EFTA Document EFTA01372651

• Politically Exposed Person • High Risk Country • Loan file to be checked for applicable functional aspects from Quarterly NCA File Assessment Form for both borrowers and co-borrowers. o Borrower(s) Name(s) o Approval and Funding Dates o Physical Address o Social Security Number o Date of Birth • Folders to be reviewed for PCR checks from a qualitative perspective o Is PCR alerted? o Did the Loan Investigation Department (LID) review the PCR hit? o Did LID escalate the true-positive alert to AML Compliance? 2.2 Quarterly NCA File Assessment Report • Enter findings from Quarterly NCA File Assessment form onto the MIT Quarterly Summary Review Excel Spread sheet o X in the named field if applicable, present and correct o N/A in the named field if not applicable to that File o X In the name field if applicable, missing or incorrect o Add to comments field to explain issue • Upon Completion of MIT Quarterly Summary Review Excel spread sheet o Tally all of the X and X in the data elements o Tally all of the X in the data elements o Calculate the percentage of X in the total data elements o Send E-mail to GM AML management and MIT compliance with findings and request for MIT to provide, where possible, corrections for designated errors .1 MIT File Assessment. xls CONFIDENTIAL - PURSUANT TO FED. R. GRIM. P. 6(e) DB-SDNY-0066446 CONFIDENTIAL SDNY_GM_00212630 EFTA01372651