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Regulatory Review

Bankers Financial Services takes pride in delivering service and attention to detail throughout our programs. The following is an example of our thorough due diligence with regulatory agencies during the development of the Market-Linked CD program and the responses we received back upon review of the program.

Washington Department of Financial Institutions Review (May 30, 2003)
"As of this date, the State of Washington Dept. of Financial Institutions-Division of Banks has no objection to banks selling equity-linked certificates of deposit, and investing in OTC options contracts as non-speculative risk management tools."

Arkansas State Bank Department Review (May 28, 2003)
Indexed CD Program Review

Colorado Department of Regulator Agencies Review (June 2003)
"It is the Division's position that Colorado state chartered banks, industrial banks, and depository trust companies have the authority to participate in the index-linked CD program as described in the materials provided to this office."

State of Idaho Department of Finance Review (November 1, 2002)
"The Idaho Bank Act is silent on the permissibility of specific investment instruments. The bank would expect a bank to perform a satisfactory due diligence assessment of any investment product or issue."

Iowa Division of Banking Indexed CD Policy Statement (August 2002)
Policy Statement and Board Resolution Guidelines from the Iowa Division of Banking for entering into Indexed CD program with BFS.

align="justify"Illinois Office of Banks & Real Estate Review #1 (August 5,2002)
Legal Counsel of IL Office of Banks & Real Estate stated that ..."The Agency does not object to state banks selling and investing in certificates of deposit offered through the BFS Program..."

Illinois Office of Banks & Real Estate Review #2 (January 29, 2003)
...the Agency is satisfied that BFS has taken sufficient steps to address Regulation DD issues related to the CDs.

Louisiana Office of Financial Institutions Review (July 3, 2003)
"While the Louisiana Banking Law is silent with respent to equity-linked certificates of deposits, LSA-R.S. 6:242(A)(1) states that a state bank may "receive any pay out deposits, with or without interest..."

Maine Department of Professional & Financial Regulation Review (June 3, 2003)
Indexed CD Program Review

State of Mississippi Department of Banking & Consumer Finance Review (August 2002)
Indexed CD Program Review

Kansas Office of the State Bank Commissioner Review (June 30, 2003)
"First, it is our opinion that Kansas state-chartered banks are authorized to sell these types of equity-linked certificates of deposits ("CD"), pursuant to the general authority given to banks in K.S.A. 9-1101, as amended, to receive deposits and pay interest on deposits."

Missouri Division of Finance Review (August 1, 2002)
The Acting Commissioner of the Missouri Division of Finance has stated that ..."Indexed CD's are a permissible product offering for Missouri state-chartered banks."

Nebraska Department of Banking and Finance Review (June 19, 2003)
"Yes, Equity-linked certificates of deposit are products Nebraska financial institutions may (and do) sell."

Oregon Department of Consumer & Business Services Review (May 21, 2003)
"The Oregon Bank Act does not prohibit or specifically address the issuance of indexed certificates of deposit. ORS 708A.400 provides that 'Oregon commercia banks may, consistent with applicable law and safe and sound banking practices, offer deposit accounts upon such terms and conditions as they consider appropriate."

Utah Department of Financial Institutions Review (December 2002)
The law is silent on the subject.

Wyoming Department of Audit - Division of Banking Review (June 20, 2003)
"The Wyoming banking statutes do not directly address equity indexed certificates of deposit. However, W.S. 13-2-101 does permit a state chartered bank to engage in any activity that is usual or incidental to the business of banking, and engage in any activity that is permissible for a national bank with the prior approval of the state banking commissioner. After review of the information submitted, our office would likely approve this activity if a request from a state chartered bank were received."

Virginia Bureau of Financial Institutions Review (June 11, 2003)
"The Bureau of Financial Institutions is not aware of any provision in the Virginia code, or any promulgated regulation thereunder, that would preclude a Virginia's state-chartered bank or savings and loan from issuing this type of certificate of deposit. In addition, this Bureau presently has issued no policy or guidance concerning this type of product."

FDIC Insurability (November 18, 2002)
Opinion of insurability of "Dow Jones Indexed Certificates of Deposit" and specific regulatory requirements.

Sound Liquidity Risk Management Practices in Community Banks
Policy Statment and Board Resolution Guidelines from the Iowa Division of Banking for entering into Indexed CD program with BFS.

Letter from Iowa Division of Banking (December 20, 2001)
Views of the Division of Banking with respect to time certificate of deposit


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