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sd-10-EFTA01432115Dept. of JusticeOther

EFTA Document EFTA01432115

Subject: Re: DB Initial Mar in Se re ation [C] From: Paul Barrett Date: Wed, 19 Sep 2018 20:04:45 -0400 To: Davide-A Sferrazza Cc: Stewart Oldfield Martin Zeman Liam Osullivan Got it. Thanks. Paul Barrett Alpha Group Capital LLC 142 W 57th Street, 11th Floor, New York, NY 10019 (o) (c) On Sep 19, 2018, at 6:26 PM, Davide-A Sferrazza <a> wrote: > Classification: Confidential Paul, I tried reaching out last week regarding the attached notice that you received, but was not able to

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Subject: Re: DB Initial Mar in Se re ation [C] From: Paul Barrett Date: Wed, 19 Sep 2018 20:04:45 -0400 To: Davide-A Sferrazza Cc: Stewart Oldfield Martin Zeman Liam Osullivan Got it. Thanks. Paul Barrett Alpha Group Capital LLC 142 W 57th Street, 11th Floor, New York, NY 10019 (o) (c) On Sep 19, 2018, at 6:26 PM, Davide-A Sferrazza <a> wrote: > Classification: Confidential Paul, I tried reaching out last week regarding the attached notice that you received, but was not able to

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Subject: Re: DB Initial Mar in Se re ation [C] From: Paul Barrett Date: Wed, 19 Sep 2018 20:04:45 -0400 To: Davide-A Sferrazza Cc: Stewart Oldfield Martin Zeman Liam Osullivan Got it. Thanks. Paul Barrett Alpha Group Capital LLC 142 W 57th Street, 11th Floor, New York, NY 10019 (o) (c) On Sep 19, 2018, at 6:26 PM, Davide-A Sferrazza <a> wrote: > Classification: Confidential Paul, I tried reaching out last week regarding the attached notice that you received, but was not able to reach you. Today it struck me that I had not connected with you yet on this topic. I spoke with our Credit and Legal departments about whether this has any effect on Southern Financial's accounts — the short answer is that you can disregard. The long answer is that per the CFTC rules, you have the option to segregate initial margin by having it held in an account with a third part bank/- custodian. Since the collateral for Southern Financial sits in an account EFTA01432115 custodied with Pershing, you are already receiving this treatment. The notice would really only apply if collateral was held directly with DB Global Markets' collateral department, which is not the case for most WM clients. Please feel free to reach out if you have any further questions, and we'll be happy to address. Regards, Davide <image001.gif> Davide Sferrazza Analyst I Key Client Partners Deutsche Deutsche 345 Park Tel. Mobile Email Bank Securities, Inc. Bank Wealth Management Avenue, 10154-0004 New York, NY, USA This communication may contain confidential and/or privileged information. If you are not the intended recipient (or have received this communication in error) please notify the sender immediately and destroy this communication. Any unauthorized copying, disclosure or distribution of the material in this communication is strictly forbidden. Please refer to https://db.com/disclosures for additional EU corporate and regulatory disclosures. Deutsche Bank does not render legal or tax advice, and the information contained in this communication should not be regarded as such. <CFTC Seg IA Notice Annual 2018823.pdf> EFTA01432116

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