1. ROCA REPORT CARD Presented to Institute of International Bankers March 4, 2008

2. ROCA REPORT CARD 2007 Overview  3 Exam cycle review  Branches and Agencies Only  95 Examinations versus 97 in 2006

3. ROCA REPORT CARD Trend 2005 to 2007

4.  Average ratings this exam cycle versus prior exam cycles  Year2005 2006 2007  Risk 1.83 1.79 1.85  Operations 1.94 1.95 1.97  Compliance 2.05 2.07 2.22  Asset Quality 1.40 1.26 1.23 ROCA REPORT CARD

7.  Composite  Most recent exam 1.99  Prior exam cycle 1.97  Slight decline in the average composite ROCA  Risk Management, Compliance, and Operations declined  Asset Quality Improved

8. ROCA REPORT CARD  R isk – 7 Upgrades, 11 downgrades  O perations - 7 upgrades 9 downgrades  C ompliance 2 upgrades, 15 downgrades  A sset quality- 9 upgrades 4downgrades

9. ROCA REPORT CARD  Changes of 2 grades, all downgrades  Seen in all components, no composite ratings  1 each Risk, Ops, Compliance, Asset Quality

10. ROCA REPORT CARD  This data includes both Continuous supervision and point in time exams.  Alternate year and joint agency exams included.  Exams performed by FRBNY, FDIC and NYS

11. ROCA REPORT CARD  David S. Fredsall  Deputy Superintendent  Foreign and Wholesale Banks Division  New York State Banking Department  david.fredsall@banking.state.ny.us david.fredsall@banking.state.ny.us  www.banking.state.ny.us www.banking.state.ny.us