Shinhan Financial Group

U.S. Section 165(d) Reduced Resolution Plan

Public Section

December 20, 2018

This document contains forward-looking statements. Statements that are not historical facts, 

including statements about Shinhan Financial Group’s beliefs and expectations, are 

forward-looking statements. These statements are based on current plans, estimates and 

projections, and therefore undue reliance should not be placed on them. The forwardlooking information contained in this document is presented for the purpose of interpreting 

the information contained herein and may not be appropriate for other purposes. Forwardlooking statements speak only as of the date they are made, and Shinhan Financial Group 

undertakes no obligation to update publicly any of them in light of new information or 

future events.
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Table of Contents

A.PUBLIC SECTION................................................................................................................................ 2

A.1 Introduction .......................................................................................................................................... 2

A.1.1 Overview of Shinhan Financial Group (SFG).....................................................................................................2

A.1.2 Overview of SFG’s U.S. Operations...................................................................................................................4

A.2 Summary of the Resolution Plan ............................................................................................................ 4

A.2.1 Overview of U.S. Resolution Plan .....................................................................................................................4

A.2.2 Material Entities...............................................................................................................................................4

A.2.3 Description of Core Business Lines...................................................................................................................4

A.3 Summary of Financial Information Regarding Assets, Liabilities, Capital and Major Funding Sources....... 5

A.3.1 Capital Adequacy..............................................................................................................................................6

A.3.2 Major Funding Sources.....................................................................................................................................7

A.4 Memberships in Material Payment, Clearing, and Settlement Systems................................................... 7

A.5 Description of Foreign Operations.......................................................................................................... 8

A.6 Material Supervisory Authorities ........................................................................................................... 8

A.7 Principal Officers ................................................................................................................................... 9

A.7.1 Executive Directors...........................................................................................................................................9

A.7.2 Non-Executive and Outside Directors ..............................................................................................................9

A.7.3 Executive Officers...........................................................................................................................................10

A.8 Resolution Planning Corporate Governance Structure and Processes.....................................................10

A.9 Material Management Information Systems.........................................................................................11

A.10 Resolution Strategy Summary ...............................................................................................................11
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A.Public Section

A.1 Introduction

Shinhan Financial Group Co., Ltd. (“SFG”) is a foreign banking organization duly organized and existing 

under the laws of Korea. SFG’s subsidiary, Shinhan Bank has established a New York state-licensed branch 

in New York (“SHBNY”). SFG also has a wholly-owned insured depository subsidiary, Shinhan Bank America 

(“SHBA”). In addition, SFG’s subsidiary, Shinhan Investment Corp., Korea has established a wholly-owned, 

registered broker-dealer, Shinhan Investment America (“SIA”). This resolution plan (the “U.S. Resolution 

Plan”) is being filed by SFG pursuant to Section 165(d) of the Dodd-Frank Wall Street Reform and 

Consumer Protection Act (the “Dodd-Frank Act”) and implementing regulations issued by the Board of 

Governors of the Federal Reserve System (“FRB”) (12. C.F.R Part 243) and the Federal Deposit Insurance 

Corporation (“FDIC”) (12 C.F.R. Part 381) (collectively, the “Regulation”).

Section 165(d) of the Dodd-Frank Act and the Regulation require a foreign bank or company that is, or is 

treated as, a banking holding company under section 8(a) of the International Banking Act of 1978 (the 

“IBA”) [12 U.S.C. §§101 et sea.] and that has $50 billion or more in total consolidated assets to submit 

annually a plan for the rapid and orderly resolution of the U.S. operations of a “covered company” in the 

event of material financial distress of failure. Foreign-based covered companies with less than $100 billion 

in total U.S. nonbank assets submit their initial resolution plan to the FRB and the FDIC on or before 

December 31, 2013. After the initial plan is submitted, each company is required to submit an updated 

resolution plan annually on or before the anniversary date of the date for submission of its initial plan.

SFG is treated as a bank holding company under Section 8(a) of the IBA, because it controls Shinhan Bank 

which maintains both a branch office and a subsidiary in the U.S. Accordingly, SFG is a “foreign based 

covered company” subject to the Regulation. 

This Public section of the U.S. Resolution Plan provides an executive summary of SFG’s overall resolution 

strategy. All financial information included in this U.S. resolution are as of December 31, 2017, SFG’s fiscal 

year-end. 

A.1.1 Overview of Shinhan Financial Group (SFG)

Incorporated on September 1, 2001, SFG is the first privately-held financial holding company to be 

established in Korea. According to reports by the Financial Supervisory Service, SFG is the largest financial 

services provider in Korea as measured by total assets as of December 31, 2017 and operates the second

largest banking business (as measured by consolidated total assets as of December 31, 2017) and the 

largest credit card business (as measured by the total credit purchase volume as of December 31, 2017) 

in Korea.

SFG has 14 direct subsidiaries and 25 indirect subsidiaries offering a wide range of financial products and 

services, including commercial banking, credit card, life insurance and securities brokerage. As parts of its 

global operations, it has 178 officesin the United States, Canada, the United Kingdom, Japan, the People’s 
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Republic of China, Germany, India, Australia, Hong Kong, Vietnam, Cambodia, Kazakhstan, Singapore, 

Mexico, Uzbekistan, Myanmar, Poland, Indonesia, Philippines and the United Arab Emirates. While SFG

has a number of overseas branches and subsidiaries, substantially all of SFG’s assets are located, and 

substantially all of SFG’s revenues are generated, in Korea. 

SFG provides comprehensive financial services, principally consisting of commercial banking services, 

credit card services, securities brokerage services, life insurance services, etc. 

A.1.1.1 Commercial Banking Services

Commercial banking services consist of retail banking, corporate and investment banking, international 

banking, and other banking services. Retail banking services include mortgage and home equity lending 

and retail lending as well as demand, savings and fixed deposit-taking, checking account services, 

electronic banking and ATM services, bill paying services, payroll and check-cashing services, currency 

exchange and wire fund transfer. SFG provides corporate banking services, primarily through Shinhan 

Bank, to small-and medium sized enterprises, including enterprises known as SOHO, or “small office, 

home office”, which are small enterprises operated by individuals or households, and, to a lesser extent, 

to large corporations, including corporations that are affiliated with chaebols1. International banking 

services include foreign currency-denominated securities trading, foreign exchange trading and services, 

trade-related financial services, international factoring services, and foreign banking operations through 

its overseas branches and subsidiaries.

A.1.1.2 Credit Card Services

SFG provides credit card services principally through its credit card subsidiary, Shinhan Card, and to a 

limited extent, through Jeju Bank. Credit card services include credit card services, cash advances, 

installment purchases, and card loans. Revenue is generated from annual membership fees paid by credit 

cardholders, interest charged on credit card balances, fees and interest charged on cash advances and 

card loans, interest charged on late and deferred payments, and merchant fees paid by retail and service 

establishments. Merchant fees and interest on cash advances constitute the largest sources of revenue.

A.1.1.3 Life Insurance Services

SFG provides life insurance products and services primarily through Shinhan Life Insurance. Life insurance 

services are provided through diversified distribution channels consisting of financial planners, 

telemarketers, agency marketers, and banc assurance specialists.

A.1.1.4 Securities Brokerage Services

Through Shinhan Investment Corp., SFG provides a wide range of financial investment services to SFG’s 

diversified customer base including corporations, institutional investors, governments, and individuals. 

Brokerage services include brokerage of stocks, corporate bonds, futures and options provided to Shinhan 

Investment Corp.’s institutional and international customers and sales of institutional financial products. 

These services are supported by a team of approximately 72 research analysts that specialize in equity, 

bonds, and derivative research as of December 31, 2017.

 1 A chaebol is a South Korean form of business conglomerate.
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A.1.2 Overview of SFG’s U.S. Operations

In the United States, SFG operates a wholly-owned insured depository subsidiary, Shinhan Bank America, 

an uninsured branch of Shinhan Bank, Korea, in New York, and a registered broker-dealer, Shinhan 

Investment America, which is a wholly-owned subsidiary of Shinhan Investment Corp., Korea. In the 

United States, SFG has the following business lines: corporate and wholesale banking, retail banking, and 

securities brokerage.

A.2 Summary of the Resolution Plan

A.2.1 Overview of U.S. Resolution Plan

SFG has limited operations in the United States which includes corporate banking, retail banking, and 

brokerage services. SFG’s U.S. Resolution Plan is intended to provide the FRB and the FDIC with an 

explanation of SFG’s plan for the rapid and orderly resolution of its U.S. operations in the event of the 

material financial distress or failure of the Covered Company. The U.S. Resolution Plan includes the 

information required by the Regulation, including a description of SFG’s banking operations and core 

business lines that are conducted in whole or in material part in the U.S.

A.2.2 Material Entities

Under the Regulation, a “material entity” is a subsidiary or foreign office of the covered company that is 

significant to the activities of a critical operation or a core business line. “Critical operations” are those 

operations, including associated services, functions, and support, the failure or discontinuance of which

would pose a threat to the financial stability of the United States. “Core business lines” are those business 

lines, including associated operations, services, functions, and support that, in the covered company’s 

view, upon failure would result in a material loss of revenue, profit, or franchise value.

SFG has determined that it does not have any critical operationsthat, upon their failure or discontinuance, 

would pose a threat to the financial stability of the United States. Overall, the relatively limited scope, 

nature, and volume of SFG’s U.S. operations are such that their failure or discontinuance would not pose 

a threat to the stability of the U.S. financial system.

SFG has also determined that it had no core business lines based on analysis performed on a quantitative,

as well as, a qualitative basis. On a qualitative basis, failure of SFG’s U.S. operations would not have a 

material effect on the overall franchise value of the company. As such, SFG determined that none of the 

business lines conducted in the United States should be considered as a core business line for the purposes 

of this U.S. Resolution Plan. 

Because none of the business lines of SFG that are conducted in the United States have been determined 

to be a “core business line” or a “critical operation”, SFG determined that it has no material entities for 

the purposes of this Resolution Plan.

A.2.3 Description of Core Business Lines

As noted above, for purpose of the U.S. Resolution Plan, SFG has identified no core business lines. None 

of the business lines in their U.S. operations is significant in quantitative aspects when compared to the 
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global financials of SFG. In addition to the above quantitative analysis, a qualitative analysis was used to 

determine whether the business lines operating in the United States would have a material effect on the 

overall franchise value of SFG. Pursuant to SFG’s qualitative and quantitative analyses, no core business 

lines were identified. A brief summary of SFG’s business lines operating in the U.S. is provided in the 

sections that follow.

A.2.3.1 Shinhan Bank New York Branch (“SHBNY”)

SHBNY conducts Corporate Banking operations including buying, paying and collecting bills, issuing letters 

of credit, and granting loans. SHBNY has extensive transactions and relationship with the Head office in 

Korea, other branches, and affiliates.

A.2.3.2 Shinhan Bank America (“SHBA”)

SHBA provides comprehensive financial services for small-to-medium sized business owners, with a focus 

on the Korean-American market, primarily in the New York-metropolitan and Southern California areas. 

These financial services are mainly for corporate and retail banking. SHBA specializes in commercial loans, 

which are mostly secured by real property, to multiethnic and small business customers. In addition, SHBA

is a preferred lender of Small Business Administration (SBA) loans and provides trade finance loans. 

A.2.3.3 Shinhan Investment America Inc. (“SIA”)

SIA engages primarily in broker and dealer transactions for Korean securities. Its principal customers are 

institutions in the U.S. investing in Asian market. SIA has a clearing agreement with Shinhan Investment 

Corporation, the parent company, whereby Shinhan Investment Corporation clears Korean security 

transactions for the SIA’s customers and carries such accounts on a fully disclosed basis as Shinhan 

Investment Corporation’s customers. Accordingly, SIA does not carry customer accounts and does not 

receive, deliver, or hold cash or securities in connection with such transactions. 

A.3 Summary of Financial Information Regarding Assets, Liabilities, Capital 

and Major Funding Sources

The following table is summary of consolidated financial information under IFRS as of December 31, 2017

for SFG. Please refer to SFG’s annual report for the 2017 fiscal year filed with the Securities and Exchange 

Commission (“SEC”) (Form 20-F) for the further detail.

Exhibit A-1: Consolidated Balance Sheet

As of December 31

2013 2014 2015 2016 2017

(In billions of Won and millions of US$, except per common share data)

Assets

Cash and due from banks ₩16,473 ₩20,585 ₩22,024 ₩19,181 ₩22,669 $21,237 

Trading assets 18,033 24,362 22,638 26,696 28,464 26,667

Financial assets designated at 

fair value through profit or 

loss

3,361 2,737 3,244 3,416 3,579 3,353

Derivative assets 1,717 1,568 1,995 3,003 3,400 3,185

Loans, net 205,723 221,618 246,441 259,011 275,566 258,165

Available-for-sale financial 

assets 33,597 31,418 33,966 37,663 42,117 39,458
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Held-to-maturity financial 

assets 11,031 13,373 16,192 19,805 24,991 23,413

Property and equipment, net 3,214 3,147 3,055 3,146 3,022 2,831

Intangible assets, net 4,226 4,153 4,266 4,227 4,272 4,002

Investments in associates 329 342 393 354 631 591

Current tax receivable 6 11 10 13 25 23

Deferred tax assets 196 228 164 641 592 555

Investment properties, net 690 268 209 353 418 392

Other assets, net 12,451 14,203 15,947 18,167 16,552 15,508

Assets held for sale 243 9 4 4 8 7

Total assets ₩311,290 ₩338,022 ₩370,548 ₩395,680 ₩426,306 $399,387 

Liabilities

Deposits ₩178,810 ₩193,710 ₩217,676 ₩235,138 ₩249,419 $233,670 

Trading liabilities 1,258 2,689 2,135 1,977 1,848 1,732

Financial liabilities designated 

at fair value through profit 

or loss

5,909 8,996 8,916 9,234 8,298 7,774

Derivative liabilities 2,019 1,718 2,599 3,528 3,488 3,267

Borrowings 20,143 22,974 21,734 25,294 27,587 25,845

Debt securities issued 37,491 37,335 41,221 44,327 51,341 48,099

Liability for defined benefit 

obligations 118 309 226 131 7 7

Provisions 750 694 699 729 429 402

Current tax payable 239 257 142 273 349 327

Deferred tax liabilities 15 10 16 11 10 9

Liabilities under insurance 

contracts 15,662 17,776 20,058 22,377 24,515 22,967

Other liabilities 19,021 21,039 23,313 20,916 25,312 23,714

Total liabilities ₩281,435 ₩307,507 ₩338,735 ₩363,935 ₩392,603 $367,813 

Equity

Capital stock ₩2,645 ₩2,645 ₩2,645 ₩2,645 ₩2,645 $2,478 

Hybrid bond 537 537 737 498 424 397

Capital surplus 9,887 9,887 9,887 9,887 9,887 9,263

Capital adjustments (393) (393) (424) (458) (398) (373)

Accumulated other 

comprehensive income 673 638 305 (102) (530) (496)

Retained earnings 14,189 15,870 17,690 18,640 20,791 19,478

Total equity attributable to 

equity holders of the Group 27,538 29,184 30,840 31,110 32,819 30,747

Non-controlling interest 2,317 1,331 973 635 884 827

Total equity ₩29,855 ₩30,515 ₩31,813 ₩31,745 ₩33,703 $31,574 

Total liabilities and equity ₩311,290 ₩338,022 ₩370,548 ₩395,680 ₩426,306 $399,387 

A.3.1 Capital Adequacy

At December 31, 2017, SFG’s consolidated capital ratios were maintained at a high level, with a Tier 1 

Capital Ratio of 13.32%, a Tier 2 Capital Ratio of 1.46% and a Total Capital Ratio of 14.78%.

SHBA’s capital ratios at December 31, 2017 were maintained at a high level, with a Tier 1 Capital Ratio of 

15.50%, a Tier 2 Capital ratio of 0.86% and a Total Capital Ratio of 16.36%.
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SHBNY and SIA do not have a stand-alone capital requirement; however it could become subject to asset 

maintenance requirements imposed by the NYDFS in certain circumstances.

A.3.2 Major Funding Sources

SFG obtainsfunding from a variety of sources, both domestic and foreign. SFG’s principal source of funding 

is customer deposits obtained from its banking operations and proceeds from the issuance of equity and 

debt securities. In addition, SFG’s subsidiaries acquire funding through call money, borrowings from the 

Bank of Korea, other short-term borrowings, corporate debentures, other long-term debt, and assetbacked securitizations. 

SFG’s sources of funds consist of deposits of KRW 249,419 billion, long-term debt of KRW 53,140 billion, 

other short-term borrowing of KRW 14,375 billion, call money of KRW 857 billion, borrowing from the 

Bank of Korea of KRW 2,913 billion, asset securitization of KRW 9,056 billion, and stockholder’s equity of 

KRW 2,645 billion. The majority of deposits come from Shinhan Bank of KRW 242,654 billion.2

A.4 Memberships in Material Payment, Clearing, and Settlement Systems

Both SHBNY and SHBA are members of certain U.S. payment, clearing, and settlementsystems that enable 

them to access systems necessary to service their customers and clients. As SIA is an introducing broker 

and does not hold customer accounts, it does not use any trading, payment, clearing, or settlement 

systems. The following is the list of SHBNY and SHBA’s memberships in material payment, clearing, and 

settlement systems;

Exhibit A-2: Memberships in Payment, Clearing, and Settlement Systems

Entity Holding Membership Name Description 

SHBNY Fedline Advantage Services Access to FRB-provided advanced 

payment service, Fedwire Funds Service

CitiDirect Access control for backup bank wire 

services

Fedwire US Dollar Payment System / US Clearing 

Securities Settlement / FI Depository

SHBA Fiserv EFT Debit Network

ACCEL Debit Network

STAR Debit Network

PLS2 Debit Network

NYCE Debit Network

CIRRUS Debit Network

VISA Debit Network

EDS Debit Network

PULSE Debit Network

 2 Source: 2017 Audited Consolidated Financial Statement for Shinhan Bank.
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Entity Holding Membership Name Description 

ACH Electronic Network for Financial 

Transactions in the US

DTCC US Clearing / Settlement Systems, USD 

Payment System, Securities System

Fedwire US Dollar Payment System / US Clearing 

Securities Settlement / FI Depository

FRB Check Processing U.S. Check Clearing

A.5 Description of Foreign Operations

As described in greater detail in Section A.1.1, SFG is a global banking organization that provides services

mainly to corporate and retail clients through its domestic and overseas operations.

As demonstrated in the table below, most of SFG’s income comes from its Korean operations. The 

exchange rate of 1,067.4 is based on the Noon Buying Rate in the City of New York on December 29, 2017 

for cable transfers according to the H.10 statistical release of the Federal Reserve Board.

Exhibit A-3: SFG Income by Geographic Area as of Dec 31, 2017

Geographic Areas Operating Income

($ million)

Domestic (Korea) $3,282 

U.S.A 44

Other foreign countries 261 

Total $3,587

Source: 2017 Form 20-F and financial statements of SFG’s U.S. operation

The following table provides information of non-current assets by geographical area as of December 31,

2017.

Exhibit A-4: SFG Non-Current Assets by Geographical Area as of Dec 31, 2017

Geographic Areas Non-Current Assets

($ million)

Domestic (Korea) $7,039 

U.S.A 21

Other foreign countries 165 

Total $7,225

Source: 2017 Form 20-F and financial statements of SFG’s U.S. operation

A.6 Material Supervisory Authorities

The consolidated operations of SFG, including its subsidiaries and overseas offices, are subject to 

supervision and regulation under the applicable laws and regulations of the countries in which it operates. 
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SFG in Korea is preliminarily supervised by the Korean Financial Supervisory Service (“FSS”), which is the 

executive body of the Financial Services Commission of Korea (“FSC”). 

SHBNY is licensed by the state banking authority of the State of New York and is therefore subject to 

regulation and examination by the New York State Department of Financial Services (“NYSDFS”). SHBNY 

is also subject to regulation by the FSS, as long as it does not conflict against local laws and regulations.

SHBA is regulated by the NYSDFS, as its chartering authority, but it is also regulated by Federal Deposit 

Insurance Corporation (FDIC), as its primary federal banking regulator and as the insurer of its deposits. 

SFG is also a financial holding company and a bank holding company under U.S. banking laws, and its’ U.S. 

operations are subject to regulation, supervision and enforcement by the Federal Reserve. SHBA is also 

subject to regulation by the FSS, as long as it does not conflict against local laws and regulations.

SIA is regulated primarily by Financial Industry Regulatory Authority (FINRA). SIA also has regulatory 

obligations to the FSS, as long as it does not conflict against local laws and regulations

The table below provides a full listing of regulators by legal entity.

Exhibit A-5: Regulators by Legal Entity

Legal Entity Primary Regulator Other Regulators

SFG • Korean Financial Supervisory Services (FSS) • The Board of Governors of the Federal 

Reserve System

SHBNY • New York State Department of Financial Services (NYSDFS)

• Federal Reserve Bank of New York

• Korean Financial Supervisory Services

(FSS)

SHBA • New York State Department of Financial Services (NYSDFS)

• Federal Deposit Insurance Corporation (FDIC)

• Korean Financial Supervisory Services 

(FSS)

SIA • Financial Industry Regulatory Authority (FINRA) • Korean Financial Supervisory Services

(FSS)

A.7 Principal Officers

The tables below list Directors and Senior Management of SFG as of October 31, 2018.

A.7.1 Executive Directors

Name Position 

Yong Byoung Cho Chairman and Chief Executive Officer 

A.7.2 Non-Executive and Outside Directors

Name Position 

Sung Ho Wi Non-Executive Director

Cheul Park Outside Director

Man Woo Lee Outside Director

Yuki Hirakawa Outside Director

Phillippe Avril Outside Director
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Name Position 

Steven Sungryang Lee Outside Director

An Soon Park Outside Director

Jae Seong Joo Outside Director

Hwa nam Kim Outside Director

Byoung dae Park Outside Director

Kyong rok Choi Outside Director

A.7.3 Executive Officers

Name Position In charge of

Dong hwan Lee Deputy President • Group & Global Investment Banking Business Group

Young woong Woo Deputy President • Strategic Planning Team 

• Investor Relations Team

• Future Strategy Research Institute

• Digital Strategy Team

• One Shinhan Strategy Team

• Platform Marketing Team

Ok dong Jin Deputy President • Brand Strategy Team

• Management Support Team

• Human Resource Team

• Shinhan Culture & Leadership Center

• Corporate Social Responsibility Team

Byeong cheol Kim Deputy President • Global Markets & Securities Group

Young taeg Heo Deputy President • Global Business Group

Chang goo Lee Deputy President • Wealth Management Group

A.8 Resolution Planning Corporate Governance Structure and Processes

SFG has integrated resolution planning into its corporate governance structure and established processes 

to ensure that the U.S. Resolution Plan received appropriate oversight from designated senior 

management officials, councils, and the Board of Directors. As such, SFG established the following 

committees and working groups to provide oversight of the resolution planning process:

• Shinhan Financial Group Resolution Plan Managing Group

• The Office of U.S. Resolution Plan Review (the “U.S. RPR”)

• The Office of U.S. Resolution Planning (the “ORP”)

Shinhan Financial Group Resolution Plan Managing Group had primary responsibility for oversight of the 

U.S. resolution planning efforts and the annual Resolution Plan submitted to U.S. regulators. Shinhan 

Financial Group Resolution Plan Managing Group’s members consist of Executive Vice President from the 

Global Business & Capital Market Team, Group Chief Risk Officer and Group Chief Compliance Officer of 

SFG.
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The U.S. RPR is a subcommittee of Shinhan Financial Group Resolution Plan Managing Group established 

to assist the Group in the approval process. The main function of the U.S. RPR was to gather all 

representatives of each entity with operations in the U.S. to review and discuss all issues related to U.S. 

resolution planning effort. It consists of senior executives from the Global Business & Capital Market Team 

and Global Business division.

The ORP provided day-to-day project management and functional leadership for oversight, development, 

maintenance, implementation, filing, and compliance of resolution plan, as well as, updating the contents 

of the Resolution Plan as part of BAU(Business-as-Usual) processes.

SFG’s U.S. Resolution Plan was prepared by the Working Group, comprising representatives from each of 

SFG’s U.S. entities. The Plan was reviewed and approved by business approvers with oversight from the 

ORP. After business approval, the Plan was also reviewed by the U.S. RPR and the Shinhan Financial Group 

Resolution Planning Managing Group before submission to the Delegee of the Board of Directors who 

provided final approval of the SFG’s U.S. Resolution Plan.

In its capacity, the Board of Directors is the most senior management body of SFG. The Board of Directors, 

located in Seoul, Korea, was ultimately responsible for evaluating and approving the SFG’s U.S. Resolution 

Plan. For SFG, however, the Board of Directors will delegate the responsibility of approval of the 

Resolution Plan to the CEO of SFG.

Clear roles and responsibilities were defined to ensure effective working processes and compliance with 

decision-making authorities. These include processes for the preparation, verification, and sign off on the 

U.S resolution plan at the global and local levels. This ensured that senior management, the Shinhan 

Financial Group Resolution Plan Managing Group, the U.S. RPR, the ORP, and where applicable, the 

Delegee of the Board of Directors took responsibility for the content provided within the Plan and were

comfortable that the information provided was appropriate and accurate.

A.9 Material Management Information Systems

SFG utilizes management information systems (“MIS”) and applications to ensure timely access to 

accurate and comprehensive data, including those for risk management, accounting, financial, and 

regulatory reporting. In preparing the U.S. Resolution Plan, SFG has identified key MIS applications and 

maintains inventories of such systems and applications.

The MIS are primarily used to collect, retain, and report information internally, as well as, to perform 

functions necessary to support business lines. Multiple reports are generated on a periodic basis for use 

by senior management to assess the financial health, risks and operations of such business lines. SFG’s 

MIS is capable of collecting, maintaining, and reporting information in a timely manner to management 

and to regulators.

A.10 Resolution Strategy Summary

The U.S. Resolution Plan takes into consideration possible strategies for the orderly resolution of SFG’s 

U.S. operations under applicable resolution regimes in the event of material financial distress or failure.
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The strategies are designed to be executed within a reasonable period of time and in a manner that avoids 

or substantially mitigates systemic impact on U.S. financial stability.

As required by the Final Rule, the U.S. Resolution Plan assumes that the material financial distress is a 

result of an idiosyncratic event that is specific to SFG and occurs at a time where general macroeconomic 

conditions are consistent with baseline economic scenario in which other financial institutions and 

markets generally are not experiencing a system-wide financial panic or crisis. This strategy addresses how 

the U.S. operations of SFG may undergo an orderly resolution without extraordinary government support 

in the U.S. or Korea.

Because SHBNY is a New York state-licensed branch, this Resolution Plan contemplates that SHBNY would 

be subject to the insolvency and liquidation provisions for foreign bank branches under the New York 

Banking Law (“NYBL”). These provisions include an orderly wind down and liquidation of SHBNY, where 

under NYBL, the assets and properties of SHBNY would be seized and “ring fenced” by the Superintendent 

of the New York State Department of Financial Services (“NYSDFS”). The Superintendent is authorized to

take possession of (1) all SHBNY assets wherever located that constitute part of the business of SHBNY 

and appear on the books as such; and (2) all assets of SHB located within New York regardless of whether 

they constitute part of the business of SHBNY. These “ring fenced” assets would be liquidated to satisfy 

permissible claims of unaffiliated creditors of SHBNY in accordance with NYBL. 

Because SHBA is an insured depository subsidiary of SFG, this Resolution Plan assumes that SHBA would 

enter into a receivership, under the Federal Deposit Insurance Act (FDIA), over Resolution Weekend with 

the FDIC appointed as a receiver. Following entry into a receivership, the FDIC may transfer all assets, 

deposits, certain contracts, and liabilities of SHBA into a bridge bank, organized by the FDIC and chartered 

by the Office of the Comptroller of the Currency (OCC). The FDIC would exercise all of the rights and 

powers of SHBA’s directors, management, and shareholders to operate the business, dispose of 

operations and assets, and resolve liabilities. The FDIC would operate the bridge bank as a going concern 

until its ultimate sale or disposition in order to maximize the value available to creditors. If acquisition by 

a third-party is not possible, the FDIC could seek to sell SHBA’s portfolio of loans and other assets or 

recapitalize the bridge bank by issuing equity in the bridge bank or a new holding company to new 

shareholders. 

Although SIA is a registered broker-dealer and a member of SIPC, SIA would only be eligible for resolution 

under the Securities Investor Protection Act of 1970 (“SIPA”) if it has “customers” as defined under SIPA 

upon its entry into resolution. Generally, SIPA is applicable only when customers entrust assets to the 

broker-dealer. SIA does not generally hold customer assets in the ordinary course of business. Therefore, 

SFG assumes that SIA would be resolved under Chapter 11 or Chapter 7 of the U.S. Bankruptcy Code and 

wound down in an orderly manner. The primary objective of both Chapter 11 and Chapter 7 proceedings 

would be to maximize the value realized from the assets and businesses of SIA.