SEC Company Response from Banco Santander, S.A. (SAN, BCDRF) (CIK 0000891478) (SAN) — Oct 29, 2010
Banco Santander, S.A. (SAN, BCDRF) (CIK 0000891478)
Date: Oct. 29, 2010 · CIK: 0000891478 · Accession: 0000950103-10-003179
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-12518
Referenced dates: April 27, 2007, September 29, 2010
Letter
Division of Corporation Finance Re: Banco Santander, S.A. Form 20-F for the Fiscal Year Ended December 31, 2009 File No. 001-12518
Dear Mr. Vaughn:
On behalf of Banco Santander, S.A. (“Santander” or the “Bank”), I hereby submit Santander’s responses to the comments of the staff of the Division of Corporation Finance (the “Staff”) of the United States Securities and Exchange Commission (the “Commission”) set forth in your letter dated September 29, 2010 in connection with the above referenced Annual Report on Form 20-F (the “20-F”) of Santander.
I set forth below our responses to each of the Staff’s comments, indicating each comment in boldface text with our response below. All references to page numbers in Santander’s responses are to pages in the filed version of the 20-F.
****************************
Form 20-F for the fiscal year ended December 31, 2009
General
1.
We note your disclosure on pages 24 and 26 that in October 2007, RFS Holdings B,V., a company owned partially by you, acquired ABN AMRO Holding N.V., which was renamed The Royal Bank of Scotland Holding N.V, in April 2010. We are aware of a U.S. Department of Justice press release dated May 10, 2010, reporting that the former ABN AMRO Bank N.V. agreed to forfeit $500 million to the United States in connection with violations of law that involved illegal U.S. dollar transactions on behalf of financial institutions and customers from Iran, Libya, Sudan, Cuba, and other countries sanctioned in programs administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”), including a limited number of transactions that occurred in 2007. Please tell us, to the best of your knowledge, whether the transactions covered by this agreement include transactions that occurred after ABN AMRO Holding N.V. was acquired by RFS Holdings B.V. Describe to us in reasonable detail the nature of any such transactions, the countries involved, and the aggregate dollar value of the transactions related to each country.
Response
We confirm that to the best of our knowledge none of the transactions covered by the Deferred Protection Agreement relate to transactions by ABN AMRO Holding N.V., ABN AMRO Bank N.V. or any of its controlled subsidiaries occurred after the acquisition of ABN AMRO Holding N.V. by RFS Holding B.V. on October 17, 2007.
2.
We note the disclosure on page 166 and elsewhere that you operate in Latin America and Asia, regions that can be understood to include Cuba, Iran, and Syria. As you know, Cuba, Iran, and Syria are identified by the U.S. Department of State as state sponsors of terrorism, and are subject to U.S. economic sanctions and export controls. Please provide us with information regarding your contacts with those countries since your letter to us dated April 27, 2007. Your response should address both direct contacts and contacts through subsidiaries, affiliates, or other indirect means. It should describe any services or funds you have provided to individuals and institutions of those countries, directly or indirectly, since your letter, and any agreements, commercial arrangements, or other contacts you have had with the governments of those countries or entities controlled by those governments since that time. Finally, discuss the applicability of Section 104 of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 to any activities related to Iran.
Response
Iran
Our contacts with, and financial services related to, Iran are limited to the following:
Legacy export credits and performance guarantees:
Since our letter dated April 27, 2007, Grupo Santander has undertaken significant steps in withdrawing from the Iranian market. It has closed its representative office in Iran and has ceased all banking activities (correspondent relationship, taking deposits from Iranian entities, issuing export letters of credit) in that country, except with respect to certain long-term performance guarantees and export credits which were in place prior to that date and which we are not contractually allowed to cancel without paying the guaranteed amount (in the case of the performance guarantees) or forfeiting the outstanding credit amount (in the case of the export credits) to the Iranian beneficiary.
As of June 30, 2010, the amounts outstanding under long term export credits provided by Banco Santander are as follows: €17.8 million with Bank Sepah and €16.2 million with Bank Mellat. Of that amount, 98.7% is insured by official export credit agencies (Spanish CESCE and French COFACE).
The outstanding amount of performance guarantees (stand-by letters of credit to guarantee the obligations – either under tender documents or under contracting agreements – of contractors who participate in public bids in Iran) as of June 30, 2010 cannot be stated, since our systems track our exposure with respect to these types of stand-by letters of credit on a per applicant (as opposed to on a per beneficiary) basis. As a result, we cannot, without significant burden and expense, calculate our aggregate exposure to performance guarantees with respect to which the beneficiary is an Iranian entity.
Financial assets:
As of June 30, 2010, Banco Santander and its majority owned affiliate Banesto had € 2.7 million in loans (mortgages mainly) extended to Iranian nationals who had an account open with Grupo Santander.
Deposits:
In addition to these financial assets, the balance as of June 30, 2010 of current accounts, deposits and time deposits held in Grupo Santander by Iranian nationals (a total of 280 accounts) amounts to €5.6 million.
We believe that Section 104 of the Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010 is not applicable to Grupo Santander, in light of the interpretations of the U.S. Department of the Treasury’s Office of Foreign Assets Control in Section 561.404 of the Iranian Financial Sanctions Regulations, 31 C.F.R. Part 561, since we do not believe we have engaged in any transactions or provided financial services that fall within the scope of this law.
Cuba
Our contacts with, and financial services related to, Cuba are limited to the following:
Correspondent relationships:
Banco Santander and/or its affiliates have correspondent relationships with banks in a number of different countries, including Cuba, for the purpose of carrying out commercial transactions on behalf of our customers. Correspondent relationships exist with the following Cuban banks: Banco Exterior de Cuba, Banco Internacional de Comercio, Banco Popular de Ahorro, Banco de Crédito y Comercio, Banco Financiero Internacional, Banco Nacional de Cuba and Banco Metropolitano. Our volume of commercial transactions to and from Cuba pursuant to these correspondent relationships continues to be very low, as explained in our letter of April 27, 2007.
Financial assets:
As of June 30, 2010, the total amount of financial assets related to Cuba was €41.2 million, of which €40.7 million corresponds to various loans to a tobacco export company, 50% owned by a UK based multinational tobacco company. The loans are guaranteed by the UK based multinational.
Deposits:
As of June 30, 2010, Banco Financiero Internacional had five time deposits with Banesto for a total value of €104.2 million. Banesto had received a further €2.0 million in deposits from Cuban non-financial entities. The balances of current accounts, deposits and time deposits made by Cuban entities and individuals in Banco Santander in Spain is €5.4 million (of which less than €0.4 million relates to the Cuban embassy and consulate and official press agency, and the rest pertains to approximately 450 Cuban nationals).
Sudan
Our contacts with, and financial services related to Sudan are very limited and relate to the following:
Correspondent relationships:
As explained in our letter of February 2, 2007, our correspondent banking relationships in Sudan are – and historically have been – de minimis. Currently, Banco Santander does not maintain a correspondent banking relationship in Sudan, but two of its affiliates (Banesto and Banco Santander Uruguay) do so with the purpose of supporting the commercial activity of their customers in Sudan. The banks with which there is a correspondent banking relationship are Byblos Bank Africa Limited and Sudanese French Bank.
Financial assets and financial liabilities:
As of June 30, 2010, the Group had financial assets of €0.006 million from Sudanese nationals and financial liabilities of €0.011 million to Sudanese nationals.
Syria
Our contacts with, and financial services related to, Syria are very limited and relate to the following:
Correspondent relationships:
After our letter of April 27, 2007, Santander cancelled its correspondent banking relationship with the Commercial Bank of Syria. Banesto, an affiliate of Grupo Santander, maintains correspondent banking relationships with Damascus Syrian Arab Republic – Arab Bank Syria, S.A., Banque Bemo Saudi Fransi and Banque Centrale de Syrie. The activity is very low.
Financial assets:
As of June 30, 2010, the total amount of financial assets related to Syria was €0.012 million.
Deposits:
As of June 30, 2010, Syrian nationals maintained current accounts, deposits and time deposits in the Group for a total amount of €7.4 million. Of such amount, €3.2 million was held in two current accounts by one individual in Banco Santander (Suisse), €1.0 million was held by the Syrian embassy in Madrid, and the rest was widely distributed.
3.
Please discuss the materiality of any contacts with Cuba, Iran, Sudan, and Syria that you, describe in response to the foregoing comments, and whether those contacts constitute a material investment risk for your security holders. You should address materiality in quantitative terms, including the approximate dollar amounts of revenues, assets, and liabilities associated with each of Cuba, Iran, Sudan, and Syria for the last three fiscal years and the subsequent interim period. Also, address materiality in terms of qualitative factors that a reasonable investor would deem important in making an investment decision, including the potential impact of corporate activities upon a company's reputation and share value. As you know, various state and municipal governments, universities, and other investors have proposed or adopted divestment or similar initiatives regarding investment in companies that do business with U.S. designated state sponsors of terrorism. Your materiality analysis should address the potential impact of the investor sentiment evidenced by such actions directed toward companies that have operations associated with Cuba, Iran, Sudan, and Syria.
Response
In assessing the materiality of our contacts with Iran, Cuba, Sudan and Syria, we believe that they are an entirely insignificant and non-material component of our business. In assessing the materiality of our contacts with these countries, both individually and in the aggregate, we have considered both quantitative and qualitative factors. For the reasons we describe below, we believe that our contacts with Iran, Cuba, Sudan and Syria are not material to our results of operations or financial condition. We further believe that, in light of the de minimis size and nature of these contacts, such contacts do not constitute a material investment risk for our securityholders. Our assessment of qualitative factors included consideration of the potential impact of our corporate activities in these countries upon our reputation and share value.
In quantitative terms, we believe that our contacts with these countries, individually and in the aggregate, are not material. In terms of our results of operations, we estimate that less than 0.02% of our net attributable income and less than 0.01% of our net interest income for the six
months ended June 30, 2010 were generated from our contacts with these countries. These contacts have made no material contribution to our results of operations and are not expected to have any material impact in subsequent periods. In terms of our financial condition, as of June 30, 2010, the aggregate financial assets held by Grupo Santander of these four countries represent less than 0.01% of the consolidated financial assets of the Group, and the aggregate financial liabilities of Grupo Santander with these four countries represent less than 0.02% of the consolidated financial liabilities of the Group. Although we are unable to estimate the impact of our contacts with these countries on our results of operations and financial condition for prior periods without undue burden and expense, we believe the estimates as of June 30, 2010 are generally consistent with the magnitudes of such impact on our results of operations and financial condition since our letter of April 27, 2010. Accordingly, these contacts have made no material contribution to our results of operations or financial condition, nor are they expected to have any material impact thereon in subsequent periods.
Further, we do not believe that any of our past or current contacts with these countries would be qualitatively material to a reasonable investor making an investment decision about our shares. Rather, we believe that any reasonable investor would expect a bank such as ours to have correspondent banking relationships throughout the countries of the world with which the Spanish government maintains trade relations.
Item 3. Key Information
A. Selected Financial Data, page 6
4.
We note your disclosure of certain Credit Quality Data information and ratios on pages 8 and 9. In order to promote greater clarity and transparency, specifically related to your loans and lending credit quality, please revise future filings to present the ratio of your allowances for impaired balances, inclusive of country risk but exclusive of the allowance for contingent liabilities, as a percentage of only gross loans. We believe this would present a more accurate reflection of the coverage of your allowance related only to loan losses to total gross loans. To the extent you choose to continue to present your other ratios, such as those where the denominator includes contingent liabilities, please revise to more clearly disclose their usefulness and limitations in evaluating the credit quality of your loan portfolio.
Response
We disclose our ratio for the Allowances for impaired balances (excluding country risk and including contingent liabilities) as a percentage of total loans and contingent liabilities because we consider it useful information when evaluating credit quality since it reflects the coverage of our balances with customers that bear credit risk (both on balance-sheet and off balance sheet items).
Nevertheless, we have taken into consideration the Staff’s comments concerning enhanced clarity and transparency of the information relating to our loan portfolio credit quality data and, accordingly, we will present the credit quality data including and excluding contingent liabilities in order to provide the reader the relevant information to compare it with similar ratios presented by other institutions in the banking industry.
We will retain the disclosure of the allowance for impaired balances including contingent liabilities and have included a footnote to the table explaining why we believe the ratio is important.
We present below the modifications that we will include, in future filings, in the section “Credit Quality Data” of the table included on page 8 of our 20-F (we have underlined the wording that we have added and struck through deleted text):
Credit Quality Data (excluding country risk)
Loans and advanc
Show Raw Text
CORRESP 1 filename1.htm October 29, 2010 Mr. Kevin W. Vaughn Accounting Branch Chief Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, N.E.; mail stop 4561 Washington, D.C. 20549 U.S.A. Re: Banco Santander, S.A. Form 20-F for the Fiscal Year Ended December 31, 2009 File No. 001-12518 Dear Mr. Vaughn: On behalf of Banco Santander, S.A. (“Santander” or the “Bank”), I hereby submit Santander’s responses to the comments of the staff of the Division of Corporation Finance (the “Staff”) of the United States Securities and Exchange Commission (the “Commission”) set forth in your letter dated September 29, 2010 in connection with the above referenced Annual Report on Form 20-F (the “20-F”) of Santander. I set forth below our responses to each of the Staff’s comments, indicating each comment in boldface text with our response below. All references to page numbers in Santander’s responses are to pages in the filed version of the 20-F. **************************** Form 20-F for the fiscal year ended December 31, 2009 General 1. We note your disclosure on pages 24 and 26 that in October 2007, RFS Holdings B,V., a company owned partially by you, acquired ABN AMRO Holding N.V., which was renamed The Royal Bank of Scotland Holding N.V, in April 2010. We are aware of a U.S. Department of Justice press release dated May 10, 2010, reporting that the former ABN AMRO Bank N.V. agreed to forfeit $500 million to the United States in connection with violations of law that involved illegal U.S. dollar transactions on behalf of financial institutions and customers from Iran, Libya, Sudan, Cuba, and other countries sanctioned in programs administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”), including a limited number of transactions that occurred in 2007. Please tell us, to the best of your knowledge, whether the transactions covered by this agreement include transactions that occurred after ABN AMRO Holding N.V. was acquired by RFS Holdings B.V. Describe to us in reasonable detail the nature of any such transactions, the countries involved, and the aggregate dollar value of the transactions related to each country. Response We confirm that to the best of our knowledge none of the transactions covered by the Deferred Protection Agreement relate to transactions by ABN AMRO Holding N.V., ABN AMRO Bank N.V. or any of its controlled subsidiaries occurred after the acquisition of ABN AMRO Holding N.V. by RFS Holding B.V. on October 17, 2007. 1 2. We note the disclosure on page 166 and elsewhere that you operate in Latin America and Asia, regions that can be understood to include Cuba, Iran, and Syria. As you know, Cuba, Iran, and Syria are identified by the U.S. Department of State as state sponsors of terrorism, and are subject to U.S. economic sanctions and export controls. Please provide us with information regarding your contacts with those countries since your letter to us dated April 27, 2007. Your response should address both direct contacts and contacts through subsidiaries, affiliates, or other indirect means. It should describe any services or funds you have provided to individuals and institutions of those countries, directly or indirectly, since your letter, and any agreements, commercial arrangements, or other contacts you have had with the governments of those countries or entities controlled by those governments since that time. Finally, discuss the applicability of Section 104 of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 to any activities related to Iran. Response Iran Our contacts with, and financial services related to, Iran are limited to the following: Legacy export credits and performance guarantees: Since our letter dated April 27, 2007, Grupo Santander has undertaken significant steps in withdrawing from the Iranian market. It has closed its representative office in Iran and has ceased all banking activities (correspondent relationship, taking deposits from Iranian entities, issuing export letters of credit) in that country, except with respect to certain long-term performance guarantees and export credits which were in place prior to that date and which we are not contractually allowed to cancel without paying the guaranteed amount (in the case of the performance guarantees) or forfeiting the outstanding credit amount (in the case of the export credits) to the Iranian beneficiary. As of June 30, 2010, the amounts outstanding under long term export credits provided by Banco Santander are as follows: €17.8 million with Bank Sepah and €16.2 million with Bank Mellat. Of that amount, 98.7% is insured by official export credit agencies (Spanish CESCE and French COFACE). The outstanding amount of performance guarantees (stand-by letters of credit to guarantee the obligations – either under tender documents or under contracting agreements – of contractors who participate in public bids in Iran) as of June 30, 2010 cannot be stated, since our systems track our exposure with respect to these types of stand-by letters of credit on a per applicant (as opposed to on a per beneficiary) basis. As a result, we cannot, without significant burden and expense, calculate our aggregate exposure to performance guarantees with respect to which the beneficiary is an Iranian entity. Financial assets: As of June 30, 2010, Banco Santander and its majority owned affiliate Banesto had € 2.7 million in loans (mortgages mainly) extended to Iranian nationals who had an account open with Grupo Santander. Deposits: In addition to these financial assets, the balance as of June 30, 2010 of current accounts, deposits and time deposits held in Grupo Santander by Iranian nationals (a total of 280 accounts) amounts to €5.6 million. 2 We believe that Section 104 of the Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010 is not applicable to Grupo Santander, in light of the interpretations of the U.S. Department of the Treasury’s Office of Foreign Assets Control in Section 561.404 of the Iranian Financial Sanctions Regulations, 31 C.F.R. Part 561, since we do not believe we have engaged in any transactions or provided financial services that fall within the scope of this law. Cuba Our contacts with, and financial services related to, Cuba are limited to the following: Correspondent relationships: Banco Santander and/or its affiliates have correspondent relationships with banks in a number of different countries, including Cuba, for the purpose of carrying out commercial transactions on behalf of our customers. Correspondent relationships exist with the following Cuban banks: Banco Exterior de Cuba, Banco Internacional de Comercio, Banco Popular de Ahorro, Banco de Crédito y Comercio, Banco Financiero Internacional, Banco Nacional de Cuba and Banco Metropolitano. Our volume of commercial transactions to and from Cuba pursuant to these correspondent relationships continues to be very low, as explained in our letter of April 27, 2007. Financial assets: As of June 30, 2010, the total amount of financial assets related to Cuba was €41.2 million, of which €40.7 million corresponds to various loans to a tobacco export company, 50% owned by a UK based multinational tobacco company. The loans are guaranteed by the UK based multinational. Deposits: As of June 30, 2010, Banco Financiero Internacional had five time deposits with Banesto for a total value of €104.2 million. Banesto had received a further €2.0 million in deposits from Cuban non-financial entities. The balances of current accounts, deposits and time deposits made by Cuban entities and individuals in Banco Santander in Spain is €5.4 million (of which less than €0.4 million relates to the Cuban embassy and consulate and official press agency, and the rest pertains to approximately 450 Cuban nationals). Sudan Our contacts with, and financial services related to Sudan are very limited and relate to the following: Correspondent relationships: As explained in our letter of February 2, 2007, our correspondent banking relationships in Sudan are – and historically have been – de minimis. Currently, Banco Santander does not maintain a correspondent banking relationship in Sudan, but two of its affiliates (Banesto and Banco Santander Uruguay) do so with the purpose of supporting the commercial activity of their customers in Sudan. The banks with which there is a correspondent banking relationship are Byblos Bank Africa Limited and Sudanese French Bank. Financial assets and financial liabilities: As of June 30, 2010, the Group had financial assets of €0.006 million from Sudanese nationals and financial liabilities of €0.011 million to Sudanese nationals. 3 Syria Our contacts with, and financial services related to, Syria are very limited and relate to the following: Correspondent relationships: After our letter of April 27, 2007, Santander cancelled its correspondent banking relationship with the Commercial Bank of Syria. Banesto, an affiliate of Grupo Santander, maintains correspondent banking relationships with Damascus Syrian Arab Republic – Arab Bank Syria, S.A., Banque Bemo Saudi Fransi and Banque Centrale de Syrie. The activity is very low. Financial assets: As of June 30, 2010, the total amount of financial assets related to Syria was €0.012 million. Deposits: As of June 30, 2010, Syrian nationals maintained current accounts, deposits and time deposits in the Group for a total amount of €7.4 million. Of such amount, €3.2 million was held in two current accounts by one individual in Banco Santander (Suisse), €1.0 million was held by the Syrian embassy in Madrid, and the rest was widely distributed. 3. Please discuss the materiality of any contacts with Cuba, Iran, Sudan, and Syria that you, describe in response to the foregoing comments, and whether those contacts constitute a material investment risk for your security holders. You should address materiality in quantitative terms, including the approximate dollar amounts of revenues, assets, and liabilities associated with each of Cuba, Iran, Sudan, and Syria for the last three fiscal years and the subsequent interim period. Also, address materiality in terms of qualitative factors that a reasonable investor would deem important in making an investment decision, including the potential impact of corporate activities upon a company's reputation and share value. As you know, various state and municipal governments, universities, and other investors have proposed or adopted divestment or similar initiatives regarding investment in companies that do business with U.S. designated state sponsors of terrorism. Your materiality analysis should address the potential impact of the investor sentiment evidenced by such actions directed toward companies that have operations associated with Cuba, Iran, Sudan, and Syria. Response In assessing the materiality of our contacts with Iran, Cuba, Sudan and Syria, we believe that they are an entirely insignificant and non-material component of our business. In assessing the materiality of our contacts with these countries, both individually and in the aggregate, we have considered both quantitative and qualitative factors. For the reasons we describe below, we believe that our contacts with Iran, Cuba, Sudan and Syria are not material to our results of operations or financial condition. We further believe that, in light of the de minimis size and nature of these contacts, such contacts do not constitute a material investment risk for our securityholders. Our assessment of qualitative factors included consideration of the potential impact of our corporate activities in these countries upon our reputation and share value. In quantitative terms, we believe that our contacts with these countries, individually and in the aggregate, are not material. In terms of our results of operations, we estimate that less than 0.02% of our net attributable income and less than 0.01% of our net interest income for the six 4 months ended June 30, 2010 were generated from our contacts with these countries. These contacts have made no material contribution to our results of operations and are not expected to have any material impact in subsequent periods. In terms of our financial condition, as of June 30, 2010, the aggregate financial assets held by Grupo Santander of these four countries represent less than 0.01% of the consolidated financial assets of the Group, and the aggregate financial liabilities of Grupo Santander with these four countries represent less than 0.02% of the consolidated financial liabilities of the Group. Although we are unable to estimate the impact of our contacts with these countries on our results of operations and financial condition for prior periods without undue burden and expense, we believe the estimates as of June 30, 2010 are generally consistent with the magnitudes of such impact on our results of operations and financial condition since our letter of April 27, 2010. Accordingly, these contacts have made no material contribution to our results of operations or financial condition, nor are they expected to have any material impact thereon in subsequent periods. Further, we do not believe that any of our past or current contacts with these countries would be qualitatively material to a reasonable investor making an investment decision about our shares. Rather, we believe that any reasonable investor would expect a bank such as ours to have correspondent banking relationships throughout the countries of the world with which the Spanish government maintains trade relations. Item 3. Key Information A. Selected Financial Data, page 6 4. We note your disclosure of certain Credit Quality Data information and ratios on pages 8 and 9. In order to promote greater clarity and transparency, specifically related to your loans and lending credit quality, please revise future filings to present the ratio of your allowances for impaired balances, inclusive of country risk but exclusive of the allowance for contingent liabilities, as a percentage of only gross loans. We believe this would present a more accurate reflection of the coverage of your allowance related only to loan losses to total gross loans. To the extent you choose to continue to present your other ratios, such as those where the denominator includes contingent liabilities, please revise to more clearly disclose their usefulness and limitations in evaluating the credit quality of your loan portfolio. Response We disclose our ratio for the Allowances for impaired balances (excluding country risk and including contingent liabilities) as a percentage of total loans and contingent liabilities because we consider it useful information when evaluating credit quality since it reflects the coverage of our balances with customers that bear credit risk (both on balance-sheet and off balance sheet items). Nevertheless, we have taken into consideration the Staff’s comments concerning enhanced clarity and transparency of the information relating to our loan portfolio credit quality data and, accordingly, we will present the credit quality data including and excluding contingent liabilities in order to provide the reader the relevant information to compare it with similar ratios presented by other institutions in the banking industry. 5 We will retain the disclosure of the allowance for impaired balances including contingent liabilities and have included a footnote to the table explaining why we believe the ratio is important. We present below the modifications that we will include, in future filings, in the section “Credit Quality Data” of the table included on page 8 of our 20-F (we have underlined the wording that we have added and struck through deleted text): 2009 2008 2007 2006 2005 Credit Quality Data (excluding country risk) Loans and advanc