SEC Division of Trading and Markets no-action letter: ACI Capital Markets LLC

June 3, 2026
Justin Tallaksen
Chief Operating Officer
ACI Capital Markets, LLC
199 Water Street, 9th Floor
New York, NY 10038
Re: Annual Audited Financial Statement Filing Requirements Under Rule 17a-5 Dear Mr. Tallaksen:
We have received your letter dated May 20, 2026 in which you request on behalf of ACI Capital Markets, LLC (the “Firm”) relief from the requirement that the Firm file audited annual reports pursuant to paragraph (d) of Rule 17a-5 under the Securities Exchange Act of 1934 for the fiscal year ending on June 30, 2026 (the “Request”). I understand that the Firm’s registration as a broker-dealer with the Securities and Exchange Commission (“Commission”) was granted on February 17, 2026, and became effective on February 18, 2026 when the Firm was approved as a Financial Industry Regulatory Authority, Inc. (“FINRA”) member. The Firm chose June 30 as its fiscal year end. Accordingly, the Firm must file audited annual reports with the Commission as of June 30, 2026. Based on the representations and the facts that the Firm has stated in the Request, the staff of the Division of Trading and Markets (“Division”) will not recommend enforcement action to the Commission if the Firm does not file the audited annual reports required under paragraph (d) of Rule 17a-5 for the fiscal year ending June 30, 2026 in the circumstance where the Firm’s audited annual reports filed for the fiscal year ending June 30, 2027 covers the entire period between February 18, 2026 and June 30, 2027. This Division staff position is based strictly on the facts and circumstances stated in the Request. Any different facts or circumstances from those set forth in the Request may require a different response. Furthermore, this response expresses the Division staff’s position regarding enforcement action only and does not purport to express any legal conclusions on the question presented. The Division staff expresses no view with respect to any other questions that the proposed activities may raise, including the applicability of any other federal, state, or foreign laws or self-regulatory organization rules. This position is subject to modification or revocation at any time. Sincerely, Raymond A. Lombardo Assistant Director cc: Michael Mailes, FINRA

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May 20, 2026
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549 tradingandmarkets@sec.gov Mr. Michael Mailes Risk Monitoring Analyst FINRA Michael.Mailes@finra.org Re: Request for Waiver of June 30, 2026 Audit (ACI Capital Markets LLC) Dear Division of Trading and Markets staff, The registration of ACI Capital Markets LLC (the “Firm”) with the Securities and Exchange Commission became effective on February 17, 2026. The Firm was approved as a FINRA member on February 18, 2026. The Firm has not engaged in any securities activities, nor has it earned any revenue to date. The Firm intends to engage in private placements, mergers and acquisitions advisory services, and correspondent clearing firm referrals, through which it would assist client firms in identifying the clearing relationship best suited to their business needs. As such, we would like to request a waiver from our June 30, 2026 annual audit. We would file a 17-month audit covering the period from February 18, 2026 through June 30, 2027, the Firm’s fiscal year end, and then an annual report for each fiscal year thereafter, from July 1st through June 30th. Once the Firm begins conducting a securities business, it will not clear transactions, will not carry customer accounts, will not maintain a correspondent clearing firm relationship and did not effectuate financial transactions with customers in accordance with SEA Rule 15c3-3(k)(2)(i) or (ii). All anticipated

2 securities activities that the Firm is approved by FINRA to conduct would fall under SEC Footnote 74. To the best of our knowledge the Firm is not in violation of any rules or regulations with regards to recordkeeping, financial reporting or net capital requirements. Sincerely, Justin Tallaksen CCO