National Bank of Greece 2014 Comprehensive Assessment Results NBG achieves a €2bn capital surplus Athens Sunday, October 26 2014 00 IMPORTANT DISCLAIMER : This presentation and all information contained hereto (the “Presentation”) has been prepared by National Bank of Greece SA (hereafter “NBG”) and/or its subsidiaries (together with NBG, the “NBG Group”) in order to explain in more detail the outcome of the Comprehensive Assessment (“CA”) pursuant to Article 33(4) of Council Regulation (EU) No 1024/2013 and should not be used for any other purpose. This Presentation should be viewed solely in conjunction with, the official announcement and template for the CA outcome for NBG as it will be published by the European Central Bank (ECB). No representation or warranty, express or implied, is made as to the fairness, accuracy or completeness of the information contained herein and no reliance should be placed on it. 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This Presentation is governed by Greek law and by accepting this material the recipient agrees that the Greek Courts shall have exclusive jurisdiction to settle any disputes arising or connected with this Presentation.. 1 Table of Contents EXECUTIVE SUMMARY 3-5 STRESS TEST ASSUMPTIONS AND METHODOLOGY 6-8 ASSET QUALITY REVIEW 9 - 14 STATIC STRESS TEST 15 - 18 DYNAMIC STRESS TEST 19 - 21 DEFERRED TAX CREDITS 22 - 23 2 EXECUTIVE SUMMARY 2014 EU-wide stress test – no further capital action required of NBG • EU-wide stress test of 130 banks under very severe, uniform rules • The Adverse Dynamic Balance Sheet (DBS) Stress Test results in a 8.9% CET I ratio at end 2016, and a capital surplus of €2.0bn and − 340 basis points above the 5.5% minimum − The DBS takes into account NBG’s 2014-18 Restructuring Plan agreed on 23.7.14 with the European Commission. • The Adverse Static Balance Sheet (SBS) stress test results in a capital shortfall of €0.9bn1 − SBS stresses 2013 – a particularly challenging year for NBG − Already NBG’s 2014 profitability and actions to Sept. 14 fully mitigate this • Asset quality review resulted in a €1.7bn impact, originating mainly from the Greek retail loan portfolio, and the severe assumptions regarding the valuation of real estate collateral • All above results do not include the impact of the new Deferred Tax Credit law voted on 16.10.2014, of approx. €0.7 – 1.2bn (110 – 220 bps). • No further capital action required of NBG. 1 including the Share Capital Increase (SCI) completed in May 2014 4 Adverse Dynamic Balance Sheet stress results in a capital surplus of € 2.0 bn at end 2016 Adverse scenario CET 1, € bn CET 1 ratio, % €2.5bn €6.3bn 4.2% -10.9% €6.0bn €2.0bn capital surplus €3.1bn 10.7% €5.3bn €2.0bn 8.9% 3.4% Does not include DTC 2.0 3.2% €3.3bn, 5.5% 1.1 minimum threshold Dynamic BS RWA’s in €bn 1 2 1.8% Completed RP actions2 2013 CET I May 14 SCI Static BS CA1 Dynamic BS CA 56.7 57.9 57.9 60.0 CA = Comprehensive Assessment, incorporates Asset Quality Review, Stress Test and AQR join-up Already completed Restructuring Plan actions, see also page 18 CA result 60.0 Surplus end 2016 60.0 5 STRESS TEST ASSUMPTIONS AND METHODOLOGY Overview of major assumptions /methodology for the adverse scenarios Line item Static Balance Sheet (SBS) Volumes • Net Interest Income • • • • Dynamic Balance Sheet (DBS) • Loan and deposit total volumes as per Restructuring Plan (RP) Loan mix as at 31.12.13 NII not higher than 2013 Pass through of sovereign spread shock to funding costs 50% of increase of funding costs applied to mortgage lending rates (75% for other loans) NII not higher than that derived from top-down ECB model • same as SBS except NII ceiling as per RP As at 31.12.13 • Trading • 1x standard deviation of last 3 historical values plus 2x standard deviation of last 5 historical values (thus including Greek PSI and Grexit fears impact on trading losses) • RP figure for baseline plus 2x standard deviation of last 5 historical values (includes Greek PSI and Grexit fears impact on trading losses) Fees & Commissions • Cap on ratio of F&C /Total Assets at level of 2013, the 6th year of recession • same as SBS Opex • Not lower than 2013 level, which includes staff cost of 2,490 staff that departed in Dec-13 • Not lower than 2013 ratio to Total Assets, after excluding the 2,490 staff Credit Risk • • • Loss rate not lower than top-down ECB model Loss rate adjusted for AQR results Apply similar LGD shock for defaulted and non-defaulted assets • same as SBS DTA • • • Phase out as per CRR IV DTC law not yet enacted Excludes DTA recognised in H1.2014 • same as SBS 7 Macro assumptions for Greece double up on steep recession of 2009-13 on bonds and house prices vs the periphery Gov’t bond adverse valuation haircut 3Y, loss rate,% GDP adverse deviation 2009 – 2016, Base = 2009 (100) 16.5 10.2 8.1 Ø8 2.2 Greece Spain 2.1 Ireland Residential House Price inflation 2009 – 2016, Base = 2009 (100) H: Historical , F: Forecasts (EBA adverse scenario) Portugal Italy Unemployment Rate 2009 – 2016, % 8 ASSET QUALITY REVIEW AQR impact resulting mainly from Greek Mortgage and SME loan portfolios • AQR workblock has reviewed 11 Greek and Turkish loan portfolios, with gross balances in excess of €60 bn − 79% of total loans • Challenger model resulted in € 2.2 bn additional regulatory provisions, of which €2.0bn in Greek mortgage and SME portfolios • Greek Mortgage loans − No impact from credit file review − Provision gap resulting from severe collateral valuation assumptions • Greek SME loans − € 0.6 bn in a € 12.0 bn portfolio re-classification to NPE − Majority of NPE’s classified as “gone concern” − Provision gap resulting from severe collateral valuation assumptions • Insignificant provision gap in all Turkish portfolios • NBG transparency on troubled assets validated 10 Increase of mortgage provisions following severe collateral mark downs and rigid treatment of rescheduled loans NBG estimates* Defaulted loans Re-scheduled loans • AQR Challenger model used severe liquidation • • assumptions Discount vs. 2013 PropIndex valuation of 8% Forward HPI -4% per annum vs. NBG -2% per annum Time to liquidation 3 years vs. NBG 5 years Forced sale haircut ~20% vs. NBG 10% No re-classification from extensive credit file review Corresponds to an increase of ~€ 650 m in provisions, of which ~€ 330 m are already provided for by IRB regulatory provisions • • • • IFRS LLA’s * Performing Rescheduled NBG loans as NPE, resulting in an increase of ~€ 400m in provisions • EBA definition of NPE includes all rescheduled loans, but AQR applies very high PI’s to NPE’s irrespective of actual performance • An alternative classification to High Risk and High Risk Cure segments would result in ~€ 400m less provisions Stratification of NPE EBA by delinquency 90+ LLA’s* €m, Dec-13 balance 820 • AQR Challenger model classified ~€ 2.9 bn 1,150 Regulatory LLA’s 1,475 Challenger* model Risk bucket Balance € bn Nil 1.9 1-29 dpd 30-59 dpd 0.4 60-89 dpd 0.4 <90 dpd 2.9 0.2 Probability of impairment ΝPG = 9 - 43% AQR* = 70 - 100% NBG estimates, back-solving Comprehensive Assessment AQR Challenger model with limited high level input from ECB. Actual parameter values may vary 11 Retail SME: Severe collateral haircut led to higher provision charges NBG estimates* Provision calculation for NPE loans – Retail SME €m, Dec-13 • Greek Retail SME loans − No NPE re-classification /impact 2,994 c.40% from credit file review − Provision gap resulting from severe collateral valuation assumptions for secured NPE’s c.55-60% 1,647 1,269 • Valuation haircuts: − NBG 40% on average − AQR* Challenger model implicit valuation haircuts of ~55-60% Nominal value of tangible collateral * NBG Collateral haircut AQR* Challenger Model Collateral haircut Provision gap • NPE coverage post AQR @55% NBG estimates, back-solving Comprehensive assessment Challenger model with limited high level input from ECB. Actual parameter values may vary 12 SME increase of provisions is due to reclassified NPE’s and severe collateral haircuts NBG estimates* Performing loans re-classification Collateral under gone concern • Net additional NPE exposure of ~€ 620m was identified (7% of total book) • For the majority of the cases the driver for reclassification was a debt service coverage ratio <1.1 in 2013 in the 6th year of Greece’s severe recession (-25% of GDP during 2008-13) • Majority of NPE’s were assessed under “gone concern” rather than “going concern”, leading to provisions based on liquidation value Coverage ratio 43% 37% 4,707 4,085 NPE Pre-AQR * 54% 47% vs. NBG’s c.30% • Collateral treatment prior to haircuts led to a 6% reduction in NBG reported collateral value • Sales haircuts and discounting averaged 29% for gone concern debtors NPE Provisions in €m; Dec. 13 NPE balances in €m, Dec. 13 NPE ratio • AQR Challenger model reduced collateral values by 35% 622 AQR impact 2,023 1,526 NPE Post-AQR NPE Pre-AQR 497 AQR impact NBG estimates, back-solving Comprehensive assessment Challenger model with limited high level input from ECB. Actual parameter values may vary NPE Post-AQR 13 Post AQR NPEs in line with IFRS reported impaired loans NBG transparency on troubled assets validated NBG estimates* Post-AQR NPEs in line with IFRS reported impaired loans1, 2 % of total GroupBalances Balancesas asat at31.12.2013 31.12.2013 33 % of total Group NPE NPE % % 22.5% 22.5% 1.5% 1.5% 8.2% 8.2% 32.2% 32.2% 2.3% 34.4% 34.4% Restructured loans clearly marked as such (even while below 90+ days past due) and receive proper impairment treatment. 1.071 NPLs Other impaired Performing Restructured NPE PreAQR AQR NPE NPE Post-AQR Reclassification As included in NBG’s 2013 Annual Report, Note 4.2.7 “Loans and Advances to Customers”. “Titlos” excluded from loan balances. 3 ECB disclosure templates refer to EAD on exposures reviewed. * NBG estimates, back-solving Comprehensive Assessment challenger model with limited high level input from ECB. Actual parameter values may vary. 1 2 14 STATIC STRESS TEST Adverse Static Balance Sheet Stress results in a capital shortfall of €0.9bn end 2016, covered by actions already implemented in 2014 Adverse scenario € million 2,500 6,305 6,058 Do not include DTC 5.5% €3,186m 933 * See page 18 3,367 3Q.14 PPI 2,253 minimum threshold Static BS RWA’s in €bn 1,114 DTC 2013 CET I capital SCI CA impact Stress Test result Shortfall 56.7 57.9 57.9 57.9 57.9 CA result Actions completed* adjusted for completed actions 57.9 57.9 16 The Static Balance Sheet Stress test is especially severe both on credit losses and PPI, despite EBA’s expectations for improved GDP and unemployment by 2016 € million 40% less than 1H14* every year 2014-17 16.9% on Greek sov. risk -1,710 32% more than 1H14* every year 2014-16 +2,970 -5,600 +1,890 -1,400 -200 -6,300 Other Capital CA impact 30% except AQR at 26% AQR * 1H14 annualised Credit losses Sovereign risk PPI Tax DTA derecognised 17 The Adverse Static Balance Sheet stress test shortfall is covered by measures already implemented in the first 9 months of 2014 2014 Realization and capital actions € million • Actual H1’14 Pre Provision Income almost double the 1H14 Stress Test result – the difference is considered a capital action DTC • NBG Pillar 1 Bonds of €1,485m repaid in 2014, which had been subject to 16.9% haircut – Repayment included in the Restructuring Plan 3Q.14 PPI 933 • Voluntary Exit Scheme (VES) was taken up by 2,490 employees and completed in Dec-13; ST methodology requires continuation of salary expense for above mentioned staff in 2014-16 • SPA for Astir Palace disposal was signed on September 17, 2014 PPI (1H.14) Sovereign Bonds VES Astir Disposal Total Stress Test shortfall (static) • Conversion of DTAs to DTCs as per current Law (passed through Greek Parliament on 16.10.14) results in an incremental positive impact 18 DYNAMIC STRESS TEST The Adverse Dynamic Balance Sheet stress test (DBS) results in a capital surplus in excess of € 2.0 bn. The DBS stresses the 2014-17 Restructuring Plan agreed with the European Commission on 23 July 2014 Adverse scenario € million 2,500 -3,236 4.2% -5.9% €2.0bn capital surplus 6,058 5,322 10.7% 2,022 8.9% 3.4% €3,300m minimum threshold Dynamic BS RWA’s in €bn Does not include DTC 2013 CET I SCI May 14 CA impact Stress Test result Surplus 56.7 57.9 60.0 60.0 60.0 20 The Dynamic Balance Sheet (DBS) reverses the majority of the Static Balance Sheet (SBS) result with improved profitability and capital actions Adverse scenario CET 1, € million CET 1 ratio, % -6,300 -10.9% 1,560 5,320 8.9% 1,500 €3.3bn, 5.5% minimum threshold Dynamic BS 3.4% 170 940 Static BS CA1 1 2,020 Improved DBS profitability CA = Comprehensive Assessment, incorporates Asset Quality Review, Stress Test and AQR join-up DBS Capital Actions CA result Surplus end 2016 21 DEFERRED TAX CREDIT The new Deferred Tax Law would improve the stress test results by €0.7- 1.2bn Legal Framework • • • Effective from 1st January 2015 Income Tax attributable to: — Unutilized amount of the PSI loss; and — Accumulated provisions for credit losses on loans granted as at 31.12.2014 for which DTA has been recognised can be converted to a receivable (Tax Credit) from the Greek State, upon Accounting (IFRS) losses after tax1, Unused Tax Credit2 is replaced with a claim on the Greek State. In exchange, the Bank issues ordinary shares3 with value equal to 110% of the unused amount NBG actions • An Extraordinary General Assembly has been convened for 7.11.14 to enable NBG to convert DTA amounts into DTCs, i.e. Deferred Tax not dependent on future profitability and not subject to CRD IV caps. Impact on capital adequacy Capital Adequacy • Impact on CET 1 under 2024 CRD IV rules on the 30.6.14 position : The new law prevents the eventual derecognition of approximately €2.6bn. Stress Test • Impact on Adverse Static BS results (period to end 2016) : The new law enables the recognition of approximately €1.2bn of capital or 220 bps • Impact on Adverse Dynamic BS results (period to end 2016) : The new law enables the recognition of approximately €0.7bn of capital or 110 bps 1 or resolution of the entity if not settled against Corporate Tax due for the year 3 at the VWAP of the last 30 days Conversion of DTAs to DTCs as per current Law (passed through Greek Parliament on 25.09.14) results into an 2 incremental positive impact of €810m against Stress Test Static (adverse) scenario. 23 National Bank of Greece Contact details Paul Mylonas Paula Hadjisotiriou Deputy CEO Deputy CEO +30210 334 1521 [email protected] +30210 334 3051 [email protected] Apostolos Kazakos Greg Papagrigoris Assistant General Manager Group Strategy +30210 334 3071 [email protected] Head of IR +30210 334 2310 [email protected] [email protected]
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