September 29, 2011

September 29, 2011 Mr. Percival E. Clouden Chief Executive Officer United States Virgin Islands Economic Development Commission 5055 None Gade, St. Thomas, VI 00802 Dear Mr. Clouden: In response to the Economic Development Commission's letter dated September 20, 2011, please be advised that there has been no change in ownership of Financial Trust Company, Inc. (the "Company"). As stated in Appendix Al of the "Extension" of the Company's Economic Development Certificate, issued by the Government of the Territory of the Virgin Islands of the United States, a copy of which was attached to the Commission's September 20 letter, Mr. Jeffrey Epstein is the sole shareholder of the Company. Moreover, Mr. Epstein has been the sole shareholder of the Company since the date of the initial grant of benefits to the Company. Respectfully, Cecile de Jongh EFTA01100227