# Clear Street Derivatives LLC X-17A-5 (2026-04-13) — Broker-dealer annual report - Company: Clear Street Derivatives LLC - Form: X-17A-5 - Filed: 2026-04-13 - Period: 2025-12-31 - Accession: 0001983408-26-000004 - CIK: 1983408 - Material weakness: No - Auditor: Ernst & Young LLP - Auditor location: New York, NY - Contact: Dan Wenger - Phone: (646) 931-0315 - Signed by: Dan Wenger (CFO) Original filing: https://www.sec.gov/Archives/edgar/data/1983408/000198340826000004/CSD_SFC_Public.pdf --- {0}------------------------------------------------ # **Clear Street Derivatives LLC** SEC # 026-00231 **Statement of Financial Condition With Report of Independent Auditors December 31, 2025** **Filed as a PUBLIC report pursuant to SEC Rule 18a-7(d)** {1}------------------------------------------------ {2}------------------------------------------------ | Daniel Wenger | swear (or affirm) that, to the best of my knowledge and belief, the | |-------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------| | tinancial report pertaining to the firm of Clear Street Derivatives LLC | as of | | 12/31 | 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. | | | | | | | Signature; | | | | | | Title: | - - - - - - - - - - - - - - - - - - - - - - - - - - - {3}------------------------------------------------ # **Table of Contents** | | PAGE | |-------------------------------------------|------| | Report of Independent Auditors | 5 | | Statement of Financial Condition | 6 | | Notes to Statement of Financial Condition | 7 | {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) Ernst & Young, LLP One Manhattan West New York, NY 10001 Tel: +1 212 773 3000 ey.com #### **Report of Independent Auditors** Member and Board of Directors of Clear Street Derivatives LLC #### **Opinion** We have audited the statement of financial condition of Clear Street Derivatives LLC (the Company) as of December 31, 2025, and the related notes (the "financial statement"). In our opinion, the accompanying financial statement presents fairly, in all material respects, the financial position of the Company at December 31, 2025, in accordance with accounting principles generally accepted in the United States of America. #### **Basis for Opinion** We conducted our audit in accordance with auditing standards generally accepted in the United States of America (GAAS). Our responsibilities under those standards are further described in the Auditor's Responsibilities for the Audit of the Financial Statement section of our report. We are required to be independent of the Company and to meet our other ethical responsibilities in accordance with the relevant ethical requirements relating to our audit. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion. #### **Responsibilities of Management for the Financial Statement** Management is responsible for the preparation and fair presentation of the financial statement in accordance with accounting principles generally accepted in the United States of America, and for the design, implementation, and maintenance of internal control relevant to the preparation and fair presentation of the financial statement that is free of material misstatement, whether due to fraud or error. In preparing the financial statement, management is required to evaluate whether there are conditions or events, considered in the aggregate, that raise substantial doubt about the Company's ability to continue as a going concern for one year after the date that the financial statement is available to be issued. #### **Auditor's Responsibilities for the Audit of the Financial Statement** Our objectives are to obtain reasonable assurance about whether the financial statement as a whole is free of material misstatement, whether due to fraud or error, and to issue an auditor's report that includes our opinion. Reasonable assurance is a high level of assurance but is not absolute assurance and therefore is not a guarantee that an audit conducted in accordance with GAAS will always detect a material misstatement when it exists. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control. Misstatements are considered material if there is a substantial likelihood that, individually or in the aggregate, they would influence the judgment made by a reasonable user based on the financial statement. {5}------------------------------------------------ ![](_page_5_Picture_0.jpeg) In performing an audit in accordance with GAAS, we: - x Exercise professional judgment and maintain professional skepticism throughout the audit. - x Identify and assess the risks of material misstatement of the financial statement, whether due to fraud or error, and design and perform audit procedures responsive to those risks. Such procedures include examining, on a test basis, evidence regarding the amounts and disclosures in the financial statement. - x Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the Company's internal control. Accordingly, no such opinion is expressed. - x Evaluate the appropriateness of accounting policies used and the reasonableness of significant accounting estimates made by management, as well as evaluate the overall presentation of the financial statement. - x Conclude whether, in our judgment, there are conditions or events, considered in the aggregate, that raise substantial doubt about the Company's ability to continue as a going concern for a reasonable period of time. We are required to communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit, significant audit findings, and certain internal control-related matters that we identified during the audit. April 13, 2026 {6}------------------------------------------------ *(amounts in thousands)* | Assets | | |--------------------------------------------------------------|--------------| | Cash and cash equivalents | \$
42 | | Financial instruments owned, at fair value | 38,243 | | Receivable from broker-dealers and clearing organizations | 45,358 | | Other assets | 617 | | Total Assets | 84,260
\$ | | | | | Liabilities and Equity | | | Liabilities | | | Financial instruments sold, not yet purchased, at fair value | \$
32,280 | | Payable to customers | 12,382 | | Accounts payable and accrued liabilities | 808 | | Total liabilities | \$
45,470 | | | | | Equity | | | Member's equity | 38,790 | | Total Liabilities and Equity | 84,260
\$ | The accompanying notes are an integral part of this Statement of Financial Condition. {7}------------------------------------------------ # **1. Organization and Description of Business** Clear Street Derivatives LLC, (the "Company" or "CSD"), is a limited liability company organized in the state of Delaware. The Company's sole member is Clear Street Holdings LLC ("Holdings", "Parent"). The Company's operating agreement provides that the CEO has sole authority to carry out management responsibilities and control day-to-day management of the Company's operations, including distributions and admittance of new members. As a limited liability company, the members' liabilities are limited to amounts reflected in their capital accounts. The Company, founded in 2022 and headquartered in New York, is a security-based swap dealer registered with the U.S. Securities and Exchange Commission ("SEC"). The Company does not effect transactions in cleared securitybased swaps for or on behalf of customers. Accordingly, the Company claims an exemption from 17 C.F.R. § 240.18a-4 under the provisions of 17 C.F.R. § 240.18a-4(f). The Company provides security-based swap dealer counterparties exposure to securities via total return swap transactions by: (i) entering into short or long total return swap transactions with security-based swap dealer counterparties, and (ii) acquiring or selling the securities underlying each total return swap via open market transactions to fully hedge the Company's market risk and create a delta neutral position. The Company is engaged in a single line of business as a security-based swap dealer. The Company has identified its CEO as the chief operating decision maker ("CODM"), who uses net income to evaluate the results of the business to manage the Company. Additionally, the CODM uses excess net capital (see Note 7, Net Capital Requirements), which is not a measure of profit and loss, to make operational decisions while maintaining capital adequacy, such as whether to reinvest profits or make distributions. The Company's operations constitute a single operating segment and therefore, a single reportable segment, because the CODM manages the business activities using information of the Company as a whole. All revenues and expenses in the Statement of Income are considered significant revenues and expenses. 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. # **2. Significant Accounting Policies** # **Basis of Presentation** The accompanying Statement of Financial Condition has been prepared on the basis of accounting principles generally accepted in the United States of America ("U.S. GAAP") as set forth by the Financial Accounting Standards Board ("FASB") and its Accounting Standards Codification ("ASC") and Accounting Standards Updates ("ASU"). The Statement of Financial Condition is presented in U.S. dollars. # **Use of Estimates** The preparation of the Statement of Financial Condition in conformity with U.S. GAAP requires management to make estimates and assumptions that affect the reported amounts of certain types of assets and liabilities and disclosure of contingent assets and liabilities at the reporting date. Actual results may differ from estimated amounts. {8}------------------------------------------------ # **Recently Adopted Accounting Pronouncements** In July 2025, the FASB issued ASU No. 2025-05, Financial Instruments—Credit Losses (Topic 326): Measurement of Credit Losses for Accounts Receivable and Contract Assets ("ASU 2025-05"). ASU 2025-05, specific to current accounts receivable and current contract assts arising from transactions accounted for under Topic 606, Revenue from *Contracts with Customers*, provides a practical expedient to all entities when developing reasonable and supportable forecasts as part of estimating expected credit losses, to assume that current conditions as of the balance sheet date do not change for the remaining life of the asset. The amendment in the ASU is effective for annual and interim periods beginning after December 15, 2025. Early adoption is permitted. The Company early adopted ASU 2025-05 in its annual Statement of Financial Condition for the year ended December 31, 2025. The adoption did not have a material impact on the Company's Statement of Financial Condition and related disclosures. # **Cash and Cash Equivalents** The Company maintains cash in bank accounts that, at times, may exceed federally insured limits. The Company manages the risk by selecting financial institutions deemed highly creditworthy to minimize the risk. Cash equivalents are defined as highly liquid investments with original maturities of three months or less when purchased. At December 31, 2025, the Company had no cash equivalents. # **Receivable from and Payable to Customers** Amounts receivable from and amounts payable to Customers include the portions of cash collateral posted to and received from counterparties for security-based swaps transactions, which are not eligible for netting under ASC 815- 10-45, or where the cash collateral delivered/received exceeds the related derivative payable/receivable as of the date of the Statement of Financial Condition. At December 31, 2025, there were no Receivables from customers. # **Allowance for Credit Loss** Per ASU 2025-05, the Current Expected Credit Loss ("CECL") model requires the measurement of expected credit losses for financial assets measured at amortized cost, using relevant information about past events, including historical credit loss experience on financial assets with similar risk characteristics, current conditions, and reasonable and supportable forecasts that affect the collectability of the remaining cash flows over the contractual term of the financial assets. The overall estimate of the allowance for credit losses is based on both quantitative and qualitative considerations. The Company deemed the credit risk of organizations with which it entered into clearing agreements, relating to Receivables from broker-dealers and clearing organizations, to be immaterial, as the in-scope assets are de minimis. Therefore, the Company did not record an allowance for credit losses related to Receivables from Brokerdealers and clearing organizations as of December 31, 2025. # **Receivable from and Payable to Broker-Dealers and Clearing Organizations** Amounts receivable from broker-dealers and clearing organizations may be restricted to the extent they serve as deposits for securities sold, not yet purchased. At December 31, 2025, Receivable from broker-dealers and clearing organizations represented cash balances held at and margin debits due to prime brokers related to the Company's security-based swap dealer activity. At December 31, 2025 there were no Payables to broker-dealers and clearing {9}------------------------------------------------ organizations. # **Financial Instruments Owned and Financial Instruments Sold, Not Yet Purchased** Financial instruments owned and Financial instruments sold, not yet purchased, relate to the Company's securitybased swap activity, and include derivative assets and derivative liabilities related to open security-based swaps in listed equity securities, listed equity securities primarily entered into to hedge the market risk exposure related to open security-based swaps in listed equity securities entered into primarily for funding or hedging purposes. The Company records Financial instruments owned, including those pledged as collateral, and Financial instruments sold, not yet purchased, at fair value. # **Fair Value of Financial Instruments** Fair value is defined as the price that would be received to sell an asset or would be paid to transfer a liability (i.e., the exit price) in an orderly transaction between market participants at the measurement date. Fair value measurements are not adjusted for transaction costs. The recognition of discounts for large holdings (block discounts) of unrestricted financial instruments where quoted prices are readily and regularly available in an active market is prohibited. The Company categorizes its financial instruments into a three-level hierarchy which prioritizes the observable inputs to valuation techniques used to measure fair value. The hierarchy level assigned to each measurement is based on the assessment of the transparency and reliability of the inputs used in the valuation, based on lowest level of input that is significant to the fair value measurement. The hierarchy gives the highest priority to unadjusted quoted prices in active markets for identical assets or liabilities (Level 1 measurements) and the lowest priority to unobservable inputs (Level 3 measurements). Financial instruments measured and reported at fair value are classified and disclosed in one of the following categories based on inputs: Level 1: Unadjusted quoted prices in active markets that are accessible at the measurement date for identical assets or liabilities; Level 2: Quoted prices for similar assets and liabilities in an active market, quoted prices in markets that are not active or for which all significant inputs are observable, either directly or indirectly; Level 3: Prices or valuations that require inputs that are both significant to the fair value measurement and unobservable. In certain cases, the inputs used to measure the fair value may fall into different levels of the fair value hierarchy. When there is more than one input at different levels within the hierarchy, the fair value is determined based on the lowest level input that is significant to the fair value measurement in its entirety. Assessment of the significance of a particular input to the fair value measurement in its entirety, requires substantial judgment and consideration of factors specific to the asset or liability. Level 3 inputs are inherently difficult to estimate. Changes to these inputs can {10}------------------------------------------------ have a significant impact on fair value measurements. Transfers in or out of levels are recognized based on the beginning fair value of the period in which they occur. For the year ended December 31, 2025, there were no transfers into or out of level 3. #### **Derivative Instruments** Derivative instruments include derivative assets and derivative liabilities primarily relate to open security-based swaps in listed equities and equities that the Company enters into primarily for funding and hedging purposes. These derivative assets and derivative liabilities are carried at fair value and reported in Financial instruments owned and Financial instruments sold, not yet purchased on the Statement of Financial Condition. Refer to Note 4, Derivative Instruments, for further information related to the Company's derivative holdings. #### **Income Taxes** The Company is a single-member limited liability company and is treated as a disregarded entity for federal tax purposes and, as such, is not subject to income taxes in federal, state and local jurisdictions. Instead, income, deductions, and credits are passed through and included by its single member on its tax return. The Company has not elected to push down and allocate current and deferred tax expense from its Parent, therefore, no provision for income taxes is made in this Statement of Financial Condition. # **3. Fair Value** # **Financial Instruments Measured at Fair Value** The Company's financial instruments recorded at fair value have been categorized based upon a fair value hierarchy in accordance with accounting standards as described in Note 2, *Significant Accounting Policies - Fair Value of Financial Instruments*. Exchange-traded equity securities are measured at the quoted prices from the primary exchanges and are classified as Level 1 securities in the fair value hierarchy. Restricted equity securities and securities with quoted prices in markets that are not active are valued based on quoted prices from the primary exchanges and are classified as Level 2 securities in the fair value hierarchy if the unobservable inputs are significant to the fair value measurement in its entirety. Security-based swaps are valued based on inputs derived from the quoted prices of the underlying listed securities from the primary exchange and are classified as Level 2 financial instruments in the fair value hierarchy. Fair values for financial instruments other than those discussed above are estimated by the Company and are generally categorized as Level 2 or Level 3 in the fair value hierarchy. Fair value measurements for items measured at fair value on a recurring basis are summarized below at December 31, 2025 (in thousands): {11}------------------------------------------------ | | Level 1 | | Level 2 | Level 3 | | Total Fair Value | | |----------------------------------------------|---------|--------|-------------|---------|---|------------------|--------| | Assets | | | | | | | | | Equities | \$ | 36,054 | \$
- | \$ | | \$ | 36,054 | | Security-based swaps | | - | 2,189 | | - | | 2,189 | | Financial assets measured at fair value | \$ | 36,054 | \$
2,189 | \$ | - | \$ | 38,243 | | | | | | | | | | | Liabilities | | | | | | | | | Equities | \$ | 30,292 | \$
- | \$ | - | \$ | 30,292 | | Security-based swaps | | - | 1,988 | | - | | 1,988 | | Financial liabilities measured at fair value | \$ | 30,292 | \$
1,988 | \$ | - | \$ | 32,280 | # **Financial Instruments Not Measured at Fair Value** The table below presents the carrying value, fair value and fair value hierarchy category of certain financial instruments that are not measured at fair value on the Statement of Financial Condition. The table below excludes non-financial assets and liabilities. The carrying value of financial instruments not measured at fair value categorized in the fair value hierarchy as Level 1 and Level 2 approximates fair value due to the relatively short-term nature of the underlying assets. The table below summarizes financial assets and liabilities not carried at fair value at December 31, 2025 (in thousands). | | Carrying
Value | Fair Value | Level 1 | Level 2 | Level 3 | |--------------------------------------------------------------|-------------------|--------------|----------|--------------|---------| | Assets | | | | | | | Cash and cash equivalents | \$
42 | \$
42 | \$
42 | \$
- | \$
- | | Receivable from broker-dealers and clearing
organizations | 45,358 | 45,358 | - | 45,358 | - | | Other assets | 105 | 105 | - | 105 | - | | Total financial assets | \$
45,505 | \$
45,505 | \$
42 | \$
45,463 | \$
- | | Liabilities | | | | | | | Payable to customers | 12,382 | 12,382 | - | 12,382 | - | | Accounts payable and accrued liabilities | 809 | 809 | - | 809 | - | | Total financial liabilities | \$
13,191 | \$
13,191 | \$
- | \$
13,191 | \$
- | In addition, the Company held Bitcoin with a fair value of \$0.5 million, which is recorded in Other assets on the Statement of Financial Condition. This Bitcoin was held to hedge a swap contract with a counterparty. # **4. Derivative Instruments** The Company does not have any derivative instruments designated as hedging instruments under ASC 815, Derivatives and Hedging ("ASC 815"). The gross fair value of the Company's derivative instruments on a gross basis consisted of the following derivative assets and derivative liabilities at December 31, 2025 (in thousands): {12}------------------------------------------------ | | Financial Statement Caption | Fair Value | | | Notional
Value | | | |-------------------------|--------------------------------------------------------------|------------|-------|----|-------------------|--|--| | Derivative Assets | | | | | | | | | Security-based
swaps | Financial instruments owned, at fair value | \$ | 2,189 | \$ | 27,542 | | | | Derivative Liabilities | | | | | | | | | Security-based
swaps | Financial instruments sold, not yet purchased, at fair value | \$ | 1,988 | \$ | 29,246 | | | The Company believes that the notional amounts of derivative contracts generally overstate its exposure. In most circumstances, notional amounts are used only as a reference point from which to calculate amounts owed between the parties to the contract. Furthermore, notional amounts do not reflect the benefit of master netting and collateral agreements or risk mitigating transactions. # *Offsetting of Derivatives* The Company enters into master netting and collateral agreements with all of its security-based swap counterparties. Where legally enforceable, these master netting and collateral agreements give the Company, in the event of default by the counterparty, the right to offset receivables, including cash collateral received, and payables with the same counterparty. At December 31, 2025, the Company had the following derivative assets and derivative liabilities under master netting and collateral agreements (in thousands): | | | | | | | Amounts not offset in the
statement of financial
condition (2) | | | | | | |------------------------|-----------------------------------------------------------|----|--------------------------------------------------------------|----|--------------------------|----------------------------------------------------------------------|-------------------------|--------------------|-------|---------------|---| | | Gross amounts of
recognized assets/
liabilities (1) | | Amounts offset in the
statement of financial
condition | | Net amounts
presented | | Counterparty
netting | Cash
collateral | | Net
amount | | | Derivative assets | | | | | | | | | | | | | Security-based swaps | \$
2,189 | \$ | - | \$ | 2,189 | \$ | - | \$ | 2,189 | \$ | - | | | | | | | | | | | | | | | Derivative liabilities | | | | | | | | | | | | | Security-based swaps | \$
1,988 | \$ | - | \$ | 1,988 | \$ | - | \$ | 1,988 | \$ | - | (1) Includes all gross balances related to securities-based swaps balances irrespective of whether they are transacted under legally enforceable master netting and collateral agreements or whether the Company has obtained sufficient evidence of enforceability of the master netting and collateral agreement. At December 31, 2025, the gross balance of derivative assets and derivative liabilities which are documented under master netting and collateral agreements for which the Company has not yet obtained sufficient evidence of legal enforceability was \$2.2 million and \$2.0 million, respectively. (2) Amounts relate to master netting and collateral agreements which are not permitted to be offset on the face of the Statement of Financial Condition in accordance with ASC 210-20, *Balance Sheet Offsetting*, and ASC 815, *Derivatives and Hedging*, but which provide the Company with the legal right to offset in the event of default. # **5. Risks and Uncertainties** {13}------------------------------------------------ The Company's activities expose it to a number of financial risks, including market risk and credit risk. The Company seeks to manage its financial risks using various mitigating controls. # **Market Risk** The Company is exposed to various market risks. Exposures to market risks arise primarily from equity price risk and changes in interest rates. # *Equity Price Risk* It is the Company's policy to mitigate its market risk exposure on security-based swaps through the purchase or sale of the corresponding underlying securities. As a result, the Company is not exposed to material market risk on its security-based swaps, other than the potential operational or trading errors that may occur. The Company monitors its exposures daily to ensure that open positions remain appropriately hedged. # **Credit Risk** The Company engages in security-based swaps dealer activities servicing a diverse client group, primarily hedge funds and other financial institutions based in the U.S. The Company's exposure to credit risk associated with the non-performance of these counterparties in fulfilling their contractual obligations pursuant to security-based swaps transactions can be directly impacted by volatile securities markets or regulatory changes, which may impair the counterparties' ability to satisfy its obligation to the Company. If parties to the financial instruments that make up the concentration failed completely to perform according to the terms of the contracts and the collateral or other security, if any, for the amount due proved to be of no value to the entity, the maximum amount of loss due to credit risk is approximately the same as the total carrying amount of the financial instruments. The credit risk team, an independent function of the Company, is tasked with minimizing credit risk from the Company's activities. The Company's process for managing credit risk includes the evaluation of the likelihood that a counterparty defaults on its payments and obligations; assignment of internal credit ratings to all active counterparties; approval of extensions of credit and establishment of credit limits; measurement, monitoring and management of the Company's current and potential future credit exposures; setting credit terms in legal documentation including margin terms; use of appropriate credit risk mitigants including netting; collateral and hedging; and active communication and co-operation with various stakeholders such as Trading units, Operations, Legal, Compliance and Finance. # **Off-Balance Sheet Risk** In the ordinary course of business, the Company purchases and sells securities and derivative financial instruments. If a party to a transaction fails to fulfill its contractual obligations, the Company may incur a loss if the market value of the security is different from the contract amount of the transaction. The majority of the Company's transactions with off-balance sheet risk are short-term in duration. # **Litigation** The nature of the Company's business subjects it to claims, lawsuits and regulatory examinations and other proceedings in the ordinary course of business. At December 31, 2025, there were no unasserted claims or assessments that management is aware of or legal counsel has advised are probable of assertion and which must {14}------------------------------------------------ be disclosed. In the opinion of management, the ultimate outcome of all matters will not have a material impact on the Company's financial condition. # **6. Related Party Transactions** The Company may engage in transactions in the ordinary course of business with related parties. The Company incurs expenses paid for by Holdings, on behalf of itself and its affiliates, under an intercompany expense sharing agreement which provides for the allocation of compensation, technology, and administrative expenses related to shared and support services based on actual usage. In addition, Clear Street Management LLC ("CS Management"), until October 1, 2025 a member of Holdings and afterwards a subsidiary of it), acts as the paying agent for any direct expenses incurred by the Company. At December 31, 2025, the Company had a \$0.2 million payable to CS Management which is included in Accounts payable and accrued liabilities on the Statement of Financial Condition. The Company clears its business through Clear Street LLC ("CS LLC"), an affiliate under common control, on a fully disclosed basis. At December 31, 2025, the Company had a \$45.1 million receivable from CS LLC which is included in Receivable from broker-dealers and clearing organizations on the Statement of Financial Condition. In April 2025, the Company novated a majority of its security-based swaps positions to CS LLC. The novation included a transfer \$163.5 million of consideration paid from CS LLC to the Company for net fair value of swap and equity hedge positions, and \$2,125.6 million of the related collateral. The swaps transferred had a notional amount of \$5,713.0 million. There was no gain or loss recognized from the novation. # **7. Net Capital Requirements** The Company is subject to the SEC Uniform Net Capital Rule ("Securities Exchange Act of 1934 Rule 18a-1" or "SEC Rule 18a-1"), which requires the maintenance of minimum net capital. The Company is required to maintain a minimum net capital (as defined in SEC Rule 18a-1) equal to the greater of \$20.0 million or two percent of the risk margin amount (as defined in "SEC Rule 18a-1"). These regulations also prohibit a security-based swap dealer from paying cash dividends, making loans to its parent, affiliates or employees, or otherwise entering into transactions, which, if executed, would result in a reduction of its total net capital to less than 120% of its minimum required capital. Moreover, security-based swap dealers are required to notify the SEC prior to paying cash dividends, making loans to its parent, affiliates or employees, or otherwise entering into transactions, which, if executed, would result in a reduction of 30% or more of its excess net capital (net capital less the minimum requirement). The SEC has the ability to prohibit or restrict such transactions if the result is detrimental to the integrity of the security-based swap dealer. At December 31, 2025, the Company had net capital of \$32.7 million which was \$12.7 million in excess of its required net capital of \$20.0 million. # **8. Subsequent Events** The Company has evaluated its subsequent events disclosures through April 13, 2026, the date that the Company's Statement of Financial Condition were issued and has determined that there have been no events that would have a material impact on this Statement of Financial Condition as of December 31, 2025. Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.