Mr. Alan Stewart:

It is addressed to National Asset Loan Management D.A.C. It regards Project Eagle NDA and is for the attention of Mr. Alan Stewart. It reads as follows:

Dear Mr. Stewart:

I am writing to follow up on my telephone conversation with Mr. McDonagh and Mr. Whelan on November 18, 2016 concerning the agreement entered into with NAMA on February 11, 2014 (the "NDA") in response to your letter of the same date.

Please allow me to repeat my apology for not bringing this matter to NAMA's attention sooner. While I do not offer it as an excuse, I was focused on preparation for the meeting with the Public Accounts Committee (the "Committee"). I intended no discourtesy to you and your colleagues.

As you are aware, I attended a meeting of the Committee on November 17, 2016 as a representative of Cerberus Capital Management L.P. and certain of its affiliates ("Cerberus"). Cerberus was invited to assist the Committee in its examination of the Special Report of the Comptroller and Auditor General with respect to a number of matters. Some of those matters related to events in relation to which I had direct contemporaneous knowledge, whereas for others, I did not.

In advance of attending a meeting of the Committee I reviewed some contemporaneous documents dating from 2014, including emails that were not copied to me in 2014. As part of that process I became aware that some information had been disclosed by Cerberus to Brown Rudnick LLP ("Brown Rudnick") in March 2014.

Cerberus engaged Brown Rudnick to provide legal and strategic services in connection with Cerberus' proposed acquisition of the Project Eagle portfolio. Cerberus was first approached by Brown Rudnick on March 14, 2014 and professional interactions began from that date. The engagement was formally documented on March 24, 2014. As solicitors permitted to practice in England and Wales Brown Rudnick are obliged by the Solicitors Regulation Authority's code of conduct to treat information received from clients or prospective clients as confidential. This professional and legal obligation was acknowledged and other related representations and warranties were made both in our discussions with Brown Rudnick and in Cerberus' formal engagement letter with Brown Rudnick.