Questionnaire re: LIBOR Benchmark Transition

Questionnaire re: LIBOR Benchmark Transition LIBOR Transition Strategy

1. Would the discontinuation of LIBOR have a sigmficant impact on your institution? a. If yes, what is your assessment of the risks arising from inadequate transition away from LIBOR? b. If not, please explain why you do not consider financial market reliance and exposure to LIBOR to be a material risk.
2. Do you have a strategy to make a timely, safe and sound transition away from LIBOR to alternative reference rates? a. If yes, please set out the key elements of your strategy to ensure a timely, safe and sound transition b. If not, please explain why LIBOR Exposures
3. Have you started the process ofLIBOR transition to alternative reference rates for legacy and new contracts? If yes, please provide details.
4. Please provide total gross exposure to LIBOR (covering derivatives products, asset side products and liability side products) and the number of contracts.

Exposure as at December 2019 DERIVATIVES Product-Total Gross Notional Ex osure Interest Rate Derivatives - OTC Interest Rate Derivatives - Exchange Traded Other (please specify) Total Derivatives Currency Benchmark A-(A^-*t^'A»- OF WHICH: with fallback' RFR LIBOR OF WHICH: with fallback RFR LIBOR OF WHICH: with fallback RFR LIBOR OF WHICH: with fallback RFR USD GBP JPY CHF EUR Value No Value No Value No. Value No. Value No. Comments 1 Fallback refers to sufficiently granular contract language that specify the replacement reference rate in the case of LIBOR cessation.

DERIVATIVES Product-Total Gross Notional Exposure USD GBP JPY CHF EUR Currency Value No Value No Value No. Value No. Value No. Comments maturing after 2021 Interest Rate Derivatives - OTC Interest Rate Derivatives - Exchange Traded Other (please specify) Total Derivatives Benchmark LIBOR OF WHICH: with fallback2 RFR LIBOR OF WHICH: with fallback RFR LIBOR OF WHICH: with fallback RFR LIBOR OF WHICH: with fallback RFR Fallback refers to sufficiently granular contract language that specify the replacement reference rate in the case of LIBOR cessation.

ASSET SffiE Product - Total Gross Ex osure Interest Rate Derivatives -OTC Interest Rate Derivatives

• Exchange Traded Other (please specify) Total Derivatives Currency Benchmark LIBOR OF WHICH: with fallback3 RFR LIBOR OF WHICH: with fallback RFR LIBOR OF WHICH: with fallback RFR LIBOR OF WHICH: with fallback RFR USD GBP JPY CHF EUR Value No Value No Value No. Value No. Value No. Comments ' Fallback refers to sufficiently granular contract language that specify the replacement reference rate in the case of LIBOR cessation.

ASSET SffiE Product - Gross Exposure Maturing after 2021 Bonds and securitisations (including CLOs) Syndicated Loans Bilateral Business Loans Retail Mortgages / Consumer Loans Preferred Stocks Other (please specify) Currency Benchmark LIBOR OF WHICH: with fallback4 RFR LIBOR OF WHICH: with fallback RFR LIBOR OF WHICH: with fallback RFR LIBOR OF WHICH: with fallback RFR LIBOR OF WHICH: with fallback RFR LIBOR OF WHICH: with fallback RFR USD GBP JPY CHF EUR Value No Value No Value No. Value No. Value No. Comments Fallback refers to sufficiently granular contract language that specify the replacement reference rate in the case of LIBOR cessation.

ASSET STOE Product - Gross Exposure Maturing after 2021 Total USD GBP JPY CHF EUR Currency Benchmark LBOR OF WHICH: with fallback RFR Value No Value No Value No. Value No. Value No. Comments

LIABILITY SIDE Product - Total Gross Ex osure CDs and deposits Senior debt Subordinated debt Preferred stock Other (please specify) Total Currency Benchmark LIBOR OF WHICH: with fallback5 RFR LIBOR OF WHICH: with fallback RFR LIBOR OF WHICH: with fallback RFR LIBOR OF WHICH: with fallback RFR LIBOR OF WHICH: with fallback RFR LIBOR OF WHICH: with fallback RFR USD GBP JPY CHF EUR Value No Value No Value No. Value No. Value No. Comments ' Fallback refers to sufficiently granular contract language that specify the replacement reference rate in the case of LIBOR cessation.

LIABILITY SIDE Product - Gross Exposure maturing after 2021 CDs and deposits Senior debt Subordinated debt Preferred stock Other (please specify) Total Currency Benchmark LIBOR OF WHICH: with fallback6 RFR LIBOR OF WHICH: with fallback RFR LIBOR OF WHICH: with fallback RFR LIBOR OF WHICH: with fallback RFR LIBOR OF WHICH: with fallback RFR LfflOR OF WHICH: with fallback RFR USD GBP JPY CHF EUR Value No Value No Value No. Value No. Value No. Comments ' Fallback refers to sufficiently granular contract language that specify the replacement reference rate in the case of LIBOR cessation.

5. Please indicate areas of assessment Governance framework and organisational stmcture, including having firm level plan and allocation of resources Measurement of own exposure and roll offtimelines Valuation Risk management Internal audit and conti-ols Tax and accounting implications New RFR product design Potentially required system changes Legal contract review and remediation Transition (LIBOR / RFR) client outreach Issues arising from regulatory frameworks Other (please specify)

6. Please discuss the progress of migration to alternative benchmarks and the adoption of robust fallbacks (e. g. ISDA's protocols for derivatives). Please discuss targets and roll of timelines, if applicable.

7. Please explain how targets are set, including underlying criteria.

8. Please discuss intermediate targets, if any, from now until end-2021.

9. Please explain how targets are tracked and applied.

10. Please discuss if there are alternative methods to ensure continued progress in transition.

11. Please discuss any LIBOR exposures that cannot be transitioned. What is the reason why the transition cannot be achieved and for which products?

12. Please indicate whether internal processes and organizational sti-uctures - i.e. "transition teams" - to manage the transition to alternative reference rates.

13. Please discuss budget and other resources committed to the ti-ansition to alternative reference rates by end-2021. What is the estimated cost of transition?

14. Please discuss work with private sector clients to mitigate issues and facilitate benchmark transition.

15. What changes to systems, products or contractual amendments are used to mitigate the impact? Are they any potential conflicts / firictions, such as re-opening of contractual negotiations, etc. expected? ISDA fallback Loan fallback System issues / changes New RFR product offerings RFR-LIBOR basis swap Other (please specify)

16. On a scale from 1 to 4, what is your assessment of the status of preparedness of your clients? 1 = not aware of transition 2 = planning on transition 3 = transition in progress 4 = transition completed Please elaborate.

17. What, if any, are the differences between client types? Please elaborate.

18. overall, what is your assessment of the main obstacles to a successful transition? Please identify the top three from the following list by writing 1, 2 and 3 in the relevant box (where 1 is the obstacle you consider to be the biggest). Where you select 'other', please specify. Lack of liquidity in new RFRs Lack oftenn rates for new RFRs Inadequacy of fallback provisions Cross border issues Challenges agreeing contract amendments Lack of action / engagement from market participants Lack of awareness Lack of understanding on the use ofRFRs Other (please specify)

19. Have internal targets and deadlines for transition from LIBOR to alternative reference rates?

20. Has audit (internal / external) assessed whether these targets are reasonable and effective? If so, please describe the overall framework.

21. What are the key indicators that are covered under these targets? e.g. % of financial conti-acts referencing LIB OR and alternative reference rates, % of financial contracts adopted fallback protocols.

22. Have any requirements been imposed by the parent company?

23. Have you evaluated external vendors for benchmark transition? 10