ir KELLERHALS FERGUSON FLETCHER KROBLIN LLP January 9, 2012 Mr. John McDonald Director Office of the Lieutenant Governor Division of Banking & Insurance 5049 Kongens Gade St. Thomas, VI 00802 Re: International Banking Center Regulatory Act Dear Mr. McDonald: 9100 HAVENSIGHT SUITE 15 ST. T FAX Enclosed please find an application for benefits as an International Banking Entity ("IBE") filed on behalf of Financial Strategy Group, Ltd. ("FSG"). We have reviewed the statute closely and have provided all information that is statutorily required in order for the application to be considered. Specifically we have included: • Proposed articles of incorporation; • Identity and business history of applicant/shareholders of FSG; • Location of principal place of business within the USVI; • Statement of assets and liabilities of the shareholders; • The identity and background of all proposed directors and officers; • Confirmation of statutory commitments • Request for waiver of the employment requirement; and • Draft management training plan; • Description of business to be undertaken by FSG. I have also enclosed check number in the amount of Ten Thousand Dollars ($10,000.00), which represents the non-refundable application fee. Please contact me if you have any questions regarding the enclosed information. Very truly yours, Erika Kellerhals TAMPA U.S. VIRGIN ISLANDS NEW YORK EFTA01104771