U.S. Holders that hold Equity Shares in any year in which the Bank is a PFIC, will be required to file Internal Revenue Service
Form 8621 with respect to their ownership of the Equity Shares. This filing requirement is in addition to a U.S. Holder’s
obligation to file other Internal Revenue Service forms with respect to our common shares, including Form 8938. In addition,
U.S. Holders may be required to file additional information with respect to their ownership of Equity Shares.

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