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Let’s start with the basics of KICS reporting

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and Broker Import requirements.

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Our regulators require that we have a system of quality control

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in place that provides reasonable assurance that the firm

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and its employees do not lack independence. Specifically, the SEC rules

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require accounting firms to have an automated tracking system

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for investments for our partners and managerial employees.

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Here at KPMG, that system is KICS. Therefore, we all have a responsibility

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to maintain an accurate KICS account,

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as it is an important element of our system of quality control.

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Investments that must be reported in KICS include those that you

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or your immediate family members hold or control, with the exception

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of investments held in KPMG-US sponsored plans. Independence applies

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to a wide range of investments including those shown here.

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Be sure to also consider the types of investments that

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are often overlooked when it comes to personal independence such as:

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investments held through a variable life or annuity contract,

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individual investments within a non-diversified fund that

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equal 20% or more of the fund’s total investments,

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indirect investments, for example, investments held in

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a partnership where you are a limited partner without control,

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that are material to your net worth, or

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investments held in non-KPMG employee benefit plans.

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Independence rules apply to these investments and they must be

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reported in your KICS account within 14 days of acquisition.

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The KICS Broker Import Program facilitates compliance with the firm’s

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personal investment reporting policies by automatically updating

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KICS with the investments held in activated accounts.

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All brokerage accounts that you or your immediate family members

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hold (including those held through investing apps) must be with

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one of the over 85 brokers that participates in KICS Broker Import.

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Each account must be enrolled and activated for KICS Broker Import

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within 14 days of opening the account. Remember to enroll and activate:

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each individual account with the same brokerage firm,

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accounts that have a zero balance, and

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new accounts that are opened as a result of changing

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brokers or brokerage firms.

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Be sure to always check the restriction status of potential investments

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before you make any changes to your portfolio. KICS Broker Import

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does not block or prevent trades in restricted investments.

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In addition to investments, any loans held, co-signed or guaranteed

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by you and your immediate family members must be manually

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reported in your KICS account. Independence rules apply to a wide range

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of loans, including those shown here.

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It is important to consider all loans and ability to borrow against

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assets that you and your immediate family members have, including:

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consumer and point-of-sale loans, for example, for appliances or furniture,

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home equity lines of credit on primary

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and non-primary residences, even if unused,

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brokerage account and digital wallet margin

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loan features, even if unused, and

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overdraft protection on bank accounts, even if unused.

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Each individual loan must be reported in KICS within 14 days of closing

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on the loan or obtaining a line of credit or margin loan feature.

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Loans must be reported by the name of the lender

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(not the loan servicer, which may be a different entity).

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Make sure you confirm the name of the lender and update KICS accordingly.

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Set a monthly reminder to review your KICS account to help

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ensure it’s up to date. If you discover a potential violation,

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report it to Risk Management - Independence using

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the Independence Inquiry Submission Form.

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