Non-compliance of non-GAAP reporting provided to investors including Forward-looking Statements: 

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These accounts that should be provided by Fintech developments recommended by FSB (June 27, 2017) to be implemented in the PERSPECTIVE OF THE CFO considering the framework of Laws and Directives in force (BCBS, Dec. 2017, SEC, April 2018, EU, May 2017, etc.) are still missing:

  • Employee Engagement (EE) Accounts,
  • Potentially Recoverable Losses (PRL) Accounts and
  • Incentivized Pay Leverage Effect (IPLE) Accounts.

Because these accounts are lacking, the non-GAAP financial measures of banks and CCRs, do not provide investors with the management accounting process mitigating operational risk losses to adjust costs, expenses, gains and losses and other items specified for take over from accounting for measures in accordance with GAAP. The legal requirement is not to provide non-GAAP financial measures most comparable to GAAP measures. The reporting provided should demonstrate to investors how the non-GAAP accounts complement the GAAP accounts from the CFO's perspective for current and future financial performance.

The Financial Stability Institute recalled in October 2017, in accordance with the Basel III liquidity monitoring tools, concerning the liquid assets of a bank that all assets in the stock should be unencumbered:

  • “Unencumbered means free of legal, regulatory, contractual or other restrictions on the ability of the bank to liquidate, sell, transfer, or assign the asset. An asset in the stock should not be pledged (either explicitly or implicitly) to secure, collateralize or credit-enhance any transaction, nor be designated to cover operational costs (such as rents and salaries).’’


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