# BRIGHTON SECURITIES CORP. X-17A-5 (2025-02-21) — Broker-dealer annual report

- Company: BRIGHTON SECURITIES CORP.
- Form: X-17A-5
- Filed: 2025-02-21
- Period: 2024-12-31
- Accession: 0002013816-25-000019
- CIK: 14213
- File #: 8-14599
- Type: Broker-dealer
- Material weakness: No
- Auditor: RDG and Partners CPAs, PLLC
- Auditor location: New York, NY
- Contact: George T. Conboy
- Phone: 585-340-2206
- Email: gtconboy@brightonsecurities.com
- Website: brightonsecurities.com
- Signed by: George T. Conboy (Chairman)

Original filing: https://www.sec.gov/Archives/edgar/data/14213/000201381625000019/brightonaudit.pdf

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| UNITED STATES                      |  |  |  |
|------------------------------------|--|--|--|
| SECURITIES AND EXCHANGE COMMISSION |  |  |  |
| Washington, D.C. 20549             |  |  |  |

## ANNUAL REPORTS FORM X-17A-5 PART II

OMB Number: 3235-0123 Expires: Nov. 30, 2026 Estimated average burden hours per response: 12 SEC FILE NUMBER

OMB APPROVAL

|  | 8-14599 |  |
|--|---------|--|
|  |         |  |

#### FACING PAGE

Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of <sup>1934</sup>

FILING FOR THE PERIOD BEGINNING 01/01/2024 MM/DD/YY AND ENDING 12/31/2024 A. REGISTRANT IDENTIFICATION MM/DD/YY NAME OF FIRM: Brighton Securities Corp. TYPE OF REGISTRANT (check all applicable boxes): Broker-dealer ☐ Security-based swap dealer Major security-based swap participant Check here if respondent is also an OTC derivatives dealer ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use <sup>a</sup> P.O. box no.) 1703 Monroe Avenue Rochester (City) (No. and Street) NY (State) 14618 (Zip Code) George T. Conboy PERSON TO CONTACT WITH REGARD TO THIS FILING 585-340-2206 gtconboy@brightonsecurities.com (Name) (Area Code - Telephone Number) (Email Address) B. ACCOUNTANT IDENTIFICATION

INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing\*

## RDG+Partners CPAs, PLLC

| 10 Winthrop St.                                  | (Name - if individual, state last, first, and middle name)<br>Rochester | Y<br>N  | 14607                                      |
|--------------------------------------------------|-------------------------------------------------------------------------|---------|--------------------------------------------|
|                                                  | (City)                                                                  | (State) | (Zip Code)                                 |
| (Address)<br>07/13/2010                          |                                                                         | 5175    |                                            |
| (Date of Registration with PCAOB)(if applicable) |                                                                         |         | (PCAOB Registration Number, 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 accountant must be supported by a statement of facts and circumstances relied on as the basis of the exemption. See <sup>17</sup> CFR 240.17a-5(e)(1)(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 OMB control number.

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## OATH OR AFFIRMATION

| George T. Conboy                                                                                                               | swear (or affirm) that, to the best of my knowledge and belief, the                         |  |  |  |
|--------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|--|--|--|
| financial report pertaining to the firm of Brighton Securities Corp.                                                           | and and the commend of the commend of the many as as of                                     |  |  |  |
| 12/37                                                                                                                          | , 2 024 , 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:                                                                                  |  |  |  |
|                                                                                                                                |                                                                                             |  |  |  |
|                                                                                                                                | Tre:                                                                                        |  |  |  |
|                                                                                                                                | Chairman                                                                                    |  |  |  |
|                                                                                                                                |                                                                                             |  |  |  |
| Wotary Public                                                                                                                  | JULIE A. GULLO                                                                              |  |  |  |
|                                                                                                                                | NOTARY PUBLIC, STATE OF NEW YORK                                                            |  |  |  |
| This filing** contains (check all applicable boxes):                                                                           | Registration No. 01GU4955352                                                                |  |  |  |
| (a) Statement of financial condition.                                                                                          |                                                                                             |  |  |  |
| [ (b) Notes to consolidated statement of financial condition.                                                                  | Qualified in WAYNE County                                                                   |  |  |  |
| (c) Statement of income (loss) or, if there is other comprehensive in the period(s) presented, a statement of                  | Commission Expires AUGUST 28, 202                                                           |  |  |  |
| 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.                                     |                                                                                             |  |  |  |
| [1) Computation of tangible net worth under 17 CFR 240.18a-2.                                                                  |                                                                                             |  |  |  |
| (i) 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.                                                                                  |                                                                                             |  |  |  |
| (I) 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 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.                                                                                                                         |                                                                                             |  |  |  |
| [ {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 240.18a-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 statements under 17                        |                                                                                             |  |  |  |
| CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable.                                                          |                                                                                             |  |  |  |
| [1] (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 240,17a-12                            |                                                                                             |  |  |  |

- as applicable. [] (y) Report describing any material inadequacies found to 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.

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## Brighton Securities Corp.

FINANCIAL STATEMENTS December 31, 2024

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|  |  | Table of Contents |  |  |
|--|--|-------------------|--|--|
|  |  |                   |  |  |

| REPORT OF INDEPENDENT REGISTERED PUBLIC                                                                                                                  |                       |  |
|----------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------|--|
| ACCOUNTING FIRM                                                                                                                                          | 1                     |  |
| FINANCIAL STATEMENTS:                                                                                                                                    |                       |  |
| Statement of Financial Condition                                                                                                                         | 2                     |  |
| Statement of Income and Comprehensive Income<br>Statement of Changes in Stockholder's Equity<br>Statement of Cash Flows<br>Notes to Financial Statements | 3<br>4<br>5<br>6 - 15 |  |
| SUPPLEMENTAL INFORMATION:                                                                                                                                |                       |  |
| Computation of Net Capital Under Rule 15c3-1 of the<br>Securities and Exchange Commission                                                                | 16 - 17               |  |
| REPORT OF EXEMPTION CLAIMED UNDER C.F.R. §240.15c3-3(k)                                                                                                  | 18                    |  |
| INDEPENDENT REGISTERED PUBLIC ACCOUNTANT'S<br>REVIEW REPORT ON REPORT OF EXEMPTION CLAIMED<br>UNDER C.F.R. §240.15c3-3(k)                                | 19                    |  |
| STATEMENT OF EXEMPTION FROM RULE 15c3-3                                                                                                                  | 20                    |  |

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# RDG + Partners

ACCOUNTING & CPA SERVICES

## REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Board of Directors and Stockholder of Brighton Securities Corp .:

## Opinion on the Financial Statements

We have audited the accompanying statement of financial condition of Brighton Securities Corp. as of December 31, 2024, the related statements of income and comprehensive income, changes in stockholder's equily, and cash flows for the year then ended, and the related notes (collectively referred to as the "financial statement"). In our opinion, the financial statements present fairly, in all material respects, the financial position of Brighton Securities Corp. as of December 31, 2024, and the results of its mailities for the year the ended in conformity with accounting principles generally accepted in the United States of Ameris a

## Basis for Opinion

These financial statements are the responsibility of Brighton Securities Corp.'s management. Our responsibility is asseunting financial collection Securities Corp.'s financial statements based on our audit. We are a pulic accounting firm registered with the Public Company Accounting Oversight Board (United States) (Pare a Dublic are required to be independent with respect to Brighton Securities Corp. in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the РСАОВ.

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 we prahe misstatement, whether due to error or fraud. Our audit included performing procedures to assess the rides 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 anounts 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 fivancial statements. We believe that our audit provides a reasonable basis for our opinion.

## Auditor's Report on Supplemental Information

The supplemental information in pages 16 and 17 has been subjected to audit procedures performed in conjunction with the audit of Brighton Securities Corp.'s financial statements. The supplemental information is the responsibility of Brighton Securities Corp.'s management. Our audit procedures included determining whether the supplemental information reconciles to the financial statements or the underlying 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. §240.17a-5. In our opinion, the supplemental information is fairly stated, in all material respects, in relation to the financial statements as a whole.

RDG+ Partners CPAs PLC

We have served as Brighton Securities Corp.'s auditor since 2017. Rochester, New York February 20, 2025

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## Statement of Financial Condition December 31, 2024

| ASSETS                                                                                                                                                                                                                                                                           |      |                                                                                                           |
|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------|-----------------------------------------------------------------------------------------------------------|
| Cash and cash equivalents<br>Investments, at fair value<br>Receivables from brokers or dealers<br>Other receivables<br>Prepaid expenses<br>Notes receivable<br>Property and equipment, net<br>Intangible assets, net<br>Operating lease right-of-use asset<br>Deferred tax asset | S    | 343,750<br>1,960,368<br>309,405<br>34,369<br>145,983<br>68,750<br>212,022<br>218,500<br>351,499<br>74,674 |
|                                                                                                                                                                                                                                                                                  | ಿ    | 3,719,320                                                                                                 |
| LIABILITIES AND STOCKHOLDER'S EQUITY                                                                                                                                                                                                                                             |      |                                                                                                           |
| LIABILITIES:<br>Accrued commissions, expenses and other liabilities<br>Due to related parties<br>Deferred revenue<br>Operating lease liability                                                                                                                                   | ea   | 352,683<br>403,817<br>61,538<br>354,197<br>1,172,235                                                      |
| STOCKHOLDER'S EQUITY:<br>Common stock, \$0.0001 par value; 1,000 shares authorized, issued and outstanding<br>Retained earnings                                                                                                                                                  |      | 2,547,085<br>2,547,085                                                                                    |
|                                                                                                                                                                                                                                                                                  | ಕ್ಕಿ | 3,719,320                                                                                                 |

December 31, 2024

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Statement of Income and Comprehensive Income For the Year Ended December 31, 2024

| REVENUE                                  |    |            |
|------------------------------------------|----|------------|
| Commission income                        | ea | 6,585,426  |
| Investment advisory and management fees  |    | 7,552,349  |
| Interest and dividend income             |    | 214,232    |
| Other income                             |    | 141,254    |
| Total revenue                            |    | 14,493,261 |
| EXPENSES                                 |    |            |
| Compensation and benefits                |    | 10,843,960 |
| Clearing and technology                  |    | 517,430    |
| Professional fees                        |    | 345,692    |
| Corporate travel                         |    | 313,521    |
| Office                                   |    | 294,554    |
| Advertising                              |    | 281,493    |
| Rent                                     |    | 261,823    |
| Other                                    |    | 141,156    |
| Regulatory fees                          |    | 127,299    |
| Insurance                                |    | 78,220     |
| Depreciation and amortization            |    | 51,946     |
| Interest                                 |    | 25,533     |
| License and Registration                 |    | 6,711      |
| Total expense                            |    | 13,289,338 |
| INCOME BEFORE PROVISION FOR INCOME TAXES |    | 1,203,923  |
| PROVISION FOR INCOME TAXES               |    | 404,011    |
| NET INCOME                               | es | 799,912    |

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## Statement of Changes in Stockholder's Equity For the Year Ended December 31, 2024

| Stockholder's equity, beginning of the year | ತಿ   | 2,754,173   |
|---------------------------------------------|------|-------------|
| Net income                                  |      | 799.912     |
| Stockholder dividends                       |      | (1,007,000) |
| Stockholder's equity, end of the year       | \$ . | 2.547.085   |

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### Statement of Cash Flows December 31, 2024

| CASH FLOWS FROM OPERATING ACTIVITIES:                                            |   |             |
|----------------------------------------------------------------------------------|---|-------------|
| Net income                                                                       | S | 799,912     |
| Adjustments to reconcile net income to net cash provided by operating activities |   |             |
| Depreciation and amortization                                                    |   | 51,946      |
| Notes receivable forgiveness expense                                             |   | 44,375      |
| Net changes in operating assets and liabilities affecting cash flows:            |   |             |
| Receivables from brokers or dealers.                                             |   | 120,270     |
| Other receivables                                                                |   | 563         |
|                                                                                  |   | (39,176)    |
| Prepaid expenses<br>Deferred tax asset                                           |   | (1,543)     |
| Accrued commissions, expenses and other liabilities                              |   | 84,077      |
|                                                                                  |   | 574,214     |
| Due to related parties                                                           |   | (35,000)    |
| Accrued profit sharing contribution                                              |   | 1,568       |
| Operating lease liability                                                        |   | (92,308)    |
| Deferred revenue                                                                 |   | (101,884)   |
| Current tax liability                                                            |   | 1,407,014   |
| Net cash provided by operating activities                                        |   |             |
| CASH FLOWS FROM INVESTING ACTIVITIES:                                            |   |             |
| Investments, at fair value                                                       |   | (224,541)   |
| Net cash used in financing activities                                            |   | (224,541)   |
|                                                                                  |   |             |
| CASH FLOWS FROM FINANCING ACTIVITIES:                                            |   |             |
| Stockholder dividends                                                            |   | (1,007,000) |
| Net cash used in financing activities                                            |   | (1,007,000) |
| NET DECREASE IN CASH AND CASH EQUIVALENTS                                        |   | 175,473     |
|                                                                                  |   |             |
| CASH AND CASH EQUIVALENTS:                                                       |   | 168,277     |
| Beginning of year                                                                |   |             |
| End of year                                                                      | S | 343.750     |
|                                                                                  |   |             |
|                                                                                  |   |             |
|                                                                                  |   |             |
|                                                                                  |   |             |
| Non Cash Transactions                                                            |   |             |
|                                                                                  |   |             |

| Notes receivable forgiveness                                       | 44,01V  |
|--------------------------------------------------------------------|---------|
|                                                                    | 230,000 |
| Intangible assets acquired for forgiveness of intercompany balance |         |
|                                                                    | 52.690  |
| Recognition of ROU asset and operating lease liability             |         |

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Notes to Financial Statements For the Year Ended December 31, 2024

#### 1. ORGANIZATION

Brighton Securities Corp. (the "Company"), a wholly-owned subsidiary of Brighton Securities Holdings, Inc. ("Brighton Holdings"), is a broker-dealer in securities Exchange Act of 1934, as amended, and an investment adviser registered under the Investment Advisers Act of 1940; as amended. The Company is registered with Securities and Exchange Commission ("SEC") and is a member of the Financial Industry Regulatory Authority ("FINRA") and the Municipal Securities Rulemaking Board ("MSRB"). The Company is also a member of Securities Investor Protection Corporation ("SIPC").

The Company maintains offices in Rochester, Lockport and Batavia, New York, and is an introducing broker. The Company offers discretionary and non-discretionary investment advisory management services, financial planning services, traditional security broker-dealer products, and insurance products to individual, institutional, and corporate clients. The Company's customers are located throughout the United States, but primarily the Western New York area.

#### 2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

Basis of Accounting - The accompanying financial statements have been presented on the accrual basis of accounting which recognizes revenues when earned and expenses when incurred.

Cash and Cash Equivalents - The Company considers all cash on hand, cash in banks and shortterm investments with original maturities of three months or less to be cash equivalents.

Investments - The Company's equity securities are reported at fair value and are classified as "trading" securities. The Company's debt securities are classified as "available for sale" and are reported at fair value. Realized gains and losses on the sale of investments are determined on the specific identification method and are reported in net in the accompanying statement of income and comprehensive income. Unrealized gains and losses on equity and debt securities are reported in net income.

Receivables from Brokers or Dealers - Commissions receivable from brokers or dealers consist primarily of amounts due from the Company's clearing broker. Other receivables consist of various amounts due to the Company. Management provides for expected credit losses through a charge to earnings and a credit to a valuation allowance based on historical experience, current conditions, and reasonable and supportable forecasts. As of the date of these financial statements, management believes that the accounts receivable are fully collectible. Accordingly, no allowance for credit losses has been recorded.

Receivables from brokers and dealers consisted of the following at December 31, 2024

| Opening balance | 429,675    |
|-----------------|------------|
| Closing balance | \$ 309,405 |

Notes Receivable - Notes receivable consist of certain amounts paid to independent contractors and key management personnel as part of their service contracts. Pursuant to the agreements, the notes are being forgiven by the Company pro rata over the terms of each contract for each month of completed service.

Property and Equipment - Property and equipment are stated at cost. Depreciation over the estimated useful lives of the assets (ranging from 5 to 39 years) is provided using the straight-line method for financial reporting purposes. Maintenance and repairs are expensed in the period incurred; significant betterments are capitalized.

{10}------------------------------------------------

Notes to Financial Statements For the Year Ended December 31, 2024

## 2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (Continued)

Intangible Assets - Intangible assets consist of customer lists, employment and non-solicitation agreements. At December 31, 2024, the amount in the accompanying statement of financial condition is reflected net of accumulated anortization of \$11,500. Amortization of thinklal condition is
ended. December, 31, 2024 and the and 11,500. Amortization expense totaled \$11,500 ended December 31, 2024 and the net intentible asset as of December 31, 2024 was \$218,500, Amortization expense is expected to be \$23,000 per year for the next nine years and \$11,500 in the tenth year, when they become fully depreciated.

Deferred Revenue – Defered revenue consists of a relationship extension award received in relation to the execution of a new clearing broker a relations in extension awalt received in relaion in relaion in term of the related agreement. As of December 31, 2024, the amount in the accompany of statement of financial condition is reflected net of the aggregate amount of revenue recognized of \$438,448.

Commission Income - Sales-based commission income is recorded on a trade-date basis as securities transactions occur. Trailing commission revenue is generally based on a percentage of the current market value of clients' investment holdings in trail-eligible assets.

Investment Advisory and Management Fees – Investment advisory and management fee income is recorded over the period in which services are provided based upon average net assets under management in accordance with the respective investment management agreements.

Advertising - The costs of advertising are expensed in the period incurred. Advertising expense totaled \$281,493 for the year ended December 31, 2024.

Income Taxes — The Company is a taxable corporation and is included in the consolidated federal and state income tax returns of its parent corporation. Income taxes are calculated as if the Company filled on a separate return basis, and the amount of current tax or benefit calculated is either remitted to or colimated folum the parent corporation. Deferred tax assets and liabilities are recognized for the estimated future tax consequences attributable to temporary differences between the financial statement carrying amounts of assets and liabilities and their respective tax bases. Such amounts are measured using enacted tax rates expected to apply in the years in which those temporary differences re expected to be recovered or settled. A valuation allowance is provided when it is probable that the full benefit of the deferred tax assets will not be realized.

The Company recognizes its unrecognized tax benefits in accordance with Financial Accounting Standards Board (FASB) Accounting Standards Codification (ASC) 740, Intorne Taxes. Jodoar this guidance, the Company assesses the likelihood, based on their technical merity that tax positions will be sustained upon examination based on the facts, circumstances and information available at the end of each period. Any estimated interest and penalties associated with unrecognized tax benefits are end of and recognized in income tax expense and the corresponding liability. As of December 31, 2024, the Company had no unrecognized tax benefits recorded in the financial statements. The Company is subject to examination by various taxing authorities, however, there were no addits in progress as of the date of these financial statements.

Use of Estimates - The preparation of financial statements in conformity 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 and disclosure of contingent assets and liabilities as of the financial statements and the reported amounts of continuents of revenues and expenses during the reporting period. Actual results could differ from those estimates.

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

Notes to Financial Statements For the Year Ended December 31, 2024

## 2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (Continued)

Recent Accounting Pronouncements - The Company has assessed recent accounting recent "Acounting" Trenined that there are no pronouncements that would be expected to have a material impact on the financial statements.

The Company is engaged in a single line of business as a securities broker-dealer, which is compised The other is orgaged in services, financial planning services, fraditional security brokers of investment advisory management of As described in FASB ASU 2023-07, FASB 280, operating segments are defined as components of an entity for which separate financial information is arailable segments are delined as ochiption of the Operating Decision Maker (the "CODM"). The Company's CODM is the Chairman. The CODM reviews net gains and expenses presented on a basis consistent with the presentation of the statement of income and comprehensive income for purposes of making operating decisions, allocating resources, and evaluating financial performance. The a sceall the operating decisions, anocaling resources, and financial condition as licial assets. As a result, the Compony's aindo Segment used to Topertial is a single reportable segment. The accounting policies of the Company's single Oompany in to entiroty is a same as those described in this Note 2. Refer to Note 1 for a description of the single segment's business

Subsequent Events - Management has evaluated events and transactions that occurred between January 1, 2025 and February 20, 2025, which is the date these financial statements were available to be issued, for possible disclosure and recognition in the financial statements.

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

Notes to Financial Statements For the Year Ended December 31, 2024

### 3. REVENUE RECOGNITION

Revenues are recognized when control of the promised services is transferred to customers, in an amount that reflects the consideration the Company expects to be entitled to in exchange for such services. Revenues are analyzed to determine whether the Company is the principal (i.e. reports revenues on a gross basis) or agent (i.e. reports revenues on a net basis) in the contract. Principal or agent designations depend on the control an entity has over the product or service before control is transferred to a customer.

Commission Income – The Company's commission income represents sales commissions generated by advisors for their clients' purchases and sales of various financial instruments. The Company views the selling, distribution and marketing, or any combination thereof, of investment products to such vilems as a single performance obligation to the product sponsors. The Company is the principal for commission revenue, as it is responsible for the execution of the clients' purchases and males and maintains relationships with the product sponsors. Advisors assist the Company in performing alls obligations. Accordingly, total commission revenues are reported on a gross basis.

The Company generates two types of commission revenue: sales-based commission revenue that is recognized at the point of sale on the trade date, and trailing commission revenue that is recognized investment mediation in in totaled \$1,070,470. Sales-based commission revenue varies by the investment product and is based on the amount of purchase and commission schedule for that particular product. Trailing commission revenue is generally based on a percentage of the current market while of clients' investment holdings in trail-eligible assets and is recognized over the period during which services are performed.

Investment Advisory and Management Fees - The Company's investment advisory and management fees are earned over the period in which such services are provided. The related performance obligations are generally satisfied daily or monthly based on assets under management. The investment management and advisory fees are calculated based upon average monthly, weekly or quarterly net assets under management in accordance with the respective investment management agreements. Investment advisory fees are recorded gross of any subadvisory payments and are included in investment management fees based on management's determination that the Company is acting in the capacity of principal service provider with respect to its relationship with the funds. Any corresponding fees paid are included in operating expenses.

#### 4. INVESTMENTS

The cost and fair value of investments were as follows at December 31, 2024:

|                                     | Unrealized<br>Cost Basis<br>Gains (Losses)<br>Fair Value |                    |    |                |    |                     |  |
|-------------------------------------|----------------------------------------------------------|--------------------|----|----------------|----|---------------------|--|
| Debt securities<br>Other securities | ക                                                        | 1.948.758<br>1.131 | છે | 7.505<br>2,974 | ಳಿ | 1,956,263<br>4.105  |  |
|                                     | ಳಿ                                                       | 1,949,889          | ક  |                |    | 10,479 \$ 1,960,368 |  |

The cost basis of debt securities is amortized cost. The debt securities have maturity dates ranging from January 2024 to August 2040.

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

Notes to Financial Statements For the Year Ended December 31, 2024

#### 4. INVESTMENTS (Continued)

Fair Value of Financial Instruments - The fair value of the Company's financial instruments is determined by using available market information and appropriate valuation methodologies. The Company's principal financial instruments consist of: cash equivalents, debt and equity securities, receivables, and payables. At December 31, 2024, cash and cash equivalents, receivables and payables, as a result of their short maturities and liquidity, are carried at amounts which reasonably approximate fair value.

Under FASB ASC 820, fair value is defined as the price that would be received to sell an asset or paid to transfer a liability (an exit price) in the principal or most advantageous market for the asset or liability in an orderly transaction between market participants on the measurement date. FASB ASC 820 establishes a three-level hierarchy for disclosure to show the extent and level of judgment used to estimate fair value measurements. The three levels of the fair value hierarchy under FASB ASC 820 are as follows:

Level 1 - Inputs to the valuation methodology that consist of unadjusted quoted prices for identical assets or liabilities in active markets that the Company has the ability to access.

Level 2 - Inputs to the valuation methodology which include: (1) quoted prices for similar assets or liabilities in active markets, (2) quoted prices for identical or similar assets or liabilities in inactive markets, (3) inputs other than quoted prices that are observable for the asset or liability, and (4) inputs that are corroborated by observable market data by correlation or other means.

Level 3 - Inputs to the valuation methodology that are unobservable and are significant to the overall fair value measurement.

As of December 31, 2024, the Company's cash and cash equivalents, receivables are recorded at cost which approximated fair value due to their short-term maturities. As such, the fair value hierarchy has not been applied in valuing any of these financial instruments. The following is a description of the valuation methodologies used for debt and equity securities measured at fair value:

Debt securities - Valued using recently executed transactions and market price quotations on active national exchanges.

Equity securities - Valued at the closing prices as reported by active national exchanges.

The preceding method described may produce a fair value calculation that may not be indicative of net realizable value or reflective of future fair values. Furthermore, the use of different methodologies or assumptions to determine the fair value of certain financial instruments could result in a different fair value measurement at the reporting date. The following table sets forth by level, within the fair value hierarchy, the Company's investments at fair value as of December 31, 2024:

|                                     |    | Level 1 | Level 2               | Level 3 |  | Total                 |
|-------------------------------------|----|---------|-----------------------|---------|--|-----------------------|
| Debt securities<br>Other securities | မာ | 4.105   | - \$ 1,956,263 \$     |         |  | \$ 1.956,263<br>4.105 |
|                                     | ಳಿ |         | 4,105 \$ 1,956,263 \$ |         |  | - \$ 1,960,368        |

{14}------------------------------------------------

Notes to Financial Statements For the Year Ended December 31, 2024

## 5. PROPERTY AND EQUIPMENT

| Leasehold improvements<br>Furniture and fixtures | સ્ક્ર<br>1,071,438 |
|--------------------------------------------------|--------------------|
| Equipment                                        | 206, 149           |
|                                                  | 139,726            |
| Less: accumulated depreciation                   | 1,417,313          |
|                                                  | (1.205,291)        |
|                                                  |                    |
|                                                  | S<br>212.022       |

Depreciation expense totaled \$40,446 for the year ended December 31, 2024

### 6. LINE OF CREDIT

The Company has an available line of credit facility with Five-Star Bank providing for maximum borrowings of \$3,000,000. Outstanding borrowings bear interest at the prime rate and are collateralized by substantially all of the Comany's assets. Future line prime fate and are collateralized
convert to seven voar term lease and vill have for business acquisitions will convert to seven-year term loans and will bear interest at either a fixed rate option equal to the Federal
Home Loan Bank of New York 7/7 ameritiring odverse rate option equa Home Loan Bank of New York 7/7 anotizing advance rate + 250 basis points or a variable rate Pederal
equal to the prime rate. At Doomber 24, 2004 the new a variable rate optin equal to the prime rate. At December 31, 2024, there was no outstanding balance on this facility.

{15}------------------------------------------------

Notes to Financial Statements For the Year Ended December 31, 2024

#### 7. INCOME TAXES

The Company's financial statements recognize the current and deferred income tax consequences that result from the Company's activities as if the Company were a separate taxpaying entity rather than a member of the parent corporation's consolidated income tax group. The provision for income taxes consisted of the following for the year ended December 31, 2024:

|                 | S<br>404.011 |
|-----------------|--------------|
|                 |              |
|                 | (1,543)      |
| Federal & State | (1,543)      |
| Deferred:       |              |
|                 | 405,554      |
| State           | 94.642       |
| Federal         | ക<br>310,912 |
| Current:        |              |

A reconciliation of the difference between the expected income tax expense computed at the U.S. statutory income tax rate and the Company's income tax expense follows for the year ended December 31, 2024:

| Expected income tax expense at U.S. statutory tax rate | ಕಿ | 252,824 |
|--------------------------------------------------------|----|---------|
| The effect of:                                         |    |         |
| State income taxes, net of U.S. federal benefit        |    | 94,642  |
| Permanent differences                                  |    | 48,358  |
| Other                                                  |    | 8.187   |
|                                                        | \$ | 404 011 |

At December 31, 2024, the Company had gross deferred tax assets of approximately \$74,674 resulting from temporary differences between the financial statement reporting and tax reporting of property and equipment and intangible assets. At December 31, 2024, accrued income taxes calculated on a separate company basis totaled \$242,993 pursuant to the Company's tax sharing agreement with Holdings and is included in due to related parties in the accompanying statement of financial condition.

### 8. NET CAPITAL REQUIREMENTS

The Company is subject to the SEC Uniform Net Capital Rule (SEC Rule 15c3-1), which requires the maintenance of minimum net capital and requires that the ratio of aggregate indebtedness to net capital, both as defined, not exceed 15 to 1. At December 31, 2024, the Company had net capital of \$1,484,074, which was \$1,384,074 in excess of its required net capital of \$100,000, and a ratio of aggregate indebtedness to net capital of 0.553 to 1.

{16}------------------------------------------------

Notes to Financial Statements For the Year Ended December 31, 2024

### 9. RELATED PARTY TRANSACTIONS

An officer of the Company maintains a 10% ownership interest in a real estate partnership that leases the Brighton office to the Company (Note 10). Additionally, the Company had amounts due to and from various related parties as follows as of and for the year ended December 31, 2024:

|                                                                              |      | Balance at<br>January<br>1.<br>2024 |    | Advances        |    | Repayments                  |    | Balance at<br>December 31.<br>2024 |
|------------------------------------------------------------------------------|------|-------------------------------------|----|-----------------|----|-----------------------------|----|------------------------------------|
| Due from Brighton Capital<br>Duc to Brighton Tax<br>Due to Brighton Holdings | ಕಾ   | 470.014<br>(69,617)                 | ಕಿ | 6.133<br>59.909 | S  | 476,147<br>1.671<br>392,438 | ಕಾ | (11,379)<br>(392,438)              |
|                                                                              | ಲ್ಲಾ | 400,397                             | ಕಾ | 66.042          | es | 870,256                     | ಿರ | (403,817)                          |

Brighton Capital's borrowings from the Company were for working capital and business acquisition purposes. Brighton Capital made repayments of these advances from advisory fees it earned which were received by the Company as well as a non-cash transfer of a customer list. Brighton Tax's borrowings were for working capital purposes. Brighton Tax's repayments of these advances were from tax preparation fees it earned which were received by the Company. Brighton Holdings repayments represents taxes of the Company on a standalone basis owed to Brighton Holdings, as the parent company filing the consolidated tax return.

#### 10. COMMITMENTS AND CONTINGENCIES

Lease Obligations - The Company leases its Batavia office under the terms of a lease agreement that expired on February 17, 2021 and converted into a month-to-month arrangement. The new Batavia lease entered into effective Febrauary 15, 2024 with monthly payments ranging from \$1,540 to \$1,763 through January 2027, is payable in monthly installments, plus additional amounts for repairs and maintenance expenses, as defined. Additionally, the Company leases its Brighton office facility under the terms of a lease agreement that expires on June 30, 2026 and requires annual base rentals ranging from \$219,798 to \$224,898, payable in monthly installments, over the term of the agreement. The agreement also requires additional payments for the Company's pro rata share of repairs and maintenance expenses and real estate taxes, as defined. The Company leases a third office in Lockport under the terms of a lease agreement that expires on January 31, 2025 and requires annual base rent of \$18,100, payable in monthly installments. This lease was subsequently renewed for an additional 12month period and annualt base rent will be increased to \$19,200 in 2025.

{17}------------------------------------------------

Notes to Financial Statements For the Year Ended December 31, 2024

#### 10. COMMITMENTS AND CONTINGENCIES (Continued)

Lease Obligations (Continued) - The Company applies the provisions of ASC Topic 842 to its lease agreements. Pursuant to this standard, the Company determines if an arrangement is a lease, or contains a lease, at inception of a contract and when the terms of an existing contract are changed. The Company recognizes a lease liability and a right of use (ROU) asset at the commencement date of the lease. The lease liability is initially and subsequently recognized based on the present value of its future lease payments. The discount rate is the implicit rate if it is readily determinable or otherwise the Company uses its incremental borrowing rate which is the rate of interest the Company would have to pay on a collateralized basis to borrow an amount equal to the lease payments under similar terms and in a similar economic environment. The ROU asset is subsequently measured throughout the lease term at the amount of the remeasured lease liability (i.e. present value of the remaining lease payments), plus unamortized initial direct costs, plus or minus any prepaid or accrued lease payments, less the unamortized balance of lease incentives received, and any impairment recognized. Lease cost for lease payments is recognized on a straight-line basis over the lease term.

As of December 31, 2024, the Company had a \$354,197 lease liability and a \$351,499 right-of-use asset on its statement of financial condition calculated using an incremental borrowing rate of 4.75%. The weighted average years to maturity was 3 years and total related rent expense was \$261,823 for the year ended December 31, 2024. Aggregate future minimum rental payments required under these agreements are as follows:

| Operating lease liability                        | S | 354.197  |
|--------------------------------------------------|---|----------|
| Less imputed interest                            |   | (22,176) |
| Total contractual future minimum rental payments |   | 376.373  |
| 2027                                             |   | 1.763    |
| 2026                                             |   | 133.491  |
| 2025                                             |   | 241,119  |
|                                                  |   |          |

Operating cash flows included in the measurement of operating lease liabilities totaled \$237,974 during the year ended December 31, 2024

Retirement Plan - The Company maintains a 401(k) retirement plan covering substantially all employees. Eligible participants can elect to contribute to the plan in accordance with Internal Revenue Code limits. The Company provides matching contributions equal to 2% of eligible wages, as defined. The Company can also elect to make profit sharing contributions to the plan at the discretion of the Board of Directors. The Company's related expense was \$122,934 for the year ended December 31, 2024.

#### 11. OFF-BALANCE SHEET CREDIT RISK AND CONCENTRATIONS

The Company maintains its cash in bank deposit accounts which, at times, may exceed federally insured limits. The Company has not experienced any losses in these accounts and believes it is not exposed to any significant credit risk.

As discussed in Note 1, the Company executes transactions and introduces them to a clearing broker on a fully disclosed basis. The clearing broker processes transactions comprising approximately 80% of the Company's total revenue. The Company's exposure to credit risk associated with nonperformance of its customers in fulfilling their contractual obligations pursuant to securities transactions can be directly impacted by volatile trading markets which may impair the customers' ability to satisfy their obligations.

{18}------------------------------------------------

Notes to Financial Statements For the Year Ended December 31, 2024

### 12. OFF-BALANCE SHEET CREDIT RISK AND CONCENTRATIONS (Continued)

The Company, through its clearing broker, seeks to control these risks by requiring customers to maintain sufficient levels of collateral in compliance with various regulatory and internal guidelines. The clearing broker monitors the required margin levels daily and, pursuant to such guidelines, requires the customers to deposit additional collateral or reduce positions, when necessary. The Company's policy is to monitor its market exposure risk. In addition, the Company has a policy of reviewing, as considered necessary, the credit standing of each customer with which it conducts business.

The Company is also engaged in various trading and brokerage activities in which counterparties primarily include broker/dealers, banks and other financial institutions. In the event counterparties do not fulfill their obligations, the Company may be exposed to risk. The risk of default depends on the creditworthiness of the counterparty or issuer of the instrument. It is the Company's policy to review, as necessary, the credit standing of each counterparty.

{19}------------------------------------------------

Computation of Net Capital Under Rule 15c3-1 of the Securities and Exchange Commission For the Year Ended December 31, 2024

| 1. Total stockholder's equity from statement of financial condition                                                                                                                                                                                                              |                    |
|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------|
| 2. Deduct: stockholder's equity not allowable for net capital                                                                                                                                                                                                                    | 2,547,085          |
|                                                                                                                                                                                                                                                                                  |                    |
| 3. Total stockholder's equity qualified for net capital                                                                                                                                                                                                                          | 2,547,085          |
| 4. Add:<br>A. Liabilities subordinated to claims for general creditors allowable in<br>computation of net capital<br>B. Other (deductions) or allowable credits                                                                                                                  |                    |
| 5. Total capital and allowable subordinated liabilities                                                                                                                                                                                                                          | 2,547,085          |
| 6. Deductions and/or charges:<br>A. Total non-allowable assets from statement of financial condition<br>B. Security demand note deficiency<br>C. Commodity futures contracts and spot commodities<br>D. Other deductions and/or charges                                          | (754.300           |
| 7. Other additions and/or allowable credits                                                                                                                                                                                                                                      |                    |
| 8. Net capital before haircuts on securities positions                                                                                                                                                                                                                           | 1,792,785          |
| 9. Haircuts on securities:<br>A. Contractual securities commitments<br>B. Subordinated securities borrowings<br>C. Trading and investment securities:<br>1. Exempted securities<br>2. Debt securities<br>3. Options<br>4. Other securities<br>D. Undue concentration<br>E. Other | (304,606<br>(4.105 |
| 10. Net capital                                                                                                                                                                                                                                                                  | 1,484,074          |

(Continued)

{20}------------------------------------------------

Computation of Net Capital Under Rule 15c3-1 of the Securities and Exchange Commission For the Year Ended December 31, 2024

### COMPUTATION OF BASIC NET CAPITAL REQUIREMENT

| 11. Minimum net capital required (6 2/3% of line 19)                                                                                                                     | S | 54.716    |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---|-----------|
| 12. Minimum dollar net capital requirement of reporting broker and dealer                                                                                                | S | 100,000   |
| 13. Net capital requirement (greater of line 11 or 12)                                                                                                                   | S | 100,000   |
| 14. Excess net capital (line 10 less line 13)                                                                                                                            | S | 1,384,074 |
| 15. Net capital less greater of 10% of line 19 or 120% of line 12                                                                                                        | S | 1,364,074 |
|                                                                                                                                                                          |   |           |
| COMPUTATION OF AGGREGATE INDEBTEDNESS                                                                                                                                    |   |           |
| 16. Total A. I. liabilities from statement of financial condition                                                                                                        | S | 820,736   |
| 17. Add:<br>A. Drafts for immediate credit<br>B. Market value of securities borrowed for which no equivalent value<br>is paid or credited<br>C. Other unrecorded amounts |   |           |
| 18. Deduct: adjustment based on deposits in special reserve accounts                                                                                                     |   |           |
| 19. Total aggregate indebtedness                                                                                                                                         |   | 820.736   |
| 20. Percentage of aggregate indebtedness to net capital (line 19 divided by line 10)                                                                                     |   | 55.30%    |

## RECONCILIATION WITH COMPANY'S COMPUTATION INCLUDED IN PART IIA OF FORM X-17A-5 AS OF DECEMBER 31, 2024

There were no material differences noted between this computation of net capital and the corresponding computation prepared by Brighton Securities Corp. and included in the Company's unaudited amended Part IIA FOCUS Report filing as of the same date.

(Concluded)

{21}------------------------------------------------

December 31. 2024

## DETERMINATION OF RESERVE REQUIREMENTS PURSUANT TO RULE 15C3-3 OF THE SECURITIES AND EXCHANGE COMMISSION

The Company claims an exemption under Rule 15c3-3 (k)(2)(i) and therefore is not subject to the reserve requirements of Rule 15c3-3.

The Company claims an exemption under Rule 15c3-3 (k)(2)(ii) and therefore is not subject to the reserve requirements of Rule 15c3-3.

## INFORMATION RELATING TO THE POSSESSION OR CONTROL REQUIREMENTS UNDER RULE 15C3-3 OF THE SECURITIES AND EXCHANGE COMMISSION

The Company claims an exemption under Rule 15c3-3 (k)(2)(i) and therefore is not subject to the reserve requirements of Rule 15c3-3.

The Company claims an exemption under Rule 15c3-3 (k)(2)(ii) and therefore is not subject to the reserve requirements of Rule 15c3-3.

See Report of Independent Registered Public Accounting Firm

{22}------------------------------------------------

## REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

ACCOUNTING & CPA SERVICES

DG + Partners

To the Board of Directors and Stockholder of Brighton Securities Corp.

We have reviewed management's statements, included in the accompanying Exemption Report, in which (1) Brighton Securities Corp. identified the Scompanying Exempling Exempion Report, in which (1)
Securities Corp. claimed an exemption of C.F. R. S.10 (1F. S Securities Corp. claimed and noming provisions of the states of the Stighton of the Brighton Brighton Securities Corp. stated that they met the identified exemption provisions (2)(i) and (2)(ii) and (2)(ii) and (2)(ii) and (2)(ii) and (2)(ii) and (2)(ii) and (2)(ii) fiscal year without exception. Brighton Securities Corp.'s management is most resembling most resembling with the exemption provisions and its statements.

The Company is also filing this Exemption Report because the business activities contemplated by Foother in the SEC Release ne Confine amendments to 17 C.F.R. business activities contemplated
effecting securities transactions on a subscribitions on a subscribition men effecting securities transactions via subscriptions on a subscription way basis where the limited to
issuer or its agent and not to the Comeny in addition the Camere the fund issuer or its agent and not to ha curver the Company did not directly or indicate payable to the otherwise owe funds or securities for or to custom; and nor drectly of indirectly receive, hold, or
prompty transmitted in compliance with paragraph (o) or dher consideration promptly transmitted in complines with paragraph (a) or (b)(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 received and payable to the issuer or its agent and not of the Company, did not of or for customers of inds are
carry PAB accounts (as defined in Rule 15c2-3) through of or for oustomers; carry PAB accounts (as defined in the to the United on the carry accounts of or rior customers; and

Brighton Securities Corp.'s management is responsible for compliance with the provisions contemplated by Footnote 74 of SEC Release No. 34-70073 adopting amendents to 17 The provisions contemplated by
Staff Frequently Asked Questions and is storements to 17 C.F.R. § 240.17a-5 an Staff Frequently Asked Questions and its statements.

Our review was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, include inquires and other required procedures to obtain evidence about Brighton Securities Corp.'s compliance with the exemplines to obtain eview is substantially less in scope than an examination, the objective of which is the exchiptoris. A review is substantially less in scope than 
we do not express such an opinion 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 and o o f ally thately in all material respects, based on the provisions set forh in paragraph (k)(2)(ii) of Rule 15c3-3 under the Secrities Exchange Act of the provisions set forth other business activities contemplated by Footnder the SEC Release No. 34-70073 adopting amendman's to 17 C.F.R. § 240.17a-5, and related SEC Staff Frequently Asked Questions.

RDG+Partners CPAs PLC

Rochester, New York February 20, 2025

RDG + Partners CPAs, PLLC 10 Winthrop Street, Rochester, NY 14607 \* Tel 585.673.2600 www.1rdg.com

{23}------------------------------------------------

Report of Exemption Claimed Under C.F.R.§240.15c3-3(k) December 31, 2024

To the best of my knowledge and belief, Brighton Securities Corp. claims exemption from 17 C.F.R. §240.15c3-3(k)(2)(i) and (ii) (the "exemption provision") for the entire year ended December 17, 2024.

(3) The Company is also filing this Exemption Report because the Company's other business activities contemplated by Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 are limited to (1) effecting securities transations via 94-0075 adopting and amending to 17 C.F. . \$ 240.17.
are payable to the issuer or its agent and mot to the Comments are payable to the issuer or its agent and tot the Company, and the Company (1) did not directly or indirectly receive, hold, or otherwise owe finds or securities for to customers, (other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of Rule 15c2-4 andor funds received and promply transmitted for effecting transacions via subscriptions on a subscription way basis where the finds are payable to the issuer or its agent and to the Company) (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year ended December 31, 2024 without exception.

To the best of my knowledge and belief, Brighton Securities Corp. has met the identified exemption provision under 17 C.F.R. §240.15c3-3(2)(i) and (ii) throughout the entire year ended December 31, 2024 as described in paragraph (d)(4)(iii) of this section without exception.

George T. Conboy, Chairman


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