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efta-01362642DOJ Data Set 10OtherEFTA01362642
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thanks
From: Katherine Stead
Sent: 19 July 201
To: Aamir Akram
Cc: Clifford Fourie
Subject: Family Office Initiative - Follow Up (II
Max Kleinert
Oliver Bettin
; lain Macara
Classification: For Internal use only
Further to our call this morning, the following thoughts come to mind where we have a FO's being covered exclusively by
KCP employees who are accessing GM systems:
Who will be ACO for these clients (for co-covered clients we have a GM ACO, but this will not be the case for
these clients)
Does this initiative undermine the co-covered model which has been operating up until this point.
How will KCP booked trades be identified?
What S&A checks will be performed by KCP? Where will they be documented? Who in compliance will review?
(markets or KCP)
What will be the ongoing monitoring of trades executed by KCP?
Do the KCP folks need to be subject to certain of the Markets supervisory controls?
Do the KCP folks need to receive the same training (Compliance/Business) as Markets people
More fundamentally, I think the SLA needs to be reviewed and consider re-executing under the new management
structure. Specifically Yanni Pipilis and Stefan Hoops need to be party to the agreement. Furthermore, if Yanni stated to
Todd that KCP need to own the product (as opposed to client) appropriateness, then this is a fundamental change in what
is currently drafted in the SLA.
I have cc'ed lain who runs Mercury for Markets and can comment on the ACO situation
Also cc Cliff who is the BM for our WIS desk who is familiar with the existing status quo and will be the point person for
ICG.
Thanks.
Kind Regards,
Katherine
Katherine Stead
Director
Global Head, ITC BCU
Tel: +44 20 7545 1254
CONFIDENTIAL - PURSUANT TO FED. R. GRIM. P. 6(e)
DB-SDNY-0052140
CONFIDENTIAL
SDNY_GM_00198324
EFTA01362642
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