EFTA01090698.pdf

EXHIBIT A TO EDR SWITZERLAND NON-PROSECUTION AGREEMENT STATEMENT OF FACTS INTRODUCTION I. Edmond de Rothschild (Suisse) SA is a corporation organized under the laws of Switzerland with its headquarters in Geneva, Switzerland.' It operates a subsidiary called Edmond de Rothschild (Lugano) SA. Edmond de Rothschild (Suisse) SA and Edmond de Rothschild (Lugano) SA are hereinafter collectively referred to as "EdR Switzerland" or the "Bank." 2. SIR Switzerland operates a financial services business in Geneva, Lausanne, Fribourg, and Lugano, Switzerland. It offers private banking and wealth management services for individual clients around the world, including U.S. citizens, legal permanent residents, and resident aliens. 3. SIR Switzerland is affiliated with the Edmond de Rothschild Group, an independent, family-controlled financial group focused on high-net-worth individual clients. Edmond de Rothschild Group was founded in 1953 and currently operates in 19 countries worldwide. EdR Switzerland is an independent Swiss legal entity, led by its own board of directors, chief executive officer, and executive committee, and is supported by its own legal and compliance functions. 1 gReci gag - Sella 5. 4.-1n 2014, the Edmond de Rothschild Group held assets under management totaling approximately $165.0 billion, out of which $44.0 billion comprised client assets managed in Switzerland. This made EdR RotlisoldkISwitzerland one of the largest private banks in Switzerland. US. INCOME TAX & REPORTING OBLIGATIONS ' Edmond de Rothschild (Suisse) SA was formerly called Banque Prised:Ix& Edmond de Rothschild SA and Edmond de Rothschild ilagannlati was formerly known as Banca Privata Edmond de Rothschild Lugano SA. Pagel of II December O14.2015 EFTA01090698  8.-United States ("U.S.") citizens, resident aliens, and legal permanent residents have an obligation to report all income earned from foreign bank accounts on their tax returns and to pay the taxes due on that income. Since tax year 1976, U.S. citizens, resident aliens, and legal permanent residents have had an obligation to report to the Internal Revenue Service ("IRS") on the Schedule B of a U.S. Individual Income Tax Return, Form 1040, whether that individual had a financial interest in, or signature authority over, a financial account in a foreign country in a particular year by checking "Yes" or "No" in the appropriate box and identifying the country where the account was maintained. &Since 1970, U.S. citizens, resident aliens, and legal permanent residents who have had a financial interest in, or signature authority over, one or more financial accounts in a foreign country with an aggregate value of more than S10,000 at any time during a particular year were required to file with the Department of the Treasury a Report of Foreign Bank and Financial Accounts, FinCEN Form 114, formerly known as Form TD F 90-22.1 (the "FBAR"). 8. 7..-An "undeclared account" was a financial account owned by an individual subject to U.S. tax and maintained in a foreign country that had not been reported by the individual account owner to the U.S. government on an income tax return and an FBAR. 9.. 8.-Since approximately the 1930s, Switzerland has maintained laws that ensure the secrecy of client relationships at Swiss banks. Swiss law prohibits the disclosure of identifying information without client authorization, especially to foreign government investigators. These are Swiss criminal laws punishable by imprisonment. Because of the secrecy guarantee that they created, these Swiss laws enabled U.S. clients to conceal their Swiss bank accounts from U.S. authorities. 9.-In or about 2008, Swiss bank UBS AG ("UBS") publicly announced that it was the target of a criminal investigation by the IRS and the United States Department of Justice ("DOJ") and that it would be exiting and no longer accepting certain U.S. clients. On February 18, 2009, the DOJ and UBS filed a deferred prosecution agreement in the Southern District of Florida, in which UBS admitted that its cross- border banking business used Swiss banking secrecy and privacy laws to aid and assist U.S. clients in opening and maintaining accounts and concealing undeclared assets and income from the IRS. Since UBS's announcement, several other Swiss banks have publicly announced that they were or are the targets of similar criminal investigations and that they would likewise be exiting and not accepting certain U.S. clients. These cases have been closely monitored by banks operating in Switzerland, including EdR Switzerland, since at least the third quarter of 2008. Commented (VII]: ravenEa 'conducted a U.S. cross border banking business' suggests a moth higher degree of strategy and OVERVIEW OF EDR SWITZERLAND'S U.S. CROSS-BORDER BUSINESS osgannation than act.i.-ty existed at EdR - there was no U.S. deg, no Ms who focused on U.S. clients, no marktung aimmtas_00 II. 40.-For decades prior to and through in or about 2013. EdR Switzerland eonclueted-a U.S., and no strategic plans focused on U.S. dionts. Vitgnia Toil UnSrecass-border-bankleg-luisiness-that-aided and assisted U.S. clients in opening 2015 12 33 10 Page 2 of II December 4014. 2015 EFTA01090699  and maintaining undeclared accounts in Switzerland and concealing the assets and income they held in these accounts. During the Applicable Period,2 EIR Switzerland held and managed approximately 9449 y 50 U.S. client accounts, which included both declared and undeclared accounts, with aggregate peak of assets under management of $2.15 billion./ 12.44.-EdR Switzerland was aware that U.S. taxpayers had a legal duty to report to the IRS and pay taxes on all of their income, including income earned in accounts that these U.S. taxpayers maintained at SIR Switzerland. SIR Switzerland knew that it was likely that certain U.S. taxpayers who maintained accounts at EdR Switzerland during the Applicable Period were not complying with their U.S. reporting obligations. 43.-EdR used a variety of means to assist U.S. clients in concealing their undeclared accounts, including by: providing traditional Swiss banking products such as hold mail, code name, and numbered account services; • assisting clients in using sham entities such as structures -and-insuranee-wrappers Commented IV 2]: See 8OER000901- the only insurance wrapper connection was that the Bank permitted the beneficial as nominee beneficial owners of the undeclared accounts; owners of G01078 and G00778 to open new named accounts at the Bank for a matter of days so that they could exit the Bank to insurance wrapper accounts at another bank. The Bank had no US providing offshore credit cards, cash cards, and debit cards to repatriate funds from reLated accounts held by Insurance wrappers. the undeclared accounts; Virginia Tent 2015.12.141033:00 • structuring transfers of funds from undeclared accounts to evade currency transaction reporting requirements; facilitating the covert repatriation of undeclared accounts via cash withdrawals, the purchase of luxury goods, and transfers to the foreign bank accounts of non-U.S. friends, family, and business associates; • accepting and suggesting the use of IRS forms that falsely stated under penalties of perjury that the sham entities beneficially owned the assets in the undeclared accounts; divesting U.S. securities from its undeclared U.S. accounts for the purpose of 2 Capitalized terms not otherwise defined in this Statement of Facts have the meanings set forth in the Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks, issued on August 29, 2013 (the "Swiss Bank Program"). 3 Of the 161 U.S. client accounts at Edmond de Rothschild (I.uganol SA. g$ accounts with peak assets under management of approximately SS6 million were accounts opened by Sella Bank AG and inherited by Edmond de Rothschild (Lugano) SA as a result of its arrpoisition of Sella Bank AG Page 3 of II December 4014. 2015 EFTA01090700  subverting its Qualified Intermediary ("QI") Agreement with the IRS. 43.-Approximately 101 private bankers were responsible for managing at least one U.S. client account during the Applicable Period. These private bankers (referred to as - relationship managers") served as the points of contact for U.S. clients at EdR Switzerland and were responsible for opening and servicing U.S. client accounts at EdR Switzerland. Certain relationship managers assisted or otherwise facilitated some U.S. individual taxpayers in establishing and maintaining undeclared accounts in a manner that concealed the U.S. taxpayers' ownership or beneficial interest in said accounts. EdR Switzerland acquired U.S. client accounts primarily from direct referrals, walk-ins, and business arrangements with external asset managers. 15.44. -Since August 2008, approximately 43 external asset managers were responsible for independently managing at least one U.S. client account held at EIR Switzerland. SIR Switzerland compensated certain of these external asset managers for the business they generated for the Bank based on a negotiated fee structure. ,111, +Sr-Relationship managers typically communicated via telephone, fax, business email, and mail (when clients did not request hold mail services) with certain of their clients in the United States. Certain relationship managers also met with U.S. clients outside of the United States to provide banking services and investment advice related to their undeclared accounts. On at least one occasion, a relationship manager traveled to the United States after August I, 2008 and met with an existing U.S. client to discuss the client's accounts. METHODS USED TO CONCEAL ASSETS AND INCOME 46.-EdR Switzerland offered a variety of traditional Swiss banking services that it knew would and did assist U.S. clients in concealing assets and income from the IRS. One such service was hold mail. For an annual fee, the Bank would hold all mail correspondence for a particular client at the Bank. At least 352 U.S. accounts utilized Edit Switzerland's hold mail services. These services allowed U.S. clients to eliminate the paper trail of undeclared assets and income held at Edit Switzerland back to the United States. la -The Bank also offered code name or numbered account services. For an annual fee, it allowed U.S. accountholders to keep their names seeretgif of account stattments Commented (VD]: Iteo Bat nxonls reflect the names of accountholdortAntb000liclalownort. ancLather_documentation received from the Bank. In lieu of keeping-records Vitsina Tcen Inreferring_to the U.S. ellentlscllent by name, the Bank would use a secret code name 201512-14 10 34.00 or number. At least 198 U.S. accounts utilized EdR Switzerland's code name or numbered account services. These services allowed U.S. clients to conceal their names from bank records which would otherwise document the undeclared assets and income they held at Edit Switzerland. Commented (VIA]: seepawn_Mom Mite wetetto 48.•EdR Switzerland relationship managers assisted U.S. clients in opening and montane wrapper accounts for US dionnotthesank Virgnia Tent maintaining bank accounts in the names of non-U.S. structures end-non-Unch 2015 12-14 10.36:00 Page 4 of II December 4014, 2015 EFTA01090701  insobance-companies. In total, approximately 42% of the Bank's U.S. client accounts that were open on or after August I, 2008 were nominally held in the name of offshore entities. These accounts held approximately 61% of the total U.S. client assets at EdR Switzerland during the Applicable Period. a VIA-At least mgidff Switzerland relationshin manager coordinated with og commented ran WIALLawarssfsatlassamaducuo RDA coordinated with external advisors m satuo slicking external trust company to create and administer an offshore stroirtitre staxture b Slacapora • room Sawed at SPOMOOlse Incorporated in Singapore EdR Switzerland relationship managers eeordifrated Virginia Tent 3015.13.141015:00 withal% had reason to know that It S. clients used external trust companies and attorneys to create and administer effsitere-structures incorporated or based in offshore locations such as the British Virgin Islands, Panama, and Liechtenstein f„r It. U.S. clients. Because Swiss law requires Edit Switzerland to identify the true beneficial owner of structures on a document called a Form A, it knew that these were U.S. client accounts. Nonetheless, for certain U.S. client accounts, Edit relationship managers and other employees knowingly accepted and included in EdR Switzerland's account records IRS Forms W-8BEN (or EdR Switzerland's substitute forms) provided by the directors of the offshore companies that falsely represented under penalty of perjury that such companies were the beneficial owners, for U.S. federal income tax purposes, of the assets in the EdR Switzerland accounts. This aided and assisted the U.S. clients in concealing these assets and income from the IRS. 20:-EdR-SivItzerland2s-At least one relationship managers aided andmonoug assisted at-least-tbreenys U.S. clients within closing their undeclared accounts at the Bank by plaeing-andirtitimainitto their-assets-ht-iteeonnis-ltehl-itt-the-staittes-of It.., U.S. /Ravi attee-eomparties-amttrot-thenetnal-iterngieialbssiter-of the funds (hntswit-eolloquialls-its-int-qnstiranee-wriqnser',-)TAtklitionallyrittleast one rehithmstrip managt, assisted a U,S-elient-itt-elositro-his-undeektretateortitt-at the-Bank* opening up a tievrattountat-the-Bank-and-transferrittrbriefly opening up new nominative accounts at the Bank. which permitted them to transfer funds from the new ateountincounts to an-insurance wrapper rteeottittoccounts in Liechtenstein. Insurance wrappers were marketed to Swiss banks, ineintlittg-te-E4R-Swittertantl-li S clients by third-party providers in the wake of the UBS investigation as a means of disguising the beneficial ownership of U.S. clients. By the operation of Swiss bank secrecy laws, the U.S. client's ownership commented WM]: seecommentOn para. U and BPER000901 Virginia Tent would not be disclosed to U.S. authorities, including the IRS. 3015.13.14103):00 12, 24rEdR Switzerland employees assisted U.S. clients in covertly repatriating offshore funds by providing credit cards, cash cards, and debit cards linked to their undeclared accounts, including three types of cards issued by American companies. These services allowed U.S. clients to withdraw funds remotely or pay for goods and services without a paper trail back to their undeclared accounts in Switzerland. The bank issued such cards to at least 24 U.S. account holders at the Bank. a 2.2rEdR Switzerland relationship managers assisted numerous U.S. clients in structuring transfers from their undeclared accounts in amounts less than $10,000 to Page 5 of II December .11414. 2015 EFTA01090702  avoid detection by U.S. authorities. This conduct assisted U.S. clients in avoiding United States currency transaction reporting requirements. For example, after numerous discussions with one U.S. client regarding his intent to covertly repatriate Commented NT7]: See BPER000889 OPERC001190. The cent deterrn-ned how he would dispose of the a%ets to close out the his undeclared account funds, an EdR Switzerland relationship manager issued a series account, Mr. Ballenegger assisted him ta e..ecuting (gamut-lions. of checks in the amount of $8,500 made out to the U.S. client drawn on EdR Virginia Tent 2015.12.1411}17:00 Switzerland's bank account at UBS in Switzerland. The same relationship manager also assisted this U.S. client in withdrawing $11,000 in cash before re-depositing $2,000 based on "customs limitations." a 2&-EdR Switzerland relationship managers assisted numerous U.S. clients in covertly repatriating their undeclared account funds with large cash withdrawals. Between August I, 2008 and May 2014, the Bank allowed at least 53 U.S. clients to make at least 155 cash withdrawals of $30,000 or more totaling more than $20.68 million. In one instance in August of 2011, the Bank allowed a U.S. client to close his account by making a single cash withdrawal in the amount of $2.53 million. 24.-EdR Switzerland relationship mangers assisted U.S. clients in covertly repatriating their undeclared account funds by purchasing luxury goods. This allowed U.S. clients to convert their undeclared accounts funds into small, transportable items of value that are difficult to trace. For example, in one instance, after numerous discussions with a U.S. client about how hestaulienakiendra to close his account and covertly repatriate his undeclared account funds, an EdR Switzerland relationship manager assisted this U.S. client in transferring 145,000 Swiss francs to the Swiss UBS account of a luxury watch maker. 26 25.-EdR Switzerland relationship managers assisted U.S. clients in closing their accounts and covertly repatriating their undeclared account funds via transfers to the foreign bank accounts of non-U.S. friends, relatives, and business associates. For example, one relationship manager noted the following about his discussion with a U.S. client: Telephonic contact with the account holder. Explained to him the situation with respect to U.S. citizen account holders. Asked what to do. Suggested to him to make a donation to his wife. Commented (VT8]: With respect to the second example included, the person who wrote the note was a relationship manages assistant - not a relationship manager. See dtscriptlers Another-relarionship-manager-made this-note-in-her-idea of account 100031 at OPER000899. Please note, moreover, mat thei assistant claims that it was the niece who made the sughtestonof a donation, although the note asoll is not totuoly clear. Explakbed4o-Kke-nitheefeeeneeduo-close-the-oecount Vligna Tent Klieot-rosidin-in-USAYancl-onipossible-solation-transfer-of 2015.12.1411.03:00 acenuatue-a-per-son-itot-reddentin-the-USA, 27.26.-In one instance, a U.S. clientthe representative of a Panamanian company CalvetMed atillOSIBBAMPSIOLGARMA MBE= accountholder told EdR Switzerland that he had-awas the "man of confidence" in Virginia Tont Switzerland and-wantedallfor the beneficial owner of the account, whom he 2015.12-1410/0:00 identified as a non-U.S. citizen resident in the U,S. ALI communication regarding his account to-gowent through thistersomthe "man of confidence." Even though no one Page 6 of II December 40112015 EFTA01090703  at the Bank had ever met the L'Fitan-of-eonlithweebenelicial owner..-2 an EdR Switzerland relationship manager assisted the 1-:„Nrelient"man of confidence" in closing histhe company account and novertlreparriating-kis-uncleclared-accoant funds-by-transferring the balance to the Swiss-bank-account-olhinian-of confi4eoce.=seman of confidence's" account at another Swiss bank. In other instances, EdR Switzerland relationship managers assisted U.S. clients in closing their accounts and covertly repatriating their undeclared account funds by opening up new accounts at the Bank for family members and then transferring the balance of the U.S. client's undeclared account into the newly formed bank accounts of their non-U.S. relatives. EDR SWITZERLAND SUBVERTED ITS QUALIFIED INTERMEDIARY AGREEMENT 3& 27.-Effective in or about January 2001, EdR Switzerland entered into a Qualified Intermediary ("QI") Agreement with the IRS. To comply with its responsibilities as a QI, EdR Switzerland introduced a new form titled "Declaration ofU.S. Status / or / Non-U.S. Status in relation to assets and income subject to United States withholding tax" ("ONUS"). EdR Switzerland required all new and existing account holders to complete a DNUS form. It required all clients to self-cenify whether they were or were not U.S. persons. lithe U.S. client provided EdR Switzerland with a validly signed IRS Form W-9, then the client could hold U.S. securities and ErIR Switzerland would conduct Form 1099 reporting in respect of any reportable amounts, in accordance with the terms of its QI Agreement with the IRS. If the U.S. client did not provide a Form W-9, then FIR Switzerland prohibited the client from holding any U.S. investments, in accordance with the QI Agreement, and the client's name was not provided to the IRS. 29.28.-As a consequence of EdR Switzerland entering into a QI Agreement with the IRS, certain relationship managers and supervisory relationship managers encouraged and allowed U.S. clients to create and open accounts in the name of 'sham offshore entities Commented (MOD Manama Virginia Teat and-insuranc-e4.4appeps. In connection with these accounts. EdR Switzerland 2015.12.14 10A1:00 employees knowingly accepted and included in its account records IRS Forms W- SBEN (or EdR Switzerland's substitute forms) provided by the directors of the offshore companies that falsely represented under penalty of perjury that such companies were the beneficial owners of the assets in the accounts for U.S. federal income tax purposes. 39-Certain relationship managers and others assisted U.S. clients in executing forms that directed EdR Switzerland not to acquire U.S. securities in their accounts. The purpose of such forms was to avoid EdR Switzerland having to disclose the identities of U.S. clients to the IRS under its QI Agreement. 31.30.-Certain relationship managers, supervisory relationship managers, and others caused EdR Switzerland to certify compliance with the QI Agreement even though the true beneficial owners were not reflected in the IRS Forms W-8BEN in the account Page 7 of II December 4014, 2015 EFTA01090704  files. EDR SWITZERLAND'S EXIT OF ITS U.S. CROSS-BORDER BUSINESS 32.31-Beginning in mid to late 2008, in the wake of the UBS investigation and deferred prosecution attreement. EdR Switzerland instituted policies that were intended to I4mU its-potential-criminaLantLeMl-ta-x-liakilitvensure compliance with U.S. laws. A 32rBeginning in approximately September 2008, EdR Switzerland instituted a formal policy prohibiting relationship managers from opening new accounts for U.S. clients unless the U.S. client first provided a Form W-9. This policy applied irrespective of whether the U.S. client wished to hold U.S. investments. Thereafter, SIR Switzerland declined to open accounts for certain prospective U.S. clients who refused to provide a Form W-9. a 33:-Beginning in May 2008, SIR Switzerland's management formally advised relationship managers and other Bank employees against traveling to the United States for business reasons and required employees to report to the Executive Committee any planned U.S. travel. In January 2009, EdR Switzerland formally prohibited relationship managers from making business trips to the United States. A 34.-Recognizing that certain accounts had been opened under prior policies without a Form W-9, EdR Switzerland instituted a legacy account remediation project beginning in October 2008. Thereafter, EdR Switzerland affirmatively required every existing U.S. client account to provide a signed, valid Form W-9, regardless of whether the U.S. client's account held U.S. securities. If the existing U.S. client did not provide a Form W-9, Edit Switzerland eventually terminated the account relationship. Although these policies did remediate most of its undeclared U.S. accounts, not all such accounts were immediately closed. With few exceptions, EdR Switzerland had successfully exited most of its undeclared U.S. client accounts by the end of 2011. EdR Switzerland closed approximately 41441§ U.S. accounts between August I, 2008 and June 30, 2014, totaling approximately $7044= million. Many of these U.S. accounts were closed in connection with EdR Switzerland's remediation efforts. 16. AS-Beginning in October 2008, EdR Switzerland adopted a policy of encouraging U.S. clients who had undeclared accounts to declare those accounts to the IRS. Under this policy, relationship managers and Bank management proactively encouraged U.S. clients to make a voluntary disclosure to U.S. authorities, through the IRS's Offshore Voluntary Disclosure Program ("OVDP") or otherwise, if and when EdR Switzerland has learned ofa client's non-compliance with U.S. tax obligations. However, EdR Switzerland identified one relationship manager who violated this policy by discouraging U.S. clients from declaring their accounts. Page 8 of II December 4014. 2015 EFTA01090705  36.-In July 2012, EdR Switzerland began requiring all new and existing U.S. clients to provide a signed FBAR or other proof of U.S. tax compliance since the opening of the U.S. client account, such as evidence of participation in an OVDP. EDR SWITZERLAND'S COOPERATION THROUGHOUT THE SWISS BANK PROGRAM 3& 3-7rIn December 2013, EdR Switzerland entered into the Department of Justice's Swiss Bank Program as a Category 2 bank. a 38rSince 2013, EdR Switzerland has cooperated with the Department of Justice to comply with the Swiss Bank Program. At the outset, EdR Switzerland formed a Steering Committee consisting of EdR Switzerland representatives and U.S. and Swiss law finn partners who, along with independent accountants, oversaw and executed each phase of Program compliance. Along with its outside advisors, EdR Switzerland established a multi-tiered review protocol to identify and analyze all U.S. accounts in accordance with the Program. Specifically, the Bank, with the assistance of U.S. and/or Swiss counsel and/or its independent accountants, performed an electronic search of U.S. indicia across all of its accounts, manually conducted a full paper record search of hundreds of physical account files, analyzed relevant management policies, interviewed dozens of current and former relationship managers and members of management, reviewed relevant paper and electronic communications, and contacted hundreds of current and former U.S. clients or their representatives, among other efforts. 39.EdR Switzerland has devoted significant time and effort to convince certain U.S. clients to participate in the OVDP, including through in-person meetings and numerous follow-up discussions to ensure that those individuals follow through on the commitment to enter the OVDP. To date, at least 1401112 of EdR Switzerland's U.S. clients, totaling approximately S3-1.17/ million in assets under management, have participated in the OVDP as a result of the Bank's efforts. 41.40.-Throughout its participation in the Swiss Bank Program, EdR Switzerland has made comprehensive disclosures regarding its U.S. craw-border-busrnessreJattd accounts.. Specifically, EdR Switzerland, with the assistance of U.S. and Swiss counsel, forensic investigators, and in compliance with Swiss banking secrecy and privacy laws has: a. Obtained waivers of Swiss banking secrecy and data privacy protections from 3.14395 current and former U.S. clients, which permit EdR Switzerland to disclose account information to the Department of Justice; b. Provided actionable information concerning numerous U.S. client accounts held at SIR Switzerland since August of 2008 permitting the Department of Justice to make treaty requests to the Swiss competent authority for U.S. client account records; Page 9 of II December 1-9 4.2015 EFTA01090706 c. Described in detail tbe-stnretore-ofinformation about EcIR Switzerland's U.S. cross-border business, which included but is not limited to: (I) the policies or lack of policies that contributed to misconduct committed by relationship managers, supervisory relationship managers, and Bank management; (2) the supervisory chain overseeing relationship managers; and (3) the names of senior management and legal and compliance officials; d. Provided detailed information concerning the operation of its U.S. cross-border business, which included but is not limited to: (1) misconduct committed by EtIR Switzerland; and (2) names of relationship managers who committed misconduct; e. Provided the names and information of key external asset managers who made significant contributions to the operation of Er1R Switzerland's U.S. cross- border business as well as the relationship managers who assisted those external asset managers; and f. Provided responsive, specific, and actionable information to the Department of Justice concerning associated persons, entities, and areas of concern for use in other ongoing and potential DOJ investigations. Page 10 of II December 4014, 2015 EFTA01090707  Summary report: Liana Change-Pro TDC 7.5.0.145 Document comparison done on 12114/2015 11:08:37 AM Style name: L&W without Moves Intelligent Table Comparison: Active Original DIMS:iw://US-DOCS/NY/7441487/1 Modified DMS: iw://US-DOCS/NY/7441487/2 Changes: Add 92 Delete 84 lime Irt 0 Vlore 7o 0 Table Insert 0 Table-Delete 0 Table moves to 0 Table-MOV6S-frem 0 Embedded Graphics (Visio, ChemDraw, Images etc.) 0 Embedded Excel 0 Format changes 0 Total Changes: 176 EFTA01090708