# FBL MARKETING SERVICES, LLC X-17A-5 (2025-03-28) — Broker-dealer annual report - Company: FBL MARKETING SERVICES, LLC - Form: X-17A-5 - Filed: 2025-03-28 - Period: 2024-12-31 - Accession: 0000078027-25-000001 - CIK: 78027 - File #: 8-15855 - Type: Broker-dealer - Material weakness: No - Auditor: Forvis Mazars, LLP - Auditor location: Kansas City, MO - Contact: Mat Gleason - Phone: 515-225-5556 - Email: mat.gleason@fbfs.com - Website: fbfs.com - Signed by: Mathew E. Gleason (President) Original filing: https://www.sec.gov/Archives/edgar/data/78027/000007802725000001/fblmarketingservices.pdf --- {0}------------------------------------------------ | | UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
ANNUAL REPORTS
FORM X-17A-5 | | OMB Number:
Expires: | 3235-0123
Nov. 30, 2026
Estimated average burden
hours per response 12
SEC FILE NUMBER
8-15855 | |--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------|-------------------------------------------|--------------------------------------------|---------------------------------------------------------------------------------------------------------------| | | PART III
FACING PAGE | | | | | Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934 | | | | | | FILING FOR THE PERIOD BEGINNING ____________________ AND ENDING ___________________________ | 01/01/24
MM/DD/YY | | 12/31/24
MM/DD/YY | | | | A. REGISTRANT IDENTIFICATION | | | | | NAME OF FIRM: FBL Marketing Services, LLC | | | | | | TYPE OF REGISTRANT (check all applicable boxes):
(X) Broker-dealer
( ) Security-based swap dealer
( ) Check here if respondent is also an OTC derivatives dealer
ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. box no.)
5400 University Avenue | | ( ) Major security-based swap participant | | | | | (No. and Street) | | | | | West Des Moines, Iowa 50266 | | | | | | (City) | (State) | | (Zip Code) | | | PERSON TO CONTACT WITH REGARD TO THIS FILING
Mat Gleason | (515) 225-5556 | | Mat.Gleason@fbfs.com | | | (Name) | (Area Code | Telephone Number) | (Email Address) | | | | B. ACCOUNTANT IDENTIFICATION | | | | | INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*
Forvis Mazars, LLP | | | | | | 1201 Walnut St, Suite 1700, Kansas City, MO 64106 | (Name if individual, state last, first, middle name) | | | | | (Address)
10/16/2003 | (City) | (State) | 686 | (Zip Code) | | (Date of Registration with PCAOB)(if applicable) | | | (PCAOB Registration Number, if applicable) | | | | | FOR OFFICIAL USE ONLY | | | | | | | | | OMB APPROVAL OMB Number: 3235-0123 \* 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 for the exemption. See 17 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. {1}------------------------------------------------ | | | Mathew E. Gleason | | | | | | |---------|--------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------|--|--|--|--|--| | | | President
Lowa | | | | | | | | | | | | | | | | | | Notary Public | | | | | | | | | | | | | | | | | | `his filing contains: | | | | | | | | (X) (a) | Statement of Financial Condition | | | | | | | | ( ) (b) | Notes to Statement of Financial Condition | | | | | | | | (X) (c) | Statement of Operations | | | | | | | | (X) (d) | Statement of Cash Flows | | | | | | | | (X) (e) | Statement of Changes in Members' Equity | | | | | | | | ( | Statement of Changes in Liabilities Subordinated to Claims of Creditors | | | | | | | | (X) (g) | Notes to Financial Statements | | | | | | | | (X) (h)
( ) (1) | Computation of Net Capital
Computation of tangible net worth under 17 CFR 240.18a-2 | | | | | | | | ( ) (j) | Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3 | | | | | | | | ( ) (k) | Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR | | | | | | | | | 240.15c3-3 or Exhibit A to 17 CFR 240.18a-4, as applicable | | | | | | | | ( ) (1) | Computation for Determination of PAB Requirements under Exhibit A to § 240.15c3-3 | | | | | | | | | ( ) (m) Information Relating to the Possession or Control Requirements Under Rule 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 in | | | | | | | | (X) (q) | An Oath or Affirmation | | | | | | | ( ) (r) | | Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable | | | | | | | | (X) (S) | Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable | | | | | | | | ( | Independent public accountant's report based on an examination of the statement of financial condition | | | | | | | | | (X) (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 | | | | | | | | | ( ) (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 | | | | | | | | | (X) (w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-5 or 17
CFR 240.18a-7, as applicable | | | | | | | | | ( ) (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-le or 17 CFR | | | | | | | | | 240.17a-12, as applicable | | | | | | | | | ( ) (y) Report describing any material inadequacies found to have existed since the date of the previous | | | | | | | | | audit, or a statement that no material inadequacies exist, under 17 CFR 240.17a-12(k) | | | | | | | | (z) (z) = | Other: | | | | | | | | | | | | | | | {2}------------------------------------------------ # Financial Statements and Supplemental Information Year Ended December 31, 2024 # Contents | Report of Independent Registered Public Accounting Firm 1 | | | | | | |----------------------------------------------------------------------------------------|--|--|--|--|--| | Audited Financial Statements | | | | | | | Statement of Financial Condition 3 | | | | | | | Statement of Operations 4 | | | | | | | Statement
5 | | | | | | | Statement of Cash Flows 6 | | | | | | | Notes to Financial Statements 7 | | | | | | | Supplemental Information | | | | | | | Supporting Schedules:
Schedule I
Computation of Net Capital Under Rule 15c3-1 14 | | | | | | {3}------------------------------------------------ ![](_page_3_Picture_1.jpeg) # **Report of Independent Registered Public Accounting Firm** Board of Managers FBL Marketing Services, LLC West Des Moines, Iowa #### *Opinion on the Financial Statements* We have audited the accompanying statement of financial condition of FBL Marketing Services, LLC (the "Company") as of December 31, 2024, the related statements of operations, changes in members' equity, and cash flows for the year then ended, and the related notes (collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Company as of December 31, 2024, and the results of its operations and its cash flows for the year then ended in conformity with accounting principles generally accepted in the United States of America. ## *Basis for Opinion* These financial statements are the responsibility of the Company's management. Our responsibility is to express an opinion on the Company's financial statements based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) ("PCAOB") and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. 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 material misstatement, whether due to error or fraud. Our 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. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall financial statement presentation. We believe that our audit provides a reasonable basis for our opinion. ## *Supplemental Information* The Computation of Net Capital Under Rule 15c3-1 of the Securities and Exchange Commission ("supplemental information") has been subjected to audit procedures performed in conjunction with the audit of the Company's financial statements. The supplemental information is the responsibility of the Company's management. Our 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. {4}------------------------------------------------ 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 CFR §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. We have served as the Company's auditor since 2024. **Kansas City, Missouri March 27, 2025** {5}------------------------------------------------ # Statement of Financial Condition # December 31, 2024 #### Assets | FBL Marketing Services, LLC | | |---------------------------------------------|-----------------------------------------| | Statement of Financial Condition | | | December 31, 2024 | | | Assets
Cash and cash equivalents: | | | Cash
Short-term investments | \$
187,223
2,077,633
2,264,856 | | Accounts receivable | 918,589 | | Due from Farm Bureau Life Insurance Company | 6,321 | | Prepaid expense | 306,438 | | Other assets | 59,939 | | Total assets | \$
3,556,143 | | Liabilities and members' equity | | | Due to FBL Financial Group, Inc. | \$
365,483 | | Accounts payable and accrued expenses | 711,538 | | Total liabilities | 1,077,021 | | Members' equity: | | | Series A member's equity | 2,475,499 | | Series C member's equity | 3,623 | | Total members' equity | 2,479,122 | | Total liabilities and members' equity | \$
3,556,143 | See accompanying notes. {6}------------------------------------------------ # Statement of Operations # December 31, 2024 | FBL Marketing Services, LLC | | | | |----------------------------------------|-------------------|--|--| | Statement of Operations | | | | | December 31, 2024 | | | | | Revenues: | | | | | Revenues from contracts with customers | \$
9,685,428 | | | | Dividend and interest income | 647,330 | | | | Other | 839 | | | | Total revenues | 10,333,597 | | | | Expenses: | | | | | Regulatory fees and expenses | 426,606 | | | | Professional service fee expenses | 545,615 | | | | Salaries and related expenses | 3,428,585 | | | | Commission and bonus expenses | 5,065,417 | | | | Software expenses | 703,008 | | | | Other operating expenses | 1,239,604 | | | | Total expenses | 11,408,835 | | | | Net loss | \$
(1,075,238) | | | | See accompanying notes. | | | | {7}------------------------------------------------ | | Series A
Member's
Equity | Series C
Member's
Equity (Deficit) | Total
Members'
Equity | |-----------------------------------------------------|---------------------------------|-------------------------------------------|-----------------------------| | Balance at January 1, 2024
Capital contributions | \$ 3.354.946 | မှ
(10,641)
210.055 | \$ 3.344.305
210.055 | | Net loss
Balance at December 31, 2024 | (879,447)
\$ 2,475,499 | (195,791)
ಳು
3.623 | (1,075,238)
\$ 2,479,122 | {8}------------------------------------------------ # Statement of Cash Flows # Year Ended December 31, 2024 | FBL Marketing Services, LLC | | |-------------------------------------------------------|-------------------| | Statement of Cash Flows | | | Year Ended December 31, 2024 | | | Operating activities | | | Net loss | \$
(1,075,238) | | Adjustments to reconcile net loss to net cash used in | | | operating activities: | | | Changes in operating assets and liabilities: | | | Accounts receivable | (202,323) | | Due from Farm Bureau Life Insurance Company | 121 | | Prepaid expense | (5,848) | | Due to FBL Financial Group, Inc. | 20,826 | | Accounts payable and accrued expenses | (2,142) | | Other assets | 25,913 | | Net cash used in operating activities | (1,238,691) | | Financing Activities | | | Capital contributions | 210,055 | | Net cash provided by financing activities | 210,055 | | Decrease in cash and cash equivalents | (1,028,636) | | Cash and cash equivalents at beginning of year | 3,293,492 | | Cash and cash equivalents at end of year | \$
2,264,856 | See accompanying notes. {9}------------------------------------------------ # Notes to Financial Statements # December 31, 2024 # 1. Significant Accounting Policies # Organization FBL Marketing Services, LLC (the Company) engages in sales of debt and equity securities, retail mutual funds and variable universal life products issued by an unrelated insurance company. The Company also provides services associated with previously sold variable universal life and annuity products offered by Farm Bureau Life Insurance Company (Farm Bureau Life), which is a wholly owned subsidiary of FBL Financial Group, Inc., and other unaffiliated companies. accepted in the United States of America (GAAP) requires management to make estimates and The Company has one Series A member, FBL Financial Group, Inc. and one Series C member, United Farm Family Life Insurance Company (collectively, the Members). # Use of Estimates The preparation of financial statements in conformity with accounting principles generally assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates. For the purpose of the statement of cash flows, the Company considers investments in money market funds, where the underlying investments are of a short-term nature, to be cash Fair value is based on an exit price, which is the price that would be received to sell an asset or measurement date. GAAP establishes a hierarchal disclosure framework for fair value that ranks the level of market price observability used in measuring financial instruments at fair value into # Cash and Cash Equivalents equivalents. # Fair Value paid to transfer a liability in an orderly transaction between market participants at the three levels. - Level 1 Fair values are based on unadjusted quoted prices in active markets for identical assets or liabilities. - Level 2 Fair values are based on inputs, other than quoted prices from active markets, that are observable for the asset or liability, either directly or indirectly. {10}------------------------------------------------ # Notes to Financial Statements (continued) Level 3 Fair values are based on significant unobservable inputs for the asset or liability. All investments included in the statement of financial condition at December 31, 2024 are in money market funds that are carried at cost, which approximates fair value. These investments are based upon daily quoted prices, and therefore are considered Level 1. There were no transfers into or out of Level 3 during 2024. which the financial statements were issued. There were no events that occurred that were required to be recognized or disclosed in the financial statements. 2. Revenues from Contracts with Customers revenue type and a reconciliation to total revenues in the Statement of Operations: ## Subsequent Events | Subsequent Events | | | |-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------|--| | The Company has evaluated the financial statements for subsequent events through the date | | | | | | | | The following table provides a disaggregation of revenue from contracts with customers by
revenue type
and a reconciliation to total revenues in the Statement of Operations: | | | | | Year ended | | | Revenue | December 31, 2024 | | | Asset-based fees | \$
4,799,633 | | | Mutual fund and other securities sales commissions | 3,011,979 | | | Variable annuity and life insurance commissions | 1,797,510 | | | Registered representative fees | 76,306 | | | Total revenues from contracts with customers | 9,685,428 | | | Dividend and interest income | 647,330 | | | Other miscellaneous revenues | 839 | | | Revenues as included in the Statement of Operations | \$
10,333,597 | | | The following discussion describes the nature, timing and uncertainty of revenues and cash flows
Asset-based fees
The Company has entered into agreements with several organizations to earn fees for servicing
and distribution of retail mutual funds
processing purchases and redemptions,
advertising,
Company receives asset-based
fees monthly or quarterly for satisfying the performance | and mutual funds included in proprietary and unaffiliated
and compensation for selling shares. The | | | obligations, which
are based on a percentage of net assets maintained. The Company does
recognize revenue for
these fees until amounts are known as the related revenue is highly | not | | | | | | ## Asset-based fees {11}------------------------------------------------ # Notes to Financial Statements (continued) uncertain and susceptible to factors outside of control. Such factors include market value of assets under management and the length of time investors hold their accounts. Mutual fund and other securities sales commissions The Company has entered into agreements with several organizations to sell mutual funds and other securities to its customers. The related performance obligation is the successful sale of mutual fund or security assets. The Company recognizes mutual fund and other securities sales commission revenue at the point in time the performance obligation has been satisfied, which is the trade date. ## Variable annuity and life insurance commissions The Company has agreements with Farm Bureau Life and other unaffiliated insurance companies to earn renewal commissions for servicing variable annuity and variable universal life insurance policies, which are closed blocks of business. The Company also has an agreement with an unrelated insurance company to sell and service variable universal life policies. performance obligations are for the initial sale of a policy and subsequent ongoing servicing of the policies. The Company receives consideration daily, weekly and monthly and recognizes revenue for these commissions when amounts are known. The Company does not recognize revenue for these fees until amounts are known as the revenue the Company will be entitled to is include length of time policies remain active and the amount of additional premiums paid by the policyholder. The Company has agreements with Farm Bureau Life and an unrelated insurance company to registered representatives. The Company does not recognize revenue for these fees until amounts ## Registered representative fees provide compliance, supervisory, and accounting services for a closed block of proprietary obligations include those services for maintaining the policies. The Company receives registered representative fees monthly based on a percentage of renewal sales commissions paid to are known as the revenue the Company will be entitled to is highly uncertain and susceptible to active and the amount of additional premiums paid by the policyholder. Receivables from contracts with customers were \$861,271 at December 31, 2024 and were recorded in accounts receivable in the statement of financial condition. Costs to fulfill the contracts with customers include commissions paid to agents for sales and servicing of the related mutual fund assets and insurance products. These costs relate to performance obligations already satisfied and are expensed when incurred. {12}------------------------------------------------ # Notes to Financial Statements (continued) # 3. Income Taxes The Company has elected to treat each of its individual Series as a separate disregarded entity for federal and state income tax purposes. As such, the taxable income or loss of each Series is included in the income tax returns of its respective Member and the Company is not subject to entity-level federal or state income taxes. # 4. Retirement and Compensation Plans The Company participates with affiliates and an unaffiliated employer in a multiemployer defined benefit pension plan. The Company and affiliates have adopted a policy allocating their share of required contributions between themselves, generally on a basis of time incurred by the \$41,798 in 2024. The Company participates with affiliates and unaffiliated employers in a 401(k) defined contribution plan which covers substantially all employees. Employee contributions are matched and certain employees receive an additional discretionary contribution. The Company and affiliates allocate these expenses in a manner consistent with pension expense discussed above. related to the plan aggregated to \$217,597 in 2024. # 5. Regulatory Requirements The Company is subject to the Securities and Exchange Commission (SEC) uniform net capital rule (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 therein, shall not exceed 15 to 1. Net capital and the related net capital ratio may fluctuate on a daily basis. At December 31, 2024, the Company had defined net capital of \$1,491,258 which was \$1,419,457 in excess of its required net capital of \$71,801. The C aggregate indebtedness to net capital ratio was 0.72 to 1 at December 31, 2024. The Company is exempt from maintaining a special reserve bank account under Rule 15c3-3. # 6. Limited Liability Company Agreement The Limited Liability Company Agreement approved by the Members outlines the capital structure of the Company, capital contributions to be made by the Members, allocations of revenues and expenses to the Members, and distributions to the Members. Interests in the Company are divided into Series, with the interest of each Member constituting a separate Series. The Company is authorized to issue 100 Series. The holder of Series A interest, referred to as the Principal Member, is the only Member with voting rights for the Company. All other members are Associate Members. {13}------------------------------------------------ # Notes to Financial Statements (continued) Associate Members are allowed to conduct business relating only to the sale of variable life insurance, variable annuity, and mutual fund products, which have been approved by the Board of Managers for distribution through the Company. A separate capital account has been established for each Member and will be established for each each calendar quarter for: (a) the operations; (b) the amount of additional capital contributions by that Member during the quarter; (c) all costs and expenses directly incurred by that Member and all costs and expenses allocated (d) the amount of all distributions made to the Member during the quarter. The amount of minimum required capital per the Limited Liability Company Agreement for each associate Member is currently \$50,000. Members may be called upon for additional capital contributions in certain situations, including the necessity to maintain minimum regulatory and required capital requirements. Distributions may be made to the Principal Member at the discretion of the Board of Managers of the Company. Distributions may be made to an Associate Member within 30 days after the end of each calendar quarter, provided that such distribution would not c capital balance to decline below the minimum required capital. Associate Members may terminate their Series at any time, so long as the balance in their capital account is greater than zero. The Board of Managers may also terminate the Series of any nimum required capital and the Associate Member has failed to honor a capital call for the shortfall. ## 7. Related-Party Transactions The Company had entered into an agreement with Farm Bureau Life to sell variable universal life and variable annuity products. This agreement provides that Farm Bureau Life compensates the Company for all commissions paid to its registered representatives. Although registered representatives of the Company are no longer selling new business under this agreement, the Company continues to collect service fee commissions on renewal premiums associated with these policies. In addition, Farm Bureau Life agrees to pay the Company a registered representative fee to cover the costs and expenses associated with facilitating variable product sales. Under this agreement, revenues earned by the Company totaled \$1,755,783 in 2024, of which the registered representative commission expenses totaled \$1,594,180 in 2024. The Company participates in a management agreement with FBL Financial Group, Inc. Under this agreement, FBL Financial Group, Inc. provides general business, administrative analysis, {14}------------------------------------------------ # Notes to Financial Statements (continued) and management services to the Company. The Company incurred management fee expenses under this contract totaling \$28,509 in 2024. General expenses consist primarily of salaries and related expenses, travel, and occupancy costs. These expenses are allocated from FBL Financial Group, Inc., to its affiliated companies on the basis of cost and time studies that are updated annually. Aggregate expenses incurred by the Company under this agreement were \$5,886,189 in 2024. In the normal course of business, the Company may be involved in litigation in which damages are alleged that are substantially in excess of contractual policy benefits or certain other During a routine examination by the Financial Industry Regulatory Authority (FINRA) in 2023, ## 8. Commitments and Contingencies agreements. the examination team cited exceptions surrounding Regulation Best Interest, Form CRS, monitoring employees outside brokerage accounts, and supervision over these activities. These findings were subsequently forwarded to FINRA Enforcement in 2024. The Company responded with action items to address the exceptions and as of December 31, 2024, the enforcement action remains open. Though a loss is reasonably possible, a range of such penalties could not be estimated as of December 31, 2024. The Company is not aware of any other claims threatened or pending against FBL Marketing Services, LLC for which a material loss is reasonably possible. 9. Segments The Company functions as a single operating segment offering a variety of third party manufactured investment products as detailed in Note 1. The President of the Company acts as the Chief Operating Decision Maker. The President along with other members of the management team primarily rely on net income/loss as reflected in the Statement of Operations, as well as the capital position as reflected in the Statement of Financial Condition to make strategic and other operating decisions. Neither of these measures are tracked or monitored on an individual investment product basis. {15}------------------------------------------------ Supplemental Information {16}------------------------------------------------ # Schedule I - Computation of Net Capital Under Rule 15c3-1 #### Computation of Net Capital | | FBL Marketing Services, LLC
Schedule I -
Computation of Net Capital | | Under Rule 15c3-1 | | |----------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------|-------------------------|---------------------------------------------------------------------| | | | | | | | | December | 31, 2024 | | | | 1.
2.
3.
4.
A.
B.
5.
6.
A.
B.
C.
D.
7.
8.
9.
A.
B.
C.
D. | Computation of Net Capital
Total ownership equity from Statement of Financial
Condition
Deduct ownership equity not allowable for Net Capital
Total ownership equity qualified for Net Capital
Add:
Liabilities subordinated to claims of general
creditors allowable in computation of net capital
Other deductions or allowable credits
Total capital and allowable subordinated liabilities
Deductions and/or charges:
Total non
allowable assets from Statement of
Financial Condition (Notes B and C):
1.
Accounts receivable
2.
Due from Farm Bureau Life Insurance Company
3.
Prepaid expenses
4.
Other assets
Secured demand note deficiency
Commodity futures contracts and spot
commodities
proprietary capital charges
Other deductions and/or charges
Other additions and/or allowable credits
Net capital before haircuts on securities positions
Haircuts on securities [computed, where applicable,
pursuant to 15c3-1(f)]:
Contractual securities commitments
Subordinated securities borrowings
Trading and investment securities:
1.
Exempted securities
2.
Debt securities
3.
Options
4.
Other securities
Undue concentration | \$
573,613
6,321
306,438
59,939 | \$
946,311
41,553 | \$
2,479,122
2,479,122
2,479,122
(946,311)
1,532,811 | {17}------------------------------------------------ # Schedule I - Computation of Net Capital Under Rule 15c3-1 (continued) #### Computation of Basic Net Capital Requirement Part A | FBL Marketing Services, LLC | | |-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------| | | | | Computation of Basic Net Capital Requirement
Part A | | | 11.
Minimum net capital required (6-2/3% of line 19)
12.
Minimum dollar net capital requirement of reporting broker or
dealer and minimum net capital requirement of subsidiaries
computed in accordance with Note (A)
13.
Net capital requirement (greater of line 11 or 12)
14.
Excess net capital (line 10 less 13)
15.
Net capital less greater of 10% of line 19 or 120% of line 12 | \$
71,801
5,000
71,801
1,419,457
1,383,556 | | Computation of Aggregate Indebtedness | | | 16.
Total A.I. liabilities from Statement of Financial Condition
17.
Add:
\$
A.
Drafts for immediate credit
B.
Market value of securities borrowed for which no equivalent
value is paid or credited
C.
Other unrecorded amounts
19.
Total aggregate indebtedness
20.
Percentage of aggregate indebtedness to net capital
(line 19 ÷ by line 10)
21.
Percentage of debt to debt-equity total computed in
accordance with Rule 15c3-1(d) | 1,077,021
1,077,021
72.22% | | Notes:
(A)
The minimum net capital requirement should be computed by adding the minimum dollar net capital
requirement of the reporting broker dealer and, for each subsidiary to be consolidated, the greater of:
1.
Minimum dollar net capital requirement, or
2.
6 2/3% of aggregate indebtedness or 2% of aggregate debits if alternative method is used.
(B)
Do not deduct the value of securities borrowed under subordination agreements or secured demand
note covered by subordination agreements not in satisfactory form and the market values of
memberships in exchanges contributed for use of Company (contra to item 1740) and partners
securities that
were included in non-allowable assets.
(C)
For
reports filed pursuant to paragraph (d) of Rule 17a-5, respondent should provide a list of material
non allowable assets. | | | There are no differences between the computation of net capital under Rule 15c3-1 included in
Form X-17A-5 Part IIA filing as of December
31, 2024. | | ## Notes: - requirement of the reporting broker dealer and, for each subsidiary to be consolidated, the greater of: - - - note covered by subordination agreements not in satisfactory form and the market values of memberships in exchanges contributed for use of Company (contra to item 1740) and partners - non allowable assets. {18}------------------------------------------------ ![](_page_18_Picture_1.jpeg) # **Report of Independent Registered Public Accounting Firm** To the Board of Managers FBL Marketing Services, LLC West Des Moines, Iowa We have reviewed management's statements, included in the accompanying *Exemption Report*, in which (1) FBL Marketing Services, LLC (the "Company") claimed an exemption from 17 CFR §240.15c3-3 under the following provision of 17 CFR §240.15c3-3: (k)(2)(ii) (the "exemption provision") and (2) the Company stated that the Company met the identified exemption provision throughout the most recent fiscal year, except as noted in Exhibit A to the exemption report. We have also reviewed management's statements, included in the accompanying *Exemption Report*, in which the Company is also filing the *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 effecting securities transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company and the Company stated it (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers (other than money or other consideration received and promptly transmitted in compliance 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 are payable to the issuer or its agent and not 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, except as noted in Exhibit B to the exemption report. The Company's management is responsible for compliance with the exemption provision, and for compliance with provisions of Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. §240.17a-5 and its statements. Our 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 the Company's compliance with 17 C.F.R. §240.15c3-3. 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, 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 above for them to be fairly stated, in all material respects, based on the conditions set forth in paragraph (k)(2)(ii) of Rule 15c3-3 under the *Securities Exchange Act of 1934* and 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. **Kansas City, Missouri March 27, 2025** {19}------------------------------------------------ {20}------------------------------------------------ ### **Exhibit A FBL Marketing Services, LLC** There were 369 instances in which the Company failed to promptly transmit funds received during the period January 1, 2024 through December 31, 2024 related to 17 C.F.R. § 240.15c3-3(k)(2)(ii). There are 329 instances included below where the Company relies upon a July 19, 2016 SEC No-Action Letter written by Michael Macchiaroli) that indicates FINRA will not recommend enforcement action if a broker/dealer fails to transmit a customer's check by noon the next business day after receipt if the purpose for holding the check is to complete broker/dealer account opening process in compliance with FINRA rules. | | # of | | | |-----------|-----------|-----------|-------------------| | Date | Instances | Date | # of
Instances | | 1/6/2024 | 2 | 3/21/2024 | 2 | | 1/19/2024 | 1 | 3/25/2024 | 4 | | 1/24/2024 | 2 | 3/26/2024 | 2 | | 1/31/2024 | 2 | 4/1/2024 | 2 | | 2/1/2024 | 3 | 4/2/2024 | 1 | | 2/5/2024 | 3 | 4/4/2024 | 2 | | 2/6/2024 | 2 | 4/5/2024 | 1 | | 2/7/2024 | 2 | 4/8/2024 | 5 | | 2/9/2024 | 1 | 4/11/2024 | 2 | | 2/12/2024 | 3 | 4/12/2024 | 2 | | 2/13/2024 | 4 | 4/15/2024 | 7 | | 2/16/2024 | 5 | 4/16/2024 | 4 | | 2/20/2024 | 21 | 4/17/2024 | 3 | | 2/21/2024 | 1 | 4/18/2024 | 3 | | 2/26/2024 | 2 | 4/19/2024 | 2 | | 2/27/2024 | 1 | 4/22/2024 | 4 | | 2/28/2024 | 1 | 4/29/2024 | 3 | | 2/29/2024 | 4 | 4/30/2024 | 1 | | 3/1/2024 | 2 | 5/1/2024 | 3 | | 3/4/2024 | 4 | 5/3/2024 | 1 | | 3/5/2024 | 1 | 5/6/2024 | 1 | | 3/7/2024 | 1 | 5/8/2024 | 2 | | 3/8/2024 | 1 | 5/9/2024 | 1 | | 3/11/2024 | 2 | 5/10/2024 | 1 | | 3/14/2024 | 2 | 5/13/2024 | 2 | | 3/15/2024 | 1 | 5/14/2024 | 1 | | 3/18/2024 | 4 | 5/17/2024 | 2 | | 3/19/2024 | 1 | 5/20/2024 | 2 | #### **Delay in Transmitting Funds:** {21}------------------------------------------------ #### **Delay in Transmitting Funds (continued):** | | # of | | # of | |-------------------|----------------|------------------|----------------| | Date
5/22/2024 | Instances
1 | Date
9/4/2024 | Instances
2 | | 5/23/2024 | 1 | 9/9/2024 | 2 | | 5/24/2024 | 1 | 9/11/2024 | 1 | | 5/28/2024 | 5 | 9/12/2024 | 1 | | 5/29/2024 | 1 | 9/13/2024 | 1 | | 5/30/2024 | 2 | 9/16/2024 | 3 | | 6/3/2024 | 3 | 9/17/2024 | 1 | | 6/7/2024 | 1 | 9/18/2024 | 1 | | 6/10/2024 | 1 | 9/20/2024 | 2 | | 6/12/2024 | 2 | 9/23/2024 | 1 | | 6/13/2024 | 1 | 9/24/2024 | 1 | | 6/17/2024 | 2 | 9/26/2024 | 1 | | 6/18/2024 | 2 | 9/30/2024 | 4 | | 6/19/2024 | 2 | 10/2/2024 | 2 | | 6/20/2024 | 1 | 10/7/2024 | 5 | | 6/21/2024 | 1 | 10/8/2024 | 1 | | 6/24/2024 | 2 | 10/14/2024 | 1 | | 6/28/2024 | 1 | 10/15/2024 | 4 | | 7/1/2024 | 2 | 10/21/2024 | 3 | | 7/5/2024 | 2 | 10/22/2024 | 1 | | 7/10/2024 | 2 | 10/28/2024 | 2 | | 7/19/2024 | 1 | 10/29/2024 | 1 | | 7/22/2024 | 2 | 10/31/2024 | 2 | | 7/24/2024 | 1 | 11/4/2024 | 2 | | 7/26/2024 | 1 | 11/6/2024 | 1 | | 7/29/2024 | 2 | 11/7/2024 | 1 | | 7/30/2024 | 1 | 11/8/2024 | 3 | | 7/31/2024 | 1 | 11/12/2024 | 1 | | 8/6/2024 | 2 | 11/14/2024 | 2 | | 8/8/2024 | 2 | 11/18/2024 | 4 | | 8/12/2024 | 56 | 11/19/2024 | 2 | | 8/13/2024 | 2 | 11/21/2024 | 1 | | 8/15/2024 | 1 | 11/25/2024 | 2 | | 8/16/2024 | 12 | 12/2/2024 | 5 | | 8/19/2024 | 5 | 12/4/2024 | 1 | | 8/22/2024 | 2 | 12/5/2024 | 2 | | 8/26/2024 | 1 | 12/6/2024 | 2 | | 9/3/2024 | 1 | 12/9/2024 | 3 | {22}------------------------------------------------ #### **Delay in Transmitting Funds (continued):** | | # of | | |-----------------|-----------|--| | Date | Instances | | | 12/11/2024 | 1 | | | 12/16/2024 | 6 | | | 12/18/2024 | 2 | | | 12/23/2024 | 2 | | | 12/26/2024 | 3 | | | 12/27/2024 | 4 | | | 12/30/2024 | 2 | | | Total Instances | 369 | | | | | | {23}------------------------------------------------ ### **Exhibit B FBL Marketing Services, LLC** There were 67 instances in which the Company failed to promptly transmit funds received during the period January 1, 2024 through December 31, 2024 related to Footnote 74 of the SEC Release No. 34- 70073 adopting amendments to 17 C.F.R. § 240.17a-5. There are 7 instances included below where the Company relies upon a July 19, 2016 SEC No-Action Letter written by Michael Macchiaroli) that indicates FINRA will not recommend enforcement action if a broker/dealer fails to transmit a customer's check by noon the next business day after receipt if the purpose for holding the check is to complete broker/dealer account opening process in compliance with FINRA rules. ## **Delay in Transmitting Funds:** | | # of | | # of | |-----------|-----------|-----------------|-----------| | Date | Instances | Date | Instances | | 1/8/2024 | 3 | 9/11/2024 | 1 | | 1/16/2024 | 1 | 10/7/2024 | 1 | | 1/18/2024 | 3 | 10/24/2024 | 1 | | 1/25/2024 | 1 | 10/28/2024 | 1 | | 2/9/2024 | 1 | 10/29/2024 | 2 | | 2/12/2024 | 1 | 11/25/2024 | 1 | | 2/20/2024 | 2 | 12/12/2024 | 1 | | 2/26/2024 | 4 | 12/18/2024 | 1 | | 3/4/2024 | 3 | 12/20/2024 | 1 | | 3/7/2024 | 1 | 12/23/2024 | 2 | | 3/11/2024 | 1 | 12/27/2024 | 2 | | 3/19/2024 | 1 | 12/30/2024 | 2 | | 4/16/2024 | 6 | 12/31/2024 | 3 | | 4/18/2024 | 1 | Total Instances | 67 | | 4/19/2024 | 1 | | | | 5/13/2024 | 1 | | | | 5/17/2024 | 1 | | | | 6/4/2024 | 4 | | | | 6/10/2024 | 3 | | | | 7/8/2024 | 1 | | | | 7/29/2024 | 1 | | | | 8/6/2024 | 1 | | | | 8/23/2024 | 1 | | | | 8/27/2024 | 1 | | | | 8/30/2024 | 1 | | | | 9/3/2024 | 1 | | | | 9/9/2024 | 2 | | | Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.