Evaluation Information Functional Assessment Evaluation Key Each capability

Evaluation Information

Functional Assessment Evaluation Key Each capability is rated to provide an indication of how the current platform enables or supports the desired functional business capability Rating 4 3 2 1 Detail Capability exists and is functionally operating today Capability exists, but is not functionally operating today; level of effort to enable the capability would be low / medium Capability exists, but is not functionally operating today; level of effort to enable the capability would be medium / high Capability does not exist and could not be supported by the platform Implication Considerations Business Differentiation (BD) ¡ Highlights the degree to which differentiating capabilities or objectives could be supported based on the Bank’s platform maturity Process Alignment (PA) ¡ Highlights the impact the maturity of the platforms have on supporting efficient and effective processes (e. g. , through automated workflow and proper controls) Customer Experience (CE) ¡ Highlights the impact which a customer or Bank associate may experience based on the Bank’s platform maturity Confidential 1

Functional Assessment Findings A. B. C. D. E. F. G. H. Consumer Deposits Small Business Deposits Commercial Deposits (including Treasury) National Direct Bank Deposit Operations Consumer Lending Small Business Lending Commercial Lending

Product Considerations

Functional Assessment Product Detailed Findings – Consumer Deposits Save More Ability to support planned Save More bundle to include the ability to add incremental transfers as assigned by the customer with each debit card and/or bill pay transaction; and to be able to offer ‘bonuses’ for the first of defined transaction types Day 1 3 3 Rate Builder Ability to support Rate. Builder (receive rate increases on “linked” savings account based on depth of relationship; could be balance level, debit usage, online bill pay, direct deposit, etc. in “linked” checking account) Post Day 1 2 2 Passbook Ability to support Passbook Savings product in the NY/NJ footprint only (no new markets) Day 1 4 Process Alignment Rewards Checking Ability to support Rewards Checking to include passing the transaction data by transaction type as appropriate for Rewards System use, posting ‘customer miles available’ on bank platform sales system, statements, and online banking Business Differentiation Company Y Rating Desired Features / Description Customer Experience Timing Client X Rating Product 3 Comments / Implications § PA: Potential for a significant amount of redevelopment work with respect to launching the Rewards Checking product on a new platform § CE: Linkage to Rewards platform must be established § BD: Functionality could be logically supported with the proper configuration in Company Y § Note: scheduled to rollout at Client X summer 2009 § BD: Functionality could be logically supported with the proper configuration in Company Y § PA: Functionality exists in Company Y to Day 1 4 2 support Passbooks but will require work effort to enhance Company Y/RDS integration, RDS functionality and teller hardware Note: The assessment of the Company Y platform is based on the current as-is integrated state. Future support for specific capabilities may differ from this assessment depending on specific integration decisions. Rating Key Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 4

Capability Considerations

Functional Assessment Capability Detailed Findings – Consumer Deposits 2. Develop Products & Services 2. 1 Ideate 2. 2 Perform Feasibility High Level Capabilities High Level Capability Description Timing Client X Rating Company Y Rating Support Non. Vanilla Products Ability to support advanced products beyond the current suite Day 1 4 3 Support Product Rate Changes / Tiers Ability to change rates quickly (including customization of tiers at the region / market level Day 1 4 4 Regionalize Product Ability to roll out and configure products by branch / region / bank Comments / Implications § BD / PA: RDS / Company Y is tabledriven; rules can be changed, although complexity depends on the offering § BD: Major profitability driver that would need to be supported § PA: Requires simple table change in Company Y § BD: Major profitability driver that would Day 1 4 2 need to be supported § PA: Not configured; would need configuration at Company Y to implement § BD: Major profitability driver that would 2. 3 Prioritize Initiatives Perform Exception Pricing Ability to perform exception pricing Day 1 4 3 need to be supported § CE: Potential negative impact to the customer if exception pricing changes § BD: Major profitability driver that would need to be supported 2. 4 Develop and Deliver Functionality Perform Relationship Pricing Ability to relationship price (rate or fee depends on criteria such as balance level, use of services like direct deposit or bill pay) § PA: Company Y has built in relationship Day 1 3 3 pricing features; would need to build the appropriate table with business rules § CE: Supports an improved customer experience 2. 5 Launch Note: The assessment of the Company Y platform is based on the current as-is integrated state. Future support for specific capabilities may differ from this assessment depending on specific integration decisions. Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 6

Functional Assessment Capability Detailed Findings – Consumer Deposits 2. Develop Products & Services High Level Capabilities High Level Capability Description Timing Client X Rating Company Y Rating Comments / Implications § BD: Both could support multiple sweep products 2. 1 Ideate 2. 2 Perform Feasibility Perform Relationship Pricing Ability to have unique SWEEP pricing schemes Day 1 3 3 Support Product Bundling Ability to support bundling of products (tie products together and modify rates, fees, and other features based on a la carte or bundle) Day 1 3 4 Ability to quickly change incentives for new product rollouts or other major changes Day 1 3 3 Ability to differentiate incentives / products by region potentially even branch Post Day 1 2 2 Ability to test incentives strategies by differing incentives in test branches vs. other baseline branches Post Day 1 2 2 Day 1 4 3 2. 3 Prioritize Initiatives Support Product Release 2. 4 Develop and Deliver Functionality 2. 5 Launch § PA: Sweep service charge pricing is handled by Weiland Account Analysis. Interest rates are balance tiered and table driven by Company Y sub-product type § CE: Company Y can exception price these accordingly § BD / CE: Bundling is a core part of Company Y product tables with flexibility to define different bundles easily § PA: Company Y has flexibility, but incentives are typically set at the beginning of the year § PA: Company Y tables can be configured New Products Ability to roll out new products at a rate of several per year (e. g. , on a quarterly basis) Converting Accounts with New Products Supports converting accounts to new product type without impacting account numbers, OLB, debit, etc. by region to support this functionality; current set up does not utilize regionalization § PA: Could support depending on the complexity of the product (would need to configure and test) § PA: Can potentially be done without Day 1 4 3 affecting the smart account number at Company Y § CE: Supports minimal impact to the customer Note: The assessment of the Company Y platform is based on the current as-is integrated state. Future support for specific capabilities may differ from this assessment depending on specific integration decisions. Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 7

Functional Assessment Capability Detailed Findings – Consumer Deposits 2. Develop Products & Services 2. 1 Ideate High Level Capabilities High Level Capability Description Timing Client X Rating Company Y Rating Debit Cards Ability to support 1 -step instant issuance & permanent card order with same day PIN & Sig usage Day 1 4 3 ‘Pretty Plastics’ Ability to maintain “pretty plastics” capabilities that exist within the current footprint Day 1 4 3 Personalize Debit Ability to personalize debit plastic (like Card Lab) Post Day 1 3 3 2. 2 Perform Feasibility Comments / Implications § CE: Real-time process in conducive to an enhanced CE at Company Y § Note: would likely use vendor (same as credit card) 2. 3 Prioritize Initiatives 2. 4 Develop and Deliver Functionality 2. 5 Launch Note: The assessment of the Company Y platform is based on the current as-is integrated state. Future support for specific capabilities may differ from this assessment depending on specific integration decisions. Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 8

Functional Assessment Capability Detailed Findings – Consumer Deposits High Level Capabilities 3. Market Products High Level Capability 3. 1 Plan Marketing Description Timing Client X Rating Company Y Rating Overdraft Functionality Support overdraft protection functionality that can link to multiple account types Day 1 3 4 Segment Based Marketing Ability to differentiate multiple marketing offers and themes on a single product (example: offer Bank at Work customer $100 to sign up for a new DDA and offer a student $50 to open the same account) 3. 2 Develop Creatives and Execute Marketing Promotional Codes Comments / Implications § BD: Sophisticated overdraft functionality at Company Y; can tie to DDA or HELOC § PA / CE: Company Y can define customer segments Day 1 4 2 § PA: May be able to tie a marketing campaign for a particular product to a defined segment § PA: Company Y uses package codes Ability to use promotional codes and have codes tied to automated benefits incenting direct deposit, debit usage, online bill pay, etc. stored in Company Y Day 1 4 3 § PA: May be some gaps in the way Company Y is able to deliver this functionality § PA: May be some gaps in the way Ability to use promotional codes to identify customers taking advantage of an offer and/or for use in establishing that accounts eligible for direct mail bonuses Day 1 4 2 Company Y is able to deliver this functionality § PA: Company Y has limited ability to track where an app came from § PA: Company Y can review outstanding offers or applications through RDS Offer / Promotion Tracking Ability to see what offers or promotions have been marketed or a customer has received § PA: Need to ensure branch staff is Post Day 1 3 3 appropriately trained § CE: Associates aren’t aware of offers customer has received and may duplicate offers § BD: Can perform conditional searches and Statement Messaging Ability to customize statement messaging Day 1 3 4 design messages § CE: Company Y can customize at the Customer level Note: The assessment of the Company Y platform is based on the current as-is integrated state. Future support for specific capabilities may differ from this assessment depending on specific integration decisions. Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 9

Functional Assessment Capability Detailed Findings – Consumer Deposits High Level Capabilities 4. Acquire Customers High Level Capability 4. 1 Perform Consultative Selling 4. 2 Open Account via Banker Description Timing Client X Rating Company Y Rating Comments / Implications § PA: Need to understand complexities at Channel Account Opening Ability to open accounts online, in the call center, or in the branch Sales Page Sales pages that support account opening are displayed to ensure that the CSR offers correct rates and products associated with the promotional offer given to the customer Day 1 Ability to capture profiling information for subsequent analysis Day 1 3 3 both banks with respect to automating the account creation process § PA: Online applications at Company Y are manually keyed by back-office § CE: Cannot fund via call center at Company Y § BD: Company Y doesn’t use Next Best 4 3 Offer functionality § BD: Associate can query RDS for pending offers § BD: Done thru salesforce. com – no 4. 3 Open Account via Call Center 4. 4 Open Account via Online Profiling 2 3 integration to RDS § PA: Used for notes; not driving relationships or offers Account Takeaway Ability to print or email a summary of what was purchased, what to expect next, contact info, Post Day 1 etc. for the customer to take with him / her 3 3 Channel Ability to start in one channel and end in another Post Day 1 2 3 Single Sign-on Single sign-on to a single system that interfaces with others as necessary Day 1 2 4 Duplicate Date Entry Supports the ability to not enter similar data into multiple systems at the time of new customer account opening § CE: Can support this process at Company Y but not in place today § CE: Unless an application is submitted, customer can not work across channels § PA: Company Y check and debit systems have SSO; ASP applications require additional sign-on § PA: Client X rekeys data from Touchpoint to other systems Day 1 2 4 § PA: Company Y enters data into Company Y – CIS first, CIS populates necessary account opening forms Note: The assessment of the Company Y platform is based on the current as-is integrated state. Future support for specific capabilities may differ from this assessment depending on specific integration decisions. Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 10

Functional Assessment Capability Detailed Findings – Consumer Deposits High Level Capabilities 4. Acquire Customers High Level Capability 4. 1 Perform Consultative Selling Description Timing Client X Rating Company Y Rating Comments / Implications § BD: If a customer exists in the CIS, can Existing Customer Information Population Ability to pre-fill customer info if the customer already has another Client X product (including Post Day 1 national businesses like Card / Auto) pre-populate information into application 2 3 § PA: Provides for a quicker, more efficient process § CE: If application is started, but not finished online, data not saved § BD: Sophisticated overdraft functionality at 4. 2 Open Account via Banker 4. 3 Open Account via Call Center Product Link Company Y; can tie to DDA or HELOC Ability to link card to DDA as overdraft protection Post Day 1 2 2 that may need to be built with the card organization § PA / CE: Company Y pull 19 credit Pulling Credit Ability to pull credit at the time of account opening Day 1 2 4 Pre-approval Ability to see if a customer is pre-approved for other Client X products (like a card) Day 1 2 3 Post Day 1 2 3 Fulfillment § PA: Complexity lies within the interface Ability to track fulfillment (ordered debit card, checks, other fulfillment items) elements for scoring at the time of account opening § PA: Not sophisticated; Teller receives prompts § PA / CE: Capability exists within RDS for tracking 4. 4 Open Account via Online Note: The assessment of the Company Y platform is based on the current as-is integrated state. Future support for specific capabilities may differ from this assessment depending on specific integration decisions. Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 11

Functional Assessment Capability Detailed Findings – Consumer Deposits High Level Capabilities 4. 5. Acquire Service Customers 5. 1 Process Customer Request 5. 2 Process Bank Initiated Transactions 5. 3 Manage Content 5. 4 Add Ancillary Products to Existing Account High Level Capability Description Timing Client X Rating Company Y Rating Customer Channel Preference Ability to specify which channel a customer prefers and then primarily manage communication through that channel Post Day 1 3 3 Comments / Implications § PA: No push-messaging capabilities between online and contact center § CE: Company Y customers can set preferences online and for ATM § BD / CE: No current external offer Sales Management Service to sales capabilities in the call centers Day 1 3 3 Channel Servicing Ability to service accounts through all channels (including most national product transactions / changes) Day 1 3 3 Issue Management (Follow-Up) Issue management system would have the capability to generate a tickler to remind Post Day 1 banker to call the customer (possibly upload to bankers’ calendar) Statements Ability to provide combined statements (all Client X products) with customized inserts / messaging Reporting Ability to support reporting and query access to debit maintenance & transaction history management system in place at Company Y § CE: Company Y can service all products through all channels – card servicing handled by JPMC § CE: Supportforce. com is not integrated 2 2 with RDS § BD / CE: Issue management handled through Contact Center § CE: Company Y statements are fully Day 1 (national products Post Day 1) 2 4 Day 1 4 4 integrated and provide the customer with a view of their entire product portfolio § CE: Potential for Company Y customers to lose statement options / functionality § PA: Can view 120 day transaction history online in Company Y; older history via IBM Content Manager (. pdf) 5. 5 Manage Banking Operations Note: The assessment of the Company Y platform is based on the current as-is integrated state. Future support for specific capabilities may differ from this assessment depending on specific integration decisions. Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 12

Functional Assessment Capability Detailed Findings – Consumer Deposits High Level Capabilities 5. Service Customers High Level Capability 5. 1 Process Customer Request Real-time ATM / Debit Ability to view in real-time, all ATM / debit transactions (including OLB) Timing Client X Rating Company Y Rating Post Day 1 1 4 Comments / Implications § BD / CE: Customer is able to view deposit real-time with Company Y § CE: Company Y truncates some ACH data Transactional Data Ability to view ACH data including: who it was from, origination, ability to gain additional transactional data (where purchase was made) Data Retention (Viewing) Increase transaction data retention, with ability to see 10 months (history online, currently Post Day 1 have to manually pull statements) 5. 2 Process Bank Initiated Transactions 5. 3 Manage Content Description TBD 3 2 2 3 (e. g. , merchant number gets cut off after 15 characters) § CE: Company Y can define reports as file feeds through OBS (new file type) direct from Pep+ § PA: Current ability to view only 120 days of transaction data online via Company Y § PA: 16 months storage online for estatements § BD: Company Y does real-time online Deposit Posting Provide the ability for “same day” posting of deposits Post Day 1 1 4 deposit posting § CE: Improved CE with the ability to realize transactions real-time 5. 4 Add Ancillary Products to Existing Account Waive Fees Support the ability to waive fees and capture the details of the decision to do so (e. g. , NSF Fee) § BD / PA / CE: RDS provides ability to Day 1 3 3 waive fees (with ceiling set for approvals) § Follow-up on ability to waive particular fees would be necessary 5. 5 Manage Banking Operations Note: The assessment of the Company Y platform is based on the current as-is integrated state. Future support for specific capabilities may differ from this assessment depending on specific integration decisions. Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 13

Functional Assessment Capability Detailed Findings – Consumer Deposits 6. Manage Customer Relationships 6. 1 Manage Portfolio 6. 2 Execute Customer Management Strategy High Level Capabilities High Level Capability Description Timing Client X Rating Company Y Rating Prompts Ability to provide pop-ups or other prompts to customer-facing associates based on a rules engine with business logic (includes CTI screen flash, Mindshare Survey) Post Day 1 2 3 Customer Relationships Ability to see full customer relationship (including national products like Card and Auto) Day 1 3 4 Comments / Implications § BD / CE: Current capability is not sophisticated; Teller receives prompts; cross-selling is more manual § BD / PA / CE: Fully integrated customer view bolsters servicing experience § PA: Transaction activity on RDS is Transaction / Contact Viewing Ability to see recent transactions and contacts (calls to the call center, complaints, etc. ) Day 1 3 3 available for up to 120 days; 16 months online § CE: Branch associate can not see all customer activity (e. g. , complaints) § PA: Doesn’t aesthetically treat the 6. 3 Retain Customers 6. 4 Solicit Customer Feedback Differentiated Serving Differentiated servicing in the call centers and branches based on the customer value / segment Post Day 1 3 3 customers any differently; Platinum go to separate line § CE: Differentiated service levels based on customers core § CE: Stored at the account level and used for defined benefits § CE: Company Y house-holding defined at Householding Ability to household customers Day 1 4 3 the customer level § CE: Limitation - can be changed in branch or over the phone; not online Maintain Notes / Event History Support the maintenance of system generated and associate notes on a customer's account § PA: Customer notepad provided through Day 1 4 salesforce. com, but not integrated with RDS 3 Note: The assessment of the Company Y platform is based on the current as-is integrated state. Future support for specific capabilities may differ from this assessment depending on specific integration decisions. Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 14

Functional Assessment Capability Detailed Findings – Consumer Deposits 6. Manage Customer Relationships 6. 1 Manage Portfolio 6. 2 Execute Customer Management Strategy High Level Capabilities High Level Capability Description Timing Client X Rating Company Y Rating Fee Waivers Systematized fee waiver authority where the system dictates who has the ability to waiver certain fees under certain circumstances (e. g. , Call Center Associate can waive NSF fees for 1 st time offenders, but only State Heads can waive TM service charges) Post Day 1 2 3 Engagement Need to be able to easily identify use of sticky services and Treasury Management services (e. g. , branch knows that Client-A has a debit card, uses Treasury Optimizer, and has Merchant Services) Day 1 4 4 Consumer Complaints Require one interface for front end system to see customer complaints and know all relationships with customer and all interactions Post Day 1 2 2 6. 3 Retain Customers Overdraft Visibility 6. 4 Solicit Customer Feedback Rewards Comments / Implications § BD / CE: Can perform refunds and may support true fee waivers, but functionality is not currently being utilized § BD / CE: Done via reporting § CE: Salesforce records notes on the customer - not integrated with RDS § CE / PA: Banker can only see complaints if they have been typed in notes (in RDS) Ability to show returns and trail of returns (post what was returned to customer if chose ‘not to pay’) Day 1 3 4 Provide automated enrollment and updates to Rewards Money Market Accounts and Branch Rewards Checking accounts on the vendor Rewards platform TBD 2 Ability to update the existing Rewards Credit Card number on a Rewards Money Market account TBD § PA / CE: Feature is available thru RDS for the branch associate and call center agent § BD / CE: Reward functionality at Company Y is less robust than at Client X § Deeper dive is required § BD / CE: Reward functionality at Company TBD Y is less robust than at Client X 2 § Deeper dive is required Note: The assessment of the Company Y platform is based on the current as-is integrated state. Future support for specific capabilities may differ from this assessment depending on specific integration decisions. Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 15

Functional Assessment Findings A. B. C. D. E. F. G. H. Consumer Deposits Small Business Deposits Commercial Deposits (including Treasury) National Direct Bank Deposit Operations Consumer Lending Small Business Lending Commercial Lending

Product Considerations

Functional Assessment Product Detailed Findings – Small Business Deposits Save More Ability to support planned Save More bundle to include the ability to add incremental transfers as assigned by the customer with each debit card and/or bill pay transaction; and to be able to offer ‘bonuses’ for the first of defined transaction types Day 1 3 3 Rate Builder Ability to support Rate. Builder (receive rate increases on “linked” savings account based on depth of relationship; could be balance level, debit usage, online bill pay, direct deposit, etc. in “linked” checking account) Post Day 1 2 2 Day 1 4 Process Alignment Rewards Checking Ability to support Rewards Checking to include passing the transaction data by transaction type as appropriate for Rewards System use, posting ‘customer miles available’ on bank platform sales system, statements, and online banking Business Differentiation Company Y Rating Desired Features / Description Customer Experience Timing Client X Rating Product 3 Comments / Implications § PA: Potential for a significant amount of redevelopment work with respect to launching the Rewards Checking product on a new platform § CE: Linkage to Rewards platform must be established § BD: Functionality could be logically supported with the proper configuration in Company Y § Note: scheduled to rollout at Client X summer 2009 § BD: Functionality could be logically supported with the proper configuration in Company Y § BD: Company Y currently has Business and Public Checking, Savings, and Money Market Continue to support all Public Product types Day 1 4 3 Public Checking, Savings, and Money market Accounts § BD: Additional product functionality could be logically supported with the proper configuration in Company Y § Currently verifying Money Markets can be Business Money Markets (Small Business Prime) Continue to support Business Money Markets (both SB Prime and Tiered) Day 1 4 TBD Commercial Savings Continue to support Commercial Savings Day 1 4 4 Commercial CDs Continue to support Commercial CDs Day 1 4 4 Check Management Ability to search for check over date range Day 1 4 3 tiered with Person B (Company Y Cash Mgmt Services) § BD / CE: Commercial Savings product available at Company Y § BD / CE: Company Y currently supports Commercial CDs § BD / CE: Ability to search transaction over date range but not images which have the ability for point search Rating Key Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 18

Functional Assessment Product Detailed Findings – Small Business Deposits Client X Rating Company Y Rating 2 Continue to support escrow, including sub accounts, in all states Day 1 4 Support 1031 Escrow Management Accounts including split interest between ‘master’ and ‘sub accounts’ Day 1 4 2 Require flexible pricing capabilities at the sub account level Day 1 4 2 Data needed to feed into CIS; view all relationships Day 1 1 3 Automate split interest calculation or need to work with manual split interest procedures Day 1 3 2 Perform dual reporting (master earned and sub account Day 1 earned) 3 2 Automated control over open and closing within the branch (real time) Post Day 1 2 2 Business Differentiation Timing Process Alignment Escrow Management Desired Features / Description Customer Experience Product Comments / Implications § PA / BD: Supporting parent /child Overdraft protection Support overdraft protection functionality that can link to multiple account types Day 1 3 4 Controlled Disbursement Continue to support controlled disbursements Day 1 4 4 relationship for escrow and tenant accounts are possible via Company Y § Note: Any escrow and tenant functionality has not been utilized by Company Y and additional research is required to identify the degree of any enhancements required to support (e. g. , new modules) § Note: Company Y recommended mainframe service (to perform full multi-tier ZBA, Escrow Management and Sweep functionality), Agiletics, scoped and scheduled for installation this year prior to the purchase announcement § BD: Sophisticated overdraft functionality at Company Y; can tie to DDA or HELOC § BD: Support disbursements with check only (no ACH) § BD: Company Y utilizes Company Y based ZBA/Target Balance Accounts CD Rom Check Service Continue to support zero balance and target balance accounts Day 1 4 4 Ability to flag for CD-Rom on host and index to check/item Day 1 4 4 sweep functionality to provide Zero Balance Accounts § CE: Multi-tiered ZBAs are available, but are discouraged due to the processing balance not reporting balances in all tiers (recommended Agiletics mainframe) § PA / BD: Image administrator passes to CD Rom which gets flagged on Company Y and recon file gets downloaded to process Rating Key Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 19

Functional Assessment Product Detailed Findings – Small Business Deposits Client X Rating Company Y Rating 2 Support for Euro, Repo, and Loan sweeps Day 1 4 Ability to have unique sweep pricing schemes Day 1 4 3 Require built in pricing flexibility (market level pricing) Day 1 4 2 Loan to DDA sweeps with ability to group deposits as a loan accounting requirement Day 1 3 2 Ability to flag accounts for account analysis Day 1 4 4 Ability to suppress hard charges and hard charge from DDA system Day 1 4 4 Ability for analysis statement illustrating earnings credit rate and service charges (calculation of excess) Day 1 4 4 Sweeps Account Analysis Business Differentiation Timing Process Alignment Desired Features / Description Customer Experience Product Comments / Implications § BD: Company Y could support multiple sweep products (investment sweep connected to ZBA sub account) with exception pricing § BD: Company Y currently performing Investment and Repo sweeps (not Euro; Loan dependent upon image exchange functionality) § PA: Sweep pricing would tie in the entire Company Y suite with need for proper feeds from other external places § Note: Sweep service charge pricing is handled by Weiland Account Analysis; interest rates are balance tiered and table driven by Company Y sub-product type § PA: Account analysis is driven by sub product code in Company Y § PA: Once account is switched to account analysis in Company Y, all hard charges are suppressed and no longer hit account § PA / BD: Any earnings credit rate and service charges on Weiland; Company Y will also do basics of service charges (earnings credit for balances to off set) § BD: Do not deliver same day check detail or images Controlled Disbursement Ability to deliver same day check detail report to customers Day 1 4 2 Ability to issue summary report includes fed items, on us (internal processing), ACH, same day Day 1 4 3 § BD: Given the limited number of Company Y customers on disbursement and current needs based process, this warrants further analysis of the ability § BD / CE: Any items sent to the fed return the next morning of which summary could be issued Rating Key Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 20

Functional Assessment Product Detailed Findings – Small Business Deposits Client X Rating Company Y Rating 4 Ability to flag accounts for outgoing data exchange Day 1 4 Ability to send account to multiple BAI 2 Destinations Day 1 4 4 Ability to selectively send transactions and balance outbound (BAI 2) Day 1 4 1 BAI 2 - host transaction codes need to be translated to BAI 2 codes Day 1 4 4 BAI 2 - host information balances and transaction needs to be transferred to BAI 2 format Day 1 4 4 BAI 2 – ability to flag accounts to identify as an information reporting account Day 1 4 4 Business Differentiation Timing Process Alignment Data Exchange Desired Features / Description Customer Experience Product Comments / Implications § PA: Company Y supports a corporate banking code to flag for outgoing data exchange § PA: Company Y can deliver to multiple end points, although, requires separate corporate banking code § PA: Do not have the option to selectively send, and have not pursued other options § PA: Company Y stores a translation table, Balance Reporting Ability to transfer between different banks and generate due settlement for bank transfers Day 1 4 2 Ability to select book transfers based on balance availability or Not Day 1 4 4 Book Transfers therefore, when balance reporting files are created, reporting in BAI 2 codes that service § BD: Transfer able to be completed in BAI 2 format § PA: Company Y supports a corporate banking exchange code § BD: Internal transfers performed real time § Note: This was noted as a follow-up item for the Company Y deposits team, although initially perceived as doable § PA: Company Y default availability is ZBA limit system, with ACH risk limit, daily overdraft limit, next day availability limit § PA / BD: All commercial accounts month Ability to generate sweep reports, cycle statements, daily stats Day 1 4 4 Ability to generate account analysis reports Day 1 4 2 Bank Reporting end (although able to have special requests) § BD: Statements following business day have archive with. pdf § CE / BD: Hard copy statements mailed out after tenth business day; current manual entries post items off of Weiland Rating Key Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 21

Capability Considerations

Functional Assessment Capability Detailed Findings – Small Business Deposits 2. Develop Products & Services 2. 1 Ideate High Level Capabilities High Level Capability Description Timing Client X Rating Company Y Rating Support Non. Vanilla Products Ability to support advanced products beyond the current suite Day 1 4 3 Support Product Rate Changes / Tiers Ability to change rates quickly (including customization of tiers at the region / market level Day 1 Regionalize Products Ability to roll out and configure products by branch / region / bank Day 1 Comments / Implications § BD / PA: RDS / Company Y is tabledriven; rules can be changed, although complexity depends on the offering § BD: Major profitability driver that would 4 4 need to be supported § PA: Requires simple table change in Company Y § BD: Major profitability driver that would 2. 2 Perform Feasibility 4 2 need to be supported § PA: Not configured; would need configuration at Company Y to implement § BD: Major profitability driver that would Perform Exception Pricing Ability to perform exception pricing Day 1 4 3 need to be supported § CE: Potential negative impact to the customer if exception pricing changes 2. 3 Prioritize Initiatives § BD: Major profitability driver that would need to be supported 2. 4 Develop and Deliver Functionality Ability to relationship price (rate or fee depends on criteria such as balance level, use of services like direct deposit or bill pay) § PA: Company Y has built in relationship Day 1 3 3 Perform Relationship Pricing pricing features; would need to build the appropriate table with business rules § CE: Supports an improved customer experience § BD: Both could support multiple sweep products § PA: Sweep service charge pricing is Ability to have unique SWEEP pricing schemes Day 1 3 3 2. 5 Launch Process Key In Scope L 0 Process L 1 Process Performed handled by Weiland Account Analysis. Interest rates are balance tiered and table driven by Company Y sub-product type § CE: Company Y can exception price these accordingly Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 23

Functional Assessment Capability Detailed Findings – Small Business Deposits 2. Develop Products & Services High Level Capabilities High Level Capability Support Product Bundling 2. 1 Ideate 2. 2 Perform Feasibility 2. 3 Prioritize Initiatives Support Product Release Description Timing Client X Rating Company Y Rating Ability to support bundling of products (tie products together and modify rates, fees, and other features based on a la carte or bundle) Day 1 3 4 Ability to quickly change incentives for new product rollouts or other major changes Day 1 3 3 Comments / Implications § BD / CE: Bundling is a core part of Company Y product tables with flexibility to define different bundles easily § PA: Company Y has flexibility, but incentives are typically set at the beginning of the year § PA: Company Y tables can be configured Ability to differentiate incentives / products by region potentially even branch Post Day 1 2 2 Ability to test incentives strategies by differing incentives in test branches vs. other baseline branches Post Day 1 2 2 Day 1 4 3 by region to support this functionality; current set up does not utilize regionalization § PA: Could support depending on the New Products Ability to roll out new products at a rate of several per year (e. g. , on a quarterly basis) Converting Accounts with New Products Supports converting accounts to new product type without impacting account numbers, OLB, debit, etc. Day 1 4 3 Debit Cards Ability to support 1 -step instant issuance & permanent card order with same day PIN & Sig usage Day 1 4 3 Rate Tiers Customize interest rate tiers at a regional or market level 4 4 complexity of the product (would need to configure and test) § PA: Can potentially be done without 2. 4 Develop and Deliver Functionality Day 1 affecting the smart account number at Company Y § CE: Supports minimal impact to the customer § CE: Real-time process in conducive to an enhanced CE at Company Y § PA: Requires simple table change in Company Y 2. 5 Launch Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 24

Functional Assessment Capability Detailed Findings – Small Business Deposits 2. Develop Products & Services High Level Capabilities High Level Capability Description Timing Client X Rating Company Y Rating Day 1 3 3 § PA: Company Y has flexibility, but Ability to quickly change incentives for new product rollouts or other major changes 2. 1 Ideate 2. 2 Perform Feasibility Support Product Release New Products Comments / Implications incentives are typically set at the beginning of the year § PA: Company Y tables can be configured Ability to differentiate incentives / products by region potentially even branch Post Day 1 2 2 Day 1 4 3 Ability to roll out new products at a rate of several per year (e. g. , on a quarterly basis) by region to support this functionality; current set up does not utilize regionalization § PA: Could support depending on the complexity of the product (would need to configure and test) 2. 3 Prioritize Initiatives 2. 4 Develop and Deliver Functionality 2. 5 Launch Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 25

Functional Assessment Capability Detailed Findings – Small Business Deposits High Level Capabilities 3. Market Products 3. 1 Plan Marketing High Level Capability Description Timing Client X Rating Company Y Rating Overdraft Functionality Support overdraft protection functionality that can link to multiple account types Day 1 3 4 Segment Based Marketing Ability to differentiate multiple marketing offers and themes on a single product (example: offer Bank at Work customer $100 to sign up for a new DDA and offer a student $50 to open the same account) 3. 2 Develop Creatives and Execute Marketing Promotional Codes Comments / Implications § BD: Sophisticated overdraft functionality at Company Y; can tie to DDA or HELOC § PA / CE: Company Y can define customer segments Day 1 4 2 § PA: May be able to tie a marketing campaign for a particular product to a defined segment § PA: Company Y uses package codes Ability to use promotional codes and have codes tied to automated benefits incenting direct deposit, debit usage, online bill pay, etc. stored in Company Y Day 1 4 3 § PA: May be some gaps in the way Company Y is able to deliver this functionality § PA: May be some gaps in the way Ability to use promotional codes to identify customers taking advantage of an offer and/or for use in establishing that accounts eligible for direct mail bonuses Day 1 4 2 Company Y is able to deliver this functionality § PA: Company Y has limited ability to track where an app came from § PA: Company Y can review outstanding offers or applications through RDS Offer / Promotion Tracking Ability to see what offers or promotions have been marketed or a customer has received § PA: Need to ensure branch staff is Post Day 1 3 3 appropriately trained § CE: Associates aren’t aware of offers customer has received and may duplicate offers § BD: Can perform conditional searches and Statement Messaging Ability to customize statement messaging Day 1 3 4 design messages § CE: Company Y can customize at the Customer level Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 26

Functional Assessment Capability Detailed Findings – Small Business Deposits High Level Capabilities 4. Acquire Customers High Level Capability Description Timing Client X Rating Company Y Rating Comments / Implications § PA: Need to understand complexities at 4. 1 Perform Consultative Selling 4. 2 Open Account via Banker Channel Account Opening Ability to open accounts online, in the call center, or in the branch Sales Page Sales pages that support account opening are displayed to ensure that the CSR offers correct rates and products associated with the promotional offer given to the customer Day 1 3 3 both banks with respect to automating the account creation process § PA: Online applications at Company Y are manually keyed by back-office § CE: Cannot fund via call center at Company Y § BD: Company Y doesn’t use Next Best Day 1 4 3 Offer functionality § BD: Associate can query RDS for pending offers § BD: Done thru salesforce. com – no 4. 3 Open Account via Call Center 4. 4 Open Account via Online Profiling Ability to capture profiling information for subsequent analysis Account Takeaway Ability to print or email a summary of what was purchased, what to expect next, contact info, Post Day 1 etc. for the customer to take with him / her 3 3 Channel Ability to start in one channel and end in another Post Day 1 2 3 Single Sign-on Single sign-on to a single system that interfaces with others as necessary Day 1 2 4 Duplicate Date Entry Supports the ability to not enter similar data into multiple systems at the time of new customer account opening Day 1 2 3 integration to RDS § PA: Used for notes; not driving relationships or offers § CE: Can support this process at Company Y but not in place today § CE: Unless an application is submitted, customer can not work across channels § PA: Company Y check and debit systems have SSO; ASP applications require additional sign-on § PA: Client X rekeys data from Touchpoint to other systems Day 1 2 4 Y – CIS first, CIS populates necessary account opening forms Process Key In Scope L 0 Process L 1 Process Performed § PA: Company Y enters data into Company Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 27

Functional Assessment Capability Detailed Findings – Small Business Deposits High Level Capabilities 4. Acquire Customers High Level Capability Description Timing Client X Rating Company Y Rating Comments / Implications § BD: If a customer exists in the CIS, can 4. 1 Perform Consultative Selling Existing Customer Information Population Ability to pre-fill customer info if the customer already has another Client X product (including Post Day 1 national businesses like Card / Auto) pre-populate information into application 2 3 § PA: Provides for a quicker, more efficient process § CE: If application is started, but not finished online, data not saved § BD: Sophisticated overdraft functionality at Product Link 4. 2 Open Account via Banker 4. 3 Open Account via Call Center Post Day 1 2 2 § PA: Complexity lies within the interface that may need to be built with the card organization § PA / CE: Company Y pull 19 credit Pulling Credit Ability to pull credit at the time of account opening Day 1 2 4 Pre-approval Ability to see if a customer is pre-approved for other Client X products (like a card) Day 1 2 3 Post Day 1 2 3 Day 1 2 TBD Fulfillment 4. 4 Open Account via Online Company Y; can tie to DDA or HELOC Ability to link card to DDA as overdraft protection Ability to track fulfillment (ordered debit card, checks, other fulfillment items) Remote Sales Private Bankers should have access to their own set of new account numbers (vs. needing to call the branches to get an account number in order to open a new market) CIP and Borrower Type Ability to recognize borrower type to prompt the relevant CIP questions elements for scoring at the time of account opening § PA: Not sophisticated; Teller receives prompts § PA / CE: Capability exists within RDS for tracking § PA / CE: Unique account numbers exists outside of branch for SB; accessed through banker support group § BD / PA: Circumventing CIP based on Post Day 1 1 2 Process Key In Scope L 0 Process L 1 Process Performed account type and how customers are related to the accounts § Note: Any CIP updates integrate real-time to CIS Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 28

Functional Assessment Capability Detailed Findings – Small Business Deposits High Level Capabilities 4. Acquire Customers High Level Capability Description Timing Client X Rating Company Y Rating Comments / Implications § PA: Can potentially be done without 4. 1 Perform Consultative Selling Ability to convert customers from one product Account Numbers to another while maintaining the same account numbers. Day 1 3 3 affecting the smart account number at Company Y § CE: Supports minimal impact to the customer § PA: Ability to change sub product code in 4. 2 Open Account via Banker Account Analysis Auto add account to analysis vs. completing a form (manually required Day 1; automated required Post Day 1) Post Day 1 1 2 Company Y to redefine account for account analysis, however, requires manual Weiland entry § CE: Company Y can perform some account analysis, “Commercial Analyze Checking” for basic check and deposit items, within limits (e. g. , not tiered) 4. 3 Open Account via Call Center 4. 4 Open Account via Online Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 29

Functional Assessment Capability Detailed Findings – Small Business Deposits High Level Capabilities 5. Service Customers 5. 1 Process Customer Request 5. 2 Process Bank Initiated Transactions 5. 3 Manage Content 5. 4 Add Ancillary Products to Existing Account High Level Capability Description Customer Channel Preference Ability to specify which channel a customer prefers and then primarily manage communication through that channel Timing Client X Rating Company Y Rating § PA: No push-messaging capabilities Post Day 1 3 3 between online and contact center § CE: Company Y customers can set preferences online and for ATM § BD / CE: No current external offer Sales Management Service to sales capabilities in the call centers Day 1 3 3 Channel Servicing Ability to service accounts through all channels (including most national product transactions / changes) Day 1 3 3 2 2 Issue Management (Follow-Up) Comments / Implications management system in place at Company Y § CE: Company Y can service all products Issue management system would have the capability to generate a tickler to remind Post Day 1 banker to call the customer (possibly upload to bankers’ calendar) Ability to enter in type of maintenance being performed to inform the customer (for tracking Post Day 1 purposes) through all channels – card servicing handled by JPMC § CE: Supportforce. com is not integrated with RDS § BD / CE: Issue management handled through Contact Center § CE: Supportforce. com is not integrated 1 2 with RDS § BD / CE: Issue management handled through Contact Center § CE: Company Y statements are fully Statements 5. 5 Manage Banking Operations Reporting Ability to provide combined statements (all Client X products) with customized inserts / messaging Day 1 4 4 Ability to suppress statements, duplicate statements, boxing statements (RE clients), combine statements Day 1 4 TBD Ability to support reporting and query access to debit maintenance & transaction history Day 1 4 4 § CE: Follow-up with Joe Matusek L 1 Process Performed (Company Y Treasury Mgmt Services / Deposit Operations) in progress § PA: Can view 120 day transaction history Process Key In Scope L 0 Process integrated and provide the customer with a view of their entire product portfolio § CE: Potential for Company Y customers to lose statement options / functionality online in Company Y; older history via IBM Content Manager (. pdf) Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 30

Functional Assessment Capability Detailed Findings – Small Business Deposits High Level Capabilities 5. Service Customers High Level Capability Real-time ATM / Debit 5. 1 Process Customer Request 5. 2 Process Bank Initiated Transactions Description Ability to view in real-time, all ATM / debit transactions (including OLB) Timing Client X Rating Company Y Rating Post Day 1 1 4 Comments / Implications § BD / CE: Customer is able to view deposit real-time with Company Y § CE: Company Y truncates some ACH data Transactional Data Ability to view ACH data including: who it was from, origination, ability to gain additional Post Day 1 transactional data (where purchase was made) Data Retention (Viewing) Increase transaction data retention, with ability Post Day 1 to see 10 months (history online, currently have to manually pull statements) 2 Provide the ability for “same day” posting of deposits 1 1 2 (e. g. , merchant number gets cut off after 15 characters) § CE: Company Y can define reports as file feeds through OBS (new file type) direct from Pep+ § PA: Current ability to view only 120 days 3 of transaction data online via Company Y § PA: 16 months storage online for estatements § BD: Company Y does real-time online 5. 3 Manage Content 5. 4 Add Ancillary Products to Existing Account Deposit Posting Post Day 1 4 deposit posting § CE: Improved CE with the ability to realize transactions real-time Multiple Payment Options Support multiple payment options Waive Fees Multiple User Profiles TBD TBD Support the ability to waive fees and capture the details of the decision to do so Day 1 3 3 Support multiple user profiles with different security access TBD TBD § BD: § PA: § CE: § BD / PA / CE: RDS provides ability to waive fees (with ceiling set for approvals) § BD: § PA: § CE: 5. 5 Manage Banking Operations Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 31

Functional Assessment Capability Detailed Findings – Small Business Deposits High Level Capabilities 5. Service Customers High Level Capability Description Timing Client X Rating Company Y Rating Comments / Implications § PA / CE: Ability to vary float at customer 5. 1 Process Customer Request Support float application (including float removals and custom floats) Floats Day 1 4 4 level thru customer scoring and database solution § PA: RDS identifies what the float should be based on item or thru an exception table § PA: RDS performs query and research 5. 2 Process Bank Initiated Transactions Debit Research Ability to pull debit research quickly for customer inquiries Post Day 1 2 and also ability to search within imaging (have flexibility here); CCOA search capabilities require additional interfaces to perform search functionality (e. g. , miscellaneous debits) 2 5. 3 Manage Content 5. 4 Add Ancillary Products to Existing Account 5. 5 Manage Banking Operations Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 32

Functional Assessment Capability Detailed Findings – Small Business Deposits 6. Manage Customer Relationships 6. 1 Manage Portfolio High Level Capabilities High Level Capability Description Timing Client X Rating Company Y Rating Prompts Ability to provide pop-ups or other prompts to customer-facing associates based on a rules engine with business logic (includes CTI screen flash, Mindshare Survey) Post Day 1 2 3 Customer Relationships Ability to see full customer relationship (including national products like Card and Auto) Day 1 3 4 Transaction / Contact Viewing Ability to see recent transactions and contacts (calls to the call center, complaints, etc. ) Comments / Implications § BD / CE: Current capability is not sophisticated; Teller receives prompts; cross-selling is more manual § BD / PA / CE: Fully integrated customer view bolsters servicing experience § PA: Transaction activity on RDS is 6. 2 Execute Customer Management Strategy Day 1 3 3 available for up to 120 days; 16 months online § CE: Branch associate can not see all customer activity (e. g. , complaints) § PA: Doesn’t aesthetically treat the 6. 3 Retain Customers Differentiated Serving Differentiated servicing in the call centers and branches based on the customer value / segment Post Day 1 3 4 customers any differently; Platinum go to separate line § CE: Differentiated service levels based on customers core § CE: Stored at the account level and used for defined benefits § CE: Company Y house-holding defined at 6. 4 Solicit Customer Feedback Householding Ability to household customers Day 1 4 3 the customer level § CE: Limitation - can be changed in branch or over the phone; not online Fee Waivers Systematized fee waiver authority where the system dictates who has the ability to waiver certain fees under certain circumstances (e. g. , Call Center Associate can waive NSF fees for 1 st time offenders, but only State Heads can waive TM service charges) § BD / CE: Can perform refunds and may Post Day 1 2 Process Key In Scope L 0 Process L 1 Process Performed support true fee waivers, but functionality is not currently being utilized 3 Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 33

Functional Assessment Capability Detailed Findings – Small Business Deposits 6. Manage Customer Relationships High Level Capabilities High Level Capability Description Timing Client X Rating Company Y Rating Engagement Need to be able to easily identify use of sticky services and Treasury Management services (e. g. , branch knows that Client-A has a debit card, uses Treasury Optimizer, and has Merchant Services) Day 1 4 2 Consumer Complaints Require one interface for front end system to see customer complaints and know all relationships with customer and all interactions 6. 1 Manage Portfolio 6. 2 Execute Customer Management Strategy Post Day 1 2 2 Day 1 3 4 Maintain Notes / Event History Support the maintenance of system generated and associate notes on a customer's account Day 1 4 3 TBD 2 Rewards Provide automated enrollment and updates to Rewards Money Market Accounts and Branch Rewards Checking accounts on the vendor Rewards platform Ability to update the existing Rewards Credit Card number on a Rewards Money Market account TBD L 1 Process Performed § PA / CE: Feature is available thru RDS for the branch associate and call center agent § PA: Customer notepad provided through salesforce. com, but not integrated with RDS § BD / CE: Reward functionality at Company Y is less robust than at Client X § Deeper dive is required § BD / CE: Reward functionality at Company TBD Y is less robust than at Client X 2 § Deeper dive is required Process Key In Scope L 0 Process customer - not integrated with RDS § CE / PA: Banker can only see complaints if they have been typed in notes (in RDS) Ability to show returns and trail of returns (post what was returned to customer if chose ‘not to pay’) 6. 4 Solicit Customer Feedback § BD / CE: Done via reporting § CE: Salesforce records notes on the Overdraft Visibility 6. 3 Retain Customers Comments / Implications Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 34

Functional Assessment Capability Detailed Findings – Small Business Deposits 6. Manage Customer Relationships High Level Capabilities High Level Capability Industry Codes 6. 1 Manage Portfolio Description Timing Ability to classify an account / client as belonging to a specific SIC/NAICS industry code Client X Rating Company Y Rating Comments / Implications § PA: Company Y can accept a variety of Post Day 1 3 4 inputs related to code § PA: Ability to add to flag a SBB / Commercial customer 6. 2 Execute Customer Management Strategy 6. 3 Retain Customers 6. 4 Solicit Customer Feedback Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 35

Functional Assessment Capability Detailed Findings – Small Business Deposits High Level Capabilities 7. Sell Loans High Level Capability Description Timing Client X Rating Company Y Rating Comments / Implications § BD: § PA: § CE: N/A 7. 1 Sell Loans to Investors 7. 2 Manage Distributions Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 36

Functional Assessment Capability Detailed Findings – Small Business Deposits High Level Capabilities 8. Manage Recoveries and Collections High Level Capability Charge Offs Description Timing Perform charge off, reverse charge–offs, and recovers Client X Rating Company Y Rating 3 4 § PA / CE: Company Y currently performs Day 1 8. 1 Manage Collections 8. 2 Manage Recoveries Comments / Implications (although, different group does for lending vs. deposit) § PA: Performed by Company Y Fraud Ability to support leading edge Fraud Management tools Day 1 2 3 NSF Ability to charge NSF fees directly to subaccount vs. direct to master account Day 1 3 2 8. 3 Detect and Prevent L 1 Process Performed § PA: Sub accounts in Company Y hard charged NSF or Weiland, bundle NSF Process Key In Scope L 0 Process operations group with ability to instantly update / maintain alerts on the fly § PA: Company Y has online real-time access to accounts, which allows for immediate changes § Note: Fraud / Security identified as a follow up area in the 2/23 session with Company Y § PA: Use EPA – ACH filters and blocks on PEP+ with various levels: Company ID (first level), Amount (fixed or threshold); both block-all and selective blocks set up on PEP+ Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 37

Functional Assessment Capability Detailed Findings – Small Business Deposits High Level Capabilities 9. Manage Risk High Level Capability Description Timing Client X Rating Company Y Rating Comments / Implications § CE: Company Y house-holding defined at Householding Ability to household customers Day 1 4 3 the customer level § CE: Limitation - can be changed in branch or over the phone; not online 9. 1 Manage Credit Risk 9. 2 Manage Credit Risk Assurance 9. 3 Manage Regulatory Affairs & Compliance 9. 4 Manage Enterprise Risk, Operational Risk, and Dept Admin Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 38

Functional Assessment Findings A. B. C. D. E. F. G. H. Consumer Deposits Small Business Deposits Commercial Deposits (including Treasury) National Direct Bank Deposit Operations Consumer Lending Small Business Lending Commercial Lending

Product Considerations

Functional Assessment Product Detailed Findings – Commercial Deposits Product Desired Features / Description Timing Client X Rating Company Y Rating Comments / Implications § BD: Company Y currently has Business and Public Checking, Savings, and Money Market Business Money Markets Continue to support all Public Product types Continue to support Business Money Markets (including Tiered) Day 1 4 3 Day 1 4 4 Public Checking, Savings, and Money market Accounts § BD: Additional product functionality could be logically supported with the proper configuration in Company Y § BD: Company Y supports Business Money Market accounts including interest tiering Automatically transfer money form MMA to cover insufficient positions for like / same accounts Ability to view accounts fro IOLA cross referenced to the attorney’s office in control over the deposits Added 3/5/09 – Analysis to be completed Add / delete attorneys as needed IOLTA / TRUST / IOLA § BD: Company Y supports IOLTA / TRUST / Continue to support IOLTA / TRUST / IOLA Day 1 4 4 Commercial Savings Continue to support Commercial Savings Day 1 4 4 Commercial CDs Continue to support Commercial CDs Day 1 4 4 Able to clearly identify gross and net sources of non Non-interest income and why any fees were waived (e. g. , tracking NSF/OD/Treasury Management gross charges, detailed fee waivers, reasons for waiver and net fee income) Day 1 3 2 Non-interest income Track to account level and assign to relationship tracking manager Post Day 1 2 2 IOLA accounts ; driven with sub product code designed to deal with interest § Note: Company Y has a significant # of these accounts in the private banking group § BD / CE: Commercial Savings product available at Company Y § BD / CE: Company Y currently supports Commercial CDs § PA: Do not perform today, although could if interactivity existed between Weiland other systems (today – only net service charge is put into Company Y via Weiland) Rating Key Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 41

Functional Assessment Product Detailed Findings – Commercial Deposits Product Escrow Management Tenant Securities Client X Rating Company Y Rating Continue to support escrow, including sub accounts, in all Day 1 states 4 2 Support 1031 Escrow Management Accounts including split interest between ‘master’ and ‘sub accounts’ Day 1 4 2 Require flexible pricing capabilities at the sub account level Day 1 4 2 Automate split interest calculation or need to work with manual split interest procedures Day 1 3 2 Perform dual reporting (master earned and sub account earned) Day 1 3 2 Ability to reopen an account if closing is delayed Post Day 1 2 2 Automated control over open and closing within the branch (real time) Post Day 1 2 3 Ability for sub-accounts to be opened/closed in the branches and online with all data occurring real-time Day 1 3 2 View sub accounts and maintain across branches (including seeing master with all the sub accounts that belong) Day 1 3 2 Once sub-accounts opened, they are added to the client’s online platform real time Post Day 1 3 2 Desired Features / Description Timing Separates customers with accelerated mailing requests (Fed Ex) - flag on deposit system Comments / Implications § PA / BD: Supporting parent /child relationship for escrow and tenant accounts are possible via Company Y § Note: Any escrow and tenant functionality has not been utilized by Company Y and additional research is required to identify the degree of any enhancements required to support (e. g. , new modules) § Note: Company Y recommended mainframe service (to perform full multi-tier ZBA, Escrow Management and Sweep functionality), Agiletics, scoped and scheduled for installation this year prior to the purchase announcement Added 3/5/09 – Analysis to be completed Produce special reports for accounts on deposit system (IM & ST) Rating Key Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 42

Functional Assessment Product Detailed Findings – Commercial Deposits Product Desired Features / Description Timing Client X Rating Company Y Rating Across Products Ability to view and track relationships Day 1 4 4 Across Products Ability to view and track households Post Day 1 3 3 Across Products Ability for the branch to transfer between accounts with different Tax ID numbers as long as signors on the account are the same Post Day 1 1 2 Comments / Implications § Company Y CIS has built in relationships § Company Y CIS would need to be configured to exhibit houesholds § PA: Manually established account ownership, and therefore, could set up tax ID and provide unlimited movement Rating Key Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 43

Functional Assessment Product Detailed Findings – Commercial Deposits Product Overdraft protection Desired Features / Description Timing Client X Rating Company Y Rating Support overdraft protection functionality that can link to multiple account types Day 1 3 4 Support for Euro, Repo, and Loan sweeps Day 1 4 2 Ability to have unique sweep pricing schemes Day 1 4 3 Require built in pricing flexibility (market level pricing) Day 1 4 2 Comments / Implications § BD: Sophisticated overdraft functionality at Company Y; can tie to DDA or HELOC § BD: Company Y could support multiple § § Sweeps § Loan to DDA sweeps with ability to group deposits as a loan accounting requirement Sweeps Day 1 3 Product types for ghost accts and coding of accounts as part of the sweep process 2 § sweep products (investment sweep connected to ZBA sub account) with exception pricing BD: Company Y currently performing Investment and Repo sweeps (not Euro) PA: Sweep pricing would tie in the entire Company Y suite with need for proper feeds from other external places Note: Loan sweeps going into production for ACBS Sprint 2009 Note: Sweep service charge pricing is handled by Weiland Account Analysis; interest rates are balance tiered and table driven by Company Y sub-product type Added 3/5/09 – Analysis to be completed Ability to interface with Mimics (Fidelity system) Controlled Disbursement Continue to support controlled disbursements Day 1 4 4 § BD: Support disbursements with check only (no ACH) § BD: Company Y utilizes Company Y based New system must support functionality Day 1 4 4 ZBA/Target Balance Accounts Ability for parent / child account type sweep functionality to provide Zero Balance Accounts § CE: Multi-tiered ZBAs are available, but are discouraged due to the processing balance not reporting balances in all tiers (recommended Agiletics mainframe) Added 3/5/09 – Analysis to be completed Funds moved automatically based on balance Rating Key Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 44

Functional Assessment Product Detailed Findings – Commercial Deposits Product Account Analysis Desired Features / Description Timing Client X Rating Company Y Rating Ability to flag accounts for account analysis Day 1 4 4 Ability to suppress hard charges and hard charge from DDA system Day 1 4 4 Ability for analysis statement illustrating earnings credit rate and service charges (calculation of excess) Day 1 4 4 Ability to flag for CD-Rom on host and index to check/item Day 1 4 4 Comments / Implications § PA: Account analysis is driven by sub product code in Company Y § PA: Once account is switched to account analysis in Company Y, all hard charges are suppressed and no longer hit account § PA / BD: Any earnings credit rate and CD Rom Check Service service charges on Weiland; Company Y will also do basics of service charges (earnings credit for balances to off set) § PA / BD: Image administrator passes to CD Rom which gets flagged on Company Y and recon file gets downloaded to process § BD: Do not deliver same day check detail or images § BD: Given the limited number of Company Controlled Disbursement Ability to deliver same day check detail report to customers Day 1 4 2 Ability to issue summary report includes fed items, on us (internal processing), ACH, same day Day 1 4 3 Ability to search for check over date range Day 1 4 3 Y customers on disbursement and current needs based process, this warrants further analysis of the ability § PA: No auto funding or auto transfer capability; all settled via zero balance transfer (concentration account) § BD / CE: Any items sent to the fed return the next morning of which summary could be issued § BD / CE: Ability to search transaction over Check Management date range but not images which have the ability for point search Rating Key Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 45

Functional Assessment Product Detailed Findings – Commercial Deposits Product Desired Features / Description Timing Client X Rating Company Y Rating Comments / Implications § PA: Company Y supports a corporate Ability to flag accounts for outgoing data exchange Day 1 4 4 Ability to send account to multiple BAI 2 Destinations Day 1 4 4 Ability to selectively send transactions and balance outbound (BAI 2) Day 1 4 2 banking code to flag for outgoing data exchange § PA: Company Y can deliver to multiple end Data Exchange points, although, requires separate corporate banking code § PA: Do not have the option to selectively send, options to customize would likely exist § PA: Company Y stores a translation table, Balance Reporting BAI 2 - host transaction codes need to be translated to BAI 2 codes Day 1 4 4 BAI 2 - host information balances and transaction needs to be transferred to BAI 2 format Day 1 4 4 BAI 2 – ability to flag accounts to identify as an information reporting account Day 1 4 4 Ability to transfer between different banks and generate due settlement for bank transfers Day 1 4 2 Ability to select book transfers based on balance availability or Not Day 1 4 4 Book Transfers therefore, when balance reporting files are created, reporting in BAI 2 codes that service § BD: Transfer able to be completed in BAI 2 format § PA: Company Y supports a corporate banking exchange code § BD: Internal transfers performed real time § Note: This was noted as a follow-up item for the Company Y deposits team, although initially perceived as doable § PA: Company Y default availability is ZBA limit system, with ACH risk limit, daily overdraft limit, next day availability limit Rating Key Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 46

Functional Assessment Product Detailed Findings – Commercial Deposits Product Desired Features / Description Timing Client X Rating Company Y Rating Comments / Implications § PA / BD: All commercial accounts month Ability to generate sweep reports, cycle statements, daily stats Day 1 4 4 end (although able to have special requests) § BD: Statements following business day have archive with. pdf § BD: Daily statements only supported on an Bank Reporting Flexible statement issuing Day 1 4 3 exception basis § BD: No ability to specify number of images per page § CE / BD: Hard copy statements mailed out Ability to generate account analysis reports Virtual Vault Day 1 4 2 after tenth business day; current manual entries post items off of Weiland Added 3/5/09 – Analysis to be completed Inbound Files from Loomis that are coded Post Transaction to DDA Rating Key Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 47

Functional Assessment Product Detailed Findings – Commercial Deposits Product Desired Features / Description International Trade Services and Wire Transfers Ability to posses profitability file and account analysis file Lockbox Uniquely identify the lockbox deposit Timing Client X Rating Company Y Rating Comments / Implications Added 3/5/09 – Analysis to be completed BAI 2 file produced from information on deposit system Tabbsfaxx/Fax Balance Reporting BAI 2 production tied to ACI/OBS/etc. Billing - hard charge based on IMCM flag Continue to support Treasury Key Day 1 4 1 § BD: No Treasury Key ‘like’ services currently at Company Y Tie child accounts to master (99999) automatically - history is on parent, not on child Parent Account # is always 5 digits plus 99999 Treasury Key Master/Sub account relationship - deposit moved from sub to master with store location information Added 3/5/09 – Analysis to be completed Last 5 digits of sub accounts populated deposit location field when item moved to master Must be part of the new system or built within to support assignment and use of the master/sub acct process and reporting Rating Key Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 48

Capability Considerations

Functional Assessment Capability Detailed Findings – Commercial Deposits 2. Develop Products & Services 2. 1 Ideate 2. 2 Perform Feasibility 2. 3 Prioritize Initiatives High Level Capabilities High Level Capability Description Timing Client X Rating Company Y Rating Comments / Implications § BD / PA: RDS / Company Y is table- Support Non. Vanilla Products Ability to support advanced products beyond the current suite Day 1 4 3 Regionalize Product Ability to roll out and configure products by branch / region / bank Day 1 4 2 Perform Exception Pricing Ability to perform exception pricing Day 1 4 3 driven; rules can be changed, although complexity depends on the offering § PA: Not configured; would need configuration at Company Y to implement § CE: Potential negative impact to the customer if exception pricing changes § PA: Company Y has built in relationship Perform Relationship Pricing Ability to relationship price (rate or fee depends on criteria such as balance level, use of Post Day 1 services like direct deposit or bill pay) 3 3 Ability to have unique SWEEP pricing schemes Day 1 3 3 pricing features; would need to build the appropriate table with business rules § CE: Supports an improved customer experience § BD: Company Y could support multiple sweep products § CE: Company Y can exception price these accordingly 2. 4 Develop and Deliver Functionality § BD / CE: Bundling is a core part of Support Product Bundling Ability to support bundling of products (tie products together and modify rates, fees, and other features based on a la carte or bundle) Post Day 1 3 4 Rate Tiers Customize interest rate tiers at a regional or market level Day 1 4 4 Company Y product tables with flexibility to define different bundles easily § PA: Requires simple table change in Company Y 2. 5 Launch Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 50

Functional Assessment Capability Detailed Findings – Commercial Deposits 2. Develop Products & Services High Level Capabilities High Level Capability Timing Client X Rating Company Y Rating Day 1 3 3 Support Product Release Post Day 1 2 2 New Products Day 1 4 3 Comments / Implications § PA: Company Y has flexibility, but Ability to quickly change incentives for new product rollouts or other major changes 2. 1 Ideate 2. 2 Perform Feasibility Description incentives are typically set at the beginning of the year § PA: Company Y tables can be configured Ability to differentiate incentives / products by region potentially even branch Ability to roll out new products at a rate of several per year (e. g. , on a quarterly basis) by region to support this functionality; current set up does not utilize regionalization § PA: Could support depending on the complexity of the product (would need to configure and test) 2. 3 Prioritize Initiatives 2. 4 Develop and Deliver Functionality 2. 5 Launch Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 51

Functional Assessment Capability Detailed Findings – Commercial Deposits High Level Capabilities 3. Market Products High Level Capability 3. 1 Plan Marketing Description Timing Client X Rating Company Y Rating Comments / Implications N/A 3. 2 Develop Creatives and Execute Marketing Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 52

Functional Assessment Capability Detailed Findings – Commercial Deposits High Level Capabilities 4. Acquire Customers High Level Capability 4. 1 Perform Consultative Selling Description Single Sign-on Single sign-on to a single system that interfaces with others as necessary Duplicate Date Entry Supports the ability to not enter similar data into multiple systems at the time of new customer account opening Timing Client X Rating Company Y Rating Day 1 2 4 Comments / Implications § PA: Company Y check and debit systems have SSO; ASP applications require additional sign-on § PA: Client X rekeys data from Touchpoint to other systems Day 1 2 4 Y – CIS first, CIS populates necessary account opening forms 4. 2 Open Account via Banker § BD: If a customer exists in the CIS, can Existing Customer Ability to pre-fill customer info if the customer Information already has another Client X product (including Population national businesses like Card / Auto) 4. 3 Open Account via Call Center Remote Sales § PA: Company Y enters data into Company Day 1 3 3 pre-populate information into application § PA: Provides for a quicker, more efficient process Private Bankers should have access to their own set of new account numbers (vs. needing to call the branches to get an account number in order to open a new market) § PA / CE: Unique account numbers exists Day 1 3 outside of branch; accessed through banker support group 4 § PA: Ability to change sub product code in 4. 4 Open Account via Online Account Analysis Auto add account to analysis vs. completing a form (manually required Day 1; automated required Post Day 1) Post Day 1 3 2 Company Y to redefine account for account analysis, however, requires manual Weiland entry § CE: Company Y can perform some account analysis, “Commercial Analyze Checking” for basic check and deposit items, within limits (e. g. , not tiered) § BD / PA: Circumventing CIP based on CIP and Borrower Type Ability to recognize borrower type to prompt the relevant CIP questions Post Day 1 3 3 Process Key In Scope L 0 Process L 1 Process Performed account type and how customers are related to the accounts § Note: Any CIP updates integrate real-time to CIS Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 53

Functional Assessment Capability Detailed Findings – Commercial Deposits High Level Capabilities 4. Acquire Customers High Level Capability 4. 1 Perform Consultative Selling CIP and Sub Account Opening Description Timing Client X Rating Company Y Rating Day 1 3 3 Ability to open sub accounts (not considered customer accounts) and bypass CIP portion (applies to all channels that needs to apply and includes tenant security) Comments / Implications § BD / PA: Circumventing CIP based on account type and how customers are related to the accounts § PA: Can potentially be done without 4. 2 Open Account via Banker Ability to convert customers from one product Account Numbers to another while maintaining the same account numbers. Day 1 3 3 affecting the smart account number at Company Y § CE: Supports minimal impact to the customer 4. 3 Open Account via Call Center 4. 4 Open Account via Online Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 54

Functional Assessment Capability Detailed Findings – Commercial Deposits High Level Capabilities 4. 5. Acquire Service Customers High Level Capability 5. 1 Process Customer Request 5. 2 Process Bank Initiated Transactions Description Timing Client X Rating Company Y Rating Reporting Ability to support reporting and query access to debit maintenance & transaction history Day 1 4 4 Deposit Posting Ability for real time posting of deposits Post Day 1 1 4 Real-time ATM / Debit Ability to view in real-time, all ATM / debit transactions (including OLB) Post Day 1 1 4 Transactional Data Ability to view ACH data including: who it was from, origination, ability to gain additional Post Day 1 transactional data (where purchase was made) Data Retention (Viewing) Increase transaction data retention, with ability to see 10 months (history online, currently Post Day 1 have to manually pull statements) § PA: Can view 120 day transaction history online in Company Y; older history via IBM Content Manager (. pdf) § BD: Company Y does real-time online deposit posting § BD / CE: Customer is able to view deposit real-time with Company Y § CE: Company Y truncates some ACH data 2 2 5. 3 Manage Content 5. 4 Add Ancillary Products to Existing Account Comments / Implications Issue Management (Follow-Up) Issue management system would have the capability to generate a tickler to remind Post Day 1 banker to call the customer (possibly upload to bankers’ calendar) (e. g. , merchant number gets cut off after 15 characters) § CE: Company Y can define reports as file feeds through OBS (new file type) direct from Pep+ § PA: Current ability to view only 120 days 2 3 of transaction data online via Company Y § PA: 16 months storage online for estatements § CE: Supportforce. com is not integrated 2 2 with RDS § BD / CE: Issue management handled through Contact Center 5. 5 Manage Banking Operations Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 55

Functional Assessment Capability Detailed Findings – Commercial Deposits High Level Capabilities 5. Service Customers High Level Capability 5. 1 Process Customer Request 5. 2 Process Bank Initiated Transactions Debit Research Statements Timing Client X Rating Company Y Rating Post Day 1 2 2 Ability to provide combined statements (all Client X products) with customized inserts / messaging Post Day 1 2 4 Ability to suppress statements, duplicate statements, boxing statements (RE clients), combine statements Day 1 4 TBD Description Ability to pull debit research quickly for customer inquiries Comments / Implications § PA: RDS performs query and research and also ability to search within imaging (have flexibility here) § CE: Company Y statements are fully integrated and provide the customer with a view of their entire product portfolio § CE: Follow-up with Joe Matusek (Company Y Treasury Mgmt Services / Deposit Operations) in progress § BD / CE: Nothing is booked outside of Tenant Securities Ability to view tenant securities online Post Day 1 3 Company Y, therefore, can view all accounts, including tenant securities online (as long as deemed owner of account) 2 5. 3 Manage Content § PA / CE: Ability to vary float at customer Floats Support float application (including float removals and custom floats) Day 1 4 4 Returned Item Processing Support returned item processing including the extraction, qualification and return of drafts Day 1 4 3 5. 4 Add Ancillary Products to Existing Account level thru customer scoring and database solution § PA: RDS identifies what the float should be based on item or thru an exception table § PA: Return items process is manual § CE: No electronic notification or reporting exists 5. 5 Manage Banking Operations Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 56

Functional Assessment Capability Detailed Findings – Commercial Deposits 6. Manage Customer Relationships 6. 1 Manage Portfolio 6. 2 Execute Customer Management Strategy High Level Capabilities High Level Capability Industry Codes Ability to classify an account / client as belonging to a specific SIC/NAICS industry code Timing Client X Rating Company Y Rating Post Day 1 3 4 Day 1 3 3 Maintain Notes / Event History Support the maintenance of system generated and associate notes on a customer's account Day 1 4 3 Engagement Need to be able to easily identify use of sticky services and Treasury Management services (e. g. , branch knows that Client-A has a debit card, uses Treasury Optimizer, and has Merchant Services) Day 1 3 3 Overdraft Visibility Ability to show returns and trail of returns (post what was returned to customer if chose ‘not to pay’) Day 1 3 4 Post Day 1 2 3 Fee Waivers Expedited Funds view bolsters servicing experience salesforce. com, but not integrated with RDS § BD / CE: Done via reporting § PA / CE: Feature is available thru RDS for the branch associate and call center agent § BD / CE: Can perform refunds and may Fees can be split to master and sub functionality for DDA, Escrow and Tenant sub accounts Ability to offer expedited funds availability on an account or on a relationship regardless of how a check gets deposited L 1 Process Performed § BD / PA / CE: Fully integrated customer § PA: Customer notepad provided through support true fee waivers, but functionality is not currently being utilized Added 3/5/09 – Analysis to be completed Process Key In Scope L 0 Process inputs related to code § PA: Ability to add to flag a SBB / Commercial customer Banker Ability to see full customer relationship (including national products like Card and Auto) Systematized fee waiver authority where the system dictates who has the ability to waiver certain fees under certain circumstances Comments / Implications § PA: Company Y can accept a variety of Customer Relationships 6. 3 Retain Customers 6. 4 Solicit Customer Feedback Description Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 57

Functional Assessment Capability Detailed Findings – Commercial Deposits High Level Capabilities 8. Manage Recoveries and Collections 8. 1 Manage Collections 8. 2 Manage Recoveries High Level Capability Charge Offs Description Timing Perform charge off, reverse charge–offs, and recoveries Day 1 Client X Rating Company Y Rating 3 4 Comments / Implications § PA / CE: Company Y currently performs § PA: Performed by Company Y Fraud Ability to support leading edge Fraud capabilities Day 1 3 3 NSF Ability to charge NSF fees directly to subaccount vs. direct to master account Day 1 3 3 8. 3 Detect and Prevent Process Key In Scope L 0 Process L 1 Process Performed operations group with ability to instantly update / maintain alerts on the fly § PA: Company Y has online real-time access to accounts, which allows for immediate changes § Note: Fraud / Security identified as a follow up area in the 2/23 session with Company Y § PA: Use EPA – ACH filters and blocks on PEP+ with various levels: Company ID (first level), Amount (fixed or threshold); both block-all and selective blocks set up on PEP+ § PA: Sub accounts in Company Y hard charged NSF or Weiland, bundle NSF Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 58

Functional Assessment Findings A. B. C. D. E. F. G. H. Consumer Deposits Small Business Deposits Commercial Deposits (including Treasury) National Direct Bank Deposit Operations Consumer Lending Small Business Lending Commercial Lending

Product Considerations

Functional Assessment Product Detailed Findings – National Direct Bank ¡ Online Savings Account (OSA) ¡ ¡ ¡ High Yield Money Market (HYMM) ¡ ¡ ¡ ¡ Rewards Money Market ¡ ¡ ¡ Variable rate with higher rates for account balances of $10, 000 or more Free online transfers to and from existing non-Client X One accounts Only available through online channel FDIC Insured; no minimum balance Fund via check, wire, internal transfer, or external transfer / ACH (online only) Variable rate; updated weekly Free online transfers to and from existing non-Client X One accounts Checks and ATM card included No fees; $1 minimum initial deposit FDIC Insured; no minimum balance Apply online, by phone, or by mail Fund via check, wire, internal transfer, or external transfer / ACH (online only) Variable rate; updated weekly Free online transfers to and from existing non-Client X One accounts Checks and ATM card included 1 mile for every $20 of average balance for the month No fees; $1 minimum initial deposit FDIC Insured; no minimum balance Apply online, by phone, or by mail Fund via check, wire, internal transfer, or external transfer / ACH (online only) Day 1 Client X Rating 4 Company Y Rating 3 Business Differentiation ¡ Timing Process Alignment Desired Features / Description Customer Experience Product Comments / Implications § BD: National footprint allows Client X to have competitive rate without having to reprice the entire portfolio § PA: Specialized workflow and centralized print / mail functionality required to adhere to compliance requirements and manage fraud risk § CE: Company Y has not enabled regionalization functionality within Company Y § BD: National footprint allows Client X to Day 1 4 3 have competitive rate without having to reprice the entire portfolio § PA: Specialized workflow and centralized print / mail functionality required to adhere to compliance requirements and manage fraud risk § CE: Company Y has not enabled regionalization functionality within Company Y § BD: National footprint allows Client X to Day 1 4 2 have competitive rate without having to reprice the entire portfolio § PA: Specialized workflow and linkages required to enable and manage rewards functionality § CE: Rewards linkages add to overall customer experience Rating Key Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 61

Functional Assessment Product Detailed Findings – National Direct Bank ¡ Traditional CD ¡ ¡ ¡ ¡ Business Money Market ¡ ¡ ¡ Costco Relationship (HYMM, OSA, CD) Minimum deposit = $5 k for Standard / $100 k for Jumbo Maximum deposit = $3 M for Retail / $1 M for Commercial Available terms are from 6 months to 10 years Apply online, by phone, or by mail Fund via check, wire, internal transfer, or external transfer / ACH (online only) FDIC Insured Variable rate No fees; $1 minimum initial deposit No minimum balance Access via checks (allowed 6 transfers/withdrawals per statement cycle, 3 of which may be checks to 3 rd parties) Account info available online or by phone Fund via check, wire, internal transfer, or external transfer / ACH (online only) FDIC Insured Additional characteristics: ¡ No 6 or 12 month terms for CDs ¡ Initial bonus of $20 or $60 depending on Costco membership level for CDs ¡ “Exclusive” rates – (higher than a non-Costco deposit product) ¡ Minimum deposit of $5, 000 to open OSA ¡ Apply online (Costco website) or by phone Day 1 Client X Rating 4 Company Y Rating 3 Business Differentiation ¡ Timing Process Alignment Desired Features / Description Customer Experience Product Comments / Implications § BD: National footprint allows Client X to have competitive rate without having to reprice the entire portfolio § PA: Specialized workflow and centralized print / mail functionality required to adhere to compliance requirements and manage fraud risk § CE: Company Y has not enabled regionalization functionality within Company Y § BD: National footprint allows Client X to Day 1 4 3 have competitive rate without having to reprice the entire portfolio § PA: Specialized workflow and centralized print / mail functionality required to adhere to compliance requirements and manage fraud risk § CE: Company Y has not enabled regionalization functionality within Company Y § BD: Affiliate programs allow NDB to expand customer base Day 1 4 2 § PA: Specialized workflow and linkages required to enable and manage affiliate relationship functionality Rating Key Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 62

Capability Considerations

Functional Assessment Capability Detailed Findings – National Direct Bank 2. Develop Products & Services High Level Capabilities High Level Capability Description Timing Client X Rating Company Y Rating Comments / Implications § BD / PA: RDS / Company Y is table. Support Non. Vanilla Products Ability to support advanced products beyond the current suite Support Product Rate Changes / Tiers Ability to change rates quickly (including customization of tiers at the region / market level) Perform Relationship Pricing Ability to relationship price (rate or fee depends on criteria such as balance level, use of services like direct deposit or bill pay) Day 1 3 3 Support Product Bundling Ability to support bundling of products (tie products together and modify rates, fees, and other features based on a la carte or bundle) Day 1 3 4 New Products Ability to roll out new products at a rate of several per year (e. g. , on a quarterly basis) Day 1 4 3 Converting Accounts to New Products Support converting accounts to new product type without impacting account numbers, OLB, debit, etc. Day 1 4 driven; rules can be changed, although complexity depends on the offering with NDB requirements being the most complex 2 2. 1 Ideate § BD: Company Y changes rates at the Day 1 4 4 2. 2 Perform Feasibility 2. 3 Prioritize Initiatives product level. Currently rates are not variable by region § PA: Requires simple table change in Company Y § PA: Company Y has built in relationship pricing features; would need to build the appropriate table with business rules § CE: Supports providing an improved customer experience § BD / CE: Bundling is a core part of Company Y product tables with flexibility to define different bundles easily § PA: Could support depending on the 2. 4 Develop and Deliver Functionality complexity of the product (would need to configure and test) Generally takes ~1 week if new product code is not required § PA: Can potentially be done without Day 1 4 3 2. 5 Launch Process Key In Scope L 0 Process L 1 Process Performed affecting the smart account number at Company Y § CE: Supports minimal impact to the customer Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 64

Functional Assessment Capability Detailed Findings – National Direct Bank High Level Capabilities 3. Market Products 3. 1 Plan Marketing 3. 2 Develop Creatives and Execute Marketing High Level Capability Segment Based Marketing Description Timing Company Y Rating Comments / Implications § PA: May be able to tie a marketing Ability to differentiate multiple marketing offers and themes on a single product (example: offer Bank at Work customer $100 to sign up for a new DDA and offer a student $50 to open the same account) Day 1 4 2 campaign for a particular product to a defined segment § PA / CE: Company Y can define customer segments § PA: Company Y uses package codes Ability to use promotional codes and have codes tied to automated benefits incenting direct deposit, debit usage, online bill pay, etc. Promotional Codes Client X Rating stored in Company Y Day 1 4 2 § PA: May be some gaps in the way Company Y is able to deliver this functionality, specifically for NDB § PA: May be some gaps in the way Ability to use promotional codes to identify customers taking advantage of an offer and/or for use in establishing that account is eligible for direct mail bonuses Day 1 4 2 Company Y is able to deliver this functionality § PA: Company Y has limited ability to track where an app came from; NDB will be the most impacted § PA: Company Y can review outstanding Offer / Promotion Tracking Ability to see what offers or promotions have been marketed or a customer has received Statement Messaging Ability to customize statement messaging offers or applications through RDS Post Day 1 2 3 § CE: Associates aren’t aware of offers customer has received and may duplicate offers § BD: Can perform conditional searches and Day 1 3 4 design messages § CE: Company Y can customize at the Customer level Sales Brochure Request Ability to request and send sales brochures to customers specific to a particular type of product. Brochures include an application for the customer to return for opening of an account § BD / CE: Company Y has real time PDF Day 1 3 Process Key In Scope L 0 Process L 1 Process Performed messaging capabilities; NDB only sends paper copies to customers (PDF capabilities on “to do” list for Client X) 3 Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 65

Functional Assessment Capability Detailed Findings – National Direct Bank High Level Capabilities 4. Acquire Customers High Level Capability Description Timing Client X Rating Company Y Rating Comments / Implications § BD: NDB has completely automated 4. 1 Perform Consultative Selling Pending Account Application Day 1 4 2 boarding process § PA: Boarding of an account and funding is separate at Company Y Account Opening and Funding 4. 2 Open Account via Banker Funding Flexibility 4. 3 Open Account via Call Center Ability to support a pending application until the funds have been resolved Sales Page Fulfillment 4. 4 Open Account via Online § PA: Company Y can open an account with Ability to open an account with a zero balance Day 1 4 3 Ability to close out account with no penalty if funds are not received with in required timeframe Day 1 4 3 Ability to direct new accounts and money in either of two legal entities - CONA or Client XUSNA as needed Day 1 4 2 a zero balance; need to understand automation from end-to-end § PA: Company Y can close an account without penalty if not funded § BD: Company Y does not have multibank functionality active in Company Y § PA: Extensive development will be required to enable RDS and Company Y § BD: Company Y doesn’t use Next Best Sales pages that support account opening are displayed to ensure that the CSR offers correct rates and products associated with the promotional offer given to the customer Day 1 Ability to track fulfillment (ordered debit card, checks, other fulfillment items) Post Day 1 4 3 Offer functionality § BD: Associate can query RDS for pending offers 2 3 § PA / CE: Capability exists within RDS for tracking § BD: If a customer exists in the CIS, can Existing Customer Information Population Ability to pre-fill customer info if the customer already has another Client X product (including Post Day 1 national businesses like Card / Auto) pre-populate information into application 2 3 § PA: Provides for a quicker, more efficient process § CE: If application is started, but not finished online, data not saved Customer Authentication Ability to authenticate requirements for NDB; consists of VRU pin and or VERID (web based 3 rd party authentication tool) for transactions § PA: Will require alignment with NDB Day 1 4 Process Key In Scope L 0 Process L 1 Process Performed processes to provide necessary fraud and compliance controls 2 Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 66

Functional Assessment Capability Detailed Findings – National Direct Bank High Level Capabilities 4. Acquire Customers High Level Capability Description Timing Client X Rating Company Y Rating Required Disclosures Support the required disclosures that must be delivered to the customer over the phone or via the Web at the time the account is opened Day 1 4 3 Documents Monitor the status of the documentation to ensure compliance requirements are met 4. 1 Perform Consultative Selling Comments / Implications § PA: Company Y disclosure tracking will need to be updated to account for disclosures required for NDB § BD: Document workflow for NDB will have Day 1 4 3 to be developed for RDS / Company Y § PA: Company Y statement data Is stored as PDFs in IBM’s content management 4. 2 Open Account via Banker 4. 3 Open Account via Call Center 4. 4 Open Account via Online Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 67

Functional Assessment Capability Detailed Findings – National Direct Bank High Level Capabilities 5. Service Customers 5. 1 Process Customer Request 5. 2 Process Bank Initiated Transactions High Level Capability Description Customer Channel Preference Ability to specify which channel a customer prefers and then primarily manage communication through that channel Post Day 1 Issue Management (Follow-Up) Allow users to complete a workflow process for which a specific Case notebook is not currently provided Day 1 4 3 Statements Ability to provide combined statements (all Client X products) with customized inserts / messaging Day 1 2 4 Timing Client X Rating Company Y Rating Comments / Implications § PA: No push-messaging capabilities 3 3 between online and contact center § CE: Company Y customers can set preferences online and for ATM § PA: Case management is not integrated with RDS § BD: Company Y has fully integrated statements that include all products § CE: Customer has ability to define relationships § BD: Company Y does real-time online Deposit Posting 5. 3 Manage Content 5. 4 Add Ancillary Product to Existing Account Day 1 1 4 posting § CE: Real time account posting enhances customer experience Interest Credit Allow the user to enter a whole dollar amount credit and reason Day 1 4 3 Unique Product Servicing Ability to capture and maintain information for servicing unique products (e. g. , membership number for the Costco MMA/CD products and the credit card number for the Cross Sell Rewards MMA product) Day 1 4 2 Ability to support the process in which customers will receive checks and ATM cards only after we have received all completed required documentation Day 1 Funds Access Limitations 5. 5 Manage Banking Operations Ability to send deposit receipts to customers via email and mail Incomplete Documentation Display an alert to the CSR if there is incomplete documentation for one or more of a customer’s new accounts § PA: Company Y can be configured to apply interest credit § BD: Affiliate relationships expand customer base § PA: Affiliate capabilities require development § PA: Workflow and centralized print, and 4 fulfillment operations would have to be updated 2 § BD: Enables CSR to finalize customers Day 1 4 3 accounts § PA: Screen prompt would have to be built into RDS Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 68

Functional Assessment Capability Detailed Findings – National Direct Bank High Level Capabilities 5. Service Customers 5. 1 Process Customer Request 5. 2 Process Bank Initiated Transactions High Level Capability Description Timing Client X Rating Company Y Rating Add Stop / Holds Special Instructions NDB has specific hold rules for deposits. Certain windows permissions added; default information for NDB and enabling/disabling logic updates Day 1 4 3 Document Imaging Support a robust imaging system and process Day 1 3 4 Costco Maintenance Allow CSR to update the existing Costco Membership Information on a Costco MMA or CD Day 1 4 3 Comments / Implications § PA: Logic would have to be developed to add capabilities to Company Y and RDS § BD: Company Y has PDF capabilities and online document distribution § PA: Update to RDS required 5. 3 Manage Content 5. 4 Add Ancillary Product to Existing Account 5. 5 Manage Banking Operations Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 69

Functional Assessment Capability Detailed Findings – National Direct Bank 6. Manage Customer Relationships High Level Capabilities High Level Capability Description Timing Client X Rating Company Y Rating Prompts Ability to provide pop-ups or other prompts to customer-facing associates based on a rules engine with business logic (includes CTI screen flash, Mindshare Survey) Post Day 1 2 3 Update Customer / Prospect Provides the ability to update or create a customer and/or a prospect and to verify a customer’s profile information Day 1 4 3 Customer Relationships Ability to see full customer relationship (including national products like Card and Auto) Day 1 3 4 Transaction / Contact Viewing Ability to see recent transactions and contacts (calls to the call center, complaints, etc. ) 6. 1 Manage Portfolio 6. 2 Execute Customer Management Strategy Comments / Implications § BD / CE: Current capability is not sophisticated; Teller receives prompts; cross-selling is more manual § PA: Salesforce. com has the capability to perform prospecting but is not currently enabled / set up § BD / PA / CE: Fully integrated customer view bolsters servicing experience § PA: Transaction activity on RDS is Day 1 3 3 6. 3 Retain Customers available for up to 120 days; 16 months online § CE: Branch associate can not see all customer activity (e. g. , complaints) § PA: Doesn’t aesthetically treat the Differentiated Serving Differentiated servicing in the call centers and branches based on the customer value / segment Post Day 1 3 3 6. 4 Solicit Customer Feedback customers any differently; Platinum go to separate line § CE: Differentiated service levels based on customers core § CE: Stored at the account level and used for defined benefits § CE: Company Y house-holding defined at Householding Ability to household customers Day 1 4 3 the customer level § CE: Limitation - can be changed in branch or over the phone; not online Consumer Complaints Require one interface for front end system to see customer complaints and know all relationships with customer and all interactions § CE: Salesforce records notes on the Post Day 1 2 2 if they have been typed in notes (in RDS) Process Key In Scope L 0 Process L 1 Process Performed customer - not integrated with RDS § CE / PA: Banker can only see complaints Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 70

Functional Assessment Capability Detailed Findings – National Direct Bank 6. Manage Customer Relationships High Level Capabilities High Level Capability Maintain Notes / Event History 6. 1 Manage Portfolio Rewards 6. 2 Execute Customer Management Strategy Description Timing Client X Rating Company Y Rating Support the maintenance of system generated and associate notes on a customer's account Day 1 4 3 Provide automated enrollment and updates to Rewards Money Market Accounts on the vendor Rewards platform Day 1 4 2 Ability to update the existing Rewards Credit Card number on a Rewards Money Market account Day 1 Comments / Implications § PA: Customer notepad provided through salesforce. com, but not integrated with RDS § BD / CE: Reward functionality at Company Y is less robust than at Client X § Deeper dive is required § BD / CE: Reward functionality at Company 4 Y is less robust than at Client X 2 § Deeper dive is required 6. 3 Retain Customers 6. 4 Solicit Customer Feedback Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 71

Functional Assessment Capability Detailed Findings – National Direct Bank High Level Capabilities 7. Sell Loans High Level Capability N/A Description Timing Client X Rating Company Y Rating N/A N/A Comments / Implications § BD: § PA: § CE: 7. 1 Sell Loans to Investors 7. 2 Manage Distributions Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 72

Functional Assessment Capability Detailed Findings – National Direct Bank 8. Manage Recoveries and Collections High Level Capabilities High Level Capability Description Timing Client X Rating Company Y Rating Charge Offs Perform charge off, reverse charge–offs, and recovers Day 1 4 4 Centralized Print Support unique NDB print process due to the additional fraud controls Account servicing performed in the back office only, since there are NDB specific letters that branches do not need to provide. Fraud Controls / Alert Support the Fraud Alert Maintenance function that allows a CSR to enter, update or delete a fraud alert message for a customer 8. 1 Manage Collections Comments / Implications § PA / CE: Company Y currently performs (although, different group does for lending vs. deposit) § BD: Client X has robust automate print Day 1 4 3 8. 2 Manage Recoveries and mail functionality to sale and service accounts § CE: Company Y can enhance customer experience through real time delivery using PDF functionality § BD: Company Y has ability to update Day 1 4 3 controls real time and apply restraints, flags, or remarks § PA: Will require complete understanding of current capabilities to tap into external fraud monitoring services 8. 3 Detect and Prevent Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 73

Functional Assessment Capability Detailed Findings – National Direct Bank High Level Capabilities 9. Manage Risk High Level Capability Deposit Hold Policy Description Timing Client X Rating Company Y Rating Support unique hold requirements that are required to manage the risk based channel in which NDB generates new accounts Day 1 4 3 Comments / Implications § BD / PA: Policy and logic for extended hold requires development 9. 1 Manage Credit Risk 9. 2 Manage Credit Risk Assurance 9. 3 Manage Regulatory Affairs & Compliance 9. 4 Manage Enterprise Risk, Operational Risk, and Dept Admin Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 74

Functional Assessment Findings A. B. C. D. E. F. G. H. Consumer Deposits Small Business Deposits Commercial Deposits (including Treasury) National Direct Bank Deposit Operations Consumer Lending Small Business Lending Commercial Lending

Deposit Operations Gap Client X / Company Y Gap Assessment Intent & Approach Evaluate and identify significant gaps between Chevy Chase Bank and Client X One Back Office Operations to serve as input into Deposit Operations integration planning & significant integration decisions. Gap Assessment Functional Capability Comparison • Map Current State Company Y & Client X • Compare Performed Services Blue Printing • Overlay Potential Considerations/ Assumptions (Products Remain, Company Y Core Systems) • Use Client X processes as scope boundaries • Assign Weighting to Close • ID Potential Day 1 and Day 1 -30 Requirements Synergy Assessment • Validate Due Diligence Finding • ID Potential New Synergies Confidential 76

Deposit Operations Functions Chevy Chase Bank Client X One Bank Research and Adjustments Exception Processing Day Shift Check Processing / Commercial ARP Night Shift Check Processing Retail / Wholesale Lockbox Ops ACH Services CIS Services Mail and Distribution Services Domestic Wire Transfer ATM Operations Remote ATM Operations Research and Adjustments Exception Processing / Return Items National Check Processing / ARP Check Image Archive Lockbox Wholesale and Retail ACH / Wire Operations CIS Maintenance and Time Support Statement Rendering / Mail / Transportation Services Domestic Wire Transfer ATM / Debit Card Dispute Settlement ATM Hardware Deployment Confidential 77

Process / Function Intersection Chevy Chase Bank Client X One Bank National Direct Bank Passbooks Lockbox * Account Analysis * Escrow Mgmt Accounts Jersey Escrow Mgmt Accounts Tenant Security Accounts Surrogate Court Accounts Check Support Services Key Accounts Items Processing Operations Investment Sweep * Treasury Management and ACH Float Management * General Document Services ACH Origination * Finance Controlled Disbursement * Electronic Banking Operations Consolidated Returns Payment Acceptance * Regional Pricing Loan to DDA Sweeps * Confidential ** Indicates Company Y has some version of this product, but CONA’s version is more customized 78

Summary of Identified Gaps for Deposit Operations Confidential 79

Summary of Identified Gaps for Deposit Operations Confidential 80

Summary of Identified Gaps for Deposit Operations Confidential 81

Summary of Identified Gaps for Deposit Operations Confidential 82

Summary of Identified Gaps for Deposit Operations Confidential 83

Functional Assessment Findings A. B. C. D. E. F. G. H. Consumer Deposits Small Business Deposits Commercial Deposits (including Treasury) National Direct Bank Deposit Operations Consumer Lending Small Business Lending Commercial Lending

Product Considerations

Functional Assessment Product Detailed Findings – Consumer Lending (CL) / National Lending (NL) Desired Features / Description Timing CL § Ability to support overdraft protection X Overdraft Protection X Home Equity Line of Credit X Home Equity Loan product § Ability to link to a DDA (similar to Company Y) § Support the ability to tie the product to Home Equity Line of Credit (HELOC) § Continue to support HELOC product § Continue to support Home Equity Loan product NL Compan y. Y Rating Process Alignment Product Customer Experience NL Business Differentiation Client X Rating CL Comments / Implications § BD / CE: Sophisticated overdraft functionality at Company Y; can tie to DDA or HELOC § Company Y does not currently link to card (business decision) Day 1 2 N/A 4 Day 1 4 N/A 4 § CE: Would maintain experience Day 1 4 2 4 § CE: Would maintain experience Day 1 4 N/A 4 § CE: Would maintain experience § Continue to support PLOC product § Ability to support linking the PLOC to X Personal Line of Credit deposit account § Support PLOC for consumers who do not qualify for a card X Other Line of Credit X Automobile Loans X Savings Secured Loans § Continue to support other lines of credit (e. g. , Student Line of Credit) § Continue to support the direct automobile loan products § Continue to support Savings Secured loans § BD / CE: Development and X X Same As Cash § Continue to support the Same as Cash loans Day 1 N/A 4 configuration work necessary to support the product and functionality at scale 2 Rating Key Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 86

Functional Assessment Product Detailed Findings – Consumer Lending (CL) / National Lending (NL) Desired Features / Description Timing CL § Ability to support the following product NL Compan y. Y Rating Process Alignment Product Customer Experience NL features: X Installment Loans - Business Differentiation Client X Rating CL Comments / Implications § PA: Not using installment feature Fixed and Variable Rate Simple and ADB Interest Single and Joint Applicants 36 – 84 Month Terms Fulfillment via check Unsecured Only Reloads (Refinances) Day 1 4 4 3 in Company Y Loans, but feature is available § CE: Company Y does support installment loans through RDS § Ability to support the following product features: X Point of Sale Loans - § No current support for POS loans Fix Rate Only Simple and ADB Interest Single Applicants Only 84 - 96 Month Terms Unsecured Only Deferred interest Reloads (Refinances) Day 1 N/A 4 at Company Y. Core functionality is represented by Company Y as existing, but significant development/ configuration would be required to support at scale 2 § Ability to support the following product features: X Small Business Loans - § Company Y splits SB loans Fix and Variable Rate Simple and ADB Interest Single and Joint Applicants 24 – 72 Month Terms Secured and Unsecured Reloads (Refinances) Day 1 3 3 between ACBS and Company Y Loans. Expect some degree of development required to support Client X book 3 Rating Key Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 87

Capability Considerations

Functional Assessment Capability Detailed Findings – Consumer Lending / National Lending 2. Develop Products & Services High Level Capabilities CL High Level Capability NL Description Timing Client X Rating CL NL Compa ny Y Rating Comments / Implications § PA: Company Y new product 2. 1 Ideate X New Product Roll -out Ability to roll out new products at a rate of several per year per LOB Day 1 3 3 3 2. 2 Perform Feasibility launches follow their SDLC process and are on bi-annual release § PA: Company Y can roll-out new product model within ~ 30 – 90 days; complex may take longer § PA: RDS integration with core X Perform Relationship Pricing Ability to relationship price (rate or fee depends on criteria such as balance level, use of services) Post Day 1 2 2 3 2. 3 Prioritize Initiatives deposits provides ready access to relationship information § PA / CE: Can perform relationship packaging / pricing – rate or fee can depend on different criteria § BD / CE: Company Y has pre. X Support Product Bundling Ability to support bundling of products (tie products together and modify rates, fees, and other features) Post Day 1 X Support Account Linking between Deposit and Lending Products Ability to link accounts to transfer funds (e. g. , Checking account to HELOC) Post Day 1 4 N/A 4 X Rate Adjustment Provide the ability to cap rates on variable products and modify rates for particular promotions Post Day 1 4 4 3 2. 4 Develop and Deliver Functionality 2. 5 Launch 2 N/A L 1 Process Performed defined bundles that operate today. Moderate degree of effort needed to define new bundles based on Client X business decisions § PA / CE: Lending and deposit products can be linked via RDS/ACAPS/Company Y Loans § CE: Rates can be adjusted Process Key In Scope L 0 Process 3 based on balance tiers the customer is in Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 89

Functional Assessment Capability Detailed Findings – Consumer Lending / National Lending High Level Capabilities 3. Market Products CL High Level Capability NL Description Timing Client X Rating CL NL Compa ny Y Rating Comments / Implications § PA: Limited ability to track 3. 1 Plan Marketing Product Offer Repository X Ability to access information relating to the product offers that have been extended to a customer Post Day 1 3 4 2 3. 2 Develop Creatives and Execute Marketing where an application came from (RDS tracks walk-in / online) § CE: Company Y has ability to know when to not offer a product to somebody (if customer didn’t qualify for a product, product isn’t available for offer) § BD / PA / CE: Company Y X Predefined Marketing Offers Ability to setup and manage a predefined list of marketing offers to a predefined list of prospects or customers Post Day 1 3 4 Process Key In Scope L 0 Process L 1 Process Performed 2 does not currently utilize true pre-defined marketing offers at specific segments § CE: Company Y Campaigns are currently directed at the entire customer base Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 90

Functional Assessment Capability Detailed Findings – Consumer Lending / National Lending High Level Capabilities 4. Acquire Customers CL High Level Capability NL Description Timing Client X Rating CL NL Compa ny Y Rating Comments / Implications § PA / CE: Customers can apply 4. 1 Perform Consultative Selling Provide the ability for customers to apply for loans through the online, Branch, Mail and phone channels X Day 1 3 3 2 Application Capture (Origination) 4. 2 Open Account via Banker 4. 3 Open Account via Call Center § PA: Client X doesn’t originate Ability to make all products available and originate through the online, branch, and call center channels X X Solicitation (Origination) from Loans through online, branch, and phone – not direct mail at Company Y § CE: Company Y lacks automations in app capture processes Day 1 3 3 3 through web today except through national lending § PA: Company Y online takes apps and routes to contact center for underwriting § PA: Company Y does not Support SOL Setup, Change and Update Solicitation Day 1 N/A 4 2 currently have campaign management capabilities for direct marketing § PA / CE: Real-time suggested 4. 4 Open Account via Online X Ability to support real-time decisioning Post Day 1 3 4 Decisioning (Origination) § BD / PA: Credit modeling Provide automated decisioning models and tools (e. g. , credit modeling) X Process Key In Scope L 0 Process L 1 Process Performed 3 decisioning through Strata only at Branch– all loans go through manual underwriting § PA: Decisioning process is not fully automated; decision is not approved until it is manually reviewed L 1 Process Not Performed Confidential available through ACAPS / Strata; need review of Post decisioning models / tools 3 4 3 Day 1 § BD / PA: ACAPS/STRATA has variable coding functionality to enable more flexibility when Rating Key modeling 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 91

Functional Assessment Capability Detailed Findings – Consumer Lending / National Lending High Level Capabilities 4. Acquire Customers CL 4. 1 Perform Consultative Selling X High Level Capability NL X Fulfillment (Origination) Description Timing Client X Rating CL Ability to approve loans , fund loans, disburse checks and socialize disclosures with customers NL Compa ny Y Rating Comments / Implications § PA / CE: Approval, funding, a Day 1 4 4 4 check disbursement managed through ACAPS; checks cut in branches § PA: Adverse action letter is 4. 2 Open Account via Banker 4. 3 Open Account via Call Center X X Fulfillment (Origination) Ability to decline and initiate adverse action correspondence Day 1 4 4 4 Support gathering and tracking documentation Day 1 4 4 4 generated and mailed to customer § CE: Customer has ability to call to question and correct issue § CE: Upon correction, can quickly redecision application § PA: ACAPS workflow managed document tracking § PA: Process does not exist X Ability to support the customer on-boarding process to assist a customer prior to their check being cashed and their loan boarded onto ALS Day 1 N/A 4 3 X Ability to support the issuance of checks, checkbooks, and electronic funds transfer Day 1 4 N/A 4 X Ability for customers to originate products across all channels (e. g. , start on the web and finish in the branch) 4. 4 Open Account via Online today, but could with limited effort § CE: Check is currently part of welcome package at Client X and number appears on disclosure forms § CE: Available in the branch, real-time today § PA / CE: Company Y process X Multi-Channel Originations Post Day 1 3 2 Process Key In Scope L 0 Process L 1 Process Performed 2 does not allow for this unless an application is saved § PA; Online apps at Company Y must be rekeyed into ACAPS after submission Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 92

Functional Assessment Capability Detailed Findings – Consumer Lending / National Lending High Level Capabilities 4. Acquire Customers CL High Level Capability NL Description Timing Client X Rating CL NL Compa ny Y Rating Comments / Implications § PA / CE: Can pull data from 4. 1 Perform Consultative Selling X X Pre-populate Demographic Information Ability to pre-fill customer info if the customer already has another Client X product (including national businesses like Card / Auto) CIS if customer exists Post Day 1 2 3 4 § CE: Process is to enter customer data into CIS prior to account application if customer does not exist § PA: Not currently being utilized 4. 2 Open Account via Banker 4. 3 Open Account via Call Center by either entity in full today X X X § CE: Company Y has more Overdraft Linkage Ability to link card to DDA as overdraft protection Post Day 1 4 N/A 3 Automated Underwriting Provide automated underwriting functionality Post Day 1 3 4 2 sophisticated overdraft functionality mainly due to deposit and lending system integration § PA: Provides automated decision suggestion, but still a manual underwriting process § PA: Manual, paper-based 4. 4 Open Account via Online X X X Automated Process Workflow Provide automated workflow capabilities throughout the lifecycle of the account opening process Post Day 1 3 3 2 Provide Customer Information to Auto Dealers Ability for auto dealers to acknowledge Client X One customers during the lending process (need to define how) Post Day 1 1 N/A 1 Process Key In Scope L 0 Process L 1 Process Performed processing between core systems; lack of online to ACAPS workflow § PA: Manually enter code to queue application to next function § CE: Does not exist in either entity today Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 93

Functional Assessment Capability Detailed Findings – Consumer Lending / National Lending High Level Capabilities 4. Acquire Customers CL NL Timing CL NL Compa ny Y Rating 4 4 4 Ability to support single and joint application processing Day 1 X Customer Needs Assessment Ability for customer to enter data and have a product recommendation delivered real-time Post Day 1 2 2 2 X Pre-Approval Ability to see if a customer is pre-approved for other Client X products (like a card) real-time Post Day 1 2 2 2 X Online Qualification Process Ability for a customer to receive real-time product qualification information online Post Day 1 2 2 2 Customer Credit Check Ability to pull credit at the time of account opening Post Day 1 4 4 3 Product Information Provide Banker or sales professional with detailed product information to drive conversation Post Day 1 3 3 4 Single Sign-On Single sign-on to a single system that interfaces with others as necessary; no duplicate entry Post Day 1 Comments / Implications § CE: RDS supports single or joint applications § BD / PA / CE: Company Y 4. 3 Open Account via Call Center X 4. 4 Open Account via Online Description Client X Rating Application Processing X 4. 1 Perform Consultative Selling 4. 2 Open Account via Banker High Level Capability X X § PA / CE: RDS has integration L 1 Process Performed for pre-approval options with Chase § CE: Does not exist in either environment today § BD / PA: Company Y can pull data from all 3 bureaus but only use 1 per application § PA: RDS Sales agreement window provides eligible and current products to customer § BD / CE: Single sign on 2 2 3 through RDS § PA: No ASP interfaces for consumer lending Process Key In Scope L 0 Process does a profile with DDA opening § CE: Not available via online channel Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 94

Functional Assessment Capability Detailed Findings – Consumer Lending / National Lending High Level Capabilities 4. Acquire Customers CL 4. 1 Perform Consultative Selling 4. 2 Open Account via Banker High Level Capability NL Description Timing Client X Rating CL NL Compa ny Y Rating § PA: Process does not exist X X Application Requirements Ability to provide customer expectations in terms Post of what s/he needs to complete the lending Day 1 process (e. g. , checklist) 3 3 3 X X Bundle Decisioning Ability to decision entire product bundle (not just product by product) Post Day 1 2 2 2 X Comprehensive Application View Provide a comprehensive view of simultaneous applications Post Day 1 X Comments / Implications today, but could with limited effort § Not done for either bank § BD / PA: RDS provides 3 N/A 3 information relative to the applications of a specific customer 4. 3 Open Account via Call Center 4. 4 Open Account via Online Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 95

Functional Assessment Capability Detailed Findings – Consumer Lending / National Lending High Level Capabilities 4. 5. Acquire Service Customers CL 5. 1 Process Customer Request X High Level Capability NL Description Timing Client X Rating CL NL Compa ny Y Rating X Vendor Integration Maintain vendor licenses and relationships (e. g. , flood certifications) Day 1 4 4 3 X 3 rd Party Reporting Ability to interface with and receive reports from various 3 rd parties (e. g. , Dunn and Bradstreet) Day 1 4 4 2 Account Maintenance Processing (i. e. , Global 360) Ability to access account maintenance / change requests that are queued through a change request system (e. g. , address change, credit loan files) Comments / Implications § PA: Potential to link 3 rd party vendors to RDS § PA; Company Y does not currently report to credit agencies § PA: Account service requests 5. 2 Process Bank Initiated Transactions X queued thru G 360 at Client X § PA: Company Y utilizes Day 1 3 3 2 supportforce to track and manage customer request; not utilizing breadth of functionality § PA: Company Y utilizes 5. 3 Manage Content X X Process and track customer requests Day 1 3 3 2 5. 4 Add Ancillary Products to Existing Account supportforce to track and manage customer request; not utilizing breadth of functionality § PA: Company Y does not have workflow case tracking § PA: Company Y utilizes X X Case Management Process and track customer complaints and disputes Day 1 3 3 5. 5 Manage Banking Operations 2 supportforce to track and manage customer request; not utilizing breadth of functionality § PA: Company Y does not have workflow case tracking § PA: Company Y has an X X Process Key In Scope L 0 Process L 1 Process Performed Ability to view, manage and escalate customer complaints / disputes across channels and the Bank L 1 Process Not Performed Confidential Post Day 1 escalation process within the contact center; is not entirely 3 3 3 automated § CE: Can speak to supervisor Rating Key in the event rep can not handle issue 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 96

Functional Assessment Capability Detailed Findings – Consumer Lending / National Lending High Level Capabilities 4. 5. Acquire Service Customers CL 5. 1 Process Customer Request X High Level Capability NL X Manage Correspondence Description Timing Client X Rating CL Ability to manage tasks and correspondence (including file transfer) relative to servicing the loan (e. g. , Process Inbound Correspondence, Process Outbound Correspondence, Issue Statements, Recurring ACH) NL Compa ny Y Rating Comments / Implications § PA: Maintain logs of customer Day 1 4 4 2 correspondence via an Access DB § PA: Physical mail from custom is placed in loan file § BD / PA / CE: Supports all 5. 2 Process Bank Initiated Transactions X Payment Options Ability to support multiple payment options (e. g. , branch payments, electronic payments (e. Box), Lockbox Paper payments, Recurring ACH Payments, Payment Exceptions/Returns/Rejects, Payment Investigations, On. Line Banking Payments) X Online Payments Processing Maintain availability of online banking features and payments processing through various channels (new features – must have) (includes recurring ACH) X Reconciliation Support the reconciliations of various monetary activities Day 1 4 4 3 X Early Loan Payoff Maintain customer early loan payoff process Day 1 4 4 4 5. 3 Manage Content 5. 4 Add Ancillary Products to Existing Account Day 1 4 4 3 forms of payment options listed, which can be initiated thru all channels and processed directly into Company Y Loans § PA: ACH set-up manual at Company Y; automated at Client X § BD / PA / CE: Supports online payment processing § BD: Client X supports debit card payments § PA: Mostly manual process; 5. 5 Manage Banking Operations data compiled from multiple sources and reconciled accordingly § PA: Supports early loan payoff and corresponding activities § BD: Company Y does not flag X Loan Re-Loads Ability to re-load an existing loan Day 1 N/A 4 Process Key In Scope L 0 Process L 1 Process Performed 3 or identify loans that may be re-loaded § PA; Does support re-load in the same fashion as refinancing Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 97

Functional Assessment Capability Detailed Findings – Consumer Lending / National Lending High Level Capabilities 4. 5. Acquire Service Customers CL 5. 1 Process Customer Request High Level Capability NL Description Timing Client X Rating CL NL Compa ny Y Rating § BD / PA: Is not nationally X Service Entire Product Suite In the Branch and Call Center Ability to service the entire product suite in the branch and over the phone (call center) Post Day 1 4 2 3 X Service to Sales Enable service to sales functionality to assist in cross-selling products to consumers at the point of service Post Day 1 3 2 3 5. 2 Process Bank Initiated Transactions scaled at Company Y, but does support servicing thru RDS in branch and contact center § BD / CE: No current external offer management system in place at Company Y § PA: Doesn’t aesthetically treat X Customer Stratification Ability to provide differentiated servicing in the call centers and branches based on the customer value / segment Post Day 1 3 2 4 X Feedback Mechanism between Bank Parties Provide a feedback loop or access point between the various parties handling the opening / servicing process Post Day 1 3 3 3 5. 3 Manage Content 5. 4 Add Ancillary Products to Existing Account Comments / Implications the customers any differently; Platinum go to separate line § PA / CE: Does segment the servicing based on the package at Company Y; can perform analytics § PA: Verbal feedback loop between parties; can enter notes in RDS, supportforce § BD: Average daily balance Ability to perform multiple interest rate calculations (daily simple interest and average daily balance) X capability not being utilized Day 1 4 4 3 balance and tier processing; rate tiering tied to balance Interest Rate Management 5. 5 Manage Banking Operations X § BD: Utilizes a variety of Ability to manage variable interest rates Day 1 4 4 Process Key In Scope L 0 Process L 1 Process Performed § PA: Utilizes rate based loan 3 indices maintained manually across platform tables § PA: Lots of flexibility in managing variable rate loans (both closed and open ended) Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 98

Functional Assessment Capability Detailed Findings – Consumer Lending / National Lending High Level Capabilities 5. Service Customers CL 5. 1 Process Customer Request NL 5. 4 Add Ancillary Products to Existing Account Description Timing Client X Rating CL NL Compa ny Y Rating Comments / Implications § PA; Can integrate with the X Financial Reporting Ability to access and reconcile financial reports Day 1 4 4 X Inquiry Backdating Ability to reconstructs the loan back to the date entered so that an associate can review what a loan looked like at any day in the past Day 1 4 4 X Transaction Backdating Ability to systematically backdate a transaction to "unpost" inappropriate late charges, adjust payment splits to principal and interest, recalculate the days past due indicators and downstream to the credit bureaus, if daily reporting is done Day 1 4 4 X Post / Repost Automation Ability to take off all the transactions that happened after the effective date and repost them with the transaction in it's appropriate position Day 1 4 4 X Effective Dating Inquiry Day 1 4 4 X Payment Restructure Day 1 4 4 5. 2 Process Bank Initiated Transactions 5. 3 Manage Content High Level Capability 3 appropriate parties and reconcile accordingly; much a manual reconciliation process 5. 5 Manage Banking Operations Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 99

Functional Assessment Capability Detailed Findings – Consumer Lending / National Lending High Level Capabilities 4. 5. Acquire Service Customers CL 5. 1 Process Customer Request 5. 2 Process Bank Initiated Transactions High Level Capability Description X Payment Posting Priority Ability to organize payment splits vertically (by balance - pay all interest due, then fees, then principal) or horizontally (pay all current due across balances, then past due, etc or vice versa) by process or loan type (i. e. charge off, bankrupt, current status, etc) X Shadow Loan Accounting X Escrow Processing for Loans NL Timing Client X Rating CL NL Day 1 4 4 Ability to house charge off loans in a shadow bank, customize accounting, and interface to the GL according to shadow accounting parameters Day 1 4 Ability to support depository accounting Day 1 4 Compa ny Y Rating Comments / Implications 4 4 5. 3 Manage Content 5. 4 Add Ancillary Products to Existing Account 5. 5 Manage Banking Operations Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 100

Functional Assessment Capability Detailed Findings – Consumer Lending / National Lending 6. Manage Customer Relationships High Level Capabilities CL NL X 6. 1 Manage Portfolio High Level Capability Description Timing Client X Rating CL Maintain Relationship Support the execution of tasks required to maintain customer relationship (e. g. , Execute Payment Drop ) Product Prompts Ability to provide pop-ups or other prompts to customer-facing associates based on a rules engine with business logic Holistic View of the Customer Ability to comprehensively view the customer profile across all channels including existing products, past offers, pre-qualifications, needs assessment NL Compa ny Y Rating Comments / Implications § PA / CE: Able to manage Day 1 4 4 4 functionality that allows a drop payment for a particular period of time § BD: Company Y doesn’t use 6. 2 Execute Customer Management Strategy X Next Best Offer functionality Post Day 1 3 2 3 § BD / CE: Current capability is not sophisticated; Teller receives prompts; crossselling is more manual § BD / CE: Can view X 6. 3 Retain Customers prequalified offers Post Day 1 3 3 3 § PA: Can view existing products § PA: Can view past offers up to a certain period of time § PA / CE: Company Y utilizes 6. 4 Solicit Customer Feedback X Customer Communication Management Ability to manage and document communication activity among customers Post Day 1 3 3 Process Key In Scope L 0 Process L 1 Process Performed 3 supportforce to track and manage customer communication activity for tier 2 and tier 3 items; not utilizing breadth of functionality § CE: Customer Needs Guide within salesforce is updated for each new account or as necessary Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 101

Functional Assessment Capability Detailed Findings – Consumer Lending / National Lending High Level Capabilities 7. Sell Loans CL High Level Capability NL Description Timing Client X Rating CL NL Compa ny Y Rating Comments / Implications § PA: Company Y manages 7. 1 Sell Loans to Investors X Sell Debt Ability to sell debt to 3 rd party brokers Day 1 4 4 X Securitization Ability to securitize loans for sale to investors Day 1 N/A 4 2 7. 2 Manage Distributions Process Key In Scope L 0 Process L 1 Process Performed recoveries using CACS; their instance of RMS is dated and needs replacement § PA: Would need to upgrade to Client X RMS version to support flow debt sale functionality Client X employs today § PA: Bank does have some post-charge off work on indirect auto side Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 102

Functional Assessment Capability Detailed Findings – Consumer Lending / National Lending 8. Manage Recoveries and Collections High Level Capabilities CL High Level Capability NL Description Timing Client X Rating CL NL Compa ny Y Rating Comments / Implications § BD: Company Y has an Auto 8. 1 Manage Collections X Collections Processes X Specialty Collections Processes 8. 2 Manage Recoveries 8. 3 Detect and Prevent Support collections processes executed to recover payments from delinquent customers Day 1 4 4 ` dialer – Novel System – integrated with CACS § PA: RMS is integrated with CACS, but would need to be upgraded to support functionality Client X employs today § PA: Does not use 3 rd party vendors for early stage collections – done in house, but has been used in the past § PA: Automatic Line Management is not being used at Company Y § PA: CACS can hold multiple Support various specialty collections processes for exception situations promises Day 1 4 4 3 § PA: CACS is capable of queuing and reporting by site or geography § PA: System has the capability X Charge Offs Ability to support charge off processing Day 1 4 4 Process Key In Scope L 0 Process L 1 Process Performed 3 of charging automatically, can be an automated charge off process § PA: Right now Company Y charges off manually on a monthly basis Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 103

Functional Assessment Capability Detailed Findings – Consumer Lending / National Lending High Level Capabilities 9. Manage Risk CL 9. 1 Manage Credit Risk NL X X 9. 2 Manage Credit Risk Assurance Description Timing Client X Rating CL NL Compa ny Y Rating Compliance and Reporting Requirements Support the management of compliance and reporting requirements (e. g. , Manage Credit Bureau Reporting, Manage 1502 Reporting (SBL Only)) Day 1 4 4 TBD Credit Risk Splitting Sophistication Ability to support credit risk splitting (credit policy, bureau connectivity, data usage capability, interaction with credit policy) Day 1 3 4 2 Comments / Implications § TBD – need input from Compliance workstream § PA: Sophistication of NIL business is much more able to handle the local banking credit policy § PA: Utilizes credit bureau flags X 9. 3 Manage Regulatory Affairs & Compliance High Level Capability Application Fraud Processes Ability to perform fraud review, notify appropriate persons, and decision issue accordingly during the application capture process Day 1 4 4 4 that run against CIS flag (some nightly, some weekly) § PA: Flag alerts within ACAPS, this is the situation, this is what is needed from an investigative standpoint § PA: Utilizes Ver. ID 9. 4 Manage Enterprise Risk, Operational Risk, and Dept Admin Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 104

Functional Assessment Findings A. B. C. D. E. F. G. H. Consumer Deposits Small Business Deposits Commercial Deposits (including Treasury) National Direct Bank Deposit Operations Consumer Lending Small Business Lending Commercial Lending

Product Considerations

Functional Assessment Product Detailed Findings – Small Business Lending Compa ny Y ACBS Installment Loans Ability to support the following product features: Fixed and Variable Rate Simple and ADB Interest Single and Joint Applicants 36 – 84 Month Terms Fulfillment via check Unsecured Only Reloads (Refinances) Point of Sale Loans § - Ability to support the following product features: Fix Rate Only Simple and ADB Interest Single Applicants Only 84 - 96 Month Terms Unsecured Only Deferred interest Reloads (Refinances) Small Business Loans § - Ability to support the following product features: Fix and Variable Rate Simple and ADB Interest Single and Joint Applicants 24 – 72 Month Terms Secured and Unsecured Reloads (Refinances) Comments / Implications § BD / CE: Sophisticated overdraft Day 1 3 4 TBD Day 1 4 4 TBD Line of Credit (HELOC) § - Business Differentiation § Ability to support overdraft protection product § Ability to link to a DDA / Card (similar to Company Y) § Support the ability to tie the product to Home Equity Timing Process Alignment Overdraft Protection Desired Features / Description Company Y Rating Customer Experience Product Client X Rating * functionality at Company Y; can tie to DDA or HELOC § Company Y does not currently link to card (business decision) § CE: Company Y does support installment loans through RDS § No current support for POS loans at Day 1 4 2 TBD Company Y. Core functionality is represented by Company Y as existing, but significant development/ configuration would be required to support at scale § Company Y splits SB loans between ACBS Day 1 3 3 TBD and Company Y Loans. Expect some degree of development required to support Client X book Rating Key * Multiple platforms used for originations and servicing (i. e. Shaw, ALS, CBS) Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 107

Functional Assessment Product Detailed Findings – Small Business Lending Compa ny Y Business Differentiation Timing Process Alignment Desired Features / Description Company Y Rating Customer Experience Product Client X Rating * ACBS Ability to adjust amortization schedule when payment is made out of schedule, “re-amortization” Day 1 3 TBD 4 “Re-amortize” payment when rate changes Day 1 3 TBD 4 Capture various accrual bases (maintain flexibility) Day 1 4 TBD 4 Ability to track parent-child relationships (subcommitments) Day 1 3 TBD 4 Ability to track legal v. non-legal commitments (for performance tracking) Day 1 3 TBD 4 Ability to calculate unused amount of commitment (exposure) Day 1 3 TBD 4 Ability to book reduction of unused commitment Day 1 4 TBD 4 Comments / Implications § PA: ACBS supports amortization without limits on the number of billing schedules § PA: ACBS offers the ability to ‘auto All Products amortize’ on every payment in one click with various options for re-amortization to kick in § PA: This is native functionality within ACBS § PA: ACBS supports parent and child capabilities § PA: ACBS supports this and has the ability to can set these up in one or two facilities § PA: ACBS will take to an additional level by auto withholding amounts § PA: This is native functionality within ACBS § PA: All loan products are tracked within Ability to track all products within total relationship Day 1 4 TBD 4 ACBS data mart § PA: All loan and deposit relationships held within Company Y CIS Construction Ability to add an additional amount beyond the payment amount (without adjusting the original payment structure) Day 1 3 TBD 4 Automation related to tracking against original budget and plan for disbursements Day 1 1 TBD 4 Automation related to ability to capture state lien laws and other state-specific data Post Day 1 2 TBD 4 § PA: This is native functionality within ACBS § PA: CLCS has the ability to capture budget for disbursements, which can be multiple types (house level, project level) § PA: CLCS has the ability to capture state lien laws Rating Key * Multiple platforms used for originations and servicing (i. e. Shaw, ALS, CBS) Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 108

Functional Assessment Product Detailed Findings – Small Business Lending Compa ny Y Business Differentiation Timing Process Alignment Desired Features / Description Company Y Rating Customer Experience Product Client X Rating * ACBS Escrow: availability to pay multiple diff taxes at multiple times of the year Day 1 4 TBD 2 Capture additional documentation with defined user fields for number of units, vacancies (multi-family real estate) Day 1 3 TBD 4 Comments / Implications § PA / BD: Require building an interface and tax payment due reporting § PA: Able to capture additional Commercial Mortgage Asset-Based Lending documentation depending on fields § ACBS will open up additional screens for Real Estate Escrow processing to include interest on some loans and not on others Day 1 3 TBD 3 Perform escrow analysis Day 1 4 TBD 3 Automated ability to track A/R and Inventory from borrowers to generate accounting base for accounting inputs (and in turn, a borrowing base) § PA / BD: ACBS possesses escrow functionality, although warrants further analysis of functionality § PA: Currently brought in electronically with Day 1 4 TBD 4 interface, however, could set up criteria to enter receivables and borrowing base to calculate § BD: Would require an interface to perform International Lending Continue to support International Export Related Lending Day 1 4 TBD 2 documentary credits, currently outsourced to M&T as processor; exposures captured on ACBS § BD: Able to perform Non-documentary credits § Note: ACBS is a multi currency system Rating Key * Multiple platforms used for originations and servicing (i. e. Shaw, ALS, CBS) Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 109

Capability Considerations

Functional Assessment Capability Detailed Findings – Small Business Lending 2. Develop Products & Services High Level Capabilities High Level Capability Description Timing Client X Rating Company Y Rating Comments / Implications § PA: Company Y new product launches 2. 1 Ideate New Product Rollout Ability to roll out new products at a rate of several per year per LOB Perform Relationship Pricing Ability to relationship price (rate or fee depends on criteria such as balance level, use of services) Support Product Bundling Ability to support bundling of products (tie products together and modify rates, fees, and other features) Post Day 1 2 3 Support Account Linking between Deposit and Lending Products Ability to link accounts to transfer funds (e. g. , Checking account to HELOC) Post Day 1 2 4 Rate Adjustment Provide the ability to cap rates on variable products and modify rates for particular promotions Post Day 1 3 3 follow their SDLC process and are on biannual release § PA: Company Y can roll-out new product model within ~ 30 – 90 days; complex may take longer § PA: RDS integration with core deposits 2. 2 Perform Feasibility Post Day 1 2 3 provides ready access to relationship information § PA / CE: Can perform relationship packaging / pricing – rate or fee can depend on different criteria § BD / CE: Company Y has pre-defined 2. 3 Prioritize Initiatives 2. 4 Develop and Deliver Functionality bundles that operate today. Moderate degree of effort needed to define new bundles based on Client X business decisions § PA / CE: Lending and deposit products can be linked via RDS/ACAPS/Company Y Loans § CE: Rates can be adjusted based on balance tiers the customer is in 2. 5 Launch Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 111

Functional Assessment Capability Detailed Findings – Small Business Lending 2. Develop Products & Services High Level Capabilities High Level Capability Pricing Model Description Timing Client X Rating Company Y Rating Support a loan pricing model which considers deposit based relationships, also based on profitability and risk rating Day 1 3 3 Comments / Implications § PA: Utilize Excel based modeling which considers pricing, deposit relationship § PA: Manual entry for Deposit relationship 2. 1 Ideate § PA / BD: ACBS supports multiple pricing Pricing / Products within Facility Support multiple pricing and products under one facility Day 1 4 and product schemes within a facility as well as flexibility related to setting up facilities by deal 4 § PA: Pull all loan relationship data from 2. 2 Perform Feasibility ACBS data mart Product Reporting Ability to pull in entire relationship and household Day 1 4 3 § PA: View of deposit relationships depending upon Company Y CIS (could feed Company Y CIS to data mart for full view) § PA: Excel pricing model maintains net 2. 3 Prioritize Initiatives Profitability Analysis Detailed profitability analysis on customer and products at the relationship level Post Day 1 3 3 revenue contribution rates and risk adjusted ROE § PA: Relationship could be manually entered into pricing model for profitability at relationship level 2. 4 Develop and Deliver Functionality 2. 5 Launch Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 112

Functional Assessment Capability Detailed Findings – Small Business Lending 2. Develop Products & Services High Level Capabilities High Level Capability Pricing Model Description Timing Client X Rating Company Y Rating Support a loan pricing model which considers deposit based relationships, also based on profitability and risk rating Day 1 3 3 Comments / Implications § PA: Utilize Excel based modeling which considers pricing, deposit relationship § PA: Manual entry for Deposit relationship 2. 1 Ideate § PA / BD: ACBS supports multiple pricing Pricing / Products within Facility Support multiple pricing and products under one facility Day 1 4 and product schemes within a facility as well as flexibility related to setting up facilities by deal 4 § PA: Pull all loan relationship data from 2. 2 Perform Feasibility ACBS data mart Product Reporting Ability to pull in entire relationship and household Day 1 4 3 § PA: View of deposit relationships depending upon Company Y CIS (could feed Company Y CIS to data mart for full view) § PA: Excel pricing model maintains net 2. 3 Prioritize Initiatives Profitability Analysis Detailed profitability analysis on customer and products at the relationship level Post Day 1 3 3 revenue contribution rates and risk adjusted ROE § PA: Relationship could be manually entered into pricing model for profitability at relationship level 2. 4 Develop and Deliver Functionality 2. 5 Launch Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 113

Functional Assessment Capability Detailed Findings – Small Business Lending High Level Capabilities 3. Market Products High Level Capability Description Timing Client X Rating Company Y Rating Product Offer Repository Ability to access information relating to the product offers that have been extended to a customer Post Day 1 3 2 Predefined Marketing Offers Ability to setup and manage a predefined list of marketing offers to a predefined list of prospects or customers Post Day 1 4 2 Pipeline Management: Front-end interface for bankers to manage their own pipeline including: entering new opportunities, advancing opportunities from stage to stage, query and sort by client, tier, size and stage of opportunity Day 1 3 4 Comments / Implications § PA: Limited ability to track where an 3. 1 Plan Marketing application came from (RDS tracks walk-in / online) § BD / PA / CE: Company Y does not 3. 2 Develop Creatives and Execute Marketing Sales Force Management Householding § CE / PA: Sales. Force. com manages leads Day 1 3 4 Ability to identify and stratify by roles in lending process (e. g. , Relationship Manager, Underwriter, Portfolio Manager, Account Executive, Credit Officer, Loan Administrator) as well as function, business unit, P&L Post Day 1 3 4 Central repository of prospects in footprint periodically updated from reliable external list providers (e. g. Dn. B) Post Day 1 3 2 Day 1 3 3 Salesforce. com for notes and interview and are able to enter data § Note: Security capabilities are available § PA: Company Y catalogs and identifies Multiple house holds for customer relationships and credit (Underwriting can view all interrelationships) L 1 Process Performed and pipeline management as well as origination progress § Note: Not integrated to ACBS or Baker Hill § CE: Company Y UW/Credit analysts view Through underwriting, query system to get prospecting updates; get input by RM, but also UW have their own notes and assessments activity as well as roles throughout the process § PA / BD: Require an interface to Dn. B to upload external prospect lists § PA: Company Y has the ability to see Process Key In Scope L 0 Process currently utilize true pre-defined marketing offers at specific segments § CE: Company Y Campaigns are currently directed at the entire customer base relationships and household in Company Y CIS, although no current feed into ACBS Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 114

Functional Assessment Capability Detailed Findings – Small Business Lending High Level Capabilities 4. Acquire Customers 4. 1 Perform Consultative Selling High Level Capability Application Capture (Origination) Solicitation (Origination) 4. 2 Open Account via Banker Decisioning (Origination) Description Timing Company Y Rating Comments / Implications Provide the ability for customers to apply for loans through the online, Branch, Mail and phone channels Ability to make all products available and originate through the online, branch, and call center channels Support SOL Setup, Change and Update Solicitation Ability to support real-time decisioning Provide automated decisioning models and tools (e. g. , credit modeling) Ability to approve loans , fund loans, disburse checks and socialize disclosures with customers 4. 3 Open Account via Call Center Client X Rating RFP process on going to select new Small Business Originations Platform Ability to decline and initiate adverse action correspondence 4. 4 Open Account via Online Fulfillment (Origination) Support gathering and tracking documentation Ability to support the customer on-boarding process to assist a customer prior to their check being cashed and their loan boarded onto ALS Ability to support the issuance of checks, checkbooks, and electronic funds transfer Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 115

Functional Assessment Capability Detailed Findings – Small Business Lending High Level Capabilities 4. Acquire Customers 4. 1 Perform Consultative Selling 4. 2 Open Account via Banker 4. 3 Open Account via Call Center 4. 4 Open Account via Online High Level Capability Description Timing Multi-Channel Originations Ability for customers to originate products across all channels (e. g. , start on the web and finish in the branch) Application Processing Ability to support single and joint application processing Customer Needs Assessment Ability for customer to enter data and have a product recommendation delivered real-time Pre-Approval Ability to see if a customer is pre-approved for other Client X products (like a card) real-time Customer Credit Check Ability to pull credit at the time of account opening Product Information Provide Banker or sales professional with detailed product information to drive conversation Single Sign-On Single sign-on to a single system that interfaces with others as necessary; no duplicate entry Pre-populate Demographic Information Ability to pre-fill customer info if the customer already has another Client X product (including national businesses like Card / Auto) Overdraft Linkage Ability to link card to DDA as overdraft protection Automated Underwriting Provide automated underwriting functionality Automated Process Workflow Provide automated workflow capabilities throughout the lifecycle of the account opening process Client X Rating Company Y Rating RFP process on going to select new Small Business Originations Platform Process Key In Scope L 0 Process L 1 Process Performed Comments / Implications Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 116

Functional Assessment Capability Detailed Findings – Small Business Lending High Level Capabilities 4. Acquire Customers 4. 1 Perform Consultative Selling 4. 2 Open Account via Banker 4. 3 Open Account via Call Center 4. 4 Open Account via Online High Level Capability Description Timing Application Requirements Ability to provide customer expectations in terms of what s/he needs to complete the lending process (e. g. , checklist) Bundle Decisioning Ability to decision entire product bundle (not just product by product) Comprehensive Application View Provide a comprehensive view of simultaneous applications Credit Analysis Support standardized tools and procedures for the first pass loan analysis prior to formal decisioning (e. g. , use of Moody's platform) Statement Spreading Ability to spread multiple statements, annuals and interims within a centralized spreading location Statement Consolidation Functionality of consolidation for two statements together – rolling 4 th quarter statement, financial templates, accommodate different types of businesses Credit / Risk Rating Sophisticated risk rating (e. g. , dual risk rating – (probability of default model)) and analysis capabilities Loan Monitoring Capture initial loan monitoring including documentation and covenant tracking (define own ratios, calculate and store) Credit Bureaus Retrieve FICO and credit reports (need both business and consumer bureaus) Client X Rating Company Y Rating RFP process on going to select new Small Business Originations Platform Process Key In Scope L 0 Process L 1 Process Performed Comments / Implications Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 117

Functional Assessment Capability Detailed Findings – Small Business Lending High Level Capabilities 4. Acquire Customers 4. 1 Perform Consultative Selling 4. 2 Open Account via Banker 4. 3 Open Account via Call Center 4. 4 Open Account via Online High Level Capability Description Timing Decision Rules Embedded rules and escalations with audit trail of who made approval Decision Tracking of turn downs, policy exceptions of underwriting criteria and archiving Decision Notification Streamlined notification of decisions to internal and external stakeholders Credit Decisioning Ability to electronically review and approve or decline loan package including electronic attachments, routing, recording, and tracking of policy exceptions Pricing Track inputs/outputs in credit files used to produce rate, terms and conditions End to End Pipeline from underwriting to documentation (tracking from documentation to receipt back from packages) Terms & Conditions Automation related to the ability to modify terms and conditions with notification to the appropriate parties Pre-populate Ability to pre-populate documents with previously gathered customer information Archiving Files Generate and archive versions as document / file changes prior to closing Flood Verification Verify that loans secured by real property are not in a flood plain and/or have appropriate flood insurance. Document Generation Automated document generation pre-close (e. g. , negotiation documents, term sheets) Client X Rating Company Y Rating RFP process on going to select new Small Business Originations Platform Process Key In Scope L 0 Process L 1 Process Performed Comments / Implications Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 118

Functional Assessment Capability Detailed Findings – Small Business Lending High Level Capabilities 4. Acquire Customers 4. 1 Perform Consultative Selling 4. 2 Open Account via Banker 4. 3 Open Account via Call Center High Level Capability Description Timing Document Formats Ability for system to support document formats (i. e. , PDF, Word, Excel) Pre-close Checklist System requires checklist pre-close and post close with exceptions issued pre-close Automated Process Workflow Provide automated workflow capabilities from originations to booking to handle SOX requirements Document Review Verification that all appropriate documentation has been gathered as part of booking the loan (i. e. , document controls to ensure docs are tracked and received) based on factors and manageable doc rules Loan Attribute Verification Ability for auto data reconciliation between origination system and processing system verifies loan is booked in accordance with the front end documents Compliance Related Workflow Automation and workflow associated with loan compliance measures including (Know your Customer OFAC, CRA, CIP) Client X Rating Company Y Rating Comments / Implications RFP process on going to select new Small Business Originations Platform 4. 4 Open Account via Online Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 119

Functional Assessment Capability Detailed Findings – Small Business Lending High Level Capabilities 5. Service Customers High Level Capability 5. 1 Process Customer Request Multiple Payment Types Description Timing Ability to support different types of payment (interest only, % of payment, staggered due dates, drop dates for bill borrower) Day 1 Client X Rating 4 Company Y Rating Comments / Implications Comp any Y ACBS TBD 4 § CE / BD: Native ACBS supports a multiple types of payments § BD: Company Y maintains standard Reporting Ability for standard and ad hoc reporting Day 1 4 TBD 4 Ability to capture Guarantor information Day 1 4 TBD 4 Ability for limited guarantee or non-limited guarantee Day 1 4 TBD 4 5. 2 Process Bank Initiated Transactions Guarantor 5. 3 Manage Content § PA: ACBS supports guarantor information § PA: ACBS can add under loan, facility or customer, can make limited or unlimited and can specify what they are limited too § PA: Ability to set processing rules for Pulling Rates / Data Have the capacity to differentiate business days from calendar days for the purposes of pull rates and data Debit DDA Ability for automatic debit on DDA account (take payments from customer’s DDA accounts directly) Day 1 Real time Transactions Loan and deposit system transactions are real time Day 1 Monthly Statements Produce monthly loan statements (including line of credit) also available on demand with Post Day 1 breakdown of how payments were applied with interest and escrows Process Key 5. 4 Add Ancillary Products to Existing Account 5. 5 Manage Banking Operations reports using business objects on data mart with ability to write a query § Note: All reporting off data mart is end of day yesterday Post Day 1 1 TBD 3 holiday, last day of month or last day of year § Note: Flexible to count ahead or in the past; can set multiple calendars § CE: Automatic debit on DDA is overnight, In Scope L 0 Process L 1 Process Performed L 1 Process Not Performed Confidential not real time 4 TBD 4 § Note: Ability to auto debit for additional funds to principle or escrow and auto two way sweep 1 TBD 4 3 TBD 4 § CE: All loan systems are real time § BD: Booking and servicing is real time § BD / CE: Company Y built ACBS statements report off data mart, which has ability to auto consolidate Rating Key 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 120

Functional Assessment Capability Detailed Findings – Small Business Lending High Level Capabilities 5. Service Customers High Level Capability 5. 1 Process Customer Request Company Y Rating Comp any Y Comments / Implications ACBS § PA / CE: ACH credits are manual, ACH Facility Search Ability to look up facilities by collateral, address, etc. (enhanced search functionality) Day 1 3 TBD 3 Post Day 1 1 TBD 4 Day 1 4 TBD 3 although could be automated with an interface § PA / CE: ACH debits are automated § CE / PA: Search functionality within ACBS Ability to pay interest on escrow funds Escrow data mart including approximately six types of searches (as of day prior) § PA: Currently not performed, although could in ACBS by setting up parameters § PA: Currently not performed, although Ability to track insurance cancellation with exception list Day 1 4 TBD 3 could do insurance premiums in ACBS § PA: Capability to feed external vendors, although not used currently 5. 3 Manage Content Payment Schedules 5. 5 Manage Banking Operations Timing Ability to perform incoming and outgoing ACH transactions 5. 2 Process Bank Initiated Transactions 5. 4 Add Ancillary Products to Existing Account Description Client X Rating Support multiple payment scheduling types including principal only, interest only, principal and interest, fixed principal plus interest due, and interest plus a % of principal balance Day 1 4 TBD 4 § CE: Ability to create and attach own payment schedule § PA / CE: Able to see pending transactions Pending Transaction Processing Ability to process a pending transaction Line of Credit Reporting Ability to report all used and unused credit lines in the form of a commitment report Online Banking Ability to integrate with online banking site to show all commercial customer relationships Day 1 4 TBD 4 and go in change and delete them § PA: Must have a primary but can have multiple secondary (within limits) § PA: ACBS supports reporting on unused Post Day 1 3 TBD credit lines in the form of a commitment report 4 § CE / BD: Customers can pull account Post Day 1 3 TBD 3 Process Key In Scope L 0 Process L 1 Process Performed L 1 Process Not Performed Confidential balance and see transactions , however this is a view only § CE: Currently batch feed of information to OLB, however, ability to do real time Rating Key 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 121

Functional Assessment Capability Detailed Findings – Small Business Lending High Level Capabilities 5. Service Customers High Level Capability ACBS 3 TBD 4 Ability to capture pending rate change, pending P&I change (to move into payment schedule) Day 1 4 TBD 4 Ability to support staggered due dates and drop dates for billing Day 1 4 TBD 4 Thresholds Support thresholds in loan process, for example, loan floors, min balances, LIBOR floors (also should include portfolio limits) Day 1 3 TBD 3 Payments Allow for payment of taxes in multiple jurisdictions Day 1 4 TBD 4 5. 2 Process Bank Initiated Transactions Track Index Pricing Ability to review, maintain (e. g. , add / remove) and track various indexes and historic view of indexes Comments / Implications Comp any Y Day 1 Billing Schedule 5. 4 Add Ancillary Products to Existing Account Timing Company Y Rating Ability to set up large number of billing schedules (i. e. 5 yr interest only, 20 yr amortized schedule, unique monthly billings for life of loan) 5. 1 Process Customer Request 5. 3 Manage Content Description Client X Rating § BD: ACBS has no limit on the number of billing schedules § BD: ACBS supports pending rate changes and P&I changes § BD: ACBS supports staggered due dates and drop dates § BD: ACBS supports thresholds, although portfolio limits are not a core capability § PA: ACBS supports payment of taxes in multiple jurisdictions § PA: No limits on index pricing within ACBS § Note: Ability to look at history on any one Day 1 4 TBD 4 index and search in either past or future § Note: Manually input index, ability to upload is there, and could get from treasury operation 5. 5 Manage Banking Operations Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 122

Functional Assessment Capability Detailed Findings – Small Business Lending 6. Manage Customer Relationships High Level Capabilities High Level Capability Description Timing Client X Rating Company Y Rating Comments / Implications § PA: Native ACBS possesses loan Notifications Automated ability to generate loan review notifications of approaching and past due requirements Day 1 3 4 Document Receipt Status Tracking whether required loan review documentation has been received Day 1 3 4 6. 1 Manage Portfolio 6. 2 Execute Customer Management Strategy 6. 3 Retain Customers notification built in with ability for user to sign in and have notices § PA: Ability to tie to email system to send notifications § PA: Company Y’s Baker Hill, the system of record, tracks core collateral and review documentation § PA / CE: ACBS able to make advances on loans or payments Automatic Transactions Ability to make advance on payment and credit to customers account Post Day 1 Covenant Tracking Automation related to maintaining covenant requirements established during underwriting or credit review Post Day 1 1 4 § PA: Ability to debit account and complete online transaction against loan or advance against loan without live tickets 3 3 § PA: Baker Hill Advisor will automate covenant requirements monitoring § PA: Baker Hill, the system of record, tracks core collateral 6. 4 Solicit Customer Feedback Collateral Monitoring Automation related to monitoring and maintaining collateral (including marketable securities) § Note: expected increased automation with Post Day 1 4 4 Baker Hill Advisor implementation § Note: Able to be done in ACBS (which feeds Baker Hill with basic facility information) Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 123

Functional Assessment Capability Detailed Findings – Small Business Lending 8. Manage Recoveries and Collections 8. 1 Manage Collections High Level Capabilities High Level Capability Description Timing Delinquency Ability to maintain the number of times delinquent on installment debt to date Fraud Automated fraud check and fraud verification pre and post booking; includes risk rating and grids Day 1 Client X Rating Company Y Rating 3 4 Comments / Implications § PA: ACBS field provides number of times (not incremental) § PA: No specific checks exist within ACBS; Day 1 3 requires further analysis into desired functionality to support operational fraud practices 1 § BD: Company Y has an Auto dialer – Novel System – integrated with CACS § PA: RMS is integrated with CACS, but 8. 2 Manage Recoveries Collections Processes Support collections processes executed to recover payments from delinquent customers Day 1 4 3 Specialty Collections Processes Support various specialty collections processes for exception situations Day 1 4 3 8. 3 Detect and Prevent would need to be upgraded to support functionality Client X employs today § PA: Does not use 3 rd party vendors for early stage collections – done in house, but has been used in the past § PA: Automatic Line Management is not being used at Company Y § PA: CACS can hold multiple promises § PA: CACS is capable of queuing and reporting by site or geography § PA: System has the capability of charging Charge Offs Ability to support charge off processing Day 1 4 3 Process Key In Scope L 0 Process L 1 Process Performed automatically, can be an automated charge off process § PA: Right now Company Y charges off manually on a monthly basis Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 124

Functional Assessment Capability Detailed Findings – Small Business Lending High Level Capabilities 9. Manage Risk High Level Capability Description Timing Client X Rating Company Y Rating Comments / Implications § CE: Company Y house-holding defined at Householding Ability to household customers Day 1 4 3 the customer level § CE: Limitation - can be changed in branch or over the phone; not online 9. 1 Manage Credit Risk 9. 2 Manage Credit Risk Assurance 9. 3 Manage Regulatory Affairs & Compliance and Reporting Requirements Support the management of compliance and reporting requirements (e. g. , Manage Credit Bureau Reporting, Manage 1502 Reporting (SBL Only)) Day 1 4 TBD Credit Risk Splitting Sophistication Ability to support credit risk splitting (credit policy, bureau connectivity, data usage capability, interaction with credit policy) Day 1 4 2 Application Fraud Processes Ability to perform fraud review, notify appropriate persons, and decision issue accordingly during the application capture process § TBD – need input from Compliance workstream § PA: Sophistication of NIL business is much more able to handle the local banking credit policy § PA: Utilizes credit bureau flags that run Day 1 4 4 9. 4 Manage Enterprise Risk, Operational Risk, and Dept Admin Process Key In Scope L 0 Process L 1 Process Performed against CIS flag (some nightly, some weekly) § PA: Flag alerts within ACAPS, this is the situation, this is what is needed from an investigative standpoint § PA: Utilizes Ver. ID Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 125

Functional Assessment Findings A. B. C. D. E. F. G. H. Consumer Deposits Small Business Deposits Commercial Deposits (including Treasury) National Direct Bank Deposit Operations Consumer Lending Small Business Lending Commercial Lending

Product Considerations

Functional Assessment Product Detailed Findings – Commercial Lending Day 1 Client X Rating Company Y Rating 4 4 Business Differentiation Ability to adjust amortization schedule when payment is made out of schedule, “re-amortization” Timing Process Alignment All Products Desired Features / Description Customer Experience Product Comments / Implications § PA: ACBS supports amortization without limits on the number of billing schedules § PA: ACBS offers the ability to ‘auto All Products “Re-amortize” payment when rate changes Day 1 4 4 All Products Capture various accrual bases (maintain flexibility) Day 1 4 4 All Products Ability to track parent-child relationships (subcommitments) Day 1 2 4 All Products Ability to track legal v. non-legal commitments (for performance tracking) Day 1 2 4 All Products Ability to calculate unused amount of commitment (exposure) Day 1 2 4 All Products Ability to book reduction of unused commitment Day 1 4 4 amortize’ on every payment in one click with various options for re-amortization to kick in § PA: This is native functionality within ACBS § PA: ACBS supports parent and child capabilities § PA: ACBS supports this and has the ability to can set these up in one or two facilities § PA: ACBS will take to an additional level by auto withholding amounts § PA: This is native functionality within ACBS § PA: All loan products are tracked within All Products Ability to track all products within total relationship Day 1 4 4 ACBS data mart § PA: All loan and deposit relationships held within Company Y CIS All Products Ability to view and track households Post Day 1 3 3 All Products Ability to add an additional amount beyond the payment amount (without adjusting the original payment structure) Day 1 2 4 Construction Automation related to tracking against original budget and plan for disbursements Day 1 1 4 Construction Automation related to ability to capture state lien laws and other state-specific data Post Day 1 2 3 § Company Y CIS would need to be configured to exhibit houesholds § PA: This is native functionality within ACBS § PA: CLCS has the ability to capture budget for disbursements, which can be multiple types (house level, project level) § PA: CLCS has the ability to capture state lien laws Rating Key Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 128

Functional Assessment Product Detailed Findings – Commercial Lending Client X Rating Company Y Rating 2 Commercial Mortgage Escrow: availability to pay multiple diff taxes at multiple times of the year Day 1 3 Commercial Mortgage Capture additional documentation with defined user fields Day 1 for number of units, vacancies (multi-family real estate) 3 Business Differentiation Timing Process Alignment Desired Features / Description Customer Experience Product Comments / Implications § PA / BD: Require building an interface and tax payment due reporting § PA: Able to capture additional 4 documentation depending on fields § ACBS will open up additional screens for Real Estate Commercial Mortgage Escrow processing to include interest on some loans and Day 1 not on others 3 3 Commercial Mortgage Perform escrow analysis Day 1 3 3 Loan Syndications Ability to support loan syndications (additional detail in capabilities 7. 0 Manage Distributions) Day 1 2 4 Asset-Based Lending Automated ability to track A/R and Inventory from borrowers to generate accounting base for accounting inputs (and in turn, a borrowing base) Day 1 4 Performed on Stuckey § PA / BD: ACBS possesses escrow functionality, although warrants further analysis of functionality § BD / PA: ACBS performs desired participant tracking and agency servicing abilities § PA: Currently brought in electronically with 3 interface, however, could set up criteria to enter receivables and borrowing base to calculate § BD: Would require an interface to perform 4 International Lending Continue to support International Export Related Lending Day 1 Performed on Cibar 2 Debt Client X Markets Fully support debt Client X markets including swaps and derivatives Day 1 3 3 Day 1 Performed on Lease. Plus Equipment Leasing Continue to support Equipment Leasing documentary credits, currently outsourced to M&T as processor; exposures captured on ACBS § BD: Able to perform Non-documentary credits § Note: ACBS is a multi currency system § BD: ACBS handles basic swaps / swap 4 transactions with – with defined standard instruments § BD: Requires significant changes to ACBS 1 as the core platform does not deal with leasing activities Rating Key Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 129

Capability Considerations

Functional Assessment Capability Detailed Findings – Commercial Lending 2. Develop Products & Services High Level Capabilities High Level Capability Pricing Model Description Timing Client X Rating Company Y Rating Support a loan pricing model which considers deposit based relationships, also based on profitability and risk rating Day 1 3 3 Comments / Implications § PA: Utilize Excel based modeling which considers pricing, deposit relationship § PA: Manual entry for Deposit relationship 2. 1 Ideate § PA / BD: ACBS supports multiple pricing Pricing / Products within Facility Support multiple pricing and products under one facility Day 1 4 and product schemes within a facility as well as flexibility related to setting up facilities by deal 4 § PA: Excel pricing model maintains net 2. 2 Perform Feasibility Profitability Analysis Detailed profitability analysis on customer and products at the relationship level Post Day 1 3 3 revenue contribution rates and risk adjusted ROE § PA: Relationship could be manually entered into pricing model for profitability at relationship level 2. 3 Prioritize Initiatives 2. 4 Develop and Deliver Functionality 2. 5 Launch Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 131

Functional Assessment Capability Detailed Findings – Commercial Lending High Level Capabilities 3. Market Products High Level Capability Description Ability to manage entire relationship and incorporate select information from core systems 3. 1 Plan Marketing 3. 2 Develop Creatives and Execute Marketing Sales Force Management House Holding Timing Client X Rating Company Y Rating Post Day 1 2 2 § PA: Sales. Force. com currently not Pipeline Management: Front-end interface for bankers to manage their own pipeline including: entering new opportunities, advancing opportunities from stage to stage, query and sort by client, tier, size and stage of opportunity Day 1 3 3 Through underwriting, query system to get prospecting updates; get input by RM, but also UW have their own notes and assessments Day 1 3 3 Ability to identify and stratify by roles in lending process (e. g. , Relationship Manager, Underwriter, Portfolio Manager, Account Executive, Credit Officer, Loan Administrator) as well as function, business unit, P&L Post Day 1 3 3 Central repository of prospects in footprint periodically updated from reliable external list providers (e. g. Dn. B) Post Day 1 2 2 Day 1 3 3 § CE / PA: Sales. Force. com manages leads and pipeline management as well as origination progress § Note: Not integrated to ACBS or Baker Hill § CE: Company Y UW/Credit analysts view Salesforce. com for notes and interview and are able to enter data § Note: Security capabilities are available § PA: Company Y catalogs and identifies Multiple house holds for customer relationships and credit (Underwriting can view all interrelationships) L 1 Process Performed functioning to support holistic relationship § Note: Not integrated to ACBS or Baker Hill activity as well as roles throughout the process § PA / BD: Require an interface to Dn. B to upload external prospect lists § PA: Company Y has the ability to see Process Key In Scope L 0 Process Comments / Implications relationships and household in Company Y CIS, although no current feed into ACBS Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 132

Functional Assessment Capability Detailed Findings – Commercial Lending High Level Capabilities 4. Acquire Customers Description Timing Client X Rating Company Y Rating Credit Analysis Support standardized tools and procedures for the first pass loan analysis prior to formal decisioning (e. g. , use of Moody's platform) Day 1 4 4 Statement Spreading Ability to spread multiple statements, annuals and interims within a centralized spreading location Day 1 4 4 4. 2 Open Account via Banker Statement Consolidation Functionality of consolidation for two statements together – rolling 4 th quarter statement, financial templates, accommodate different types of businesses 4. 3 Open Account via Call Center Credit / Risk Rating Sophisticated risk rating (e. g. , dual risk rating – (probability of default model)) and analysis capabilities Day 1 4 2 Loan Monitoring Capture initial loan monitoring including documentation and covenant tracking (define own ratios, calculate and store) Day 1 3 3 Credit Bureaus Retrieve FICO and credit reports (need both business and consumer bureaus) Day 1 3 3 Decision Rules Embedded rules and escalations with audit trail of who made approval Post Day 1 1 1 4. 1 Perform Consultative Selling High Level Capability Comments / Implications § PA / BD: Baker Hill Advisor , implementation due in March 2009, used for loan analysis § PA: Baker Hill Advisor will serve as centralized location to spread multiple statements, annuals, and interims § PA: Ability to consolidate rolling 4 th Day 1 4 quarters would be complex (would involve spreading each quarter on its own, not year to date, and then setting the calculation to combine the 4 th quarters that apply) 2 § PA / BD: Baker Hill Advisor requires 4. 4 Open Account via Online external data (via Moody’s) to perform dual risk rating § Note: ACBS has capability to do split risk and dual risk ratings § PA: Baker Hill Advisor will possess enhanced covenant tracking abilities § PA: Any business and consumer bureaus pulled via websites currently § PA: ACBS Originations only has the ability Process Key In Scope L 0 Process L 1 Process Performed to track approvals under signature Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 133

Functional Assessment Capability Detailed Findings – Commercial Lending High Level Capabilities 4. Acquire Customers 4. 1 Perform Consultative Selling 4. 2 Open Account via Banker High Level Capability Description Timing Client X Rating Company Y Rating Decision Tracking of turn downs, policy exceptions of underwriting criteria and archiving Day 1 1 2 Decision Notification Streamlined notification of decisions to internal and external stakeholders Post Day 1 1 2 Credit Decisioning Ability to electronically review and approve or decline loan package including electronic attachments, routing, recording, and tracking of policy exceptions Post Day 1 1 2 Comments / Implications § PA: ACBS Origination will offer tracking as a function of term sheets to maintain records and built in time stamping § BD / PA: Implementation of ACBS Origination will offer ability to kick out commitment to customer and internal email notifications if term sheet has changed § BD / PA: ACBS Origination with no central tracking repository for approvals, declines, or exceptions § PA: Ability to view inputs/outputs in 4. 3 Open Account via Call Center 4. 4 Open Account via Online Company Y’s Excel based pricing model Track inputs/outputs in credit files used to produce rate, terms and conditions Post Day 1 End to End Pipeline from underwriting to documentation (tracking from documentation to receipt back from packages) Post Day 1 1 3 Terms & Conditions Automation related to the ability to modify terms and conditions with notification to the appropriate parties Post Day 1 1 2 Pre-populate Ability to pre-populate documents with previously gathered customer information Post Day 1 1 3 Pricing Tracking 1 2 workflow exists today to produce terms and conditions L 1 Process Performed § PA: ACBS Originations tracks receipts of documentation through loan processing § PA: Once imaging is implemented, could Process Key In Scope L 0 Process § PA: ACBS Originations although no modify terms and conditions, with approval, to feed ACBS and release notifications § PA: Laser. Pro will pre-populate with the implementation of ACBS Origination Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 134

Functional Assessment Capability Detailed Findings – Commercial Lending High Level Capabilities 4. Acquire Customers High Level Capability Description Timing Client X Rating Company Y Rating Comments / Implications § PA: Capability to copy package, version, Archiving Files 4. 1 Perform Consultative Selling Generate and archive versions as document / file changes prior to closing and index into ACBS exists Post Day 1 2 3 not currently implemented within originations process § PA: Baker Hill document tracking system Flood Verification Verify that loans secured by real property are not in a flood plain and/or have appropriate flood insurance. Document Generation Day 1 3 3 Automated document generation pre-close (e. g. , negotiation documents, term sheets) Post Day 1 1 4 Pre-close Document Formats Ability for system to support document formats (i. e. , PDF, Word, Excel) Post Day 1 1 3 Closing Document Formats Ability for system to support document formats (i. e. , PDF, Word, Excel) Day 1 4 4 4. 2 Open Account via Banker 4. 3 Open Account via Call Center § Note: Imaging platform installed, although in addition to 3 rd party life of loan flood zone identifier § PA: ACBS has flood capabilities which Small Business is currently experimenting with § PA: ACBS Originations includes built in templates of which will populate the commitment letter § PA / CE: ACBS Originations supports documentation in PDF and other formats pre-close § PA / CE: Company Y utilizes Laser. Pro which supports closing documentation in PDF and other formats § PA: Checklist , based on type of loan 4. 4 Open Account via Online Pre-close Checklist System requires checklist pre-close and post close with exceptions issued pre-close Automated Process Workflow Provide automated workflow capabilities from originations to booking to handle SOX requirements Post Day 1 1 2 (although not the structure of the deal), is software is by an outside vendor tool; and not integrated with other systems § Consideration: determine how this will integrate with ACBS Origination § PA: ACBS Origination system will offer Post Day 1 2 3 Process Key In Scope L 0 Process L 1 Process Performed tracking timing between approval and receipt of documents § Note: Salesforce. com also offers basic statuses Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 135

Functional Assessment Capability Detailed Findings – Commercial Lending High Level Capabilities 4. Acquire Customers 4. 1 Perform Consultative Selling High Level Capability Timing Client X Rating Company Y Rating Document Review Verification that all appropriate documentation has been gathered as part of booking the loan (i. e. , document controls to ensure docs are tracked and received) based on factors and manageable doc rules Day 1 1 2 Loan Attribute Verification Ability for auto data reconciliation between origination system and processing system verifies loan is booked in accordance with the front end documents Day 1 1 3 Compliance Related Workflow Automation and workflow associated with loan compliance measures including (Know your Customer OFAC, CRA, CIP) Description Comments / Implications § PA: ACBS Originations tracks receipts of documentation through loan processing § PA: Company Y ACBS Origination 4. 2 Open Account via Banker implementation will offer additional automation for reconciliation purposes § ACBS Originations will begin when a Day 1 2 customer moves from prospect to real customer – do not do now – could monitor – but could – Currently house CRA in ACBS do CRA reporting out of ACBS 2 4. 3 Open Account via Call Center 4. 4 Open Account via Online Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 136

Functional Assessment Capability Detailed Findings – Commercial Lending High Level Capabilities 5. Service Customers High Level Capability Description Timing Client X Rating Company Y Rating Comments / Implications § PA / CE: ACH credits are manual, Day 1 3 3 Ability to pay interest on escrow funds Day 1 4 4 Systematic capture for cancellation notice and reporting from insurance providers Day 1 4 3 Automated insurance tracking and receipt of notice Day 1 2 2 Capture insurance exception reporting Day 1 4 4 Payment Schedules Support multiple payment scheduling types including principal only, interest only, principal and interest, fixed principal plus interest due, and interest plus a % of principal balance Day 1 4 4 Pending Transaction Processing Ability to process a pending transaction Day 1 4 4 Line of Credit Reporting Ability to report all used and unused credit lines in the form of a commitment report Post Day 1 2 4 credit lines in the form of a commitment report Ability to look up facilities by collateral, address, etc. (enhanced search functionality) Post Day 1 2 4 § CE / PA: Search functionality within ACBS Facility Search ACBS data mart ACH 5. 1 Process Customer Request 5. 2 Process Bank Initiated Transactions 5. 3 Manage Content 5. 4 Add Ancillary Products to Existing Account 5. 5 Manage Banking Operations although could be automated with an interface § PA / CE: ACH debits are automated Ability to perform incoming and outgoing ACH transactions Escrow could in ACBS by setting up parameters § PA: Capability to feed external vendors, although not used currently § PA: Would require development to automate insurance and receipt § PA: Currently not performed, although could report exceptions in ACBS § CE: Ability to create and attach own payment schedule § PA / CE: Able to see pending transactions and go in change and delete them § PA: Must have a primary but can have multiple secondary (within limits) § PA: ACBS supports reporting on unused Process Key In Scope L 0 Process § PA: Currently not performed, although L 1 Process Performed data mart including approximately six types of searches (as of day prior) Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 137

Functional Assessment Capability Detailed Findings – Commercial Lending High Level Capabilities 5. Service Customers 5. 1 Process Customer Request High Level Capability Billing Schedule 5. 2 Process Bank Initiated Transactions Thresholds 5. 3 Manage Content Tax Payments 5. 4 Add Ancillary Products to Existing Account Multiple Payment Types Description Timing Client X Rating Company Y Rating Ability to set up large number of billing schedules (i. e. 5 yr interest only, 20 yr amortized schedule, unique monthly billings for life of loan) Day 1 4 4 Ability to capture pending rate change, pending P&I change (to move into payment schedule) Day 1 4 4 Ability to support staggered due dates and drop dates for billing Day 1 4 4 Support account level thresholds in loan process, for example, loan floors, min balances, LIBOR floors (also should include portfolio limits) Day 1 4 4 Support thresholds at the portfolio level Day 1 3 3 Allow for payment of taxes in multiple jurisdictions Day 1 4 4 Comments / Implications § BD: ACBS has no limit on the number of billing schedules § BD: ACBS supports pending rate changes and P&I changes § BD: ACBS supports staggered due dates and drop dates § BD: ACBS supports thresholds, although portfolio limits are not a core capability Ability to support different types of payment (interest only, % of payment, staggered due dates, drop dates for bill borrower) § PA: ACBS supports payment of taxes in multiple jurisdictions § CE / BD: Native ACBS supports a multiple types of payments § BD: Company Y maintains standard Reporting Ability for standard and ad hoc reporting Day 1 4 4 5. 5 Manage Banking Operations reports using business objects on data mart with ability to write a query § Note: All ad hoc reporting off data mart is end of day yesterday § CE / BD: Customers can pull account Online Banking Ability to integrate with online banking site to show all commercial customer relationships Post Day 1 2 2 Process Key In Scope L 0 Process L 1 Process Performed L 1 Process Not Performed Confidential balance and see transactions , however this is a view only § CE: Currently batch feed of information to OLB, however, ability to do real time Rating Key 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 138

Functional Assessment Capability Detailed Findings – Commercial Lending High Level Capabilities 5. Service Customers 5. 1 Process Customer Request High Level Capability Guarantor Timing Client X Rating Company Y Rating Comments / Implications Ability to capture Guarantor information Day 1 4 4 § PA: ACBS supports guarantor information Ability for limited guarantee or non-limited guarantee Day 1 4 4 Description § PA: ACBS can add under loan, facility or customer, can make limited or unlimited and can specify what they are limited too § PA: Ability to set processing rules for 5. 2 Process Bank Initiated Transactions Ability to flag business and non business days for changes to any index ratings Track Index Pricing 5. 3 Manage Content Post Day 1 1 3 holiday, last day of month or last day of year § Note: Flexible to count ahead or in the past; can set multiple calendars § PA: No limits on index pricing within ACBS § Note: Ability to look at history on any one Automated interfaces with subscription services to review, maintain (e. g. , add / remove) and track various indexes and historic view of indexes Day 1 2 2 index and search in either past or future § Note: Manually input index, ability to upload is there, and could get from treasury operation § CE: Automatic debit on DDA is overnight, Day 1 Real time Transactions Loan and deposit system transactions are real time Day 1 2 4 Monthly Statements Produce monthly loan statements (including line of credit) also available on demand with breakdown of how payments were applied with interest and escrows Post Day 1 3 4 Debit DDA 5. 4 Add Ancillary Products to Existing Account 5. 5 Manage Banking Operations not real time Ability for automatic debit on DDA account (take payments from customer’s DDA accounts directly) 4 4 funds to principle or escrow and auto two way sweep L 1 Process Performed § BD: Booking and servicing is real time § BD / CE: Company Y built ACBS Process Key In Scope L 0 Process § Note: Ability to auto debit for additional statements report off data mart, which has ability to auto consolidate Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 139

Functional Assessment Capability Detailed Findings – Commercial Lending 6. Manage Customer Relationships High Level Capabilities High Level Capability Description Timing Client X Rating Company Y Rating Comments / Implications § PA: Native ACBS possesses loan Notifications 6. 1 Manage Portfolio Automated ability to generate loan review notifications of approaching and past due requirements Day 1 3 4 notification built in with ability for user to sign in and have notices § PA: Ability to tie to email system to send notifications § PA: Company Y’s Baker Hill, the system of 6. 2 Execute Customer Management Strategy 6. 3 Retain Customers Document Receipt Status Tracking whether required loan review documentation has been received Day 1 3 4 record, tracks core collateral and review documentation § PA: ACBS can perform document receipt status § PA / CE: ACBS able to make advances on loans or payments Automatic Transactions Ability to debit or credit a DDA account for an advancement on a loan payment Post Day 1 Covenant Tracking Automation related to maintaining covenant requirements established during underwriting or credit review Post Day 1 2 4 § PA: Ability to debit account and complete online transaction against loan or advance against loan without live tickets 2 Manual data entry 3 § PA: Baker Hill Advisor will automate covenant requirements monitoring 6. 4 Solicit Customer Feedback Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 140

Functional Assessment Capability Detailed Findings – Commercial Lending 6. Manage Customer Relationships High Level Capabilities High Level Capability Description Timing Client X Rating Company Y Rating Comments / Implications § PA: Baker Hill, the system of record, tracks core collateral 6. 1 Manage Portfolio Collateral Monitoring Automation related to monitoring and maintaining collateral (including marketable securities) § Note: expected increased automation with Post Day 1 4 4 Baker Hill Advisor implementation § Note: Able to be done in ACBS (which feeds Baker Hill with basic facility information) 6. 2 Execute Customer Management Strategy § PA: Baker Hill Advisor Implementation will Compliance Tracking and Notification Automation and tracking related to loan compliance measures Day 1 2 3 offer compliance document housing as well as tracking and required ratios § PA: Ability to identify fields and notify customers with required compliance documentation § PA: Ability to set ticklers (e. g. , by period and day) 6. 3 Retain Customers 6. 4 Solicit Customer Feedback Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 141

Functional Assessment Capability Detailed Findings – Commercial Lending High Level Capabilities 7. Sell Loans 7. 1 Sell Loans to Investors High Level Capability Description Timing Client X Rating Company Y Rating Loan Syndication Indicator Indication of master servicer (vs. participant) and as % entitlements Day 1 3 4 Remit Payments Auto remit payments to participants where appropriate Post Day 1 2 4 Agency Services Support of agency services once loan is booked (Example: generate automatic notifications to participants (whenever a rate change, disbursement)) Post Day 1 2 3 Multiple Syndications Allow for the input of multiple syndicates and participants with the ability to handle greater than five participations Day 1 3 4 7. 2 Manage Distributions § PA / BD: ACBS contains agent record and L 1 Process Performed shows participants with option of % or $ proportion § PA / BD: Auto generate information to receive / remit payments § PA / BD: ACBS email notification system Process Key In Scope L 0 Process Comments / Implications exists, although utilized by Company Y today via faxing notices to members § Note: Has not licensed Synd. Trak § PA / BD: No limit on number of participations Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 142

Functional Assessment Capability Detailed Findings – Commercial Lending 8. Manage Recoveries and Collections 8. 1 Manage Collections High Level Capabilities High Level Capability Description Timing Client X Rating Company Y Rating Delinquency Ability to maintain the number of times delinquent on installment debt to date Day 1 3 3 Fraud Automated fraud check and fraud verification pre and post booking; includes risk rating and grids Day 1 2 2 Comments / Implications § PA: ACBS field provides number of times (not incremental); no aging § PA: Ability to mark a Confirmed Fraud Account with a unique flag immediately upon verification of fraudulent activity. 8. 2 Manage Recoveries 8. 3 Detect and Prevent Process Key In Scope L 0 Process L 1 Process Performed Rating Key L 1 Process Not Performed Confidential 4 Operational 2 Med / High Effort 3 Low / Med Effort 1 Will not support 143