2025-09-12
Added · Updated
The Bank of Ghana has issued the Large Exposures Directive to establish prudential limits and risk governance frameworks for Regulated Financial Institutions, including banks, savings and loans companies, finance houses, and financial holding companies. The directive caps single counterparty exposures at twenty percent of net own funds for banks and financial holding companies, and fifteen percent for savings and loans and finance houses, while setting aggregate large exposure limits at six times and four times net own funds respectively. Effective January 2027, the rules require institutions to implement robust internal monitoring processes, submit Board-approved compliance plans by December 2025, and align their single obligor limits with Basel Committee standards to safeguard financial system stability.
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BANK OF GHANA
Large Exposures Directive for Banks, Savings and Loans, Finance Houses and Financial Holding Companies Prepared by the Bank of Ghana September 2025
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Table of Contents
PART I – PRELIMINARY............................................................................................... 1
Title......................................................................................................................... 1
Application........................................................................................................... 1
Interpretation........................................................................................................ 1
Objectives............................................................................................................. 5
Relevant Legal Provisions .................................................................................... 5
Transitional Arrangements and Effective Implementation............................... 6
PART II – DEFINITIONS................................................................................................ 7
Large Exposures.................................................................................................... 7
The Large Exposure Limit...................................................................................... 7
Connected Persons ............................................................................................. 7
PART III – VALUES OF EXPOSURES........................................................................... 10
Financial Exposure Values................................................................................. 10
Eligible Credit Risk Mitigation (CRM) Technique.............................................. 10
Computation of Exposure Value for Trading Book Positions........................... 10
PART IV – EXEMPTIONS ........................................................................................... 13
PART V – TREATMENT OF SPECIFIC EXPOSURE TYPES ............................................ 14
Exposure to Foreign Sovereigns ........................................................................ 14
Exposure to Foreign Banks................................................................................. 14
Interbank Exposures........................................................................................... 14
Exposures to Qualifying Central Counterparties.............................................. 14
PART VI – RISK GOVERNANCE AND REPORTING REQUIREMENTS........................ 16
Board and Senior Management Responsibilities............................................. 16
Regulatory Reporting......................................................................................... 17
PART VII – SUPERVISORY REVIEW AND DISCLOSURES........................................... 19
APPENDIX – Returns on Large Exposures.............................................................. 20
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PART I – PRELIMINARY
Title
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PUBLIC d) has the ability to direct the activities of the person so as to affect the financial returns on any investment made with the person; “CRD” means the BOG Capital Requirements Directive, 2018; “CRM” means credit risk mitigation, which refers to techniques used by RFIs to reduce the credit risk associated with an exposure by using collateral, guarantees, or netting arrangements; “CSD” means Central Securities Depository; “ECD” means the BOG Eligible Collateral Directive, 2022; “Financial Exposure” in relation to a bank, specialised deposit-taking institution, or financial holding company with respect to a person is the aggregate of; a) the loans, advances, placements, and credit facilities, including offbalance sheet obligations, given to that person, and b) the value of the holdings by that bank, specialised deposit-taking institution, or financial holding company of shares and debentures and other debt securities issued by that person; “Financial Holding Company” means a company that controls a bank or specialised deposit-taking institution which is subject to the registration requirements of Act 930; “Foreign Bank” means a foreign company that is authorised to engage in a deposit-taking business in the country where its head office is located; “Foreign Company” means a company incorporated under the laws of a country other than Ghana; “Foreign Sovereign” means Central Government, Central Bank, Public Sector Entities and other Subnational Governments in jurisdictions other than Ghana; “GCX” means Ghana Commodity Exchange; “GFIM” means Ghana Fixed Income Market; “GhIPSS” means Ghana Interbank Payment and Settlement System; “Insider” means a director, an executive director, a key management personnel and a significant shareholder, with respect to a bank or
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PUBLIC specialised deposit-taking institution, other than a financial holding company; “Key Management Personnel” means the chief executive officer or managing director, deputy chief executive officer, chief operating officer, chief financial officer, Board secretary, treasurer, chief internal auditor, chief risk officer, the head of compliance, the anti-money laundering reporting officer, the head of internal control functions, the chief legal officer, the manager of a significant business unit of the Regulated Financial Institution; “Large Exposure” means financial exposure to a single borrower or group of connected borrowers that, in the aggregate, is equal to or exceeds ten per cent of the net own funds of the bank, a specialised deposittaking institution, or financial holding company; “NOF” means Net Own Funds; “Person” includes an individual, a body corporate, a partnership, an association and any other group of persons acting in concert, whether incorporated or not; “Qualifying Central Counterparty (QCCP)” means an entity that is licensed to operate as a CCP and is permitted by the appropriate regulator to operate as such with respect to the products offered. This is subject to the provision that the CCP is based in, and prudentially supervised in, a jurisdiction where the relevant regulator has established, and publicly indicated that it applies to the CCP on an ongoing basis, domestic rules and regulations that are consistent with the Committee on Payment and Settlement System – International Organization of Securities Commissions (CPSS-IOSCO) Principles for Financial Market Infrastructures; “Regulated Financial Institution (RFI)” means a bank, savings and loans company, finance house and financial holding company regulated under Act 930; “Related Interest” in relation to an insider means a) a firm or company in which an insider is interested, directly or indirectly, as a director or controlling shareholder, partner, proprietor, employee or guarantor; and/or b) a holding company, subsidiary or affiliate of that company in which an insider is interested, directly or indirectly, as a director, key management personnel, controlling shareholder, partner, proprietor,
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“Related Party” means:
a. the RFI’s subsidiaries, affiliates (including their subsidiaries, affiliates and special purpose entities), and any other party that the RFI exerts control over or that exerts control over the RFI; b. the RFI’s significant shareholders, including ultimate beneficial owners;
c. directors, key management personnel, corresponding persons in
affiliated companies and parties that can exert significant influence on the directors or key management personnel; and d. related persons and related interests of natural persons identified in a, b, and c above. “Related Persons” in relation to an insider means a spouse, son, daughter, stepson, stepdaughter, brother, sister, father, mother, cousin, nephew, niece, aunt, uncle, stepsister and stepbrother of an insider; “Senior Management” means members of the Executive Management Committee (EXCO) of a Regulated Financial Institution and any other Key Management Personnel as may be determined by the Regulated Financial Institution; “Trading Book” consists of positions in financial instruments and commodities held either with trading intent or to hedge other elements of the trading book. Positions held with trading intent are those held intentionally for short-term resale, and/or with the intent of benefiting from actual or expected short-term price movements, or to lock in arbitrage profits, and/or hedging instruments in the trading book.
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Objectives
4. The objectives of this Directive are to:
a) Limit the maximum loss that RFIs can incur in the event of the sudden failure of a counterparty or a group of connected counterparties to a level that does not endanger the RFI’s solvency; b) Provide direction to Regulated Financial Institutions (RFIs) on regulatory requirements in order to eliminate any ambiguities in the interpretation of the rules related to limits on financial exposures; c) Establish a framework for large exposures that complements and serves as a backstop to the risk-based capital requirements in alignment with the Basel Committee on Banking Supervision (BCBS) standards; d) Ensure RFIs manage large exposures effectively in order to contribute to the stability of the broader financial system; e) Align the existing Single Obligor Limit (SOL) as defined by Act 930 with the BCBS standards to achieve the equivalent of 25% of Tier 1 capital for banks; f) Introduce a conservative limit for Specialised Deposit-Taking Institutions (SDIs) to ensure that the sector focuses more on lending to Micro, Small and Medium-sized Enterprises (MSMEs) and engender sustainable business models; and g) Enable the Bank of Ghana to effectively monitor and assess risks to the banking system associated with large exposures. Relevant Legal Provisions
5. Section 92 (2)(a) of Act 930 states that the BOG may issue directives to
provide for:
(v) the lending limits on credits extended to insiders; and (vi) the limitations for advances or credit facilities to a single borrower.
6. Section 77 (1) of Act 930 provides that the BOG may, in respect of a
prudential limit prescribed under this Act, impose a stricter limit for banks, specialised deposit-taking institutions or financial holding companies or a class of specialised deposit-taking institutions or a particular bank, specialised deposit-taking institution or financial holding company for the
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7. The Directive seeks to operationalise the following sections of Act 930:
a) Section 62 (1), (2), (3), (4), (5), (6), and (7); b) Section 64 (2); c) Section 67 (2), (3) and (5); and d) Section 74 (1). Transitional Arrangements and Effective Implementation date
8. This directive shall be effective from 1st January 2027.
9. RFIs shall conduct impact assessments prior to the implementation date
and, where there is non-compliance with the requirements of this Directive, submit a credible Board-approved plan acceptable to the BOG by 31st December 2025 detailing the manner in which RFIs propose to achieve compliance.
10. The submitted plan shall include the proposed time frame within which it
proposes to become fully compliant with this Directive, which shall not, in any event, exceed one (1) year from the required submission date in paragraph 9 above.
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PART II – DEFINITIONS
Large Exposures
11. A large exposure is defined as the sum of all financial exposure values of
an RFI to a single person or group of connected persons that is equal to or more than 10% of the NOF of the RFI. The Large Exposure Limit
12. The sum of all financial exposure values of an RFI to a person or to a group
of connected persons (non-exempt) shall not exceed 20% of NOF for banks and FHCs, and 15% for savings and loans companies and finance houses.
13. The aggregate amount of all large financial exposure values (nonexempt) of a bank or FHC shall not at any time exceed six (6) times the
NOF of the bank or FHC as directed by Section 62 (7) of Act 930.
14. The aggregate amount of all large financial exposure values (nonexempt) of a savings and loans company and finance house shall not at
any time exceed four (4) times the NOF of the savings and loans company and finance house as directed by Section 62 (7) of Act 930.
15. The sum of all financial exposure values to related parties to an RFI (nonexempt) shall comply as follows:
a) The insiders and their related interests and related persons shall not exceed 10% of NOF. b) RFI’s subsidiaries, affiliates and associates shall not exceed 20% of NOF. Connected Persons
16. Two or more persons shall be deemed to be a group of connected
persons constituting a single risk if at least one of the following criteria is satisfied; a) Control relationship: one of the persons, directly or indirectly, controls the other; or b) Economic interdependence: if one of the persons were to experience financial problems, in particular funding or repayment problems, the other(s), as a result, would also likely encounter funding or repayment problems.
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17. RFIs shall assess the relationship amongst persons with reference to
paragraph 16 (a) and (b) above in order to establish the existence of a group of connected persons.
18. In assessing whether there is a ‘control’ relationship between persons, an
RFI shall consider ‘control’ as defined in Act 930 and in this Directive.
19. RFIs shall also refer to the criteria specified in the International Financial
Reporting Standard (IFRS) for further qualitative guidance for determining the existence of a control relationship.
20. In establishing connectedness based on economic interdependence,
RFIs shall consider the following criteria:
a) Where 50% or more of the customer’s annual gross receipts or gross expenditures is derived from transactions with the other person; b) Where one counterparty has fully or partly guaranteed the exposure of the other counterparty, and the exposure is so significant that the guarantor is likely to default if a claim arises; c) Where a significant part of one counterparty’s production/ output is sold to another counterparty; d) When the expected source of funds to repay the loans of two or more counterparties is the same, and none of the counterparties has another independent source of income from which the loan may be serviced and fully repaid; e) When it is likely that the financial problems of one counterparty will cause difficulties to the other counterparty in making full and timely repayment of liabilities; f) Where the insolvency or default of one counterparty is likely to be associated with the insolvency or default of the other(s); and g) When two or more counterparties rely on the same source for the majority of their funding, and in the event of the common provider’s default, an alternative funding source cannot be found.
21. In some cases, an RFI may have exposures to a group of counterparties
with specific relationships or dependencies such that, if one of the counterparties fails, all the counterparties would very likely fail. A group of this sort shall be treated as a single counterparty for the purpose of large exposures.
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22. The sum of the RFI’s exposures to all the individual entities included within
a group of connected counterparties shall be subject to the large exposure limit and to the regulatory reporting requirements as per this Directive.
23. RFIs shall put in place robust processes and mechanisms for the timely
identification and reporting of connected counterparties and should be able to fully demonstrate the effectiveness of the process to BOG. The processes should be regularly subjected to independent review by the internal audit function.
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PART III – VALUES OF EXPOSURES
Financial Exposure Values
24. All financial exposures defined under the risk-based capital framework
shall be considered in the identification of large exposures to a counterparty. This includes on- and off-balance sheet exposures in both the banking 1 and the trading book. However, an exposure to a counterparty that is deducted from capital shall not be added to other exposures to that counterparty for the purpose of the large exposure limit.
25. For the purpose of determining the exposure amount of off-balance
sheet items, the Credit Conversion Factors (CCFs) as specified in the CRD shall be used.
26. RFIs shall put in place appropriate internal limits aimed at constraining
their exposures to large single or connected counterparties. In setting such limits, specific considerations shall be given to:
a) The prevailing regulatory/prudential limits on exposure to a single obligor; b) The quality of the RFI’s processes for its management of credit concentration risk; and c) The RFI’s risk appetite is informed by its risk-taking capacity, including its capital and liquidity position. Eligible Credit Risk Mitigation (CRM) Technique
27. RFIs shall exclude the application of CRM techniques in computing
exposure values except for collaterals that qualify as CRM under Section 62 (8) of Act 930 and Appendix 1 of the ECD. Computation of Exposure Value for Trading Book Positions
28. RFIs shall aggregate all exposures to a single counterparty arising in the
trading book to any other exposures to that counterparty in the banking book in the calculation of the total exposure value to that counterparty. 1 Banking book refers to any other financial instruments/ exposures that do not meet the criteria for classification as trading book.
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29. Exposures in financial instruments in the trading book, such as bonds,
equities, foreign currencies and commodities, must be constrained by the RFI’s internal limits.
30. RFIs shall define the exposure value of straight debt instruments and
equities as the accounting value of the exposure (i.e. the market value of the respective instruments).
31. RFIs with instruments such as swaps, futures, forwards, and credit
derivatives shall convert such positions in line with the risk-based capital requirements. The instruments shall be decomposed into individual legs, and only transaction legs representing exposures in the scope of the large exposures shall be considered.
32. In the case of credit derivatives that represent sold protection, the
exposure to the referenced name shall be the amount due in the case that the respective referenced name triggers the instrument, minus the absolute value of the credit protection.
33. In the determination of exposures in options, RFIs shall use the change(s)
in option prices that would result from a default of the respective underlying instrument. The resulting positions shall in all cases be aggregated with those from other exposures. After aggregation, negative net exposures shall be set to zero.
34. RFIs shall use the net position in a specific issue for the purpose of
calculating their exposure value to a particular counterparty for the same issue. RFIs shall offset long and short positions in the same issue (two issues are defined as the same if the issuer, coupon, currency, and maturity are identical).
35. RFIs shall offset positions in different issues from the same counterparty
only when the short position is junior to the long position, or if the positions are of the same seniority.
36. For positions hedged by credit derivatives, the hedge may be recognised
by the RFI provided the underlying of the hedge and the position hedged fulfil the provision that the short position is junior or of equivalent seniority to the long position.
37. In order to determine the relative seniority of positions, securities shall be
allocated into broad buckets of degrees of seniority (for example,
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"Equity", "Subordinated Debt" and "Senior Debt").
38. RFIs that find it excessively burdensome to allocate securities to different
buckets based on relative seniority shall recognise no offsetting of long and short positions in different issues relating to the same counterparty in calculating exposures.
39. Where the result of the offsetting is a net short position with a single
counterparty, this net exposure shall not be considered as an exposure for large exposure purposes.
40. RFIs shall not net across the banking and trading books (e.g., offsetting
short positions in the trading book against long positions in the banking book).
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PART IV – EXEMPTIONS
41. This Directive is applicable to all RFIs’ exposures to single counterparties
and groups of connected counterparties, irrespective of their performance or the quality of any pledged collateral, with the exception of the following exposures:
a) Exposures to the Government of Ghana (GOG), Bank of Ghana (BOG) and other Public Sector Entities (PSEs) fully guaranteed by GOG; b) Exposures that are fully secured by financial instruments issued by the GOG (to the extent allowed by the ECD) or the BOG; c) Exposures where the principal and interest are fully guaranteed by the BOG; d) Intraday Interbank exposures; e) Short-term Interbank exposures (placements) with other RFIs supervised by BOG with an original maturity of three (3) months or less; f) Exposures deducted from an RFI’s Regulatory Capital under the riskbased capital requirements for Regulatory Capital Purposes; g) RFIs’ clearing exposures to qualifying central counterparties; and h) Exposures to Multilateral Development Banks (MDBs) to the extent allowed by the CRD.
42. RFIs shall report all exempted exposures that meet the criteria for the
definition of large exposures.
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PART V – TREATMENT OF SPECIFIC EXPOSURE TYPES
Exposure to Foreign Sovereigns
43. Exposure to foreign sovereigns shall be subject to the Large Exposure Limit
of 20% of NOF for banks and FHCs, and 15% of NOF for savings and loans companies and finance houses. Exposure to Foreign Banks
44. Exposure to foreign banks shall be subject to the Large Exposure Limit of
20% of NOF for banks and FHCs and 15% of NOF for savings and loans companies and finance houses. Interbank Exposures
45. Intraday interbank exposures are exempted from the application of the
large exposure limit. This is to avoid disrupting the payment and settlement system.
46. Short-term interbank exposures (placements) with original maturity of
three (3) months or less are also exempted from the application of the large exposure limit.
47. However, all other interbank exposures shall be subject to the large
exposure limits of 20% of NOF for banks and FHCs and 15% of NOF for savings and loans companies and finance houses. In addition, under stressed and exceptional circumstances, the BOG may accept a breach of an interbank limit ex post, in order to help ensure stability in the interbank market. Exposures to Qualifying Central Counterparties
48. RFIs’ exposures to qualifying central counterparties (QCCPs) related to
clearing activities (e.g. GhIPSS, GFIM, GCX, and CSD ) are exempted from the application of the large exposure limit. However, these exposures will be subject to the regulatory reporting requirements.
49. The concept of connected counterparties described in this Directive shall
not apply in the context of exposures to CCPs that are specifically related to clearing activities.
50. RFIs shall identify exposures to a CCP related to clearing activities and
sum together these exposures. Exposures related to clearing activities are
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Clearing Activities Exposure Exposure Value
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PART VI – RISK GOVERNANCE AND REPORTING REQUIREMENTS
Board and Senior Management Responsibilities
53. The Board of an RFI shall ensure that:
a) The RFI establishes and adheres at all times to the approved internal policies governing concentration risks; b) The internal policies are reviewed regularly (at least annually) to ensure that they remain current, adequate, and appropriate; and c) Independent reviews are conducted regularly to verify ongoing compliance with the prudential limits set by the BOG as well as the established internal policies.
54. Senior management of an RFI shall:
a) Establish and implement internal policies, processes and procedures governing risk concentrations; b) Clearly communicate and monitor compliance with the internal policies throughout the RFI; and c) Establish and maintain adequate management information systems that are able to identify, measure, monitor, aggregate and report exposures to single counterparties or groups of connected counterparties in a timely manner.
55. The internal policies on risk concentration shall, at a minimum, include the
following:
a) Procedures for identifying, measuring, monitoring, controlling, and reporting single counterparty exposures of the institution; b) Detailed internal parameters for identifying persons connected to a single counterparty; c) Internal exposure limits (including limits on total large exposures) that are reflective of the RFI’s risk appetite and risk bearing capacity, and which also take into consideration the potential changes to the market value of the underlying exposures; d) Clearly defined roles and accountability for ensuring compliance and effective communication of the policies, procedures, and internal limits throughout the RFI;
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56. RFIs shall have adequate procedures and controls in place for managing
and monitoring the concentration risks associated with exposures and counterparties exempted from the application of the large exposure limit. Regulatory Reporting and Disclosure Requirements Regulatory Reporting
57. An RFI shall report to the BOG, on a monthly basis, all information relating
to its large exposures, including exemptions permitted under this Directive, in the forms stipulated in the Appendix below.
58. RFIs shall report the exposure values before and after application of the
credit risk mitigation techniques as follows:
a) All exposures with values equal to or above 10% of the RFI’s NOF (Template 1); b) Details of group of connected counterparties (Template 1a); c) RFI’s Top 100 exposures to counterparties irrespective of the values of these exposures relative to the RFI’s NOF (Template 2); d) All the exempted exposures with values equal to or above 10% of the RFI’s NOF (Template 3). e) All other exposures with values, measured without the effect of credit risk mitigation being taken into account, equal to or above 10% of the RFI’s NOF (not including exposures reported in b already) (Template 4); and
59. In line with Section 62 (6), RFIs shall within five (5) days
a) report to the Bank of Ghana a financial exposure that exceeds the limits in this Directive; and b) provide a written plan for remedying the violation as soon as practicable.
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Disclosure
60. RFIs shall disclose in their audited financial statements, among others, the
level of compliance or otherwise with the limits in this Directive.
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PART VII – SUPERVISORY REVIEW
61. The BOG shall assess the adequacy of processes, procedures and policies
put in place by an RFI to ensure that it does not face excessive concentration risk due to over-exposure to a specific counterparty or group of connected counterparties, sector, geographical location, asset class, or collateral type.
62. Where the risks arising from concentrations are not adequately
addressed, the BOG may take appropriate action, including prohibiting the RFI from taking additional exposure and imposing a higher capital charge.
63. RFIs that breach the set large exposure limits at any time shall be required
to deduct the excess amount over the set limit from Common Equity Tier 1 (CET 1) capital in the case of banks and FHCs and Tier 1 Capital in the case of savings and loans companies and finance houses in the computation of Pillar 1 Capital Adequcy Ratios (CARs). RFIs may also be:
a) appropriately sanctioned in line with the relevant provisions of Act 930; b) restricted from distributing dividends and from making other discretionary payments, including executive bonuses; and/or c) required to maintain a higher CAR above the minimum requirement specified by the BOG.
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APPENDIX – RETURNS ON LARGE EXPOSURES
Template 1 - RFI’s exposures with values equal to or above 10% of Net Own Funds (ie. meeting the definition of large exposure) No Counterparty Name Single /Group of Connected counter parties Counterparty TIN/ Ghana Card No. Foreign and Domestic Currency Exposures Section 62 (8) Collaterals and
Appendix 1 ECD
Net
Exposure
% of
Exposure
Value to
NOF
IFRS
Staging
Classification as per BOG
Prudential
Drawn Norms
Down
Undrawn2
Facility
Other
Contingent
Liability
Total
Exposure
Type Amount
…
…
…
Total
Tier 1 Capital
Net Own Funds
The values of the ‘Undrawn Facility and Other Contingent Liability’ columns shall be after applying CCF.
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Template 1a. Details of Connected Counterparties No Unique ID Counterparty Name Group of Connected counterparties Basis of Connection Counterparty TIN/ Ghana Card No. Type of Facility Foreign and Domestic Currency Exposures Section 62 (8) Collaterals and
Appendix 1
ECD
Net
Exposure
Other
Collaterals
IFRS
Staging
Classification as per BOG
Prudential
Norms
Drawn
Down
Undrawn
Facility
Other
Contingent
Liability
Total
Exposure
Type Amount Type Amount
…
…
…
….
Total
Tier 1 Capital
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Template 2 - RFI’s Top 100 exposures to counterparties (single as well as group of connected counterparties), irrespective of the values of these exposures relative to the RFI’s Net Own Funds No Counterparty Name Counterparty TIN/ Ghana Card No. Type of Facility Purpose of Facility Foreign and Domestic Currency Exposures Deductible Collaterals (Section 62(8) of Act 930) Net Exposure Other Collaterals Specific loan loss provisions IFRS Staging Classification as per BOG Prudential Norms Drawn Down Undrawn Facility Other Contingent Liability Total Exposure … … Total Net Own Funds
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Template 3 - RFI’s exempted exposures with values equal to or above 10% of RFIs' Net Own Funds No Counterparty Name Counterparty TIN Type of Facility Purpose of Facility Foreign and Domestic Currency Exposures Deductible Collaterals (Section 62(8) of Act 930) Net Exposure Other Collaterals IFRS Staging Classification as per BOG Prudential Norms Drawn Down Undrawn Facility Other Contingent Liability Total Exposure … … … Total
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Template 4 - RFI’s other exposures with values, measured without the effect of credit risk mitigation being taken into account, equal to or above 10% of RFI’s Net Own Funds (not including exposures reported in Template 2 already) No Counterparty Name Counterparty TIN/ Ghana Card No. Type of Facility Purpose of Facility Foreign and Domestic Currency Exposures % of Exposure Value to NOF IFRS Staging Classification as per BOG Prudential Norms Drawn Down Undrawn Facility Other Contingent Liability Total Exposure … … Tier 1 Capital Net Own Funds
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Source: Bank of Ghana — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
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