views We suggest that management make this evaluation during the due diligence process; inquire of your CPA, legal counsel and primary regulator, as considered necessary; and contemporaneously document management’s considerations for these items. About DHG Financial Services DHG Financial Services, a national practice of Dixon Hughes Goodman, focuses on publicly traded and privately-held financial services companies across the U.S. Our 30 financial services partners and more than 300 dedicated professionals provide you with in-depth, specialized industry knowledge and a wide range of assurance, tax and advisory services to address issues facing your industry in today’s challenging environment. For more information, visit dhgllp.com/financial-services. • Determining the appropriate risk weighting of the investment/loan for regulatory capital purposes. We suggest that management evaluate the current FFIEC RC-R instructions to determine the appropriate risk weighting. • Who should own the investment – the bank or the holding company? About the Authors While it is not uncommon for a holding company to make the investment, we have commonly seen these investments made by the bank. Matt Miller is a senior associate in the DHG Financial Services practice. Matt has more than two years of experience with public and private financial institutions and more than four years of experience with companies in the renewable energy industry.

He works primarily in the area of financial statement audits and reviews, internal control evaluation and Sarbanes-Oxley (SOX) compliance. • The need to possibly engage legal counsel and/or a CPA, or to inquire of your legal counsel and/or auditors, to assist in evaluating the aforementioned regulatory considerations. When inquiring of your external auditors, management should be aware that certain limitations, as prescribed by auditing standards, or client service relationships, with the investor/ investee, may limit the auditors’ ability to provide guidance in order to avoid potential impairments of independence. Adam Thomas, Partner, DHG Financial Services, has 14 years’ experience serving financial institutions. Adam has significant experience working with public companies, including navigating business combinations, liaising with SEC counsel, reviewing SEC filings and auditing internal controls (for both FDICIA and Sarbanes-Oxley). Adam has led internal and external training sessions, with subject matter ranging from the allowance for loan losses to acquired loan accounting.

Adam also brings experience with dealing with share-based compensation, fair value measurements, and income tax provision accounting. • The need to inquire of or inform your regulator as to a possible or recent investment in a renewable energy project. Management may also consider reviewing relevant FDIC Financial Institution Letters, Federal Reserve Supervisory and Regulation Letters and OCC Interpretive Letters (e.g., Interpretive Letter #1048 – January 2006 – 12 USC 29). While the accounting for investments in renewable energy projects is not overly complex, management needs to carefully consider the potential accounting, reporting/disclosure and regulatory implications of such investments, especially when those investments are material to the institution’s financial statements. Management also should document assessment of the pertinent accounting and regulatory issues related to these items. It is equally as important to assess the need to establish and document internal controls that support the institution’s objectives, while ensuring proper accounting treatment for and reporting/disclosure of such investments. As a firm with experience providing advisory, assurance attestation services to financial institutions, companies within the renewable energy industry and other types of investors, DHG is ready to serve you. Assurance | Tax | Advisory | dhgllp.com Matt Miller Senior Associate DHG Financial Services matt.miller@dhgllp.com Adam Thomas Partner DHG Financial Services adam.thomas@dhgllp.com 3 .