EFTA01413301.pdf

Deutsche Bank Annual Private Bank AML Monitoring Program Report August 2012 PWM AML Compliance Annual Private Bank AML Monitoring Program Report Objective This document is a comprehensive summary of the current AML Monitoring Program for the Private Bank, in particular, the Prime rules scenarios. The following document describes the current rules scenarios in use, as well as discusses any recent changes made and any recommendations for modification in the future. Prime Compliance Suite Overview Prime is used by the Private Bank Transaction Monitoring Team to effect two kinds of surveillance: Account Profiling Rules Based Monitoring Account Profiling is designed to capture overall activity levels in excess of expectations and/or account history. Monthly profiles (expected activity levels) are created for each account according to the KYC and maintained according to transaction & investigation history. The customer's risk class determines the percentage variance allowed and the minimum thresholds needed before a suspicious activity case is created. Risk Class Chart: Risk Class Variance Percentage Minimum Threshold Amount Minimum Threshold Count 1 (Low) 50% 750,000 12 2 (Low) 40% $ 500,000 10 3 (Moderate/Low) 30% $ 400,000 10 4 (Moderate) 25% EFTA01413301  $ 150,000 5 5 (Moderate/High) 20% 50,000 5 6 (High) 15% 50,000 2 Prime automatically generates cases whenever an account exceeds the transaction dollar amount or volume established in Prime's account profiling tool. Each case relates to a single account for a specific 1-month time period. Each case will be assigned a risk-based score by the Prime system. The score is used to determine which cases will be researched. Cases with scores less than the predetermined limit will not be investigated. To ensure the validity of current thresholds, a sampling of auto-closed cases is reviewed monthly. The AML team reviews a risk-weighted, random sample of cases that fall below the specified scoring range. Rules-Based Monitoring focuses on individual transactions and groups of transactions regardless of the customer's risk level. PB AML utilizes a suite of rules designed to capture high risk activity types and patterns. Transactions considered to present the highest risk of criminal activity are targeted for further investigation. There are 26 individual rules active today. They are grouped into the following rule families: CTR/Cash Dormant High (and Moderate High) risk countries Repetitive Transactions Velocity Hub/SpokeOverview of Current Prime Rules & Parameters Overview of Current Prime Rules Following is a report from Prime listing all of the current rules, a description of what the rule does, the parameters associated with the rule, and schedule frequency: EFTA01413302 Recent Changes In May 2012, countries used in the High Risk and Moderate Risk Country rules were updated as per the PWM High Risk Country Circular. All high risk country alerts (RACS3, RACS3Neg, RACS4, and RACS4Neg) were adjusted accordingly. On July 31, 2012, RACS3 and RACS3Neg alerts were updated to include country code CW Curacao, Netherlands Antilles. The Netherlands Antilles is considered a moderate high risk country. The International Organization of Standardization (ISO) added the code in 2011 (http://- en.wikipedia.org/wiki/ISO_3166-2:CW <http://en.wikipedia.org/wiki/- ISO 3166-2:CW>). New Vendor Offerings Version 10.0 is the last planned release to on-premise users of Prime BSA, EDD, and Legal Reporter. FIS expects to provide support for the current release and one release back. Going forward, FIS will provide only an ASP deployment option for Prime AML. Suggested Modifications Analysis of Rules in Prime CTR INTRODUCTION The Daily CTR Activity rule is designed to detect customers with cash transactions in a single day that exceed $10,000. The objective is to flag situations where a CTR filing may be required. The dollar amount parameter is driven by the Currency Transaction Reporting Requirement of $10,000. RECOMMENDATION No changes recommended. A cash transaction review is done every quarter to review cash reports along with Prime's cash transaction history for potential CTR avoidance or transaction structuring. LARGE CASH DEPOSITS INTRODUCTION The Large Cash Deposits rule specifically targets cash deposits and aggregate cash deposit activity for a specific customer and creates a case when the aggregate amount of cash deposits exceeds $27,000 (10% tolerance with max. total CTR amount of $30,000) over a one month period. Individual transactions must be at least $9,000. This rule is designed to be complementary to the Suspicious Cash Transactions rule because it identifies accounts where there has been a pattern of cash deposit activity throughout a one month period. Only three alerts have been generated since January 1, 2011. ANALYTICAL PROCESS A review of all cash deposits from January 1, 2011 to December 31, 2011 was EFTA01413303 conducted. Over the course of a year, a total of 244 cash deposits received. Only 2 deposits were for amounts greater than $10,000, and 17 of the 244 cash deposits were for amounts between $7,000 and $10,000, It appears that the same customers tend to have recurring cash activity since the larger cash deposits ($7,000 or more) are only linked to 5 customers. RECOMMENDATION Recommend adjusting alert parameters by lowering the individual transaction amount from $9,000 to $7,000 and increasing the maximum aggregate amount from $30,000 to $150,000. As previously noted, a quarterly cash transaction review is conducted every quarter to evaluate Branch cash reports along with Prime's cash transaction history including large cash deposits. DORMANT INTRODUCTION The Dormant Account rule evaluates accounts that been dormant for a predefined number of months and then experience transaction activity. The dollar threshold is set to $500 and the recommended number of months (12) is consistent with what is considered in Global Plus for a dormant account. ANALYTICAL PROCESS Rule Name Additional Details/Parameter Settings Investigation Frequency/Sample Size dDormntAcct Detects accounts that have been dormant for at least 12 months and become active with a transaction of $500 or greater. Runs daily. —Type A (Low Risk) transactions auto-closed —Type B (well-covered) transactions and Type C (Wires) transactions under $10,000 are sampled on a monthly basis at 10% —Type B (well-covered) transactions over $10,000 are sampled on a monthly basis at 25% The underlying transactions of dormant alerts generated from October 1, 2011 to March 31, 2012 were reviewed. The following information was found: During the 6 month period, over a third of the activity captured in dormant alerts was caused by incoming/outgoing wire activity and another third were caused by internal transfers (classified as Transfer To/From, Incoming/- Outgoing Transfer, and Withdrawal/TD Withdrawal). RECOMMENDATION The Dormant account rule cannot restrict specific transaction types (i.e. low risk transactions like internal transfers) to be excluded from the process. So, a weighted methodology for weekly/monthly sampling based on underlying transactions and risk class has been established. No new recommendations. EFTA01413304 RACS INTRODUCTION The Prime High Risk Country rule looks for transactions that originate, pass through, or come to an end in high or moderate risk countries based on the Global PWM High Risk Countries List. AML Compliance currently runs 4 variations of the High Risk Country (RACS) rule. The objective of the suite of RACS rules currently used is to flag transactions meeting the specific parameters set in each variation of the rule, as they pertain to cross- border involvement in moderate-high and high risk countries. The rules evaluate the country code fields associated with the originator, originator bank, beneficiary, beneficiary bank, and up to four (4) intermediary address fields. There are eight (8) available country fields in each transaction record. When a country field is not populated with a valid country code, that country field will not be evaluated by the RACS rule(s). Each country field is evaluated independently; therefore all country fields DO NOT need to be populated in order for the transaction to be evaluated by the rule(s). ANALYTICAL PROCESS Although the RACS rules will evaluate the country codes in every transaction type, this analysis is limited to wire transactions only. The intention of PWM AML Compliance in using the RACS rules is to focus on wire transactions. Additionally, party data (names, addresses, country, etc.) is not expected to be captured electronically for transactions other than wires, and is not available on most non-wire transactions. The analysis included in this document is based on the population of wire transactions with a "bookdate" between November 1, 2011 and March 31, 2012. Total wire transactions for this period: 35,451. Rule Name Additional Details/Parameter Settings RACS3 Must include at least 2 txns of at least $1,000, with a cumulative amount at least $10,000. Runs weekly. RACS3Neg Must include at least 2 txns between $1 and $1,000, with a cumulative amount between $1 and $10,000. Runs weekly. In 10 2012, there were 1,602 wire transactions involving moderate-high risk countries. 1,021 of the 1,602 transactions have contributed to generating (114) RACS3 and (21) RACS3Neg alerts. And so, approximately 69% of all moderate-high risk wires were captured in a RACS alert. The other 580 transactions did not meet RACS3 criteria of at least 2 transactions per customer in one week. RECOMMENDATION For RACS3 Rule, recommend expanding dollar range: lowering minimum transaction amount from $1,000 to $500; and modifying minimum aggregate amount from $10,000 to $7,000. Also, for RACS3Neg rule, recommend increasing maximum transaction amount from $1,000 to $2,000, while maintaining a maximum aggregate transaction amount of $10,000. If these EFTA01413305 changes were accepted, another 3% of moderate-high risk country wires would be reviewed. Rule Name Additional Details/Parameter Settings RACS4 Must include at least ltxn of at least $1,000, cumulative amount at least $10,000. Runs weekly. RACS4Neg Must include at least 1 txn between $1 and $1000, cumulative amount between $1 and $10,000. Runs weekly. In 1Q 2012, there were 2,186 wire transactions involving high risk countries. 1,801 of the 2,186 transactions would have contributed to generating (957) RACS4 and (179) RACS4Neg alerts. And so, approximately 82% of all high risk wires are reviewed. The remaining 385 did not meet RACS4 criteria of transaction amount greater than $10,000 or RACS4Neg criteria of aggregate amount less than $10,000. RECOMMENDATION For RACS4 Rule, recommend broadening transaction amount range to include transactions with a minimum aggregated amount from $10,000 to $7,000. Also, for RACS4Neg rule, recommend increasing maximum transaction amount from $1,000 to $2,000 while maintaining a maximum aggregate transaction amount of $10,000. If these changes were accepted, another 4% of high risk country wires would be reviewed. REPETITIVE INTRODUCTION The Repetitive Transactions rule will allow PWM to flag repetitive transactions of the same type that occur within a predefined timeframe and exceed a predefined dollar value. Repetitive transactions of the same type and/or similar amount may be an indicator of suspicious activity in the sense that the transacting parties may be attempting to mask the magnitude/- nature of the transactions and the financial relationship between the parties by breaking large transactions into smaller components. Repetitive transactions may also be suspicious in the sense that multiple wires to the same party within a short timeframe will incur multiple transaction fees, making them financially less efficient than sending a single large wire. The dollar thresholds for this rule are set at or near the average dollar amount for each transaction type at PWM, and the transaction count thresholds are set to flag situations where the number of average dollar size transactions in one week is unusual because it is more in line with what would be expected in a full month. ANALYTICAL PROCESS Rule Name Additional Details/Parameter Settings RepATMOut 5 ATM transactions exceeding $250. Runs weekly. EFTA01413306 The rule is designed to flag accounts that have 5 or more ATM transactions of at least $250 each within 7 days. The analysis included in this document is based on the population of transactions with a "bookdate" between 3/1/2011and 3/31/2011. Total number of ATM withdrawals for this period: 4,563. In 10 2012, about 11% or 527 of 4,563 ATM withdrawals were captured in an ATM alert. About 169 Private Bank accounts have ATM withdrawals every week. More than 58% (-98) of those accounts have only 1 ATM withdrawal per week. The average PWM account with ATM transactions has 2 ATM transactions per week and the average size of the transaction is $344.80 ($712.16/2). RECOMMENDATION No changes recommended. Current parameters are sufficient. Rule Name Additional Details/Parameter Settings RepOffChks 5 Official Checks exceeding $13,000. Runs weekly. The rule is designed to flag accounts that have 5 or more official check transactions of at least $13,000 each within 7 days. The analysis included in this document is based on the population of transactions with a "bookdate" between 3/1/2011and 3/31/2011. Total number of official checks for this period: 5,055. In 1Q 2012, about 3% or, 132 of 5,055 official checks were captured in a repetitive alert. On average, official checks are issued from about 246 Private Bank accounts every week. About 73% (-180) of those accounts issue only 1 official check per week. About 11% of all official checks in 10 2012 are less than $13,000. The average PWM account with official checks has 2 of these transactions per week and the average size of the transaction is $11,598.05 ($23,196.10/2). RECOMMENDATION Recommend lowering parameters to 3 Official Checks exceeding $8,000. If changes were accepted, another 2% of official checks would be captured in this alert scenario. EFTA01413307 Rule Name Additional Details/Parameter Settings RepPersChks 10 Personal Checks exceeding $5,000. Runs weekly. The rule is designed to flag accounts that have 10 or more personal check transactions of at least $5,000 each within 7 days. The analysis included in this document is based on the population of transactions with a "bookdate" between 3/1/2011and 3/31/2011. Total number of personal checks for this period: 77,843. In 10 2012, about 9% or, 7,078 of 77,843 personal checks were captured in a repetitive alert. On average, personal checks are issued from about 1,047 Private Bank accounts every week. A little more than one third of those accounts (-359) issued only 1 check per week, and over 50% of accounts only issue 1-2 checks per week. The average check amount is $7,149.80. About half of the checks are for amounts less than $500 and more than 80% are less than $5,000. However, accounts with repetitive check activity (issuing more than 2 checks per week) average about 10 checks per week with the average check amount being $6,200. RECOMMENDATION No changes recommended. Current parameters are sufficient. Rule Name Additional Details/Parameter Settings RepPreDebit 5 Pre-authorized debits exceeding $5,000. Runs weekly. The rule is designed to flag accounts that have 5 or more pre-authorized debit transactions of at least $5,000 each within 7 days. The analysis included in this document is based on the population of transactions with a "bookdate" between 3/1/2011and 3/31/2011. Total number of pre-authorized debits for this period: 20,538. In 10 2012, about 1% or, 186 of 20.538 pre-authorized debit transactions were captured in a repetitive alert. On average, pre-authorized debits are issued from about 739 Private Bank accounts every week. More than half of those accounts (-399) of those accounts have only 1 pre-authorized debit per week. The average PWM account with pre-authorized debits has 2 of these transactions per week and the average size of the transaction is $5,964.38 ($12,717.63/2). More than 83% (17,060 of 20,538) of all pre-authorized debits are less than $5,000. EFTA01413308 RECOMMENDATION No changes recommended. Current parameters are sufficient. Rule Name Additional Details/Parameter Settings RepTranIn2 4 Incoming Transfers exceeding $95,000. Runs weekly. The rule is designed to flag accounts that have 4 or more incoming transfers of at least $95,000 each within 7 days. The analysis included in this document is based on the population of transactions with a "bookdate" between 3/1/2011and 3/31/2011. Total number of incoming transfers for this period: 9,671. In 10 2012, about <1% or, 10 of 9,671 incoming transfers were captured in a repetitive alert. On average, incoming transfers are received from about 562 Private Bank accounts every week. More than 80% of those accounts (-461) have only 1 incoming transfer per week. About 16 accounts per week (4%) have 4 or more incoming wires. The average PWM account with incoming transfers has 1 of these transactions per week and the average size of the transaction is $69,873.55 ($95,038.06/1.36). RECOMMENDATION Recommend maintaining minimum count at 4, but lowering minimum amount from $95,000 to $70,000. Rule Name Additional Details/Parameter Settings RepTranOut2 5 Outgoing Transfers exceeding $52,000. Runs weekly. The rule is designed to flag accounts that have 5 or more outgoing transfers of at least $52,000 each within 7 days. The analysis included in this document is based on the population of transactions with a "bookdate" between 3/1/2011and 3/31/2011. Total number of outgoing transfers for this period: 17,086. In 10 2012, about <1% or, 65 of 17,086 outgoing transfers were captured in a repetitive alert. On average, outgoing transfers are sent from about 964 Private Bank accounts every week. About 79% of those accounts (-754) have only 1 outgoing transfer per week. About 26 accounts per week (4%) have 4 or more outgoing transfers and roughly 12 accounts per week (2%) have 5 or more outgoing transfers. EFTA01413309 The average PWM account with outgoing transfers has 1 of these transactions per week and the average size of the transaction is $45,283.18 ($63,617.53/1.40). RECOMMENDATION Recommend decreasing minimum count from 5 to 4 and minimum amount from $52,000 to $40,000. Rule Name Additional Details/Parameter Settings RepWiresln 4 Incoming Wires exceeding $600,000. Runs weekly. The rule is designed to flag accounts that have 4 or more incoming wires of at least $600,000 each within 7 days. The analysis included in this document is based on the population of transactions with a "bookdate" between 3/1/2011and 3/31/2011. Total number of incoming wires for this period: 7,659. In 1Q 2012, about 4% or, 279 of 7,659 incoming wires were captured in a repetitive alert. On average, 327 Private Bank accounts receive incoming wires every week. About 80% of those accounts (-259) of those accounts received only 1 incoming wire per week. About 28 accounts per week (9%) have 3 or more incoming wires and roughly 17 accounts per week (5%) have 4 or more incoming wires. The average PWM account with outgoing transfers has 2 of these transactions per week and the average size of the transaction is $847,133.98 ($1,694,267.97/2). RECOMMENDATION No changes recommended. Current parameters are sufficient. Rule Name Additional Details/Parameter Settings RepWiresOut 3 Outgoing Wires exceeding $300,000. Runs weekly. The rule is designed to flag accounts that have 3 or more outgoing wires of at least $300,000 each within 7 days. The analysis included in this document is based on the population of transactions with a "bookdate" between 3/1/2011and 3/31/2011. Total number of incoming wires for this period: 27,971. In 10 2012, about 3% or, 908 of 27,971 outgoing wires were captured in a EFTA01413310 repetitive alert. On average, 975 Private Bank accounts send outgoing wires every week. About 73% of those accounts (-714) of those accounts sent only 1 outgoing wire per week. About 93 accounts per week (9%) have 3 or more outgoing wires and roughly 50 accounts per week (5%) have 4 or more outgoing transfers. The average PWM account with outgoing wires has 2 of these transactions per week and the average size of the transaction is $416,046.83 ($882,093.67/2). RECOMMENDATION No changes recommended. Current parameters are sufficient. VELOCITY INTRODUCTION The Velocity rule identifies activity that may be indicative of attempts to use bank accounts as "pass-throughs" to facilitate layering of transactions and obscure the trail of funds. This rule will allow AML Compliance to identify situations where funds enter a PWM account and then exit the account within a short timeframe. Since there are various ways (transaction types) that funds may enter and leave PWM accounts, this family of rules will be designed to monitor the most prevalent combinations of transaction types (wires, checks, deposits, free receipts and free deliveries). Since PWM has many types of transactions, the velocity rule is applicable to various combinations of transaction types (e.g. — an incoming wire followed by an outgoing check for the same amount could be considered "velocity"). There are seven (7) types of alerts within this rule. ANALYTICAL PROCESS The analysis included in this document is based on the population of transactions with a "bookdate" between 2/1/2012 and 2/29/2012. Total incoming and outgoing amounts were calculated based on customer each week and then difference of percentage and pattern types was reviewed. Rule Name Additional Details/Parameter Settings VelDepOffCk Deposits followed by official checks within 2%. Runs weekly. VelDepPerCk Deposits followed by Personal Checks within 2%. Runs weekly. VelDepWire Deposits followed by Outgoing Wires within a 5%. Runs weekly. VelFrRecDel Free Receipts followed Free Deliveries within 0%. Runs weekly. VelWireChk Incoming Wires followed by checks within 3%. Runs weekly. VelWireOfCk EFTA01413311 Incoming Wires followed by Official Checks within 3%. Runs weekly. VelWireWir Incoming Wires followed by outgoing wires within 1%. Runs weekly. There were 5,700 distinct customers who had activity in this time period. Only 1% or 61 of those customers had incoming and outgoing activity amounts that differed by 5% of less. However, within that subset of customers, 17 customers did not generate velocity alerts because the percentage difference did not meet the criteria for that particular pattern of activity. Another 8 customers did not generate velocity alerts because the pattern of activity is not currently monitored. An in-depth analysis of transaction patterns by customers found the following: The combination of transaction types that were observed but are not currently monitored is: Free Receipts followed by Outgoing Wires, Incoming Wires followed by Free Deliveries, and Reversals of Free Receipts, Incoming Wires and/or Outgoing Wires. These combinations are not relevant patterns of potentially suspicious movement of funds. RECOMMENDATION Rule Name Parameter Settings Recommendations VelDepOffCk Deposits followed by official checks within 5%. Changed from 2%. VelDepPerCk Deposits followed by Personal Checks within 5%. Changed from 2%. VelDepWire Deposits followed by Outgoing Wires within a 5%. No change. VelFrRecDel Free Receipts followed Free Deliveries within 2%. Changed from 0%. VelWireChk EFTA01413312 Incoming Wires followed by checks within 5%. Changed from 3%. VelWireOfCk Incoming Wires followed by Official Checks within 5%. Changed from 3%. VelWireWir Incoming Wires followed by outgoing wires within 5%. Changed from 1%. HUB SPOKE INTRODUCTION The Hub-Spoke rules are set up to identify multiple ordering parties sending to a single beneficiary and vice versa (a single ordering party sending to multiple beneficiaries). If the specific parameters for transaction type, dollar amount and number of transactions are met, the rule will flag the transactions. There are four versions of the rule, which are designed to run monthly with a look-back period of 30 days. ANALYTICAL PROCESS Rule Name Additional Details/Parameter Settings HubMBenM Must include at least six (6) transactions. Cumulative amount between $100K- $250K HubMBenLow Must include at least five (5) transactions. Cumulative amount between ($5K- $25K) For the Hub-Spoke rules involving multiple beneficiaries, all outgoing wires for the month of February were reviewed. The average number of wires per customer and corresponding amount were calculated. It was determined that out of the 8,889 outgoing wires in February 2012, the average outgoing wires per customer is 4.6 (excluding the omnibus account and those with only 1 wire for the entire month), while the average wire amount per customer is $946,664.58. About 48% of all February wires do not contain beneficiary information because the transactions passed through the omnibus account and/- or were internal transfers. So, taking into account only wires in which the beneficiary field is populated a review of varying dollar ranges yielded the following: The orange highlights current parameters, while the green shows proposed recommendation. RECOMMENDATION EFTA01413313 For the HubMBenM rule, recommend lowering minimum transaction count from 6 to 5 and increasing the maximum aggregate transaction amount from $250,000 to $500,000. For the HubMBenLow rule, recommend lowering minimum transaction count from 5 to 4, while increasing the maximum aggregate transaction amount from $25,000 to $50,000. Rule Name Additional Details/Parameter Settings HubMOrgM Must include at least eight (8) transactions. Cumulative amount between ($100K-$400K) HubMOrgLow Must include at least three (3) transactions. Cumulative amount between ($5K-$25K) For the HubSpoke rules involving multiple originators, all incoming wires for the month of February were reviewed. The average number of wires per customer and corresponding amount were calculated. It was determined that out of the 2,195 incoming wires in February 2012, the average outgoing wires per customer is 4.8 (excluding the omnibus account and those with only 1 wire for the entire month), while the total amount per customer is $4,126,703.08. A review of different dollar ranges yielded the following: The orange highlights current parameters, while the green shows proposed recommendation. RECOMMENDATION For the HubMOrgM rule, recommend lowering minimum transaction count from 8 to 5 and increasing the maximum aggregate transaction amount from $400,000 to $500,000. For the HubMOrgLow rule, recommend maintaining the minimum transaction count of 3 or more wires, while increasing the maximum aggregate transaction amount from $25,000 to $30,000. Future Modifications No future modifications recommended. EFTA01413314 Data Quality No additional analysis conducted on transactional data quality in Prime. PWM US AML Compliance & DB US AML Compliance Approval AML Compliance Management has reviewed the above documentation regarding the PCS AML Monitoring Program. The program is deemed to be sufficient as is and no residual risks are anticipated. OR AML Compliance Management has reviewed the above documentation regarding the PCS AML Monitoring Program. The program is deemed to be sufficient, except for the area of The residual risk is limited to As such, no action items are recommended at that time. OR AML Compliance Management has reviewed the above documentation regarding the PCS AML Monitoring Program. The program is deemed to be sufficient, but I recommend the following action items: A. B. C. Signature — Head of PWM US AML Compliance Date 3Signature — Head of DB US AML Compliance Date http://compliance.intranet.db.com// <http://compliance.intranet.db.com//> 38 http://lrc.intranet.db.com/ <http://lrc.intranet.db.com/> 18 EFTA01413315  Electronic Signatures are acceptable and attached Customer Sum of In Amt Sum of Out Amt % Diff Pattern Type Observed Current parameter (%) Comments 10000212733 1,178,504.05 $ 1,175,381.91 $ 0.2649% Dep-OutWire, IncWire-Chk Dep-Wire 5% Dep-Chk 2% IncWire-OutWire 1% IncWire-Chk 3% Generate alert 10000438559 101,157.20 $ 96,579.09 $ 4.5257% Deposit-Chk 2% Doesn't meet criteria 10000026421 1,799.70 $ 1,844.03 $ EFTA01413316 -2.4632% Deposit-Chk 2% Doesn't meet criteria 10000438240 50,000.00 $ 50,000.00 $ 0.0000% FrRec-OutWire N/A N/A - Trx pattern not monitored 10000228459 13,235.00 $ 13,244.08 $ -0.0686% IncWire-OffChk 3% Generate alert 10000240292 25,000.00 $ 23,983.61 $ 4.0656% IncWire-OutWire 1% Doesn't meet criteria 10000471615 100,000.00 $ 96,952.87 $ 3.0471% IncWire-OutWire 1% Doesn't meet criteria 10000407103 350,000.00 $ EFTA01413317 350,000.00 $ 0.0000% IncWire-OutWire 1% Generate alert 10000415498 866,286.37 $ 866,286.37 $ 0.0000% IncWire-OutWire 1% Generate alert 10000443029 15,000.00 $ 15,000.00 $ 0.0000% IncWire-OutWire 1% Generate alert 40000460282 100,000.00 $ 100,000.00 $ 0.0000% IncWire-OutWire 1% Generate alert 40000460283 100,000.00 $ 100,000.00 $ 0.0000% IncWire-OutWire 1% EFTA01413318 Generate alert 10000461481 2,960,870.50 $ 2,960,871.00 $ 0.0000% IncWire-OutWire 1% Generate alert 10000437652 500,000.00 $ 500,812.50 $ -0.1625% IncWire-OutWire 1% Generate alert 10000417184 65,960.00 $ 68,000.00 $ -3.0928% IncWire-OutWire 1% Doesn't meet criteria 40000290300 200.00 $ 210.00 $ -5.0000% IncWire-OutWire 1% Doesn't meet criteria 10000441022 9,949,915.86 $ 9,846,725.90 $ EFTA01413319 1.0371% Reversal FrRec N/A N/A - Trx pattern not monitored 40000004652 4,871.84 $ 4,871.84 $ 0.0000% Reversal IncWire N/A N/A - Trx pattern not monitored 40000450949 240,000.00 $ 240,000.00 $ 0.0000% Reversal IncWire N/A N/A - Trx pattern not monitored Week 2/6/12-2/10/12 Week customers with inc/out activity # customers with inc/out activity within 5% # of customers with monitored pattern of activity # of customers w/o EFTA01413320 monitored pattern of activity # of customers excluded b/c did not meet % criteria 2/6/12-2/10/12 2014 19 15 4 6 2/13/12-2/17/12 1982 22 21 1 11 2/21/12-2/24/12 1704 20 17 3 6 total 5700 61 53 8 23 average 1,900 20.33 17.67 2.67 7.67 EFTA01413321 Week Total # accounts with out wires accounts with 1 out wire % of accounts with 1 out wire # of accounts with >= 3 out wire % of accounts with >= 3 out wire # of accounts with >= 4 out wire % of accounts with >= 4 out wire Week Vol Amt Vol Amt 1 1282 946 74% 120 9% 52 4% 1 2.018720749 1,068,015.24 $ 4.88690476 EFTA01413322 2,373,170.52 $ 2 745 543 73% 72 10% 42 6% 2 2.609395973 1,198,503.75 $ 6.93564356 3,778,030.25 $ 3 891 658 74% 87 10% 44 5% 3 2.411896745 543,015.59 $ 6.39914163 1,331,247.10 $ 4 1098 844 77% 95 9% 46 4% EFTA01413323 4 2.021857923 551,316.62 $ 5.41732283 1,344,475.38 $ 5 1293 937 72% 119 9% 66 5% 5 2.105181748 659,106.64 $ 5.01404494 1,490,687.15 $ 6 779 581 75% 70 9% 40 5% 6 2.172015404 492,138.62 $ 5.61111111 1,352,728.23 $ 7 857 646 75% EFTA01413324 71 8% 41 5% 7 2.35705951 802,327.39 $ 6.51184834 1,986,868.90 $ 8 697 522 75% 68 10% 40 6% 8 2.490674319 611,056.32 $ 6.93714286 1,384,163.83 $ 9 1340 946 71% 159 12% 78 6% 9 2.207462687 740,067.65 $ 5.10659898 1,993,474.61 EFTA01413325 $ 10 764 559 73% 69 9% 43 6% 10 2.208115183 1,205,894.90 $ 5.50243902 2,488,622.07 $ 11 972 699 72% 82 8% 53 5% 11 2.111111111 1,081,751.63 $ 4.95604396 2,412,721.56 $ 12 812 592 73% 83 10% 45 6% 12 EFTA01413326 2.160098522 980,161.16 $ 5.28181818 2,633,745.34 $ 13 1144 813 71% 118 10% 62 5% 13 2.093531469 883,862.17 $ 4.77945619 1,899,851.11 $ average 974.92308 714.30769 73% 93.30769 10% 50.15385 5% average 2.228240103 832,093.67 $ 5.64150126 2,036,137.39 $ Avg. out wire per account Avg. credit per account (excl. accounts with only 1 out wire & omni a/c) EFTA01413327 Week Total # accounts with out transfers accounts with 1 out trf % of accounts with 1 out trf accounts with 4 or more out trf % of accounts with 4 or more out trf # of accounts with 5or more out trf % of accounts with 5 or more out trf Week Vol Amt Vol Amt 1 2270 1764 78% 24 1.1% 14 0.6% 1 1.300440529 29,368.71 $ 2.34782609 85,957.30 EFTA01413328 $ 2 502 332 66% 58 11.6% 33 6.6% 2 1.958167331 79,500.54 $ 3.82941176 109,317.41 $ 3 345 278 81% 3 0.9% 1 0.3% 3 1.307246377 47,753.63 $ 2.58208955 28,443.01 $ 4 399 316 79% 10 2.5% 5 1.3% 4 1.368421053 129,864.75 $ 2.77108434 115,642.87 EFTA01413329 $ 5 1213 1053 87% 14 1.2% 7 0.6% 5 1.200329761 133,436.32 $ 2.51875 428,342.07 $ 6 2029 1602 79% 20 1.0% 10 0.5% 6 1.260226713 59,320.86 $ 2.23653396 19,464.23 $ 7 481 343 71% 38 7.9% 10 2.1% 7 1.559251559 75,762.75 $ 2.94927536 158,611.24 EFTA01413330 $ 8 296 262 89% 8 2.7% 4 1.4% 8 1.280405405 53,611.55 $ 3.44117647 140,050.23 $ 9 1120 901 80% 17 1.5% 8 0.7% 9 1.280357143 33,744.75 $ 2.43378995 55,213.42 $ 10 2126 1478 70% 81 3.8% 36 1.7% 10 1.524459078 15,627.47 $ 2.72067901 44,138.93 EFTA01413331 $ 11 437 333 76% 48 11.0% 16 3.7% 11 1.604118993 23,355.19 $ 3.53846154 26,419.81 $ 12 327 254 78% 17 5.2% 7 2.1% 12 1.44648318 29,799.79 $ 3 27,631.60 $ 13 991 880 89% 11 1.1% 5 0.5% 13 1.173562059 115,881.64 $ 2.54954955 449,947.06 EFTA01413332 $ avg 964.30769 753.53846 79% 26.84615 4% 12 2% avg 1.404882245 63,617.53 $ 2.83989443 129,936.86 $ Avg. debit per account (excl. accounts with only 1 out trf) Avg. out transfer per account Week Total # accounts with inc transfers # accounts with 1 inc trf % of accounts with 1 inc trf # of accounts with >=4 inc trf % of accounts with >= 4 inc trf Week Vol Amt Vol Amt 1 563 465 EFTA01413333 83% 11 2% 1 1.367673179 117,060.40 $ 3.112244898 274,183.66 $ 2 443 341 77% 16 4% 2 1.410835214 71,684.15 $ 2.784313725 100,717.97 $ 3 349 272 78% 2 1% 3 1.280802292 47,597.73 $ 2.272727273 26,435.83 $ 4 397 313 79% 10 3% 4 1.360201511 132,398.00 EFTA01413334 $ 2.702380952 117,669.43 $ 5 1175 991 84% 16 1% 5 1.235744681 136,964.46 $ 2.505434783 103,173.65 $ 6 376 327 87% 10 3% 6 1.284574468 319,838.19 $ 3.183673469 233,085.37 $ 7 461 318 69% 41 9% 7 1.607375271 79,516.08 $ 2.958041958 150,498.70 $ EFTA01413335 8 280 246 88% 10 4% 8 1.285714286 56,328.63 $ 3.352941176 128,333.74 $ 9 997 872 87% 11 1% 9 1.192577733 37,106.63 $ 2.536 95,772.62 $ 10 532 413 78% 14 3% 10 1.421052632 67,653.74 $ 2.882352941 98,205.58 $ 11 430 328 76% 54 13% EFTA01413336 11 1.620930233 22,008.79 $ 3.617647059 21,225.12 $ 12 318 247 78% 11 3% 12 1.440251572 30,669.03 $ 2.971830986 58,340.61 $ 13 982 871 89% 11 1% 13 1.17413442 116,668.95 $ 2.540540541 320,584.13 $ avg. 561.7692308 461.8461538 81% 16.69231 4% avg. 1.360143653 95,038.06 $ 2.87847152 EFTA01413337 132,940.49 $ Avg. inc transfer per account Avg. credit per account (excl. accounts with only 1 inc trf) Week Total # accounts with preauthorized debits # accounts with 1 debit % of accounts with 1 debit Week avg/trx Vol Amt Vol Amt 1 924 497 54% 1 2.286797 11,485.61 $ 3.784543326 11,252.68 $ 2,973.32 $ 2 819 415 51% 2 1.937729 19,576.67 $ EFTA01413338 2.900990099 29,411.91 $ 10,138.58 $ 3 628 344 55% 3 2.052548 10,844.71 $ 3.327464789 13,640.55 $ 4,099.38 $ 4 618 336 54% 4 2.150485 10,456.21 $ 3.521276596 16,285.79 $ 4,624.97 $ 5 843 471 56% 5 2.161329 12,525.85 $ 3.63172043 20,485.35 $ EFTA01413339 5,640.67 $ 6 768 413 54% 6 2.151042 9,898.29 $ 3.490140845 14,695.58 $ 4,210.60 $ 7 722 401 56% 7 2.114958 12,292.34 $ 3.507788162 23,127.92 $ 6,593.30 $ 8 552 303 55% 8 2.036232 14,626.81 $ 3.297188755 19,037.60 $ 5,773.89 $ EFTA01413340 9 933 561 60% 9 2.037513 11,409.51 $ 3.602150538 19,752.11 $ 5,483.42 $ 10 698 342 49% 10 2.265043 12,393.60 $ 3.480337079 16,449.06 $ 4,726.28 $ 11 831 401 48% 11 2.322503 17,184.59 $ 3.555813953 24,241.40 $ 6,817.40 $ 12 621 EFTA01413341 341 55% 12 2.062802 10,721.52 $ 3.357142857 15,664.77 $ 4,666.10 $ 13 655 364 56% 13 2.140458 11,913.44 $ 3.567010309 19,598.90 $ 5,494.49 $ avg 739.3846154 399.1538462 54% avg 2.132265 12,717.63 $ 3.463351364 18,741.82 $ 5,411.47 $ Avg. debit per account Avg. Debit per account (excl. accounts with only 1 ck) EFTA01413342 Week Total # accounts with inc wires # of accounts with 1 inc wire % of accounts with 1 inc wire # of accounts with 3 or more inc wires % of accounts with 3 or more inc wires # of accounts with 4 or more inc wires % of accounts with 4 or more inc wires Week Vol Amt Vol Amt 1 410 318 78% 38 9% 20 5% 1 2.114634146 EFTA01413343 1,617,557.77 $ 5.9673913 4,295,767.70 $ 2 299 230 77% 25 8% 18 6% 2 1.799331104 2,485,177.38 $ 4.46376812 7,120,455.03 $ 3 284 219 77% 25 9% 13 5% 3 1.535211268 966,758.99 $ 3.33846154 1,486,242.28 $ 4 303 233 77% 30 10% 17 6% 4 1.844884488 EFTA01413344 2,241,985.94 $ 4.65714286 7,272,750.22 $ 5 404 332 82% 36 9% 25 6% 5 1.868811881 1,873,877.75 $ 5.875 7,851,595.75 $ 6 309 249 81% 23 7% 11 4% 6 1.540453074 1,144,236.37 $ 3.78333333 2,463,382.66 $ 7 273 218 80% 29 11% 17 6% 7 1.802197802 EFTA01413345 1,202,646.92 $ 4.98181818 2,964,150.59 $ 8 240 197 82% 21 9% 9 4% 8 1.691666667 1,771,005.15 $ 4.86046512 5,367,940.80 $ 9 409 331 81% 30 7% 20 5% 9 1.696821516 1,473,916.54 $ 4.65384615 5,014,023.57 $ 10 332 260 78% 28 8% 15 5% 10 1.75 EFTA01413346 1,278,757.20 $ 4.49295775 3,717,550.62 $ 11 360 291 81% 27 8% 15 4% 11 1.619444444 1,165,230.60 $ 4.23188406 3,217,469.39 $ 12 256 208 81% 20 8% 14 5% 12 1.94140625 3,069,345.65 $ 6.02083333 10,406,588.27 $ 13 368 275 75% 37 10% 26 7% 13 2.105978261 EFTA01413347 1,734,987.30 $ 5.37634409 4,738,092.27 $ average 326.69231 258.53846 79% 28.38462 9% 16.92308 5% average 1.793141608 1,694,267.97 $ 4.8233266 5,070,462.24 $ Avg. inc wire per account Avg. credit per account (excl. accounts with only 1 inc wire and omni a/c) Month Vol Total Amt Vol Amt Feb-12 8889 2,539,174,840.68 $ 4.662361624 946,664.58 $ WiresOut Avg. Wires Out per cust (excl. omni account and accounts >=2 wires) EFTA01413348 Customer Sum of In Amt Sum of Out Amt % Diff Pattern Type Observed Current parameter (%) Comments 10000408981 3,935,295.15 $ 4,030,266.82 $ -2.413% Dep-Chk, IncWire-OutWire Dep-Chk 2% IncWire-OutWire 1 Generate alert 10000288070 206,622.12 $ 207,786.00 $ -0.563% FrRec-FrDel 0% Doesn't meet criteria 10000438263 103,287.33 $ 103,893.00 $ -0.586% FrRec-FrDel 0% Doesn't meet criteria 10000459067 103,287.33 $ EFTA01413349 103,893.00 $ -0.586% FrRec-FrDel 0% Doesn't meet criteria 10000113121 25,000.00 $ 25,000.00 $ 0.000% IncWire-Chk 3% Generate alert 10000437201 26,940,007.32 $ 26,475,255.34 $ 1.725% IncWire-FrDel N/A N/A - Trx pattern not monitored 10000437202 26,940,007.32 $ 26,475,255.34 $ 1.725% IncWire-FrDel N/A N/A - Trx pattern not monitored 10000247822 19,000.00 $ 18,557.03 $ 2.331% IncWire-OutWire 1% EFTA01413350 Doesn't meet criteria 10000410487 1,300,000.00 $ 1,300,000.00 $ 0.000% IncWire-OutWire 1% Generate alert 10000411349 14,608.00 $ 14,608.00 $ 0.000% IncWire-OutWire 1% Generate alert 10000417834 287,876.87 $ 287,876.87 $ 0.000% IncWire-OutWire 1% Generate alert 10000417835 36,900.78 $ 36,900.78 $ 0.000% IncWire-OutWire 1% Generate alert 10000420458 500,000.00 $ 500,000.00 $ EFTA01413351 0.000% IncWire-OutWire 1% Generate alert 10000432856 500,000.00 $ 500,000.00 $ 0.000% IncWire-OutWire 1% Generate alert 10000453429 169,732.50 $ 169,732.50 $ 0.000% IncWire-OutWire 1% Generate alert 40000440110 9,000.00 $ 9,000.00 $ 0.000% IncWire-OutWire 1% Generate alert 10000453068 17,512,687.00 $ 18,083,462.86 $ -3.259% IncWire-OutWire 1% Doesn't meet criteria 10000453069 11,537,313.00 EFTA01413352 $ 11,913,338.97 $ -3.259% IncWire-OutWire 1% Doesn't meet criteria 10000244120 950,000.00 $ 982,842.61 $ -3.457% IncWire-OutWire 1% Generate alert 10000411610 9,049.90 $ 9,377.54 $ -3.620% Reversal OutWire N/A N/A - Trx pattern not monitored Week 2/21/12-2/24/12 total # customers sum # cust % to total # cust % to total # cust % to total # cust % to total # cust % to total $5K<$25K 17 12% EFTA01413353 6 7% 0 0% 0 0% 0 0% $5K<$30K 19 13% 8 9% 2 3% 2 5% 1 4% $5K<$50K 29 20% 10 12% 3 5% 2 5% 1 4% $50K - $250K 39 27% 22 26% 15 25% 8 20% 5 18% $100K-$250K 27 18% 14 16% 11 19% 5 12% 3 EFTA01413354 11% $100K-$400K 42 29% 23 27% 18 31% 11 27% 5 18% $100K-$500K 47 32% 27 31% 21 36% 13 32% 6 21% $100K-$1MM 54 37% 30 35% 23 39% 15 37% 8 29% Population: 8+ out 28 Population: 3+ out Population: 4+ out Population: 5+ out Population: 6+ out 147 86 59 41 Month Vol EFTA01413355 Total Amt Vol Amt Feb-12 2,195 1,854,293,691.87 $ 4.819079 4,126,703.08 $ WiresIn Avg. Wires In per cust (excl. omni account and accounts >2= wires) total # customers sum # cust % to total # cust % to total # cust % to total # cust % to total $5K<$25K 24 20% 11 16% 5 12% 1 4% $5K<$30K 27 22% 12 17% 6 15% 1 4% $5K<$50K EFTA01413356 37 30% 17 25% 9 22% 4 17% $50K - $250K 26 21% 16 23% 11 27% 4 17% $100K-$250K 14 11% 10 14% 7 17% 2 9% $100K- $400K 21 17% 16 23% 8 20% 3 13% $100K-$500K 24 20% 19 28% 10 24% 5 22% $100K- $1MM 31 25% 24 35% 12 29% EFTA01413357 6 26% 23 Population: 6+ out wires 122 69 41 Population: 3+ out wires Population: 4+ out wires Population: 5+ out wires Week Total # accounts with per chk # accounts with 1 chk % of accounts with 1 chk accounts with 2 chk % of accounts with 1-2 chks Week avg/trx Vol Amt Vol Amt 1 1141 379 33% 189 50% 1 5.429447853 36,740.92 $ EFTA01413358 9.490401396 58,352.13 $ 6,148.54 $ 2 1022 338 33% 190 52% 2 4.623287671 29,234.83 $ 8.111336032 45,174.42 $ 5,569.29 $ 3 1070 359 34% 190 51% 3 5.093457944 44,470.36 $ 9.042226488 79,566.32 $ 8,799.42 $ 4 1102 382 35% 198 53% 4 EFTA01413359 5.494555354 46,488.17 $ 12.34760705 74,264.20 $ 6,014.46 $ 5 1064 385 36% 197 55% 5 5.160714286 41,039.41 $ 9.77593361 62,202.42 $ 6,362.81 $ 6 1103 347 31% 214 51% 6 8.728921124 99,279.85 $ 16.33394834 192,567.77 $ 11,789.42 $ 7 974 339 35% EFTA01413360 162 51% 7 5.998973306 47,113.13 $ 10.97245763 75,611.29 $ 6,891.01 $ 8 971 373 38% 147 54% 8 6.391349125 32,215.24 $ 12.28159645 54,404.31 $ 4,429.74 $ 9 970 351 36% 188 56% 9 5.03814433 39,274.89 $ 9.651972158 66,166.63 $ 6,855.24 $ 10 EFTA01413361 1127 362 32% 213 51% 10 5.536823425 23,848.37 $ 9.876811594 39,675.31 $ 4,017.02 $ 11 1011 362 36% 167 52% 11 6.191889219 34,958.24 $ 11.54356846 62,123.00 $ 5,381.61 $ 12 1068 378 35% 182 52% 12 5.15917603 26,754.91 $ 9.385826772 48,397.85 $ 5,156.48 EFTA01413362 $ 13 993 313 32% 200 52% 13 5.390735146 26,905.98 $ 9.666666667 41,017.02 $ 4,243.14 $ average 1047.384615 359.0769231 0.3433797 187.4615 0.522264 average 5.710574986 40,640.33 $ 10.65233482 69,194.05 $ 6,281.40 $ Avg. Ck per account Avg. Ck per account (excl. accounts with only 1 ck) Combined Week Customer Sum of In Amt Sum of Out Amt % Diff EFTA01413363 Pattern Type Observed Current parameter (%) Comments 2/6/12-2/10/12 10000438559 101,157.20 $ 96,579.09 $ 4.5257% Deposit-Chk 2% Doesn't meet criteria 2/6/12-2/10/12 10000026421 1,799.70 $ 1,844.03 $ -2.4632% Deposit-Chk 2% Doesn't meet criteria 2/13/12-2/17/12 10000422584 115,163.78 $ 113,700.89 $ 1.270% FrRec-FrDel 0% Doesn't meet criteria 2/13/12-2/17/12 10000425735 115,163.78 $ 113,700.89 $ 1.270% FrRec-FrDel 0% EFTA01413364 Doesn't meet criteria 2/13/12-2/17/12 10000425737 115,163.78 $ 113,700.89 $ 1.270% FrRec-FrDel 0% Doesn't meet criteria 2/13/12-2/17/12 10000424966 230,158.91 $ 227,401.78 $ 1.198% FrRec-FrDel 0% Doesn't meet criteria 2/13/12-2/17/12 10000421115 25,841.48 $ 25,703.56 $ 0.534% FrRec-FrDel 0% Doesn't meet criteria 2/13/12-2/17/12 10000417820 4,948,872.89 $ 4,931,974.85 $ 0.341% FrRec-FrDel 0% Doesn't meet criteria 2/13/12-2/17/12 10000417818 EFTA01413365 703,673.34 $ 701,310.84 $ 0.336% FrRec-FrDel 0% Doesn't meet criteria 2/13/12-2/17/12 10000417819 300,233.96 $ 299,225.96 $ 0.336% FrRec-FrDel 0% Doesn't meet criteria 2/21/12-2/24/12 10000288070 206,622.12 $ 207,786.00 $ -0.563% FrRec-FrDel 0% Doesn't meet criteria 2/21/12-2/24/12 10000438263 103,287.33 $ 103,893.00 $ -0.586% FrRec-FrDel 0% Doesn't meet criteria 2/21/12-2/24/12 10000459067 103,287.33 $ EFTA01413366 103,893.00 $ -0.586% FrRec-FrDel 0% Doesn't meet criteria 2/6/12-2/10/12 10000240292 25,000.00 $ 23,983.61 $ 4.0656% IncWire-OutWire 1% Doesn't meet criteria 2/6/12-2/10/12 10000471615 100,000.00 $ 96,952.87 $ 3.0471% IncWire-OutWire 1% Doesn't meet criteria 2/6/12-2/10/12 10000417184 65,960.00 $ 68,000.00 $ -3.0928% IncWire-OutWire 1% Doesn't meet criteria 2/6/12-2/10/12 40000290300 200.00 $ 210.00 $ EFTA01413367 -5.0000% IncWire-OutWire 1% Doesn't meet criteria 2/13/12-2/17/12 10000242765 7,250.00 $ 6,968.45 $ 3.883% IncWire-OutWire 1% Doesn't meet criteria 2/13/12-2/17/12 10000410066 2,750,818.00 $ 2,653,128.00 $ 3.551% IncWire-OutWire 1% Doesn't meet criteria 2/13/12-2/17/12 10000177992 47,955.00 $ 50,000.00 $ -4.264% IncWire-OutWire 1% Doesn't meet criteria 2/21/12-2/24/12 10000247822 19,000.00 $ 18,557.03 $ 2.331% IncWire-OutWire 1% EFTA01413368 Doesn't meet criteria 2/21/12-2/24/12 10000453068 17,512,687.00 $ 18,083,462.86 $ -3.259% IncWire-OutWire 1% Doesn't meet criteria 2/21/12-2/24/12 10000453069 11,537,313.00 $ 11,913,338.97 $ -3.259% IncWire-OutWire 1% Doesn't meet criteria Customer Sum of In Amt Sum of Out Amt % Diff Pattern Type Observed Current parameter (%) Comments 10000211551 19,097.59 $ 18,889.21 $ 1.091% Deposit-Chk 2% Generate alert 10000156095 10,000.00 EFTA01413369 $ 10,154.32 $ -1.543% Deposit-Chk 2% Generate alert 10000011050 19,890.30 $ 20,370.00 $ -2.412% Deposit-Chk 2% Generate alert 10000041009 2,600.00 $ 2,500.00 $ 3.846% Dep-OutWire 5% Generate alert 10000422584 115,163.78 $ 113,700.89 $ 1.270% FrRec-FrDel 0% Doesn't meet criteria 10000425735 115,163.78 $ 113,700.89 $ 1.270% FrRec-FrDel EFTA01413370 0% Doesn't meet criteria 10000425737 115,163.78 $ 113,700.89 $ 1.270% FrRec-FrDel 0% Doesn't meet criteria 10000424966 230,158.91 $ 227,401.78 $ 1.198% FrRec-FrDel 0% Doesn't meet criteria 10000421115 25,841.48 $ 25,703.56 $ 0.534% FrRec-FrDel 0% Doesn't meet criteria 10000417820 4,948,872.89 $ 4,931,974.85 $ 0.341% FrRec-FrDel 0% Doesn't meet criteria 10000417818 703,673.34 $ 701,310.84 EFTA01413371 $ 0.336% FrRec-FrDel 0% Doesn't meet criteria 10000417819 300,233.96 $ 299,225.96 $ 0.336% FrRec-FrDel 0% Doesn't meet criteria 40000021022 3,213,770.51 $ 3,222,672.29 $ -0.277% IncWire/OutWire 1% Generate alert 10000454019 693,795.32 $ 703,335.09 $ -1.375% IncWire-Chk, IncWire-OutWire IncWire-OutWire 1% IncWire-Chk 3% Generate alert 10000397771 1,229,673.04 $ 1,229,675.18 $ 0.000% IncWire-FrDel EFTA01413372 N/A N/A - Trx pattern not monitored 10000242765 7,250.00 $ 6,968.45 $ 3.883% IncWire-OutWire 1% Doesn't meet criteria 10000410066 2,750,818.00 $ 2,653,128.00 $ 3.551% IncWire-OutWire 1% Doesn