ALD: Broker – Dealers Problem Escalation Process Flows A Guideline to broker-dealers for resolving problems occurring during the daily ALD process flow October 2006 1 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows

Content Broker-dealer connecting directly to DTCC File and notification flow Guidelines and Legend File retrieval decision making process Problem research flows: Agent Lender direct to DTCC Agent Lender using EquiLend Agent Lender using SunGard Broker-dealer using EquiLend Broker-dealer using SunGard 2 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows

Broker-Dealer Accessing Through DTCC Files and Notification Flow Problem Notification & Update Expected File Receipt/ Delivery Agent Lender SunGard client DTCC systemic failure notification SunGard Broker-Dealer DTCC EquiLend Agent Lender (EquiLend client) Agent Lender DTCC direct 3 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows

Broker-Dealer Daily file receipt via DTCC Guidelines Broker-dealers that experience problems retrieving agent lender files from DTCC should: Check for e-mail notification from vendors (SunGard, EquiLend) or agent lenders of problems or delays in delivering the loan and/or collateral file(s) Check the file status on the DTCC website or contact the DTCC, 24 hour PIP Hotline (+ 1 212 855.8989) Contact agent lenders directly DTCC WILL NOT NOTIFY BROKER-DEALERS OF PROBLEMS RECEIVING AGENT LENDER FILES AND DOES NOT TRACK EXPECTED VERSUS RECEIVED FILES. DTCC will send automatic notifications (through their existing crisis management system) only in the case of systemic failures. These notifications will be sent to anyone who wishes to receive them and who provides a contact email to DTCC. Any broker-dealer connecting directly to DTCC who wishes to be part of this notification process should send their contact email to Margaret Koontz, mkoontz@dtcc.com Broker-dealers should be notified by vendors (SunGard, EquiLend) and agent lenders of problems or delays in delivering loan and/or collateral file(s) Notifications should be received at the broker-dealer’s group e-mail address that was specified to their vendor and agent lender counterparties A vendor or agent lender notification should include: Identity of sending firm and contact information The general nature and severity of the problem An estimate for correcting the problem Identification if this is the initial notification of the problem or an update related to a prior notification 4 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows

Broker-Dealer Daily file receipt via DTCC Legend Broker-dealers must research missing or unavailable files using the DTCC website and the DTCC PIP Hotline to determine if the files were successfully received by DTCC Check DTCC Website For File Availability If the broker-dealer finds that files were not successfully received by DTCC then the broker-dealer should check for vendor or agent lender notifications of problems If the broker-dealer determines that DTCC successfully received the agent lender files, then the broker-dealer should verify their processing with DTCC and contact the DTCC PIP Hotline for additional support Call DTCC PIP Hotline & Monitor Status Monitoring Notifications: Once the broker-dealer receives e-mail notification of a problem, they should continue to monitor e-mail for updates on resolving the issue If the sender (agent lender, vendor) does not specify an expected time for resolving the problem or has not provided an update by the time specified, the broker-dealer should call the sender using contact information provided Agent lenders must produce notification and status updates of: problems creating the loan and/or collateral file(s) that may result in no files being sent; delays in creating files; problems transmitting the loan and/or collateral file(s) to their primary recipient (EquiLend, SunGard or DTCC). Monitor A/L File Status Monitor Vendor File Status Vendors must produce notification and status updates of problems sending agent lender files to DTCC. Agent lenders should be contacted directly when no e-mail notification has been received from either the agent lender or a vendor regarding the missing files Contact A/L Re: Missing Files Broker dealer should monitor status with DTCC in the case where a systemic failure email notice was received from DTCC. Monitoring should be done through the DTCC website or by contacting the PIP hotline. Monitor System Status with DTCC 5 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows

Broker-Dealer via DTCC Decision Making Process Flow Retrieve Agent Lender Loan & Collateral Files Start All Files Retrieved by 3:00 AM? Continue Standard ALD Processing Yes No Sys. Failure notification rec’d from DTCC? Monitor System Status with DTCC Yes Check DTCC Website For File Availability No Yes Files Available at DTCC? Call DTCC PIP Hotline & Monitor Status No A/L Delay or Failure Notification Received? Yes No Monitor A/L File Status Vendor Failure Notification Received? Monitor Vendor File Status Yes No Research Missing Files See next 3 slides for specific problem research flow s Wait for A/L Files?* Delay Processing Until A/L files Received; then continue with standard processing Yes No Continue with prior day A/L files As contingency * Decision making process must be determined internally by each broker-dealer 6 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows

Broker-dealer Agent Lender Problem research flows (Direct to DTCC) A/L Files created? No Start Check DTCC website for agent lender files Yes Update B/D with status Correct related Problems Contact Agent Lender by phone & e-mail No File Available? Create A/L Files No Files Accepted by DTCC? Yes Yes Yes A/L Files created? No Check DTCC website for A/L Files Update B/D with status Notify DTCC & B/D of conflicting info Resolve issue with DTCC Resolve retrieval problem with DTCC hotline Correct related Problems Send Files to DTCC Update B/D with status Update B/D with status Files Accepted by DTCC? No Yes Update B/D with status Retrieve files from DTCC End 7 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows

Agent Lender Broker-dealer EquiLend Problem research flows (EquiLend) (DTCC) EquiLend A/L Files created? No Contact Agent Lender by e-mail Start Check DTCC website for agent lender files Yes Update B/D & EquiLend with status Correct related Problems No Files Received from A/L? Contact EquiLend by phone & e-mail No File Available? Create A/L Files Yes Yes Yes A/L Files created? No Files Accepted by DTCC? Files Accepted by EquiLend? Resolve retrieval problem with DTCC hotline Yes Update B/D & EquiLend with status No No Yes EquiLend & B/D Resolve retrieval problem with DTCC Notify EquiLend & B/D of conflicting info EquiLend & A/L resolve conflicting info Correct related Problems Update B/D & A/L with status Update B/D & EquiLend with status Send Files to EquiLend Resolve issue with DTCC Update B/D & EquiLend with status Files Accepted by EquiLend? Update B/D & A/L with status No Yes Update B/D & EquiLend with status Retrieve files from DTCC End 8 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows

Agent Lender SunGard Broker-dealer Problem research flows (SunGard) (DTCC) A/L Files created? No Start Contact Agent Lender by phone & e-mail Check DTCC website for agent lender files Yes Update B/D & SunGard with status Correct related Problems No Files Received from A/L? Contact SunGard by phone & e-mail No File Available? Create A/L Files Yes Yes Yes A/L Files created? No Files Accepted by DTCC? Files Accepted by SunGard? Resolve retrieval problem with DTCC hotline Yes Update B/D & SunGard with status No No Yes SunGard & B/D Resolve retrieval problem with DTCC Notify SunGard & B/D of conflicting info SunGard & A/L resolve conflicting info Correct related Problems Update B/D & A/L with status Send Files to SunGard Update B/D & SunGard w/ status Resolve issue with DTCC Update B/D & SunGard with status Files Accepted by SunGard? Update B/D & A/L with status No Update B/D & SunGard with status Yes Retrieve files from DTCC End 9 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows

Broker-dealer using EquiLend File and notification flow Process flow guidelines and legend Decision making process flow Problem research flows for B/D using EquiLend: Agent Lender direct to DTCC Agent Lender using EquiLend Agent Lender using SunGard 10 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows

Broker-dealer Accessing Through EquiLend Files and Notification Flow Problem Notification & Update Expected File Receipt/ Delivery DTCC systemic failure notification Agent Lender SunGard client SunGard Agent Lender EquiLend client DTCC EquiLend Agent Lender DTCC direct Broker-Dealer 11 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows

Broker-Dealer Daily file receipt via EquiLend Guidelines and Legend Broker-dealers should be notified by vendors (SunGard, EquiLend) and agent lenders of problems or delays in delivering loan and/or collateral file(s) Notifications should be received at the broker-dealer’s group e-mail address that was specified to their vendor and agent lender counterparties A vendor or agent lender notification should include: Identity of sending firm and contact information The general nature and severity of the problem An estimate for correcting the problem Identification if this is the initial notification of the problem or an update related to a prior notification Monitoring Notifications: Once the broker-dealer receives e-mail notification of a problem, they should continue to monitor e-mail for updates on resolving the issue If the sender (agent lender, vendor) does not specify an expected time for resolving the problem or has not provided an update by the time specified, the broker-dealer should call the sender using contact information provided DTCC will send automatic notifications (through their existing crisis management system) only in the case of systemic failures. These notifications will be sent to anyone who wishes to receive them and who provides a contact email to DTCC. Any broker-dealer using a vendor who wishes to be part of this notification process should send their contact email to Margaret Koontz, mkoontz@dtcc.com Legend Agent lenders must produce notification and status updates of: problems creating loan and/or collateral file(s) that may result in no files being sent, delays in creating files, problems transmitting the loan and/or collateral file(s) to their primary recipient (EquiLend, SunGard or DTCC) Monitor A/L File Status Monitor Vendor File Status Vendors must produce notification and status updates of: Problems sending agent lender files to DTCC, Issues preventing broker-dealers from receiving files Contact A/L Re: Missing Files Agent lenders should be contacted directly when no e-mail notification has been received from either the agent lender or a vendor regarding the missing files 12 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows

Broker-Dealer via EquiLend Decision Making Process Flow Start Receive Agent Lender Loan & Collateral Files All Files Received by 3:00 AM? Continue Standard ALD Processing Yes No Yes A/L Delay or Failure Notification Received? Monitor A/L File Status No Vendor Failure Notification Received? Monitor Vendor File Status Yes No See next three slides for specific problem research flows. Contact vendor Re: Missing Files Wait for A/L Files?* Delay Processing Until A/L files Received; then continue with standard processing Yes No Continue with prior day A/L files As contingency * Decision making process must be determined internally by each broker-dealer 13 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows

Agent Lender Broker-dealer Problem research flows EquiLend (DTCC) A/L Files created? Start No Files Available at DTCC? No Contact Agent Lender by phone & e-mail Yes Update B/D & EquiLend with status Check EquiLend browser for agent lender files Yes Correct related Problems Check DTCC website for A/L Files Create A/L Files Files Accepted by DTCC? Yes No A/L Files created? No Files Received from DTCC? Contact EquiLend by phone & e-mail No Files Available? No Check DTCC website for A/L Files Yes Yes Yes Update B/D & EquiLend with status Resolve B/D retrieval Issue Resolve retrieval problem with EquiLend Notify DTCC, B/D & EquiLend of conflicting info Update B/D with status Correct related Problems Resolve issue with DTCC Resolve retrieval problem with DTCC Send Files to DTCC Update B/D & EquiLend with status Update B/D & EquiLend with status Files Accepted by DTCC? Update B/D with status No Yes Update B/D & EquiLend with status Retrieve files from EquiLend End 14 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows

Agent Lender Broker-dealer Problem research flows EquiLend (EquiLend) A/L Files created? No Start Yes Update B/D & EquiLend with status Check EquiLend browser for agent lender files Contact Agent Lender by e-mail Contact EquiLend by phone & e-mail Correct related Problems Notify EquiLend & B/D of conflicting vendor info File Available? Create A/L Files No A/L Files created? No Yes EquiLend & A/L resolve conflicting info Files Accepted by EquiLend? Yes Yes Update B/D & EquiLend with status No Update B/D & A/L with status Correct related Problems Send Files to EquiLend Resolve retrieval problem with EquiLend Update B/D & EquiLend with status Files Accepted by EquiLend? No Yes Update B/D & EquiLend with status Retrieve files from EquiLend End 15 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows

Broker-dealer Agent Lender Problem research flows SunGard EquiLend A/L Files created? No Start Contact Agent Lender by phone & e-mail Yes Update B/D, SunGard & EquiLend with status No Files Received from A/L? Contact SunGard by e-mail Check EquiLend browser for agent lender files No Yes Correct related Problems Files Available at DTCC? Files Accepted by DTCC? Yes Yes No Files Available? Create A/L Files A/L Files created? EquiLend & SunGard resolve retrieval problem with DTCC Check DTCC website for A/L Files No No Yes Yes No Files Received from DTCC? Contact EquiLend by phone & e-mail Update B/D, SunGard & EquiLend with status Update B/D, EquiLend & A/L with status Files Accepted by SunGard? Yes Resolve issue with DTCC Resolve retrieval problem with EquiLend Resolve B/D retrieval Issue No Yes Update B/D with status Notify EquiLend, SunGard & B/D of conflicting info Update B/D, EquiLend & A/L with status Resolve retrieval problem with DTCC SunGard & A/L resolve conflicting info Correct related Problems Update B/D with status Update B/D, EquiLend & A/L with status Send Files to SunGard Update B/D, SunGard & EquiLend with status Update SunGard & B/D with status Files Accepted by SunGard? No Retrieve files from EquiLend Update B/D, SunGard & EquiLend with status Yes End 16 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows

Broker-dealer using SunGard File and notification flow Process flow guidelines and legend Decision making process flow Problem research flows for B/D using SunGard: Agent Lender direct to DTCC Agent Lender using EquiLend Agent Lender using SunGard 17 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows

Broker-dealer Accessing Through SunGard Files and Notification Flow Problem Notification & Update Expected File Receipt/ Delivery DTCC systemic failure notification Agent Lender SunGard client SunGard Broker-Dealer DTCC Agent Lender DTCC direct EquiLend Agent Lender EquiLend client 18 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows

Broker-Dealer Daily file receipt via SunGard Guidelines and Legend Broker-dealers should be notified by vendors (SunGard, EquiLend) and agent lenders of problems or delays in delivering loan and/or collateral file(s) Notifications should be received at the broker-dealer’s group e-mail address that was specified to their vendor and agent lender counterparties A vendor or agent lender notification should include: Identity of sending firm and contact information The general nature and severity of the problem An estimate for correcting the problem Identification if this is the initial notification of the problem or an update related to a prior notification Monitoring Notifications: Once the broker-dealer receives e-mail notification of a problem, they should continue to monitor e-mail for updates on resolving the issue If the sender (agent lender, vendor) does not specify an expected time for resolving the problem or has not provided an update by the time specified, the broker-dealer should call the sender using contact information provided DTCC will send automatic notifications (through their existing crisis management system) only in the case of systemic failures. These notifications will be sent to anyone who wishes to receive them and who provides a contact email to DTCC. Any broker-dealer using a vendor who wishes to be part of this notification process should send their contact email to Margaret Koontz, mkoontz@dtcc.com Legend Agent lenders must produce notification and status updates of: problems creating loan and/or collateral file(s) that may result in no files being sent, delays in creating files, problems transmitting the loan and/or collateral file(s) to their primary recipient (EquiLend, SunGard or DTCC) Monitor A/L File Status Monitor Vendor File Status Vendors must produce notification and status updates of: Problems sending agent lender files to DTCC, Issues preventing broker-dealers from receiving files Contact A/L Re: Missing Files Agent lenders should be contacted directly when no e-mail notification has been received from either the agent lender or a vendor regarding the missing files 19 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows

Broker-Dealer via SunGard Decision Making Process Flow Start Receive Agent Lender Loan & Collateral Files All Files Received by 3:00 AM? Continue Standard ALD Processing Yes No Yes A/L Delay or Failure Notification Received? Monitor A/L File Status No Vendor Failure Notification Received? Monitor Vendor File Status Yes No See next three slides for specific problem research flows. Contact vendor Re: Missing Files Wait for A/L Files?* Delay Processing Until A/L files Received; then continue with standard processing Yes No Continue with prior day A/L files As contingency * Decision making process must be determined internally by each broker-dealer 20 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows

Broker-dealer Agent Lender Problem research flows SunGard (SunGard) (DTCC) Broker-dealer (SunGard) SunGard A/L Files created? No Contact Agent Lender by phone & e-mail Start Yes Yes Files Available at DTCC? No Update B/D & SunGard with status Check SunGard website for agent lender files Correct related Problems Check DTCC website for A/L Files Create A/L Files Files Accepted by DTCC? Yes No A/L Files created? No Files Received from DTCC? Contact SunGard by phone & e-mail No File Available? No Check DTCC website for A/L Files Yes Yes Yes Update B/D & SunGard with status Resolve B/D retrieval Issue Notify DTCC, B/D & SunGard of conflicting info Resolve retrieval problem with SunGard Update B/D with status Correct related Problems Resolve issue with DTCC Send Files to DTCC Resolve retrieval problem with DTCC Update B/D & SunGard with status Update B/D & SunGard with status Files Accepted by DTCC? Update B/D with status No Yes Update B/D & SunGard with status Retrieve files from SunGard End 21 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows

Broker-dealer Agent Lender Problem research flows EquiLend SunGard A/L Files created? No Contact Agent Lender by e-mail Start Yes Update B/D, SunGard & EquiLend with status No Files Received from A/L? Check SunGard website for agent lender files Contact EquiLend by phone & e-mail Yes No Correct related Problems Files Available at DTCC? Files Available? Files Accepted by DTCC? No Yes Yes Create A/L Files Yes Contact SunGard by phone & e-mail A/L Files created? No No EquiLend & SunGard resolve retrieval problem with DTCC Check DTCC website for A/L Files Yes No Files Received from DTCC? Update B/D, SunGard & EquiLend with status Update SunGard & A/L with status Resolve retrieval problem with SunGard Files Accepted by EquiLend? Yes Resolve issue with DTCC Resolve B/D retrieval Issue No Yes Update B/D with status Notify EquiLend, SunGard & B/D of conflicting info Update SunGard & A/L with status Resolve retrieval problem with DTCC EquiLend & A/L resolve conflicting info Update B/D with status Correct related Problems Update SunGard & A/L with status Send Files to EquiLend Update EquiLend & B/D with status Update B/D, SunGard & EquiLend with status Update B/D with status Files Accepted by EquiLend? No Retrieve files from SunGard Update B/D, SunGard & EquiLend with status Yes End 22 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows

Agent Lender Broker-dealer Problem research flows SunGard (SunGard) A/L Files created? No Start Contact Agent Lender by phone & e-mail Check SunGard website for agent lender files Yes Update B/D & SunGard with status No Files Received from A/L? Contact SunGard by phone & e-mail File Available? Correct related Problems No Notify SunGard & B/D of conflicting vendor info Create A/L Files Yes Yes Resolve B/D retrieval Issue A/L Files created? No Update B/D with status Files Accepted by SunGard? Yes Yes Update B/D & SunGard with status No SunGard & A/L resolve conflicting info Resolve retrieval problem with SunGard Correct related Problems Update B/D & A/L with status Send Files to SunGard Update B/D & SunGard with status Files Accepted by SunGard? No Update B/D & SunGard with status Yes Retrieve files from SunGard End 23 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows

Problem Research Flows Version 5 changes Changed method of EquiLend contacting agent lenders and SunGard from “phone & e-mail” to “e-mail” only on all flows as per comments from EquiLend. 24 10/9/06 Agency Lending Disclosure Taskforce Broker-Dealer Problem Escalation Process Flows