# EFCG TRANSACTION SERVICES LLC X-17A-5 (2026-02-11) — Broker-dealer annual report - Company: EFCG TRANSACTION SERVICES LLC - Form: X-17A-5 - Filed: 2026-02-11 - Period: 2025-12-31 - Accession: 0002045178-26-000001 - CIK: 2045178 - File #: 8-71307 - Type: Broker-dealer - Material weakness: No - Auditor: Anson, Brian, W - Auditor location: TARZANA, CA - Contact: Jessica Barclay - Phone: (212) 752-2203 - Email: jzbarclay@efcg.com - Website: efcg.com - Signed by: Jessica Barclay (CEO) Original filing: https://www.sec.gov/Archives/edgar/data/2045178/000204517826000001/2025CertAudEFCGfull.pdf --- {0}------------------------------------------------ **EFCG Transaction Services LLC** **Financial Statements and Supplemental Schedules Required by the U.S. Securities and Exchange Commission** **Including Independent Auditor's Report Thereon** **for the Seven Months Ended December 31, 2025** {1}------------------------------------------------ | Report of Independent Registered Public Accounting Firm 3 | |-------------------------------------------------------------| | Financial Statements 4 | | Statement of Financial Condition .4 | | Statement of Income 5 | | Statement of Cash Flows 6 | | Statement of Changes in Members' Equity 7 | | Notes to Financial Statements 8 | | Supplementary Schedules Pursuant to SEA Rule lla-5 12 | | Computation of Net Capital 12 | | Determination of Reserve Requirements 13 | | Information Related to Possession or Control 14 | | Assertions Regarding Exemption Provisions 15 | | Report of Independent Registered Public Accounting Firm 16 | {2}------------------------------------------------ **UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549** # **ANNUAL REPORTS FORM X-17 A-5 PART Ill** 0MB APPROVAL 0MB Number: 3235-0123 Expires: Nov. 30, 2026 Estimated average burden hours per response: 12 SEC Fili NUMBER 8-71307 **FACING PAGE** **Information Required Pursuant to Rules 17a-5, Ua-12, and lSa-7 under the Securities Exchange Act of 1934** FILING FOR THE PERIOD BEGINNING 06/27 /25 AND ENDING 12/31 /25 MM/DD/YY MM/DD/YY **A. REGISTRANT IDENTIFICATION** # NAME oF FIRM: EFCG Transaction Services, LLC TYPE OF REGISTRANT (check all applicable boxes): [!l Broker-dealer D Security-based swap dealer D Major security-based swap participant □ Check here if respondent is also an OTC derivatives dealer ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) # 4915 West 31st Avenue | co
(State)
PERSON TO CONTACT WITH REGARD TO THIS FILING
(212) 752-2203
(Area Code -Telephone Number)
B. ACCOUNTANT IDENTIFICATION
INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing* | (Email Address) | 80212
(Zip Code)
jzbarclay@efcg.com | |-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------|----------------------------------------------------------| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 18455 Burbank Blvd. Suite 406 Tarzana | CA | 91356 | | (City) | (State) | (Zip Code) | | | 2370 | | | (PCAOB Registcatioo N,mbe,, if applicable I | | | | | | | | | | (Name-if individual, state last, first, and middle name) | **\*** 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 17 CFR 240.17a-5(e)(l)(ii), if applicable. **Persons who are to respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid 0MB control number.** {3}------------------------------------------------ #### OATH OR AFFIRMATION | 1, Jessica Barclay | swear (or affirm) that, to the best of my knowledge and bel i ef, th e | | |--------------------------------------------------------------------------------|---------------------------------------------------------------------------------------|-------| | fi nancial report pe rtain in g to the firm of EFCG Transactions Services, LLC | | as of | | 1 2/3
1 | 2� is tru e and correct. I further swear (or affirm) that neither the company nor any | | partner, officer, director, or eq uiva lent person, as th e case may be, has any proprietary i nterest in any account classified solely as that of a custome r. **s;gnatu ,e \_ �** Title: f CEO #### **Th is fil ing\*\* conta ins (check all appl icable boxes):** - [!] (a ) Statement offinancial condition. - □ (b) Notes to consolidated statement of fi na ncial condition. - [!] (c) Statement of i ncome (loss) or, if there is other comprehensive i ncome in the period(s) presented, a statement of comprehensive income (as defined i n § 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 cred itors. - [!] (g) Notes to consolidated financial statements. - [!] (h) Computation of net ca pital 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 req uirements pursuant to Exhibit A to 17 CFR 240.15c3-3. - □ (k) Computation for determi nation 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) I nformation relating to possession or control req u irements for security-based swap customers under 17 CFR 240.15c3-3 (p)(2) or 17 CF R 240.18a-4, as applicable. - [!] (o) Reconciliations, including appropriate expla nations, of the FOCUS Report with computation of net capital or ta ngi ble net worth under 17 CFR 240.15c3-1, 17 CFR 240.18a-1, or 17 CF R 240. 18a-2, as a pplicable, a nd the reserve req uirements 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 fi nancial data for subsid iaries 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 applica ble. - □ (r) Complia nce report in accorda nce with 17 CFR 240.17a-5 or 17 CFR 240. 18a-7, as applica ble. - [!] (s) Exemption report in accordance with 17 CF R 240. 17a-5 or 17 CFR 240.18a-7, as applica ble. - □ (t) I ndependent public accou nta nt's report based on an examination of the statement of financial cond ition. - [!] (u) I ndependent public accou nta nt's report based on an examination of the fi na ncial report or fi na ncial statements under 17 CFR 240.17a-5, 17 CFR 240. 18a-7, or 17 CFR 240.17a-12, as applicable. - □ (v) I ndependent public accou ntant's report based on an exami nation of certain statements in the compliance report u nder 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - [!] (w) I ndependent public accou nta nt's report based on a review of the exemption report under 17 CF R 240. 17a-5 or 17 CFR 240. 18a-7, as applica ble. - □ (x) Supplemental reports on applying agreed-u pon proced u res, in accordance with 17 CFR 240.15c3-le or 17 CFR 240.17a-12, as applica ble. - □ (y) Report describi ng any material inadeq uacies found to exist or found to have existed since the date of the previous a ud it, or a statement that no material i nadeq uacies exist, under 17 CFR 240. 17a-12(k). - □ (z ) other: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ \_ - *\*\*To request confidential treatmen t of certain portions of this filing, see 17 CFR 240. 1 7a-5(e}(3}* or *17 CFR 240.18a-7{d}(2), as applicable.* {4}------------------------------------------------ # **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** To the Member of EFCG Transaction Services LLC #### **Opinion on the Financial Statements** I have audited the accompanying statement of financial condition of EFCG Transaction Services LLC, as of December 31, 2025, the related statements of income, changes in members' equity, and cash flows for the seven months then ended, and the related notes (collectively referred to as the financial statements). In my opinion, the financial statements present fairly, in all material respects, the financial position of EFCG Transaction Services LLC as of December 31, 2025, and the results of its operations and its cash flows for the seven months ended December 3 1, 2025, in conformity with accounting principles generally accepted in the United States of America. 7 #### **Basis for Opinion** These financial statements are the responsibility of EFCG Transaction Services LLC's management. My responsibility is to express an opinion on EFCG Transaction Services LLC's financial statements based on my audit. I am a public accounting firm registered with the Public Company Accounting Oversight Board (United States) "(PCAOB)" and am required to be independent with respect to EFCG Transaction Services LLC in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. I conducted my audit in accordance with the standards of the PCAOB. Those standards require that I plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. My audit included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. My audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. I believe that my audit provides a reasonable basis for my opinion. ### **Auditor's Report on Supplemental Information** The information contained in Schedule I, II, and III ("Supplemental Information") has been subjected to audit procedures performed in conjunction with the audit of the EFCG Transaction Services LLC's financial statements. Supplemental Information is the responsibility of EFCG Transaction Services LLC's management. My audit procedures included determining whether the Supplemental Information reconciles to the financial statements or the underlying accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the Supplemental Information. In forming my opinion on the Supplemental Information, I evaluated whether the Supplemental Information, including its form and content is presented in conformity with 17 C.F .R. § 240. 1 7a-5. In my opinion, Schedules I, II, and III are fairly stated, in all material respects, in relation to the financial statements taken as a whole. *I* • nan W. **A** nson Certified Public Accountant I have served as EFCG Transaction Services LLC's auditor since 2025. Tarzana, California February 2, 2026 {5}------------------------------------------------ # EFCG Transaction Services LLC Financial Statements Statement of Financial Condition December 31, 2025 ASSETS Cash Accounts Receivable Prepaid Expenses TOTAL ASSETS LIABILITIES & EQU ITY Due to Parent Total Liabilities Members' Equity Members' Equity Total Equity TOTAL LIABILITIES & MEMBERS' EQU ITY 7,783,279 81,801 5,255 7,870,335 261,939 261,939 7,608,396 7,608,396 7,870,335 The accompanying notes are an integral part of these financial statements. {6}------------------------------------------------ # EFCG Transaction Services LLC Financial Statements Statement of I ncome For the Seven Months Ended December 31, 2025 | Revenues | | |-----------------------------|-----------| | M&A Consulting Fees | 9,096,249 | | | | | Total Revenues | 9,096,249 | | | | | Expenses | | | Payroll & Benefits | 2,232,146 | | Professional Fees | 80,086 | | Information Technology Fees | 68,785 | | Membership & Subscriptions | 64,347 | | Rent | 41,223 | | Travel & Entertainment | 5 1,003 | | Office Supplies | 40,683 | | General & Administrative | 21,414 | | | | | Total Expenses | 2,599,687 | | Income ( Loss) Before Taxes | 6,496,562 | | | | | Provision for Income Taxes | 217,540 | | Net Income (Loss) | 6,279,022 | | | | The accompanying notes are an integral part of these financial statements. {7}------------------------------------------------ # EFCG Transaction Services LLC Financial Statements Statement of Cash Flows For the Seven Months Ended December 31, 2025 CASH FLOWS FROM OPERATING ACTIVITIES Net Income (Loss) Accounts Receivable Prepaid Expenses Due to Parent Net cash provided by operating activities NET INCREASE ( DECREASE) IN CASH CASH - June 26, 2025 CASH AT END OF PERIOD 2025 6,279,022 (81,801) (5,255) 261,939 6,453,905 6,453,905 1,329,374 7,783,279 Cash paid for Income Taxes: \$217,540 Cash Paid for Interest: \$0 The accompanying notes are an integral part of these financial statement {8}------------------------------------------------ EFCG Transaction Services LLC Financial Statements Statement of Changes in Members' Equity For the Seven Months Ended December 31, 2025 **Balance, June 26, 2025** 6,279,022 Balance, December 31, 2025 7,608,396 **Net Income (Loss)** 1 ,329,374 The accompanying notes are an integral part of these financial statements. {9}------------------------------------------------ ### Note 1: GENERAL AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES ### *General* EFCG Tra nsaction Services, LLC, (the "Compa ny"), was formed in the state of Colorado as a Limited Lia bility Corporation on August 7, 2024. The company was approved as a broker-dealer on June 27, 2025 with the Secu rities and Excha nge Commission ("SEC") and is a member of the Fina ncial Industry Regulatory Authority ("FINRA") and Secu rities Investor Protection Corporation ("SIPC"). The Company is authorized to engage in mergers and acquisitions and private placements of secu rities. The Company does not hold customer fu nds or safeguard customer secu rities. # *Summary of Significant Accounting Policies* The presentation of fina ncial statements in conformity with accounting principles generally accepted in the United States of America req uires ma nagement to make estimates and assumptions that affect the reported amounts of assets and lia bilities and disclosure of contingent assets and lia bilities at the date of the fina ncial statements and the reported amounts of revenue and expenses during the reporting period. Actual results could differ from those estimates. The ma nagement has reviewed the results of operations for the period of time from its December 31, 2025, through February 2, 2026, the date the fina ncial statements were availa ble to be issued and have determined that no adjustments are necessary to the amounts reported in the accompa nying fina ncial statements nor have any subseq uent events occurred, the nature of which would require disclosure. On January 9, 2026, the Company distributed \$6,500,000 to its parent com pa ny. The Company is subject to audit by the taxing agencies for the year ending December 31, 2024. Segment Reporting: The Company is engaged in a single line of business as a securities broker dealer, which is comprised of one class of service. The Company has identified its Chief Executive Officer as the chief operating decision maker (CODM), who uses net income to evaluate the results of the business, predomina ntly in the forecasting process, to ma nage the Compa ny. {10}------------------------------------------------ Additional ly, the CODM uses excess net ca pital, which is not a measure of profit and loss, to make operational decisions while maintaining ca pital adequacy, such as whether to reinvest profits or pay dividends. The Company's operations constitute a single operating segment and therefore, a single reporta ble segment, because the CODM manages the business activities using information from the Company as a whole. The accounting pol icies used to measure the profit and loss of the segment are the same as those described in the summary of significant accounting pol icies. FASB ASC 820 defines fair value, esta bl ishes a framework for measuring fair value, and esta bl ishes a fair value hierarchy which prioritizes the in puts to valuation techniq ues. Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date. A fair value measurement assumes that the transaction to sell the asset or liability or, in the absence of a principal market, the most advantageous market for the asset or liability. Valuation techniq ues that are consistent with the market, income or cost approach, as specified by FASB ASC 820 are used to measure fair value. The fair value hierarchy prioritizes the inputs to valuation techniq ues used to measure fair value into three broad levels: Level 1 inputs are quoted prices (unadjusted) in active markets for identical assets or liabilities the Company has the ability to access. Level 2 inputs are inputs (other than quoted prices included within Level 1) that are observa ble for the asset or liability, either directly or indirectly. Level 3 are unobserva ble inputs for the asset or liability and rely on management's own assumptions about the assumptions that market participants would use in pricing the asset or liability. {The unobserva ble in puts should be developed based on the best information availa ble in the circumstances and may include the Com pany's own data.) There were no levels to measure on December 31, 2025. {11}------------------------------------------------ #### Note 2: ASC 606 REVENUE RECOGNITION: Revenue A. Significa nt accounting policy Revenue is measured based on a consideration specified in a contract with a customer, and excludes any sales incentives and amounts collected on behalf of third parties. The Com pany recognizes revenue when it satisfied a performa nce obligation by transferring control over a product or service to a customer. B. Nature of services The following is a description of activities - separated by reporta ble segments, per FINRA Form "Supplemental Statement of Income (SSOI)"; from which the Company generates its revenue. For more detailed information about reporta ble segments, see below. Revenue from broker/dealer selling mergers and acquisitions, and private placements of secu rities. #### **Note 3:** RELATED **PARTY:** The Com pany has an expense sharing agreement ("Expense Sharing Agreement") with The Environmental Fina ncial Consulting Group, LLC ("EFCG"), which is 100% owned by the Managing Partners, who are also the 100% owners of the Com pany. Pu rsua nt to the terms of the Expense Sharing Agreement dated August 8, 2024, EFCG agrees to Furnish to EFCG Tra nsaction Services LLC, to the extent req uired, office space, office equipment and supplies as well as any other service req uired in EFCG Tra nsaction Services LLC's administration as agreed from time to time by EFCG and EFCG Tra nsaction Services LLC. It is expressly understood that EFCG will not assist or otherwise have any involvement in the ma nagement, sales activities or decision-making process of EFCG Tra nsaction Services LLC incident to its broker/dealer activities but rather shall only be providing administrative and back-office su pport services for such activities. The terms and conditions of the Expense Sharing Agreement may be cha nged in writing by mutual agreement of the parties. {12}------------------------------------------------ The following services and fees shall be shared between EFCG Tra nsaction Services LLC and EFCG as follows and pursua nt to the terms of the Expense Sharing Agreement: | Descri�tion Of Services And Fees To Be Shared | Monthli Cost Al
location to be �aid bi EFCG
Transaction Services LLC | |-----------------------------------------------|----------------------------------------------------------------------------| | 1. Office Rent | \$41,223 | | 2. Office Supplies | \$40,683 | | 3. General & Administrative | \$2
1,414 | | 5. Information Technology Fees | \$68,785 | | 6. Su
bscriptions and Membership Expenses | \$64,347 | | 7. Payrolls & Benefits | \$2,232,
146 | | 8. Professional Fees | \$80,086 | \$261,939 is owed to its parent at December 31, 2025. In February 2016 the FASB issued ASU 2016-02 on Leases. Under this guida nce lessees are req uired to recognize lease lia bility and a right-to-use asset for all leases at the commencement date, with the exception of short-term leases. ASU 2016-02 is effective for annual and interim periods beginning after December 15, 2018, and early adoption is permitted. The Company is not subject to this req uirement in as much as it has an expense sharing agreement with its related party through common ownership. #### Note 4: NET CAPITAL The Company is subject to the Secu rities and Excha nge Commission Uniform Net Ca pital Rule (SEC rule 15c3-l), which req uires the maintena nce of minimum net ca pital and req uires that the ratio of aggregate indebtedness to net ca pital, both as defined, shall not exceed 8 to 1. Net ca pital and aggregate indebtedness cha nge day to day, but on December 31, 2025, the Company had net ca pital of \$7,52 1,340, which was \$7,488,598 in excess of its req uired net ca pital of \$32,742; and the Compa ny's ratio of aggregate indebtedness (\$261,939) to net ca pital was .035:1, which is less than the 8 to 1 maximum ratio allowed for a broker dealer. #### Note 5: COM MITMENTS AND CONTINGENCIES The Company did not have any litigation or other legal action that would req uire disclosure during the year ended December 31, 2025. #### Note 6: CONCENTRATION OF CREDIT **RISK** The company maintains cash bala nces with various fina ncial institutions. Ma nagement performs periodic evaluations of the relative credit sta nding of these institutions. The Company has not sustained any material credit losses from these instruments. For the seven-months ended December 31, 2025, 90% of fee income was earned from two clients. {13}------------------------------------------------ #### Note 7: INCOME TAXES The Company operates as a Limited Lia bility Company treated as a partnership for tax pu rposes. In 2025, the Company paid to the State of Colorado \$139,406, the State of New York \$77,400 and the State of Delaware \$734, for a total of \$2 17,540. The Company is subject to audit by the taxing agencies for the year ending Decem ber 31, 2024. {14}------------------------------------------------ # EFCG Transaction Services LLC Computation of Net Capital For the Seven Months Ended December 31, 2025 #### Computation of Net Capital | Total Members' Equity | 7,608,396 | |------------------------------------------------------------------------|-----------------| | Non-Allowable Assets: | | | Accounts Receivable | 81,801
5,255 | | Prepaid Expenses | | | Total Non-Allowable Assets | 87,056 | | Net Allowable Capital | 7,521,340 | | Computation of Net Capital Requirement | | | Minimum Net Capital Required as a Percentage of Aggregate Indebtedness | 32,742 | | Minimum Dollar Net Capital Requirement of Reporting Broker/Dealer | 32,742 | | Excess Net Capital | 7,488,598 | | Computation of Aggregate Indebtedness | | | Total Aggregate Indebtedness | 261,939 | | Percentage of Aggregate Indebtedness to Net Capital | .035 :1 | | Computation of Reconciliation of Net Capital | | | Net Capital Computed and Reported on FOCUS IIA as of | | | December 31, 2025 Adjustments | 7,488,598 | | Net Capital per Audit | 7,488,598 | | Reconciled Difference | 0 | {15}------------------------------------------------ EFCG Transaction Services LLC Schedule II - Determination of Reserve Requirements Under Rule 1 5c3-3(e) For the Seven Months Ended December 31, 2025 EFCG Transaction Services LLC has no reserve deposit obligations under SEC 1 5c3-3(e) because it is a "noncovered" firm pursuant to Footnote 74 to SEC Release 34-70073 and therefore is not subject to the Rule. {16}------------------------------------------------ EFCG Transaction Services LLC Schedule III - Information Related to Possession or Control Requirements Under Rule 15c3-3(b) For the Seven Months Ended December 31, 2025 EFCG Transaction Services LLC has no possession or control obligations under SEC 1 5c3-3(b) because it is a "non-covered" firm pursuant to Footnote 74 to SEC Release 34-70073 and therefore is not subject to the Rule. {17}------------------------------------------------ EFCG Transaction Services LLC Assertions Regarding Exemption Provisions For the Seven Months Ended December 31, 2025 I, as member of the management ofEFCG Transaction Services LLC (the "Company") am responsible for compliance with the annual reporting requirements under Rule 17a-5 of the Securities Exchange Act of 1934. Those requirements compel a broker or dealer to file annual reports with the SEC and the broker's or dealer's designated examining authority. One of the reports to be included in the annual filing is an exemption report prepared by an independent registered public accounting form, based upon a review of assertions provided by the broker or dealer. Pursuant to that requirement, the management of the Company hereby makes the following assertions. The Company is a "non-covered" firm pursuant to Footnote 74 to SEC Release 34-70073 and is therefore not subject to SEA Rule 1 5c3-3 for the most recent seven months ended December 31, 2025. The Company represents that it has not held customer funds or securities, did not carry accounts of or for customers and did not carry broker-dealer proprietary accounts as defined in Exchange Act rule 1 5c3-3 . The Company limits its business activities to the following: - Mergers & Acquisitions; and - Private Placements of Securities The Company has maintained compliance with the above throughout the seven months ended December 3 1, 2025, without exception. Jessie Zo a Barclay, CEO February 2, 2026 {18}------------------------------------------------ ## **8RIAN W. ANSON** *Certified Public Accountant* I 8455 Burbank Blvd., Suite 406, Tarzana, CA 91356 • Tel. (8 1 8) 636-5660 ## **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** Board of Members' EFCG Transaction Services LLC Denver, Colorado I have reviewed management's statements, included in the accompanying SEC Rule 1 5c3-3 Exemption Report in which EFCG Transaction Services LLC, stated that EFCG Transaction Services LLC's, business activities are limited to providing mergers and acquisitions and private placements of securities on a best efforts basis only and corporate finance and other investment banking advisory services, and that it has not held customer funds or securities and that EFCG Transaction Services LLC is classified as "non-covered" pursuant to footnote 74 to SEC Release 34-70073, dated July 30, 2013, and as discussed in Q & A 8 of the related FAQ issued by SEC state on July 1, 2020. EFCG Transaction Services LLC also stated that it had maintained compliance with the above declaration throughout the most recent year ended December 31, 2025, without exception. EFCG Transaction Services LLC's management is responsible for compliance and is not subject to the provisions set forth in Rule 1 5c3-3 under the Securities and Exchange Act of 1934 and its statements. My review was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and accordingly, included inquiries and other required procedures to obtain evidence about EFCG Transaction Services LLC's declaration concerning the provisions set forth in Rule 1 5c3-3 under the Securities Exchange Act of 1934. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, I do not express such an opinion. Based on my review, I am not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based on the provisions set forth in Footnote 74 to SEC Release 34-70073. Bnan W. Anson Certified Public Accountant T arzana, California February 2, 2026 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.