BANCO BRADESCO S.A.

Resolution Plan

Public Section

July 2022
i

Table of Contents

Page

I. INTRODUCTION..............................................................................................................1

II. EXECUTIVE SUMMARY ...............................................................................................1

A. Material Entities.....................................................................................................2

Banco Bradesco S.A. New York Branch .................................................................2

Bradesco Securities Inc............................................................................................2

Bradesco BAC Florida Bank ...................................................................................2

Bradesco BAC Florida Investments Corp................................................................2

B. Core Business Lines...............................................................................................3

C. Critical Operations ................................................................................................3

D. Principal Officers...................................................................................................3

E. High-Level Description of Resolution Strategy...................................................4

III. FINANCIAL INFORMATION ........................................................................................4

A. Assets and Liabilities of Material Entities...........................................................4

B. Capital and Funding Sources................................................................................6

C. Material Hedges/Hedging Strategies....................................................................6

D. Booking of Trading and Derivatives Activities ...................................................6

E. Membership in Trading, Payment and Clearing Systems.................................6

IV. ORGANIZATIONAL STRUCTURE/FOREIGN OPERATIONS...............................7

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

VI. CORPORATE GOVERNANCE......................................................................................8

A. Risk Management ................................................................................................11

B. Communications with Regulators......................................................................13

VII. MANAGEMENT INFORMATION SYSTEMS...........................................................14
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A. Daily Liquidity Ratio/Capital Ratio Reports ....................................................14

B. Data Pro (eIBS System).......................................................................................14

C. Order Management Systems...............................................................................15

Table of Figures1

Figure 1. - Key Management and Principal Officers...................................................................... 3

Figure 2. - Executive Committees of the Capital Management Framework ................................ 10

Figure 3. - Banco Bradesco S.A. Senior Management ................................................................. 11

Figure 4. - Loan Classification Table ........................................................................................... 12

1 All figures embedded in this section of the Resolution Plan are listed on Annex A (see separate file).
1

I. INTRODUCTION

This resolution plan (the “Plan”) for the U.S. operations of Banco Bradesco S.A. 

(“Bradesco”) is submitted pursuant to Section 165(d) of the Dodd-Frank Wall Street Reform and 

Consumer Protection Act, as amended by the Economic Growth, Regulatory Relief, and 

Consumer Protection Act of 2018, and applicable regulations of the Board of Governors of the 

Federal Reserve System (the “Federal Reserve”) and the Federal Deposit Insurance Corporation 

(the “FDIC”), as codified at 12 C.F.R. Parts 243 and 381. In October 2019, the Federal Reserve 

and the FDIC adopted a final rule revising resolution planning requirements (the “Final Rule”).2

Bradesco is a foreign banking organization required to file this Plan pursuant to the Final 

Rule. This Plan is intended to describe the resolution strategy for Bradesco’s material entities 

and core business lines domiciled in the United States as well as provide an explanation of how 

resolution planning for certain U.S. entities is integrated into Bradesco’s overall resolution and 

contingency planning process. Under the Final Rule, Bradesco is a triennial reduced filer and is 

required to submit a reduced resolution plan as described in 12 C.F.R. § 243.7 and 12 C.F.R. 

§ 381.7. Accordingly, this Plan will address material changes experienced by Bradesco, changes 

to the strategic analysis and any changes to information provided in accordance with 12 U.S.C. 

§§ 5365(d)(1)(A), (B) and (C) since Bradesco’s last filed resolution plan.

II. EXECUTIVE SUMMARY

Bradesco is a sociedade anônima organized under the laws of Brazil. Bradesco is a fullservice financial institution providing, directly or through its subsidiaries, a full range of 

banking, financial, purchasing consortium management, asset management, insurance, 

investment banking, pension plan and capitalization bond services for all segments of the 

Brazilian market. While Bradesco’s activities are based primarily in Brazil, Bradesco also offers 

international services through branches and subsidiaries located in the United States, the United 

Kingdom, Cayman Islands, Argentina, Luxembourg, Japan, China and Mexico.

Bradesco’s U.S. presence consists of four entities: (i) Banco Bradesco S.A. New York 

Branch (the “New York Branch”); (ii) Bradesco Securities Inc. (“Bradesco Securities”), a 

brokerage firm based in New York; (iii) Bradesco BAC Florida Bank (the “Florida Bank”), a 

state-chartered non-member bank; and (iv) Bradesco BAC Florida Investments Corp. (“Florida 

Investments”), a brokerage firm based in Florida and a direct subsidiary of the Florida Bank. As 

of December 31, 2021, the U.S. total assets of Bradesco were $6.86 billion.

This Plan describes Bradesco’s resolution planning for the New York Branch, Bradesco 

Securities, the Florida Bank and Florida Investments under two hypothetical material financial 

distress or failure scenarios: (i) the U.S. operations only are under resolution; and (ii) Bradesco is 

also in resolution. We have omitted from this strategic analysis any resolution plan that may 

involve an insolvency regime other than the U.S. bankruptcy laws in accordance with 12 C.F.R. 

§ 243.4(h)(3) and 12 C.F.R. § 381.4(h)(3).

2 See Federal Reserve and FDIC, Resolution Plans Required, 84 Fed. Reg. 59194 (Nov. 1, 2019). 
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A. Material Entities

A material entity is defined by the Final Rule as “a subsidiary or foreign office of the 

covered company that is significant to the activities of an identified critical operation or core 

business line, or is financially or operationally significant to the resolution of the covered 

company.” Bradesco has identified four material entities within the meaning of the Final Rule, 

as described below (collectively, “Material Entities”).

Banco Bradesco S.A. New York Branch

The New York Branch is a legal and operational extension of Bradesco and is not a 

separate legal entity. The New York Branch is licensed by the Office of the Comptroller of the 

Currency (the “OCC”) and is principally engaged in trade finance for Brazilian and 

U.S. companies. The New York Branch also engages in a de minimis amount of non-trade 

finance related lending to U.S. companies. The New York Branch is located at 450 Park 

Avenue, 32nd floor, New York, New York 10022-2605. As of December 31, 2021, the New 

York Branch had total assets of $3.89 billion and a credit portfolio of $519 million.

Bradesco Securities Inc. 

Bradesco Securities is a broker-dealer incorporated under the laws of the State of 

Delaware. It is registered with the Securities and Exchange Commission (“SEC”) and has been a 

member of the Financial Industry Regulatory Authority (“FINRA”) since March 23, 2001. 

Bradesco Securities is also a member of NASDAQ, obtaining membership status therewith on 

July 31, 2006. The main business function of Bradesco Securities is acting as an executing 

broker for major institutional clients. Bradesco Securities facilitates the purchases and sales of 

U.S. equities with an emphasis on Brazilian American Depository Receipts and fixed income 

instruments with a focus on Brazilian corporate Eurobonds in U.S. dollar denominations. The 

clients of Bradesco Securities are fully introduced to the firm’s clearing agent and custodian, 

National Financial Services, L.L.C. (“NFS”). All securities transactions executed by Bradesco 

Securities are settled on a delivery versus payment/receive versus payment (“DVP/RVP”) basis 

between NFS and the client’s custodian or prime broker. Bradesco Securities is not at any time 

in possession of a customer’s funds or securities. Bradesco Securities is located at 450 Park 

Avenue, 32nd Floor, New York, New York 10022-2605.

Bradesco BAC Florida Bank

Bradesco BAC Florida Bank is a full-service bank with one branch located in Coral 

Gables, Florida. It has total assets of approximately $2.9 billion and total deposit liabilities of 

approximately $2.6 billion as of March 31, 2022. The Florida Bank is located at 2333 Ponce de 

Leon Boulevard, Coral Gables, Florida 33134-5427.

Bradesco BAC Florida Investments Corp.

Florida Investments is a broker-dealer incorporated under the laws of the State of Florida. 

It is registered with the SEC and is a member of FINRA. Florida Investments is wholly owned 

by the Florida Bank. The main business function of Florida Investments is acting as an 

executing broker for retail and institutional clients. Florida Investments clears all of its securities 
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transactions on a fully-disclosed basis through Pershing LLC (“Pershing”). Accordingly, 

customer accounts are cleared and carried by Pershing. Florida Investments is located at 2333 

Ponce de Leon Boulevard, Suite 700, Coral Gables, Florida 33134-5427.

B. Core Business Lines

A core business line is defined by the Final Rule as “those business lines of the covered 

company, including associated operations, services, functions and support, that, in the view of 

the covered company, upon failure would result in a material loss of revenue, profit, or franchise 

value.” Bradesco has identified two core business lines within the meaning of the Final Rule. 

Corporate Banking and Private Banking

Through the New York Branch and Florida Bank, Bradesco provides corporate banking 

services to multinational companies consisting of trade finance, revolving credit facilities, letters 

of credit and guarantees. Both the New York Branch and Florida Bank also provide certain 

private banking products, such as money market and demand deposit accounts, savings and time 

deposits.

Trading

Through Bradesco Securities and Florida Investments, Bradesco’s trading activities 

consist of trading on a riskless principal basis, executing transactions in equity and fixed income 

securities on behalf of its clients and affiliates and acting as a placement agent for initial public 

offerings and other capital market transactions on behalf of other affiliates. As a placement 

agent, Bradesco Securities and Florida Investments have no capital commitment, and all 

financial risk remains with the affiliates or issuers.

C. Critical Operations

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

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

which would pose a threat to the financial stability of the United States.” Bradesco has not 

identified any critical operations within the meaning of the Final Rule.

D. Principal Officers

Figure 1. - Key Management and Principal Officers

Bradesco

Octavio de Lazari Junior Chief Executive Officer

Maurício Machado de Minas Executive Vice President

Marcelo de Araújo Noronha Executive Vice President

André Rodrigues Cano Executive Vice President
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New York Branch

Roberto Schwartz Deputy General Manager

Amir Silva Operations Manager

Androula Sergiou Controller

Luis Cifuentes Chief Compliance Officer

John Christie IT Manager

Bradesco Securities

Fernando Reitzfeld Head of Global Markets

Isabela Behar Chief Compliance Officer

Florida Bank

Henrique Pinto Chief Executive Officer

David Hernandez Chief Risk Officer

Florida Investments

Ricardo Lanfranchi Chief Executive Officer

Dulce Maria Galindo Gnibus Chief Compliance Officer

E. High-Level Description of Resolution Strategy

In the event of material financial distress or failure of any or all of the Material Entities, 

whereas Bradesco is not under resolution, Bradesco would evaluate the business viability of the 

Material Entities. If the Material Entities are found to be viable, then Bradesco would provide 

liquidity and capital to them for whatever time period is necessary. If the Material Entities are 

found not to be viable, then Bradesco would proceed with a winding down of the Material 

Entities in an organized and expedited manner, providing sufficient liquidity to repay its 

creditors in connection with all of its outstanding debt facilities.

In the event of material financial distress or failure of the Brazilian company, this Plan 

assumes that the Brazilian government does not provide Bradesco with financial assistance to 

provide inter-company liquidity to the Material Entities. In this event, each Material Entity 

would wind down in accordance with U.S. federal laws and regulations.

III. FINANCIAL INFORMATION

A. Assets and Liabilities of Material Entities

The New York Branch’s assets consist of cash and other cash items, loans made to 

affiliates, loans made abroad, loans and other amounts due from other banking institutions and 

capital equivalency deposits pledged to the OCC. The New York Branch’s material liabilities 

include debt owed to third-party banking institutions in connection with its outstanding working 
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capital and trade finance loan facilities. As of December 31, 2021, debt outstanding to such 

third-party banks equaled $217,468,422.26. Payments required to service such debt are required 

at maturity, with interest, at various maturity dates not exceeding one year. The New York 

Branch also has material liabilities consisting of inter-company loans payable to affiliates, time 

deposits and certificates of deposits and customer and affiliate deposit accounts, including 

money market and savings accounts. The inter-company loans payable to affiliates generally 

have maturities ranging from one to seven years (last maturity deal date February 24, 2023) and 

are unsecured obligations of the New York Branch. The maturities are always matched with 

assets of the New York Branch. 

The New York Branch generally has little reliance on credit sensitive funding (due to the 

high credit quality of its loan portfolio and absence of complex funding structures). Its $5 billion

Yankee CD program (the “Yankee CD Program”) has been used, since its inception in 

September 2010, as a source of funding. There are no secured or subordinated debt instruments 

issued by the New York Branch or any other complex debt instruments used as a source of 

funding for the New York Branch.

The liabilities of the New York Branch are matched to the maturity of its assets. Funding 

obtained and having a tenor up to seven days is kept with the Federal Reserve Bank of New York

(e.g., sight cash deposited by customers through money market, demand deposit accounts and 

overnight and time deposits). The New York Branch’s capitalization consists of $1,215,014,831, 

including long-term funding from Bradesco. As of December 31, 2021, the New York Branch’s 

net due to position was $274,580,000 (equivalent to 0.77% of the New York Branch’s total 

liabilities). Such amounts, together with the New York Branch’s equity, amount to 0.22% of the 

New York Branch’s third-party loan portfolio.

As of December 31, 2021, the total assets of Bradesco Securities were $60,551,952 and 

material liabilities, consisting of accrued operating expenses and taxes payable, were 

$8,569,353.75. None of these material liabilities consist of secured obligations. As of December 

31, 2021, Bradesco Securities reported net capital in the amount of $13,018,335, which exceeds 

Bradesco Securities’ minimum net capital requirement of $250,000.

The Florida Bank’s assets consist of cash and other cash items, loans and other amounts 

due from other banking institutions and securities. The Florida Bank’s material liabilities 

include interest-bearing deposits, of which approximately 55% are insured, and other borrowed 

funds. As of March 31, 2021, these other borrowed funds equaled $63,050,000. The Florida 

Bank also has material liabilities certificates of deposits and customer and affiliate deposit 

accounts, including money market and savings accounts.

As of December 31, 2021, the total assets of Florida Investments were $5,824,808 and 

material liabilities, consisting of accrued operating expenses and other payables, were 

$1,266,345. As of December 31, 2021, Florida Investments reported net capital in the amount of 

$3,384,492, which exceeds its minimum net capital requirement of $100,000.
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B. Capital and Funding Sources

The New York Branch receives its funding for operating expenses largely from its 

deposit-taking activities in the form of corporate time deposits, direct-deposit accounts, escrow 

account, money market accounts and through its Yankee CD Program. Further, the New York 

Branch receives loans from third-party banks (consisting of both foreign and domestic banks). 

As of December 31, 2021, debt outstanding to such third-party banks equaled $217,468,422.26. 

Finally, the New York Branch also borrows certain amounts from Bradesco’s Cayman Islands 

branch. As of December 31, 2021, amounts outstanding owed to the Cayman Islands branch 

equaled $975,550,944.

Bradesco Securities obtains its working capital for operating expenses from its parent by 

means of a Transfer Pricing Agreement. Bradesco Securities does not borrow any amounts from 

any third-party lenders.

The Florida Bank is a wholly owned subsidiary of Banco Bradesco, S.A. and it funds 

itself largely through domestic and foreign deposits and borrowings. As of December 31, 2021, 

the Florida Bank had non-interest- and interest-bearing deposits totaling $2,263,498,054 and 

borrowings of $106,623,319.

Accordingly, subject to liquidity reserves being utilized for the continued operations of 

the U.S. Material Entities, the resolution of Bradesco would also likely have a negative impact 

on the liquidity needs of the Material Entities and their core business lines.

C. Material Hedges/Hedging Strategies

None of the Material Entities engage in any material hedges. However, the New York 

Branch engages in certain ordinary course FX forwards in connection with loans made by the 

New York Branch in foreign currencies.

D. Booking of Trading and Derivatives Activities

The trading activities of Bradesco Securities are booked through one of its electronic 

order management systems, (i) Bloomberg Sell-Side Execution & Order Management Solutions 

(“SSEOMS”) for equity orders and (ii) Bloomberg Trade Order Management Solutions 

(“TOMS”) for fixed income orders. These systems, with the assistance of the Operations 

Department of Bradesco Securities, feed directly into the FBSI system, which is the internal 

clearance and settlement system of the firm’s clearing agent. Order tickets and confirmations are 

created and maintained in accordance with all applicable SEC and FINRA requirements. 

Although not currently dealing with any derivatives, the New York Branch is considering 

engaging in swap transactions for hedging purposes in the near future.

E. Membership in Trading, Payment and Clearing Systems

Bradesco Securities is an SEC registered broker-dealer and member of FINRA and

NASDAQ. Bradesco Securities executes equity transactions using Electronic Communication 

Networks or brokers on the NYSE floor. Bradesco Securities uses Bloomberg L.P.’s electronic 

order management systems, SSEOMS and TOMS, for all of its orders. Bradesco Securities has 
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engaged NFS to serve as its custodian and clearing firm and the entity to Bradesco Securities’ 

clients are introduced. All transactions are settled on a DVP/RVP basis between NFS and the 

client’s custodian or prime broker. Bradesco Securities does not hold client funds or securities at 

any time, and it does not conduct trading for its own proprietary account.

Florida Investments is an SEC registered broker-dealer and member of FINRA. Florida 

Investments has engaged Pershing to serve as Florida Investments’ custodian and clearing firm 

and the entity to which clients of Florida Investments are introduced. All transactions are settled 

on a fully-disclosed basis between Pershing and the client’s custodian or prime broker.

IV. ORGANIZATIONAL STRUCTURE/FOREIGN OPERATIONS

Bradesco is a sociedade anônima organized under the laws of Brazil. The New York 

Branch is a branch of Bradesco. Bradesco Securities is a direct, wholly owned subsidiary of 

Bradesco. The Florida Bank is a subsidiary bank of Bradesco. Florida Investments is a direct, 

wholly owned subsidiary of the Florida Bank.

V. MATERIAL SUPERVISORY AUTHORITIES

The New York Branch is supervised by: 

Office of the Comptroller of the Currency

400 7th Street, SW, Suite 3E-218

Washington, DC 20219

Telephone: (202) 649-6800

Federal Reserve Bank of New York

33 Liberty Street

New York, NY 10045

Telephone: (212) 720-5000

Bradesco Securities is supervised by:

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Telephone: (202) 942-8088

Financial Industry Regulatory Authority

1735 K Street, NW

Washington, DC 20006

Telephone: (301) 590-6500
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The Florida Bank is supervised by:

Florida Office of Financial Regulation

200 E. Gaines Street

Tallahassee, FL 32399

Telephone: (850) 487-9687

Federal Deposit Insurance Corporation

550 17th Street, NW

Washington, DC 20429-9990

Telephone: (877) 275-3342

Florida Investments is supervised by:

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Telephone: (202) 942-8088

Financial Industry Regulatory Authority

1735 K Street, NW

Washington, DC 20006

Telephone: (301) 590-6500

The Brazilian authority responsible for resolving Bradesco is the following:

Central Bank of Brazil

Av. Paulista, 1804

São Paulo, SP 01310-922

Brazil

Telephone: 55 11 (3491-6122)

VI. CORPORATE GOVERNANCE

The National Monetary Board, in its Act no. 3988/2011(adjusted by Act no. 4388/2014) 

(the “Act no. 3988” and “Act no. 4388”), issued regulations for the implementation of a 

compliance structure for all financial institutions in the Brazilian financial system. “Capital 

management” was defined therein as the ongoing process of monitoring and control of capital 

held by the institution, evaluating capital requirements to cover risks to which the institution is 

exposed and the planning of targets for capital considering the institution’s strategic objectives. 

In managing their capital, the Act no. 3988 and Act no. 4388 requires institutions to adopt a 

forward-looking perspective, anticipating capital requirements deriving from potential changes in 

market conditions.

Pursuant to the Act no. 3988 and Act no. 4388, the capital management structure calls 

upon institutions to define a capital plan in conformity with the institution’s strategic planning, 

including projections for at least three years. Current regulations require the following 
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considerations to be included in preparation of such capital plan: targets, projections and capital 

sufficiency for the base scenarios and stress scenarios. Capital plans shall also identify the 

institution’s main sources of capital and the actions to be considered in the capital contingency 

plan.

One of the tools used for capital management is the risk appetite, which refers to risk 

types and levels that Bradesco is willing to accept in pursuing its objectives. It is reflected in its 

risk and capital management, which in turn influences the culture or actions of the Bradesco.

Within Bradesco, risk appetite is defined and formalized by the Board of Directors. It is 

supported by the Risk and Capital Allocation Integrated Management Committee, whose 

responsibility is to validate and submit to the Board of Directors the proposed risk appetite and 

exposure limits by type of risk and risk and capital management policies. Risk appetite is 

aligned with Bradesco’s strategy, demonstrating the engagement of the governance structure in 

defining and monitoring it. The risk monitoring process is corporate and begins with Bradesco’s 

budget process.

In December 2014, the Board of Directors approved the adoption of a buffer to 

supplement the regulatory capital requirement. It is applied to the Basel Index Capital, Capital 

Tier 1 and Capital Common Tier 1. The methodology to calculate the buffer is based on three 

premises: strategic acquisitions, other non-measurable risks and stress scenarios. This 

supplementary measurement of risk appetite uses solvency limit alerts, with reports and specific 

actions for each alert status, adhering to the governance defined by Bradesco. 

For Bradesco, the capital plan and capital contingency plan are considered to comprise 

part of the Bank’s capital management structure. In this context, capital management is 

performed through collegiate decisions made in corporate governance forums, where different 

levels of executive management are represented. The meetings are held at least quarterly and 

more frequently if necessary.

The capital plan and capital contingency plan consider a consolidated view of all of 

Bradesco, including foreign branches, and aim to maintain and restore capital ratios according to 

internal (i.e., risk appetite buffer) and regulatory limits. The plans are prepared by the Planning, 

Budget and Control Department. The processes and procedures established by the Planning, 

Budget and Control Department include the participation of several other departments and 

business units, including Integrated Risk Control, Guarantees and Registration, Research and 

Economic Studies Department, Treasury, Accounting Department, Tax Audit Department, 

Internal Audit and Bradesco Insurance Group.

Additionally, with the objective of evaluating eventual contingency situations and 

required actions to restructure Bradesco’s capital, Executive Directors from the Finance and Risk 

areas, meet monthly, considering projections and simulations for a time horizon from three to 

five years. These simulations contemplate several variables impacting Bradesco’s capital base 

for the upcoming five years. The results are presented to the executive forums defined in 

Bradesco’s Corporate Governance for Capital Management for the required decisions.
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The policies and strategies for capital management and contingency plan are evaluated by 

the Capital Management Executive Committee, validated by the Integrated Risk Management 

and Allocation of Capital Committee and approved annually by the Board of Directors. In 

addition to the capital management policy, Bradesco has specific rules that govern the capital 

management process, which are reviewed at least annually by the Planning, Budget and Control 

Department. The capital management framework, composed of Committees to advise the Board 

of Directors and the Executive Board in making strategic and capital decisions, is as follows:

Figure 2. - Executive Committees of the Capital Management Framework

(1) Risk management executive committees: Credit, Market and Liquidity, Operational and Social and Environmental Risk and 

Bradesco Insurance Group and BSP Empreendimentos Imobiliários.

Executive management receives daily reports on liquidity and capital risk, such as 

minimum liquidity reserve (“RML”) and capital adequacy, weekly reports of interest rate risk for 

the banking book through economic value of equity methodology and monthly reports of trial 

balance and financial results versus the plans included in the budget. Any deviations or 

exposures in excess of the predetermined values (alert triggers) are immediately reported to 

management, the forums and/or the Board of Directors pursuant to prevailing policies.

BOARD OF 

DIRECTORS

INTEGRATED RISK 

MANAGEMENT AND 

ALLOCATION OF 

CAPITAL COMMITTEE

EXECUTIVE RISK 

MANAGEMENT 

COMMITTEES (1)

CAPITAL 

MANAGEMENT 

EXECUTIVE 

COMMITTEE

STRATEGIC 

PLANNING 

EXECUTIVE 

COMMITTEE
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Figure 3. - Banco Bradesco S.A. Senior Management

Banco Bradesco S.A. Senior Management Officials responsible for overseeing the 

development, maintenance, implementations and filing of this Plan and compliance 

therewith:

Name Title

André Rodrigues Cano Executive Vice President (coordinator) 

Maurício Machado de Minas Executive Vice President 

Marcelo de Araújo Noronha Executive Vice President 

Cassiano Ricardo Scarpelli Executive Vice President 

Eurico Ramos Fabri Executive Vice President 

Moacir Nachbar Junior Executive Vice President (CRO) 

Marlos Francisco de Souza Araujo Department Director 

Reports regarding the development, maintenance and implementation of the capital and 

contingency plans are delivered to such individuals monthly.

A. Risk Management

Risk management at Bradesco is governed by non-statutory and executive committees, 

responsible for assisting the Board of Directors in making strategic decisions. The Integrated 

Risk Management and Capital Allocation Committee, a non-statutory committee, advises the 

Board of Directors on the performance of its role in managing and controlling risks and capital.

This non-statutory committee is assisted by four executive risk management committees: 

(i) Credit, (ii) Market and Liquidity, (iii) Operational and Social and Environmental Risk and 

(iv) Bradesco Insurance Group and BSP Empreendimentos Imobiliários and by a Capital 

Management Executive Committee.

Credit risk is conducted on an institution-wide basis. The credit risk governance policy 

and limits are validated by the Integrated Risk Management and Capital Allocation Committee 

and submitted to the Board of Directors for approval at least once a year. Trade finance loans 

disbursed by the New York Branch are subject to credit approval by Bradesco’s head office. 

Such loans must comply with the global policy on exposure limits to single borrowers, with 

maximum exposure to any one client being up to 10% of Bradesco shareholder’s equity.

Bradesco utilizes a credit score evaluation system for each loan that is approved. This 

system analyzes the profile and economic capacity of the borrower and guarantors in addition to

specific information regarding the loan. The following loan classification table is used by 

Bradesco for purposes of classifying existing loans (including loans made by the New York 

Branch):
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Figure 4. - Loan Classification Table

“AA”

(Excellent)

These are loans paying as agreed and are supported by the customer’s 

capacity to repay and /or support of cosigners / endorsers and/or guarantors. 

Premium company/group, with size, tradition and market leadership, with 

excellent reputation and economic and financial position.

“A”

(Very Good)

These are loans paying as agreed and are supported by the customer’s 

capacity to repay and /or support of cosigners / endorsers and/or guarantors. 

Company/group, with size, sound economic and financial position, acting in 

markets with good prospects and/or potential for expansion.

“B”

(Good)

These are loans paying as agreed and are supported by the customer’s 

capacity to repay and /or support of cosigners / endorsers and/or guarantors. 

Company/ group that, regardless of size, has a good economic/financial 

position.

“C”

(Acceptable)

These are loans paying as agreed and are supported by the customer’s 

capacity to repay and /or support of cosigners / endorsers and/or guarantors. 

Company/group with a satisfactory economic and financial situation, but 

with performance subject to economic scenario variations.

Global market risk management processes also incorporate the market risk of the New 

York Branch, Bradesco Securities, the Florida Bank and Florida Investments, through value at 

risk, economic value of equity, stress testing and sensitivity analysis methodologies, in addition 

to limits for profit and loss and financial exposure. All such risk measurement methodologies 

are set forth in a global Market and Liquidity Risk Management Policy, reviewed annually by the 

Board of Directors. For the New York Branch and Florida Bank banking portfolios, the global 

policy requires the branch to monitor interest rate risk limits. For the Bradesco Securities’ 

trading portfolio, the global market risk management policy requires the business unit to monitor 

the following limits: risk, stress, results and financial exposure. In addition to daily risk reports, 

global market risk exposures are discussed weekly by an Executive Committee, which assesses 

results and risks and discusses and validates strategies for the coming weeks. This governance 

process and the limits are validated by both the Board of Directors and the Integrated Risk 

Management and Capital Allocation Committee at least once a year.

Liquidity risk is based on the sizing and monitoring of cash for RML. This monitoring is 

performed daily for the financial conglomerate. Furthermore, the liquidity monitoring is also 

performed individually for each cash center, such as the cash foreign currency financial, where 

the New York Branch is included.

Bradesco adopts for management purposes an additional capital buffer above the 

minimum regulatory capital, aiming to create an additional capital reserve to cover losses arising 

from not measurable risks or resulting from market stress and possible strategic acquisitions. 

Monitoring of capital adequacy is performed by tracking three limits (Total, Pillar 1 and 

Common Pillar 1) by evaluating the excess of available capital in comparison with the minimum 

regulatory and managerial buffer.
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B. Communications with Regulators

The New York Branch communicates credit risk exposures to its regulators through the 

following reports:

(1) Call Report as of the end of each quarter to the Federal Reserve and OCC

Report of Assets and Liabilities of U.S. Branches and Agencies of Foreign Banks—

FFIEC 002

Schedule C reports total Third Party loans

Schedule N reports Past Due, Nonaccrual and Restructured Loans.

Schedule L reports letters of credit and loan commitments

Schedule M reports all related assets & liabilities

(2) Country Exposure Report for U.S. Branches and Agencies of Foreign Banks—FFIEC 

019 at the end of each quarter to the Federal Reserve and OCC. This report includes

direct and indirect claims by country that amount in the aggregate to more than $20 

million.

(3) Shared National Credit Review Report at year-end to the OCC. This report lists all 

loan participations where the New York Branch is the lead bank.

Moreover, Bradesco informs the Central Bank of Brazil of the credit exposure of the Bank. 

The following reports are sent monthly to the Central Bank of Brazil:

(i) SCR: Information Credit System of the Central Bank. This system is a tool for 

recording and query information about loans, guarantees and credit limits granted by 

financial institutions to individuals and companies in the country. SCR is the main 

tool used for banking supervision to monitor the portfolios of financial institutions.

(ii) DLO: Operating Limits Report. The DLO delivers information about capital and 

credit, market and operational risks according to Basel requirements. It must be sent 

by financial institutions to report the scope of the financial conglomerate.

The Florida Bank communicates credit risk exposures to its regulators through the 

following reports:

(i) Call Report as of the end of each quarter to the FDIC

Schedule C reports total Third Party loans

Schedule N reports Past Due, Nonaccrual and Restructured Loans.

Schedule L reports letters of credit and loan commitments

Schedule M reports all related assets & liabilities

(ii) Shared National Credit Review Report at year-end to the FDIC. This report lists all 

loan participations where the Florida Bank is the lead bank.

Additionally, Bradesco is required to submit an Internal Capital Adequacy Assessment 

Process (“ICAAP”) report to Brazilian regulators annually. Bradesco Securities does not have 
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credit risk exposure to be reported to regulators. As required of all FINRA-member brokerdealers, Bradesco Securities and Florida Investments file a Financial and Operational Combined 

Uniform Single Report with FINRA monthly and at the end of each fiscal year to report the 

firm’s aggregate indebtedness and its net capital computation. 

As of December 31, 2021, Bradesco Securities reported net capital in the amount of 

$13,018,335, which exceeds Bradesco Securities’ minimum net capital requirement of $250,000. 

In addition, Bradesco Securities is required to file a Risk Assessment Report for Broker and 

Dealers (“Form 17-H”) with the SEC quarterly and at the end of each fiscal year. Finally,

Bradesco Securities must file annually audited financial data with the SEC and FINRA as well as 

a Securities Investor Protection Corporation (“SIPC”) computation with SIPC.

As of December 31, 2021, Florida Investments reported net capital in the amount of 

$3,384,492, which exceeds its minimum net capital requirement of $100,000. In addition, 

Florida Investments is required to file Form 17-H with the SEC quarterly and at the end of each 

fiscal year. Finally, Florida Investments must file annually audited financial data with the SEC 

and FINRA as well as a SIPC computation.

VII. MANAGEMENT INFORMATION SYSTEMS

The New York Branch and the Florida Bank must comply with Bradesco’s anti-money 

laundering policy and procedures. Such procedures require an analysis of account activity 

reports for money laundering daily. Further, when warranted, the New York Branch and the 

Florida Bank file Suspicious Activity Reports and Currency Transaction Report with the 

Financial Crimes Enforcement Network of the U.S. Department of the Treasury. The New York 

Branch also has an electronic Office of Foreign Assets Control (“OFAC”) system, which will 

notify branch representatives if a customer opening an account is on an OFAC list.

A. Daily Liquidity Ratio/Capital Ratio Reports

All Daily Liquidity Ratio/Capital Ratio Reports are prepared by the Controller of the 

New York Branch and submitted to senior management daily and discussed in the Assets and 

Liabilities Committee at their monthly meetings. The controller uses the eIBS System (discussed 

below) to obtain the information needed for these reports and then compiles the information into 

Microsoft Excel spreadsheets.

B. Data Pro (eIBS System)

The eIBS system is a comprehensive banking software solution that was targeted to a 

customer base of small banks along with the U.S. Branches of large foreign financial institutions. 

This product was developed by Datapro, Inc. of Miami, FL, and its initial release was in the mid1980s.

The system was designed with a modulated concept that can support many of the 

financial activities that are associated with both retail and wholesale banking. These activities 

include retail accounts, lending, trade finance, credit facilities, branch administration and more. 

Supporting these activities is a core system that registers the customer information and produces 
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the financial statements of the bank. The system also facilitates interfacing with external 

payment systems to process wire transfers with other banks. Additionally, the system supports 

the handling of multiple currencies and is capable of processing multiple branches or banks all 

within the same host system.

The New York Branch in 1999 licensed the eIBS system to be used as the central data 

processing system for all branch transactions with each branch employee including management 

interacting in some form with the system to process these transactions. This system also 

generates a wide range of reports intended for various levels of employees, including at the 

department level, supervisor and, ultimately, the senior management of the New York Branch. 

The eIBS system produces customer notifications and generates the financial balances for 

official reporting. This system also maintains a historical database for several years that is 

readily available for customer and transaction statements.

Daily, the eIBS banking system produces a comprehensive set of reports on the New 

York Branch’s financial activities and balances from both the customer and financial product 

perspective. These reports include various financial statements with details of the balance sheet 

and off-balance sheet ledgers, along with a profit and loss statement. The system also provides

supporting setoff customer reports that detail the balances and transaction activities for all 

customer accounts. Further, it generates reports on the position of all financial transactions that 

are registered within the New York Branch, including each and every asset, liability and 

contingent that composes the New York Branch’s and financial statement. Management has the 

ability to check reports that validate the balances of financial products with the positions of the 

financial ledgers and serve as an absolute integrity check on the financial statements of the New 

York Branch. These reports are kept on file for future reference, audits and historical research.

C. Order Management Systems

Bradesco Securities utilize two of Bloomberg L.P.’s order management systems, 

SSEOMS and TOMS, to enter securities transaction orders on behalf of its clients. Use of each

system is governed by a contractual agreement with Bloomberg L.P. Under such contractual 

agreement, Bloomberg L.P. is required to provide technical support and address any technical 

difficulties with the systems. To date, no material deficiencies with Bloomberg L.P.’s order 

management systems have been identified by Bradesco Securities. Other than these Bloomberg 

L.P. systems, Bradesco Securities does not use any other key management information system.

Through the Bloomberg order management systems or through its clearing firm, 

Bradesco Securities has the ability to obtain daily, weekly and monthly activity reports. These 

activity reports can be sorted by security, client, date or by transaction. Any discrepancies will 

be reported in a timely manner to the compliance department and management and if necessary, 

to the Board of Directors. All data underlying the resolution plan may also be obtained through the 

Bradesco Securities’ financial reports.