February 9, 2014 Ms. Jennifer Nugent-Hill ACE)/Chief Operating Officer United States Virgin Islands Economic Development Authority 8000 Nisky Shopping Center Suite 620 St. Thomas, USVI 00802 Dear Ms. Nugent- Hill, This is in response to your Compliance Review Report dated January 31, 2014 received via U.S. Post on February 5, 2014, for Financial Trust Company, Inc. (FTC) As Of December 31, 2008 and As Of March 23, 2012. As instructed in your cover letter we are providing a response to the Compliance Report as we are not in agreement with your findings. Our response are as noted herein. Report covering the Period January 1, 2007 to December 31, 2008 The Beneficiary did not comply with the requirements of procurement process Your report concludes that FTC did not comply with procurement requirements. We provide the following. We strongly assert that FTC is a responsible EDC Citizen and take our obligation to the Virgin Islands community very seriously. FTC has always supported the premise on which the Economic Development Council (EDC) Program was founded and makes the utmost effort to support local Virgin Islands business. We note that in many instances our procurement of local goods would allow us to purchase off-island to be more cost effective, while falling within the procurement rules, however we have never purchased goods or services to save money at the expense of local Virgin Islands businesses. Any procurement with a Non-Virgin Islands supplier was due to circumstances that goods and service were not available locally. Your findings provide a summary of expenditures as provided in our annual report. However we believe your analysis is skewed as the report findings do not break out exempt procurements under Section 708-706 4. - Contracts for professional services. Although you do not take exception to procurement for the period January 1, 2009 to March 23, 2012 we provide these expenditures in our analysis as it demonstrates and