THE 360 NEWSLETTER

Please be advised that the following improvements will be made to the KYP tool effective June 3, 2024.

1. To provide more detailed information, the KYP tile will no longer be displayed by the 80/20 split, but will now display new rows A, B & C, as shown below:

A. All Funds:

This row displays the number of red, yellow and green funds in your book which are part of the KYP due diligence evidence requirements (“KYP”). When any of these values are clicked, you will be directed to the “My Fund Listing” page, which displays all funds in your book and includes the KYP status of the fund:

B. Incomplete KYP:

This row displays the number of red, yellow and green funds in your book which are part of the KYP requirements but also have an incomplete KYP status. When any of these values are clicked, you will be directed to the “Funds with Incomplete KYP” page, which displays funds with either a “Reset” or “Never Completed” due diligence status:

C. Recently Traded Funds with Incomplete KYP:

This row displays the number of red, yellow and green funds in your book that are part of the KYP requirements which have been traded on in the past 6 months but have an incomplete KYP status. When any of these values are clicked, you will be directed to a new page: “Funds Traded within past 6 months with Incomplete KYP”, which displays the funds traded on in the past 6 months with either a “Reset” or “Never Completed” KYP status. The date of the last trade, impacted clients and type of transaction will also be displayed:

NOTE: As the KYP tile will now direct you to 3 different pages, you will have the option of completing the KYP due diligence process from any of those pages. The remaining pages will update accordingly.

2. The previous status options of Yes/No/NA in the “Due Dil Status” column displayed on the “My Fund Listing” page will be replaced with the status options below. Note that these options will also be applied to the new “Funds with Incomplete KYP” and “Funds Traded within past 6 months with Incomplete KYP” pages.

• Completed: The KYP has been completed on this fund and there has been no material changes since.
• Never Completed: The KYP has never been completed on this fund since it has appeared in your book.
• Reset: The KYP was completed previously but has since been reset due to a material change and requires re-review.
• N/A: A fund that is not applicable for KYP.

NOTE: When a fund with either a “Never Completed” or “Reset” due diligence status is selected from the “My Fund Listing” page and the KYP evidence is submitted, the due diligence status will be updated to “Completed” and updated accordingly on all the pages.

Should you have any questions or require additional information, please do not hesitate to contact your Compliance Officer.