# MID-CONTINENT SECURITIES ADVISORS, LTD. X-17A-5 (2019-03-01) — Broker-dealer annual report - Company: MID-CONTINENT SECURITIES ADVISORS, LTD. - Form: X-17A-5 - Filed: 2019-03-01 - Period: 2018-12-31 - Accession: 0001171134-19-000001 - CIK: 1171134 - File #: 8-65298 - Material weakness: No - Auditor: Bauer & Company, LLC - Auditor location: Austin, TX - Contact: Kristy Johnson - Phone: 2813670380 - Signed by: William H. Van Pelt, IV (President, FINOP) Original filing: https://www.sec.gov/Archives/edgar/data/1171134/000117113419000001/midcontinent.pdf --- {0}------------------------------------------------ UNITED STATES SECURITIESANDEXCHANGECOMMISSION Washington, D.C. 20549 # **ANNUAL AUDITED REPORT FORM X-17 A-5 PART Ill** | OMB APPROVAL | | |--------------------------|---------------------------| | OMB Number: | 3235-0123 | | Expires: | August 31, 2020 | | Estimated average burden | | | | hours per response 12.00 | | | SEC FILE NUMBER | |----|-----------------| | 8- | | ## 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 01/01/2018 | | AND ENDING 12/31/2018 | | |------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------|-----------------------|------------------------------------| | | MM/DD/YY | | ----------------------
MM/00/YY | | | A. REGISTRANT IDENTIFICATION | | | | NAME oF BROKER-DEALER: Mid-Continent Securities Advisors, Ltd. | | | OFFICIAL USE ONLY | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.) | | | FIRM 1.0. NO. | | 1218 Webster Street | | | | | | (No. and Street) | | | | Houston | TX | | 77002 | | (City) | (State) | | (Zip Code) | | NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT
William H. Van Pelt, IV | | | 713-289~200 | | | | | (Area Code- Telephone Number) | | | B. ACCOUNTANT IDENTIFICATION | | | | INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report* | | | | | Bauer & Company, LLC | | | | | | (Name- if individual, state last, first, middle name) | | | | 5910 Courtyard Drive #230 | Austin | TX | 78731 | | (Address) | (City) | (State) | (Zip Code) | | CHECK ONE: | | | | | l.f I
Certified Public Accountant | | | | | Public Accountant | | | | | B
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 facts and circumstances relied on as the basis for the exemption. See Section 240.17 a-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 OMB control number. SEC 141 0 (06-02) {1}------------------------------------------------ ## **OATH OR AFFIRMATION** IWilliam H. Van Pelt, IV ' \_\_\_\_\_\_\_ \_:\_\_ \_\_\_\_\_ ------- , swear (or affirm) that, to the best of my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of Mid-Continent Securities Advisors, Ltd. as of December 31 • 20\_1\_8 \_ \_\_, are true and correct. I further swear (or affirm) that neither the company nor any partner, proprietor, principal officer or director has any proprietary interest in any account classified solely as that of a customer, except as follows: ![](_page_1_Picture_6.jpeg) Signature President, FINOP Title ~C).~ ~y Public --- This report\*\* contains (check all applicable boxes): - **0** (a) Facing Page. - -1 (b) Statement of Financial Condition. - 1 (c) Statement of Income (Loss). - (d) Statement of Changes in Financial Condition. - *-t* (e) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors' Capital. - (f) Statement of Changes in Liabilities Subordinated to Claims of Creditors. - "' (g) Computation of Net Capital. - (h) Computation for Determination of Reserve Requirements Pursuant to Rule l5c3-3 . - - ./ (i) Information Relating to the Possession or Control Requirements Under Rule 15c3-3. **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. - ~ (l) An Oath or Affirmation. - 0 {m) A copy of the SIPC Supplemental Report. - **0** (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 240.17a-5(e)(3).* {2}------------------------------------------------ ![](_page_2_Picture_0.jpeg) ## REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Board of Directors and Partners of Mid-Continent Securities Advisors, Ltd. ## **OtJinion on the Financial Statements** We have audited the accompanying statement of financial condition of Mid-Continent Securities Advisors, Ltd. as of December 31, 2018, the related statements of operations, changes in partners' equity, and cash flows for the year 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 Mid-Continent Securities Advisors, Ltd. as of December 31, 2018, 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 Mid-Continent Securities Advisors, Ltd.'s management. Our responsibility is to express an opinion on Mid-Continent Securities Advisors, Ltd.'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 Mid-Continent Securities Advisors, Ltd. 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 perfonn 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. ## **Auditor's Report on SuptJlemental Information** The Computation of Net Capital and Aggregate Indebtedness Under Rule 15c3-1 (Schedule I), the Computation for Determination of Reserve Requirements Under Rule l5c3 -3 (Schedule II) and the Infonnation Relating to the Possession or Control Requirements Under Rule 15c3-3 (Schedule III) {collectively, the "Supplemental lnfonnation") has been subjected to audit procedures perfonned in conjunction with the audit of Mid-Continent Securities Advisors, Ltd.'s financial statements. The Supplemental Information is the responsibility of Mid-Continent Securities Advisors, Ltd.'s management. Our audit procedures included detetmining whether the Supplemental Infmmation 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 Infonnation. In forming our opinion on the Supplemental Information, we evaluated whether the Supplemental Information, including its form and content, is presented in confonnity with 17 C.F.R. §240.17a-5. In our opinion, the Supplemental Information is fairly stated, in ail material respects, in relation to the financial statements as a whole. **BAUER & COMPANY, LLC** We have served as Mid-Continent Securities Advisors, Ltd.'s auditor since 2018. Austin, Texas February 28, 2019 Bauer & Company, LLC 5910 Courtyard Drive #230 Austin, TX 78731 Tel512.731.3518 I www.bauerandcompany.com {3}------------------------------------------------ ![](_page_3_Picture_0.jpeg) ## Supplemental Information Based on the regulatory requirements of SEC Rule 17a-5, the Company presents the Computation of Net Capital and Aggregate Indebtedness Under Rule l5c3-l (Schedule I), the Computation for Determination of Reserve Requirements Under Rule 15c3-3 (Schedule II) and the Information Relating to the Possession or Control Requirements Under Rule l5c3-3 (Schedule III) (collectively, the "Supplemental Information") that accompanies the financial statements. We subjected that Supplemental Information to audit procedures in accordance with *AS 2701, Auditing Supplemental Information Accompanying Audited Financial Statements.* Based on our audit procedures perfonned, the Supplemental Information is fairly stated, in all material respects, in relation to the financial statements taken as a whole. This information is intended solely for the use of the Board of Directors and management of the Company and is not intended to be, and should not be, used by anyone other than these specified parties. ## **BAUER & COMPANY, LLC** {4}------------------------------------------------ ### MID-CONTINENT SECURITIES ADVISORS, LTD. STATEMENTS OF FINANCIAL CONDITION DECEMBER 31,2018 AND 2017 #### ASSETS | | 2018 | 2017 | |---------------------------|---------------|---------------| | ASSETS: | | | | Cash and Cash Equivalents | \$
235,890 | \$
475,439 | | Commission Receivable | 204,921 | 416,000 | | Note Receivable | | 1,354 | | Prepaid Expenses | | 12.721 | | TOTAL ASSETS | \$
440,811 | \$
905,514 | | | | | ### LIABILITIES AND PARTNERS' CAPITAL | LIABILITIES:
Commissions Payable
Accmed Liablities | \$
292,868
300 | \$
761,399
6,227 | |----------------------------------------------------------|----------------------|------------------------| | TOTAL LIABILITIES | 293,168 | 767,()26 | | PARTNERS' CAPITAL | 147,643 | 137,888 | | TOTAL LIABILITIES AND PARTNERS' CAPITAL | \$
440,811 | \$
905,514 | {5}------------------------------------------------ ### MID-CONTINENT SECURITIES ADVISORS, LTD. STATEMENTS OF INCOME FOR THE YEARS ENDED DECEMBER 31, 2018 AND 2017 | | 2018 | 2017 | |-------------------------------------------|-----------------|-----------------| | REVENUES: | | | | Fee Income | \$
1,766,678 | \$
1,796,097 | | GENERAL AND ADMINISTRATIVE EXPENSES: | | | | Commission Expense | 1,034,621 | 1,232,348 | | Office Rent | 25,500 | 54,000 | | Office Supplies | 388 | | | Professional Fees | 14,116 | 12,993 | | License and Registration Fees | 15,779 | 26,814 | | Meals and Entertainment | 7,000 | 7,000 | | Subscriptions and Membership Dues | 3,277 | 3,211 | | Travel | | 4,556 | | Total General and Administrative Expenses | 1,100,681 | 1,340,922 | | INCOME FROM OPERATIONS | 665,997 | 455,175 | | OTHER INCOME (EXPENSE): | | | | Interest Income | 16 | 1,373 | | Other Expense | (1,005) | (990) | | Total Other Income (Expense) | (989) | 383 | | NET INCOME | \$
665,008 | \$
455,558 | {6}------------------------------------------------ ## MID-CONTINENT SECURITIES ADVISORS, LTD. STATEMENTS OF CHANGES IN PARTNERS' CAPITAL FOR THE YEARS ENDED DECEMBER 31, 2018 AND 2017 | | General
Partner | Limited
Partner | Total | |----------------------------|--------------------|--------------------|---------------| | Balance, January 1, 2017 | \$
4,552 | \$
463,959 | \$
468,511 | | Net Income | 4,556 | 451,002 | 455,558 | | Distributions | (7,861) | (77'0, 20) | (786,181) | | Balance, December 31, 2017 | 1,247 | 136,641 | 137,888 | | Net Income | 6,650 | 658,358 | 665,008 | | Distributions | (6,553) | (648,700) | (655,253) | | Balance, December 31, 2018 | \$
1,344 | \$
146,299 | \$
147,643 | {7}------------------------------------------------ ### MID-CONTINENT SECURITIES ADVISORS, LTD. STATEMENTS OF CASH FLOWS FOR THE YEARS ENDED DECEMBER 31,2018 AND 2017 | | 2018 | 2017 | |-------------------------------------------------|---------------|---------------| | CASH FLOWS FROM OPERATING ACTIVITIES: | | | | Net income | \$
665,008 | \$
455,558 | | Adjustments to reconcile net income to net cash | | | | provided by operating activities | | | | Net change in: | | | | (Increase) decrease in commission receivable | 211,079 | (2,000) | | (Increase) decrease in prepaid expense | 12,721 | 13,386 | | Increase (decrease) in commissions payable | (468,531) | 364,185 | | Increase (decrease) in accmed liabilities | (6,227) | 3,045 | | Net cash provided by operating activities | 414,050 | 834,174 | | CASH FLOWS FROM INVESTING ACTIVITIES: | | | | Change in Notes Receivable | 1,354 | 3,952 | | Advance to Related Party | (70,000) | (70,000) | | Repayment from Related Party | 70,000 | 70,000 | | Net cash provided by investing activities | 1,354 | 3,952 | | CASH FLOWS FROM FINANCING ACTIVITIES: | | | | Distributions to Partners | (654,953) | (467,999) | | NET CHANGE IN CASH AND CASH EQUIVALENTS | (239,549) | 370,127 | | CASH AND CASH EQUIVALENTS, BEGINNING OF YEAR | 475,439 | 105,312 | | CASH AND CASH EQUIVALENTS, END OF YEAR | \$
235,890 | \$
475,439 | | | | | ### SUPPLEMENTAL DISCLOSURE OF NONCASH INVESTING AND FINANCING ACTIVITIES: | Reduction to Note Receivable via Distribution to Partner | \$ | \$
315,000 | |------------------------------------------------------------|-----------|---------------| | Increase to Accmed Liabilities via Distribution to Partner | \$
300 | \$
3,182 | {8}------------------------------------------------ ### MID-CONTINENT SECURITIES ADVISORS, LTD. NOTES TO THE FINANCIAL STATEMENTS ### NOTE 1: ORGANIZATION AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES ### Organization and Nature of Business Activity Mid-Continent Securities Advisors, Ltd. (the Partnership) was organized on April 2, 2002 tmder the laws of the State of Texas to engage solely in the business as a registered broker-dealer. As of December 31, 2018, the general partner has a 1% partnership interest and the limited partner a 99% partnership interest. The Partnership terminates on December 31, 2102, unless tenninated at an earlier date as provided for in the Partnership Agreement. This summary of significant accotmting policies ofthe Partnership is presented to assist in understanding the financial statements. The financial statements and notes are representations of management, who are responsible for their integrity and objectivity. These accounting policies reflect industry practices, conform to accounting principles generally accepted in the United States of America and have been consistently applied in the preparation of the financial statements. The following items comprise the significant accounting policies of the Partnership. ### Basis of Accounting The Partnership maintains its accounts on the accnml basis of accounting in accordance with accounting principles generally accepted in the United States of America. Accounting principles followed by the Partnership and the methods of applying those principles, which materially affect the determination of financial position, results of operations and cash flows are summarized below. #### Fee Income The Partnership receives com1nissions for directing its customers to invest in hedge funds, mutual funds and variable life insurance products. The Partnership does not carry any securities tor its customers. #### Estimates Management uses estimates and assumptions in preparing these financial statements in accordance with accounting principles generally accepted in the United States of America. Those estimates and assumptions affect the reported amounts of assets and liabilities, the disclosure of contingent assets and liabilities, and the reported revenues and expenses. Actual results could vary from the estimates that were used. #### Cash and Cash Equivalents Cash and cash equivalents include cash on hand, cash in banks and all short-term, highly liquid investments which are readily convertible into cash nnd hnve an original maturity of three months or less. #### Income Tax The Partnership tiles a federal income tax return on a calendm-year basis. The entity is organized as a Partnership and the entity is not liable for income taxes. All income and losses are passed through to the partners of the Partnership. As a result, no current or deferred income tax expense is recognized in the Pnrtnership's financial statements. The Partnership is subject to Texns franchise tax, commonly referred to as the Texas mnrgin tax, for the years ended December 31, 2018 and 2017. For the Partnership, tnxable mnrgin is revenue less interest expense. The mnrgin tax was insignificant for the years ended December 31,2018 and 2017. This tax is current and does not haven deferred tax component. {9}------------------------------------------------ ## MID-CONTINENT SECURITIES ADVISORS, LTD. NOTES TO THE FINANCIAL STATEMENTS ### NOTE 1: ORGANIZATION AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES- continued #### Income Tax - continued The Partnership had no unrecognized tax benefits at December 31, 2018 and 2017. The Partnership recognizes interest accmed on and penalties related to unrecognized tax benefits in tax expense. During the years ended December 31, 2018 and 2017, the Partnership recognized no interest and penalties. ### Lease Commitment The Partnership leases oftlce space on a month to month basis. For the years ended December 31, 2018 and 2017, rent expense totaled \$54,000 and \$54,000, respectively. ### NOTE2: PARTNERSHIP AGREEMENT The following are some of the significant terms of the Partnership Agreement: ### Management The general partner, MCSALGP, LLC, except as otherwise expressly stated or provided in the Partnership Agreement and subject to the approval of the limited partner to the extent required by the Partnership Agreement, shall have the sole and exclusive right to manage the business of the Partnership. ### Liability of Limited Partner The liability of the limited partner to the Partnership shall be limited to the difference between the limited partner's capital contributions as actually made and that stated in the initial offering certificate as having been made; provided, however, that when the limited partner has received the retum in whole or in part of his capital contribution, he shall nevertheless be liable to the Partnership to the extent required by law for any sum, not in excess of such return with interest at the legal rate thereon, necessary to discharge the Partnership's liabilities to all creditors who extend credit or whose claims arose before such return, and who have not waived this provision in whole or in part. #### General Allocation oflncome and Expenses Net income and losses shall be allocated one percent to the general partner and ninety-nine percent to the limited pmtner. ### Special Allocation of Income and Expenses To the extent that an allocation of losses would cause a limited partner to have an adjusted capital account deficit at the end of any fiscal year, then, those losses shall be allocated 100% to the general partner. If losses have been allocated pursuant to the ten11S of the agreement, then profits shall be allocated 100% to the general partner until the aggregate profits allocated to the general partner for the fiscal year end and all previous years is equal to the aggregate losses allocated to the general pmtner for all fiscal years. ### Payment of Distributions The general partner shall make distributions from time to time, by majority vote of the general partner, to cause the Partnership to distribute cash or property to the partners as a return of capital. Distributions need not to be made in accordance with the pattners' units or capital accounts. Rather, distributions can be made to any partner, in the general partner's discretion, including itself, as long as that distribution is designated as a return of capital, provided, however, that the distributions may be made only to a partner to the extent of the positive balance in that pmtner's capital account. {10}------------------------------------------------ ## MID-CONTINENT SECURITIES ADVISORS, **LTD.** NOTES TO **THE** FINANCIAL STATEMENTS ### **NOTE3: RELATED PARTY TRANSACTIONS** Under terms of a formal agreement, the Partnership pays \$500 monthly to the limited partner for rent and certain administrative services. The monthly payment is not necessarily indicative of the costs that would have been incurred had the Partnership been a separate and independent pattnership. During the years ended December 31, 2018 and 2017, the Partnership paid \$6,000 to the limited pa1tner. On May 28, 2015, the Pattnership advanced a related party \$315,000 under a formal note that bears interest at .43% per annum, payable in annual im;tallments of interest only, with repayment of outstanding principal and related accrued interest at the maturity, May 27, 2018. During the year ended December 31, 2017, the note receivable was reclassified as a distribution in lieu of repayment. For the year ended December 31, 201, interest income and accrued interest on this note was deemed to be insignificant. During the year ended December 31, 2017, the Partnership advanced a related party \$70,000 and was repaid this amount by another related party. At December 31, 2017, the Partnership owed various related pmties \$3,045 for deposits received in error on their behalf which are included in accrued liabilities on the accompanying balance sheet. During the year ended December 31, 2018, these amounts were repaid to the related parties. At December 31, 2018 and 2017, the Partnership accmed a distribution to the general partner totaling \$300 and \$3,182, respectively, which is included in accmed liabilities on the accompanying balance sheet. ### **NOTE4: CONCENTRATIONS OF CREDIT RISK** Financial instruments that potentially subject the Partnership to concentrations of credit risk consist of cash and cash equivalents and conunission receivable. At various times during the year, the Pattnership may have bank deposit in excess of Federal Deposit Insurance Corporation insunmce limits. Management believes any credit risk is low due to the overall financial strength of the financial institutions. For the year ended December 31, 2018, one customer accounted tor 45% of total revenues. For the year ended December 31, 2017, one customer accounted tor 46% of total revenues. At December 31, 2018 and 2017, one customer comprised 83% and 100%, respectively, of commission receivable. ### **NOTES: NET CAPITAL REQUIREMENTS** The Pminership is subject to the Securities and Exchange Conunission Uniform Net Capital Rule (SEC Rule l5c3-l), which requires the maintenance of minimum net capital and requires that the ratio of aggregate indebtedness to net capital, both as defined, shall not exceed 15 to l (and the mle of the "applicable" exchange also provides that equity capital may not be withdrawn or cash dividends paid if the resulting net capital ratio would exceed 10 to l ). At December 31, 2018, the Partnership had net capital of \$116,725 which was \$91,725 in excess of its required net capital of \$25,000. Additionally, the Partnership's ratio ()f aggregate indebtedness to net capital was 25 I%. ### **NOTE6: SUBSEQUENT EVENTS** The Partnership has evaluated all subsequent events through Febmary 28, 2019, the date the financial statements were available to be issued. {11}------------------------------------------------ ## MID-CONTINENT SECURITIES ADVISORS, LTD. SCHEDULE I- COMPUTATION OF AGGREGATE INDEBTEDNESS AND NET CAPITAL IN ACCORDANCE WITH RULE l5c3-l OF THE SECURITIES AND EXCHANGE COMMISSION DECEMBER 31,2018 | Net Capital: | | |--------------------------------------------------------------------|----------------------------| | Partners' capital from statement of financial condition | \$
147,643 | | Nonallowable assets | (30,918) | | Net capital before haircuts | 116,725 | | Haircuts | | | NET CAPITAL | \$ ====i'=':.i6,=72=5== | | Computation of basic net capital requirement: | | | Minimum net capital required (6-2/3% of aggregate
indebtedness) | \$ ----"1-'--'9,:.:55:4;._ | | Minimum dollar net capital requirement | 25,000 | | Excess capital | 91 ,725 | | Net capital less 120% of minimum dollar net capital requirement | \$ ===8=6,=72=5= | | Ratio: | | | Aggregate indebtedness to net capital | 251% | | Ratio of subordinated indebtedness to debt/equity total | | Note: There are no material differences between the above computation and the <:amputation of net capital as of December 31, 2018 previously filed by Mid-Continent Securities Advisors, Ltd. on Form X-l7A-5. See Independent Auditor's Repot1. {12}------------------------------------------------ ## MID-CONTINENT SECURITIES ADVISORS, LTD. SCHEDULE II- COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS PURSUANT TO RULE 15c3-3 DECEMBER 31, 2018 Mid-Continent Securities Advisors, Ltd. does not effect transactions for anyone defined as a customer under Rule 15c3-3. Accordingly, there are no items to report under the requirements of this rule. See Independent Auditor's Report {13}------------------------------------------------ **Mid-Continent Securities Advisors, Ltd.** *The Benjamin Building 1218 Webster Street Houston, Texas 77002* **William H.** Van **.Pelt, IV** *Direct: (713) 289-6202 E-mail: bvp4@,mccltd.com* Telephone: (713) 289-6200 Facsimile : (713) 289-6247 February 28, 2019 Exemption Report Mid-Continent Securities Advisors, Ltd. is exempt from the filing requirement of Rule 15c3-3 under the exemption provided under (k)(2)(i)-"Special Account for the Exclusive Benefit of customers" maintained. Our firm does not hold nor receive customer funds nor securities. Mid-Continent Securities Advisors, Ltd. has met this exemption continuously since the firm's inception, including the calendar year 2018. William H. Van Pelt, IV President {14}------------------------------------------------ ![](_page_14_Picture_0.jpeg) ## REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Board of Directors and Partners of Mid-Continent Securities Advisors, Ltd. We have reviewed management's statements, included in the accompanying Exemption Report Year Ended December 31, 2018, in which (1) Mid-Continent Securities Advisors, Ltd. identified the following provisions of 17 C.F.R. §15c3-3(k) under which Mid-Continent Securities Advisors, Ltd. claimed an exemption from 17 C.F.R. §240.15c3-3: (2)(i) (the "exemption provisions") and (2) Mid-Continent Securities Advisors, Ltd. stated that Mid-Continent Securities Advisors, Ltd. met the identified exemption provisions throughout the most recent fiscal year without ,exception. Mid-Continent Securities Advisors, Ltd.'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 Mid-Continent Securities Advisors, Ltd.'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)(2)(i) of Rule 15c3-3 under the Securities Exchange Act of 1934. **BAUER & COMPANY, LLC** Austin, Texas February 28,2019 Bauer & Company, LLC 5910 Courtyard Drive #230 Austin, TX 78731 Tel512.731.3518 I www.bauerandcompany.com Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.