# ST. GERMAIN SECURITIES, INC. X-17A-5 (2022-03-30) — Broker-dealer annual report

- Company: ST. GERMAIN SECURITIES, INC.
- Form: X-17A-5
- Filed: 2022-03-30
- Period: 2021-12-31
- Accession: 0000200664-22-000003
- CIK: 200664
- File #: 8-04575
- Type: Broker-dealer
- Material weakness: No
- Auditor: WOLF AND COMPANY PC
- Auditor location: Boston, MA
- Contact: Jason Schuck
- Phone: 4137335111
- Signed by: Michael R Matty (President)

Original filing: https://www.sec.gov/Archives/edgar/data/200664/000020066422000003/St_Germain_Securities.pdf

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UNITEDSTATES SECURITIESANDEXCHANGECOMMIS~ON Wasbington,D.C. 20549

### **ANNUAL AUDITED REPORT FORM X-17A-5 PART Ill**

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| Expires:                 | August 31, 2020 |  |
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# SEC FILE NUMBER **s..04575**

**FACING PAGE Information Required of Brokers and Dealers Pursuant** to **Section 17 of the Securities Exchange Act of 1934 and Rule 17a-5 Thereunder** 

| REPORT FOR THE PERIOD BEGINNING01/01/2020              |                                                                                                         | AND ENDING 12/31/2020 |                               |  |
|--------------------------------------------------------|---------------------------------------------------------------------------------------------------------|-----------------------|-------------------------------|--|
|                                                        | MM/DD/YY                                                                                                |                       | MM/DD/YY                      |  |
|                                                        | A. REGISTRANT IDENTIFICATION                                                                            |                       |                               |  |
| NAME OF BROKER-DEALER: St. Germain Securities, Inc.    |                                                                                                         | OFFICIAL USE ONLY     |                               |  |
|                                                        | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.)                                       |                       | FIRMJ.O. NO.                  |  |
| 1500 Main Street                                       |                                                                                                         |                       |                               |  |
|                                                        | (No. and Street)                                                                                        |                       |                               |  |
| Springfield                                            | MA                                                                                                      |                       | 01115                         |  |
| (City)                                                 | (State)                                                                                                 |                       | (Zip Code)                    |  |
| Jason Schuck 413-733-5111                              | NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT<br>B. ACCOUNTANT IDENTIFICATION |                       | (Area Code -Telephone Number) |  |
|                                                        | INDEPENDENT PUBLIC ACCOUNT ANT whose opinion is contained in this Report•                               |                       |                               |  |
| Wolf and Company, P.C.                                 |                                                                                                         |                       |                               |  |
|                                                        | {Name - if individual, state last, first, middle name)                                                  |                       |                               |  |
| 99 High Street                                         | Boston                                                                                                  | MA                    | 02110                         |  |
| (Address)                                              | (City)                                                                                                  | (State)               | (Zip Code)                    |  |
| CHECK ONE:                                             |                                                                                                         |                       |                               |  |
| !certified Public Accountant<br>B<br>Public Accountant |                                                                                                         |                       |                               |  |
|                                                        | Accountant not resident in United States or any of its possessions.<br>FOR OFFICIAL USE ONLY            |                       |                               |  |
|                                                        |                                                                                                         |                       |                               |  |

*\*Claims for exemption.from the requirement that the annual report be cuvered by the opinion of an Independent public accountant must be supported by a statement qffacts and circumstances relied on as the basis/or the exemption. See Section 240.J7a-S(e}{2)* 

> Potential 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.

SEC 1410 (11-05)

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#### **OATH OR AFFIRMATION**

I, Michael R. Matty , swear (or affirm) that, to the best of my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of St. Germain Securities, Inc. -------------------------------------------, as of December31st 2020 , are true and correct. I further swear ( or affirm) that

**neither the company nor any partner, proprietor, principal officer or director has any proprietary interest in any account**  classified solely as th•t of a customer, except as follows: .· **.• ,oi\ih1u,,,, .** 

|  | . . ~,t~. ·F<br>b ".•·,<br>. • •T '.' ~,.,_<br>. "'-''-~<br>.,, • .,<br>.:t.,.1,                                                                  |
|--|---------------------------------------------------------------------------------------------------------------------------------------------------|
|  | ~Q ~-~~,M. Ed'. •-}.'\+JJitt                                                                                                                      |
|  |                                                                                                                                                   |
|  | (.__.,.,-'                                                                                                                                        |
|  | President                                                                                                                                         |
|  | Title                                                                                                                                             |
|  |                                                                                                                                                   |
|  | This report •• contains (check all applicable boxes):                                                                                             |
|  | 0 ( a) Facing Page.                                                                                                                               |
|  | 0 (b) Statement of Financial Condition.                                                                                                           |
|  | 0 (c) Statement of Income (Loss) or, ifthere is other comprehensive income in the period(s) presented, a Statement                                |
|  | of Comprehensive Income (as defined in §210.1-02 of Regulation S•X).                                                                              |
|  | ✓ (d) Statement of Changes in Financial Condition.<br>(e) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors' Capital. |
|  | (f) Statement of Changes in Liabilities Subordinated to Claims of Creditors.                                                                      |
|  |                                                                                                                                                   |
|  | § (g) Computation of Net Capital.<br>(h) Computation for Determination of Reserve Requirements Pursuant to Rule l5c3-3.                           |
|  | (i) Information Relating to the Possession or Control Requirements Under Rule J5c3-3.                                                             |
|  | 0 0) A Reconciliation, including appropriate explanation of the Computation ofNet Capital Under Rule 15c3-l and the                               |
|  | Computation for Determination of the Reserve Requirements Under Exhibit. A of Rule l 5c3-3.                                                       |
|  | 0 (k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of<br>consolidation.           |
|  | ✓ (1) An Oath or Affirmation.                                                                                                                     |

- (m) A copy of the SIPC Supplemental Report.
- (n) A report describing any material inadequacies found to exist or found to have existed since the date of the previous audit.

*\*\*For conditions of corifidenlia/ treatment of certain portions of this filing, see section 240.17a-5(e)(]}.* 

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# St. Germain Securities, Inc. Financial Statements and Supplementary Infonnation Year Ended December 31, 2020

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# **Table of Contents**

| Report of Independent Registered Public Accounting Firm | 1-2 |
|---------------------------------------------------------|-----|
| Financial Statements:                                   |     |
| Statement of Financial Condition                        | 3   |
| Statement of Operations                                 | 4   |
| Statement of Changes in Shareholder's Equity            | 5   |
| Statement of Cash Flows                                 | 6   |
| Notes to Financial Statements                           | 7   |
| Supplementary Information:                              |     |
| Computation of Net Capital Pursuant to Rule 15c3-1      | l2  |
| Report of Independent Registered Public Accounting Firm | 13  |
| Exemption Rep011                                        | 14  |

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# Report of Independent Registered Public Account"ing Firn1

#### To the Board of Directors and Shareholder of St. Gennain Securities, Inc.:

#### *Opinion on the Financial Statements*

We have audited the accompanying statement offinancial condition of St. Gennain Securities, Inc. (the "Company") as of December 31; 2020, and the related statements of operations, changes in shareholder's equity, and cash flows for the year then ended, and the related notes (collectively, refened to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Company, 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.

#### *Bas;sfor Opinion*

These financial statements are the responsibility of the Company's management. Our responsibility is to express an opinion on the Company's fmancial statements based on our audit. We are a public accotmting fim1 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 req1rire 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. The Company is not required *to* have, nor were we engaged to perform, an audit of its internal control over financial reporting. As part of our audit, we are required to obtain an understanding of internal control over financial reporting, but not for the purpose of expressing an opinion on the effectiveness of the Company's internal control over financial reporting. Accordingly, we express no such opinion.

Our audit included performing procedures to assess the risk of material misstatement of the financial statements, whether due to en-or or fraud, and pe1fo1ming procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the fmancial statements. Our audit also included evaluating the acco1mting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for **our opinion.** 

**99 HIGH STREET BOSTON, MA 02110.2320 P** 617~439~97□ 0 **WOLFANDCO.COM** 

i

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#### *SupplemenUIJ}' Information*

The Computation of Net Capital Pursuant to Rule l 5c3-l ("supplementaty infotmation") has been subjected to audit procedures performed in conjunction with the audit of the Company's financial statements. The supplementary information is the responsibility of the Company's management. Our audit procedures included determining whether the supplementary infonnation reconc.iles to the financial statements or the underlying accounting and other records <sup>1</sup>as applicable and performing procedures to test the completeness and accuracy of the information presented in the supplementary information. In fmming our opinion on the supplementary infonnation, \Ve evaluated whether the supplementary information, including its form mid content, is presented in conformity with 17 C.F.R. § 240.l 7a-5. In our opinion, the supplementary information is fairly stated, in all material respects, in relation to the financial statements as a whole.

\Ve have served as the Company's auditor since 2004.

Boston, Massachusetts February 26, 2021

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### Statement of Financial Condition

#### December 31, 2020

**Assets** 

| Cash and cash equivalents<br>Receivable from Broker<br>Prepaid ell.penses<br>Other assets |                                      | \$2,803,720<br>48,942<br>9,379<br>125,000 |
|-------------------------------------------------------------------------------------------|--------------------------------------|-------------------------------------------|
|                                                                                           | Liabilities and Shareholder's Equity | \$?,987,041                               |

| Liabilities:                                          |             |
|-------------------------------------------------------|-------------|
| Due to parent                                         | 99,840      |
| Accrued ell.pe11Ses and other liabilities             | 27,642      |
| Total liabilities                                     | 127,482     |
| Shareholder's equity:                                 |             |
| Common shm-es, \$1 par value, I 00 shares authorized, |             |
| issued and outstanding                                | 790,897     |
| Retained earnings                                     | 2,068,662   |
| Total sbareholder's equity                            | 2,859,559   |
|                                                       |             |
| Total liabilities and shareholder's equity            | \$2,987,041 |

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

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### Statement of Operations

#### Year Ended December *31, 1020*

| Operating revenue:                                 |                 |
|----------------------------------------------------|-----------------|
| Commissions and fees                               | \$<br>1.318,681 |
| lnterest income                                    | 14,216          |
| Mutual fond distribtttion fees                     | 901,744         |
| Realized llild unrealized gain on inveshnents, net | (8,916)         |
| Other income                                       | 312,739         |
| Total operating revenue                            | 2,538,464       |
| Operathig expenses:                                |                 |
| Production costs                                   | 585,209         |
| Salmy and benefits                                 | 723,745         |
| Other operating expenses                           | 669,676         |
| Total operating expense                            | 1,978,630       |
| Income before income taxes                         | 559,834         |
| Income tax provision                               | 146,830         |
| Net income                                         | \$<br>413,004   |

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

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### Statement of Changes in Shareholder's Equity

#### Year Ended December 31, 2020

|                                           | Shares | Common<br>Stock | Retained<br>Earnings | Total        |
|-------------------------------------------|--------|-----------------|----------------------|--------------|
| Shareholder's equity at December 31, 2019 | 100    | S790,897        | S 1,655,658          | S 2,446~555  |
| Net income                                |        |                 | 413,00.)             | 413,00.)     |
| Shareholder's equity at December 31, 2020 | 100    | \$790,897       | \$2,068,662          | \$ 2,859,559 |

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

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### Statement of Cash Flows

#### Year Ended December 31, 2020

| Cash tlO\VS from operating activities:         |                 |
|------------------------------------------------|-----------------|
| Net income                                     | \$<br>413,004   |
| Adjustments to reconcile net n1come to net     |                 |
| cash pro,ided by operatn1g acti\-ities:        |                 |
| Change in operatnog assets and liabilities:    |                 |
| Prepaid expenses                               | 4,021           |
| Due to Parent                                  | 102,944         |
| Receivable from Broker, net                    | 40,037          |
| Accrnecl expenses and other liabilities        | (8,874)         |
| Net cash provided by operatn1g activities      | 551,132         |
| Net increase in cash and cash equivalents      | 551,132         |
| Cash and cash equivalents at beginning of year | 2,252,588       |
| Cash and cash equivalents at end of year       | \$<br>2,803,720 |

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

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i\otes to Financial Statements

December 31, 2020

#### **1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES**

### *Nature of Business*

The financial statements include the accounts of St. Germain Securities, Inc. (the "Company"), a wholly-owned subsidiary ofD.J. St. Germain Company, Inc. ("DJS" or "Parent").

The Company is registered as a broker-dealer with the Securities and Exchange Commission, is a member of the Financial Industry Regulatory Authority ("FINRA") and is licensed as a broker-dealer in all 50 states.

I

I

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The Company claims exemption from the requirements of Rule 15c3-3 under Section (k)(2)(ii) of Rule 15c3-3.

### *Use of Estimates*

The preparation of financial statements in confonnity with accounting principles generally accepted in the United States of America ("GAAP") requires management to make estimates and assumptions that affect the repo1ied amounts of assets and liabilities, the disclosure of contingent assets and liabilities at the date of the financial statements, and the reported amounts of revenues and expenses during the repo1iing period. Actual results could differ from those estimates.

#### *Revenue Recognition*

Revenue from contracts with customers includes commission income, mutual fund distribution fees, and other fees. The recognition and measurement of revenue is based on the assessment of individual contract terms. Significant judgement is required to determine whether performance obligations are satisfied at a point in time or over time; how to allocate transactions prices where multiple performance obligations are identified; when to recognize revenue on the appropriate measure of the Company's progress under the contract and whether constraints on variable consideration should be applied due to uncertain events.

The Company buys and sells securities on behalf of its customers. Each time a customer enters into a buy or sell transaction, the Company c.harges a commission. Commissions and

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#### Notes to Financial Statements

December 31, 2020

#### **SUMMARY OF SIGNIFICANT ACCOU:"ITING POLICIES (continued)**

related clearing expenses are recorded on the trade date (the elate the Company fills the trade order by finding and contracting with a counterpaity and confirms the trade with the customer). The Company believes that the performance obligation is satisfied on the trade date because that is when the underlying financial instrument or purchaser is identified. the pricing is agreed upon and the risks and rewards of ownership have been transferred to/from the customer.

The Company recognizes mutual fi.md income in the period it is received as amounts are not determined and constraint not satisfied until such time.

The Company receives remuneration on customer cash that is treated as an overnight sweep account into FDIC insured deposits. The Company received \$289,227 for the year ended December 31, 2020 which is recorded in the other income on the statement of operations.

#### *Caslz and Cash Equimlellts*

The Company considers all instruments with an original maturity of three months or less when purchased to be cash equivalents.

#### *Receivables*

Amounts receivable from broker-dealers and clearing organizations at December 31, 2020 was \$48,942. The Company considered the need for an allowance for doubtful accounts as of December 31, 2020 and dete1mined none was necessary.

#### *Investments*

Investments owned are recorded at fair value with changes in fair value recorded in earnings. Cost is dete1mined on the specific identification method. Income from investments owned is recorded as earned on an accrual basis. Realized gains and losses are detennined based on the specific identification of the securities sold, and any dividends are recorded on the payment date. There were no investments held as of December 31, 2020.

#### *Fair Value*

Fair value is defined as the price that would be received to sell an asset or paid to transfer a liability (i.e., the exit price) in an orderly transaction between market participants at the measurement date.

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'.\.'otes to Financial Statements

December 31, 2020

#### **SU:VIMARY OF SIGNIFICANT ACCOUNTING POLICIES (continued)**

GA<\P establishes a hierarchal framework which prioritizes and ranks the level of market price observability used in measuring fair value. Observable inputs are those that market pmticipants would use in pricing the asset or liability based on market data obtained from sources independent of the Company. Unobservable inputs reflect the Company's assumptions about the inputs market participants would use in pricing the asset or liability developed based on the best information available in the circumstances. The fair value hierarchy is categorized into three levels based on the inputs as follows:

Level 1 - Inputs are unadjusted quoted prices in active markets for identical assets or liabilities that management has the ability to access at the measurement elate.

Level 2 -Inputs include quoted prices for similar assets and liabilities in active markets, quoted prices for identical or similar assets or liabilities in mm·kets that are not active, inputs other than quoted ptices that are observable for the asset or liability (i.e., interest rates, yield curves, etc.), and inputs that are derived principally from or cotrnborated by observable market data by correlation or other means (market con-oborated inputs).

Level 3 - Inputs include llllobservable inputs that reflect management's assumptions about the assumptions that market participants would use in pricing the asset or liability. Management develops these inputs based on the best information available, including management's own data.

In certain cases, the inputs used to measure fair value may fall into different levels of the fair value hierarchy. In such cases, the level within the fair value hierm·chy is based on the lowest level of input that is significant to the fair value measurement.

#### *Income Taxes*

The Company is part of an affiliated group which files a consolidated tax return. Pursuant to a tax allocation agreement by and amongst the members of the affiliated group, the consolidated tax liability is allocated to the members of the group on the basis of the percentage of the total tax which the tax of such member, if computed on a separate return, would bear to the total amount of the taxes for all members of the group so computed ("separate return liability method").

The Company does not have any uncertain tax positions at December 31, 2020 which require accrual or disclosure. The Company records interest and penalties as pmi of income tax expense. No interest or penalties were recorded for the year ended

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#### Notes to Financial Statements

#### December 31, 2020

#### **SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (concluclccl)**

December 31, 2020. The consolidated DJS income tax returns are subject to review and examination by federal and state taxing authorities. These returns are currently open to audit under applicable statutes of limitations by the Internal Revenue Service generally back to and including 2017.

### *Concentration of Credit Risks*

During the year ended December 31, 2020, the Company had amounts in excess,of \$250,000 in a brokerage account. These balances fluctuate during the year. Amounts are insured by the Securities Investors Protection Corporation ("SIPC") up to \$500,000, of which no more than \$250,000 may be in cash. The Company's principal clearing firm carries additional protection on terms similar to SIPC for brokerage account balances in excess of \$500,000. Management monitors the clearing firm regularly, along with the Company's balances, and seeks to keep this potential risk to a minimum.

#### **2. REGULATORY NET CAPITAL REQUIREMENTS**

As a broker-dealer, the Company is subject to the Securities and Exchange Commission's regulations and operating guidelines, which require the Company to maintain a minimum amount of net capital, as defined, and a ratio of aggregate indebtedness to net capital, as defined, not to exceed 15 to 1. Net capital and the related ratio of aggregate indebtedness to net capital may fluctuate on a daily basis. At December 31, 2020, the Company had net capital of \$2,792,348 which is \$2,692,348 in excess of its required net capital of \$100,000. At December 31, 2020, the Company's ratio of aggregate indebtedness to net capital was 0.046 to **1.** 

The Company is currently exempt from compliance with Rules 15c3-3 and 17a-13 under the Securities Exchange Act of 1934, because it does not hold any customer secmities or customer cash.

#### **3. RELATED PARTY TRANSACTIONS**

Certain expenses incurred are allocated between DJS and the Company pursuant to an agreed-upon allocation percentage based on the nature of the expense. Amounts clue to/from the Parent will fluctuate based on these expense allocations and are reflected on the statement of financial condition as a Due to Parent. Substantially all of the Company's revenue is commissions and fees resulting from transactions with an investment advisor related through common ownership.

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### **St. Germain Securities, Inc;**

-- - --- ------------------------ -----------------

-- ---

#### Notes to Financial Statements

#### December 31, 2020

#### **4. COM:\1IT!VIBNTS**

The Parent is obligated under lease agreements for office space expiring between October 31, 2022 and December 31, 2024 in four locations throughout Massachusetts. The Company's expected share of fi.,ture rent commitments as pmt of the expense sharing agreement is as fol!ows:

Year ended December 31:

| 2021 | 57,661    |
|------|-----------|
| 2022 | 56,296    |
| 2023 | 48,101    |
| 2024 | 34.296    |
|      | \$196,354 |

Total rent expense allocated to the Company for the year ended December 31, 2020 was \$61,123.

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Computation of Net Capital Pursuant *to* Rule 15c 3-1 of the Securities and Exchange Commission

December 31, 2020

#### **Computation of nc** *t* **capital:**

| T ot1I shareholder's equity qualified for net capital                      | \$ 2,859,559         |
|----------------------------------------------------------------------------|----------------------|
| Less: non-allowable assets:<br>Receivable from Broker<br>Prepaid e,q,enses | 1,853<br>\$<br>9,379 |
| Total non-allowable assets<br>Less: 2% Haircut on Money Mm·kets            | 11,232<br>55,979     |
| Net capital                                                                | \$ 2,792,348         |
| Computation of basic net capital requirement:                              |                      |
| Net capital requirment ofreporting broker-dealer                           | \$<br>100,000        |
| Excess net capital                                                         | \$ 2,692,348         |
| Aggregate indebtedness                                                     | \$<br>127,482        |
| Percentage of aggregate indebtedness to net capital                        | 4.6%                 |

f '

TI1ere were no material differences between the above computation ofnet capital and the Company's computation as repmted in the unaudited Pmt II ofForm-17A-5 as of December 31, 2020

See repott of independent registered public accounting firm.

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# Report of Independent Registered Public Accounting Firn1

To the Board of Directors and Shareholder of St. Gerniain Securities, Inc.:

**\Ve have reviev;.'ed management's statements 1 included in the accompanying Exemption Report,**  · in which (a) St. Germain Securities, Inc. (the "Company") claimed an exemption from 17 C.F.R. § 240.15c3-3 underthe following provisions of 17 C.F.R. § 240.15c3-3 (k)(2)(ii) (the "exemption provisions") and (b) the Company stated that it met the identified exemption provisions in 17 C.F.R. § 240. !5c3-3(k) throughout the most recent fiscal year without exception. The **Company's management is: responsible for compliance with the exemption provisio11s and its statements.** 

Our review was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, includes inquiries and other review procedures to obtain evidence about the Company's compliance with the exemption provisions. A review is substantially less in scope than an exan1ination, the objective of which is the expression of an **opinion on manageinent'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 provisions set forth in paragraph (k)(2)(ii) of Rule l 5c3-3 under the Securities Exchange Act of 1934.

Boston, Massachusetts February 26, 2021

**MEMBER OF ALLJNtAL GLOBAL, AN ASSOCIATION OF LEGALLY INDEPENDENT FIRMS**  **99 HIGH STREET BOSTON, MA 0211()-.2320 P 617-439-9700 WOL~ANDCO.COM** 

f I

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#### **St.** Germain Securities, Inc. Exemption Report

St. Gennain Securities, Inc. (the "Company") is a registered broker-dealer subject to Rule l 7a-5 promulgated by the Securities and Exchange Commission (17 C.F.R §240.l 7a-5, "Reports to be made by cert.ain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R § 240.]7a-5(d)(l) and (4). To the best of its knowledge aud belief, the Company states the **foJJoi,ving:** 

**The COmpany clalmed a11 exemption from l 7 G,F.R. § 240.15c3e3 under the following provisions**  of 17 C.F.R. § 240.!Sc3-3:(k)(2)(ii).

The Company met the identified exemption provisions in 17 C.F;R, § 240.15c3-3(k) throughout **the rriost recent fisc·a1 year without exception.** 

**St. Gennain Setattties, tac\_.** 

I, Michael R. Mattv , swear (or affirm) that, to my ]Jest knowledge and

belief, this Exemption Report is true atid con-ect. *---7* ' /4~~\

**Pres-ident**  Title

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**Report of Independent Registered Public Accounting Firm on Applying Agreed-Upon Procedures** 

*To* the Board of Directors of **St. Gennain Securities, Inc. Springfield! :rvrassachusetts** 

We have perfom1ed the procedures included in Rule ! 7a-5( e )( 4) under the Secmities Exchange Act of 1934 and in the Securities Investor Protection Corporation (SIPC) Series 600 Rules, which are enumerated below, and were agreed to by St. Ge1main Securities, Inc., (Company) and the SIPC, solely to assist you and the SIPC in evaluating the Company's compliance with the applicable instructions of the General Assessment Reconciliation (Form SIPC-7) for the year ended December 31, 2020. Management of the Company is responsible for its Form SIPC-7 and for its compliance with those requirements. This agreed-upon procedures engagement was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and in accordance with attestation standards established by the American Institute of Ce1tified Public Accountants. The sufficiency of these procedures is solely the responsibility of those pruties specified in this repmt. Consequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose.

I. Compared the listed assessment payments in Form SIPC-7 with respective cash disbursement records entries.

No differences noted.

2. Compared the Total Revenue amotmts reported on the Amrnal Audited Report Form X-17 A-5 Part Ill for the year ended December 31, 2020, with the Total Revenue amounts repmted in Form SIPC-7 for the year ended December 31, 2020.

No differences noted.

3. Compared any adjustments reported in Form SIPC-7 with supporting schedules and working papers.

No differences noted.

**MEMBER OF ALLINIAL GLOBAL, AN ASSOCIATION OF LEGALLY INDEPENDENT FIRMS**  **99 HIGH STREET BOSTON, MA 02110-2320 P 617-439·9700 \11/0LFANDCO .COM** 

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4. Recalculated the arithmetical accuracy of the calculations reflected in Fonn SIPC-7 and **in the related schedules and \Vorking papers supporting the adjustments.** 

No findings noted.

**5. Compared the amount of any overpayment applied to the CLLITent assessment with the Form SIPC-7 on which it \Vas originalJy computed.** 

1\o overpayment has been applied.

**\Ve were not engaged ta, and did not conduct an examination or a review: the objective of which would be the expression of an opinion or conclusion, respectively, on the Company's compliance**  with the applicable instmctions of the Form SIPC-7 for the year ended December31, *2020.*  **Accordingly, we do not express such an opinion or conclusion. Had \Ve perfomiecl additional procedures~ other matters might have come to our attention that \VOu{d have been rep011ed to you.** 

\*\*\*\*\*\*

This repmt is intended solely for the info1mation and use of the specified parties listed above and is not intended to be and should not be used by anyone other than these specified paities.

Boston, Massachusetts February 26, 2021


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