Mgmt determined that EEA retain Brokerage accounts need to be transferred to
the client service center to meet reverse solicitation requirements at the
transaction level. However, BSO expressed concerns ... complex products or the business was not feeling comfortable transferring
accounts to the client service center. As a results, exceptions were
granted to maintain EEA brokerage accounts with ... transfer to
the client service center. EEA brokerage account population details are
saved on share drive. Path: Y:\Business Risk\CPI\MiFID II\EEA Remaining
Countries\Accts transferring
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01399165.pdf