This document provides you with important information about how the MFI Cash Sweep Program works. These terms and conditions supplement the terms and conditions contained in the Customer Agreement and related documents which govern your Brokerage Account.
YOU ACKNOWLEDGE THAT YOU HAVE RECEIVED AND CAREFULLY READ THESE TERMS AND CONDITIONS IN CONNECTION WITH THE MFI CASH SWEEP PROGRAM.
Moomoo Financial Inc. (collectively, "MFI", "we", "our" or "us"), are pleased to offer to act as your agent so that you can invest in the MFI Cash Sweep Program (the "Program") as a sweep investment option for available cash balances in your brokerage account. Accounts subject to the Employee Retirement Income Security Act ("ERISA") are not eligible to participate in the Program at this time.
Available cash balances will be swept through the Program into interest-bearing deposit accounts ("Deposit Accounts") at one or more participating banks (each a "Deposit Bank") set forth on the Deposit Bank List (defined below), which can be accessed on our website at www.moomoo.com/usor by contacting Moomoo Financial Inc. The Deposit Bank List may change over time. For a current list of the Deposit Banks at any point in time, please refer to our website or contact Moomoo Financial Inc.
The Deposit Accounts held at any Deposit Bank participating in the Program will be eligible for FDIC insurance up to the maximum applicable deposit insurance amount ("Maximum Applicable Deposit Insurance Amount"), which currently is $250,000 in the aggregate at each Deposit Bank, as described in detail below. Through the Program, joint accounts are eligible for FDIC insurance up to $500,000 per Deposit Bank.
Any deposits (including certificates of deposit issued by a particular Deposit Bank) that you maintain in the same capacity directly with a Deposit Bank, or through an intermediary (such as Moomoo Financial Inc. or another broker-dealer), including multiple accounts held at Moomoo Financial Inc. or another broker- dealer, will be aggregated with deposits in your Deposit Accounts at the Deposit Bank for purposes of determining the Maximum Applicable Deposit Insurance Amount. You are responsible for monitoring the total amount of deposits that you have with each Deposit Bank, in order to determine the extent of FDIC deposit insurance coverage available to you.
MFI will place up to $250,000 ($500,000 for joint accounts) into one or more Deposit Accounts at one or more Deposit Banks on the Deposit Bank List (described in more detail below under Operations) irrespective of the capacity in which you hold your brokerage account and of the Maximum Applicable Deposit Insurance Amount available for the deposits held in that capacity.
If available cash to be invested in Deposit Accounts exceeds the aggregate maximum coverage limit of $1,000,000 ($2,000,000 for joint accounts), any additional funds will be invested in a Deposit Bank but will not be FDIC insured.
Each Deposit Account constitutes a direct obligation of the Deposit Bank and is not directly or indirectly an obligation of MFI. You can obtain publicly available financial information concerning each Deposit Bank at www.ffiec.gov/nicor by contacting the FDIC Public Information Center by mail at L. William Seidman Center, Virginia Square, 3501 North Fairfax Drive, Arlington, VA 22226 or by phone at 703-562-2200. MFI does not guarantee in any way the financial condition of the Deposit Banks or the accuracy of any publicly available financial information concerning the Deposit Banks.
You will not have a direct account relationship with the Deposit Banks with respect to accounts established under this Program and you will not be able to deposit money into or withdraw money directly from the Deposit Account. Your money will be deposited through a sweep of cash in your MFI brokerage account. MFI, as your agent, will establish the Deposit Accounts for you and its other customers on an omnibus basis at each Deposit Bank and make deposits to and withdrawals from the Deposit Accounts. MFI will receive a fee from each Deposit Bank. The amount of the fee paid to MFI will affect the interest rate paid on the Deposit Accounts. You should review carefully the section of these Terms and Conditions titled "Information about Your Relationship with MFI and the Deposit Banks".
Due to daily deadlines for sweeping funds to the Deposit Banks, funds that are deposited and cleared into your brokerage account after 2 PM ET may be held as a free credit balance in your brokerage account (and therefore may be covered by SIPC insurance) or swept to a single Deposit Bank until the next business day. Depending on the size of the deposit, this may affect the amount of FDIC insurance available until these funds are allocated across Deposit Banks as described above.
As discussed herein, the interest rates on the Deposit Accounts in which your funds may be placed may be tiered based upon the amount of funds in the Program and maintained in your household brokerage accounts and will vary based upon prevailing economic and business conditions. The Deposit Banks provide FDIC insurance, but do not have a duty to offer the highest rates available or rates that are comparable to money market funds. By comparison, money market funds generally seek to achieve the highest rate of return consistent with their respective investment objectives.
The Program is MFI’s exclusive sweep option. We do not currently provide an option for sweeping available cash to money market funds.
MFI is not obligated to offer you any sweep investment or to make available to you sweep investments that offer a rate of return that is equal to or greater than other comparable investments.
Participation in the Program will not affect your brokerage account fees.
Sweep means that cash is automatically invested when eligible cash becomes available in your MFI brokerage account from any source such as proceeds from securities sales, receipt of dividends or interest income, or any deposit from you. Cash is automatically withdrawn from Deposit Accounts when appropriate to cover purchases or other activities in your account. In addition, there is no minimum cash balance associated with the Program.
Participation in the Program is not intended to impact your ability to access funds, including the ability to write checks against your brokerage account.
For most clients, interest earned from the Program will be taxed as ordinary income in the year it is received. Interest income you have earned in the Program will be included in the INT section of Form 1099, which MFI will send to you each year. You should consult with your tax advisor about how income derived from the Program affects you.
MFI may be required to withhold U.S. federal income for certain customers under certain circumstances. Please consult your tax advisor for more information applicable to your individual tax circumstances.
The "Deposit Bank List" is a list of available Deposit Banks into which your funds may be deposited as of the date of this mailing. You should review the Deposit Bank List carefully. The Deposit Bank List may be found on our website at www.moomoo.com/us. The Deposit Bank List
may change over time. For a current list of the banks at any point in time, please refer to our website or ask Moomoo Financial Inc. for a copy.
As discussed further in these Terms and Conditions, it is your responsibility to notify Moomoo Financial Inc. if you wish to remove a Deposit Bank from your Deposit Bank List for any reason, including, without limitation, the fact that you may maintain funds directly with a particular Deposit Bank already or may have purchased CDs issued by a particular Deposit Bank and are concerned that you may have reached the Maximum Applicable Deposit Insurance Amount. In the event that you have deposits equal to $1,000,000 in Deposit Accounts ($2,000,000 for joint accounts), for U.S. accounts, any additional funds will be invested in a Deposit Bank but will be uninsured.
The Deposit Bank List along with the number of Deposit Banks may change. Please review the section "Changes to the Deposit Bank List".
When funds are first available for deposit, MFI, as your agent, will open a Deposit Account on your behalf at one or more of the Deposit Banks on the then current Deposit Bank List. Note that Deposit Accounts are non-transferable. As necessary, MFI, as your agent, will open Deposit Accounts at other Deposit Banks on the Deposit Bank List and place your additional funds in those Deposit Banks held in the name "Moomoo Financial Inc. acting as agent for customers, each acting for themselves and others" or a similar title.
The allocation algorithm that MFI utilizes is a non-discretionary allocation methodology. Each day, Program Banks are ranked according to the following objective process:
• Each Program Bank is initially prioritized according to the target level that it has available to accept deposits from the Program for that day. Under this ranking process, the Program Bank with the greatest target deposit level is ranked first, the Program Bank with the second greatest target level is ranked second, and so on until all deposits are allocated; and
• The initial priority ranking is adjusted, as needed, to take into account Program Bank- specific conditions that may, pursuant to the terms of its participation agreement and certain regulatory requirements, restrict its ability to receive individual client deposits under the Program below certain minimum dollar amounts or from only certain types of accounts (e.g., based on legal category of account ownership, whether held by a U.S. or non-U.S. person).
With respect to the above adjustment, Program Banks that require specific types of deposits or deposit minimums per individual depositor will be moved to the top of the priority ranking, based
first on the dollar amount of any individual depositor minimum, and then based on the target level, each by descending amounts. The initial ranking with any as needed adjustments for each business day is referred to as that business day’s "Deposit Allocation Ranking".
Once established, all customer funds participating in the Program are allocated and re-allocated each business day to the Program Banks according to the current Deposit Allocation Ranking, subject to (i) a customer’s opt-out preference (ii) the Program Bank’s individual depositor minimum, where applicable; (iii) the Program Bank’s account type restrictions; and (iv) the Program Bank’s stated capacity. Customer funds are allocated to the Program Banks individually, based on deposit size, in descending order. As such, customers with larger deposits will be allocated before customers with smaller deposits.
You may designate a Deposit Bank as ineligible to receive your funds, in which case, monies which would otherwise be deposited to that bank will simply be deposited to the next bank on the Deposit Bank List, as identified by the aforementioned deposit algorithm. Any amount you have in a Deposit Account at a Deposit Bank that you have designated as ineligible to receive deposits will treated as if they were a Cash Balance in your brokerage account and reallocated to the remaining banks active Deposit Bank List.
Please note that because we have committed to remain within specific deposit capacity thresholds at the Deposit Banks, from time to time your total deposits at a specific bank may be moved to a different bank.
Please note that designating one or more Deposit Banks as ineligible to receive your funds may reduce the total amount of FDIC insurance available to you through the Program, as there are only a limited number of Deposit Banks in the Program.
At any point in time, you may contact MFI to determine the banks in which your funds have been deposited.
MFI will establish the Deposit Accounts on an omnibus basis at each Deposit Bank, and maintain records regarding the balances belonging to each MFI customer. Your Deposit Account will be reflected by a book entry on MFI’s account records in a manner consistent with FDIC rules governing "pass-through" deposit insurance. No evidence of ownership, such as a passbook or certificate, will be issued to you. The ownership title, tax identification number, and address of your Deposit Accounts will be the same as your brokerage account to which they are linked, and a single statement covering your brokerage account and the related Deposit Accounts will be sent to you.
Withdrawals from your Deposit Accounts, necessary to satisfy debits or deficiencies in your brokerage account will be made by MFI in its sole discretion as your agent. A debit is created to satisfy a securities purchase, cover fees or charges to your brokerage account, satisfy a request for
a withdrawal of funds from your brokerage account and, if applicable, when you write a check on your brokerage account or withdraw funds or make purchases using the debit card linked to your brokerage account. Checks written on your brokerage account are not drawn directly against the Deposit Accounts established for you at the Deposit Banks.
Withdrawals to cover debits or deficiencies in your brokerage accounts will be made from one or more Deposit Accounts at the Deposit Bank(s) in which your funds have been deposited. The Deposit Banks from which such withdrawals will be made shall be determined based on the aggregate Program settlements (net deposits and withdrawals) on the date your debit occurs, as well as the Deposit Banks’ then-current capacity thresholds.
If there are insufficient funds in the Deposit Accounts at the Deposit Banks on the Deposit Bank List to satisfy a debit or deficiency in your brokerage account, MFI may take the actions described in the Client Account Agreement and other documentation governing the terms of your brokerage account.
You may instruct Moomoo Financial Inc. at any time to withdraw all or a portion of the monies invested through the Program.
One or more of the Deposit Banks included on the Deposit Bank List may be replaced with a Deposit Bank not previously included on the Deposit Bank List; or a Deposit Bank may be removed from the Deposit Bank List. In general, you will receive notification in advance of changes that result in the addition of a Deposit Bank to the Deposit Bank List and have an opportunity to designate a Deposit Bank as ineligible to receive your deposits before any funds are deposited into a new Deposit Bank. If a Deposit Bank is unable to accept deposits for regulatory or other reasons or withdraws or is removed from the Program, MFI may not be able to provide you with advance notice. MFI also reserves the right to add Deposit Banks to the Deposit Bank List. If you receive notice that the Deposit Bank List has changed, it is your obligation to review the Deposit Bank List on our website at www.moomoo.com/usor obtain the Deposit Bank List from your broker.
If a Deposit Bank at which you have Deposit Accounts no longer makes the Deposit Accounts available, you will be notified by MFI and your funds will be transferred to another Deposit Bank on the Deposit Bank List.
All Deposit Banks will utilize the same Interest Rate and Annual Percentage Yield ("APY") Tiers and will pay the same rate of interest and APY on the Deposit Accounts within the same Interest Rate and APY Tier. Generally, each Deposit Bank sets an aggregate cost of funds that includes both the interest rate it is willing to pay and the fees to MFI and other service providers involved in the Program. The interest rates on the Deposit Accounts will be determined by the amount the
Deposit Banks are willing to pay on the Deposit Accounts minus the fees paid to MFI and other service providers as set forth below under "Fees".
The interest rates on the Deposit Accounts into which your funds will be placed may vary based upon the amount of funds you maintain in the Deposit Accounts held in the Program ("Interest Rate Tiers"). The APY may also vary, but unlike the Interest Rate, it will take into account compounded interest and therefore, may appear as a higher rate ("APY Tiers"). Both the interest rates and APYs available through the Program may be lower than the rates available from money market funds or other bank deposits. In determining your Deposit Account Interest Rate and APY Tier for a given posting period, we will utilize the average daily balance invested in the Program from the prior interest posting period. Aggregate balances in the Program invested in your participating household accounts will be used to calculate this monthly average. If certain of your accounts are not currently household, and you receive separate statements for these accounts, please contact Moomoo Financial Inc. to discuss how to household all of your accounts to achieve the best rate with the Program.
You may contact Moomoo Financial Inc. or access our website at www.moomoo.com/usto determine the current interest rate and APY on the Deposit Accounts for each Interest Rate and APY Tier. Interest rates may change daily without prior notice. Interest will accrue on Deposit Account balances from the day funds are deposited into the Deposit Accounts at a Deposit Bank through the business day preceding the date of withdrawal from the Deposit Accounts at the Deposit Bank. The daily balance method is used to calculate the interest in your Deposit Accounts. This method applies a daily periodic rate to the principal in the Deposit Account each day. Interest will be compounded daily and credited to your account monthly, or when you close your account. There is no minimum Deposit Account size or balance required to participate in the Program. MFI or the Deposit Banks may, at any time, change the basis upon which interest rates and APYs are calculated, set a minimum balance for accrual of interest, or change the Interest Rate or APY Tiers.
Interest Rate and APY Tiers may be changed at any time without notice. The interest rates paid with respect to the Deposit Accounts at a Deposit Bank may be higher or lower than the interest rates available to depositors making deposits directly with the Deposit Bank or other depository institutions in comparable accounts, or investments in money market funds or other investments available through MFI. You should compare the terms, interest rates, required minimum amounts, and other features of the Program with other accounts and alternative investments. At any time current Interest Rate and APY Tier information may be obtained by contacting Moomoo Financial Inc. or visiting our website at www.moomoo.com/us.
Your "Household Balance", the total cash balance of all of your household accounts, may be used to determine the interest rates and Deposit Accounts available to you. Your Household Balance is based upon the amount of funds you maintain in the household eligible accounts in the Program.
In determining your Household Balance, all eligible accounts may be linked by Moomoo Financial Inc. Certain brokerage accounts may not be eligible for linking in determining your Household Balance. MFI is not responsible for identifying your brokerage accounts that are eligible to be linked for purposes of determining your Household Balance. It is your obligation to notify Moomoo Financial Inc. of brokerage accounts that you would like to have linked for purposes of calculating the Household Balance.
Transactions in the Program will be displayed on your monthly MFI account statement. You will not receive trade confirmations for each deposit and withdrawal. For each statement period, your brokerage account statement will reflect:
• All deposits to and withdrawals from your MFI brokerage account to/from the Program
• The opening balance invested in the Program from the previous period
• The closing balances of the Deposit Accounts at each Deposit Bank
• The interest earned on your investment in the Program
• The interest rate applicable to your Deposit Accounts at the end of the statement period (based on your average household balances during the prior interest cycle)
MFI is responsible for the accuracy of your statement, not the Deposit Banks. MFI can assist you in understanding your brokerage account statement and can answer any questions you may have about your statement.
All notices described in these Terms and Conditions may be made (1) by email at the email address specified by you; (2) by posting the communication on our website; (3) by sending you an email that includes a hyperlink to a website or an address on the Internet where the information is posted and can be read and printed; and (4) by sending you a notice that directs me to an address on the Internet where the communication is posted and from which it can be read and printed.
MFI is acting as your agent in establishing the Deposit Accounts at each Deposit Bank, depositing funds into the Deposit Accounts, withdrawing funds from the Deposit Accounts and transferring funds among the Deposit Accounts. Deposit Account ownership will be evidenced by a book entry on the account records of each Deposit Bank and by records maintained by MFI as your custodian. No evidence of ownership, such as a passbook or certificate, will be issued to you. Your brokerage account statements will reflect the balances in your Deposit Accounts at the Deposit Banks. You should retain the brokerage account statements for your records. You may at any time obtain information about your Deposit Accounts by contacting your broker.
Unless you establish accounts directly with a Deposit Bank, all transactions with respect to your Deposit Accounts must be directed by MFI and all information concerning your Deposit Accounts can only be obtained from MFI. The Deposit Banks have no obligation to accept instructions from you with respect to your Deposit Accounts or provide you with information concerning your Deposit Accounts. MFI may, in its sole discretion, terminate your use of the Program as a sweep investment option. If MFI terminates your use of the Program as a sweep investment option, you may establish a direct depository relationship with each Deposit Bank, subject to its rules with respect to opening and maintaining deposit accounts.
Similarly, you may decide at any time to terminate your participation in the Program. If you or MFI terminate your participation in the program, any cash previously held in Deposit Accounts will be returned to the free credit balance in your brokerage account.
As described above, you will not have a direct account relationship with the Deposit Banks. However, each Deposit Account constitutes an obligation of a Deposit Bank and is not directly or indirectly an obligation of MFI. You can obtain publicly available financial information concerning each Deposit Bank at www.ffiec.gov/nicor by contacting the FDIC Public Information Center by mail at L. William Seidman Center, Virginia Square, 3501 North Fairfax Drive, Arlington, VA 22226 or by phone at 703-562-2200. MFI does not guarantee in any way the financial condition of the Deposit Banks or the accuracy of any publicly available financial information concerning such Deposit Banks.
The compensation received by MFI and other service providers involved in operating the Program will affect the interest rate you receive from the Deposit Bank on your Deposit Accounts. Since Deposit Banks consider their all-in cost of funds (including service provider fees) when setting this payment for the Deposit Accounts, MFI and other service providers may establish or vary their fees for different Deposit Banks or customer account balance levels in order to implement interest rate tiering, equalize the interest rates paid on the Deposit Accounts, or based on arrangements with specific Deposit Banks. Each Deposit Bank will pay MFI an annual fee, payable monthly, equal to a percentage of the average daily deposit balance in the Deposit Accounts at the Deposit Bank (the "Fee"). The Fee earned by MFI will be based on a variety of
factors, including, without limitation, client household balances invested in the Program, and prevailing market rates, less fees for service providers. The Fee MFI earns could reach up to 5%. You will receive the same interest rates and APYs from each Deposit Bank on any given date. In the event the interest rate paid by Deposit Banks on your Deposit Accounts is insufficient to pay the service provider compensation and the MFI Fee, you may be charged a shortfall fee (the "Shortfall Fee"). The Shortfall Fee will be calculated daily, charged monthly, not to exceed 50 basis points (annualized) on your average account balance. Information on the Shortfall Fee may be obtained by contacting Moomoo Financial Inc. or visiting our website at www.moomoo.com/us. You will receive the same interest rates and APYs from each Deposit Bank for any given date.
Upon request, MFI will provide you with information about MFI’s compensation arrangements with respect to its sweep investments.
MFI has contracted with other service providers to assist in locating and negotiating deposit arrangements with Deposit Banks, calculating and coordinating transfers among the Deposit Banks, and providing other services in connection with the Program. In addition to MFI, other service providers will receive fees from each Deposit Bank.
Other than applicable fees imposed by MFI on your brokerage account, there will be no charges, fees or commissions imposed on your brokerage account with respect to the Program.
The Deposit Accounts (including principal and accrued interest) are insured by the FDIC, an independent agency of the U.S. government, to the Maximum Applicable Deposit Insurance Amount for all deposits held in the same insurable capacity at any one Deposit Bank. Your funds become eligible for deposit insurance immediately upon placement into a Deposit Account at a Deposit Bank. Generally, any accounts or deposits that you may maintain directly with a particular Deposit Bank, or through any other intermediary, in the same insurable capacity in which the Deposit Accounts are maintained would be aggregated with the Deposit Accounts for purposes of the Maximum Applicable Deposit Insurance Amount.
You are responsible for monitoring the total amount of deposits that you hold with any one Deposit Bank, directly or through an intermediary, in order to determine the extent of deposit insurance coverage available to you on your deposits, including your Deposit Accounts. Once the available funds in your account reach $1,000,000 ($2,000,000 for joint accounts), you have a higher likelihood of reaching the Maximum Applicable Deposit Amount in any one bank on our Deposit Bank List. MFI is not responsible for any insured or uninsured portion of the Deposit Accounts or any other deposits.
In the event a Deposit Bank fails, the Deposit Accounts at that Deposit Bank are insured, up to the Maximum Applicable Deposit Insurance Amount, for principal and interest accrued to the day the Deposit Bank is closed.
Under certain circumstances, if you become the owner of deposits at a Deposit Bank because another depositor dies, beginning six (6) months after the death of the depositor, the FDIC will aggregate those deposits for purposes of the Maximum Applicable Deposit Insurance Amount with any other deposits that you own in the same insurable capacity at the Deposit Bank. Examples of deposit accounts that may be subject to this FDIC policy include joint accounts, "payable on death" accounts and certain trust accounts. The FDIC provides the six-month "grace period" to permit you to restructure your deposits to obtain the maximum amount of deposit insurance for which you are eligible.
In the event that federal deposit insurance payments become necessary, payments of principal plus unpaid and accrued interest will be made to you. In the event of a failure of a Deposit Bank, there may be a time period during which you may not be able to access your funds in the Program. There is no specific time period during which the FDIC must make insurance payments available, and MFI is under no obligation to credit your account with funds in advance of payments received from the FDIC. Furthermore, you may be required to provide certain documentation to the FDIC and MFI before insurance payments are made. For example, if you hold deposits as trustee for the benefit of trust participants, you may be required to furnish affidavits and provide indemnities regarding an insurance payment.
If your Deposit Accounts or other deposits at a Deposit Bank are assumed by another depository institution pursuant to a merger, acquisition, or consolidation, such deposits will continue to be insured separately, up to the FDIC insurance coverage limits, from the deposits that you might have established with the acquirer until (i) the maturity date of any time deposits (including certificates of deposit) that were assumed, or (ii) with respect to deposits that are not time deposits, the expiration of a six-month period from the date of the merger, acquisition, or consolidation. Thereafter, any assumed deposits will be aggregated with your existing deposits with the acquirer held in the same capacity for purposes of FDIC insurance coverage. Any deposit opened at the acquirer after the merger, acquisition, or consolidation will be aggregated with deposits established with the acquirer for purposes of FDIC insurance coverage.
Questions about FDIC Deposit Insurance Coverage. If you have questions about basic FDIC insurance coverage, please contact Moomoo Financial Inc. You may wish to seek advice from your own attorney concerning FDIC insurance coverage of deposits held in more than one insurable capacity. You may also obtain information by contacting the FDIC, Office of Consumer Affairs, by mail at 550 17th Street, N.W., Washington, DC 20429, by phone at 877-275-3342 or 800-925-4618 (TDD), by e-mail at email@example.com or by visiting the FDIC website at www.fdic.gov.
Balances maintained in the Deposit Accounts at each Deposit Bank are not protected by SIPC or excess coverage purchased by MFI. Money market fund shares, by comparison, are considered to be securities for purposes of SIPC coverage. You may obtain further information about SIPC
coverage, including a brochure that describes SIPC and SIPC insurance, by accessing the SIPC website at www.sipc.org.
MFI may change these terms and conditions from time to time in its discretion by providing 30 days’ prior notice to you, either by mail or by posting the revised terms and conditions on our website at www.moomoo.com/us. Your continued use of your brokerage account and the Program without notifying us of your election to terminate your participation in the Program shall indicate your consent to the revised terms and conditions.
In Case of Errors or Questions about Program Balances or Fund Transfers in Your Account Please contact us as soon as you can if you think your statement is wrong or if you need more information about a balance or transfer listed on your statement. We must hear from you no later than 60 days after we sent the first statement on which the problem or error appeared. Please provide the following information:
• Name and account number
• Describe the error or the transfer you are unsure about, and explain as clearly as you can why you believe it is an error or why you need more information
• Dollar amount of the suspected error
Generally, we will determine whether an error occurred within 10 business days after we hear from you and will correct any error promptly. If we need more time, however, we may take up to 45 days to investigate your complaint or question.
For errors involving new accounts, point-of-sale, or foreign-initiated transactions, we may take up to 90 days to investigate your complaint or question. If we decide that there was no error, we will send you a written explanation. You may ask for copies of the documents that we used in our investigation.