ANDBANK RESEARCH
Global Economics &
Markets
Alex Fusté
Chief Economist
[email protected]
+376 881 248
Working paper - 54
Understanding the regional financing system in Spain
September 11th, 2013
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The discussion on the process of
decentralization and regional financing in Spain,
which opens with the 1978 Constitution, has
not helped in resolving disputes about the
concept of equity and efficiency.
With the passage of time, and now with the
crisis, the sharpness of the debate has
intensified, reaching worrying levels and giving
wings to independence sentiments in key
regions that, being already at significant levels
of acceptance and political representation, could
destabilize the entire economy of the state as a
whole.
Indeed, there is room for improvement, and the
leeway is more or less extensive depending on
what level of solidarity we had defined as
sufficient.
(My special thanks to Mr. Angel de la Fuente,
who had the courtesy and patience to respond
to many of our queries).
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The current system of regional financing in Spain is based on
four principles
1. An initial assessment of the differences among regions
2. An assessment of the relative costs and spending needs of
each region. The concept of “adjusted population”
3. The allocation of resources
4. The equalization mechanism
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1st. Differences among regions are significant
The only two regions that operate under the Foral Regime (Special status) are the Basque Country
and Navarra. Given historical rights, both regions enjoy greater tax autonomy. Precisely the two with
the highest GDP per capita. The other regions operate under the Common Regime (normal status).
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2nd. The relative spending needs of each region - The concept
of “adjusted population” as criterion for allocating resources to
each region
1. The equalization mechanism incorporates a formula to quantify the resources needed in each
region to fund a uniform level of public services. This formula is implemented through the
calculus of a variable based on the concept of “adjusted population” (rather than real
population).
2. What you get with this operation is a regional population adjusted by a factor that reflects the
cost differential in per capita terms of the main public services. This cost differential can be
higher (or lower) due to factors such as greater aging of the population or greater dispersion, to
cite two examples.
Per capita expenditure needs to finance a uniform level of public
services (relative cost)
Variables considered in the calculation of the
Regional Spending Needs (relative cost)
Protected population equivalent
Population
School-age population (0-16)
Population 65+
Extension of the territory
Dispersion of the population
Insularity
Factor
Weight
Regions less densely populated and more aged,
have higher relative costs for a uniform level of
public sectors, thus, have higher spending needs
per capita
38%
30%
20,5%
8,5%
1,8%
0,6%
0,6%
Angel de la Fuente – published by BBVA. Working paper 12/27
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3rd. The allocation of resources - The central government has
entrusted its regions with key responsibilities. In order for the
regions to finance these responsibilities, it has allocated a high
share of taxes to the regional level …
TABLE 1 – RESOURCES & COMPETENCES TRANSFERRED TO THE REGIONS
•
The share of taxes that the regions can keep has been increased (2009 financing pact between central government & regions)…
•
… increasing the fiscal autonomy of the Spanish regions operating under the Common Regime…
•
… although, admittedly, the regions are still only marginally involved in direct tax collection.
•
At this point, we have realized that some analysts believe the full effects of the new system will be seen in 2014, based on
the hypothesis that the new settlement will take place in 2014. This is FALSE, since the new regime applies from 2011.
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4th. The equalization mechanism - The two elements in charge
of allocating the resources.
1. Guarantee Fund for Basic Public Services (Horizontal mechanism)
1. The Fund is fed with the 75% of theoretical tax revenues of the regions, plus an extra EUR 7.4bn contribution
from the central government.
2. This fund represents 70% of total resources available in the system
3. The fund's resources are shared between communities each year in proportion to the needs of equivalent public
spending and according to the “adjusted population” criteria.
4. In essence, this Fund receives resources from the regions and then distributes these resources among them. It
is, therefore, a horizontal leveling mechanism.
2. Other Funds with a vertical nature
1. Sufficiency Fund
•
These funds channel economic transfers from central government to
regional governments
•
The distribution criteria used is very wide, considering logical adjustment
factors (income per capita, density of population, etc.) but also some
factors that could be considered not so logical (the principle of maintaining
the status quo). This is, the assurance that no one will lose out with a
change made in the system. Which would perpetuate, if anything, an unfair
sharing mechanism.
2. Cooperation Fund
3. Convergence Fund
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And now, having considered the four principles and checked how
the mechanisms of equalization are implemented (resulting in the
Common Regime of regional financing system), let us see what
the results are.
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The starting point – What would be the financing capacity of
each region without applying equalization mechanism? That is, the
tax revenue that corresponds to each region given the distribution of fiscal resources
described in Table 1
Gross Fiscal
Capacity
Fiscal Capacity of each Region at homogeneous competences
150
Canary Is.
Extremadura
C. la Mancha
Andalusia
Galicia
Murcia
Valencia
C. León
Asturias
Rioja
Aragón
Cantabria
Catalonia
Balearic Is.
Madrid
51.8
72.0
81.9
82.2
84.5
86.2
92.3
94.9
100.1
101.0
106.1
108.5
118.6
124.5
143.3
Average
Max-Min
Desv. Standard
100
52.5 *
22.4
140
130
120
110
100
90
80
70
60
Gross Fiscal Capacity
50
(1) All the values are relative funding rates per capita, where the ensemble average is normalized to 100
(2) All the calculations are made at homogeneous levels of competences, excluding the resources dedicated to fund singular competences only
assumed by some regions (regional police, prisons, etc.). If we include them, the resources perceived will be greater (and also the spending incurred)
(3) These calculations also make an adjustment to incorporate in this line the resources received for linguistic policies. Some argue that this resources
should be placed in the computation of Financing for Singular competences (and thus, be excluded from this chart). However, in 2009, as part of the
regional financing agreement, it was agreed to increase the official assessment of the linguistic competences, multiplying its previous value by 3.5
times. Assuming that the initial assessment of this competence had been made in a reasonable manner, it is hardly justifiable to remove an increase of
this magnitude from the computation of the homogeneous fiscal capacity.
(4) Source: De la Fuente (2012a)
* Exluding outliers
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The results of the system (I) – What is the financing capacity
of each region after applying the first level of the equalization
mechanism? (The fund with a horizontal nature or the Guarantee Fund)
Gross
Fiscal
Capacity
Fiscal Capacity post
1st equalization
(after applying the
Guarantee Fund)
Canary Is.
Extremadura
C. la Mancha
Andalusia
Galicia
Murcia
Valencia
C. León
Asturias
Rioja
Aragón
Cantabria
Catalonia
Balearic Is.
Madrid
51.8
72.0
81.9
82.2
84.5
86.2
92.3
94.9
100.1
101.0
106.1
108.5
118.6
124.5
143.3
97.3
93.7
95.8
96.0
96.1
97.2
95.9
99.2
99.1
100.4
99.2
97.8
103.3
106.4
110.8
Average
Max-Min
Desv. Standard
100
52.5 *
22.4
100
17.1
4.5
150
140
130
120
Spanish Regions 2010, resources per capita
before and after 1st level of equalization
The application of the Guarantee Fund significantly
reduces the disparities in available resources
between the regions, with respect to the original
ordering in Gross Fiscal Capacity
110
100
90
80
70
Gross Fiscal Capacity
60
After Guarantee Fund
50
Source: De la Fuente (2012a), published by BBVA, Working Document 12/27 as of November 2012
* Exluding outliers
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The results of the system (II) – What is the financing capacity
of each region after applying the two levels of equalization?
(Both the Horizontal Fund (Guarantee Fund) and the Vertical Transfers (Sufficiency,
Cooperation and Convergence Funds)
Gross
Fiscal
Capacity
Fiscal Capacity post
1st equalization
(after applying the
Guarantee Fund)
Fiscal Capacity post 2nd
equalization (after
applying the vertical
economic transfers)
Canary Is.
Extremadura
C. la Manc ha
Andalusia
Galic ia
Murc ia
Valenc ia
C. León
Asturias
Rioja
Aragón
Cantabria
Catalonia
Balearic Is.
Madrid
51.8
72.0
81.9
82.2
84.5
86.2
92.3
94.9
100.1
101.0
106.1
108.5
118.6
124.5
143.3
97.3
93.7
95.8
96.0
96.1
97.2
95.9
99.2
99.1
100.4
99.2
97.8
103.3
106.4
110.8
95.3
113.0
98.7
95.9
105.5
95.3
92.9
109.4
107.4
115.9
104.9
117.9
99.3
102.4
100.7
Average
Max-Min
Desv. Standard
100
52.5 *
22.4
100
17.1
4.5
100
25.0
7.8
Spanish Regions 2010, resources per capita
before and after 2nd level of equalization (vertical & horizontal)
150
140
130
120
110
100
90
80
Gross Fiscal Capacity
70
After Guarantee Fund
60
After Vertical Transfers
50
Sourc e: De la Fuente (2012a), published by BBVA, Working Doc ument 12/27 as of November 2012
* Exluding outliers
The effect of the Vertical Transfers (from Central Government) is quite different. This element drives up
dispersion of fiscal capacity (funding) per capita in adjusted terms.
Extremadura wins 12 positions in fiscal capacity after total equalization. Catalonia and Madrid lose 7 and 8
positions respectively.
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Comparing with other economies - Equalization in Spain is by
no means as “extensive” as in Germany
• Whereas the resources per capita after equalization are similar for all German states (with slightly
higher figures for the wealthier states, and those with lower resources are lifted to a minimum level),
the picture after equalization within regions looks markedly different in Spain.
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This apparent arbitrariness of central government (that leads to a
higher dispersion of fiscal capacity per person) may (and only may)
respond to a broader objective: further reducing the total resources
(private & public) available within each region after equalization.
Fiscal Capacity
post 2nd
equalization
Fiscal Capacity x
cap post 2nd
equalization
(100 = 6027 of
Asturias)
Total resources within a
region after 2nd
equalization (GDP less
fiscal load + Fiscal
capacity after 2nd
equalization)
5,929
95.3
5,744
19,383
4,555
113.0
6,811
17,650
17,698
5,171
98.7
5,949
18,475
16,960
5,029
95.9
5,780
17,711
84.5
20,723
6,043
105.5
6,358
21,039
Murcia
86.2
18,520
5,480
95.3
5,744
18,784
Valencia
92.3
19,964
6,006
92.9
5,599
19,557
C. León
94.9
22,289
6,600
109.4
6,594
22,283
Asturias
100.1
21,035
6,027
107.4
6,473
21,481
Rioja
101.0
25,508
8,000
115.9
6,985
24,493
Aragón
106.1
25,540
7,731
104.9
6,322
24,132
Cantabria
108.5
22,341
6,450
117.9
7,106
22,997
Catalonia
118.6
27,248
7,944
99.3
5,985
25,289
Balearic Is.
124.5
24,393
7,309
102.4
6,172
23,256
Madrid
143.3
29,385
8,785
100.7
6,069
26,669
Gross Fiscal
Capacity per
capita at
homog comp
(Index)
Gross GDP
per capita
Theoretical Fiscal
Resources (€bn
per capita) *
Canary Is.
51.8
19,568
Extremadura
72.0
15,394
C. la Mancha
81.9
Andalusia
82.2
Galicia
Average
100
Max-Min
52.5
8,999
5,606
Desv. Standard
22.4
4,003
2,891
* Computed as Regional GDP / Population * 30%. Assumes the same level of fiscal load (30% of total GDP) and the same relative presence of
corporations. It also assumes that central government spending is also equitable.
Some of the
data contained
in this table are
based on our
own estimates
which, for
reasons of data
availability, we
obtain by
applying
assumptions.
This means
they could be
inaccurate and
should
therefore be
used only as an
approximation.
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This apparent arbitrariness of central government (that leads to a
higher dispersion of fiscal capacity per person) may (and only may)
respond to a broader objective: further reducing the total resources
(private & public) available within each region after equalization. If
true, the hypothesis of arbitrariness should be removed.
Total resources per capita within each region (before
and after equalization)
29000
Some of the
data contained
in this table are
based on our
own estimates
which, for
reasons of data
availability, we
obtain by
applying
assumptions.
27000
25000
23000
21000
19000
17000
Total Resources within a region before equalization (Gross GDP per cap)
Total resources within a region after equalization
15000
This means
they could be
inaccurate and
should
therefore be
used only as an
approximation.
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And now What? A new reform of the financing system will
eventually be on the agenda, but … the timing and nature is
unpredictable
1. In the absence of economic growth, the central government will be reluctant to relinquish a
proportion of its own resources in favor of the regions.
2. Those regions currently benefiting from the system are expected to push back any reforms until
the final outcome of the current system is known in 2015.
3. Most importantly, the regions currently demanding reforms lack a united front given different
political agendas (Catalonia, Balearic Islands, Valencia, etc).
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Meanwhile, in the past few years, the Central Government
Support to the Autonomous Communities has been extensive
and is expected to continue advancing forward
The
central
government set
up two funds
with the aim of
enabling
the
centralization
of public debt
issuance
to
provide
liquidity to the
regions, with a
significant
reduction
in
funding costs.
The mechanism
includes
strengthening
conditionality
and supervision
of the regions
requesting
support,
with
the
aim
of
ensuring
the
achievement of
deficit targets
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Conclusions on the Spanish Regional Financing System
1. While the first level of equalization (Horizontal Transfers) in the regional financing system in Spain reduces significantly the disparities in
available resources between the regions (compared to the original ordering in Gross Fiscal Capacity), the effect of the Vertical Transfers
(from Central Government) drives up dispersion of fiscal capacity per capita at homogeneous levels and in adjusted terms.
2. This means that the equalization mechanism in Spain is by no means as “extensive” as in Germany. Whereas the level of fiscal resources
per capita after equalization is similar for all German states, the picture after equalization within regions looks markedly different in
Spain.
3. Admittedly, there could be deeper and complex reasons to justify an equalization resulting in a different level of fiscal resources per
capita (at homogeneous competences & adjusted population). In Spain, these reasons may be related to a starting point in income per
capita which is markedly different among regions. This means that although fully homogenizing fiscal capacity (like in Germany), total
resources (private and public) available in the different Spanish regions after equalization would continue being very different, thus
preventing convergence between regions.
4. At this point, can anyone determine which system is more fair and to whom? In the same way, can anyone determine which of the two
systems (the German or the Spanish one) is more efficient? Admittedly, the lower the solidarity the greater the growth potential for
regions that by its nature grow more, and thus greater will be the overall growth. But do not fall into this simplistic assertion. It could
result more counterproductive a higher GDP when there is only a few participants, than a lower GDP with more participants. And it is not
acceptable to use here the hypothesis that “if the ceteris paribus clause remains in the poorest regions, what can be wrong with that
the rich are richer?”. Everyone shares the sneaking suspicion that the extreme concentration of wealth, if not established a reversal
mechanism, leads to more concentration and this will end up reducing the level of potential growth. This refers to the concept of
“convergence”. So, be cautious when talking about efficiency.
5. What seems indisputable is that the level of solidarity in the Spanish regional financing system reaches higher levels than in the German
system. But let me clarify here an important issue. Solidarity in Spain is a concept that is only implemented between the regions under
the Common Regime of financing. Specifically, the weight of this solidarity is borne only by the communities that cede fiscal capacity in
favor of the most disadvantaged, to the point that the communities transferring resources enjoy even a lower fiscal capacity in favor of
the other ones. In this sense, the regions most generous with the rest (and according to the figures shown) are Catalonia, Balearic
Islands and Madrid, although in the latter case, it should be noted that this region enjoys a greater benefit of all the government
spending to fund the state structure, given its status of the state capital. Just as an example, with only 6.4 million inhabitants, Madrid
counted more than 400.000 civil servants in 2007 (6.2% of total population). Catalonia, with 7.5 million inhabitants, just counted with
277.000 civil servants (3.6% over total population) and Balearic Islands 48.000 civil servants (4.3% of total population). This relative
difference (72% higher in Madrid than in Catalonia), responds to the fact that the weight of the Central Administration staff on all public
employment in Madrid accounts 40.7%, versus just an 11.1% in Catalonia or 22.7% in Balearic Islands. In other words, the structure of
the State generates much more employment (and thus wealth) in Madrid than in the other two regions. This is why, if we adjust by this
factor, the two regions more genuinely generous with the rest would be Catalonia and Balearic Islands.
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Conclusions on the Spanish Regional Financing System
6. Two Spanish regions must be excluded from the set of autonomous communities that effectively practice the exercise of solidarity. Two
communities that, for historical reasons, do not participate of the Common Regime of regional financing but are regulated under the
Special Regime (or statutory). A regime that, honestly speaking, is much more favorable to their particular interests. These two
communities are the Basque Country and Navarra. Stressing that, being these two regions the ones with the highest level of income per
capita, are precisely those that maintain intact their gross fiscal capacity without giving even the slightest portion of that capacity.
7. There are many who argue that the system of transfers from central government to the regions is arbitrary.
Indeed, there is a range of 25 points between the regions with greater adjusted fiscal capacity and those with lower fiscal
capacity. Not that poor or rich regions are being consistently well or poorly treated (Andalusia and Murcia would be between 95
and 96 in fiscal capacity, while Extremadura is receiving 113. -100 is the average-). This is because the final ranking has nothing
to do with cost factors or tax revenues (maybe the reason that fuels the suspicion of arbitrariness). Nevertheless, and as we
have mentioned, there could be reasonable doubts that the dispersion in fiscal capacity (caused by the central government after
implementing the equalization mechanism) could have more to do with the ultimate goal of real convergence in terms of Total
Resources (public & private) available in each region, rather than with fiscal capacity. If true, the hypothesis of the arbitrariness
should be removed.
7. The fact that transfers are distributed through a complicated and opaque tangle of funds does not help to reduce suspicions about this
hypothetical arbitrariness; a point that continues to fuel the acrimony of the debate and political tension.
8. Although there may be a hypothetical and well-intended target of interregional solidarity, this is not made explicit; meaning that there is
also a lack of explicit limits to interregional solidarity in Spain. In Germany these limits are clear, thus, also the objectives.
9. As suggested by independent reports (from agencies and foreign banks), this lack of explicit limits and goals makes the estimation of
fiscal capabilities complicated for the different regions, leading to greater uncertainty as regards future expected revenues, which in turn
complicates the budgetary planning process.
10. The ability to maneuver in the regional financing system in Spain is very high, as long as the current level of solidarity
implemented is, likewise, very high.
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About the new tensions arising from Catalan nationalism.
1. The origin of the dispute: The eternal discussion on the process of decentralization and regional financing in Spain has led to an
increased bitterness of the debate (specially now with the crisis), reaching worrying levels and giving wings to independence sentiments in
key regions that, being already at significant levels of acceptance and political representation, could destabilize the entire economy of the
state as a whole.
2. The costs of the break (at a first glance):
i.
For Spain: Our assessment is of a traumatic impact. With the breakdown, the Spanish government should assume a fiscal
balance that as of today is favorable for the whole state. According to sources, the net resource flow would be favorable to Spain
in about EUR8bn, which would represent about 0.8% of GDP in new deficit, and therefore, in new adjustments. Imponderables
that may appear by the reaction of economic agents (enterprises, trade and international investment community) must also be
considered.
ii. For Catalonia: Unaffordable.
3.
First Package of issues to be considered by the hypothetically newly created state of Catalonia.
i.
Integration in the EU (a direct process?): According to sources familiar with the international laws, the ownership of the
current arrangements for Spain's membership in the EU corresponds to what is known in international law as “the Kingdom of
Spain”. Catalonia is certainly within the EU as an integral part of that kingdom (in other words, Catalonia is in the EU without
being a member but through its status of part of an EU member). Indeed, there is no history that could assist us in this matter,
but it would seem that Catalonia should request access to the EU (no direct integration), as many other independent states who
have aspired to be full. Here, we have to consider the list of countries that are still waiting to be accepted as members of the EU
(Romania and Bulgaria in 2016, Poland, Czech R and Denmark in 2017, Hungary in 2020, etc…).
ii.
Difficulties in the integration process in the Euro area: Having been part of a integral member of the euro, the integration
process should be, a priori, easier since negotiations would go through pacts already collected between the Eurozone and Spain
(agreements and assumptions for which Catalonia would have been positioning in the last years of the crisis). However, we must
not forget that after the euro crisis, which triggered numerous rescue programs for several members of the EUR, and has even
come to raise the potential expulsion of some country, will make the entry conditions revised upwards. It is also legitimate to think
that the valuation process of compliance will be much more strict and lenghty. This translates into more time. A time that
Catalonia might not have.
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… package of issues to be considered by the hypothetically
newly created state of Catalonia.
iii.
International isolation? The EU integration necessarily involves the acceptance of the norms of international laws, among which
are the Spanish laws. Some experts suggest that not having the acceptance of secession by the Spanish state, it could leave the
new state of Catalonia internationally isolated.
iv.
The distribution of assets and liabilities. As in the process featured by the Czech Republic and Slovakia in 1993, opting for the
distribution of assets and liabilities would be very costly for the new state of Catalonia, since it could not prevent inheriting a
significant part of the reality and the obligations of a highly indebted country. To the debt owed by the regional government itself
(about EUR50bn) it should be added about EUR200bn of Central Government debt resulting from the liabilities’ distribution
process. In total, the new state would have a debt that may reach the EUR250bn figure (> 100% of current GDP of Catalonia).
Admittedly, the assets should also be distributed (but public companies should first be valued, also buildings, etc ...). The
temporal mismatch between the duration of liabilities and assets will be evident, leaving Catalonia with highly liquid liabilities and
highly illiquid assets.
v.
On Social Security accounts: Here is also required an understanding to settle the contributions belonging to one and another in
a fair and reasonable basis. In the best of cases, this will require opening a transition period (probably a long one) in which both
systems should work to extinguish the mutual obligations. Failing to achieve a reasonable distribution would presumably mean the
bankruptcy of one of the two pension systems.
vi.
On the reaction of economic agents (enterprises, trade and international investors): Since the hypothetical process of
secession would be long and hard, insecurity and uncertainty generated so would. In terms of financial markets, with a debt
presumably near the EUR250bn, and with an average duration of five years in this debt (in the best case), the new state of
Catalonia would be forced to finance EUR50bn in the financial markets in the first year. Honestly, with a High Yield rating, the
current situation of financial repression, and presumably being outside of the ECB liquidity schemes, it will result highly unlikely to
see a good performance of the new state of Catalonia, at least in the initial phase of its journey (a phase that could take several
years). In a different order of things, establishing borders always affects (negatively) the flow of commerce without exception. It is
very difficult to assess at this point but, with no doubt, the flow of trade between Spain and Catalonia would be affected in the
first stages of the process, being the latter probably the most affected by such commercial alteration (due to its greater orientation
to export).
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… package of issues to be considered by the hypothetically
newly created state of Catalonia.
vii. Potential benefits of the Independence:
A.
Have all the fiscal resources available in Catalonia. No doubt, a factor that would impact positively on the
economy of the new state. However, it is also legitimate to think that most of these additional resources (if not all)
would go to cover the high costs generated by the secessionist process (higher cost of debt, trade disruption that
will result in an adjustment of GDP that, in turn, will raise public spending on social policies, etc )
B.
Political autonomy. We must understand here that the main source of the conflict between Spain and Catalonia
comes from the economic policy arena (although there have been episodes of tension in other fields of politics
such as education). Therefore, it is legitimate to thing that one of the main objectives pursued with this process is
the political autonomy, particularly in the economic area. Well. Do not forget that the euro crisis has opened a
deep process of integration among the countries that are members of the EUR. A process that inexorably leads
towards more control and intervention from Brussels as regards economic policy, entailing an explicit transfer of
fiscal policy. Since monetary policy is already fully transferred, it is clear that the space left for doing economic
policy is already limited, and will be more as the integration process will move forward.
Bottom line:
We can not ignore the economic consequences of an eventual secessionist process. The costs (quantifiable or not) should be put on the
table. To date, I have not seen even the minimal analysis providing reliable data on the effects arising from a process such as the one
proposed in Catalonia. Honestly, without assessing the legitimacy (this is something that I keep to myself and is beyond the scope of
this analysis), I strongly believe that a decision of this magnitude without putting the necessary information available to the population,
is at least, unwise.
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The financial institution cannot in any way guarantee that the predictions or events given in this document will take place, and expressly reminds
readers that any past performances mentioned do not in any circumstances imply future returns; that the investments analysed may not be
suitable for all investors; that investments can fluctuate over time in terms of their share price and value; and that any changes that might occur in
interest rates or currency exchange rates are other factors that may also make it unadvisable to follow the opinions expressed herein.
This document cannot be regarded, under any circumstances, as an offer or proposal to buy the financial products or instruments that may have
been mentioned, and all the information herein is for guidance purposes and should not be regarded as the only relevant factor when it comes to
making a decision to proceed with a specific investment.
This document does not, therefore, analyse any other determining factors for properly appraising the decision to make a specific investment, such
as the risk profile of the investor, his/her knowledge, experience and financial situation, the duration or the liquidity of the investment in question.
Consequently, investors are responsible for seeking and obtaining appropriate financial advice in order to assess the risks, costs and other
characteristics of any investments they wish to make.
The financial institution cannot accept any responsibility for the accuracy or suitability of the evaluations or estimates of the models used in the
valuations in this document, or any possible errors or omissions that may have been made when preparing this document.
The financial institution reserves the right to change the information in this document at any time, whether partially or in full.
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