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Deutsche Bank Corporate & Investment Bank Global Market Structure Background: The Large Trader Reporting Rule 1 was driven by the SECs 2010 Concept Release on Equity Market Structure and the Flash Crash of May 6, 2010. The new rule seeks to bolster the SECs ability to monitor activity across markets and more effectively reconstruct market activity. Who is a Large Trader? Generally, Rule 13h-1 defines a “Large Trader” as a person or entity that: 1. Exercises investment discretion over one or more accounts and in relation to those accounts, effects transactions in NMS Securities, which in aggregate equals or exceeds (a) 2 million shares or $20 million in a calendar day; or (b) 20 million shares or $200 million in a calendar month; or 2. Voluntarily registers as a large trader To determine whether the relevant thresholds have been met, certain trading activity can be excluded; such as, certain corporate actions. A participant may not net purchases and sales when determining whether it has met the relevant thresholds. The Rule establishes a methodology for determining the market value of options transactions. Large Trader ID Rule The SEC approved the new Large Trader Reporting Rule (Rule 13h-1) on August 3, 2011. Rule 13h-1 is expected to impact market participants that conduct substantial amounts of trading activity in certain U.S. securities, and registered broker-dealers who effect transactions or carry accounts for these participants. New Requirements for Large Traders: December 1, 2011 is the currently scheduled deadline for Large Traders to comply with the Rule’s filing and disclosure requirements. 3. 1. Filing Requirement: Generally, Large Traders must self-identify to the SEC promptly after exceeding a relevant threshold by filing Form 13H through the SECs Edgar Website. Once a Large Trader files its form 13H, it must make an annual filing within 45 days after the end of each calendar year, and also promptly following the end of a calendar quarter in the event that its current Form 13H filing becomes inaccurate. Notably, complex organizations may have multiple related legal entities each qualifying as a Large Trader, the parent company may file and maintain a single Form 13H on behalf of all Large Traders in its organization, or each Large Trader within the organization may file and maintain a form 13H on its own behalf. 4. Disclosure Requirement: Each Large Trader must self- identify itself as a Large Trader to each registered broker- dealer effecting transactions on its behalf by providing each with: (a) the large trader identification number (LTID) obtained by the Large Trader from the SEC after submitting an initial Form 13H filing, and (b) each account to which the LTID applies. Industry groups are working to determine whether the SEC expects Large Traders to provide an LTID to each and every broker- dealer involved in the execution and clearance of the Large Trader’s transactions, or if the SEC expects an executing or clearing broker who obtains an LTID to forward the LTID to other brokers who may be involved in executing and or clearing the Large Trader’s transactions. Point of Note: Industry groups are working with the SEC and other regulators to define the Large Trader ID (LTID) field length, character requirements, and format consistent FIX specifications. How to Report Your LTIDs to Deutsche Bank: If you are required to provide your LTID or LTID(s) to Deutsche Bank Securities Inc., you may do so by completing and then submitting the attached form via email to: [email protected] For General Questions on Large Trader ID: Please contact your sales representative 1 SEC Speech on LTID Key Dates: August 3, 2011: LTID Approved October 3, 2011: LTID Rule Effective Date December 1, 2011: Scheduled Compliance Date for Large Traders to identify themselves to the SEC pursuant to Rule 13h-1(b). April 30, 2012: Scheduled Broker Dealer Compliance Date to maintain records, report LTID activity to the SEC via blue sheets, and monitor for unregistered LTID activity. Relevant Links: SEC Approved LTID Rule Filing Federal Register Approved SEC Filing Edgar Filing Website for Form 13H Edgar Filing Instructions for Form 13H For Corporate Investment Banking Customers: How to Report your Large Trader ID to Deutsche Bank November 1, 2011

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Page 1: Global Market Structureglobalmarkets.db.com/new/img/GMS_LTID_Form_v2_active.pdf · Deutsche Bank Corporate & Investment Bank Global Market Structure If you would like further information

Deutsche BankCorporate & Investment Bank

Global Market Structure

Background:The Large Trader Reporting Rule1 was driven by the SECs 2010 Concept Release on Equity Market Structure and the Flash Crash of May 6, 2010. The new rule seeks to bolster the SECs ability to monitor activity across markets and more effectively reconstruct market activity.

Who is a Large Trader?Generally, Rule 13h-1 defines a “Large Trader” as a person or entity that:1. Exercises investment discretion over one or more

accounts and in relation to those accounts, effects transactions in NMS Securities, which in aggregate equals or exceeds (a) 2 million shares or $20 million in a calendar day; or (b) 20 million shares or $200 million in a calendar month; or

2. Voluntarily registers as a large trader

To determine whether the relevant thresholds have been met, certain trading activity can be excluded; such as, certain corporate actions. A participant may not net purchases and sales when determining whether it has met the relevant thresholds. The Rule establishes a methodology for determining the market value of options transactions.

Large Trader ID Rule The SEC approved the new Large Trader Reporting Rule (Rule 13h-1) on August 3, 2011. Rule 13h-1 is expected to impact market participants that conduct substantial amounts of trading activity in certain U.S. securities, and registered broker-dealers who effect transactions or carry accounts for these participants.

New Requirements for Large Traders:December 1, 2011 is the currently scheduled deadline for Large Traders to comply with the Rule’s filing and disclosure requirements.3. 1. Filing Requirement: Generally, Large Traders must

self-identify to the SEC promptly after exceeding a relevant threshold by filing Form 13H through the SECs Edgar Website. Once a Large Trader files its form 13H, it must make an annual filing within 45 days after the end of each calendar year, and also promptly following the end of a calendar quarter in the event that its current Form 13H filing becomes inaccurate. Notably, complex organizations may have multiple related legal entities each qualifying as a Large Trader, the parent company may file and maintain a single Form 13H on behalf of all Large Traders in its organization, or each Large Trader within the organization may file and maintain a form 13H on its own behalf.

4. Disclosure Requirement: Each Large Trader must self-identify itself as a Large Trader to each registered broker-dealer effecting transactions on its behalf by providing each with: (a) the large trader identification number (LTID) obtained by the Large Trader from the SEC after submitting an initial Form 13H filing, and (b) each account to which the LTID applies. Industry groups are working to determine whether the SEC expects Large Traders to provide an LTID to each and every broker-dealer involved in the execution and clearance of the Large Trader’s transactions, or if the SEC expects an executing or clearing broker who obtains an LTID to forward the LTID to other brokers who may be involved in executing and or clearing the Large Trader’s transactions.

Point of Note: Industry groups are working with the SEC and other regulators to define the Large Trader ID (LTID) field length, character requirements, and format consistent FIX specifications.

How to Report Your LTIDs to Deutsche Bank:If you are required to provide your LTID or LTID(s) to Deutsche Bank Securities Inc., you may do so by completing and then submitting the attached form via email to:

[email protected]

For General Questions on Large Trader ID:Please contact your sales representative

1SEC Speech on LTID

Key Dates: —August 3, 2011: LTID Approved —October 3, 2011: LTID Rule Effective Date —December 1, 2011: Scheduled Compliance Date for Large Traders to identify themselves to the SEC pursuant to Rule 13h-1(b). —April 30, 2012: Scheduled Broker Dealer Compliance Date to maintain records, report LTID activity to the SEC via blue sheets, and monitor for unregistered LTID activity.

Relevant Links: —SEC Approved LTID Rule Filing — Federal Register Approved SEC Filing — Edgar Filing Website for Form 13H — Edgar Filing Instructions for Form 13H

For Corporate Investment Banking Customers: How to Report your Large Trader ID to Deutsche Bank November 1, 2011

Page 2: Global Market Structureglobalmarkets.db.com/new/img/GMS_LTID_Form_v2_active.pdf · Deutsche Bank Corporate & Investment Bank Global Market Structure If you would like further information

Deutsche BankCorporate & Investment Bank

Global Market Structure

Name of Institution: ______________________________________________________________________________________

Large Trader ID(s): ______________________________________________________________________________________

LTID Apply to all sub-accounts?: YES NO

If YES, please provide one sub-account number (ADP Account Number and ADP Account Name) and we will cross

reference all others: ______________________________________________________________________________________

If NO, please provide a list of the specific sub-account numbers (ADP Sub-Account Number and ADP Sub-Account

Name) to which each LTID applies (Attach a separate list if necessary): _________________________________________

___________________________________________________________________________________________________________

Contact Name: ______________________________________________________________________________________

Contact Title: ______________________________________________________________________________________

Contact Phone: ______________________________________________________________________________________

Contact Email: ______________________________________________________________________________________

Sales/Account Rep @ DB: _______________________________________________________________________________

Notification of LTID(s) will be accepted by DB Client Services Department by returning this form (or all relevant information) by email to: [email protected]

— If you have questions about this requirement, please do not hesitate to contact your Account Representative at DB for assistance.

—Specific questions regarding the completion of the form can be directed to DB Client Services via email or by calling 212-250-3130.

Please note that we may provide information that you submit to us on this form to other broker-dealers involved in effecting, clearing or carrying your transactions, but only to the extent reasonably necessary to comply with Rule 13h-1.

Thank you for your cooperation in this matter.

Large Trader ID (“LTID”) Reporting Form

Page 3: Global Market Structureglobalmarkets.db.com/new/img/GMS_LTID_Form_v2_active.pdf · Deutsche Bank Corporate & Investment Bank Global Market Structure If you would like further information

Deutsche BankCorporate & Investment Bank

Global Market Structure

If you would like further information on any of the items included in these documents then please contact the Global Market Structure team ([email protected]; +44 207 547 4390 / +1 212 250 4170 / +852 2203 5710).

IMPORTANT DISCLAIMERThis document is intended for discussion purposes only and does not create any legally binding obligations on the part of Deutsche Bank AG and/or its affiliates (“DB”). Without limitation, this document does not constitute an offer, an invitation to offer or a recommendation to enter into any transaction. When making an investment decision, you should rely solely on any specific final documentation relating to a transaction and not the summary contained herein. DB is not acting as your legal, financial, tax or accounting adviser or in any other fiduciary capacity with respect to any proposed transaction mentioned herein. This document does not constitute the provision of investment advice and is not intended to do so, but is intended to be general information. Any product(s) or proposed transaction(s) mentioned herein may not be appropriate for all investors and before entering into any transaction you should take steps to ensure that you fully understand the transaction and have made an independent assessment of the appropriateness of the transaction in the light of your own objectives, needs and circumstances, including the possible risks and benefits of entering into such transaction. For general information regarding the nature and risks of the proposed transaction and types of financial instruments please go to www.globalmarkets.db.com/riskdisclosures. You should also consider seeking advice from your own advisers in making any assessment on the basis of this document. If you decide to enter into a transaction with DB, you do so in reliance on your own judgment. The information contained in this document is based on material we believe to be reliable; however, we do not represent that it is accurate, current, complete, or error free. Assumptions, estimates and opinions contained in this document constitute our judgment as of the date of the document and are subject to change without notice. Any projections are based on a number of assumptions as to market conditions and there can be no guarantee that any projected results will be achieved. Past performance does not guarantee or predict future results. This material was prepared by a Sales or Trading function within DB, and was not produced, reviewed or edited by the Research Department. Any opinions expressed herein may differ from the opinions expressed by other DB departments including the Research Department. Sales and Trading functions are subject to additional potential conflicts of interest which the Research Department does not face. DB may engage in transactions in a manner inconsistent with the views discussed herein. DB trades or may trade as principal in the instruments (or related derivatives), and may have proprietary positions in the instruments (or related derivatives) discussed herein. DB may make a market in the instruments (or related derivatives) discussed herein. Sales and Trading personnel are compensated in part based on the volume of transactions effected by them. DB seeks to transact business on an arm’s length basis with sophisticated investors capable of independently evaluating the merits and risks of each transaction, with investors who make their own decision regarding those transactions. The distribution of this document and availability of these products and services in certain jurisdictions may be restricted by law. You may not distribute this document, in whole or in part, without our express written permission. DB SPECIFICALLY DISCLAIMS ALL LIABILITY FOR ANY DIRECT, INDIRECT, CONSEQUENTIAL OR OTHER LOSSES OR DAMAGES INCLUDING LOSS OF PROFITS INCURRED BY YOU OR ANY THIRD PARTY THAT MAY ARISE FROM ANY RELIANCE ON THIS DOCUMENT OR FOR THE RELIABILITY, ACCURACY, COMPLETENESS OR TIMELINESS THEREOF. DB is authorized under German Banking Law (competent authority: BaFin - Federal Financial Supervising Authority) and regulated by the Financial Services Authority for the conduct of UK business. In the US this document is approved and or distributed by Deutsche Bank Securities Inc., a member of the NYSE, FINRA, NFA and SIPC. In accordance with US regulations, please contact your local DB US registered broker dealer, Deutsche Bank Securities Inc., for any questions or discussion of potential transactions.

JAPANESE DISCLAIMERThis document has been prepared by Deutsche Securities Inc. (“DSI”) for information purposes only. Although the information contained herein is based on sources that DSI believes reliable, DSI does not make any representation or warranty, express or implied, with respect to the fairness, correctness, accuracy, reasonableness or completeness of the information and opinion herein. DSI is not responsible for any losses or damages incurred by your relying on such information and opinion. The analyses or opinions contained herein may be based on assumptions that if altered can change the analyses or opinion expressed. Nothing contained herein shall constitute any representation or warranty as to future performance of any financial product, credit, currency rate, interest rate or any other market or economic measure. Furthermore, past performance is not necessarily indicative of future results. DSI has no obligations to update, modify or amend this document or to notify a reader in the event that any matter stated herein changes or subsequently becomes inaccurate. DSI is not acting as your adviser, agent or fiduciary. When you analyze risks and issues on investment, finance, tax, law and/or accounting contained herein, you should take steps to ensure that you understand the transaction and have made an independent assessment of the appropriateness of the transaction and it is strongly recommended to seek advice from your own experts and/or advisors, in light of your own objectives and circumstances. This document shall not be construed as and does not form part of an offer, nor an invitation to offer, nor a solicitation or recommendation to enter into any transaction with DSI or any of its affiliates, nor is it an official or unofficial confirmation of terms. This document and any information contained herein are confidential and may not be reproduced or distributed in whole or in part without our prior written consent.