# CAPCONNECT EMARKETS, LLC X-17A-5 (2026-03-02) — Broker-dealer annual report - Company: CAPCONNECT EMARKETS, LLC - Form: X-17A-5 - Filed: 2026-03-02 - Period: 2025-09-30 - Accession: 0001826150-26-000005 - CIK: 1826150 - File #: 8-70596 - Type: Broker-dealer - Material weakness: No - Auditor: Brian W. Anson - Auditor location: Tarzana, CA - Contact: Brian Sweeney - Phone: 8134200555 - Email: rich@finopsolutions.com - Website: finopsolutions.com - Signed by: Brian Sweeney (Chief Compliance Officer) Original filing: https://www.sec.gov/Archives/edgar/data/1826150/000182615026000005/CapconnectSECAuditFINAL_1.pdf --- {0}------------------------------------------------ **UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549** # **ANNUAL REPORTS FORM X-17A-S PART** Ill 0MB APPROVAL 0MB Number: 3235-0123 Expires: Nov. 30, 2026 Estimated average burden hours per response: 12 SEC FILE NUMBER 8-70596 | FACING PAGE
Information Required Pursuant to Rules 17a-S, 17a-12, and 18a-7 under the Securities Exchange Act of 1934 | | | | | |------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------|---------|-------------------------|--| | AND ENDING 09/30/2025
FILING FOR THE PERIOD BEGINNING 10/01/2024 | | | | | | | MM/DD/YY | | MM/DD/YY | | | | A. REGISTRANT IDENTIFICATION | | | | | NAME oF FIRM: Capconnect + Emarkets, LLC | | | | | | TYPE OF REGISTRANT (check all applicable boxes):
~ Broker-dealer
□ Security-based swap dealer
□ Major security-based swap participant
'.J Check here if respondent is also an OTC derivatives dealer | | | | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) | | | | | | 340 North Westlake Blvd., Suite 160 | | | | | | | (No. and Street) | | | | | Westlake Village | CA | | 91362 | | | (City) | (State) | | (Zip Code) | | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | | | Rich Onesto | (34 7) 853-6534 | | rich@finopsolutions.com | | | (Name) | (Area Code -Telephone Number) | | (Email Address) | | | B. ACCOUNTANT IDENTIFICATION | | | | | | INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*
Anson, Brian W. | | | | | | (Name - if individual, state last, first, and middle name) | | | | | | 18455 Burbank Blvd., #404 Tarzan | | CA | 91356 | | | (Address) | (City) | (State) | (Zip Code) | | | 9/15/2005 | | 2370 | | | | T"
(PCAOB Registof ResistcaUoo with PCAOB)(if applicable) | | | | | | | FOR OFFICIAL USE ONLY | | | | • Claims for exemption from the requirement that the annual reports be covered by the reports of an independent public a,,ountant must be supported by a statement of facts and circumstances relied on as the basis of the ex.emption. 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** | I, Konstantinos Dafoulas | swear (or affirm) that, to the best of my knowledge and belief, the | |-----------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------| | financial report pertaining to the firm of capconnect + Emarkets, LLC | as of | | 2~
9/30
, | 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. | | | Signature: | | | | |------------|--|--|--| | Title: | | | | | CFO | | | | Notary Public #### **This filing\*\* contains (check all applicable boxes):** - **!!I** (a) Statement of financial condition. - iii (b) Notes to consolidated statement of financial condition. - **!!I** (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). - iil (d) Statement of cash flows. - iil (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. - iii (g) Notes to consolidated financial statements. - Iii (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. - iil (j) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3. - 0 (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. - D (I) Computation for Determination of PAB Requirements under Exhibit A to§ 240.15c3-3. - Iii (m) Information relating to possession or control requirements for customers under 17 CFR 240.1Sc3-3. - □ (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. - ~ (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. - **!!I** (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. - D (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-S 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. - iii (u) Independent public accountant's report based on an examination of the financial report or financial statement s 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. - iii (w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-S or 17 CFR 240.18a-7, as applicable. - 0 (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-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 240.17a-12(k). □ (z) Other:- ----------------------------------- --- - - \*\*To request confidential treatment af certain portions af this filing, see 17 CFR 240.17a-5(e)(3) or 17 CFR 240.18a-7(d){2), as applicable. {2}------------------------------------------------ **FINANCIAL** STATEMENTS **AND ACCOMPANYING SUPPLEMENTARY INFORMATION** REPORT PURSUANT TO SEC RULE 17a-5(d) FOR THE YEAR ENDED SEPTEMBER 30, 2025 {3}------------------------------------------------ # CAPCONN ECT + Emarkets, LLC # Table of Contents | | Repon of (ndependent Registered Public Accounting Finn | | |----------------------------------|------------------------------------------------------------------------------------------|-----| | Statement of Financial Condition | | 2 | | Statement oflncome | | 3 | | Statement of Member's Equity | | 4 | | Statement of Cash Flows | | 5 | | Notes to Financial Statements | | 6-8 | | Supplemental Information | | | | Schedule I | Statement of Net Capital | 9 | | Schedule II | Determination of Reserve Requirements | 10 | | Schedule III | lnfonnation Relating to Possession or Control | | | | Report of Independent Registered Public Accounting Finn
On Review of Exemption Report | l l | | | Assertions Regarding Exemption Provisions | 12 | {4}------------------------------------------------ # **BRIAN W. ANSON** *Certified Public Accountant* 18455 Burbank Blvd., Suite 406, Tarzana, CA 91356 • Tel. (818) 636-5660 # **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** To the Member's and Board of Members of CapConnect+Emarkets, LLC. # **Opinion on the Financial Statements** I have audited the accompanying statement of financial condition of CapConnect+Emarkets, LLC as of September 30, 2025, the related statements of 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 my opinion, the financial statements present fairly, in all material respects, the financial position of CapConnect+Emarkets, LLC as of September 30, 2025, and the results of its operations and its cash flows for the year then ended in conformity with accounting principles generally accepted in the United States of America. # **Basis for Opinion** These financial statements are the responsibility of CapConnect+Emarkets, LLC's management. My responsibility is to express an opinion on CapConnect+Emarkets, LLC's financial statements based on my audit. I am a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and am required to be independent with respect to CapConnect+Emarkets, LLC in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. I conducted my audit in accordance with the standards of the PCAOB. Those standards require that I 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. My 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. My audit also included evaluating the accounting principles used and significant estimates made by management, as evaluating the overall presentation of the financial statements. I believe that my audit provides a reasonable basis for my opinion. # **Auditor's Report on Supplemental Information** The information contained in Schedule I, II, and III ("Supplemental Information") has been subjected to audit procedures performed in conjunction with the audit of the CapConnect+Emarkets, LLC's financial statements. The Supplemental Information is the responsibility of the CapConnect+Emarkets, LLC's management. My 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 lnformation. In forming my opinion on the Supplemental Information, I evaluated whether the Supplemental Information, including its form and content is presented in conformity with 17 C.F.R. § 240. l 7a-5. In my opinion, Schedules I, II, and III are fairly stated, in all material respects, in relation to the financial atements taken as a whole. B **A** I have served as CapConnect+Emarkets, LLC's auditor since 2023. Tarzana, California December 9, 2025 {5}------------------------------------------------ #### Statement off inancial Condition September :m, 2025 #### ASSETS | Cash and Cash Equivalents | \$
36,089 | |-----------------------------------|---------------| | Accounts Receivable | 312.500 | | Prepaid Expenses and Other Assets | 2,086 | | Total Assets | \$
350,675 | #### UABILITIES AND MEMBER'S EQUITY #### LIABILITIES | Accounts payable
Due to Parent | 8,440
\$
1,888 | |--------------------------------------|----------------------| | Total Liabilities | 10.317 | | Member's Equity | 340,358 | | Total Liabilities and Members Equity | \$
350,675 | The accompanying notes are an integral part of these financial statements {6}------------------------------------------------ #### Statement of Income For the Year Ended September 30, 2025 | REVENUES
Revenue Share Income
Software Licensing Agreement
Inta-1::sl lm:.omc | \$9,467
937,500
1,641 | |----------------------------------------------------------------------------------------|-----------------------------| | Total Revenue | \$
948,608 | | OPERATING EXPENSES | | | Professional Fees | 40,679 | | lntercompany Expenses | 7,056 | | Email Archiving & Software | 5,212 | | Insurance | 6,612 | | Regulatory Fees | 3,057 | | Office and Other Expenses | 2,176 | | | 64,792 | | NET INCOME | s
§BJ,Bl!l | {7}------------------------------------------------ # Statement of Changes Member's Equity For the Year Ended September 30, 2025 | | Total
Member's
Equity | | | |------------------------------------|-----------------------------|--|--| | Beginning balance, October 1, 2024 | \$
53,242 | | | | Distributions | (596.700) | | | | Net lncome | SS3,S\6 | | | | Ending balance, September 30, 2025 | S
340,358 | | | The accompanying note1> are an integral part of these financial statements {8}------------------------------------------------ # Statement of Cash Flows For the Year Ended September 30, 2025 #### CASH FLOWS FROM OPERA TING ACTJVJTJES: | Net Income | \$ | 883,816 | |---------------------------------------------------------|----|-----------| | Adjustments to reconcile net income to net cash used in | | | | Operating activities: | | | | (Increase) decrease in assets: | | | | Accounts Receivable | | (312,500) | | Prepaid Expenses and Other Assets | | (1,683) | | Increase {decrease) in liabilities: | | | | Accounts Payable | | 2,373 | | Due to Parent | | 1,417 | | Total adjustments | | (310.393) | | Net Increase provided by operating activities | | 573.423 | | Cash flows from financing activities
Distributions | | (596,700) | | Net Decrease in cash and cash equivalents | | (23,277) | | Cash and Cash Equivalents at beginning of year | | 59.366 | | Cash and Cash Equivalents at end of year | \$ | 36,089 | | Supplemental Disclosures | | | | Cash paid during the year for: | | | | Interest | i | ~ | | Income taxes | \$ | 0 | The accompanying notes are an integral part of1h5e financial statements *5* {9}------------------------------------------------ Notes to Financial Statements September 30, 2025 ### **Note 1: GENERAL AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES** #### Organization Capconnect+ £markets, LLC (the "Company"), a Delaware Limited Liability Company, was fonned on September 27, 2020. The company received approval as a broker dealer by the Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FIN RA) effective August 10, 2021. The Company maintains an office in Westlake Village. California and is wholly owned by CapConnect+ lnc. (the "Parent"). The Company is approved, on a placement agent basis, to broker the sale of registered and private placement debt securities. The Company licenses, from its Parent, CapConnect+, Inc., a cloud-based debt issuance platform. During the year ended September 30, 2025, the Company signed a three-year agreement with one customer to lease the platform from the Company. The agreement is for three years ending September 30, 2027 with one quarter advanced notice of termination which would be the fee. The Company does not clear trades nor carry customer accounts. The Company does not take custody of customer cash or securities and operates in reliance on Footnote 74 to SEC Release 34-70073 and does not require the services of a clearing firm. #### Accounting Method The financial statements are prepared using the accrual basis of accounting m accordance with accounting principles generally accepted in the United States of America ("U.S. GAAP"). #### Use ofEstimates The preparation of financial statements in conformity with generally accepted accounting principles requires management to make estimates and assumptions that affect the reported amounts of assets 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, but management does not believe such differences will materially affect the Company's financial position, results of operations, or cash flows. # Concentrations ofCredit Risk The Company is engaged in activities in which counter parties primarily include corporations, banks., and other financial institutions. In the event counter parties do not fulfill their obligations, the Company ma\_y be exposed to nsk. The risk of default depends on the creditworthiness of the counter party or issuer of the instrument. It is the Company's policy *to* review, as necessary, the credit standing of each counter party. #### Fair Value Measurement ASC Topic 820 establishes a fair value hierarchy that prioritizes the inputs to valuation techniques used to measure fair value. The three levels ofthe fair value hierarchy are described below: Level 1 - Valuations based on quoted prices in active markets for identical assets or liabilities that an entity has the ability to access. Level 2 - Valuations based on quoted prices for similar assets and liabilities in active markets, quoted prices for identical assets and liabilities in markets that are not active, or other inputs that are observable or can be corroborated by observable data for substantially the full term of the assets or 1 iabi I ities. Level 3 - Valuations based on inputs that are supportable by little or no market activity and that are significant to the fair value of the asset or liability. {10}------------------------------------------------ Notes to Financial Statements September 30. 2025 # **Note t: GENERAL AND SUMMARY OF SIGNIFICANT ACCOt;NTING POLICIES (CONTINUED)** # Fair Value Measurement The Company had no financial instruments to measure for fair value as ofSeptember 30, 2025. #### Cash and Cash Equivalents The Company considers all highly liquid instruments with an original maturity of three months or less when purchased to be cash equivalents. The Company maintains principally alt cash balances in one financial institution which, at times, may exceed the amount insured by the Federal Deposit Insurance Corporation. The exposure to the Company is solely dependent upon daily bank balances and the respective strength of the financial institution. The Company has not incurred any losses on this account. At September 30, 2025, the amount in excess of insured limits was zero. 99% of the revenue was from one customer. #### **Note 2: INCOME TAXES** The Company is treated as a disregarded entity and has no direct federal, state, or city tax liabilities through September 30, 2025. The Company has adopted the tax prov1s1ons of Accounting for Uncertain Income Taxes which prescribes recognition thresholds that must be met before a tax p-0sition is recognized in the financial statements and provides guidance on de-recognition, classification, and interest and penalties. Cnder this guidance, an entity may only recognize or continue to recognize tax positions that meet a "more likely than not" threshold. At September 30, 2025, management has determined that the Company had no uncertain tax positions that would require financial statement recognition. This determination will always be subject to ongoing reevaluation as facts and circumstances may require. # **Note 3: NET CAPITAL REQUIREMENT** The Company is subject to the uniform net capital rule (Rulel Sc3• l) of the Securities and Exchange Commission, which requires both the maintenance Ofminimum net capital and the maintenance ora maximum ratio ofaggregate indebtedness to net capital. Net capital and aggregate indebtedness change day by day, but at September 30. 2025 the Company's net capital of\$25,772 exceeded the minimum net capital requirement of 6 2/3% of aggregate indebtedness or \$5,000, whichever is greater, by \$20,772, and the Company's ratio of aggregate indebtedness of \$ I 0,317 to net capital was 0.40: I, which is less than the 15: I maximum ratio requirement. #### **Note 4: RELATED PARTY TRANSACTIONS** During the fiscal year ended September 30, 2025, the Company has an expense sharing arrangement with its Parent company and incurred a monthly allocation of overhead costs. As of September 30, 2025, the intercornpany balance owed to the parent was \$1.888. This amount is included in due to parent company in the accompanying statement of financial condition. Total expenses incurred during the year ended September 30th. 2025 was \$7,056, which was recorded as lntercompany Expenses on the Statement of Income. {11}------------------------------------------------ Notes to Financial Statements September 30. 2025 #### **Note !5; LEASE OBLIGATIONS** Management has reviewed ASC 842 Lease Accounting and does not believe that it is applicable to the Company as it hag no formal lease agreements and no recorded rent expense for the year ended September *30,* 2025. #### **Note 6: COMMITMENTS AND CONTINGENCIES:** The Company was not subject to any litigation during the period October I", 2024, through September 30, 2025. #### **Note** 7: **SEGMENT REPORTING:** The Company Is engaged in a single line of business as a securities broker dealer, which is comprised of one class of service. The Company has identified its President 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. 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 dividends. The Company's operations constitute a single operating segment and therefore, a single reportable segment, because the CODM manages the business activities using infonnation from 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. #### **Note 8: SUBSEQUENT EVENTS** The management has reviewed the results of operalions for the period oftime ftom its year end September 30, 2025, through December 9. 2025, the date the financial statements were available to be issued and have determined that no adjustments are necessary to the amounts reported in the accompanying financial statements nor have any subsequent events occurred, the nature of which would require disclosure. There was a distribution in the amount of \$250,000 on October 30th, 2025 {12}------------------------------------------------ #### Schedule I Statement of Net Capital September 30. 2025 | | Focus 09/30/202.S | | Audit 09/30/202.S | Change | |-------------------------------------------------|-------------------|----|-------------------|--------| | Member's Equity, September 30, 2025 | \$
340,358 | \$ | 340,358 | | | Less: Non-allowable Assets | | | | | | Prepaid Expenses and Other Assets | 2,086 | | 2,086 | | | Accounts Receivable | 312,500 | | 312,500 | | | Temati~e net capital | 314,SS6 | | 3\4,5S6 | | | Haircuts: | | | | | | NET CAPITAL | 25,772 | | 25,772 | | | Minimum requirements of 6 2/3% of aggregate | | | | | | indebtedness or \$5,000, whichever is greater | 5,000 | | 5,000 | | | Excess net capital | \$
20,772 | \$ | 20,772 | | | Aggregate indebtedness | \$
J0,317 | \$ | 10,317 | | | R11tio of aggregate indebtedness to net capital | 0.40:1 | | 0.40:1 | | There are no differences between the Audit and FOCUS filed at September 30, 2025 {13}------------------------------------------------ September 30, 2025 #### **Schedule 11 Determination of Reserve Requirements Under Rule 1~-3 of the Securities and Exchange CommisMon** The Company is exempt from the Reserve Requirement computation as supported by footnote 74 to SEC Release 34-70073. # **Schedule Ill Information Relating to Possession or Control Requirements Under Rule 1Sc3-3** The Company is exempt from the Rule I Sc3-3 as it relates to Possession and Control requirements as supported by footnote 74 to SEC Release 34-70073. The accompanying notes are an integral part of these financial statements {14}------------------------------------------------ **BRIAN W. ANSON** *Certified Public Accountant* 18455 Burbank Blvd .. Suite 406, Tarzana, CA 91356 • Tel. (818) 636-5660 # **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** Board of Members CapConnect+EMarkcts. LLC Westlake Village, California I have reviewed management's statements, included in the accompanying SEC Rule 15c3-3 Exemption Report in which CapConncct+EMarkets, LLC, stated that CapConnect+EMarkets, LLC does not claim and exemption unver paragraph (k) of 17 C.F.R s, business activities are limited to participating in distributions of securities ( other than firm commitment underwritings) in accordance of paragraphs (a) or (b)(2) of Rule 15c2-4, and the Company did 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 Rule l 5c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not the Company); did not carry accounts of or for customers; and did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year ended September 30, 2025, without exception. CapConnect+EMarkets, LLC's management, is responsible for compliance and is not subject to the provisions set forth in Rule 15c3-3 under the Securities and Exchange Act of 1934 and its statements. My 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 CapConnect+EMarkets, LLC's declaration concerning the provisions set forth in Rule I 5c3-3 under the Securities Exchange Act of 1934. 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, I do not express such an opinion. Based on my review, I am not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based on the provisions set forth in Footnote 74 to SEC Release 34-70073. rian W. Anson Certified Public Accountant Tarzana, California December 9, 2025 {15}------------------------------------------------ # **Assertions Regarding Exemption Provisions** CapConnect+ Emarkets, LLC (the "Company") is a registered broker-dealer subject to Rule I 7a-5 promulgated by the Securities and Exchange Commission (17 C.F.R. §240. l 7a-5, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F .R. §240. l 7a-5(d)(l) and (4). To the best of its knowledge and belief, the Company states the following: - (I) The Company does not claim an exemption under paragraph (k) of 17 C.F .R. § 240. l 5c3-3, and - (2) The Company is filing this Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.l 7a-5 because the Company limits its business activities exclusively to participating in distributions of securities (other than firm commitment underwritings) in accordance with the requirements of paragraphs (a) or (6)(2) of Rule 15c2-4 and the Company did 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 (6)(2) of Rule 15c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company); did not carry accounts of or for customers; and did not carry PAB accounts (as defined in Rule l 5c3-3) throughout the most recent fiscal year without exception. Konstantinos Dafoulas Date 12/9/2025 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.