EFTA01422782.pdf

Subject: FW: Butterfly brokerage [C] [I] From: Coley Jellinghaus Date: Thu, 11 Oct 2018 12:06:35 -0400 To: Stewart Oldfield a> Classification: For internal use only Fyi — pls don't forward From: Kimberly Hart Sent: Thursday, October 11, 2018 11:01 AM To: Zb nek Kozelsk ; Coley Jellinghaus Cc: zia Memon ; Diana Canter < >; Funda Bozkurt Subject: RE: Butterfly brokerage [C] [I] Classification: For internal use only I do not have an issue with KCP servicing the account. I just need to know the controls to ensure that the client is clear re: investments that are not appropriate for Butterfly. In my mind it would be clearer to the client (and better controlled) if someone else serviced that one account — but I defer to the folks who service accounts on a day to day basis. If someone wants to send the proposed controls to BSO and DCO, we will review. fhttps://brandportal.intranet.db.com/img/modules/- DAWM_logo_metallic 46x46.gifl Kimberly Hart Managing Director I Divisional Control Officer Wealth Management Americas Deutsche Bank Trust Company Americas 345 Park Avenue, 14th floor, New York, NY 10154 EFTA01422782 Tel. Fax Mobile Email Securities offered through Deutsche Bank Securities Inc. From: Zbynek Kozelsky Sent: Thursday, October 11, 2018 10:56 AM To: Kimberly Hart ; Coley Jellinghaus Cc: zia Memon ; Diana Canter < ; Funda Bozkurt ; Zbynek Kozelsky Subject: RE: Butterfly brokerage [C] [I] Good morning Kim, Just to offer different perspective — separating of the account may not be only disruptive to the client but also operationally since all the communication, trading is concentrated to KCP (for the balance of the accounts). Thank you fcid:[email protected] Zbynek "Ziggy" Kozelsky Director I Branch Administrative Manager Investment Solutions Group US & Latin America Deutsche Bank Securities Inc. EFTA01422783 Deutsche Bank Wealth Management 345 Park Avenue, 24th Floor New York, NY 10154 Tel. Email: All trade execution information contained herein is being provided as an accommodation at your request in advance of your receipt of the official trade confirmation(s). Additional trade detail information available upon request. The terms of the trade(s) may be subject to change prior to settlement, and therefore the official trade confirmation(s) and account statements issued by Deutsche Bank shall govern. Deutsche Bank is not responsible for any discrepancy between the informal execution report and the official trade confirmation(s) or account statements. This email may contain confidential and/or privileged information. If you are not the intended recipient (or have received this email in error), please notify the sender immediately and delete the email from your computer. Any unauthorized copying, disclosure or distribution of the material in this email is prohibited. From: Kimberly Hart Sent: Thursday, October 11, 2018 10:51 AM To: Coley Jellin haus Cc: zia Memon ; Diana Canter < : Funda Bozkurt ; Zbynek Kozelsky Subject: RE: Butterfly brokerage [C] [I] Classification: For internal use only It could possibly be treated as another exception but KCP would need to submit a proposal that includes the controls that they would put in place. This one is a bit tricky from my perspective since it would probably be better to keep the KCP conversations directed to him as a KCP-eligible investor separate from the conversations with him as the POA for the Butterfly account which is not KCP eligible. However, if this will be very disruptive to the client relationship, I am willing to review a proposal that would detail controls to ensure that there is no confusion around investments that are or not appropriate for Butterfly. EFTA01422784 fhttps://brandportal.intranet.db.com/img/modules/- DAWM_logo_metallic 46x46.gifl Kimberly Hart Managing Director I Divisional Control Officer Wealth Management Americas Deutsche Bank Trust Company Americas 345 Park Avenue, 14th floor, New York, NY 10154 Tel. Fax Mobile Email Securities offered through Deutsche Bank Securities Inc. From: Coley Jellinghaus Sent: Thursday, October 11, 2018 10:35 AM To: Kimberly Hart Cc: zia Memon ; Diana Canter Bozkurt ; Zbynek Kozelsky Subject: RE: Butterfly brokerage [C] [I] Classification: For internal use only Ok that's what I thought. This would not be a 'ring fence' opportunity to pursue. I'll assign the new account to someone on my team. Thanks From: Kimberly Hart Sent: Wednesday, October 10, 2018 :59 PM To: Coley Jellin haus Cc: zia Memon ; Diana Canter < ; Funda Bozkurt ; Zbynek Kozelsky Subject: Re: Butterfly brokerage [C] [I] EFTA01422785 KCP should only be servicing KCP eligible clients - with the exception of a few clients belonging to Josh Shoshan which have been ring-fenced with special controls (including a quarterly attestation). If this account is another exception, someone will need to detail how it will be handled and what special controls will be put in place. Kimberly Hart Managing Director I Divisional Control Officer Wealth Management Americas Deutsche Bank Trust Company Americas 345 Park Avenue, New York, NY 10154 Tel. Fax Mobile Email Securities offered through Deutsche Bank Securities Inc On Oct 10, 2018, at 11:19 AM, Coley Jellinghaus <=MI > wrote: Classification: For internal use only To be clear, I have not asked if we can adopt this account to KCP, I'm forwarding a request from the Banker to have this account covered by KCP as the POA on the account IS a KCP adopted account and is covered by the KCP team. The Banker thinks that for continuity the POA on this account would prefer to have one desk to trade with (KCP). I know that the KCP desk currently covers accounts that are not KCP adopted, hence the request from the Banker to maintain coverage on one desk. If answer is no, I am perfectly fine with it, and will assign ISG coverage to the new account. Thank you EFTA01422786 <image001.gif> Coley Jellinghaus Managing Director I Head of Investment Solutions Group Wealth Management Americas DB Securities Inc. 345 Park Avenue, 10154-0004 New York, NY, USA Tel. Email From: zia Memon Sent: Wednesday, October 10, 2018 :10 AM To: Coley Jellinghaus Cc: Diana Canter ; Kimberly Hart >; Funda Bozkurt <S> Subject: Re: Butterfly brokerage [C] Coley, May be I don't understand the full picture as described to me. As I recall, account in question is a trust for benefit of employees, has value/net worth of less than $5 mil, and the authorized officer will be authorized by a POA to execute syndicate trades. This POA happens to be a KCP client. How can we qualify this account as a KCP client (Non advised, 50 mil-2111 qualification)? EFTA01422787 Would appreciate if you can setup a call between you, me, Kim, Funda and may be Igor/Jeff Roth. Thank you. Kind regards! Zia Memon, Managing Director/BSO. , cell On Oct 9, 2018, at 5:28 PM, Coley Jellinghaus wrote: Classification: Confidential Hello — Just following up on this. The client has completed the new account paperwork and we are getting ready to open the account (for which we need to assign a CA..). Again, the client's accounts are covered by KCP, but this new account, as described below, is not the same set-up as his other accounts and by definition is not a KCP "type" account. Can the KCP continue to cover him for this account or will we need to assign an ISG ca? Thank you From Stew: "This a trust with several of Epstein's employees as beneficiaries, and him EFTA01422788 as grantor. He will have trading authority along with the trustee, but the assets are no longer his since the trust is irrevocable. So Zia felt we could not combine with his other assets to get to the KCP standard. Having said that, it's not clear to me that a client needs to be $50mm net worth to trade cash equities and bonds in KCP. Presumably not all of the IPO business meets that threshold, but you would know better. Either way, need to decide and get an account open as soon as we can at this point." <image001.gif> Coley Jellinghaus Managing Director I Head of Investment Solutions Group Wealth Management Americas DB Securities Inc. 345 Park Avenue, 10154-0004 New York, NY, USA Tel. Email From: zia Memon Sent: Thursday, September 27, 2018 11:39 AM To: Coley Jellinghaus Cc: Diana Canter Subject: RE: Butterfly brokerage Coley, I haven't forgotten this one. I need to discuss further with Kim and others. We just closed a CCT (compliance testing) action item, where they had questioned KCP coverage of clients which didn't meet KCP standards, including Josh's syndicate accounts. Kim is back from London tomorrow, so discussion may occur early next week. EFTA01422789 Everyone needs to re-evaluate the risk of having an account covered by KCP team without KCP qualifying paperwork, 2110/50 million and big -brother letter etc. Also, this will be an irrevocable employee benefit trust, trading cash equities and IPOs, and we have been advised that the trust is valued around $5 million. Thank you. <image002.png> Kind Regards Zia Memon Managing Director I Head, WM-US Business Supervisory Office Deutsche Bank Securities Inc. Wealth Management Americas 345 Park Avenue, 10154-0004 New York, NY, USA Tel. Fax Mobile Email <image003.png> From: Coley Jellinghaus Sent: Tuesday, September 25, 2018 11:13 AM To: zia Memon Cc: Diana Canter Subject: FW: Butterfly brokerage Hi Zia - Ziggy and Stew Oldfield brought me up to speed on this quickly last EFTA01422790 week (Stew recaps the details below) and the client has been waiting to open the account for some time. From my perspective it seems inefficient for the new account being opened to be covered by ISG when all the other account, albeit with distinct beneficial owners, are covered by KCP. My understanding is that not every account that currently trades in KCP is KCP adopted. Can we get comfortable with this new account being covered by the same KCP coverage team? Coley Sent with BlackBerry Work (www.blackberry.com) From: Stewart Oldfield < › Date: Tuesday, Sep 25, 2018, 7:44 AM To: Coley Jellinghaus <a> Cc: Bradley Gillin Subject: RE: Butterfly brokerage Yes. This a trust with several of Epstein's employees as beneficiaries, and him as grantor. He will have trading authority along with the trustee, but the assets are no longer his since the trust is irrevocable. So Zia felt we could not combine with his other assets to get to the KCP standard. Having said that, it's not clear to me that a client needs to be $50mm net worth to trade cash equities and bonds in KCP. Presumably not all of the IPO business meets that threshold, but you would know better. Either way, need to decide and get an account open as soon as we can at this point. Thanks From: Coley Jellinghaus Sent: Tuesday, September 25, 2018 10:41 AM To: Stewart Oldfield > Cc: Bradley Gillin EFTA01422791 Subject: RE: Butterfly brokerage Is this the one we discussed with Ziggy that currently has KCP coverage for some related accounts? Sent with BlackBerry Work (www.blackberry.com) From: Stewart Oldfield Date: Tuesday, Sep 25, 2018, 7:05 AM To: Coley Jellinghaus < => Cc: Bradley Gitlin ‹ > Subject: FW: Butterfly brokerage What's your current thinking on this? Need to get something opened for him. He asked a month ago From: Richard Kahn [mailto: Sent: Tuesday, September 25, 2018 10:04 AM To: Stewart Oldfield ‹ > Subject: Re: Butterfly brokerage any update on when account may be opened? please advise EFTA01422792 thank you Richard Kahn HBRK Associates Inc. 575 Lexington Avenue 4th Floor New York, NY 10022 tel fax cell On Sep 18, 2018, at 3:12 PM, Stewart Oldfield wrote: Who will have trading authority? Thanks <image001.png> Stewart Oldfield, CFA, CAIA Director Deutsche Bank Trust Company Americas Deutsche Bank Wealth Management 345 Park Avenue, New York, NY 10154 Tel. Mobil Email ■ Securities offered through Deutsche Bank Securities Inc. EFTA01422793 This communication may contain confidential and/or privileged information. If you are not the intended recipient (or have received this communication in error) please notify the sender immediately and destroy this communication. Any unauthorized copying, disclosure or distribution of the material in this communication is strictly forbidden. Please refer to https://db.com/disclosures for additional EU corporate and regulatory disclosures. Deutsche Bank does not render legal or tax advice, and the information contained in this communication should not be regarded as such. EFTA01422794