Page 1 of 20 Current mode: Edit URUGUAY Depository Review and Risk Evaluation Service CBU Qualified Assessment Publication Date: March 2011 Support Bank(s) Instruments Supported Equities Corporate Debt Money Markets Government Debt Role of the Depository The Central Bank of Uruguay (CBU) was established in 1967 as an autonomous entity of the Uruguayan State. The BCU's Charter was enacted on 30 March 1995 (Law 16,696). It's government and management are in charge of a three members Board of Directors, wich is responsible for the policy and general administration of the Bank. In addition to performing the functions of a central bank, it regulates and supervises the financial system (institutions for financial intermediation, insurance companies, investment and pension funds, stock exchanges and its intermediaries). As well as its market supervision and regulatory functions, the central bank participates in the capital markets as issuer and financial agent of securities issued by the State of Uruguay (Bonos de Tesoro and Letras de Tesoreria). It acts as bookentry registrar for these securities and for those issued by the Central Bank and as a global custodian for Pension Fund investments. The central bank has a unilateral processing link with Clearstream Banking S.A. Transfers between the two institutions occur in batches. The relationship CBU has with Clearstream Banking is governed by the negotiated terms and conditions of participation between the depositories. Around 92% of issued government securities are either dematerialised or immobilised within the Central Bank. The remaining positions are kept in physical form and maintained with the investor or their local bank. CBU is developing a new CSD for all Uruguayan securities. Currently, CBU already provides safekeeping and settlement services for government bonds and it is planning to extend these services to other private and public listed securities. Risk Summary Overall Risk Asset Commitment Risk Generally, asset commitment periods for both purchases and sales are less than a full business day. For the small volume of settlements using cheques, the asset commitment period for sales is one day. Liquidity Risk The system supports credit facilities through repo transactions, although securities and cash settle on a gross basis and there are no stock lending facilities or other fails management procedures in place. Risk BBB A A Counterparty Risk At present, there are no specific measures in place to protect against counterparty risk. The system neither
Page 2 of 20 operates a linked settlement DVP mechanism, nor has a guarantee fund to cover counterparty risk exposure. In the Bolsa Electrónica de Valores del Uruguay SA there is a credit lines system through which each user determines the level of risk that it is willing to assume with each counterparty. Asset Servicing Risk CBU acts as the financial agent to the securities issued by the State of Uruguay (Bonos de Tesoro and Letras de Tesoreria). It acts as bookentry registrar for these securities and as a global custodian for Pension Fund investments. B A Therefore, events handled by the depository are likely to be mandatory interest and redemption payments and there would be no participant instructions to process. Financial Risk Financial risk appears to be medium to high since as a central bank, the financial risk exposure is tied to that of the sovereign risk of the country which stands at BB by Standard & Poor s and Ba1 by Moody s. However, the central bank has insurance coverage against claims made against it by participants for losses due to breakdowns in its control procedures to mitigate this risk. Operational Risk The depository indicates that there has been no disputes or problems in the history of the system. External and internal audits are performed on a regular basis. CSD on CSD Credit Risk CBU has a link with Clearstream Banking SA. Settlement is carried out with respect to the same international carried out through Clearstream Banking SA. BBB BBB Links Exist
Page 3 of 20 Asset Commitment Risk Summary Settlement of securities and funds is on a gross basis, tradebytrade, following the matching of corresponding orders. The bulk of settlements are on T+0 / T+1. However there are no standard timeframes instituted in the market. The asset commitment period is less than a full business day and so is considered moderate. Processing Cycles Settlement of securities and funds is on a gross basis, tradebytrade, following the matching of corresponding orders. The bulk of settlements takes place on trade day. CBU is developing a new CSD for all Uruguayan securities. Currently, CBU already provides safekeeping and settlement services for government bonds and it is planning to extend these services to other private and public listed securities. CBU will use Realtime Gross Settlement (RTGS) systems to settle both securities and cash which will be linked through an electronic system to settle on a DVP basis. Cash Over 90% of financial settlements occur on trade day, through an electronic payment system of the CBU. This operates from 10.00am until 5.30pm on all business days. In the case of payment by cheques, the settlement and receipt of funds takes 24 hours. Asset Commitment Periods Over 90% of financial settlements occur on trade day, through an electronic payment system of the CBU. This operates from 10.00am until 5.30pm on all business days. In the case of payment by cheques, the settlement and receipt of funds takes 24 hours. Irrevocability Payment is irrevocable. Finality Securities and cash transfers cannot be unwound once they have been settled. Asset Commitment Risk Key Indicators Irrevocable commitment to the processing cycle Transaction Type Start Finish Securities Securities 10.00am 5.30pm Cash Cash 10.00am 5.30pm (i.e., on prefunding and irrevocability) Securities processing cycle outlined Securities settlement is gross, through a bookentry system. Cash processing cycle outlined Financial settlements are processed through the central bank s electronic payments systems AGATA. AGATA is the system link with the Central Bank for movements of cash and securities. AGATA will be replaced in 2011 by a standard system as part of a Payment System Reform. The software selection is a result of Public Bidding # 02/2008 for the procurement of "the desing, provision, installation and initial configuration, implementation, training, guarantee, support and maintenance of versions of RTGS a CDS, and other related applications. All these systems must be fully integrated, supporting settlements for all kinds af payments and transactions involving public and private securities". The new system offers the full functionality of RTGS and Depository, in segregated mode,with advanced risk management, monitoring and control possibilities. It also follows BIS and World Bank Principles to avoid risks and implement worldbest practices. The telecomunication environment allows secured message sending and receiving. All messages exchanged in RTS/X correspond to SWIFT format, regardless of implemented network.
Page 4 of 20 BCU will have the ability to adapt the system to market`s needs. This requires technical training and license, already considered in the contract with the system supplier.
Page 5 of 20 Liquidity Risk Summary The system supports credit facilities trough Repo transactions, although securities and cash settle on a gross basis and there is no stock lending and borrowing in place. However, risk exposure is mitigated somewhat since securities settled in the CBU are fully dematerialised and become final on transfer within the bookentry system. Processing Model Settlement of both securities and funds are executed on a gross basis in systems operated by the central bank. Fails Management Formal buyin procedures are set to ensure settlement on due date, but there is an internal process to deal with fails. If an Institution does not have enought funds, it can obtain them via an overnight repo (at penalty rate) equal to 30% of the average minimum reserve required. If this is not enought to cover the debt, CBU can purchasethe institution's goverment securities at penalty rate (Cir.2037 22/10/2009). Credit Facilities credit facilities are provided by the depository. Instead, tripartite Repo is used. Securities Lending There are no securities lending arrangements in the market. Registration Model Ownership of securities is recorded by bookentry at the CBU. There is no securities registration. The account holders at the central bank are considered the beneficial owners. When money or other considerations are transferred, the title or entitlement to securities held in the central bank passes between participants. Deposited securities Almost all securities are held in dematerialised form. As at 31 July 2010, 92% of the issued government securities were held at CBU, of which 90% are in dematerialised form and the remainder in immobilised form. Deposit and Withdrawal of securities Securities are dematerialised and can be held outside of CBU using legitimation certificates issued by CBU. Liquidity Risk Key Indicators Settlement Models The model for settlement is similar to BIS model 1, with gross settlement of funds and gross settlement of securities Processing Periods Overnight (by batch) End of day Batch daylight processing Realtime and online Other Generally settlement is on the same day as the trade, on a gross settlement basis.
Page 6 of 20 Credit Facilities Central bank money used to settle cash elements of trades Credit facilities provided by the CSD Planned Credit facilities provided by commercial banks Stock Lending Is stock lending permitted in the market Are stock lending facilities provided by the CSD? Are stock lending facilities provided by commercial banks/brokers? Transfer of Securities Are securities deliveries achieved by bookentry? Generally in bookentry form, but there may be transactions with physical securities. Registration of Securities Period of time required to register a holding? Same Day
Page 7 of 20 Counterparty Risk Summary Counterparty risk is high. At present, there are no specific measures in place to protect against counterparty risk exposure. The system does not have a guarantee fund to cover defaulting participants. The system has the capacity to block securities movement from the seller's account prior to receipt of the buyer's payment and it has the capacity to block payment until securities are moved. In regards to transactions undertaken by the AFAP (Welfare Savings Funds), the central bank waits until the counterparties fulfill their obligations before transfering securities or funds, thereby effecting DVP. Participant Counterparty Risk Risk Containment Model The Bolsa de Valores de Montevideo (BVM) has a custody agreement with the Nuevo Banco Commercial to support custody and broker to broker settlement. Delivery Versus Payment All securities settle on a DVP basis as the central bank waits for the counterparty to perform before paying or transferring securities. Role of Central Counterparty (CCP) The CBU does not act as central counterparty. Participant Criteria Prospective participants must meet financial threshold, regulatory oversight and market experience requirements. Prospective participants do not undergo a formal review and approval process regarding compliance with eligibility requirements. Participants are not required to contribute to the central bank s capital. However, CBU is planning to amend the membership requirements. Participant Concentration Insufficient information available to assess. Financial Compliance/Surveillance The CBU system monitors participant volumes, and has the capacity to block securities movement from the seller s account prior to receipt of the buyer s payment and block payment until securities are moved. Guarantee Funds The Central Bank of Uruguay, as a depository institution, does not have a pooled separate guarantee fund for settlement. Counterparty Risk Key indicators Capacity of CSD Agent Surveillance of participants by CSD Settlement assurance guarantee fund Participation criteria Prospective participants must meet financial threshold, regulatory oversight and market experience requirements. Prospective participants do not undergo a formal review and approval process regarding compliance with eligibility requirements. Participants are not required to contribute to the central bank s capital. Minimum Capital (local currency) Size of Guarantee Fund (Name, local currency, Euro and USD (millions))
Page 8 of 20 ne Does the CSD act as a central counterparty Participant Concentration (Local Currency Millions) Value of transactions in the market by top 10% of participants USD 455,796,856,674 (2010) Volume of transactions by top 10% of participants 90% Volume of largest individual participant 38%
Page 9 of 20 Asset Servicing Risk Summary The asset servicing risk assessment relies on the disclosure by the depository of their corporate action, income payment and proxy voting procedures. CBU financial agent rol is focused in securities issued by the State of Uruguay (Bonos de Tesoro and Letras de Tesoreria) and CBU. It acts as bookentry registrar for these securities and as a global custodian for investments of the Welfare Savings Funds (Fondos de Ahorro PrevisionalAFAPS). Therefore a vast majority of events are likely to be mandatory interest and redemption payments. Participant instructions are required in very few cases, only for stocks maintained in Global Depositories (Clearstream). Information processing As a supervisor of the capital market, CBU actively collects information from issuers and the two stock exchanges and elaborates Official Reports of stock market transactions. Instruction processing Virtually all events are likely to be mandatory interest and redemption payments which do not require instructions from participants. Proxy Voting CBU provides information on general meetings via email although it does not vote on behalf of investors. Other services Due to the nature of the securities covered by CBU the scope for providing additional asset servicing facilities is going to be limited until a significant development of stock market. Asset Servicing Risk Key indicators Information processing Securities covered Government debt, equities and corporate debt. Information sources used Issuers, stock exchanges Information provided in English Number of Events during last full year Dividends 5 Interest & Redemptions 50 Corporate actions 15 tification via SWIFT message types tification within Information processing comments
Page 10 of 20 Instruction processing Use of depository Settlement on due date Optional corporate actions supported Cash account credited Central paying agent Entitlements based on Instruction processing comments Most corporate actions are restricted to mandatory events such as dividend payments and redemptions. Proxy voting services Online Outsourced Announcement of meetings Elections (Voting) Results reporting Proxy voting services comments This service is provided, although few assets require it.
Page 11 of 20 Financial Risk Summary Financial risk appears to be significant since as a central bank, the financial risk exposure is tied to that of the sovereign risk of the country which stands at BB by Standard & Poor s and Ba1 by Moody s. Financial and other Resources Capital Structure The CBU is owned by the State of Uruguay. The central bank is a nonprofit institution. The total capital has considerably decreased during the last years, mainly as a result of the net losses reported in some years, which have had a negative impact on the accumulated earnings and reserves. Net capital as at 31 December 2009 stood at a negative UYU 7,750 million (USD 389 million). However, Article 1 of Law 18,401 sets the capital of the Central bank at UYU 10,027 for 2009 as well as the level of reserves required. Reserves are constituted by means of profits made as a result of positive movements in assets held in foreign currency. A second reserve would be constituted by retaining 25% of net profits. Reserves at 31 December 2009 stood at UYU 4,529 million (USD 227 million) while net profits for year 2009 were UYU 22,306 million (USD 1,119 million). In mid 2010, the CBU was capitalised by UYU 45,700 million (USD 2,474 million). Sovereign Ratings The credit rating of sovereign entities may be considered relevant in the event of a major disruption in infrastructure: Standard and Poor's: BB Fitch: BB Moody's: Ba1 Earnings Performance The Central Bank of Uruguay reported losses in 2009 of UYU 22,306 million (USD 1,119 million) after reporting a net profit of UYU 11,871 million (USD 477 million). The total operational income amounted to UYU 4,684 million (USD 235 million) during 2009. Guarantee Funds (Central Counterparty Funds Only) As a depository institution, the central bank does not act as central counterparty and does not operate a guarantee fund. Access to Credit There is no access to credit. The central bank does not borrow funds. Insurance The central bank has security insurance to cover the deposit of securities, theft, robbery of the vault and vandalism or similar destruction and other insurance, including fire insurance covering the main building. Potential Claims on Financial Resources Credit Loss Central Counterparty Exposure Liability for Operational Losses Investment in Infrastructure Insufficient information to assess. Financial Risk Key indicators Ownership of the CSD Number Domestic Number Foreign Total Percentage
Page 12 of 20 Central Bank 1 100% Stock Exchange Participant banks Broker/dealers Mutual funds Private clients Others Statistics Capital structure Local Currency Issued capital 10,027 Surplus 0 Reserves 4,529 Retained earnings (22,306) Total (7,750) Statistics in UYU millions as of 31 December 2009 Lines of stock 2007 2008 2009 2010 2011 Lines of stock % Stock Exchange transactions cleared & settled through CSD Total value of securities under custody 2,947 Figures in USD million Equities 2007 2008 2009 2010 2011 Market Value % of issued securities in the CSD % of market capitalisation in the CSD
Page 13 of 20 Fixed Income 2007 2008 2009 2010 2011 Market Value 2,947 % of issued securities in the CSD % of market capitalisation in the CSD 92% Figures in USD million Money Markets 2007 2008 2009 2010 2011 Market Value % of issued securities in the CSD % of market capitalisation in the CSD Expenses 2007 2008 2009 2010 2011 Expenses as % total operating revenue 78.17% 644%
Page 14 of 20 Operational Risk Summary The depository indicates that there have been no disputes or problems in the history of the system. Internal audits, conducted by the General Inspection Department, are performed two or more times a year. The information about operational risk assessment has not been forthcoming either by the depository completing the apporpiate parts of the Depository Service questionnaire or by the provision of a thirdparty independent revie of the internal controls and procedures of the depository. As a result, the operational risk assessment is incomplete and cannot be fully relied upon. The new system will include disaster recovery/ business continuity procedures. Depository controls Assets of foreign investors held by participants are maintained under safekeeping conditions that are no less favourable than those that apply to other participants. Clearing controls In the case of securities of international title, the settlement is carried out with respect to the international standards carried out through Clearstream Banking SA. Data processing controls Operations are carried out through the AGATA system. Each participant is responsible for carrying out their own settlement. In the case of operations with international securities, the settlement takes place through Clearstream Banking SA, governed by its internal controls. Disaster Recovery/Business Continuity Procedures The Business Recovery Plan includes a back up data storage and a backup file of all computer files. A back up off site location it's planned to be implemented in 2011. Depository Liability Systems Performance Systems performance within CBU is monitored on a regular basis. Operational Risk Key indicators Control objectives identified by the CSD match standard objectives Key controls and procedures are identified by the CSD Independent evidence exists that key controls and procedures have operated effectively through the last year Material errors have been identified
Page 15 of 20 CSD on CSD (Credit) Risk Summary CBU has a link with Clearstream Banking SA. Settlement is carried out with respect to the same international standards carried out through Clearstream Banking SA. CSD CSD Links Processing Cycles CSD on CSD (Credit Risk) Key indicators International Links: List of international links established and/or planned by the CSD Clearstream Banking SA European Central Bank logo ECB Monetary Operations
Page 16 of 20 Governance and Regulation Management and governance of the depository The Central Bank of Uruguay was established in 1967 under Article 196 of the Constitution of the Republic of Uruguay. It is an autonomous state entity governed by constitutional standards, laws and regulations that are applicable. It is linked to the Executive through the Minister of Economics and Finance, although it is not subject to the Ministry in a hierarchical sense. The Charter for the Central Bank was approved by Law 16,696 of 30 March 1995, and was updated by Law 18.401 of 24 October 2008. The central bank fulfils, in accord with stipulations in Law 18.627 of December 2009 (Law of the Securities Market), the function of regulator and supervisor for securities markets and for physical persons and legal entities that intervene in the public offering of securities in Uruguay. In this sense, it has, for example, prepared the collection of standards of regulation and control of the financial system, the collection of standards for insurance and reinsurance, the collection of standards for administrators of welfare funds, collection of standards for the securities markets and the collection of standards for operations. Its governement and management are in charge of a three members' Board of Directors, wich is responsible for the policy and general administration of the Bank. The Superintendency of Financial Institutions and the Superintendency of Financial Services, within other areas depend from the Board of Directors. Regulatory and independent examination of the depository CBU is subject to review by the Tribunal de Cuentas, an independent body of state control, in accord with Article 211 of the Constitution. In other matters, the central bank is subject to constitutional, legal and external audit controls that correspond to its quality of autonomous state entity (disciplinary responsibilities, civil, etc.). In its position as depository for securities, the Central Bank of Uruguay has not had any disputes or complaints over the last three years. Internal controls and procedures for safeguarding investments If the availability of an account or security is legally blocked (embargo, ban, etc) the security is not accessible to the central bank or the owner until they have received a court order freeing the account or security. In addition, there is an internal auditor, Inspector General with maximum authority and whose functions are defined in article 22 of the Charter of the Central Bank Other legal protection mechanisms About the Depository Name and Address Central Bank of Uruguay Diagonal Fabini 777 Montevideo Uruguay Website www.bcu.gub.uy Date of establishment 1967 Date commenced operations 1967 Legal status t for profit Type of legal entity Central Bank Regulated by Constitution, laws, decrees of the Executive in some areas, Segregation of Assets at the Depository Depository assets from participants Participant assets from clients Eligible Securities Depository under SEC Rule 17f7 System of central handling of securities Regulated by a financial regulatory authority Holds assets of all participants on equivalent terms Identifies and segregates participant assets Periodic reports to participants Periodic examination by a regulator or independent
Page 17 of 20 and selfregulation in the areas overseen and governed by the central bank itself. accountant Is use of the CSD required? Settlement Safekeeping By Law By Market Practice How securities are held A Registry of bookentry securities is held for securities issued by the government and CBU. Domestic eligible participants Institutions of financial intermediation, AFAPS, insurance companies and other institutional investors. Foreign eligible participants There are no participants from outside the country at the level of local issuers. Ownership The Central Bank is 100% owned by the state. Internal Safety Measures Services Provided Participant Eligibility Criteria Minimum Capital Standards Financial Aspects Ability to raise capital/borrow Committed lines of credit in place Publish audit financials Take lien on stock held Central Bank Guarantee Other third party guarantee Third party insurance Matching Prematching services Matching services Clearing Clearing services Securities Settlement Bookentry settlement Fails management Cash Settlement Internal cash settlement
Page 18 of 20 Safeguard Facilities Offsite Backup Disaster Recovery Disaster Recovery Plan Planned Backup power generator UPS (Uninterruptible power supply) Stock Lending Securities lending for fails coverage Asset Servicing tifications Securities processing Paying agent Central registrar Proxy voting services Communications Electronic communications Reporting Services Electronic reporting Reporting of every movement Regular statement of securities deposited Definitions Qualified Assessment. This assessment has been compiled from information provided by third parties believed to be accurate and reliable at the time of publication. Despite having the opportunity, the CSD has declined to: (1) provide information requested to complete a full risk assessment; (2) verify the information provided by the thirdparty support bank(s); or (3) review and comment on this assessment. These are integral aspects to the checks and balances designed into the Depository Service. Consequently, this assessment must be regarded as being less reliable than those without this qualification.
Page 19 of 20 Publication Date The publication date represented here is March 2011. This is the date that the assessment report has been reviewed by third parties that may include the CSD (for proprietary assessments). The report is updated on an ongoing basis throughout the year as new information is received and should be read in conjunction with the relevant newsflashes issued since the publication date. RISK EXPOSURE DEFINITIONS Asset Commitment Risk The period of time from when control of securities or cash is given up until receipt of countervalue. This risk concerns the time period during which a participant s assets, either cash or stock, are frozen within the CSD and payment system pending final settlement of the underlying transaction(s). Following settlement, the risk period is extended until the transfer of funds and stock becomes irrevocable. It excludes any periods when assets, cash or stock, are committed to a market participant including brokers, banks and custodians, not caused by CSD processing. Liquidity Risk The risk that insufficient securities and or funds are available to meet commitments; the obligation will be covered some time later. This is where for certain technical reasons (e.g., stock out on loan, stock in course of registration, turn round of recently deposited stock is not possible) one or both parties to the trade has a shortfall in the amount of funds (credit line) or unencumbered stock available to meet settlement obligations when due. These shortfalls may lead to settlement fails but do not normally lead to a default. Counterparty Risk The risk that a counterparty (i.e., a participant) will not settle its obligations for full value at any time. This is simply the total default of a direct participant of the CSD. This is the event when a participant is unable to meet its financial liability to other participants. This risk only goes as far as direct participants of the CSD and excludes clients of direct participants that default on liabilities to such participants, even if such a default should systemically cause the direct participant to subsequently default. Asset Servicing Risk The risk that a participant may incur a loss arising from missed or inaccurate information provided by the depository, or from incorrectly executed instructions, in respect of corporate actions and proxy voting. This risk arises when a participant places reliance on the information a depository provides or when the participant instructs the depository to carry out an economic transaction on its behalf. If the depository fails either to provide the information or to carry out the instruction correctly then the participant may suffer a loss for which the depository may not accept liability. The depository may provide these services on a commercial basis, without statutory immunity, or it may provide the service as part of its statutory role, possibly with some level of protection from liability. This risk is likely to become much higher when international securities are included in the service. RATING SCALE AAA AA+ AA AA Contact: Extremely low risk Very low risk A+ Low risk A A BBB BB B CCC N/R Acceptable risk Less than acceptable risk Quite high risk High risk rating has been given due to insufficient information Thomas Murray Depository Service Horatio House, 77 85 Fulham Palace Road LONDON, W6 8JA Tel: +44 (0) 20 8600 2300 Fax: +44 (0) 20 8741 7468 Email: depositoryservice@thomasmurray.com Website: www.thomasmurray.com Names of analysts available on request. Financial Risk The ability of the CSD to operate as a financially viable company. This risk concerns the financial strength of the depository and if its financial resources are sufficient to meet the ongoing operation of the organisation. This risk also includes where the CSD may act as central counterparty, or otherwise acts in a Principal capacity. Operational Risk The risk that deficiencies in information systems or internal controls, human errors or management failures will result in losses. The risk of loss due to breakdowns or weaknesses in internal controls and procedures. Internal factors to be considered in the assessment include ensuring the CSD has formalised procedures established for its main services. The CSD should have identified control objectives and related key controls to ensure operation and proper control of established procedures. Systems and procedures should be tested periodically. There should be external audit processes in place to provide thirdparty audit evidence of the adequacy of the controls.
Page 20 of 20 CSD on CSD Credit Risk the risk that a CSD is taking when linking to another CSD. The credit risk that a CSD is taking when linking to a peer group CSD, i.e. the risks a domestic CSD is taking in either providing a service for a foreign CSD or using a foreign CSD as a local service provider (host CSD). The risks arising from using these links to make crossborder settlements or to hold securities in a nondomestic CSD have not been assessed as part of this risk. Copyright 2011 Thomas Murray Ltd. Reproduction in whole or in part prohibited except by permission. All rights reserved. The services and analysis provided by Thomas Murray are provided on an "as is" basis and Thomas Murray make no representations or warranties, express or implied, as to the accuracy, adequacy or completeness of its analysis or results to be obtained from accessing and using this report (or any information included therein), including without limitation, any warranties of merchantability or fitness for any particular purpose or use. Neither Thomas Murray nor their affiliates shall be liable to any user or anyone else for any inaccuracy, error or omission, regardless of cause, in this report or for any damages resulting therefrom. In no event shall Thomas Murray have any liability for lost profits or for indirect, special, punitive or consequential damages, even if advised of the possibility of such damages. Thomas Murray shall have no liability to any third party arising from or related to this report. Neither this report nor any component of the service provided by Thomas Murray is a rating, endorsement or guarantee of any Depository or its financial strength or a recommendation to enter into any agreement with any Depository. Thomas Murray relied on information provided by third parties believed to be accurate and reliable but due to the possibility of human or mechanical error, Thomas Murray can not guarantee the accuracy of any such information. Report Date Uruguay 17 August 2011