1. Data Problems and Requirements:Transparency Across Products, Markets, and Legal Entities American Association for Budget and Program Analysis Thomas Day Managing Director, Risk and Policy, SunGard Ambit Financial Solutions 18-May-2010

2. Broad Bank and Bank Supervisory Trends Major consolidation over the course of the last twenty years Since 1990, the number of banks have declined by 7,146 institutions Since 2001, the number of banks have declined by 1,735 Total assets have increased From approximately ~$4.0 trillion as of FYE-1991 to a FYE-09 level of $13.1 trillion Supervisory staff have declined FDIC staff only: A 1991 level of 22,586 to a 2009 level of 6,558 (~+1,500 from 2008/2009), or approximately $2,000 million per employee versus 1991 level of ~$177 million per employee

3. Financial Mega-Trends and Issues The 1990’s saw a rapid increase in: Use of Derivatives Structured Products Increased Use of Securitization Disintermediation of deposits (more wholesale $’s) Rapid Increase in Technological Advances Increases in productivity Wider distributions of risk across geographies and investor type Increased use of models in order to “sell” complexity Wider bid/ask spreads Greater faith in financial engineering Stability v. instability Period of relative calm and steady growth Much greater belief in the “fine tuning” of our economy

4. The Decade of “The” Bubble Beginning in 2000 and continuing through 2004, a rapid decline in O/N funds rate Well communicated increase (and slow) increase in rates.

5. To Recap We saw a significant increase in the use of technology to increase efficiencies over the last two decades Banks got bigger, risk-taking got more “scientific” Funding liquidity seemed endless Products became more complex Competition, globally, became more intense Economies-of-scale seemed to “rule” and “diseconomies” of scale were “inconceivable” in banking My experience: Multiple source systems Legacy data problems Inability to pull current position balance sheets together Inability to evaluate, plan and budget over such a large book Governance by volume and performance, not by risk

7. Systemic Risk Monitoring one-bank at a time is necessary, but not sufficient Horizontal reviews of risk are necessary Image/idea: The entire country’s financial system as a series of cash flows, some more volatile to macro- and micro-shocks that others The SCAP stress-test was a good, albeit painful, proxy for this “idea” Comptroller Dugan: “Bank information systems are not designed to aggregate information in this way on a regular basis. Much improvement is needed in these systems…but until strides are made, comprehensive stress-testing will remain very difficult.””…the issues I’ve just mentioned make me reluctant to begin conducting such tests routinely as the cornerstone of our supervision.” (also stressed PFRs shouldn’t disclose the results) – April 15, 2010 at the Richmond FRB

8. Stress-Test Result: Similar to Evaluating Loss Coverage in a Securitization

9. Data Needs Lessons Learned: Data quality at our large, systemically important financial institutions is largely in need of vast improvement The modeling issues confronting the supervisory teams (economists and examiners) during the stress-test should not be “rare” or “unique” Enterprise-wide stress testing should be common and ubiquitous Large firms should be able to defend their stress-tests and the supervisors need adequate tools to assess the inherent quality and robustness of internal tests A “debate and confirm” atmosphere would be healthy FDIC fees should have a relationship to the potential volatility of DI assets We live in a 21st century world without 21st century data-management expectations This has to change. There are already some excellent examples.

10. Data Requirements Standards Flexibility Scalability Practicality Portability Thanks to Mark Flood, http://papers.ssrn.com/sol3/papers.cfm?abstract_id=924618 See also: http://www.ce-nif.org/about-us The NIF/OFR needs to proceed to ensure sustained improvement in EWRM at our TBTF institutions You can’t manage what you can’t measure …and you don’t get improved data standards without a standard setter

11. Regulatory Change: Liquidity and Capital Liquidity Risk Management BCBS, SSG, IIF and Domestic Regulators Key areas of focus will be: The forgotten “dark art”: asset liquidity = “counterbalancing capacity” = liquidity buffer Cash-flow based stress-testing (forward looking) Contingency funding plans Capital Adequacy What is capital? The “definition of capital” work-stream at the international level is a top priority. Are you prepared? Counter-cyclical rather than pro-cyclical capital International convergence on a “leverage” ratio standard

12. Regulatory Change: Transparency and Disclosure Transparency The Office of Financial Research (OFR) CMSA IRP, ALERT, FpML, Project RESTART as examples The EDM Council and various types of mark-up languages SEC proposed rule AB Covers all private label 144-A transactions Loan-level (collateral) detail Computer code for the waterfall registered and available “No more secrets” The return of the “3-6-3” “2-5-2” rule?

13. Conclusion Thank You thomas.day@sungard.com

14. Data Problems and Requirements:Transparency Across Products, Markets, and Legal Entities For more information: thomas.day@sungard.com For Analyst Relations: nicole.rowe@sungard.com