# IBN FINANCIAL SERVICES, INC. X-17A-5 (2021-02-26) — Broker-dealer annual report - Company: IBN FINANCIAL SERVICES, INC. - Form: X-17A-5 - Filed: 2021-02-26 - Period: 2020-12-31 - Accession: 0001028562-21-000002 - CIK: 1028562 - File #: 8-49815 - Material weakness: No - Auditor: Evans & Bennett, LLP - Auditor location: Syracuse, NY - Contact: Richard Carlesco - Phone: 3156524426 - Signed by: Richard Carlesco, Jr. (CEO) Original filing: https://www.sec.gov/Archives/edgar/data/1028562/000102856221000002/newpubfull.pdf --- {0}------------------------------------------------ CERTIFIED PUBLIC ACCOUNTANTS 2112 Erie Blvd. East Suite 100 Syracuse, New York 13224 **(315) 474-3986 FAX# (315) 474.0716** #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Board of Directors IBN Financial Services, Inc. Liverpool, NY 13088 #### Opinion on the Financial Statements We have audited the accompanying statement of financial condition of IBN Financial Services, Inc. (a New York Corporation), as of December 31, 2020, and the related statements of income, changes in stockholder's equity, changes in liabilities subordinated to claims of general creditors, and cash flows for the year then ended, and the related notes and Schedule I through Schedule IV (collectively referred to as the financial statements}. In our opinion, the financial statements present fairly, in all material respects, the financial position of IBN Financial Services, Inc. as of December 31, 2020, and the results of its operations and its cash flows for the year then ended in conformity with accounting principles generally accepted in the United States of America. #### **Basis for Opinion** These financial statements are the responsibility of IBN Financial Services, lnc.'s management. Our responsibility is to express an opinion on IBN Financial Services, Inc. 's financial statements based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to IBN Financial Services, Inc. in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion. #### **Auditors' Report on Supplemental Information** The Supplementary Schedules I through Schedule IV has been subjected to audit procedures performed in conjunction with the audit of IBN Financial Services, lnc.'s financial statement. The supplementary information is the responsibility of IBN Financial Services, lnc.'s management. Our audit procedures included determining whether the supplemental information reconciles to the financial statements or the underlying accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the supplemental information. In forming our opinion on the supplemental information, we evaluated whether the supplemental information, including its form and content, is presented in conformity with 17 C.F.R. §240.17a-5. In our opinion, Supplementary Schedules I through Schedule IV is fairly stated, in all material respects, in relation to the financial statements as a whole. Certified Public Accountants We have served as IBN Financial Services, lnc.'s auditor since 2002. Syracuse, New York February 24, 2021 {1}------------------------------------------------ **LIVERPOOL, NEW YORK** ### **AUDITED STATEMENT OF FINANCIAL CONDITION** **DECEMBER 31, 2020** **PUBLIC DOCUMENT** {2}------------------------------------------------ #### **CONTENTS** | | Pages | |-----------------------------------------------------------|-----------| | ANNUAL AUDITED REPORT FORM X-17A-5 PART Ill (Facing Page) | 1 | | OATH OR AFFIRMATION | 2 | | INDEPENDENT AUDITORS' REPORT | 3 | | FINANCIAL STATEMENTS: | | | Statement of Financial Condition | 4 | | Notes to Financial Statements | 5 -
13 | {3}------------------------------------------------ | | | | UNITED STATES | | | 0MB APPROVAL | |----------------------------------------------------------------------|---------------------|----------------------------------------------------------------------------------------------------------------------------------|------------------------------|---------------------|---------------------------|--------------------------------| | | | SECURITIES AND EXCHANGE COMMISSION | | | | 0MB Number : 3235-0123 | | PUBLIC | | | Washington, D.C. 20549 | | | Expires: October 31, 2023 | | | DOCUMENT | | | | | Estimated average burden | | | | ANNUAL AUDITED REPORT | | | | hours per response 12.00 | | | | | FORM X-17 A-5 | | | | | | | | PART Ill | | | SEC FILE NUMBER | | | | | | | | 8- 49815 | | | | | FACING PAGE | | | | | | | Information Required of Brokers and Dealers Pursuant to Section 17 of the | | | | | | | | Securities Exchange Act of 1934 and Rule l7a-5 Thereunder | | | | | | | | REPORT FOR THE PERIOD BEGINNING 01/01/20 | | AND ENDING 12/31/20 | | | | | | | MM/00/YY | | MM/0D/YY | | | | | | | | | | | | | | A. REGISTRANT IDENTIFICATION | | | | | NAME OF BROKER-DEALER: | | | IBN FINANCIAL SERVICES, INC. | | | Official Use Only | | | | | | | | | | | | | | | | FIRM I.D. NO. | | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.) | | | | | | | | | | | | | | | | 404 OLD LIVERPOOL ROAD
(No. and Street) | | | | | | | | | | | | | | | LIVERPOOL | | NEW YORK | | 13088 | | | | (City) | | (State) | | (Zip Code) | | | | | NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT fN REGARD TO THIS REPORT | | | | | | | | | | | (315) 652-4426 | | | | | RICHARD J. CARLESCO, JR. | | | | (Arca Code - Telephone Number) | | | | | | | | | | | | | B. ACCOUNTANT IDENTIFICATION | | | | | | | INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report* | | | | | | | | EVANS AND BENNETT, LLP | | | | | | | | | | | | | | | (Address) | 2112 ERIE BLVD. E., STE 100 | SYRACUSE
(City) | | NEW YORK 13224
(State) | (Zip Code) | | | | | | | | | | CHECK ONE: | | | | | | | | | | IRl Certified Public Accountant | | | | | | | D Public Accountant | | | | | | | D 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 he covered by the opinion of an independent public accountant | | | | | *must be supported by a statement of facts and circums1ances relied on as the basis/or rhe exemption. See Sec/ion 240. I 7a-5(e)(2)* **SEC 1410 (06-02) 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 valld 0MB control number.** {4}------------------------------------------------ ### **OATH OR AFFIRMATION** **I, RICHARD J, CARLESCO, JR., swear (or affirm) that to the best of my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of IBN FINANCIAL SERVICES, INC., as of DECEMBER 31, 2020, 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:** N/A **BRIAN D SCIPIONE NOTARY PUBLIC STATE OF NEW YORK ONONDAGA COUNTY UC. #01 SC6325228 COMM. EXP. 5" -2 6 • .2--o 2 3** **C. E. O.** **Title** This report•• contains (check all applicable boxes): - **� (a)** Facing page. - � (b) Statement of Financial Condition. - D **(c)** Statement of Income. - 0 (d) Statement of Cash Flows. - 0 **(e)** Statement of Changes in Stockholder's Equity. - D **(f)** Statement of Changes in Liabilities Subordinated to Claims of Creditors. - D **(g)** Computation of Net Capital for Brokers and Dealers pursuant to Rule 15c3-1. - D **(h)** Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3. - D **(i)** Information Relating to the Possession or control Requirements Under Rule 15c3-3. - 0 0) A Reconciliation, including appropriate explanation, of the Computation of Net Capital Under Rule 15c3-1. - D **(k)** A Reconciliation between the audited and unaudited Statements of Financial Condition and Net Capital. - � (I ) An Oath or Affirmation. - D **(m)** A copy of the Securities Investor Protection Corporation Supplemental Report. (Bound Separately) - 0 **(n)** A report describing any material inadequacies found to exist or found to have existed since the date of the previous audit. - D **(o)** Independent auditors' report on internal accounting control. •• *For conditions of confidential treatment of certain portions of this filing,* sea *section 240. 17a-5(e)(3).* {5}------------------------------------------------ # STATEMENT OF FINANCIAL CONDITION # DECEMBER 31, 2020 # ASSETS | Cash and cash equivalents
Receivable from clearing organization and funds
Prepaid expenses
Right of Use Asset
Investment securities -
at fair value | \$
137,996
463,736
25,459
508,560
68,142 | |---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------| | Total assets | \$1,203,893 | | LIABILITIES AND STOCKHOLDERS' EQUITY | | | Liabilities:
Accounts payable and accrued expenses
Payroll Protection Program Liability-debt
Lease Liability
Total liabilities | \$
439,967
109,500
512,176
1,06
1,643 | | Stockholders' equity:
Common stock -
no par -
200 shares authorized,
100 shares issued and outstanding
Additional paid-in capital
Retained earnings (deficit)
Total Stockholders' equity | 30,000
353,035
(240,786)
142,250 | | Total liabilities and stockholders' equity | \$1,203,893 | The accompanying notes are an integral part of these financial statements {6}------------------------------------------------ # NOTES TO FINANCIAL STATEMENTS # DECEMBER 31, 2020 # **Note 1. Organization and Nature of Business** IBN Financial Services, Inc. (the Company) is a regional securities broker-dealer registered with the Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority **(FINRA).** The Company is an introducing broker, engaged principally in the trading and brokerage of investment company shares (mutual funds), equity securities, bonds and other investment products. ## **Note 2. Summary of Significant Accounting Policies** # Use of Estimates The preparation of financial statements in conformity with U.S. generally accepted accounting principles requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates. ### Cash - Concentration of Credit Risk The Company maintains its cash in bank deposit accounts, which, at times, may exceed federally insured limits. The Company has not experienced any losses in such accounts. The Company believes it is not exposed to any significant credit risk on cash and cash equivalents. #### Cash and Cash Equivalents For purposes of the statement of cash flows, the Company considers all money market accounts to be cash equivalents. #### Investments Marketable securities in the Company's investment account are classified as available for sale and are valued at fair value pricing as those terms are described for financial statement purposes. All securities valuations are from quoted market prices (unadjusted) and are considered Level 1 inputs in the fair value hierarchy as established. For tax purposes, any unrealized gain or loss recognized on the investment account is removed from the calculation of taxable income. {7}------------------------------------------------ ### NOTES TO FINANCIAL STATEMENTS # DECEMBER 31, 2020 # **Note 2. Summary of Significant Accounting Policies** (continued) #### Investments (continued) Marketable securities are exposed to various risks such as interest rates, market and credit risks. Due to the level of risk associated with certain investment securities, it is at least reasonably possible that changes in the values of investment securities will occur in the near term and that such changes could materially affect the Company's account balances and the amounts reported on the balance sheet. #### Property, Equipment and Depreciation Property and equipment are recorded at cost. Renewals and betterments of property are accounted for as additions to asset accounts. Repairs and maintenance charges are expensed as incurred. Depreciation is computed using accelerated methods for financial reporting and income tax purposes. Estimated useful lives vary from 5 to 7 years for office equipment. ### Securities Transactions Proprietary securities transactions in regular-way trades are recorded on the trade date, as if they had settled. Profit and loss arising from all securities transactions entered into for the account and risk of the Company are recorded on a trade date basis. Customers' securities transactions are reported on a settlement date basis with related commission income and expenses reported on a trade date basis. #### Commission Income Commission and related clearing expenses are recorded on a trade date basis as securities transactions occur. #### Income Taxes The Company has analyzed filing positions in all of the federal and state jurisdictions where it is required to file income tax returns, as well as all open tax years in these jurisdictions. The Company believes that its income tax filing positions and deductions would be sustained on audit and does not anticipate any adjustments that would result in a material change to its financial position. Therefore, no reserves for uncertain income tax positions have been recorded. In addition, the Company did not record a cumulative effect adjustment related to this adoption. {8}------------------------------------------------ #### NOTES TO FINANCIAL STATEMENTS ### DECEMBER 31, 2020 #### **Note 2. Summary of Significant Accounting Policies** (continued) #### Income Taxes (continued) The Company's policy for recording interest and penalties associated with audits is to record such items as a component of income before taxes. There were no such items during the periods covered in this report. The Company has elected to be treated as a Subchapter "S" Corporation under the Internal Revenue Code and the New York State Corporation Tax Law. Under these elections, the income generally is taxed directly to the stockholders. New York State has a minimum tax on corporations, which resulted in a corporate level tax of \$ 1,000 and is reflected in these financial statements. #### Events Occurring After Reporting Date Management has evaluated subsequent events through the date which the financial statements were issued. #### Recent Accounting Pronouncements In February 20 16 FASS issued Accounting Standards Update 2016-02, Leases (Topic 842). The new standard sets forth a change in accounting to bring operating leases onto the balance sheet by way of a Right of Use Asset and a Lease Liability. The Right of Use Asset will be amortized straight line over the life of the lease, while the lease liability will follow N PV amortization as a loan would. The update was effective January 1, 2019, and was implemented by the Company as of that date. {9}------------------------------------------------ # NOTES TO FINANCIAL STATEMENTS DECEMBER 31, 2020 # **Note 2. Summary of Significant Accounting Policies** (continued) # Revenue Recognition In May 2014, FASB issued ASU 2014-09, Revenue from Contracts with Customers (Topic 606), which supersedes the revenue recognition requirements in Topic 605, Revenue Recognition. Under the new guidance, an entity should recognize revenue to depict the fees and commissions for services rendered to customers in an amount that reflects the consideration to which the entity expects to be entitled in exchange for these services rendered. ASU 2014-09 also requires additional disclosures about the nature, amount, timing, and uncertainty of revenue and cash flows. This ASU was effective as of January 1, 20 18 and was implemented by the Company as of that date. Brokerage and direct business commIssIons. IBN Financial buys and sells securities and variable products on behalf of its customers. Each time a customer enters into a buy or sell transaction, IBN Financial or the underlying variable offering (Annuity, Mutual Fund, REIT, Reg D, etc.) charges a commission. Commissions and related clearing expenses for securities trades are recorded on the trade date (the date that the clearing firm fills the trade order by finding and contracting with a counterparty and confirms the trade with the customer). Commissions for direct business are recorded on the trade date (the date the counter firm receives fully signed purchase instructions and funding is received). IBN Financial believes that the performance obligation is satisfied on the trade date because that is when the underlying financial instrument or purchaser is identified, the pricing is agreed upon and the risks and rewards of ownership Investment advisory fees. IBN Financial provides investment advisory services on a daily basis. I BN believes the performance obligation for providing advisory services is satisfied over time because the customer is receiving and consuming the benefits as they are provided by IBN and/or the third-party advisory service. Fee arrangements are based on a percentage applied to the customer's assets under management. Fees are received monthly or quarterly and are recognized as revenue at that time as they relate specifically to the services provided in that period, which are distinct from the services provided in other periods. Practical expedients. As part of the adoption of the ASU, the Company elected to use the following practical expedients . The Company states its accounts receivable at their transaction price and does not adjust for financing components . Costs incurred to obtain a contract are expensed as incurred when the amortization period is less than a year. {10}------------------------------------------------ # NOTES TO FINANCIAL STATEMENTS # DECEMBER 31, 2020 # **Note 2. Summary of Significant Accounting Policies** (continued) # Forgivable Loan Received Under the Small Business Administration Payroll Protection Program In response to the coronavirus (COVID-1 9) outbreak in 2020, the U.S. Federal Government enacted the Coronavirus Aid , Relief, and Economic Security Act that, among other economic stimulus measures, established the Pay check Protection Program (PPP) to provide small business loans. In April 2020, the Company obtained a PPP loan f or \$ 109,500 which is included in the Company's debt balance at December 31, 2020. The note matures in April 2022 and bears interest at a fixed annual rate of 1 %, with the first ten months of interest deferred. The Company believes it used the proceeds from the note less the repaid amount , for qualifying expenses and thus expects to receive approval of its application for the loan to be f orgiven in the future, at which time the Company will recognize gain on forgiveness of the loan. # **Note 3. Receivables from Clearing Organization and Funds** The Company is engaged in various trading and brokerage activities whose counterparties include a fully disclosed carrying broker and other financial institutions. In the event the counterparties do not fulfill their obligations, the Company may be exposed to r isk. The risk of default depends on the creditworthiness of the counterparty. The Company has not experienced any credit risk related to loss and there has been no bad debt related expense from these transact ions during the reporting period. It is the Company 's policy to review, as necessary , the credit standing of each counterparty . The Company uses the direct write-off method in recognizing bad debt. There was no bad debt expense incurred during the year ended December 31, 2020. {11}------------------------------------------------ ### NOTES TO FINANCIAL STATEMENTS ### DECEMBER 31 , 2020 ### **Note 4. Fair Value Measurement and Investments** #### Fair Value Measurement Generally Accepted Accounting Principles (GMP), 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, the most advantageous market. Valuation techniques that are consistent with the market, income or cost approach are used to measure fair values . The fair value hierarchy prioritizes the inputs to valuation techniques used to measure fair value into three broad levels : *Level 1 Inputs* are quoted prices (unadjusted) in active markets for identical assets or liabilities the Company has the ability to access ; *Level 2 Inputs* are inputs (other than quoted prices included within level 1) that are observable for the asset or liability, either directly or indirectly; *Level 3* are unobservable inputs for the asset or liability and rely on management's own assumptions that market participants would use in pricing the asset or liability. | Investments -
Available for Sale | Level 1 | |--------------------------------------|----------------------| | Fair value of equity securities
: | Inputs
Fair Value | | Equity securities | \$
68,142 | Investments are recorded at fair value. Cost is determined on the first-in, first-out (FIFO) basis when calculating gains and losses. {12}------------------------------------------------ #### NOTES TO FINANCIAL STATEMENTS #### DECEMBER 31, 2020 #### **Note 5. New A ccounting Pronouncement** In June 2016, the FASB issued ASU No. 2016-13, Measurement. of Credit Losses on Financial Instruments related to ASC Topic 326 ("ASC 326"), requiring the immediate recognition of management's estimates of current expected credit losses. ASC 326 is effective for fiscal years beginning after December 1 5, 2019, and has been adopted by the Company for fiscal year ending December 31, 2020. The Company currently has no assets on its balance sheet that require measurement of credit losses. As such, the Company has determined that there is no material impact on the Company's financials resulting from the adoption of ASC 326. #### **Note 6. Property and Equipment - Net** A schedule of property and equipment is as follows : | Office equipment
Accumulated depreciation | \$
39,079
(39,079) | |----------------------------------------------|--------------------------| | Property and equipment -
net | \$ | Depreciation expense was \$ 0 for the year ended December 31, 2020. #### **Note 7. Long-Term Debt** Long-term debt at December 31 consists of the following: | PPP loan payable to KeyBank, bearing interest
at 1 %, due April 2022, unsecured | | 2020 | |------------------------------------------------------------------------------------|----|------------------| | | | 109,500 | | Current maturites | | (82,047) | | Long-term debt | \$ | 27,453 | | Maturities of long-term debt are as follows
: | | | | 202
1
2022 | \$ | 82,057
27,443 | | Total | \$ | 109,500 | Total interest expense was \$0 for the year ended December 31, 2020. {13}------------------------------------------------ # NOTES TO FINANCIAL STATEMENTS # DECEMBER 31, 2020 # **Note 8. Commitments and Contingencies** The Company l eased office space on a month-to-month basis from January 1, 2020 to June 30, 2020. The lease required monthly payments of \$3,780. Ownership of the building transferred and the Company signed a new ten year lease with two IBN stockholders for office space on July 1, 2020. The lease requires monthly payments of \$4,000. Rent and Amo rtization of Right of Use Asset expenses were \$3,480 and \$44,809 respectively for the year ended December 31 , 2020. The minimum annual rental commitments over the next five years as as follows : | 2021 | \$
48,600 | |---------------------------|--------------| | 2022 | 50,058 | | 2023 | 51,660 | | 2024 | 53, 107 | | 2025 | 54,700 | | Thereafter | 272,334 | | Total Payments | 530,459 | | Less Discounted Amount | {18,283} | | Actual Lease Liability \$ | 512, 176 | The Company, in its ordinary course of business, has pending arbitration, in which, no ultimate outcome can be determined as of the date of the financial statement. #### **Note 9. Off-Balance-S heet Credit Risk** In the normal course of business, the Company's customer transactions are cleared on a fully disclosed basis with a correspondent clearing broker-dealer. As such, the Company does not handle either customer cash or securities . In the event the customer fails to satisfy its obligations, the Company may be required to purchase or sell financial instruments at prevailing market prices to fulfill the customer's obligations. Settlement of these transactions is not expected to have a significant effect upon the Company's financial position. The Company does not engage in proprietary trading of volatile securities such as short options and futures. {14}------------------------------------------------ # NOTES TO FINANCIAL STATEMENTS # DECEMBER 31, 2020 # **Note 10. Net Capital Requirements** As a registered broker-dealer, IBN Financial Services, Inc. is subject to the requirements of Rule 1 5c3-1 ("The Net Capital Rule") under the Securities and Exchange Act of 1934. The basic concept of the rule is liquidity, its object being to require a broker-dealer to have, at all times, sufficient liquid assets to cover its current indebtedness. Specifically , the rule prohibits a brokerdealer from permitting its "aggregate indebtedness" from exceeding fifteen t imes its "net capital" as those terms are defined and the rule also provides that equity capital may not be w ithdrawn or cash dividends paid if the resulting net capital ratio would exceed 1 O to 1. On December **3**1, 2*0*2*0,* IBN Financial Services , lnc.'s aggregate indebtedness and net capital were \$44**3**,58**3** and \$208,418, respectively, a ratio of 2.1**3** to 1 and net capital exceeded the minimum capital requirement of \$ 29,572 by \$ 178,846. ### N**o***t***e 11. Employee Pension Plan** The Company adopted a SI**M**PLE IRA that is available to all eligible employees. The Company has elected to match contributions up to **3**% for 2*0*2*0* compensation for each participating employee. The Company obligation for contributions to the plan as of December **3**1*,* 202*0* was \$ 1**3**,146, which consisted entirely of the Company's employer matching contribution. ### N**o***t***e 12. Risks and Uncer***t***ain***t***ies** The recent COVID-19 virus outbreak in the United States has resulted in a disruption of the Company's operations. The economic uncertainties associated w ith the spread of COVID-19 has negatively impacted the Company's sources of revenue. The negative impact is somewhat m itigated by the Company's \$109,5*00* loan received under the Paycheck Protection Program (PPP) established under the CARES Act and the Small Business Adm inistration. The total financial impact and duration of the pandemic cannot be reasonably estimated at this time. #### N**o***t***e 13. Rela***t***ed Par***t***y Transac***t***ions** As described in Note 8*,* the Company leases office space from two stockholders. Payments on the lease amounted to \$2*0,000* for the year ended December **3**1, 202*0*. #### N**o***t***e 14. Subsequen***t* **Even***t* The Company subsequent to year end received a notice of determination from the SEC regarding violations noted in their 2*0*2*0* exam. IBN is in the process of providing their written response. The potential f inanc ial impact, if any*,* is unknown at this time. Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.