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Fair Values of Assets and Liabilities

3 Months Ended

Mar. 31, 2019

Fair values of assets and liabilities [Text Block]

Fair Values of Assets and Liabilities

GAAP defines fair value as the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date; that is, an exit price. The exit price assumes the asset or liability is not exchanged subject to a forced liquidation or distressed sale.

Valuation Hierarchy

The Company categorizes its fair value measurements according to a three-level hierarchy. The hierarchy prioritizes the inputs used by the Company’s valuation techniques. A level is assigned to each fair value measurement based on the lowest level input that is significant to the fair value measurement in its entirety. The three levels of the fair value hierarchy are defined as follows:

Level 1 Unadjusted quoted prices for identical assets or liabilities in active markets that are accessible at the measurement date.

Level 2 Prices or valuations based on observable inputs other than quoted prices in active markets for identical assets and liabilities.

Level 3 Prices or valuations that require inputs that are both significant to the fair value measurement and unobservable.

The following tables present the balances of assets and liabilities of Ameriprise Financial measured at fair value on a recurring basis:



	March 31, 2019
	Level 1		Level 2		Level 3		Total
	(in millions)
Assets
Cash equivalents	$	199	$	2,656	$	—	$	2,855
Available-for-Sale securities:
Corporate debt securities	—		12,091		847		12,938
Residential mortgage backed securities	—		6,264		37		6,301
Commercial mortgage backed securities	—		4,801		—		4,801
Asset backed securities	—		1,297		6		1,303
State and municipal obligations	—		1,424		—		1,424
U.S. government and agency obligations	1,710		—		—		1,710
Foreign government bonds and obligations	—		287		—		287
Total Available-for-Sale securities	1,710		26,164		890		28,764
Equity securities	—		1		—		1
Equity securities at net asset value (“NAV”)							6		⁽¹⁾
Trading securities	11		44		—		55
Separate account assets at NAV							83,571		⁽¹⁾
Investments and cash equivalents segregated for regulatory purposes	232		—		—		232
Other assets:
Interest rate derivative contracts	3		933		—		936
Equity derivative contracts	84		1,941		—		2,025
Foreign exchange derivative contracts	5		46		—		51
Total other assets	92		2,920		—		3,012
Total assets at fair value	$	2,244	$	31,785	$	890	$	118,496



Liabilities
Policyholder account balances, future policy benefits and claims:
Indexed annuity embedded derivatives	$	—	$	3	$	23	$	26
IUL embedded derivatives	—		—		745		745
GMWB and GMAB embedded derivatives	—		—		180		180		⁽²⁾
Total policyholder account balances, future policy benefits and claims	—		3		948		951		⁽³⁾
Customer deposits	—		13		—		13
Other liabilities:
Interest rate derivative contracts	—		366		—		366
Equity derivative contracts	34		2,591		—		2,625
Credit derivative contracts	—		21		—		21
Foreign exchange derivative contracts	1		32		—		33
Other	10		7		31		48
Total other liabilities	45		3,017		31		3,093
Total liabilities at fair value	$	45	$	3,033	$	979	$	4,057



	December 31, 2018
	Level 1		Level 2		Level 3		Total
	(in millions)
Assets
Cash equivalents	$	155	$	2,350	$	—	$	2,505
Available-for-Sale securities:
Corporate debt securities	—		13,153		913		14,066
Residential mortgage backed securities	—		6,193		136		6,329
Commercial mortgage backed securities	—		4,857		20		4,877
Asset backed securities	—		1,392		6		1,398
State and municipal obligations	—		2,345		—		2,345
U.S. government and agency obligations	1,745		—		—		1,745
Foreign government bonds and obligations	—		298		—		298
Total Available-for-Sale securities	1,745		28,238		1,075		31,058
Equity securities	—		1		—		1
Equity securities at NAV							6		⁽¹⁾
Trading securities	36		38		—		74
Separate account assets at NAV							77,925		⁽¹⁾
Investments and cash equivalents segregated for regulatory purposes	301		—		—		301
Other assets:
Interest rate derivative contracts	—		796		—		796
Equity derivative contracts	191		1,527		—		1,718
Foreign exchange derivative contracts	5		55		—		60
Total other assets	196		2,378		—		2,574
Total assets at fair value	$	2,433	$	33,005	$	1,075	$	114,444



Liabilities
Policyholder account balances, future policy benefits and claims:
Indexed annuity embedded derivatives	$	—	$	3	$	14	$	17
IUL embedded derivatives	—		—		628		628
GMWB and GMAB embedded derivatives	—		—		328		328		⁽⁴⁾
Total policyholder account balances, future policy benefits and claims	—		3		970		973		⁽⁵⁾
Customer deposits	—		6		—		6
Other liabilities:
Interest rate derivative contracts	—		424		—		424
Equity derivative contracts	78		2,076		—		2,154
Credit derivative contracts	—		18		—		18
Foreign exchange derivative contracts	4		31		—		35
Other	13		6		30		49
Total other liabilities	95		2,555		30		2,680
Total liabilities at fair value	$	95	$	2,564	$	1,000	$	3,659

⁽¹⁾ Amounts are comprised of certain financial instruments that are measured at fair value using the NAV per share (or its equivalent) as a practical expedient and have not been classified in the fair value hierarchy.

⁽²⁾ The fair value of the GMWB and GMAB embedded derivatives included $557 million of individual contracts in a liability position and $377 million of individual contracts in an asset position as of March 31, 2019.


⁽³⁾	The Company’s adjustment for nonperformance risk resulted in a $(536) million cumulative increase (decrease) to the embedded derivatives as of March 31, 2019.


⁽⁴⁾	The fair value of the GMWB and GMAB embedded derivatives included $646 million of individual contracts in a liability position and $318 million of individual contracts in an asset position as of December 31, 2018.


⁽⁵⁾	The Company’s adjustment for nonperformance risk resulted in a $(726) million cumulative increase (decrease) to the embedded derivatives as of December 31, 2018.

The following tables provide a summary of changes in Level 3 assets and liabilities of Ameriprise Financial measured at fair value on a recurring basis:



	Available-for-Sale Securities
	Corporate Debt Securities				Residential Mortgage Backed Securities				Commercial Mortgage Backed Securities				Asset Backed Securities			Total
	(in millions)
Balance, January 1, 2019	$	913			$	136			$	20			$	6		$	1,075
Total gains (losses) included in:
Other comprehensive income	15				—				—				—			15
Settlements	(81		)		(4		)		—				—			(85		)
Transfers out of Level 3	—				(95		)		(20		)		—			(115		)
Balance, March 31, 2019	$	847			$	37			$	—			$	6		$	890

Changes in unrealized gains (losses) relating to assets held at March 31, 2019	$	—			$	—			$	—			$	—		$	—

	Policyholder Account Balances, Future Policy Benefits and Claims															Other Liabilities
	Indexed Annuity Embedded Derivatives				IUL Embedded Derivatives				GMWB and GMAB Embedded Derivatives				Total			Other Liabilities
	(in millions)
Balance, January 1, 2019	$	14			$	628			$	328			$	970		$	30
Total (gains) losses included in:
Net income	2			⁽¹⁾	98			⁽¹⁾	(230		)	⁽²⁾	(130		)	1			⁽³⁾
Issues	7				36				84				127			—
Settlements	—				(17		)		(2		)		(19		)	—
Balance, March 31, 2019	$	23			$	745			$	180			$	948		$	31

Changes in unrealized (gains) losses relating to liabilities held at March 31, 2019	$	—			$	98		⁽¹⁾	$	(230	)	⁽²⁾	$	(132	)	$	—

					Available-for-Sale Securities
					Corporate Debt Securities				Residential Mortgage Backed Securities				Asset Backed Securities			Total
					(in millions)
Balance, January 1, 2018					$	1,139			$	155			$	7		$	1,301
Total gains (losses) included in:
Net income					(1		)		—				—			(1		)	⁽⁴⁾
Other comprehensive loss					(14		)		(2		)		—			(16		)
Purchases					—				—				10			10
Settlements					(29		)		(7		)		—			(36		)
Balance, March 31, 2018					$	1,095			$	146			$	17		$	1,258

Changes in unrealized gains (losses) relating to assets held at March 31, 2018					$	(1	)		$	—			$	—		$	(1	)	⁽⁴⁾



	Policyholder Account Balances, Future Policy Benefits and Claims													Other Liabilities
	Indexed Annuity Embedded Derivatives		IUL Embedded Derivatives				GMWB and GMAB Embedded Derivatives				Total			Other Liabilities
	(in millions)
Balance, January 1, 2018	$	—	$	601			$	(49	)		$	552		$	28
Total (gains) losses included in:
Net income	—		(25		)	⁽¹⁾	(356		)	⁽²⁾	(381		)	—
Issues	3		20				83				106			—
Settlements	—		(11		)		(7		)		(18		)	—
Balance, March 31, 2018	$	3	$	585			$	(329	)		$	259		$	28

Changes in unrealized (gains) losses relating to liabilities held at March 31, 2018	$	—	$	(25	)	⁽¹⁾	$	(348	)	⁽²⁾	$	(373	)	$	—

⁽¹⁾ Included in interest credited to fixed accounts in the Consolidated Statements of Operations.

⁽²⁾ Included in benefits, claims, losses and settlement expenses in the Consolidated Statements of Operations.

⁽³⁾ Included in general and administrative expense in the Consolidated Statements of Operations.

⁽⁴⁾ Included in net investment income in the Consolidated Statements of Operations.

The increase (decrease) to pretax income of the Company’s adjustment for nonperformance risk on the fair value of its embedded derivatives was $(158) million and $33 million, net of DAC, DSIC, unearned revenue amortization and the reinsurance accrual, for the three months ended March 31, 2019 and 2018, respectively.

Securities transferred from Level 3 primarily represent securities with fair values that are now obtained from a third-party pricing service with observable inputs.

The following tables provide a summary of the significant unobservable inputs used in the fair value measurements developed by the Company or reasonably available to the Company of Level 3 assets and liabilities:



	March 31, 2019
	Fair Value		Valuation Technique	Unobservable Input	Range				Weighted Average
	(in millions)
Corporate debt securities (private placements)	$	846	Discounted cash flow	Yield/spread to U.S. Treasuries	0.8	%	–	2.8%	1.3	%
Asset backed securities	$	6	Discounted cash flow	Annual short-term default rate	2.8%
				Annual long-term default rate	2.5%
				Discount rate	11.5%
				Constant prepayment rate	5.0	%	–	10.0%	10.0	%
				Loss recovery	36.4	%	–	63.6%	63.6	%
IUL embedded derivatives	$	745	Discounted cash flow	Nonperformance risk ⁽¹⁾	85 bps
Indexed annuity embedded derivatives	$	23	Discounted cash flow	Surrender rate	0.0	%	–	50.0%
				Nonperformance risk ⁽¹⁾	85 bps
GMWB and GMAB embedded derivatives	$	180	Discounted cash flow	Utilization of guaranteed withdrawals ⁽²⁾	0.0	%	–	36.0%
				Surrender rate	0.1	%	–	73.4%
				Market volatility ⁽³⁾	3.9	%	–	15.4%
				Nonperformance risk ⁽¹⁾	85 bps
Contingent consideration liabilities	$	31	Discounted cash flow	Discount rate	9.0%



	December 31, 2018
	Fair Value		Valuation Technique	Unobservable Input	Range				Weighted Average
	(in millions)
Corporate debt securities (private placements)	$	912	Discounted cash flow	Yield/spread to U.S. Treasuries	1.0	%	–	3.6%	1.5	%
Asset backed securities	$	6	Discounted cash flow	Annual short-term default rate	2.3%
				Annual long-term default rate	2.5	%	–	3.0%	2.9	%
				Discount rate	11.5%
				Constant prepayment rate	5.0	%	–	10.0%	10.0	%
				Loss recovery	36.4	%	–	63.6%	63.6	%
IUL embedded derivatives	$	628	Discounted cash flow	Nonperformance risk ⁽¹⁾	119 bps
Indexed annuity embedded derivatives	$	14	Discounted cash flow	Surrender rate	0.0	%	–	50.0%
				Nonperformance risk ⁽¹⁾	119 bps
GMWB and GMAB embedded derivatives	$	328	Discounted cash flow	Utilization of guaranteed withdrawals ⁽²⁾	0.0	%	–	36.0%
				Surrender rate	0.1	%	–	73.4%
				Market volatility ⁽³⁾	4.0	%	–	16.1%
				Nonperformance risk ⁽¹⁾	119 bps
Contingent consideration liabilities	$	30	Discounted cash flow	Discount rate	9.0%


⁽¹⁾	The nonperformance risk is the spread added to the observable interest rates used in the valuation of the embedded derivatives.


⁽²⁾	The utilization of guaranteed withdrawals represents the percentage of contractholders that will begin withdrawing in any given year.


⁽³⁾	Market volatility is implied volatility of fund of funds and managed volatility funds.

Level 3 measurements not included in the table above are obtained from non-binding broker quotes where unobservable inputs utilized in the fair value calculation are not reasonably available to the Company.

Uncertainty of Fair Value Measurements

Significant increases (decreases) in the yield/spread to U.S. Treasuries used in the fair value measurement of Level 3 corporate debt securities in isolation would have resulted in a significantly lower (higher) fair value measurement.

Significant increases (decreases) in the annual default rate and discount rate used in the fair value measurement of Level 3 asset backed securities in isolation, generally, would have resulted in a significantly lower (higher) fair value measurement and significant increases (decreases) in loss recovery in isolation would have resulted in a significantly higher (lower) fair value measurement. Significant increases (decreases) in the constant prepayment rate in isolation would have resulted in a significantly lower (higher) fair value measurement.

Significant increases (decreases) in nonperformance risk used in the fair value measurement of the IUL embedded derivatives in isolation would have resulted in a significantly lower (higher) fair value measurement.

Significant increases (decreases) in nonperformance risk and surrender rate used in the fair value measurement of the indexed annuity embedded derivatives in isolation would have resulted in a significantly lower (higher) liability value.

Significant increases (decreases) in utilization and volatility used in the fair value measurement of the GMWB and GMAB embedded derivatives in isolation would have resulted in a significantly higher (lower) liability value. Significant increases (decreases) in nonperformance risk and surrender rate used in the fair value measurement of the GMWB and GMAB embedded derivatives in isolation would have resulted in a significantly lower (higher) liability value. Utilization of guaranteed withdrawals and surrender rates vary with the type of rider, the duration of the policy, the age of the contractholder, the distribution channel and whether the value of the guaranteed benefit exceeds the contract accumulation value.

Significant increases (decreases) in the discount rate used in the fair value measurement of the contingent consideration liability in isolation would have resulted in a significantly lower (higher) fair value measurement.

Determination of Fair Value

The Company uses valuation techniques consistent with the market and income approaches to measure the fair value of its assets and liabilities. The Company’s market approach uses prices and other relevant information generated by market transactions involving identical or comparable assets or liabilities. The Company’s income approach uses valuation techniques to convert future projected cash flows to a single discounted present value amount. When applying either approach, the Company maximizes the use of observable inputs and minimizes the use of unobservable inputs.

The following is a description of the valuation techniques used to measure fair value and the general classification of these instruments pursuant to the fair value hierarchy.

Assets

Cash Equivalents

Cash equivalents include time deposits and other highly liquid investments with original or remaining maturities at the time of purchase of 90 days or less. Actively traded money market funds are measured at their NAV and classified as Level 1. The Company’s remaining cash equivalents are classified as Level 2 and measured at amortized cost, which is a reasonable estimate of fair value because of the short time between the purchase of the instrument and its expected realization.

Investments (Available-for-Sale Securities, Equity Securities and Trading Securities)

When available, the fair value of securities is based on quoted prices in active markets. If quoted prices are not available, fair values are obtained from third-party pricing services, non-binding broker quotes, or other model-based valuation techniques.

Level 1 securities primarily include U.S. Treasuries.

Level 2 securities primarily include corporate bonds, residential mortgage backed securities, commercial mortgage backed securities, asset backed securities, state and municipal obligations and foreign government securities. The fair value of these Level 2 securities is based on a market approach with prices obtained from third-party pricing services. Observable inputs used to value these securities can include, but are not limited to, reported trades, benchmark yields, issuer spreads and non-binding broker quotes.

Level 3 securities primarily include certain corporate bonds, non-agency residential mortgage backed securities, commercial mortgage backed securities and asset backed securities. The fair value of corporate bonds, non-agency residential mortgage backed securities, commercial mortgage backed securities and certain asset backed securities classified as Level 3 is typically based on a single non-binding broker quote. The underlying inputs used for some of the non-binding broker quotes are not readily available to the Company. The Company’s privately placed corporate bonds are typically based on a single non-binding broker quote. The fair value of certain asset backed securities is determined using a discounted cash flow model. Inputs used to determine the expected cash flows include assumptions about discount rates and default, prepayment and recovery rates of the underlying assets. Given the significance of the unobservable inputs to this fair value measurement, the fair value of the investment in certain asset backed securities is classified as Level 3.

In consideration of the above, management is responsible for the fair values recorded on the financial statements. Prices received from third-party pricing services are subjected to exception reporting that identifies investments with significant daily price movements as well as no movements. The Company reviews the exception reporting and resolves the exceptions through reaffirmation of the price or recording an appropriate fair value estimate. The Company also performs subsequent transaction testing. The Company performs annual due diligence of third-party pricing services. The Company’s due diligence procedures include assessing the vendor’s valuation qualifications, control environment, analysis of asset-class specific valuation methodologies, and understanding of sources of market observable assumptions and unobservable assumptions, if any, employed in the valuation methodology. The Company also considers the results of its exception reporting controls and any resulting price challenges that arise.

Separate Account Assets

The fair value of assets held by separate accounts is determined by the NAV of the funds in which those separate accounts are invested. The NAV is used as a practical expedient for fair value and represents the exit price for the separate account assets. Separate account assets are excluded from classification in the fair value hierarchy.

Investments and Cash Equivalents Segregated for Regulatory Purposes

Investments and cash equivalents segregated for regulatory purposes includes U.S. Treasuries that are classified as Level 1.

Other Assets

Derivatives that are measured using quoted prices in active markets, such as foreign currency forwards, or derivatives that are exchange-traded are classified as Level 1 measurements. The variation margin on futures contracts is also classified as Level 1. The fair value of derivatives that are traded in less active over-the-counter (“OTC”) markets is generally measured using pricing models with market observable inputs such as interest rates and equity index levels. These measurements are classified as Level 2 within the fair value hierarchy and include swaps and the majority of options. The counterparties’ nonperformance risk associated with

uncollateralized derivative assets was immaterial as of both March 31, 2019 and December 31, 2018. See Note 12 and Note 13 for further information on the credit risk of derivative instruments and related collateral.

Liabilities

Policyholder Account Balances, Future Policy Benefits and Claims

The Company values the embedded derivatives attributable to the provisions of certain variable annuity riders using internal valuation models. These models calculate fair value by discounting expected cash flows from benefits plus margins for profit, risk and expenses less embedded derivative fees. The projected cash flows used by these models include observable capital market assumptions and incorporate significant unobservable inputs related to contractholder behavior assumptions, implied volatility, and margins for risk, profit and expenses that the Company believes an exit market participant would expect. The fair value also reflects a current estimate of the Company’s nonperformance risk specific to these embedded derivatives. Given the significant unobservable inputs to this valuation, these measurements are classified as Level 3. The embedded derivatives attributable to these provisions are recorded in policyholder account balances, future policy benefits and claims.

The Company uses various Black-Scholes calculations to determine the fair value of the embedded derivatives associated with the provisions of its fixed index annuity and IUL products. The Company uses a discounted cash flow model to determine the fair value of the embedded derivatives associated with the provisions of its equity index annuity product. The projected cash flows generated by this model are based on significant observable inputs related to interest rates, volatilities and equity index levels and, therefore, are classified as Level 2. The fair value of fixed index annuity and IUL embedded derivatives includes significant observable interest rates, volatilities and equity index levels and the significant unobservable estimate of the Company’s nonperformance risk. Given the significance of the nonperformance risk assumption to the fair value, the fixed index annuity and IUL embedded derivatives are classified as Level 3. The embedded derivatives attributable to these provisions are recorded in policyholder account balances, future policy benefits and claims.

Customer Deposits

The Company uses various Black-Scholes calculations to determine the fair value of the embedded derivative liability associated with the provisions of its stock market certificates (“SMC”). The inputs to these calculations are primarily market observable and include interest rates, volatilities and equity index levels. As a result, these measurements are classified as Level 2.

Other Liabilities

Derivatives that are measured using quoted prices in active markets, such as foreign currency forwards, or derivatives that are exchange-traded, are classified as Level 1 measurements. The variation margin on futures contracts is also classified as Level 1. The fair value of derivatives that are traded in less active OTC markets is generally measured using pricing models with market observable inputs such as interest rates and equity index levels. These measurements are classified as Level 2 within the fair value hierarchy and include swaps and the majority of options. The Company’s nonperformance risk associated with uncollateralized derivative liabilities was immaterial as of both March 31, 2019 and December 31, 2018. See Note 12 and Note 13 for further information on the credit risk of derivative instruments and related collateral.

Securities sold but not yet purchased include highly liquid investments which are short-term in nature. Securities sold but not yet purchased are measured using amortized cost, which is a reasonable estimate of fair value because of the short time between the purchase of the instrument and its expected realization and are classified as Level 2.

Contingent consideration liabilities consist of earn-outs and/or deferred payments related to the Company’s acquisitions. Contingent consideration liabilities are recorded at fair value using a discounted cash flow model under multiple scenarios and an unobservable input (discount rate). Given the use of a significant unobservable input, the fair value of contingent consideration liabilities is classified as Level 3 within the fair value hierarchy.

Fair Value on a Nonrecurring Basis

The Company assesses its investment in affordable housing partnerships for other-than-temporary impairment. The investments that are determined to be OTTI are written down to their fair value. The Company uses a discounted cash flow model to measure the fair value of these investments. Inputs to the discounted cash flow model are estimates of future net operating losses and tax credits available to the Company and discount rates based on market condition and the financial strength of the syndicator (general partner). The balance of affordable housing partnerships measured at fair value on a nonrecurring basis was $104 million and $112 million as of March 31, 2019 and December 31, 2018, respectively, and is classified as Level 3 in the fair value hierarchy.

Asset and Liabilities Not Reported at Fair Value

The following tables provide the carrying value and the estimated fair value of financial instruments that are not reported at fair value:



	March 31, 2019
	Carrying Value		Fair Value
	Carrying Value		Level 1		Level 2		Level 3		Total
	(in millions)
Financial Assets
Mortgage loans, net	$	2,644	$	—	$	—	$	2,657	$	2,657
Policy and certificate loans	854		—		—		802		802
Receivables	3,209		86		958		2,125		3,169
Restricted and segregated cash	2,332		2,332		—		—		2,332
Other investments and assets	590		—		522		61		583

Financial Liabilities
Policyholder account balances, future policy benefits and claims	$	9,456	$	—	$	—	$	9,867	$	9,867
Investment certificate reserves	8,126		—		—		8,099		8,099
Brokerage customer deposits	3,397		3,397		—		—		3,397
Separate account liabilities at NAV	5,098								5,098		⁽¹⁾
Debt and other liabilities	3,695		105		3,617		40		3,762



	December 31, 2018
	Carrying Value		Fair Value
	Carrying Value		Level 1		Level 2		Level 3		Total
	(in millions)
Financial Assets
Mortgage loans, net	$	2,696	$	—	$	—	$	2,661	$	2,661
Policy and certificate loans	861		—		—		810		810
Receivables	1,677		179		965		489		1,633
Restricted and segregated cash	2,609		2,609		—		—		2,609
Other investments and assets	572		—		491		60		551

Financial Liabilities
Policyholder account balances, future policy benefits and claims	$	9,609	$	—	$	—	$	9,672	$	9,672
Investment certificate reserves	7,886		—		—		7,845		7,845
Brokerage customer deposits	3,660		3,660		—		—		3,660
Separate account liabilities at NAV	4,843								4,843		⁽¹⁾
Debt and other liabilities	3,296		188		3,059		57		3,304

Receivables include the reinsurance deposit receivable, brokerage margin loans, securities borrowed and loans to financial advisors. Restricted and segregated cash includes cash segregated under federal and other regulations held in special reserve bank accounts for the exclusive benefit of the Company’s brokerage customers. Other investments and assets primarily include syndicated loans, certificate of deposits with original or remaining maturities at the time of purchase of more than 90 days, the Company’s membership in the FHLB and investments related to the Community Reinvestment Act. See Note 6 for additional information on mortgage loans, policy loans, certificate loans, syndicated loans and the reinsurance deposit receivable.

Policyholder account balances, future policy benefit and claims include fixed annuities in deferral status, non-life contingent fixed annuities in payout status, indexed annuity host contracts and the fixed portion of a small number of variable annuity contracts classified as investment contracts. See Note 8 for additional information on these liabilities. Investment certificate reserves represent customer deposits for fixed rate certificates and stock market certificates. Brokerage customer deposits are amounts payable to

brokerage customers related to free credit balances, funds deposited by customers and funds accruing to customers as a result of trades or contracts. Separate account liabilities primarily relate to investment contracts in pooled pension funds offered by Threadneedle. Debt and other liabilities include the Company’s long-term debt, short-term borrowings, securities loaned and future funding commitments to affordable housing partnerships and other real estate partnerships. See Note 10 for further information on the Company’s long-term debt and short-term borrowings.

- Definition

The entire disclosure for the fair value of financial instruments (as defined), including financial assets and financial liabilities (collectively, as defined), and the measurements of those instruments as well as disclosures related to the fair value of non-financial assets and liabilities. Such disclosures about the financial instruments, assets, and liabilities would include: (1) the fair value of the required items together with their carrying amounts (as appropriate); (2) for items for which it is not practicable to estimate fair value, disclosure would include: (a) information pertinent to estimating fair value (including, carrying amount, effective interest rate, and maturity, and (b) the reasons why it is not practicable to estimate fair value; (3) significant concentrations of credit risk including: (a) information about the activity, region, or economic characteristics identifying a concentration, (b) the maximum amount of loss the entity is exposed to based on the gross fair value of the related item, (c) policy for requiring collateral or other security and information as to accessing such collateral or security, and (d) the nature and brief description of such collateral or security; (4) quantitative information about market risks and how such risks are managed; (5) for items measured on both a recurring and nonrecurring basis information regarding the inputs used to develop the fair value measurement; and (6) for items presented in the financial statement for which fair value measurement is elected: (a) information necessary to understand the reasons for the election, (b) discussion of the effect of fair value changes on earnings, (c) a description of [similar groups] items for which the election is made and the relation thereof to the balance sheet, the aggregate carrying value of items included in the balance sheet that are not eligible for the election; (7) all other required (as defined) and desired information.

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