1. Regulation R Workshop Presented By: Satish G. Pattegar Fiduciary & Risk Management Association 2011 National Risk Management Training Conference April 20, 2011 10:30 AM – 11:30 AM Atlanta, GA

2. Did We Pass? Combined vs. Segregated Trust & Fiduciary Exemption Custody & Safekeeping Sweep & Money Market Funds

3. Did We Pass? Continued… Advertisement Compensation RReferral Awards CCampaigns BBonus Incentives RRewards RRecognition Programs EEtc.

4. How Involved Are We? Lead Coordinate Participate Implement Assess Review

5. Were There Independent Reviews? Outside Legal Internal Audit Self Assessments Regulators Consultants

6. How Did You Establish? Policies Procedures Database Administration & Logic Subject Matter Expert (SME) Oversight Escalation Documentation

7. Did You Balance Compliance Needs With Strategy? Share of Wallet Inclusive Technology Client Segregation Retention Initiatives Sales Practices

8. Did You Balance Compliance Needs With Strategy? Continued… Recognition Programs Incentive Programs Greater Than Nominal Referral Payments Accountability Oversight

9. Food For Thought Some Examples for Discussion –Plans vs. Scorecards –Discretionary –Referrals and Bonus Plans –Revenue Share in Long Mutual Funds –System History vs. Regulatory Requirements –Cost of Services

10. In Closing Frustrating as it may be, there is no relief and the regulators are carefully looking at how compliant the organizations are with Regulation R requirements

11. Q & A