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Financial Crime Risk Management Services – Additional Terms

1. Services. If purchased by Client, the following risk services (collectively, the “Risk Services”) will be provided via a web-based access solution for Client’s authorized employees that have been given the Data Transfer (as described in Section 1(b) below). 51�Թ������ճԹ� will only provide those Risk Services for which fees are paid.

(a) Types of Risk Services.

(i) AML Risk Manager™. Anti- money laundering services include:

· Automated Regulatory Reporting – automates reporting for SARs and CTRs by evaluating suspicious activity and currency transactions reporting

o Scans transactions

o Pre-populates required reports and allows Client editing

o Links customer accounts as one group for monitoring and reporting

o Tracks exempt persons

o Client may elect electronic or manual submission reports for FinCEN

· Monetary Instrument Reporting – allows end users to automatically import monetary instrument transactions or enter monetary instrument purchases manually into log and allows management reporting

· Dynamic Risk Scoring

o Periodically calculates customer risk scores based on configured rules using static and dynamic information

o Compares import customer risk score determined by Client to the AML Risk Manager calculated risk score

o Notifies end user of deviations between Client provided and AML Risk Manager score

o Monitors expected customer behavior profiles which can be imported or end user can create manual profiles

· Watch List Comparison tool - comparison of Client customer information against those certain industry watch list database(s) that 51�Թ������ճԹ� makes generally available to all users of the Risk Services at the given time (“Standard Watch List”) for all compatible transactions routed through this functionality

(ii) Fraud Risk Manager™. Transaction and customer monitoring includes:

· Transaction Monitoring – intelligent transaction monitoring of financial and non-financial events utilizing behavioral profiling, rules and Alert Definitions

o Deposit and ‘On-Us’ Fraud – monitors account activity to detect suspicious deposits for multi-channel check deposit monitoring from new or existing accounts

o ATM and Debit Card Fraud – monitors multiple channels including PIN POS swiped, Internet, ATM and Signature POS key/swiped

o Kite Fraud Monitoring – analyzes transit deposits and withdrawal activity to identify kiting patterns

o Payments Fraud – monitors ACH, wire, and external debit transactions to detect fraudulent activity in batch files; real-time ACH and wire monitoring subject to additional charges.

· 51�Թ������ճԹ� Fraud Pack – a pre-defined library of Risk Views, Alert Definitions and Rules from which the licensed number of said may be selected

· Alerts - generated alerts resulting from transactions triggering installed Alert Definitions

· Alert Management - a tool for investigating Alerts through a view of customers and transactions with drill down capability

· Workflow – Client configurable, pre-defined workflows and built-in configuration functionality including check lists and automated alert assignment and routing

· Case Management – an integrated case management system that tracks, prioritizes, and manages cases; and records an audit trail with case history and detailed log of actions taken and reports filed

(iii) Payment Fraud Manager™. Requires FCRM version 6.X or higher. Real-time ACH or Wires processed through the related 51�Թ������ճԹ� services purchased by Client. Transaction and customer monitoring includes:

· Transaction Monitoring – intelligent transaction monitoring of financial and non-financial events utilizing behavioral profiling, rules and Alert Definitions

· Payments Fraud – monitors wire transactions in real-time in conjunction with 51�Թ������ճԹ�’s wires or ACH services purchased by Client from 51�Թ������ճԹ�

· 51�Թ������ճԹ� Fraud Pack – a pre-defined library of Risk Views, Alert Definitions and Rules

· Alerts - generated alerts resulting from transactions triggering installed Alert Definitions

· Alert Management - a tool for investigating Alerts through a view of customers and transactions with drill down capability

· Workflow – Client configurable, pre-defined workflows and built-in configuration functionality including check lists and automated alert assignment and routine

· Case Management – an integrated case management system that tracks, prioritizes, and manages cases; and records an audit trail with case history and detailed log of actions taken and reports filed.

(b) Data Transfer. 51�Թ������ճԹ� will provide a data transmission protocol which will allow for the transmission of then available data feeds that are sleeved by the Client between the 51�Թ������ճԹ� core account processing platform and the 51�Թ������ճԹ� system for the Risk Services. Use of such protocols is limited to the exchange of 51�Թ������ճԹ�-approved data types for use with the Risk Services. 51�Թ������ճԹ� will establish schedules related to data transmissions from the 51�Թ������ճԹ� core account processing platform to Risk Services system.

(c) Processing Priority. 51�Թ������ճԹ� does not subscribe to any processing priority; all 51�Թ������ճԹ� clients using Risk Services receive equal processing consideration.

(d) Additional Functionalities. 51�Թ������ճԹ� will also provide for an automated file validation on the customer data files that meet the 51�Թ������ճԹ�-approved data types. This will include standard error tracking and reporting, where information regarding data errors will be made available, and Client will be notified via an email by 51�Թ������ճԹ� to allow Client to review and make necessary corrections.

(e) Hours for Accessing the 51�Թ������ճԹ� System. 51�Թ������ճԹ� will use reasonable efforts to cause the 51�Թ������ճԹ� System providing the Risk Services to be available for access by Client in a 7x24 environment, excluding reasonable downtime for maintenance and when batch processes are running. Product support is available to Client Monday through Friday 8:30-6:30 Eastern Time, excluding 51�Թ������ճԹ� holidays.

(f) Interfaces. 51�Թ������ճԹ� has sole discretion in determining the content and availability of interfaces it develops between any 51�Թ������ճԹ� financial application and the Risk Services.

2. Additional Terms and Conditions.

(a) Services Warranties. Client acknowledges that the Risk Services are provided only to supplement Client’s financial diligence and review purposes, and Client is responsible for determining all compliance obligations and adopting a full compliance program. Accordingly, no warranty that functionality provided with the Services will enable Client to comply with regulations applies to the Services; provided, however that 51�Թ������ճԹ� will provide all reasonable technical information about the functionality provided by the Services as requested by Client to allow Client to properly evaluate, design and implement such a compliance program.

(b) ADDITIONAL DISCLAIMER. CLIENT ACKNOWLEDGES AND AGREES THAT THE USE OF THE RISK SERVICES, ANY OUTPUTS THEREFROM AND ANY ASSOCIATED DELIVERABLES, INFORMATION, AND/OR MATERIALS PROVIDED IN CONNECTION THEREWITH, AND ANY DECISIONS MADE IN RELIANCE UPON SUCH SERVICES, DELIVERABLES, INFORMATION OR MATERIALS, ARE MADE AT CLIENT’S OWN RISK. IN ADDITION TO ANY OTHER DISCLAIMERS SET FORTH IN THE AGREEMENT, CLIENT ACKNOWLEDGES AND AGREES THAT: (I) THE RISK SERVICES AND ANY OUTPUTS THEREFROM ARE MEANT ONLY TO SUPPLEMENT ANY DUE DILIGENCE OR OTHER ACTIONS CLIENT WOULD TAKE PRIOR TO OFFERING ANY SERVICES OR OTHERWISE ENGAGING WITH ANY CUSTOMER OR OTHER PARTY; (II) THE RISK SERVICES AND ANY OUTPUTS THEREFROM ARE BASED ON THE INPUT DATA, SPECIFICATIONS AND CONFIGURATIONS SELECTED BY CLIENT, EACH OF WHICH MAY AFFECT ACCURACY AND RELIABILITY; AND (III) ANY OUTPUTS FROM THE RISK SERVICES AND ANY INFORMATION CONTAINED THEREIN OR OTHERWISE PROVIDED IN CONNECTION WITH THE RISK SERVICES ARE PROVIDED ON AN “AS IS” AND “WITH ALL FAULTS” BASIS. CLIENT ACKNOWLEDGES THAT ANY FRAUD-RELATED TOOLS PROVIDED AS PART OF THE RISK SERVICES ARE SUPPLEMENTAL IN NATURE AND ARE NOT ABLE TO DETECT ALL FRAUD OR BE OTHERWISE 100% ACCURATE.

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