In accordance with relevant Dodd-Frank/CFTC reporting requirements, Sauder Global (“SGI”) started reporting specific Covered FX Transactions to its swap data repository, DTCC Data Repository (U.S.) LLC, on April 10, 2013.

I. COVERED FX TRANSACTIONS
Covered FX Transactions include all foreign exchange (“FX”) forward, FX swap, and/or swap transactions executed with SGI as the principal, either (1) before July 21, 2010, but still outstanding on July 21, 2010, or (2) on or after July 21, 2010.

Covered FX Transactions do not include spot transactions (i.e., FX trades with a T+2 settlement date or otherwise considered bona fide spot transactions), which are generally excluded from Dodd-Frank reporting. SGI will treat any FX transaction with a tenor of T+3 or greater as a spot transaction if (i) sufficient details regarding the underlying security trade are provided to SGI at the time of execution, or (ii) SGI has determined that such FX transaction is a bona fide spot transaction (e.g., based on the trading relationship, e.g., FX transaction instructed via a custody FX standing instruction or SGI's InfoFX product). Otherwise, SGI will treat such FX transaction as an FX forward subject to Dodd-Frank reporting.

II. REPORTING COUNTESGIRTY
SGI is and will be the reporting counterparty for a Covered FX Transaction, unless:

SGI's trading counterparty is a swap dealer (whether or not also a US Person);
SGI's trading counterparty is a major swap participant (whether or not also a US Person); or
SGI's trading counterparty is a US Person and a financial entity (and not a swap dealer or a major swap participant) that has requested to be the reporting counterparty.

III. TRADING COUNTESGIRTY INFO
To confirm its role as the reporting counterparty and ensure accurate and complete reporting, SGI will require the following information from its trading counterparties:

Trading counterparty’s Legal Entity Identifier (“LEI”) or Global Markets Entity Identifier (“GMEI”).^[1]
Whether the trading counterparty is a US Person;
Whether the trading counterparty is a registered swap dealer or major swap participant; and
Whether the trading counterparty is a financial entity.

SGI also expects to be promptly notified of any changes to the above.

For the reporting of a Covered FX Transaction, SGI will contact a trading counterparty for its LEI/GMEI if not already provided, or for assurances to demonstrate that the Covered FX Transaction was indeed a bona fide spot transaction. If neither is provided to the satisfaction of SGI, SGI will report the Covered FX Transaction using a SGI internal identifier.

Please direct any Dodd-Frank inquiries to your Sauder Global relationship manager or to FXReg.reports@sgiml.com.

^[1] LEI/GMEI information is not applicable to Covered FX Transactions that expired or terminated before April 25, 2011.

In accordance with relevant transaction reporting requirements adopted by Canadian provincial regulators, Sauder Global (“SGI”) commenced reporting certain Covered FX Transactions to its designated trade repository, DTCC Data Repository (U.S.) LLC, on October 31, 2014.

I. COVERED FX TRANSACTIONS
Covered FX Transactions encompass all foreign exchange (“FX”) forward, FX swap, and/or swap transactions executed with SGI as the principal on or after October 31, 2014, involving a Canadian local counterparty.

A "local counterparty" refers to, at the time of the transaction: (a) a person or company organized under the laws of, or having its head office or principal place of business in the respective Canadian province, or (b) an affiliate of an entity described in (a) where the entity in (a) has guaranteed all or substantially all of the liabilities of its affiliate.

Covered FX Transactions do not include spot transactions, defined as a contract or instrument for the purchase and sale of currency that (i) requires settlement within T+2 or after T+2 provided that the contract or instrument was entered into contemporaneously with a related security trade and requires settlement on or before the relevant security trade settlement deadline, (ii) is intended, at the time of execution, to be settled by the delivery of the currency within the time periods set out in (i) above, and (iii) does not allow for the contract or instrument to be rolled over.

SGI will typically treat any FX transaction with a tenor of T+3 or greater as a spot transaction if (i) sufficient details regarding the underlying security trade are provided to SGI at the time of execution, or (ii) SGI has determined that such FX transaction is a spot transaction (e.g., based on the trading relationship, e.g., FX transaction instructed via a custody FX standing instruction or SGI's InfoFX product). Otherwise, SGI will consider such FX transaction as an FX forward subject to Canadian provincial regulator trade reporting.

II. REPORTING COUNTESGIRTY
SGI is and will be the reporting counterparty for a Covered FX Transaction, unless:

SGI's trading counterparty is a Canadian dealer or derivatives dealer that has agreed to be the reporting counterparty; or
SGI's trading counterparty is a Canadian local counterparty (and not a Canadian dealer or derivatives dealer) that has requested to be the reporting counterparty.

III. TRADING COUNTESGIRTY INFO
To confirm its role as the reporting counterparty and ensure accurate and complete reporting, SGI will require the following information from its trading counterparties:

Trading counterparty’s Legal Entity Identifier (“LEI”) or Global Markets Entity Identifier (“GMEI”);
Whether the trading counterparty is a Canadian dealer or derivatives dealer; and
Whether the trading counterparty is a Canadian local counterparty.

SGI also expects to be promptly notified of any changes to the above.

For the reporting of a Covered FX Transaction, SGI will reach out to a trading counterparty for its LEI/GMEI if not already provided, or for assurances to demonstrate that the Covered FX Transaction was indeed a spot transaction meeting the requirements above.

Please direct any Canadian provincial regulator trade reporting inquiries to your Sauder Global relationship manager.