FICO Assessments . The Financing Corporation (“FICO”) is a mixed-ownership governmental corporation  chartered by the former Federal Home Loan Bank Board pursuant to the Competitive Equality Banking Act of 1987  to function as a financing vehicle for the recapitalization of the former Federal Savings and Loan Insurance  Corporation. FICO issued 30-year noncallable bonds of approximately $8.1 billion that mature in 2017 through  2019. FICO’s authority to issue bonds ended on December 12, 1991. Since 1996, federal legislation has required  that all FDIC-insured depository institutions pay assessments to cover interest payments on FICO’s outstanding  obligations. These FICO assessments are in addition to amounts assessed by the FDIC for deposit insurance. During  the year ended December 31, 2012, the FICO assessment rate was approximately 0.0066%, which reflects the change  from an assessment base computed on deposits to an assessment base computed on assets as required by the Dodd- Frank Act.  Supervisory Assessments . National banks are required to pay supervisory assessments to the OCC to fund the  operations of the OCC. The amount of the assessment is calculated using a formula that takes into account the bank’s  size and its supervisory condition. During the year ended December 31, 2012, the Bank paid supervisory assessments to  the OCC totaling $161,000.  Capital Requirements. Banks are generally required to maintain capital levels in excess of other  businesses. For a discussion of capital requirements, see “—The Increasing Regulatory Emphasis on Capital” above.  Dividend Payments. The primary source of funds for the Company is dividends from the Bank. Under the  National Bank Act, a national bank may pay dividends out of its undivided profits in such amounts and at such times as  the bank’s board of directors deems prudent. Without prior OCC approval, however, a national bank may not pay  dividends in any calendar year that, in the aggregate, exceed the bank’s year-to-date net income plus the bank’s retained  net income for the two preceding years.  The payment of dividends by any financial institution is affected by the requirement to maintain adequate  capital pursuant to applicable capital adequacy guidelines and regulations, and a financial institution generally is  prohibited from paying any dividends if, following payment thereof, the institution would be undercapitalized. As  described above, the Bank exceeded its minimum capital requirements under applicable guidelines as of  December 31, 2012. As of December 31, 2012, approximately $2.0 million was available to be paid as dividends by the  Bank. Notwithstanding the availability of funds for dividends, however, the OCC may prohibit the payment of  dividends by the Bank if it determines such payment would constitute an unsafe or unsound practice.  Insider Transactions. The Bank is subject to certain restrictions imposed by federal law on “covered  transactions” between the Bank and its “affiliates.” The Company is an affiliate of the Bank for purposes of these  restrictions, and covered transactions subject to the restrictions include extensions of credit to the Company,  investments in the stock or other securities of the Company and the acceptance of the stock or other securities of the  Company as collateral for loans made by the Bank. The Dodd-Frank Act enhances the requirements for certain  transactions with affiliates as of July 21, 2011, including an expansion of the definition of “covered transactions” and  an increase in the amount of time for which collateral requirements regarding covered transactions must be  maintained.  Certain limitations and reporting requirements are also placed on extensions of credit by the Bank to its  directors and officers, to directors and officers of the Company and its subsidiaries, to principal stockholders of the  Company and to “related interests” of such directors, officers and principal stockholders. In addition, federal law  and regulations may affect the terms upon which any person who is a director or officer of the Company or the Bank,  or a principal stockholder of the Company, may obtain credit from banks with which the Bank maintains a  correspondent relationship. Safety and Soundness Standards. The federal banking agencies have adopted guidelines that establish  operational and managerial standards to promote the safety and soundness of federally insured depository  institutions. The guidelines set forth standards for internal controls, information systems, internal audit systems, loan  documentation, credit underwriting, interest rate exposure, asset growth, compensation, fees and benefits, asset  quality and earnings.  In general, the safety and soundness guidelines prescribe the goals to be achieved in each area, and each  institution is responsible for establishing its own procedures to achieve those goals. If an institution fails to comply  with any of the standards set forth in the guidelines, the institution’s primary federal regulator may require the  22 