financials criteria due to strong business rational to be retained. • New accounts: i. Implemented approval process for new EEA clients/accounts (EMEA legal & compliance approvals — see attached evidence for operational effectiveness). it Implemented reverse solicitation controls at the lead/prospect. account, and tr

CO (Kim/Julie to facilitate) 9 No Was the client approved for non-target coverage (use non-target paper form) 10 Yes Was the client approved by EMEA legal & compliance 11 Yes Is the "Banker" attestation form confirming that reverse solicitation is not require d on file 12 No Tax documents received and Tax appro