Basel III Pillar 3 Regulatory Capital Disclosures

Transcription

1 Wells Fargo & Company Basel III Pillar 3 Regulatory Capital Disclosures For the quarter ended June 30, 2015

2 Table of Contents Disclosure Map... 3 Introduction... 5 Executive Summary... 5 Company Overview... 6 Basel III Overview... 6 Capital Requirements and Management Capital Summary...12 Credit Risk...14 Overview...14 Wholesale Credit Risk...15 Retail Credit Risk...16 Counterparty Credit Risk...18 Securitization Credit Risk Equity Investment Credit Risk Operational Risk...27 Market Risk Supplementary Leverage Ratio Glossary of Acronyms...31 ForwardLooking Statements

3 Any reference to Wells Fargo, the Company, we, our or us in this Report, means Wells Fargo & Company and Subsidiaries (consolidated). When we refer to the Parent, we mean Wells Fargo & Company. See the Glossary of Acronyms and Other Terms for the definition of terms used throughout this Report. This Report contains forwardlooking statements, which may include our current expectations and assumptions regarding our business, the economy, and other future conditions. Please see the ForwardLooking Statements section for more information, including factors that could cause our actual results to differ materially from our forwardlooking statements. Disclosure Map The table below shows where disclosures related to topics addressed in this Pillar 3 disclosure report can be found in our second quarter 2015 Form 10Q and our 2014 Form 10K. Pillar 3 Requirement Scope of Application/ Capital Structure & Capital Adequacy Pillar 3 Report page Description Second Quarter 2015 Form 10Q reference 2014 Form 10K reference 59 Overview Capital Management, Capital Management, Note 1 Risk Management Framework and Culture, Notes 1 and Capital Management and Structure 1213 Measurement of Capital Capital Planning and Stress Testing Capital Management, Risk Management Framework and Culture, Capital Planning and Stress Testing, Notes 18 and 19 Credit Risk: General Disclosures Credit Risk: Internal RatingsBased 1417 Credit Risk Management Overview 1415 Exposure types/ Impaired Loans and ALLL 1415 Industry and Geographic distribution 13 Risk Weighted Assets Credit Risk Management, Note 1 Notes 4, 5 and 12 Note 4, Tables 1, 8, 13, 14, 17, 22 and Credit Risk Management Table Credit Quality Overview Credit Risk Management, Asset/Liability Management, Note 1 Counterparty Credit Risk 18 Overview 1820 Counterparty Credit Risk Management/Collateral Note 12 Credit Risk Mitigation Guarantees and Credit Derivatives Securitization 2022 Objectives and Roles Equity Investments Noncovered Note 10 OffBalance Sheet Arrangements, Note Risk Management and Methodology 2425 Accounting, Valuation and Note 7 Current Period Activity 24 Assets Securitized and Resecuritized Note Policies and Practices Note 1 Note 1 26 Nonmarketable and Marketable Equity Investments 2426 Realized and Unrealized Gains/(Losses) Consolidated Statement of Income Operational Risk 2728 Operational Risk Operational Risk Management Operational Risk Management Market Risk 28 Market risk Market RiskTrading Activities, Market Risk Governance Risk Management Framework and Culture Interest Rate Risk for NonTrading Activities Supplementary Leverage Ratio Overview Interest Rate Risk Earnings Sensitivity Asset/Liability Management and Table Supplementary Leverage Ratio Capital Management 3

4 The tables below provide page references to our second quarter 2015 Form 10Q and our 2014 Form 10K for certain topics and financial information listed in the table on the previous page. Second Quarter 2015 Form 10Q Page reference Management's Discussion and Analysis Operational Risk Management 20 Credit Risk Management 2043 Asset/Liability Management 4457 Interest Rate Risk 44 Market RiskTrading Activities 4553 Market Risk Governance 52 Capital Management 5863 Capital Planning and Stress Testing 6263 Table 1 Average Balances, Yields and Rates Paid (TaxableEquivalent Basis) 6 Table 8 Maturities for Selected Commercial Loan Categories 17 Table 13 Commercial and Industrial Loans and Lease Financing by Industry 23 Table 14 CRE Loans by State and Property Type 24 Table 17 Real Estate 14 Family First and Junior Lien Mortgage Loans by State 28 Table 22 Junior Lien Mortgage Line and Loan and Senior Lien Mortgage Line Portfolios Payment Schedule 33 Table 28 Loans 90 Days or More Past Due and Still Accruing 39 Table 29 Net Chargeoffs 40 Table 33 Earnings Sensitivity Over 24 Month Horizon Relative to Most Likely Earnings Plan 45 ForwardLooking Statement 6667 Consolidated Statement of Income 69 Notes to Consolidated Financial Statements Note 1 Summary of Significant Accounting Policies 7576 Note 4 Investment Securities 7884 Note 5 Loans and Allowance for Credit Losses Note 7 Securitizations and Variable Interest Entities Note 10 Guarantees, Pledged Assets and Collateral Note 12 Derivatives Form 10K Management's Discussion and Analysis OffBalance Sheet Arrangements Operational Risk Management Credit Risk Management Risk Management Framework and Culture Asset/Liability Management Capital Management Capital Planning and Stress Testing Risk Factors Notes to Consolidated Financial Statements Page reference Note 1 Summary of Significant Accounting Policies Note 3 Cash, Loan and Dividend Restrictions 150 Note 14 Guarantees, Pledged Assets and Collateral Note 18 Preferred Stock Note 19 Common Stock and Stock Plans

5 Introduction Executive Summary The Pillar 3 disclosures included within this Report are required by the regulatory capital rules issued by the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (FRB)(collectively, the Agencies), and the Federal Deposit Insurance Corporation (FDIC), and are designed to comply with the rules and regulations associated with the capital adequacy framework, known as Basel III, which prescribed these disclosures under its Pillar 3 Market Discipline rules. These disclosures should be read in conjunction with our Quarterly Report on Form 10Q for the period ended June 30, 2015 (second quarter 2015 Form 10Q) and our Annual Report on Form 10K for the year ended December 31, 2014 (2014 Form 10K). The Pillar 3 disclosures provide qualitative and quantitative information about regulatory capital calculated in conformity with the transition provisions under the Advanced Approach for second quarter In March 2015, the Agencies announced that the Company and its subsidiary national banks may exit the parallel run phase and begin using and reporting under the Advanced Approach capital framework to determine riskbased capital requirements starting in second quarter At June 30, 2015, we calculated our common equity tier 1 (CET 1), tier 1 and total capital ratios in accordance with the Standardized and Advanced Approaches. The lower of each ratio calculated under the two approaches will be used in the assessment of our capital adequacy. The CET 1 and tier 1 capital ratios calculated in accordance with the Standardized Approach were lower than that calculated with the Advanced Approach, whereas the total capital ratio was lower under the Advanced Approach. Table 1 summarizes CET 1, tier 1, total capital, riskweighted assets (RWAs), and the respective capital ratios under the Advanced and Standardized Approaches with transition requirements at June 30, These ratios exceed minimum fully phasedin ratios, inclusive of a 2% buffer applicable to us given our designation as a global systemically important bank (GSIB) under domestic rules, of 9.0%, 10.5%, and 12.5% for CET 1, tier 1, and total capital ratios, respectively. T able 1: Capital Com ponents and Ratios Under Basel III (T ransition Requirem ents) June 30, 2015 (in millions) Advanced Standardized Approach Approach Common Equity Tier 1 Capital 140, ,860 Tier 1 Capital 160, ,405 Total Capital 187, ,988 RiskWeighted Assets 1,297,080 1,306,132 Common Equity Tier 1 Capital Ratio 10.86% 10.78% * Tier 1 Capital Ratio 12.37% 12.28% * Total Capital Ratio 14.45% * 15.16% * Denotes the lowest capital ratio determined under the Basel III Advanced and Standardized Approaches In addition, under supplementary leverage ratio (SLR) requirements, which require disclosure beginning in 2015, the Company s estimated SLR was 7.8% at June 30, 2015, assuming full phasein of the Advanced Approach capital framework. The SLR rule, which becomes effective on January 1, 2018, will require a covered bank holding company to maintain a minimum SLR of at least 5% to avoid restrictions on capital distributions and discretionary bonus payments. The rule will also require that all of our insured depository institutions maintain a SLR of at least 6% in order to be considered well capitalized under applicable regulatory capital adequacy guidelines. Based on our review, our current leverage levels would exceed the applicable requirements for each of our insured institutions. 5

6 Company Overview Wells Fargo & Company is a nationwide, diversified, communitybased financial services company with $1.7 trillion in assets. Founded in 1852 and headquartered in San Francisco, we provide banking, insurance, investments, mortgage, and consumer and commercial finance through 8,700 locations, 12,800 ATMs, the internet (wellsfargo.com) and mobile banking, and we have offices in 36 countries to support customers who conduct business in the global economy. With approximately 266,000 active, fulltime equivalent team members, we serve one in three households in the United States and are ranked No. 30 on Fortune s 2015 rankings of America s largest corporations. We ranked fourth in assets and first in the market value of our common stock among all U.S. banks at June 30, As a financial institution, Wells Fargo must manage a variety of business risks that can significantly affect our financial performance. Among the key risks that we manage are, credit, operational, and asset/liability management risks, which include interest rate, market, liquidity, and funding risks. Our risk culture is strongly rooted in our Vision and Values, and in order to achieve our vision of satisfying all our customers financial needs and helping them succeed financially, our business practices and operating model must support prudent risk management practices. A discussion of our risk management framework and culture is provided in the Risk Management Framework and Culture section in Management s Discussion and Analysis to our 2014 Form 10K and is applicable to our management of the credit, operational, and asset/liability management risks as discussed in this Report. Basel III Overview In July 2013, the Agencies and FDIC approved final and interim final rules to implement the Basel Committee on Banking Supervision (BCBS) Basel III capital guidelines for U.S banking organizations (Final Rule) with an effective date of January 1, Basel III establishes a capital adequacy framework, which provides for measuring required capital under two approaches applied in a phased manner encouraging market discipline. These approaches include the Advanced Approach and Standardized Approach. Also see the Capital Management section in Management s Discussion and Analysis to our 2014 Form 10K and our second quarter 2015 Form 10 Q for additional background and history of the various regulatory capital adequacy rules applicable to us. In July 2012, prior to the finalization of the Final Rule, we entered the parallel run phase of Basel II, during which banking organizations were required to successfully complete an evaluation of specific risk measurement and management criteria for the period under supervision of regulatory agencies in order to receive approval to calculate riskbased capital requirements under the Advanced Approach methodology. In March 2015, the FRB and OCC directed the Company and its subsidiary national banks to exit the parallel run phase and begin using the Advanced Approach capital framework, in addition to the Standardized Approach, to determine our riskbased capital requirements starting in second quarter of Consistent with the Collins Amendment to the DoddFrank Act, we must report the lower of our CET 1, tier 1, and total capital ratios calculated under the Standardized Approach and under the Advanced Approach in the assessment of our capital adequacy. As of June 30, 2015, the CET1 and tier 1 capital ratios were lowest using RWAs determined under the Standardized Approach, whereas the total capital ratio was lower under the Advanced Approach. The capital requirements that apply to us can change in future reporting periods as a result of these rules, and the tables within this report include RWAs information under the Advanced Approach. The Final Rule is part of a comprehensive set of reform measures and regulations intended to improve the banking sector s ability to absorb shocks arising from financial and economic stress, improve risk management and governance, and strengthen banks transparency and disclosures. To achieve these objectives, the Final Rule, among other things: Implemented in the United States the Basel III regulatory capital reforms including those that revise the definition of capital, increased minimum capital ratios, and introduced a minimum CET1 ratio of 4.5%, and a capital conservation buffer of 2.5% (for a total minimum CET1 ratio of 7.0%), and a potential countercyclical buffer of up to 2.5%, which would be imposed by regulators at their discretion if it is determined that a period of excessive credit growth is contributing to an increase in systemic risk; 6

7 Required a ratio of Tier 1 capital to average total consolidated assets of 4.0% and introduced, for large and internationally active bank holding companies (BHCs), a Tier 1 SLR of 3% that incorporates offbalance sheet exposures; Revised Basel I rules for calculating RWAs to enhance risk sensitivity under the Standardized Approach; Modified the existing Basel II Advanced Approach rules for calculating RWAs to implement Basel III; Deducted certain assets from CET1, such as deferred tax assets that could not be realized through net operating loss carrybacks, significant investments in nonconsolidated financial entities, and MSRs, to the extent any one category exceeds 10% of CET1 or all such items, in the aggregate, exceed 15% of CET1; Eliminated the accumulated other comprehensive income or loss filter that applies under the riskbased capital rules over a fiveyear phasein period beginning in 2014; and Complied with the DoddFrank Act provision prohibiting the reliance on external credit ratings. In addition, in July 2015, the FRB finalized a rule to implement an additional CET1 capital surcharge on those U.S. banking organizations, such as the Company, that have been designated by the Financial Stability Board (FSB) as global systemically important banks (GSIBs). The GSIB surcharge will be in addition to the minimum Basel III 7.0% CET1 requirement. Under the rule, a GSIB must annually calculate its surcharge under two methods and use the higher of the two surcharges. The first method will consider the G SIB s size, interconnectedness, crossjurisdictional activity, substitutability, and complexity, consistent with a methodology developed by the BCBS and FSB. The second method will use similar inputs, but will replace substitutability with use of shortterm wholesale funding, which will generally result in higher surcharges than the BCBS methodology. Under the rule, estimated surcharges for GSIBs will range from 1.0% 4.5% of a firm s RWAs. Based on yearend 2014 data, the FRB estimated that the Company s GSIB surcharge would be 2% of the Company s RWAs. However, because the GSIB surcharge will be calculated annually based on data that can vary overtime, the amount of the surcharge is subject to change in future periods. The GSIB surcharge will be phasedin beginning on January 1, 2016 and become fully effective on January 1, The Advanced Approach is only applicable to banking organizations with consolidated assets greater than $250 billion or with foreign exposures exceeding $10 billion on their balance sheet. The Final Rule is structured around three Pillars as follows: Pillar 1 Minimum Capital Adequacy Standards: Relative to Basel I, Basel III requires banks to develop more refined approaches to quantifying the capital requirements for credit risk, and also introduces a capital charge for operational risk under the Advanced Approach, which was not included in Basel I. Pillar 2 Internal Capital Adequacy Assessment Process: Pillar 2 modifies Pillar 1 capital requirements to include idiosyncratic risk in addition to risks banks face that are not included in Pillar 1 (e.g. interest rate risk on the banking book). Pillar 2 is principlebased and places significant emphasis not just on the calculations of capital, but also the calculation processes and the mechanisms management uses to assure itself that Wells Fargo is adequately capitalized. In accordance with Pillar 2, Wells Fargo is required to develop and maintain an Internal Capital Adequacy Assessment Process (ICAAP) to support the assessment of its capital adequacy. Furthermore, Pillar 2 outlines principles of supervisory review to monitor the banks capital and evaluate the banks management of risks through the use of internal control processes. Pillar 3 Market Discipline: The objective of Pillar 3 is to improve risk disclosure in order to permit market forces to exert pressure on insufficiently capitalized banks. This results in the establishment of new minimum requirements for qualitative and quantitative disclosures to be made available to the public that contain the outcome of capital calculations and risk estimates, as well as the methods and assumptions used in performing those calculations. Wells Fargo was required to comply with the Final Rule beginning January 1, 2014, with certain provisions subject to phasein periods. On January 28, 2015, the BCBS issued the final standard for the revised Pillar 3 disclosure requirements. These revisions will enable market participants 7

8 to compare banks disclosures of riskweighted assets and improve transparency of the internal modelbased approaches that banks use to calculate minimum regulatory capital requirements. The proposed effective date for the revised Pillar 3 requirements is December 31, 2016, and is currently pending action by U.S. regulators. Scope of Application of Basel III The Basel III framework applies to Wells Fargo & Company and its banking subsidiaries. Wells Fargo & Company s bank subsidiaries are Wells Fargo Bank, National Association (Wells Fargo Bank, N.A.), Wells Fargo Bank South Central, National Association (Wells Fargo Bank South Central, N.A.), Wells Fargo Bank Northwest, National Association (Wells Fargo Bank Northwest, N.A.), Wells Fargo Financial National Bank, Wells Fargo Delaware Trust Company, National Association (Wells Fargo Delaware Trust Company, N.A.), and Wells Fargo Bank, Ltd. The basis of consolidation used for regulatory reporting is the same as that used under U.S. Generally Accepted Accounting Principles (GAAP). There are no entities within Wells Fargo that are deconsolidated for Basel III purposes, or whose capital is deducted except for certain excludable insurance subsidiaries. At June 30, 2015, the capital of insurance subsidiaries deducted from total capital was $590 million. For additional information on our basis for consolidating entities for accounting purposes, see Note 1 (Summary of Significant Accounting Policies) to Financial Statements in our 2014 Form 10K and our second quarter 2015 Form 10Q. For information regarding restrictions or other major impediments on the transfer of funds and capital distributions, see Note 3 (Cash, Loan and Dividend Restrictions) to Financial Statements in our 2014 Form 10K. Capital under Basel III Basel III modified earlier rules by narrowly defining qualifying capital and increasing capital requirements for certain exposures. CET1 capital primarily includes common stockholders equity, accumulated other comprehensive income (AOCI), and retained earnings less deductions for certain items such as goodwill, gains related to securitization transactions, intangibles, and minority interest, as well as setting thresholds for items including: mortgage servicing rights (MSRs) and deferred tax assets (DTAs) and investments in financial institutions as defined by the Final Rule. Tier 1 capital consists of CET1 capital in addition to capital instruments that qualify as Tier 1 capital such as preferred stock. Tier 2 capital includes qualifying allowance for credit losses and subordinated debt. Total capital is the sum of Tier 1 and Tier 2 capital. The new requirements of CET1 capital, Tier 1 capital and Total capital are subject to a phasein period that began on January 1, 2014 and concludes on December 31, RiskWeighted Assets under Basel III Compared with the Standardized Approach, the calculation of RWAs under the Advanced Approach requires that applicable banks employ robust internal models for risk quantification. The significant differences in the two approaches consist of the following: Credit Risk: under the Advanced Approach, credit risk RWAs is calculated using risksensitive calculations that rely upon internal credit models based upon the Company s experience with internal rating grades, whereas under the Standardized Approach, credit risk RWAs is calculated using riskweights prescribed in the Final Rule that vary by exposure type; Operational Risk: the Advanced Approach includes a separate operational risk component within the calculation of RWAs, while the Standardized Approach does not; Credit Valuation Adjustment (CVA) capital charge: the Advanced Approach for counterparty credit risk includes a charge for CVA and the Standardized Approach does not; and Addon Multiplier: under the Advanced Approach only, a 6% addon multiplier is applied to all components of credit risk RWAs other than the CVA component. 8

9 The primary components of RWAs under the Advanced Approach include: Credit Risk RWAs, which reflects the risk of loss associated with a borrower or counterparty default (failure to meet obligations in accordance with agreed upon terms) and is presented by exposure type including wholesale credit risk, retail credit risk, counterparty credit risk, securitization exposure, equity investments, and other assets; Market Risk RWAs, which reflects the risk of loss due to adverse changes in the financial instruments held by the Company due to market risk factors such as interest rates, credit spreads, foreign exchange rates, equity, and commodity prices; and Operational Risk RWAs, which reflects the risk of loss resulting from inadequate or failed internal processes or systems, resulting from internal/external operational loss events. Transitional Period for Basel III The Final Rule provides for a transitional period for certain elements of the rule calculations extending through the end of 2018, at which point the capital requirements become fully phasedin, as demonstrated in the diagram below. The riskweighted assets disclosed within this report are based upon the transitional capital provisions, unless otherwise expressly stated. 9

10 Capital Requirements and Management Wells Fargo s objective in managing its capital is to maintain sufficient and adequate capital resources appropriate for our risk profile including current and future requirements to meet business and customer needs, regulatory requirements and economic volatility demands while maintaining strong protection for depositors and creditors, and to provide a meaningful return on capital via dividends and net share repurchases for maximum shareholder benefit. Our potential sources of capital primarily include the retention of earnings net of dividends, and issuance of preferred stock. We manage requirements for capital with the goal of ensuring that sufficient capital reserves remain in excess of regulatory requirements and internal targets (set in excess of minimum regulatory requirements by the Company s Board of Directors). There are operational and governance processes in place to manage, forecast, monitor, and report to management and the Company s Board of Directors capital levels in relation to regulatory requirements and capital plans. The Company and each of its insured depository institutions are subject to various regulatory capital adequacy requirements administered by the Agencies. Riskbased capital guidelines establish a riskadjusted ratio relating capital to different categories of assets and offbalance sheet exposures. Our capital adequacy assessment process contemplates a wide range of risks that the Company is exposed to and also takes into consideration our performance under a variety of stressed economic conditions, as well as regulatory expectations and guidance. The following chart presents the regulatory minimum ratios which the Company and each of its insured depository institutions are subject to, as of June 30, Minimum Fully Phased in Minimum Fully Phased in Capital Ratios Capital Ratios with GSIB Surcharge (1) Capital Ratios CET 1 7.0% 9.0% Tier 1 8.5% 10.5% Total 10.5% 12.5% U.S. Supplementary Leverage Ratio (effective January 1, 2018) Bank Holding Company 5.0% Insured Depository Institution 6.0% (1) Applicable only to Wells Fargo & Company and not each of its individual insured depository institutions. Capital Management Wells Fargo actively manages capital through a comprehensive process for assessing its overall capital adequacy. Refer to Note 18 (Preferred Stock) and Note 19 (Common Stock and Stock Plans) to Financial Statements in our 2014 Form 10K for information on the terms and conditions of our regulatory capital instruments. Our Corporate Asset/Liability Committee (ALCO), overseen by the Finance Committee of our Board of Directors (Board), determines the Company s capital management objectives to ensure alignment with the expectations and guidance offered by regulatory agencies and our Board. ALCO reviews the actual and forecasted capital requirements every month, and economic and stress test results semiannually. The Company s annual capital plan serves as our primary planning tool to establish and test our capital strategy relative to our capital policy, and provides a comprehensive discussion of our capital targets. Throughout the year, progress against this plan is monitored and reported to executive management, ALCO and our Board. Our capital plan incorporates baseline forecasts as wells as forecasts under stress, in order to assess our capital position under multiple economic conditions. Our Board s Risk Committee, Finance Committee, and Credit Committee meet multiple times throughout the year to establish the risk appetite and review the results of stress testing, in to order to evaluate and manage the Company s projected capital 10

11 adequacy. For a discussion on our Risk Management Framework, see the Risk Management Framework and Culture section in Management s Discussion and Analysis to our 2014 Form 10K. Additionally, the Company s Capital Reporting Committee (CRC) provides oversight of the regulatory capital calculation results and capital calculation disclosures. The CRC reports directly to the Regulatory Reporting Oversight Committee (RROC), a management governance committee overseen by the Audit and Examination Committee of the Company s Board. The RROC provides oversight of Wells Fargo s regulatory reporting and disclosures, and assists executive management in fulfilling their responsibilities for oversight of the regulatory financial reports and disclosures made by the Company. Wells Fargo & Company is the source of strength and the primary provider of capital to its subsidiaries. However, each of the Company s insured depository institutions manages its own capital to support planned business growth and meet regulatory requirements within the context of the Company s annual capital plan. For additional information on our capital management framework and culture, see the Capital Management section in Management s Discussion and Analysis to our 2014 Form 10K. Internal Capital Adequacy Assessment Process (ICAAP) Our internal capital adequacy assessment process, referred to as ICAAP, is designed to ensure we understand our exposure to material risks and evaluates the capital resources available to absorb potential losses arising from those risks. Semiannually, we execute companywide capital stress tests as a key analytical tool to assess our capital adequacy relative to our risk profile and risk appetite. Companywide capital stress testing is a forwardlooking assessment of the potential impact of adverse events and circumstances on Wells Fargo s capital adequacy. The key outputs from stress testing are pro forma balance sheets and income statements prepared consistent with U.S. GAAP, which are then used to evaluate capital adequacy. Comprehensive Capital Analysis and Review In addition to its use in Wells Fargo s ongoing ICAAP processes, companywide capital stress testing also supports the FRB s annual Comprehensive Capital Analysis and Review (CCAR), the FRB s MidCycle Stress Test as required by the DoddFrank Act for BHCs with assets in excess of $50 billion and the OCC Annual Stress Test, including related regulatory reporting requirements and disclosure by Wells Fargo of stress testing methodologies and certain adverse scenario results. For details on our CCAR process, refer to the Capital Planning and Stress Testing section in Management s Discussion and Analysis to our second quarter 2015 Form 10Q and to our 2014 Form 10K. 11

12 Capital Summary Table 2 shows the adequacy of riskbased capital for Wells Fargo & Company and its banking subsidiaries under the Advanced Approach with transition requirements. T able 2: Capital Adequacy of Bank Holding Company and Insured Depository Subsidiaries June 30, 2015 Basel III Advanced Approach (in millions) CET 1 Capital (1) Tier 1 Capital (2) Total Capital (3) Advanced Approach RWAs (4) CET1 Capital Ratio (5) Tier 1 Capital Ratio (6) Total Capital Ratio (7) Wells Fargo & Company $ 140,860 $ 160,405 $ 187,426 $ 1,297, % 12.37% 14.45% Wells Fargo Bank, N.A. 122, , ,742 1,117, % 10.99% 12.23% Wells Fargo Bank South Central, N.A. 1,220 1,220 1,255 7, % 17.05% 17.53% Wells Fargo Bank Northwest, N.A. 1,233 1,233 1,233 3, % 35.73% 35.73% Wells Fargo Financial National Bank , % 12.63% 12.63% Wells Fargo Delaware Trust Company, N.A % % % Wells Fargo Bank, Ltd , % 34.87% 34.87% (1) Common Equity Tier 1 capital (CET 1 capital) consists of common stockholders' equity, AOCI and retained earnings less deductions for goodwill, intangibles and minority interest. (2) Tier 1 capital is the sum of CET1 capital and additional Tier 1 capital. (3) Total capital is defined as Tier 1 capital plus Tier 2 capital. (4) RWAs under Basel III Advanced Approach includes the 6% credit risk multiplier where applicable. (5) CET 1 capital ratio = CET 1 capital / RWAs. (6) Tier 1 capital ratio = Tier 1 capital / RWAs. (7) Total capital ratio = Total capital / RWAs. Table 3 provides information regarding the components of capital used in calculating CET1 capital, Tier 1 capital, Tier 2 capital, and Total capital under Basel III transition requirements for Wells Fargo & Company at June 30, T able 3: Total Regulatory Capital Base June 30, 2015 (in m illions) Common stock plus related surplus, net of treasury stock $ 53,435 Retained earnings 114,093 Accumulated other comprehensive income (AOCI) 955 Common Equity Tier 1 capital (CET1) before regulatory adjustments and deductions 168,483 Less: Goodwill (net of associated deferred tax liabilities) 25,943 Other (includes intangibles, net gain/loss on cash flow hedges) 1,680 Total adjustments and deductions for Common Equity Tier 1 capital 27,623 CET 1 capital 140,860 Additional Tier 1 capital instruments 19,962 Less: Total additional Tier 1 capital deductions 417 Additional Tier 1 capital 19,545 Tier 1 capital 160,405 Tier 2 capital before regulatory adjustments and deductions 27,335 Less: Total Tier 2 capital deductions 314 Tier 2 capital 27,021 Total capital $ 187,426 12

13 Table 4 presents information on the RWAs components included within our regulatory capital ratios under the Advanced Approach with transition requirements for Wells Fargo & Company at June 30, Table 4: Risk Weighted Assets by Risk Ty pe June 30,2015 Advanced Approach (in millions) Credit Wholesale exposures: Corporate $ 287,741 Bank 32,458 Sovereign 1,176 Income Producing Real Estate 65,764 High Volatility Commercial Real Estate 24,957 Total Wholesale exposures 412,096 Retail exposures: Residential mortgage first lien 111,122 Residential mortgage junior lien 10,505 Residential mortgage revolving 61,825 Qualifying revolving (1) 36,513 Other retail 85,435 Total Retail exposures 305,400 Counterparty exposures: OTC Derivatives 21,957 Margin loans and repo style transactions 12,684 Cleared transactions (2) 3,543 Unsettled Trades 64 Total Counterparty exposures 38,248 Credit Valuation Adjustments (CVA) 26,053 Securitization exposures 111,281 Equity investment exposures 39,839 Other exposures (3) 61,035 Total Credit Risk Weighted Assets $ 993,952 Market risk 42,320 Operational risk 260,808 Total Risk Weighted Assets (Basel III Advanced Approach) $ 1,297,080 (1) Qualifying revolving exposures are unsecured revolving exposures where the undrawn portion of the exposure is unconditionally cancellable by the bank. (2) Includes Derivative and Repo exposures to Central Counterparties with RWAs of $ 539 million and $ 29 million, respectively. Default fund contribution to counterparties resulted in RWAs of $ 2,975 million, which is also included. (3) Other exposures include other assets and transition items (nondeducted Intangibles and Mortgage Servicing Rights). 13

14 Credit Risk Overview We define credit risk as the risk of loss associated with a borrower or counterparty default (failure to meet obligations in accordance with agreed upon terms). Credit risk exists with many assets and exposures such as debt security holdings, derivatives, and loans. Our loan portfolios represent the largest source of credit risk to the Company. A critical component of our loan credit risk management is a wellcontrolled underwriting process that is appropriate for the needs of customers, as well as investors who purchase loans or securities collateralized by the loans we underwrite. We only approve applications and make loans if we believe the customer has the ability to repay the loan or line of credit in accordance with all of its contractual terms. Our ongoing methods for monitoring and measuring various forms of credit risks are discussed by respective credit risk type in subsequent sections. Wells Fargo uses numerous control processes to monitor and validate its systems on an ongoing basis. These control processes are independent of the development, implementation, and operation of the Advanced Internal Ratings Based (AIRB) systems. Under the AIRB systems, risk parameters (probability of default PD, loss given default LGD, and exposure at default EAD of exposures) are calculated using internal models. We rely on historical data along with external benchmarks, such as agency reports and macroeconomic data, to develop and implement these models. The Company s credit risk management process is governed centrally, but provides for decentralized management and accountability by each of our lines of business. The overall credit process includes comprehensive credit policies, disciplined credit underwriting, frequent and detailed risk measurement and modeling, extensive credit training programs, and a continual independent loan review and audit process. In addition, regulatory examiners review and perform detailed tests of our credit underwriting and loan administration processes. Refer to the Credit Risk Management section in Management s Discussion and Analysis to our 2014 Form 10K for additional information. Information about our credit risk management and practices, accounting policies, and current exposures as reported under U.S. GAAP is provided in our second quarter 2015 Form 10Q and 2014 Form 10K. The following provides specific references: Accounting Policies Refer to Note 1 (Summary of Significant Accounting Policies) to Financial Statements in our 2014 Form 10K and our second quarter 2015 Form 10Q for a summary of our significant accounting policies, including policy discussion on nonaccrual and past due loans, as well as returning nonaccrual loans to accrual status, impaired loans, and loan chargeoff policies. Total Credit Risk Exposures, Impaired Loans, Net chargeoff, and Allowance for Credit Losses Investment Securities refer to Note 4 (Investment Securities) to Financial Statements in our second quarter 2015 Form 10Q; Credit Exposure and Impaired Loans refer to Note 5 (Loans and Allowance for Credit Losses) to Financial Statements in our second quarter 2015 Form 10Q; Derivatives refer to Note 12 (Derivatives) to Financial Statements in our second quarter 2015 Form 10Q; and Net Chargeoffs refer to Table 29 (Net Chargeoffs) to Financial Statements in our second quarter 2015 Form 10Q. Distribution by Geography, Industry or Counterparty Type and Contractual Maturity Investment Securities refer to Note 4 (Investment Securities) to Financial Statements in our second quarter 2015 Form 10Q for details on counterparty type and contractual maturity; Loans refer to Table 8 (Maturities for Selected Commercial Loan Categories), Table 13 (Commercial and Industrial Loans and Lease Financing by Industry), Table 14 (CRE Loans by State and Property Type), Table 17 (Real Estate 14 Family First and 14

15 Junior Lien Mortgage Loans by State), Table 22 (Junior Lien Mortgage Line and Loan and Senior Lien Mortgage Line Portfolios Payment Schedule), and Table 28 (Loans 90 Days or More Past Due and Still Accruing) in Management s Discussion and Analysis to our second quarter 2015 Form 10Q; Derivatives refer to Note 12 (Derivatives) to Financial Statements in our second quarter 2015 Form 10Q. Average Balances refer to Table 1 (Average Balances, Yields and Rates Paid (TaxableEquivalent Basis)) in Management s Discussion and Analysis to our second quarter 2015 Form 10Q. Following is a discussion of how we assess, manage, and measure credit risk by Basel exposure type. Wholesale Credit Risk Overview / Management approach Wholesale exposures primarily include the following: All individually riskrated loans and commitments, excluding certain wholesale loans under $1 million which receive retail regulatory capital treatment and other wholesale loans which meet the definition of securitization exposures; Deposits with and money due from banks, excluding cash items in the process of collection; Debt securities, excluding those assetbacked securities which meet the definition of a securitization exposure; Trading assets that do not qualify as covered positions, but meet the definition of a wholesale exposure; Reverse repurchase transactions that do not meet the definition of a securitization exposure or a repostyle transaction due to the nature of the collateral or contractual terms of the arrangement; and Nonderivative financial guarantees that obligate the bank to make payment if another party fails to perform. At origination, and throughout the life of a wholesale loan exposure, our underwriters and loan officers use a risk rating methodology to indicate credit quality. Risk rating is essential to wholesale credit approval, risk management monitoring and reporting, loan pricing, determination of an appropriate allowance for loan and lease losses, regulatory capital assignments under the Advanced Approach, and sound corporate governance processes. Risk ratings are individually evaluated and incorporate, quantitative, qualitative, and third party factors including both pointintime and throughthecycle elements. Credit Officers certify risk ratings quarterly and are accountable for their accuracy. Our Corporate Credit Group and line of business credit functions continually evaluate and modify credit policies, including risk ratings, to address unacceptable levels of risk as they are identified. Further oversight is provided by our Corporate Risk Asset Review group. RWAs Measurement: Advanced Internal Ratings Based Table 4 presents riskweighted assets by Basel reporting classification. The Corporate, Bank and Sovereign classifications include both credit and issuer exposure to corporate entities, banks, and sovereign entities, respectively. Loans made for the purposes of acquisition, development and construction, other than 14 family residential properties, present higher risk and are categorized as high volatility commercial real estate (HVCRE). Additionally, loans which finance commercial real estate, where the prospects for repayments and recovery depend solely on the cash flows generated by the real estate serving as collateral for the exposures, are categorized as incomeproducing real estate (IPRE) in the Final Rule. 15

16 Risk weighted assets are determined by using internal risk weight parameters. The estimation process for these parameters begins with internal riskratings assigned to the obligor and internal loss severity classifications assigned to the credit facility. The obligor ratings are mapped to estimates of PD and the loss severity classifications are mapped to estimates of LGD. Obligor ratings and loss severity classifications are used for both internal risk management and regulatory capital calculations. Parameters are based on modeled outputs which are validated and backtested by an independent internal model risk governance team. To calculate wholesale credit RWAs, the Company inputs its modeled risk parameters (PD, LGD, and EAD) and maturity (M) into the A IRB risk weight formula, as specified by the Final Rule. PD is an estimate of the probability that an obligor will default over a oneyear horizon. LGD is an estimate of the portion of the EAD that would be lost (including the economic cost of delayed recovery and the cost of collection) in a stressed environment with high default rates. EAD is an estimate of the amount that would be owed to Wells Fargo if the obligor were to default and M is the effective remaining maturity of the exposures. Additionally, modeled parameters are supplemented with judgmental overlays to address model or data limitations and ensure conservatism where appropriate. The risk mitigating benefit of guarantees and credit derivative hedges are reflected in the RWAs calculation by adjusting the PD or LGD. At June 30, 2015, $85.6 billion of wholesale exposure reflected the benefit of eligible guarantees, excluding exposures conveyed to other banks via syndications or participations. Table 5 provides the distribution of the portfolio and key parameter estimates by PD bands. While the commercial loan portfolio comprises the majority of the wholesale EAD and more than 80% of the wholesale RWAs, the nonloan categories add significant balances to the lowrisk part of the portfolio. Table 5: The Company 's CreditRiskAssessment ofwholesale Exposuresby Probability ofdefault (PD)Grades June 30,2015 (in millions, except ratios) Exposureweighted average Advanced PD Range (percentage) Balance Sheet Amount Undrawn Commitments Exposure at Default Approach RWAs (2) PD LGD Risk Weight 0.00 to < ,558 11, ,840 12, % 6.61 % 3.01 % 0.05 to < , , , , to < , , , , to < ,884 22,387 54,598 64, to < ,996 4,017 7,683 7, to <100 9,144 10,210 14,829 25, (default) 3, ,201 3, Total Wholesale (1) $ 862,863 $ 435,979 $ 1,065,891 $ 412, % % % (1) Includes debt securities, deposits and other funds due from other institutions, plus other nonloan exposure. (2) RWAs under Basel III Advanced Approach includes the 6% credit risk multiplier where applicable. Retail Credit Risk Overview / Management approach The credit quality of retail exposures is indicated through loan scoring or other statistical approaches appropriate for homogenous types of credits. Lines of business with retail portfolios are responsible for developing valid, statistically based, automated models for credit decisions, collateral valuation, and risk management. Our corporate risk group is responsible for model preimplementation validation approval and ongoing oversight. All credit scoring, risk rating, loss forecasting, valuation, and other risk management models are subject to the Wells Fargo Model Risk Management Policy. See Asset/Liability Management section in Management s Discussion and Analysis to our 2014 Form 10K for discussion on our model risk management. 16

17 RWAs Measurement: Advanced Internal Ratings Based In accordance with Basel III, the retail population for regulatory capital includes all loans in the consumer loan segment for U.S. GAAP except certain small business banking loans, which have characteristics similar to commercial loans and are reported as wholesale loans for regulatory reporting purposes. Retail exposures are assigned to segments and PD, LGD, and EAD are estimated for each retail segment, taking into account the risk mitigating impact of collateral and guarantees. The retail segmentation process uses various factors relevant to the credit risk of retail borrowers to group those borrowers into pools for risk quantification purposes, after which the risk parameters are quantified at the pool level. The risk parameters for each retail segment are used as inputs to an AIRB riskbased capital formula specified in the Final Rules. As with the wholesale parameters, the retail risk parameters are estimated using proprietary internal models and independently validated by a model governance team. Table 6 provides the distribution of the portfolio segments in alignment with Basel segmentation and key parameter estimates by PD bands. Table 6: The Company 's Credit Risk Assessment of Retail Exposures by Probability of Default (PD) Grades June 30,2015 (in millions, except ratios) Exposureweighted average Advanced PD range Balance Sheet Undrawn Exposure at Approach (percentage) Amount Commitments Default RWAs (1) PD LGD Risk Weight Residential mortgage first lien 0.00 to < ,708 71,631 5, to < ,568 38,071 5, to < ,764 10,928 86,683 20, to < ,196 39,719 28, to < ,094 8,219 10, to < , ,272 19, (default) 28,882 29,367 20, Total residential mortgage first lien $ 273,510 $ 11,648 $ 288,962 $ 111, % % % Residential mortgage junior lien 0.00 to < ,504 1, to < to < ,723 1,796 1, to < ,675 2,722 5, to < , to < , (default) Total residential mortgage junior lien $ 6,940 $ $ 7,081 $ 10, % % % Residential mortgage revolving 0.00 to < ,600 54,703 30,565 3, to < ,824 4,808 13,241 5, to < ,807 7,584 15,510 5, to < ,442 2,070 21,725 33, to < , to < 100 1, ,097 9, (default) 1, ,182 1, Total residential mortgage revolving $ 66,213 $ 69,346 $ 84,887 $ 61, % % % Qualifying revolving (2) 0.00 to < ,489 86,034 30,491 2, to < ,199 14,108 16,137 7, to < ,337 2,259 7,654 6, to < ,921 1,205 2,290 2, to < , ,002 5, to < , ,506 11, (default) Total qualifying revolving $ 34,496 $ 105,252 $ 66,089 $ 36, % % % Other retail 0.00 to < ,533 30,895 48,750 15, to < ,811 4,200 48,850 34, to < ,780 1,456 11,454 11, to < , ,788 8, to < , ,794 4, to < , ,354 9, (default) Total other retail $ 111,172 $ 36,862 $ 129,743 $ 85, % % % (1) RWAs under Basel III Advanced Approach includes the 6% credit risk multiplier where applicable. (2) Qualifying revolving exposures are unsecured revolving exposures where the undrawn portion of the exposure is unconditionally cancellable by the bank. 17

18 Counterparty Credit Risk Overview / Management Approach Counterparty Credit Risk (CCR) is the possibility that a customer or trading counterparty will fail to fulfill contractual obligations, and such failure may result in the termination or replacement of the transaction at a loss to Wells Fargo. Such exposures arise primarily in relation to overthecounter (OTC) derivatives, repostyle transactions, margin loans, transactions cleared through a central counterparty or exchange, and unsettled trades. The majority of CCR exposure is incurred in transactions designed to help our clients manage their interest rate, currency, and other risks, and in the associated hedging of those transactions. Wells Fargo uses a range of models and methodologies to estimate the potential size of counterparty exposures and establishes limits and controls around activities incurring these risks. Counterparty exposure is typically mitigated using collateral. Collateral arrangements supporting Wells Fargo s counterparty credit risk exposures can be grouped into two broad categories: Many of Wells Fargo s counterparty risks arise out of its derivatives activities undertaken with corporate clients. In many cases, the counterparty credit risk is managed by relationship/credit officers close to the client and is crosscollateralized with securities supporting loan and other exposures to the same counterparty (e.g. receivables and inventory). Any benefit deemed to accrue from this type of crosscollateralization is reflected in the credit grades applied to the exposure, which in turn impacts the regulatory capital required. Exposures for many counterparty relationships are covered by standalone collateral arrangements, which require the posting of liquid financial collateral. Collateral arrangements are managed by a dedicated collateral management function, which handles the posting and receipt of collateral per the Collateral Support Annex (CSA). The CSA is supporting documentation for a collateral arrangement between counterparties. The majority of the absolute value of collateral received and posted typically comprises cash with the remainder primarily in the form of instruments issued or backed by the U.S. Government or Government Sponsored Entities (GSEs)(e.g. treasuries, agencies, or agency mortgagebacked securities). For disclosure of the impact on the amount of collateral we would be required to post in the event of a significant deterioration in our credit, see Note 12 (Derivatives) to Financial Statements in our second quarter 2015 Form 10Q. RWAs Measurement Wells Fargo uses the Current Exposure Method (CEM) to calculate EAD, which is used in the calculation of RWAs using the wholesale model. Mitigants are recognized using the Collateral Haircut approach with prescribed regulatory haircuts. Under the CEM approach, EAD is the sum of current credit exposure (CCE) and the potential future exposure (PFE). The CCE is the sum of net positive fair values and the PFE is an estimate of the maximum amount of the exposure that could occur over a one year horizon. The PFE is based on the derivative notional amount and a credit conversion factor (CCF) and is a component of EAD irrespective of the fair value of the derivative contract. The CCF is based on the underlying contract type and remaining maturity. PFE is also adjusted for those contracts subject to a master netting agreement as prescribed by the Final Rule. The netting benefits of master netting agreements (e.g. International Swaps and Derivatives Association) and collateral arrangements (e.g. Credit Support Annex) are reflected in the EAD. For descriptions of counterparty credit risk, see Note 12 (Derivatives) to Financial Statements in our second quarter 2015 Form 10Q. Table 7 shows derivative metrics by underlying exposure type and segregates our derivative activity between contracts traded in OTC markets from those cleared through a central counterparty or exchange. OTC derivatives are those traded between two parties directly without the use of an exchange and result in counterparty credit exposure to the OTC counterparty. Derivatives cleared through a 18

19 central counterparty or an exchange, limit counterparty risk because the central clearing party or exchange serves as the counterparty to both parties to the derivative. T able 7 : Counterparty Credit Risk Deriv ativ es Ex posure Ty pes June 30,2015 Product (in millions) Notional (1) Gross Positive Fair Value Gross Exposure at Default Post Mitigant Exposure at Default Advanced Approach RWAs (2) OTC derivatives: Interest rate contracts $ 2,258,963 30,638 43,829 16,959 12,080 Foreign exchange contracts 331,208 7,644 16,875 4,770 2,569 Equity contracts 127,581 4,634 13,132 5,752 3,295 Credit derivatives contracts 18, , Commodities and Other 53,249 2,013 6,790 4,851 3,325 Total OTC derivative contracts (principal+agent) 2,789,370 45,626 83,213 33,139 21,957 Central counterparty (CCPs) & Exchange traded derivatives: Interest rate contracts $ 4,272,196 37,404 67,553 14, Foreign exchange contracts Equity contracts 31,826 4,373 6,332 4, Credit derivatives contracts 1, Commodities and Other 23,346 2,986 5,479 5, Total CCP & Exchange traded derivatives contracts $ 4,328,584 44,772 79,505 25, (1) Excluding sold derivatives and written options. (2) RWAs under Basel III Advanced Approach includes the 6% credit risk multiplier where applicable. The table above distinguishes between OTC and centrally cleared or exchange traded derivatives, and includes: Notional, which is used in the calculation of the PFE addon; Gross Positive Fair Value, which is the sum of all derivative transactions with a positive fair value before the mitigating effects of counterparty netting and collateral; Gross Exposure at Default, which is the Gross Positive Fair Value plus the unadjusted PFE; Post Mitigant Exposure at Default, which is the amount CCE and PFE attributed to derivatives after counterparty netting, PFE adjustment, and the reduction of exposure due to eligible collateral; Advanced Approach RWAs, which is calculated under the Basel III Advanced Approach. 19

20 Table 8 displays a breakout of collateral by type which has been received by the Company as part of derivatives, repostyle transactions, and margin loans. T able 8: Counterparty Collateral Types June 30,2015 (in millions) Derivatives Collateral Repo & Margin Loan Collateral Cleared Transaction Collateral Cash Treasuries Agencies Corporate Bonds Main Index Equities Other Public Equities Mutual Funds Other $ 6,579 1, ,978 11,890 9,586 2,116 13,226 7,039 5,617 1,241 18,195 14,974 2, Total Collateral $ 8, ,693 35,622 Table 9 presents a distribution of EAD, RWAs, and weighted average measures by PD band for counterparty credit risk exposures. T able 9: Counterparty CreditRiskExposure Type June 30,2015 (in millions, except ratios) Exposureweighted average Advanced PD Range Approach Risk (percentage) Exposure at Default RWAs (1) PD LGD weight OTC Derivatives & Repos 0.00 to < 0.05 $ $ % % % 0.05 to < ,948 18, to < ,015 12, to < , to < to < (default) Default Fund Contribution 509 2, Margin Loans 606 1, Cleared Transactions 26, Total Counterparty Credit Risk Exposure (2) $ 86,013 $ 38, % % % (1) RWAs under Basel III Advanced Approach includes the 6% credit risk multiplier where applicable. (2) Excludes Unsettled trades RWAs of $64mm. CVA The CVA is a required fair value adjustment under U.S. GAAP, which is included in earnings and capital, to reflect counterparty credit risk in the valuation of an OTC derivative contract. In order to improve a bank s ability to withstand losses due to CVA volatility, an incremental CVA capital charge was introduced in the Final Rule. The CVA capital charge is a bank holding company level, bilateral derivative portfolio measure and is based on counterparty credit quality, remaining trade duration, and EAD. Securitization Credit Risk Overview / Management Approach Securitization exposures are those which arise from traditional securitization, synthetic securitization, or resecuritization transactions where credit risk has been separated into at least two tranches, performance of the exposure is dependent on the performance of the underlying assets, and substantially all of the underlying assets are financial assets. A resecuritization is a securitization which has more than one underlying exposure and in which one or more of the underlying exposures is a securitization exposure. In addition, the Final Rule distinguishes between traditional and synthetic securitizations. In a traditional securitization, assets, which are typically loans or debt securities, are transferred from an originator or sponsor to a special purpose entity (SPE), which receives funds to 20