Text extracted via OCR from the original document. May contain errors from the scanning process.
From:
Armel
---
Brash
)
Sent:
7/19/2016 4:02:48 PM
To:
Stewart 0ldfield
CC:
Anna-Sofiya Lupolover
Subject:
ACTION REQUIRED: STFR Regulation Mailing (Part 2)111
Attachments: SFTR Article 15 Risk Disclosure Statement - Client Outreach_v2 0 (2).pdf; SFTR_Internal_FAQs_Wealth Management
08072016.pdf
Classification: For Internal use only
Stew,
I apologize if you received a similar request last week—it turns out that the data was (shocker) incomplete. The
database (PLN) which holds maintains the data for ISDA clients is owned by another group; that database, unfortunately,
had misclassified the clients listed below as Global Markets clients when in fact, they're Wealth Management clients.
Therefore, if you are receiving this email, you have a client with an active ISDA contract on file and MUST take the action
outlined for the client(s) listed below. Even though these ISDA contracts may be old, they are still considered active
because an ISDA contract never expires until the client terminates with DB in writing.
CP_LEGAL_NAME
ORG_ID
Contact Type
Contact Owner
8032932 Active Client
Stewart Oldfield
8032930 Active Client
Stewart Oldfield
1)
SFTR Regulation - Overview:
The EU Securities Financing Transactions Regulation ("SFTR") requires Deutsche Bank to provide to clients with whom
Deutsche Bank has certain security collateral arrangements a disclosure statement regarding the general risks and
consequences that may be involved in consenting to a right of use of collateral provided under the security collateral
arrangement. Among other things, SFTR requires that certain clients with an open ISDA or repo agreement receive the
disclosure even if that agreement is not currently being utilized. You are receiving this email because one of more of
your clients has such an open ISDA or repo agreement that requires you to deliver the disclosure statement to those
clients.
Please note that clients are not required to take any action in response to the disclosure statement.
2)
Steps for you to follow to comply:
a)
You must deliver the attached SFTR Disclosure Letter by July 27" to those of your clients/counterparties in
scope. You may deliver the Disclosure Letter to you clients by mail or by fax or email if your client has consented to
electronic delivery of documents.
•
Please note that clients are not required to take any action in response to the disclosure statement.
b)
Attach proof of delivery to the client's record in dbForce (Email, Fax, or letter sent to the client).
•
Please include a copy of the Letter AND the Envelope/FedEx Label in one attachment
c)
Notify me once a) and b) have been completed.
3)
Response/questions from clients:
The SFTR Disclosure Letter clearly states that no response is required from the clients. However, any questions
regarding this matter should be managed by the Relationship Manager, with the involvement of legal or compliance as
needed.
An Internal Use Only Q&A is also attached (do not send the Q&A to the client).
If you need any assistance or have any questions, please reach out to me or Anna-Sofiya.
CONFIDENTIAL - PURSUANT TO FED. R. GRIM. P. 6(e)
DB-SDNY-0079971
CONFIDENTIAL
SDNY_GM_00226155
EFTA01381182