Basel 2 Pillar 3 Disclosure BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 2 Index Introduction .................................................................................................................................5 Table 1 – General requirements.................................................................................................9 Table 2 – Scope of application .................................................................................................24 Table 3 – Supervisory capital structure ....................................................................................43 Table 4 – Capital adequacy......................................................................................................45 Table 5 – Credit risk: general disclosures for all banks............................................................48 Table 6 – Credit risk: disclosures for portfolios treated under the standardized approach and specialized lending and equity exposures treated under IRB approaches ..............................59 Table 7 – Credit risk: disclosures for portfolios treated under IRB approaches .......................62 Table 8 – Risk mitigation techniques......................................................................................102 Table 9 – Counterparty risk ....................................................................................................106 Table 10 – Securitization transactions....................................................................................113 Table 11 – Market risks: disclosures for banks using the internal models approach (IMA) for position risk, foreign exchange risk and commodity risk ........................................................119 Table 12 – Operational risk ....................................................................................................127 Table 13 – Equity exposures: disclosures for banking book positions...................................128 Table 14 – Interest rate risk on positions in the banking book ...............................................130 Glossary / Abbreviations.........................................................................................................132 3 BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 4 Introduction The Basel 2 discipline is an international initiative aimed to implement, inside the banks, more sensitive frameworks for the assessment of risk, calculation of regulatory capital and minimum capital requirements for banks. Further purpose is to standardize the risk assessment methods at European level. The directive also includes a detailed set of minimum requirements to ensure sound internal evaluations. Starting from January 1st, 2008 the “New regulations for the prudential supervision of banks” (Bank of Italy Circular letter n. 263/2006 and further updates) is in force; it acknowledges the rules set by the “International Convergence of Capital Measurement and Capital Standards” (EU directives n. 2006/48 and 2006/49 - Capital Requirements Directive – CRD), the new prudential discipline for banks and banking groups, in short “Basel 2”. This discipline is based on the so called three “Pillars”: Pillar 1 – defines the calculation methodology for capital requirements in order to face the typical risk of banking and financial business; Pillar 2 – requires the banks to adopt strategies and control processes aimed to ensure actual and future capital adequacy; Pillar 3 – introduces market disclosure rules: by one side capital adequacy, risk exposure of banks and banking groups and on the other side the features of the managerial and control systems. The directive defines the step-by-step enforcement of the new rules, targeted to limit the possible reduction of the capital requirements. It will reach the full effectiveness after the transition period (January 2010). Pillar 1 The new directive doesn’t change the minimum capital ratio of 8% provided by the previous regulation (Basel 1); changes are on definition and calculation of Risk Weighted Assets (RWA); risk exposure of a banking group in measured with the regulatory capital requirement, calculated with the following formula: Regulatory capital minimum capital requirement = Risk Weighted Assets The ratio coming out from this calculation has to be ≥ 8%. The risk weighted assets must be calculated using methodologies more sensitive and sophisticated, if compared to the previous ones. Further to credit risk and market risk (already ruled under Basel I), the new directive introduces a new type of risk: the operational risk. Table 1 lists the possible methodologies applicable to the capital requirements calculation in connection to the various type of risk according to Basel 2 discipline. 5 Table 1: Primary approaches to CRD Approaches for reporting capital requirements Credit Risk Market Risk Operational Risk (1) Standardized Approach (1) Standardized Approach (1) Basic Indicator Approach (BIA) (2) Foundation Internal (2) Internal Models (2) Traditional Rating Based Approach Approach (IMA) Standardized Approach (FIRB) (TSA) (3) Advanced Internal (3) Advanced Rating Based Approach Measurement Approach (AIRB) (AMA) For the purpose of the credit risk measurement, the UniCredit Group has adopted both the standardized approach and the Advanced Internal Rating Based approach (AIRB). The standardized approach for the calculation of the credit risk is very similar to the previous one, provided by Basel 1 regulation, apart the possibility to use external ratings published by authorized agencies and a more wide use of financial collaterals. The standardized approach to credit risk provides that risk assets are weighted in connection to the exposure class (“portfolio”) assigned to the counterparty or to the characteristic of the transaction; such a rating can be connected to the credit standing assigned by a third party entity acknowledged by the Bank of Italy (rating agencies). Six banks of UniCredit Group have been authorized by local supervisory entities (when established out of Italy) and in any case all of them by the Bank of Italy to use the Advanced IRB approach (AIRB). According to this methodology, the weighting factors to be applied to risk assets are set in accordance to internal assessments that banks make to the debtors (or, in some cases, on the transactions); in the AIRB approach, the whole set of parameters listed below is specifically calculated internally: EAD Exposure At Default; PD Probability of Default; LGD loss rate in case of default (Loss Given Default): it is calculated considering the expected value (eventually subject to unfavourable scenarios) of the transaction, defined as the percentage rate of loss in case of default, and the amount at the time of default (EAD); CCF Credit Conversion Factor; M Maturity; The calculation made with this methodology allows to calculate risk weighted assets more consistent with the characteristic of the counterparty. This methodology will be extended to other banks and financial entities of the Group. BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 6 The marker risk capital requirement in UniCredit Group is calculated with both the approaches provided: the internal models and the standardized method. The use of internal models is subject to the Bank of Italy (and also local regulator) approval. Operational risk capital requirements are the real new feature of Basel 2 regulations. UniCredit Group uses, for its subsidiaries, all of the three possible approaches, assigned to each subsidiary based on its size and its type of business. It is still ongoing, as well as for the IRB approaches, the extension of the AMA approach to other entities of the Group. To avoid significant impacts on capital requirements as a consequence of the first application, transitional rules (better known as “floor”) were introduced: they concern all the banks or banking groups that apply the IRB approach (credit and counterparty risk) and/or the AMA approach (operational risk). These transitional rules, to be applied from 2007 up to the end of 2009, define a minimum threshold of the requirement calculated on the basis of the previous Basel 1 rules. Pillar 2 The second pillar or Supervisory Review Process (SRP) includes the two following processes: Internal process to determine capital adequacy (internal Capital Adequacy Assessment Process – ICAAP) through the comparison of risk assessment and available capital; Supervisory Review and Evaluation Process (SREP). Therefore ICAAP means using internally developed methodologies to assess the risk profile and their embedding in the processes. ICAAP allows banks to review their risk management policy and the capital position compared to the risks assumed. The UniCredit Group has developed an approach involving: Risk identification and measurement; Capital planning, that includes setting risk appetite; Risk governance; Capital adequacy is mainly assessed at Group level and then cascaded at Division, and Legal entity level and Subgroups as well. The SRP ensures that the bank or the banking group identifies its risks, and that an adequate capital is allocated to face the risk identified, establishing suitable managerial processes directed to support these risks. The SRP encourages banks and banking groups to implement and to use better managerial techniques to monitor and to measure credit risk, market risk and operational risk in addition to what is already provided by Bank of Italy circular letter n. 263/2006. The ICAAP allows banks to review their risk management policy and the capital position compared to the risks acquired. Pillar 3 In the Bank of Italy circular letter n. 263/2006 is stated how and when Italian banks have to publish the disclosure of capital and risk management. The disclosure has to be made according to the provisions of the above mentioned circular letter, that acknowledges in full what has been provided by the XII annex to the EU directive 2006/48. The disclosure is a document on consolidated basis that has to be published once a year by the Italian banking groups in connection with the annual report. The banking groups authorized to use IRB approaches or AMA approaches publish also the following interim reports: 7 December 31st: full disclosure, both qualitative and quantitative (mandatory for all the banking groups, independently from the approaches adopted); June 30th: Update of the quantitative disclosure: only for groups that have, in one or more of their subsidiaries, the IRB and/or AMA approach; March 31st:and September 30th: Update of the regulatory capital and capital adequacy figures: only for groups that have, in one or more of their subsidiaries, the IRB and/or AMA approach; This report, on June the 30th, being a first application, has to be fulfilled on both its parts, qualitative and quantitative. With this document UniCredit Group gives complete information about all the different types of risk included in its books, both on and off-balance-sheet, about risk management and capital, according to Pillar 3 regulations. This report is structured as follows: Description of the UniCredit Group structure with the mismatches coming out from the comparison between this scope of consolidation and the IAS/IFRS one. It is important to point out that differences between the two scopes can generate different outcomes from similar set of data disclosed in both Annual report and Pillar 3; Breakdown of regulatory capital and capital adequacy; Information on credit risk shared between the standardized and IRB approaches, breakdown of the exposures with pertaining RWA and loan losses; Credit risk mitigation techniques; Market risk; Operational risk; Off-balance-sheet transactions, derivative contracts included; Securitization breakdown according to Pillar 3 requirements with the integration of structured financial instruments according to the Financial Stability Forum (FSF); Pillar 3 will be published by UniCredit and also by the parent company of the subgroups Bank Austria AG and Pekao S.A. for their scopes of consolidation. The data of regulatory capital and capital adequacy are also published in the part E of the note to the account of the financial statement, according to the provisions of Bank of Italy; further information about the various types of risk are also disclosed in the part E of the notes to the accounts in the Annual Report and in the Half Year Report. Notes: 1. All the amounts, if not differently specified, are expressed in Euro thousands; 2. Data are referred to the prudential scope of consolidation; 3. This report is a first application of the regulations, therefore no historical data are disclosed; this information will be included in the next report as at December 31st, 2008. BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 8 Table 1 – General requirements Qualitative disclosure Credit risk Group risk management (principally credit, market and operational risk and combinations of these) is performed by Group Risk Management (the CRO’s department), which is responsible for: optimising asset quality by minimising the cost of the relevant risks, in line with the risk/return objectives assigned to each business area and drawing up guidelines, policies and methodologies for the measurement and control of the above risks in line with internal and external rules and regulations. The Risk Committee, which is chaired by the CEO and comprises the Deputy CEOs, the CRO, the CFO and the CSO, provides advice and proposals to governing bodies or risk decision-taking bodies that (according to their responsibility and function) approve strategic guidelines, financial policy directives, Group policy and methodologies for the measurement of all risk types. To ensure optimal risk management while devoting increasing attention to the needs of business, Risk Management s structured around a Strategic Risk Management & Control department - which centralises Group-wide governance, control, management and overall risk reporting by defining methodologies, strategies, guidelines, general policy and that relating to interdivisional risk, in order to ensure a uniform and consistent approach to Group-wide topics – plus three structures known as Divisional Risk Offices (DROs), which are responsible for controlling, managing and reporting risk at the Business Division level (i.e., Corporate / Private Banking, Retail and Market & Investment Banking (MIB)) by drawing up divisional guidelines, specific policies and coordinating, supporting and interfacing with the subsidiaries in its competence area. Responsibility for the organisational processes for the management of credit and market risk is vested in departments belonging to Organisation. Management of the Basel 2 project is vested with a dedicated project team, which reports directly to the Deputy CEO in charge of organisational and service functions, in co-leadership with the Strategic Risk Management & Control department. Credit risk concentration limits in respect of supervisory capital are subject to the Parent’s opinion on ‘large exposures’. Relations between the Parent and Group entities carrying on credit business are governed by specific governance documents which attribute the same role of governance, support and control to the Parent, in the following areas: credit policies, by ensuring that credit principles are adopted and followed, as well as the common rules and for credit approvals, monitoring / management and recovery, within the local characteristics of each country of operation credit strategies, by ensuring that the Group’s credit portfolio is appropriately structured to optimise value creation models ensuring that Group credit risk assessment and measurement systems are consistent and uniform, in respect of each borrower and each portfolio 9 credit concentration risk, by realising centralisation within the Parent of credit risk approvals vis-à-vis banks and sovereign states, and the similar process whereby large exposures are assessed, measured and controlled for the Group credit products, by providing guidelines for issuance and monitoring, and monitoring portfolio credit risk, by enabling the relevant governing bodies to be regularly and promptly informed of this total for every Group entity. In line with the role given to the Parent, specifically to the CRO’s department, under Group governance, General Group Credit Policies – instructions for the performance of credit business Group-wide – have been issued to lay down the rules and principles that should guide, govern and make uniform the assessment and management of credit risk, in line with Group principles and best practice. The general rules are supplemented by specific rules governing credit business with certain counterparties (e.g., banks and sovereign states), process stages (e.g. classifying and managing risky positions or the recovery process and management of general provisions using the IBNR method) or industrial sectors (including the commercial real estate financing policy, which gives common standards and methods as well as specific parameters for business in the various regions in which the Group operates, and the bridge equity policy, which gives guidelines for equity finance and capital investment). The CRO’s department within the Parent is also responsible for realising and utilising specific methodologies for the management and measurement of credit risk and, in cooperation with the Organisation department, which is responsible for the pertinent processes, their implementation in compliance with Basel 2 standards and Banca d’Italia requirements. As noted above, credit risk is measured for individual counterparties and portfolios. For individual borrower risk the logic and tools supporting credit business are differentiated according to the type of customer. The assessment of a counterparty’s creditworthiness, on examination of a loan application, begins with an analysis of the client’s financials and the quality of its business (competitive positioning, corporate and organisational structure, etc., where the borrower is a corporate), regional and sectoral factors (corporate borrowers) and account conduct within the bank and the banking system (e.g., central risk bureau), in order to reach a rating, i.e., its PD out to a oneyear time horizon. Borrower creditworthiness is reviewed annually on the basis of new information acquired during the year. The borrower is assessed within its industrial group or conglomerate, where relevant, thus considering the maximum exposure of the UniCredit Group towards the client’s group. Monitoring is in two stages, which use different tools and information sources: daily checks for anomalies are based on information arising from the ongoing client relationship; systematic oversight uses automated systems to promptly identify positions with symptoms of deterioration in risk terms and manage the account accordingly. Systematic oversight, which is monthly, centres on account conduct management, which uses all internal and external information to produce a credit score; this indicates the riskiness of each monitored borrower and is obtained using a statistical function which filters all the available information through a set of variables which have been shown to be significant as indicators of a future default, twelve months in advance. The tools and the processes used for loan approval and monitoring, without prejudice to the general principles mentioned below, are adapted according to the customer segment to ensure maximum effectiveness. This set of data produces an internal rating, which takes into account both quantitative and qualitative information as well as the account conduct information seen in the scoring described above. The internal rating, i.e., the borrower’s risk level, is used to calculate the lending authority required to approve loans to the borrower. The discretion of credit officers and committees becomes progressively smaller, the higher the borrower risk, when required to approve a facility of a certain amount. BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 10 The organisational model includes a rating desk and a Rating Committee for larger exposures, which is independent of the approval function, and responsible for the management of any changes to the automatic rating produced by the model using overrides. Several entities have initiated projects aiming to bring their credit processes into line with the above Group best practice. Group entities are required to seek the Group CRO’s department’s opinion before granting or reviewing lines of credit to individual borrowers or groups, whenever they exceed certain amounts, which have been appropriately modulated on the basis of objective parameters. The Group CRO’s department monitors the credit risk portfolio systematically and produces both regular and one-off reports covering the Group, with the aim of analysing the main components of credit risk and monitoring changes over time, in order to detect signs of deterioration in a timely manner and undertake suitable corrective action. The performance of the credit portfolio is analysed with reference to its main drivers – such as growth and risk indicators customer segments, industrial sectors and the performance of credits in default and the relevant coverage. Group-wide monitoring and reporting of the portfolio is achieved in close cooperation with DROs who report on and monitor their respective divisional credit risk. Advanced credit risk management of the whole portfolio is part of the Group’s credit strategy formation process. There are three objectives when credit strategy is formulated: to define the optimal make-up of credit portfolios in accordance with the sustainable value creation objective, starting from an agreed risk appetite in line with the Group’s capital allocation and value creation criteria and framework to provide support to the responsible functions and Divisions in the Parent and Group entities when the latter take measures to optimise the portfolio make-up through strategic plans and business initiatives to provide a set of guidelines and support when drawing up business and credit budgets, in line with the Group’s strategic vision. Credit strategies are implemented by using all available credit risk measures especially the credit VaR model, which enables correct and prudent management of portfolio risk, using advanced methodologies and tools. As part of credit strategy these applications are subjected to vulnerability analysis and used to support Capital Adequacy, through credit risk stress testing. Portfolio risk management pays special attention to credit concentration in light of its importance within total assets. This risk, according to the Basel 2 definition, consists of exposure to any counterparty or industrial group with the potential to generate losses of such magnitude as to prejudice the Group’s ability to carry on its normal business. In order to identify, manage, measure and monitor concentration risk, the Parent’s function sets credit limits using various operating procedures to cover two different types of concentration risk: large exposure to a single counterparty or group of industrially related entities (bulk risk), or sectoral exposure. Please see Table 8 Credit Risk Mitigation Techniques – Qualitative Information for coverage and risk mitigation policy. 11 Management, measurement and control One of the credit risk management responsibilities of Group HQ's CRO area is to manage and measure credit risks through the design and use of appropriate methods. This task also involves updating previously developed methods in order to ensure, in cooperation with Global Banking Services (which is responsible for organizational processes), that these policies are implemented in accordance with Basel II standards and the requirements of Banca d'Italia. Credit risk is measured at individual borrower level and for the whole portfolio. The approach and tools used for lending to individual borrowers during both the approval and monitoring phases include a credit rating process with high added value, which is differentiated by customer category. During the credit application review process, a customer’s creditworthiness is assessed on the basis of an analysis of the following: operating, financial and cash flow data; qualitative information regarding the company’s competitive position, its corporate and organizational structure, etc. (only for business customers in the Corporate area); geographical and sector characteristics (only for business customers in the Corporate area); performance data at bank and industry levels (e.g., the Central Risk Bureau); and necessary to assign a rating, meaning the borrower’s PD (probability of default) over a time horizon of one year. Each borrower’s credit rating is reviewed annually on the basis of new information received during the year. Each borrower is also assessed in the context of any business group with which it is affiliated by taking into account the theoretical maximum risk for the entire Group. Monitoring is carried out using automated systems designed to enable rapid identification and appropriate management of positions showing signs of a deteriorating risk profile, on the basis of models originally created for the Group’s Italian entities. Regular monthly monitoring focuses on borrower performance management. This uses all available internal and external information to arrive at a score that represents a short assessment of the risk associated with each borrower monitored. This score is obtained using a statistical function that summarizes available information using a set of proven significant variables that are predictors of an event of default 12 months in advance. Subject to the more general principles given below, the tools and processes used for loan approval and monitoring incorporate appropriate adaptations to address the unique characteristics of different customer segments in order to ensure the highest degree of effectiveness. All information is statistically summarized in an internal rating that takes quantitative and qualitative elements into account, as well as information on the borrower's conduct of the account, if available, which is taken from the loan management scoring procedures described above. The internal rating, or risk level assigned to the customer, forms a part of the lending decision calculation. In other words, at a constant credit amount the lending powers granted to the appropriate bodies are gradually reduced in proportion to a heightened borrower-related risk level. The organizational model in use calls for a rating desk, which is separate from loan approval functions. This unit is charged with managing any adjustments made to the automated opinion provided by the model using an override process. Several Group entities have launched projects to standardize lending processes on the basis of the Group’s best practice as described above. Other entities are required to ask Group HQ CRO area for its special opinion before providing or reviewing credit facilities for individual customers or business groups if these lines exceed preset limits adjusted according to objective parameters. BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 12 UniCredit has been authorised by Banca d’Italia to use advanced methods to determine regulatory capital for credit risk under Basel 2. In the first stage these methodologies have been adopted by the Parent, certain Italian subsidiaries, HypoVereinsbank (HVB AG) and Bank Austria (BA AG). The remaining Group entities will apply them under a plan of gradual extension notified to Banca d’Italia. These ratings are used to calculate the regulatory requirement under Pillar I, but they are principally a fundamental component of decision-making and governance. The main areas where internal rating systems are used are the following: Credit Process, as follows: - Loan approvals and renewals. The assignment of an internal rating is a key factor in credit assessment of counterparty and transaction and the preliminary stage of approval or renewal of a line of credit. The rating is assigned before the credit decision is taken and included in the approval process as an integral part of the assessment, and commented on in the credit proposal. The rating is therefore indispensable, together with the amount of the line, in the selection of the appropriate position or committee for the credit decision. - Monitoring. Credit monitoring aims to identify and promptly react to early symptoms of deterioration in the borrower’s credit quality and thus to be able to act before any default occurs, i.e., when there it is still possible to recover the loan. Monitoring focuses primarily on the use of the facility and outcomes concerning the exposure, up to complete closure of the borrowing relationship, where necessary. This not only impacts positively on EAD, it also makes it possible to optimise the conditions for a later recovery, in so far as additional collateral or guarantees are obtained from the borrower, causing a reduction of LGD. - Workout. The process of deciding the strategy to be followed for defaulting loans in respect of the borrower and the transaction, aiming to calculate the Net Present Value of net amounts recovered and the LGD, is based on the LGD definition. If there are alternative strategies, the choice falls on the one with the lowest forecast LGD. LGD is also the basis for the pricing of nonperforming loans transferred to Aspra Finance. Provisioning Policy. Performing loans attract generic provisions on an IBNR basis (“Incurred but not reported losses”,), which gives expected loss values using the LCP (Loss Confirmation Period) to calculate provisions. Defaulting loans’ expected losses are based on a risk assessment and the LGD. Capital Management and Allocation. Ratings are an essential element for the quantification, management and allocation of capital. The rating systems’ outputs are assembled by the Parent to arrive at a rating for the whole Group, when measuring capital (both regulatory and economic) and managing capital, on the one hand; and in determining “risk-adjusted performance” and the adjusted income statement for strategic planning purposes, on the other. Strategic Planning. Borrower risk is an important driver for strategic planning, budgeting and forecasting, for the quantification of RWA, net adjustments to the income statement and loans held in the balance sheet. Reporting. Specific reports are produced for senior management on the credit risk portfolio’s performance at consolidated, divisional and regional levels and by individual entity, including average EADs, ELs, PDs and LGDs for each customer segment, in accordance with the internal rating systems in use. Ratings are used in pricing and the targets set for account managers, as well as to identify borrowers producing negative EVA, for whom targeted action is taken. In order to comply with Basel 2, UniCredit Group has carried out specific activities to define and meet all the requirements for the application of CRM (Credit Risk Mitigation) techniques, as follows: 13 Policies were issued to transpose, interpret and internalise CRM within the Group. These documents are in accordance with Banca d'Italia Circular 263 dated 27 December 2006 as amended, EU directives 2006/48/CE and 2006/49/CE and the Basel Committee on Banking Supervision’s "International Convergence on Capital Measurement and Capital Standards: a New Framework" and aimed to encourage optimisation of the management of loan security and to define the rules for accepting, assessing, monitoring and managing personal guarantees and collateral in line with general and specific requirements. New processes were designed to apply these policies in the management of loan security Group-wide. A gap analysis between the ”as-is” and the target model was the basis for new loan security management processes to be implemented in line with Banca d’Italia rules and Group guidelines. In assessing CRM techniques UniCredit Group emphasizes the importance of legal certainty, so this issue was given special attention. IT tools were introduced to automate the loan security management process. UniCredit Group developed a solid and effective system for the application of CRM techniques starting with the assessment and acquisition of loan security and extending through to monitoring and realising security/calling guarantees. This information system enables management, recording and archiving of the data necessary to verify that the guarantee acceptance criteria have been met and calculate the risk indicators. These data are used to determine whether loan security is valid under CRM and appropriate margins as required by Basel 2 (to assess volatility, internally calculated margins are determined based on Value at Risk methodology). Development of advanced rating systems and their introduction into the Group’s processes required, under the new regulatory framework, that rating system validation processes be set up within the Parent and all Group entities using advanced rating, as well as an extension of the tasks to be performed by Internal Audit, now to include auditing the systems. Validation aims to assess whether IRB systems work properly and are able to predict accurately as well as their overall performance and compliance with regulations, as follows: Assessment of the model development process, specifically its underlying logic and the methodological criteria underlying the calculation of risk parameters. Assessment of the accuracy of the estimates of all significant risk components by analysing the performance of the system, the calibration of the parameters and benchmarking. Checking whether the rating systems are actually in use in the various business areas. Analysing operating processes, control systems, documentation and the IT infrastructure used for the rating systems. The results of internal validation, carried out in accordance with the validation standards and using a depth of analysis according to the type, i.e., Group-wide or local, or location, i.e., Italy or outside Italy) of the rating system, are reported in a single framework with the aim of unifying the analysis of the various components of the rating system. The framework in use consists of a schedule showing the minimum quantitative and detailed organisational requirements of Banca d’Italia against specific key principles, regarding various subject areas of analysis of the rating systems, viz. model design, risk components, internal use and reporting, IT and data quality and corporate governance, and serves to assess the detailed position of the rating system as against regulatory requirements. The areas of organisational analysis under the Circular are model design, internal use and reporting, IT and data quality and governance. The aims of internal audits of the internal rating systems include checking the functionality of the entire system of controls over them, specifically by checking: that IRB systems comply with the regulations BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 14 how rating systems are used in the business and the adequacy and completeness of the validation process of rating systems. The Parent’s Internal Audit Department – in order to assist Group entities to ensure the quality of their Internal Control Systems and oversee changes in revision methodologies in line with changes in market scenarios – has coordinated the development of a common methodology for revising rating systems. This methodology was developed in order to assess whether the conclusions of the risk control function were well grounded and whether regulatory requirements were being met, with special reference to the internal validation of internal rating and risk control systems. Market risk Generally speaking banks’ market risks are due to price fluctuations or other market risk factors affecting the value of positions on its own books, both the trading book and the banking book, i.e. those arising from transactions and strategic investment decisions. UniCredit Group’s market risk management includes, therefore, all activities relating to cash and capital structure management, both in the Parent and in the individual Group companies. The Parent monitors risk positions at Group level. The individual Group companies monitor their own risk positions, within the scope of their specific responsibilities, in line with UniCredit Group supervision policies. The results of individual companies’ monitoring activities are, in any event, shared with the Parent company. The individual companies comprising the Group produce detailed reports on business trends and related risks on a daily basis, forwarding market risk documentation to the Parent company. The Parent’s Group Market Risk unit is responsible for aggregating this information and producing information on overall market risks. Organizational Structure The Parent’s Board of Directors lays down strategic guidelines for taking on market risks by calculating, depending on the propensity to risk and objectives of value creation in proportion to risks assumed, capital allocation for the Parent company and its subsidiaries. The Parent’s Risks Committee provides advice and recommendations in respect of decisions taken by the Chief Executive Officer and in drawing up proposals made by the Chief Executive Officer to the Board of Directors with regard to the following: guidance as to the methods to be used to realise models for the measurement and monitoring of Group risks; the Group’s risk policies (identification of risk, analysis of the level of propensity to risk, definition of capital allocation objectives and the limits for each type of risk, assignment of related functional responsibilities to the relevant Departments and Divisions); corrective action aimed at rebalancing the Group’s risk positions. The Risk Committee comprises the following members: the Chief Executive (Chair of the Committee), the Deputy General Managers, the Chief Risk Officer (chairs the Committee in the absence of the Chief Executive) and the Chief Financial Officer. The Head of the Group Internal Audit Department also attends meeting of the Risk Committee, but is not entitled to vote. 15 In April 2008 the Board of Directors approved the reorganization guidelines for the Group Market Risks model, aimed at combining all Market Risk functionalities under a single responsibility and therefore established the new Group Market Risk Department within the MIB Divisional Risk Office and Group Market Risks Dept. In particular this entails: unifying responsibility for Market Risk Management (measurement, evaluation, monitoring and control) under the new “Group Market Risks” department, responsible for trading and banking book risk management at Group level and for ensuring consistency in market risk policies, methodologies and practices across divisions and LEs establishing, within the new Group Market Risk department, two specialized teams for Trading and Treasury Risk Management, including: - introduction of trading risk manager role, responsible for market risk management of its specific business lines Group-wide - introduction of treasury risk manager role, responsible for treasury risk management of its specific banking books Group-wide •Establishing unitary groups for Market Risk architecture and methodologies, including responsibilities concerning Risk Technologies, Risk Methods, Model Testing and Group-wide New Products Process, but excluding Front Office Risk Modelling reallocating responsibilities coherently between Holding and Legal Entities: in particular, Legal Entities/Branches will focus on local New Products Process (“NPP”) implementation, Infrastructure implementation, P&L validation and Desk Control maintaining the CRO’s overall responsibilities on Group Market Risks and on MIB Market/ Credit Risks through guidance and monitoring activities to be performed also within the Risk Committee (competent body to approve/share DROs proposals referred to risk strategies, policies, models, limits and monitoring activities/ initiatives), of which the CRO is a member. As a consequence the Board of Directors approved on Aug 1st the new Market Risk Governance which sets out the framework of the Holding Company Market Risks function in its guiding, supporting and controlling of the correspondent functions in the Legal Entities, in coherence with the role of UniCredit SpA as holding company. In short, the Parent company proposes limits and investment policies for the Group and its entities in harmony with the capital allocation process when the annual budget is drawn up. Group HQ's Asset and Liability Management unit, in coordination with other regional liquidity centers, manages strategic and operational ALM, with the objective of ensuring a balanced asset position and the operating and financial sustainability of the Group’s growth policies on the loans market, optimizing the Group’s exchange rate, interest rate and liquidity risk. BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 16 Operational risk General aspects, management processes and operational risk measurement methodologies Operational Risk definition Operational risk is the risk of loss due to errors, infringements, interruptions, damages caused by internal processes or personnel or systems or caused by external events. This definition includes legal and compliance risks, but excludes strategic and reputational risk. As an example, are classified as operational losses the ones resulting from internal or external fraud, employment practices and workplace safety, clients claims, products distribution, fines and penalties due to regulation breaches, damage to company’s physical assets, business disruption and system failures, process management. Group Operational Risk framework UniCredit Group established the Operational Risk Management framework as a combination of policies and procedures for controlling, measuring and mitigating the Operational Risk of the Group and controlled Legal Entities. The Operational Risk policies, applying to all Group Legal Entities, are common principles defining the roles of the company bodies, the Operational Risk Management function as well as the relationship with other functions involved in Operational Risk monitoring and management. The Parent company coordinates the Group companies according to the internal regulation and the Group operational risk control rulebook. Specific risk committees (risk committee, operational risk committee) are set up to monitor risk exposure, to define risk appetite and mitigating actions, to approve measurement and control methods. The methodology for data classification and completeness, scenario analysis, risk indicators, reporting and capital at risk measurement is set by the Parent company operational risk management function and applies to all Group Legal Entities. A pivot element of the risk control framework is the Operational Risk Management IT application, allowing the collection of the data required for operational risk control and capital measurement. The Operational Risk control methodologies have been extended to the relevant Capitalia Group Legal Entities acquired during 2007 and this entities have been included in the AMA Group roll out plan. UniCredit Group achieved / received in March 2008 the authorization to adopt the AMA model for capital at risk calculation. During the next years this method will be extended to the main Group Legal Entities following the AMA roll out plan. Organizational structure Top management is responsible for the approval of all relevant aspects of the operational risk Group framework, for verifying the measurement and control system adequacy and it is regularly informed regarding the operational risk exposure. The Risk Committee defines the guidelines and management policies of different risk types and particularly has deliberative function on measurement and control methodologies and related manuals. The Operational Risk Committee, headed by the Group Chief Risk Officer, involves the main Legal Entities Operational Risk control functions and others relevant Parent company functions. The committee is updated on the operational risk exposure and actions taken to mitigate those risks. The Operational Risk Management (ORM) unit of the Parent company, in the Strategic Risk Management & Control department – Risk Management division, defines the capital at risk calculation model for the Group and the 17 operational risk control guidelines, supports and controls the Legal Entities Operational Risk functions, verifying that the implementation of the control processes and methodologies is in line with the Group standards.. The Legal Entities Operational Risk Management functions provide specific training on operational risk to the personnel, web-based trainings are also available, and are responsible for the correct implementation of Group framework. A regular update on operational risk regulations and practices is provided to the local operational risk control function by the UniCredit ORM unit. Capital at risk measurement UniCredit developed a proprietary model for measuring the capital at risk. The system for measuring operational risk is based on internal loss data, external loss data (consortium and public data) scenario generated loss data and risk indicators. Capital at risk is calculated per event type class. For each risk class, severity and frequency of loss data are separately estimated to obtain the annual loss distribution through simulation, considering also insurance coverage. The severity distribution is estimated on internal, external and scenario generated data, while the frequency distribution is determined using only the internal data. An adjustment for key operational risk indicators is applied to each risk class. Annual loss distributions of each risk class are aggregated through a copula based method. Capital at risk is calculated at confidence level of 99.9% on the overall loss distribution for regulatory purpose and at confidence level 99.97% for economic capital purpose. By the allocation mechanism, the individual legal entities’ capital requirements are identified, reflecting the Legal Entities’ risk exposure and risk management effectiveness. UniCredit Group received the formal approval by the Regulators to use the Advanced Measurement Approach (AMA) for regulatory capital at risk calculation for operational risk. As of 30 June 2008, the AMA covers 62% of the Group, considering the relevant indicator (i.e. gross margin), and the roll out plan set the time schedule for the extension of the method to all relevant Group legal entities that will be completed by 2012. The subsidiaries that at the moment are not yet AMA compliant apply TSA or BIA method to calculate the regulatory capital requirements. Reporting A reporting system has been developed by the Parent company Operational Risk management to inform senior management and relevant bodies about the Group operational risk exposure and the risk mitigation actions. The parent company ORM function, on quarterly basis provides update on operational losses trend, capital at risk calculation, external event and the main initiatives taken for operational risk mitigation in business divisions. A synthesis of the risk indicators trend is issued monthly. During the Operational Risk Committee are presented the main scenario analysis results at Group level and the related mitigation actions. Operational Risk Management Operational risk management consist of processes’ review to reduce the risk exposure, including the option to outsource certain processes, and insurance policies management, defining proper deductibles and policies’ limits. Regularly tested business continuity plans will also assure operational risk management in case of interruption of main services. BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 18 The Risk Committee (or other bodies in accordance to local regulations) reviews risks tracked by the operational risk functions of the Legal entities, with the support of functions involved in daily operational risk control, and monitors the risk mitigation initiatives. Other Risks The types of risk described above are the main ones. There are others. The Group has identified and re-delineated the risk types and broadened the range, in order to increase the accuracy of risk measurement. At the same time aggregation procedures were developed to enable measurement of overall risk, adding to each type through the determination of internal capital. This work has two aims: the main one is to improve understanding of the value drivers within each business line, so that Risk Management can play an effective role in decision-making. The second objective is to refine the internal control system, in which Risk Management is one of the main players. Redrawing and broadening the identified risk type perimeter to be managed in the Group is accomplished in two stages. The first is the recognition of risk implicit in existing assets and liabilities and the business carried on. The second is definition of measurement methods. Under the first stage the Group has identified the following risk types: business risk; real estate risk; equity investment risk; strategic risk and; reputational risk. Defined as follows. Business Risk A contraction of margins not due to market, credit or operational risk, but changes in the competitive environment or customer behaviour. Business risk guidelines give a standard method of calculating the risk arising from income fluctuations. Only midsize and large subsidiaries are required to fully implement the model; small subsidiaries are exempted from this since this risk will be calculated using a simplified procedure. Data are collected quarterly according to a set format provided by the Parent and updated by each Group entity for accounts items that determine income and expense to be input to the model. These items are chosen in such a way as to avoid overlapping with other risk types. Historical series to be used to calibrate volatility and correlations are constructed starting with the monthly accounts and grouped in divisional clusters, while the annual market values by which they are multiplied are extracted from quarterly accounts. The calculation uses normal distribution, on the basis of which an EaR is calculated with a 99.97% confidence interval and a one-year time horizon (variance-covariance method). VaR is then calculated by multiplying the EaR by a factor, which is a function of the three-year time horizon and the interest rate. This is measured for the Group, each 19 Division, each Sub-group and each entity, both in terms of stand-alone risk capital, and diversified; in the case of the latter, the benefit of intra-risk diversification is subsequently reallocated to individual entities in proportion to the ratio of Group VaR to the sum of the stand-alone VaRs of all entities. Each entity’s marginal diversified capital exists only as part of the Group’s, and is one of the preliminary elements for the calculation of aggregated economic capital. For monitoring purposes business risk is calculated for the Group, the Parent and the Divisions quarterly or whenever thought necessary due to changes in the relevant market. For budgeting purposes it is calculated prospectively to assist the capital allocation process since it is one of the risk measures to be aggregated. Real Estate Risk This consists of the potential losses arising from adverse fluctuations in the value of the Group’s property portfolio held by subsidiaries, property trusts and special-purpose vehicles (but not customers’ property bearing a charge or mortgage). Only mid-size and large subsidiaries are required to fully implement the model; small subsidiaries are exempted from this since this risk will be calculated using a simplified procedure. The calculation of real estate risk excludes property pledged as collateral but includes ancillary companies’ and subsidiaries’ property. Data are collected quarterly, according to a set format provided by the Parent and used by each Group entity to provide general information on property held, its market value and carrying amount. For the purposes of real estate risk calculation, if market value cannot be supplied, it is temporarily replaced by carrying amount. Each entity is also required to provide sector indexes for each property according to region or city, which are necessary for the calculation of volatility and correlations in the model. The calculation uses normal distribution, on the basis of which an EaR is calculated with a 99.97% confidence interval and a one-year time horizon (variance-covariance method). The resulting VaR is measured for the Group, each Division, each Sub-group and each entity both in terms of stand-alone risk capital, and diversified; in the case of the latter, the benefit of intra-risk diversification is subsequently reallocated to individual entities on the basis of the entity’s marginal contribution to the Group’s intra-diversified VaR. Each entity’s marginal diversified capital exists only as part of the Group’s, and is one of the preliminary elements for the calculation of aggregated economic capital. For monitoring purposes real estate risk is calculated for the Group, the Parent and the Divisions quarterly or whenever thought necessary due to changes in the relevant market. For budgeting purposes it is calculated prospectively to assist the capital allocation process since it is one of the risk measures to be aggregated. Equity Investment Risk This consists of the potential losses arising from non-speculative financial investments in companies outside the Group, i.e., outside the scope of consolidation for accounting purposes. Trading book assets are therefore not considered under this heading. Only mid-size and large subsidiaries are required to fully implement the model; small subsidiaries are exempted from this since this risk will be calculated using a simplified procedure. The calculation of equity investment risk excludes equity investments in companies not belonging to the Group or the trading book, but may include: listed or unlisted shares, equity derivatives, private equity and shares in mutual, hedge and private equity funds. Risk assessment is carried out using two distinct methodologies: one is market-based in approach, i.e., based on market prices, for listed investments. The other is an IRB PD/LGD approach taking the carrying amount as its basis, BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 20 for unlisted investments including those in private equity. Where there is no PD, even one of local origin, mapping using market indexes or standard weights are used. Data are collected quarterly, according to a set format provided by the Parent and updated by each Group entity. To calculate volatility and the correlations needed for the model, specific price indexes are used for listed shares and regional or sectoral indexes for unlisted shares, until an internal rating model is developed for them. Once the database is defined, the calculation uses log-normal distribution, starting from which a VaR calculated with a 99.97% confidence interval and a one-year time horizon (variance-covariance method). The resulting VaR is measured for the Group, each Division, each Sub-group and each entity both in terms of stand-alone risk capital, and diversified; in the case of the latter, the benefit of intra-risk diversification is subsequently reallocated to individual entities on the basis of the entity’s marginal contribution to the Group’s intra-diversified VaR with a 99.97% confidence interval and a one-year time horizon (variance-covariance method). For monitoring purposes equity investment risk is calculated for the Group, the Parent and the Divisions quarterly or whenever thought necessary due to changes in the relevant market. For budgeting purposes it is calculated prospectively to assist the capital allocation process since it is one of the risk measures to be aggregated. Strategic Risk This arises from unexpected changes in market conditions, failure to recognise trends in the banking sector, or inappropriate assessments of these trends. The risk is that divergent decisions as to how to achieve long-term objectives may be made and be reversible only with difficulty. Reputational Risk The risk that profit or capital may be reduced due to a negative perception of the bank’s image by customers, market players, shareholders, investors or the regulator. In the second stage of redefining and broadening the scope of the risk types to be managed by the Group, the best analytical method was identified: some risk types can be analysed quantitatively using statistical methods, while others require a qualitative approach, for example scenario analysis. Risk Measurement Methods Credit, market, operational, business, real estate and equity investment risk can be measured quantitatively, using: estimated economic capital and stress tests. The Group measures business, real estate and equity investment risk using a quantitative model, since the capital amount determined in this way is used to meet potential losses. By contrast, strategic risk is analysed using scenario analysis, which makes it possible to estimate potential losses in certain situations but this risk is not included in the estimate of aggregate risk, because in this situation capital would not be effective to cope with strategic errors. The multi-dimensional nature of risk makes it necessary to accompany the measurement of economic capital with stress testing, not only in order to estimate losses in certain scenarios, but also to obtain the impact of their determinants. Stress testing is carried out on both individual risk types and aggregated risk by simulating changes together with risk factors to provide consistent support for the calculation of aggregate economic capital. 21 Economic Capital and Internal Capital Aggregate Economic Capital is the maximum potential loss due to the joint effect of the various risk types in a oneyear time horizon and a confidence level consistent with the Group’s risk appetite. The risks considered are credit, market, operational, business, real estate and equity investment risk and their interdependence, both in terms of diversification within each risk type and between risks. As prescribed by the Basel 2 Project Rulebook, the Parent is responsible for developing methodology for measurement at Group and Division level, and for designing and implementing measurement processes for the Group’s Economic Capital and Internal Capital. Each entity is responsible for developing the processes needed to measure risk in line with the Parent’s instructions. Internal Capital, in line with the Group’s risk appetite, is calculated by adding a buffer to Aggregate Economic Capital to take account of stress test results and other non-quantifiable risks considered significant for the Group. Economic Capital is a fundamental element when assessing the adequacy of the Group’s capital. For monitoring purposes, the Group’s, the Parent’s and the Divisions’ Economic Capital is calculated quarterly or whenever thought necessary due to significant changes in the relevant market. For budgeting purposes it is calculated prospectively to assist the capital allocation process. Aggregate Economic Capital and resulting Internal Capital form a significant part of the information on the bank’s risk profile, and should be submitted to the entity’s governing or decision-making bodies (e.g., the Risk Committee or the Board of Directors). In addition to the foregoing, Group intends to consider the effects of a disaster scenario, i.e., losses arising from extreme situations impacting all risk variables, such as pandemics. Refinement of the risk profile is fully in keeping with Pillar 2 in the new supervisory regulations. The Group’s approach to capital adequacy is in five stages: risk identification risk measurement capital planning and allocation monitoring and risk governance. The activities described above cover the first two stages in particular, i.e., risk identification and risk measurement both at individual level, and aggregated. BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 22 Reporting The Group CRO’s department’s Reporting and Monitoring provides reports and manages credit risk portfolio oversight using various regular and specific monthly and quarterly reports. Its principal purpose is to analyse the main drivers and parameters of credit risk (exposure at default (EAD), expected loss (EL), migration, cost of risk, etc.) in order to take timely countermeasures for portfolios subject to this risk. In addition, within each Division (Retail, Corporate, Private Banking and Market & Investment Banking) there are reporting units charged with monitoring credit risk positions within the Division. In H1 2008 Reporting and Monitoring activities changed markedly due to the steady improvement of data quality and the production processes for the various reports (CRO Flash Report, Quarterly Risk Report, and Risk Summary etc.). To assist production of these reports, the divisional reporting units use a Credit Tableau de Bord, a quarterly tool containing specific divisional information. In H1 2008, the Group CRO’s department continued its intense involvement in the process of integrating the Capitalia Group by analysing risk management processes and methodologies. 23 Table 2 – Scope of application Qualitative disclosure In this section of the pillar 3 is disclosed the prudential scope of consolidation do the UniCredit group, in this scope, defined “Banking Group” have to be enclosed the subsidiaries with the following characteristics: Banks, financial companies and ancillary banking services companies directly or indirectly controlled to which the line-by-line consolidation method is applied; Banks, financial companies and ancillary banking services companies directly or indirectly participated for a share equal or more than the 20% when they are jointly controlled with other entities, to these subsidiaries has to be applied the proportional consolidation method Further prudential treatments provided by the regulation are: the deduction of the value of the subsidiary from the capital and the sum of the subsidiary value to the Risk Weighted Assets. It has to be underlined that the prudential scope of consolidation is set in order to comply with the solvency regulation, different from the IAS/IFRS rules applied to the scope of the Financial Statement, this situation could cause mismatches among similar set of information disclosed in this document and in the F/S BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 24 CONSOLIDATED SUBSIDIARIES Banks UNICREDIT SPA ROME ITALY X X AS UNICREDIT BANK RIGA LATVIA X X ASSET MANAGEMENT GMBH VIENNA AUSTRIA X X ATF BANK KYRGYZSTAN OJSC BISHKEK KIRGHIZISTAN X X X BANCO DI SICILIA S.P.A. PALERMO ITALY X BANK AUSTRIA CREDITANSTALT AG VIENNA AUSTRIA X X BANK AUSTRIA CREDITANSTALT WOHNBAUBANK AG VIENNA AUSTRIA X X BANK AUSTRIA REAL INVEST GMBH VIENNA AUSTRIA X X BANK BPH SA CRACOW POLAND X X BANK PEKAO SA VARSAW POLAND X X BANKHAUS NEELMEYER AG BREMEN GERMANY X X BANKPRIVAT AG VIENNA AUSTRIA X X BAYERISCHE HYPO- UND VEREINSBANK AG MUNICH GERMANY X X BIPOP CARIRE S.P.A. BRESCIA ITALY X X BPH BANK HIPOTECZNY S.A. VARSAW POLAND X X CAPITALIA LUXEMBOURG S.A. LUXEMBURG LUXEMBOURG X X CARD COMPLETE SERVICE BANK AG VIENNA AUSTRIA X X CJSC BANK SIBIR OMSK CITY RUSSIA X X DAB BANK AG MUNICH GERMANY X X DIREKTANLAGE.AT AG SALZBURG AUSTRIA X X FACTORBANK AKTIENGESELLSCHAFT VIENNA AUSTRIA X X FINECOBANK SPA MILAN ITALY X X FONDO SIGMA ROME ITALY X X HVB BANQUE LUXEMBOURG SOCIETE ANONYME LUXEMBURG LUXEMBOURG X X HVB INVESTITIONSBANK GMBH HAMBURG GERMANY X X IRFIS - MEDIOCREDITO DELLA SICILIA S.P.A. JOINT STOCK COMMERCIAL BANK FOR SOCIAL DEVELOPMENT UKRSOTSBANK PALERMO ITALY X X KIEV UKRAINE X X JSC ATF BANK ALMATY CITY KAZAKHSTAN X X LEASFINANZ BANK GMBH VIENNA AUSTRIA X X MCC - MEDIOCREDITO CENTRALE S.P.A. ROME ITALY X X PIONEER INVESTMENTS AUSTRIA GMBH VIENNA AUSTRIA X X PRVA STAMBENA STEDIONICA DD ZAGREB ZAGREB CROATIA X X SCHOELLERBANK AKTIENGESELLSCHAFT VIENNA AUSTRIA X X SOHIBKORBANK OJSC KHUJAND CITY TADZHIKISTAN X X UNICREDIT (SUISSE) BANK SA LUGANO SWITZERLAND X X UNICREDIT BANCA DI ROMA S.P.A. ROME ITALY X X UNICREDIT BANCA PER LA CASA SPA MILAN ITALY X X UNICREDIT BANCA SPA BOLOGNA X X UNICREDIT BANK AD BANJA LUKA BANJA LUKA ITALY BOSNIA AND HERCEGOVINA X X UNICREDIT BANK CAYMAN ISLANDS LTD. GEORGE TOWN CAYMAN ISLANDS X X UNICREDIT BANK CZECH REPUBLIC A.S. PRAGUE CZECH REPUBLIC X X 25 proportional consolidatio fully consolidated RWA Deduction from capital Country proportional consolidated Company name Town consolidation in F/S treatment in prudential report full consolidated Headquarter proportional consolidatio fully consolidated RWA Deduction from capital Country proportional consolidated Company name Town consolidation in F/S treatment in prudential report full consolidated Headquarter Banks BOSNIA AND HERCEGOVINA UNICREDIT BANK DD MOSTAR X X UNICREDIT BANK HUNGARY ZRT. BUDAPEST HUNGARY X X UNICREDIT BANK IRELAND PLC DUBLIN IRELAND X X UNICREDIT BANK LTD LUCK UKRAINE X X UNICREDIT BANK SLOVAKIA AS BRATISLAVA SLOVAKIA X X UNICREDIT BANK SRBIJA JSC BELGRADE SERBIA X X UNICREDIT BANKA SLOVENIJA D.D. LJUBLJANA SLOVENIA X X UNICREDIT BULBANK AD SOFIA BULGARIA X X UNICREDIT CAIB AG VIENNA AUSTRIA X X UNICREDIT CONSUMER FINANCING BANK SPA MILAN ITALY X X UNICREDIT CORPORATE BANKING SPA VERONA ITALY X X UNICREDIT CREDIT MANAGEMENT BANK SPA VERONA ITALY X X UNICREDIT INTERNATIONAL BANK (LUXEMBOURG) SA LUXEMBURG LUXEMBOURG X X UNICREDIT JELZALOGBANK ZRT. BUDAPEST HUNGARY X X UNICREDIT PRIVATE BANKING SPA TURIN ITALY X X UNICREDIT TIRIAC BANK S.A. BUCAREST ROMANIA X X UNICREDIT XELION BANCA SPA MILAN ITALY X X VEREINSBANK VICTORIA BAUSPAR AKTIENGESELLSCHAFT MUNICH GERMANY X YAPI KREDI AZERBAIJAN BAKU AZERBAIJAN X X YAPI KREDI BANK NEDERLAND NV AMSTERDAM NETHERLANDS X X YAPI KREDI MOSCOW MOSCOW RUSSIA X X YAPI VE KREDI BANKASI AS ISTANBUL TURKEY X ZAGREBACKA BANKA DD ZAGREB CROATIA X X ZAO UNICREDIT BANK MOSCOW RUSSIA X X X X Financial entities AI BETEILIGUNG GMBH VIENNA AUSTRIA X X ALINT 458 GRUNDSTUCKVERWALTUNG GESELLSCHAFT M.B.H. BAD HOMBURG GERMANY X X ALLEGRO LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X ALLIB LEASING S.R.O. PRAGUE CZECH REPUBLIC X X ALLIB NEKRETNINE D.O.O. ZA POSLOVANJE NEKRETNINAMA ZAGREB CROATIA X X ALLIB ROM S.R.L. BUCAREST ROMANIA X X ALMS LEASING GMBH. SALZBURG AUSTRIA X X ALV IMMOBILIEN LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X ANI LEASING IFN S.A. BUCAREST ROMANIA X X ANTARES IMMOBILIEN LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X ARNO GRUNDSTUCKSVERWALTUNGS GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X ARTEMUS MACRO FUND SPC LIMITED GEORGE TOWN CAYMAN ISLANDS X X ARUNA IMMOBILIENVERMIETUNG GMBH VIENNA AUSTRIA X X ASPRA FINANCE SPA MILAN ITALY X X ATF CAPITAL B.V. ROTTERDAM NETHERLANDS X X AUSTRIA LEASING GMBH AUTOGYOR INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG VIENNA AUSTRIA X X BUDAPEST HUNGARY X X BA- ALPINE HOLDINGS, INC. WILMINGTON U.S.A. X X BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 26 Financial entities BA CA LEASING (DEUTSCHLAND) GMBH BAD HOMBURG GERMANY X BA CA SECUND LEASING GMBH VIENNA AUSTRIA X X X BA CREDITANSTALT BULUS EOOD SOFIA BULGARIA X X BA EUROLEASE BETEILIGUNGSGESELLSCHAFT M.B.H. VIENNA AUSTRIA X X BA/CA-LEASING BETEILIGUNGEN GMBH VIENNA AUSTRIA X X BA/CA-LEASING FINANZIERUNG GMBH VIENNA AUSTRIA X X BAC FIDUCIARIA SPA DOGANA SAN MARINO X X BA-CA ADAGIO LEASING GMBH VIENNA AUSTRIA X X BA-CA ANDANTE LEASING GMBH VIENNA AUSTRIA X X BACA BARBUS LEASING DOO LJUBLJANA SLOVENIA X X BACA BAUCIS LEASING GMBH VIENNA AUSTRIA X X BACA CENA IMMOBILIEN LEASING GMBH VIENNA AUSTRIA X X BACA CHEOPS LEASING GMBH VIENNA AUSTRIA X X BA-CA CONSTRUCTION LEASING OOO SAINT PETERSBURG RUSSIA X X BA-CA FINANCE (CAYMAN) II LIMITED GEORGE TOWN CAYMAN ISLANDS X X BA-CA FINANCE (CAYMAN) LIMITED GEORGE TOWN X SARAJEVO CAYMAN ISLANDS OSNIA AND HERCEGOVINA X BACA GIOCONDO NEKRETNINE D.O.O., SARAJEVO X X BACA HYDRA LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X BACA KOMMUNALLEASING GMBH VIENNA AUSTRIA X X BACA LEASING ALFA S.R.O. PRAGUE CZECH REPUBLIC X X BACA LEASING CARMEN GMBH VIENNA AUSTRIA X X BA-CA LEASING DREI GARAGEN GMBH VIENNA AUSTRIA X X BACA LEASING GAMA S.R.O. PRAGUE CZECH REPUBLIC X X BA-CA LEASING MAR IMMOBILIEN LEASING GMBH VIENNA AUSTRIA X X BA-CA LEASING MODERATO D.O.O. LJUBLJANA X X X X X X BACA LEASING NEKRETNINE DRUSTVO SA OGRANICENOM BANJA LUKA SLOVENIA OSNIA AND HERCEGOVINA BA-CA LEASING POLO, LEASING D.O.O. LJUBLJANA SLOVENIA BACA LEASING UND BETEILGUNGSMANAGEMENT GMBH (EX CALG 434 GRUNDSTUCKVER VIENNA AUSTRIA X X BA-CA MARKETS & INVESTMENT BETEILIGUNG GMBH VIENNA AUSTRIA X X BACA MINERVA LEASING GMBH VIENNA AUSTRIA X X BACA MINOS LEASING GMBH VIENNA AUSTRIA X X BACA MOBILIEN UND LKW LEASING GMBH VIENNA AUSTRIA X X BA-CA PRESTO LEASING GMBH VIENNA AUSTRIA X X BACA ROMUS IFN S.A. BUCAREST ROMANIA X X BACAL ALPHA DOO ZA POSLOVANJE NEKRETNINAMA BACAL BETA NEKRETNINE D.O.O. ZA POSLOVANJE NEKRETNINAMA BACA-LEASING AQUILA INGATLANHASNOSITO KORLATOLT FELELOSSEGU TARSASAG ZAGREB CROATIA X X ZAGREB CROATIA X X BUDAPEST HUNGARY X X BUDAPEST HUNGARY X X BUDAPEST HUNGARY X X BUDAPEST HUNGARY X X BUDAPEST HUNGARY X X BUDAPEST HUNGARY X X BACA-LEASING GEMINI INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG BACA-LEASING HERKULES INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASA BACA-LEASING MIDAS INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG BACA-LEASING NERO INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG BACA-LEASING OMIKRON INGATLANHASZNOSTO KORLATOLT FELELOSSEGU TARSASAG 27 proportional consolidatio fully consolidated RWA Deduction from capital Country proportional consolidated Company name Town consolidation in F/S treatment in prudential report full consolidated Headquarter Financial entities BACA-LEASING URSUS INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG BUDAPEST HUNGARY X X BA-CREDITANSTALT LEASING ANGLA SP. Z O.O. VARSAW POLAND X X BA-CREDITANSTALT LEASING DELTA SP. Z O.O. VARSAW POLAND X X BA-CREDITANSTALT LEASING ECOS SP. Z O.O. VARSAW POLAND X X BA-CREDITANSTALT LEASING POLUS SP. Z O.O. VARSAW POLAND X X BAL CARINA IMMOBILIEN LEASING GMBH VIENNA AUSTRIA X X BAL DEMETER IMMOBILIEN LEASING GMBH VIENNA AUSTRIA X X BAL HESTIA IMMOBILIEN LEASING GMBH VIENNA AUSTRIA X X BAL HORUS IMMOBILIEN LEASING GMBH VIENNA AUSTRIA X X BAL HYPNOS IMMOBILIEN LEASING GMBH VIENNA AUSTRIA X X BAL LETO IMMOBILIEN LEASING GMBH VIENNA AUSTRIA X X BAL OSIRIS IMMOBILIEN LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X BAL PAN IMMOBILIEN LEASING GMBH VIENNA AUSTRIA X X BAL SOBEK IMMOBILIEN LEASING GMBH VIENNA AUSTRIA X X BANCA AGRICOLA COMMERCIALE DELLA R.S.M. S.P.A. BORGO MAGGIORE SAN MARINO X X BANK AUSTRIA CREDITANSTALT LEASING BAUTRAGER GMBH BANK AUSTRIA CREDITANSTALT LEASING IMMOBILIENANLAGEN GMBH BANK AUSTRIA HUNGARIA BETA LEASING KORLATOLT FELELOSSEGU TSRSASAG VIENNA AUSTRIA X X VIENNA AUSTRIA X X BUDAPEST HUNGARY X X BANK AUSTRIA LEASING ARGO IMMOBILIEN LEASING GMBH VIENNA AUSTRIA X X BANK AUSTRIA LEASING HERA IMMOBILIEN LEASING GMBH BANK AUSTRIA LEASING IKARUS IMMOBILIEN LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X VIENNA AUSTRIA X X BANK AUSTRIA LEASING MEDEA IMMOBILIEN LEASING GMBH VIENNA AUSTRIA X X BAULANDENTWICKLUNG GDST 1682/8 GMBH & CO OEG VIENNA AUSTRIA X X BDR ROMA PRIMA IRELAND LTD DUBLIN IRELAND X X BETEILIGUNGS-UND HANDELSGESELLSCHAFT IN HAMBURG MIT BESCHRANKTER HAFTUNG HAMBURG GERMANY X X BETEILIGUNGSVERWALTUNGSGESELLSCHAFT DER BANK AUSTRIA CREDITANSTALT LEASING GMBH VIENNA AUSTRIA X X BLUE CAPITAL EQUITY GMBH HAMBURG GERMANY X X BLUE CAPITAL FONDS GMBH HAMBURG GERMANY X X BLUE CAPITAL GMBH HAMBURG GERMANY X X BLUE CAPITAL TREUHAND GMBH BORDER LEASING GRUNDSTUCKSVERWALTUNGSGESELLSCHAFTM.B.H. HAMBURG GERMANY X X VIENNA AUSTRIA X X BREAKEVEN SRL VERONA ITALY X X BREWO GRUNDSTUCKSVERWALTUNGS-GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X BULBANK LEASING EAD SOFIA BULGARIA X X CA IB CORPORATE FINANCE D.D. LJUBLJANA SLOVENIA X X CA IB INVEST D.O.O ZAGREB CROATIA X X CABET-HOLDING-AKTIENGESELLSCHAFT VIENNA AUSTRIA X X CABO BETEILIGUNGSGESELLSCHAFT M.B.H. VIENNA AUSTRIA X X CAC REAL ESTATE, S.R.O. PRAGUE CZECH REPUBLIC X X CAC-IMMO SRO CA-LEASING ALPHA INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG CESKE BUDEJOVICE CZECH REPUBLIC X X BUDAPEST HUNGARY X X BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 28 proportional consolidatio fully consolidated RWA Deduction from capital Country proportional consolidated Company name Town consolidation in F/S treatment in prudential report full consolidated Headquarter Financial entities CA-LEASING BETA 2 INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG CA-LEASING DELTA INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG CA-LEASING EPSILON INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG BUDAPEST HUNGARY X X BUDAPEST HUNGARY X X BUDAPEST HUNGARY X X CA-LEASING EURO, S.R.O. CA-LEASING KAPPA INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG CA-LEASING LAMBDA INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG CA-LEASING OMEGA INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG PRAGUE CZECH REPUBLIC X X BUDAPEST HUNGARY X X BUDAPEST HUNGARY X X BUDAPEST HUNGARY X X CA-LEASING OVUS S.R.O. PRAGUE CZECH REPUBLIC X X CA-LEASING PRAHA S.R.O. PRAGUE CZECH REPUBLIC X X CA-LEASING SENIOREN PARK GMBH VIENNA AUSTRIA X X CA-LEASING TERRA POSLOVANJE Z NEPREMICNINAMI D.O.O. CA-LEASING YPSILON INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG CA-LEASING ZETA INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG LJUBLJANA SLOVENIA X X BUDAPEST HUNGARY X X BUDAPEST HUNGARY X X CALG 307 MOBILIEN LEASING GMBH VIENNA AUSTRIA X X CALG 443 GRUNDSTUCKVERWALTUNG GMBH VIENNA AUSTRIA X X CALG 451 GRUNDSTUCKVERWALTUNG GMBH VIENNA AUSTRIA X X CALG ALPHA GRUNDSTUCKVERWALTUNG GMBH VIENNA AUSTRIA X X CALG ANLAGEN LEASING GMBH VIENNA AUSTRIA X X CALG ANLAGEN LEASING GMBH & CO GRUNDSTUCKVERMIETUNG UND -VERWALTUNG KG MUNICH GERMANY X X CALG DELTA GRUNDSTUCKVERWALTUNG GMBH VIENNA AUSTRIA X X CALG GAMMA GRUNDSTUCKVERWALTUNG GMBH VIENNA AUSTRIA X X CALG GRUNDSTUCKVERWALTUNG GMBH CALG HOTELGRUNDSTUCKVERWALTUNG GRUNDUNG 1986 GMBH VIENNA AUSTRIA X X VIENNA AUSTRIA X X CALG IMMOBILIEN LEASING GMBH VIENNA AUSTRIA X X CALG MINAL GRUNDSTUCKVERWALTUNG GMBH CAL-PAPIER INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG VIENNA AUSTRIA X X BUDAPEST HUNGARY X X CAPITALIA MERCHANT S.P.A. ROME ITALY X X CAPITALIA PARTECIPAZIONI S.P.A. ROME ITALY X X CDM CENTRALNY DOM MAKLERSKI PEKAO SA VARSAW POLAND X X CHARADE LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X CHEFREN LEASING GMBH VIENNA AUSTRIA X X CIVITAS IMMOBILIEN LEASING GESELLSCHAFT M.B.H. COMMUNA - LEASING GRUNDSTUCKSVERWALTUNGSGESELLSCHAFT M.B.H. VIENNA AUSTRIA X X VIENNA AUSTRIA X X CONTRA LEASING-GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X CORDUSIO SOCIETA' FIDUCIARIA PER AZIONI CUKOR INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG MILAN ITALY X X BUDAPEST HUNGARY X X DEBO LEASING IFN S.A. BUCAREST ROMANIA X X DLB LEASING, S.R.O. PRAGUE CZECH REPUBLIC X X DLV IMMOBILIEN LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X DUODEC Z IMMOBILIEN LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X ENTASI SRL ROME ITALY X X EUROFINANCE 2000 SRL EUROLEASE AMUN IMMOBILIEN LEASING GESELLSCHAFT M.B.H. ROME ITALY X X VIENNA AUSTRIA X X 29 proportional consolidatio fully consolidated RWA Deduction from capital Country proportional consolidated Company name Town consolidation in F/S treatment in prudential report full consolidated Headquarter Financial entities EUROLEASE ANUBIS IMMOBILIEN LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X EUROLEASE ISIS IMMOBILIEN LEASING GESELLSCHAFT M.B.H. EUROLEASE MARDUK IMMOBILIEN LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X VIENNA AUSTRIA X X EUROLEASE RA IMMOBILIEN LEASING GESELLSCHAFT M.B.H. EUROLEASE RAMSES IMMOBILIEN LEASING GESELLSCHAFT M.B.H. EUROPA FUND MANAGEMENT (EUROPA BEFEKTETESI ALAPKEZELO RT) VIENNA AUSTRIA X X VIENNA AUSTRIA X X BUDAPEST HUNGARY X X EUROPEAN TRUST S.P.A. BRESCIA ITALY X X EXPANDA IMMOBILIEN LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X FIDES IMMOBILIEN TREUHAND GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X FINANSE PLC. LONDON UNITED KINGDOM X X FINECO CREDIT S.P.A. MILAN ITALY X X FINECO LEASING S.P.A. BRESCIA ITALY X X FINECO PRESTITI S.P.A. MILAN ITALY X X FINECO VERWALTUNG AG FRANKFURT AM MAIN GERMANY X X FM GRUNDSTUCKSVERWALTUNGS GMBH & CO. KG FMC LEASING INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG BAD HOMBURG GERMANY X X BUDAPEST HUNGARY X X FMZ SAVARIA SZOLGALTATO KFT BUDAPEST HUNGARY X X FMZ SIGMA PROJEKTENTWICKLUNGS GMBH VIENNA AUSTRIA X X FOLIA LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X FUGATO LEASING GESELLSCHAFT M.B.H. G.N.E. GLOBAL GRUNDSTUCKSVERWERTUNG GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X VIENNA AUSTRIA X X GALA GRUNDSTUCKVERWALTUNG GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X GBS GRUNDSTUCKSVERWALTUNGSGESELLSCHAFT M.B.H. GEBAUDELEASING GRUNDSTUCKSVERWALTUNGSGESELLSCHAFT M.B.H. GEMEINDELEASING GRUNDSTUCKVERWALTUNG GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X VIENNA AUSTRIA X X VIENNA AUSTRIA X X GRUNDSTUCKSVERWALTUNG LINZ-MITTE GMBH GRUNDSTUCKSVERWALTUNGSGESELLSCHAFT M.B.H. & CO. KG. VIENNA AUSTRIA X X BREGEN AUSTRIA X X H.F.S. HYPO-FONDSBETEILIGUNGEN FUR SACHWERTE GMBH MUNICH GERMANY X X HERKU LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X HOKA LEASING-GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X HONEU LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X HVB - LEASING PLUTO KFT BUDAPEST HUNGARY X X HVB ALTERNATIVE ADVISORS LLC NEW YORK U.S.A. X X HVB ALTERNATIVE FINANCIAL PRODUCTS AG VIENNA AUSTRIA X X HVB ASSET MANAGEMENT HOLDING GMBH MUNICH GERMANY X X HVB AUTO LEASING EOOD SOFIA BULGARIA X X HVB CAPITAL ASIA LIMITED HONG KONG JAPAN X X HVB CAPITAL LLC WILMINGTON U.S.A. X X HVB CAPITAL LLC II WILMINGTON U.S.A. X X HVB CAPITAL LLC III WILMINGTON U.S.A. X X HVB CAPITAL LLC VI WILMINGTON U.S.A. X X HVB CAPITAL LLC VIII WILMINGTON U.S.A. X X HVB CAPITAL PARTNERS AG MUNICH GERMANY X X HVB CESAR D.O.O. BEOGRAD BELGRADE SERBIA X X BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 30 proportional consolidatio fully consolidated RWA Deduction from capital Country proportional consolidated Company name Town consolidation in F/S treatment in prudential report full consolidated Headquarter Financial entities HVB FIERO LEASING OOD SOFIA BULGARIA X HVB FONDSFINANCE GMBH MUNICH GERMANY X X X HVB FUNDING TRUST II WILMINGTON U.S.A. X X HVB FUNDING TRUST VIII WILMINGTON U.S.A. X X HVB GLOBAL ASSETS COMPANY L.P. NEW YORK U.S.A. X X HVB HONG KONG LIMITED HONG KONG CHINA X X HVB IMMOBILIEN AG MUNICH GERMANY X X HVB INVESTMENTS (UK) LIMITED CAYMAN ISLANDS X X HVB LEASING CPB D.O.O. SARAJEVO CAYMAN ISLANDS OSNIA AND HERCEGOVINA X X HVB LEASING CZECH REPUBLIC S.R.O. PRAGUE CZECH REPUBLIC X X HVB LEASING GMBH HVB LEASING MAX INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG HAMBURG GERMANY X X BUDAPEST HUNGARY X X HVB LEASING OOD SOFIA BULGARIA X X HVB LEASING SLOVAKIA S.R.O. BRATISLAVA SLOVAKIA X X HVB PROJEKT GMBH MUNICH GERMANY X X HVB SUPER LEASING EOOD SOFIA BULGARIA X X HVB TECTA GMBH MUNICH GERMANY X X HVB U.S. FINANCE INC. NEW YORK U.S.A. X X HVB VERWA 4 GMBH MUNICH GERMANY X X HVB VERWA 4.4 GMBH HVB-LEASING AIDA INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG MUNICH GERMANY X X BUDAPEST HUNGARY X X BUDAPEST HUNGARY X X BUDAPEST HUNGARY X X BUDAPEST HUNGARY X X HVB-LEASING ATLANTIS INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG HVB-LEASING DANTE INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG HVB-LEASING FIDELIO INGATLANHASNOSITO KORLATOLT FELELOSSEGU TARSASAG HVB-LEASING FORTE INGATLANHASNOSITO KORLATOLT FELELOSSEGU TARSASAG BUDAPEST HUNGARY X X HVB-LEASING GARO KFT HVB-LEASING HAMLET INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG BUDAPEST HUNGARY X X BUDAPEST HUNGARY X X HVB-LEASING JUPITER KFT BUDAPEST HUNGARY X X HVB-LEASING LAMOND INGATLANHASZNOSITO KFT. BUDAPEST HUNGARY X X HVB-LEASING MAESTOSO INGATLANHASZNOSITO KFT. BUDAPEST HUNGARY X X HVB-LEASING NANO KFT HVB-LEASING OTHELLO INGATLANHASNOSITO KORLATOLT FELELOSSEGU TARSASAG HVB-LEASING ROCCA INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG BUDAPEST HUNGARY X X BUDAPEST HUNGARY X X BUDAPEST HUNGARY X X HVB-LEASING RUBIN KFT. BUDAPEST HUNGARY X X HVB-LEASING SMARAGD KFT. HVB-LEASING SPORT INGATLANHASZNOSITO KOLATPOT FEOEOASSEGU TARSASAG BUDAPEST HUNGARY X X BUDAPEST HUNGARY X X HVB-LEASING ZAFIR KFT. IMMOBILIENLEASING GRUNDSTUCKSVERWALTUNGSGESELLSCHAFT M.B.H. BUDAPEST HUNGARY X X VIENNA AUSTRIA X X INPROX CHOMUTOV, S.R.O. PRAGUE CZECH REPUBLIC X X INPROX KARLOVY VARY, S.R.O. PRAGUE CZECH REPUBLIC X X INPROX KLADNO, S.R.O. PRAGUE CZECH REPUBLIC X X INPROX POPRAD, SPOL. S.R.O. BRATISLAVA SLOVAKIA X X INPROX SR I., SPOL. S R.O. BRATISLAVA SLOVAKIA X X 31 proportional consolidatio fully consolidated RWA Deduction from capital Country proportional consolidated Company name Town consolidation in F/S treatment in prudential report full consolidated Headquarter proportional consolidatio fully consolidated RWA Deduction from capital Country proportional consolidated Company name Town consolidation in F/S treatment in prudential report full consolidated Headquarter Financial entities INTERNATIONALES IMMOBILIEN-INSTITUT GMBH MUNICH GERMANY X X INTRO LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X JAUSERN-LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X KADMOS IMMOBILIEN LEASING GMBH VIENNA AUSTRIA X X KAMILLE SENIORENRESIDENZ IMMOBILIEN G.M.B.H. & CO. KEG VIENNA AUSTRIA X X KOC FINANSAL HIZMETLER AS ISTANBUL TURKEY KUNSTHAUS LEASING GMBH VIENNA AUSTRIA X X KUTRA GRUNDSTUCKSVERWALTUNGS-GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X LAGERMAX LEASING GMBH VIENNA AUSTRIA X X LAGEV IMMOBILIEN LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X LARGO LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X LEASFINANZ GMBH VIENNA AUSTRIA X X LEGATO LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X LELEV IMMOBILIEN LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X LF BETEILIGUNGEN GMBH VIENNA AUSTRIA X X LFL LUFTFAHRZEUG LEASING GMBH HAMBURG GERMANY X X LINO HOTEL-LEASING GMBH VIENNA AUSTRIA X X X X LIPARK LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X LIVA IMMOBILIEN LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X LOCAT CROATIA DOO ZAGREB CROATIA X X LOCAT SPA M. A. V. 7., BANK AUSTRIA LEASING BAUTRAGER GMBH & CO.OHG. BOLOGNA ITALY X X VIENNA AUSTRIA X X MBC IMMOBILIEN LEASING GESELLSCHAFT M.B.H. MENUETT GRUNDSTUCKSVERWALTUNGS-GESELLSCHAFT M.B.H. MIK BETA INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG MIK INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG VIENNA AUSTRIA X X VIENNA AUSTRIA X X BUDAPEST HUNGARY X X BUDAPEST HUNGARY X X MM OMEGA PROJEKTENTWICKLUNGS GMBH VIENNA AUSTRIA X X MOBILITY CONCEPT GMBH UNTERHACHING GERMANY X X MOGRA LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X NAGE LOKALVERMIETUNGSGESELLSCHAFT M.B.H. VIENNA AUSTRIA X X NATA IMMOBILIEN-LEASING GESELLSCHAFT M.B.H. NO. HYPO LEASING ASTRICTA GRUNDSTUCKVERMIETUNGS GESELLSCHAFT M.B.H. NORDINVEST NORDDEUTSCHE INVESTMENT-GESELLSCHAFT MBH VIENNA AUSTRIA X X VIENNA AUSTRIA X X HAMBURG GERMANY X X OBI-2 INGATLANKZELO KFT BUDAPEST HUNGARY X X OBI-3 INGATLANKZELO KFT BUDAPEST HUNGARY X X OBI-4 INGATLANKZELO KFT BUDAPEST HUNGARY X X OCT Z IMMOBILIEN LEASING GESELLSCHAFT M.B.H OLG HANDELS- UND BETEILIGUNGSVERWALTUNGSGESELLSCHAFT M.B.H. VIENNA AUSTRIA X X VIENNA AUSTRIA X X OLG INDUSTRIEGUTER LEASING GMBH & CO. KG. VIENNA AUSTRIA X X OOO IMB LEASING COMPANY MOSCOW RUSSIA X X OPEN SAVING PENSIOON FUND OTAN JSC ALMATY CITY KAZAKHSTAN X X ORBIT ASSET MANAGEMENT LIMITED HAMILTON BERMUDA X X BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 32 Financial entities ORESTOS IMMOBILIEN-VERWALTUNGS GMBH PARZHOF-ERRICHTUNGS- UND VERWERTUNGSGESELLSCHAFT M.B.H. PAZONYI'98 INGATLANHASZNOSITO KORLATOLT FELELOSSEGU TARSASAG MUNICH GERMANY X X VIENNA AUSTRIA X X BUDAPEST HUNGARY X X PEKAO AUTO FINANSE SA VARSAW POLAND X X PEKAO FAKTORING SP. ZOO LUBLIN POLAND X X PEKAO FINANCIAL SERVICES SP. ZOO VARSAW POLAND X X PEKAO FUNDUSZ KAPITALOWY SP. ZOO VARSAW POLAND X X PEKAO LEASING HOLDING S.A. VARSAW POLAND X X PEKAO LEASING I FINANSE VARSAW POLAND X X PEKAO LEASING SP ZO.O. VARSAW POLAND X X PEKAO PIONEER P.T.E. SA VARSAW POLAND X X PELOPS LEASING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X X PESTSZENTIMREI SZAKORVOSI RENDELO KFT. BUDAPEST HUNGARY X X PIANA LEASING GESELLSCHAFT M.B.H. PIONEER ALTERNATIVE INVESTMENT MANAGEMENT (BERMUDA) LIMITED VIENNA AUSTRIA X X HAMILTON BERMUDA X X PIONEER ALTERNATIVE INVESTMENT MANAGEMENT LTD DUBLIN IRELAND X X PIONEER ALTERNATIVE INVESTMENT MANAGEMENT SGR PA MILAN ITALY X X PIONEER ALTERNATIVE INVESTMENTS (ISRAEL) LTD TEL AVIV ISRAEL X X PIONEER ALTERNATIVE INVESTMENTS (NEW YORK) LTD DOVER U.S.A. X X PIONEER ASSET MANAGEMENT AS PRAGUE CZECH REPUBLIC X X PIONEER ASSET MANAGEMENT S.A.I. S.A. BUCAREST ROMANIA X X PIONEER ASSET MANAGEMENT SA LUXEMBURG LUXEMBOURG X X PIONEER CZECH FINANCIAL COMPANY SRO PRAGUE CZECH REPUBLIC X X PIONEER FUNDS DISTRIBUTOR INC BOSTON U.S.A. X X PIONEER GLOBAL ASSET MANAGEMENT SPA MILAN ITALY X X PIONEER GLOBAL FUNDS DISTRIBUTOR LTD HAMILTON BERMUDA X X PIONEER GLOBAL INVESTMENTS (AUSTRALIA) PTY LIMITED MELBOURNE AUSTRALIA X X PIONEER GLOBAL INVESTMENTS (HK) LIMITED HONG KONG CHINA X X PIONEER GLOBAL INVESTMENTS (TAIWAN) LTD. TAIPEI TAIWAN X X PIONEER GLOBAL INVESTMENTS LIMITED DUBLIN IRELAND X X PIONEER INSTITUTIONAL ASSET MANAGEMENT INC WILMINGTON U.S.A. X X PIONEER INVESTMENT COMPANY AS PRAGUE CZECH REPUBLIC X X PIONEER INVESTMENT FUND MANAGEMENT LIMITED BUDAPEST HUNGARY X X PIONEER INVESTMENT MANAGEMENT INC WILMINGTON U.S.A. X X PIONEER INVESTMENT MANAGEMENT LIMITED DUBLIN IRELAND X X PIONEER INVESTMENT MANAGEMENT LLC PIONEER INVESTMENT MANAGEMENT SHAREHOLDER SERVICES INC. PIONEER INVESTMENT MANAGEMENT SOC. DI GESTIONE DEL RISPARMIO PER AZ MOSCOW RUSSIA X X BOSTON U.S.A. X X MILAN ITALY X X PIONEER INVESTMENT MANAGEMENT USA INC. WILMINGTON U.S.A. X X PIONEER INVESTMENTS AG BERN SWITZERLAND X X PIONEER INVESTMENTS KAPITALANLAGEGESELLSCHAFT MBH MUNICH GERMANY X X PIONEER PEKAO INVESTMENT FUND COMPANY SA (POLISH NAME: PIONEER PEKAO TFI SA) VARSAW POLAND X X PIONEER PEKAO INVESTMENT MANAGEMENT SA VARSAW POLAND X X 33 proportional consolidatio fully consolidated RWA Deduction from capital Country proportional consolidated Company name Town consolidation in F/S treatment in prudential report full consolidated Headquarter proportional consolidatio fully consolidated RWA Deduction from capital Country proportional consolidated Company name Town consolidation in F/S treatment in prudential report full consolidated Headquarter Financial entities POLIMAR 13 SPOLKA Z OGRANICZONA ODPOWIEDZIALNOSCIA VARSAW POLAND X X POLIMAR 6 SPOLKA Z OGRANICZONA ODPOWIEDZIALNOSCIA VARSAW POLAND X X POSATO LEASING GESELLSCHAFT M.B.H. PRELUDE GRUNDSTUCKSVERWALTUNGS-GESELLSCHAFT M.B.H. 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CRACOW POLAND X X DOMUS BISTRO GMBH VIENNA AUSTRIA X X DOMUS CLEAN REINIGUNGS GMBH VIENNA AUSTRIA X X DOMUS FACILITY MANAGEMENT GMBH DUSSELDORF-MUNCHENER BETEILIGUNGSGESELLSCHAFT MBH VIENNA AUSTRIA X X MUNICH GERMANY X FINANCIAL RISK MANAGEMENT GMBH VIENNA AUSTRIA X FOOD & MORE GMBH MUNICH GERMANY X GANYMED IMMOBILIENVERMIETUNGSGESELLSCHAFT M.B.H. GRUNDSTUCKSGESELLSCHAFT SIMON BESCHRANKT HAFTENDE KOMMANDITGESELLSCHAF VIENNA AUSTRIA X MUNICH GERMANY X HUMAN RESOURCES SERVICE AND DEVELOPMENT GMBH HVB DIREKT GESELLSCHAFT FUR DIREKTSERVICE UND DIREKTVERTRIEB MBH VIENNA AUSTRIA X MUNICH GERMANY X HVB FINANCE LONDON LIMITED LONDON UNITED KINGDOM X HVB GESELLSCHAFT FUR GEBAUDE BETEILIGUNGS GMBH MUNICH GERMANY X HVB REALITY CZ, S.R.O. PRAGUE CZECH REPUBLIC X HVB SECUR GMBH MUNICH X HVB SERVICES SOUTH AFRICA (PROPRIETARY) LIMITED JOHANNESBURG GERMANY SOUTH AFRICAN REPUBLIC HYPO-BANK VERWALTUNGSZENTRUM GMBH MUNICH GERMANY X HYPOVEREINS IMMOBILIEN EOOD SOFIA BULGARIA X IMMOBILIEN RATING GMBH VIENNA AUSTRIA X X X KLEA ZS-IMMOBILIENVERMIETUNG G.M.B.H. VIENNA AUSTRIA X KLEA ZS-LIEGENSCHAFTSVERMIETUNG G.M.B.H. VIENNA AUSTRIA X LIMITED LIABILITY COMPANY B.A. REAL ESTATE MOSCOW RUSSIA X X MARKETING ZAGREBACKE BANKE DOO MERKURHOF GRUNDSTUCKSGESELLSCHAFT MIT BESCHRANKTER HAFTUNG ZAGREB CROATIA X X HAMBURG GERMANY X MY DREI HANDELS GMBH VIENNA AUSTRIA X NADINION VERWALTUNGSGESELLSCHAFT MBH MUNICH GERMANY X PALAIS ROTHSCHILD VERMIETUNGS GMBH VIENNA AUSTRIA X BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 40 proportional consolidatio fully consolidated RWA Deduction from capital Country proportional consolidated Company name Town consolidation in F/S treatment in prudential report full consolidated Headquarter Ancillary banking services entities PALAIS ROTHSCHILD VERMIETUNGS GMBH & CO OEG PORTIA GRUNDSTUCKSVERWALTUNGS-GESELLSCHAFT MIT BESCHRANKTER HAFTUNG VIENNA MUNICH GERMANY X PROPERTY SP. Z.O.O. (IN LIQUIDAZIONE) VARSAW POLAND X SALVATORPLATZ-GRUNDSTUCKSGESELLSCHAFT MBH SALVATORPLATZ-GRUNDSTUCKSGESELLSCHAFT MBH & CO. OHG SAARLAND MUNICH GERMANY X MUNICH GERMANY X SAS-REAL KFT. SOCIETA' AMMINISTRAZIONE IMMOBILI - S.A.IM. S.P.A. IN LIQUIDAZIONE SOCIETA' ITALIANA GESTIONE ED INCASSO CREDITI S.P.A. IN LIQUIDAZIONE BUDAPEST HUNGARY X ROME ITALY X ROME ITALY X TC-QUINTA PROJEKTVERWALTUNGSGESELLCHAFT M.B.H. VIENNA AUSTRIA X UNICREDIT AUDIT (IRELAND) LTD DUBLIN SARAJEVO IRELAND BOSNIA AND HERCEGOVINA X UPI POSLOVNI SISTEM DOO VERWALTUNGSGESELLSCHAFT KATHARINENHOF MBH WEILBURG GRUNDSTUCKVERMIETUNGSGESELLSCHAFT M.B.H. HAMBURG GERMANY X VIENNA AUSTRIA X ZAGREB NEKRETNINE DOO ZAGREB X X ZANE BH DOO SARAJEVO CROATIA BOSNIA AND HERCEGOVINA X X 41 AUSTRIA X X proportional consolidatio fully consolidated RWA Deduction from capital Country proportional consolidated Company name Town consolidation in F/S treatment in prudential report full consolidated Headquarter SUBSIDIARIES ADDED TO RWA Banks HVB SINGAPORE LIMITED SINGAPORE SINGAPORE X B.I. INTERNATIONAL LIMITED GEORGE TOWN CAYMAN ISLANDS CA IB CORPORATE FINANCE OOO MOSCOW RUSSIA CA IB D.D. ZAGREB CROATIA X X CA IB SECURITIES (UKRAINE) AT KIEV UKRAINE X X CAMERON GRANVILLE 2 ASSET MANAGEMENT INC TAGUIG PHILIPPINES X CAMERON GRANVILLE 3 ASSET MANAGEMENT INC. TAGUIG PHILIPPINES X CAMERON GRANVILLE ASSET MANAGEMENT (SPV-AMC) , INC TAGUIG PHILIPPINES X COBB BETEILIGUNGEN UND LEASING GMBH VIENNA AUSTRIA X DINERS CLUB CZECH REPUBLIC S.R.O. PRAGUE CZECH REPUBLIC X DINERS CLUB POLSKA SP.Z.O.O. VARSAW POLAND X DINERS CLUB SLOVAKIA S.R.O. BRATISLAVA SLOVAKIA X FM BETEILIGUNGS-GMBH VIENNA AUSTRIA X GRUNDERFONDS GMBH & CO KEG VIENNA AUSTRIA X HVB ASIA ADVISERS SDN. BHD. KUALA LAMPUR MALAYSIA X HVB ASSET LEASING LIMITED LONDON UNITED KINGDOM X HVB ASSET MANAGEMENT ASIA LTD. SINGAPORE SINGAPORE X HVB AUSTRALIA PTY LTD. SYDNEY AUSTRALIA X HVB CAPE BLANC LLC WILMINGTON U.S.A. X Financial entities X X X X HVB REALTY CAPITAL INC. NEW YORK U.S.A. X HVBFF INTERNATIONAL GREECE GMBH MUNICH GERMANY X LB HOLDING GESELLSCHAFT M.B.H. VIENNA AUSTRIA X REAL INVEST IMMOBILIEN GMBH VIENNA AUSTRIA X SFS FINANCIAL SERVICES GMBH VIENNA AUSTRIA X UNICREDIT CA IB ROMANIA SRL BUCAREST ROMANIA X X UNICREDIT CAIB CZECH REPUBLIC AS PRAGUE CZECH REPUBLIC X X UNICREDIT CAIB HUNGARY LTD BUDAPEST HUNGARY X X UNICREDIT CAIB SERBIA LTD BELGRADE BELGRADE SERBIA X X UNICREDIT CAIB SLOVAKIA, A.S. BRATISLAVA SLOVAKIA X X UNICREDIT CAIB UK LTD. LONDON UNITED KINGDOM X X UNICREDIT LEASING AUTO BULGARIA EOOD SOFIA BULGARIA X X ZAO IMB-LEASING MOSCOW RUSSIA X X ZB INVEST DOO ZAGREB CROATIA X X BA-CA BETRIEBSOBJEKTE AG & CO BETA VERMIETUNGS OEG VIENNA AUSTRIA X BA-CA BETRIEBSOBJEKTE PRAHA SPOL.S.R.O. PRAGUE CZECH REPUBLIC X HVB FINANCNE SLUZBY S.R.O. BRATISLAVA SLOVAKIA X MILARIS S.A. EN LIQUIDATION VEREINSBANK LEASING INTERNATIONAL VERWALTUNGSGESELLSCHAFT MBH WAVE SOLUTIONS HUNGARY BANK ES PENZUGYTECHNIKAI TANACSADA KFT. PARIS FRANCE X HAMBURG GERMANY X BUDAPEST HUNGARY X Ancillary banking services entities BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 42 proportional consolidatio fully consolidated RWA Deduction from capital Country proportional consolidated Company name Town consolidation in F/S treatment in prudential report full consolidated Headquarter Table 3 – Supervisory capital structure Qualitative disclosure Capital instruments included in Tier 1 capital Amounts as at June 30, 2008 – (€ thousand) Amount included in Regulatory Capital (Eur/000) step-up clause 540 450 750 300 350 600 300 200 300 100 200 25.000 540.000 285.460 750.000 378.668 442.140 600.000 290.000 200.000 190.110 126.230 126.740 150.150 yes yes yes yes yes yes no no no no no no yes yes yes yes yes no no no yes yes yes yes yes yes yes yes yes yes no no yes yes yes yes EUR 245 248.800 no no no mar-12 EUR 147 149.756 no no no (°°°) perpetual dec-11 TOTALE (*) Prepayment option is not available (**) Constant Maturity Swap (***) Interest is linked to results of the company EUR 10 10.778 4.488.832 no no sì Amount in original currency (million) Interest rate maturity date Starting date of prepayment option 8,05% 9,20% 4,03% 5,40% 8,59% 7,055% 12m L + 1,25% 12m L + 1,25% 8,741% 7,76% 9,00% 3,50% perpetual perpetual perpetual perpetual 31-dec-50 perpetual 7-jun-11 7-jun-11 30-jun-31 13-oct-36 22-oct-31 31-dec-31 oct-10 oct-10 oct-15 oct-15 jun-18 mar-12 (°) (°) jun-29 oct-34 oct-29 dec-29 EUR USD EUR GBP GBP EUR EUR EUR USD GBP USD JPY 10y CMS (°°) +0,10%, cap 8,00 % perpetual oct-11 10y CMS (°°) +0,15%, cap 8,00 % perpetual Option to Issued through a suspend interest SPV subsidiary payment Tier 2 capital – upper tier 2 instruments which account for more then 10% of the total issued amount: Amounts as at June 30, 2008 – (€ thousand) Interest rate maturity date Starting date of prepayment option Amount in original currency (million) Amount included in Regulatory Capital (Eur/000) step-up clause Option to suspend interest payment 3,95% 1-feb-16 not applicable EUR not applicable Yes (°) 900 897.452 5,00% 1-feb-16 not applicable GBP not applicable Yes (°) 450 567.153 6,70% 5-jun-18 not applicable EUR not applicable Yes (°) 1.000 998.232 6,10% 28-feb-12 not applicable EUR not applicable Yes (°) 500 489.860 (*) -- if dividend is not paid, payment of intertest is suspended (deferral of interest) -- if losses take share capital and reserves under the threshold set by Banca d'Italia to authorize banking business, face value and interest are proportionally reduced 43 Quantitative disclosure (€ thousand) Composition of capital for regulatory purposes CAPITAL FOR REGULATORY PURPOSES A. 06/30/2008 Tier 1 before solvency filters Tier 1 positive items: A.1 A.1.1 - Capital A.1.2 - Share premium account 35.576.021 A.1.3 A.1.4 - Reserves - Non-innovative capital instruments 15.517.447 1.492.564 A.1.5 - Innovative capital instruments 2.996.268 A.1.6 - Net income of the period/Interim profit 1.445.842 A.2 7.323.240 Tier 1 negative items: A.2.1 - Treasury stocks A.2.2 A.2.3 - Goodwill - Other intangible assets A.2.4 - Loss of the year/Interim loss A.2.5 - Other negative items: -880.754 -21.268.274 -4.208.770 * Value adjustments calculated on the supervisory trading book * Others B. Tier 1 solvency filters Positive IAS/IFRS solvency filters (+) B.1 B.2 Negative IAS/IFRS solvency filters (-) C. Tier 1 capital gross of items to be deducted (A+B) -459.751 37.533.833 D. Items to be deducted -1.903.740 E. F. Total TIER 1 (C-D) Tier 2 before solvency filters Tier 2 positive items: 35.630.093 F.1 F.1.1 - Valuation reserves of tangible assets F.1.2 - Valuation reserves of available-for-sale securities F.1.3 - Non-innovative capital instruments not eligible for inclusion in Tier 1 capital F.1.4 F.1.5 - Innovative capital instruments not eligible for inclusion in Tier 1 capital - Hybrid capital instruments F.1.6 - Tier 2 subordinated liabilities F.1.7 - Surplus of the overall value adjustments compared to the expected losses F.1.8 - Net gains on participating interests F.1.9 F.2 F.2.1 F.2.2 F.2.3 G. G.1 G.2 - Other positive items 401.306 4.266.025 18.766.916 277.495 Tier 2 negative items: - Net capital losses on participating interests - Loans - Other negative items Tier 2 solvency filters Positive IAS/IFRS solvency filters (+) Negative IAS/IFRS solvency filters (-) -200.653 H. Tier 2 capital gross of items to be deducted (F+G) I. Items to be deducted -1.903.740 L. M. Total TIER 2 (H-I) Deductions from Tier 1 and Tier 2 21.607.349 -980.751 N. O. Capital for regulatory purposes (E+L-M) Tier 3 P Capital for regulatory purposes included Tier 3 (N+O) 56.256.691 640.778 56.897.469 23.511.089 The amounts of negative difference between expected losses and related write-downs is €638.715 thousand. BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 44 Table 4 – Capital adequacy Qualitative disclosure The UniCredit Group has made a priority of capital management and allocation (for both regulatory and internal capital) on the basis of the risk assumed in order to expand the Group’s operations and create value. These activities are part of the Group planning and monitoring process and comprise: planning and budgeting processes: - proposals as to risk propensity and capitalisation objectives; - analysis of risk associated with value drivers and allocation of capital to business areas and units; - assignment of risk-adjusted performance objectives; - analysis of the impact on the Group’s value and the creation of value for shareholders; - preparation and proposal of the financial plan and dividend policy; monitoring processes - analysis of performance achieved at Group and business unit level and preparation of management reports for internal and external use; - analysis and monitoring of limits; - analysis and performance monitoring of the capital ratios of the Group and individual companies. The Group has set itself the goal of generating income in excess of that necessary to remunerate risk (cost of equity), and thus of creating value, so as to maximise the return for its shareholders in terms of dividends and capital gains (total shareholder return). This is achieved by allocating capital to various business areas and business units on the basis of specific risk profiles and by adopting a methodology based on risk-adjusted performance measurement (RAPM), which will provide, in support of planning and monitoring processes, a number of indicators that will combine and summarise the operating, financial and risk variables to be considered. Capital and its allocation are therefore extremely important for strategy, since capital is the object of the return expected by investors on their investment in the Group, and also because it is a resource on which there are external limitations imposed by regulatory provisions. The definitions of capital used in the allocation process are as follows: Risk or employed capital: This is the equity component provided by shareholders (employed capital) for which a return that is greater than or equal to expectations (cost of equity) must be provided; Capital at risk: This is the portion of capital and reserves that is used (the budgeted amount or allocated capital) or was used to cover (at period-end - absorbed capital) risks assumed to pursue the objective of creating value. Capital at risk is dependant on the propensity for risk and is based on the target capitalisation level which is also determined in accordance with the Group’s credit rating. If capital at risk is measured using risk management methods, it is defined as internal capital, if it is measured using regulatory provisions, it is defined as regulatory capital. In detail: 45 Internal capital is the portion of equity that is actually at risk, which is measured using probability models over a specific confidence interval. Regulatory capital is the component of total capital represented by the portion of shareholders’ equity put at risk (Core Equity or Core Tier 1) that is measured using regulatory provisions. Internal capital and regulatory capital differ in terms of their definition and the categories of risk covered. The former is based on the actual measurement of exposure assumed, while the latter is based on schedules specified in regulatory provisions. The relationship between the two different definitions of capital at risk can be obtained by relating the two measures to the Group’s target credit rating (AA- by S&P) which corresponds to a probability of default of 0.03%. Thus, internal capital is set at a level that will cover adverse events with a probability of 99.97% (confidence interval), while regulatory capital is quantified on the basis of a Core Tier 1 target ratio in line with that of major international banking groups with at least the same target rating. Thus, during the application process the “double track” approach is used which assumes that allocated capital is the greater of internal capital and regulatory capital (Core Tier 1) at both the consolidated and business area or business unit levels. If internal capital is higher, this approach makes it possible to allocate the actual capital at risk that regulators have not yet been able to incorporate, and if regulatory capital is higher, it is possible to allocate capital in keeping with regulatory provisions. The starting point for the capital allocation process is consolidated capital attributable to the Group. The purpose of the capital management function performed by the Capital Allocation unit of Planning, Finance and Administration is to define the target level of capitalisation for the Group and its companies in line with regulatory restrictions and the propensity for risk. Capital is managed dynamically: the Capital Allocation unit prepares the financial plan, monitors capital ratios for regulatory purposes on a monthly basis and anticipates the appropriate steps required to achieve its goals. On the one hand, monitoring is carried out in relation to both shareholders’ equity and the composition of capital for regulatory purposes (Core Tier 1, Tier 1, Lower and Upper Tier 2 and Tier 3 Capital), and on the other hand, in relation to the planning and performance of risk-weighted assets (RWA). The dynamic management approach aims to identify the investment and capital-raising instruments and hybrid capital instruments that are most suitable for achieving the Group’s goals. If there is a capital shortfall, the gaps to be filled and capital generation measures are indicated, and their cost and efficiency are measured using RAPM. In this context, value analysis is enhanced by the joint role played by the Capital Allocation unit in the areas of regulatory, accounting, financial, tax-related, risk management and other aspects and the changing regulations affecting these aspects so that an assessment and all necessary instructions can be given to other Group HQ areas or the companies asked to perform these tasks. BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 46 Quantitative disclosure (€ thousand) Capital adequacy Categories/Items RWA Requirement A. CAPITAL REQUIREMENTS A.1 Credit and counterparty risk 1. Standardized approach 485.054.586 38.804.367 317.482.031 25.398.563 162.642.222 13.011.378 4.930.334 394.427 2. IRB approaches 2.1 Foundation 2.1 Advanced 3. Securitizations A.2 Market risk 1.732.806 1. Standardized approach 948.711 2. Internal models approach 784.095 A.3 Operational risk 3.392.185 1. Basic indicator approach (BIA) 392.416 2. Traditional standardized approach (TSA) 1.229.461 3. Advanced measurement approach (AMA) 1.770.308 A.4 Other requirements - A.5 Total capital requirements (A.1+A.2+A.3+A.4) 43.929.358 B. RISK ASSETS AND CAPITAL RATIOS B.1 Weighted risk assets B.2 TIER 1 capital/Weighted risk assets (TIER 1 capital ratio) B.3 Capital for regulatory purposes (included TIER 3)/Weighted risk assets (Total capital ratio) 47 549.116.974 6,49% 10,36% Table 5 – Credit risk: general disclosures for all banks Qualitative disclosure Definition of impaired and past-due exposures Impaired loans and receivables are divided into the following categories: Non-performing loans - formally impaired loans, being exposure to insolvent borrowers, even if the insolvency has not been recognised in a court of law, or borrowers in a similar situation: measurement is on a loan-by-loan or portfolio basis; Doubtful loans - exposure to borrowers experiencing temporary difficulties, which the Group believes may be overcome within a reasonable period of time: measurement is generally on a loanby- loan basis or, for loans singularly not significant, on a portfolio basis for homogeneous categories of loans; Restructured loans - exposure to borrowers with whom a rescheduling agreement has been entered into including renegotiated pricing at interest rates below market, the conversion of part of a loan into shares and/or reduction of principal: measurement is on a loan-by-loan basis, including the present value of losses due to loan rates being lower than funding cost. Past-due loans - total exposure to any borrower not included in the other categories, who at the balancesheet date has expired facilities or unauthorised overdrafts that are more than 180 days past due. Total exposure is recognised in this category if, at the balance-sheet date, either: - - the expired or unauthorised borrowing; or: - the average daily amount of expired or unauthorised borrowings during the last preceding quarter are equal to or exceed 5% of total exposure. Measurement is on a portfolio basis using historical and statistical information. Collective assessment is used for groups of loans for which individually there are no indicators of impairment, but to which latent impairment can be attributed, inter alia on the basis of the risk factors in use under Basel II. Description of methodology applied to determinate the write-downs Loans and receivables are non-derivative financial assets with fixed or determinable payments that are not quoted in an active market. Loans and receivables are recognised on the date of contract signing, which normally coincides with the date of disbursement to the borrower. These items include debt instruments with the same characteristics. BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 48 After initial recognition at fair value, which usually is the price paid including transaction costs and income which are directly attributable to the acquisition or issuance of the financial asset (even if not paid), a loan or receivable is measured at amortised cost using the effective interest method, allowances or reversals of allowances being made where necessary on remeasuring. A gain or loss on loans and receivables that are not part of a hedging relationship is recognised in profit or loss: when a loan or receivable is derecognised: in item 100 (a) “Gains (losses) on disposal”; or: when a loan or receivable is impaired: in item 130 (a) “Impairment losses (a) loans and receivables”. Interest on loans and receivables is recognised in profit or loss on an accruals basis under item 10 “Interest income and similar revenue”. Delay interest is taken to the income statement on collection or receipt. A loan or receivable is deemed impaired when it is considered that it will probably not be possible to recover all the amounts due according to the contractual terms, or equivalent value. Allowances for impairment of loans and receivables are based on the present value of expected cash flows of principal and interest less recovery costs and any prepayments received; in determining the present value of future cash flows, the basic requirement is the identification of estimated collections, the timing of payments and the rate used. The amount of the loss on impaired exposure classified as nonperforming, doubtful or restructured according to the categories specified below, is the difference between the carrying value and the present value of estimated cash flows discounted at the original interest rate of the financial asset. If the original interest rate on a financial asset discounted for the first time in the year of changeover to IFRS, was not available, or obtaining it would have been too costly, the average interest rate on unimpaired positions in the year in which the original impairment of the asset was recognised, is used. This rate is maintained in all later years. Recovery times are estimated on the basis of any repayment schedules agreed with the borrower or included in a business plan or reasonably predicted, based on historical recovery experience observed for similar classes of loans, taking into account the type of loan, the geographical location, the type of security and any other factors considered relevant. Loans and receivables are reviewed to identify those that, following events occurring after initial recognition, display objective evidence of possible impairment. These problem loans are reviewed and analysed periodically at least once a year. Any subsequent change vis-à-vis initial expectations of the amount or timing of expected cash flows of principal and interest causes a change in allowances for impairment and is recognised in profit or loss in item 130(a) “Impairment losses (a) loans and receivables”. If the quality of the loan or receivable has improved and there is reasonable certainty that principal and interest will be recovered in a timely manner according to contractual terms, a reversal is made in the same profit or loss item, within the amount of the amortised cost that there would have been if there had been no impairments. Derecognition of a loan or receivable in its entirety is made when the loan or receivable is deemed to be irrecoverable or is written off. Write-offs are recognised directly in profit or loss under item 130(a) “Impairment losses (a) loans and receivables” and reduce the amount of the principal of the loan or receivable. Reversals of all or part of previous impairment losses are recognised in the same item. 49 Quantitative disclosure (€ thousand) Credit and counterparty risk AMOUNTS AS AT 06/30/2008 CREDIT AND COUNTERPARTY RISK NON-WEIGHTED AMOUNTS WEIGHTED AMOUNTS REQUIREMENT A. CREDIT AND COUNTERPARTY RISK A.1 STANDARDIZED APPROACH - RISK ASSETS A.1.1. Exposures with or secured by central governments or central banks 696.161.921 317.482.031 25.398.563 61.980.475 5.323.233 425.859 A.1.2. Exposures with or secured by regional administrations and local authorities 35.535.373 A.1.3. Exposures with or secured by administrative bodies and noncommercial undertakings 14.630.416 2.010.023 160.802 3.658.817 292.705 522.630 3.423 274 96.861 1.332 107 69.164.309 11.875.749 950.060 A.1.7. Exposures with or secured by corporates 296.836.139 182.816.542 14.625.324 A.1.8. Retail exposures 106.067.418 49.643.886 3.971.511 62.464.467 26.099.756 2.087.980 A.1.10. Past due exposures 8.492.226 9.232.377 738.590 A.1.11. High risk exposures 1.709.463 1.808.995 144.720 A.1.12. Exposures in the form of guaranteed bank bonds (covered bond) 2.784.569 271.838 21.747 A.1.13. Short term exposures with corporates A.1.14. Exposures in the form of Collective Investment Undertakings (CIU) 1.587.268 571.077 45.686 A.1.4. Exposures with or secured by multilateral development banks A.1.5. Exposures with or secured by international organizations A.1.6. Exposures with or secured by supervised institutions A.1.9. Exposures secured by real estate property 2.028.429 1.317.756 105.420 32.261.878 22.847.227 1.827.778 A.2 IRB APPROACH - RISK ASSETS A.2.1. Exposures with or secured by central administration and central banks A.2.2. Exposures with or secured by supervised institutions, public and territorial entities and other entities 500.325.298 159.867.119 12.789.370 5.703.572 199.513 15.961 143.538.637 18.775.358 1.502.029 A.2.3. Exposures with or secured by corporate 221.354.024 98.888.188 7.911.055 75.677.250 18.567.087 1.485.367 7.765.986 2.104.195 168.336 42.405.466 17.134.821 1.370.786 A.1.15. Other exposures A.2.4. Retail exposures secured by residential real estate property A.2.5. Qualified revolving retail exposures A.2.6. Other retail exposures A.2.7. Purchased receivables: diluition risk A.2.8. Other assets A.2.9. Specialized lending - slotting criteria A.2.10. Alternative treatment of mortgages A.2.11. Settlement risk: exposures connected to non DVP transactions with supervisory weighting factors A.3 IRB APPROACH - EXPOSURES IN EQUITY INSTRUMENTS A.3.1. PD/LGD approach: risk assets 0 0 0 34.261.864 1.114.570 89.166 3.819.314 3.022.338 241.787 0 0 0 61.049 61.049 4.884 2.457.553 2.775.103 222.008 18.669 41.289 3.303 38.214 A.3.2. Simple risk weight approach: risk assets - Private equity exposures in sufficiently diversified portfolios 251.407 477.673 - Exchange-traded equity exposures 24.531 71.141 5.691 - Other equity exposures A.3.3. Internal models approach: risk assets 2.162.946 0 2.185.000 0 174.800 0 BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 50 (€ thousand) Credit Risk: on/off balance sheet information to banks Amounts as at: 06/30/2008 Balance-sheet exposures Exposures/Portfolio Financial assets held for trading Gross exposure Average exposure Financial assets at fair value Available for sale financial through profit or loss assets Gross exposure Average exposure Gross exposure Average exposure Held to maturity financial instruments Loans and receivables with banks Gross exposure Gross exposure Average exposure Average exposure Non-current assets and disposal groups classified as held for sale Gross exposure Average exposure Off-Balance sheet exposures Gross exposure Average exposure A. Balance sheet exposures a) Non-performing loans 0 0 0 0 0 0 0 0 115.225 133.879 0 4 b) Doubtful loans 0 0 0 0 0 0 0 0 31.862 33.264 0 0 c) Restructured exposures 0 0 0 0 0 0 0 0 0 8.331 0 0 d) Past due exposures 0 0 0 0 0 0 0 0 0 0 0 0 e) Country Risk 0 0 0 0 0 0 0 0 107.764 117.899 0 0 f) Other assets 47.799.487 53.349.800 4.707.334 8.927.506 7.706.457 7.539.798 2.150.827 1.389.243 120.710.902 106.851.777 150.145 468.795 47.799.487 53.349.800 4.707.334 8.927.506 7.706.457 7.539.798 2.150.827 1.389.243 120.965.753 107.145.150 150.145 468.799 Total A B. Off-balance sheet exposures a) Impaired b) Others Total B TOTAL A+B 51 47.799.487 53.349.800 4.707.334 8.927.506 7.706.457 7.539.798 2.150.827 1.389.243 120.965.753 107.145.150 150.145 468.799 88.098 90.656 150.345.731 146.352.845 150.433.829 146.443.501 150.433.829 146.443.501 (€ thousand) Credit Risk: on/off balance sheet information to customers Amounts as at: 06/30/2008 Balance-sheet exposures Exposures/Portfolio Financial assets held for trading Gross exposure Average exposure Financial assets at fair value through profit or loss Gross exposure Average exposure Available for sale financial assets Gross exposure Held to maturity financial instruments Average exposure Gross exposure Loans and receivables with customers Average exposure Gross exposure Average exposure Non-current assets and disposal groups classified as held for sale Gross exposure Average exposure Off-Balance sheet exposures Gross exposure Average exposure A. Balance sheet exposures a) Non-performing loans 0 632 0 0 108.570 86.535 0 0 27.018.643 24.257.240 71.593 97.676 b) Doubtful loans 0 0 0 0 0 0 0 0 6.427.190 5.625.545 13.180 19.481 c) Restructured exposures 0 0 0 0 0 0 16.793 21.322 1.429.527 2.008.393 23 2.033 19.546 13.286 0 0 26.583 11.026 0 0 2.253.011 1.674.936 12.248 5.681 e) Country Risk 176 98 2.723 1.661 6.092 4.641 0 0 21.777 23.696 0 0 f) Other assets 76.972.457 82.267.364 10.588.777 6.329.089 25.728.523 24.880.716 9.312.307 9.569.267 585.137.696 530.284.223 3.024.034 2.770.003 76.992.179 82.281.380 10.591.500 6.330.750 25.869.768 24.982.918 9.329.100 9.590.588 622.287.844 563.874.034 3.121.078 2.894.875 d) Past due exposures Total A B. Off-balance sheet exposures a) Impaired b) Others Total B TOTAL A+B 76.992.179 82.281.380 10.591.500 6.330.750 25.869.768 24.982.918 9.329.100 9.590.588 622.287.844 BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 52 563.874.034 3.121.078 2.894.875 1.508.849 1.764.081 227.374.821 210.141.032 228.883.670 211.905.113 228.883.670 211.905.113 (€ thousand) Distribution of balance sheet and off-B/S exposures to banks by geo area Amounts as at: 06/30/2008 Italy Exposures/Geographical areas Gross exposure Other European countries Net exposure Gross exposure America Net exposure Gross exposure Asia Net exposure Gross exposure Rest of the world Net exposure Gross exposure Net exposure A. Balance sheet exposures a) Non-performing loans b) Doubtful loans 919 918 50.735 4.254 62.419 0 1.109 12 43 0 0 0 12.309 9.380 8.279 8.279 0 0 11.274 11.274 c) Restructured exposures 0 0 0 0 0 0 0 0 0 0 d) Past due exposures 0 0 0 0 0 0 0 0 0 0 e) Other exposures Total A 24.435.677 24.432.297 145.498.433 145.497.620 5.664.060 5.654.879 4.084.349 4.083.722 3.650.397 3.641.469 24.436.596 24.433.215 145.561.477 145.511.254 5.734.758 5.663.158 4.085.458 4.083.734 3.661.714 3.652.743 B. Off-Balance sheet exposures a) Non-performing loans 0 0 275 275 27.599 16.947 0 0 0 0 59.392 59.392 0 0 0 0 0 0 0 0 832 832 0 0 0 0 0 0 0 0 12.929.657 12.925.556 115.825.557 115.809.501 17.143.611 17.142.155 3.253.816 3.252.574 1.193.090 1.192.135 Total B 12.989.881 12.985.780 115.825.832 115.809.776 17.171.210 17.159.102 3.253.816 3.252.574 1.193.090 1.192.135 Total A+B 37.426.477 37.418.995 261.387.309 261.321.030 22.905.968 22.822.260 7.339.274 7.336.308 4.854.804 4.844.878 b) Doubtful loans c) Other impaired assets d) Other exposures (€ thousand) Distribution of balance sheet and off-B/S exposures to costumers by geo area Amounts as at: 06/30/2008 Exposures/Geographical areas Italy Other European countries Gross exposure Net exposure Gross exposure Net exposure America Gross exposure Asia Net exposure Gross exposure Rest of the world Net exposure Gross exposure Net exposure A. Balance sheet exposures a) Non-performing loans b) Doubtful loans c) Restructured exposures d) Past due exposures e) Other exposures Total A 15.227.050 5.693.885 11.487.344 3.620.090 251.157 125.902 220.976 68.823 12.280 4.059.010 2.663.816 2.185.145 1.345.245 32.623 22.908 162.559 125.585 1.033 5.640 778 635.393 586.462 798.824 432.660 6.210 3.743 65 65 5.851 5.851 1.698.662 1.493.109 608.672 520.563 3.978 3.850 24 16 52 41 293.469.670 292.177.648 381.185.184 379.859.453 20.731.630 20.675.814 10.553.353 10.495.840 4.854.725 4.844.301 315.089.785 302.614.920 396.265.169 385.778.011 21.025.598 20.832.217 10.936.977 10.690.329 4.873.941 4.856.611 B. Off-Balance sheet exposures a) Non-performing loans 366.447 334.786 464.445 303.815 182.758 154.521 5.742 2.210 0 0 b) Doubtful loans 125.021 118.993 61.420 40.851 75 60 93 76 0 0 c) Other impaired assets d) Other exposures Total B Total A+B 53 132.059 131.289 170.738 107.260 50 50 1 0 0 0 45.207.188 44.858.386 161.086.111 160.981.490 14.569.890 14.569.811 4.889.497 4.889.113 1.622.135 1.621.644 45.830.715 45.443.454 161.782.714 161.433.416 14.756.273 14.724.442 4.891.833 4.891.399 1.622.135 1.621.644 360.920.500 348.058.374 558.047.883 547.211.427 35.781.871 35.556.659 15.828.810 15.581.728 6.496.076 6.478.255 (€ thousand) Distribution of balance-sheet and off-B/S exposures to customers by business sector Amounts as at: 06/30/2008 Governments Other public entities Financial companies Exposures/Business sector Gross exposure Total writedowns Net exposure Gross exposure Total writedowns Net exposure Gross exposure Total writedowns Net exposure A. Balance sheet exposures a) Non-performing loans b) Doubtful loans c) Restructured exposures d) Past due exposures e) Other exposures Total A 7.357 1.461 5.896 41.081 24.791 16.290 467.603 344.135 0 0 0 132.986 41.967 91.019 37.546 12.293 123.468 25.253 0 0 0 0 0 0 26.386 216 26.170 8.281 0 8.281 6.207 490 5.717 14.728 1.472 13.256 54.093.058 48.839 54.044.219 19.061.082 14.314 19.046.768 64.275.235 132.435 64.142.800 54.108.696 50.300 54.058.396 19.241.356 81.562 19.159.794 64.821.498 490.551 64.330.947 188.590 B. Off-Balance sheet exposures a) Non-performing loans b) Doubtful loans c) Other impaired assets d) Other exposures Totale B TOTAL A+B 1.062 856 206 0 0 0 190.355 1.765 0 0 0 24.387 1.706 22.681 5.177 75 5.102 0 0 0 989 0 989 10.199 85 10.114 2.661.777 470 2.661.307 2.579.442 2.256 2.577.186 39.372.273 322.569 39.049.704 2.662.839 1.326 2.661.513 2.604.818 3.962 2.600.856 39.578.004 324.494 39.253.510 56.771.535 51.626 56.719.909 21.846.174 85.524 21.760.650 104.399.502 815.045 103.584.457 BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 54 (€ thousand) Distribution of balance-sheet and off-B/S exposures to customers by business sector (continued) Amounts as at: 06/30/2008 Insurance companies Non financial companies Other entities Exposures/Business sector Gross exposure Total writedowns Net exposure Gross exposure Total writedowns Net exposure Gross exposure Total writedowns Net exposure A. Balance sheet exposures a) Non-performing loans b) Doubtful loans c) Restructured exposures d) Past due exposures e) Other exposures Total A 57.350 31.174 26.176 17.998.569 12.052.882 5.945.687 8.626.847 5.230.024 3.396.823 2.795 792 2.003 3.797.318 1.449.673 2.347.645 2.469.725 777.314 1.692.411 26.511 136 26.375 1.271.179 399.188 871.991 122.267 18.022 104.245 143 46 97 1.462.097 136.994 1.325.103 819.932 154.807 665.125 5.175.248 5.047 5.170.201 371.245.464 1.611.537 369.633.927 196.944.475 929.336 196.015.139 5.262.047 37.195 5.224.852 395.774.627 15.650.274 380.124.353 208.983.246 7.109.503 201.873.743 634 67 567 650.688 192.324 458.364 176.653 29.048 147.605 0 0 0 151.400 24.325 127.075 5.645 523 5.122 B. Off-Balance sheet exposures a) Non-performing loans b) Doubtful loans c) Other impaired assets d) Other exposures 19 2 17 270.770 49.524 221.246 20.871 14.638 6.233 2.571.622 1.051 2.570.571 159.223.609 115.278 159.108.331 20.966.098 12.754 20.953.344 Totale B 2.572.275 1.120 2.571.155 160.296.467 381.451 159.915.016 21.169.267 56.963 21.112.304 TOTAL A+B 7.834.322 38.315 7.796.007 556.071.094 16.031.725 540.039.369 230.152.513 7.166.466 222.986.047 55 (€ thousand) Breakdown of loans to non-financial companies and family firms by type Amounts as at: 06/30/2008 Resident in Italy Non resident in Italy Total Agriculture - forestry - fisheries 3.898.349 1.751.015 5.649.364 Energy products 7.011.321 13.276.812 20.288.133 Ores, ferrous and non-ferrous metals (except fissile and fertile ones) 2.164.474 4.203.883 6.368.357 Minerals and non-metallic mineral products 3.616.862 2.896.798 6.513.660 Chemicals 2.159.551 7.239.853 9.399.404 Metal products except cars and means of transport 6.532.801 4.634.565 11.167.366 Farming and industrial machinery Office machines, data processing machines, precision, optical and similar instruments 5.634.453 4.324.358 9.958.811 1.367.383 2.474.733 3.842.116 Electric materials and supplies 3.464.109 1.456.794 4.920.903 Means of transport 2.555.142 5.783.384 8.338.526 Foodstuffs, beverages and tobacco-based products 5.072.451 6.483.453 11.555.904 Textiles, leather and footwear and clothing products 4.929.990 1.590.451 6.520.441 Paper, paper products, printing and publishing 2.762.865 4.894.767 7.657.632 Rubber and plastic products 2.280.518 1.926.707 4.207.225 Other industrial products 3.979.031 3.991.629 7.970.660 Construction and civil engineering 20.114.088 6.631.403 26.745.491 Commercial, recovery and repair services 27.890.470 28.854.431 56.744.901 Hotel and public commercial concern services 4.497.918 3.295.313 7.793.231 Inland transport services 4.003.335 3.582.911 7.586.246 Sea and air transport services 1.854.011 6.604.421 8.458.432 Transport-related services 2.471.072 3.349.520 5.820.592 Communications services 1.130.138 2.233.593 3.363.731 53.213.634 172.603.966 102.190.877 223.671.671 155.404.511 396.275.637 Other saleable services Total BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 56 (€ thousand) Time breakdown by contractual residual maturity of financial assets Amounts as at: 06/30/2008 Items/Maturities On demand 1 to 7 days 7 to 15 days 15 days to 1 month 1 to 3 months 3 to 6 months 6 months to 1 to 5 years over 5 years 1 year Balance-sheet assets a) Government securities 875.330 117.142 800.232 137.541 780.297 227.555 4.762.747 8.380.238 8.996.653 b) Listed debt securities 169.098 232.818 229.857 914.971 4.692.628 7.886.534 9.796.392 41.242.256 29.680.749 c) Other debt securities 1.602.314 5.822 9.303 235.732 487.781 1.883.570 264.475 763.020 4.843.444 52.083 0 0 0 0 0 0 0 8.918.559 - Banks 46.171.377 7.024.134 3.547.755 34.276.219 16.421.642 13.900.947 13.241.635 6.359.838 5.102.040 - Customers 77.886.320 6.662.681 3.190.915 25.746.758 37.746.448 30.145.412 31.473.713 129.410.377 218.389.573 - long positions 13.883.134 14.626.601 6.608.851 12.828.227 30.898.479 20.244.541 8.741.586 13.624.207 3.459.861 - short positions 15.302.509 10.757.143 8.284.692 13.793.162 28.648.879 20.592.343 8.126.036 10.401.085 1.455.310 3.077.234 4.074.268 0 0 46.165 95.590 2.180.349 16.000.000 14.537.379 3.399.064 1.718.781 263.527 264.358 325.831 1.304.310 2.482.996 16.002.120 14.250.000 d) Units in Invetsment Funds e) Loans Off-Balance sheet transactions a) Financial derivatives with exchange of principal b) Deposits and borrowings to be received - long positions - short positions c) Irrevocable commitments to disburse funds 57 - long positions 8.849.184 1.843.399 1.250.824 1.283.433 6.407.303 10.073.593 12.310.576 55.186.551 19.704.685 - short positions 24.337.096 2.138.533 1.229.168 158.718 6.203.142 7.339.498 11.108.232 37.635.212 13.245.109 (€ thousand) Balance-sheet exposures: change in overall impairments Amounts as at: 06/30/2008 Exposures to banks Exposures to customers Source/Categories Nonperforming loans A. Opening gross writedowns B. Increases B.1 Writedowns B.2 Transfers from other impaired exposures B.3 Other increases Doubtful loans Restructured exposures Past due exposures Country Risk Non-performing Restructured Doubtful loans loans exposures Total Past due exposures Country Risk Total 114.907 4.461 - - 17.077 136.445 17.936.825 1.833.574 479.846 187.653 12.209 6.608 197 0 0 2.288 9.093 6.450.414 1.193.958 58.128 245.634 682 20.450.107 7.948.816 25 0 0 0 1.736 1.761 1.924.545 629.530 30.069 165.128 648 2.749.920 0 0 0 0 0 0 374.438 74.978 10.528 5.340 0 465.284 6.583 197 0 0 552 7.332 4.151.431 489.450 17.531 75.166 34 4.733.612 11.474 1.729 0 0 2.015 15.218 6.702.772 745.493 120.412 139.478 793 7.708.948 C.1 Write-backs from evaluation 29 1.729 0 0 418 2.176 256.962 99.092 17.310 14.373 555 388.292 C.2 Write-backs from recoveries 4.966 0 0 0 244 5.210 779.173 110.627 6.276 17.638 99 913.813 0 0 0 0 0 0 944.376 73.623 11.253 653 0 1.029.905 0 0 0 15.859 326.773 65.970 56.679 0 465.281 C. Reductions C.3 Write-offs C.4 Transfers to other impaired exposures C.5 Other reductions D. Final gross writedowns 0 0 0 6.479 0 0 0 1.353 7.832 4.706.402 135.378 19.603 50.135 139 4.911.657 110.041 2.929 0 0 17.350 130.320 17.684.467 2.282.039 417.562 293.809 12.098 20.689.975 20.492.081 of which: - specific writedowns - portfolio adjustments E. Writedowns through Profit or Loss 110.041 0 0 0 0 110.041 17.673.974 2.192.393 417.493 208.221 0 0 2.929 0 0 17.350 20.279 10.493 89.646 69 85.588 12.098 1.761 BASEL 2 THIRD PILLAR AS AT 30 JUNE 2008 197.894 2.749.920 58 Table 6 – Credit risk: disclosures for portfolios treated under the standardized approach and specialized lending and equity exposures treated under IRB approaches Qualitative disclosure Credit risk – Standardized approach List of the ECAI (External Credit Assessment Institution) and ECA (Export Credit Agency) used in the standaridized approach and of the credit portfolios on which the ratings supplied by these entities are applied. Credit risk Porfolios ECA / ECAI Ratings (1) characteristics - Fitch Ratings; - Moody's Investor Services; - Standard and Poor's Rating Services Solicited e unsolicited Exposures with central governments and central banks Exposures with international organizations Exposures with multilateral development banks Exposures with corporate and other entities Exposures with Collective Investments Undertakings (CIU) - – solicited rating: shall mean a rating assigned for a fee following a request a request from from the entity evaluated. Ratings assigned without such a request shall be treated as equivalent to solicited ratings if the entity had previously obtained a solicited rating from the same ECAII. - unsolicited rating: shall mean a rating assigned without a request from the entity evaluated and without payment of a fee. 59 Securitizations Porfolios Position on securitizations with short term rating Position on securitizations different from those with short term rating ECA / ECAI - Fitch Ratings; - Moody's Investor Services; - Standard and Poor's Rating Services Quantitative disclosure (€ thousand) Specialized lendings Exposure amounts as at 06/30/2008 Remaining maturity/Assesment Regulatory categories 1 - strong 2 - good 552.632 3 - satisfactory 4 - weak 8.154 5 - default Remaining maturity less than 2,5 years Remaining maturity equal to or more than 2,5 years 199.288 492 637.015 2.183.376 179.125 46.588 12.644 Total Specialized Lendings 836.303 2.736.008 187.279 47.080 12.644 (€ thousand) Equity exposures - simple risk weight approach Weights Exposure amounts as at 06/30/2008 Private equity exposures in sufficiently diversified portfolios 190% 251.407 Exchange-traded equity exposures 290% 24.531 Other equity exposures 370% 2.162.946 Categories Total Equity Exposures 2.438.884 60 (€ thousand) Standardized approach - risk assets Amounts as at 06/30/2008 Secured exposures Exposures classes Exposures deducted from Supervisory Capital Exposure amount Guarantees and other similar contracts Collaterals Exposures with or secured by central governments and central banks 52.425 10.933.011 0 0 49.268 4.808.963 46.870 0 613.054 629.831 0 0 525 3.237 0 0 0 0 0 0 629.905 1.136.191 4.191.966 0 14.497.147 5.264.155 467.028 0 106.067.417 16.366.486 186.096 0 0 0 - credit quality step 1 52.843.303 - credit quality step 2 1.481.839 - credit quality step 3 4.083.664 - credit quality step 4 and 5 3.571.669 - credit quality step 6 0 Exposures with or secured by regional administrations and local authorities - credit quality step 1 32.085.982 - credit quality step 2 2.685.210 - credit quality step 3 - credit quality step 4 and 5 - credit quality step 6 Exposures with or secured by administrative bodies and non-commercial undertakings 0 764.183 0 - credit quality step 1 7.521.641 - credit quality step 2 1.858.077 - credit quality step 3 - credit quality step 4 and 5 - credit quality step 6 Exposures with or secured by multilateral development banks 0 5.250.028 672 - credit quality step 1 522.630 - credit quality step 2 0 - credit quality step 3 0 - credit quality step 4 and 5 - credit quality step 6 Exposures with or secured by international organizations Exposures with or secured by supervised institutions 0 0 96.861 - credit quality step 1 57.681.471 - credit quality step 2 6.458.567 - credit quality step 3 0 - credit quality step 4 and 5 3.593.618 - credit quality step 6 1.430.654 Exposures with or secured by corporates - credit quality step 1 - credit quality step 2 - credit quality step 3 and 4 - credit quality step 5 and 6 Retail exposures Exposures secured by real estate property Credit derivatives 10.077.093 8.687.592 277.241.116 830.338 62.464.469 4.011.951 486 0 Past due exposures 8.492.224 20.061 24.679 0 0 High risk exposures Exposures in the form of guaranteed bank bonds 1.709.463 0 0 0 0 2.784.569 0 285.000 0 0 0 52 0 0 0 133.000 0 0 0 Short-term exposures with corporates - credit quality step 1 - credit quality step 2 54.425 - credit quality step 3 288.558 - credit quality step form 4 to 6 Exposures in the form of Collective Investment Undertakings (CIUs) - credit quality step 1 - credit quality step 2 - credit quality step 3 and 4 - credit quality step 5 and 6 Other exposures Total on-balance-sheet risk assets Total guarantees given and committed lines Total derivatives contracts Total SFT transactions and long settlement transactions Total from contractual cross product netting Total 61 1.239.305 4.980 588.248 90.884 1.304.424 44.874 32.261.878 0 21.462 0 444.688.360 9.869.727 21.502.891 1.977.831 221.612.988 1.718.358 1.923.272 2.728.033 14.175.006 303.466 0 0 15.685.567 24.349.271 0 0 36.240.822 23.426.163 4.705.864 0 696.161.921 0 Table 7 – Credit risk: disclosures for portfolios treated under IRB approaches Qualitative disclosure Credit risk - Information on portfolios to which IRB approaches are applied In the first half of 2008 the “New Regulatory Provisions for Banks” (Banca d’Italia Circular No. 263) went into effect. These provisions cover regulations concerning the international convergence of measures of capital and capital ratios (Basel 2). In this context, UniCredit obtained authorization from Banca d’Italia to use advanced methods for determining capital requirements for credit risk. In this first phase, these methodologies have been adopted by the Parent Company, several Italian subsidiaries as well as HypoVereinsbank (HVB AG) and Bank Austria (BA AG), and they will be later used by other Group companies based on a gradual coverage plan communicated to the regulator. In general, the following table summarizes the rating systems requiring authorization that are used by the Group with an indication of the entities where they are used and the related asset class. Rating system Legal entity Asset portfolio Sovereign states UCI, HVB, BA Central governments and central banks Banks UCI, HVB, BA Regulated intermediaries Multinational companies UCCB, HVB Companies Global Project Finance (GPF) HVB Companies Integrated Corporate Rating (ICR) PD UCCB Companies ICR LGD UCCB Companies Mid Corporate (PD, LGD, EAD) HVB Companies Commercial Real Estate Finance (PD, LGD, EAD) HVB Companies/Retail exposure Asset Backed Commercial Paper (PD, LGD, EAD) HVB Companies Income Producing Real Estate (IPRE) Slotting HVB Companies Criteria 62 Acquisition and Leverage Finance (PD, LGD, EAD) HVB Companies Mid Corporate (PD, LGD, EAD) BA Companies IPRE (PD, LGD, EAD) BA Companies Non Profit (PD, LGD, EAD) BA Companies Integrated Small Business Rating (ISBR) UCB Retail exposure ISBR LGD UCB Retail exposure Integrated Individual Rating (IIR) Mortgages PD UCB Retail exposure Integrated Individual Rating (IIR) Mortgages LGD UCB Retail exposure Integrated Individual Rating (IIR) Mortgages PD UBCasa Retail exposure Integrated Individual Rating (IIR) Mortgages LGD UBCasa Retail exposure Small Business (PD, LGD, EAD) HVB Retail exposure Private Individuals (PD, LGD, EAD) HVB Retail exposure Small Business (PD, LGD, EAD) BA Retail exposure Private Individuals (PD, LGD, EAD) BA Retail exposure In 2008 the Group was authorized to use the internal estimates of parameters PD and LGD especially for Group loan portfolios, Sovereign Entities, Banks, Multinationals and Global Project Finance, and for local loan portfolios of the Group’s Italian banks (mid-corporate and retail excluding those banks that are a part of the former Capitalia, for which the standardized approach is initially used). For the current year, the regulatory EAD parameter will be used for the above portfolios since in 2009 a request for authorization to use the internal estimates of that parameter is to be sent to Banca d’Italia. The above rating models are used for the purposes of calculating the regulatory requirement resulting from “first pillar” obligations, but more importantly, they represent a fundamental component of decision-making and governance processes. Specifically, the areas where internal rating systems are most often used are as follows: Various phases of credit processes: - Approval/renewal. The assignment of internal ratings is a key moment in the credit assessment of the counterparty/transaction and is a preliminary phase in providing/renewing lines of credit. The rating, which is assigned before approval, is made available as a part of the approval process, which is largely integrated in the assessment and discussed in the credit proposal. Thus, along with loan exposure, the rating is a key factor for defining the appropriate body for the approval. 63 - Monitoring. The loan monitoring process is aimed at identifying and quickly reacting to the initial symptoms of a potential deterioration in a customer’s credit quality, and thus, it makes it possible to intervene before an actual default occurs (i.e., when it is still possible to recover credit exposure). This activity mainly focuses on monitoring exposure movements leading to the point of completely disengaging from the customer as necessary. In addition to determining the positive impact in terms of EAD, the monitoring process makes it possible to optimize conditions for the potential subsequent recovery phase through requests for additional security resulting in the reduction of LGD. Loan recovery. The process of assessing the strategy to be used for loans classified as default positions, which is carried out at the customer/transaction level and aimed at the simulated calculation of the Net Present Value of the net amounts recovered and LGD, is based on the definition of LGD. If there are several alternative recovery strategies, the one with the lowest LGD is chosen. LGD is also the basis for pricing to be assigned to non-performing loans transferred to Aspra Finance. Provision policies. For performing loan customers, the “incurred but not reported loss” (IBNR) methodology has been adopted. This approach uses the amounts of the projected loss by means of the Loss Confirmation Period (LCP) parameter for the calculation of provisions. For counterparties in the default category, loss provisions are based on the assessment of the exposure risk profile and LGD. Capital management and allocation. Ratings are also an essential element in the process of quantifying, managing and allocating capital. Specifically, the output of rating systems is integrated, at the level of the Parent Company of the overall Group, in processes aimed at measuring and managing (regulatory and economic) capital, on the one hand, and in processes aimed at determining “risk adjusted performance" measures and the adjusted income statement for the purposes of strategic planning. Strategic planning. Customer risk is a key determinant in the area of strategic planning, budgeting and provisions for quantifying RWA, impairment losses reported in the income statement, and loans reported in the balance sheet. Reporting. Specific reports are produced for top management at the consolidated, divisional and regional levels and for individual entities. These reports show credit risk portfolio performance and provide information on default exposure, projected losses, PD and average LGDs for various customer segments in accordance with the internal rating systems implemented. Ratings are also used to determine pricing and MBOs to be assigned to account managers and to identify customers with negative EVA for which targeted strategies are adopted. To achieve compliance with the so-called Basel 2 regulations, the UniCredit Group has carried out specific actions aimed at determining and meeting all the requirements needed to apply Credit Risk Mitigation (CRM) procedures. These actions include the following: Issuance of policies reflecting the implementation, interpretation and internalization of CRM regulatory requirements within the Group. There were several reasons for producing this documentation, for which reference was made to Banca d’Italia Circular No. 263 of 27 December 2006 and subsequent updates, EU directives 2006/48/EC and 2006/49/EC and to the document “International Convergence of the Measurement of Capital and Capital Ratios, New Regulatory Framework” of the Basel Committee on Banking Supervision. Its aim was to encourage the optimization of collateral management and to establish rules for the acceptability, assessment, monitoring and management of guarantees and collateral in keeping with general and specific requirements. Definition of new processes reflecting the application of policies in the management of collateral within the Group. Based on a gap analysis between the “current status” and target model, the Group implemented new 64 processes for managing collateral in keeping with the requirements of Banca d’Italia regulations and the Group’s guidelines. Since the UniCredit Group emphasizes the importance of the requirement of legal certainty in the assessment of CRM procedures, there was a special focus on implementing processes needed to meet this requirement. Implementation of IT tools that make it possible to automate the process of managing collateral. In particular, the UniCredit Group developed a reliable and effective system for applying CRM procedures starting with the assessment and acquisition of collateral to the monitoring and enforcement of collateral. The implementation of the IT system made it possible to manage, gather and archive the data needed to verify whether acceptability requirements have been met and to calculate risk indicators. These data are used to determine whether collateral is valid for the purposes of CRM and to apply appropriate prudential margins as required by the Basel 2 regulations (margins estimated internally that are based on the Value at Risk methodology have been determined for the assessment of volatility)1. In addition, based on the new regulatory structure, the development of advanced rating systems and their introduction in corporate processes have resulted in the need to establish at both the Parent Company and individual entities a process for validating rating systems and an increase in the activities that Internal Audit is required to audit with respect to such systems. The purpose of the validation process is to express an opinion concerning the proper operation, predictive ability and overall performance of the IRB systems adopted and their consistency with regulatory requirements specifically through: the assessment of the model development process with a particular emphasis on the underlying approach and the methodological criteria supporting the estimate of risk parameters; the assessment of the accuracy of estimates of all major risk components through system performance analysis, parameter calibration and benchmarking; verification that the rating system is actually used in various management areas; the analysis of operating processes, monitoring safeguards, documentation and IT facilities related to the rating systems. The validation process established within the Group first calls for a distinction to be made between the initial and ongoing validation. The purpose of the initial validation is to assess the positioning of the Group’s rating systems in relation to minimum regulatory requirements and the Parent Company’s guidelines and standards concerning methodology, processes, data quality, quantitative and qualitative validation procedures, internal governance and technological environment by identifying any gaps or critical areas in relation to these requirements. On the other hand, the purpose of ongoing validation is to continually assess the proper operation of all components of the rating system and to monitor its compliance with internal and regulatory requirements. Secondly, the process calls for the specific assignment of responsibilities for validating so-called Group-wide systems and local systems. For Group-wide systems, the methodology for which applies only at the Group level, responsibility is assigned to the Parent Company, while individual entities are responsible for local rating systems. The Parent Company is still responsible 1 See Table 8, “Procedures for Mitigating Credit Risk – Qualitative Information” for additional details on the management of the process for determining procedures for mitigating credit risk. 65 for the initial and ongoing monitoring of the proper performance of development and validation activities carried out locally and the proper operation of the rating system by also providing suggestions generated by internal and external benchmarking that are aimed at following best practices. Based on the revalidation process, the Parent Company issues a non-binding opinion on local rating systems during the initial phase before approval is given by the appropriate bodies, and later whenever significant changes are made. The unit responsible for validation procedures is independent from the units responsible for developing models and from the internal audit area that audits the process and outcome of the validation. This unit has established guidelines for validating rating systems aimed at a convergence towards standard validation procedures in terms of both content and tools, thereby ensuring that the criteria for assessing results are shared including through the introduction of standard trigger values and encouraging a comparison between the different systems. The use of triggers makes it possible to depict test results using a stop-light system whose colors are associated with various levels of severity of the phenomena reported. Special emphasis was placed on establishing a standard approach for validating models by identifying minimum test requirements and methods for reporting the related results. Tests are divided into qualitative and quantitative analyses. The qualitative section is used to assess the effectiveness of the methodology used to create the model, the inclusion of all significant factors and the ability to depict the data used during the development phase; The quantitative section assesses the performance, stability and calibration of the overall model as well as its specific components and individual factors. A hierarchy of the above analyses has been established that provides details as a function of the specific (initial or ongoing) validation or ongoing monitoring phase and the results obtained. In fact, the performance of certain tests is dependent on whether critical areas are identified in the performance of analyses at the next-highest level. The data and documents related to the validation procedures done to date are saved in special storage areas ensuring rapid access to, and security of, the information and the ability to reproduce all analyses performed. In addition, the Group has a validation tool that makes it possible to calculate the indicators required by the Basel Committee in Working Paper 14, “Studies on the Validation of Internal Rating Systems,” for validating credit risk models. This tool complies with the IT requirements of Banca d’Italia and is fully integrated with the workplace environment. The results of internal validation activities are related to a single reporting model (framework) in order to assign the analysis of the various components of the rating system to business units. These activities are performed in accordance with validation standards, and the depth of their analyses is a function of the type (group-wide or local) or location (Italy or abroad) of the rating system. The framework adopted consists of the schematic reclassification of all detailed minimum quantitative and organizational requirements imposed by Banca d’Italia into specific key principles related to different subject areas for analyzing the rating system (model design, risk components, internal use and reporting, IT, data quality and corporate governance). The framework is useful for assessing the detailed status of rating systems vis-a-vis regulatory provisions. The analysis areas attributable to the organizational requirements specified in the Circular are model design, internal use and reporting, IT/data quality and governance. When auditing internal rating systems, Internal Audit’s aim is to check the functionality of the entire system of controls over them. These checks comprise the following: Check that the IRB systems comply with regulations Ascertain how the rating systems are used for business purposes and 66 Check that the rating validation process is adequate and complete. In order to assist Group entities to ensure the quality (functionality and adequacy) of their Internal Control Systems and to modify their internal auditing methods in line with changes in their business scenarios, the Parent’s Internal Audit Department (UC IAD) has coordinated the development of a common set of internal auditing methods. These methods have been developed in order to assess the accuracy of the conclusions of the risk control functions as well as compliance with the regulatory requirements, particularly in respect of the internal validation process of internal rating and risk control systems. It should be noted that internal audit functions are not directly involved in the design or selection of the model. In accordance with its mission UC IAD directly audits UniCredit SpA and coordinates the activity of Group entities’ internal audit functions. The audits necessary to assess the functionality of the rating systems are given suitable space in the Group audit planning process, organised by UC IAD, which agrees their inclusion in internal audit plans with the Group entities. UC IAD then monitors performance of these audits by a specific function and if necessary contacts the entity where there are deviations from plan. UC IAD also regularly reports on its activity and results to the Parent’s Internal Control & Risks Committee and Statutory Auditors. Furthermore, the audits needed to assess the functionality of rating systems are given appropriate emphasis in the group’s audit plan. These activities are promoted by the Parent Company’s Internal Audit department which, al3ong with the entities assigned, includes them in the control plan. These audits are monitored by the Audit Monitoring area which oversees the performance of planned activities, and intervenes locally if there are any deviations. Description of Rating Systems Group-wide models Rating model for countries The approach used for the development of the country rating model is shadow rating whereby an attempt is made to duplicate the ranking capabilities of external (ECAI) ratings using macroeconomic and qualitative factors. The following steps were taken to arrive at the final model: Sample Selection: Determination of countries to be included in the sample; Univariate Analysis: Calculation of explanatory potential of each qualitative and quantitative factor; Multivariate Analysis: Determination of optimal subset of factors using stepwise techniques supported by the experience of analysts; Combination of quantitative and qualitative modules; Calibration: The score of the final model is calculated on the basis of parameters in order to reproduce the actual PDs; Model Testing: Mapping of model results with approved PDs. Two separate models were designed for emerging and developed countries. 67 The quantitative module for the latter uses variables related to the balance of trade, interest rates, the importance of the banking system, per-capita GDP and the level of government debt. The qualitative module includes variables related to the development of the financial system, socio-political conditions and economic conditions. The quantitative module for emerging countries uses the following variables: exports as a percentage of gross domestic product (GDP); external debt; the amount of foreign currency reserves; the level of direct, foreign investments as a percentage of GDP; debt service compared to exports; the inflation rate and per-capita GDP. The qualitative module includes variables concerning the stability of the financial system, the flexibility of the economic system, socio-political conditions, economic conditions and debt service. The validation unit checked the design of the model, the implicit default definition, the qualitative and quantitative characteristics of the model, override methods, calibration, segmentation into the two groups (developed and emerging countries) and the development sample and conducted the usual performance and stability tests. Naturally, because of the type of counterparties involved and low number of defaults among sovereign entities, development and validation samples are limited in size. LGD model for countries This model, which was developed in November 2006, uses a regressive approach with the involvement of experts, starting with a large set of macroeconomic variables, of which six were included in the final version. The dependent variable (LGD) was calculated using internal and external data. The model, which was designed with the aim of calculating LGD for direct exposure to sovereign counterparties, provides LGD only for unsecured exposure. The explanatory variables selected are as follows: GDP as a percentage of total world GDP; external debt as a percentage of exports; indicator of debt position with respect to IMF; export volatility; average inflation rate in G7; and default timing (period preceding the default). In addition to performing the usual performance and stability tests, the validation unit checked the consistency of definitions of default, segmentation and override; the use of internal and external sources for recoveries; cost estimates and the methodology for discounting recoveries; and the need to introduce conservative adjustments for negative phases in the economic cycle. Rating model for banks The approach used for developing bank ratings, which are defined as shadow ratings, attempts to duplicate the ranking capability of external ratings using a combination of quantitative and qualitative factors. It was decided to construct two different models – one for banks resident in developed countries and one for banks in emerging markets – since it is believed that there are different risk drivers for the two segments. Specific adjustments to be made to the PD resulting from the EM and DC model were introduced to take the following aspects into account: Environmental factor: The rating is improved for banks with high environmental standards; Government support and industry guarantee funds: Various corrections were introduced to take into account the support provided to banks by governments and by special industry-based guarantee funds; Transfer risk: The model takes into account the risk that the debtor is unable to obtain foreign currency to meet its obligations, even though it has the corresponding local currency. 68 The final quantitative model for banks resident in developed countries covers several categories of factors: profitability, risk profile, size and funding. The situation is similar for banks in emerging countries with different weightings for factor categories: profitability, risk profile, size, capitalization and funding. The validation unit has checked the design of the model, the implicit default definition, the selection of factors and transformations of variables, the multivariate analysis of the quantitative and qualitative model, the combination of the two modules, calibration, and adjustments for the environment and transfer risk, and it conducted performance and stability tests. The LGD model for banks The model developed is based on experience. The methodology is currently only applied to senior, unsecured performing loan exposure, which represents the majority of exposure to banks. The application of advanced methodologies to situations of default exposure or unsecured junior exposure is planned for 2009. The individual LGD value was calculated starting with an analysis of financial statements by simulating the break-up and sale of the bank’s assets after repaying any creditors with a higher level of seniority. In order to obtain a realistic and conservative valuation of the bank’s assets, “haircuts” were established for each type of asset to take into account the likely deterioration that occurs before default, the differences between market and book value and between market value and sales proceeds. In addition, based on the fact that the success of the recovery phase largely depends on the applicable legal/institutional environment, specific haircuts were introduced for each country to take legal risk into account. Finally, haircuts were introduced to reflect the costs of the recovery process based on the assessment of workout experts. Since the assets of the borrowing bank are stated in local currency, but the final recovery must be estimated in the currency of the creditor, a haircut is applied to assets in local currency that is tied to exchange rate volatility in order to take depreciation risk into account. The validation unit checked the design and scope for applying the model, the model’s components, experience-based amendments and overrides. It conducted performance analyses, checked the methodology used for discounting recoveries, grouping by countries, and the estimate of haircuts due to legal and institutional risks, and it analyzed distressed debt transactions as an external benchmark. Rating model for multinational companies This rating model applies to multinational companies defined as companies with consolidated turnover or operating revenues greater than €500 million for at least 2 consecutive years. Following the shadow rating methodology, the model is made up of a quantitative and qualitative component. The quantitative section is developed around a multivariate analysis of elements such as financial ratios for capital, profitability, interest coverage and size. This module produces a probability of default. The qualitative module consists of a set of questionnaires that analyze corporate aspects such as management quality, organizational structure, market share, etc. 69 The qualitative module produces a value, expressed in terms of notches, that is used to modify the quantitative rating; the maximum variation with respect to the qualitative rating was set by experts. The result of the two modules is then upgraded or downgraded to reflect the company’s inclusion in a group. The multivariate selection led to the inclusion of the following variables that have been appropriately altered: ordinary cash flows over value of production, earnings before taxes over value of production, EBITDA over interest expense, adjusted net worth over capital employed and value of production. A regression is done of these variables on the logarithm of the relative frequency of default furnished by Standard & Poors. The validation unit checked the design and segmentation of the model, the quantitative and qualitative modules and their composition and calibration, override mechanisms and the role of warning signals. It analyzed combined performance and performance by geographic area, the definition of economic group used for rating purposes, and the quality of internal and external data used for the shadow rating. LGD model for multinational companies Rating agencies recently evaluated recovery levels for speculative grade companies. Since they did not have historical series of internal recovery rates for multinational companies (since this is a portfolio with a low risk of default), they started with these evaluations and developed a model based on the shadow rating approach supplemented by experts’ opinions. The construction of the model consists of several phases: 1. Use of industry averages in which differences can be interpreted by experts (heuristically these represent the intersections in a regression model); 2. Determination of a list of factors provided by experts; 3. Elimination of outliers; 4. Projection of factors at the default level, defining the time from default as Log(100%) – Log(PD). This makes it possible to compare companies with different ratings; 5. Selection of factors at the univariate level based on discriminating power; 6. Multivariate regression; verification of impact; 7. Calibration and downturn adjustment; 8. Haircuts for legal risk and recovery costs based on the counterparty’s country of residence. The model designed in this manner represents LGD derived from a database for bond debt, and as such it has a negative impact since it does not take into account the probability and effects of debt restructuring that are typical of bank loans and similar products that make up the most representative portion of the UniCredit Group’s portfolio. Thus, a cure rate was used that was defined by experts on the basis of results obtained with local models using corporations (Italy, Austria and Germany). This parameter makes it possible to go from a so-called LGD bond to an LGD loan. The validation unit checked the design of the model and the quality and representative nature of the sample, which is based on internal and external data, and used for the development, performance and conservative nature of estimates. It also conducted a benchmarking analysis of recoveries using external data and data from rating agencies regarding the growing literature on this subject, which is more abundant in the area of bond assets. 70 The rating model for project finance The GPF rating model is an expert model. It is based on a set of 29 factors that drive a questionnaire in which there are 5 possible levels of answers. The 29 factors can be grouped in five key areas that cover project risks. The final score is a weighted average of scores obtained from the factors. The 5 combined areas are as follows: project sponsor risk, execution or completion risk, operating risk, exogenous risks (e.g., macroeconomic risks) and cash-flow-related risk. The development of the rating system was supported by experts in the origination area. The specific nature of project finance and partial independence from counterparties that support the project can only be addressed with a high degree of flexibility, which is made possible by the use of risk mitigation phenomena or by a change of weightings of individual factors, or from the standpoint of weak links. Portfolio segmentation is based on the following criteria: The project is developed by a legal entity separate from the sponsor; There is a separation (lack of recourse) between the special-purpose vehicle and sponsor. At times, for short periods, this separation may disappear. Credit decisions are mainly based on future cash flows produced by the project; The financial structure is based on the quality and quantity of project cash flows; Risks are shared by those participating in financing; Project assets and revenues are used to secure creditors; Only specialized departments at UCI HVB and BA-CA are involved; Project volume is over €20 million; Projects for which economic risk is limited to 15% (maximum of €30 million) through export insurance guarantees are specifically excluded from the portfolio. The model was calibrated by determining which score levels are assigned to rating levels. Thus, the associated PD values are not continuous but absolute; a single PD value is assigned to each rating. The validation unit has checked the design of the model as well as performance on a combined, group risk, and single factor basis. It also analyzed stability, adjustment mechanisms and overrides, and whether estimates are conservative, and it performed a benchmarking analysis, although the availability of external ratings is limited. The LGD model for Project Finance operations (GPF) To summarize, the GPF LGD model is based on estimates differentiated by the industry sector underlying the project. The final result, LGD as a percentage of EAD, is provided by the ones’ complement of the discounted recovery rate to which recovery costs are added as well as an adjustment for the timing of recoveries. For sectors in which sufficient internal information was available, external data were ignored, and for those in which there was insufficient internal data, analyses of recovery rates done by Standard & Poors were used in the area project finance, at times directly, and at times in combination with internal data if allowed by the large size of the subset. Using Standard & Poors data for December 2005, a downturn scenario was determined, taking the crisis period following the Enron situation between 2001 and 2002 as a reference, from which a specific downturn factor was obtained. The validation unit has checked the design of the model, and the performance and representation of the sample (used for the development of the model, which was built using internal and external data) in terms of geographic areas and sectors. 71 Local models, Italy Integrated Corporate Rating (ICR) The ICR provides a rating for exposure to the category of companies at UniCredit Corporate Banking in the mid-corporate segment, i.e., for borrowers with revenues (or total assets if revenue information is not available) up to €250 million. In its current version, the ICR, which was developed in several phases with the support of the company Centrale Bilanci, integrates various components at several levels. At the first level, the score generated by financial statement variables (the CE.BI score) is integrated with qualitative information from questionnaires completed by the account manager. At the second level, the previous rating is supplemented with geographic, industry and size information. Finally, at the third level, performance information is combined to arrive at an integrated corporate rating. The first phase of the project, which was launched operationally in May 2003, ended with the integration of geographic and industry risk factors in the first-level company rating (financial statements + qualitative assessment) already used by the bank. These variables make it possible to complete the company risk profile with risk elements that are “ordinarily” attributable to a company’s industry, geographic location and size with the industry risk level assessed on a projected basis. In order to incorporate performance monitoring information in the rating, a model was structured using second-level company scores and the performance score for 13 months prior to the default as explanatory variables. The Kernel analysis of the distribution of the ICR score over the UniCredit Corporate Banking portfolio led to the identification of 9 rating categories. The validation unit checked the design of the model and the reliability (performance and stability, including in significant sub-portfolios) of its various modules (financial statement score, qualitative score, geographic and industry component and performance score), and reviewed the model’s override rules. It also analyzed coverage by relationships and exposure and calibration by counterparty monitoring status, including at the segment level. Rating model for the Italian Small Business segment The Integrated Small Business Rating (ISBR) model provided UniCredit Banca (UCB) with a system to evaluate small business counterparties that integrates information from the loan approval phase for new or renewed credit facilities (CRSB) with information from the performance process (SMR). The variables analyzed to establish loan approval grids can be broken down into the following categories: Customer data concerning the applicant and its affiliates; Operating and financial information from the financial statements or from simplified accounting documents; Information from the Experian credit bureau on the applicant and its affiliates; CR information. The assessment method is broken down into the following phases: Accepted/Rejected Model (multivariate analysis): An initial statistical model based on the comparison of all credit files accepted (good, unspecified, bad) and the credit files rejected makes it possible to assign the probability of rejection to each counterparty in the sample. Initial Good/Bad Model (multivariate analysis): This model, which was developed only in relation to the accepted sample, was later applied to the entire portfolio, thus also including rejected counterparties. 72 Reject Inference: The analysis of output from the two models developed (Accepted/Rejected and Good/Bad) makes it possible to also assign a theoretical performance level to Rejects using the Reject Inference technique. Final Good/Bad Model (multivariate analysis): After assigning a performance level to each counterparty in the sample using the Reject Inference method, a scoring algorithm is applied. Finally, the integration of loan approval and performance components was estimated using a logistic regression. In addition to the quantitative and performance modules, there is a qualitative module, which is based on questionnaires that are a part of the process to assess the company, and that are segmented by area of economic activity. The approach of assigning weightings is based on a hierarchy in order to make the process of optimizing weightings more orderly and rational and to ensure greater clarity in the process of interpreting results. Weighting assignment levels start with the procedures for answering questions. Weightings for individual questions are then determined within the section, and in the end, the section’s weighting is assigned to the overall assessment. Integration with the quantitative module is linear in nature with a weighting determined by experts. The validation unit checked the design of the model and its modules: the loan approval, performance and qualitative modules. It also tested their reliability in terms of performance and stability, including in significant sub-portfolios, with a particular focus on the impact of introducing the Basel 2 default definition. Finally, it analyzed portfolio coverage and the model’s calibration overall. Rating model for the Italian Individual segment: Mortgages The target portfolio of the Integrated Individual Rating (IIR) model, which is based on a pool approach, consists of the set of all categories of mortgages handled at UniCredit Banca and UniCredit Banca per la Casa which are used for the purchase, construction and remodeling of residential properties by individual customers and for the purchase of properties for the purposes of business carried out by individuals included in the family firm sector. As regards the Group’s installment products, the incorporation of specific characteristics of an individual product for the purposes of determining its pool resulted in assigning a potentially different probability of default to each relationship of the same counterparty, although the customer’s characteristics are among the fundamental drivers used to identify pools. Like all other rating systems for the Group’s portfolio of individuals, the development of the IIR model was also broken down into two separate phases. The first phase consists of identifying pools related to the portfolio in the loan approval phase, and the second consists of identifying pools related to the existing portfolio. Using statistical techniques, pools covering the entire portfolio were identified. Following this process, tree structures were created in which the “leaves” correspond to the pools identified. The PD associated with each pool is then estimated using the default rate observed for the exposure attributed to it. The individual pools were then combined into rating categories using cluster analysis. In the process of assigning the probability of default, the assessment made during the initial approval process is maintained during the first six months of the relationship unless an excess of over a month is discovered, and starting in the seventh month, the transaction’s allocation to the corresponding pool is recalculated using the tree established for the existing portfolio. Performance variables gain greater significance with the age of the mortgage. Since the rating model is consistent with the development approach and overall style of UniCredit Banca, it offers certain customization features for specific characteristics related to the different origins of exposure making up the risk portfolio of UB Casa, especially with regard to the portfolio acquired through the Abbey National channel. 73 In the analysis of the overall portfolio of Banca per la Casa, three segmentation trees were determined, the initial discriminating variable of which is the maturity of the mortgage (the number of months from disbursement greater of less than 6) and the place of origin for mortgages with a longer maturity. Specifically these include: a tree created for the portfolio in the loan approval or application phase, used for assigning the probability of default to all mortgages that are less than 6 months old; a tree for the “existing” former ANBI portfolio to be used for mortgages from the former ANBI that are more than 6 months old; a tree for the “existing” former Adalya-Kiron portfolio created in order to estimate PD for former Adalya mortgages that are more than 6 months old. A feature common to the three segmentations is the assignment of greater risk to the pool of those credit files that have payment delays or delinquencies of over one month. The validation unit checked the design of the model and the underlying loan approval process score, their discriminating capacity and the stability of the sample over time. In addition, special emphasis was placed on analyzing sub-models identified based on the mortgage’s age and its channel of origin. Finally, coverage, in terms of relationships and exposure, and calibration were analyzed on a combined and sub-portfolio basis. LGD for local Italian portfolios LGD models are specific to UniCredit Corporate Banking, UniCredit Banca and UniCredit Banca per la Casa depending on the area of application (product and segment), although the estimating methodology is the same (i.e., regressive). The Group selected the workout method for measuring LGD. In this method, the loss rate is calculated on the actual recovery observed using historical data, starting with cash flows generated on the specific loan from the time it goes into default until the end of the recovery process. With regard to the estimate, separate regressive models were used for the watchlist and non-performing phases, while for the past-due phase, an average change in exposure was calculated by counterparty segment and by major product category (installment, non-installment loans). The block approach makes it necessary to determine a method for integrating the results of the various models for the calculation of the overall LGD. In particular, it is necessary to determine two types of parameters. The first are tied to the composition of loans when they initially enter into default (assuming a default, the probability that it will occur in the form of a past-due, watchlist or non-performing loan). The second are tied to the probability of a transition between the various stages of default (using UniCredit's terminology, the latter are defined as "danger rates"). In addition to several variables concerning the counterparties’ customer data and the type and characteristics of relationships, the collateral used to cover exposure is particularly important. UniCredit Corporate Banking, UniCredit Banca and Banca per la Casa have decided to incorporate the impact of the various types of collateral in LGD, even if regulations call for an alternative, as in the case of guarantees, for which it is possible to replace the customer’s PD and LGD with the corresponding parameters of the guarantor when assessing the risk associated with the portion of exposure secured. Thus, the possibility of treating the secured and unsecured portions of exposure separately is not taken into account. Instead, the Loss Given Default is calculated at the relationship level as a function of the existing collateral and its value, if significant. With particular reference to the segment consisting of individuals, it was decided to jointly (UniCredit Banca and Banca per la Casa) develop the model for mortgages. As regards Corporate and Small Business, the group opted to use a jointly developed model for certain types of relationships. Limited to the non-performing loan phase, the highest level of detail possible, i.e., the relationship, was taken into account for the calculation of the value of LGD. With regard to the watchlist phase, the bank instead developed two models for each segment with a differentiation based on installment and noninstallment exposure. This decision was driven by the database used for the calculation of observed LGD (i.e., SISBA) in 74 which unpaid debt resulting from advances becomes, for all intents and purposes, cash exposure, which is therefore indistinguishable from current account exposure. Thus, the relationship is the unit of measure for creating models for the watchlist phase only with respect to the model for installment exposure, while the unit of measure for all non-installment relationships with the same customer is exposure by counterparty. The validation unit reviewed the structure of the model, its consistency with the definition of PD, the effect of the economic cycle, the methodology used for discounting recoveries, the cost allocation and the treatment of assets in default. It checked the construction of development samples, migrations from one status to another, and the treatment of specific assets such as derivatives and bank guarantees. Finally, it conducted tests aimed at checking the models’ accuracy and calibration. Local models, Germany “Mid-corporate” rating model The “Mittelstandsrating” model aims to provide ratings for exposure to the HVB category of companies headquartered in Germany with revenues of €3-500 million. The model is made up of two components: a quantitative and qualitative module. The score resulting from the analysis of financial statements (adjusted as necessary as a function of their quality) results in the partial rating for operating conditions. The qualitative model instead provides the partial rating for the company’s situation. The final rating is created from a combination of the two partial ratings. The quantitative module is made up of 12+1 statistical sub-modules called “Maschinelle Analyse von Jahresabschlüssen” (automated financial statement analyses) or MAJA. The area of application of each of these sub-modules is dependent upon the company’s industry and size. In general, the risk factors included in the quantitative module (which were selected using a process including statistical analyses and discussions with experts) cover the following areas of analysis: Asset structure; Financial situation; Growth in production/Margins. The qualitative module instead covers areas of analysis concerning: the financial situation (not directly covered by the quantitative module) in the context of assessing the ability to repay debt and the future ability to incur debt; 75 sector, market and product; management/business structure; risk factors and performance. Finally, the final rating can be adjusted manually (overridden) if the additional information indicate that the calculated rating is not appropriate. This practice is subject to specific restrictions and constraints and is closely monitored by the internal validation unit. The internal validation unit checked the design of the model, the reliability (performance and stability) of its various modules (the quantitative module with its related sub-modules, and the qualitative module) and its calibration. It also analyzed the process of assigning ratings, rules for attributing exposure to the model concerned and the override process. “Small business” rating model The “HVB smallcorp” rating model covers small and medium-sized German companies (up to €3 million in net income based on simplified accounting) and individuals with residence in Germany whose income is mainly from freelance activities, independent work or income from a small or medium-sized business in which they are major shareholders or owners. The application of the model depends on how many affiliated entities are involved in the credit facility: If there are no affiliated entities, the “Scoring GK (small business)” module is used; if there are affiliated entities, the “Rating GK (small business)” module is used. The “Scoring GK” module calculates a single score that is then mapped to a PD. The score is obtained using two different scorecards depending on whether the counterparty is fully responsible for the company’s liabilities or professional activities. 76 In both cases, the same information is used: The so-called “MAJA Values,” which are true financial statement scores developed statistically in a manner similar to what was used for mid-sized corporations; Internal industry scores; Performance scores. In the case of an individual, debt levels are used as an additional risk factor. The “Rating GK” module consists of two separate modules, one for the company and one for the related individual(s) (owners/major shareholders). The score used for each related individual follows the rules of the model used for individuals combining elements that are typical of the loan approval phase and performance aspects. The ratings of each related individual are then combined in an overall rating of the “individual” portion on the basis of their equity investments in the company(ies). The score of the small and medium-sized companies is calculated in subsequent steps: 1. First, a quantitative rating is calculated for each company combining: - “MAJA Values”; - Internal industry scores; - Length of bank relationship. The above does not apply to the "construction" sector where MAJA values are only combined with the "MORIX" rating for the real estate market and the property being financed. 2. The financial rating is combined with the performance rating of each of the small and medium-sized businesses creating an overall company rating. 3. A down-notching is required if the financial information is more than 18 months old. 4. The overall rating of the “individual” portion is combined with the rating of the “company” portion with different weightings depending on whether the loan is provided to the company or to one of the related individuals. 5. Finally, the rating may be adjusted upon the occurrence of one of the so-called “termination events” (a set of predetermined events that require the immediate downgrading of the counterparty) on the basis of an expert assessment. In the latter case, a downgrade correction may be made, but an upgrade is subject to specific approval and is closely monitored by the internal validation unit. The internal validation unit checked the design of the model, including through user audits. It also analyzed the performance and calibration of the overall model and the various modules (quantitative module with the related submodules, and qualitative module) and the stability of the underlying sample. Finally, it reviewed the process for assigning the rating and the override process. “Individual” rating model The “HVB private individuals” rating model covers all individuals excluding independent contractors and independent workers. Individuals with high property lease income are also excluded. They are considered a part of the Commercial Real Estate portfolio and assessed using the appropriate rating system. 77 The rating model for individuals is made up of 12 scorecards: 8 loan-approval-phase scorecards (one for each product type) and 4 performance scorecards. Both scores are combined, or one of the two scores is used depending on the transaction’s phase in the life cycle. A so-called “supplemental approach” makes it possible to combine all assessments available on each customer (in the event the customer has more than one relationship with the bank) to obtain an overall probability of default for the individual customer. First, this approach calls for determining a “relationship PD” for each transaction. All relationship PDs for the same product category are then combined (using a weighted average for exposure) into a “product PD.” Finally, all product PDs contribute to the determination of a “customer PD” based on exposure, the “information weighting” (that summarizes how, and how far in advance, each product contributes information on the future default of the customer) and the “risk factor for the product combination” that specifies the different contribution of each product combination to the projected rate of default. The validation unit checked the design of the model and its reliability in terms of performance and calibration. In addition, it analyzed the performance of the various underlying modules and their calibration, and also separately reviewed the different possible combinations of products used by the same customer. Rating model for “Commercial Real Estate Finance” The rating model for HVB’s Commercial Real Estate Finance (CRE) is used in Germany to assess exposure to: Real estate dealers: Companies whose financial statements report income that comes mainly from the construction (or purchase) and subsequent sale of buildings for residential or commercial (offices, stores) uses; Real estate investors that publish financial statements: Companies whose financial statements report income that comes mainly from the lease of owned residential and commercial properties; Real estate investors that do not publish financial statements: Companies with no financial statements or individual customers with income coming mainly from the lease of owned properties. This model provides a different module for each of the three categories of counterparties indicated above. Each module is made up of three sub-modules: a) a qualitative module that aims to assess the quality and reliability of management, the abilities of the management team, the quality of organizational management and the bank's experience in managing relationships with the company; b) a qualitative module that aims to assess the asset/project to be financed or already financed (by the bank or other lender), including the quality and implicit risk of the portfolio of the company’s properties/projects, its planning capabilities (based on past experience) and cash flows planned/projected in future years; c) a quantitative financial module based on the company’s financial statements supplemented with a qualitative assessment of the quality, reliability and completeness of the financial statements. 78 Modules a) and b) are expert-based systems in which the factors and their weightings were determined by a team of experts and refined over time based on experience gained, while module c) was developed statistically. The results of the three sub-modules are then combined on the basis of the score (Log-PD for the quantitative module), with the weighting defined on the basis of expert opinions, and the final score calibrated statistically. The three modules all use the same sub-modules. What changes is the weighting used to combine the partial scores into the overall score. The validation unit assessed the design of the model including through an analysis of responses to a questionnaire provided to users. It also tested the reliability of the model and its modules in terms of performance and calibration, and the stability of the sample, including through the use of transition matrices. Finally, it analyzed the coverage of the portfolio and checked in how many cases there were invalid ratings due to the failure to update several components of the model and overruling rules. Rating model for “Acquisition and Leveraged Finance” transactions The “Acquisition and Leveraged Finance" (ALF) model is used for the assessment of projects to finance/refinance corporate acquisition transactions in which additional bank liabilities are added to the normal operating debt of the company acquired in order to finance the acquisition. The debt resulting from the acquisition is repaid out of the future cash flow of the company acquired, and, in certain cases (i.e., acquisitions that involve strategic investors), out of the cash flows of the acquiring company. Acquisition transactions and their corporate and tax implications (often involving several jurisdictions) demand specific expertise during the audit phase, and require: appropriate risk-return relationships in addition to a loan structure based on a realistic cash flow simulation model; 79 the adjustment of the acquired company’s financial and debt repayment structure to future cash flows; the combined use of highly differentiated borrowing tools (senior debt, junior debt, mezzanine debt, etc.). In terms of procedural aspects, the "ALF rating" is essentially a financial rating that calculates the acquired company’s probability of default based on equity and financial ratios taken from the provisional financial statements and income statement. There is no qualitative module since in the preparation of the provisional financial statements, a large amount of qualitative information based on experts’ opinions is already implicitly taken into consideration. The provisional financial statements are prepared with the aid of models that simulate future cash flows (INCAS, international financial model). In this case, manual adjustments (overrides) are also allowed with respect to individual financial ratios and the end rating, and these adjustments must be approved by the units in charge and must be closely monitored by the internal validation unit. The validation unit performed qualitative and quantitative analyses to check the model’s reliability. In particular, the qualitative analyses of the model’s design are based on results of a questionnaire provided to users. The results of the model were compared with internal and external benchmarks from a quantitative viewpoint. “Income Producing Real Estate” (IPRE) rating model The IPRE-Slotting Criteria model provides an assessment of a particular category of specialized loan related to cash-flowbased real estate transactions in which the bank has direct access to the cash flows produced in the transaction. Since it is the result of slotting criteria, the model was obtained by following the project assessment procedures dictated by prudential rules. To be specific, the model uses qualitative risk factors and a scoring process that produces an overall score on the basis of the type of property or number of properties to be assessed. Different scorecards are created as a function of the type of ownership/property. The valuation criteria of the scorecards are divided into 5 risk categories as indicated in the regulatory provisions. Each risk category is assessed on the basis of different risk factors using a questionnaire, and the user assigns an individual score on a scale of 1-5 to each question. The combination of the various scores results in the final assessment. 80 Rating model for “Asset Backed Commercial Paper” operations The model, developed by replicating the approach of the rating agencies, assigns a rating to HVB’s commitments in relation to vehicles that issue “Asset Backed Commercial Paper”, and is used only in cases where the transaction is suitable to be given an internal valuation as required by the Regulatory Authority. Three types of exposure are distinguished: Letters of credit Lines of liquidity Swap agreements This Rating System comprises different models which are applied according to the type of exposure underlying the securitization operation. In particular, there are 7 models: 1. Trade receivables; 2. Mortgage warehousing (to cover the residential mortgages segment); 3. Single rated securities; 4. Commercial mortgages (to cover the commercial mortgages segment); 5. Loans and leases; 6. Rated securities and corporate loans; 7. Credit cards All of the above models consist of a quantitative module which supplies a rating class and a qualitative module whose results influence the quantitative module through the upward or downward movements of notches. For the quantitative module, two principal methodologies are used according to the type of underlying exposure and the residual life of the assets within the vehicles: “Reserve Based” approach: used for assets with a short residual life (typically less than 6 months) within the vehicle (and consequently the commitment also has a limited duration). For this type of transaction, a “point in time” valuation is carried out in order to determine, in a static manner, the reserves required to cover the losses. “Cash Flow Based” approach: used for assets with a longer residual life. In this case, instead of making a “point in time” valuation, the evolution of the assets within the vehicle is evaluated by using models which take account of the expected cash flows to determine the reserves necessary to cover the losses suffered. 81 Apart from the above difference, the structure of the model is generally very similar, as can be seen from the graphic below: General model structure – Reserve Based Model 82 General model structure – Cash flow models All the qualitative modules have been developed on the basis of feedback from experts in the sector. The validation unit has assessed the conformity of the approach followed by HVB with the criteria used by the Rating Agencies and declared that it satisfies the minimum requirements prescribed by current legislation. LGD model The LGD represents the financial loss suffered by the bank on the individual transaction, and is calculated as a percentage of the exposure to default. The LGD is calculated for each individual transaction and takes account of the fact that different types of default are possible: Liquidation: total liquidation of the guarantees and forced recovery of the residual debts. The relationship with the customer is terminated and the customer is removed from the portfolio. Settlement: the customer re-enters the performing portfolio after reporting a major loss (> €100) to the bank. Cure: once the period of difficulty is over, the customer re-enters the performing portfolio after reporting a major loss to the bank. In the case of a Cure, the LGD is set at 0, while in the other two cases the estimation of the LGD follows a work-out approach, with separate estimation of the recoveries deriving from guarantees and those deriving from the unsecured part of the exposure. Personal guarantees are not taken into account in the models, since the substitution approach is used for this type of guarantee. 83 In order to determine the final value of the LGD, the following factors are taken into consideration: minimum value that the LGD can fall to under legislative provisions (e.g. 10% for mortgages); estimated rate of non-cure cases; expected recovery value of the guarantee, net of direct costs; expected rate of loss of the unsecured portion of the transaction, discounted and net of direct costs; percentage of indirect costs (net of the recoveries made after closure of the positions which it has not been possible to re-attribute to the individual position); refinancing costs; any adjustment factor to take account of a potential worsening of the economic cycle. With regard to the procedure for estimating the rate of recovery from the guarantee, this has been obtained on the basis of a historical sample and calculated differently for the following types of guarantee: real estate; other guarantees (physical); other guarantees (non-physical). This value has then been discounted by taking account of the average observed duration of the defaults. With regard to the procedure for estimating the unsecured part, on the other hand, this has been carried out separately for seventeen customer categories (the principal categories are retail, small business, corporate, real estate developers, real estate investors, real estate housing companies, etc.). The validation unit has examined the structure of the model, its coherence with the definition of PD, the effect of the economic cycle, the methodology for discounting recovery flows, the allocation of costs and the handling of the assets in default. The calibration of the model and its components has also been checked. EAD model The EAD model determines the expected exposure on a transaction at the time of the default. It is estimated for each individual transaction as the sum of two components: Where the parameter that is estimated is obviously the EAD (Off balance). This parameter may be generically defined as the sum of the following elements: Where: CEQ: Credit Equivalent Factor; this is the credit conversion factor for the credit, and represents the portion of the commitment/guarantee issued by the bank that will be used; 84 LEQ: Limit Equivalent Factor; this is the percentage of the amount unused 12 months before the default that is expected to be used at the time of the default; LOF: Limit Overdraft Factor; BO: Base Overdraft; BO and LOF: these are the parameters that estimate the expected amount of use that, at the time of the default, will exceed the allocated maximum limit (overdraft amount); in the application phase, in order to avoid a “double counting” for cases where the counterparty is already in an overdraft situation, a correction is made using the OCF (Overdraft Correction Factor); Endorsement: amount of commitments issued to the bank’s customer; external line: irrevocable line of credit; drawing: current use. The parameters defined above are then differentiated according to the product macro-typologies defined within the regulatory calculation engine. For the purposes of evaluating the model, the parameters have been assessed by calculating on the basis of the weighted averages for each segment. The validation unit has examined the design model with particular reference to the coherence of the defined parameters, the need to include a downturn parameter and the coherence of the definition of default with that used in the PD and LGD models. The calibration of the model and its components, including their major sub-segments, has also been checked. Local Models, Austria division “Mid corporate” rating model The “Firmenkundenrating Inland” rating (= Midcorporate PD rating) concerns itself with ratings for exposures to the category of Bank Austria (BA) businesses based in Austria of more than €1.5 million and less than €500 million. The model consists of two components: a quantitative module and a qualitative module. The risk factors for the quantitative module have been selected on the basis of both statistical and expert criteria. The principal risk factors included in the quantitative module generally cover the following areas of analysis: Size; Growth; Cost/Income; ROI. The qualitative module, on the other hand, covers the areas of analysis relating to: financial situation (not directly covered by the quantitative model), with view to evaluating the capacity for repayment and the future serviceability of the debt; 85 managerial/entrepreneurial setup; risk factors and behaviors. The “qualitative rating” and the “final financial rating” (= quantitative rating after verification of the possibility of applying an “age restriction” and carrying out a first “override” on the basis of the information available) are combined to obtain the socalled “Combined Customer Rating”. The “warning signals” are applied to this rating in order to obtain the “Modified Customer Rating”. If this rating is older than 15 months, an “age restriction” is applied, resulting in a downgrade of the qualitative and quantitative rating. It is also possible to apply an override to this rating, thus producing the “Stand alone Customer Rating”. If there are no situations of default, or if the counterparty does not belong to a Group (this could entail a modification of the rating), then the “Stand alone Customer Rating” is also the “Approved Customer Rating”. The figure below depicts in detail the different phases involved in determining the final rating. The validation unit has also evaluated the design of the model by analyzing the responses to a questionnaire submitted to users. It has also tested the behavior of the model and the modules that it comprises in terms of performance and calibration. Finally, it has carried out analyses aimed at identifying any distorting behaviors in the use of the qualitative questionnaire, the overrides and the warning signals, as well as analyzing the matrix of transition between financial rating and final rating. “Small Business” rating model This rating model is applicable to small or medium-sized Austrian businesses (up to €1.5 million net profit or using shortform accounting) and small-scale self-employed professionals and non-profit organizations. The general design of the model differentiates between “application scorecard” and “behavior scorecard”. 86 The application scorecard is applied principally in the following cases: new client; the customer requests a further line of credit for which the total exposure exceeds €50,000 or there is no behavior score (irrespective of the amount of the exposure); the updated balance sheet information is available; the “warning signals” have been modified / have arisen. The application scorecard contains a qualitative and a quantitative module. There are two different scorecards according to the accounting regime of the counterparty: one for small businesses and self-employed professionals drawing up a balance sheet, and for non-profit organizations; and one for small businesses and self-employed professionals subject to a short-form accounting regime. The principal risk factors included in the quantitative modules principally cover the following areas of analysis: Profitability; Debt coverage. There are also two qualitative scorecards (one for small businesses and one for self-employed professionals). For nonprofit organizations, the scorecard for small businesses is applied. The qualitative scorecards cover, among other things, the areas of analysis relating to: Reliability of management; Level of disclosure to the bank; Quality of the accounting systems. If the customer’s transaction is older than 6 months, the behavior scorecard is calculated automatically on a monthly basis. The behavior scorecard, on the other hand, is the same for all types of counterparties. The risk factors for the behavior score have been selected on the basis of a thorough analysis carried out by a mixed team of experts in statistics and credit analysis. The two scorecards (application and behavior) are combined using different weights according to the exposure and the age of the application score in order to obtain the so-called combined PD, which, once mapped to the master scale, determines the “calculated rating”. The final “valid rating” is obtained by modifying the calculated rating on the basis of any available negative information or of “warning signals” in general. The figure below depicts in detail the different phases involved in determining the final rating. 87 The validation unit has verified the appropriateness of the design of the model and carried out quantitative analyses principally aimed at evaluating the discriminating power of the model and its components. It has also verified the stability of the small business population and the calibration of the model. “Private” rating model The Private rating model is applicable to all individuals other than self-employed professionals and independent laborers. The model consists of 6 scorecards: 3 yield cards and 3 behavior cards, differentiated according to the type of product (mortgages, current accounts and consumer loans), statistically combined in order to obtain a counterparty PD. In a first step, one of the six scorecards mentioned above is applied for each transaction. If the age of the transaction is less than 6 months, the application scores are used; conversely, if the transaction is older than 6 months, the behavior score is calculated and updated each month. In a second step, the so-called integration principle makes it possible to consider, for each transaction, the possible effects deriving from any other types of transactions that the client has with the bank. The result of this integration determines the “Account specific customer score” for each transaction. In the third step, according to the integration principle, all the PDs thus determined for the products of the customer concerned are combined in order to obtain, through the use of a geometric mean, the “Customer PD”. In the fourth and final step, the PDs are mapped to the rating classes using the BA Masterscale. Both the transaction PD and the counterparty PD may be modified owing to “warning signals” or negative information received from external credit agencies. The internal validation unit has also verified the design of the model by means of checks among users. The behavior (performance and stability) of the model and its various components has also been analyzed, along with the associated calibration. Finally, an analysis of the portfolio hedging and a thorough examination of the use of warning signals have been carried out. 88 “Non Profit Building Association” rating model The “Non Profit Building Association” (NPBA) rating model is applied to non-profit associations created for the construction of buildings. This is a rating model consisting of a quantitative component (financial rating) and a qualitative component. The financial rating is based on three principal types of information: 1. Adequacy of the available capital; 2. Profitability; 3. Available liquidity. The qualitative rating, on the other hand, is based on 6 basic components: 1. Quality of management; 2. Accounting and reporting; 3. Organization; 4. Market position; 5. Performance behavior; 6. Specific characteristics of the NPBA. The quantitative and qualitative ratings are combined in order to obtain the “Combined Rating”; this rating may be subject to an overruling on the basis of information available to the manager of the transaction, and the final product of this activity is the so-called “Valid customer rating”. “Income Producing Real Estate” (IPRE) rating model The IPRE model is a transaction rating applied to a particular type of specialized loan linked to “cash flow based” real estate transactions in which the bank has direct access to the cash flows deriving from the transaction. In this type of transaction, the essential question to which an answer is sought through careful evaluation is whether the cash flows from the transaction are sufficient to repay the bank. In addition, BA also carries out an evaluation of the investor/builder. Consequently, the IPRE model consists of two components: 1. transaction rating; 2. counterparty rating. Both of these components are combined in order to obtain the final rating. The transaction rating distinguishes three different phases in which the financing may take place: a) construction of the building; b) sale of the building; c) leasing of the building. The counterparty rating is a “corporate rating” which differentiates between “real estate investors” and “real estate constructors”. For both of these, a quantitative module (referring to the balance sheet data) and a qualitative module are used. 89 After integration of the transaction rating and the counterpart rating, further adjustments are applied to take account of warning signals, overrulings (using, among other things, any available external ratings) and “age restrictions” (according to the age of the rating). The figure below shows the structure of the model: In order to verify the adequacy of the model, the validation unit has carried out a qualitative analysis of its overall design. Quantitative analyses have also been carried out with regard to the performance and calibration of the model. “Income Producing Real Estate” (IPRE) LGD model Generally speaking, the LGD represents the financial loss suffered by the bank on the individual transaction, and is calculated as a percentage of the exposure to default. For the purposes of determining the final LGD for an IPRE, three different situations are distinguished: “Cure”: when the counterparty returns to a “performing” state without causing any loss for the bank; “Settlement”: when the counterparty returns to a “performing” state but causes a financial loss for the bank; “Liquidation”: all other cases. When the customer does not cause any financial loss for the bank, an LGD of zero is assumed. Thus, the overall LGD for an IPRE transaction becomes as follows: 90 Below are specific details of the procedure for determining the LGD relating to “liquidation” status. The remaining parameters have been determined, in view of the nature of the transaction, on the basis of expert evaluation carried out by analysts in the sector. In order to determine the liquidation LGD, different elements of information are taken into consideration. In particular: EAD; Rate of recovery; Costs; Discount factor; Value of the guarantee; Priority in repayment of the loan. Both the EAD and the guarantees assume different values according to the different phases of the transaction (construction, sale, rental). The guarantees that can be used in the liquidation phase and therefore considered for the purposes of determining the LGD for the IPRE are as follows: the principal subject of the transaction (the property); additional subjects of the transaction (any other properties); cash; securities. LGD model for the other transactions The LGD represents the financial loss suffered by the bank, and is calculated as a percentage of the exposure to default; the general scheme of the LGD model in BA provides for the separate estimation, according to a work-out approach, of the recoveries deriving from guarantees and those deriving from the unsecured part of the exposure. Personal guarantees are not taken into account in the models, since the substitution approach is used for this type of guarantee. In order to determine the final value of the LGD, the following factors are taken into consideration: 91 minimum value that the LGD can fall to under legislative provisions (e.g. 10% for mortgages); expected recovery rate of the guarantee, net of direct costs; expected recovery rate of the unsecured portion of the transaction, net of direct costs; value of the guarantee; refinancing costs; any adjustment factor to take account of a potential worsening of the economic cycle. With regard to the procedure for estimating the rate of recovery from the guarantee, this has been obtained on the basis of a historical sample and calculated differently for the following types of guarantee: residential real estate; commercial real estate; financial guarantees; life insurance policies; other. This value has then been discounted by taking account of the average observed duration of the defaults. With regard to the procedure for estimating the “unsecured” part, on the other hand, this has been carried out separately for seven customer categories (the three principal categories are retail, small business and corporate). In a first phase, an estimation has been made (in a different manner than for retail and with respect to the other categories) of the gross recovery value with respect to the unsecured percentage of exposure; this value has then been corrected to take account of the direct costs. Finally, this value has been discounted by taking account of the average observed duration of the defaults (in a similar manner to that applied for the value of the guarantees). The validation unit has examined the structure of the model, its conformity with the definition of PD, the effect of the economic cycle, the methodology for discounting recovery flows and the allocation of costs. The design of the model has also been evaluated through targeted discussions with experts in the sector. From the quantitative point of view, performance and calibration analyses have been carried out for all important sub-portfolios. EAD model The EAD model determines the expected exposure on a transaction at the time of the default. It is estimated for each individual transaction by using the following information: effective exposure at the time of the estimation; amount of guarantees/commitments issued by the bank to the counterparty; allocated maximum credit limit. The estimated parameters are as follows: CEQ: this is the credit conversion factor for the credit, and represents the portion of the commitment/guarantee issued by the bank that will be used; LEQ: this is the percentage of the amount unused 12 months before the default that is expected to be used at the time of the default; BO and LOF: these are the parameters that estimate the expected amount of use that at the time of the default will exceed the allocated maximum limit (overdraft amount); COF: this is important only if the client’s exposure, in the application phase of the model, is above the allocated maximum limit, and is calculated as the ratio between the overdraft amount at the time of the default and the overdraft amount 12 months earlier. 92 The parameters have been estimated by calculating weighted averages for each segment. The estimation and segmentation have been carried out separately for transactions that refer to a single type of product and those that refer to multiple products. For the first type of transaction, the observations have been segmented according to the product type, the segment of the counterparty and the sector of economic activity, while for the second type of transaction only the last two aggregation approaches have been taken into consideration. For both types of transaction, the segments have been aggregated by following a 2-step clustering algorithm: in the first step, those categories that differ only in one segmentation criterion have been aggregated; in the second step, the clusters have been further aggregated in order to minimize the dispersion of the model’s parameters. 93 Quantitative disclosure (€ thousand) IRB approach - risk assets Foundation IRB approach Advanced IRB approach Amounts as at 06/30/2008 Exposures classes Exposure weighted Exposure weighted Exposure amount Exposure amount amount amount Exposures with or secured by central administrations and central banks Exposures with or secured by supervised institutions, public and territorial entities and other entities: 0 0 5.703.572 199.513 - Supervised institutions 0 0 141.203.198 18.354.708 - Public and territorial entities 0 0 1.476.996 150.677 - Others 0 0 858.444 269.971 - Specialized lendings 0 0 7.576.954 3.205.633 - Small/Medium enterprises (SME) 0 0 98.511.696 44.998.674 - Other corporates 0 0 115.265.374 50.683.886 11.086.199 3.554.222 64.591.051 15.012.865 Exposures with or secured by corporates: Retail exposures: - Exposures secured by residential real estate property: SME - Exposures secured by residential real estate property: individuals - Qualified revolving reatil exposures - Other retail exposures: SME - Other retail exposures: individuals Purchased receivables: dilution risk 0 0 Other assets 7.765.986 2.104.195 27.816.065 8.886.856 14.589.402 8.247.965 0 0 34.261.864 1.114.570 3.819.314 3.022.338 Specialized lending - slotting criteria 0 0 Alternative treatment of mortgages Settlement risk: Exposures connected to non DVP transactions (Delivery Versus Payment) with supervisory weighting factors 0 0 0 0 61.049 61.049 Total on-balance-sheet risk assets 0 0 295.413.524 121.245.641 Total guarantees given and committed lines 0 0 135.433.391 26.664.656 Total derivatives contracts 0 0 39.951.831 10.909.737 1.047.090 Totale SFT transactions and long settlement transactions 0 0 63.788.416 From contractual cross product netting 0 0 0 0 Total 0 0 534.587.162 159.867.124 94 (€ thousand) Advanced IRB approach Exposures classes Exposures with or secured by Central Administrations and Central Banks of which: offbalance sheet items Exposure amounts 7.837.593 522.936 PD - 0,00% 591.024 0 PD - 0,02% 3.130.006 174.038 PD - 0,03% 35.808 8.500 PD - 0,04% 13.589 0 PD - 0,08% 201.181 11.036 PD - 0,10% 21.119 16.866 PD - 0,14% 10.000 10.000 PD - 0,19% 2.981.448 75.051 PD - 0,26% 5.568 3.001 PD - 0,34% 40.000 0 PD - 0,36% 2.677 1.242 PD - 0,49% 5.860 5.150 PD - 0,61% 5.000 0 PD - 0,66% 10.303 10.001 PD - 0,90% 13.352 10.967 PD - 1,23% 175.572 164.519 PD - 1,68% 5.000 5.000 PD - 2,29% 551.048 0 PD - 3,12% 32.534 27.421 PD - 7,90% 187 76 PD - 20,00% 135 61 PD - 100,00% 6.182 7 186.040.697 9.803.462 PD - 0,02% 26.696.302 2.560.436 PD - 0,03% 101.854.180 1.381.498 PD - 0,04% 14.077.979 630.907 PD - 0,06% 3.628.709 934.365 PD - 0,08% 14.107.436 796.188 PD - 0,09% 123 62 PD - 0,10% 3.616.401 133.003 PD - 0,14% 3.681.121 375.684 PD - 0,19% 3.959.544 56.752 PD - 0,22% 11.476 0 PD - 0,26% 337.050 41.253 PD - 0,27% 553.530 36.302 PD - 0,36% 157.522 39.739 PD - 0,40% 19.375 4.361 PD - 0,43% 445.465 16.373 PD - 0,49% 1.627.552 211.535 PD - 0,52% 5.645 947 PD - 0,61% 6 0 Exposures with or secured by supervised institutions, public and territorial entities, and other entities 95 Exposures classes of which: offbalance sheet items Exposure amounts PD - 0,66% 599.033 PD - 0,70% 1.117.291 77.182 48.846 PD - 0,90% 462.185 139.134 PD - 0,96% 18.374 946 PD - 1,12% 3.225.216 1.369.131 PD - 1,23% 1.027.347 294.044 PD - 1,54% 70.757 22.719 PD - 1,64% 9.503 528 PD - 1,68% 421.817 150.889 PD - 1,89% 620.037 40.893 PD - 2,29% 1.477.166 61.792 PD - 2,60% 31.111 8.916 PD - 2,99% 11.055 4.656 PD - 3,00% 60 0 PD - 3,12% 308.275 50.116 PD - 3,19% 356.981 26.377 PD - 4,25% 98.729 16.371 PD - 4,87% 5.549 249 PD - 5,38% 216.182 10.724 PD - 5,80% 111.240 21.806 PD - 7,90% 200.936 111.623 PD - 10,77% 45.488 16.132 PD - 10,95% 4.190 0 PD - 12,06% 485.953 27.470 PD - 14,67% 22.601 9.402 PD - 20,00% 39.829 4.822 PD - 20,48% 1.511 123 PD - 25,00% 177.533 64.987 PD - 53,54% PD - 100,00% Exposures with or secured by corporates 262 0 95.070 4.179 222.595.130 38.620.746 PD - 0,00% 51.957 0 PD - 0,02% 3.496.701 361.319 PD - 0,03% 7.817.999 1.834.473 PD - 0,04% 2.484.308 501.939 PD - 0,06% 4.163.593 888.992 PD - 0,08% 3.788.258 1.051.550 PD - 0,09% 8.157.008 615.018 PD - 0,10% 6.947.168 2.400.334 PD - 0,14% 4.122.906 1.817.729 PD - 0,15% 961.097 214.544 PD - 0,19% 7.900.939 2.816.188 PD - 0,22% 14.362.414 1.132.883 PD - 0,24% 1.623.531 408.360 PD - 0,26% 5.004.089 1.859.167 PD - 0,27% 10.521 0 96 Exposures classes of which: offbalance sheet items Exposure amounts PD - 0,36% 4.520.570 PD - 0,40% 3.140.933 1.143.107 356.673 PD - 0,49% 7.657.257 2.552.570 PD - 0,52% 24.543.108 2.146.912 PD - 0,65% 851.647 89.697 PD - 0,66% 5.211.021 1.148.602 PD - 0,90% 3.084.080 673.274 PD - 0,96% 17.605.436 1.169.166 PD - 1,07% 887.822 39.470 PD - 1,23% 11.036.533 3.034.215 PD - 1,54% 13.091.785 1.065.658 PD - 1,64% 1.114.534 158.279 PD - 1,68% 4.267.926 1.134.502 PD - 1,79% 411.172 69.034 PD - 1,89% 10.000 0 PD - 2,29% 3.259.054 793.301 PD - 2,60% 9.843.587 698.141 PD - 2,99% 1.662.130 188.647 PD - 3,12% 8.376.454 2.314.886 PD - 4,25% 5.735.368 1.098.146 PD - 4,87% 4.125.488 376.823 PD - 4,99% 112.047 2.567 PD - 5,38% 883.841 134.034 PD - 5,80% 2.446.921 542.544 PD - 7,90% 3.414.444 628.521 PD - 10,77% 1.589.566 183.867 PD - 10,95% 1.076.602 134.117 PD - 11,45% 7.555 75 PD - 14,67% 258.790 38.781 PD - 20,00% 968.045 204.472 PD - 20,48% 159.548 11.719 PD - 25,00% 58.805 0 PD - 31,85% 2.240.739 121.708 PD - 53,54% 72.577 2.217 7.977.256 462.525 PD - 100,00% Equity exposures: PD/LGD approach 18.669 PD - 0,02% 44 n/a PD - 0,08% 1.136 n/a PD - 0,19% 8.601 n/a PD - 1,23% 1.343 n/a PD - 3,12% 6.250 n/a PD - 20,00% 1.295 n/a 2.438.884 n/a n/a n/a Equity exposures: simple risk weight approach Equity exposures: internal models approach 97 (€ thousand) IRB Approaches - Advanced approach - Retail exposures Exposures classes TOTAL RETAIL EXPOSURES Exposures secured by residential real estate property: SME Exposure amounts of which: offbalance sheet items 125.848.887 8.590.989 11.086.199 583.033 PD - 0,02% 37.474 0 PD - 0,08% 138.593 2.454 PD - 0,19% 2.100.536 37.402 PD - 0,40% 139.228 35.995 PD - 0,49% 3.896.765 60.360 PD - 0,96% 223.558 53.527 PD - 1,23% 1.887.285 28.303 PD - 1,64% 338.876 58.514 PD - 2,99% 535.174 115.879 PD - 3,12% 602.502 9.947 PD - 5,38% 426.655 95.256 PD - 7,90% 163.039 2.105 PD - 10,95% 261.320 55.788 PD - 20,00% 72.704 909 PD - 20,48% 78.041 17.960 PD - 53,54% 34.387 4.336 PD - 100,00% 150.062 4.298 64.591.051 222.649 PD - 0,06% 130.265 496 PD - 0,08% 3.295 0 PD - 0,10% 33.478 1.500 PD - 0,11% 1.581.852 627 PD - 0,14% 37.698 1.053 PD - 0,15% 10.403 0 Exposures secured by residential real estate property: individuals PD - 0,18% 36.581 164 PD - 0,19% 158.267 3.309 PD - 0,24% 7.716.585 6.128 PD - 0,25% 20.413 0 PD - 0,26% 532.293 8.841 PD - 0,30% 6.820.863 4.061 PD - 0,34% 9.718 0 PD - 0,36% 424.776 4.729 PD - 0,37% 7.281.344 6.772 PD - 0,40% 474 0 PD - 0,45% 29.359 78 PD - 0,49% 1.124.134 8.328 PD - 0,52% 12.383 27 PD - 0,54% 4.445.662 13.210 PD - 0,65% 165 0 PD - 0,66% 2.736.626 28.426 98 Exposures classes of which: offbalance sheet items Exposure amounts PD - 0,67% 21.852 8 PD - 0,84% 2.941.708 8.533 PD - 0,90% 2.502.395 10.914 PD - 0,91% 10.445 0 PD - 0,96% 28 0 PD - 1,09% 22.907 15 PD - 1,12% 1.384.659 2.473 PD - 1,23% 7.312.513 39.980 PD - 1,54% 5.095 0 PD - 1,64% 79.014 370 PD - 1,68% 2.268.288 7.592 PD - 1,69% 61.058 221 PD - 1,79% 1.006.563 2.833 PD - 2,20% 661.765 3.088 PD - 2,29% 1.793.596 7.464 PD - 2,45% 27.872 216 PD - 2,99% 284.705 974 PD - 3,10% 6.060 14 PD - 3,11% 5.075 101 PD - 3,12% 1.915.067 16.722 PD - 3,19% 1.086 68 PD - 4,25% 1.051.015 5.391 PD - 4,30% 2.907 0 PD - 5,38% 157.299 151 PD - 5,80% 1.599.186 10.597 PD - 7,90% 516.631 1.595 PD - 10,77% 690.193 3.814 PD - 10,95% 282.281 7 PD - 13,78% 81 0 PD - 14,67% 544.147 3.302 PD - 20,00% 500.466 1.535 PD - 20,48% 122 0 PD - 31,85% 1.131.881 660 PD - 50,38% 508 0 PD - 50,69% 457 0 PD - 53,54% 40.603 0 PD - 100,00% 2.614.889 6.262 Qualified revolving retail exposures 7.765.986 5.822.428 PD - 0,02% 114 21 PD - 0,03% 14 14 PD - 0,06% 97 59 PD - 0,08% 22.915 19.575 PD - 0,10% 695.852 682.456 PD - 0,14% 145.356 141.002 PD - 0,19% 662.883 592.488 PD - 0,26% 244.953 221.049 99 Exposures classes Exposure amounts of which: offbalance sheet items PD - 0,36% 106.097 91.623 PD - 0,49% 2.200.922 1.961.211 PD - 0,66% 319.085 258.494 PD - 0,90% 139.422 106.540 PD - 1,23% 1.762.530 1.315.128 PD - 1,68% 84.006 46.009 PD - 2,29% 77.299 38.662 PD - 3,12% 495.848 166.482 PD - 4,25% 73.886 34.358 PD - 5,80% 186.261 61.832 PD - 7,90% 151.746 25.327 PD - 10,77% 23.145 8.442 PD - 14,67% 74.804 20.311 PD - 20,00% 141.951 25.733 PD - 100,00% 156.800 5.612 27.816.249 843.389 Other retail exposures: SME PD - 0,02% 24.133 0 PD - 0,08% 1.212 127 PD - 0,10% 963 744 PD - 0,14% 359 293 PD - 0,19% 12.775 9.499 PD - 0,26% 8.483 6.659 PD - 0,36% 3.039 2.453 PD - 0,40% 5.154.094 127.833 PD - 0,49% 73.694 39.687 PD - 0,66% 48.863 37.191 PD - 0,90% 13.146 7.143 PD - 0,96% 4.444.544 71.776 PD - 1,23% 278.936 151.505 PD - 1,64% 3.709.047 47.530 PD - 1,68% 11.514 4.524 PD - 2,29% 13.923 5.195 PD - 2,99% 3.927.680 44.481 PD - 3,12% 321.660 114.582 PD - 4,25% 14.711 5.161 PD - 5,38% 3.436.495 33.511 PD - 5,80% 91.932 30.093 PD - 7,90% 191.628 34.639 PD - 10,77% 11.188 3.363 PD - 10,95% 2.506.782 24.787 PD - 14,67% 29.669 6.727 PD - 20,00% 72.722 7.773 PD - 20,48% 838.535 12.545 PD - 53,54% PD - 100,00% 488.326 4.467 2.086.196 9.101 100 Exposures classes Other retail exposures: individuals Exposure amounts 14.589.402 of which: offbalance sheet items 1.119.490 PD - 0,02% 97.388 0 PD - 0,06% 179 122 PD - 0,08% 99.187 12.709 PD - 0,10% 54.419 15.658 PD - 0,14% 21.553 4.038 PD - 0,19% 1.240.073 168.811 PD - 0,26% 171.022 22.722 PD - 0,36% 140.412 17.178 PD - 0,49% 2.554.622 287.698 PD - 0,66% 754.319 59.649 PD - 0,90% 472.835 28.862 PD - 1,23% 3.241.652 232.229 PD - 1,68% 604.166 27.797 PD - 2,29% 640.404 23.035 PD - 3,12% 1.366.777 88.979 PD - 4,25% 392.230 15.763 PD - 5,80% 579.657 25.412 PD - 7,90% 457.072 16.823 PD - 10,77% 278.762 35.083 PD - 14,67% 168.686 8.338 PD - 20,00% 270.973 8.513 PD - 100,00% 983.014 20.071 101 Table 8 – Risk mitigation techniques Qualitative disclosure Within the compliance to the framework of Basel II requirements, UniCredit Group has been carrying out specific activities aiming at defining all the requirements for recognition of Credit Risk Mitigation techniques and to take all the necessary steps for their satisfaction, i.e. policies / internal guidelines, processes and supporting IT systems, in relation to the different approaches adopted (Standardized, IRB-F or IRB-A) and in accordance with each Country’s domestic legal system and all local supervisory requirements. With these regards specific policies representing the Group acknowledgement and interpretation of the regulatory requirements concerning the Credit Risk Mitigation have been issued. In particular the requirements set out by the “International Convergence of Capital Measurement and Capital Standards” and “Directive 2006/48/EC of the European Parliament and of the Council” have been translated into internal guidelines, pursuing several objectives: to encourage collateral and guarantees optimal management; to maximize the credit protections’ mitigating effect on credit losses; to attain positive effect on Group Capital Requirements, ensuring that Local CRM practices meet minimum Basel 2 requirements; to define general rules for eligibility, valuation, monitoring and management of collateral (funded protection) and guarantees (unfunded protection) and to detail special rules and requirements for specific collaterals/guarantees. Collateral / guarantee is accepted only to support loans and they cannot serve as a substitute for the borrower’s ability to meet obligations. For this reason they have to be evaluated in the credit application along with the assessment of the creditworthiness and the repayment capacity of the borrower. In the credit risk mitigation technique assessment, UniCredit Group emphasizes the importance of the legal certainty requirement for all the funded and unfunded credit protection techniques, as well as their suitability. Legal Entities put in place all necessary actions in order to: fulfill any contractual and legal requirements in respect of, and take all steps necessary to ensure the enforceability of the collateral/guarantee arrangements under the applicable law; conduct sufficient legal review confirming the enforceability of the collateral/guarantee arrangements on all parties and in all relevant jurisdictions. Legal Entities conduct such review as necessary to ensure enforceability for the whole life of the underlying collateralized credit exposure. In general operative instructions and related processes are particularly severe, aiming at granting the perfection of each collateral/guarantee acquired. On the other hand, suitability has always to be granted. Any collateral / guarantee can be considered adequate if it is consistent with the underlying credit exposure and, for guarantees, when there are no relevant risks towards the protection provider. 102 Policies and processes for, and an indication of the extent to which the Group makes use of, on – and off – balance sheet netting In general netting agreements are considered eligible if they are legally effective and enforceable in all relevant jurisdictions, including in the event of insolvency or bankruptcy of counterparty. Specifically, master netting agreements must meet the following minimum operational conditions: provide for the netting of gains and losses on transactions cleared under the master agreement so that a single net amount is owed by one party to the other; fulfill the minimum requirements for recognition of financial collateral (valuation requirements and monitoring). Legal Entities can use netting agreement only if they are able at any time to determine the position netting value (assets and liabilities with the same counterparty that are subject to the netting), monitoring and controlling debts, credit and netting value. Policies and processes for collateral evaluation and management Unicredit Group has implemented a clear and robust system for managing the credit risk mitigation techniques, governing the entire process for evaluation, monitoring and management. The collateral value is based on the current market price or the estimated amount which the underlying asset could reasonably be liquidated for (i.e. financial instrument or real estate Fair Value). In detail, for financial instruments, valuation methods are different depending on their type: securities listed on a recognized stock exchange, are evaluated according to the market price (the price of the most recent trading session); securities not listed on a recognized stock exchange, have to be based on pricing models based on market data; undertakings for Collective Investments and mutual funds are based on the price for the units that are publicly quoted daily. Market price of pledged securities are adjusted by applying haircuts for market price and foreign exchange volatility according to Basel 2 regulation requirements. In case of currency mismatch between the credit facility and the collateral, an additional haircut is applied. Possible mismatches between the maturity of the exposure and that of the collateral are also considered in the adjusted collateral value. The current models in place within the Group are mainly based on pre-defined prudential haircuts. Internal haircuts for each security based on Value at Risk (VaR) respectively estimated volatility adjustment approach are in use or under implementation. The main Legal Entities of the Group are also provided with tools for the automatic evaluation of the mark to market of the pledged securities, granting the constant monitoring of the financial collateral values. For the valuation of real estate collateral, specific processes and procedures ensure that the property is valuated by an independent expert at or less than the market value. For the Legal Entities operating in Austria, Germany and Italy, systems for the periodic monitoring and revaluation of the real estate serving as collateral, based on statistical methods and internal databases or provided by external infoproviders, are in place. 103 The other types of collateral (such as movable assets) are subject to through evaluation and specific prudential haircuts are applied. Monitoring activities strictly depend on the collateral characteristics. In general pledges on goods are treated with caution. A description of the main types of collateral taken by the Group The list of collateral types taken by each Legal Entity within the Group strictly depends on the approach adopted (Standardized, IRB-F, IRB-A) and on the specific legal framework of the Country. The Holding Company provides specific guidelines for the eligibility of all kind of collaterals and each Legal Entity defines the list of eligible collaterals according to uniform Group methods and procedures and in compliance with all domestic legal and supervisory requirements and local peculiarities. The main collateral types are represented by real estate, both residential and commercial, financial collaterals (including cash deposits, debt securities, equities, Undertakings for Collective Investments in Transferable Securities (UCITS) and mutual funds) and insurance policies. The main types of guarantor and credit derivative counterparty and their creditworthiness In general, the main types of guarantor counterparty are entrepreneurs and company partners/shareholders (and their relatives if the case) of the borrower. Less frequent are credit facilities covered by personal guarantees provided by other companies, usually the holding company or other companies belonging to the same economic group of the borrower, or by financial institutions and insurance companies. Credit derivative providers are mainly banks and institutional counterparties. The list of eligible protection providers depends on the specific approach adopted by each single Legal Entity. For instance, under the Standardized approach, eligible protection providers pertain to a restricted list of counterparts, such as central government and central banks, public sector entities and regional and local authorities, multilateral development banks, supervised institutions and corporate entities that have a credit assessment by an eligible ECAI associated with credit quality step 2 or above). Legal Entities adopting IRB-A have no particular restrictions and the list of eligible protection providers has to be defined by local Risk Management and Strategic Risk Management (if existing) and approved by the competent Body, in coordination with the Holding Company. Before a personal guarantee is acquired, the protection provider (or the protection seller in case of credit default swap) has to be assessed in order to measure his/her solvency and risk profile. The hedging effect of guarantees / credit derivatives for the purpose of credit protection depends basically on the protector’s creditworthiness and the protected amount must be reasonably proportionate to the economic performance capabilities of the protection provider. 104 Information about market or credit risk concentrations under the credit risk mitigation instruments used There is concentration risk when the major part of Group-wide collateral assets (at portfolio level) are concentrated in a small number of collateral types, instruments, special providers of collaterals or sectors. Such concentration is monitored and controlled by the following processes / mechanisms: In case of personal guarantees / credit derivatives, a contingent liability (indirect risk) is charged to the protection provider. In the evaluation of the credit application, the secondary commitment is added to the guarantor and it is reflected in the guarantor’s total credit exposure as deemed competent and approved in accordance with the bank’s system of authority; In case the protection provider, directly or indirectly, is a bank or a sovereign, a specific credit limit has to be instructed and, if the guarantor is a foreign subject, a country limit must be obtained, if necessary; For all the collateral / guarantee types, both credit and market risk, specific reporting and monitoring activities at consolidated level have to be implemented. Quantitative disclosure (€ thousand) Total amount of secured exposures (securitizations excluded) Amounts as at 06/30/2008 Exposures with Central governments and central banks Financial collaterals Other guarantees Guarantees and credit derivatives 52.425 0 10.933.011 629.905 279.200 5.048.957 49.268 101 4.855.732 613.054 0 629.831 525 0 3.237 0 0 0 Corporate and other entities 14.497.147 251.641 5.479.542 Retail exposures Supervised institutions Regional administrations and local authorities Administrative bodies and non-commercial undertakings Multilateral development banks International organizations 16.366.486 6.242 179.854 Corporate (short term exposures) 0 0 52 Collective Investment Undertakings (CIU) 0 133.000 0 4.011.951 0 486 Exposures secured with real estate property Exposures in the form of guaranteed bank bonds (covered bond) 0 0 285.000 Past due exposures 20.061 643 24.036 High risk exposures 0 0 0 Other exposures 0 0 21.462 36.240.822 670.827 27.461.200 Total 105 Table 9 – Counterparty risk Qualitative disclosure Counterparty Risk - Qualitative Information Role of the Parent Company The Parent is responsible for realising risk measurement and management methodologies, developing its own risk measurement system, establishing the grid of operating limits for itself and individual Group entities and monitoring the Group’s total risk profile. The following is a brief description of the risk measurement and control methods in use in the Group’s larger entities. HVB AG Counterparty risk is measured and monitored by an independent risk management unit using an internal model based on a Montecarlo simulation approach. This model is used to calculate – with a 99% confidence interval – the potential future exposure arising from OTC derivatives. The model takes into account the mitigation effect of the netting and collateral agreements entered into with various counterparties. Internal limits are used to monitor the following risks: money market risk; pre-settlement risk for positions margined by collateral agreements; pre-settlement risk for positions not subject to collateral agreements; and settlement risk. The limits grid is specified for all counterparties individually, large groups and countries. The grid is an integral part of the credit approval process. Counterparty exposure is monitored in real time. The integration of front office and internal risk measurement systems enables continuous monitoring of changes in exposure due to derivatives. An automatic report is generated for all interested parties of all excesses over the limits. 106 BA-CA AG Counterparty risk is measured and monitored by an independent risk management unit using an internal model based on a Montecarlo simulation approach which calculates potential future exposure on a daily basis for individual counterparties and portfolios. The following are the main risk measures produced: Current Exposure: The replacement cost that the bank would have to bear on default by the counterparty, i.e., the positive mark-to-market value of derivatives. Potential Future Exposure: The future replacement cost arising from future increases in exposure due to unexpected changes in risk factors (interest rates, exchange rates and share prices), which is calculated using two methods: Montecarlo approach and Add on approach. The Montecarlo approach is used to calculate the main product classes’ potential exposure: currency derivatives, interestrate derivatives, equity and credit derivatives; the future exposure of commodity derivatives and repurchase agreements is calculated by means of add-ons differentiated according to contract maturity. The Montecarlo method in use includes the full revaluation of all transactions by present time buckets. The internal model is able to pick up the mitigation effect of the netting and collateral agreements and to provide internal effective maturity measures as prescribed under Basel II. Counterparty risk monitoring is based on a system of limits for individual counterparties and product groups (spot, derivatives, money markets, securities and repos). Counterparties’ exposures and information relating to the use of credit lines for derivatives transactions is made available 0on line by the central treasury system. UniCredit Banca d’Impresa Counterparty risk relating to derivatives is subject to prior specific credit approval which sets exposure limits for specific Group and outside counterparties. Monitoring of risk profiles is carried out as follows. Positions with mark-to-market higher than approved limit The account manager monitors differences between the credit equivalent – calculated by applying the weighting coefficient to the notional value of the contract – and mark-to-market value, and, where the difference is significant, the risk is reviewed. To facilitate this activity the bank’s markets control department (Presidio Operativo Finanza) identifies significant (i.e., min. 10%) differences between mark-to-market values and limits. The branch manager is informed of these differences so that the counterparty’s credit lines can be promptly reviewed. The assessment is completed positively where the customer brings the mark-to-market value within its limits or provides a real guarantee for the excess amount, or, alternatively, the limit itself is increased accordingly. 107 Positions with large negative mark-to-market A special monitoring process is carried out on customers with negative mark-to-market value of over €500,000. The Derivatives Committee is kept informed by the business functions of potentially critical situations of inconsistent or high risk. These positions are notified by the Derivatives Department to the Risk Management Monitoring unit of the Credit Department; the latter distributes a list of critical positions to the Regional Managers so that the relationship can be closely managed. Local Risk Management Monitoring units check that the instructions of HQ are carried out. The Derivatives Committee regularly monitors the mark-to-market value of derivatives, inter alia, quantitatively and qualitatively, in terms of distribution by product class (focussing on very complex products) and bands of notional principal. IRSs are the most-used derivative for non-financial companies and this portfolio is also tested for sensitivity to various possible interest-rate shocks. Pioneer Global Asset Management An International Swap and Derivatives Association (ISDA) Master Agreement is required for all OTC contracts and Global Policies require that OTC counterparties should be of high standing, viz.: a) S&P Long Term ≥ A or Moody’s ≥ A2; b) capital ratios in excess of an internally defined threshold, viz.: shareholders’ equity, shareholders’ equity net of intangibles/total assets; liquid assets/short-term borrowing; ROE; Cost/Income; and Tier 1. Risk management continuously checks that these standards are met. In addition the Executive Committee and the Board of Directors have also set limits on derivatives transactions for Italianlaw fund managers. Only staff with proven experience and high seniority (viz., investment heads, trading desk heads and senior portfolio managers) are authorised to deal in derivatives. Luxembourg-law funds managed by PIM Ltd have a counterparty limit for CDS hedge purchases. Counterparty risk reports on both standard and derivatives business are given submitted by Risk Management to PIM Ltd’s Credit Committee and regularly sent to PGAM’s Risk Management. 108 Parent and Other Subsidiaries The distribution of business in the Group and its own role are such that the Parent controls most derivatives business entered into with institutional counterparties. In order to contain and control counterparty risk, the Parent has drawn up a schedule of limits based on the credit equivalent of the exposure, i.e., the weighted sum of transactions with an individual counterparty. The weighting takes the specific riskiness of instruments into account. The Parent’s OTC derivatives business uses the internationally recognised ISDA Master Agreement and calls for netting agreements with counterparties, thus limiting the use of the credit line for long or short positions with the same counterparty. Since July 2006 the Parent has been using the Murex IT system for money market instruments and since February 2007 has been developed to take derivatives as well. This makes it possible to manage counterparty risk in keeping with the nature of the business. Within this regulatory and procedural framework, the Parent uses lines of credit assessed and approved, according to their area of responsibility, by the Global Financial Services Department or the Risk Management Department. The amount of each line and the extent of usage are available in the Murex front office system which is automatically updated through data downloads from the loan approval system (Fidi e Garanzie) and the front office system, with no intervention by traders. Controls are as follows: 109 prior check that a line of credit is available by front office staff (line control); a real time and ex-post control by credit approval staff (line control); and a check by middle and back office (line control) that new lines or renewals have been updated. Quantitative disclosure (€ thousand) Counterparty risk - collaterals EAD AMOUNT AS AT COUNTERPARTY RISK - COLLATERALS 06/30/2008 Standardized approach - derivatives contracts 303.466 - SFT transactions and long settlement transactions 24.349.271 (€ thousand) Counterparty risk EAD AMOUNT AS AT COUNTERPARTY RISK 06/30/2008 Standardized approach - derivatives contracts 14.175.006 - SFT transactions and long settlement transactions 15.685.567 IRB approaches - derivatives contracts 39.951.831 - SFT transactions and long settlement transactions 63.788.416 (€ thousand) Counterparty risk - Credit derivative contracts Amounts as at 06/30/2008 Credit derivative contracts (Notional amount) Regulatory trading book Purchases of Sales of protection protection (Sales of (Purchases of risk) risk) 202.849.997 224.692.725 201.140.997 220.472.725 - Credit Default Option 0 0 - Credit Spread Option 0 0 - Credit Spread Swap - Credit Linked Note 0 0 1.294.000 4.220.000 415.000 0 - Credit Default Swap - Total Rate of Return Swap - Other Credit derivative contracts Banking book - Credit Default Swap 0 0 5.686.590 1.287.483 4.250.552 752.483 - Credit Default Option 88.810 0 - Credit Spread Option 0 0 - Credit Spread Swap 0 0 - Credit Linked Note 533.418 535.000 - Total Rate of Return Swap 813.810 0 0 0 - Other Credit derivative contracts 110 (€ thousand) OTC financial derivatives: positive fair value - counterparty risk Amounts as at 06/30/2008 A.1 Central Governments and banks A.2 Public bodies A.3 Banks Offsetting agreement effects Total exposures after offsettings agreements Gross amount settled Offset Gross amount not settled Gross amount not settled Other underlying assets Gross amount settled Gross amount settled Gross amount not settled Exchange rates and gold Gross amount settled Equity securities and share indices Gross amount not settled Gross amount settled Counterparty/Underlying Assets Gross amount not settled Bonds and Interest rates 9.394 3.302 0 0 65.515 12.486 0 0 0 74.909 0 666.252 8.324 5.000 0 39.839 675 0 0 3.797 711.091 3.797 3.820.853 37.247.049 331.016 5.113.511 1.857.839 7.642.242 83.434 79.557 6.190.274 6.093.142 6.190.274 A.4 Financial companies 612.059 3.989.268 3.608.586 1.816.824 260.546 659.273 120.993 102.813 1.606.911 4.602.184 1.606.911 A.5 Insurance companies 69.417 60.520 3.983 4.037 747 3.000 0 0 29.000 74.147 29.000 991.052 374.687 107.573 972 1.072.305 1.358.474 285.045 88.876 1.225.576 2.455.975 1.225.576 A.6 Non-financial enterprises A.7 Other entities Total 111 33.134 23.000 43.519 0 66.764 133.246 511 0 144.000 143.928 144.000 6.202.161 41.706.150 4.099.677 6.935.344 3.363.555 9.809.396 489.983 271.246 9.199.558 14.155.376 9.199.558 (€ thousand) Credit derivatives: positive fair value - counterparty risk Amounts as at: 06/30/2008 Type of transaction Notional amount A. REGULATORY TRADING BOOK A.1 Purchases of protection - counterparty 1. Central governments and central banks Potential future exposure (add-on) 211.400.385 7.390.029 15.988.838 174.325.845 6.138.645 13.437.788 0 0 0 28.997 3.652 2.000 142.024.076 4.836.610 10.988.060 32.218.778 1.298.323 2.444.728 5. Insurance companies 11.999 60 0 6. Non-financial enterprises 41.995 0 3.000 2. Public bodies 3. Banks 4. Financial companies 7. Other entities A.2 Sales of protection - counterparty 1. Central governments and central banks 2. Public bodies 3. Banks 4. Financial companies 5. Insurance companies 6. Non-financial enterprises 7. Other entities B. BANKING BOOK B.1 Purchases of protection - counterparty 1. Central governments and central banks 2. Public bodies 0 0 0 37.074.540 1.251.384 2.551.050 0 0 0 58.000 1.826 4.000 28.996.319 1.127.343 1.941.521 8.015.221 121.302 604.529 0 0 0 5.000 913 1.000 0 0 0 4.500.363 15.521 325.125 3.762.880 13.695 299.125 0 0 0 143.000 1.826 7.000 3. Banks 1.567.853 0 140.148 4. Financial companies 1.308.407 1.826 100.215 10.000 0 1.000 556.000 10.043 33.000 5. Insurance companies 6. Non-financial enterprises 7. Other entities B.2 Sales of protection - counterparty 1. Central governments and central banks 177.620 0 17.762 737.483 1.826 26.000 0 0 0 50.000 0 3.000 3. Banks 459.000 1.826 23.000 4. Financial companies 218.483 0 0 0 0 0 2. Public bodies 5. Insurance companies 6. Non-financial enterprises 7. Other entities Total Positive fair value 10.000 0 0 0 0 0 215.900.748 7.405.550 16.313.963 Table 10 – Securitization transactions Qualitative disclosure The Group acts as originator and sponsor of securitisations as well as investor, as defined by Basel 2 and transposed by Banca d’Italia Circular 263 “New Supervisory Instructions for Banks” dated 27 December 2006. The Group’s origination consists of the sale of on-balance sheet receivables portfolios to vehicles set up as securitization companies under Law 130/1999 or similar non-Italian legislation. The buyer finances the purchase of the receivables portfolios by issuing bonds of varying seniority and transfers its issue proceeds to the Group. The yield and maturity of the bonds issued by the buyer therefore mainly depend on the cash flow expected from the assets being sold. As a further form of security to bondholders, these transactions may include special types of credit enhancement, e.g., subordinated loans, financial guarantees, standby letters of credit or over-collateralization. The Group’s objectives when carrying out these transactions are usually the following: to free up economic and regulatory capital by carrying out transactions that reduce capital requirements under current rules by reducing credit risk and to reduce funding costs given the opportunity to issue higher-rated bonds with lower interest rates than ordinary senior bonds. The Group carries out both traditional securitizations whereby the receivables portfolio is sold to the SPV and synthetic securitizations which use credit default swaps to purchase protection over all or part of the underlying risk of the portfolio. Use by the Group of this type of structures is limited. The amount of loans securitized2 is equal to 7.56% of the Group’s total loan portfolio. Under traditional securitizations the Group keeps the first loss in the form of junior bonds or similar exposure and in some cases provides further credit enhancement as described above. This enables the Group to benefit from the portion of the sold receivables’ yield in excess of the yield due to the senior and mezzanine tranches. Retention by the Group of the first loss risk and the corresponding yield means that most of the risk and return on the portfolio is retained. Consequently these transactions are recognized in the accounts as financings and no profits arising out of the transfer of the assets are recognized and the sold receivables are not derecognized. Exceptions to this rule are those which the Group – while retaining most of the risk and return of the underlying portfolio – has derecognised as being prior to 1 January 2002. On first adoption of IFRS we took the option afforded by IFRS 1 of not rerecognising assets sold before 1 January 2004, regardless of the extent of the risk and return that had been retained. As well as an originator, the Group is also a sponsor of asset-backed commercial paper conduits (i.e., SPVs issuing commercial paper) set up both as multi-seller customer conduits to give clients access to the securitization market, and as arbitrage conduits. - 2 We refer to loans sold, also synthetically, but not derecognized from balance sheet 113 These SPVs are not part of the banking group, but have been consolidated since December 2007. Customer conduits require the formation and management of a bankruptcy-remote company (i.e., one that would be immune from any financial difficulties of the originator) which directly or indirectly buys receivables created by companies outside the Group. The receivables underlying these transactions are not bought directly by the conduit set up by the Group, but by a purchase company which in turn is wholly funded by the conduit by means of commercial paper or medium term notes. The main purpose of these transactions is to give corporate clients access to the securitization market and thus to lower funding costs than would be borne with direct funding. Arbitrage conduits require the formation and management of an SPV that buys highly rated corporate bonds, asset-backed securities and loans. The purpose is to achieve a profit on the spread between the yield on the assets held, usually medium/long-term, and the short/medium-term and the securities issued to fund the purchase. The conduits’ purchase of assets is financed by short-term commercial paper and medium-term notes. Payment of interest and redemption of the securities issued by the conduit therefore depends on cash flow from the receivables purchased (credit risk) and the ability of the conduit to roll over its market funding on maturity (liquidity risk). To guarantee prompt redemption of the securities issued by the conduit, these transactions are guaranteed by a standby letter of credit covering the risk of default both of specific assets and of the whole program. The underwriters also benefit from security provided by specific liquidity lines which the conduit may use if it unable to place new commercial paper to repay maturing paper, e.g. during market turmoil. These liquidity lines may not however be used to guarantee redemption of securities issued by the conduit in the event of default by the underlying assets. In its role as sponsor, the Group selects the asset portfolios purchased by conduits or purchase companies, provides administration of the assets and both standby letters of credit and liquidity lines. For these services the Group receives fees and also benefits from the spread between the return on the assets purchased by the SPV and the securities issued. The current market turmoil has created a significant contraction in investor demand for the securities issued by these conduits. The Group has consequently purchased directly all outstanding commercial paper. Due to the activity performed, the Group bears most of the risk and receives most of the return on conduit business and also has control of the conduits. Consequently, as required by IAS 27 and SIC 12, we have consolidated the above-listed SPVs. The ABCP conduits are consolidated and not the second-level vehicles that are the direct purchasers of the assets, as described above. Accordingly the funding of purchase companies by the ABCP conduits is recognized in the consolidated accounts. However, since the purchase companies are wholly funded by the consolidated conduits, the consolidated accounts in fact disclose the assets in the books of the purchase companies. As well as originator and sponsor, the Group is also an investor in structured credit instruments. These risks are on the books of the Markets and Investment Banking Division (MIB) and UniCredit Ireland mainly for trading purposes. 114 Quantitative disclosure The following tables give a breakdown of the Group’s non-derecognized securitised credits by region and asset quality, and by traditional and synthetic securitizations. (€ millions) Amounts as at 30.6.2008 Traditional Italy Germany Austria Rest of the world Total - Residential mortgage loans 13.068 - Leasing 8.873 0 0 0 13.068 0 385 0 - Consumer loans 9.258 73 0 0 0 73 - SME loans 63 0 0 0 63 - Corporate loans 0 5.402 0 0 5.402 - Others 0 0 0 22.077 5.402 385 Assets sold but not derecognized Total 0 0 27.864 (€ millions) Amounts as at 30.6.2008 Synthetic Austria Other UE Countries Other European Countries (non UE) America Rest of the world Italy Germany Total - Residential mortgage loans 0 13.709 0 0 0 0 0 13.709 - Commercial mortgage loans 0 2.009 7 2 4 0 0 2.022 - SME loans 0 3.183 1.835 15 92 0 0 5.125 993 1.125 1.660 965 511 464 1 5.719 0 0 0 0 0 0 0 0 993 20.026 3.502 982 607 464 1 Synthetic transactions - Corporate loans - Others Total 115 26.575 (€ millions) Amounts as at 30.6.2008 Traditional Other assets (performing) Impaired assets Total Assets sold but not derecognized - Residential mortgage loans 12.980 88 13.068 9.109 149 9.258 - Consumer loans 72 1 73 - SME loans 63 0 63 5.383 19 5.402 0 0 0 27.607 257 27.864 - Leasing - Corporate loans - Others Total (€ millions) Amounts as at 30.6.2008 Synthetic Other assets (performing) Impaired assets Total - Residential mortgage loans 13.525 184 13.709 - Commercial mortgage loans 2.015 7 2.022 - SME loans 5.091 34 5.125 - Corporate loans 5.719 0 5.719 0 0 0 26.350 225 26.575 Synthetic transactions - Others Totale As noted, the traditional securitisation tables give the amount of the assets sold but not derecognised due to retention by the Group of most of the related risk and rewards. Alongside these there are further exposures totalling €1,392 million, almost all of which are impaired assets derecognised as being prior to 1 January 2002, as detailed in the previous section. The total amount of the exposures securitised by the Group by means of traditional securitisation is €29,256 million. Funded securitization structures originated by the Group mainly have residential mortgages and leasing granted to Italian counterparties as underlyings. Structures originated in Germany, a significant part of the securitized portfolio, have corporate loans as underlyings. Synthetic securitization structures have mainly residential mortgages and loans to Small Medium Entities originated in Germany as underlyings. Both for funded and unfunded securitization structures, the underlying portfolio is almost entirely performing. The Group is not an originator of securitizations having US subprime or Alt-A residential mortgages as underlyings. In H1 2008 a single securitization was carried out involving performing receivables arising out of motor, equipment and property leases, with a nominal amount of €2,489 million. Sale of these assets occasioned neither gains nor losses for the Group, which underwrote the entire amount of the securities issued by the vehicle. 116 The following table gives the amounts of in-house and others’ securitisations divided according to the Group’s role and the type of exposure. Where the Group acted as investor the table shows only those exposures that are held in the banking book. The trading book contains further exposures totalling €11,485 million. Further information on the Group’s total exposure to structured credit products is available in the specific disclosure and the glossary of terms and acronyms given in the 2008 Consolidated First Half Report. (€ millions) Amounts as at 30.6.2008 Investment in securitizations Senior Mezzanine Junior Total Assets sold totally derecognized 122 428 574 1.124 - CLO/CBO - CLO / CBO others 112 0 69 181 112 0 69 181 - Others 10 428 505 943 Guarantees given 267 0 0 267 0 721 0 721 Assets sold but not derecognized 3.959 425 897 5.281 - RMBS - Prime 1.109 1.109 154 154 290 290 1.553 1.553 Investments in own ABS transactions Credit facilities - CLO/CBO - CLO SME 485 31 99 615 480 16 23 519 - CLO arbitrage/balance sheet 0 0 0 0 - CLO / CBO others 5 15 76 96 - Consumer loans 3 1 10 14 - Leasing 2.362 238 498 3.098 - Others 0 1 0 1 Guarantees given 0 0 0 0 Credit facilities 0 0 45 45 Synthetic transactions 6.456 504 26 6.986 - RMBS 4.242 265 26 4.533 - Prime 4.242 265 26 4.533 - CLO/CBO 2.453 2.214 239 0 - CLO SME 80 133 0 213 - CLO arbitrage/balance sheet 140 35 0 175 - CLO / CBO others 1.994 71 0 2.065 Guarantees given 0 0 67 67 Credit facilities 0 0 0 0 Balance sheet exposures 0 5.384 0 5.384 - ABCP 0 5.384 0 5.384 Guarantees given 0 0 0 0 1.828 0 0 1.828 Balance sheet exposures 770 793 93 1.656 - RMBS 268 0 0 268 268 0 0 268 Consolidated Conduits sponsored by the Group Credit facilities Investments in third party securitizations - Prime - CMBS 92 1 0 93 - CDO 232 14 0 246 232 14 0 246 27 49 56 132 - CLO SME 27 4 1 32 - CLO arbitrage/balance sheet 0 12 3 15 - CLO / CBO others 0 33 52 85 - Consumer loans 17 0 0 17 - Credit cards 27 0 0 27 - Leasing 43 5 0 48 - Others 53 1 37 91 - Warehouse Financing 11 723 0 734 0 0 38 38 892 74 0 966 - CDO others - CLO/CBO Guarantees given Credit facilities 117 (€ thousand) Standardized approach: securitisation positions Amounts as at 06/30/2008 On-Balance-Sheet risk assets WEIGHTING FACTORS Off-Balance-Sheet risk assets "in house" securitisations third party securitisations Securitisation type Traditional "in house" securitisations third party securitisations Securitisation type Synthetic Traditional Pre-payment clauses Securitisation type Synthetic Traditional "in house" securitisations Securitisation type Synthetic Traditional Securitisation type Synthetic Traditional Synthetic Weighting 20% 570.990 0 4.686.372 106.738 0 0 0 0 Weighting 50% 0 0 21.881 33.321 0 0 0 0 Weighting 100% 0 0 37.125 22.545 0 0 0 0 Weighting 350% 0 0 15.131 12.411 0 0 0 0 Weighting 1250% - with rating 0 0 0 0 0 0 0 0 Weighting 1250% - without di rating 0 0 9.561 0 0 0 0 0 Look-through - second loss in ABCP 0 0 0 0 0 0 0 0 Look-through - other 0 0 0 0 0 0 0 0 0 0 570.990 0 4.770.070 175.015 0 0 0 0 0 0 Total exposures (€ thousand) IRB approach: securitisation positions Amounts as at 06/30/2008 On-Balance-Sheet risk assets WEIGHTING FACTORS Off-Balance-Sheet risk assets Pre-payment clauses "in house" securitisations third party securitisations "in house" securitisations third party securitisations "in house" securitisations Securitisation type Securitisation type Securitisation type Securitisation type Securitisation type Traditional Synthetic Traditional Synthetic Traditional Synthetic Traditional Weighting 6-10% 0 10.735.391 442.409 0 0 0 Weighting 12-18% 0 356.026 164.913 100 0 Weighting 20-35% 0 116.600 410.312 100 0 Weighting 50-75% 0 101.922 380.932 0 0 Weighting 100% 0 0 49.309 0 Weighting 250% 0 0 0 0 Weighting 425% 0 35.873 4.201 0 Weighting 650% 0 0 0 Weighting 1250% - with rating 0 0 Weighting 1250% - without rating 0 0 Nc (1) 0 Total exposures 0 Synthetic Traditional Synthetic 350.487 0 0 5.619 0 0 160.418 0 0 83.990 0 0 0 95.873 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 963.491 40.889 98.651 0 1.223 7.886.120 0 0 0 12.309.303 1.492.965 98.851 0 1.223 8.582.507 0 0 0 Securitized assets for €827.067 thousand has been deducted from regulatory capital. 118 Table 11 – Market risks: disclosures for banks using the internal models approach (IMA) for position risk, foreign exchange risk and commodity risk Qualitative disclosure Interest Rate Risk – Trading Book General Regulatory trading book interest rate risk arises when financial positions are taken by specialist centres holding assigned market risk limits within certain levels of discretion. Following the absorption of the Capitalia group in October 2007, the risk positions held in the latter’s trading book were initially controlled and managed by pre-existing units. Positions have moved out of Capitalia and transferred to HVB’s Italian branch all along the year, while risk exposures are gradually reduced. In performing cash management duties, or in the integrated management of the Group’s liquidity, the interest rate risk proves to be closely linked to market maker activities on money market products and related derivatives. Active participation in auctions for government securities issued by the main European countries — as a primary dealer rather than as a market maker — is a source of interest rate risk, owing also to both directional positions in fixed income securities taken on the property portfolio and to relative value strategies employed by individual desks. This risk is managed by recourse to derivatives traded on regulated markets or, in their absence, with innovative and complex products traded over-the-counter with individual counterparties. Interest Rate Risk Management Processes and Measurement Methods Within the organizational context described above, the policy implemented by the UniCredit Group within the scope of market risk management — and so, specifically, in managing interest rate risk — is aimed at the gradual adoption and use of common principles, rules and processes in terms of appetite for risk, ceiling calculations, model development, pricing and risk model scrutiny. Group Market Risk Dept is specifically required to ensure that principles, rules and processes are in line with industry best practice and consistent with standards and uses in the various countries in which they are applied. The main tool used by the UniCredit Group to measure market risk on trading positions is Value at Risk (VaR), calculated using the Historical simulation method. During this phase of convergence, however, some companies belonging to the Group still use a Monte Carlo-type simulation approach. The Historical simulation method provides for the daily revaluation of positions on the basis of trends in market prices over an appropriate observation period. The empirical distribution of profits/losses deriving there from is analyzed to determine the effect of extreme market movements on the portfolios. The distribution value at the percentile corresponding to the fixed confidence interval represents the VaR measurement. The parameters used to calculate the VaR are as follows: 99% confidence interval; 1 day time 119 horizon; daily update of time series, which can be extended to cover at least a year. Use of a 1-day time-horizon makes it possible to make an immediate comparison between profits/losses realized. As for internal scenario analysis policies and procedures (so called “stress testing”), these procedures have been entrusted to the individual legal entities. Overall, however, a set of scenarios common to the Group as a whole, is applied to all positions in order to check on a monthly basis the potential impact that their occurrence could have on the global trading portfolio. In aggregating the various risk profiles of the different risk taking units of the Group, the diversification arising from positions taken by group companies which have adopted different internal models has conservatively been disregarded when calculating the overall risk. The harmonization of VaR methodologies and the definition of an appropriate consistent framework to come to the calculation of a Group’s VaR is one of the main targets of the Market Risk reorganization within the group. Price Risk – Trading Book General information As described in paragraph “Interest Rate Risk – Trading Book” above, price risk relating to equities, commodities, UCITS and related derivative products included in the trading book, originates from positions taken by specialist centres holding assigned market risk limits within certain levels of discretion. Price risk deriving from own trading of these instruments is managed using both directional and relative value strategies via direct sale and purchase of securities, regulated derivatives and OTCs and recourse to security lending. Volatility trading strategies are implemented using options and complex derivatives. Price Risk Management Processes and Measurement Methods For both a description of internal processes for monitoring and managing risk and an illustration of the methodologies used to analyse exposure, please refer in paragraph “Interest Rate Risk – Trading Book” on internal models. Price Risk – Banking Book General Aspects, Price Risk Management Processes And Measurement Methods Banking book price risk primarily originates in equity interests held by the Parent company and its subsidiaries as a stable investment, as well as units in mutual investment funds not included in the trading book in so far as they are also held as a stable investment. Just in respect of these last instruments, internal price risk management and measurement processes reproduce what has already been said with regard to the regulatory trading book. 120 Exchange Rate Risk General Aspects, Exchange Rate Risk Management Processes and Measurement Methods As it has already been said in the previous in paragraph “Interest Rate Risk – Trading Book”, exchange rate risk also originates from positions taken by specialist centres holding assigned market risk limits within certain levels of discretion. Exchange risk originates from currency trading activities performed through the negotiation of the various market instruments, and is constantly monitored and measured by using internal models developed by group companies. These models are, in addition, used to calculate capital requirements on market risks corresponding to this type of risk. Hedging Exchange Rate Risk The Parent company implements a policy of hedging profits created by the Group’s Polish subsidiaries (which constitute the main subsidiaries not belonging to the euro zone), as well as dividends relating to the previous year, said policy being activated during the period between year-end and the payment date. This hedging policy is implemented using foreign exchange derivative products aimed at protecting against fluctuations in the Euro/Zloty exchange rate. Internal Model for Price, Interest Rate and Exchange Rate Risk of the Regulatory Trading Book In its capital calculation and risk monitoring functions, UniCredit adopts the internal models used by former UBM (now HVB Milan Branch), HVB AG and BA-CA AG and approved by the respective national supervisory authorities. For the purposes of calculating capital requirements, the internal model method has been authorized for full use for HVB AG and BA-CA AG, whilst in the case of HVB Milan Branch, model cover for regulatory purposes does not include structured credit products. No recourse is made, on the other hand, to the internal model for calculating capital requirements regarding trading positions in relation to the Parent company, UCI Ireland and Bank Pekao. The standardized measurement method is also applied to the calculation of capital covering the risk of holding banking book exposure in foreign currencies for the subsidiaries that do not perform trading activities. The characteristics of the internal models are as follows: Former UBM (now HVB Milan Branch): historical simulation based on a one-year historical observation period, with VaR calculated as 1-day expected loss with 99% double tail confidence level. Option-related risk is estimated by using the delta-gamma-vega approximation. HVB AG: Monte Carlo simulation with the full evaluation of individual positions taken in options, with VaR calculated as 1day expected loss with 99% confidence level. The Monte Carlo simulation is based on a variance-covariance matrix calculated on a one-year historical observation period without weighting scheme. BACA AG: Declustered3 historical simulation based on a two-years historical observation period with VaR calculated as 1-day expected loss with 99% confidence level and with the full evaluation of individual positions taken in options. Trading portfolios are subject to stress tests according to a wide range of scenarios for managerial reporting, which are described in paragraph “Independent price verification process” below. According to the national regulations, some relevant scenarios are also - 3 Historical returns for each risk factor are weighted by the ratio between the current volatility and the historical volatility. 121 matter of regulatory reporting on a quarterly basis. Moreover, substituted risk measures, i.e. sensitivities, defined stress scenarios or the indication of nominal amounts, are considered and included in the regulatory reporting for the estimation of risks that are not covered by the VaR simulation of HVB internal model. Apart from use in calculating capital requirements on market risks, internal models are applied to all positions included in the trading book to perform back testing, through the continuous comparison of the bank’s daily VaR measures with the subsequent daily profit or loss. This test consists of comparing the estimated expected loss with clean P&L data, i.e. simulated changes in portfolio value that would occur were end-of-day positions to remain unchanged. Stress Testing Stress tests complement the sensitivity analysis and VaR results in order to assess the potential risks in a different way. Stress test performs the evaluation of a portfolio under both simple scenarios (assuming change to single risk factors) and complex scenarios (assuming simultaneous changes in a number of risk factors). Results for simple scenarios are reported to top management on a weekly basis, together with the most relevant sensitivities. They include shocks on: Interest rates: Parallel shifts and Steepening/Flattening of IR curves; Increase/Decrease in IR volatilities Credit Markets: Parallel shifts of Credit Spreads curves (both absolute changes and relative changes); sensitivity to Base Correlation, Issuer Correlation and Recovery Rates Fx Rates: Appreciation/Depreciation of each currency; Increase/Decrease in FX volatilities Equities: Increase/Decrease in Spot Prices; Increase/Decrease in Equity volatilities; sensitivity to Implied Correlation Commodities: Increase/Decrease in Spot Prices As far as complex scenarios are concerned, so far, two different recession scenarios (mild and severe) are applied to the whole MIB portfolio on a monthly basis and reported to top management. “Recessionary Fears” Scenario This scenario presumes the spreading of US recessionary fears possibly affecting the rest of the world by a “contagion effect”. In terms of macro-economic variables, this scenario assumes: Stock markets slowing (fall) related to an increase in equity volatilities; A comprehensive decrease in interest rates (different stress factors depending on the maturity) with a principal focus on the short term, and an even stronger stress scenario on the US (also different stress factors depending on the maturity). In this scenario also an increase in interest rate volatility is assumed; A dramatic and comprehensive widening of credit spreads with different stress factors depending on rating and industry class. 122 “Full US Recession” Scenario This scenario assumes a severe US recession affecting also the rest of the world by a “contagion effect”. In terms of macroeconomic variables this scenario assumes: A dramatic decrease in equity stocks prices and indices either on the US and non-US markets associated to an equity volatility increase; A dramatic US (different stress factors depending on the maturity) and non-US (different stress factors depending on the maturity and geographic area) interest rate decrease each also associated to an increase in interest rate volatility; A dramatic and comprehensive widening in credit spreads depending on rating and industry class. Independent price verification process In this respect, further to the market turmoil following the sub-prime mortgages’ meltdown and the subsequent uncertainties in the valuation of most of the Structured Credit Products, the Holding Company (HC) Group Market Risk function in a joint effort with Risk Control functions at the Legal Entity (LE level established to: 1. centralize the Independent Price Verification (IPV) process for such products in the Risk Control function of HVB London branch which has been elected as the group’s “competence centre” for the evaluation of complex structured credit products, i.e. ABS, CDO, CLO, CDO of ABS etc which represent the various sectors. 2. harmonize the IPV methodology across the group defining a consistent approach based on the ranking of to each single position according to the availability and relative reliability of available price sources. As a consequence all such positions have been treated and valued uniformly at the group level including Bank of Austria Credit Anstalt ’s (BACA) and UCI Ireland’s 3. define and develop a proper methodology to apply specific Fair Value Adjustments to such valuations. The chosen approach is essentially based on the above ranking of price sources and define specific stress tests for market valuations, the wider the less reliable is the ranking through their respective sensitivity to a one-notch downgrade 4. the whole process has been shared and developed within the framework of the established cooperation model between all CRO (Chief Risk Office) functions either at the HC as well as at the LE level and the HC and LE CFO (Chief Financial Office) functions, responsible for the accounting treatment of such valuations and adjustments. 123 Liquidity risk General aspects, operational processes and methods for measuring liquidity risk Definition and Sources of Liquidity Risk Liquidity risk is a term used to indicate the possibility that a bank may encounter difficulties in meeting expected or unforeseen cash payments or delivery obligations, thereby impairing daily operations or the financial condition of the bank. The UniCredit Group defines liquidity risk components as follows: 1. Liquidity mismatch risk: the risk that the amounts and/or timing of cash inflows and outflows will not coincide; 2. Liquidity contingency risk: the risk that unexpected future events may require a greater than expected amount of liquidity. This risk can be generated by events such as loans not being repaid, the need to finance new operations, difficulty in selling liquid assets or obtaining cash in times of crisis. 3. Market liquidity risk: the risk that the bank may liquidate assets at a loss due to market conditions. This risk is managed by those responsible for the different trading portfolios and is measured and monitored in accordance with market risk management criteria. 4. Operational liquidity risk: the risk that a party will not meet payment obligations due to errors, breaches, failures or damage due to internal processes, people, systems or external events, while still remaining solvent; 5. Funding risk: the risk of a potential increase in the cost of funding due to changes in an entity’s rating (internal factor) and/or a widening of credit spreads (market factor); 6. Margin calls liquidity risk: this refers to a situation in which the bank is contractually required to provide new collateral and/or margin payments to cover its financial instrument positions. Basic Principles of the Liquidity Risk Management Model and the Units Responsible for LRM The Group’s objective is to fund its operations at best interest rate conditions under normal operating circumstances and to remain in a position to meet payment obligations in the event of a liquidity crisis. The basic principles underlying the Group’s internal liquidity management are as follows: 1. Centralization of liquidity management functions 2. Diversification of sources of funding based on geographic location, counterparties, currency and funding instruments 3. Management of short-term liquidity in accordance with the applicable regulatory framework in the countries where the Group operates 4. Issuance of financial instruments in order to meet prudential capital ratio targets. This methodological and operational framework is part of the Group Liquidity Policy, which was drawn up by the Group’s Finance Area in concert with the Group’s Group Market Risk function and adopted by all Group entities. The Group’s liquidity management rules are based on two principles. 1. Short-term liquidity management, the purpose of which is to ensure that anticipated and unforeseen obligations to make cash payments are met by maintaining a sustainable balance between inflows and outflows. Management in this area is an essential condition to ensure the continuity of day-to-day banking operations; 124 2. Management of structural liquidity, the purpose of which is to maintain an appropriate balance between overall liabilities and medium- to long-term assets in order to avoid pressures on current and future short-term liquidity sources. Group liquidity risk management functions are carried out by the Group HQ’s Finance Area, which falls under the responsibility of the Group’s Chief Financial Officer (CFO). The Market Risk Management Area, headed by the Group’s Chief Risk Officer (CRO), is charged with setting and monitoring operating limits. Group HQ manages the Group’s liquidity, ensuring that consolidated thresholds are met and setting out the relevant tactical and structural funding strategies. If any of the Group’s banks or companies experiences liquidity problems, Group HQ is also responsible for implementing, managing and coordinating the Group’s Liquidity Contingency Plan. In performing these duties, Group HQ works with the Regional Liquidity Centres, i.e. – under the Liquidity Policy – the Liquidity Centre for Italy, Milan; Liquidity Centre for Germany, Munich; Liquidity Centre for Austria and CEE banks, Vienna; and Liquidity Centre for Poland, Warsaw. Regional Liquidity Centres are responsible at local level for all the banks and companies included in their consolidation scope and act as “sub-holding” companies by receiving and managing cash flows. In addition to ensuring compliance with local liquidity policies and regulatory requirements imposed by national regulators. Regional Liquidity Centres are responsible for optimising funding activities in their markets and with their customers through functional specialisation. Net cash flows from the Group’s Regional Liquidity Centres are concentrated and managed at the parent company level. The latter employs a centralised management system for cash flows. This centralised approach to liquidity risk management aims to: 1. Reduce overall borrowing requirements from non-Group counterparties and 2. Optimize access to liquidity markets by leveraging the Group’s credit rating and minimizing funding costs. Methods and Tools Regional Liquidity Centres run daily cash flow reports to measure short-term liquidity risk. These reports are then assessed against available liquid asset reserves, consisting primarily of the most liquid securities available. In addition, several stress scenarios are simulated based on liquidity profiles. The Group’s structural liquidity management is aimed at ensuring its financial equilibrium in terms of maturities with a time horizon greater than one year. Typical measures taken for this purpose are as follows: 1. Lengthening its liabilities maturity profile in order to reduce dependence on less stable sources of funding, while at the same time optimizing the cost of funding (integrated management of strategic and tactical liquidity); and 2. Reconciling medium- to long-term wholesale funding requirements with the need to minimize cost by diversifying the sources of funding, national markets, currencies of issuance and the instruments used (in accordance with the Funding Plan). On the basis of its structured liquidity policy, the Group has kept as a guiding principle that of moderate maturity transformation. Risk Monitoring and Financial Planning The duty of monitoring the Group’s liquidity risk position has been entrusted, on the basis of their role and functions, to the Treasury, Asset Liability Management and Market Risk Management Units of each Group entity and at Group HQ. 125 This is performed at Group level and consists of analysis, classification and management of the cash flow gap for all maturities together with a check on observance of limits using appropriate methods and frequency according to the level of analysis (daily for short-term liquidity and monthly for structural liquidity). Short-term liquidity is monitored using a maturity ladder showing all cash flows with daily maturities starting from overnight up to 1 year. Structural liquidity is monitored by incorporating a dynamic projection of business growth in terms of customer loans and deposits. The Group’s annual financial plan is drafted through a planning process that is consistent with the criteria applied in setting out budget objectives and complies with regulatory requirements. Liquidity Stress Tests Liquidity stress testing is the technique used to evaluate the potential effects on an institution’s financial condition of a specific event and/or movement in a set of financial variables. As a forward looking tool, liquidity stress testing diagnostic the institution’s liquidity risk. The results of the liquidity stress tests are used to 1) assess the adequacy of liquidity limits; 2) planning and implementing alternative sourcing transactions; 3) structuring or modifying the liquidity profile of the Group’s assets; 4) setting additional criteria with the objective of determining an appropriate structure and composition of the Group’s assets; 5) providing support to the development and upgrade of the liquidity contingency plan. In order to execute stress tests that are consistent across the Liquidity Centers, the Group has a centralized approach to stress testing, requiring each Regional Liquidity Center to run the same scenario set under the coordination of the Group CRO through the activation of local procedures. Liquidity stress scenarios are related to either market or name related crisis. The Group runs liquidity scenarios and sensitivity analyses, the latter assessing the impact on an institution's financial condition of a move in one particular risk factor, the source of the shock not being identified, whereas scenario tests tend to consider the impact of simultaneous moves in a number of risk factors, the stress event being well defined. Liquidity Contingency Plan The objective of the Liquidity Contingency Plan (LCP) is to safeguard the Group’s assets from losses or risks which may arise as a result of a liquidity crisis. In the event of the occurrence of an actual crisis, the LCP is aimed at ensuring effective intervention starting from the very outset of the crisis, through the clear identification of individuals, powers, responsibilities and potential actions with a view to increase significantly the probability of successfully overcoming the state of emergency. 126 Table 12 – Operational risk Qualitative disclosure UniCredit Group received the approval from the Bank of Italy to use the Advanced Measurement Approach (AMA) for the operational capital at risk calculation. As of 30 June 2008, the AMA covers 62% of the Group considering the relevant indicator (i.e. gross margin), the roll out plan set the time schedule for the extension of the method to all relevant Group legal entities and it will be completed by 2012. The subsidiaries that at the moment are not yet AMA compliant apply TSA or BIA method to calculate the capital at risk. UniCredit Group (UCG) developed an internal model for measuring the capital at risk for its AMA compliant subsidiaries. The operational risk profile of UCG is reliably covered by the analysis of internal loss data. External data (consortium and public data) properly captures the effects of extreme events, which are typically not present in internal data. The inclusion of scenario data and key risk indicators provides a forward looking element in the operational risk capital model. Capital at risk is calculated per event type class. For each risk class, severity and frequency of losses are separately estimated to obtain the annual loss distribution through simulation. Based on internal loss data and expert opinion, the probability of coverage, the single and aggregate limit, and the single and aggregate deductible of relevant insurance contracts is obtained. The possibility of insurance payments is then taken into account in the Monte Carlo simulation of the aggregate yearly loss. The severity distribution is estimated on internal, external and scenario generated data, while the frequency distribution is determined using only internal data. An adjustment for key operational risk indicators is applied to each risk class. The dependence structure between the different event types is derived from internal data. From the annual aggregated loss distributions for each risk class, the overall annual loss distributions is obtained by aggregating the distributions through a t-Student copula based method. Capital at risk is calculated at confidence level of 99.9% on the overall loss distribution for regulatory purposes. The 99.97% confidence level for economic capital is deduced from the regulatory one by applying a scaling function based on external loss data. By the allocation mechanism, the individual legal entities’ capital requirements are identified, reflecting the Legal Entities’ risk exposure and risk management effectiveness. Operational Risk Management function is involved in the process of analyzing the insurance policies, supporting the analysis concerning operational risk exposure, effectiveness of deductibles and limits. National discretions still hold, even if a set of policies have been grouped at sub-holding level. Most common risks that are covered are damage to physical assets, frauds and liability. As a general approach higher limits and deductibles are preferred instead of lower deductibles, even if local discretion by minor subsidiaries is accepted. 127 Table 13 – Equity exposures: disclosures for banking book positions Qualitative disclosure Description of accounting techniques and valuation methodologies Available-for-sale Financial Assets (AfS) On initial recognition, an AfS financial asset is measured at fair value plus transaction costs and income directly attributable to the instrument, less fees and commissions. In subsequent periods available-for-sale financial assets are measured at fair value, the amount of amortised cost being recognised through profit or loss. Gains or losses arising out of changes in fair value are recognised in equity item 140 “Revaluation reserves” except losses due to impairment which are recognised in item 80 “Gains (losses) on financial assets and liabilities held for trading” until the financial asset is sold, at which time cumulative gains and losses are recognised in profit or loss in item 100(b) “Gains (losses) on disposal or repurchase of AfS financial assets”. Equity instruments (shares) not listed in an active market and whose fair value cannot be reliably determined are valued at cost. If there is objective evidence of an impairment loss on an available-for-sale financial asset, the cumulative loss that had been recognized directly in equity item 140 “Revaluation reserves”, is removed from equity and recognised in profit or loss under item 130(b) “Impairment losses (b) Available for sale financial assets”. The amount that is removed is the difference between carrying amount (acquisition cost less any impairment loss already recognised in profit or loss) and current fair value. Impairment losses recognised in profit or loss for an investment in an equity instrument classified as available for sale are not reversed through profit or loss, but recognised at equity, even when the reasons for impairment no longer obtain. Financial Instruments at Fair Value through Profit and Loss (FIaFV) Equity instruments booked in FIaFV portfolio are accounted for in a similar manner to HfT financial assets, however gains and losses, whether realised or not, are recognised in item 110 “Gains (losses) on financial assets and liabilities measured at fair value”. In FlaFV portfolio have not to be booked investments in equity instruments for which there is no price quoted in active markets and whose fair value cannot be reliably determined; 128 (€ thousand) Banking portfolio: exsposures in equity instruments and funds Amounts as at: 06/30/2008 Items Balance-sheet amounts Listed Fair value Unlisted Listed Gains and losses on disposals/repurchases Market value Unlisted Listed Gains Unrealized capital gains/losses Losses Capital gains Capital losses Unrealized capital gains/losses included in Tier 1/Tier 2 Capital gains Capital losses A. Equity instruments A.1 Shares A.2 Innovative capital instruments A.3 Other equity instruments 695.064 2.002.374 677.613 1.824.212 677.613 25.623 -219 15.316 -586 1.582.481 -1.624.343 0 0 0 0 0 0 0 0 0 0 0 155 1.158.039 155 1.229.692 155 13.325 -103 483 -1.093 0 0 27.310 228.371 27.310 228.371 27.310 0 0 3.230 -1.408 0 0 2.348 0 2.348 0 2.348 0 0 0 -158 0 0 0 B. Investments funds B.1 Under Italian law - harmonized open-ended - non harmonized open-ended - closed-ended - reserved - speculative B.2 Other UE Countries - harmonized - non harmonized open-ended - non harmonized closed-ended B.3 Non EU countries - open-ended - closed-ended Total 0 2.107 0 2.107 0 0 0 0 0 0 24.962 201.770 24.962 201.770 24.962 0 0 2.723 -1.250 0 0 0 6.415 0 6.415 0 0 0 0 0 0 0 0 18.079 0 18.079 0 0 0 507 0 0 0 363.098 2.017.244 363.092 2.017.299 363.092 2.144 -1.366 3.385 -1.032 0 0 319.175 73.188 319.169 73.243 319.169 830 -1.366 2.972 -903 0 0 43.923 1.887.542 43.923 1.887.542 43.923 1.314 0 413 -129 0 0 0 56.514 0 56.514 0 0 0 0 0 0 0 61.424 224.524 61.424 222.409 61.424 86 -85 1.029 -2.455 0 0 61.078 224.524 61.078 222.409 61.078 86 -85 1.029 -2.455 0 0 346 0 346 0 346 0 0 0 0 0 0 1.147.051 5.630.552 1.129.594 5.521.983 1.129.594 41.178 -1.773 23.443 -6.574 1.582.481 -1.624.343 Categories Private equity exposures in sufficiently diversified portfolios Exchange-traded equity exposures Balance-sheet amounts as at 06/30/2008 3.035.850 423.058 Other equity exposures 3.318.688 Total Equity Exposures 6.777.603 Table 14 – Interest rate risk on positions in the banking book Qualitative disclosure Interest Rate Risk – Banking Book General Aspects, Interest Rate Risk Management Processes and Measurement Methods Interest rate risk consists of changes in interest rates that are reflected in: Interest income sources, and thus, the bank’s earnings (cash flow risk); The net present value of assets and liabilities, due to their impact on the present value of future cash flows (fair value risk). The Group measures and monitors interest rate risk on a daily basis within the framework of its banking book interest rate risk policy which defines methods and corresponding limits or thresholds of interest margin sensitivity and economic value for the Group. Interest rate risk affects all proprietary positions arising out of business operations and strategic investment decisions (banking book). The main sources of interest rate risk can be classified as follows: repricing risk - the risk resulting from timing mismatches in maturities and the repricing of the bank’s assets and liabilities; the main features of this risk are: - yield curve risk - risk resulting from exposure of the bank's positions to changes in the slope and shape of the yield curve - basis risk - risk resulting from the imperfect correlation in lending and borrowing interest rate changes for different instruments that may also show similar repricing characteristics; optionality risk – risk resulting from implicit or explicit options in the Group’s banking book positions. Some limits have been set out, in the above described organization, to reflect a risk propensity consistent with strategic guidelines issued by the Board of Directors. These limits are defined in terms of VaR, Sensitivity or Gap Repricing for each Group bank or company, depending on the level of sophistication of its operations. Each of the Group’s banks or companies assumes responsibility for managing exposure to interest rate risk within its specified limits. Both micro- and macrohedging transactions are carried out for this purpose. At the consolidated level, Group HQ's Asset Liability Management Unit takes the following measures: It performs sensitivity analysis in order to measure any changes in the value of shareholders' equity based on parallel shocks to rate levels for all time buckets along the curve. Using static gap analysis (i.e., assuming that positions remain constant during the period), it performs an impact simulation on interest income for the current period by taking into account different elasticity assumptions for demand items. It analyses interest income using dynamic simulations of shocks to market interest rates. It develops methods and models for better reporting of the interest rate risk of items with no contractual maturity date (i.e. demand items) or with prepayment features. In coordination with the ALM and Treasury Areas, the Market Risk Management Area sets interest rate risk limits using VaR methodologies and verifies compliance with these limits on a daily basis. Fair Value Hedging Hedging strategies aimed at complying with interest rate risk limits for banking portfolio, are carried out with derivative contracts, listed or not listed – the last ones, commonly interest rate swaps, are the most used kind of contracts. The hedges used are generally of the generic type, i.e. connected to monetary amounts contained in asset or liability portfolios. Sometimes the effects of specific accounting hedges are recognized in connection with securities in issue or individual financial assets, especially if held as available for sale assets. Cash Flow Hedging Sometimes cash flow hedges are used as an alternative to fair value hedges to stabilize current and future income statement results. Macro-hedging strategies are generally used and are in most cases designed for interest rate risk of the core portion of financial assets “on demand”. According to the Italian regulatory requirement (Circolare 263_2006, Titolo IV, Tavola 14 - b ), UCI Group reports the effect of an unexpected, either negative or positive, interest rate shock with a break down into the main currencies, respecting the managerial view and assumptions on the banking book portfolio as described above: Group Wide Interest Rate Risk in the Banking Book Stress Test As at June 30, 2008 (€ million) -150bps 131 +200bps Total 775 -1.042 AUD CHF CZK EUR GBP HRK HUF JPY PLN RON RUB SKK TRY USD Others 2 -19 -4 324 -13 24 8 -1 238 5 2 -3 26 180 5 -2 25 5 -440 17 -31 -11 1 -317 -7 -3 3 -35 -240 -7 Glossary / Abbreviations ABCP Asset-backed commercial paper ABS Asset-backed securities AMA Advanced measurement approach, applying this methodology the operational risk requirement is obtained with calculation models based on operational loss data and other evaluation elements collected and processed by the bank. Admittance threshold and specific suitability requirements have been provided for the use of the standardized and advanced approaches. For the AMA approach the requirements concern, beside the management system, also the measurement system CCF Credit conversion factor CIU Collective investment undertakings CRD Capital requirements Directive, EU directives n. 2006/48 and 2006/49, acknowledged by the Bank of Italy with its circular letter n. 263/2006 and following updates CRM Credit risk mitigation EAD Exposure at default ECA Export credit agency ECAI External credit assessment institution EL Expected loss IAA Internal assessment approach ICAAP Internal Capital Adequacy Assessment process; the discipline of the so called “Pillar 2” requires the banks to implement processes and systems to determinate the level of internal capital adequate to face any type of risk, also different from those provided by the capital requirements (Pillar 1) rules; in the scope of an assessment of the exposure, actual and future, that has to consider also the strategies and the evolution of the reference environment IMA Internal Models Approach (market risk) IRB Internal ratings-based approach LGD Loss given default M Effective maturity MDB Multilateral development bank OTC Over the Counter (derivative contracts) PD Probability of default RBA Ratings-based approach RUF Revolving underwriting facility SF Supervisory formula SL Specialised lending 132 SME Small- and medium-sized entity SREP Supervisory Review and Evaluation Process; this process is conducted through interaction with the banks and the use of the supervisor’s system for analyzing and assessing the banks subject to its supervision. The dialogue with banks enables supervisors to acquire a more extensive understanding of the ICAAP and the methodological hypotheses underpinning it, while giving banks the opportunity to describe the rationale supporting their capital adequacy assessments. Where necessary, the supervisory authorities can require the banks to adopt corrective measures, in the form of organizational improvements or additional capital, indicating the measures most appropriate to the circumstances from among the range of those available UCITS Undertakings for collective investments in transferable securities UL Unexpected loss VaR Value at risk 133
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