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efta-efta01384852DOJ Data Set 10Correspondence

EFTA Document EFTA01384852

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From: Paul Barrett Sent: 9/19/2018 8:04:45 PM To: Oavide-A Sferrazza CC: Stewart Oldfield I ; Martin Zeman I Liam Osullivan Subject: Re: DB Initial Margin Segregation [C] Got it. Thanks. Paul Barrett Alpha Group Capital LLC 142 W S7 t' Street 111 Floor New York, NY 10019 (o) (c) On Sep 19, 2018, at 6:26 PM, Davide-A Sferrazza < wrote: Classification: Confidential Paul, I tried reaching out last week regarding the attached notice that you received, but was not able to reach you. Today it struck me that I had not connected with you yet on this topic. I spoke with our Credit and Legal departments about whether this has any effect on Southern Financial's accounts — the short answer is that you can disregard. The long answer is that per the CFTC rules, you have the option to segregate initial margin by having it held in an account with a third part bank/custodian. Since the collateral for Southern Financial sits in an account custodied with Pershing, you are already receiving this treatment. The notice would really only apply if collateral was held directly with DB Global Markets' collateral department, which is not the case for most WM clients. Please feel free to reach out if you have any further questions, and we'll be happy to address. Regards, Davide <image001 gif> Davide Sferrazza Analyst I Key Client Partners Deutsche Bank Securities. Inc. Deutsche Bank Wealth Management 345 Park Avenue. 10154-0004 New York, NY, USA Tel corn CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0085417 CONFIDENTIAL SDNY_GM_00231601 EFTA01384852

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