# UTC FINANCIAL SERVICES USA, INC. X-17A-5 (2019-02-25) — Broker-dealer annual report - Company: UTC FINANCIAL SERVICES USA, INC. - Form: X-17A-5 - Filed: 2019-02-25 - Period: 2018-12-31 - Accession: 0001168037-19-000001 - CIK: 1168037 - File #: 8-65202 - Material weakness: No - Auditor: Accell Audit and Compliance, PA - Auditor location: Tampa, FL - Contact: Rick Alvarez - Phone: 770-263-7300 - Signed by: Gayle Daniel-Worrell (President and Chief Compliance Officer) Original filing: https://www.sec.gov/Archives/edgar/data/1168037/000116803719000001/utcaud.pdf --- {0}------------------------------------------------ UNITEDST ATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 ## **ANNUAL AUDITED REPORT FORM X-17A-5 PART Ill** | | | OMS APPROVAL | | |--------------------------|------------------|---------------------------|--| | OMB Number: | | 3235-0123 | | | Expires: | August 31 , 2020 | | | | Estimated average burden | | | | | | | hours per response 12.00 | | | | | | | | SEC FILE NUMBER | |-----------------| | 8-65202 | | | 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 01/01/18 | | | AND ENDING 12/31/18
---------------------- | | |-----------------------------------------------------------------------------------------|-----------------------------------------------------|------------------------------------|-----------------------------------------------|-------------------| | | MM/DD/YY | | MM/DD/YY | | | | A. REGISTRANT IDENTIFICATION | | | | | NAME o F BROKER-DEALER: UTC Financial Services USA, Inc. | | OFFICIAL USE ONLY | | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not usc P.O. Box No.) | | FIRM 1.0. NO. | | | | 82 Independence Square | | | | | | | (No. and Street) | | | | | Port of Spain_ | | West Indies
Trinidad anq_Jobago | | | | (City) | (State) | | (Zip Code) | | | NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT
Rick Alvarez | | | 770-263-7300 | | | | | | (Area Code | Telephone Number) | | | B. ACCOUNTANT IDENTIFICATION | | | | | INDEPENDENT PUBLIC ACCOUNT ANT whose opinion is conta | | ined in this Report* | | | | Accell Audit and Compliance, PA | | | | | | | (Name if individual. state last. first. middle name | ) | | | | 4806 W. Gandy Blvd. | Tampa | FL | | 33611 | | (Address) | (City) | (State) | | (Zip Code) | | CHECK ONE: | | | | | | llllcertified Public Accountant
B
Public Accountant | | | | | | Accountant not resident in United States or any of its possessions. | | | | | | | FOR OFFICIAL USE ONLY | | | | | | | | | | | | | | | | *\*Claims fur exemption from the requirement that the annual report be covered by the opinion of an independent public accountant must be supported by a statement of facts and circumstances relied on as the basis for the exemption. See Section 240. 1 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 OMB control number. SEC 141 0 (06-02) {1}------------------------------------------------ #### OATH OR AFFIRMATION | ··--
1. Gayl
Oani~I·Worrell | - _______ -
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_ ,swear (or affirm) that, to the best of
__ __ _ _ | | | |-----------------------------------|-----------------------------------|-------------------------------------------------------------------------------------------------------------------------------|--|--| | UTC Financial Services USA, Inc. | ·-
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- | my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the finn of
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--· 20~---· -' arc 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: This report •• contains (check all applicable boxes): EJ (a) facmg Page. - (b) Statement of Financial Condition. - (c) Statement of Income (Loss). - (d) Statement of Changes in r:inancial Condition. (c) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors' Capital. - (I) 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 I 5c3-3. - (i) Information Relating to the Possession or Control Requirements Under Rule I 5c3-3. - 0 d) A Reconciliation, induding appropriate explanation of the Computation of Net Capital Under R uJc 15c3-1 and the Computation for Determination of the Reserve Requirements Under Exhibit A of Rule 15c3-3. - 0 (k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of consolidation. - - ~ (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 of the previous audit. • • *For* com/it *ions of C'Onjidetllinl* treallll<'nl *uf certain 1mrtions of this filing. see* seNio11 *240. 17cJ·5{e)( 3).* {2}------------------------------------------------ Financial Statements and Supplementary Schedules December31 , 2018 (With Report of Independent Registered Public Accounting Firm Thereon) {3}------------------------------------------------ #### Table of Contents | Report of Independent Registered Public Accounting Firm | | |-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------| | Statement of Financial Condition | 2 | | Statement of Operations | 3 | | Statement of Changes in Stockholder's Equity | 4 | | Statement of Cash Flows | 5 | | Notes to Financial Statements | 6-10 | | Schedule I -Computation of Net Capital under Rule
15c3-1 of the Securities and Exchange Commission | 11 | | Schedule II-
Computation for Determination of Reserve
Requirements and Information Relating to Possession or
Control Requirements under Rule 15c3-3 of the
Securities and Exchange Commission | 12 | | Report of Independent Registered Public Accounting Firm
on Management's Assertions Regarding Exemption
Provisions | 13 | | Assertions Regarding Exemption Provisions | 14 | {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Board of Directors and Stockholder of UTC Financial Services USA, Inc. #### Opinion on the Financial Statements We have audited the accompanying statement of financial condition of UTC Financial Services USA, Inc. as of December 31, 2018, the related statements of operations and 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 UTC Financial Services USA, Inc. as of December 31, 2018, and the results of its operations and its cash flows for the year then ended in conformity with accounting principles generally accepted in the United States of America. #### Basis for Opinion These financial statements are the responsibility of UTC Financial Services USA, Inc.'s management. Our responsibility is to express an opinion on UTC Financial Services USA, Inc.'s financial statements based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversiight Board (United States) (PCAOB) and are required to be independent with respect to UTC Financial Services USA, 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 includled evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion. #### Auditor's Report on Supplemental Information Schedule I -Computation of Net Capital Under Rule 15c3-1 and Schedule II -Computation for Determination of Reserve Requirements and Information Relating to Possession or Control Requirements under Rule 15c3-3 have been subjected to audit procedures performed in conjunction with the audit of UTC Financial Services USA, Inc.'s financial statements. The supplemental information is the responsibility of UTC Financial Services USA, Inc.'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, Schedules I and II are fairly stated, in all material respects, in relation to the financial statements as a whole. We have served as UTC Financial Services USA, Inc.'s auditor since 2015. Tampa, Florida February 19, 2019 {5}------------------------------------------------ #### UTC Financial Services USA, Inc. #### (A Wholly-Owned Subsidiary of UTC Fund Services, Inc.) #### (A Wholly-Owned Subsidiary of the Trinidad and Tobago Unit Trust Corporation) #### Statement of Financial Condition #### December 31 , 2018 #### Assets | Cash and cash equivalents | \$
352,266 | |-----------------------------------------------------|---------------| | Accounts receivable-related party | 46,538 | | Accounts receivable-federal income tax | 24,521 | | Deposits | 6,224 | | Prepaid expenses | 3,573 | | Total assets | \$
433,122 | | Liabilities and Stockholder's Equity | | | Accounts payable | \$
4,202 | | Accounts payable-related party | 11,431 | | Total liabilities | 15,633 | | Stockholder's equity: | | | Common stock (\$1 per share par value, 8,000 shares | | | authorized, 1,010 issued and outstanding) | 1,010 | | Additional paid-in capital | 340,092 | | Accumulated profit | 76,387 | | Total stockholder's equity | 417,489 | | Total liabilities and stockholder's equity | \$
433,122 | See accompanying report of independent registered public accounting firm and notes to financial statements {6}------------------------------------------------ #### Statement of Operations #### For the year ended December 31 , 2018 | Revenues : | | |-----------------------------------|---------------| | Fee income | \$
210,825 | | Expenses: | | | Professional Fees | 61 ,347 | | Overhead allocation | 26,923 | | Regulatory fees | 13,567 | | Bank Charges | 1,809 | | Communications | 1,676 | | Travel | 1,303 | | Fee processing charges | 1,200 | | Total expenses | 107,825 | | Net operating income before taxes | 103,000 | | Income tax expense (note 2g) | 22,585 | | Net income | \$
80,415 | See accompanying report of independent registered public accounting firm and notes to financial statements {7}------------------------------------------------ #### Statement of Changes in Stockholder's Equity #### For the year ended December 31 , 2018 | | | Common Stock
Additional | | | | Total | | |-------------------------------|--------|----------------------------|--------------------|-----------------------|----|-------------------------|--| | | Shares | Amount | Paid-in
Capital | Accumulated
Profit | | Stockholder's
Equity | | | Sal ance at January 1 , 2018 | 1,010 | \$1,010 | \$ 340,092 | \$
(4,028) | \$ | 337,074 | | | Net Income | | | | 80,415 | | 80,415 | | | Balance at December 31 , 2018 | 1,010 | \$1,010 | \$ 340,092 | \$
76,387 | \$ | 417,489 | | See accompanying report of independent registered public accounting firm and notes to financial statements {8}------------------------------------------------ #### Statement of Cash Flows #### For the year ended December 31 , 2018 | Cash flows from operating actiVities: | | |---------------------------------------------------|---------------| | Net income | \$
80,415 | | Changes in assets and liabilitites: | | | Accounts receivable-related party | 7,849 | | Accounts receivable-federal income tax | (24,521) | | Deposits | (1 ,433) | | Prepaid expenses | (112) | | Accounts payable | 1,228 | | Accounts payable-related party | 9,346 | | Net cash prm.1ded by operating activities | 72,772 | | Net increase in cash and cash activities | 72,772 | | Cash and cash equivalents, beginning of year: | 279,494 | | Cash and cash equivalents, end of year: | \$
352,266 | | Supplemental disclosures of cash flow infonnation | | | Income taxes paid during the year | \$
47,106 | | | | {9}------------------------------------------------ #### (1) Organization and Nature of Business and Liquidity UTC Financial Services USA, Inc. (the Company) is a Rhode Island corporation that is a wholly- owned subsidiary of UTC Fund Services, Inc., a wholly-owned subsidiary of Trinidad and Tobago Unit Trust Corporation, (the Parent) a foreign corporation located and incorporated in Trinidad. The Company is registered as a broker-dealer with the Securities and Exchange Commission (SEC) and a member of the Financial Industry Regulatory Authority (FINRA). The Company is engaged to conduct a limited security business consisting of the distribution of open- ended investment shares of an affiliated company, UTC North American Fund (the Fund), to customers residing in the United States of America. The Company does not act as a clearing broker or transact any trades on behalf of its customers. #### (2) Significant Accounting Policies #### (a) Basis of Presentation The financial statements and notes are representations of the Company's management who are responsible for their integrity and objectivity. These accounting policies conform to generally accepted accounting principles in the United States of America (GAAP) and have been consistently applied in the preparation offinancial statements. #### (b) Cash and Cash Equivalents The Company classifies highly liquid instruments with original maturities ofthree months or less from the date of purchase as cash equivalents. #### (c) Deposits The Company maintains a cash deposit with FINRA to facilitate FINRA 's payment of certain expenses related to the Company's operations as a broker-dealer. #### (d) Fee Income Fees are recorded when recognizable from the Fund of the distribution of 12b-1 fees pursuant to the Fund distribution plan up to 50 basis points of the Fund's Net Asset Value (NAV). Revenue is recognized when earned, which generally occurs when the Fund's NAV is calculated on a quarterly basis. #### (e) Accounts Receivable Accounts receivable in the accompanying statement of financial condition are due from the Company's only customer (see Note 4 ). {10}------------------------------------------------ #### (2) Significant Accounting Policies- Continued #### (e) Accounts Receivable (continued) The carrying amount of accounts receivable can be reduced by a valuation allowance that reflects management's best estimate of the amount that will not be collected. Management reviews accounts receivable balances that exceed 90 days from invoice date and, based on an assessment of the customer current creditworthiness, estimates the portion, if any, of the balance that will not be collected. Uncollectible accounts receivable are written off in the period in which they are incurred. For the year ended December 31, 2018, \$0 was written off as uncollectible. #### (f) Use of Estimates The preparation of financial statements in conformity with GAAP 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. #### (g) Income Taxes T he Company is treated as a C corporation for federal and state income tax purposes. Income taxes are accounted for under the asset and liability method. Deferred tax assets and liabilities are recognized for the estimated future tax consequences attributable to differences between the financial statement carrying amounts of existing assets and liabilities and their respective tax bases. The Company is required to record deferred tax assets relating to the unrecognized benefit of all temporary differences that will result in future federal and state tax deductions and for all unused federal and state net operating loss and tax credit carryforwards and a deferred tax liability relating to the unrecognized obligations of all temporary differences that will result in a future federal and state tax expense. Deferred tax assets and liabilities are measured using enacted tax rates expected to be applied to taxable income in the years in which those temporary differences are expected to be recovered or settled. The effe.ct on deferred tax assets and liabilities of a change in tax rates is recognized in income in the period that includes the enactment date. {11}------------------------------------------------ #### (2) Significant Accounting Policies- Continued #### (g) Income Taxes- Continued Significant components of the Company's income taxes are as follows: | | 2018 | | |-----------------|--------------|--| | Tax Expense: | | | | Current Federal | \$
22,235 | | | Current State | 350 | | | Total Expense | \$
22,585 | | The provision for income taxes charged to operations for the year ended December 31 , 2018 had a current component of approximately \$22,585. The Company has a federal income tax receivable of approximately \$24,521 due from a refund of income taxes paid for the year ended December 31, 2017. Accounting Standards Codification (ASC) 740, Accounting for Income Taxes, requires management to evaluate tax positions taken by the Company. Management has analyzed the tax positions taken by the Company and has concluded that, as of December 31, 2018, there were no uncertain tax positions taken or expected to be taken that would require recognition of a liability or asset or disclosure in the Company's financial statements. The Company has recognized no interest or penalties related to uncertain tax positions. The Company is subject to rouUne audits by taxing jurisdictions; however, there are currently no audits for any tax periods in progress. {12}------------------------------------------------ #### (3) Concentrations of Credit Risk The Company maintains its cash accounts with a banking institution insured by the Federal Deposit Insurance Corporation. At times, cash deposits may exceed federally insured limits. During 2018, all fee income was generated from one customer (see Note 4). #### (4) Related Party Transactions The Company shares office space, personnel, and other administrative expenses with its Parent. The Company is billed by its Parent for an allocated amount of overhead that is incurred and paid by the Parent. The Parent is responsible for expenses such as salaries, bonuses, payroll taxes, medical insurance, office rent and maintenance, telephone usage, and workman's compensation. The Company is responsible to pay for certain expenses, including electronic communications, certain legal and professional fees, printing and forms, advertising, promotional, consulting fees, licenses and fees, club dues, conferences and meetings, subscriptions and publications and charitable contributions. During 2018, the Company received an allocation of overhead expenses from the Parent. Total allocation of overhead for 2018 was \$26,923 of which \$1 1,431 is recorded in accounts payable- related party at December 3 1, 2018. The Fund, the Company's one customer, is also a related party. The Fund is one of several funds under the management of the Parent. The Parent is the majority owner of this fund. All of the Company's revenue in 2018 was earned from the Fund and amounted to \$210,825, of which \$46,538 was due from the fund as of December 31 , 2018. The Fund that the Company earned its revenue for 2018 was dissolved at the end of 201.8. #### (5) Net Capital Requirements The Company is subject to SEC Uniform Net Capital Rule (SEC Rule 15c3-1), which requires the maintenance of a minimum net capital, as defined, equal to the greater of \$5,000 or 6 2/3% of aggregate indebtedness as well as a percentage of aggregate indebtedness to net capital that shall not exceed 1500%. At December 31 , 2018, the Company had net capital of \$336,633 which was \$331 ,633 in excess of its required net capital of \$5,000. The Company's percentage of aggregate indebtedness to net capital was 4.64%. #### (6) Exemption Under Section (k)(1) The Company is exempt from Rule 15c3-3 pursuant to subparagraphs (k)(1 ). {13}------------------------------------------------ #### (7) Contingent Liabilities The Company was involved in a regulatory examination arising in the ordinary course of business. The resolution of regulatory requirements did not have a material adverse effect on the financial position or results of operations of the Company. #### (8) New Accounting Pronouncements The Company has adopted Accounting Standards Updates ("ASU") 2014-09, Revenue from Contracts with Customer" ("Topic 606") as of January 1, 2018. Management has evaluated the impact of the Company's adoption of ASU 2014-09 on its financial statements and determined that there was no significant impact to its financial position, results of operations and related disclosures. To make this determination, management has identified the contract with its customer, identified the performance obligations, determined the transaction price, allocated the transaction price to the performance obligations in the contract, and recognized revenue when the Company satisfies the performance obligation. The Company's main revenue stream is receiving 12b-1 fees pursuant to a Fund distribution plan. The Company receives up to 50 basis points of the Fund's Net Asset Value (NAV) which is calculated on a quarterly basis. Management believes that since the 12b-1 fees payable to the Company has a variable consideration (NAV calculation) the 12b-1 fee is recognized when calculated at a certain point in time. At this point in time, the revenue has no probability of being reversed and is when it should be recognized. There are no costs directly related to the contract. #### (9) Subsequent Events In accordance with ASC 855, Subsequent Events, the Company has evaluated events and transactions through the date the financial statements were available to be issued. {14}------------------------------------------------ ### UTC Financial Sel".ices USA, Inc. (A Wholly-Owned Subsidiary of UTC Fund Sei"Aces, Inc.) (A Wholly-Owned Subsidiary of the Trinidad and Tobago Unit Trust Corporation) #### Schedule I Computation of Net Capital under Rule 15c3-1 of the Securities and Exchange Commission #### December 31 , 2018 | Net Capital: | | |-----------------------------------------------------------------|---------------| | Total stockholder's equity | \$
417,489 | | Deductions: | | | Non-allowable assets: | | | Accounts receivable-related party | 46,538 | | Accounts receivable-federal income tax | 24,521 | | Deposits | 6,224 | | Prepaid expenses | 3,573 | | Total deductions | 80,856 | | Net capital | 336,633 | | Minimum net capital required | 5,000 | | (greater of \$5,000 or 6 2/3% of total ag-gregate indebtedness) | | | Excess net capital | \$
331,633 | | Aggregate indebtedness | \$
15,633 | | Percentage of aggregate indebtedness to net capital | 4.64% | Reconcilitation with Company's computation of net capital included in Part IIA of Form X-17A-5 as of December 31 , 2018 There is no significant difference between net capital reported in Part IIA of Form X-17A-5 as of December 31 , 2018 and net capital as reported abo-.e. See accompanying report of independent registered public accounting firm. {15}------------------------------------------------ #### Schedule II Computation for Determination of Reser~.e Requirements and Information Relating to Possesion or Control Requirements under Rule 15c3-3 of the Securities and Exchange Commission The Company is not required to file the above schedue as it claims exemption from Rule 15c3-3 under Paragraph (k)(1) of the Rule. {16}------------------------------------------------ ![](_page_16_Picture_0.jpeg) #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Board of Directors and Stockholder of UTC Financial Services USA, Inc. We have reviewed management's statements, included in the accompanying Exemption Report for SEC Rule 15c3-3, in which (1 ) UTC Financial Services USA, Inc. (the "Company") identified the following provisions of 17 C.F.R. §15c3-3(k) under which the Company claimed an exemption from 17 C.F.R. §240.15c3-3(k)(1) (the "exemption provision") and (2) the Company stated that UTC Financial Services USA, Inc. met the identified exemption provision throughout the most recent fiscal year without exception. The Company's management is responsible for compliance with the exemption provisions and its statements. Our review was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, include,d inquiries and other required procedures to obtain evidence about the Company's compliance with the exemption provisions. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, we do not express such an opinion. Based on our review, we are not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based on the provisions set forth in paragraph (k)(1) of Rule 15c3-3 under the Securities Exchange Act of 1934. Tampa, Florida February 19, 2019 {17}------------------------------------------------ ![](_page_17_Picture_0.jpeg) UTC FINANCIAL SERVICES (USA), INC. #### Assertions Regarding Exemption Provisions We, as members of management of UTC Financial Services USA. Inc- ("the Company"), are responsible for compliance with the annual reporting requirements under Rule 15c3-3 of the Securities Exchange Act of 1934. Those requirements compel a broker or dealer to file annual reports with the Securities Exchange Commission (SEC) and the broker dealer's designated Examining authority (DEA). One of the reports to be included in the annual filing is an exemption report prepared by an independent public accountant based upon a review of assertions provided by-the broker or dealer. Pursuant to that requirement the management of the Company hereby makes the following assertions: #### Identified Exemption Provision: The Company claimed exemption from the reserves and custody provisions of Rule 15c3- 3 by operating under the exemption provided by Rule 15c3-3, Paragraph (k)(1) for the entire year of 2018. ## Statement Regarding Meeting Exemption Provision: The Company met the identified exemption provision without exception throughout the year ended December 31,2018. UTC Financial Services USA, INC By: ~~-:~~~01 Date: 02/19/2019 {18}------------------------------------------------ ![](_page_18_Picture_0.jpeg) #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM ON APPLYING AGREED-UPON PROCEDURES RELATED TO AN ENTITY'S CLAIM FOR EXCLUSION FROM MEMBERSHIP IN SIPC To the Board of Directors and Stockholder of UTC Financial Services USA, Inc. We have performed the procedures included in Rule 17a-5(e)(4) under the Securities Exchange Act of 1934 and the Securities Investor Protection Corporation (SIPC) Series 600 Rules, which are enumerated below and were agreed to by UTC Financial Services USA, Inc. (the "Company") and the SIPC, solely to assist you and SIPC in evaluating the Company's compliance with the exclusion requirements from membership in SIPC under section 78ccc(a)(2)(A) of the Securities Investor Protection Act of 1970 for the year ended December 31 , 2018, as noted on the accompanying Certification of Exclusion From Membership (Form SIPC-3). The Company's management is responsible for its Form SIPC-3 and for its compliance with those requirements. This agreed-upon procedures engagement was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and in accordance with attestation standards established by the American Institute of Certified Public Accountants. 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 described 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 Total amount included in the accompanying Schedule of Form SIPC-3 Revenues prepared by the Company for the year ended December 31 , 2018 to the total revenues in the Company's audited financial statements included on Annual Audited Report Form X-17A-5 Part Ill for the year ended December 31 , 2018, noting no differences; - 2) Compared the amount in each revenue classification reported in the Schedule of Form SIPC-3 ReveniUes prepared by the Company for the year ended December 31 , 2018 to supporting schedules and working papers, noting no differences; - 3) Recalculated the arithmetical accuracy of the Total Revenues amount reflected in the Schedule of Form SIPC-3 Revenues prepared by the Company for the year ended December 31, 2018 and in the related supporting schedules and working papers, noting no differences. We were not engaged to and did not conduct an examination or review, the objective of wihich would be the expression of an opinion or conclusion, respectively, on the Company's compliance with the exclusion requirements from membership in SIPC for the year ended December 31 , 2018. Accordingly, we do not express such an opinion or conclusion. 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 Company and the SIPC and is not intended to be and should not be used by anyone other than these specified parties. Tampa, Florida February 19, 2019 {19}------------------------------------------------ UTC Fina ncial Services USA, Inc. | Amount(\$) | Business activities through which revenue was earned | |---------------|--------------------------------------------------------------------------------------------------------------------------| | \$0 | Business conducted outside the United States and its
territories and possessions | | 10,825
\$2 | Distribution of shares of registered open end investment
companies or unit investment trusts | | \$0 | Sale of variable annuities | | \$0 | Insurance commissions and fees | | \$0 | Investment advisory services to one of more registered
investment companies or insurance company separate
accounts | | \$0 | Transactions in securities futures products | | \$210,825 | Total Revenues | ## Schedule of Form SIPC-3 Revenues for the year ended December 31, 2018 {20}------------------------------------------------ *Securities Investor Protection Corporation* 1667 K Street NW, Ste I 000 Washington, DC 20006-1620 #### Forwardiing and Address Correction Requested S- Ob5~d- ~t.JR~ ~G I lc?-ttf rOOJvm:., Ft~~ S6R~Ict~ ( \..-1 ~~) Itr-JC . vto ~'"-~'~ "l 1"0&frCrt) 1.-f•.,wr ~~-r c.{)R.POI2J\-'n ON '-"TV PI,.JANC-\'n..,. GeNTf. | entities, is conducted outside the United States and its territories and possessions;•
(ii) its business as a broker-dealer is expected to consist exclusively of:
(I) the distribution of shares of registered open end investment companies or w>it investmefll trusts;
(II) the sale of variable aMuities;
(II!) the business of insurance;
(IV) the business of rendering investment advisory services to one or more rcgis1ered investmer~ | |----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | | | | | | | | | companies or irr;urarx;e cornpseparate accounts; | | A) as a broker-dealer with respect to transactions in
78o(bX
securities tinwes products; | | terms | | | | | | | *Securities Investor Protection Corporation* 1667 K Street NW, Ste 1000 Washington, DC 20006-1620 # **Form SIPC-3** # **FY 201** 9 ## *Certification of Exclusion From Membership.* TO BE FILED BY A BROKER-DEALER WHO CLAIMS EXCLUSION FROM MEMBERSHIP IN THE SECURITIES INVESTOR PROTECTION CORPORA TJON ("SIPC") UNDER SECTION 78ccc(a)(2)(A) OF THE SECURITIES INVESTOR PROTECTION ACT OF 1970 ("SIP A"). The above broker-dealer certifies that during the fiscal year ending ·;t;x,:;q;:""i.g.E.Q ~~ ~l'l its business as a broker-dealer is expected to consist exclusively of one or more of the following (check appropriate boxes): 0 (i) its principal business, in the detennination of SIPC, taking into account business of affiliated entities, is conducted outside the United States and its territories and possessions;\* (ii) its business as a broker-dealer is expected to consist exclusively of: - (I) the distribution of shares of registered open end investment companies or unit investment trusts; - (II) the sale of variable annuities; - (III) the business of insurance; - (IV) the business of rendering investment advisory services to one or more registered investment companies or insurance company separate accounts; - 0 (iii) it is registered pursuant to I *5* U.S.C. 78o(b){l I ){A) as a broker-dealer with respect to transactions in securities futures products; and that, therefore, under section 78ccc(a)(2)(A) of SIP A it is excluded from membership in SIPC. \*If you have any questions concerning the foreign exclusion provision please contact SIPC via telephone at 202-3 71-8300 or e-mail at asksipc@sipc.org to request a foreign exclusion questionnaire. The following bylaw was adopted by the Board of Directors: Interest on Assessments . ... If any broker or dealer has incorrectly filed a claim for exclusion from membership in the Corporation, such broker or dealer shall pay, in addition to all assessments due, interest at the rate of 20% per annwn of the unpaid assessment for each day it has not been paid since the date on which it should have been paid. In the event of any subsequent change in the business of the undersigned broker-dealer that would tenninate such broker-dealer's exclusion from membership in SIPC pursuant to section 78ccc(a)(2)(A) of the SIP A, the undersigned broker-dealer will immediately give SIPC written notice thereof and make payment of all assessments thereafter required under section 78ddd( c) of the SIP A. Sign, date and return this form no later than 30 days after the beginning of the fiscal year, using the enclosed return envelope. Retain a copy of this form for a period of not less than 6 years, the latest 2 years in an easily accessible place. Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.