# BANKOH INVESTMENT SERVICES, INC. X-17A-5/A (2021-08-25) — Broker-dealer annual report - Company: BANKOH INVESTMENT SERVICES, INC. - Form: X-17A-5/A - Filed: 2021-08-25 - Period: 2020-12-31 - Accession: 0000879857-21-000005 - CIK: 879857 - File #: 8-04420 - Material weakness: No - Auditor: Ernst & Young, LLP - Auditor location: Honolulu, HI - Contact: Christopher Keller - Phone: 8086948949 - Signed by: Christopher A. Otto (President / CEO) Original filing: https://www.sec.gov/Archives/edgar/data/879857/000087985721000005/X-17A-5.pdf --- {0}------------------------------------------------ **UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549** # **ANNUAL AUDITED REPORT FORM X-17A-5 PART Ill** **FACING PAGE** **Information Required of Brokers and Dealers Pursuant to Section 17 of the Securities Exchange Act of 1934 and Rule 17a-5 Thereunder** | REPORT FOR THE PERIOD BEGINNING 01/01/2020 | | -----------
AND ENDING 12/31/2020 | | | | |--------------------------------------------------------------------------|---------------------------------------------------------|--------------------------------------|---------------------------------|--|--| | | -----------
MM/DDIYY | | M MID D / Y Y | | | | | A. REGISTRANT IDENTIFICATION | | | | | | Sankoh Investment Services, Inc.
NAME OF BROKER-DEALER: | | | OFFICIAL USE ONLY | | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.) | | | FIRM I.D. NO. | | | | 130 Merchant Street, CC 4 75 | | | | | | | | (No. and Street) | | | | | | Honolulu | HI | | 96813 | | | | (C11y) | (Stale) | | (Zip Code) | | | | NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT | | | | | | | | | | (Area Code
Telephone Number) | | | | | B. ACCOUNTANT IDENTIFICATION | | | | | | INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report* | | | | | | | Ernst & Young, LLP | | | | | | | | (Name - ff111d11'idual, state last. first. mMdlt ,tame) | | | | | | 1003 Bishop Street, Suite 2600 | Honolulu | HI | 96813 | | | | (Address) | (City) | (Stale) | (Zip Code) | | | | CHECK ONE: | | | | | | | &Z]certified Public Accountant | | | | | | | Public Accountant | | | | | | | B
Accountant not resident in United States or any of its possessions. | | | | | | | | | | | | | | | FOR OFFICIAL USE ONLY | | | | | | | | | | | | *\*Claims for exemption from the requirement that the annual report be col'ered by the opinion of an i11depe11de11t public accountant must be supported by a statement of facts and circ11111sta11ces relied 011 as the basis f or the exemption. See Seclio11 140.* J *7a-5(e)(2)* > **Potential persons who are to respond to the collection of Information contained In this form are not required to respond unless the form displays a currently valid 0MB control number.** SEC 1410 {11-05) 0MB APPROVAL 0MB Number: 3235-0123 Expires: October 31, 2023 Estimated average burden hours per response ..... . 12.00 SEC FILE NUMBER **8-44201** {1}------------------------------------------------ #### **OATH OR AFFIRMATION** | | 1, Christopher A. Otto | | , swear (or affirm) that, to the best of | |------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | | Sankoh Investment Services, Inc. | | my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of
-------------------------------------------- | | of March 2 | | 2021 | , as
are true and correct. I further swear (or affirm) that | | | classified solely as that of a customer, except as follows: | | neither the company nor any partner, proprietor, principal officer or director has any proprietary interest in any account | | | | | fk
CL 0
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Signature | | | | | President/ CEO | | | | | Title | | D
~ | Notary Public
This report** contains (check all applicable boxes):
~ (a) Facing Page.
~ (b) Statement of Financial Condition.
of Comprehensive Income (as defined in §210.1-02 of Regulation S-X).
(yf (d) Statement of Changes in Financial Condition.
EZ! (e) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors' Capital.
(f) Statement of Changes in Liabilities Subordinated to Claims of Creditors.
(g) Computation of Net Capital.
(h) Computation for Determination of Reserve Requirements Pursuant to Rule J 5c3-3.
(i) Information Relating to the Possession or Control Requirements Under Rule 15c3-3.
Computation for Determination of the Reserve Requirements Under Exhibit A of Rule 15c3-3.
consolidation.
~ (I) An Oath or Affirmation. | | ~ (c) Statement of Income (Loss) or. if there is other comprehensive income in the period(s) presented. a Statement
D (j) A Reconciliation, including appropriate explanation of the Computation of Net Capital Under Rule 15c3-1 and the
D (k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of | | | □~ (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. | | | **For co11ditions of confide11tial treatment of certain portions of this filing, see section 240.17a-5(e)(3). | | | Due to difficulties arising from COVID-19, Bankoh Investment Services, Inc. ("BISI") was unable to obtain the required notarization. As permitted under the statement from Commission staff (Updated Division of Trading and Markets Staff Statement Regarding Requirements for Certain Paper Submissions in Light of COVID-19 Concerns, dated April 2, 2020 and modified June 18, 2020), BISI is filing this annual report without a notarization. {2}------------------------------------------------ #### F I N A N C I A L S T A T E M E N T S A N D S U P P L E M E N T A L I N F O R M A T I O N Bankoh Investment Services, Inc. Year Ended December 31, 2020 With Report of Independent Registered Public Accounting Firm {3}------------------------------------------------ # Financial Statements and Supplemental Information Year ended December 31, 2020 # Contents | Report of Independent Registered Public Accounting Firm 1 | | |--------------------------------------------------------------|--| | Financial Statements | | | Statement of Financial Condition 2 | | | Statement of Income 3 | | | Statement of Changes in Stockholder's Equity 4 | | | Statement of Cash Flows 5 | | | Notes to Financial Statements 6 | | | Supplemental Information | | | Schedule I - Computation of Net Capital Under Rule 15c3-1 12 | | | Schedule II- Statement Pursuant to SEC Rule 17a-5(d) 14 | | | Schedule III - Statement Pursuant to SEC Rule 17a-5(d) 15 | | {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) Ernst &Young 1003 Bishop Street Suite 2600 Honolulu, HI 96813 Tel: + 1 808 531 2037 Fax: +1 808 548 T?44 ey.com #### **Report oflndependent Registered Public Accounting Finn** To the Shareholder and the Board of Directors of Bankoh Investment Services, Inc. #### **Opinion on the Financial Statements** We have audited the accompanying statement of financial condition of Bankoh Investment Services, Inc. (the Company) as of December 31, 2020, the related statements of income, changes in stockholder's equity, and cash flows for the year then ended, and the related notes ( collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Company at December 31, 2020, and the results of its operations and its cash flows for the year then ended in conformity with U.S. generally accepted accounting principles. #### **Basis for Opinion** These financial statements are the responsibility of the Company's management. Our responsibility is to express an opinion on the Company's financial statements based on our audit. We are a public accounting finn registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion. #### **Supplemental Information** The accompanying information contained in Schedules I, II and Ill has been subjected to audit procedures performed in conjunction with the audit of the Company's 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 l 7a-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. We have served as the Company's auditor since 1992. March 2, 2021 {5}------------------------------------------------ ## Statement of Financial Condition December 31, 2020 | Assets | | |------------------------------------------------------|---------------| | Cash and cash equivalents | \$
508,435 | | Commissions receivable from brokers and dealers, net | 90,229 | | Equipment, net | 51,555 | | Due from parent for income taxes | 168,899 | | Other assets | 131,913 | | Total assets | \$
951,031 | | Liabilities and stockholder's equity | | | Liabilities: | | | Accrued expenses and other liabilities | \$
443,195 | | Total liabilities | 443,195 | | Stockholder's equity: | | | Common stock (\$10 par value), | | | authorized, issued and outstanding 50,000 shares | 500,000 | | Retained earnings | 7,836 | | Total stockholder's equity | 507,836 | | Total liabilities and stockholder's equity | \$
951,031 | | | | {6}------------------------------------------------ ### Statement of Income #### Year Ended December 31, 2020 | Revenues | | |-------------------------------------|-----------------| | Annuity and insurance fee income | \$
2,708,687 | | Mutual fund and securities income | 1,899,005 | | Investment advisor fees | 2,241,809 | | Other income | 16,907 | | | 6,866,408 | | Expenses | | | Salaries, commissions and benefits | 5,179,207 | | Broker charges | 930,305 | | Occupancy | 381,234 | | Equipment | 140,943 | | Legal | 631,122 | | Other operating expenses | 708,613 | | | 7,971,424 | | Income (loss) before income taxes | (1,105,016) | | Provision (credit) for income taxes | (298,193) | | Net income (loss) | \$
(806,823) | | | | {7}------------------------------------------------ #### Statement of Changes in Stockholder's Equity Year Ended December 31, 2020 | | Common
Stock | | Retained
Earnings | | Total | | |------------------------------|-----------------|---------|----------------------|-----------|-------|-----------| | | | | | | | | | Balance at December 31, 2019 | \$ | 500,000 | \$ | 814,659 | \$ | 1,314,659 | | Net income (loss) | | – | | (806,823) | | (806,823) | | Balance at December 31, 2020 | \$ | 500,000 | \$ | 7,836 | \$ | 507,836 | | | | | | | | | {8}------------------------------------------------ ### Statement of Cash Flows #### Year Ended December 31, 2020 | Operating activities | | |------------------------------------------------------------------|-----------------| | Net income (loss) | \$
(806,823) | | Adjustments to reconcile net loss to net cash | | | used by operating activities: | | | Deferred taxes | 42,766 | | Depreciation and amortization | 16,391 | | Decrease in commissions receivable from brokers and dealers, net | 9,946 | | Increase in other assets | (8,091) | | Decrease in due to parent for income taxes | (208,983) | | Decrease in accrued expenses and other liabilities | (152,321) | | Net cash used by operating activities | (1,107,115) | | Investing activities | | | Purchases of equipment | (22,985) | | Decrease in cash and cash equivalents | (1,130,100) | | Cash and cash equivalents at beginning of year | 1,638,535 | | Cash and cash equivalents at end of year | \$
508,435 | | | | {9}------------------------------------------------ # Notes to Financial Statements December 31, 2020 ## 1. Organization Bankoh Investment Services, Inc. (the "Company") is a wholly-owned subsidiary of Bank of Hawaii (the "Bank"). The Bank is a wholly-owned subsidiary of Bank of Hawaii Corporation (the "Parent"). The Company is a broker-dealer in securities registered with the Securities and Exchange Commission ("SEC"). The Company is exempt from Rule 15c3-3 under paragraph (k)(2)(ii) of the Securities Exchange Act of 1934, which provides that all funds and securities belonging to the Company's customers be handled by a correspondent broker-dealer. The Company acts only as an introducing broker-dealer. The Company is a member of the Financial Industry Regulatory Authority and Securities Investor Protection Corporation ("SIPC") and provides access to a broad range of investments through major financial markets, including the New York Stock Exchange, Chicago Board Options Exchange and the NASDAQ market. The Company is also licensed to sell annuity, life insurance and other retirement plan products under a sub-agent agreement with a general agency. Additionally, the Company is a Registered Investment Advisor offering a variety of managed account solutions directed by third-party asset managers. The Company conducts its business primarily in the State of Hawaii. The Company executes its customers' transactions on a fully-disclosed basis through an unaffiliated clearing broker-dealer, National Financial Services, LLC ("NFS"), which maintains the accounts and securities of the Company's customers. ### 2. Summary of Significant Accounting Policies #### Basis of Presentation The accounting and reporting principles of the Company conform with U.S. generally accepted accounting principles ("GAAP") and prevailing practices within the industry. The preparation of financial statements in conformity with GAAP requires management to make estimates and assumptions that affect the reported amounts in the financial statements and accompanying notes. Actual results may differ from those estimates and such differences could be material to the financial statements. ### Cash Equivalents The Company has defined cash equivalents as highly liquid investments with original maturities of less than ninety days. Cash equivalents represent funds held in a money market fund that totaled \$469,249 as of December 31, 2020. These money market funds are held with NFS and are below SIPC insurance limits. {10}------------------------------------------------ #### Revenue Recognition Revenue is largely derived from commissions received from the sale of annuity and life insurance products, mutual funds, and securities. In addition, the Company earns investment advisor fees from the Company's Managed Account Platform Services wealth management product. See Note 9. Revenue Recognition for more information. #### 3. Service Agreement The Company has a service agreement with NFS who provides certain services as the Company's clearing firm. These services include carrying customers' cash and margin accounts on a fully disclosed basis; executing transactions in the customers' accounts as instructed by the Company; preparing transaction confirmations and monthly statements for customers; settling contracts and transactions in securities on behalf of the Company; performing cashiering functions for customer accounts, including receipt and delivery of securities purchased, sold, borrowed and loaned; providing custody and safekeeping of customers' securities and cash; and handling margin accounts, dividends and exchanges, and rights and tender offers. #### 4. Regulatory and Net Capital Requirements The Company is subject to the SEC's Uniform Net Capital Rule (SEC rule 15c3-1), which requires the maintenance of minimum net capital and requires the ratio of aggregate indebtedness to net capital, both as defined, not to exceed 15-to-1. At December 31, 2020, the Company had net capital of \$141,927, which was \$91,927 in excess of its required net capital of \$50,000. The Company's aggregate indebtedness to net capital ratio was 3.123-to-1. The Company had no subordinated debt at December 31, 2020, or at any time during the year then ended. ### 5. Related Party Transactions The Bank, pursuant to an internal expense sharing agreement, allocates certain personnel and operating costs to the Company. These expenses are reimbursed by the Company and recorded in the appropriate expense line item. Allocated expenses in 2020 included: | Salaries, commissions and benefits | \$
732,486 | |------------------------------------|---------------| | Occupancy | 378,085 | | Other operating expenses | 197,964 | At December 31, 2020, amounts due to the Bank included in accrued expenses and other liabilities totaled \$116,257. At December 31, 2020, the Company maintained \$26,586 in cash in non-interest bearing accounts at the Parent. #### 6. Income Taxes The Company is included in the consolidated federal income tax and State of Hawaii franchise tax returns of the Parent. Income taxes are provided based upon the taxable income or loss of the Company. The Parent's tax sharing policy provides for the settlement of income taxes with the {11}------------------------------------------------ Company, as if the Company had filed a separate return. Payments are made to the Parent for current tax liabilities, and if current tax benefits are generated, payments are received from the Parent for the benefits as used. The Company received \$131,977 from the Parent for income tax benefits during 2020. The Company had a federal deferred tax liability of \$11,882 as of December 31, 2020, which is predominantly the result of temporary differences relating to the state tax benefit for 2020 and included in other liabilities. The Company had a state deferred tax asset of \$5,783 as of December 31, 2020, which is predominantly the result of temporary differences relating to accrued vacation and included in other assets. Management believes it is more likely than not that the deferred tax assets will be realized. The components of the provision (credit) for income taxes for the year ended December 31, 2020, are as follows: | Current: | | |-------------------------------------|-----------------| | Federal | \$
(255,759) | | State | (85,200) | | Total Current | (340,959) | | Deferred: | | | Federal | 42,809 | | State | (43) | | Total Deferred | 42,766 | | Provision (credit) for income taxes | \$
(298,193) | The provision (credit) for income taxes is different from that which would be obtained by applying the statutory federal income tax rate of 21% to income before income taxes primarily due to the effect of state taxes. The Parent's federal tax returns for 2017 through 2019 remain subject to examination. The Parent's State of Hawaii income tax returns for 2017 through 2019 remain subject to examination by the taxing authorities. ### 7. Employee Benefits The Company participates in the Parent's Retirement Savings Plan (the "Savings Plan"). The Savings Plan has three Company contribution components in addition to employee contributions: 1) 401(k) matching; 2) a 3% fixed amount based on eligible compensation; and 3) a discretionary value-sharing contribution. Under the 401(k) component, participating employees may contribute up to 50% of their eligible compensation (within federal limits) to the Savings Plan. The Company makes matching contributions on behalf of the participants equal to \$1.25 for each \$1.00 contributed by participants, up to 2% of the participants' eligible compensation, and \$0.50 for every \$1.00 contributed by participants over 2%, up to 5% of the participants' eligible compensation. A 3% fixed contribution and discretionary value-sharing contribution that is linked {12}------------------------------------------------ to the Parent's financial goals, are made regardless of whether the participant contributes to the Savings Plan and are invested in accordance with the participant's selection of investment options available under the Savings Plan. The Company's expense for the Savings Plan totaled \$285,596 in 2020 and was included in salaries, commissions and benefits. In 1995, the Parent froze its non-contributory, qualified defined-benefit retirement plan ("Retirement Plan") and excess retirement plan ("Excess Plan"), which covered employees of the Parent and participating subsidiaries who met certain eligibility requirements. Beginning January 1, 2001, the Retirement Plan and Excess Plan no longer provides for compensation increases in the determination of benefits. The assets of the Retirement Plan primarily consist of equity and fixed income mutual funds. The Parent's postretirement benefit plan provides retirees with medical and dental insurance coverage. The costs of providing postretirement benefits are "shared costs" where both the employer and former employees pay a portion of the premium. The Parent has no segregated assets to provide for postretirement benefits. For the year ended December 31, 2020, the Company's expense for the Retirement Plan, Excess Plan and postretirement benefits was \$42,254 and was included in salaries, commissions and benefits. ## 8. Contingencies During 2020, a few customers filed separate FINRA Arbitration Claims against the Company. The claims allege negligence, breach of fiduciary duty and negligent supervision by the Company in the sale of products offered by Northstar Financial Services Bermuda Ltd. The claims seek damages, punitive damages, attorney's fees, interest, costs and any further relief the arbitration panel deems proper. The Company has filed its responses to the claims. As there are many unresolved issues of fact and law, no liabilities associated with these matters have been recognized. Management disputes any wrongdoing and the cases are being vigorously defended. In addition to the litigation noted above, the Company is occasionally subject to lawsuits, investigations and claims arising out of the conduct of our business. Based on information currently available, management believes the eventual outcome of any claims against the Company will not have a material adverse effect on the Company's statements of income and financial condition. However, in the event of unexpected future developments, it is possible the ultimate resolution of those matters, if unfavorable, may be material to the Company's financial statements. ### 9. Revenue Recognition The Company's significant revenue streams are discussed below. ### Mutual Fund and Securities Income Mutual fund and securities income primarily consists of commissions from sales of mutual funds and other investments. Commissions from the sale of mutual funds and other investments are recognized at a point in time on trade date, which is when the Company satisfies its performance obligation of executing the sale. The Company also receives periodic service fees (i.e., 12b-1 fees) from mutual fund companies typically based on a percentage of net asset value. Trailer revenue is recorded over time, usually monthly or quarterly, as net asset value is determined. {13}------------------------------------------------ #### Annuity and Insurance Fee Income Annuity and insurance income primarily consists of commissions received on annuity product sales, primarily fixed annuities. The Company acts as an intermediary between the Company's customer and the insurance carrier. The Company's performance obligation is generally satisfied upon the issuance of the annuity policy. Shortly after the policy is issued, the carrier remits the commission payment to the Company and the Company recognizes the revenue. The majority of the trailer commission fees relates to variable annuity products and are calculated based on a percentage of market value at period end. Although much of the performance obligation is satisfied upon the sale of the policy, revenue for trailer commission fees remains constrained until the Company can confirm that the annuity is still active at period end and the market value can be determined. Therefore, trailer commission fees are recognized over time as the constraints are resolved. #### Investment Advisor Fees Investment advisor fees from the Company's Managed Account Platform Services (MAPS) wealth management product are earned over time (as the performance obligation is satisfied) and based on an annual percentage rate of the net asset value. The investment advisor fees are charged to the customer's account in advance, on the first month of the quarter, and the revenue is recognized over the following three-month period. #### Contract Balances Receivables arise when the Company has an unconditional right to receive payment under a contract with a customer and are derecognized when the cash is received. Receivables from contracts with customers of \$90,229 as of December 31, 2020, are reported in net commissions receivable from brokers and dealers in the statement of financial condition. #### 10. Subsequent Events On February 23, 2021, the Company received a \$1.0 million capital contribution from the Bank, which was recorded as an increase to net capital. Subsequent events have been evaluated through March 2, 2021, the date the financial statements were issued. No other subsequent events were noted that would have a material impact on the financial statements. {14}------------------------------------------------ Supplemental Information {15}------------------------------------------------ # Schedule I # Bankoh Investment Services, Inc. # Computation of Net Capital Under Rule 15c3-1 # As of December 31, 2020 | Net Capital | | |----------------------------------------------------------------------------|---------------| | Total stockholder's equity qualified for net capital | \$
507,836 | | Deductions and/or charges: | | | Nonallowable assets: | | | Commissions receivable from brokers and dealers | 24,157 | | Due from Parent for Income Taxes | 168,899 | | Deferred taxes | 5,783 | | Equipment | 51,555 | | Other assets | 76,130 | | | 326,524 | | Deduction for excess Fidelity Bond | 30,000 | | Total deductions and charges | 356,524 | | Net capital before haircuts on securities positions: | | | (Tentative net capital) | 151,312 | | Haircuts on money market funds | (9,385) | | Net capital | \$
141,927 | | Aggregate Indebtedness | | | Items included in statement of financial condition: | | | Accrued expenses and other liabilities | \$
443,195 | | Total aggregate indebtedness | \$
443,195 | | Computation of basic net capital requirement | | | Minimum net capital required (6-2/3% of total aggregate indebtedness) | \$
29,546 | | Minimum dollar net capital requirement | \$
50,000 | | Net capital requirement (greater of above two minimum requirement amounts) | \$
50,000 | | Net capital in excess of required minimum | \$
91,927 | | Ratio: Aggregate Indebtedness to Net Capital | 3.123 to 1 | {16}------------------------------------------------ | | Schedule I | |------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------| | Bankoh Investment Services, Inc. | | | Computation of Net Capital Under Rule 15c3-1 (continued) | | | As of December 31, 2020 | | | Reconciliation with Company's computation (included in
Part II of Form X-17A-5 as of December 31, 2020):
Net capital, as reported in Company's Part II
(unaudited) FOCUS Report | \$
162,972 | | Adjustments | (21,045) | | Net capital per above | \$
141,927 | {17}------------------------------------------------ # Schedule II # Bankoh Investment Services, Inc. # Statement Pursuant to SEC Rule 17a-5(d) Computation for Determination of Reserve Requirements ## December 31, 2020 The Company is exempt from the computation of reserve requirements under paragraph (k)(2)(ii) of Rule 15c3-3 of the Securities Exchange Act of 1934. {18}------------------------------------------------ # Schedule III # Bankoh Investment Services, Inc. # Statement Pursuant to SEC Rule 17a-5(d) Information Relating to Possession or Control of Securities # December 31, 2020 The Company is exempt from the possession or control requirements under paragraph (k)(2)(ii) of Rule 15c3-3 of the Securities Exchange Act of 1934. {19}------------------------------------------------ ![](_page_19_Picture_0.jpeg) Ernst & Young LLP 1003 Bishop Street Suite 2600 Honolulu, HI 96813 Tel: + 1 808 531 2037 Fax: + 1 808 548 77 44 ey.com #### **Report of Independent Registered Public Accounting Firm on Applying Agreed-Upon Procedures** To the Board of Directors and Management of Bankoh Investment Services, Inc.: We have performed the procedures enumerated below, which were agreed to by the Board of Directors, management ofBankoh Investment Services, Inc. (the Company), and the Securities Investor Protection Corporation (SIPC), as set forth in the Series 600 Rules of SIPC, solely to assist the specified parties in evaluating the Company's schedule of assessments and payments is in accordance with the applicable instructions of the General Assessment Reconciliation (Form SIPC-7) for the fiscal year ended December 31, 2020. The Company's management is responsible for the Company's compliance with those requirements. The sufficiency of these procedures is solely the responsibility of those parties specified in this report. Consequently, we make no representation regarding the sufficiency of the procedures enumerated below either for the purpose for which this report has been requested or for any other purpose. The procedures we performed and our findings are as follows: 1. Compared the assessment payments made in accordance with the General Assessment Payment Form (Form SIPC-6) and applied to the General Assessment calculation on Form SIPC-7 with respective cash disbursement record entries in the cash disbursements journal. No findings were found as a result of applying the procedure. 2. Compared the amounts reported in the audited financial statements required by SEC Rule l 7a-5 with the amounts reported in Form SIPC-7 for the fiscal year ended December 31, 2020. No findings were found as a result of applying the procedure. 3. Compared any adjustments reported in Form SIPC-7 **with** supporting schedules and working papers supporting the adjustments. No findings were found as a result of applying the procedure. 4. Recalculated the arithmetical accuracy of the calculations reflected in Form SIPC-7 and in the schedules and working papers supporting the adjustments. No findings were found as a result of applying the procedure. 5. Compared the amount of any overpayment applied with the Form SIPC-7 on which it was computed. No findings were found as a result of applying the procedure. 1 {20}------------------------------------------------ ![](_page_20_Picture_0.jpeg) This agreed-upon procedures engagement was conducted in accordance with the interim attestation standards of the Public Company Accounting Oversight Board (United States) and the attestation standards established by the American Institute of Certified Public Accountants. We were not engaged to and did not conduct an examination or a review, the objective of which would be the expression of an opinion or conclusion, respectively, on whether Bankoh Investment Services, Inc. 's schedule of assessments and payments is in accordance with the applicable instructions of the General Assessment Reconciliation (Form SIPC-7) for the fiscal year ended December 31, 2020. Accordingly, we do not express such an opinion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you. This report is intended solely for the information and use of the specified parties listed above and is not intended to be and should. not be used by anyone other than these specified parties. March 2, 2021 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.