# RONDEIVU SECURITIES, LLC X-17A-5 (2026-03-04) — Broker-dealer annual report - Company: RONDEIVU SECURITIES, LLC - Form: X-17A-5 - Filed: 2026-03-04 - Period: 2025-12-31 - Accession: 0001929957-26-000001 - CIK: 1929957 - File #: 8-70931 - Type: Broker-dealer - Material weakness: No - Auditor: Cropper Accountancy Corp. - Auditor location: Walnut Creek, CA - Contact: David Brant - Phone: 4022151352 - Email: brant@acaglobal.com - Website: acaglobal.com - Signed by: Michael Ashmore (CEO) Original filing: https://www.sec.gov/Archives/edgar/data/1929957/000192995726000001/fullfs25.pdf --- {0}------------------------------------------------ **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 # **ANNUAL REPORTS FORM X-17A-S PART Ill** SEC FILE NUMBER 8-70676 **FACING PAGE** | FILING FOR THE PERIOD BEGINNING | ________
1/1/2025
AND ENDING | | | _______
12/31/2025
_ | |-------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------|-----------------------------------------|-----------------|--------------------------------------------| | | MM/DD/YY | | | MM/DD/YY | | | A. REGISTRANT IDENTIFICATION | | | | | NAME OF FIRM: Rondeivu Securities LLC | | | | | | TYPE OF REGISTRANT (check all applicable boxes):
ii!!i Broker-dealer
□ Security-based swap dealer
D Check here if respondent is also an OTC derivatives dealer | | □ Major security-based swap participant | | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) | | | | | | 354 Pequot Avenue | | | | | | | (No. and Street) | | | | | Southport | CT | | | 06890 | | (City) | (State) | | | (Zip Code) | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | | | David Brant | (402) 215-1352 | | | david .brant@acaglobal.com | | (Name) | (Area Code -Telephone Number) | | (Email Address) | | | | B. ACCOUNTANT IDENTIFICATION | | | | | INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing* | | | | | | Cropper Accountancy Corporation | | | | | | | (Name - if individual, state last, first, and middle name) | | | | | 2700 Ygnacio Valley Road, Suite 270 | Walnut Creek | | CA | 94598 | | (Address) | (City) | | (State) | (Zip Code) | | 03/04/2009 | | 3381 | | | | | | | | (PCAOB Reg;,tcat;oo N,mbec, • applkable) I | | | FOR OFFICIAL USE ONLY | | | | | | | | | | 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, Michael Ashmore swear (or affirm) that, to the best of my knowledge and belief, the financial report pertaining to the firm of Rondeivu Securities LLC as of December 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. Signature: 1/{;k~ Title: CEO #### Notary Public #### **This filing\*\* contains (check all applicable boxes):** - Ill (a) Statement of financial condition. - □ (b) Notes to consolidated statement of financial condition. - Ill (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. - □ (f) Statement of changes in liabilities subordinated to claims of creditors. - @ (g) Notes to consolidated financial statements. - Ill (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. - Ill (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. - Ill (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. - Ill (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. - @ (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. - Ill (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - D (t) Independent public accountant's report based on an examination of the statement of financial condition. - @ (u) Independent public accountant's report based on an examination of the financial report or financial statements under 17 CFR 240.17a-5, 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. - @ (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-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 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}------------------------------------------------ # FINANCIAL STATEMENTS For the Year Ended December 31 , 2025 {3}------------------------------------------------ # FINANCIAL STATEMENTS DECEMBER 31, 2025 # TABLE OF CONTENTS # Report oflndependent Registered Public Accounting Firm ............................................................................ 2 Statement of Financial Condition ..................................................................................................................... 3 Statement of Operations .................................................................................................................................... 4 Statement of Changes in Member's Equity ...................................................................................................... 5 Statement of Cash Flows ................................................................................................................................... 6 Notes to Financial Statements ........................................................................................................................ 7-10 Supplemental Schedules ................................................................................................................................. 11 Schedule I - Computation ofNet Capital Pursuant to SEA Rule 15c3-1 .................................................. 12 Schedule II - Statement Pursuant to SEA Rule 15c3-3 .............................................................................. 13 Review Report oflndependent Registered Public Accounting Firm ........................................................ 14 Exemption Report Regarding SEA Rule 17a-5(d)(4) ................................................................................ 15 {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) ## REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Member ofRondeivu Securities, LLC #### **Opinion on the Financial Statements** We have audited the accompanying statement of financial condition of Rondeivu Securities, LLC as of December 31, 2025, the related statements of operations, changes in member's equity, and cash flows for the year then ended, and the related notes and schedules ( collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position ofRondeivu Securities, LLC as of December 31, 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 ofRondeivu Securities, LLC's management. Our responsibility is to express an opinion on Rondeivu Securities, LLC'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 Rondeivu Securities, 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. 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. #### **Auditor's Report on Supplemental Information** The supplemental information contained in Schedule I - Computation of Net Capital Under Rule 15c3-l of the Securities and Exchange Commission and Schedule II - Computation for Determination of Reserve Requirements and Information Relating to Possession or Control Requirements for Brokers and Dealers Pursuant to Rule 15c3-3 has been subjected to audit procedures performed in conjunction with the audit of Rondeivu Securities, LLC's financial statements. The supplemental information is the responsibility of Rondeivu Securities, LLC'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. l 7a-5. In our opinion, the supplemental information is fairly stated, in all material respects, in relation to the financial statements as a whole. ~ c~ c~d: We have served as Rondeivu Securities, LLC's auditor, since 2024. Walnut Creek, California February 26, 2026 {5}------------------------------------------------ ## STATEMENT OF FINANCIAL CONDITION ## DECEMBER 31 , 2025 | ASSETS | | |---------------------------------------------------------------------------------------|----------------------------------| | Cash and cash equivalents
Accounts receivable
Prepaid expenses and other assets | \$
80,259
297,525
4,208 | | Total assets | \$ 381 992 | | LIABILITIES AND STOCKHOLDER'S EQUITY | | | LIABILITIES | | | Accounts payable and accrued expenses | \$ 47,572 | | Total liabilities | 47,572 | | MEMBER'S EQUITY | | | Member's equity | 334,420 | | Total member's equity | 334,420 | | Total liabilities and member's equity | \$ 381 992 | {6}------------------------------------------------ #### STATEMENT OF OPERATIONS #### For the Year Ended December 31 , 2025 | Revenue: | | |--------------------------|-------------| | Placement success fees | \$406,421 | | Platform access fees | \$89,276 | | Total revenue | 495 697 | | Operating expenses: | | | Salaries and benefits | 168,601 | | Professional fees | 77,239 | | Travel & entertainment | 6,547 | | Occupancy | 5,250 | | Regulatory fees | 4,358 | | Other expenses | 2,149 | | Total operating expenses | 264,144 | | Net operating loss | 231
,553 | | Bad debt recovery | 50,000 | | Net income | \$281 553 | {7}------------------------------------------------ #### STATEMENT OF CHANGES IN MEMBER'S EQUITY For the Year Ended December 31 , 2025 | Equity on January 1, 2025 | \$
38,908 | |--------------------------------|---------------| | Additions | 35,809 | | Distributions | (21
,850) | | Net income | 281
,553 | | Equity on Deember 31
, 2025 | \$
334,420 | {8}------------------------------------------------ #### STATEMENT OF CASH FLOWS #### For the Year Ended December 31 , 2025 | Cash flows from operating activities: | | |---------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------| | Net income | \$281
,553 | | Adjustments to reconcile net income to net cash flows from operating activities: | | | Changes in operating assets and liabilities:
Accounts receivable
Prepaid expenses and other assets
Accounts payable and accrued expenses | (297,525)
(652)
36,335 | | Net cash flows from operating activities | 19 711 | | Financing Activities | | | Member contributions | 35,809 | | Member distributions | (21,850) | | Net cash provided by financing activities | 13,959 | | Net increase in cash and cash equivalents | 33,670 | | Cash and cash equivalents at beginning of year | 46 589 | | Cash and cash equivalents at end of year | \$ 80 259 | | | | | Supplemental information | | | Cash paid for taxes | -0- | | Cash paid for interest | -0- | |------------------------|-----| {9}------------------------------------------------ # **1.** Nature of Activities Rondeivu Securities LLC (the "Company") is a broker-dealer and registered with the Securities and Exchange Commission ("SEC") and is a member of the Financial Industry Regulatory Authority ("FINRA") on April 4, 2023. The Company was organized under the laws of the State of Connecticut on March 18, 2022. The Company is 100% owned by Rondeivu Inc. ( the 'Parent'), and operates in Southport, Connecticut. As a securities broker-dealer, the Company provides services related to the private placements of securities for customers. # **2.** Summary of Significant Accounting Policies # *Basis of Accounting* The financial statements have been prepared on the accrual basis in accordance with accounting principles generally accepted in the United States of America ("GAAP"). # *Use of Estimates* The preparation of financial statements in accordance with accounting principles generally accepted in the United States of America requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates and may have an impact on future periods. # *Fair Value of Financial Instruments* Unless otherwise indicated, the fair values of all reported assets and liabilities that represent financial instruments approximate the carrying values of such amounts. The Company has no financial instruments required to be reported at fair value on a recurring basis. # *Cash and Cash Equivalents* The Company considers all demand deposits held in banks and certain highly liquid investments with original maturities of three months or less, other than those held for sale in the ordinary course of business, to be cash equivalents. For the year ending December 31 , 2025, the Company has no investments in securities. At December 31 , 2025, the Company's cash did not exceed the Federal Deposit Insurance Company's limit of \$250,000.00 per financial institution. {10}------------------------------------------------ # 2. Summary of Significant Accounting Policies (Continued) ## *Accounts Receivable* Accounts receivable represents amounts that have been earned and billed to clients in accordance with the terms of the Company's engagement letters with respective clients that have not yet been collected. # *Income Taxes* The Company, a limited liability company, is taxed as a partnership under the Internal Revenue Code and a similar state statute. In lieu of income taxes, the Company passes 100% of its taxable income and expenses to the Parent. Therefore, no provision or liability for federal or state income taxes is included in these financial statements. The Company is subject to examinations by major tax jurisdictions since inception. ## *Segment Reporting* The Company adopted Accounting Standards Update (ASU) 2023-7, Disclosure of Financial Information for a Single Segment Entity. Under this guidance, the Company is required to disclose specific financial information for its single reportable segment. The Company operates as a single reportable segment, focusing on broker dealer activities, mainly trading registered and unregistered securities. All material financial information, including revenue, expenses, and assets, is reviewed and managed by the Company's Chief Operating Decision Maker (CODM). The Company has identified the Chief Executive Officer as the CODM. As a result of operating as a single segment entity, the Company's financial statements reflect its overall performance without disaggregation into multiple segments. The accounting policies used to measure the profit and loss of the segment are the same as those described in the policies listed in this report. ## 3. Revenue from Contracts with Customers The Company recognizes revenue under ASC Topic 606, Revenue from Contracts with Customers Revenue is recognized when the Company satisfies its performance obligations by providing services to customers, in an amount that reflects the consideration to which the Company expects to be entitled in exchange for those services. The Company's revenue is currently derived from two primary streams: Platform Access Fees and Placement Success Fees. {11}------------------------------------------------ # 3. Revenue from Contracts with Customers (Continued) # *Platform Access Fees* The Company provides customers with ongoing access to its proprietary technology platform, which facilitates private market deal and portfolio workflow management. The performance obligation is satisfied over time, as customers simultaneously receive and consume the benefits of platform access throughout the contractual term. Revenue is recognized ratably over the term of the agreement using a time-elapsed measure of progress (daily recognition, billed monthly or quarterly). Fees are typically structured as either (i) a fixed monthly retainer or (ii) a quarterly fee calculated as the higher of a specified percentage of committed capital or net asset value. # *Placement Success Fees* The Company earns placement fees for successfully arranging investments into alternative investment funds. The Company has identified a single performance obligation, to successfully introduce and place an investor into a fund. This performance obligation is satisfied at a point in time, specifically upon the investor's acceptance by the fund and execution of the related subscription agreement, which represents the point at which the Company has fulfilled its obligation and has an enforceable right to consideration. While the performance obligation is met at the point of closing, the actual recognition of revenue may be subject to the resolution of variable consideration (e.g., amounts contingent upon final capital funding or fund-level fee realization). Variable consideration is included in the transaction price only to the extent that it is probable that a significant reversal of cumulative revenue recognized will not occur. Fees are generally structured as either (i) a fixed percentage of investor capital committed or (ii) a percentage of fund-level fees. # *Contract Balances* Income is recognized upon completion of the related performance obligation and when an unconditional right to payment exists. The timing of revenue recognition may differ from the timing of customer payments. A receivable is recognized when a performance obligation is met prior to receiving payment by the customer. Receivables related to revenue from contracts with customers totaled \$0 and \$297,525 as of December 31 , 2024 and December 31 , 2025, respectively. Alternatively, fees received or billed prior to the completion of the performance obligation are recorded as deferred revenue on the statement of financial condition until such time when the performance obligation is met. Deferred revenue would primarily relate to commissions earned for capital raised for private placements on a best-efforts basis. Deferred revenue was \$0 and \$0 as of December 31 , 2024, and December 31 , 2025, respectively. During the year ended December 31 , 2025, the Company recovered \$50,000 of fees that had been writtenoff as uncollectable in a prior year. {12}------------------------------------------------ # 4. Related Party Transactions The Company has an expense sharing agreement with the Parent that requires the Company to be responsible for reimbursement to the Parent for any expenses that were a direct obligation of the broker-dealer. Under this agreement the Parent also provides administrative services, office facilities and salaries for persons associated with the Broker-Dealer who are employees of the Parent. For the year ended December 31 , 2025, a total of \$183,825 in expenses were reimbursed by the Broker Dealer to the Parent. During 2025, the Parent and Company agreed to convert payables due to the Parent from the Company to additional paid-in-capital in lieu of repayment and the Company distributed profits to the Parent. Total debt forgiveness capital contributions during the year ended December 31 , 2025 was \$35,809. The total profits distributed to the Parent for the year ended December 31 , 2025 was \$21 ,850. Expenses were recorded on the Statement of Operations. The Company's results of operations and financial position could differ significantly from those that would have been obtained if the entities were autonomous. # 5. Net Capital Requirements The Company is subject to the Uniform Net Capital Rule (Rule 15c3-1) under the Securities Exchange Act of 1934, the Company is required to maintain net capital of not less that \$5,000 and a ratio of aggregate indebtedness to net capital not exceeding 15 to 1. As of December 31 , 2025, the Company's net capital was \$32,687, excess net capital was \$27,687, and the ratio of aggregate indebtedness to net capital was 1.46. ## 6. Subsequent Events The Company has evaluated all subsequent events through the date the financial statements were available for issuance and has determined there were no additional material subsequent events to disclose or recogmze. # 7. Commitments and Contingencies As of December 31 , 2025, the Company had no material commitments or contingencies to report. {13}------------------------------------------------ SUPPLEMENTAL SCHEDULES {14}------------------------------------------------ # **SCHEDULE I** ## **RONDEIVU SECURITIES, LLC** ## COMPUTATION OF NET CAPITAL PURSUANT TO RULE 15c3-1 ## December 31 , 2025 | Total member's equity from statement of financial condition | \$ 334,420 | |-----------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------| | Less non-allowable assets from statement of financial condition
Accounts receivable
Prepaid Expenses and other assets
Total non-allowable assets | 297,525
4,208
301
,733 | | Net capital | 32,687
\$ | | Aggregate indebtedness
Total A.I. liabilities from statement of financial condition | 47,572
\$ | | Minimum net capital required ( 6.67% of aggregate indebtedness) | 3,171 | | Minimum dollar net capital requirement of reporting broker or dealer | 5,000 | | Net capital requirement (greater of minimum percent or dollar requirement) | 5 000
\$ | | Excess net capital | \$ 27 687 | | Percentage of aggregate indebtedness to net capital | 146% | There are no material differences between the computation of net capital presented above and the computation of net capital reported in the Company's amended Form X-17 A-5 as of December 31 , 2025. See Report oflndependent Registered Public Accounting Firm {15}------------------------------------------------ # **SCHEDULE** II # SCHEDULE II- STATEMENT PURSUANT to SEA RULE 15c3-3 # **Statement of Exemption From the Computation for Determination of Reserve Requirements and Information Relating to Possession or Control Requirements Under Rule 15c3-3 of The Securities and Exchange Commission as of December 31, 2025** The Company engages in the private placement of securities. The Company does not accept customer funds or securities and will not have possession of any customer funds or securities in connection with these activities. Therefore, in reliance on Footnote 74 to SEC Release 34-70073 and as discussed in Q & A 8 of the related FAQ issued by SEC staff, the firm will not claim an exemption from SEA Rule 15c3-3 as it does not affect transactions for anyone defined as a customer under Rule 15c3-3, and there are no items to report under the requirements of this Rule. See Report oflndependent Registered Public Accounting Firm {16}------------------------------------------------ ![](_page_16_Picture_0.jpeg) 2700 Ygnacio Valley Road, Ste 270 Walnut Creek, CA 94598 (925) 932-3860 tel (925) 4 76-9930 efax www. cropperaccountancy, com # REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Member ofRondeivu Securities, LLC We have reviewed management's statements, included in the accompanying Exemption Report, in which (I) Rondeivu Securities, LLC (the Company) did not claim an exemption under paragraph (k) of 17 C.F.R. §240.15c3-3, and (II) 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: private placements of securities, and providing platform access, 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. Rondeivu Securities, LLC's management is responsible for compliance with Footnote 74 of the SEC Release No. 34-70073 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 Rondeivu Securities, LLC's compliance with Footnote 74 of the SEC Release No. 34- 70073. 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 upon the Company's business activities contemplated by Footnote 74 of the SEC Release No. 34-70073. CROPPER ACCOUNTANCY CORPORATION Walnut Creek, California February 26, 2026 {17}------------------------------------------------ # **Rondeivu Securities LLC** EXEMPTION REPORT December 31, 2025 Rondeivu Securities 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: - I. The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240. 15c3-3, and - II. 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: private placements of securities 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, **Michael Ashmore,** swear and affirm that, to the best knowledge and belief, this Exemption Report is true and correct. CEO, Rondeivu Securities LLC January 23, 2026 ■ Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.