Trust Technology & Support Services

Securities Processing and Vault Services

Controls
Name Controls for Free Receiving Physical Securities
Subject Matter Expert Anne Potkay
Last Approved By Mary Forgy Date Last Approved 7/20/09
Last Reviewed By Anne Potkay Date Last Reviewed 6/16/09
Related Policies, Performing SIC inquiries and reporting, Asset Funding (Physical), Asset
Procedures, Process Flows Funding Third Party (Physical)

Purpose

Document the control environment surrounding activity within the process of free receipt of physical
securities.

Roles and Control Responsibilities

Responsibilities and tasks are assigned within the Physical Processing and Vault Services teams to
create or enhance the control environment, thereby mitigating risks associated with this activity. Duties
are segregated so that proper oversight is provided, either by management or across teams. The Vault
Services team does not have access to SEI asset receipt functions.

Management Responsibilities
The management of Trust Securities Services is responsible for the following:
o Providing oversight and guidance to the team members listed above
o Monitoring the status of the daily DTC Position Reconciliation report
o Determining the appropriate staffing levels within the teams
o Establishing policies and procedures to be used by the processing specialists
o Periodically reviewing and updating procedures
o Training newly hired staff on all procedures, and training all staff when procedures are changed
o Reviewing SEI model access to ensure appropriate separation of duties on a quarterly basis
o Verifying that SIC check was performed or that exclusion is noted
o Reviewing Vault Access list to ensure proper vault security controls on a quarterly basis

Responsibilities of Vault Services Specialists

The Vault Services Specialists are responsible for the following activities:
o Opening and delivering all incoming UPS mail, and recording date received, tracking number,
description of contents, associated account number, and who the package was delivered to
o Creating logs on the Trust Securities Services Requests (TSSR) database and assigning a
physical processing specialist
o Changing location code to vault location if deposited in vault
o Preparing UPS labels

Responsibilities of Physical Processing Specialists

The Physical Processing Specialists are responsible for the following activities:
o Reviewing the certificate and attached documentation to determine if they are in good delivery
order

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 o Performing a SIC check if applicable in accordance with the SIC procedure
o Reporting any hits to SIC or its designee
o Running the registered owner name through OFAC screening in accordance with the OFAC
Screening policy
o Determining if the certificate is eligible for deposit to DTC
o Sending to transfer agent for re-registration if applicable
o Entering free receives using CASH ACCE on SEI.
o Verifying receipt at DTC and changing location codes on SEI accordingly.
o Entering DTC deposit tickets
o Clearing asset breaks associated with deposits as identified on the DTC Position Reconciliation
report

Controls and Process Flow Description

The following controls are identified and documented in various Securities Processing and Vault Services
and Trust Technology & Support Services procedures, workflows, and policies.
o Management review of SEI products and access
o Recording incoming UPS mail information by vault services team
o Checking all securities on the Securities Information Center (SIC) database that do not qualify for
exclusion or exemption
o Verification by manager or officer that SIC check was performed or exclusion noted within five
business days of receipt
o Reporting any previously reported lost or stolen certificate to SIC or its designee
o Manager signoff on registration instruction letter
o Verification of registration authorization by a Secondary Physical Processing Specialist
o Checking of DTC deposit instructions by a Secondary Physical Processing Specialist
o Review of all outgoing documents and certificates by a Secondary Physical Processing Specialist
o Monthly audit of location 237 items
o Management review of the DTC Position Reconciliation report

Process and Escalation

Process

Role
Securities Processing and Vault
Services (SP&VS) Team Manager
Vault Services Specialist
Accountability
1. Reviews SEI function models and the users in each of the
models, as reported quarterly by TPC (Trust Production
Control), and ensures that the product access within each
model is appropriate for the role, and that all SP&VS team
members are in the correct models. Makes note of
deletions, corrections, and additions, and returns them to
TPC.
2. Receives physical securities mailed from branch offices
via UPS. Opens UPS mail and records relevant information
regarding the package the UPS Tracking Log stored in the
UPS Tracking folder on the shared drive.

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Role
Vault Services Specialist
Physical Processing Specialist
Physical Processing Specialist
Securities Services Manager/Officer
Physical Processing Specialist
Secondary
Physical Processing Specialist
Physical Processing Specialist
Physical Processing Specialist
Securities Services Manager/Officer
Accountability
3. Creates a log on the Trust Securities Services Requests
(TSSR) database for the incoming certificates and assigns a
Physical Processing Specialist. Delivers the certificates to the
assigned physical processing specialist.
4. Determines if certificate meets the criteria by which an
inquiry on the SIC database is necessary. If excluded
from SIC inquiry, creates an account note on the log on
the TSSR database noting the specific exclusion. If not,
performs the inquiry and attaches the result to the log on
the TSSR database. This must be done within 5 business
days of receipt of the asset.
5. Reviews the certificate and attached documentation to
determine if they are in good order for deposit to the vault
or DTC.
° If the certificate and attached documentation ARE NOT in
good order, notifies the account administrator as to what is
needed, and checks the box on the log for “awaiting
paperwork”.” The physical processing specialist posts a
CASH ACCE at location 237 (in process) on SEI and the
certificate is held in the vault until required paperwork is
received. Show evidence to Physical Processing Manager
that SIC inquiry was performed within five business days or
that the applicable exemption was noted in the TSSR
database log.
° If the certificate and attached documentation ARE in good
order, the physical processing specialist posts a CASH
ACCE at location 237 on SEI and performs OFAC check
using the “Blocked Entity Search” on USBnet if the
certificate is to be deposited to DTC. Show evidence to
Physical Processing Manager that SIC inquiry was
performed within five business days or that the applicable
exclusion was noted in the TSSR database log.
6. Initials supporting documentation when SIC inquiry or
exclusion note is verified.
7. For DTC deposits, prepares the certificates and
accompanying documents for deposit and enters deposit
tickets on DTC.
7a. Prints a DTC deposit manifest. Reviews all documentation
to make sure that all the appropriate stamps and signatures
have been acquired, the applicable OFAC screening was
performed, the SIC inquiry was done and verified by manager,
and the deposit information was entered correctly on DTC.
Seals the certificates in a UPS envelope for mailing to DTC.
7b. Monitors DTC activity, and when the shares have been
deposited to US Bank’s DTC participant account, changes the
location code to 16 on SEI and closes the TSSR log.
8. For vault deposits, determines if re-registration is
necessary and if so, prepares an instruction letter for the
transfer agent, and forwards it to the department manager or
compliance officer for approval.
8a. Reviews the instruction letter for accuracy in registration
and direction. Signs and returns the instruction letter to the
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Role
Physical Processing Specialist
Secondary Physical Processing
Specialist or Securities Services
Manager/Officer
Vault Services Specialist
Physical Processing Specialist
Vault Services Specialist
Physical Processing Specialist
Securities Services Manager/Officer
Physical Processing Specialist
Vault Services Specialist
Vault Services Specialist with a
Physical Processing Specialist
Physical Processing Manager
Physical Processing Manager
Accountability
Physical Processing Specialist.
8b. Makes two copies of the signed instruction letter; one for
the records to be filed, and one to attach to the UPS envelope
for secondary review. Forwards the original signed instruction
letter, the certificate and accompanying documents and the
instruction letter copy to a Secondary Physical Processing
Specialist for review.
8c. Reviews the certificate and related documents for
appropriate stamps, signatures, and SIC screening verification
by manager, and places all original documentation in the UPS
envelope and seals it, initials the extra copy of the instruction
letter, and forwards the instruction letter copy and sealed
envelope to a Vault Services Specialist.
8d. Prepares the UPS mailing label.
8e. Proofreads all UPS mailing labels against the delivery
instruction cover letters.
8f. Records the UPS tracking number, name of sender, and
addressee on the “Outgoing UPS” spreadsheet stored in the
UPS Tracking folder on the shared drive. Stores and retains
the initialed instruction letter in a daily file.
8g. When the certificate comes back in proper registered form,
the Physical Processing Specialist updates the TSSR log to
reflect date received, and that the new certificate is excluded
from SIC inquiry having come directly from the transfer agent,
and shows evidence of such to Physical Processing Manager
or Compliance Officer.
8h. Verify the account note was added to the log within five
business days stating that the new certificate received was
excluded from SIC inquiry and initial the documentation
submitted.
8i. Places the certificate and accompanying documentation in
the “forward to vault” tray.
8j. Along with a Physical Processing Specialist (for dual
control), compares the certificate to be deposited to an SEI
position screen print to ensure accuracy of the SEI record and
verifies manager’s/officer’s initials on the documentation.
Changes the location code to the appropriate vault location
and files the certificate in accordance with normal vault
safekeeping procedures.
9. Along with a Physical Processing Specialist (for dual
control), audits location 237 monthly by comparing all the
assets as listed on an ad hoc location 237 report to the
physical folders on the location 237 shelf in the vault. Notes
discrepancies on the report and forwards them to the Physical
Processing Manager.
9a. Determines whether the discrepancies are true
exceptions, and makes a notation next to the item on the
report. For those that are true exceptions, the Physical
Processing Manager assigns the exception the appropriate
Physical Processing Specialist to take corrective action, and
then follows up to ensure that the exception was cleared.
10. Reviews all “PP” exceptions shown on the DTC asset
reconciliation report that is produced the next business day. If
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Role
Physical Processing Manager
Escalation
If … (circumstances)
There are SLA failures
Manager/officer initials are not on
accompanying documentation
verifying SIC check
DTC exceptions age greater than 10
days
DTC exceptions age greater than 30
days
DTC exceptions age greater than 90
days
There is an error resulting in the
purchase of shares or cash
compensation
The certificate has been reported lost
by SIC and verified by the transfer
agent
Accountability
correction is required, assigns the exceptions to the
appropriate Physical Processing Specialist to resolve.
11. Pulls ‘Asset Funding’ report from the TSSR database
within the first 10 days of the month for SLA achievement level
from the prior month.
Then … (who does what)
The Physical Processing Manager determines the cause of the
failure and takes appropriate action with the specialist responsible.
The specialist returns to the initiating specialist to obtain proper
verification.
The SP&VS Team Manager requires explanation from the
Physical Processing Team Manager.
Explanations are reported to Site Manager and Group Manager for
Trust Securities Services.
Exceptions are reported to Risk Management
The SP&VS Team Manager requires an explanation from the
responsible Team Manager and completes the Write Off and
Compensation Claim form. The Write Off and Compensation form
is approved by the Site Manager
The Physical Processing Specialist notifies the Physical
Processing Manager. Physical Processing Manager completes
form X-17F-1A and sends to the designated authority.
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