1. 1 Annual Account Review June 10, 2014

2. Agenda Situation Analysis Solution Requirements and Development Solution Delivery Measurable Benefits of the Solution Demonstration of the Solution Pinpoint Global Communications Confidential |2

3. Situation Analysis – Investment Advisory AAR Process Pinpoint Global Communications Confidential |3 IARs utilized paper forms to satisfy this requirement No process to determine status of reviews other than manual review by Branch Examiners In regulatory or litigation situations, documentation was either missing or not in good order when requested.

4. Solution Requirements and Development Establish electronic Annual Account Review Design “smart form” and workflow for Annual Account Review submission & review Provide dashboards for IARs, Agency Supervisors & Compliance to manage submission status Pinpoint Global Communications Confidential |4

5. Solution Delivery IARs access Dashboard & Smart Form via link on Guardian Online Compliance System Simplified form completion & submission process OSJs, ACOs and Home Office Compliance utilize Work Queue to access and approve/pend back to IARs the account submissions Pinpoint Global Communications Confidential |5

6. Measurable Benefits – What Improved? Pinpoint Global Communications Confidential |6 Dashboard and Reports provide IARs, OSJs and ACOs & Home Office real-time access to Account submission status User feedback positive with several suggested enhancements –Cloning for Household Accounts –Delegation for field admin usage Total number of approved submissions in the first three months: –4526 accounts

7. Guardian AAR Demonstration Pinpoint Global Communications Confidential |7