Kellerhals Ferguson Kroblin PLLC 9100 Port of Sale Mall. Suite 15. St. Thomas, VI 00802-3602 340 779 2564 Telephone I 1 888.316 9269 Fax I www kellfer com MEMORANDUM To: Darren K. Indyke Cecile deJongh Jeanne Brennan From: Erika A. Kellerhals Re: IBE Reporting Date: October 7, 2015 Re: International Banking Entity Record Keeping and Reporting Requirements To comply with the Rules and Regulations of the International Banking Center Regulatory Act (the "Rules and Regulations"), all International Banking Entities ("IBEs") in the U.S. Virgin Islands must submit quarterly and annual reports to the Director of Banking and Insurance of the Office of the Lieutenant Governor of the U.S. Virgin Islands (the "Director"). To assist you with this process, we have prepared guidelines for the proper record keeping and reporting practices according to the Rules and Regulations as set forth in the V.I. Code (the "Code") and included a chart of deadlines that you need to comply with. A. Keeping Records • Books & Records Requirements The Rules and Regulations require that each IBE keep accounts and records of all transactions that it completes in its normal course of operations. The original accounting books and records should be kept in the IBE's place of business in the U.S. Virgin Islands, and should include a balance sheet, income statement, statement of cash flow, and statement of changes in capital. All entries must be written in ink, typewritten, electronically typed then printed, or printed in some other legible form. The IBE's accounting books and records must be the IBE's alone, separate from those of any other person, including the person of which the IBE is a unit or subsidiary. • Investor Accounts Records of investor accounts must include at minimum the account number and the name, physical address, mailing address, and occupation of any investors. Records of lending transactions and other extensions of credit must include this same inform