EFTA Document EFTA01399167

MIFID II - Remaining EEA Countries (Excl Germany & UK) — Evidence Document Finding ID: GFMS 90-017/2019 #43 (dbTrack2407699) Evidence # 1: Daily Middle Office Exception Report Description: Daily automated report distributed to Middle Office to ensure that EEA brokerage accounts are only serviced on a reverse solicitation basis. The report contains 4 worksheets described below: Sheet 1: The accounts on this worksheet are coded EEA on dbForce, but are not coded EEA on NetX. Must code EEA on NetX Sheet 2: The accounts on this worksheet are coded EEA on NetX, exist on dbForce, but are not coded EEA on dbForce. Must uncode EEA NetX Sheet 3: Organized Entity accounts where NetX is not coded "UK HNW Company" and dbForce EEA Country contains UK. Check if CA is outside of CSC and if yes, confirm HNW Company Exemption form is on file. The following CSG CA Numbers are excluded: DOL, GGC, EHM, WAM, L6S, EMP, EIS, MUR, A3B, EEA, Alf). Accounts coded "EEA Exception Approved" on NetX are excluded Sheet 4: Brokerage accounts where NetX is not coded "UK HNW Company" and dbForce reflects EEA. Check if CA is outside of CSC and if yes, confirm HNW Company Exemption form is on file or Notes reflect EEA exception was approved. The following CSG CA Numbers are excluded: DOL, GGC, EHM, WAM, L6S, EMP, EIS, MUR, A3B, EEA, Alf). Accounts coded "EEA Exception Approved" on NetX are excluded Attachments: Daily email with Middle Office Exception report Daily Middle Office Exception report Evidence # 2: Mismatch EEA Report Description: outlines EEA client identification mismatches between dbForce and IT logic to identify EEA clients. Worksheet 3 has the mismatches and related comments. Attachment: Mismatch EEA Report Evidence # 3: EMEA Legal & Compliance approvals Description: selected a sample of EEA lead/prospects and clients for which US compliance facilitated approvals from EMEA Legal & Compliance. The following testing was performed for the selected record: Confirm if KYC was approved Confirm if EEA fields were updated in dbForce Confirm reverse solicitation evidence EFTA01399167 Attachment: To be added Evidence # 4: Sample of KYCs approved from Feb 1 through April 10 Description: report outlines KYCs approved from Feb 1 through April 10. A sample was selected to perform the following testing: EEA determination EEA classification/tracking Confirmation of reverse solicitation, if required Attachments: To be added For internal use only For internal use only For internal use only EEA Mismatch Rep ort.xls EFTA01399168 Copy of EeaV3Changes (002) - MO Brokerage Exception Report.xls EFTA01399169