Commonwealth Bank Impacts/ Changes to Operations Resulting from G20 Reform 31st August 2015/ Confidential

22 Discussion Points Commonwealth Bank of Australia Confidential Reporting – intraday or T+1 Reconciliation – with trade repository Collateral – portfolio and material terms recs, margin calls Clearing – Mandatory clearing via direct or by broker Maintenance of client information – correctly identifying clients

33 Jan 15FebMarAprMayJuneJulyAugSeptOctNovDecJan 16Feb United States Australia HK SG Europe CAN 2014/15 OTC Reform Regulation Project Impact Assessment Margin on Uncleared – IM margin Phase in from 1/12/15. VM required from 1/12/15 Substituted Compliance Expiry of Cross Border Relief on 1/12/15 Possible Part 45 & 46 Entity Implementation Mandatory Execution (SEF’s) – Ongoing timeline linked to clearing SEC Requirements – Quarterly De Minimus Calculations. Implementation dates TBC Central Clearing Interest Rates Q3/ Footnote 513: Relief expires 30/09/15 HKMA Consultation period Reporting : Expanded products and scope. Earliest May 2015 Mandatory Clearing & MTF’s for Rates & Credit Q3 / (TBC) No or Low impact for this project/ITMedium Business/IT Impact High Impact for Project, & IT Indicates uncertainty in Regulations and/or dates not finalised: Russia, China, Malaysia & Sth Africa & Japan are being monitored HKMA to set Mandatory Reporting dates Cam Margin on Uncleared Monitoring Other Canadian Provinces Volcker Rule – 21 July /02/15 Version Large Trader Reporting changes – Phased dates from 30/09/2014 to Changes to the trade reporting solution 30/04/2016 Commodity Position Limits & Aggregation – Date TBC Collateral Rpting (CBA date) Oct 2015 Items in solid colour indicates confirmed dates: ASIC Client Delegation Phase 3A Other Asset classes & 3B All Products 12 Oct 15 ASIC Reporting Exemption Expiry : Entity Identifiers, UTI pairing and sharing, Collateral, Entity Name, Lifecycle, ETD Reporting, unmasking 30 Sep 15 FX, Credit and Rates derivatives Reporting ‘Traded In’ & Additional Fields – 1 Nov FX Reporting Phase 1 ‘Booked in’ 1 May UTI Pair & Share – 1 Oct 2015 (counterparts to agree to UTI) USI/UTI Feb 2016 Client Delegation Phase 3A Credit & Rates 13 April 15 ASIC Legal Entity Name Exemption expiry (subject to TR capability)– 1 July 2015 Reporting Dead Trades 2016 FX Securities Conversion Transactions Exp 30 Sep 16 ASIC Client Delegation Phase 3A Backloading 19 Oct 15 Mandatory Clearing Q (TBC) Phase 3A commence collateral, barriers and valuations for FX, Commods and equities 2 May 16 Relief exp for Val Reporting of Cleared Trades (letter – 14-90) 30 Jun 15 ASIC Phase 2 Nexus Rpting – 24 Feb 15 Phase 3A commence rpting of collateral barriers & valuations for credits & rates 2 Nov 15 Phase 1d Entities Backloading for Credit & Rates Transactions 1 Apr 15 New Jurisdictional fields 27 March Reporting Deadline for Backloading 30 Apr Mandatory Clearing. Q (Date TBC). Final Regs & Determination June 2015 ASIC Margin on Uncleared : APRA consultation Q2/Q3

44 Highlights Commonwealth Bank of Australia Confidential -CBA cleared their first OTC trade via LCH in March CBA was the first Australian bank to clear an AUD swap via the ASX on the 10 Sept CBA has cleared over 10k OTC trades through different exchanges. -In June 2015 CBA participated in the biggest ever AUD swap compression with the London Clearing House – in terms of notional reductions – a total of $4.3 trillion. -CBA is reporting approximately 70k trades to different trade repositories.

55 Issues Commonwealth Bank of Australia Confidential -Needed to implement a number of tactical solutions to meet tight deadlines. -There were and still are a number of manual processes in place. -Increased resourcing required to handle new processes and extra workload. -Client maintenance issues, needed to ensure clients were flagged against correct jurisdictions within our product systems. -A number of product system changes required.

66 Questions Commonwealth Bank of Australia Confidential ?