Medicare Tax

Certain U.S. Holders who are individuals, estates, or trusts are required to pay a 3.8% Medicare surtax on all or part of that
holder’s “net investment income” or “undistributed net investment income” in the case of an estate or trust, which includes,
among other items, dividends on, and capital gains from the sale or other taxable disposition of, the Equity Shares, subject to
certain limitations and exceptions. The 3.8% Medicare surtax is determined in a different manner than the regular U.S. income
tax. Prospective investors should consult their own tax advisors regarding the effect, if any, of this surtax on their ownership
and disposition of the Equity Shares.

Information with Respect to Foreign Financial Assets

Individuals and certain entities who are U.S. Holders that own “specified foreign financial assets”, including stock of a non-
U.S. corporation not held through a financial institution, with an aggregate value in excess of certain dollar thresholds may be
required to file an information report with respect to such assets on IRS Form 8938 with their United States federal income tax
returns. Penalties apply for failure to properly complete and file IRS Form 8938. U.S. Holders are encouraged to consult their
tax advisors regarding the application of this reporting requirement to their ownership of the Equity Shares.

Passive Foreign Investment Company

Certain U.S. federal income tax rules generally apply to a U.S. person that owns or disposes of stock in a non-U.S. corporation
that is treated as a PFIC. A non-U.S. corporation is considered to be a PFIC, for any taxable year if either:

. at least 75% of its gross income is passive income, or

. at least 50% of its assets (based on an average of the quarterly values of the assets during a taxable year) is attributable
to assets that produce or are held for the production of passive income.

Passive income for these purposes generally includes dividends, interest, royalties, rents and gains from commodities and
securities transactions. The Bank will be treated as owning its proportionate share of the assets and earning its proportionate
share of the income of any other corporation in which it owns, directly or indirectly, 25% or more (by value) of the stock.

Although not free from doubt, the Bank does not believe it was a PFIC for its taxable year ending March 31, 2018, and does not
expect to be a PFIC for the current year or any future years. However, the determination of whether the Bank is a PFIC is a
factual determination made annually after the end of each taxable year, and there can be no assurance that the Bank will not be
considered a PFIC in the current taxable year or any future taxable year because, among other reasons, (i) the composition of
the Bank’s income and assets will vary over time, (ii) there can be no assurance that the proposed treasury regulations applicable
to foreign banks will be finalized in their current form, (iii) there can be no assurance that Notice 89-81 (also applicable to
foreign banks) will remain effective, and (iv) the manner of the application of Notice 89-81 is uncertain in several respects, as
are the proposed treasury regulations addressing income derived in the active conduct of a banking business and other relevant
rules. Furthermore, the Bank’s PFIC status may depend on the market price of its Equity Shares, which may fluctuate
considerably.

PROSPECTIVE PURCHASERS ARE URGED TO CONSULT YOUR TAX ADVISORS REGARDING THE BANK’S
POSSIBLE STATUS AS A PFIC.

If the Bank is a PFIC for any taxable year during which you are a U.S. Holder of Equity Shares, you will be subject to special
tax rules with respect to any “excess distribution” that you receive and any gain you realize from a sale or other disposition
(including a pledge) of the Equity Shares, unless you make a “mark-to-market” election as discussed below. Distributions you
receive in a taxable year that are greater than 125% of the average annual distributions you received during the shorter of the
three preceding taxable years or your holding period for the Equity Shares will be treated as an excess distribution. Under these
special tax rules:

. the excess distribution or gain will be allocated ratably over your holding period for the Equity Shares,

. the amount allocated to the current taxable year, and any taxable year prior to the first taxable year in which the Bank
became a PFIC, will be treated as ordinary income, and

. the amount allocated to each other year will be subject to the highest tax rate in effect for that year and the interest
charge generally applicable to underpayments of tax will be imposed on the resulting tax attributable to each such year.

The tax liability for amounts allocated to years prior to the year of disposition or “excess distribution” cannot be offset by any

net operating losses for such years, and gains (but not losses) realized on the sale of the Equity Shares cannot be treated as
capital, even if you hold the Equity Shares as capital assets.

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