[GRADE A2 — Internal DB email chain (EFTA production) — EFTA01458801-829]
November 10–16, 2015. Morris to Packard: "JE called, he requested coverage change, not working with DS, before I reach out to Todd wanted to discuss, between new investor sales/me/Stew we should be able to cover and increase flow business."
Packard: "Thanks, I am sandwiched today and this needs immediate attention so please take up with Gallivan and keep me in the loop. I am not as confident though that we can handle this through investor sales and you guys as this is non-advised business. Let's think this through carefully."
Packard then: "Please start with Andrew as we should address this soon. I can follow up with you guys Thursday/Friday."
WHAT THIS SHOWS AND DOES NOT SHOW: Packard (EXECUTIVE-1) explicitly flagged a compliance concern — "non-advised business" and "think this through carefully" — demonstrating awareness that the Epstein coverage model had regulatory implications. He then delegated to Gallivan, establishing the chain of command. This is 10 months after the ARRC home visit. Despite flagging the concern, Packard did not escalate to compliance or ARRC — he handled it within the business line. Three senior executives (Morris, Packard, Gallivan) all coordinating on a convicted sex offender's demands about his own banking coverage.