# AMERICAN HERITAGE SECURITIES, INC. X-17A-5 (2021-03-29) — Broker-dealer annual report - Company: AMERICAN HERITAGE SECURITIES, INC. - Form: X-17A-5 - Filed: 2021-03-29 - Period: 2020-12-31 - Accession: 0000883126-21-000004 - CIK: 883126 - File #: 8-44466 - Material weakness: No - Auditor: HARTGRAVES ACCOUNTING & CONSULTING LLC - Auditor location: DALLAS, TX - Contact: JEFFREY THOMAS - Phone: 330-374-7500 - Signed by: JEFFREY THOMAS (PRESIDENT) Original filing: https://www.sec.gov/Archives/edgar/data/883126/000088312621000004/ahs2020annualaudit1.pdf --- {0}------------------------------------------------ **UNlTEDSTATES SECURITIESANDEXCHANGECOMMISSION Washington, D.C. 20549** ## **ANNUAL AUDITED REPORT FORM X-17A-5 PART Ill** | | 0MB APPROVAL | | |-------------------|--------------|--------------------------| | OMBNumber: | | 3235-0123 | | Expires: | | October 31, 2023 | | | | Estimated average burden | | hours oerresnonse | | . 12.00 | SEC FILE **NUMBER** 8-44466 **FACING PAGE** **Information Required of Brokers and Dealers Pursuant to Section 17 of the Securities Exchange Act of 1934 and Rule 17a-5 Thereunder** | REPORT FOR THE PERIOD BEGINNING 01/01/2020 | | | AND ENDING 12/31/2020 | | |-------------------------------------------------------------------------------------------|---------------------------------------------------------------------|---------|--------------------------------|--| | | MM/DD/YY | | MM/DD/YY | | | | A. REGISTRANT IDENTIFICATION | | | | | NAME OF BROKER-DEALER: American Heritage Securities, Inc. | | | OFFICIAL USE ONLY | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.) | | | FIRM I.D. NO. | | | 50 S. Main St. Suite 1210 | | | | | | | (No. and Street) | | | | | Akron | OH | | 44308 | | | (City) | (State) | | (Zip Code) | | | NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT
Jeffrey Thomas | | | 330-37 4-7500 | | | | | | (Area Code - Telephone Number) | | | | B. ACCOUNTANT IDENTIFICATION | | | | | INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report* | | | | | | Hartgraves Accounting and Consulting, LLC | | | | | | | (Name - if individual, state last. first, middle name) | | | | | 325 N. St. Paul Street Ste 3100 Dallas | | TX | 75201 | | | (Address) | (City) | (State) | (Zip Code) | | | CHECK ONE: | | | | | | I
✓
Certified Public Accountant | | | | | | 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 annual report be covered by the opinion of an independent public accountant must be supported by a statement of/acts and circumstances relied on as the basis/or the exemption. See Section 240.17a-5(e)(2)* > **Potential persons who are to respond to the collection of information contained In this form are not required to respond** unless the form displays a currently valid 0MB control number. SEC 1410 (11-05) {1}------------------------------------------------ #### **OATH OR AFFIRMATION** | I, Jeffrey Thomas | , swear (or affirm) that, to the best of | |------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | --------------------------
American Heritage Securities, Inc. | my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of
---
---
--------- | | of December 31 | -
-
-
-
, as
are true and correct. I further swear (or affirm) that | | classified solely as that of a customer, except as follows: | neither the company nor any partner, proprietor, principal officer or director has any proprietary interest in any account | | | | | This report** contains (check all applicable boxes):
0 (a) Facing Page.
0 (b) Statement of Financial Condition. | | | of Comprehensive Income (as defined in §210.1-02 of Regulation S-X). | 1ZJ (c) Statement of Income (Loss) or, if there is other comprehensive income in the period(s) presented, a Statement | | ✓ ( d) Statement of Changes in Financial Condition.
0 (e) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors' Capital. | | | D (f) Statement of Changes in Liabilities Subordinated to Claims of Creditors. | | | (g) Computation of Net Capital.
(h) Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3. | | | (i) Information Relating to the Possession or Contro.l Requirements Under Rule J 5c3-3.
~ | 0 (j) A Reconciliation, including appropriate explanation of the Computation ofNet Capital Under Rule 15c3-l and the
Computation for Determination of the Reserve Requirements Under Exhibit A of Rule 15c3-3. | | | 0 (k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of | | consolidation.
[21 ✓✓ (1) An Oath or Affirmation. | | | 0 (m) A copy of the SIPC Supplemental Report. | | | | D (n) A report describing any material inadequacies found to exist or found to have existed since the date of the previous audit. | \*\* *For conditions of confidential treatment of certain portions of this filing, see section 240. l 7a-5(e)(3).* {2}------------------------------------------------ ![](_page_2_Picture_0.jpeg) FINANCIAL STATEMENTS WITH ADDITIONAL INFORMATION YEAR ENDED DECEMBER 31 , 2020 {3}------------------------------------------------ ## YEAR ENDED DECEMBER 31, 2020 ## TABLE OF CONTENTS | REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM | 1 | |---------------------------------------------------------------------------------------------------------------------------------------------------------|-----------| | STATEMENT OF FINANCIAL CONDITION
December 31 , 2020 | 3 | | STATEMENT OF INCOME
Year ended December 31
, 2020 | 4 | | STATEMENT OF CHANGES IN STOCKHOLDER'S EQUITY
Year ended December 31
, 2020 | 5 | | STATEMENT OF CASH FLOWS
Year ended December 31
, 2020 | 6 | | NOTES TO THE FINANCIAL STATEMENTS | 7 -
10 | | SUPPLEMENTARY FINANCIAL INFORMATION | | | COMPUTATION OF NET CAPITAL PURSUANT TO RULE 15c3-1
December 31
, 2020 | 11 | | REPORT OF A BROKER-DEALER CLAIMING EXEMPTION FROM SEC RULE
15c3-3 | 13 | | INFORMATION RELATING TO POSESSION OR CONTROL REQUIREMENTS
UNDER RULE 15C3-3 OF THE SEC | 13 | | REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
REQUIRED BY SEC RULE 17a-5 FOR A BROKER-DEALER CLAIMING AN
EXEMPTION FROM SEC RULE 15c3-3 | 14 | | REPORT OF INDEPENDENT REGISTERED ACCOUNTANTS ON APPL YING
AGREED-UPON PROCEDURES | 15 | {4}------------------------------------------------ *i¾* # **Accounting & Consulting, LLC** #### **Report of Independent Registered Public Accounting Firm** To the Stockholder of American Heritage Securities, Inc. #### **Opinion on the Financial Statements** We have audited the accompanying statement of financial condition of American Heritage Securities, Inc. (the "Company") as of December 31, 2020, and the related statements of operations, changes in stockholders' equity and cash flows for the year then ended, and the related notes to the financial statements (collectively, the financial statements). In our opinion, the financial statements referred to above present fairly, in all material respects, the financial position of the Company as of December 31 , 2020, and the results of its operations and its cash flows for the year then ended in conformity with accounting principles generally accepted in the United States of America. #### **Basis for Opinion** These financial statements are the responsibility of the Company's management. Our responsibility is to express an opinion on the Company's financial statements based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to the Company in accordance with U.S. federal securities laws and the applicable rules and regu lations 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. The Company is not required to have, nor were we engaged to perform, an audit of its internal control over financial reporting. As part of our audit we are required to obtain an understanding of internal control over financial reporting but not for the purpose of expressing an opinion on the effectiveness of the Company's internal control over financial reporting. Accordingly, we express no such opinion. Our audit included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion. #### **Supplemental Information** The supplementary information contained in Schedule I, Computation of Net Capital Under Ru le 15c3-1 , Schedule II, Computation of Requirements Under Rule 15c3-3 (exemption) and Schedule Ill Information Relating to the Possession or Control Requirements Under Rule 15c3-3, all under the Rules of the Securities and Exchange Commission have been subjected to audit procedures performed in conjunction with the audit of the Company's financial statements. The Supplemental Information is the responsibility of the Company's management. Our audit procedures included determining whether the Supplemental Information reconciles to the financial statements or the underlying accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the Supplemental Information. In forming our opinion on the Supplemental {5}------------------------------------------------ Information, we evaluated whether the Supplemental Information, including its form and content, is presented in conformity with 17 C.F .R. § 240.1 ?a-5. In our opinion, the supplementary information contained in Schedule I, Computation of Net Capital Under Rule 15c3-1 , Schedule II, Computation of Requirements Under Rule 15c3-3 (exemption) and Schedule Ill Information Relating to the Possession or Control Requirements Under Rule 15c3-3, all under the Rules of the Securities and Exchange Commission are fairly stated, in all material respects, in relation to the financial statements as a whole. We have served as the Company's auditor since 2019. Dallas, Texas March 4, 2021 {6}------------------------------------------------ ## STATEMENT OF FINANCIAL CONDITION ## DECEMBER 31 , 2020 ## ASSETS | ASSETS | | |-----------------------------|---------------| | Cash | \$
223,505 | | Restricted cash | 25,000 | | Commissions receivable | 35,232 | | Property and equipment, net | 1,303 | | | \$
285,040 | | | | #### LIABILITIES AND STOCKHOLDER'S EQUITY | LIABILITIES | | |--------------------------------------------------------------|---------------| | Accounts payable | 51,548
\$ | | Accrued liabilities | 5,497 | | Note payable | 26,000 | | Interest payable | 170 | | Deferred clearing charge rebate | 74,995 | | | 158,210 | | STOCKHOLDER'S EQUITY | | | Common stock (15 shares authorized, issued, and outstanding) | 45,000 | | Retained earnings | 81,830 | | Total stockholder's equity | 126,830 | | | 285,040
\$ | {7}------------------------------------------------ #### STATEMENT OF INCOME #### FOR THE YEAR ENDED DECEMBER 31 , 2020 | REVENUES | | |-------------------------|---------------| | Commissions | \$
735,092 | | Distribution Fees | 179,899 | | Management fees | 618,045 | | Administrative fees | 97,656 | | Interest income | 56,862 | | Trading income (loss) | (16) | | Other income | 26,000 | | | 1,713,538 | | | | | EXPENSES | | | Commissions | 1,324,853 | | Depreciation | 610 | | Office related expenses | 7,533 | | Other expenses | 2,572 | | Insurance expenses | 19,659 | | Professional fees | 16,975 | | Regulatory fees | 9,905 | | Interest expense | 461 | | Communication expenses | 5,292 | | Tax expense | 4,490 | | Salaries and wages | 109,202 | | Software expenses | 83,281 | | | 1,584,833 | | | | | NET INCOME | \$
128,705 | {8}------------------------------------------------ ## STATEMENT OF CHANGES IN STOCKHOLDER'S EQUITY ## FOR THE YEAR ENDED DECEMBER 31 , 2020 | | Common
Stock | Retained
Earnings | Total | |----------------------------------|-----------------|----------------------|---------------| | Balance at December 31
, 2019 | \$
45,000 | \$
130,683 | \$
175,683 | | Net income | | 128,705 | 128,705 | | Dividends | | (177,558) | (177,558) | | Balance at December 31
, 2020 | \$
45,000 | \$
81,830 | \$
126,830 | {9}------------------------------------------------ ## STATEMENT OF CASH FLOWS ## FOR THE YEAR ENDED DECEMBER 31 , 2020 | | \$
128,705 | |-----------|---------------| | | | | | | | | | | \$
610 | | | | | | 8,646 | | | 25,000 | | | 249 | | | (3,134) | | | 170 | | | 450 | | | (20,004) | 11
,987 | | | 140,692 | | | | | | (177,558) | | | 26,000 | | | | | | (10,866) | | | 234,371 | | | 223,505 | | | | | | | | | \$ | CASH PAID DURING THE YEAR FOR: | LOCAL INCOME TAXES | \$
4,240 | |--------------------|-------------| | INTEREST EXPENSE | \$ | {10}------------------------------------------------ ## 1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES #### Nature of Businesses American Heritage Securities, Inc. (the Company) was incorporated in 1991 for the purpose of operating as a broker-dealer in securities. The Company operates as an introducing broker, whose services are limited to accepting customer orders. The Company has a business relationship with an independent clearing broker who is responsible for processing and settling customer transactions on a fully disclosed basis. The Company is registered with the Securities and Exchange Commission (SEC) and is a member of the Financial Industry Regulation Authority (FINRA). ## Use of Estimates The preparation of financial statements in conformity with U.S. generally accepted accounting principles (GAAP) requires management to make estimates and assumptions that affect the amounts reported in the financial statements and accompanying notes. Actual results could differ from those estimates. ## Restricted Cash Restricted deposits consist of cash. These deposits are restricted in accordance with the Company's agreement with its independent clearing broker, who is responsible for processing and settling customer transactions on a fully disclosed basis. #### Commissions Receivable Commissions receivable are from clearing organizations and mutual funds and are stated at the amount management expects to collect from outstanding balances related to commission fees and gains. Since these relate to commission fees receivable from customers, an allowance for doubtful accounts is not deemed necessary by management, nor is it required according to the computation for determination of reserve requirements pursuant to Rule 15c3-3. #### Property and Equipment Property and equipment are recorded at cost. Depreciation of property and equipment are provided by the use of accelerated and straight-line methods over the following estimated useful lives of the assets: | Furniture and fixtures | 3
-
5 | years | |------------------------|-------------|-------| | Office equipment | 3
-
5 | years | | Vehicle | 5 | years | #### Revenue Recognition #### Commission Revenue Commission revenue is generally recognized at a point in time upon delivery of contracted services based on a predefined contractual amount on a trade date for a trade execution services based on providing {11}------------------------------------------------ ## 1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (continued) market prices and internal and regulatory guidelines. Commission revenue consists of the sale of equity and fixed income securities and unit investment trusts. ## Management Fees The Company provides investment advisory services on a daily basis. The Company believes the performance obligation for providing advisory services is satisfied over time because the customer is receiving and consuming the benefits as they are provided by the Company. Fee arrangements are based on a percentage applied to the customer's assets under management. Fees are received quarterly and are recognized as revenue at that time as they relate specifically to the services provided in that period, which are distinct from the services provided in other periods. ## Distribution Fees ## Mutual Funds, Insurance and Annuity Products The Company earns revenue for selling affiliated and unaffiliated mutual funds, fixed variable annuities and insurance products. The performance obligation is satisfied at the time of each individual sale. A portion of the revenue is based on a fixed rate applied, as a percentage, to amounts invested at the time of sale. The remaining revenue is recognized over the time the client owns the investment or holds the contract and is generally earned based on a fixed rate applied, as a percentage, to the net asset value of the fund, or the value of the insurance policy or annuity contract. The ongoing revenue is not recognized at the time of sale because it is 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. #### Income Taxes American Heritage Securities, Inc. is taxed as an S-Corporation. The S-Corporation is subject to a built-in gain tax on the net appreciation of assets realized if they are sold within the first 5 years after the S election was made. The Company does not expect to incur any material tax expense as a result of built-in gain tax. No provision or liability for federal income taxes has been included in the financial statements. The Company is liable for city income tax as applicable. As of December 31 , 2020, the Company paid \$4,240 of city income tax. The Company's federal income tax returns for December 31, 2017, 2018, and 2019 are subject to examination by the Internal Revenue Service, generally for three years after they were filed . ## 2. NET CAPITAL REQUIREMENTS Pursuant to the net capital provisions of Rule 15c3-1 of the Securities Exchange Act of 1934, the Company is required to maintain a minimum net capital, as defined under such provisions. Net capital and the related net capital ratio may fluctuate on a daily basis. {12}------------------------------------------------ ## 3. NET CAPITAL REQUIREMENTS (continued) At December 31 , 2020, the Company had net capital of approximately \$125,527 and net capital requirements of \$5,000. The Company's ratio of aggregate indebtedness to net capital was 1.1 to 1. The Securities and Exchange Commission permits a ratio of no greater than 15 to 1. ## 4. RELATED PARTY TRANSACTIONS The Company shares office space and personnel with EGI Financial, Inc. (EGI). EGI is a related entity owned by the Company's sole stockholder. As compensation for this arrangement, the Company receives a management fee equal to 100% of EGl's advisory fee revenue. During the year ended December 31 , 2020, management fees from EGI totaled \$618,045. #### 5. PROPERTY AND EQUIPMENT Property and equipment as of December 31 , 2020 consists of: | Furniture and fixtures | \$
25,226 | |--------------------------------|--------------| | Less: Accumulated depreciation | (23,923) | | Property and equipment, net | \$
1,303 | #### 6. RETIREMENT PLAN The Company has a defined contribution retirement plan (the Plan) that meets the requirements of a "Savings Incentive Match Plan for Employees" (SIMPLE), as defined by the Internal Revenue Code. For the year ended December 31 , 2020, the Company contributed \$2,946 to the Plan. #### 7. INDEMNIFICATION In the normal course of its business, the Company indemnifies and guarantees certain service providers, such as clearing and custody agents, trustees and administrators, against specified potential losses in connection with their acting as an agent of, or providing services, to the Company. The maximum potential amounts of future payments that the Company could be required to make under these indemnifications cannot be estimated. However, the Company believes that it is unlikely it will be required to make significant payments under these arrangements and, therefore, no contingent liability has been recorded in the accompanying financial statements. #### 8. RISKS AND UNCERTAINTIES The Company's marketable securities are exposed to various risks such as interest rate, market and credit risks. The Company could incur losses or gains as a result of changes in the fair value of the securities and such changes could materially affect the Company's financial condition. {13}------------------------------------------------ ## 9. SUBSEQUENT EVENTS Management has evaluated the impact of all subsequent events through the date the financial statements were available to be issued and has determined that there were no subsequent events requiring disclosure in these financial statements. {14}------------------------------------------------ ## COMPUTATION OF NET CAPITAL PURSUANT TO RULE 15c3-1 ## DECEMBER 31 , 2020 | FORM
X-17A-5
LINE | | | |--------------------------------------|----------------------------------------------------------------------------------------------------|--------------------------| | 1 | COMPUTATION OF NET CAPITAL:
Total stockholder's equity from statement of
financial condition | 126,830
\$ | | 2 | Less: Stockholder's equity not allowable for net capital | | | 3 | Total stockholder's equity qualified for net capital | 126,830 | | 6D | Total other deductions | (1 ,303) | | 8 | Net capital before haircuts on security positions | 125,527 | | 9 | Haircuts on securities pursuant to 15c3-1 | | | 10 | Net capital | 125,527
\$ | | 11 | COMPUTATION OF BASIC NET CAPITAL REQUIREMENT:
Minimum net capital required | \$
8,803 | | 12 | Minimum dollar requirement | \$
5,000 | | 13 | Net capital requirement | \$
8,803 | | 14 | Excess net capital
Net capital
Less: Net capital requirement | 125,527
\$
(8,803) | | | Total | \$
116,724 | | 15 | Net capital less the greater of 10% of line 19 or 120% of line 12 | \$
112,323 | | AGGREGATE INDEBTEDNESS:
16 and 19 | Aggregate indebtedness liabilities | \$
132,040 | | 20 | Percent of aggregate indebtedness to net capital | 105.19% | | | Ratio of aggregate indebtedness | 1.1 to 1 | There were no material differences in the computation of net capital under Rule 15c3-1 from the Company's unaudited FOCUS II-A Report. See the Report of Independent Registered Public Accounting Firm. {15}------------------------------------------------ #### SUPPLEMENTARY FINANCIAL INFORMATION ## YEAR ENDED DECEMBER 31 , 2020 COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENT TO RULE 15c3-3 Not applicable due to exemption under Section (k)(2)(ii) and was considered a "Non-Covered Firm" by relying on footnote 74 to SEC Release 34-70073 to exempt the Company from Rule 15c3-3. RECONCILIATION BETWEEN NET CAPITAL COMPUTATION AND RESERVE REQUIREMENT COMPUTATION There are no material differences between the computation of net capital under Rule 15c3-1 as prepared by the Company and filed with their most recent Part IIA unaudited report and schedule included with these statements. INFORMATION RELATING TO POSESSION OR CONTROL REQUIREMENTS TO RULE 15C3-3 Not applicable due to exemption under (k)(2)(ii) and was considered a "Non-Covered Firm" by relying on footnote 74 to SEC Release 34-70073 to exempt the Company from Rule 15c3-3. {16}------------------------------------------------ *i¾* # **Accounting & Consulting, LLC** ## **Report of Independent Registered Public Accounting Firm** To the Board of Directors and the Stockholders of American Heritage Securities, Inc. We have reviewed management's statements, included in the accompanying Exemption Report, in which American Heritage Securities, Inc. (the Company) stated that: - 1. The Company identified the following provisions of 17 C.F .R. § 240.15c3-3(k) under which the Company claimed an exemption from 17 C.F.R. § 240.15c3-3: (k)(2)(ii) (the exemption provisions), and the Company stated that it met the identified exemption provisions throughout the most recent fiscal year without exception; - 2. The Company is also filing this Exemption Report because the Company's other business activities contemplated by Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 are limited to acting as a mutual fund retailer and acting as a broker or dealer selling variable life insurance or annuities. - 3. The Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers (other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of 17 C.F.R. § 240.15c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription-way basis where the funds are payable to the issuer or its agent and not to the Company); (2) did not carry accounts of or for customers; and (3) did not carry proprietary accounts of broker-dealers (as defined in 17 C.F.R. § 240.15c3-3), throughout the most recent fiscal year without exception. The Company's management is responsible for its statements. Our review was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included inquiries and other required procedures to obtain evidence about the Company's compliance with the exemption provisions of paragraph (k)(2)(ii) of Rule 15c3-3 and that the Company's other business activities were limited to acting as a mutual fund retailer and acting as a broker or dealer selling variable life insurance or annuities and (1 ) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers (other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of 17 C.F.R. § 240.15c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription-way basis where the funds are payable to the issuer or its agent and not to the Company); (2) did not carry accounts of or for customers; and (3) did not carry proprietary accounts of broker-dealers (as defined in 17 C.F.R. § 240.15c3-3) throughout the most recent fiscal year without exception. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, we do not express such an opinion. {17}------------------------------------------------ Based on our review, we are not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based on the provisions set forth in 17 C.F.R. § 240.15c3-3 and 17 C.F.R. § 240.17a-5. f/~ACCP~✓ ~~ *LL{;,* Dallas, TX March 4, 2021 {18}------------------------------------------------ ## **American Heritage Securities,** Inc. **Exemption Report** American Heritage Securities, Inc. {the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (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. §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}(2}(ii}. - (2) The Company met the identified exemption provisions in 17 C.F .R. §240.15c3-3(k) throughout the most recent fiscal year without exception. - (3} The Company is considered "Non-Covered Firm" exempt from 17 C.F.R. §240.15c3-3 and is filing an Exemption Report relying on footnote 74 to SEC Release 34-70073, and as discussed in Q&A 8 of the related FAQ issued by the SEC staff. The Company limits its business activities exclusively to: { 1) acting as a mutual fund retailer (2) acting as a broker or dealer selling variable life insurance or annuities. - (4) The Company (1} did not directly or indirectly receive, hold or otherwise owe funds or securities for or to customers, other than money or other consideration received and promp~y transmitted in compliance with paragraph (a) or (b)(2) of Rule 15c2-4; (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3), throughout the most recent fiscal year without exception. I, Jeffrey Thomas, swear {or affirm} that, to my best knowledge and belief, this exemption report is true and correct. Date of Report: February 12, 2021 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.