# WILTON RE DISTRIBUTORS LLC X-17A-5 (2026-03-06) — Broker-dealer annual report

- Company: WILTON RE DISTRIBUTORS LLC
- Form: X-17A-5
- Filed: 2026-03-06
- Period: 2025-12-31
- Accession: 0001993021-26-000001
- CIK: 1993021
- File #: 8-71151
- Type: Broker-dealer
- Material weakness: No
- Auditor: Exempt from Audit Requirement
- Auditor location: NA, IA
- Contact: Karen Carpenter
- Phone: 3192704410
- Email: smoser@wiltonre.com
- Website: wiltonre.com
- Signed by: Karen Carpenter (CEO)

Original filing: https://www.sec.gov/Archives/edgar/data/1993021/000199302126000001/Distributors2025.pdf

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8-71151

|                             | 1/1/2025            |     | 12/31/2025 |                     |
|-----------------------------|---------------------|-----|------------|---------------------|
|                             |                     |     |            |                     |
|                             |                     |     |            |                     |
| WILTON                      | RE<br>DISTRIBUTORS  | LLC |            |                     |
| ■                           |                     |     |            |                     |
|                             |                     |     |            |                     |
| 4840<br>N.<br>RIVER<br>BLVD | NE,<br>Suite<br>400 |     |            |                     |
|                             |                     |     |            |                     |
| Cedar<br>Rapids             | IA                  |     |            | 52411               |
|                             |                     |     |            |                     |
|                             |                     |     |            |                     |
| Shawn<br>Moser              | 319-491-8380        |     |            | smoser@wiltonre.com |
|                             |                     |     |            |                     |
|                             |                     |     |            |                     |
|                             |                     |     |            |                     |
|                             |                     |     |            |                     |
|                             |                     |     |            |                     |
|                             |                     |     |            |                     |
|                             |                     |     |            |                     |
|                             |                     |     |            |                     |

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### OATH OR AFFIRMATION

| Karen Carpenter                                                       | , swear (or affirm) that, to the best of my knowledge and belief, the |
|-----------------------------------------------------------------------|-----------------------------------------------------------------------|
| financial report pertaining to the firm of Wilton Re Distributors LLC | as of                                                                 |

December 31 1 m = 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 proprietary interest in any account classified solely as that of a customer.

Signature Title: CEO

### This filing \*\* contains (check all applicable boxes):

- (a) Statement of financial condition.
- [ (b) Notes to consolidated statement of financial condition.
- @ (c) Statement of income (loss) or, if there is other comprehensive 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.
- (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-1, as applicable.
- [ (i) Computation of tangible net worth under 17 CFR 240.18a-2.
- [j) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3.
- [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.
- [1) Computation for Determination of PAB Requirements under Exhibit A to § 240.15c3-3.
- (m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3.
- [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.
- @ (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capible net worth under 17 CFR 240.15c3-1, 17 CFR 240.18a-2, 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.
- [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.
- [ (r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- [ (t) Independent public accountant's report based on an examination of the statement of financial condition.
- [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.
- [ (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.
- [ [x] Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-1e or 17 CFR 240.17a-12, as applicable.
- [] (y) Report describing any material inadequacies found to have existed since the date of the previous audit, or a statement that no material inadequacies exist, under 17 CFR 240.17a-12(k).
- O (z) Other:
- \*\* To request confidential treatment of certain portions of this filing, see 17 CFR 240.17a-5(c)(3) or 17 CFR 240.180-7(d)(2), as applicable.

{2}------------------------------------------------

# Wilton Re Distributors LLC (SEC I.D. 8-71151)

Financial Statements and Supplemental Schedules as of and for the Year Ended December 31, 2025, and for the Period Ended December 31, 2024.

Filed pursuant to Rule 17a-5(e)(3) under the Securities Exchange Act of 1934 as a PUBLIC DOCUMENT.

{3}------------------------------------------------

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| G4<?C8>=(4?>AC                                                                                                                                                                                                                                           |      |

{4}------------------------------------------------

## Duly Authorized Officer Affirmation Pursuant to Rule 17a-5 under the Securities Exchange Act of 1934 December 31, 2025

Wilton Re Distributors 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"). Pursuant to 17 C.F.R. § 240.17a-5(e)(1)(ii), I affirm that, to the best of my knowledge and belief, the Company is exempt from the requirement to engage an independent public accountant to provide the reports required under 17 C.F.R. § 240.17a-5(d)(1)(i)(C) because, during the year ended December 31, 2025:

- 1. The securities business of the Company was limited to acting as broker (agent) for a single issuer in soliciting subscriptions for securities of that issuer; and,
- 2. The Company promptly transmitted to the issuer all funds and promptly delivered to the subscriber all securities received in connection with the transaction, and the Company did not otherwise hold funds or securities for or owe money or securities to customers.

Dated: May ( In 2026 Karen Carpenter Title: CEO Notary Public

![](_page_4_Picture_5.jpeg)

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{6}------------------------------------------------

## STATEMENTS OF INCOME (LOSS)

FOR THE YEAR ENDED DECEMBER 31, 2025 AND FOR THE PERIOD FROM AUGUST 22, 2024 TO DECEMBER 31, 2024 (Expressed in thousands of US dollars)

|                              | 2025 |       |    | 2024   |
|------------------------------|------|-------|----|--------|
| Revenues                     |      |       |    |        |
| Commission revenue           | \$   | 548   | S  | 167    |
| Other revenue                |      | 1,471 |    | 166    |
| Total revenues               |      | 2,019 |    | 333    |
| General expenses             |      |       |    |        |
| Commission expense           | \$   | 548   | \$ | 167    |
| General expenses - allocated |      | 1,336 |    | ર્દે ર |
| General expenses - direct    |      | 135   |    | 111    |
| Total general expenses       |      | 2,019 |    | 333    |
| Income tax expense           |      |       |    |        |
| Net income                   | S    |       | S  |        |

The accompanying notes are an integral part of these financial statements.

{7}------------------------------------------------

## STATEMENTS OF CHANGES IN MEMBER'S EQUITY

FOR THE YEAR ENDED DECEMBER 31, 2025 AND FOR THE PERIOD FROM AUGUST 22, 2024 TO DECEMBER 31, 2024

(Expressed in thousands of US dollars)

|                                                | 2025 |           | 2024 |
|------------------------------------------------|------|-----------|------|
| Member's equity                                |      |           |      |
| Member's equity at the beginning of the period | S    | 650<br>રે | 650  |
| Contributions from member                      |      | 500       |      |
| Total member's equity                          |      | 1,150 \$  | 650  |

The accompanying notes are an integral part of these financial statements.

{8}------------------------------------------------

## STATEMENTS OF CASH FLOWS

FOR THE YEAR ENDED DECEMBER 31, 2025 AND FOR THE PERIOD FROM AUGUST 22, 2024 TO DECEMBER 31, 2024 (Expressed in thousands of US dollars)

|                                                                            | 2025        | 2024          |
|----------------------------------------------------------------------------|-------------|---------------|
| Cash flows from operating activities                                       |             |               |
| Net income                                                                 | \$          | S             |
| Adjustments to reconcile net income to net cash from operating activities: |             |               |
| Increase in intercompany payables                                          |             | 349<br>46     |
| Increase in intercompany receivables                                       |             | (10)<br>(28)  |
| Increase in accounts payable and accrued expenses                          |             | 258           |
| Increase in net deferred tax asset                                         |             | (142)<br>(35) |
| Increase in income tax payable                                             |             | 94<br>35      |
| Net cash flows from operating activities                                   |             | 51<br>549     |
| Cash flows from financing activities                                       |             |               |
| Contributed capital                                                        |             | 500           |
| Net cash flows from financing activities                                   |             | 500           |
| Increase in cash and cash equivalents                                      | 1,049       | 51            |
| Cash and cash equivalents - beginning of the period                        |             | 891<br>840    |
| Cash and cash equivalents - end of period                                  | \$<br>1,940 | \$<br>891     |

The accompanying notes are an integral part of these financial statements.

{9}------------------------------------------------

## Wilton Re Distributors LLC NOTES TO FINANCIAL STATEMENTS AS OF AND FOR THE YEAR ENDED DECEMBER 31, 2025 AND FOR THE PERIOD ENDED DECEMBER 31, 2024 (Expressed in thousands of US dollars)

#### 1. ORGANIZATION

Wilton Re Distributors LLC (WDLC or the Company) is a Delaware entity. WDLC is registered with the Securities and Exchange Commission (SEC). WDLC is a wholly owned subsidiary of Wilton Re U.S. Holdings, Inc., a Delaware corporation (WRUS). WRUS is a wholly owned subsidiary of Wilton Re U.S. Holdings Trust, established under the laws of Nova Scotia, Canada, which itself is a wholly owned subsidiary of Wilton Re Ltd. (WRL), a Nova Scotia company. WRL is the ultimate parent in the holding company structure.

The Company is a limited liability company approved to conduct business as a registered broker-dealer in securities under the Securities Exchange Act of 1934, specifically selling variable life insurance or annuities, with an effective date of August 22, 2024. The Company does not maintain custody or receive customer funds or securities; customer accounts are held by Wilton Reassurance Life Company of New York (WRNY). Furthermore, the Company does not maintain a clearing arrangement with any firm. In addition, the Company is a member of the Financial Industry Authority (FINRA) and is subject to its rules and regulations. The Company is excluded from the Securities Investor Protection Corporation (SIPC).

The Company is a non-clearing broker-dealer and serves as principal underwriter for a closed block of variable life and variable annuity policies administered by an affiliated insurance company, WRNY. The Company will not offer or sell any new securities and WRNY will not sell or issue any new variable life and variable annuity policies. Additional deposits are accepted on existing contracts. The Company will stand ready to perform the services of a broker-dealer in conformity with its Principal Underwriting Agreement (PUA) with WRNY.

### SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES 2.

## Basis of Presentation

The accompanying financial statements have been prepared in accordance with accounting principles generally accepted in the United States of America (US GAAP).

## Use of Estimates

The preparation of financial statements in conformity with US GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the dates of the financial statements and the reported amounts of revenues and expenses during the reporting periods. Actual results could differ from those estimates.

## Revenues

The Company earns revenue in connection with the PUA with WRNY (further discussed in Note 4 Related Party Transactions), wherein its performance obligation is to stand ready to perform services of a broker-dealer for a closed block of variable annuity policies. The PUA specifies that the Company will be reimbursed for all expenses incurred to stand ready in performing its duties, which include allocated and direct expenses. The substance of the PUA is that commission expenses related to trailing commissions are calculated and paid to the relevant agents by WRNY on behalf of the Company and WRNY reimburses the Company for those expenses. The reimbursement of these expenses represents revenue to the Company. As there is only one performance obligation (i.e., standing ready

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{11}------------------------------------------------

accrual, bonus accrual and depreciation which are general expenses allocated to the Company under its Services Agreement with WRSI.

WRUS allocates the consolidated amount of current and deferred taxes to members of the tax group based on each member's proportionate share of the consolidated taxable income or loss. This method ensures that each member's tax expense reflects its contribution to the consolidated tax liability. There have been no changes in this allocation method during the year.

#### 4. RELATED PARTY TRANSACTIONS

The Company is party to a Service Agreement with its affiliate, WRSI under which WRSI provides certain services which include, but are not limited to, general executive management, general legal counsel, treasury, tax, financial accounting, information technology services, subscriptions, insurance, banking, office accommodation, and various other support functions. For the year ended December 31, 2025, and period ended December 31, 2024, fees incurred and not paid for these services were \$1,336 and \$55, respectively. The cost to the Company is allocated based on the proportion of time spent by WRSI employees on the Company's operations relative to their total available working hours. This allocation methodology is reviewed periodically to ensure it remains fair and consistent.

As of December 31, 2025 and 2024, the Company had a payable to WRSI of \$50 and \$233, respectively, for payments made in the ordinary course of business on behalf of the Company by WRSI.

The Company is party to a PUA with its affiliate, WRNY. The Company will serve a limited role whose principal purpose will be to provide broker-dealer services for the closed block pursuant to the selling agreements. WRNY agrees to assume on behalf of the Company the responsibility for the processing and payment of trail commissions. WRNY shall pay to the Company a fee equal to all expenses, direct and indirect. For the year ended December 31, 2025, and period ended December 31, 2024, fees earned were \$1,463 and \$166, respectively, of which \$109 and \$98, respectively, is due from WRNY. The Company had a receivable from WRNY of \$22 for commissions as of December 31, 2025 and 2024, respectively.

The Company has no net income from operations and has relied upon capital contributions from WRUS to fund operating activities. The Company's ability to continue as a going concern is dependent upon the continued financial support from WRUS. WRUS has indicated that it will provide additional capital as needed to sustain the Company one year from the date these financial statements are available to be issued.

#### 5. NET CAPITAL REQUIREMENTS

As a registered broker-dealer, the Company is subject to the SEC Uniform Net Capital Rule 15c3-1, which requires the maintenance of minimum net capital. In the first year of operations, the Company is required to maintain net capital equivalent to the greater of \$5 or 12-1/2% of aggregate indebtedness.

As of December 31, 2025 and 2024, the Company had net capital, as defined under the Rule, of \$827 and \$479, respectively. These amounts exceeded the required net capital of \$74 and \$51 by \$753 and \$428, respectively.

The Company's aggregate indebtedness, as defined under the Rule, shall not exceed 800%, and was 135% of its net capital.

{12}------------------------------------------------

## Wilton Re Distributors LLC NOTES TO FINANCIAL STATEMENTS AS OF AND FOR THE YEAR ENDED DECEMBER 31, 2025 AND FOR THE PERIOD ENDED DECEMBER 31, 2024 (Expressed in thousands of US dollars)

#### 6. COMMITMENTS AND CONTINGENCIES

There were no commitments or contingencies to disclose as of December 31, 2025 or 2024.

#### 7. SEGMENT REPORTING

The Company is engaged in a single line of business as a broker-dealer and engages in various activities as described in Note 1. The Company has identified its CEO as the Chief Operating Decision Maker (CODM). The CODM uses segment net income to evaluate the results of the business, to allocate resources, and to monitor the services rendered, billed to and recovered from WRNY. Additionally, the CODM uses excess net capital (see Note 5 Net Capital Requirement), which is not a measure of profit and loss, to make operational decisions while maintaining capital adequacy. The Company's operations constitute a single operating segment and, therefore, a single reportable segment. The CODM manages the business activities using information of the Company as a whole. All commission revenue and other revenue are derived from WRNY, an affliate domiciled in the United States. The accounting policies of the reportable segment are the same as those described in the summary of significant accounting policies. Segment expenses include commission expenses and general expenses. Segment net income, expenses and total assets used by the CODM are the same as those respective amounts reported on the Statements of Financial Position and Statements of Income (Loss).

#### SUBSEQUENT EVENTS 8.

The Company has evaluated subsequent events from the balance sheet date through February 28, 2026, the date at which the financial statements were issued and determined there are no subsequent events requiring adjustments to or disclosure in these financial statements.

{13}------------------------------------------------

### COMPUTATION OF NET CAPITAL FOR BROKER AND DEALERS

| PURSUANT TO RULE 15c3-1 UNDER THE SECURITIES EXCHANGE ACT OF 1934 |     |            |
|-------------------------------------------------------------------|-----|------------|
| December 31, 2025 (Expressed in thousands of US dollars)          |     | Schedule H |
| NET CAPITAL                                                       |     |            |
| TOTAL MEMBER'S EQUITY                                             |     | 1,150      |
| ADJUSTMENTS TO NET CAPITAL PURSUANT TO RULE                       |     |            |
| 15C3-1:                                                           |     |            |
| Nonallowable assets:                                              |     |            |
| Receivable from affiliates                                        | 5   | 109        |
| Other assets                                                      | 5   | 214        |
| Total non allowable assets                                        | 5   | 323        |
| HAIRCUTS ON SECURITIES POSITIONS:                                 |     |            |
| 2% Haircut on money market                                        |     |            |
| NET CAPITAL                                                       | 5   | 827        |
| AGGREGATE INDEBTEDNESS                                            |     |            |
| COMPUTATION OF ALTERNATE NET CAPITAL                              |     |            |
| REQUIREMENT:                                                      |     |            |
| MINIMUM NET CAPITAL REQUIRED                                      | ર્  | 74         |
| MINIMUM DOLLAR NET CAPITAL REQUIREMENT OF                         |     |            |
| REPORTING BROKER OR DEALER                                        | 5   | ഗ          |
| NET CAPITAL REQUIREMENT                                           | ર્ડ | 74         |
| EXCESS NET CAPITAL                                                | ર્ડ | 753        |
| PERCENTAGE OF AGGREGATE INDEBTEDNESS TO NET                       |     | 135%       |
| CAPITAL                                                           |     |            |

Note: There are no material differences between the computation using the amounts reported in the accompanying audited financial statements and the computations as reported in the Company's unaudited FOCUS report, Part IIA, Form X17a-5, as of December 31, 2025

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## COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS FOR BROKERS AND DEALERS PURSUANT TO RULE 15c3-3 UNDER THE SECURITIES EXCHANGE ACT OF 1934 December 31, 2025

The Company does not claim an exemption under paragraph (k) of Rule 15c3-3.

The Company is filing an exemption report in reliance on footnote 74 to SEC Release 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 because the Company limits its business activities exclusively as a broker selling variable life insurance or annuities and the Company does not accept customer funds or securities, does not take possession of any customer funds or securities in connection with its activities, and does not carry accounts of or for customers. The Company did not carry Proprietary Accounts of Broker-Dealers or PABs accounts (as defined in Rule 15c3-3 of the Securities Exchange Act of 1934).

The Company met the conditions of Footnote 74 for the year ended December 31, 2025, without exception.

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### Exemption Report

Wilton Re Distributors LLC (the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C.F.R. §240.17a-5, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R. § 240.17a-5(d)(1) and (4). To the best of its knowledge and belief, the Company states the following:

- 1. The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240.15c3-3, 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. § 240.17a-5 because 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 period from January 1, 2025 to December 31, 2025 without exception.

Wilton Re Distributor LLC

I, Karen Carpenter, swear (or affirm) that, to my best knowledge and belief, this Exemption Report is true and correct.

Sign:

Title: CEO

Date: 3/ 6/26


Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.