OFSAA and Oracle Banking Platform (OBP) Regulatory Updates Effective Date: 15-December-2017

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1 OFSAA and Oracle Banking Platform (OBP) Regulatory Updates Effective Date: 15-December-2017 Table of Contents 1. OFSAA Regulatory Updates Delivery Policy 2. OFSAA Regulatory Updates Delivery Policy Definitions 3. Applicable OFSAA Regulatory Programs, Applicable Regulations, and Applicable Jurisdictions 4. OBP Regulatory Updates Delivery Policy 5. Applicable OBP Modules, Applicable Regulatory Business Areas, and Applicable US Federal Regulations 1. OFSAA Regulatory Updates Delivery Policy Oracle will provide updates for the Applicable OFSAA Regulatory Programs, Applicable Regulations, and Applicable Jurisdictions (as specified in section 3 of this policy) in accordance with the thencurrent Oracle Technical Support Policies and as further specified in this document. Minor Regulatory Changes For Minor Regulatory Changes involving only template changes, Oracle shall supply updates within two months after the final publically available disclosure of the Applicable Regulation, or one month prior to the Applicable Regulation s enforcement date (i.e., the date by which a customer is expected to be in compliance to the updated Applicable Regulation), whichever date comes later. The updates will be based on Oracle s interpretation of the Applicable Regulation as published by the relevant legislatively empowered agency or commission and may require applying of one or more patches, and upgrading to the current minor release of the relevant application(s), platform and the data foundation. For Minor Regulatory Changes involving calculation changes, Oracle shall supply updates within three months after the final publically available disclosure of the Applicable Regulations, or three months prior to the Applicable Regulation s enforcement date (i.e., the date by which a customer is expected to be in compliance to the updated Applicable Regulation), whichever date comes later. The updates will be based on Oracle s interpretation of the Applicable Regulation as published by the relevant legislatively empowered agency or commission and may require applying of one or more patches, and upgrading to the current minor release of the relevant application(s), platform and the data foundation. Major Regulatory Changes For Major changes, Oracle shall supply updates within six months after the final publically available disclosure of the Applicable Regulations, or six months prior to the Applicable Regulation s enforcement date (i.e., the date by which a customer is expected to be in compliance to the updated Applicable Regulation), whichever date comes later. The final updates will be based on Oracle s interpretation of the Applicable Regulation as published by the relevant legislatively empowered agency or commission. Major updates will likely have a long consultation period. During this consultation period, Oracle will endeavor to provide intermediate updates to the OFSAA Regulatory Products including data documentation so that customers may start to absorb these changes prior to the final release is available. These updates may require applying of one or more patches, and upgrading to the current minor or major release of the relevant application(s), platform and the data foundation. On occasion, certain relevant legislatively empowered agencies or commissions demand compliance with extremely aggressive deadlines not consistent with the timelines set forth above. Oracle may not be able to deliver updates to comply with these aggressive deadlines and will advise customer of these circumstances. OFSAA OBP Regulatory Updates: 15-December-2017 Page 1 of 6

2 2. OFSAA Regulatory Updates Delivery Policy Definitions Minor Regulatory Changes refers to changes which are required by a relevant legislatively empowered agency or commission to the Applicable Regulations as specified in section 1 above, that represent a like for like change or modification to the layout, appearance or operation of the templates and do not significantly impact the templates, or simple changes to the rules and/or calculations. Examples of Minor Regulatory Changes include, but are not limited to, adjustment to validation rules/edit checks, evolution of an existing template by addition/removal of a small proportion of cells (but not entire pages/schedules), addition and removal of reporting elements, reorganization of elements on a template for a different view of the data, addition of new memo/notes information that requires manual data entry, evolution of a data point model for electronic transmission but not a new data point model, update of HQLA (High-Quality Liquid Assets) classification for LCR (Liquidity Coverage Ratio) for the US jurisdiction. A new transmission mechanism such as XML or XLS to XBRL would NOT be classed as a Minor Regulatory Change. Major Regulatory Changes refers to changes of a material nature which are required by a relevant legislatively empowered agency or commission to the Applicable Regulations as specified in section 1 above, that would include, but not be limited to, new and/or additional returns or major overhauls (where a change does not represent a like for like change or modification to existing rules/reporting but is altogether of a more material nature or not evolutionary in nature). This includes but is not limited to situations where a like for like does not exist; where a new regime is being introduced (e.g., a new risk type not there before), where a new transmission taxonomy or equivalent is introduced, where a class of reporting not there before is introduced for the first time either a technical class, e.g., reporting transaction data where previously templated, or a type of reporting (e.g., Credit Valuations Adjustment computations), where the rule set behind a template is effectively re-written as a result of a change to the legal basis of reporting (e.g., UK law replaced by EU law), where the jurisdictional boundaries are changed, where validations or edit checks are changed on a revolutionary and not evolutionary basis and where file submission mechanisms change (e.g., file upload to web services integration). 3. Applicable OFSAA Regulatory Programs, Applicable Regulations, and Applicable Jurisdictions The Applicable OFSAA Regulatory Programs, Applicable Regulations, and Applicable Jurisdictions to which this delivery policy applies are as specified in the table below. This table is subject to change at Oracle s discretion. In no event shall Oracle be deemed to assume any or other obligation of yours. Notwithstanding any interpretation that Oracle may provide with respect to any Applicable Regulations, you are solely responsible for maintaining your compliance with any Applicable Regulations and determining whether or not Oracle s Regulatory Updates are sufficient for such purposes. Please see table below. OFSAA OBP Regulatory Updates: 15-December-2017 Page 2 of 6

3 India Applicable Jurisdictions/Applicable Regulations European Islamic USA Union Brazil China Banking Netherlands Thailand OFSAA REGULATORY PRODUCTS Reserve Bank of India European Banking Authority Federal Reserve Board/ Office of the Comptroller of Currency/ Federal Deposit Insurance US Department of the Treasury Banco Central Do Brazil Central Bank of Republic of China Islamic Financial Services Board De Nederlandsche Bank Bank of Thailand Corporation Basel Regulatory Capital Basic Basel II, Basel III CRR IV Basel II, Basel III Basel II Basel II, Basel III Basel II Basel III Basel Regulatory Capital Internal Ratings Based Basel II, Basel II, Basel Approach Basel III CRR IV Basel II, Basel III Basel II III Basel II Basel Regulatory Capital Basel II, Basel II, Basel Analytics Basel III CRR IV Basel II, Basel III Basel II III Basel II AgileREPORTER US Federal Reserve Reg Reserve Bank of India Reports European Banking Authority De Nederlandsche Bank - Reserve Bank of India - Lombard Risk Integration Pack Reg Reports - US Federal Reserve - Lombard Risk Integration Pack European Banking Authority - Integration Pack for Lombard Risk Data Governance for European Central Reporting BCBS239 Data Governance for US Regulatory Reporting BCBS239 BCBS239 requiremen ts changes for Data Foundation ICAAP Analytics BASEL BASEL pillar pillar II II requiremen ts BASEL pillar II LCR, NSFR, LCR, CRR LCR, Calculations to NSFR, CRR NSFR, support FR 2052a Intraday CRR LMM, (5G) & FR 2052a LCR, NSFR Monitoring DA LCR, DA & b (4G), Liquidity Financial Services Liquidity Risk metrics NSFR Risk Aspects of Regulation YY Management Notes: Regulatory templates for submission will be delivered by the Regulatory Reporting SKUs, not by the Basel or LRM applications OFSAA OBP Regulatory Updates: 15-December-2017 Page 3 of 6

4 4. OBP Regulatory Updates Delivery Policy Oracle will provide updates for the Applicable OBP Modules based upon the Applicable Regulatory Business Areas and the Applicable US Federal Regulations (as specified in section 5 of this policy) in accordance with the then-current Oracle technical support policies and as further specified in this document. Regulatory Changes Requiring System Updates The changes requiring system updates to the relevant business areas to the Applicable OBP Modules will be based on Oracle s interpretation of the Applicable US Federal Regulations as published by the relevant legislatively empowered agency or commission and may require applying of one or more patches, and upgrading to the current minor release of OBP. Oracle will monitor Applicable US Federal Regulations from the proposed phase to the final release of the regulation and shall supply system updates as set out below after the final publically available disclosure of the Applicable US Federal Regulation. For Applicable US Federal Regulations changes with a long consultation period, Oracle may endeavor to provide at its discretion, intermediate system updates to the Applicable OBP Modules including documentation so that customers may start to absorb these changes prior to the final release is available. These updates may require applying of one or more patches, and upgrading to the current minor or major release of the relevant and applicable OBP application(s). Regulatory Changes Not Requiring System Updates Some Applicable US Federal Regulations changes may not require a system update and can be fulfilled with configuration changes such as addition or modification of data parameters, business rules, and updates in general configuration settings. The changes not requiring system updates will be based on Oracle s interpretation of the Applicable US Federal Regulation. Oracle will notify customers when Applicable US Federal Regulations changes do not require system updates by supplying bulletin updates with the modified configuration settings or noting that modifications in the configuration settings are not necessary. Oracle will supply the bulletin updates as set out below after the final publically available disclosure of the Applicable US Federal Regulation. Oracle will incorporate bulletin updates in the OBP product documentation in the next scheduled release. Timing of Delivery for Regulatory Updates Oracle will supply system updates, patches, bulletin updates, or product documentation after the final publically available disclosure of the Applicable US Federal Regulation but before the enforcement date of the Applicable US Federal Regulation. Oracle will endeavor to supply system updates and system documentation with sufficient lead time for customers to test and assimilate changes, after the final release of the regulation and before the published enforcement date, once those same changes have been tested in the available OBP product releases. On occasion, certain relevant legislatively empowered agencies or commissions demand compliance with extremely aggressive deadlines that might prevent delivery of system and documentation updates with sufficient lead time before the enforcement date. Oracle may not be able to deliver updates to comply with these aggressive deadlines and will advise customer of these circumstances. 5. Applicable OBP Modules, Applicable Regulatory Business Areas, and Applicable US Federal Regulations The Applicable OBP Modules, Applicable Regulatory Business Areas, and Applicable US Federal Regulations to which this delivery policy applies are as specified in the tables below. These tables are subject to change at Oracle s discretion. In no event shall Oracle be deemed to assume any or other obligation of yours. Notwithstanding any interpretation that Oracle may provide with respect to any Applicable US Federal Regulations, you are solely responsible for maintaining your compliance with any Applicable US Federal Regulations and determining whether or not Oracle s Regulatory Updates are sufficient for such purposes. OFSAA OBP Regulatory Updates: 15-December-2017 Page 4 of 6

5 Applicable OBP Modules Oracle Banking Core Applications o Banking Base o Banking Current and Savings Account o Banking Loans o Banking Term Deposits o Banking Limits and Collaterals o Banking Relationship Pricing o Banking Originations o Banking Collections Oracle Banking Enterprise Originations o Oracle Banking Secured Retail Loan Originations o Oracle Banking Secured Retail Loan Originations o Oracle Banking Unsecured Retail Loan Originations o Oracle Banking Deposits Originations Oracle Banking Enterprise Collections Applicable Regulatory Business Areas Consumer Deposits Consumer Lending Default Management Applicable US Federal Regulations E-Sign Act Regulation E Electronic Fund Transfer Act SCRA Service Member Civil Relief Act ECOA- Equal Credit Opportunity Act (Regulation B) SAFE- Secure & Fair Enforcement for Mortgage Licensing Act OFAC Office of Foreign Asset Control MLA Military Lending Act Regulation O Escheatment TILA Truth in Lending Act (Regulation Z) Real Estate Appraisal Regulation (Regulation H) SLTV - Supervisory Loan To Value FDPA - Flood Disaster Protection Act FCRA Fair Credit Reporting Act (Regulation V) CERCLA Comprehensive Environmental Response, Compensation and Liability Act IRS TIN Certification Regulation P US Bankruptcy Processing Compliance Children s Online Privacy Protection Act of 1998 (COPPA) Garnishment of Accounts Containing Federal Benefit Payments Regulation D Regulation CC BSA - CTR Uniform Retail Credit Classification and Account Management Policy FAS91 Accounting CAN-SPAM Overdraft Guidance Statement of Financial Accounting Standards (SFAS) Reg AA Regulation O Regulation W Delinquency Tracking Methods Delinquency Tracking Methods TISA - Truth in Savings Act Usury laws OFSAA OBP Regulatory Updates: 15-December-2017 Page 5 of 6

6 HMDA Home Mortgage Disclosure Act CRA - Community Reinvestment Act FDCPA Fair Debt Collections Practices Act TCPA Telephone Consumer Protection Act OFSAA OBP Regulatory Updates: 15-December-2017 Page 6 of 6

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