Consolidated Reports of Condition and Income

DRAFT

Draft Instructions

for New and Revised Call Report Items
for December 31, 2009
(Schedule RC-T - Fiduciary and Related Services)

RC-T - FIDUCIARY AND RELATED SERVICES

FFIEC 031 and 041

DRAFT
SCHEDULE RC-T - FIDUCIARY AND RELATED SERVICES
General Instructions
This schedule should be completed on a fully consolidated basis, i.e., including any trust company
subsidiary (or subsidiaries) of the reporting institution. For report dates through December 31,2008, the
information reported in Schedule RC-T on fiduciary and related services income (except total gross
fiduciary and related services income) and on fiduciary settlements, surcharges, and other losses will not
be made available to the public on an individual institution basis. Beginning with the March 31,2009,
report date, all of the information reported in Schedule RC-T for each bank will be publicly available.

Item No. Caption and Instructions
1 Does the institution have fiduciary powers? Federally-chartered institutions granted trust
powers by the acc to administer accounts in a fiduciary capacity should answer "Yes."
State-chartered institutions should answer "Yes" if (a) the state has granted trust powers to
the institution to offer fiduciary services as defined by the state and (b) the institution's federal
supervisory agency (the FDIC or the Federal Reserve) has granted consent to exercise the
trust powers (see Sections 333.2 and 333.101 of the FDIC's regulations and Federal Reserve
Regulation H). Institutions with trust company subsidiaries should also answer "Yes."
Institutions responding "No" should not complete the remainder of this schedule. Fiduciary
capacity generally means trustee, executor, administrator, registrar of stocks and bonds,
transfer agent, guardian, assignee, receiver, custodian under a uniform gifts to minors act,
investment adviser (if the institution receives a fee for its investment advice), any capacity in
which the institution possesses investment discretion on behalf of another, or any other

similar capacity.

2 Does the institution exercise the fiduciary powers it has been granted? Institutions
exercising their fiduciary powers should respond "Yes." Exercising fiduciary powers means
that an institution, or a trust company subsidiary of the institution, serves in a fiduciary
capacity as defined in the instructions for item 1 of this schedule.

3 Does the institution have fiduciary or related activity (in the form of assets or
accounts)? Institutions (including their trust company subsidiaries) with fiduciary assets,
accounts, income, or other reportable fiduciary related services should respond "Yes."
Institutions responding "No" should not complete the remainder of this schedule.
Reportable fiduciary and related services include activities that do not require trust powers but
are incidental to fiduciary services. Specifically, this includes custodial services for assets
held by the institution in a fiduciary capacity. An institution should report custodial activities
that are offered through the fiduciary business unit or through another distinct business unit
that is devoted to institutional custodial services. Institutions should exclude those custodial
and escrow activities related to commercial bank services such as retail and institutional
brokerage assets, escrow assets held for the benefit of third parties, safety deposit box
assets, and any other similar commercial arrangement.
Institutions with fiduciary activities that are limited to only land trusts and/or custodial activity
for mortgage-backed securities (such as GNMA or FNMA) should respond "No."

If the answer to item 3 is "Yes," complete the applicable items of Schedule RC-T, as follows:

Institutions with total fiduciary assets (item 10, sum of columns A and B) greater than
$250 million (as of the preceding December 31) or with gross fiduciary and related services
interest income) for
income greater than 10 percent of revenue (net interest income plus non
the preceding calendar year must complete:

FFIEC 031 and 041

RC-T-1

(12-09)

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FFIEC 031 and 041

DRAFT
Item No. Caption and Instructions
3

· Items 4 through 22 on the FFIEC 041 quarterly; items 4 through 22.a on the FFIEC 031

quarterly;

(cont.)

. Items 23 through 26 annually with the December report; and

. Memorandum items 1 through 4 annually with the December report.
Institutions with total fiduciary assets (item 10, sum of columns A and B) greater than
$100 million but less than $250 million (as of the preceding December 31) that do not meet

the fiduciary income test for quarterly reporting must complete:
. Items 4 through 26 annually with the December report; and

. Memorandum items 1 through 4 annually with the December report.
Institutions with total fiduciary assets (item 10, sum of columns A and B) of $100 million or
less (as of the preceding December 31) that do not meet the fiduciary income test for

quarterly reporting must complete:
. Items 4 through 13 annually with the December report; and

. Memorandum items 1 through 3 annually with the December report.

Fiduciary and Related Assets
Institutions should generally report fiduciary and related assets using their market value as of the report
date. While market value quotations are readily available for marketable securities, many financial and
physical assets held in fiduciary accounts are not widely traded or easily valued. If the methodology for
determining market values is not set or governed by applicable law (including the terms of the prevailing
fiduciary agreement), the institution may use any reasonable method to establish values for fiduciary and
related assets for purposes of reporting on this schedule. Reasonable methods include appraised values,
book values, or reliable estimates. Valuation methods should be consistent from reporting period to
reporting period. This "reasonable method" approach to reporting market values applies both to financial
assets that are not marketable and to physical assets. Common physical assets held in fiduciary
accounts include real estate, equipment, collectibles, and household goods.
Only those Individual Retirement Accounts, Keogh Plan accounts, Health Savings Accounts, and similar
accounts offered through a fiduciary business unit of the reporting institution should be reported in
Schedule RC-T. When such accounts are not offered through an institution's fiduciary business unit, they
should not be reported in Schedule RC-T. For example, an institution that has such accounts that consist
solely of deposits in the bank itself and are not administered by the institution's trust department or other
fiduciary business unit should not report these accounts in Schedule RC-T.

If two institutions are named co-fiduciary in the governing instrument, both institutions should report the
account. In addition, where one institution contracts with another for fiduciary or related services
(i.e., Bank A provides custody services to the trust accounts of Bank B, or Bank A provides investment
management services to the trust accounts of Bank B) both institutions should report the accounts in their

respective capacities.
Exclude unfunded insurance trusts, testamentary executor appointments, and any other arrangements
representing potential future fiduciary accounts.

Asset values reported on this schedule should generally exclude liabilities. For example, an employee
benefit account with associated loans against account assets should be reported gross of the outstanding
loan balances. As another example, an account with a real estate asset and corresponding mortgage
loan should be reported gross of the mortgage liability. However, there are two exceptions. First, for
purposes of this schedule, overdrafts should be netted against gross fiduciary assets. Second, the fair
value of derivative instruments, as defined in FASB Statement No. 133, should be included in (i.e., netted
against) gross assets even if the fair value is negative.
FFIEC 031 and 041

RC-T-2
(12-09)

RC-T - FIDUCIARY AND RELATED SERVICES

RC-T - FIDUCIARY AND RELATED SERVICES

FFIEC 031 and 041

DRAFT
Fiduciary and Related Assets (cont.

Securities borrowing/lending transactions should be reflected as sales or as secured borrowings according
to FASB Statement No. 140. A transferee ("borrower") of securities generally is required to provide
"collateral" to the transferor ("lender") of securities. When such transactions do not qualify as sales,
securities "lenders" and "borrowers" should account for the transactions as secured borrowings in

which cash (or securities that the holder is permitted by contract or custom to sell or repledge) received as
"collateral" by the securities "lender" is considered the amount borrowed and the securities "loaned" are
considered pledged against the amount borrowed. For purposes of this schedule, securities held in
fiduciary accounts that are "loaned" in securities lending transactions (that are accounted for as secured
borrowings) should be reported as an asset of the fiduciary account that "loaned" the securities, but the
"collateral" received should not also be reported as an asset of this fiduciary account.

In the Fiduciary and Related Assets section, the market value of Collective Investment Fund (CIF) units
should be reported along with individual participant accounts in the Column and Item that corresponds to
each participant. The aggregate amount of a CIF that is operated by an institution should NOT also be
reported as a separate, additional account in the Fiduciary and Related Assets section of this schedule.

Managed Assets - Column A
Report the total market value of assets held in managed fiduciary accounts. An account should be
categorized as managed if the institution has investment discretion over the assets of the account.
Investment discretion is defined as the sole or shared authority (whether or not that authority is exercised)
to determine what securities or other assets to purchase or sell on behalf of the fiduciary related account.
An institution that delegates its authority over investments and an institution that receives delegated
authority over investments are BOTH deemed to have investment discretion.
Therefore, whether an account where investment discretion has been delegated to a registered
investment adviser, whether affiliated or unaffiliated with the reporting institution, should be reported as a
managed account depends on whether the delegation of investment authority to the registered investment
adviser was made pursuant to the exercise of investment discretion by the reporting institution. If so, the
account is deemed to be a managed account by the reporting institution. Otherwise, the account would be
a non-managed account for purposes of Schedule RC- T.

An entire account should be reported as either managed or non-managed based on the predominant
responsibility of the reporting institution.

Non-Managed Assets - Column B
Report the total market value of assets held in non-managed fiduciary accounts. An account should be
categorized as non-managed if the institution does not have investment discretion. Those accounts for
which the institution provides a menu of investment options but the ultimate selection authority remains
with the account holder or an external manager should be categorized as non-managed. For example, an
institution that offers a choice of sweep vehicles is not necessarily exercising investment discretion. The
process of narrowing investment options from a range of alternatives does not create a managed fiduciary
account for the purposes of this schedule.

Number of Managed Accounts - Column C
Report the total number of managed fiduciary accounts.

Number of Non-Managed Accounts - Column D
Report the total number of non-managed fiduciary accounts.

FFIEC 031 and 041

RC-T-3
(12-09)

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RC-T - FIDUCIARY AND RELATED SERVICES

FFIEC 031 and 041

DRAFT
Item No. Caption and Instructions
4 Personal trust and agency accounts. Report the market value and number of accounts for

all testamentary trusts, revocable and irrevocable living trusts, other personal trusts, and
non-managed personal agency accounts. Include accounts in which the institution serves as
executor, administrator, guardian, or conservator. Exclude personal investment management
and investment advisory agency accounts, which should be reported in Schedule RC-T,
item 7. Also exclude Keogh Act plans, Individual Retirement Accounts (IRAs), Health Savings
Accounts, and other pension or profit-sharing plans for self-employed individuals, which
should be reported in Schedule RC-T, item 5. Personal accounts that are solely custody or
safekeeping should be reported in item 11 of this schedule.

S Employee benefit and retirement-related trust and agency accounts:
S.a Employee benefit - defined contribution. Report the market value and number of
accounts for all employee benefit defined contribution accounts in which the institution serves
as either trustee or agent. Include 401 (k) plans, 403(b) plans, profit-sharing plans, money
purchase plans, target benefit plans, stock bonus plans, employee stock ownership plans,

and thriftsavings plans. Also report the market value of assets and the number of accounts
for employee welfare benefit trusts and agencies. Employee welfare benefit plans include
plans, funds, or programs that provide medical, surgical, or hospital care benefits; benefits in
the event of sickness, accident, disability, death, or unemployment; vacation benefits;
apprenticeship or other training programs; day care centers; scholarship funds; or prepaid
legal services. Employee benefit accounts for which the institution serves as a directed
trustee should be reported as non-managed. The number of accounts reported should reflect
the total number of plans administered rather than the number of plan participants. Employee
benefit accounts that are solely custody and safekeeping accounts should be reported in
Schedule RC-T, item 11.

S.b Employee benefit - defined benefit. Report the market value and number of accounts for
all employee benefit defined benefit plans, including welfare benefit plans, in which the
institution serves as either trustee or agent. Employee benefit accounts for which the
institution serves as a directed trustee should be reported as non-managed. The number of
accounts reported should reflect the total number of plans administered rather than the

number of plan participants. Employee benefit accounts that are solely custody and
safekeeping accounts should be reported in Schedule RC-T, item 11.
S.c Other employee benefit and retirement-related accounts. Report the market value and

number of accounts for all other employee benefit and retirement-related fiduciary accounts in
which the institution serves as trustee or agent. Include Keogh Act plans, Individual
Retirement Accounts, Health Savings Accounts, Medical Savings Accounts, and other

pension or profit-sharing plans for self-employed individuals. Exclude accounts, originated by
fiduciary or non-fiduciary personnel, that are solely administered to hold own-bank deposits.
Also exclude those retirement accounts that are originated and managed through a brokerage
account. Other retirement accounts that are solely custody and safekeeping accounts should
be reported in Schedule RC-T, item 11.
6 Corporate trust and agency accounts. Report the market value of assets held by the

institution for all corporate trust and agency accounts. Report assets that are the
responsibility of the institution to manage or administer in accordance with the corporate trust
agreement. Include assets relating to unpresented bonds or coupons relating to issues that
have been called or matured. Do NOT report the entire market value of the associated
securities or the outstanding principal of associated debt issues. Include accounts for which
the institution is trustee for corporate securities, tax-exempt and other municipal securities,
and other debt securities including unit investment trusts. Also include accounts for which the
institution is dividend or interest paying agent, and any other type of corporate trustee or agent
appointment. Accounts that are solely custodial or safekeeping should be reported in
Schedule RC- T, item 11.
FFIEC 031 and 041

RC-T -4

(12-09)

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RC-T - FIDUCIARY AND RELATED SERVICES

FFIEC 031 and 041

DRAFT
Item No. Caption and Instructions
7 Investment management and investment advisory agency accounts. Report the market

value and number of accounts for all individual and institutional investment management and
investment advisory agency accounts that are administered within the fiduciary area of the
institution. Investment management accounts are those agency accounts for which the
institution has investment discretion; however, title to the assets remains with the client.
Include accounts for which the institution serves as a sub-advisor. Investment advisory
accounts are those agency accounts for which the institution provides investment advice for a
fee, but for which some other person is responsible for investment decisions. Investment
management agency accounts should be reported as managed. Investment advisory agency
accounts should be reported as non-managed. Exclude investment management and
investment advisory agency accounts that are administered in bank subsidiaries that are SEC
registered investment advisors. Include those mutual funds that are advised by the fiduciary
area that is a separately identifiable department or division (as defined in section 217 of the
Gramm-Leach-Bliley Act). Classes of the same mutual fund should be combined and
reported as a single account.
8 Foundation and endowment trust and agency accounts. Report the market value and

number of accounts for all institutional foundations and endowments for which the institution
serves as either trustee or agent. Exclude personal charitable trusts, foundations, and
endowments, which should be reported in Schedule RC-T, item 4. Accounts that are solely
custodial or safekeeping should be reported in Schedule RC-T, item 11.
9 Other fiduciary accounts. Report the market value and number of accounts for all other

trusts and agencies not reported in Schedule RC-T, items 4 through 8. Custody and
safekeeping accounts should be reported in Schedule RC-T, item 11.

10 Total fiduciary accounts. Report the sum of items 4 through 9.

11 Custody and safekeeping accounts. Report the market value and number of accounts for
all personal and institutional custody and safekeeping accounts held by the institution.
Safekeeping and custody accounts are a type of agency account in which the reporting
institution performs one or more specified agency functions but the institution is not a trustee
and also is not responsible for managing the asset selection for account assets. These
agency services may include holding assets, processing income and redemptions, and other
keeping and customer reporting services. For employee benefit custody or
record
safekeeping accounts, the number of accounts reported should reflect the total number of
plans administered rather than the number of plan participants. Include accounts in which the
institution serves in a sub-custodian capacity. For example, where one institution contracts
with another for custody services, both institutions should report the accounts in their
respective capacity.

Accounts in which the institution serves as trustee or in an agency capacity in addition to
being custodian should be reported in the category of the primary relationship. For example,
personal trust accounts in which the institution also serves as custodian should be reported as
personal trust accounts and not as custodian accounts. An institution should report an

account only once in Schedule RC-T, items 4 through 9 and 11.
Report custodian accounts that are incidental to fiduciary services. Include those custody and
safekeeping accounts that are administered by the trust department, and those that are
administered in other areas of the institution through an identifiable business unit that focuses
on offering fiduciary related custodial services to institutional clients. Exclude those custodial
and escrow activities related to commercial bank services such as retail and institutional
brokerage assets, securities safekeeping services for correspondent banks, escrow assets
held for the benefit of third parties, safety deposit box assets, and any other similar
commercial arrangement.

FFIEC 031 and 041

RC-T-5
(12-09)

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RC-T - FIDUCIARY AND RELATED SERVICES

FFIEC 031 and 041

DRAFT
Item No. Caption and Instructions
NOTE: Item 12 is applicable only to banks filing the FFIEC 031 report form.

12 Fiduciary accounts held in foreign offices. Report the market value and number of
accounts included in Schedule RC- T, items 10 and 11, above that are attributable to accounts
held in foreign offces.

13 Individual Retirement Accounts. Health Savings Accounts. and other similar accounts.
Report the market value and number of Individual Retirement Accounts, Health Savings
Accounts, and other similar accounts included in Schedule RC-T, items 5.c and 11. Other
similar accounts include Roth IRAs, Coverdell Education Savings Accounts, and Archer
Medical Savings Accounts.

Fiduciary and Related Services Income
The following income categories correspond to the fiduciary asset categories described in Schedule RC-T,
items 4 through 11, above. For a detailed definition of the categories, please refer to the corresponding
account descriptions. Income and expenses should be reported on an accrual basis. Institutions may
report income and expense accounts on a cash basis if the results would not materially differ from those
obtained using an accrual basis. For report dates through December 31,2008, the information reported in
Schedule RC-T on fiduciary and related services income (except total gross fiduciary and related services
income) will not be made available to the public on an individual institution basis. Beginning with the
March 31,2009, report date, all of the information reported in Schedule RC-T for each bank will be
publicly

available.

Item No. Caption and Instructions

14 Personal trust and agency accounts. Report gross income generated from personal trust
and agency accounts as defined for item 4 of this schedule.

15 Employee benefit and retirement-related trust and agency accounts:
15.a Employee benefit - defined contribution. Report gross income generated from defined
contribution employee benefit trust and agency accounts as defined for item 5.a of this

schedule.
15.b Employee benefit - defined benefit. Report gross income generated from defined benefit
employee benefit trust and agency accounts as defined for item 5.b of this schedule.
15.c Other employee benefit and retirement-related accounts. Report gross income generated

from other employee benefit and retirement-related accounts as defined for item 5.c of this

schedule.

16 Corporate trust and agency accounts. Report gross income generated from corporate
trust and agency relationships as defined for item 6 of this schedule.
17 Investment management and investment advisory agency accounts. Report gross

income generated from investment management and investment advisory agency accounts
as defined for item 7 of this schedule.
18 Foundation and endowment trust and agency accounts. Report gross income generated

from foundation and endowment trust and agency accounts as defined for item 8 of this

schedule.

FFIEC 031 and 041

RC-T -6

(12-09)

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FFIEC 031 and 041

DRAFT
Item No. Caption and Instructions
19 Other fiduciarv accounts. Report gross income generated from other trust and agency
accounts as defined for item 9 of this schedule.
20 Custody and safekeeping accounts. Report gross income generated from custody and

safekeeping agency accounts as defined for item 11 of this schedule.

21 Other fiduciary and related services income. Report all other gross fiduciary related
income that cannot properly be reported in Schedule RC-T, items 14 through item 20, above.
Include income received from others (including affiliates) for fiduciary and related services

provided by the institution. Also include income received from investment advisory activities
when the assets are not held by the institution. Income received from investment advisory
services in which the account assets are held in a custody or safekeeping account at the
reporting institution should be reported in item 17 of this schedule. Also include net income
generated from securities lending activities (i.e., after broker rebates and income paid to
lending accounts). Include income from custodial activities for land trusts and mortgagebacked securities. Exclude allocations of income to the trust department from other areas of
the institution such as credits for fiduciary cash held as a deposit in the commercial bank.

22 Total gross fiduciary and related services income. Report the sum of items 14
through 21. This item must equal Schedule RI, item 5.a, "Income from fiduciary activities."
NOTE: Item 22.a is applicable only to banks filing the FFIEC 031 report form.

22.a Fiduciary and related services income - foreign offices. Report the total amount of
fiduciary and related services income included in Schedule RC-T, item 22, above that is
attributable to fiduciary accounts held in foreign offices.

23 Less: Expenses. Report total direct and indirect expenses attributable to the fiduciary and
related services reported in this schedule. Include salaries, wages, bonuses, incentive pay,
and employee benefits for employees assigned to reportable activities. If only a portion of
their time is allocated to reportable activities, report that proportional share of their salaries
and employee benefits. Include direct expenses related to the use of premises, furniture,
fixtures, and equipment, as well as depreciation/amortization, ordinary repairs and
maintenance, service or maintenance contracts, utilities, lease or rental payments, insurance
coverage, and real estate and other property taxes if they are directly chargeable to the
reportable activities. Income taxes attributable to reportable activity earnings should not be
included. Also exclude settlements, surcharges, and other losses, which are to be reported in
Schedule RC-T, item 24.
Include indirect expenses charged to the department or function offering reportable activities
by other departments or functions of the institution as reflected in the institution's internal
management accounting system. Include proportional shares of corporate expenses that
cannot be directly charged to particular departments or functions. Examples of indirect
expenses include such items as audit and examination fees, marketing, charitable
contributions, customer parking, holding company overhead, proportional share of building
rent or depreciation, utilities, real estate taxes, insurance, human resources, corporate
planning, and corporate financial staff. Reporting methods for indirect expenses should
remain consistent from period to period.

FFIEC 031 and 041

RC-T-7
(12-09)

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RC-T - FIDUCIARY AND RELATED SERVICES

FFIEC 031 and 041

DRAFT
Item No. Caption and Instructions
24 Less: Net losses from fiduciarv and related services. Report net losses resulting from
fiduciary and related services. Net losses are gross losses less recoveries. Gross losses
include settlements, surcharges, and other losses that are realized in the reporting period
attributable to the fiduciary and related services. Recoveries should include those that are
attributable to prior and current period losses. This item must equal Schedule RC-T,
Memorandum item 4.e, sum of columns A and B minus column C. For further information,
see the instruction to Schedule RC-T, Memorandum item 4.

25 Plus: Intracompany income credits for fiduciary and related services. If applicable to
the reporting institution, report credits from other areas of the institution for activities
reportable in this schedule. Include intracompany income credit made available to the
fiduciary area for fiduciary account holdings of own-bank deposits. Also include credits for
other intracompany services and transactions.

26 Net fiduciary and related services income. Report the total from item 22 less the amounts
reported in item 23 and item 24 plus the amount reported in item 25.

FFIEC 031 and 041

RC-T-8
(12-09)

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RC-T - FIDUCIARY AND RELATED SERVICES

FFIEC 031 and 041

DRAFT
Memoranda

Item No. Caption and Instructions
1 Managed assets held in fiduciary accounts.

Column Instructions for Memorandum items 1.a through 1.p:
Column A, Personal Trust and Agency and Investment Management Agency Accounts:
Report the market value of managed assets held in (a) personal trust and agency accounts as
defined for item 4 of this schedule and (b) investment management agency accounts as
defined for item 7 of this schedule.

Column B, Employee Benefit and Retirement-Related Trust and Agency Accounts:
Report the market value of managed assets held in employee benefit and retirement-related
trust and agency accounts as defined for items 5.a, 5.b, and 5.c of this schedule.

Column C, All Other Accounts: Report the market value of managed assets held in
(a) corporate trust and agency accounts as defined for item 6 of this schedule, (b) foundation
and endowment trust and agency accounts as defined for item 8 of this schedule, and
(c) other fiduciary accounts as defined for item 9 of this schedule.
Report in the appropriate column and in the appropriate subitem the market value of all
managed assets held in the fiduciary accounts included in Schedule RC-T, items 4 through 9,
column A. For units in common trust funds and collective investment funds that are held by

a

managed fiduciary account, report the market value of the units in Schedule RC-T,

Memorandum item 1.h. Do not allocate the underlying assets of each common trust fund and
collective investment fund attributable to managed accounts to the individual subitems for the
various types of assets reported in Schedule RC-T, Memorandum item 1.
Securities held in fiduciary accounts that are "loaned" in securities lending transactions (that
are accounted for as secured borrowings) should be reported as an asset of the fiduciary
account that "loaned" the securities, but the "collateral" received should not also be reported
as an asset of this fiduciary account.

interest-bearing deposits. Report
interest-bearing deposits of both principal and income cash.

1.a Noninterest-bearing deposits. Report all non
non

1.b Interest-bearing deposits. Report all interest-bearing savings and time deposits. Include

NOW accounts, MMDA accounts, "BICs" (bank investment contracts) that are insured by the
FDIC, and certificates of deposit. Report interest-bearing deposits of both principal and

income cash.

1.c U.S. Treasurv and U.S. Government agency obligations. Report all securities of and/or
loans to the U.S. Government and U.S. Government corporations and agencies. Include
certificates or other obligations, however named, that represent pass-through participations in
pools of real estate loans when the participation instruments: (1) are issued by FHA-approved
mortgagees and guaranteed by the Government National Mortgage Association, or (2) are
issued, insured, or guaranteed by

a U.S. Government agency or corporation (e.g., the Federal

Home Loan Mortgage Corporation's Mortgage Participation Certificates). Collateralized
mortgage obligations (CMOs) and real estate mortgage investment conduits (REMICs) issued
by the Federal National Mortgage Association (FNMA) ("Fannie Mae") and the Federal Home
Loan Mortgage Corporation (FHLMC) ("Freddie Mac") should be included.

FFIEC 031 and 041

RC-T-9
(12-09)

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RC-T - FIDUCIARY AND RELATED SERVICES

FFIEC 031 and 041

DRAFT
Memoranda

Item No. Caption and Instructions
1.d State. county. and municipal obligations. Report all short and long-term obligations of

state and local governments, and political subdivisions of the United States. Include
obligations of U.S. territories and insular possessions and their political subdivisions and all
Federal income tax-exempt obligations of authorities such as local housing and industrial
development authorities that derive their tax-exempt status from relationships with State or
local governments. Tax-exempt money market mutual funds should be reported with money

market mutual funds in Schedule RC-T, Memorandum item 1.e.

1.e Money market mutual funds. Report all holdings of mutual funds registered under the
Investment Company Act of 1940 that attempt to maintain net asset values at $1.00 per
share. Include taxable and tax-exempt money market mutual funds. Exclude short-term
collective investment funds.
1.f Equity mutual funds. Report all holdings of mutual funds registered under the Investment

Company Act of 1940 that invest primarily in equity securities.

1.9 Other mutual funds. Report all holdings of all other mutual funds registered under the
Investment Company Act of 1940.

1.h Common trust funds and collective investment funds. Report all holdings of all common
trust funds and collective investment funds. Common trust funds and collective investment
funds are funds that banks are permitted to operate by Section 9.18(a) of the Office of the

Comptroller of the Currency's regulations.

1.i Other short-term obligations. Report all other short-term obligations (i.e., original maturities
of less than 1 year, or 13 months in the case of the time portion of master notes). In addition
to short-term notes, include in this item such money market instruments as master note
arrangements, commercial paper, bankers acceptances, securities repurchase agreements,
and other short-term liquidity investments. Exclude state, county, and municipal obligations.

1.j Other notes and bonds. Report all other bonds, notes (except personal notes), and
debentures. Include corporate debt, insurance annuity contracts, "GICs" (guaranteed
investment contracts), "BICs" (bank investment contracts) that are not insured by the FDIC,
and obligations of foreign governments. Also include certificates or other obligations,
however named, representing pass-through participations in pools of real estate loans when
the participation instruments are issued by financial institutions and guaranteed in whole or in
part by private guarantors. Collateralized mortgage obligations (CMOs) and real estate
mortgage investment conduits (REMICs) that are not issued by the Federal National
Mortgage Association (FNMA) ("Fannie Mae") and the Federal Home Loan Mortgage
Corporation (FHLMC) ("Freddie Mac") should be reported here, even if the collateral consists
of GNMA ("Ginnie Mae") or FNMA pass-throughs or FHLMC participation certificates.
Exclude short-term obligations (which should be reported in Schedule RC-T, Memorandum

item 1.i, above).
1.k Investments in unregistered funds and private equity investments. Report all holdings of

funds exempt from registration under Securities Act of 1933 Regulation D and private equity
investments, including investments made via private equity-related funds. Private equity
investments is an asset class consisting of purchased equity securities in operating
companies that are not publicly traded on a stock exchange or otherwise registered with the
SEC under federal securities laws. Private equity-related funds are funds that invest primarily
in private equity investments.

FFIEC 031 and 041

RC-T-10
(12-09)

RC-T - FIDUCIARY AND RELATED SERVICES

RC-T - FIDUCIARY AND RELATED SERVICES

FFIEC 031 and 041

DRAFT
Memoranda
Item No.

Caption and Instructions

1.k
(cont.)

Investments in closely-held family businesses should not be reported in this Memorandum
item as "private equity investments" if such investments represent in-kind transfers to a
fiduciary account of securities in a closely-held family business or an increase in a fiduciary
account's percentage ownership of an existing closely-held family business whose securities
are held in the account. Such investments should be reported in Schedule RC-T,
Memorandum item 1.0, "Miscellaneous assets."

1.1

Other common and preferred stocks. Report all holdings of domestic and foreign
common and preferred equities, including warrants and options, but excluding investments
in unregistered funds and private equity investments (which should be reported in
Schedule RC-T, Memorandum item 1.k, above).

1.m

Real estate mortgages. Report real estate mortgages, real estate contracts, land trust
certificates, and ground rents. These assets may be reported at their unpaid balance if that

figure is a fair approximation of market value.
1.n

Real estate. Report real estate, mineral interests, royalty interests, leaseholds, and other
similar assets. Land and buildings associated with farm management accounts should be

reported in this item. Also include investments in limited partnerships that are solely or
primarily invested in real estate.

1.0

Miscellaneous assets. Report personal notes, tangible personal property, and other
miscellaneous assets that cannot properly be reported in Schedule RC-T, Memorandum
items 1.a through 1.n, above. Crops, equipment, and livestock associated with farm
management accounts should be reported in this Memorandum item. Also include
Investments in closely-held family businesses if such investments represent in-kind transfers
to a fiduciary account of securities in a closely-held family business or an increase in a
fiduciary account's percentage ownership of an existing closely-held family business whose
securities are held in the account.

1.p

Total managed assets held in fiduciary accounts. Report the sum of Memorandum
items 1.a. through 1.0. The total reported in column A must equal the sum of Schedule RC-T,
items 4 and 7, column A. The total reported in column B must equal the sum of
Schedule RC-T, items 5.a, 5.b, and 5.c, column A. The total reported in column C must
equal the sum of Schedule RC-T, items 6,8, and 9, column A.

1.q

Investments of managed fiduciary accounts in advised or sponsored mutual funds.
Report in column A the market value of all managed assets invested in mutual funds that are
sponsored by the institution or a subsidiary or affiliate of the institution or where the institution
or a subsidiary or affiliate of the institution serves an investment manager to the fund. Report
the number of managed accounts with assets invested in advised or sponsored mutual funds

in column B. The term "affiliate" means any company that controls, is controlled by, or is
under common control with another company, as set forth in the Bank Holding Company Act

of 1956.

FFIEC 031 and 041

RC-T-11
(12-09)

RC-T - FIDUCIARY AND RELATED SERVICES

RC-T - FIDUCIARY AND RELATED SERVICES

FFIEC 031 and 041

DRAFT
Memoranda

Item No. Caption and Instructions
2 Corporate trust and agency accounts:
2.a Corporate and municipal trusteeships. Report in column A the total number of corporate

and municipal issues, including equities such as trust preferred securities, for which the
institution serves as trustee. Also report other debt issues, such as unit investment trusts and
private placement leases, for which the institution serves as trustee. If more than one
institution is trustee for an issue, each institution should report the issue. Securities with
different CUSIP numbers should be considered separate issues; however, serial bond issues
should be considered as a single issue. When an institution serves as trustee of a bond
issue, it may also perform agency functions for the issue such as registrar (transfer agent) or
interest and principal paying agent. In those cases, report the issue only in Memorandum
item 2.a, "Corporate and municipal trusteeships," as the trustee appointment is considered

the primary function. Consider the primary function of the appointment when selecting the
item in which to report the appointment. Exclude issues that have been called in their entirety
presented bonds or coupons for which funds are being
held.

or have matured even if there are un

Report in column B the unpaid principal balance of the outstanding securities for the issues
reported in column A for which the institution serves as trustee. For trust preferred securities,
report the redemption price. Exclude assets (i.e., cash, deposits, and investments) that are
being held for corporate trust purposes; they shoLlld be reported in Schedule RC-T, item 6,

above.

2.a.(1)

Issues reported in Memorandum item 2.a that are in default. Report the total number and
unpaid principal balance (redemption price for trust preferred securities) of the issues
reported in Schedule RC-T, Memorandum item 2.a, above, that are in substantive default. A
substantive default occurs when the issuer (a) fails to make a required payment of principal or
interest, defaults on a required payment into a sinking fund, files for bankruptcy, or is declared
bankrupt or insolvent, and (b) default has been declared by the trustee. Issues should not be
reported as being in substantive default during a cure period, provided the indenture for the
issue provides for a cure period. Private placement leases where the trustee is required to
delay or waive the declaration of an event of default, unless requested in writing to make such
declaration, should not be reported as being in substantive default, provided such written
request has not been made. Once a trustee's duties with respect to an issue in substantive
default have been completed, the issue should no longer be reported as being in default.
Do not report issues that are in technical default, for instance, if the obligor failed to provide
information or documentation to the trustee within specified time periods.

2.b Transfer agent, registrar, paying agent, and other corporate agency. Report in column A

the total number of issues for which the institution acts in a corporate agency capacity.
Include the total number of equity, debt, and mutual fund issues for which the institution acts
as transfer agent or registrar. Separate classes of a mutual fund should be consolidated and
reflected as a single issue. Include the total number of stock or bond issues for which the
institution disburses dividend or interest payments. Also include the total number of issues of
any other corporate appointments that are performed by the institution through its fiduciary
capacity. Issues for which the institution serves in a dual capacity should be reported once.
Corporate and municipal trusteeships reported in Schedule RC-T, Memorandum item 2.a,
above, in which the institution also serves as transfer agent, registrar, paying agent, or other
corporate agency capacity should not be included in Memorandum item 2.b. Include only
those agency appointments that do not relate to issues reported in Schedule RC-T,

Memorandum item 2.a, above.

FFIEC 031 and 041

RC-T-12
(12-09)

RC-T - FIDUCIARY AND RELATED SERVICES

RC-T - FIDUCIARY AND RELATED SERVICES

FFIEC 031 and 041

DRAFT
Memoranda

Item No. Caption and Instructions
3 Collective investment funds and common trust funds. Report in the appropriate subitem

the number of funds and the market value of the assets held in Collective Investment Funds
(CIFs) and Common Trust Funds operated by the reporting institution. If an institution
operates a CIF that is used by more than one institution, the entire CIF should be reported in
this section only by the institution that operates the CIF. Exclude mutual funds from this
section. Each CIF should be reported in the subitem that best fits the fund type.

3.a Domestic equity. Report funds investing primarily in U.S. equities. Include funds seeking
growth, income, growth and income; U.S. index funds; and funds concentrating on small, mid,
or large cap domestic stocks. Exclude funds specializing in a particular sector (e.g.,
technology, health care, financial, and real estate), which should be reported in
Schedule RC-T, Memorandum item 3.g, "Specialty/Other."
3.b International/Global equity. Report funds investing exclusively in equities of issuers located

outside the U.S. and those funds representing a combination of U.S. and foreign issuers.
Include funds that specialize in a particular country, region, or emerging market.

3.c Stock/Bond blend. Report funds investing in a combination of equity and bond investments.
Include funds with a fixed allocation along with those having the flexibility to shift assets

between stocks, bonds, and cash.
3.d Taxable bond. Report funds investing in taxable debt securities. Include funds that
specialize in U.S. Treasury and U.S. Government agency debt, investment grade corporate
bonds, high-yield debt securities, mortgage-related securities, and global, international, and
emerging market debt funds. Exclude funds that invest in municipal bonds, which should be
reported in Schedule RC-T, Memorandum item 3.e, and funds that qualify as short-term
investments, which should be reported in Schedule RC-T, Memorandum item 3.f.

3.e Municipal bond. Report funds investing in debt securities issued by states and political
subdivisions in the U.S. Such securities may be taxable or tax-exempt. Include funds that
invest in municipal debt issues from a single state. Exclude funds that qualify as short-term
investments, which should be reported in Schedule RC-T, Memorandum item 3.f.
3.f Short-term investments/Money market. Report funds that invest in short-term money

market instruments with an average portolio maturity that is limited to 90 days with individual
securities limited to maturities of 13 months or less. Money market instruments may include
U.S. Treasury bills, commercial paper, bankers acceptances, and repurchase agreements.
Include taxable and nontaxable funds.

3.g Specialty/Other. Include funds that specialize in equity securities of particular sectors (e.g.,
technology, health care, financial, and real estate). Also include funds that do not fit into any
of the above categories.
3.h Total collective investment funds. Report the sum of Memorandum items 3.a. through 3.g.

FFIEC 031 and 041

RC-T-13
(12-09)

RC-T - FIDUCIARY AND RELATED SERVICES

RC-T - FIDUCIARY AND RELATED SERVICES

FFIEC 031 and 041

DRAFT
Memoranda

Item No. Caption and Instructions
4 Fiduciary settlements. surcharges, and other losses. Report aggregate gross

settlements, surcharges, and other losses arising from errors, misfeasance, or malfeasance
on managed accounts in column A and on non-managed accounts in column B. For the
definitions of managed and non-managed accounts, refer to the instructions for the Fiduciary
and Related Assets section of this schedule. Gross losses should reflect losses recognized
on an accrual basis before recoveries or insurance payments. Exclude contingent liabilities
for fiduciary-related loss contingencies, including pending or threatened litigation, for which a
loss has not yet been recognized in accordance with FASB Statement NO.5.

Report recoveries in column C. Recoveries may be for current or prior years' losses and
should be reported when payment is actually realized. The filing of an insurance claim does
not serve as support for a recovery.

For report dates through December 31,2008, the information reported on fiduciary
settlements, surcharges, and other losses will not be made available to the public on an
individual institution basis. Beginning with the March 31,2009, report date, all of the
information reported in Schedule RC- T for each bank will be publicly available.
4.a Personal trust and agency accounts. Report gross losses and recoveries for personal trust

and agency accounts as defined for item 4 of this schedule.

4.b Employee benefit and retirement-related trust and agency accounts. Report gross
losses and recoveries for employee benefit and retirement-related trust and agency accounts
as defined for item 5 of this schedule.
4.c Investment management and investment advisory agency accounts. Report gross

losses and recoveries for investment management and investment advisory agency accounts
as defined for item 7 of this schedule.
4.d Other fiduciary accounts and related services. Report gross losses and recoveries for all

other fiduciary accounts and related services that are not included in Schedule RC-T,
Memorandum items 4.a, 4.b, and 4.c, above. Include losses and recoveries from corporate
trust and agency accounts, foundation and endowment trust and agency accounts, other
fiduciary accounts, custody and safekeeping accounts, and other fiduciary related services.
4.e Total fiduciary settlements. surcharges, and other losses. Report the sum of

Memorandum items 4.a through 4.d. The sum of columns A and B minus column C must
equal Schedule RC- T, item 24, above.

FFIEC 031 and 041

RC-T-14
(12-09)

RC-T - FIDUCIARY AND RELATED SERVICES