Agreement Concerning Fiduciary Engagements and Process Requirements for Employer Stock Transactions

This document is about the agreement between Lubbock National Bank and the United States Department of Labor regarding the policies and procedures that the Trustee must follow when serving as a fiduciary for an ESOP in transactions involving the purchase or sale of non-publicly traded employer securities. It covers the selection and use of a valuation advisor, oversight of the valuation process, required analysis and documentation, financial statement requirements, and the Trustee's fiduciary review process.