EFTA01356576

Reverse Solicitation Controls (Excluding German Clients) • Account Opening Review Group to ensure EEA Client Declaration form is part of account opening documents and signed by the client, Relationship Manager and Business Manager. If EEA Client Declaration form is not complete, the request must be rejected and sent back to the Relationship Manager for completion. • Confirm that all fields are completed and signatures are there. • Original stamp is not required on the declaration form. • There will be no exception to open the account without signed declaration form for EEA Client. • If WM NOC receives re-opening request and client falls under EEA regulation (EEA Client Type = Retail, EEA Country except Germany) then check if the EEA form already exists. If so, Please provide approval and if the form does not exist, request the "EEA Client declaration form". • EEA Client declaration form is not require for Account Title Change cases. • Go Live Date —06/12/2018. • With effect from 01ST Oct 2018, EEA client declaration form must be signature verified. 54. EEA Client Procedure— For internal use only CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042491 CONFIDENTIAL SDNY_GM_00188675 EFTA01356576