Global Program Management Dawn Davis, SVP Global Records Management

Bank of America Profile 282,000 Employees Clients in 150 Countries –98% of US Fortune 500 –84% of Global Fortune million consumer and small business relationships 6,100+ retail banking offices & nearly 18,500 ATMs Online banking with 6.63 million active users $1.5 trillion Community Development Lending & Investing goal over 10 years (largest ever set by a financial institution) #1 or #2 in a variety of financial services offerings $200 million in philanthropic investments in 2009 –Unprecedented $2 billion, 10-year goal for philanthropic giving began in

Main goal: Manage the lifecycle of records including the systematic disposition approval in accordance with retention schedule & preservation notices Bank of America Global Records Management Profile Legal entities in 43 countries with 6,800 citations involving records storage requirements Large inventory –Develop and manage a global policy and the retention schedule. –Ensure compliance with legal, statutory, regulatory, and business requirements for the access and storage of corporate records. –Partner with Legal to standardize identification and application of Legal Preservation Notices on all items in offsite storage. –Develop, implement and govern all program enhancements through the Records Management Governance Board. –Ensure the immediate availability of vital information. –Monitor and control the service, the volume and cost of record storage and handling. –Manage approved contracted suppliers for hard copy storage, and secured destruction services. –Manage data mapping, chain of custody, and transition of legacy records into end-state environment. –Manage life-cycle of cartons in storage including all activity and ultimate systematic destruction. –Enable associates to better manage their records by providing centralized resources, intuitive technology tools and required education. –Consult LOBs on best-in-class record management practices. 3 Regulatory/Legal Suppliers Associates

Challenges Multiple audiences, records, data sources, languages, locations to manage –Company size and scale –Vendor selection/capabilities globally –Different regulations in each jurisdiction that are constantly changing (ex: Cross Border Data Regulations) –Growing volume of data (electronic and paper) –Managing and migrating inherited inventory –Defining global infrastructure and identifying records custodians –Communicating to & educating associate population –Complicated technology environment Financial Services Regulations –Banking –Lending –Insurance 4 – Investments – Securities – Accounting

Global Records Strategy Objective: Centrally manage global records Step 1: Planning: Sponsorship, Resources, Timelines Step 2: Establish Standard Records Policy and Retention Schedule Step 3: Implement Global Records Policy Step 4: Prioritize launch of Global Retention Schedule Step 5: Implement Global Retention Schedule Step 6: Improve, Control, and Monitor A compliance program, not a project. 5

Global Retention Program Best Practices Centralize Global Records Management functions Secure executive sponsorship and build governance structure Specialize your Records Management Team Engage the experts Make friends: find your internal stakeholders Build a user-friendly retention schedule –Legal, industry and business requirements –Consider risk/reward balance –Drive out a global taxonomy Focus on the end to end lifecycle to identify compliance risks Use risk identification tools to error-proof processes and technology Communicate and train 6

Global Retention Program Best Practices 7 Make it easy to do the right thing.