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Our interpretation of the CRS reporting requirements are as follows:
1. Entities which issue derivatives should not be required to report under the CRS. TRAction Fintech understands that clients who issue derivatives by entering into contracts with their clients as principal are not caught by the CRS reporting requirements.
2. Entities which deal in direct equities should be required to report under the CRS. TRAction Fintech understands that when an entity deals in direct equities, the entity is conducting business on behalf of its client (i.e. Investment Entity Type A as described below).”