Report of the Board EBA CLEARING Shareholders Meeting 14 th May 2012 Contents

1. The Company’s activities in 2011 3

1.1 Introduction 3 1.2 EURO1/STEP1 Services 3 1.3 STEP2 Services 8 1.4 Operations of the clearing systems 15 1.5 Resilience, Business Continuity and Incident Management 17 1.6 MyBank initiative 19 1.7 Activities of Board Committees 21 1.8 Corporate matters 25 1.9 Financial situation: P&L statement as of 31 st December 2011 27

2. The Company’s activities in 2012 31

2.1 EURO1/STEP1 Services 31 2.2 STEP2 Services 33 2.3 Operations of the clearing systems 35 2.4 Resilience, Business Continuity and Incident Management 36 2.5 MyBank initiative 37 2.6 Other relevant matters of interest 39

Appendices 40

Appendix 1: Changes in EURO1/STEP1 participation 40 Appendix 2: List of Direct Participants in EURO1/STEP1 46 Appendix 3: List of Direct STEP2 Participants 54 Appendix 4: Annual accounts for 20 11 63

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2 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board 1. The Company’s activities in 2011

The period under report is 1 st January 2011 to 31 st December 2011.

1.1 Introduction 2011 witnessed another strong performance for EBA CLEARING with significant progress made on a number of fronts including the EURO1 reform programme, the successful evolution of STEP2 and the take up of new initiatives such as MyBank. In close consultation with its users, EBA CLEARING took important steps to further evolve its services in line with their future needs as well as the regulatory and oversight outlook. The EURO1 reform programme saw a first set of deliverables implemented throughout the year, which were geared at further improving the parti- cipants’ liquidity recycling and credit risk management capabilities. This proved to be of particularly crucial value to its participants in a year that was again marked by considerable liquidity constraints and increasing risk concerns.

EBA CLEARING’s PE-ACH continued its successful evolution as a key element of the industry’s SEPA strategy, accounting for over a third of the SEPA Credit Transfers channelled through CSMs. Two additional commu - nities moved their domestic payment business to the platform in 2011, which testified again the flexibility of STEP2 in supporting different migration paths for credit transfers and direct debits.

Towards the end of the year, the Company kicked off a SEPA large volume exchange project. The project is aimed at orchestrating a smooth ramp-up of the migration of domestic volumes leading up to the migration end-date on 1 st February 2014.

EBA CLEARING also took a major step towards the deployment of a pan-European e-SEPA solution: the objective of the MyBank initiative launched in June 2011 is to roll out a Europe-wide e-authorisation solution for online shopping, based on online banking.

1.2 EURO1/STEP1 Based on lessons learned from the financial crisis and in view of adapting Services EURO1 to the changed approaches to financial risk, the Board agreed to launch the EURO1 Reform Programme. The Board established the Future Development Group (FDG), which comprises representatives from both the treasury and payments departments of the largest users of the system, to accompany the works on the EURO1 Reform Programme. Work continued

3 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board throughout the year to address, as a matter of priority, risk mitigation in the system coupled with the maintaining of efficient liquidity usage.

Statistics

EURO1 achieved an all-time daily average record for payments sent in December 2011. This figure was 260,978 which surpassed the previous record of 249,042 transactions dating back to March 2008.

The improved volume figures were partly due to the closure of the STEP2 XCT service, and the re-routing of some of those payments into EURO1 and STEP1. For EURO1 there were 350,000 more payments for the month of December in the value category below EUR 12,500 compared with November.

EURO1 Reform Program – risk control

During the course of the year, the proposal to reduce the minimum amount of the mandatory element of the bilateral limit allocation from EUR 5 million per bank to EUR 2 million per bank took shape. To offset the resultant reduction in the amount of liquidity in the system, at the same time the maximum amount of the discretionary element of the bilateral limit allocation was to be increased from EUR 25 million to EUR 50 million.

Detailed modelling took place to ensure there would be no negative impact on the daily flow of payments through the system. EBA CLEARING then undertook an intensive programme of communication and visits to banks and country communities to ensure all users fully understood their obligatio n to recalibrate their bilateral limit allocations in order to maintain the debit and credit caps required for their individual payments traffic in EURO1.

Following the approval by the ECB as Overseer, the limit amount changes were introduced in two stages over two days (24 th and 25 th October 2011) and, concurrently with these, the system cut-off time for amending the discretionary element was put at 07.00 CET on day D. This change means that banks can now react to deteriorating events that may have taken place over a bank holiday, over a weekend or overnight and adjust their exposures accordingly.

4 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board The change-over was a complete success with no impact on the integrity of the system. On the first day over 3,400 bilateral limit changes were recorded by the central system, which demonstrated how all the Partici - pants had duly reapplied their bilateral limit allocations. The queuing profile and payment throughput did neither alter for the system as a whole nor for any individual bank.

EBA CLEARING, through its internal Risk Management Task Force and under the auspices of the Risk Committee of the Board, actively looks at ways to address potential concerns in the area of credit risk deterioration. The Risk Committee is composed of Robert Heisterborg, Hays Littlejohn and Christian Westerhaus.

EURO1 Reform Program – liquidity management

Following in-depth analysis of usage of the liquidity bridge by the Partici - pants it was identified that two additional distribution windows would serve to further reduce queuing and release payments for processing earlier. After due discussion with and approval from the ECB as Overseer, the new windows at 11.00 CET and 12.00 CET were introduced in May 2011. Naturally distributions increased substantially with the move from four to six windows and as a result 98% of what was pre-funded on a daily basis is now distributed back to the banks on average.

Additionally, at the same time, the algorithm for calculating how much could be distributed to each eligible bank was adjusted from 60% of credit cap usage to 40% of credit cap usage, which also helped to increase the distribution percentage.

The two new windows resulted in the EURO1 system as a whole achieving a Liquidity Efficiency Ratio (LER) of 14, meaning that each euro in the system turned over 14 times per day on average. For the larger users of the system in terms of value sent and received this ratio can be as high as 100 to 200 times.

Oversight

The comprehensive oversight assessment of EURO1 against the 10 Core Principles for Systemically Important Payment Systems was completed during 2011. The assessment had been started in 2010 and required,

5 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board amongst other items, the updating of the German and French legal opinions in respect to the system.

EURO1 remains fully compliant with Core Principles I to IX and, due to the fact that there was no dedicated risk management function within EBA CLEARING, EURO1 was found to be broadly compliant with Core Principle X on governance. This has already been addressed by EBA CLEARING, starting from September 2011, and has been marked as a footnote as such within the published report on the ECB’s website.

The assessment was carried out by the ECB as lead overseer with the participation by a panel of the Eurosystem central banks (Banco de Espana, Banque de France, Banca d’Italia, and ).

During 2011 the CPSS-IOSCO new Principles for Financial Market Infrastructures were issued for consultation. EBA CLEARING has responded to the consultation with a focus on the possible impact of each of the 24 new Principles on how EURO1 as a system operates and on how EBA CLEARING functions as a system operator. Further discussions on this topic with the ECB are planned to understand how the Principles should be interpreted for application to EURO1 and by when compliance must be achieved.

EURO1 Simulator

EBA CLEARING has built a EURO1 simulator tool. The Bank of Finland already had a standard product but it required specific enhancement to incorporate the credit cap arrangement applying within EURO1. The simulator provided valuable support in the modelling required to test the impact of changes in the levels of the constituent parts of the bilateral limits.

The simulator is also being used to model various scenarios in the context of works on risk mitigation such as the limit amount changes in EURO1.

System Releases

Release 11.1 was a functional release on 16 th May 2011 basically covering housekeeping changes with low impact on users.

6 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board Release 11.1.1 was a technical patch for a mandatory Oracle upgrade with no impact on the users.

Release 11.2 was the functional release to introduce the new risk controls.

While normally a maximum of one functional release per year is planned, the situation in the financial markets has required an accelerated release timetable.

Negotiations with SWIFT during the year resulted in the Annual Operating Charge (SWIFT AOC) being reduced by 10%, so that over the last three years there has been over a 30% reduction in this charge.

At the request of both the commercial banks and SWIFT, EBA CLEARING was invited to join the Payments Markets Practice Group (PMPG) forum that is addressing the development of MX payments messaging for high value payment systems. For EURO1 in particular this means looking at the creation of a new MX for the MT 400 messages handled within EURO1 (in December there were some 6.500 MT 400s sent by over half the EURO1 community). Another issue is the need for a partial copy version of Interact - Copy so EURO1 can remain in its partial copy environment.

Directory

By year-end, some 60 banks from 13 countries had entered details of over 12,700 reachable identities in the EURO1/STEP1 Directory. In turn these represented a further 22,000 BICs on top of the 10,600 Participant BICs already within the system.

A study for enhancing the functionality and increasing the acceptability and usage of the Directory is now linking into the work of SWIFT related to their Global Payments Reference Utility, recognising the banks’ concerns at the ever-growing number of directories that they have to manage. The proposed developments should be in place by the end of 2012.

Participation

In November 2011 National Westminster Bank withdrew from EURO1 as a direct participant to become a sub-participant of . This brought the number of direct participants to 66. At the end of the year

7 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board there were 53 sub-participants in EURO1 compared with 58 at the beginning . This reflects the ongoing consolidation within the industry and also within banking groups themselves.

Other changes in ownership are still being finalised that concern EURO1 participants.

There were 94 STEP1 banks at the start of the year and 93 at the end of 2011, which also took into account the connection of The Bank of New York Mellon in March 2011 and Kookmin Bank International in June 2011. Consolidation within the Spanish savings bank market (Cajas de Ahorros) and the reconstitution of many Cajas into quoted companies resulted in a reduction in STEP1 sub-participants from 47 at the beginning of the year to 41 at the end of the year.

With the closure of the STEP2 XCT system the 10 pre-fund participants (7 national central banks and 3 commercial banks) were withdrawn from the EURO1 system. The pre-fund participant status was only available for settlement of STEP2 XCT and is therefore inactive.

SEPA End-date Regulation

During the course of the year, EBA CLEARING added its own voice to advocate for high value payment systems to be out of scope for the SEPA end-date regulation. This has been successful in the light of the wording of Regulation 260/2012 published on 30 th March 2012.

1.3 STEP2 Services During 2011, the main activities of the Company regarding the STEP2 Services and platform were based around four work strands:

1. The ongoing work of attracting domestic volumes to the SCT Service; 2. The positioning of additional services on the STEP2 platform; 3. The gradual build up of volumes in the SDD Services; 4. The mandatory release work and developments from the EPC Rulebooks.

Banks and domestic communities were assessing throughout 2011 how to maximise the advantage of the SEPA investments they have made.

8 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board 1.3.1 Average daily volumes

XCT Service

During most of 2011, STEP2 XCT volumes remained steady with a daily average of 150,000 payments per day. In October there were still over 100,000 payments per day and only in the last weeks and days did traffic drop below this figure, before the service was closed on the 5 th December 2011.

The decision to close the service came following the recommendation of the STEP2 XCT User Advisory Group to close down the service by 31 st December 2011 and the Board’s approval of this recommendation.

A detailed analysis of the STEP2 XCT payment traffic showed that 97.5 percent of all XCT transactions could migrate to SCT. The remaining payments (circa 3,500 payments per day) either related to banks that had not yet adhered to the SCT Scheme or to banks that had joined the scheme and were already reachable via STEP2 SCT but not for those BICs.

The formal termination notice, as well as a separate cover note on record keeping after closure of the service, were sent to each Direct Participant.

The closure went smoothly and payments migrated to other services.

SEPA Credit Transfer Service (SCT)

Volumes in SCT continued to grow rapidly during 2011 doubling in volume to 2.4 million payments per day by the end of the year. The platform is fully scalable and has undergone significant performance / resilience tests based on 50 million transactions per day.

During the year, the banks operating in Finland completed their domestic migration to SEPA with STEP2 being their prime clearing system. Finnish payments now make up over 50% of the SCT traffic. Banks from all countries are using STEP2 for domestic payments, with Italy, France, Luxembourg sending increasing volumes. Ireland has commenced domestic migration to SEPA using STEP2 SCT. In total, 70% of all payments sent to STEP2 SCT are domestic.

Multinational banks are also pulling payments out of local systems and sending all SEPA payments, whether domestic or cross-border, through SCT as a single channel.

9 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board SEPA Direct Debit Services (SDD Core)

At the beginning of the year, STEP2 SDD Core had a daily average volume of 5,000 transactions doubling to 10,000 in July 2011 and volume growth was constant until November. In December this figure grew tenfold to over 100,000 collections with 250,000 received on one single day. These volumes come almost exclusively from Belgium where Debit migration is taking place and STEP2 is the only clearing system being used for SEPA Direct Debits.

SEPA Direct Debit Services (SDD B2B)

At the beginning of the year STEP2 SDD B2B had a daily average volume of 1,897 collections. This has grown to just over 5,000 transactions per day.

Italian Credit Transfer Service (ICT)

During 2011, the volume has continued to be stable with a daily average of 1,200,000 payments a day, which is similar to the year before.

Irish Transfer Service (IET)

IET went live in October 2011 and has performed very smoothly since. Each day IET is responsible for settling 700,000 legacy Irish Credits and Debits between the six banks that are Direct Participants.

IET does not process individual transactions and is built on an efficient Bilateral File Exchange model.

1.3.2 Service activities undertaken during the reporting period

General Points

Incidents

No serious incidents occurred during the period.

During 2011, the STEP2 SCT Service witnessed an improvement of STP rates. As volumes rose, the rejection rate fell. In January 2011, the rate was

10 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board one rejection for every 10,000 transactions, whereas by the end of the year the rate was one rejection for every 40,000 transactions. For certain banks, the rate has even been as low as one rejection per 2 million transactions.

This appeared to be a result of the increased number of domestic payments being equipped with the correct combination of BIC and IBAN, as well as the awareness-raising activities of EBA CLEARING and the subsequent improvement of bank-internal validation processes. This task of continuous improvement is actively pursued.

This high STP rate has led EBA CLEARING to create a low-cost service level, removing redundant validation, for those banks that are interested in using it (see “Batch Processing” under Point 2.2 New initiatives).

Receiving Bank Performance Monitoring

As high domestic volumes have started to be sent through the service, it was noticed on several occasions that some of the receiving banks had a low bandwidth in place, which considerably slowed down the reception of large payment volumes.

This affects the speed of STEP2 sending to other banks, and indicates the need for addressing readiness to receive high volumes on the part of the receiving banks. Results of EBA CLEARING’s speed monitoring activities were distributed to the user community and led to banks upgrading lines and bandwidth. Furthermore, preparations to offer file split to suit multi- processing environments started in 2011.

Direct Debit Cut-off times, and Notification of R-messages

A number of banks have said that EBA CLEARING’s cut-off and settlement times give STEP2 SDD a competitive disadvantage. This with a number of other settlement issues is being looked at through the STEP2 SEPA BWG. There is also discussion around how a bank can guard itself against wrong R-messages, whether R-messages and Debits should be settled together, whether a bank should be able to reject a refund message and what the level of controls should be around these messages.

11 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board Strengthening STEP2 Resilience

As volumes are increasing, a consultation was launched to consider how to enhance STEP2 as it becomes more critical. The consultation led to three recommendations:

 STEP2 should have more cycles, to smooth file sending patterns and allow better handling of problems if one bank does not have sufficient liquidity. This was delivered in February 2012.

 EBA CLEARING should test that banks can properly handle duplicate payments, bulks and files if they are resent during a contingency scenario. This was included in November 2011 testing.

 EBA CLEARING should provide an automated way for a bank to ask for a file to be resent via the DPWS and under the control of the bank. This was delivered in November 2011.

Fraunhofer Review of STEP2 XML Capability

EBA CLEARING decided to seek specialist guidance on the use of XML, which is seen as new technology within banking, but which is well- established in other areas.

The Fraunhofer Institute, as highly regarded independent body that specialises in applied engineering, was contacted to give an opinion firstly on the specific case of XML file corruption risks due to use of combinations of characters, with a view to coming to a longer term understanding taking into account large volume processing and the relating infrastructure options.

A review of the STEP2 XML parser was completed. Some suggestions were made for improving the way the parser works, but Fraunhofer were able to state that the implementation is sound and in line with practices in other industries.

STEP2 Interoperability Framework

EBA CLEARING has raised awareness about its interoperability framework, and the successful way of achieving reach by linking with 14 other CSMs.

12 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board 1.3.3 Service Improvements

The following improvements were implemented during 2011.

Single URL for disaster recover.

An enhancement was deployed on 17 th January 2011 so that in the case STEP2 moves to a Disaster Recovery situation, the banks do not have to change the URL in the test or live environment.

Upgrade of SWIFT lines on the Test System for Bank volume testing

A number of banks have asked for the ability to exchange large volumes of SEPA Credit Transfers on the test system, in order to prove the capabilities of their own systems. The test system SWIFTNet line was upgraded on 6 th May 2011 to better manage volume testing.

Improving Night-time Settlement Process (MNM 2.1).

The STEP2 MNM was upgraded on 25 th July 2011 to allow multiple ASI6 cycles to be handled, and to automatically freeze position when no files have been received. EBA CLEARING procedures were also upgraded to allow for addressing operational or technical issues occurring during an ASI6 cycle until a later time during the night.

STEP2 SEPA Rulebook release

The November release contains the 2011 Rulebook updates as well as user driven and operational related requests. This release also brings compatibility with SWIFTNet Release 7.0 and TARGET2 version 5.0. This was successfully deployed on 21 st November 2011.

Making Routing Table Updates more flexible

Due to complex mergers, banks sometimes need routing table updates that fall outside the timetable of the planned change dates. From November 2011, additional change dates were allowed, although the related changes are all to be sent in one routing table file once a month.

13 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board DMRF Simplification

Participants have requested that for simplicity the letter of notification for an indirect participant, and the DMRF form that contains the BICs are merged into one document. This was delivered with updated forms and legal documentation as part of the November 2011 release.

Additional Reporting on Cancellations

Following the 2010 implementation of the EPC Recall message, users have asked for an additional report clarifying when a recall has been accepted and applied and when a recall has been accepted and forwarded. This was implemented as part of the November 2011 release.

Additional cycles

Two new cycles were added to STEP2 SCT, bringing a total of four cycles during the day, and extending the window for same day payments by one hour until 14:00. This was actually implemented in February 2012.

Sending Settlement Output Comments Cut off time 02:00 07.30 08:30 Existing SCT Cycle

09:00 09:45 10:45 New

11:30 12:15 12:45 Existing SCT Cycle

14:00 14:45 15:45 New

Banks can send payments for a given cycle. Banks can also send payments without specifying when they should be settled. They will be put into the available next cycle. As a result:

 The receiver has payments delivered even more smoothly throughout the day;

 Problems with settlement can be managed even more quickly;

 Where one bank has problems, their payments can be removed from the Settlement and STEP2 automatically puts them into the next cycle;

14 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board  Delivery can continue to the rest of the community without one bank waiting to solve a liquidity problem.

At the same time a new optional night cycle is being offered with a 20:00 CET cut off and settling shortly after in TARGET2 using ASI 6. This allows payments that would have been settled the next morning to be settled this evening, but with tomorrow’s settlement date, and so the output can be processed during the night.

1.4 Operations of the The central systems, operated by EBA CLEARING Service suppliers, clearing systems SWIFT and SIA, performed throughout the year in full compliance with the service level agreements.

The volumes in EURO1/STEP1 and STEP2 showed continuing month- on-month increase with no impact on the processing behaviour and speed of the central systems.

The values transmitted via EURO1 were aligned with the recommended target figures as indicated in EBA CLEARING’s Code of Conduct for the EURO1/STEP1 Services.

In EURO1, the successful implementation of two additional distribution cycles, the revision of the credit cap threshold in the distribution algorithm and the addition of more regular intervals for circles processing resulted in liquidity benefits, in significant increase in the volume of the distributed liquidity, and an increased number of Participants in each distribution cycle.

The settlement of the STEP2 XCT Service in EURO1 during 2011 had no negative impact on the functioning of the operational process as a whole. The EURO1 settlement completion of the end-of-day in TARGET2 using ASI 4 module stayed firm at 16:08 CET. The settlement of the STEP2 Services cycles in TARGET2 using ASI4 and ASI6 modules functioned as designed throughout 2011.

The mandatory hardware upgrades and scheduled software release implementations on the in-house Operations infrastructure supporting EURO1 settlement, pre-funding, liquidity distribution services and SWIFT - Net browsing services were transparent to the Participants.

The test environments of all Services were available during all operating days. The test time schedules are also available on the EBA CLEARING

15 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board website. The SATP application for SEPA SDD testing Participants was available during the scheduled testing windows throughout the year and proved to be an efficient tool for the Participants’ end to end testing activities. Further enhancement of this tool, i.e. process automation and the addition of SCT Services is scheduled in 2012.

Statistics

The regular statistical reports for all live Services were distributed to the Participants via dedicated pages of the EBA CLEARING website. In addition to the monthly statistics reports published on the website, specific statistical reports and analysis were provided to the Overseer, as well as to Participants (and their NCBs) as per their specific requests.

Investigations and customer support

The EBA CLEARING Investigations and Customer Support Unit continuously supported the participants throughout the year. The Unit handled approximately 200 cases per month of which almost 80% were submitted via the web form, followed by queries channelled by phone and via e-mails.

In 2011, the third ICU survey on customer satisfaction was addressed to more than 400 contacts representing 137 different banks over 23 countries. The questions related to the satisfaction level of the rendered services in terms of problem resolution, skill level, courtesy, timing and the usage of the broadcast communication channel, Real Time Window (RTW). The outcomes displayed very high customer satisfaction levels with all live Services.

The survey resulted in the improved quality of the contact list management, launch of the new SMS incident alert and in the enhancement of the inquiry webforms available on the website.

Business continuity testing

Numerous testing exercises for all the live Services were carried out throughout the year. These exercises involved stakeholders such as Services suppliers, participating banks and the EBA CLEARING staff members and focused mostly on the self-certification, testing of abnormal and emergency procedures and simulation of the crisis events.

16 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board Incident process management

In 2011, the activities were to revise and embed the new incident management structure within the Company. This effort resulted in the production of new documentation, company-wide training of the concepts, and desktop crisis and incident exercises. During the year, comprehensive incident reporting was complemented with dedicated e-mail and SMS alerts to banks.

1.5 Information Security Early 2011, EBA CLEARING has created a new organisational unit where and Business all Information Security and Business Continuity related tasks and Continuity responsibilities are centralized. Management Although the business continuity related activities initially focused on EURO1, with the growing role of the STEP2 service in supporting the banks’ retail payments business, the Company’s Business Continuity Management focus has been increasingly directed to include as well the STEP2 SEPA services platform.

More recently, Information Security gained importance through increased oversight and customer expectations. The centralized management of Information Security ensures that key information assets are effectively protected by standardized measures and controls, while at the same time not impeding EBA CLEARING from achieving its business goals and objectives.

With these considerations in mind the objective of EBA CLEARING is to maintain both a Business Continuity Management System (BCMS), as well as an Information Security Management System (ISMS), covering all activities.

The creation of the unit also corresponded to “best practice” in the context of Business Continuity Oversight Expectations of the ECB.

Information Security

Throughout 2011, EBA CLEARING has focussed on the roll-out of an Information Security Management System (ISMS), which can be compared to and is aligned with the ISO/IEC 27001 certification requirements. For this purpose an ISMS readiness assessment was completed by an external

17 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board firm, and company-wide classroom sessions were organised to raise the general levels of awareness in this regard.

On 28 th March 2012 the EBA CLEARING Board formally endorsed an Information Security Policy (ISP) document as part of the official introduction for establishing, implementing, operating, monitoring, reviewing, maintaining and improving a documented ISMS, within the context of the organisation’s overall business risk.

The ISP is subject to a regular (yearly) assessment by the Board.

Business Continuity Management

Throughout 2011, the IS&BCM Unit focussed also on the maintenance of its Business Continuity Management System (BCMS) which has been aligned with the British Standard (BS) 25999.

The EBA CLEARING Board re-endorsed its Business Continuity Policy and Strategy (BCP and BCS) on 28th March 2012. Both documents, were firstly introduced in 2010, and are subject to yearly assessment, which formalises the Board’s commitment and accountability regarding Business Continuity.

Apart from the abovementioned, EBA CLEARING continued to regularly test the various resiliency and business continuity tools at its disposal. OPC site switches continue to take place with regular intervals and include the exchange of staff members between the centres. Moreover, all mandatory and voluntary EURO1 fall back settlement exercises have been carried out and were completed successfully.

On 29 th January 2011 the yearly STEP2 Crisis Simulation test was executed successfully. The exercise was co-ordinated by EBA CLEARING following an invitation letter that was sent to all banks in September 2010. The test, in which 43 banks participated, was designed to Live test the availability and the functionality of the SIA Disaster Recovery Site for the STEP2 SEPA Services, namely SCT, SDD Core as well as SDD B2B, both in terms of file sending/receiving and connectivity to the Direct Participant Workstation (DPWS) or an equivalent. Moreover, the exercise included EBA CLEARING’s own Remote Operational Location (ROL) facilities for enquiring purposes ensuring disaster recovery capabilities. A final test report has been sent to all STEP2 participants.

18 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board On 24 th and 25 th May 2011 EBA CLEARING participated in the Bi-Annual SWIFT Crisis Coordination & Communication (SC3) Exercise. This global event was attended by a large delegation from all principal SWIFT Banks, leading Central Banks and key Market Infrastructures. A closing report has been produced which demonstrated that the exercise successfully achieved its desired goals and objectives, with participants noting a high level of satisfaction.

The simulation identified a number of overarching insights in case of a significant SWIFT crisis and revealed the need for further improvements in the communication process and the overall understanding of the business and operational aspects of DRI, reconciliation and distributed architecture.

On 25 th October 2011 EBA CLEARING organised an internal ‘Live’ Crisis Management Exercise (CME), under the guidance of an external firm. In summary, the exercise simulated the simultaneous outage of one of EBA CLEARING’s Operational Centres and SWIFT. This realistic exercise included the participation of a broad variety of EBA CLEARING units, such as Communications, Legal, and Human Resources.

Moreover, the simulation demonstrated that the new layout of Tactical and Strategic Crisis Management Team guidelines operates well, even under extremely stressful circumstances. In co-operation with EBA CLEARING Operations, the ISBCM Unit aims to repeat such exercises at least on a yearly basis.

1.6 MyBank initiative During the first half of 2011, EBA CLEARING, at the request of the Board, prepared a Blueprint outlining the kind of services the Company sees in the area of e-authorisation. The Blueprint included an approach for moving forward and implementing e-services by the Company.

The MyBank initiative was publicly launched on 15 th June 2011 at EBAday in Madrid. The Blueprint that the Company had delivered served as a basis for consultations with the wider community of shareholders, other banks and payment service providers and representative stakeholders amongst the e-merchants and consumer communities, which started in mid-June.

Following the positive results of the consultation, EBA CLEARING continued the detailed definition of the MyBank solution and the planning for its deployment.

19 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board At a delivery level, the technical documentation of MyBank was drawn up and distributed to those having confirmed an interest in being future Participants. Feedback confirmed that the documentation provides a comprehensive basis allowing a straightforward implementation of the solution by future Participants.

A solution description was produced to give an overview of the relationships and the activities of the players. It also constituted a starting point for the delivery of the MyBank legal documentation foreseen for the first half of 2012.

Much work also went into defining the ongoing tasks that will be performed as MyBank moves out of the project delivery phase and into the live running phase. EBA CLEARING laid out the tasks for a “Solution Manager” role and started an analysis into the pros and cons of creating a specific corporate vehicle for owning and managing the solution, separately from the activities related to the management and operation of EBA CLEARING’s payment infrastructure services.

Considerable effort was made in the second half of the year in promoting MyBank with a broad community of payment service providers (“PSPs”) and other stakeholders. This work stream included a press campaign, participation in industry conferences and events, meetings with stakeholder industry organisations, such as merchant organisations and public authorities , at a pan-European level and nationally. A dedicated MyBank website (www.mybankpayments.eu ) was launched in September 2011 to provide the wider professional public with up-to-date information.

EBA CLEARING also entertained a very fruitful exchange with the vendor community, which started to engage in preparations geared at providing routing services, validation services, merchant plug-ins and other ancillary services facilitating the roll-out of MyBank.

By the end of the year, MyBank was firmly embedded in the minds of those interested in e-payments and e-mandates. All interlocutors confirmed the need for a pan-European online banking e-payment solution. They provided favourable feedback and are being kept informed by the EBA CLEARING Management of the progress of the initiative via regular meetings.

20 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board 1.7 Activities of Board Operations and Technical Committee (OTC) Committees The Committee convened three times during 2011 under the rotating chairmanship of Kristine De Lepeleire and Hays Littlejohn. The main subjects of discussion were the review of the EURO1/STEP1 Directory, MX format for payments and the introduction of a mandatory testing schedule in relation to EURO1/STEP1 technical and functional releases.

Furthermore, the OTC approved EURO1/STEP1 change requests, finalised the decommissioning of the SWIFT Monthly Information Letter and supported the limit changes and the implementation of additional distribution cycles. The OTC was also advised on the evolution of the STEP2 platforms and in particular of the November release, the launch of the Irish Domestic Service and the XCT closure.

Moreover, the Committee had an on-going dialogue on the operational business processes focusing on clearing and settlement, incident process management, customer support and its ICU survey results, statistics, reports on the business continuity testing, and on Business Continuity Management process.

Strategy and Policy Committee (SPC)

Under the chairmanship of Robert Heisterborg, the main items of discussion for the Strategy and Policy Committee in 2011 were the interoperability model practiced by EBA CLEARING with regard to other CSMs and the positioning of the Company towards new service opportunities.

With regard to the interoperability model, the SPC monitored the discussions that took place at industry level. The SPC concluded that the interoperability of STEP2 for SEPA services as currently in place through links with 14 ACH providers should be more widely communicated.

The Committee confirmed the positioning of the Company as an infrastructure solutions provider offering solutions in the cooperative space, and fully supports a multi-supplier policy foreseeing regular re-assessments of the supplier choices. As regards new services, the Committee pointed out that the introduction of urgent payments on STEP2 could be extended with bilateral file exchange as a new service opportunity.

The SPC considered the growing importance of the regulatory environment for the Company, and concluded that ongoing impact analyses are required

21 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board to ensure the Company’s activities and services continue to be compliant with all relevant regulatory requirements.

Innovation Committee

Under the chairmanship of Thomas Egner, the Committee held four meetings in 2011.

The Committee activities in 2011 where mainly focused on the status of activities around e-services. Following the delivery of a Blueprint document and the positive results of the stakeholder consultation, the MyBank initiative was publicly launched on 15 th June 2011 at EBAday in Madrid. The Committee was actively involved in the initiative and provided guidance on security aspects, legal considerations, stakeholder dialogue and governance model.

Additional subjects of discussions focused on potential Additional Optional Services that could emerge in the scope of the migration to SEPA, the evolution of the different initiatives around Account Numbers Transferability and the follow-up of the Structured Creditor Reference adoption.

The Innovation Committee will concentrate its forthcoming meetings on following the MyBank initiative status and roll out process, pursue discussions on Batch processing, Large Volume Exchange project, SEPA Card Clearing and Extended Remittance Information.

Furthermore, it will continue to broaden the dialogue with technology companies operating in the market and invite relevant parties to foster debate on dedicated topics.

Audit and Finance Committee (AFC)

The Audit and Finance Committee assists the Board in its responsibility to oversee EBA’s financing, financial statements, financial reporting process, and internal audit.

In 2011, the AFC held four meetings to review the quarterly financial results, the publication of annual report and full year financial statements prior to their release.

22 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board In the context of the three-year cycle audit process, the AFC defined an internal audit plan for 2012 in connection to Operations’ design and operating effectiveness.

In addition, the AFC launched in 2011 the initiative to introduce SEPA Direct Debits for the collection of payments of Company invoices that will be completed during the year 2012.

Risk Committee

During its meeting of 6 th September 2011, the Board decided to create a Risk Committee. The Risk Committee is composed of Robert Heisterborg, Hays Littlejohn and Christian Westerhaus and meets with the attendance of the EBA CLEARING Chairman and Chief Executive Officer.

The Committee met on several occasions in the fourth quarter of 2011. It dealt with the risk situation and potential risk scenarios for the Company's services in an environment of financial market turbulence and uncertainties. The Risk Committee issued in particular recommendations on the review of the risk profile of the EURO1 system. In 2012, the Risk Committee will oversee the work carried out by the Company on the finalisation of a comprehensive risk framework covering all services and activities and monitor its application. The Risk Committee will further focus on defining and finetuning the risk appetite statement to be adopted by the Board.

Legal Advisory Group (LAG)

During 2011, two meetings of the Legal Advisory Group were held under the chairmanship of Caroline Neyrinck. In addition, a conference call meeting was held on the specific topic of access by payment service providers other than credit institutions for the STEP2 SEPA services.

The activities of the EBA Legal Advisory Group during 2011 were for a good part devoted to changes and enhancements of STEP2. The Group accompa - nied the documenting of the new STEP2 Irish Service, the simplification of the document requirements for inclusion of indirect participants by direct participants in STEP2, the 2011 November release, the phasing out of STEP2 XCT, the preparations for the introduction of additional cycles in the STEP2 SCT Service and the preparations for a new batch processing service. The Group also started initial work looking at options to revisit the

23 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board system design and legal basis for settlement of STEP2-T, in particular from the viewpoint of strengthening certainty of settlement with an initial focus on the night time cycles. The latter works are expected to be resumed once the requirements for retail payment systems as will stem from the upcoming CPSS-IOSCO Principles for Financial Market Infrastructures will have been spelled out by the overseer.

The Group accompanied the changes relating to the intraday liquidity distributions and relating to the timing and amounts for limit setting in EURO1 as were introduced during 2011. The Group also followed the works on the EURO1 reform programme and will assist the legal work as is expected for 2012 in relation to changes to the risk profile of the EURO1 system.

In relation to the MyBank initiative, the EBA Legal Advisory Group analysed a term sheet and an initial draft for legal documentation to govern participation in the MyBank initiative. While a dedicated legal working group comprised of lawyers representing payment service providers that have confirmed their support and/or willingness to participate in the piloting of MyBank will be set up for detailed input on the legal documentation for MyBank, it is foreseen that the EBA Legal Advisory Group will review the legal documentation as per the same approach that applies for the legal documentation governing the payment system offerings of EBA CLEARING. For 2012, a specific work stream will consist of the review of drafts for updated country opinions on EURO1 in view of submitting the same to the ECB as lead overseer of the EURO1 system. As was agreed with the ECB, all country opinions must be updated now that the changes of 2009 to the Settlement Finality Directive have been implemented into national law. The EBA Legal Advisory Group has set up dedicated sub-groups which each will review a given set of updated country opinions. It is thereby foreseen that only those country opinions will be updated that are currently relevant for participation in EURO1.

24 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board 1.8 Corporate matters The term of office of five Board Members expired at the Shareholders Meeting on 14 th June 2011.

The following Board Members were appointed by the Shareholders Meeting on 14 th June 2011 for a three-year term of office:

Kristine De Lepeleire KBC BANK Pip Evans BANK Olli Kähkönen BANK FINLAND Narinda Viguier CREDIT AGRICOLE Christian Westerhaus

At the end of the Shareholders Meeting on 14 th June 2011 the Board was composed as follows:

Chairman: (until Shareholders Meeting in )

Giorgio Ferrero 20 13

Deputy Chairman:

Robert Heisterborg ING BANK 20 13

Other Board Members:

Daniele Danese BANCO POPOLARE 2012 Rui Fonseca CAIXA GERAL DE DEPOSITOS 2012 Diarmuid Hanrahan 2012 José Luis F. Iglesias BANCO BILBAO VIZCAYA ARGENTARIA 2012 Kirstine Nilsson 2012 Yannick Chagnon SOCIETE GENERALE 2013 Thomas Egner 2013 Hays Littlejohn UBS AG 2013 Kristine De Lepeleire KBC BANK 2014 Pip Evans BARCLAYS BANK 2014 Olli Kähkönen NORDEA BANK FINLAND 2014 st ANsaorfin3d1 a VDigeucieemr ber 2010CtRhEeDBIoTaArdGwRaICsOcoLmE posed as follows: 2014 Christian Westerhaus DEUTSCHE BANK 2014

25 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board Paul Nixon, HSBC Bank, was appointed by the Board as EBA CLEARING Board member for the remaining term of office of Pip Evans further to the resignation of the latter and further to a correspondence vote called on 4 th November 2011.

Marie Cheval, Société Générale, was appointed on 21 st November 2011 by the Board as EBA CLEARING Board member for effect as from 1 st January 2012 and for the remaining term of office of Yannick Chagnon further to the resignation of the latter.

Bart Guns, KBC Bank, was appointed on 13 th April 2012 by the Board as EBA CLEARING Board member for the remaining term of office of Kristine De Lepeleire further to the resignation of the latter.

The Chairman thanks those Board Members whose mandate will terminate at the end of the present Shareholders Meeting.

The following EBA CLEARING Board meetings took place in 2011:

 8th & 9 th February (Board seminar)  6th April  11 th May  6th September  21 st November

Transfer of shares and changes in share capital of EBA CLEARING

The following changes occurred in 2011 as far as EBA CLEARING share capital and EBA CLEARING shareholders are concerned:

With effect as of 1 st July 2011, Caja Madrid was replaced by S.A. as EURO1 Participant and EBA CLEARING Shareholder.

With effect as of 1 st July 2011 Caixa d’Estalvis i Pensions de Barcelona (“La Caixa”) was replaced by CaixaBank S.A. as EURO1 Participant and EBA CLEARING Shareholder.

With effect as of 21 st November 2011, National Westminster Bank Plc withdrew as EURO1 Participant and EBA CLEARING Shareholder and on the same day the EBA CLEARING share held by National Westminster Bank Plc was purchased by EBA CLEARING in view on its cancellation and

26 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board the EBA CLEARING share capital was decreased accordingly from EUR 67,000 to EUR 66,000.

As a consequence the share capital of EBA CLEARING amounted to EUR 66,000 on 31 st December 2011.

Regulated agreements entered into by the Company

With reference to regulated agreements subject to the procedure of Article L-227-10 of the French Commercial Code entered into in 2011 by the Company, it is hereby reported that 495 shares of ABE Administration SA held by the as well as 10 individual shares of ABE Administration SA held by the Board members of ABE Administration SA were purchased on 7 th June 2011 by EBA CLEARING at the price of EUR 100 per share in view of the absorption by EBA CLEARING of ABE Administration S.A. approved by the Shareholders Meeting of EBA CLEARING on 14 th June 2011.

1.9 Financial situation: The result before tax of the Company for the fiscal year 2011 stands at EUR P&L statement as of 1,799,988 on a total business revenue of EUR 29,932,363. The latter 31 st December 2011 progressed by 9.54% compared to 2010 and is higher by 6% than foreseen in the Budget 2011.

At the same time, the increase of the Services’ direct costs is less pronounced (+2% compared to Budget), which creates a gross margin that is higher by 12% than the one budgeted and largely covers the company costs that have been kept at the level of the budgeted figures.

The components of this result are as follows:

The Services’ revenues

A combination of factors has contributed to the increase in income and has led to a higher result than initially budgeted:

 The long established services, namely EURO1/STEP1, ICT and XCT have substantially over-performed compared to the amount budgeted

27 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board in November 2010. As a consequence, the traffic revenues generated by the EURO1 and STEP1 services exceeded budget respectively by 15% and 6%. Actually the revenues of EURO1 increased by 4% compared to 2010.

Even if the XCT traffic diminished compared with 2010, it was at a much lower rate than expected, leading to additional traffic revenue that, compared with the 2011 Budget, is higher by 155%.

The ICT service revenue also benefited from traffic revenue that was higher than foreseen.

 Participation in the SEPA systems continued its growth with a slightly lower rate than the budgeted figures. The traffic billed in excess of the minimum fees in the SCT services grew by 6%, contrary to the traffic of the Direct Debit services, keeping the overall traffic revenue of the SEPA services close to the budgeted figures (-1%).

 It should also be noted that the introduction of the Irish service created another stream of non-budgeted revenue.

The Services’ direct costs

The direct cost of the EURO1/STEP1 systems is in line with the budgeted figures, with a small increase of 0.45%.

The direct variable cost of the XCT system is in line with the traffic and, logically, higher than expected but was compensated by lower figures in the Direct Debit services.

The major part of the 2% increase in overall direct cost vis-à-vis the 2011 Budget results from new developments and analysis such as the Irish service and the “MyBank project”.

The total direct cost is EUR 18,457,265 compared to EUR 16,163,249 in 2010; i.e. a 14% difference, explained by the increase in the SCT variable cost, the first full impact of the depreciation of the Direct Debit services, and the above mentioned new developments.

28 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board Gross Margin

With higher revenues and a proportionally lower increase in the direct cost, the gross margin 2011 comes logically to a substantially higher level than expected against the Budget (+12%).

Company Costs

The Company’s operating charges were EUR 9,675,110 and are slightly under the 2011 budgeted figures (-1%), while human resources costs were kept below budget. The increase compared to the 2010 figures (+1%) results from opportunities seized in terms of equipment and premises and from the effort put into the external relations for the promotion of the “MyBank” project.

At the same time, the financial charges were reduced thanks to the higher- than-expected liquidity, resulting from the above-mentioned increased revenues, that allowed the Company to reduce the use of its credit lines with its house banks.

Result before tax

As explained above, the unexpected substantial increase in revenues coupled with less than proportional Services’ direct costs and stable company costs against the budget enabled the Company to make a profit before tax of EUR 1,799,988 i.e. 15% higher than the 2010 figures, which, nevertheless, represents only 6 % of the 2011 total revenue.

Income tax and net result

The French corporate tax for 2011 will be EUR 566,719.

According to the French fiscal law, the following amounts are non- deductible:

 Never deductible: income tax for EUR 630,069  Non-deductible on the current year (timing difference)  Organic Tax: EUR 7,049  Profit sharing attributed by law to employees: EUR 128,087

29 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board The tax to be paid in Belgium (for a branch that has no direct revenues) is proportional to the costs borne in the Brussels branch and needs to be adjusted “a posteriori”. It will be finally determined and paid in 2012 for this 2011 result. The amount provisioned for 2011 is EUR 75,000 but will be reduced to EUR 63,351 by the excess recovered on previous years.

The Net Result after tax is then EUR 1,169,918 for 2011.

The Board recommends to the Shareholders Meeting to carry forward this profit.

Since the creation of EBA CLEARING, no dividends have been paid to shareholders. This was again the case in 2011 and it is proposed to be maintained for the following years.

General comment

It is worth underlining that 2011 was the last year of the existence of ABE Administration S.A., the service company which until end of July 2011 concentrated the relationship between the group and the main suppliers of the components of the company costs as well as a large part of the Human Resources. Since then and for the first full year in 2012, the accounting of the group is substantially simplified and will consist of a direct invoicing by EBA CLEARING to the Euro Banking Association for the different services supplied.

30 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board 2. The Company’s activities in 2012

The following EBA CLEARING Board meetings took place so far in 2012:

 8th February (Board seminar)  28 th March  13 th April

Transfer of shares and changes in share capital of EBA CLEARING

With effect as of 19 th March 2012, National Australia Bank Limited withdrew as EURO1 Participant and EBA CLEARING Shareholder and on the same day the EBA CLEARING share held by National Australia Bank Limited was purchased by EBA CLEARING in view on its cancellation and the EBA CLEARING share capital was decreased accordingly from EUR 66,000 to EUR 65,000.

2.1 EURO1/STEP1 Risk control Services The Future Development Group (FDG) continues to analyse how the risk profile of EURO1 can be further enhanced. A number of potential solutions are being considered by the FDG and discussions with the Overseer as well as feedback from the EURO1 community will be sought. It is intended to be able to have a proposal for the Board at its meeting in November.

In the meantime the potential for a further reduction of the mandatory element of the bilateral limit allocation to EUR 1 million per bank is being envisaged, including modelling the impact. This would mean halving the present exposure and would represent an overall 80% reduction in counterparty exposure compared to this time last year.

Liquidity management

Now that the liquidity bridge has reached its optimum functionality, the FDG has focussed on further refining the circles processing applied to resolve queuing. The process will be automated so that circles are applied by the system at frequent regular intervals throughout the day, once the initial start-up process has been completed.

31 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board Oversight

A full update of all the country legal opinions held to support the EURO1 system will be undertaken in the course of 2012. This exercise was deferred from 2011 while pending legislation to implement changes to the Settlement Finality Directive into national laws was enacted to ensure the opinions reflect the latest legislative situation.

Additionally it is being proposed that EBA CLEARING introduce its own form of Self-Certification for its Critical Participants. This is in line with the proposals contained within the new Principles concerning how a system operator should ensure adequate control of its Participants’ performance. EBA CLEARING has already designated all its Participants as critical in relation to participation in the settlement operations of EURO1.This view was endorsed by the ECB. The text of the self-assessment form will be agreed with the Board Risk Committee.

System Releases

Release 12.0 is a technical upgrade for the migration to SWIFTNet 7.0 and will be implemented early in the second quarter this year in line with the overall migration plans for the industry as a whole. There will be no impact on the users.

Release 12.1 is a functional release and will include the automation of the circles processing procedures and enhancements to the monitoring functionality for EBA CLEARING. There will be no impact on the users.

An additional minor system change is expected for the introduction of the planned further change to the mandatory element of the bilateral limits. This is expected to be in June/July (before the summer break) and should be relatively light given the nature of the changes involved.

Separately the redevelopment of the Business Administrators Workstation (BAWS) is progressing on schedule. The BAWS is still operating on the same platform as for the launch of EURO1 twelve years ago and needs to be upgraded as support for old version hardware/software will cease before the end of the year.

The assessment of the MX messaging requirements of EURO1/STEP1 will continue throughout this year with consultation by EBA CLEARING at bank and country level. It is intended to have a proposal for the Board in November

32 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board as to how the eventual migration for EURO1/STEP1 should be handled, as well as what in particular will be adapted. Such changes will need to track closely with the developments in TARGET2 to ensure at no time is EURO1 disadvantaged in terms of its offering to its members compared with TARGET2.

Participation

On 19 th March 2012 National Australia Bank withdrew from the EURO1 system. This means the number of direct participants is now 65. The number of sub-participants in EURO1 has reduced to 50.

Within STEP1 there have been a number of withdrawals for reasons related primarily to the ongoing crisis and the closure of the STEP2 XCT Service (since STEP1 offered an alternative means for settling STEP2 XCT payments). The number of direct participants is now 88 with 41 sub- participants.

2.2 STEP2 Services New Initiatives are being launched that relate to additional services or service enhancements requested by user banks.

Batch Processing

EBA CLEARING plans to offer batch processing capability for the STEP2 SCT Service as from April 2012. Banks will be able to send payments in batch files, which will attract a reduced validation at transaction level and a reduced processing cost.

Large Volume Exchange Project

In view of the upcoming SEPA migration end date, EBA CLEARING launched a programme to understand the specific requirements of users intending to channel very large volumes of retail payments through the STEP2 platform.

33 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board A blueprint document resulting from the work done within an initial study group on the matter will be discussed with the broader community of interested banks throughout the second quarter of 2012.

Given the capabilities the Company already has to cope with large volumes, the programme aims at defining additional requirements, where needed, for the platform evolution in terms of scale, operations and resilience. Based on the outcome of these discussions, the Company will establish a platform architecture strategy and consider available options for implementation. It is expected that this matter is ready for decision by mid-2012.

Account Number services

Most countries have solutions around account numbers that facilitate customers moving banks, banks merging with associated bank identifier and account number changes, and verification services that check that the account exists and belongs to the person claiming to own it.

The Management, under guidance from the Innovation Committee, is now developing a proposal for market testing that would solve these issues in a streamlined way.

Mandate Related Services

The EPC Advance Mandate Information (AMI) and the Italian SEPA Electronic Data Alignment (SEDA) concepts are two initiatives aimed at facilitating and (for SEDA) storing and validating mandate information. This work is being monitored for take up in 2012.

Overcoming risks of fragmentation post end-date

The industry has recently focused on the risks of continued fragmentation of the payments markets and the underlying infrastructures that may result from maintaining divergent business rules and services post end-date – often required by local regulation – that impact the processing of payments. EBA CLEARING shares the concern that banks operating in a multi-country mode may have to adapt to diverging market requirements and therefore will be forced to participate in several CSMs. While recognising

34 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board that this matter requires in a first place public authorities to cause relevant actors to change and to adjust towards harmonised business rules, EBA CLEARING wishes to contribute to this effort by bringing in its expertise as a pan-European operator. Such divergences hinder interoperability and the desired payment market integration.

2.3 Operations of the The central systems, both at the level of SWIFT and SIA, continued to clearing systems perform fully in line with the agreed service levels in the first months of 2012.

Customer suppor t

The fourth survey on customer satisfaction will be conducted this year and has started on 30 th March 2012. The results of the survey will be shared among the participants.

Business resilience testing

The time schedule for all the business resilience testing activities for 2012 was established. The testing areas cover all live Services, EURO1 / STEP1 and STEP2 and involve Operations staff, EBA CLEARING Service suppliers (SIA, SWIFT, ECB), and the Participants. In total, there are 15 types of exercises scheduled over 44 days; excluding summer months, this equates to a test per week.

Incident process management

In 2012, the objectives are to roll out the structure to Service suppliers such as SIA, SWIFT, and the ECB in order to assure there is common escalation reference in the event of an anomaly, and to leverage any synergies to assist in quicker resolution. Moreover, parts of the incident simulation exercises are incorporated into the scheduled business resilience testing activities performed by Operations Unit throughout the year 2012. The company crisis exercise, similar to the one organised in 2011, will be scheduled in the last quarter of 2012.

35 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board 2.4 Resilience, Business EBA CLEARING continued to regularly test the various IT resiliency and Continuity business continuity tools at its disposal. Site switches continued to take and Incident place with regular intervals and included the exchange of staff between the centres. Management With regard to the implementation of FACT24 – the technical supplier chosen for optimising the notification and alerting processes – the project has entered the next phase in preparation for the roll-out. As reported previously, the feasibility study was completed and new developments in the project will now focus on embedding all related processes (general communications, conference call facilities, etc.) into a single system used throughout the EBA Group.

The Information Security and Business Continuity Management Unit (ISBCMU) has completed the roll out of the ISO27001 aligned Information Security Management System (ISMS) guidelines within the Company. A specific work stream has been launched to assist EBA CLEARING in managing the information security risk and protecting its information assets.

The overarching Information Security Policy (ISP) has been formally endorsed by the Board on 28 th March 2012. The ISMS readiness assessment has been completed by an external company and an implementation plan towards an official certification process has been presented.

Exercises per department and unit are being prepared to ensure full under - standing and adoption.

With regard to the maintenance of the Company’s Business Continuity Management System (BCMS), the Policy and Strategy documents have been updated for 2012, and formally re-endorsed by the Board on 28 th March 2012.

On 31 st March 2012, the yearly STEP2 Crisis Simulation test was executed. This exercise was co-ordinated by EBA CLEARING following an invitation letter that was sent to all banks in September 2011. The test - in which 40 banks participated - is designed to Live test the availability and the functio - nality of SIA’s Disaster Recovery Site for the STEP2 SEPA Services, namely SCT, SDD Core as well as SDD B2B, both in terms of file sending/receiving and connectivity to the Direct Participant Workstation (DPWS) or an equivalent. The exercise also included EBA CLEARING’s own Remote Operational Location (ROL) facilities for enquiring purposes ensuring disaster recovery capabilities. A final test report is being produced.

36 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board 2.5 MyBank initiative In the first quarter of 2012, the Company continued to work on the implementation of the MyBank initiative and further geared up its preparations for the MyBank technical pilot starting on 4 th June 2012. A progress report on the 2011 activities, which also included an outlook on the planning for this year, was circulated to interested parties and stakeholders in January 2012.

Achievements for SCT

 The Technical and Security specifications are complete.

 The Security Report (external audit by the Fraunhofer institute) is complete.

 The Solution Description is complete.

 A Legal Working Group has been established. A first draft of the Legal documentation has been issued and a full set will be ready by the beginning of the pilot (4 th June).

To support the pilot:

 In March, the MyBank Test tool was released into the MyBank Pilot environment. Banks and integrators are now testing against it.

 In April the MyBank provisioning forms were deployed in the Pilot environment.

 In May, the MyBank directory was installed and is now running.

 A new set of explanatory documents, concentrating on factsheets, presentations and training slides has been commissioned to reflect the significant evolution of the MyBank initiative since 2011.

Since the beginning of 2012, the MyBank initiative has been given a further boost by the increasing emphasis public authorities and agencies are putting on the ‘digital agenda’. On 11 th January 2012 the European Commission published its Green Paper “Towards an integrated future for card, internet and mobile payments”, which includes the MyBank initiative. The “Digital Agenda” that is being pursued in a number of countries as a national reaction to improving efficiency and cutting costs in a time of budget cuts, is also helping to drive the demand for MyBank. The ECB response to the Commission’s green paper stresses the need for “ secure, efficient and

37 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board user-friendly online m-payment and e-payment services based on online banking infrastructure ”.

The MyBank Pilot

The MyBank pilot will be a period of technical testing with merchants, customers, payment service providers and routing service providers. It is the aim of the pilot to prove, before a wider roll-out, that the different components of MyBank work together seamlessly and to the satisfaction of all parties involved. The pilot mixes a cross-border and a country approach with national communities and pioneer payment service providers in other countries interested in proving cross-border concepts.

MyBank Business and Technical Working Groups have been created in early 2012. A test strategy has been published, and EBA CLEARING is now working with PSPs and merchants to describe the test cases around security, usability and end to end reconciliation.

Market readiness to adopt MyBank

It is clear that regulatory priorities such as Basel III and the SEPA end-date mean that banks face difficulties in scheduling MyBank into their project pipeline, and subsequently that they are reluctant to make planning commitments for a very quick development. However, the following facts are indicative of the good position MyBank has in the market.

 Italian Banks representing a very wide coverage of customer accounts and merchants intend to join the MyBank Pilot in Italy.

 The Luxembourg banks are working with local government on a MyBank pilot (“MengBank” in Luxembourgish).

 Discussions with iDEAL in the Netherlands and the Dutch Banks on the subject of interoperability are going well, with an MOU in preparation at the time of writing.

 Discussions are also ongoing with EPS in Austria.

 The Greek banks, driven by the mandate to cut Government ad- ministration costs are embracing MyBank. Three are preparing for the Pilot.

38 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board  Swedish banks are interested in knowing whether they can migrate the local scheme to MyBank (Direktbetalning). Other Nordic countries are in the same situation.

 The first demonstration of a working MyBank interface linked into an online banking application was made by a French bank in early April.

There is growing awareness of the ability of MyBank to deliver e-mandates and this is an important deliverable in SEPA migration plans.

The integrator community is also mobilised to follow MyBank, with tools to help merchants and banks, and mobile plug-in’s being developed. It is intended to use EBAday as communication platform to show case this progress.

2.6 Other relevant Presentations concerning the risk mitigation and liquidity management tools matters of interest available within EURO1 have taken place for the majority of users.

EBAday, Sibos, and country group meetings will be used to promote the current and future offerings of EBA CLEARING. Furthermore, the Company will remain dedicated to meet individual banks to discuss their needs and offer guidance.

39 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board APPENDIX 1

Changes to EURO1/STEP1 participation

2011

3rd January Cariprato (Cassa di Risparmio di Prato) was withdrawn as a Sub-Participant in STEP1 under Gruppo Banca Popolare di Vicenza.

Ibercaja – Caja de Ahorros y Monte de Piedad de Zaragoza, Aragon y Rioja withdrew as a STEP1 Bank.

10 th January Banca Cívica, S.A. was included as a Sub-Participant in STEP1 under CECA – Confederación Española de Cajas de Ahorros.

17 th January Banca Caripe was withdrawn as a Sub-Participant in EURO1 under Banco Popolare.

1st February The name of Veneto Banca Holding scpa (STEP1 Bank) changed to Veneto Banca scpa.

7th March The Bank of New York Mellon, Frankfurt branch, was connected as a STEP1 Bank.

Pohjola Bank Estonia was included as a Sub-Participant in EURO1 under Pohjola Bank Helsinki.

Banca Caripe was included as a Sub-Participant in STEP1 under TERCAS – Cassa di Risparmio di Teramo.

40 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board 4th April HSBC UBP was withdrawn as a Sub-Participant in EURO1 under HSBC France.

Banco Guipuzcoano was withdrawn as a STEP1 Bank and included as a Sub-Participant in EURO1 under Banc Sabadell.

Banco Grupo Cajatrés was included as a Sub-Participant in STEP1 under CECA – Confederación Española de Cajas de Ahorros.

9th May Banco Mare Nostrum was included as a Sub-Participant in STEP1 under CECA – Confederación Española de Cajas de Ahorros.

6th June Kookmin Bank International was connected as a STEP1 Bank.

21 st June Caja de Ahorros del Mediterráneo (STEP1 Bank) changed its name to Banco CAM, S.A.U.

1st July Caja Madrid (EURO1 Participant) changed its name to Bankia S.A., as part of its corporate restructuring into a quoted company.

Caixa d’Estalvis i Pensions de Barcelona - La Caixa (EURO1 Participant) changed its name to CaixaBank S.A. for the same reason.

UGF Banca (STEP1 Bank) changed its name to Unipol Banca SpA as part of a major rebranding exercise.

8th August Cassa di Risparmio della Spezia SpA was included as a Sub-Participant in EURO1 under Crédit Agricole S.A..

41 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board 5th September Roskilde Bank withdrew as a STEP1 Bank following its restructuring into FS Bank A/S.

Novacaixagalicia (CAVIES2V) withdrew as a STEP1 Sub-Participant of CECA – Confederación Española de Cajas de Ahorros.

15 th September STEP1 Bank Caixa de Aforros de Galicia, Vigo, Ourense e Pontevedra - Novacaixagalicia (CAGLESMM) changed its name to NCG Banco, SA.

1st October Caixa d’Estalvais de Catalunya Tarragona i Manresa (STEP1 Bank) changed its name to Catalunya Banc S.A..

Unnim – Caixa d’Estalvis Unio de Caixes de Manlleu, Sabadell i Terrassa (STEP1 Sub-Participant of CECA) changed its name to Unnim Banc S.A..

3rd October Banca MPS Belgio was withdrawn as a Sub-Participant in EURO1 of Banca Monte dei Paschi di Siena.

7th November The London branch of JP Morgan was included as a Sub-Address in EURO1.

Efibanca was withdrawn as a Sub-Participant in EURO1 of Banco Popolare as part of this group’s further rationalisation process.

11 th November DnB NOR Bank ASA (EURO1 Participant) changed its name to DNB Bank ASA.

42 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board 21 st November National Westminster Bank was withdrawn as EURO1 Participant and became a Sub-Participant in EURO1 under Royal Bank of Scotland Plc as part of the group’s overall policy of consolidation.

28 th November BancAperta (STEP1 Bank) merged into its existing STEP1 Sub-Participant , which then became STEP1 Bank with Credito Artigiano SpA, Cassa di Risparmio di Fano SpA and Credito Siciliano SpA as Sub- Participants, Banca dell’Artigianato e dell’Industria SpA and Credito Piemontese SpA being removed as Sub-Participants.

12 th December The following Pre-fund Participants were withdrawn from the EURO1 system as a result of the closure of the STEP2 XCT Service:

 Banca d'Italia  Banka Slovenije  bpost s.a. de Droit public  De Nederlandsche Bank N.V.  Deutsche Bundesbank  ICCREA Banca SpA  Magyar Nemzeti Bank  Narodowy Bank Polski  Oesterreichische Nationalbank  Raiffeisen Landesbank Südtirol AG / Cassa Centrale Raiffeisen dell’Alto Adige SpA

43 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board 2012

1st January The financial business of Bilbao Bizkaia Kutxa (STEP1 Bank), Caja Gipuzkoa San Sebastian – Kutxa (STEP1 Bank), Caja Vital (STEP1 Sub- Participant) and BBK Bank Cajasur (STEP1 Sub-Participant) was regrouped into S.A. with continuation of the separate STEP1 participations through four different participant BICs.

9th January Pohjola Bank, Latvia became a Sub-Participant in EURO1 of Pohjola Bank Finland.

Piraeus Bank, Greece (STEP1 Bank) was withdrawn from the STEP1 system.

6th February Banca Monte Parma (STEP1 Bank) was withdrawn from the STEP1 system, following internal reorganisation within the Intesa Sanpaolo group.

Société Générale Bank and Trust SA Luxembourg (STEP1 Bank) was withdrawn from the STEP1 system, having only been connected for the purposes of XCT settlement.

13 th February Cassa di Risparmio di Alessandria was withdrawn as a Sub-Participant in EURO1 of Banca Popolare di Milano, following its merger into another Sub- Participant, Banca di Legnano.

5th March Banca Popolare di Crema withdrew as a Sub -Address in EURO1 of Banco Popolare, as part of that group’s ongoing consolidation program.

Amagerbanken A/S (STEP1 Bank) was withdrawn from the STEP1 system.

44 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board 19 th March National Australia Bank withdrew from the EURO1 system as a Participant. At the same time its Sub-Participant Clydesdale Bank was also withdrawn.

Dexia Bank Belgium NV/SA (STEP1 Bank) was withdrawn from the STEP1 system.

22 nd March Banque Internationale à Luxembourg S.A. (EURO1 Participant) changed its name to Banque Internationale à Luxembourg S.A.

10 th April Banca Popolare di Verona was withdrawn as a Sub-Address in EURO1 of Banco Popolare, continuing that banking group’s consolidation process.

7th May Banca Popolare di Novara was withdrawn as a Sub-Participant in EURO1 of Banco Popolare.

45 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board APPENDIX 2

List of Direct Participants in EURO1/STEP1 (as of 14 th May 2012 )

ABN AMRO Bank N.V. EURO1 Participant Aktia Bank plc STEP1 Bank Allgemeine Sparkasse Oberösterreich Bank AG STEP1 Bank Allied Irish Banks EURO1 Participant Allied Irish Bank (GB) EURO1 Sub-Participant First Trust Bank EURO1 Sub-Participant AE EURO1 Participant A/S STEP1 Bank Banca Agricola Popolare di Ragusa STEP1 Bank Banca del Fucino STEP1 Bank Banca del Piemonte STEP1 Bank Banca delle Marche S.p.A STEP1 Bank Banca di Imola S.p.A STEP1 Bank Banca di Romagna S.p.A. STEP1 Bank Banca Monte dei Paschi di Siena SpA EURO1 Participant Banca Antonveneta EURO1 Sub-Participant Biverbanca - Cassa di Risparmio di Biella e Vercelli SpA EURO1 Sub-Participant Monte dei Paschi di Siena Leasing & Factoring EURO1 Sub-Participant Banca Nazionale del Lavoro S.p.A. EURO1 Participant STEP1 Bank Banca Popolare dell'Alto Adige STEP1 Bank Banca Popolare dell'Emilia Romagna STEP1 Bank Banca Popolare di Milano S.C.A.R.L. EURO1 Participant Banca di Legnano SpA EURO1 Sub-Participant Banca Popolare di Mantova EURO1 Sub-Participant WeBank S.p.A. EURO1 Sub-Participant Banca Popolare di Sondrio STEP1 Bank Banca Popolare di Spoleto S.p.A. STEP1 Bank Banca Popolare di Vicenza SCPARL STEP1 Bank Banca Nuova SpA STEP1 Sub-Participant Banca Sella SpA STEP1 Bank Banco Bilbao Vizcaya Argentaria S.A. EURO1 Participant

46 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board Banco BPI S.A. STEP1 Bank Banco CAM S.A.U. STEP1 Bank Banco Comercial Português SA EURO1 Participant Banco Cooperativo Español SA STEP1 Bank Banco de Sabadell S.A. EURO1 Participant Banco Guipuzcoano STEP1 Sub-Participant Banco Español de Credito EURO1 Participant Banco Espirito Santo SA EURO1 Participant Banco Pastor SA STEP1 Bank Banco Popolare S.C. EURO1 Participant Credito Bergamasco EURO1 Sub-Participant Banco Popular Español SA EURO1 Participant Banco Popular Portugal, S.A. EURO1 Sub-Participant S.A. EURO1 Participant Banco Santander Totta S.A. EURO1 Sub-Participant Santander UK Plc EURO1 Sub-Participant Bank BPH S.A. STEP1 Bank Bank für Tirol und Vorarlberg AG STEP1 Bank Bank of Åland PLC STEP1 Bank Bank of America NA EURO1 Participant Public Company Ltd STEP1 Bank Bank of Cyprus (Greece) STEP1 Sub-Participant EURO1 Participant Bank of Tokyo-Mitsubishi UFJ Ltd EURO1 Participant Bankia S.A. EURO1 Participant S.A. STEP1 Bank Banque et Caisse d'Epargne de l'Etat, Luxembourg EURO1 Participant Banque Internationale à Luxembourg EURO1 Participant Banque Michel Inchauspé (BAMI) STEP1 Bank Banque Palatine STEP1 Bank STEP1 Bank Barclays Bank PLC EURO1 Participant BHF-Bank STEP1 Bank BKS Bank AG STEP1 Bank BNP Paribas SA EURO1 Participant

47 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board BPCE EURO1 Participant BRED Banque Populaire EURO1 Participant Bremer Landesbank STEP1 Bank Caixa Central de Crédito Agrícola Mútuo STEP1 Bank Caixa Geral de Depósitos EURO1 Participant CaixaBank S.A. EURO1 Participant Caja Laboral Popular Coop. de Credito STEP1 Bank Carilo - Cassa di Risparmio di Loreto STEP1 Bank Cassa di Risparmio della Provincia di Chieti STEP1 Bank Cassa di Risparmio di Cesena S.p.A. STEP1 Bank Cassa di Risparmio di Fermo S.p.A. STEP1 Bank Cassa di Risparmio di Ferrara SpA STEP1 Bank Cassa di Risparmio di Ravenna S.p.A STEP1 Bank Catalunya Banc, S.A. STEP1 Bank NA EURO1 Participant Commerzbank AG EURO1 Participant Commerzbank AG (formerly Dresdner Bank AG) EURO1 Sub-Participant Confederación Española de Cajas de Ahorros STEP1 Bank Banca Cívica, S.A. STEP1 Sub-Participant Banco de Castilla - La Mancha SA STEP1 Sub-Participant Banco Grupo Cajatrés, S.A. STEP1 Sub-Participant Banco Mare Nostrum, S.A. STEP1 Sub-Participant BBK Bank Cajasur, S.A. STEP1 Sub-Participant Caixa d'Estalvis del Penedès STEP1 Sub-Participant Caixa d'Estalvis Laietana STEP1 Sub-Participant Caja de Ahorros de Asturias STEP1 Sub-Participant Caja de Ahorros de la Inmaculada de Aragón STEP1 Sub-Participant Caja de Ahorros de la Rioja STEP1 Sub-Participant Caja de Ahorros de Murcia STEP1 Sub-Participant Caja de Ahorros de Santander y Cantabria STEP1 Sub-Participant Caja de Ahorros de Vitoria y Alava (Caja Vital) STEP1 Sub-Participant Caja de Ahorros Municipal de Burgos STEP1 Sub-Participant

48 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board Caja de Ahorros y Monte de Piedad de Extremadura STEP1 Sub-Participant Caja de Ahorros y Monte de Piedad de las Baleares STEP1 Sub-Participant Caja de Ahorros y Monte de Piedad de Navarra STEP1 Sub-Participant Caja de Ahorros y Monte de Piedad de Ontinyent STEP1 Sub-Participant Caja de Ahorros y Monte de Piedad de Segovia STEP1 Sub-Participant Caja de Ahorros y Monte de Piedad del Circulo Catolico de Obreros de Burgos STEP1 Sub-Participant Caja España de Inversiones Salamanca y Soria, CAMP - Caja Espiga STEP1 Sub-Participant Caja General de Ahorros de Canarias STEP1 Sub-Participant Caja General de Ahorros de Granada STEP1 Sub-Participant Caja Insular de Ahorros de Canarias STEP1 Sub-Participant CajaSol STEP1 Sub-Participant Colonya Caixa Pollença STEP1 Sub-Participant Monte de Piedad y Caja General de Ahorros de Badajoz STEP1 Sub-Participant Unicaja (MP y CA de Ronda, Cádiz, Almería, Málaga, Antequera y Jaén) STEP1 Sub-Participant Unnim - Caixa d'Estalvis Unió de Caixes de Manlleu, Sabadell i Terrassa STEP1 Sub-Participant Crédit Agricole S.A. EURO1 Participant Banca Popolare Friuladria SpA EURO1 Sub-Participant CA-CIB - Crédit Agricole Corporate and Investment Bank EURO1 Sub-Participant Cassa di Risparmio della Spezia S.p.A. EURO1 Sub-Participant Cassa di Risparmio di Parma e Piacenza SpA EURO1 Sub-Participant Crédit Lyonnais (LCL) EURO1 Sub-Participant Emporiki Bank of Greece S.A. EURO1 Sub-Participant

49 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board Crédit Coopératif STEP1 Bank Crédit du Nord EURO1 Participant Crédit Mutuel - CIC Banques EURO1 Participant Crédit Industriel et Commercial EURO1 Sub-Participant Crédit Mutuel Arkéa STEP1 Bank SpA STEP1 Bank Credito Valtellinese S.C. STEP1 Bank Cassa di Risparmio di Fano SpA STEP1 Sub-Participant Credito Artigiano SpA STEP1 Sub-Participant Credito Siciliano SpA STEP1 Sub-Participant Danske Andelskassers Bank A/S STEP1 Bank A/S EURO1 Participant Deutsche Bank AG EURO1 Participant Deutsche Bank Privat- und Geschäftskunden AG EURO1 Sub-Participant DIBA Bank A/S STEP1 Bank Djurslands Bank A/S STEP1 Bank DNB Bank ASA, London Branch EURO1 Participant DNB Bank ASA, Filial Finland EURO1 Sub-Participant DZ BANK AG EURO1 Participant EFG S.A. EURO1 Participant Bank AG EURO1 Participant Europe Arab Bank plc STEP1 Bank Europe Arab Bank PLC - Austria Branch STEP1 Sub-Participant Europe Arab Bank PLC - France Branch STEP1 Sub-Participant Europe Arab Bank PLC - Rome Branch STEP1 Sub-Participant Europe Arab Bank PLC - Sucursal en España STEP1 Sub-Participant Europe Arab Bank PLC - UK Branch STEP1 Sub-Participant Fortis Bank SA/NV EURO1 Participant BGL BNP Paribas EURO1 Sub-Participant Hamburger Sparkasse AG STEP1 Bank Public Company Ltd STEP1 Bank Hellenic Bank Greece STEP1 Sub-Participant HSBC Bank Plc EURO1 Participant HSBC France EURO1 Participant

50 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board ICCREA Banca - Istituto Centrale del Credito Coop. STEP1 Bank ING Bank NV EURO1 Participant Bank Mendes Gans N.V. EURO1 Sub-Participant ING Bank Slaski EURO1 Sub-Participant ING Belgium NV/SA EURO1 Sub-Participant ING Belgium S.A., Succursale en France EURO1 Sub-Participant ING Luxembourg SA EURO1 Sub-Participant Intesa Sanpaolo SpA EURO1 Participant Banca Intesa France EURO1 Sub-Participant Société Européenne de Banque S.A. EURO1 Sub-Participant Ipar Kutxa Rural SCC STEP1 Bank Istituto Centrale delle Banche Popolari Italiane STEP1 Bank J.P. Morgan AG EURO1 Participant J.P. Morgan Bank (Ireland) PLC EURO1 Sub-Participant Joh. Berenberg, Gossler und Co. KG STEP1 Bank AS STEP1 Bank KBC Bank N.V. EURO1 Participant KBL European Private Bankers S.A. EURO1 Participant Kookmin Bank International Ltd. STEP1 Bank Kutxabank S.A. (form. Bilbao Bizkaia Kutxa) STEP1 Bank Kutxabank S.A. (form. Caja Gipuzkoa San Sebastian - Kutxa) STEP1 Bank STEP1 Bank Landesbank Baden-Württemberg EURO1 Participant Landesbank Berlin AG STEP1 Bank Landesbank Hessen Thueringen () EURO1 Participant Lloyds TSB Bank Plc EURO1 Participant Marfin Popular Bank Public Co Ltd STEP1 Bank Bank PSC STEP1 Bank EURO1 Participant EURO1 Participant NCG Banco S.A. STEP1 Bank Nordea Bank Finland Plc EURO1 Participant Nordea Bank A/S EURO1 Sub-Participant Nordea Bank Norge Asa EURO1 Sub-Participant

51 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board Nordea Bank AB (Publ) EURO1 Sub-Participant Nordjyske Bank A/S STEP1 Bank Nørresundby Bank A/S STEP1 Bank Oberbank AG STEP1 Bank Oldenburgische Landesbank AG STEP1 Bank Østjydsk Bank A/S STEP1 Bank OTP Bank Plc. EURO1 Participant Pohjola Pankki OYJ EURO1 Participant Pohjola Bank Plc, Estonian branch EURO1 Sub-Participant Pohjola Bank Plc., Latvian branch EURO1 Sub-Participant Nederland EURO1 Participant Raiffeisen Bank International AG EURO1 Participant Raiffeisenlandesbank Oberösterreich AG STEP1 Bank Raiffeisen-Landesbank Tirol AG STEP1 Bank Ringkjøbing Landbobank A/S STEP1 Bank Royal Bank of Scotland Plc EURO1 Participant National Westminster Bank Plc EURO1 Sub-Participant The Royal Bank of Scotland N.V. EURO1 Sub-Participant S-Bank Ltd STEP1 Bank SECB Swiss Euro Clearing Bank GmbH STEP1 Bank Skandinaviska Enskilda Banken EURO1 Participant AS SEB Pank EURO1 Sub-Participant SEB AG EURO1 Sub-Participant SEB Banka EURO1 Sub-Participant SEB Private Banking EURO1 Sub-Participant Skjern Bank STEP1 Bank Société Générale EURO1 Participant Bank STEP1 Bank Sparekassen Sjælland STEP1 Bank Standard Chartered Bank EURO1 Participant Standard Chartered Bank Germany Branch EURO1 Sub-Participant Steiermärkische Bank und Sparkassen AG STEP1 Bank Svenska EURO1 Participant Swedbank AB (publ) EURO1 Participant Swedbank AB, Lithuania EURO1 Sub-Participant Swedbank AS, Estonia EURO1 Sub-Participant

52 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board Swedbank AS, Latvia EURO1 Sub-Participant Sydbank A/S STEP1 Bank Tapiola Pankki Oy STEP1 Bank Tercas - Cassa di Risp. della Prov. di Teramo SpA STEP1 Bank Banca Caripe STEP1 Sub-Participant The Bank of New York Mellon, Frankfurt Branch STEP1 Bank UBI Banca (Unione di Banche Italiane) S.C.P.A STEP1 Bank UBS AG EURO1 Participant Unicredit S.p.A. EURO1 Participant UniCredit Bank AG EURO1 Sub-Participant UniCredit Bank Austria AG EURO1 Sub-Participant Unipol Banca SpA STEP1 Bank Veneto Banca SCPA STEP1 Bank Vestfyns Bank A/S STEP1 Bank Vestjysk Bank STEP1 Bank VTB Bank (Deutschland) AG STEP1 Bank Bank NA EURO1 Participant WestLB AG EURO1 Participant

53 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board APPENDIX 3

List of Direct STEP2 Participants (as of 14 th May 2012)

STEP2 SCT

ABN AMRO BANK NV AKTIA BANK PLC ALLIED IRISH BANKS PLC ALPHA BANK ARBEJDERNES LANDSBANK AS SEB PANK BANCA D’ITALIA BANCA MONTE DEI PASCHI DI SIENA BANCA POPOLARE DELL EMILIA ROMAGNA BANCA POPOLARE DI SONDRIO SCPA BANCA POPOLARE FRIULADRIA BANCA SELLA HOLDING SPA BANCO BILBAO VIZCAYA ARGENTARIA SA BANCO BPI SA BANCO COMERCIAL PORTUGUES SA BANCO DE ESPANA BANCO DE SABADELL SA BANCO ESPANOL DE CREDITO BANCO ESPIRITO SANTO SA BANCO PASTOR SA BANCO POPOLARE SOCIETA COOPERATIVA BANCO POPULAR ESPANOL BANCO SANTANDER SA BANCO SANTANDER TOTTA SA BANK OF ALAND PLC BANK OF AMERICA FRANKFURT BANK OF GREECE S.A. BANKA SLOVENIJE BANKIA S.A. BANKINTER SA BANQUE DE FRANCE BANQUE DE LUXEMBOURG BANQUE ET CAISSE D’EPARGNE DE L’ETAT, LUXEMBOURG

54 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board BANQUE INTERNATIONALE A LUXEMBOURG BARCLAYS BANK PLC BGL BNP PARIBAS BNP PARIBAS IRELAND BNP PARIBAS SA BPCE BPOST BRED BANQUE POPULAIRE CAIXA CENTRAL DE CREDITO AGRICOLA MUTUO CAIXA GERAL DE DEPOSITOS CAIXABANK SA CASSA CENTRALE BANCA – CREDITO COOPERATIVO CASSA DEPOSITI E PRESTITI SPA CASSA DI RISPARMIO DELLA SPEZIA SPA CASSA DI RISPARMIO DI PARMA E PIACENZA SPA CITIBANK NA LONDON COMMERZBANK AG CONFEDERACION ESPANOLA DE CAJAS DE AHORROS CREDIT AGRICOLE SA CREDIT MUTUEL ARKEA CREDIT MUTUEL - CIC BANQUES CREDIT SUISSE CREDITO EMILIANO SPA DANSKE BANK DANSKE BANK INTERNATIONAL S.A., LUXEMBOURG DE NEDERLANDSCHE BANK NV DEUTSCHE BANK AG DEUTSCHE BUNDESBANK AG DEXIA BANK BELGIUM NV/SA DNB BANK ASA DZ BANK AG EFG EUROBANK ERGASIAS FORTIS BANK SA/NV HSBC BANK PLC ICCREA BANCA

55 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board ING BANK NV ING BELGIUM NV/SA ING LUXEMBOURG SA ISTITUTO CENTRALE DELLE BANCHE POPOLARI ITALIANE INTESA SANPAOLO SPA ITELLA PANKKI OY JP MORGAN AG JYSKE BANK AS KBC BANK NV LA BANQUE POSTALE LAN & SPAR BANK AS LANDESBANK HESSEN THUERINGEN LBBW LANDESBANK BADEN WUERTTEMBERG LLOYD TSB BANK PLC NARODOWY BANK POLSKI NATIONAL BANK OF GREECE SA NATIONAL WESTMINSTER BANK PLC NATIXIS NORDEA BANK FINLAND PLC OESTERREICHISCHE NATIONALBANK OTP BANK PLC POHJOLA PANKKI OYJ RABOBANK NEDERLAND RAIFFEISEN BANK INTERNATIONAL AG RAIFFEISEN LANDESBANK SÜDTIROL AG S-BANK LTD SAMPO BANK PLC SECB SWISS EURO CLEARING BANK SKANDINAVISKA ENSKILDA BANKEN SOCIETE GENERALE SOCIETE GENERALE BANK AND TRUST SA SPAR NORD BANK AS SPAREKASSEN KRONJYLLAND STANDARD CHARTERED BANK GERMANY BRANCH SVENSKA HANDELSBANKEN SWEDBANK AB (PUBL)

56 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board SYDBANK LTD THE ROYAL BANK OF SCOTLAND NV THE ROYAL BANK OF SCOTLAND PLC UBI BANCA INTERNATIONAL UBI BANCA SCPA UBS AG ZURICH UNICREDIT BANK AG HYPOVEREINSBANK UNICREDIT BANK AUSTRIA AG UNICREDIT SPA WESTLB AG

STEP2 SDD CORE

ABN AMRO BANK NV AKTIA BANK PLC ALLIED IRISH BANKS PLC BANCA CARIGE S.P.A BANCA D’ITALIA BANCA DELLE MARCHE SPA BANCA GENERALI SPA BANCA MONTE DEI PASCHI DI SIENA SPA BANCA POPOLARE DELL’EMILIA ROMAGNA BANCA POPOLARE DI SONDRIO SCPA BANCO BILBAO VIZCAYA ARGENTARIA S.A. BANCO BPI SA BANCO COMERCIAL PORTUGUES SA BANCO DE ESPANA BANCO DE SABADELL SA BANCO ESPANOL DE CREDITO BANCO ESPIRITO SANTO SA BANCO PASTOR S.A. BANCO POPOLARE S.C. BANCO POPULAR ESPANOL BANCO SANTANDER S.A.

57 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board BANCO SANTANDER TOTTA SA BANK OF AMERICA NA FRANKFURT BANK OF GREECE S.A. BANKA SLOVENIJE BANKIA SA BANQUE DE FRANCE BANQUE ET CAISSE D’EPARGNE DE L’ETAT, LUXEMBOURG BANQUE INTERNATIONALE A LUXEMBOURG BGL BNP PARIBAS BNP PARIBAS SA BPCE BPOST BRED BANQUE POPULAIRE CAIXA CENTRAL DE CREDITO AGRICOLA MUTUO CAIXA GERAL DE DEPOSITOS CAIXABANK S.A. CASSA CENTRALE BANCA – CREDITO COOPERATIVO CASSA DI RISPARMIO DI PARMA E PIACENZA SPA CITIBANK NA LONDON COMMERZBANK AG CONFEDERACION ESPANOLA DE CAJAS DE AHORROS CREDIT AGRICOLE SA CREDIT MUTUEL - CIC BANQUES (BFCM) CREDIT MUTUEL ARKEA CREDITO EMILIANO S.P.A. DANSKE BANK AS DE NEDERLANDSCHE BANK NV DEUTSCHE BANK AG DEUTSCHE BUNDESBANK DEUTSCHE POSTBANK AG DEXIA BANK BELGIUM NV/SA DZ BANK AG FORTIS BANK SA/NV HSBC BANK PLC ICBPI SPA

58 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board ING BELGIUM NV/SA INTESA SANPAOLO SPA J.P. MORGAN AG KBC BANK NV LA BANQUE POSTALE LANDESBANK BADEN-WUERTTEMBERG LANDESBANK HESSEN-THUERINGEN LLOYDS TSB BANK PLC NATIXIS NORDEA BANK FINLAND PLC OESTERREICHISCHE NATIONALBANK POHJOLA PANKKI OYJ RABOBANK NEDERLAND RAIFFEISEN BANK INTERNATIONAL AG RAIFFEISEN LANDESBANK SUEDTIROL AG S-BANK LTD SECB SWISS EURO CLEARING BANK SKANDINAVISKA ENSKILDA BANKEN AB SOCIETE GENERALE STANDARD CHARTERED BANK GERMANY BRANCH SVENSKA HANDELSBANKEN THE ROYAL BANK OF SCOTLAND NV UBI BANCA SCPA UBI BANCA INTERNATIONAL SA UNICREDIT BANK AG - HYPOVEREINSBANK UNICREDIT BANK AUSTRIA AG UNICREDIT S.P.A. WESTLB AG

59 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board STEP2 SDD B2B

ABN AMRO BANK NV BANCA CARIGE S.P.A. BANCA D’ITALIA BANCA DELLE MARCHE SPA BANCA GENERALI SPA BANCA MONTE DEI PASCHI DI SIENA SPA BANCA POPOLARE DELL’EMILIA ROMAGNA BANCA POPOLARE DI SONDRIO SCPA BANCO BILBAO VIZCAYA ARGENTARIA S.A. BANCO BPI S.A. BANCO COMERCIAL PORTUGUES SA BANCO DE ESPANA BANCO DE SABADELL SA BANCO ESPANOL DE CREDITO BANCO ESPIRITO SANTO SA BANCO POPOLARE S.C. BANCO POPULAR ESPANOL BANCO SANTANDER S.A. BANCO SANTANDER TOTTA SA BANK OF AMERICA NA FRANKFURT BANK OF GREECE S.A. BANKA SLOVENIJE BANKIA SA BANQUE ET CAISSE D’EPARGNE DE L’ETAT, LUXEMBOURG BANQUE INTERNATIONALE A LUXEMBOURG BGL BNP PARIBAS BNP PARIBAS SA BRED BANQUE POPULAIRE CAIXA CENTRAL DE CREDITO AGRICOLA MUTUO CAIXA GERAL DE DEPOSITOS CAIXABANK S.A. CASSA CENTRALE BANCA – CREDITO COOPERATIVO CASSA DI RISPARMIO DI PARMA E PIACENZA SPA CITIBANK NA LONDON COMMERZBANK AG

60 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board CONFEDERACION ESPANOLA DE CAJAS DE AHORROS CREDIT MUTUEL - CIC BANQUES CREDITO EMILIANO S.P.A. DANMARKS NATIONALBANK DANSKE BANK AS DE NEDERLANDSCHE BANK NV DEUTSCHE BANK AG DEUTSCHE BUNDESBANK DEUTSCHE POSTBANK AG DEXIA BANK BELGIUM NV/SA DZ BANK AG FORTIS BANK SA/NV ICBPI SPA ING BELGIUM NV/SA INTESA SANPAOLO SPA J.P. MORGAN AG KBC BANK NV LANDESBANK BADEN-WUERTTEMBERG LANDESBANK HESSEN-THUERINGEN LLOYDS TSB BANK PLC NATIXIS NORDEA BANK FINLAND PLC OESTERREICHISCHE NATIONALBANK RABOBANK NEDERLAND RAIFFEISEN BANK INTERNATIONAL AG RAIFFEISEN LANDESBANK SUEDTIROL AG SECB SWISS EURO CLEARING BANK GMBH SKANDINAVISKA ENSKILDA BANKEN SOCIETE GENERALE SVENSKA HANDELSBANKEN THE ROYAL BANK OF SCOTLAND NV UBI BANCA SCPA UBI BANCA INTERNATIONAL SA UNICREDIT BANK AG - HYPOVEREINSBANK UNICREDIT BANK AUSTRIA AG UNICREDIT S.P.A. WESTLB AG

61 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board STEP2 ICT

BANCA MONTE DEI PASCHI DI SIENA S.P.A BANCA NAZIONALE DEL LAVORO S.P.A. BANCO POPOLARE SOCIETA COOPERATIVA INTESA SANPAOLO SPA MONTE DEI PASCHI DI SIENA LEASING & FACTORING UNICREDIT SPA

STEP2 IET

ALLIED IRISH BANKS BANK OF IRELAND BNP PARIBAS IRELAND IRISH LIFE & PERMANENT PLC T/A PERMANENT TSB NATIONAL IRISH BANK ULSTER BANK IRELAND LTD.

62 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board APPENDIX 4

Accounts as of 31 st December 2011

The annual accounts for 20 11 (and for 2010) are attached separately.

63 EBA CLEARING Shareholders Meeting 14 th May 2012 // Report of the Board Contact details

For any additional information, please contact:

Daniel Szmukler Director [email protected]

ABE CLEARING S.A.S. à capital variable (EBA CLEARING) 40 rue de Courcelles F - 75008 Paris RCS Paris B 419 020 193 No. TVA: FR 524 19020193