ROCA REPORT CARD Presented to Institute of International

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

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

ROCA REPORT CARD Trend 2005 to 2007

ROCA REPORT CARD § Average ratings this exam cycle versus prior exam cycles § Year 2005 2006 § Risk 1. 83 1. 79 § Operations 1. 94 § Compliance 2. 05 2. 07 § Asset Quality 1. 40 1. 26 1. 95 2007 1. 85 1. 97 2. 22 1. 23

ROCA REPORT CARD

ROCA REPORT CARD

ROCA REPORT CARD § Composite § Most recent exam 1. 99 § Prior exam cycle 1. 97 § Slight decline in the average composite ROCA § Risk Management , Compliance, and Operations declined § Asset Quality Improved

ROCA REPORT CARD § Risk – 7 Upgrades, 11 downgrades § Operations - 7 upgrades 9 downgrades § Compliance 2 upgrades, 15 downgrades § Asset quality- 9 upgrades 4 downgrades

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

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

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