SEC Division of Investment Management staff letter: South State Bank

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Gregory S. Rowland
Davis Polk & Wardwell LLP 212 450 4930 tel
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New York, NY 10017 gregory.rowland@davispolk.com May 8, 2018 Re: South State Bank Mr. Douglas J. Scheidt Associate Director and Chief Counsel Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington , D.C. 20549 Dear Mr. Scheidt:
On behalf of South State Bank ("SSB"), we respectfully request that the staff (the "Staff') of the Division of Investment Management of the Securities and Exchange Commission (the "Commission") confirm that it will not recommend enforcement action to the Commission under Sections 206(1 ), (2) or (4) of the Investment Advisers Act of 1940, as amended (the "Advisers Act") or Rule 206(4)-1(a)(5) thereunder if the Minis Division (as defined below), following the Restructuring (as defined below), uses the performance track record of Minis (as defined below) to the same extent as Minis could have had the Restructuring not occurred. Background South State Advisory, Inc. ("SSA") and Minis & Co., Inc. ("Minis" and, together with SSA, the "Advisers") are two wholly-owned registered investment adviser subsidiaries of SSB, which in turn is a wholly-owned subsidiary of South State Corporation. South State Corporation is a registered bank holding public company incorporated under the laws of South Carolina and trades on NASDAQ under the ticker symbol SSB. At present, the Advisers are operated largely independently of one another. The Advisers are located in different states, serve different types of clients and operate under different brands. SSA operates primarily in South Carolina and its current client base primarily consists of individuals, retirement plans and corporations. SSA first registered as an investment adviser with the Commission in 2010. Minis operates primarily in Georgia and its current client base primarily consists of individuals, charitable organizations and for-profit businesses. Minis's predecessor firm Minis & Company traces its history back to 1932 and the brand is well-known in the Savannah, Georgia area. Each Adviser has its own management team , which reports separately #89881345v15