Market Impact of TLAC Requirements. FIG DCM Bank Capital Solutions

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Market Impact of TLAC Requirements FIG DCM Bank Capital Solutions December 1, 15

RWA vs. SLR Driven TLAC Requirements Fed's SLR driven TLAC requirement is more stringent than FSB TLAC framework 5%.5% The Fed s RWA driven minimum TLAC requirements appear to be well aligned with FSB requirements The Fed s leverage ratio driven minimum TLAC (9.5%) materially exceeds FSB requirements (6.5%) The Fed s implied minimum TLAC debt (i.e. %) requirement is also more binding than FSB s % TLAC debt requirement % 15% 1% 5%.%.5% 1.5% 1.5% 9.5% 1.% 1.% % FSB Max.% 1.5% 1.5% 1.5% 1.% 1.% 1% FSB Min 1.5%.5%.5%.% 1.5% 16.5% 9.% 9.% 9.%.%.5%.% 11.% 11.5% 11.5% 1.5% 1.% 9.5% Key 1 TLAC % 1% JPM C BAC WFC MS GS STT BK LTD External LTD requirement (RWA approach 6.% + GSIB surcharge) % 6%.5%.5%.5%.5%.5%.5%.5%.5% FSB SLR 6.5% Tier 1 Capital Capital Conservation Buffer (.5% + GSIB surcharge) 1.5% Additional Tier 1 % % 5.% 5.% 5.% 5.% 5.% 5.% 5.% 5.%.5% CET1 Minimum % JPM C BAC WFC MS GS STT BK 1. GSIB surcharge applied to minimum LTD requirement and the capital conservation buffer is based on estimates disclosed with the GSIB capital surcharge final rule in July 15. 1

U.S. G-SIBs Appear to be Well Positioned Proposed rule is fairly benign relative to market expectations We estimate that the US G- SIBs will need $16bn of additional TLAC, $6bn of which is capital shortfall and $1bn of which is due to LTD shortfall Some of the LTD shortfall can be met by refinancing bank level debt with Holdco leading to ~bn incremental supply Capital & TLAC Shortfall Need ($Bn) LTD Shortfall 1 1 1 15 16 16 9 19 LTD Shortfall 1 1 1 Additional 11 6 1 TLAC Qualifying 16 1 5 Capital Shortfall 1 59 1 69 ($Bn) Tier JPM BAC Additional Tier 1 C Common WFC Equity Tier 1 ($Bn) GS MS 6 5 1 1 6 1 5 19 1 1 6 1 6 5 16 1 15 15 11 1 1 1 16 1 1 1 1 1 11 1 5 6 59 JPM BAC C WFC GS MS Avg. Annual Sr. Issuance $1.5 $9. $. $1.5 $. $19.5 $. $. LTD Need as Multiple 1.x.9x n/a.x n/a n/a n/a 1.x Sr. Bank Debt Out $5. $11.5 $. $1. n/a n/a n/a n/a % of LTD Need 5% 6% n/a 5% n/a n/a n/a n/a BK STT Source: Bloomberg, SNL, Company Filings as of 6//15; debt outstanding as of 1//15. 1. We estimate that 1% TLAC / Leverage Exposure is binding for JPM relative to 16% RWA and for BNY & STT relative to 16 & 1% RWA

The Canadian D-SIBs Have Excess Wholesale Funding Canadian D-SIBs have excess wholesale funding and regularly access the unsecured funding market globally Given their regular access to the capital markets and upcoming maturity profile, the Canadian banks would be able to meet TLAC needs through refinancing However, the grandfathering of the outstanding senior unsecured has made the situation more complicated Capital Structure & TLAC Need at 16 / 1% RWAs (6. / 6.5% SLR) 1 (CAD Bn) 16 1 1 1 6 Incremental Grandfathered Senior Debt TLAC Required to Reach 1% TLAC Required to Reach 16% Tier Additional Tier 1 Common Equity Tier 1 5 6 1 1 1 9 5 6 RBC BNS TD 6 5 1 5 5 1 16 BMO CIBC CCDJ NBC 1 6 Avg. Annual Sr. Issuance $1. $1. $. $6. $.5 $.9 $. 1% TLAC Need as Multiple 1.1x.6x.x.x.X 1.x.x Source: Bloomberg, SNL, Company Filings as of /1/15; debt outstanding as of 1//15. 1. We do not anticipate a 6.5% leverage requirement to be binding for any Canadian bank

Meaningful Uncertainty Remains in Europe For the European banks included in our analysis below, we estimate a total TLAC need at 1% of RWAS to be about.5bn The criteria by which debt will qualify for TLAC in Europe will vary from jurisdiction to jurisdiction For example, Deutsche Bank appears to have ample senior unsecured and is in a regime that already has a clear solution CS & UBS, on the other hand, will need to issue HoldCo debt to meet the newly announced 1% leverage requirement for Swiss TLAC Capital Structure & TLAC Need at 16 / 1% RWAs (6. / 6.5% SLR) 1 (EUR Bn) 5 TLAC Shortfall 19 TLAC Shortfall Additional TLAC Qualifying Debt 1 1 Tier 6 Additional Tier 1 16 5 Common Equity Tier 1 1 1 9 1 1 11 15 16 5 95 16 1 11 1 6 1 5 5 56 1 15 16 96 6 1 1 1 1 9 11 1 16 9 11 1 9 19 19 15 59 5 9 9 6 5 5 59 66 6 6 HSBC BNP BARC SAN CA DB RBS BPCE UNI BBVA SG STAN CS UBS NDA Avg. Annual Sr. Issuance 1. 1.6.5.. 16..6 1.9 1. 1.5 1....6 16. Shortfall to 1% RWAs 56.9 6.1 1.. 1.1-1. 1. 9.6. 5.6 -. Source: Bloomberg, SNL, Company Filings as of 6//15; debt outstanding as of 1//15. 1. We estimate that the 6.5% leverage requirement is binding vs. 1% for BARC, and the 1% requirement is binding vs. both 16 and 1% for CS and UBS.. Hatch pattern represents senior debt of banks / in jurisdictions where the treatment is uncertain.

Spread Moves in U.S. Bank Senior We observed a modest 5 to 15 bps of relative widen in US Senior Holdco Spreads US$ domestic market (Spread to Treasury) Euro market (Spread to Swap) 1 Pre-TLAC Jan Aug 1 JPM/ PNC Spread= -1bps FSB to Fed Proposal Sep 1 Sep 15 JPM./ PNC Spread= 15-5bps Post Fed -NPR Oct-Dec 15 JPM./ PNC 5-15bps 1 16 Pre-TLAC Jan Aug 1 GS /JPM Spread= 5-5bps FSB to Fed Proposal Sep 1 -Sep15 GS/JPM Spread= 15-5ps Post Fed - NPR Oct-Dec 15 GS/JPM =5-5ps 15 15 1 FSB Proposal Nov 1, 1 JPM./ PNC= 1bps 1//15 JPM/PNC = 5bps 1 1 FSB Proposal Nov 1, 1 GS /JPM=5bps Fed -NPR Oct-Dec 15 GS/JPM ~bps 1 11 11 9 Fed NPR Oct JPM./ PNC= 15bps 1 9 1/15 GS./ JPM ps Jan-1 Feb-1 Mar-1 Apr-1 May-1 Jun-1 Jul-1 Aug-1 Sep-1 Oct-1 Nov-1 Dec-1 Jan-15 Feb-15 Mar-15 Apr-15 May-15 Jun-15 Jul-15 Aug-15 Sep-15 Oct-15 Nov-15 Dec-15 Jan-1 Feb-1 Mar-1 Apr-1 May-1 Jun-1 Jul-1 Aug-1 Sep-1 Oct-1 Nov-1 Dec-1 Jan-15 Feb-15 Mar-15 Apr-15 May-15 Jun-15 Jul-15 Aug-15 Sep-15 Oct-15 Nov-15 Dec-15 JPM Sep- PNC Nov- GS Feb- JPM Feb- Source: Bloomberg Source: Bloomberg 5

Spreads moves in German bank Senior Confirmation of Bail-in risk has seen German senior spreads widen by to bps on a relative basis US$ domestic market (Spread to Treasury) Euro market (Spread to Swap) 1 1 1-Mar: German Draft Law DB / Rabobank Spread = bps 1 9 1-Mar: German Draft Law DB / Rabobank Spread = -11bps 1 11 Current Current DB / Rabobank Spread = bps 1 DB / Rabobank Spread = 5bps 6 9 5 6 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov DB Feb-19 RABOBK Jan-19 DB Jan- RABOBK May- Source: Bloomberg Source: Bloomberg 6

Impact of NPR on Issuance Volume November and December GSIB Senior Holdco issuance has been impacted by the Fed's NPR The Fed's NPR provided the market with clarity on the total amount of required TLAC and LTD Monthly Senior HoldCo Issuance 1-15.% 5.% 1 1 15 However, the qualification criteria (no cross-defaults, must be governed by U.S. law, etc.) have left issuers with meaningful questions on whether currently outstanding and interimissued debt will qualify or be grandfathered.% 15.% 1.% 5.% Nov and Dec made up 5.6% of supply in 15 vs. 1.5% and.5% in 1 and 1, respectively This has resulted in less supply from GSIBs since the NPR.% Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec GSIB Senior HoldCo Issuance Since November 15 Issue Date Issuer Ranking Rating Coupon (%) Size ($mm) Maturity Date BANK OF NY MELLON 11/19/15 CORP Senior HC A1/A.5 11// 11//15 WELLS FARGO & COMPANY Senior HC A/A.55 1 1// 11//15 WELLS FARGO & COMPANY Senior HC A/A 1.6 1// 1/1/15 CITIGROUP INC Senior HC Baa1e/BBB+.5 165 1//1 1/1/15 CITIGROUP INC Senior HC A/BBB+ 1.1 5 1//1

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