Trust Examiner School eBook

52. Describe process of review of accounts before acceptance and post acceptance. Also, describe the annual review process for discretionary accounts, specifically the tracking system in place to monitor the investment review and how the exception tracking process provides follow up and resolution of exceptions.

[Type Management Response Here]

53. Access to policies and procedures (or copy of) that have been adopted by the Board of Directors to ensure compliance with Section 3(a)(4) and Section 3(a)(5) of the Securities Exchange Act of 1934 as well as Regulation R in regards to your bank brokerage activities.

[Type Management Response Here]

54. State whether you are utilizing the bank-wide or account by account approach for purposes of the trust activities exception in Section 3(a) (4) of the Securities Exchange Act of 1934 and Regulation R. Provide documentation regarding the annual calculation of the chiefly compensated test. Documentation must show fees included in relationship compensation and accounts and fees excluded from calculation.

[Type Management Response Here]

55. A list of estates under administration longer than 36 months. Also, provide a list of estates under administration longer than 18 months for which you have no filed an accounting.

[Type Management Response Here]

56. A list of all accounts. Have available a list of holdings on specific accounts that the examiner will request upon arrival.

[Type Management Response Here]

Asset Management

57. A copy of your list of investments approved for discretionary purchase or retention, including mutual funds. Also provide a list of discretionary accounts in investments not on the approved list. For each account, provide an explanation regarding the investment and list the type of investment.

[Type Management Response Here]

58. Describe how investment decisions are made, supported and evaluated. Specifically, address the methodology used to determine the investment objective of discretionary accounts. If investment decisions are delegated, describe the process used to determine that investment service providers are properly scrutinized before use and reevaluated on an annual basis.