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P.

76

2018 Pillar 3 Disclosures

Annex

classifications: countries, ratings, sectors, economic

groups, etc.

For the management of concentration risk, prudent

criteria are applied so as to be able to manage the

limits available with sufficient leeway with regard to the

legal concentration limits established.

As for the level of sector concentration, this is the

consequence of Cecabank’s specialisation in the

execution of all manner of activities, operations and

services inherent in the banking business in general, or

directly or indirectly associated with this. As a result,

financial sector risks account for around 56.3% of overall

exposure, although in the assessment of this degree of

sector concentration it must be borne in mind that the

exposure is maintained within a highly regulated and

supervised sector.

Contractual netting and financial guarantee

contracts or “collateral”

The general policy regarding trading of financial

derivatives, and repo, sell/buy-back and securities

lending operations is to sign netting agreements

prepared by national or international associations.

In the event of a breach by the counterparty, these

contracts allow for the foreclosure of the operations

covered by them and offsetting, which means that the

parties will only be able to demand the net balance of

the product of the settlement of such operations.

For financial derivatives, ISDA Master Agreements are

formalised, subject to UK law or that of the State of New

York, or otherwise the CMOF Master Agreement, subject to

Spanish law, depending on the counterparty. Meanwhile,

for hedging derivative financial instruments beyond a

certain risk level, financial guarantee agreements are

formalised, namely the Credit Support Annex for the ISDA

Master Agreements and Annex III for CMOF.

In the case of repo and sell/buy-back operations, the

Global Master Repurchase Agreements (GMRA) are

signed, while for securities lending, the European

Master Agreement (EMA) or the Global Master Securities

Lending Agreements (GMSLA) are formalised. In this

type of contractual netting agreement, the clauses

incorporate the regulation of the financial guarantees or

“margins” for the operations.

At present, most collateral (to be handed over or

received) in derivatives takes the form of cash, although

market practices are demonstrating that non-cash

collateral usage is increasing, a trend which Cecabank

is taking into consideration in its active collateral

management.

Credit risk exposure in accordance with

the credit ratings

At 31 December 2018, some 81.3% of exposure

(without taking into consideration investments in

the public sector, nor central counterparties (CCP)

with direct or indirect access) has been given a

rating granted by one of the credit rating agencies

recognised by the Bank of Spain.

The distribution by rating level of the rated exposure

is as follows:

Level

Rating

Percentage

1

AAA-AA

9.8%

2

A

24.3%

3

BBB

55%

4

BB

10.4%

5

B

0.5%

6

CCC and lower

0.0%

Total

100%

2. Risks associated with

the trading book

The General Risk Management Framework approved by

the Board, implementing the Risk Tolerance Framework,

contains the policies regarding the assumption and

management of market risk.

Market risk management objectives, policies

and processes

Market risk is defined as the risk affecting results

or capital and resulting from adverse movements

in the prices of bonds, securities, commodities and

exchange rates in operations registered in the trading

book. This risk arises from market-making activities,

trading, adoption of positions in bonds, securities,

currencies, commodities and derivatives (based on

bonds, securities, currencies and commodities). This

risk includes foreign currency risk, defined as the

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