# SECURIAN FINANCIAL SERVICES, INC. X-17A-5 (2020-02-28) — Broker-dealer annual report

- Company: SECURIAN FINANCIAL SERVICES, INC.
- Form: X-17A-5
- Filed: 2020-02-28
- Period: 2019-12-31
- Accession: 0000746670-20-000001
- CIK: 746670
- File #: 8-31955
- Material weakness: No
- Auditor: CROWE LLP
- Auditor location: New York, NY
- Contact: Lisa Carriere
- Phone: 651-665-3045
- Signed by: George I. Connolly (President & CEO)

Original filing: https://www.sec.gov/Archives/edgar/data/746670/000074667020000001/SFSfinal2a.pdf

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Financial Statements and Supplementary Schedules (with report of independent registered public accounting firm thereon)

December 31, 2019

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|                                                                                          | UNITED STATES<br>SECURITIES ANDEXCHANGE COMMISSION<br>Washington, D.C. 20549                                                                          | Expires:            | OMB APPROVAL<br>OMB Number:<br>3235-0123<br>August 31, 2020<br>Estimated average burden |
|------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------|-----------------------------------------------------------------------------------------|
| ANNUAL AUDITED REPORT<br>FORM X-17A-5<br>PART III                                        |                                                                                                                                                       |                     | hours per response  12.00<br>SEC FILE NUMBER<br>8                                       |
|                                                                                          | FACING PAGE<br>Information Required of Brokers and Dealers Pursuant to Section 17 of the<br>Securities Exchange Act of 1934 and Rule 17a-5 Thereunder |                     |                                                                                         |
| REPORT FOR THE PERIOD BEGINNING 01/01/19                                                 |                                                                                                                                                       | AND ENDING 12/31/19 |                                                                                         |
|                                                                                          | MM/DDYYY                                                                                                                                              |                     | MM/DD/YY                                                                                |
|                                                                                          | A. REGISTRANT IDENTIFICATION                                                                                                                          |                     |                                                                                         |
| NAME OF BROKER-DEALER: Securian Financial Services, Inc.                                 |                                                                                                                                                       |                     | OFFICIAL USE ONLY                                                                       |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.)                        |                                                                                                                                                       |                     | FIRM I.D. NO.                                                                           |
| 400 Robert Street North                                                                  |                                                                                                                                                       |                     |                                                                                         |
|                                                                                          | (No. and Street)                                                                                                                                      |                     |                                                                                         |
| Saint Paul                                                                               | MN                                                                                                                                                    | 55101               |                                                                                         |
| (Caty)                                                                                   | (State)                                                                                                                                               | (Zip Code)          |                                                                                         |
| NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT<br>Lisa Carriere |                                                                                                                                                       | 651-665-3045        |                                                                                         |
|                                                                                          |                                                                                                                                                       |                     | (Area Code - Telephone Number)                                                          |
|                                                                                          | B. ACCOUNTANT IDENTIFICATION                                                                                                                          |                     |                                                                                         |
| INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report®<br>Crowe LLP    |                                                                                                                                                       |                     |                                                                                         |
|                                                                                          | (Name - if individual, state Sast, first, middle mane)                                                                                                |                     |                                                                                         |
| 488 Madison Ave, Floor 3                                                                 | New York                                                                                                                                              | NY                  | 10022                                                                                   |
| (Address)                                                                                | (City)                                                                                                                                                | (54me)              | (Zip Code)                                                                              |
| CHECK ONE:<br>Certified Public Accountant<br>Public Accountant                           | Accountant not resident in United States or any of its possessions.                                                                                   |                     |                                                                                         |
|                                                                                          | FOR OFFICIAL USE ONLY                                                                                                                                 |                     |                                                                                         |
|                                                                                          |                                                                                                                                                       |                     |                                                                                         |
|                                                                                          |                                                                                                                                                       |                     |                                                                                         |

\*Claims for exemption from the requirement that the armusic operal by the opinion of an ine basis occountent public accountant

SEC 1410 (11-05)

Potential persons who are to respond to the collection of
information contained in this form are not required to responsive

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## OATH OR AFFIRMATION

I. George I. Connolly \_, swear (or affirm) that, to the best of my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of Securian Financial Services, Inc. Inc.

of December 31 20 19 are true and correct. I further swear (or affirm) that neither the company nor any partner, principal officer or director has any proprietary interest in any account classified solely as that of a customer, except as follows:

agra Notary Public This report \*\* contains (check all applicable boxes): (a) Facing Page.

(b) Statement of Financial Condition. 1

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- (c) Statement of Income (Loss) or, if there is other compratensive 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.
- বাবা (e) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors' Capital.
- (f) Statement of Changes in Liabilities Subordinated to Claims of Creditors.
- 1 (g) Computation of Net Capital.
- (h) Computation for Determination of Reserve Requirements Pursuant to Rule 1503-3.
- (i) Information Relating to the Possession or Control Requirements Under Rule 15c3-3.
- 0 () A Reconcelliation, including appropriate explanation of tie Computation of Net Capital Under Rule 15c3-1 and the Computation for Determination of the Reserve Requirements Under Exhibit A of Rule 15c3-3.
- O (k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of consolidation.
- 7 (I) An Oath or Affirmation.
- 1 (m) A copy of the SIPC Supplemental Report.
- (n) A report describing any material inadequacies found to existed since the date of the previous audit.

\*\* For conditions of confidential treatment of certain portions of this filing, see section 240.17a-5(e)(3).

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Crowe LLP Indopendent Mamber Crowe Global

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

Board of Directors and Stockholder Securian Financial Services, Inc. Gt Paul Minnesata

## Opinion on the Financial Statements

We have audited the accompanying statement of financial condition of Securian Financial Services, Inc. (the "Company") as of Decention 31, 2019, the related statements of uperations, changes In slocklistiber's equity, and cash flows for the year ended December 31, 2019, 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, 2019, and the results of its operations and its cash flows for the year ended December 31, 2019, 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 excress 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 requirations 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 enor 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 evaluation of the financial statements. We believe that our audit provides a reasonable basis for our opinion

## Supplemental Information

The Schedule I Computation of Net Capital Under Rule 15c3-1 of the Securities and Exchange Commission and Schedule II Computation for Determination of Customer Reserve Requirements and PAB Accounts Reserve Requirements for Broker Dealers Pursuant to Rule 15c3-3 under the Securities Exchange Act of 1934 (collectively the "Supplemental Information") have been subjected to aucif procedures performant in orginanting with the aurit of Securies Financial Services, Inc.'s financial statements. The Supplemental Information is the responsibility of the Company's management. Our audit procedures included determining whether the Supplemental Information reconcies to the financial statoments or the underlying acounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the Supplemental Information. In forming our opinion on the Supplemental Information, we evaluated whether the Supplemental Information, including its form and content is presented in conformity wth 17 C.F.R. § 240.17a-5. In our opinion, the Supplemental Information is fairly stated, in all material respects, in relation to the financial statements as a whole.

Crown II LE

We have served as the Company's auditor since 2019.

New York, New York February 28, 2020

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## Statement of Financial Condition

## December 31, 2019

(in thousands)

## Assets

| Cash and cash equivalents                           | 8 | 15.654 |
|-----------------------------------------------------|---|--------|
| Securities owned, at fair value                     |   | 20,021 |
| Commissions receivable                              |   | 6,088  |
| Due from affiliates                                 |   | 471    |
| Income tax recoverable:                             |   |        |
| Current                                             |   | 1,221  |
| Other receivables                                   |   | 2.029  |
| Software, net of accumulated amortization of S6,082 |   | 1,920  |
| Prepaid expenses                                    |   | 1.158  |
| Deposit with clearing organizations                 |   | 120    |
| Total assets                                        | S | 48.682 |

# Liabilities and Stockholder's Equity

Liabilities:

| Commissions payable   | 8 | 6.856  |
|-----------------------|---|--------|
| Accrued expenses      |   | 2,303  |
| Income tas liability: |   |        |
| Deferred              |   | 256    |
| Due to affiliates     |   | 5,097  |
| Unearned fees         |   | 1,262  |
| Total habilities      |   | 15.774 |

## Stockholder's equity:

| Paid-in capital; 25,000 shares of common stock<br>authorized, no par value; 100 shares issued and outstanding |   | 53.216   |
|---------------------------------------------------------------------------------------------------------------|---|----------|
| Accumulated deficit                                                                                           |   | (20,308) |
| Total stockholder's equity                                                                                    |   | 32.908   |
| Total liabilities and stockholder's equity                                                                    | 8 | 48.682   |

See accompanying notes to financial statements.

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## Statement of Operations

# For the year ended December 31, 2019

(in thousands)

Revenues:

| Investment advisory and financial planning fees                    | S | 144,796 |
|--------------------------------------------------------------------|---|---------|
| Commissions and distribution and service fee income.               |   |         |
| Affiliated variable life, variable annuities and other products    |   | 90,644  |
| Variable life, variable annuities, mutual funds and other products |   | 84,503  |
| 12b-1 fees from insurance products                                 |   | 16,515  |
| Compliance fee income received from affiliates                     |   | 1.292   |
| Other income                                                       |   | 8,945   |
| Net investment income                                              |   | 538     |
| Net trading investment gains                                       |   | 1,370   |
| Total revenues                                                     |   | 348,633 |
| Expenses:                                                          |   |         |
| Commissions on investment advisory and financial planning fees     |   | 115,206 |
| Commissions and distribution and service fee expense:              |   |         |
| Affiliated variable life, variable annuities and other products    |   | 90,644  |
| Variable life, variable annuities, mutual funds and other products |   | 73,322  |
| 12b-1 fees from insurance products                                 |   | 16,545  |
| Salaries and benefits                                              |   | 20,040  |
| Registration fees                                                  |   | 1,616   |
| Clearing fees                                                      |   | 312     |
| General and administrative expenses                                |   | 15,615  |
| Total expenses                                                     |   | 333,900 |
| Income before income taxes                                         |   | 14,733  |
| Income tax expense:                                                |   |         |
| Current                                                            |   | 3,471   |
| Deferred                                                           |   | 707     |
| Total income tax expense                                           |   | 4.178   |
| Net income                                                         | S | 10,555  |

See accompanying notes to financial statements.

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## Statement of Changes in Stockholder's Equity

# For the year ended December 31, 2019

(in thousands)

|                               |    | Paid-in<br>capital |   | Accumulated<br>deficit |   | Total   |
|-------------------------------|----|--------------------|---|------------------------|---|---------|
| Balances at January 1, 2019   | S  | 53,216             | S | (22,863)               | S | 30,353  |
| Net income                    |    | 1                  |   | 10.555                 |   | 10.555  |
| Dividend to stockholder       |    |                    |   | (8,000)                |   | (8,000) |
| Balances at December 31, 2019 | 69 | 53,216             | S | (20,308)               | S | 32,908  |

See accompanying notes to financial statements.

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# Statement of Cash Flows

# For the year ended December 31, 2019

(in thousands)

Cash flows provided by operating activities

| S<br>Net income                                 | 10,555  |
|-------------------------------------------------|---------|
| Adjustments to reconcile net income to net cash |         |
| provided by operating activities:               |         |
| Software amortization                           | 479     |
| Deferred tax provision                          | 707     |
| Change in operating assets and liabilities:     |         |
| Decrease in commissions receivable              | 576     |
| Increase in securities owned                    | (1,370) |
| Change in income tax recoverable - current      | (661)   |
| Decrease in due from affiliates                 | 91      |
| Increase in other receivables                   | (10)    |
| Increase in prepaid expenses                    | (76)    |
| Increase in commissions payable                 | 587     |
| Increase in accrued expenses                    | 389     |
| Increase in due to affiliates                   | 4.109   |
| Increase in unearned fees                       | 42      |
| Net cash provided by operating activities       | 15,418  |
| Cash flows used for investing activity          |         |
| Additions to capitalized software               | (7)     |
| Net cash used for investing activity            | (7)     |
| Cash flows used for financing activity          |         |
| Dividend to stockholder                         | (8,000) |
| Net cash used for financing activities          | (8.000) |
| Increase in cash and cash equivalents           | 7,411   |
| Cash and cash equivalents at beginning of year  | 8,243   |
| Cash and cash equivalents at end of year<br>S   | 15,654  |

See accompanying notes to financial statements.

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## Notes to Financial Statements

#### December 31, 2019 (In thousands)

#### (1) Basis of Presentation and Nature of Business

The accompanying financial statements have been prepared in accordance with U.S. generally accepted accounting principles (GAAP). The financial statements Include the accounts of Securian Financial Services, Inc. (the Company), a wholly-owned subsidiary of Securian Financial Group, Inc. (SFG).

The preparation of the financial statements in conformity with GAAP requires management to make and assumptions that affect the reported assets and liabilities, including disclosure of contingent assets and liabilities, as of the statement of financial condition date and the reported amounts of revenue and expenses during the reporting period. Actual results could differ from those estimates.

The Company is a registered broker in securities under the Securities Exchange Act of 1934. The Company is also a registered investment adviser under the Investment Advisers Act of 1940. The Company is the distributor of Minnescta Life Insurance Company's (Minnesota Life), a subsidiary of SFG, variable and fixed annuity contracts, variable life Insurance policles and certain equity indexed annuity contracts and the insurance policies. The Company is also the distributor of Securan Life Insurance Company's (Securian Life), a subsidiary of Minnesota Life, variable ine insurance policles and oertain equity Indexed life Insurance policies. Additionally, the Company also sells mutual funds, annuity contracts and Insurance policles sponsored by third parties. The Company does not hold or carry securities for customer accounts. The Company clears all customer transactions on a fully disclosed basis with clearing broker/dealers.

The Company's results of operations may not be indicative of the results that might be obtained had it operated independently.

## (2) Summary of Significant Accounting Policies

## Revenue from Contracts with Customers

Revenue from contracts with customers is recognized when promised goods or services are delivered to the customers in an amount that reflects consideration the Company expects to receive in exchange for those goods or services (transaction price). Contracts with customers may include multiple services, which are accounted for as separate performance obligations If determined to be distinct. The Company's performance obligations are generally satisfied when the Company transfers the promised good or service to the customer, either at a point in time or over time. Revenue from a performance obligation transferred at a point in time is recognized at the time the customer obtains control over the good or service. Revenue from a performance obligation salstled over time is recognized by measuring the Compary progress In salshing the transaction price, the Company considers multiple factors, Including the effects of variable consideration. Variable consideration is only included in revenue when amounts are not subject to significant reversal, which is generally when uncertainty around the amount of revenue to be received is resolved.

The following describes the nature and timing of revenue and cash flows arising from the Company's contracts with customers.

### Investment advisory and financial planning fees

The Company earns revenue for performing investment advisory services for certain brokerage customer accounts. The revenue is earned based on a contractual fixed rate applied in arrears, as a percentage, to the market value of assets held in the account. The investment advisory performance obligation is considered a series of distinct services that are substantially the same and are salisfied each day over the contract term. Advisory fees are generally considered to be variably constrained due to factors outside the Company's control including market volatility and client behavior (such as how long clients hold their investment, insurance policy or annuity contract). The revenue will not be recognized until it is probable that a significant reversal will not occur, and are accrued daily and involced or charged on a monthly or quarterly basis.

б

(Continued)

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## Notes to Financial Statements (Continued) (in thousands)

#### (2) Summary of Significant Accounting Policies (Continued)

#### Revenue from Contracts with Customers (Continued)

## Investment advisory and financial planning fees (Continued)

The Company earns revenue for providing financial plans to its clients. The revenue earned for each financial plan is a fixed fee (received monthly, quarterly, semi-annually or annually). The financial planning fee is based on the complexity of a client's financial and ife situation and the respective advisor's experience. The performance obligation is satisfied at the time the financial plan is delivered to the customer and revenue is recognized at that firme. Within the terms of the financial plan contract, the parties of the contract may lerminate the contract at any time with proper notfication. It the contract is terminated by the customer, the Company is entitled to a transaction price in a pro-rata amount based upon the degree of completion of the financial plan. This pro-rata calculation can result in either amounts due to the Company or amounts refundable to the client.

The Company records a contract liabilly for the unearned fee when cash is received before the financial plan is delivered and the performance obligations have been satisfied The contracts with clients are annual contracts. Amounts recorded as a contract liability are recognized as revenue when the financial plan is delivered, which occurs within the annual period.

The following table provides a summary of changes in the unearned fee liability for the year ended December 31, 2019;

| Balance at beginning of year             | 1.220   |
|------------------------------------------|---------|
| Fee revenue recognized during the year   | (1,220) |
| Fees received during year not recognized | 1.262   |
| Balance at and of year                   | 1.262   |

The difference between the beginning of year and of veer balances of the changes in the Company's uneamed fee liability primarily results from the timing of Company's completion of the performance obligation and the recorpt of payment for the plan by the client.

As allowed in termination provisions of the contract, a client may cancel their financial plan after the Company has delivered the plan and completed its performance obligation. The Company has historically refunded certain financial planning fees after the performance obligation has been satisfied and revenue has been recognized. The Company calculates a refund based on historical information and includes this liability within accrued expenses on the statement of financial condition. Related to this refund, the Company also calculates the estimate commission paid to the advisor that would be recaptured and includes this within other receivables on the statement of financial condition.

The following table provides a summary of changes in the refund liability for the year ended December 31, 2019:

| Balance at beginning of year                        | 410   |
|-----------------------------------------------------|-------|
| Refunds made during the year                        | (425) |
| Fees recognized during year expected to be refunded | 475   |
| Balance at end of year                              |       |

The following table promoty of charges in the commission recapture assel for the year ended Decamber 31, 2019:

| Balance at beginning of year                                     | 358   |
|------------------------------------------------------------------|-------|
| Commissions recaptured during the year                           | (372) |
| Commissions recognized during the year expected to be recaptured | 372   |
| Balance at end of year                                           | 358   |

The difference between the beginning of year and end of year balances of the Company's retund liability and related commission recaplure assel primarily results from the timing of Company's performance and the ultinate acceptance by the client of the plan.

(Continued)

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#### Notes to Financial Statements (Continued) (in thousands)

### (2) Summary of Significant Accounting Policies (Continued)

#### Revenue from Contracts with Customers (Continued)

### Commissions and Distribution and Service Fee Income

#### Variable life, variable annuities, mutual funds and other products

The Company earns commissions, distribution income and service for selling affiliated and unaffiliated variable life, fixed and variable annuity products and certain other products. The Company also earns revenue from selling unaffiliated multiple There are multiple performance obligations related to these contracts. The initial performance obligation is satisfied at the time of each individual sale. The revenue recognized at time of sale (commission revenue) is based on a food rate applied, as a percentage, to amounts invested at the time of sale. These revenues are accrued daily and received weekly, monthly, or quarterly. The second portion of revenue, trailing distribution income, is recognized over the time the investment or holds the contract and is generally earned based on a fixed rate applied, as a percentage to the fund, or the fund, or the value of the insurance policy or annuty contract. Trailing distribution income is not recognized at the time of sale because it is variably constrained due to factors cutside the Company's control including market volatility and client behavior (such as how long clients hold their investment, insurance policy or annuity contract). The revenue is not to be recognized until it is probable that a significant reversal will not occur. These revenues are received weekly, monthly, or quarterly

The additional performance obligation is related to the service of the client contract, including but not limited to, answering clent inquiries and providing fund (contract performance information to clients. The service performance obligation is satisfied over time. This service fee is based on a fixed rate applied, as a percentage, to amounts invested after the date of the initial sale of the contract. The recognized until it is probable that a significant reversal will not occur. These revenues are received weekly, monthly, or quarterly

Relative to the sale of affiliated variable life, fixed and variable annuity products and certain other products, the Company acts as a principal and receives revenue from the affiliate that is paid out directly to the advisor. The Company provides compliance services for these products and, acting as the contract, the Company recognizes these revenue dollars in a gross manner.

## 12b-1 fees from insurance products

The Company, as the principal party in the related customer contract, receives 12b-1 fees from the affiliated Securian Funds Trust funds' portfolos and Waddell and Reed Target Portfolios, and under an assignment agreement with Minnesota Life, transfers the 12b-1 fees received in total to Minnesota Life. 12b-1 fee revenue is earned for providing certain services to customers, including, but not limited to, responding to phone inquiries, providing information to distributors and shareholders regarding fund performance and training advisors. These services to customers represent the performance obligation and are considered a series of distinct services that are substantially the same. The revenue is recognized over the time the Company's client owns the investment and is generally earned based on a fixed rate applied, as a percentage, to the nel assel value of the fund. The passage of time reflects the salisfaction of the Company's performance obligation. The 12b-1 fee revenue variably constrained due to factors outside the Company's control including market volatility and dient behavior (such as how long clients hold their investment). The revenue is not recognized until it is probable that a significant reversal will not occur.

#### Compliance Fee income received from affiliates

The Company earns revenue from its affiliated insurance partners for providing advertising compliance services as well as compliance services related to selling of variable annuity and certain other insurance products. The performance obligation related to compliance services is considered a series of distinct services that are substantially the same and are satisfied over time and recognized each day over the contract term at a fixed rate. These fees are invoiced and collected on a quarterly basis

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#### Notes to Financial Statements (Continued) (In thousands)

## (2) Summary of Significant Accounting Policies (Continued)

Revenue from Contracts with Customers (Continued)

#### Other Income

Other Income Includes fees received from stratedic partners for placing and maintaining fund partners and Insurance companies' products on the Company's sales platform (subject to the Company's due diligence standards) along with marketing support and sales force education and training. Revenue for these performance obligations is generally calculated as a fixed fee, or as a percentage of the assels. This performance obligation is onellered a series of distinci These fees are involced and collected on quarterly basis.

Under a contract with the Company's clearing agent, the Company receives revenue related to money market sweep fees generated on clients' money market cash sweep accounts held at the Company's clearing agent. The performance obligation is the client administration services provided. These administrative services are performed daily and as such, the performance obligation is salstied dally and revenue is recognized daily based on a fixed rate applied, as a percentage, to the deposits held in the money market cash sweep accounts. These amounts are settled with the Company's clearing agent monthly.

Other Income Includes fees charged to advisors for providing various the advisors need to support and grow their practices. These fees Include, but are not limited to, training, education, Insurance complance supervision, technology services and support, licensing fees and other services. These services to advisors represent single performance obligations that are satisfied at the time of the Company recognizes revenues for the gross amount of the fees charged to advisors based on actual services provided. Fees are primarily collected semimonthly as a reduction of commission payments.

Other income includes fixed transational fees the Company charges and their clients for executing ontaln
 transactions in brokerage and fee-based advisory accounts. Transact that a transaction is executed and the performance obligation is completed, which is trade-date. The fee is collected by the clearing broker dealer at time of trade and settled with the Company on a monthly basis.

The following table presents our total revenue disaggregated by category for the year ending December 31, 2019:

| Investment advisory                            | ર્ફ | 132,369 |
|------------------------------------------------|-----|---------|
| Financial planning fees                        |     | 12.427  |
| Sales based commissions                        |     | 127,980 |
| Trailing distribution Income                   |     | 44.904  |
| Service fee Income                             |     | 2.263   |
| 12b-1 fees                                     |     | 16,545  |
| Compliance fee income received from affiliates |     | 1,292   |
| Strategic partner Income                       |     | 2.124   |
| Money market sweep fee income                  |     | 1,708   |
| Advisor fee Income                             |     | 2.472   |
| Transaction fee Income                         |     | 1.067   |
| Other revenues                                 |     | 1,574   |
| Total revenue from contracts with customers    |     | 346,725 |
| Revenue from other sources                     |     | 1,908   |
| Balance at end of year                         |     | 348,633 |

## Practical expedients

The Company has applied an allowed practical expedient that permils for the value of unsaltsfied performance obligations for contracts with an original expected length of one year or less.

The Company has also applied an allowed practical expedient that allows for no adjustment to consideration due to a significant financing component if the expectation at contract inception is such that the period between payment by the customer and the transfer of the promised goods or services to the customer will be one year or less

(Continued)

ழ

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## Notes to Financial Statements (Continued) (in thousands)

## (2) Summary of Significant Accounting Policies (Continued)

## Commissions Receivable

As of December 31, 2019, the Company has certain commissions and distribution and service fee income that has been recognized but not received by the Company. These amounts are included in commissions receivable on the statement of financial condition.

The following table provides a summary of changes in the commissions receivable for the year ended December 31, 2019:

| Balance at beginning of year                          | ਣ | 6.664   |
|-------------------------------------------------------|---|---------|
| Commissions and distribution and service fees income  |   |         |
| related to prior year received during the year        |   | (6,664) |
| Commissions and ristribution and secure fees increase |   |         |
| recognized but not received during the year.          |   | 6.008   |
| Balance at end of year                                | 5 | A nex   |

The difference between the beginning of year and end of year balances of the changes in the Company's commissions receivable primarily results from the timing of Company's completion of the performance obligation and the receipt of payment by the customer.

#### Commissions and Distribution and Service Fee Expenses and Related Commissions Payable

Commissions and distribution and service fee expenses are recognized on a trade date basis and paid to advisors sernmonthly. Unpaid commission amounts due to advisors are included in commissions payable on the etalement of financial condition.

#### Securities Owned and Related Net Investment Income and Net Trading Investment Gains

Securities owned are comprised of equities and are recorded on a trade date basis al fair value on the statement of financial condition. Changes in fair value of equity securities are included in net trading investment of operations. The Company recognizes dividend income upon the dividend. Dwidend income is included in net investment income on the statement of operations.

#### Cash and Cash Equivalents

Cash is carried at cost, which approximates fair value. Cash equivalents of sufficient credit quality are carried at fair market. value. The Company considers all money market funds to be cash equivalents.

#### Other Receivables

Other receivables are carried at original anount, less an estimate made for doubtiul receivables based on a review of all outstanding amounts on a monthly basis. At December 31, 2019, the Company had no allowance for doubtly receivables. Other receivables are written off when deemed uncollectible. Recoveries of accounts receivable previously written off are recorded as income when received. Interest is not accrued on past-due other receivables balances.

#### Income Taxes

The Company files a lifeinon-life consolidated federal income tax relum with Minnesota Mutual Companies, Inc., the Company's ultimate parent. The Company utilizes a conscilidated approach to the allocation of current taxes, whereby, the tax benefits resulting from any losses by the Company, which would be realized by Minnesota Mutual Companies, Inc. on a consolidated return, go to the benefit of the Company is included in the federal tax sharing agreement with Minnesota Mulual Companies, Inc. Intercompany tax balances are settled annually when the lax refurn is filed with the Internal Revenue Service (IRS),

(Continued)

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

#### Notes to Financial Statements (Continued) (In thousands)

## (2) Summary of Significant Accounting Policies (Continued)

#### Income Taxes (Continued)

Inherent in the provision for federal income taxes are estimates regarding the deductibility of certain liems and the realization of certain tax credits. In the event the ultimate deductbillty of certain items or the realization of certain tax credits differs from estimates, the Company may be regulred to significantly change the provision for federal income taxes recorded on the financial statements. Any such change could significantly affect the amounts reported on the statement of operations. Management has used best estimates to establish reserves based on ourrent facts and circumstances regarding tax exposure items where the ultimate deductibility is open to interpretation. Management evaluaties the appropriationess of such reserves based on any new developments specific to their fact patterns. Information considered includes results of completed tax examinations, Technical Advice Memorandums and other rulings Issued by the IRS or the tax courts.

The Company utilizes the asset and ilability method of accounting for income tax. Under this method, deferred tax assets and liabilities are recognized for the future tax consequences attributable to differences between the financial statement carrying amounts of existing assets and liablittes and their respective tax bases and operating loss and tax credit carryforwards. Deferred tax assets and llabilities are measured using enacted tax rates expected to apply to taxable Income in the years in which those temporary differences are expected to be recovered or settled. Under this method, the effect on deferred tax assets and llabilities of a change in tax rates is recognized in Income in the perfod that includes the enacments dates. Valuation allowances are established when it is determined that it is more likely than not that the deferred tax asset will not be fully realized. Current income taxes are charged to operations based upon amounts estimated to be payable or receivable as a result of taxable operations for the current year. Interest and penalties, If any, related to income tax matters are accrued in the income tax expense line them in the period they are incurred or such changes are enacted.

#### Software Capitalization

Computer software costs incurred for internal use are capitalized over a three or five-year perfod. Computer software costs Include application software, purchased software packages and significant upgrades to software. At December 31, 2019, the Company had unamortized software costs of \$1,920.

#### (3) Risks

The Company's financial statements are based on estimates and assumptions that are subject to significant business, economic and competitive risks and uncertainties, many of which are beyond the Company's confrol or are subject to change. As such, actual results could differ from the estimates used in the financial statements and the Company's investments, its financial condition and its liquidity could be adversely affected. The following risks and uncertaintles, among others, may have such an effect:

- Economic environment and capital markets-related risks such as those related to Interest rates and equity markets. Business and operational-related risks such as those related to liquidity, competition, cyber or other information
- security, fraud, and overall risk management. Acquisition, disposition, or other structural change related risks.
- Regulatory and legal risks such as those related to changes in fiscal, tax and other legislation, broker-dealer regulation, and accounting standards.

The Company actively monitors and manages risks and uncertainties through a variety of policles and procedures in an effort to mitigate or minimize the adverse impact of any exposures impacting the financial statements.

(Continued)

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

Notes to Financial Statements (Continued) (in thousands)

#### (4) New Accounting Pronouncements

## Adoption of New Accounting Pronouncements

In August 2018, the Financial Accounting Standards Board (FASB) issued Accounting Standards Update (ASU) 2018-13, Fair Value Measurement (Topic 620): Disclosure Framework - Changes to the Disclosure Requirements for Fair Value Measurement, which modifies the disclosure requirements of assets and liabilities reported at fair value on the balance sheet by removing some requirements and modifying others. ASU 2018-13 is effective for the annual reporting period beginning January 1, 2020 and provides various transition methods by topic that an entity may elect to adopt. Early adoption is permitted. The Company elected to early adopt ASU 2018-13 for the year ended December 31, 2019 which resulted in the removal of certain disclosures within footnote 5 Investments.

In November 2016, the FASB issued ASU 2016-15, Statement of Cash Flows (Topic 230): Classification of Certain Cash Receipts and Cash Payments, which clarify fransactions are to be presented on the statement of cash flows. ASU 2016-15 is effective for the annual reporting January 1. 2019 and is required to be applied on a retrospective basis with early adoption of this new standard did not have an impact on the Company's financial statements.

### (5) Investments

#### Fair Value of Financial Instruments

The fair value of the Company's financial assets has been determined using available market information as of December 31, 2019. Although the Company is not aware of any factors that would significantly affect the tair value of financial assets, such amounts have not been comprehensively revalued since that date. Therefore, estimates of fair value subsequent to the valuation date may differ significantly from the amounts presented herein. Considerable judgment is required to interpret market data to develop the estimates of fair value. The use of different market assumptions and/or estimation methodologies may have a material effect on the estimated fair value amounts.

Fair value is defined as the price that would be received to sell an asset (exit price) in an orderly transaction between market participants at the measurement date. In determining fair value, the Company primanly uses the market approach which utilizes prices and other relevant information generated by market transactions involving identical or comparable assets.

The Company is required to categorize its thancial assets recorded on the balance sheet according to a three-level hierarchy. A level is assigned to each financial asset based on the lowest level input that is significant to the fair value measurement in its onlirety. The tevels of fair value hierarchy are as fallows:

Level 1 - Fair value is based on unadjusted quoted prices for identical assets in an active market.

Lovel 2 ~ Fair value is based on significant inputs, other than quoted prices included in Level 1, that are observable in active markets for identical or similar assets.

Level 3 - Fair value is based on at least one or more significant unobservable inputs. These incuts reflect the Company's assumptions about the inputs market participants would use in pricing the assets.

The Company uses prices and inputs that are current as of the measurement date. In periods of market disruption, the ability to observe prices and inputs may be reduced, which could cause an asset to be reclassified to a lower level.

Inculs used to measure fair value of an asset may fall into different levels of the fair value hierarchy. In these situations, the Company will determine the level in which the fair value talls based upon the lowest level input that is significant to the determination of the fair value.

(Continued)

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

## Notes to Financial Statements (Continued) (in thousands)

## (5) Investments (Continued)

Fair Value of Financial Instruments (Continued)

The following table summartzes the Company's financial assets measured at fair value on a recurring basis as of December 31, 2019:

|                        | December 31, 2019 |           |         |  |         |  |       |           |
|------------------------|-------------------|-----------|---------|--|---------|--|-------|-----------|
|                        | Level 1           |           | Level 2 |  | Level 3 |  | Total |           |
| Securities owned       |                   |           |         |  |         |  |       |           |
| Equities               |                   | \$ 20,021 | 2       |  | ต       |  |       | \$ 20.021 |
| Total investments      |                   | 20.021    |         |  |         |  |       | 20,021    |
| Cash equivalens        |                   | 191       |         |  |         |  |       | ות ה      |
| Total financial assots |                   | \$ 20,812 | 6       |  | 6       |  |       | \$ 20,812 |

The Company did not have any financial liabilities that would be required to be measured at fair value as of December 31, 2019.

The methods and assumptions used to estimate the fair value of financial assets are summarized as follows:

## Equity securities

The Company's equity securities consist of investment in common stock of publicly traded companies. The fair value of equity securities are based on quoted markets for identical assets and are classified within Level 1.

#### Cash equivalents

Cash equivalents include money market funds are generally valued using unadjusted quoted prices in active markets and are reflected in Level 1.

The Company did not have any assets or liabilities reported at fair value on a nonrecurring basis.

The portion of net trading investment gains that relates to securities still held at December 31, 2019 was \$1,370.

#### Net Investment Income

| Securities owned<br>Cash equivalents | 5 | 537<br>ੀ। |
|--------------------------------------|---|-----------|
| Gross investment income              |   | 546       |
| Investment expenses                  |   | (8)       |
| Total                                |   | રેજિક્લ   |

## (6) Related Party Transactions

The Company is the distributor of Minnesota Life's fixed annuity, variable life and certain life and annuity indexed products and is also the distributor of Securian Life's fixed annuity, variable life insurance products. The Company received compliance fees of \$1,282 during 2019, which is included in compliance fee income received from affiliates in the statement of operations, from Minnesota Life for performing compliance functions for these products. The Company also recognized commission income, which is included in commissions and distribution and service fee income: affiliated variable life, variable annuities and other products in the statement of operations of \$90,644 in 2019 related to distribution activities, of which \$2,007 was included in the statement of financial condition at December 31, 2019.

(Continued)

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

## Notes to Financial Statements (Continued) (in thousands)

## (6) Related Party Transactions (Continued)

The Company also has agreements with an affiliate. Securian Trust Company. N.A. (STC), an affiliated national bank. Under these agreements, the Company provides investment advisory services to STC clients and receives referral fees for clients of the Company who name STC trust. The Company received fees of \$1,328 for the year ended December 31, 2019, of which is \$1.170 is included in investment advisory and financial planning fees and \$150 is included in commissions and distribution and service fee income; variable life, variable annuities, mutual funds and other products in the statement of operations

Under management services agreements with Minnesota Life, Securian Life and STC, the Company charges or is charged expenses including allocations for occupancy costs, data procession, advertising and promotion and other administrative expenses. The Company either incurs these expenses on behalf of Minnesota Life. Securian Life or STC or these expenses are incurred on behalf of the Company by Minnesda Life. Securian Life or STC. For the year ended December 31, 2019, the Company was charged net expenses totaing \$14,186 primarily included in general and administrative expenses on the statement of operations. of which \$4.942 was included in due to affiliates in the statement of financial condition and \$61 was included in due from affiliates in the statement of financial condition all December 31, 2019.

Under a consuiting services agreement with Minnesota Life, the company is charged an annual fee for services rendered to oversee certain mutual funds, including quaritiative review, risk mebics, systems operations, and portfolio management practices. Consulting service fees incurred by the Company during 2019 were \$3 included in general and administrative expenses on the statement of operations. At December 31, 2019, there was no amount due to Minnesota Life under this agreement.

Under an assignment agreement with Minnesota Life, 12b-1 fees from affiliated Securian Funds Trust, the Waddell and Reed Target portfolios and other mulual funds, are transferred to Minnescla Life. During 2019, \$16,545 was received and \$16,321 was transferred. \$16.545 was included in 12b-1 fees from insurance products revenues and 12b-1 fees from insurance products expenses in the statement of coerations. At December 31, 2019, \$155 was payable to ML and included in due to affiliates in the statement of financial condition.

For the vear ended December 31, 2019, included in the \$16,545 12b-1 tees from insurance products in the statement of operations is \$8,850 of distribution and service fee income related to agreements with certain investment companies managed by an affiliate, Securian Asset Management, Inc. Such fees are used to pay certain expenses incurred in the distribution of shares of associated mutual funds which have adopted Plans of Distribution pursuant to Rule 12b-1 under the Investment Company Act of 1940 (as amended).

The Company has an agreement with ORI Eecurities, LLC (CRI). Under this agreement, the Company assists CRI in compliance, training and marketing and provides services such as accounting and auditing. The Company charges expenses related to these activities to the affiliated party and receives reimbursement. For the year ended December 31, 2019, the Company charged expenses totaling \$2,618 included in general and administrative expenses on the statement of operations and \$410 was included in due from affiliates in the statement of financial condition.

Under a marketing services agreement with CRI, the Company pays commissions for the sale of certain insurance products. For the year ended December 31, 2019, the Company paid commissions of \$5,442 included in commissions and distribution and service fee expense: variable annuities, mutual funds and other products on the statement of operations

The Company has an investment advisory agreement with an affiliate, Securian Asset Management, Inc. Under this agreement. the Company pays quarterly investment management fees based on total assets managed. Investment management fees incurred by the Company during 2019 were \$7 included in net investment income on the statement of operations. At December 31, 2019, there was no amount due to Securian Asset Management, Inc. under this agreement.

#### (7) Transactions with Clearing Agents

The agreements with the Company's clearing agents provides for clearing charges at a fixed rate multiplied by the number of trades processed by the Company. The clearing agreements also require the Company to maintain a minimum deposit of \$120.

(Continued)

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

## Notes to Financial Statements (Continued) (in thousands)

(8) Income Taxes

The income tax expense for the year ended December 31, 2019 consists of the following:

|                  | Current      | Deferred   |     | lotal          |
|------------------|--------------|------------|-----|----------------|
| Federal<br>State | 2.799<br>672 | 295<br>412 | న్న | 3.094<br>1.084 |
|                  | 3.471.       | 707        |     | 4.178          |

The difference between the income tax expense and income taxes computed using the U.S. federal income tax rate of 21% is as fallows:

| Amount computed using the statutory rate<br>State taxes, net of federal bergefir | 3.094<br>084 |
|----------------------------------------------------------------------------------|--------------|
|                                                                                  | 4 470        |

The tax effects of temporary differences that gave rise to the Company's net deferred tax liability at December 31, 2019 are as follows:

| Deferred tax assels.<br>Net operating losses<br>Uneamed income | 293<br>va<br>305 |  |
|----------------------------------------------------------------|------------------|--|
| Bonus accrual                                                  | 320              |  |
| Other<br>Cross deferred bax easela                             | 13<br>031        |  |
| Deferred tax liabilities:                                      |                  |  |
| Prepaid expenses                                               | 284              |  |
| Deferred gain on investment                                    | 439              |  |
| Capitalized software                                           | 464              |  |
| Gross deferred tax liabilities                                 | 1.187            |  |
| Net defered tax liability                                      | ಲ್<br>256        |  |
|                                                                |                  |  |

The gross not operating loss carryforwards. which were generated in various states, amount to \$11,627 at December 31, 2019, with the majority expiring beginning in 2027.

As of December 31, 2019, management determined that no valuation allowance was nonded related to the benefits of ortain state operating loss carryforwards or for other deferred tax liems based on management's assessment that it is more likely than not that these deferred tso secents will be realized.

Income taxes paid for the year ended December 31, 2019 were \$4,132.

The balance of unrecognized tax benefits was zero as of January 1, 2019 and December 31, 2019,

As of December 31. 2019. the Company did not have any amounts accrued for interest and penallies.

At December 31, 2019, there are no positions for which it is reasonably possible that the total amounts of unrecognized tax benefits will significantly increase or decrease within 12 mornths of the reporting date.

Minneerlat Multial Companies, Inc. (MMC) is closed for lax years through 2014. MMC is not currently under IRS avain for any open year.

(Continued)

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

## Notes to Financial Statements (in thousands)

## (9) Net Capital Requirements

Pursuant to the net capital provisions of Rule 15:3-1 of the Securities and Exchange Commission, the Company is required to maintain minimum net capital as defined under such provisions. Net capital and the related net capital ratio may fluctuate on a daily basis. Al December 31, 2019, the Company had net capital of \$23,207, which was \$22,152 in excessof is required December 31, 2019. The Company's minimum capital, as defined to be greater than 6 23% of aggregate indebtedness and the ratio of aggregate indebtedness to net capital shall not exceed 15 to 1.

#### (10) Rule 15c.3-3

The Company clears all customer transactions on a fully disclosed basis with clearing broker/dealers. The Company does not hold customer funds or safekeep customer securities and therefore claims exemptions from Rule 15c3-3 of the Securities leterination of Reserver Subsections (K)2)(j) and (K)(1) and (K)(1) required.

## (11) Stock Dividends

During the year ended December 31, 2019, the Company declared and paid a cash dividend to SFG in the amount of \$6,000,

#### (12) Contingencies

The Company is involved in various pending or threatened legal proceedings arising out of the normal course of business. In the opinion of management, the ultimate resolution of such litigation will not have a material adverse effect on operations or the financial position of the Company.

## (13) Subsequent Events

The Company has evaluated the impact of events that have accurred subsequent to December 31, 2019, through the date the financial statements were issued.

![](_page_18_Picture_12.jpeg)

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

## Schedule I

# SECURIAN FINANCIAL SERVICES, INC. Computation of Net Capital Under Rule 15c3-1 of the Securities and Exchange Commission as of December 31, 2019 (in thousands)

S 32,908 Stockholder's equity Deductions - nonallowable assets: State income tax recoverable 1,277 Other receivables 2,029 Goftware, net 1,920 Prepaid expenses 849 Other assets 510 Total nonallowable assets 6.585 Net capital before haircuts on securities 26,323 Haircuts on securities 3,116 Net capital S 23,207 Total aggregate indebtedness S 15,831 Net capital � 23,207 Minimum capital required to be maintained (the greater of \$50 or 6-2/3% of aggregate indebtedness of \$15,831) 1,055 22,152 S Net capital in execus of requirements 0.68 to 1 Ratio of aggregate indebtedness to net capital

There were no material differences in the computation of net capital or aggregate indebtedness between the amounts included in the Company's unaudited December 31, 2019 Part IIA of FOCUS Form X-17A-5 and the above computations.

See accompanying report of independent registered public accounting firm.

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

## Schedule II

SECURIAN FINANCIAL SERVICES, INC. Computation for Determination of Customer Reserve Requirements and PAB Accounts Reserve Requirements for Broker Dealers Pursuant to Rule 15c3-3 under the Securities Exchange Act of 1934 December 31, 2019

The Company does not carry customer accounts. For the period January 1, 2019 to December 31, 2019, the Company was exempt from Securities and Exchange Rule 15c3-3 under paragraphs (k)(1) and (k)(2)(ii) for the Company's approved business activities. All customer transactions are cleared through other broker-dealers on a fully disclosed basis.

See accompanying report of independent registered public accounting firm,

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

## Schedule III

# SECURIAN FINANCIAL SERVICES, INC. Information Relating to Possession or Control Requirements Pursuant to Rule 15c3-3 under the Securities Exchange Act of 1934 December 31, 2019

The Company does not carry castomer accounts. For the period January 1, 2019 to December 31, 2019, the Company was exempt from Securities and Exchange Rule 15c3-3 under paragraphs (k)(1) and (k)(2)(ii) for the Company's approved business activities. All customer transactions are cleared through other broker-dealers on a fully disclosed basis.

See accompanying report of independent registered public accounting firm,

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

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Crowe LLP

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

Securian Financial Services, Inc. St. Paul, Minnesota

We have reviewed management's statements, included in the accompanying Securian Financial Services, Inc.'s Exemption Report, dated February 28, 2020, in which (1) Securian Financial Services, Inc. identified the following provisions of 17 C.F.R. § 15c3-3(k) under which Securian Financial Services, Inc. claimed an exemption from 17 C.F.R. § 240.15c3-3: (k)(1) and (k)(2)(i) (the "exemption provisions") and (2) Securian Financial Services, Inc. stated that Securian Financial Services, Inc. met the identified exemption provisions throughout the most recent fiscal year ended December 31, 2019 except as described in its exemption report. Securian Financial Services, Inc.'s management is responsible for compliance with the exemption provisions 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 Securian Financial Services, Inc.'s compliance with the exemption provisions. A review is substantially less in soope 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 paragraphs (k)(1) and (k)(2)(ii) of Rule 15c3-3 under the Securities Exchange Act of 1934.

Crowe LLP

New York, New York February 28, 2020

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

Securion Floancial Seevices, Inc. 400 Robert Street North St. Poul, MN 55101-20198 1-A00-420-6205 securion.com

![](_page_23_Picture_1.jpeg)

### Securian Financial Services, Inc.'s Exemption Report

Securian Financial Services, Inc. (the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (the "SEC")[17 C.F.R. § 240.17a-5, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R. 5 240.17a-5(d){1} and (4). To the best of its knowledge and belief, the Company states the following:

- (1) The Company claimed an exemption from 17 C.F.R. § 240.15c3-3 under the following provisions of 17 C.F.R. § 240.15c3-3: (k)(1) and (k)(2)(ii).
- (2) The Company met the identified exemption provisions in 17 C.F.R. 240.15c3-3 (k)[1) and (k)(2)[ii) throughout the most recent fiscal year ended December 31, 2019, except as described below.

The Company identified 12,983 exceptions, 3,081 of which related to checks transmitted from branch offices to the requisite third parties, and the remaining 9,902 related to checks that were forwarded by the home office to the requisite third parties outside of the timeframes prescribed by 17 C.F.R. 240.15c3-3 (k)[1) and (k)(2)(ii).

During the most recent fiscal year (Covered Period), 2,665 of the 3,081 checks transmitted from the Company's branch offices to the requisite third parties were forwarded within 2 days following the check's receipt in a branch office. Of the 9,902 checks received by the home office from the branch offices and made payable to the requisite third partles, 9,744 were forwarded by noon after receipt and approval by the Company's Home Office. This delay was primarily due to the quality assurance process.

I, George I. Connolly, affirm that, to my best knowledge and belief, this Exemption Report is true and correct.

George I. Connolly President & Chief Executive Officer Securian Financial Services, Inc.

February 28, 2020 Date

Securian Financial Services, Inc., securities dealer, registered investment advisior, member filhRA/SIPC. F51390 Res 7-2018

{24}------------------------------------------------

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Crowe LLP

### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM ON APPI YING AGREED-UPON PROCEDURES

To the Board of Directors of Securian Financial Services, Inc. St. Paul, Minnesota

In accordance with Rule 17a-5(e)(4) under the Securities Exchange Act of 1934 and with the SIPC Series 600 Rules, we have performed the procedures enumerated below with respect to the accompanying Schedule of General Assessment Reconciliation (Form SIPC-7) to the Securities Investor Protection Corporation (SIPC) for the year ended December 31, 2019, which were agreed to by Securian Financial Services, Inc. (the "Company") and SIPC, solely to assist you and the other specified party in evaluating the Company's compliance with the applicable instructions of the Form SIPC-7. The Company's management is responsible for the Company's compliance with those requirements. This agreed-upon procedures engagement was conducted in accordance with attestation standards established by the Public Company Accounting Oversight Board (United States). The sufficiency of these procedures is solely the responsibility of those parties specified in this report. 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. The procedures we performed and our findings are as follows:

- 1. Compared the listed assessment payments in Form SIPC-7 with respective cash disbursement records entries noting no differences;
- 2. Compared the amounts reported in the annual audited financial statements with the amounts reported in Form SIPC-7 for the year ended December 31, 2019 noting no differences;
- Compared any adjustments reported in Form SIPC-7 with supporting schedules and working papers 3. supporting adjustments noting no differences;
- 4. Proved the arithmetical accuracy of the calculations reflected in Form SIPC-7 and in the schedules and working papers supporting adjustments noting no differences; and
- 5. Compared the amount of any overpayment applied to the current assessment with the Form SIPC-7 on which it was computed noting no differences.

We were not engaged to, and did not conduct an examination, the objective of which would be the expression of an opinion on compliance. Accordingly, we do not express such an opinion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you.

This report is intended solely for the information 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 parties

Crowe LLP

New York, New York February 28, 2020

{25}------------------------------------------------

|                                                             | SECURITIES INVESTOR PROTECTION CORPORATION<br>P.O. Box 92185 Washington, D.C. 20090-2185<br>202-371-8300                                                                                                               |                                                                                    |                                                                                                                                                                                                                                                                                     |                                                                                                                                                                                |
|-------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| General Assessment Reconcilliation<br>(36-REV 12/18)        |                                                                                                                                                                                                                        |                                                                                    |                                                                                                                                                                                                                                                                                     | 36-REV 12/18                                                                                                                                                                   |
|                                                             |                                                                                                                                                                                                                        | For the fiscal year ended 12/31/2019                                               |                                                                                                                                                                                                                                                                                     |                                                                                                                                                                                |
|                                                             | TO BE FILED BY ALL SIPC MEMBERS WITH FISCAL YEAR ENDINGS                                                                                                                                                               | (Read carefully the instructions in your Working Copy before completing this Form) |                                                                                                                                                                                                                                                                                     |                                                                                                                                                                                |
|                                                             | 1. Name of Member, address, Designated Examining Authority, 1934 Act registration no. and morth in which liscal year ends for<br>purposes of the audit requirement of SEC Rule 17a-5:                                  |                                                                                    |                                                                                                                                                                                                                                                                                     |                                                                                                                                                                                |
|                                                             | 11=1 franswer 2018 seemanness wones were WADC 220<br>31955 PINIRA DEC<br>SECURIAN FINANCIAL SERVICES INC.<br>ATTN: ISA CARRIERE<br>400 ROBERT ST N STE N<br>SAINT PAUL, MN 55101-2037                                  |                                                                                    | Note: If any of the information shown on the<br>mailling label requires correction, please e-mail<br>any corrections to form@sipc.org and so<br>indicate on the form filed.<br>Name and telephone number of person to<br>contact respecting this form.<br>LISA CARRIERE Los 1-6165- |                                                                                                                                                                                |
|                                                             | 2. A. General Assessment (item 2e from page 2)<br>B. Less payment made mith SIPC-6 filed (exclude interest)                                                                                                            |                                                                                    |                                                                                                                                                                                                                                                                                     | 84.429<br>43,043                                                                                                                                                               |
| 8/15/2019<br>Date Paid<br>C. Less prior overpayment applied |                                                                                                                                                                                                                        |                                                                                    |                                                                                                                                                                                                                                                                                     |                                                                                                                                                                                |
|                                                             | D. Assessment balance due or (overpayment)                                                                                                                                                                             |                                                                                    |                                                                                                                                                                                                                                                                                     |                                                                                                                                                                                |
|                                                             | E. Interest computed on late payment (see instruction E) for _________________________________________________________________________________________________________________                                         |                                                                                    |                                                                                                                                                                                                                                                                                     |                                                                                                                                                                                |
|                                                             | F. Total assessment balance and interest due {or overpayment carried forward}                                                                                                                                          |                                                                                    |                                                                                                                                                                                                                                                                                     | 41 386                                                                                                                                                                         |
| G. PAYMENT: √ the box                                       | Check mailed to P.O. Box W Funds Wired D<br>Total (must be same as F above)                                                                                                                                            | ACH [                                                                              |                                                                                                                                                                                                                                                                                     |                                                                                                                                                                                |
| H. Overpayment carried forward                              |                                                                                                                                                                                                                        |                                                                                    |                                                                                                                                                                                                                                                                                     |                                                                                                                                                                                |
|                                                             | 3. Subsidiaries (S) and producessors (P) included in this form (glve name and 1934 Act registration number):                                                                                                           |                                                                                    |                                                                                                                                                                                                                                                                                     |                                                                                                                                                                                |
| and complete.                                               | The SIPC member submitting this form and the<br>person by whom it is executed represent thereby<br>that all information contained herein is true, correct                                                              |                                                                                    | ECURIAN FINANCIAL CERUICE<br>San, Partnership or other organization)                                                                                                                                                                                                                |                                                                                                                                                                                |
|                                                             |                                                                                                                                                                                                                        |                                                                                    | [Authorized Signature]<br>Unici                                                                                                                                                                                                                                                     |                                                                                                                                                                                |
|                                                             | This form and the assessment payment is due 60 days after the end of the fiscal year. Retain the Working Copy of this form<br>for a period of not less than 6 years, the latest 2 years in an easily accessible place. |                                                                                    | (Tilla)                                                                                                                                                                                                                                                                             |                                                                                                                                                                                |
| Dates:<br>Postmarked                                        | Received                                                                                                                                                                                                               | Reviewed                                                                           |                                                                                                                                                                                                                                                                                     |                                                                                                                                                                                |
| PC REVIEWER<br>Calculations                                 |                                                                                                                                                                                                                        | Documentation_                                                                     |                                                                                                                                                                                                                                                                                     | Forward Copy _________________________________________________________________________________________________________________________________________________________________ |
| Exceptions:                                                 |                                                                                                                                                                                                                        |                                                                                    |                                                                                                                                                                                                                                                                                     |                                                                                                                                                                                |
| IS<br>Disposition of exceptions:                            |                                                                                                                                                                                                                        |                                                                                    |                                                                                                                                                                                                                                                                                     |                                                                                                                                                                                |

-

1

{26}------------------------------------------------

# DETERMINATION OF "SIPC NET OPERATING REVENUES" AND GENERAL ASSESSMENT

| AND GENERAL ASSESSMENT                                                                                                                                                                                                                                                                                                                                                 | Amounts for the fiscal period<br>beginning 1/1/2019<br>and ending 12/31/2019 |
|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------|
| Item No.<br>2a. Total revenue (FOCUS Line 12/Part IIA Line 9, Cade 4030).                                                                                                                                                                                                                                                                                              | Eliminate cents<br>348,632,699                                               |
| 2b. Additions:<br>[1) Total revenues from the securities business of subsidiaries (except foreign subsidiaries) and<br>predecessors not included above.                                                                                                                                                                                                                |                                                                              |
| (2) Net loss from principal transactions in securities in trading accounts.                                                                                                                                                                                                                                                                                            |                                                                              |
| (3) Net loss from principal transactions in commodities in trading scounts.                                                                                                                                                                                                                                                                                            |                                                                              |
| (4) Interest and dividend expense deducted in determining item 2a.                                                                                                                                                                                                                                                                                                     |                                                                              |
| (5) Net loss from management of er participation in the underwrilling or distribution of securities.                                                                                                                                                                                                                                                                   |                                                                              |
| (6) Expenses other than advertising, printing, registration tees and legal tees deducted in determining nel<br>profit from management of or participation in underwriting or distribution of securities.                                                                                                                                                               |                                                                              |
| (7) Net loss from securities in investment accounts.                                                                                                                                                                                                                                                                                                                   |                                                                              |
| Total additions                                                                                                                                                                                                                                                                                                                                                        |                                                                              |
| 2c. Deductions:<br>(1) Revenues from the distribution of shares of a registered open end investment company or unit<br>investment Irust, from the sale of variable annuities, from the business of insurance, from investment<br>advisory services readered to registered investment company separate<br>accounts, and from transactions in security futures products. | (290,664,281                                                                 |
| (2) Revenues from commodily transactions.                                                                                                                                                                                                                                                                                                                              |                                                                              |
| (3) Commissions, fiver brokerage and clearance paid to other SIPC members in connection with<br>securities fransactions.                                                                                                                                                                                                                                               | (312,223                                                                     |
| (4) Reimbursements for postage in connection with proxy solicitation.                                                                                                                                                                                                                                                                                                  |                                                                              |
| (5) Net gain from securities in investment accounts.                                                                                                                                                                                                                                                                                                                   | 1.370,278                                                                    |
| (6) 100% of commissions and markups carned from transactions in (i) certificates of deposit and<br>(ii) Treasury bills, bankers acceptances or commercial paper that mature nine months or less<br>from issuance date.                                                                                                                                                 |                                                                              |
| (7) Direct expenses of printing and legal lees incurred in connection with other revenue<br>related to the securities business [revenue defined by Section 16(9)(L) of the Act).                                                                                                                                                                                       |                                                                              |
| (8) Other revenue not related either directly or indirectly to the securities business.<br>(See Instruction C):                                                                                                                                                                                                                                                        |                                                                              |
| (Deductions in excess of \$100,000 require documentation)                                                                                                                                                                                                                                                                                                              |                                                                              |
| [9] [i] Total interest and dividend expense [FOCUS Line 22/PART IIIA Line 13,<br>Code 4075 plus line 2b(4) above) but not in excess<br>of total interest and dividend income.                                                                                                                                                                                          |                                                                              |
| (ii) 40% of margin interest earned on customers securities<br>accounts (40% of FOCUS line 5, Code 3980).                                                                                                                                                                                                                                                               |                                                                              |
| Enter the greater of line (i) or (ii)                                                                                                                                                                                                                                                                                                                                  |                                                                              |
| Total deductions                                                                                                                                                                                                                                                                                                                                                       | (292,346,782                                                                 |
| 2d. SIPC Net Operating Revenues                                                                                                                                                                                                                                                                                                                                        | 56,285,91                                                                    |
| 2e. General Assessment @ . 0015                                                                                                                                                                                                                                                                                                                                        | પ્રત<br>(to page 1, line 2.A.)                                               |
| 2                                                                                                                                                                                                                                                                                                                                                                      |                                                                              |


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