Procedures for Transfer of Certain Customer Brokerage Accounts

Under $250,000 in Net Value

Posted 3/9/09

As a result of an order issued by the Court on March 5, 2009 (click here to view the March 5
order) at the request of the Receiver, certain previously frozen brokerage accounts of customers
of Stanford Group Company may now be transferred by the customer to a new brokerage firm.

Question 1. Which brokerage accounts are eligible to be transferred?

Answer. To be eligible for transfer, an account must:

• be held in custody at Pershing LLC;

• have a balance of less than $250,000 in net assets as of the close of business on February
27, 2009; and

• not be subject to any of the exceptions described below in FAQ 9 regarding accounts that
are not eligible for transfer.

Question 2. How do I know if my brokerage account is at Pershing LLC?

Answer. You can look at your Stanford Group Company month-end statement and see
the Pershing LLC name at the bottom of the first page. Almost all of Stanford Group
Company’s customer accounts are held at Pershing.

Question 3. Once I see the Pershing LLC name on my statement, what should I do next?
Answer. To transfer your brokerage account away from Stanford Group Company, you
need to contact a new brokerage firm and open a new account with them. As part of the account
opening process, one of the forms you will be asked by your new firm to fill out is a transfer
form referred to as an ACATS form. Once that has been completed, your new firm may begin
the account transfer process by presenting the completed ACATS form to Pershing through the
ACATS system. If your account is an Individual Retirement Account (IRA), please see FAQ 18
for additional information.

Question 4. How do I open a new account at another firm?

Answer. You may obtain the forms to open a new account at a new firm either from the
new firm or from its website.

                             
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Question 5. How long will the transfer process take?

Answer. Once the ACATS form has been submitted to Pershing by your new firm
through the ACATS system, it will then take about a week to complete the transfer in most cases.
The process may take longer for accounts with unusual circumstances. Please follow up with
your new firm to see if there are any issues during that time.

Question 6. Do I have to pay any fees to transfer my account?

Answer. No. The receivership estate will absorb the fees associated with the ACATS
transfer process, as well as any maintenance and termination fees associated with the transfer of
Individual Retirement Accounts (IRAs).

Question 7. May I transfer my account to a bank or trust company, or to some other type of
recipient, rather than to a brokerage firm?
Answer. You may transfer the assets in the account to any financial institution of your
choice that can accept the brokerage account assets on your behalf, but the transfer process will
be completed most quickly if the recipient is a participant in the ACATS transfer system. In
addition to brokerage firms, many banks and trust companies are ACATS participants.

Question 8. What does ACATS stand for?

Answer. ACATS stands for Automated Customer Account Transfer Service. ACATS is
a system that facilitates the automated movement of account balances and holdings between
brokerage firms and other financial institutions.

Question 9. Which accounts with net assets under $250,000 are not eligible to be transferred?
Answer. Under the Court’s order, the following categories of accounts are not eligible to
be released, even if the February 27, 2009 balance was less than $250,000:

• any account owned by an individual Defendant or by any person who as of February 16,
2009 had any of the following relationships to any Defendant or to any entity owned or
controlled by the Defendants: shareholder, director, member of senior management or
registered representative or financial advisor who earned fees and commissions;

• any account owned for the benefit of any individual Defendant or any Stanford entity;

• any account that contains investment assets managed by any Stanford entity (for more
information on these accounts, see FAQ 22 below

• any account that secures an unpaid balance owed by a customer or a non-purpose loan
made to a customer (this criteria, however, does not preclude accounts with margin loan
balances that are in compliance with applicable margin rules from being transferred); and

• any account that is related to any account in the four categories above by social security
number, address or other similar indicator.

                             
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Question 10. Will I be able to take money out of my current Stanford brokerage account using
Pro Cash, check writing, my debit card or my Stanford Cash Account before the transfer is
completed?
Answer. No. You will not be able to write checks on your account or withdraw cash
from it while it remains a Stanford account at Pershing. You will need to establish check-writing
or cash withdrawal privileges at your new brokerage firm.

Question 11. Will I still be able to use my current debit cards or checks when my account is
moved over to the new firm?
Answer. No. You will need to apply for a new card and checks at your new firm. All
cards and checks under the Stanford Group Company relationship will be voided.

Question 12. Will I be able to liquidate positions in my Stanford account while I’m looking for
a new brokerage firm?
Answer. Yes, but it is recommended that you transfer your account first and then place
orders to liquidate positions in order to minimize the risk that placement of a liquidating order
interferes with the transfer process.. Alternatively, if you wish to place a liquidating order before
initiating the transfer process, you should direct your new firm to wait three business days after
you place the liquidating order before it presents the ACATS transfer form to Pershing through
the ACATS system. To liquidate a position while your account remains at Stanford, you may
call the phone number established by the Receivership for this purpose (1-866-964-6301 or 713-
964-6300).

Question 13. Will the transfer request include both my cash, securities and margin balances?
Answer. Yes. The ACATS process will move your full account balances and holdings in
your Stanford Group Company brokerage account to the new firm. Please see FAQ 20 below for
more information about margin balances.

Question 14. What happens if I transfer my account to a new firm and I am due to receive a
dividend or interest payment?
Answer. You will still be entitled to receive the dividend or interest payment. Your new
firm will be entitled to receive the dividend or interest payment from Pershing LLC, once it is
paid. Your new firm will process the dividend or interest payment into your account, once it is
received from Pershing, and it will be reflected as “received” on your next account statement
from your new firm.

Question 15. Will I still receive a statement for my Stanford account at month end?
Answer. You will receive a month end statement for your Stanford Group Company
brokerage account from Pershing as long as it had activity during the month. If you transfer your
account during the month, the statement that you receive will reflect that your account balances
and holdings have been transferred. After that, your account will be officially closed at Pershing
and you will receive no further account statements from Pershing on behalf of Stanford.

                             
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Question 16. Will I still receive a 1099 form for tax purposes at the end of 2009 from Stanford
Group Company or Pershing for the time my account was still active?
Answer. Yes. Pershing, as clearing broker, will produce your year end 1099 form and
other tax reporting forms for your Stanford Group Company brokerage account for the time
period in 2009 during which your account was held in custody by Pershing. These forms will be
mailed to you early in 2010. Tax forms for 2008 have already been mailed.

Question 17. Will I still earn interest or dividends on the money fund in my Stanford Group
Company brokerage account until my account is transferred to my new firm?
Answer. Yes. If your cash is currently invested in a money fund account that pays
interest or dividends, then it will continue to earn interest or dividends applicable to the
particular money fund that you own until the transfer has taken place.

Question 18. If my Stanford Group Company brokerage account that is eligible to be transferred
is an individual retirement account (IRA), may I still transfer it?
Answer. Yes. You can request that your IRA account be transferred to your new firm.
Please contact your new firm on the procedures for opening a new IRA account, so that when
you transfer your Stanford IRA account you will not trigger any penalties related to early
withdrawal.

Question 19. How long do I have to transfer my Stanford Group Company brokerage account to
a new firm?
Answer. There is no fixed deadline at this time, but it is in your best interest to act
promptly in order to begin the account transfer process.

Question 20. If my account that is eligible to be transferred has a margin loan associated with it,
may I still transfer it?
Answer. If your account is in compliance with applicable margin rules, the margin loan
will transfer with the account to your new firm. You should advise your new firm of the
existence of the margin loan and the approximate margin loan balance. If your account is not in
compliance, your account may not be transferred until it is in compliance. Please discuss these
requirements with your new firm.

Question 21. I have multiple Stanford Group Company brokerage accounts at Pershing LLC.
Will each account be treated separately for the $250,000 maximum net value for transfer
eligibility ?
Answer. Yes, even if the same owner has multiple accounts that total more than
$250,000 in net assets in the aggregate, each account will treated separately for transfer
eligibility purposes, so long as all of the accounts meet the eligibility requirements described
above in FAQ 9.

Question 22. What is a Stanford managed account and how can I identify it?
Answer. This term generally includes accounts that were charged periodic fees that
were equal to a percentage of the assets under management. Included in this category are all
accounts that were managed by Stanford Capital Management (“SCM”) asset managers such as
                             
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Stanford Allocation Strategies (SAS), Stanford Global Fixed Income; accounts that were directly
managed by Stanford advisors; and accounts managed by third party asset managers made
available to Stanford customers through their Stanford financial advisor, such as the Portfolio
Advisors program. Most (but not all) of these accounts have account codes that begin with one
of the following three-character prefixes: 0C9, 0P1, 5LW, 6QK, A00, AB9, HC4, HGC, JAH,
JC3, JEJ, N2E, NCW, NJA, NJE, NJF, NJG, NJH, NJJ, NJK, NJL, NJV, NJX, NJW, NUJ or
NWQ. Other accounts in this category are accounts that have account codes that (1) begin with
one of the following three-character prefixes: N14, NJB, NJM, NM2, NM4, NMY and NNC, and
(2) are charged quarterly fees based on a percentage of assets under management. These
accounts are not eligible for transfer at the present time.

Question 23. I have a brokerage account and a Stanford managed account. Why is my
brokerage account not eligible for transfer if its net value is less than $250,000?
Answer. Your brokerage account is not eligible for transfer at this time because you also
have a Stanford managed account. Stanford managed accounts are not eligible for transfer, nor
are brokerage accounts that are related by social security number, address or other similar
indicators, even if the net asset value of each account is less than $250,000.

Question 24. Do annuity investments shown on my Stanford/Pershing statement count in

determining whether my net assets are under $250,000?
Answer. In most cases, no. In the case of the vast majority of annuities shown on these
statements, Pershing is not the custodian of the annuity and the annuity amounts are displayed
for informational purposes only. The annuity investment is held by the insurance company that
issued the annuity and is not subject to the asset freeze, so it will not be considered in calculating
the $250,000 maximum. In a small number of cases, however, the annuity is held in a Pershing
IRA account and Pershing is the custodian. In those cases, the annuity amount will be
considered in determining whether the net asset value of the account exceeds $250,000.

Question 25. Will the annuity investments shown on my Stanford/Pershing statement be part of
the ACATS transfer process?
Answer. Annuity investments that are held by insurance companies and shown on the
statement for informational purposes only do not need to be transferred. Custody of these
annuities will remain with the insurance company. You should consult with your new brokerage
firm to request that your annuity holdings be reported on your new firm’s monthly statements.
This is typically accomplished by completing a broker-dealer change form that is submitted by
your new broker-dealer directly to the insurance company. If the annuity investment is held by
Pershing in an IRA account that is transferred, the annuity will be transferred along with the
other assets.

Question 26. What is Pershing LLC and are my assets safe there?
  Answer. Pershing LLC, a subsidiary of The Bank of New York Mellon Corporation and
member of the Securities Investor Protection Corporation (SIPC), is one of the world’s largest
securities brokerage clearing firms that provides technology and securities custody solutions to
over 1,000 financial service organizations worldwide. For information about Pershing LLC and

                             
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customer account protection for accounts held in custody by Pershing LLC, please visit
www.pershing.com and www.pershing.com/media/PER_SIPC_2.pdf.

                             
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