Internal Control Questionnaires and Verification Procedures

Private Placements

1. Review advisory fees associated with private placements and trace selected fees to appropriate income accounts.

2. Trace all participations purchased or sold in any loans which were used to fund private placements advised by the bank.

3. Review advised private placements since the previous examination. Scan appropriate investment or dealer accounts to determine if any bank funds were directly involved in purchasing securities that were subsequently placed with private investors.

4. Using an appropriate sampling technique, select funds managed by the bank, its trust department, subsidiary(s) or affiliate(s), and determine if those funds have purchased private placements advised by the bank since the last examination.

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