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National Australia Bank Ltd (“NAB Ltd”)

Public Section of 2021 §165(d) Resolution Plan 
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Public Section 

I.A. Introduction

To promote financial stability, Section 165(d) of the Dodd-Frank Wall Street Reform and Consumer 

Protection Act (the “Dodd-Frank Act”) and the related rule (the “Rule”) 1 require each nonbank financial 

company supervised by the Board of Governors of the Federal Reserve System (the “FRB”) and each 

bank holding company with total consolidated assets of $50 billion or more (each a “Covered Company”) 

to periodically submit to the FRB a plan for such company’s rapid and orderly resolution in the event of 

material financial distress or failure. Included in Covered Companies are foreign-based covered 

companies, which are defined in the Rule as “any covered company that is not incorporated or organized 

under the laws of the United States.” National Australia Bank Ltd (“NAB Ltd”) is considered a “Covered 

Company” under the Rule and must file this Resolution Plan with the FRB.

Under the requirements of the Rule, Covered Companies are required to assess their U.S. banking 

operations for the presence of Material Entities, Critical Operations, and Core Business Lines. NAB Ltd

assessed its U.S. operations and determined there are no Material Entities, Critical Operations, or Core 

Business Lines as defined in the Rule. Therefore, the focus of this Resolution Plan is the orderly 

resolution of NAB Ltd’s New York Branch, which conducts the vast majority of the Covered Company’s 

U.S. operations.

I.B. Background

NAB Ltd, an Australian company that is incorporated under the Corporations Act (Australia), is a global 

financial services organization with approximately U.S. $668 billion in assets as of September 30, 2021. 

While the vast majority of its operations are in Australia, NAB Ltd and its subsidiaries (collectively, “NAB 

Group”) also operate in New Zealand, Asia, the United Kingdom and the United States. NAB Ltd is an 

international financial services organization with more than 32,000 colleagues, over 618,000 shareholders 

and serving approximately eight million customers. NAB Ltd is a foreign-based Covered Company under 

the Rule, and is required to submit a resolution plan under the Dodd-Frank Act and the Rule. NAB has 

developed a Resolution Plan (“Plan”) that sets forth a detailed analysis of how NAB’s U.S. operations 

could be resolved in a rapid and orderly manner without creating adverse effects on the financial stability 

of the United States. In the United States, NAB Ltd operates primarily through its federally licensed New 

York Branch. 

NAB’s brands share a commitment to provide customers with quality products and services. NAB’s

relationships are based on the principles of help, guidance and advice to achieve better financial 

outcomes for its customers. In the September 2021 full year, the NAB Group operated the following 

divisions:

• Business and Private Banking focuses on NAB's priority small and medium (SME) customer 

segments. This includes the leading NAB Business franchise, specialised Agriculture, Health,

 

1 12 C.F.R. Part 243
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Government, Education and Community services, along with Private Banking and JBWere, as well as 

the micro and small business segments.

• Personal Banking provides customers with products and services through proprietary networks in 

NAB, as well as third party and mortgage brokers. Customers are served through the Personal 

Banking network to secure home loans or manage personal finances through deposit, credit or 

personal loan facilities. The network also provides servicing support to individuals and business 

customers.

• Corporate and Institutional Banking provides a range of products and services including client 

coverage, corporate finance, markets, asset servicing, transactional banking and enterprise 

payments. The division services its customers in Australia and globally, including branches in the 

United Kingdom, United States and Asia, with specialised industry relationships and product teams. It 

includes Bank of New Zealand's Markets Trading operations.

• New Zealand Banking provides banking and financial services across customer segments in New 

Zealand. It consists of Partnership Banking, servicing retail, business and private customers; 

Corporate and Institutional Banking, servicing corporate and institutional customers, and includes 

Markets Sales operations in New Zealand. New Zealand Banking also includes the Wealth and 

Insurance franchises operating under the ‘Bank of New Zealand’ brand but excludes the Bank of New 

Zealand’s Markets Trading operations.

• Corporate Functions and Other division includes UBank, 86 400 and enabling units that support all 

businesses including Treasury, Technology and Enterprise Operations, Strategy and Innovation, 

Support Units and eliminations.

I.C. Material Entities

As it was determined that NAB Ltd does not have any Core Business Lines or Critical Operations as 

defined by the Rule, there are no Material Entities. NAB Ltd has however, as an extension of the Covered 

Company and the entity through which the majorities of U.S. operations are carried out, analyzed the NY 

Branch and provided a strategy for winding down its affairs in an orderly fashion. 

I.D. Core Business Lines

All of NAB Ltd’s U.S. business lines are viewed by management as providing ongoing strategic value to 

the bank. Management performed qualitative and quantitative assessments and determined that the 

cessation of any one of its U.S. business lines would not result in a material loss of revenue, profit, or 

franchise value relative to NAB Ltd’s global operations. Thus, as defined by the Rule, NAB Ltd does not 

have any Core Business Lines.
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I.E. Consolidated Financial Information

The following is NAB Ltd’s global balance sheet2 as of the end of its 2021 fiscal year.

 

2 All figures are in Australian dollars unless otherwise noted.
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I.F. Derivative and Hedging Activities

Hedging strategy

The Group’s hedging strategy is to manage its exposure to interest rate risk on a net variable basis in 

Australian dollars. For Australian denominated exposures this requires the Group to enter into interest 

rate swaps where the exposure is to a fixed interest rate. In some instances, cash flow hedges of interest 

rate risk are also used to arrive at a net variable rate position. Foreign currency exposures are swapped 

to Australian dollars using cross-currency interest rate swaps. These may be float-to-float or fixed-to-float 

cross currency swaps depending on whether the underlying interest rate exposure is floating or fixed, 

respectively.

Not all exposures are automatically managed under the above strategy. Where a risk is within acceptable 

limits the Group may decide not to apply hedge accounting to that risk. Instead, the Group will manage its 

exposure under broader risk management processes.

Hedging instruments

The table below3 sets out hedging derivative assets and liabilities by the hedged risk and type of hedge 

relationship in which they are designated. The Group may designate separate derivatives to hedge 

different risk components of one hedged item. In such scenario the notional amount of hedging 

derivatives will, in sum, exceed the notional amount of the hedged item. In the case of cross-currency 

swaps the Group will often designate a single instrument to hedge both interest rate risk in a fair value 

hedge and currency risk in a cash flow hedge.

 

3 All figures are in Australian dollars unless otherwise noted.
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I.G. Payment, Clearing, and Settlement Systems

The following is a table outlining the payment, clearing, and settlement systems used in conjunction with 

NAB Ltd’s U.S. operations. 

System Name System Type

Bank of NY/Inform Settlement

Bank of NY/BDC Settlement

FICC/GSD Settlement

Citibank Clearing

CITI Securities CDS Settlement

Fedwire Funds Payment

Fedwire Securities Settlement

GMM Payment

SWIFT Payment

I.H. Description of Foreign Operations

The Group has operations in Australia (the Company’s country of domicile), Europe, New Zealand, the 

United States and Asia. The allocation of income and non-current assets4 is based on the geographical 

location in which transactions are booked.

 

 

4 All figures are in Australian dollars unless otherwise noted.
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I.I. Material Supervisory Authorities

In Australia, the lead authority responsible for safety and soundness of authorized deposit-taking 

institutions like NAB Ltd is the Australian Prudential Regulatory Authority (“APRA”). In the United States, 

the New York Branch is primarily regulated by its licensing authority, the Office of the Comptroller of the 

Currency (“OCC”), and the Federal Reserve Bank of New York. 

I.J. Identities of Principal Officers

The following people are the members of National Australia Bank’s Executive Leadership Team.

Name Role/Title

Ross McEwan Group Chief Executive Officer

Gary Lennon Group Chief Financial Officer

Sharon Cook Group Executive, Legal and Commercial Services

David Gall Group Executive, Corporate and Institutional Banking

Angela Mentis Group Chief Digital, Data and Analytics Officer

Patrick Wright Group Executive, Technology and Enterprise Operations

Rachel Slade Group Executive, Personal Banking

Shaun Dooley Group Chief Risk Officer

Susan Ferrier Group Executive, People and Culture

Nathan Goonan Group Executive, Strategy and Innovation

Andrew Irvine Group Executive, Business and Private Banking

Les Matheson Group Chief Operating Officer

I.K. Corporate Governance Structure and Processes Related to Resolution Planning

NAB Ltd has developed and implemented comprehensive processes, including robust internal controls, 

and incorporated Resolution Planning into its Global Risk Management Framework. Regular updates on 

the development of the Resolution Plans are provided to the Risk Management Committee and Group 

Chief Risk Officer by the Chief Risk Officer of the New York Branch. 
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I.L. Description of Material Management Information Systems

NAB Ltd’s management information systems (“MIS”) are applications that aggregate, analyze, and report 

financial data necessary for prudent decision making and risk management. The applications consist of 

third-party and in-house platform technologies and user interfaces that staff use to generate reports on 

both a periodic and ad-hoc basis. The key MIS at NAB Ltd generate numerous reports used in the normal 

course of business to monitor the financial health, risks, and operations of NAB Ltd.

The ability of NAB Ltd’s MIS to aggregate and analyze data locally and globally is robust. Additionally, 

NAB Ltd maintains detailed business continuity plans with respect to all technology platforms, including its 

MIS. 

I.M. High level Description of the Resolution Strategy for the Covered Company

The New York Branch will be resolved by the OCC through a receivership pursuant to the governing 

provisions of the International Banking Act of 1978 and the National Banking Act. The receivership will 

include liquidation of NAB Ltd’s U.S. assets to satisfy the claims of New York Branch creditors to the 

fullest extent possible. Pursuant to this strategy, the plan outlines the asset sales that could occur during 

the resolution process. These plans include assessments as to the marketability and liquidity of the 

various classes of New York Branch assets.