EFTA02488862

From: Richard Kahn < Sent: Tuesday, September 8, 2015 8:12 PM To: jeffrey E. Subject: Fwd: Southern Country International Ltd Jeanne and I reviewed attached with Alan Dlugash today and he =eels strongly that we should use biz activity code 525990 (other =inancial vehicles) along with Business Activity: Investments Product =r Service: Investments Alan believes that if we were to include language that =ncluded "International Banking" it may unnecessarily trigger an =udit from IRS task force Please advise how to proceed Thank =ou Richard Kahn HBRK Associates Inc. 575 Lexington =venue 4th Floor New York, NY 10022 tel fax cell Begin forwarded message: From: =/b>Richard Kahn <[email protected]> Subject: =/b>Souther Country =nternational Ltd Date: September 2, 2015 at 4:43:58 PM EDT To: =/b>"jeffrey E." <[email protected]> please =dvise on proper code we should report under business activity on form =120 in addition please advise on business activity =nd product or service FTC uses: 523900 (other financial investment =ctivities) EFTA_R1_01609101 EFTA02488862 Bus activity: Financial =ervices Product / Services: Financial =ervices suggestions for =ode: Securities, Commodity =ontracts, and Other Financial Investments and Related Activities 523900 - Other Financial Investment Activities (including =ortfolio management & investment advice) Funds, Trusts, and Other =inancial Vehicles 525990 - Other Financial Vehicles (including mortgage REITs =amp; closed-end investment funds) suggestions for product or =ervice: Bus activity: =nternational Banking Entity Product / Services: =inancial services Bus activity: Financial services Product / Services: Financial services Bus =ctivity: Investments Product / Services: =nvestments Richard Kahn HBRK Associates Inc. 575 Lexington =venue 4th Floor New York, NY 10022 tel =12-971-1306 fax 646-350-0954 cell =17-414-7584 2 EFTA_R1_01609102 EFTA02488863