EFTA01356670.pdf

MIFID II - Remaining EEA Countries (Excl Germany & UK) — Evidence Document • Finding ID: Evidence # 1: Daily Middle Office Exception Report • Description: Daily automated report distributed to Middle Office to ensure that EEA brokerage accounts are only serviced on a reverse solicitation basis. The report contains 4 worksheets described below: o Sheet 1: The accounts on this worksheet are coded EEA on dbForce, but are not coded EEA on NetX. Must code EEA on NetX o Sheet 2: The accounts on this worksheet are coded EEA on NetX, exist on dbForce, but are not coded EEA on dbForce. Must uncode EEA NetX o Sheet 3: Organized Entity accounts where NetX is not coded "UK NNW Company" and dbForce EEA Country contains UK. Check if CA is outside of CSC and if yes, confirm HNW Company Exemption form is on file. The following CSG CA Numbers are excluded: DOL, GGC, EHM, WAM, L6S, EMP, EIS, MUR, A3B, EEA, AlD. Accounts coded "EEA Exception Approved" on NetX are excluded o Sheet 4: Brokerage accounts where NetX is not coded "UK HNW Company" and dbForce reflects EEA. Check if CA is outside of CSC and if yes, confirm HNW Company Exemption form is on file or Notes reflect EEA exception was approved. The following CSG CA Numbers are excluded: DOL, GGC, EHM, WAM, L6S, EMP, EIS, MUR, A3B, EEA, Accounts coded "EEA Exception Approved" on NetX are excluded • Attachments: o Daily email with Middle Office Exception report MO_Brokerage_Exc eption_Report pAr o Daily Middle Office Exception report CrzWof FeaV3Chargrs org For internal use only CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042649 CONFIDENTIAL SDNY_GM_00188833 EFTA01356670