U.S. Banking Sector: Progress on Resolution, Still Fed Up With Low Rates Financial Institutions Ratings November 18, 2015

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1 U.S. Banking Sector: Progress on Resolution, Still Fed Up With Low Rates Financial Institutions Ratings November 18, 2015 Permission to reprint or distribute any content from this presentation requires the prior written approval of Standard & Poor s. Copyright 2015 by Standard & Poor s Financial Services LLC. All rights reserved.

2 U.S. Global Systemically Important Bank Ratings On CreditWatch Eight U.S. GSIB holding company ratings placed on CreditWatch with negative implications following the Fed s NPR. Our review will likely result in extraordinary government support no longer being factored into the Holdco ratings Potential positive rating actions on the operating entities of some banks reflects stronger fundamentals, ALAC criteria uplift Reviewing our treatment of NDSD, as we are considering whether these instruments could absorb losses ahead of nonviability Expect to resolve the CreditWatch by early December, as we assess the effectiveness of the U.S. resolution plan, apply ALAC 2 Company Current U.S. Global Systemically Important Bank Ratings SACP/unsupporte d GCP OpCo Ratings Notches of gov. support (#) Long-term rating (HoldCo) Short-term rating (HoldCo) Bank of America Corp. a- A/Watch Pos/A-1 1 A-/Watch Neg A-2 Citigroup Inc. a- A/Watch Pos/A-1 1 A-/Watch Neg A-2 Wells Fargo & Co. a+ AA-/Stable/A-1+ 1 A+/Watch Neg A-1 JPMorgan Chase & Co. a A+/Stable/A-1 1 A/Watch Neg A-1 / Watch Neg Morgan Stanley bbb+ A/Watch Pos/A-1 2 A-/Watch Neg A-2 The Goldman Sachs Group Inc. bbb+ A/Watch PosA-1 2 A-/Watch Neg A-2 Bank of New York Mellon Corp. a+ AA-/Stable/A-1+ 1 A+/Watch Neg A-1 State Street Corp. a+ AA-/Stable/A-1+ 1 A+/Watch Neg A-1 SACP--Stand-alone credit profile. GCP--group credit profile. Opco--Operating company. holdco--holding company. The GCP is Standard & Poor's opinion of a groups' creditworthiness as if it were a single legal entity. Unsupported GCP designates our opinion of a group's creditworthiness excluding the likelihood of extraordinary government support, ALAC or negative intervention from a government or wider group. ALAC- Additional loss absorbing capacity as defined by our criteria. Source: Standard & Poor s Financial Institutions Ratings.

3 Expectations Going Into 2016 Revenue We expect core profitability to improve slightly in 2016 based on expectations of earning assets growth and better noninterest income. NIM compression will constrain results longer than we had originally envisioned. Expenses Banks will need to focus on keeping operating costs low. Regulatory compliance costs remain elevated, but potential legal accruals will be less punitive Credit Quality Leading indicators of asset quality still appear to be mostly benign but there are risks to the downside as interest rates rise, demand improves and lending standards continue to ease. Capital Capital ratios remaining mostly steady because most banks we rate already exceed their minimum required regulatory ratios. But higher finalized capital buffers for US GSIBs should underpin accretion. Funding Most banks largely asset sensitive; Funding mix could change when interest rates eventually increase; Outflows of noninterest-bearing deposits out of larger LCRconstrained banks into regional banks or other nonbanks Liquidity Continued robust levels of HQLA and a focus on LCR compliance 3 Source: Standard & Poor s Financial Institutions Research

4 Q3 Results

5 Q3 Revenue Trends Stable Across Regional Banks, Broker Dealers Continue to Experience Volatility 15.0% 10.0% 5.0% Total Revenue Growth Y-o-Y Q3 Results (y/y) Trust Banks: +2% 0.0% Regional Banks: +3.6% -5.0% -10.0% -15.0% Money Center Banks: -4.7% Broker Dealers: -15% -20.0% 2013Q3 2013Q4 2014Q1 2014Q2 2014Q3 2014Q4 2015Q1 2015Q2 2015Q3 Money Centre Broker Dealers Trust Banks Regionals Fee income declined as mortgage originations and capital markets weaken; Modest loan growth helped marginally 5 Source: S&P Capital IQ and SNL Rated banks which have released Q3 earnings BAC, C, JPM, GS, MS adjusted for DVA

6 Capital Markets Revenue Weighed Down By FICC Y-o-Y Change in Capital Markets Revenues 60% 50% 40% 30% 20% 10% 0% -10% -20% -30% 4Q12 1Q13 2Q13 3Q13 4Q13 1Q14 2Q14 3Q14 4Q14 1Q15 2Q15 3Q15-40% FICC Equity Investment Banking Total Capital Markets Revenue Weaker FICC and Underwriting revenues, offset advisory and equity trading 6 Source: Company Reports Includes BAC, C, GS, JPM, MS FICC, Equity, Investment Banking

7 Advisory And Equities Remain Strong, As U.S. Banks Gain Market Some European banks have reduced capital markets activity as higher regulatory capital requirements have made it more difficult to generate desirable returns Solid performance in the capital markets, all else equal, has helped contribute to some recent positive rating actions on large U.S. investment banks We expect 2015 capital markets revenue to be flat to down 5% (compared with 2014), largely because of recent market upheaval We look for capital markets revenue to be up modestly in

8 Modest Loan Growth Partially Offsetting NIM Pressures $ Trillions Median Rated Bank NIM vs. Total Loans (Gross) 2009Q1 2009Q2 2009Q3 2009Q4 2010Q1 2010Q2 2010Q3 2010Q4 2011Q1 2011Q2 2011Q3 2011Q4 2012Q1 2012Q2 2012Q3 2012Q4 2013Q1 2013Q2 2013Q3 2013Q4 2014Q1 2014Q2 2014Q3 2014Q4 2015Q1 2015Q2 2015Q NIM(%) Q3 Q-o-Q Loan Growth Regional Banks: +1.6% Money Center Banks: +0.7% Regional Banks Total Gross Loans Regionals Bank NIM Money Center Banks - Total Gross Loans Money Center Banks NIM Bank Group Median NIM 3Q'14 2Q'15 3Q'15 Money Center Banks* 2.29% 2.22% 2.16% Regional Banks 3.20% 3.16% 3.10% * Adj. for the impact of BAC premium Amortization 8 Source: S&P Capital IQ and SNL All rated banks, excluding GS & MS

9 Credit Provisions Poised To Rise $ Billions % 40.0% 35.0% % % 20.0% % % 5.0% - 0.0% Loan Loss Provisions ($ billions) Avg PTPP Margin 9 Source: S&P Capital IQ and SNL All rated banks, excludes MS & GS

10 Focus Remains On Containing Operational Costs Median Efficiency Ratio For Rated Banks Regional Banks Money Center Banks Strict cost controls continue to support operating efficiency, as rates expected to remain lower 10 Source: S&P Capital IQ and SNL

11 Asset Quality

12 Asset Quality Unlikely To Improve From Current Levels 4.00% 3.50% Non Accruals and NCOs to Total Loans 3.00% 2.50% 2.00% 1.50% 1.00% 0.50% 0.00% NonAccruals/ Total Loans (Gross) Annualized Net Charge-offs/ Avg Loans (Gross) Asset quality remained benign, with little room to improve further 12 Source: S&P Capital IQ and SNL All rated banks, excludes GS & MS

13 Reserve Releases Becoming Less Of A Tailwind 60.0% Reserve Releases/Pre-tax Profit 50.0% 40.0% 30.0% 20.0% 10.0% 0.0% Contribution of reserve releases to pre-tax profits is declining 13 Source: S&P Capital IQ and SNL All rated banks, excludes GS & MS

14 Net Charge-offs Unsustainably Low In Most Asset Classes Loan Category NCO Rate 2015:Q2 Q/Q Change LT Median (1993- Present) Gap (Current Quarter v. Median) Historic al Peak Total Real Estate Loans 0.13% -0.03% 0.16% -0.03% 2.67% Construction and Development Loans 0.00% 0.13% 0.15% -0.15% 8.02% Real Estate Loans Secured by 1-4 Family Residential Properties 0.19% -0.07% 0.15% 0.04% 2.47% Home Equity Lines of Credit 0.39% -0.07% 0.22% 0.17% 3.13% Real Estate Loans Secured by Nonfarm Nonresidential Properties 0.09% 0.03% 0.12% -0.03% 2.02% Commercial & Industrial Loans 0.24% 0.06% 0.53% -0.29% 2.72% Credit Cards 3.03% 0.05% 4.44% -1.41% 13.21% Other Loans to Individuals 0.58% -0.10% 1.08% -0.50% 3.04% Total Loans & Leases 0.42% -0.01% 0.61% -0.19% 3.00% 14 Source: Standard & Poor's Financial Institutions Research; FDIC QBP

15 Capital, Funding, And Liquidity

16 Capital Should Stabilize Near Current Levels 10% S&P Median Risk Adjusted Capital Ratios 40% 9% 35% 30% 8% 25% 20% 7% 15% 6% 10% 5% 5% 'Q2 0% Money Center Bank Simple Avg. Regional Bank Simple Avg. Median Common Dividend payout Ratio (Right Scale) 16 Source: Standard & Poor s, S&P Capital IQ and SNL Based on preliminary Q215 RACs. All rated banks, excludes GS, MS, Trust Banks

17 Fed Finalized G-SIB Surcharges At Levels Higher Than The Global Average Company --Tier 1 Common Equity Ratio Basel III Fully Phased-in-- Q215 Q315 QoQ Change (in bps) Approach US Fed Final GSIB Surcharge (Method 2) Basel III Minimum* Current Surplus (deficit) from fully phased in Basel III CET1 Requirement* Bank of America 10.30% 10.80% 50.0 A 3% 10.0% 0.80% Citigroup 11.37% 11.60% 23.0 S 3.50% 10.5% 1.10% JPMorgan Chase 11.00% 11.40% 40.0 A 4.0% 11.0% 0.40% Wells Fargo % 10.70% 15.0 S 2% 9.0% 1.70% Morgan Stanley 12.50% 12.40% (10.0) A 3% 10.0% 2.40% Goldman Sachs 11.00% 11.70% 70.0 S 3% 10.0% 1.70% Bank of New York Mellon 9.90% 9.30% (60.0) A 1% 8.0% 1.30% State Street 10.90% 11.2% 30.0 S 1.50% 8.5% 2.70% Source : Company filings; * Including the final Fed GSIB surcharge A: Advanced Approach, S: Standardized Approach The Fed released final rules on US bank holding company GSIB surcharges which are on average 1.8x the BCBS/FSB G-SIB surcharge for the group. The surcharges will be phased in beginning on January 1, 2016, becoming fully effective on January 1, The GSIB surcharge could be incorporated in the CCAR earliest in Source: Company Filings

18 Banks Have Improved Supplementary Leverage Ratios Company Q3'15 Holdco. Supplementary Leverage Ratio (%) Double Leverage Ratio (%) Q Bank of America Corp. 6.40% Citigroup Inc. 6.80% JPMorgan Chase & Co. 6.30% Wells Fargo & Co. 7.80% Goldman Sachs Group Inc. 5.80% Morgan Stanley 5.90% Bank of New York Mellon Corp. 4.80% State Street Corp. 5.40% Based on the banks estimated supplementary leverage ratio rules (fully-phased in basis) 18 Source: Company Filings, Standard & Poor's Financial Institutions Research

19 Funding & Liquidity Metrics Remain At Improved Levels 250 Net Stable Funding Ratio 200 % Money Center Banks Regional Banks Broker/Dealers Trust Banks Q2 14 Broad Liquid Assets to Short Term Wholesale Funding Ratios x Money Center Banks Regional Banks Broker/Dealers Trust Banks Q2 19 Source: Company Filings, Standard & Poor s Financial Institutions Research; Simple average of funding & liquidity ratios

20 U.S. Fed TLAC & S&P Additional Loss Absorbing Capacity (ALAC)

21 Estimating Potential TLAC Requirements For Systemically Important Banks Estimates of TLAC Shortfalls ($mil) Based on June 2015 Data BAC C JPM WFC GS MS BK STT Total TLAC Requirement Without Considering LTD Constraint Min TLAC by RWA 18% 18% 18% 18% 18% 18% 18% 18% Min TLAC by Leverage 9.5% 9.5% 9.5% 9.5% 9.5% 9.5% 9.5% 9.5% Min total TLAC/RWA 22.0% 22.5% 23% 21.5% 22% 25.8% 23.8% 24.8% TLAC Required - 18,070 31,051 39, ,521 6,189 98,085 Binding Constraint at 2022 RWA RWA RWA RWA RWA Leverage Leverage Leverage Minimum Long term Debt Calculation Min LTD by RWA 9.00% 9.50% 10.00% 8.00% 9.00% 9.00% 7.00% 7.50% Min LTD by Leverage 4.50% 4.50% 4.50% 4.50% 4.50% 4.50% 4.50% 4.50% Implied Long-Term Debt Shortfall - 19,244 33,543 24, ,919 6,712 85,427 Total Additional LTD and Tier 1 Capital Needed - 19,244 33,543 39, ,521 6, ,284 Constraining Factor None LTD LTD TLAC None None TLAC LTD Notes: 1. Assumes JPM's GSIB surcharge has fallen to 4%. 2. Does not incorporate any assumption that the companies could reduce total leverage exposure. 3. Does not exclude non-us jurisdictional debt 4. Excludes structured debt wherever disclosure is available 21 Source: Company Filings; US Fed TLAC NPR; Data as of 06/30/2015;

22 Estimated ALAC - U.S. Banks 20.00% 18.00% 16.00% 14.00% 12.00% 10.00% 8.00% 6.00% 4.00% 2.00% 0.00% Bank of America Corp. U.S. G-SIB Est. S&P Additonal Loss Absorbing Capacity (ALAC) Citigroup Inc. JPMorgan Chase & Co. Wells Fargo & Co. Goldman Sachs Morgan Stanley Group Inc. (The) Bank of New York Mellon Corp. Excess TAC Sub debt Holdco Senior Debt (ex Structured debt) at holdco State Street Corp. 2 ALAC Notches 1 ALAC Notch Source: Company Filings; Data as of 06/30/2015; Calculations based on Est Q215 S&P RWA; Excludes structured debt, debt maturing in months >0.5% of S&P RWA, and TruPs; includes non U.S. jurisdictional debt We may adjust the ALAC thresholds based on qualitative factors including material differences between the effective ALAC versus the ALAC/S&P RWA metric, large maturities of ALAC instruments within five years, or any other material obstacle to deploying ALAC flexibly within a group in a stress scenario. 22 Source: S&P Capital IQ and SNL, Y9LP filings, Company Filings Data as of 06/30/2015; * Based on Est Q215 S&P RWA

23 U.S. GSIB Non Deferrable Sub-debt Ratings For Illustrative Purposes Only NDSD / Preferred Ratings Bank with an SACP of "a-" Operating Company Holding Company AA- A+ ICR A ICR NDSD* A- NDSD ICR BBB+ NDSD** NDSD ICR BBB NDSD* ** BBB- Preferred Preferred BB+ Preferred Preferred BB BB- * If subordinated debt treated as conventional debt and maximum notches of ALAC applied to operating company rating. ** If subordinated debt treated as a hybrid. Preferred ratings are already treated as hybrid, notched down for subordination, and for coupon nonpayment, write-down, and conversion risks Non-deferrable Subordinated Debt Ratings Current Ratings Assuming gov t support removed, ALAC implemented 23 Source: Standard & Poor s Financial Institutions Research.

24 Key Credit Concerns

25 Underwriting Standards Remain Broadly Accommodative Percentage of Banks Tightening Standards for Various Types of Loans Residential Mortgages CRE (Non-Farm Non Res) Credit Cards 10 % Changes in C&I Lending Standards Vs. Loan Demand Net Tightening in Lending Standards to Large and Midsize Businesses Net Stronger Demand for C&I Loans By Large and Midsize Businesses % Jan-2010 Apr-2010 Jul-2010 Oct-2010 Jan-2011 Apr-2011 Jul-2011 Oct-2011 Jan-2012 Apr-2012 Jul-2012 Oct-2012 Jan-2013 Apr-2013 Jul-2013 Oct-2013 Jan-2014 Apr-2014 Jul-2014 Oct-2014 Jan-2015 Apr-2015 Jul-2015 Oct 2015 Jan-2010 Apr-2010 Jul-2010 Oct-2010 Jan-2011 Apr-2011 Jul-2011 Oct-2011 Jan-2012 Apr-2012 Jul-2012 Oct-2012 Jan-2013 Apr-2013 Jun-2013 Oct-2013 Jan-2014 Apr-2014 Jul-2014 Oct-2014 Jan-2015 Apr-2015 July 2015 Oct 2015 CRE demand increased, and banks reported somewhat easier standards for cards and auto loans 25 Source: Standard & Poor's Financial Institutions Research; Federal Reserve Senior Loan Officer Survey October 2015; GSE-Eligible Mortgage as a proxy for prime residential mortgages from Q414 reflecting changes in SLOS reporting

26 Leveraged Loans And Energy Dominate The 2015 SNC Review Classified & Special Mention Special mention(left scale) Classified(left scale) Criticized assets as % of committed(right scale) 25% 20% 15% 10% 5% 0% Criticized Assets as % of Committed 26 Source: 2015 SNC review, OCC, Standard & Poor s Financial Institutions.

27 Sensitivity Of Earnings To Changes In Interest Rates Several banks increased their asset sensitivity in the third quarter compared to the second quarter Most banks remain asset sensitive by their own measure, but we believe these assumptions reflect divergent deposit beta assumptions. S&P in-house economists project a 25-basis-point rate hike in December. We continue to surveil for rise in duration, higher deposit sensitivity, and high reliance on more costly wholesale funding Banks Scenarios Large Banks Interest Rate Sensitivity Q315 Change in net interest income due to 100- basis-point parallel rise in rates across the yield curve (%) Q215 Change in net interest income due to 100-basispoint parallel rise in rates across the yield curve (%) Q Net interest income/revenues (%) Q3 impact on Basel III common equity Tier 1 ratio from reduction in unrealized gains Non interest Bearing deposits/total deposits Bank of America Corp. Instantaneous 9.60% 11.30% 47% 0.16% 36.69% Citigroup Inc. Instantaneous 4.20% 4.50% 59% 0.06% 23.73% Wells Fargo & Co.* Varying, over 24 months Nd Nd 80% -0.07% 28.26% U.S. Bancorp Instantaneous 1.70% 1.70% 62% 0.06% 28.30% PNC Financial Services Group Gradual, over 12 months 1.70% 2.70% 46% 0.05% 31.94% JPMorgan Chase & Co. Instantaneous 6.20% 6.90% 55% -0.03% 33.40% Capital One 1 Instantaneous 3.00% 3.40% 60% 0.04% 11.77% BB&T Corp Gradual, over 12 months 1.60% 1.90% 55% 0.05% 30.24% SunTrust Instantaneous 2.30% 3.20% 52% 0.12% 28.34% Source: Company filings. N.D.--Not disclosed. All numbers Q3 unless specified otherwise. *Wells Fargo discloses the impact of varying degrees of rising short-term (up 25 bps) and longterm interest rates (up 50 bps) on its net income over a 24 month horizon. 1 Capital One discloses impact on 200-basis-point parallel shift and USB discloses a 50 basis-point parallel shift impact. 2 For BBT capital impact represents BIII transitional RWA, for all others it is fully-phased in BIII RWA. 27

28 Cyberattack Is A Rising Threat For Banks Technology advances in the banking industry bring opportunities and challenges Sources of cyberattack could stem from: hostile nation-states, terrorist organizations, activists or hackers, industrial/economic espionage, and company insiders Significant cyberattacks could cause significant reputational, legal and monetary damages We view the global credit risk of a cyberattack as medium, for now Weak cybersecurity is an emerging risk that could result in negative rating actions on a individual bank, either: Before an attack, where we assess a bank is ill-prepared to withstand a cyberattack After an attack, where we believe the attack has caused significant reputational issues that could result in a major loss of customers or if the monetary or legal losses significantly hurts capital 28

29 M&A Intensifies After Long Lull After a prolonged period of quiet, there have been greater signs of life on the bank M&A front 2015 is poised to be the strongest year for bank M&A since the financial crisis. We see the potential as greater for smaller banks than for bigger banks mega deals will be hard to pull off, still. If loan growth is softer than expected, could prompt regional banks to acquire greater scale via acquisition. Credit leverage will offer little support to bank earnings going forward, so one way for banks to boost earnings is use acquisitions to generate greater operating leverage. Buyer Name Target Name Target: Assets ($bn) Announcement Date Deal Value ($M) Price/ Tangible Book (%) Royal Bank of Canada City National Corporation /22/ KeyCorp First Niagara /30/ New York Community Astoria Financial Corporation /29/ BB&T Corporation National Penn Bancshares, Inc /17/ Western Alliance Bridge Capital Holdings 1.8 3/9/ Valley National Bancorp CNLBancshares, Inc /27/ Source: S&P Capital IQ and SNL, Company Filings

30 Q&A

31 Appendix

32 Current U.S. Bank Holding Company Ratings Distribution 25% HoldCo Ratings Distribution 20% 15% 10% 5% 0% AA+ AA AA- A+ A A- BBB+ BBB BBB- BB+ BB BB- B+ B B- 12/31/ /17/ Source: Standard & Poor s Financial Institutions Research. Includes Puerto Rican banks. As of 11/17/2015

33 Current Bank Holding Company Ratings Outlooks Ratings Outlook Distribution 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% Money Center Banks 3 Regional Banks Trust Banks 1 2 Broker Dealers 2 Total HoldCo Ratings Positive Stable Negative Money Center Banks: BAC, C, JPM Broker Dealers: MS, GS Trust Banks: BK, NTRS, STT 33 Source: Standard & Poor s Financial Institutions Research. Includes Puerto Rican banks As of 11/17/2015

34 US BICRA: Comparative View Of Global Economic Risk And Industry Risk Scores Source : Standard & Poor s, October 2015 Source : Standard & Poor s, August 2015 We classify the banking sector of the U.S. (AA+/Stable/A-1+) in group '3' under our Banking Industry Country Risk Assessment (BICRA) 34 Source: Standard & Poor s Financial Institutions Research.

35 Industry Profit Forecast Remains Modestly Optimistic (%) 40% 120 (USD Bn) 35% % 80 25% 60 20% % 0 10% -20 5% -40 0% F 2016 F 2017 F Pretax return on revenues (Left Scale) Core ROR (Left Scale) LLP minus NCOs (Right Scale) 35 Source: Standard & Poor's Financial Institutions Research; FDIC F = Forecast, E = Estimate

36 Legal Expenses Should Remain Less of A Headwind in 2016 Banks Reasonably Possible Litigation Costs Beyond Current Reserves ($ bn) 2014 Q Q Q Q Q Q3 JPMorgan Chase & Co Citigroup Inc Goldman Sachs Group Inc./The Bank of America Corp Wells Fargo & Co Bank of New York Mellon Total Banks Litigation Expenses ($ bn) 2014 Q Q Q Q Q Q3 Bank of America Corp Citigroup Goldman Sachs Group JPMorgan Chase & Co Total Source: Standard & Poor s Financial Institutions Research, Company Filings. MS & WFC do not disclose litigation expenses regularly

37 Sub-Groups Of Rated Banks Regional Banks Money Center Banks Bank of America Corp. Citigroup, Inc. JPMorgan Chase & Co. Trust Banks Bank of New York Mellon Northern Trust State Street Broker Dealers Goldman Sachs Morgan Stanley Large Regional Banks American Express Co. BB&T Corp. Capital One Financial Corp. Comerica Inc. Fifth Third Bancorp Huntington Bancshares Inc. KeyCorp M&T Bank Corp. PNC Financial Services Group Regions Financial Corp. SunTrust Banks Inc. U.S. Bancorp Wells Fargo & Co. Zions Bancorporation Associated Banc Corp. Astoria Financial Corp. BancorpSouth Inc. BancWest Corporation Bank of North Dakota BBVA Compass Bancshares, Inc. BMO Financial Corp. BOK Financial Corp. Commerce Bancshares Inc. Cullen/Frost Bankers Inc. Discover Financial Corp East West Bancorp. FirstBank Puerto Rico First Citizens BancShares First Horizon National Corp. First Midwest Bancorp Inc. First National Bank of Omaha, Inc. First Niagara Financial Group Inc. First Republic Bank FirstMerit Corp. Hancock Holding Co. HSBC USA Inc. MUFG Americas Holdings Corporation New York Community Bancorp Inc. OFG Bancorp Popular Inc. Peoples United Financial Inc. Citizens Financial Group Santander Bancorp Santander Holdings USA, Inc. S&T Bancorp Inc. SVB Financial Group Synovus Financial Corp. Synchrony Financial TCF Financial Corp. Texas Capital Bancshares, Inc. Trustmark Corp. UMB Financial Corp. Valley National Bancorp Webster Financial Corp. Western Alliance Bank 37 Data in the presentation may exclude certain domestic subsidiaries of foreign banks & certain other banks that do not file Y9C s. Large Regional Banks included with Regional Banks throughout in the presentation.

38 Related Reports U.S. Global Systemically Important Bank Ratings On CreditWatch Pending Review Of Regulators' New Resolution Plan Details 02-Nov-2015 Bank Bail-in Should Become A More Credible Option Under The FSB's Final Total Loss- Absorbency Standard 09-Nov-2015 How Shifts In The Capital Markets Business Can Affect The Ratings On Global Investment Banks 13-Oct-2015 How Ready Are Banks For The Rapidly Rising Threat Of Cyberattack? 28-Sep-2015 Is Illiquidity The Market's Natural State? 02-Nov U.S. Banking Barometer: September Oct-2015 Banking Industry Country Risk Assessment: U.S. 20-Aug-2015 Top 100 Banks: Risk-Adjusted Capital Ratios Continue To Differentiate Banks 11-Aug-2015 Bank Rating Methodology And Assumptions: Additional Loss-Absorbing Capacity 27-April Fannie, Freddie, And The FHLB System: Plus Ca Change Oct-2015 U.S. Weekly Economic Roundup: She Loves Me, She Loves Me Not 30-Oct-2015 Visit Financial Institutions - S&P Ratings 38

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