# MEEDER DISTRIBUTION SERVICES, INC. X-17A-5 (2026-03-02) — Broker-dealer annual report - Company: MEEDER DISTRIBUTION SERVICES, INC. - Form: X-17A-5 - Filed: 2026-03-02 - Period: 2019-12-31 - Accession: 0000926174-26-000002 - CIK: 926174 - File #: 8-47374 - Type: Broker-dealer - Material weakness: No - Auditor: HHH CPA Group LLC - Auditor location: Columbus, OH - Contact: Douglas R Cooper - Phone: 6147602104 - Email: rdun1as@hhhcpagroup.com - Website: hhhcpagroup.com - Signed by: Douglas R Cooper (President/Treasurer) Original filing: https://www.sec.gov/Archives/edgar/data/926174/000092617426000002/2019.pdf --- {0}------------------------------------------------ **UNITED STATES SECURITIESANDEXCHANGECOMMISSION Washington, D.C. 20549** # **ANNUAL AUDITED REPORT FORM X-17A-5 PARTIII** | 0MB APPROVAL | | | | | | |----------------------------|-----------------|--|--|--|--| | 0 MB Number: | 3235-0123 | | | | | | Expires: | August 31, 2020 | | | | | | Estimated average burden | | | | | | | hours oer response 12.00 | | | | | | | SEC FILE NUMBER | |-----------------| | eA7374 | **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 TIIE PERIOD BEGINNING | -----------
01/01/19 | AND ENDING | -----------
12/31/19 | | | |---------------------------------------------------------------------------------------------|--------------------------------------------------------|------------|--------------------------------|--|--| | | MM/DD/YY | | MM/DU/YY | | | | | A. REGISTRANT IDENTIFICATION | | | | | | NAME OF BROKER-DEALER: Adviser Dealer Services, Inc. | | | OFFICIAL USE ONLY
36773 | | | | ADDRESS OF PRTNCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.) | | | FIRM I.D. NO. | | | | | 6125 Memorial Drive | | | | | | | (No. and Slrcct) | | | | | | IDubllrn | Olriio | | 43017 | | | | (Ci Ly) | (State) | | (Zip Code) | | | | NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT
Douglas R Cooper | | | (614) 760-2104 | | | | | B. ACCOUNTANT IDENTIFICATION | | (Area Code - Telephone Number) | | | | HHH CPA Group LLC | (Name - ,f individual, state last. first, middle name) | | | | | | 1250 Old Henderson Road | Columbus | Ohio | 43220 | | | | (Address) | (City) | (State) | (Zip Code) | | | | CHECK ONE:
I a/ I
Certified Public Accountant | | | | | | | Public Accountant | | | | | | | B
Accountant not resident in United States or any of its possessions. | | | | | | | | FOR OFFICIAL USE ONLY | | | | | | | | | | | | | | | | | | | | | | | | | | *must be supported by a statement of facts and circumstances relied on as the ba~·isfor the exemption. See Section 240. l 7a-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 OM B control number.** SEC 1410 (11-05) {1}------------------------------------------------ #### **OATH OR AFFIRMATION** | 1, Douglas R Cooper
, swear (or affirm) that, to the best of | |---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of
----------
---------------
----------'-------
Adviser Dealer Services, Inc. | | -
-
-
-
-
, as
of February 27
arc true and correct. l further swear (or affirm) that | | neither the company nor any partner, proprietor, principal officer or director has any proprietary interest in any account | | classified solely as that of a customer, except as follows: | | Ir ,,,
,, _._i,.
,,, ~~~'-,c_: ;;,!~,.~ >-
,,~
.:- vq-.S , , - \ f / ·-,o-<-
, | | ___
· · -~%
f ~rt;,•~'-:\
'1,--\____:=-_-1,_S_ig_n,1.
~
at~ur_e _
_ | | :j
t!:~';· Q
:
e:==•O
- | | )freJdent/TreasurerTitle
{
~ ::~
_; | | ~#~~
L ~c;;;J I'( •·;}~-
\ | | \~~
--
---. ~1~i:.-,,;:~ ~"l
=--:._---"""'-µ.=----"",<--\----
~ IN DE\J'~ ~ """.,,
-%,,,~
~
,,,,,,,'Ss,oN 8<.~~~ ,,~
,,,,.,. 11•' | | This report*"' contains (check all applicable boxes):
B (a) Facing Page. | | B (h) Statement of Financial Condition. | | ~ (c) Statement of Income (Loss) or, if there is other comprehensive income in the pcriod{s) presented, a Statement | | of Comprehensive Income (as defined in §210.1-02 of Regulation S-X).
Statement of Changes in Financial Condition. | | Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors' Capital. | | Statement of Changes in Liabilities Subordinated to Claims of Creditors. | | Computation o[Net Capital. | | Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3.
Information Relating to the Possession or Control Requirements Under Ruic l 5c3-3. | | A Reconciliation, including appropriate explanation ofthc Computation of Net Capital Under Ruic 15c3-l and the | | Computation for Determination of the Reserve Requirements Under Exhibit A of Rule 15c3-3. | | D (k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of | | consolidation.
(I) An Oath or Affirmation. | | (m) A copy of the S!PC Supplemental Report. | | (n) A report describing any material inadequacies found to exist or found to have existed since the date of the previous audit | | * *For conditions of confidential trearment of certain portions of this filing. see section 240.1 ?a-5 (e)(3). | {2}------------------------------------------------ ADVISER DEALER SERVICES, INC. FINANCIAL STATEMENTS DECEMBER 31, 2019 AND 2018 {3}------------------------------------------------ #### DECEMBER 3 1, 2019 ## TABLE OF CONTENTS | ANNUAL AUDITED REPORT FORM X-1 7 A-5 PART III
2 -
3 | |--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | INDEPENDENT AUDITORS' REPORT
4 -
5 | | STATEMENTS OF FINANCIAL CONDITION
December 31, 2019












6 | | STATEMENTS OF OPERATIONS
Years ended December 31, 2019 and 2018 7 | | STATEMENTS OF CHANGES IN STOCKHOLDER'S EQUITY
Years ended December 31, 2019 and 2018 8 | | STATEMENTS OF CASH FLOWS
Years ended December 31, 2019 and 2018
9 | | 10-
15
NOTES TO FINANCIAL STATEMENTS | | 18
SUPPLEMENTARY INFORMATION


16 - | | SEC RULE 15C3-3 EXEMPTION REPORT 19 | | 20
REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM | | REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
ON APPLYING AGREED-UPON PROCEDURES RELATED TO AN ENTITY'S
CLAIM FOR EXCLUSION FROM MEMBERSHIP IN SIPC 21-
22 | {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) Richard B. Durnas, CPA rdun1as@hhhcpagroup.com **Dontinic J. OiBartolornt:oJ C..PA** nick@hhhcpagmup.com #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Board of Directors of Adviser Dealer Service, Inc. Dublin, Ohio #### **Opinion on the Financial Statements** We have audited the accompanying statements of financial condition of Adviser Dealer Service, Inc. as of December 31, 2019 and 2018, and the related statements of operations, changes in stockholder's equity, and cash flows for the years then ended, and the related notes [and schedules] (collectively referred to as the financial statements). In our opinion, the financial statements present fairly, in all material respects, the financial position of Adviser Dealer Service, Inc. as of December 31, 2019 and 2018, and the results of its operations and its cash flows for the years 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 Adviser Dealer Service, Inc.'s management. Our responsibility is to express an opinion on Adviser Dealer Service, Inc.'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 Adviser Dealer Service, Inc. in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. **We** believe that our audit provides a reasonable basis for our opinion. ## HHH CPA Group LLC 1250 Old Henderson Road Columbus, OH 43220 614.451.4644 Office • 614.451.3818 Fax www.hhhcpagwup.com Member; Am.erican In"stitute of Certified Public Au.:ountants {5}------------------------------------------------ #### **Supplemental Information** The schedule of Computation of Net Capital Under Rule 15c3-l of the Securities and Exchange Commission and Reconciliation with Company's Computation of Net Capital as Included in Part IIA of Form X-17A-5 has been subjected to audit procedures performed in conjunction with the audit of Adviser Dealer Service, Inc. 's financial statements. The supplemental information is the responsibility of Adviser Dealer Service, Inc.'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 information, we evaluated whether the supplemental information, including its form and content, is presented in conformity with 17 C.F.R. §240.17a-5. In our opinion, the Computation of Net Capital Under Rule 15c3-1 of the Securities and Exchange Commission and Reconciliation with Company's Computation of Net Capital as Included in Part IIA of Form X-17 A-5 is fairly stated, in all material respects, in relation to the financial statements as a whole. */11t11 Llt9 G,.,,t-J, Llt-* HHH CPA Group, LLC We have served as Adviser Dealer Service, Inc.'s auditor since 2012. Columbus, Ohio February 27, 2020 {6}------------------------------------------------ #### **STATEMENTS OF FINANCIAL CONDITION** #### **DECEMBER 31, 2019 AND 2018** | ASSETS | 2019 | 2018 | |------------------------------------------------------|---------------|---------------| | Cash | \$
136,347 | \$
54,158 | | Accounts receivable | 273 | 444 | | Accounts receivable - related party | 295,899 | 371,103 | | Prepaid expense | 24,958 | 826 | | Total current assets | 457,477 | 426,531 | | | \$
457,477 | \$
426,531 | | LlABILfTIES AND STOCKHOLDER'S EQUITY | | | | Accounts payable | \$ | \$ | | Accounls payable - related party | | | | Commissions payable | 310,287 | 264,038 | | Accrued liabilities | 43,000 | 58,303 | | Total current liabilities | 353,287 | 322,341 | | Long-term liabilities | | | | Total liabilities | 353,287 | 322,341 | | Stockholder's equity: | | | | Common stock; no par value, 1,000 shares authorized, | | | | issued and outstanding | 10,000 | 10,000 | | Paid in capil8.l | 740,000 | 740,000 | | Retained earnings | (645,810) | (645,810) | | Total stockholder's equity | 104,190 | 104,
190 | | | \$
457,477 | \$
426,531 | {7}------------------------------------------------ #### **STATEMENTS OF OPERATIONS** #### **FOR THE YEARS ENDED DECEMBER 31, 2019 AND 2018** | | 2019 | 2018 | |----------------------------------------|-----------------|-----------------| | Revenues: | | | | Affiliated entities fees | \$
8,296,068 | \$
5,259,140 | | 12b-1 fees | 93,916 | 86,497 | | Commissions | 5,664 | 29,078 | | Interest | 1,838 | 3,572 | | Total revenues | 8,397,486 | 5,378,287 | | Expenses: | | | | Salaries | 3,772,055 | 2,957,948 | | Commissions | 2,415,278 | 2,212,624 | | General, Administrative and Regulatory | 1,810,688 | | | Marketing reimbursement | 93,916 | 86,497 | | Registration fees | 53,145 | 45,634 | | Professional fees | 11,570 | 9,500 | | Other | 240,834 | 66,084 | | Total expenses | 8,397,486 | 5,378,287 | | Net income/(loss) | \$ | \$ | | | | | {8}------------------------------------------------ #### **STATEMENTS OF CHANGES IN STOCKHOLDER'S EQUITY** #### **FOR THE YEARS ENDED DECEMBER 31, 2019 AND 2018** | | 2019 | 2018 | |---------------------------------|---------------|---------------| | Common Stock: | | | | Bc1lance at beginning of period | \$
10,000 | \$
10,000 | | Issued/ (Repurchased) stock | | | | Balance at end of period | 10,000 | 10,000 | | Paid In Capital: | | | | B.llance at beginning of period | 740,000 | 740,00U | | Contributed capital | | | | Balance at end of period | 740,000 | 740,000 | | Retained Earnings: | | | | Balance at beginning of period | (645,810) | (645,810) | | Net income/ (loss) | | | | Distributions | | | | Balance at end of period | (645,810) | (645,810) | | Total stockholder's equity | \$
104,190 | \$
104,190 | {9}------------------------------------------------ #### **STATEMENTS OF CASH FLOWS** #### **FOR THE YEARS ENDED DECEMBER 31, 2019 ANO 2018** | | 2019 | 2018 | |--------------------------------------------------------|---------------|--------------| | Cash flows from operating activities: | | | | Net income/ (loss) | \$ | \$ | | Adjustments lo reconcile net income/(loss) to net cash | | | | used in operating activities: | | | | (Increase) decrease in: | | | | Accounts receivable | 171 | 2,240 | | Accounts receivable -
related party | 75,204 | (340,266) | | Prepaid expense | (24,132) | 90 | | Deposit with clearing organiw.tion | | | | Increase (decrease) in: | | | | Accounts payable | | (2,000) | | Accounts payable -
related party | | (55,963} | | Commissions payable | 46,249 | 109,224 | | Accmed liabilities | (15,303) | 49,303 | | Total adjustments | 82,189 | (237,372) | | Net cash used in opcrating activities | 82,189 | (237,372) | | Cash flows from investing activitie1> | | | | Cash tlows from financing activities: | | | | Net decrease in cash | 82,189 | (237,372) | | Cash at beginning of period | 54,158 | 29 1,530 | | Cash at end of period | \$
136,347 | \$
54,158 | | Supplemental disclosures: | | | | lntl:rest paid | \$ | \$ | | | | | | Income taxes paid | \$ | \$ | {10}------------------------------------------------ ## **NOTES TO FINANCIAL STATEMENTS** ## **DECEMBER 31t 2019 AND 2018** ## Note 1 - Summary of Significant Accounting Policies #### A. Organization Adviser Dealer Services, Inc. (the Company) has been operating as a broker-dealer registered with the Securities and Exchange Commission (SEC) and the Slate of Ohio Securities Division; it is a member of the Financial Tndustry Regulatory Authority, Inc. (FINRA). The Company operates pursuant to Exchange Act Rule 15c3-3(k)(l). Customer accounts held directly at a product issuer for which the Company is listed as the broker-dealer of record. The Company does not hold customer funds or safeguard customer securities. As of December 31, '.2019, the Company is licensed in 48 states, excluding Florida and Tex.:J.s. #### B. Management's Estimates The preparation of financial statements in conformity with generally accepted accounting principles requires management to make estimates and assumptions that affect reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements, and the reported amounts of revenue and expenses during the reporting period. Actual results could differ from those estimates. ## C. Cash The Company maintains cash balances at one bank and in several money market accounts. The cash bahmce in the bank was under lhe federally insured limit of \$250,000 as of December 31, 2019. Por purpo8es or the sta ternent of cash llows, the Company considers all cash in checking accounts and money market accounts to be cash equivalents. #### D. Concen tration of Credit Risk Financial instruments that potentially subject the Company to significant concentrations of credit risk consist principally of cash and commissions receivable. The Company places its cash with high credit quality financial institutions, which at times may be in excess of FDIC insurance limits. The Company's receivables represent commissions from completed securities trades. {11}------------------------------------------------ ## **NOTES TO FINANCIAL STATEMENTS** ## **DECEMBER 31, 2019 AND 2018** ## Note l - Summary of Significant Accounting Policies - Continued #### E. Fair Value Measurements Financial Accounting Standards Board Statement No. 157 , Fair Value Measurements (FASB Statement No. 157), establishes a framework for measu ring fair value. That framework provides a fair value hierarchy that prioritizes the inputs to valuation techniques used to measure fair value. The hierarchy gives the highest priority to u nadjusted quoted prices in active markets for identical assets or liabilities (level 1 measurements) and the lowest priority to unobservable inputs (level 3 measurements). The three levels of the fair value hierarchy under FASB Statement No. 157 are described below: - Level 1 inputs to the valuation methodology are unadjusted quoted prices for identical assets or liabilities in aclive markets that the Plan has the ability to access. - Level 2 Inputs to the valuation methodology include: Quoted prices for similar assets or liabilities in active markets; Quoted prices for identical or similar assets or liabilities in inactive marke ts; Inputs other than quoted prices that arc observable for the asset or liability; Inputs that arc derived principally from ur corroborated by observable market data by correlation or other means. If the asset or liability has a specified (contractual) term, the Level 2 input must be observable for substantially the full term of the asset or liability. Level 3 Inputs to the valuation methodology are unobservable and significant to the fair value measurement. The asset's or liability's fair value measurement level within th e fair value hierarchy is based on the lowest level of any input that is significant to the fair value measurement. Valuation techniques used need to maximize the use of observable inputs an d minimize the u se of u nobservable inputs. Following is a description of the valua tion methodologies used for assets measured a t fair value. There have been no changes in lhe methodologies used a t Decem ber 31, 2019. {12}------------------------------------------------ ## **NOTES TO FINANCIAL STATEMENTS** ## **DECEMBER 31, 2019 AND 2018** ## Note 1 - Summary of Significant Accounting Policies - Continued ## E. Fair Value Measur emenls (continued) Money Market Funds: Valued at the net asset value ('NAV") of shares held by the Company at year end. | Assets (2019) | Level 1 | Level-2 | Level 3 | Total | |---------------|-------------|---------|---------|-----------| | Money Market | \$1 lfi,424 | \$ | \$ | \$116,424 | | | | | | | | Total assets | W6,424 | L | L__ - | li6.424 | | Assets (2018} | Level 1 | Level 2 | Level 3 | Total | | Money Market | \$25,120 | \$ | \$ | \$25,120 | | | | | | | | | | | \$_ | | #### F. Securities Transactions and Revenue Recognition Securities transactions, commissions and related expenses are reported on a trade date basis. The change in the resulting difference between cost and market is included in net trading profits in the statement of income. The Company's activities are transacted on either a cash or margin basis. Margin transactions arc subject to various regulatory and internal m21rgin requirements and are collateralized by cash and securities in the Company's accounts. Commission expense is also recorded on a trade-date bc1.sis as security transactions occur. #### G. Receivables Accounts receivable are stated at the amount billed. Management individually reviews all receivable balances and based on an assessment ofcurrenl creditworthiness, estimates the portion, if any, of the balance that will not be collected. In the opinion of management, all receivables are considered collectible and no allowance was necessary at December 31, 2019. Accounts receivable - related party are stated at the amount billed. Registered representative affiliation fees, commission charge backs and other costs that are the responsibility ofregistered representatives or entities with common control arc offset against amounts owed to these representatives or entities. If the balance of the debits owed to the Company exceeds the amount owed to the registered representatives or the entities, the net balance owed to the Company is recorded as a receivable. {13}------------------------------------------------ ## **NOTES TO FINANCIAL STATEMENTS** ## **DECEMBER 31, 2019 AND 2018** #### Note l - Summary of Significant Accounting Policies ~ Continued #### H. Government and Other Regul ation s The Company's business is subject to significant regulations by various governmental agencies and self-regulatory organizations. Such regulation includes, among other things, periodic examinations by these regulatory bodies to determine whether the Company is conducting and reporting its operations in accordance with the requirements of these organizations. As a registered broker-dealer, the Company is subject to the SEC's Net Capital Rule 15c3-l which requires that the Company maintains a minimum net capital, as defined [see Note 3]. #### Note 2 - Reserve Requirements The Company is not obligated to report under SEC Rule 15c3-3 since it does not maintain customer accounts or hold securities. Therefore, the Company does not have a reserve requirement nor does it have any information relating to the possession or control requirement under Rule 15c3-3. ## Note 3 - Net Capital Requirements (Schedules I and II) Under SEC Rule 15c3-1, the Company is required to maintain net capital of not less than the greater of 6.67% of total liabilities, exclusive of subordinated debt, for the year ended December 31, 2019, \$23,552 or \$5,000. At December 31, 2019 the Company's net capital as defined by SEC Rule 15c3-l was \$53,352 in excess of the minimum net capital required. ln addition to the minimum net capital provision, SEC Rule 15c3-1 requires that the Company maintain a ratio of aggregate indebtness, as defined, to capital, of not more than 15 to 1. At December 31, 2019 the ratio was 4.5939 to 1. #### Note 4 - Related Parties The Company is the Distributor and principal agent for the sale and distribution of the Meeder Funds. Pursuant to this agreement, the Company is entitled to reimbursement under the Meeder Funds Shareholder Distribution Plan for costs actually incurred by the Company, which is included in the related party receivable in the accompanying balance sheet. These services accounted for \$93,916 in revenues during the year. The Company is affiliated through common ownership with Meeder Asset Management, Inc. (MAM), which provides marketing services and other overhead costs. At December 31, 2018, MAM owed the Company \$269,448 for the above mentioned services, which is included in the related party payable in the accompanying balance sheet. The Company is also paid a fee by MAM for various administrative services relating to licensing of representatives. These services accounted for \$7,998,021 in expenses during the year. {14}------------------------------------------------ #### **NOTES TO FINANCIAL STATEMENTS** ## **DECEMBER 31, 2019 AND 2018** ## Note 4 - Related Parties - Continued The Company from time to time invests cash balances in th e Meeder Funds Money Ma rket Fu n d [the Fund). The Fu nd is managed by MAM, and certain officers of the Company, Meeder Investment Management, In c. , and MAM are also officers and/ or trustees of the Fund. At December 3 1, 2019 , cash and cash equivalents included \$ 116 ,424 invested in th e Fund. ## Note 5 - Income Taxes Meeder Investment Management, Inc. files a consolidated income tax re turn wh ich inclu des the Company and other related entities. Meeder Investment Management, Inc. has elec ted to be treated as un S corp oration under the provision or Section 1362(a ) of the internal Revenue Code (IRC), and the Company qualifies as a QSUB as defined by the IRC, which allows for the Com pany's income to be taxed directly to Meeder Fin ancial, Inc. As a result, no provision for federal income taxes has been recognized. The Company recognizes and discloses u ncertain tax p ositions in accord ance with accounting principles gene rally accepted in th e United States of America (US GAAP). As of an d during th e year ended December 31, 2 0 19 , the Company did n ot h ave a liability for unrecognized tax benefits. The Company is no longer subject to examination by federal and state ta.'\$ | |--------------------------------------------------------------------------------------------------------------|-------------------------| | Non-allowable assets: Other assets | 24
,827 | | Net capital before haircuts on securities positions | 79,232 | | Haircuts on security positions | 2,328 | | Total net capital | \$ -
76.904 | | Minimum net capital requirement -
greater of \$5,000 or
6 2/ 3% of aggregate indebtedness of \$322,341 | 23,552 | | Excess net capital | \$
_ 53.352 | | Ratio of aggregate indebtedness to net capital | 4.5939 to 1 | | Schedule of aggregate indebtedness
Accounts payable and accrued liabilities
Commissions payable | 43,000
\$
310,287 | | Total aggregate indebtedness | \$ 353!287 | {18}------------------------------------------------ #### **SUPPLEMENTARY SCHEDULES** #### **AS OF DECEMBER 31, 2019** #### **Schedule II** #### **Reconciliation with Company's Computation of Net Capital as Included in Part HA of Form X-l 7A-5** | Net capital, as reported in Company's Part IIA (unaudited)
FOCUS report | \$ 76,904 | |----------------------------------------------------------------------------|-----------| | Audit adjustments | - ) | | Net capital per audited financial statements | \$ 76.9Q4 | No material differences were found during the audit that affected the net capital calculation. #### **Schedule III** ## **Computation of Reserve Requirement under Rule 15c3-l of the Securities and Exchange Commission** In accordance with the exemptive provisions of SEC Rule 15c3-3, specifically exemption k(l), the Company is exempt from the computation of a reserve requirement and the information relating to the possession or control requirements. {19}------------------------------------------------ ## **SEC Rule 15c3-3 Exemption Report** Board of Directors Adviser Dealer Services, Jnc. Adviser Dealer Services, Inc. (the Company) is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 CFR 240.17a-5 - "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 CFR 240. l 7a-5(d)(l) and (4). To the best of its knowledge the Company states the following: The Company is exempt from Rule 1 7 CFR 15c3-3 under provision (k)( 1) of Rule l 5c3-3 of the Securities Exchange Act of 1934. The Company met the identified exemption provision identified above throughout the most recent fiscal year ended December 31, 2019, without exception. Adviser Dealer Services, Inc. *o~~-* I, swear (or affirm) that, to my best knowledge and belief, this Exemption Report is true and correct. Douglas R. Cooper President & Treasurer February 27, 2020 {20}------------------------------------------------ ![](_page_20_Picture_0.jpeg) Richard R, Dumas, CPA rd umas@hhhcpagrnup.com Dominic J. biRartnlornco, CPA nick@hhbcpagroup.com #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Board of Directors of Adviser Dealer Services, Inc. Dublin, Ohio We have reviewed management's statements, included in the accompanying SEC Rule 15c3-3 Exemption Report, in which (1) Adviser Dealer Services, Inc. identified the following provisions of 17 C.F.R. §15c3-3(k) under which Adviser Dealer Services, Inc. claimed an exemption from 17 C.F.R. §240.15c3-3: (1) (the "exemption provisions") and (2) Adviser Dealer Services, Inc. stated that Adviser Dealer Services, lnc. met the identified exemption provisions throughout the most recent fiscal year without exception. Adviser Dealer 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 Adviser Dealer Services, lnc.'s compliance with the exemption provisions. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, we do not express such an opinion. Based on our review, we are not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based on the provisions set forth in paragraph (k)(l)) of Rule 15c3-3 under the Securities Exchange Act of 1934. /iffft *LIil G,-,.,17, LL,:\_* HHH CPA Group, LLC Columbus, Ohio February 27, 2020 > HHH CPA Group LLC 1250 Old Henderson Road Columbus, OH 43220 614.451.4644 Office • 614.451.3818 Fax www.hhhcpagroup.com Member: American In's titute of Certified Public Accoun tams {21}------------------------------------------------ ![](_page_21_Picture_0.jpeg) Richarcl R, Dumas, CPA rclumas@hhhcpagn,up,con~ Dominic J. DiBartolomeo, CPA nick@)hhhcpagroup,c:om #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM ON APPLYING AGREED-UPON PROCEDURES RELATED TO AN ENTITY'S CLAIM FOR EXCLUSION FROM MEMBERSHIP IN SIPC To the Board of Directors of Adviser Dealer Service, Inc. Dublin, Ohio We have performed the procedures included in Rule 17a-5(e)(4) under the Securities Exchange Act of 1934 and in the Securities Investor Protection Corporation (SIPC) Series 600 Rules, which are enumerated below and were agreed to by Adviser Dealer Service, Inc. and the SIPC, solely to assist you and the SIPC in evaluating Adviser Dealer Service, Inc.'s compliance with the exclusion requirements from membership in SIPC under section 78ccc(a)(2)(A) of the Securities Investor Protection Act of 1970 for the year ended December 31, 2019, as noted on the accompanying Certification of Exclusion From Membership (Form SIPC-3). Adviser Dealer Service, lnc.'s management is responsible for its Form SIPC-3 and for its compliance with those requirements. This agreed-upon procedures engagement was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States} and in accordance with attestation standards established by the American Institute of Certified Public Accountants. 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 Total amount included in the accompanying Schedule of Form SIPC-3 Revenues prepared by Adviser Dealer Service, Inc. for the year ended December 31, 2019 to the total revenues in Adviser Dealer Service, Inc.'s audited financial statements included on Annual Audited Report Form X-1 7 A-5 Part III for the year ended December 31, 2019, noting no differences; - 2) Compared the amount in each revenue classification reported in the Schedule of Form SIPC-3 Revenues prepared by Adviser Dealer Service, Inc. for the year ended December 31, 2019 to the internal financial statements and supporting documentation, noting no differences; - 3) Recalculated the arithmetical accuracy of the Total Revenues amount reflected in the Schedule of Form SIPC-3 Revenues prepared by Adviser Dealer Service, Inc. for the year ended December 31, 2019 and in the related internal financial statements and supporting documentation, noting no differences. **HHH** CPA Group LLC 1250 Old Henderson Road Columbus, OH 43220 614.451.4644 Office • 614.451.3818 Fax www.hhhcpagroup.com Member: American In·stitute of Certified Public Accountants {22}------------------------------------------------ We were not engaged to and did not conduct an examination or review, the objective of which would be the expression of an opinion or conclusion, respectively, on Adviser Dealer Service, lnc.'s compliance with the exclusion requirements from membership in SIPC for the year ended December 31, 2019. Accordingly, we do not express such an opinion or conclusion. 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 Adviser Dealer Service, Inc. and the SIPC and is not intended to be and should not be used by anyone other than these specified parties */11t11* Lf?fJ *G#y?, LLc:\_.* HHH CPA Group, LLC Columbus, Ohio February 27, 2020 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.