Key Recommendations and Findings to FirstAmerica Bank Board of Directors

| May 21, 2014

First America Bank (FAB) needs to return its fees from The Poseidon Cruise Line (PCL) transaction brokered by Linda. FAB’s fees were excessiveand resulted from willfully misleading PCL. Although there exists no profit gauging regulations to protect customers from abusive derivative trade institutions, this transaction by FAB crosses the line of ethical corporate citizenship to “do no harm to the clients we represent.”

Linda took advantage of PCL’s misguided trust and created an asymmetrical information advantage for herself, thus clearing the way to charge excessive transaction fees. As an institution that truly values our customer base and the opportunity for repeat business, FAB cannot knowingly profit from this type of questionable transaction.In an effort to deter similar situations from occurring in the future, we propose the following stopgap measures be implemented at FAB:

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