Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697751947677.pdf (Georgia)
Cross-Country Comparative Research on Credit Effective Interest Rates National Bank of Georgia 11 March 2014 Introduction Purpose and the Scope of works Incorporating the results of the cross-country comparative research on credit effective interest rates conducted by KPMG for National Bank of Georgia during December 2013 – January 2014.
The banking products under review included: Product Fixed rate mortgage credits Floating rate mortgage credits Consumer credits (pledged) Consumer credits (non-pledged) Credit cards Corporate credits for capital investments Corporate credits for working capital SME credits for capital investments SME credits for working capital Amount (USD) (equivalent in NC/FC) Maturity (years) 50,000 50,000 10,000 1,500 600 1,500,000 600,000 300,000 150,000 10 10 3 2 n/a 5 2.5 5 2.5 © 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.
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2 Purpose and the Scope of works Initial screening of the in-scope products included leading banks of 11 countries, including Georgia Country Banks Georgia Armenia Azerbaijan Kazakhstan Moldova Poland Romania Russia Serbia Turkey Ukraine Bank of Georgia TBC Bank Ameriabank ACBA Credit Agricole Bank HSBC Bank Armenia International Bank of Azerbaijan Standard Bank Xalq Bank Bank CenterCredit BTA Bank Halyk Bank Kazakhstan Moldova Agroind Victoriabank Bank Pekao PKO Bank Polski BCR BRD Sberbank VTB Group Banca Intesa a.d. Beograd Komercijalna banka a.d. Beograd Türkiye İş Bankası Ziraat Bankası Oschandbank Privatbank © 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.
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3 Purpose and the Scope of works The criteria of selection  The overall banking sector compatibility with the Georgian banking sector  The number of the credit products under review that are offered by the bank  The availability of information on each credit product under review The final list of comparator banks included the following leading banks from 5 countries.
Country Banks Armenia Azerbaijan Kazakhstan Poland Serbia Ameriabank ACBA Credit Agricole Bank HSBC Bank Armenia International Bank of Azerbaijan Standard Bank Xalq Bank Bank CenterCredit BTA Bank Halyk Bank Kazakhstan Bank Pekao PKO Bank Polski Banca Intesa a.d. Beograd Komercijalna banka a.d. Beograd © 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.
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4 Methodology and approach On-desk research of the official websites of the selected banks; E-mail contact with the representatives of the selected banks; Direct contact with the representatives of the selected banks via phone.
Average Exchange Rates for the period of 01 January to 01 December 2013 were taken as a basis The following Interbank reference rates were considered as of 20 December 2013: • • • • 3M Wibor 3M Euribor 6M Euribor 6M Belibor Refinancing rates were taken as of 01 December 2013 (Georgia, Armenia, Kazakhstan)       © 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.
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5 Effective interest rate calculation formula k k– credit amount withdrawal serial number k´– credit payment serial number Ak– amount of the k th order withdrawal A´ ´- amount of the k´ th order payment m– total number of withdrawals m´- total number of payments tk - time interval, expressed in years or fractions, between the first withdrawal and the next withdrawals, k=1,…m tk´ – time interval, expressed in years or fractions, between first payment and following payments, k´=1,…m´ ἰ – effective interest rate © 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.
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6 Effective interest rate calculation formula  The concept of the effective interest rate and the methodology of its calculation of the selected countries are similar to that of Georgia  The financial expenses that should be considered in the calculation of the effective interest rate are as follows:  Payments of the principal amount and the accrued interest  Bank service fees  Commissions, credit withdrawal charges  Mandatory insurance fees  Property valuation charges  Fees defined by state, such as notary fees, credit bureau fees, pledge registration charges, etc.
 All other expenses that are mandatory for obtaining the credit product.

© 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.

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7 Analysis of Banking Products Analysis of banking products: Fixed rate mortgage credits  Polish and Serbian banks do not offer any type of mortgage at fixed rates  Azeri banks do not provide fixed rate mortgages in foreign currency (FC)  One of the Georgian banks does not provide the product in national currency (NC) Weighted average nominal and effective interest rates by country Georgia Armenia Azerbaijan Kazakhstan Poland Serbia Nominal Rate (NC) 15.0% 16.3% 10.5% 12.4% - - Effective Rate (NC) Nominal Rate (FC) Effective Rate (FC) Common expenses Expenses not incurred in Georgia 16.9% 18.2% 12.4% 13.4% - - 12.5% 13.4% - 12.4% - - 14.4% 14.8% - 13.4% - -  Credit commission fee  Insurance fees  Collateral registration charges  Collateral valuation charges  Notary fees  Annual customer account service fees Loans with special terms: Armenian bank ACBA Credit Agricole provides mortgage credits to young families at privileged terms that are subsidized by the Republic of Armenia (RA) Finance Ministry.
© 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.

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9 Analysis of banking products: Fixed rate mortgage credits Weighted average nominal and effective interest rates by country NC credits 20% 18% 16% 14% 12% 10% 8% 6% 4% 2% 0% Azerbaijan Kazakhstan Georgia Armenia FC credits Nominal Rate Effective Rate 16% 14% 12% 10% 8% 6% 4% 2% 0% © 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.
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10 Analysis of banking products: Floating rate mortgage credits (continued)  The floating rate mortgage credits are not popular in the banking sector of Armenia, Azerbaijan and Kazakhstan  In Poland and Serbia mortgage credits are provided only at floating rates  Mortgage credits at floating interest rates are not provided by any top 5 Azeri bank  The floating mortgages are not provided in foreign currency by the Georgian banks, the Kazakh comparator bank and one of the comparators in Poland  The floating rates are linked to the refinancing rate defined by the central banks of each respective country in case of Georgia, Armenia and Kazakhstan  In Poland and Serbia the rates are linked to the interbank reference rates, such as Euribor, Wibor and Belibor © 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.
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11 Analysis of banking products: Floating rate mortgage credits (continued) Weighted average nominal and effective interest rates by country Georgia Armenia Azerbaijan Kazakhstan Poland Serbia Nominal Rate (NC) Effective Rate (NC) Nominal Rate (FC) Effective Rate (FC) 7.4% 10.5% - 13.5% 5.5% 8.9% 8.8% 11.6% - 15.5% 7.0% 10.4% - 11.3% - 13.5% 3.9% 5.8% - 12.5% - 15.5% 6.3% 6.9% Common expenses Expenses not incurred in Georgia  Credit commission fee  Insurance fees, both for borrower’s life insurance and the insurance of the collateral  Mandatory fixed insurance charges  Pledge valuation charges  Collateral registration charges Loans with special terms:  Notary fees  Credit Bureau query charges The Serbian banks provide mortgage credits insured at the National Mortgage Insurance Corporation (NMIC) founded by the Serbian Government.
© 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.

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12 Analysis of banking products: Floating rate mortgage credits Weighted average nominal and effective interest rates by country NC credits FC credits 18% 16% 14% 12% 10% 8% 6% 4% 2% 0% 18% 16% 14% 12% 10% 8% 6% 4% 2% 0% Poland Serbia Armenia Kazakhstan Poland Georgia Serbia Armenia Kazakhstan Nominal Rate Effective Rate © 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.
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13 Analysis of banking products: Pledged Consumer Credits  Armenian comparators do not offer pledged consumer credits in foreign currency  Polish comparators do not offer pledged consumer credits in foreign currency Weighted average nominal and effective interest rates by country Georgia Armenia Azerbaijan Kazakhstan Poland Serbia Nominal Rate (NC) Effective Rate (NC) Nominal Rate (FC) Effective Rate (FC) 15.1% 24.0% 19.4% 14.4% 11.5% 21.2% 19.2% 29.3% 21.7% 17.1% 13.7% 25.7% 15.1% - 19.0% 14.4% - 16.5% 19.2% - 20.9% 17.1% - 19.9% Expenses to be considered  Credit commission fees are common in all comparator countries  Insurance fees are considered non mandatory, hence they are not considered in the calculation of the effective interest rates  Other expenses, if such exist, mainly relate to the credit processing fees and credit bureau query fees © 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.
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14 Analysis of banking products: Pledged Consumer Credits Weighted average nominal and effective interest rates by country NC credits FC credits 35% 30% 25% 20% 15% 10% 5% 0% Poland Kazakhstan Georgia Azerbaijan Serbia Armenia 25% 20% 15% 10% 5% 0% Nominal Rate Effective Rate Kazakhstan Georgia Serbia Azerbaijan © 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.
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15 Analysis of banking products: Non-Pledged consumer credits  The interest rates and financial expenses do not significantly vary from the pledged consumer credit products, so as: - The Georgian and Armenian banks provide non-pledged and pledged consumer credits at the same rates and terms - In case of other banks, the non-pledged consumer credits are offered at slightly higher interest rates  The non-pledged credits are not offered by the Armenian and Polish comparators in foreign currency Weighted average nominal and effective interest rates by country Georgia Armenia Azerbaijan Kazakhstan Poland Serbia Nominal Rate (NC) Effective Rate (NC) Nominal Rate (FC) Effective Rate (FC) 15.1% 24.0% 22.0% 16.4% 14.3% 20.5% 18.8% 29.9% 25.0% 19.2% 17.6% 26.1% 15.1% - 22.0% - - 15.3% 18.8% - 24.6% - - 19.6% Expenses to be considered  Credit commission fees are common in all the comparator countries  Other expenses, if such exist, mainly relate to the credit processing fees and credit bureau query fees © 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.
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16 Analysis of banking products: Non-pledged Consumer Credits Weighted average nominal and effective interest rates by country NC credits FC credits 35% 30% 25% 20% 15% 10% 5% 0% Poland Georgia Kazakhstan Azerbaijan Serbia Armenia 30% 25% 20% 15% 10% 5% 0% Nominal Rate Effective Rate Georgia Serbia Azerbaijan © 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.
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17 Analysis of banking products: Credit cards  The comparator banks do not differentiate the nominal interest rates for credit card used for cash or trade operations - In Georgian banks the usage of the credit card in cash operations has much higher interest rate compared to trade operations - In case of the comparators, the difference is reflected in the disbursement fees.
Weighted average nominal and effective interest rates by country (cash operations) Nominal Rate (NC) Effective Rate (NC) Nominal Rate (FC) Effective Rate (FC) Georgia Armenia Azerbaijan Kazakhstan Poland Serbia 36.0% 21.7% 24.3% 22.7% 16.0% 26.7% 53.8% 26.9% 27.5% 30.6% 23.8% 32.6% 20.3% 20.5% 24.3% 22.7% - 21.1% 30.4% 25.5% 27.5% 30.6% - 25.6% Weighted average nominal and effective interest rates by country (trade operations) Effective Rate (NC) Nominal Rate (NC) Nominal Rate (FC) Effective Rate (FC) Georgia Armenia Azerbaijan Kazakhstan Poland Serbia 19.1% 21.7% 24.3% 22.7% 16.0% 26.7% 20.9% 24.0% 27.1% 25.3% 19.1% 31.8% 11.3% 20.5% 24.3% 22.7% 0.0% 21.1% 12.4% 22.6% 27.1% 25.3% 0.0% 24.8% © 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.
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18 Analysis of banking products: Credit cards Weighted average nominal and effective interest rates by country (cash operations) NC credits FC credits 60.0% 50.0% 40.0% 30.0% 20.0% 10.0% 0.0% Poland Armenia Azerbaijan Kazakhstan Serbia Georgia 35.0% 30.0% 25.0% 20.0% 15.0% 10.0% 5.0% 0.0% Armenia Serbia Azerbaijan Georgia Kazakhstan Nominal Rate Effective Rate © 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.
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19 Analysis of banking products: Credit cards Weighted average nominal and effective interest rates by country (trade operations) NC credits FC credits 35% 30% 25% 20% 15% 10% 5% 0% 30% 25% 20% 15% 10% 5% 0% Poland Georgia Armenia Kazakhstan Azerbaijan Serbia Georgia Armenia Serbia Kazakhstan Azerbaijan Nominal Rate Effective Rate © 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.
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20 Analysis of banking products: Corporate credits for capital investments  Standard Bank (Azerbaijan) and BTA Bank (Kazakhstan) do not provide any indicative interest rates and estimates on other terms and conditions.
Weighted average nominal and effective interest rates by country Nominal Rate Effective Rate Georgia Armenia Azerbaijan Kazakhstan Poland Serbia 11.0% 14.7% 18.0% 12.5% 6.3% 6.9% 11.8% 16.2% 19.6% 13.3% 7.2% 7.7% Expenses that should be considered in the effective interest rate calculation:  Credit commission fees are common in all comparator countries  Valuation fees (business or property that serves as a collateral), for which we could not obtain any estimates from banks, since they can be indicated only with regards to a particular object/business Loans with special terms:  Ameriabank (Armenia) provides special corporate credits for the renewable energy sector.
The credit is financed by the projects of International Finance Corporation (IFC) and FMO Entrepreneurial Development Bank.

 The Serbian bank Komercijalna Banca provides agricultural credits for purchase of new agricultural machinery with the guarantee, as well as agricultural credits for local economic development in the Balkans.
© 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.

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21 Analysis of banking products: Corporate credits for capital investments Weighted average nominal and effective interest rates by country FC credits 25% 20% 15% 10% 5% 0% Nominal Rate Effective Rate Poland Serbia Georgia Kazakhstan Armenia Azerbaijan © 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.
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22 Analysis of banking products: Corporate credits for working capital Weighted average nominal and effective interest rates by country Nominal Rate Effective Rate Georgia Armenia Azerbaijan Kazakhstan Poland Serbia 11.0% 14.7% 15.8% 12.5% 6.3% 13.6% 11.9% 16.6% 17.2% 13.3% 7.8% 15.6% Expenses that should be considered in the effective interest rate calculation:  Credit commission fees are common in all comparator countries  Valuation fees (business or property that serves as a collateral), for which we could not obtain any estimates from banks, since they can be indicated only with regards to a particular object/business Loans with special terms:  Banca Intesa provides loans for investments and durable working assets from the credit line of European Fund for Southeast Europe (EFSE) on the basis of the framework agreement for the assignment of individual loans signed with EFSE, as well from the Fund for Local Economic Development in the Balkans (LEDIB) based on an agreement with the Kingdom of Denmark.
© 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.

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23 Analysis of banking products: Corporate credits for working capital Weighted average nominal and effective interest rates by country NC credits 20% 18% 16% 14% 12% 10% 8% 6% 4% 2% 0% Nominal Rate Effective Rate Poland Georgia Kazakhstan Serbia Armenia Azerbaijan © 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.
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24 Analysis of banking products: SME credits for capital investments  Standard Bank (Azerbaijan) and BTA Bank (Kazakhstan) do not provide any indicative interest rates and estimates on other terms and conditions.
Weighted average nominal and effective interest rates by country Nominal Rate Effective Rate Georgia Armenia Azerbaijan Kazakhstan Poland Serbia 12.0% 15.2% 18.0% 16.5% 4.2% 10.9% 12.8% 16.9% 19.6% 18.4% 4.9% 12.1% Expenses that should be considered in the effective interest rate calculation:  Credit commission fees are common in all comparator countries  Valuation fees (business or property that serves as a collateral), for which we could not obtain any estimates from banks, since they can be indicated only with regards to a particular object/business Loans with special terms:  Banca Komercijalna: loans from the Credit Line of the Italian Government and from the credit line of the EBRD Credit Line for financing the purchase of equipment, technologies, services, spare parts and industrial licenses of the SME.
 Halyk Bank: loans from the fund of DAMU Entrepreneurship Development Fund JSC for capital expenditures of SME.

 BTA Bank: loans financed by the Business road map 2020 program within the frameworks of the Decree of the Government of the Republic of Kazakhstan to support particularly new business initiatives.

 Bank Pekao: loans for SMEs with free of charge guarantees of the European Investment Fund (EIF) provided under the European Community's Competitiveness and Innovation Framework Program.
© 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.

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25 Analysis of banking products: SME credits for capital investments Weighted average nominal and effective interest rates by country FC credits 25% 20% 15% 10% 5% 0% Nominal Rate Effective Rate Poland Serbia Georgia Armenia Kazakhstan Azerbaijan © 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.
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26 Analysis of banking products: SME credits for working capital  Standard Bank (Azerbaijan) and BTA Bank (Kazakhstan) do not provide any indicative interest rates and estimates on other terms and conditions.
Weighted average nominal and effective interest rates by country Nominal Rate Effective Rate Georgia Armenia Azerbaijan Kazakhstan Poland Serbia 13.0% 15.8% 15.8% 16.5% 4.2% 17.9% 14.2% 18.1% 17.2% 18.8% 5.6% 20.9% Expenses that should be considered in the effective interest rate calculation:  Credit commission fees are common in all comparator countries  Valuation fees (business or property that serves as a collateral), for which we could not obtain any estimates from banks, since they can be indicated only with regards to a particular object/business Loans with special terms:  Banca Komercijalna: loans from the Credit Line of the Italian Government and from the credit line of the EBRD Credit Line for financing the purchase of equipment, technologies, services, spare parts and industrial licenses of the SME.
 Halyk Bank: loans from the fund of DAMU Entrepreneurship Development Fund JSC for capital expenditures of SME.

 BTA Bank: loans financed by the Business road map 2020 program within the frameworks of the Decree of the Government of the Republic of Kazakhstan to support particularly new business initiatives.

 Bank Pekao: loans for SMEs with free of charge guarantees of the European Investment Fund (EIF) provided under the European Community's Competitiveness and Innovation Framework Program.
© 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.

All rights reserved.
27 Analysis of banking products: SME credits for working capital Weighted average nominal and effective interest rates by country NC credits 25% 20% 15% 10% 5% 0% Nominal Rate Effective Rate Poland Georgia Azerbaijan Armenia Kazakhstan Serbia © 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.
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28 Q&A KPMG in Banking in Georgia and Armenia Georgia Client name JSC TBC Bank JSC TBC Bank ProCredit Bank IS Bank Basis Bank Service description Senior Management Remuneration System review Tax advice Armenia Client name Service description International Undisclosed Bank Pre-investment due-diligence to International Bank in its acquisition of an Armenian bank.
Anelik Bank CJSC Inecobank CJSC IT Advisory services HR Advisory Services Audit of Financial Statements Converse Bank CJSC Developing a marketing plan for attracting corporate customers.

Armimpexbank CJSC Development and implementation of “a one window” system.

Byblos Bank Armenia CJSC Study of the commercial and retail lending market of Armenia.

Ardshininvestbank CJSC Development and implementation of “a one window” system.
© 2014 KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.

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30 Thank you!


© KPMG Georgia LLC, a Organization incorporated under the Laws of Georgia, a part of the KPMG Europe LLP, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.

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