EFTA Document EFTA01356551

From: Sylvia Escobar Sent: 4/11/2019 5:05:01 PM To: Kimberly Hart CC: Julie Cataudella ; Karen Cohen Subject: SII Closure: MIFID II - Remaining EEA Countries (Excl Germany r UK FM 17/2019 #43 (dbTrack2407699) Attachments: Finding Owner Closure Pack Template 04.12.2019.docx; EEA Remaining CLients_SII_Evidence_Document.docx Hi Kim, As requested, please see attached/below the following documents to support closure of the 511 mentioned above: 1. Closure template a. Outstanding: add new SD ID for EEA Designated Bankers Team b. File name: Finding Owner Closure Pack Template 04.12.2019 2. New MI for EEA Designated Bankers Team a. Drafted and reviewed with Karen. Please see proposed language below in blue. b. I don't have access to raise a new 511 in GFMS. Julie and I will raise the new SII tomorrow. Tittle: EEA Designated Bankers Team - Implementation As a resu€t of the changes in the regulatory framework in the European Economic Area (EEA) and the significant number of important relationships across many customer owners a decision was made to reduce the number of customer owners per Sub-GMTs to service existing and new EEA clients. EEA relationships/accounts must always be the result of Reverse Solicitation (client exclusively initiates the business rather than the other way around) as client facing staff is prohibited from actively solicit or offer any products or services to EEA clients. This SII is to track the implementation of the EEA Designated Bankers Team to service existing and new EEA clients. Implementation will include: 1. Mgmt to identify EEA designated bankers 2. Sub-GMTs to complete relationship/account transfers 3. Implementation of control framework Due date: Dec 31, 2019 Rating: Important 3. Evidence document: outlines evidence to support closure of the SII a. Julie and I are still working on the evidence but will be ready for tomorrow's meeting with Patrick C at 4:30pm. b. File name: EEA Remaining Clients_SII_Evidence_Document Let me know if you have any questions. Regards, Sylvia Sylvia Escobar Vice President Deutsche Bark Securities Inc. Wealth Management-Americas 1 South Street, Baltimore. MD21202-3298 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042458 CONFIDENTIAL SDNY_GM_00188642 EFTA01356551