“ Making Great Ideas Become Reality ”

1. “Making Great Ideas Become Reality” The Dodd-Frank Initiative Summary

2. Source of the Financial Crisis Major Causes: Other Causes: • High Risk Lending • Regulatory Failure • Inflated Credit Ratings • Investment Bank Abuses • Monetary Policy • Leverage of Financial Firms • Aggressive Mortgage Origination System • Transparency of Securitizations • Derivatives Assurance • Investments in Toxic Assets In response to the above, the Dodd-Frank Wall Street Reform Consumer Protection Act was signed into law in July, 2010 by President Obama.

3. Dodd-Frank: What it Means to Financial Firms • Volatility in the world financial markets has led to a growing scrutiny of the financial services • industry, raising costs for institutions that fail to adhere to mounting regulatory requirements. • firms must implement a rigorous robust solution that limits exposure to potential fines yet • does not harm their competitive position or economic value. • Failure, is expensive. Recently, financial service firms paid over $250 million • annually in fines for failing to comply with published policies. • Regulators around the world are looking to monitor systemic risk through rules such as • Dodd-Frank Act in the U.S. • For financial firms these financial regulations will have a major impact on nearly every area • including compliance, operations, data management, risk management and IT. • Financial firms will need to monitor counter party risk, manage regulatory risk, and handle • real-time reporting to senior management and the regulators. • Difficult to implement due to lack of regulatory clarity because regulations are still being debated • and formulated. • Clearing Documentation moving forward towards standard cross-product documentation. • International inconsistencies due to lack of a uniform standardized approach. • In order to be Dodd-Frank compliant, operations will need to: • Build/implement new clearing technology for buy and sell side • Provide capability for additional new reporting and reconciliation • Be Scalable and have the capability to handle increased operations volume

4. CMA Client Services Due to the 2008 financial crisis, consumer credit crisis, several high profile compliance breakdowns and increased emphasis on consumer protection, the federal and state regulatory agencies, investors, legislators and the general public are today more focused on financial institutions’ customer practices and regulatory compliance performance like never before. Financial institutions are now facing new and challenging regulatory requirements. Thus, a huge focus for IT executives in 2012 will include Dodd-Frank compliance in many technology areas. CMA believes that in order to maximize value from IT spending on regulatory/compliance, financial firms must align their otherwise compartmentalized technology systems. Financial firms must ensure an appropriate level of automation that mitigates operational and legal risk throughout their process workflows. And they must do so while meeting all Dodd-Frank regulatory requirements. CMA’s financial regulatory / compliance team is well qualified to assist financial institutions in addressing these complex challenges and staying abreast of changing Dodd-Frank regulatory requirements and expectations and industry practices. Our highly qualified and experienced professional provide a full range of regulatory compliance risk management services. We do not advocate a “one-size fits all” solution; instead we offer regulatory compliance advice and solutions that are tailored to each client’s individual business needs. We provide a proven approach with the emphasis on developing innovative, low-cost approaches to managing and overseeing compliance risk. We work closely with our global network to provide regulatory advisory services across all geographic locations. Our commitment to client service means that CMA brings the right skills and resources to meet your specific needs.

5. How CMA can Help 5 • Our staff specialists cover all aspects of the forthcoming reforms, evolution of the OTC derivatives market and the impact of using a central counter party (CCP). • Determine whether existing architecture could be enhanced to accommodate the mandated changes: (the Futures or ETD platform, the Cash Securities platform or the Prime Services Platform). • Work with our clients in developing and testing alternative strategic options for OTC clearing. This approach allows us to determine the most cost effective ways of achieving compliance, while ensuring the capability to take advantage of future opportunities presented by OTC clearing. • Implement key process/control technology changes across various areas and systems. • Conceptualize solutions that leverage organization's existing platforms, workflow, connectivity and cross-product capabilities providing maximum ROI. • Facilitate and support the building of platforms to comply with the Dodd-Frank regulatory rules for real-time processing. • Ensure solution delivery includes real-time rules engine, processing engines, dashboards and scheduled end-of-day reporting built on cross-asset trading and processing platforms. • Leverage experiences and lessons learned from BASEL, Sarbanes-Oxley (SOX) and other regulatory initiatives in better understanding how to interpret and apply regulatory changes presented by Dodd-Frank. • Develop and implement best practices for cross border trading desk, risk control and governance. • Advise clients on a variety of business process services that help identify, assess, manage and measure risk exposures and implementation to the new derivatives changes associated with global regulatory reforms. Areas addressed include: new OTC business model designs, trading business processes, derivatives execution (voice and SEF execution), real time reporting, clearing, collateral management and client reporting.

6. Dodd-Frank Project Delivered by CMA Resource 6 • Dodd-Frank implementation by a CMA resource for Tier 1 European Investment Bank (clearing): • Dodd-Frank Act– Title VII: Responsible for leading study & implementation effort on the technology • side for Dodd-Frank legislation impact on our OTC businesses. Initial scope of the initiative was focusing on seven main streams. The areas of initial focus  • Reference Data: Focus was on incorporating new industry data elements like UCI, LEI, UPI and • USI in to Ref data. Also includes enrichment to securities and client data. • Reporting & Record Keeping: Focus was on real time, continuation and transition reporting needs to • SDRs, implementation of record keeping requirements was also part of it. • Execution and e-Commerce: Integration with SEFs for electronic execution of swaps. • Clearing and Affirmation: Integration with DCOs for the clearing of eligible OTC instruments. Review of • changes in operational processes was also part of work scope. • Legal and Compliance: In study phase, assessing effort to re-document clients, new business conduct • rules, entity registration and rework of policies and procedures. • Collateral Management: Study phase in progress as rules are still being debated, closely monitoring • and commenting on new margin and capital requirements by CFTC and SEC. • Process Flows and Swap Dealer setup: Development of comprehensive views of e2e process and • system flows by product. • Current achievements include successful integration with ICE and LCH for the clearance and settlement of • Interest Rate and Credit Swaps. Integration with CME is in progress.