SWIFT Standards Release 2018 Summary of Changes

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1 SWIFT Standards Release 2018 Summary of Changes July 9, 2018

2 Dear Infomediary Client: SWIFT has designated November 18, 2018 as the implementation date for the 2018 SWIFT Standards Release (SR2018). As your SWIFT service provider, BBH Infomediary invests heavily to prepare for this annual, industry-wide initiative to ensure a successful transition for all of our clients to SWIFT s newest standards. Each year our team of SWIFT experts coordinates hundreds of BBH Infomediary mapping updates in response to these messaging and market practice changes. In addition to the updates we maintain for our client specific SWIFT maps, BBH Infomediary also applies the required changes within the following on-line tool(s): InfoAction, Message Entry, and Message View and Repair. In general, the updates that BBH Infomediary manages relate to those standards changes that have been deemed mandatory by SWIFT. However, there are also optional changes that clients may consider in order to comply with certain market practice guidelines or a SWIFT counterpart's request. We recommend that every client reference the following SR2018 change summary books by following the attached link in order to assess any potential impacts to your organization. If you require further information, BBH Infomediary will be happy to provide a more detailed list of the standards updates as well as a copy of the SWIFT Standards Release Guide Please do not hesitate to contact your Relationship Manager if you have any questions or would like to discuss Infomediary SR2018 plans in greater detail. Best regards, BBH Infomediary Infomediary Client Service Infomediary.Support@BBH.com US Phone#: Option #2 UK Phone#: Option #2 Int'l Phone#: Option #2 US Relationship Management John Hartnett John.Hartnett@bbh.com Europe Relationship Management Keeva Doran Keeva.Doran@bbh.com Asia Relationship Management Lisa Wong Lisa.Wong@bbh.com

3 Table of Contents 1. BBH Infomediary Approach 2. SWIFT Standards Release (MT) Highlights 3. SWIFT Standards Release (MT) Details 4. Category 6 Changes: Treasury Markets Commodities

4 1. BBH Infomediary Approach In preparation for the SWIFT Standards Release each year, BBH Infomediary creates a project team to focus on the changes that impact all of our client work flows. This section provides an overview of the analysis approach and focus areas for our clients in implementing the Standards Release. BBH Infomediary has divided this into two categories for your convenience in identifying the impacts to your organization and follow-up with your providers. 1. Infomediary Product Modules and Tools The SR2018 updates will be made to ensure messaging compliance with all of BBH Infomediary's product modules and on-line tools. The BBH Infomediary products modules include InfoFX, InfoUploader SM, InfoRecon SM, Connect-to-Connect SM, InfoAction TM and InfoSettle. The Infomediary on-line tools include InfoMonitor, Message Entry, Message View and Repair, Data Manager, InfoFX Report Card, InfoFX Live, InfoSelf Service, and InfoReports. BBH Infomediary will be applying the required changes within the following on-line tool(s): InfoMessage is the only on-line tool(s) requiring development changes to meet the new messaging guidelines. The changes are related to qualifiers and codes available within the BBH Infomediary application. 2. File and Data Mapping Infomediary File Format (IFF) or Proprietary Format to SWIFT Format Mapping: BBH Infomediary clients utilizing a proprietary file format or one of many of the IFFs may be required to add or modify specific data fields in their files in order to prepare for some or all of the new requirements that result from this Standards Release. The changes to these files may be dependent on codes and qualifiers that will no longer be supported as of November 18, As a result, it is possible that SR2018 will require a development change by both Infomediary and its clients to ensure continued SWIFT compliance. These workflows may include files that contain SWIFT-formatted messages sent by clients to Infomediary via FTP/MQ/leased line that are enriched or transformed by Infomediary. Likewise, BBH Infomediary also suggests that clients that utilize Infomediary for inbound data routing from service providers review all related SR2018 changes. SWIFT Format to IFF or Proprietary Format Mapping: BBH Infomediary clients that have SWIFT flows translated into a proprietary file format may be notified of required changes as this may impact the file format, data in the file, or structure of the file that Infomediary creates. Infomediary will be assessing each message type to determine the impact to each client s specific file, denoting required mapping and development to support new field formats, qualifiers, and codes. As requirements are completed, Infomediary will schedule meetings with each client to discuss the recommended changes. SWIFT Format to SWIFT Format: BBH Infomediary understands that clients who send messages to Infomediary in a pass-through capacity are responsible for updating all applicable data formats in order to accommodate the SR2018. However, the Infomediary project team is available for guidance and messaging expertise as needed to support any questions as they arise. *Note: Any of the above mentioned file and data mapping changes may also include maps that support client workflows related to Infomediary product modules i.e. InfoFX and Connect-to-Connect

5 2. SWIFT Standards Release (MT) 2018 Highlights This section is intended to provide a high level overview of the changes for the SR2018. Please be advised that this section does not represent all changes related to the release; the subsequent sections of this document provide detailed field changes from a formatting perspective. BBH Infomediary plans to move all message changes into production on Saturday, November 17, Messages sent and received by BBH Infomediary from November 18, 2018 (08:00 EST / 14:00 CET) onward must comply with the SR2018 Standards. The main highlights of the SR2018 include the following changes: Category 6 Commodities: A new repetitive optional field has been added to indicate commission and fees. This field specifies the type of the commission and either the currency and amount of the commission or the rate (percentage) which is used to calculate the amount. Category 6 Reference Data: No Changes Category 6 Syndications: No Changes

6 3. SWIFT Standards Release (MT) 2018 Details This section is intended to provide the detailed changes for the SR2018. Please be advised that this does not represent all changes related to the release across every message type. This represents the critical changes and message types commonly utilized. Please note the following: This table has been sorted by message type then change type Text in blue indicates new SWIFT qualifiers, codes or fields Text in red indicates removed SWIFT qualifiers, codes or fields Sequence refers to the SWIFT message sequence O/M/C refers to Optional, Mandatory and Conditional

7 4. Category 1 Changes: Treasury Markets Commodities Message Type MT Name Sequence O/M/C Tag Qualifier Generic Field Name Detailed Field Name Changes

8 MT 600 Commodity Trade Confirmation A M 77H N/A Type, Date, Version of the Agreement Type, Date, Version of the Agreement Industry Requirements: ==> Definition change If field 77H specifies ISDA as the type of master agreement and Party A and Party B are parties to an ISDA Master Agreement or an Interest Rate and Currency Exchange Agreement (each an Agreement), this Confirmation constitutes a Confirmation as referred to in, and supplements, forms a part of, and is subject to that Agreement. If Party A and Party B have not entered into any ISDA Master Agreement or other master agreement, Party A and Party B agree to use all reasonable efforts to promptly negotiate, execute, and deliver an agreement in the form of a 2002 ISDA Master Agreement (the "ISDA Form"), with such modifications as Party A and Party B will in good faith agree. Upon the execution by Party A and Party B of such an agreement, this Confirmation will supplement, form part of, and be subject to that agreement. All provisions contained or incorporated by reference in that agreement upon its execution will govern this Confirmation. If field 77H specifies ISDA as the type of master agreement and Party A and Party B are parties to an ISDA Master Agreement or an Interest Rate and Currency Exchange Agreement (each an Agreement), this Confirmation constitutes a Confirmation as referred to in, and supplements, forms a part of, and is subject to that Agreement. If Party A and Party B are not parties to an agreement, this Confirmation evidences a complete and binding agreement between Party A and Party B as to the terms of the Transaction to which this Confirmation relates. Party A and Party B agree to use all reasonable efforts promptly to negotiate, execute, and deliver an agreement in the form of a 2002 ISDA Master Agreement (Multicurrency- Cross Border) (the "ISDA Form"), with such modifications as Party A and Party B will in good faith agree. Upon the execution by Party A and Party B of such an agreement, this Confirmation will supplement, form part of, and be subject to that agreement. All provisions contained or incorporated by reference in that agreement upon its execution will govern this Confirmation except as expressly modified below. Until Party A and Party B execute and deliver that agreement, this Confirmation, together with all other documents referring to the ISDA Form (each a "Confirmation") confirming transactions (each a "Transaction") entered into between Party A and Party B (notwithstanding anything to the contrary in a Confirmation) shall supplement, form a part of, and be subject to an agreement in the form of the ISDA Form as if Party and Party B had executed that agreement in such form (but without any Schedule thereto except for the election of English Law as the governing law, EUR as Termination Currency and Automatic Early Termination not applicable to Party A and Party B, provided, however, that where the Event of Default specified in Sections 5(a)(vii)(1), (3), (4), (5), (6) of the ISDA Form or, to the extent analogous thereto, Section 5(a)(vii)(8) of the ISDA Form is governed by a system of law which does not permit termination to take place after the occurrence of the relevant Event of Default, then the Automatic Early

9 Termination provision of Section 6(a) of the ISDA Form shall apply to the Defaulting Party) on the Trade Date of the first such Transaction between us. In the event of any inconsistency between the provisions of that agreement and this Confirmation, this Confirmation will prevail for the purpose of this Transaction.

10 MT 601 Commodity Option Confirmation A M 77H N/A Type, Date, Version of the Agreement Type, Date, Version of the Agreement Industry Requirements: ==> Definition change If field 77H specifies ISDA as the type of master agreement and Party A and Party B are parties to an ISDA Master Agreement or an Interest Rate and Currency Exchange Agreement (each an Agreement), this Confirmation constitutes a Confirmation as referred to in, and supplements, forms a part of, and is subject to that Agreement. If Party A and Party B have not entered into any ISDA Master Agreement or other master agreement, Party A and Party B agree to use all reasonable efforts to promptly negotiate, execute, and deliver an agreement in the form of a 2002 ISDA Master Agreement (the "ISDA Form"), with such modifications as Party A and Party B will in good faith agree. Upon the execution by Party A and Party B of such an agreement, this Confirmation will supplement, form part of, and be subject to that agreement. All provisions contained or incorporated by reference in that agreement upon its execution will govern this Confirmation. If field 77H specifies ISDA as the type of master agreement and Party A and Party B are parties to an ISDA Master Agreement or an Interest Rate and Currency Exchange Agreement (each an Agreement), this Confirmation constitutes a Confirmation as referred to in, and supplements, forms a part of, and is subject to that Agreement. If Party A and Party B are not parties to an agreement, this Confirmation evidences a complete and binding agreement between Party A and Party B as to the terms of the Transaction to which this Confirmation relates. Party A and Party B agree to use all reasonable efforts promptly to negotiate, execute, and deliver an agreement in the form of a 2002 ISDA Master Agreement (Multicurrency- Cross Border) (the "ISDA Form"), with such modifications as Party A and Party B will in good faith agree. Upon the execution by Party A and Party B of such an agreement, this Confirmation will supplement, form part of, and be subject to that agreement. All provisions contained or incorporated by reference in that agreement upon its execution will govern this Confirmation except as expressly modified below. Until Party A and Party B execute and deliver that agreement, this Confirmation, together with all other documents referring to the ISDA Form (each a "Confirmation") confirming transactions (each a "Transaction") entered into between Party A and Party B (notwithstanding anything to the contrary in a Confirmation) shall supplement, form a part of, and be subject to an agreement in the form of the ISDA Form as if Party and Party B had executed that agreement in such form (but without any Schedule thereto except for the election of English Law as the governing law, EUR as Termination Currency and Automatic Early Termination not applicable to Party A and Party B, provided, however, that where the Event of Default specified in Sections 5(a)(vii)(1), (3), (4), (5), (6) of the ISDA Form or, to the extent analogous thereto, Section 5(a)(vii)(8) of the ISDA Form is governed by a system of law which does not permit termination to take place after the occurrence of the relevant Event of Default, then the Automatic Early

11 Termination provision of Section 6(a) of the ISDA Form shall apply to the Defaulting Party) on the Trade Date of the first such Transaction between us. In the event of any inconsistency between the provisions of that agreement and this Confirmation, this Confirmation will prevail for the purpose of this Transaction.

12 MT 600 Commodity Trade Confirmation D O 34C N/A Commission and Fees Commission and Fees PRESENCE Optional in optional sequence D DEFINITION This field specifies the type of the commission and either the currency and amount of the commission or the rate (percentage) which is used to calculate the amount. CODES Commission Type may contain one of the following codes: ACCA Accrued Capitalisation ACRU Accrued Interest Amount AKTI Aktiengewinn ANTO Net Gain/Loss Amount BAKL Backload Fees Amount CBCH Correspondent Bank Charges CHAR Charges/Fees COAX Consumption Tax COUN Country, National, Federal Tax CREB Rebate/Bonification DEAL Trade Amount DSCA Discount Amount ENTF Entrance Fees Amount EQUL Equalisation/Depreciation Deposit ERFE Early Redemption Fee Amount EUTR EU Tax Retention Amount EXEC Executing Broker's Commission HDGE Hedging cost ISDI Issue Discount/Allowance LADT Local Tax (Country specific 1) LEVY Payment Levy Tax LIDT Local Tax (Country specific 2) LOCL Local Tax LOCO Local Broker's Commission LOTE Local Tax (Country specific 3) LYDT Local Tax (Country specific 4) MACO Matching/Confirmation Fee MARG Margin Amount OCMT Original Currency Amount

13 OTHR Other Amount OTMG On top Margin PRDF Difference in Price PRMA Premium Amount PRWI Partial Redemption Withholding Amount REFD Expected Refund REGF Regulatory Fees REMU Remuneration Amount RESU Resulting Amount RSCH Research fees SAMG Sales Margin SETT Settlement Amount SHIP Shipping Amount SPCN Special Concessions STAM Stamp Duty STEX Stock Exchange Tax SUBS Subscription Interest TOTL Total value of all commissions TRAN Transfer Tax TRAX Transaction Tax VATA Value-Added Tax WITH Withholding Tax ZWIS Zwischengewinn NETWORK VALIDATED RULES Currency/Percent must be a valid ISO 4217 currency code or the code PCT (Error code(s): T52). The integer part of Amount/Rate must contain at least one digit. A decimal comma is mandatory and is included in the maximum length. The number of digits following the comma must not exceed the maximum number allowed for the specified currency (Error code(s): C03,T40,T43). If Amount/Rate is zero, Sign must not be present (Error code(s): T14). USAGE RULES This field is used to report details of fees, expenses and commissions. This field is not intended to be used to instruct separate settlement of these charges, as this is typically incorporated within other settlement fields in the message. The field may be repeated, in order to provide a breakdown of charges. The code TOTL may be used

14 on its own, or in addition to other codes, to report the total charges related to the trade. If a charge is negative, Sign must be present.

15 MT 601 Commodity Option Confirmation D O 34C N/A Commission and Fees Commission and Fees PRESENCE Optional in optional sequence B DEFINITION This field specifies the type of the commission and either the currency and amount of the commission or the rate (percentage) which is used to calculate the amount. CODES Commission Type may contain one of the following codes: ACCA Accrued Capitalisation ACRU Accrued Interest Amount AKTI Aktiengewinn ANTO Net Gain/Loss Amount BAKL Backload Fees Amount CBCH Correspondent Bank Charges CHAR Charges/Fees COAX Consumption Tax COUN Country, National, Federal Tax CREB Rebate/Bonification DEAL Trade Amount DSCA Discount Amount ENTF Entrance Fees Amount EQUL Equalisation/Depreciation Deposit ERFE Early Redemption Fee Amount EUTR EU Tax Retention Amount EXEC Executing Broker's Commission HDGE Hedging cost ISDI Issue Discount/Allowance LADT Local Tax (Country specific 1) LEVY Payment Levy Tax LIDT Local Tax (Country specific 2) LOCL Local Tax LOCO Local Broker's Commission LOTE Local Tax (Country specific 3) LYDT Local Tax (Country specific 4) MACO Matching/Confirmation Fee MARG Margin Amount OCMT Original Currency Amount

16 OTHR Other Amount OTMG On top Margin PRDF Difference in Price PRMA Premium Amount PRWI Partial Redemption Withholding Amount REFD Expected Refund REGF Regulatory Fees REMU Remuneration Amount RESU Resulting Amount RSCH Research fees SAMG Sales Margin SETT Settlement Amount SHIP Shipping Amount SPCN Special Concessions STAM Stamp Duty STEX Stock Exchange Tax SUBS Subscription Interest TOTL Total value of all commissions TRAN Transfer Tax TRAX Transaction Tax VATA Value-Added Tax WITH Withholding Tax ZWIS Zwischengewinn NETWORK VALIDATED RULES Currency/Percent must be a valid ISO 4217 currency code or the code PCT (Error code(s): T52). The integer part of Amount/Rate must contain at least one digit. A decimal comma is mandatory and is included in the maximum length. The number of digits following the comma must not exceed the maximum number allowed for the specified currency (Error code(s): C03,T40,T43). If Amount/Rate is zero, Sign must not be present (Error code(s): T14). USAGE RULES This field is used to report details of fees, expenses and commissions. This field is not intended to be used to instruct separate settlement of these charges, as this is typically incorporated within other settlement fields in the message. The field may be repeated, in order to provide a breakdown of charges. The code TOTL may be used

17 on its own, or in addition to other codes, to report the total charges related to the trade. If a charge is negative, Sign must be present.

18 This publication is provided by Brown Brothers Harriman & Co. and its subsidiaries ("813H"Ito recipients, who are classified as Professional Clients and Eligible Counterparties if in the European Economic Area ("EEA"), solely for informational purposes. This does not constitute legal, tax or investment advice and is not intended as an offer to sell or a solicitation to buy securities or investment products. Any reference to tax matters is not intended to be used, and may not be used, for purposes of avoiding penalties under the U.S. Internal Revenue Code or for promotion, marketing or recommendation to third parties. This information has been obtained from sources believed to be reliable that are available upon request This material does not comprise an offer of services. Any opinions expressed are subject to change without notice. Unauthorized use or distribution without the prior written permission of BBH is prohibited. This publication is approved for distribution in member states of the EM by Brown Brothers Harriman Investor Services Limited, authorized and regulated by the Financial Conduct Authority BBH is a service mark of Brown Brothers Harriman & Co., registered in the United States and other countries. Brown Brothers Harriman & Co All rights reserved.