If the Bank is a PFIC for any year during which you are a U.S. Holder of Equity Shares, the Bank generally will continue to be
treated as a PFIC with respect to you for all succeeding years during which you hold Equity Shares, regardless of whether the
Bank continues to meet the income or asset test described above.

In addition, if the Bank is treated as a PFIC, to the extent any of its direct or indirect subsidiaries (if any) are also PFICs, you
may be deemed to own shares in such subsidiaries (if any) and you may be subject to the adverse PFIC tax consequences with
respect to the shares of such subsidiaries (if any) that you would be deemed to own.

Qualified electing fund election

To mitigate the application of the PFIC rules discussed above, a U.S. Holder may make an election to treat the Bank as a
qualified electing fund (“QEF”) for U.S. federal income tax purposes. To make a QEF election, the Bank must provide U.S.
Holders with information compiled according to U.S. federal income tax principles. The Bank does not currently intend to
prepare or provide the information that would enable you to make a QEF election.

Mark-to-market election

AUS. Holder of “marketable stock” (as defined below) in a PFIC may make a mark-to-market election with respect to such
stock to elect out of the tax treatment discussed above, although it is possible the mark-to-market election may not apply or be
available with respect to the shares in the Bank’s subsidiaries (if any) to the extent they are PFICs that you may be deemed to
own if the Bank is treated as a PFIC, as discussed above. If you make a valid mark-to-market election for the Equity Shares,
you will include in income each year an amount equal to the excess, if any, of the fair market value of the Equity Shares as of
the close of your taxable year over your adjusted basis in such Equity Shares. You are allowed a deduction for the excess, if
any, of the adjusted basis of the Equity Shares over their fair market value as of the close of the taxable year. However,
deductions are allowable only to the extent of any net mark-to-market gains on the Equity Shares included in your income for
prior taxable years. Amounts included in your income under a mark-to-market election, as well as gain on the actual sale or
other disposition of the Equity Shares, are treated as ordinary income. Ordinary loss treatment also applies to the deductible
portion of any mark-to market loss on the Equity Shares, as well as to any loss realized on the actual sale or disposition of the
Equity Shares, to the extent that the amount of such loss does not exceed the net mark-to-market gains previously included for
such Equity Shares. Your basis in the Equity Shares will be adjusted to reflect any such income or loss amounts. If you make
such an election, the tax rules that apply to distributions by corporations that are not PFICs generally would apply to
distributions by the Bank, except that the lower applicable capital gains rate with respect to qualified dividend income
(discussed above) would not apply.

The mark-to-market election is available only for “marketable stock”, which is stock that is traded in other than de minimis
quantities on at least 15 days during each calendar quarter on a qualified exchange or other market, as defined in the applicable
USS. Treasury regulations. Under applicable U.S. Treasury regulations, a “qualified exchange” includes a foreign exchange
that is regulated by a governmental authority in the jurisdiction in which the exchange is located and in respect of which certain
other requirements are met. If a US Holder makes a mark-to-market election, it will be effective for the taxable year for which
the election is made and all subsequent taxable years unless the Equity Shares are no longer regularly traded on a qualified
exchange or the IRS consents to the revocation of the election. U.S. Holders of Equity Shares should consult their own tax
advisors as to whether the Equity Shares would qualify for the mark-to-market election.

PROSPECTIVE PURCHASERS ARE URGED TO CONSULT THEIR TAX ADVISOR REGARDING THE
APPLICATION OF THE PFIC RULES TO THEIR INVESTMENT IN EQUITY SHARES, AND THE
AVAILABILITY AND ADVISABILITY OF ANY ELECTIONS.

Information Reporting and Backup Withholding

Dividend payments with respect to the Equity Shares and proceeds from the sale, exchange or redemption of Equity Shares
may be subject to information reporting to the Internal Revenue Service and possible U.S. backup withholding under certain
circumstances.

Backup withholding will not apply, however, to a U.S. Holder who furnishes a correct taxpayer identification number and
makes any other required certification or who is otherwise exempt from backup withholding. U.S. Holders who are required
to establish their exempt status generally must provide such certification on Internal Revenue Service Form W9. U.S. Holders
should consult their tax advisors regarding the application of the U.S. information reporting and backup withholding rules.

Backup withholding is not an additional tax. Amounts withheld as backup withholding may be credited against your United
States federal income tax liability, and you may obtain a refund of any excess amounts withheld under the backup withholding
rules by timely filing the appropriate claim for refund with the Internal Revenue Service and furnishing any required
information.

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