# Ares Management Capital Markets LLC/DE X-17A-5 (2026-03-10) — Broker-dealer annual report - Company: Ares Management Capital Markets LLC/DE - Form: X-17A-5 - Filed: 2026-03-10 - Period: 2025-12-31 - Accession: 0001628280-26-016380 - CIK: 1562245 - File #: 8-69194 - Type: Broker-dealer - Material weakness: No - Auditor: Ernst & Young LLP - Auditor location: Los Angeles, CA - Contact: Mark C. Infanger - Phone: 310-432-8873 - Email: minfanger@aresmgmt.com - Website: aresmgmt.com - Signed by: Mark C. Infanger (Chief Financial Officer) Original filing: https://www.sec.gov/Archives/edgar/data/1562245/000162828026016380/amcmfs2025.pdf --- {0}------------------------------------------------ ### **UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549** | ANNUAL REPORTS | |----------------| | FORM X-17A-5 | | PART Ill | | 0MB APPROVAL | |---------------------------| | 0MB Number: 3235-0123 | | Expires: Nov. 30, 2026 | | Estimated average burden | | hours per response:
12 | SEC FILE NUMBER 8-69194 **FACING PAGE** **Information Required Pursuant to Rules 17a-5, 17a-12, and lSa-7 under the Securities Exchange Act of 1934** FILING FOR THE PERIOD BEGINNING 01101125 AND ENDING 12131125 ---------- ----------- MM/DD/YY MM/DD/VY **A. REGISTRANT IDENTIFICATION** NAME OF FIRM: ARES MANAGEMENT CAPITAL MARKETS LLC TYPE OF REGISTRANT (check all applicable boxes): **liil** Broker-dealer D Security-based swap dealer D Major security-based swap participant D Check here if respondent is also an OTC derivatives dealer ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) 1200 17TH STREET, STE 2900 | | (No. and Street) | | |----------------------------------------------|------------------|------------------------| | Denver | co | 80202 | | (City) | (State) | (Zip Code) | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | MARK C. INFANGER | 310.432.8873 | MINFANGER@ARESMGMT.COM | | {Name) | (Area Code - Telephone Number) | (Email Address) | |--------|--------------------------------|-----------------| |--------|--------------------------------|-----------------| #### **B. ACCOUNTANT IDENTIFICATION** INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing\* ERNST & YOUNG LLP | LOS ANGELES | | |-------------|-------------------------------------------------| | | CA
90017 | | | (State)
(Zip Code} | | 42 | | | | I
(PCAOB Registcatioo Nombec, if applicable) | | | | | | | | (City) | 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.** {1}------------------------------------------------ #### **OATH OR AFFIRMATION** | MARK C. INFANGER
I, | |------------------------| |------------------------| I, MARK C. INFANGER swear (or affirm) that, to the best of my knowledge and belief, the financial report pertaining to the firm of ARES MANAGEMENT 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 a customer. ![](_page_1_Picture_5.jpeg) Signature~ **C.** ~ ,---- Title: CHIEF FINANCIAL OFFICER ### **This filing\*\* contains (check all applicable boxes):** - ii (a) Statement of financial condition. - D (b} Notes to consolidated statement of financial condition. - ii (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}. - ii (d} Statement of cash flows. - ii (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. - ii (g) Notes to consolidated financial statements. - ii (h) Computation of net capital under 17 CFR 240.1Sc3-1 or 17 CFR 240.18a-1, as applicable. - 0 (i) Computation of tangible net worth under 17 CFR 240.18a-2. - D (j} Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.1Sc3-3. - D (k) Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.1Sc3-3 or Exhibit A to 17 CFR 240.18a-4, as applicable. - 0 (I) Computation for Determination of PAB Requirements under Exhibit A to§ 240.1Sc3-3. - 0 (m) Information relating to possession or control requirements for customers under 17 CFR 240.1Sc3-3. - D (n) Information relating to possession or control requirements for security-based swap customers under 17 CFR 240.1Sc3-3(p)(2) or 17 CFR 240.18a-4, as applicable. - 0 (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capital or tangible net worth under 17 CFR 240.1Sc3-l, 17 CFR 240.18a-1, or 17 CFR 240.18a-2, as applicable, and the reserve requirements under 17 CFR 240.1Sc3-3 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. - ii (q) Oath or affirmation in accordance with 17 CFR 240.17a-S, 17 CFR 240.l 7a-12, or 17 CFR 240.18a-7, as applicable. - D (r) Compliance report in accordance with 17 CFR 240.l 7a-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. - 0 (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. l 7a-S, 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-S or 17 CFR 240.18a-7, as applicable. - (w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.l 7a-S or 17 CFR 240.18a-7, as applicable. - D (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.1Sc3-le or 17 CFR 240.17a-12, as applicable. - D (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.l 7a-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. {2}------------------------------------------------ ### **ARES MANAGEMENT CAPITAL MARKETS, LLC** ### **Table of Contents** | Report of Independent Registered Public Accounting Firm | 1 | |--------------------------------------------------------------------------------------------------------|----| | Financial Statements: | | | Statement of Financial Condition | 2 | | Statement of Comprehensive Income | 3 | | Statement of Changes in Member's Equity | 4 | | Statement of Cash Flows | 5 | | Notes to the Financial Statements | 6 | | Supplemental Schedules | | | Schedule I – Computation of Net Capital Under Rule 15c3-1 of the Securities and Exchange
Commission | 10 | {3}------------------------------------------------ ![](_page_3_Picture_0.jpeg) Ernst & Young LLP Suite 500 725 South Figueroa Street Los Angeles, CA 90017-5418 Tel: +1 213 977 3200 Fax: +1 213 977 3152 ey.com # **Report of Independent Registered Public Accounting Firm** To the Managing Member and Those Charged with Governance of Ares Management Capital Markets, LLC ## **Opinion on the Financial Statements** We have audited the accompanying statement of financial condition of Ares Management Capital Markets, LLC (the "Company") as of December 31, 2025, the related statements of comprehensive income, 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 opinion, the financial statements present fairly, in all material respects, the financial position of the Company at December 31, 2025, and the results of its operations and its cash flows for the year then ended in conformity with U.S. generally accepted accounting principles. # **Basis for Opinion** These financial statements are the responsibility of the Company's management. Our responsibility is to express an opinion on 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** The accompanying information contained in Schedule I has been subjected to audit procedures performed in conjunction with the audit of the Company's financial statements. Such information is the responsibility of the Company's management. Our audit procedures included determining whether the 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. In forming our opinion on the information, we evaluated whether such information, including its form and content, is presented in conformity with Rule 17a-5 under the Securities Exchange Act of 1934. In our opinion, the information is fairly stated, in all material respects, in relation to the financial statements as a whole. We have served as the Company's auditor since 2014. March 2, 2026 {4}------------------------------------------------ #### **ARES MANAGEMENT CAPITAL MARKETS, LLC Statement of Financial Condition** | | As of | | |---------------------------------------|-------------------|-----------| | | December 31, 2025 | | | Assets | | | | Cash | \$ | 8,705,015 | | Interest and other receivables | | 121,567 | | Prepaid expense and other assets | | 603,919 | | Total assets | \$ | 9,430,501 | | | | | | Liabilities and member's equity | | | | Accrued expenses | \$ | 207,167 | | Payable to affiliate, net | | 6,128 | | Total liabilities | | 213,295 | | | | | | Member's equity | | 9,217,206 | | | | | | Total liabilities and member's equity | \$ | 9,430,501 | {5}------------------------------------------------ ### **ARES MANAGEMENT CAPITAL MARKETS, LLC Statement of Comprehensive Income** | | For the Year Ended | | |-------------------------------------|--------------------|--| | | December 31, 2025 | | | Revenue | | | | Placement fees from affiliate | \$
19,875,204 | | | Capital markets transaction fees | 15,345,568 | | | Total revenues | 35,220,772 | | | | | | | Expenses | | | | Compensation and benefits | 23,235,635 | | | Occupancy | 2,829,350 | | | Regulatory costs | 1,432,732 | | | General and administrative expenses | 1,571,359 | | | Total expenses | 29,069,076 | | | | | | | Non-operating income | | | | Interest and other income, net | 210,010 | | | Total other income | 210,010 | | | | | | | Net income | \$
6,361,706 | | {6}------------------------------------------------ #### **ARES MANAGEMENT CAPITAL MARKETS, LLC Statement of Changes in Member's Equity** | Balance at December 31, 2024 | \$
5,005,500 | |------------------------------|-----------------| | Distributions | (2,150,000) | | Net income | 6,361,706 | | Balance at December 31, 2025 | \$
9,217,206 | . {7}------------------------------------------------ #### **ARES MANAGEMENT CAPITAL MARKETS, LLC Statement of Cash Flows** | | For the Year Ended | | |----------------------------------------------------------------|--------------------|--| | | December 31, 2025 | | | Cash flows from operating activities: | | | | Net income | \$
6,361,706 | | | Cash flows due to changes in operating assets and liabilities: | | | | Other receivables | 1,036,433 | | | Prepaid expenses and other assets | (383,244) | | | Payable to affiliate, net | 195,900 | | | Accrued expenses | 130,236 | | | Net cash provided by operating activities | 7,341,031 | | | | | | | Cash flows used in financing activities: | | | | Distributions | (2,150,000) | | | Net cash used in financing activities | (2,150,000) | | | | | | | Net increase in cash | 5,191,031 | | | Cash at beginning of year | 3,513,984 | | | Cash at end of year | \$
8,705,015 | | {8}------------------------------------------------ ### **(1) Nature of Business and Summary of Significant Accounting Policies** Ares Management Capital Markets, LLC ("AMCM" or the "Company"), a wholly owned subsidiary of Ares Management, LLC ("AM LLC"), is a registered broker-dealer with the Securities and Exchange Commission ("SEC") and a member of the Financial Industry Regulatory Authority ("FINRA"). AM LLC is a wholly owned subsidiary of Ares Management Corporation. AMCM acts as a private offering placement agent, best efforts underwriter, and advisor for AM LLC and its affiliates in connection with various corporate transactions. AMCM is subject to the SEC's uniform net capital rule of the Securities Exchange Act ("Rule 15c3-1"), which specifies the minimum level of net capital a broker-dealer must maintain. ### *Basis of Accounting and Use of Estimates* The Company prepares the financial statements in accordance with generally accepted accounting principles in the United States of America ("GAAP"). The preparation of financial statements in conformity with GAAP requires management to make assumptions and estimates that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements, as well as, the reported amounts of revenues and expenses during the reporting period. Management's estimates are based on historical experiences and other factors, including expectations of future events that management believes to be reasonable under the circumstances; however, due to the inherent uncertainties in making estimates, actual amounts could differ from these estimates. #### *Cash* Cash includes a liquid balance in a demand deposit account that is available to support the general liquidity needs of the Company. At December 31, 2025, the Company had cash balances with financial institutions in excess of Federal Deposit Insurance Corporation insured limits. The Company monitors the credit standing of financial institutions holding its cash balances. ### *Financial Instruments* The Company considers cash, receivables, prepaid expenses, payables to affiliates, and accrued expenses to be its financial instruments. The carrying amounts reported in the Statement of Financial Condition for these financial instruments equal or closely approximate their fair values. #### *Revenues* The Company recognizes revenue in a way that depicts the transfer of promised goods or services to customers in an amount that reflects the consideration to which the Company expects to be entitled in exchange for those goods or services. The Company's revenue is based on a determinable transaction price and distinct performance obligations with probable collectability. Revenues are not recognized until the performance obligations are satisfied. The Company provides services to AM LLC pursuant to an executed related party agreement ("Placement Agency Agreement"), and in return for its services, the Company is reimbursed for the amount to ensure that AMCM's net income is not less than zero. The Company records these expense reimbursements as revenue in the period in which the expenses are incurred. As the Company is deemed a principal with respect to services provided, revenues received pursuant to the Placement Agency Agreement are presented gross of the related operating expenses. The Company earns capital markets transaction fees for participating as an underwriter and/or acting as an advisor in structuring capital markets transactions. Underwriting activities are recognized on the trade date, while advisory services are recognized upon the successful completion of the associated transaction. As the Company is deemed a principal with respect to transactions in which it acts as an underwriter, the Company presents its proportionate share of capital markets transaction revenues and expenses on a gross basis. {9}------------------------------------------------ ### *Compensation and Benefits* Compensation generally includes allocated salaries, bonuses and stock-based compensation from affiliates of the Company as the Company has no employees. Bonuses are recorded and paid during the period in which the services are provided. Effective July 1, 2025 and in connection with amendment to the Expense Reimbursement Agreement described below, the Company no longer records the allocation of expenses provided by certain affiliates, including compensation and benefits expenses. ### *Income Taxes* The Company's earnings flow through to AM LLC, the parent of the Company, without being subject to entity level income taxes. Consequently, the Company's earnings reflect no provision for income taxes. At December 31, 2025, the Company had no significant uncertain tax position. The Company is subject to income tax examination by taxing authorities for all tax years after and including 2022. The Company recognizes both accrued interest and penalties in its statement of comprehensive income, when appropriate. For the year ended December 31, 2025, no such interest or penalties have been incurred. ### *Recent Accounting Pronouncements* The Company considers the applicability and impact of all Accounting Standards Updates ("ASUs") issued. No recent accounting pronouncements were determined to be applicable or are expected to have minimal impact on its financial statements. ### **(2) Related Party Transactions** AM LLC and its affiliates share personnel, office space and equipment with the Company. The Company entered into an agreement with AM LLC, as amended and restated on June 1, 2019 and July 1, 2025, referred to herein as the "Expense Reimbursement Agreement," under which shared expenses are allocated based on the provisions of this agreement. The Expense Reimbursement Agreement states that AM LLC either directly or through its affiliate, Ares Operations, LLC ("Ares Ops"), will provide personnel, overhead, office facilities and equipment and various other shared services. AM LLC and its affiliates are willing to provide the Company with these shared services subject to being reimbursed for the costs of such services. As of the amendment effective July 1, 2025, AM LLC will continue to provide these services, but the Company is not directly or indirectly liable for expenses related to these services and no expense allocation is recorded at the Company. Expenses allocated to the Company prior to the amendment are included in the Statement of Comprehensive Income. The following is a summary of these expenses for January 1 through June 30, 2025: | Compensation and benefits | \$
23,235,635 | |-------------------------------------|------------------| | Occupancy | 2,829,350 | | General and administrative expenses | 1,413,470 | | Total | \$
27,478,455 | The Company is party to a Placement Agency Agreement with AM LLC, as amended and restated on July 1, 2025. In consideration for the services performed by the Company, AM LLC shall cause the Company to be reimbursed to ensure that AMCM's net income is not less than zero, including expenses allocated in accordance with the terms of the Expense Reimbursement Agreement. Additionally, all parties agree that all non-securities transactions resulting in accounts receivable and accounts payable among the Companies may be recorded as they originated but for accounting purposes shall be treated on a net basis. {10}------------------------------------------------ During the twelve months ended December 31, 2025, the Company paid \$7,187,334 to AM LLC under the terms of the Placement Agency Agreement and the Company paid \$294,633 to Ares Ops related to expenses paid directly on behalf of the Company. Further, as of December 31, 2025, the Company had payables to Ares Ops of \$6,128 related to expenses paid on behalf of the Company included in payable to affiliate, net in the Statement of Financial Condition. ## **(3) Regulatory and Net Capital Requirements** The Company is subject to the SEC's Uniform Net Capital Rule (Rule 15c3-1), which specifies the minimum level of net capital a broker-dealer must maintain and also requires that a significant portion of a broker-dealer's assets be kept in relatively liquid form. Rule 15c3-1 requires that the Company maintain minimum net capital, as defined, and requires that the ratio of aggregate indebtedness to net capital, as those terms are defined by the rule, may not exceed 15-to-1. As of December 31, 2025, the Company's net capital was \$8,512,959 which was \$8,412,959 in excess of its required net capital of \$100,000. The Company's ratio of aggregate indebtedness to net capital was approximately 0.03-to-1.0 at December 31, 2025. # **(4) Contingencies** In the normal course of business, the Company enters into agreements that may include indemnities in favor of third parties and affiliated parties, such as engagement letters with advisors and consultants, as well as service agreements. In accordance with the Company's by-laws, the Company has also agreed to indemnify its officers, employees and agents in certain cases. Certain agreements do not contain any limits on the Company's liability, and therefore it is not possible to estimate the Company's potential liability under these indemnities. In certain cases, the Company may have recourse against third parties with respect to these indemnities. Further, the Company maintains insurance policies that may provide coverage against certain claims under these indemnities. In the normal course of business, the Company may be subject to various legal proceedings and regulatory matters. Currently there are no commitments or contingencies, inclusive of legal proceedings or regulatory matters, pending against the Company that would have a material impact on the Statement of Financial Condition. ## **(5) Segment Reporting** The Company is engaged in a single line of business as a broker-dealer, earning capital markets transaction fees for participating as an underwriter and/or acting as an advisor in structuring capital markets transactions. The Company has identified its President as the chief operating decision maker ("CODM"). The President uses net income to make operational decisions while maintaining capital adequacy. 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. {11}------------------------------------------------ ## **(6) Subsequent Events** The Company has evaluated subsequent events for potential recognition and/or disclosure through March 2, 2026, the date the financial statements were issued. On January 2, 2026, the Company completed a legal merger with its affiliated broker-dealer, Ares Wealth Management Solutions, with AMCM continuing as the surviving entity. This transaction occurred subsequent to the Company's balance sheet date and does not provide additional evidence about conditions that existed as of December 31, 2025. Accordingly, no adjustments have been made to the accompanying financial statements as of and for the year ended December 31, 2025. Except as disclosed above, no events were identified for recognition or disclosure. {12}------------------------------------------------ #### **Schedule I** #### ARES MANAGEMENT CAPITAL MARKETS, LLC Computation of Net Capital Under Rule 15c3-1 of the Securities and Exchange Commission December 31, 2025 | \$
9,217,206 | |-----------------| | | | | | 100,328 | | 603,919 | | 704,247 | | 8,512,959 | | 100,000 | | \$
8,412,959 | | \$
213,295 | | 0.03 : 1 | | | Statement pursuant to SEC Rule 17a-5(d)(2)(iii): There are no material differences between the amounts presented in the computation of net capital set forth above and the amounts reported in Ares Management Capital Markets, LLC unaudited Part II-A Quarterly FOCUS report as of December 31, 2025. {13}------------------------------------------------ ### **ARES MANAGEMENT CAPITAL MARKETS, LLC** EXEMPTION REPORT Ares Management Capital Markets, LLC (the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C.F.R. §240.17a-5, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R. §240 17a-5(d)(1) and (4). To the best of its knowledge and belief, the Company states the following: - (1) The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240. 15c3-3. - (2) The Company is filing this Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 because the Company limits its business activities exclusively to (1) acting as a placement agent for private offerings of AM LLC and its affiliates, and (2) best efforts underwriting and financial advisory services in connection with corporate transactions for affiliates of AM LLC and the Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers; (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception. I, Mark C. Infanger, affirm that, to my best knowledge and belief, this Exemption Report is true and correct. By: f. ' l (~ Chief Financial Officer March 2, 2026 {14}------------------------------------------------ ![](_page_14_Picture_0.jpeg) Ernst & Young LLP Suite 500 725 South Figueroa Street Los Angeles, CA 90017-5418 Tel: +1 213 977 3200 Fax: +1 213 977 3152 ey.com # **Report of Independent Registered Public Accounting Firm** To the Managing Member and Those Charged with Governance of Ares Management Capital Markets, LLC: We have reviewed management's statements, included in the accompanying Exemption Report, in which Ares Management Capital Markets, LLC (the "Company") stated that: - (1) The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240. 15c3-3. - (2) The Company is relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 because, the Company limits its business activities exclusively to (1) acting as a placement agent for private offerings of AM LLC and its affiliates, and (2) best efforts underwriting and financial advisory services in connection with corporate transactions for affiliates of AM LLC and the Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers; (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year ended December 31, 2025 without exception. Management is responsible for compliance with 17 C.F.R. § 240.15c3-3 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 17 C.F.R. § 240.15c3-3. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, we do not express such an opinion. Based on our review, we are not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, pursuant to footnote 74 of SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5. This report is intended solely for the information and use of the Managing Member, those charged with governance, management, the SEC, the Financial Industry Regulatory Authority, other regulatory agencies that rely on Rule 17a-5 under the Securities Exchange Act of 1934 in their regulation of registered brokers and dealers, and other recipients specified by Rule 17a-5(d)(6) and is not intended to be and should not be used by anyone other than these specified parties. March 2, 2026 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.