Pricing Supplement No. J224
To the Underlying Supplement dated June 24, 2010,
Product Supplement No. JPM-III dated July 15, 2009,
Prospectus Supplement dated March 25, 2009 and
Prospectus dated March 25, 2009
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Filed Pursuant to Rule 424(b)(2)
Registration Statement No. 333-158199-10
October 28, 2011
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Structured
Investments
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Credit Suisse
$8,128,000
Buffered Return Enhanced Notes due November 15, 2012
Linked to a Basket Consisting of the Hang Seng China Enterprises Index, the KOSPI 200 Index, the MSCI Taiwan Index, the Hang Seng® Index and the MSCI Singapore Index and related Asian Currencies
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·
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The notes are designed for investors who seek a return at maturity of two times the appreciation, if any, of a weighted basket of Asian indices multiplied by the performance of their respective currencies relative to the U.S. dollar up to a Maximum Return on the notes of 15.60%. Investors should be willing to forgo interest and dividend payments and, if the Basket declines by more than 10%, be willing to lose some or all of their investment. Any payment on the notes is subject to our ability to pay our obligations as they become due.
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Senior unsecured obligations of Credit Suisse AG, acting through its Nassau Branch, maturing November 15, 2012.†
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Minimum purchase of $10,000. Minimum denominations of $1,000 and integral multiples of $1,000 in excess thereof.
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The notes priced on October 28, 2011 (the “Pricing Date”) and are expected to settle on November 2, 2011. Delivery of the notes in book-entry form only will be made through The Depository Trust Company.
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Issuer:
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Credit Suisse AG (“Credit Suisse”), acting through its Nassau Branch
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Basket:
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A weighted basket consisting of five Asian indices (each a “Basket Component,” and together, the “Basket Components”) and the spot exchange rates of four Asian currencies relative to the U.S. dollar (each a “Basket Currency” and, together, the “Basket Currencies”). We refer to the Basket Components and the Basket Currencies collectively as the “Basket”.
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Basket Component
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Ticker
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Initial Basket Component Level
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Basket Currency
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Initial Spot Rate
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Weighting
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Hang Seng China Enterprises Index
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HSCEI
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10625.20
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Hong Kong dollar (HKDUSD)
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0.12880456
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21.00%
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KOSPI 200 Index
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KOSPI2
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252.47
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Korean won (KRWUSD)
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0.00090494
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25.00%
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MSCI Taiwan Index
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TAMSCI
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269.99
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Taiwan dollar (TWDUSD)
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0.03349186
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20.00%
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Hang Seng Index
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HSI
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20019.20
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Hong Kong dollar (HKDUSD)
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0.12880456
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25.00%
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MSCI Singapore Index
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SIMSCI
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333.04
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Singapore dollar (SGDUSD)
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0.80580177
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9.00%
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Currency of the Issue:
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United States dollars
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Upside Leverage Factor:
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2
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Payment at Maturity:
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If the Basket Return is greater than 1.00, your payment per $1,000 principal amount of notes will be equal to the lesser of (i) $1,000 x [1 + the Maximum Return] and (ii) $1,000 x [1 + (Basket Return – 1) × Upside Leverage Factor].
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If the Basket Return is greater than or equal to 0.90 and less than or equal to 1.00, you will receive a cash payment of $1,000 per $1,000 principal amount of notes.
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If the Basket Return is less than 0.90, you will lose an amount equal to 1.1111% of the principal amount of your notes for every 1% by which the Basket Return is less than 0.90, and you will receive a cash payment per $1,000 principal amount of notes, calculated as follows:
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$1,000 x [1 + (Basket Return – 1 + 10%) × 1.1111]
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You will lose some or all of your investment on the notes if the Basket Return is less than 0.90. Any payment on the notes is subject to our ability to pay our obligations as they become due.
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Maximum Return:
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15.60%
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Basket Component Return:
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For each Basket Component, the performance of such Basket Component from its Initial Basket Component Level to its Final Basket Component Level, calculated as follows:
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Final Basket Component Level
Initial Basket Component Level
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Initial Basket Component Level:
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For each Basket Component, as set forth in the table above.
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Final Basket Component Level:
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For each Basket Component, the arithmetic average of the closing levels of such Basket Component on each of the five Valuation Dates.
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Currency Return:
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For each Basket Currency, the performance of such Basket Currency from its Initial Spot Rate to its Final Spot Rate, calculated as follows:
Final Spot Rate
Initial Spot Rate
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Price to Public(1)
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Fees(2)
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Proceeds to Issuer
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Per note
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$1,000.00
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$10.00
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$990.00
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Total
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$8,128,000.00
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$7,200.00
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$8,046,720.00
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Title of Each Class of Securities Offered
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Maximum Aggregate Offering Price
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Amount of Registration Fee
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Notes
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$8,128,000.00
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$931.47
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October 28, 2011 | (cover continued on next page) |
Spot Rate:
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For each Basket Currency on any day, the official MID WM Reuters fixing at 4:00 pm London Time on such day (Bloomberg page WMCO or any successor page), expressed as the number of U.S. dollars per one unit of such Basket Currency, as determined by the calculation agent, subject to the provisions set forth under “Description of the Notes—Market disruption events” in the accompanying product supplement.
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Initial Spot Rate:
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For each Basket Currency, as set forth in the table above.
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Final Spot Rate:
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For each Basket Currency, the Spot Rate on the Final Valuation Date.
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Basket Return:
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(21.00% x Hang Seng China Enterprises Index Basket Component Return x Hong Kong dollar Currency Return) + (25.00% x KOSPI 200 Index Basket Component Return x Korean won Currency Return) + (20.00% x MSCI Taiwan Index Basket Component Return x Taiwan dollar Currency Return) + (25.00% x Hang Seng Index Basket Component Return x Hong Kong dollar Currency Return) + (9.00% x MSCI Singapore Index Basket Component Return x Singapore dollar Currency Return)
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Valuation Dates:†
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November 5, 2012; November 6, 2012; November 7, 2012; November 8, 2012 and November 9, 2012 (each a “Valuation Date” and November 9, 2012, the “Final Valuation Date”)
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Maturity Date:†
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November 15, 2012
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Listing:
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The notes will not be listed on any securities exchange.
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CUSIP:
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22546TGG0
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•
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Underlying supplement dated June 24, 2010:
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•
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Product supplement No. JPM-III dated July 15, 2009:
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•
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Prospectus supplement dated March 25, 2009:
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•
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Prospectus dated March 25, 2009:
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Basket Component
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Hang Seng China Enterprises Index
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KOSPI 200 Index
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MSCI Taiwan Index
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Hang Seng Index
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MSCI Singapore Index
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Basket Currency
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Hong Kong dollar
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Korean won
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Taiwan dollar
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Hong Kong dollar
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Singapore dollar
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Weighting
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21.00%
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25.00%
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20.00%
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25.00%
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9.00%
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Basket Component Return
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105%
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105%
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105%
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105%
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105%
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Currency Return
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100%
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100%
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100%
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100%
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100%
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Basket Return
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1.050
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Payment at Maturity
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$1,100
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Basket Return
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=
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(21.00% x Hang Seng China Enterprises Index Basket Component Return x Hong Kong dollar Currency Return) + (25.00% x KOSPI 200 Index Basket Component Return x Korean won Currency Return) + (20.00% x MSCI Taiwan Index Basket Component Return x Taiwan dollar Currency Return) + (25.00% x Hang Seng Index Basket Component Return x Hong Kong dollar Currency Return) + (9.00% x MSCI Singapore Index Basket Component Return x Singapore dollar Currency Return)
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=
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(21.00% x 105% x 100%) + (25.00% x 105% x 100%) + (20.00% x 105% x 100%) + (25.00% x 105% x 100%) + (9.00% x 105% x 100%)
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=
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1.050
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Payment at Maturity
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=
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$1,000 x [1 + (Basket Return - 1) x Upside Leverage Factor]
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=
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$1,000 x [1 + (1.050 - 1) x 2]
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=
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$1,100
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Basket Component
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Hang Seng China Enterprises Index
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KOSPI 200 Index
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MSCI Taiwan Index
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Hang Seng Index
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MSCI Singapore Index
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Basket Currency
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Hong Kong dollar
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Korean won
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Taiwan dollar
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Hong Kong dollar
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Singapore dollar
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Weighting
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21.00%
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25.00%
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20.00%
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25.00%
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9.00%
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Basket Component Return
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100%
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100%
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100%
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100%
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100%
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Currency Return
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100%
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110%
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110%
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100%
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110%
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Basket Return
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1.054
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Payment at Maturity
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$1,108
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Basket Return
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=
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(21.00% x Hang Seng China Enterprises Index Basket Component Return x Hong Kong dollar Currency Return) + (25.00% x KOSPI 200 Index Basket Component Return x Korean won Currency Return) + (20.00% x MSCI Taiwan Index Basket Component Return x Taiwan dollar Currency Return) + (25.00% x Hang Seng Index Basket Component Return x Hong Kong dollar Currency Return) + (9.00% x MSCI Singapore Index Basket Component Return x Singapore dollar Currency Return)
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=
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(21.00% x 100% x 100%) + (25.00% x 100% x 110%) + (20.00% x 100% x 110%) + (25.00% x 100% x 100%) + (9.00% x 100% x 110%)
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=
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1.054
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Payment at Maturity
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=
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$1,000 x [1 + (Basket Return - 1) x Upside Leverage Factor]
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=
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$1,000 x [1 + (1.054 - 1) x 2]
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=
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$1,108
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Basket Component
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Hang Seng China Enterprises Index
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KOSPI 200 Index
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MSCI Taiwan Index
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Hang Seng Index
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MSCI Singapore Index
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Basket Currency
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Hong Kong dollar
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Korean won
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Taiwan dollar
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Hong Kong dollar
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Singapore dollar
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Weighting
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21.00%
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25.00%
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20.00%
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25.00%
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9.00%
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Basket Component Return
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120%
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120%
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120%
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120%
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120%
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Currency Return
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100%
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110%
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110%
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100%
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110%
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Basket Return
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1.2648
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Payment at Maturity
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$1,156.00
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Basket Return
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=
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(21.00% x Hang Seng China Enterprises Index Basket Component Return x Hong Kong dollar Currency Return) + (25.00% x KOSPI 200 Index Basket Component Return x Korean won Currency Return) + (20.00% x MSCI Taiwan Index Basket Component Return x Taiwan dollar Currency Return) + (25.00% x Hang Seng Index Basket Component Return x Hong Kong dollar Currency Return) + (9.00% x MSCI Singapore Index Basket Component Return x Singapore dollar Currency Return)
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=
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(21.00% x 120% x 100%) + (25.00% x 120% x 110%) + (20.00% x 120% x 110%) + (25.00% x 120% x 100%) + (9.00% x 120% x 110%)
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=
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1.2648
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Payment at Maturity
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=
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$1,000 x [1 + (Basket Return - 1) x Upside Leverage Factor],
subject to the Maximum Return
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=
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$1,000 x [1 + (1.2648 - 1) x 2], subject to the Maximum Return
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=
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$1,156.00
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Basket Component
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Hang Seng China Enterprises Index
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KOSPI 200 Index
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MSCI Taiwan Index
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Hang Seng Index
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MSCI Singapore Index
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Basket Currency
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Hong Kong dollar
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Korean won
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Taiwan dollar
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Hong Kong dollar
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Singapore dollar
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Weighting
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21.00%
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25.00%
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20.00%
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25.00%
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9.00%
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Basket Component Return
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90%
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90%
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90%
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90%
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90%
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Currency Return
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100%
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100%
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120%
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100%
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125%
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Basket Return
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0.95625
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Payment at Maturity
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$1,000
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Basket Return
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=
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(21.00% x Hang Seng China Enterprises Index Basket Component Return x Hong Kong dollar Currency Return) + (25.00% x KOSPI 200 Index Basket Component Return x Korean won Currency Return) + (20.00% x MSCI Taiwan Index Basket Component Return x Taiwan dollar Currency Return) + (25.00% x Hang Seng Index Basket Component Return x Hong Kong dollar Currency Return) + (9.00% x MSCI Singapore Index Basket Component Return x Singapore dollar Currency Return)
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=
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(21.00% x 90% x 100%) + (25.00% x 90% x 100%) + (20.00% x 90% x 120%) + (25.00% x 90% x 100%) + (9.00% x 90% x 125%)
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=
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0.95625
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Basket Component
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Hang Seng China Enterprises Index
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KOSPI 200 Index
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MSCI Taiwan Index
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Hang Seng Index
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MSCI Singapore Index
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Basket Currency
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Hong Kong dollar
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Korean won
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Taiwan dollar
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Hong Kong dollar
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Singapore dollar
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Weighting
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21.00%
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25.00%
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20.00%
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25.00%
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9.00%
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Basket Component Return
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85%
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70%
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75%
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80%
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90%
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Currency Return
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100%
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100%
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120%
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100%
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125%
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Basket Return
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0.83475
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Payment at Maturity
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$927.50
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Basket Return
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=
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(21.00% x Hang Seng China Enterprises Index Basket Component Return x Hong Kong dollar Currency Return) + (25.00% x KOSPI 200 Index Basket Component Return x Korean won Currency Return) + (20.00% x MSCI Taiwan Index Basket Component Return x Taiwan dollar Currency Return) + (25.00% x Hang Seng Index Basket Component Return x Hong Kong dollar Currency Return) + (9.00% x MSCI Singapore Index Basket Component Return x Singapore dollar Currency Return)
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=
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(21.00% x 85% x 100%) + (25.00% x 70% x 100%) + (20.00% x 75% x 120%) + (25.00% x 80% x 100%) + (9.00% x 90% x 125%)
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=
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0.83475
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Payment at Maturity
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=
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$1,000 x [1 + (Basket Return -1 + 10%) x 1.1111]
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=
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$1,000 x [1 + (0.83475 - 1 + 10%) x 1.1111]
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=
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$927.50
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Basket Component
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Hang Seng China Enterprises Index
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KOSPI 200 Index
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MSCI Taiwan Index
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Hang Seng Index
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MSCI Singapore Index
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Basket Currency
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Hong Kong dollar
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Korean won
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Taiwan dollar
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Hong Kong dollar
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Singapore dollar
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Weighting
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21.00%
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25.00%
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20.00%
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25.00%
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9.00%
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Basket Component Return
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60%
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65%
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70%
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75%
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80%
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Currency Return
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100%
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75%
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85%
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100%
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55%
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Basket Return
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0.593975
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Payment at Maturity
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$659.98
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Basket Return
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=
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(21.00% x Hang Seng China Enterprises Index Basket Component Return x Hong Kong dollar Currency Return) + (25.00% x KOSPI 200 Index Basket Component Return x Korean won Currency Return) + (20.00% x MSCI Taiwan Index Basket Component Return x Taiwan dollar Currency Return) + (25.00% x Hang Seng Index Basket Component Return x Hong Kong dollar Currency Return) + (9.00% x MSCI Singapore Index Basket Component Return x Singapore dollar Currency Return)
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=
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(21.00% x 60% x 100%) + (25.00% x 65% x 75%) + (20.00% x 70% x 85%) + (25.00% x 75% x 100%) + (9.00% x 80% x 55%)
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=
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0.593975
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Payment at Maturity
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=
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$1,000 x [1 + (Basket Return -1 + 10%) x 1.1111]
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=
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$1,000 x [1 + (0.593975 - 1 + 10%) x 1.1111]
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=
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$659.98
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·
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APPRECIATION POTENTIAL IF THE BASKET RETURN IS POSITIVE — The notes provide the opportunity to enhance returns by multiplying any appreciation in the value of the Basket by two, up to the Maximum Return on the notes of 15.60%. Accordingly, the maximum amount payable on the notes is $1,156.00 for every $1,000 principal amount of notes. Because the notes are our senior unsecured obligations, payment of any amount on the notes is subject to our ability to pay our obligations as they become due.
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LIMITED PROTECTION AGAINST LOSS — Payment at maturity of the principal amount of the notes is protected against a decline in the value of the Basket of up to 10%. If the Basket Return is less than 0.90, for every 1% by which the Basket Return is less than 0.90, you will lose an amount equal to 1.1111% of the principal amount of your notes and you could lose your entire investment.
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DIVERSIFICATION AMONG THE BASKET COMPONENTS — The return on the notes is linked to a basket consisting of the Hang Seng China Enterprises Index, the KOSPI 200 Index, the MSCI Taiwan Index, the Hang Seng® Index, the MSCI Singapore Index, and the exchange rates of the Hong Kong dollar, the Korean won, the new Taiwan dollar and the Singapore dollar, each with respect to the U.S. dollar. The Hang Seng China Enterprises Index is a market-capitalization weighted index consisting of all the Hong Kong listed H-shares of Chinese enterprises one year after the first H-share company was listed on the HKSE. H-shares are Hong Kong listed shares, traded in Hong Kong dollars, of Chinese state-owned enterprises. The KOSPI 200 is a capitalization-weighted index of 200 Korean stocks which make up a large majority of the total market value of the KRX Stock Market (“KRX”). The constituent stocks are selected on a basis of the market value of the individual stocks, liquidity and their relative positions in their respective industry groups. The MSCI Taiwan Index is a free float-adjusted market capitalization index of securities listed on the Taiwan Stock Exchange. The Hang Seng® Index is a free-float adjusted market capitalization weighted stock market index of The Stock Exchange of Hong Kong Ltd. (“HKSE”) and purports to be an indicator of the performance of the Hong Kong stock market. The MSCI Singapore Index is a free float-adjusted market capitalization index that is calculated by MSCI Inc. (“MSCI”) and designed to measure equity market performance in Singapore. For further information on the Basket Components, see “The Reference Indices—The Hang Seng® Indices—The Hang Seng China Enterprises Index,” “The Reference Indices—The Korea Stock Price Index 200,” “The Reference Indices—The MSCI Indices—The MSCI Taiwan Index,” “The Reference Indices—The Hang Seng® Indices—The Hang Seng® Index” and “The Reference Indices—The MSCI Indices—The MSCI Singapore Index” in the accompanying underlying supplement.
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THE MATERIAL U.S. FEDERAL INCOME TAX CONSIDERATIONS — Please refer to “The Material United States Federal Income Tax Considerations” in this pricing supplement for a discussion of the material U.S. federal income tax considerations for making an investment in the notes.
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YOUR INVESTMENT IN THE NOTES MAY RESULT IN A LOSS — The notes do not guarantee any return of your investment. The return on the notes at maturity is linked to the performance of the Basket as reflected by the Basket Return. If the Basket Return is greater than or equal to 0.90, you will be entitled to receive at least the principal amount of your notes at maturity. However, if the Basket Return is less than 0.90, your investment will be fully exposed on a leveraged basis to the decline in the value of the Basket and for every 1% by which the Basket Return is less than 0.90, you will lose an amount equal to 1.1111% of the principal amount of your notes and you could lose your entire investment.
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·
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THE NOTES ARE SUBJECT TO THE CREDIT RISK OF CREDIT SUISSE — Although the return on the notes will be based on the performance of the Basket, the payment of any amount due on the notes is subject to the credit risk of Credit Suisse. Investors are dependent on our ability to pay all amounts due on the notes and, therefore, investors are subject to our credit risk. In addition, any decline in our credit ratings, any adverse changes in the market’s view of our creditworthiness or any increase in our credit spreads is likely to adversely affect the value of the notes prior to maturity.
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·
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YOUR MAXIMUM GAIN ON THE NOTES IS LIMITED TO THE MAXIMUM RETURN — If the Basket Return is greater than 1.00, you will receive at maturity $1,000 plus an additional amount that will not exceed the Maximum Return on the notes of 15.60%, regardless of the appreciation in the Basket, which may be significant. Accordingly, the maximum amount payable on the notes is $1,156.00 per $1,000 principal amount of notes. Any payment on the notes is subject to our ability to pay our obligations as they become due.
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·
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CHANGES IN THE VALUES OF THE BASKET COMPONENTS AND THE EXCHANGE RATES OF THE BASKET CURRENCIES MAY OFFSET EACH OTHER — Price movements in the Basket Components and movements in the exchange rates of the Basket Currencies may not correlate with each other. At a time when the value of one or more of the Basket Components increases and/or one or more of the Basket Currencies appreciates relative to the U.S. dollar, the value of the other Basket Components may not increase as much or may even decline and/or one or more of the Basket Currencies may not appreciate as much or may weaken relative to the U.S. dollar. Therefore, in calculating the Basket Return, increases in the value of one or more of the Basket Components and/or increases in the value of one or more of the Basket Currencies relative to the U.S. dollar may be moderated, or more than offset, by lesser increases or declines in the value of the other Basket Components and/or the value of the other Basket Currencies relative to the U.S. dollar.
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·
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THE HONG KONG DOLLAR DOES NOT FLOAT FREELY — Exchange rates of many developed and major emerging economies, including the United States, currently are “floating,” meaning that they are permitted to fluctuate in value relative to other currencies. However, the Hong Kong dollar does not float freely. The exchange rate of the Hong Kong dollar relative to the U.S. dollar is fixed within a narrow range by the Hong Kong Monetary Authority. For so long as the Hong Kong Monetary Authority restricts the Hong Kong dollar from floating relative to the U.S. dollar, the exchange rate between the Hong Kong dollar and the U.S. dollar will not fluctuate by any appreciable amount. If at any time the Hong Kong Monetary Authority permits the Hong Kong dollar to float, the exchange rate between the Hong Kong dollar and the U.S. dollar is likely to move significantly in a very short period of time, which would affect the Basket Return, and, consequently, the value of your notes.
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·
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THE NOTES ARE SUBJECT TO CURRENCY EXCHANGE RISK — Foreign currency exchange rates vary over time, and may vary considerably during the term of the notes. The relative values of the U.S. dollar and each of the Basket Currencies are at any moment a result of the supply and demand for such currencies. Changes in foreign currency exchange rates result over time from the interaction of many factors directly or indirectly affecting economic and political conditions in the country or countries in which such currency is used, and economic and political developments in other relevant countries. Of particular importance to currency exchange risk are:
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·
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existing and expected rates of inflation;
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·
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existing and expected interest rate levels;
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·
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the balance of payments in the United States, China, Korea, Taiwan and Singapore and between each country and its major trading partners; and
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·
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the extent of governmental surplus or deficit in the United States, China, Korea, Taiwan and Singapore.
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·
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CERTAIN BUILT-IN COSTS ARE LIKELY TO ADVERSELY AFFECT THE VALUE OF THE NOTES PRIOR TO MATURITY — While the Payment at Maturity described in this pricing supplement is based on the full principal amount of your notes, the original issue price of the notes includes the agent’s commission and the cost of hedging our obligations under the notes through one or more of our affiliates. As a result, the price, if any, at which Credit Suisse (or its affiliates), will be willing to purchase notes from you in secondary market transactions, if at all, will likely be lower than the original issue price, and any sale prior to the Maturity Date could result in a substantial loss to you. The notes are not designed to be short-term trading instruments. Accordingly, you should be able and willing to hold your notes to maturity.
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·
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NO VOTING RIGHTS OR DIVIDEND PAYMENTS — As a holder of the notes, you will not have voting rights or rights to receive cash dividends or other distributions or other rights with respect to the stocks that comprise the Basket Components.
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·
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NO INTEREST PAYMENTS — As a holder of the notes, you will not receive interest payments.
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RISKS ASSOCIATED WITH INVESTMENTS IN SECURITIES INDEXED TO THE VALUE OF FOREIGN EQUITY SECURITIES — Investments in securities indexed to the value of foreign equity securities, such as the securities composing the Hang Seng China Enterprises Index, the KOSPI 200 Index, the MSCI Taiwan Index, the Hang Seng® Index and the MSCI Singapore Index, involve risks associated with the securities markets in those countries, including the risk of volatility in those markets, governmental intervention in those markets and cross-shareholdings in companies in certain countries. Foreign companies are subject to accounting, auditing and financial reporting standards and requirements different from those applicable to U.S. reporting companies.
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LACK OF LIQUIDITY — The notes will not be listed on any securities exchange. Credit Suisse (or its affiliates) intends to offer to purchase the notes in the secondary market but is not required to do so. Even if there is a secondary market, it may not provide enough liquidity to allow you to trade or sell the notes when you wish to do so. Because other dealers are not likely to make a secondary market for the notes, the price at which you may be able to trade your notes is likely to depend on the price, if any, at which Credit Suisse (or its affiliates) is willing to buy the notes. If you have to sell your notes prior to maturity, you may not be able to do so or you may have to sell them at a substantial loss.
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POTENTIAL CONFLICTS — We and our affiliates play a variety of roles in connection with the issuance of the notes, including acting as calculation agent and hedging our obligations under the notes. In performing these duties, the economic interests of the calculation agent and other affiliates of ours are potentially adverse to your interests as an investor in the notes.
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MANY ECONOMIC AND MARKET FACTORS WILL AFFECT THE VALUE OF THE NOTES — In addition to the levels of the Basket Components and the exchange rates of the Basket Currencies with respect to the U.S. dollar on any day, the value of the notes will be affected by a number of economic and market factors that may either offset or magnify each other, including:
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the expected volatility of the Basket Components;
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the time to maturity of the notes;
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the dividend rates on the stocks comprising the Basket Components;
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interest and yield rates in the market generally;
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geopolitical conditions and a variety of economic, financial, political, regulatory or judicial events that affect the components comprising the Basket Components or markets generally;
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the exchange rate and volatility of the exchange rate between the U.S. dollar, the Hong Kong dollar, the Korean won, the new Taiwan dollar and the Singapore dollar; and
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our creditworthiness, including actual or anticipated downgrades in our credit ratings.
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a financial institution,
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a mutual fund,
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a tax-exempt organization,
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a grantor trust,
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certain U.S. expatriates,
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an insurance company,
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a dealer or trader in securities or foreign currencies,
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a person (including traders in securities) using a mark-to-market method of accounting,
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a person who holds securities as a hedge or as part of a straddle with another position, constructive sale,conversion transaction or other integrated transaction, or
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an entity that is treated as a partnership for U.S. federal income tax purposes.
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