <sup>17</sup> CFR 240.15c3-3 ог Exhibit <sup>A</sup> to <sup>17</sup> CFR 240.18a-4, as applicable.
- (1) Computation for Determination of PAB Requirements under Exhibit <sup>A</sup> to § 240.15c3-3.
- 미 (m) Information relating to possession or control requirements for customers under <sup>17</sup> CFR 240.15c3-3.
- (n) Information relating to possession or control requirements for security-based swap customers under <sup>17</sup> CFR 240.15c3-3(p)(2) or <sup>17</sup> 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 <sup>17</sup> CFR 240.15c3-1, <sup>17</sup> CFR 240.18a-1, or <sup>17</sup> CFR 240.18a-2, as applicable, and the reserve requirements under <sup>17</sup> CFR 240.15c3-3 or <sup>17</sup> CFR 240.18a-4, as applicable, if material differences exist, or <sup>a</sup> statement that no material differences exist.
- (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition.
- (q) Oath or affirmation in accordance with <sup>17</sup> CFR 240.17a-5, <sup>17</sup> CFR 240.17a-12, or <sup>17</sup> CFR 240.18a-7, as applicable.
- (r) Compliance report in accordance with <sup>17</sup> CFR 240.17a-5 or <sup>17</sup> CFR 240.18a-7, as applicable.
- (s) Exemption report in accordance with <sup>17</sup> CFR 240.17a-5 or <sup>17</sup> 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 report or financial statements under 17 CFR 240.17a-5, <sup>17</sup> CFR 240.18a-7, or <sup>17</sup> CFR 240.17a-12, as applicable.
- D (v) Independent public accountant's report based on an examination of certain statements in the compliance report under <sup>17</sup> CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- (w) Independent public accountant's report based on <sup>a</sup> review of the exemption report under <sup>17</sup> CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- (x) Supplemental reports on applying agreed-upon procedures, in accordance with <sup>17</sup> CFR 240.15c3-1e or <sup>17</sup> CFR 240.17a-12, as applicable.
- (y) Report describing any material inadequacies found to exist or found to have existed since the date of the previous audit,or <sup>a</sup> statement that no material inadequacies exist, under <sup>17</sup> CFR 240.17a-12(k). (z) Other:

<sup>\*\*</sup>To request confidential treatment of certain portions of this filing, see <sup>17</sup> CFR 240.17a-5(e)(3) or <sup>17</sup> CFR 240.18a-7(d)(2), as applicable.

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#### LEXINGTON PARK CAPITAL MARKETS, LLC

FINANCIAL STATEMENTS WITH REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

FOR THE YEAR ENDED DECEMBER 31, 2025

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### Lexington Park Capital Markets, LLC Financial Statements For The Year Ended December 31, 2025

#### CONTENTS

Report of Independent Registered Public Accounting Firm

Financial Statements

Statement of Financial Condition

Statement of Operations

Statement of Changes in Member's Equity

Statement of Cash Flows

Notes to Financial Statements

SUPPLEMENTARY INFORMATION TO FINANCIAL STATEMENTS

Schedule I- Computation of Net Capital under Rule 15c3-1

of the Securities and Exchange Commission

Schedule II - Computation for Determination of Reserve Requirements

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

Report of Independent Registered Public Accounting Firm on the Company's Exemption Report

Exemption Report

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3500 Lenox Road NE Suite 1500 Atlanta, GA 30326 770-690-8995

# REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Member of Lexington Park Capital Markets, LLC

# Opinion on the Financial Statements

We have audited the accompanying statement of financial condition of Lexington Park Capital Markets, 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 (collectively referred to as the "financial statements"). In our cissn't the financial statements present fairly, in all material respects, the financial position of the Company as of December 3, 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 the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

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

Our audit included performing procedures to assess the risks of material misstatement to 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 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 Company's management. Our audit procedures included determining whether the information in Schedules I, II, and III 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 accompanying schedules. In forming our opinion on the accompanying schedules, we evaluated whether the supplemental information, including its form and content, is presented

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in conformity with 17 C.F.R. §240.17a-5. In our opinion, the aforementioned supplemental information is fairly stated, in
all material respects, in reletion to the Financial all material respects, in relation to the financial statements as a wholenia.

We have served as the Company's auditor since 2023.

March 30, 2026 Atlanta, Georgia

ubio CP

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## Lexington Park Capital Markets, LLC Statement of Financial Condition As of December 31, 2025

# ASSETS

| Cash<br>Prepaid Expenses and Deposits | સ્ત્ર | 15,391<br>2,521 |
|---------------------------------------|-------|-----------------|
| Total Assets                          |       | 17,912          |
| LIABILITIES AND MEMBER'S EQUITY       |       |                 |
| LIABILITIES                           |       |                 |
| Accounts Payable and Accrued Expenses | ક     | 4,070           |
| Total Liabilities                     |       | 4,070           |
| Member's Equity                       |       | 13,842          |
| TOTAL LIABILITIES AND MEMBER'S EQUITY |       | 17,912          |

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# Lexington Park Capital Markets, LLC Statement of Operations For The Year Ended December 31, 2025

### Revenue

| Total Revenue     |             |
|-------------------|-------------|
| Expenses          |             |
| Professional Fees | 17,300      |
| Other             | 2,247       |
| Total Expenses    | 19,547      |
| Net Loss          | \$ (19,547) |
|                   |             |

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### Lexington Park Capital Markets, LLC Statement of Changes in Member's Equity For The Year Ended December 31, 2025

| Balance - December 31, 2025 | છ | 13,842   |
|-----------------------------|---|----------|
| Net Loss                    |   | (19,547) |
| Contributions               |   | 23,000   |
| Balance - January 1, 2025   | ಳ | 10,389   |

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## Lexington Park Capital Markets, LLC Statement of Cash Flows For The Year Ended December 31, 2025

| Cash Flows From Operating Activities:<br>Net Loss                                                                                                                             | ક | (19,547)         |
|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---|------------------|
| Adjustments to Reconcile Net Loss to Net Cash Used by Operating Activities:<br>Increase in Prepaid Expenses and Deposits<br>Increase in Accounts Payable and Accrued Expenses |   | (1,573)<br>800   |
| Net Cash Used by Operating Activities                                                                                                                                         |   | (20,320)         |
| Cash Flows From Financing Activities:<br>Contributions<br>Net Cash Provided By Financing Activities                                                                           |   | 23,000<br>23,000 |
| Net Increase in Cash                                                                                                                                                          |   | 2,680            |
| Cash - Beginning of Year                                                                                                                                                      |   | 12.711           |
| Cash - End of Year                                                                                                                                                            | S | 15,391           |

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# Lexington Park Capital Markets, LLC Notes to Financial Statements December 31, 2025

### (1) Organization and Description of Business

Lexington Park Capital Markets, LLC, (the "Company"), is a wholly owned subsidiary of Lexington Park Group, LLC (the "Member"). The Company is a securities broker-dealer registered with the Securities and Exchange Commission ("SEC") and is a member of the Financial Industry Regulatory Authority ("FINRA"). The Company is a Delaware limited liability company organized in May 2011 and became a broker-dealer in May 2014. As a limited liability company, the Member's liability is limited to its investment.

The Company provides private placement services to middle market companies and develops structured programs for arranging finance and affecting merger and acquisition transactions.

#### (2) Summary of Significant Accounting Policies

#### (a) Basis of Presentation

The accompanying financial statements have been prepared in accordance with accounting principles generally accepted in the United States of America ("U.S. GAAP") as established by the Financial Accounting Standards Board ("FASB") to ensure consistent reporting of financial condition, results of operations, and cash flows.

#### (b) Estimates

The preparation of the financial statements in conformity with U.S. GAAP requires management to make estimates and assumptions that affect the reported amounts of assets, liabilities, revenues, and expenses. Actual results could differ from the estimates that were assumed in preparing the financial statements.

#### (c) Income Taxes

The Company is a single-member limited liability company and is considered a disregarded entity for federal income tax reporting purposes. Accordingly, the Company does not file a separate income tax return. The income or losses of the Company flow through to and are taxable to the Member. Therefore, no income taxes are reflected in the accompanying financial statements.

The Company follows the provisions of FASB Accounting Standards Codification 740-10 ("ASC 740-10"), Accounting for Uncertainty in Income Taxes. Under FASB ASC 740-10, the Company is required to evaluate each of its tax positions to determine if they are more likely than not to be sustained if the taxing authority examines the respective position. A tax position includes an entity's status, including its status as a pass-through entity, and the decision not to file a return.

The Company has evaluated each of its tax positions and has determined that it has no uncertain tax positions for which a provision or liability for income taxes is necessary.

#### (d) Cash

The Company maintains its cash in a bank account at a high credit quality financial institution. The balance at times may exceed federally insured limits.

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# Lexington Park Capital Markets, LLC Notes to Financial Statements December 31, 2025

### (2) Summary of Significant Accounting Policies (continued)

### (e) Revenue Recognition

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

The Company provides placement and advisory services related to capital raising activities and mergers and acquisitions transactions. Revenue for advisory agreements is generally recognized at the point in time that performance under the agreement is completed (the closing date of transaction) or the contract is terminated. However, for certain contracts, revenue is recognized over time for advisory agreements in which the performance obligations are simultaneously provided by the Company and consumed by the customer. In some circumstances, significant judgment is needed to determine the timing and measure of progress appropriate for revenue recognition under a specific contract. Retainers and other fees received from customers prior to recognizing the revenue would be reflected as deferred revenues.

The Company recognizes success fee revenue upon completion of a success fee-based transaction as this satisfies the only performance obligation identified by the Company.

#### (3) Related Party Transaction

The Company operates from office space provided by its Member at no cost to the Company.

Financial condition and results of operations would differ from the amounts in the accompanying financial statements if this related party transaction did not exist.

#### (4) Contingencies

The Company is subject to litigation in the ordinary course of business as a registered broker-dealer. The Company has no litigation in progress at December 31, 2025.

#### (5) Net Capital Requirements

The Company is subject to the SEC's Uniform Net Capital Rule 15c3-1, 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 15 to 1. At December 31, 2025, the Company had net capital of \$11,321 which was \$6,321 in excess of its required minimum net capital of \$5,000. The Company's ratio of aggregate indebtedness to net capital was 0.36 to 1.00.

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# Lexington Park Capital Markets, LLC Notes to Financial Statements December 31, 2025

### (6) Subsequent Events

Subsequent events were evaluated through the date the financial statements were issued.

### (7) Segment Reporting

The Company is engaged in a single line of business as a securities broker-dealer, which is comprised of several classes of services, including pivate placements of securities and merger and acquisition advisory services. The Company has identified its Chief Executive Officer as the chief operating decision maker (COMM'), who uses met income or loss to evaluate the results of the business, predominantly in the forecasting process, to manage the Company. Additionally, the CODM uses excess net capital (see Note 5), which is not a measure of profit and loss, to make operational decisions while maintaining capital adequacy, such as whether to reinvest profits or pay distributions. The Company's operations constitutes 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 same as those described in the summary of significant accounting policies.

### (8) Net Loss

The Company incurred a loss for 2025 and was dependent upon capital contributions from its Member for working capital and net capital. The Company's Member has represented that it has the means and intention to provide capital contributions as needed to ensure the Company's survival through at least one year subsequent to the date of the report of the independent registered public accounting firm.

Management expects the Company to continue as a going concern and the accompanying financial statements have been prepared on a going-concern basis without adjustments for realization in the event that the Company ceases to continue as a going concern.

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# Lexington Park Capital Markets, LLC Schedule I Computation Of Net Capital Under Rule 15c3-1 Of The Securities And Exchange Commission

### December 31, 2025

| Member's Equity                                                                          | સ્ત્ર | 13,842       |
|------------------------------------------------------------------------------------------|-------|--------------|
| Non-allowable Assets<br>Prepaid Expenses and Deposits                                    |       | 2,521        |
| Total Non-Allowable Assets                                                               |       | 2,521        |
| Net Capital                                                                              |       | 11,321       |
| Minimum Net Capital Required (greater of \$5,000<br>or 6-2/3% of aggregate indebtedness) |       | 5,000        |
| Excess Net Capital                                                                       | સ્ત્ર | 6,321        |
| Total Aggregate Indebtedness                                                             |       | 4,070        |
| Ratio of Aggregate Indebtedness to Net Capital                                           |       | 0.36 to 1.00 |

 Reconciliation with the Company's Computation of Net Capital in Part IIA of Form X-17A-5 as of December 31,2025: There is no material difference between the above computation of net capital and the corresponding computation reported in Part IIA of Form X-17A-5 as of December 31, 2025

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### LEXINGTON PARK CAPITAL MARKETS, LLC SCHEDULE II COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION

### AS OF DECEMBER 31, 2025

 The Company does not claim exemption from Rule 15c3-3 in reliance upon Footnote 74 of the 2013 Release. The Company does not hold customer funds or securities.

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### LEXINGTON PARK CAPITAL MARKETS, LLC SCHEDULE III INFORMATION RELATING TO THE POSSESSION OR CONTROL REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION

# AS OF DECEMBER 31, 2025

The Company does not claim exemption from Rule 15c3-3 in reliance upon Footnote 74 of 2013 Release. The Company does not hold customer funds or securities.

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RUBIO CPA. PC

CERTIFIED PUBLIC ACCOUNTANTS

3500 Lenox Road NE Suite 1500 Atlanta, GA 30326 770-690-8995

# REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Member of Lexington Park Capital Markets, LLC

We have reviewed management's statements included in the accompanying Broker Dealers Annual Exemption Report in which (1) Lexington Park Capital Markets, LLC did not claim an exemption from Rule 1503-3 in reliance upon Footote 14 of the 2013 Release, (2) Lexington Park Capital Markets, LLC stated that it conducted business activities upvolving private placement of securities and mergers and acquisition advisory services throughout the year ended December 31. 2025. without exception, and (3) Lexington Park Capital Markets, LLC stated that Lexington Park Capital Markets, LLC met the identified conditions for such reliance throughout the most recent fiscal year without exception. Lexington Park C anital Markets, LLC'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 Lexington Park Capital Markets, LLC's compliance with the exemption provisions. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, we do not express such an opinion.

Based on our review, we are not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based on the provisions set forth in Footnote 74 of the 2013 Release.

March 30, 2026 Atlanta. GA

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# LEXINGTON PARK CAPITAL MARKETS, LLC 390 N Orange Ave, 23rd Floor Orlando, FL 32801

### EXEMPTION REPORT

We, as members of management of Lexington Park Capital Markets, LLC (the "Company"), are responsible for complying with Rule 17a-5, "Reports to be made by certain brokers and dealers". We have performed an evaluation of the Company's compliance with the requirements of Rule 17a-5 and the exemption in Rule 15c3-3(k) (the "exemption provisions") and of the 2013 Release adopting amendments to Rule 17a-5, including Footnote 74 of the 2013 Release.

We have determined that the Company does not meet any of the exemption conditions of paragraph (k) of Rule 15c3-3 (i.e., paragraph (k)(1), (k)(2)(i) or (k)(2)(ii)) but also (1) does not directly 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 Exchange Act Rule 15c2-4"); (2) does not carry accounts of or for customers; and (3) does not carry PAB accounts (as defined in Rule 15c3-3) and therefore is covered by Footnote 74 of the 2013 Release.

Accordingly, based on our evaluation we make the following statements to the best knowledge and belief of the Company:

- 1. We reviewed the provisions of Rule §15c3-3 and related guidance stated in the SEC Staff's FAQ and confirmed that the Company relied on Footnote 74 of the 2013 Release.
- 2. The Company conducted business activities involving private placement of securities and mergers and acquisition advisory services throughout the year ended December 31, 2025, without exception.
- 3. The Company met the identified conditions for such reliance throughout the period January 1, 2025, to December 31, 2025, without exception.

Rajib Das, CEO March 15, 2026


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