Trust Examiner School eBook

[Type Management Response Here]

69. Describe the OFAC process. If internal, please send a list of blocked or rejected transactions with individuals or entities on the OFAC list and reported to OFAC. If maintained, please make available logs or other documentation related to reviewing potential OFAC matches, including the method for reviewing and clearing those determined not to be matches. If external, please send a copy of records verifying that the most recent updates to the OFAC software have been installed.

[Type Management Response Here]

70. Describe whether the trust uses a manual or an automated account monitoring system, or a combination of the two. If an automated system is used, state whether the system is proprietary or vendor supplied. If the system was provided by an outside vendor, request (i) a list that includes the vendor, (ii) application names, and (iii) installation dates of any automated account monitoring system provided by an outside vendor. a) Please send a list of flags or rules used by the monitoring system to capture suspicious activity and the algorithms and thresholds for each flag or rule. b) Please send a list of algorithms, thresholds and/or rules used by the monitoring system to capture exemptions to customer profiles. c) Please send a list of authorized users and their profiles (rights) for the monitoring system. d) Please send copies of the most recent independent validation of the monitoring software.

[Type Management Response Here]

Asset Management

71. A copy of your list of investments approved for discretionary purchase or retention, including mutual funds. Also provide a list of discretionary accounts in investments not on the approved list. For each account, provide an explanation regarding the investment and list the type of investment.

[Type Management Response Here]

72. Describe how investment decisions are made, supported and evaluated. Specifically, address the methodology used to determine the investment objective of discretionary accounts. If investment decisions are delegated, describe the process used to determine that investment service providers are properly scrutinized before use and reevaluated on an annual basis.

[Type Management Response Here]

73. A list of brokers used and a description of the process used to determine whether best execution is being provided by each broker.