EFTA Document EFTA01401995

Subject: RE: Southern Financial From: Zack Bunimovich Date: Thu, 26 Apr 2018 To: Martin Zeman Nina Tona Rita Shteynberg Cc: Liam Osullivan Davide-A Sferrazza Xavier Avila Joshua Shosha - KYC Docs. [I] 17:38:23 -0400 Classification: For internal use only Hi Martin, Verification is not accepting Southern's confirmation of NOB in the way they structured their response. They will need Southern to clearly specify that they are confirming the below is their NOB. If you can pose the below to them once more, a 'confirmed' from them will suffice. Clarification of the Nature of Business o Private investment vehicle; allocates capital across various asset classes and trading strategies. Thanks, Zack From: Martin Zeman Sent: Thursday, April 19, 2018 10:54 AM To: Zack Bunimovich Nina Tona Cc: Liam Osullivan • Davide-A Sferrazza • Xavier Avila ; Joshua os an Subject: RE: Southern Financial - KYC Docs. [I] Classification: For internal use only EFTA01401995 Zack, See attached the FATCA + CRS form. Three follow-up questions from the client: 1. Can we clarify the definition of 'Active NFE — other' versus 'Passive NFE' under Part 2 (b). The definition is not very clear to the client. They believe they are 'Active NFE — other' but want clarification 2. Can you say what happens with the information in this form? What does DB do with it and who is it reported to? 3. Do US Virgin Islands also fall under this reporting requirement? On the other points, note the DOB of their legal reps are: Darren IndykiIIIIIIIIII Richard Kahn (see confirmation of this in the attached email from Richard Kahn) Thanks Martin From: Zack Bunimovich Sent: Wednesday, April 11, 2018 5:50 PM To: Martin Zeman Nina Tona Subject: RE: Southern Financial - KYC Docs. [I] Classification: For internal use only Hi Martin, EFTA01401996 Verification asked for two more points of information — see below. DOB for the Legal Reps o Darren K. Indyke o Richard Kahn Clarification of the NOB. o The NOB provided in the Articles of Organization and Operating Agreement is too vague. Please provide more detailed explanation of NOB. Thanks, Zack From: Martin Zeman Sent: Tuesday, April 10, 2018 1:28 PM To: Zack Bunimovich ; Nina Tona Subject: RE: Southern Financial - KYC Docs. [I] Classification: For internal use only Zack See the attached email chain where we established that a FATCA form was not needed. Martin From: Zack Bunimovich EFTA01401997 Sent: Monday, AprillaimmalamILialmagim To: Martin Zeman a, Nina Tona Subject: FW: Southern Financial - KYC Docs. [I] Classification: For internal use only Hey Martin / Nina, Southern Financial is with Verification but they noticed that we do not have a CRS Self Certification form on file anymore from previous onboardings. We are usually looking for something similar to the attached format, but it's possible that the client has provided this before and has their own template. Can this be requested from the client? Thanks, Zack From: Anthony Lentini Sent: Monday, April 09 2018 10:51 AM To: Zack Bunimovic Subject: Southern Financial - KYC Docs. [I] Classification: For internal use only Hi Zack, An update on Southern Financial, it is with Verification and they are reviewing right now. While they were going through their review they noticed that the CRS Self Cert file from a previous onboarding is no longer on file/- in the system. Could you please send over a new CRS Self Cert so they can proceed with EFTA01401998 their review? Apologies for the inconvenience. Kind Regards, {cid:1 [email protected]} Anthony Lentini Client Data Services I COO DBUSA Core Corp. 5201 Gate Parkway Jacksonville FL32256 EFTA01401999