MMMF Investment Policy Management

Table of Contents Overview.....................................................................................................................................................................4 How to Set Up MMMF Investment Policy Limitations.......................................................................................5 Setting MMMF Investment Policy Scenarios.......................................................................................................9 Maker Checker Functionality..................................................................................................................................11 Override Setup, E-mail Alerts & Maker Checker User Roles..........................................................................13 Override Feature..................................................................................................................................................... 14 Trade Override Approval........................................................................................................................................17 E-mail Alert Functionality..................................................................................................................................... 18 Additional Purchases: Sweeps, Future Dated, Bulk Upload & Dividend Recapitalization..........................19

Scheduled Sweep Purchase........................................................................................................................... 19



Future Dated Purchase................................................................................................................................... 19



Bulk Upload Purchase..................................................................................................................................... 19



MTD Dividend Recapitalization..................................................................................................................... 19

MMMF Investment Policy Report....................................................................................................................... 20

Overview This section describes how to set up, modify and use the MMMF Investment Policy parameters for MMMF investment through Citibank® Online Investments (OLI). The MMMF Investment Policy feature creates modifiable controls that an administrator can set, in terms of fund amount limits or percentage of the fund that your investment makes of the AUM. It eliminates the need for someone manually having to monitor these controls once they are determined and set for improved risk control. This section includes the following: How to Set Up MMMF Investment Policy Limitations Setting MMMF Investment Policy Scenarios Maker Checker Functionality Override Setup, E-mail Alerts & Maker Checker User Roles Override Feature Trade Override Approval E-mail Alert Functionality Additional Purchases: Sweeps, Future Dated, Bulk Upload & Dividend Recapitalization —— Scheduled Sweep Purchase —— Future Dated Purchase —— Bulk Upload Purchase —— MTD Dividend Recapitalization —— MMMF Investment Policy Report

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How to Set Up MMMF Investment Policy Limitations Provided that you have already followed the steps for How to Open a Money Market Fund Account and How to Invest in a Money Market Fund, investment policy limits can be set up as follows: 1. Under the Administration heading, click on MMMF Investment Policy Management. 2. You will be presented with a screen on which you can either Create Investment Policy (if one does not currently exist) or Modify Investment Policy and will be presented with the following components. • When you Create Investment Policy, you will have a slightly modified screen that does not include the “Current Amount Limit of Fund” nor “Current % Limit of Fund AUM.”

• C  lient: You may choose to modify the investment policy for those clients or subsidiaries to which you have access by selecting the appropriate client from the drop-down menu. • Product Category: This will be prepopulated with MMMF. • I nvestment Policy Name: You may enter a policy name for your own purposes, possibly relating to a company-specific regulation or the date that the policy was drafted. • A  mount Limit of Fund**: Enter an amount for the limit of the fund. The amount that you enter will correlate to the currency of the fund. —— An investment limit can be removed by entering a zero value for the particular fund. A blank field is not permitted. —— See Setting MMMF Investment Policy Scenarios for additional information and examples.

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• %  Limit of Fund AUM** (Assets Under Management): Enter the maximum investment percentage limit to be as a portion of the AUM of the fund. —— An investment limit can be removed by entering a zero value for the particular fund. Blank is not permitted. —— See Setting MMMF Investment Policy Scenarios for additional information and examples. —— If a fund releases an updated AUM and subsequently the Investment Policy is now in violation, an e-mail notification will be sent. See Override Setup, E-mail Alerts & Maker Checker User Role and E-mail Alerts Functionality for additional information. **NOTE: If both the Amount Limit and Percentage Limit are populated, the system will consider the lesser of the two as the limit for the fund. • A  pply to All Products: Use this field at the top of the list of funds in order to apply a benchmark standard to all the funds. —— You must check the box next to “Apply to All Products” or you will receive an error message when you try to save stating:

—— If you select this option, it will present you with a warning message stating “The system will override existing limits. Do you want to proceed?”

—— After checking “Apply to All Products,” you may deselect boxes next to funds which you would not like to apply to all products.

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—— It is suggested to only use this function when Creating an Investment Policy and to Modify an Investment Policy at the individual fund level. —— Fund listing will include all funds to which you are entitled (NOT restricted to fund with which you have an open account). • V  erify Investment Policy Limit: Allows you to test the policy limits you have set or modified against the current investments for compliance. **NOTE: This does not save your changes but just allows you to reference the modifications against your current investments. —— The results of the verification will be displayed as follows, in line with the list of funds:

—— Possible statuses that you will see under Verify Investment Policy Limit

• Green — Within Investment Policy Limit



• Red — Out of Investment Policy Limit



• White — Investment Policy Limit Not Set —— To view trades executed in excess of the set Investment Policy limits, Investment Policy Report and Out of Policy Trades report should be used. (See MMMF Investment Policy Report for additional detail.)

• S  ave: Will save the changes that you have made to the policy. —— If the user is setting up policy limits that are less than the current outstanding balance of the fund, an informational message will be presented stating “The outstanding balance is already more than the Limit being set” and allow the user to continue.

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• Reset: Will reset the policy screen to the last saved version. • V  iew Changes: Allows you to review a history of the changes that have been made to the investment policy and includes the following information: —— V  iew Investment Policy via the icon to the left of status and is an expandable line that will show you the changes that were made to the policy for that modification. —— Status

• May say Approved, Revoked or Pending.



• If Maker Checker functionality is enabled, you may see Pending if awaiting approval or Revoked if the checker denied the change.



• If Maker Checker functionality is not enabled, the status will show Approved upon saving the changes. —— Investment Policy Name —— Nature of Change —— Changes Done At —— Changes Done By —— Approved At —— Approved By

To return to the Modify Investment Policy screen, click Close at the bottom of the pop-up window. 3. When you have completed all your desired changes, click Save at the bottom of the page. You should be presented with a message “Saved Successfully” on the same screen below the Save, Reset and View Changes buttons.

• The current values will be updated on the screen to reflect the new set of values.

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Setting MMMF Investment Policy Scenarios The Amount Limit and AUM percentage parameter checks are calculated each day, as well as when trades are being initiated. The Amount Limit per Fund parameter functions in the following manner: 1. Active Purchase above the limit User Defined Amount Limit per Fund = $250,000 Principal Balance across all the MMMF Active and Sweep Accounts = $125,000 Purchase Trade Amount = $200,000 In this example the Purchase Trade will bring Principal Balance to $325,000, which exceeds defined Amount Limit and will need to go through the Override process. (See Override Function.) 2. Active Purchase within the limit User Defined Amount Limit per Fund = $250,000 Principal Balance across all the MMMF Active and Sweep Accounts = $125,000 Purchase Trade Amount = $50,000 In this example the Purchase Trade will bring Principal Balance to $175,000, which is within the limits. 3. Dividend Reinvestment above Limit Amount will be allowed. The AUM Percentage Limit per Fund parameter functions in the following manner:

How AUM Percentage is calculated:

It is recommended to review the Percentage Limit check whenever the fund AUM is updated by the Fund Provider and reflected on the system. 1. Active Purchase above the limit User Defined AUM Percentage Limit per Fund = 2% AUM of Investment Fund = $10,000,000 Principal Balance across all the MMMF Active and Sweep Accounts = $125,000 Purchase Trade Amount = $200,000 In this example the Purchase Trade will bring Principal Balance to $325,000 and 3.25% of the total Fund AUM, which exceeds defined AUM Percentage Limit and will need to go through the Override process. (See Override Function.)

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2. Active Purchase within the limit User Defined AUM Percentage Limit per Fund = 2% AUM of Investment Fund = $10,000,000 Principal Balance across all the MMMF Active and Sweep Accounts = $125,000 Purchase Trade Amount = $50,000 In this example the Purchase Trade will bring Principal Balance to $175,000 and 1.75% of the total Fund AUM, which is within the limits. The Amount Limit per Fund in conjunction with the AUM Percentage Limit (both functioning simultaneously) functions in the following manner: 1. Active Purchase above the limit User Defined Amount Limit per Fund = $250,000 User Defined AUM Percentage Limit per Fund = 3% AUM of Investment Fund = $10,000,000 Principal Balance across all the MMMF Active and Sweep Accounts = $125,000 Purchase Trade Amount = $200,000 In this example the lower of the two limits set is the Amount Limit per Fund, for which the Purchase Trade would total $325,000. Therefore the Purchase Trade exceeds defined limitations and will need to go through the Override process. (See Override Function.)

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Maker Checker Functionality (for MMMF Investment Policy Setup) 1. Once the Maker Checker Process is entitled for MMMF Investment Policy Setup and an MMMF Investment Policy has been implemented, Makers will be able to submit changes to be approved by the Checker. • Approvals are also required for trades that are out of policy when this functionality is enabled. Please see Maker Checker portion in the MMMF trading guide for further information. 2. There are two avenues to access Pending Approvals: • NOTE: A pop-up alert and the Pending Approval tab will be provided for all users, regardless of whether they are a Checker. • When the Checker logs on to OLI, they should be presented with a pop-up notification, similar to the one below, informing them of the pending approval that requires their attention

• Click on the Pending Approval tab and then select the Investment Policy tab.

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3. The Checker can click on the link(s) of the policy that is pending approval to view and will be presented with a screen resembling:

• It will list the status in the top left corner and provide three options: —— V  iew Changes: Allows you to review a history of the changes that have been made to the investment policy. —— A  pprove: After confirming your action, approves the proposed Investment Policy changes, producing a “Changes Approved” message on the same page. —— R  eject: After confirming your action, rejects the proposed Investment Policy changes, producing a “Changes Rejected” message on the same page.

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Override Setup, E-mail Alerts & Maker Checker User Roles 1. Under the Administration heading, click on Assign User Parameters and will see a screen similar to below with the following options: —— For information on the Checker Parameters tab, please refer to the How to Invest in a Money Market Fund information.

• User Role Type: Allows the user to set the Maker, Checker(s) or select None. —— The selection of None will allow the user both Maker and Checker capabilities. • A  llow Investment Policy Override: This will allow a user the capability to trade above the Investment Policy Limits. —— Default is set to Yes. —— This must be set for BOTH the Maker and the Checker if Maker Checker Functionality is enabled. • S  end E-mail Alert: A notification e-mail will be generated to the user’s address on file informing that the MMMF Investment Policy limits have been exceeded. —— Default is set to Yes NOTE: In the case of Sweep and Future Dated trades, there is no setup for MMMF Investment Policy Override. Should a violation occur, an alert e-mail will automatically be sent. See Additional Purchases: Sweeps, Future Dated, Bulk Upload & Dividend Recapitalization for additional information.

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Override Function From the Deal Entry screen, following the instructions on How to Invest in a Money Market Fund, the user may enter a purchase amount that exceeds the MMMF Investment Policy Limits. There are three possible outcomes after proceeding to Confirm Order for an investment amount that exceeds the MMMF Investment Policy Limits: 1. In the situation where the user has capability to Override Limit and the current balance of fund is below investment limit, the user will see the following options displayed in a pop-up box:

• A  ccept This Amount: This option modifies the investment amount to the proposed by the system to remain within the MMMF Investment Policy Guidelines. —— In the example above, the investment amount would be modified to $84,464.12. • Enter New Trade Amount: Returns you to the Deal Entry screen. • O  verride Limit: Allows you to continue with the amount that was entered that exceeds the MMMF Investment Policy Limit. —— In the example above, the investment amount would be $200,000.00. —— The transaction would then show up in the Out of Policy Trades (See MMMF Investment Policy Report) NOTE: If E-mail Alerts (see Override Setup, E-mail Alerts & Maker Checker User Role) are enabled, all designated users will receive an e-mail alert notification that the MMMF Investment Policy has been violated.

• T  he user will then have to select Confirm Order after making the appropriate selection and will be able to proceed to the confirmation page to Place Order or Cancel Order. 2. In the situation where the user does not have capability to Override Limit and the current balance of fund is below investment limit, the user will see the following options displayed in a pop-up box:

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• A  ccept This Amount: This option modifies the investment amount to that which is proposed by the system that is within the MMMF Investment Policy Guidelines. —— In the example above, the investment amount would be modified to $84,464.12. • E  nter New Trade Amount: Returns you to the Deal Entry screen. • T  he user will then have to select Confirm Order after making the appropriate selection and will be able to proceed to the confirmation page in which they may Place Order or Cancel Order. 3. In the situation where the user does have capability to Override Limit and the current balance of fund is in violation of Investment Policy, the user will see the following options displayed in a pop-up box:

• E  nter New Trade Amount: Returns you to the Deal Entry screen. • O  verride Limit: Allows you to continue with the amount that was entered that exceeds the MMMF Investment Policy Limit. —— In the example above, the investment amount would be $200,000.00. —— The transaction would then show up in the Out of Policy Trades. (See MMMF Investment Policy Report.) NOTE: If E-mail Alerts (see Override Setup, E-mail Alerts & Maker Checker User Role) are enabled, all designated users will receive an e-mail alert notification that the MMMF Investment Policy has been violated. • The user will then have to select Confirm Order after making the appropriate selection and will be able to proceed to the confirmation page in which they may Place Order or Cancel Order.

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4. In the situation where the user does not have capability to Override Limit and the current balance of fund is in violation of Investment Policy, the user will see the following options displayed in a pop-up box:

• E  nter New Trade Amount: Returns you to the Deal Entry screen. • S  ince the user does not have override capabilities, they will not be able to invest in this fund since the limit has already been exceeded.

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Trade Override Approval If Maker Checker Functionality is enabled and the maker has the capability to enter a trade with the Override Function, the checker will still have to approve the trade. Both the Maker and Checker must have Override capabilities set. Please see Override Setup, E-mail Alerts & Maker Checker User Role for more information. When the trade is approved, a pop-up message will display: “The Trade being approved is allowed investment policy override. Do you want to Approve the trade?” and will present the options “OK” and “Cancel.” Please see Maker Checker portion in the MMMF trading guide for further information on the Maker Checker Process for trades.

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E-mail Alert Functionality An e-mail will be sent in the following circumstances: 1. If a violation of the MMMF Investment Policy occurs as a result of a purchase trade. 2. If a violation occurs as a result of a dividend reinvestment or fund AUM change. The notification will be sent at the beginning of the business day. The e-mail will look similar to the following:

Sender ID: [email protected]

Subject Line: MMMF Investment Policy rule breached in Citibank Online Investments Text: Please note that the trade booked for fund [fund name, fund #] breached user defined Investment Policy rules.

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For details view Investment Policy Tracking Report.



Do not reply to the sender e-mail ID.

Additional Purchases: Sweeps, Future Dated, Bulk Upload & Dividend Recapitalization Scheduled Sweep Purchase The Max Limit that is set at Sweep Rule level will still limit the amount that can be executed in a sweep trade, up to the limit that is set for that Fund, for an individual account. The MMMF Investment Policy Limit (amount limitation or percentage AUM limitation) is applicable to all accounts in a particular Fund. The MMMF Investment Policy Limit applies to all holdings across all accounts for a particular Fund and aggregates all holdings in the Fund to determine the maximum available. The system will determine which the lower of the two limits is: the Sweep Rule or the MMMF Investment Policy. It will then calculate the maximum available based on the current available and future dated trades. The sweep will execute for the calculated maximum available. Therefore, the Investment Policy will not be breached by the Sweep Purchase at any point. Please see Sweep and Trade History Report sections in the MMMF trading guide for further information.

Future Dated Purchase If the MMMF Investment Policy Limit is violated by an approved Future Dated transaction, an e-mail notification will be sent. Override amount will be displayed in the Trade History Report. See Override Setup, E-mail Alerts & Maker Checker User Roles for further information on e-mail alert settings. Please see Future Date Purchase and Trade History Report sections in the MMMF trading guide for further information.

Bulk Upload Purchase In the event of a Trade Bulk Upload, the MMMF Investment Policy check will be done upon upload. If the policy is breached, an error message will be displayed in the error file for corrective action to take place. Please see Bulk Upload Purchase in the MMMF trading guide for further information.

Dividend Recapitalization In the event of a Dividend Recapitalization purchase, if the MMMF Investment Policy is violated, the purchase will be processed and an e-mail notification will be sent. Override amount will be displayed in the Trade History Report and signified through a corresponding color code. See Override Setup, E-mail Alerts & Maker Checker User Roles for further information on e-mail alert settings. Please see Dividend Recapitalization and Trade History Report sections in the MMMF trading guide for further information.

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MMMF Investment Policy Report The MMMF Investment Policy Report is available for you to review all your open accounts, balances and MMMF Investment Policy Limitations. Under the Reports heading, click on Investment Policy Report.

1. You have the option to modify the report contents via these options: • C  lient: You may choose to view the investment policy report for those clients or subsidiaries to which you have access by selecting the appropriate client from the drop-down menu. • P  roducts: This will be prepopulated with MMMF. • C  urrency: You many choose to view all or a single currency in which you invest. • Additional information available in the report: —— Funds: Fund listing will include all funds with which you have an open account. • If you do not see a fund you expect to see in the list, refer to the section How to Open a Money Market Fund Account Some of the information displayed on the report include: • 1 Day Net Yield • Total Net Assets (MM) • Current Balance • Future dated trade balances • Total balance • % of Fund • % Limit of Fund 20

• $ Limit of Fund • Maximum Available • Trade • Out of Policy Trades 2. You also have the following options, located in the upper right-hand portion of the page to: • Export to Excel • Export to PDF • Print 3. Under the Trade heading, if you select the checkbox Entry page in order to enter a trade.

for that line item, it will take you to the Deal

4. Out of Policy Trades • By selecting “View” on the Investment Policy Report, the user will be navigated to a filtered Trade Inquiry report to display all policy overridden trades. —— It lists the Override Amount for you to review. This is the amount over the MMMF Investment Policy Limit that the trade was executed for. —— The screen display will color code the Amount of the trade and Override Amount for Out of Policy Trades. —— This DOES NOT indicate which funds are in or out of MMMF Investment Policy. To review the Funds in relation to current MMMF Investment Policy, refer to Verify Investment Policy Limit section of How to Set Up MMMF Investment Policy Limitations. • You also have the options, located in the upper right hand portion of the page to: —— Export to Excel —— Export to PDF —— Print

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