it - KELLERHALS FERGUSON FLETCHER KROBUN LLP March 21, 2013 Via Hand Delivery Mr. John McDonald Director Office of the Lieutenant Governor '1; Insurance DATE STAMPED COPY Re: International B Act Dear Mr. McDonald: Enclosed please fmd the updated application for permission to organize an International Banking Entity (`IBE") filed on behalf of Financial Strategy Group, Ltd. ("FSG"). FSG respectfully requests, in addition to a waiver of the employment requirement which is discussed in Appendix 11, that it be permitted to commence business with authorized shares of 1,000,000 with a par value of $1.00 of which at least 100,000 shares shall be issued upon incorporation and $100,000.00 of capital will he fully paid in at the time the license is issued. We previously submitted the required application fee. Please do not hesitate to contact me should you have any questions. Very truly yours, Erika Kellerhals TAMPA U.S. VIRGIN ISLANDS NEW YORK EFTA00606417