UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
FORM 8-K
CURRENT REPORT
Pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934
| Date of Report (Date of Earliest Event Reported): | January 15, 2016 |
Federal Home Loan Bank of Topeka
__________________________________________
(Exact name of registrant as specified in its charter)
| Federally Chartered Corporation | 000-52004 | 48-0561319 |
|
_____________________ (State or other jurisdiction |
_____________ (Commission |
______________ (I.R.S. Employer |
| of incorporation) | File Number) | Identification No.) |
| One Security Benefit Pl. Suite 100, Topeka, Kansas | 66606 | |
|
_________________________________ (Address of principal executive offices) |
___________ (Zip Code) |
| Registrant’s telephone number, including area code: | 785.233.0507 |
Not Applicable
______________________________________________
Former name or former address, if changed since last report
Check the appropriate box below if the Form 8-K filing is intended to simultaneously satisfy the filing obligation of the registrant under any of the following provisions:
[ ] Written communications pursuant to Rule 425 under the Securities Act (17 CFR 230.425)
[ ] Soliciting material pursuant to Rule 14a-12 under the Exchange Act (17 CFR 240.14a-12)
[ ] Pre-commencement communications pursuant to Rule 14d-2(b) under the Exchange Act (17 CFR 240.14d-2(b))
[ ] Pre-commencement communications pursuant to Rule 13e-4(c) under the Exchange Act (17 CFR 240.13e-4(c))
Item 5.02 Departure of Directors or Certain Officers; Election of Directors; Appointment of Certain Officers; Compensatory Arrangements of Certain Officers.
2014 and 2015 Executive Incentive Compensation Plan Targets
On December 18, 2015, the Board of Directors (Board) of the Federal Home Loan Bank of Topeka (FHLBank) adopted revisions to FHLBank’s 2014 and 2015 Executive Incentive Compensation Plan (EICP) Targets. Before becoming effective, the FHLBank must first receive notification from the Federal Housing Finance Agency of non-objection for the revisions to the EICP Targets, which was received on January 15, 2016. The EICP is a cash-based annual incentive plan with a long-term deferral component that establishes individual incentive compensation award opportunities related to achievement of performance objectives by FHLBank during each performance period as defined in the EICP and set forth in each EICP Targets document.
The amendments to the 2014 and 2015 EICP Targets documents include four key changes to the long-term Deferral Performance Period Metrics, and apply to the 2015-2017 Deferral Performance Period under the 2014 EICP Targets and the 2016-2018 Deferral Performance Period for the 2015 EICP Targets. First, the revisions approved by FHLBank’s Board take into account the recently completed merger of the FHLBanks of Seattle and Des Moines by changing the denominator for each of the Threshold, Target and Optimum metrics to reflect FHLBank is measured against 11 total FHLBanks, and changing the Target for each of the metrics from 6/12 FHLBanks to 5/11 FHLBanks. Second, the revisions approved by FHLBank’s Board revise the long-term performance metrics to reflect FHLBank’s focus on Total Regulatory Capital. This change included revising the calculation of the Total Return metric by replacing Average Capital with Total Regulatory Capital in the denominator and revising the Market Value of Equity ratio by replacing Total Regulatory Capital Stock with Total Regulatory Capital in the denominator. Third, FHLBank’s Board revised the threshold achievement level for each of the metrics by providing that if FHLBank’s performance is 10/11 or 11/11 compared to the other FHLBanks, Participants in the EICP would receive 75 percent of their Final Deferred Incentive Award for that metric. Finally, FHLBank’s Board established a Minimum Requirement for Receiving a Final Deferred Incentive Award that requires FHLBank to have a Market Value of Equity of not less than 100 percent of Total Regulatory Capital Stock outstanding, as of the last day of the Deferral Performance Period, in order for Participants to be eligible to receive a Final Deferred Incentive Award.
Total awards payable under the 2014 and 2015 EICP Targets are not determinable at this time.
A copy of the 2014 and 2015 EICP Targets are attached hereto as Exhibits 10.1 and 10.2, respectively, and are incorporated herein by reference.
A description of the EICP and other compensation and benefits provided or made available to FHLBank’s Named Executive Officers may be found in "Item 11 – Executive Compensation" of FHLBank’s Annual Report on Form 10-K filed with the SEC on March 13, 2015.
Item 9.01 Financial Statements and Exhibits.
(d) Exhibits
10.1 2014 Executive Incentive Compensation Plan Targets, revised December 18, 2015.
10.2 2015 Executive Incentive Compensation Plan Targets, revised December 18, 2015.
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.
| Federal Home Loan Bank of Topeka | ||||
| January 21, 2016 | By: |
/s/ Patrick C. Doran
|
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|
|
||||
| Name: Patrick C. Doran | ||||
| Title: SVP, General Counsel | ||||
Exhibit Index
| Exhibit No. | Description | |
|
|
|
|
|
10.1
|
2014 Executive Incentive Compensation Plan Targets, revised December 18, 2015. | |
|
10.2
|
2015 Executive Incentive Compensation Plan Targets, revised December 18, 2015. |
December 20, 2013
Revised December 18, 2015
Federal Home Loan Bank of Topeka
Executive Incentive Compensation Plan Targets
Goal Metrics, Metric Performance Ranges, Participant Eligibility and Metric Weights
This document specifies goal metrics, metric performance ranges/objectives, and metric weights for the participants (Participants) in the Executive Incentive Compensation Plan (Plan).
The Plan targets contained in this document specifically cover the 2014 Base Performance Period (January 1, 2014 through December 31, 2014) and the 2015 — 2017 Deferral Performance Period (January 1, 2015 through December 31, 2017).
| A. | 2014 Base Performance Period Metrics. The following goal metrics are assigned to the Participants under the Plan. All calculations including interest rates will be rounded to two decimal places. |
| 1. | Adjusted Return Spread on Regulatory Total Capital |
Definition: The spread between (a) adjusted net income divided by daily average regulatory total capital and (b) the average daily Overnight Federal funds effective rate (Fed Effective).
Measure:
|
||
| |
||
| Adjusted net income is defined as follows: |
||
| • | Net income calculated under generally accepted accounting principles (GAAP) |
| • | Plus recorded AHP assessments |
| • | Excluding the impact or adjustment required because of Accounting Standards Codification 815 (ASC 815) |
| • | Plus dividends on redeemable Class A and Class B Common Stock treated as interest expense under ASC 450 |
| • | Minus prepayment fees |
| • | Minus/plus realized or unrealized gains/losses on securities (excludes any charges for other-than-temporary impairment of securities) |
| • | Minus/plus gains/losses on mortgage loans held for sale |
| • | Minus/plus gains/losses on early retirement of debt and related derivatives |
| • | Minus/plus any amortization/accretion of premium/discount on unswapped mortgage-backed securities in the FHLBank’s trading portfolio (not amortized/accreted under GAAP) |
| • | Less a calculated 10% AHP assessment |
Performance Range:
| Annual Performance Range | ||||
Threshold |
4.73 | % | ||
Target |
6.02 | % | ||
Optimum |
7.30 | % | ||
| 2. | Net Income after Capital Charge |
Definition: The dollar amount of adjusted net income as defined in the above metric which exceeds the cost of the required return on capital.
Measure: Adjusted income as defined in the Net Income after Capital Charge Definition above, less required return on all capital. The required return on capital is the sum of the outstanding regulatory Class B Common Stock times the average of three-month LIBOR plus 1.00 percent for each day during the year plus the sum of all other capital (regulatory for Class A Common Stock and GAAP for retained earnings and other comprehensive income) times the average of three-month LIBOR for each day during the year.
Performance Range:
| Annual Performance Range | ||||
Threshold |
$ | 80,208,963 | ||
Target |
$ | 105,208,963 | ||
Optimum |
$ | 130,208,963 | ||
| 3. | Retained Earnings |
Definition: The dollar amount of GAAP Retained Earnings as of 12/31/2014.
Measure: Retained earnings as defined above as reported on the 12/31/2014 balance sheet.
Performance Ranges:
| Annual Performance Range | ||||
Threshold |
$ | 617,202,106 | ||
Target |
$ | 646,572,966 | ||
Optimum |
$ | 675,943,826 | ||
| 4. | Core Mission Assets (CMA) Ratio |
Definition: Core Mission Assets Ratio is defined as daily advances divided by daily consolidated obligations.
Measure: Average Daily Advances as reported to the Federal Housing Finance Agency (CRS reference SC11800) divided by the average daily consolidated obligations as reported to the Federal Housing Finance Agency (CRS reference SC15100) averaged over the Performance Period.
Performance Range:
| Annual Performance Range | ||||
Threshold |
57.40 | % | ||
Target |
59.40 | % | ||
Optimum |
61.40 | % | ||
| 5. | Risk Management – Market, Credit and Liquidity Risks |
Definition: Management of FHLBank risks as determined by the weighted average rating by the board of directors in an annual evaluation of the Risk Appetite metrics in this area using a 1 (lowest) to 5 (highest) point scale. General risk categories are market, credit, and liquidity risks.
Performance Ranges
| Score | ||||
Threshold |
3.0 | |||
Target |
4.0 | |||
Optimum |
5.0 | |||
Risk Management Metric Weights: The following metric weight for each goal metric is assigned to the Participants:
| Risk Management Category | Weighting | |||
Liquidity Risk
|
30 | % | ||
Market Risk
|
40 | % | ||
Credit Risk
|
30 | % | ||
Total
|
100 | % | ||
| 6. | Risk Management – Compliance, Business and Operations Risks |
Definition: Management of FHLBank risks as determined by the weighted average rating by the board of directors in an annual evaluation of the Risk Appetite metrics in this area using a 1 (lowest) to 5 (highest) point scale. General risk categories are compliance, business and operations risks.
Performance Ranges
| Score | ||||
Threshold |
3.0 | |||
Target |
4.0 | |||
Optimum |
5.0 | |||
Risk Management Metric Weights: The following metric weight for each goal metric is assigned to the Participants:
| Risk Management Category | Weighting | |||
Compliance Risk
|
30 | % | ||
Business Risk
|
35 | % | ||
Operations Risk
|
35 | % | ||
Total
|
100 | % | ||
| B. | 2015-2017 Deferral Performance Period Metrics. |
These metrics apply to the 2015-2017 Deferral Performance Period.
Minimum Requirement for Receiving a Final Deferred Incentive Award
In order for Participants to be eligible to receive a Final Deferred Incentive Award for the
2015-2017 Deferral Performance Period, FHLBank must have a Market Value of Equity (MVE) of not
less than 100 percent of FHLBank’s Total Regulatory Capital Stock (TRCS) outstanding (as
defined in FHLBank’s Risk Management Policy), as of the last day of the Deferral Performance
Period. Upon determining FHLBank has achieved this minimum requirement, the calculation of the
Final Deferred Incentive Award amounts shall be measured by evaluating the following:
| Threshold | Target | Optimum | ||||||||||
| 10/11 or 11/11 vs | 2/11 or 1/11 vs | |||||||||||
Total Return(1) |
FHLBanks | 5/11 vs FHLBanks | FHLBanks | |||||||||
Deferred Incentive |
||||||||||||
Performance Measure Percentage |
75 | % | 100 | % | 125 | % | ||||||
Weighting |
0.50 | 0.50 | 0.50 | |||||||||
Dollar Value (Deferred
Incentive x Performance
Measure Percentage x Weight) |
$ | $ | $ | |||||||||
MVE / Total Regulatory |
10/11 or 11/11 vs | 2/11 or 1/11 | ||||||||||
Capital (TRC)(2) |
FHLBanks | 5/11 vs FHLBanks | vs FHLBanks | |||||||||
Deferred Incentive |
||||||||||||
Performance Measure Percentage |
75 | % | 100 | % | 125 | % | ||||||
Weighting |
0.50 | 0.50 | 0.50 | |||||||||
Dollar Value (Deferred
Incentive x Performance
Measure Percentage x Weight) |
$ | $ | $ | |||||||||
Final Deferred Incentive
Award (Dollar value for Total
Return + Dollar Value for
MVE/TRC) |
||||||||||||
Footnotes:
1) Total Return. Total Return equals the Total Dividends, plus the Change in
Retained Earnings, divided by the Average Total Regulatory Capital (TRC) over the three-year
period. Total Dividends is defined as all dividends paid on all capital stock during the
three-year period; Change in Retained Earnings is defined as the change in retained earnings
from 12/31/2014 to 12/31/2017; and Average TRC is defined as the average daily ending balance
of Regulatory Capital for dates starting with 01/01/2015 and ending 12/31/2017. TRC is defined
as total capital stock plus total retained earnings plus subordinated debt plus mandatorily
redeemable capital stock. TRC will also include any additional capital from mergers that will
be reported in the CRS statement of condition. For performance comparison purposes, FHLBank
Topeka will be ranked against the other FHLBanks, with the highest total return being the best
performance, and ranking 1st out of the 11 FHLBanks.
2) MVE/TRC. Using amounts reported on the Trendbook Analysis from the FHFA Call Report System (CRS), MVE/TRC is calculated by dividing base case MVE by TRC (as defined above) calculated at the end of the Deferral Performance Period. For performance comparison purposes, FHLBank Topeka will be ranked against the other FHLBanks, with the highest MVE/TRC being the best performance, and ranking 1st out of the 11 FHLBanks.
| C. | Total Base Opportunity Metric Weights. |
Total Base Opportunity Matrix
(As a percent of base)
| Participant | Total Base Opportunity | |||||||||||
| Thresh | Target | Optimum | ||||||||||
Level 1 |
||||||||||||
CEO |
40 | 80 | 120 | |||||||||
Level 2 |
||||||||||||
COO |
32.5 | 65 | 97.5 | |||||||||
Level 3 |
||||||||||||
CRO |
25 | 50 | 75 | |||||||||
General Counsel |
25 | 50 | 75 | |||||||||
CFO |
25 | 50 | 75 | |||||||||
1 In the event FHLBank’s performance during the Base Performance Period results in the achievement of a Total Base Opportunity that exceeds 100% of a Participant’s base salary at the start of the Base Performance Period, the Total Base Opportunity shall be capped at 100% of the Participant’s base salary.
D. Base Opportunity Metric Weights. The following metric weight for each goal metric is assigned to the Participants:
| Objective | CEO/COO/CFO | CRO | General Counsel | |||||||||
1. Adjusted Return Spread on Regulatory Total Capital |
20% |
10% |
15% |
|||||||||
2. Net Income after Capital Charge
|
20 | % | 10 | % | 15 | % | ||||||
3. Retained Earnings
|
10 | % | 20 | % | 10 | % | ||||||
4. Core Mission Assets (CMA) Ratio
|
10 | % | 10 | % | 10 | % | ||||||
5. Risk Management- Market, Credit,Liquidity |
20% |
25% |
25% |
|||||||||
6. Risk Management- Compliance, Business, Operations |
20% |
25% |
25% |
|||||||||
Total
|
100 | % | 100 | % | 100 | % | ||||||
Revised December 18, 2015
Federal Home Loan Bank of Topeka
Executive Incentive Compensation Plan Targets
Goal Metrics, Metric Performance Ranges, Participant Eligibility and Metric Weights
This document specifies goal metrics, metric performance ranges/objectives, and metric weights for the participants (Participants) in the Executive Incentive Compensation Plan (Plan).
The Plan targets contained in this document specifically cover the 2015 Base Performance Period (January 1, 2015 through December 31, 2015) and the 2016 — 2018 Deferral Performance Period (January 1, 2016 through December 31, 2018).
| A. | 2015 Base Performance Period Metrics. The following goal metrics are assigned to the Participants under the Plan. All calculations including interest rates will be rounded to two decimal places. |
| 1. | Adjusted Return Spread on Regulatory Total Capital |
Definition: The spread between (a) adjusted net income divided by daily average regulatory total capital and (b) the average daily Overnight Federal funds effective rate (Fed Effective).
Measure:
|
||
| |
||
| Adjusted net income is defined as follows: |
||
| • | Net income calculated under generally accepted accounting principles (GAAP) |
| • | Plus recorded AHP assessments |
| • | Excluding the impact or adjustment required because of Accounting Standards Codification 815 (ASC 815) |
| • | Plus dividends on redeemable Class A and Class B Common Stock treated as interest expense under ASC 450 |
| • | Minus prepayment fees |
| • | Minus/plus realized or unrealized gains/losses on securities (excludes any charges for other-than-temporary impairment of securities) |
| • | Minus/plus gains/losses on mortgage loans held for sale |
| • | Minus/plus gains/losses on early retirement of debt and related derivatives |
| • | Minus/plus any amortization/accretion of premium/discount on unswapped securities in the FHLBank’s trading portfolio and any investment that is tied to an economic swap where an upfront fee was not received (not amortized/accreted under GAAP) |
| • | Less a calculated 10% AHP assessment |
Performance Range:
| Annual Performance Range | ||||
Threshold |
4.72 | % | ||
Target |
5.85 | % | ||
Optimum |
6.42 | % | ||
| 2. | Net Income after Capital Charge |
Definition: The dollar amount of adjusted net income as defined in the above metric which exceeds the cost of the required return on capital.
Measure: Adjusted income as defined in the Net Income after Capital Charge Definition above, less required return on all capital. The required return on capital is the sum of the outstanding regulatory Class B Common Stock times the average of three-month LIBOR plus 1.00 percent for each day during the year plus the sum of all other capital (regulatory for Class A Common Stock and GAAP for retained earnings and other comprehensive income) times the average of three-month LIBOR for each day during the year.
Performance Range:
| Annual Performance Range | ||||
Threshold |
$ | 71,477,000 | ||
Target |
$ | 91,477,000 | ||
Optimum |
$ | 101,477,000 | ||
| 3. | Retained Earnings |
Definition: The dollar amount of GAAP Retained Earnings as of 12/31/2015.
Measure: Retained earnings as defined above as reported on the 12/31/2015 balance sheet.
Performance Ranges:
| Annual Performance Range | ||||
Threshold |
$ | 655,263,000 | ||
Target |
$ | 681,920,000 | ||
Optimum |
$ | 702,007,000 | ||
| 4. | Core Mission Assets (CMA) Ratio |
Definition: Core Mission Assets Ratio is defined as daily advances plus mortgage loans held for portfolio divided by daily consolidated obligations.
Measure: Average Daily Advances as reported to the Federal Housing Finance Agency (CRS reference SC11800) plus Daily Average mortgage loans held for portfolio (CRS reference SC12100) divided by the average daily consolidated obligations as reported to the Federal Housing Finance Agency (CRS reference SC15100) averaged over the Performance Period.
Performance Range:
| Annual Performance Range | ||||
Threshold |
60 | % | ||
Target |
70 | % | ||
Optimum |
80 | % | ||
| 5. | Risk Management – Market, Credit and Liquidity Risks |
Definition: Management of FHLBank risks as determined by the weighted average rating by the board of directors in an annual evaluation of the Risk Appetite metrics in this area using a 1 (lowest) to 5 (highest) point scale. General risk categories are market, credit and liquidity risks.
Performance Ranges
| Score | ||||
Threshold |
3.0 | |||
Target |
4.0 | |||
Optimum |
5.0 | |||
Risk Management Metric Weights: The following metric weight for each goal metric is assigned to the Participants:
| Risk Management Category | Weighting | |||
Liquidity Risk
|
30 | % | ||
Market Risk
|
40 | % | ||
Credit Risk
|
30 | % | ||
Total
|
100 | % | ||
| 6. | Risk Management – Compliance, Business and Operations Risks |
Definition: Management of FHLBank risks as determined by the weighted average rating by the board of directors in an annual evaluation of the Risk Appetite metrics in this area using a 1 (lowest) to 5 (highest) point scale. General risk categories are compliance, business and operations risks.
Performance Ranges
| Score | ||||
Threshold |
3.0 | |||
Target |
4.0 | |||
Optimum |
5.0 | |||
Risk Management Metric Weights: The following metric weight for each goal metric is assigned to the Participants:
| Risk Management Category | Weighting | |||
Compliance Risk
|
30 | % | ||
Business Risk
|
35 | % | ||
Operations Risk
|
35 | % | ||
Total
|
100 | % | ||
| B. | 2016-2018 Deferral Performance Period Metrics. |
These metrics apply to the 2016-2018 Deferral Performance Period.
Minimum Requirement for Receiving a Final Deferred Incentive Award
In order for Participants to be eligible to receive a Final Deferred Incentive Award for the
2016-2018 Deferral Performance Period, FHLBank must have a Market Value of Equity (MVE) of not
less than 100 percent of FHLBank’s Total Regulatory Capital Stock (TRCS) outstanding (as
defined in FHLBank’s Risk Management Policy), as of the last day of the Deferral Performance
Period. Upon determining FHLBank has achieved this minimum requirement, the calculation of the
Final Deferred Incentive Award amounts shall be measured by evaluating the following:
| Threshold | Target | Optimum | ||||||||||
| 10/11 or 11/11 vs | 2/11 or 1/11 vs | |||||||||||
Total Return(1) |
FHLBanks | 5/11 vs FHLBanks | FHLBanks | |||||||||
Deferred Incentive |
||||||||||||
Performance Measure Percentage |
75 | % | 100 | % | 125 | % | ||||||
Weighting |
0.50 | 0.50 | 0.50 | |||||||||
Dollar Value (Deferred
Incentive x Performance
Measure Percentage x Weight) |
$ | $ | $ | |||||||||
MVE / Total Regulatory |
10/11 or 11/11 vs | 2/11 or 1/11 | ||||||||||
Capital (TRC)(2) |
FHLBanks | 5/11 vs FHLBanks | vs FHLBanks | |||||||||
Deferred Incentive |
||||||||||||
Performance Measure Percentage |
75 | % | 100 | % | 125 | % | ||||||
Weighting |
0.50 | 0.50 | 0.50 | |||||||||
Dollar Value (Deferred
Incentive x Performance
Measure Percentage x Weight) |
$ | $ | $ | |||||||||
Final Deferred Incentive
Award (Dollar value for Total
Return + Dollar Value for
MVE/TRC) |
||||||||||||
Footnotes:
1) Total Return. Total Return equals the Total Dividends, plus the Change in Retained
Earnings, divided by the Average Total Regulatory Capital (TRC) over the three-year period. Total
Dividends is defined as all dividends paid on all capital stock during the three-year period;
Change in Retained Earnings is defined as the change in retained earnings from 12/31/2015 to
12/31/2018; and Average TRC is defined as the average daily ending balance of Regulatory Capital
for dates starting with 01/01/2016 and ending 12/31/2018. TRC is defined as total capital stock
plus total retained earnings plus subordinated debt plus mandatorily redeemable capital stock.
TRC will also include any additional capital from mergers that will be reported in the CRS
statement of condition. For performance comparison purposes, FHLBank Topeka will be ranked
against the other FHLBanks, with the highest total return being the best performance, and ranking
1st out of the 11 FHLBanks.
2) MVE/TRC. Using amounts reported on the Trendbook Analysis from the FHFA Call Report System (CRS), MVE/TRC is calculated by dividing base case MVE by TRC (as defined above) calculated at the end of the Deferral Performance Period. For performance comparison purposes, FHLBank Topeka will be ranked against the other FHLBanks, with the highest MVE/TRC being the best performance, and ranking 1st out of the 11 FHLBanks.
| C. | Total Base Opportunity Metric Weights. |
Total Base Opportunity Matrix
(As a percent of base)
| Participant | Total Base Opportunity 1 | |||||||||||
| Threshold | Target | Optimum | ||||||||||
Level 1 |
||||||||||||
CEO |
40 | 80 | 120 | |||||||||
Level 2 |
||||||||||||
COO |
32.5 | 65 | 97.5 | |||||||||
Level 3 |
||||||||||||
CRO |
25 | 50 | 75 | |||||||||
General Counsel |
25 | 50 | 75 | |||||||||
CFO |
25 | 50 | 75 | |||||||||
| 1 | In the event FHLBank’s performance during the Base Performance Period results in the achievement of a Total Base Opportunity that exceeds 100% of a Participant’s base salary at the start of the Base Performance Period, the Total Base Opportunity shall be capped at 100% of the Participant’s base salary. |
| D. | Base Opportunity Metric Weights. The following metric weight for each goal metric is assigned to the Participants: |
| Objective | CEO/COO/CFO | CRO | General Counsel | |||||||||
1. Adjusted Return Spread on Regulatory Total Capital |
20% |
10% |
15% |
|||||||||
2. Net Income after Capital Charge
|
20 | % | 10 | % | 15 | % | ||||||
3. Retained Earnings
|
10 | % | 20 | % | 10 | % | ||||||
4. Core Mission Assets (CMA) Ratio
|
10 | % | 10 | % | 10 | % | ||||||
5.Risk Management — Market, Credit, Liquidity |
20% |
25% |
25% |
|||||||||
6.Risk Management — Compliance, Business, Operations |
20% |
25% |
25% |
|||||||||
Total
|
100 | % | 100 | % | 100 | % | ||||||