FOCUS Report Suntrust Investment Services, Inc.

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

Published: 2017-03-15 10:31:53
Submitted: 2017-03-01
Period Ending In: 2016-12-31
scanned.pdf Scanned paper document


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                                                        EN I"
        p~AR~~~                             FORM X-17A-5 41SECFILE NUMBER
       vvas ''~
                DC                             PART III
                  111
                                                              8-35355
                                                        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                   01/01/16                         AND ENDING                12/31/16
                                                              MM/DD/YY                                              MM/DD/YY

                                     A. REGISTRANT IDENTIFICATION

NAME OF BROILER-DEALER:                                                                                             OFFICIAL USE ONLY
                                         h+y_".S+
                                                                 1nVe5f?wf
ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.)                                    'A%C               FIRM I.D. NO.
                                                                                                     !V
                     303 Peachtree Center Avenue
                                                            (No. and Street)

                     Atlanta                                        GA                                      30303
                   (City)                                          (State)                                 (Zip Code)

NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT
                                               Sarah Rich                                            404-813-5604
                                                                                                            (Area Code — Telephone Number)

                                    B. ACCOUNTANT IDENTIFICATION

INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report*

                                              Ernst & Young LLP
                                              (Name — ifindividual, state last,first, middle name)

      55 Ivan Allen Blvd, Suite 1000 Atlanta                                                         GA                     30308
     (Address)                                       (City)                                      (State)                    (Zip Code)


CHECK ONE:

         a    Certlfied Public Accountant
              Public Accountant

      .H      Accountant not resident in United States or any of its possessions.

                                              FOR OFFICIAL USE ONLY




*Claimsfoi- exemptionft•ont the requirenient that the annual report be covered by the opinion ofan independent public accountant
must be supported by a statement offacts and circurnslances relied on as the basisfor the exemption. See Section 240.17a-5(e)(2)



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


CONSOLIDATED FINANCIAL STATEMENTS AND
SUPPLEMENTAL INFORMATION

SunTrust Investment Services, Inc.
(A Wholly Owned Subsidiary of SunTrust Banks, Inc.)
Year Ended December 31, 2016
With Report ofIndependent
Registered Public Accounting Firm


                                              OATH OR AFFIRMATION

      Sarah Rich                                                                , swear (or affirm) that, to the best of
my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of
    SunTrust Investment Services, Inc.                                                                               , as
of                  December   31                     20 16       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:




                                                                                    Signature

                                                                             Chief Financial Officer
                                                                                       Title
                     --

               Notary Public
                                                                               CLAIRE DAVIS
                                                                               Notary
This report ** contains (check all applicable boxes):
                                                                               Clarke Co
D (a) Facing Page.
0 (b) Statement of Financial Condition.                                               PuLiul
                                                                              State of Ge
                                                                      My Commission Expi111
  r
Q (c) Statement of Income (Loss).
Rr (d) Statement of Changes in Financial Condition.
Cr (e) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors' Capital.
❑ (f) Statement of Changes in Liabilities Subordinated to Claims of Creditors.
Rr (g) Computation of Net Capital.
Q (h) Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3.
9(i) Information Relating to the Possession or Control Requirements Under Rule 150-3.
❑ 0) A Reconciliation, including appropriate explanation ofthe Computation of Net Capital Under Rule 150-1 and the
        Computation for Determination of the Reserve Requirements Under Exhibit A of Rule 150-3.
Q (k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of
        consolidation.
Q (1) An Oath or Affirmation.
❑ (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 ofthe previous audit.

**For conditions ofconfidential ireatrnent ofcertain portions ofthisfiling, see section 240.17a-5(e)(3).


                                     SunTrust Investment Services, Inc.
                           (A Wholly Owned Subsidiary of SunTrust Banks, Inc.)

             Consolidated Financial Statements and Supplemental Information

                                           Year Ended December 31, 2016




                                                         Contents

Report of Independent Registered Public Accounting Firm ............................................................

Financial Statements

Consolidated Statement of Financial Condition ..............................................................................2
Consolidated Statement of Operations.............................................................................................3
Consolidated Statement of Changes in Shareholder's Equity .........................................................4
Consolidated Statement of Cash Flows ...........................................................................................5
Notes to Consolidated Financial Statements....................................................................................6

Supplemental Information

Schedule I — Computation of Net Capital and Aggregate Indebtedness Pursuant to
  Rule 15c3-1 ofthe Securities and Exchange Commission.........................................................18

Schedule II — Computation of Determination of Reserve Requirements Pursuant to
  Rule 150-3 ofthe Securities and Exchange Commission .........................................................22

Schedule III — Information Relating to Possession or Control Requirements Pursuant
  to Rule 15c3-3 ofthe Securities and Exchange Commission.....................................................23


                                         Ernst & Young LLP             Tel: +1404 874 8300
Sam IT                                   Suite 1000                    Fax: +1404 817 5589
                                         55 Ivan Allen Jr. Boulevard
                                         Atlanta, GA 30308
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             Report of Ernst & Young LLP, Independent Registered Public Accounting Firm


The Shareholder and Board of Directors of
SunTrust Investment Services, Inc.

We have audited the accompanying consolidated statement of financial condition of SunTrust
Investment Services, Inc., (the Company) as of December 31, 2016, and the related consolidated
statements of operations, changes in shareholder's equity and cash flows for the year then ended that
are filed 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 the standards of the Public Company Accounting Oversight
 Board (United States). Those standards require that we plan and perform the 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 a reasonable basis for our opinion.

 In our opinion, the financial statements referred to above present fairly, in all material respects, the.
 consolidated financial position of SunTrust Investment Services, Inc. at December 31, 2016, and the
 consolidated results of its operations and its cash flows for the year then ended in conformity with U.S.
 generally accepted accounting principles.

 The accompanying information contained in Schedules I, II, and III has been subjected to audit
 procedures performed in conjunction with the audit of the Company's consolidated financial
 statements. Such information is the responsibility of the Company's management. Our audit
 procedures included determining whether the 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. In forming our opinion on the information, we evaluated
 whether such information, including its form and content, is presented in conformity with Rule 17a-5
 under the Securities Exchange Act of 1934. In our opinion, the information is fairly stated, in all
 material respects, in relation to the financial statements as a whole.




 February 27, 2017




A mene_r hnr of Rnst 9 Ycing Glo   aI L• nit ted


                               SunTrust Investment Services, Inc.
                       (A Wholly Owned Subsidiary of SunTrust Banks,Inc.)

                       Consolidated Statement of Financial Condition

                                           December 31, 2016


Assets
Cash and cash equivalents                                                   $   66,733,193
Securities segregated under Federal and other regulations                        4,509,009
Securities owned                                                                     7,282
Commissions receivable                                                           2,979,638
Furniture, equipment, and leasehold improvements, less
   accumulated depreciation and amortization of$6,690,741                         1,164,816
Goodwill                                                                         42,706,365
Prepaid assets                                                                   41,220,132
Current income tax receivable from Parent                                         1,412,174
Other assets                                                                      2,391,084
Total assets                                                                $   163,123,693

Liabilities and shareholder's equity
Liabilities:
   Accrued compensation and benefits                                        $    19,269,458
   Deferred income tax payable to Parent                                          6,271,220
   Payable to Parent                                                              1,579,554
   Accrued other expenses                                                         5,447,552
Total liabilities                                                                32,567,784

Shareholder's equity:
  Common stock, $1 par value; 52,125 shares authorized
     52,125 shared issued and outstanding                                            52,125
  Additional paid-in capital                                                     93,944,723
  Retained earnings                                                              36,559,061
Total shareholder's equity                                                      130,555,909
Total liabilities and shareholder's equity                                  $   163,123,693

The accompanying notes are an integral part ofthesefinancial statements.




                                                                                              2


                                SunTrust Investment Services, Inc.
                       (A Wholly Owned Subsidiary of SunTrust Banks, Inc.)

                              Consolidated Statement of Operations

                                     Year Ended December 31, 2016


Revenues
Commissions                                                                  $   169,613,653
Investment management income                                                     124,775,171
Other income                                                                       9,735,855
Total revenue                                                                    304,124,679

Expenses
Compensation and benefits                                                        188,050,758
Expenses paid to related parties                                                  90,007,620
Clearing expense                                                                  32,491,819
Computer services                                                                  2,780,583
Legal, consulting, and examination fees                                            4,868,287
Other expenses                                                                     8,781,830
Occupancy and equipment                                                            1,097,021
Office expense                                                                     1,316,228
Total expenses                                                                   329,394,146

Income before taxes                                                              (25,269,467)
Income tax benefit                                                                 9,576,241
Net loss                                                                     $   (15,693,226)
Total other comprehensive income
Total comprehensive loss                                                     $   (15,693,226)

The accompanying notes are an integral part ofthesefinancial statements.




                                                                                               3


                                   SunTrust Investment Services, Inc.
                          (A Wholly Owned Subsidiary of SunTrust Banks, Inc.)

                  Consolidated Statement of Changes in Shareholder's Equity



                                               Common               Additional          Retained
                                                Stock             Paid-in Capital       Earnings           Total

Balance, December 31, 2015                           52,125           93,944,723         52,252,287        146,249,135



                                           $
                                                              $
                                                                                    $
                                                                                                       $
  Distribution to Parent




                                                          —
                                                                                —
                                                                                                   —
                                                                                                                    —
   Contribution from Parent




                                                          —
                                                                                —
                                                                                                   —
  Net loss                                                                              (15,693,226)       (15,693,226)




                                                          —
                                                                                —
Balance, December 31, 2016                           52,125           93,944,723         36,559,061        130.555.909
                                           $
                                                              $
                                                                                    $
                                                                                                       $
The accompanying notes are an integral part ofthesefinancial statements




                                                                                                                        4


                                 SunTrust Investment Services, Inc.
                        (A Wholly Owned Subsidiary of SunTrust Banks, Inc.)

                              Consolidated Statement of Cash Flows

                                       Year Ended December 31, 2016


Cash flows used in operating activities
Net loss                                                                            (15,693,226)




                                                                                $
Adjustments to reconcile net income to net cash used in operating activities:
  Depreciation and amortization                                                        541,830
  Deferred tax benefit                                                                (113,911)
  (Increase) decrease in operating assets:
     Securities segregated under Federal and other regulations                           15,195
     Securities owned                                                                    (1,189)
     Commissions receivable                                                            (237,607)
     Prepaid assets                                                                  (4,987,548)
     Other assets                                                                      (893,993)
  Increase (decrease) in operating liabilities:
     Accrued compensation and benefits                                                  278,964
     Income tax payable to Parent                                                        62,573
     Payable to Parent                                                                  577,565
     Accrued other expenses                                                           5,290,341
Net cash used in operating activities                                               (15,161,006)

Cash flows used in investing activities
Purchases of furniture and equipment                                                  (222,741)
Net cash used in investing activities                                                 (222,741)

Cash flows used in financing activities
Contribution from Parent                                                                     —
Distribution to Parent
Net cash used in financing activities                                                        —

Net decrease in cash and cash equivalents                                           (15,383,747)
Cash and cash equivalents, beginning of year                                         82,116,940
Cash and cash equivalents, end of year                                          $    66,733,193

Supplemental cash flow information
Cash paid for income taxes to Parent                                            $            —

The accompanying notes are an integral part ofthesefinancial statements.




                                                                                              5


                            SunTrust Investment Services, Inc.
                    (A Wholly Owned Subsidiary of SunTrust Banks, Inc.)

                       Notes to Consolidated Financial Statements




1. Organization

SunTrust Investment Services, Inc.(the Company or STIS)is a broker-dealer registered with the
Securities and Exchange Commission (the SEC)and the Financial Industry Regulatory Authority
(FINRA). The Company is a wholly owned subsidiary of SunTrust Bank Holding Company,
which is a wholly owned subsidiary of SunTrust Banks, Inc. (the Parent or STI). The Company
acts as an introducing broker-dealer offering full-service and discount brokerage services in
various equity and debt securities, mutual funds, unit investment trusts, insurance and annuity
products, and individual retirement accounts primarily to retail customers of SunTrust Bank.
SunTrust Bank is a subsidiary of SunTrust Bank Holding Company that provides deposit, credit,
trust, and investment services. During 2016, STIS established a wholly-owned subsidiary,
SunTrust Advisory Services, LLC (STAS), which is a Registered Investment Advisor with the
SEC. Activity in this entity was de minimis for the year ended December 31,2016.

2. Summary of Significant Accounting Policies

Principles of Consolidation and Basis of Presentation

The Consolidated Financial Statements have been prepared in accordance with U.S. GAAP and
include the accounts of the Company and its subsidiary after elimination of significant
intercompany accounts and transactions. In the opinion of management, all adjustments,
consisting only of normal recurring adjustments that are necessary for a fair presentation of the
results of operations in these consolidated financial statements, have been made.

The preparation of financial statements in conformity with accounting principles generally
accepted in the United States requires management to make estimates and assumptions that
affect the reported amounts of assets and liabilities, the disclosure of contingent assets and
liabilities at the date of the financial statements, and the reported amounts of revenues and
expenses during the reporting period. Actual results could vary from those estimates.

Cash and Cash Equivalents

The Company has defined cash and cash equivalents as highly liquid investments with original
maturities of less than three months that are not held for sale in the ordinary course of business.
Included in cash and cash equivalents at December 31,2016, is cash of $18,925,438 at SunTrust
Bank and $47,807,755 of money market funds.


                                                                                                      rel


                            SunTrust Investment Services, Inc.
                    (A Wholly Owned Subsidiary of SunTrust Banks, Inc.)

                       Notes to Consolidated Financial Statements




Securities Segregated Under Federal and Other Regulations

At December 31, 2016, total securities of $4,509,009 have been segregated in a special reserve
account at SunTrust Bank for the exclusive benefit of customers of the Company under SEC
Rule 156-3.

Furniture, Equipment, and Leasehold Improvements

Furniture and equipment are stated at cost less accumulated depreciation. Depreciation is
calculated using the straight-line method over the assets' estimated useful lives. Maintenance and
repairs are charged to expense as incurred and included in the consolidated statement of
operations in occupancy and equipment expense. Leasehold improvements are capitalized and
amortized over the lesser ofthe economic useful life ofthe improvement or the term of the lease.

                                                                                Useful Life

   Leasehold improvements                                                        1-30 years
   Furniture and equipment                                                       1-20 years

Revenue Recognition

The Company places all trades through an unaffiliated clearing broker. The clearing broker
collects the gross brokerage commissions from customers and remits the net brokerage
commissions to the Company based on agreed-upon terms. Revenues are recorded on a trade-
date basis and included in commissions in the accompanying consolidated statement of
operations.

The Company recognizes fee income earned from investment advisory services which is
calculated per contracted percentage fees based on current fair value of assets under
management. This revenue which is recognized as services are provided is recorded as
investment management income in the accompanying consolidated statement of operations.

Secondary trading transactions, which consist primarily of riskless principal fixed income and
unit investment trust trades, and related gains, primarily mark-ups on the trades, and losses are
recorded on a trade-date basis in commissions revenue in the accompanying consolidated
statement of operations.




                                                                                                     7


                             SunTrust Investment Services, Inc.
                     (A Wholly Owned Subsidiary of SunTrust Banks, Inc.)

                       Notes to Consolidated Financial Statements




The Company recognizes fee income earned from the trading activity associated with various
mutual fund groups. This fee income consists of administrative services fees; which include
recordkeeping, reporting, and processing services. The fees are included in commissions revenue
in the accompanying consolidated statement of operations. Other income primarily consists of
referral fees.

Customer Accounts

The clearing broker maintains all customers' accounts, receives cash on purchases, and
distributes cash on sales. The Company records commissions receivable for its share of
commissions charged to customers.

Prepaid Assets

The Company records prepaid assets at the transaction date which are amortized on a straight
line basis over the remaining useful life of the asset. Prepaid assets relating to advances are
amortized over the period of expected future revenue generation. The Prepaid assets generally
relate to incentive bonuses paid to advisors upon hire.

Expense Paid to Related Parties

Affiliates of the Company provide services to STIS in accordance with various agreements.
These services include finance, human resources, facilities management, etc. The Company
pays these affiliates for the services it receives.

Income Taxes

The provision for income taxes is based on income and expense reported for financial statement
purposes after adjustment for permanent differences. Deferred income tax assets and liabilities
result from differences between the timing of the recognition of assets and liabilities for financial
reporting purposes and for income tax purposes. These assets and liabilities are measured using
the enacted federal and state tax rates and laws that are expected to apply in the periods in which
the deferred tax assets or liabilities are expected to be realized. Subsequent changes in the tax
laws require adjustment to these assets and liabilities with the cumulative effect included in the
provision for income taxes for the period in which the change is enacted. A valuation allowance
is recognized for a deferred tax asset if, based on the weight of available evidence, it is more
likely than not that some portion or all ofthe deferred tax asset will not be realized. In computing
the income tax provision, the Company evaluates the technical merits of its income tax positions


                                          SunTrust Investment Services, Inc.
                              (A Wholly Owned Subsidiary of SunTrust Banks, Inc.)

                                  Notes to Consolidated Financial Statements




based on current legislative,judicial and regulatory guidance. Interest and penalties related to the
Company's tax positions are recognized as a component of the income tax provision. For
additional information on the Company's activities related to income taxes, see Note 9,"Income
Taxes."

The Company is included in the consolidated federal income tax return and various consolidated
or combined state income tax returns filed by SunTrust Banks, Inc. In accordance with the Tax
Allocation Agreement applicable to SunTrust Banks, Inc. and each of its subsidiaries, the
Company's income taxes are calculated as if the Company filed separate income tax returns with
appropriate adjustments to properly reflect the impact of a consolidated filing. Payments to tax
authorities are made by SunTrust Banks, Inc.

Goodwill

The Company reviews goodwill on an annual basis for impairment and as events occur or
circumstances change that would more-likely-than-not reduce the fair value below its carrying
amount. No impairment of goodwill was recorded in 2016.

3. Pending Accounting Pronouncements


                                                                                    Required Date of Effect on the Financial Statements
    Standard                                Description                                Adoption         or Other Signifeant Matters

 Standards Not Yet Adopted
 ASU       2016-01, The UU amends ?SC Topic 325, Financial Instruments- January 1; 2013                     The Company is evaluating the impact
 Recognition and Overall; and addresses certain aspect; o: recognition;                                     o= this —SU on the Consolidated
 Measurement o: measurement: presentation; and disclosure of financial Early adoption is                    Financial Statements and related
 Financial .Assets instruments. The main provisions require investments in equity permitted beginning       disclosures. however, the impact is not
 and       Financial securities to be measured at :air value through net income. January 1; 2016 or         expected to be material.
 Liabilities         unless they quatiti for a practicability exception, and require 201'        for  the
                     fair value changes arising from changes in instrument-speseic provision related to
                     credit risk for financial liabilities that are measured under the changes         in
                     fair value option to be reco;nized in other operations. With instrument-specific
                     the exception of disclosure requirentents that still be adopted credit      risk for
                     prospectively; the ASU must be adopted on a modified financial liabilities
                     retrospective basis.                                              under the FV0.




                                                                                                                                                      0


                                         SunTrust Investment Services, Inc.
                             (A Wholly Owned Subsidiary of SunTrust Banks,Inc.)

                                  Notes to Consolidated Financial Statements




                                                                                    Required Date of Effect on the Financial Statements
    Standard                                Description                                 Adoption        or Other Significant Matters
ASU     2016-02, The ASU creates ASC Topic 342,Leases, and supersedes Topic January 1, 2019                The adoption of this ASU will result in
Leases             340, Leases. Topic 342 requires lessees to recognize right-of-                          an increase to the Consolidated
                   use assets and associated liabilities that arise from leases; with Early adoption is    Statement oEFinancial Condition for
                   the exception of short-term leases. The ASU does not make           permitted.          right-o:-use assets and associated lease
                   significant changes to lessor accounting; however, there were                           liabilities for operating leases in which
                   certain improvements nude to align lessor accounting with the                           the Company is the lessee. The
                   lessee accounting model and Topic 606,Revenue from                                      Company is evaluating the other effects
                   Contracts with Customers. There are several new qualitative                             o:adoption on the Consolidated
                   and quantitative disclosures required. Upon transition. lessees                         Financial Statements and related
                   and lessor are required to recognize and measure Lases at the                           disclosures.
                   beginning of the earliest period presented using a modified
                   retrospective approach.
ASU     2014-09, These ASUs supersede the revenue recognition                       in January 1, 2013     The Company is evaluating the
                                                                  requirements
Revenue      front ASC Topic 605, Revenue Recognition, and most industry-                                  anticipated effects of these ASUs an the
Contracts with specific guidance throughout the industry Topics of the                 Early adoption is   Consolidated Financial Statements and
Customers          Codification. The core principle_ of the ASUr.is that in entity permitted beginning     related disclosures. The Company has
                   should recognize revenue to depict the transfer of promised         January 1, 201'.    conducted a comprehensive seoping
ASU     2015-14. goods or services to customers in an amount that reflects the                             exercise to determine the revenue
Deferral of the consideration to which the entity expects to be entitled in                                streanu that are in the scope of these
Effective Date     exchange for those goods or services. The AsUs may be                                   updates. Preliminary; results indicate
                   adopted either retrospectively or on a modified retrospective                           that certain conuitission revenue
ASU      2016-03. basis to new contracts and existing contracts; with remaining                            streams are in scope of these updates.
Principal versus performance obligations as of the effective date.                                         Pretiminary findings indicate that there
Agent                                                                                                      may be some changes in grass versus net
Considerations                                                                                             presentation based on principal versus
                                                                                                           agent guidance within these updates; the
ASU      2016-10,                                                                                          materiality of these chang=es is still
Identifying                                                                                                being assessed. The Company plans to
Performance                                                                                                adopt the standards beginning January: 1.
Obligations and                                                                                            2013 and expects to use the modified
Licensing                                                                                                  retrospective method of adoption.

ASU     2016-12.
 Jarrow    $cope
Improvements
and     Practical
Expedients

ASU      2016-20.
Technical
Corrections and
Improvements to
Topic        606,
Revenr.e     from
Contracts     with
Customers


                              SunTrust Investment Services, Inc.
                     (A Wholly Owned Subsidiary of SunTrust Banks, Inc.)

                        Notes to Consolidated Financial Statements




4. Fair Value of Financial Instruments

ASC Topic 820, Fair Value Measurements(ASC Topic 820), defines fair value, establishes a
framework for measuring fair value, and establishes a fair value hierarchy which prioritizes the
inputs to valuation techniques. Fair value is the price that would be received to sell an asset or
paid to transfer a liability in an orderly transaction between market participants at the
measurement date. A fair value measurement assumes that the transaction to sell the asset or
transfer the liability occurs in the principal market for the asset or liability or, in the absence of a
principal market, income or cost approach, as specified by ASC Topic 820, are used to measure
fair value.

The fair value hierarchy priorities the inputs to valuation techniques used to measure fair value
into three broad levels:

   • Level 1 — Assets or liabilities valued using unadjusted quoted prices in active markets for
     identical assets or liabilities that the Company can access at the measurement date, such
     as publicly-traded instruments or futures contracts.

   • Level 2 — Assets and liabilities valued based on observable market data for similar
     instruments.

   • Level 3 — Assets or liabilities for which significant valuation assumptions are not readily
     observable in the market; instruments valued based on the best available data, some of
     which is internally developed, and considers risk premiums that a market participant
     would require.

The Company's financial instruments, which are included in the accompanying consolidated
statement of financial condition, are either measured at quoted market prices or are short-term in
nature. As a result, the carrying amounts reported approximate their estimated fair values at
December 31, 2016. Money market funds of$47,807,755, included in cash and cash equivalents,
and US Treasuries of $4,509,009, included in securities segregated under federal and other
regulations, are valued using quoted prices in active markets and are classified as Level 1 assets
in accordance with ASC Topic 820. The other securities owned includes $7,282 of non-
marketable securities which are valued based on the best available data provided by an unrelated
third party in order to approximate fair value and are considered Level 3 assets. The total amount
of gains relating to the securities owned for the period included in other income in the
consolidated statement of operations is not significant. There were no transfers between Level 1
and Level 2 or between Level 2 and Level 3 during the year ended December 31, 2016.

                                                                                                           11


                             SunTrust Investment Services, Inc.
                     (A Wholly Owned Subsidiary of SunTrust Banks, Inc.)

                       Notes to Consolidated Financial Statements




5. Related-Party Transactions

During the period ended December 31, 2016, the Company engaged in various transactions with
the Parent and its affiliates. Balances with respect to related parties reflected in the December 31,
2016, consolidated financial statements, are as follows:

   Cash and cash equivalents                                                     $18,925,438
   Securities segregated under Federal and other regulations                        4,509,009
   Current income taxes receivable from Parent                                      1,412,174
   Pension receivable from Parent                                                   1,169,130
   Deferred income taxes payable to Parent                                          6,271,221
   Payable to Parent                                                                1,579,554
   Expense paid to related parties                                                90,007,620
   Pension and other employee benefit plan expense                                 12,354,724
   Restricted stock expense                                                         1,058,022
   Other income                                                                     8,129,076


Expense to affiliates arises from the use of STI's internal services and corporate real estate based
on an agreed expense sharing agreements. Allocation methodologies vary for these services but
are generally based on revenue, headcount or utilization. Expense attributable to pension and
other employee benefit plans and restricted stock awards is further discussed in Note 8.

Other income primarily represents contractual referral fees from the SunTrust Private Wealth
line of business. Further, at client request, STIS will purchase bank-sponsored or affiliate-
underwritten products and sell them to the client for a commission.

During 2016, STIS began guaranteeing loans made by SunTrust Bank to certain key STIS
employees. While ordinarily payable to SunTrust Bank on demand, generally STIS would not
be called upon to make a payment on the loan unless the loan becomes past due or the employee
ceases to be employed by STIS. In the event STIS is called upon to reimburse SunTrust Bank,
the payment made to SunTrust Bank will be for any outstanding principal and interest. STIS
will then have the ability to pursue reimbursement through other standard channels. As of
December 31, 2016, the principal outstanding on these loans subject to STIS guarantee totaled
$7,329,992. During 2016, the Company was not called upon by SunTrust Bank to make a
payment nor has it recorded a liability for future payments as they were neither estimable nor
probable at December 31, 2016.



                                                                                                        12


                           SunTrust Investment Services, Inc.
                    (A Wholly Owned Subsidiary of SunTrust Banks, Inc.)

                       Notes to Consolidated Financial Statements




6. Commitments and Contingencies

In the ordinary course of business, the Company is subject to regulatory examinations,
investigations, and requests for information, and is also party to numerous civil claims and
lawsuits. Some of these matters involve claims for substantial amounts. The Company's
experience has shown that the damages alleged by plaintiffs or claimants are often overstated,
based on novel or unsubstantiated legal theories, unsupported by the facts, and/or bear no
relation to the ultimate award that a court might grant. Additionally, the outcome of litigation
and regulatory matters and the timing of ultimate resolution are inherently difficult to predict.
Because of these factors, the Company typically cannot provide a meaningful estimate of the
range of reasonably possible outcomes of claims in the aggregate or by individual claim. On a
case-by-case basis, however, reserves are established for those legal claims in which it is
probable that a loss will be incurred and the amount of such loss can be reasonably estimated.
In no cases are those accrual amounts material to the financial condition of the Company.
The actual costs of resolving these claims may be substantially higher or lower than the
amounts reserved.

Based on current knowledge, it is the opinion of management that liabilities arising from legal
claims in excess of the amounts currently accrued, if any, will not have a material impact to the
Company's financial condition, results of operations, or cash flows. However, in light of the
significant uncertainties involved in these matters, and the large or indeterminate damages
sought in some of these matters, there is a remote possibility that an adverse outcome in one or
more of these matters could be material to the Company's results or cash flows for any given
reporting period.

The SEC Division of Enforcement is investigating whether STIS committed fraud under the
Investment Advisers Act of 1940("IAA") by purchasing mutual fund shares on behalf of clients
that imposed an SEC Rule 12b-1 distribution fee on the investment when share classes which did
not impose such a fee were available to such clients. On February 8, 2017, the SEC Staff
informed the Company that it has made a preliminary determination to recommend that the SEC
bring an enforcement action against the Company. The Company is researching the extent to
which alternate mutual fund classes were available to its clients which did not impose Rule 12b-
1 distribution fees, and other matters. The Company estimates that the amount of Rule 12b-1
distribution fees at issue was $5 million or less over the period 2012-2015. If there is a finding
or admission that the Company violated the antifraud provisions of the IAA, the Company could
be subject to penalties. If there is a finding or admission that the Company violated the IAA
with scienter, the Company's ability to earn certain investment advisory referral fees will be
limited unless the SEC grants appropriate waivers. Beginning July 1, 2015, the Company began


                                                                                                     13


                            SunTrust Investment Services, Inc.
                    (A Wholly Owned Subsidiary of SunTrust Banks, Inc.)

                       Notes to Consolidated Financial Statements




crediting 12b-1 fees related to all advisory accounts on a going forward basis. The Company is
assessing the matter and how it intends to proceed. The Company is cooperating with the
investigation and is in discussions with the SEC.

7. Guarantees to Third Parties

The Company uses a third-party clearing broker to clear and execute customers' securities
transactions and maintain customer accounts. Under the agreement with the clearing broker,
the Company agrees to indemnify the clearing broker for losses that result from a customer's
failure to fulfill its contractual obligations. As the clearing broker's rights to charge the
Company have no maximum amount, the Company believes that the maximum potential
obligation cannot be estimated. However, to mitigate exposure, the Company may seek recourse
from the customer through cash or securities held in the defaulting customer's account. The
Company believes it is unlikely it will have to make material payments under this arrangement,
and has not recorded any contingent liability in the financial statements for this indemnity. For
the year ended December 31, 2016, the Company experienced no material net losses as a result
ofthe indemnity. The clearing agreement expires in May 2020.

8. Employee Benefits

The Company participates in the pension plan and other employee benefit plans of STI for the
benefit of substantially all employees of the Company. Costs of the pension plan are allocated to
the Company based on its estimated pro rata share. Benefit information is not available from the
actuary for individual subsidiaries of STI. The Company's expense allocated to the pension and
other employee benefit plans was $12,354,724 which is included in compensation and benefits
expense in the accompanying consolidated statement of operations. The Company incurred
$120,091,409 in incentive-based compensation expense, which is included in compensation and
benefits expense in the accompanying consolidated statement of operations.

The Parent provides stock-based awards through the SunTrust Banks Inc., 2009 Stock Plan (as
amended and restated effective January 1, 2012) under which the Compensation Committee of
the Board of Directors (the Committee) has the authority to grant stock options, restricted stock,
and restricted stock units, of which some may have performance features to key employees of
the Company. All incentive awards are subject to claw back provisions.

The Parent allocates stock option and restricted stock option expense to the Company. The
Company's restricted stock expense for 2016 was $1,058,022 which is also included in
compensation and benefits expense in the accompanying consolidated statement of operations.


                                                                                                     14


                            SunTrust Investment Services, Inc.
                    (A Wholly Owned Subsidiary of SunTrust Banks, Inc.)

                      Notes to Consolidated Financial Statements




At December 31, 2016, there was $2,224,419 of unrecognized stock-based compensation
expense related to restricted stock and stock options.

9. Income Taxes

The Company is included in the consolidated federal income tax return and various consolidated
or combined state income tax returns filed by SunTrust Banks, Inc. In accordance with the Tax
Allocation Agreement applicable to SunTrust Banks, Inc. and each of its subsidiaries, the
Company's income taxes are calculated as if the Company filed separate income tax returns with
appropriate adjustments to properly reflect the impact of a consolidated filing. Additionally the
Company files its own separate state income tax returns in certain jurisdictions. The current and
deferred portions of the income tax expense/(benefit) included in the consolidated statement of
operations as determined in accordance with ASC 740,Income Taxes, are as follows:

                                               2016


                                Current       Deferred   Total
                  Federal    $(8,011,770) $ (121,641) $(8,133,411)
                  State       (1,450,560)      7,730 (1,442,830)
                             $(9,462,330) $ (113,911) $(9,576,241)

A reconciliation of the income tax provision, using the statutory federal rate of 35%, to the
Company's actual provision for income taxes is as follows:

                                                                         2016


        Income tax at federal statutory rate of35%                   $(8,844,314)
        State income taxes, net offederal benefit                       (937,839)
        Other                                                            205,912
        Total provision for income taxes                             $(9,576,241)


Deferred income tax assets and liabilities result from differences between the timing of the
recognition of assets and liabilities for financial reporting purposes and for income tax purposes.


                                                                                                      15


                             SunTrust Investment Services, Inc.
                     (A Wholly Owned Subsidiary of SunTrust Banks, Inc.)

                        Notes to Consolidated Financial Statements




These assets and liabilities are measured using the enacted federal and state tax rates expected to
apply in the periods in which the deferred tax assets or liabilities are expected to be realized. The
significant components of the deferred tax assets and deferred tax liabilities, net of the federal
impact for state taxes, as of December 31, 2016 were as follows:

                                                                             2016
             Deferred Tax Assets:
                    Employee benefits                                  $     7,837,722
                    Litigation accrual                                 $     1,929,953
                    State tax credit                                            59,909
                    Other                                                       20,337
                    Total Deferred Tax Assets                          $     9,847,921

             Deferred Tax Liabilities:
                   Prepaid expenses                                    $ (15,860,985)
                    Fixed assets                                            (258,156)
                    Total Deferred Tax Liabilities                     $ (16,119,141)

             Net Deferred Tax Liabilities                              $    (6,271,220)

The deferred tax assets include state tax credit carryforwards of $59,909 as of December 31,
2016, that will expire, if not utilized, in 2018. The Company determined that a valuation
allowance is not required for the federal and state deferred tax assets because it is more-likely-
than-not these assets will be realized.

No unrecognized tax benefits have been recorded, and no corresponding interest or penalties
have been accrued. The Company continually evaluates the unrecognized tax benefits
associated with its uncertain tax positions. The Company does not expect a significant change in
its unrecognized tax benefits within 12 months of this reporting date.

The Company is included in the consolidated federal income tax return and various consolidated
or combined state income tax returns filed by SunTrust Banks, Inc. Additionally, the Company
files its own separate state income tax returns and local tax returns in certain


                                                                                                        16


                             SunTrust Investment Services, Inc.
                    (A Wholly Owned Subsidiary of SunTrust Banks, Inc.)

                      Notes to Consolidated Financial Statements




jurisdictions. SunTrust Banks, Inc.'s federal income tax returns are no longer subject to
examination by the Internal Revenue Service for taxable years prior to 2011. With limited
exceptions, the various consolidated or combined state income tax returns filed by SunTrust
Banks, Inc., in which the Company is included, along with the Company's separate income tax
returns, are no longer subject to examination by state and local taxing authorities for taxable
years prior to 2012.

10. Net Capital Requirements

Rule 15c3-1 of the Securities Exchange Act of 1934 (the Rule)requires the Company to
maintain minimum net capital, as defined. At December 31, 2016, the Company was in
compliance with the net capital requirements of the Rule. At December 31, 2016, the Company,
on a standalone basis, had net capital, as defined, of $38,124,633, which was $35,956,139 in
excess of the required net capital of $2,168,494. The Company's ratio of aggregate indebtedness
to net capital was 0.85:1 at December 31, 2016, which is below the 15:1 maximum allowed. A
reconciliation between total assets, liabilities and equity of STIS presented in the FOCUS to the
consolidated financial statements is presented below.

                                  Per FOCUS             Eliminations
                                 (Unaudited)    STAS      /Other     Consolidated
Total assets                    $ 163,123,693 $ 281,835 $ (281,835) $ 163,123,693
Total liabilities                   32,567,784      -           -       32,567,784
Total stockholder's equity         130,555,909  281,835    (281,835)   130,555,909

11. Subsequent Events

The Company evaluated subsequent events through the date its consolidated financial statements
were issued. Effective January 1, 2017, STIS transferred its investment advisory business into
STAS and then proceeded to dividend its ownership in STAS to its Parent. The dividend to the
Parent had no impact to net capital. In conjunction with the dividend, goodwill of
approximately $12,400,000 transferred to STAS as well. During 2016, revenue associated with
the investment advisory business at STIS totaled $124,736,272. STIS personnel will continue to
provide sales and administrative services to STAS in 2017 and STIS will record as revenue fees
charged to STAS for these services. On January 27, 2017, the Company filed a Form ADV W
to de-register itself as a Registered Investment Advisor, but will continue to be regulated by
FINRA and the SEC.


                                                                                                    17


Supplemental Information


                      SunTrust Investment Services, Inc.
               (A Wholly Owned Subsidiary of SunTrust Banks, Inc.)

Schedule I — Computation ofNet Capital and Aggregate Indebtedness Pursuant to
            Rule 15c3-1 ofthe Securities and Exchange Commission




                                                                            18


                           FINANCIAL AND OPERATIONAL COMBINED UNIFORM SINGLE REPORT                                                                             2017-01-26 10:29AM EST
                                                                                                                                                                Status: Accepted      _
                                                                                                    PART 11

    BROKER OR DEALER
    SUNTRUST INVESTMENT SERVICES, INC.
                                                                                                                               as of   12/31/16


                                                               COMPUTATION OF NET CAPITAL
1. Total ownership equity (from Statement of Financial              Condition Item 1800) .....................                                                     130,555,909 3460




                                                                                                        -
                                                                                                                                                  $
2. Deduct: Ownership equity not allowable for Net Capital              ....................................                                                                    F3490




                                                                                                                                                                              )
                                                                                                                                                      (
3. Total ownership equity qualified for Net Capital             ..........................................                                                         130,555,909 3500
4. Add:
    A. Liabilities subordinated to claims of general creditors allowable in computation of net capital ......                                                                     3520
    B. Other (deductions) or allowable credits (List) .........................................                                                                                    525
                                                                                                                                                                                  LL
5. Total capital and allowable subordinated liabilities ........................................                                                                   130,555.909 LL59




                                                                                                                                                  $
6. Deductions and/or charges:
    A. Total non-allowable assets from
       Statement of Financial Condition (Notes B and C) ..............                        91,407,945 3540




                                                                                                                       $
       1. Additional charges for customers' and
           non-customers' security accounts .......... .............                                      3550
                                                                                .
       2. Additional charges for customers' and
           non-customers' commodity accounts .....................                                        3560
    B. Aged fail-to-deliver: ....................................                                         3570
       1. number of items ...............                                3450
    C. Aged short security differences-less
       reserve of ......................                                 3460                             3580
                                                       $
       number of items ................                                 JL470
    D. Secured demand note deficiency ..........................                                          3590
    E. Commodity futures contracts and spot commodities
                                                                                    -
       proprietary capital charges ................................                                       3600
    F. Other deductions and/or charges ..........................                                  20,018 3610
    G. Deductions for accounts carried under
       Rule 15c3-1(a)(6), (a)(7) and (c)(2)(x) .......................                                    3615
    H. Total deductions and/or charges         ................................................                                                                     91,427,963) 3620
                                           .
                                               .
                                                                                                                                                          (
7. Other additions and/or allowable credits (List) ...........................................                                                                                  3630
8. Net Capital before haircuts on securities positions .................. ....................                                                                      39,127,946 136401
                                                                                                                           .
                                                                                                                                                  $
9. Haircuts on securities:(computed, where applicable,
    pursuant to 15c3-1(f)):
    A. Contractual securities commitments ........................                                        3660
                                                                                                                       $
    B. Subordinated securities borrowings, ,,,                ,,      ,, ,,                               3670
                                                   ,
                                                           ,
                                                                ,
                                                                    ,
                                                                        ,
                                                                            ,
                                                                                    ,
                                                                                        ,
                                                                                            ,
                                                                                                ,
                                                                                                    ,
                                                                                                        ,
                                                                                                               ,
                                                                                                                   ,
    C. Trading and investment    securities:  .........................
        1. Bankers' acceptances, certificates of deposit
           and commercial paper ................................                                          3680
        2. U.S. and Canadian government obligations ................                               33,818 3690
       3. State and municipal government obligations ................                                     3700
       4. Corporate obligations .................................                                         3710
        5. Stocks and warrants ..................................                                         3720
       6. Options ...........................................                                             3730
       7. Arbitrage ..........................................                                            3732
       8. Other securities   .....................................                                969,495 3734
    D. Undue concentration ...................................                                            3650
     E. Other (List) .........................................                                            3736                                                       1,003,313) 3740
                                                                                                                                                          (
 10. Net Capital ...................................................................$                                                                               38,124,633 3750

                                                                                                                                                              OMIT PENNIES
                                                                                                            Page 5


                          FINANCIAL AND OPERATIONAL COMBINED UNIFORM SINGLE REPORT                                                  2017-01-26 10:29AM EST
                                                                                                                                    Status: Accepted
                                                    PART 11
   BROKER OR DEALER
                                                                                             as of               12/31/16
   SUNTRUST INVESTMENT SERVICES, INC.


                                    COMPUTATION OF BASIC NET CAPITAL REQUIREMENT
Part A
11. Minimal net capital required (6-213% of line 19)        ...............................................                                2,168,49457R




                                                                                                                                $
12. Minimum dollar net capital requirement of reporting broker or dealer and minimum net capital requirement
    of subsidiaries computed in accordance with Note(A)           .........................................                                  250,000 3758




                                                                                                                                $
13. Net capital requirement(greater of line 11 or 12)          ............................................                                2,168,494 3760




                                                                                                                                $
14. Excess net capital (line 10 less 13)            .....................................................                                 35,956,139 3770




                                                                                                                                $
15. Net capital less greater of 10% of line 19 or 120% of line 12 ............................ .........                                                 1
                                                                                                                                          34,871,894 F3780




                                                                                                     .
                                                                                                         .
                                                                                                                                $
                                        COMPUTATION OF AGGREGATE INDEBTEDNESS
16.Total A.I. liabilities from Statement of Financial Condition    .......................................                                              1
                                                                                                                                          32,527,392F379-0




                                                                                                                                $
17. Add:
    A. Drafts for immediate credit        .................................                                 3800




                                                                                $
    B. Market value of securities borrowed for which no
        equivalent value is paid or credited       ............................                             3810




                                                                                $
    C. Other unrecorded amounts (List)           ..............................                             3820                                     3830




                                                                                $
                                                                                                                                $
18. Deduct: Adjustment based on deposits in Special Reserve Bank Accounts(15c3-1(c)(1)(vii)) ...............                                         3838




                                                                                                                                $
19. Total aggregate indebtedness                  ..   ..................................................                                 32.527,392F 1
                                                                                                                                                    3840
                                                  .
                                              .
                                                      .
                                                                                                                                $
20. Percentage of aggregate indebtedness to net capital (line 19 divided by line 10)     .... ..................                               85.32[L
                                                                                                                                                     89




                                                                                                                            %
                                                                                         .
21. Percentage of aggregate indebtedness to net capital after anticipated capital withdrawals
    (line 19 divided byline 10 less item 4880 page 12)       .............................................                                     85.32F38531




                                                                                                                            %
                                 COMPUTATION OF ALTERNATE NET CAPITAL REQUIREMENT
Part B
22.2% of combined aggregate debit items as shown in Formula for Reserve Requirements pursuant
    to Rule 15c3-3 prepared as of the date of net capital computation including both
    brokers or dealers and consolidated subsidiaries' debits        .......................................                                          3870




                                                                                                                                $
23. Minimum dollar net capital requirement of reporting broker or dealer and minimum net capital
    requirement of subsidiaries computed in accordance with Note(A)                                                                                  3880



                                                                                                                                $
24. Net capital requirement(greater of line 22 or 23)         .................................... .......   I




                                                                                                                                $
25. Excess net capital (line 10 less 24)             ....................................................                                            3910
                                                                                                                                $
26. Percentage of Net Capital to Aggregate Debits (line 10 divided byline 17 page 8) ........................
                                                                                                                            %
                                                                                                                                                     3851
27. Percentage of Net Capital, aflfI anticipated capital withdrawals, to Aggregate Debits
    item 10 less Item 4880 page 12 divided by line 17 page 8)      ........................................                                          3854
                                                                                                                            %
28. Net capital in excess of the greater of:
    5% of combined aggregate debit items or 120% of minimum net capital requirement .....................                                            3920
                                                                                                                                $
                                                             OTHER RATIOS
Part C
29. Percentage of debt to debt-equity total computed in accordance with Rule 15c3-1 (d) ....................                                    0.00F3860
                                                                                                                            %
30. Options deductions/Net Capital ratio(1000% test) total deductions exclusive of liquidating
   equity under Rule 15c3-1(a)(6),(a)(7) and (c)(2)(x) divided by Net Capital    ............................                                        3852
                                                                                                                            %
NOTES:
(A)The minimum net capital requirement should be computed by adding the minimum dollar net capital requirement
    of the reporting broker dealer and, for each subsidiary to be consolidated, the greater of:
     1. Minimum dollar net capital requirement, or
    2.6-213% of aggregate indebtedness or 2% of aggregate debits if alternate method is used.
(B)Do not deduct the value of securities borrowed under subordination agreements or secured demand notes
    covered by subordination agreements not in satisfactory form and the market values of memberships in
    exchanges contributed for use of company (contra to item 1740) and partners' securities which were
    included in non-allowable assets.
(C) For reports filed pursuant to paragraph (d) of Rule 17a-5, respondent should provide a list of material
     non-allowable assets.

                                                                     Page 6


                                  SunTrust Investment Services, Inc.
                        (A Wholly Owned Subsidiary of SunTrust Banks,Inc.)

        Schedule I — Computation of Net Capital and Aggregate Indebtedness
         Pursuant to Rule 156-1 of the Securities and Exchange Commission
                         Schedule of Non Allowable Assets

                                               December 31, 2016


Non-marketable securities                                                       $             7,282
Furniture, equipment, and leasehold improvements                                          1,164,816
Commissions receivable                                                                    2,369,708
Goodwill                                                                                 42,706,365
Prepaids and other assets                                                                45,159,774
Total nonallowable assets                                                                91,407,945

There are no material differences between this computation and the Company's unaudited
Form X-1 7A-5 as ofDecember 31, 2016,filed on Jamuafy 26, 2017.




                                                                                                      21


                         SunTrust Investment Services, Inc.
                   (A Wholly Owned Subsidiary of SunTrust Banks, Inc.)

      Schedule II — Computation of Determination of Reserve Requirements
       Pursuant to Rule 15c3-3 of the Securities and Exchange Commission

                                    December 31, 2016




The Company is exempt from Rule 15c3-3 of the Securities and Exchange Commission as it
relates to the computation of reserve requirements under paragraph (k)(2)(ii) of that rule.




                                                                                         OX


                        SunTrust Investment Services, Inc.
                 (A Wholly Owned Subsidiary of SunTrust Banks, Inc.)

   Schedule III — Information Relating to Possession or Control Requirements
      Pursuant to Rule 15c3-3 ofthe Securities and Exchange Commission

                                  December 31,-2016



The Company is exempt from Rule 15c3-3 of the Securities and Exchange Commission as it
relates to possession and control under paragraph (k)(2)(ii) ofthat rule.




                                                                                    23



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