ALD: Broker – Dealers Problem Escalation Process Flows

1. ALD: Broker – Dealers Problem Escalation Process Flows A Guideline to broker-dealers for resolving problems occurring during the daily ALD process flow October 2006

2. Content • Broker-dealer connecting directly to DTCC • File and notification flow • Guidelines and Legend • File retrieval decision making process • Problem research flows: • Agent Lender direct to DTCC • Agent Lender using EquiLend • Agent Lender using SunGard • Broker-dealer using EquiLend • File and notification flow • Guidelines and Legend • File retrieval decision making process • Problem research flows: • Agent Lender direct to DTCC • Agent Lender using EquiLend • Agent Lender using SunGard • Broker-dealer using SunGard • File and notification flow • Guidelines and Legend • File retrieval decision making process • Problem research flows: • Agent Lender direct to DTCC • Agent Lender using EquiLend • Agent Lender using SunGard

3. Broker-Dealer Accessing Through DTCC Files and Notification Flow Problem Notification & Update Expected File Receipt/ Delivery Agent Lender SunGard client DTCC systemic failure notification SunGard Broker-Dealer DTCC EquiLend Agent Lender (EquiLend client) Agent Lender DTCC direct

4. Broker-Dealer Daily file receipt via DTCC Guidelines • Broker-dealers that experience problems retrieving agent lender files from DTCC should: • Check for e-mail notification from vendors (SunGard, EquiLend) or agent lenders of problems or delays in delivering the loan and/or collateral file(s) • Check the file status on the DTCC website or contact the DTCC, 24 hour PIP Hotline (+ 1 212 855.8989) • Contact agent lenders directly DTCC WILL NOT NOTIFY BROKER-DEALERS OF PROBLEMS RECEIVING AGENT LENDER FILES AND DOES NOT TRACK EXPECTED VERSUS RECEIVED FILES. DTCC will send automatic notifications (through their existing crisis management system) only in the case of systemic failures. These notifications will be sent to anyone who wishes to receive them and who provides a contact email to DTCC. Any broker-dealer connecting directly to DTCC who wishes to be part of this notification process should send their contact email to Margaret Koontz, mkoontz@dtcc.com Broker-dealers should be notified by vendors (SunGard, EquiLend) and agent lenders of problems or delays in delivering loan and/or collateral file(s) • Notifications should be received at the broker-dealer’s group e-mail address that was specified to their vendor and agent lender counterparties • A vendor or agent lender notification should include: • Identity of sending firm and contact information • The general nature and severity of the problem • An estimate for correcting the problem • Identification if this is the initial notification of the problem or an update related to a prior notification

5. Broker-Dealer Daily file receipt via DTCC Legend Broker-dealers must research missing or unavailable files using the DTCC website and the DTCC PIP Hotline to determine if the files were successfully received by DTCC Check DTCC Website For File Availability • If the broker-dealer finds that files were not successfully received by DTCC then the broker-dealer should check for vendor or agent lender notifications of problems • If the broker-dealer determines that DTCC successfully received the agent lender files, then the broker-dealer should verify their processing with DTCC and contact the DTCC PIP Hotline for additional support Call DTCC PIP Hotline & Monitor Status • Monitoring Notifications: • Once the broker-dealer receives e-mail notification of a problem, they should continue to monitor e-mail for updates on resolving the issue • If the sender (agent lender, vendor) does not specify an expected time for resolving the problem or has not provided an update by the time specified, the broker-dealer should call the sender using contact information provided • Agent lenders must produce notification and status updates of: • problems creating the loan and/or collateral file(s) that may result in no files being sent; • delays in creating files; • problems transmitting the loan and/or collateral file(s) to their primary recipient (EquiLend, SunGard or DTCC). Monitor A/L File Status Monitor Vendor File Status Vendors must produce notification and status updates of problems sending agent lender files to DTCC. Agent lenders should be contacted directly when no e-mail notification has been received from either the agent lender or a vendor regarding the missing files Contact A/L Re: Missing Files Broker dealer should monitor status with DTCC in the case where a systemic failure email notice was received from DTCC. Monitoring should be done through the DTCC website or by contacting the PIP hotline. Monitor System Status with DTCC

6. Broker-Dealer via DTCC Retrieve Agent Lender Loan & Collateral Files Decision Making Process Flow Start All Files Retrieved by 3:00 AM? Continue Standard ALD Processing Yes No Sys. Failure notification rec’d from DTCC? Monitor System Status with DTCC Yes Check DTCC Website For File Availability No Files Available at DTCC? Yes Call DTCC PIP Hotline & Monitor Status No A/L Delay or Failure Notification Received? Yes No Monitor A/L File Status Vendor Failure Notification Received? Monitor Vendor File Status Yes No Research Missing Files See next 3 slides for specific problem research flow s Wait for A/L Files?* Delay Processing Until A/L files Received; then continue with standard processing Yes No Continue with prior day A/L files As contingency * Decision making process must be determined internally by each broker-dealer

7. Problem research flows Broker-dealer (Direct to DTCC) Agent Lender (Direct to DTCC) A/L Files created? No Start Check DTCC website for agent lender files Yes Update B/D with status No Correct related Problems Contact Agent Lender by phone & e-mail File Available? Create A/L Files Yes Files Accepted by DTCC? No Yes A/L Files created? Yes No Check DTCC website for A/L Files Update B/D with status Notify DTCC & B/D of conflicting info Resolve retrieval problem with DTCC hotline Resolve issue with DTCC Correct related Problems Update B/D with status Send Files to DTCC Update B/D with status Files Accepted by DTCC? No Yes Update B/D with status Retrieve files from DTCC End

8. Problem research flows Agent Lender (EquiLend) Broker-dealer (DTCC) EquiLend A/L Files created? Contact Agent Lender by e-mail No Start Check DTCC website for agent lender files Yes Update B/D & EquiLend with status Correct related Problems No Files Received from A/L? No File Available? Contact EquiLend by phone & e-mail Create A/L Files Yes Yes A/L Files created? Yes No Files Accepted by DTCC? Files Accepted by EquiLend? Resolve retrieval problem with DTCC hotline Yes No No Update B/D & EquiLend with status Yes EquiLend & B/D Resolve retrieval problem with DTCC EquiLend & A/L resolve conflicting info Notify EquiLend & B/D of conflicting info Correct related Problems Update B/D & A/L with status Update B/D & EquiLend with status Send Files to EquiLend Resolve issue with DTCC Update B/D & EquiLend with status Files Accepted by EquiLend? Update B/D & A/L with status No Update B/D & EquiLend with status Yes Retrieve files from DTCC End

9. Problem research flows SunGard Broker-dealer (DTCC) Agent Lender (SunGard) A/L Files created? No Start Check DTCC website for agent lender files Contact Agent Lender by phone & e-mail Yes Update B/D & SunGard with status Correct related Problems No Files Received from A/L? File Available? Contact SunGard by phone & e-mail No Create A/L Files Yes Yes A/L Files created? Yes No Files Accepted by DTCC? Files Accepted by SunGard? Resolve retrieval problem with DTCC hotline Yes No No Update B/D & SunGard with status Yes SunGard & B/D Resolve retrieval problem with DTCC Notify SunGard & B/D of conflicting info SunGard & A/L resolve conflicting info Update B/D & A/L with status Correct related Problems Update B/D & SunGard w/ status Send Files to SunGard Resolve issue with DTCC Update B/D & SunGard with status Files Accepted by SunGard? Update B/D & A/L with status No Update B/D & SunGard with status Yes Retrieve files from DTCC End

10. Broker-dealer using EquiLend • File and notification flow • Process flow guidelines and legend • Decision making process flow • Problem research flows for B/D using EquiLend: • Agent Lender direct to DTCC • Agent Lender using EquiLend • Agent Lender using SunGard

11. Broker-dealer Accessing Through EquiLend Files and Notification Flow Problem Notification & Update Expected File Receipt/ Delivery DTCC systemic failure notification Agent Lender SunGard client SunGard Agent Lender EquiLend client DTCC EquiLend Agent Lender DTCC direct Broker-Dealer

12. Broker-Dealer Daily file receipt via EquiLend Guidelines and Legend Broker-dealers should be notified by vendors (SunGard, EquiLend) and agent lenders of problems or delays in delivering loan and/or collateral file(s) • Notifications should be received at the broker-dealer’s group e-mail address that was specified to their vendor and agent lender counterparties • A vendor or agent lender notification should include: • Identity of sending firm and contact information • The general nature and severity of the problem • An estimate for correcting the problem • Identification if this is the initial notification of the problem or an update related to a prior notification • Monitoring Notifications: • Once the broker-dealer receives e-mail notification of a problem, they should continue to monitor e-mail for updates on resolving the issue • If the sender (agent lender, vendor) does not specify an expected time for resolving the problem or has not provided an update by the time specified, the broker-dealer should call the sender using contact information provided DTCC will send automatic notifications (through their existing crisis management system) only in the case of systemic failures. These notifications will be sent to anyone who wishes to receive them and who provides a contact email to DTCC. Any broker-dealer using a vendor who wishes to be part of this notification process should send their contact email to Margaret Koontz, mkoontz@dtcc.com Legend • Agent lenders must produce notification and status updates of: • problems creating loan and/or collateral file(s) that may result in no files being sent, • delays in creating files, • problems transmitting the loan and/or collateral file(s) to their primary recipient (EquiLend, SunGard or DTCC) Monitor A/L File Status Monitor Vendor File Status • Vendors must produce notification and status updates of: • Problems sending agent lender files to DTCC, • Issues preventing broker-dealers from receiving files Agent lenders should be contacted directly when no e-mail notification has been received from either the agent lender or a vendor regarding the missing files Contact A/L Re: Missing Files

13. Broker-Dealer via EquiLend Decision Making Process Flow Start Receive Agent Lender Loan & Collateral Files All Files Received by 3:00 AM? Continue Standard ALD Processing Yes No A/L Delay or Failure Notification Received? Yes Monitor A/L File Status No Vendor Failure Notification Received? Monitor Vendor File Status Yes No See next three slides for specific problem research flows. Contact vendor Re: Missing Files Wait for A/L Files?* Delay Processing Until A/L files Received; then continue with standard processing Yes No Continue with prior day A/L files As contingency * Decision making process must be determined internally by each broker-dealer

14. Problem research flows Agent Lender (DTCC) Broker-dealer (EquiLend) EquiLend A/L Files created? Start No No Contact Agent Lender by phone & e-mail Files Available at DTCC? Yes Update B/D & EquiLend with status Check EquiLend browser for agent lender files Yes Correct related Problems Check DTCC website for A/L Files Create A/L Files Files Accepted by DTCC? Yes No A/L Files created? Files Received from DTCC? No No Contact EquiLend by phone & e-mail Files Available? Check DTCC website for A/L Files No Yes Yes Yes Update B/D & EquiLend with status Resolve retrieval problem with EquiLend Resolve B/D retrieval Issue Notify DTCC, B/D & EquiLend of conflicting info Update B/D with status Correct related Problems Resolve issue with DTCC Resolve retrieval problem with DTCC Send Files to DTCC Update B/D & EquiLend with status Update B/D & EquiLend with status Files Accepted by DTCC? Update B/D with status No Yes Update B/D & EquiLend with status Retrieve files from EquiLend End

15. Problem research flows Agent Lender (EquiLend) Broker-dealer (EquiLend) EquiLend A/L Files created? No Start Yes Check EquiLend browser for agent lender files Update B/D & EquiLend with status Contact Agent Lender by e-mail Contact EquiLend by phone & e-mail Correct related Problems Notify EquiLend & B/D of conflicting vendor info File Available? No Create A/L Files A/L Files created? No Yes EquiLend & A/L resolve conflicting info Files Accepted by EquiLend? Yes Yes Update B/D & EquiLend with status No Update B/D & A/L with status Correct related Problems Resolve retrieval problem with EquiLend Send Files to EquiLend Update B/D & EquiLend with status Files Accepted by EquiLend? No Yes Update B/D & EquiLend with status Retrieve files from EquiLend End

16. Problem research flows Broker-dealer (EquiLend) Agent Lender (SunGard) SunGard EquiLend A/L Files created? Start No Contact Agent Lender by phone & e-mail Yes No Update B/D, SunGard & EquiLend with status Files Received from A/L? Contact SunGard by e-mail Check EquiLend browser for agent lender files No Yes Files Available at DTCC? Correct related Problems Files Accepted by DTCC? Yes Yes Files Available? No Create A/L Files Check DTCC website for A/L Files EquiLend & SunGard resolve retrieval problem with DTCC A/L Files created? No Yes No Yes No Contact EquiLend by phone & e-mail Files Received from DTCC? Update B/D, SunGard & EquiLend with status Update B/D, EquiLend & A/L with status Files Accepted by SunGard? Yes Resolve issue with DTCC Resolve retrieval problem with EquiLend Resolve B/D retrieval Issue No Yes Update B/D with status Update B/D, EquiLend & A/L with status Notify EquiLend, SunGard & B/D of conflicting info Resolve retrieval problem with DTCC SunGard & A/L resolve conflicting info Correct related Problems Update B/D with status Update B/D, EquiLend & A/L with status Send Files to SunGard Update B/D, SunGard & EquiLend with status Update SunGard & B/D with status Files Accepted by SunGard? No Retrieve files from EquiLend Update B/D, SunGard & EquiLend with status Yes End

17. Broker-dealer using SunGard • File and notification flow • Process flow guidelines and legend • Decision making process flow • Problem research flows for B/D using SunGard: • Agent Lender direct to DTCC • Agent Lender using EquiLend • Agent Lender using SunGard

18. Broker-dealer Accessing Through SunGard Files and Notification Flow Problem Notification & Update Expected File Receipt/ Delivery DTCC systemic failure notification Agent Lender SunGard client SunGard Broker-Dealer DTCC Agent Lender DTCC direct EquiLend Agent Lender EquiLend client

19. Broker-Dealer Daily file receipt via SunGard Guidelines and Legend Broker-dealers should be notified by vendors (SunGard, EquiLend) and agent lenders of problems or delays in delivering loan and/or collateral file(s) • Notifications should be received at the broker-dealer’s group e-mail address that was specified to their vendor and agent lender counterparties • A vendor or agent lender notification should include: • Identity of sending firm and contact information • The general nature and severity of the problem • An estimate for correcting the problem • Identification if this is the initial notification of the problem or an update related to a prior notification • Monitoring Notifications: • Once the broker-dealer receives e-mail notification of a problem, they should continue to monitor e-mail for updates on resolving the issue • If the sender (agent lender, vendor) does not specify an expected time for resolving the problem or has not provided an update by the time specified, the broker-dealer should call the sender using contact information provided DTCC will send automatic notifications (through their existing crisis management system) only in the case of systemic failures. These notifications will be sent to anyone who wishes to receive them and who provides a contact email to DTCC. Any broker-dealer using a vendor who wishes to be part of this notification process should send their contact email to Margaret Koontz, mkoontz@dtcc.com Legend • Agent lenders must produce notification and status updates of: • problems creating loan and/or collateral file(s) that may result in no files being sent, • delays in creating files, • problems transmitting the loan and/or collateral file(s) to their primary recipient (EquiLend, SunGard or DTCC) Monitor A/L File Status Monitor Vendor File Status • Vendors must produce notification and status updates of: • Problems sending agent lender files to DTCC, • Issues preventing broker-dealers from receiving files Agent lenders should be contacted directly when no e-mail notification has been received from either the agent lender or a vendor regarding the missing files Contact A/L Re: Missing Files

20. Broker-Dealer via SunGard Decision Making Process Flow Start Receive Agent Lender Loan & Collateral Files All Files Received by 3:00 AM? Continue Standard ALD Processing Yes No A/L Delay or Failure Notification Received? Yes Monitor A/L File Status No Vendor Failure Notification Received? Monitor Vendor File Status Yes No See next three slides for specific problem research flows. Contact vendor Re: Missing Files Wait for A/L Files?* Delay Processing Until A/L files Received; then continue with standard processing Yes No Continue with prior day A/L files As contingency * Decision making process must be determined internally by each broker-dealer

21. Problem research flows Broker-dealer (SunGard) Agent Lender (DTCC) SunGard A/L Files created? Start Contact Agent Lender by phone & e-mail No No Yes Files Available at DTCC? Yes Update B/D & SunGard with status Check SunGard website for agent lender files Correct related Problems Check DTCC website for A/L Files Create A/L Files Files Accepted by DTCC? Yes No Files Received from DTCC? A/L Files created? No File Available? Contact SunGard by phone & e-mail No Check DTCC website for A/L Files No Yes Yes Yes Update B/D & SunGard with status Resolve B/D retrieval Issue Resolve retrieval problem with SunGard Notify DTCC, B/D & SunGard of conflicting info Update B/D with status Correct related Problems Resolve issue with DTCC Resolve retrieval problem with DTCC Send Files to DTCC Update B/D & SunGard with status Update B/D & SunGard with status Files Accepted by DTCC? Update B/D with status No Yes Update B/D & SunGard with status Retrieve files from SunGard End

22. Problem research flows Broker-dealer (SunGard) Agent Lender (EquiLend) EquiLend SunGard A/L Files created? Contact Agent Lender by e-mail No Start Yes No Update B/D, SunGard & EquiLend with status Files Received from A/L? Check SunGard website for agent lender files Contact EquiLend by phone & e-mail No Yes Files Available at DTCC? Correct related Problems Files Available? Files Accepted by DTCC? No Yes Yes Create A/L Files Yes Contact SunGard by phone & e-mail Check DTCC website for A/L Files EquiLend & SunGard resolve retrieval problem with DTCC A/L Files created? No No Yes No Files Received from DTCC? Update B/D, SunGard & EquiLend with status Update SunGard & A/L with status Resolve retrieval problem with SunGard Files Accepted by EquiLend? Yes Resolve issue with DTCC Resolve B/D retrieval Issue No Yes Update B/D with status Update SunGard & A/L with status Notify EquiLend, SunGard & B/D of conflicting info Resolve retrieval problem with DTCC EquiLend & A/L resolve conflicting info Update B/D with status Correct related Problems Update SunGard & A/L with status Update EquiLend & B/D with status Send Files to EquiLend Update B/D, SunGard & EquiLend with status Update B/D with status Files Accepted by EquiLend? No Retrieve files from SunGard Update B/D, SunGard & EquiLend with status Yes End

23. Problem research flows Agent Lender (SunGard) Broker-dealer (SunGard) SunGard A/L Files created? No Start Contact Agent Lender by phone & e-mail Check SunGard website for agent lender files Yes Update B/D & SunGard with status No File Available? Files Received from A/L? Contact SunGard by phone & e-mail No Correct related Problems Notify SunGard & B/D of conflicting vendor info Create A/L Files Yes Yes Resolve B/D retrieval Issue A/L Files created? No Update B/D with status Files Accepted by SunGard? Yes Yes No Update B/D & SunGard with status SunGard & A/L resolve conflicting info Resolve retrieval problem with SunGard Correct related Problems Update B/D & A/L with status Send Files to SunGard Update B/D & SunGard with status Files Accepted by SunGard? No Update B/D & SunGard with status Yes Retrieve files from SunGard End

24. Problem Research Flows Version 5 changes • Changed method of EquiLend contacting agent lenders and SunGard from “phone & e-mail” to “e-mail” only on all flows as per comments from EquiLend.