Accounting and Regulatory Guidance for the Federal Home ... · PDF fileFederal Home Loan Bank...

Accounting and Regulatory Guidance for the Federal Home Loan Banks’ MPF® Program

Federal Home Loan Bank of

Federal Home Loan Banks MPF Program

Federal Home Loan Bank of Des Moines

Charting Your Course Member ConferenceConference

Mortgage Partnership Finance Program®

MPF Accounting and Regulatory Guidance

“Mortgage Partnership Finance”, “MPF” and “MPF Xtra” are registered trademarks

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g g p , gof the Federal Home Loan Bank of Chicago.

Accounting and Regulatory Guidance for the Federal Home Loan Banks’ MPF® ProgramFederal Home Loan Banks MPF Program

Today’s TopicsToday s Topics

1) Product Descriptions

2) Valuation of Mortgage Servicing Rights, Credit Enhancement Fees Receivable and Credit Enhancement Recourse Liabilities

3) Journal entries for recording the loan sale including MSR CE Fees3) Journal entries for recording the loan sale, including MSR, CE Fees Receivable and CE Recourse Liability

4) Regulatory Reporting Requirements

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MPF Closed Loan Product Descriptions

1. Original MPF• FHLB provides the first loss account (FLA) which increases at 4 basis

points per year• PFI provides a Credit Enhancement (CE) Recourse Obligation to the

FHLB• PFI is paid a fixed Credit Enhancement Fee (CE Fee) for providing the

CE Recourse ObligationCE Recourse Obligation

2. MPF 125• FHLB provides the FLA which is equal to 100 basis points of the

delivered amountdelivered amount• PFI provides a minimum CE Recourse Obligation of 25 basis points

based on the delivered amount• PFI receives a performance based CE Fee for providing the CE

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Recourse Obligation


MPF Closed Loan Product Descriptions - ContinuedMPF Closed Loan Product Descriptions Continued

3. MPF Xtra ®

• Loans sold to the FHLBs are concurrently sold to a third party investor• No CE Recourse Obligation or CE Fees

4. MPF Government Loans• Includes FHA, VA, HUD 184 and RHS Section 502 loans• No CE Recourse Obligation or CE Fees

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How to Determine if an MSR Asset exists?How to Determine if an MSR Asset exists?

• Transfer of loan that meets “sales accounting” requirements

• Sales accounting is a very complex topic discussed in FAS ASC 860-10-40

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Criteria for a Sale*


1) The transferred financial assets have been isolated from the transferor –put presumptively beyond the read of the transferor and its creditors, even in bankruptcy or other receivership.

2) No condition both constrains the transferee (or third party holder of its beneficial interests) from taking advantage of its right to pledge or exchange and provides more than a trivial benefit to the transferor –“continuing involvement”

3) The transferor, its consolidated affiliates included in the financial statements being presented, or its agents do not maintain effective control over the transferred financial assets or third-party beneficial interests related to those transferred assets.

*ASC 860 10 40 5

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ASC 860-10-40-5


Continuing Involvement


Characteristics of the MPF Program could be construed as continuing involvement:

1. The servicing contract – safe harbor for servicing – ASC 860-10-40-6A

2. The credit enhancement fee is an ongoing and could be construed as an interest only strip y p

3. The CE Recourse Obligation is a form of recourse or guarantee arrangement

4. Agreements to purchase or redeem transferred financial assets –involves normal representations and warranties – again a safe harbor –ASC 860-10-40-6A

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Cannot Divide the Financial Asset Unless You Create a P ti i ti I t t


Participating Interest

Participating Interest must meet three criteria:

1. Proportionate ownership rights with equal priority to each participating interest holder

2 Involves no recourse (other than standard representations and2. Involves no recourse (other than standard representations and warranties) to, or subordination by, any participating interest holder

3. Does not entitle any participating interest holder to receive cash before any other participating interest holderany other participating interest holder

Wilary Winn does not believe the Credit Enhancement fee would meet the participating interest criteria.

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Unit of Account*


A PFI can receive an interest only strip in a transfer provided the transfer of the loan meets the sales accounting test – essentially that the PFI has sold its entire interest in the loan.

The PFI then enters into a separate transaction in which it receives the credit enhancement fee in consideration of assuming the CE Recourse Obligation. The PFI records and accounts for the credit enhancement fee greceivable as a separate entire financial asset.

GAAP does not also preclude entering into a separate recourse obligation such as the “CE Recourse Obligation Amount”. A PFI records a liability for g ythe recourse obligation. The case for recording a separate liability is reinforced in situations in which the transferor could be obliged to write a check in excess of the fees received as is the case under the MPF program (FAS 166 response to questions 67 and 68)

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program. (FAS 166 – response to questions 67 and 68)

*ASC 860-10-55-17F


Accounting for Servicing of Financial Assets


Accounting for Servicing of Financial Assets

• Must initially recognize MSRs at their fair value

• PFI can elect either the amortization method or the fair value method for future reporting of their MSRs

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Mortgage Servicing Right (MSR) Primary ValuationMortgage Servicing Right (MSR) Primary Valuation Components

1. The loan amount2. Servicing fee percentage 3. Ancillary income4. Expected loan life – prepayment 5. Discount rate6. Costs to service – market costs7. Delinquency rate and foreclosure losses8. Remittance methodology – single vs. multiple9. Escrow Payment (Tax & Insurance)

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MSR Yield Curve and Convexity

Federal Home Loan Banks MPF® Program

1.500%

30 Year Conforming Conventional Par Rate Servicing Fee Value

1.000%

1.250%

0.750%-200 bps -100 bps -50 bps Base +50 bps +100 bps +200 bps

Change in Interest Rates

Value

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MSR Asset Volatility

Federal Home Loan Banks MPF® Program

Value of MSR Asset

700

800

1.300%

1.450%

Value of MSR Asset

400

500

600

0.850%

1.000%

1.150%

100

200

300

0 400%

0.550%

0.700%

1000.400%

Mar

. 200

8

Jun.

200

8

Sep

t. 20

08

Dec

. 200

8

Mar

. 200

9

Jun.

200

9

Sep

t. 20

09

Dec

. 200

9

Mar

. 201

0

Jun.

201

0

Sep

t. 20

10

Dec

. 201

0

Mar

. 201

1

Jun.

201

1

Sep

t. 20

11

Dec

. 201

1

Mar

. 201

2

Jun.

201

2

Sep

t. 20

12

Dec

. 201

2

Mar

. 201

3

Jun.

201

3

MSR Value % Prepayment Speed

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Mortgage Servicing RightsAccounting and Regulatory Guidance for the Federal Home Loan Banks’ MPF® Program

MPF Product Credit Structure


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MPF Credit Enhancement FeeMPF Credit Enhancement Fee

1. Paid to member for assuming credit risk (CE Recourse Obligation) on mortgage defaultsg g

2. Determined by the quality of the loans at the pool level and the MPF program selected

3. Fee paid monthly over the life of the loans

4. Sensitive to prepayments

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The Primary Valuation Factors of the CE Fees Receivable are:

1 Th l t1. The loan amount

2. The CE Fee percentage and whether or not it is performance based – depends upon the program selectedp p p g

3. The expected life of the loan – sensitive to prepayments

4 The discount rate used to discount the cash flows4. The discount rate used to discount the cash flows

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Example: $100,000 loan


p $ ,

CE Fee Value30 Yr. 20 Yr. 15 Yr.

MPF Original CE Fee % 0.420% 0.387% 0.337%MPF Original CE Fee $ $419.72 $387.39 $336.50

MPF 125 CE Fee % 0.218% 0.202% 0.175%MPF 125 CE Fee $ $218.39 $201.61 $175.23

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The Primary Valuation Factors of the CE Recourse Liability are:

1. The loan amount2 The CE Recourse Obligation amount – depends on quality of2. The CE Recourse Obligation amount depends on quality of

loans delivered3. The expected life of the loan – sensitive to prepayments4. The expected default rate

Th d i f l f l l5. The expected severity of actual foreclosure losses6. The level of credit risk assumed – depends on program selected7. The discount rate used to discount the cash flows8. The amount in the First Loss Account (FLA) – depends on8. The amount in the First Loss Account (FLA) depends on

program selected

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CE Recourse Liability vs CE Recourse Obligation


CE Recourse Liability vs. CE Recourse Obligation Amount

ff C CThere is a difference between the CE Recourse Liability and the CE Recourse Obligation Amount

The CE Recourse Liability is related to properly accounting for theThe CE Recourse Liability is related to properly accounting for the loans delivered under the program per Generally Accepted

Accounting Principles

Th CE R Obli ti t i l t d t th t f i kThe CE Recourse Obligation amount is related to the amount of risk based capital that a PFI must hold for regulatory purposes for loans

delivered under the program

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Example: $100 000 loan


Example: $100,000 loan

CE Obligation Liability30 Yr. 20 Yr. 15 Yr.

MPF Original CE Obligation % -0.040% -0.037% -0.033%MPF Original CE Obligation $ -$39.91 -$37.15 -$32.81

MPF 125 CE Obligation % 0 000% 0 000% 0 000%MPF 125 CE Obligation % 0.000% 0.000% 0.000%MPF 125 CE Obligation $ $0.00 $0.00 $0.00

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Accounting for Loans Sold Under the MPF Program


The discussion which follows are based on general examples. PFIs are strongly encouraged to review the accounting for the program with their

external auditors and primary regulators before implementing the accounting described in the presentation, because the facts and circumstances for a

particular institution may lead to different accounting and regulatory interpretations.

We further note that for purposes of simplicity, we have omitted the accounting requirements related to the Interest Rate Lock Commitments

PFIs make to their borrowers and Forward Sales Commitments a PFI enters into with the FHLB which are both derivativesinto with the FHLB, which are both derivatives.

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Recording of the CE Recourse Liability

• Record the CE Recourse Liability and the CE Fee receivable at their fair values

• Record CE Recourse Liability equal to CE Fee receivable – FINRecord CE Recourse Liability equal to CE Fee receivable FIN 45

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Example: $100 000 loan sold with an MSR of 1%


Example: $100,000 loan sold with an MSR of 1%

Fair ValuesCash proceeds 100 000Cash proceeds 100,000 Servicing asset 1,000 CE Fees Receivable 400

Net ProceedsCash proceeds 100,000 Servicing asset 1,000

N t d 101 000Net proceeds 101,000

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Example #1 – Journal Entries CE Recourse Liability at Calculated Fair Value

JE 1 Cash 100,000$ CE Fees Receivable 400$

CE R Li bilit 40$

CE Recourse Liability at Calculated Fair Value

CE Recourse Liability 40$ Loan Receivable 100,000$ Gain on Sale 360$

Record Loan Sale with CE fees and CE obligation at fair valueRecord Loan Sale with CE fees and CE obligation at fair value

JE 2 Servicing Asset 1,000$ Gain on Sale 1,000$

Record fair value of MSR

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JE 1 Cash 100,000$

Example #2 – Original MPF: Journal Entries – Liability = Receivable

CE Fees Receivable 400$ CE Recourse Liability 400$ Loan Receivable 100,000$

Record Loan Sale

JE 2 Servicing Asset 1,000$ Gain on Sale 1,000$

Record fair value of MSR

JE 3 Cash 100$ CE Fees Receivable 90$ Other Income 10$

Record year one CE fees and amortize discount on liability

JE 4 CE Recourse Liability 90$ Other Expense 10$

Other Income 100$ Recognize fee income and amortize discount on liability

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How to account for the MSR after initial recording?


How to account for the MSR after initial recording?

FAS ASC paragraph 860-50-35-1 allows the asset to be measured and reported in one of two ways:p y

1) Amortization Method

2) Fair Value Method

A PFI may select either method, but cannot switch methodologies unless it moves to the Fair Value method at the beginning of the fiscal year before interim financial statements have been released. A PFI cannot go back to the amortization method after it has elected Faircannot go back to the amortization method after it has elected Fair Value.

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Amortization Method


Amortization Method

Amortize the MSR in proportion and over the period of estimated net i i i (l l i ld th d) d i i t fservicing income (level yield method) and assess servicing assets for

impairment based on fair value at each reporting date.

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Fair Value Method


Fair Value Method

• The fair value is determined at each reporting period

• The asset is adjusted to equal its fair value

• The difference is taken into income or expense for that reporting period

• PFIs that hedge their servicing rights portfolios can benefit from the fair value method because the accounting is less complex than under FAS ASC Topic 815 – Derivatives and Hedging. PFIs that do p g gnot hedge their portfolios and that elect the fair value method could experience earnings volatility.

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Regulatory Reporting Requirements

FFIEC F d l Fi i l I tit ti E i tiFFIEC – Federal Financial Institutions Examination Council

NCUA – National Credit Union AdministrationNCUA National Credit Union Administration

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Accounting and Regulatory Guidance for the Federal Home Loan Banks’ MPF® ProgramFederal Home Loan Banks MPF Program Federal Home Loan Bank of Des Moines Active Master Commitments - Summary funded through 9/30/2013

PFI Number: XXXX ABC Bank ___________________________________________________________________ MC Number:

XXXX

Totals for MC Number: XXXX Original (Contracted) C/E: $1,500,000.00 MC Pool Amount: $45,000,000.00

$1 149 173 68 Pool (Total Used) C/E: $1,149,173.68 Delivery Commitment Amounts: $29,425,685.00 Balance (Available) C/E: $350,826.32 Amount Funded to Date: $28,332,685.00 Outstanding Delivery Commitment Amount Available: $0.00 Highest Zip Code Concentration XXXX 15.128% Number of Loans to Date: 186 Average Loan Level CE 4.056% Total PairOff Fees by MC: $5.01 Total Extension Fees by MC: $129.34 MC Expiration Date: 12/31/2013 MC Program: Original

Remaining MC Available: $5 575 000 00

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Remaining MC Available: $5,575,000.00


FFIEC Call Report Requirements for MPF Closed Loan P d t M t S i i Ri ht


Products – Mortgage Servicing Rights

1) Total volume of loans sold - Schedule RC-S, item 11A and RC-S, Memoranda item 2a (for MPF Xtra loans the onl req ired entr isMemoranda, item 2a (for MPF Xtra loans the only required entry is RC-S Memoranda, item 2b because there is no recourse)

2) Book value of retained servicing – RC-M, Memoranda, item 2a

3) Estimated fair value of retained servicing – RC-M, Memoranda, item 2a(1)

4) Gain or Loss on loan sales for the quarter should be reported on ) q pSchedule RI, item 5i

5) Servicing fees for the quarter should be reported on Schedule RI, item 5f

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Basel III Impact on MSR Assets


1) Servicing assets are limited to 10% of total Common Equity Tier 1

2) Deduction phases in through the end of 2017

3) Eligible portion is risk weighted at 250% beginning January 1, 2018

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FFIEC Call Report Requirements for Mortgage Banking A ti iti


Activities

Schedule RC-P – 1-4 Family Residential Mortgage needs to be completed if the follo ing is tr ecompleted if the following is true:

1. The Bank has over $1 Billion in Total Assets.

2. The Bank has less than $1 Billion in Total Assets at which either 1-4 family residential mortgage loan originations and purchases for resale from all sources, loan sales, or quarter-end loans held for sale exceed $10 Million for two consecutive quarterssale exceed $10 Million for two consecutive quarters.

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FFIEC Call Report Requirements CE Recourse Obligation


RC-R Line 50 vs. Line 51:

A bank can elect to calculate its risk weighted assets based on the th d l th t i t f bl t th b k’ it l Th tmethodology that is most favorable to the bank’s capital. The most

favorable treatment is dependent on several factors including the dollar amount of the CE Obligation amount as a percentage of the outstanding principal balance of the loans in the master g p pcommitment and the bank’s Tier 1 Capital percentage. Wilary Winn recommends that a bank calculate its risk weighted assets by first entering the outstanding principal balance of the loans on RC-R line 51 and multiplying the balance by a 50% risk weight51 and multiplying the balance by a 50% risk weight.

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FFIEC Call Report Requirements CE Recourse Obligation


RC-R Line 50 vs. Line 51 (Cont.):

We then recommend that a bank calculate its risk weighted assets by l l ti th i i k i ht d t th t ld lt fcalculating their risk weighted assets that would result from

reporting the CE Obligation amount on RC-R line 50. We encourage banks with more than 8% Tier 1 capital to calculate their institution specific multiplier on line 50 because it will most likely be p p yless than the default factor of 12.5. The bank can then report the CE Obligation according to the method which results in the lower amount of risk weighted assets.

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FFIEC Call Report Requirements Direct Reduction Method


Direct Reduction Method

In general PFIs with total risk based capital in excess of 8 percent willIn general, PFIs with total risk based capital in excess of 8 percent will generally benefit from the use of the direct reduction method when calculating the Credit Conversion Factor because it will result in a factor lower than 12.5, and thus less total risk weighted assets.

Contact Wilary Winn and we can provide a spreadsheet that can assist you with the calculation of the direct reduction Credit Conversion Factor or refer to our MPF Accounting manual (pages 32-33)Factor or refer to our MPF Accounting manual (pages 32-33) located on our website for details of how to calculate your institution specific Credit Conversion Factor.

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FFIEC Call Report Requirements for CE Fees Receivable and CE Recourse Liabilities – Line 50 Example


CE Recourse Liabilities Line 50 Example1) The CE Recourse Obligation amount (less any CE recourse liability

recorded) is reported in Schedule RC-S, item 12A and RC-R, item 50A50A

2) The amount in RC-R, 50A is multiplied by the Credit Conversion Factor of 12.5 (gross-up method) or the institution-specific factor for the PFI (direct reduction method)( )

3) The resulting multiplicand is reported as the Credit Equivalent Amount in RC-R, Item 50F

4) The CE Fees receivable is to be reported on RC F item 3a as an4) The CE Fees receivable is to be reported on RC-F, item 3a as an interest only strip (and for MPF 125 only on RC-S 2a column A)

5) The CE recourse liability is reported on RC-G, item 3

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FFIEC Call Report Requirements for CE Fees Receivable and CE R Li biliti Li 51 E l


CE Recourse Liabilities – Line 51 Example

1) The unpaid principal balance of the loans is reported on RC-R item 51A51A

2) The amount in RC-R, 51A is risk weighted at 50 percent in Column E

3) The CE Fees receivable is to be reported on RC F item 3a as an3) The CE Fees receivable is to be reported on RC-F, item 3a as an interest only strip (and for MPF 125 only on RC-S 2a column A)

4) The CE recourse liability is reported on RC-G, item 3

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Regulatory Reporting Example – FFIEC – Line 50 Example


ExampleABC Bank - FFIEC Call Report Summary

9/30/2013 Valuation - Client Uses Amortization Method

Item Amount to Report Location to ReportfOutstanding Prin. Bal. of Sold Loans 37,165,653.46 Schedule RC-S, item 11A

Outstanding Prin. Bal. of Sold Loans 37,165,653.46 Schedule RC-S, Memoranda, item 2aBook Value of Retained Servicing 329,203.91 Schedule RC-M, Memoranda, item 2aEstimated Fair Value of Retained Servicing 334,831.91 Schedule RC-M, Memoranda, item 2a (1)CE Recourse Obligation Amount – Net of Recourse Liability 1,024,617.44 Schedule RC-S, item 12ACE Recourse Obligation Amount – Net of Recourse Liability 1,024,617.44 Schedule RC-R, item 50A

CE Recourse Obligation Amount* 12.5 (gross up method) 12,807,718.02 Schedule RC-R, item 50FCE Fees Receivable 124,556.24 Schedule RC-F, item 3a, Sc edu e C , e 3aGain or Loss on Sale (for the quarter) 27,027.53 Schedule RI, item 5iServicing Fees (for the quarter) N/A Schedule RI, item 5fRecourse Liability (actual liability reported on G/L) 124,556.24 Schedule RC-G, item 4

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Regulatory Reporting Example – FFIEC – Line 51 Example


ExampleABC Bank - FFIEC Call Report Summary

9/30/2013 Valuation - Client Uses Amortization Method

Item Amount to Report Location to ReportfOutstanding Prin. Bal. of Sold Loans 37,165,653.46 Schedule RC-S, item 11A

Outstanding Prin. Bal. of Sold Loans 37,165,653.46 Schedule RC-S, Memoranda, item 2aBook Value of Retained Servicing 329,203.91 Schedule RC-M, Memoranda, item 2aEstimated Fair Value of Retained Servicing 334,831.91 Schedule RC-M, Memoranda, item 2a (1)CE Recourse Obligation Amount – Net of Recourse Liability 1,522,753.70 Schedule RC-S, item 12AOutstanding Loan Balance of Master Commitment 37,165,653.46 Schedule RC-R, item 51A

Outstanding Loan Balance of Master Commitment * 50% 18,582,826.73 Schedule RC-R, item 51ECE Fees Receivable 124,556.24 Schedule RC-F, item 3a, Sc edu e C , e 3aGain or Loss on Sale (for the quarter) 27,027.53 Schedule RI, item 5iServicing Fees (for the quarter) N/A Schedule RI, item 5fRecourse Liability (actual liability reported on G/L) 124,556.24 Schedule RC-G, item 4

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Basel III Impact on Credit Enhancement


1) Under Basel III the CE Obligation is treated as a securitization (see page 346 of the Basel III rules).

2) A bank can use the Simplified Supervisory Formula Approach2) A bank can use the Simplified Supervisory Formula Approach (“SSFA”) or a gross up method under the general risk-based capital rules.

3) The SSFA formula is:3) The SSFA formula is:

KA – A D - KAD – A D - A

X 1,250% X 1,250% X KSSFA+

4) The (simplified) gross up method formula is:

1) (Outstanding UPB – Remaining FLA) * 50% Risk Weight

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NCUA Call Report Requirements for Mortgage Servicing Rights


1) Servicing fees are included in Non-Interest Income – Page 5, line 12

2) Loan servicing expenses are included in Non-Interest Expense –Page 5, line 24

3) Total amount of 1st mortgage loans sold into the secondary market year-to-date is reported on Schedule A, line 16

4) Amount of real estate loans sold but serviced by the credit union (dollar amount of servicing) is reported on Schedule A, line 18

5) The MSR book value is reported on Schedule A line 195) The MSR book value is reported on Schedule A, line 19

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NCUA Call Report Requirements for CE Fees Receivable and CE R Li biliti


Recourse Liabilities

1) The CE Fees receivable is reported on Page 2, line 32C

2) The CE Recourse liability is reported on Page 3, line 8

3) The outstanding principal amount of loans sold is reported on Page 10 li i h C i Li bili i i Th i i l10, line 5 in the Contingent Liabilities section. The principal amount sold is then subject to the Risk Based Net Worth requirement equal to six percent (NCUA 702.107 (d)). • Complex credit unions (defined as those having more than $10MComplex credit unions (defined as those having more than $10M

in total assets and a standard risk based net worth of over 6%) may benefit from calculating the capital charge under 702.107. In this way, the capital charge is limited to the actual CE Obligation

t

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percentage.


Regulatory Reporting Example - NCUA


ABC Credit Union - NCUA Call Report SummaryABC Credit Union NCUA Call Report Summary3/31/2012 Valuation - Client Uses Amortization Method

Item Amount to Report Location to ReportLoan Servicing Fees (for the quarter) N/A * Page 5, Line 12

(f ) /Loan Servicing Costs (for the quarter) N/A * Page 5, Line 24

Total amount of loans sold in secondary market Year‐to‐Date 5,897,315.00 Schedule A, Line 16

Total amount of first mortgage loans sold but serviced by the credit union 37,165,653.46 Schedule A, Line 18

CE Fees Receivable 124,556.24 Page 2, Line 32C

Recourse Liability 124,556.24 Page 3, Line 8

Book Value of Mortgage Servicing Assets 329 203 91 Schedule A Line 19Book Value of Mortgage Servicing Assets 329,203.91 Schedule A, Line 19

Outstanding Principal Amount of Loans Sold 37,165,653.46 ** Page 10, Line 5

* This information is internal to the credit union and can not be provided by Wilary Winn.** The principal amount sold is then subject to the Risk Based Net Worth requirement, equal to the lesser of the actual

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CE Recourse Obligation percent or 6 percent (NCUA 702.107 (d)).


How Wilary Winn Can Help


1. Wilary Winn can perform a valuation of your entire mortgage servicing portfolio. The valuation will include determining the values of the MSR, the CE Fees Receivable, the CE Recourse Liability at the Loan Level and assist with any questions related to the accounting for the portfolio.

2. For those electing the amortization method for MSRs, Wilary Winn ill i h MSR i l l l b i ll f d filwill incorporate the MSR into a loan level basis roll forward file,

which will provide information necessary to produce the amortization journal entries going forward. The file will also include a section where newly sold loans can be added and theinclude a section where newly sold loans can be added and the amount of the new MSR will be calculated; the amortization for these loans will also be calculated.

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Services and Contact InformationMortgage Servicing Rights and Mortgage Banking Derivatives:

Eric Nokken [email protected]

Private Label MBS/CMOs and Asset Liability Management:Frank Wilary [email protected]

Mergers and Acquisitions, Fair Value Footnotes, and TDRs:Brenda Lidke [email protected]

Pooled Trust Preferred CDOs:Gregg Johnson [email protected]

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Wilary Winn LLCAlliance Bank Center

55 East 5th Street Suite 102055 East 5 Street, Suite 1020St. Paul, MN 55101

651-224-1200

www.wilwinn.com

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