Global Program Management

1. Global Program Management Dawn Davis, SVP Global Records Management

2. Bank of America Profile • 282,000 Employees • Clients in 150 Countries • 98% of US Fortune 500 • 84% of Global Fortune 500 • 53 million consumer and small business relationships • 6,100+ retail banking offices & nearly 18,500 ATMs • Online banking with 6.63 million active users • $1.5 trillion Community Development Lending & Investing goal over 10 years (largest ever set by a financial institution) • #1 or #2 in a variety of financial services offerings • $200 million in philanthropic investments in 2009 • Unprecedented $2 billion, 10-year goal for philanthropic giving began in 2009

3. Bank of America Global Records Management Profile Main goal:  Manage the lifecycle of records including the systematic disposition approval in accordance with retention schedule & preservation notices • Legal entities in 43 countries with 6,800 citations involving records storage requirements • Large inventory • Develop and manage a global policy and the retention schedule. • Ensure compliance with legal, statutory, regulatory, and business requirements for the access and storage of corporate records. • Partner with Legal to standardize identification and application of Legal Preservation Notices on all items in offsite storage. • Develop, implement and govern all program enhancements through the Records Management Governance Board. • Ensure the immediate availability of vital information. • Monitor and control the service, the volume and cost of record storage and handling. • Manage approved contracted suppliers for hard copy storage, and secured destruction services. • Manage data mapping, chain of custody, and transition of legacy records into end-state environment. • Manage life-cycle of cartons in storage including all activity and ultimate systematic destruction. • Enable associates to better manage their records by providing centralized resources, intuitive technology tools and required education. • Consult LOBs on best-in-class record management practices. Regulatory/Legal Suppliers Associates

4. Challenges • Multiple audiences, records, data sources, languages, locations to manage • Company size and scale • Vendor selection/capabilities globally • Different regulations in each jurisdiction that are constantly changing (ex: Cross Border Data Regulations) • Growing volume of data (electronic and paper) • Managing and migrating inherited inventory • Defining global infrastructure and identifying records custodians • Communicating to & educating associate population • Complicated technology environment • Financial Services Regulations • Banking • Lending • Insurance • Investments • Securities • Accounting

5. Global Records Strategy • Objective: Centrally manage global records Step 1: Planning: Sponsorship, Resources, Timelines Step 2: Establish Standard Records Policy and Retention Schedule Step 3: Implement Global Records Policy Step 4: Prioritize launch of Global Retention Schedule Step 5: Implement Global Retention Schedule Step 6: Improve, Control, and Monitor • A compliance program, not a project.

6. Global Retention Program Best Practices • Centralize Global Records Management functions • Secure executive sponsorship and build governance structure • Specialize your Records Management Team • Engage the experts • Make friends: find your internal stakeholders • Build a user-friendly retention schedule • Legal, industry and business requirements • Consider risk/reward balance • Drive out a global taxonomy • Focus on the end to end lifecycle to identify compliance risks • Use risk identification tools to error-proof processes and technology • Communicate and train

7. Global Retention Program Best Practices • Make it easy to do the right thing.