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EFTA01394829

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Reputational Risk Memorandum — CAF — NAVARRO 1. Sponsorship and referral Business Division(s) involved: DB Private Wealth Management Global Unit Sponsor: Fabrizio Campelli Unit Sponsor: Patrick Campion Deal Sponsor (MD minimum): Joanne Jensen Committee/Unit, requesting referral: Principal business contacts: Joanne Jensen, Jessica Wilbur 2. Statement of matter There are three points to be considered by the CAF: 1) Sherman Financial Group — RDC alert, 5/2014 — Press release from NY State Attorney General detailing a settlement due to filing debt collection actions outside of the required statute of limitations, $175K (see "RDC Sherman_NY" attached) 2) Resurgent Capital — Article found in internet search, 7/11/2012 — Baltimore Business Journal article detailing a voluntary settlement between Resurgent Capital and the Maryland State Collection Agency regarding debt collection cases, $1MM (see "Article_Resurgent BBS" attached) 3) Resurgent Capital - RDC alerts and research — included 2 settled court cases, which are due to the nature of the entity's business, distressed consumer debt: • NY, 2013 - Resurgent pays $50K for mortgage license violation and agrees to get/stay in compliance with state laws (see "RDC Resurgent NY" attached) • AZ, 2014 - Resurgent pays 595K for a disclosure violation on license renewal applications and a mislabelled trust account and agrees to get/stay in compliance with state laws (see "RDC Resurgent AZ" attached) 3. Rationale for referral Research was run on all relevant parties and generated most of the aforementioned material. Given the timely nature of the subject transaction (detailed in point 7), we flagged these points to Andrew Gallivan and Kim Hart and a CAF meeting was recommended. 4. Statement of support We confirm that Andrew Gallivan has reviewed the financial and non-financial risks of the transaction, including the reputational risks, and supports proceeding with the transaction. 5. Impact DBAG, DB

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