STATEMENT OF FACTS INTRODUCTION I. Edmond de Rothschild (Suisse) S.A. (together with its Lugano-based subsidiary, "EdR Switzerland" or the "Bank") is a corporation organized under the laws of Switzerland with its headquarters in Geneva, Switzerland. 2. EdR Switzerland operates a financial services business in Geneva, Lausanne, Fribourg, and Lugano, Switzerland. It offers private banking and wealth management services for individual clients around the world, including a relatively small number of U.S. citizens, legal permanent residents, and resident aliens. 3. EdR Switzerland is affiliated with the Edmond de Rothschild Group, an independent, family-controlled financial group focused on asset management and private banking. Edmond de Rothschild Group was founded in 1953 and currently operates in 19 countries worldwide. Edit Switzerland is an independent Swiss legal entity, led by its own board of directors, chief executive officer, and executive committee, and is supported by its own legal and compliance functions. 4. In 2014, the Edmond de Rothschild Group held Assets under Management ("AuM") totaling approximately $170 billion, out of which $44.0 billion comprised client assets managed in Switzerland. U.S. INCOME TAX & REPORTING OBLIGATIONS 5. U.S. citizens, resident aliens, and legal permanent residents have an obligation to report all income earned from foreign bank accounts on their U.S. tax returns and to pay the taxes due on that income. Since the tax year 1976, U.S. citizens, resident aliens, and legal permanent residents had an obligation to report to the Internal Revenue Service ("IRS") on the Schedule B of a U.S. Individual Income Tax Return, Form 1040, whether that individual had a financial interest in, or signature authority over, a financial account in a foreign country in a particular year by checking "Yes" or "No" in the appropriate box and identifying the country where the account was maintained. 6. Since 1970, U.S. citize