NEW YORK STATE BANKING DEPARTMENT www'banking'state'ny'us IIBCSBS FBO Executive Orientation July 25,

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NEW YORK STATE BANKING DEPARTMENTwww.banking.stat
e.ny.usIIB/CSBS FBO Executive Orientation July
25, 2006Michael J LesserDeputy
SuperintendentBank Supervisionmichael.lesser_at_ban
king.state.ny.us1-212-709-3502
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NYSBD - WHO WE ARE

• Established 1851 Oldest bank regulatory agency
  in U.S.
• Mission Statement
• Insure safe and sound conduct.
• Conserve assets.
• Prevent unsound and destructive competition.
• Maintain public confidence in the banking system
  in NYS.
• Protect public interest and interests of
  depositors, creditors and shareholders.

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NYSBD- WHO WE ARE (cont.)

• Superintendent of Banks
• Diana L. Taylor
• Appointed by Governor Pataki 6/2003
• Confirmed by State Senate
• Superintendent has broad authority
• Approves mergers and acquisitions, branch
  applications and non-bank licenses.
• Sets safety and soundness standards.
• Issues regulations and supervisory procedures.
• Conducts examinations and investigations.
• Issues enforcement actions
• Power to take possession and conduct liquidations
  or revoke licenses.
• Banking Board
• 17 Member board, headed by Superintendent.
• Selected from industry and public
• Oversees policies, approves charters and foreign
  banking licenses.
• Issues regulations.

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NYSBD- WHO WE ARE (cont.)

• Employs nearly 550 full-time employees
• Almost 73 of staff are bank examiners
• Offices
• Main office at One State Street, NY, NY
• Syracuse, New York
• Albany, New York
• London, England
• Website http//www.banking.state.ny.us

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NEW YORK STATE BANKING DEPARTMENT ORGANIZATION
CHART
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WHERE WE FIT IN

• Dual Banking System
• Bank Regulatory Structure
• FBO Regulatory Structure
• Thrift Regulatory Structure
• Non-bank regulation
• Money Services Businesses
• Other

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PRESENT BANK and TRUST COMPANY REGULATORY
STRUCTURE
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PRESENT FBO REGULATORY STRUCTURE
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PRESENT THRIFT REGULATORY STRUCTURE
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NYSBD Supervised Banking Institutions, Year-End
2004 and Year-End 2005
1 Brown Brothers Harriman is a private banking
partnership organized under the NYS Banking Law,
many other banks, trust companies and FBO
branches and agencies also engage in private
banker activities 2 Includes 5 entities that act
as holding companies to provide consolidated
supervision for the international banking
activies of US non-banking corporations
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NYSBD Supervised Non-bank Institutions, Year-End
2004 and Year-End 2005 (cont.)
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SUM OF TOTAL ASSETS OF U.S. BRANCHES AND AGENCIES
FINANCIALS AS OF 12-31-2005 AND STRUCTURE DATA
AS OF 03-23-2006 (IN MILLIONS)
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NUMBER OF BRANCHES AND AGENCIES
1 OCC branch number include all offices, NYS
number reflects only number of licensed FBOs,
total number of offices in NY is 119
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FBO BRANCHES AND AGENCIES

• Permissible Activities
• National Treatment Virtually all activities
  permissible to domestically chartered banks,
  except the taking of retail deposits, are
  permitted in foreign branches. Foreign agencies
  have similar powers, but may not accept domestic
  deposits. With approval, FBO branches and
  agencies may have trust (fiduciary) powers.

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FBO REPRESENTATIVE OFFICES

• Permissible Activities
• Under the New York Banking Law Section 221-a and
  Supervisory Policy FB 2, permissible activities
  on behalf of a foreign banking corporation shall
  be limited to representational and liaison
  activities. Such office may NOT solicit retail
  business and may NOT effect transactions.