July 2022 Crypto Assets Call

MEMORANDUM TO FILE

DATE: July 26, 2022

TO: Files

THROUGH: Catherine H. Goñi
Assistant Regional Director

FROM: XXXXX
Trust Examination Specialist

SUBJECT: XXXXX - Crypto Related Assets Conference Call - Update

Attendees:

FDIC:
XXXXX
Trust Examination Specialist (TES)
XXXXX:
XXXXX
SVP & Wealth Manager
Operations Manager

On 7/21/2022, a conference call was held with trust department management to obtain an update on the previously reported (4/11/22 & 6/30/2022) crypto-related holdings held in client accounts. The call was intended to obtain clarification on the assets and clients reported in the 6/30/2022 letter and request the retention letters previously requested on the 6/28/2022 conference call.

Operations Manager XXXXX stated that the 4/11/2022 and 6/30/2022 correspondence to the FDIC and subsequent discussions inadvertently excluded a client directed holding in XXXXX held in the XXXXX account. SVP XXXXX clarified that there are currently three clients XXXXX that hold four crypto-related holdings. The crypto-related holdings are detailed on the table below.

TES XXXXX requested the bank provide the FDIC with retention letters for all three clients to substantiate they were client-directed purchases and are being retained with client direction. Operations Manager XXXXX sent TES XXXXX the retention letters for XXXXX on 7/22/2022 and requested a signed authorization from XXXXX on 7/21/2022. On 7/26/2022, Operations Manager XXXXX provided the FDIC with a signed retention letter from XXXXX although it was dated 7/27/2022. Additional email correspondence with XXXXX confirmed that the client utilized an incorrect signature date. Supporting email communication between the bank and the client evidence a receipt date of 7/26/2022. Attached

Memo to File
XXXXX

to this memo is documentation supporting the retention authorization for each of the three clients, and the email chain confirming the request and receipt of information from XXXXX XXXXX.

The table below summarizes what crypto-related assets the trust department holds upon client direction in client accounts. As of 6/27/2022, all of the accounts have been negatively impacted by the recent market environment.

Crypto-Related Asset	Account Name	Number of Shares	Cost As of 4/15/2022	Market Value As of 7/21/2022
XXXXX	XXXXX	XXXXX	XXXXX	XXXXX

XXXXXXXXXX

XXXXXXXX

XXXXXXXXXX

From: XXXXX
To: XXXXX
Cc: XXXXX
Subject: [EXTERNAL MESSAGE] RE: SECURE EMAIL: Crypto-related assets
Date: Wednesday, July 27, 2022 11:24:15 AM
Attachments: XXXXX

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XXXXX

Sorry, I looked at the retention letter before sending and I thought the date was 7/22/22. XXXXX actually sent the request to XXXXX on 7/21 through e-mail. XXXXX e-mailed back the letter on July 26, 2022. I have attached the e-mail stream as support.

Kindest Regards,
XXXXX

Originally sent by XXXXX on Jul 27, 2022 11:07 AM

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Good morning XXXXX

I just took a quick look at the retention letter you sent me yesterday, 7/26/2022. The date on the form is 7/27/2022 (today). Can you just send me a reply with the actual date you received the authorization from your client? We will place that notation in our files with the original copy you sent us.

Thanks!
XXXXX

From: XXXXX
Sent: Tuesday, July 26, 2022 1:52 PM
To: XXXXX
Cc: XXXXX
Subject: RE: [EXTERNAL MESSAGE] RE: SECURE EMAIL: Crypto-related assets

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Good afternoon XXXXX

We have received back the signed retention from XXXXX for the XXXXX I have attached for your reference.

Regards,

XXXXX

--- Originally sent by

XXXXX

on Jul 22, 2022 11:00 AM ---

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Thank you

XXXXX

I will take a look at the information provided and be sure to get back to you with any questions!

I hope you have a great weekend! Stay cool!

XXXXX

From:

XXXXX

Sent: Friday, July 22, 2022 10:45 AM To:

XXXXX

Cc:

XXXXX

Subject: [EXTERNAL MESSAGE] RE: SECURE EMAIL: Crypto-related assets

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XXXXX

Good morning! I have attached a holders report for each of the accounts that hold the Crypto-related assets. This report will show the cost and market and last activity date for the security. I have also attached the retention letters for

XXXXX

you may already have). We do not have a retention letter in the file for

XXXXX

. His last retention letter was November 2021 and the next would be November 2022. I have attached the 2021 letter so you can see that we actually do send one to him. I have attached the correspondence (3 e-mails) in the file related to the trade placed for

XXXXX

it shows his direction for the trade. In the meantime, I have requested that a current retention letter be sent to

XXXXX

to cover the Crypto-related asset, as you suggested would be best to have a current one.

It was really good meeting and speaking with you yesterday.

Please don't hesitate to contact me, should you need anything else.

Regards,

XXXXX

--- Originally sent by

XXXXX

on Jul 21, 2022 12:34 PM ---

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XXXXX Thanks again for meeting. You should be able to respond to this email and it will remain secure. In an abundance of caution just make sure the ‘SECURE EMAIL:’ remains at the start of the Subject line – delete anything that may precede it if possible!

Best,

XXXXX

Trust Examination Specialist, Division of Risk Management Supervision

Federal Deposit Insurance Corporation

15 Braintree Hill Office Park, Suite 200

Braintree, MA 02184-8701

XXXXX

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