EFTA Document EFTA01418020

Subject: RE: Excessive Transactions March 2019 Account # From: Robert Dicerbo Date: Tue, 02 Apr 2019 09:22:58 -0400 To: Stewart Oldfield Arthur Tremblay Bradley Gillin < Cc: Charlie Burrows Anthony Western Classification: For internal use only Stew, [I] This account is an MMDA and under Reg D there is limit of six withdrawals during the month. Not sure when the account will be closing , however they may want to consider converting the account to a checking account if they plan of doing more disbursements. Give me a call if you have any questions. Thanks, Rob Regards, Robert DiCerbo Deutsche Bank Trust Company Americas Deutsche Bank Wealth Management 345 Park Ave. New York, NY 10154 Tel: EFTA01418020 Mobile: From: Stewart Oldfield Sent: Monday, April 01, 2019 5:46 PM To: Robert Dicerbo Arthur Tremblay Cc: Charlie Burrows Subject: Fwd: Excessive Transactions March 2019 Account [I] Can you guys have a look and let me know what needs to be done here? I didn't know we had any accounts with Epstein that had transaction limits. With the exiting of the relationship there is clearly increased activity. Thanks. Stewart Oldfield, CFA, CAIA Deutsche Bank Trust Company Americas Deutsche Bank Wealth Management 345 Park Avenue, New York, NY 10154 Tel. Mobile Email Securities offered through Deutsche Bank Securities Inc. EFTA01418021 Begin forwarded message: From: dboi oversight <[email protected]> Date: April 1, 2019 at 11:41:30 PM GMT+2 To: Stewart Oldfield ‹ > Cc: Ryan Neumann <a, Surendra Singh Teresa Metallo <fla, Debra Jasper > Subject: Excessive Transactions March 2019 Account 4 [I] Classification: For internal use only Hello Stewart, Please be advised that the below listed money market account has exceeded the allowed number of transactions on Date (03/29/2019). You are receiving this email because you are the banking officer on this account. Letter to the client will be sent out on (04/04/2019) notifying them of the violation. If it is the third violation, the account must be converted to a transactional account (i.e., DDA or NOW) within 10 days from the date of the final notice. In the event a subsequent transaction is posted to the non- transactional account post 3rd violation, during the 10 day grace period, the funds must be transferred to a transactional account immediately. If you think your client's violation is due to a bank error, please respond to both myself and Ryan Neumann in Compliance with your reason and it will be reviewed. If we do not receive a response in next two business day, we will assume you are not disputing this violation and letters will be sent according to Federal Regulations. Acc Southern Trust Company, 1st violation Please advise your client about the Regulation D requirement allowing only 6 transactions per month. {cid:[email protected]} 8 Transactions- Preauthorized Debit Thanks & regards, Oversight & Escalation Team EFTA01418022 Oversight & Escalation DBOI Global Services Private Limited COO Wealth Management Operations A-1 & A-2, Evolve - Mahindra Technology Park, Inside Mahindra World Cit - SEZ 302029 Jaipur, India Tel. (BCP) Email [email protected] EFTA01418023