Deutsche Bank Compliance / RECOMMENDATION The Dormant account rule cannot restrict specific transaction types (i.e. low risk transactions like internal transfers) to be excluded from the process. So, a weighted methodology for weekly/monthly sampling based on underlying transactions and risk class has been established. No new recommendations. http://compliance.intranet.db.com// 21 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0060602 CONFIDENTIAL SDNY_GM_00206786 EFTA01368697