Agreement No. 11 (2017): Guidelines for Operations with Financial Derivative Instruments

Republic of Panama
Superintendency of Banks
AGREEMENT No. 011-2017
(of December 26, 2017)
“By which guidelines are established for operations with financial derivative instruments”

THE BOARD OF DIRECTORS

In exercise of its legal powers, and

CONSIDERING

That following the issuance of Decree-Law No. 2 of February 22, 2008, the Executive Branch elaborated a systematic ordering in the form of a Single Text of Decree-Law No. 9 of 1998 and all its modifications, which was approved by Executive Decree No. 52 of April 30, 2008, hereinafter the Banking Law;

That in accordance with the provisions of paragraphs 1 and 2 of Article 5 of the Banking Law, it is the objective of the Superintendency of Banks to ensure the maintenance of the solidity and efficiency of the banking system; as well as to strengthen and foster the conditions conducive to the development of the Republic of Panama as an international financial center;

That in accordance with paragraph 5 of Article 11 of the Banking Law, it corresponds to this Board of Directors to establish, within the administrative scope, the interpretation and scope of legal or regulatory provisions in banking matters;

That operations with financial derivative instruments have experienced significant growth, both in terms of the volumes traded of basic derivatives, forwards, options, and interest, currency, and credit swaps, as well as in the volume traded of complex instruments, structured notes, and structured credit products;

That the increase in the complexity of these instruments or operations is a critical factor in terms of risk, as it impacts relevant aspects of the financial risk management of banks;

That in working sessions of this Board of Directors, the need and convenience of establishing prudential regulatory norms that favor and incentivize good practices in the handling of financial derivative instruments by banking entities has been manifested.

AGREES:

CHAPTER I
SCOPE OF APPLICATION AND DEFINITIONS

ARTICLE 1. SCOPE OF APPLICATION. This Agreement applies to:

1. Official banks.
2. General license banks.
3. International license banks.

ARTICLE 2. DEFINITIONS. For the purposes of this Agreement, the following concepts shall be understood as follows:

1. Derivative Instrument: It is a financial instrument whose fair value depends on one or more underlying variables and its settlement is carried out on a future date, that is, different from the date considered by agreement as the spot settlement date of the operation. Such settlement may be in cash, in financial instruments, or in tradable products or goods, as established in the contract or in the corresponding regulations of the securities trading system, the securities operations registration system, or the securities clearing and settlement system.

A financial derivative instrument allows for the administration or assumption of one or more risks associated with the underlyings and meets either of the following two (2) alternative conditions:
a. Does not require a net initial investment. b. Requires a net initial investment lower than that which would be needed to acquire instruments that provide the same expected payment in response to changes in market factors.

2. Forward: Over-the-counter (OTC) financial contracts, in which the two parties agree to exchange, on a future date, a specific amount of a specific product (stocks, bonds, currencies, commodities) for a predetermined exercise price initially set in the contract.

3. Forward Rate Agreement (FRA): An OTC contract settled in cash on a future date, based on a nominal amount, a market interest rate, a reference term, and an exercise interest rate agreed upon on the date of negotiation of the contract. The settlement is determined based on the difference in interest calculated on the nominal amount, with the market interest rate and the agreed interest rate, and with respect to the reference term. The contract also specifies how the market interest rate is determined.

4. Financial Futures: Financial contracts in which the two parties agree to exchange, on a future date, a specific amount of a specific product for a determined price. Futures are forwards traded on stock exchanges through standardized contracts regarding quantities and maturity dates. Futures contracts are settled daily through the stock exchange with losses and gains for the parties to the contract. The most common underlyings are commodities, oil, currencies, interest rates, stocks, and stock indices. There are several possible maturity dates for negotiating contracts, but each negotiated contract has a single maturity date. The stock exchange regulations determine the nature and amount of guarantees that the parties must provide and the rules for adjusting the amount of guarantees to risks.

5. Interest Swaps: Contracts traded in OTC markets in which the two parties agree to exchange cash, on agreed dates, on nominal amounts, generally equal, defined in the contract, corresponding to interest calculated with a fixed interest rate established in the contract versus interest calculated with a market interest rate that is determined over the life of the swap. The amount of interest is determined by the nominal amount, the applied interest rate, and the term corresponding to each interest settlement period.

6. Currency Swaps: Currency swap contracts are traded in OTC markets, and in them the parties agree to the exchange of amounts of cash in different currencies on dates established in the contract until the maturity date. Frequently, the cash amounts correspond to interest, calculated with the interest rates of each currency and as established in the contract. The notionals used for the calculation of interest are initially determined by the spot exchange rate of the date of the transaction. The notionals are usually exchanged at the end of the contract.

7. Options: Contracts in which rights, but not obligations, are purchased on future cash flows, or their equivalent. The seller of the right does have the obligation if the buyer exercises the right. The rights refer to receiving a cash amount on one or more future dates or to being able to buy or sell certain financial instruments at a price established in the contract, on one or more future dates. The price of the rights is called the premium or option price. Options are traded both on stock exchanges and in OTC markets. There is a wide variety of options, and here the most traded are defined:

7.1. Standard European Options: There are two modalities, the call option and the put option. In the standard European call option, the buyer purchases the right to buy a specific amount of product at a price (exercise price) established in the contract, on the maturity date. In the standard European put option, the buyer purchases the right to sell a specific amount of product at an exercise price established in the contract on the maturity date.

7.2. Standard American Option: This option differs from the European one in that the exercise of the option is not limited to the maturity date of the option, but can be on any business date from the negotiation date of the option until the maturity date.

7.3. Bermuda Option: The way of defining the right coincides with the standard European option except that in this option, settlement can be demanded on a number of intermediate dates between those allowed by the American option and the European option.

7.4. Exotic Options: Any option that differs from the three above is called exotic. Below, the most important are defined:

a. Digital Option: Settled by a fixed amount, determined on the negotiation date. Digital options can be call or put, depending on whether the right is exercised when the underlying variable has a value greater than the exercise value or when the underlying variable has a value lower than the exercise value, both on the maturity date of the contract.

b. Range Option: Settled by a fixed amount, determined on the negotiation date. The option is exercised if the underlying variable is located, on the maturity date of the contract, within a range of values determined on the negotiation date of the option.

c. Asian Average Price Option: Settled according to the average price of the underlying instrument. The average is defined either as arithmetic mean or as geometric mean. The frequency (daily, weekly, monthly, among others) for the calculation of the average is defined in the contract.

d. Asian Average Exercise Price Option: The exercise price is defined on the maturity date by the average, arithmetic or geometric, of prices. The frequency (daily, weekly, monthly, among others) for the calculation of the average is defined in the contract.

e. Lookback Option: Settled at maturity based on the maximum (or minimum) reached by the underlying in a certain period.

f. Barrier Option: The settlement of the option is the same as standard European options, but subject to an additional condition, called a barrier, which is a certain level of the underlying variable determined in the contract. There are many different modalities of barrier options. The fundamental aspect is that the fact that the behavior of the

underlying variable, in the case that it reaches the barrier or never reaches it, conditions the exercise of the right.

g. Basket Option: Settlement is based on a weighted average of different underlyings.

h. Exchange Option: In settlement, one asset is exchanged for another.

i. Quanto Option: An option that is settled in a currency different from that in which the underlying financial instrument is denominated, at an exchange rate determined on the start date of the contract.

8. Credit Derivatives: Credit derivatives are contracts that allow the buyer of protection to transfer the credit risk of a certain underlying instrument, or a portfolio of underlying instruments, to the seller of protection without the sale of the underlying instrument. Generally, the buyer is the owner of the underlying instrument, but not necessarily.

The most traded credit derivative is the credit default swap, which has a single underlying instrument. The buyer of protection pays periodically to the seller of protection an amount called the contract premium, resulting from multiplying the nominal of the contract by a determined percentage, until the maturity date of the contract, or until a credit event occurs under the terms defined in the contract. In the latter case, the contract is settled, either by the cash payment of the nominal by the seller to the buyer and the delivery of the underlying instruments with the same nominal amount by the buyer to the seller, or it is settled by differences between the nominal of the contract and the market price of the underlying instruments, by cash payment by the seller of protection to the buyer of protection.

9. Structured Instruments: Structured financial instruments are contracts whose cash flows can be reproduced by a portfolio formed by traditional financial instruments and derivative instruments, called implicit derivatives. Traditional financial instruments are generally debt instruments with fixed or variable coupons or without coupons (zero-coupon instruments), while derivatives are usually options, generally exotic. Structured instruments are sometimes marketed under the names of the exotic options that are implicit in the financial structure of the instrument. Structured financial instruments are also called hybrid products.

10. OTC Markets: Over-the-counter (OTC) markets are markets in which financial instruments are traded outside the scope of stock exchanges. Market makers usually exist who set supply and demand prices. Important OTC markets are interbank markets and currency markets. OTC contracts are bilateral agreements between the parties, although master contracts (e.g., ISDA) usually exist to favor the legal security of transactions.

11. Fair Value of a Financial Instrument: It is the amount by which a financial asset could be delivered, or a financial liability settled, between independent parties acting in their own interest (IFRS 39, IFRS 9). The best evidence of fair value will be the market price when that instrument has been traded in an active market. In financial instruments with no active market, valuation techniques will be used whose objective is to establish what the price would have been under conditions similar to those of an active market.

12. Active Market: A financial instrument is considered to be quoted in an active market if quotation prices are easily and regularly available through a stock exchange, financial intermediaries, a sector institution, a price service, or a regulatory body, and those prices reflect current market transactions that occur regularly, between parties acting under conditions of mutual independence.

13. Risks of Derivatives: The position in a derivative instrument exposes the entity to specific risks, whose nature and intensity depend on the use (hedging, trading, intermediation) that the entity assigns to the derivative. The most important risks are:

13.1. Counterparty Risk: The risk of losses because the counterparty fails to fulfill its contractual obligations, both with respect to the derivative contract and the provision and replacement of guarantees.

13.2. Market Risk: The risk of losses due to adverse changes in the valuation of the contract, both throughout the life of the contract and at settlement.

13.3. Liquidity Risk: The risk of losses due to the impossibility of closing a position due to the absence of counterparties, or due to adverse modifications of market prices when attempting to open or close a contract.

13.4. Operational Risk: The risk of losses due to operational events, such as recording errors, accounting, valuation of contracts and calculation of guarantees, and errors in the measurement of risks. Legal risk is very relevant in derivatives, especially in contracts marketed to clients.

13.5. Reputational Risk: The risk of losses due to deterioration of reputation, which may originate from suffering losses in the handling of derivatives, and from claims by clients who have suffered losses with derivatives or structured products marketed by the entity.

The definitions contemplated in this Agreement are examples of the most common derivative instruments and do not constitute an exhaustive and exclusive list.

CHAPTER II
RESPONSIBILITIES AND RISK MANAGEMENT

ARTICLE 3. CORPORATE GOVERNANCE. The board of directors of the bank that carries out operations with derivative instruments and structured products must assume, at a minimum, the following responsibilities:

1. Approve the precise objectives that the entity seeks with operations with derivative instruments, as well as establish the role that derivatives play in the bank's overall business strategy, distinguishing between:
   a. Proprietary positions with the aim of obtaining short-term profits. b. Derivative positions with the objective of hedging a certain risk.
   c. Derivative positions as a counterparty to client positions in which the entity occupies the opposite position, assuming some type of risk.
   d. Investment positions in structured products in which there are implicit or explicit derivatives.

2. Approve the bank's policies and manuals on the management of derivative instruments and structured products, including a risk profile consistent with the bank's strategy. In the job description manual, the specific contents of the different functions and the respective coordination tasks between said functions must be established.

3. Monitor that the internal regulations on derivatives and structured products, and limit policy, are a reality effectively translated into the bank's daily practices and that there is independent internal control that allows for such incorporation.

4. Authorize the use or investment in new derivative instruments and structured products, as well as establish prudential limits, ensuring that before their implementation, the essential systems to support the new operations and sufficient technical capacity in the different functional areas exist.

5. Approve the adequate organizational structure for the management of derivative instruments and structured products, including an effective and independent internal control system,

that enjoys sufficient backing for the development of its function and is endowed with the necessary independence from the business areas.

6. Know and understand the bank's risk exposures in operations with derivative instruments and structured products.

The senior management of the bank that carries out operations with derivative instruments must assume, at a minimum, the following responsibilities:

1. Develop and propose policies for the management of derivative instruments and structured products.

2. Implement the strategies and policies approved by the Board of Directors on derivative instruments and structured products.

3. Know the levels of risk assumed by the bank in operations with derivatives and structured products.

4. Maintain an organizational structure for the management of derivative instruments and structured products, which clearly assigns responsibilities, authority, and hierarchical lines.

5. Establish procedures that ensure an appropriate and timely flow of information on exposures with derivative instruments and structured products, among the different areas involved.

6. Ensure the functioning, effectiveness, and compliance with objectives, procedures, and controls in the management of derivative instruments and structured products.

7. Ensure that training and updating programs are established for personnel involved in the management of derivative instruments and structured products.

8. Daily at market close, information on the position in the different contracts, gains and losses, both valuation and realized, and the estimation of risk assumed according to the different types of risk must be available to senior management, and ensure the consistency of these, with the defined tolerance levels.

The audit or internal control area of each bank is responsible for verifying and monitoring compliance with all requirements established here.

ARTICLE 4. COMPREHENSIVE RISK MANAGEMENT. The bank, within its comprehensive risk management process, must consider all risks associated with the trading of derivative instruments, paying special attention to the following aspects:

1. The valuation of the derivative instrument as a starting point for most risks associated with the trading of derivatives, which the bank must manage; therefore, weaknesses in the field of valuation must be considered in the field of identification, measurement, management, and control of risks.

2. In the measurement of market risks, the liquidity factor must be taken very seriously to avoid underestimating risks.

3. The management of counterparty risks requires their adequate identification and measurement, and the implementation of an adequate guarantee and collateral policy to the assumed risk exposure. In addition, the monitoring of the valuation of guarantees and procedures to achieve the adequacy of the value of guarantees, both due to changes in the value of the derivative and of the guarantee itself.

4. Banks must identify operational risks and design appropriate policies to neutralize their effects. In particular, they must pay special attention to legal risks linked to the interpretation and fulfillment of contracts, recording risks, accounting of operations, and model risks, both for valuation and for risk measurement, to name the most important.

5. It is necessary to strengthen the risk and internal control unit so that they identify, with the greatest precision, what type of use of derivatives the bank makes and what level of exposure it has to different risks.

ARTICLE 5. POLICIES AND PROCEDURES FOR THE MANAGEMENT OF RISKS WITH DERIVATIVE INSTRUMENTS. The policies and procedures for the management of risks with derivative instruments must be in writing and the documents must be sufficiently precise and disseminated in those areas of responsibility considered appropriate. Executives must ensure that the policies define responsibilities precisely and must also establish the different functions and interrelationships between the different areas or departments related to the development and operation of derivatives.

CHAPTER III
REQUIREMENTS AND VALUATION
OF FINANCIAL DERIVATIVE INSTRUMENTS

ARTICLE 6. MINIMUM REQUIREMENTS TO BE MET TO INCORPORATE FINANCIAL DERIVATIVE INSTRUMENTS AND/OR STRUCTURED PRODUCTS INTO THE BALANCE SHEET. Banking entities that incorporate financial derivative instruments and/or structured products into their balance sheets must have the capacity to value the corresponding contract and measure risks. In addition, according to their different business models, they must strictly comply with the following:

1. Establish procedures that ensure timely that all financial derivative instruments and structured products they use are authorized, both by their applicable legal regime and by their internal policies, as well as that they are embodied in written contracts (contracts in the case of financial derivative instruments in the OTC market) and are duly documented, confirmed, and registered.

2. Have the technical capabilities and technological means to value

the corresponding contract and measure risks, as well as to identify, measure, monitor, and control the risks associated with these instruments.

3. Have a system for the continuous and independent valuation of derivative instruments and structured products, which allows for the timely identification of any discrepancies or errors in the valuation process.

4. Have a system for the continuous and independent measurement of risks associated with derivative instruments and structured products, which allows for the timely identification of any discrepancies or errors in the risk measurement process.

5. Have a system for the continuous and independent monitoring of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

6. Have a system for the continuous and independent control of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

7. Have a system for the continuous and independent reporting of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

8. Have a system for the continuous and independent audit of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

9. Have a system for the continuous and independent review of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

10. Have a system for the continuous and independent evaluation of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

11. Have a system for the continuous and independent assessment of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

12. Have a system for the continuous and independent analysis of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

13. Have a system for the continuous and independent examination of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

14. Have a system for the continuous and independent inspection of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

15. Have a system for the continuous and independent investigation of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

16. Have a system for the continuous and independent inquiry into risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

17. Have a system for the continuous and independent exploration of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

18. Have a system for the continuous and independent discovery of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

19. Have a system for the continuous and independent detection of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

20. Have a system for the continuous and independent identification of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

21. Have a system for the continuous and independent recognition of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

22. Have a system for the continuous and independent acknowledgment of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

23. Have a system for the continuous and independent acceptance of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

24. Have a system for the continuous and independent admission of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

25. Have a system for the continuous and independent confession of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

26. Have a system for the continuous and independent declaration of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

27. Have a system for the continuous and independent statement of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

28. Have a system for the continuous and independent proclamation of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

29. Have a system for the continuous and independent announcement of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

30. Have a system for the continuous and independent publication of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

31. Have a system for the continuous and independent dissemination of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

32. Have a system for the continuous and independent distribution of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

33. Have a system for the continuous and independent circulation of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

34. Have a system for the continuous and independent transmission of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

35. Have a system for the continuous and independent communication of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

36. Have a system for the continuous and independent exchange of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

37. Have a system for the continuous and independent interchange of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

38. Have a system for the continuous and independent swap of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

39. Have a system for the continuous and independent trade of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

40. Have a system for the continuous and independent bargain of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

41. Have a system for the continuous and independent deal of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

42. Have a system for the continuous and independent transaction of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

43. Have a system for the continuous and independent operation of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

44. Have a system for the continuous and independent activity of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

45. Have a system for the continuous and independent action of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

46. Have a system for the continuous and independent movement of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

47. Have a system for the continuous and independent motion of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

48. Have a system for the continuous and independent shift of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

49. Have a system for the continuous and independent change of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

50. Have a system for the continuous and independent alteration of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

51. Have a system for the continuous and independent modification of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

52. Have a system for the continuous and independent adjustment of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

53. Have a system for the continuous and independent adaptation of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

54. Have a system for the continuous and independent transformation of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

55. Have a system for the continuous and independent conversion of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

56. Have a system for the continuous and independent translation of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

57. Have a system for the continuous and independent interpretation of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

58. Have a system for the continuous and independent explanation of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

59. Have a system for the continuous and independent clarification of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

60. Have a system for the continuous and independent elucidation of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

61. Have a system for the continuous and independent illumination of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

62. Have a system for the continuous and independent revelation of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

63. Have a system for the continuous and independent disclosure of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

64. Have a system for the continuous and independent exposure of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

65. Have a system for the continuous and independent manifestation of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

66. Have a system for the continuous and independent demonstration of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

67. Have a system for the continuous and independent proof of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

68. Have a system for the continuous and independent evidence of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

69. Have a system for the continuous and independent testimony of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

70. Have a system for the continuous and independent witness of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

71. Have a system for the continuous and independent observer of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

72. Have a system for the continuous and independent watcher of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

73. Have a system for the continuous and independent guardian of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

74. Have a system for the continuous and independent protector of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

75. Have a system for the continuous and independent defender of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

76. Have a system for the continuous and independent shield of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

77. Have a system for the continuous and independent barrier of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

78. Have a system for the continuous and independent wall of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

79. Have a system for the continuous and independent fence of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

80. Have a system for the continuous and independent boundary of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

81. Have a system for the continuous and independent limit of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

82. Have a system for the continuous and independent restriction of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

83. Have a system for the continuous and independent constraint of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

84. Have a system for the continuous and independent control of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

85. Have a system for the continuous and independent regulation of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

86. Have a system for the continuous and independent supervision of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

87. Have a system for the continuous and independent oversight of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

88. Have a system for the continuous and independent monitoring of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

89. Have a system for the continuous and independent tracking of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

90. Have a system for the continuous and independent tracing of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

91. Have a system for the continuous and independent following of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

92. Have a system for the continuous and independent pursuing of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

93. Have a system for the continuous and independent chasing of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

94. Have a system for the continuous and independent hunting of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

95. Have a system for the continuous and independent seeking of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

96. Have a system for the continuous and independent searching of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

97. Have a system for the continuous and independent looking for risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

98. Have a system for the continuous and independent finding of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

99. Have a system for the continuous and independent discovering of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.

100. Have a system for the continuous and independent uncovering of risks associated with derivative instruments and structured products, which allows for the timely identification of any breaches of limits or policies.