Dear Mr.

Andreas,

Further to this research, the following entities are required to

report CRS and FATCA reportable accounts:

*Financial entities (whether legal entity or legal arrangement such

as trust or partnership):
1. Custodial Institution (custodian banks, brokers, depositaries)
2. Depositary Institution (banks, savings/loan institutions, credit unions)
3. Investment Entity (funds, portfolio managers, investment trusts)
4. Special Insurance company (life insurance companies, insurance company making
payments on a Cash Value Insurance/Annuity contracts)

NON-REPORTING FINANCIAL INSTITUTIONS:

1. Government entities and their pension funds
2. International organizations
3. Central banks
4. Certain retirement funds
5. Qualified Credit Card Issuers
6. Exempt Collective Investment Vehicles
7. Trustee Documented Trusts
8. Other low-risk financial institutions

FATCA SCOPE:
-US Individual accounts
-US Entity accounts
-Passive NFFE accounts held by substantial US owners
THRESHOLDS:
-New Individual: USD 50,000
-Pre-existing individual: USD 50,000 generally and USD 250,000 cash value insurance
-Pre-existing entity: USD 250,000

CRS SCOPE:
-Individual and entity accounts held by residents of any participating jurisdiction
or passive NFFE's with controlling persons that are resident in any CRS
jurisdiction.
THRESHOLDS:
-With the exception of preexisting entity accounts, no thresholds applicable

CRS MANNER OF REPORTING:

In general, the Financial Institution shall report to Tax Authority through
a filing process as through a government portal. The data to be collected from
Reporting Financial institutions need to be available in the format of CRS
XML Schema. The Tax authority shall then send the report to the participating
jurisdiction of the individual/entity involved through the Common Transition
System (CTS). The CTS is a secure and encrypted �pipe�, complying with
the latest IT-security standards, through which Competent
Authorities can send and/or received information both over a
server-to-server link-up (SFTP) and in a browser-based manner
(HTTPS). This transmission system is (initially) available for
the exchange of information between Competent Authorities
pursuant to the CRS, Country-by-Country reporting and exchange on
tax rulings.