Dodd-Frank Wall Street Reform and Consumer Protection Act

Banking and Financial Companies Capital Requirements The “Collins Amendment” Risk-based and leverage capital requirements that currently apply to U.S. insured depository institutions will apply to BHCs, thrift holding companies and systemically important nonbank financial companies Banking regulators must issue rules to implement this change by January, 2012 Phase-in of Collins Amendment capital requirements may coincide with implementation of Basel III recommendations

Banking and Financial Companies Capital Requirements Key Exceptions – Collins Amendment does not apply to: Securities issued by BHCs subject to the Federal Reserve’s “Small Bank Holding Company Policy Statement” TARP CPP securities Securities issued before May 19, 2010 by a BHC (or other depository institution holding company), with assets less than $15 billion at December 31, 2010 Key Impact – Eliminate Tier 1 capital treatment for Trust Preferred Securities (unless issuer is otherwise excepted)

Banking and Financial Companies Deposit Insurance Reform New Assessment Base for FDIC Deposit Insurance = Average total consolidated assets, less average tangible equity Impact – shift DIF assessment burden to larger banks that finance assets with significant non- deposit funding sources and other liabilities Changes to DIF Reserve Ratio: No upper limit Minimum reserve ratio raised to 1.35% from 1.15% FDIC Assessment Authority – the FDIC may now collect assessments to cover the cost of regular and special examinations

Banking and Financial Companies Deposit Insurance Reform Deposit Account Insurance: Maximum deposit insurance increases to $250,000, with retroactive application to certain FDIC receiverships between January and October 2008 Deposit insurance for noninterest bearing transaction accounts extended to December 31, 2012 FDIC has additional authority to require reports from insured institutions, after consultation with other federal regulators Content of these reports is not specified Previously, the other federal banking regulators needed to consent before the FDIC could require additional reports

Banking and Financial Companies Other Regulatory Reforms Prohibition on Charter Conversion when Formal or Informal Supervisory Action is Pending Relaxation of Bank De Novo Interstate Branching Expanded Restrictions on Affiliate Transactions including what is “Covered”, Collateral Requirements, Coverage for Financial Subsidiaries, and more Greater Restrictions on Transactions with Insiders

Banking and Financial Companies Small Business Lending Fund SBLF was adopted by the U.S. House of Representatives; currently under consideration by U.S. Senate Objective – to encourage lending to small businesses Mechanics – U.S. Treasury would purchase up to $30 billion of preferred stock in community banks and other eligible institutions Key Characteristics – Participants must submit a small business lending plan; preferred stock dividend rate decreases as lending to small businesses increases TARP Refinance – SBLF would permit participating institutions to refinance TARP CPP securities