Bank of America Real Estate Services: Compliance & Operational Risk Training

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1 Bank of America Real Estate Services: Compliance & Operational Risk Training Space Sharing U.S.-Based Employees In this chapter, you will learn about Space Sharing. This includes: * Definition of space sharing * Space-sharing requirements * Real Estate Services space-sharing process By the end of this chapter, you should be able to: * Define space sharing. * Identify the three space-sharing requirements. * Explain the Real Estate Services space-sharing process. What Is Space Sharing? Space sharing is a vital element of Bank of America's Information Wall Policy. An information wall is a formally documented information barrier designed to prevent the inappropriate use or transmission of Material Non-public Information (MNPI) and protect the integrity of the financial markets. * Employees who require access to MNPI to perform their roles are referred to as working on the private side of the wall. * Employees who do not require access to MNPI are referred to as working on the public side of the wall. To protect MNPI, employees who work on the private side of the wall typically should not share the same office space with employees who work on the public side.

2 What Is Space-Sharing Risk? The Information Wall Policy is designed to protect MNPI and ensure that only authorized employees have access to sensitive information. Noncompliance with the bank s Information Wall Policy could lead to space-sharing risk, which includes: * Jeopardizing the integrity of the investment marketplace * Reputational risk * Regulatory violations including fines and Matter(s) Requiring Attention (MRA) If no space sharing risks are identified, CBRE Planning Team routes move requests directly to the Regional Implementation Team for execution. If there are potential space-sharing risks identified, then the CBRE Planning team validates the move request and engages a thorough compliance review. When a project request requires additional review, the Planning and Space Sharing Forum evaluates the move request and provides direction as needed. When all issues are resolved, the move request is routed back to the appropriate CBRE Regional Teams. It is important that CBRE employees follow the proper procedures to avoid consequences. Space-Sharing Components * There are established requirements pertaining to the flow of MNPI designed to prevent sensitive information from being transmitted or used inappropriately. * Whenever a wall-cross request is received, LOB/ECF compliance managers review the management reporting hierarchies involved to confirm the appropriateness of the request from a business perspective. * Physical and functional separation generally includes separate office space for private and public employees, limiting or restricting access to files, offices, computers and data, as well as separation of systems and back-office operations.

3 Space-Sharing Requirements * Information Walls Information walls are barriers designed to separate (or permit limited access to) computer systems, databases and recordkeeping for individual groups on the private side of the wall. When a private group must be co-located with a public group, all workspace should be physically segregated with restricted access. * Confidentiality Compliance All employees must adhere to the bank's compliance policies, which address requirements for specific rules and standards, as well as regulatory best practices for Information Protection and Code of Ethics. * Registered Employees When registered employees (such as broker-dealer, investment advisors or insurance groups) from different legal entities share space (with either private or public groups), there are specific FINRA, SEC and NFA regulations that apply regarding space, signage and regulatory filings. Information Wall Components Bank of America s Information Wall Policy contains three critical components. * Information Walls Functional Separation Some groups on the private side of the wall should not be co-located, thus creating walls within walls. This includes separate (or limited access to) computer systems, data bases and recordkeeping. Partial Co-Location When a group with MNPI access must be co-located with a public group, the physical space may be segregated. This includes separate key/card access to office space, file rooms, printing, fax machines, recycling bins, and copy and conference rooms. If the space cannot be physically separated, a written request for an exception to the policy may be submitted to the compliance representatives of the LOBs sharing space on the floor/suite in question.

4 * Confidentiality Compliance Bank of America is committed to protecting the confidentiality and integrity of our customers and the bank's confidential information. To protect MNPI, all employees must comply with the rules, standards and best practices outlined in the following: Information Security website Code of Ethics Policy * Registered Employees If registered employees from different legal entities (such as broker dealer, investment advisors or Insurance groups) are co-located (together or with a public group), there are specific Financial Industry Regulatory Authority (FINRA), Securities and Exchange Commission (SEC) and National Futures Association (NFA) regulations and other local regulatory requirements in non- U.S. markets that apply regarding the segregation of space, signage and regulatory filings. Employee concerns should be escalated through Advice and Council. Customers should be directed to Executive Relations or TPS_Executive_Relations@bankofamerica.com. Real Estate Services Space-Sharing Process The MAC Team receives move request Work Orders submitted by Lines of Business through FMS. MAC Team queues the Work Orders for CBRE Occupancy Planning Team solution. Occupancy Planning runs a space sharing test and determine if there is space-sharing risk. If no risk, the CBRE Planning Team forwards the approved requests to the appropriate market resources for execution. When a line of business submits a Move Request or a Project Request, CBRE Planning Team initiates a space sharing test to determine if there is space-sharing risk. If no risk, the CBRE Planning Team forwards the approved requests to the appropriate market resources for execution. When space-sharing risk is identified, a thorough compliance review is conducted by the Planning and Space Sharing Forum. The CBRE Regional Implementation Team oversees the implementation process and engages resources to execute.

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