This is a Must Have Item for Financial Services

1. Audit-proof supervision of post archival content and electronic communications for IBM ECM repositories April 25, 2013

2. This is a Must Have Item for Financial Services • FINRA expects a firm to have supervisory policies and procedures to monitor all electronic communications technology used by the firm and its associated persons to conduct the firm’s business. • As required by previous SEC, NASD, and NYSE rules, firms must ensure that they have processes in place to keep records of these communications to prove in an audit that the required supervision was consistently being accomplished.

3. Industry Challenges Require companies to Establish and Maintain systems to Supervise Activities and Electronic Communications. Failure to do so can result in hefty fines. • Ex: ING Firms Fined for Review Failure. In February 2013, FINRA fined five ING affiliates $1.2 million for failing to capture millions of emails, and for failing to review nearly six million messages flagged by their review software. • Ex: Metlifefined $1.2 Million because brokers withheld emails and concealed evidence or "red flags" of misconduct without detection by the firm Internal Business Challenges: • Multiple archive systems and un-integrated tools • Unnecessary time and resources used reviewing false positives and duplicates • All changes in lists not being versioned or captured • Struggle completing regulatory audits • Manual process for escalation and review • Restricting supervision process to specific people • Foreign language review

4. iZon Target Market Financial Services Sector: • Capital Markets, Broker Dealers, Hedge Funds • Banking • Insurance Line of Business: • Compliance, Legal, Risk Management Decision Makers: • Chief Compliance and Risk Officers, General Council, CIO Decision Influencers: • President, CEO, CFO, Legal, Operations, • IT Business Analyst Firm Size: • Will support any firm that has a Compliance and Risk Management requirements

5. Solution Introduction iZon Complianceprovides a single integrated supervisory solution for post-archival content and electronic communications Built on the IBM ECM platform Easy to use graphical dashboards, with customizable desktop views that can be defined by user roles: • Supervisor • Manager • Legal Create Keyword Groups and Lists • Versioned and Secured • Leverages meaning based and lexicon search technologies • Provides fewer false positives • Group level rules for: Distribution, Restrictions, Exclusions, and Random Sampling • Records – Date and Time, Type and Person making Changes to any group or list

6. Unique Capabilities Detail audit trail of every action taken associated with every flagged item • “Flagged” content can participate in workflows based on reason codes • Eliminating a manual process for escalation and review Discussion threads linked to item through a tab through a tab in user interface Custom warnings and notifications that are easily generated and delivered to appropriate parties with a click of the mouse • Generates a PDF letter and auto adds process information with your specific legal language Preview items prior to opening in native application • Secure Microsoft language translation (optional) Bulk review capability • Ability to select multiple items in the review queue and mark as reviewed Supports ad-hoc searching through eDiscovery providing access to all archived content

7. IBM Software Pull Through iZon Compliance requires four IBM ECM products to operate: • IBM Content Collector • IBM eDiscovery Manager • IBM eDiscovery Analyzer • Repository choice of CM8 or P8 iZon Compliance with the IBM software stack and core implementation services has a starting point of $200K for managing up to 50 registered representative email boxes.

8. iZon Architecture • Built on Microsoft .NET Framework and MS SQL • Fully XML based design and implementation • Web 2.0 Features • Full HTML/HTTP/HTTPS Support • Web Services Support • Proven Multi-Tiered Architecture for DMZ/Scalable Deployments • AES/DES/SSL/MDAC5 secured system • AJAX based UI for interactive web interface

9. Clients Georgia Based Large Financial Services Company: • The company offers term life insurance coverage to some 4 million customers in the US and Canada. It also serves as a broker of debt consolidation loans, investment and savings products, and long term care insurance through other underwriters. • Approximately 40,000 Licensed Securities Representatives Requiring Supervision • Was using Autonomy – but in a head-to-head review of the same pool of messages over 15 days, iZon Compliance flagged about 85% fewer messages. However, the iZon Compliance system identified 25% more violations. International Bank with New York Operations: • U.S. and international private banking services as well as a full range of securities and insurance products through its brokerage subsidiary.   • Was an existing FileNet shop using manual processes for flagging and reviewing emails.  Which we automated - greatly improving the efficiency and accuracy of the review process.     

10. $$ Call to Action $$ Working together to develop local OI campaigns – contact Pete Current campaign in place to generate leads (tactic code: 101CB2CE) Demos to compliance officers = key to success and displacing what they “have” Low hanging fruit • Existing IBM ECM install base (likely don’t have ECM licenses in Compliance/Legal) • All Autonomy, (Zantaz, CA Message Manager, and Iron Mountain) Accounts • Symantec and EMC Accounts

11. Conversation Starters How are you accomplishing FINRA required electronic message supervision today? • Is this manual or are you using software? • If software, what vendor are you using and how licensed? • Own or term licensed? • If term – when does term expire? • If owned – when is the maintenance renewal date? Are you prepared today to pass a FINRA audit regarding electronic communications, monitoring and supervision? How many registered reps are you responsible for monitoring and supervising their electronic communications? How many employees do you have focused on monitoring your electronic communications as required by FINRA?

12. Contact Headquartered in New York, NY – will go where the deals are! Significant ECM BPM Experience - working and selling IBM ECM since 1996 AST can compete with the “big boys” www.izoncompliance.com AST Contacts Peter Ettinger Marjory Dury peterettinger@astworld.commdury@astworld.com (917) 284-3886 (212) 682-4160 IBM Contact Dianne O’connor-Miele Channel Sales Manager, Software Group, ECM dmoconno@us.ibm.com (914)806-2504 Thank you for your time today. Questions? 12