# ACORNS SECURITIES, LLC X-17A-5 (2026-02-26) — Broker-dealer annual report - Company: ACORNS SECURITIES, LLC - Form: X-17A-5 - Filed: 2026-02-26 - Period: 2025-12-31 - Accession: 0001578860-26-000001 - CIK: 1578860 - File #: 8-69294 - Type: Broker-dealer - Material weakness: No - Auditor: PricewaterhouseCoopers LLP - Auditor location: Los Angeles, CA - Contact: Derek Harper - Phone: (949) 438-2978 - Email: dharper@acorns.com - Website: acorns.com - Signed by: Derek Harper (Director of Financial Operations) Original filing: https://www.sec.gov/Archives/edgar/data/1578860/000157886026000001/public.pdf --- {0}------------------------------------------------ **Acorns Securities, LLC {SEC ID 008-69294) Statement of Financial Condition and Report of Independent Registered Public Accounting Firm December 31, 2025** Filed pursuant to Rule 17a-5(e)(3) under the Securities Exchange Act of 1934 as a PUBLIC DOCUMENT. {1}------------------------------------------------ #### **UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549** 0MB APPROVAL 0MB Number: 3235-0123 Expires: Nov. 30, 2026 Estimated average burden hours per response: 12 > SEC FILE NUMBER 088-69294 # **ANNUAL REPORTS FORM X-17A-5 PART** Ill **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 | | | AND ENDING 12/31 /25 | | | MM/DD/YY | | MM/DD/YY | | | A. REGISTRANT IDENTIFICATION | | | | NAME oF FIRM: Acorns Securities, LLC | | | | | TYPE OF REGISTRANT (check all applicable boxes):
~ Broker-dealer
□ Check here if respondent is also an OTC derivatives dealer | D Security-based swap dealer | D Major security-based | swap participant | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) | | | | | 5300 California Avenue | | | | | | (No. and Street) | | | | Irvine | CA | | 92617 | | (City) | (State) | | (Zip Code) | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | | Derek Harper | 949-438-2978 | | dharper@acorns.com | | (Name) | (Area Code -Telephone | Number) | (Email Address) | | | B. ACCOUNTANT IDENTIFICATION | | | | INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing* | | | | | PricewaterhouseCoopers | LLP | | | | | (Name - if individual, state last, first, and middle name) | | | | 601 S Figueroa St | Los Angeles | | CA
90017 | | (Address) | (City) | (State) | (Zip Code) | |------------------------------------------|-----------------------|---------|---------------------------------------------| | T''
10/20/2003 | | 238 | | | of Reg;st,aHoo w;th PCAOBJ(ff appHcableJ | | | {PCAOB Reg;st,afoo N"mbec, ;fa ppHcable I I | | | 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)(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 0MB control number.** {2}------------------------------------------------ #### **OATH OR AFFIRMATION** I, Derek Harper swear (or affirm) that, to the best of my knowledge and belief, the financial report pertaining to the firm of Acorns Securities, LLC as of **12/31** 2~ 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 a customer. ,,,,.,,,, \ \ I I ![](_page_2_Picture_3.jpeg) | s;gn~4--- | | | |-----------|----------------------------------|--| | Title: | | | | | Director of Financial Operations | | #### **This filing\*\* contains (check all applicable boxes):** - **!!!!I** (a) Statement of financial condition. - **!!!!I** (b) Notes to consolidated statement of financial condition. - □ (c) Statement of income (loss) or, if there is other comprehensive income in the period(s) presented, a statement of comprehensive income (as defined in § 210.1-02 of Regulation S-X). - □ (d) Statement of cash flows. - □ (e) Statement of changes in stockholders' or partners' or sole proprietor's equity. - D (f) Statement of changes in liabilities subordinated to claims of creditors. - □ (g) Notes to consolidated financial statements. - □ (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-1, as applicable. - D (i) Computation of tangible net worth under 17 CFR 240.18a-2. - □ (j) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3. - D (k) Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.15c3-3 or Exhibit A to 17 CFR 240.18a-4, as applicable. - D (I) Computation for Determination of PAB Requirements under Exhibit A to§ 240.15c3-3. - D (m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3. - D (n) Information relating to possession or control requirements for security-based swap customers under 17 CFR 240.15c3-3{p)(2) or 17 CFR 240.18a-4, as applicable. - D (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capital or tangible net worth under 17 CFR 240.15c3-1, 17 CFR 240.18a-1, or 17 CFR 240.18a-2, as applicable, and the reserve requirements under 17 CFR 240.15c3-3 or 17 CFR 240.18a-4, as applicable, if material differences exist, or a statement that no material differences exist. - D (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition. - D (q) Oath or affirmation in accordance with 17 CFR 240.17a-5, 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable. - □ (r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - □ (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - ~ (t) Independent public accountant's report based on an examination of the statement of financial condition. - D (u) Independent public accountant's report based on an examination of the financial report or financial statements under 17 CFR 240.17a-5, 17 CFR 240.18a-7, or 17 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 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - D (w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - D (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-1e or 17 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 a statement that no material inadequacies exist, under 17 CFR 240.17a-12(k). - □ (z) Other: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ \_ - \*\*To request confidential treatment of certain portions of this filing, see 17 CFR 240.17a-5{e)(3} or 17 CFR 240.18a-7(d)(2}, as applicable. {3}------------------------------------------------ ![](_page_3_Picture_0.jpeg) #### **Report of Independent Registered Public Accounting Firm** To the Management and Member of Acorns Securities, LLC #### **Opinion** *on the Statement of Financial Condition* We have audited the accompanying statement of financial condition of Acorns Securities, LLC (the "Company") as of December 31, 2025 (the "financial statement"). In our opinion, the financial statement presents fairly, in all material respects, the financial position of the Company as of December 31, 2025, in conformity with accounting principles generally accepted in the United States of America. #### *Basis for Opinion* The financial statement is the responsibility of the Company's management. Our responsibility is to express an opinion on the Company's financial statement based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. We conducted our audit of this financial statement in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statement is free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statement, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statement. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as, evaluating the overall presentation of the financial statement. We believe that our audit provides a reasonable basis for our opinion. **u:p** February 26, 2026 We have served as the Company's auditor since 2022. www.pwc.com PricewaterhouseCoopers LLP, 601 South Figueroa Street, Los Angeles, CA 90017 +1213 356 6000 {4}------------------------------------------------ | ASSETS | | |--------------------------------------------------------------------------------|-------------------| | Cash and cash equivalents | \$
23,371,685 | | Cash and securities segregated under federal or other regulations | 18,117,190 | | Receivable from clearing firms | 50,771,574 | | Investments in fractional shares held by customers | 1,440,014,129 | | Securities owned -
at fair value | 1,390 | | Receivable from customers, net of allowance for doubtful accounts of \$251,942 | 937,440 | | Receivable from affiliates | 27,191 | | Prepaid expenses and other assets | 3,963,301 | | Cash deposited with clearing firm | 252.720 | | TOTAL ASSETS | \$ 1 .537.456.620 | | LIABILITIES AND MEMBER'S EQUITY | | | LIABILITIES | | | Payable to customers | \$
65,889,203 | | Repurchase obligation for investments held by customers | 1,440,014,129 | | Accounts payable and accrued expenses | 3,633,599 | | Payable to affiliates | 2,390.822 | | TOTAL LIABILITIES | 1,511,927,753 | |-----------------------------------------|---------------| | COMMITMENTS AND CONTINGENCIES (Note 11) | | | MEMBER'S EQUITY | 25.528.867 | |---------------------------------------|-------------------| | TOTAL LIABILITIES AND MEMBER'S EQUITY | \$ 1 .537.456.620 | {5}------------------------------------------------ ### **1. Organization and Nature of Business** Acorns Securities, LLC (the "Company") was organized in the State of Delaware on April 9, 2013. The Company is a registered broker-dealer in securities under the Securities and Exchange Act of 1934. The Company is a member of the Financial Industry Regulatory Authority(" FINRA") and the Securities Investor Protection Corporation (" SIPC"). Under its membership agreement with FINRA, the Company maintains subaccounts pursuant to an omnibus arrangement with two clearing firms. The Company provides custodial services to the retail advisory customers of its affiliated investment adviser, Acorns Advisers, LLC ("Advisers"). The Company is subject to the requirements of Customer Protection Rule 1 Sc3-3 ("Rule 1 Sc3-3") and Net Capital Rule 1 Sc3-1 ("Rule 1 Sc3-1 ") under the Securities Exchange Act of 1934. The Company operates in one segment, based on similarities in economic characteristics between its operations, the common nature of its services and the regulatory environment under which it operates. ## **2. Significant Accounting Policies** Basis of Presentation - The Company maintains its accounts and prepares its financial statements in conformity with accounting principles generally accepted in the United States of America ("U.S. GAAP"). Use of Estimates in the Preparation of Financial Statements - The preparation of the accompanying financial statements requires management to make estimates, judgments, 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. Management believes that the estimates utilized in the preparation of the financial statements are prudent and reasonable based on the best available information. Actual results could differ from those estimates. **Segment Reporting** - The Company operates as a broker-dealer as one reportable segment, which is comprised of several classes of services, including principal transactions and custodial services for its affiliate as described in Note 2, Significant Accounting Policies sub-section 'Revenue' of the financial statements. The Company's {6}------------------------------------------------ chief operating decision maker (CODM) is the chief executive officer. The CODM manages the Company, assesses performance and decides how to allocate resources based on net income of the Company as a whole, as constructed and presented on the Statement of Operations. Additionally, the CODM uses excess net capital (see Note 16), which is not a measure of profit and loss, to make operational decisions while maintaining capital adequacy. The Company manages its business activities on a consolidated basis based on similarities in economic characteristics between its operations, the common nature of its services and the regulatory environment under which it operates. The accounting policies used to measure the profit and loss of the segment are the same as those described in Note 2, Significant Accounting Policies. Cash and Cash Equivalents - The Company has defined cash equivalents as highly liquid investments, with original maturities of three months or less that are not segregated and on deposit for federal or regulatory purposes. Cash and cash equivalents include deposits with financial institutions in the form of checking deposits and money market funds. Receivable from Clearing Firms - Receivable from clearing firms includes amounts receivables arising from unsettled trades and cash deposited at the clearing firms. Securities Transactions - The Company does not actively trade in exchange traded funds (ETFs) or other securities for its own account. Leases - In connection with Financial Accounting Standards Board ("FASB") Accounting Standards Update Topic 842, Leases ("ASU No. 2018-11 "), the Company has a sublease arrangement with its Parent whereby the Company rents office space from the Parent for a monthly fee. The Company does not possess control over the lease terms. As such, the Company does not have an obligation to record a right to use asset or an offsetting lease obligation. Revenue - The Company earns brokerage and custodial service fees from its affiliate, Advisers, by maintaining accounts, acting as custodian, effecting securities transactions, and generating account statements for Advisers' clients. Fee revenue made up 63 percent of the Company's total revenue for the year ended December 31, 2025. In addition, the Company earns fees for facilitating the transfer of assets for Advisers' clients and earns revenue from a third-party service provider for proxy-service reimbursements. {7}------------------------------------------------ *Stock-Based Compensation* - The company estimates the fair value of stock-based awards of options to purchase shares of common stock to employees using the Black-Scholes option pricing model. Stock-based awards are subject to service-based vesting conditions. Compensation expense related to awards with service-based vesting conditions is recognized on a straight-line basis based on the grant date fair value over the associated requisite service period of the award, which is generally the vesting term. Stock-based awards with performance conditions, which we have offered infrequently, are expensed under the accelerated attribution method to the extent the achievement of the performance condition is probable. Forfeitures are accounted for as they occur. *Accounting Policies Adopted* - In November 2023, the FASB issued ASU 2023-07, Segment Reporting. This ASU amends ASC Topic 280 and requires incremental disclosures related to a public business entity's reportable segments. The Company adopted this ASU in 2024 and has provided the additional disclosures in Note 2, Significant Accounting Policies. The adoption did not have a material impact on its financial statements. ## **3. Cash Segregated Under Securities Regulations** At December 31, 2025, cash of \$18,117,190 has been segregated in a special reserve account for the exclusive benefit of customers pursuant to Rule 15c3-3 under the Securities Exchange Act of 1934. ## **4. Deposit at Clearing Firms** The Company has omnibus account trading agreements with clearing firms, RBC Capital Markets, LLC and DriveWealth, LLC in order to execute trades on behalf of the clients of its affiliated adviser, Acorns Advisers, LLC. The clearing firms have custody of the Company's cash balances which serve as collateral for any amounts due to the clearing firms. The combined cash balance at December 31, 2025 was \$250,000. RBC Capital Markets, LLC and DriveWealth, LLC pay interest monthly on the cash deposited at the average overnight repurchase rate. ## **5. Fair Value of Financial Instruments** We apply fair value accounting for all financial instruments that are recognized or disclosed at fair value in the financial statements on a recurring basis. Fair value is {8}------------------------------------------------ defined as the price that would be received from selling an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date. When determining the fair value measurements for assets and liabilities we consider the principal or most advantageous market in which we would transact and the marketbased risk measurements or assumptions that market participants would use in pricing the asset or liability, such as risks inherent in valuation techniques, transfer restrictions and credit risk. For certain instruments, including cash and cash equivalents, clearing firm receivable, accounts receivable, customer payable, and accounts payable, it is estimated that the carrying amount approximated fair value because of the short maturities of these instruments. Cash and cash equivalents are classified as Level 1 of the fair value hierarchy. Clearing firm receivables, accounts receivable, customer payable, and accounts payable are classified as Level 2 of the fair value hierarchy due to their short-term nature. US GAAP requires disclosure of the estimated fair value of certain financial instruments and the methods and significant assumptions used to estimate their fair values. ASC 820 (Fair Value Measurements and Disclosures) defines fair value, establishes a framework for measuring fair value, establishes a fair value hierarchy based on the quality of inputs used to measure fair value, and enhances disclosure requirements for fair value measurements. In accordance with ASC 820, the Company has categorized its financial instruments, based on the priority of the inputs to the valuation technique, into a three-level fair value hierarchy. The fair value hierarchy gives the highest priority to unadjusted quoted prices in active markets for identical assets or liabilities (Level 1) and the lowest priority to unobservable inputs (Level 3). The inputs and assumptions used in valuation models are classified in the fair value hierarchy as follows: Level 1: Quoted prices (unadjusted) in active markets that are accessible at the measurement date for assets or liabilities. The fair value hierarchy gives the highest priority to Level 1 inputs. Level 2: Quoted market prices for similar instruments in an active market; quoted prices for identical or similar assets and liabilities in markets that are not active; and modelderived valuations inputs of which are observable and can be corroborated by market data. Level 3: Unobservable inputs and assumptions that are supported by little or no market activity and that are significant to the fair value of the asset and liability. The fair value hierarchy gives the lowest priority to Level 3 inputs. {9}------------------------------------------------ In determining the appropriate hierarchy levels, the Company analyzes the assets and liabilities that are subject to fair value disclosure. Financial assets and liabilities are classified in their entirety based on the lowest level of input that is significant to their fair value measurement. There were no assets and liabilities measured at fair value on a non-recurring basis at December 31, 2025. Securities held by the Company were exchange-traded funds and stocks. The following table presents the Company's securities that are measured at fair value on a recurring basis by fair value hierarchy at December 31, 2025: | Assets | Level 1 | Level2 | | Level3 | | |---------------------------------------|------------------|--------|--------|--------|--------| | Investments in fractional shares held | | \$ | | \$ | | | by customers | \$ 1,440,014,129 | | | | | | Securities owned | 1,390 | | | | | | Total assets | \$1,440,015,519 | \$ | | \$ | | | Liabilities | Level 1 | | Level2 | | Level3 | | Repurchase obligation for investments | | | | | | | held by customers | \$ 1,440,014,129 | \$ | | \$ | | | Total liabilities | \$ 1,440,014,129 | \$ | | \$ | | ## **6. Receivable From Clearing Firms** Pursuant to the clearing agreements, the Company introduces all its securities transactions to its clearing firms on an omnibus basis. In accordance with the clearing agreements, the Company has agreed to indemnify the clearing firms for losses, if any, which the clearing firms may sustain from carrying securities transactions introduced by the Company. As of December 31, 2025, receivable from clearing firms were \$50,771,574 related to pending customer transactions, and the Company has not recognized any losses related to the clearing firms carrying of securities. # **7. Investment in Fractional Shares and Repurchase Obligation for Investments Held By Customers** The Company executes and allocates purchases and sales of investment securities based on Advisers' customer portfolio investment engine algorithm. These transactions result in fractional shares of ETFs held by customers and Advisers. Fractional shares {10}------------------------------------------------ held by customers do not meet the criteria for derecognition under ASC 860, Transfers and Servicing, and are accounted for as a secured borrowing (repurchase obligation). These financial assets are presented as investments in fractional shares held by customers and a corresponding repurchase obligation for investments held by customers. We have elected the fair value option to measure these financial assets and the corresponding repurchase obligation for investments. The fair value of these investments is determined by quoted prices in active markets. ### **8. Receivable from Customers** Customer receivables represent amounts due to the Company in connection with the reversal of ACH transactions related to security transactions. Total customer receivables net of allowance for doubtful accounts as of December 31, 2025 were \$937,440. ## **9. Payable to Customers** Customer payables represent free credit balances from customer funds on deposit, funds related to settled security transactions and dividend payments. Total customer payables as of December 31, 2025 were \$65,889,203. ## **10. Related-Party Transactions** In October 2021, the Company and the Parent entered into an expense sharing agreement whereby the Parent will provide the Company technology services required to operate the Company's business, including access to the Parent's administration tool so it can monitor brokerage customer activity. In addition, the Company agrees to reimburse the Parent for payroll, equipment, costs related to automated clearing house transactions and other incidental expenses paid on behalf of the Company. The agreement was superseded by the September 2025 agreement between the Company and the Parent for which all services are described. For the year ended December 31, 2025 the Company paid \$2,617,506 in technology licensing fees to the Parent of which \$224,468 was payable at year-end. In addition, the Company reimbursed \$3,582,450 to the Parent per the agreement. As of December 31, 2025, \$354,117 was payable to the Parent included in Payables to Affiliates. The Company is affiliated through common ownership with Advisers. During April of 2014, the Company and Advisers entered into a brokerage and custodial services agreement whereby the Company agrees to establish and maintain an account on its {11}------------------------------------------------ books and records for each client of Advisers ("Clients"). Accordingly, the Company has established several omnibus accounts for the benefit of Clients which are maintained by two clearing firms. Furthermore, the Company is responsible for instructing the clearing firms to maintain possession or control of investments in these omnibus accounts free of any charge, lien, or claim of any kind in favor of the clearing firms or any person claiming through the clearing firms. The agreement was superseded by the June 2022 agreement between the Company and Advisers, whereby the Company is reimbursed for all orders and instructions obtained by Advisers. For the twelve months ended December 31, 2025, the Company earned \$11,131,764 from Advisers in fees that are settled monthly as part of the intercompany settlement process and of which \$0 was receivable at year-end. Further, the Company allocates payroll costs to Advisers for services provided by the Company's employees on behalf of the affiliated investment adviser. As of year-end, the Company allocated \$1,957,354 of payroll costs to Advisers of which \$160,964 was receivable as of December 31, 2025, which is netted with the amounts payable to Advisers. The Company had a net receivable from Advisers of \$27,191 which includes reimbursements for orders and instructions and reimbursable payroll costs as of December 31, 2025 and is included in Receivable from affiliates in the accompanying statement of financial condition. Stock-based awards are granted to employees pursuant to the Company's Parent Equity Incentive Plan. The awards are treated as additions to capital from the Parent and expensed on a straight-line basis. Total stock compensation expense for the year ending December 31, 2025 was \$585,464. It is possible that the terms of certain of the related-party transactions are not the same as those that would result for transactions among wholly unrelated parties. #### **11. Commitments and Contingencies** As of December 31, 2025 the Company had no contractual commitments. #### **12. Guarantees** FASB ASC Topic 460, Guarantees ("ASC 460") requires the Company to disclose information about its obligations under certain guarantee arrangements. ASC 460 defines guarantees as contracts and indemnification agreements that contingently require a guarantor to make payments to the guaranteed party based on changes in an {12}------------------------------------------------ underlying factor (such as an interest or foreign exchange rate, security or commodity price, an index or the occurrence or nonoccurrence of a specified event) related to an asset, liability or equity security of a guaranteed party. This guidance also defines guarantees as contracts that contingently require the guarantor to make payments to the guaranteed party based on another entity's failure to perform under an agreement as well as indirect guarantees of indebtedness of others. The Company has issued no guarantees for the year ended December 31, 2025. ## **13. Concentration of Credit Risk** The Company maintains bank accounts at financial institutions. These accounts are insured either by the Federal Deposit Insurance Commission ("FDIC"), up to \$250,000, or the Securities Investor Protection Corporation ("SIPC"), up to \$500,000. At times during the year, cash balances held in financial institutions were in excess of the FDIC and SIPC's insured limits. The Company has not experienced any losses in such accounts and management believes that it has placed its cash on deposit with financial institutions which are financially stable. The Company is engaged in various trading and brokerage activities in which counterparties primarily include broker-dealers, banks, and other financial institutions. In the event counterparties do not fulfill their obligations, the Company may be exposed to risk. The risk of default depends on the creditworthiness of the counterparty or issuer of the instrument. It is the Company's policy to review, as necessary, the credit standing of each counterparty. ## **14. Net Capital Requirements** The Company is subject to the Securities and Exchange Commission Uniform Net Capital Rule (SEC Rule 15c3-1 ). The Company computes its net capital requirement under the alternative method provided for in Rule 15c3-1, which requires the Company to maintain minimum net capital of not less than 2% of aggregate debit items arising from customer transactions or \$250,000, whichever is greater. Rule 15c3-1 also requires that equity capital may not be withdrawn or cash dividends paid if the resulting net capital is less than 5% of such items. At December 31, 2025, the Company had net capital of \$21,100,531 which was \$20,088,167 in excess of its required net capital of \$1,012,364. {13}------------------------------------------------ #### **15. Subsequent Events** Subsequent to the balance sheet date, the Company returned capital of \$15,000,000 to its parent company. The repayment was approved by management and executed on February 24, 2026, as part of the Company's ongoing capital management strategy. The Company remains fully capitalized and in compliance with all applicable regulatory capital requirements following this transaction. The Company has evaluated subsequent events through February 26, 2026, the date the financial statements were authorized for issuance, and no other events requiring disclosure were noted." \*\*\*\*\*\* Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.