EFTA Document EFTA01436156

JAMES DESNICK account exceeded the Incoming amount for February 2016. Account III472 was reviewed for the period January 2016 through February 2016. Account balance: $4,507,986.52 There were 4 Incoming transactions totaling $1,200,018.21 which consisted of a $1.2MM Wire from the client's same name account at FIRST REPUBLIC BANK and 3 Transfers totaling $18.21 TRANSFER FROM INC TO PRIN SAME ACCOUNT. There were 6 Outgoing transactions totaling $1,803,770.79 which consisted of a $1.8MM Wire to AQL HARTWELL LLC (related account under same relationship) at FIRST REPUBLIC BANK, $2.1K & $1.5K Wires to BTCO INSTALLMENT LOAN JAMES DESNICK INTEREST, and 3 Transfers totaling $18.21 TRANSFER FROM INC TO PRIN SAME ACCOUNT. Per KYC #1274014, JAMES DESNICK is a licensed physician (board certified ophthalmologist). He has not practiced medicine in approximately 20 years. His current business consists primarily of private equity transactions in the health care arena. With his partner, they acquire control of small public (and occasionally private) companies in the health care sector, change or improve management, to try and enhance shareholder value and ultimately sell to a larger entity or sell the stock. His primary source of income presently consists of private equity from his company Medical Equity Dynamics, LLC. Account was used to transfer funds between same name and related accounts, pay loan interest, and Inc to Prin transfers. Activity does not appear suspicious. No change in profile necessary. Tammy McFadden: Specify alerted INCOMING and OUTGOING amount/count For internal use only For internal use only EFTA01436156 For internal use only EFTA01436157