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EEA Retain — Project Documentation
Background:
As a result of the regulatory environment in the EEA, WM Americas decided to
further analyze its current EEA account population and identify
relationships/accounts meeting financial thresholds established by
management and with account holders or primary decision makers residing in
the EEA retain approved country list.
EEA retain approved country list:
Austria, France, Germany, Italy, Netherlands, Spain, Portugal, Germany and
UK.
EEA account criteria:
Individual/joint accounts: account holder and/or primary decision maker
resides in the EEA
Legal Entity accounts: primary decision maker resides in the EEA
Financial Thresholds:
CBV >Eur2mm
Rev>Eur2Ok
EEA Retain Account Population:
The initial EEA retain account population was determined based on data
stored in WM America systems. Any account with an EEA nexus was included in
the initial account population.
Subsequently, the accounts in scope were
validated by DCO and the FO to confirm the EEA nexus based on the EEA
criteria mentioned above.
As a result the EEA retain account population
was reduced from 163 to 60.
EEA Retain Accounts Remediation:
For the 60 EEA retain accounts reverse solicitation evidence was required in
order to retain the account.
Reverse solicitation evidence for existing
was obtained through:
EEA Bankers attestation form (Internal form)
EEA Client declaration form (External form)
Each reverse solicitation form was reviewed and approved by DCO and US
compliance to ensure requirements were met.
Details of the reverse solicitation forms and approval dates were captured
on the EEA_Act_Rev_Solicitation_Required_Final file saved on the share
drive.
Path: Y:\Business Risk\CPI\MiFID II\EEA Remaining Countries\Account
Data\Acct Data Rev-Solicitation Required
EEA Retain — Brokerage Accounts:
Mgmt determined that EEA retain Brokerage accounts need to be transferred to
the client service center to meet reverse solicitation requirements at the
transaction level.
However, BSO expressed concerns for accounts trading
complex products or the business was not feeling comfortable transferring
accounts to the client service center. As a results, exceptions were
granted to maintain EEA brokerage accounts with ISG and don't transfer to
the client service center.
EEA brokerage account population details are
saved on share drive. Path: Y:\Business Risk\CPI\MiFID II\EEA Remaining
Countries\Accts transferring to CSC
EEA Reverse Solicitation Controls — New EEA Clients/Accounts:
Reverse solicitation controls were identified, documented and implemented
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for new clients/accounts.
Documentation of the reverse solicitation controls are saved on the share
drive. Path: Y:\Business Risk\CPI\MiFID II\EEA Remaining Countries\Reverse
Solicitation Controls
EEA Training:
US compliance and Armen Brash facilitated the EEA training sessions for the
FO.
Final materials are saved on the share drive. Path: Y:\Business
Risk\CPI\MiFID II\EEA Remaining Countries\Reverse Solicitation
Controls\Training
EEA Banker Re-assignment:
Mgmt made a commitment to reduce the number of bankers to service EEA
existing and new clients.
As a result, the project team drafted a proposal
identifying bankers across Sub-GMTs to service EEA clients.
The proposal
was shared with Sub-GMT Heads and they are currently implementation
details.
Files related to the proposal are saved on share drive. Path: Y:-
\Business Risk\CPI\MiFID II\EEA Remaining Countries\RM Team Proposal
For internal use only
For internal use only
For internal use only
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