[C;OEMT NAME] SSN. Form 709—United States Gift (and Generation-Skipping Transfer) Tax Return Tax Year xxxx STATEMENT I On [DATE], [NAME OF CLIENT] B (the "Donor") transferred 100% of his interest in and to Account No. [ ] at [NAM EOF INSTITUTION], to [NAMES OF TRUSTEES], as Trustees of the [NAME OF GRAT] GRAT No. 1 created pursuant to a First Written Direction dated [DATE] ("GRAT No. 1") under the the [NAME OF GRAT] GRAT Agreement dated [DATE]. Copies of the First Written Direction and said Master Trust (together, the "Trust Instruments") are annexed as Exhibit A to this Statement. Under the terms of the Trust Instruments, the Donor retained the right to receive from GRAT No. 1 an annual annuity payment equal to 54.39% of the initial fair market value of the property transferred to GRAT No. 1 for a period of 2 years from the date of the Trustee's receipt of such property. The annuity payments are payable to the Donor (or if he is not then living, to the Donor's estate) until the second anniversary of the funding of GRAT No.1, at which time the remaining assets of GRAT No. 1, after payment of the final annuity amount, will pass to the remainder beneficiaries as provided in the Trust Instruments. The Donor's retained interest is a qualified annuity interest within the meaning of the Treas. Reg. §25.2702-2(a)(6). The interest rate in effect under Section 7520 of the Internal Revenue Code on [DATE]was 5.8%. The fair market value of the property transferred to the GRAT No. 1, as described above, on [DATE]was $ . The value was determined by [NAM EOF INSTITUTION], A copy of the valuation report provided by [NAM EOF INSTITUTION], is attached as Exhibit B to this Statement. The Donor computed the amount of the gift in accordance with Treas. Reg. §25.2512-5(d)(1) & (2), which provides that the value of the gift is the value of the property transferred less the value of the Donor's retained interest. The value of the Donor's retained interest in G