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					Operational Support
CONTINUOUS IMPROVEMENT TO INCREASE BUSINESS EFFICIENCY




Your Business Without Limits   TM
Partner With a Reliable and Experienced Leader
In today’s aggressive marketplace, consolidation, strong competitive pressures, the fast
pace of regulatory change, and a quarterly focus on financial performance are driving
many to critically review the cost and ease of providing operational support.

For nearly 70 years, Pershing has been providing operational support for financial services organizations just like
yours. Your challenge lies in reducing operational expenses while handling increased volumes and satisfying more
demanding clients.

The breadth of our experience in clearing and settlement, billing, custody, and reporting services gives us
an enormous advantage in tailoring our services to your needs. With that experience, we bring the practical,
hands-on understanding necessary to harness, manage, and streamline operational processes.

Our passionate, knowledgeable professionals have an unrivaled foundation of experience—creating a partnership
that you can rely on.

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     Comprehensive Service
     Pershing offers world-class financial services to support an evolving, global market.


     Today’s marketplace can no longer be defined           With Pershing as your partner, your firm has
     by national boundaries. That is why Pershing           access to enhanced solutions, which are structured
     has execution capabilities in over 65 exchanges        to support all your business needs.
     throughout the world. Our international agency
     trading services include 24-hour accessibility,        Asset Movements
     quality executions and settlement, American
                                                            Pershing has developed a workflow and rules
     depositary receipt (ADR) conversions, trading
                                                            engine-based process for all asset movements
     strategies, comprehensive month-end reporting,
                                                            initiated on our platform by your home office
     and the ability to satisfy soft-dollar obligations.
                                                            or investment professionals. These requests are
     Through our worldwide facilities, Pershing             reviewed by Pershing and directed for further
     provides integrated, multilingual, multicurrency       review by your firm, or Pershing, as determined
     capabilities, including execution, clearing,           by the rules violations and workflow routing.
     settlement, custody, and reporting services            All actions taken are detailed in the requests
     for all types of transactions.                         audit trail and can be viewed by all NetExchange
     > Equities Processing                                  Pro® users, Pershing’s online brokerage platform,
                                                            with transaction information available in Work
     > Fixed and Variable Annuities
                                                            History on NetExchange Pro for up to two years
     > Fixed Income Processing                              after processing.
     > Money Markets
     > Mutual Funds                                         Service Center
     > Non-U.S. Dollar Processing                           Pershing’s Service Center application is a
     > Options                                              communication vehicle that provides a link
                                                            between your front and home offices, and
     We offer you the expertise and reliability of          between your firm and ours. This tool provides
     the industry’s largest provider, serving more          transparency and accountability to service requests
     than 1,150 financial organizations, independent        and inquiries. The real-time status of any request
     registered investment advisors, money managers,        or inquiry may be found on a single screen,
     and hedge fund managers. These firms operate in        providing a quick update on all outstanding items.
     more than 35 countries, with more than 100,000         Each item contains a complete, real-time audit trail
     investment professionals who collectively represent    that identifies, for each action, a user ID, and a
     over five million active investors. We have attained   date and time stamp. Lastly, we provide monthly
     this leadership position by maintaining our focus.     quality scorecards that measure the efficiency and
     With no retail network to distract us, our total       effectiveness with which these requests are handled.
     commitment centers on serving the needs of
     our customers. We work tirelessly to earn your
     trust, harmonizing control and reliability with
     innovative thinking.




4	   oper a tiona l ­ sup po rt
Compliance Solutions to Protect You and Your Business
Regulatory management and support is one of the many benefits of partnering
with Pershing.


The regulatory environment is always changing,
and we strive to help you stay ahead of the curve.                The Rules Engine™: Provides Control,
We devote considerable time and effort to sharing                 Flexibility, and Faster Executions
our knowledge and best practices in compliance                    A powerful order management tool, The Rules
with you, to help you better prepare for changes in               Engine is designed to improve the effectiveness of
the rules, and manage your risk more effectively.                 your compliance department. Operating through a
Our Chief Compliance Officer conducts quarterly                   link within our ComplianceView system, The Rules
compliance conference calls and regularly visits                  Engine addresses a variety of regulatory, credit,
customers who need a more detailed analysis.                      and business issues, and lets you set applicability

Beyond these calls and onsite visits, we offer an                 standards according to your firm’s needs. Orders

arsenal of tools to support compliance, supervisory,              that do not meet the parameters you set are

and surveillance efforts, including:                              routed to your firm for manual approval; orders
                                                                  that pass go directly for execution.
> Regular compliance Bulletins
> Periodic interactive compliance training sessions               The Rules Engine plays an important role in
                                                                  alerting you to suspicious activity of all types in
> ComplianceView®, a flexible, user-friendly
                                                                  client accounts. In addition, the AML rules allow
  system to help uncover existing or potential
                                                                  you to apply different values depending on the
  compliance problems, with reports based on
                                                                  risks that an account or a transaction may pose. If
  criteria set by your compliance department
                                                                  a rule is triggered, you will be alerted immediately
                                                                  (in real time) and allowed to review any exceptions
                                                                  relative to what you know about your client and
                                                                  the source of the funds before proceeding. It is a
                                                                  proactive, risk-based solution that helps you
                                                                  protect your business and your clients.




           “Our global expertise in legal, credit, and compliance matters is extensive. We
           strive to provide our customers with the tools, knowledge, and resources that they
           need to effectively navigate the regulatory environment in which they operate.”
                                                       —Claire Santaniello, Chief Compliance Officer




­                                                                                           y o ur­ b us i n e s s ­ wi t h o u t ­ l i m i t s ­   5
     Tools That Support the Regulatory Environment
     Pershing gives you choices. A combination of dedicated desks and electronic
     trading tools lets us customize a solution that best fits your needs.


     In addition to The Rules Engine, Pershing has a             on a daily basis. This improves FINRA’s ability
     variety of regulatory systems in place to ensure accuracy   to monitor the NASDAQ market for violations
     and maintain standards for your business.                   of the investor protection rules. If your firm is an
                                                                 OATS reporting member, and you have designated
     Trade Reporting and                                         Pershing to report on your behalf, Pershing will
     Compliance EngineSM (TRACESM)                               submit OATS reports for orders entered on the
     Pershing can report to TRACE on behalf of any               Pershing platform for further order handling.
     firm that either inputs trades into NetExchange
     Pro, or delivers to Pershing real-time messages. We         Sophisticated AML Review Programs
     also maintain a dedicated computer-to-computer              We provide a robust AML review program utilizing
     interface connection to TRACE, providing the                industry-leading Actimize™ software. Actimize is
     real-time trade matching monitor in NetExchange             woven into our applications, integrating a new case
     Pro that allows your firm to view all trade                 manager and providing you with a powerful AML
     submissions to TRACE. Within that monitor,                  monitoring tool and targeted, meaningful alerts.
     there are filters that allow you to view data such          Surveillance models complement existing reports
     as rejected trades, reversals, and cancellations.           and provide a risk-ranking component capable
                                                                 of being tailored all the way down to the client
     Items for Attention (IFA)                                   account attribute level. You will have access to
     Pershing’s IFA application provides notification to         an enhanced alert investigation tool, as well as
     you of important events, but for which action may           electronic workflow and audit trail.
     not be required. These events are called “items for
     attention.” For example, a client reaches age 70 ½          People Make the Difference
     which triggers the required minimum distribution.           Service is the key differentiating factor. We have
     An IPA notification will be sent to remind you of           expanded our compliance staff to improve customer
     this requirement, so that one of your investment            support. We have distinct groups of specialists to
     professionals can meet with the customer to                 help you address trading and AML issues, with
     determine the appropriate withdrawls. These                 growth now coming in privacy compliance. The
     IFAs streamline the communications process                  focus of privacy compliance is to help you comply
     between your home office and sales force.                   with different laws in different states, yet assure your
                                                                 clients of the privacy of their personal information.
     Order Audit Trail System (OATS)
                                                                 We are committed to providing you with the
     Under the OATS rules, the Financial Industry                regulatory knowledge to help you safeguard your
     Regulatory Authority™ (FINRA™) Rules 6950                   business. In addition to the alerts that The Rules
     through 6957, member firms that receive and/or              Engine generates, we encourage you to call us with
     handle orders in NASDAQ® equity securities,                 any questions about suspicious activity on behalf
     are required to develop a means to capture                  of your clients.
     information on specific order events and to
     report that information electronically to FINRA

6	   oper a tiona l ­ sup po rt
Solid Resources
Pershing is committed to providing the resources needed to effectively deliver
ultimate satisfaction.


With over $900 billion in client assets under
custody, Pershing is a global leader, providing         Operational Support Stats
a comprehensive array of services that enable           > Pershing’s custody services support more
organizations and investors to move and manage           than 1,150 introducing firms and five million
their financial assets in more than 65 markets           active client accounts worldwide.
worldwide. Our core custody platform includes
online multicurrency reporting, portfolio accounting,   > Pershing’s customers initiate approximately

corporate actions servicing, and proxy services.         750,000 requests for account transfers per
                                                         year or roughly 62,000 per month.
Pershing is backed by the resources of our
parent company, The Bank of New York Mellon             > For the 2007 tax year, Pershing issued more

Corporation, whose principal subsidiary, The             than three million tax statements.

Bank of New York Company, founded in 1784,              > Pershing prints and mails over five million
is the oldest bank in the United States. The Bank        statements on a quarterly basis.
of New York Mellon has over $1 trillion in assets
under management and more than $23 trillion in
assets under custody and administration. The Bank
of New York Mellon is a global leader in providing
services that enable institutions and individuals to
move and manage their financial assets in more
than 100 markets worldwide.




­                                                                              y o ur­ b us i n e s s ­ wi t h o u t ­ l i m i t s ­   7
     Investor Services That Help You Maximize Efficiency
     Custody today encompasses a range of solutions to help you measure and manage risk.
     Pershing strives to enhance efficiencies for you through our investor services.


     Portfolio Evaluation Service® (PES®)                     Dividend Bond and Interest Processing
     We provide the necessary data to enable you to           We provide you with cash flow projections,
     assist your clients in assessing their portfolios,       enabling you to easily manage your clients’ funds.
     quantifying gains and losses, and determining the        With dividend and income processing services
     impact of current market conditions. PES empowers        for all types of securities, payments are processed
     you and your clients to determine if the portfolio s     to client accounts on the payable date, regardless
     meeting the agreed-upon investment objectives. PES       of whether the funds were collected, in order to
     offers tools such as tax-lot accounting, allowing you    provide immediate access to those funds. Pershing
     to more easily identify profit and loss situations. It   also offers an Equity Dividend Reinvestment
     also assists your clients in monitoring their current    Program that provides you with the option to
     and potential tax liabilities.                           purchase additional shares of equities or closed-
                                                              end funds for your clients, based on the entitled
     Global Corporate Actions                                 cash dividend and capital gain distribution due
                                                              on the payable date.
     Here at Pershing, we receive information on
     corporate actions from various services, depositories,
     and custodians. Information is provided to you via       Proxy Voting
     NetExchange Pro, where you can view the terms            For increased convenience, we provide you with
     of the offer, critical dates, affected positions, and    proxy and shareholder materials and the ability
     submit elections. Your responses are monitored           to submit your voting instructions by mail, phone,
     to track elections and minimize risk.                    or online. We also provide you with the option
                                                              to consolidate and redirect proxies on behalf of
                                                              your clients.




8	   oper a tiona l ­ sup po rt
Extensive Billing and Reporting Services
Leave the details to us—we have created clear and comprehensive reporting services.

The most visible aspect of your relationship with                                             We also offer extensive and customizable billing
your clients is the monthly or quarterly statements                                           support. For financial organizations that offer
they receive. We take that responsibility very                                                managed accounts, our Customer Billing Support
seriously. Our statements—streamlined to let your                                             (CBS) system lets you create an unlimited number
clients focus on what is important to them—have                                               of fee schedules that can be customized at the firm,
consistently been rated “Excellent” by DALBAR,                                                office, investment professional, or account level. Fee
as among the best in our industry.                                                            schedules can be individually defined for advanced
                                                                                              billing or amounts outstanding, with multiple
A simple, attractive, and practical way to keep
                                                                                              billing cycle options.
track of financial activity, clients can see the value
of their accounts, view activity summaries, review                                            Our vast reporting capabilities are extended through
their portfolio holdings, and much more. For added                                            our tax-reporting services. As an active member
convenience, our SelectLink® service combines                                                 of the Securities Industry and Financial Markets
statements delivered to a client’s household into one                                         Association (SIFMA) committee pertaining to tax
envelope, to avoid sending multiple envelopes, and                                            compliance and retirement plans, Pershing retains
provides a consolidated account summary page.                                                 external counsel and accounting firms to assist
                                                                                              and ensure compliance with all applicable tax laws
Helping You Be More Efficient                                                                 and regulations. Pershing generates a substitute
                                                                                              Form 1099 for investors, consisting of reportable
To facilitate your own internal record keeping,
                                                                                              information, as well as nonreportable information,
we offer SelectView® service. SelectView delivers
                                                                                              with a consolidated statement also generated to
all your clients’ statements on a single CD-ROM,
                                                                                              provide cost-basis information. Additionally,
for convenient and efficient storage, as well as
                                                                                              Pershing provides the ability to supply downloads to
rapid sorting and retrieval of information.
                                                                                              TurboTax®, for even greater tax-reporting efficiency.
Also designed to streamline record keeping,
e-Document Suite™ enables you to access copies
of your clients’ statements, trade confirmations,
and 1099 tax statements electronically through
NetExchange Pro, or a separate stand-alone web site.1




1
    The stand-alone e-Document Suite web site is only accessible to those firms that do not use NetExchange®. Firms using NetExchange cannot access this web site.
    All e-Document Suite features are available through both the stand-alone web site and NetExchange.




­                                                                                                                                    y o ur­ b us i n e s s ­ wi t h o u t ­ l i m i t s ­   9
          A Forward-Focused Approach
          Staying at the forefront of our business enables us to provide services that strengthen
          your competitive position.


          Every day, we challenge ourselves to meet                                           The Pershing Advantage
          higher standards—more efficient processes,                                          Pershing’s operational support encompasses nearly
          greater capacity, and expansion of the straight-                                    70 years of experience and includes the solutions
          through environment to accommodate an ever                                          on which our firm was founded. We recognize the
          widening range of processes—passing the cost                                        need to provide faster, better, and easier solutions
          savings on to you.                                                                  to compete in an aggressive marketplace. When you
          Pershing also acts as your change management                                        partner with Pershing, you gain not only the depth
          partner with a wide range of regulatory bodies,                                     and breadth of our experience, but also the ability
          holding more than 250 membership positions on                                       to benefit from financial services that are tailored
          approximately 150 industry committees, boards,                                      to meet your needs.
          and task forces.




          Pershing LLC, a subsidiary of The Bank of New York Mellon Corporation. Member FINRA, NYSE, SIPC. Trademark(s) belong to their respective owners.
          For professional use only.



	   10	   oper a tiona l ­ sup po rt
Your Business Without Limits               TM




This is a partnership focused on your success. To learn more about our operational support services,
call us at (866) 355-5556 or visit us online at www.pershing.com.
About Us
Pershing LLC (member FINRA, NYSE, SIPC) is a leading global provider of financial business solutions to more than 1,150 institutional and retail financial
organizations and independent registered investment advisors who collectively represent over five million active investors. Financial organizations, investment
professionals, and independent registered investment advisors depend on Pershing’s depth of experience and consultative approach to provide them with
forward-thinking solutions that help them to grow their businesses. Located in 19 offices worldwide, Pershing is committed to delivering dependable operational
support, robust trading services, flexible technology, an expansive array of investment solutions, practice management support, and service excellence. Pershing
is a member of every major U.S. securities exchange and its international affiliates are members of the Deutsche Börse, the Irish Stock Exchange, and the London
Stock Exchange. Pershing LLC is a subsidiary of The Bank of New York Mellon Corporation. Additional information is available at www.pershing.com.




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                                                                                                                                                            CCB-PER-OS-10-08

				
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