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The following is an excerpt from a S-4/A SEC Filing, filed by PARTNERS TRUST FINANCIAL ... on 5/7/2004.

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Plan of Distribution and Marketing Arrangements

Offering materials have been initially distributed to certain persons by mail, with additional copies made available through our conversion center and Sandler O'Neill. All prospective purchasers are to send payment directly to SBU Bank, where such funds will be held in a segregated savings account and not released until the offering is completed or terminated.

We have engaged Sandler O'Neill, a broker-dealer registered with the NASD, as a financial and marketing advisor in connection with the offering of our common stock. In its role as financial and marketing advisor, Sandler O'Neill will assist us in the offering as follows: (i) consulting as to the securities marketing implications of any aspect of the plan of conversion or related corporate documents; (ii) reviewing with our board of directors the financial and securities marketing implications of the independent appraiser's appraisal of the common stock; (iii) reviewing all offering documents, including the prospectus, stock order forms and related offering materials (we are responsible for the preparation and filing of such documents); (iv) assisting in the design and implementation of a marketing strategy for the offering; (v) assisting us in preparing for meetings with potential investors and broker-dealers; and (vi) providing such other general advice and assistance regarding financial and marketing aspects of the conversion. For these services, Sandler O'Neill will receive a fee of 1.00% of the aggregate dollar amount of the common stock sold in the offering, excluding shares sold to the Partners Trust Financial Group employee stock ownership plan, and to Partners Trust Financial Group's officers, employees and directors, and their immediate families. We have made an advance payment of $25,000 to Sandler O'Neill in this regard. If there is a syndicated community offering, Sandler O'Neill will receive a management fee of 1.00% of the aggregate dollar amount of the common stock sold in the syndicated community offering. The total fees payable to Sandler O'Neill and other NASD member firms in the syndicated community offering will not exceed 5.5% of the aggregate dollar amount of the common stock sold in the syndicated community offering.

Partners Trust Financial Group and SBU Bank also will reimburse Sandler O'Neill for its legal fees and expenses associated with its marketing effort, up to a maximum of $80,000. If the plan of conversion is terminated or if Sandler O'Neill terminates its agreement with us in accordance with the provisions of the agreement, Sandler O'Neill will only receive reimbursement of its reasonable out-of-pocket expenses. We will indemnify Sandler O'Neill against liabilities and expenses (including legal fees) incurred in connection with certain claims or litigation arising out of or based upon untrue statements or omissions contained in the offering material for the common stock, including liabilities under the Securities Act of 1933.

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We also have engaged Sandler O'Neill to act as conversion agent in connection with the offering. In its role as conversion agent, Sandler O'Neill will assist us in the offering as follows: (i) consolidation of accounts and development of a central file; (ii) preparation of proxy, order and request forms; (iii) organization and supervision of the conversion center; (iv) proxy solicitation and special meeting services; and (v) subscription services. For these services, Sandler O'Neill will receive a fee of $65,000 and reimbursement for its reasonable out-of-pocket expenses, up to a maximum of $30,000. We have made an advance payment of $5,000 to Sandler O'Neill in this regard.

In addition, Partners Trust Financial Group engaged Sandler O'Neill as its financial advisor in connection with the merger. Under the terms of the engagement, Partners Trust Financial Group has agreed to pay Sandler O'Neill a cash fee equal to 0.80% of the aggregate purchase price. Twenty-five percent of such fee became payable upon the signing of the merger agreement, with remainder due upon completion of the merger. We also will reimburse Sandler O'Neill for its reasonable out-of-pocket expenses incurred in connection with its engagement and will indemnify Sandler O'Neill against certain liabilities arising out of such engagement, including liabilities under federal securities laws.

Our directors and executive officers may participate in the solicitation of offers to purchase common stock. Other trained employees may participate in the offering in ministerial capacities, providing clerical work in effecting a sales transaction or answering questions of a ministerial nature. Other questions of prospective purchasers will be directed to executive officers or registered representatives. We will rely on Rule 3a4-1 of the Exchange Act, so as to permit officers, directors, and employees to participate in the sale of the common stock. No officer, director, or employee will be compensated for his participation by the payment of commissions or other remuneration based either directly or indirectly on the transactions in the common stock.

Procedure For Purchasing Shares

Expiration Date. The community offering will begin concurrently with the subscription offering and is expected to terminate at the same time as the subscription offering, and must terminate no more than 45 days following the subscription offering. Partners Trust Financial Group may decide to extend the community offering for any reason and is not required to give purchasers notice of any such extension unless such period extends beyond [ ]. If 14,875,000 shares have not been issued by [ ], unless this period is further extended with the consent of the Office of Thrift Supervision, we will provide each person who subscribed for common stock with an amendment to this prospectus indicating that each person who subscribed for common stock may increase, decrease, or rescind their subscription within the time remaining in the extension period. These extensions may not go beyond [ ], which is two years after the special meeting of members of Partners Trust, MHC to vote on the conversion.

If we have not sold the minimum number of shares offered in the offering by the expiration date or any extension thereof, we may terminate the offering and promptly refund all orders for shares of common stock. If the number of shares offered is reduced below the minimum of the offering range, or increased above the adjusted maximum of the offering range, all funds delivered to us to purchase shares of common stock in the offering will be returned promptly to the subscribers with interest at SBU Bank's passbook savings rate and all deposit account withdrawal authorizations will be canceled. Purchasers will be given an opportunity to resubmit their orders.

In the event that the maximum purchase limitation is increased to 5% of the shares issued in the offering, such limitation may be further increased to 9.99%, provided that orders for new Partners Trust Financial Group common stock exceeding 5% of the shares of new Partners Trust Financial Group common stock issued in the offering may not exceed in the aggregate 10% of the total shares issued. Requests to purchase additional shares in the event that the purchase limitation is so increased will be determined by the board of directors of Partners Trust Financial Group in its sole discretion.

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To ensure that each purchaser receives a prospectus at least 48 hours before the expiration date of the offering in accordance with Rule 15c2-8 of the Securities Exchange Act of 1934, no prospectus will be mailed any later than five days prior to this date or hand delivered any later than two days prior to this date. Execution of an order form will confirm receipt of delivery in accordance with Rule 15c2-8. Order forms will be distributed only with a prospectus. Subscription funds will be maintained in a segregated account at SBU Bank and will earn interest at our passbook savings rate from the date of receipt.

We reserve the right in our sole discretion to terminate the offering at any time and for any reason, in which case we will cancel any deposit account withdrawal orders and promptly return all funds submitted, with interest at SBU Bank's passbook savings rate from the date of receipt.

Liquidation Rights

In the unlikely event of a complete liquidation of Partners Trust Financial Group prior to the conversion, all claims of creditors of Partners Trust Financial Group, including those of depositors of SBU Bank (to the extent of their deposit balances), would be paid first. Thereafter, if there were any assets of Partners Trust Financial Group remaining, these assets would be distributed to stockholders, including Partners Trust, MHC. In the unlikely event that Partners Trust, MHC and Partners Trust Financial Group liquidated prior to the conversion, all claims of creditors would be paid first. Then, if there were any assets of Partners Trust, MHC remaining, members of Partners Trust, MHC would receive those remaining assets, pro rata, based upon the deposit balances in their deposit account in SBU Bank immediately prior to liquidation. In the unlikely event that SBU Bank were to liquidate after the conversion, all claims of creditors, including those of depositors, would be paid first, followed by distribution of the "liquidation account" to certain depositors, with any assets remaining thereafter distributed to Partners Trust Financial Group as the holder of SBU Bank capital stock. Pursuant to the rules and regulations of the Office of Thrift Supervision, a post-conversion merger, consolidation, sale of bulk assets or similar combination or transaction with another insured savings institution would not be considered a liquidation and, in these types of transactions, the liquidation account would be assumed by the surviving institution.

The plan of conversion and reorganization provides for the establishment, at the time of the conversion, of a special "liquidation account" for the benefit of Eligible Account Holders and Supplemental Eligible Account Holders in an amount equal to the greater of:

(1) Partners Trust, MHC's ownership interest in the stockholders' equity of Partners Trust Financial Group as of the date of its latest balance sheet contained in this prospectus; or

(2) the stockholders' equity of SBU Bank as of the latest financial statements set forth in the prospectus used at the time that SBU Bank reorganized into Partners Trust, MHC in April, 2002.

The purpose of the liquidation account is to provide Eligible Account Holders and Supplemental Eligible Account Holders who maintain their deposit accounts with SBU Bank after the conversion with a liquidation interest in the unlikely event of the complete liquidation of SBU Bank after the conversion. Each Eligible Account Holder and Supplemental Eligible Account Holder that continues to maintain his or her deposit account at SBU Bank, would be entitled, on a complete liquidation of SBU Bank after the conversion, to an interest in the liquidation account prior to any payment to the stockholders of Partners Trust Financial Group. Each Eligible Account Holder and Supplemental Eligible Account Holder would have an initial interest in the liquidation account for each deposit account, including savings accounts, transaction accounts such as negotiable order of withdrawal accounts, money market deposit accounts, and certificates of deposit, with a balance of $50 or more held in SBU Bank on December 15, 2002, or March 31, 2004. Each Eligible Account Holder and Supplemental Eligible Account Holder would have a pro rata interest in the total liquidation account for each such deposit account, based on the proportion that the balance of each such deposit account on December 15, 2002, or March 31, 2004, bears to the balance of all deposit accounts in SBU Bank on such dates.

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If, however, on any December 31 annual closing date commencing after the effective date of the conversion, the amount in any such deposit account is less than the amount in the deposit account on December 15, 2002 or March 31, 2004, or any other annual closing date, then the interest in the liquidation account relating to such deposit account would be reduced from time to time by the proportion of any such reduction, and such interest will cease to exist if such deposit account is closed. In addition, no interest in the liquidation account would ever be increased despite any subsequent increase in the related deposit account. Payment pursuant to liquidation rights of Eligible Account Holders and Supplemental Eligible Account Holders would be separate and apart from the payment of any insured deposit accounts to such depositor. Any assets remaining after the above liquidation rights of Eligible Account Holders and Supplemental Eligible Account Holders are satisfied would be distributed to Partners Trust Financial Group as the sole stockholder of SBU Bank.

Tax Aspects

Consummation of the conversion is conditioned upon the prior receipt by Partners Trust, MHC, Partners Trust Financial Group and SBU Bank of an opinion of counsel with respect to federal and New York State income tax laws, to the effect that consummation of the transactions contemplated by the conversion will qualify as a tax-free reorganization under the provisions of the applicable codes and will not otherwise result in any material adverse tax consequences to Partners Trust, MHC, Partners Trust Financial Group, the Holding Company (as defined herein) or SBU Bank, or the account holders receiving subscription rights before or after the conversion, except in each case to the extent, if any, that subscription rights or interests in the Liquidation Account are deemed to have value on the date such rights are issued.

In the view of RP Financial, LC, the subscription rights do not have any ascertainable value, based on the fact that these rights are acquired by the recipients without cost, are nontransferable and of short duration, and afford the recipients the right only to purchase the common stock at the same price as will be paid by members of the general public in the community offering. Eligible Account Holders and Supplemental Eligible Account Holders are encouraged to consult with their own tax advisors as to the tax consequences in the event that subscription rights are deemed to have an ascertainable value. Unlike private rulings, an opinion of RP Financial is not binding on the Internal Revenue Service and the Internal Revenue Service could disagree with the conclusions reached therein.

Based on the Supreme Court's analysis in Paulsen v. Commissioner, the interests in the Liquidation Account in SBU Bank should have nominal, if any, fair market value. This conclusion is due in part to the fact that such interests may only be realized in the event of a complete liquidation of SBU Bank, which according to the rules and regulations of the Office of Thrift Supervision does not include a merger, consolidation or sale of assets or similar transaction of SBU Bank.

A private letter ruling will not be requested in connection with the conversion. Unlike private letter rulings, opinions of counsel are not binding on the Internal Revenue Service or any state tax authority, and such authorities may disagree with such opinions. In the event of such disagreement, there can be no assurance that the Holding Company, which term we use in this discussion to specifically refer to the new Delaware corporation named "Partners Trust Financial Group, Inc.," or SBU Bank would prevail in a judicial proceeding.

Partners Trust, MHC, Partners Trust Financial Group, and SBU Bank have received an opinion of counsel, Hogan & Hartson L.L.P., regarding the material federal income tax consequences of the conversion, which includes the following:

1. The conversion of Partners Trust Financial Group to an interim federal stock savings bank, still referred to as Partners Trust Financial Group, will constitute a mere change in identity, form or place of organization within the meaning of Section 368(a)(1)(F) of the Code.

2. The merger of Partners Trust Financial Group with and into SBU Bank (the "Mid-Tier Merger") will qualify as a reorganization within the meaning of
Section 368(a)(1)(A) of the Code.

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3. Partners Trust Financial Group will not recognize any gain or loss in the Mid-Tier Merger.

4. SBU Bank will not recognize any gain or loss in the Mid-Tier Merger.

5. The basis of the assets of Partners Trust Financial Group to be received by SBU Bank in the Mid-Tier Merger will be the same as the basis of such assets in the hands of Partners Trust Financial Group immediately prior to the Mid-Tier Merger.

6. The holding period of the assets of Partners Trust Financial Group to be received by SBU Bank in the Mid-Tier Merger will include the holding period of such assets in the hands of Partners Trust Financial Group immediately prior to the Mid-Tier Merger.

7. Partners Trust Financial Group stockholders will not recognize any gain or loss upon their constructive exchange of Partners Trust Financial Group common stock in the Mid-Tier Merger.

8. The conversion of Partners Trust, MHC to an interim federal stock savings bank, still referred to as Partners Trust, MHC, will constitute a mere change in identity, form or place of organization within the meaning of Section 368(a)(1)(F) of the Code.

9. The merger of Partners Trust, MHC with and into SBU Bank (the "MHC Merger") will qualify as a reorganization within the meaning of Section 368(a)(1)(A) of the Code.

10. The exchange in the MHC Merger of Eligible Account Holders' and Supplemental Account Holders' interests in Partners Trust, MHC for interests in a Liquidation Account established in SBU Bank will satisfy the continuity of interest requirement of Section 1.368-1(e) of the Treasury Regulations.

11. In the MHC Merger, Partners Trust, MHC will not recognize any gain or loss on the transfer of its assets to SBU Bank, SBU Bank's assumption of its liabilities, and the cancellation of shares of common stock of SBU Bank that Partners Trust, MHC received in the Mid-Tier Merger, except to the extent the fair market value of the interests in the Liquidation Account, if any, plus the amount of liabilities assumed exceeds Partners Trust, MHC's basis in the assets transferred.

12. SBU Bank will not recognize any gain or loss in the MHC Merger.

13. The basis of the assets of Partners Trust, MHC to be received by SBU Bank in the MHC Merger will be the same as the basis of such assets in the hands of Partners Trust, MHC immediately prior to the MHC Merger.

14. The holding period of the assets of Partners Trust, MHC to be received by SBU Bank in the MHC Merger will include the holding period of such assets in the hands of Partners Trust, MHC immediately prior to the MHC Merger.

15. Eligible Account Holders and Supplemental Account Holders will recognize gain, if any, upon the issuance to them of an interest in the Liquidation Account in SBU Bank and the non-transferable subscription rights to purchase Holding Company common stock, but only to the extent of the fair market value, if any, of the non-transferable subscription rights and the interest in the Liquidation Account.

16. The merger of SBU Interim Savings Bank, an interim federal savings bank subsidiary of the Holding Company ("Interim") into SBU Bank, with SBU Bank surviving the merger (the "SBU Bank Merger"), will qualify as a reorganization within the meaning of Section 368(a)(1)(A) of the Code pursuant to Section 368(a)(2)(E) of the Code.

17. In the SBU Bank Merger, Interim will not recognize any gain or loss on the transfer of its assets to SBU Bank in exchange for SBU Bank common stock and the assumption by SBU Bank of the liabilities, if any, of Interim.

18. SBU Bank will not recognize any gain or loss upon the receipt of the assets of Interim in the SBU Bank Merger.

19. The Holding Company will not recognize any gain or loss upon its receipt of SBU Bank common stock in exchange for Interim common stock in the SBU Bank Merger.

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20. Partners Trust Financial Group stockholders other than Partners Trust, MHC
(who by virtue of the Mid-Tier Merger will be considered SBU Bank stockholders) (the "Minority Stockholders") will not recognize any gain or loss upon the exchange of their common stock solely for shares of Holding Company common stock in the Bank Merger.

21. The payment of cash in lieu of fractional shares of the Holding Company to Minority Stockholders will be treated as though the fractional shares were distributed as part of the SBU Bank Merger and then redeemed by the Holding Company. The cash payments will be treated as distributions in full payment for the fractional shares deemed redeemed under Section 302(a) of the Code, with the result that such stockholders will have short-term or long-term capital gain or loss to the extent that the cash they receive differs from the basis allocable to such fractional shares.

22. Each Minority Stockholder's aggregate basis in his or her Holding Company common stock received in the SBU Bank Merger will be the same as the aggregate basis of the common stock surrendered in exchange therefor. It is more likely than not that the basis of the Holding Company common stock purchased in the Offering by the exercise of the nontransferable subscription rights will be the purchase price thereof.

23. Each Minority Stockholder's holding period in his or her Holding Company common stock received in the SBU Bank Merger will include the period during which the common stock surrendered was held (which would include the holding period of such stockholder's Partners Trust Financial Group common stock prior to the Mid-Tier Merger), provided that the common stock surrendered (or the Mid-Tier Holding Company common stock surrendered in the Mid-Tier Merger) was a capital asset in the hands of the stockholder on the date of the exchange. The holding period of the Holding Company common stock purchased pursuant to the exercise of a subscription right shall commence on the date on which the right was exercised.

24. No gain or loss will be recognized by the Holding Company on the receipt of money in exchange for Holding Company common stock sold in the offering.

The federal tax opinion of Hogan & Hartson L.L.P. has been filed with the Securities and Exchange Commission as an exhibit to the registration statement. An opinion regarding New York state income tax consequences consistent with the federal tax opinion is being issued by Hogan & Hartson L.L.P., counsel to Partners Trust, MHC, Partners Trust Financial Group and SBU Bank.

Certain Restrictions on Purchase or Transfer of Our Shares After Conversion

All shares of common stock purchased in the offering by our directors or executive officers generally may not be sold for a period of one year following the closing of the conversion, except in the event of the death of the director or executive officer. Shares purchased by these persons after the conversion will be free of this restriction. Each certificate for restricted shares will bear a legend giving notice of this restriction on transfer, and instructions will be issued to the effect that any transfer within this time period of any certificate or record ownership of the shares other than as provided above is a violation of the restriction. Any shares of common stock issued at a later date as a stock dividend, stock split, or otherwise, with respect to the restricted stock will be similarly restricted. Our directors and executive officers also will be restricted by the insider trading rules promulgated pursuant to the Securities Exchange Act of 1934.

Purchases of shares of our common stock by any of our directors, executive officers and their associates, during the three-year period following the closing of the conversion may be made only through a broker or dealer registered with the Securities and Exchange Commission, except with the prior written approval of the Office of Thrift Supervision. This restriction does not apply, however, to negotiated transactions involving more than 1% of our outstanding common stock or to purchases of our common stock by our stock option plan or any of our tax-qualified employee stock benefit plans or nontax-qualified employee stock benefit plans, including any recognition and retention plans or restricted stock plans.

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We have filed with the Securities and Exchange Commission a registration statement under the Securities Act of 1933 for the registration of the common stock to be issued in the conversion. This registration does not cover the resale of the shares. Shares of common stock purchased by persons who are not affiliates of Partners Trust Financial Group may be resold without registration. Shares purchased by an affiliate of Partners Trust Financial Group will have resale restrictions under Rule 144 of the Securities Act. If we meet the current public information requirements of Rule 144, each of our affiliates who complies with the other conditions of Rule 144, including those that require the affiliate's sale to be aggregated with those of certain other persons, would be able to sell in the public market, without registration, a number of shares not to exceed, in any three-month period, the greater of 1% of our outstanding shares or the average weekly volume of trading in the shares during the preceding four calendar weeks. Provision may be made in the future to permit our affiliates to have their shares registered for sale under the Securities Act under certain circumstances.

Office of Thrift Supervision regulations prohibits us from repurchasing our common stock during the first year following conversion unless compelling business reasons exist for such repurchases. After one year, the Office of Thrift Supervision does not impose any repurchase restrictions.

Interpretation, Amendment and Termination

To the extent permitted by law, all interpretations by us of the plan of conversion will be final; however, such interpretations have no binding effect on the Office of Thrift Supervision. The plan of conversion provides that, if deemed necessary or desirable, we may substantively amend the plan of conversion as a result of comments from regulatory authorities or otherwise, without the further approval of Partners Trust, MHC's members or Partners Trust Financial Group's stockholders.

Completion of the conversion requires the sale of all shares of the common stock within 24 months following approval of the plan of conversion by Partners Trust, MHC's members and Partners Trust Financial Group's stockholders. If this condition is not satisfied, the plan of conversion will be terminated and Partners Trust Financial Group will continue its business in the mutual holding company form of organization. We may terminate the plan of conversion at any time.

Comparison of Stockholders' Rights for Existing Stockholders of Partners Trust Financial Group

As a result of the conversion and reorganization, existing stockholders of Partners Trust Financial Group will become stockholders of new Partners Trust Financial Group. There are differences in the rights of stockholders of Partners Trust Financial Group and stockholders of new Partners Trust Financial Group caused by differences between federal and Delaware law and regulations and differences in Partners Trust Financial Group's federal stock charter and bylaws and new Partners Trust Financial Group's Delaware certificate of incorporation and bylaws.

Set forth below is a general summary of the material differences between the rights of existing holders of common stock of Partners Trust Financial Group, and their prospective rights as holders of common stock of new Partners Trust Financial Group. This discussion is not intended to be a complete statement of the differences affecting the rights of stockholders, but rather summarizes the material differences affecting the rights of stockholders. This discussion is qualified in its entirety by reference to the federal and Delaware certificates of incorporation and bylaws of Partners Trust Financial Group and federal law and the Delaware General Corporation Law. See "Where You Can Find Additional Information" for procedures for obtaining a copy of the certificates of incorporation and bylaws of Partners Trust Financial Group, Inc., a federal corporation, and Partners Trust Financial Group, Inc., a Delaware corporation.

Authorized Capital Stock. Our authorized capital stock currently consists of 35,000,000 shares of common stock, par value $0.10 per share, and 5,000,000 shares of preferred stock. After the conversion, our authorized capital stock as a Delaware corporation will consist of 190,000,000 shares of common stock, $0.0001 par value

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per share, and 10,000,000 shares of preferred stock, par value $0.0001 per share. We authorized more capital stock than will be issued in the conversion and acquisition of BSB Bancorp, Inc. in order to provide our board of directors with flexibility to effect, among other transactions, financings, acquisitions, stock dividends, stock splits and stock option grants. These additional authorized shares may also be used by our board of directors, however, consistent with its fiduciary duty, to deter future attempts to gain control of new Partners Trust Financial Group.

Issuance of Capital Stock. Under applicable laws and regulations, Partners Trust, MHC is required to own not less than a majority of the outstanding Partners Trust Financial Group Financial Group common stock. Partners Trust, MHC will no longer exist following completion of the conversion.

New Partners Trust Financial Group's Delaware certificate of incorporation does not contain restrictions on the issuance of shares of capital stock to directors, officers or controlling persons. By comparison, Partners Trust Financial Group's federal stock charter restricts such issuances to general public offerings, or to directors for qualifying shares, unless the share issuance or the plan under which they would be issued has been approved by a majority of the total votes eligible to be cast at a legal stockholders' meeting. Thus, stock-related compensation plans, such as stock option plans and recognition and retention plans, may be adopted by new Partners Trust Financial Group without stockholder approval and shares of new Partners Trust Financial Group capital stock may be issued directly to directors or officers without stockholder approval. The rules of the Nasdaq National Market System, however, generally require corporations with securities that are quoted on the Nasdaq National Market System to obtain stockholder approval of most stock compensation plans for directors, officers and key employees of the corporation. Although generally not required, stockholder approval of stock-related compensation plans also may be sought in certain instances in order to qualify such plans for favorable federal income tax and securities law treatment under current laws and regulations.

Our board of directors also has sole authority to determine the terms of any one or more series of preferred stock, including voting rights, conversion rates and dividend and liquidation preferences. As a result of the ability to fix voting rights for a series of preferred stock, our board of directors has the power, to the extent consistent with its fiduciary duty, to issue a series of preferred stock to persons friendly to management in order to attempt to block a hostile tender offer, merger or other transaction by which a third party seeks control, and thereby assist management to retain its position. We currently have no plans for the issuance of shares of preferred stock.

Payment of Dividends. The ability of Partners Trust Financial Group to pay dividends on its capital stock is restricted by Office of Thrift Supervision regulations and by federal income tax considerations related to savings associations such as SBU Bank. See "Regulation - Federal Banking Regulation - Capital Distributons"and "Taxation-Taxable Distributions and Recapture." Although new Partners Trust Financial Group is not subject to these restrictions as a Delaware corporation, these restrictions will indirectly affect new Partners Trust Financial Group because dividends from SBU Bank will be the primary source of funds of new Partners Trust Financial Group for the payment of dividends to its stockholders.

Delaware law also generally provides that new Partners Trust Financial Group is limited to paying dividends in an amount equal to the excess of its net assets (total assets minus total liabilities) over its statutory capital or, if no such excess exists, equal to its net profits for the current year and/or the immediately preceding fiscal year.

Filling of Board Vacancies; Removal of Directors. Under Partners Trust Financial Group's federal bylaws, any vacancies on the board of directors may be filled by the affirmative vote of a majority of the remaining directors. Persons elected by the board of directors of Partners Trust Financial Group to fill vacancies may only serve until the next annual meeting of stockholders. Under new Partners Trust Financial Group's Delaware certificate of incorporation, any vacancy occurring on the board of directors, including any vacancy created by reason of an increase in the number of directors, may be filled by the remaining directors, and any director so chosen shall hold office for the remainder of the term of the class to which the director has been elected and until his or her successor is elected and qualified.

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Under Partners Trust Financial Group's federal bylaws, any director may be removed only for cause by a vote of the holders of a majority of the shares then entitled to vote at an election of directors. New Partners Trust Financial Group's Delaware certificate of incorporation provides that any director may be removed only for cause by the holders of at least two-thirds of the outstanding voting shares entitled to vote generally in the election of directors.

Limitations on Liability. The federal stock charter and bylaws of Partners Trust Financial Group do not limit the personal liability of directors.

New Partners Trust Financial Group's Delaware certificate of incorporation provides that no director will be personally liable to the corporation or its stockholders for monetary damages for breach of fiduciary duty as a director other than liability (a) for any breach of the director's duty of loyalty to the corporation or its stockholders, (b) for acts or omissions not in good faith or which involve intentional misconduct or a knowing violation of law, (c) for any payment of a dividend or approval of a stock repurchase that is illegal under
Section 174 of the Delaware corporation law, or (d) for any transaction from which a director derived an improper personal benefit.

Special Meetings of Stockholders. Partners Trust Financial Group's federal bylaws provide that special meetings of stockholders may be called by the chairman, the president, a majority of the board of directors or the holders of not less than one-tenth of the outstanding capital stock entitled to vote at the meeting. Partners Trust Financial Group's federal stock charter also provides that for a period of five years from April 3, 2002 special meetings of stockholders relating to changes in control or amendments to its charter may be called only by the board of directors.

New Partners Trust Financial Group's Delaware certificate of incorporation provides that special meetings of the stockholders may be called only by majority of the directors or by the holders of not less than two-thirds of the then outstanding shares of capital stock entitled to vote generally in the election of directors.

Stockholder Nominations and Proposals. Partners Trust Financial Group's federal bylaws generally provide that stockholders may submit nominations for election of directors at an annual meeting of stockholders and may propose any new business to be taken up at such a meeting by filing the proposal in writing with Partners Trust Financial Group at least five days before the date of any such meeting.

New Partners Trust Financial Group's Delaware bylaws generally provide that any stockholder desiring to make a nomination for the election of directors or a proposal for new business must submit timely written notice to the secretary of new Partners Trust Financial Group. To be timely, a stockholder's notice must be received at the principal executive offices of new Partners Trust Financial Group no later than the date designated for receipt of stockholders' proposals in a prior public disclosure made by new Partners Trust Financial Group. If there has been no such prior public disclosure, then to be timely, a stockholder's notice must be delivered to or mailed and received at the principal executive offices of new Partners Trust Financial Group not less than 60 days nor more than 90 days prior to the annual meeting. If less than 70 days' notice of the date of the annual meeting is given to stockholders or prior public disclosure of the date of the meeting is made, notice by the stockholder to be timely must be so received not later than the close of business on the 10th day following the day on which such notice of the date of the annual meeting was mailed or such public disclosure was made. The stockholder must also satisfy specified informational requirements.

Management believes that it is in the best interests of new Partners Trust Financial Group and its stockholders to provide sufficient time to enable management to disclose to stockholders information about a dissident slate of nominations for directors. This advance notice requirement may also give management time to solicit its own proxies in an attempt to defeat any dissident slate of nominations, should management determine that doing so is in the best interests of stockholders generally. Similarly, adequate advance notice of stockholder proposals will give management time to study such proposals and to determine whether to recommend to the

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stockholders that such proposals be adopted. In certain instances, such provisions could make it more difficult to oppose management's nominees or proposals, even if stockholders believe such nominees or proposals are in their best interests.

Limitations on Voting Rights of Greater-Than-10% Stockholders. Partners Trust Financial Group's federal charter provides that, for a period of five years from April 3, 2002, no person other than Partners Trust, MHC may directly or indirectly offer to acquire or acquire the beneficial ownership of more than 10% of any class of any equity security of Partners Trust Financial Group. This limitation does not apply to the purchase of shares by underwriters in connection with a public offering, or the purchase of shares by a tax-qualified employee stock benefit plan which is exempt from the approval requirements of the Office of Thrift Supervision's regulations. If shares are acquired in violation of this provision, all shares beneficially owned by any person in excess of 10% are considered "excess shares" and may not be counted as shares entitled to vote and may not be voted by any person or counted as voting shares in connection with any matters submitted to the stockholders for a vote.

New Partners Trust Financial Group's Delaware certificate of incorporation provides that no record owner of any outstanding common stock which is beneficially owned, directly or indirectly, by a person who, as of any record date for the determination of stockholders entitled to vote on any matter, beneficially owns in excess of 10% of the then-outstanding shares of common stock is entitled or permitted to vote the shares held in excess of the 10% limit. Under this provision, neither any employee stock ownership or similar plan of new Partners Trust Financial Group or any subsidiary of new Partners Trust Financial Group, nor any plan trustee or any affiliate of such trustee (solely by reason of such capacity of such trustee), will be deemed to beneficially own any common stock held under any such plan. The number of votes which may be cast by any record owner by virtue of this provision is a number equal to the total number of votes which a single record owner of all common stock beneficially owned by the person would be entitled to cast, multiplied by a fraction, the numerator of which is the number of shares of such class which are both beneficially owned by such person and owned of record by such record owner and the denominator of which is the total number of shares of common stock beneficially owned by such person. This limitation is perpetual.

Approvals for Acquisitions of Control and Offers to Acquire Control. New Partners Trust Financial Group's Delaware certificate of incorporation prohibits any person, whether an individual, company or group acting in concert, from acquiring beneficial ownership of 25% or more of the then outstanding shares of new Partners Trust Financial Group's stock entitled to vote generally in the election of directors, unless the acquisition has been approved by holders of at least two-thirds of the outstanding shares of new Partners Trust Financial Group's stock entitled to vote generally in the election of directors and of all required federal and state regulatory authorities. This provision does not apply to the purchase of shares by underwriters in connection with a public offering or employee stock ownership plan or other employee benefit plan of new Partners Trust Financial Group or any of its subsidiaries.

Shares acquired in excess of the 25% limitation are not entitled to vote or take other shareholder action or be counted in determining the total number of outstanding shares in connection with any matter involving shareholder action. These excess shares are also subject to transfer to a trustee, selected by Partners Trust Financial Group, for sale on the open market or otherwise. The proceeds from the sale by the trustee of such excess shares will be paid (a) first, to the trustee in the amount equal to the trustee's reasonable fees and expenses, (b) second, to the beneficial owner of such excess shares in an amount up to such owner's federal income tax basis in such excess shares, and (c) third, to the Partners Trust Financial Group as to any remaining balance.

The federal stock charter of Partners Trust Financial Group, a federal corporation, does not contain a comparable provision.

Control Share Acquisitions. Under new Partners Trust Financial Group's Delaware certificate of incorporation, any acquisition of "control shares" must be approved by holders of a majority of the then outstanding shares of stock of new Partners Trust Financial Group entitled to vote generally in the election of

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directors (other than shares held by the acquiring person or member of a group proposing to make the control share acquisition and shares held by officers or employee directors of new Partners Trust Financial Group) in order for the control shares to be voted. "Control shares" are those shares that would have voting power that, when added to all the other shares of new Partners Trust Financial Group owned by a person or which that person may exercise or direct the exercise of voting power, would entitle that person, immediately after acquisition of the shares, directly or indirectly, alone or as part of a group, to exercise or direct the exercise of the voting power of new Partners Trust Financial Group in the election of directors within any of the following ranges of voting power: (a) one-fifth or more but less than a third of all voting power; (b) one-third or more but less than a majority of all voting power; or
(c) a majority or more of all voting power.

If the control shares acquired in a control share acquisition are accorded full voting rights and the acquiring person has acquired the control shares with a majority or more of all voting power, all stockholders of new Partners Trust Financial Group, other than the acquiring person, have the right under new Partner Trust Financial Group's Delaware certificate of incorporation to dissent from the granting of voting rights and to demand payment of the fair value of their shares. For purposes of this provision, the fair value of the shares may not be less than the highest price per share paid in the control share acquisition.

If an acquiring person acquires control shares in violation of the provisions of new Partner Trust Financial Group's Delaware certificate of incorporation, new Partners Trust Financial Group may redeem the control shares at a redemption price per share equal to the average per share price paid by the acquiring person for such shares.

The acquisition of shares will not constitute a control share acquisition if the acquisition is consummated: (a) pursuant to the laws of descent and distribution; (b) pursuant to the satisfaction of a pledge or other security interest created in good faith and not for the purpose of circumventing this control share acquisition provisions; (c) pursuant to a merger or plan of consolidation if new Partners Trust Financial Group is a party to the agreement of merger or consolidation; or (d) pursuant to a tender or exchange offer that is made pursuant to an agreement to which new Partners Trust Financial Group is a party, or directly from new Partners Trust Financial Group, or from any of its wholly owned subsidiaries.

The federal stock charter of Partners Trust Financial Group, a federal corporation, does not contain a comparable provision.

Mergers, Consolidations and Sales of Assets.Federal regulations do not expressly address the votes required for mergers, consolidations or sales of all or substantially all of Partners Trust Financial Group's assets.

New Partners Trust Financial Group's Delaware certificate of incorporation requires the approval of the holders of at least (a) 80% of the outstanding shares of stock entitled to vote generally in the election of directors and (b) two-thirds of the voting power of the outstanding shares entitled to vote generally in the election of directors excluding shares held by the "interested stockholder" and any associates or affiliates of the interested stockholder to approve certain "business combinations" involving an "interested stockholder" except where:

• the proposed transaction has been approved by two-thirds of the members of the board of directors who are unaffiliated with the interested stockholder and who were directors prior to the time when the interested stockholder became an interested stockholder; or

• certain "fair price" provisions are complied with.

The term "interested stockholder" includes any individual, corporation, partnership or other entity, other than new Partners Trust Financial Group, any subsidiary of new Partners Trust Financial Group or any employee stock purchase plan, pension plan, profit sharing plan or other employee benefit plan of new Partners Trust Financial Group or any subsidiary, which owns beneficially or controls, directly or indirectly, 5% or more of the outstanding shares of stock entitled to vote generally in the election of directors of new Partners Trust Financial

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Group, or an affiliate of such person or entity. This provision applies to any "business combination," which is defined to include, among other transactions:

• any merger or consolidation of new Partners Trust Financial Group or any subsidiary with or into any interested stockholder;

• any sale, lease, exchange, mortgage, pledge, transfer, or other disposition of assets other than in the ordinary course of business to an interested stockholder having a book value of 10% or more of the fair market value of the outstanding shares of new Partners Trust Financial Group or of its net worth as of the most recent fiscal quarter;

• the issuance or transfer of equity securities of new Partners Trust Financial Group or a subsidiary to an interested stockholder having a value of 5% or more of the fair market value of the outstanding shares of new Partners Trust Financial Group or such subsidiary, but excluding issuances of equity securities pro rata to all stockholders;

• the adoption of any plan or proposal for the liquidation or dissolution of new Partners Trust Financial Group or any subsidiary of new Partners Trust Financial Group proposed by an interested stockholder; or

• any reclassification of securities, any recapitalization, or any merger with a subsidiary or other transaction that has the effect of increasing an interested stockholder's proportionate share of any class of equity or convertible securities of new Partners Trust Financial Group or any subsidiary.

Under the Delaware General Corporation Law, absent this provision, business combinations, including mergers, consolidations and sales of substantially all of the assets of a corporation must, subject to certain exceptions, be approved by the vote of the holders of a majority of the outstanding shares of new Partners Trust Financial Group entitled to vote thereon.

In addition, under the Delaware General Corporation Law, a corporation is prohibited from engaging in any business combination with a stockholder who, together with its affiliates or associates, owns, or who is an affiliate or associate of the corporation and within the previous three years did own, 15% or more of the corporation's voting stock, for a three-year period following the time the stockholder became an interested stockholder, unless:

• prior to the time the stockholder became an interested stockholder, the board of directors of the corporation approved either the business combination or the transaction which resulted in the stockholder becoming an interested stockholder;

• the interested stockholder owned at least 85% of the voting stock of the corporation, excluding specified shares, upon consummation of the transaction which resulted in the stockholder becoming an interested stockholder; or

• at or subsequent to the time the stockholder became an interested stockholder, the business combination is approved by the board of directors of the corporation and authorized by the affirmative vote, at an annual or special meeting and not by written consent, of at least 66 2/3% of the outstanding voting shares of the corporation, excluding shares held by that interested stockholder.

A business combination generally includes:

• mergers, consolidations and sales or other dispositions of 10% or more of the assets of a corporation to or with an interested stockholder;

• specified transactions resulting in the issuance or transfer to an interested stockholder of any capital stock of the corporation or its subsidiaries; and

• other transactions resulting in a disproportionate financial benefit to an interested stockholder.

A Delaware corporation may exempt itself from the requirements of the Delaware statute by, among other things, adopting an amendment to its certificate of incorporation. New Partners Trust Financial Group has not taken any action to exempt itself from the application of this provision and therefore is governed by this provision.

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The increased stockholder vote required to approve a business combination may have the effect of preventing mergers and other business combinations which a majority of stockholders deem desirable and placing the power to prevent such a merger or combination in the hands of a minority of stockholders.

Under the Delaware General Corporation Law, no stockholder vote is required for a merger not involving an interested stockholder in which Partners Trust Financial Group is the surviving corporation if (a) the agreement of merger does not amend new Partners Trust Financial Group's certificate of incorporation, (b) each share of stock of new Partners Trust Financial Group outstanding immediately before the merger is an identical share of new Partners Trust Financial Group after the merger and (c) the shares of common stock of new Partners Trust Financial Group to be issued or delivered under the plan of merger, plus those initially issuable upon conversion of any securities or obligations to be issued or delivered under such plan, do not exceed 20% of the shares of common stock of new Partners Trust Financial Group outstanding immediately before the merger.

Criteria for Evaluating Offers. New Partners Trust Financial Group's Delaware certificate of incorporation provides that the board of directors, when evaluating any offer of another party to (a) make a tender or exchange offer for any equity security of new Partners Trust Financial Group, (b) merge or consolidate new Partners Trust Financial Group with another institution, or (c) purchase or otherwise acquire all or substantially all of the properties and assets of new Partners Trust Financial Group, will, in connection with the exercise of its judgment in determining what is in the best interests of new Partners Trust Financial Group and its stockholders, be authorized to give due consideration to any such factors as the board of directors determines to be relevant, including, without limitation, the economic effects of acceptance of the offer on depositors, borrowers and employees of its insured institution subsidiaries and on the communities in which its subsidiaries operate or are located, as well as on the ability of its subsidiaries to fulfill the objectives of insured institutions under applicable federal statutes and regulations.

The federal stock charter of Partners Trust Financial Group does not contain a comparable provision.

Dissenters' Rights of Appraisal. Office of Thrift Supervision regulations generally provide that a stockholder of a federally chartered corporation that engages in a merger, consolidation or sale of all or substantially all of its assets shall have the right to demand from such institution payment of the fair or appraised value of his or her stock in the corporation, subject to specified procedural requirements. However, if the federally chartered corporation's stock is listed on a national securities exchange or quoted on the Nasdaq Stock Market, stockholders are not entitled to dissenters' rights in connection with a merger if the stockholders are required to accept cash or shares of stock which will be listed on a national securities exchange or quoted on the Nasdaq Stock Market, or any combination thereof.

Under Delaware law, except for cash merger transactions, stockholders of new Partners Trust Financial Group generally will not have dissenters' appraisal rights in connection with a plan of merger or consolidation to which new Partners Trust Financial Group is a party because the common stock is expected to be listed on the Nasdaq National Market.

As described above under "- Control Share Acquisitions," if control shares acquired in a control share acquisition are accorded full voting rights and the acquiring person has acquired the control shares with a majority or more of all voting power, all stockholders of new Partners Trust Financial Group, other than the acquiring person, have the right under new Partner Trust Financial Group's Delaware certificate of incorporation to dissent from the granting of voting rights and to demand payment of the fair value of their shares.

Amendment of Governing Instruments. No amendment of Partners Trust Financial Group's federal stock charter may be made unless it is first proposed by the board of directors, then preliminarily approved by the Office of Thrift Supervision and thereafter approved by the holders of a majority of the total votes eligible to be cast, unless a higher vote is otherwise required and approved or preapproved by the Office of Thrift Supervision.

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Amendments to new Partners Trust Financial Group's certificate of incorporation must first be proposed by at least two-thirds of the directors and thereafter must be approved by the vote of the holders of a majority of the outstanding shares stock entitled to vote generally in the election of directors, except that:

• the provisions governing the number and staggered three-year terms of directors, vacancies on the board of directors and removal of directors, limitation of director liability, the calling of special meetings of stockholders, action by unanimous written consent of stockholders, approval for acquisitions of control and offers to acquire control, control share acquisitions, criteria for evaluating offers, indemnification of officers and directors and the manner of amending the certificate of incorporation may not be repealed, altered, amended or rescinded except if proposed by a vote of two-thirds of the directors and thereafter approved by the holders of at least two-thirds of the outstanding shares of stock entitled to vote thereon; and

• the provisions governing the approval of specified business combinations involving interested stockholders may not be repealed, altered, amended or rescinded except if proposed by a vote of two-thirds of the directors and thereafter approved by the holders of at least 80% of the outstanding shares of stock entitled to vote thereon.

The federal bylaws of Partners Trust Financial Group may be amended by a majority vote of the board of directors or by a majority vote of the votes cast by the stockholders and receipt of any applicable regulatory approval.

New Partners Trust Financial Group's Delaware bylaws may only be amended by a majority vote of the board of directors or by the holders of at least 80% of the outstanding stock entitled to vote generally in the election of directors.

Purpose and Anti-Takeover Effects of Partners Trust Financial Group's Delaware Certificate of Incorporation and Bylaws. New Partners Trust Financial Group's Delaware certificate of incorporation and bylaws and Delaware law contain a number of provisions that may have the effect of discouraging future takeover attempts. These provisions include the above-described provisions of its certificate of incorporation and bylaws governing the removal of directors, the calling of special meetings of stockholders, limitations on voting rights of greater-than-10% stockholders, approval for acquisitions of control and offers to acquire control, control share acquisitions, approval of business combinations with 5% or greater stockholders, criteria for evaluating offers and the manner of amending the certificate of incorporation and bylaws, as well as the provisions of Delaware law relating to approval of certain business combinations with stockholders owning 15% or more of the stock entitled to vote generally in the election of directors. In addition, under its certificate of incorporation:

• The board of directors is divided into three classes. The members of each class are elected for a term of three years, with one class elected annually. Thus, it would take at least two annual elections to replace a majority of Partners Trust Financial Group's board of directors;

• The number of directors constituting the board of directors may not be fewer than five nor more than fifteen, with the number of directors within the range fixed by a majority vote of the board of directors

• Cumulative voting is not permitted in the election of directors;

• Vacancies in the board of directors, including those resulting from an increase in the size of the board, may be filled for the remaining term of the class in which the vacancy occurred;

• Action by stockholders in lieu of a meeting must be by unanimous written consent; and

• The board of directors is authorized to issue preferred stock having a preference as to dividends or liquidation over the common stock without stockholder approval. The issuance of preferred stock could adversely affect the voting power of the holders of the common stock and could be used to discourage, delay or prevent a change in control of Partners Trust Financial Group.

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The Partners Trust Financial Group board of directors believes that these provisions are prudent and in the best interests of new Partners Trust Financial Group and its stockholders and will reduce the new Partners Trust Financial Group's vulnerability to takeover attempts and certain other transactions that have not been negotiated with and approved by the Partners Trust Financial Group board of directors. These provisions also will assist the new Partners Trust Financial Group in the orderly deployment of the conversion proceeds into productive assets during the initial period after the conversion. The Partners Trust Financial Group board of directors believes that it will be in the best position to determine the true value of new Partners Trust Financial Group and to negotiate more effectively for what may be in the best interests of its stockholders. Accordingly, the Partners Trust Financial Group board of directors believes that it is in the best interests of new Partners Trust Financial Group and its stockholders to encourage potential acquirers to negotiate directly with the board of directors of new Partners Trust Financial Group and that these provisions will encourage such negotiations and discourage hostile takeover attempts. It is also the view of the Partners Trust Financial Group board of directors that these provisions should not discourage persons from proposing a merger or other transaction at a price reflective of the true value of new Partners Trust Financial Group and that is in the best interests of all stockholders.

Takeover attempts that have not been negotiated with and approved by the Partners Trust Financial Group board of directors present the risk of a takeover on terms that may be less favorable than might otherwise be available. A transaction that is negotiated and approved by the new Partners Trust Financial Group board of directors, on the other hand, can be carefully planned and undertaken at an opportune time in order to obtain maximum value of new Partners Trust Financial Group for its stockholders, with due consideration given to matters such as the management and business of the acquiring corporation and maximum strategic development of new Partners Trust Financial Group's assets.

Although a tender offer or other takeover attempt may be made at a price substantially above the current market price, such offers are sometimes made for less than all of the outstanding shares of a target company. As a result, stockholders may be presented with the alternative of partially liquidating their investment at a time that may be disadvantageous, or retaining their investment in an enterprise that is under different management and whose objectives may not be similar to those of the remaining stockholders.

Despite the Partners Trust Financial Group board of directors' belief as to the benefits to stockholders of these provisions of new Partners Trust Financial Group's Delaware certificate of incorporation and bylaws, these provisions may also have the effect of discouraging a future takeover attempt that would not be approved by the new Partners Trust Financial Group board of directors, but pursuant to which stockholders would otherwise receive a substantial premium for their shares over then current market prices. As a result, stockholders who might desire to participate in such a transaction may not have any opportunity to do so. Such provisions will also make it more difficult to remove the new Partners Trust Financial Group board of directors and management. The Partners Trust Financial Group board of directors, however, has concluded that the potential benefits outweigh the possible disadvantages.

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PARTNERS TRUST FINANCIAL GROUP'S PROPOSAL II AND