ESOP Transaction Process Requirements

This document is about the policies and procedures that First Bankers Trust Services, Inc. (FBTS) will apply whenever it serves as trustee or other fiduciary of an employee stock ownership plan (ESOP) that is purchasing, selling, or receiving an offer to purchase or sell employer securities that are not publicly traded. It covers requirements for selection and use of a valuation advisor, oversight of the valuation advisor, review of financial statements, fiduciary review process, preservation of documents, debt and fair market value, control, and consideration of claw-back arrangements.