Digital Progress: Canada

Canadian Bail-in Regulations: Jurisdictional Comparison Best in class approach K Instrument type Opco senior Holdco senior Holdco senior¹ Holdco senior Opco non- preferred senior Ranking in Liquidation Pari passu with deposits and other senior liabilities Structural subordination² Structural subordination² Structural subordination² Contractual subordination² Senior Deposits Other senior liabilities debt subject to Subordination schematic bail-in Depositor preference Participation in equity post resolution Acceleration rights upon failure to pay principal and interest Capital Deposits Opco senior / senior preferred / other senior liabilities Holdco senior / senior non-preferred Capital No Yes Yes Yes Yes Conversion to equity of the bank or an affiliate allows participation in the upside, if any³ N/A4 Uncertain given possibility of writedown Uncertain given possibility of writedown Uncertain given possibility of writedown Yes Yes Yes Yes No 5 1Applicable in practice for G-SIBs' issuance of non-capital bail-in debt; 2 Approach applicable to G-SIBS in relevant jurisdictions. Additionally, Switzerland uses structural subordination, Germany uses statutory subordination, Spain uses contractual subordination; 3 Assuming only bail-in is triggered. If other resolution powers are exercised, debt holders could be exposed to losses in a manner similar to a write-down of their claims; 4 No bail-in power. In resolution, debtholders could potentially receive partial recoveries (analogous to a write-down) or have their claims satisfied through the issuance of new securities (analogous to a bail-in conversion); 5 The terms of senior non-preferred do not include acceleration rights upon failure to pay principal and interest; however, there is no statutory restriction in this regard. Once resolution proceedings are underway, holders may declare an event of default for failure to meet payment obligations 77

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