Mr. Barney Frank
Chairman, Financial Services Committee
United States House of Representatives
2129 Rayburn House Office Building
Washington, DC  20515

Dear Congressman Frank:

Thank you for your letter dated February 24, 2009.

We understand this is a time of great anxiety and financial distress, and your question regarding our support of an event such as the Northern Trust Open is legitimate. We deeply regret that some of the events associated with the Northern Trust Open have distracted from the positive nature of an event that has raised more than $50 million for charity since its inception.

We take our responsibilities to our shareholders, clients, employees and taxpayers seriously, and we remain committed to doing the right thing for all constituencies. While our client educational and entertainment activities have all been within applicable guidelines under the Capital Purchase Program, we will redouble our efforts to ensure that these activities are appropriate given the current environment.
 
Our capital ratios are, and consistently have been, strong. Our company has been consistently profitable, including net income in 2008 of $795 million - up 9 percent from 2007. Shareholders, clients and the communities we serve, including United States taxpayers who invested in Northern Trust, have been well-served by our responsible management and success.  

As you are aware, the U.S. Treasury yesterday released an FAQ addressing the Capital Purchase Program under the American Recovery and Reinvestment Act of 2009, including guidance on repayment procedures.  Northern Trust has engaged our regulators with the goal of repaying Capital Purchase Program funds as quickly as prudently possible under the new guidelines.

As we have stated publicly, the Northern Trust Open and its related activities were in no way reliant upon Capital Purchase Program funds, and would have occurred even had we not received Capital Purchase Program funds.  

Moreover, as disclosed in public documents, Northern Trust has used Capital Purchase Program funds to support high quality loan growth, benefiting personal and institutional clients. As of December 31, 2008, our loans and leases grew to more than $30 billion, a 21% increase from December 31, 2007.

Northern Trust is profitable and well capitalized, and we will continue to invest in our clients and the communities we serve. We appreciate your efforts to help our nation's financial system and economy achieve a full recovery.

  Sincerely,

 Frederick H. Waddell
 President and Chief Executive Officer
 Northern Trust
 

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About Northern Trust
Northern Trust Corporation (Nasdaq: NTRS) is a leading provider of investment management, asset and fund administration, fiduciary and banking solutions for corporations, institutions and affluent individuals worldwide. Northern Trust, a financial holding company based in Chicago, has a growing network of 85 offices in 18 U.S. states and has international offices in 15 locations in North America, Europe, the Middle East and the Asia-Pacific region. As of December 31, 2008, Northern Trust had assets under custody of US$3.0 trillion, and assets under investment management of US$575.5 billion. Northern Trust, founded in 1889, has earned distinction as an industry leader in combining exceptional service and expertise with innovative products and technology. For more information, visit http://www.northerntrust.com.