reatment Requested by JPMorgan Chase JPM-SDNY-00000417 EFTA_00187762 EFTA01300252 3) We have a bonus recoupment policy beyond that's required by Sarbanes-Oxley. 4) We do not provide executives with change-of-control agreements, golden parachutes, special retirement plans, severance packages or merger bonus

ion process with investment team and outside counsel including negotiation of fund terms • Strengthened internal controls to ensure compliance with Sarbanes-Oxley requirements • Directed migration to and implementation of new software platform applicable to private equity funds • Prepared business-line budg

spectus, • rot being requited to comply with the auditor attestaton requiernents of Section 404 of the Sarbanes-Oxley Act of 2032. as amended a the 'Sarbanes-Oxley • reduced didosure obligators regardng executive compensation in our penodc reports, proxy statements and regstabon statements, and • exemptons tan

cy has not yet been on the menu. See generally Stephen Bainbridge, The Creeping Federalization of Corporate Law, 26 REG. 26 (2003) (arguing that the Sarbanes-Oxley legislation was the most dramatic expansion of federal regulatory power). For internal use only CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)

cy has not yet been on the menu. See generally Stephen Bainbridge, The Creeping Federalization of Corporate Law, 26 REG. 26 (2003) (arguing that the Sarbanes-Oxley legislation was the most dramatic expansion of federal regulatory power). For internal use only CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)

ol over financial reporting. We have not performed an evaluation of our internal control over financial reporting, as required by Section 404 of the Sarbanes-Oxley Act, nor have we engaged an independent registered public accounting fern to perform an audit of our internal control over financial reporting as of

evel 3 assets. (v) Deloitte's Certification 735. As an auditor Deloitte also certified Bear Steams' third quarter 2006 Form 10-Q, as required by Sarbanes-Oxley, and, in so doing, knowingly and recklessly falsely offered an opinion as to the financial statement's accuracy. As set out in detail at paragraphs

8B2.1 & app. note 2 (2011). 311 This was underscored by then-SEC Commissioner Cynthia Glassman in 2003 ina speech on the SEC’s implementation of the Sarbanes-Oxley Act: “[T Jhe ultimate effectiveness of the new corporate governance rules will be determined by the ‘tone at the top. Adopting a code of ethics means