Endowment Policy Purchasing Company Limited

PO BOX 559 T +353 1 224 4000 Dame Street F +353 1 671 6561 Dublin 2 Settlement Agreement between the Central Bank of Ireland and The Endowment Policy Purchasing Company Limited The Central Bank of Ireland (“the Central Bank”) has entered into a Settlement Agreement with effect from 9 November 2010 with The Endowment Policy Purchasing Company Limited (“the firm”), a regulated financial services provider, in relation to breaches of regulatory requirements contained in the Investment Intermediaries Act, 1995 (“IIA”), the Client Asset Requirements (“CAR”) and the Handbook for Authorised Endowment Policy Traders (“Handbook”). The 7 breaches identified comprised of the firm failing to maintain adequate controls and accounting systems to facilitate effective management and to ensure it was in a position to satisfy supervisory and reporting requirements. In particular:-  Failure to properly designate the firm’s internal record of its client account;  Failure to obtain a required confirmation from an eligible credit institution, prior to lodging client monies, that the funds are held by the firm as a trustee and will be dealt with in a prescribed manner;  Failure to carry out daily calculations of client monies in accordance with regulatory requirements and failure to notify the Central Bank that it had not performed the daily calculations;  2 instances of failure to correct an error identified during the reconciliation process as soon as possible, and a failure in both instances to notify the Central Bank of such error;  Failure to provide annual statements to clients.