Revenue Manager and Sarbanes-Oxley Compliance

1. Revenue Manager andSarbanes-Oxley Compliance

2. SOX Accountability Standards Sarbanes-Oxley Act of 2002 requires CEOs and CFOs to certify in writing that their financial disclosures are complete and accurate Section 404: Management Assessment of Internal Controls - states the responsibility of management for establishing and maintaining an adequate internal control structure and procedures for financial reporting

3. Your SOX Compliance Requirements Comply with Section 404 Standards by instituting the following internal controls: Support Your Numbers Control Your Data Control Your Security Centralize Your Processing Make Your Data Available to Auditors

4. Revenue Manager System Centralized, Fully Documented Calculations Management of Accounts Receivable Contract Management Accurate and Timely Revenue Recognition Automatic Journal Entry Creation Security and Segregation of Duties Automatic Audit Trails Retains Historical Data

5. Revenue Manager Data Flow

6. Satisfy SOX Audit Standards with Revenue Manager Audit trail – all database tables contain user ID , date and timestamp for additions or changes Transactions are readily available for independent audit and validation Historical data may be viewed on-line to help detect trends of underpayment or overpayments

7. Support Your Numbers Fully Documented Calculations all supporting details are stored in the database for reporting. Detailed Documentation for Contested Amounts include: daily NAV used, daily position balance used for each account, the dollar value for each day and the average daily balance for the period for each account, including sub-omnibus accounts.

8. Control Your Data Straight-through processing Interfaces between source accounting systems ensure faster updating of data needed for calculations and thus quicker calculation of revenue and posting to general ledger, reducing errors due to manual data entry.

9. Control Your Security Security Manager controls user access to the application menus Prevent access to the database via a third party SQL tool using password encryption, expiration & minimum length Define level of access using user-defined security groups Define who may setup contracts, do maintenance, perform calculations, reverse calculations or have view-only access Segregate duties for internal control using user-defined security groups

10. Key Components

11. Transactions Transactions posted to Revenue Manager as accounts receivable or accounts payable Payments are then applied against accounts receivable or accounts payable Variances between calculated amounts and amounts received are flagged for management review and further analysis Transactions validated against actual contract terms Differences between billing and collection may be adjusted, written off, or remain as a receivable Amounts adjusted/written off are classified with user-defined adjustment reason codes for periodic reporting

12. Revenue Recognition Accurate and timely Manages revenue sharing agreements that are based on periodic payments. Monthly accrual of income on quarterly based agreements Allows proper revenue recognition per GAAP Revenue may be calculated immediately at month end for timely reporting

13. Automatic Journal Entry Creation User-defined chart of accounts can use the same account numbering as the corporate ledger system User-defined automatic journal entries are created for billings, cash receipts and adjustment transactions System created journal entries may post to the system ledger and create an export file for posting to the corporate ledger Reversals of previously posted transactions will automatically create a reversing entry

14. Account Receivable Management Revenue Manager’s accounts receivable system ages all billing amounts as well as tracks future due accrual amounts Historical data is stored for researching prior adjustment history for underpayments, etc. The system provides better monitoring of receivable amounts and faster collection of amounts due

15. Contract Management Revenue sharing legal agreements and all relative terms are all stored in the database User-defined tolerances may be set as a percentage and/or dollar cap allowable variance Rates, rules & effective dates drive the calculations which create transactions Calculation rules: basis points per account/per participant dollar amount ranges/tiers applicable accounts applicable CUSIPs applicable share classes effective dates

16. Revenue Manager andSarbanes-Oxley Compliance