1 China s Surging Local Government Debt and the Measures Being Taken to Contain It Prospects for public-private partnership (PPP) a new countermeasure aimed at tackling the problem Yongyu Shao, Ph.D. and Economist China Business Promotion Division Mizuho Bank, Ltd. 1. Introduction The European sovereign debt crisis that commenced in 21 just as the global economy was showing signs of a modest recovery from the global financial crisis of 28 is continuing to cast dark shadows over the European Union s future in the form of the Greek debt crisis, whilst the mounting fiscal deficits of Japan, the U.S. and other major industrialized governments show no signs of improvement. China, which implemented one of the largest stimulus packages of any country (in the form of an RMB 4 trillion fiscal investment package), is becoming a cause for concern due to the state of its public finances and its mounting local government debt, and there are calls for the central government to furnish a full account and to provide details of the measures that are being taken to resolve the problem. China s increasing scale of government debt is evidenced in Table 1, which summarizes the audit findings published by the National Audit Office of the People s Republic of China (which is the Chinese equivalent of the Board of Audit of Japan) (and put government debt at around RMB 3.27 trillion as of June 213, or 5% of GDP). Of this, it is local government debt (accounting for approximately RMB 17.9 trillion or 6% of the total) that is the focus of most attention. Moreover, according to the latest report from the Chinese Academy of Social Sciences, China s government debt in fact exceeds this level 1. Fig. 1 shows the increasing scale of local government debt over time, and points to a rapid surge in the debt pile beginning in 29 when local governments commenced large-scale public spending. Date Table 1: Change in scale of China s government-related debt burden (1 million RMB) Debt category Government category Direct government debt (Category I) Governmentbacked debt (Category II) Other governmentrelated debt (Category III) Total (for the three categories of government debt) End of 21 Local governments 67,11 23,37 16,696 17,175 Central government 94,377 2,836 21, ,834 End of 212 Local governments 96,282 24,871 37,75 158,858 Total 19,659 27,77 59, ,692 Central government 98,129 2,61 23, ,841 End of June Local governments 18,859 26,656 43, , Total 26,989 29,256 66,55 32,75 Source: Compiled from the audit reports of Chinese government debt for 211 and 213 published by the National Audit Office of the People s Republic of China. 1 A July 27, 215 article in the China Business ews, announced the publication of Balance Sheet of China 215: Leverage Adjustment and Risk Management by the Institute of Finance and Banking, Chinese Academy of Social Sciences, which puts the total debt pile of local governments at RMB 3.28 trillion at the end of 214, against total assets at RMB 18.2 trillion and net assets at RMB trillion.
2 Fig. 1: Outstanding local government debt & year-on-year growth rates (trillion RMB) Outstanding debt at year end YOY 7% 6% 5% % 3% 2% 1% % Source: Compiled from the China Economic Yearbook 214, edited by the China Economic Yearbook Committee of the Development Research Center of the State Council of the People s Republic of China and the audit reports for 211 and 213 by the National Audit Office of the People s Republic of China. Year-on-year growth rates are calculated values. Outstanding debt figures are for year-end through 212 and for the end of June 213. This article examines the current state of China s local government debt as revealed by central government research findings, clarifies the role and function of local government financing vehicles (LGFV) 2 in the mechanisms underpinning its expansion, looks at the impact of central government moves to tackle the problem and the challenges it faces, and examines the prospects for the PPP model that is being actively promoted by Beijing. 2. Current status of surging local government debt and the mechanisms As Fig. 2 suggests, China s local governments appear to be largely dependent on the revenue from land transfers within the region, but this is the case as from 2. This is largely attributable to rising demand for land on the back of expanding urbanization and the surge in land prices that has accompanied growth in China s real estate market, both of which commenced around 2, but the fact that local governments depend on the revenue from land transfers for upwards of 5% of their budgetary needs is evidence of land-based financing, and this has led to land resource shortages and political corruption surrounding land management and sales and is clearly unsustainable and problematic. It has been reported that local government revenue from land transfers dropped by more than 4% in the first five months of this year. 2 Local Government Financing Vehicles (LGFVs), the investment entities or platforms set up by local governments to raise funds, are integral to the surge in local government debt. China s local governments not only face chronic funding shortages but are, in principle and in an effort to maintain fiscal discipline, banned from issuing municipal bonds, thus the creation and operation of LGFVs to take out loans and issue bonds provided a means of procuring the funds necessary for local government finance.
3 Fig. 2: China s local government revenue sources and the degree of dependence on land transfers 8, 7, 6, 5, 4, 3, 2, 1, Revenue from land transfers (1 million RMB) Revenue from land transfers Local government revenues Dependence on land transfers as source of revenue 9% 8% 7% 6% 5% 4% 3% 2% 1% Dependence on land transfers as source of local government revenue % Source: Compiled from the Ministry of Land and Resources and the Ministry of Finance statistics. Figures for the degree of dependence on land transfer revenue (revenue from land transfers local government revenue %) are calculated values. Local governments need to issue bonds to plug their budgetary shortfalls and supplement the various tax revenues available, and a multitude of local investment companies were established for this purpose beginning in the late 199s, but the global financial crisis of 28 triggered a surge of LGFV activity with these entities taking on the role of government financing and investment for China s local governments (Fig. 3). Fig. 3: Structure of local government debt in China (LGFV roles) 地 Local 方 政 governments 府 Security/ guarantee Gain on sale of land Business licenses 出 Investment/ 資 設 立 establishment Supplement credit Supplement funds for repayment Project companies (LGFV) Public investment Financing Trust funds Urban construction investment bonds Banks Source: Excerpted and altered from FUJITA Hironori, China s Government Debt Problem: The Challenges and Prospects for China s Government Presented by its Hidden Debt (in Japanese), Mizuho Industry Focus, Volume 134. Table 2 is compiled on the basis of the audit results of Chinese government debt published by the National Audit Office at the end of 213. This breakdown gives an overview of the structure of local government debt in China (at the provincial, municipal, prefectural and township levels). As of the end of June 213, China had a local government debt burden (for all three debt categories) amounting to approximately RMB 17.9 trillion, details of which are given by government, borrower, fund use, and
4 financing channel. Broadly speaking, municipal and prefectural governments have a high percentage of direct debt (Category I debt), whilst for provincial governments the percentages of government-backed debt (Category II debt) and other government-related debt (Category III debt) are high. By borrower, LGFVs are the main borrower across all three debt categories, accounting for 39% of the total, followed by local government departments and organizations. In other words, LGFVs are central players in China s local government debt and are the biggest debtors. The implementation by the central government of a massive RMB 4 trillion in fiscal investment beginning in 29 triggered the establishment of numerous LGFVs, which were used by local governments to develop various public investment projects, including urban infrastructure construction, transport, and social housing. Many LGFVs were also called upon to seize and/or stockpile land for future construction and development (see Table 2). With this breakdown of the increasing scale of local government debt revealing LGFVs to be key players, the National Audit Office concentrated on these entities in their detailed debt audit of 213. However, these LGFVs have monumental administrative functions and number in the thousands, making it difficult to obtain a comprehensive picture of their current activities. Table 2: A Breakdown of China s local government debt (as of the end of June 213) Government debt category By government By borrower By fund use By financing channel Government debt type Direct government debt (Category I) Governmentbacked debt (Category II) Other governmentrelated debt (Category III) Total for the three categories Totals for each government debt (1 million RMB) 18,859 26,656 43, ,99 Province 16.3% 58.6% 42.7% 29.% City 44.5% 27.9% 39.3% 4.7% Prefecture 36.4% 13.1% 17.% 28.2% Township 2.8%.4% 1.1% 2.% Total 1.% 1.% 1.% 1.% Local government financing vehicles (LGFVs) 37.4% 33.1% 46.4% 39.% Local government departments, organizations 28.4% 36.3%.% 22.7% Expense subsidy project units 16.3% 3.9% 11.9% 13.4% State-owned enterprises (wholly-owned & limited by shares) 1.6% 21.6% 32.4% 17.5% Self-financed, self-supporting project units 3.2% 1.4% 5.% 3.4% Public works units 1.1%.5% 4.4% 1.8% Other units 2.9% 3.1%.% 2.2% Total 1.% 1.% 1.% 1.% Urban infrastructure construction 34.8% 19.8% 34.2% 32.4% Land seizure, stockpiling 15.5% 4.% 1.9% 1.5% Transport infrastructure 12.8% 49.5% 31.8% 22.9% Social housing 6.3% 5.3% 6.2% 6.1% Education, science, culture and hygiene 4.5% 2.8% 9.4% 5.4% Agriculture, forestry and fisheries construction 3.8% 2.2% 1.8% 3.% Ecology, environmental conservation 3.% 1.6% 2.% 2.5% Industry, energy 1.1% 3.%.6% 1.3% Other 11.2% 7.9% 5.9% 9.4% Unused 7.% 3.8% 6.2% 6.4% Total 1.% 1.% 1.% 1.% Bank loans 5.8% 71.6% 61.9% 56.6% Build-transfer 11.2% 1.7% 5.% 8.3% Bond issue 1.7% 6.3% 11.8% 1.3% Outstanding funds 7.1%.3% 1.6% 4.8% Trust finance 7.% 9.5% 9.5% 8.% Loans (commercial & personal) 6.1% 2.1% 2.7% 4.7% Other 7.1% 8.5% 7.6% 7.4% Total 1.% 1.% 1.% 1.% Source: Compiled and computed from the audit results of Chinese government debt published by the National Audit Office of the People s Republic of China as of December 3, 213.
5 A look at local government debt sources (i.e., financing channels) finds banks to be the biggest financers, accounting for some 5% to 6%, followed by tenders and bond issue, whilst loans from corporations and individuals account for 7% to 8% level of the total. As this demonstrates, China s local governments have used LGFVs acting on their behalf as official organizations to accumulate debt whilst initiating various urban development projects, but this has, of necessity, led to the rise of problematic shadow banking finance channels. Fig. 4 plots the current debt levels of China s various regional governments. It shows the cumulative debts of 3 regional governments (excluding the Tibetan Autonomous Region) as of the end of June 213, revealing considerable disparity in the levels of debt but pointing to higher debt-to-gdp ratios in China s interior provinces and autonomous regions (local government debt has reached 8% level of GDP in Guizhou Province, with the city of Chongqing having the second highest level of debt). This is corroborated by Fig. 5, which not only finds an extremely strong positive correlation between regional GDP scale and outstanding local government debt (r =.7921), but also reveals a similarly strong positive correlation between the number of LGFVs in a particular region and its outstanding debt (r =.7782; omitted from Fig. 5). This bears testimony to the massive financing demands that are imposed by the necessity of fostering ongoing urban development and economic growth, and to the essential role that is played by LGFVs in local government finance. Fig. 4: A comparison of GDP-to-outstanding government debt ratios in regional China (213) Regional GDP and government debt (1 million RMB) 7, 6, 5, 4, 3, 2, GDP Total government debt GDP-to-government debt ratio GDP-to-government debt ratio 9% 8% 7% 6% 5% 4% 3% 2% 1, 1% Jiangsu Guangdong Sichuan Shanghai Hunan Hubei Liaoning Beijing Hebei Chongqing Shandong Zhejiang Guizhou Source: Compiled from National Bureau of Statistics and official local government figures. The GDP-to-government debt ratios are calculated values. Shaanxi Yunnan Henan Anhui Tianjin Fujian Inner Mongolia Guangxi Jilin Shanxi Jiangxi Heilongjiang Gansu Xinjiang Hainan Qinghai Ningxia %
6 Fig. 5: Local government debt as measured on a GDP scale in regional China (213) 16, 14, 12, 1, 8, 6, 4, Local government debt (1 million RMB) Shanghai Sichuan Chongqing Liaoning Hebei Beijing Hubei Shaanxi Anhui Fujian y =.149x R 2 =.6275 r =.7921 Henan Zhejiang Shandong Jiangsu Guangdong 2, Regional GDP (1 million RMB) 1, 2, 3, 4, 5, 6, 7, Source: Compiled from National Bureau of Statistics and official local government figures. 3. Factors underpinning the growing local government debt burden and the negative impact Whilst the expansion in China s local government debt pile has no single cause, it is principally the result of the pursuit of development and growth at all costs (combined with ubiquitous financial engineering), and of the system used by China to finance central and local governments. The tax sharing system 3 introduced in 1994 led to major changes in the structure of central and local government tax receipts, producing a long-term bias toward the central government in terms of fiscal power (i.e., greater revenue), whilst local government expenditure obligations increased exponentially. This is clearly evidenced by the data presented in Fig. 6 and Fig. 7. The standardization of fiscal revenues that commenced in 1994 meant that local government revenues were consistently lower than the central government revenue up until 21, though this trend has become inverted in recent years with local government revenues now topping 5%. A look at expenditure obligations, however, reveals a rapid expansion in local government expenditure, against a gradual easing in central government responsibilities, with central government expenditure running at less than 15% in recent years. 3 China s tax sharing system was introduced as part of tax system reforms aimed at ensuring tax collection and securing revenue, and is of critical importance to any consideration of central and local government revenue. The tax sharing system categorized revenue by item and taxpayer and assigned the levying of taxation and allocation of revenue to either the central government or local governments, which led to the separation of revenue sources into central government taxes, local government taxes and shared taxes, and brought individual tax items under the respective jurisdiction of the State Administration of Taxation and local tax bureaus.
7 Fig. 6: Transitions in central and local government revenues in China 8, 9% 7, 6, 5, 4, 3, 2, 1, Central and local government revenues (1 million RMB) Central government revenue Ratio of central government revenue Local government revenue Ratio of local government revenue Central and local government revenues as a percentage of total fiscal revenue 8% 7% 6% 5% 4% 3% 2% 1% % Source: Compiled from the China Statistical Yearbook 214 and Ministry of Finance data. Fig. 7: Transitions in central and local governments expenditure in China 16, 14, 12, 1, Fiscal expenditure (1 million RMB) Local government expenditure Central government expenditure Ratio of central government expenditure Ratio of local government expenditure 1% 9% 8% 7% 6% Ratio of total 8, 5% 6, 4% 4, 3% 2% 2, 1% % Source: Compiled from the China Statistical Yearbook 214 and Ministry of Finance data. Ratios are calculated figures. The fact that three-quarters of the RMB 4 trillion in investment that was undertaken between 29 and 21 to counter the effects of the global financial crisis was covered by local government investment is due to this imbalance in central and local government revenue and expenditure. China s massive public spending drive was welcomed and acclaimed by governments the world over, but it also had negative
8 outcomes in the shape of stockpiles of industrial equipment and massive local government debt. Moreover, the negative impact of China s mounting local government debt pile is not only hobbling recent measures to stimulate the economy, it will become increasingly apparent as these debts come due and there are fears that the fiscal burden on local governments will skyrocket as a result. As Fig. 8 demonstrates, local government debt repayments are expected to peak in 218 onwards, with repayment levels for all debt categories forecast to escalate (topping 4% of the total) in the near future with a corresponding increase in credit risk (i.e., the risk of default). Fig. 8: China s local government debt repayments by fiscal year 6, 5, 4, 3, 2, 1, Repayments for the three debt categories (1 million RMB) Direct government debt (Category I) Government-backed debt (Category II) Other government-related debt (Category III) Ratio of category I debt Ratio of category II debt Ratio of category III debt Repayment ratios for the three debt categories 5% 4% 3% 2% 1% onwards Source: As for Table 2, compiled from the audit results of Chinese government debt published by the National Audit Office of the People s Republic of China as of December 3, 213. The ratios given for Category II and Category III debt are calculated figures. % 4. The role of the public-private partnership model and its prospects as a new solution to China s local government debt woes As discussed above, there is a sense of impending crisis in central government over the escalating pile of local government debt, and various new measures are being introduced in an attempt to tackle the problem. A system designed to straighten out the LGFVs was put into place several years ago, though there has been no significant reduction in LGFV numbers, which had risen to as many as 1, nationwide in 21 (as compared to the 7,17 recorded in the National Audit Office s 213 audit), and little headway has been made with efforts to control borrowing and curb bond issue 4. Since the beginning of 214, major departments of the State Council have issued some ten regulatory documents in a show of their determination to tackle the problem of local government debt. Among these, in line with the basic 4 In the past, LGFVs issued large volumes of urban construction investment bonds to fund urban infrastructure development, but the emergence of shadow banking issues imposed further constraints on regional finances and sparked a sharp increase in issues of such urban construction investment bonds, with redemptions surging to RMB 4.95 trillion by the end of 214 (which saw the largest issue of such bonds to date) (National Institute of Financial Research, Tsinghua University, Research Report Vol , China s Great Debt Wall: An Analysis on Credit Spreads of Local Government Debt in Chinese, April 3, 215).
9 policy of the Opinions of the State Council on Strengthening the Administration of Local Government Debt (September 214) and Methods for the Consolidation and Handling of Outstanding Local Government Debt (October 214) issued by the Ministry of Finance, measures to resolve the local government debt problem have been clearly specified. In addition, regional (provincial and municipal, etc.) government authorities throughout China have subsequently unveiled a succession of measures aimed at strengthening the handling of local government debt. Some local governments have proposed bond issue and debt replacement (refinancing) as a solution to the problem, whilst others are pushing for a change in the way in which LGFVs are managed. Whilst debt amortization and new bond issues can be expected to yield certain results, however, China s local governments remain unable to meet the massive demand for funding created by the need to maintain economic growth and promote the National New-Type Urbanization Plan. Further reforms to the tax system thus need to be introduced to make up for this shortfall in fiscal resources, and efforts to rationalize/streamline the distribution of tax revenues between central and local governments and introduce private-sector or external funding are coming to the fore. Among these, public-private partnerships (PPP) are gaining recognition as a new method of tackling the problem (Fig. 9), and with the September 23, 214 release by the Ministry of Finance of the Circular on Promoting Government-Social Capital Cooperation, there has been a surge of interest in the PPP model as a means of financing a wide range of projects. This model is also being looked into as a means of easing regional financing difficulties and of curbing local government debt. In addition to the list of 3 PPP model projects that was unveiled by the Ministry of Finance in November 214 (Table 3), in May this year, the National Development and Reform Commission released a list of 1,43 region-specific recommended PPP projects (with community, public services, transport infrastructure accounting for nearly 8% of a total proposed investment budget of RMB 1.97 trillion; Fig. 1) by region (projects located in China s central and western hinterlands, including Anhui, Guizhou, Gansu being given priority), both of which have received widespread attention. Fig. 9: A general schematic for PPP-financed investment projects Government department Policy support Subsidy assistance PPP-financed project Investment Operation & management Private investor Source: A simplified version of the PPP schematic in reference to official Chinese government materials. An opinion piece published in the May 25, 215 edition of the Caijing Magazine (edition No. 431) argues that some RMB 1.5 to 2 trillion will be needed in PPP financing to make up the shortfall of approximately RMB 2.2 trillion in funding for regional infrastructure development created by measures to strengthen the administration of local government debt and reductions in land transfer revenues (which are forecast to drop by approximately one-third this year). However, forecasts put PPP finance at a mere 1% of the total funding requirements of the projects currently being put forward by the government, and there can be little doubt that China has a long way to go in its efforts to promote the PPP model of financing for government-backed infrastructure projects and as a means of easing local government debt.
10 Table 3: List of PPP model projects published by the Ministry of Finance ( ovember 3, 214) Project name Province/ City Status Sector 1 Public charging station network project for new energy vehicles Tianjin New New energy vehicles 2 Centralized heating supply project for Qiaoxi District, Zhangjiakou Hebei Existing Heating supply 3 Comprehensive pipe network project for Zhengdong New Underground pipe Hebei Existing District, Shijiazhuang network 4 plant project for Sanbaotun, Fushun Liaoning Existing 5 Jilin 6th waterworks construction project (Phase I) Jilin Existing Water supply No. 6 Jilin Thermal Power Station heat source remodeling work project Jilin Existing Heating supply 7 Phase I wastewater plant construction project, Jiading Nanxiang Shanghai New 8 Kunshan Hyundai railway project Jiangsu New Rail transit 9 Xuzhou Luoma Lake Wetland and raw water pipeline project Jiangsu Existing Nanjing Chengdong wastewater plant and Xianlin wastewater plant project project for Suqian Ecological Chemical Science and Technology Industry Park Phase I and Phase II wastewater improvement work and Phase III extension work for Rugao Jiangsu Jiangsu Jiangsu Existing Existing Existing Water supply 13 Nanjing garbage disposal facility project Jiangsu Existing Garbage disposal 14 Xuzhou urban rail transit Line 1 Phase I construction project Jiangsu Existing Rail transit 15 Suzhou rail transit Line 1 construction project Jiangsu Existing Rail transit 16 Rudong County hospital reconstruction project Jiangsu Existing Healthcare 17 Hangzhou subway Line 5 Phase I and Line 6 Phase I project Zhejiang Existing Rail transit 18 Hangzhou-Haining urban light rail transit project Zhejiang Existing Rail transit 19 Chizhou wastewater and municipal government drainage procurement services Anhui 2 Eastern Maanshan wastewater plant Anhui Existing 21 Anqing urban wastewater project Anhui Existing New 22 Hefei rail transit Line 2 Anhui Existing Rail transit 23 Dongshan County water diversion engineering project (secondary water source) Fujian Existing 24 Jiujiang Zhelinhu Lake ecology conservation project Jiangxi New 25 Phase I Jiaozhou Bay seabed tunnel project Qingdao Existing 26 Qingdao physical education center project Qingdao Existing Phase I wastewater works project for Xiangtan High-Tech Industrial Development Zone Chongqing rail transit Line 3 project (including Phase I and Phase II works and construction of the southern extension) Hunan New Water supply Environment management Traffic maintenance Educational Chongqing Existing Rail transit 29 Phase II Nanming River water environment maintenance project Guizhou New Environment management 3 Weinan Main Urban District urban central heating project Shanxi New Heating supply Source: Compiled from the Ministry of Finance website.
11 Fig. 1: Geographical distribution and sectors involved in PPP projects published by the ational Development and Reform Commission (major government departments) 14 No. of projects No. of projects Ratio Ratio 14% 12 1 Water 6% Environmental projects 11% Other 5% Community 36% 12% 1% 8 6 Transport infrastructure 17% 8% 6% 4 Public services 25% [Insert] Breakdown of the 1,43 official government projects by sector 4% 2 2% Xizang Shenzhen Dalian XPCC Hebei Guangxi Qingdao Chongqing Hainan Guangdong Heilongjiang Fujian Liaoning Beijing Jilin Zhejiang Ningxia Sichuan Shaanxi Inner Mongolia Xinjiang Qinghai Jiangxi Yunnan Gansu Shandong Guizhou Jiangsu Anhui Source: Both the main figure and its insert are compiled from data published on the National Development and Reform Commission website. % Widely adopted in Europe and the U.S. in the late 199s, the PPP model involves partnerships between a government or government department and a private-sector company on public works projects, and is a method that has been used by the Chinese government in the past. Aside from enabling the allocation of public utility funds, the PPP framework means that the operation and maintenance of newly built infrastructure can be outsourced to the private sector efficiently and rationally, allowing private-sector companies and entities not only to participate in investment in government-backed projects but also to benefit from future operation and management arrangements. The PPP model thus offers a win-win situation for both government and the private sector. China still has limited PPP experience and, given the need for more work to ensure that the relevant systems are in place, that examples both domestic and foreign of best practice are available for reference, and that efforts are made to educate the various players on operational methods and to train specialized personnel, it would be unrealistic to expect the PPP framework to yield immediate results. The whole concept of regional finances and the financial system will need to be reformed in order for the PPP model to become usable, and China must avoid viewing this framework as an easy financing alternative to the existing LGFVs. Ongoing improvements to China s investment and loan system and efforts to enhance fiscal discipline remain essential.
12 China s budget deficit is increasing as a result of the slowdown in economic growth (Fig. 11). Given the current state of local government debt dealt with in this article and the figure given in Balance Sheet of China 215 by the Chinese Academy of Social Sciences (see footnote 1), which puts local government debt at RMB 56 trillion or 2% higher than its level in 213, the outlook is far from encouraging. There is now an incontrovertible need for efforts to promote the PPP model as an effective and sustainable means of financing and to strengthen the financial basis of local governments if China is to make steady headway with its New-Type Urbanization Plan, and hopes are high for forthcoming initiatives. Fig. 11: Long-term trends in government fiscal revenue and expenditure in China ( ) Fiscal revenue and expenditure (1 million RMB) 16, 14, 12, 1, 8, 6, Fiscal revenue Revenue growth rate Fiscal expenditure Expenditure growth rate Fiscal revenue and expenditure YOY (%) 4, 5 2, Source: Compiled from statistics published by the National Bureau of Statistics and the Ministry of Finance. Caution 1. Legal or accounting advice: The information included in this material does not contain any advice on respective professional advisors. 2. Confidentiality: The information included in this material is disclosed to you on the premise of your confidentiality obligation, and should be used for internal purposes only. Disclosure of the contents herein to a third party is prohibited. 3. Copyright: Copyright of the information included in this material belongs to the bank, in principle. You are prohibited to make a copy of, make a reproduction of, quote, reprint, translate, loan, or in any way exploit the content of this material in part or in whole, by any means, for any purpose, without our permission. 4. Indemnity: The information included in this material is obtained from various sources that the bank believes are reliable. However, the bank shall not guarantee its correctness, trustworthiness, or integrity. The bank shall also not be liable for any damage, whatsoever, arising from this information. 5. This publication is not deemed to constitute advice, solicitation or recommendation to sell financial assets. 6. This document is a translation of the Japanese original, and the original will take precedence in the event of any difference between the two versions.
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