# APPLIED CAPITAL, LLC X-17A-5 (2026-03-31) — Broker-dealer annual report

- Company: APPLIED CAPITAL, LLC
- Form: X-17A-5
- Filed: 2026-03-31
- Period: 2025-12-31
- Accession: 0001563236-26-000002
- CIK: 1563236
- File #: 8-69199
- Type: Broker-dealer
- Material weakness: No
- Auditor: Crowe
- Auditor location: Chicago, IL
- Contact: Loren Heger
- Phone: 888.580.2588
- Email: lheger@fnex.com
- Website: fnex.com
- Signed by: Loren Heger (CCO)

Original filing: https://www.sec.gov/Archives/edgar/data/1563236/000156323626000002/2.pdf

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# **Applied Capital, LLC (d/b/a FNEX Capital, LLC)**

&ŝŶĂŶĐŝĂů^ƚĂƚĞŵĞŶƚƐĂŶĚ^ƵƉƉůĞŵĞŶƚĂů/ŶĨŽƌŵĂƟŽŶ For the Year End December 31, 2025 With

Report of Independent ZĞŐŝƐƚĞƌĞĚWƵďůŝĐĐĐŽƵŶƟŶŐ&ŝƌŵ

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

0 M B APPROVAL 0 MB Number: 3235--0123 Expires: Nov. 30, 2026 Estimated average burden hours per response: 12

## **ANNUAL REPORTS FORM X-17A-5 PART Ill**

SEC FILE NUMBER

| Information Required Pursuant to Rules 17a-5, 17a-12, and lSa-7 under the Securities Exchange Act of 1934                                | FACING PAGE                                                |            |                                          |
|------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------|------------|------------------------------------------|
|                                                                                                                                          | ----------<br>1/1/25                                       |            | -----------<br>12/31/25                  |
| FILING FOR THE PERIOD BEGINNING                                                                                                          | MM/DD/YY                                                   | AND ENDING | MM/DD/YY                                 |
|                                                                                                                                          | A. REGISTRANT IDENTIFICATION                               |            |                                          |
| NAME OF FIRM:                                                                                                                            | Applied Capital, LLC<br>____________________________       |            | _                                        |
| TYPE OF REGISTRANT (check all applicable boxes):<br>□ Broker-dealer<br>■<br>□ Check here if respondent is also an OTC derivatives dealer | □ Security-based swap dealer                               |            | □ Major security-based sw ap participant |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.)                                                                      |                                                            |            |                                          |
| One Indiana Square, Suite 2252                                                                                                           |                                                            |            |                                          |
|                                                                                                                                          | (No. and Street)                                           |            |                                          |
| Indianapolis                                                                                                                             | IN                                                         |            | 46204                                    |
| (City)                                                                                                                                   | (State)                                                    |            | {Zip Code)                               |
| PERSON TO CONTACT WITH REGARD TO THIS FILING                                                                                             |                                                            |            |                                          |
| Loren Heger                                                                                                                              | 888-580-2588                                               |            | lheger@fnex.com                          |
| {Name)                                                                                                                                   | (Area Code - Telephone Number)                             |            | (Email Address)                          |
|                                                                                                                                          | B. ACCOUNTANT IDENTIFICATION                               |            |                                          |
| INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*                                                                |                                                            |            |                                          |
| Crowe                                                                                                                                    |                                                            |            |                                          |
|                                                                                                                                          | (Name - if individual, state last, first, and middle name) |            |                                          |
| 225 West Wacker Drive                                                                                                                    | Chicago                                                    |            | IL<br>60606                              |
| {Address)                                                                                                                                | (City)                                                     |            | (State)<br>{Zip Code)                    |
| 09/24/2003                                                                                                                               |                                                            | 173        |                                          |
|                                                                                                                                          |                                                            |            |                                          |
|                                                                                                                                          | 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 a statement of facts and circumstances relied on as the basis of the exemption. See 17 CFR 240.17a-S(e)(l)(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 0MB control number.** 

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| Loren Heger |                      |  |
|-------------|----------------------|--|
|             | Applied Capital, LLC |  |

December 31 025

Loren Heger

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![](_page_3_Picture_0.jpeg)

#### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

The Member and Management Applied Capital, LLC (d/b/a FNEX Capital, LLC) Indianapolis, Indiana

#### **Opinion on the Financial Statements**

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

#### **Basis for Opinion**

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

We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion.

#### **Supplemental Information**

Schedule IDQGSchedule II ("Supplemental Information") have been subjected to audit procedures performed in conjunction with the audit of Applied Capital, LLC'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 is fairly stated, in all material respects, in relation to the financial statements as a whole.

Crowe LLP

We have served as Applied Capital, LLC's auditor since 2025.

New York, New York March 30, 2026

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## FNEX Capital, LLC ^ƚĂƚĞŵĞŶƚŽĨ&ŝŶĂŶĐŝĂůŽŶĚŝƟŽŶ December 31, 2025

#### Assets

| Cash and cash equivalents     | \$ 1,690,806 |
|-------------------------------|--------------|
| Investments                   | 23,305       |
| Accounts receivable, net      | 487,584      |
| Prepaid expenses and deposits | 154,459      |
| Total assets                  | \$ 2,356,154 |

## >ŝĂďŝůŝƟĞƐĂŶĚDĞŵďĞƌ's Equity

| >ŝĂďŝůŝƟĞƐ                       |                 |
|----------------------------------|-----------------|
| Accounts payable                 | \$<br>338,472   |
| Commissions payable              | 1,227,421       |
| Deferred revenues                | 15,000          |
| Accrued expenses                 | 41,988          |
| dŽƚĂůůŝĂďŝůŝƟĞƐ                  | 1,622,881       |
| DĞŵďĞƌ's equity                  | 733,273         |
| dŽƚĂůůŝĂďŝůŝƟĞƐĂŶĚŵĞŵďĞƌƐĞƋƵŝƚLJ | \$<br>2,356,154 |

^ĞĞĂĐĐŽŵƉĂŶLJŝŶŐŶŽƚĞƐƚŽƚŚĞĮŶancial statements

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## FNEX Capital, LLC Statement of KƉĞƌĂƟŽŶƐ For the year Ended December 31, 2025

| Revenues                                   |                  |
|--------------------------------------------|------------------|
| Investment banking fees                    | \$<br>36,662,159 |
| DƵƚƵĂůĨƵŶĚƌĞĨĞƌƌĂůĨĞĞƐ                     | 1,883,274        |
| Referral fees                              | 3,024,106        |
| ŽŶƐƵůƟŶŐĨĞĞƐ                               | 922,510          |
| Interest income                            | 7,719            |
| Other income                               | 4,643            |
| Other fees & reimbursed expenses           | 180,145          |
| Total revenues                             | \$<br>42,684,556 |
| Expenses                                   |                  |
| Commission expense                         | \$<br>38,531,473 |
| Referral fees paid to other broker-dealers | 990,890          |
| ŽŵƉĞŶƐĂƟŽŶĂŶĚďĞŶĞĮƚƐ                       | 655,088          |
| >ŝĐĞŶƐĞƐĂŶĚƌĞŐŝƐƚƌĂƟŽŶ                     | 410,195          |
| Professional services                      | 165,336          |
| Occupancy                                  | 41,836           |
| /d͕ĚĂƚĂĂŶĚĐŽŵŵƵŶŝĐĂƟŽŶƐ                    | 51,346           |
| KƚŚĞƌŽƉĞƌĂƟŶŐĞdžƉĞŶƐĞƐ                     | 32,023           |
| Total expenses                             | \$<br>40,878,187 |
| Net Income                                 | \$<br>1,806,369  |

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## FNEX Capital, LLC ^ƚĂƚĞŵĞŶƚŽĨŚĂŶŐĞƐŝŶDĞŵďĞƌ͛ƐƋƵŝƚLJ For the year Ended December 31, 2025

| Balance at January 1, 2025   | \$<br>676,904 |
|------------------------------|---------------|
| Net Income                   | 1,806,369     |
| DĞŵďĞƌ͛ƐĚŝƐƚƌŝďƵƟŽŶ          | (1,750,000)   |
| Balance at December 31, 2025 | \$<br>733,273 |

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## FNEX Capital, LLC Statement of Cash Flows For the year Ended December 31, 2025

| ĂƐŚ&ůŽǁƐĨƌŽŵKƉĞƌĂƟŶŐĐƟǀŝƟĞƐ͗                                |                 |
|-------------------------------------------------------------|-----------------|
| Net Income                                                  | \$<br>1,806,369 |
|                                                             |                 |
| Adjustments to reconcile net income to net cash provided by |                 |
| ŽƉĞƌĂƟŶŐĂĐƟǀŝƟĞƐ͗                                           |                 |
| ŚĂŶŐĞŝŶŽƉĞƌĂƟŶŐĂƐƐĞƚƐĂŶĚůŝĂďŝůŝƟĞƐ͗                         |                 |
| Accounts receivable, net                                    | 112,111         |
| Investments                                                 | (23,305)        |
| Prepaid expenses and deposits                               | (48,779)        |
| Accounts payable                                            | 274,369         |
| Commissions payable                                         | 109,773         |
| ƵĞƚŽĂĸůŝĂƚĞ                                                 | 15,496          |
| Net Cash PƌŽǀŝĚĞĚďLJKƉĞƌĂƟŶŐĐƟǀŝƟĞƐ                         | 2,246,036       |
| ĂƐŚhƐĞĚŝŶ&ŝŶĂŶĐŝŶŐĐƟǀŝƟĞƐ͗                                  |                 |
| DĞŵďĞƌƐĚŝƐƚƌŝďƵƟŽŶƐ                                         | ( 1,750,000)    |
|                                                             |                 |
| Net Increase in Cash and Cash Equivalents                   | 496,034         |
| Cash and Cash Equivalents, Beginning of Year                | 1,194,772       |
| Cash and Cash Equivalents, End of Year                      | \$<br>1,690,806 |

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# **NOTE 1- NATURE OF BUSINESS AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES**

Nature of Business: Applied Capital, LLC (the "Company"), which conducts business under the name FNEX Capital, LLC, is an Indiana Limited Liability Company which organized in June of 2012 and was approved to begin operations as a broker-dealer in January of 2014. The Company is an independent registered broker-dealer and subject to regulation by the U.S. Securities and Exchange Commission (SEC), the Financial Industry Regulatory Authority (FINRA), Securities Investor Protection Corporation (SIPC) and various states. The Company engages in the business of private placements, investment banking, and mutual funds referrals.

The Company is a wholly-owned subsidiary of FNEX, LLC ("Parent" or "Member").

Basis of Presentation: The accompanying financial statements have been prepared on the accrual basis of accounting in accordance with accounting principles generally accepted in the United States of America ("GAAP"). The Company complies with the accounting and reporting requirements under the FASB ASC Topic 940, Financial Services-Broker and Dealers.

Income Taxes: The Company has elected to be a Limited Liability Company taxed as a partnership under Internal Revenue Code (the "Code") regulations and is treated as a disregarded entity. Therefore, the income or losses of the Company flow through to and are taxable to its Parent, and no liability for income taxes is reflected in the accompanying financial statements.

The Company complies with the provisions of ASC Topic 740 Income Taxes. Under this provision, 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 no provision or liability for income taxes is necessary.

The Company's Member filed federal and various state income tax returns. The Company's Member is no longer subject to US Federal and State income tax examinations by tax authorities for years before 2022.

Use of Estimates: The preparation of financial statements in accordance with GAAP requires the use of estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities, if any, 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.

Cash and Cash Equivalents: For the purpose of the statement of cash flows, the Company considers deposits with maturities of ninety days or less to be cash and cash equivalents.

Concentration of Credit Risk: The Company maintains its cash and cash equivalents in a high credit quality bank. Balances at times may exceed Federal Deposit Insurance Corporation (FDIC) insured limits of \$250,000 per depositor. No losses have been incurred to date.

#### Financial Instruments:

The Company's financial instruments include cash, accounts receivable, and accounts payable, the carrying amounts of which approximate fair value due to their short-term nature.

The Company also holds equity securities, which are recorded at fair value in accordance with ASC 820, *Fair Value Measurement*. Changes in fair value are recognized in earnings as unrealized gains and losses. Realized gains and losses are recognized upon disposition of the securities.

The Company may receive non-cash consideration, including equity securities, in exchange for services. Such consideration is recorded as revenue at fair value on the trade date, with a corresponding financial instrument recorded at fair value.

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## **NOTE 1- NATURE OF BUSINESS AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)**

Accounts Receivables and Allowance for Credit Losses: Accounts Receivable are uncollateralized customer obligations generally requiring payment within 30 days from the invoice date and which do not bear interest. Accounts receivable are recorded at invoiced amounts. The Company has historically experienced minimal credit losses, and management determined there were no expected credit losses at December 31, 2025. Management monitors the Company's accounts receivable for any changes in credit risk and would record an allowance against accounts receivable if credit losses were expected.

Revenue Recognition: ASC Topic 606, "Revenue from Contracts with Customers", core principle is that an entity, should recognize revenue when it transfers promised goods or services performed to customers in an amount that reflects the consideration to which the entity expects to be entitled in exchange for those goods or services. ASC Topic 606 prescribes a five-step process to accomplish this core principle, including:

- · Identification of the contract with the customer;
- · Identification of the performance obligation(s) under the contract;
- · Determination of transaction price;
- · Allocation of the transaction price to the identified performance obligation(s); and
- · Recognition of revenue as (or when) an entity satisfies the identified performance obligation(s).

Private Placements of Debt and Equity: The Company as an agent of the issuer presents to prospective investors a private placement memorandum ("PPM") from the issuer and subscription agreement. The Company or other brokerdealers collects consideration from the issuer when 1) an investor executes a subscription agreement, 2) the investor then delivers funds to the issuer, and 3) the issuer accepts the investor. Revenue is based on a percentage of the transaction amount. Revenue is recognized when the capital commitment by the investor has been accepted by the issuer. The performance obligation has been fulfilled at this point in time and is when the risk and rewards has been transferred.

Mutual Fund Commissions and Fees: The Company contracts with various mutual fund advisers to provide marketing services for funds. For compensation specified in the agreements, the Company presents to interested investors a prospectus from funds and subscription agreement. Asset-based fees earned by the Company are variable because amounts are dependent on the terms and conditions accepted and reported by the fund. Commissions and fees reported relate to specific investors shares purchased, market values at points in time, trailing commissions, fee reversals based on investor withdrawals, and other fees. Generally, agreements require reporting and payment of Company commissions and fees by fund advisors within thirty days after the previous month's end. Contractually, commissions and fees are considered uncertain and unearned until reported.

Cost to Obtaining or Fulfilling a Contract: The Company pays sales commission to its registered representatives for all the services provided above. Management does not believe that there are costs related directly to the contract with the issuer or that the costs are expected to be recovered. Therefore, sales commission are expensed as incurred.

Securities transactions are recorded on the trade date as transactions occur. Investment banking revenue includes fees earned from providing merger and acquisition, private placement, and other advisory services to clients. Securities transactions from mutual funds are recorded in the period the sales occur on a trade date basis and the mutual fund trail fees are recorded in the period the fee is calculated. Referral fees include referring buyers to sellers or vice versa for introduction in private securities transactions. Revenue is recognized when earned, which generally occurs as services are performed or upon consummation of a transaction. Related commissions expense to registered representatives is recognized in the same period in which revenue is recognized.

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## **NOTE 1- NATURE OF BUSINESS AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)**

Deferred Revenue: Deferred revenue arising from non-refundable retainers and mutual fund contracts are recognized as revenues when considered earned, which generally occurs upon consummation of a transaction.

Recently adopted accounting standards: The FASB issued new guidance in FASB ASC Topic 280, Segment Reporting, as amended by the FASB Accounting Standards Update (ASU) No. 2023-07, *Segment Reporting: Improvements to Reportable Segment Disclosures* (ASU-2023-07), which requires all public entities, including those with a single reportable segment, to disclose additional information about a reportable segment's expenses in interim and annual periods, among other requirements. The new guidance does not change how a public entity identifies its operating segments, aggregates those operating segments or applies the quantitative thresholds to determine its reportable segments. The guidance in FASB ASU-2023-07 is effective for all public entities for fiscal years beginning after December 15, 2023, and interim periods within fiscal years beginning after December 15, 2024, and should be applied retrospectively to all periods presented in the financial statements. ASU 2023-07 was adopted by the Company in the current year.

Subsequent Events: Subsequent events were evaluated by management through March 12, 2026, the date the financial statements were available to be issued.

## **NOTE 2- NET CAPITAL REQUIREMENTS**

The Company is an introducing broker-dealer subject to the Securities and Exchange Commission Uniform Net Capital Rule (SEC Rule 15c3 1), which requires the Company to maintain "net capital" of 6 2/3 percent of "aggregate indebtedness" or \$5,000, whichever is greater, as these terms are defined. In addition, the ratio of aggregate indebtedness to net capital shall not exceed 15 to 1.

Net capital and aggregate indebtedness change daily. As of December 31, 2025, the Company had net capital and net capital requirements of \$543,782 and \$107,192 respectively and excess net capital of \$436,590. The net capital rule may effectively restrict the withdrawal of member's equity.

## **NOTE 3- RELATED PARTY TRANSACTIONS**

The Company entered into an expense sharing agreement with the Parent to whom it pays certain general and administrative expenses. The Company's share of expenses is calculated based on estimated usage.

For the year ended December 31, 2025, allocated expenses under the agreement amounted to \$796,001 and can be found on the accompanying statement of operations under compensation and benefits, IT, data, and communication, occupancy, professional services, and operating expenses. \$117,004 of the Accounts Payable balance on the accompanying statement of financial condition arose from this services agreement.

## **NOTE 4-CONTINGENCIES**

The Company is subject to litigation in the normal course of business. The Company has no litigation that the Company believes to be material at December 31, 2025.

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## **NOTE 5- INDEMNIFICATIONS**

The Company's broker-dealer agreements may include indemnification provisions that could limit our potential litigation liability. These provisions generally require counterparties to indemnify us for certain losses, damages, or expenses arising from specific claims or legal proceedings, subject to applicable legal and regulatory limitations. While such provisions are designed to mitigate financial exposure, they do not eliminate all potential liabilities, and there can be no assurance that indemnification will be available in all circumstances.

## **NOTE 6- 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 referral fees, investment banking, investment advisory, and mutual fund fees. The Company has identified its managing principal as the chief operating decision maker ("CODM"), who uses net income 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 2), which is not a measure of profit and loss, to make operational decisions while maintaining capital adequacy, such as whether to reinvest profits or pay distributions. The Company's operations constitute a single operating segment and therefore, 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.

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## FNEX Capital, LLC Schedule I Computation of Net Capital Pursuant to Rule 15c3-1 of the Securities and Exchange Commission Act of 1934 as of December 31, 2025

Net Capital:

| Total members equity qualified for net capital                                        | \$<br>733,273   |
|---------------------------------------------------------------------------------------|-----------------|
| Deduction for non-allowable assets:                                                   |                 |
| Accounts receivable, net                                                              | 34,563          |
| Prepaid expenses and deposits                                                         | 154,459         |
| Net Capital before haircuts                                                           | \$<br>544,251   |
| Less haircuts                                                                         | 469             |
| Net capital                                                                           | 543,782         |
| Minimum net capital required (greater of \$5,000 or 6 2/3% of aggregate indebtedness) | 107,192         |
| Excess net capital                                                                    | \$<br>436,590   |
| Aggregate indebtedness (ai), net of non-ai liabilities of \$15,000                    | \$<br>1,607,881 |
| Percentage of aggregate indebtedness to net capital                                   | 295%            |

Reconciliation with the Company's computation of Net Capital included in Part IIA of Form X-17A-5 as of December 31, 2025

There is no significant difference between net capital reported in Part IIA of Form X-17A-5 as of December 31, 2025 and net capital as of reported above.

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## FNEX Capital, LLC

#### Schedule II

The Company operates as a broker-dealer engaged solely in ƉƌŝǀĂƚĞƉůĂĐĞŵĞŶƚŽĨƐĞĐƵƌŝƟĞƐ͕ďƌŽŬĞƌŽƌĚĞĂůĞƌƐĞůůŝŶŐƚĂdž ƐŚĞůƚĞƌƐŽƌůŝŵŝƚĞĚƉĂƌƚŶĞƌƐŚŝƉƐŝŶƉƌŝŵĂƌLJĚŝƐƚƌŝďƵƟŽŶƐ͕ĂŶĚƚŚĞŽŵƉĂŶLJŵĂLJƌĞĨĞƌŝŶǀĞƐƚŽƌƐƚŽƵŶĂĸůŝĂƚĞĚƚŚŝƌĚƉĂƌƚLJ broker-deals ĨŽƌŐĞŶĞƌĂůƐĞĐƵƌŝƟĞƐĂŶĚŝŶǀĞƐƚŵĞŶƚďĂŶŬŝŶŐďƵƐŝŶĞƐƐĨŽƌǁŚŝĐŚŝƚŵĂLJƌĞĐĞŝǀĞƌĞĨĞƌƌĂůĨĞĞ͖ƚŚĞ Company ĚŽĞƐŶŽƚĐĂƌƌLJĐƵƐƚŽŵĞƌĂĐĐŽƵŶƚƐŽƌŚŽůĚĐƵƐƚŽŵĞƌĨƵŶĚƐŽƌƐĞĐƵƌŝƟĞƐ͘ĐĐŽƌĚŝŶŐůLJ͕ƚŚĞŽŵƉĂŶLJĚŽĞƐŶŽƚ ĐůĂŝŵĞdžĞŵƉƟŽŶƵŶĚĞƌZƵůĞϭϱĐϯ-3 of the SecuƌŝƟĞƐdžĐŚĂŶŐĞĐƚŽĨϭϵϯϰ͕ĂƐĂŵĞŶĚĞĚ͘

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#### **EXEMPTION REPORT**

#### **SEA RULE 17a-5(d)(4)**

March 26, 2026

Crowe LLP 225 West Wacker Drive, Suite 2600 Chicago, IL 60606-1224

#### To Whom it May Concern:

We, as members of management of FNEX, 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 provisions 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 l 5c3-3 (i.e., paragraph (k)(l), (k)(2)(i) or (k)(2)(ii) but also (1) does not directly or indirectly receive, hold or otherwise owe funds or securities for or to customers , other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of Exchange Act Rule 15c2-4 ("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:

- We reviewed the provi sions 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.
- The Company conducted business activities involving private placement of securities, broker or dealer selling tax shelters or limited partnerships in primary distributions and the Company may refer investors to unaffiliated third party broker-deals for general securities and investment banking business for which it may receive referral fee activity throughout the year ended December 31, 2025 without exception.
- The Company met the identified conditions for such reliance throughout the period January 1, 2025 to December 31, 2025 without exception.

Signed: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Name: Loren Heger

Title: Managing Principal

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#### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

We have reviewed management's statements, included in the accompanying Exemption Report, in which (1) Applied Capital, LLC (the "Company") stated that it does not claim an exemption under paragraph (k) of 17 C.F.R § 15c3-3 and (2) the Company is filing the 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 private placement of securities, broker or dealer selling tax shelters or limited partnerships in primary distributions and the Company may refer investors to unaffiliated third party broker-deals for general securities and investment banking business for which it may receive referral fee; 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) during 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, based on the conditions set forth in of Rule 15c3-3 under the Securities Exchange Act of 1934 and in reliance on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R § 240.17a-5.

Crowe LLP

New York, New York March 30, 2026


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