Bank One Corporation - Page 50

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          analyst (who would compile the information and prepare a written            
          analysis), a junior credit officer, and a senior credit officer.            
          The credit officers also would consult with the relationship                
          managers and marketers before assigning a risk classification.              
               FNBC’s credit officers set a potential counterparty’s risk             
          class rating by first referencing the counterparty’s public debt            
          rating.  FNBC could rate a counterparty differently than its                
          public debt rating but generally did not give the customer a risk           
          class rating higher than its public debt rating.                            
                         c.  Review of Risk Classifications                           
               FNBC regularly reviewed the credit ratings of its customers.           
          Credit officers and relationship managers would regularly review            
          the customer’s financial statements and news reports relating to            
          the customer and would hold discussions with the customer.                  
          Reviews would also occur each time the customer sought additional           
          credit which was not covered by established credit limits.                  
          Formal credit reviews of each customer would occur at least                 
          annually.                                                                   
               The credit risk classifications were reviewed both                     
          internally and externally.  Internally, a unit of the bank known            
          as “Credit Process Review” (CPR) would review the ratings                   
          assigned by the credit officers and the thoroughness of their               
          analysis.  CPR did not always agree with the ratings and the                
          analysis of the credit officers and would sometimes upgrade or              






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Last modified: May 25, 2011