Copyright, 2013 by Bretton Woods, Inc. ALL RIGHTS RESERVED. Any use of text, graphics, and analyses materials, including reproduction, modification,

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1 Copyright, 2013 by Bretton Woods, Inc. ALL RIGHTS RESERVED. Any use of text, graphics, and analyses materials, including reproduction, modification, distribution or republication, without the prior written consent of Bretton Woods, Inc., is strictly prohibited.

2 Table of Contents Overview... 3 Methodology... 5 Findings... 7 Cost Trends... 8 Comparative Cost Analysis... 9 Summary Final Thoughts Mobile Wallet Disclosures Exhibit I Philadelphia Fed Prepaid Card Transaction Study Exhibit II - Data Sources Exhibit III Cost Comparison Exhibit IV Market Share Bretton Woods, Inc. Page 2

3 Overview This is the fourth annual report in which Bretton Woods analyzes and updates the various financial transaction products available. It is a report that looks at the average consumer costs associated with utilizing general purpose reloadable (GPR) prepaid cards (issued by highly regulated financial institution, bearing network brands of Visa, MasterCard, Discover and American Express), and good wherever these brands' debit cards are accepted, low balance checking accounts and services for cash-based lifestyles. The legacy of the prepaid industry is an alternative to other financial services available to low income consumers. We have captured a comparison to low balance checking accounts and cash based services but this year we have expanded the report with primary data from program managers and an issuing bank to show a customer cost stratification amongst prepaid card users. This is because GPR cards have been adopted by higher income segments, younger consumers and banked consumers. This year the report compares the costs of basic checking accounts, general purpose reloadable prepaid cards, and using cash, to conduct a basic level of financial transactions based on the Consumers Union suggested transaction pattern. While we have kept the basic transaction profile suggested by Consumers Union, we made the following modifications: Altered the POS transactions to 2/3 signature and 1/3 PIN to better align with actual usage derived from the Philadelphia Fed study Added two annual overdrafts for a total of seven based on updated data from Moebs Services 1 This is the only report of its kind that examined actual customer costs using program manager and issuing bank data. The key finding is that a majority of consumers pay less than $7.50 per month for a transaction product that provides similar safety and functionality as a traditional bank checking account. These costs are reflected in the following manner: Mean and median monthly fees paid by consumers A consumer cost stratification showing the percent of consumers whose monthly fees are: o < $7.50 o $ $10.00 o $ $15.00 o $ $20.00 o > $20.00 o Fee/Spend ratio for each strata The fee/spend ratio is enlightening as it depicts the cost per dollar spent. The analysis was modified this year to include basic checking costs, both with and without direct deposit, because new fee structures make this a significant cost differential for the consumer. 1 Moebs Services, Retrieved from Billion Bretton Woods, Inc. Page 3

4 The results can be compared to the annual Consumer Union report which now ranks individual cards based on their criteria. The report incorporates the following data from select program managers and the Philadelphia Fed study 2, Consumers Use of Prepaid Cards: A Transaction-Based Analysis, which analyzes the actual transaction profile and costs incurred by cardholders provided by Meta Payment Systems. 2 Wilshusen, S., et al, Federal Reserve Bank of Philadelphia, Consumers Use of Prepaid Cards: A Transaction Based Analysis, (2012). Retrieved from: Bretton Woods, Inc. Page 4

5 Methodology As in past years, this analysis looks at the Consumers Union transaction profile used in their reports on prepaid cards 3. The transaction set is: Transaction Type Monthly Transactions Annualized Transactions ATM Withdrawals 3 36 Bill Payments 3 36 Point of Sale 8 96 Balance Inquiries 4 48 Deposits 2 24 An analysis of prepaid card usage is only as good as the assumptions made regarding how the consumer uses the card. To determine the typical consumer transaction pattern, Bretton Woods conducted an independent review with input from prepaid card providers and third party sources. We also considered the results of the Philadelphia Fed prepaid card study released in (See Exhibit I). The middle or third quintile transaction pattern is significantly lower than the proforma Consumers Union pattern. Transaction Type Web GPR Monthly Transactions 3 rd Quintile Annualized Transactions (Rounded) ATM Withdrawals Transactions Loans/Deposits Transaction Type Retail GPR Monthly Transactions 3 rd Quintile ATM Withdrawals Transactions Loans/Deposits Annualized Transactions (Rounded) This study indicates that there are a group of prepaid card users that have relatively few transactions (first quintile) and do not reload their cards. On the other end of the spectrum, there are users (fifth quintile) that have a much higher transaction usage. We continued to use the Consumer Union (CU) transaction model for annual comparative purposes and altered the POS transactions to 2/3 signature and 1/3 PIN to better align with actual usage derived from the Philadelphia Fed study. Transaction Type GPR Annualized Transactions Bank Annualized Transactions ATM Withdrawals In Network 7 30 Out of Network 29 6 Bill Payments Point of Sale Signature PIN Balance Inquiries Deposits Overdrafts Bretton Woods, Inc. Page 5

6 In previous reports, we only added five annual overdrafts to the transaction profile. This was quite conservative given annual analyses from Moebs Services. This year, we modified that number to seven, which was derived from this analysis. 4 Exhibit III documents the banks sampled and the source of the product and pricing data. They were chosen for regional and national significance and represent 43% (Exhibit IV) of the total deposits in the United Stated. Bretton Woods chose the entry level, or basic checking product, from each bank in order to compare their lowest cost product to GPR prepaid cards. These basic checking accounts have monthly fees that range up to $13.95 but can be avoided with a recurring direct deposit or a daily minimum balance of up to $1,500. The typical consumer of a GPR prepaid card maintains a balance of less than $ The fee schedules for banks, major providers on general purpose reloadable prepaid cards and check cashing services were obtained via their web sites on December 21, For cards without direct deposit, third party fees (MoneyGram, Western Union, Green Dot Money Pak, REloadit and Visa ReadyLink) are applicable for reload fees Billion?WT.qs_osrc=fxb Network Branded Prepaid Card Association Bretton Woods, Inc. Page 6

7 Findings Prepaid cards continue to have a cost advantage over basic checking accounts. The three-year trend shows that the average cost a consumer incurs for a checking account is increasing, while decreasing for GPR prepaid cards. At the low end of the scale, operating in a cash environment has a somewhat lower cost due to low cost cash services provided by companies like Wal-Mart 6. However, the hard dollar cost does not reflect the lack of security risks of carrying cash and the inconvenience of buying money orders to pay and mail bills. TRADITIONAL COST COMPARISON Basic Checking DIRECT DEPOSIT BANK CHECKING MEDIAN $ DIRECT DEPOSIT BANK CHECKING MEAN $ NO DIRECT DEPOSIT BANK CHECKING MEDIAN $ NO DIRECT DEPOSIT BANK CHECKING MEAN $ GPR Cards DIRECT DEPOSIT GPR MEDIAN $ DIRECT DEPOSIT GPR MEAN $ NO DIRECT DEPOSIT GPR MEDIAN $ NO DIRECT DEPOSIT GPR MEAN $ PHILADELPHIA FED STUDY PHILADELPHIA FED WEB GPR MEDIAN $ PHILADELPHIA FED WEB GPR MEAN $ PHILADELPHIA FED RETAIL GPR MEDIAN $ PHILADELPHIA FED RETAIL GPR MEAN $ PROGRAM MANAGER DATA PROGRAM BATCH "A" MEDIAN $ PROGRAM BATCH "A" MEAN $ PROGRAM BATCH "B" MEDIAN $66.72 PROGRAM BATCH "B" MEAN $99.36 CASH USAGE CASH MEDIAN $ Bretton Woods, Inc. Page 7

8 Cost Trends The following chart highlights the cost trends since 2010 using the standard transaction pattern methodology. Bretton Woods, Inc. Page 8

9 New to the analysis this year is data that has been made available from key program managers on the mean and median monthly costs consumers paid in 2012 plus the fees incurred as a percent of the total dollars spent. Additionally, the analysis indicates the percent of consumers who pay under the following monthly cost strata. % of Customers Paying Program $ $ $ > Average Median < $7.50 Batch A $10.00 $15.00 $20.00 $20.00 Monthly Cost $13.75 $ % 7.1% 9.6% 6.2% 20.5% Cumulative 56.6% 63.7% 73.3% 79.5% 100.0% Program $ $ $ > Average Median < $7.50 Batch B $10.00 $15.00 $20.00 $20.00 Monthly Cost $8.28 $ % 8.8% 14.2% 9.1% 9.8% Cumulative 58.1% 66.% 81.1% 90.2% 100.0% Fees/Spend Ratio 1.6% 1.4% 1.3% 1.2% 1.3% In both groups of programs, the majority of consumers pay less than $7.50 per month ($90 annually). It is clear from both a pro-forma analysis using a standard transaction pattern and actual costs incurred by consumers, GPR prepaid cards provide a valuable and cost effective service, particularly when one analyzes the fees as a percent of the total spend. It should be noted that this comparison does not purport that this consumer has equal access to basic checking accounts. Many cannot qualify for a checking account due to being listed on ChexSystems or TeleCheck for mishandling accounts in the past. Comparative Cost Analysis On a relative basis, the prepaid card scores better than basic checking from banks. Direct deposit checking accounts cost over twice, on average, than direct deposit GPR cards while nondirect deposit checking accounts are 1.5 times more expensive. BASIC BANK CHECKING - DIRECT DEPOSIT Bank of America Essentials (with Bill Pay) $ Bank of Oklahoma Basic (with Bill Pay) $ BB&T Bright Banking $ BBVA Compass - Basic $ CitiBank Basic $ Fifth Third $ J P Morgan Chase Total Checking $ PNC Free $ Regions Lifegreen Simple $ SunTrust Everyday $ Synovus Access $ Wells Fargo $ DIRECT DEPOSIT BANK MEDIAN $ DIRECT DEPOSIT BANK MEAN $ BASIC BANK CHECKING - NO DIRECT DEPOSIT Bank of America Essentials (with Bill Pay) $ Bank of Oklahoma Basic (with Bill Pay) $ BB&T Bright Banking $ BBVA Compass - Basic $ CitiBank Basic $ Fifth Third $ J P Morgan Chase Total Checking $ PNC Free $ Regions Lifegreen Simple $ SunTrust Everyday $ Synovus Access $ Wells Fargo Value Checking $ NO DIRECT DEPOSIT BANK MEDIAN $ NO DIRECT DEPOSIT BANK MEAN $ Bretton Woods, Inc. Page 9

10 GPR PREPAID CARD - DIRECT DEPOSIT AccountNow MasterCard $ American Express Bluebird $ ApprovedCard (Suzie Orman) $ Chase Liquid $ Green Dot Visa/MC $ NetSpend Visa - FeeAdvantage $ nfinanse $ ReadyCard Visa $ RUSHCARD - Unlimited $ US Bank $ Walmart MoneyCard $ DIRECT DEPOSIT GPR MEDIAN $ DIRECT DEPOSIT GPR MEAN $ GPR PREPAID CARD - NO DIRECT DEPOSIT AccountNow MasterCard $ American Express Bluebird $ ApprovedCard (Suzie Orman) $ Chase Liquid $ Green Dot Visa/MC $ NetSpend Visa - FeeAdvantage $ nfinanse $ ReadyCard Visa $ RUSHCARD - Unlimited $ US Bank $ Walmart MoneyCard $ NO DIRECT DEPOSIT GPR MEDIAN $ NO DIRECT DEPOSIT GPR MEAN $ Exhibit II is a complete analysis with transaction detail for the banks and GPR card products surveyed and calculate their costs on a comparative basis. For 2012, the increased number of annual overdrafts and the implementation of extended overdraft charges by six of the thirteen banks impact the total costs for basic checking accounts. Pricing for GPR cards has trended down while pricing for bank accounts have trended up. The costs for GPR cards show a steady downward trend since The data from a major GPR program manager shows that actual costs incurred by consumers is less than the pro-forma numbers used for the past three years. It should be noted that there are several methods for the consumer to limit their costs for both checking and GPR cards, including using in-network ATM s, getting cash bank at the point of sale, using direct deposit and balancing their checking accounts to avoid NSF/OD fees. Bretton Woods, Inc. Page 10

11 Summary The trends are unmistakable and undeniable. General purpose reloadable prepaid cards are both serving the needs of the underbanked but are also gaining a foothold with traditionally banked consumers given the number of banks and credit unions now offering GPR cards. However, the actual usage transaction pattern is quite different from traditional checking accounts and the proforma transaction pattern based on assumptions of the minimum number and types of transactions needed to meet basic financial transaction needs of the consumer. One must also realize that traditional checking accounts are used quite differently today than, say twenty years ago. As check writing continues to decline and debit card transactions replace some cash transactions, we may actually see checking account and prepaid card activity settle on quite different transaction paradigms. Therefore, the reasons a consumer chooses a prepaid card rather than a checking account include: No pre-qualifications nor credit checks Cultural there is still distrust of banks by many consumers Convenience to purchase and reload in thousands of locations Real time pushed alerts of purchases and updated balances as well as updated information with automated phone inquiries No overdrafts unless offered by the card and accepted by the consumer A demonstrable cost advantage While similar to checking accounts, prepaid cards serve unique markets and needs and are a textbook example of the market filling a need in a responsible manner. Bretton Woods, Inc. Page 11

12 Final Thoughts Community banks, especially under $1 billion in assets, continue to struggle to devise a 21 st century business model that addresses changing consumer behavior based on generational preferences and disruptive technologies; legacy operating cost structures; artificially low interest rates contributing to interest margin squeeze and loss of fee income sources. To meet consumer demands, the Alternative Financial Services (AFS) industry continues to move forward to develop products and services outside of the traditional banking model. However, this year we have witnessed a number of banks offering direct to consumer GPR prepaid cards to both meet the evolving needs of existing consumers as well as attempt to meet the needs of the low to moderate income (LMI) consumer. The steady growth of network branded prepaid cards issues by regulated financial institutions, as an alternative to high cost checking accounts and as a way for the unbanked to gain access to the payments system, is reinforced by the 2010 Federal Reserve Payments Study 7 In a study 8 released by the Federal Reserve in the United States, 63% of unbanked consumers have a mobile phone, and 91% of underbanked consumers have a mobile phone. Underbanked consumers make comparatively heavy use of both mobile banking and mobile payments: 28% have used mobile banking and 17% have used mobile payments in the past 12 months, compared with 2% and 12%, respectively, for fully banked consumers. Regulation is having the unintended consequence of limiting the benefit of reloadable prepaid cards, especially those issued by banks with assets greater than $10 billion. The Durbin Amendment disallows the higher interchange rate afforded to prepaid cards if there is a method to access the funds beyond the card itself. The unbanked and underbanked consumers are adversely impacted by this rule if the bank chooses to retain the higher interchange fees. In essence, this eliminates the bill pay feature and any automatic debits for monthly obligations although bills can be paid by phone and on-line at the merchant site using the card data. Nearly 60 percent of banks are now offering GPR cards, according to a study by the American Bankers Association 9. Many banks have offered prepaid cards to their business and government customers for several years now. However, the following banks are a representative sample of those banks that have made news with their direct to consumer GPR card offerings: BB&T MoneyAccount 10 JP Morgan Chase Liquid Card 11 PNC SmartAccess 12 Regions Now Card 13 US Bank Convenient Cash Card 14 Wells Fargo Prepaid Bretton Woods, Inc. Page 12

13 Mobile Wallet A roundtable was conducted in December 2012 by Paybefore.com to discuss the latest trends. The participants included executives from American Express, Discover, MasterCard and Visa. The consensus of opinion was that mobile is the future but that there are still significant obstacles to address including merchant POS technology upgrades. The companies that these executives represent are actively preparing for mobile. While consumer acceptance and preferences will drive the rate of change, mobile will nevertheless happen sooner than later. Disclosures In general, GPR card providers and banks have significantly improved their fee disclosures. Most GPR card providers fee disclosures are within one click from the home page. Bank web sites vary significantly with some complete fee disclosures two or more clicks away. Bretton Woods still believes that comparing costs to fees is better for the consumer s understanding. There are sites such as nerdwallet 16 that allow consumers to estimate their true costs based on their projected usage characteristics. Both banks and prepaid card providers should make an on-line calculator available to assist consumers in their cost assessment of their products SmartAccess+Prepaid+Visa+Card/PNC+SmartAccess+Prepaid+Visa+Card aid%2f See Bretton Woods, Inc. Page 13

14 Exhibit I Philadelphia Fed Prepaid Card Transaction Study Source: Bretton Woods, Inc. Page 14

15 Exhibit II - Data Sources May, 2013 Branded Prepaid Card Report BASIC BANK CHECKING Bank of America Bank of Oklahoma BB&T BBVA Compass CitiBank Basic Fifth Third J P Morgan Chase PNC Regions WEB SOURCE f 8ffc6d630ad7/ServiceCharges_ pdf?MOD=AJPERES&amp;CACHEID=dedbb4004e5c8da 38fc18ffc6d630ad7 ng_fees SunTrust Synovus US Bank Wells Fargo GPR PREPAID CARD AccountNow American Express Bluebird The ApprovedCard Chase Liquid Green Dot Visa/MC NetSpend Visa nfinanse ReadyCard RUSHCARD US Bank Walmart MoneyCard CASH Walmart Check Cashing & Money Orders Check Cashing & Money Orders WEB SOURCE Oklahoma/en/Other/Terms_Conditions/pdf/BOKSummaryOfFeesAndDefinitions.pdf % - 5% Fees - This analysis assumes 2%. $27,041 per capita income ( Postal Money $.99. Bretton Woods, Inc. Page 15

16 Branded Prepaid Card Report Exhibit III Cost Comparison Bretton Woods, Inc. Page 16

17 Minimum Opening Balance Credit Check Balance/Other to Avoid Fees Monthly Fee Other Fees Deposit/Lo ad ATM Out-of- Network ATM One Time Per Teller Point of Sale Point of Bill Payment Debit Card Withdrawal Signature Sale PIN Fee ATM Balance Inquiries (In- Network) Call Center Inquiries or SMS Alerts First Overdraft/NS F Fee Two or More Overdraft/NSF Fees Annual Transaction Profile BASIC BANK CHECKING - DIRECT DEPOSIT Extended Overdraft Fee (1 day over limit) Deposit Advance Available? TOTAL ANNUAL COST Bank of America Essentials (with Bill Pay) $ Y $ $ 2.00 $ - $ $ $ N $ Bank of Oklahoma Basic (with Bill Pay) $ Y $ 8.90 $ 2.00 $ - $ Y $ BB&T Bright Banking $ Y $1,500 - Free With $100 Direct Deposit - $10 Monthly Fee $ 2.50 $ $ N $ BBVA Compass - Basic $ Y $1,500 - Free with Direct Deposit of $300/month $ - $ 2.00 $ $ $ N $ CitiBank Basic $ Y $1,500 - Free With Direct Deposit and 1 Bill Pay $ 2.00 $ $ N $ Fifth Third $ Y J P Morgan Chase Total Checking $ Y $1,500 - Free with Direct Deposit of $500/month $1,500 - Free With Direct Deposit $ - $ 2.00 $ $ Y $ $ - $ 2.00 $ - $ $ $ N $ PNC Free $ Y $ - $ - $ 2.50 $ - $ $ $ 7.00 N $ Regions Lifegreen Simple $ Y $ 5.00 $ 2.00 $ $ N $ SunTrust Everyday $ Y $500 or Direct Deposit - $7.00 $ 2.00 $ $ $ N $ Synovus Access $ Y $1,000 average daily balance or have $500 in Direct Deposits $ - $ 2.00 $ $ $ N $ Wells Fargo $ Y $1,500 or Direct Deposit of $500 $ 2.50 $ $ y $ BASIC BANK CHECKING - NO DIRECT DEPOSIT Bank of America Essentials (with Bill Pay) $ Y $ $ 2.00 $ $ $ $ N $ Bank of Oklahoma Basic (with Bill Pay) $ Y $ 8.90 $ 2.00 $ - $ Y $ BB&T Bright Banking $ Y $1,500 - Free With $ $100 Direct Deposit $ 2.50 $ $ N $ BBVA Compass - Basic $ Y $ $ 2.00 $ $ $ N $ CitiBank Basic $ - Y $1,500 - Free With Direct Deposit and $ $ 2.00 $ $ N $ Bill Pay Fifth Third $ Y $1,500 - Free with Direct Deposit of $500/month $ $ 2.00 $ $ Y $ J P Morgan Chase Total Checking $ Y $1,500 - Free With $ $500 Direct Deposit $ 2.00 $ $ $ N $ PNC Free $ Y $ - $ - $ 2.50 $ $ $ 7.00 N $ Regions Lifegreen Simple $ Y $ 5.00 $ 2.00 $ $ N $ SunTrust Everyday $ Y $500 or Direct Deposit - $7.00 $ 7.00 $ 2.00 $ $ $ N $ $1,000 average Synovus Access $ Y daily balance or $ have $500 in Direct $ 2.00 $ $ $ N $ Deposits US Bank $ Y $1,500 average balance or $500 Direct Deposit $ 6.95 $ 2.50 $ $ $ N $ Wells Fargo Value Checking $ Y $1,500 or Direct Deposit of $500 $ 7.00 $ 2.50 $ $ y $ Bretton Woods, Inc. Page 17

18 GPR PREPAID CARD - DIRECT DEPOSIT Minimum Opening Balance Credit Check Balance/Other to Avoid Fees Monthly Fee Other Fees Deposit/Lo ad ATM Out-of- Network ATM One Time Per Teller Point of Sale Point of Bill Payment Debit Card Withdrawal Signature Sale PIN Fee Balance Call Center Inquiries - Inquiries ATM ATM Decline or or Overdraft SMS Alerts Fee Two or More ATM Declines or Overdraft/NSF Fees Annual Transaction Profile - Modified AccountNow MasterCard N $ 2.50 $ 2.50 $ 4.95 $ 1.00 $ 1.00 $ 1.50 $ 1.00 N $ American Express Bluebird N $ - $ 2.00 N $ ApprovedCard (Suzie Orman) N $ 3.00 $ - $ 2.00 $ 3.00 $ 1.00 $ 1.00 N $ Chase Liquid $ N $ 4.95 $ 2.00 N $ Green Dot Visa/MC N $ 2.50 $ 4.95 $ - N $ NetSpend Visa - FeeAdvantage N $ 9.95 $ 2.50 $ 2.50 $ 0.50 $ 0.50 $ 1.00 $ - Y $ nfinanse N $ - $ 0.99 $ 0.99 $ 3.00 $ - $ - $ 0.49 $ 0.49 N $ ReadyCard Visa N $ 4.95 $ 1.95 $ 1.95 $ 0.25 $ 0.95 $ 0.95 N $ RUSHCARD - Unlimited N $ 5.95 $ - $ 2.50 $ 3.95 $ - $ - $ - N $ US Bank N $ 3.00 $ 3.00 $ - $ 2.00 $ 2.00 N $ Walmart MoneyCard N $ 3.00 $ - $ 2.00 $ 1.00 N $ GPR PREPAID CARD - NO DIRECT DEPOSIT AccountNow MasterCard N $ 3.95 $ 2.50 $ 2.50 $ 4.95 $ 1.00 $ 1.00 $ 1.00 $ 1.00 N $ American Express Bluebird N $ - $ - $ 2.00 N $ ApprovedCard (Suzie Orman) N $ 3.00 $ 3.50 $ 2.00 $ 2.00 $ 1.00 $ 1.00 N $ Chase Liquid N $ 4.95 $ 2.00 N $ Green Dot Visa/MC N $ 5.95 $ 4.95 $ 2.50 $ 4.95 $ - N $ NetSpend Visa - FeeAdvantage N $ 9.95 $ 2.60 $ 2.50 $ 2.50 $ - $ - $ 0.50 $ 0.50 $ 1.00 $ - Y $ nfinanse N $ 2.95 $ 2.95 $ 0.99 $ 0.99 $ 3.00 $ 0.49 N $ ReadyCard Visa N $ - $ 4.95 $ 1.95 $ 1.95 $ 0.25 $ 0.95 $ 0.95 N $ RUSHCARD - Unlimited N $ 7.95 $ 3.74 $ - $ 2.50 $ 3.95 $ - $ - $ - N $ US Bank N $ 3.00 $ 3.00 $ - $ 2.00 $ 2.00 N $ Walmart MoneyCard N $ 3.00 $ 3.00 $ - $ 2.00 $ 1.00 N $ CASH Walmart Check Cashing & Money Orders $ 3.00 $ 1.00 $ Check Cashing & Money Orders 1.91% $ 1.15 $ Extended Overdraft Fee (1 day over limit) Overdraft Available? TOTAL ANNUAL COST Bretton Woods, Inc. Page 18

19 Exhibit IV Market Share Branded Prepaid Card Report State No. Office Total Deposit Headquartered of Market Deposits Market Institution Name Cert Offices Share 30-Jun-12 Share Bank of America, National Association 3510 NORTH CAROLINA 5, % 991,685, % Wells Fargo Bank, National Association 3511 SOUTH DAKOTA 6, % 847,727, % JPMorgan Chase Bank, National Association 628 OHIO 5, % 832,455, % Citibank, National Association 7213 SOUTH DAKOTA 1, % 394,664, % PNC Bank, National Association 6384 DELAWARE 3, % 203,375, % Branch Banking and Trust Company 9846 NORTH CAROLINA 1, % 131,594, % SunTrust Bank 867 GEORGIA 1, % 130,414, % Regions Bank ALABAMA 1, % 95,495, % Fifth Third Bank 6672 OHIO 1, % 86,987, % Compass Bank ALABAMA % 48,097, % Chase Bank USA, National Association DELAWARE 3 0.0% 32,552, % Wells Fargo Bank South Central, National Association 5146 TEXAS 1 0.0% 29,479, % Synovus Bank 873 GEORGIA % 21,589, % BOKF, National Association 4214 OKLAHOMA % 18,258, % Total Sample 29, % 3,864,375, % TOTAL USA 97, % 8,947,239, % Bretton Woods, Inc. Page 19