Wholesale Banking - Positioned for Growth
Additional Tier 1 Capital
▪ Credit hierarchy is codified as a principle in regulatory and legislative documents in Canada
■ If a deposit-taking bank reaches the point of non-viability, OSFI's capital guidelines require Additional Tier 1 and Tier 2 capital
instruments to be converted into common shares in a manner that respects the hierarchy of claims in liquidation
■ Such a conversion ensures that Additional Tier 1 and Tier 2 holders are entitled to a more favorable economic outcome than
existing common shareholders
Recently, OSFI issued the following statement illustrating regulatory intent of the resolution regime in Canada:
If a deposit-taking bank reaches the point of non-viability, OSFI's capital guidelines require Additional Tier 1 and Tier 2 capital
instruments to be converted into common shares in a manner that respects the hierarchy of claims in liquidation. This results in
significant dilution to existing common shareholders. Such a conversion ensures that Additional Tier 1 and Tier 2 holders are
entitled to a more favorable economic outcome than existing common shareholders who would be the first to suffer losses¹.
AT1 Loss absorption jurisdictional comparison²
Jurisdiction
Canada
Switzerland
EU
UK
US
Regulator
OSFI
FINMA
SRB
Loss
NVCC
Trigger Event
CET1 Trigger Event & Non-
Viability Event
CET1 Trigger Event
Bank of England
CET1 Trigger
Event
FDIC
absorption
trigger
CET1 trigger
Point of non-
viability
trigger
Discretionary
Cancellation
of Interest
Loss
absorption
mechanism
Contractual at PONV, at regulator's
discretion Statutory bail in
regulations
provide that NVCC instruments
should be converted ahead of or at
the same time as bail in liabilities
Yes
For LRCN, full discretion to trigger
delivery of preferred shares in lieu
of interest payments
Conversion
7% high trigger
5.125% low trigger
Contractual at PONV, at
regulator's discretion
Statutory regulations provide
for write down / conversion,
before or together with
resolution power
Yes
(+ dividend stopper)
Conversion or permanent
write-down
5.125% / 7%
differs by jurisdiction
Statutory at PONV,
before or
together with
resolution power
Yes
7%
Statutory at
PONV, before or
together with
resolution power
Conversion or
temporary write-
down
Conversion
TD
Australia
APRA
CET1 & Non
Viability Trigger
Event
5.125%
Statutory, at
Contractual at
regulator's
discretion
PONV, at
regulator's
discretion
Yes
Yes
Yes
(+ dividend stopper)
(+ dividend stopper)
Permanent write-
down
Conversion
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