FOCUS Report Vestech Securities, Inc.

X-17A-5 [Paper] - FOCUS Report

Published: 2006-09-14 16:16:38
Submitted: 2006-08-28
Period Ending In: 2006-06-30
scanned.pdf Scanned paper document


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                                   06008958                              TIESAND EXCHANGECOMMISSION                                                                _                OMB Number:             3235—0123
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                                                                                       20
                                                                                 Washington?D.C. 20549
                                                                                                    - .                                      .
                                                                                                                                                           i                        Expires:         January 31, 2007
                                                                                                                                                                       \,| Estimated average burden                     J
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                                             |                 ANNUAL AUDITED REPO s\;/;w\g%@urs per response... ... 12.00 ol                    £J

                                                                                 EORM X—17A—5:                                   &                                         —_             C        SEC FILE NUMBER
                                                                                        PART II1 |                                           e                                                        49409
                                                                                                                                         AUG *
                                    -                                                  FACING PAGE                              \G%.
                                                                                                                                 >
            .. Information Required of Brokers and Dealers Pursuant&
                           _        Securities Exchange Act of 1934 and Rule 17a—5

 REPORT FOR THE PERIOD BEGINNING
                                                                       o7/o1/05                                         AND Enpmig"06/30 /06
                                                                                           MM/DD/YY                                                            \                          MM/PDYY

                                                              A. REGlISTRANT TIDENTIFICATION

NAME OF BROKER—DEALER:                                        \/_@S #&@1 gqu fi,{% I%é’                                                                                          _         |OFEICIAL USE ONLY
ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.)                                                                                                                                  FIRM 1.D. NO.

  8100 E. 22nd@ St. North #B, Blag. 600                                                                                              '
 2e                .                                                                    (No. and Street)                                               —               .              .

  Wichita.                              ’                                                  ~o—   KS _               10                                                              67226
                           (City)                 ‘                      .         .             (State)   _                             .                                      (Zip Code)

. NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARDTO THIS REPORT
.Earle W Evans                              III           _                                                        to       .                                              (316)                   686—6222
                                                                                                                                                                                    (Area Code — Telephone Number)

                                                              B. ACCOUNTANT IDENTIFICATION

INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report* >

 Hewitt & Company,                                        PA                                                   ’
                                                                      ~ (Name —— if individual, state last, first, middle name)

 205 W. 2nd St. North —                                                           Wichita                                                             Kansas                                             67202
      (Address)                                       i           ’               (City)               i                ~                             (State)                                  .    «_ (Zip Code)


CHECK ONE:

           KK Certified Public Accogntant                                    —                    O                              '                .            P ’OCESSED
           O Public Accountant
           J 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 covexed by the opinion of an independent public accountant
‘must be supported by a statement offacts and circumstances relied on as theNbasis or&(l exemption. See Section 240.17a—5(e)(2)



                               —                 Potential persons who are to respon ‘to the\cdllection of
                                                 information contained in this form are not                    required to respond
   SEC 1410 (06—02)                              unless the form displays a currently valid OMB control number.

                                                                                                                                                       C8


     o        h us                  |             OATH OR AFFIRMATION
I,       Earle W           Evans,       III~                               1             , swear (or affirm) that, to the best of
my knowledge and belief the accompanying fmanc1a] statement and supportmg schedules pertaining to the firm of
      Vestech Securltles,                      Inc.              —                                                            , as
of       June 30       _                                       , 20 06   , are true and correct: I further swear (or affirm) that
neither the company nor any partner, proprietor, principal.officer or director hasany proprietary interest in any account
classified solely as that of a customer, except as follows:




                                                                                        Signature

                                                                         President
                                                                                           Title


              | Notary Pub ic                                                        a PATRICIA A. McCULL
                                                                                                                   OUGH
                                                                                      ApplNotary Public —yState of K ansa
This report ** contains(check all appllcable boxes)                                                                       s
                                                                                              Expires
C    (a)   Facing Page.
C    (b)   Statement of Financial Condition.
C    (c)   Statement of Income (Loss).
Bs   (d)   Staterment of Changes in Financial Condition.                                            '
5i   (e) Statement of Changes in Stockholders‘ Equity or Partners® or Sole Proprietors‘ Capital.
D (f) Statement of Changes in Liabilities Subordmated to Claims of Creditors.        ©
8 (g) Computation of Net Capital.
C (h) Computation for Determination of Reserve Requirements Pursuant to Rule 15c3—3.
El   (i)   Information Relating to the Possession or Control Requirements Under Rule 15c3—3.
O () A Reconciliation, including appropriate explanation of the Computation of Net Capital Under Rule 15c3—1and the
           Computation for Determination of the Reserve Requirements Under Exhibit A of Rule. 15c3—3.
{Q (k) A Reconciliation between the audlted and unaudited Statements of Financial Condmon with respect to methods of
           consolidation. .                                P
CX (1) An Oath or Affirmation.
O (m) A copy of the SIPC Supplemental Report. .
     (n) A report describing any material inadequacies found to exist or found to have existed since the date of the previous audit.

,*bf"For conditions of confidential treatment ofcerz'ain portions of this filing, see section 240.17a—5(e)(3).


    VESTECH SECURITIES, ING, .

     FINANCIAL STATEMENTS O

              and _

— INDEPENDENT AUDITOR‘S REPORT

    YEAR ENDED JUNE 30, 2006


EINANCIAL STATEMENTS                                      |                           |                       Page
Independent Auditor‘s Report                                                  :                       .         1

Statement of Fifiancial Condition                      -           |                                             2

Statement of Income            |                                                  |                             3

Statement of Changevs in Stockholders‘ Equity     *                   ~                           |       '    4

Statement ofCash Flows             _ |          C s               S                       -                   .5
Notes to FinancialyStatements                                 ’           '                   .               6— 7

SUPPLEMENTARY INFORMATION

Computation of Net Capital Under Rule 15c3—1
   of the Securities and Exchange Commission                      ;                                             8

Computation for Determination of Reserve Requirements and Possession and Control
   Requirements Under Rule 15¢c3—3 of the Securities and Exchange Commission                                    9

INDEPENDENT AUDITOR‘S REPORT ON INTERNAL CONTROL                                                                      ‘
 Reqwred by SEC Rule 17a—5 ‘        —                                                                         10—11


                              %wdft & @mpcmg,
                                            /2/4

                                   iNDEPENDENT AUDITOR‘S REPORT




  Board of Directors
  Vestech Securities


_ We have audited the accompanying statement of financial condition of Vestech Securities, Inc. as of
  June 30, 2006, and the related statements of income, changes in stockholders‘ equity and cash
  flows for the year then ended that you are filing pursuant to rule 17a—5 under the Securities
  Exchange Act of 1934. These financial statements are the responsibility of the Company‘s
  management. Our responsibility is to express an opinion on these financial statements based on
  our audit.

  We conducted our audit in accordance with auditing standards generally accepted in the United
  States of America. Those standards require that we plan and performthe audit to obtain reasonable
  assurance about whether the financial statements are free of material misstatement. An audit
  includes examining, on a test basis, evidence supporting the amounts and disclosures in the
~ financial statements. An audit also includes assessing the accounting principles used and
  significant estimates made by management, as well as evaluating the overall financial statement
  presentation. We believe that our audit provides reasonable basis for our opinion.

 ‘In our opinion, the financial statements referred to above present fairly, in all material.respects, the
  financial position of Vestech Securities, Inc., as of June 30, 2006, and the results of their operations
  and their cash flows for the year then endedin conformltyW|th accounting pnncnples generally
  accepted in the United States of America.

  Our audit was made for the purpose of forming an opinion on the basic financial statements taken
  as a whole. The information contained in Schedules 1 and 2 is presented for purposes of additional
  analysis and is not a required part of the basic financial statements, but is supplementary
  information required by rule 17a—5 of the Securities Exchange Act of 1934. Such information has
  been subjected to the auditing procedures applied in the audit of the basic financial statements and,
  in our opinion, is fairly stated in all material respects in relation to the—basic financial statements
  taken as a whole.               —                                            >


      Newutl + Compony . Pa
  August 18, 2006




                                  CERTIFIED PUBLIC ACCOUNTANTS
Members + American Institute of Certified Public Accountants * Kansas Society of Certified Public Accountants
                  205 W. 2nd « Wichita, KS 67202 « 316—269—4500 « fax 316—269—2005                          -


                                    VESTECH SECURITIES, INC.
                             STATEMENT OF FINANCIAL CONDITION
                                       JUNE 30, 2006

                                                                   ASSETS

Current Assets                                     ,
   Cash                                                                                                                             $                   7,273
   Cash deposits with clearing organization                '                                                                                          12,971
   Receivables from broker—dealers and clearing organization                                                                                          66,777
   Prepaid expense .                             .                                                                                                      2,382
   Marketable securities                                                                                                e                              8,970


      Total Current Assets               60                                                                                                                     $   98,373

Fixed Assets:                         _
   Furniture and equipment          _ __|___—                                                                                                         13,435
 _ Less: Accumulated depreciation                                                                                                                 {(13,435)

      Total Fixed Assets                                  ‘                         »                   v                                                                0

Other Assets                                                                                        .
  _ Note receivable       C                                                                     —                           ‘                ._          200
    Stockholder receivable .                                                ,                                   .                                     40,497

      Total Other Assets        _             .       '                         .                                   .                                               40,697_

          Total Assets                                        60    s                                                                    .        |             139,070,

                             LIABILITIES AND STOCKHOLDERS®‘ EQUITY                                                                                                            |

Current Liabilities
   Accounts payable ©                                                                                                   |           $        21,493
   Payroll taxes payable             .                                                                                               '         4,040
   Retirement plan payable                                                                  C                                                          3,815

      Total Current Liabilities                                         v               '                                                .                      $   29,348

Stockholders‘ Equity                         ‘
   Common stock, no par value, 100,000 shares
      authorized, 1,000 shares issued and outstanding                                                                                                 40,000
   Additional paid—in capital                                                                                                                          5,701
    Retained earnings    >                                                                                                                            63,151
    Net unrealized gain on marketable securities                                                                                '                        870


       Total Stockholders‘ Equity                 —                                                         |                                                       109,722
          Total Liabilities and Stockholder‘s Equity                                                                                                            139,070.




The accompanying notes are an integral part of these financial statements.
                                                                    29.


                                                    . VESTECH SECURITIES, INcC.
                                                        STATEMENT OF INCOME_
                                                   FOR THE YEAR ENDED JUNE 30, 2006



 Revenues                                                                                                                                                                       —                      .
 \_—_—Commissions                  ‘                   e                       ’                                            '                               —                       $ 621,058
    Other income                                                                                                                                                                               5,257
    Interest income                    O                           .                   .                    »                                   ,                                               412

       Total Revenues                              .                                       '                                                                                                               $   626,727

 Operating Expenses                        .                                       |                                                                                                No    s
    Commissions                                                                o                                ‘                   .                                   .                 308,509
    Officer salaries                           C                                                                                                                    '                     114,250
    Salaries and wages _                               |                                               .                '                                       -                             30,543
    Payroll taxes          _   _       _                                                                            e                                                                         10,601
    Retirement plan expense                                    o                                       Cl                                                               .                      3,848
    Clearance paid                                                 2                                                                                                                          26,701
    Dues and fees     O                                                                                         o.                                  ns                                     11,476
    Professional fees                                      _                   m               s                                                                            o            . 39,116
    Travel and entertainment _                                 .                                                                                                                              15,172
    Quotation expense                                                      ‘                                                            .                                            '         5,513
    Rent                    t                                                                                                                                                                 10,466
    Communication expense                                                                          .                                        .                                                  7,314
     Insurance expense                                                                                                                                  >                                      3,164
    Office expense .                                                           18                                               .                                                              7,389
    .Property and other taxes                                                                                       ‘                                                                          3,582
  ~ Other expense                                                                                                                                   |                                          2,599

       Total Operating Expenses                                                                                                                                                          200                   600,243_

 Net Income            |                                               '                                                                                                                         —_=       26,484.




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

                                                                                           _3_


                                     VESTECH SECURITIES, INC.
                         ‘STATEMENT OF CHANGES IN STOCKHOLDERS‘ EQUITY
                                FOR THE YEARENDED JUNE 30, 2006




                                                                                               ACCUMULATED
                                                              ADDITIONAL
                                          COMMON—               PAID—IN:        RETAINED       COMPREHENSIVE
                                               STOCK           CAPITAL          EARNINGS                           TOTAL

Balance, Begivnning >of Year _       >./. $     40,000 $            ©5,701      $   _ ‘36,667. $          0    $     82,368

Capital contribu_tions   f                             . O’                 0              0                               0

Net income                       |                     ‘o              o              26,484                         26,484
Other Comprehensivé Income:
   Unrealized income on securities                :_     0                  0              0             870            870

Balance, End of Year |                    $‘    40,000        $ |    5,701      $     63-,151 —$         870   $     109,722




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

                                                                    —40 0


                                    vEsTECH SECURITIES, INC.
                                   STATEMENT OF CASH FLOWS
                                FOR THE YEAR ENDED JUNE 30, 2006




 Cash Flows from Operating Activities
    Net income for the year                                       ‘                                            $       26,484 _
    Adjustments to reconcile net income to net
     cash provided by operating activities:
        (Increase) Decrease in:.          ‘
          Cash deposits with clearing organization                                                                        (412)
          Prepaid expense                     .                                                                         (1,533)
          Receivables from broker—dealers
           and clearing organization >                        '               ',                               _       (30,648)
       Increase (Decrease) in:                «                                                                    >
          Accounts payable                                                                                              9,188
          Payroll taxes payable       .       W                                                                         3,305
          Retirement plan payable                                                                                       1,951

    Net Cash Provided by Operating Activities                             |                                                             $   8,335

 Cash Flows from Investing Activities                                              ‘
    Fee to exercise stock warrant         ‘                                                    ‘                        (4,800)
    Loans made                    ‘                                                                                     {4,000)
    Repayment of note receivable                      ‘                                            .                          100

    Net Cash Used for Investing Activities                            ‘                                    .                        .       (8,700)

.Cash Flows From FinancingActivities                                                   .                                                        0

 Net Decrease in Cash                             '                                        ‘                                                 (365)

 Cash at Beginning of Year                                —               o                                               —                 7,638

 Cash at End of Year        '       -                                                                  —                                ___ZL273.




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

                                              —5.


                                  VESTECH SECURITIES. INC.
                               NOTES TO FINANCIAL STATEMENTS
                             —          JUNE 30, 2006


 1. SUMMARY OF ACCOUNTING POLICIES

 A. Business Activity

     Vestech Securities, Inc. (the Company) is a broker—dealer of securities in Wichita,
   . Kansas. The Company, incorporated on March 13, 1996, holds membership in the
     National Association of Securities Dealers, Inc. and is registered with the Securities and
     Exchange Commission in accordance with Section 15(b) of the Securities Exchange
     Act of 1934. Security, mutual fund, and annuity commissions make up the Company‘s
     revenue. The Company‘s customers live primarily in Kansas. The Company does not
     receive, directly or indirectly, nor hold funds or securities for, nor owe funds or
     securities to customers and does not carry accounts of, or for, customers. Accounts
     receivable are primarily held by the Company‘s clearing broker or dealer. The _
   _ Company has no union contracts and generally acquires labor and other services
     locally.


 B; Cash and Cash Equivalents

     For purposes of the statement of cash flows, the Company considers any highly liquid
     investment instruments, with a maturity of six months or less to be cash equivalents.


 C. Income Recognition
    Income and expenses related to the purchase or sale of customer securities are
    recorded on the settlement date basis. Expenses relating to fees and registrations with
    agencies of federal and state governments and the National Association of Security
    Dealers are expensed as incurred.

 D. Marketable Securities

     The Company classifies its marketable security as "available—for—sale" and reports it at
     fair value with unrealized gains and losses excluded from earnings and reported as a
     separate component of stockholders‘ equity. Realized gains and losses are reported as
     earnings.                       |


 E. Use of Estimates

     The preparationof financial statements in conformity with accounting principles
     generally accepted in the United States of America requires management to make
     estimates and assumptions that affect certain reported amounts and disclosures.
     Accordingly, actual results could differ from thoseestimates.


  2. INCOME TAXES

~— The Company files as an "S" corporation for federal and state income tax purposes. The
 Company‘s net income is taxed at the shareholder level rather than at the corporate level .
 for income tax purposes, and thus, no provision for income taxes has been made in the
 accompanying financial statements.


                                 _ VESTECH SECURITIES, INC.
                               NOTES TO FINANCIAL STATEMENTS
                                        JUNE 30, 2006


3. RELATED PARTIES
The Company rents office space from a related party on a month—to—month basis. Rent
expense for the period ended June 30, 2006, was $10,466.                          ‘

Receivable from stockholdér represents advances to the stockholder which are non—interest
bearing and due on demand.                   .

4. NET CAPITAL REQUIREMENTS

Pursuant to the net capital provisions of Rule 15¢c3—1 of the Securities and Exchange Act of
1934, the Company is required to maintain a minimum netcapital, as defined under such
provisions. Net capital and the related net capital ratio may fluctuate on a daily basis. At
June 30, 2006, the company had net capital of approximately $65,038 and net capital
requirements of $5,000. The Company‘s ratio of aggregate indebtedness to net capital
was 0.45 to 1. The Securities and Exchange Commission permits a ratio of no greater than
15 to 1.                   |             >                  |


5. EMPLOYEE BENE‘FITS

The Company has a Simple IRA pension plan, whereby eligible employees may voluntarily
contribute a percentage of compensation. The company matches a portion of the         _
employee‘s contribution up to 3% of the employee‘s compensation for the year. For the
period ending June 30, 2006, the Company recognized retirement plan expense of $3,848.


             SUPPLEMENTAL INFORMATION

Pursuant to Rule 17a—5of the Securities Exchange Act of 1934


                                 VESTECH SECURITIES, INC.
                                       = SCHEDULE 1
                    COMPUTATION OF NET CAPITAL UNDER RULE 15c3—1 OF THE
                           SECURITIES AND EXCHANGECOMMISSION
                               ‘    AS OF JUNE 30, 2006


— Net Capital                              —                                                                                               >                                                                                                                ‘
      Total stockholders‘ equity                                                                                       .                                                                                             $                    109,722
            Deduct stockholders‘ equity not aIIowed for net capital                                                                                                      ‘                                                                      0
      Total Stockholders‘ Equity Qualified for Net Capital        O                                                                                                                                                              _        109,722
      Add:                                                               -
           A. Liabilities subordinated to claims of general creditors allowable                                                                                                                              .
                   in computation of net capital                                                                                                                                                                                                0 _
            B.— Other deductions or credits                                  :                                                                                                                                                                _ 0
      Total Capital and Allowable Subordinated Liabilities   _     .                                                                                                                                                                      109,722
       Deductions and/or Other Charges
             A. Non—allowable assets: . °
                  Clearing deposit interest receivable                         —                   |                                   '                                         L                                                        .                 0
                   Nonallowable receivable from broker—dealer :                                                                                                                                                                  —_        (40,497)
                 . Receivable from non—customers                                       .                                                       f                 —                               .                                                     (200)‘
                   Deferred income tax asset                               O       l                                                                       2                                                                                  ’             0
                   Prepaid income tax              .                                                                                                                                                     '           j                                      0
                  Other assets                                 |                   2                       C                                                   Sn                    e                                                        ©(2,382)
             B. Secured demand note deficiency                   :                                                                                                           f                       .                                                «_    0
             C. Commodity futures contracts and spot commodities                                                                                                                                                                                            0
         _  D. Other deductions and/or charges      >                                          .                                                                                     >                                                             0
       Net Capital Before Haircuts on Securities Posmons                                                           :                                   .                                                         -                            66,643
       Haircuts on Securities:
             A. Contractual securities commltments                                                                                                                                                                                                          0
             .B. Deficit in securities collateralizing demand notes                                                                                                                                                                                         0
             C. Trading and investment securities.                                                                                                                                                                                                          0
                 ~ 1. Exempted securities                                                                                                                                                                                                                   0
                   2. Debt securities                                                                                                                                                                                                                       0
                   3. Options                                                                                                                                                                                                                              0
                  4.. Other securities .                                                                                                                                                                                                                    0
             D. Undue concentrations                                                                                                                                                                                                                        0
             E. Other                                                                                                                                                                                                                 _           (1,605)
    _ Net Capital >                                                                                                                                                                                                  $                            65,038

Aggregate Indebtedness                                                                                                                                               .                   .                                   —
     _ Accounts payable                                            .                   [                                                                       200                           —                       $                            21,493
       Payroll taxes payable:                              S                            .                                          ‘                                                                                                               4,040
       Retirement plan payable                                         ‘                                                                           >                                                                                               3,815
       Total Aggregate Indebtedness                                                        .                                   .                           .                 .                                       $                            29,348

 Computation of Basic Net Capital Requirement           >            .                                                                                                                                       .                                                   .
      Minimum of Net Capital Requirement of.Reporting Broker or Dealer                                                                                                                                               $                                5,000, —

       Excess Net Capital        .                     ‘                                                       .                                                                                                         $                        60.038
       Excess Net Capital at 1000%                                                                                                                                       .                                           ___682,103.
       Excess Net Capital at 1500%             .                           0                                               .                                                                                             $                        63.082

       Ratio: Aggregate Indebtedness to Net Capital                                                    —                                                   e                                                                                      45 to 1

 Reconciliation of the basic net capital requirement is not included as there is no matenal difference from the
 Companys computation.

See independent auditor‘s report.


                            VESTECH SECURITIES, INC.      .
                                  SCHEDULE 2         C      '
          COMPUTATION FORDETERMINATION OF RESERVE REQUIREMENTS
                 AND POSSESSION AND CONTROL REQUIREMENTS
         UNDER RULE 15C3—3 OF THE SECURITIES AND EXCHANGE COMMISSION
                               AS OF JUNE 30, 2006 _


The Company is exempt from Rule 15c3—3 based on (k)(2)(ii) of Rule 15—c3—1 of the Securities.énd ‘
Exchange Commission. All customer transactions are cleared through another broker—dealer.

                 Company‘s clearing firm: National Financial Services Corporation




See independent auditor‘s rebort.


INDEPENDENT AUDITOR‘S REPORT ON INTERNAL CONTROL‘

 Required by the Securities Exchange Commission Rule 17a—5


                                        \/élewvifl & amf)cm% B4


      Board of Directors
      Vestech Securities, Inc.

      In planning and performing our audit of the financial statements and supplemental schedules of
      Vestech Securities, Inc. (the Company) for the year ended June 30, 2006, we considered its
      internal control, including control activities for safeguarding securities, in order to determine our
      auditing procedures for the purpose of expressing our opinion on the financial statements and not to
      provide assurance on the internal control:

      Also, as required by Rule 17a—5(g)(1) of the Securities and Exchange Commission (SEC), we have
      made a study of the practices and procedures followed by the Company including tests of such
      practices and procedures that we consideredrelevant to the objectives stated in rule 17a—5(g) in
      making the periodic computations of aggregate indebtedness and net capital under rule 17a—
      3(a)(11) and for determining compliance with the exemptive provisions of rule 15¢c3—3. Because the
       Company does not carry securities accounts for customers or perform custodial functions relating to
      _customer securities, we did not make a—study of the practices and procedures followed by the
      Company in any of the following:

               1. Making the quarterly securities examinations, counts, verifications and
                  comparisons

              2. Recordation of differences required by Rule 17a—13

              3. Complying with the requirements for prompt payment for securities under
                 Section 8 of Federal Reserve Regulation T of the Board of Governors of the
                 Federal Reserve System

      The managemént of the Company is responsible for establishing and maintaining intérnal control
      and the practices and procedures referred to in the preceding paragraph. In fulfilling this
      responsibility, estimates and judgements by management are required to assess the expected
      benefits and related costs of controls and of the practices and procedures referred to in the:
      preceding paragraph and to assess whether those practices and procedures can be expected to
      achieve the SEC‘s above—mentioned objectives. Two of the objectives of internal control and the
      practices and procedures are to provide management with reasonable but not absolute assurance
      that assets for which the Company has responsibility are safeguarded against loss from
      unauthorized use or disposition and that transactions are executed in accordance with
      management‘s authorization and recorded properly to permit the preparation of financial statements
      in conformity with generally accepted accounting principles in the United States of America. Rule
      17a—5(g)lists additional objectives of the practices and procedures listed in the preceding
      paragraph.                                                                          v

      Because of inherent limitations in internal control or the practices and proceduresreferred to above,
      error or fraud may occur and not be detected. Also, projection of any evaluation of them to future
      periods is subject to the risk that they may become inadequate because of changes in conditions or
      that the effectiveness of their design and operation may deteriorate.
a +




                                         ~CERTIFIED PUBLIC ACCOUNTANTS
         Members « American Institute of Certified Public Accountants « KansasSociety of Certlfied Public Accountants
                           205 W. 2nd « Wichita, KS 67202 + 316—269—4500 « fax 316—269—2005


 Page 2

 Our consideration of internal control would not necessarily disclose all matters in internal control
 that might be material weaknesses under standards established by the American Institute of
 Certified Public Accountants. A material weakness is a condition in which the design or operation
 of the specific internal control component does not reduce to a relatively low level the risk that error
 or fraud in amounts that would be material in relation to the financial statements being audited may
 occur and not be detectedwithin a timely period by employees in the normal course of performing
 their assigned functions. However, we noted no matters involving internal control, including control
 activities for safeguarding securities, that we consider to be weaknesses as defined above.

 We understand that practices and procedures that accomplish the objectives referred to in the
 second paragraph of this report are considered by the SEC to be adequate for its purposes in
 accordance with the Securities ExchangeAct of 1934 andrelated regulations, and that practices
~ and procedures that do not accomplish such objectives in all material respects indicate a materiat
  inadequacy for such purposes. Based on this understanding and on our study, we believe the
  Company‘s practices and procedures were adequate at June 30, 2006, to meet the SEC‘s
 objectives.          .                        '    2l          |             ‘

 This report is intended solely for the information and use of the Board of Directors, management,
 the SEC, the National Association of Securities Dealers, Inc. and other regulatory agencies which
 rely on Rule 17a—5(g) under Securities Exchange Act of 1934 in their regulation of registered
 brokers and dealers, and is not intended to be and should not be used by anyone other than these
 specified parties.


  Nt + Compory . PA
 Hewitt & Company, PA
 Wichita, Kansas
 August 18, 2006



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