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personnel. FNBC did not include the total amounts of these costs
but only the portions needed to manage its existing portfolio.
FNBC’s administrative costs adjustments for the front office may
also have included hedging expenses.
2. Amounts From Other Areas of FNBC
FNBC’s administrative costs adjustment for swaps also
included costs from other departments, including: (1) Computer
systems; (2) accounting; (3) facilities management; (4) credit
process review department; (5) corporate staff from other
departments; (6) systems development; (7) general manager;
(8) service products group; (9) risk management administration;
(10) financial analysis; (11) corporate and institutional
banking; and (12) other service charges. These costs, to the
extent allocated to swaps and interest rate guarantees, included:
(1) Charges from FNBC’s law department, audit department, data
processing center, allocable rent (occupancy area), cost to hedge
the swaps in existence to maturity, and telephone costs;
(2) charges from FNBC’s credit policy group, which set policy on
all customer credit transactions, including loans, leasing
products and derivatives; (3) charges from management for the
credit policy group in addition to other charges from the credit
department of FNBC; (4) charges from FNBC’s treasury management
group which was responsible for corporate customer cash and other
accounts; (5) charges from FNBC’s facilities management section,
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