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Document Title Public Section of the Nordea U.S. Living Will 2018

(Resolution Plan)

December 14, 2018 Date

Version 1.0 1 (19) Page

Author Group Recovery and Resolution Planning and 

Strategy (RRPS)
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TABLE OF CONTENTS

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1 Nordea Group .....................................................................................................5

1.1 Legal Structure..........................................................................................7

2 Summary of the resolution plan .........................................................................8

3 Summary of the resolution strategy....................................................................8

4 Names/Description of material entities..............................................................8

5 Description of core business lines......................................................................9

6 Financial information regarding assets, liabilities, capital and major funding 

sources..............................................................................................................11

6.1 Balance sheet information.......................................................................11

6.2 Major funding sources ............................................................................13

6.3 Capital .....................................................................................................13

6.4 Description of derivatives activities and hedging activities....................15

7 List of memberships in material payment-, clearing- and settlement systems.15

8 Description of foreign operations.....................................................................15

9 Identities of material supervisory authorities...................................................15

10 Identities of principal officers ..........................................................................15

11 Description of corporate governance structure and processes related to 

resolution planning ...........................................................................................18

12 Description of material management information systems..............................19
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PUBLIC SECTION

In November 2011, the Board of Governors of the Federal Reserve System (“Federal Reserve”) 

and the Federal Deposit Insurance Corporation (“FDIC”) issued a final rule to implement the 

resolution planning requirements of Section 165(d) of Title I of the Dodd-Frank Wall Street 

Reform and Consumer Protection Act (the “Dodd-Frank Act”). Regulation QQ (the “Final 

Rule”) requires bank holding companies and certain foreign banking organizations with worldwide consolidated assets of $50 billion or more, as well as companies designated as systemically important under Title I of the Dodd-Frank Act, to submit plans for their rapid and orderly 

resolution in the event of material distress or failure. The plan must be submitted to the Federal 

Reserve, to the FDIC and to the Financial Stability Oversight Council (“FSOC”).

This is the public section of the 2018 update of the resolution plan for the U.S. operations of 

Nordea Bank Abp. According to the Final Rule, a resolution plan should provide for the "rapid 

and orderly resolution" of the covered company. As applied to a banking organization organized outside of the U.S. (a "Foreign Banking Organization" or "FBO"), the Final Rule requires 

the creation of a resolution plan that addresses the reorganization or liquidation of the FBO's

subsidiaries and operations domiciled in the U.S. under the insolvency regime applicable to 

those operations. The Final Rule requires that the plan provides for a resolution that “can be accomplished within a reasonable period of time and in a manner, that substantially mitigates the 

risk that the failure of the covered company would have serious adverse effects on financial 

stability in the U.S.”.

1 Nordea Group

The Nordea Group (Nordea Bank Abp and its subsidiaries) is the largest financial services 

group in the Nordic markets (Denmark, Finland, Norway and Sweden) measured by total income, with additional operations in a number of other international locations. Nordea believes 

that the Group has the largest customer base of any financial services group based in the Nordic markets with approximately 10 million customers across the markets in which it operates, 

including approximately 9.6 million household customers and approximately 0.58 million corporate and institutional customers in the Nordic markets, in each case as of 31 December 2017. 

As of the same date, the Nordea Group had total assets of $698.5 billion (EUR 582 billion)

1

and tier 1 capital of $28.9 billion (EUR 26.5 billion)

1

, and was the largest supplier of savings

products to Nordic customers, with total assets under management amounting to $397 (EUR 

330 billion)1

.

 1 From the Group Annual Report 2017. An EUR/USD exchange rate as of 31 December 2017 of 1.2002 has been 

used to convert numbers from EUR to USD.
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As a universal bank, the Nordea Group offers a comprehensive range of banking and financial 

products and services to household and corporate customers, including financial institutions.

The Nordea Group’s products and services comprise a broad range of household banking services, including mortgages and consumer loans, credit and debit cards, and a wide range of 

savings, life insurance and pension products. In addition, the Nordea Group offers a wide range 

of corporate banking services, including business loans, cash management, payment and account services, risk management products and advisory services, debt and equity-related products for liquidity and capital raising purposes, as well as corporate finance, institutional asset 

management services and corporate life and pension products. The Nordea Group also has a 

large distribution network for customers in the Nordic markets with approximately 500 branch 

office locations, call centres in each of the Nordic markets and a net bank. 

Since October 2, 2018 Nordea Bank Abp, the parent company of the Nordea Group, is incorporated in the Republic of Finland and is headquartered in Helsinki. Its ordinary shares are listed 

on Nasdaq Nordic, the stock exchanges in Helsinki (in euro), Stockholm (in Swedish krona), 

and Copenhagen (in Danish krone).

Figure 1: Nordea Group's main legal structure as of 1 October 2018 (non-exhaustive)

The Nordea Group currently operates in the U.S. primarily through the New York branch, 

Nordea Bank Abp, New York Branch (“Nordea New York”), licensed by the New York State 

Department of Financial Services (the “NYDFS”). Nordea New York services the Nordea 

Group customers doing business in the U.S. and Canada, primarily by offering loans and other 

credit services, cash management services and markets services, especially foreign exchange.
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However, in the case of Shipping, Offshore & Oil Services (“SOO”), customers are not customers of the Nordea Group in the Nordics but are customers of Nordea New York exclusively. 

In addition, Nordea New York plays an important role in providing USD funding for the 

Nordea Group globally. 

1.1 Legal Structure

The Nordea Group has undergone changes in its legal structure. In 2017, the Legal Simplification Programme 1 (“LSP1”) was executed, with the purpose of combining all legacy banks into 

one legal entity. In 2018, the Legal Structure Programme 2 (“LSP2”) was executed, with the 

purpose of joining the Banking Union, in order to have similar regulatory requirements as our 

European peers. 

1.1.1. Legal Simplification Programme 1

Nordea announced on 4 February 2016 that the Board of Directors of Nordea Bank AB (publ), 

together with each of the Boards of Directors of Nordea Bank Danmark A/S, Nordea Bank Finland Plc and Nordea Bank Norge ASA, had signed cross-border merger plans. On 17 March 

2016, the general meeting of Nordea's shareholders approved the merger plans that were entered into with the aim to convert Nordea's Danish, Finnish and Norwegian subsidiary banks to 

branches of Nordea Bank AB (publ). The mergers took effect on 2 January 2017 and Nordea 

Bank Danmark A/S, Nordea Bank Finland Plc and Nordea Bank Norge ASA became branches 

of Nordea Bank AB (publ). In connection with the execution of the mergers, Nordea Bank Finland Plc’s New York branch was also transferred to Nordea Bank AB (publ) and Nordea Bank 

Finland Plc’s Cayman branch was closed as it did no longer have any business purpose.

1.1.2. Legal Structure Programme 2

On 6 September 2017, the Board of Directors of Nordea Bank AB (publ) initiated a process to 

re-domicile the parent company of the Nordea Group, Nordea Bank AB (publ) from Sweden to 

Finland. The Boards of Directors of each of Nordea Bank AB (publ) and the newly established 

and wholly-owned Finnish company Nordea Holding Abp signed on 25 October 2017 a joint 

cross-border merger plan that was approved by the shareholders at the annual general meeting 

on 15 March 2018. The merger, and consequently the re-domiciliation, was effected on 1 October 2018 and Nordea Holding Abp had, prior thereto, changed its name to Nordea Bank Abp.

After the execution of the merger, the business activities of Nordea Bank AB (publ) are, to the 

extent they originate from Sweden, conducted by Nordea Bank Abp through a branch in Sweden. Correspondingly, the business activities of Nordea Bank AB (publ), to the extent they 

originate from Denmark, Finland and Norway as well as China, Estonia, Poland, Singapore, the 

United Kingdom, Germany and the US, are conducted by Nordea Bank Abp through new
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branches in each such jurisdiction (except Finland where the operations will be carried out directly via Nordea Bank Abp).

1.1.3. Implications of the Legal Simplification Programme 1 and Legal 

Structure Programme 2 on Nordea New York

LSP1 and LSP2 will not alter Nordea’s presence, activities or operations in the U.S. in any 

way, and will consequently not affect our relationships with our U.S. customers, counterparties 

or public administrative bodies.

2 Summary of the Resolution Plan 

The Resolution Plan for Nordea New York (the “Plan”) calls for the orderly termination of all 

Nordea New York operations within the U.S.

The Plan anticipates that Nordea New York will be placed into resolution by the Superintendent of the NYDFS immediately following initiation of an "interruption proceeding" for 

Nordea Bank Abp by the Single Resolution Board (“SRB”), the group resolution authority and 

the European Central Bank (“ECB”), the group supervisory authority. Under the New York 

resolution proceeding, the Superintendent would marshal and liquidate the assets of Nordea 

Bank Abp in the U.S. and distribute the proceeds to creditors of Nordea New York. The Superintendent would return any excess proceeds to Nordea Bank Abp (being in resolution) in Finland.

3 Summary of the resolution strategy

The Plan calls for Nordea New York (which is the primary entity holding assets and liabilities

in the U.S.) to cease operations during resolution and be liquidated in a proceeding pursuant to 

New York State law. The Plan does not assume any extraordinary assistance during the resolution process, whether from the New York State, the U.S. or any supervisory authority in the 

U.S., the Nordea Group, or any of the Nordic countries in which the Nordea Group operates.

4 Names/Description of material entities 

For this Plan, Nordea Group had one material legal entity as of 1 October 2018: Nordea Bank 

Abp, New York Branch - The primary operating entity of the Nordea Group in the U.S. It employs all personnel responsible for operating Nordea New York. Most of the Nordea Group’s 

assets and liabilities in the U.S. are booked in Nordea New York.
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5 Description of core business lines

The major business activities/areas comprising Nordea New York are:

• Corporate Banking (“CB”)

CB provides a range of banking services to a targeted set of corporate customers. CB’s target 

customer markets include: (1) North American subsidiaries of Nordic companies; (2) select 

North American multinational companies with a large footprint in Northern Europe; (3) select 

non-bank financial institutions conducting business within Northern Europe and (4) select oil 

services companies. All of CB’s customers have a relationship, and a relationship manager, in 

the respective Nordea legal entity within the Nordics to which it has been allocated.

CB offers its customers a variety of banking services, including term loans and working capital 

financing, cash management, stand-by letters of credit (“SBLC”) and bank guarantees. In coordination with the Markets group (described below), CB also offers markets products, including 

foreign exchange and interest rate swaps.

• Shipping Offshore & Oil Services (“SOO”) 

SOO provides traditional commercial banking services to shipping, offshore and cruise line

companies. SOO’s clients are primarily located in North America and are generally either publicly listed companies or large private companies. SOO's strategy limits its target market to 

customers meeting defined market criteria, including type of business, size and financial 

strength. 

SOO generates the majority of its revenue from lending. In addition, SOO offers cash management, interest rate swaps and foreign exchange services. In most cases, these additional products are provided only to customers with whom SOO has a lending relationship. The credit facilities consist mainly of term loans and revolving credits for the purpose of providing long 

term financing for assets such as ships. Large credit facilities are generally syndicated to other 

banks. If SOO has arranged the credit facility, it usually acts as administrative agent. 

• Financial Institutions Group (FIG) 

In early 2017, the FIG, (a Wholesale Banking unit in Nordea Group) established a presence in 

New York.

FIG provides bank loans, trade finance and other banking products loans to Financial Institutions. FIG NY’s clients are primarily located in North America and are generally either publicly listed companies or large private companies. Like SOO FIG's strategy limits its target 
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market to customers meeting defined market criteria, including type of business, size and financial strength. 

• Group Treasury & ALM, Short Term Funding and Internal Bank (“STF & IB”)

STF & IB’s primary role is to access North American funding sources, primarily in USD, but 

also in other currencies, to support the funding needs of Nordea New York and the Nordea 

Group globally. Approximately 95 percent of the funding obtained by Nordea New York is in 

USD.

To fulfill its mandate, STF & IB sources funding through: (i) the overnight deposit balances of

Nordea New York’s customers; (ii) term deposits of Nordea New York’s customers; (iii) issuance of certificates of deposit; (iv) interbank sources and placements from other financial institutions, including government-sponsored entities (“GSEs”) and U.S. asset managers, and (v) 

intercompany deposits. Diversification of funding sources is a key component of the Group’s 

funding strategy.

STF & IB also manages the liquidity and pledge portfolios held in New York.

• Markets 

The Markets (Fixed Income, Currencies and Commodities) group is the North American sales 

and trading arm for Nordea Group’s global Markets FICC activities. The Markets group runs 

the business based on 24-hour global coverage of customers and markets. Foreign exchange activities are run as a global book, which moves across the three regions (Asia, Europe and North 

America). However, all foreign exchange transactions are booked in the name of Nordea Bank 

Abp. No transactions are booked in the name of Nordea New York, even for customers of 

Nordea New York. The types of foreign exchange activities conducted by Markets are primarily spot, forwards and FX swaps. The majority of Markets’ activities in the U.S. or New York

are foreign exchange related. 

In addition to foreign exchange, the Markets group executes money market transactions and interest rate derivatives for Nordea New York’s customers. 
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6 Financial information regarding assets, liabilities, capital and major funding 

sources 

6.1 Balance sheet information2

The following figure displays the Nordea Group balance sheet as of 31 December 2017: 

USDm 31-dec-17 31-dec-16

Assets

Cash and balances with central banks 51706 38525

Loans to central banks 5756 13484

Loans to credit institutions 10312 10833

Loans to the public 372252 381290

Interest-bearing securities 90368 105259

Financial instruments pledged as collateral 7788 6131

Shares 20619 25833

Assets in pooled schemes and unit-linked investments contracts 31060 27727

Derivatives 55342 83965

Fair value changes of the hedged items in portfolio hedge of 

interest rate risk 196 214

Investments in associated undertakings and joint ventures 1482 706

Intangible assets 4780 4551

Properties and equipment 749 679

Investment properties 1738 3743

Deferred tax assets 142 72

Current tax assets 145 346

Retirement benefit assets 300 367

Other assets 14932 22771

Prepaid expenses and accrued income 1756 1739

Assets held for sale 26628 10678

Total assets 698051 738914

 2 From the Group Annual Report 2017. An EUR/USD exchange rate as of 31 December 2017 of 1.2002 has been 

used to convert numbers from EUR to USD. Explanations to the individual categories can be found in the Groups’ 

Annual report 2017, which is available at www.nordea.com.
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USDm 31-dec-17 31-dec-16

Liabilities

Deposits by credit institutions 47988 45771

Deposits and borrowings from the public 206955 208868

Deposits in pooled schemes and unit-linked investment contracts 31605 28301

Liabilities to policyholders 23298 49460

Debt securities in issue 214973 230138

Derivatives 51264 82377

Fair value changes of the hedged items in portfolio hedge of 

interest rate risk 1740 2960

Current tax liabilities 467 584

Other liabilities 34224 29300

Accrued expenses and prepaid income 1924 2110

Deferred tax liabilities 867 996

Provisions 395 367

Retirement benefit liabilities 337 362

Subordinated liabilities 10786 12553

Liabilities held for sale 31242 5867

Total liabilities 658065 700015

USDm 31-dec-17 31-dec-16

Equity

Additional Tier 1 capital holders 900 0

Non-controlling interests 202 1

Share capital 4861 4861

Share premium reserve 1296 1296

Other reserves -1852 -1228

Retained earnings 34579 33968

Total Equity 39986 38898

Total liabilities and equity 698051 738914
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6.2 Major funding sources

The Nordea Group’s broad and diversified funding structure originates from having a strong 

and stable retail customer base in the Nordic markets and through active funding programs.

The funding strategy is centrally managed and is focused on issuance in a few but very liquid 

funding programs, which has enabled Nordea to secure a safe and cost-efficient funding platform. Nordea is a benchmark issuer and its liquid programs are part of major investors’ portfolios. 

External funding is raised by different legal entities, with each having a special function and 

target. Funding programs includes both short-term (US commercial papers, European commercial papers, certificates of deposits) and long-term (covered bonds, European medium-term 

notes, medium-term notes and US medium-term notes) programs denominated in various currencies. The senior unsecured long-term funding and the short-term funding of the Nordea 

Group is raised by the parent company in the Nordea Group, Nordea Bank Abp. Further, the 

interbank deposits are channelled through Nordea Bank Abp and its branches in the Nordea 

group. This set up allows for a great deal of flexibility, as the proceeds can be swapped to any 

currency, regardless of the original currency of the issuance, and channelled to any of the legal 

entities, thus also covering foreign exchange risk. 

Nordea New York’s major funding sources are:

• Certificates of deposit (“CDs”): Nordea New York issues term CDs through the 

wholesale markets.

• Overnight funding: Nordea New York raises overnight funds from money market 

funds, Federal Home Loan Banks and other investors.

• Inter-company deposits: Nordea New York receives overnight deposits from affiliates, 

primarily Nordea Bank Abp.

• Demand deposits: Nordea New York receives demand deposits from customers.

• Term deposits: Nordea New York receives term deposits from customers.

6.3 Capital

As a branch licensed by the NYDFS, Nordea New York is not required to maintain capital on a 

separate basis apart from the capital of Nordea Bank Abp. As required by applicable law, the 

Nordea Group measures its capital ratio in accordance with CRR/CRD IV, the EU implementation of the standards promulgated by the Basel Committee on Banking Supervision. 
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6.3.1. Nordea Group Capital Ratios3

Nordea’s Common Equity Tier 1 capital ratio, excluding transition rules, was 19.5 % at the end 

of 2017, strengthened by 110 basis points from the end of 2016. The improved capital position 

was achieved by strong profit generation in combination with a maintained focus on capital 

management.

The key capital adequacy figures for Nordea Group can be found in the table below. Conversion from EUR to USD has been done using the exchange rate as of 31 December 2017

(EUR/USD 1.2002).

Group capital adequacy figures, USDm 31-dec-17 31-dec-16

Capital and REA

REA including transition rules 242949 259018

REA excluding transition rules 150960 159815

Capital requirement including transition rules 19436 20721

CET1 capital 29423 29451

Tier 1 capital 33615 33072

Own funds ("Capital base") 38103 39491

Capital ratios excluding transition rules

CET1 capital ratio 19,5% 18,4%

Tier 1 capital ratio 22,3% 20,7%

Total Capital ratio 25,2% 24,7%

Capital adequacy quotient (Own funds/capital requirement) 3,2 3,1

Capital ratios including transition rules

CET1 capital ratio 12,3% 11,5%

Tier 1 capital ratio 14,0% 12,9%

Total capital ratio 15,8% 15,3%

Capital adequacy quotient (Own funds/capital requirement)) 2,0 1,9

 3 As a result of re-domiciliation of Nordea on 1 October 2018 the supervisory regime of Nordea Group was 

changed from the Swedish FSA to the ECB. The supervisory regime change had implications to the capital 

requirements and capital ratios of the Group. In October 2018, Nordea received a capital implementation letter 

from the ECB determining the expected minimum Pillar 2 levels of own funds and the voluntary capital 

commitment applicable during the transition period (i.e. until the ECB has issued a decision establishing 

prudential requirements prepared in accordance with the 2019 Joint Decision on Capital concerning the Nordea 

Group, expected Q4 2019). Based on the letter Nordea is expected to maintain a Pillar 2 level of at least EUR 

4,945m in CET1, equal to a forecasted level of approximately 3.1% for the fourth quarter 2018. The ECB also 

expects that Nordea will hold Pillar 2 of at least EUR 5,759m in total capital. The voluntary capital commitment 

corresponds to maintaining a CET1 capital requirement of at least EUR 21,651 million, forecasted to equal a 

CET1 ratio of 13.7% by the end of the fourth quarter of 2018.
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6.4 Description of derivatives activities and hedging activities

Nordea New York engages in limited derivative activity all of which is for hedging purposes, 

either for customers or for itself.

This normally takes the form of Interest Rate Swaps (“IRS”) or Overnight Indexed Swaps 

(“OIS”).

7 List of memberships in material payment-, clearing- and settlement systems

Nordea New York is a participant in Fedwire and ACH. Other than the direct access to its account at the Federal Reserve Bank of New York, Nordea New York is not a direct member of 

any material payment, clearing or settlement system. Most customer payments are effected 

through Fedwire.

Payments related to the STF & IB operations are effected through Nordea New York’s U.S. 

correspondent bank, Bank of America N.A. 

Nordea New York does not process payments on behalf of its affiliates, who instead act 

through their own U.S. correspondent accounts.

Nordea New York does not clear or otherwise process securities transactions for its customers. 

The Nordea Group is a member of DTCC and CLS. Nordea New York participates in CLS 

through an affiliate with full membership.

8 Description of foreign operations

Nordea New York represents the U.S. banking operations of the Nordea Group. Nordea New 

York itself has no foreign operations. Nordea Group's global operations are discussed in Section 1 above. 

9 Identities of material supervisory authorities

Nordea Bank Abp is supervised by the ECB and is subject to Single Supervisory Mechanism.

Nordea New York is supervised by the NYDFS and the Federal Reserve Bank.

10 Identities of principal officers
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The General Manager and the executive responsible of Nordea New York is Henrik M. Steffensen.

Nordea New York operates as part of the International Division of Nordea Group, which is 

overseen by the Head of International Division (“ID”) Claus Asbjørn Stehr.

Henrik M. Steffensen is responsible for the daily management of Nordea New York together 

with the Management Committee of Nordea New York, which is comprised of (as of 1 October 

2018): 

Nordea Bank Abp, New York Branch Management Committee

Name Position 

Henrik M. Steffensen General Manager

Susan Tucillo Head of Compliance 

Leena Parker Head of Corporate Banking

Raymond Knott Head of Risk Management & Control

Anders Holmgaard Head of Markets Sales

Stefan Bartholsen Head of Markets Trading

Kren Holm-Jorgensen Head of Operational Services

Martin Lunder Head of Shipping, Off Shore and Oil Services

Colin Williams-Hawkes Head of Short Term Funding in International 

Units

Christopher Spitler General Counsel
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The overall strategy of Nordea New York is overseen by an Executive Committee, consisting 

of (as of 1 December 2018):

Executive Committee

Name Unit

Martin A. Persson Head of Wholesale Banking (member of Group 

Executive Management)

Mathias Leijon Corporate & Investment Banking

Magnus Montan Commercial and Business Banking

Thor Erling Bech SOO 

Mark Kandborg Treasury & ALM

Mick Ankjaer Markets 

Erik Zingmark Transaction Banking

Jessica Malmfors Wealth & Asset Management

Claus Asbjørn Stehr International Division

Henrik M. Steffensen Nordea New York

As of 1 December 2018, the Nordea Group Executive Management ("GEM") consisted of: 

Group Executive Management (GEM)

Name Position 

Casper von Koskull President and Group CEO

Torstein Hagen Jørgensen Group COO and Deputy Group CEO

Head of Group Corporate Centre

Erik Ekman Head of Commercial and Business Banking

Matthew Elderfield Head of Group Compliance
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Julie Galbo Group CRO

Head of Group Risk Management and Control

Jussi Koskinen Chief Legal Officer

Head of Group Legal

Frank Vagn-Jensen Head of Personal Banking

Martin A Persson Head of Wholesale Banking

Christopher Rees Group CFO

Head of Group Finance & Treasury 

Snorre Storset Head of Wealth Management 

Karen Tobiasen Chief People Officer

Head of Group People

11 Description of corporate governance structure and processes related to resolution planning

At the Nordea Group level, recovery and resolution planning is the responsibility of Group Recovery and Resolution Planning and Strategy (“RRPS”), headed by Acting Head Johanna 

Hirvonen. Group RRPS, along with the RRPS activities, is fully embedded in the Risk Management framework. The Head of RRPS reports to the Head of CRO Functions, Søren Dahlgaard, who reports directly to the Group Chief Risk Officer, and is a member of the Group 

Risk Executive Management (“GREM”).

The recovery and resolution activities are run by the Group RRPS, and employees in the Group 

RRPS are responsible for preparing resolution and recovery plans, in accordance with local 

regulatory requirements, together with key resources from Nordea’s business areas, Group Legal, Group Corporate Centre and other relevant group functions. The operational responsibility 

is with the Head of Group RRPS. 

Resolution planning for Nordea New York is a joint responsibility of the Nordea Group and the 

management of Nordea New York. At Nordea New York, the General Manager, Henrik M. 

Steffensen, is responsible for resolution planning, assisted by the Management Committee of 

Nordea New York, whose members are listed in the previous section. Henrik Steffensen is responsible for the filing of the Nordea New York Resolution Plan, and for the maintenance of 

the Plan. 
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The 2018 Resolution Plan submission for Nordea New York was approved by Henrik M. Steffensen, General Manager of Nordea New York and Søren Dahlgaard, Head of CRO Functions. 

On 12 December 2018 the Nordea Bank Abp Board was updated on the 2018 Resolution Plan

submission regarding Nordea Bank Abp’s U.S. operations. 

12 Description of material management information systems

Nordea New York relies on key management information systems (“MIS”) and applications for 

financial, accounting, risk management and regulatory reporting. These systems, as well as the 

reports generated from the systems, are wholly owned and controlled by Nordea New York. In 

addition, the core business lines leverage reports provided by the key MIS to monitor daily 

functionalities. 

Nordea New York’s key MIS reports are produced and available on a regular basis. Nordea 

New York has identified key functionalities that would support branch management during an 

orderly resolution as outlined in the Plan.