EFTA Document EFTA01356577

MIFID II is a package of EU legislation, which regulates firms who provide services to clients linked to financial instruments and the venues where those instruments are traded. Checklist for client account on-boarding: MIFID II • DPM & Custody: Confirm German clients filled out agreement supplement specific to German clients (check if EEA client field and country field, if "EEA type" does NOT contain "N/A" or blank and EEA country contains Germany); Supplement will be created to include additional attestations/checkbox client received best ex and starter package. Ensure completion of supplement. • DPM: Ensure accounts have "MIFID" selected with the investment objective. Example: Old name: GAT — Growth, New name: MIFID- Growth. • All accounts (Deposits, Trust, etc.): No non-GAT bankers can open German domiciled accounts (check if EEA client field and country field, if "EEA Type" does not contain "N/A" or blank and EEA country contains Germany). If a new account opening request for a German domiciled client is submitted, reject. Only new accounts which come from non-GAT bankers can be opened for existing German clients with Business Manager Exception approval (email to be attached to account opening docs). To review Banker's sub-GMT information review Alias field in DB Force. • For EEA clients where in DB force it is given as retail they cannot be allowed to open IA accounts as Non-Discretionary as the case needs to be rejected by WM NOC AOG. MIFID II & PRIIPs DPM Control: For internal use only CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042494 CONFIDENTIAL SDNY_GM_00188678 EFTA01356577