SEC Company Response from UBS AG (AMUB, BDCX, BDCZ, CEFD, HDLB, IFED, IWDL, IWFL, IWML, MLPB, MLPR, MTUL, MVRL, PFFL, QULL, SCDL) (CIK 0001114446) (AMUB) — Feb 28, 2013
UBS AG (AMUB, BDCX, BDCZ, CEFD, HDLB, IFED, IWDL, IWFL, IWML, MLPB, MLPR, MTUL, MVRL, PFFL, QULL, SCDL) (CIK 0001114446)
Date: Feb. 28, 2013 · CIK: 0001114446 · Accession: 0001193125-13-082505
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-15060
Referenced dates: January 30, 2013
Letter
Division of Corporation Finance Securities and Exchange Commission Filed March 15, 2012 Forms 6-K filed July 31, 2012 and October 30, 2012 Response dated September 10, 2012 File No. 001-15060
Dear Ms. Ciboroski:
We respectfully submit the responses set forth below to the Comment Letter dated January 30, 2013 (the “Comment Letter” and individually or collectively “Comments”) from the Staff of the Securities and Exchange Commission relating to (a) the annual report on Form 20-F for the fiscal year ended December 31, 2011 (the “2011 Form 20-F”), (b) the second quarter 2012 report on Form 6-K (the “Q2 2012 Form 6-K”) and (c) the third quarter 2012 report on Form 6-K (the “Q3 2012 Form 6-K”) of UBS AG (“UBS”). For your convenience, we have set out the text of each Comment contained in the Comment Letter, followed by our response. We are in the final stages of preparing our annual report for the fiscal year ended December 31, 2012, which is expected to be authorized for issue by the Board of Directors on March 7, 2013 and then filed on Form 20-F (the “2012 Form 20-F”). Where relevant, we have included in the relevant responses below our current proposed disclosure for the 2012 Form 20-F.
Comment 1
Form 20-F for Fiscal Year Ended December 31, 2011
Composition of credit risk – business divisions, page 120
Wealth Management & Swiss Bank, page 120
We note your response to prior comment 5. Please provide us with the proposed disclosures that you intend to provide in your future filings to address our comment.
We have considered your Comments requesting additional disclosure for our residential real estate loan portfolio with regard to our process for loan-to-value (“LTV”) ratios at the origination of such loans, quantitative information on our current LTV ratios and the process for calculating current LTV ratios. Our current proposed disclosure on this matter, in the Composition of credit risk – business divisions section of the 2012 Form 20-F, is below. We believe that this enhanced disclosure addresses these Comments.
UBS AG
Form 20-F for the Fiscal Year Ended
December 31, 2011 filed March 15,
Forms 6-K filed July 31, 2012 and October
30, 2012
Response dated September 10, 2012
File No. 001-15060
28 February 2013
Page 2 of 22
“Our largest loan portfolio is our mortgage loan portfolio, which principally comprises loans within Switzerland which are secured by residential and commercial real estate. These mortgage loans mainly originate from our Retail and Corporate business but also include mortgage loans originating from our Wealth Management business. The majority of these mortgage loans relate to residential properties that the borrower either occupies or rents out and are full recourse to the borrower.
We use a scoring model as part of a standardized front-to-back process to support credit decisions for the origination or modification of all Swiss mortgage loans. The two key factors within this model are an affordability calculation relative to gross income and the loan-to-value ratio (LTV). The calculation of affordability takes into account interest payments, minimum amortization requirements, potential property maintenance costs and, in the case of properties expected to be rented out, the level of rental income. Interest payments are estimated using a predefined framework, which takes into account the potential for significant increases in interest rates during the lifetime of the loan.
Approximately 70% of the Swiss residential mortgage loan portfolio relates to properties occupied by the borrower. For such mortgage loans, the maximum LTV allowed within the standard approval process is 80%. This is reduced to 60% in the case of vacation properties and luxury real estate. The value assigned by UBS to each property is based on the lowest value determined based on an internal valuation, the purchase price and, in some cases, an additional external valuation. Valuations of owner-occupied real estate are reviewed and updated throughout the lifetime of the loan, typically using real estate price indices. The average LTV ratio of this portfolio was approximately 55% at 31 December 2012, compared with 58% at 31 December 2011. Over 99% of the aggregate amount of mortgage loans within this portfolio would continue to be covered by the real estate collateral even if the value assigned to that collateral were to decrease by 20%. Furthermore, these loans are full recourse to the borrower. The average LTV for 2012 of newly originated loans in this portfolio was 63%.
Approximately 30% of the Swiss residential mortgage loan portfolio relates to properties rented out by the borrower. For such mortgage loans, the maximum LTV allowed within the standard approval process ranges from 60% to 80%, depending on the type of property, the age of the property and the amount of any renovation work required. LTVs are reviewed and updated periodically throughout the lifetime of the loan. The rental income from properties is reviewed, at a minimum, once every three years, but indications of significant changes in the amount of rental income or the level of vacancy rate can trigger an interim reappraisal. The average LTV ratio of this portfolio was approximately 58% at 31 December 2012, compared with 59% at 31 December 2011. Over 99% of the aggregate amount of mortgage loans within this portfolio would continue to be covered by the real estate collateral even if the value assigned to that collateral were to decrease by 20%. Furthermore, these loans are full recourse to the borrower. The average LTV for 2012 of newly originated loans in this portfolio was 56%.”
Comment 2
Consolidated Financial Statements, page 284
Note 1 – Summary of significant accounting policies, page 297
a) Significant accounting policies, page 297
10) Loans and Receivables – Renegotiated Loans, page 301
We note your response to prior comments 14 and 15. Please address the following:
•
Revise your disclosure in future filings to clarify the differences between loans renegotiated on concessionary terms and loans renegotiated on a non-concessionary basis in terms of nonperforming classification and method of impairment measurement.
•
Tell us and revise future filings to disclose whether you monitor or segregate these loans from other non-renegotiated loans within the general collective loan assessment for purposes of measuring credit losses. If you do not segregate these loans from loans that were not previously renegotiated, please tell us whether you otherwise take into consideration the fact that these loans have been renegotiated when measuring credit losses.
UBS AG
Form 20-F for the Fiscal Year Ended
December 31, 2011 filed March 15,
Forms 6-K filed July 31, 2012 and October
30, 2012
Response dated September 10, 2012
File No. 001-15060
28 February 2013
Page 3 of 22
We have considered your Comments with regard to clarifying the differences between loans renegotiated on concessionary terms and loans renegotiated on a non-concessionary basis—in terms of non-performing classification and method of impairment measurement. Additionally, we have considered how we treat and monitor these loans within the general collective loan assessment for purposes of measuring credit losses. Consequently, our current proposed disclosure on this matter in Note 1, the Summary of significant accounting policies section of the 2012 Form 20-F, is as follows:
“A renegotiated loan is defined as a loan that has been subject to restructuring, or for which additional collateral has been requested that was not contemplated in the original contract.
Typical key features of terms and conditions granted through renegotiation to avoid default include the provision of special interest rates, postponement of interest or amortization payments, modification of the schedule of repayments or amendment of loan maturity. There is no change in the effective interest rate following a renegotiation.
If a loan is renegotiated with concessionary conditions (i.e. new terms and conditions are agreed which do not meet the normal market criteria for the quality of the obligor and the type of loan), the position is still classified as non-performing and is rated as being in counterparty default. It will remain so until the loan is collected or written off and will be assessed for impairment on an individual basis.
If a loan is renegotiated on a non-concessionary basis (e.g. additional collateral is provided by the client, or new terms and conditions are agreed which meet the normal market criteria for the quality of the obligor and the type of loan), the loan will be re-rated using our regular rating scale. In these circumstances, the loan is removed from impaired status and therefore included in our collective assessment of loan loss allowances. For the purposes of measuring credit losses, these loans are not segregated within the collective loan loss assessment from other loans which have not been renegotiated. Management regularly reviews all loans to ensure that each of the criteria contained in the loan agreement continues to be met and that future payments are likely to occur.
In those situations where the restructuring of a loan results in a fundamental change in the terms and conditions of the loan, the original loan is derecognized and a new loan is recognized. A change is considered fundamental if the present value of the contractual cash flows (as a proportion of notional) has been changed by 10% or more, or there has been a significant change in the risk profile of the instrument. If a loan is derecognized in these circumstances, the new loan is measured at fair value at initial recognition. Any allowance taken to date against the original loan is eliminated and is not attributed to the new loan. Consequently, the new loan is not considered impaired and is included within the general collective loan loss assessment for the purpose of measuring credit losses.”
Comment 3
Note 16 – Goodwill and intangible assets, page 336
We note your response to prior comment 16, including the statement that you do not specifically identify the assets and liabilities that make up the excess capital. Please confirm that the carrying value of each cash generating unit (CGU) includes only those assets that can be attributed directly, or allocated on a reasonable and consistent basis, to each CGU and provide a robust explanation of your asset allocation process. In this regard, clarify whether you are able to specifically identify the assets that remain in the Corporate Center after allocations (or conversely, whether you are able to specifically identify which assets have been allocated out to the CGUs). If not, please tell us how you concluded that you met the criteria in paragraphs 76 of IAS 36.
UBS AG
Form 20-F for the Fiscal Year Ended
December 31, 2011 filed March 15,
Forms 6-K filed July 31, 2012 and October
30, 2012
Response dated September 10, 2012
File No. 001-15060
28 February 2013
Page 4 of 22
As noted in the Capital Management section of our 2011 Form 20-F, equity is attributed to the businesses and the Corporate Center (“CC”) after considering their risk exposure, risk-weighted assets (“RWA”) usage, asset size, goodwill and intangible assets. Thus in order to attribute equity under the equity attribution framework (“EAF”), the assets of each segment (or cash-generating unit (“CGU”)) and the CC are identified. Because we identify the assets attributable to each CGU and the CC, we can confirm that the carrying amount of each respective CGU and the CC includes only those assets that can be attributed directly or allocated on a reasonable and consistent basis to it.
We attribute assets directly to the CGUs and the CC based on the way assets are managed internally, meaning that assets are attributed to the business division (or the CC) that is responsible for managing them and their performance. Hence, that approach is aligned with our segment reporting pursuant to IFRS 8 Operating Segments as most recently disclosed in our fourth quarter 2012 report on Form 6-K (“the Q4 2012 Form 6-K”).
As we can identify the assets in the CC, for the purpose of our goodwill impairment testing, we evaluate them to determine whether they represent corporate assets, as described in IAS 36.100-101. Corporate assets in the CC are identified and allocated to the CGUs on a reasonable and consistent basis. Allocated corporate assets consist of property and equipment, which have been allocated based on actual rates of usage incurred by each CGU. Other assets in the CC are not deemed to represent corporate assets because they generate cash flows independently of the other CGUs and thus are not allocated (e.g. our multi-currency portfolio of unencumbered, high quality, short-term financial assets that are managed by Group Treasury). The Legacy Portfolio financial assets in CC also are not allocated for that same reason.1
As a result of the process described above, we are able to specifically identify the assets that remain in the CC after allocations. We believe that our attribution and allocation methodology results in an appropriate basis for determining the carrying amount of each CGU in accordance with IAS 36.76–79.
Comment 4
Furthermore, to the extent that you do not identify the specific assets and liabilities directly attributed to each CGU, please tell us how you are able to estimate the cash flows from such CGUs. In your response, please address why you believe your methodology complies with the guidance in paragraph 77 of IAS 36.
As explained in our response to Comment 3, we are able to identify the specific assets for each CGU. Thus we have the requisite information to determine that our attribution and allocation methodology results in an appropriate basis for determining both the recoverable amount and the carrying amount of our CGUs. Hence, we believe that our methodology complies with the guidance in IAS 36.77.
Comment 5
In your response dated September 16, 2011 you noted that one potential shortfall of the equity attribution framework was that the attribution process will not always result in aggregated attributed equity at the segment level being the same as equity attributed to your shareholders. You further recognized that adjustments would need to be made to ensure that the carrying amount for purposes of the goodwill impairment test was not less than the equity attributable to shareholders and therefore the net carrying amount of your assets and liabilities, which you believed was consistent with the premise and requirements of paragraphs 76-79 of IAS 36. Please tell us how your current equity attribution framework, including how it is used in determining the carrying value of your CGUs for purposes of goodwill impairment testing is consistent with your prior response.
The Legacy Portfolio was transferred to CC before the end of 2011; its assets consist of financial instruments.
UBS AG
Form 20-F for the Fiscal Year Ended
December 31, 2011 filed March 15,
Forms 6-K filed July 31, 2012 and October
30, 2012
Response dated September 10, 2012
File No. 001-15060
28 February 2013
Page 5 of 22
Please also refer to our response to Comment 3, where we outline our attribution and allocation methodology which results in an appropriate basis for determining the carrying amount of each CGU in accordance with IAS 36.76–79.
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CORRESP 1 filename1.htm CORRESP UBS AG Postfach 8098 Zürich Tel. +41-44-234 11 11 Corporate Center Group CFO Management Tom Naratil Tel. +41-44-234 24 07 Fax +41-44-234 21 00 tom.naratil@ubs.com www.ubs.com Ms. Stephanie Ciboroski Senior Assisstant Chief Accountant Division of Corporation Finance Securities and Exchange Commission 100 F Street, NE Washington DC 20549-1090 28 February 2013 UBS AG Form 20-F for the Fiscal Year Ended December 31, 2011 Filed March 15, 2012 Forms 6-K filed July 31, 2012 and October 30, 2012 Response dated September 10, 2012 File No. 001-15060 Dear Ms. Ciboroski: We respectfully submit the responses set forth below to the Comment Letter dated January 30, 2013 (the “Comment Letter” and individually or collectively “Comments”) from the Staff of the Securities and Exchange Commission relating to (a) the annual report on Form 20-F for the fiscal year ended December 31, 2011 (the “2011 Form 20-F”), (b) the second quarter 2012 report on Form 6-K (the “Q2 2012 Form 6-K”) and (c) the third quarter 2012 report on Form 6-K (the “Q3 2012 Form 6-K”) of UBS AG (“UBS”). For your convenience, we have set out the text of each Comment contained in the Comment Letter, followed by our response. We are in the final stages of preparing our annual report for the fiscal year ended December 31, 2012, which is expected to be authorized for issue by the Board of Directors on March 7, 2013 and then filed on Form 20-F (the “2012 Form 20-F”). Where relevant, we have included in the relevant responses below our current proposed disclosure for the 2012 Form 20-F. Comment 1 Form 20-F for Fiscal Year Ended December 31, 2011 Composition of credit risk – business divisions, page 120 Wealth Management & Swiss Bank, page 120 We note your response to prior comment 5. Please provide us with the proposed disclosures that you intend to provide in your future filings to address our comment. We have considered your Comments requesting additional disclosure for our residential real estate loan portfolio with regard to our process for loan-to-value (“LTV”) ratios at the origination of such loans, quantitative information on our current LTV ratios and the process for calculating current LTV ratios. Our current proposed disclosure on this matter, in the Composition of credit risk – business divisions section of the 2012 Form 20-F, is below. We believe that this enhanced disclosure addresses these Comments. UBS AG Form 20-F for the Fiscal Year Ended December 31, 2011 filed March 15, 2012 Forms 6-K filed July 31, 2012 and October 30, 2012 Response dated September 10, 2012 File No. 001-15060 28 February 2013 Page 2 of 22 “Our largest loan portfolio is our mortgage loan portfolio, which principally comprises loans within Switzerland which are secured by residential and commercial real estate. These mortgage loans mainly originate from our Retail and Corporate business but also include mortgage loans originating from our Wealth Management business. The majority of these mortgage loans relate to residential properties that the borrower either occupies or rents out and are full recourse to the borrower. We use a scoring model as part of a standardized front-to-back process to support credit decisions for the origination or modification of all Swiss mortgage loans. The two key factors within this model are an affordability calculation relative to gross income and the loan-to-value ratio (LTV). The calculation of affordability takes into account interest payments, minimum amortization requirements, potential property maintenance costs and, in the case of properties expected to be rented out, the level of rental income. Interest payments are estimated using a predefined framework, which takes into account the potential for significant increases in interest rates during the lifetime of the loan. Approximately 70% of the Swiss residential mortgage loan portfolio relates to properties occupied by the borrower. For such mortgage loans, the maximum LTV allowed within the standard approval process is 80%. This is reduced to 60% in the case of vacation properties and luxury real estate. The value assigned by UBS to each property is based on the lowest value determined based on an internal valuation, the purchase price and, in some cases, an additional external valuation. Valuations of owner-occupied real estate are reviewed and updated throughout the lifetime of the loan, typically using real estate price indices. The average LTV ratio of this portfolio was approximately 55% at 31 December 2012, compared with 58% at 31 December 2011. Over 99% of the aggregate amount of mortgage loans within this portfolio would continue to be covered by the real estate collateral even if the value assigned to that collateral were to decrease by 20%. Furthermore, these loans are full recourse to the borrower. The average LTV for 2012 of newly originated loans in this portfolio was 63%. Approximately 30% of the Swiss residential mortgage loan portfolio relates to properties rented out by the borrower. For such mortgage loans, the maximum LTV allowed within the standard approval process ranges from 60% to 80%, depending on the type of property, the age of the property and the amount of any renovation work required. LTVs are reviewed and updated periodically throughout the lifetime of the loan. The rental income from properties is reviewed, at a minimum, once every three years, but indications of significant changes in the amount of rental income or the level of vacancy rate can trigger an interim reappraisal. The average LTV ratio of this portfolio was approximately 58% at 31 December 2012, compared with 59% at 31 December 2011. Over 99% of the aggregate amount of mortgage loans within this portfolio would continue to be covered by the real estate collateral even if the value assigned to that collateral were to decrease by 20%. Furthermore, these loans are full recourse to the borrower. The average LTV for 2012 of newly originated loans in this portfolio was 56%.” Comment 2 Consolidated Financial Statements, page 284 Note 1 – Summary of significant accounting policies, page 297 a) Significant accounting policies, page 297 10) Loans and Receivables – Renegotiated Loans, page 301 We note your response to prior comments 14 and 15. Please address the following: • Revise your disclosure in future filings to clarify the differences between loans renegotiated on concessionary terms and loans renegotiated on a non-concessionary basis in terms of nonperforming classification and method of impairment measurement. • Tell us and revise future filings to disclose whether you monitor or segregate these loans from other non-renegotiated loans within the general collective loan assessment for purposes of measuring credit losses. If you do not segregate these loans from loans that were not previously renegotiated, please tell us whether you otherwise take into consideration the fact that these loans have been renegotiated when measuring credit losses. UBS AG Form 20-F for the Fiscal Year Ended December 31, 2011 filed March 15, 2012 Forms 6-K filed July 31, 2012 and October 30, 2012 Response dated September 10, 2012 File No. 001-15060 28 February 2013 Page 3 of 22 We have considered your Comments with regard to clarifying the differences between loans renegotiated on concessionary terms and loans renegotiated on a non-concessionary basis—in terms of non-performing classification and method of impairment measurement. Additionally, we have considered how we treat and monitor these loans within the general collective loan assessment for purposes of measuring credit losses. Consequently, our current proposed disclosure on this matter in Note 1, the Summary of significant accounting policies section of the 2012 Form 20-F, is as follows: “A renegotiated loan is defined as a loan that has been subject to restructuring, or for which additional collateral has been requested that was not contemplated in the original contract. Typical key features of terms and conditions granted through renegotiation to avoid default include the provision of special interest rates, postponement of interest or amortization payments, modification of the schedule of repayments or amendment of loan maturity. There is no change in the effective interest rate following a renegotiation. If a loan is renegotiated with concessionary conditions (i.e. new terms and conditions are agreed which do not meet the normal market criteria for the quality of the obligor and the type of loan), the position is still classified as non-performing and is rated as being in counterparty default. It will remain so until the loan is collected or written off and will be assessed for impairment on an individual basis. If a loan is renegotiated on a non-concessionary basis (e.g. additional collateral is provided by the client, or new terms and conditions are agreed which meet the normal market criteria for the quality of the obligor and the type of loan), the loan will be re-rated using our regular rating scale. In these circumstances, the loan is removed from impaired status and therefore included in our collective assessment of loan loss allowances. For the purposes of measuring credit losses, these loans are not segregated within the collective loan loss assessment from other loans which have not been renegotiated. Management regularly reviews all loans to ensure that each of the criteria contained in the loan agreement continues to be met and that future payments are likely to occur. In those situations where the restructuring of a loan results in a fundamental change in the terms and conditions of the loan, the original loan is derecognized and a new loan is recognized. A change is considered fundamental if the present value of the contractual cash flows (as a proportion of notional) has been changed by 10% or more, or there has been a significant change in the risk profile of the instrument. If a loan is derecognized in these circumstances, the new loan is measured at fair value at initial recognition. Any allowance taken to date against the original loan is eliminated and is not attributed to the new loan. Consequently, the new loan is not considered impaired and is included within the general collective loan loss assessment for the purpose of measuring credit losses.” Comment 3 Note 16 – Goodwill and intangible assets, page 336 We note your response to prior comment 16, including the statement that you do not specifically identify the assets and liabilities that make up the excess capital. Please confirm that the carrying value of each cash generating unit (CGU) includes only those assets that can be attributed directly, or allocated on a reasonable and consistent basis, to each CGU and provide a robust explanation of your asset allocation process. In this regard, clarify whether you are able to specifically identify the assets that remain in the Corporate Center after allocations (or conversely, whether you are able to specifically identify which assets have been allocated out to the CGUs). If not, please tell us how you concluded that you met the criteria in paragraphs 76 of IAS 36. UBS AG Form 20-F for the Fiscal Year Ended December 31, 2011 filed March 15, 2012 Forms 6-K filed July 31, 2012 and October 30, 2012 Response dated September 10, 2012 File No. 001-15060 28 February 2013 Page 4 of 22 As noted in the Capital Management section of our 2011 Form 20-F, equity is attributed to the businesses and the Corporate Center (“CC”) after considering their risk exposure, risk-weighted assets (“RWA”) usage, asset size, goodwill and intangible assets. Thus in order to attribute equity under the equity attribution framework (“EAF”), the assets of each segment (or cash-generating unit (“CGU”)) and the CC are identified. Because we identify the assets attributable to each CGU and the CC, we can confirm that the carrying amount of each respective CGU and the CC includes only those assets that can be attributed directly or allocated on a reasonable and consistent basis to it. We attribute assets directly to the CGUs and the CC based on the way assets are managed internally, meaning that assets are attributed to the business division (or the CC) that is responsible for managing them and their performance. Hence, that approach is aligned with our segment reporting pursuant to IFRS 8 Operating Segments as most recently disclosed in our fourth quarter 2012 report on Form 6-K (“the Q4 2012 Form 6-K”). As we can identify the assets in the CC, for the purpose of our goodwill impairment testing, we evaluate them to determine whether they represent corporate assets, as described in IAS 36.100-101. Corporate assets in the CC are identified and allocated to the CGUs on a reasonable and consistent basis. Allocated corporate assets consist of property and equipment, which have been allocated based on actual rates of usage incurred by each CGU. Other assets in the CC are not deemed to represent corporate assets because they generate cash flows independently of the other CGUs and thus are not allocated (e.g. our multi-currency portfolio of unencumbered, high quality, short-term financial assets that are managed by Group Treasury). The Legacy Portfolio financial assets in CC also are not allocated for that same reason.1 As a result of the process described above, we are able to specifically identify the assets that remain in the CC after allocations. We believe that our attribution and allocation methodology results in an appropriate basis for determining the carrying amount of each CGU in accordance with IAS 36.76–79. Comment 4 Furthermore, to the extent that you do not identify the specific assets and liabilities directly attributed to each CGU, please tell us how you are able to estimate the cash flows from such CGUs. In your response, please address why you believe your methodology complies with the guidance in paragraph 77 of IAS 36. As explained in our response to Comment 3, we are able to identify the specific assets for each CGU. Thus we have the requisite information to determine that our attribution and allocation methodology results in an appropriate basis for determining both the recoverable amount and the carrying amount of our CGUs. Hence, we believe that our methodology complies with the guidance in IAS 36.77. Comment 5 In your response dated September 16, 2011 you noted that one potential shortfall of the equity attribution framework was that the attribution process will not always result in aggregated attributed equity at the segment level being the same as equity attributed to your shareholders. You further recognized that adjustments would need to be made to ensure that the carrying amount for purposes of the goodwill impairment test was not less than the equity attributable to shareholders and therefore the net carrying amount of your assets and liabilities, which you believed was consistent with the premise and requirements of paragraphs 76-79 of IAS 36. Please tell us how your current equity attribution framework, including how it is used in determining the carrying value of your CGUs for purposes of goodwill impairment testing is consistent with your prior response. 1 The Legacy Portfolio was transferred to CC before the end of 2011; its assets consist of financial instruments. UBS AG Form 20-F for the Fiscal Year Ended December 31, 2011 filed March 15, 2012 Forms 6-K filed July 31, 2012 and October 30, 2012 Response dated September 10, 2012 File No. 001-15060 28 February 2013 Page 5 of 22 Please also refer to our response to Comment 3, where we outline our attribution and allocation methodology which results in an appropriate basis for determining the carrying amount of each CGU in accordance with IAS 36.76–79. The following table