Federal Deposit
Insurance Corporation

Audit

1.

Have the directors/trustees made provision for an audit of the foreign exchange area? If �Yes,� indicate method utilized:

X

X

Employment of full time auditor.

X

Periodic employment of independent auditor.

Designation of an audit supervisor and an established program of internal audit by bank personnel.

Name of Audit Supervisor:

2.

If the answer to question 1 is �yes�, does the audit program include the following:

(a)

Periodic proof of forward and spot contracts?

X

(b)

Periodic proof and/or reconcilement of foreign exchange general ledger accounts?

X

(c)

Periodic direct verification of forward and spot contracts?
Frequency: Annually Amount: $25,200,000

X

(d)

Review of management reports and adherence to guidelines?

X

(e)

Comparison of rate quotations in management reports and revaluations with outside sources?

X

(f)

Perusal of authorized signatures?

X

(g)

Briefly describe any other audit procedures conducted:

3.

If applicable, has the bank corrected major criticisms noted in the last independent audit report?

X

Date of audit: 12/31/2003

Briefly describe major criticisms and/or recommendations in such report:

The bank was criticized for not maintaining a complete and current set of instructional memoranda describing the information generated from the accounting system and the general and subsidiary ledger accounts affected by trading activity. This defect has been corrected. Deficiencies still exist with respect to confirmation procedures.

4.

Is the foreign exchange audit program adequate as to scope and frequency?

X

5.

Does the foreign exchange auditor or audit supervisor report regularly and directly to the bank's board of directors/trustees or a committee thereof?

X

6.

Is a written audit report of the foreign exchange area maintained by the bank?

X