Calculating Lending Limits

COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF BANKING 333 Market Street, 16th Floor Harrisburg, PA 17101-2290 CORPORATE APPLICATIONS (717) 783-2253 Fax (717) 787-8773 May 13, 2004 Dear : This letter responds to the notification letter you submitted on behalf of [redacted] (the “Bank”), a Pennsylvania State-chartered Bank, to the Pennsylvania Department of Banking (the “Department”) regarding the Bank’s proposal to calculate its legal lending limit on a quarterly basis as permissible for a national bank, pursuant to the authority granted by Section 201(c) of the Banking Code of 1965, 7 P.S. § 201(c)(“Parity Authority”). Specifically, the Bank intends to utilize the authority granted to national banks at 12 C.F.R. § 32.4 in order calculate the Bank’s legal lending limit on a quarterly basis. Please be advised that the Department does not object to the Bank calculating its lending limit on a quarterly basis as described above, pursuant to Parity Authority. The Department’s non-objection is based upon the facts and representations as stated in the Bank’s April 16, 2004, notice letter and the Bank Parity and Subsidiary Notice form provided to the Department. Any changes in the facts could result in an amendment or reversal of the Department’s non-objection. Additionally, the Department will review the Bank’s lending limit calculation and will continue to exercise its regulatory authority and may take actions as deemed appropriate to ensure the safety and soundness of the Bank. I trust this letter is responsive to your request. Please contact Joseph A. Moretz, Manager of Corporate Applications, of this office should you require additional explanation or information regarding this matter. Very truly yours, Timothy J. Blase Director – Bureau of Supervision and Enforcement TJB:JAM:kse cc: Joseph A. Moretz Carter D. Frantz, Esq.