The Internal Capital Adequacy Assessment Process (ICAAP) under Basel II

Current Developments, Challenges and Potential Solutions

The ICAAP under Basel II Ernst & Young 2009

Table of Contents

1. 2. 3. 4.

Current Developments Philosophy and Structure of Pillar II and the ICAAP Relevant Questions and Need for Action Ernst & Youngs Flexible ICAAP Framework

4 5 9 10

Editorial

The developments and tremendous losses witnessed over the last 1824 months in the banking and financial markets have shocked bankers, politicians, people on the street and regulators alike. People, with due reason, are starting to ask: Why have financial regulation and the praised Basel II framework not been able to prevent this meltdown? Were the skeptics about Basel II right when they said that minimum capital requirements are an inadequate measure to control and manage risk? How will and must financial regulation evolve in order to prevent these mistakes happening in the future? Skeptics have already started digging the grave of Basel II and heralding its replacement with Basel 2.5 or Basel 3. Regulatory Trends Throughout many jurisdictions, we have observed regulators leaning toward more stringent capital requirements and closer observation of the regulated banks. In general, developments seem to be moving in the direction of the Second Pillar within the Basel II framework, whereby capital requirements are no longer fully based on the generic Pillar I calculations but more strongly influenced by the more differentiated requirements of the Internal Capital Adequacy Assessment Process (ICAAP), which gives more weight to the economic risk profile of the regulated financial institutions.

Economic Value Simultaneously, equity capital has become more and more scarce, making this strategic resource even more crucial. Hence, in order to support current and future growth ambitions, banks are evaluating the availability and allocation of equity capital more than ever before. In the current environment of economic stress, the consolidation underway in certain market segments may offer short-term business opportunities. In order to ensure the necessary funding to take advantage of any strategic opportunities that may arise, sufficient equity cushions need to be available. Additionally, approximating the capital requirements of a bank based on its economic risk profile allows the banks management to strike a better balance between the sometimes differing views of regulators, investors and the banks internal strategic business plans. Purpose of this Brochure The purpose of this brochure is to provide an overview of national and international developments and challenges related to Pillar II and the ICAAP. Furthermore, an outline is given of possible methods of addressing these challenges and the additional added value for financial institutions beyond regulatory compliance. For financial institutions who have not yet addressed the potential consequences or impacts of the ICAAP, this brochure may help in the establishment of a first overview and the initiation of further activities.

Bruno Oppliger Partner

Daniel Martin Senior Manager

The ICAAP under Basel II Ernst & Young 2009

1. Current Developments
The downturn environment is placing considerable strain on the capital positions of firms subject to Basel II requirements. The capital base is at threat from falling income, mark-tomarket losses and rising defaults. Fresh capital is potentially difficult to raise and expensive to service. The current developments on the financial markets have emphasized the necessity for more stringent supervision of banks and their risk management activities. Alongside this, regulators are asking firms to perform increasingly robust stress testing in order to assess the range of scenarios that may hit. The complexity of such stress tests is compounded by the fact that, under Basel II, capital requirements for many firms could rise substantially during the downturn. Regulators are challenging firms to increasingly involve senior management in developing and reviewing stress testing and to embed this within the day-to-day running of the business. Moreover, supranational institutions like the OECD have announced methods to increase regulation and supervision of the global financial system, while discussion papers released by the BIS emphasize the extension of Basel II and, particularly, its Second Pillar. The stress testing exercises and Pillar II review activities currently being performed by the FINMA in Switzerland are further examples of such increased supervision. Overall, it can be said that the Second Pillar of Basel II (regulatory supervision with assessment of bank-internal capital adequacy) is receiving increasing attention. Pillar II and the ICAAP, unlike the First Pillar, are principlebased guidelines, and national regulators first had to incorporate these principles into national regulations and allow market standards to develop. This development has now taken place, and many regulators have already integrated reasonably sophisticated ICAAP directives into their supervised institutions. Initial reports are presently being reviewed by regulators. As opposed to the First Pillar (the minimum capital requirements), the Second Pillar does not differentiate between standardized and IRB banks. Rather, regulators are asking banks to strengthen the link between an institutions risk profile, its risk management and risk mitigation systems, and its capital. As such, the intensity and depth of the Pillar II review is proportionate to the nature, scale, complexity and systemic importance of the institution (its economic risk profile). Unlike our neighboring countries, so far Switzerland has not introduced any concrete ICAAP directives. Nevertheless, based on the aforementioned developments and the stress testing and review activities currently being performed by the FINMA in the Swiss market, it can be anticipated that more stringent requirements may follow and, eventually, that capital requirement levels may rise.

Core Messages

Pillar II and its ICAAP have been developed from a principle-based section of the original Basel II paper to a widely accepted market standard. The ICAAP directives currently applied have reached a reasonable level of sophistication and are generally seen as a valuable enhancement to the Pillar I minimum capital requirements. Differentiation between standardized and IRB banks is generally irrelevant in the ICAAP, and regulators focus on the economic risk profile of supervised banks. Switzerland has so far not introduced any concrete ICAAP directives, but the FINMA recently asked larger and complex Swiss banks to conduct stress testing within their institutions based on given indicators and scenarios. The results and possible actions have not been published at this point in time. Regulatory actions such as stress testing and Pillar II reviews may lead to increased capital requirements.

The ICAAP under Basel II Ernst & Young 2009

The two sides of Pillar IIII The two sides of Pillar

ICAAP and SREP ICAAP and SREP

2. Philosophy and Structure of Pillar II and the ICAAP

Philosophy of Pillar II vis--vis Pillar I
From a preliminary standpoint, the events of the recent past seem to support the critical voices that regard Basel II as inadequate, since even the equity buffers of relatively highly capitalized banks have not been sufficient to compensate for the losses incurred following the severe market dislocations. However, discussions about the effectiveness of Basel II often focus on the capital requirement calculated under the First Pillar of the framework and fail to consider the Second Pillar. The Second Pillar not only goes beyond this mere minimum requirement to encompass other risk types previously not addressed in the First Pillar, but also comprises calculationJuli 20092009 7. 7. Juli and estimation techniques not discussed in the First Pillar, or only discussed to a limited extent. The figure below outlines how the First and Second Pillars aim to provide comprehensive coverage for the relevant risk types under varying severities of the anticipated economic environment.

Basel II II Pillar II II Basel Pillar

Basel II Pillar II

Bank Side Bank Side

Supervisory Side Supervisory Side

ICAAP ICAAP
(Internal Capital Adequacy (Internal Capital Adequacy Assessment Process) Assessment Process)

SREP SREP
(Supervisory Review Evaluation (Supervisory Review Evaluation Process) Process)

Intended to be be proportional to Intended to proportional to the complexity and risk the complexity and risk exposure exposure

Intended to be be proportional to Intended to proportional to the overall risk situation of of the overall risk situation financial institutions financial institutions

Subsequently, the ICAAP Subsequently, the ICAAP side will bebe focused side will focused

Structure of Pillar II
When considering the second Pillar and its influence on regulated institutions, a distinction needs to be made between its two mayor components: the ICAAP (Internal Capital Adequacy Assessment Process) and the SREP (Supervisory Review Evaluation Process).

The SREP is reserved for the regulator, defines said instituPage 8 8 Page Pillar II ICAAP Pillar II / ICAAP tions regulatory/ review activities, and may take rather different forms depending on the jurisdiction and, as such, has limited influence on banks risk management activities. The ICAAP, on the other hand, carries great importance for banks since it assesses their capital adequacy levels based on their indigenous complexity and risk exposures. Hence, the ICAAP is usually described as a process owned by the bank and reviewed by the regulator as part of the SREP. As a result, banks usually focus on the ICAAP side in their implementation of Pillar II solutions. Consequently, section 4 will introduce Ernst & Youngs comprehensive yet flexible framework as to how banks may address the challenges posed by the ICAAP.

Philosophy of Basel II and its first two Pillars

The philosophy of Basel II is that banks have to be adequately capitalized even under severe stress conditions given their conduct of business and the specific risk types they are exposed to.
Coverage of Risk Types

Coverage of risk types

Credit Risk Market Risk Operational Risk Concentration Risk Interest Rate in Banking Book Liquidity & Country Funding Risk Risk Residual Risks Reputation Non-conclusive Risks selection of risk types

Severity of Economic Environment

Pillar I
Minimum Requirements for Credit, Market and Operational Risks only

Pillar II

The Committee also wishes to highlight the need for banks and supervisors to give appropriate consideration to the Second Pillar. It is critical that the minimum capital requirements of the First Pillar are accompanied by a robust implementation of the Second Pillar, including efforts by banks to assess their capital adequacy and by supervisors to review such assessments. (Quote from Basel II Core Text)

Pillar I is only the first step on a journey in realizing the aims of Basel II.
7. Juli 2009 Page 6 Pillar II / ICAAP
The ICAAP under Basel II Ernst & Young 2009 5

Differentiation between standardized and IRB banks is generally irrelevant in the ICAAP, and regulators focus on the economic risk profile of supervised banks.

The ICAAP under Basel II Ernst & Young 2009

Outcome of the ICAAP Reviews

Regulators use the outcome of ICAAP reviews to establish the level of capital requirements and, to the extent necessary, of additional supervisory actions. The figure below provides a graphical overview of the potential composition of a banks total capital requirement: From a general perspective, the basis is still the calculation of the Pillar I minimum capital requirements for credit, market and operational risks. Afterwards, the Pillar II target levels are established based on the banks risk profile and the quality of its ICAAP implementation. If a regulator is particularly dissatisfied with an ICAAP solution or diagnoses incomplete implementation or other serious flaws, add-ons may even be imposed. However, regulators may also decide to grant reductions in capital requirements in light of highly sophisticated ICAAP solutions.

One such specific example is explained below:

One of the great challenges of modern-day bank management is assessing a banks true economic risk profile, its alignment with board oversight duties, management actions and risk management activities, and coherent communication to key stakeholders such as owners and investors, regulators, bank personnel or business partners, as illustrated in the following figure. The present financial crisis has illustrated how institutions that neglected this aspect have suffered not only in terms of their share prices, but even more importantly also in their daily business activities by losing future earnings through the erosion of client bases and the loss of funding and liquidity sources. From an economic perspective, the ICAAP greatly supports banks governing bodies in conducting a thorough analysis of banks economic risk profiles, assessing the influence of economic stress situations, and helping prepare for such stress situations. Based on this assessment, banks are much better prepared to weather future storms and to communicate a coherent business and risk profile that will not disappoint the market and other outside parties.

Economic Added Value

Notwithstanding the above, pure regulatory developments and regulatory compliance should not be the only motivator for adopting a sound ICAAP solution.

Pillar II / ICCAP Value Added

Capital Requirement

At the Core of Present Challenges

Economic Added Value A coherent business and risk profile

One of the core challenges of modern bank management is the alignment of the banks risk profile with the expectations of the banks owners, business partners and the regulatory body.

Board Oversight and Managements Actions Board Oversight and Managements Actions Investors & Owner Investors & Owner

Banks Risk Profile Banks Risk Profile

CommunicaCommunication tion

Alignment Alignment

Regulators Regulators

Business Partners Business Partners Risk Management Risk Management

Pillar II supports every one of these aspects significantly

7. Juli 2009

Page 1

Pillar II / ICAAP

The ICAAP under Basel II Ernst & Young 2009

Regulators use the outcome of ICAAP reviews to establish the level of capital requirements and, to the extent necessary, of additional supervisory actions.

The ICAAP under Basel II Ernst & Young 2009

3. Relevant Questions and Need for Action

Given the aforementioned developments, banks need to address a variety of questions and consider the strategic impact these decisions may have. Based on the results and insights gained when addressing the aforementioned questions, banks should consider the following actions.

Typical questions encountered are:

How will the banks capital base impact the banks reputation and how will this, in turn, affect the banks regular business activities as well as its funding and client base? How will the banks risk management influence its strategic position in the market? What is our banks real risk strategy and risk appetite and how does this correspond with its risk capacity? How would an ICAAP solution have to be structured in order to create maximum economic benefit? How is our risk management positioned at the moment and how much investment would be required to achieve a wellsuited ICAAP solution? What would happen if we adhered only to minimum standards, or do we want to position ourselves as a subject leader (toward the regulator and investors)? How will we involve the Board of Directors and what communication strategy do we need to establish with the regulator and other outside parties? Are we trying to achieve economic benefit or do we see it only as a regulatory compliance exercise in the aim of minimizing the operational burden? How diligently is our Pillar I capital calculated? Are we using overly conservative assumptions due to a lack of data and are currently faced with higher Pillar I capital levels than we actually need? Are the available capital resources sufficient to support future business strategies, such as growth ambitions, even in times of economic stress? What amount of strategic flexibility is required in order to make use of market opportunities? Does the bank know the expectations of the local regulator for additional capital (SREP)?

Need for Action:

Creating awareness throughout the Executive Management and the Board of Directors, since the ICAAP will involve both governing bodies to a significant degree Establishing a communication strategy, including both external and internal parties as well as the national regulator Allocating ownership, whereby the project should receive significant attention from the Executive Management (often, either the CRO or CFO assumes responsibility for the ICAAP) Establishing a small and effective first phase project team capable of managing the initial analyses as well as defining and initiating the subsequently fully established ICAAP project Ensuring that the Board of Directors clearly articulates the banks risk capacity and risk appetite as the guiding principle behind future solutions Conducting internal analysis as to which ICAAP target framework most ideally suits the banks business model, and deciding on the future state of the ICAAP target framework Conducting a gap analysis of the banks present business conduct vis--vis a good practice Pillar II framework (most ideally, the future ICAAP target framework already chosen by the bank) Defining the most ideal avenue in the pursuit of a suitable ICAAP framework Enhancing presently applied stress testing approaches toward a well-defined top-down oriented Pillar II stress testing framework Establishing a base case 35 capital plan representing the current best estimate for the future capital needs based on quantifiable growth ambitions and business plans Transforming the Pillar II stress testing results into a 35 year risk-adjusted capital plan, providing the decision basis for potentially necessary mitigation plans Maintaining an ongoing dialogue with the regulator and keeping the regulator well informed on the progress of the project Estimating the possible extent of incremental capital on the basis of Basel II/Pillar I Both banks and regulators need to appreciate that the definition and implementation of a well-defined ICAAP Solution is a multi-year process. Experience has shown that the enhancement of current solutions will take place in an iterative process of solution development, validation and enhancement. As such, it is imperative that banks start with their current solutions and enhance these over time. Pragmatic shortcuts will be required in the beginning, especially in the field of group-wide Pillar II stress testing. Over time, such frequently expert-based approximations can be replaced by more rigorous analytical methods.

The ICAAP under Basel II Ernst & Young 2009

4. Ernst & Youngs Flexible ICAAP Framework

When considering the components of a suitable ICAAP framework, the reader should not get the wrong impression that everything has to be built up completely from scratch. On the contrary, to a large extent the ICAAP target solution should resemble the banks present business and risk management conduct, but may need to be enhanced or supplemented in certain areas or streamlined to bring dispersed solutions into sharper focus. Based on this, Ernst & Young has developed a flexible ICAAP framework that takes into account existing risk management activities, puts these into perspective, and allows banks to enhance and strengthen existing solutions and fill the gaps where solutions are currently missing. The major components of the framework are explained below.

Contingency and Mitigation Planning

In order to ensure that a bank remains solvent even in times of economic downturn contingency plans have to be established and then revised whenever the surrounding environment changes. ICAAP solutions implicitly expect a bank to maintain such plans, including inter alia raising new capital, disposing of certain assets, and reducing or hedging specific risk types. However, it is imperative to prove to the regulator that these plans are realistic and that the bank is willing and capable of putting them into practice.

Capital Planning
Capital planning is one of the ultimate tools for determining and maintaining an adequate level of capital. In order to be prepared for difficult economic environments, it is imperative that capital plans incorporate various potential scenarios and are made responsive to changes in the economy, market, competitive or political landscape, or other external factors. Hence, a solid combination of the finance and risk view has to be achieved.

Risk Strategy & Appetite

Clearly defining and articulating the banks risk strategy and risk appetite is the cornerstone of any ICAAP solution. The strategy clearly has to reflect the banks business preferences and conduct, and must be aligned with its risk capacity. Some banks decide to define elements such as an external target rating as part of their risk appetite. While this is certainly possible, banks have to ensure that the components defined in their risk appetite can be neatly translated into manageable operational targets.

Capital Modeling and Stress Testing

The ICAAP does not require banks to maintain economic capital and value-at-risk models that meet the highest levels of sophistication per se. On the contrary, such models are often unable to produce meaningful stress capital figures when used in isolation.1

Contents of a flexible Pillar II / ICAAP Framework

Ernst & Youngs Framework & Youngs flexible ICAAP made approach to ICAAP Ernst allows a tailor Framework

Risk Strategy & Appetite

Contingency & Mitigation Planning Capital Planning & Management Capital Model

Risk Monitoring & Management Information Senior Management Training & Controls Review Risk Concentrations Risk Controls including Limit Setting, Policies and Procedures Scenario Analysis & Stress Testing Risk Aggregation Risk Modelling Risk Dictionary
Credit Risk Country Risk Market Risk Interest Rate in Banking Book Liquidity & Funding Risk Operational Risk Insurance Risk Legal & Compliance Risk Reputation Risks Business/ Strategic Risks Tax Risks Environmental Risks Residual Risks

Communication with Regulator

Comprehensive Assessment of Risks

Page 13 Pillar II / ICAAP Proposed7. Juli 2009 enhancements to the Basel II framework; January 2009; p. 25 To provide a complementary risk perspective to other risk management tools such as Value at Risk (VaR) and economic capital, stress tests should be used to provide an independent risk perspective.

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The ICAAP under Basel II Ernst & Young 2009

Hence, banks will prefer to focus on well-defined stress testing frameworks which are tailored to their organization and their particular risk profile. Stress testing is generally seen as a vital component of the ICAAP framework. It allows the bank to estimate its loss potential under a variety of highly severe but still plausible scenarios, as well as to assess the respective impact on capital sources. One area that usually receives particular attention within stress testing is the field of concentration risk. Entity concentration techniques such as those currently applied as part of many regulatory frameworks do not suffice for Pillar II stress testing techniques and should be supplemented by more rigorous methods.

First approaches of Concentration Risk management have started with single names concentrations, which have also been reflected in most regulatory frameworks. Additionally, some regulators have started to introduce requirements regarding concentrations in economic sectors, which is in line which ICAAP requirements. This is supported by studies which have identified the field of sector concentration to be of significantly greater relevance than name concentration. Moreover, banks are increasingly starting to reflect concentrations in their portfolio of accepted collaterals due to credit risk mitigation techniques in their concentration risk measurement. Finally, as a major source of risk, concentration risk should be diligently reflected in a banks stress testing framework.

Involvement of Governing Bodies

Pillar II places particular importance on the involvement of the Board of Directors and Executive Management. The ICAAP framework and its constituting elements have to be approved by the Board of Directors, and the representatives thereof usually participate in key discussions with the regulators. Additionally, members of the governing bodies have to have a solid understanding of both risk management in general and the risk situation of their specific institution.

Comprehensive Risk Assessment

As explained above, Pillar II and the ICAAP go beyond the risk types covered under the First Pillar. Hence, a bank needs to work through the universe of risks it might be exposed to. In order to identify the risks relevant to an individual bank, a definition of materiality has to be established. Based on this definition, the identified risks can be assessed and categorized. These efforts are usually summarized in a dedicated document called the Risk Dictionary, which is one of the key elements for defining bank-wide stress scenarios.

Dialog with the Regulator

Dialog with the regulator is another key component. Establishing an ICAAP solution for the first time can easily grow into a 12-month project or longer, and the regulatory body should be kept well informed of the banks progress. Conducting a thorough assessment of an implemented ICAAP framework is also an extensive task. Involving the regulator from the beginning will thus ensure that expectations are managed adequately and that the final review will be conducted more efficiently.

Liquidity Risk
Access to sufficient liquidity is the lifeblood of each and every institution. Hence, the implementation of a robust liquidity risk management framework ensuring the continuous maintenance of sufficient liquidity and the ability to withstand a liquidity crisis are key elements of a suitable ICCAP framework. Accordingly, Senior Management is in charge of establishing liquidity risk tolerance levels as well as adequate contingency funding plans. The main focus of attention in actively managing liquidity risk should be on conducting liquidity stress tests (institution-specific as well market wide crisis scenarios) to assess the potential impact of extreme events and maintaining a liquidity buffer to raise liquidity within a short timeframe in the case that funding sources are no longer available.

Reporting
Finally, in order to keep not only governing bodies but also risk and line management adequately informed about the banks risk profile and the impact of current and anticipated market developments, a comprehensive risk reporting suite is required. As with any risk reporting, it is vital to make the information and insights responsive to key risk indicators.

Risk Concentration
The necessity for and the clear added value of diligent concentration risk management solutions has been widely recognized by regulators and practitioners alike. A study conducted by the BIS2 reveals that credit concentration risk, usually in real estate, was cited in nine out of the 13 episodes of bank failures in mature economies.

2 Bank for International Settlements; Working Paper No. 13; Bank Failures in Mature Economies; April 2008; page 66

The ICAAP under Basel II Ernst & Young 2009

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Finding the suitable service and financial instrument for each client: every financial advisors most Capital Adequacy Meeting the Requirements of the Second Pillar within the Basel II Framework important service
This brochure outlines the current developments in the field International supervisory practice on Investment of Pillar II and the ICAAP and their respective importance for banks management boards. Beyond regulatory pressure, the Suitability is distinguished by attention to detail and economic added value of a sound ICAAP framework is signifia high degree of differentiation. Regulations are cant and can be attained with reasonable effort. no detailed following a global convergence trend, yet

What is the appropriate way to fulfill these tasks? standards. However, as attention on these areas intensifies, more concrete standards are expected view of In this brochure, we summarize ourto evolve.the potential need for action in five topics:

ance is still rather principle-based due to the lack of concrete

regulatory guidelines financial crisis as well to date. In response to the presentexist in Switzerland as in light The Federal current Swiss regulation thus offers cover of the fact thatSupreme Court ruling does not fullya suit all aspects relevantof reference for the duties of finan able framework to Pillar II / ICAAP, the FINMA decided to take action.institutions in the field contacted and cial services Various Swiss banks were of investment informed The the FINMA will conduct Pillar II identified advice. that Federal Court has expressly review activities throughout 2009. The result of these reviews may the following obligations: lead to increased capital requirements. Disclosing detailed guidance on some of the major ICAAP Internationally,risk Interviewing clients on their degree funding risk topics such as stress testing and liquidity andof knowledge is evolving. At the moment, the available regulatory guidand risk tolerance

Investment adviser training framework provides a Our standardized yet flexible ICAAP

Ernst & Young has successfully completed a large number of ICAAP projects with a variety of banks worldwide. As such, Client investment profile and product classification Ernst & Young is well placed to advise and support any bank Risk disclosure and verifiability that is reflecting on its Pillar II strategy, is in need of conPortfolio solutions, or would like to compare its present crete ICAAPdiversification standards approaches against current institute level standards. Concentration risks at market practice

Dealing withyour bank. We would beright wayto discuss the these topics in the delighted can cific needs of significantlyfor your bank with you in person and identify best strategy mitigate the risks facing your company andbest way to the quality in your future ICAAP and risk the enhance support you of your investment advice.
management endeavors.

sound basis for establishing a framework tailored to the spe-

Providing tailored advice Warning the client, if and when necessary

Contact Zurich Iqbal Khan, Partner, Financial Services iqbal.khan@ch.ey.com, tel. +41 58 286 42 54
Your contacts roger.senteler@ch.ey.com, tel. +41 58 286 33 76 Zurich Christian Rthlin, Financial Services, Legal Bruno Oppliger, Partner christian.roethlin@ch.ey.com, tel. +41 58 286 35 38 Phone +41 58 289 46 67 e-mail bruno.oppliger@ch.ey.com Alessandro Lana, Financial Services, Risk Thomas Schneider, Partner Phone +41 58 289 33 18 e-mail Geneva thomas.schneider@ch.ey.com

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Ernst & Young is a leading provider of audit, tax, transaction and advisory services. Our 135,000 employees around the world provide quality services by combining our common values with consistent commitment. In Switzerland, Ernst & Young is a leading audit and advisory company offering services in the area of tax and legal issues, as well as in transactions and accounting. Our 1,900 employees in Switzerland generated revenue of CHF 563 million in the 2007/2008 business year. We stand out as a company because we help our employees, clients and stakeholders to realize their full potential. Further information can be found on our website at www.ey.com/ch. Ernst & Young refers to the global organization of member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, UK, does not provide services for clients.

Daniel Martin, Senior Manager stephane.muller@ch.ey.com, tel. +41 58 286 55 95 Phone +41 58 289 37 18 e-mail daniel.martin@ch.ey.com

Stphane Muller, Partner, Financial Services

Barbara Ofner, Financial Services, Legal barbara.ofner@ch.ey.com, tel. +41 58 286 32 07 Geneva/Lugano

Stphane Mller, Partner Matthieu de Wolff, Financial Services, Risk Phone +41 58 289 55 95 matthieu.dewolff@ch.ey.com, tel. +41 58 286 55 49 e-mail stephane.muller@ch.ey.com Matthieu de Wolff, Manager Mario Phone Mosca, Partner,55 49 +41 58 289 Financial Services e-mail matthieu.wolff@ch.ey.com mario.mosca@ch.ey.com, tel. +41 58 286 58 66

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