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Swedbank AB

U.S. Resolution Plan

Public Section

December 31, 2018

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

facts, including statements about Swedbank’s beliefs and expectations, are forwardlooking 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. Forward-looking statements speak only as of the date they are made, and 

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

information or future events.
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TABLE OF CONTENTS

INTRODUCTION ................................................................................................................................... 3

OVERVIEW OF THE BANK.............................................................................................................................3

OVERVIEW OF THE BANK’S U.S. OPERATIONS...........................................................................................4

MATERIAL CHANGES SINCE THE 2016 RESOLUTION PLAN SUBMISSION...................................................4

OVERVIEW OF THE RESOLUTION PLAN.......................................................................................................4

1. CORE BUSINESS LINES AND CRITICAL OPERATIONS........................................................... 5

2. MATERIAL ENTITIES....................................................................................................................... 5

3. CONSOLIDATED FINANCIAL INFORMATION REGARDING ASSETS, LIABILITIES, 

CAPITAL AND MAJOR FUNDING SOURCES.................................................................................. 5

CONSOLIDATED STATEMENT OF FINANCIAL POSITION...............................................................................5

CAPITAL .........................................................................................................ERROR! BOOKMARK NOT DEFINED.

MAJOR FUNDING SOURCES ........................................................................................................................6

4. DERIVATIVE ACTIVITIES AND HEDGING ACTIVITIES.............................................................. 7

5. MEMBERSHIPS IN MATERIAL PAYMENT, CLEARING AND SETTLEMENT SYSTEMS ...... 8

6. FOREIGN OPERATIONS................................................................................................................. 8

7. MATERIAL SUPERVISORY AUTHORITIES.................................................................................. 7

REGULATION AND SUPERVISION IN SWEDEN..............................................................................................7

REGULATION AND SUPERVISION IN THE U.S. .............................................................................................9

8. PRINCIPAL OFFICERS AS OF OCTOBER 31, 2018 .................................................................. 9

9. CORPORATE GOVERNANCE STRUCTURE AND RESOLUTION PLANNING PROCESS.. 10

10. MATERIAL MANAGEMENT INFORMATION SYSTEMS......................................................... 11

11. RESOLUTION STRATEGY.......................................................................................................... 11
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INTRODUCTION

Swedbank AB (“Swedbank” or the “Bank”, and together with its subsidiaries, the 

“Swedbank Group” or “Group”) is pleased to present its resolution plan as required by 

Regulation QQ, 12 CFR Part 243 of the Board of Governors of the Federal Reserve 

System (the “Federal Reserve”) and 12 CFR Part 381 of the Federal Deposit Insurance 

Corporation (the “FDIC”) (together, the “Final Rule”) issued pursuant to Section 165(d) of 

the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank 

Act”). The Federal Reserve and FDIC are together referred to as the “Agencies” in this 

plan.

Swedbank is a bank organized under the laws of Sweden. Swedbank is a foreign bank 

that (i) is treated as a bank holding company under Section 8(a) of the International 

Banking Act of 1978 (“IBA”) because it maintains a branch office located in New York, 

and (ii) has USD 50 billion or more in total consolidated assets, as determined based on 

Swedbank’s most recent annual Capital and Asset Reports for FBOs as reported on 

Federal Reserve Form FR Y-7Q. Accordingly, Swedbank is a “covered company” as 

defined in the Final Rule and is required to submit a U.S. resolution plan under Section 

165(d) and the Final Rule.

As required by the Final Rule, this document constitutes the Public Section of the Bank’s 

U.S. resolution plan.

Overview of the Bank 

Swedbank is a public limited liability bank company (Sw: Bankaktiebolag) incorporated 

under the laws of the Kingdom of Sweden with its registered office in Stockholm. 

Swedbank ́s shares are listed on NASDAQ OMX Stockholm. As of December 31, 2017, 

the Group served a total of 7.4 million private customers and more than 600,000 

corporate and organizational customers through approximately 350 branches in 11 

countries, primarily in its principal markets of Sweden, Estonia, Latvia and Lithuania. To 

support business in these markets, the Group has established branches in neighboring 

markets such as Finland, Norway and Denmark, as well as in major markets of financial 

importance such as China (where the Group has a branch), and the United States 

(where the Group has both a branch and a subsidiary). The Group also has a branch in 

Luxembourg and representative offices in Spain and South Africa.

The Group offers a broad range of financial products and services, including retail 

banking, corporate and investment banking, asset management and insurance products, 

with the majority of the Group’s income being derived from its Swedish retail banking 

services.

The Group has four business areas (Swedish Banking, Large Corporates & Institutions, 

Baltic Banking and Group Functions & Other) and employs approximately 14 600 fulltime employees.
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Overview of the Bank’s U.S. Operations

In the U.S., the Group has a branch in New York and one subsidiary, Swedbank 

Securities US, LLC which is conducting nonbanking operations. Another subsidiary, 

Ektornet US LLC, which also conducted nonbanking operations, was closed in October 

2015. 

Swedbank, New York Branch

Swedbank, New York Branch (the “Branch” or “NY Branch”) was established 1991. The 

Branch is not a separate legal entity and as such forms part of Swedbank AB, Sweden 

as an integral part of business area Large Corporates & Institutions (“LC&I”), 

International Branches. The NY Branch conducts operations mainly through three 

functions: Treasury, Corporate Banking and Commercial Real Estate. The NY Branch 

does not engage in retail banking with private individual customers and is not allowed to 

offer deposits insured by the FDIC.

Swedbank Securities US, LLC

Swedbank Securities US, LLC (“Swedbank Securities”), established in 2006, is a 

registered broker-dealer under the Securities and Exchange Act of 1934. Swedbank 

Securities is a fully disclosed introducing broker/dealer whereby it does not hold 

customer funds or securities. Swedbank Securities does not trade for its own account.

Swedbank Securities is a wholly owned subsidiary of Swedbank and has no 

subsidiaries.

Material Changes since the 2016 Resolution Plan Submission

There have been no material changes since the 2016 U.S. Resolution Plan submission.1

Overview of the Resolution Plan

The key building blocks of the Bank’s U.S. Resolution Plan are the identification of core 

business lines, critical operations, and material entities (each as defined in the Final 

Rule), if any, and the determination of whether any such core business lines, critical 

operations, or material entities are within the scope of the requirements of the Final Rule.

 1 The Bank was not required to submit a U.S. resolution plan in 2017. On September 28, 2017, the Federal Reserve and 

the FDIC extended by 1 year, to December 31, 2018, the next U.S. resolution plan submission deadline for 82 foreign

banks with limited U.S. operations, including the Bank.
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1. CORE BUSINESS LINES AND CRITICAL OPERATIONS

Definition

“Core business lines” are defined in the Final Rule as the business lines of the covered 

company which are conducted in whole or material part in the U.S., and the failure of 

which would result in a material loss of revenue, profit or franchise value to the covered 

company.

“Critical operations” are defined in the Final Rule as those operations of the covered 

company, including associated services, functions and support, the failure or 

discontinuance of which, in the view of the covered company or as jointly directed by the 

Agencies, would pose a threat to the financial stability of the United States.

Identification of Core Business Lines and Critical Operations

Swedbank has determined that it has no core business lines for purposes of the Final 

Rule. Additionally, Swedbank has determined that it has no critical operations for 

purposes of the Final Rule. Analyses included a combination of quantitative and 

qualitative judgments along with a comparison to the list of critical operations (as 

identified by the Agencies) and a review of market share and customer profiles.

Under the Final Rule, the Agencies have the authority to jointly designate an operation of 

a covered company as a critical operation. No operations of Swedbank have been 

designated by the Agencies as critical operations for purposes of the Final Rule.

2. MATERIAL ENTITIES

Definition

“Material entities” are defined as a subsidiary or foreign office of the covered company 

that is significant to the activities of a critical operation or core business line. 

Identification of Material Entity

As noted above, Swedbank has determined that it has no core business lines and no 

critical operations for purposes of the Final Rule. Accordingly, the Bank has no material 

entities, as defined in the Final Rule.

3. CONSOLIDATED FINANCIAL INFORMATION REGARDING ASSETS, 

LIABILITIES, CAPITAL AND MAJOR FUNDING SOURCES

Consolidated Statement of Financial Position

The following table summarizes the consolidated accounts and presents the financial 

position of the Group, in accordance with International Financial Reporting Standards, as 
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adopted by the EU, and the Annual Accounts Act for Credit Institutions and Securities 

Companies.

Balance sheet, Group (as of December 31, 2017, amount in millions of SEK, unless 

otherwise stated)

Capital requirements

Swedbank’s Common Equity Tier 1 (CET1) capital ratio was 24.6% as of year-end 2017 

which was 270 bps above the CET1 capital requirement at that time.

The capital adequacy rules stipulates the regulatory requirements for how much capital a 

bank must hold in relation to the risk that the bank faces. When assessing its capital

needs, Swedbank takes into consideration its current and future risk profile, internal risk 

measurement and assessment of the risk capital needed. In addition to capital 

requirements for credit, market and operational risk (i.e. Pillar 1), all other risks, such as 

interest rate risk in the banking book, concentration risks, pension risks, earnings 

volatility risk, and strategic risk must be taken into account when assessing the total 

capital need (i.e. as part of the Pillar 2 assessment). In recent years, the Pillar 2 capital 
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charges have increased in importance as a supervisory tool. In particular, the Swedish 

Financial Supervisory Authority (SFSA) has introduced both a systemic risk buffer (2%) 

for systemically important banks and a risk-weight floor (25%) for Swedish mortgages 

within the Pillar 2 framework. SFSA decided during the fall 2018 that the capital 

requirement related to the risk weight floor on Swedish mortgages is moved to pillar 1 

from the end of 2018. 

The table below outlines Swedbank Group’s regulatory capital requirements in 

comparison to the capital position expressed as percent of Risk Exposure Amount (REA) 

end of 2017. As mentioned above, Swedbanks’ buffers above the requirements were 

adequate the CET1 buffer amounted to 270bps and Total capital buffer was 300bps.

In addition, the leverage ratio, which is a non-risk-based solvency requirement proposed 

through Basel III. The leverage ratio requirement is a backstop requirement to the riskbased capital requirements intended to constrain excess leverage in the banking system 

and to provide an extra layer of protection against model risk and measurement error. 

The expected minimum Leverage ratio requirement in coming updates of the CRR ( 

Capital requirement regulation (EU) No 575/2013) that Swedbank eventually has to meet 

is 3%. On 31 December 2017, Swedbank’s leverage ratio was 5.25%

Major Funding Sources

The funding activities of the NY Branch are closely tied to Head Office. Treasury within 

the NY Branch manages the market and liquidity risk in the assets of the Branch, either 

directly in its own balance sheet within set risk limits, or through funding from Head 

Office.

4. DERIVATIVE ACTIVITIES AND HEDGING ACTIVITIES

Estimated capital requirements (forward-looking) 1) Total

% CET1 AT1 T2 capital

Pillar 1

Minimum requirement 4,5 1,5 2,0 8,0

Systemic risk buffer (P1) 2) 3,0 3,0

Capital conservation buffer (CCoB) 2,5 2,5

Countercyclical capital buffer (CCyB) 3) 1,3 1,3

11,3 1,5 2,0 14,8

Pillar 2 4)

Mortgage floor 5) 6,8 0,7 1,0 8,5

Systemic risk charge (P2) 2,0 2,0

Individual Pillar 2 charge 1,8 0,2 0,3 2,3

 of which Interest rate risk in the banking book 0,5 0,1 0,1 0,7

 of which Credit-related concentration risk 0,6 0,1 0,1 0,8

 of which Adjustment to estimates of probability of default 0,5 0,1 0,1 0,6

 of which Maturity floor for corporate exposures 0,2 0,0 0,0 0,3

 of which Pension risk 0,0 0,0 0,0 0,0

 of which Other 0,0 0,0 0,0 0,0

10,6 1,0 1,3 12,9

Capital requirements 21,9 2,5 3,3 27,7

Actual capital ratios as of 31 December 2017 24,6 2,7 3,4 30,7

1) Swedbank's estimate based on SFSA's announced capital requirements, including implemented buffers and Pillar 2 requirements 

Note: Values in columns and rows might not sum up exactly due to rounding

5) The mortgage floor capital requirement is affected by the countercyclical buffer rate for Sweden.

2) Other systemically important institution buffer (O-SII buffer) entered into force on 1 January 2016. The higher of the systemic risk buffer and the O-SII buffer applies. The O-SII bu

is 2%.

3) The estimate is based on Swedbank's relevant exposures and the calculation takes into account impending increases in the countercyclical buffer rates published by ESRB as of 

December 2017.

4) Mortgage floor and systemic buffer as of 31 December 2017. The individual Pillar 2 charge items as of 31 December 2016 according to SFSA’s SREP report of 29 September 201 

relation to REA as of 31 December 2017.
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The Branch does not enter into swap agreements with external parties directly. Such 

agreements are entered into with Head Office. The NY Branch may engage in 

transactions in cleared derivatives, such as financial futures, to hedge interest rate risk. 

The Branch uses these instruments to reduce its sensitivity to interest rate fluctuations.

5. MEMBERSHIPS IN MATERIAL PAYMENT, CLEARING AND SETTLEMENT 

SYSTEMS

Currently, Swedbank entities have direct access to USD clearing mechanisms via 

chosen correspondent banks and settle transactions independently from each other. The 

NY Branch uses one main SSI (Standard Settlement Instruction) counterpart in USD 

clearing, which is used only for interbank settlements on behalf of the Branch.

6. FOREIGN OPERATIONS

Swedbank has four geographical home markets: Sweden, Estonia, Latvia and Lithuania. 

To support our customers’ businesses, Swedbank also has operations in Norway, 

Finland, Denmark, the US, China, Luxembourg and South Africa.

Sweden is Swedbank’s largest market. Swedbank has a leading position in several of 

Sweden’s most important market segments, including mortgage lending, private savings 

and cards. Swedbank also offers a broad range of products and banking services, 

including life and non-life insurance, as well as leasing, in Estonia, Latvia and Lithuania.

7. MATERIAL SUPERVISORY AUTHORITIES

Regulation and Supervision in Sweden

The banking and financing business in Sweden is regulated pursuant to the Swedish 

Banking and Financing Business Act (Sw: lagen (2004:297) om bank- och 

finansieringsrörelse) (the ‘‘BFBA’’). The BFBA governs the conduct of banking business 

in Sweden. 

The BFBA also empowers the SFSA to supervise the business of banking in Sweden 

and contains provisions regarding the SFSA's supervisory and regulatory authority, 

including the power to conduct examinations, access records and other information, and 

to take appropriate remedial actions. The SFSA supervises Swedbank and all of its 

subsidiaries on a consolidated basis.

The investment services of Swedish banks are regulated by the Swedish Securities 

Markets Act (Sw: lagen (2007:528) om värdepappersmarknaden) (the “SSMA”). The 

SSMA covers investment services provided by banks and investment firms. 

Swedbank has been granted a license from the SFSA to conduct banking business 

under the BFBA as well as, inter alia, licenses to carry out securities business under the 

SSMA.
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Regulation and Supervision in the U.S.

Banking regulation

Swedbank’s banking operations in the U.S. are subject to both federal and state 

regulatory regimes. The NY Branch is licensed and supervised by the New York State 

Department of Financial Services (“NYSDFS”) and subject to examination by the 

NYSDFS. The NY Branch is also supervised by the Federal Reserve. The NY Branch 

does not accept deposits insured by the FDIC. 

Under the IBA, because Swedbank maintains a branch in the U.S., it is treated as a

bank holding company and thus is subject to many of the provisions of the Bank Holding 

Company Act of 1956, as amended, including activity restrictions and supervisory and 

enforcement authorities of the Federal Reserve. The Federal Reserve is responsible for 

supervising all of Swedbank’s activities in the U.S.

Broker Dealer Regulation 

As a registered U.S. broker-dealer under the Securities Exchange Act of 1934, 

Swedbank Securities is subject to regulation by the Securities Exchange Commission 

and Financial Industry Regulatory Authority.
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8. PRINCIPAL OFFICERS AS OF OCTOBER 31, 2018

Group Executive Committee Position 

Birgitte Bonnesen President and CEO

Mikael Björknert Chief Strategy Officer

Christer Trägårdh Head of Swedish Banking

Anders Karlsson Chief Financial Officer 

Ģirts Bērziņš

Head of Strategy Digital Banking. Head of Baltic 

Banking Channel Development and Customer 

Service.

Björn Elfstrand Head of Group Savings

Anders Ekedahl Head of Group IT

Lars-Erik Danielsson Chief Credit Officer

Leif Karlsson Head of Lending & Payments

Ola Laurin Head of Large Corporates & Institutions 

Aet Altroff Head of Group Customer Value Management

Ragnar Gustavii Head of CEO Office

Cecilia Hernqvist Head of Compliance 

Helo Meigas Chief Risk Officer

Lotta Lovén Head of Digital Banking

Charlotte Elsnitz Head of Baltic Banking

Carina Strand Head of Human Resources 

9. CORPORATE GOVERNANCE STRUCTURE AND RESOLUTION PLANNING 

PROCESS

Swedbank has established a governance framework at both the group level and U.S.

operations level to ensure that all aspects of resolution planning receive appropriate 

attention by the designated Board of Directors and Executive Committees. 

The Board of the Bank has laid down key principles for the structure which comprise of 

three primary levels:

• Board level oversight,

• Group level executive management oversight, and

• Business level executive management monitoring and oversight.

The governance framework establishes the roles and responsibilities of committees for 

the global and local management of recovery and resolution planning. The “Recovery 

and Resolution Planning” requirement that describes the roles and responsibilities 

around recovery and resolution planning was adopted by the CEO on October 21, 2016. 

Different functions within the Bank and the U.S. operations own the content, and thus

are responsible for providing relevant information, reviewing and signing off on their 
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respective parts of the U.S. resolution plan. The maintenance of the plan is coordinated 

by the CRO through Group Operational Risk. This function is also responsible for 

coordinating the activities needed to keep the plan updated and securing proper review 

and approval by the authorized decision making bodies.

10. MATERIAL MANAGEMENT INFORMATION SYSTEMS

The Bank’s U.S. banking operations utilize management information systems to support 

a variety of business functions. These systems include applications to conduct business 

activities across all financial products, as well as generate accounting, financial, 

operations, regulatory and risk management reports. The relevant management 

information systems are described in Swedbank’s resolution plan.

11. RESOLUTION STRATEGY

As required by the Final Rule, the Bank has assumed for purposes of this Resolution Plan 

that:

• An idiosyncratic event causes the failure of one or more major branches and 

subsidiaries of the Bank, leading to the material financial distress and ultimate 

failure of the Bank under the severely adverse economic conditions provided to the 

Bank by the Federal Reserve pursuant to 12 U.S.C. § 5365(i)(1)(B);

• Financial markets are functioning normally; and

• There is no extraordinary government support available to the Bank in the U.S. or 

Sweden that would affect the U.S. operations of the Bank.

Swedbank is assuming for purposes of this resolution plan that the Bank’s resolution 

strategy for its U.S. operations, in the event of a material financial distress or failure of 

the Bank, would be to pursue an orderly liquidation of all assets of the NY Branch and 

the Bank’s U.S. nonbank subsidiary. 

Swedbank’s operations in the U.S. will be subject to several different insolvency regimes 

in the event of a failure or resolution of Swedbank:

• The NY Branch would be subject to liquidation under New York Banking Law.

• Swedbank Securities would be wound down after the initiation of a Securities 

Investor Protection Act (SIPA) proceeding. SIPA operates in conjunction with the 

U.S. Bankruptcy Code in a liquidation proceeding. 

However, the Bank recognizes that future developments in the context of its global 

resolution strategy might impact its future resolution planning, and that ultimately, the 

resolution strategy chosen by the relevant resolution authority will be dependent on the 

facts and circumstances existing at the time of resolution. Sweden has adopted the 

legislative act implementing the European Parliament ́s and the Council ́s Bank 

Recovery and Resolution Directive (the “BRRD”) into local legislation, and the recovery 

and resolution planning requirements of the BRRD are effective since February 1, 2016.