THE INVESTOR FOR SECURITIES COMPANY. PILLAR III DISCLOSURE As of 31 December 2017

Transcription

1 THE INVESTOR FOR SECURITIES COMPANY PILLAR III DISCLOSURE As of 31 December 2017

2 Table of Contents 1. Scope of Application Basis of Disclosure Frequency of Disclosures Material or Legal Impediments between INVESCO and its Subsidiaries Capital Structure Tier 1 Capital Tier 2 Capital Capital Adequacy Capital Adequacy Ratio and Minimum Capital Requirements ICAAP Scenario Analysis and Stress Testing Risk Management Risk Management Objectives Risk Management Framework The elements of Risk Management Framework are as follows: Risk Governance Structure Roles and Responsibilities Board of Directors ( Board ) Managing Director ( MD ) Risk Appetite Credit Risk Credit Risk Management Impairments and Past Due Claims Use of Credit Rating Information Geographic Concentration Credit Risk Exposures by Credit Quality Credit Risk capital charge Counterparty Credit Risk and Off BS Exposure Credit Risk Exposures before/ after Credit Risk mitigation Market Risk Market Risk Management Market Risk capital charge Operational Risk Operational Risk Management Operational Risk capital charge Liquidity Risk Liquidity risk Management Funding Sources Liquidity Ratio Analysis Appendices Appendix 1 - Disclosure on Capital Base Appendix 2 - Disclosure on Capital Adequacy Appendix 3 - Disclosure on Credit Risk s Risk Weight Appendix 4 - Disclosure on Credit Risk s Credit Rating Appendix 5 -Disclosure on Credit Risk Mitigation (CRM) Page 2

3 1. Scope of Application The Investor for Securities Company ( the Company or INVESCO ) is a Saudi closed joint stock company registered in the Kingdom of Saudi Arabia under commercial registration numbered dated 6 Jamad Al Awal 1429H, corresponding to 12 May On 22 Ramadan 1429H, corresponding to August 18, 2008 the Capital Markets Authority (CMA) in the Kingdom of Saudi Arabia granted The Investor for Securities Company the full license to operate as a Shariah compliant investment bank under the license number The licensed activities of the company include providing Dealing, Managing, Custody, Arranging and Advising services. The Pillar III disclosures contained herein relate to the audited financial statements of INVESCO for the year ended December 31, The CMA Prudential Rules comprise of three Pillars : Pillar I sets the minimum capital requirements to meet credit, market and operational risk. INVESCO Investment uses the Standardized Approach in the calculation of the capital required for Credit risk. The capital charge for market risk is assessed for trading book portfolio and Foreign exchange positions in the books. The capital charge for operational risk is calculated as higher of the amounts under the Basic Indicator Approach or the Expenditure Based Approach Pillar II The Internal Capital Adequacy Assessment Process (ICAAP) requires firms and their supervisors to consider whether additional capital should be held to cover risks not covered by Pillar I requirements and to perform an extensive stress testing, scenario analysis, strategic capital planning and reviewing the internal control framework and the roles and responsibilities of departments / individuals that are critical to the implementation of the risk management framework. The Company has taken various initiatives to implement the ICAAP and assess capital requirements in accordance with its risk appetites taking into consideration the size, nature and complexity of its business. Pillar III aims to provide a detailed and transparent reporting framework that enhances market discipline to operate while sharing key information that facilitates assessment of the AP s capital adequacy by all stakeholders including creditors, investors, analysts, customers, suppliers, employees, regulators and rating agencies, which leads to an improved corporate governance. The information provided here has been reviewed and validated by the Management and is in accordance with the rules in force at the time of publication, covering both the qualitative and quantitative items. INVESCO shall publish the Pillar III disclosures at its website Page 3

4 1.1. Basis of Disclosure These disclosures are compiled in accordance with CMA s minimum requirements for the annual market disclosure of information as referred to by the Part 7 Pillar III Disclosure and Reporting of the Prudential Rules. Specifically, they cover The Company s risk management objectives and policies; the processes for managing its material risks; the structure and organization of its risk management functions; the scope and nature of its risk reporting and measurement systems; and its policies for mitigating risk Frequency of Disclosures These disclosures will be produced on an annual basis. This report discloses the positions as on 31 December Material or Legal Impediments between INVESCO and its Subsidiaries INVESCO does not envisage any material or legal impediment to the prompt transfer of capital or repayment of liabilities between INVESCO and the related business partners/subsidiaries/associates. Page 4

5 2. Capital Structure The Company s authorised share capital is SR 400,000,000 consisting of 40,000,000 shares of SR 10 each. As of 31 December 2017, the Company s issued and paid up capital is SR 200,000,000 consisting of 20,000,000 shares of SR 10 each. For regulatory purposes, capital is categorized into two main classes, Tier 1 and Tier 2, which are described below: 2.1. Tier 1 Capital Tier-1 capital of the Company consists of paid-up capital, reserves (other than revaluation reserves) and Audited Retained Earnings / Accumulated (losses). (All amounts in 000 SAR) Tier 1 Capital Paid-up capital 200, , ,000 Share premium Tier-1 capital contribution Statutory Reserves 18,540 18,548 19,303 Audited retained earnings / Accumulated (losses) -49,815-8,441 15,699 Loss offsetting against capital reduction Tier-1 adjustment* Total Tier-1 capital 168, , ,002 * The tier-1 adjustment comes from an unverified interim loss 2.2. Tier 2 Capital Tier-2 capital of the Company consists of revaluation reserves which resulted from the change in fair value of AFS equity investments. (All amounts in 000 SAR) Tier 2 Capital Subordinated loans Cumulative preference shares Revaluation reserves 59,569 45,281 72,892 Other deductions from Tier-2 (-) Deduction to meet Tier-2 capital limit(-) Total Tier-2 capital 59,569 45,281 72,892 TOTAL CAPITAL BASE (Tier-1 & 2) 228, , ,894 Please refer to Appendix 1 for detailed disclosure on capital base. Page 5

6 3. Capital Adequacy The Company aims to maximize shareholders value through an optimal capital structure that protects the stakeholders interests under extreme stress conditions, and provides sufficient capacity for growth whilst ensuring compliance with the regulatory requirements and meeting shareholders expectations Capital Adequacy Ratio and Minimum Capital Requirements The Company is capitalized with total capital ratio of 1.03 X, against a minimum regulatory requirement for capital ratio of 1 x. The below table reflects the further details of the minimum capital required. (All amounts in 000 SAR) Particulars % Change Capital Base: Tier I Capital 168, ,107-20% Tier II Capital 59,569 45,281 32% Total Capital Base 228, ,387-11% Minimum Capital Required Credit Risk 214, ,320-15% Market risk 1, % Operational risk 5,585 10,722-48% Total Minimum Capital Required 221, ,857-16% Capital Adequacy Ratio % Surplus in Capital Base 6,809-9, % Please refer to Appendix 2 for detailed disclosure on capital adequacy ICAAP INVESCO has introduced an Internal Capital Adequacy Assessment Process (ICAAP) by which it examines its risk profile from both regulatory and internal risk capital point of view. The ICAAP describes the Firm s business strategy, its forecasts for the next three years for risk weighted assets, its risk appetite and the assessment of specific risk exposures, their mitigation and the capital allocated to these risks. In effect, the ICAAP is a crucial part of the Company s strategic decision making process and risk management framework. The ICAAP is reviewed and approved by the Board committee on an annual basis and a Report is submitted to the CMA. The assessment draws on the results of existing risk management techniques and reporting Scenario Analysis and Stress Testing Scenario analysis and stress testing refers to various techniques (quantitative and/or qualitative) used by the Company to assess their susceptibility to exceptional but probable events. It is a risk management technique used to evaluate the potential effects of a specific Page 6

7 event and/or movement in a set of financial variables on the Firm s financial condition. Senior Management is regularly informed of the stress test outcomes to ensure that the Company has sufficient capital in place and that any unacceptable risks are mitigated. These scenarios are regularly reviewed and updated to account for changing market dynamics. Various stress scenarios and their impact on capital position is reported to CMA on annual basis. Page 7

8 4. Risk Management The Company has a risk management framework to manage its exposure to diverse set of risks it undertakes during the course of its business objectives Risk Management Objectives The primary goal of risk management is to ensure that INVESCO asset and liability profile, its trading positions, its credit and operational activities do not expose it to losses that could threaten the existence of the Company. Risk management helps ensure that risk exposures do not become excessive relative to the Company s capital position and its financial position. The objective of Risk Management Process is to help business units and support units to identify risks, measure risks exposures, assess the effects of exposures, control and mitigate risk s exposures and monitor/evaluate the performance of risk management to help INVESCO to achieve its strategic goals and to meet regulatory requirements Risk Management Framework The Company established a robust risk management framework for efficiently managing its risks. Following is the schematic representation of the risk management framework established by the Firm: The elements of Risk Management Framework are as follows: A. Risk Direction It consists of the following components: Risk Appetite: It is the level of risk that the Firm is prepared to accept, before action is deemed necessary to reduce it. Page 8

9 Line of Independence Line of Independence The Investor for Securities Company Pillar III Disclosure 31 December 2017 Risk Strategy: The strategy for effective management of all material and potential risks has been identified based on the understanding of the Firm s business strategy. B. Risk Organization and Methodology It consists of the following components: Risk Governance: The Risk Organization Structure of the Firm includes Risk Committee, Risk Management Department and the corresponding skills and resources. The Risk Governance Structure has been detailed in the next section. Risk Management Life Cycle: Identification, Assessment, Monitoring, and Reporting and Mitigation of all material risks faced by the Firm Risk Governance Structure The Risk Management Governance Structure at the Firm based on the Three Lines of Defense model which is proven and widely adopted by leading investment companies and financial institutions. The diagram below illustrates the Risk Management Governance Structure: Board of Directors Executive & Investment Committee Managing Director Audit Committee Risk Committee Business & Support Units Risk Management Department Internal Audit Day-to-day management of risk Risk Oversight Independent Assurance The governance structure ensures that there are clearly defined roles and responsibilities throughout the organization at the Board level, at the Executive Management level and at the business unit and support unit level. It sets out our requirements for the segregations of duties to ensure adequate independence of risk management staff. Page 9

10 4.4. Roles and Responsibilities This section describes the roles and responsibilities of the Board, their committees to the capital management process at the Company Board of Directors ( Board ) The Board will be responsible for the following: Approving the ICAAP Policy; Approving the Risk Appetite of the Firm as part of the risk management framework; Approving the annual ICAAP report; and Approving Pillar III disclosures Managing Director ( MD ) The MD will be responsible for the following: Reviewing on quarterly basis capital adequacy under Pillar I standardized approach provided by CMA; Reviewing the annual document of ICAAP that outlines the Firm s current capital needs and anticipated capital requirements to ensure alignment with the overall business strategy of the Firm on an annual basis; Reviewing Pillar III disclosures; Overseeing the results of the quality assurance process by the Internal Audit and their report on the effectiveness of the ICAAP framework; and Recommending to The Board for approval of ICAAP document and pillar III disclosures Risk Appetite The Board of Directors of INVESCO is responsible for overall risk appetite of the Company. Risk appetite of INVESCO is defined as the amount of risk that the company is willing to accept to achieve its stated objectives and respective returns to shareholders, while safeguarding against key sources of risk for the company. The Company has established a Risk Appetite along with limits to monitor the risks across various businesses and at the Company as a whole. Risk limits are thresholds to monitor that actual risk exposure does not deviate too much from the target and stays within an organization s risk tolerance/risk appetite. Exceeding risk limits will typically act as a trigger for management action. This requires the Company to consider at a more general level how much risk an individual units/heads should be allowed to take. All limit breaches are monitored by the Risk Department who seeks clarifications of such breaches from the business and reports to the Risk Committee. Limit breaches are followed by corrective actions in order to bring the risk to acceptable levels. The Risk Appetite statement has been detailed below: Page 10

11 No. Risk Type Risk Appetite Statement Risk Appetite Indicator 1. Concentration Risk The Firm shall not exceed the thresholds defined for large exposure to a particular sector. Approved Concentration Risk Limits Quick Ratio 2. Liquidity Risk The Firm shall maintain adequate liquidity to meet its short-term obligations. Maximum Asset Liability Mismatch 3. Market Risk 4. Leverage 5. Earnings Volatility The Firm shall take a calculated risk on the market positions. The company shall not exceed the threshold prescribed on debt to equity ratio and maximum borrowings limits set for foreign exposures, The projection of net profit based on an approved business plan should not deviate beyond a reasonable range. Value at Risk (VaR) Debt Equity Ratio Maximum foreign exposure borrowings limit Deviation from projections 6. Capital Adequacy The Firm to maintain minimum Capital adequacy coverage with adequate buffer at all times to meet CMA rules as well as to remain adequately solvent. Capital adequacy coverage 7. Operational risk loss Operational Risk Loss to be controlled with improvement in systems, policies and procedures of the Firm s business. Annual operational risk loss Number of fraud incidents 8. Regulatory Compliance Risk The Firm shall maintain zero tolerance for any violation on regulatory guidelines related to its business lines and rules issued by CMA. Instances of noncompliance with any applicable regulatory requirements Human Resources Risk Reputational Risk 11. Legal Risk Annual attrition rate shall be kept under check and unfulfilled approved vacancies at management level to be filled in stipulated interval The Firm shall have zero tolerance for earning bad name resulting from adverse media News/Statements or customer services complaints The Firm shall have no tolerance for risk arising from litigations Annual attrition rate (%) Unfulfilled approved vacancies at management level Adverse media news or customer complaints Number of litigations filed against the company Maximum value of legal claims settled Page 11

12 5. Credit Risk Credit risk is the risk of loss arising out of failure of counterparties to meet their financial or contractual obligations when due. The Company s credit exposures can be categorized as: Risk against listed equity kept under available for sale investments. Risk against placement with the financial institutions. Risk against corporate receivable. Risk against accrued income Credit Risk Management Currently, the Company uses the Standardized Approach prescribed under the Pillar I requirements of the CMA Prudential Rules to calculate regulatory capital for the credit risk faced by it. Please refer to Appendix 3 for more details Impairments and Past Due Claims The Company exercises judgment to calculate the impairment loss of available for sale investments and other underlying assets. The Company follows yearly review on impairments of assets and impairments resulting losses or gains are recognized through the statement of income. Following table give depict the breakdown of impairments: Reconciliation of Impairment: (Value in SAR as of 31 December) Details Opening impairment 25,000,000 10,260,000 5,610,000 Charge for the year 4,363,731 14,740,000 4,650,000 Reversal during the year Closing Impairment 29,363,731 25,000,000 10,260,000 Sector-wise and Geographical breakdown of Impairment charge: Total impairment related to investment property and completely in Kingdom of Saudi Arabia Use of Credit Rating Information The Company uses ratings of established credit rating agencies (CRA) before placing its deposits in Banks. Page 12

13 5.4. Geographic Concentration INVESCO has 89.9% of its credit risk exposure inside the Kingdom of Saudi Arabia and 10.1% outside. Country Amount in 000 SAR Percentage Kingdom of Saudi Arabia 192, % Cayman islands 21, % Egypt % Total 214, % 5.5. Credit Risk Exposures by Credit Quality Please refer to Appendix 4 for the details Credit Risk capital charge (All amounts in 000 SAR) Credit Risk Exposures to government, central banks 0 Exposures to corporates, admin bodies, NPO 2,002 Exposures to APs, banks 162 Listed shares 0 Investment funds 38,397 High risk investments 148,507 Securitizations, resecuritisations 0 Margin financing 0 Prohibited risks 12,192 Other on-balance sheet exposures 8,928 Off-balance sheet commitments 4,508 Credit Risks Capital Charge 214, Counterparty Credit Risk and Off BS Exposure The Company does not have transactions in OTC derivatives, repos and reverse repos and securities borrowing/lending, hence this section does not apply Credit Risk Exposures before/ after Credit Risk mitigation Please refer to Appendix 5 for the details. Page 13

14 6. Market Risk Market risk is defined as the risk of losses on financial instruments arising from changes in market prices. Market risk covers foreign exchange, equity price, commodity price and interest rate risks Market Risk Management There are no trading book positions in the Company and the investments are made in AFS category. There are investments in USD & other currencies for which foreign exchange risk capital is reserved as per CMA Pillar I minimum capital requirement Market Risk capital charge (All amounts in 000 SAR) Market Risks Equity Risk 0 Fund Risk 0 Interest Rate Risk 0 Commodities Risk 0 FX Risk 1,204 Underwriting Risk 0 Excess Exposure Risk 0 Settlement Risk 0 Market Risk Capital Charge 1,204 Page 14

15 7. Operational Risk Operational risk is operational risk is defined as the risk of loss resulting from inadequate or failed internal processes, human behavior, systems or from external events. This definition includes legal risk, but excludes strategic and reputational risk. Operational risk is inherent in all products, activities, processes and systems of the Firm Operational Risk Management The INVESCO will use Risk Assessment approach and Risk Control Matrix ( RCM ) as a tool to manage operational risks in its business activities, which starts with mapping all processes and sub-process to relevant departments and identifying potential risks for each sub-process and existing controls to mitigate/manage the risks. The Company recognizes that good management information systems (MIS) and a strong internal control culture and contingency planning are all crucial elements of effective operational risk management and takes measures to continually develop procedures and systems to support such requirements Individual line managers are responsible for identifying and assessing the operational risks of their area. This process will be conducted in a workshop with Risk Management Department support Operational Risk capital charge The Operational Risk capital charge is calculated as higher of the amounts under the following two approaches. 1. Basic Indicator Approach: Under the Basic Indicator Approach, 15% capital charge is calculated on average gross income of current and last two years, excluding gains and losses from non trading books. 2. Expenditure Based Approach: Under the Expenditure Based Approach, 25% capital charge is calculated on overhead expenses, as reported in most recent audited financial statements of the Company, except extraordinary expenses. 1. Basic Indicator Approach Average Risk charge (%) Capital requirements (SAR '000) Operating income (SAR '000) 24,136 15,018 7,236 15, , Standardised Approach 0 Corporate Finance (SAR '000) Research & Advisory (SAR '000) Trading & Sales (SAR '000) Custody (SAR '000) Asset Management (SAR '000) Expenditure-based approach 2017 Overhead expenses (SAR '000) 22, ,585 Total Operational Risks 5,585 Page 15

16 8. Liquidity Risk Liquidity risk is the risk resulting from the Firm s inability to fund its portfolio of assets, and meet obligations at appropriate maturities. Liquidity risk could also arise due to the inability of an institution to liquidate a position in a timely manner at a reasonable price. Market Liquidity Risk Market Liquidity Risk is the risk that the Firm is unable to liquidate or eliminate a position without incurring a significant loss Liquidity risk Management INVESCO has liquidity risk policy uses the following approaches: A. Liquidity Ratios B. Structural Liquidity Gap Analysis (Maturity Ladder Approach) C. Liquidity Pool D. Liquidity Contingency Plan INVESCO uses asset and liability mismatch model for calculating liquidity risk and related capital charge. If the cumulative gap in all buckets is positive this reflecting that the cash inflows are more than cash outflows. If there is negative gap in any periodic bucket the Company will calculate the charge of taking incremental borrowing and additional charge for funding cost. The time intervals have been defined as per the prudential rules of Capital Market Authority (CMA) as stated below: 1 Day > 1 day to 1 week >1 week to 1 month >1 month to 3 months > 3 months to 6 months > 6 months to 1 year > 1 year Non Maturity 8.2. Funding Sources The Company has funding source from operating activities, investing and financing activities. Page 16

17 8.3. Liquidity Ratio Analysis INVESCO maintains adequate liquidity to meet its day to day obligations and cash outflows. Below table shows the Liquidity ratio analysis for the Company: Indicator Value Comments Current asset/ current liabilities 0.65 The ratio has improved in 2017 due to the improvement of current assets. The major reason for the improvement of current assets is the increase of liquidity and reclassification of some investment properties as held for sale in Liquid assets / Total Assets 0.05 This reflects the cushion/comfort level in meeting its short-term liabilities and fixed cost payment. The ratio has improved in 2017 because of a higher amount of cash available at the end of the year. Page 17

18 9. Appendices 9.1. Appendix 1 - Disclosure on Capital Base (All amounts in SAR 000) CAPITAL BASE Tier-1 Capital Paid-up capital 200, ,000 Share premium 0 0 Reserves 18,540 18,548 Audited retained earnings (49,815) (8,441) Verified previous year profit/(loss) 0 0 Verified interim profit/(loss) 0 0 Loss offsetting against capital reduction 0 0 Tier-1 adjustment * 0 Deductions (-) 0 0 Tier-1 capital 168, ,107 Tier-2 Capital Subordinated loans 0 Cumulative preference shares 0 Revaluation reserves 59,569 45,281 Other deductions from Tier-2 (-) Deduction to meet Tier-2 capital limit (-) 0 Tier-2 capital 59,569 45,281 CAPITAL BASE 228, ,387 Page 18

19 9.2. Appendix 2 - Disclosure on Capital Adequacy (All amounts in SAR 000) Exposure Class Exposures before CRM SAR '000 Net Exposures after CRM SAR '000 Risk Weighted Assets SR '000 Capital Requirement SAR '000 Credit Risk On-balance Sheet Exposures Governments and Central Banks Authorised Persons and Banks 5,769 5,769 1, Corporates 2,003 2,003 14,302 2,002 Retail Investments 356, ,613 1,335, ,904 Securitisation Margin Financing Other Assets 9,078 9,078 63,774 8,928 Total On-Balance sheet Exposures 373, ,463 1,414, ,996 Off-balance Sheet Exposures OTC/Credit Derivatives Repurchase agreements Securities borrowing/lending Commitments Other off-balance sheet exposures Total Off-Balance sheet Exposures 32,200 4,508 Total On and Off-Balance sheet Exposures 1,446, ,504 Prohibited Exposure Risk Requirement 87,088 12,192 Total Credit Risk Exposures 1,533, ,697 Market Risk Long Position Short Position Interest rate risks Equity price risks Risks related to investment funds Securitisation/resecuritisation positions Excess exposure risks Settlement risks and counterparty risks Foreign exchange rate risks 58,489 1,204 Commodities risks. Total Market Risk Exposures 58,489 1,204 Page 19

20 Operational Risk 5,585 Minimum Capital Requirements 221,486 Surplus/(Deficit) in capital 6,809 Total Capital ratio (time) 1.03 Page 20

21 The Investor for Securities Company Pillar 3 Disclosure 31 December Appendix 3 - Disclosure on Credit Risk s Risk Weight Risk Weights Governments and central banks Administrative bodies and NPO Authorised persons and banks Margin Financing Exposures after netting and credit risk mitigation Corporates Retail Past due items Investments Securitisation Other assets Off-balance sheet commitments (All amounts in SAR 000) Total Exposure after netting and Credit Risk Mitigation 0% % 5,769 5,769 1,154 50% 100% 150% 200% 300% 91, , ,941 Total Risk Weighted Assets 400% 265,192 8, ,242 1,092, % 714% (include prohibited exposure) Average Risk Weight Deduction from Capital Base 2,003 12,192 8,837 23, ,487 20% 714% 386% 703% 400% 390% 1,533, , ,097 8,928 4, ,697 Page 21

22 The Investor for Securities Company Pillar 3 Disclosure 31 December Appendix 4 - Disclosure on Credit Risk s Credit Rating Exposure Class On and Off-balance-sheet Exposures Governments and Central Banks Credit quality step S&P Fitch Moody's Capital Intelligence Long term Ratings of counterparties (All amounts in SAR 000) Unrated AAA TO AA- AAA TO AA- Aaa TO Aa3 AAA A+ TO A- A+ TO A- A1 TO A3 AA TO A BBB+ TO BBB- BBB+ TO BBB- Baa1 TO Baa3 BB+ TO BB- BB+ TO BB- Ba1 TO Ba3 B+ TO B- B+ TO B- B1 TO B3 CCC+ and below CCC+ and below Caa1 and below Unrated Unrated Unrated BBB BB B C and below Unrated Authorised Persons and Banks 5,769 Corporates 2,003 Retail Investments 356,613 Securitisation Margin Financing Other Assets 9,078 Total 373,463 Page 22

23 The Investor for Securities Company Pillar 3 Disclosure 31 December Appendix 5 -Disclosure on Credit Risk Mitigation (CRM) (All amounts in SAR 000) Exposure Class Exposures before CRM Exposures covered by Guarantees/ Credit derivatives Exposures covered by Financial Collateral Exposures covered by Netting Agreement Exposures covered by other eligible collaterals Exposures after CRM Credit Risk On-balance Sheet Exposures Governments and Central Banks Authorised Persons and Banks 5, ,769 Corporates 2,003 2,003 Retail Investments 356, ,613 Securitisation Margin Financing Other Assets 9, ,078 Total On-Balance sheet Exposures 373, ,463 Off-balance Sheet Exposures OTC/Credit Derivatives Exposure in the form of repurchase agreements Exposure in the form of securities lending Exposure in the form of commitments *Other Off-Balance sheet Exposures Total Off-Balance sheet Exposures - - Total On and Off-Balance sheet Exposures 373, ,463 Page 23