EQNIKH TRAPEZA THS ELLADOS A.E.
(Exact name of Registrant as specified in its charter)

Gregory Papagrigoris—Investor Relations manager
Tel: +30 210 334 2310—Email:IR@NBG.gr
86 Eolou Street, 10232 Athens, Greece
(Name, Telephone, E-mail and/or Facsimile number and Address of company contact Person)

Securities registered or to be registered pursuant to Section 12(b) of the Securities Exchange Act of 1934:

* Not for trading but only in connection with the registration of American Depositary Shares, pursuant to the requirements of the Securities and Exchange Commission.

Securities registered or to be registered pursuant to Section 12(g) of the Securities Exchange Act of 1934:

Securities for which there is a reporting obligation pursuant to Section 15(d) of the Securities Exchange Act of 1934:

Number of outstanding shares of each of the Registrant's classes of capital or common stock as at December 31, 2011, the close of the period covered by the annual report:

270,000,000 Redeemable Preference Shares of a nominal value of EUR 5.00 per share issued to the Hellenic Republic

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act.

If this report is an annual or transition report, indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934.

Note—Checking the box above will not relieve any registrant required to file reports pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934 from their obligations under those Sections.

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the Registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days.

Indicate by check mark whether the registrant has submitted electronically and posted on its corporate Web site, if any, every Interactive Data File required to be submitted and posted pursuant to Rule 405 of Regulation S-T (§232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit and post such files).

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, or a non-accelerated filer. See definition of "accelerated filer and large accelerated filer" in Rule 12b-2 of the Exchange Act. (Check one):

Indicate by check mark which basis of accounting the registrant has used to prepare the financial statements included in this filing:

U.S. GAAP ý International Financial Reporting Standards as issued by the International Accounting Standards Board o Other o

If "Other" has been checked in response to the previous question, indicate by check mark which financial statement item the registrant has elected to follow:

If this is an annual report, indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act).

Information Regarding National Bank of Greece S.A. and the National Bank of Greece Group

Historically, Greek law prohibited banks from engaging directly in financial service activities outside their traditional deposit and loan functions. Therefore, specialized financial institutions were established in Greece, each for the provision of a particular type of financial service. A Greek bank that sought to provide multiple financial services to its customers would establish several subsidiaries, each a specialized institution within the bank's integrated group of diverse financial services companies. As a consequence of this historical practice, the Greek financial services sector today is characterized by a group of specialized companies established around a principal bank. National Bank of Greece S.A. is the principal bank, around which our consolidated financial services subsidiaries are organized.

All references in this annual report on Form 20-F (the "Annual Report") to the "Bank" or "NBG" are to National Bank of Greece S.A. without its subsidiaries. The Bank and its consolidated subsidiaries, collectively, are referred to in this Annual Report as the "NBG Group" or the "Group". All references in this Annual Report to "we", "us" or "our" are, as the context requires, to the Bank or to the NBG Group as a whole. In addition, all references in this Annual Report to the "Greek State" or "Hellenic Republic" are to the Hellenic Republic.

The NBG Group operates in many countries and earns money and makes payments in many different currencies. All references to "$", "U.S. dollars", "USD" or "US$" are to United States dollars and all references to "€", "EUR" or to "euro" are to the lawful currency introduced at the start of the third stage of the European Economic and Monetary Union in accordance with the Treaty Establishing the European Community, as amended, which was adopted by the Hellenic Republic as of January 1, 2001. All references to the "eurozone" are to the member states of the European Union (the "EU") that have adopted the euro as their national currency in accordance with the Treaty on EU signed at Maastricht on February 7, 1992. All references to "BGN" are to Bulgarian leva, all references to "£" or "GBP" are to British pounds, all references to "RSD" are to Serbian dinars, all references to "JPY" are to Japanese yen, all references to "MKD" are to Macedonian dinars, all references to "RON" are to Romanian lei, all references to "TL" are to Turkish lira and all references to "ZAR" are to South African rand.

Solely for convenience, this Annual Report contains translations of certain euro amounts into U.S. dollars at specified rates. These are simply convenience translations and you should not expect that a euro amount actually represents a stated U.S. dollar amount or that it could be converted into U.S. dollars at the rate suggested, or any other rate. In this Annual Report, the translations of euro amounts into U.S. dollars, where indicated, have been made at the noon buying rate for cable transfers of euro into U.S. dollars of US$1.00 = 0.7559, as certified for customs by the Federal Reserve Bank of New York (the "Noon Buying Rate") on April 30, 2012. The respective rates for the South African rand, Macedonian dinar, Bulgarian leva, Romanian lei, Serbian dinar and Turkish lira are: South African rand 7.7594 per US$1.00, Macedonian dinars 46.4475 per US$1.00, Bulgarian leva 1.4801 per US$1.00, Romanian lei 3.3370 per US$1.00, Serbian dinars 84.7635 per US$1.00 and Turkish lira 1.7583 per US$1.00. The table below sets out the highest and lowest exchange rate between the euro and the U.S. dollar, for each of the completed six months preceding the filing of this Annual Report:

The following table sets forth the average exchange rates between the euro and the U.S. dollar and the euro and the Turkish lira (TL) for each of the five years ended December 31, 2007, 2008, 2009, 2010 and 2011 and for the current annual period through April 30, 2012. The following exchange rates have been calculated using the average of the Noon Buying Rates for euro on the last day of each month during each of these periods.

As further discussed in "Recent Developments" below, the financial statements prepared in accordance with United States Generally Accepted Accounting Principles ("U.S. GAAP") for the financial years ended December 31, 2007, 2008, 2009 and 2010 have been restated and/or reclassified.

This Annual Report includes forward-looking statements. Such items in this Annual Report include, but are not limited to, statements made under Item 3.D, "Risk Factors", Item 4.B, "Business Overview" and Item 5, "Operating and Financial Review and Prospects". Such statements can be generally identified by the use of terms such as "believes", "expects", "may", "will", "should", "would", "could", "plans", "anticipates" and comparable terms and the negatives of such terms. By their nature, forward-looking statements involve risk and uncertainty, and the factors described in the context of such forward-looking statements in this Annual Report, could cause actual results and developments to differ materially from those expressed in or implied by such forward-looking statements. We have based these forward-looking statements on our current expectations and projections about future events. These forward-looking statements are subject to risks, uncertainties and assumptions about the Group, including, among other things:

We undertake no obligation to publicly update or revise any forward-looking statements, whether as a result of new information, future events or otherwise. In light of these risks, uncertainties and assumptions, the forward-looking events discussed in this Annual Report might not occur. Any statements regarding past trends or activities should not be taken as a representation that such trends or activities will continue in the future.

Readers are cautioned not to place undue reliance on such forward-looking statements, which are based on facts known to us only as of the date of this Annual Report.

We have restated our financial statements prepared in accordance with U.S. GAAP for the financial years ended December 31, 2008, 2009 and 2010 as follows:

In addition, we have also made certain reclassifications to prior year amounts in order to conform to current year presentation.

The above restatements and reclassifications are described in detail in Note 43 to the U.S. GAAP Financial Statements.

The tables below present the impact of the above restatements and reclassifications on the balance sheets as at December 31, 2007, 2008, 2009 and 2010 and on the statements of income and comprehensive income for the years ended December 31, 2007, 2008, 2009 and 2010.

	As of December 31, 2007									As of December 31, 2008

	As reported		Restatements		Reclassifications			As restated		As reported			Restatements		Reclassifications			As restated
	(EUR in thousands)									(EUR in thousands)
ASSETS
Money market investments		254,034		—		(254,034	)		—		241,257			—		(241,257	)		—
Trading assets		6,678,634		—		62,341			6,740,975		2,056,589			—		131,254			2,187,843
Available-for-sale securities		4,550,227		—		191,693			4,741,920		12,250,841			—		110,003			12,360,844
Held-to-maturity securities		—		—		—			—		130,548			—		—			130,548
Summary other assets		9,493,301		—		—			9,493,301		11,034,132			75,770		—			11,109,902
Total assets		90,960,648		—		—			90,960,648		101,849,175			75,770		—			101,924,945
LIABILITIES AND SHAREHOLDERS' EQUITY
Summary other liabilities		7,447,771		—		—			7,447,771		8,190,739			13,581		—			8,204,320
Total liabilities		83,266,965		—		—			83,266,965		94,862,022			13,581		—			94,875,603
PERMANENT EQUITY:
NBG shareholders' equity
Accumulated surplus		1,419,743		—		—			1,419,743		2,015,971			62,189		—			2,078,160
Accumulated other comprehensive income / (loss)		271,060		—		—			271,060		(1,696,839	)		—		—			(1,696,839	)
Total NBG shareholders' equity		6,544,113		—		—			6,544,113		5,932,396			62,189		—			5,994,585
Non-controlling interest		494,334		—		—			494,334		798,549			—		—			798,549
Total permanent equity		7,038,447		—		—			7,038,447		6,730,945			62,189		—			6,793,134
Total liabilities and equity		90,960,648		—		—			90,960,648		101,849,175			75,770		—			101,924,945

	As of December 31, 2009												As of December 31, 2010

	As reported			Restatements			Reclassifications			As restated			As reported			Restatements			Reclassifications			As restated
	(EUR in thousands)												(EUR in thousands)
ASSETS
Money market investments		1,239,867			—			(1,239,867	)		—			1,180,274			—			(1,180,274	)		—
Trading assets		3,167,740			—			897,250			4,064,990			774,374			1,062,834			948,114			2,785,322
Available-for-sale securities		15,740,696			—			342,617			16,083,313			14,512,870			(1,042,680	)		218,320			13,688,510
Held-to-maturity securities		99,604			—			—			99,604			3,611,797			(27,352	)		13,840			3,598,285
Summary other assets		11,205,734			(69,279	)		—			11,136,455			11,929,898			(76,226	)		—			11,853,672
Total assets		113,184,158			(69,279	)		—			113,114,879			118,815,302			(83,424	)		—			118,731,878
LIABILITIES AND SHAREHOLDERS' EQUITY
Summary other liabilities		8,141,160			4,529			—			8,145,689			8,757,402			(5,915	)		—			8,751,487
Total liabilities		103,818,065			4,529			—			103,822,594			109,997,122			(5,915	)		—			109,991,207
PERMANENT EQUITY:
NBG shareholders' equity
Accumulated surplus		2,523,833			(73,808	)		—			2,450,025			2,182,661			(160,519	)		—			2,022,142
Accumulated other comprehensive income / (loss)		(1,517,127	)		—			—			(1,517,127	)		(3,468,821	)		83,225			—			(3,385,596	)
Total NBG shareholders' equity		8,266,867			(73,808	)		—			8,193,059			7,730,352			(77,294	)		—			7,653,058
Non-controlling interest		844,727			—			—			844,727			821,846			(215	)		—			821,631
Total permanent equity		9,111,594			(73,808	)		—			9,037,786			8,552,198			(77,509	)		—			8,474,689
Total liabilities and equity		113,184,158			(69,279	)		—			113,114,879			118,815,302			(83,424	)		—			118,731,878

	Year ended December 31, 2007											Year ended December 31, 2008

	As reported			Restatements		Reclassifications			As restated			As reported			Restatements			Reclassifications			As restated
	(EUR in thousands)											(EUR in thousands)
Total interest income		5,606,240			—		—			5,606,240			6,695,077			—			—			6,695,077
Net interest income before provision for loan losses		2,986,356			—		—			2,986,356			3,405,136			—			—			3,405,136
Net interest income after provision for loan losses		2,795,601			—		—			2,795,601			2,979,599			—			—			2,979,599
Net trading profit/ (loss)		(97,693	)		—		—			(97,693	)		(329,550	)		82,919			—			(246,631	)
Total non-interest income / (loss) excluding gains / (losses) on investment securities		2,018,064			—		—			2,018,064			1,536,151			82,919			—			1,619,070
Net gains/(losses) on available-for-sale securities		129,816			—		989			130,805			8,415			—			17,772			26,187
OTTI of available-for-sale securities and held-to-maturity securities (of which nil was recognised through OCI)		—			—		(989	)		(989	)		—			—			(17,772	)		(17,772	)
Net gains / (losses) on investment securities		129,816			—		—			129,816			8,415			—			—			8,415
Total non-interest income / (loss)		2,147,880			—		—			2,147,880			1,544,566			82,919			—			1,627,485
Income / (loss) before income tax		1,695,289			—		—			1,695,289			1,145,169			82,919			—			1,228,088
Income tax (expense) / benefit		(311,491	)		—		—			(311,491	)		(242,081	)		(20,730	)		—			(262,811	)
Net income / (loss)		1,383,798			—		—			1,383,798			903,088			62,189			—			965,277
Less: Net income attributable to the non-controlling interest		(65,007	)		—		—			(65,007	)		(81,664	)		—			—			(81,664	)
Net income / (loss) attributable to NBG shareholders		1,318,791			—		—			1,318,791			821,424			62,189			—			883,613

	Year ended December 31, 2009												Year ended December 31, 2010

	As reported			Restatements			Reclassifications			As restated			As reported			Restatements			Reclassifications			As restated
	(EUR in thousands)												(EUR in thousands)
Total interest income		6,231,380			—			—			6,231,380			6,153,434			(4,598	)		—			6,148,836
Net interest income before provision for loan losses		3,786,265			—			—			3,786,265			4,088,199			(4,598	)		—			4,083,601
Net interest income after provision for loan losses		2,787,817			—			—			2,787,817			2,883,204			(4,598	)		—			2,878,606
Net trading profit/ (loss)		(87,096	)		(180,035	)		—			(267,131	)		(1,085,160	)		(160,162	)		—			(1,245,322	)
Total non-interest income / (loss) excluding gains / (losses) on investment securities		1,727,899			(180,035	)		—			1,547,864			802,523			(160,162	)		—			642,361
Net gains/(losses) on available-for-sale securities		(8,399	)		—			358,328			349,929			(23,957	)		49,419			89,497			114,959
OTTI of available-for-sale securities and held-to-maturity securities (of which nil was recognised through OCI)		—			—			(358,328	)		(358,328	)		—			—			(89,497	)		(89,497	)
Net gains / (losses) on investment securities		(8,399	)		—			—			(8,399	)		(23,957	)		49,419			—			25,462
Total non-interest income / (loss)		1,719,500			(180,035	)		—			1,539,465			778,566			(110,743	)		—			667,823
Income / (loss) before income tax		809,905			(180,035	)		—			629,870			(150,352	)		(115,341	)		—			(265,693	)
Income tax (expense) / benefit		(220,624	)		44,038			—			(176,586	)		(61,634	)		19,323			—			(42,311	)
Net income / (loss)		589,281			(135,997	)		—			453,284			(211,986	)		(96,018	)		—			(308,004	)
Less: Net income attributable to the non-controlling interest		(62,232	)		—			—			(62,232	)		(56,075	)		9,307			—			(46,768	)
NET INCOME / (LOSS) attributable to NBG shareholders		527,049			(135,997	)		—			391,052			(268,061	)		(86,711	)		—			(354,772	)

All amounts for 2007, 2008, 2009 and 2010 referred to in this Annual Report reflect the relevant amounts on a restated and/or reclassified basis. The previously issued financial statements prepared in accordance with U.S. GAAP for the financial years ended December 31, 2008, 2009 and 2010 should no longer be relied upon. We do not intend to amend our annual reports on Form 20-F for the financial years ended December 31, 2007, 2008, 2009 and 2010.

The following information as at, and for the years ended, December 31, 2007 through 2011 has been derived from the consolidated financial statements of the Group. These financial statements have been prepared in accordance with U.S. GAAP. The selected financial and operating data should be read in conjunction with Item 5, "Operating and Financial Review and Prospects", in this Annual Report and with the Group's audited U.S. GAAP financial statements and the notes thereto as at December 31, 2010 and 2011 and for the years ended December 31, 2009, 2010 and 2011 (the "U.S. GAAP Financial Statements") included elsewhere in this Annual Report.

As described in this Annual Report under the headings "Currency and Financial Statement Presentation" and "Recent Developments" Presentation of Financial Information", this Annual Report contains restated and/or reclassified financial statements and related financial information for the financial years ended December 31, 2007, 2008, 2009 and 2010.

	Year ended December 31,

	2007 As restated⁽⁴⁾			2008 As restated⁽⁴⁾			2009 As restated⁽⁴⁾			2010 As restated⁽⁴⁾			2011			2011⁽¹⁾
	(EUR in thousands, except per share data)															(USD in thousands, except per share data)
CONSOLIDATED STATEMENT OF INCOME DATA
Continuing operations
Total interest income		5,606,240			6,695,077			6,231,380			6,148,836			6,259,650			8,281,056
Total interest expense		(2,619,884	)		(3,289,941	)		(2,445,115	)		(2,065,235	)		(2,611,499	)		(3,454,820	)

Net interest income before provision for loan losses		2,986,356			3,405,136			3,786,265			4,083,601			3,648,151			4,826,236
Provision for loan losses		(190,755	)		(425,537	)		(998,448	)		(1,204,995	)		(3,703,269	)		(4,899,152	)

Net interest income after provision for loan losses		2,795,601			2,979,599			2,787,817			2,878,606			(55,118	)		(72,916	)

Non-interest income / (loss)
Credit card fees		209,105			243,048			200,939			188,771			198,411			262,483
Service charges on deposit accounts		43,121			50,546			49,005			52,722			78,342			103,641
Other fees and commissions		626,485			554,161			502,140			475,692			435,421			576,030
Net trading profit loss		(97,693	)		(246,631	)		(267,131	)		(1,245,322	)		(1,877,038	)		(2,483,183	)
Equity in earnings of investees and realized gains/(losses) on disposals		159,536			(23,730	)		(27,879	)		9,245			8,661			11,458
Income from insurance operations		834,681			852,557			990,054			1,017,172			777,280			1,028,284
Other income		242,829			189,119			100,736			144,081			85,085			112,561

Total non-interest income / (loss) excluding gains / losses on investment securities		2,018,064			1,619,070			1,547,864			642,361			(293,838	)		(388,726	)
Net gains/(losses) on available-for-sale securities		130,805			26,187			349,929			114,959			(19,466	)		(25,752	)
OTTI of available-for-sale securities and held-to-maturity securities (of which NIL was recognised through AOCI)		(989	)		(17,772	)		(358,328	)		(89,497	)		(9,173,713	)		(12,136,146	)

Net gains / (losses) on investment securities		129,816			8,415			(8,399	)		25,462			(9,193,179	)		(12,161,898	)
Total non-interest income / (loss)		2,147,880			1,627,485			1,539,465			667,823			(9,487,017	)		(12,550,624	)

	Year ended December 31,

	2007⁽⁴⁾ As restated			2008⁽⁴⁾ As restated			2009⁽⁴⁾ As restated			2010⁽⁴⁾ As restated			2011			2011⁽¹⁾
	(EUR in thousands, except per share data)															(USD in thousands, except per share data)
Non-interest expense
Salaries, employee benefits and voluntary early retirement schemes		(1,420,092	)		(1,439,415	)		(1,557,784	)		(1,511,875	)		(1,426,428	)		(1,887,059	)
Depreciation of premises and equipment		(91,576	)		(104,405	)		(122,765	)		(129,310	)		(121,652	)		(160,937	)
Amortization of intangible assets		(48,235	)		(58,073	)		(65,260	)		(79,906	)		(98,930	)		(130,877	)
Impairment of goodwill		(11,224	)		(4,585	)		—			(6,320	)		(418,676	)		(553,877	)
Insurance claims, reserves movements, commissions and reinsurance premiums ceded		(764,883	)		(741,565	)		(898,934	)		(941,589	)		(1,013,879	)		(1,341,287	)
Summary other⁽²⁾		(912,182	)		(1,030,953	)		(1,052,669	)		(1,143,122	)		(1,426,434	)		(1,887,067	)

Total non-interest expense		(3,248,192	)		(3,378,996	)		(3,697,412	)		(3,812,122	)		(4,505,999	)		(5,961,104	)

Income / (loss) from continuing operations before income tax		1,695,289			1,228,088			629,870			(265,693	)		(14,048,134	)		(18,584,644	)
Income tax (expense) / benefit		(311,491	)		(262,811	)		(176,586	)		(42,311	)		(459,345	)		(607,679	)

Net income / (loss)		1,383,798			965,277			453,284			(308,004	)		(14,507,479	)		(19,192,323	)
Less: Net income / (loss) attributable to the non-controlling interest		(65,007	)		(81,664	)		(62,232	)		(46,768	)		(32,189	)		(42,584	)

Net income / (loss) attributable to NBG shareholders		1,318,791			883,613			391,052			(354,772	)		(14,539,668	)		(19,234,907	)

Net income per share from continuing operations
Basic EPS—Net income / (loss)⁽³⁾		2.10			1.35			0.53			(0.56	)		(15.22	)		(20.13	)
Diluted EPS—Net income / (loss)⁽³⁾		2.09			1.35			0.53			(0.56	)		(15.22	)		(20.13	)
Cash dividends declared per share		1.00			0.40			—			—			—			—

The number of shares as adjusted to reflect changes in capital is presented in the following table:

	Year ended December 31,

	2007 As restated⁽⁶⁾			2008 As restated⁽⁶⁾			2009 As restated⁽⁶⁾			2010 As restated⁽⁶⁾			2011			2011⁽¹⁾
	(EUR in thousands)															(USD in thousands)
CONSOLIDATED BALANCE SHEET DATA
ASSETS
Cash and due from banks		4,226,768			1,540,170			1,430,381			1,436,157			1,717,736			2,272,438
Deposits with Central Bank		2,372,145			2,882,480			2,921,346			2,961,828			2,898,998			3,835,161
Securities purchased under agreements to resell		1,415,688			657,070			532,111			146,302			673,187			890,577
Interest bearing deposits with banks		1,777,422			1,750,516			3,077,953			6,398,767			3,767,624			4,984,289
Trading assets		6,740,975			2,187,843			4,064,990			2,785,322			2,964,088			3,921,270
Financial instruments marked to market through the profit and loss		5,692,692			—			—			—			—			—
Available-for-sale securities		4,741,920			12,360,844			16,083,313			13,688,510			8,571,724			11,339,759
Held- to- maturity securities		—			130,548			99,604			3,598,285			1,002,202			1,325,839
Loans		55,560,492			70,467,044			75,833,904			79,038,440			76,002,857			100,546,179
Less: Allowance for loan losses		(1,132,952	)		(1,232,626	)		(2,065,178	)		(3,175,405	)		(6,550,635	)		(8,666,007	)

Net loans		54,427,540			69,234,418			73,768,726			75,863,035			69,452,222			91,880,172
Assets classified as held for sale⁽²⁾		72,197			71,154			—			—			—			—
Summary other assets⁽³⁾		9,493,301			11,109,902			11,136,455			11,853,672			12,419,454			16,430,023

Total assets		90,960,648			101,924,945			113,114,879			118,731,878			103,467,235			136,879,528

LIABILITIES AND SHAREHOLDERS' EQUITY
Deposits excluding interbank deposits		60,113,568			67,183,941			70,898,987			67,768,292			58,912,852			77,937,362
Interbank deposits		6,759,314			13,338,844			16,935,424			26,127,189			32,662,450			43,210,015

Total deposits		66,872,882			80,522,785			87,834,411			93,895,481			91,575,302			121,147,377
Securities sold under agreements to repurchase		3,509,525			1,757,153			4,485,440			3,538,289			1,302,239			1,722,766
Long-term debt		5,425,319			4,385,023			3,357,054			3,805,950			2,937,371			3,885,925
Liabilities classified as held for sale⁽⁴⁾		11,468			6,322			—			—			—			—
Summary other liabilities⁽⁵⁾		7,447,771			8,204,320			8,145,689			8,751,487			11,555,636			15,287,254

Total liabilities		83,266,965			94,875,603			103,822,594			109,991,207			107,370,548			142,043,322

Redeemable non-controlling interest- Temporary equity		655,236			256,208			254,499			265,982			283,368			374,875
PERMANENT EQUITY
Preferred stock (25,000,000 shares of par value EUR 0.30 each at 2010 and 2011 and 70,000,000 and 270,000,000 shares of par value EUR 5.00 each at 2010 and 2011, respectively)		—			7,500			357,500			357,500			1,357,500			1,795,872
Common stock		2,385,992			2,483,271			3,035,208			4,780,452			4,780,452			6,324,186
Additional paid-in capital		2,488,919			3,267,770			3,878,079			3,883,461			4,090,184			5,411,012
Accumulated other comprehensive income/(loss)		271,060			(1,696,839	)		(1,517,127	)		(3,385,596	)		(1,938,578	)		(2,564,595	)
Treasury stock, at cost		(21,601	)		(145,277	)		(10,626	)		(4,901	)		(110	)		(146	)
Accumulated surplus / (deficit)		1,419,743			2,078,160			2,450,025			2,022,142			(12,547,110	)		(16,598,901	)

Total NBG shareholders' equity / (deficit)		6,544,113			5,994,585			8,193,059			7,653,058			(4,257,662	)		(5,632,572	)

Non-controlling interest		494,334			798,549			844,727			821,631			70,981			93,903

Total liabilities and equity		90,960,648			101,924,945			113,114,879			118,731,878			103,467,235			136,879,528

For exchange rate information, see "Introduction—Currency and Financial Statement Presentation".

This Annual Report contains references to certain measures which are not defined by U.S. GAAP, namely "adjusted net loans" and "deposits excluding interbank deposits".

The Group defines "adjusted net loans" as "net loans" excluding an amortizing loan to the Hellenic Republic expiring in September 2037, of EUR 4,760.2 million (see Item 4.E, "Selected Statistical Data—Assets—Loan Portfolio").

The Group defines "deposits excluding interbank deposits" as "Total deposits" deducting "Interbank deposits" amounting to:

The Group uses the measures "adjusted net loans" to distinguish loans originated by the Group from the loan provided to the Hellenic Republic and the loans exchanged in the PSI. Furthermore, the Group uses the measure "deposits excluding interbank deposits" in order to enhance the comparability of its financial performance between reporting periods, particularly in light of increased funding from ECB resulting from the pressure experienced by the Hellenic Republic in its public finances. "Adjusted net loans" and "deposits excluding interbank deposits" are not financial measures determined in accordance with U.S. GAAP and, accordingly, should not be considered as an alternative to other measures derived in accordance with U.S.GAAP.

On May 25, 2007, at the Bank's general meeting of ordinary shareholders ("General Meeting"), the Bank's ordinary shareholders approved the distribution of a cash dividend in the amount of EUR 1.00 per share with respect to the year ended December 31, 2006.

On April 17, 2008, at the Bank's General Meeting, the Bank's ordinary shareholders approved the distribution of a dividend in the amount of EUR 1.40 per share with respect to the year ended December 31, 2007. All ordinary shareholders received EUR 0.40 in cash. The remaining EUR 1.00 was received in the form of shares at a rate of 4 to 100, as approved at the Bank's repeat General Meeting held on May 15, 2008.

On June 2, 2009, the Bank's General Meeting approved the non-payment of dividends to ordinary shareholders as a result of the Bank's participation in the Hellenic Republic Bank Support Plan and the payment of dividends to preferred shareholders as follows:

On May 21, 2010, the Bank's General Meeting approved the non-payment of dividends to ordinary shareholders as a result of the Bank's participation in the Hellenic Republic Bank Support Plan and the payment of dividends to preferred shareholders as follows:

On June 23, 2011, the Bank's General Meeting approved the non-payment of dividends to ordinary shareholders as a result of the Bank's participation in the Hellenic Republic Bank Support Plan, as well as the non-payment of dividends to holders of our non-cumulative non-voting redeemable preference shares and to the Hellenic Republic, as sole holder of the 70 million preference shares issued as part of our participation in the Hellenic Republic Bank Support Plan, in accordance with the Bank's Articles of Association, the Greek Law 3965/2011 and the provisions of article 44a in combination with articles 42c and 43 of the Greek Companies Act, which prohibit the payment of dividends in the absence of sufficient distributable funds.

The following tables set forth the actual dividends per ordinary share paid by the Bank for the years ended December 31, 2007, 2008, 2009, 2010 and 2011 in respect of ordinary shareholders. For more information on how dividends are distributed see Item 8.A, "Consolidated Statements and Other Financial Information—Policy on Dividend Distributions".

For a description of the Bank's dividend policy please refer to Item 8, "Financial Information".

If you are considering purchasing our ordinary shares, preference shares or American Depositary Receipts ("ADRs"), you should carefully read and think about all the information contained in this document, including the risk factors set out below, prior to making any investment decision. If any of the events described below actually occur, our business, results of operations and financial condition could be materially adversely affected, and the value and trading price of our ordinary shares, preference shares or ADRs may decline, resulting in a loss of all or a part of any investment in our ordinary shares, preference shares or ADRs. Furthermore, the risks described below are not the only risks we face. Additional risk factors which are not currently known or are currently believed to be immaterial may also have a material adverse effect on our business, results of operations and financial condition.

Uncertainty resulting from the Hellenic Republic's economic crisis is having and is likely to continue to have a significant adverse impact on our business, results of operations and financial condition.

For the financial year ended December 31, 2011, 58.3% of the Group's net interest income before provision for loan losses and as of December 31, 2011, 70.0% of our loans, were derived from our

operations in the Hellenic Republic. In addition, our holdings of EUR 7.1 billion in Greek government bonds and Greek treasury bills represented 6.8% of our total assets after the impairment due to the Hellenic Republic's debt restructuring ("PSI"), and 59.0% of our trading and investment fixed income portfolio (amounting to EUR 12.0 billion) as of December 31, 2011. Accordingly, the quality of our assets, our financial condition and our results of operations are heavily dependent on macroeconomic and political conditions prevailing in Greece.

The completion of the PSI in April 2012, in conjunction with the Program for the period 2012 - 2015 (see also Item 4.B, "Business Overview—The Macroeconomic Environment in Greece" and Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece") is expected to provide more time for economic policy to implement fiscal adjustment efforts and growth-enhancing structural reforms. At the same time, the PSI implies a significant decline of the Greek debt burden by approximately 50% of GDP, as well as a sharp reduction in debt servicing needs through low interest rates and a substantial extension of the average debt maturity. The Program also includes a comprehensive strategy for recapitalization of the banking system following PSI-related losses and the detrimental impact of a prolonged recession on bank loan quality. However, there can be no assurance that the completion of the PSI and the implementation of the Program in accordance with its terms will obtain its stated objectives or have the anticipated effects.

The Greek economy has faced and continues to face unprecedented macroeconomic headwinds originating from the still sizeable fiscal imbalances and compounded by other deep-rooted structural vulnerabilities, making the achievement of the targets posed by the Program a challenge. More specifically:

For more information about the main elements of each reform and the substantial risks to the Program, see Item 4.B, "Business Overview—The Macroeconomic Environment in Greece—The Hellenic Republic's Economic Crisis".

The uncertainty relating to the implementation of the Program and the sovereign debt reduction have directly affected the capital levels, liquidity and profitability of the financial system in the Hellenic Republic:

A failure of the Program to result in a marked improvement in the Greek economy would have significant adverse consequences on the Bank. After the completion of PSI, our holdings of Greek government bonds amount to EUR 4.8 billion, and we have additional exposure to Greek treasury bills of EUR 2.3 billion and other Greek government debt of EUR 8.8 billion. If another credit event with respect to the Greek government debt or an additional restructuring of Greek government debt were to occur, our regulatory capital would be severely affected due to our direct exposure to Hellenic Republic debt, requiring the Bank to raise additional capital and thus diluting existing shareholders significantly. Furthermore, there would be no assurance that the Bank could raise all of the required additional capital on acceptable terms.

Similar developments could be triggered by any further significant deterioration of global economic conditions, including the credit profile of other EU countries such as Ireland, Portugal or Spain or the creditworthiness of Greek or international banks. Any of these events may give rise to concerns regarding the ability of the Hellenic Republic to meet its funding needs. These developments could:

Political risks linked to the result of the parliamentary elections of May 6, 2012 create additional uncertainty about policy implementation.

Political risks linked to the result of the parliamentary elections of May 6, 2012 create additional uncertainty about policy implementation (the trio of the European Commission, the IMF and the ECB (the "Troika") has already sought political assurances from large political parties to ensure continuity in policy implementation. PASOK and New Democracy—the two largest political parties in Greece for the past 30 years, and coalition partners in the government that was in power from November 2011 to the May 6, 2012 election, under prime minister Lucas Papademos, have made public commitments to the Program objectives and key policy measures on behalf of their parties, throughout and beyond any election period. Nonetheless, potential delays in the formation of a new government post election, as well as a weak parliamentary majority of the parties supporting the Program over others that are opposed to IMF/EU support could pose significant risks to the implementation of the Program.

Recessionary pressures in Greece stemming from the Program have had and may continue to have an adverse effect on our business, results of operations and financial condition.

Our business activities are dependent on the level of banking, finance and financial products and services we offer, as well as our customers' capacity to repay their liabilities. In particular, their levels of savings and credit demand are heavily dependent on customer confidence, employment trends and the availability and cost of funding.

Following a cumulative output decline of 14% during the period 2009-2011, the cumulative decline in economic activity in 2012 and 2013 is likely to exceed 5.0%, according to Program estimates, taking a heavy toll on disposable income, spending and debt repayment capacity of the Greek private sector.

The worsening macroeconomic conditions in the Hellenic Republic are materially adversely affecting the liquidity, businesses and/or financial conditions of our borrowers, which in turn leads to further increases in our non-accruing loan ratios, impairments on our loans and other financial assets and decreased demand for borrowings in general and increasing deposit outflows.

Adding to the negative impact of a sharp drop in consumer and business confidence resulting from the economic crisis and ongoing sizeable macroeconomic imbalances, the additional fiscal adjustment agreed under the Program is likely to have a significant negative effect on economic activity in the Hellenic Republic.

Loans to businesses and households are expected to decline in Greece as the sizeable downward pressure on household disposable incomes and firms' profitability from the austerity measures, as well as the resulting deterioration in the business environment against a backdrop of tighter credit criteria and stressed liquidity conditions, are likely to impair further demand for loans. In addition, the need to reduce our dependency on Eurosystem funding will also increase the likelihood of deleveraging. Moreover, our customers may further significantly decrease their risk tolerance to non-deposit investments such as stocks, bonds and mutual funds, which would adversely affect our fee and commission income.

In the context of continued market turmoil, worsening macroeconomic conditions and increasing unemployment, coupled with declining consumer spending and business investment and the worsening credit profile of our corporate and retail borrowers, the value of assets collateralizing our secured loans, including houses and other real estate, could decline significantly. Such a decline could result in impairment of the value of our loan assets or an increase in the level of non-accruing loans, either of which may have a material adverse effect on our business, results of operations and financial condition.

Finally, if the Program is not implemented successfully—especially with respect to the ambitious structural reform agenda—or if additional austerity measures beyond those agreed to in the Program are required to counterbalance potential deviations from the Program's targets, economic activity may register a sharper than expected drop in 2012, as it did in 2011, resulting in a further delayed recovery and a further adverse effect on our business, results of operations and financial condition.

There are risks associated with the Bank's need for additional capital and liquidity, most notably from greater-than-anticipated asset impairment, as well as a higher-than-expected deterioration in asset quality.

The Bank is required by regulators in the Hellenic Republic and other countries in which it undertakes regulated activities to maintain adequate capital. Where it undertakes regulated activities elsewhere in the European Economic Area (the "EEA"), it will remain subject to the minimum capital requirements prescribed by regulators in the Hellenic Republic, except in jurisdictions where it has regulated subsidiaries, which will be subject to the capital requirements prescribed by local regulators. In jurisdictions where it has branches, including within the EEA, the Bank may also be subject to capital and liquidity requirements. The Bank and its regulated subsidiaries are, and its branches may be, subject to the risk of having insufficient capital resources to meet the minimum regulatory capital and/or liquidity requirements. In addition, those minimum regulatory capital requirements are likely to increase in the future, the methods of calculating capital resources may change. Likewise, liquidity requirements may come under heightened scrutiny, and may place additional stress on the Bank's liquidity demands in the jurisdictions in which it operates.

The Bank participated in the PSI and as a result, the Group recognized impairment on its Greek government bond portfolio and loans of EUR 10.1 billion. Furthermore, as a result of economic conditions in Greece, the Bank also impaired its non-PSI exposure to the Hellenic Republic, in an amount of EUR 0.7 billion. These impairments had an adverse effect on the Bank's capital position, resulting in losses of EUR 14.5 billion. As a result, the Group's capital adequacy ratio decreased below the minimum threshold of 8% (negative 2.6%) and requested access to the Hellenic Financial Stability Fund ("HFSF"), initially receiving a commitment from the HFSF on April 19, 2012 to participate in the Group's share capital increase for EUR 6.9 billion, which raised its total capital ratio as at December 31, 2011 to 8.3% on a pro-forma basis. The Bank will need to raise its Core Tier I capital ratio (according to the European Banking Authority (the "EBA") definition) to at least 9% from September 30, 2012, and to 10% from June 30, 2013 according to the new minimum targets set by the Bank of Greece.

The initial IMF/eurozone Stabilization and Recovery Program introduced measures in the form of the HFSF whose role was to maintain the stability of the Greek banking system by providing capital support in the form of ordinary shares or contingent convertible securities, if a significant decline in capital buffers occurs. Under the Program, the role of the HFSF was enhanced, providing it with greater oversight capacities. The HFSF has been established under Greek Law 3864/2010 and modified by Greek Laws 3870/2010, 4021/2011, 4051/2012, 4056/2012, 4063/2012 and legislative acts dated April 19, 2012 (published in the Government Gazette Issue 94/19.04.2012) and April 30, 2012 (published in the Government Gazette Issue 103/30.04.2012).

As a result of funds to be provided by the HFSF to the Bank, the HFSF may exercise significant control over the operations of the Bank and could have a material adverse effect on its profitability, capital management and financial condition. Furthermore, according to EU state aid rules and the European Commission practices, the Bank will have to develop a detailed restructuring plan or amend any such plan already submitted to the European Commission.

The terms of the new capital injected by the HFSF have not yet been fully determined. However, if the Bank does not succeed in raising at least 10%, as further specified by a Ministerial Act, of its capital shortfall from the private sector, the HFSF-sourced capital will be in the form of common equity with full voting rights, resulting in the heavy dilution of existing shareholders. If the Bank

succeeds in raising the requisite private sector funds, the recapitalization will occur through common equity with restricted voting rights, which will allow the HFSF to exercise its voting rights in the general meeting of shareholders of the Bank only for resolutions regarding modifications of its Articles of Association, including: an increase or reduction of the share capital of the Bank or provision of relevant authorization to the Board of Directors of the Bank; merger, division, conversion, revival, extension of duration or dissolution of the Bank; material asset transfers, including sale of subsidiaries; or any other matters that require an increased majority, as explicitly provided in Greek Law 2190/1920 regulating Greek sociétés anonymes. Thus, if the Bank succeeds in raising the requisite private sector funds, HFSF's shares will only be taken into account for the calculation of quorum and majority percentages for the aforementioned resolutions.

In addition, the terms and processes of the recapitalization expected to be announced by the new government to be formed, will determine the incentives of the private sector to participate in the capital raising of the Bank and thus may result in the Bank being capitalized through common equity shares, effectively resulting in its nationalization. As of the date of this annual report, the new government has not been formed, and therefore, no announcement has been made in respect of the recapitalization program.

The Bank may need to request a further capital injection from the HFSF beyond those already identified on April 19, 2012. Such a request depends on the finalization of the estimates of the recapitalization needs, which may be reduced by the capital raising plans that the Bank has submitted to the Bank of Greece.

The main risks to the Bank's recapitalization needs are: (a) the unfavorable conditions in the capital markets, which may result in lower-than-envisaged proceeds from the capital plan; (b) the poor economic environment in Greece, which may result in a sharper deterioration in asset quality than the one projected by the BlackRock loan diagnostic and weaker pre-provision profits in the domestic market; and (c) a weaker international environment, which may lead to lower-than-projected profits from our international subsidiaries. Even if the Bank initially meets the minimum capital ratio requirements, there are no assurances that the above risks will not result in subsequent shortfalls, requiring additional capital requests from the HFSF at more onerous terms.

We are currently severely restricted in our ability to obtain funding in the capital markets and are heavily dependent on the ECB and central banks for funding, which may be affected by changes in ECB and central banks rules relating to the eligibility of collateral such as Greek government bonds and guarantees.

Concerns relating to the impact of the ongoing economic crisis may adversely affect the Bank's credit risk profile, delay its return to the markets for funding, increase the cost of such funding and/or trigger additional collateral requirements in repo contracts and other secured funding arrangements, including with the ECB and central banks.

The severity of pressure experienced by the Hellenic Republic in its public finances has restricted the access of the Bank to the capital markets for funding because of concerns by counterparty banks and other lenders, particularly for unsecured funding and funding from the short-term inter-bank market. These markets have been effectively closed to all Greek banks since the end of 2009. As a result, maturing inter-bank liabilities have not been renewed, or have been renewed only at higher costs. In addition, deposit outflows beginning in late 2009, and subsequently persisting, continue to put pressure on the liquidity position of many Greek banks.

Reflecting the loss of access to market funding as well as the sharp decline in deposits, our net ECB funding and funding from other central banks has increased considerably since the start of the crisis. As at December 31, 2011, our ECB funding and funding from central banks amounted to EUR 31.3 billion (see Note 18 to the U.S. GAAP Financial Statements for the analysis of instruments pledged).

Access to ECB funding collateralized by Greek government bonds has been maintained following changes in the ECB rules. In May 2010, the ECB announced that it would suspend certain minimum credit rating requirements for Greek government bonds and would accept Greek government bonds as collateral, irrespective of their credit rating. The ECB has not yet determined the length of the period of suspension of the rating requirement. In addition, the ECB has also permitted the use of bank issued bonds, benefiting from Greek government guarantees, as eligible collateral for liquidity purposes, a rule change applying to all member countries.

The liquidity we receive from the ECB may be affected by changes in ECB rules. The amount of funding available from the ECB is tied to the value of the collateral we provide, including the market value of our holdings of Greek government bonds, which itself may decline. If the value of our assets declines, then the amount of funding we can obtain from the ECB will be correspondingly limited. In addition, if the ECB were to revise its collateral standards or increase the rating requirements for collateral securities such that these instruments were not eligible to serve as collateral with the ECB, the Group's funding costs could increase and its access to liquidity could be limited. The ECB could also place time limitations on the use of government guaranteed securities as eligible collateral, and may set conditions for the continued use of liquidity under exceptional terms. Furthermore, it is unclear how long the ECB will offer unlimited access to short-term repos. In the event that these exceptional terms are terminated, or the terms on which such access is offered change in a way which materially prejudices the Bank, our access to liquidity and funding costs could be adversely affected.

In addition, we use our covered bonds as collateral with the ECB. Our covered bonds may also become ineligible for use as collateral as a result of further credit ratings downgrades or changes in ECB rules currently permitting this collateral. A further downgrade or withdrawal of Greek sovereign ratings would likely have a material adverse effect on our ability to continue to access current levels of funding from the ECB or from any other source.

A continued loss of deposits and the concomitant need for additional Eurosystem funding may result in the exhaustion of collateral eligible for funding from the Eurosystem.

An accelerated outflow of funds from customer deposits could cause an increase in our costs of funding and have a material adverse effect on our operating results, financial condition and liquidity prospects.

Historically, one of our principal sources of funds has been customer deposits. Since we rely on customer deposits for the majority of our funding, if our depositors withdraw their funds at a rate faster than the rate at which borrowers repay their loans, or if we are unable to obtain the necessary liquidity by other means, we may be unable to maintain our current levels of funding without incurring significantly higher funding costs or having to liquidate certain of our assets, or without increasing access to the ECB under its exceptional terms. As at December 31, 2011, the Group's domestic deposits excluding interbank deposits were 17.7% lower compared to December 31, 2010 and 27.1% lower compared to December 31, 2009 due to the outflow of customer deposits during 2010 and 2011. The trend of outflowing domestic deposits has continued in 2012, in line with market outflows as reported by the Bank of Greece, for the two months period to February 2012.

The ongoing availability of customer deposits to fund the Bank's loan portfolio is subject to potential changes in certain factors outside the Bank's control, such as depositors' concerns relating to the economy in general, the financial services industry or the Bank specifically, significant further deterioration in economic conditions in Greece and the availability and extent of deposit guarantees. Any of these factors on their own or in combination could lead to a sustained reduction in the Bank's ability to access customer deposit funding on appropriate terms in the future, which would impact on the Bank's ability to fund its operation and meet its minimum liquidity requirements and have an adverse effect on the Group's results, financial condition and prospects. Unusually high levels of withdrawals could have the result that the Bank or another member of the Group may not be in a position to continue to operate without additional funding support, which it may be unable to secure.

Funding from the ECB and central banks was limited to EUR 31.3 billion as of December 31, 2011, out of which, funding needs covered through funding from the Bank of Greece, which has less strict collateral rules, are through its Emergency Liquidity Assistance ("ELA") facility.

Our independent auditors have added an explanatory paragraph to their audit opinion issued in connection with the financial statements for the years ended December 31, 2010 and 2011, respectively, with respect to their doubt about our ability to continue as a going concern, as a result of the uncertainty surrounding the completion of the recapitalization from the HFSF mainly due to political and macroeconomic developments in Greece. The going concern basis of the Bank is dependent on raising sufficient funds to restore the Group's and the Bank's financial position and maintain adequate levels of capital, as well as the Bank's continued ability to rely on liquidity facilities provided by the ECB and the Bank of Greece (collectively referred to as the "Eurosystem liquidity facilities").

Negative results in the Bank's stress testing may lead to further capital increases or loss of public confidence in the Bank.

Stress tests analyzing the European banking sector recently have been, and we anticipate that they will continue to be, published by national and supranational regulatory authorities. At present, it is not clear how the EBA stress tests will be aligned with the requirements of the Program. In the event, a loss of confidence in the banking sector following the announcement of stress tests regarding a bank or the Greek banking system as a whole, or a market perception that any such tests are not rigorous enough also could have a negative effect on the Bank's cost of funding and may thus have a material adverse effect on its results of operations and financial condition.

Greek banks may be required in the future to meet more stringent capital requirements regarding their Core Tier I capital ratios. If the Bank were to fail to meet any such new requirements by accessing the capital markets, we would be required to receive additional capital from the HFSF. As a result the HFSF could exercise significant control over our operations, which could have a material adverse effect on our business, profitability, capital management and financial performance.

Our wholesale borrowing costs and access to liquidity and capital have been negatively affected by a series of downgrades of the Hellenic Republic's credit rating.

Since 2009, the Hellenic Republic has undergone a series of credit rating downgrades and in 2010 moved to below investment grade. The credit rating of the Hellenic Republic was lowered by all three credit rating agencies to levels just above default status following the activation of collective action clauses in Greek government bonds subject to Greek law in late February 2012. Specifically, Standard & Poor's lowered the Hellenic Republic's credit rating to Selective Default-SD (February 27, 2012), Fitch lowered the Hellenic Republic's credit rating to Restricted Default-RD (March 9, 2012), and Moody's lowered the Hellenic Republic's credit rating to C (March 2, 2012). Following the conclusion of the exchange of Greek government bonds under Greek law, Fitch raised its rating to B- and Standard & Poor's raised its rating to CCC.

A further downgrade of the Hellenic Republic's rating may occur in the event of a failure to implement the Program or if the Program fails to produce sufficient results. Accordingly, the cost of risk for the Hellenic Republic would increase further, with negative effects on the cost of risk for Greek banks and thereby on their results. Further downgrades of the Hellenic Republic could result in a corresponding downgrade in the Bank's credit rating.

Deteriorating asset valuations resulting from poor market conditions may adversely affect our future earnings through a negative impact on our trading income as well as the recovery value of collateral.

An increase in financial market volatility or adverse changes in the liquidity of our assets could impair our ability to value certain of our assets and exposures. The value ultimately realized by us will depend on their fair value determined at that time and may be materially different from their current value. Any decrease in the value of such assets and exposures could require us to realize additional impairment charges, which could adversely affect our financial condition and results of operations, as well as our capital.

The global economic slowdown and economic crisis in Greece from 2009 to 2012 have resulted in an increase in non-accruing loans and significant changes in the fair values of our credit exposures. A substantial portion of our loans to corporate and individual borrowers are secured by collateral such as real estate, securities, vessels, term deposits and receivables. In particular, as mortgage loans are one of our principal assets, we are currently highly exposed to developments in real estate markets, especially in Greece. From 2002 to 2007, demand for housing and mortgage financing in Greece increased, significantly driven by, among other things, economic growth, declining unemployment rates, demographic and social trends, the desirability of Greece as a vacation destination and historically low interest rates in the eurozone. During late 2007, the housing market began to adjust in Greece as a result of excess supply and higher interest rates. In 2008 economic growth came to a halt and since 2009 economic activity has contracted at an accelerating pace. As a result, home prices began to decline, with home prices in March 2012 approximately 20% below their third quarter 2008 peak. The sharp increase in unemployment during the economic crisis, which in early 2012 exceeded 21% (compared with 7.2% in September 2008), aggravated the situation, with mortgage delinquencies increasing.

A continued decline in the Greek economy, or a deterioration of economic conditions in any industries in which our borrowers operate or in any other markets in which the collateral is located, may result in the value of collateral securing the loans falling to below the outstanding principal balance on some loans, particularly those disbursed in the few years prior to the crisis. A decline in the value of collateral securing these loans, or our inability to obtain additional collateral, may require us to establish additional allowance for loan losses. In addition, our failure to recover the expected value of collateral in the case of foreclosure, or our inability to initiate foreclosure proceedings due to domestic legislation, may expose us to losses which could have a material adverse effect on our business, results of operations and financial condition. Specifically, since July 1, 2010, Greek legislation forbids auctions initiated by credit institutions for satisfaction of claims not exceeding EUR 200,000. Greek Law 4047/2012 currently prohibits an auction process for such claims until December 31, 2012, and this period could be further extended. As at December 31, 2011, outstanding balances that could be subject to this law were EUR 365.7 million.

Under Greek Law 3723/2008, in conjunction with Greek Laws 4063/2012, 3965/2011, 3844/2010 and 3756/2009, we will not pay any cash dividends to our ordinary shareholders in 2012 in respect of the 2011 financial year, and did not do so in 2011 in respect of the 2010 financial year or in 2010 in respect of the 2009 financial year. In general, as a result of our participation in the Hellenic Republic Bank Support Plan, our dividends are subject to a maximum of 35% of the Bank's distributable profits (on an unconsolidated basis) for as long as the Bank participates in the Hellenic Republic Bank Support Plan, and any decisions regarding distribution of dividends and remuneration can be vetoed by the Hellenic Republic representative who sits on our Board of Directors.

In June 2008, we issued 25 million non-cumulative, non-voting redeemable preference shares at an issue price of USD 625 million. If the Bank has sufficient distributable funds, each preference share is

entitled to USD 2.25 per share dividend per annum paid in cash. We have not paid any dividends on our preference shares since March 2011.

Similarly, in the case of an issuance of capital from the HFSF, the HFSF's representative (who would sit on our Board of Directors) would have the power to veto any distribution of dividends, and our dividends would also be subject to a maximum of 35% of the Bank's distributable profits, according to Greek Law 3864/2010, as currently in force.

Our participation in Pillar I of the Hellenic Republic Bank Support Plan has also resulted in the issuance of fixed return preference shares to the Hellenic Republic (EUR 350 million in January 2009 and EUR 1,000 million in December 2011).

Payments of dividends on the aforementioned redeemable preference shares and payments of the fixed return for the preference shares issued pursuant to the Hellenic Republic Bank Support Plan take preference over distributable profits otherwise available to our ordinary shareholders. No dividend will be paid to holders of U.S. preferred securities or to the Hellenic Republic as holder of preference shares in 2012 for the 2011 financial year in accordance with the Bank's Articles of Association, Greek Law 4063/2012 and the provisions of article 44a in combination with articles 42c and 43 of the Greek Companies Act, which prohibit the payment of dividends in the absence of sufficient distributable funds (see Item 8.A, "Consolidated Statements and Other Financial Information—Policy on Dividend Distributions").

We are vulnerable to the ongoing disruptions and volatility in the global financial markets.

Global economic growth maintains a steady, albeit weaker than normal, pace. Nonetheless, most of the economies with which Greece has strong export links, including a number of euro area economies, continue to face significant economic headwinds. Activity remains dependent on highly accommodative macroeconomic policies and is subject to downside risks, as room for countercyclical policy measures has sharply diminished and fiscal fragilities have come to the fore. Policymakers in many advanced economies have publicly acknowledged the need to urgently adopt credible strategies to contain public debt and excessive fiscal deficits and later bring them down to more sustainable levels. The implementation of these policies may restrict economic recovery, with a corresponding negative impact on our business, results of operations and financial condition.

In financial markets, concerns surfaced in a progressive widening of intra-eurozone government bond and sovereign credit default swap ("CDS") spreads for several eurozone issuers with large fiscal imbalances. Against a background of increasing unease over the macrofinancial implications of sizeable fiscal imbalances, investors have reduced their investment in these countries. Continued reduction in investment flows may retard economic recovery, with a corresponding negative impact on our business, results of operations and financial condition, including our ability to fund our operations.

Results of operations, both in Greece and our international operations, in the past have been, and in the future may continue to be, materially affected by many factors of a global nature, including: political and regulatory risks and the condition of public finances; the availability and cost of capital; the liquidity of global markets; the level and volatility of equity prices, commodity prices and interest rates; currency values; the availability and cost of credit; inflation, the stability and solvency of financial institutions and other companies; investor sentiment and confidence in the financial markets; or a combination of these factors.

We are exposed to risks potentially faced by other financial institutions.

We routinely transact with counterparties in the financial services industry, including brokers and dealers, commercial banks, investment banks, mutual and hedge funds, and other institutional clients. Sovereign credit pressures may weigh on Greek financial institutions, limiting their funding operations

and weakening their capital adequacy by reducing the market value of their sovereign and other fixed income holdings. These liquidity concerns have negatively impacted, and may continue to negatively impact, inter-institutional financial transactions in general. Many of the routine transactions we enter into expose us to significant credit risk in the event of default by one of our significant counterparties. In addition, our credit risk may be exacerbated when the collateral we hold cannot be realized upon or is liquidated at prices not sufficient for us to recover the full amount of the loan or derivative exposure. A default by a significant financial counterparty, or liquidity problems in the financial services industry in general, could have a material adverse effect on our business, results of operations, financial condition and capital position.

Our auditor, like other independent registered public accounting firms operating in the Hellenic Republic is not permitted to be subject to inspection by Public Company Accounting Oversight Board, and as such, investors may be deprived of the benefits of such inspection.

Our independent registered public accounting firm that issues the audit reports included in our annual reports filed with the SEC, as an auditor of companies that are traded publicly in the United States and a firm registered with the Public Company Accounting Oversight Board (United States) ("PCAOB"), is required by the laws of the United States to undergo regular inspections by PCAOB to assess its compliance with the laws of the United States and professional standards. Because our auditor is located in the Hellenic Republic, a jurisdiction where PCAOB is currently unable to conduct inspections without the approval of the Greek authorities, our auditor, like other independent registered public accounting firms operating in the Hellenic Republic, is currently not inspected by PCAOB. Inspections of other firms that PCAOB has conducted outside of the Hellenic Republic have identified deficiencies in those firms" audit procedures and quality control procedures, which may be addressed as part of the inspection process to improve future audit quality. The inability of PCAOB to conduct inspections of independent registered public accounting firms operating in the Hellenic Republic makes it more difficult to evaluate the effectiveness of our auditor's audit procedures or quality control procedures. As a result, investors may be deprived of the benefits of PCAOB inspections.

Our Turkish operations make a significant contribution to our net profit, and operating in Turkey carries certain macroeconomic and political risks.

Turkish operations through Finansbank, our Turkish subsidiary, represented 19.4% of our gross loans as at December 31, 2011 compared to 18.9% as at December 31, 2010 and accounted for 30.3% net interest income before provisions for loan losses for the year ended December 31, 2011 compared to 31.9% for the year ended December 31, 2010. As a result, the Group is subject to operating risks in Turkey, including the following:

At the time of our share capital increase in September 2010, we announced plans to dispose of a minority interest in Finansbank through an offering that may comprise both primary and secondary shares. We currently intend to complete this offering when market conditions are favorable; however, our decision to proceed with the offering and its timing are subject to various considerations, including

market conditions, offer size and structure and obtaining all necessary regulatory and other approvals. A reduction in our level of ownership in Finansbank would result in a reduction in the level of Finansbank's contribution to the Group's net income/loss going forward.

Any loss in consumer confidence in Finansbank's banking operations may lead to an accelerated outflow of funds from customer deposits and could cause an increase in our costs of funding.

Historically, Finansbank's principal sources of funds have included individual deposits. All of Finansbank's individual deposits are effectively short-term deposits (the average maturity of individual deposits in 2011 was approximately 59 days), which could expose Finansbank to liquidity risks if retail customers were to withdraw large amounts of their deposits or do not roll over their term deposits upon maturity. Although customer deposits have increased rapidly in 2011 (23.4% year-on-year in TL terms), any loss in consumer confidence in Finansbank's banking operations could significantly increase the amount of individual deposit withdrawals in a short space of time or result in higher interest rates on individual deposits, which could significantly increase Finansbank's cost of funding. Finansbank also relies heavily upon other types of short-term liabilities in addition to individual deposits for its funding. As at December 31, 2011, 96% of Finansbank's other borrowed funds and long-term debt had maturity of less than one year. Given such reliance upon short-term liquidity, there can be no assurance that, in the event of a sudden or unexpected shortage of funds in the banking system or otherwise, Finansbank will be able to maintain its levels of funding and at commercially reasonable terms.

A deterioration of the credit quality of Finansbank's loans could have a material adverse effect on Finansbank's and the Group's business, results of operations and financial condition.

The 2009 economic downturn had an adverse effect on the financial condition of some of Finansbank's corporate and retail customers and, in some instances, ultimately affected their ability to service and repay their obligations. This has led to an increase in Finansbank's impaired loans that are more than 90 days past due ("dpd"), accompanied by increased allowance for loan losses. During 2010 and 2011, with output growing strongly, credit quality and recoveries improved markedly. However, over time, Finansbank has increased its exposure to retail customers, whose loans generally yield higher interest income but also tend to have higher levels of default than loans of corporate customers. There can be no assurance that continued weakness in consumer spending, high unemployment, decreased profitability of corporate businesses, increasing numbers of insolvencies and/or deterioration of the credit quality of corporate customers will not result in continued increases in the levels of Finansbank's impaired loans in the future, which could have a material adverse effect on Finansbank's and the Group's business, results of operations and financial condition.

A reduction in Finansbank's current long-term credit ratings may increase Finansbank's funding costs.

Finansbank engages in limited international capital market transactions for funding purposes. Although no specific trigger exists relating to a credit rating downgrade in any one of the outstanding agreements, a reduction in the current long-term credit ratings of Finansbank or any of its principal subsidiaries may increase Finansbank's or that subsidiary's funding costs, limit access to the capital markets and trigger additional collateral requirements in secured funding arrangements when they are renewed. In addition, any further deterioration in NBG's credit rating or any decrease in Turkey's sovereign credit rating could affect Finansbank's ability to obtain financing in international capital markets. Any reduction or deterioration in Finansbank's credit ratings could have a material adverse effect on Finansbank's and the Group's business, results of operations and financial condition.

Changes in the competitive environment in Turkey may adversely affect Finansbank's business.

The Turkish banking sector is highly competitive and has in recent years undergone a period of consolidation. As at December 31, 2011, there were a total of 44 banks (excluding the Turkish central bank and four "participation banks" (i.e. interest-free banking institutions)) licensed to operate in

Turkey. A small number of these banks have a significant presence in the industry. The intense competition may increase the pressure for Finansbank to expand the range and sophistication of its products and services it offers, as well as to reduce its margins. Increased pricing competition in the Turkish banking markets may also impact customer behavior patterns and loyalty. In addition, state-owned banks in Turkey historically have had access to inexpensive funding in the form of significant Turkish government deposits, which has provided a competitive advantage over private banks. Any failure to maintain customer loyalty or to offer customers a wide range of competitive products could have a material adverse effect on Finansbank's and the Group's business, results of operations and financial condition.

We conduct significant international activities in SEE operations, which carries certain political, governmental or macroeconomic risks.

Apart from our operations in the Hellenic Republic and Turkey, we have built up substantial operations in Bulgaria, Romania, Former Yugoslavian Republic of Macedonia ("FYROM"), Serbia and other developing economies. The Group's SEE operations accounted for 10.4% of our gross loans as at December 31, 2011 compared to 10.7% as at December 31, 2010 and 11.1% of our net interest income before provisions for loan losses at and for the year ended December 31, 2011 compared to 11.4% for the year ended December 31, 2010. Our SEE operations are exposed to the risk of adverse political, governmental or economic developments in the countries in which we operate. In addition, most of the countries outside the Hellenic Republic in which we operate are emerging markets in which we face particular operating risks. These factors could have a material adverse effect on our business, results of operations and financial condition.

Our SEE operations also expose us to foreign currency risk. A decline in the value of the currencies in which our SEE subsidiaries receive their income or hold their assets relative to the value of the Euro may have an adverse effect on our results of operations and financial condition.

We have incurred and may continue to incur significant losses on our trading and investment activities due to market fluctuations and volatility.

We maintain trading and investment positions in debt, currency, equity and other markets. These positions could be adversely affected by continuing volatility in financial and other markets and the Greek sovereign debt crisis, creating a risk of substantial losses. Significant decline in perceived or actual values of the Group's assets has resulted from previous market events. Continuing volatility and further dislocation affecting certain financial markets and asset classes could further impact the Group's results of operations, financial condition and prospects. In the future these factors could have an impact on the mark-to-market valuations of assets in the Group's AFS, trading portfolios and financial assets and liabilities for which the fair value option has been elected. In addition, any further deterioration in the performance of the assets in the Group's AFS and HTM portfolios could lead to additional other-than-temporary impairment losses, including on holdings of Greek government bonds. The AFS and HTM portfolios accounted for 9.3% of the Group's total assets as at December 31, 2011. Volatility can also lead to losses relating to a broad range of other trading securities and derivatives held, including swaps, futures, options and structured products. For further information on market risk exposures in those portfolios, you should refer to Item 11, "Quantitative and qualitative disclosures about Market Risk—Market Risk".

The increase of non-accruing loans may have a negative impact on our operations in the future.

Non-accruing loans represented 15.1% of our loan portfolio as of December 31, 2011 (compared to 8.1% as at December 31, 2010), while the same ratio for our Greek operations was 16.7% (see Item 4.E, "Selected Statistical Data—Credit Quality—Non-accruing Loans, Allowance for Loan Losses, and Loan Loss Experience" and Item 5, "Operating and Financial Review and Prospects—Key Factors Affecting our Results of Operations—Non-accruing Loans and Write-offs"). The effect of the economic crisis in Greece and adverse macroeconomic conditions in the countries in which we operate may result in further adverse effects on the credit quality of our borrowers, with increasing delinquencies and defaults. In accordance with Greek Law 3869/2010, debtors that are individuals and cannot be declared bankrupt and who are in a state of permanent inability to pay their debts not attributable to willful misconduct, have the ability to adjust their debts and may be released from a portion of such debts through filing of an application to the competent court (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece"). In order for an individual to apply to the courts under this law, the applicant is required to follow a lengthy procedure, which we believe is the principal reason why, as at December 31, 2010, no customer had applied to the courts under this law, and as at December 31, 2011, 5,930 customers, with combined outstanding balances of EUR 286 million, had applied to the court under the provisions of Greek Law 3869/2010. In addition, collateral collections are more difficult in a period of economic recession and in view of existing legislation relating to the valuation of collateral in enforcement proceedings. Moreover, as a result of the financial crisis, and for the protection of the weaker debtors, auctions have been suspended until December 31, 2012, in cases where the outstanding balance does not exceed EUR 200,000 (pursuant to legislative act dated December 12, 2011, having been ratified by Greek Law 3949/2011 (See "—Applicable bankruptcy laws and other laws and regulations governing creditors' rights in Greece and various SEE countries may limit the Group's ability to obtain payments on defaulted credit—"). As at December 31, 2010 and 2011, outstanding balances that could be subject to the abovementioned Act were EUR 121.4 million and EUR 365.7 million, respectively. Future provisions for non-accruing loans could have a materially adverse effect on our profitability.

Volatility in interest rates may negatively affect our net interest income and have other adverse consequences.

Interest rates are highly sensitive to many factors beyond our control, including monetary policies and domestic and international economic and political conditions. There can be no assurance that further events will not alter the interest rate environment in Greece and the other markets in which the Group operates. Cost of funding is especially at risk for the Bank in view of increased Eurosystem funding and the tight liquidity conditions in the domestic deposit market.

As with any bank, changes in market interest rates affect the interest rates we charge on our interest-earning assets differently than the interest rates we pay on our interest-bearing liabilities. This difference could reduce our net interest income before provisions for loan losses. Since the majority of our loan portfolio effectively re-prices within a year, rising interest rates may also result in an increase in our allowance for loan losses if customers cannot refinance in a higher interest rate environment. Further, an increase in interest rates may reduce our clients' capacity to repay in the current economic circumstances.

The general scarcity of wholesale funding since the onset of the economic crisis has led to a significant increase in competition for retail deposits in Greece. We also face competition from foreign banks, some of which may have resources greater than our own. We may not be able to continue to compete successfully with domestic and international banks in the future. These competitive pressures on the Group may have an adverse effect on our business, results of operations and financial condition.

Applicable bankruptcy laws and other laws and regulations governing creditors' rights in Greece and various SEE countries may limit the Group's ability to obtain payments on defaulted credits.

Bankruptcy laws (Greek Law 3869/2010) and other laws and regulations governing creditors' rights vary significantly within the region that the Group operates in. In some countries, the laws offer significantly less protection for creditors than the bankruptcy regimes in Western Europe and the United States. If the current economic downturn persists or worsens, bankruptcies could intensify, or applicable bankruptcy protection laws and regulations may change to limit the impact of the recession on corporate and retail borrowers. Such changes may have an adverse effect on the Group's business, results of operations and financial condition.

Changes in consumer protection laws might limit the fees that the Group may charge in certain banking transactions.

Changes in consumer protection laws in Greece, Turkey and/or other jurisdictions where the Group has operations could limit the fees that banks may charge for certain products and services such as mortgages, unsecured loans and credit cards. If introduced, such laws could reduce the Group's net income, though the amount of any such reduction cannot be estimated at this time. There can be no assurance that such effects will not have an adverse effect on our business, results of operations and financial condition.

Our business is subject to increasingly complex regulation which may increase our regulatory and capital requirements.

The Group is subject to financial services laws, regulations, administrative actions and policies in each jurisdiction in which it operates. All of these regulatory requirements are subject to change, particularly in the current market environment, where there have been unprecedented levels of government intervention and changes to the regulations governing financial institutions. In response to the global financial crisis, national governments as well as supranational groups, such as the EU, have been considering significant changes to current regulatory frameworks, including those pertaining to capital adequacy, liquidity and scope of banks' operations. As a result of these and other ongoing and possible future changes in the financial services regulatory landscape (including requirements imposed by virtue of our participation in any government or regulator-led initiatives, such as the Hellenic Republic Bank Support Plan), we may face greater regulation in the Hellenic Republic, Turkey and SEE. Current and future regulatory requirements may be different across each of these locations and even requirements with EEA-wide application may be implemented or applied differently in different jurisdictions.

Compliance with these new requirements may increase our regulatory capital and liquidity requirements and costs, heighten disclosure requirements, restrict certain types of transactions, affect our strategy and limit or require the modification of rates or fees that we charge on certain loan and other products, any of which could lower the return on the Group's investments, assets and equity. We may also face increased compliance costs and limitations on our ability to pursue certain business opportunities. The new regulatory framework may have significant scope and may have unintended consequences for the global financial system, the Greek financial system or our business, including reducing competition, increasing general uncertainty in the markets or favoring or disfavoring certain lines of business. We cannot predict the effect of any such changes on our business, financial condition, cash flows or future prospects.

Regulation of the banking industry in the Hellenic Republic has changed in recent years largely as a result of Greece's implementation of applicable EU directives and in response to the economic crisis in the Hellenic Republic. In this context:

The Basel III proposals have been assessed at EU level. The European Commission has published several consultation and other policy documents indicating its intention to implement the Basel III standards throughout the EEA by way of further changes to the Directives 2006/48/EC and 2006/49/EC and/or additional regulations. The final legislative proposals were published on July 20, 2011 (CRD 4). Commission's aim is to create for the first time a single set of harmonized prudential rules which Banks throughout the EU must respect. Commission's proposal follows the timelines as agreed in the Basel Committee: entry into force of the mew legislation on January 1, 2013 and full implementation on January 1, 2019.

The Solvency II Directive (Directive 2009/138/EC), adopted by the European Parliament on April 22, 2009 and endorsed by the Council of Ministers on May 5, 2009, is a fundamental review of the capital adequacy regime for the European insurance industry. When implemented (expected to be on January 1, 2014) the capital structure and overall governance of the Group's life assurance business will change significantly, and this may have an impact on the capital structure of the Group.

Finansbank is subject to a number of banking and other regulations in Turkey, in particular those of the Banking Regulation and Supervision Agency of Turkey ("BRSA"). Banking regulations in Turkey are evolving in parallel to the global changes and international regulatory environment. The Turkish regulator has announced a roadmap for Basel II implementation starting from June 2011. Banks in

Turkey report their results according to both Basel I and Basel II, and after June 2012 only Basel II will be used.

The loss of senior management may adversely affect our ability to implement our strategy.

Our current senior management team includes a number of executives that we believe contribute significant experience and expertise to our management in the banking sectors in which we operate. The continued success of our business and our ability to execute our business strategy will depend, in large part, on the efforts of our senior management. For instance, a change of government in the Hellenic Republic could lead to the departure of certain senior managers. If a substantial portion of our senior management leaves us, our business may be materially adversely affected.

We may be unable to recruit or retain experienced and/or qualified personnel.

Our competitive position depends, in part, on our ability to continue to attract, retain and motivate qualified and experienced banking and management personnel. Competition in the Greek and other SEE banking industries for personnel with relevant expertise is intense due to the relatively limited availability of qualified individuals. To recruit qualified and experienced employees and to minimize the possibility of their departure, we provide compensation packages consistent with evolving standards in the relevant labor markets. Under the terms of the Hellenic Republic Bank Support Plan, as currently applicable, the Bank is prohibited from paying bonuses to the members of the Board of Directors, the Chief Executive Officer and any general managers or their substitutes. Furthermore, as a result of the economic crisis and regulatory restrictions on bonus payments, we are limiting or restricting the bonuses we pay our personnel, which may inhibit the retention and recruitment of qualified and experienced personnel. However, inability to recruit and retain qualified and experienced personnel in the Hellenic Republic, Turkey and SEE, or manage our current personnel successfully, could have a material adverse effect on our business, results of operations, financial condition and prospects. This risk has increased in view of the current economic situation in Greece.

We could be exposed to significant future pension and post-employment benefit liabilities.

Like other large companies in the Hellenic Republic that are, or were, in the public sector, the employees of the Bank and certain of our subsidiaries participate in employee-managed pension schemes. The Bank and certain of our subsidiaries make significant contributions to these schemes. In addition, the Bank and several of our subsidiaries offer other post-employment benefit plans, including medical benefit plans. Our consolidated net liability under these plans as of December 31, 2011 was EUR 224.7 million, determined by reference to a number of critical assumptions. These include assumptions about movements in interest rates which may not be realized. Such variation may cause us to incur significantly increased liability in respect of these obligations. For more information on our current obligations under pension plans and the assumptions by reference to which they are determined, please refer to Note 38 to the U.S. GAAP Financial Statements.

In accordance with Greek Law 3655/2008, applicable from April 2008, the Bank's main pension plan and the main pension branch of Ethniki Hellenic General Insurance S.A.'s ("EH") post-employment and health plan, both of which are defined-contribution plans, have been incorporated into the main pension branch of the state-sponsored social security fund ("IKA - ETAM"). Pursuant to this legislation, the Bank will contribute into IKA - ETAM EUR 25.5 million per year for 15 years starting from December 2009.

In addition, in 2005 and 2006, the Hellenic Republic passed legislation permitting bank employee auxiliary pension schemes to merge with the new Insurance Fund of Bank Employees ("ETAT"). The relevant legislation provides that, in connection with the merger of auxiliary schemes with ETAT, the relevant employer shall make a payment to ETAT solely in an amount to be determined by an

independent financial report commissioned by the Ministry of Finance pursuant to this legislation. Subsequently, in April 2006 the Bank applied under Greek Law 3371/2005, as amended, to merge its Auxiliary Pension Fund into ETAT. Consequently, the Bank may have to contribute a significant amount to ETAT in relation to this merger.

In addition, Greek Law 3863/2010 amended substantially the structure and operation of the Greek pensions system. These developments, as well as future interpretations of existing laws and any future legislation regarding pensions and pension liabilities or other post-employment benefit obligations, including those under the Program may increase the liability of the Bank or its subsidiaries with respect to pension and other post-employment benefit plan contributions to cover actuarial or operating deficits of those plans.

The Greek banking sector is subject to strikes which may adversely affect the Group's operations.

Most of the Bank's employees belong to a union and the Greek banking industry has been subject to strikes over the issues of pensions and wages. Bank employees throughout the Hellenic Republic went on strike for 14 days in 2011. In 2012, Bank employees have gone on strike four days (through April 30, 2012), largely to express their opposition to the new austerity measures implemented in light of the Program. Greek bank unions in general participate in general strikes which have increased. Prolonged labor unrest could have a material adverse effect on the Bank's operations in the Hellenic Republic, either directly or indirectly, for example on the willingness or ability of the government to pass the reforms necessary to successfully implement the Program.

The value of certain financial instruments recorded at fair value is determined using financial models incorporating assumptions, judgments and estimates that may change over time or may not be accurate.

In establishing the fair value of certain financial instruments, the Group relies on quoted market prices or, where the market for a financial instrument is not sufficiently active, internal valuation models that utilize observable financial market data. In certain circumstances, the data for individual financial instruments or classes of financial instruments utilized by such valuation models may not be available or may become unavailable due to changes in financial market conditions. In such circumstances, the Group's internal valuation models require the Group to make assumptions, judgments and estimates to establish fair value. In common with other financial institutions, these internal valuation models are complex, and the assumptions, judgments and estimates the Group is required to make often relate to matters that are inherently uncertain, such as expected cash flows. Such assumptions, judgments and estimates may need to be updated to reflect changing facts, trends and market conditions. The resulting change in the fair values of the financial instruments could have a material adverse effect on the Group's earnings and financial condition. Also, recent market volatility and illiquidity has challenged the factual bases of certain underlying assumptions and has made it difficult to value certain of the Group's financial instruments. Valuations in future periods, reflecting prevailing market conditions, may result in changes in the fair values of these instruments, which could have a material adverse effect on the Group's results, financial condition and prospects.

We are exposed to credit risk, market risk, liquidity risk, operational risk and insurance risk.

As a result of our activities, we are exposed to a variety of risks. Among the most significant of these risks are credit risk, market risk, liquidity risk, operational risk and insurance risk. Failure to control these risks could result in material adverse effects on our financial performance and reputation.

Credit Risk. Credit risk is the risk of financial loss relating to the failure of a borrower to honor its contractual obligations. It arises in lending activities as well as in various other activities where we are exposed to the risk of counterparty default, such as our trading, capital markets and settlement

activities. The risk of counterparty default is the largest single risk we face. Credit risk has increased significantly since September 2007.

Market Risk. Market risk is due to the uncertainty arising out of volatility in market prices and rates (including interest rates, equity and bond prices and foreign exchange rates). Changes in interest rate levels, yield curves and spreads may affect our net interest margin. Changes in currency exchange rates affect the value of assets and liabilities denominated in foreign currencies and may affect income from foreign exchange dealing. The performance of financial markets or financial conditions generally may cause changes in the value of our investment and trading portfolios. We have implemented risk management methods to mitigate and control these and other market risks to which our portfolios are also exposed (see Item 11 "Quantitative and Qualitative Disclosures about Market Risk"). However, it is difficult to predict with accuracy changes in economic or market conditions and to anticipate the effects that such changes could have on our financial performance and business operations.

Liquidity Risk. Liquidity risk is defined as the current or prospective risk to earnings and capital arising from the an entity's inability to meet its liabilities when they come due without incurring unacceptable losses. It reflects the potential mismatch of payment obligations to incoming payments, taking into account unexpected delays in repayments (term liquidity risk) or unexpectedly high payment outflows (withdrawal/call risk). Liquidity risk involves both the risk of unexpected increases in the cost of funding a portfolio of assets at appropriate maturities and rates, and the risk of being unable to liquidate a position in a timely manner on reasonable terms. The severity of pressure experienced by the Hellenic Republic in its public finances has restricted the access to markets for the Bank, which currently relies almost entirely on the ECB and central banks (see "—Risks Relating to the Hellenic Republic Economic Crisis—We are currently severely restricted in our ability to obtain funding in the capital markets and are heavily dependent on the ECB and central banks for funding and liquidity, which may be affected by changes in ECB and central banks rules relating to the eligibility of collateral such as Greek government bonds and guarantees", Item 5.B "Liquidity and Capital Resources" and Item 11"Quantitative and Qualitative Disclosures about Market Risk").

Operational Risk. Operational risk corresponds to the risk of loss due to inadequate or failed internal processes, or due to external events, whether deliberate, accidental or natural occurrences. Internal events include, but are not limited to, fraud by employees, clerical and record keeping errors and information systems malfunctions or manipulations. External events include floods, fires, earthquakes, riots or terrorist attacks, fraud by outsiders and equipment failures. Finally, we may also fail to comply with regulatory requirements or conduct of business rules.

Insurance Risk. The principal risk that the Group may face under its insurance policies is that the actual claims and benefit payments, or the timing thereof, differ from expectations. This could occur because the frequency or severity of claims is greater than estimated. Depending on the insurance product, this risk is influenced by macroeconomic changes, changes in customer behavior, changes in public health, pandemics and catastrophic events such as earthquakes, industrial disasters, fires, riots or terrorism.

Although the Bank believes that its risk management and risk mitigation policies are adequate, our risk management processes may not prevent all instances of fraud. In addition, continuing volatility as a result of market forces out of our control could cause the Bank's liquidity position to deteriorate. Such deterioration would increase funding costs and limit the Bank's capacity to increase its credit portfolio and the total amount of its assets, which could have a material adverse effect on the Bank's business, results of operations and financial condition.

We plan to limit our dependence on official support through the implementation of a capital plan already submitted to the Bank of Greece, for their approval. This capital plan includes a disposal of a minority stake in our subsidiary Finansbank, of which we own 94.81%, through an offering that may comprise both primary and secondary shares. We currently intend to complete this offering when market conditions are favorable; however, our decision to proceed with the offering and its timing are subject to various considerations, including market conditions, offer size and structure and obtaining all necessary regulatory and other approvals. NBG intends to retain a majority equity stake in Finansbank of at least 75%.

In addition, we are considering the sale of a minority stake in a new subsidiary, currently in the process of being formed, to which we will transfer our SEE banking subsidiaries. Our decision to proceed with these offerings, as well as their related timing, are subject to various considerations, including market conditions, offer size and structure and our obtaining all necessary regulatory and other approvals. Further capital could be raised from the sale of non-core assets, which may include the Astir Palace Hotel, the bancassurance business in Turkey, as well as further initiatives in the area of asset and liability management.

The successful implementation of these transactions is subject to market conditions. Should market unfavorable market conditions prevail, the completion of the capital plan could be delayed, may fail to achieve its objectives or may not be consummated.

If any of the variety of instruments and strategies that we use to economically hedge our exposure to market risk is not effective, we may incur losses. Many of our strategies are based on historical trading patterns and correlations. Unexpected market developments therefore may adversely affect the effectiveness of our hedging strategies. Moreover, we do not economically hedge all of our risk exposure in all market environments or against all types of risk. For example, we are exposed to TL fluctuations and do not always economically hedge this exposure. Finally, the methodology by which certain risks are economically hedged may not qualify for hedge accounting, which may result in additional volatility in the Group's income statement. We have not hedged the sovereign credit risk of the Hellenic Republic.

The Bank's operational systems and networks have been, and will continue to be, vulnerable to an increasing risk of continually evolving cybersecurity or other technological risks which could result in the disclosure of confidential client or customer information, damage to the Bank's reputation, additional costs to the Bank, regulatory penalties and financial losses.

A significant portion of the Bank's operations relies heavily on the secure processing, storage and transmission of confidential and other information as well as the monitoring of a large number of complex transactions on a minute-by-minute basis. The Bank stores an extensive amount of personal and client-specific information for its retail, corporate and governmental customers and clients and must accurately record and reflect their extensive account transactions. These activities have been, and will continue to be, subject to an increasing risk of cyber attacks, the nature of which is continually evolving.

The Bank's computer systems, software and networks have been and will continue to be vulnerable to unauthorized access, loss or destruction of data (including confidential client information), account takeovers, unavailability of service, computer viruses or other malicious code, cyber attacks and other events. These threats may derive from human error, fraud or malice on the part of employees or third parties, or may result from accidental technological failure. If one or more of these events occurs, it could result in the disclosure of confidential client information, damage to the Bank's reputation with

its clients and the market, additional costs to the Bank (such as repairing systems or adding new personnel or protection technologies), regulatory penalties and financial losses, to both the Bank and its clients and customers. Such events could also cause interruptions or malfunctions in the operations of Bank (such as the lack of availability of the Bank's online banking system), as well as the operations of its clients, customers or other third parties. Given the volume of transactions at the Bank, certain errors or actions may be repeated or compounded before they are discovered and rectified, which would further increase these costs and consequences.

In addition, third parties with which the Bank does business under stringent contractual agreements, may also be sources of cyber security or other technological risks. The Bank outsources a limited number of supporting functions, such as printing of customer credit card statements, which results in the storage and processing of customer information. Although the Bank adopts a range of actions to eliminate the exposure resulting from outsourcing, such as not allowing third-party access to the production systems and operating a highly controlled IT environment, unauthorized access, loss or destruction of data or other cyber incidents could occur, resulting in similar costs and consequences to the Bank as those discussed above.

While the Bank maintains insurance coverage that may, subject to policy terms and conditions, cover certain aspects of cyber risks such as fraud and financial crime, such insurance coverage may be insufficient to cover all losses.

The Hellenic Republic and state-related entities may have an important influence on the Bank.

In 2008, the Greek Parliament approved the Hellenic Republic Bank Support Plan, in response to the difficult funding conditions in 2008. The Greek Parliament originally approved for EUR 28 billion in 2008 and augmented the Hellenic Republic Bank Support Plan by EUR 40 billion in 2010 and another EUR 30 billion in 2011. The Hellenic Republic Bank Support Plan, as amended, comprised three tranches or pillars:

As at April 27, 2012, the Hellenic Republic directly owns all 270 million non transferable redeemable preference shares issued by NBG under the capital facility of the Hellenic Republic Bank Support Plan. This direct stake in NBG provides the Hellenic Republic with voting rights at the general meeting of preferred shareholders and requires the participation on the Board of Directors of NBG of a Government appointed representative, who attends the General Meeting. In certain circumstances, this representative has the ability to veto actions relating to strategic issues or decisions for which the General Meeting is otherwise competent, such as the distribution of dividends and the remuneration of NBG's directors and senior management. By its letter dated October 11, 2010 regarding NBG's rights offering initiated by the September 10, 2010 decision of its Board of Directors, the Hellenic Republic exercised in full its pre-emptive right arising from its holding of preference shares to subscribe for new shares and convertible equity notes that would not be subscribed for by holders of rights and their transferees, equal to approximately 10.3%. Consequently, the Hellenic Republic directly holds 1.23% of the Bank's ordinary shares. (see Item 4.B, "Information on the Company—Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic Bank Support Plan"). NBG also participates in the Pillar II and Pillar III of the Hellenic Republic Bank Support Plan.

In addition, the Hellenic Republic may exercise a degree of indirect influence on us, through certain state-related entities (primarily pension funds, most of whose boards of directors are appointed by the Hellenic Republic). As of December 31, 2011, various domestic pension funds owned approximately 16.4% of our share capital, and other domestic public sector related legal entities and the Church of Greece owned approximately 7.5% of our share capital. If there is not a full voting participation by all of our other shareholders at a given shareholders' meeting, these state-related entities, despite holding a non-controlling level of our total shares, may have a voting majority at such meeting (see Item 7.A, "—Major Shareholders—State Interests").

There is a risk that the Hellenic Republic might seek to exert influence over the Group and may disagree with certain decisions of the Bank and the Group relating to dividend distributions, benefits policies and other commercial and management decisions which may ultimately limit the operational flexibility of the Group.

If economic conditions do not improve or continue to deteriorate, or if the financial position of the Group deteriorates, further government or inter-governmental intervention may take place in addition to the amounts already contemplated through the HFSF. Any further government or inter-governmental intervention, including through the HFSF, may have a material adverse effect on the interests of other holders of our securities, results of operations and financial condition. Capital shares issued under the HFSF will provide it with significant management powers (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece").

Furthermore, the Hellenic Republic also has interests in other Greek financial institutions and an interest in the health of the Greek banking industry and other industries generally, and those interests may not always be aligned with the commercial interests of the Group or its shareholders. An action supported by the Hellenic Republic may not be in the best interests of the Group or its shareholders generally.

In the current economic environment, our Greek loan portfolio may continue to decline, and our foreign loan portfolio may not grow at historic rates or may even decline. Furthermore, there are a limited number of high credit quality customers to whom banking services may be provided in our target markets. Developments in our loan portfolio will be affected by, among other factors, the health of the Greek economy in light of the economic crisis and the Program. The continuing decline in our loan portfolio, in combination with non-performing loans, may limit our net interest income, and this could have a material adverse effect on our business, results of operations and financial condition.

Due to the uncertainty regarding the success of the Program, new taxes may be imposed on the Group, such as the "one-off" taxation on profitable companies, and existing taxes may be increased. In 2010, the Group was subject to a EUR 79.1 million windfall tax, which comprised of a tax on 2009 earnings of EUR 26.1 million and a reversal of a tax credit from withholding tax of EUR 53.0 million relating to interest income from bonds. In addition, at the European Council Summit held on June 17, 2010, representatives agreed that member states should introduce a system of levies and taxes on financial institutions to promote an equitable distribution of the costs of the global financial crisis. Any additional taxes imposed on us in the future may have a material adverse effect on our business, results of operations and financial condition.

In connection with the restatement of our previously reported financial statements, we may be subject to the risk of litigation or regulatory proceedings or actions.

We have restated our previously reported financial statements for the years ended December 31, 2007, 2008, 2009 and 2010 as described in detail in Note 43 to the U.S. GAAP Financial Statements. Consequently, we may be subject to class action lawsuits or regulatory proceedings or actions relating to the restatement of our financial statements. We may incur substantial legal and accounting expenses in connection with the restatement. In addition, should any litigation or regulatory actions occur, it may be time consuming and distract certain management personnel from performing their daily operational duties.

Material weakness in our disclosure controls and procedures could negatively affect shareholder and customer confidence towards our financial reporting and other aspects of our business.

As described above, we have restated our previously reported financial statements for the years ended December 31, 2007, 2008, 2009 and 2010, as described in detail in Note 43 to the U.S. GAAP Financial Statements.

The Public Company Accounting Oversight Board's Auditing Standard No. 5—"An Audit of Internal Control Over Financial Reporting that is integrated with An Audit of Financial Statements" specifies that the restatement of previously reported financial statements to reflect the correction of a misstatement should be regarded as at least a significant deficiency and as a strong indicator that a material weakness in internal control over financial reporting exists. We considered this guidance, applied our judgment in assessing the reason why a restatement was necessary, taking into account the high uncertainty created by the rapidly evolving economic crisis in Greece and concluded that a material weakness in our internal control over financial reporting existed with regards to the credit value adjustment following the revision of our assumption methodology relating to the impact on the Group of credit risk on derivatives (for both counterparty and own risk) and that, as a result, our disclosure controls and procedures were not effective as of December 31, 2011. See Item 15 "Controls and Procedures—Management's Annual Report on Internal Control over Financial Reporting".

The existence of that material weakness could negatively affect shareholder and customer confidence towards our financial reporting and other aspects of our business. Furthermore, further and continued determinations that there are material weaknesses in the effectiveness of our material controls would also reduce our ability to obtain financing or could increase the cost of any financing we obtain and require additional expenditures of both money and management's time to comply with applicable requirements. We have initiated remedial steps to address this material weakness in our internal control over financial reporting.

Exchange rate fluctuations could have a significant impact on the value of our shares.

The market price of our shares traded on the ATHEX is denominated in euros. Fluctuations in the exchange rate between the euro and other currencies may affect the value of the Bank's shares in the local currency of investors in the United States and other countries that have not adopted the euro as their currency. Additionally, any cash dividends on our ordinary shares are paid in euros and, therefore, are subject to exchange rate fluctuations when converted to an investor's local currency, including U.S. dollars.

The principal trading market for our ordinary shares is the ATHEX. The ATHEX is less liquid than other major stock markets in Western Europe and the United States. As a result, shareholders

may have difficulty assessing the past performance of the ordinary shares based on our prior trading record on the ATHEX. In 2011, the average daily trading value on the ATHEX was approximately EUR 82.4 million, while in the first four months of 2012 it was approximately EUR 54.1 million. In comparison, the average daily trading value on the London Stock Exchange was approximately GBP 3.7 billion in 2011.

As at December 30, 2011, the aggregate market value of all shares listed on the ATHEX was approximately EUR 27.5 billion, while as at April 30, 2012 it was approximately EUR 27.5 billion. The market value of our ordinary shares listed on the ATHEX on December 30, 2011 and April 30, 2012, was EUR 1.5 billion and EUR 1.6 billion, representing approximately 5.6% and 5.8%, respectively, of the capitalization of all companies listed on the ATHEX. We cannot make assurances about the future liquidity of the market for our shares.

The market price of our shares has been subject to significant volatility in the past, and could be subject to wide fluctuations in response to numerous factors, many of which are beyond our control. These factors include the following:

For the annual high and low market prices of the Bank's shares on the ATHEX for the five most recent financial years see Item 9.A, "Offer and Listing Details".

The exercise of pre-emptive rights may not be available to U.S. holders of the Bank's ordinary shares and American Depositary Receipts.

Under Greek law and our Articles of Association, prior to the issuance of any new ordinary shares, we must offer holders of our existing ordinary shares pre-emptive rights to subscribe and pay for a sufficient number of ordinary shares to maintain their existing ownership percentages. These pre-emptive rights are generally transferable during the rights trading period for the related offering and may be traded on the ATHEX.

Holders in the United States of the Bank's ordinary shares and American Depositary Shares evidenced by ADRs may not be able to exercise pre-emptive rights for any such offering of shares unless a registration statement under the U.S. Securities Act of 1933, as amended ("Securities Act"), is effective with respect to such rights or an exemption from the registration requirements of the Securities Act is available. Our decision to file a registration statement with respect to any future offering will depend on the costs and potential liabilities associated with any such registration statement, as well as the perceived benefits of enabling U.S. holders of ordinary shares and ADRs to exercise their pre-emptive rights and any other factors we may consider appropriate at the time.

If holders in the United States of the Bank's ordinary shares and ADRs are not able to exercise pre-emptive rights granted in respect of their shares in any rights offering by us, they might not receive the economic benefit of such rights. In addition, their proportional ownership interests in the Bank will be diluted.

National Bank of Greece S.A. was founded in 1841 and incorporated as a société anonyme pursuant to Greek law. Our current corporate form will expire on February 27, 2053, but may be further extended by a shareholder resolution passed at the General Meeting. The Bank's headquarters and our registered office are located at 86 Eolou Street, 10232 Athens, Greece. The telephone number of the Bank is (+30) 210 334 1000. The Bank's agent for service of process in the United States is Corporation Service Company, 1180 Avenue of the Americas, Suite 210, New York, NY 10036.

The Bank has operated a commercial banking business for 171 years. Since our founding, our business has expanded to become a large, diversified financial services group. As part of our diversification, the Bank founded EH in 1891. Until the establishment of the Bank of Greece as the central bank of Greece in 1928, the Bank, in addition to commercial banking activities, was responsible for issuing currency in Greece.

In 2006, we undertook our largest international acquisition to date. On August 18, 2006, we acquired 46% of the ordinary shares and 100% of the founder shares in Finansbank, a commercial and retail bank in Turkey, from Fiba Holding A.S., Fina Holding A.S., Girisim Factoring A.S. and Fiba Factoring Hizmetleri A.S. (together, the "Fiba Sellers") for a consideration of US$2,323 million and US$451 million for ordinary shares and founder shares, respectively. In order to finance our acquisition of Finansbank, we increased our share capital through a rights issue in July 2006 by payment in cash with pre-emptive rights to our existing shareholders at a ratio of four new shares for every ten shares. The Fiba Sellers retained a residual stake of 9.68% in the ordinary share capital of Finansbank, which was subject to a call option exercisable by us, and a put option (to us) exercisable by the Fiba Sellers for a period of two years commencing on the second anniversary of the initial acquisition. As a result of Turkish capital markets legislation, the Bank made a mandatory offer to the minority shareholders of Finansbank. During the mandatory tender offer period between January 8 and January 29, 2007, the Bank acquired a further 43.44% of Finansbank's outstanding ordinary shares, for a consideration of EUR 1,733 million, through the Istanbul Stock Exchange ("ISE"). On April 5, 2007, we disposed of 5% of Finansbank's share capital to the International Finance Corporation ("IFC"). This shareholding remains subject to a call option exercisable by us, and a put option (to us) exercisable by the IFC within seven years (See Item 10.C, "Material Contracts"). Following the completion of the mandatory tender offer and the sale of shares to the IFC, we have proceeded to acquire further outstanding ordinary shares in Finansbank. On August 19, 2008, we accepted the proposal of Fiba Holding to acquire the remaining shares of Finansbank held by the Fiba Sellers (9.68%). The exercise price was determined in accordance with the agreement and amounted to US$697 million. Currently we hold 94.81% of Finansbank's outstanding share capital (a 5% stake held is by the IFC and subject to the put and call options). Non-controlling interests ("NCI") that are subject to put options held by third parties are accounted for as described in Note 3 to the U.S. GAAP Financial Statements.

Since March 2009, the Bank consolidates Titlos Plc, a variable interest entity established in the UK, for the purpose of the securitization of Greek State loans and receivables, in which the Bank has a beneficial interest;

On May 19, 2009, the Bank established Ethniki Factors S.A., a wholly owned subsidiary.

On June 8, 2009, Finansbank established Finans Faktoring Hizmetleri A.S., (Finans Factoring) a wholly owned subsidiary.

In June 2009, the Bank participated in the one-for-one share capital increase in the Hellenic Postal Savings Bank (PSB), thus acquiring 9,420,000 new shares in PSB. Furthermore, during 2009 the Bank acquired additional 200,000 shares, via the ATHEX, raising its total shareholding to 6.69%.

On July 31, 2009, the Bank and TOMI S.A. of ELLAKTOR Group entered into a private agreement to acquire joint control of AKTOR FM, through the Bank's acquisition of a non-controlling interest in AKTOR FM. On January 18, 2010, the Bank acquired 53,846 new ordinary registered shares at their nominal value of EUR 3.0 per share, paying a consideration of EUR 161.5 thousand each in cash and currently owns 35% of the share capital.

In September 2009 the Bank established NBG Pangaea Real Estate Investment Company ("NBG Pangaea"), a newly formed real estate investment company wholly owned by the Bank. NBG contributed to NBG Pangaea 241 properties, in lieu of cash for share capital. The net book value of these properties as at December 31, 2009 was EUR 164.8 million.

On September 15, 2009, the Group disposed of its investment in Phosphoric Fertilizers Industry S.A. for a consideration of EUR 18.9 million, of which EUR 2.6 million has been deposited in an escrow account up to September 15, 2011, to set off contingent liabilities. Up to September 15, 2011, no contingent liability had arisen and the escrow account was subsequently released. The loss on sale for the Group was EUR 10 million.

On October 14, 2009, the Bank partially participated in the share capital increase of its associate Larco S.A. The Bank's contribution amounted to EUR 20.5 million and after the completion of the share capital increase, the Bank's participation was reduced from 36.43% to 33.36%.

On October 16, 2009, United Bulgarian Bank (UBB) established UBB Factoring EOOD, a wholly owned subsidiary of UBB.

On January 14, 2010, an extraordinary General Meeting of the Bank approved the contribution of real estate property of the Bank with a carrying amount of EUR 168.4 million to NBG Pangaea.

On August 17, 2010, the Bank acquired 21.6% of Stopanska Banka AD—Skopje, from European Bank for Reconstruction and Development ("EBRD") and IFC, possessing 10.8% shareholding each, through put and call arrangements as provided for in the 2001 shareholders agreement, between the Bank and EBRD and IFC, for the acquisition of Stopanska Banka AD—Skopje. The total consideration paid amounted to EUR 35.2 million.

On September 3, 2010, Banca Romaneasca S.A. established NBG Factoring Romania IFN S.A. Banca Romaneasca S.A. owns 99% and NBG Leasing IFN S.A. owns 1% of the new company.

On November 4, 2010, following a decision of Finansbank's Board of Directors on August 2, 2010, the share capital of the Finansbank was increased by TL 551.3 million (TL 547.1 million in cash and TL 4.1 million by capitalization of reserves). The cash contribution by the Group amounted to TL 518.7 million and covered by the proceeds from repayment by Finansbank of subordinated debt amounting to TL 495.8 million (USD 325 million) and cash payments by the reinvestment of the dividend received TL 22.9 million.

During December 2010, Finans Invest acquired 5.11% of Finans Finansal Kiralama A.S. (Finans Leasing), a listed subsidiary company in ISE, from the market with a cost of TL 20.5 million. Prior to this, on August 13, 2010, the Bank had increased its shareholding in Finans Leasing, through a public offer, pursuant to which the Bank acquired 27.3% of the share capital for EUR 42.3 million (TL 81.7 million). After these acquisitions the NBG Group owns 90.9% of Finans Leasing.

On June 29, 2011, the Bank acquired 49.9% of CPT Investments Ltd from Credit Suisse A.G. The total consideration amounted to EUR 587.8 million of which amount of EUR 42.9 million was paid in cash. The remaining amount of EUR 544.9 million related to waiver of debt from Credit Suisse A.G.

On September 19, 2011 the Bank established the variable interest entity SPITI PLC in the UK, for the securitization of mortgage loans in which the Bank has a beneficial interest.

On September 22, 2011 the Bank established the variable interest entity AGORAZO PLC in the UK, for the securitization of consumer loans in which the Bank has a beneficial interest.

On September 22, 2011 the Bank established the variable interest entity AUTOKINITO PLC in the UK, for the securitization of car loans in which the Bank has a beneficial interest.

On December 12, 2011, following a decision of Finansbank's Board of Directors of August 4, 2011, the share capital of the Finansbank was increased by TL 120.0 million (TL 116.3 million in cash and TL 3.7 million by capitalization of reserves). The cash contribution by the Group amounted to TL 110.3 million and was covered by the reinvestment of the dividend received.

During 2011 Finansbank disposed of 20.88% of its participation in Finans Yatirim Ortakligi A.S. (Finans Investment Trust) for TL 5.0 million. Prior to this, in April 2010, Finansbank had disposed of 10.73% of its participation in Finans Investment Trust for TL 2.7 million. After these transactions the Group owns 52.1% of the entity.

The table below sets out the Group's principal items of capital expenditure for 2009, 2010 and 2011.

Also, as part of our strategy to streamline our operations, we continue to divest, if market conditions are favorable, non-core equity investments and real estate assets that are unrelated to our principal financial services business and to commit these released resources to more profitable activities.

The table below sets out the Group's principal divestitures for 2009, 2010 and 2011.

The Bank is our principal operating company, representing 67.5% of our total assets as at December 31, 2011. The Bank's liabilities represent 76.4% of our total liabilities as at December 31, 2011. While the Bank conducts most of our banking activities, it is supported by eight non-Greek banking subsidiaries: Finansbank A.S. ("Finansbank"), United Bulgarian Bank AD—Sofia ("UBB"), Vojvodjanska Banka A.D. Novi Sad ("Vojvodjanska"), Banca Romaneasca S.A. ("Banca Romaneasca"), Stopanska Banka A.D.—Skopje ("Stopanska Banka"), the National Bank of Greece (Cyprus) Ltd. ("NBG Cyprus"), South African Bank of Athens Ltd. ("SABA") and NBG Bank (Malta) Ltd. ("NBG Malta"). We intend to continue to expand our operations in SEE and the Southeastern Mediterranean region when conditions permits it.

We hold leading positions in many financial services products in Greece. As at December 31, 2011, we had the largest market share of deposits and mortgage loans in Greece, with 30.8% in core deposits and 25.1% in mortgage lending, respectively, according to our internal analysis of published information of the Bank of Greece and other Greek banks. We are also strongly positioned in consumer and credit card lending, where, according to our internal analysis of information published by the Bank of Greece, we are first with a market share of 19.2% as at December 31, 2011. We are also second in mutual fund management with a market share of 17.4% as at the same date according to Hellenic Fund and Asset Management Association.

For a breakdown of our total revenues by category of activity and geographic market, see Item 5.A, "Operating Results—Segment Information".

Most of our banking business is domestic and includes retail, corporate and investment banking. The Group's Greek banking operations account for 69.9% of our total lending activities as at December 31, 2011 the ("Greek Banking Loans" and "Greek Banking Deposits"). Banking activities in Greece includes the Bank's domestic operations, Ethniki Leasing S.A. ("Ethniki Leasing") and Ethniki Factors S.A. ("Ethniki Factors"). In this section, "—Banking Activities in Greece", financial information pertaining to the Bank relates to banking activities in Greece.

The following table sets forth details of the Greek Banking loans and deposits as at December 31, 2011:

We believe that the Bank has a significant advantage in attracting domestic deposits from retail and corporate clients due to the:

The chart below indicates the fluctuations in Greek Banking loans and Greek Banking deposits excluding interbank deposits attributable to the Bank from December 31, 2009 through December 31, 2011.

As at December 31, 2011, we operated in Greece through 539 branches, one private banking unit, one unit for financial institutions and seven specialized banking units that deal exclusively with troubled and non-performing loans. As at December 31, 2011, we had 1,398 ATMs, of which at least 573 were situated in key locations such as supermarkets, metro stations, shopping centers, hospitals and airports (42% of our ATMs are equipped with cash deposit devices). During 2011, the total number of ATM transactions reached approximately 101 million with a total value of approximately EUR 18 billion. In addition, we have developed alternative distribution channels, such as an e-banking platform targeted at both corporate and retail clients. During 2011, the total number of phone and internet banking users increased by 13%, reaching approximately 574 thousand, out of which 364 thousand were also phone banking users. The total number of electronic transactions during 2011 was approximately 44.7 million with a total value of approximately EUR 17 billion. We operate a contact center, through which the Bank provides information and transaction services through the use of a voice portal and a manned help desk, which began operation in 2007. In 2011, we launched three new "i-bank" stores (two in Athens and one in Thessaloniki) which offer all i-bank services (internet, mobile and phone banking, ATM and APS) and where we also host entertainment and educational events. In their first year of operation, "i-bank" stores accepted over 400,000 visitors.

The Bank's branches are located in almost every major city and town in Greece. Approximately 42% of the Bank's branches are located in Attica and Thessaloniki prefectures, the major population centers in Greece. The Bank is engaged in a continuous process of rationalizing the organization of its branch network in order to reduce costs, primarily by centralizing back-office functions to free more employees to work on sales activities directly with customers. In addition, the Bank is continuing to consolidate redundant branches in order to maintain equivalent geographic coverage at a lower cost. As at December 31, 2011, the Bank operated 232 full banking branches and 307 retail banking branches.

We participate in DIAS Interbanking Systems S.A., which currently has 41 banks as shareholder-participants, including the Bank. DIAS Interbanking Systems provides interbank services such as check clearing, ATM networking, fund transfers and payroll and pension services for the benefit of customers of shareholder-participants.

We use a variety of marketing channels to maintain and enhance our market position, including telemarketing (particularly for credit card sales and consumer loans), radio, television, press and internet advertising and distributing promotional information brochures in our branches. As part of our marketing strategy, we seek to capitalize on our existing relationships with individual customers through cross-selling efforts aimed at increasing such customers' awareness of other products that are offered by Group companies. For instance, our mortgage customers are informed of our insurance products, through which they may insure against damage to their property and against events and circumstances that might cause them to default on their mortgage loans. Our marketing strategy also includes indirect marketing, pursuant to which we have entered into agency agreements with retailers, such as automobile dealers and electronics chain stores, who agree to offer our consumer loan products to their customers in connection with purchases of consumer goods.

In addition, we employ various alternative distribution methods, such as cooperation with real estate agents and construction businesses in the sale of mortgage loans and with accountants and consultants in the sale of small business loans. We have also entered into contractual arrangements with mobile telephone service providers in Greece that enable us to offer to our customers certain banking services, such as balance inquiries, through their mobile telephones. We provide certain banking services over the internet, including the transfer of funds between accounts, balance inquiries, bill payments, stock brokerage services and subscriptions to initial public offerings on the ATHEX.

We have also introduced "i-bank", a web-based portal which allows our clients to select the ideal place and method to transact with the Bank in order to achieve immediate and reliable service at low cost. Our "i-bank" is being implemented at Group level in all countries in which we operate, which will create convergence across our distribution channels through the utilization of a common platform for trans-border products and services.

Savings and investment products of the Bank are offered both in euro and in other currencies. In response to customer demand, the Bank offers investment products with high yields. These products include repurchase agreements between the Bank and our clients (backed by Greek government bonds), Greek government bonds from the Bank's proprietary portfolio, capital guaranteed principal products and a wide range of mutual funds and unit trust products provided by NBG Asset Management Mutual Funds S.A. ("NBG Asset Management"), which is 100% owned by Group companies. See Item 4.B, "Business Overview—Banking Activities in Greece—Global Markets & Asset Management".

We offer payment services to our clients participating in all local interbank payment channels. We are also a direct member of the euro interbank channels of TARGET, TARGET2, EBA for Euro 1, Step 1 and Step 2. As a member of Step 2, the Bank is the main Greek entry point for eurozone payments. For payments, especially outside the eurozone, the Bank maintains a global network of correspondent banks. The Bank has completed the centralization of its payment operations. Our Cash Management product offering in Greece leverages extensively the Bank's branch network in providing our customers with on-line transaction processing particularly as regards electronic collection services.

All of our retail banking activities in Greece are conducted by the Bank. The Bank offers retail customers a number of different types of deposit and investment products, as well as a wide range of traditional services and products.

As a result of the economic crisis, we have adopted a more conservative approach to new consumer lending, with a greater emphasis on risk-averse lending criteria. As a result, we experienced a reduction in balances in 2011, and we also expect slower credit expansions across each of our products in 2012, also in line with the current market conditions.

The following table illustrates our estimated market share in Greece for certain categories of retail banking activities as at the dates indicated:

We believe our strong corporate image and name recognition in Greece, our large customer base and our extensive network of branches and ATMs are advantages that will facilitate the Bank's access to the largest and most diverse depositor base in Greece, providing the Bank with a large, stable and low-cost source of funding.

The Bank's objective for 2011 was to continue supporting customers experiencing difficulties in the smooth repayment of their obligations, through the improvement of solutions for debt restructuring, depending on each customer's needs and repayment ability. At the same time and despite the economic crisis, the Bank maintained its strong position in consumer retail banking by offering a wide range of consumer finance solutions to financially healthy customers. The Bank is among the most active credit

card issuers in Greece, having circulated approximately 735 thousand cards and managing a total credit card portfolio of EUR 1.5 billion as at December 31, 2011.

During 2011, the Bank focused on restructuring consumer loans and deleveraging the portfolio, targeting financially healthy customers for new loans and simplifying as well as strengthening credit processing. In particular, the Bank focused on implementing more stringent credit criteria as well as a more effective and targeted portfolio management. The Bank has also modified the way in which it grants loans and takes on new customers by targeting customers that plan to invest rather than consume. The offer of green loan products was enhanced through the accomplishment and extension of various agreements with retail companies specialized in providing innovative technology solutions for energy saving. In addition, the Bank participated in major exhibitions about Environmental Technologies, Energy Saving and Renewable Energy Sources in order to communicate the Bank's series of green products. The Bank continues participating successfully in the "Energy Saving at Home" program managed by Institute of Financing Small & Very Small Sized Enterprises ("ETEAN S.A. former TEMPE S.A.), supporting the goal for energy efficiency and use of renewable energy sources.

Consumer and credit card portfolio restructuring products are addressed mainly to customers with at least one consumer loan or credit card in delinquency for at least 90 days. Under the restructuring all consumer loan and credit card debt is consolidated into a single fixed-term consumer loan, even if certain of the consumer loans and/or credit cards have less than 90 days delinquency. The standard terms of these products include (i) a grace period of 18 months, during which the customer pays only interest, (ii) a reduction of up to 50% of the interest accrued off-balance sheet since a loan or credit card was placed in non-accrual status and (iii) a down payment by the customer equal to one installment. The interest rate on the new loan may be reduced and/or the duration may be extended if the borrowers are willing and able to secure their consumer loan and credit card debt with real property or provide an additional down payment. The maturity of these restructured products varies from 10 to 20 years.

Currently the average duration of the restructured fixed-term consumer loan portfolio is approximately 10 years, while their average interest rate is 9.7% as at December 31, 2011. In 2011, more sophisticated products with a reduced installment amount have also been introduced making the service of all kinds of distress possible.

The Group classifies modified consumer loans and credit cards as Troubled Debt Restructurings ("TDRs") when, for economic or legal reasons related to the debtor's financial difficulties, the Group grants a concession to the debtor that it would not otherwise consider. In relation to the above restructuring products, the Group considers that the reduction of off-balance sheet interest represents a concession because it causes a direct economic loss for the Group that it would not otherwise consider. By contrast, the lower interest rate and extended maturity is offered only to customers that provide real property as collateral and/or additional down payment, thus mitigating our risk exposure, and for this reason these modifications are not deemed concessions. Consequently, typically the Group classifies as TDRs consumer and credit card balances that have been non-accruing, at the time of the restructuring and, as a result, off-balance sheet interest is waived.

Our basic goal for 2012 is to strengthen the conditions that help keep its loan book robust under the particularly adverse macroeconomic conditions currently prevailing.

The year 2011 was a year of deep recession in the Greek economy, marked by low personal incomes, high unemployment, heavier taxation especially in the real estate sector and particularly low construction activity. In this difficult environment, the number of housing transactions declined by 44% and house prices by 5.3% (Source: Bank of Greece_Bulletin of Conjunctural Indicators), following prior falls in house prices by 4.4% in 2010 and 4.3% in 2009. Notwithstanding the above, the housing

market is not considered to be overpriced, since the decline in house prices over the last three years was rather moderate and gradual, a trend that is expected to continue in the near future.

Since the beginning of 2009, apartment prices in Greece have declined. In 2011, apartment prices decreased by 5.1% on an average annual basis compared to a 4.7% decrease in 2010 and a 3.7% decrease in 2009. The new index of apartment prices (Index 2007=100) has declined to 85.5 at the end of 2011, compared to 90.9 at the end of 2010, 97.7 at the end of 2009 and 101.8 at the end of 2008 (source: Bank of Greece, Real Estate Market Analysis department report, Table II.6. New Index of apartment prices by age). It should be noted that the real estate market in Greece is considered to have long-term investment-type characteristics since the property is transferred from one generation to another, in order to meet housing needs. In addition, the high costs of property transactions, including fees and taxes, has an adverse effect in housing activity, thus limiting volatility in house prices.

During 2011, mortgage lending in Greece declined faster compared to 2010, at an annual rate of around 3%. The Bank balances followed the same trend, reaching EUR 18.7 billion at the end of 2011, compared to EUR 19.5 billion as at December 31, 2010, posting a decrease of 4.0% and constituting 35.3% of its total lending to enterprises and households in Greece. Nevertheless, the Bank managed to maintain leadership in the market, with a share of 25.1%. In Greece, 10.6% of our mortgage portfolio carries an interest rate subsidy, either by the State or the Social Housing Organization (O.E.K.), and another 7.5% is fully guaranteed by the Hellenic Republic. Most of these programs, with the exception of mortgages subsidized by the State, were inactive or discontinued, even before 2010. The volume of new mortgage loan disbursements amounted to EUR 298 million in 2011, compared to EUR 1.4 billion in 2010.

During 2011, new mortgage lending was limited to EUR 298 million, and was subject to more stringent lending criteria. The average Loan-to-Value ("LTV") fell to less than 64% and Payment-to-Income ("PTI") fell to 25%, compared to a maximum limit of 40% set by the Bank of Greece. The Bank followed conservative selection criteria, with an approval rate at 35%, compared to 49% in 2010. The vast majority of these loans were granted through the Bank's branch network, with very limited participation of third parties, reflecting the Bank's new policy. Pricing became more expensive as in 2011 average spread rose to 341 basis points, from 259 bps in 2010 and 224 bps in 2009. Around 46% of new production was of a fixed interest rate type and 54% floating, with maximum duration 30 years. For further information regarding the underwriting criteria of the mortgage loan products, see Item 4.E, "Information on the Company—Selected Statistical Data—Credit Quality—Risk Management—Loan Approval Process—Retail Banking—Mortgage Loans".

Since 2010, the Bank's attention has been mainly focused on proactively dealing with customers who currently face financial difficulty in serving their mortgage in accordance with contractual terms. For loans in delinquency for over 90 days, a number of modification programs was applied, offering, in addition to maturity extension (i) a 24 month interest-only period and (ii) a reduction of up to 30% of the interest accrued off-balance sheet for loans placed in non-accrual status (over 180 days past due). In certain cases, a down payment on behalf of the borrower was required. Non TDRs mortgage loans modified within 2011 amounted to EUR 0.6 billion compared to EUR 0.5 billion in 2010.

In relation to the above products for mortgage loans, the Group assessed whether in certain circumstances these modifications were for the purpose of maximizing the collection of the amounts due, and thus constituting a concession. The Group concluded that in relation to the above options the reduction of off-balance sheet interest represents a concession because it causes a direct economic loss for the Group. Remaining options that allow for modification in interest rate or extension in maturity are not considered to be concessions as these products would be offered to borrowers of equal credit quality, similar circumstances and similar standing. As at December 31, 2011 and 2010, modified loans that were concluded to be TDRs amounted to EUR 1.2 billion and EUR 0.5 billion, respectively.

Modified mortgages have an average duration of 31.3 years, almost 6 years longer than prior to modification. Of all modifications, 47% covers the vintage period 2006-2008. Post modification almost all mortgages became of a floating interest rate type, indexed to 3-month euribor plus a spread, whereas, before modification, fixed and floating rate mortgages were almost equally divided (43% fixed and 57% floating). On average, the spread of floating rate mortgage loans has increased by 30 bps after modification.

In mid-2011, as a result of the prolonged economic crisis, the Bank offered to customers still experiencing problems in servicing their restructured mortgage, the opportunity to become current in their payments, by offering a new product of "fractional payment", where the customer pays for a 3-year period a proportion of the installment due (40% in the first year, 60% in the second year and 80% in the third year). In this case, the minimum interest margin charged was set at 250 bps over 3-month euribor. This new product represents a concession for the Bank and is accounted for as TDR since it would not be considered by the Bank if the customer was not in financial difficulty.

In addition to fire and earthquake property insurance, we offer an optional life insurance plan together with mortgages. This option has been successful, with 97.6% of new mortgages in 2010 and 2011 carrying a life insurance plan. In July 2009, the Bank's range of insurance products was further enriched with the introduction of a mortgage payment insurance plan that guarantees up to 18 monthly loan installments in case of a borrower's involuntary unemployment or temporary disability due to illness or accident. This new insurance product is complementary to life insurance plans and further improves the safety of mortgage payments. Almost all new mortgages in 2010 and 2011 carried the payment insurance plan. For further information, see "—Insurance" below. Offering optional life insurance plans together with mortgages has improved the quality of our mortgage credit as credit risk due to death, permanent disability or temporary unemployment at the Bank level is mitigated.

More specifically, life insurance as well as payment protection insurance improve the quality of our mortgage portfolio because when the event occurs (i.e. death, disability, unemployment etc.), the Bank receives either the outstanding loan amount or monthly payments corresponding to the loan installments, instead of waiting for the temporarily disabled or unemployed borrower to resume payments or in case of death or permanent disability for the loan to go into foreclosure. In 2010 and 2011, claims incurred under such policies amounted to EUR 23.5 million and EUR 29.7 million, respectively.

The insurance risk arising from these policies is assumed at the level of our insurance subsidiary EH and has historically been covered by the premium revenue earned on these insurance policies; therefore the total exposure to these borrowers is not diminished at consolidated level. For substantially all mortgage loans originated by the Bank and insured for life, disability and payment protection, the insurance policies have been underwritten by the Bank's subsidiary EH and a corresponding provision for the insurance risk is recognized. The insurance risk provision associated with the insurance policies sold together with our mortgage products is estimated based on historical trends and the indemnification amounts like any other life insurance policy. For the purposes of estimating the allowance for loan losses, the Bank ignores these insurance policies when estimating losses incurred in the portfolio.

As 2012 is expected to be another recessionary year, new mortgage production will be kept at low levels, similar to those experienced in 2011. The Bank's main effort will continue to focus on managing effectively its portfolio. The current environment exerts downward pressure on house prices, which are expected to continue declining similarly to 2011.

The year 2011 can be characterized as a year in which we have witnessed stabilization of the housing sector. The commencement of new housing construction projects and house sales slowed down in comparison to previous years. The Turkish House Prices Index has increased from 88 at the end of

2008, to 91.1 at the end of 2009, reaching 93.5 at the end of 2010. The upward trend continued in 2011 and reached 100.8 at the end of 2011.

Due to high competition in the mortgage loan market, we have observed a contraction in the mortgage loan spreads which led some banks to slow down their mortgage loan sales due to profitability concerns. Finansbank took a decision to pull back from mortgage loan origination in May 2011 and shifted our sales force efforts to more profitable products such as personal need loans and overdrafts. Finansbank had 8.3% market share by the end of 2011 in mortgage loans compared to 10.5% in 2010 according to statistics published by the BRSA.

In SEE and particularly in Romania and Bulgaria, the decrease in real estate prices continues, albeit at a slower pace.

In Romania, the correction in real estate prices appears to have come to a halt, with the real estate price index (Residential Advisors index: average asking price of residential space in Bucharest (in EUR terms)) falling only by 0.1% in 2011, following a drop of 8% in 2010, keeping prices at their end-2007 levels, 16.8% below their 2008 peak. The relatively better performance of the real estate market in Romania could be attributed to the mild recovery for real estate demand, in line with the rebound in economic growth to 2.5% from -1.7% in 2010 as well as from the buoyant mortgage lending activity, supported by guarantees from the Romanian government for families, which do not own a home or dwelling of 50 square meters or less, to buy a house, leading to mortgage lending growth of 15.3%.

In Bulgaria, the real estate price index (National Statistical Service index: average price of second-hand dwellings in district centers (in BGN terms)) continued on its downward trend, at a slower pace, falling by 6.1% in 2011, following a drop of 10.1% in 2010, leading prices back to end-2006 levels, 33% down from their 2008 peak. In Bulgaria, economic growth improved only slightly to 1.7% from 0.4% in 2010. Mortgage lending posted an anemic growth of 1.1% in 2011, reflecting mainly bank liquidity pressures and asset quality concerns.

Furthermore, an indicator of the real estate activity is also reflected on the relatively small stock of foreign investments in the real estate sector. Indeed, balance of payments data shows that over the period 2004-2008, total foreign investments channeled to the Romanian real estate sector amounted to 4.4% of 2008 GDP, against 15.8% in Bulgaria. For information on real estate prices in Turkey, see "Banking Activities outside of Greece—Turkish Operations—Retail Banking" below.

The Small Business Lending Unit ("SBL Unit") in Greece manages the extension of credit to small businesses with annual turnover of up to EUR 2.5 million and total exposure up to EUR 1.0 million.

The SBL Unit offers lending solutions as outlined below, which cover a full range of business credit needs:

The portfolio size of our SBL Unit was negatively affected by the limited demand for funds as a result of the crisis, and also partly by the repayment of loans (mainly those guaranteed by ETEAN S.A.). Total portfolio as at December 31, 2011 was EUR 3,782.7 million compared to EUR 4,115.4 million in 2010.

The Bank has adopted new procedures that govern its active participation in the ETEAN S.A.. They involve the financing of enterprises by issuing state guarantees for loans, covering up to 80% of principal. In 2011, the SBL Unit's participating in ETEAN S.A. evaluated approximately 273 applications resulting in over EUR 7.5 million in disbursements.

The Bank continued to support Small and Medium Sized Enterprises ("SME") financing, both towards healthy companies troubled by the domestic economic crisis by providing the necessary liquidity and towards those experiencing difficulties in servicing their debt obligations, by setting favorable terms and conditions for the management of their debts.

More specifically, the Bank supported SMEs by providing an amount of EUR 290.0 million in new disbursements in 2011, compared with EUR 535.0 million in 2010.

In addition to customized financing products targeted at certain categories of businesses and professionals such as trade unions, technical chamber of commerce of Greece and car dealers, the SBL Unit offers term loans geared towards medium and long-term working capital needs for the financing of asset purchases.

The Bank, in an effort to boost competitiveness of SMEs within the context of the financial distress in Greece, has ensured participation in two projects regarding co-funded risk sharing products. More specifically:

In 2012, the SBL will focus on these development initiatives and the active management of the existing portfolio.

Already the Bank, in cooperation with the State Funded ETEAN S.A., participates in a EUR 150 million budget initiative to finance business projects related to thematic tourism, renewable energy and implementation of technologies that help conserve natural resources and environmental protection.

In addition, the Bank is proposing to its customer modification programs. Corporate and SBL portfolio modification products in Greece are addressed to borrowers with at least one account in delinquency of at least 90 days. These products are divided into two categories, those that fall under Greek Law 3816/2010 (see Item 4.B, "Business Overview—Settlement of Business and Corporate Debts") and those that are specially designed by the Bank in order to supplement the limited specifications of the requirements of such law. The restructuring product under Greek Law 3816/2010 was offered for a limited period and addressed only the overdue amounts, while the product designed by the Bank allows the restructuring of the total debt and is still offered.

The modification product offered by the Bank includes: i) the granting of a grace period of up to 24 months during which the borrower pays only interest, ii) the prolongation of the maturity of the loan up to 10 years while applying the same interest rate, iii) the option to the borrower to make a down payment, which, if the loan is repaid in accordance with the renegotiated terms, is returned as a discount. This discount is limited to the lower of 10% of the restructured debt or maximum EUR 100,000.

The Group considers as TDRs the above products for SBL and corporate loans given that they represent a concession that would not be otherwise considered by the Group if the customer was not in financial difficulty.. Therefore, typically the Group classifies as TDRs, SBL and Corporate loans that have been non-accruing, that is at least 90 dpd, at the time of the restructuring and, as a result, off-balance sheet interest is waived.

Furthermore, the Bank has also launched a new product for restructuring-on-restructuring ("R-O-R") in August 2011 in order to further assist customers having difficulty in servicing their obligations, despite the settlement of their debts, as a result of the prolonged economic crisis. The product which is accounted for as TDR, offers the recalibration of the debt under the following framework: Eligible clients for this R-O-R product are those with balance in delay for more than 60 days, outstanding balances fully secured or when new collateral is obtained to fully cover the new debt, when at least 50% of the accrued interest of the previous restructured debt is paid and when there is no new negative information in relation to the customer. In 2011, the SBL Unit sponsored a total of 653 customers with this R-O-R product of EUR 117.3 million.

The Bank's commercial loan portfolio in Greece comprises approximately 58 thousand corporate clients, including SMEs, and most of the largest corporate groups in Greece. As a Group, we are able to offer corporate clients a wide range of products and services, including financial and investment advisory services, deposit accounts, loans denominated in euro and other currencies, foreign exchange services, insurance products, custody arrangements and trade finance services.

As a result of the ongoing economic crisis in Greece, the Bank has adopted a more conservative approach to new commercial lending, with a greater focus on larger corporate borrowers that it perceives to be lower-risk. As a result, substantial deleverage took place in relation to the SME balances during 2011 partially offset by increased financing to Large Corporate borrowers for energy sector projects. The Bank expects an additional deleverage of 3% in its lending portfolio during 2012 compared to 2011.

The Bank lends to all sectors of the economy. As at December 31, 2011, domestic commercial lending (including loans to the public sector) amounted to EUR 27.9 billion and represented 52.5% of the total domestic loan portfolio of the Bank. Its lending exposure to the ten largest performing loans to non-affiliated enterprises amounted to EUR 3.4 billion as at December 31, 2011, representing 6.4% of its domestic loan portfolio.

The Bank lends primarily in the form of credit lines, which are generally at variable rates of interest with payment terms of up to 12 months. In addition, the Bank provides letters of credit and guarantees for its clients. At December 31, 2011, the Bank had standby letters of credit and financial

guarantees amounting to EUR 3.2 billion. Most loans are collateralized to a certain degree, although Greek law imposes significant delays to foreclosing on collateral.

The table below sets forth certain key nominal interest rates charged by the Bank:

Greece is a maritime nation with a long tradition in ship-owning and is one of the world's largest ship-owning and ship-flagging nations. Shipping remains one of the most important sectors of the Greek economy and the Bank is one of the most active participants in the local market, as well as one of the strongest competitors to foreign banks involved in shipping finance in Greece. The Bank's shipping finance activities are carried out almost exclusively through its Piraeus-based operation.

The Bank has traditionally provided financing for many of the largest Greek shipping companies. As at December 31, 2011, outstanding shipping loans (mainly concerning bulk shipping) were EUR 2.3 billion, representing 4.3% of the Bank's total domestic loan portfolio compared to EUR 2.2 billion or 4.0% of the Bank's total domestic loan portfolio, as at December 31, 2010. Of the Bank's shipping finance portfolio as of December 31, 2011, 4% concerned the financing of new vessels (new buildings), with the remainder relating to financing purchases of second hand vessels.

The Bank's conventional shipping finance and syndicated loan portfolio consists of first-tier shipping groups involved in diversified shipping activities (e.g., dry bulk, wet bulk, liner business) in a continuous effort towards maintaining quality, spreading risk and enhancing the profitability of its shipping loan portfolio. Nearly all of the Bank's shipping loans are secured by vessels.

The shipping industry is highly cyclical, experiencing volatility in revenues and cash flows resulting from changes in the demand and supply of vessel capacity. The demand for vessels is influenced by, among other factors, global and regional economic conditions, developments in international trade and changes in seaborne and other transportation patterns that are not within the Bank's control. During 2011, freight rates in main shipping segments dry, wet and liner shipping have in broad terms significantly decreased. For 2012, the shipping markets are expected to remain at lower-than-average historical levels, (with variations between dry and wet sub-markets) due to increased tonnage supply (new-building vessel deliveries) and modest demand for shipping services, as a consequence of macroeconomic conditions.

The Bank's goal for 2012 remains to closely monitor existing shipping facilities while at the same time supporting existing clientele. The Bank's management believes that this effort will result in maintaining a high quality portfolio and its solid presence in this sector in the years to come.

The Bank's project finance loan portfolio includes loans to large infrastructure projects both in Greece and abroad (Western Europe, U.K., U.S.A.). The overall size of this portfolio was EUR 454.2 million as at December 31, 2011, decreased by 20.8% since 2010. The decrease was a result of a deleveraging effort undertaken by the Bank during 2011. Only EUR 23.2 million of new loans were advanced in 2011 for projects outside Greece. The domestic loan portfolio remained stable as all but one of the large motorway infrastructure projects stagnated during 2011 due to problems encountered in their implementation and the overall deterioration of the country's financial standing, which resulted in an effective draw-stop of the disbursements under the corresponding loans. The Greek government has undertaken concerted efforts to support these projects so that construction may resume during the current year. If these projects are restarted, the progress of construction of these projects during the next three to four years would lead to a significant increase of the Bank's domestic loan portfolio, since the total commitment of the Bank amounts to EUR 310.0 million, compared to EUR 71.0 million disbursed until December 31, 2011. Through an operational agreement signed in December 2011, the Bank, acting as an Urban Development Fund (UDF), has been awarded management of EU Structural Funds under the JESSICA (Joint European Support for Sustainable Investment in City Areas) initiative for three Lots (out of ten Lots in total for Greece) amounting to EUR 83.3 million (30.0% total Jessica Funds for Greece). The Lots correspond to Attica, Western Greece and Ionian Islands Regions and the operational Program "Environment and Sustainable Development". Jessica funds, along with the Bank's and other private funds are intended to be used during the period 2012- 2015 to make repayable investments in the respective regions.

Advisory activity in 2011 to the public and private sector developed at a considerably lower pace compared with that of previous years, as the execution of certain projects was postponed by the Greek government in the context of the current economic environment. However, the Bank as head of an international team of advisors, continues to provide financial advisory services to government bodies for two projects, namely "22 schools complexes in Attica" and "Thrace Democritus University Student Accommodation". Preferred bidders for the first project have been selected while an international tender for the implementation of the second project is currently under way. The Bank also leads a group of domestic and international firms in providing financial advisory services to the Public Real Estate Co, an entity in charge of the development of a portfolio of national properties, selected by their value.

In January 2012, the Bank has been appointed by the Greek government, together with Guggenheim Capital LLC, as a joint financial advisor for the ambitious large scale renewable energy sources project HELIOS, to provide advisory services related to the structuring, development, implementation and financing of the project and related infrastructure.

We began leasing activities in 1990 through our subsidiary, Ethniki Leasing. Ethniki Leasing leases land and buildings, machinery, transport equipment, furniture and appliances, computers and communications equipment. As at December 31, 2011, 59% of the finance lease receivables of Ethniki Leasing were to the trading and services sector, 17% to industry and mining, 22% to construction and real estate and 2% to other sectors. As at and for the year ended December 31, 2011, Ethniki Leasing had total assets of EUR 699.4 million and interest income of EUR 32.6 million, before elimination of intercompany transactions and balances, compared to EUR 750.2 million and EUR 29.6 million, respectively in 2010.

We have been active in the provision of factoring services since 1994. In May 2009, Ethniki Factors was established as a wholly-owned factoring subsidiary of the Bank, as part of the strategic decision to

expand our factoring operations in Greece. The company is a specialist factoring agency offering a comprehensive range of factoring services including prepayment (discounting), management and collection of receivables, credit control, and protection for credit risk. Ethniki Factors provides both domestic and international factoring services. During 2011 the company focused mainly on broadening its portfolio by offering wide range of services to NBG Group corporate customers and developing synergies with the Bank which resulted in establishing robust portfolio, enhancing market share and sustaining profitability.

In 2011, the Bank's Investment Banking Division focused on providing advisory services in privatizations, mergers and acquisitions and equity capital markets transactions.

The Bank was appointed as financial advisor to the Hellenic Republic in the privatizations of Athens International Airport, Public Power Corporation and OPAP (Greek gaming company), as well as co-ordinator of the extensive real estate development program. The Bank acted as advisor to ATEbank and to KORRES S.A. - Natural Products in their respective capital raising, acting as underwriter for the former. The Bank also provided a fairness opinion to the Board of Directors of RILKEN S.A. in the tender offer launched by HENKEL HELLAS S.A. In January 2012, the Bank's Investment Banking was appointed as financial advisor to the Hellenic Republic for the large-scale solar renewable energy project "Helios".

The Bank and each of our banking subsidiaries carry out their own treasury activities within the prescribed position and counterparty limits. These activities include:

The Group's Treasury is active across a broad spectrum of capital market products and operations, including bonds and securities, interbank placements in the international money and foreign exchange markets and market-traded and over-the-counter financial derivatives. It supplies the branch network with value-added deposit products, and its client base includes institutions, large corporations, insurance funds and large private-sector investors. In general, the Bank and our subsidiaries enter into derivatives transactions for economic hedging purposes or in response to specific customer requirements. In recent years, the Bank's treasury-related activities have represented a significant source of revenues. In 2011, total turnover for foreign exchange trading and money market transactions by the Bank's central dealing room in Athens was approximately EUR 150 billion and EUR 924 billion respectively (compared to approximately EUR 206 billion and EUR 1,107 billion, respectively, in 2010).

The Bank is active in the primary and secondary trading of Greek government securities, as well as in the international Eurobond market. The Bank is a founding member of the Group of Greek Government Securities Primary Dealers which was established by the Bank of Greece in early 1998.

The Bank launched its private banking operations ("Private Banking") in 2003 and is dedicated to serving a high net worth clientele, by offering first-class services that maximize clients' personal aspirations. Our team of investment experts provides customers with continuous support and direct access to the major international financial centers and Private Banking services of a global reach.

Each Private Banking client is unique, with specific financial needs and goals. The understanding of clients' personal investment profile is the essence of Private Banking. To that end, a personal and long-standing relationship between the Bank and the client is established, based on trust, confidence and discretion, such that the client's requirements can be efficiently and effectively addressed.

As the Private Banking team provides services on execution basis only, advisory and discretionary asset management services are provided by NBG Asset Management, adding important solutions to the Bank's investment services. For information related to NBG Asset Management, see below "—Asset Management".

NBG Private Banking received the Euromoney Private Banking Award "Best Private Banking in Greece" for 2008 and 2010.

The Bank offers custody services to foreign and domestic institutional clients investing in the Greek and Cypriot markets, as well as clearing services to remote members of the ATHEX. The range of services the Bank offers includes trade settlement, together with clearing services as a General Clearing Member on the ATHEX, safekeeping of securities, corporate action processing, income collection, proxy voting, tax reclamation, customized reporting and regular market flashes. The Bank also acts as global custodian for its domestic clients who invest in international markets using, where possible, its subsidiaries in SE Europe.

As at December 31, 2011, the Bank serviced 55 domestic institutional clients (three mutual funds, 12 insurance companies, 29 pension funds, two asset management companies, four brokerage companies, one investment company and four other companies) and 33 foreign institutional clients, including several leading global custodians. The Bank also offers custody services to approximately 284 thousand private Greek investors.

In recognition of the quality custody services offered, the Bank has been awarded "Top Rated" status and highest ranking positions in both Cross Border/Non-Affiliated and Domestic categories for the years 2009-2011, and ranked first in the Leading Clients category for the year 2011, in the Agent Banks in Major Markets Survey of Global Custodian.

Our domestic fund management business is operated by NBG Asset Management, which is wholly owned by the Group. NBG Asset Management manages funds that are made available to customers through the Bank's extensive branch network.

As of December 31, 2011, NBG Asset Management's total assets under management, in mutual funds, were EUR 1.1 billion compared to EUR 1.4 billion as of December 31, 2010. Its market share in Greece was 17.4% as of December 31, 2011, compared to 17.3% as of December 31, 2010. (Source: Hellenic Fund and Asset Management Association—report of December 31, 2011).

The total value of mutual funds managed since 2007 is set forth in the table below:

NBG Asset Management offers 23 investment funds under the brand name Delos, two under the NBGAM brand name and eight under the NBG International SICAV and NBG Synesis SICAV brand names, which are registered in Luxemburg. NBG Asset Management offers a wide range of investment products that provide to institutional and private investors access to significant markets in stocks, bonds and money market products, in Greece and internationally.

Additionally, NBG Asset Management offers a more integrated range of contemporary investment services such as:

As of December 31, 2011, NBG Asset Management had approximately 70 institutional and over 52,000 private investors, totaling EUR 1.3 billion assets under management (asset management and mutual fund operations combined).

National P&K Securities S.A., renamed to National Securities S.A. on May 20, 2010, is the Bank's brokerage arm and was founded in 2007 following the merger of the Bank's former subsidiary companies National Securities S.A. and P&K Securities S.A. National Securities S.A. offers a spectrum of investment services to both individual and institutional customers.

As at December 31, 2011, National Securities S.A. had a market share of 11.7% of trades brokered by total trading volume on the ATHEX, ranking third in terms of total trading volume, according to ATHEX data.

The provision of capital markets and advisory services in Greece has become increasingly competitive, with a number of banks and brokerage houses participating actively in this area.

With offices in London, Athens, Paris, Istanbul and Bucharest, NBGI Private Equity Limited ("NBGI Private Equity"), a subsidiary of NBGI International Ltd, manages the private equity funds described below. In 2011, NBGI Private Equity had invested amounts of approximately

EUR 366.5 million as at December 31, 2011, compared to approximately EUR 268.8 million at December 31, 2010.

Fund	Closing Date	Invested amounts	Geographic Focus

		(in millions)
NBG Private Equity Fund LP	August 2000	GBP 61	UK
NBGI Private Equity Fund II LP	June 2007	GBP 43	UK
NBG South Eastern Europe Fund LP	March 2006	EUR 24	SEE
NBGI SEE Development Capital Fund LP	March 2007	EUR 36	SEE
NBGI SEE Real Estate Fund LP	October 2009	EUR 72	SE and Central Europe
NBGI SEE Energy Fund LP	October 2008	EUR 8	Predominantly Central & Eastern Europe, and selectively Western Europe
NBGI Private Equity France Fund LP	December 2009	EUR 11	France and other French speaking countries
NBGI Turkish Private Equity Fund LP	October 2008	EUR 18	Turkey
NBG Technology LP	October 2001	EUR 29	Predominantly Europe
NBGI Technology Fund II LP	October 2009	EUR 44	Predominantly Europe & US

NBG is the sole investor in the funds, with the exception of NBGI Private Equity Fund II LP and NBG Technology LP where external investors also participate.

NBG Private Equity Fund LP ("UK Fund I") has an established track record, having exited ten of its thirteen investments to realize an overall gross 35.9% internal rate of return and a money multiple of 3.39.

During 2011 the UK Fund I partially exited one investment realizing a money multiple of 1.64, with the remaining holding in this investment currently valued at a money multiple of 6.59.

In total, during 2011, NBGI Private Equity's funds, invested in 11 new investments including five Real Estate deals, and made 13 follow-on investments. An additional an amount of EUR 42 million has been invested into the Real Estate Fund in 2011, including follow-on investments.

We operate, as a Group, in 11 countries outside Greece. As at December 31, 2011, our international network comprised 1,194 branches (including foreign subsidiaries and Bank branches in the United Kingdom, Albania, Egypt and Cyprus) and branches of subsidiaries, which offer traditional banking services and financial products and services. The Bank has seven commercial banking subsidiaries in Turkey, Bulgaria, Romania, FYROM, Serbia, Cyprus and South Africa. Furthermore, the Group has a presence in Malta through its subsidiary, NBG Bank (Malta) Ltd. Our policy, since the early 1990s, has been to focus on the Bank's regional strength in SEE by strengthening our existing network and expanding into growing markets that present low banking penetration and greater profit margins and also to withdraw from mature markets where growth prospects are limited. In particular, we seek to develop our wholesale banking business by targeting major financial centers to which we can offer Greek and Balkan lending exposure. Our retail banking presence in some geographical areas may only be justified by our success in niche markets in which we have the ability to exploit significant advantages.

Since 2000, the Bank has expanded its presence in SEE through acquisitions and green field start-ups. The Bank's regional strategy aims at diversifying our operations and enlarging our footprint to cover a region with attractive economic prospects. The Bank offers commercial banking services to customers in the region through our branches and subsidiaries in Turkey, Bulgaria, Serbia, Romania, FYROM and Albania.

Our Turkish operations include the Finansbank group of companies (except for Finans Pension, which the Group classifies under Group insurance operations) and NBG Malta, which holds a portfolio of Turkish business.

In 2011, Turkish operations contributed EUR 375.9 million of net income to the Group, compared to EUR 454.5 million in 2010. Turkish operations' income before income tax expense was EUR 481.2 million as at December 31, 2011 and EUR 553.5 million as at December 31, 2010. As at December 31, 2011, total gross lending was EUR 14,710.5 million while total deposits (excluding interbank deposits) reached EUR 11,926.3 million, compared to EUR 14,944.6 million and EUR 11,545.2 million, respectively, as at December 31, 2010. Total assets of Turkish operations as at December 31, 2011 were EUR 20.7 billion, accounting for 20.0% of our total assets compared to EUR 20.7 billion and 17.4% as at December 31, 2010.

Retail loans of Turkish operations amounted to TL 18.9 billion as at December 31, 2011, compared to TL 16.7 billion as at December 31, 2010 whereas retail sector deposits amounted to TL 19.8 billion compared to TL 14.0 billion for the same dates.

Corporate and commercial loans of Turkish operations amounted to TL 17.3 billion as at December 31, 2011, compared to TL 14.4 billion as at December 31, 2010, whereas corporate and public sector deposits amounted to TL 7.6 billion compared to TL 8.3 billion for the same dates.

On September 7, 2010, NBG announced, as part of its capital plan, its decision to dispose of a minority interest in Finansbank, through an offering that may comprise both primary and secondary shares. We currently intend to complete this offering when market conditions are favorable; however, our decision to proceed with the offering and its timing are subject to various considerations, including market conditions, offer size and structure and obtaining all necessary regulatory and other approvals. Although a reduction in our level of ownership in Finansbank, it would result in a reduction in the level of Finansbank's contribution to the Group's earnings going forward, it would expand its franchise in the attractive Turkish banking market, grow its balance sheet and improve its independent access to the capital markets.

Finansbank's group of companies includes Finans Invest, Finans Leasing, Finans Portfolio Management, Finans Investment Trust, Finans Factoring, IBTech, Finans Pension, and Finans Consumer Finance. Finansbank was the fifth largest private bank in Turkey in terms of total assets, loans and deposits as at September 30, 2011, according to data from the Banks Association of Turkey and it offers a wide range of retail, commercial, corporate, private banking and international trade finance services. In addition, Finansbank's subsidiaries provide financial leasing, capital market, corporate finance, portfolio management, brokerage and insurance services. As at December 31, 2011, Finansbank operated through a network of 522 branches in 62 cities, making it the sixth largest private bank in Turkey by size of branch network according to statistics published by the BRSA. As at December 31, 2011, Finansbank and its subsidiaries had 12,015 employees.

As at December 31, 2011, Finansbank maintained a branch network of 522 branches, consisting of 468 full service branches, 14 corporate and commercial branches, two retail only branches, 36 satellite and Easy Credit branches and one branch at the Atatürk International Airport Free Trade Zone in Istanbul, as well as one branch in Bahrain. While all Finansbank's corporate banking branches include a retail banking unit, certain branches are now dedicated only to retail customers and are located primarily in upper-middle income residential areas. Finansbank expects the reach of its branches to

become even broader in connection with the significant ongoing expansion of its branch network, which includes a plan to open a total of 30 new branches in 2012.

As at December 31, 2011, 73.0% of Finansbank's customer transactions were made through alternative distribution channels (internet, phone banking, ATM and IVR). The number of online banking customers exceeded 1.8 million, an increase of 30.7% compared to December 2010. The total number of transactions through Finansbank's internet banking services increased by 28.2% in 2011. Finansbank's ATM network grew by 16.0% in 2011 as the number of ATMs reached 1,826 compared with 1,574 at December 31, 2010.

Finansbank's retail banking activities consist primarily of mortgages, consumer lending, credit and debit card services, deposits and investment management, and insurance products. Income from Finansbank's retail banking activities includes net interest income from loans and advances to retail customers and deposits collected from individuals, as well as fee and commission income received from loan underwriting, asset management services, life insurance and property and casualty insurance products, credit and debit card-related services, settlements and cash-related transactions with or for individuals. Retail banking has been one of the principal drivers of Finansbank's growth during the past three years.

As at December 31, 2011, Finansbank had approximately 9.5 million retail banking customers, compared to approximately 8.5 million retail banking customers as at December 31, 2010. The continuous expansion of the retail branch network has allowed Finansbank to organically grow its customer base. Retail deposits increased by 41.0% during the same period from TL 14.0 billion at the end of 2010 to TL 19.8 billion at the end of 2011. Finansbank's market share in time deposits was 4.4% as at December 31, 2011, according to statistics published by the BRSA.

Finansbank retail loan portfolio increased by 13.8% from TL 16.6 billion as at December 31, 2010 to TL 18.9 billion as at December 31, 2011. Finansbank mortgage portfolio decreased by 4.5% from TL 6.2 billion as at December 31, 2010 to TL 5.9 billion at the end of 2011.

Finansbank's retail products and services include retail loans, which comprise mortgage loans, credit card loans, personal loans, auto loans and overdraft and other loans, retail time and demand deposits as well as investment products such as mutual funds and insurance products.

Finansbank's retail banking operations are divided into three main sub-groups: private banking, affluent segment and mass. Private banking serves customers with assets under management exceeding TL 500,000 who are served through dedicated relationship managers in branches and private banking centers and provides investment advisory services, advanced investment products, and fully customized services. Affluent banking, branded as "Xclusive Banking," was launched at the beginning of 2009, and serves customers with assets under management between TL 50,000 and TL 500,000. The services offered to affluent banking customers are based on dedicated relationship managers in branches supported by dedicated agents at the call center, offering a diverse set of banking and non-banking benefits. The mass segment is served through more standardized product and packaged offerings.

Finansbank seeks both to broaden its customer base and to improve profitability per customer with a view to continuing to grow retail banking operations. Finansbank targets a balanced retail lending business mix with higher exposure to higher margin operations such as consumer lending and credit cards and a more limited presence in less profitable, highly competitive businesses such as car loans.

Finansbank earns interest income on outstanding credit balances, transaction commissions from merchants, cash withdrawal fees, annual membership fees from cardholders and other service based

fees such as insurance fees and payment fees from its credit card business. As at December 31, 2011, the number of credit cards issued by Finansbank exceeded 4.7 million, representing 9.1% of the total Turkish credit card market, according to statistics published by the BRSA, and the number of member merchants was 141,448. Within the Turkish credit card market, Finansbank was the second largest Visa card issuer in terms of the number of cards issued, according to statistics published by the BRSA. The number of CardFinans commercial credit cards in issue was approximately 139,000 as at December 31, 2011, representing 9.7% of the total Turkish commercial credit card market, according to statistics published by the BRSA. The number of POS terminals of CardFinans reached 170,187 as at December 31, 2011, representing a 7.0% market share, according to statistics published by the BRSA.

Finansbank Group's total credit card loan portfolio was TL 8.8 billion as at December 31, 2011 compared to TL 6.9 billion as at December 31, 2010.

The CardFinans SME Business Card addresses the particular needs of SMEs by offering an installment credit facility and a post-installment feature. Finansbank had issued 130,000 credit cards to SMEs as at December 31, 2011. Finansbank Group's net fees and commissions from credit card operations amounted to TL 319.0 million in 2011 compared to TL 230.7 million in 2010.

Since its foundation, Finansbank's focus on Corporate Banking continues to serve its customers with the approach of being a solution partner.

Finansbank's corporate banking activities aiming to establish long-term relationships with customers continue to develop tailor made solutions to its customers. Finansbank serves its corporate customers via four branches located in Istanbul and Ankara, all employing expert staff at customers' service. Large-sized groups and multinational companies in Turkey get service under the roof of corporate banking.

Within corporate banking, foreign trade volume is aimed to increase in the diversity of the foreign trade products in corporate companies.

Corporate Banking, focusing on relationship banking and value added approach has contributed to creating a stable customer profile.

Finansbank has played an active role in the project finance, acquisition finance, privatization and infrastructure finance deals in recent years. Thanks to its qualified service approach as well as extensive knowledge and experience in the sector, it serves its local and multinational clients in all segments, particularly the Corporate segment, whose investments meet project finance criteria under Structured Finance and Syndications Group. In 2011, Finansbank supported green field investments and acquisitions realized in leading sectors which have contributed to the development of Turkey's economy in such sectors as energy, construction, real estate, transportation and infrastructure.

In 2012, Finansbank continues to lead the developments in the sector by analyzing its customers' needs and by giving support to their investments as a Lead Arranger through its know-how and innovative financing approach. Finansbank aims to provide qualified, rapid and diversified solutions to its clients parallel to their needs by closely following up the current projects in construction, infrastructure, real estate and energy sectors and Public-Private Partnership Projects.

In 2011, Finansbank Commercial Banking was able to realize its main goal of maintaining sustainable growth and has increased its total balances by 13%, its demand deposits by 18% and its time deposits by 25%.

Turnover criterion for Commercial Banking service was over TL 10 million before devolving of Medium Sized Enterprises; the criterion has determined between TL 2 million to TL 100 million afterwards.

A new organizational framework has been established "Network Project" in order to provide a holistic approach to the banking industry and the customers, aiming to improve relationship banking, increase opportunities to cross-sell and expand the existing trade network. Under this framework, the business line has been structured to operate under 4 main groups in order to serve its present and prospective clients:

As of July 2011, the Commercial Marketing Insurance Product and Sales Management unit was established under the Commercial Marketing Group to meet the insurance needs of Corporate, Commercial and SME banking customers.

The Commercial Marketing Group focuses on increasing income from loans and customer penetration. The promotion of Bank Assurance and subsidiary transactions have been transferred to Commercial Marketing Group. In the year 2011, the Group has worked on "Network Project" offering customer-designed products and POS and cash management tools with special prices for Corporate, Commercial and Retail Banking customers and their dealers/suppliers.

Cash Management Department is concentrating not only on attracting new customers but also increasing the loyalty of existing customers via technology-based applications which also reduced transaction costs significantly. In this period, the number of customers using Electronic Banking Product has increased by 62%. Throughout 2011, activities enhancing effective use of the Bank's client network ensured circulation of customers' cash flow within the bank and helped increase synergy between business units, cross-selling ratio and the attraction of new customers. The technical infrastructure regarding the Direct Debit System (DDS) has been completely revised. Upon the completion of the third phase of the project, Finansbank now offers far more technologically renewed, competitive DDS to its customers. In 2011, the number of active firm has increased by 43%, while the number of dealer has increased by 183%.

In charge of development and marketing of trade finance products, the Trade Finance Unit has made major contributions to the overall foreign trade volume and profitability of Finansbank in 2011. In this period, annual foreign trade volume of Finansbank increased by 17%.

With its twelve Regional Offices established for understanding and managing regional needs, Medium Sized Enterprise and Commercial Banking portfolios; Commercial Banking's branch network which was increased from 84 to 255 service points and 520 Portfolio Managers with mixed branch structure passing to a more effective sales and customer management model.

Finansbank was one of the first banks in Turkey to focus on SME banking. Finansbank started its SME banking operations at the beginning of 2003 to support small business enterprises, which Finansbank defines as small- and medium-scale enterprises with an annual turnover of up to TL 2.0 million. As at December 31, 2011, Finansbank had 516,541 SME customers with at least one product. In addition to traditional banking products and services, Finansbank offers an extensive range of products and services to create financial resources for SMEs' specific needs.

Finansbank Investment Banking consists of Project Finance, Corporate Finance and Technical Consulting. Investment Banking acts as a client relations specialist while providing medium- to long-term loans and other products.

Finansbank's Private Banking department helps customers build and preserve their financial wealth through tailored investment strategies and offers its customers time deposits, mutual funds, emerging market bonds, domestic and international equities, government bonds, corporate bonds, currency exchange, forward contracts, futures, options and structured products. The Private Banking department also creates and implements medium—to long-term asset allocation within the context of each customer's particular risk tolerance. The Private Banking department serves investors with assets of more than TL 500,000 or the TL equivalent in one or more foreign currencies. The Private Banking department supports all of Finansbank's business lines (Retail, SME, Commercial and Corporate) in Finansbank within a matrix structure and cooperates within Finans Portfolio Asset Management and Finans Invest to execute and advise clients transactions.

As at December 31, 2011, Finansbank Private Banking provided investment products and asset management services through seven private banking centers and 14 private banking corners located in Finansbank's branches in all major cities throughout Turkey. As at December 31, 2011, Finansbank Private Banking had approximately 6.000 active clients and TL 9,596.5 million in assets under management compare to TL 6,352.2 million in 2010.

Finans Invest was established in December 1996 and began operations in January 1997. The company provides a wide range of financial services to both individual and institutional investors, including investment counseling and brokerage services, portfolio management, fund investment services, corporate finance and international investment services. According to a monthly report on the ISE website titled "Breakdown Of Stock Market Transactions By Members (YTD)"), the company ranks fourth by volume of stocks traded on the ISE. According to a breakdown of stock market transactions by ISE members in 2011,the company had a 3.76% market share. Finans Invest's client portfolio amounted to EUR 5,034 million as at December 31, 2011. Total assets as at December 31, 2011 amounted to EUR 161.8 million and its net income was TL 15.3 million in 2011, compare to TL 203.1 million in TL 15.5 million, respectively.

Finans Leasing was established in March 1990. As at December 31, 2011 Finans Leasing ranked eighth in the leasing sector in Turkey, with a total business volume representing a market share of 4.9%, according to the Turkish Leasing Association. Finans Leasing's target customer segment is SMEs, and it was one of the first leasing companies in Turkey to identify the investment needs of SMEs, targeting them as a distinct market segment. Finans Leasing has a lease portfolio that is diversified across several industries, with the proportion of finance lease receivables as at December 31, 2011 of: textile 19.4%, building and construction 16.3%, manufacturing 12.8%, health and social activities 10.2%, metal 8.7%, printing 7.4%, mining and quarrying 5.6% and agriculture, hunting and forestry 4.0%. As at December 31, 2011, total assets of Finans Leasing reached TL 1,302.6 million and its net income was TL 39.1 million compared to TL 1,607.4 million and TL 37.0 million respectively, in 2010.

Finans Portfolio Management, was established in September 2000, currently manages seven ETFs, ten mutual funds, five principal protected funds, three absolute return fund, seven pension funds, two funds of funds. Finans Portfolio Management also manages discretionary portfolios for high net worth individuals and select institutional clients. As of December 31, 2011 total assets of Finans Portfolio Management amounted to TL 18.3 million and net income (including ETFs) was TL 6.4 million. In 2011, Finansbank and Finans Portfolio Management introduced four principal protected funds. The market share stood at 3.41% as of December 31, 2011. As of December 31, 2011 the company's assets under management exceeded TL 1 billion.

Finans Investment Trust, established in 1995, is a closed-end investment company, managing portfolios composed of capital and money market instruments. Its shares have been traded on the ISE since 1996. Finans Investment Trust's total assets amounted to TL 18.3 million as at December 31, 2011, and its net loss as of December 31, 2011 was TL 2.1 million.

Finans Factoring was established in 2009. As at December 31, 2011, the total assets of Finans Factoring amounted to TL 281.4 million and its net income for 2011 was TL 3.1 million, compare to TL 265.4 million and TL 2.5 million in 2010, respectively. As at December 31, 2011, total factoring receivables for Finans Factoring amounted to TL 255.8 million compared to TL 221.1 million as at December 31, 2010. The distribution of factoring receivables by industry as at December 31, 2011 was as follows: building and construction 17.6%, textile 15.1%, tourism 7.6%, chemical 6.2% and food 4.9%.

Finans Consumer Finance was established in 2008. As at December 31, 2011, the total assets of Finans Consumer Finance amounted to TL 1.9 million. Finans Consumer Finance's primary focus is to provide loans to consumers at the point of sale. Finans Consumer Finance received its BRSA audit approval in October 2009, and in September 2010 originated its first loan to activate its operation license in the Turkish market among 10 other consumer finance companies. Finans Consumer Finance aims to provide market share support to the Finansbank Group with lower risk customer loans where only the actual purchase of services or goods can be financed at the points of sale with partnership agreements.

Ibtech was established in 2005 and is located in Istanbul. As at December 31, 2011, the total assets of Ibtech amounted to TL 22.7 million and the net loss for the year was TL 2.3 million. Ibtech's focus is to design and enhance software such as Core Banking (Core Finans), credit cards, internet banking and to develop applications for the use of Finansbank.

Finansbank (Malta) Ltd was established on June 30, 2005. Subsequent to its disposal from Finansbank to NBG (Malta) Holdings Ltd in 2009, Finansbank (Malta) Ltd was renamed to NBG Bank Malta Ltd effective on March 18, 2010.

NBG Malta has attracted significant business volumes from Turkish corporates. During the third quarter of 2011, NBG Malta received the Investment Services License from the Maltese Financial Services Authority that will enable the bank to provide a full range of financial products and services to meet the constantly changing needs of corporate customers and private individuals.

Selected financial information with respect to NBG Malta as at December 31, 2011 is provided in the table below:

The Bank's international operations include the Bank's branches in Albania, Egypt and Cyprus as well as banking subsidiaries in six countries. United Bulgarian Bank A.D. in Bulgaria, Banca Romaneasca S.A. in Romania, Stopanska Banka A.D. in FYROM, Vojvodjanska Banka A.D. Novi Sad in Serbia, National Bank of Greece (Cyprus) Ltd in Cyprus and the South African Bank of Athens Ltd in South Africa, along with other subsidiaries, primarily in the leasing sector. Our international operations contributed EUR 416.8 million or 11.4% of net interest income before provisions for loan losses of the Group and accounted for EUR 10.2 billion or 9.9% of the Group's total assets as at and for the year ended December 31, 2011. Total gross loans were EUR 8.1 billion at December 31, 2011, a decrease of 6.8% from EUR 8.7 billion at December 31, 2010, whereas deposits (excluding interbank deposits) were EUR 5.7 billion at December 31, 2011, a decrease of 5.9% from EUR 6.1 billion at December 31, 2010.

Our international network is described below. In the analysis that follows, all amounts are before elimination of intercompany transactions and balances.

As at December 31, 2011, the Bank had foreign branches in four countries, including one in the United Kingdom, 27 in Albania, one in Cyprus and 18 in Egypt. At December 31, 2011, net loans of the Bank's Albania, Cyprus and Egypt operations were EUR 201.9 million, EUR 280.8 million and

EUR 86.4 million, respectively. The table below provides selected financial information of the Bank's foreign branches as at and for the year ended December 31, 2011:

The table above relates solely to the business of the Bank's foreign branches with the exception of the United Kingdom branch, which is considered part of domestic operations and is not included with the branches of the Bank's non-Greek subsidiaries.

UBB is a commercial bank with headquarters in Sofia, which provides retail and corporate finance services in Bulgaria. It was acquired in 2000 and as at December 31, 2011 the Bank held a 99.9% interest in UBB. At December 31, 2011, UBB's distribution network included 222 units: 126 "Type 1" (retail business), 46 "Type 2" (retail and micro business), 18 "Type 3" (retail, micro and SME business), nine "Type 4" (SME business) and 23 offices and operated over 780 ATMs and over 10,000 POS terminals in Bulgaria.

Selected financial information with respect to UBB as at and for the year ended December 31, 2011, is provided in the table below:

Banca Romaneasca is a commercial bank with headquarters in Bucharest, providing a range of retail, SME and corporate banking services in Romania through its head office and through 134 units in Bucharest and other cities in Romania. The Bank acquired Banca Romaneasca in October 2003 and as at December 31, 2011 held 89.07% of its share capital. EBRD was the second largest shareholder of Banca Romaneasca, with 10.2% of its share capital. On January 31, 2012, the Bank acquired the remaining 10.2% of Banca Romaneasca from EBRD through put and call arrangements as provided for in the 2005 shareholders agreement, between the Bank and EBRD. The total consideration paid amounted to EUR 26.1 million (for information on the accounting treatment of EBRD's holding, see Note 3 to the U.S. GAAP Financial Statements).

In order to further enhance the financial services offered by the Group in Romania, a new company, NBG Factoring Romania IFN S.A. has been established during 2010, with Banca Romaneasca holding 99.3% of its share capital.

Selected financial information with respect to Banca Romaneasca as at and for the year ended December 31, 2011, is provided in the table below:

Stopanska Banka is a commercial bank registered in FYROM and headquartered in Skopje. It provides payment transfers, brokerage, credit and deposit-taking services in FYROM and abroad. The Bank acquired Stopanska Banka in 2000 and as at December 31, 2011, held a 94.6% stake in it, while the remaining 5.4%, is held by other minority shareholders. On August 17, 2010, the Bank increased its shareholding in Stopanska Banka by 21.6%, acquiring the related shareholdings from EBRD and IFC (10.8% each) through the exercise of existing put and call arrangements.

Stopanska Banka operates the largest branch network in FYROM, with a dense nationwide network of ATMs and POS terminals. As at December 31, 2011, the bank had 64 branches which are transforming into modern sales outlets and is also a leader in e-banking within FYROM, promoting internet banking and offering its clients electronic payment facilities. Stopanska Banka aims to continue improving its loan portfolio by targeting high quality customers, in the SME and large company segments.

Selected financial information with respect to Stopanska Banka as at and for the year ended December 31, 2011, is provided in the table below:

In December 2006, we acquired a 99.4% stake in Vojvodjanska and in October 2007, we became the sole shareholder. In February 2007, the NBG's branch network in Serbia with 24 branches became a subsidiary, NBG Beograd. Following relevant decisions of the shareholders' general assemblies of Vojvodjanska and NBG Beograd, dated January 3, 2008, the latter was absorbed by the former and the merger was completed on February 14, 2008.

As of December 31, 2011, Vojvodjanska's 119 branches served over one million private accounts and 95 thousand company accounts and is ranked ninth in the Serbian market in terms of total assets and fourth in terms of branch network according to data from the National Bank of Serbia.

Selected financial information with respect to Vojvodjanska as at December 31, 2011, is provided in the table below:

NBG Cyprus, headquartered in Nicosia, had 14 branches, one satellite branch and one foreign exchange bureau as at December 31, 2011, and in 2010 established a representative office in Moscow. It provides a range of commercial and retail banking services. In 2011, NBG Cyprus enforced its risk management policies and processes, focusing in maintaining good asset quality, along with sufficient regulatory reserves and strong capital base. It also updated its framework of corporate governance, in alignment with regulatory requirements and Group guidelines.

Selected financial information with respect to NBG Cyprus as of and for the year ended December 31, 2011, is provided in the table below:

SABA, which the Bank founded in 1947, has eight branches, primarily in urban centers, across South Africa. It generally offers traditional commercial and retail banking services, with particular emphasis however, on commercial banking services for the SME market in South Africa.

Selected financial information with respect to SABA as at and for the year ended December 31, 2011, is provided in the table below:

As part of its International operations, the Group offers leasing services through certain of its foreign subsidiaries.

We provide insurance services primarily to individuals and companies through our wholly owned subsidiary EH and Finans Pension.

EH offers a full range of products such as life, accident and health insurance for individuals and groups, fire, catastrophe, motor, marine hull and cargo insurance, and general third party liability. Through the expertise of its personnel and the professionalism of its sales force, EH provides advanced insurance solutions that can meet the demands of the increasingly competitive Greek insurance market.

EH operates through a network of 4,200 tied agents and 1,830 independent insurance brokers, in addition to selling bancassurance products through the Bank's network.

Gross written premiums decreased to EUR 0.7 billion in 2011, from EUR 1.0 billion in 2010. In particular EH's property and casualty insurance businesses gross written premiums reached EUR 471.7 million for the year ended December 31, 2011, compared to EUR 597.9 million in 2010; and life insurance gross written premiums at an EH Group level reached EUR 263.5 million for the year ended December 31, 2011 compared to EUR 386.6 million in 2010. Bancassurance premiums for life and fire insurance amounted to EUR 89.9 million and EUR 36.9 million, respectively, in 2011 compared to EUR 161.8 million and EUR 36.2 million respectively for 2010. For more information on our bancassurance business, see "—Bancassurance" below.

With a view towards expansion in SEE, EH operates two Cypriot subsidiaries in collaboration with NBG Cyprus which are active in life and non-life insurance. EH also operates in Romania, where it holds a 94.96% share in Societate Comerciala Asigurari Garanta S.A. ("Garanta"). Garanta offers consumer credit insurance and personal accident products through the network of four banks, namely Pireaus Bank Romania, Romextera, ATE Bank and Credit Europe.

In Bulgaria, EH operates two insurance companies jointly with UBB and ALICO: UBB ALICO Life Insurance Company AD and UBB Chartis Insurance Company AD, for life and non-life insurance, respectively. These companies promote bancassurance products in the Bulgarian market. Additionally in partnership with UBB, EH operates UBB Insurance Broker AD holding 20% of the share capital.

National Insurance Brokerage S.A., a Greek insurance broker acquired in 2005 by EH, contributes to the further expansion of services provided in the maritime and aviation insurance markets.

EH provides bancassurance products through our insurance brokerage subsidiary NBG Bancassurance S.A. ("NBGB"), which assumes no insurance underwriting risk, and the Bank's extensive network in Greece.

More specifically, the types of insurance products offered to mortgage loan customers of the Bank are the following:

Finans Pension was established in 2007. Finans Pension's operations include providing life insurance and retirement income services to groups and individuals, establishing pension mutual funds and conducting private pensions and annuity insurance businesses. Finans Pension started operating in the life and accident insurance market in 2007 and in the private pension market in 2008. As at December 31, 2011 Finans Pension had established seven pension mutual funds. As at December 31, 2011, the total assets of Finans Pension reached TL 156.6 million and its net income for the year in 2011 was TL 9.6 million, compared to TL 109.1 million and TL 9.5 million in 2010, respectively.

The Bank engages in real estate management activities, including warehousing and third-party property management. As at December 31, 2011, the Bank owned 1,408 real estate units, 930 of which were buildings and 418 were land that the Bank acquired through seizure of collateral on loan foreclosures. The remaining 60 units were acquired for its own business purposes. As at December 31, 2011, the carrying value of the 1,348 units that were acquired through foreclosure was EUR 61.5 million (2010: EUR 61.0 million). The Group reports these items in other assets, under the line "Assets acquired through foreclosure proceedings" and is currently actively marketing these properties for sale.

The Bank has established guidelines and procedures relating to the disposal of properties, including properties acquired through foreclosure, in order to ensure the reliability, transparency and accountability in transactions and the completion of the process on a timely basis. The ability to dispose of properties acquired through foreclosure has been affected by the recent adverse economic conditions in Greece, as the demand for properties has stalled, resulting in a significant decrease in sales of foreclosed properties. Furthermore, the limited liquidity from the Greek banks, limited credits for mortgage loans and the increasing uncertainty further weakened the demand for properties.

NBG Pangaea, NBG's real estate investment company wholly owned by the Bank, owned 242 properties with a net book value of EUR 167.0 million as at December 31, 2011. The commercial value of the properties contributed was EUR 822.3 million at December 31, 2011. The majority of the properties are currently being leased to the Bank under long term leases.

In addition, Ethniki Kefalaiou S.A., a wholly owned subsidiary of the Bank that is engaged in asset and liability management, including asset liquidation, managed 44 properties with an aggregate book value of EUR 12.9 million as at December 31, 2011. Most of these properties have been bought from the Bank, which acquired them on realization of collateral under foreclosure procedures. In line with our strategy of streamlining our activities, we intend to continue to dispose of certain non-core real estate holdings through Ethniki Kefalaiou S.A. For the year ended December 31, 2011, proceeds from the disposal of land and buildings by the Bank and by Ethniki Kefalaiou S.A. amounted to EUR 13.2 million and EUR nil respectively compared to EUR 2.5 million and EUR nil respectively for the year ended December 31, 2010.

National Real Estate performed warehousing functions and held real estate property as a subsidiary. On March 31, 2006, the Bank absorbed National Real Estate and, on March 17, 2008, completed the spin-off of the general warehouses branch to its wholly owned subsidiary, Pronomiouhos S.A. Genikon Apothikon Hellados. See Item 4.D, "Property, Plant and Equipment" below for general information regarding our real estate holdings and Item 4.A, "History and Development of the Company—History and Development of the NBG Group" above for information regarding our principal real estate divestitures in recent years. The Bank intends to continue to divest real estate holdings as part of its non-core asset divestment strategy.

Ethnodata S.A., provide consulting and development in the area of information systems and software to other companies in the Group and to third parties. In addition, the Bank runs a training center through its subsidiary NBG Training Center S.A. for its employees as well as for other banks and companies in Greece and abroad. The Bank's training center offers training courses and advisory services.

We also engage in business consultancy services through Planet S.A., a business consultancy firm based in Athens in which the Bank held a 33.30% stake, as at December 31, 2011.

Our presence in the tourism sector is through the Bank's subsidiary, Astir Palace, owner of the Astir Palace Hotel Complex, which is currently under the management of Starwood Hotels & Resorts Worldwide Inc.

In December 2011, Astir Palace announced the successful bidder of the international competition for the 40 year long lease of the Tourist Port of Vouliagmeni, offering an amount of EUR 43.0 million. Under this long-term lease agreement, Astir Palace will establish a subsidiary company to take over the lease agreement and the management of the Tourist Port of Vouliagmeni including its upgrade and renovation.

In 2011, Astir Palace invested more than EUR 1.6 million (compared to EUR 3.1 million in 2010) in renovations and facility improvement projects. Astir Palace is currently engaged in the following projects:

The tables below present the Group's exposure at December 31, 2011 to European countries (other than Greece) that are those receiving financial support from the eurozone countries and/or the IMF, as well as those that have initiated severe austerity measures in an attempt to improve their fiscal budgets. The countries included in the tables are Portugal, Ireland, Italy, Spain and Hungary.

As at December 31, 2011, the Group has recognized a EUR 17.0 million impairment with respect to the AFS investment securities issued by Ireland. No impairment has been recognized with respect to the remaining exposures shown above.

As at December 31, 2011, we did not have any derivatives bought or sold related to the sovereign risk of these countries.

Our equity method investment portfolio includes participations in Greek corporations.

The following table sets out equity participations in which we hold an equity interest in excess of 20% but less than 50%, or in which we do not have control as at December 31, 2011:

		December 31, 2011

	Name	Country of incorporation	(%) Interest held by Group			Reported book value⁽¹⁾
						(EUR in thousands)		(USD in thousands)⁽²⁾
1.	Planet S.A.	Greece		33.30	%		1,519		2,010
2.	UBB ALICO Life Insurance Company	Bulgaria		59.97	%		4,892		6,472
3.	Eviop Tempo S.A.	Greece		21.21	%		2,682		3,548
4.	UBB Chartis Insurance Company AD	Bulgaria		59.97	%		3,020		3,995
5.	Social Securities Funds Management S.A.	Greece		20.00	%		956		1,265
6.	Drujestvo za Kasova Deinost A.D.	Bulgaria		19.98	%		1,204		1,593
7.	Teiresias S.A.	Greece		39.34	%		708		937
8.	Hellenic Spining Mills of Pella S.A.	Greece		20.89	%		—		—
9.	Pyrrichos Real Estate S.A.	Greece		21.83	%		396		524
10.	AKTOR Facility Management S.A.	Greece		35.00	%		284		376
11.	Bantas A.S.	Turkey		31.60	%		1,304		1,725
12.	NBG Funding Ltd.	U.K.		100.00	%		17,466		23,106

Equity participations in which the percentage of ownership interest held by the Group is less than 20% are accounted as portfolio investments in accordance with ASC 320 "Investments—Debt and Equity Securities", as the Group does not have the ability to influence the operations of the investees. Equity participations in which:

are accounted for using the equity method because the Group can influence the operations of the investees.

Based on the terms of the Joint Venture Agreements signed by group companies UBB and EH and companies of the Metlife and Chartis Groups, UBB ALICO Life Insurance Company AD and UBB Chartis Insurance Company AD are jointly controlled. The terms of these Joint Venture Agreements require, for the taking of certain actions, the affirmative vote of all shareholders and the unanimous agreement by the Board of Directors of all parties. Based on the above neither party has unilateral control, therefore, the Group does not consolidate these entities and accounts for them using the equity method.

NBG Funding Ltd: The Bank is the only equity investor in this entity. As the equity contribution was a nominal amount and the purpose of NBG Funding Ltd is to finance NBG Group, NBG Funding Ltd has issued debt instruments to third parties, the proceeds of which were lent to the Group. The only assets of NBG Funding Ltd are loans to and deposits with the Bank, and as a result the Bank does not have exposure to expected losses or returns in NBG Funding Ltd. Therefore, the Group is not the primary beneficiary of and does not consolidate NBG Funding Ltd.

Our business and profitability are not materially dependent on patents or licenses, industrial, commercial or financial contracts or new manufacturing processes.

The following table shows a breakdown of gross loans to customers and customer deposits in the universal banking sector for the Bank and its three main competitors in Greece as at December 31, 2011. We have compiled these figures based on publicly available information (stand-alone financial statements of the banks shown prepared in accordance with IFRS):

The macroeconomic environment in Greece—The Hellenic Republic's economic crisis, the successful sovereign debt restructuring (PSI) and the agreement on the Program for Greece

The Greek economy continued to face unprecedented macroeconomic headwinds in 2011, as mounting uncertainty about the sustainability of Greek debt and the imposition of additional austerity measures to ameliorate slippages in the 2011 budget implementation amplified recessionary pressures, creating a self-reinforcing cycle of weakening economic sentiment, declining liquidity and reduced private spending. This situation posed additional challenges to the fiscal adjustment effort by eroding the tax base and by increasing social spending needs.

As a result, the fiscal consolidation process has slowed, with the 2011 Greek government deficit declining by about 1.5% to the vicinity of 9% of GDP, following a fiscal adjustment of 5.0% in 2010. The revenue side has underperformed, due to the deepening recession, as well as to implementation shortfalls (especially regarding the timely completion of a comprehensive strategy against tax evasion).

Greece also achieved mixed results regarding progress towards the other ambitious objectives of the original adjustment program, especially regarding structural reforms, against a backdrop of high uncertainty—amplified by a severe recession, and poor results in terms of economic and policy implementation. Other related factors such as limited administrative capacity and social tensions have also hampered implementation. Slippages from 2011 fiscal targets led to the adoption of additional consolidation measures in the second half of 2011, which deepened the recession. Nevertheless, Greece achieved a substantial reduction in the general government deficit, from 15.75% of GDP in 2009 to about 9% in 2011, which is much larger than most other fiscal consolidation episodes in Organization for Economic Cooperation and Development ("OECD") countries observed in the past. Moreover, this fiscal consolidation was achieved over a period in which economic activity contracted by more than 14%, in real terms.

The pension reform and the agreed privatization plan are important institutional changes, which are expected to result in positive changes over the medium term. Labor market flexibility increased substantially and wage adjustment in the public sector was significant (exceeding 12% in the 2010-2011 period), while private sector wages declined by approximately 10% during the same period. Nevertheless, unemployment increased to an unprecedented 20.7% in the fourth quarter of 2011. However, insufficient progress was made in modernizing revenue administration and expenditure control, and steps taken in the fight against tax evasion and the prompt settlement of payments to suppliers have remained weak. Moreover, achievements in other growth-enhancing structural reforms

were not commensurate with the pressing need to accelerate productivity growth and restore competitiveness.

In 2012, Greece proceeded with the first sovereign debt restructuring process in the euro area, following the agreement by a very high portion of investors (96.9%) to participate voluntarily in the debt restructuring under PSI—following an agreement by EU leaders on October 26, 2011 and pursuant to the offer launched on February 24, 2012. This exercise imposed deep haircuts on private debt holders (53.5% of the nominal value), with the residual 46.5% replaced by short-dated EFSF paper (one and two year notes) for 15% of the original nominal value for which the Program had set aside EUR 30 billion, and the remaining 31.5% of the nominal value by the issuance of new long-term Greek bonds (with an average maturity of 20 years). The high level of participation (EUR 177 billion out of an offer for EUR 205.5 billion) reflected the fact that the Greek government introduced collective action clauses into eligible Greek law-governed bonds of the Hellenic Republic.

The Offer also contained detachable GDP-linked warrants, providing for higher returns if actual output in Greece exceeded that set out in the IMF's medium-term debt sustainability scenario as well as the payment of accrued interest on the exchanged bonds, also in the form of short-term EFSF notes. Holders of the new bonds will also be entitled to the benefit of a cofinancing agreement with the EFSF, linking the new bonds to the Hellenic Republic loans from the EFSF up to EUR 30 billion. The exchange was launched on February 24, 2012 (and for bonds issued by state enterprises and guaranteed by the Hellenic Republic on April 4, 2012) and completed by the bonds issued under Greek law on March 12, 2012, while the offer was extended until April 25, 2012 for bonds issued under foreign law to accommodate the specific terms regarding the holding of bondholder meetings.

The new Greek bonds have a term of 30 years (final maturity is in 2042) and an amortization period starting on the eleventh anniversary of the issue date. They bear a coupon of 2.0% p.a. until 2015, 3.0% p.a. until 2020, 3.65% p.a. until 2021 and 4.3% p.a. thereafter. Greece's debt service capacity will also be improved by the fact that official creditors lowered spreads on EU loans to Greece disbursed under the original program to 150 bps over Euribor and pushed maturities out beyond 2020. The second loan facility will be funded through the EFSF at cost, with loans amortizing over 25 years (with grace periods of 10 years) and interest paid annually while the IMF contribution will be financed through the lower-cost extended financing facility (EFF). Furthermore, governments of member states whose central banks currently hold Greek government bonds in their investment portfolio (which was excluded from the exchange) commit to pass on to Greece amounts equal to any future income accruing to their national central bank stemming from this portfolio until 2020 (estimated benefit of 1.8% of GDP).

The successful completion of the PSI implies a significant decline of the Greek debt burden, as well as a sharp reduction in debt servicing needs through low interest rates on the new bonds and a substantial extension of the average debt maturity. The PSI achieves nominal debt relief on EUR 199 billion of eligible bonds, directly reducing Greece's debt burden by approximately 50% of GDP from a level of 165% of GDP at the end of 2011. Interest service costs are reduced as the effective average cost of Greek debt servicing is brought down to approximately 3.3% in the 2012-2014 period, from about 5% in 2011. Finally, amortization payments are minimal until 2020 due to the long grace periods on the PSI bonds and a large part of the official financing.

Overall, the completion of debt exchange is expected to result in a sustainable reduction of Greek debt to below 120% of GDP by 2020, and below 90% by 2030 (from 165% in 2011), with the expected debt trajectory being relatively more robust even under more adverse macroeconomic conditions or outcomes of the Program's measures compared with the baseline projections of the Program. Nevertheless, due to the large disbursements under the Program in 2012, the debt stock is expected to revert to 163% of GDP at the end of 2012, before declining gradually towards 120% by 2020. Due to the significant debt and debt service reduction, the required primary surplus target for the 2014-2019

period was scaled back from an ambitious 6.5% of GDP under the original program to 4.5% of GDP for the 2014-2020 period.

During the debt exchange process, the Hellenic Republic's long-term sovereign credit rating was lowered to the lowest rating available (corresponding to selective default state) by all rating agencies. The downgrade was triggered after Greece retroactively inserted collective action clauses in the documentation of certain sovereign debt series governed by Greek law. The credit rating of the Hellenic Republic has been subsequently upgraded after the completion of the exchange of Greek government bonds subject to Greek law (corresponding to approximately 94% of all eligible bonds in the exchange) by Fitch to B- and by Standard & Poor's to CCC, while Moody's has retained its rating at C.

In March 2012, the Greek government agreed to the Program, a second economic adjustment program, the term of which extends through 2015 and is jointly supported by the IMF and eurozone member states. This Program will replace the original program of EUR 110 billion, agreed in May 2010, for the period 2010-2013 and had the form of a cooperative package of IMF and eurozone member states funding. The international assistance loans disbursed under the original program amounted to EUR 73 billion. Of this amount, EUR 52.9 billion has been sourced from eurozone member states, and EUR 19.9 billion from the IMF. In the Program, for the years 2012-2015, eurozone member states through the EFSF and the IMF commit the undisbursed amounts from the first program, plus an additional EUR 130 billion, covering Greece's expected funding needs fully for the four-year period. During this period, the EFSF could provide an overall amount of EUR 144.7 billion, while the IMF will contribute EUR 28 billion during four years under its extended fund facility (EFF mechanism). The Program will be heavily front-loaded, especially regarding financing from eurozone member states—disbursements of about EUR 75 billion is expected to occur in the first half of 2012— to fund EUR 35.7 billion of PSI debt enhancements and accrued interest and EUR 25 billion to recapitalize Greek banks through the HFSF. The IMF contribution of EUR 28 billion will be disbursed in 17 equal tranches over a four-year period ending 2015.

The disbursements of financial assistance to Greece are conditional on quarterly reviews for the duration of the arrangement. The release of the tranches by the lenders will be based on observance of quantitative performance criteria and a positive evaluation of progress made with respect to policy criteria set by the Memorandum of Economic and Financial Policies (MEFP) and the Memorandum underlying the Program and committed to by the Greek government. Moreover, in April 2012, the Greek parliament passed new legislation prioritizing government debt service obligations to private and official holders of Greek debt over any other fiscal use of Program funding, and the same is committed to occur with primary budget surpluses which are expected to be achieved from 2013 onwards.

The Program also sets forth a blueprint for the stabilization of public finances and the economy of Greece and safeguarding financial stability in Greece. Overall, the implementation of the growth-enhancing structural reforms gains prominence in the overall implementation of the Program, while the debt restructuring and higher official financing allows a more realistic pace of fiscal adjustment and a more gradual privatization process. Specifically, the strategy is primarily based on expenditure reduction—so as to achieve a primary surplus of 1.8% of GDP in 2013, and 4.5% of GDP for the period 2014-2020—and the timely and decisive implementation of growth enhancing structural reforms. The Program also foresees more aggressive nominal wage adjustments and benefit cuts, to reduce costs and thus improve price competitiveness, and permit Greece's transition to a more investment and export-led growth model.

The adjustment process will be also based on a successful completion of an ambitious privatization agenda, which has been adapted to the current conjuncture and the impact of recession on asset valuations. Similarly, the ambitious structural reform agenda includes measures to increase fiscal efficiency, strengthen Greece's institutional capacity and improve efficiency of the labor market and product and service markets.

At the same time, Greece is receiving an unprecedented level of technical assistance—with a view to enhancing the government's capacity to implement policies—coordinated by the EU Commission's taskforce under the guidance of the European Commission, Member States, and the IMF. The assistance concerns several areas which are crucial for the success of the Program, such as tax administration and the fight against tax evasion, public financial management, public administration and business environment reforms.

Against this background, the Greek economy continues to face significant short-term challenges. Economic activity is expected to continue on a downward trend in 2012, declining by around 5.0% year-on-year (according to the latest IMF, EU program forecasts), hampered by additional fiscal policy tightening and further reductions in private and public sector wages and pensions, continuing high uncertainty and high international oil prices. Consequently, labor market conditions will deteriorate further, likely increasing social fatigue and social tensions. At the same time, the support from the export sector, and especially tourism, will be lower compared with 2011, mainly due to the weaker outlook of eurozone economies.

Although the beneficial impact from the activation of the new Program may support an improvement in the economic environment by late-2012, the turning point for economic activity in Greece is expected to be delayed to 2013 according to latest EU/IMF forecasts.

For more detail on the risks and uncertainties relating to a failure to successfully implement the Program, see Item 3.D, "Risk Factors—Risks Relating to the Hellenic Republic Economic Crisis".

In August 2011, the Bank of Greece mandated BlackRock Financial Management Inc. ("BlackRock"), a U.S.-based investment, advisory and risk management company to conduct an independent diagnostic exercise of the domestic loan portfolio of the largest Greek banks, including the Bank. This was in accordance with the commitment undertaken by the Bank of Greece under the Program in the context of ensuring that the Greek banks are adequately capitalized. The exercise has been completed and its findings have been communicated to the individual banks. These losses are offset by the existing provisions (allowance for loan losses) as at the end of December 2011 (EUR 5.4 billion of which EUR 1.7 billion relates to loan to the Hellenic Republic and loans exchanged

in PSI) as well as future pre-provision earnings in Greece for the period 2012-2014 and the earnings from the Bank's international subsidiaries. The earnings estimates provided by the Bank based on the macroeconomic guidance provided by the Bank of Greece were vetted by the Bank of Greece with the assistance of an external consultant, Bain Capital.

We estimate that the Bank's future earnings and current level of allowance for loan losses are sufficient to cover the estimated loan losses in both the baseline and adverse scenario, implying no additional capital needs for the Bank arising from the BlackRock loan diagnostic.

The Program also contains measures to protect the stability of the banking system by providing capital support. The HFSF, funded by the government out of the resources available from the IMF and EU under the Program, was established under Greek Law 3864/2010 with a view to ensuring adequate capitalization of the banking system. If supervisory assessments conclude that a bank's capital buffer might fall below adequate levels, the shareholders will be invited to immediately bring additional capital or take capital support from the HFSF. The minimum capital ratios have been set at 9% core capital by the end of September 2012 (calculated in accordance with the EBA definition, which includes preference shares issued by the Bank and purchased exclusively by the Greek government under pillar I of the Hellenic Republic Bank Support Plan increasing to 10% by the end of June 2013).

A prior action for the approval of the Program was the approval of Greek Law 4051/2012, which modified the governance structure of the HFSF and altered the Greek bank recapitalization framework. Pursuant to this law, the decision-making bodies of the HFSF will henceforth be the General Council and the Executive Committee. The General Council consists of five members, and the Executive Committee consists of three members. A representative of the Ministry of Finance and an appointee of the Bank of Greece sit on the General Council, while an appointee of the Bank of Greece sits on the Executive Committee. Save for these persons, the other members of the General Council and the Executive Committee are selected from a special committee that consists of an equal number of representatives of the Ministry of Finance and the Bank of Greece. Representatives of the EC and ECB may participate in this committee. The appointment of the members of the General Council and Executive Committee, save for those appointed by the Bank of Greece and the Ministry of Finance, requires the consent of Euro Working Group.

The HFSF, a fully-owned entity of the Greek government, will have an initial duration of seven years. Any shares remaining in the HFSF at the time it ceases its activities will be transferred to the Hellenic Republic. The amount of funds earmarked for the HFSF out of the Program is resources to date is about EUR 50 billion.

As stipulated in its founding law 3864/2010, the HFSF will manage its participations in the banks with a view to safeguarding the value of its holdings, minimizing the risks for the Greek public and ensuring adequate competition in the Greek banking system.

More specifically, the recapitalization of each credit institution will occur through common equity shares with restricted voting rights if the individual credit institution succeeds in raising at least 10%, as further specified by a Ministerial Act, of its capital shortfall compared with the above-stated minimum core capital targets. Otherwise, a bank would be recapitalized by standard common equity to be held by the HFSF. In the former case, the recapitalization will occur through common equity with voting rights only for resolutions regarding modifications of its Articles of Association, including increase or reduction of the share capital of the Bank or provision of relevant authorization to the Board of Directors of the Bank, merger, division, conversion, revival, extension of duration or dissolution of the Bank, material asset transfers, including the sale of subsidiaries, or any other matters that require an increased majority, as explicitly provided in Greek Law 2190/1920). The HFSF will decide on the procedure for disposing its shares at a time it deems appropriate, and in any case within five years of its participation in the credit institution's share capital increase. If a bank is unable to raise at least

10% of its capital shortfall from the private sector, the HFSF shall dispose of its shares in the credit institution within two years from its participation in the credit institution's share capital increase, which may be extended for two further years by decision of the Minister of Finance. A Ministerial Act is required to define the conditions for the conversion of these securities and other terms of the recapitalization framework, and this is expected to occur soon after the formation of the new government.

In view of the delay in completing the recapitalization framework, pursuant to Greek Law 3864/2010 as amended by legislative act dated April 19, 2012, the HFSF, following a decision by the Bank of Greece, would issue to credit institutions which have been deemed viable by the Bank of Greece and have submitted a request for recapitalization to the HFSF, a certificate by which the HFSF would commit to participate in the share capital increase of such credit institutions for an amount determined by the Bank of Greece, provided that: (i) the business plan of the credit institution has been assessed by the Bank of Greece as viable and credible, (ii) the above request has been approved by the Bank of Greece and notified to the EC, and (iii) the Bank of Greece considers the issuance of the certificate necessary for the smooth continuation of the credit institution's operation as a going concern and the attainment of the capital requirements in accordance with the decisions of the Bank of Greece, as well as for the maintenance of the stability of the Greek banking system.

On April 4, 2012, the Bank of Greece sent a letter to the Bank, by which it informed the Bank that its capital adequacy ratio was below the acceptable level and therefore suggested that the Bank should submit to the HFSF a request for capital support, along with a three-year business plan. Following receipt of this letter, the Bank submitted the necessary documents, and the HFSF provided the Bank with the relevant certificate, by which it committed to participate in the Bank's share capital increase. In an effort to safeguard the participation of Greek credit institutions in the Eurosystem's liquidity operations, a capital injection by the HFSF may be granted before the completion of the share capital increase of credit institutions. More specifically, pursuant to article 6 of Greek Law 3864/2010, as recently amended by legislative act dated April 30, 2012, following a decision by the Bank of Greece, and upon consent of the EC, the ECB and the EFSF, the HFSF may advance its contribution to the share capital increase of a credit institution, or part thereof, up to the amount to be determined by the Bank of Greece, provided that: (a) the credit institution has submitted a recapitalization request, along with a business plan and a detailed timetable for the implementation of the measures provided for in the business plan; (b) the recapitalization request has been approved by the Bank of Greece and notified to the EC, and the credit institution's business plan has been assessed by the Bank of Greece as viable and reliable; (c) the Bank of Greece deems that the advance payment of the contribution is necessary for the attainment by the credit institution of the capital adequacy requirements according to the decisions of the Bank of Greece, for the maintenance of the access of the credit institution to the monetary policy operation of the Eurosystem and for the stability of the Greek banking sector; and (d) the credit institution has executed a pre-subscription agreement with the HFSF regarding the share capital increase of the credit institution. In this case, the HFSF shall have the right to appoint up to two representatives in the credit institution's board of directors and may request from the credit institution any data and information it deems necessary in order to fulfill its purpose, carry out due diligence and generally exercise its rights. The advance amount shall be deposited in an account held by the credit institution at the Bank of Greece exclusively for the purpose of HFSF's participation in the above share capital increase, and shall be released upon certification of payment of the share capital according to par. 2 of article 11of Greek Law 2190/1920. Until its release, the HFSF's contribution shall be used by the credit institution only to ensure its liquidity through sale and repurchase transactions with market counterparties or in the Eurosystem though the ECB or the Bank of Greece. On May 3, 2012, by Act of Ministerial Cabinet, the minimum terms that must be included in the pre-subscription agreement to be concluded between the HFSF, the credit institution and the EFSF were determined.

The representatives of the HFSF in a credit institution's board of directors shall have the right:

For more information on the HFSF please see below "Regulation and Supervision of Banks in Greece".

The implementation of Program measures is subject to a range of substantial risks including:

Accordingly, these are extremely uncertain times for the banking sector in the Hellenic Republic and the EU and it is difficult for us to predict or state with any degree of certainty whether the Program and any amendments thereto, will be implemented successfully and, if implemented successfully, whether it will have the effects intended, and how severe an impact on our results of operations and financial condition an implementation of the Program and any amendments thereto, successful or unsuccessful, might have. For more detail on the risks and uncertainties that we face regarding the failure to implement the stabilization plan and otherwise, see Item 3.D, "Risks Relating to the Hellenic Republic Economic Crisis".

The Greek banking sector has expanded rapidly in recent years from the early 1990s, due to both deregulation and technological advances. This trend was reversed since the outbreak of the global financial crisis in 2008. As of January 2012, according to information from the Bank of Greece, there were 57 credit institutions in Greece (as compared to 62 a year ago): 17 Greek banks, 16 cooperative banks and 23 foreign banks, as well as one specialized credit institution. In March 2012, the Bank of Greece revoked the licenses of three cooperative banks, reducing the number of institutions operating in the country to 54, and the number of cooperative banks to 13.

Traditionally, commercial banks have dominated the Greek financial services market. However, specialized credit institutions have expanded into commercial banking thereby increasing competition in the market. The distinction between commercial and investment banks has ceased to formally exist and the Bank of Greece classifies all banks operating in Greece as "universal banks", with the exception of the Consignment Deposits and Loans Fund (which is a legal entity under public law, fully owned and controlled by the Hellenic Republic). Universal banks have been shielded to some degree from the deteriorating interbank lending conditions as they are able to access funding through deposits, compared with institutions that are unable to draw on such deposit bases.

There are three banks that are controlled, directly or indirectly, by the Hellenic Republic: Bank of Attica, Hellenic Postbank, and ATE Bank (formerly the Agricultural Bank of Greece). Over the last ten years, the Hellenic Republic has proceeded with privatizing a large number of credit institutions. A majority stake of Geniki Bank was disposed of to Société Générale in early 2004, followed by the disposal of a majority stake of Emporiki Bank to Crédit Agricole in August 2006. In addition, the Hellenic Republic proceeded with the partial privatizations of the Hellenic Postbank and ATE Bank through the listing of their shares on the ATHEX.

In the years 2000 to 2008, many of the major Greek banks have expanded internationally, establishing or enhancing their presence in SEE. In addition to the Bank's acquisition of controlling stakes in Finansbank and Vojvodjanska during 2006 and the first months of 2007, other Greek banks have proceeded with acquisitions of banks in the region. Eurobank EFG became the owner of 100% of the shares of Nacionalna Stedionica Banca in Serbia in March 2007 and took control of over 90% of DZI Bank in Bulgaria in December 2006. Also, in March 2007, Eurobank EFG concluded the purchase of a 99% stake of Universal Bank in Ukraine, and completed the acquisition of the majority of shares in Tekfenbank in Turkey. Piraeus Bank acquired a nearly 100% stake in International Commerce Bank JSC in the Ukraine in 2007, and Alpha Bank acquired the majority of shares of the Ukrainian OJSC Astra Bank in 2008. ATE Bank made its first expansion steps in SEE by acquiring a 20% stake in AIK

Bank in Serbia and a stake of MindBank in Romania during the same year (source: banks' financial statements for 2006 and 2007).

The economic downturn of the recent years has led the Greek financial institutions to plan or make divestments, in order to shield their balance sheet against the new adverse conditions. In 2011, Eurobank EFG announced its agreement with Raiffeisen Bank International AG in Poland ("RBPL") to dispose of 70% stake of its operations in the country (Polbank EFG) and exchange the remaining 30% stake for a 13% stake in the combined RBPL-Polbank EFG operations. In April 2012, Eurobank EFG signed an agreement with Kuwaiti Burgan Bank, to dispose of its 70% holding in its Turkish subsidiary Eurobank Tekfen.

In January 2012, according to data published by the Bank of Greece, there were 23 foreign-owned or incorporated credit institutions that were established in the Greek banking market—4 credit institutions less than a year ago. These include Citibank, Bank of Cyprus and HSBC. The majority of foreign banks operating in Greece have little presence in retail banking services.

The Consignment Deposits and Loans Fund, an autonomous financial institution organized as a public law legal entity under the supervision of the Ministry of Finance, is the only remaining specialized credit institution in Greece. Its activities include the acceptance of consignments in cash or in kind, the granting of housing loans to qualifying borrowers, primarily civil servants, and the support of regional development.

As of April 2002, Greek law allows non-banking institutions that are licensed by the Bank of Greece to extend consumer credit or loan facilities. These institutions are in direct competition with universal banks in the consumer credit sector.

The Macroeconomic Environment and the Banking Services Sector in SEE and Turkey⁽¹⁾

In 2011, the macroeconomic picture in South Eastern Europe-6 ("SEE-6", comprising Albania, Bulgaria, Cyprus, FYROM, Romania and Serbia) and Turkey was mixed.

In SEE-6, growth recovered only slightly, inflation moderated, and external imbalances receded further; however, the banking sector performance weakened. Economic activity recovered moderately, due to subdued domestic demand, reflecting, inter alia, tight incomes and fiscal policy, and weak credit activity. Real GDP growth rate in SEE-6 is estimated to have rebounded to 2.1% in 2011 after two consecutive years of negative growth. Inflation decelerated to 3.5% year-on-year in December 2011 from 6.9% in December 2010, reflecting subsiding domestic demand, favorable food prices, and strong base effects (e.g., an increase in the value-added tax in Romania in 2010). On another positive note, the current account deficit remained at the 2010 level of 4.9% of GDP, down from 6.4% in 2009 and 15.1% in 2008, while the quality of its financing improved. In fact, non debt-generating foreign direct investments covered 63.2% of the current account deficit in 2011 against 47.6% in 2010.

Despite this relatively improved operating environment, activity remained sluggish due to limited financing of the majority foreign-owned banking sector by parent banks as well as tight credit standards by banks due to deteriorating asset quality. Indeed, in SEE-6, financial intermediation embarked on a downward trend. Loans and deposits recorded low growth rates of 6.2% year-on-year and 7.1% year-on-year, respectively, in 2011 while the corresponding penetration rates stood at 66.9% and 61.6%.

Lending to corporations was the main driver of credit activity in SEE-6 as a whole, growing by 9.3% year-on-year in December 2011 and bringing the loans to corporates-to-GDP ratio to 38.1%.

As a result, the profitability of the banking sector in SEE-6 remained weak, and in Cyprus the profitability was negative. Overall, due to the participation of Cypriot banks in the PSI (with the three largest banks—Bank of Cyprus, Marfin Bank, and Hellenic Bank posting losses of EUR 3.6 billion in 2011). Profitability was also hampered, but to a smaller extent, by an environment of scarce and more expensive external financing, which led, in some countries, to a "deposit war", and subdued credit activity, reflecting bank efforts to contain the deteriorating asset quality (with the non-accruing loans standing around 16%).

By contrast, in Turkey, growth remained strong and the banking sector performance remained robust. Real GDP growth remained high at 8.5%, following a rebound to 9.2% in 2010 from negative of 4.8% in 2009. Economic activity maintained momentum, on the back of buoyant domestic demand. Domestic demand growth remained strong, supported by increasing capital inflows, in line with the easing of the global financial crisis, and strong credit activity. However, inflation soared to 10.5% year-on-year in December 2011 from a historical low of 6.4% in December 2010, despite tighter fiscal stance and a more prudent monetary policy, on the back of unfavorable domestic food prices, strong domestic demand, and a sharp 12.7% depreciation of the TL in 2011 against the basket of 50% EUR and 50% USD. On another negative note, the current account deficit widened markedly to the high level of 10.0% of GDP in 2011 from 6.4% in 2010 and 2.3% in 2009. Non debt-generating foreign direct investments remained weak, covering only 17.4% of the current account deficit in 2011 against 16.2% in 2010.

In this environment of strong growth, the profitability of the Turkish banking sector remained impressive, with the full-year Return on Average Equity standing at 15.5%, benefiting from very strong credit activity, despite the authorities efforts to contain it at 20%-25%, and improving bank asset quality, with the non-accruing loan ratio reaching an all-time low of 2.7% in December 2011. Loans and deposits rose by 31.4% year-on-year and 12.5% year-on-year, respectively, in 2011, while their corresponding penetration rates stood at 49.1% and 50.7% of GDP.

Turkey remains dependent on external financing, and its economy is highly exposed to a turnaround in global activity and investor sentiment. Turkey's current account deficit is expected by the IMF to ease markedly in 2012. In the event and provided that the bulk of the current account deficit continues to hinge on large portfolio inflows and a drawdown of bank and non-bank residents' assets abroad, as was the case in the past two years, Turkey will continue to be vulnerable to sudden shifts in global investor sentiment. As a result, there can be no assurance that Turkey will not experience volatility in domestic financial markets. Such likelihood would increase if international market turbulence continues and would have a negative impact on Finansbank's business and could adversely affect the Group's business, results of operations and financial condition.

NBG Group is subject to financial services laws, regulations, administrative actions and policies in each location where the Group operates. The Bank of Greece is the central bank in Greece. It is responsible for the licensing and supervision of credit institutions in Greece, in accordance with Greek Law 3601/2007 on licensing, operation, supervision and control of credit institutions, Greek Law 3746/2009 on the Greek deposit and investment guarantee fund, Greek Law 3691/2008 on anti-money laundering provisions, Greek Law 3862/2010 on payment services and credit institutions and other relevant laws of Greece, each as amended and in force. Also, in accordance with Greek Law 1266/1982 on organizations exercising monetary, credit and currency policy, the Bank of Greece has regulatory and supervisory powers relating to the operation of credit institutions in Greece.

Regulation of the banking industry in Greece has changed in recent years as Greek law has changed largely to comply with applicable EU directives. In August 2007, the EU directives

(2006/48/EC and 2006/49/EC) regarding the adoption of the revised Basel Capital Accord, known as Basel II, were incorporated into Greek law relating to the business of credit institutions and to the capital adequacy of investment firms and credit institutions. Following this, on August 20, 2007, the Bank of Greece issued ten Governor's Acts specifying the details for the implementation of Basel II, which took effect from January 1, 2008. These Acts were amended during 2010, in order to adopt the respective amendments of the EU directives as regards risk management, own funds, capital adequacy and large exposures.

Recently, the Greek government has revised the terms of the Hellenic Republic Bank Support Plan to strengthen Greek banks' capital and liquidity positions. For more information concerning our participation in this plan, see "—The Hellenic Republic's Bank Support Plan" below. In addition, in response to the unprecedented economic downturn in the Hellenic Republic, in early May 2010, the Greek government agreed to the IMF/eurozone Stabilization and Recovery Program, replaced by the Program, a second economic adjustment program, in March 2012. This program was amended on February 9, 2012.

Under Greek Law 3601/2007, the Bank of Greece Governor's Acts and other relevant laws of Greece, the Bank of Greece, in the exercise of its control over credit institutions, has the power to conduct audits and inspect the books and records of credit institutions. If a credit institution breaches any law or a regulation falling within the scope of the supervisory power attributed to the Bank of Greece, the Bank of Greece is empowered to:

Greek Laws 4021/2011 and 4051/2012 have substantially amended the provisions of Greek Law 3601/2007 regarding supervision, resolution and liquidation of credit institutions. The new provisions of Greek Law 3601/2007, in general terms, (i) reinforce the supervisory powers of the Bank of Greece in addressing an actual or potential breach by credit institutions of Greek Law 3601/2007 and the relevant decisions of the Bank of Greece; (ii) extend the role and powers of a commissioner appointed by the Bank of Greece to manage troubled credit institutions and (iii) empower the Bank of Greece to take specific resolution measures vis-à-vis credit institutions. These provisions aim to enhance the framework for the supervision and control of credit institutions and to introduce resolution powers to the Bank of Greece in order to protect financial stability and public confidence in the Greek financial system.

Pursuant to the amended provisions of Greek Law 3601/2007, the Bank of Greece has the following additional powers:

The circumstances in which the Bank of Greece may take resolution measures under Greek Law 3601/2007, as amended by Greek Laws 4021/2011 and 4051/2012, include, inter alia, the following:

Whenever the Bank of Greece decides that a credit institution fulfills any of the above circumstances, it must notify the HFSF and provide the HFSF with information about the financial situation of such credit institution, as well as any other information that the HFSF may need in order to apply the resolution or the recapitalization measures. The Bank of Greece and the HFSF will execute a memorandum of understanding, which shall provide the information that must be exchanged between them and the details of their cooperation with respect to such credit institutions.

The shareholders or the creditors of the credit institution who believe that their financial position has deteriorated following the implementation of the resolution measures on the credit institution may request compensation from the Greek State in an amount that would restore them to the financial position they would have had if a special liquidation had instead taken place.

The regulatory framework has been effected by the new recapitalization framework and the creation of the HFSF (see Item 4.B, "Business Overview—The Macroeconomic Environment in Greece—The Hellenic Republic's economic crisis, the successful sovereign debt restructuring (PSI) and the agreement on the Program for Greece-Recapitalization Framework").

In November 2008, the Greek Parliament passed Greek Law 3723/2008 setting forth the Hellenic Republic Bank Support Plan initially at the amount of EUR 28 billion and following increases thereof, at the amount of EUR 98 billion. The law was passed with the goal of strengthening Greek banks' capital and liquidity positions in an effort to safeguard the Greek economy from the adverse effects of the international financial crisis. Moreover, the Hellenic Republic Bank Support Plan was revised by Greek Laws 3844/2010, 3845/2010, 3872/2010, 3956/2011, 3965/2011, 4063/2012 and ministerial decisions no. 132624/B.527/2010, 29850/B.1465/2010, 59181/B.2585/24.12.2010, 29264/B.1377/2011, 57376/B.2355/29.12.2011, 57863/B.2535/29.12.2011, and 5209/B.237/2012, which rendered preference shares of Pillar I referred to below not mandatorily redeemable, increased the return on the preference shares of Pillar I, amended the payment of dividends prohibition, increased the total amount that can be provided by the Hellenic Republic under Pillar II referred to below, extended the veto power of the State's representative on the decisions of the Board of Directors, extended the duration of the period for participation in the Plan until June 30 2012, and increased the commission paid to the Hellenic

Republic for Hellenic Republic guarantees provided for under Pillar II from July 1, 2010 onwards. In May 2011, the Hellenic Republic, in accordance with Greek Law 3965/2011, approved an additional disbursement of EUR 30 billion in the form of Greek government guaranteed bonds, thereby increasing Pillar II of the Hellenic Republic Bank Support Plan to EUR 85 billion.

The Hellenic Republic Bank Support Plan, as currently applicable, is comprised of the following three pillars.

Pillar I: up to EUR 5 billion in capital designed to increase Tier I ratios. The capital will take the form of non-transferable voting redeemable preference shares with a 10% fixed return. The shares are to be mandatorily redeemed at the subscription price either within five years after their issuance or earlier with the approval of the Bank of Greece. In accordance with Ministerial Decision 2/98029/0023A/17-01-2012, the redemption of the preference shares issued in favor to the Greek State, will, from December 31, 2011 onwards, be effected at the original par value of the preference shares through the exchange of Greek government bonds or treasury bills. At any redemption date the Greek government bonds or treasury bills to be exchanged should have the following characteristics:

However, if the preference shares are not redeemed within five years from their issuance and if the participating bank's general meeting of shareholders has not approved their redemption, the Greek Minister of Finance will impose, pursuant to a recommendation by the Bank of Greece, a gradual cumulative increase of 2% per year on the 10% fixed return provided for during the first five years from the issuance of the shares to the Hellenic Republic. The issue price of the preference shares will be the nominal value of the common shares of the last issue of each bank. Pursuant to decision No. 54201/B2884/2008 of the Minister of Finance, as currently in force, the banks will be required to convert the preference shares into common shares or another class of shares if the redemption of the preference shares as described above is impossible, because the Tier I capital of those banks after such redemption would be less than the level set by the Bank of Greece. The conversion ratio will only be determined at the time of conversion and the full dilutive effect of any such conversion will therefore only be known at that time.

Pillar II: up to EUR 85 billion in Hellenic Republic guarantees in accordance with Greek Law 3965/2011. These guarantees will guarantee new borrowings (excluding interbank deposits) to be concluded until June 30, 2012 (whether in the form of debt instruments or otherwise) and with a maturity of three months to three years. These guarantees will be granted to banks that meet the minimum capital adequacy requirements set by the Bank of Greece as well as criteria set forth in Decision No. 54201/B.2884 of the Minister of Finance, as currently in force, regarding capital adequacy, market share size and maturity of liabilities and share in the SME and mortgage lending market. The terms under which guarantees will be granted to financial institutions are included in Decision Nos. 2/5121/2009, 29850/B.1465/2010 and 5209/B.237/2012 of the Minister of Finance.

On May 3, 2010, the Greek parliament passed Greek Law 3844/2010 amending Greek Law 3723/2008 to render preference shares not mandatorily redeemable. However, if the preference shares are not redeemed within five years from their issuance and if the participating bank's general meeting of shareholders has not approved their redemption, the Greek Minister of Finance will impose, pursuant to a recommendation by the Bank of Greece, a gradual cumulative increase of 2% per year

on the 10% fixed return provided for during the first five years from the issuance of the shares to the Hellenic Republic.

Pillar III: up to EUR 8 billion in debt instruments. These debt instruments will have maturities of less than three years and will be issued by the Public Debt Management Agency by June 30, 2012 to participating banks meeting the minimum capital adequacy requirements set by the Bank of Greece. These debt instruments bear no interest, are issued at their nominal value in denominations of EUR 1,000,000 and are listed on the ATHEX. They are issued by virtue of bilateral agreements executed between each participating bank and the Hellenic Republic. The debt instruments must be repaid at the applicable termination date of the bilateral agreement (irrespective of the maturity date of the debt instruments) or at the date Greek Law 3723/2008 ceases to apply to a bank. The participating banks must use the debt instruments received only as collateral for refinancing, in connection with fixed facilities from the ECB or for interbank financing purposes. The proceeds of liquidation of such instruments must be used to finance mortgage loans and loans to SMEs at competitive terms.

Participating banks that use either the capital or guarantee facility will have to accept a government-appointed member of the Board of Directors as State representative. Such representative will be in addition to the existing members of the Board of Directors and will have veto power on strategic decisions or decisions resulting to a significant change in legal or financial position of the Bank and for which the shareholders approval is required. The same veto power applies to corporate decisions relating to the dividend policy and the compensation of the Chairman, the Managing Director and the other members of the Board of Directors of the participating banks, as well as its General Directors and their deputies. However, the State appointed representative may only utilize its veto power following a decision of the Minister of Finance or if he considers that the relevant corporate decisions may jeopardize the interests of depositors or materially affect the solvency and effective operation of the participating bank. Moreover, the State appointed representative has full access to the bank's books, on reports for restructuring and viability, medium-term funding needs of the Bank as well as on reports for the level of financing of the Greek economy. In addition, participating banks will be required to limit maximum executive compensation to that of the Governor of the Bank of Greece, and must not pay bonuses to senior management as long as they participate in the Hellenic Republic Bank Support Plan. Also, during that period, dividend payouts for those banks will be limited to up to 35% of distributable profits of the participating bank (at the parent company level). According to the provisions of article 28 of Greek Law 3756/2009 and decision 20708/B/1175/23.4.2009 of the Minister of Economy and Finance, banks participating in the Hellenic Republic Bank Support Plan were allowed to distribute dividends to ordinary shareholders only in the form of shares, but excluding treasury shares, for the financial year ended on December 31, 2008. Also, pursuant to the provisions of article 39 of Greek Law 3844/2010, article 28 of Greek Law 3756/2009 was modified to provide that distributions to ordinary shareholders were restricted to share distributions (excluding treasury shares), for the financial years ended on December 31, 2008 and 2009. These provisions did not apply to the payments of dividends in respect of preference shares issued by credit institutions and traded on foreign organized markets. However, these cannot be treasury shares. See Item 8.A, "Consolidated Statements and Other Financial Information—Policy on Dividend Distributions". Pursuant to article 19 of Greek Law 3965/2011 and article 4 of Greek Law 4063/2012, the distribution of dividends for the financial years ended 2010 and 2011 is also restricted to share distributions.

To monitor the implementation of the Plan, Greek Law 3723/2008 provided for the establishment of a supervisory council (the "Council"). The Council is chaired by the Minister of Finance. Members will include the Governor of the Bank of Greece, the Deputy Minister of Finance, who is responsible for the Greek General Accounting Office, and the state representative at each of the participating banks. The Council convenes on a monthly basis with a mandate to supervise the correct and effective implementation of the Plan and ensure that the resulting liquidity is used for the benefit of the depositors, the borrowers and the Greek economy overall. Participating banks which fail to comply with

the terms of the Plan will be subject to certain sanctions, while the liquidity provided to them may be revoked in whole or in part.

Towards the end of 2008, the Bank, together with Eurobank EFG, Alpha Bank, Piraeus Bank and ATE Bank, among others, announced that it would participate in the Plan. The deadline for inclusion in the Plan initially was February 1, 2009, but was subsequently extended to June 30, 2012.

According to a resolution adopted by shareholders at an extraordinary General Meeting held on January 22, 2009, the Bank issued 70 million redeemable preference shares at a par value of EUR 5.00 each, with the cancellation of the preemptive rights of the existing shareholders in favor of the Hellenic Republic. Furthermore, on December 22, 2011, an extraordinary General Meeting approved a) the share capital increase by EUR 1,000 million through the issue of additional 200 million Redeemable Preference Shares at a nominal value of EUR 5.0 each with the cancellation of the pre-emptive rights of the existing shareholders in favor of the Hellenic Republic, and b) the revocation of the decision of an extraordinary General Meeting held on November 26, 2010 regarding the repurchase by the Bank of the 70 million Redeemable Preference Shares in favor of the Hellenic Republic. On December 30, 2011, following the above decision, the Bank issued the 200 million Redeemable Preference Shares at a nominal value of EUR 5.0 each. Both issues were fully subscribed by the Hellenic Republic, through the transfer by the latter to the Bank of an equivalent amount of Greek government bonds, in accordance with Greek Law 3723/2008. For more information concerning the effects of our participation in the Hellenic Republic Bank Support Plan, see Item 10.J, "Relationship with the Hellenic Republic—Hellenic Republic as Shareholder".

Other Greek banks participating in the support plan accessed Pillar I of the Hellenic Republic Bank Support Plan, are as follows: Eurobank EFG by EUR 950 million, Alpha Bank by EUR 940 million, Piraeus Bank by EUR 750 million (in two tranches), ATE Bank by EUR 675 million, the Hellenic Postal Savings Bank by EUR 225 million and Attica Bank by EUR 100 million and Proton Bank by EUR 80 million. Emporiki Bank, a subsidiary of Credit Agricole S.A., has not utilized the facilities of the Hellenic Republic Bank Support Plan but has proceeded with a share capital increase of EUR 850 million in 2009.

Under Greek law, interest rates applicable to bank loans are not subject to a legal maximum, but they must comply with certain requirements intended to ensure clarity and transparency, including with regard to their readjustments.

Limitations apply to the compounding of interest. In particular, the compounding of interest with respect to bank loans and credits only applies if the relevant agreement so provides and is subject to limitations that apply under article 30 of Greek Law 2789/2000 (as amended by article 42 of Greek Law 2912/2001 and article 47 of Greek Law 2873/2000) and article 39 of Greek Law 3259/2004 (as supplemented by article 8 of Greek Law 3723/2008).

Since 1992, Greek Law 2076/1992, as amended by Greek Law 3601/2007, has permitted banks to grant to customers loans and credit that are secured over real estate and movable assets of the debtor (including cash).

Mortgage lending is extended mostly on the basis of mortgage pre-notations, which are less expensive and easier to record than mortgages and may be converted into full mortgages upon final non appealable court judgment.

The compulsory commitments framework of the Bank of Greece has been amended in line with Eurosystem regulations. Effective July 10, 2000, commitment ratios are determined by category of deposits to clients instead of a single ratio of 12% previously in force for commercial banks. The commitment ratio is 2% for all categories of deposits to clients comprising the commitment base, with the exception of the following categories to which a zero ratio applies:

According to Greek Law 3814/2010, the forced auctions initiated either by credit institutions or by companies providing credit or by their assignees to satisfy claims not exceeding EUR 200,000 were suspended until and including June 30, 2010. Pursuant to Greek Law 3858/2010, and specifically under article 40, the above suspension was initially extended until December 31, 2010. Moreover, pursuant to Greek Law 3949/2011 and specifically under article 1, the suspension was further extended until June 30, 2011. Relative legislation guaranteed the above mentioned extension initially until December 31, 2011 according to article 46 of Greek Law 3986/2011 and subsequent, pursuant to article 1 of Greek Law 4047/2012, until December 31, 2012. As at December 31, 2010 and 2011, outstanding balances that could be subject to this treatment were EUR 121.4 million and EUR 365.7 million, respectively.

Furthermore, enforcement of collateral has been affected by Greek Law 3869/2010 regarding restructuring of individuals' debt through a court application. As at December 31, 2011, customers that had applied to the court under the provisions of Greek Law 3869/2010 had outstanding balances of EUR 286 million.

Greek Law on banking No 3601/2007 "Taking up and pursuit of the business of credit institutions, capital adequacy of credit institutions" transposed to Greek banking legislation the provisions of Directives of the European Parliament and of the Council Nos. 2006/48/EC relating to the taking up and pursuit of the business of credit institutions and 2006/49/EC on the capital adequacy of investment firms and credit institutions. The provisions of this law were amended several times during last year. Firstly, Greek Law 4002/2011 added new provisions concerning governance arrangements and internal control systems of credit institutions. Specifically credit institutions should on the one hand implement remuneration policies and practices that promote sound and efficient risk management and on the other hand provide proper information to Bank of Greece about remuneration of the staff, according to its instructions, as explicitly stipulated in new Governor's Act No 2650/19.1.2012 which incorporated the provisions of 2009/111/EC Directive for remunerations.

In addition to the above, Greek Law 4021/2011 transposed to Greek banking legislation the provisions of 2009/111/EC of the European Parliament and of the Council of September 16, 2009 amending Directives 2006/48/EC, 2006/49/EC and 2007/64/EC as regards banks affiliated to central institutions, certain own funds items, large exposures, supervisory arrangements, and crisis management. As a result, Greek Law 3601/2007 was amended accordingly at the following (amongst others) points: (i) the level of supervisory convergence and cooperation at the EU level was enhanced by the implementation of colleges of Supervisors for the first time implemented into Greek banking legislation

for the purpose of reaching agreement on key supervisory tasks, (ii) Bank of Greece is obliged to properly adopt Standards and Recommendations developed by EBA, or provide with appropriate explanations otherwise, and (iii) with respect to financial crises and systemic risk mitigation, notion of significant branches of credit institutions in other countries was defined.

Moreover, Greek Law 3601/2007 was amended in order to enhance the framework for the supervision and control of credit institutions and to introduce resolution powers to protect financial stability and public confidence in the Greek financial system. For this purpose Greek Laws 4021/2011 and 4051/2012 were enacted. Specifically, the new provisions of Greek Law 4021/2011: (i) reinforced the Bank of Greece's supervisory powers in addressing an actual or potential breach by credit institutions and take all the necessary actions or corrective measures at an early stage, (ii) extended the role and powers of the Commissioner appointed to manage troubled credit institutions, and (iii) empowered Bank of Greece to take specific resolution measures vis-à-vis credit institutions. On the other hand, the amendments to the Law on Banking by Greek Law 4051/2012 aimed to clarify the procedures and allocation of tasks for valuing assets and liabilities and thus, for the opening balance sheets of the transitional credit institutions established in accordance with Article 63E of the Law on Banking.

Lastly, according to new provisions of article 27 of Greek Law 3601/2007, as amended by Greek Law 4051/2012, Bank of Greece has the ability to determine by a generally applicable decision the percentage of the total of the risk-weighted assets that must be covered by items of credit institution's own funds. Subsequently, Bank of Greece Governor's Act No 2654/29.2.2012 was issued according to which the relevant percentage of original own funds, for credit institution seated in Greece, was determined to be at least a) 9%, from September 30, 2012 and b) 10%, from June 30, 2013.

In June 2004 the Basel Committee issued a revised capital adequacy framework and, in November 2005, the Basel Committee issued its final proposals on capital standards, known as "Basel II". Basel II promotes the adoption of certain enhanced risk management practices. It introduces counterparty-risk sensitive, conceptually sound approaches for the calculation of capital requirements that take into account the sophistication of risk management systems and methodologies applied by banks.

The revised framework retains key elements of the 1988 capital adequacy framework, including the general requirement for banks to hold an 8% own funds to risk-weighted asset ratio, the basic structure of the 1996 Amendment regarding the treatment of market risk and the definition of assets eligible for own capital purposes.

A significant innovation of the revised framework is the greater use of assessments of risk provided by banks' internal systems as inputs to capital calculations. In taking this step, the framework also puts forward a detailed set of minimum requirements designed to ensure the integrity of these internal risk assessments. The revised framework introduces capital requirements for operational risk and directs banks to establish an internal capital adequacy assessment process. This process takes into account market, credit and operational risks as well as other risks, including, but not limited to, liquidity risk, concentration risk, interest rate risk in the bank's investment portfolio, business risk and strategic risk.

The revised framework provides a range of options of escalated sophistication for the determination of the capital requirements for credit and operational risk. Various options allow banks and supervisors to select those approaches that are most appropriate for their own operations and the structure of their capital market. Furthermore, Basel II significantly enhances the requirements for market disclosures on both quantitative and qualitative aspects of risk management practices and capital adequacy.

The Basel II framework was implemented in the EU in June 2006 by means of EU Directives 2006/48 and 2006/49 ("CRD 1"). These EU directives were transposed in Greece in August

2007 by means of Greek Law 3601/2007. Following the adoption of Greek Law 3601/2007 on August 20, 2007, the Governor of the Bank of Greece issued ten Governor's Acts relating to the implementation of Basel II. These Governor's Acts took effect on January 1, 2008.

On November 9, 2007, the Bank applied to the Bank of Greece requesting authorization to implement the Basel II capital adequacy framework. Specifically, the Bank of Greece's approval was sought for permission to use:

Approval was granted by the relevant Bank of Greece authority in charge of bank supervision.

The Bank is in compliance with the Basel II regulations and consistently applies all relevant rules and guidelines at a Bank and Group level. The Bank uses both the option for gradual implementation of IRB in its portfolios and the option for permanent exemption of certain categories of exposures from the application of IRB.

The Bank has developed a comprehensive and well-documented roll-out plan that should enable the Group to gradually implement IRB with respect to the aggregate loan exposures included in the banking book (except those permanently exempted).

In 2008, the European Commission submitted a Proposal for a Directive of the European Parliament and the European Council amending Directives 2006/48/EC and 2006/49/EC regarding banks affiliated with central institutions, certain own funds items, large exposures, supervisory arrangements and crisis management which led to the adoption of Directive 2009/111/EC of the European Parliament and of the Council, and Directives 2009/27/EC and 2009/83/EC ("CRD 2") as regards technical provisions concerning risk management. Greece adopted the new measures as from December 31, 2010.

On November 24, 2010, EU Directive 2010/76/EC ("CRD 3") was issued amending Directives 2006/48/EC and 2006/49/EC as regards capital requirements for the trading book and for re-securitizations, and the supervisory review of remuneration policies. This Directive introduces a number of changes in response to the recent and current market conditions, such as:

The changes relating to remuneration have already come into force and the changes relating to the trading book and re-securitization positions will come into force on December 31, 2011.

In December 2010, the Basel Committee issued two prudential framework documents ("Basel III: A global regulatory framework for more resilient banks and banking systems", December 2010 and "Basel III: International framework for liquidity risk measurement, standards and monitoring", December 2010) which contain the Basel III capital and liquidity reform package. The so called Basel III documents were revised in June 2011. According to the documents the proposed changes shall

be implemented gradually ("phase-in arrangements") within the period from 2013 to 2019. Some major points of Basel III include:

The Basel III proposals have been assessed at EU level. The European Commission has published several consultation and other policy documents indicating its intention to implement the Basel III standards throughout the EEA by way of further changes to the Directives 2006/48/EC and 2006/49/EC and/or additional regulations. The final legislative proposals were published on July 20, 2011 (CRD 4). Commission's aim is to create for the first time a single set of harmonized prudential rules which Banks throughout the EU must respect. Commission's proposal follows the timelines as agreed in the Basel Committee: entry into force of the new legislation on January 1, 2013 and full implementation on January 1, 2019.

The Solvency II Directive (Directive 2009/138/EC), adopted by the European Parliament on April 22, 2009 and endorsed by the Council of Ministers on May 5, 2009 is a fundamental review of the capital adequacy regime for the European insurance industry. When implemented (required by October 31, 2012) the capital structure and overall governance of the Group's life assurance business will alter significantly and this may have an impact on the capital structure of the Group.

Other regulatory changes which may have potential impact on the business of NBG

In Europe, the U.S. and elsewhere, there is increased political and regulatory pressure to introduce recovery and/or resolution planning requirements for banks and other financial institutions as a solution to the issues raised by financial institutions that are considered "Too Big To Fail". In 2011, the European Commission consulted on Technical Details of a Possible EU Framework for Bank Recovery and Resolution Proposal. The EU Recovery and Resolution Proposal establishes a series of "resolution tools" which may be applied by the relevant authorities in seeking to ensure that the institution in question is able to continue as a going concern. Such tools include business sales, use of a bridge bank, asset separation of powers and possibly a form of "bail-in". If this proposal is implemented, it could have a material adverse effect on NBG and the cost and availability of funding for NBG.

Following the adoption of Basel II guidelines, the Governor of the Bank of Greece issued Act No. 2606/2008 determining the new reporting requirements for credit institutions in Greece. This Act was recently replaced by Act 2651/20.01.2012 applicable from December 31, 2011. The requirements include the following reports:

The Bank submits to the Bank of Greece a full set of regulatory reports both at Bank level and at Group level, on a quarterly basis. Some of the above references are submitted on a monthly basis at Bank level.

Banking regulations in Turkey are evolving in parallel to the global changes and international regulatory environment. Turkish regulator has announced the roadmap for Basel II and stated that starting from June 2011, the banks in Turkey have started to report their results according to both Basel I and Basel II; and after June 2012 only Basel II will be used. Also, Serbia is obliged to fully adopt the Basel II framework from January 1, 2012. Romania, Bulgaria and Cyprus, in their capacity as EU members, have already adopted the Basel II framework".

Pursuant to Greek Law 3746/2009, which replaced Greek Law 2832/2000, the Hellenic Deposit and Investment Guarantee Fund (the "HDIGF") was established for the purposes of providing compensation (1) to persons who have deposited funds in bank accounts with credit institutions in the Hellenic Republic, and (2) to clients regarding the provision of investment services by such credit institutions, when the credit institutions cannot fulfill their obligations to the clients. Greek Law 4021/2011 amended Greek Law 3746/2003 extending its scope to the provision of financial assistance to credit institutions for the purposes of resolution measures. In addition to the existing Depositors' Coverage Branch and the Investors' Coverage Branch, a new separate resolution branch would be created within the HDIGF and financed by contributions paid by credit institutions. All credit institutions established in the Hellenic Republic are obliged to participate in the compensation scheme available by virtue of the HDIGF. The HDIGF, which is a private entity, is administered jointly by the Bank of Greece, the Hellenic Bank Association, the Ministry of Finance and the Association of Greek Cooperative Banks.

The HDIGF is funded by annual contributions of participating credit institutions and cooperative banks. The level of each participant's annual contribution is generally determined according to certain percentages applied to the total amount of eligible deposits, as regards the deposit compensation scheme. If accumulated funds are not sufficient to cover the claimants, participants may be required to pay an additional contribution. However, this additional contribution may not exceed an amount equal to 300% of a bank's last annual contribution and is set off against the annual contributions of subsequent years. Moreover, pursuant to Greek Law 4051/2012 the HDIGF shall increase the amount of contributions if its funds fall below a certain level of coverage of insured deposits, taking due account developments in the financial system.

Following adverse market developments, and based on the resolutions of the meeting of the Economic and Financial Affairs Council of the EU on October 7, 2008, the coverage level was set to maximum EUR 100,000 until December 31, 2011, in accordance with Greek Law 3714/2008. The deadline may be extended by decision of the Minister of Finance. Subsequently, pursuant to Ministerial Decision No 23384/2011 the deadline was further extended until December 31, 2015. Annual contributions of participating credit institutions and cooperative banks were accordingly increased by a factor of five. The proposed level of coverage extended to credit institution clients relating to the provision of investment services was set at maximum EUR 30,000.

Greek Law 3816/2010, passed in January 2010, allowed the settlement of amounts, which were either due (from January 1, 2005 onwards) or not due by businesses and professionals to credit institutions. To take advantage of the relevant provisions, an application must have been submitted by the debtor to the relevant bank by April 15, 2010.

Enforcement proceedings have been suspended until July 31, 2010, when an application has been submitted by the debtor.

Greek Law 3816/2010 also allows the settlement of debts from loans which are not yet due and the outstanding balance of which does not exceed EUR 350,000. The settlement arrangement may provide for a grace period of up to one year, with no interest and capital payment with a corresponding extension of the contractual term of the loan and capitalization of the interest at the end of the grace period, or two-year suspension of the capital payment with a corresponding extension of the contractual term of the loan and interest payment during the suspension period or an extension of the contractual term of the loan by three years. Additionally, loans or credits which become due between March 26, 2010 and June 30, 2011 are considered eligible for settlement under the Greek Law 3816/2010 subject to other requirements of the respective law. The law foresees interest payment based on the current rate in a period of five years (with no capital payment for the first year).

Given the fact that the Greek Law 3816/010 had very strict specifications and very limited duration, the Bank has also launched restructuring products with more favorable criteria than those specified in the said law.

One of the most important differences between the Greek Law 3816/2010 products and the Bank products is the fact that the Bank allows the reform of the total amount of the loan and not only the overdue amount. In addition, the Bank did not offer these products for a limited time but such products are still offered. As result, the majority of our restructured corporate portfolio comes from these products and not from the mandatory restructuring products specified by the law.

The Bank's products offer a two year capital freeze period where only interest payment can be received from the customer. The interest rate of the new restructured loan is the same with the one used in the old loan. A customer has the right to replace more than one loan (performing and delayed) with a new restructured loan. These products mainly relate to SBLs portfolio.

On August 3, 2010, Greek Law 3869/2010 was put in force (Government's Gazette A, 130/3.8.2010) with respect to the "settlement of amounts due by indebted individuals". The law allows the settlement of amounts, due to credit institutions by individuals evidencing permanent inability to repay their debts, by arranging the partial repayment of their debts for four years and writing off the remainder of their debts, provided the terms of settlement are agreed. All individuals, both consumers and professionals, are subject to the provisions of Greek Law 3869/2010, with the exception of individuals already subject to mercantile law.

This regulatory regime, as amended by article 85 of Greek Law 3996/2011, allows the settlement of all amounts due to credit institutions (consumer, mortgage and commercial loans either promptly serviced or overdue), as well as those due to third parties with the exception of debts from intentional torts, administrative fines, monetary sanctions, debts from taxes and charges due to the State or levies to Social Security funds. Furthermore, it should be noted that, according to the stipulations of Greek Law 4019/2011, to the above exceptions from settlement are added loans granted from Social Security funds under the provisions of articles 15 and 16, Greek Law 3586/2007.

Debts must have been contracted more than one year before the application date and relief may be used only once. In order to qualify for relief, the debtor must have proposed a voluntary settlement with creditors without success in the six months preceding the application. Banks must deliver a credit analysis within five working days from request.

The debtor may apply to the local Justice of the Peace Court (Eirinodikeio) and present evidence regarding the relevant property, income, debts and settlement proposal. Creditors' claims that have not been notified in such court are not affected. The debtor undertakes the obligation to pay part of its

income to its creditors in monthly disbursements for a period of four years. The amount of the installment is determined by court based on the individual's income and after taking into consideration the life necessities of the debtor and his or her dependents. The court may also absolve the debtor from the obligation by imposing a monthly payment schedule and may even substantially reduce the monthly payment amounts in cases of exceptionally adverse conditions (e.g., unemployment or health problems), upon re-evaluation of the debtor's circumstances on a regular basis (although, not starting earlier than five months from the date of the original payment schedule). The debtor's property is liquidated but the debtor may exclude his main residence from the liquidation estate if the debtor undertakes the obligation to repay debts corresponding to 85% of the fair market value of his or her main residence at a floating or fixed, according to the stipulations of article 85 of Greek Law 3996/2011, interest rate and with a potential grace period of up to 20 years. It should also be noted that according to the amendments of article 85 of Greek Law 3996/2011, the debtor's main residence is protected not only in the case of full ownership, but also in cases of bare ownership and usufruct.

If, following submission of an application by the debtor for debt settlement, any enforcement proceedings against his or her property are initiated or carried out, the court, upon the debtor's petition for injunction, may order the suspension of such enforcement proceedings until the debt settlement decision is released, provided that the court considers that the debtor will be subject to some debt settlement and that the enforcement proceedings will cause substantial harm to the debtor.

Regarding housing loans, the court may order the suspension of enforcement proceedings, if the loan agreement has not terminated or there are no debts due, whether or not any portion of the monthly installment payments have become due from the relevant loan decision date until the court's decision on the debt settlement. The court may take into account the debtor's income.

Due performance by the debtor of the obligations under the settlement plan releases the debtor from any remaining unpaid balance of the claims, including claims of creditors who had not announced their claims. On application by the debtor, the court certifies such release. If the debtor delays performance of the obligations under the settlement plan for more than three months or otherwise disputes the settlement plan, the court may order cancellation of the settlement plan, upon the application of any creditor submitted within four months of the breach. A cancellation has the effect of restoring the claims to the amount prior to ratification of the settlement plan, subject to deduction of any amount paid by the debtor.

The rights of creditors against co-borrowers or guarantors are not affected, unless such co-borrowers or guarantors are also subject to the same insolvency proceedings. Co-borrowers and guarantors have no rights of recourse against the debtor for any amount paid by them. The rights of secured creditors are not affected.

Within the six-month period commencing August 3, 2010 (the date of publication of Greek Law 3869/2010 in the Government Gazette), no enforcement is permitted over the debtor's only residence, as long as the latter does not exceed the specified "first home" tax allowance increased by 50%. Pursuant to Greek Law 3910/2011 and specifically under article 36, this period was extended until June 30, 2011. The above mentioned deadline was further extended until December 31, 2011 pursuant to Greek Law 3986/2011. In addition, Greek Law 3986/2011 added new provisions according to which the restriction of enforcement over the only residence refers to all natural persons, without taking into consideration whether they are subject to mercantile law or not. Moreover, pursuant to Greek Law 4047/2012 the relevant deadline was further extended until December 31, 2012.

Directive 2007/64/EC setting out the conditions for the provision of payment has come into effect in Greece as of July 13, 2010, by Greek Law 3862/2010. The new law adopts rules on electronic payments that are currently applied uniformly across 30 European countries (i.e. in the countries of the

EU, Iceland, Norway and Liechtenstein), and accordingly ensures that the provision of payment services in Greece is as easy and secure as in the rest of Europe.

This new legislation establishes rules on terms of collaboration transparency, regulates in detail a minimum level of information that must be provided in an accessible form to the users of the payment services and renders the payments faster and more secure. Moreover, it sets out the rights and obligations of those who use or provide such services. It also permits to new entities called "payment institutions" (e.g. companies of money transfers, retailers, telecommunication companies) to provide payment services in parallel to banks as "payment services providers". The new law covers any kind of payment through electronic means, from transfer of credit and direct charge orders to payments through the use of cards (including credit cards), wire transfers and payments through the use of mobile phones and the internet, excluding payments with cash and checks. Payments in every European currency, not only Euros, are covered, under the condition that the payment service providers of both the payer and the payee are located in one of the 30 European countries.

Customers are provided, free of charge, in printed or electronic form, with the framework contract, that describes in detail the terms and conditions of the payment services, which are mandatory under the law and also apply to existing cooperation contracts and agreements between the Bank and its customers, insofar they include payment transactions, and prevail over any contrary agreement. Under the provisions of the new law, customers have the right to advance any objections they may have, within two months of being informed of the framework contract terms. In addition, if the customer does not wish to continue cooperating with the Bank, he is entitled, under the terms of the framework contract, to terminate, in writing, the said cooperation agreement. Furthermore if the customer wishes at some future date, despite having initially accepted the terms to terminate the framework contract for payment transactions, he may terminate it without charge, at any time, unless the parties have agreed on a period of notice, which may not, in any case, exceed one month.

Customers are provided with basic information needed before and after execution of the payment. Accordingly, customers can easily compare the terms and conditions offered and choose the best option for their needs. Charges are not imposed to customers for providing all mandatory required information as well as any information related to the corrective and preventive measures taken to ensure the proper execution of payment orders.

Customers are legally entitled to a refund in the following specific cases of payment transactions:

On June 23, 2010, Ministerial Decision Z1-699, which implemented the Council Directive 2008/48/EC, was put in force (Government's Gazette B, 917/23.06.2010). This Directive facilitates a well-functioning internal market in consumer credit and provides for a harmonized Community framework in a number of areas. The Decision Z1-699 does not apply to certain types of credit agreements, such as credit agreements involving amounts less than EUR 200 or more than EUR 75,000, credit agreements, under the terms of which the credit has to be repaid within three months and only insignificant charges are payable, credit agreements covering the granting of credit secured by

real estate, credit agreements by the employer to the employees, lease or financial lease agreements when there is no obligation of the consumer to buy the leasehold.

This Decision contains specific provisions on advertising concerning credit agreements as well as certain items of standard information to be provided to consumers in order to enable them, in particular, to compare different offers. In order to enable them to make their decisions in full knowledge of the facts, consumers receive adequate information in a clear, concise and prominent way by means of a representative example, which they may take away and consider, prior to the conclusion of the credit agreement, on the conditions and cost of the credit and on their obligations, to ensure the fullest possible transparency and comparability of offers. Moreover, creditors should exercise responsible practices during all phases of the credit relationship, taking into account the specific features of their credit market. Creditors also bear the responsibility of checking individually the creditworthiness of the consumers. Furthermore, consumers have the right to withdraw within 14 days without penalty and with no obligation to provide justification. In the case of linked credit agreements, a relationship of interdependence exists between the purchase of goods or services and the credit agreement concluded for that purpose. The consumer has the right to discharge his obligations before the date agreed in the credit agreement. In the case of early repayment, either in part or in full, the creditor is entitled to compensation for the costs directly linked to the early repayment, taking into account also any savings thereby made by the creditor.

Two new laws address and introduce important amendments to corporate legislation.

Greek Law 3884/2010, which incorporated into national law Directive 2007/36/EC, facilitates the exercise of shareholders' rights in general meetings of listed companies and accordingly provides for:

In addition to the above, Greek Law 3873/2010, which incorporated into Greek law Directives 2006/46/EC on annual and consolidated accounts and 2007/63/EC on the independent expert's report for the merger or division of public limited liability companies, determines that companies whose securities are traded in a regulated market must include a corporate governance statement in their annual report. Moreover, a corporate governance statement is now mandatory in the annual report of the Board of Directors which contains, among others, information on the corporate governance code and practices of the company, the main features of the company's internal control and risk management systems, information on the General Meetings of shareholders, the Board of Directors and other administrative, management and supervisory bodies of the company.

Furthermore, according to Greek Law 3873/2010, additional information must be included in the notes to the financial statements of companies, such as information on the nature and business purpose of arrangements which are not reflected in the balance sheet, the financial impact of those arrangements and information on transactions which have been entered into with related parties. The notes to the consolidated financial statements must also include a description of certain transactions with affiliated companies, save for intra-group transactions. Companies which prepare consolidated financial statements are also obliged to describe the company's internal control and risk management systems in the annual report of the Board of Directors.

The Board of Directors of the company has the duty to ensure that the annual accounts, the annual report and, when provided separately, the corporate governance statement to be provided pursuant to article 43a par. 3 section d of Greek Law 2190/1920 are drawn up and published in accordance with the requirements of Greek Law 3873/2010 and, where applicable, in accordance with the international accounting standards adopted in accordance with Regulation (EC) No 1606/2002.

Moreover, according to the new provisions of Greek Law 3873/2010 neither an examination of the draft terms of merger or division of companies nor an expert report shall be required if all the shareholders and the holders of other securities conferring the right to vote of each of the companies involved in the merger or division have so agreed.

The Greek parliament has amended Greek Law 3601/2007 regarding disclosure requirements for shareholders of Greek credit institutions and insurance companies. The new Greek Law 3862/2010, effective July 13, 2010, introduces new provisions and approval procedures for certain sectors as well as minor changes to the evaluation procedure by the Bank of Greece.

In summary, Greek Law 3862/2010 stipulates the disclosure obligations for shareholders wishing to acquire or dispose of significant holdings, as well as the procedure for the pre-approval requirements for investors who wish to acquire shares and reach the threshold limits of 5%, 10%, 20%, and 1/3 or 50% of a credit institution, and 10%, 20%, and 1/3 or 50% of an insurance company registered in Greece. The Bank of Greece's approval process, the relevant timeframes as well as the notification process to/from relevant regulators of other EU member states are also detailed.

If an investor intends to increase or dispose of shares to reach or fall under one of the threshold limits, he would have to inform the Bank of Greece in advance of the intended participation, providing full details of the percentage to be acquired or disposed.

It should be noted that Greek Law 3943/2011, as amended by legislative act dated December 31, 2011, provides considerable changes in relation to the taxation of profits arising from the sale of shares listed on the ATHEX or a foreign Stock Exchange which are acquired from April 1, 2012 onwards. Specifically, any profits arising from the sale of the aforementioned shares will be taxed according to the general provisions of tax law, and any losses will be tax deductible.

Moreover, the transaction tax rate imposed on sale of shares listed on the ATHEX or a foreign Stock Exchange increased to 2? as of April 1, 2011. The tax is calculated on the value of the shares sold and is payable by the seller, whether a natural or legal person, a body of persons, or property group and regardless of nationality and place of residence or seat of the lender and of any exemption from tax or duty on the basis of other legislative provisions.

Furthermore, a new procedure for withholding and remitting the 2? tax on the sale of shares listed on the ATHEX is introduced, according to which the Hellenic Exchange S.A. charges and pays the amount of the aforementioned tax to its competent tax authority.

In addition to the above, Greek Law 3943/2011 imposes a 25% withholding tax on profits distributed by Greek sociétés anonymes in the form of dividends as well as interim dividend payments made to individuals or legal entities, Greek or foreign, body of persons, or property group, independent of whether the payment is made in cash or in shares.

According to article 4 of Greek Law 4038/2012, a tax rate of 2 ? is imposed on the value of shares (listed on ATHEX) on over-the-counter stock lending, while it is explicitly provided that the stock lending agreement and any related transaction are not subject to stamp duty. Such tax is payable by the lender, whether a natural or legal person, body of persons, or property group regardless of nationality and place of residence or seat of the lender and regardless of any exemption from tax or duty on the basis of other legislative provisions.

A definition of tax residence is introduced, and is based on OECD Guidelines. According to article 12 of Greek Law 3943/2011, subject to taxation for their global income are natural persons with residence or usual residence in Greece are subject to taxation for their global income. Moreover, all natural persons are subject to taxation for their income in Greece, without taking into account of their residence or usual residence.

The concept of "usual residence" is determined, for tax purposes, to be situated in Greece if the natural person resides in Greece for more than 183 days in total within the same calendar year. The usual residence is assumed to exist, unless the taxpayer proves to the contrary.

Furthermore, an exception of the above rule is stipulated for the cases that natural persons who have their usual residence in Greece and are subject to taxation for their global income in a country (1) which has not signed an income tax treaty for the avoidance of double taxation with Greece and (2) which is not on the list of non-cooperating countries, are subject to taxation in Greece, only for income arising in Greece and only for the first three years of residence in Greece.

If natural persons wish to transfer their residence to another country, they must provide certain evidence (that is to be determined subsequently through a Ministerial Decision).

Moreover, a Greek tax resident who transfers tax residence or usual residence to a country with a preferential tax regime and has substantial financial interests (as defined according to Greek Law 3943/2011) in Greece, is considered to be subject to tax in Greece for the taxpayer's global income for a period of five years after changing residence, with the five-year period commencing from the date of the filing of the declaration for the change of residence.

Article 21 of Greek Law 3943/2011 and article 4 of Greek Law 4038/2012, amend the provisions concerning the tax certificate issued for S.A. and Ltd companies upon the completion of a tax audit conducted by individual certified auditors and audit firms registered in the public registry of Greek Law 3693/2008. Specifically, the certificate must express an opinion in respect of tax compliance and that any tax "infringements" must also be explicitly stated in the certificate. The content of the tax certificate issued by certified auditors is subject to examination by the tax authorities, and any omission of the obligations of the certified auditors can result in penalties and administrative sanctions. If the tax certificate does not include comments and findings of tax violations, the taxpayer/company will not be subject to a regular tax audit (unless the provisions of article 80 of Greek Law 3842/2010, which provides for a methodology risk analysis system for selecting cases to be audited apply). Moreover, competent tax authorities will conduct, as priority, investigations for S.A. and Ltd companies for which tax certificates have not been issued and administrative sanctions will be applied.

Furthermore, Ministerial Decisions POL 1159/26.7.2011 and POL 1011/10.1.2012 provide clarifications for the appropriate and consistent application of the provisions regarding tax certificates. As stipulated by the above-mentioned Ministerial Decision the annual tax certificate should consist of two sections: 1) the "Tax Compliance Report" and 2) the "Appendix of detailed data." The Tax Compliance Report covers all areas specified by the audit program. Individual certified auditors and audit firms issuing a Tax Compliance Report are required to maintain detailed documentation for each special tax audit performed.

Within the context of application of the Greek debt restructuring program (PSI) several legislative acts were enacted. First, Greek Law 4046/2012 was enacted on February 14, 2012 and its purpose was to enable the voluntary bond exchange between the Hellenic Republic and certain private sector investors, as described in the statement of the Euro Summit dated October 26, 2011.

Moreover, Greek Law 4050/2012 on the rules for the amendment of debt securities issued or guaranteed by the Hellenic Republic with the bondholder's agreement, which became effective on February 23, 2012, introduced a legal framework to amend the eligible debt securities. Based on the abovementioned law, the Ministerial Council Act No. 5 dated February 24, 2012 sought the consent of holders of Greek-law governed debt securities, issued or guaranteed by the Hellenic Republic prior to December 31, 2011, for the amendment of these debt securities. The proposed amendments provided for the redemption of the affected debt securities in exchange with new ones issued by the Hellenic Republic and the EFSF. Ministerial Council Act No. 5, amongst others, provided for the commencement of the amendment process of eligible debt securities by the bondholders and set the principal or the notional amount, duration as well as governing law of the new debt securities to be issued by the Hellenic Republic.

Furthermore, the Public Debt Management Agency was authorized to issue one or more invitations on behalf of the Hellenic Republic. Under these invitations the bondholders of eligible debt securities were invited to decide within a specified period of time, whether to accept or not the

amendment of the eligible debt securities, as proposed by the Hellenic Republic and in accordance with the process stipulated by Greek Law 4050/2012. The invitations, according to Greek Law 4052/2012, included, inter alia, terms relevant to: the eligible bonds and other terms such as subdivisions of the bonds, grace period, currency, terms and methods of payment, repayment and repurchase, termination reasons, negative obligations of the issuer (negative pledges), rights and obligations of the trustee acting for the bondholders, etc.

In addition to the above, it should be noted that under the collective action clauses, the proposed amendments would become binding on the holders of all the Hellenic Republic's Greek-law governed debt securities issued prior to December 31, 2011 identified in the Act No. 5 of the Ministerial Council approving the PSI invitations, if at least two-thirds (2/3) by face amount of a quorum of these bonds, voting collectively without distinction by series, approved the proposed amendments.

The publication in the Government Gazette (Issue B No. 50 dated March 9, 2012) of the decision of the Ministerial Council Act No. 10 dated March 9, 2012 followed. According to this Act, Bank of Greece, as process manager, confirmed and ratified the decision of the Bondholders of eligible debt securities to consent to the proposed amendments in accordance with Greek Law 4050/2012, Act, Ministerial Council Act No. 5 and the relevant invitations. As a result, according to the provisions of Greek Law 4052/2012 this decision applied vis-à-vis any party, bind all holders of eligible debt securities and superseded all contrary provisions of law or contractual terms.

Additionally, the Hellenic Republic after the confirmation and certification by the Bank of Greece, accepted the consents received and amended the terms of all of its Greek law governed bonds, including those not tendered for exchange pursuant to the invitations, since the above mentioned quorum, in relation to the participation of the Bondholders in the decision making process, was achieved. Subsequently Ministerial Decision No 2/20964/0023A was issued for the implementation of the amendment procedure of the eligible debt securities and the issuance of new bonds and GDP-linked securities. The abovementioned Ministerial Decision provided the details of the new debt securities as well as a list with the ISIN numbers of all the new debt securities, their duration and worth. Moreover, individual bondholders were called to convert their titles. Lastly, it should be underlined that the new bonds and the GDP-linked securities are admitted for trading on the ATHEX and the Electronic Secondary Securities Market operated by the Bank of Greece.

Greece, as a member of the Financial Action Task Force ("FATF") and as a member state of the EU, fully complies with FATF recommendations and the relevant EU legal framework. The FATF recognizing Greece's significant progress in improving its Anti Money Laundering / Counter Financing Terrorism ("AML/CFT") regime and noting that Greece has met its commitments in its Action Plan regarding the strategic AML/CFT deficiencies that the FATF had identified in February 2010, decided that Greece was no longer subject to monitoring under the FATF's ongoing global AML/CFT compliance process. Consequently, Greece was moved to regular monitoring.

The Greek Law 3691/2008 on the prevention and suppression of money laundering and terrorist funding was further amended in 2011 (Greek Laws 3932/2011 and 3994/2011) to reflect better implementation of FATF standards. The main improvements relate mainly to the following issues:

In March 2012, the Bank of Greece amended its Decisions No. 281/5/2009 on the "Prevention of the use of the credit and financial institutions, which are supervised by the Bank of Greece, for the purpose of money laundering and terrorist financing" and No. 285/6/09.07.2009, which provides an indicative typology of unusual or suspicious transactions within the meaning of Greek Law 3691/2008 on the prevention and suppression of money laundering and terrorist funding. These amendments incorporate "prerequisite actions" imposed by the Memorandum of Understanding between Greece, the European Commission and the Bank of Greece, which was ratified by Greek Law 4046/2012. They relate to the following:

Credit institutions must follow certain procedures regarding holdings in other companies. Under Greek Law 3601/2007, a credit institution may not have a qualifying holding exceeding 15% of its own funds in an undertaking that is not a credit institution, a financial institution, an insurance or re-insurance company, an investment firm or an undertaking carrying on activities which are a direct extension of banking or concern services ancillary to banking. The total amount of a credit institution's qualifying holdings in these undertakings may not exceed 60% of its own funds. A "qualifying holding" means a direct or indirect holding in an undertaking which represents 10% or more of the capital or the voting rights, or which makes it possible to exercise a significant influence over the management of that undertaking.

To calculate these thresholds, the following shares or holdings are not taken into account:

The above thresholds or the time limit referred to in (b) above may be exceeded in exceptional cases and for a period of up to six months following a decision of the Bank of Greece to that effect, provided that the credit institution either increases its own funds or takes equivalent measures. The Bank of Greece may also allow the thresholds and the time limits to be exceeded, provided that the excess is fully covered by own funds which are not taken into account for the calculation of the capital adequacy ratio.

According to the Act of the Governor of Bank of Greece No. 2604/2008, credit institutions must obtain the Bank of Greece's prior approval to acquire or increase a qualifying holding in the share capital of credit institutions, financial institutions, insurance and re-insurance companies, investment firms, information technology companies, real estate property management companies, asset and liability management companies, paying systems management companies, external credit assessment institutions and financial data collection and processing companies. The provisions of such Act do not apply to branches of credit institutions with their registered seat in a country of the EEA, or outside the EEA provided that the Bank of Greece has recognized the equivalence of their supervisory regime.

Prior approval by the Bank of Greece for the acquisition or increase of a qualifying holding is not required in any of the following circumstances:

Subject to EU regulations, new and significant holdings (concentrations) must be reported to the Greek Competition Commission according to Greek Law 3959/2011, as in force.

The HCMC and the ATHEX must be notified once certain ownership thresholds are exceeded with respect to listed companies. See Item 9.C, "Markets—The Athens Exchange (ATHEX)".

Our medium-term goal has been to become a large regional financial institution, a strategy which we have been implementing through measured, organic expansion combined with carefully considered strategic acquisitions, most notably our acquisition of Finansbank, the fifth largest private sector bank in Turkey. Our focus has been on high-growth countries in the region with traditional ties to Greece and a European orientation. Moreover, the international crisis has confirmed the prudence of the Bank's historically conservative approach to risk management as our subsidiaries in Turkey and SEE Europe have all emerged on a solid footing from their respective country's crisis, with the performance of Finansbank, our largest international subsidiary, particularly standing out. The main challenge currently is the Greek sovereign debt crisis, and its impact on the Bank's operations. In this regard, our strong liquidity position and capital base at the beginning of the crisis, as well as our diversified footprint, provide a strong advantage.

Our strategy for meeting the challenges of the crisis entails the following five pillars:

Set forth below is a chart indicating the individual companies within the Group and the Group's participation (direct and indirect) in each company at December 31, 2011.

Primary Operating Area	Country of incorporation

Corporate & Investment Banking
Ethniki Leasing S.A.	Greece	93.33	%	6.67	%	100.00	%
Ethniki Factors S.A.	Greece	100.00	%	—		100.00	%
Titlos Plc⁽¹⁾	UK	—		—		—
Retail Banking
Revolver APC Limited⁽¹⁾	UK	—		—		—
Revolver 2008-1 PLC⁽¹⁾	UK	—		—		—
Spiti PLC⁽¹⁾	UK	—		—		—
Autokinito PLC⁽¹⁾	UK	—		—		—
Agorazo PLC⁽¹⁾	UK	—		—		—
Turkish Operations
Finansbank A.S.	Turkey	77.23	%	17.58	%	94.81	%
Finans Leasing A.S.	Turkey	29.87	%	61.03	%	90.90	%
Finans Invest A.S.	Turkey	0.20	%	94.58	%	94.78	%
Finans Portfolio Management A.S.	Turkey	0.01	%	94.78	%	94.79	%
Finans Investment Trust A.S.	Turkey	5.30	%	46.80	%	52.10	%
IB Tech A.S.	Turkey	—		94.72	%	94.72	%
Finans Consumer Finance A.S.	Turkey	—		94.81	%	94.81	%
Finans Factoring A.S.	Turkey	—		94.81	%	94.81	%
NBG (Malta) Holdings Ltd	Malta	—		100.00	%	100.00	%
NBG Bank Malta Ltd	Malta	—		100.00	%	100.00	%
International
The South African Bank of Athens Ltd	South Africa	94.36	%	5.35	%	99.71	%
National Bank of Greece (Cyprus) Ltd.	Cyprus	100.00	%	—		100.00	%

Primary Operating Area	Country of incorporation

National Securities Co (Cyprus) Ltd	Cyprus	—		100.00	%	100.00	%
NBG Management Services Ltd	Cyprus	100.00	%	—		100.00	%
Stopanska Banka A.D. (Skopje)	FYROM	94.64	%	—		94.64	%
United Bulgarian Bank AD—Sofia (UBB)	Bulgaria	99.91	%	—		99.91	%
UBB Asset Management Inc.	Bulgaria	—		99.92	%	99.92	%
UBB Insurance Broker A.D.	Bulgaria	—		99.93	%	99.93	%
UBB Factoring E.O.O.D.	Bulgaria	—		99.91	%	99.91	%
Interlease E.A.D.	Bulgaria	100.00	%	—		100.00	%
Interlease Auto E.A.D.	Bulgaria	—		100.00	%	100.00	%
Banca Romaneasca S.A.	Romania	89.07	%	—		89.07	%
NBG Leasing IFN S.A.	Romania	100.00	%	—		100.00	%
NBG Factoring Romania IFN S.A.	Romania	—		89.18	%	89.18	%
Vojvodjanska Banka a.d. Novi Sad	Serbia	100.00	%	—		100.00	%
NBG Leasing d.o.o. Belgrade	Serbia	100.00	%	—		100.00	%
NBG Services d.o.o. Belgrade	Serbia	—		100.00	%	100.00	%
Global Markets & Asset Management
National Securities S.A.	Greece	100.00	%	—		100.00	%
NBG Asset Management Mutual Funds S.A.	Greece	81.00	%	19.00	%	100.00	%
NBG Greek Fund Ltd.	Cyprus	100.00	%	—		100.00	%
NBG Finance Plc	UK	100.00	%	—		100.00	%
NBG Finance (Dollar) Plc	UK	100.00	%	—		100.00	%
NBG Finance (Sterling) Plc	UK	100.00	%	—		100.00	%
NBG International Ltd	UK	100.00	%	—		100.00	%
NBGI Private Equity Ltd	UK	—		100.00	%	100.00	%
NBGI Private Equity S.A.S	France	—		100.00	%	100.00	%
NBG Securities Romania S.A. (formerly ETEBA Romania S.A.)	Romania	100.00	%	—		100.00	%
NBG Asset Management Luxembourg S.A.	Luxemburg	94.67	%	5.33	%	100.00	%
NBGI Private Equity Funds	UK	—		100.00	%	100.00	%
CPT Investments Ltd	Cayman Islands	100.00	%	—		100.00	%
Insurance
NBG Bancassurance S.A.	Greece	99.70	%	0.30	%	100.00	%
Ethniki Hellenic General Insurance S.A.	Greece	100.00	%	—		100.00	%
National Insurance Brokers S.A.	Greece	—		95.00	%	95.00	%
Ethniki Insurance (Cyprus) Ltd	Cyprus	—		100.00	%	100.00	%
Ethniki General Insurance (Cyprus) Ltd	Cyprus	—		100.00	%	100.00	%
S.C. Garanta Asigurari S.A.	Romania	—		94.96	%	94.96	%
Audatex Hellas S.A.	Greece	—		70.00	%	70.00	%
Finans Pension AS	Turkey	—		94.81	%	94.81	%

Primary Operating Area	Country of incorporation

Other
Ethniki Kefalaiou S.A.	Greece	100.00	%	—		100.00	%
NBG Property Services S.A.	Greece	100.00	%	—		100.00	%
Pronomiouhos S.A. Genikon Apothikon Hellados	Greece	100.00	%	—		100.00	%
Innovative Ventures S.A. (I-Ven) (under liquidation)	Greece	—		100.00	%	100.00	%
Astir Palace Vouliagmenis S.A.	Greece	85.35	%	—		85.35	%
Grand Hotel Summer Palace S.A.	Greece	100.00	%	—		100.00	%
NBG Training Center S.A.	Greece	100.00	%	—		100.00	%
Ethnodata S.A.	Greece	100.00	%	—		100.00	%
KADMOS S.A.	Greece	100.00	%	—		100.00	%
DIONYSOS S.A.	Greece	99.91	%	—		99.91	%
EKTENEPOL Construction Company S.A.	Greece	100.00	%	—		100.00	%
Mortgage, Touristic Protypos S.A.	Greece	100.00	%	—		100.00	%
Hellenic Touristic Constructions S.A.	Greece	77.76	%	—		77.76	%
Ethniki Ktimatikis Ekmetalefsis S.A.	Greece	100.00	%	—		100.00	%
NBG Pangaea Real Estate Investment Company	Greece	100.00	%	—		100.00	%
NBG International Holdings BV	The Netherlands	100.00	%	—		100.00	%

As at December 31, 2011, the Group owned 2,751 properties, of which 1,887 are buildings. These properties are, for the most part, held free of encumbrances. Most of our properties are attributable to the branches and offices through which we maintain our customer relationships and administer our operations. Most of our other properties have been acquired as a result of foreclosure on the collateral of defaulted loans. There are no environmental issues of which we are aware of that may affect the Group's utilization of our real estate assets.

The Group's real estate portfolio was recorded at a net book value of EUR 854.5 million as at December 31, 2011, which is included in the U.S. GAAP Financial Statements under "premises and equipment". Those of our properties that have been acquired as a result of foreclosure on the collateral of defaulted loans had a carrying value of EUR 184.8 million as at December 31, 2011, are included under "Other assets" in the Group's U.S. GAAP Financial Statements and are accounted for as held for sale.

For any new property acquired from foreclosure procedure, the Group performs valuations by applying internationally recognized valuation methodologies. The valuations are performed either internally by qualified appraisers or externally by international certified valuation companies or qualified appraisers. Additionally, valuations are back-tested for outliers through a standardized statistical process. Due to the current circumstances in the property market a valuation performed within the last six months is required prior to the liquidation of a foreclosed asset. Moreover, all assets are monitored for signs of physical impairment. In such case the Group performs a valuation in order to determine any potential write-down. A full review for potential impairment of foreclosed assets of material value is performed on a regular basis, by taking into account the condition of the properties and the market conditions. However, in order to expedite the process of divesting these non-core assets, we have simplified the auction process and have established a subsidiary, Ethniki Kefalaiou S.A., which acquires from the Bank and other Group companies certain real estate assets with the sole purpose of realizing more efficiently the value of such assets for the Group. For more information on the Group's management of its properties see Item 4.B, "Business Overview—Other—Real Estate Management".

Information included in this section, except where otherwise stated, relates to the Bank and its subsidiaries. The statistical data presented below may differ from data included in the consolidated financial statements of the Group included elsewhere in this Annual Report. In certain cases, the statistical data is derived from statutory reports and from statistical data reported in the forms prescribed by the central bank for regulatory purposes. Such data are compiled as a normal part of our financial reporting and management information systems. Unless otherwise noted, amounts presented below are based on U.S. GAAP financial information.

The following tables set forth the average balances of our assets and liabilities for the years ended December 31, 2009, 2010 and 2011, from our domestic and foreign activities, and, for interest-earning assets and interest-bearing liabilities, provide the amount of interest earned or paid and the average rate of such interest for such asset or liability, as applicable. Where available, the Group calculates the average balances for certain line items on the basis of daily averages. To the extent that daily information is not available for other balances and without causing undue burden or expense, the Group utilizes quarterly, monthly or annual average balances.

	Year ended December 31,

	2009 As restated⁽⁴⁾								2010 As restated⁽⁴⁾								2011
	Average Balance			Interest		Average Rate			Average Balance			Interest		Average Rate			Average Balance			Interest		Average Rate
	(EUR in thousands, except percentages)
Domestic:
Assets:
Deposits with central bank		1,196,929			14,765		1.23	%		1,086,723			11,006		1.01	%		970,288			12,286		1.27	%
Interest bearing deposits with banks and securities purchased under agreements to resell⁽¹⁾		725,942			7,697		1.06	%		4,363,772			19,129		0.44	%		5,666,132			28,721		0.51	%
Trading, available for sale and held to maturity securities⁽¹⁾⁽³⁾		15,000,545			670,643		4.47	%		15,655,082			740,288		4.73	%		13,784,803			814,222		5.91	%
Loans and other interest earning assets⁽²⁾		52,748,951			2,525,716		4.79	%		55,637,250			2,438,724		4.38	%		53,234,610			2,499,432		4.70	%
Less: Allowance for loan losses		(1,184,167	)		—		—			(1,723,997	)		—		—			(3,137,008	)		—		—
Net loans		51,564,784			—		—			53,913,253			—		—			50,097,602			—		—

Total interest earning assets		68,488,200			3,218,821		4.70	%		75,018,830			3,209,147		4.28	%		70,518,825			3,354,661		4.76	%
Total non interest earning assets		7,810,169								7,567,251								13,013,695

Total assets		76,298,369								82,586,081								83,532,520

Liabilities:
Total deposits		69,412,348			1,144,522		1.65	%		72,897,501			844,539		1.16	%		72,600,508			1,122,546		1.55	%
Securities sold under agreements to repurchase		258,591			5,000		1.93	%		384,118			2,181		0.57	%		1,010,115			10,561		1.05	%
Long term debt, other borrowed funds and other interest bearing liabilities		280,415			7,965		2.84	%		1,780,688			69,103		3.88	%		2,127,735			89,996		4.23	%

Total interest bearing liabilities		69,951,354			1,157,487		1.65	%		75,062,307			915,823		1.22	%		75,738,358			1,223,103		1.61	%
Total non interest bearing liabilities		6,254,691								6,809,182								8,746,732

Total Liabilities		76,206,045								81,871,489								84,485,090

	Year ended December 31,

	2009 As restated⁽⁴⁾								2010 As restated⁽⁴⁾								2011
	Average Balance			Interest		Average Rate			Average Balance			Interest		Average Rate			Average Balance			Interest		Average Rate
	(EUR in thousands, except percentages)
Foreign:
Assets:
Deposits with central bank		1,559,913			14,897		0.95	%		1,496,517			6,774		0.45	%		2,251,126			5,105		0.23	%
Interest bearing deposits with banks and securities purchased under agreements to resell⁽¹⁾		2,670,667			84,371		3.16	%		3,472,216			55,913		1.61	%		1,912,176			66,292		3.47	%
Trading, available for sale and held to maturity securities⁽¹⁾⁽³⁾		3,607,226			380,560		10.55	%		4,305,667			284,769		6.61	%		4,151,703			260,914		6.28	%
Loans and other interest earning assets⁽²⁾		21,293,466			2,532,731		11.89	%		23,515,773			2,592,233		11.02	%		24,252,811			2,572,678		10.61	%
Less: Allowance for loan losses		(554,496	)		—		—			(870,461	)		—		—			(1,103,388	)		—		0.00	%
Net loans		20,738,970			—		—			22,645,312			—		—			23,149,423			—		0.00	%

Total interest earning assets		28,576,776			3,012,559		10.54	%		31,919,712			2,939,689		9.21	%		31,464,428			2,904,989		9.23	%
Total non interest earning assets		5,093,359								5,598,318								3,268,349

Total assets		33,670,135								37,518,030								34,732,777

Liabilities:
Total deposits		18,466,817			988,985		5.36	%		20,364,424			977,427		4.80	%		19,456,993			1,142,388		5.87	%
Securities sold under agreements to repurchase		3,930,719			85,052		2.16	%		4,736,598			73,531		1.55	%		2,206,594			111,456		5.05	%
Long term debt, other borrowed funds and other interest bearing liabilities		4,626,779			213,591		4.62	%		2,645,899			98,454		3.72	%		3,349,947			134,552		4.02	%

Total interest bearing liabilities		27,024,315			1,287,628		4.76	%		27,746,921			1,149,412		4.14	%		25,013,534			1,388,396		5.55	%
Total non interest bearing liabilities		708,623								3,156,238								3,389,400

		27,732,938								30,903,159								28,402,934

Analysis of Changes in Net Interest Income before provision for loan loss—Volume and Rate Analysis

The following tables analyze the change in our net interest income before provision for loan losses attributable to changes in the average volume of interest-earning assets and interest-bearing liabilities, and changes in their respective interest rates for the periods presented from our operations. Amounts due to changes in volume have been calculated by multiplying the change in volume during the year times the average rate for the preceding year. Amounts due to changes in rates have been calculated by multiplying the change in the current year average rate times the volume of the current year.

	Year ended December 31,

	2010 vs. 2009 As restated⁽¹⁾									2010 vs. 2009 As restated⁽¹⁾
	Total interest change			Due to change in volume			Due to change in interest rate			Total interest change			Due to change in volume			Due to change in interest rate
	(EUR in thousands, except percentages)
	Domestic:									Foreign:
ASSETS
Deposits with central bank		(3,759	)		(1,359	)		(2,400	)		(8,123	)		(605	)		(7,518	)
Interest bearing deposits with banks, securities purchased under agreements to resell		11,432			38,571			(27,139	)		(28,458	)		25,322			(53,780	)
Trading, available for sale and held to maturity securities		69,645			29,263			40,382			(95,791	)		73,685			(169,476	)
Loans		(86,992	)		138,297			(225,289	)		59,502			264,330			(204,828	)

Total Assets		(9,674	)		204,772			(214,446	)		(72,870	)		362,732			(435,602	)

LIABILITIES
Total deposits		(299,983	)		57,466			(357,449	)		(11,558	)		101,626			(113,184	)
Securities sold under agreements to repurchase		(2,819	)		2,427			(5,246	)		(11,521	)		17,437			(28,958	)
Long term debt and other borrowed funds		61,138			42,614			18,524			(115,137	)		(91,446	)		(23,691	)

Total Liabilities		(241,664	)		102,507			(344,171	)		(138,216	)		27,617			(165,833	)

	Year ended December 31,

	2011 vs. 2010 restated⁽¹⁾							2011 vs. 2010 as restated⁽¹⁾
	Total interest change		Due to change in volume			Due to change in interest rate		Total interest change			Due to change in volume			Due to change in interest rate
	(EUR in thousands, except percentages)
	Domestic:							Foreign:
ASSETS
Deposits with central bank		1,280		(1,179	)		2,459		(1,669	)		3,416			(5,085	)
Interest bearing deposits with banks, securities purchased under agreements to resell		9,592		5,709			3,883		10,379			(25,121	)		35,500
Trading, available for sale and held to maturity securities		73,934		(88,441	)		162,375		(23,855	)		(10,183	)		(13,672	)
Loans		60,708		(105,314	)		166,022		(19,555	)		81,246			(100,801	)

Total Assets		145,514		(189,225	)		334,739		(34,700	)		49,358			(84,058	)

LIABILITIES
Total deposits		278,007		(3,441	)		281,448		164,961			(43,554	)		208,515
Securities sold under agreements to repurchase		8,380		3,554			4,826		37,925			(39,276	)		77,201
Long term debt and other borrowed funds		20,893		13,468			7,425		36,098			26,198			9,900

Total Liabilities		307,280		13,581			293,699		238,984			(56,632	)		295,616

The following table shows the levels of average interest earning assets and total interest income and net interest income before provision for loan losses of the Group and the net interest margin for each of the periods indicated from domestic and foreign activities. This information is derived from the table of average balance and interest rates above and is based on the Group's U.S. GAAP Financial Statements.

	Year ended December 31,

	2009 As restated⁽²⁾			2010 As restated⁽²⁾			2011
	(EUR in thousands, except percentages)
Domestic:
Average interest earning assets		68,488,200			75,018,830			70,518,825
Total interest income		3,218,821			3,209,147			3,354,661
Average interest bearing liabilities		69,951,354			75,062,307			75,738,358
Total interest expense		1,157,487			915,823			1,223,103
Net interest income		2,061,334			2,293,324			2,131,558
Net interest margin⁽¹⁾		3.01	%		3.06	%		3.02	%
Foreign:
Average interest earning assets		28,576,776			31,919,712			31,464,428
Total interest income		3,012,559			2,939,689			2,904,989
Average interest bearing liabilities		27,024,315			27,746,921			25,013,534
Total interest expense		1,287,628			1,149,412			1,388,396
Net interest income		1,724,931			1,790,277			1,516,593
Net interest margin⁽¹⁾		6.04	%		5.61	%		4.82	%

The following table presents certain selected financial information and ratios for the Group for the periods indicated from operations:

	Year ended December 31,

	2009 As restated⁽³⁾			2010 As restated⁽³⁾			2011
	(EUR in thousands, except percentages)
Net interest income before provision for loan losses		3,786,265			4,083,601			3,648,151
Net income / (loss)		453,284			(308,004	)		(14,507,479	)
Net income / (loss) attributable to NBG shareholders		391,052			(354,772	)		(14,539,668	)
Average total assets		109,968,504			120,104,111			118,265,297
Average NBG shareholders' equity⁽¹⁾		7,093,822			7,923,059			1,697,698
Net interest income before provision for loan losses as a percent of:
Average total assets		3.44	%		3.40	%		3.08	%
Average NBG shareholders' equity⁽¹⁾		53.37	%		51.54	%		214.89	%
Net income / (loss) as a percent of:
Average total assets		0.41	%		(0.26	)%		(12.27	)%
Net income / (loss) attributable to NBG shareholders as a percent of:
Average NBG shareholders' equity⁽¹⁾		5.51	%		(4.48	)%		—
Average NBG shareholders' equity to average total assets		6.45	%		6.60	%		1.44	%

On December 31, 2011, the Group's securities had a carrying value of EUR 12.5 billion, representing 12.1% of the Group's total assets and sovereign securities held accounted for EUR 10.7 billion, or 85.0% of the Group's securities portfolio. In preparing the U.S. GAAP Financial Statements, the Group classified its securities as required by U.S. GAAP according to the following categories: trading, AFS and HTM.

The Group holds a significant amount of Greek government bonds and treasury bills. The market and book value of these bonds held by the Group (which includes securities held in our trading, AFS and HTM portfolios) on December 31, 2011 was EUR 7.0 billion and EUR 7.1 billion respectively. The book value of Greek government bonds represents 6.8% of the Group's total assets.

Furthermore, on December 31, 2011, the Group held debt securities rated AAA (or equivalent), issued by Germany, France, Austria, the EFSF and the European Investment Bank ("EIB") (classified as trading, AFS, or HTM) with a market and book value of EUR 165.5 million and EUR 157.3 million respectively, and through its subsidiary Finansbank, held securities issued by the Republic of Turkey (classified as trading or AFS) with a market (and book) value of EUR 2.7 billion.

The Group's equity portfolio comprises proprietary investment activities on the ATHEX as well as equities obtained in loan foreclosure actions and workouts. As part of our aim to restructure our operations, the Group has been strategically divesting our holdings in non-core businesses. In 2009 the Bank disposed 20% of its participation in Social Securities Funds Management S.A. reducing its participation from 40% to 20% for a consideration of EUR 1.3 million and disposed of its investment in Phosphoric Fertilizers Industry S.A. for a consideration of EUR 18.9 million, EUR 2.6 million of which has been deposited in an escrow account to set off contingent liabilities. For more information on the Group's divestitures see Item 4.A, "History and Development of the Company".

The following table sets forth the cost and fair value of each type of the Group's debt and equity assets held for trading on December 31, 2009, 2010 and 2011:

	Year ended December 31,

	2009 As restated⁽¹⁾				2010 As restated⁽¹⁾				2011
	Amortized Cost		Fair Value		Amortized Cost		Fair Value		Amortized Cost		Fair Value
	(EUR in thousands)
Trading Account Securities
Greek government bonds		2,100,714		2,070,858		991,450		797,377		871,013		259,233
Debt securities issued by other governments and public sector entities		182,122		194,986		183,294		177,333		231,383		219,807
Debt securities issued by Greek financial institutions incorporated in Greece		180,898		175,933		344,140		316,997		79,862		55,271
Debt securities issued by foreign financial institutions		403,939		344,022		569,070		509,293		171,470		115,573
Equity securities issued by companies incorporated in Greece		28,414		29,692		4,506		6,082		7,413		7,767
Equity securities issued by foreign companies		6,385		7,682		10,794		10,272		10,175		8,750
Greek treasury bills		896,797		893,471		937,472		934,552		2,271,880		2,268,222
Foreign treasury bills		3,779		3,779		13,562		13,562		27,778		24,057
Mutual funds		340,258		344,567		19,579		19,854		6,825		5,408

Total		4,143,306		4,064,990		3,073,867		2,785,322		3,677,799		2,964,088

The following table sets forth the amortized cost and fair value as well as gross unrealized gains and losses of each type of the Group's AFS and HTM securities at December 31, 2009, 2010 and 2011:

	Year ended December 31,

	2009 As restated⁽¹⁾									2010 As restated⁽¹⁾									2011
	Amortized Cost		Gross Unrealized Gains		Gross Unrealized Losses			Fair Value		Amortized Cost		Gross Unrealized Gains		Gross Unrealized Losses			Fair Value		Amortized Cost		Gross Unrealized Gains		Gross Unrealized Losses			Fair Value
	(EUR in thousands)
Available-for-sale securities
Greek government bonds		9,945,165		20,264		(661,831	)		9,303,598		9,581,861		—		(2,925,797	)		6,656,064		3,730,682		—		(33,304	)		3,697,378
Debt securities issued by other governments and public sector entities		3,195,125		64,961		(37,636	)		3,222,450		3,671,148		92,991		(3,433	)		3,760,706		3,154,367		7,840		(108,456	)		3,053,751
Corporate debt securities issued by companies incorporated in Greece		924,228		4,159		(73,897	)		854,490		1,093,095		3		(254,310	)		838,788		701,889		685		(242,048	)		460,526
Corporate debt securities issued by companies incorporated outside Greece		1,587,378		22,443		(92,964	)		1,516,857		1,414,465		66,649		(58,822	)		1,422,292		715,904		32,653		(93,675	)		654,882
Equity securities issued by companies incorporated in Greece		221,689		957		(1,636	)		221,010		145,444		1,535		(483	)		146,496		56,968		817		(165	)		57,620
Equity securities issued by companies incorporated outside Greece		44,542		6,030		(1,699	)		48,873		145,022		4,394		(2,918	)		146,498		42,107		6,121		(3,273	)		44,955
Foreign treasury bills		342,617		0		0			342,617		220,121		2		(1,803	)		218,320		181,130		53		(733	)		180,450
Mutual fund units		588,759		4,068		(19,409	)		573,418		510,566		6,296		(17,516	)		499,346		452,200		2,254		(32,292	)		422,162

Total available-for-sale securities		16,849,503		122,882		(889,072	)		16,083,313		16,781,722		171,870		(3,265,082	)		13,688,510		9,035,247		50,423		(513,946	)		8,571,724

Held-to-maturity securities
Greek government bonds		34,389		—		(6,251	)		28,138		3,473,774		—		(983,862	)		2,489,912		845,015		—		(40,589	)		804,426
Debt securities issued by other governments and public sector entities		60,214		6,827		—			67,041		105,671		8,263		(2,161	)		111,773		107,206		8,258		(6,570	)		108,894
Corporate debt securities issued by companies incorporated outside Greece		5,001		14		—			5,015		5,000		—		—			5,000		—		—		—			—
Foreign treasury bills		—		—		—			—		13,840		—		—			13,840		49,981		—		—			49,981

Total held-to-maturity securities		99,604		6,841		(6,251	)		100,194		3,598,285		8,263		(986,023	)		2,620,525		1,002,202		8,258		(47,159	)		963,301

As of December 31, 2010 and 2011, the Group did not hold any U.S. federal debt securities.

Excluded from the unrecognized losses presented in the table above relating to the held to maturity securities, as at December 31, 2011 are EUR 16.7 million unrealized losses, which relate to the unamortized balance of the unrealized losses (before tax) that have been recorded in OCI prior to the reclassification in 2010 of certain held to maturity securities from available for sale.

	Year ended December 31, 2011

	Within one year or less							After one year through five years							After five years through ten years							After ten years
	Amortized Cost		Weighted average yield			Fair Value		Amortized Cost		Weighted average yield			Fair Value		Amortized Cost		Weighted average yield			Fair Value		Amortized Cost		Weighted average yield			Fair Value
	(EUR in thousands, except percentages)
Trading account debt securities:
Greek government and agencies		101,857		10.38	%		27,233		246,314		6.43	%		66,934		306,693		8.13	%		88,936		216,149		6.72	%		76,130
Debt securities issued by other governments and public sector entities		15,207		6.30	%		15,383		76,090		5.12	%		67,542		74,449		5.34	%		75,196		65,637		4.42	%		61,686
Debt securities issued by Greek financial institutions		15,000		3.50	%		14,835		45,012		12.48	%		29,189		—		0.00	%		—		1,085		3.33	%		371
Debt securities issued by foreign financial institutions		16,166		9.94	%		16,025		100,428		16.74	%		71,818		23,554		7.80	%		14,696		24,699		6.00	%		7,487
Corporate debt securities issued by Greek companies		—		0.00	%		—		18,765		4.22	%		10,876		—		0.00	%		—		—		0.00	%		—
Corporate debt securities issued by foreign companies		—		0.00	%		—		6,623		8.10	%		5,547		—		0.00	%		—		—		0.00	%		—
Greek treasury bills		2,271,880		4.85	%		2,268,222		—		0.00	%		—		—		0.00	%		—		—		0.00	%		—
Foreign treasury bills		27,778		0.00	%		24,057		—		0.00	%		—		—		0.00	%		—		—		0.00	%		—

Total trading account debt securities		2,447,888		5.06	%		2,365,755		493,232		8.82	%		251,906		404,696		7.59	%		178,828		307,570		6.16	%		145,674

Available-for-sale debt securities:
Greek government and agencies		130,901		8.99	%		130,901		1,988,566		7.09	%		1,955,262		643,437		10.68	%		643,437		967,778		9.46	%		967,778
Debt securities issued by other governments and public sector entities		64,871		6.19	%		64,178		1,725,279		7.95	%		1,667,905		1,150,657		5.83	%		1,120,792		213,560		5.85	%		200,876
Corporate debt securities issued by companies incorporated in Greece		123,809		6.14	%		109,263		354,739		9.23	%		221,078		142,069		0.25	%		48,913		81,272		1.66	%		81,272
Corporate debt securities issued by companies incorporated outside Greece		43,106		5.56	%		38,085		453,554		12.98	%		447,115		149,655		4.19	%		134,020		69,591		2.44	%		35,662
Foreign treasury bills		178,695		3.59	%		178,001		2,434		4.00	%		2,449		—		0.00	%		—		—		0.00	%		—

Total available-for-sale debt securities		541,382		5.95	%		520,428		4,524,572		8.18	%		4,293,809		2,085,818		6.83	%		1,947,162		1,332,201		8.04	%		1,285,588

Held-to-maturity securities:
Greek government and agencies		90,493		7.43	%		90,493		356,897		4.73	%		316,308		368,963		6.07	%		368,963		28,662		12.00	%		28,662
Debt securities issued by other governments and public sector entities		7,935		1.52	%		8,007		19,301		9.83	%		16,328		20,836		10.33	%		17,239		59,134		4.93	%		67,320
Foreign treasury bills		49,981		4.61	%		49,981		—		0.00	%		—		—		0.00	%		—		—		0.00	%		—

Total held-to-maturity debt securities		148,409		6.16	%		148,481		376,198		5.00	%		332,636		389,799		6.30	%		386,202		87,796		7.23	%		95,982

As at December 31, 2011, the amount of the Group's total net loans equaled EUR 69,452.2 million. The Group's loan portfolio consists of 47.7% consumer and 52.3% commercial loans (see Note 13 to the U.S. GAAP Financial Statements). As at December 31, 2011, loans to Greek residents represent 68.4% of the Group's loan portfolio.

Loans by Type of Customer: The Group offers a wide range of credit instruments to domestic and foreign businesses as well as to Greek government- related entities and individuals, including letters of credit and long-term and short-term loans.

The following table provides details of loans to customers made by the Group, classified by type of loan, the borrower's principal economic activity, as well as the breakdown of loans to Greek and foreign residents as at December 31, 2007, 2008, 2009, 2010 and 2011.

	Year ended December 31,

	2007		2008			2009			2010			2011
	(EUR in thousands)
Greek residents:
*Consumer:*
Residential mortgages		15,675,911		17,772,186			19,411,436			19,544,275			18,762,689
Credit card		1,543,832		1,722,520			1,913,804			1,773,156			1,527,119
Auto financing		181,973		250,130			433,563			405,734			308,598
Other consumer		3,878,343		4,622,064			4,890,722			4,852,444			4,763,063

Total		21,280,059		24,366,900			26,649,525			26,575,609			25,361,469

*Commercial:*
Industry and mining		3,150,111		3,431,239			3,471,756			3,675,468			4,084,213
Small-scale industry		1,353,943		1,857,602			2,066,500			2,090,239			1,962,344
Trade		5,067,392		7,290,620			8,280,514			7,788,532			7,374,620
Construction		736,584		1,216,237			1,252,555			1,226,936			1,131,868
Tourism		169,937		312,513			493,206			484,394			479,955
Shipping and transportation		1,204,350		1,882,210			1,876,137			2,152,631			2,216,777
Commercial mortgage		678,880		832,593			925,085			880,697			774,709
Public sector		1,814,646		8,101,757			8,522,357			8,860,862			8,711,152
Other		1,906,747		647,654			421,479			247,319			88,376

Total		16,082,590		25,572,425			27,309,589			27,407,078			26,824,014

Total Greek residents loans		37,362,649		49,939,325			53,959,114			53,982,687			52,185,483
Unearned income		53,600		(187,135	)		(28,711	)		(58,824	)		(92,749	)

Total Greek residents loans net of unearned income		37,416,249		49,752,190			53,930,403			53,923,863			52,092,734

The Bank has on its balance sheet under the line item Commercial loans—Public sector:

	Year ended December 31,

	2007			2008			2009			2010			2011
	(EUR in thousands)
Foreign:
*Consumer:*
Residential mortgages		2,814,814			3,466,936			3,841,014			4,725,702			4,148,062
Credit card		1,645,264			1,844,527			2,403,912			3,503,593			3,763,261
Auto financing		340,841			319,705			263,254			205,996			144,085
Other consumer		1,958,759			2,445,982			2,680,275			3,084,471			2,990,411

Total		6,759,678			8,077,150			9,188,455			11,519,762			11,045,819

*Commercial:*
Industry and mining		1,271,942			2,237,964			2,653,578			2,974,037			3,020,134
Small-scale industry		1,528,069			1,802,722			1,663,914			1,449,556			1,295,509
Trade		1,465,008			2,279,365			3,412,668			3,784,789			3,600,619
Construction		1,439,452			1,776,701			1,461,677			1,597,771			1,629,284
Tourism		387,607			423,302			335,369			396,622			279,303
Shipping and transportation		462,110			593,026			676,727			780,670			799,940
Commercial mortgage		113,046			1,260,464			613,213			700,715			647,331
Public sector		1,414			120,290			383,686			392,521			280,712
Other		4,922,183			2,417,140			1,697,936			1,707,828			1,479,101

Total		11,590,831			12,910,974			12,898,768			13,784,509			13,031,933

Total foreign loans		18,350,509			20,988,124			22,087,223			25,304,271			24,077,752
Unearned income		(206,266	)		(273,270	)		(183,722	)		(189,694	)		(167,629	)

Total foreign loans net of unearned income		18,144,243			20,714,854			21,903,501			25,114,577			23,910,123
Total loans net of unearned income		55,560,492			70,467,044			75,833,904			79,038,440			76,002,857

Less: Allowance for loan losses		(1,132,952	)		(1,232,626	)		(2,065,178	)		(3,175,405	)		(6,550,635	)

Total net loans		54,427,540			69,234,418			73,768,726			75,863,035			69,452,222

A brief description of the type of loan classifications included in the above analysis is as follows.

Residential mortgages consist primarily of fixed rate and floating rate loans collateralized by first-ranking security interests in owner-occupied dwellings including houses and condominiums. These loans are nearly all secured by pre-notation which is less expensive and easier to record than mortgages. See, below in Item 4.E, "Selected Statistical Data—Credit Quality and Risk Management—Credit Quality—Risk Management—Loan Approval Process". Greek government-subsidized mortgage loans are offered by the Group to domestic borrowers who meet certain criteria.

Auto financing loans are extended for personal vehicles and are mostly secured.

Other consumer loans are made to individuals on installment plans to finance the purchase of consumer goods and to pay for services. The Bank extends revolving credit facilities for retail customers under which approved customers can withdraw funds up to the limit of their individual credit facility as needed for personal purposes. These loans are unsecured.

Short-term credit facilities lasting one year or less make up the majority of the Group's commercial loans. Generally, if the borrower meets interest payments in a timely manner, his/her facility is rolled over, subject to the wishes of the borrower and the Bank's credit review policies.

The rollover policy of the Group stipulates full repayment of loan obligations upon maturity or the expiry of a loan facility before a new loan is extended. Bank's procedures and policies imply a formal comprehensive re-assessment of client's creditworthiness and credit facility structure (renewal of credit facility) at least annually or whenever early warning signs appear. Early warning signs indicatively, may be: decline of financial standing; improper financial management (new investments financed from short term sources; improper distribution of profits, excessive additional debts to suppliers or banks, etc); negative market information (business partners, other Bank's clients, media channels etc.) regarding the debtor's ability to honor financial obligations; repeated delays in debt servicing; deterioration of collateral's value. Borrower comprehensive reassessment involves the assignment a rate that corresponds to a PD that is considered upon the impairment assessment.

Industry and mining loans include credit extensions primarily made to corporations involved in textile, food and beverage, chemical, and metals mining ventures. Such loans are generally secured by interests in the customers' real property and operating assets.

Small scale industry loans are made to commercial ventures that generally employ fewer than 50 persons, and such loans are secured by assets owned by the company or its shareholders.

Trade loans are made to ventures which do not manufacture goods but import, export, distribute and sell goods. Such loans are typically secured by inventory or assets of the company's shareholders.

Construction loans are made for large-scale infrastructure or commercial projects undertaken by private entities on their own behalf or on behalf of government public works offices. Construction loans for commercial projects are typically secured by mortgages.

Tourism loans are made primarily to developers and operators of hotel and resort properties and are secured by interests in those properties.

Shipping and transportation loans are advanced primarily for shipbuilding, and to a lesser extent, shipyard construction and vessel acquisitions and are secured by interests in the vessels or other property and the future revenues generated by the vessels. Other transportation loans relate to ground and air transport.

Commercial mortgages are loans for the acquisition of real estate used in business. These loans are nearly all secured by pre-notation which is less costly and easier to administer than a mortgage.

Public sector loans are advanced to the Hellenic Republic, public utilities and entities governed by the public law of Greece.

The following table provides details of loans to customers made by the Group by maturity, classified by type of loan, the borrower's principal economic activity, as well as the breakdown of domestic and foreign loans as at December 31, 2011.

	Year ended December 31, 2011

	Within one year or less			After one year through five years			After five years			Total
	(EUR in thousands)
Greek Residents:
*Consumer:*
Residential mortgages		2,950,031			3,741,141			12,071,517			18,762,689
Credit card		1,527,119									1,527,119
Auto financing		42,585			225,690			40,323			308,598
Other consumer		2,369,854			1,639,561			753,648			4,763,063

Total		6,889,589			5,606,392			12,865,488			25,361,469

*Commercial:*
Industry and mining		2,139,516			1,378,122			566,575			4,084,213
Small-scale industry		1,081,893			632,235			248,216			1,962,344
Trade		3,838,984			2,483,178			1,052,458			7,374,620
Construction		551,556			372,968			207,344			1,131,868
Tourism		265,061			150,530			64,364			479,955
Shipping and transportation		779,324			863,967			573,486			2,216,777
Commercial mortgages		112,842			154,198			507,669			774,709
Public sector		780,971			3,631,452			4,298,729			8,711,152
Other		47,962			27,657			12,757			88,376

Total		9,598,109			9,694,307			7,531,598			26,824,014

Total Greek residents loans		16,487,698			15,300,699			20,397,086			52,185,483

Foreign:
*Consumer:*
Residential mortgages		580,333			1,473,872			2,093,857			4,148,062
Credit card		3,352,293			327,714			83,254			3,763,261
Auto financing		56,068			80,012			8,005			144,085
Other consumer		1,234,028			1,199,750			556,633			2,990,411

Total		5,222,722			3,081,348			2,741,749			11,045,819

*Commercial:*
Industry and mining		1,641,071			982,151			396,912			3,020,134
Small-scale industry		966,669			278,922			49,918			1,295,509
Trade		2,079,245			1,122,455			398,919			3,600,619
Construction		669,441			454,072			505,771			1,629,284
Tourism		104,347			102,888			72,068			279,303
Shipping and transportation		373,512			254,949			171,479			799,940
Commercial mortgages		148,085			280,918			218,328			647,331
Public sector		22,507			86,888			171,317			280,712
Other		543,037			572,986			363,078			1,479,101

Total		6,547,914			4,136,229			2,347,790			13,031,933

Total foreign loans		11,770,636			7,217,577			5,089,539			24,077,752
Unearned income		(108,294	)		(94,088	)		(57,996	)		(260,378	)

Loans, net of unearned income		28,150,040			22,424,188			25,428,629			76,002,857
Less: Allowance for loan losses		(6,550,635	)		—			—			(6,550,635	)

Total net loans		21,599,405			22,424,188			25,428,629			69,452,222

Out of the Group's loans outstanding at December 31, 2011 that are due after one year, EUR 14.5 billion had fixed interest rates while EUR 33.4 billion had floating interest rates.

The Group's foreign country outstandings, representing specific country risk, are extended primarily by the Group's foreign branches and banking subsidiaries. The Bank's Greek and London operations also provide loans customarily made in U.S. dollars to the shipping industry, as well as loans denominated in other currencies as requested by customers. The Group's most significant exposure to foreign countries for the year ended December 31, 2009 was to Turkey, Bulgaria, Romania, United Kingdom and Cyprus, for the year ended December 31, 2010 to Turkey, Bulgaria Romania and United Kingdom and for the year ended December 31, 2011 to Turkey, Bulgaria, Romania and United Kingdom. These foreign country outstandings represent additional economic and political risks. For additional information on the macroeconomic and political risks from operating in Turkey, as well as for the risks of conducting significant international activities and expanding in emerging markets, see Item 3.D, "Risk Factors".

The tables below show the amount of foreign country outstandings, as at December 31, 2009, 2010 and 2011, in each foreign country where such outstandings amounts exceeded 1% of the Group's total assets.

The table below shows the amount of foreign country loans, excluding unearned income, by type of borrower for countries where the Group's exposure exceeded 1% of total assets at December 31, 2009, 2010 and 2011.

	Year ended December 31, 2009

	Country
	Turkey		Bulgaria		Romania		Serbia		United Kingdom
	(EUR in thousands)
Consumer:
Residential mortgages		2,274,690		690,094		456,386		92,982		34
Credit card		2,193,471		136,163		4,615		5,086		—
Auto financing		164,985		39,475		17,517		3,803		—
Other consumer		1,104,242		663,447		466,467		41,718		114

Total		5,737,388		1,529,179		944,985		143,589		148

Commercial:
Industry and mining		1,324,098		326,520		193,733		136,560		320,722
Small-scale industry		1,111,217		377,973		32,679		—		—
Trade		1,892,706		591,390		308,071		195,293		71,036
Construction		360,861		612,377		147,207		164,085		82,661
Tourism		160,456		94,332		31,153		30,921		234
Shipping and transportation		300,973		189,825		52,207		48,051		—
Mortgages		18,419		20,290		460,186		—		30,182
Public sector		—		6,430		80,000		52,393		—
Other		388,539		310,401		101,122		67,324		146,071

Total		5,557,269		2,529,538		1,406,358		694,627		650,906

Total loans		11,294,657		4,058,717		2,351,343		838,216		651,054

	Year ended December 31, 2010

	Country
	Turkey		Bulgaria		Romania		United Kingdom
	(EUR in thousands)
Consumer:
Residential mortgages		3,004,096		678,601		582,446		14
Credit card		3,323,439		116,014		4,904		—
Auto financing		120,970		33,429		14,103		—
Other consumer		1,620,372		607,858		411,690		125

Total		8,068,877		1,435,902		1,013,143		139

Commercial:
Industry and mining		1,748,652		311,033		174,174		269,789
Small-scale industry		962,745		316,072		25,968		—
Trade		2,350,663		536,771		261,851		79,049
Construction		497,569		552,772		165,343		85,345
Tourism		242,611		75,264		38,570		261
Shipping and transportation		428,690		149,744		44,213		—
Mortgages		126,303		20,781		432,451		33,834
Public sector		—		7,856		80,000		—
Other		495,932		259,800		83,954		147,361

Total		6,853,165		2,230,093		1,306,524		615,639

Total loans		14,922,042		3,665,995		2,319,667		615,778

	Year ended December 31, 2011

	Country
	Turkey		Bulgaria		Romania		United Kingdom
	(EUR in thousands)
Consumer:
Residential mortgages		2,430,215		652,647		589,929		19,784
Credit card		3,608,473		90,137		5,250		—
Auto financing		74,852		24,315		13,336		—
Other consumer		1,632,633		544,943		353,033		193

Total		7,746,173		1,312,042		961,548		19,977

Commercial:
Industry and mining		1,814,633		276,970		129,106		312,381
Small-scale industry		961,398		257,995		23,021		—
Trade		2,392,217		491,967		208,110		26,277
Construction		639,233		457,475		136,534		88,056
Tourism		132,642		72,914		34,660		248
Shipping and transportation		434,369		143,798		28,415		—
Mortgages		73,944		23,337		422,086		33,819
Public sector		54,899		6,317		—		14
Other		386,174		217,536		64,300		97,953

Total		6,889,509		1,948,309		1,046,232		558,748

Total loans		14,635,682		3,260,351		2,007,780		578,725

NBG Group has a well-established framework and supporting policies for managing the credit risk associated with lending across our business divisions. The framework and policies encompass all stages of the credit cycle including origination, evaluation, approval, documentation, settlement, on-going administration and problem management.

The discussion below relates to the Bank and our banking subsidiaries, Finansbank, UBB, Banca Romaneasca, Vojvodjanska, Stopanska Banka, NBG Cyprus and SABA.

The Bank has established a centralized credit approval process, which is governed by the Credit Policy for the Corporate Banking Portfolio (the "Credit Policy"). The Corporate Banking Portfolio includes all corporate customers managed by Corporate Banking. The Credit Policy addresses core credit policies and procedures for identifying, measuring, approving and reporting credit risk. To this end, it includes a set of rules related to the extensions of credit and the granting of approval authority.

We have established criteria for corporate and institutional lending, which may vary by industry segment. Industries include manufacturing, wholesale trade, logistics and communication, services, retail, energy, construction, food, textiles, hotels, restaurants etc. The underwriting process and credit evaluation are fully centralized. All of the Bank's Corporate customers are evaluated through the Moody's Risk Analyst ("MRA") platform. It comprises four models for rating corporate obligors, according to the existence of full financial statements by the firm and to the specificity of the obligor's business. Around 85% of corporate customers are rated using a standard Corporate Rating Model ("CRM") which collects and analyzes historical and projected financial information, taking also into consideration qualitative parameters like the industry sector and an assessment of the company's management. CRM's assessment criteria are set by our Group Risk Control and Architecture Division ("GRCAD"). The remaining 15% of corporate customers are evaluated through specialized lending models (incl, shipping and project finance) and other scorecards (e.g. for firms with limited or no financial data). There are comprehensive multi-level approval authorities in place that are based upon a function of total exposure and security value with the requirement to have at least two individuals involved (the "four-eyes principle") throughout the underwriting process.

The loan approval process relies on both qualitative criteria (such as information on industry of operation, history of the borrower, information on the management, and dependence on key personnel) as well as quantitative criteria arising from the financial information of the borrower. We focus on the performance of key financial risk ratios, including interest coverage debt serviceability and balance sheet structure. In addition, consideration of the future prospects of the borrower and its market is given through business plans, budgets as well as macroeconomic indicators. The analysis is based on the documents requested such as tax forms, recent financial statements, borrower's articles of incorporation, budgets, and other documents as applicable, depending on the purpose of the funding.

When providing finance to smaller business, commercial and corporate borrowers, we typically obtain security, such as a charge over business assets and/or real estate. For larger corporations and institutions, we typically also require compliance with selected financial ratios and undertakings and we may hold security. In respect of commercial property lending, we maintain loan origination and on-going risk management standards, including specialized management for higher value loans. We consider factors such as the nature, location, quality and expected demand for the asset, tenancy profile

and experience and quality of management. We actively monitor the Greek property market and the composition of our commercial property loan book across the Bank.

Credit approvals are based on credit proposals prepared by Corporate Banking and submitted for approval as appropriate. The approval level primarily depends on the total amount of proposed facilities, tenor, the classification of the obligor and the sector. All credit extensions are subject to the approval of authorized Credit Division members or the Chief Credit Risk Officer.

The Bank offers a full range of retail credit products ranging from credit cards to SME financing. Retail Banking is organized into four sub-divisions: Mortgage Lending, Consumer Banking, Credit Cards and SBL.

Credit policies are communicated throughout the Bank by means of credit manuals and circulars, supplemented by bulletins and local directives on particular issues. The Bank has developed and implemented a credit manual for each of the retail portfolios described below, which is periodically revised. All credit policies are submitted to and approved by the Group's Board Risk Committee.

The credit granting processes and procedures are fully centralized with comprehensive multi-level approval authorities in place that are based upon a function of total exposure and security value. Although each sub-division maintains credit approval authorities, the credit approval process is ultimately governed by the Group Retail Credit Risk Division, which serves as the Retail Credit Policy custodian. It operates under the supervision of the Group Chief Risk Officer and takes active part in the credit approval process, its consent being necessary for exposures above certain levels. The rationale behind this organizational structure is to ensure the correct application of credit policy, to efficiently channel applications through the business pipeline while ensuring accuracy and consistency and to effectively monitor the client information input process.

Applications for all retail product categories are originated at the branch network level, where application processing systems are utilized and physical documentation is obtained and verified (for example income certificates, payroll slips, collateral certificates and other documents depending on the product type). We have established product-based standards for lending to individuals with key controls,

including maximum PTI and maximum LTV, maximum loan tenor, application and behavioral scores that are considered for the analysis and final decision by the appropriate approval authority. As in Corporate Banking, the four-eye principle is implemented throughout the underwriting process. In addition, periodic post approval reviews are conducted to ensure quality and completeness.

The development of portfolio models also allows our GRCAD to calculate, evaluate and monitor expected and unexpected losses for all portfolio asset classes and segments. For more information on our Group Risk Control and Architecture Division, see Item 5.B, "Liquidity and Capital Resources—Risk Management Governance—Group Risk Management".

The Bank has adapted its credit policies in response to the crisis that started in 2008 by setting more stringent underwriting criteria.

In particular, all mortgage applications received by the Bank are rated using a bespoke application scorecard and a behavioral model which further enhances the credit decision. The application scorecard takes into account the applicant's and the guarantor's (if any) demographics, income, employment, credit history with the Bank as well as throughout the Greek banking system and the overall relationship with the Bank. The maximum application score is 280, and the Bank has gradually increased the highest rejection score from 170 in 2008 to 199 since February 2010. In addition, PTI and LTV ratios are also taken into consideration.

PTI ratio is defined as the amount of total annual payments derived from any retail exposure of the applicant and any guarantors towards NBG as well as to other banks, such as amortizing loans, credit cards limits and open loans, including any guarantees, in relation to their total annual income of a stable nature. In case of businessmen, self employed, doctors and lawyers, as well as for civil servants or employees with annual income exceeding EUR 40,000, the Bank requires the income statements for the last three years. Since 2010, the Bank gradually decreased maximum PTI below the threshold limit of 40% set by the Bank of Greece, at the low level of 25% since April 2011.

Generally, LTV cannot exceed 75% of the asset's market value. However, in some instances, 85% may be acceptable depending on various factors and specific circumstances including, among others, the applicant's credit profile, type of ownership, location of the asset and type of financed property. Average LTV of mortgage loans decreased from 75% for loans originated in 2008 to 66% for loans originated in 2010 and 72% in 2011. Average current LTV of the total Greek mortgage portfolio as at December 31, 2011 was 64%.

Due to the abovementioned stringent underwriting criteria applied in recent years, our approval rate for mortgage lending has decreased from 80% in 2008 to 33% in 2011.

We expect that these actions will reduce the probability of default by reducing the generation of impaired loans in future years, and will also improve the loss rates as future impaired loans will be better collateralized. Therefore, although the methodology for estimating the allowance for loan losses has not changed, we expect that the application of these more stringent loan approval criteria will reduce the allowance for loan losses as a percentage of both our total loan portfolio and our impaired loans. The underwriting process is centralized under Mortgage Lending. Centralized underwriting ensures segregation of duties and uniform enforcement of underwriting standards. The loan security is typically in the form of a mortgage pre-notation on a property for 120% of the loan amount. Pre-notation is easily converted into a full mortgage following a non-appealable court order or decision, which may be obtained at the request of the Bank in the event of default.

Qualified appraisers, both in-house and outsourced, are completely independent from the underwriting process and carry out collateral valuation. In doing so, they have to take into account the market value of the property. In addition, they perform an estimation of liquidation possibilities, taking into account the levels of commercial activity with respect to properties with similar characteristics. Furthermore, the appraisers apply conservative assumptions in estimating market values and formulate a useful benchmark, serving as an indication of the minimum asking price for the asset.

The Bank offers a wide range of mortgage products, mainly in euro, to both owner-occupiers and investors with floating, fixed, or a combination of fixed and floating interest rates, secured by a mortgage over the subject property or other acceptable collateral. Floating rate mortgages are indexed, based on three-month Euribor plus a spread, depending predominately on the customer's credit profile and loan characteristics (i.e. LTV and PTI ratios, loan purpose, loan amount). Tenor period may vary and reach up to 30 years subject to an individual's age and loan purpose (i.e. acquisition or repair). Other than the aforementioned products, the Bank does not offer any hybrid loans or sub-prime loans. Although a standard industry definition for subprime loans (including subprime mortgage loans) does not exist, we define subprime loan as specific product offerings for higher risk borrowers, including individuals with one or a combination of high credit risk factors, such as high debt to income ratios and inferior payment history.

As at December 31, 2011, approximately 17.8% of balances and 24.1% of accounts of our mortgage portfolio, is either guaranteed or subsidized by the Hellenic Republic. The economic crisis affecting the Hellenic Republic had no impact so far on the subsidies and guarantees. A further deterioration of the Hellenic Republic's finances may adversely affect its ability to pay the subsidies and honor the guarantees and as a result the provision charge and allowance for loan losses may increase in the future.

The Bank offers mortgages subsidized by the Hellenic Republic or/and by the Social Housing Organization (OEK). These subsidies are available solely for mortgages extended to fund the purchase or construction of the borrower's primary residence.

For the mortgages subsidized by the Hellenic Republic, the subsidy is calculated as a percentage on the loan's interest rate and is offered for half of the loan's contractual life with a maximum of 8 to 10 years, depending on the relevant Ministry's decisions. These mortgages follow the same underwriting procedure as all other mortgage loans; however, the borrower has to comply with certain lending criteria imposed by the Hellenic Republic in order to be eligible for a subsidy. These criteria mainly refer to the borrower's financial and family status.

For the mortgages subsidized by OEK, the subsidy is calculated as a percentage of the loan's interest rate and depends on the borrower's family status and is offered for 9 years. The underwriting procedure is the one followed for a "typical" mortgage loan with the exception that the applicant has to submit to the Bank a certificate from OEK, that verifies his/her eligibility as well as the property evaluation conducted by OEK.

As at December 31, 2010 and 2011, the total amount of mortgage loans subsidized by the Hellenic Republic or OEK amounted to EUR 2,463 million and EUR 2,062 million, respectively. Mortgage loans subsidized by the Hellenic Republic or OEK are not subject to restructuring.

Mortgages guaranteed by the Hellenic Republic represent loans to victims of natural disasters (e.g. earthquakes, floods, landslides and fires), loans to Greeks repatriated from the former Soviet Union and loans to Greek Roma. The Hellenic Republic guarantees both the principal and the interest

of these loans. Loan applications do not follow the Bank's origination process. Instead, all documentation as well as the loan application is submitted to the relevant public authority for approval. The maximum amount per loan is EUR 60,000 with the exception of the loans to victims of natural disasters where the loan amount is determined by the public authority, in accordance with the guidelines set by Greek legislation.

The Repatriated Greek program was formally ceased by the Hellenic Republic on February 29, 2008 and the Bank's participation in the Greek Roma program ended on November 1, 2007. Since 2008 the Bank has not been active in the funding of victims of natural disasters.

As of December 31, 2010 and 2011, the total amount of mortgage loans guaranteed by the Hellenic Republic amounted to EUR 1,498 million and EUR 1,411 million, respectively. Mortgage loans guaranteed by the Hellenic Republic are not subject to restructuring.

For personal loans and credit cards, the credit approval process is carried out through the use of bespoke credit scorecards, developed on the basis of historical data. These are used for the review of applications to ensure effective and accurate decision-making. Sophisticated statistical methods are subsequently implemented to determine pricing and risk/return ratios. Furthermore, a behavioral model is used in the decision-making and line increase process as well as for strategic marketing.

The aforementioned behavioral scoring models are combined to produce a Bank Customer Rating regardless of specific sub-products.

The GRCAD produces, among other reports, ageing analyses by period of disbursement, issuing channel, and product type for various delinquency definitions. Exposures are pooled by application score and delinquency bucket to produce estimates of default probabilities. Consumer loans are generally not collateralized, with the exception of car loans.

The SME Division has created small business credit centers in Athens, Thessaloniki and Patras in order to standardize lending criteria. These credit centers handle all of the Bank's credit applications, whether from entrepreneurs or SMEs.

The credit centers are staffed by lending teams under the supervision of a team leader. Credit underwriters use a decision support model to assist in their credit decisions when reviewing and making credit decisions on applications forwarded by branches. An internal rating model is also used for the credit evaluation of loan requests. This model further improves the quality of decisions and reduces the time required for the credit granting process. In addition, an, internally developed, behavioral scoring model has been implemented and utilized. Its scope is to continually assess repayment behavior and performance and to further enhance the quality of credit decisions regarding to the existing portfolio. Finally, the Bank is currently participating in the development of a Bureau Score tailored specifically for SME credit. This new model will be used in a two-fold manner, as a parameter in credit decisions and for purposes of benchmarking.

There are four credit approval authority levels applicable to SME lending. However, SME credit exposures above EUR 5.0 million and up to EUR 7.5 million must also be approved by the Group Retail Credit Manager while SME credit exposures in excess of EUR 7.5 million have to be approved jointly by the Group Credit Risk Officer and the General Manager of Retail Banking.

Collateral values and related trends in Greece are monitored and updated based on independent appraisals, an independent published Greek real property index and official reports prepared by the Bank of Greece.

For the mortgage portfolio, only in very rare cases we expect to recover the outstanding balance through foreclosure given the low LTV ratio (average LTV of portfolio at 64% as at December 31, 2011), which deters customers from missing payments that could result in legal actions against them. This acts as a persuasive factor for the customer in finding resources to meet repayment schedules. As a result, for the purposes of estimating the allowance for loan losses for mortgage loans, the Bank considers the LTV ratios in determining whether foreclosure is probable.

According to the Bank's Credit Policy, the existence and value of collateral is closely monitored. The frequency and the objective of the appraisals are determined by the approval responsible parties and do not usually exceed an interval of two years.

Similar practices are followed by our subsidiary in Turkey, while our SEE subsidiaries, in general, perform appraisals more frequently.

According to the Group impairment methodology, corporate business units that are responsible for the impairment assessment have to ensure that in cases where cash flows are expected from collateral liquidation, collateral value has to be based on a recent (within the current year) independent appraisal from a qualified appraiser, unless loan exposures are significantly lower than the collateral values.

Finansbank follows credit procedures similar to those used by the Bank, from approval to remedial management, follow-up and implementation. The Credit Department approves loans within the framework of its policy and ensures the collectability of the loan through receipt of proper security.

Finansbank's Board of Directors has the right to grant loans within the limits set by Turkish Banking Law and may assign its credit-granting authority to the Credit Committee and Finansbank head office up to 10% and 1% of capital, respectively. Finansbank's head office may delegate this credit-granting authority in its units, regional offices and branches. Finansbank's head office and regions are currently empowered to approve exposures up to TL 50 million.

Loans between TL 50 million and TL 300 million are approved by the Credit Committee, which consists of the General Manager and three members of the Finansbank Board of Directors. Extensions of credit in excess of TL 300 million are approved by the Board of Directors.

UBB has created Risk Rating Systems in order to improve the ability to measure, manage and approve credit risk and also to use the Internal Rating Approach for the calculation of capital requirements against credit risk. According to the Group's Credit Policy, all obligors of the Corporate Banking Portfolio are rated on a 22-grade scale using calibrated and validated rating systems with each grade corresponding to a probability of default. The rating, as well as the credit proposal, are based on both quantitative and qualitative data that is validated and reviewed by the responsible approval parties based on the following authorization levels that depend on the size of the aggregate exposure of the borrower:

In alignment with Group Policy, Banca Romaneasca has established customer rates based on a Risk Rating System that is related to the probability of default on the part of the obligor and exclusively reflects the obligor's creditworthiness.

The credit approval system for lending depends on the total aggregate exposure of a client or a group of related/connected clients. Proposals for the establishment of a new or the increase or renewal of an approved credit facilities framework are prepared by Business Divisions and submitted for approval to the responsible Credit Approving Body. Credit approving bodies are as follows:

Any transaction which leads to an exposure on obligor, which is equal or exceeds 10% of the bank's own funds, is carried out only with the prior approval of Banca Romaneasca's Executive Committee.

Unsecured retail credit facilities are approved based on the gross exposure on a group of connected clients (only individuals) for this type of facilities, including the facility under assessment. The authority levels are: up to EUR 10,000, approval authority is given to the Retail Credit Center; between EUR 10,000 and EUR 20,000 approval is given by the Head of Retail Products and Segments Division and the Retail Credit Risk Manager; above EUR 20,001, approval is given by the Risk Executive Director and the Retail Executive Director.

Consumer loans secured with mortgage on a real estate and mortgage loans are approved based on the gross exposure to a group of connected clients for this type of facilities, including the facility under assessment. The authority levels are as follows: up to EUR 60,000, approval authority is given to the Retail Credit Center; between EUR 60,001 and up to EUR 150,000, approval is given by the Head of Retail Products and Segments Division and the Retail Credit Risk Manager; between EUR 150,001 and up to EUR 200,000, the approval is at the level of the Risk Executive Director and Retail Executive Director; the exposures between EUR 200,001 and up to EUR 7 million are approved by the Head Office Credit Committee; the exposures exceeding EUR 7 million up to the legal lending limit are approved by the Executive Committee.

Stopanska Banka has adopted a five-tiered credit approval system for lending to companies, depending on the size of the loan. The Small Banking Business Committee approves loans for which the cumulative exposure of Stopanska Banka to a single client does not exceed EUR 100,000. The Commercial Clients Credit Committee approves loans for which the cumulative exposure of Stopanska Banka to a single client is between EUR 100,000 and EUR 500,000. The Credit Committee approves loans for which the cumulative exposure of Stopanska Banka to a single client is between EUR 500,000 and EUR 3 million. The Executive Corporate Credit Committee must approve any credit exposure to a single subject in the amount between EUR 3 million and EUR 10 million. All financing that exceeds 10% of the Regulatory Capital of Stopanska Banka is approved by Stopanska Banka's Supervisory Board.

Vojvodjanska follows a five tiered credit approval system for the extension of corporate credit. All credit approvals, as well as any other decisions that involve credit risk require the approval of the appropriate level credit committee. In each credit committee an authorized person from Credit Risk Management Division participates with veto right.

Vojvodjanska's Executive Board approves credit exposures up to EUR 1 million. For credit exposures up to EUR 10 million, credit approvals can be granted only with the approval of the Head of Group International Credit Division. Credit Policy Manual revision is pending approval by Group International Credit Division. It provides for an increase of the local credit limit to EUR 3 million.

The Board of Directors approves credit exposures beyond the limits of the credit approval bodies mentioned above and up to the maximum amount per group permitted by the regulations in the Republic of Serbia, provided that the Group International Corporate Credit Committee has previously approved any proposed exposure in the range of EUR 10 million to EUR 200 million or NBG Senior Credit Committee for exposures exceeding EUR 200 million. The Board of Directors also has the authority to approve exposures to political parties, legal entities affiliated to Vojvodjanska, media and gambling business.

NBG Cyprus enforced its risk management policies and processes. Credit proposals up to EUR 6 million on individual or group basis (for large corporates, SMEs and Retail customers), are presented for approval to Credit Committees (members are the bank management officers). Credit proposals exceeding EUR 6 million require the approval of the members of the three-level Executive Credit Committees, in which two or three NBG Group executives are included (with one of them in the chair).

The loan approval process at SABA is centralized in the Credit Risk Department located at SABA's head office. Credit managers are mandated at different levels, with higher level facilities being considered by a Local Credit Committee. Facility requests that exceed the country mandate are considered by a Senior Credit Committee on the basis of a recommendation from the Local Credit Committee.

The Group has implemented a systematic control and monitoring of credit risk whereby the Bank and each of its subsidiaries conduct the credit risk process separately. The Group Risk Management Division ("GRMD") coordinates each of the credit risk procedures established by Group subsidiaries. For further information concerning the Group Risk Management Division, see Item 5.B, "Liquidity and Capital Resources—Asset/Liability, Internal Audit and Risk Management—Group Risk Management".

The Credit Policy determines the contents of credit proposals for the Corporate Banking Portfolio, which are conducted at least annually depending on the classification of the obligor and at the decision of the Credit Committee. Each credit proposal includes, among other items, the purpose and amounts of the facilities proposed, their main terms and conditions, key risks and mitigants, the risk rating and classification status of the obligor and business, financial and industry reviews and analyses.

According to the Credit Policy, all obligors of the Corporate Banking Portfolio are rated on a 22-grade scale using calibrated and validated rating systems with each grade corresponding to a probability of default.

The Bank uses a number of obligor rating models, assigning a borrower rating to each Corporate Banking Portfolio customer. This rating is based on quantitative and qualitative criteria. Additionally, the Bank's and its subsidiaries' rating systems considers the borrower's industry risk and relative position within its peer group. As the Group gradually complies with Basel II Internal Ratings Based methods, corporate borrower ratings are mapped to probabilities of default in order to estimate specific expected loss per obligor.

The Bank manages its corporate credit granting function, controls credit exposures and ensures regulatory compliance with a set of obligor, industry and large exposure limits. The assignment of obligor limits is directly related to the obligor risk rating.

The Bank has established and implemented an obligor classification system in order to facilitate early recognition of problems in various credit relationships and proactively take remedial action. Business Units, Head of Credit Division and relevant Credit Approving Bodies are responsible for the classification process. There are five classification categories: current, watch list, sub-standard, doubtful and loss. The obligor classification also determines the frequency of the credit reviews and the level of credit approval authority.

The Work-out Division is responsible for monitoring and collecting past due amounts for corporate portfolios, ensuring proactive remedial management and reducing costs.

The Bank has completed its estimation of key credit risk measurement variables, including probability of default, loss given default and exposure at default for all retail portfolios. Simultaneously, new credit risk management and rating systems for consumer credit and SMEs were completed and expected loss is estimated internally for these portfolios.

The Retail Banking Collection Division holds the responsibility of monitoring and collecting past due amounts for all retail portfolios and focuses on reducing delinquency rates, facilitating early awareness of defaulted loans, ensuring proactive remedial management and reducing costs to maximize overall profitability.

While the underwriting units are responsible for day to day management of the credit risk, Credit Policy Committees control the whole lending process by approving the lending criteria, credit risk policies and delegating authorities depending on the type of the product. The responsibility of the credit risk management unit is the establishment of effective and efficient internal policy, procedure and methodologies for definition, quantification, measurement, control and reporting of the credit risks.

Finansbank has established a sound internal rating system supported with adequate number of rating and scoring models to ensure its robustness across all lending types. Risk Management unit is responsible for building a regular cycle of rating models validation that includes monitoring of model performance and stability; and model improvement where necessary.

Under the consideration that inadequate diversification may have a significant impact on the value of the credit portfolio, Finansbank has established maximum concentration limits for single-name and

industries. In addition to exposure limits per obligor, product base limits are also in place. Counterparty credit risk exposure limits cover the potential future exposure calculations which may result due to market fluctuations.

Finansbank actively uses collateral management as the major risk mitigation mechanism. Sufficient legal review confirming the enforceability of the collateral arrangements under the applicable law and strong operational requirements are pre-requisites of the consideration of the risk mitigation effect. The market value of the collateral is appraised at least annually or more often whenever there is a reason to believe that a significant decrease in its market value has occurred.

Credit risk surveillance is a cradle to grave process in Finansbank i.e. credit risk of the obligors is continuously monitored as long as there exists a credit line. Quality, actuality and sufficiency of information flow are under the responsibility of underwriting department. The financial standing and the business risk profile of a customer are being continuously monitored, the corporate ratings are updated and the customer limits are reviewed at least annually. Early warning systems ensure that customers for which a significant deterioration in the credit quality or payment performance observed are transferred to watch list and closely monitored. Similarly, restructured and rescheduled loans are monitored with special care in line with the Credit Risk Policy.

The performance of outstanding business loans and exposures to large corporations is reviewed on a continuous basis by the Corporate Division and the Credit department of the Risk Management Division, in accordance with the provisions of UBB's Corporate Credit Policy.

UBB has established a Workout function (independent from the Corporate Banking Division) to ensure a timely monitoring and more appropriate management of the delinquent cases and to deploy the necessary actions to optimize the recovery of the relevant claims.

UBB strictly complies with the requirements of the Bulgarian National Bank regarding the classification of its borrowers into categories 1, 2, 3 and 4, based on the criteria set by the Bulgarian National Bank. In parallel and in accordance with the Group policy and practice, UBB has:

The Risk Management submits a detailed quarterly report for the Risk Management Committee of the Board of Directors and at least once a year, UBB Executive Management presents a full report on the quality of the UBB loan portfolio to the UBB Board of Directors.

Banca Romaneasca strictly complies with the requirements of the National Bank of Romania regarding the classification of its borrowers to the categories A, B, C, D and E as per the existing regulation in place through a specific procedure approved and validated by National Bank of Romania.

In parallel and in accordance with the NBG Group policy and practice, the Banca Romaneasca introduced a second internal classification system of the corporate portfolio's obligors, in order to enhance the timely identification and handling of problems relating to obligors and credit facilities.

Furthermore, Banca Romaneasca established a Workout Sector, with a main goal to suggest a series of measures (including but not limited to rescheduling, adjusting the capital repayments as per the cash flow, gradual exiting part of the leverage, change of currency in the original indebtedness) to be taken in order to limit the risk of registering late payments or to ensure the timely collection of the late payments.

In accordance with the Group policy and practice, Stopanska Banka has an internal classification system of its Corporate Portfolio's Obligors, in order to enhance the timely identification and handling of problems relating to obligors and credit facilities. The obligor's classification system applies a five-point risk rating system (GA, GB, GC, GD and GE). Only obligors incorporated in categories GB, GC, GD and GE described below are considered to be classified obligors. In the event that the obligor is classified, the Business Divisions have to:

Loans, other placements, guarantees and other off-balance sheet exposures are classified into five categories in accordance with the requirements of the regulations adopted by the National Bank of Serbia. Loans are classified based on an evaluation of their collectability, the number of days in arrears, the general financial background of the counterparty and the quality of the collateral. In accordance with the revised credit review framework, implemented in 2009, the Risk Management Division prepares and distributes quarterly reports based on which obligors are classified. Interim reviews and presentations of key portfolio quality data are conducted according to the regular audit schedule. Regular reporting on the credit quality related issues takes place at sessions of the Executive Board, the Board of Directors (this is a statutory requirement) and the Audit Committee.

NBG Cyprus has adopted the Bank's risk rating system. The duties and responsibilities of the Financial Assets Impairment Provision and Write-off Committee were updated and enriched. The Committee presents a relative report annually to the newly established Risk Management Committee of the bank's Board of Directors.

SABA focuses on working capital facilities and asset-based finance for SMEs with annual turnovers in the range of ZAR 5 million to ZAR 50 million. Facilities are reviewed on an annual basis in light of the most recent financial statements for clients.

In general, for domestic loans the accrual of interest is discontinued at the time the loan is 90 days delinquent unless the credit is well secured and in process of collection. Residential real estate loans are placed on non-accrual status at the time the loan is 180 days delinquent. In addition, all loans modified under TDR are placed in non-accrual status at the time of their restructuring. In all cases, loans are placed on non-accrual status, or written-off at an earlier date, if collection of principal or interest is considered doubtful. The Group's non-accruing loans amounted to EUR 11,466.9 million on December 31, 2011. This corresponds to 15.1% of the Group's loans outstanding at the same date. Of the Group's non-accruing loans, EUR 8,625.0 million or 75.2% were held by the Bank. This amount represented 15.4% of the Bank's loan portfolio.

When an account is classified as non-accruing, the Bank immediately initiates all required actions (both business and legal) to recover or settle the outstanding balance. The Bank has dedicated departments responsible for the collection of non-accruing loans in coordination with Corporate and Retail Banking, the central non-performing loan divisions.

The Bank's non-accruing loans, including those that have been restructured, are monitored by the credit staff at the Bank's specialized divisions, certain regional branches and specialized branches which handle only non-accruing loans. The prospects of recovery and the estimated losses are frequently reviewed. See Item 4.E, "Selected Statistical Data—Credit Quality—Risk Management—Credit Review Policies".

For Turkish and International entities, the accrual of interest is typically discontinued at the time the loan is 90 days delinquent. In addition, all loans modified under TDR are placed in non-accrual status at the time of their restructuring. In all cases, loans are placed on non-accrual, or written-off at an earlier date, if collection of principal or interest is considered doubtful. When overdue amounts are fully repaid, companies renew their balance sheet accruals. Remedial management procedures are employed for loans falling under the non-accruing loan category. Under these remedial procedures, the first action is to try to receive the amount from the customers by using alternative solutions. The second action is to recover the amounts due and to enforce or execute the collaterals through court orders. See Item 4.E, "Selected Statistical Data—Credit Quality—Risk Management—Credit Review Policies".

International entities have their own non-performing loan division in charge of collecting non-accruing loans. The practice of outsourcing the collection of some consumer loans is also followed in some cases.

When a company is assessed to have only temporary financial problems but has the potential to successfully operate in the near future, it reschedules or restructures its non-accruing loans in accordance with the Banking Regulation and Supervision Agency regulation on the procedures and principles determining the qualifications of loans and other receivables by banks and the provisions to be taken. A restructuring depends on the assessment of the potential of the client for the regular payment of loans in the future and the existing or additional collateral that the client is ready to offer. Rescheduled loans remain classified in the same risk category for a period of approximately six months after rescheduling. After that period the rescheduled loans can be gradually upgraded to a higher category only if the client consistently meets its obligations.

The table below shows (i) all loans that are non-accruing, and (ii) all accruing loans which are contractually past due 90 days or more as to principal or interest payments for each of the five years ended December 31, 2007, 2008, 2009, 2010 and 2011:

	Year ended December 31,

	2007		2008		2009		2010		2011
	(EUR in thousands)
Domestic loans:
Accruing loans:
Past due 90 days—180 days		266,625		391,230		642,690		680,125		667,827
Past due 180 days—365 days		177,867		46,106		47,795		51,161		102,078

Total accruing loans		444,492		437,336		690,485		731,286		769,905

Non-accruing loans:
Past due 0 days—90 days		—		—		—		—		1,806,703
Past due 90 days—180 days		73,736		222,735		262,033		392,919		880,768
Past due 180 days—365 days		318,441		512,216		903,492		1,052,394		1,455,057
Past due 365 days or more		774,384		895,889		1,706,024		2,902,992		4,581,241

Total non-accruing loans		1,166,561		1,630,840		2,871,549		4,348,305		8,723,769

Foreign loans:
Accruing loans:
Past due 90 days—180 days		—		—		48,781		204,879		66,512
Past due 180 days—365 days		—		—		13,925		63,997		90,569

Total accruing loans		—		—		62,706		268,876		157,081

Non-accruing loans:
Past due 0 days—90 days										487,170
Past due 90 days—180 days		151,811		267,960		440,131		444,415		227,046
Past due 180 days—365 days		114,874		155,475		268,696		364,259		401,680
Past due 365 days or more		213,845		257,587		586,106		1,268,307		1,627,275

Total non-accruing loans		480,530		681,022		1,294,933		2,076,981		2,743,171

Since 2010, the Group, and mainly the Bank, implemented various loan modification programs that aim to reduce customers' monthly installments to a more viable level. Restructuring efforts have been continued throughout 2011, and several new products are proposed to customers (see Item 4.B, "Business Overview—Banking Activities in Greece").

Modifications are considered TDRs if, for economic or legal reasons related to the debtor's financial difficulties, the Group has agreed to make certain concessions to customers to both meet the needs of the customers and to maximize the ultimate recovery of a loan. TDRs occur when a borrower is experiencing, or is expected to experience, financial difficulties and the loan is modified using a modification that would otherwise not be granted to the borrower. The concession granted typically involves the reduction of interest accrued off-balance sheet or the prolongation of maturity. TDRs are considered impaired.

Allowance for loan losses are established to recognize losses inherent in funded loans intended to be held-for-investment that are probable and can be reasonable estimated. Prior to a TDR modification, the Group generally measures its allowance under a loss contingency methodology whereby consumer loans with similar risk characteristics are pooled and loss experience information are monitored for credit risk and deterioration with statistical tools considering factors such as delinquency,

LTV, and credit scores. Upon TDR modification, the Group generally measures impairment based on a present value of expected future cash flows methodology considering all available evidence. The amount of the required valuation allowance is equal to the difference between the loan's impaired value discounted at the loan's original effective interest rate and the recorded investment.

Typically, commercial loans whose terms are modified in a TDR will have previously been identified as impaired prior to modification and accounted for generally using a present value of expected future cash flows methodology unless the loan is considered collateral dependent. Loans considered collateral dependent are measured for impairment based on their fair values of collateral less its estimated cost to sell. Accordingly, upon TDR modification, the allowance methodology remains unchanged.

The tables below present the amounts of modified loans and TDRs granted during the last 12 months, analyzed between non-accruing, accruing and less than 90 dpd and accruing and more than 90 dpd by class of loans, as at December 31, 2010. As at December 31, 2011, TDRs are, analyzed between non-accruing with delays over 90 days and less than 90 days:

Modified and TDRs loans are separately monitored by dedicated teams. Special reports are produced for modified loans and in case of non-payment, they are subject to more intensive collection actions. As at December 31, 2011, the percentage of TDRs loans granted during the last 12 months that became past due (+30 dpd) was 41.2% for consumer loan portfolio and 41.3% for commercial loan portfolio, and 33.1% and 40.9%, respectively for modified loans.

As the Group implemented loan modification programs in 2010, none of the loans that were modified in 2010 was subsequently modified again in 2010. New modification programs for previously modified loans were first launched during the third quarter of 2011. As of 2011, the percentage of modified loans which were subsequently modified again was 7.2%.

The Group has defined as PPLs, the loans that although are not yet in a non-accrual status, past due over 90 days or TDR status at the reporting date, but where known information about possible credit problems of borrowers, causes management to have serious doubts as to the ability of such borrowers to comply with the present loan repayment terms and which may result in disclosure of such loans as Non-accruing, Past Due over 90 days or TDR in the future. Management defines as known information about possible credit problems with loans the following:

The table below presents PPLs for the Group by loan category for the years ended December 31, 2010 and 2011.

We maintain an allowance for loan losses sufficient to absorb probable incurred losses in the loan portfolio. The NBG Group has a comprehensive financial assets impairment provision and write-off policy which applies to all subsidiaries and establishes guidelines for the assessment process. In addition, impairment provision and write-off committees have been established at each banking subsidiary, which approve the amount of loan loss allowances on an individual basis for customers' exposures individually assessed and on a collective basis for portfolios collectively assessed. Members of these committees include members of the Group's senior management.

The allowance for loan losses incorporates the measurement methods, income recognition and disclosures as provided for in the following accounting pronouncements:

Specifically, our methodology has three primary components: specific allowances, coefficient analysis and homogeneous analysis, described in Note 3 "Summary of Significant Accounting Policies" and Note 13 "Loans and allowance for loan losses" to the U.S. GAAP Financial Statements.

Allowances for losses inherent in loans made through our branches and subsidiaries outside of Greece are estimated by the branch or subsidiary which originated the loan. Methodologies applied are similar to those employed by the Group for loans in Greece.

As a result of the improvement of our methodology for calculating loan loss allowances by increasingly incorporating recent loan experience as well as geographical and industry segment concentrations, since 2008, unallocated provisions are included in the coefficient and homogenous components.

The allowance for credit losses is based upon estimates of probable incurred losses in the loan portfolio. The amount actually observed for these losses can vary significantly from the estimated amounts, but we expect that the consistent application of our methodology described above will reduce such variances. To ensure this is the case, we evaluate our loans and the methodologies applied thereto, including loss estimation percentages, on a regular basis based on management's judgment of the changing dynamics within the portfolio. See Item 4.E, "Selected Statistical Data—Credit Quality and Risk Management—Risk Management—Credit Review Policies".

When the Group determines the amount of allowance for loan losses for our pool of homogeneous loans, loss rates are applied that have been produced by our risk models, which collect historical evidence of recoveries spanning across many years. Our analysis of past data has demonstrated that we collect insignificant amounts from the unsecured portion of our portfolio after a period of four years after the loan agreement is legally terminated. Therefore, for this portion of past due loans a 100% loss allowance is recorded, which represents a full reserve. A write-off may not be made since legal actions may still be pending.

For loans individually assessed and for which a specific allowance for loans losses is estimated, the loss rate is 100% if we do not expect to receive any cash flows from the obligor or foreclosure of collateral (if any).

The following table sets forth the loan loss allowances by methodology for the last five years to which the methodology was applied to respective loan balances:

For a further analysis of loan loss allowances see Item 5.A, "Operating Results—Results of Operations for the year ended December 31, 2011 compared with the year ended December 31, 2010 (as restated)" and Item 5.A, "Operating Results—Results of Operations for the year ended December 31, 2010 compared with the year ended December 31, 2009 (both as restated)."

The following table illustrates the activity in the loan loss allowance balance over the previous five years:

	Year ended December 31,

	2007			2008			2009			2010			2011
	(EUR in thousands)
Domestic:
Balance at beginning of year		906,318			779,608			838,169			1,325,085			2,122,803
Add: Allowances for probable loan losses from continuing operations		119,379			249,033			591,637			878,145			3,378,788
Write-offs		(259,200	)		(205,716	)		(110,272	)		(85,050	)		(77,073	)
Recoveries		13,120			15,230			5,639			4,597			8,122

Less: Net write-offs		(246,080	)		(190,486	)		(104,633	)		(80,453	)		(68,951	)
Translation differences		(9	)		14			(88	)		26			1,188

Domestic balance at end of year		779,608			838,169			1,325,085			2,122,803			5,433,828

Foreign:
Balance at beginning of year		318,439			353,344			394,457			740,093			1,052,602
Add: Allowance (upon acquisition) attributable to companies acquired during the year		6,582			—			—			—			—
Add: Allowances for probable loan losses from continuing operations		71,376			176,504			406,811			326,850			324,481
Write-offs		(82,372	)		(116,524	)		(86,040	)		(55,321	)		(92,439	)
Recoveries		32,903			27,203			24,024			18,652			23,078

Less: Net write-offs		(49,469	)		(89,321	)		(62,016	)		(36,669	)		(69,361	)
Sale of impaired loans		—			—			—			—			(107,244	)
Translation differences		6,416			(46,070	)		841			22,328			(83,671	)

Foreign balance at end of year		353,344			394,457			740,093			1,052,602			1,116,807

Total balance at end of year		1,132,952			1,232,626			2,065,178			3,175,405			6,550,635

Key ratios related to the activity in our loan loss allowance for the previous five years to which our loan loss methodology was applied are as follows:

The table below shows allowances for loan losses for the Group by loan category for each of the years ended December 31, 2007, 2008, 2009, 2010 and 2011.

	2007				2008				2009				2010				2011

	Amount		%⁽¹⁾		Amount		%⁽¹⁾		Amount		%⁽¹⁾		Amount		%⁽¹⁾		Amount		%⁽¹⁾
	(EUR in thousands, except percentages)
Greek residents:
Consumer
Residential mortgages		118,190		28.1		105,208		25.1		123,614		25.5		228,606		24.7		528,869		24.6
Credit card		77,582		2.8		79,086		2.4		200,592		2.5		335,642		2.2		415,536		2.0
Auto financing		—		0.3		—		0.4		—		0.6		—		0.5		—		0.4
Other consumer		96,090		7.0		156,626		6.5		281,140		6.4		593,175		6.1		1,010,516		6.2

Total		291,862		38.2		340,920		34.4		605,346		35.0		1,157,423		33.5		1,954,921		33.2

Commercial
Industry and mining		145,146		5.7		167,180		4.8		210,270		4.6		262,816		4.7		514,678		5.5
Small-scale industry		47,565		2.4		61,319		2.6		89,377		2.7		99,147		2.6		177,187		2.6
Trade		148,748		9.1		169,855		10.3		263,083		10.9		378,143		9.8		654,162		9.7
Construction		46,135		1.3		51,155		1.7		72,621		1.6		134,812		1.6		153,183		1.6
Tourism		11,111		0.3		11,824		0.4		21,715		0.6		23,692		0.6		38,540		0.6
Shipping and transportation		18,372		2.2		11,683		2.7		32,117		2.5		45,544		2.7		55,355		2.9
Commercial mortgages		—		1.2		—		1.2		6,114		1.2		8,424		1.1		14,795		1.0
Public sector		—		3.3		—		11.4		6		11.2		113		11.2		1,855,266		11.4
Other		63,496		3.4		24,233		0.9		24,436		0.6		12,689		0.3		15,741		0.1

Total		480,573		28.9		497,249		36.0		719,739		35.9		965,380		34.6		3,478,907		35.4

Total Greek residents loans		772,435		67.1		838,169		70.4		1,325,085		71.0		2,122,803		68.1		5,433,828		68.6

Foreign:
Consumer
Residential mortgages		5,222		5.1		6,742		4.9		23,235		5.1		51,249		5.9		55,664		5.3
Credit card		41,405		3.0		62,017		2.6		149,099		3.2		216,040		4.4		246,477		4.9
Auto financing		9,039		0.6		4,225		0.5		3,809		0.3		205		0.3		272		0.2
Other consumer		77,980		3.5		106,490		3.4		222,658		3.5		252,423		3.9		303,694		3.9

Total		133,646		12.2		179,474		11.4		398,801		12.1		519,917		14.5		606,107		14.3

Commercial
Industry and mining		51,911		2.3		93,946		3.2		107,136		3.5		143,793		3.7		130,162		4.1
Small-scale industry		4,744		2.7		8,593		2.5		33,094		2.2		40,252		1.8		44,034		1.7
Trade		72,269		2.6		65,507		3.2		116,134		4.5		178,522		4.8		165,407		4.7
Construction		14,217		2.6		14,710		2.5		26,504		1.9		53,938		2.0		70,392		2.1
Tourism		5,735		0.7		5,611		0.6		6,509		0.4		13,373		0.5		13,857		0.4
Shipping and transportation		2,707		0.8		4,565		0.8		7,580		0.9		15,174		1.0		17,255		1.0
Commercial mortgages		417		0.2		436		1.8		370		0.8		3,916		0.9		7,145		0.8
Public sector		34		—		30		0.2		31		0.5		40		0.5		32		0.4
Other		67,664		8.8		21,585		3.4		43,934		2.2		83,677		2.2		62,416		1.9

Total		219,698		20.7		214,983		18.2		341,292		17.0		532,685		17.4		510,700		17.1

Total foreign loans		353,344		32.9		394,457		29.6		740,093		29.0		1,052,602		31.9		1,116,807		31.4

Unallocated		7,173		—		—		—		—		—

Total Allowance for loan losses		1,132,952		100.0		1,232,626		100.0		2,065,178		100.0		3,175,405		100.0		6,550,635		100.0

An analysis of the Group's write-offs and recoveries for non-accruing loans for the years ended 2007, 2008, 2009, 2010 and 2011 is presented in the following table:

	Year ended December 31,

	2007			% of total loans		2008			% of total loans		2009			% of total loans		2010			% of total loans		2011			% of total loans
	(EUR in thousands, except percentages)
Write-offs
Greek Residents:
Commercial and industrial		77,345			0.14		69,162			0.10		48,733			0.07		60,144			0.07		31,125			0.04
Real estate—construction		5,032			0.01		6,118			0.01		6,959			0.01		4,096			0.01		10,443			0.02
Real estate—mortgage		9,304			0.02		11,441			0.02		2,898			—		4,137			0.01		6,177			0.01
Other loans to individuals		167,519			0.31		118,995			0.17		51,682			0.07		16,673			0.02		29,328			0.04

Total write-offs for loans to Greek residents		259,200			0.48		205,716			0.30		110,272			0.15		85,050			0.11		77,073			0.11

Foreign:
Commercial and industrial		27,926			0.05		56,543			0.08		35,174			0.05		15,072			0.02		41,589			0.06
Real estate—construction		804			—		1,029			—		6,349			0.01		7,316			0.01		902			—
Real estate—mortgage		669			—		32			—		85			—		414			—		3,757			0.01
Other loans to individuals		52,973			0.10		58,920			0.09		44,432			0.06		32,519			0.04		46,191			0.07

Total write-offs for foreign loans		82,372			0.15		116,524			0.17		86,040			0.12		55,321			0.07		92,439			0.14

Total write-offs		341,572			0.63		322,240			0.47		196,312			0.27		140,371			0.18		169,512			0.25

Recoveries
Greek Residents:
Commercial and industrial		—			—		(340	)		—		—			—		—			—		—			—
Other loans to individuals		(13,120	)		0.02		(14,890	)		0.02		(5,639	)		0.01		(4,597	)		0.01		(8,122	)		0.01

Total recovery on loans to Greek residents		(13,120	)		0.02		(15,230	)		0.02		(5,639	)		0.01		(4,597	)		0.01		(8,122	)		0.01

Foreign:
Commercial and industrial		(3,953	)		0.01		(9,099	)		0.01		(6,254	)		0.01		(12,171	)		0.01		(7,735	)		0.01
Real estate—mortgage		(323	)		—		(126	)		—		(119	)		—		(138	)		—					—
Other loans to individuals		(28,627	)		0.05		(17,978	)		0.03		(17,651	)		0.02		(6,343	)		0.01		(15,343	)		0.02

Total recovery on foreign loans		(32,903	)		0.06		(27,203	)		0.04		(24,024	)		0.03		(18,652	)		0.02		(23,078	)		0.03

Total recoveries		(46,023	)		0.08		(42,433	)		0.06		(29,663	)		0.04		(23,249	)		0.03		(31,200	)		0.04

Since 2008 in line with our commitment to social awareness and our responsibility for alleviating the impact of the economic crisis to our customers, as well as due to the expectations of the introduction of legislative actions, like Greek laws 3869/2010 and 3949/2011, for the protection of those facing difficulties in repaying on time their loans we have postponed legal actions taken against past due customers and modified our write-off policy. This policy change has extended the maximum period from up to three to up to five years before taking write-offs in our unsecured portfolio. In addition we have introduced modification programs for loans more than 90 dpd in order to assist our customers in servicing their debt. These practices have significantly reduced the amount of unsecured loans that are written off since legal actions have not been completed and estimated recoveries are difficult to be assessed. As at December, 31 2011, write-offs amount to EUR 77.1 million and were still influenced by the change in the write-off policy in relation to unsecured portfolios. Domestic write-offs mainly consisted of corporate and small business loans individually assessed which were, either partially written-off, keeping only the secured balance on balance sheet, or written-off completely.

As at December 31, 2010 and 2011, unsecured consumer and credit card exposures whose agreement has been terminated more than 3 years and SBL exposures that are fully provided for but not written off amounted to EUR 67.4 million and EUR 276.2 million, respectively. The write-off of those loans would result in a reduction of the allowance for loan losses on the balance sheet by

EUR 53.7 million in 2010, and EUR 241.5 in 2011, cumulatively. Had we written-off those loans in accordance with our previous policy, the non-accruing loans ratio as at December 31, 2010 and 2011 would have been 8.1% (no change) and 14.8% instead of 15.1%, respectively. Furthermore, the non-accruing loans coverage ratio as at December 31, 2010 and 2011 would have been 49.1% instead of 49.4% and 56.4% instead of 57.1%, respectively.

Although Turkey and the countries in South Eastern Europe in which we operate do not face the unprecedented crisis that Greece is currently facing and the enforcement of collateral or exhaustion of legal actions take significantly less time than in Greece, non-accruing loans increased and write-offs decreased during 2009 and 2010 due to changes in prevailing best practices especially in Turkey due to uncertainties over the tax treatment of write-offs made when all legal actions have not been exhausted. In 2011, foreign write-offs increased to EUR 92.5 million mainly due to the increase of commercial loans write-offs.

The following table shows details of the Group's average deposits and average interest rates thereon, for the Group's continuing domestic and foreign operations, in each of the three years ended December 31, 2009, 2010 and 2011:

	Year ended December 31,

	2009				2010				2011
	Average Balance		Average rate (%)		Average balance		Average rate (%)		Average balance		Average rate (%)
	(EUR in thousands, except percentages)
Domestic Operations:
Deposits by Greek residents:
Demand deposits		4,538,627		0.54		4,515,645		0.36		3,847,375		0.60
Savings		22,955,846		0.36		23,438,310		0.24		20,284,201		0.25
Time deposits		27,272,223		3.18		23,885,460		2.23		20,524,647		2.91
Interbank		10,203,087		1.31		20,006,719		1.06		24,446,379		1.54
Other		459,032		1.24		430,861		3.71		494,288		3.19
Non-Greek residents or foreigners:
Demand deposits		140,354		0.49		124,367		0.32		213,441		0.48
Savings		22,768		0.36		22,914		0.24		20,010		0.26
Time deposits		641		3.12		592		2.20		35,096		2.89
Interbank		457,347		3.15		563,059		0.99		779,397		0.51
Deposits in foreign banking offices:
Banks located in foreign countries		7,437,293		1.45		4,488,081		1.13		3,912,996		2.09
Other foreign demand deposits		1,506,591		0.60		1,020,140		0.79		1,031,563		1.19
Other foreign time and savings deposits		12,885,356		6.90		14,765,777		6.25		16,468,108		6.69

Total deposits		87,879,165		2.43		93,261,925		1.95		92,057,501		2.46

The table below shows the amount outstanding of customer time certificates of deposit and other time deposits (including interbank deposits) in amounts of US$100,000 or more of the Group's operations by remaining maturity at December 31, 2011. Determination of whether certain time deposits in currencies other than the U.S. dollar are in amounts of US$100,000 or more has been based on exchange rates at December 31, 2011.

	Year ended December 31, 2011

	(EUR in thousands)
Domestic Operations:⁽¹⁾
Other time deposits of US$100,000 or more by time remaining until maturity:
3 months or less		36,383,188
Over 3 through 6 months		1,797,735
Over 6 through 12 months		4,665,749
Over 12 months		812,376

Total time certificates of deposit and other deposits in amount of US$100,000 or more		43,659,048

Foreign Operations:
Time certificates of deposit in amounts US$100,000 or more:
3 months or less		117,468
Over 3 through 6 months		4,232
Over 6 through 12 months		911
Over 12 months		9,579
Other time deposits of US$100,000 or more by time remaining until maturity:
3 months or less		8,629,410
Over 3 through 6 months		677,675
Over 6 through 12 months		595,782
Over 12 months		314,554

Total time certificates of deposit and other deposits in amount of US$100,000 or more		10,349,611

The table below shows outstanding amounts of short-term borrowings of Group companies for each of the three years ended December 31, 2009, 2010 and 2011.

Of the year-end balance as at December 31, 2011, 99.9% relates to Finansbank borrowings (see Note 21 to the U.S. GAAP Financial Statements, for the major other borrowed funds issued in 2011).

There are no unresolved written comments from the SEC regarding periodic Exchange Act reports received not less than 180 days before the end of the fiscal year ended December 31, 2011.

The following review is based upon the selected financial data prepared in accordance with U.S. GAAP and should be read in conjunction with our U.S. GAAP Financial Statements and the notes explaining those financial statements included elsewhere in this Annual Report.

We are the largest financial institution in Greece by market capitalization, holding a significant position in Greece's retail banking sector, with more than 11 million deposit accounts, more than three million lending accounts, 539 branches and 1,398 ATMs as at December 31, 2011. We provide a wide range of financial services, including retail (such as mortgage lending and consumer lending), commercial and investment banking services and asset management and insurance, through our network of branches and subsidiaries in Greece and abroad. Our principal sources of income historically have been interest earned on customer loans and debt securities and income from fees and commissions. We fund our lending activities and our securities portfolio principally through customer deposits in our branch network and interbank funding primarily from the ECB. As at December 31, 2011, our loans-to-deposits ratio (adjusted loans and deposits excluding interbank deposits) was 109.8%.

We hold leading positions in many financial services products in Greece. As at December 31, 2011, we had the largest market share of deposits and mortgage loans in Greece, with 30.8% in core deposits and 25.1% in mortgage lending, respectively, according to our internal analysis of published information of the Bank of Greece and other Greek banks. We are also strongly positioned in consumer and credit card lending where, according to our internal analysis of published information by the Bank of Greece, we are first with a market share of 19.2% as at December 31, 2011. We are also second in mutual fund management with a market share of 17.4% at the same date according to the Hellenic Fund and Asset Management Association.

Outside Greece, the Group is active in eleven countries: Turkey, Bulgaria, Romania, Serbia, Albania, FYROM, Cyprus, South Africa, Egypt, Malta and the United Kingdom, represented by 1,194 branches that employ 59.3% of our total workforce. For the year ended December 31, 2011, International Operations' contribution to the Group's net income was EUR 54.2 million, while Turkey's contribution to the Group's net income was EUR 375.9 million.

The Greek economy has faced and continues to face unprecedented macroeconomic headwinds, originating from the still sizeable fiscal imbalances and compounded by other deep-rooted structural vulnerabilities making the achievement of the targets posed by the Program a challenge.

The completion of the PSI in April 2012 implies a significant decline of the Greek debt burden, as well as a sharp reduction in debt servicing needs through low interest rates on the new bonds and a substantial extension of the average debt maturity. The PSI achieves nominal debt relief on EUR 199 billion of eligible bonds, directly reducing Greece's debt burden by approximately 50% of GDP from a level of 165% of GDP at the end of 2011. Interest service costs are reduced as the effective average cost of Greek debt servicing is brought down to approximately 3.3% in the 2012-2014

period, from about 5% in 2011. Finally, amortization payments are minimal until 2020 due to the long grace periods on the PSI bonds and a large part of the official financing.

The sustainability of Greece's public finances and its membership in eurozone depend upon the implementation of ambitious structural and fiscal reforms and their effectiveness in laying the foundations for a sustained economic recovery.

The tensions relating to Greek public finance have affected the liquidity and profitability of the financial system in the Hellenic Republic and have resulted in:

In March 2012, the Greek government agreed to the Program, a second economic adjustment program, the term of which extends through 2015 and is jointly supported by the IMF and eurozone member states. This Program will replace the original program of EUR 110 billion, agreed in May 2010, for the period 2010-2013 and had the form of a cooperative package of IMF and eurozone member states funding. The international assistance loans disbursed under the original program amounted to EUR 73 billion. Of this amount, EUR 52.9 billion has been sourced from eurozone member states, and EUR 19.9 billion from the IMF. In the Program, for the years 2012-2015, eurozone member states through the EFSF and the IMF commit the undisbursed amounts from the first program, plus an additional EUR 130 billion, covering Greece's expected funding needs fully for the three-year period. During this period, the EFSF could provide an overall amount of EUR 144.7 billion, while the IMF will contribute EUR 28 billion during four years under its extended fund facility (EFF mechanism). The Program will be heavily front-loaded, especially regarding financing from eurozone member states—disbursements of about EUR 75 billion is expected to occur in the first half of 2012—to fund EUR 35.7 billion of PSI debt enhancements and accrued interest and EUR 25 billion to recapitalize Greek banks through the HFSF. The IMF contribution of EUR 28 billion will be disbursed in 17 equal tranches over a four-year period ending 2015.

The disbursements of financial assistance to Greece are conditional on quarterly reviews for the duration of the arrangement. The release of the tranches by the lenders will be based on observance of

quantitative performance criteria and a positive evaluation of progress made with respect to policy criteria set by the memorandum of economic and financial policies (MEFP) and the Memorandum underlying the Program and committed to by the Greek government. Moreover, in April 2012, the Greek parliament passed new legislation prioritizing government debt service obligations to private and official holders of Greek debt over any other fiscal use of Program funding, and the same is committed to occur with primary budget surpluses which are expected to be achieved from 2013 onwards.

The Program also sets forth a blueprint for the stabilization of public finances and the economy of Greece and safeguarding financial stability in Greece. Overall, the implementation of the growth-enhancing structural reforms gains prominence in the overall implementation of the Program, while the debt restructuring and higher official financing allows a more realistic pace of fiscal adjustment and a more gradual privatization process. Specifically, the strategy is primarily based on expenditure reduction so as to achieve a primary surplus of 1.8% of GDP in 2013, and 4.5% of GDP for the period 2014-2020 and the timely and decisive implementation of growth enhancing structural reforms. The Program also foresees more aggressive nominal wage adjustments and benefit cuts, to reduce costs and thus improve price competitiveness, and permit Greece's transition to a more investment and export-led growth model.

At the same time political risks linked to the result of the parliamentary elections of May 6, 2012 create uncertainty about policy implementation efficiency and step up structural reform effort (the Troika has already sought political assurances from large political parties to ensure continuity in policy implementation). Nonetheless, potential delays in the formation of a new government post-election, as well as a weak parliamentary majority of the parties supporting the Program over others that are opposed to IMF/EU support could pose significant risks to the implementation of the Program. Similarly, the eurozone member states' commitment to provide long-term support to Greece on adequate terms is subject to significant risks related not only with Greece's ability to avoid any additional slippages in the implementation of the Program but also to increasing discontent of public opinion in these countries regarding support to Greece.

The large losses experienced by private creditors from the PSI exchange in conjunction with the still high level of Greek sovereign debt post-PSI (above 120% until 2019) render an improvement of market sentiment and a significant upward revision of sovereign ratings of the country highly unlikely for the short-to-medium-term. In this respect, valuations of the Greek state assets (and thus privatization revenue budgeted in the Program) remain subject to substantial risks. A failure to successfully implement the Program may lead to termination of the financial support by the IMF and the EU, which would create the conditions for a new credit event with respect to Hellenic Republic debt or lead to a default by the Hellenic Republic on its debt which will include both marketable instruments and official EU loans.

Even if the Hellenic Republic successfully implements the Program, government debt as a percentage of GDP is projected in the Program to rise to approximately 160% of GDP in 2013 and it remains uncertain whether the Greek economy will grow sufficiently to ease the financing constraints of the Hellenic Republic. These concerns may result in a credit event with respect to the Hellenic Republic occurring earlier and prior to the completion of the Program.

A failure of the Program to result in a marked improvement in the Greek economy would have significant consequences on the Bank. After the completion of PSI, our holdings of Greek government bonds amount to EUR 4.8 billion, and we have additional exposure to Greek treasury bills of EUR 2.3 billion and other Greek government debt of EUR 8.8 billion. If another credit event with respect to the Greek government debt or an additional restructuring of Greek government debt were to occur, our regulatory capital would be severely affected due to our direct exposure to Hellenic Republic debt, requiring the Bank to raise additional capital and thus diluting existing shareholders significantly. Furthermore, there would be no assurance that the Bank could raise all of the required additional capital on acceptable terms.

Similar developments could be triggered by any further significant deterioration of global economic conditions, including the credit profile of other EU countries such as Ireland, Portugal or Spain or the creditworthiness of Greek or international banks . Any of these events may give rise to concerns regarding the ability of the Hellenic Republic to meet its funding needs. These developments could:

For the impairment of Greek government bonds and the related accounting treatment, see Item 4.B, "Business Overview—The macroeconomic environment in Greece—The Hellenic Republic's economic crisis, the successful sovereign debt restructuring (PSI) and the agreement on the Program for Greece" and Item 5 "Operating and Financial Review and Prospects—Critical Accounting Policies, Estimates and Judgments—Other-Than-Temporary-Impairment of Greek government bonds due to PSI", respectively.

The Program provides additional capital for the Greek banking sector and is, in addition to the Hellenic Republic Bank Support Plan, approved by the Greek Parliament in response to the difficult funding conditions in 2008 originally approved for EUR 28 billion in 2008 and augmented the support plan by EUR 40 billion in 2010 and another EUR 30 billion in 2011. For more information on the Hellenic Republic Bank Support Plan, see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic Bank Support Plan". The Hellenic Republic Bank Support Plan, as amended, comprises three tranches or pillars:

For the financings under the Hellenic Republic Bank Support Plan, see Item 5.B, "Liquidity and Capital Resources—Financing Under the Hellenic Republic Bank Support Plan".

Our performance has been and will continue to be influenced by the difficult economic conditions in Greece and in the countries in which we operate, particularly in SEE. The outlook for the global economy over the short to medium term remains challenging, with the consequent impact on prospects for stabilization and improvement of economic and financial conditions in Greece. In addition, the global financial system has yet to fully overcome the difficulties which first manifested themselves in August 2007, and were intensified by the bankruptcy filing of Lehman Brothers in September 2008. Financial markets conditions have remained challenging and in certain respects, have deteriorated. In addition, there is a contagion risk for banks in the EU stemming from the downgrades of European States, as experienced in Greece, and related market participants. To the extent this affects other EU economies and their banking systems, it could pose a common threat to EU banks generally. Moreover, contagion may extend to banks outside the EU, in particular to those economies on the periphery of the EU, such as Turkey and SEE. As a result of these turbulent conditions in the global financial markets, there is ongoing significant deterioration in the interbank and term funding markets as well as a material reduction in the availability of longer-term funding. Furthermore, these conditions have led to deterioration in the operating conditions for many of the Group's clients, adversely affecting demand for new lending as well as increasing stress on the asset quality of the Group's loan portfolio.

In response to this economic instability and illiquidity in the market, a number of governments, including the governments of Greece (as described above), the other EU member states and the United States have intervened in the global financial markets on an unprecedented scale during the periods covered by this discussion, including through the Program. Despite such measures, the volatility and disruption of the capital and credit markets have continued, with many forecasts predicting only modest GDP growth or, in some EU countries, such as Greece, GDP declined during 2011. These conditions have exerted, and may continue to exert, downward pressure on asset prices and on the availability and cost of credit for financial institutions, including the Group, and will continue to impact the credit quality of the Group's customers and counterparties. These conditions, alone or in combination with regulatory changes or actions of other market participants, may cause the Group to incur losses or to experience further reductions in business activity, increased funding costs and funding pressures, lower share prices, decreased asset values, additional write-downs and impairment charges and lower profitability.

Turkish operations through Finansbank, our Turkish subsidiary, represented 19.4% of our gross loans as at December 31, 2011 (compared to 18.9% as at December 31, 2010), accounted for 30.3% of our net interest income before provisions for loan losses and contributed EUR 375.9 million to our net income for the year ended December 31, 2011 (compared to 31.9% and EUR 454.5 million respectively for the year ended December 31, 2010). Concurrently with our announcement of the rights offering in September 2010, we announced that we are exploring opportunities to realize value for our shareholders from the growth of our business in Turkey and create an additional capital market access point for the Group through the Finansbank Offering. We currently intend to complete this offering when market conditions are favorable; however, our decision to proceed with the Finansbank Offering and its timing are subject to various considerations, including market conditions, offer size and structure and obtaining all necessary regulatory and other approvals.

If we successfully complete the Finansbank Offering, it will reduce Finansbank's contribution to the Group's profit attributable to NBG equity shareholders going forward. However, we believe that the successful completion of such a sale is likely to benefit the Group in the following ways:

Our level of non-accruing loans increased from 8.1% of our loans portfolio at December 31, 2010 to 15.1% at December 31, 2011, and subsequently it has increased even further. We have made the necessary allowances for non-accruing loans as at December 31, 2011, as appropriate in accordance with our provisioning policy, and having taken into account any collateral with respect to such loans. The effect of the economic crisis in Greece, the implementation of the Program and adverse macroeconomic conditions in the countries in which we operate may result in adverse effects on the credit quality of our borrowers, with increasing delinquencies and defaults. Provisions will continue to negatively affect net income in 2012. We also have provided for other probable losses inherent to the portfolio to the extent such losses are reasonably estimable. See Item 4.E, "Information on the Company-Selected Statistical Data—Credit Quality—Allowance for Loan Losses—Methodology".

Non-accruing loans generally remain on our balance sheet significantly longer than would be the case for banks in Western European countries.

The Group's write-off policy prescribes which loans and receivables fall into its scope and the criteria that must be met for each type of asset in order for each write-off to be approved by the relevant competent committee. Loan amounts to be written off for accounting purposes are individually identified and fully provided for. For all loan amounts written-off for accounting purposes, documentation is retained and is available to evidence and support the reasoning for the write-off and that the appropriate actions have been taken.

The following factors are taken into consideration when qualifying a loan for write-off: (i) the past due status of the loan; (ii) the existence of collateral held by the Group; to secure the loan and the ability to liquidate that collateral; (iii) the status of legal actions undertaken by the Group as well as the results of recent research regarding the borrower's real property (however, completion of such legal actions is not a necessary condition to write-off a loan if the claim against the borrower would remain valid after the loan is written-off); (iv) the existence of other assets held by the borrower identified through available databases; and (v) an assessment of the costs expected to be incurred for pursuing recovery compared to the expected recovery.

In specific cases corroborated with legal evidence, such as for example fraud or bankruptcy of the borrower, exposures can be written-off for accounting purposes regardless of whether the above criteria are satisfied. Written-off loans, either retail or corporate, are monitored until completion and exhaustion of legal actions having taken into consideration of the efforts and cost required. Write-offs are approved by each competent committee in accordance with its authority limits prescribed in its charter. See Item 4.E, "Selected Statistical Data—Credit Quality—Non-accruing Loans, Allowance for Loan Losses, and Loan Loss Experience".

As part of our strategy to preserve the quality of our loan portfolio, we have improved our methods of assessing credit quality in our loan portfolio. In Greece, we have taken and are continuing to take steps to improve our credit approval and risk management procedures in order to reduce the amount of non-accruing loans that occur in the future. See Item 4.E, "Selected Statistical Data—Credit Quality". Our credit procedures ensure consistency in the loan approval process throughout the Bank while tailoring this process to meet the specific needs of the Bank's borrowers. We have established centralized credit centers, thereby removing the decision-making discretion for loan approval from our branches. We have also established special divisions to monitor and strengthen our position with respect to delinquent commercial and consumer loans by working flexibly with clients (i.e., restructuring payments and taking additional collateral) to help them meet their payment obligations. See Item 4.E, "Selected Statistical Data—Credit Quality".

Outside of Greece, we are in the process of fully harmonizing credit approval and credit review policies throughout the Group's lending operations in order to reduce future non-accruing loans. For a

discussion of these policies at the various Group banks, see Item 4.E, "Selected Statistical Data—Credit Quality".

As part of our strategy to streamline our operations, we are disposing of certain investments in non-core businesses. In 2009, we disposed of 20% of Social Securities Funds Management S.A., which limited our participation to 20%, for a consideration of EUR 1.3 million and our non-controlling shareholding in Phosphoric Fertilizers Industry S.A. for a consideration of EUR 18.9 million. In addition, the Group received proceeds of approximately EUR 21.0 million in 2009, EUR 6.8 million in 2010 and EUR 15.5 million in 2011 from disposals of various real estate property holdings. We expect to continue divestitures of non-core assets in the future when circumstances permit.

In order to streamline their operations, some Group companies have implemented voluntary retirement schemes.

On December 31, 2010 the Bank's wholly owned subsidiary EH completed the voluntary retirement scheme that had been announced on November 25, 2008, whereby employees fulfilling certain criteria had the opportunity to leave service receiving additional benefits to those provided by law, subject to the approval of the Voluntary Retirement Scheme Committee which included representatives of the company and its employees. A total of 237 employees have left service taking advantage of the provisions of the scheme (not including those who had subscribed to the scheme and subsequently withdrew their interest). The Group has recognized a total expense of EUR 46.7 million with respect to this scheme (EUR 16.8 million in 2008, EUR 24.6 million in 2009 and EUR 5.3 million in 2010) and no further cost is expected to be incurred. In 2008, Vojvodjanska implemented a voluntary retirement scheme with an additional expense of EUR 1.4 million, which was completed in 2010.

We have also achieved further reductions in our cost base through voluntary retirements taken by certain employees of the Bank, as discussed above, allowing us to hire replacement and restricted personnel at a lower overall cost as well as with no salary increases. Specifically, in 2011 salaries, employee benefits and voluntary early retirement schemes in Greece on a comparable basis decreased by 5.7% year-on-year (see also below Item 5.A, "Operating Results-Results of Operations for the year ended December 31, 2011 compared with the year ended December 31, 2010 (as restated)".

In accordance with Greek Law 3655/2008, applicable from April 2008, the Bank's main pension plan, which was a defined-contribution plan, has been incorporated into the main pension branch of the state sponsored social security fund IKA - ETAM as of August 1, 2008. Pursuant to Greek Law 3655/2008, the Bank will contribute EUR 25.5 million per annum into IKA - ETAM for 15 years starting from December 2009. This legislation also prescribes that employer contributions made by the Bank will be reduced every three years in equal increments starting from 2013 from 26.5% until they reach 13.3% for employees who joined any social security plan prior to January 1, 1993. Employer contributions for employees who joined any social security fund after January 1, 1993, will remain at 13.3%. See Item 6.D, "Employees".

In addition, in 2005 and 2006, the Hellenic Republic passed legislation permitting bank employee auxiliary pension schemes to merge with the new ETAT. In connection with the proposed merger of the Bank's employee auxiliary schemes with ETAT, we expect to incur a substantial one-time expense, in accordance with an actuarial estimate, which will be commissioned on that time.

The applicable Greek statutory corporation income tax rate was 25% for 2009, 24% for 2010 and 20% for 2011.

On February 14, 2012, Greek Law 4046/2012 was enacted and effectively extends the period over which the tax losses realized on implementation of the PSI exchange may be utilized from a five year loss carry forward to an amortization period over the life of the New Greek government bonds.

On March 31, 2011, Greek Law 3943/2011 was enacted, according to which the nominal corporation tax rate is reduced to 20% for the periods commencing from January 1, 2011. Furthermore, upon profit distribution, approved by the general meetings of the shareholders as from January 1, 2012 and onwards, a 25% withholding tax is imposed on distributed profits. In particular, the distribution of profits approved in 2011 were subject to a withholding tax of 21%.

On May 6, 2010, Greek Law 3845/2010 was enacted, according to which entities with total net income in excess of EUR 100 thousand were required to pay a special tax levy for purposes of reducing the State deficit as agreed with the IMF and the EU. The tax levy accrued to the Group's current year income statement amounted to EUR 26.1 million.

In accordance with Greek Law 3842/2010 the receivable amount of withholding taxes which was reflected in the Bank's corporation tax returns for the year 2009 was not refundable provided that it related to taxes withheld on bond interest income. In this respect the Bank recognized in the income statement the amount of EUR 53.0 million.

On December 10, 2009, Greek Law 3808/2009 was enacted, according to which entities with profits exceeding EUR 5 million in 2008, were required to pay a special tax levy calculated on the higher of the taxable profits or IFRS profits reported for that year. The tax levy accrued to the Group's income statement in 2009, amounted to EUR 47.7 million.

The preparation of financial statements in accordance with U.S. GAAP requires management to make a number of judgments, estimates and assumptions that affect the reported amount of assets, liabilities, income and expense in our U.S. GAAP Financial Statements and accompanying notes. We believe that the judgments, estimates and assumptions used in the preparation of our U.S. GAAP Financial Statements are appropriate given the factual circumstances as of December 31, 2011.

Various elements of our accounting policies, by their nature, are inherently subject to estimation techniques, valuation assumptions and other subjective assessments. In particular, we have identified the following accounting policies which, due to the judgments, estimates and assumptions inherent to those policies, and the sensitivity of our financial condition and results of operations to those judgments, estimates and assumptions, are critical to an understanding of our financial statements.

The crisis in the Greek economy resulted in impairment losses recorded in several classes of assets, such as Greek government bonds and other loans in Greece (see Note 11 and Note 13 to the U.S. GAAP Financial Statements). This has adversely impacted the financial position, the results of operations, cash flows and regulatory ratios of the Bank, and consequently of the Group. Furthermore, the crisis has limited the Bank's access to liquidity from other financial institutions.

In addition, during 2011 the Bank has relied on the Eurosystem liquidity facilities.

Article 47 of Greek Law 2190/1920 requires any entity whose total equity is less than 50% of its share capital to convene a shareholders' meeting within six months after its prior year end to approve

actions for improving this ratio. In addition article 48 of Greek Law 2190/1920 provides that an entity whose total equity is less than 10% of its share capital and whose shareholders' meeting fails to take any decision for the restoration of the equity ratio may be liquidated following a court decision, which may be requested by anyone who has a legitimate interest.

At December 31, 2011, the Group's capital adequacy ratio was below the minimum threshold of 8.0% (negative 2.6%). The amount required for the restoration of the capital adequacy ratio to 8.0% is estimated by the Bank of Greece at EUR 6.9 billion.

The going concern of the Bank is dependent on (a) raising sufficient funds to restore the Group's and the Bank's financial positions and maintain adequate levels of capital and (b) the continuing reliance on and the continuation of the Eurosystem liquidity facilities. The Directors have considered the following main factors in concluding that the Group and the Bank can continue to operate for the foreseeable future:

The Program, which has already been approved by the Troika along with a specific sequence of disbursements, commits funds for the recapitalization plan, amounting up to EUR 50 billion and is now in the implementation phase under the auspices of the Bank of Greece. The main features of this Program are:

The Directors consider that it is appropriate to continue to adopt the going concern basis in preparing the financial statements for the Group and the Bank because:

In its letter to the Bank on April 20, 2012, the HFSF stated that, on April 19, 2012 the Bank of Greece replied to HFSF with the following:

In the same letter to the Bank, HFSF stated that it will participate in the share capital increase or in the issuance of a convertible bond by the Bank up to the amount of EUR 6.9 billion. Furthermore, the HFSF stated that it will cover any amount of unsubscribed share capital and/or the convertible bonds and that this commitment is valid until September 30, 2012.

Financial assets and liabilities that are trading instruments or are designated at fair value are recorded at fair value on the balance sheet date, with changes in fair value reflected in net trading loss in the income statement. Financial assets that are classified as AFS are recorded at fair value on the balance sheet date, with changes in fair value reflected in "Other comprehensive income". Judgment is involved in the determination of financial instruments to be designated at fair value in accordance with ASC 825 "Financial Instruments", such as loans, deposits and long-term debt. For more information on financial instruments designated at fair value, see Note 13 "Loans and allowance for loan losses", Note 19 "Deposits", Note 24 "Long-term debt" and Note 36 "Fair Value of Financial Instruments" to the U.S. GAAP Financial Statements.

The Group's management exercises judgment in determining the fair value of financial assets and liabilities. For exchange traded financial instruments, fair value is based generally on quoted market prices for the specific instrument. Where no active market exists, or where quoted prices are not otherwise available, we determine fair value using a variety of valuation techniques. These include present value methods, models based on observable input parameters, and models where some of the input parameters are unobservable. The Group considers the impact of both the credit risk of its counterparties, as well as its own creditworthiness in determining fair value of financial instruments, including over-the-counter derivative instruments and financial liabilities designated at fair value in accordance with ASC 825. This impact is estimated by calculating a separate CVA for each counterparty to which the Group has exposure. The calculation considers expected exposures generated using simulation techniques, as well as netting agreements and collateral postings. Furthermore, the CVA is based on expected loss rates derived from CDS rates observed in the market. If these are not available then we apply the regulatory risk weight that corresponds to the internal rating of the counterparty, or to unrated counterparties, if no internal rating is available. With respect to own credit risk, the Group estimates a debit value adjustment ("DVA") by applying a methodology symmetric to the one applied for CVA. The bilateral CVA recognized by the Group at December 31, 2010 and 2011 amounted to a cumulative loss of EUR 92.0 million and a cumulative gain of EUR 158.7 million, respectively. The gain in 2011 is attributed mainly to the high DVA due to the Bank's increased CDS

rate. The Group seeks to reduce counterparty risk by standardizing relationships with counterparties through International Swaps and Derivatives Association, Inc. ("ISDA") and Global Master Repurchase Agreement ("GMRA") contracts, which encompass all necessary netting and margining clauses. Additionally, for almost all active counterparties in over-the-counter transactions, Credit Support Annexes (CSAs) have been put into effect, so that net current exposures are managed through margin accounts on a daily basis, through the exchange of cash collateral. For a further discussion on the management of counterparty credit risk and the effect of a change in interest rates and foreign exchange rates on our portfolio see Item 11, "Quantitative and Qualitative Disclosures about Market Risk", in this document.

Valuation models are used primarily to value debt instruments, for which quoted market prices are not available and derivatives transacted in the over-the-counter market. The fair value for such instruments is estimated using discounted cash flow analysis based on contractual cash flows discounted at the corresponding market rates, quoted prices for instruments with similar characteristics or other pricing models. All valuation models are validated before they are used as a basis for financial reporting, and periodically reviewed thereafter by qualified personnel independent of the area that created the model. Wherever possible, we compare valuations derived from models with quoted prices of similar financial instruments, and with actual values when realized, in order to further validate and calibrate our models. A variety of factors are incorporated into our models, including actual or estimated market prices and rates, time value and volatility, and market depth and liquidity.

We apply our models consistently from one period to the next, ensuring comparability and continuity of valuations over time, but estimating fair value inherently involves a significant degree of judgment. Management therefore establishes valuation adjustments to cover the risks associated with the estimation of unobservable input parameters and the assumptions within the models themselves.

Financial assets and liabilities whose values are based on prices or valuation techniques that require inputs that are both unobservable and are significant to the overall fair value measurement are classified as Level 3 under the fair value hierarchy established in ASC 820 "Fair Value Measurements and Disclosures". Inputs to valuation models are considered unobservable if they are supported by little or no market activity. In periods of extreme volatility, lessened liquidity or in illiquid markets, there may be more variability in market pricing or a lack of market data to use in the valuation process. An illiquid market is one in which little or no observable activity has occurred or one that lacks willing buyers or willing sellers.

As of December 31, 2011, Level 3 assets amounted to EUR 4,248.5 million, which included EUR 292.4 million in trading assets, EUR 73.2 million in derivative assets, EUR 3,873.6 million in AFS securities and EUR 9.3 million in other assets. Level 3 assets represent 27.3% of assets measured at fair value (or 4.1% of total assets). As of December 31, 2011 Level 3 liabilities amounted to EUR 10.9 million, all of which relate to derivative liabilities. Level 3 liabilities represent 0.1% of the liabilities measured at fair value (or 0.0% of total liabilities). Level 3 financial instruments at December 31, 2011 include:

See Note 36 to the U.S. GAAP Financial Statements for a table that presents the fair value of Level 1, 2 and 3 assets and liabilities as at December 31, 2011.

Although a significant degree of judgment is, in some cases, required in establishing fair values, management believes the fair values recorded in our balance sheet and the changes in fair values recorded in our income statement are prudent and reflective of the underlying economics, based on the controls and procedural safeguards we employ.

Further details on this subject are given in Note 3 and Note 36 to the U.S. GAAP Financial Statements.

Recognition and measurement of intangibles recognized upon business combinations

We account for acquired businesses using the purchase method of accounting which requires that the assets acquired and liabilities assumed be recorded at the date of acquisition at their respective fair values.

The application of the purchase method requires certain estimates and assumptions especially concerning the determination of the fair values of the acquired intangible assets and property, plant and equipment as well as the liabilities assumed at the date of the acquisition. Moreover the useful lives of the acquired intangible assets, property, plant and equipment have to be determined. The judgments made in the context of the purchase price allocation can materially impact our future results of operations. Accordingly, for significant acquisitions, we obtain assistance from third party valuation specialists. The valuations are based on information available at the acquisition date.

Significant judgments and assumptions made regarding the purchase price allocations in the course of the acquisitions of Finansbank and Vojvodjanska include the following:

For the valuation of core deposits, the alternative source of funds method was applied. The value of Core Deposit Intangibles ("CDI") is measured by the present value of the difference, or spread, between the CDI's ongoing cost and the cost of a market alternative replacement. Acquired core deposit accounts typically provide a low-cost source of funds to the buyer. To replace these established, low-cost deposit accounts in a timely manner, any potential buyer's alternative would be to utilize higher-cost funds at current market rates. The valuation results were also subject to sensitivity analysis.

For the valuation of customer relationships, the multi-period excess of earnings method was applied. Excess earnings can be defined as the difference between the net operating profit attributable to the existing customers at the acquisition date and the required cost of invested capital on all the other assets (contributory assets such as fixed assets, CDI, trade name, assembled workforce and software) used in order to deliver a product or maintain the customer relationship. Value is estimated through the sum of the discounted future excess earnings attributable to these customers over the remaining life span of the customer relationship. The valuation results were also subject to sensitivity analysis.

For the valuation of brands, the relief-from-royalty method was applied which is based on hypothetical royalty income attributable to an asset. In particular, it estimates the expected annual royalty cost savings that result from the company's ownership of trademarks and licenses on which it does not have to pay royalties to a licensor. The intangible asset is then recognized at the present value of these savings. The valuation results were also subject to sensitivity analysis. The corporate brands used by Finansbank and Vojvodjanska were assessed to have an indefinite life based on their qualitative characteristics (history, strength, market awareness, etc.), as well as the circumstances of the trade name in relation to the specific acquisition.

For the valuation of software, the cost approach method was applied. The cost approach is based upon the economic principles of substitution and price equilibrium. The cost approach suggests that a prudent investor would not pay, for an intangible, more than the cost to acquire a comparable intangible on the market. Software intangibles were valued using the reproduction cost methodology, which is based on the assumption that the value of any intangible asset is the cost incurred to reconstruct or purchase an exact replica of the given intangible asset.

Under applicable accounting guidance, goodwill is reviewed at the reporting unit level for potential impairment at least on an annual basis at the end of the reporting period, or more frequently if events or circumstances indicate a potential impairment. This analysis is a two-step process. The first step of the goodwill impairment test compares the fair value of the reporting unit with its carrying amount, including goodwill. If the fair value of the reporting unit exceeds its carrying amount, then the goodwill of the reporting unit is considered not impaired; however, if the carrying amount of the reporting unit exceeds its fair value, the second step must be performed. The second step involves calculating an implied fair value of goodwill for each reporting unit for which the first step indicated possible impairment. The implied fair value of goodwill is determined in the same manner as the amount of goodwill recognized in a business combination, which is the excess of the fair value of the reporting unit, as determined in the first step, over the aggregate fair values of the individual assets, liabilities and identifiable intangibles as if the reporting unit was being acquired in a business combination. The adjustments to measure the assets, liabilities and intangibles at fair value are for the purpose of measuring the implied fair value of goodwill and such adjustments are not reflected in the consolidated balance sheet. If the implied fair value of goodwill exceeds the goodwill assigned to the reporting unit, there is no impairment. If the goodwill assigned to a reporting unit exceeds the implied fair value of the goodwill, an impairment charge is recorded for the excess. An impairment loss recognized cannot exceed the amount of goodwill assigned to a reporting unit, and the loss establishes a new basis in the goodwill. Subsequent reversal of goodwill impairment losses is not permitted under applicable accounting standards.

The fair values of the reporting units were determined using a combination of valuation techniques consistent with the income approach and the market approach and included the use of independent valuations. For purposes of the income approach, discounted cash flows were calculated by taking the net present value of estimated cash flows. Our discounted cash flow employs a capital asset pricing model in estimating the discount rate (i.e., cost of equity financing) for each reporting unit. The inputs to this model include: risk-free rate of return; beta, a measure of the level of non-diversifiable risk associated with comparable companies for each specific reporting unit; market equity risk premium; and in certain cases an unsystematic (company-specific) risk factor. The unsystematic risk factor is the input that specifically addresses uncertainty related to our projections of earnings and growth, including the uncertainty related to loss expectations. We use our internal forecasts to estimate future cash flows and actual results may differ from forecasted results. Cash flows were discounted using a discount rate based on expected equity return rates. We utilized discount rates that we believe adequately reflected the risk and uncertainty in the financial markets generally and specifically in our internally developed forecasts. Expected rates of equity returns were estimated based on historical market returns and risk/return rates for similar industries and geographies of the reporting unit. For purposes of the market approach, valuations of reporting units were based on actual comparable market transactions and market earnings multiples for similar industries and geographies of the reporting unit. Determination of fair value requires management to make assumptions and use estimates. We believe that the assumptions and estimates used are reasonable and supportable in the existing market environment and commensurate with the risk profile of the assets valued. However, different ones could be used which would lead to different results.

management regularly reviews the operating results of that unit. The reporting units where significant goodwill is allocated are the Turkish banking operations and the Serbian operations within the International banking segment. The goodwill relates to the acquisitions of Finansbank and Vojvodjanska Banka.

Goodwill is tested for impairment annually, at December 31. In 2011, in step 1 of the goodwill impairment test the fair value of the above reporting units was estimated using the income approach and in particular the Dividend Discount Model ("DDM") because (a) the reporting units consist of subsidiaries of the Group, and therefore their operations are directed by the Group, (b) the DDM incorporates the earnings variability associated with the restructuring of these subsidiaries operations following their acquisition, and (c) the DDM incorporates management's views of the near and medium term as well as detailed views of current and near future market conditions and strategy.

The DDM is based on management's forecasts, long-term growth rates based on the respective country GDP rates adjusted for inflation and discount rates based on observable market long term government bond yields and average industry betas.

The result of the DDM is cross-checked with other valuation methods, such as book value and earnings market multiples. These multiples corroborate the result or the DDM.

Underlying assumptions to the valuation models are: that the entities comprising these reporting units will remain subsidiaries of the Group, that the general macroeconomic and political conditions in the respective markets will remain stable, that economic activity will continue to grow in the medium term and that the reporting units will continue to be able to fund their operations. If any of these conditions changes in the future, it may reduce the value of the reporting units and cause an impairment charge with respect to goodwill.

The methodology applied has not changed since the previous assessment; however, the estimated cash flows were updated to reflect the current management estimates and market conditions.

Based on the results of step 1 of the impairment test, we determined that the fair value of Turkish banking operations, based on a 6.8% (2010: 5.8%) terminal growth rate and 18.1% (2010: 17.7%) pretax discount rate, exceeded the carrying amount by EUR 0.1 billion (2010: EUR 0.6 billion). A 1% increase in the discount rate or a 1% decrease in the terminal growth rate would decrease the fair value by approximately EUR 0.3 billion (2010: EUR 0.4 billion) and EUR 0.2 billion (2010: EUR 0.3 billion) respectively. In addition, a 5% decrease in the forecast amounts available for dividends would decrease the fair value by approximately EUR 0.2 billion (2010: EUR 0.2 billion).

The fair value of Serbian operations, based on a 8.0% (2010: 8.0%) terminal growth rate and 13.53% (2010: 13.74%) pre tax discount rate, was less than the carrying amount by EUR 80.8 million (2010: greater by EUR 169.2 million). A 1% increase in the discount rate or a 1% decrease in the terminal growth rate would decrease the fair value by EUR 57.1 million (2010: EUR 95.1 million) and EUR 47.4 million (2010: EUR 77.8 million) respectively. In addition, a 5% decrease in the forecast pre-tax earnings would decrease the fair value by EUR 16.8 million (2010: EUR 29.7 million). Based on the results of step 1 of the impairment test for Serbian operations, we performed step 2 of the impairment test, which resulted in an impairment charge of EUR 100.0 million. Since the DDM is based on management's forecasts that are unobservable inputs, the measurement of the goodwill impairment charge relating Serbian operations is classified as a Level 3 fair value measurement.

The Group also wrote-off the total amount of goodwill relating to its domestic insurance operations of EUR 236.7 million, due to the continuing adverse developments in the Greek economy and the profound effect of the PSI on the subsidiary's equity. Furthermore, the Group wrote-off EUR 56.5 million and EUR 25.1 million of goodwill relating to certain other domestic and foreign operations, respectively.

The Group recognized nil impairment losses for goodwill in 2009 and EUR 6.3 million in 2010 relating to private equity fund investments.

Further details on this subject are given in Note 3 and Note 14 to the U.S. GAAP Financial Statements.

The amount of the allowance set aside for loan losses is based upon management's ongoing assessments of the probable estimated losses inherent in the loan portfolio. Assessments are conducted by members of management responsible for various types of loans employing a methodology and guidelines that are continually monitored and improved. We assess whether objective evidence of impairment exists for all loans that are individually significant (i.e., specific allowances), and collectively for loans that are not considered individually significant (i.e., coefficient and homogeneous analysis).

Individually significant loans are subject to an impairment test when interest and/or capital is in arrears for a certain period and/or qualitative indications exist, at the assessment date, which demonstrate that the borrower will not be able to meet its obligations. Usually such indications include, but are not restricted to, significant financial difficulty, deterioration of credit rating and the probability of bankruptcy, renegotiation or other financial reorganization procedures. A specific impairment loss is recognized for loans evaluated individually for impairment and is based upon management's best estimate of the present value of the cash flows which are expected to be received. In estimating these cash flows, management makes judgments about the counterparty's financial situation and the net realizable value of any underlying collateral or guarantees in our favor. Each impaired loan is assessed on its merits, and the workout strategy and estimate of cash flows considered recoverable are independently reviewed.

In assessing the need for collective loan loss allowances, management considers factors such as credit quality, portfolio size, concentrations, and economic factors. In order to estimate the required allowance, we make assumptions both to define the way we model inherent losses and to determine the required input parameters, based on historical experience and current economic conditions. Allowances for loan losses made by our foreign subsidiaries are estimated by the subsidiary using similar criteria as the Bank uses in Greece.

The accuracy of the allowances and provisions we make depends on how well we estimate future cash flows for specific counterparty allowances and provisions and the model assumptions and parameters used in determining collective allowances. While this necessarily involves judgment, we believe that our allowances and provisions are reasonable and supportable. As the process for determining the adequacy of the allowance requires subjective and complex judgment by management about the effect of matters that are inherently uncertain, subsequent evaluations of the loan portfolio, in light of the factors then prevailing, may result in changes in the allowance for loan losses. The methodology for each component, the estimates and judgments are described in further detail in Item 4.E, "Selected Statistical Data—Credit Quality—Allowance for Loan Losses—Methodology".

Insurance reserves for our life insurance operations (long-duration contracts) are estimated using approved actuarial methods that include assumptions about future investment yields, mortality, expenses, options and guarantees, morbidity and terminations. Insurance reserves for our property and casualty insurance operations (short-duration contracts) are determined using loss estimates, which rely on actuarial observations of loss experience for similar historic events.

Assumptions and observations of loss experience are periodically adjusted, with the support of qualified actuaries, in order to reflect current conditions. Any additional future losses anticipated from the revision of assumptions and estimates are charged to the income statement.

We continue to monitor potential changes in loss estimates in order to ensure that our recorded reserves in each reporting period reflect current conditions. Our assumptions for insurance reserves are based on a subjective analysis and management judgment. Actual results may result in adjustments to reserves.

Insurance reserves increased from EUR 2.5 billion in 2010 to EUR 2.8 billion in 2011, due mainly to an improvement in the computational methodology and procedure applied for estimating the parameters used in valuing the liabilities for the health riders for closed portfolio of hospitalization policies (ECU contracts). In particular, during the past two years we collected and verified historical data and portfolio losses and calculated up to date statistical data, which is based on our existing portfolio and is supported by our historical experience. Therefore, we believe that this data provides the maximum reliable and representative information, and therefore is used as the best estimate in the formulation of appropriate assumptions.

The net periodic benefit cost is actuarially determined using assumed discount rates, assumed rates of compensation increase and the expected return on plan assets. These assumptions are ultimately determined by reviewing the Group's salary increases each year. The expected long-term return on plan assets represents management's expectation of the average rate of earnings on the funds invested to provide for the benefits included in the projected benefit obligation. To determine the expected long-term rate of return assumption the Group and its advisors make forward-looking assumptions in the context of historical returns and volatilities for each asset class as well as correlations among asset classes. The expected long-term rate of return assumption is annually adjusted based on revised expectations of future investment performance of the overall capital markets, as well as changes to local regulations affecting investment strategy. The weighted average expected long-term rate of return assumption used in computing the 2011 net periodic pension cost was 5.5% compared to 6.4% for 2010. The rate of compensation increases decreased from 5.1% in 2010 to 3.5% in 2011. The discount rate increased from 5.2% in 2010 to 5.3% in 2011. The change in assumptions and the difference between actual outcomes and assumptions resulted in a net actuarial gain of EUR 14.8 million in 2011. As at December 31, 2011, equity securities of the Bank represented 10% of plan assets of all Group funded defined benefit plans and therefore the performance of plan assets is largely dependent on the performance of the Bank's share price. The impact to the pension benefit obligation, as well as to service and benefit cost if certain assumptions are changed is further disclosed in Note 38, "Employee Benefit Plans", to the U.S. GAAP Financial Statements.

The assessment of impairment for the eligible Greek government bonds as at December 31, 2011 has been performed based on the provisions of ASC 310-20—Investments in Debt and Equity Securities indicating that if the fair value of an investment is less than its amortized cost basis at the balance sheet date of the reporting period for which impairment is assessed, the impairment is either temporary or other than temporary. The Group assessed whether its investments in the eligible Greek government bonds are impaired by comparing the fair value with the amortized cost of these debt instruments. This comparison has indicated that all eligible Greek government bonds are impaired and consequently the Group assessed whether the impairment is other than temporary.

The Group participated in the PSI (see Item 4.B, "Business Overview—The Macroeconomic Environment in Greece—The Hellenic Republic's Economic Crisis, the successful sovereign debt restructuring (PSI) and the agreement on the Program for Greece") and an exchange of Greek government bonds that were subject to Greek law took place on March 12, 2012 (and for bonds issued by State enterprises and guaranteed by the Hellenic Republic on April 4, 2012), while the exchange of Greek government bonds subject to foreign law was extended until April 25, 2012.

Based on the terms and the conditions in the Memoranda, and due to financial difficulties of the issuer, the Group does not expect to recover the amortized cost basis of the Greek government bonds eligible for the PSI, and therefore these bonds are other-than-temporarily-impaired. Therefore, as at December 31, 2011 the Group concluded that there was an other than temporary impairment in its portfolio of GGBs and a credit loss was determined as the difference between the fair value of these securities and the amortized cost reflected in the financial statements as at December 31, 2011. Given

the significant difficulties of the issuer, the Group concluded that the entire other than temporary impairment was attributable to credit related deterioration and therefore this amount was charged to the income statement.

The Offer was considered an adjusting event after the reporting period in relation to the annual financial statements for the year ended December 31, 2011, because it provided evidence of conditions that existed at the end of the reporting period. The Group concluded that there was not an active market for GGBs at December 31, 2011 and estimated the fair value at December 31, 2011 based on the contractual cash flows of the new Greek government bonds, a discount rate of 12% and appropriate market information.

The discount rate was based on the new fundamentals regarding the Hellenic Republic debt (the successful implementation of the PSI, together with the financial assistance under the Program, which is expected to improve the Hellenic Republic's debt sustainability aiming at the reduction of the Hellenic Republic debt to GDP ratio to 120% by 2020, the new reform effort and the escrow account arranged for the new PSI bonds that raises their seniority). Specifically, to arrive at this estimate, we have considered the yields of similarly rated sovereign and corporate entities, and we have analyzed the relationship of credit ratings and public debt with the bond yields for other European countries.

At December 31, 2011 Greek government bonds held by the Group that were not eligible for exchange comprised of:

Consistent with the assessment of the Greek bonds eligible for PSI, the Group has conducted an assessment of whether the decline in fair value below amortized cost is an other-than-temporary-impairment. The Group does not intend to sell these Greek government bonds, and it is not more likely than not to be required to sell them before the recovery of their amortized cost basis. Furthermore, the Group expects to recover the entire amortized cost basis of these bonds, because there is no evidence at the date these financial statements were authorized that there is a loss event that has an impact on the estimated future cash flows associated with these bonds, hence that the future cash flows will not be recovered in accordance with the contractual terms. Accordingly the unrealized losses of these bonds are included within AOCI.

To arrive at this conclusion the Group has considered that, although the issuer has financial difficulties, there is an expectation that the contractual cash flows will be met due to the guarantees in place as a result of the new Program for economic support for Greece as well as continuous support offered to Greece by the IMF and the Eurozone countries. Further the group gave consideration to the short duration of these bonds as all three bonds mature by 2014, that is within the period of the new Program for economic support for Greece. Furthermore, in reaching that conclusion we also took into consideration the guarantees in place as a result of the new Program for economic support for Greece as well as the continuous support offered to Greece by the IMF and the Eurozone countries.

Furthermore, the Group gave consideration to the short duration of these bonds as all three bonds mature by 2014, that is, within the period of the new Program for economic support for Greece.

In particular for the bond received in settlement of the Redeemable Preference Shares issued to the Greek State (see (a) above), the Bank also considered that this transaction formed an integral part of the public policy of the Official Sector to support the regulatory capital of the Greek banks in an effort to sustain the systemic stability of the financial sector in Greece. The Hellenic Republic would not benefit from defaulting on this bond since such action would not result to any reduction of the public debt, merely would be more than offset by the increased capitalization needs of the Greek banks and would therefore increase the Greek public debt. This result would have been in clear contradiction to the basic aim of the new Program for economic support for Greece, which was approved by the Heads of State of the Eurozone states and is supervised by the IMF, the ECB and the EU. Additionally, subject to obtaining Bank of Greece and other statutory approvals for the repurchase of the Redeemable Preference shares of a nominal value of EUR 1,350.0 million, the Bank could elect to exchange this bond at its maturity in May 2014 with the Redeemable Preference shares.

In accordance with Ministerial Decision 2/98029/0023A/17-01-2012, the redemption of the preference shares issued in favor to the Greek State, will, from December 31, 2011 onwards, be effected at the original par value of the preference shares through the exchange of Greek government bonds or treasury bills. At any redemption date the Greek government bonds or treasury bills to be exchanged should have the following characteristics:

For the bond issued by TANEO (see (b) above), the Group also considered that the fair value of the company's investments and the cash and cash equivalents held by TANEO exceeds the total outstanding bond issue and therefore the probability of TANEO defaulting on the bonds it has issued is very small.

Finally, it is expected that the successful implementation of the PSI together with the financial assistance under the Program agreed by the Eurozone members and the IMF will improve Greece's debt sustainability aiming at the reduction of the Greek debt to GDP ratio to 120% by 2020 (see above). This conclusion is also supported by the statements issued by the Euro summit and the EU Heads of State or Government on October 26, 2011, the Eurogroup statement on February 21, 2012, the press release of the Institute of International Finance (the "IIF") on March 3, 2012 and the statement by the IMF managing director on March 9, 2012.

Other-Than-Temporary-Impairment of other available-for-sale and held-to-maturity financial assets

Management follows the guidance of ASC 320 and is required to exercise judgment in determining whether an Other-Than-Temporary-Impairment ("OTTI") has occurred in securities classified as AFS or HTM. If an OTTI is identified, the unrealized losses recorded in accumulated other comprehensive income for the impaired security should be reclassified to net income. More information on assumptions and estimates requiring management judgment relating to the assessment of OTTI is provided in Note 3 and details regarding the unrealized losses by type of investment are provided in Note 11 to the U.S. GAAP Financial Statements, together with details regarding the unrealized losses by type of investment.

During 2011, the Group recognized an OTTI charge of EUR 259.8 million in relation to the majority of its equity securities and mutual fund units held with significant and prolonged unrealized

losses. Also during 2011, the Group recognized an OTTI charge of EUR 143.0 million in relation to certain bonds issued by Greek financial institutions, for which the issuers completed tender offers in the first quarter of 2012.

As at December 31, 2011, the Group had unrealized losses in AFS equity and debt instruments of EUR 35.7 million and EUR 478.2 million, respectively, and in HTM debt instruments of EUR 63.8 million, including EUR 16.7 million losses, which relate to the unamortized balance of the unrealized losses (before tax) that have been recorded in OCI prior to the reclassification in 2010 of certain of the HTM debt instruments from AFS.

Where cash flows related to an investment are readily determinable, a low level of judgment may be involved. However, where determination of estimated future cash flows requires consideration of a number of variables, some of which may be unobservable, more significant judgment is required. The most significant judgment applied by management relates to OTTI for certain debt securities issued by Greek financial institutions. No OTTI has been recognized for these positions based on management's assessment that the Group neither has the intention to sell nor expects it will be required to sell these securities before the recovery of their respective amortized cost bases, and that the issuers' payment obligations associated with these positions will be met on time and the full amount will be recovered. A key factor considered in this assessment was the existence of the recapitalization plan for the Greek banks (see Item 5.B "Liquidity and Capital Resources—Capital Adequacy") that significantly reduces the likelihood of default of the Greek banks.

Other significant judgment applied by management relates to equity instruments, where it is necessary to evaluate the near-term prospects of the issuer in relation to the severity and duration of the impairment and assess whether recovery is unlikely even after considering management's intention and ability to hold the investment. In this context "near-term" is defined as the next twelve months. The majority of the unrealized losses relating to equity instruments relate to mutual fund units, all of which have losses of less than 20%.

It is reasonably possible that outcomes in the next financial year could be different from the assumptions and estimates used in identifying OTTI. The recognition of OTTI charges would reduce the net income for the year by the amount disclosed above.

We are subject to income taxes in various jurisdictions. Significant judgment is required in determining the Group-wide provision for income taxes. We consider many factors including statutory, judicial and regulatory guidance in estimating the appropriate accrued income taxes for each jurisdiction. There are many transactions and calculations for which the ultimate tax determination is uncertain during the ordinary course of business. We recognize liabilities for anticipated tax audit issues based on estimates of whether additional taxes will be due. Where the final tax outcome of these matters is different from the amounts that were initially recorded, such differences will impact the current and deferred income tax assets and liabilities in the period in which the final outcome is determined.

Realization of deferred tax assets is dependent on generating sufficient taxable income. Although realization is not assured, the Group believes that the realization of the net deferred tax assets after valuation allowance of EUR 259.1 million at December 31, 2011(see Note 30 to the U.S. GAAP Financial Statements), is more likely than not based upon all available positive and negative evidence in Greece and the other countries where the Group operates. The Group believes this is a critical accounting estimate due to the current market and economic conditions in Greece (see Item 3.D, "Risk Factors—Risks Relating to the Hellenic Republic Economic Crisis".

A significant piece of objective negative evidence evaluated was the cumulative loss incurred over the three-year period ended December 31, 2008, 2009 and 2010 in the Bank. Such objective evidence limits the ability to consider other subjective evidence in taxable entities where there is a cumulative loss.

Greek Law 4046/2012 was enacted on February 14, 2012 and effectively extends the period over which the tax losses realized on implementation of the PSI exchange may be utilized from a 5 year loss carry-forward to an amortization period over the life of the New Greek government bonds. The Group will assess in 2012 whether this change in tax law impacts the valuation allowance for deferred tax assets.

Results of Operations for the year ended December 31, 2011 compared with the year ended December 31, 2010 (as restated)

Overview. Our net loss for the year ended December 31, 2011, was driven by the significant, negative impact of our participation in the PSI, the exceptionally adverse economic conditions in Greece and the still volatile condition of the economy of the SEE countries. These negative developments were partially offset by the positive impact of the robust performance of the Turkish economy. The Greek GDP declined by 4.2% in 2010 and 6.9% in 2011, leading to another year of recession, and the unemployment rate increased from 14.4% at December 31, 2010, to 17.7% at December 31, 2011. In addition, the pay reduction suffered by state employees and pensioners in 2011 in order to reduce the government expenses as part of the stabilization program jointly supported by the IMF, the ECB and the member States of the eurozone, also affected the ability of consumer borrowers to repay loans, leading to deteriorating performance of the unsecured consumer and mortgage loan portfolio. These events have resulted in significantly higher provisions for loan losses during the year, OTTI charges of EUR 9,173.7 million for debt and equity securities and EUR 1,877.0 million for trading losses in the trading and derivatives portfolio. For these reasons the Group posted in 2011 a net loss attributed to shareholders of EUR 14,539.7 million from EUR 354.8 million in 2010.

Net Interest Income before provision for loan losses. Net interest income before provision for loan losses for 2011 was EUR 3,648.2 million, a decrease of 10.7% for 2011, compared to EUR 4,083.6 million in 2010. Net interest margin was at 3.6% in 2011 compared to 3.8% in 2010, despite the pressure from competition in domestic deposit gathering. The components of our net interest income after provision for loan losses for 2010 and 2011 are reflected in the following table:

	Year ended December 31,

	2010 As restated⁽¹⁾			2011			2010/2011 Change
	(EUR in thousands)						(%)
Interest Income:
Loans		5,007,064			5,050,455			0.9
Securities available-for-sale		700,962			760,414			8.5
Securities held-to-maturity		94,895			123,281			29.9
Trading assets		229,200			191,441			(16.5	)
Securities purchased under agreements to resell		13,510			31,646			134.2
Interest-bearing deposits with banks		61,532			63,367			3.0
Other		41,673			39,046			(6.3	)

Total interest income		6,148,836			6,259,650			1.8

Interest Expense:
Deposits		(1,821,966	)		(2,264,935	)		24.3
Securities sold under agreements to repurchase		(75,712	)		(122,017	)		61.2
Other borrowed funds		(25,391	)		(24,914	)		(1.9	)
Long-term debt		(139,450	)		(197,381	)		41.5
Other		(2,716	)		(2,252	)		(17.1	)

Total interest expense		(2,065,235	)		(2,611,499	)		26.5

Net interest income before provision for loan losses		4,083,601			3,648,151			(10.7	)
Provision for loan losses		(1,204,995	)		(3,703,269	)		207.3

Net interest income after provision for loan losses		2,878,606			(55,118	)		(101.9	)

Our total interest income increased by 1.8% to EUR 6,259.7 million for 2011, from EUR 6,148.8 million for 2010. The Group's interest income from loans in 2011 had a small increase of 0.9% compared with 2010, reflecting the benefits from the repricing efforts during 2011, despite the decrease in the Group's total loans of EUR 3,035.6 million.

Our total interest expense increased by 26.5% to EUR 2,611.5 million for 2011, from EUR 2,065.2 million for 2010, mainly due to higher rates paid for deposits and wholesale funding in all the countries where we operate. Interest expense on deposits increased by 24.3% for 2011 compared with 2010. This is mainly due to the significantly higher rates paid to interest bearing deposits in 2011 compared with 2010. Total deposits decreased to EUR 91.6 billion as at December 31, 2011, from EUR 93.9 billion as at December 31, 2010. This decrease was mainly due to the reduced interest bearing deposits from individuals by EUR 4,983.5 million, although interbank interest-bearing deposits rose to EUR 32.5 billion as at December 31, 2011, as compared with EUR 25.9 billion as at December 2010.

Our provision for loan losses charged to the income statement increased from EUR 1,205.0 million as at December 31, 2010, to EUR 3,703.3 million as at December 31, 2011, or 207.3%. The domestic provision for loan losses charged to the income statement amounted to EUR 3,378.8 million in 2011 compared to EUR 878.1 million in 2010, or an increase of 284.8%. The provision for domestic loan losses includes as at December 31, 2011 an amount of EUR 1,720.4 million relating to the loan to the Hellenic Republic and loans granted to public sector entities, which were included in the list of PSI eligible Greek Government Bonds and loans (see Item 4.E. "Selected Statistical Data—Loan Portfolio"). The remaining balance of EUR 1,658.4 million charged to the income statement reflects the deterioration of the loan portfolio. The provision for foreign loans losses charged to the income statement remained almost stable amounting to EUR 324.5 million as at December 31, 2011 compared to EUR 326.9 million as at December 31, 2010.

Total impaired loans as at December 31, 2011 amounted to EUR 19,942.0 million, an increase of EUR 11,556.0 million since December 31, 2010. Domestic impaired loans amounted to EUR 16,551.5 million and foreign impaired loans amounted to EUR 3,390.5 million, increased by 194.0% and 23.1% respectively since December 31, 2010 (see Note 13 to the U.S. GAAP Financial Statements).

Domestic impaired and non-accruing loans increased as at December 31, 2011, as a consequence of the unprecedented economic downturn in the Hellenic Republic, which accelerated in the first months of 2010 and continued through 2010 and 2011 and is evidenced by the worsening macroeconomic environment (see Item 5A. "Operating Results—Results of Operations for the year ended December 31, 2011 compared with the year ended December 31, 2010 (as restated)—Overview").

Domestic impaired loans for the year ended December 31, 2011, increased from EUR 5,630.6 million as at December 31, 2010 to EUR 16,551.5 million as at December 31, 2011, or 194.0%. This increase is mainly attributed to the classification as impaired of an amount of EUR 6,939.8 million of the other commercial loans relating to (a) the loan to the Hellenic Republic amounting to EUR 5,160.8 million, as at December 31, 2011, and (b) the loans exchanged in the PSI, amounting to EUR 1,779.0 million, as at December 31, 2011, and also to the deterioration of our loan portfolio due to the substantial impact of the recession in the debt servicing. The consumer portfolio and Small Business Loans of our domestic portfolio deteriorated significantly in 2011, with impaired balances increasing by EUR 1,752.0 million, and EUR 435.1 million respectively, since December 31, 2010. Impaired balances of other commercial loans of our domestic portfolio for the year ended December 31, 2011, also increased by EUR 8,733.9 million compared to December 31, 2010, mainly due to the loan to the Hellenic Republic and the loans exchanged in the PSI.

The increase in non-accruing domestic loans as at December 31, 2011 of EUR 4,375.5 million is due to the following two factors: (a) the deterioration of the quality of our portfolio and (b) the effect

from classification in 2011 of loans modified in a trouble debt restructuring as non-accruing, amounting to EUR 2,023.9 million as at December 31, 2011.

Foreign impaired loans as at December 31, 2011, amounted to EUR 3,390.5 million, increased by EUR 635.1 million or 23.1% compared to December 31, 2010, mainly due to the continuing volatile economic conditions prevailing, since 2009, in the SEE countries in which we operate. Real GDP growth rate in SEE-6 is estimated to have rebounded to 2.1% in 2011 after two consecutive years of negative growth. Unemployment rate confirmed its increasing trend across SEE-6 countries in 2010 and 2011. This unfavorable economic environment directly affected the ability of retail and corporate borrowers to repay loans.

Foreign non-accruing loans as at December 31, 2011, amounted to EUR 2,743.3 million increased by EUR 666.2 million or 32.1% compared to December 31, 2010. The increase is mainly attributed to the effect from classification in 2011 of loans modified in a trouble debt restructuring as non-accruing amounting to EUR 487.2 million as at December 31, 2011.

Total write-offs as at December 31, 2011, amounted to EUR 169.5 million, an increase of EUR 29.1 million compared to 2010. Domestic write-offs as at December 31, 2011, amounted to EUR 77.1 million and foreign write-offs amounted to EUR 92.4 million, a decrease of 9.4% and an increase of 67.1% respectively, from the same period in 2010.

Total allowance for loan losses (allowance for impaired and non-impaired loans) at December 31, 2011, amounted to EUR 6,550.6 million, an increase of EUR 3,375.2 million, or 106.3% compared to December 31, 2010. As at December 31, 2011, allowance for impaired domestic and foreign loans amounted to EUR 5,288.0 million and EUR 1,077.8 million respectively, an increase of 161.8% and 18.6% respectively, compared to December 31, 2010.

The increase in the allowance for loan losses is mainly due to the increase in the provision for loan losses charged to the income statement in 2011 by EUR 2,498.3 million compared to 2010 which includes an amount of EUR 1,720.4 million relating to the provision charge in relation to (a) the loans eligible to PSI, and (b) the loan to the Hellenic Republic.

The allowance for loan losses as a percentage of total loans increased from 4.0% as of December 31, 2010 to 8.6% as of December 31, 2011, out of which 2.3% is attributed to the allowance for loan losses accounted for in relation to the loan to the Hellenic Republic and the loans exchanged in the PSI, which amounted to EUR 1,720.4 million at December 31, 2011. The remaining increase reflects the increased balance of impaired and non-accruing loans in our portfolio and the higher loss rates applied to most classes of the domestic loan portfolio.

The ratio of allowance for impaired loans to impaired loans ("impaired coverage ratio") at December 31, 2011, was 31.9%, lower by 301 basis points from the ratio of 34.9% at December 31, 2010. Given that the impaired coverage ratio for the loan to the Hellenic Republic and the loans

eligible to PSI amounted to 24.8% at December 31, 2011, impaired coverage ratio on the remaining portfolio has increased to 35.7%, which is mainly due to the higher loss rates applied to the impaired portfolio. The impaired coverage ratios of domestic and foreign loans as at December 31, 2011, were 31.9% and 31.8% respectively. The impaired coverage ratio for the domestic loan portfolio at December 31, 2011, has decreased by 393 basis points from the ratio of 35.9% at December 31, 2010. This decrease is mainly attributed to the effect of the allowance for loan losses of the loan to the Hellenic Republic and the loans eligible to PSI for which the impaired coverage ratio is 24.8%. The impaired coverage ratio on the remaining domestic loan portfolio has increased to 37.1% as at 31 December 2011 which is due to the higher loss rates applied to the remaining impaired domestic portfolio.

The ratio of allowance for impaired loans to non-accruing loans ("non-accruing coverage ratio") at December 31, 2011, was 55.5%, higher by 993 basis points from the ratio of 45.6% at December 31, 2010. The non-accruing coverage ratio is affected by the effect in the domestic non-accruing coverage ratio of the allowance accounted for the loan to the Hellenic Republic and the loans exchanged in the PSI, since these loans are still accruing. The non-accruing coverage ratio of domestic and foreign loans as at December 31, 2011, was 60.6% and 39.3% respectively.

The non-accruing coverage ratio for the domestic portfolio increased from 46.5% as at December 31, 2010 to 60.6% as at December 31, 2011, or 1,416 basis points.

The impaired coverage ratio for the foreign portfolio at December 31, 2011, has decreased by 120 basis points since December 31, 2010, due to the fact that the impaired balances in 2011 increased while a provision for loan losses had been taken in previous years. The non-accruing coverage ratio for the foreign portfolio as at December 31, 2011, decreased by 448 basis points since December 31, 2010. Both ratios were negatively affected by the sale of fully provided impaired loans by Finansbank amounting to EUR 107.2 million. Furthermore, the non-accruing coverage ratio for the foreign portfolio was affected by the significant increase of non-accruing loan balances by EUR 666.2 million, the majority of which includes commercial loans with significant real estate collateral, which outpaced the increase of allowance for loan losses of EUR 168.7 million.

The most significant increase is noted within the specific allowances, which increased almost five times from EUR 564.6 million as at December 31, 2010 to EUR 2,811.4 million as at December 31, 2011. Specific allowances mainly include corporate loans, as well as SBLs to a lesser extent. This increase, combined with the write-offs of corporate loans, reflects the increase of individually assessed customers, the additional allowances on already impaired customers due to the adverse economic conditions, as well as the allowances for loan losses booked for the loan to the Hellenic Republic and the loans exchanged in the PSI.

Homogeneous allowances, increased during 2011 from EUR 1,451.8 million as at December 31, 2010 to EUR 2,424.2 million as at December 31, 2011. This is in line with the significant increase of our retail non-accruing loans during the same period.

Coefficient allowances increased from EUR 106.4 million as at December 31, 2010 to EUR 198.2 million as at December 31, 2011, reflecting both the increase of customers provided for using this methodology (i.e. corporate loans with a balance of EUR <750 thousand, see Note 3, "Summary of significant accounting policies" to the U.S. GAAP Financial Statements) as well as a slight downgrading of customers to a credit rating requiring higher loan loss allowances.

When the Group determines the amount of allowance for loan losses for our pool of homogeneous loans, loss rates are applied. These loss rates have been produced by our risk models, which collect historical evidence of recoveries spanning across many years. Our analysis of past data has demonstrated that we collect insignificant amounts from the unsecured portion of our portfolio after a period of four years after the loan agreement is legally terminated. Therefore, for this portion of past due loans, a 100% loss allowance is recorded, which represents a full reserve. A write-off may not be made since legal actions may still be pending.

The decrease in write-offs for domestic operations during 2009 and 2010, resulted from a change in the Bank's policy, which now allows for a period of at least five years before the write-off for the unsecured portfolio. In 2011, write offs levels are still influenced by the change of the write-off policy in relation to unsecured portfolios. Domestic write-offs mainly consist of Corporate and Small business loans individually assessed which have been written-off partially, therefore keeping only the secured balance on balance sheet, or in total.

Non-interest Income. Non-interest income decreased to EUR (9,487.0) million for 2011, compared to EUR 667.8 million for 2010. The following table summarizes the principal components of non-interest income during each of the two years ended December 31, 2010 and 2011:

	Year ended December 31,

	2010 As restated⁽¹⁾			2011			2010/2011 Change
	(EUR in thousands)						(%)
Credit card fees		188,771			198,411			5.1
Service charges on deposit accounts		52,722			78,342			48.6
Other fees and commissions		475,692			435,421			(8.5	)
Net trading loss		(1,245,322	)		(1,877,038	)		(50.7	)
Equity in earnings of investees and realized gains/(losses) on disposals		9,245			8,661			(6.3	)
Income from insurance operations		1,017,172			777,280			(23.6	)
Other		144,081			85,085			(40.9	)

Total non-interest income / (loss) excluding gains / (losses) on investment securities		642,361			(293,838	)		(145.7	)

Net realized gains / (losses) on sales of available for sale securities		114,959			(19,466	)		(116.9	)
Other-Than-Temporary-Impairment (of which nil was recognized in OCI)		(89,497	)		(9,173,713	)		—
Net gains / (losses) on available for sale and held to maturity securities		25,462			(9,193,179	)		—

Total non-interest income / (loss)		667,823			(9,487,017	)		—

Our net trading losses consist of valuation losses in our bond portfolio and derivative positions. Net trading losses increased to EUR 1,877.0 million in 2011 from EUR 1,245.3 million in 2010. Other-Than-Temporary-Impairment includes the effect to the income statement of the impairment of Greek government bonds due to Private Sector Involvement and the exchange of the Greek government bonds subject to the PSI (see Note 11 to the U.S. GAAP Financial Statements). The decrease in income from insurance operation reflects mainly (a) the decrease in new policies written in the life insurance single premium bancassurance business, as a result of the lower savings rate caused by the financial crisis and austerity measures, and (b) the decrease in the production of the motor business, as a result of both the financial crisis and the streamlining of the motor policy portfolio.

Non-interest Expense. Non-interest expense in 2011 was EUR 4,506.0 million increased by 18.2% compared with EUR 3,812.1 million for 2010.

Salaries, employee benefits and voluntary early retirement schemes decreased by 5.7% and amounted to EUR 1,426.4 million in 2011 from EUR 1,511.9 million in the same period in 2010, reflecting the effect of the management's cost-cutting measures. Occupancy and equipment expense decreased by 13.1% in 2011 compared with 2010 due to the ongoing initiatives to reduce non-interest expenses such as rentals in Greece.

Impairment of goodwill amounted to EUR 418.7 million in 2011, compared to EUR 6.3 million in 2010. In 2011 we recognized an impairment of EUR 236.7 million in our domestic insurance business due to the continuing adverse developments in the Greek economy, EUR 48.6 million in domestic real estate business, EUR 8.0 million in our private equity business and EUR 125.1 million in our SE Europe banking and leasing subsidiaries due to the volatile economic developments in these countries.

Insurance claims, reserves movement, commissions and reinsurance premia ceded increased by 7.7% in 2011, compared to 2010, due to an increase in lapses as a result of the austerity measures, as well as the strengthening of reserves.

The increase in other non-interest expense and deposit insurance premium line relates mainly to an amount of EUR 169.9 million regarding staff leaving indemnity contingencies (see Note 25 to the U.S. GAAP Financial Statements).

Income / (Loss) Before Income Tax. In 2011, the Group reported losses before income tax of EUR 14,048.1 million compared to loss before income tax of EUR 265.7 million in 2010, principally due to the loss from our participation in the PSI, higher net trading losses and increased provisions

made by the Bank and its banking subsidiaries in SEE, in light of deteriorating economic conditions and higher net non-interest expense.

Income Tax (Expense) / Benefit. In 2011, we recognized a current tax expense of EUR 153.6 million and a deferred tax expense of EUR 305.7 million compared to a current tax expense of EUR 260.2 million and a deferred tax benefit of EUR 217.9 million in 2010. Our total tax expense in 2011 amounted to EUR 459.3 million compared to EUR 42.3 million in 2010. The applicable Greek statutory corporation income tax rate was 20% for 2011 and 24% for 2010.

In 2010, in accordance with Law 3842/2010 the Bank recognized a non-recurring tax of EUR 53.0 million, which relates to non-offsettable income taxes and also in accordance with Law 3845/2010, the Group recognized a tax expense of EUR 26.1 million, which relates to a special tax levy on profitable companies.

Net Income / (Loss) attributable to NBG shareholders. For the reasons discussed above, net losses attributable to NBG shareholders were EUR 14,539.7 million for 2011, compared to EUR 354.8 million for 2010.

Exchange Rate Exposure. The Group is an active participant in the foreign exchange markets and also grants loans denominated in currencies other than the euro. The Group's goal in managing exchange rate exposure is to minimize the effect of exchange rate fluctuations on profitability. The Group adheres to central Bank guidelines and other guidelines applicable to the Group and actively manages its foreign currency position. To the extent that foreign currency-denominated assets are not matched with liabilities denominated in the same currencies, the Group engages in swaps and other economic hedging transactions in order to reduce the effects of these imbalances. Furthermore, following the Group's expansion to Turkey (through the Finansbank acquisition) the exposure to TL has increased. The Group closely monitors its exposure to the TL arising from the net investment in Finansbank and when necessary it engages in swap and other economic hedging transactions in order to reduce the volatility in the Group's equity arising on the translation of Finansbank's net assets from TL to Euro. As at December 31, 2011, 21.2% of the Group's liabilities and 28.7% of the Group's assets were denominated in currencies other than euro, before taking into account economic hedging transactions. For more information on foreign exchange risk see Item 11, "Quantitative and Qualitative Disclosures About Market Risk".

Results of Operations for the year ended December 31, 2010, compared with the year ended December 31, 2009 (both as restated)

Overview. Our results for the year ended December 31, 2010 were significantly impacted by the exceptionally adverse economic conditions, extraordinary tax charges and the substantial losses from the fall in the price of Greek sovereign bonds. These events have resulted in significantly higher provisions for loan losses during the year and OTTI charges of EUR 89.5 million for debt and equity securities and trading losses of EUR 1,245.3 million in the trading securities and derivatives portfolio. Lower income from non-core asset disposals in 2010 also contributed to the 190.7% decrease in net income attributed to our shareholders from EUR 391.1 million in 2009 to incurred losses of EUR 354.8 million in 2010.

Net Interest Income before provision for loan loss. Net interest income before provision for loan losses increased by 7.9% to EUR 4,083.6 million for 2010, compared to EUR 3,786.3 million in 2009, underscoring the stability of the Group's business model even in period of crisis, and highlighting the importance of the geographical dispersion of the Group's income sources. Net interest margin was at 3.8% in 2010 compared to 3.9% in 2009, despite the pressure from competition in domestic deposit

gathering. The components of our net interest income for 2009 and 2010 are reflected in the following table:

	Year ended December 31,

	2009 As restated⁽¹⁾			2010 As restated⁽¹⁾			2009/2010 Change
	(EUR in thousands)						(%)
Interest Income:
Loans		5,039,925			5,007,064			(0.7	)
Securities available for sale		844,074			700,962			(17.0	)
Securities held-to-maturity		9,425			94,895			—
Trading assets		197,704			229,200			15.9
Securities purchased under agreements to resell		28,553			13,510			(52.7	)
Interest-bearing deposits with banks		63,515			61,532			(3.1	)
Other		48,184			41,673			(13.5	)

Total interest income		6,231,380			6,148,836			(1.3	)

Deposits		(2,133,507	)		(1,821,966	)		(14.6	)
Securities sold under agreements to repurchase		(90,052	)		(75,712	)		(15.9	)
Other borrowed funds		(34,244	)		(25,391	)		(25.9	)
Long-term debt		(184,144	)		(139,450	)		(24.3	)
Other		(3,168	)		(2,716	)		(14.3	)

Total interest expense		(2,445,115	)		(2,065,235	)		(15.5	)

Net interest income before provision for loan losses		3,786,265			4,083,601			7.9
Provision for loan losses		(998,448	)		(1,204,995	)		20.7

Net interest income after provision for loan losses		2,787,817			2,878,606			3.3

Our total interest income decreased by 1.3% to EUR 6,148.8 million for 2010, from EUR 6,231.4 million for 2009. The Group's interest income from loans in 2010 decreased slightly by 0.7% compared with 2009, reflecting lower short and long-term interest rates prevailing throughout 2010 despite the increase in the Group's retail and corporate lending activities. Interest income from securities available for sale decreased by 17.0% and interest income from securities HTM increased, due to the transfers of investment securities between categories that took place within 2010 (see Note 11 to the U.S. GAAP Financial Statements). Interest income from trading assets increased by 15.9% mainly due to the higher yields on Greek Government Bonds that mainly comprise the trading portfolio.

Our total interest expense decreased by 15.5% to EUR 2,065.2 million for 2010, from EUR 2,445.1 million for 2009, mainly due to lower rates paid for deposits and lower balances of individual customer deposits. Interest expense on deposits decreased by 14.6% for 2010 compared to 2009. This is mainly due to the decrease of interest bearing deposits from individuals by 7.7% as at December 31, 2010, compared to the corresponding balance as at December 31, 2009. Although, total deposits increased to EUR 93.9 billion as at December 31, 2010, from EUR 87.8 billion as at December 31, 2009, this increase was mainly due to the increase of interbank interest-bearing deposits to EUR 25.9 billion as at December 31, 2010 of which EUR 24.2 billion were due to ECB, as compared with EUR 16.6 billion as at December 2009, of which EUR 11.0 billion were due to ECB.

Our provisions for loan losses increased from EUR 998.4 million as at December 31, 2009 to EUR 1,205.0 million as at December 31, 2010, or an increase of 20.7%. The provision for domestic

loans losses amounted to EUR 878.1 million in 2010 compared to EUR 591.6 million in 2009, an increase of 48.4%. The provision for foreign loans losses decreased by 19.7% from EUR 406.8 million as at December 31, 2009 to EUR 326.9 million as at December 31, 2010.

Total impaired loans at December 31, 2010 amounted to EUR 8,386.0 million, an increase of EUR 3,420.3 million, or 68.9% compared to December 31, 2009. Domestic impaired loans amounted to EUR 5,630.6 million and foreign impaired loans amounted to EUR 2,755.4 million, an increase of 83.7% and 45.0% respectively compared to December 31, 2009.

Domestic impaired loans for the year ended December 31, 2010 were negatively affected by the increase in non-accruing loans of EUR 1,476.8 million as well as the increased balances under TDRs of EUR 1,112.6 million. Mortgage loans and unsecured consumer balances were the worst performing classes of our domestic portfolio and increased by EUR 863.2 million and EUR 867.3 million respectively, while SBLs also increased by EUR 507.5 million for the year ended December 31, 2010. Commercial impaired loans also increased by EUR 288.0 million since more balances fell into the Moody's Rating Advisor >14 buckets and +30dpd buckets, were individually assessed and provided for.

Foreign impaired loans for the year ended December 31, 2010 increased by EUR 854.6 million, a 45.0% increase mainly due to increased (i) accruing commercial loans classified as impaired of EUR 308.9 million in SEE and (ii) non-accruing commercial balances of EUR 429.8 million in SEE and Turkey.

Total non-accruing loans as at December 31, 2010 amounted to EUR 6,425.3 million, increased by EUR 2,258.8 million, or 54.2% compared to December 31, 2009. Domestic non-accruing loans amounting to EUR 4,348.3 million, increased by 51.4% compared to December 31, 2009, and foreign non-accruing loans amounting to EUR 2,077.0 million, an increase of 60.4% compared to December 31, 2009. Foreign non-accruing loans increased by EUR 782.0 million due to the increased commercial loans becoming non-accruing in SEE countries and increased commercial and consumer balances in Turkey.

As at December 31, 2010, domestic impaired and non-accruing loans increased by 83.7% and 51.4%, respectively, due to the substantial impact of the recession in the debt servicing ability of the Greek private sector. The unprecedented economic downturn in the Hellenic Republic, which accelerated in the first months of 2010 and continued through 2010, is evidenced by the worsening macroeconomic environment. More specifically, Greek GDP declined by 4.2% in 2010, leading to another year of recession, and the unemployment rate grew from 12.6% at December 31, 2009 to 14.4% at December 31, 2010. In addition, the pay reduction suffered by state employees and pensioners in 2010 in order to reduce the government expenses as part of the stabilization program jointly supported by the IMF, the ECB and the member States of the eurozone, also affected the ability of consumer borrowers to repay loans, leading to deteriorating performance of the unsecured consumer and mortgage loan portfolio.

Foreign impaired loans increased by 45.0% and amounted to EUR 2,755.4 million at December 31, 2010 mainly resulting from the adverse economic conditions prevailing, since 2009, in SEE countries in which we operate. After a severe recession in 2009, GDP declined by 7.1% in Romania, 5.5% in Bulgaria, 3.5% in Serbia; in 2010 GDP continued its decrease in Romania, whereas in other countries GDP growth is nearly flat. Unemployment rate confirmed its increasing trend across SEE countries in 2010. This unfavorable economic environment directly affected the ability of retail and corporate borrowers to repay loans.

Total net write-offs for the year ended December 31, 2010 amounted to EUR 117.1 million, a decrease of EUR 49.5 million compared to 2009. Domestic net write-offs were EUR 80.5 million and foreign net write-offs were EUR 36.7 million, or lower by 23.1% and 40.9% respectively, from the same period in 2009.

Total allowance for loan losses (allowances for impaired and non-impaired loans) at December 31, 2010, was EUR 3,175.4 million and increased by EUR 1,110.2 million, or 53.8% compared to December 31, 2009. As at December 31, 2010, allowances for impaired domestic and foreign loans were EUR 2,019.9 million and EUR 909.1 million respectively, increased by 72.1% and 26.7% compared to 2009.

The allowance for loan losses as a percentage of total loans increased from 2.7% as of December 31, 2009 to 4.0% as of December 31, 2010. This was mainly due to (i) the increased balance of impaired and non-accruing loans in our portfolio and (ii) the increase of our non-accruing loans coverage ratio for the domestic segment due to higher loss rates applied to most classes of the domestic loan portfolio.

The impaired coverage ratio at December 31, 2010 was 34.9%, lower by 316 basis points from the ratio of 38.1% at December 31, 2009. The impaired coverage ratios of domestic and foreign loans as at December 31, 2010, were 35.9% and 33.0% respectively.

The non-accruing coverage ratio at December 31, 2010 was 45.6%, higher by 19 basis points compared to the ratio of 45.4% at December 31, 2009. The non-accruing coverage ratio of domestic and foreign loans as at December 31, 2010, was 46.5% and 43.8% respectively. Contrary to the impaired loans, the non-accruing coverage improved due to the higher loss rates applied in most classes of the domestic portfolio leading to an increase of allowances by 72.1% while non-accruing loan balances increased by 51.4% for the year ended December 31, 2010.

The impaired coverage ratio for the domestic segment at December 31, 2010 has decreased by 242 basis points since December 31, 2009, due to (i) increased balances of impaired mortgages and (ii) increased balances of TDRs in mortgage and SBLs classes which attract provisions with a loss rate lower than the ratio of 38.3% of the domestic impaired coverage ratio at December 31, 2009. The non-accruing coverage ratio for the domestic segment as at December 31, 2010, increased by 558 basis points since December 31, 2009. Contrary to the impaired loans, the non-accruing coverage improved due to the higher loss rates applied in most classes of the domestic portfolio leading to an increase of allowances by 72.1%, while non-accruing loan balances increased by 51.4% for the year ended December 31, 2010.

The impaired coverage ratio for the foreign segment at December 31, 2010 has decreased by 476 basis points since December 31, 2009, due to the significant increase in impaired balances of EUR 854.6 million, which outpaced the increase in allowance for loan losses of EUR 191.5 million. As already discussed impaired balances increased due to (i) accruing commercial loans of EUR 308.9 million in SEE and (ii) non-accruing commercial balances of EUR 429.8 million in SEE and Turkey. The non-accruing coverage ratio for the foreign segment as at December 31, 2010, decreased by 1,164 basis points since December 31, 2009. This development was mainly due to the significant increase of non-accruing loan balances by EUR 782.0 million, the majority of which includes

commercial loans with significant real estate collateral, which outpaced the increase of allowances of EUR 191.5 million.

All components of our loan allowances have increased during 2010, reflecting an increase in non-accruing loans in all segments and geographical locations where the Group operates.

The most significant increase is noted within the homogeneous allowances, which almost doubled during 2010 from EUR 838.1 million as at December 31, 2009 to EUR 1,451.8 million as at December 31, 2010. This is in line with the significant increase of our retail non-accruing loans during the same period.

Specific allowances increased from EUR 398.2 million as at December 31, 2009 to EUR 564.6 million as at December 31, 2010. This net increase, combined with the write-offs of corporate loans, reflects both the increase of individually assessed customers and the additional allowances on already impaired customers due to the adverse economic conditions.

Coefficient allowances increased from EUR 88.8 million as at December 31, 2009 to EUR 106.4 million as at December 31, 2010, reflecting both the increase of customers provided for using this methodology as well as a slight downgrading of customers to a credit rating requiring higher loan loss allowances.

When the Group determines the amount of allowance for loan losses for our pool of homogeneous loans, loss rates are applied which have been produced by our risk models, which collect historical evidence of recoveries spanning across many years. Our analysis of past data has demonstrated that we collect insignificant amounts from the unsecured portion of our portfolio after a period of four years after the loan agreement is legally terminated. Therefore, for this portion of past due loans a 100% loss allowance is recorded, which represents a full reserve. A write-off may not be made since legal actions may still be pending.

Up to 2009, write-offs had been accelerating and unsecured loans were written off ahead of the maximum period stated in our write-off policy. Moreover, since 2008, in line with our commitment to social awareness and our responsibility for alleviating the impact of the economic crisis to our customers, as well as due to the introduction of legislative actions, like Greek laws 3869/2010 and 3949/2011, for the protection of those facing difficulties in repaying their loans on time, we have postponed legal actions taken against past due customers and modified our write-off policy by extending the maximum period before taking write-offs in our unsecured portfolio beyond three years. The combined effect of the increased write-offs in previous years and the extension of the maximum period before writing off unsecured loans during 2010 led to the significant decrease of write-offs in 2010.

Non-interest Income. Non-interest income decreased by 56.6% to EUR 667.8 million for 2010, compared to EUR 1,539.5 million for 2009. The following table summarizes the principal components of non-interest income during each of the two years ended December 31, 2009 and 2010:

	Year ended December 31,

	2009			2010 As restated⁽¹⁾			2009/2010 Change
	(EUR in thousands)						(%)
Credit card fees		200,939			188,771			(6.1	)
Service charges on deposit accounts		49,005			52,722			7.6
Other fees and commissions		502,140			475,692			(5.3	)
Net trading loss		(267,131	)		(1,245,322	)		366.2
Equity in earnings of investees and realized gains/(losses) on disposals		(27,879	)		9,245			(133.2	)
Income from insurance operations		990,054			1,017,172			2.7
Other		100,736			144,081			43.0

Total non-interest income / (loss) excluding gains / (losses) on investment securities		1,547,864			642,361			(58.5	)

Net realized gains / (losses) on sales of available for sale securities		349,929			114,959			(67.1	)
Other-Than-Temporary-Impairment (of which nil was recognized in OCI)		(358,328	)		(89,497	)		(75.0	)
Net gains / (losses) on available for sale and held to maturity securities		(8,399	)		25,462			(403.2	)

Total non-interest income / (loss)		1,539,465			667,823			(56.6	)

Our net trading losses consist of valuation losses in our bond portfolio and derivative positions. They also include a realized gain of EUR 10.9 million from the buy back of EUR 110.2 million of hybrid securities issued by NBG Funding Ltd. Net trading losses increased to EUR 1,245.3 million in 2010 from EUR 267.1 million in 2009. The increase in income from insurance operations reflects mainly the increase in gross written premia of the motor line of business as a result of the higher penetration in the Greek market.

Non-interest Expense. Non-interest expense increased by 3.1% to EUR 3,812.1 million for 2010, compared to EUR 3,697.4 million for 2009.

Salaries, employee benefits and voluntary early retirement schemes decreased by 2.9% and amounted to EUR 1,511.9 million in 2010 from EUR 1,557.8 million in the same period in 2009,

reflecting the effect of the management's cost-cutting measures which was partially offset by the increase of 13.0% of the salaries and employee benefits in the segment "Turkish operations" due to the opening of 41 new branches in 2010 and additional 1,627 employees. Insurance claims, reserves movement, commissions and reinsurance premia ceded increased in line with the higher production in the motor line of business mentioned above.

Income / (Loss) Before Income Tax Expense. In 2010, the Group reported losses before income tax expense of EUR 265.7 million, a 142.2% decrease as compared to income before income tax expense of EUR 629.9 million in 2009, due principally to higher net trading losses, realized losses on sales of AFS securities, increased provisions made by the Bank and its banking subsidiaries in SEE taken during 2010 in light of deteriorating economic conditions and higher net non-interest expense.

Income Tax (Expense) / Benefit. In 2010, we recognized a current tax expense of EUR 260.2 million and a deferred tax benefit of EUR 217.9 million compared to a current tax expense of EUR 163.7 million and a deferred tax expense of EUR 12.9 million in 2009. Our total income tax expense in 2010 amounted to EUR 42.3 million compared to EUR 176.6 million in 2009. The applicable Greek statutory corporation income tax rate was 24% for 2010 and 25% for 2009. However, in accordance with tax Law 3943/2011, which was enacted in March 2011, the nominal corporation tax rate for the periods commencing from January 1, 2011, was reduced to 20%.

In 2009, in accordance with Law 3845/2010, a non-recurring tax was imposed on legal entities for social responsibility purposes and is calculated on the total net income for the year 2009, provided that it exceeded EUR 100 million. The tax accrued to the Group's 2010 income statement in accordance with this Law, amounted to EUR 26.1 million.

Also, included in tax expense for 2009 is the amount of EUR 47.7 million related to a special tax levy, following the new tax legislation enacted on December 10, 2009 (Law 3808/2009), according to which entities with profits exceeding EUR 5 million in 2008, are required to pay this special tax levy.

Net Income / (Loss) attributable to NBG shareholders. For the reasons discussed above, net losses attributable to NBG shareholders were EUR 354.8 million for 2010, compared with a net income attributable to NBG shareholders of EUR 391.1 million for 2009.

Exchange Rate Exposure. The Group is an active participant in the foreign exchange markets and also grants loans denominated in currencies other than the euro. The Group's goal in managing exchange rate exposure is to minimize the effect of exchange rate fluctuations on profitability. The Group adheres to central Bank guidelines and other guidelines applicable to the Group and actively manages its foreign currency position. To the extent that foreign currency-denominated assets are not matched with liabilities denominated in the same currencies, the Group engages in swaps and other economic hedging transactions in order to reduce the effects of these imbalances. Furthermore, following the Group's expansion to Turkey (through the Finansbank acquisition) the exposure to TL has increased. The Group closely monitors its exposure to the TL arising from the net investment in Finansbank and when necessary it engages in swap and other economic hedging transactions in order to reduce the volatility in the Group's equity arising on the translation of Finansbank's net assets from TL to Euro. As at December 31, 2010, 21.7% of the Group's liabilities and 26.3% of the Group's assets were denominated in currencies other than euro, before taking into account economic hedging transactions. For more information on foreign exchange risk see Item 11, "Quantitative and Qualitative Disclosures About Market Risk".

For a discussion of recently issued accounting pronouncements please refer to Note 3, "Summary of significant accounting policies" to the U.S. GAAP Financial Statements.

We measure the performance of each of our business segments primarily in terms of "profit before tax". Profit before tax and the business segment information of the Group, set forth below, is derived from the internal management reporting system used by management to measure the performance of the business segments. Unlike financial accounting, there is no authoritative body of guidance for management accounting. The business segment information, set forth below, is based on the financial information prepared in accordance with IFRS. Accordingly, the format and information is presented primarily on the basis of IFRS and is not consistent with the consolidated financial statements prepared on the basis of U.S. GAAP. A reconciliation is provided for the total amounts of segments' total
profit / (loss) before tax with income / (loss) before income tax.

Retail banking includes all individual customers, professionals, small-medium and small sized companies (companies with annual turnover of up to EUR 2.5 million). The Bank, through its extended network of branches, offers its retail customers various types of loan, deposit and investment products as well as a wide range of other traditional services and products.

Corporate & Investment banking includes lending to all large and medium-sized companies, shipping finance and investment banking activities. The Group offers its corporate customers a wide range of products and services, including financial and investment advisory services, deposit accounts, loans (denominated in both euro and foreign currency), foreign exchange and trade service activities.

Global Markets and Asset management includes all treasury activities, private banking, asset management (mutual funds and closed end funds), custody services, private equity and brokerage.

The Group offers a wide range of insurance products through its subsidiary company, EH and other subsidiaries in SE Europe and Turkey.

The Group's international banking activities, other than its Turkish operations, include a wide range of traditional commercial banking services, such as commercial and retail credit, trade financing, foreign exchange and taking of deposits. In addition, the Group offers shipping finance, investment banking and brokerage services through certain of its foreign branches and subsidiaries.

The Group's banking activities in Turkey through Finansbank and its subsidiaries include a wide range of traditional commercial banking services, such as commercial and retail credit, trade financing, foreign exchange and taking of deposits.

This category includes proprietary real estate management, hotel and warehousing business, as well as unallocated income and expense of the Group (interest expense of subordinate debt, loans to personnel etc.) and intersegment eliminations.

12-month period ended December 31, 2011	Retail Banking

	(EUR in thousands)
Net interest income		1,203,449		775,789		371,353		62,831		387,197		903,357		138,832		3,842,808
Net fee and commission income		101,398		81,691		(106,766	)	6,935		94,218		313,622		2,751		493,849
Other		(25,192	)	(61,766	)	8,674		178,720		5,824		35,646		(106,603	)	35,303

Total income		1,279,655		795,714		273,261		248,486		487,239		1,252,625		34,980		4,371,960

Direct costs		(687,823	)	(52,153	)	(65,095	)	(135,460	)	(293,350	)	(656,414	)	(249,029	)	(2,139,324	)
Allocated costs and provisions		(1,514,674	)	(2,151,714	)	(10,723,025	)	(633,054	)	(202,164	)	(147,058	)	(282,246	)	(15,653,935	)
Share of profit of associates		—		—		(2,592	)	1,051		1,193		94		1,433		1,179

Profit / (Loss) before tax		(922,842	)	(1,408,153	)	(10,517,451	)	(518,977	)	(7,082	)	449,247		(494,862	)	(13,420,120	)

Segment assets as at December 31, 2011
Segment assets		27,368,430		16,195,725		24,903,725		2,041,287		9,856,192		20,671,864		4,280,798		105,318,021
Tax assets																1,551,968

Total assets																106,869,989

Other Segment items
Depreciation, amortization & impairment charges⁽¹⁾		18,759		1,688		4,848		8,895		36,261		54,593		101,187		226,231
Provision for loans impairment & advances		1,180,171		2,101,421		10,702,049		631,329		200,322		147,058		259,932		15,222,282
Non-current assets additions		5,517		10,805		35,736		3,112		18,872		80,175		66,134		220,351

12-month period ended December 31, 2010	Retail Banking

	(EUR in thousands)
Net interest income		1,368,231		621,918		472,177		54,066		461,836		1,053,634		116,095		4,147,957
Net fee and commission income		127,788		77,841		37,556		8,054		102,260		262,723		(6,297	)	609,925
Other		(25,223	)	(73,770	)	(205,549	)	101,146		28,456		47,939		8,595		(118,406	)

Total income		1,470,796		625,989		304,184		163,266		592,552		1,364,296		118,393		4,639,476

Direct costs		(683,711	)	(53,058	)	(77,823	)	(159,653	)	(300,583	)	(659,239	)	(160,099	)	(2,094,166	)
Allocated costs and provisions		(1,155,003	)	(259,477	)	(60,472	)	(37,603	)	(209,568	)	(144,586	)	(42,569	)	(1,909,278	)
Share of profit of associates		—		—		310		903		1,055		289		(959	)	1,598

Profit / (Loss) before tax		(367,918	)	313,454		166,199		(33,087	)	83,456		560,760		(85,234	)	637,630

Segment assets as at December 31, 2010
Segment assets		30,079,448		18,957,278		29,793,880		3,052,124		10,506,104		20,619,183		7,129,220		120,137,237
Deferred tax assets and Current income tax advance																607,368

Total assets																120,744,605

Other Segment items
Depreciation and amortization⁽¹⁾		19,746		1,291		5,968		9,698		35,483		53,633		101,441		227,260
Credit provisions and other impairment charges		796,593		204,037		39,865		36,987		209,528		144,586		18,731		1,450,327
Non-current assets additions		8,730		13,254		4,093		5,137		52,360		67,704		105,934		257,212

12-month period ended December 31, 2009	Retail Banking

	(EUR in thousands)
Net interest income		1,402,316		536,138		584,022		48,832		488,762		968,856		(62,611	)	3,966,315
Net fee and commission income / (loss)		166,243		72,270		95,488		3,872		94,040		228,546		(71	)	660,388
Other		(26,448	)	(67,169	)	268,099		149,498		17,873		96,860		11,679		450,392

Total income / (loss)		1,542,111		541,239		947,609		202,202		600,675		1,294,262		(51,003	)	5,077,095

Direct costs		(670,025	)	(53,509	)	(79,390	)	(182,192	)	(302,526	)	(523,994	)	(255,232	)	(2,066,868	)
Allocated costs and provisions		(798,813	)	(207,704	)	(190,290	)	(70,431	)	(189,914	)	(250,085	)	(51,042	)	(1,758,279	)
Share of profit of associates		—		—		(1,429	)	560		783		(190	)	393		117

Profit / (loss) before tax		73,273		280,026		676,500		(49,861	)	109,018		519,993		(356,884	)	1,252,065

Segment assets as at December 31, 2009
Segment assets		31,961,306		18,639,070		26,859,396		2,851,745		11,446,389		15,819,570		5,453,008		113,030,484
Tax assets																363,699

Total assets																113,394,183

Other Segment items
Depreciation, amortization & impairment charges⁽¹⁾		20,096		1,021		3,538		9,127		32,688		42,186		104,784		213,440
Provision for loans impairment & advances		442,576		151,257		171,804		69,813		189,914		250,085		28,196		1,303,645
Non- current assets additions		14,814		634		11,741		8,289		62,445		58,782		115,725		272,430

Segment analysis for year ended December 31, 2011 compared to the year ended December 31, 2010 based on IFRS

The Group's overall decrease in loss before tax in 2011 compared to profit before tax in 2010, primarily reflects the impairment of Greek government bonds due to PSI and loans eligible to PSI of EUR 11,783.3 million, the increased losses before tax in retail banking and in corporate & investment banking.

The increase in loss before tax in our retail banking segment is due to lower net interest income and to the increased cost of provisions for loan losses. More specifically, the decrease in total operating income in our retail banking segment by EUR 191.1 million is mainly attributable to a decrease in mortgage lending, consumer lending and products and lending to small-medium and small sized companies of EUR 111.7 million, EUR 72.7 million and EUR 6.8 million, respectively. Moreover, the

Bank continued in 2011 its restructuring efforts relating to mortgages and consumer loans by introducing flexible terms in performing loans, such as interest-only periods, installment ceilings, interest rate caps and extended loan maturities. Additionally, net interest income was negatively affected by the increased rates paid to depositors in 2011 in order to preserve our market share as a result of increased competitive pressures as other domestic banks sought to attract liquidity. Impairment charges for credit losses increased to EUR 1,180.2 million in 2011, from EUR 796.6 million in 2010. This increase was due to the deteriorating credit quality of the loan portfolio as the economic climate in Greece continues to be severely stressed.

The loss before tax in our corporate and investment banking segment of EUR 1,408.2 million in 2011 from profit before tax of EUR 313.5 million in 2010, is mainly attributable to the increased provision for impairment charges for credit losses from EUR 204.0 million in 2010 to EUR 2,101.4 million in 2011, which outpaced the improved results in net interest income from EUR 621.9 million in 2010 to EUR 775.8 million in 2011. The improved results in net interest income reflect the effectiveness of the re-pricing efforts made in the Bank's Greek corporate loan portfolio and especially with respect to large companies. As a result of the ongoing economic crisis in Greece, the Bank retains its conservative approach to new commercial lending, with a greater focus on larger corporate borrowers that it perceives to be lower-risk.

Loss before tax from global markets and assets management operations amounted to EUR 10,517.5 million in 2011, from profit of EUR 166.2 million for the same period in 2010. This decrease was principally due to net interest income which decreased to EUR 371.4 million in 2011, from EUR 472.2 million, mainly as a result of higher cost of funding. Impairment charges for credit losses increased to EUR 10,702.0 million in 2011, from EUR 39.9 million in 2010, reflecting the impairment of the investment securities due to PSI.

Loss before tax from our International banking operations of EUR 7.1 million in 2011, from profit before tax of EUR 83.5 million in 2010, is principally attributed to the net interest income which decreased to EUR 387.2 million in 2011, from EUR 461.8 million, mainly as a result of loan volume contraction and the increase in the volume and cost of deposits in the context of the Group's strategy for independent financing of all its subsidiaries. Impairment charges for credit losses slightly decreased to EUR 200.3 million in 2011, from EUR 209.5 million in 2010, reflecting the first signs of stabilization in our international loan portfolio.

Profit before tax from our Turkish banking operations slightly decreased in 2011, to EUR 449.2 million compared to EUR 560.8 million in 2010, reflecting in part the TL depreciation against the euro between 2010 and 2011. The decrease in net interest income from EUR 1,053.6 million in 2010 to EUR 903.4 million mainly reflects the result of the deposit growth which exceeded the loan expansion and the asset yield pricing gap. Impairment charges for credit losses slightly increased to EUR 147.1 million in 2011, from EUR 144.6 million in 2010, reflecting further improvement in the already high quality of Finansbank's loan portfolio and the growth in the Turkish economy.

The loss before tax in insurance operations increased from EUR 33.1 million in 2010 to EUR 519.0 million in 2011. It mainly reflects the increase in credit provisions and other impairment changes from EUR 37.0 million in 2010 to EUR 631.3 million in 2011, as a result of the impairment of Greek government bonds due to PSI of EUR 532.5 million and the impairment of the equity shares and mutual funds. The improved results in total operating income from EUR 163.3 million in 2010 to EUR 248.5 million in 2011, mainly reflects the improved loss ratio of the motor and life line of business, the exit from the harmful credit line of business, the effective reduction in operating costs through synergies with the Bank and the decrease in costs related to the voluntary retirement scheme from EUR 5.3 million in 2010 to EUR nil in 2011.

The business segment "Other" consists of proprietary real estate management, hotel and warehousing business, other unallocated income and expenses of the Group, intersegment eliminations,

as well as the share of profits or losses of our associate undertakings. The increase in loss before tax in this segment in 2011 to EUR 494.9 million from to EUR 85.2 million in 2010, is mainly attributable to the increase in credit provisions and other impairment changes from EUR 18.7 million in 2010 to EUR 259.9 million in 2011, principally due to the impairment of goodwill of EUR 120.2 million relating mainly to Vojvodjanska, National Securities and NBG Leasing IFN and to provisions for legal cases of EUR 85.4 million. Direct costs increased to EUR 249.0 million from EUR 160.1 million mainly due to the one-off provision of EUR 169.9 million for the employees statutory retirement indemnity. Excluding this one-off provision, the direct cost decreased by 50.6% year on year, which reflects the effectiveness of the cost cutting measures.

Segment analysis for year ended December 31, 2010 compared to the year ended December 31, 2009 based on IFRS

The Group's overall decrease in profit before tax in 2010 compared to the same period in 2009, primarily reflects losses before tax in our retail segment and significantly lower results in global markets & asset management, which were only partially offset by improved performance in corporate & investment banking and Turkish banking operations.

The decrease in profit before tax in our retail banking segment is due to lower interest income and to the increased cost of provisions for loan losses. More specifically, the decrease in total operating income in our retail banking segment of EUR 71.3 million is mainly attributable to a decrease in mortgage lending, consumer lending and products and lending to small-medium and small sized companies of EUR 46.4 million, EUR 16.8 million and EUR 8.1 million, respectively.

During 2010, the Bank's retail banking activity was mainly focused on debt restructurings of mortgages and consumer loans. The restructuring terms included lower payments, extended loan maturities, payment or interest rate caps and skipped payments. Additionally, net interest income was negatively affected by the increased rates paid to depositors during 2010 to preserve our market share as a result of increased competitive pressures as other domestic banks sought to attract liquidity.

Impairment charges for credit losses increased to EUR 796.6 million in 2010 from EUR 442.6 million in 2009, arising mainly from consumer and mortgage lending. This increase was due to the deteriorating credit quality due to adverse economic conditions in Greece.

Improved results in the Bank's corporate and investment banking in 2010, were primarily due to increased net interest income reflecting the effectiveness of the re-pricing efforts in Bank's Greek corporate loan portfolio and especially to large companies, which outpaced the increased provision charges for loan loss allowances. Since March 2010, the Bank has launched restructuring products addressed to medium size corporate and SBL customers, some of which fall under Greek Law 3816/2010 (see Item 4.B, "Business Overview—Settlement of Business and Corporate Debts"). As a result of the ongoing economic crisis in Greece, the Bank has adopted a more conservative approach to new commercial lending, with a greater focus on larger corporate borrowers that it perceives to be lower-risk.

Profit before tax from global markets and assets management operations decreased to EUR 166.2 million in 2010, from EUR 676.5 million in 2009. This decrease was principally due to the adverse result in activities from trading and investment securities, which resulted in losses of EUR 205.5 million in 2010, from gains of EUR 268.1 million in 2009, as well as the decrease in net interest income and net fee and commission income to EUR 509.7 million in 2010, from EUR 679.5 million in 2009, which is mainly attributed to higher cost of funding.

The reduced losses before tax in 2010 in the insurance operations, from losses of EUR 49.9 million in 2009 to losses of EUR 33.1 million in 2010, mainly reflects the increase in gross written premia of the motor line of business as a result of the higher penetration in the Greek market, the decrease in

costs related to the voluntary retirement scheme from EUR 24.6 million in 2009 to EUR 5.3 million in 2010 and the decrease in credit provisions and other impairment changes from EUR 69.8 million in 2009 to EUR 37.0 million in 2010 relating to equity securities and mutual funds.

Profit before tax from our International banking operations decreased to EUR 83.5 million in 2010 from EUR 109.0 million in 2009. This decrease in profit before tax was principally due to decreased net interest income mainly due to loan volume contraction and to a significant increase in provisions amounting to EUR 209.6 million in 2010 compared with EUR 189.9 million in 2009. Net interest income from our International banking operations, as described in Item 4. "Information on the Company—International", decreased for 2010 to EUR 461.8 million from EUR 488.8 million in 2009.

Profit before tax from our Turkish banking operations increased in 2010 to EUR 560.8 million from EUR 520.0 million in 2009 as a result of the increased total operating income, despite the increase in direct costs to EUR 659.2 million in 2010 compared to EUR 524.0 million in 2009. The increase in direct costs by 25.8% is mainly attributed to Finansbank's network expansion program, which brought the number of branches to over 500 by the end of 2010. The increase in net interest income and net fee and commission income is mainly due to the loan portfolio growth. Moreover, net interest income was positively affected by the decreased rates paid for deposits during 2010 as interest rates decreased in 2010 compared to 2009. Impairment charges for credit losses decreased to EUR 144.6 million in 2010 from EUR 250.1 million in 2009, reflecting both the recovery of the Turkish economy and the stabilization of new delinquencies at lower levels as compared to 2009.

The business segment "Other" comprises of proprietary real estate management, hotel and warehousing business, other unallocated income and expenses of the Group, intersegment eliminations, as well as the share of profits or losses of our associate undertakings. The reduction of losses in this segment in 2010 as compared to 2009, is attributable to the increase of net interest income / (expense) from a net interest expense of EUR 62.6 million in 2009 to a net interest income of EUR 116.1 million in 2010 from the corporate treasury operations and the decrease of direct costs from EUR 255.2 million in 2009 to EUR 160.1 million in 2010 reflecting the effectiveness of the cost cutting measures.

Our principal sources of liquidity are our own funds, our deposit base and repurchase agreements with the ECB and central banks, as well as long-term debt, securitizations, covered bonds and credit lines with other banks and our participation in the Hellenic Republic Bank Support Plan in the form of issuance of state guarantee notes. Also, the securities classified as trading or AFS can be sold to satisfy our liquidity requirements. The securities reclassified to the HTM category, consistent with our positive intent and ability to hold them to maturity, are no longer available to raise funds through sale. However, the Bank can still use these securities as collateral in repo transactions with central banks as these transactions are accounted for as secured borrowings and therefore the impact of such reclassifications on our liquidity position is reduced.

The reduced access to interbank and wholesale markets affecting all Greek banks combined with a reduction in domestic deposits has resulted in increased reliance on ECB and central banks repo facilities in 2011. In response to the international financial crisis, the ECB has significantly expanded the scope of its repo facilities both by permitting full allocation of bids, instead of auction process for certain tenors, lengthening tenors and broadening the scope of collateral it accepts. In this context, ECB offers access to short-term and long-term repos, with tenors from one week to three years, respectively.

As at December 31, 2011, ECB funding and funding from other central banks amounted to EUR 31.3 billion. As at December 31, 2010 and 2009, ECB funding and funding from other central banks amounted to EUR 24.2 billion and EUR 11.0 billion, respectively (see Note 18 to the U.S. GAAP Financial Statements for the analysis of instruments pledged).

The following table provides a summary of our interest bearing interbank borrowing activity for each of the three years ended December 31, 2009, 2010 and 2011.

In addition, the Group enters into agreements to repurchase securities sold as a means of collateralized financing with inter-bank counterparties. The following table provides quantification of the average quarterly balance for each of the three years ended December 31, 2009, 2010 and 2011, as well as the period end balance for each of these quarters and the maximum balance at any month-end.

	Year ended December 31,

	2009		2010		2011
	(EUR in thousands)
Average balance Q.1.		2,806,353		7,772,025		4,637,374
Period end balance Q.1.		3,388,670		8,192,043		5,187,643
Maximum balance Q.1.		3,388,670		9,861,416		5,187,643
Average balance Q.2.		3,304,314		5,353,290		3,782,732
Period end balance Q.2.		2,287,075		4,318,192		2,606,337
Maximum balance Q.2.		3,915,039		4,910,773		4,360,673
Average balance Q.3.		4,198,026		4,279,904		2,376,931
Period end balance Q.3.		5,202,192		4,004,623		1,930,242
Maximum balance Q.3.		5,386,574		4,517,778		2,661,253
Average balance Q.4.		5,012,842		3,365,732		2,103,197
Period end balance Q.4.		4,485,440		3,538,289		1,302,239
Maximum balance Q.4.		5,316,094		3,538,289		3,144,079

Operating cash flow provides us with an important source of liquidity. The following table provides a summary of our cash flows for each of the three years ended December 31, 2009, 2010 and 2011.

During 2009, compared to the corresponding period ended on December 31, 2008, our cash outflows in investing activities decreased from EUR 20,104.1 million to EUR 10,089.0 million, mainly due to the decrease in cash flows provided by our AFS and HTM portfolios, which amounted to a net cash outflow of EUR 3,053.2 million during 2009. The relevant cash flows for the period ended on December 31, 2008, resulted to a net cash outflow of EUR 4,471.5 million. Furthermore, net cash outflows from our loan portfolio amounted to EUR 5,523.6 million in the period ended December 31, 2009, while in the corresponding period ended December 31 2008, there was a net cash outflow of EUR 15,200.6 million.

Moreover, during 2009, compared to the corresponding period ended on December 31, 2008, our cash flows from financing activities were reduced by EUR 1,525.6 million, from inflows of EUR 11,883.6 million in 2008 to inflows of EUR 10,358.0 million in 2009, mainly due to the decrease in net inflows from deposits (in 2009 the inflows from deposits amounted to EUR 7,298.2 million while in 2008 the corresponding inflows amounted to EUR 13,655.3 million. In addition, during 2009, there was an inflow from securities sold under agreements to repurchase of EUR 2,728.3 million compared to an outflow of EUR 1,752.4 million in 2008.

During 2010, compared to the corresponding period ended on December 31, 2009, our cash outflows in investing activities decreased from EUR 10,089.0 million to EUR 9,455.2 million, mainly due to the decrease in cash flows provided by our AFS and HTM portfolios, which amounted to a net cash outflow of EUR 2,909.7 million during 2010. The relevant cash flows for the period ended on December 31, 2009, resulted to a net cash outflow of EUR 3,053.2 million. Furthermore, net cash outflows from our loan portfolio amounted to EUR 3,309.3 million in the period ended December 31, 2010, while in the corresponding period ended December 31, 2009, there was a net cash outflow of EUR 5,523.6 million.

Moreover, during 2010, compared to the corresponding period ended on December 31, 2009, our cash flows from financing activities were reduced by EUR 2,236.6 million from inflows of EUR 10,358.0 million in 2009 to inflows of EUR 8,121.5 million in 2010, mainly due to the decrease in net inflows from deposits (in 2010 the inflows from deposits amounted to EUR 6,080.2 million while in 2009 the corresponding inflows amounted to EUR 7,298.2. million. In addition in 2010, there was an outflow from securities sold under agreements to repurchase of EUR 947.2 million compared to an inflow of EUR 2,728.3 million in 2009.

During 2011, compared to the corresponding period ended on December 31, 2010, our cash inflows in investing activities increased from outflows of EUR 9,455.2 million in 2010 to inflows of

EUR 6,302.1 million in 2011, mainly due to the increase in cash flows provided by our AFS and HTM portfolios, which amounted to a net cash inflow of EUR 1,742.4 million during 2011. The relevant cash flows for period ended December 31, 2010, resulted to a net cash outflow of EUR 2,909.7 million. Furthermore, due to the decrease in the credit expansion of the Greek segment, net cash inflows from our loan portfolio amounted to EUR 2,683.0 million in the period ended on December 31, 2011, while in the corresponding period ended on December 31 2010, there was a net cash outflow of EUR 3,309.3 million. Additionally, the net cash inflows from interest bearing deposits with banks amounted to EUR 2,542.3 million in the period ended on December 31, 2011, while in the corresponding period ended December 31 2010, there was a net cash outflow of EUR 3,320.8 million. Generally, the crisis has limited the Bank's access to liquidity from other financial institutions.

Moreover, during 2011, compared to the corresponding period December 31, 2010, our cash flows from financing activities were reduced by EUR 13,731.2 million from inflows of EUR 8,121.5 million in 2010 to outflows of EUR 5,609.7 million in 2011, mainly due to the net outflow of deposits by EUR 2,175.5 million during 2011, as a result primarily of the outflow in Greek deposits, while in 2010 there was a net inflow from deposits of EUR 6,080.2 million. In addition, during 2011, there was an outflow in securities sold under agreements to repurchase of EUR 2,236.1 million compared to the outflow of EUR 947.2 million in 2010.

In 2009 we took measures to strengthen our capital in anticipation of expected changes in Greek capital adequacy requirements as set by the Basel Committee under the Capital Adequacy Directive. In line with our proactive approach to capital management, in June 2009, we completed tender offers for any and all of our outstanding non-cumulative, non-voting preferred securities issued by our wholly owned subsidiary, National Bank of Greece Funding Limited, and guaranteed on a subordinated basis by the Bank. These tender offers created additional Core Tier I capital in the Bank's capital structure and strengthened the quality of our capital base, although overall Tier I capital was reduced.

In addition, in July 2009 the Bank increased its ordinary share capital by issuing new ordinary shares of nominal value of EUR 5.00 each at a subscription price of EUR 11.30 each through a rights issue of 110,367,615 shares, raising EUR 1,247.2 million of which EUR 551.8 million was credited to the "Common stock" account and the remaining amount less expenses incurred was credited to "Additional paid-in capital" account.

On February 18, 2010, the second repeat General Meeting of the Bank's shareholders authorized the Board of Directors to issue bonds convertible into shares, in accordance with the provisions of articles 3a and 13 of the Companies Act and article 5 of the Bank's Articles of Association, for a period of five years, up to an amount corresponding to 50% of the paid-up Common stock of the Bank as at the time of the authorization of this right, i.e. EUR 1,696 million. The Meeting delegated it to the Board of Directors to decide the particular terms and details of such issuance, as well as the procedure by which the bonds would be converted to shares.

In accordance with the above authorizations, the Board of Directors on September 10, 2010, approved the increase of the Bank's ordinary share capital through a rights issue by offering:

In January 2012, we completed tender offers for any and all of our outstanding third series fixed rate covered bonds of EUR 1.5 billion issued by the Bank and due in 2016, which form part of the existing Bank's EUR 10 billion covered bonds program and non-cumulative, non-voting preferred securities issued by our wholly owned subsidiary, National Bank of Greece Funding Limited, and guaranteed on a subordinated basis by the Bank. These tender offers created additional Core Tier I capital in the Bank's capital structure.

For our share capital increase based on Greek Law 3723/2008, see below "—Sources of Capital and Liquidity-Financings under the Hellenic Republic Bank Support Plan—Pillar I Preference share facility".

We are focused on enhancing our capital base, especially in the current economic environment where our ability to manage capital and liquidity faces significant challenges. Accordingly, we continue to explore all capital raising and liability management opportunities that may be available to us in light of market conditions.

The table below sets forth the credit ratings that have currently been assigned to the Bank by Moody's, Standard & Poor's and Fitch.

Any further reductions in the long-term credit ratings of the Bank could delay the Bank's return to the capital and interbank markets for funding, increase our borrowing costs and/or restrict the potential sources of available funding available to the Bank. It could also, coupled with the deterioration of the market conditions, lead to higher spreads on bonds and have an adverse effect on the Bank's ability to use its collateral to secure funding. See also Item 3.D, "Risk Factors—We are currently severely restricted in our ability to obtain funding in the capital markets and are heavily dependent on the ECB for funding and liquidity, which may be affected by changes in the ECB rules relating to the eligibility of collateral such as Greek government bonds and guarantees—Our wholesale borrowing costs and access to liquidity and capital have been negatively affected by a series of recent credit rating downgrades of the Bank and may be negatively affected by further downgrades".

As at December 31, 2011, total assets were EUR 103.5 billion, a decrease of 12.9% from the Group's total assets of EUR 118.7 billion, as at December 31, 2010, which in turn was an 5.0% increase from the Group's total assets of EUR 113.1 billion as at December 31, 2009. Deposits with the central bank were EUR 2.9 billion in 2011, EUR 3.0 billion in 2010 and EUR 2.9 billion in 2009. Securities purchased under agreements to resell were EUR 673.2 million as at December 31, 2011, EUR 146.3 million as at December 31, 2010 and EUR 532.1 million as at December 31, 2009. Interest

bearing deposits with banks were EUR 3.8 billion in 2011, EUR 6.4 billion in 2010 and EUR 3.1 billion in 2009. The Group's securities portfolio was EUR 12.5 billion as at December 31, 2011, EUR 20.1 billion as at December 31, 2010, and EUR 20.2 billion as at December 31, 2009.

The Group's loan portfolio increased from EUR 75.8 billion at December 31, 2009 to EUR 79.0 billion at December 31, 2010 and decreased to EUR 76.0 billion at December 31, 2011. At December 31, 2011, the Group's loan portfolio accounted for 73.4% of total assets. Allowance for loan losses increased from EUR 2.1 billion in 2009 to EUR 3.2 billion in 2010 and to EUR 6.6 billion in 2011. See Item 4.E, "Selected Statistical Data—Assets—Loan Portfolio".

Deposits increased from EUR 87.8 billion on December 31, 2009 to EUR 93.9 billion on December 31, 2010 and decreased to EUR 91.6 billion on December 31, 2011. Of these, interbank funding, including funding from the ECB and central banks, increased from EUR 16.9 billion in 2009 to EUR 26.1 billion in 2010 and to EUR 32.7 billion in 2011.

For further discussion of Liquidity and Capital Resources, including the maturity profile, currency and interest rate structure of debt, see Note 21 and Note 24 to the U.S. GAAP Financial Statements.

Our capital expenditure requirements, excluding interests in other companies, have been principally for upgrading our information technology and other electronic systems and for general plant and equipment. Additionally, capital expenditure cost for 2011 include branch renovation costs, costs relating to establishment of new branches and costs relating to reallocation of existing branches. Capital expenditure for the Group, excluding such interests in other companies, amounted to EUR 283.5 million in 2011. We fund our capital expenditure requirements principally through operating cash flow. Our capital expenditures also include interests acquired in other companies, and amounted to an additional EUR 104.8 million for the year ended December 31, 2011. See Item 4.A, "History and Development of the Company—Acquisitions, Capital Expenditures and Divestitures".

On June 6, 2008, the Board of Directors of the Bank approved the issuance of 25 million non-cumulative non-voting redeemable preference shares, which were offered in the form of ADRs in the United States, at a price of USD 25 per preference share (equivalent to EUR 16.11 on the date of the issuance). The total proceeds of the offering amounted to USD 625 million or EUR 402.6 million. The annual dividend rate is set to USD 2.25 per preference share.

In July 2009, following the Board of Director's resolution of June 18, 2009, the Bank, increased its ordinary share capital by offering 110,367,615 new ordinary shares of nominal value of EUR 5.00 each and at a subscription price of EUR 11.30 each through a rights issue for a total share capital increase of EUR 1,247.2 million. The shares were initially offered to existing ordinary shareholders at a ratio of two new shares for every nine shares held. The new shares were listed on the ATHEX on July 30, 2009.

On February 18, 2010, the second Repeat General Meeting of the Bank's shareholders authorized to the Board of Directors to issue bonds convertible to shares, as per the provisions of articles 3a and 13 of the Companies Act and article 5 of the Bank's Articles of Association, for a period of five years, up to an EUR 1,696 million, representing 50% of the paid-up share capital of the Bank at the time of such assignment. The Meeting authorized the Board of Directors to decide the particular terms and details of such issuance, as well as the procedure by which the bonds will be converted to shares.

On September 10, 2010, following the above authorization and the authorization granted to the Board of Directors by the second Repeat General Meeting of the Bank's Shareholders on May 15,

2008, the Board of Directors approved an increase of the Bank's ordinary share capital through a rights issue by offering:

For the preference shares issued under the Republic Bank Support Plan see section "—Financings under the Hellenic Republic Bank Support Plan".

The Bank, through its VIE, has the following securitized notes in issue as at December 31, 2011:

Issuer	Description	Type of collateral	Issue date	Maturity date			Interest rate

Revolver 2008—1 Plc⁽¹⁾	Secured Floating Rate Notes—Class A	Consumer loans and credit card accounts	December 12, 2008	September 2020	1,000.0	⁽²⁾	Paid monthly at a fixed rate of 2.6% per annum
Revolver 2008—1 Plc⁽¹⁾	Secured Floating Rate Notes—Class B	Consumer loans and credit card accounts	December 12, 2008	September 2020	268.9	⁽²⁾	Paid monthly at a fixed rate of 2.9% per annum
Titlos Plc	Floating Rate Asset Backed Notes	Receivables from Public sector	February 26, 2009	September 2039	5,100.0	⁽³⁾	Paid semi-annually at a rate of six-month Euribor plus 50 bps per annum
Spiti Plc	Asset Backed Floating Rate Notes—Class A	Residential mortgages	September 20, 2011	September 2058	1,500.0	^(2),(5)	Paid semi-annually at a rate of six-month Euribor plus a margin of 400 bps
Spiti Plc	Asset Backed Floating Rate Notes—Class B	Residential mortgages	September 20, 2011	September 2058	249.5	⁽²⁾	Paid semi-annually at a rate of six-month Euribor plus a margin of 700 bps
Autokinito Plc	Asset Backed Floating Rate Notes—Class A	Auto loans	September 23, 2011	September 2023	400.0	^(2),(5)	Paid semi-annually at a rate of six-month Euribor plus a margin of 200 bps

Issuer	Description	Type of collateral	Issue date	Maturity date			Interest rate

Autokinito Plc	Asset Backed Floating Rate Notes—Class B	Auto loans	September 23, 2011	September 2023	96.5	⁽²⁾	Paid semi-annually at a rate of six-month Euribor plus a margin of 350 bps
Agorazo Plc	Asset Backed Floating Rate Notes—Class A	Consumer loans	September 23, 2011	September 2033	1,250.0	^(2),(4)	Paid semi-annually at a rate of six-month Euribor plus a margin of 300 bps
Agorazo Plc	Asset Backed Floating Rate Notes—Class B	Consumer loans	September 23, 2011	September 2033	412.8	⁽²⁾	Paid semi-annually at a rate of six-month Euribor plus a margin of 450 bps

Additionally, in May 2010, the following transaction was unwound with the loans being sold back to the transferor in exchange for the notes:

All of the above notes issued are not presented within "Long-term debt" and the loans are not derecognized as the Bank is the owner of the issued secured notes and primary beneficiary of the above VIEs.

Under the covered bond Programs I and II, the Bank has the following covered bond series in issue as at December 31, 2011:

Program	Series number	Type of collateral	Issue date	Maturity date		Interest rate

Program I⁽¹⁾	Third Series⁽³⁾	Residential mortgage loans	October 7, 2009	October 2016	1,500.0	Paid annually at a fixed coupon rate of 3.875%
Program II⁽²⁾	First Series⁽⁴⁾	Residential mortgage loans	June 24, 2010	June 2015 (with an additional ten-year extension option)	1,500.0	Paid quarterly at the ECB's refinancing rate plus a margin of 170 bps
Program II⁽²⁾	Second Series⁽⁴⁾	Residential mortgage loans	June 24, 2010	June 2017 (with an additional ten-year extension option)	1,500.0	Paid quarterly at the ECB's refinancing rate plus a margin of 200 bps
Program II⁽²⁾	Third Series⁽⁴⁾	Residential mortgage loans	June 24, 2010	June 2019 (with an additional ten-year extension option)	1,500.0	Paid quarterly at the ECB's refinancing rate plus a margin of 230 bps
Program II⁽²⁾	Fourth Series⁽⁶⁾	Residential mortgage loans	November 25, 2010	November 2018 (with an additional ten-year extension option)	1,500.0	Paid quarterly at the ECB's refinancing rate plus a margin of 210 bps
Program II⁽²⁾	Fifth Series⁽⁵⁾	Residential mortgage loans	May 6, 2011	September 2013 (with an additional ten-year extension option)	1,500.0	Paid quarterly at the ECB's refinancing rate plus a margin of 230 bps
Program II⁽²⁾	Sixth Series	Residential mortgage loans	May 6, 2011	September 2014 (with an additional ten-year extension option)	1,300.0	Paid quarterly at the ECB's refinancing rate plus a margin of 250 bps

Other than the third Series of Program I, all the above issues have not been sold to investors, are held by the Bank and therefore are not presented within Note 24.

Furthermore, the Bank, in 2010 and 2011, has cancelled the following issues under the covered bond Program I of EUR 10 billion:

The financial condition of other borrowings as of December 31, 2011, is as follows:

Issuer	Type	Issue date	Maturity date	Currency				Interest rate

Finansbank (via a VIE)	Fixed Rate Notes	March 24, 2006	March 2013	USD	110.0		39.0	Paid semi-annually at a rate of 6.5%
Finansbank (via a VIE)	Series 2005—A Floating Rate Notes (secured on Finansbank's Diversified Payment Rights)	March 15, 2005	March 2012	USD	500.0	⁽¹⁾	55.5	Paid quarterly at a rate of three-month LIBOR plus 180 bps
NBG Finance Plc⁽²⁾	Fixed Rate Notes— Lower Tier II	August 3, 2010	August 2020 (Early redemption 2015)	EUR	450.0		20,0	Paid annually at a rate of 7.0% for the first 5 years and 9.5% thereafter.
NBG Finance Plc	Fixed Rate Notes, guaranteed by the Bank	September 21, 2010⁽³⁾	February 2012	EUR	80.0		—	Paid semi-annual at fixed interest rate of 2.07%
Finansbank	Senior Unsecured Notes	May 11, 2011	May 2016	USD	500.0		3.0	Paid semi-annually at fixed interest rate of 5.5%
Finansbank	Fixed Rate Bonds⁽⁴⁾	November 2, 2011	April 2012	TL	150.0		34.8	Capital amount and the interest at a fixed rate of 10.66% will be paid at maturity in a single payment
Finansbank	Fixed Rate Bonds⁽⁴⁾	November 30, 2011	May 2012	TL	200.0		37.0	Capital amount and the interest at a fixed rate of 10.45% will be paid at maturity in a single payment

Issuer	Type	Issue date	Redemption date	Currency

Bayerische Hypo-und Vereinsbank AG and Bayerische Landesbank	Schuldscheindarlehen loan agreement	August 4, 2008	August 4, 2010	USD	500.0	—
Finansbank (via a VIE)	Fixed Rate Notes	March 24, 2006	March 24, 2011	USD	110.0	(31.12.2010: 50.0	)
NBG Finance Plc	Subordinated Callable Fixed Rate Notes	June 28, 2005	June 20, 2011*	JPY	30,000	—
Finansbank	Credit card secured loan	March 31, 2006	April 13, 2011	TL	300.0	—

On January 22, 2009, the Extraordinary General Meeting of Shareholders approved the share capital increase by EUR 350 million through the issue of 70 million redeemable preference shares of a nominal value of EUR 5.00 each, to be covered by the Hellenic Republic, with the cancellation of existing shareholders' pre-emptive rights, pursuant to the provisions of Greek Law 3723/2008 on the Hellenic Republic liquidity support plan.

On November 26, 2010, at an extraordinary General Meeting of the Bank's Shareholders approved the repurchase by the Bank of the preference shares of a nominal value of EUR 350 million through payment in cash, subject to obtaining Bank of Greece and other statutory approvals.

Furthermore, on December 22, 2011, an extraordinary General Meeting approved a) the share capital increase by EUR 1,000 million through the issue of additional 200 million Redeemable Preference Shares at a nominal value of EUR 5.00 each with the cancellation of the pre-emptive rights of the existing shareholders in favor of the Hellenic Republic, and b) the revocation of the decision of the extraordinary General Meeting held on November 26, 2010. On December 30, 2011, following the above decision, the Bank issued the 200 million Redeemable Preference Shares at a nominal value of EUR 5.00 each. Both issues were fully subscribed by the Hellenic Republic, through the transfer by the latter to the Bank of an equivalent amount of Greek government bonds, in accordance with Greek Law 3723/2008. Please also refer to Item 4.B, "Information on the Company—Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic Bank Support Plan" and Note 33 to the U.S. GAAP Financial Statement.

Under the government-guaranteed borrowings facility, the Bank participated in the second pillar of Greek Law 3723/2008 as follows:

Description					Interest rate

Floating Rate Notes	April 26, 2010	April 2013	2,500.0		Paid quarterly at a rate of three month Euribor plus 1,200 bps per annum⁽²⁾
Floating Rate Notes	May 4, 2010	May 2013	1,345.0	⁽¹⁾	Paid quarterly at a rate of three month Euribor plus 500 bps per annum
Floating Rate Notes	May 4, 2010	May 2013	655.0		Paid quarterly at a rate of three month Euribor plus 1,200 bps per annum⁽²⁾
Floating Rate Notes	June 28, 2010	June 2013	4,265.6		Paid quarterly at a rate of three month Euribor plus 1,200 bps per annum⁽²⁾
Floating Rate Notes	December 23, 2010	December 2013	4,107.7		Paid quarterly at a rate of three month Euribor plus 1,200 bps per annum⁽²⁾
Floating Rate Notes	June 7, 2011	June 2014	1,925.0		Paid quarterly at a rate of three month Euribor plus 1,200bps per annum⁽²⁾

Total			14,798.3

The notes described above are held by the Bank and therefore, are not presented as liabilities on the Consolidated Balance sheet.

Additionally, on June 4, 2009, we issued EUR 500 million of floating rate notes bearing interest at a rate of three month Euribor plus a margin of 0.25%, due in December 2009 that we repaid in December 2009.

On April 12, 2010, the Bank obtained from Public Debt Management Agency, Greek government bonds having a nominal value of EUR 787 million collateralized with shipping and mortgage loans. The bonds are currently rated C by Moody's and B- by Fitch. These bonds can only be used as collateral for financing and therefore are reflected in off-balance sheet items.

On February 24, 2012, the Bank issued EUR 3,000 million Fixed Rate Notes maturing on May 24, 2012, bearing a 13% coupon payable quarterly in arrears. The notes are held by the Bank.

We consider effective risk management to be a key factor in our ability to deliver sustained returns to our shareholders. We allocate substantial resources to upgrading our policies, methods and infrastructure to ensure compliance with best international practices and the guidelines of the Basel Committee for Banking Supervision. For a discussion of management's specific risks, see Item 11, "Quantitative and Qualitative Disclosures About Market Risk".

The Group aims to adopt practices regarding risk management governance, taking into account all relevant guidelines and regulatory requirements, as set by the Basel Committee, the EBA, the Bank of Greece and the HCMC, as well as any decisions of the competent authorities supervising the Group's entities.

The Group's risk governance framework comprises a number of different constituents. In particular, the Board of Directors has established the Risk Management Committee ("RMC") overseeing all risk management functions across the Group. All risk management units report to the NBG GRCAD and to the NBG Group Market and Operational Risk Management Division ("GMORMD"), which are supervised by the Group Risk Manager. A separate compliance function, the Compliance Division, oversees all internal and external compliance matters, such as applicable Greek and EU, laws and regulations, as well as accounting standards. The Internal Audit—Inspection Division ("IAID"), which reports directly to the Board of Directors through the Audit Committee, complements the risk management framework and acts as an independent reviewer, focusing on the effectiveness of the risk management framework and control environment.

The RMC forms and submits for approval to the Board of Directors the risk assumption and capital management strategy of the Bank and the Group, on an annual basis. It also sets the principles and approves the policies that govern the management of risk and monitors the implementation and outcome of these policies. The members of the RMC are the Chairman of the Board of Directors, the Chief Executive Officer (CEO) and two other non-executive members of the Board of Directors. The Committee is chaired by the CEO of the Group. The RMC has the responsibility to review reports and evaluate the overall risk exposure of the Bank and the Group on a regular basis, taking into account the approved strategy and the business plan of the Group. The proposals to the RMC are submitted by the Group Risk Manager. For a further description of the RMC and a list of its current members, see Item 6.C, "Board Practices—Board Committees".

During 2010, the Group, acknowledging the need for enhanced risk management, has split up the GRMD into two specialized units, the NBG GRCAD and the NBG GMORMD, to properly measure, analyze and manage the risks entailed in all its business activities. All risk management units of the Group report to the two aforementioned Divisions.

Both divisions seek to protect the Group against unforeseen losses and to maintain earnings stability through independent identification and assessment of risks. The framework used for the evaluation of different types of risk is based on generally accepted banking practices to produce transparent, objective and consistent risk management information as the basis for organizing the Group structure. Their role in maximizing the Bank's earnings potential involves measuring performance on a risk-adjusted basis and allocating capital accordingly. In addition, they are responsible for providing the RMC with accurate data and analysis required for measuring, monitoring and managing risks and for supporting the implementation of risk management decisions. Group risk management policies are approved by the RMC.

Both divisions guide decision-making processes in their corresponding areas of expertise and responsibility at the Group level, by providing the necessary risk management and related evaluation.

The asset/liability and risk management policy is designed to structure the balance sheet in order to control exposure to liquidity, interest rate and exchange rate risks, as well as to enable the Group to take advantage of market opportunities which may contribute to its profitability.

Although the asset and liability management policies of the Bank and the other subsidiaries in the Group are currently planned and implemented separately, the Bank's Asset and Liability Committee ("ALCO") sets the general guidelines for asset and liability management. ALCO determines the Bank's

strategy and policy as to matters relating to the structuring and management of assets and liabilities taking into account the current market conditions and the risk limits set by the Bank. The Bank's ALCO meets monthly and is comprised of the Chief Executive Officer, the Deputy Chief Executive Officers, General Managers and the Deputy General Manager of the Bank involved in the asset allocation functions. Day-to-day asset and liability management is delegated to the Treasury, which is divided into several operating units. The subsidiaries of the Group follow asset and liability management policies similar to those of the Bank.

Internal Audit in the NBG Group is an independent function, whose objective is to conduct assurance and consulting activities designed to add value and improve operations. It contributes to the achievement of corporate objectives by (a) bringing a systematic, disciplined approach to the evaluation of the effectiveness of risk management, internal controls and corporate governance, (b) recommending appropriate measures to improve their efficiency and effectiveness, and (c) monitoring the implementation of corrective actions.

The IAID of the Bank and the Group is administratively independent from other Bank and Group units. The Chief Audit Executive is assigned or discharged exclusively by the Bank's Board of Directors, on the recommendation of the Audit Committee and the Bank's CEO. Any dismissal or replacement of the Chief Audit Executive is communicated to the Bank of Greece. The Chief Audit executive reports on the IAID's activities directly to the Audit Committee on a regular basis and to the Bank's Board of Directors, through the Audit Committee on a quarterly basis.

According to the IAID's Charter, which has been approved by the Bank's Board of Directors, the IAID is authorized to operate at Group level and to coordinate the activities of the Internal Audit Units ("IAUs") of the Group subsidiaries that maintain their own Internal Audit functions. Since 2010 Bank's IAID has undertaken the Internal Audit activities of key domestic subsidiaries aiming to improve quality of service and achieve economies of scale.

All IAUs across the NBG Group use the same internal audit methodology that has been developed by Bank's IAID and follows the COSO—ERM principles and the International Standards for the Professional Practice of the Internal Auditing of the Institute of Internal Auditors ("IIA").

As at December 31, 2011, the IAID's total audit staff, including the Chief Audit Executive was 118 employees, while total Group IAU's audit staff was 328.

Liquidity risk is defined as the current or prospective risk to earnings and capital arising from the institution's inability to meet its liabilities when they come due without incurring unacceptable losses. It reflects the potential mismatch of payment obligations to incoming payments, taking into account unexpected delays in repayments (term liquidity risk) or unexpectedly high payment outflows (withdrawal/call risk). Liquidity risk involves both the risk of unexpected increases in the cost of funding the portfolio of assets at appropriate maturities and rates, and the risk of being unable to liquidate a position in a timely manner on reasonable terms.

Liquidity risk management seeks to ensure that the liquidity risk of the Group is measured properly and is maintained within acceptable levels and that, even under adverse conditions, the Group has access to funds necessary to cover customer needs, maturing liabilities and capital requirements.

The Bank's executive and senior management have the responsibility for implementing the liquidity risk strategy approved by the RMC and for developing the policies, methodologies and procedures for identifying, measuring, monitoring and controlling liquidity risk, consistent with the nature and complexity of the relevant activities. The Bank's executive and senior management is regularly informed about current liquidity risk exposures ensuring that the Group's liquidity risk profile stays within approved levels.

The ALCO monitors the gap in maturities between assets and liabilities, as well as the Bank's funding requirements, based on various assumptions, including conditions that might have an adverse impact on the Bank's ability to liquidate investments and trading positions and its ability to access the capital markets.

Currently, the Group's principal source of liquidity are own funds, its deposit base and repurchase agreements with the ECB, as well as long-term debt, securitizations, covered bonds, credit lines with other banks and the participation in the Hellenic Republic Bank Support Plan in the form of issuance of state guarantee notes. The Group also derives liquidity from cash generated by operations and disposals of securities and other assets.

The reduced access to inter-bank and wholesale markets affecting all Greek banks combined with a reduction in domestic deposits has resulted in increased reliance on ECB and central banks repo facilities in 2011. In response to the international financial crisis, the ECB has significantly expanded the scope of its repo facilities both by permitting full allocation of bids, instead of auction process for certain tenors, lengthening tenors and broadening the scope of collateral it accepts. In this context,

ECB offers access to short term and long term repos, with tenors from one week to three years, respectively.

As at December 31, 2011, ECB funding and funding from other central banks amounted to EUR 31.3 billion (see Note 18 to the U.S. GAAP Financial Statements for the analysis of instruments pledged). This included funding from the ELA, collateralized with loans that amounted to EUR 4.2 billion.

Interest rate risk in the banking book is the current or prospective risk to earnings (net interest income) and capital due to adverse movements in interest rates affecting the banking book positions. Exposure to interest rate risk in the banking book arises from re-pricing mismatches between assets and liabilities. The Group's banking book consists mainly of loans, interest bearing deposits with banks, securities purchased under agreements to resell, HTM securities, interest bearing deposits, securities sold under agreements to repurchase, other borrowed funds and long-term debt that are measured at amortized cost.

The Group maintains adequate measurement, monitoring and control functions for interest rate risk in the banking book, including:

See also Item 11, "Quantitative and Qualitative Disclosures About Market Risk—Sensitivity Analysis—Interest rate sensitivity analysis".

The following table sets forth the assets and liabilities and shareholders' equity by those denominated in euro and those denominated in other currencies for the Group under U.S. GAAP on December 31, 2009, 2010 and 2011.

	Year ended December 31,

	2009									2010									2011
	EUR			As restated⁽²⁾ Other Currency			Total			EUR			As restated⁽²⁾ Other Currency			Total			EUR			Other Currency			Total
	(in thousands)
Assets:
Cash and due from banks		1,023,498			406,883			1,430,381			753,590			682,567			1,436,157			963,264			754,472			1,717,736
Deposits with central bank		1,871,094			1,050,252			2,921,346			1,950,228			1,011,600			2,961,828			2,337,521			561,477			2,898,998
Securities purchased under agreements to resell		408,162			123,949			532,111			96,496			49,806			146,302			340,689			332,498			673,187
Interest bearing deposits with banks		2,196,035			881,918			3,077,953			5,894,673			504,094			6,398,767			2,886,597			881,027			3,767,624
Trading assets		3,879,871			185,119			4,064,990			2,626,587			158,735			2,785,322			2,254,053			710,035			2,964,088
Derivative assets		1,437,633			342,471			1,780,104			1,184,148			450,122			1,634,270			2,615,310			990,655			3,605,965
Available-for-sale securities, at fair value		12,312,075			3,771,238			16,083,313			9,164,344			4,524,166			13,688,510			5,476,963			3,094,761			8,571,724
Held to maturity securities		99,604			—			99,604			3,577,235			21,050			3,598,285			989,265			12,937			1,002,202
Equity method investments		16,815			8,512			25,327			39,497			10,597			50,094			52,769			6,370			59,139
Loans		59,595,837			16,238,067			75,833,904			59,172,384			19,866,056			79,038,440			56,756,048			19,246,809			76,002,857
Less: Allowance for loan losses		(1,504,888	)		(560,290	)		(2,065,178	)		(2,385,239	)		(790,166	)		(3,175,405	)		(5,807,694	)		(742,941	)		(6,550,635	)

Net loans		58,090,949			15,677,777			73,768,726			56,787,145			19,075,890			75,863,035			50,948,354			18,503,868			69,452,222
Goodwill, software and other intangibles		414,359			3,431,024			3,845,383			439,823			3,519,146			3,958,969			241,496			2,848,360			3,089,856
Premises and equipment net		814,180			380,522			1,194,702			854,186			367,803			1,221,989			938,594			334,861			1,273,455
Accrued interest receivable		751,675			278,560			1,030,235			909,505			286,225			1,195,730			905,425			250,804			1,156,229
Other assets		2,731,561			529,143			3,260,704			3,280,797			511,823			3,792,620			2,838,007			396,803			3,234,810

Total assets		86,047,511			27,067,368			113,114,879			87,558,254			31,173,624			118,731,878			73,788,307			29,678,928			103,467,235

	Year ended December 31,

	2009						2010						2011
	EUR		As restated⁽¹⁾ Other Currency		Total		EUR		As restated⁽¹⁾ Other Currency		Total		EUR			Other Currency		Total
	(in thousands)
Liabilities and Shareholders' Equity:
Total deposits		69,440,522		18,393,889		87,834,411		73,790,905		20,104,576		93,895,481		73,236,341			18,338,961		91,575,302
Securities sold under agreements to repurchase		4,460,522		24,918		4,485,440		2,959,367		578,922		3,538,289		697,983			604,256		1,302,239
Other borrowed funds		24,092		286,692		310,784		375,428		736,235		1,111,663		235,977			689,994		925,971
Accounts payable, accrued expenses and other liabilities		4,303,046		1,210,486		5,513,532		3,341,792		1,766,688		5,108,480		5,482,706			2,386,118		7,868,824
Long-term debt		2,548,897		808,157		3,357,054		3,199,889		606,061		3,805,950		2,228,992			708,379		2,937,371
Insurance reserves		2,286,131		35,242		2,321,373		2,493,785		37,559		2,531,344		2,719,833			41,008		2,760,841

Total liabilities		83,063,210		20,759,384		103,822,594		86,161,166		23,830,041		109,991,207		84,601,832			22,768,716		107,370,548
Non-controlling interests		767,704		331,522		1,099,226		793,440		294,173		1,087,613		42,362			311,987		354,349
Total equity		6,950,449		1,242,610		8,193,059		5,942,708		1,710,350		7,653,058		(5,755,125	)		1,497,463		(4,257,662	)

Total liabilities and equity		90,781,363		22,333,516		113,114,879		92,897,314		25,834,564		118,731,878		78,889,069			24,578,166		103,467,235

The Group actively manages its capital base to ensure that entities in the Group maximize the return to stakeholders through the optimization of the debt and equity balance. The Group takes advantage of contemporary means for raising capital, with the objective to sustain its capital adequacy ratios well above the minimum regulatory levels and at the same time to improve the weighted average cost of capital to the benefit of its shareholders (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece"). In this context, in 2010 the Bank increased its capital by EUR 1.8 billion through cash in order to strengthen its Tier I capital. In this framework, both the calculation of the capital requirements and the dynamic management of the capital base are embedded in the business plan and the annual budgeting processes, in accordance with the capital adequacy targets that have been set in the Group's risk strategy.

Quantitative measures established by regulation to ensure capital adequacy require the Bank to maintain a minimum ratio determined on a risk-weighted basis, of capital (as defined) to assets, certain off-balance sheet items, and the notional credit equivalent arising from the total capital requirements against market risk, of at least 8%. At least half of the required capital must consist of "Tier I" capital (as defined), and the rest of "Tier II" capital (as defined). The framework applicable to Greek banks conforms to EU requirements, in particular the Own Funds, the Solvency Ratio and the Capital Adequacy Directives. However, under the relevant European legislation, supervisory authorities of the member states have some discretion in determining whether to include particular instruments as capital guidelines and to assign different weights, within a prescribed range, to various categories of assets.

The unique events that occurred during 2011, such as the continuation, for a third year in a row, of the crisis in the Greek economy and the impairment losses recognized due to the completion of the PSI (refer to Note 11 to the U.S. GAAP Financial Statements), have adversely impacted the regulatory capital of the Group and the Bank which has been reduced significantly, and there is need for recapitalization. The recapitalization plan for Greek banks forms an integral part of the financial assistance under the Program.

The voting rights of the common shares held by the HFSF will be strictly limited to specific strategic decisions, unless the private participation in the form of common shares is less than a given minimum percentage of the bank's total capital needs (to be defined in a separate law).

On December 31, 2010, the Group had EUR 8,959 million of Tier I capital and EUR 9,311 million of total capital, as calculated in accordance with Basel II. On December 31, 2011, the Group had EUR (2,367) million, of Tier I capital and EUR (1,664) million of total capital, as calculated in accordance with Basel II. By taking into account the amount of EUR 6.9 billion of capital confirmed by the HFSF and the amount of EUR 77 million of capital created from the voluntary tender offer for the acquisition of the preferred securities issued by NBG Funding Ltd and for the EUR 1,500 million Third Series fixed rate covered bonds due in 2016, which completed on January 17, 2012 (see Note 42 to the U.S. GAAP Financial Statements), the Group had on a pro forma basis EUR 4,610 million of Tier I capital and a pro forma basis EUR 5,313 million of total capital.

The following table shows the EU capital adequacy ratios for the Group as at December 31, 2007, 2008, 2009, 2010 and the proforma ratios for the Group and 2011.

In accordance with the Bank of Greece directives (Governor's Act 2630/29.10.2010), the Group's capital base includes different types of eligible own funds, among others: the share capital, the share premium account, the reserves and retained earnings, preferred securities and subordinated debt issues.

At December 31, 2011, the Group's capital adequacy ratio of (2.6%) was below the required minimum of 8% due to the recognition of losses from the Groups' participation in the PSI (see Note 11 to the U.S. GAAP Financial Statements), and to this extent Tier I and Total capital have been calculated before the application of the regulatory limits prescribed in the Bank of Greece Governor's

Act 2630/2010. Specifically, in case of negative regulatory equity the recognition of minority rights as well as Lower Tier I capital and Tier II is prohibited, and certain investments in financial institutions are deducted from Tier I capital.

In the context of actions designed to fortify the Group's capital position, in December 2011 the Bank raised EUR 1 billion through the issuance of redeemable preference shares to the Hellenic Republic, under Pillar I of the Hellenic Republic Bank Support Plan, and in January 2012 completed a tender offer to repurchase all or part of the covered bonds and hybrid securities issued by the Group in the past. This move enabled the Bank to strengthen its Core Tier I and Tier I capital by EUR 302 million and EUR 77 million, respectively. (See "—Liquidity and Capital Resources—Capital Management").

In addition, in its letter to the Bank on April 20, 2012, the HFSF stated that, on April 19, 2012, the Bank of Greece replied to HFSF with the following:

In the same letter to the Bank, HFSF stated that it will participate in the share capital increase or in the issuance of a convertible bond by the Bank up to the amount of EUR 6.9 billion. Furthermore, the HFSF stated that it will cover any amount of unsubscribed share capital and/or the convertible bonds, and that this commitment is valid until September 30, 2012.

We have not engaged in any significant research and development activities during any of the last three financial years.

Our performance has been and will continue to be influenced by the difficult economic conditions in Greece.

The successful completion of the PSI in April 2012, in conjunction with the activation of the Program for Greece for the period 2012-2015, could provide more time for economic policy to implement fiscal adjustment efforts and growth-enhancing structural reforms. At the same time, the PSI implies a significant decline of the Greek debt burden, as well as, a sharp reduction in debt servicing needs through low interest rates and a substantial extension of the average debt maturity. The Program, which also includes a comprehensive strategy for banking system recapitalization following PSI-related losses, as well as in connection with the detrimental impact of a prolonged recession on bank loan quality, is expected to lay the ground for a more stable and growth friendly financial environment.

Nevertheless, the Greek economy continues to face unprecedented macroeconomic headwinds, originating from the still sizeable fiscal imbalances, which were compounded by other deep-rooted structural vulnerabilities. Recessionary pressures are far more dense and prolonged than initially projected taking a heavy toll on fiscal adjustment effort both on the revenue and expenditure sides, while the deterioration in labor market conditions is unprecedented (unemployment rate of 20.7% in the fourth quarter of 2011) and is likely to suppress further domestic demand through an adverse feedback between austerity, wage adjustment and the decline in activity.

The quasi-coercive nature of the PSI in conjunction with the still high level of Greek sovereign debt post-PSI (above 120% until 2019), and the substantial effort needed to ensure fiscal sustainability of the country render a rapid improvement of market sentiment and a significant upward revision of sovereign ratings of the country highly unlikely for the near-to-medium-term. Poor market valuations of new Greek government bonds, aside from very limited market liquidity, also reflect an embedded eurozone exit-risk premium for Greece, which could take a lot of time and effort to subside. According to the IMF, Greece has little if any margin to absorb additional adverse shocks or slippages in the implementation of the Program. In the event that policy implementation takes longer or falls short, the economy takes longer to respond to labor market and other structural-competitiveness enhancing reforms, or the fiscal impact of recession is higher than estimated, a higher debt trajectory than that suggested by the post-PSI analysis underlying the Program would result.

Political risks linked to the parliamentary elections of May 6, 2012 create additional uncertainty about policy implementation (the Troika has already sought political assurances from large political parties to ensure continuity in policy implementation). Nonetheless, potential delays in the formation of a new Government post elections, as well as a weak parliamentary majority of the parties supporting the Program versus others that are opposed to IMF/EU support could pose additional risks to the implementation of the Program.

Additionally, these conditions have exerted, and may continue to exert, downward pressure on asset prices and on availability and cost of credit for financial institutions, including the Group, and will continue to impact the credit quality of the Group's customers and counterparties. These conditions, alone or in combination with regulatory changes or actions of other market participants, may cause the Group to incur losses or to experience further reductions in business activity, increased funding costs and funding pressures, lower share prices, decreased asset values, additional write downs and impairment charges and lower profitability.

Regarding 2012, the continuing fall in private sector's disposable income and still high fiscal imbalances will continue to erode the domestic deposit base although, in the event of a reduction of uncertainty, the pace of bank deposits contraction is likely to slow through the containment of deposit flight abroad and the reduction of cash hoarded domestically but outside the banking system.

As at December 31, 2011, the Group's domestic deposits excluding interbank deposits were 17,7% lower compared with December 31, 2010 and 27.1% lower compared with December 31, 2009 due to the outflow of customer deposits during 2010 and 2011. The trend of outflowing domestic deposits has continued in 2012, in line with market outflows as reported by the Bank of Greece, for the two months period to February 2012.

Non-accruing loans represented 15.1% of our loans portfolio as at December 31, 2011 (compared to 8.1% as at December 31, 2010), of which 75.0% were loans to borrowers in Greece. The effect of the economic crisis in Greece and adverse macroeconomic conditions in the countries in which we

operate may result in further adverse effects on the credit quality of our borrowers, with increasing delinquencies and defaults.

Turkish operations through Finansbank, our Turkish subsidiary, represented 19.4% of our gross loans as at December 31, 2011 (compared to 18.9% as at December 31, 2010). Such loans accounted for 30.3% of net interest income before provisions for loan losses and contributed a net income of EUR 375.9 million to our net loss for the year ended December 31, 2011 (compared to 31.9% and EUR 454.5 million, respectively, for the year ended December 31, 2010).

Additionally, we have built up substantial operations in Bulgaria, Romania, FYROM, Serbia and other developing economies. The Group's SEE operations accounted for 10.4% of our gross loans as at December 31, 2011 (compared to 10.7% as at December 31, 2010) and 11.1% of our net interest income before provisions for loan losses as at and for the year ended December 31, 2011 (compared to 11.4% for the year ended December 31, 2010). The economic crisis in Greece may materially adversely affect the operations of our SEE subsidiaries and Turkey, increase depositors' concerns in these countries regarding the creditworthiness of the Hellenic Republic and the Bank, which may, in turn, affect their willingness to continue to do business with our international subsidiaries and result in local governmental intervention.

As a result of the prevailing uncertainty, our ability to foresee the market conditions is significantly restricted, and therefore long-term targets are not expected to be reliable.

In the normal course of business, the Group enters into a number of contractual commitments on behalf of its customers and is a party to financial instruments with off-balance sheet risk to meet the financing needs of its customers. These contractual commitments consist of commitments to extend credit, commercial letters of credit and standby letters of credit and guarantees. Commitments to extend credit are agreements to lend to a customer as long as there is no violation of the conditions established in the contract. Commercial letters of credit ensure payment by a bank to a third party for a customer's foreign or domestic trade transactions, generally to finance a commercial contract for the shipment of goods. Standby letters of credit and financial guarantees are conditional commitments issued by the Group to guarantee the performance of a customer to a third party (see Note 25 to the U.S. GAAP Financial Statements). All of these arrangements are related to the normal lending activities of the Group.

The Group's exposure to credit loss in the event of non-performance by the other party to the financial instrument for commitments to extend credit and commercial and standby letters of credit is represented by the contractual notional amount of those instruments. The Group uses the same credit policies in making commitments and conditional obligations as it does for on-balance sheet instruments, policy discussed in more detail on Note 3 to the U.S. GAAP Financial Statements.

The following tables summarize the Group's off-balance-sheet financial instruments, whose contract amounts represent credit risk, as of December 31, 2010 and 2011:

Our contractual obligations as at December 31, 2011, can be summarized as follows:

See "Special Note Regarding Forward-Looking Statements" in the introduction to this Annual Report.

The Bank is managed by the Board of Directors, which is responsible for ensuring strategic direction, management supervision and adequate control of the Bank, with the ultimate goal of increasing the long-term value of the Bank and protecting the corporate interest at large, in compliance with the provisions of the law.

The members of the Board of Directors are elected by the Bank's General Meeting of Shareholders for a three-year term that can be extended until the Annual General Meeting of Shareholders of the year during which the three-year term ends. All members can be re-elected.

The Bank's General Meeting of Shareholders determines each time the exact number of the members of the Board of Directors and elects its independent non-executive members. The Board of Directors consists of a minimum of nine to a maximum of 16 members. The sixteenth member is filled by the representative of the Greek government, as per article 1 para. 3 of Greek Law 3723/2008 (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic's Bank Support Plan"). The Articles of Association and the Corporate Governance Code specifically define the minimum number of executive, as well as independent and non-executive directors (see Item 10.B, "Additional information—Memorandum and Articles of Association" and Item 16E, "Purchases of equity securities by the issuer and affiliated purchasers").

The General Meeting of Shareholders may, at any time, discharge the members of the Board of Directors. In the event that as a result of resignation, death or forfeiture for whatever reason a Director ceases to be on the Board of Directors, and his replacement by substitute Directors elected by the General Meeting is not feasible, the remaining Directors may either provisionally elect another Director to fill the vacancy for the remaining term of office of the Director replaced, or continue to manage and represent the Bank without replacing the missing Director(s), provided that the number of the remaining Directors shall be at least nine. In the event that a new Director is provisionally elected, the election announced by the Board of Directors at the next General Meeting, which may replace the Directors elected even if no relevant item is included in the agenda. Under all circumstances, the remaining Directors, irrespective of number, may call a General Meeting solely for electing a new Board of Directors.

The Board of Directors elects by absolute majority, from its members, the Chairman and the Chief Executive Officer, who manages the Bank. Moreover, the Board of Directors may elect Vice Chairmen and Deputy Chief Executive Officers. The Chairman and the Chief Executive Officer may be the same person, and the same applies for the Vice Chairmen and the Deputy Chief Executive Officers.

The Board of Directors is constituted into a body at its first meeting following each election of Directors by the General Meeting, as well as under any circumstances when the Chairman's or the Chief Executive Officer's post is vacated for whatever reason. Until the Board of Directors elects a new Chairman or Chief Executive Officer, the relevant duties are exercised by the substitute thereof.

The Board of Directors is convened by the Chairman, by means of an invitation to the Directors at least two business days prior to the meeting. The invitation must clearly specify the items on the agenda, otherwise resolutions may not be adopted at the meeting unless all Directors are present or being represented and no Director objects to resolutions being adopted. Moreover, at the request of two Directors, to be filed with the Chairman or his substitute, the Chairman or his substitute must call a Board of Directors meeting to convene within seven days as of the date the request was filed.

The Board of Directors forms a quorum and validly deliberates when one half plus one of the Directors is present or being represented, but under no circumstances may the number of Directors present in person be less than five. The Articles of Association describes in detail the requirements for Directors' representations for valid resolutions adoption.

The Board of Directors represents the Bank in court and out of court and may delegate its powers and functions, in all or in part, including the right of representation, to the Chief Executive Officer, one or more of its executive members, the Bank's General Managers, Deputy General Managers, Managers, employees and third parties in general, by virtue of a Board of Directors resolution, which determines the matters in respect of which, the said powers and functions are delegated. Excluded are any such matters which may require collective action by the Board of Directors.

The Bank is bound in its transactions by the signature of either one or two authorized signatories. The Board of Directors may validly grant sole signature authorization only to the Chief Executive Officer, the Deputy Chief Executive Officers and the General Managers of the Bank.

The Bank's Board of Directors is supported by competent Committees, which have been established and operate for this purpose (see Item 6.C, "Board Practices—Board Committees").

The nomination procedure and the qualification criteria for Directors are subject to specific rules that have been established by the Bank's Articles of Association, the Corporate Governance Code and the Directors' Nomination Policy. Each nominee fulfills such criteria that ensure the appropriate governance and guidance of the Bank's strategy in relation to economic, business and policy issues.

In discharging their nomination responsibilities and proposals to the General Meeting of Shareholders, the Board of Directors pursues to propose candidates to be appointed as Directors to the Board of Directors or replace members of the Board of Directors that have submitted their resignation, whose nomination ensures that the Board of Directors as a collective body presents the following profile:

Evaluation of the Chief Executive Officer, the Board of Directors and the Board Committees

The performance of the Bank's Chief Executive Officer and the executive members of the Board of Directors is evaluated, on an annual basis, by the non-executive members of the Board of Directors in accordance with specific procedures that are described in detail in the Corporate Governance Code. Furthermore, on an annual basis, the Board of Directors conducts an annual effectiveness evaluation of its operations and its Committees' operations, on the basis of a methodology developed and approved by the Corporate Governance and Nominations Committee. Every three years, the evaluation is carried out more profoundly by an outside consultant whose selection and oversight are the responsibility of the Corporate Governance and Nominations Committee.

The Board of Directors develops a proposal on the remuneration of its members for the services they provide, which is submitted to the General Meeting of Shareholders. This proposal is developed according to the Bank's Remuneration Policy as well as industry best practices, in a way that adequately reflects the time and effort they are expected to contribute to the work of the Board of Directors, while at the same time promoting efficiency of the Board of Directors. Regarding, specifically, the executive members of the Board of Directors, the Bank has adopted a Policy for the determination of their remuneration within the broader context of determining senior executives' remuneration so as to promote meritocracy and create a performance based mentality. The Bank's Remuneration Policy was adopted by the Board of Directors on September 30, 2010, following the recommendation of the Human Resources and Remuneration Committee. The Policy is in accordance with the Management Act no. 7 on June 9, 2010 of the Department for the Supervision of Credit and Financial Institutions of the Bank of Greece, the recommendations of European statutory bodies and the international best practices.

The Bank informs the Board of Directors about current corporate governance, risk management, compliance, financial and accounting issues. For the new Directors, the Bank provides a comprehensive briefing about, among others, the structure and operations of the Bank, as well as the rights and obligations of Directors.

The current Board of Directors, whose term expires in 2013, was elected by the extraordinary General Meeting of Shareholders on January 14, 2010, with the exception of Mr. Alexandros N. Makridis who was appointed on February 26, 2009 as the representative of the Greek government as per Greek Law 3723/2008, and Mr. Avraam I. Triantafyllidis who was appointed on March 18, 2010 in replacement of Mr. Alexandros G. Stavrou. Further, the extraordinary General Meeting of Shareholders held on November 26, 2010 elected three executive members, Messrs. Alexandros G. Tourkolias, Anthimos C. Thomopoulos and Leonidas T. Theoklitos, who during the Board of Directors meeting which followed were elected Deputy Chief Executive Officers. On November 23, 2010, Ms. Maria (Marily) A. Frangista was elected a Director in replacement of Ms. Maria S. Sklavenitou. Her appointment was announced in the extraordinary General Meeting of Shareholders held on November 26, 2010. On the April 14, 2011, Mr. Spyridon J. Theodoropoulos was appointed in replacement of the late Vassilios Konstantakopoulos.

Specifically, the Bank's Board of Directors is comprised of the following members:

Board of Directors of the Bank

Name	Position in Board	Election Date	End of Term	Profession
Vassilios T. Rapanos	Chairman (Non-executive Member)	January 14, 2010	2013	Chairman of the Board, Professor, University of Athens
Executive members
Apostolos S. Tamvakakis	Chief Executive Officer (Executive Member)	January 14, 2010	2013	Chief Executive Officer
Alexandros G. Tourkolias	Member	November 26, 2010	2013	Deputy Chief Executive Officer
Anthimos C. Thomopoulos	Member	November 26, 2010	2013	Deputy Chief Executive Officer
Leonidas T. Theoklitos	Member	November 26, 2010	2013	Deputy Chief Executive Officer
Non-executive members
Ioannis C. Giannidis	Member	January 14, 2010	2013	Professor, University of Athens Law School, and Legal Counselor
Ioannis P. Panagopoulos	Member	January 14, 2010	2013	Employee Representative, Chairman of the Greek General Confederation of Labor
Avraam J. Triantafyllidis	Member	March 18, 2010	2013	Employee Representative

Board of Directors of the Bank

Name	Position in Board	Election Date	End of Term	Profession
Independent non-executive members
H.E. the Metropolitan of Ioannina Theoklitos	Member	January 14, 2010	2013	Bishop of the Greek Orthodox Church, Ioannina prefecture
Stefanos C. Vavalidis	Member	January 14, 2010	2013	Former Member of the Board of Directors, European Bank for Reconstruction & Development,
Georgios P. Zanias	Member	January 14, 2010	2013	Economist, Professor of Economics, Chairman of the Board of SOE
Alexandra T. Papalexopoulou-Benopoulou	Member	January 14, 2010	2013	Member of the Board of Directors, TITAN Cement S.A.
Petros K. Sabatacakis	Member	January 14, 2010	2013	Economist
Maria (Marily) A. Frangista	Member	November 23, 2010	2013	Chief Executive Officer of Franco Compania Naviera S.A.
Spyridon J. Theodoropoulos	Member	April 14, 2011	2013	Chief Executive Officer, Chipita S.A.
Greek Government Representative
Alexandros N. Makridis	Member	February 26, 2009	2013*	Chairman of the Board & Chief Executive Officer of Chrysafidis S.A.
Board and Board Committees' Secretary
Martha A. Pylioti		July 29, 2010		Attorney, LLM, NBG Legal Services Division

Pursuant to the Bank's participation in the support plan for the liquidity of the Greek economy as per Greek Law 3723/2008, the Greek government has the right to participate in the Board of Directors through the appointment of a representative, who has veto power on strategic decisions or decisions resulting to a significant change in legal or financial position of the Bank and for which the shareholders approval is required. The same veto power applies to corporate decisions relating to the Chairman, Chief Executive Officer and the other members of the Board of Directors as well as the General Managers' and the alternate General Managers' compensation, and dividend distribution. However, the State appointed representative may only utilize its veto power following a decision of the Minister of Finance or if he considers that the relevant corporate decisions may jeopardize the interests of depositors or materially affect the solvency and effective operation of the participating bank. Moreover, the State appointed representative has full access in the bank's books, on reports for restructuring and viability, medium term funding needs of the Bank as well as on reports for the level

of financing of the Greek economy. See Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic's Bank Support Plan".

The Greek government may be able to exercise a greater level of control in the future, following our recapitalization by the HFSF. See Item 4.B, "Business Overview—The macroeconomic environment in Greece—The Hellenic Republic's economic crisis, the successful sovereign debt restructuring (PSI) and the agreement on the Program for Greece—Recapitalization Framework".

Below are the curricula vitae of the Chairman, Chief Executive Officer and Deputy Chief Executive Officers, as well as those of the principal managers of various business lines of the Bank.

Vassilios Rapanos, born 1947, was appointed Non Executive Chairman of the Board of Directors of the National Bank of Greece and Chairman of the Hellenic Bank Association in December 2009. He holds a Bachelor's degree in Business Administration from the Athens University of Economics and Business, a Master's degree in Economics from Lakehead University in Canada and a PhD in Economics from Queen's University in Canada. Mr. Rapanos has been actively involved in research in the field of Economics, not only as a Researcher at the Center of Planning and Economic Research, but also as a Professor at the University of Athens, where he has been teaching Economic Analysis and Public Economics since 1992. His research interests focus on taxation, the role of the government in the economy, as well as EU Economics. In addition to his academic and research activity, he has also served in several posts; as Counselor at the Ministry of Economy and Finance, as Counselor to the Permanent Greek Delegation to the EU, and as Deputy Head of the Greek Delegation to the OECD. For the period 2007-2009, he was Research Associate at the Foundation for Economic & Industrial Research, of which he is still a member of the Board. During the years 2000-2004, he was Chairman of the Council of Economic Advisors at the Ministry of Economy and Finance. Moreover, during the period 1998-2000 he served as Chairman of the Board of the Hellenic Telecommunications Organization, and in the years 1995-1998 he was initially Deputy Governor and later Governor of the National Mortgage Bank of Greece. He was also member of the Board of Directors of the National Bank of Greece from 1997 to 2004.

Apostolos Tamvakakis, born 1957, was appointed Chief Executive Officer of the NBG Group in December 2009. In March 2009, he joined the management team of Latsis Group in Geneva as Head of Strategy and Business Development of the Group, whereas in 2004 he was appointed Executive Chairman & Managing Director at LAMDA Development. From 1998 to 2004 he served as Vice Chairman at the National Bank of Greece, whereas during the years 1996-1998 he served as Deputy Governor at the National Mortgage Bank. From 1989 to 1996 he was Deputy General Manager for Greece at ABN AMRO Bank and from 1986 to 1989 he worked at the Hellenic Investment Bank as Manager of the Corporate Finance. From 1984 to 1986 he worked at Mobil Oil Hellas as strategic planning Executive. He has also served as Vice-President of Hellenic Exchanges SA (HELEX); Chairman of the Steering Committee of the Interalpha Group of Banks; Chairman of Ethnocard (National Management & Organization Co), National Securities S.A. and ETEVA (National Investment Bank for Industrial Development); President of the Southeastern European Board of the Europay Mastercard group; and a member of various other boards and committees. Today he is Chairman of the Board of Directors of Astir Palace Vouliagmenis S.A. and member of the Boards of Directors of American Hellenic Chamber of Commerce, Foundation for the Support of the Ecumenical Patriarchate and Holy Patriarchal and Stavropegic Monastery of St Anastasia the Farmakolytria in Chalkidiki. He is also member of the General Council of the Hellenic Federation of Enterprises, member of the Steering Committee of Inter Alpha Group of Banks and member of the Institut International d'Etudes

Bancaires. He holds a Bachelor's degree in Economics from the University of Athens, and a Master of Arts in Econometrics from Saskatchewan University in Canada.

Alexandros Tourkolias, born 1946, was appointed Deputy CEO of National Bank of Greece and executive member of the Board of Directors in November 2010. From 2006, he became a member of the NBG Executive Committee, in combination with his duties as a General Manager of Corporate and Investment Banking, where he was responsible since 2004. He also has the responsibility of the Group's wholesale banking activities, brokerage, private equity and private banking. Before joining the bank in 1997 as Head of Shipping, he worked for Bank of America in London and Piraeus for twelve years. He then joined Bank of Nova Scotia in 1988 as Deputy General Manager for Greece. He is the Chairman of the Board of Directors of NBG Cyprus, Vice Chairman of the Board of Directors of EH and a Director of UBB and NBG International Ltd. He holds a BSc in Political Sciences and Public Administration from Pantios School, a BSc in Law from the University of Athens, a Postgraduate Diploma in Shipping Administration Management and Marine Insurance and Maritime Law and a Master's degree in Shipping Economics from the University of Wales in Great Britain. He is President of the Association of Banking and Financial Executives of Hellenic Shipping, member o f the Piraeus Maritime Arbitration Committee and member of the Board of Directors of the HELEX. He also participates in committees of the Hellenic Bank Association.

Anthimos Thomopoulos, born 1961, was appointed Deputy Chief Executive Officer of National Bank of Greece in November 2010. He is a member of the NBG Executive Committee. He joined the Bank in 1998 as Group Risk Director after serving as a managing partner of KPMG Greece. He is Chairman of NBG Asset Management and NBGB and Director of EH, SABA, UBB, Finansbank A.S., the HDIGF, AEDAK Insurance Organization, and Wind. He holds a BSc in Electrical Engineering and postgraduate degrees in Finance and Computer Science. He is a qualified Chartered Accountant with the Institute of Chartered Accountants in England and Wales and a CFA charter holder.

Leonidas Theoklitos, born 1961, was appointed Deputy CEO and a member of the NBG Board of Directors, in November 2010. He is a member of the NBG Executive Committee and he has served as Group Chief Operating Officer from August 2010. In March 2010 he was appointed Chairman of the Board at EH. He also serves as Vice Chairman and Managing Director of Astir Palace Vouliagmenis S.A. and as Chairman of NBG Pangaea. From 2005 to 2006 he served as Advisor to the Administration at EFG Eurobank, whereas during the years 2000-2004 he was appointed Executive Vice-President at TT Hellenic Postbank and Chairman at TT Hellenic Postbank-Hellenic Post AEDAK (TT ELTA AEDAK). From 1998 to 1999 he served as Chief Executive Officer at the Bank of Central Greece and during the years 1994-1998 he was Deputy General Manager at Egnatia Bank. He started his career at National Investment Bank for Industrial Development (ETEBA S.A.) (1986-1994). He has also served as a member of the Executive Committee of Hellenic Bank Association and also as a board member at HELEX, Attica Bank S.A., National Investment Co SA (ETHNEX), Eurobank Properties S.A., Egnatia Finance S.A., Egnatia AEDAK, Anelixis Commercial S.A. and Sklavenitis J.&S. S.A. He holds Bachelor's degrees in Chemical Engineering from the National Technical University of Athens and in Business Administration from the Athens University of Economics and Business, and also a Master in Business Administration (MBA) from the Imperial College, University of London.

Dr. Ömer A. Aras, born 1954, is Chairman and Executive Member of Finansbank A.S. and Chief Executive Officer of Finansbank Group. He is a member of the NBG Executive Committee. Dr. Aras graduated from the Academy of Economic and Commercial Sciences, Department of Economics, in 1975. He received an MBA in 1978 and a PhD in Business Administration in 1981 from Syracuse University. Over the next three years, he was a faculty member at the Business Administration Department of Ohio State University, and worked as a consultant. Between 1984 and 1987, he served as Credit Marketing Manager and Credit Committee Member at Citibank, and worked as the Head of Yapi Kredi Securities. Dr. Aras participated in the founding of Finansbank in 1987, and served as an Assistant General Manager for two years and as the General Manager for six years and as an Executive Board Member of Finansbank and Vice Chairman of Fiba Holding from 1989 to 2006. Between 2003 and 2007 he held the Board Member position in TUSIAD (Turkish Industrialists' Businessmen's Association). Dr. Aras served as Vice Chairman of Finansbank A.S. and Group CEO of Finansbank Group of Financial Companies (Finans Leasing, Finans Invest and Finans Portfolio Asset Management) between November 2006 and April 2010. Dr. Aras was appointed as Chairman of the Board of Directors in April 2010.

Yannis Katsouridis, born 1967, has been the Chief Executive Officer of EH, since November 2010. Before taking this position, Mr. Katsouridis was Chairman of the Board and C.E.O. of National Securities S.A. from 2003 to 2007. Mr. Katsouridis holds a B.A. (Economics) from the University of Athens and an MSc in Money, Banking and Finance from University of Birmingham. Mr. Katsouridis is Chairman of the Board of Garanta, National Insurance Brokers S.A., Ethniki Insurance (Cyprus) Ltd and Ethniki General Insurance (Cyprus) Ltd, Vice- President of the Board of Directors of Finans Life & Pensions Turkey and member of the Board of Directors of Petros Petropoulos S.A.

Marinos Vathis, born 1957, has been the President of the Executive Board of Vojvodjanska Banka since May 2010. He started his career in banking in 1986 with Midland Bank/HSBC in Corporate and Investment Banking. From 1997 to 2002, he served in several managerial positions with Egnatia Bank S.A., initially as Head of Corporate Banking and later as Head of Consumer and Retail Banking. In 2002, he joined National Bank of Greece S.A. and served as General Manager of French operations until 2005 and as General Manager of the UK operations from 2005 to 2007. Between 2007 and 2010, he served as Director of the NBG Group, International Corporate. He holds a BA from the City of London Polytechnic, a Postgraduate Degree in Monetary Economics from Kent University and a Postgraduate Degree in Business Finance from Reading University. Between 2005 and 2010, he served as a Board Member in the Association of European Banks in the UK, representing Greece.

Stilian Vatev, born 1956, is the Chief Executive Officer and a member of the Board of Directors of UBB. He joined UBB in 1993 after serving in several managerial positions at the National Bank of Bulgaria. He is also a member of the Board of Directors of Interlease AD, Interlease Auto AD, UBB Asset Management AD, UBB Insurance Broker EOOD and Bankservice Borika AD. Mr. Vatev is the Chairman of the Management Boards of UBB - ALICO Life Insurance Company AD and UBB—Chartis Insurance Company AD and is a member of the SEE Regional Advisory Board of MasterCard—Europe and Plenary Member of the European Payment Council . Mr. Vatev holds an MA in Finance and Credit from the University for National and World Economy, Sofia, Bulgaria and has attended several banking related programs in the United Kingdom, Switzerland and Japan.

Gligor Bishev, born 1958, has been the Chief Executive Officer and Chairman of the Board of Directors of Stopanska Banka AD. He joined Stopanska Banka in 2000 after serving as Deputy Governor of the National Bank of Republic of Macedonia. Mr. Bishev is an Associate Professor of Graduate and Postgraduate Studies at the Faculty of Economics—Prilep, and Professor of Post-Graduate Studies at the Faculty of Economics—Skopje. He is also a member of the Business Council of the Faculty of Economics—Ljubljana since 2008. He advised on recent monetary reforms in

Republic of Macedonia as well as in several research projects in banking, monetary policy, applied economics, and economic development. He holds a PhD in Economics from the Faculty of Economics—Skopje and has attended various seminars and training courses in Austria, the United Kingdom and Switzerland.

Nicholas Th. Beis, born 1952, is the Managing Director of National Bank of Greece (Cyprus) since April 2010 and a member of the Board of Directors since March 2010. During his career, he has held several managerial positions like General Manager and Executive Board Member at Emporiki Bank S.A., General Manager at Piraeus Bank S.A., Corporate Manager at ABN AMRO Bank NV, Athens and Relationship Manager at Barclays Bank PLC, Athens. Nicholas Beis holds a Bachelor in Economics from Kapodistriakon Athens, University, a Bachelor of Science in Business Economics from New York Institute of Technology and a Master of Arts in Quantitative Economics from New York University, New York, USA.

Marinis S. Stratopoulos, born 1964, has been appointed the Chief Executive Officer and Deputy Chairman of the Board of Directors of Banca Romaneasca since August 2010. He has been also appointed as the Chairman of the Board of Directors of NBG Leasing IFN S.A., as Deputy Chairman of the Board of Directors of NBG Factoring Romania IFN S.A. and as a member of Board of Directors of Garanta and NBG Securities Romania S.A. In Banca Romaneasca he is also Chairman of the Executive Committee, Credit Committees, ALCO and Loan Monitoring Committee. He started his career in banking in 1993 in Xiosbank S.A. and then served in several managerial positions in Piraeus Bank Group, Egnatia Bank Romania S.A., Egnatia Bank S.A., National Bank of Greece a.d. Beograd and as President of the Executive Board of Vojvodjanska since 2007. In parallel to his banking career, he worked from 1993 to 2000 as a part-time instructor in Accounting, Mathematics of Finance, Business Administration and Business Finance at the American College of Greece. He holds a Deck Officer Diploma from the Merchant Marine, a BSc in Business Administration from the American College of Greece and an MSc from the University of Lancaster.

Cenk Kahraman, born 1975, is the Managing Director of NBG Bank (Malta) Limited since 2008. He started his banking career in 1998 in Finansbank Turkey where he worked in different departments in the Finansbank Group. In 2005, he was appointed as General Manager in the newly established Finansbank (Malta) Ltd. He also is a board member in NBG (Malta) Holdings Ltd., Executive Committee member in the Malta Bankers Association and served as co-chairman of the Malta Banker's Association in 2008-2009. He holds a BSc in Mechanical Engineering from Istanbul Technical University.

Efstratios Sarantinos, born in 1965, has been the Chief Executive Officer of NBG Asset Management since 1^st February 2012. He has previously worked as a derivatives trader at Merrill Lynch, Barclays de Zoete Wedd, Citibank N.A. in London and as Counsel at National Bank of Greece and General Manager of Kyprou Asset Management M.F.M.C. He is also a holder of the United Kingdom Investment Management Certificate. Mr. Sarantinos holds a PhD in Computer Science—Artificial Intelligence from the University of London and a BSc (Hons) in Computer Science from the University of Wales.

Petros Katsoulas, born 1966, has been the Chief Executive Officer of National Securities S.A. since July 2011. He is a graduate of the Computer Sciences department of the University of Crete (1988). He also holds an MSc in Software Engineering and MBA from Aston University, Birmingham, UK (1990 and 1993 respectively). From July 1993 to October 1996 he worked in the investment banking department of Barclays Bank (BZW) in Athens. From October 1996 to December 1997 he worked in the equities department of BZW in London. From 1998 he worked in the equities department of the investment bank of Credit Suisse in London, where he was Research Director of for European telecommunication companies and Greek Equities. Since 2010 he runs the equity sales desk of National Securities S.A., initially in London and from early 2011 in Athens.

The General Managers, currently 13 in number, each report to the Chief Executive Officer and Deputy Chief Executive Officers are responsible for:

Miltiadis Stathopoulos, born 1944, is the General Counsel since February 2010. He has been a lawyer since 1970 and joined the Group in 1972 as a lawyer of ex National Mortgage Bank S.A. From 1995 he was the Director of the Legal Services of ex National Mortgage Bank S.A. until 1998 when it merged with the Bank. From 1998 to the end of January 2010 he was Director of the Legal Services of the Bank. He participates in the Legal Council, the Credit Committees and the Supreme Disciplinary Council of the Bank. He has served as Vice Chairman, CEO and Board member of the brokerage firm DELPHI S.A. He is currently Vice Chairman of Ektenepol, Ethniki Kefalaiou S.A. and member of the Board of Directors of NBGB. He is also a member of the Legal Committee of the Hellenic Bank Association and a founding member of the Banking and Stock Exchange Law society. Mr. Stathopoulos holds a Bachelor's degree from the Law School of Aristotle University of Thessaloniki.

Charalampos (Babis) Mazarakis, born 1964, is the Chief Financial Officer and member of the ALCO. He is also a Board Member of the NBG subsidiaries Ethnodata S.A., NBGB, Ethniki Factors S.A., Ethniki Kefalaiou S.A., NBG Pangaea and Astir Palace Vouliagmenis S.A. Before joining NBG, he was Chief Operating Officer at the NYSE-listed Corporation Excel Maritime Carriers Ltd, while from 2008 until 2010 he was Group Chief Financial Officer and Member of the Group Executive Committee at TITAN Cement Company (listed on the ATHEX), where he was responsible for the financial and IT management of 70 active companies across 12 countries. From 1999 to 2008 he served in various executive positions in Vodafone Greece and Hungary; he was Group CFO and Member of the Board of Directors in Greece (1999-2006), Interim Chief Executive Officer in Hungary (2006-2007) and in 2007 he returned to Greece as COO and Vice Chairman of the Board of Directors. During the period 1997-1999 he held the position of Finance Director and Member of the Board of Directors at Georgia Pacific-Delica, while from 1992 until 1997 he worked as Financial Analysis Group Manager at Procter & Gamble, at first in Athens and then in the European Headquarters in Brussels. Babis Mazarakis holds a Bachelor's degree in Business Administration from the University of Piraeus (with distinction) and an MBA from Ohio State University, The Fischer School of Business (Wielder Scholar), where he was Teaching Assistant in Finance. He has been listed within the 30 most distinguished CFOs in Europe below 40 years old (2002, CFO Europe).

Andreas Vranas, born 1952, is the Head of Human Resources, since January 2010. He is also Chairman of the Board of NBG Training Center S.A. From 1979 to 1985 he worked as investment analyst at the National Investment Bank for Industrial Development (ETEBA). During the period 1985-1988 he worked at the Ministry of National Economy as economic advisor and Special Secretary for Private Investments. From 1988 to 1996 he rejoined ETEBA, as a manager in the fields of project financing, equity investments and portfolio management. From 1996 to 2004, he was Deputy Governor at the National Bank of Greece and Vice Chairman of the Board of Directors, responsible for corporate credit, shipping and the domestic branch network of the Bank. From April 2004 to January 2010, he was Chairman of the Board of Directors of Ethniki Leasing. He holds a degree in Business

Administration from Athens University of Economics and Business, a Master's degree in Finance from Manchester University and a PhD in Finance from the University of Athens.

Agis Leopoulos, born 1968, is the General Manager of International. Before joining the Group, he worked for three years at the European Commission in Brussels. He is the Chairman of UBB, Stopanska Banka, Banca Romaneasca, SABA, Vojvodjanska and Deputy Chairman of NBG Cyprus. He is also a member of the Board of Directors of Finansbank A.S. He graduated from Athens College and holds a BSc and MSc from the faculty of Economics and Social Science of the London School of Economics.

Paul Mylonas, born 1958, joined NBG Group in 2000. From April 2004 to December 2010, he was General Manager of Strategy and Research, Chief Economist of the Group and Head of Investor Relations. His responsibilities were broadened in December 2010, when he became General Manager of Strategy and Governance. He runs the Investment Committee, he is the secretary of the Executive Committee and a member of ALCO. Mr. Mylonas serves on the Boards of Directors of: Finansbank A.S., Astir Palace Vouliagmenis S.A., NBG Asset Management and National Securities S.A. Moreover, he is a member of the Economic Advisory Board of the Foundation for Economic and Industrial Research and the Hellenic Banks' Association. Before joining the Bank, he worked at the OECD and the IMF and taught at Boston University. Mr. Mylonas holds a PhD from Princeton University and a BSc from Brown University.

Michael Oratis, born 1957, is the Chief Risk Officer. Before joining the Bank in 1999, he worked for Midland Bank, Bank of America, ABN AMRO Bank, Mytilinaios S.A. and Citibank as Country Treasurer. He is a member of the Board of Finansbank A.S., SABA, NBG Asset Management and NBG Staff Self Insurance. He holds a BSc in Chemical Engineering from National Technical University of Athens, an M.S. in Industrial Engineering from Columbia University and an MBA in Finance and International Business from New York University.

George Paschas, born 1956, has been the General Manager of Business Processes, IT & Purchasing at NBG Group since July 2010, after serving as Group CAE (Chief Audit Executive) for 8 years. He is a member of the IIA and the Association of Certified Fraud Examiners. He is non-executive member of the Board of Directors and Chairman of the Audit Committee of EH. He is a member of various executive committees of the Bank and EH, including the Group Procurement and the Risk Management Committee, either in an executive or consulting role. He is a graduate of the University of Piraeus, holding two degrees in Business Management and Money & Foreign Exchange Markets.

Demitrios Dimopoulos, born 1947, is the General Manager of Corporate Banking in National Bank of Greece, since 2008. He joined National Bank of Greece in 1975. He served as Director of the Corporate Division and was involved in corporate financing as well as project financing of investments in infrastructure, energy and tourism sectors. He is member of the Board of Directors of National Securities S.A., Ethniki Leasing and Ethniki Factors S.A. He is also permanent representative of the Bank at the Board of Directors of the Athens Chamber of Commerce and Industry. Mr. Dimopoulos holds a postgraduate degree in Economics from the University of East Anglia, United Kingdom.

Aristotelis Karytinos, born 1956, is the General Manager of Real Estate in National Bank of Greece. He is also CEO of NBG Pangaea, Chairman and CEO of NBG Property Services S.A., Hellenic Touristic Constructions S.A., Kadmos S.A., Ektenepol, Dionysos S.A., Mortgage Touristic Protypos S.A., Chairman of Grand Hotel Summer Palace S.A., Pronomiouhos S.A. Genikon Apothikon Hellados, Aktor Facility Management S.A. and Ethniki Ktimatikis Ekmetalefsis S.A., Vice Chairman of Propindex S.A. and a member of the board of directors of Dipli Anaplasi S.A. Before joining the Bank, he held senior positions within Eurobank EFG Group, including Head of Group Real Estate, Head of Mortgage Lending and CEO of Eurobank Properties REIC. In the past, he has served for several years as manager in companies of the public and private sector. Dr A. Karytinos holds a degree (BSc) in

economics from the University of Athens, a master's degree (MSc) in urban economics from Pantion University and a doctorate (PhD) in finance from the University of Warwick.

Nelly Tzakou, born 1962, is Group Chief Operations Officer and Group Head of Global Transaction Services. She is responsible for the Group Operations, e-Business & Alternative Channels and is Group Head of the Global Transaction Services. She is Chairman at Ethniki Factors S.A., and Vice Chairman at Dias S.A. and National Securities S.A. Moreover, she is a member of the EBA, Single Euro Payments Area ("SEPA") High Level Meeting run by the ECB and a Council Member of the European Financial Management Association ("EFMA") Operational Excellence Advisory Council. Before joining the Bank, Mrs. Tzakou was an executive at Eurobank EFG between 1990 and 2007, responsible for Group Operations and the Global Transaction Services business unit. Mrs. Tzakou holds a Bachelor's Degree in Economics from the University of Piraeus (with honors) and an MBA from the University of Wales & Manchester Business School.

Leonidas Fragkiadakis, born 1966, is the General Manager of Treasury and Global Markets. He is a member of the Board of National Securities S.A. and the Chairman of the Hellenic Chapter of Forex Club/ACI. He obtained his Bachelor's Degree in Economics from Trinity College, Cambridge University and his MBA from the Wharton School of the University of Pennsylvania. Prior to joining the Bank, he was employed by Credit Suisse First Boston, New York.

Marianna Politopoulou, born 1969, has been the General Manager of Group Retail Collections since July 2010. She has been extensively involved in the fields of finance, marketing and strategy for banks and corporations in Greece and abroad. Before joining the Bank, she held senior positions including e-Banking / Private Banking at Credit Agricole, General Manager of Eurolease S.A. and CEO of Eurobank-FPS. She holds a BSc in Civil Engineering from the National Technical University in Athens and an MBA from the Wharton School, University of Pennsylvania.

Andreas Athanassopoulos, born 1966, was appointed General Manager of Retail Banking at National Bank of Greece in April 2011. He is currently leading the Mortgage, Consumer Credit, Card Issuing and Acquiring, SBL, Investment Products and Deposits, Corporate Key Account Services, Customer Service, Marketing & Communication divisions. He holds a Bachelor of Science in Applied Mathematics from the University of Patras, a Master's of Science in Statistics and Operational Research from the University of Essex, a PhD in Management Science from the University of Warwick and a Post-Doc from London Business School. He has worked as a professor at Warwick University (1991-1996) and at ALBA Graduate School. Before joining the Bank he served as a Director of Marketing in Piraeus Bank and in Eurobank EFG as a Deputy General Manager of Small Business Banking. He is board member of NBGB, board member of Hellenic Ombudsman for Banking Investment Services and Vice Chairman of NBG Asset Management. He is a member of the EFMA, the Institute for Operations Research and the Management Sciences (INFORMS) and an honorary professor at Warwick Business School.

Petros Fourtounis, born 1955, has been Deputy General Manager and Group Chief Audit Executive at NBG since July 2010. He is a member of the Economic Chamber of Greece and the IIA. He has been extensively involved in the fields of audit, corporate—project financing and international credit. From August 2002 to July 2010, he held the position of Director in the NBG Divisions of Corporate Banking, Structured and International Finance and Group International Credit. During 1984-1999, he worked as Internal Auditor of the Bank. He joined NBG in 1975. He has been a member of the Board of Directors or Executive Credit Committees of several NBG subsidiaries and he was actively involved in the due diligence procedures of foreign bank acquisitions by NBG. P. Fourtounis holds a Bachelor's Degree in Economics from the University of Macedonia, Economic and Social Sciences.

Dimitris Frangetis, born 1951, holds the position of the Group Chief Credit Officer at National Bank of Greece, having previously been Deputy General Manager of NBG Group International Activities. He is a member of NBG Group Senior Credit Committees and a Board member of Vojvodjanska, Stopanska Banka, as well as of NBG Albania. He has served as Managing Director of Piraeus Group International Subsidiaries, General Manager and Board member at Emporiki Bank, General Manager and Vice Chairman at Ionian Bank, Chairman or Board member in a number of Emporiki Group & Ionian Group Subsidiaries and Deputy General Manager at ANZ Grindlays (Greece). Mr. Frangetis is an Athens College graduate and has studied Economics at the University of Athens and at Essex University.

Demetrios Vrailas, born 1951, is currently the Executive President of Ethnodata S.A., and IT service provider member of the NBG Group. In 2009 he was appointed Deputy General Manager of Information Technology at National Bank of Greece, whereas from 2002 to 2009, he was the NBG IT Manager. During the period of 1998-2002, he worked for Alpha Bank as Deputy Manager in the Business Processes Division. He joined NBG in 1975 and served for 23 years as Application Developer and Systems Engineer. Between 1988 and 1998, he was assigned as Technical Coordinator for Greece of the IBM European User's Association. D. Vrailas holds a Bachelor's Degree in Mathematics from the National and Kapodestrian University of Athens, and a Master of Science in Mathematics of Modern Control Systems from the Loughborough University of Technology (UK).

Ioanna Katzilieri-Zour, born 1961, is Deputy General Manager in Retail Banking. She holds an MSc in Economics from the London School of Economics and a BSc in Economics from Bristol University. She joined the Bank in 2006 after having served as Deputy General Manager of Strategic Marketing at Eurobank EFG. She has also worked for Millennium, Wind, Pepsico IVI and Procter & Gamble Hellas.

Panos Goutakis, born 1958, was appointed Deputy General Manager of Investment Banking at National Bank of Greece and Chairman of the Board of Directors at National Securities S.A. in January 2011. Before joining the Bank, he was Advisor to the Management at Piraeus Bank, responsible for strategic planning. Between 1990 and 2009 he served as Managing Director of Morgan Stanley & Co Ltd., Country Head of Greece. Mr. Goutakis holds an MBA from the University of Rochester and a Bachelor's Degree in Business Administration from the Athens Graduate School of Economic and Commercial Studies.

Spiridon Mavrogalos, born 1968, was appointed Deputy General Manager of Group Procurement and Administrative Support in February 2008. He is a certified accountant (ACCA) and holds an MBA in Finance from the University of Nottingham and a BSc in Computer Information Systems from Deree College. Before joining the Bank he served as General Manager of Group Operations in Cosmote Group. He has also worked in Eurobank EFG in their Integration Office, Risk Management and Internal Audit divisions, at ABN Amro Bank N.V. and at KPMG.

Theofanis Panagiotopoulos, born 1955, was appointed Deputy General Manager in Corporate Banking at National Bank of Greece in May 2008. He holds a BSc from the University of Piraeus. He is a member of the boards of Ethniki Leasing, Ethniki Factors S.A. and General Cables Company S.A.

Telemachos Palaiologos, born 1950, was appointed Deputy General Manager at the Bank in May 2010. From March 2010, he has served as Vice-President of Ethniki Leasing and member of its Board of Directors. He is also member of the Board of Directors of EH. From 1999 to 2009 he served as General Director of Ethniki Leasing. From December 1993 to March 2002 he was member of the Board of Directors of Ethniki Kefalaiou S.A. Before joining the Group, he served as a Chief Executive in leading organizations and enterprises. Telemachos Palaiologos holds a Bachelor's degree in Economics from the National and Kapodistrian University of Athens. He also holds Master's degrees in Development Economics from the University of Bath, and in Business Administration from the University of Birmingham.

Spyros Asimopoulos, born 1951, was appointed Deputy General Manager of the Branch Network at National Bank of Greece in March 2010. He is member of the Board of Directors of NBGB. He has also served as Deputy Human Resources Director (1999-2002), as Branch Network Director, responsible for the bank branches in Attica (2002-2004) and he has worked as Director of the Small & Medium Enterprises Financing Division (2004-2010). From 1994 to 1997 he was Vice Chairman and CEO of the National Housing Bank. Mr. Asimopoulos holds a Bachelor's degree from the Athens University of Economics and Business.

Yiannis Balampanis, born in 1952, he has been Deputy General Manager of Organization and Business Processes at National Bank of Greece since July 2010. He is a System's and Business Processes' Analyst and a member of the Board of Directors of the NBG Group subsidiary Ethnodata S.A. He is also a member of the following NBG Group Committees: Procurement Committee, IT Committee, Security Committee, Operational Risk Committee, and NBG Executive Placement Committee. In addition to all the aforementioned, Mr. Balampanis is NBG Group Business Continuity General Coordinator in Greece. From July 2002 to July 2010, he was the Manager of Business Processes Division at NBG. Among other major projects, Mr. Balampanis was responsible for major NBG projects, such as the consolidations of NBG Subsidiaries ETEBA, EAEDO and National-P&K Securities S.A. During the years 1997-2002 he was Deputy Manager of Business Processes Division. In this capacity, he participated in the project management team of the consolidation of the Mortgage Bank of Greece.

Nikolaos Christodoulou, born 1966, was appointed Group CIO at National Bank of Greece in November 2011. Before joining NBG, he was a Partner at Accenture, the global consulting and technology firm, where he was heading the Management Consulting Unit in Greece. He was also heading the Financial Services Unit in Greece. During the 15 years of his consulting experience he has worked for many of the largest Financial Institutions in Greece and Eastern Europe, advising on large scale transformation programs, defining IT Strategies, conducting feasibility studies for technology investments, designing new operating and organization models. He has served as member of the Board of ICAP S.A. and member of the Advisory Committee of Attica Ventures. He has been Chairman of the Greek Information Society Observatory for 4 years and Chairman of the Digital Aid S.A. for 2 years. He holds a Bachelor's degree in Electrical and Computer Engineering from National Technical University of Athens, an MBA from Warwick Business School, UK and a PhD in Decision Systems from National Technical University of Athens. He has also worked as a Research Associate at INSEAD and at the National Technical University of Athens.

The Senior Executive Committee was established by the Board of Directors in 2004 and operates as per a special Charter, which came in force by the Management Act 145/2.3.2007. The Senior Executive Committee is the Bank's supreme committee, with approving authority that supports the Chief Executive Officer of the Bank in his duties. The Senior Executive Committee has strategic powers and is responsible for monitoring the execution of the Bank's business plan. Furthermore, it has approval powers that cannot be delegated to other members of the Bank's management or to other collective bodies of the Bank.

The Executive Credit Committee was established in 2008 by Management's Act No. 244/8.4.2008 and its purpose is to:

The Disclosure and Transparency Committee was established in 2003 in order to be aligned with the US legal requirements for the financial markets. Its purpose is to monitor the accuracy and completeness of the information included in public announcements and in any publications issued by the Bank, including information submitted to the SEC. Specifically, the Committee has the following responsibilities:



Chairman	Anthimos Thomopoulos	Deputy CEO
Member	Miltiadis Stathopoulos	General Counsel
Member	Dimitrios Dimopoulos	G.M. of Corporate Banking
Member	Agis Leopoulos	G.M. of International Activities
Member	Leonidas Fragkiadakis	G.M. of Treasury and Global Markets
Member	George Paschas	G.M. of Business Processes, IT and Purchasing
Member	Michael Oratis	G.M. of Risk Management
Member	Paul Mylonas	G.M. of Strategy and Governance
Member	Charalampos (Babis) Mazarakis	Chief Financial Officer
Member	Andreas Athanassopoulos	G.M. of Retail Banking
Member	Petros Fourtounis	Chief Audit Officer

The Committee is convened at the invitation of its Chairman, at least twice per annum and ad hoc as deemed necessary.

The IT Steering Committee was established in compliance with the requirements of the Bank of Greece Governor's Act No. 2577/2006, aiming at providing support to the Bank's management with regards to IT Governance. Its key objective is the implementation of the Bank's and the Group's IT strategy and IT Security Policy. Specifically, the Committee is responsible for:



Chairman	Leonidas Theoklitos	Deputy CEO
Member	George Paschas	G.M. of Business Processes, IT and Purchasing
Member	Michael Oratis	G.M. of Risk Management
Member	Leonidas Fragkiadakis	G.M. of Treasury and Global Markets
Member	Andreas Athanassopoulos	G.M. of Retail Banking
Member	Theofanis Panagiotopoulos	Deputy G.M. of Corporate Banking
Member	Nikolaos Christodoulou	Deputy G.M. of IT
Member	Ioannis Balampanis	Deputy G.M. of Business Processes

The Committee convenes at the invitation of its Chairman, at least twice per annum and ad hoc as required.

For the Asset and Liability Committee, see Item 5.B, "Liquidity and Capital Resources".

The Committee was established in 2010. Its purport is the decision making on the provisions and write-offs of Bank claims of any nature, which are considered by the Committee to be liable of a loss in value. Specifically, the Committee's key responsibilities are the following:

During 2011, total remuneration to the Bank's Board of Directors, General Managers, members of the Executive Committees and the Group's key management amounted to EUR 15.2 million.

For more information on related party transactions, see Note 31 to the U.S. GAAP Financial Statements.

Total remuneration comprises salaries, fees, bonuses and other short-term benefits, post employment and other long-term benefits, and termination benefits.

According to the Bank's management, apart from the above amounts, our Directors, General Managers and Deputy General Managers are not entitled to any further monetary amounts from the Bank or our subsidiaries.

We do not set aside or accrue amounts to provide pension, retirement or similar benefits for the Board of Directors or members of management apart from their participation in social security schemes. We do not have Directors' service contracts or other agreements that provide for benefits on termination of employment.

The Bank's corporate governance framework is aligned with the requirements of the Greek legislation, the decrees of the HCMC and the Bank's Articles of Association and regulations. The Bank, being listed on the NY Stock Exchange (NYSE), is also subject to the U.S. legal and regulatory framework (Sarbanes Oxley Act), the SEC decrees and the NYSE regulations. For more information on the differences between the Bank's Corporate Governance Practices and NYSE listing standards see Item 16G, "Corporate governance".

In February 2006, the Bank's Board of Directors adopted a framework that describes the Bank's corporate governance structure and policy. This framework was based on international best practices and fosters continuity, consistency and efficiency in the modus operandi of the Board of Directors and the governance of the Bank and its Group. The Corporate Governance Code, which was adopted by the Bank's Board of Directors in March 2011, results from the provisions of the corporate governance framework and specifically defines:

The Bank, remaining abreast of the international developments in corporate governance issues, continuously updates its corporate governance framework and consistently applies the principles and rules dictated by the Corporate Governance Code, focusing on the long-term protection of the interests of its depositors and customers, shareholders and investors, employees and other stakeholders.

The Bank has adopted the Corporate Governance Code and provides explanations for any exceptions identified in accordance with Greek Law 3873/2010. Within the context of its Corporate Governance Code, the Bank is in the progress of developing a high level Chart of Authorities and Responsibilities of the Bank's management at a Group level, which is expected to be adopted by the Board of Directors in 2012. Delay is due to the extraordinary market conditions in the Greek banking system during 2011. Furthermore, this reason coupled with a very limited tenure of the three out of four executive Board members, who were appointed at the end of the year 2010, has not allowed for the annual evaluation of executive Board members by the non executive members. Moreover, in the period from December 2011 to January 2012, the Board of Directors performed assessment of its effectiveness which was conducted with the support of external advisor. The key results and the improvement recommendations were presented to the Chairman and the Board of Directors. The Chairman has adopted action plan for the implementation of improvements within 2012.

The Corporate Governance Code has been posted on the Bank's website: www.nbg.gr (section: The Bank / Corporate Governance / Regulations and Principles).

Corporate Governance describes the principles and regulations that govern the relations among the Bank's shareholders, management and stakeholders. The Bank aims at attaining corporate governance excellence, enhancing its risk management framework, complying with the national and international legal and regulatory framework and being aligned to the international best banking standards. Hence, the Bank has adopted, in addition to the Corporate Governance Code, a number of corporate governance policies and practices, which are aligned with its activities and ensure the transparency and effectiveness of its operations.

The Bank has implemented the following key corporate governance policies and practices over and above the legal requirements:

As dictated by international best practices for the nomination of Directors in such a way as to ensure meritocracy and the increase of the long-term share value, the nomination responsibility has been assigned to the Corporate Governance and Nominations Committee. This Committee has been entrusted with the evaluation of the needs of the Board of Directors as well as with the identification of those characteristics that warrant the best composition profile for the Board of Directors, as per the

Directors' Nomination Policy. Upon recommendation of the Committee, the Board of Directors approves the Committee's recommended nominations and submits a relevant proposal to the General Meeting of Shareholders. The Shareholders have the right to nominate, at will, additional candidates.

The Directors' Nomination Policy was based on the Corporate Governance Code and the Corporate Governance and Nominations Committee Charter and was approved by the Board of Directors (meeting no. 1379/29.05.09).

The Conflict of Interest Policy for Senior Executives aims at enhancing the Bank's Internal Controls System, and preventing and managing potential conflicts of interest between the Bank and its Senior Executives, that may have an adverse impact on the reputation and interests of the Bank, its clients, Shareholders and employees.

The Conflict of Interest Policy assigns specific roles and responsibilities to the Chief Executive Officer, the Board of Directors, the Audit Committee and the Group Compliance Division with respect to its implementation and monitoring. The Policy is aligned to the Bank's Articles of Association, the Code of Ethics and the Corporate Governance Code. A summary of the main provisions of the Policy has already been included in the Corporate Governance Statement included in the Annual Report for the year 2010 (available on the Bank's website www.nbg.gr (section: The Bank / Investor Relations / Annual Reports and Info Memorandums / 2010).

On November 26, 2006, the Bank's Board of Directors approved a Group Code of Ethics (the "Code of Ethics"), which sets out the core principles and values underlying its internal regulations and policy and the conduct of its employees.

The Code of Ethics has been formulated on the basis of the fundamental values that the Bank upholds in its business activities and the provisions of the national and international legislation which, accordingly, concern employees throughout the Bank and its Group.

The Code of Ethics applies to the entire management and employees of the Bank and the Group, including Independent Associates and Consultants.

The Code of Ethics has been posted on the Bank's website: www.nbg.gr (section: The Bank / Corporate Governance / Regulations and Principles).

According to the Corporate Governance Code, the Directors have the right to a full insurance coverage against legal or other risks related to their duties within the Bank. Accordingly, the Bank has entered into a multi-insurance contract in order to cover the civil liability of the Directors and Executives of all the Group entities, the civil liability for claims against the Bank arising from negligence, error or oversight by Executives and employees and damages arising from fraud, including electronic fraud.

The Bank's Board of Directors, in compliance with the U.S. legal and regulatory framework and the decrees of SEC, has approved a separate Code of Ethics for Financial Professionals, which stipulates the fundamental ethical obligations which are binding for:

The Code aims at preventing situations where conflict of interest may arise where the interests of the Covered Persons are not aligned with those of the Bank and the Group, as well as in the cases of unauthorized disclosure of confidential information obtained or created in connection with the Covered Persons' duties. Furthermore, it stipulates that the information contained in public announcements and in official reports and documents are complete, accurate, timely and understandable, and that all such information is presented in accordance with applicable rules and regulations.

The Code of Ethics for Financial Professionals has been posted on the Bank's website: www.nbg.gr (section: The Bank / Corporate Governance / Regulations and Principles).

The Bank, in compliance with the U.S. legal and regulatory framework and the decrees of SEC as well as the relevant provisions of the Bank of Greece Governor's Act 2577/9.3.2006, as currently in force, has implemented a Whistle blowing Policy for the submission of confidential reports by any party, whether anonymously or not. These reports mainly relate to behaviors employed by the Bank's and the Group's Executives and employees that raise concerns for irregular or illegal actions related to accounting and auditing matters, which are inconsistent with the international practices and regulations.

These reports are directly received by the Bank's Audit Committee, which ensures they are kept confidential and classified and that the whistleblowers remain anonymous. With this policy, the Audit Committee's operation is enhanced as the Committee holds the overall responsibility for the development and establishment of this Policy, the supervision of its implementation and the monitoring of the investigations and the progress of corrective actions.

The Bank's website www.nbg.gr (section: The Bank / Corporate Governance / Contact us), provides the Audit Committee's contact information for the submission of confidential reports.

The Bank fully recognizes the value of CSR as a prerequisite for the sustainable growth of the organization, and has been applying increasingly systematic management techniques in its approach to the concept of Social Responsibility, an issue that has long been high on the Bank's agenda.

The Bank, standing by its commitments, continued in 2011 within its strategic framework its wide ranging community actions, attaining targets that were formulated to achieve economic prosperity, support actions designed to foster environmentally friendly growth, enhance the quality of its workforce and the services offered to its customers, and contribute to the community in which it conducts its business.

Despite the extremely adverse economic climate the Bank stood by its commitment to social support continuing its tradition of contributing to the community. Accordingly, in 2011 it implemented a sponsorship program amounting to approximately EUR 14.3 million. The Bank supported a wide range of corporate, social and cultural responsibility initiatives, both directly as a bank and via its funding of the activities of the NBG Cultural Foundation and its Historical Archives. The core lines of action focus on the Community, Environment and Cultural Heritage.

The Bank has adopted a CSR Policy that reflects the keystones of the CSR framework, determines the CSR Action framework for the Bank and the Group and provides guidelines to NBG and its subsidiaries for the delegation of authorities and responsibilities for the planning, implementation and control of these Actions.

The Bank's Board of Directors and the boards of those Group entities that are involved in CSR actions, approve the CSR budget within the context of the Group budget approval. The Bank's Chief Executive Officer approves any commitment within the approved CSR budget and informs the Board of Directors accordingly. For any commitment exceeding the budget, the Chief Executive Officer requests Board of Directors approval.

The CSR has been posted on the Bank's website: www.nbg.gr (section: The Bank / Corporate Governance / Regulations and Principles).

The Audit Committee was established in 1999 and operates in accordance with the provisions of Bank of Greece Governor's Act No. 2577/2006, Greek Law 3693/2008 (article 37) and the U.S. Sarbanes Oxley Act. Its responsibilities include:

The members of the Committee are elected by the General Meeting upon recommendation of the Corporate Governance and Nominations Committee to the Chairman of the Board. The Chairman of the Committee is appointed by the Board of Directors. The Committee is composed of five non-executive and independent Directors, at least one of whom is a financial expert with adequate knowledge and experience in auditing issues. The Committee's members are appointed for a one-year term of office, which can be renewed indefinitely.

The Committee meets on a regular basis, at least six times a year, and on an extraordinary basis if required; it keeps minutes of its proceedings and reports to the Board of Directors every three months or more often, if deemed necessary. The external auditor or the Chief Audit Officer may request a meeting with the Committee. The Committee Chairman specifies the agenda, the frequency and the

length of meetings, and ensures the Committee's effectiveness in discharging its duties. At the beginning of each calendar year, the Committee prepares its annual audit program and submits it to the Board of Directors.

The current Audit Committee members were elected, as per the requirements of Greek Law 3693/2008, by the annual General Meeting of Shareholders on June 23, 2011, following the consent of the Corporate Governance and Nominations Committee and the Board of Directors. The Committee's term of office was set to one year extended until the annual General Meeting of Shareholders for the year 2012.

During 2011, the Audit Committee convened ten times. The members of the Committee receive compensation for their participation.

The Human Resources and Remuneration Committee was established by a decision of the Board of Directors (meeting no. 1259/5.5.2005) and is of a consultatory nature. Its purpose is to assist the Board of Directors in performing its duties with respect to attracting, retaining, developing and motivating executives and employees of the highest professional and moral caliber; providing incentives aiming at the development of a culture of fairly evaluating effort and rewarding performance; and developing and maintaining a coherent system of values and incentives for the development of human resources throughout the Bank.

The Committee consists of at least three members of the Board of Directors, the majority of whom (including the Chairman) are independent Directors, as per the independency definition included in the Corporate Governance Code. The members and the Chairman of the Committee are appointed thereon by the Board of Directors upon recommendation of the Corporate Governance and Nominations Committee. The Committee members are selected based on of their competence and experience and are appointed for a one-year term of office, which can be renewed indefinitely.

The Committee meets at least three times a year, keeps minutes of its proceedings and reports regularly to the Board of Directors. The Chairman determines the agenda, the frequency and the length of meetings and ensures in general, the Committee's effectiveness in discharging its responsibilities. At its first meeting of the calendar year, the Committee decides on an annual calendar and rolling agenda.

During 2011, the Human Resources and Remuneration Committee convened four times. Its members receive compensation for their participation.

The Corporate Governance and Nominations Committee was established by a decision of the Board of Directors (meeting no. 1259/5.5.2005) and is of a supervisory nature. Its purpose is to assist the Board of Directors in ensuring that its composition, structure, policies and processes meet all relevant legal and regulatory requirements, strive to achieve best practice standards of corporate governance across the Group and facilitate the work of the Board of Directors and the Bank's management, with a view to increasing the long-term value of the Bank.

The Committee consists of at least three Directors. The members and the Chairman of the Committee are appointed thereto by the Board of Directors. All members of the Committee are non-executive and in their majority independent Directors, as per the independency definition included in the Corporate Governance Code. The Committee members are appointed for a one-year term of office, which can be renewed indefinitely. The Committee meets at least three times a year, keeps minutes of its proceedings and reports to the Board of Directors on a regular basis. At the first meeting of each calendar year, the Committee decides on an annual calendar and rolling agenda.

During 2011, the Corporate Governance and Nominations Committee convened four times. Its members receive compensation for their participation.

The RMC was established by a decision of the Board of Directors (meeting no. 1308/20.7.06) in accordance with the requirements of Bank of Greece Governor's Act No. 2577/9.3.2006. The Committee has the following responsibilities:

The Committee consists of Directors appointed by the Board of Directors pursuant to the Corporate Governance and Nominations Committee's recommendation to the Chairman of the Board. The Committee has a minimum membership of three members of whom at least one must be an executive member and at least one a non-executive member. The members must have adequate knowledge and experience in banking and financial matters as well as risk management. They are appointed for a term of one year, which may be renewed indefinitely.

The Committee meets at least four times a year (on a quarterly basis) and extraordinarily whenever the Chairman deems fit. The Committee keeps minutes of its proceedings and submits reports on each meeting thereof to the Board of Directors. The Chairman determines the agenda and the frequency and length of meetings and ensures that the Committee's functions are performed effectively. At the first meeting of each calendar year, the Committee decides on a schedule and a rolling agenda of meetings for the rest of the year.

During 2011, the RMC convened eight times. Its members receive compensation for their participation.

The Strategy Committee was established by a decision of the Board of Directors (meeting no. 1387/29.9.09). Its purposes is to assist the executive members of the Board of Directors in developing the Group's strategic options; assist the Board of Directors in taking decisions on all issues related to the Group strategy; and review regularly the implementation of the Group's strategy by the Group's management.

At least three of the Strategy Committee's five members are independent non-executive members of the Board of Directors. The Strategy Committee is chaired by the Chairman of the Board of Directors. Its members are appointed by the Board of Directors upon recommendation of its Chairman, who consults with the Corporate Governance and Nomination Committee to this effect. The Committee members are appointed for an one-year term of office, which can be renewed indefinitely. The Committee meets at least three times per year and as often as necessary to discuss issues before they are assessed by the Board of Directors, keeps minutes of its proceedings and reports regularly to the Board of Directors. The Chairman determines the agenda, the frequency and the length of meetings and ensures the Committee's effectiveness in discharging its responsibilities. At the first meeting of the calendar year, the Committee decides on an annual calendar and rolling agenda and informs the Board of Directors accordingly.

During 2011, the Strategy Committee convened nine times. Its members receive compensation for their participation.

As of December 31, 2011, the Bank employed a total of 12,189 staff of which 546 are employed in the Bank's foreign branches, compared to 12,775 and 587 respectively, as of December 31, 2010 and 13,066 and 535 respectively, as of December 31, 2009. Additionally, the Group's subsidiaries in Greece and abroad employed approximately 22,509 employees as of December 31, 2011, compared to 24,091 as of December 31, 2010 and 23,248 as of December 31, 2009. As of December 31, 2011 Group-wide temporary employees were approximately 514. The table below sets forth the average number of our employees by geographic location for 2011:

The table below sets forth the main categories of activity in which our employees were engaged, domestically and internationally, during 2011:

The majority of the Bank's staff are members of one of the various unions operating within the banking sector. A high level of union membership is common in most Greek industries. Each union that represents the Bank's employees is affiliated with a larger, general union of employees in the banking sector known as the Union of Greek Bank Employees ("OTOE"). OTOE, in turn, is part of a multi-industry union, the General Confederation of Greek Workers. Accordingly, almost all of our Greek employees, including those not employed in the banking sector, are ultimately affiliated with the General Confederation of Greek Workers. Collective bargaining arrangements were concluded in the past between representatives of the Greek banks and OTOE based on the Hellenic Republic's inflation estimates, and then implemented by each bank (including the Bank) in agreement with its own unions.

In light of the Group's strategy to streamline its operations and maximize efficiency, voluntary retirement schemes have been implemented. On December 31, 2010 the Bank's wholly owned subsidiary EH completed the voluntary retirement scheme, that had been announced on November 25, 2008, whereby employees fulfilling certain criteria had the opportunity to leave service receiving additional benefits to those provided by law, subject to the approval of the Voluntary Retirement Scheme Committee which included representatives of the company and its employees. A total of 237 employees have left service taking advantage of the provisions of the scheme (not including those who had subscribed to the scheme and subsequently withdrew their interest).

Following legislation passed in April 2008, the Bank's main pension plan and the main pension branch of EH's post-retirement and health plan, both of which are defined-contribution plans, have been incorporated into the main pension branch of the state sponsored social security fund IKA -ETAM as of August 1, 2008. Pursuant to this legislation, the Bank will contribute EUR 25.5 million into IKA - ETAM per year for 15 years starting from December 2009. The April 2008 legislation also prescribed that employer contributions made by the Bank to the existing funds that are to be merged into IKA - ETAM will be reduced every three years in equal increments starting from 26.5% in 2013 until they reach 13.3%. This rule applies to employees who joined any social security plan prior to January 1, 1993. Employer contributions made by EH to the existing funds that are to be merged with IKA - ETAM will also be reduced every three years in equal increments until they reach 13.3% (from 20.0%) for employers who joined any social security plan prior to January 1, 1993.

In addition, in 2005 and 2006, the Hellenic Republic passed legislation permitting bank employee auxiliary pension schemes to merge with the newly-formed ETAT. The relevant legislation provides that,

in connection with the merger of auxiliary schemes with ETAT, the relevant employer shall make a payment to ETAT solely in an amount to be determined by an independent financial report commissioned by the Ministry of Finance pursuant to this legislation. Subsequently, in April 2006 the Bank applied under Greek Law 3371/2005, as amended, to merge its Auxiliary Pension Fund, a defined contribution plan, into ETAT. For risks associated with the new pension reform legislation, see Item 3.D, "Risk Factors—Risks Relating to Our Business—We could be exposed to significant future pension and post-employment benefit liabilities".

At the General Meeting held on June 22, 2005, a stock option program was approved for the executive directors, executive management and personnel of the Group (Program A). The maximum number of new ordinary shares to be issued under Program A was set at 2.5 million and adjusted to 3.5 million as a consequence of the four to ten share capital increase in 2006. Program A was set to last for five years and expired in 2010. Under the terms of Program A, the exercise price range was between EUR 5.0 and 70% of the average market price for the ordinary shares over a period starting on January 1 of the financial year during which such rights were granted until and including the first exercise date.

At the repeat General Meeting held on June 1, 2006, a new Group-wide stock option program was approved for the Bank's executive directors, executive management and personnel of the Group (Program B). The maximum number of new ordinary shares to be issued under Program B was set at 2.5 million and adjusted to 3.5 million as a consequence of the four to ten share capital increase in 2006. Program B was set to last five years and expired in 2011. Under the terms of Program B, the exercise price range was between EUR 5.0 and 70% of the average market price for the ordinary shares over a period starting on June 2, 2006 until the date at which such rights were first exercised.

At the repeat General Meeting held on June 28, 2007, the shareholders of the Bank approved a new Group-wide stock option program for the Bank's executive directors, executive management and personnel of the Group (Program C). Program C is set to last eight years and expires in 2015. The stock options were to be granted up until 2010. The maximum number of new ordinary shares to be issued under Program C was originally set at 12 million and adjusted to approximately 12.5 million as a consequence of four for every hundred shares held issue as stock dividend, in accordance with the resolution passed at the repeat General Meeting held on May 15, 2008. The maximum number of options that could have been granted per year could not exceed 1% of the total number of ordinary shares outstanding. The strike price should be within the range of EUR 5.0 to 85% of the average market price of the ordinary shares within the time period from January 1 of the year the options are granted until October 31 of that same year. No stock options have been granted under this program.

The total number of share options granted, exercised and cancelled per Program, are analyzed as follows:

After December 10, 2010 the outstanding options of the first and second grant of Program A expired.

All outstanding options of Program B would have been exercised between June 1, 2011 and June 10, 2011. After June 10, 2011, the unexercised options expired.

Details of the share options outstanding during the period to December 31, 2011 and December 31, 2010 are as follows:

The weighted average remaining contractual term of options outstanding was 0.5 and nil years for 2010 and 2011 respectively.

No new options were granted in 2010 or 2011. The total fair value of options vested during 2010 and 2011 was EUR 4,814 thousand and nil respectively.

At the General Meeting held on May 25, 2007, the shareholders of the Bank approved the distribution to the Bank's staff of bonus shares with the issuance of 350,000 new ordinary shares of a par value of EUR 5.0, by capitalizing profits of EUR 1.75 million, resulting in a share capital increase of an equal amount. For a period of three years following their issuance (up to October 6, 2010), such new ordinary shares may be transferred only pursuant to approval granted at the General Meeting. The total expense recognized during 2009, 2010 and 2011 amounted to EUR 4,433 thousand, EUR 1,847 thousand and nil thousand respectively.

As at April 27, 2012, the Bank's outstanding issued share capital consisted of 956,090,482 ordinary shares, 25 million Series A non-cumulative non-voting redeemable preference shares offered in the form of ADRs in the United States and 270 million preference shares issued to the Hellenic Republic pursuant to the Hellenic Republic Bank Support Plan.

The following table sets forth certain information regarding holders of the Bank's ordinary shares, based on information known to or ascertainable by the Bank.

The Bank's major ordinary shareholders do not possess different voting rights from the Bank's other ordinary shareholders. Other than certain Hellenic Republic-related entities whose boards of directors are appointed by the Hellenic Republic, the Bank does not know of any other persons who, directly or indirectly, jointly or individually, exercise or could exercise control over the Bank.

No single shareholder beneficially owns 5% or more of the Bank's ordinary shares.

The Bank of New York Mellon is the depositary of the Bank's ordinary shares and of the preference shares traded in the NYSE in the form of ADRs. Based on information known to or ascertainable by the Bank, there were 54 registered holders of the Bank's ADRs in the United States on April 27, 2012, and the portion of the Bank's ordinary shares held in the United States in the form of ADRs as a percentage of total shares outstanding was approximately 1.0%.

As at April 27, 2012, there were registered holders of the Bank's ADSs evidencing our non-cumulative non-voting redeemable preference shares issued in June 2008.

Subject to certain conditions, Greek law allows an entity to acquire and own its own shares and also allows subsidiaries to acquire and own shares of their parent company. Treasury shares in our financial statements represent shares of the Bank owned by our subsidiaries. Due to its participation in the Hellenic Republic liquidity support plan (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic's Bank Support Plan") the Bank has not purchased any of its own shares from January 1, 2009 to the date of this Annual Report.

As at April 27, 2012, the Hellenic Republic, through the Hellenic Republic Asset Development Fund, directly holds 1.23% of the Bank's ordinary shares acquired from the exercise of its preemptive right to subscribe for new ordinary shares that were not subscribed by holders of rights pursuant to the rights issue undertaken by the Bank in July 2009 and October 2010. See Item 3.D, "Risk Factors—Risks Relating to Our Business". Furthermore, certain state-related entities, primarily pension funds (most of whose boards of directors are appointed by the Hellenic Republic) may exercise indirect influence on the Bank. As at April 27, 2012, domestic pension funds owned approximately 16.4% of our ordinary share capital and other domestic public sector related legal entities and the Church of Greece owned approximately 7.5%.

The Group has entered into transactions with its affiliates, employee benefits related funds and the members of the Board of Directors of the Bank, the General Managers and the members of the Executive Committees of the Bank, the key management of other Group companies, as well as with the close members of family and entities controlled or jointly controlled by those persons. See Note 31 to the U.S. GAAP Financial Statements for details.

All loans granted to related parties (i) were made in the ordinary course of business, (ii) were made on substantially the same terms, including interest rates and collateral, as those prevailing at the time for comparable transactions with other persons, and (iii) did not involve more than the normal risk of collectibility or present other unfavorable features, except for the following transactions:

The Bank grants loans to its employees on preferential terms compared to customers that are not employees. This policy, which is common practice for banks in Greece, applies only to employees and not to close members of family and entities controlled by them. The preferential terms mainly refer to a lower fixed interest rate of 3.0% for mortgage loans, while collateral is required as in the ordinary course of business. As such, certain General Managers and members of the Executive Committees of the Bank have taken loans with reduced interest rates of total amount EUR 25.6 million and EUR 24.8 million as of December 31, 2011 and March 31, 2012 respectively.

Please refer to Item 18 "Financial Statements" for the consolidated financial statements of NBG, the comparative financial statements of NBG and the Report of Independent Registered Public Accounting Firm given by Deloitte Hadjipavlou Sofianos & Cambanis S.A.

Net interest income before provisions for loan losses derived from foreign sources was EUR 1,519.9 million and represents 41.7% of our net interest income before provisions for loan losses.

The Group and certain of its subsidiaries is defendant in certain claim and legal actions and proceedings arising in the ordinary course of business. These actions and proceedings are generally based on alleged violations of consumer protection, banking, employment and other laws. None of these actions and proceedings is individually material. In accordance with ASC 450 the Group establishes accruals for all litigations, for which it believes it is probable that a loss has been incurred and the amount of the loss can be reasonably estimated. These accruals may change from time to time, as appropriate, in light of additional information. At December 31, 2010 and 2011 the Group has accrued for cases under litigation the amount of EUR 43.6 million and EUR 85.4 million, respectively, for those litigations for which the Group believes that this loss is probable and reasonably estimated. For the cases for which an accrual has not been recognized, management is not able to estimate reasonable possible losses, because the proceedings may last for many years, many of the proceedings

are in early stages, there is uncertainty of the likelihood of the final result, there is uncertainty as to the outcome of pending appeals and there are significant issues to be resolved. However, in the opinion of the management, after consultation with legal counsel, the ultimate disposition of these matters is not expected to have a material adverse effect on the consolidated balance sheet, results of operation or cash flows of the Group.

As and when we are permitted to pay dividends, under Greek Law 2190/1920 and our Articles of Association, our profit for the period is to be allocated as follows:

Subject to the provisions regulating a share capital decrease, no profits may be distributed to shareholders if at the end of the previous financial year, the Bank's total equity is, or as a result of the said distribution will be, less than the Bank's share capital plus reserves, whose distribution is prohibited by law or our Articles of Association.

The distributable profits shall not exceed the profits for the last financial year on an unconsolidated basis net of tax, plus retained earnings and reserves the distribution of which is allowed (and has been approved at the annual General Meeting), less any losses carried forward and any amounts required by law or our Articles of Association to be allocated towards the formation of reserves. The profits to be distributed are payable to the shareholders within two months from the approval of the annual financial statements at the annual General Meeting. A shareholder's claim to a declared dividend is subject to a five-year statute of limitations, after which the dividend passes to the Hellenic Republic. The five-year period begins as of the end of the year during which its distribution was approved by the annual General Meeting.

Additional restrictions on dividends arise from our participation in the Hellenic Republic Bank Support Plan. Under Greek Law 3723/2008 setting forth the terms of the Hellenic Republic Bank

Support Plan, participating banks will be subject to a maximum dividend distribution of 35% of profits otherwise set at the minimum dividend distribution by article 3, par. 1 of Greek Law 148/1967. For more information on the Hellenic Republic Bank Support Plan, see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic Bank Support Plan". Moreover, under the law, the representative of the government appointed to our Board of Directors or attending the annual General Meeting may veto any resolution relating to our dividend policy, pursuant to a decision of the Minister of Finance, or if it is determined that such policy may jeopardize the interests of our depositors or materially affect our solvency and orderly operation.

According to the provisions of article 28 of Greek Law 3756/2009 and decision 20708/B/1175/23.4.2009 of the Minister of Finance, banks participating in the Hellenic Republic Bank Support Plan are allowed to distribute dividends to ordinary shareholders only in the form of shares, but excluding treasury shares, for the financial year ended on December 31, 2008. Also, pursuant to the provisions of article 39 of Greek Law 3844/2010, article 28 of Greek Law 3576/2009 was modified to provide that the restriction of dividends distribution to ordinary shareholders only in the form of shares, but excluding treasury shares, was applicable and for the financial year ended on December 31, 2009. This restriction did not include any dividend or fixed return on preference shares that are being traded in foreign organized markets, as well as any interim dividend paid which, however, is included in the calculation of the minimum dividend of 35%.

In accordance with Greek Law 3965/2011 (Government Gazette Issue 113-18/5/2011), for the year 2010, banks participating in the Plan are allowed to distribute dividends only in the form of shares. However, these cannot be treasury shares. The same applies for the year 2011 in accordance with Greek Law 4063/2012.

For information on dividend distributions by the Bank see Item 3.A, "Selected Financial Data—Dividends".

For a discussion of significant changes that have occurred since December 31, 2011, the date of the last audited financial statements included in this Annual Report, please see Note 42 to the U.S. GAAP Financial Statements which describes post-balance sheet events and Note 43 to the U.S. GAAP Financial Statements, which refers to the restatement of our financial statements prepared in accordance with U.S. GAAP for the financial years ended December 31, 2008, 2009 and 2010.

The Bank's shares have been listed on the ATHEX since the foundation of the exchange in 1880. Since October 1999, the Bank's shares have also been listed on the New York Stock Exchange and traded in the form of ADRs. Each ADR currently represents one share.

The annual high and low market prices of the Bank's shares on the ATHEX for the five most recent financial years are shown below, expressed in euro.

The quarterly high and low market prices of the Bank's shares on the ATHEX for the two most recent financial years are shown below, expressed in euro.

The high and low market prices of the Bank's shares on the ATHEX for the first quarter of 2012 are shown below, expressed in euro.

The monthly high and low market prices of the Bank's shares on the ATHEX for each of the six most recent months are presented in the table below, expressed in euro.

The Bank's share price in each period is adjusted to reflect the issuance of new shares in connection with the four-for-100 shares issued as stock dividend of EUR 1 for the 2007 financial year rights issue (adjustment effective at May 16, 2008), the two for nine rights issue that took place in 2009 (adjustment effective as at July 30, 2009), the one for five rights issue (adjustment effective as at October 13, 2010) and the three for eight rights issue of Convertible Equity Notes (adjustment effective as at October 25, 2010) and the new shares issued in January 2007, January 2008, June 2008 and December 2009, following the exercise of employee stock options. For more information see: Item 14.A, "General Effect of the Modifications on the Rights of Security Holders".

On May 15, 2008 the Bank's General Meeting of Shareholders approved the share capital increase of up to EUR 1.5 billion through the issue of redeemable preference shares, with exclusion of the preemptive right in favor of existing shareholders, that were made available to private investors in the U.S. As a result, the Bank's share capital increased by EUR 7.5 million through payment in cash of EUR 402,638 thousand and the issue of 25 million redeemable preference shares without voting right or cumulative dividend, of a par value of EUR 0.30 and a selling price of USD 25 each. The preference shares were sold in the form of American Depositary Shares (ADSs), and each ADS represents one preference share.

The high and low market prices of the Bank's ADSs on the New York Stock Exchange for 2008 (starting on June 2, which was the first trading day of the ADSs), 2009, 2010 and 2011 are shown below, expressed in USD.

The quarterly high and low market prices of the Bank's ADSs on the New York Stock Exchange for the most recent two financial years are shown below, expressed in USD.

The high and low market prices of the Bank's ADSs on the New York Stock Exchange for the first quarter of 2012 are shown below, expressed in USD.

The monthly high and low market prices of the Bank's ADSs on the New York Stock Exchange for the six most recent months are shown below, expressed in USD.

The annual high and low market prices of the Bank's ADRs evidencing common shares on the New York Stock Exchange are shown below, expressed in U.S. dollars, for the five most recent financial years:

The quarterly high and low market prices of the Bank's ADRs on the New York Stock Exchange for the two most recent financial years are shown below, expressed in USD.

The high and low market prices of the Bank's ADRs on the New York Stock Exchange for the quarter following the most recent financial year are shown below, expressed in USD.

The monthly high and low market prices of the Bank's ADRs on the New York Stock Exchange for the six most recent months are shown below, expressed in USD.

Other than the suspension of trading of shares on the ATHEX and of ADRs on the New York Stock Exchange, in anticipation of the announcement of the acquisition of Finansbank, there have been no trading suspensions with respect to the Bank's shares on the ATHEX during the past three years ending December 31, 2009, 2010 and 2011, nor have there been any trading suspensions with respect to the Bank's ADRs on the New York Stock Exchange since the Bank's listing thereon in October 1999.

The Bank's shares are listed on the ATHEX. In addition, the Bank's Global Depositary Receipts are listed on the London Stock Exchange and its ADRs and preference shares are listed on the New York Stock Exchange.

The ATHEX formerly known as the Athens Stock Exchange, was established in 1876. Since 1995, the ATHEX has progressively been privatized, and its privatization is now complete. On May 31, 2001, the ATHEX was upgraded by the Morgan Stanley Composite Index from emerging to developed markets status. The first edition of the Athens Exchange Regulation (the "ATHEX Regulation") was issued following authorization by Greek Law 3152/2003, and came into force on June 16, 2004. Under

Greek Law 3606/2007 (the "MiFID Law"), which transposed into Greek law the Markets in Financial Instruments Directive ("MiFID") a revised ATHEX Regulation was issued and came into force on July 22, 2008. The currently applicable Codified ATHEX Regulation is the third edition of the revised ATHEX Regulation (the latest amendment being effective as of March 16, 2009) and governs the relationships between the ATHEX and its Members, the companies that have listed securities for trading or have submitted an application for the listing of their securities on the ATHEX, as well as any other legal or physical entity towards which the ATHEX Regulation introduces rights and obligations.

Today, the ATHEX operates two regulated markets: the Securities Market and the Derivatives Market (which includes the Repo Market). The securities of companies listed on the Securities Market are classified into one of the following seven categories: (a) the Large Cap Category, (b) the Small and Medium Cap Category, (c) the Exchange Traded Funds Category, (d) the Low Dispersion, Low Liquidity & Special Features Category, (e) the Under Surveillance Category, (f) the Synthetic Financial Instruments Category and (g) the Fixed Income Securities Category. When securities, other than units in listed mutual funds, debts securities and synthetic financial instrument, are listed for the first time on the Securities Market of the ATHEX they will fall within one of the first two categories. Finally, a new non-regulated market, the Alternative Market or "EN.A.", has been established by virtue of article 29 of Greek Law 3556/2007 and HCMC Decision 4/443/2007. Pursuant to the entry into force of the MiFID Law and HCMC Decision No 2/477/1.7.2008, which governs the requirements of an operation license for a multilateral trading facility EN.A is operated by the ATHEX in accordance with HCMC Decision No 2/505/2009. EN.A. is a multilateral trading facility within the meaning of the MiFID and therefore, the obligatory provisions that apply in regulated markets and impose strict admission and on-going requirements are not applicable. EN.A is supervised by the HCMC.

HELEX owns 100% of the ATHEX and the majority of the share capital of the Thessaloniki Stock Exchange Centre S.A., which was established in order to facilitate the listing of companies operating in the north of Greece, trading through the ATHEX trading system by investors in the north of Greece and the collaboration with securities and exchange commissions of northern SEE in order to promote bilateral and multilateral cooperation.

The Greek capital markets, in general, and the ATHEX in particular, are currently regulated by a series of laws enacted by the Greek Parliament, decisions and regulations issued by the Board of Directors of the HCMC, the ATHEX Regulation and decisions issued by the Board of Directors of the ATHEX.

In 2011, the average daily trading value on the ATHEX was EUR 82.4 million, compared with EUR 139.8 million in 2010, which represents a decrease of 41.1%. From January 2, 2012 to February 16, 2012, the average daily value traded on the ATHEX was EUR 66 million. On February 16, 2012, 275 companies had shares listed on the Cash Market of the ATHEX. On February 16, 2012, the total market capitalization of the ATHEX was EUR 31.0 billion, with the top 25 companies accounting for 75.8% of the total market capitalization, and the Bank's market capitalization was EUR 6.0 billion, or 19.2%, of the total.

Membership is required for investment services firms ("ISF") and for credit institutions in order to effect transactions on the ATHEX. Membership is subject to approval by the Board of Directors of the ATHEX, while licensing, where required, is approved by the HCMC (or the Bank of Greece, in the case of a credit institution). In addition, ISFs must appoint at least one official representative, authorized to conduct transactions on the ATHEX. The representatives must fulfill certain qualifications required by law and pass an examination administered by the HCMC. For companies established in Greece, the minimum capitalization requirement in order to obtain a license to operate

an ISF and qualify as an ATHEX member is at least EUR 1.0 million or EUR 3.0 million if engaging in underwriting, placement of securities on a firm commitment basis, proprietary trading or in the operation of a multilateral trading facility.

Members of the ATHEX may engage in transactions through the Automated Exchange Trading System ("OASIS"), an electronic trading system, on behalf of their customers or on their own behalf. Pursuant to the MiFID and the MiFID Law, investment services may be provided in Greece by ISFs established in Greece that have received an appropriate operating license from the HCMC, as well as by EU ISFs benefiting from a European passport in accordance with the MiFID and the MiFID Law in which case no further licensing in Greece is required or by ISFs established outside the EU maintaining a permanent establishment (branch) in Greece. Principal investment services within the scope of the MiFID include the receipt and transfer of orders from investors to effect stock exchange transactions, the execution of such orders, the trading for the ISFs own behalf and the underwriting and the provision of advice. ISFs licensed pursuant to the MiFID Law to provide exclusively the services of reception and transmission of orders, consulting and portfolio management, without holding, in any case, funds or securities of their customers, must have a minimum share capital of EUR 300,000. Pursuant to the ATHEX Regulation, ISFs established in the EU or the EEA may become remote members of the ATHEX and are therefore not required to be permanently established in Greece. Nevertheless, they would need to appoint a local custodian, acting in their name and on their behalf, to clear and settle stock exchange transactions and any other actions in relation to which they would be otherwise required to perform by being physically present in Greece. Such appointment is not necessary if the remote member has established a direct connection with the Greek Dematerialized Securities System. In the latter case, the remote members would need to appoint a representative and agent for the service of process in Athens.

The most widely followed index in Greece is the ATHEX Composite Index, a market capitalization index which tracks the price movement in the shares of 49 leading Greek companies, listed today under the Large Cap Category.

Another composite index, called the FTSE/ASE 20, was introduced in September 1997. This index is made up of the 20 largest companies by market capitalization listed on the ATHEX.

On December 9, 1999, another composite index was introduced, the FTSE/ASE Mid40, which is made up of 40 medium capitalization companies (i.e., the 40 largest companies by capitalization, ranking after those listed on the FTSE/ASE 20). On June 1, 2001, the FTSE/ASE SmallCap 80 composite index was introduced, which is made up of 80 small capitalization companies (i.e., the 80 largest companies by capitalization ranking after those listed on the FTSE/ASE 20 and FTSE/ASE Mid 40 Indices). On January 2, 2003, the FTSE/ASE 140 composite index was introduced, a new benchmark comprising the constituents of the FTSE/ASE 20, FTSE/ASE Mid 40 and FTSE/ASE Small Cap, in order to track cumulative performance. On January 2, 2006, the FTSE ATHEX International Index was introduced, a representative index for eligible companies, Greek and non-Greek, that trade on the ATHEX Common Trading Platform and are eligible for the Large Cap Category of the ATHEX.

The trading of shares on the Securities Market of the ATHEX is conducted through the remote placing of the orders into OASIS from the ATHEX member offices. Trading on the ATHEX takes place every week from Monday to Friday, except for public holidays. In general, the daily trading session is as follows according to Decision 22 of the Board of Directors of the ATHEX: for the Large Cap Category, the auction session is from 13:45 to between 13:58 and 14:00, pre-trading session from 10:15 to between 10:28 and 10:30, continuous trading from 10:30 to 17:00, the closing auction session

from 17:00 to between 17:09 and 17:11 and trading at the closing session from 17:11 to 17:20. For the Medium Cap Category and Small Cap Category, the auction session is from 12:00 to between 13:58 and 14:00, the pre-trading session is from 10:15 to between 10:28 and 10:30 and continuous trading is from 10:30 to 17:00 and then from 17:00 to 17:20. The ATHEX Regulation and the Decision 22/2008 of the Board of Directors of the ATHEX, as amended, contains detailed provisions regarding the trading of shares and other securities listed on the different categories of the Securities Market of the ATHEX.

In principle, all share prices of shares classified under the Large Cap Category are eligible for maximum +/-30% fluctuations from the "opening price" (as the latter is defined in the ATHEX Regulation and Decision 22/2008 of the Board of Directors of the ATHEX, as amended). The rights on shares of this category fluctuate freely. All market prices of shares classified under the Small and Medium Cap the Low Dispersion, Low Liquidity & Special Features and the Under Surveillance Category are eligible for escalated fluctuation, starting from +/-10% from the "opening price" (as the latter is defined in the ATHEX Regulation and the Decision 22/2008 of the Board of Directors of the ATHEX, as amended). Rights on shares of these categories also fluctuate freely. However, if the market price of a share classified under these two categories remains at the best bid offer (i.e. if all incoming purchase orders are at the upper limit or the sale orders are at the lower limit) for 15 minutes, then the daily fluctuation limit is extended to +/-20%. Further, securities that are newly listed on the ATHEX (unless already listed on another stock exchange where specific fluctuation limits are applicable), as well as re-traded securities, previously being under suspension for a period exceeding three months, are allowed to fluctuate freely during the first three sessions of their listing. Finally, securities classified under the Fixed Income Securities Category are allowed to fluctuate freely while units traded in the Exchange Traded Funds Category are allowed to fluctuate up to +/-30% from the "opening price" (as the latter is defined in the ATHEX Regulation, as currently applicable, and the Decision 22/2008 of the Board of Directors of the ATHEX, as amended). Moreover, pursuant to the ATHEX Regulation, the ATHEX introduced volatility interrupters to check abrupt share price changes in the Large Cap and Exchange Traded Funds Categories. In general, volatility interrupters allow for the automated cessation of trading of a share and the carrying out of a call auction when: (i) the share price changes 10% or more from the opening price; and (ii) the transaction to be carried out represents a large variation (i.e., approximately 2% change) compared with the previous one. After the temporary cessation of trading, a call auction is carried out to determine the "effective" price for the share. The particular process and details for the implementation of the volatility interrupters are specifically set forth in the Decision 22/2008 of the Board of Directors of the ATHEX, as amended.

Simple block trades of shares, that is pre-agreed trades, with an "average daily turnover" (as defined in the ATHEX Regulation):

The aforementioned provisions regarding block trades became effective as of January 1, 2009.

All prices of completed block trades are communicated to the ATHEX through OASIS and published in a separate section of the Official List of the ATHEX, although such prices are not shown as the last traded price. Trades are noted in the official register of the ATHEX, and all information on bids and offers is made available to Reuters on a continuous basis.

Shares are traded in lots of one. Prices of all securities listed on the ATHEX are published in the Official List of the ATHEX. Over-the-counter transactions are now free in the context of the MiFID

rules. Over-the-counter transactions may be settled free of payment or delivery versus payment and a fee depending upon the way the over-the-counter transaction is effected, on the transfer value applies for both parties, currently varying between 0.35% and 0.08%.

There are no exchange controls in Greece that would restrict the payment of dividends or other capital distributions to a holder of ordinary shares outside Greece or that would affect the right of a non-Greek holder of ordinary shares to dispose of his or her ordinary shares and receive the proceeds of such disposal outside Greece.

In 1997, Greek Law 2533/1997 created a derivatives exchange modeled after other European derivatives exchanges. According to this law, the Athens Derivatives Exchange, known as "ADEX", operated separately from the ATHEX, was organized as a corporate entity. In 2002, by virtue of Greek Law 2937/2001, ADEX S.A. merged with Athens Securities Exchange SA. The Derivatives Market of the ATHEX now constitutes one of the two markets of the ATHEX.

The Derivatives Market posted an increase in the volume of transactions in 2009. The 2009 average daily number of contracts amounted to 43,616, an increase of 9.2% compared to an average volume of 39,930 contracts in 2008.

In connection with the development of the Greek capital markets, the ATHEX, in cooperation with the Athens Derivatives Exchange Clearing House (or "ADECH") and the CSD (both currently under HELEX), have been developing the ability for investors to engage in stock lending transactions, by short selling shares listed on the ATHEX, with a simultaneous or previous borrowing of shares to be sold by the ADECH. The stock lending from the ADECH is made through an agreement of purchase of shares with a stock reverse repo through trading of the corresponding product.

The purchase of shares on credit (margin accounts) can be made available by members of the ATHEX to their clients/investors, using their investments as collateral, pursuant to a written agreement between the ATHEX member and its client. The provision of credit is possible following the completion of the relevant regulatory framework, i.e., decisions of the HCMC, in accordance with article 6 paragraph 1 of Greek Law 2843/2000, the amendments of the DSS Regulation, as well as the Act of the Governor of the Bank of Greece, in accordance with the article 6 paragraph 2 of the Greek Law 2843/2000.

Under Greek Law 2843/2000, the initial margin is set to 40% (minimum) of the market value of the investor's "collateral portfolio". This percentage level can be changed by act of the Governor of the Bank of Greece after a decision by the Board of Directors of the HCMC. It should be noticed that the ATHEX members have the flexibility to require higher initial and maintenance margins provided that the investor is given prior notice and an express provision is included in the relevant contract.

Pursuant to Act No. 2474/31.5.2001, as amended by Acts No. 2567/23.11.05 and No. 2599/2.11.2007, of the Governor of the Bank of Greece, the maintenance margin on brokerage margin accounts is set at 30% of the market value of the investor's "collateral portfolio".

Margin accounts contribute to the improvement of the liquidity of the market. They enable the investor to buy new shares by offering as "collateral" the shares that composed his or her initial portfolio. Investors generally use margin accounts to increase their purchasing power.

Greek Law 3301/2004 transposed into Greek law the Collateral Directive (Directive 2002/47/EC), thereby facilitating the use of securities listed on the ATHEX as collateral for entities falling within its scope, in particular simplifying the procedure for the enforcement of such collateral.

The Bank's Articles of Association (and English translation thereof), as amended on December 2011, are included as Exhibit 1 to this Annual Report. The required information regarding the Bank's Articles of association is stated below.

NBG and its subsidiaries are party to various contracts in the ordinary course of business. For the years ended December 31, 2010 and 2011, there have been no material contracts entered into outside the ordinary course of business apart from the following.

In March 2007, the Bank entered into an agreement (the "IFC Agreement") with the IFC whereby the IFC purchased 5% of the ordinary shares of Finansbank (the "IFC Shares") from the Bank at the date of the agreement. The agreed purchase price for the IFC Shares was US$259.2 million in cash. The agreement included an option for IFC to sell its shares back to NBG (the "put option") and another option for NBG to buy the shares from IFC (the "call option"). Furthermore, IFC can only sell those shares to a third party with a written consent from NBG.

At any time during the put option period (the period commencing from the date that the financial statements of the financial year ending after the fifth anniversary of the signing of the IFC Agreement have been delivered to the IFC but not later than six months after the respective year-end, and ending on the date the IFC ceases to hold any shares in Finansbank), the IFC shall have the right to sell and the Bank shall be obligated to purchase all or part of the IFC Shares at the higher of fair market value per share (as determined by one of nine reputable investment banks designated by the IFC and the Bank acting jointly) and the compounded share price per share, i.e. the aggregate amount corresponding to the cost to the IFC for acquiring the IFC Shares compounded semi-annually at the rate of six-month LIBOR plus 25 basis points divided by the number of shares.

At any time during the call option period (the period commencing from the date that the audited financial statements of the financial year ending after the seventh anniversary of the signing of the IFC Agreement have been delivered to the IFC and ending on the date the IFC ceases to hold any shares in Finansbank), the Bank shall have the right to purchase and IFC shall be obligated to sell all or part of the IFC Shares at the higher of fair market value per share (as determined by one of nine reputable investment banks designated by the IFC and the Bank acting jointly) and the compounded share price per share, i.e. the aggregate amount corresponding to the cost to the IFC for acquiring the IFC Shares compounded semi-annually at the rate of six-month LIBOR plus 25 basis points divided by the number of shares.

All forms of capital movement in and out of Greece have been liberalized pursuant to Presidential Decrees 96/1993 and 104/1994 (implementing Directives 1988/361/EEC and 1992/122/EEC) and corresponding acts of the Governor of the Bank of Greece. Foreign investors may purchase securities listed on the ATHEX, as well as Hellenic Republic bonds and treasury bills. Repatriation of capital and

dividends and any other income on securities is fully liberalized subject to compliance with certain reporting procedures and requirements and payment of any applicable tax.

Depositary receipts may be placed in the custody of a bank, a securities company or a brokerage company, operating legally in Greece, as custodian on behalf of a shareholder. Banks and securities companies must issue a receipt to each shareholder for any securities in their custody.

The following is a summary of material U.S. federal income tax consequences of the purchase, ownership and disposition of ordinary shares, preference shares or ADRs by a U.S. Holder.

For the purposes of this summary, a "U.S. Holder" is a beneficial owner of ordinary shares, preference shares or ADRs that is, for U.S. federal income tax purposes, (i) a citizen of or an individual resident in the United States, (ii) a corporation created in or organized under the laws of the United States or any state thereof or the District of Columbia, (iii) an estate, the income of which is subject to U.S. federal income taxation regardless of its source, or (iv) a trust that is subject to U.S. tax on its worldwide income regardless of its source. If a partnership holds ordinary shares, preference shares or ADRs, the consequences to a partner will generally depend upon the status of the partner and the activities of the partnership. A partner of a partnership holding shares, preference shares or ADRs should consult its tax advisor regarding the associated tax consequences. The summary does not purport to be a comprehensive description of all of the tax consequences of the ownership or disposition of ordinary shares, preference shares or ADRs. In particular, this summary deals only with U.S. Holders that will hold ordinary shares, preference shares or ADRs as capital assets and does not address the tax treatment of special classes of U.S. Holders, such as financial institutions, tax-exempt entities, insurance companies, retirement plans, persons holding ordinary shares, preference shares or ADRs as part of a "straddle" or as part of a "synthetic security" or a hedging or conversion transaction or other integrated transaction, real estate investment trusts, regulated investment companies, partnerships, pass-through entities or persons who hold through partnerships or other pass-through entities, U.S. expatriates, persons subject to the alternative minimum tax, dealers or traders in securities, currencies or notional principal contracts, persons that own (or are deemed to own for U.S. federal income tax purposes) 10% or more of the voting stock of the Bank, holders who hold ordinary shares, preference shares or ADRs in connection with a trade, profession or vocation carried on in Greece (whether through a branch, agency or otherwise) and holders whose "functional currency" is not the U.S. dollar. Further, this discussion does not address any tax consequences applicable to holders of equity interests in a holder of ordinary shares, preference shares or ADRs. This summary is based upon current U.S. federal income tax law, including the U.S. Internal Revenue Code of 1986 (the "Code"), its legislative history, existing, temporary and proposed regulations thereunder, published rulings and court decisions, all of which are subject to change (possibly with retroactive effect); and the Convention Between the United States of America and the Kingdom of Greece (now the Hellenic Republic) for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, with effect from December 30, 1953 (the "Treaty").

Prospective purchasers should consult their tax advisors as to the consequences under U.S. federal, estate, gift, state, local and applicable foreign tax laws of the purchase, ownership and disposition of ordinary shares, preference shares and ADRs.

Holders of ADRs will generally be treated for U.S. federal income tax purposes as owners of the ordinary shares or preference shares underlying the ADRs. Accordingly, except as noted, the U.S. federal income tax consequences discussed below apply equally to holders of ordinary shares, preference shares and ADRs.

The taxation of ADRs listed on New York Stock Exchange held by a U.S. Holder falls outside the scope of Greek tax law; therefore there are no tax consequences in Greece for the U.S. Holder, unless a surrendering of the ADRs in exchange for the preference shares occurs. However it should be mentioned that to the extent that the dividends paid in respect of the underlying ordinary shares have been subject to withholding tax, the return on the ADRs received by a U.S. Holder may be impacted from such withholding. The gross amount of any distributions paid by the Bank to a U.S. Holder that are actually or constructively received by the U.S. Holder will generally be subject to U.S. federal income tax as dividend income to the extent paid out of current or accumulated earnings and profits of the Bank, as determined for U.S. federal income tax purposes. Such dividends will not be eligible for the dividends received deduction allowed to corporations.

The Bank does not maintain calculations of its earnings and profits under U.S. federal income tax principles. Therefore, a U.S. Holder should expect that a distribution will generally be treated as a dividend. The amount of any distribution of property other than cash will be the fair market value of that property on the date of the distribution.

Certain dividends received by non-corporate U.S. Holders before January 1, 2013 will be subject to a maximum income tax rate of 15%. This reduced income tax rate is only applicable to dividends paid by "qualified foreign corporations" (which term excludes "passive foreign investment companies", as defined below) and only with respect to ordinary shares, preference shares or ADRs held for a minimum holding period (generally, 61 days during the 121-day period beginning 60 days before the ex-dividend date). The Bank expects to be considered a qualified foreign corporation for this purpose.

The gross amount of dividends paid in euros will be included in the income of the relevant U.S. Holder in a U.S. dollar amount calculated by reference to the spot exchange rate in effect on the day the dividends are received by the U.S. Holder (or, in the case of the ADRs, by The Bank of New York Mellon, in its capacity as depositary) regardless of whether the payment is in fact converted into U.S. dollars. A U.S. Holder will have a basis in any euros distributed equal to their U.S. dollar value on the date they are received by the U.S. Holder (or, in the case of the ADRs, by The Bank of New York Mellon in its capacity as depositary). Any gain or loss recognized upon a subsequent disposition of euros will generally be U.S. source ordinary income or loss. If euros are converted into U.S. dollars on the date of the receipt, the U.S. Holder should not be required to recognize any foreign currency gain or loss in respect of the receipt of euros as dividends.

The 2011 Greek tax law re-introduced a withholding tax on dividend distributions by Greek sociétés anonymes, such as the Bank, including any dividends paid to U.S. Holders of ordinary shares and preference shares. As a result, any distributions of profits approved by the General Meeting of the shareholders as from January 1, 2012 will be subject to a 25% withholding tax. The deduction and withholding of the relevant withholding tax from any dividends extinguishes the beneficiary's Greek income tax liability with respect to such dividend. As discussed in more detail below, under the Treaty, U.S. Holders of the ordinary shares or preference shares may be able to claim a foreign tax credit with regard to any Greek withholding tax that has been applied. It should be noted that especially for dividends payable under the preference shares issued by the Bank to a U.S. Holder a gross up clause applies and payments are grossed up for the corresponding amount of tax. Dividends paid by the Bank will be treated as foreign source income for U.S. foreign tax credit limitation purposes. The limitation on foreign taxes eligible for the U.S. foreign tax credit is calculated separately with respect to specific classes of income. Income received with respect to ordinary shares, preference shares or ADRs generally will constitute "passive category income" or "general category income". For purposes of calculating a U.S. Holder's foreign tax credit limitation, the amount of foreign source dividend income subject to the reduced dividend income tax rate that is taken into account for purposes of calculating the U.S. Holder's U.S. foreign tax credit limitation must be reduced by the "rate differential portion"

of such dividend. The rules relating to foreign tax credits and the timing thereof are complex. U.S. Holders should consult their tax advisors regarding the availability of foreign tax credits under their particular circumstances.

Subject to the discussion below under this Item 10.E, "Taxation—Passive Foreign Investment Company Status", gain or loss realized by a U.S. Holder on the sale or other disposition of ordinary shares, preference shares or ADRs will be subject to U.S. federal income taxation as capital gain or loss in an amount equal to the difference between the U.S. Holder's adjusted tax basis in the ordinary shares, preference shares or ADRs and the amount realized on the disposition. Such gain or loss generally will be treated as long-term capital gain or loss if the ordinary shares, preference shares or ADRs have been held for more than one year. Capital gains of non-corporate U.S. Holders derived from capital assets held for more than one year are eligible for reduced rates of taxation. The deductibility of capital losses is subject to significant limitations. Any gain or loss realized will generally be treated as derived from U.S. sources.

Except as otherwise provided in the next paragraph, the Bank believes that for U.S. federal income tax purposes, U.S. Holders should generally recognize gain or loss upon the redemption or mandatory repurchase of their preference shares or the underlying ADRs in an amount equal to the excess, if any, of the cash and the fair market value of any property received in the redemption (other than amounts attributable to accrued but otherwise unpaid dividends) over the U.S. Holder's adjusted tax basis in the preference shares or the underlying ADRs surrendered. That capital gain or loss will be long-term capital gain or loss if the U.S. Holder's holding period in respect of such preference shares or the underlying ADRs is more than one year. Any cash and the fair market value of any property received that is attributable to accrued dividends not previously recognized in income should be taxed as ordinary income.

Although the matter is not free from doubt, if the preference shares or the underlying ADRs are redeemed or mandatorily repurchased by the Bank, a portion of the redemption amount equal to the liquidation preference reduction amount may be characterized for U.S. federal income tax purposes as attributable to declared but otherwise unpaid dividends. In such an event, it is possible that U.S. Holders will recognize in a redemption or mandatory repurchase additional dividend income equal to the liquidation preference reduction amount, and a capital loss of the same amount. Under current law, any redemption or repurchase proceeds characterized as dividends for U.S. federal income tax purposes would be eligible for taxation at the reduced income tax rates available for foreign source dividend income as discussed above under Item 10.E, "Taxation—Dividends".

The U.S. federal income tax consequences of a redemption or mandatory repurchase for U.S. Holders that own, actually or constructively, other classes of stock of the Bank in addition to preference shares or the underlying ADRs may differ from that described above.

The surrender of ADRs in exchange for ordinary shares or preference shares (or vice versa) will not be a taxable event for U.S. federal income tax purposes and U.S. Holders will not recognize any gain or loss upon such an exchange.

If a U.S. Holder receives any foreign currency on the sale, exchange or disposition of ordinary shares or preference shares, such U.S. Holder generally will realize an amount equal to the U.S. dollar value of such foreign currency on the settlement date of such sale, exchange or disposition if (i) such U.S. Holder is a cash basis or electing accrual basis taxpayer and the ordinary shares are treated as being "traded on an established securities market" or (ii) such settlement date is also the date of such sale, exchange or disposition. If the foreign currency so received is converted to U.S. dollars on the settlement date, such U.S. Holder should not recognize foreign currency gain or loss on such conversion. If the foreign currency so received is not converted into U.S. dollars on the settlement date,

such U.S. Holder will have a basis in such foreign currency equal to its U.S. dollar value on the settlement date. Any gain or loss on a subsequent conversion or other disposition of such foreign currency generally will be treated as ordinary income or loss to such U.S. Holder and generally will be income or loss from sources within the United States for U.S. foreign tax credit purposes. Each U.S. Holder should consult their tax advisor regarding the U.S. federal income tax consequences of receiving foreign currency from the sale, exchange or other disposition of ordinary shares or preference shares.

The foregoing discussion of dividends and capital gains assumes that the Bank is not a passive foreign investment company (a "PFIC") for U.S. federal income tax purposes. Based upon (i) U.S. Treasury Regulations (the "Regulations") and (ii) the regulatory status of the Bank under local laws, its banking activities performed in the ordinary course of business (including lending, accepting deposits and depositing money in other banks), the proportion of its income derived from activities that are "bona fide" banking activities for U.S. federal income tax purposes and its securities activities performed in the ordinary course of business (including selling debt instruments to customers in a dealer capacity), the Bank believes that it was not a PFIC for 2011 (the latest period for which the determination can be made) and, based further on its present regulatory status under local laws, the present nature of its activities, and the present composition of its assets and sources of income, the Bank does not expect to be a PFIC for the current year or for any future years. However, because PFIC status is a factual determination made annually and because there are uncertainties in the application of the relevant rules, there can be no assurances that the Bank will not be considered to be a PFIC for any particular year.

If for any year in which a U.S. Holder held ordinary shares, preference shares or ADRs, the Bank were to qualify as a PFIC, the U.S. Holder would be subject to special rules with respect to (i) any gain realized on the sale or other disposition (including a pledge) of the ordinary shares, preference shares or ADRs and (ii) any "excess distribution" by the Bank to the U.S. Holder (generally, any distributions to the U.S. Holder in respect of the ordinary shares, preference shares or ADRs during a single taxable year to the extent the distributions exceed 125% of the average annual distributions received by the U.S. Holder in respect of the ordinary shares, preference shares or ADRs during the three preceding taxable years or, if shorter, the U.S. Holder's holding period for the ordinary shares, preference shares or ADRs). Under these rules, (i) the gain or excess distribution would be allocated ratably over the U.S. Holder's holding period for the ordinary shares, preference shares or ADRs, (ii) the amount allocated to the taxable year in which the gain or excess distribution was realized would be taxable as ordinary income, (iii) the amount allocated to each prior year, with certain exceptions, would be subject to tax at the highest tax rate in effect for that year and (iv) the interest charge generally applicable to underpayments of tax would be imposed in respect of the tax attributable to each such year.

U.S. Holders can avoid the interest charge by making a "mark to market election" with respect to the ordinary shares, preference shares and ADRs, provided that the relevant ordinary shares, preference shares or ADRs are "marketable" within the meaning of the Regulations. The ordinary shares, preference shares and ADRs will not be considered "marketable" for purposes of this election unless the exchange or market on which the relevant ordinary shares, preference shares or ADRs are regularly traded is a qualified stock exchange or other market. Under the Regulations, a stock exchange is a "qualified stock exchange" if it is either one of the recognized U.S. stock exchanges, such as the NYSE. Alternatively, a foreign stock exchange, such as the ATHEX, may constitute a qualified exchange if it meets certain trading, listing, financial disclosure and other requirements set forth in the Regulations. The mark to market election will remain in effect unless the Internal Revenue Service ("IRS") consents to revocation, or until the relevant ordinary shares, preference shares or ADRs cease to be marketable. A U.S. Holder that makes a mark to market election generally will, subject to certain limitations, be required to take into account the difference, if any, between the fair market value and

the adjusted tax basis of its ordinary shares, preference shares or ADRs at the end of a taxable year, as ordinary income (or, subject to certain limitations, ordinary loss) in calculating its income for such year. In the case of a mark to market election, gains from an actual sale or other disposition of the ordinary shares, preference shares or ADRs will be treated as ordinary income, and any losses incurred on a sale or other disposition of the ordinary shares, preference shares or ADRs will be treated as ordinary loss to the extent of any net mark to market gains for prior years.

Special rules apply with respect to the calculation of the amount of the foreign tax credit with respect to excess distributions by a PFIC. If the ordinary shares, preference shares or ADRs constitute equity interests in a PFIC, a U.S. Holder will be required to make an annual return on IRS Form 8621 regarding its investment in a PFIC.

U.S. Holders may be subject to the information reporting requirements of the Code, as well as to backup withholding on the payment of dividends on, and the proceeds received from the disposition of, ordinary shares, preference shares or ADRs. Backup withholding may apply if a U.S. Holder (i) fails to furnish its taxpayer identification number ("TIN"), which, in the case of an individual, is his or her social security number; (ii) fails to provide certification of exempt status; (iii) is notified by the IRS that he or she has failed properly to report payments of interest and dividends; (iv) under certain circumstances, fails to certify, under penalty of perjury, that he or she has furnished a correct TIN or the Bank has been notified by the IRS that such U.S. Holder is subject to backup withholding for failure to furnish a correct TIN; or (v) otherwise fails to comply with the applicable requirements of the backup withholding rules.

U.S. Holders should consult their tax advisors regarding their qualification for exemption from backup withholding and the procedure for obtaining such an exemption, if applicable. The amount withheld from a payment to a U.S. Holder under the backup withholding rules generally will be allowed as a credit against such holder's U.S. federal income tax liability and may entitle such holder to a refund, provided that the required information is timely furnished to the IRS.

A U.S. Holder that participates in any "reportable transaction" (as defined in the Regulations) must attach to its U.S. federal income tax return a disclosure statement on IRS Form 8886. U.S. Holders are urged to consult their tax advisor as to the possible obligation to file IRS Form 8886 with respect to the sale, exchange or other disposition of any foreign currency received as a dividend on, or as proceeds from the sale, exchange or other disposition of ordinary shares, preference shares or ADRs.

The information set out above is a summary only and U.S. and other taxation may change from time to time. Prospective investors should consult their tax advisors as to the consequences of the purchase, ownership and disposition of ordinary shares, preference shares and ADRs including, in particular, the effects of the tax laws of any other jurisdiction.

NBG is subject to the informational requirements of the U.S. Securities Exchange Act of 1934, as amended (the "Exchange Act"), applicable to foreign private issuers. In accordance with these requirements, NBG files reports and other information with the Securities and Exchange Commission ("SEC"). These materials may be obtained, upon written request, from The Bank of New York Mellon, as depositary, at its Corporate Trust Office located at 101 Barclay Street, New York, New York 10286. Such reports and other information can be inspected without charge and copied at prescribed rates at the public reference room maintained by the SEC at 100 F Street, N.W., Washington, D.C. 20549. Copies of such material and any part thereof will also be available by mail from the Public Reference Section of the SEC at 100 F Street, N.W., Washington, D.C. 20549, at prescribed rates. Also, certain reports and other information concerning NBG will be available for inspection at the offices of the NYSE at 20 Broad Street, New York, New York 10005.

The Hellenic Republic directly holds 1.2% of the Bank's ordinary shares acquired from the exercise of its preemptive right to subscribe for new ordinary shares that were not subscribed by holders of rights pursuant to the rights issue undertaken by the Bank in July 2009 and in October 2010. See Item 3.D, "Risk Factors—Risks Relating to Our Business". Furthermore, certain state- related entities, primarily pension funds (most of whose boards of directors are appointed by the Hellenic Republic) may exercise indirect influence on the Bank. As at April 27, 2012, certain domestic pension funds owned approximately 16.4% of our share capital and other domestic public sector related legal entities and the Church of Greece owned approximately 7.5%. See Item 3.D, "Risk Factors—Risks Relating to Our Business—The Hellenic Republic and state-related entities may have an important influence on the Bank and Item 7.A, "Major Shareholders".

Following implementation of the preference share facility of the Hellenic Republic Bank Support Plan, the Hellenic Republic currently owns all of the 270 million non-transferable redeemable preference shares issued under this facility. See also Item 7.A, "Major Shareholders—State interests". These preference shares carry voting rights at the general meeting of preferred shareholders. The Hellenic Republic has also appointed a representative to the Bank's Board of Directors who has veto power relating to corporate decisions both at the Board of Directors level and at the General Meeting on matters pertaining to Director and senior management compensation and dividend policy. See Item 6.E, "Share Ownership". The government-appointed director may only utilize his veto power following a decision of the Minister of Finance or if he considers that the relevant corporate decisions may jeopardize the interests of depositors or materially affect the solvency and orderly operation of the participating bank. The Bank originally was required to convert these preference shares into ordinary shares or another class of shares five years after issuance, if redemption of the preference shares by the Bank would cause its Tier I capital to fall below the minimum levels set by the Bank of Greece. In May 2010, Greek Law 3844/2010, which amended Greek Law 3723/2008, rendered such preference shares not mandatorily redeemable. However, if the preference shares are not redeemed within five years from their issuance and if the participating bank's general meeting of shareholders has not approved their redemption, the Greek Minister of Finance will impose, pursuant to a recommendation by the Bank of Greece, a gradual cumulative increase of 2% per year on the 10% fixed return provided for during the first five years from the issuance of the shares to the Hellenic Republic. For more information on the Hellenic Republic Bank Support Plan, please see Item 4.B, "Business Overview—The

Macroeconomic Environment in Greece—The Hellenic Republic's Economic Crisis, the successful sovereign debt restructuring (PSI) and the agreement on the Program for Greece".

Following its implementation, the HFSF will have certain powers over credit institutions receiving capital from the HFSF to be exercised following consultation with the Bank of Greece and will have on its Board of Directors appointees by the Bank of Greece and the Hellenic Republic with one observer to be nominated by the ECB and the EC. In addition, any shares remaining in the HFSF at the time it ceases its activities will be transferred to the Hellenic Republic. See Item 4.B, "Business Overview—The Macroeconomic Environment in Greece—the Hellenic Republic's Economic Crisis".

The Hellenic Republic, including state-related entities, is a large customer of the Bank in terms of loans and deposits. At December 31, 2011, 16.1% of the Bank's outstanding gross loans were to the Hellenic Republic and state-related entities, and 2.8% of the Bank's deposits were from the Hellenic Republic and state-related entities. The commercial relationship between the Bank, the Hellenic Republic and other state-owned enterprises is conducted on a normal "arm's length" basis. The Group's senior management believes that the commercially-oriented strategy currently being implemented will continue for the foreseeable future.

Through various agencies, including the Bank of Greece, the Hellenic Republic is also the regulator of our business activities. For more information see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece".

Market risk arises from the uncertainty concerning changes in market prices and rates (including interest rates, equity and bond prices and foreign exchange rates) and their levels of volatility. In recent years, we have expanded our trading activities to include a wide variety of financial products in order to enhance our profitability and service our clientele. These trading activities require us to assume market risk, which we seek to identify, estimate, monitor and manage effectively through a framework of principles, measurement processes and a valid set of limits that apply to all of the Group's transactions. The most significant types of market risk for the Group are interest rate risk, equity risk and foreign exchange risk.

Interest rate risk is the risk related to the potential loss on the Group's portfolio due to adverse movements in interest rates. A principal source of interest rate risk exposure arises from our trading and AFS bond portfolios and our interest rate exchange-traded and over-the-counter transactions.

More specifically, the Bank retains a substantial portfolio of Greek sovereign debt and also holds positions in Greek and international corporate bonds. In order to provide a hedge for the interest rate risk arising from the position in fixed rate Greek government bonds, we enter into future contracts on two, five and ten-year German government bonds. To a lesser extent, the Bank maintains positions in bond and interest rate futures for speculative purposes.

Additionally, we are active in the swap market and engage in vanilla and more sophisticated deals for hedging and proprietary purposes. As a means of hedging, we use swaps to eliminate the interest rate risk arising from our positions in fixed rate bonds, mostly Greek government debt.

Apart from the Bank, the most significant source of market risk on a Group level relates to Finansbank's portfolio. Of the three types of market risk (interest rate, equity and foreign exchange risk), Finansbank is mostly exposed to and has to manage the interest rate risk that derives from the positions it retains in Turkish government bonds, denominated mostly in TL. In addition, Finansbank enters into swap transactions either for hedging purposes, or for proprietary reasons. As a means of hedging, Finansbank enters into swap transactions in order to hedge the interest rate risk of its Eurobond portfolio, which consists of Turkish government bonds denominated in foreign currency.

Moreover, Finansbank obtains liquidity in U.S. dollars which are then converted into TL through Cross Currency Interest Rate Swaps, in order to offer loans to its clientele. These Cross Currency Interest Rate Swaps also act as a hedge of the interest rate risk inherent in Finansbank's loan portfolio.

Equity risk is the risk related to the potential loss that might occur due to adverse movements in the prices of stocks and equity indices. The Group holds a portfolio of stocks, the majority of which are traded on the ATHEX, and also retains positions in stock and equity index derivatives traded on the ATHEX and international exchanges. Our cash portfolio comprises of trading (i.e. short-term) and AFS (i.e. long-term) positions. Our portfolio of equity derivatives is held for trading purposes and as a mechanism to hedge the equity risk arising from our cash position and from the equity-linked products offered to our clientele. In the same context and to a lesser extent, we also enter into over-the-counter equity transactions for trading and hedging purposes.

Foreign exchange risk is the risk related to the potential loss due to adverse movements in foreign exchange rates. The foreign exchange risk derives from the Bank's net Open Currency Position ("OCP"), which primarily consists of transactions in foreign currencies (i.e. foreign exchange spot and forward deals) executed by our Treasury Division. The OCP is distinguished between Trading and Structural OCP. The Structural OCP contains all of the Bank's assets and liabilities in foreign currency (i.e. loans, deposits, etc.) along with the foreign exchange transactions performed by the Treasury Division.

On a Group level, the foreign exchange risk derives from the OCP of each subsidiary, due to the transactions in foreign currencies performed by the local treasury divisions.

The Group trades in all major currencies, holding mainly short-term positions for trading purposes and for servicing its institutional, corporate, domestic and international clientele. According to the Bank's policy, at the end of each trading day, the OCP should remain within the limits set by the Treasury and the GMORMD. The same policy applies to all of our subsidiaries.

Furthermore, the Group actively manages its exposure to TL, in order to reduce the volatility in the Group's equity arising from the conversion of Finansbank's assets and liabilities from TL into euro.

The Bank estimates the market risk of its trading and AFS portfolios using the VaR methodology. This has been implemented trough RiskWatch by Algorithmics. In particular, the Bank has adopted the variance-covariance methodology, with a 99% confidence interval and a one-day holding period. The VaR is calculated on a daily basis for the Bank's trading and AFS portfolios, along with the VaR per risk type (interest rate, equity and foreign exchange risk). The approach and the VaR calculations have been thoroughly examined and approved by the Bank of Greece, as well as by internal auditors and external consultants.

The VaR estimates are used internally as a risk management tool, as well as for regulatory purposes. For internal use, the GMORMD calculates on a daily basis the VaR of the Bank's Trading and AFS portfolios, using the latest 75 exponentially weighted daily observations. The risk factors relevant to the financial products in NBG's portfolio are interest rates, equity indices, foreign exchange rates and commodity prices. Currently the number of risk factors involved in the VaR calculations is 929. Additionally, NBG calculates the VaR of the Bank's portfolios by applying the Historical Simulation approach, for comparative purposes.

The Bank has also established a framework of VaR limits in order to control and manage more efficiently the risks to which it is exposed. These limits have been determined by reference to worldwide best practices; they refer not only to specific types of market risk, such as interest rate, foreign exchange and equity risk, but also to the overall market risk of the Bank's trading and AFS portfolios.

The table below presents the Bank's VaR (99%, 1-day) for 2011 and 2010 respectively:

The most significant type of market risk to which the Bank is exposed is interest rate risk. This mainly arises from the Bank's Trading and AFS bond portfolios, as well as from the interest rate derivatives, both exchange traded and over-the-counter. In order to measure and manage this risk, NBG calculates the Interest Rate ("IR") VaR of its portfolios on a daily basis. The level of IR VaR mostly depends on the volatility of the underlying interest rates and the positions in the portfolio.

In the first quarter of 2010, interest rate volatility remained at relatively low levels. However, the volatility of the EUR and USD interest rates began to increase significantly from the middle of the second quarter. The volatility remained at the same, high, levels until the end of the year. This increased volatility led to higher total VaR estimations for the Bank for the year ended December 31, 2010.

On the other hand, during 2010, a large portion of the Bank's Greek government bonds was transferred from the trading and AFS categories to HTM. Since the VaR model measures the Market Risk of any instruments held with the intention to be traded or sold, the positions held in HTM are excluded from the VaR calculations. Therefore, the transfer of a large portion of Greek government bonds from the trading and AFS categories to HTM caused the IR and Total VaR to decrease for the year ended December 31, 2010.

In the first half of 2011, the main reason that affected the VaR estimations was the change in the hedge maintained by the Bank to manage its interest rate exposure. More specifically, there was a decrease in the number of futures contracts and swap transactions, which are used to hedge the interest rate risk of the Bank's Greek government bonds. This caused the IR and Total VaR to increase. Moreover, during the second half of the year, the volatility of the EUR interest rates began to increase significantly, leading to higher VaR estimations for the Bank.

Other than the Bank, on a Group level, market risk mainly derives from the positions held in Finansbank's trading and AFS portfolios (market risk undertaken by the rest of our subsidiaries is insignificant). In order to monitor and efficiently manage market risk, Finansbank calculates VaR on a daily basis for both its trading and AFS portfolios, as well as the VaR per risk type (interest rate,

equity and foreign exchange risk). These calculations are based on a 99% confidence interval and 1-day holding period. The system used is RiskWatch.

Finansbank has also established a framework of VaR limits, similar to the one that the Bank has in place.

The change in Finansbank's Total VaR is mainly attributed to the change in the IR VaR. During the first months of the year, the Turkish Government interest rates increased, thus causing the respective volatility to increase and this led to a higher VaR. Then, since interest rates remained at the same level until the end of the second quarter, the volatility returned to the previous levels and the IR and Total VaR gradually decreased. However, during the last quarter of the year, the Turkish Government interest rates, and the respective volatility, began to increase again, which resulted to higher VaR estimations for Finansbank for the year ended December 30, 2011.

Finally, on a Group level, the VaR (99%, 1-day) estimations for 2011 and 2010 are presented in the table below:

Our VaR model is based on certain theoretical assumptions, which under extreme market conditions might not capture the maximum loss the Bank would suffer. The restrictions of our methodology are summarized as follows:

The Bank performs back-testing on a daily basis, in order to verify the predictive power of the VaR model. The calculations refer only to the Bank's trading positions, in accordance with the guidelines from the Bank of Greece, and involve the comparison of "hypothetical" daily gains and losses with the respective estimates of the VaR model used for regulatory purposes. The aim of back-testing is to examine whether the hypothetical change in the value of the portfolio, due to the actual movements in the prices of the underlying risk factors, is captured by the VaR estimate of that day. The procedure of back-testing is summarized as follows:

Any excess of the hypothetical losses over the VaR estimate is immediately reported to the Bank of Greece within five (5) business days. Back-testing is applied on the Bank's end-of-day positions and does not take into account intra-day transactions. During each of 2010 and 2011, there were only 2 exceptions where the back-testing result exceeded the respective VaR calculations.

For the same reasons, Finansbank also performs back-testing on a daily basis, following a procedure similar to the one that the Bank has established. In 2011, there were 7 exceptions where the back-testing result exceeded the respective VaR calculations.

As stated above, the VaR model is based on certain theoretical assumptions, which do not fully capture the potential "tail events" in the markets.

To enhance the predictability of our VaR model and minimize the effect of the aforementioned limitations, we perform stress testing on a weekly basis. The aim of stress testing is to evaluate the gains or losses that may occur under extreme market conditions. Stress testing applies on both trading

and AFS portfolios and the scenarios used have been approved by our regulatory authorities. These scenarios are presented in the following tables:

Moreover, stress test analysis is also performed by Finansbank on its trading and AFS portfolios, on a monthly basis. The scenarios refer to extreme movements of interest rates and foreign exchange prices and are based on the latest financial crises which have taken place in Turkey.

Country risk is the risk that political or economic changes in a foreign country, could adversely impact our exposure to that country. The main categories of country risk consist of sovereign risk, convertibility risk and transfer risk. Sovereign risk denotes a foreign government's capacity and willingness to repay its debt or other obligations. Convertibility and transfer risk arise when a borrower is unable to convert funds from local to foreign currency in order to repay external obligations. Therefore, country risk refers to all cross border transactions, either with a central government, or with a financial institution, a corporate / retail client.

The balance sheet items which potentially entail country risk are the following:

In this context, the GMORMD monitors the country risk arising from the Bank's operations on a daily basis, mainly focusing on the countries of South East Europe, Turkey, Egypt and South Africa, where the Group has presence.

Additionally, we perform stress test on our country risk on a regular basis and the results are reported to the regulatory authorities.

Counterparty risk for the Group stems from the over-the-counter transactions, the money market placements and the repo/reverse repo agreements which it transacts. It is the risk arising from an obligor's failure to meet its contractual obligations. For the efficient management of counterparty risk, the Bank has established a framework of counterparty limits. The GMORMD is responsible for the setting and monitoring of the limits.

Counterparty limits are based on the credit rating of the financial institutions. The credit ratings are provided by internationally recognized ratings agencies, in particular by Moody's and Standard & Poor's. According to the Bank's policy, if agencies diverge on the creditworthiness of a financial institution, the lowest one will be taken into consideration.

The counterparty limits apply to all financial instruments in which the Treasury is active in the interbank market. The limits framework is revised according to the business needs of the Bank and the prevailing conditions in international and domestic financial markets. A similar limit structure for the management of counterparty risk is enforced across all of the Group's subsidiaries.

The Group seeks to reduce counterparty risk by standardizing relationships with counterparties through ISDA and GMRA contracts, which encompass all necessary netting and margining clauses. Additionally, for almost all active counterparties in over-the-counter transactions, CSAs have been put into effect, so that net current exposures are managed through margin accounts on a daily basis, through the exchange of cash collateral.

The Group avoids taking positions on derivative contracts where the values of the underlying assets are highly correlated with the credit quality of the counterparty.

The estimation of counterparty exposure depends on the type of the financial product. In the case of money market placements the exposure is equal to the face amount of the deals. In over-the-counter transactions, the exposure to counterparty risk is calculated based on the Credit Exposure Factors for the relevant exposure period of the deals.

We made certain assumptions in calculating fair values for presentation in the U.S. GAAP Financial Statements. These assumptions are stated in Note 36 "Fair value of financial instruments" to the U.S. GAAP Financial Statements included in this Annual Report, and include the notion that assets and liabilities that re-price or mature within a relatively short period of time have a fair value that approximates their carrying amount. However, for the purposes of the sensitivity analysis below, we included such assets and liabilities and calculated the effect on the fair value of all positions. The effect that financial instruments, which re-price frequently or have short periods to maturity, had on the revised fair values was immaterial.

We performed a sensitivity analysis to estimate the potential impact of certain changes in interest rates on the fair value of financial instruments held as at December 31, 2011, which are not included in the VaR model developed by the Bank. The analysis below was performed based on the following assumptions:

	December 31, 2011				Market Value Change						Market Value Change

	Carrying Amount		Fair value		+100bps			-100bps			+50bps			-50bps
	(EUR in thousands)
Assets
Deposits with central bank		2,898,998		2,898,998		(5,945	)		5,946			(5,378	)		5,382
Securities purchased under agreements to resell		673,187		673,187		(1,724	)		1,726			(2,548	)		2,372
Interest bearing deposits with banks		3,767,624		3,771,226		(12,319	)		12,310			(11,475	)		10,781
Held to Maturity securities		1,002,202		963,301		(70,247	)		73,394			(64,245	)		69,330
Net loans		69,452,222		69,327,664		(383,353	)		397,811			(478,543	)		502,243

Total interest rate sensitive assets		77,794,233		77,634,376		(473,588	)		491,187			(562,189	)		590,108

Liabilities
Total deposits		91,575,302		91,586,745		132,736			(130,273	)		135,707			(117,446	)
Securities sold under agreements to repurchase		1,302,239		1,302,239		23,463			(23,479	)		21,240			(21,241	)
Other borrowed funds		925,971		920,699		4,314			(4,391	)		2,884			(2,919	)
Long term debt		2,937,371		2,897,932		72,892			(80,071	)		108,959			(117,740	)

Total interest rate sensitive liabilities		96,740,883		96,707,615		233,405			(238,214	)		268,790			(259,346	)

Total interest rate balance sheet sensitivity						(706,993	)		729,401			(830,979	)		849,454

	December 31, 2010 As restated⁽¹⁾				Market Value Change						Market Value Change

	Carrying Amount		Fair value		+100bps			-100bps			+50bps			-50bps
	(EUR in thousands)
Assets
Deposits with central bank		2,961,828		2,961,828		(2,157	)		2,161			(1,085	)		1,086
Securities purchased under agreements to resell		146,302		146,302		(2,099	)		1,923			(1,050	)		1,052
Interest bearing deposits with banks		6,398,767		6,399,000		(8,254	)		7,565			(4,691	)		4,679
Held to Maturity securities		3,598,285		2,620,525		(46,407	)		51,883			(28,686	)		31,443
Net loans		75,863,035		75,779,314		(546,556	)		579,396			(313,197	)		323,468

Total interest rate sensitive assets		88,968,217		87,906,969		(605,473	)		642,928			(348,709	)		361,728

Liabilities
Total deposits		93,895,481		93,882,661		102,672			(99,174	)		56,854			(56,400	)
Securities sold under agreements to repurchase		3,538,289		3,538,289		8,563			(8,563	)		4,314			(4,328	)
Other borrowed funds		1,111,663		1,109,408		3,304			(3,359	)		2,209			(2,234	)
Long term debt		3,805,950		3,930,350		106,728			(115,623	)		56,814			(59,724	)

Total interest rate sensitive liabilities		102,351,383		102,460,708		221,267			(226,719	)		120,191			(122,686	)

Total interest rate balance sheet sensitivity						(826,740	)		869,647			(468,900	)		484,414

We deal in several currencies thus a sensitivity analysis has been performed to show the effects that a simultaneous change of all currencies against the euro would have on our financial position.

The foreign currency exchange sensitivity analysis below was performed based on the following assumptions:

	December 31, 2011				Market Value Change

	Carrying amount		Fair value		10%			-10%
	(EUR in thousands)
Assets
Cash and due from banks		1,717,736		1,717,736		83,830			(68,588	)
Deposits with central bank		2,898,998		2,898,998		62,386			(51,043	)
Securities purchased under agreements to resell		673,187		673,187		36,944			(30,227	)
Interest bearing deposits with banks		3,767,624		3,771,226		97,892			(80,093	)
Held to Maturity securities		1,002,202		963,301		1,437			(1,176	)
Net loans		69,452,222		69,327,664		2,055,985			(1,682,170	)
Accrued interest receivable		1,156,229		1,156,229		27,867			(22,800	)

Total foreign exchange sensitive assets		80,668,198		80,508,341		2,366,341			(1,936,097	)

Liabilities
Total deposits		91,575,302		91,586,745		(2,037,662	)		1,667,178
Securities sold under agreements to repurchase		1,302,239		1,302,239		(67,140	)		54,932
Other borrowed funds		925,971		920,699		(76,666	)		62,727
Long-term debt		2,937,371		2,897,932		(78,709	)		64,398

Total foreign exchange sensitive liabilities		96,740,883		96,707,615		(2,260,177	)		1,849,235

Total foreign exchange balance sheet sensitivity						106,164			(86,862	)

	December 31, 2010 As restated⁽¹⁾				Market Value Change

	Carrying amount		Fair value		10%			-10%
	(EUR in thousands)
Assets
Cash and due from banks		1,436,157		1,436,157		75,841			(62,052	)
Deposits with central bank		2,961,828		2,961,828		112,400			(91,964	)
Securities purchased under agreements to resell		146,302		146,302		5,534			(4,528	)
Interest bearing deposits with banks		6,398,767		6,399,000		56,010			(45,827	)
Held to Maturity securities		3,598,285		2,620,525		1,467			(1,200	)
Net loans		75,863,035		75,779,314		2,119,543			(1,734,172	)
Accrued interest receivable		1,195,730		1,195,730		31,803			(26,020	)

Total foreign exchange sensitive assets		91,600,104		90,538,856		2,402,598			(1,965,763	)

Liabilities
Total deposits		93,895,481		93,882,661		(2,233,842	)		1,827,689
Securities sold under agreements to repurchase		3,538,289		3,538,289		(64,325	)		52,629
Other borrowed funds		1,111,663		1,109,408		(81,804	)		66,930
Long-term debt		3,805,950		3,930,350		(67,340	)		55,096

Total foreign exchange sensitive liabilities		102,351,383		102,460,708		(2,447,311	)		2,002,344

Total foreign exchange balance sheet sensitivity						(44,713	)		36,581

The Bank of New York Mellon is the depositary of the Bank's preference shares and ordinary shares in the form of ADRs traded on the NYSE. The depositary collects its fees for delivery and surrender of ADSs directly from investors depositing shares or surrendering ADSs for the purpose of withdrawal or from intermediaries acting for them. The depositary collects fees for making distributions to investors by deducting those fees from the amounts distributed or by selling a portion of distributable property to pay the fees. In the case of preference shares, the depositary may collect its annual fee for depositary services by deductions from cash distributions or by directly billing investors or by charging the book-entry system accounts of participants acting for them. The depositary may generally refuse to provide fee-attracting services until its fees for those services are paid.

Persons depositing or withdrawing shares must pay:		For:

$5.00 (or less) per 100 ADSs (or portion of 100 ADSs)		Issuance of ADSs, including issuances resulting from a distribution of shares or rights or other property
		Cancellation of ADSs for the purpose of withdrawal, including if the deposit agreement terminates
$0.15 (or less) per ADS (or portion thereof)		Any cash distribution to ADS registered holders, except for distribution of cash dividends (applicable to ordinary shareholders only)
$0.02 (or less) per ADS (or portion thereof) per calendar year		Depositary Services (applicable to preference shareholders only)
A fee equivalent to the fee that would be payable if securities distributed had been shares and the shares had been deposited for issuance of ADSs		Distribution of proceeds of sale of securities or rights, which are sold by the depositary, and the net proceeds distributed by the depositary to ADS registered holders
Registration or transfer fees		Transfer and registration of shares on our share register to or from the name of the depositary or its nominee or the custodian or its nominee on the making of deposits or withdrawals
Expenses of the depositary		Cable, telex and facsimile transmissions (when expressly provided in the deposit agreement)
		Converting foreign currency to U.S. dollars
Taxes and other governmental charges the depositary or the custodian have to pay on any ADS or share underlying an ADS, for example, stock transfer taxes, stamp duty or withholding taxes		As necessary
Any charges incurred by the depositary or its agents for servicing the deposited securities		As necessary

In January 2010, we received a payment of USD 2.2 million, net of tax, from the depositary as reimbursement for certain fees and expenses, including stock exchange listing, legal counsel's, accountants', printers' and other fees, which we incurred and expect to incur in connection with the maintenance of the ADR facility for our ordinary shares, for the financial years 2009 to (and including) 2013. During that period, the depositary has also agreed to waive annual administration and other fees payable by us in connection with the facility.

ITEM 14 MATERIAL MODIFICATIONS TO THE RIGHTS OF SECURITY HOLDERS AND USE OF PROCEEDS

On May 21, 2009 the Board of Directors confirmed the payment in full of the shares issued pursuant to the aforementioned share capital increase amounting to EUR 350 million, with the issue of 70 million redeemable preference shares. The issue was fully subscribed to by the Hellenic Republic, through the transfer by the latter to the Bank of an equivalent amount of Greek government bonds in accordance with Greek Law 3723/2008. These bonds have a coupon equal to six-month Euribor plus 1.3% and expire on May 21, 2014. The preference shares issued by the Bank in favor of the Hellenic Republic are not transferable and embody the following privileges:

In July 2009, following the Board of Directors' resolution held on June 18, 2009, the Bank increased its ordinary share capital by offering 110,367,615 new ordinary shares of nominal value of EUR 5.00 each and subscription price of EUR 11.30 each through a rights issue. The shares were initially offered to existing ordinary shareholders at a ratio of two new shares for every nine shares held. The total capital raised amounted to EUR 1,247,154. The new shares were listed in the ATHEX on July 30, 2009.

On December 22, 2009, the Board of Directors of the Bank approved the share capital increase by EUR 98,465 through the issue of 19,693 ordinary shares derived from the exercise of stock options under Programs A and B.

On February 18, 2010, the second Repeat General Meeting of the Bank's shareholders approved the assignment to the Board of Directors of the right to issue bonds convertible to shares, as per the provisions of articles 3a and 13 of the Companies Act and article 5 of the Bank's Articles of Association, for a period of five years, up to an amount corresponding to 50% of the paid-up share capital of the Bank as at the time of the assignment of the said right, that is EUR 1,696 million. The Meeting authorized the Board of Directors to decide the particular terms and details of such issuance, as well as the procedure by which the bonds will be converted to shares.

Following the above authorizations, the Board of Directors on September 10, 2010, approved the increase of the Bank's ordinary share capital through a rights issue by offering:

On December 22, 2011, the Extraordinary General Meeting of the Bank's Shareholders approved a) the share capital increase by €1.000 million through the issue of additional 200 million Redeemable Preference Shares at a nominal value of EUR 5.00 each with the cancellation of the pre-emptive rights of the existing shareholders in favor of the Hellenic Republic, in accordance with the Greek Law 3723/2008 and b) the revocation of the decision of the Extraordinary General Meeting of the Bank's Shareholders held on November 26, 2010 regarding the repurchase by the Bank of the 70 million Redeemable Preference Shares in favor of the Hellenic Republic, in accordance with Greek Law 3723/2008.

On December 30, 2011, following the above decision, the Bank issued the 200 million Redeemable Preference Shares at a nominal value of EUR 5.00 each. The issue was fully subscribed to by the Hellenic Republic, through the transfer by the latter to the Bank of an equivalent amount of Greek

government bonds in accordance with Greek Law 3723/2008. These bonds have a coupon equal to six-month Euribor plus 1.3% and expire on May 21, 2014.

As of December 31, 2011, the total paid-up share capital of the Bank amounted to EUR 6,137,952 thousand divided into a) 956,090,482 ordinary shares of a nominal value of EUR 5.00 each, b) 25,000,000 non-cumulative, non-voting, redeemable preference shares, of a nominal value of EUR 0.30 each, and c) 270,000,000 redeemable preference shares of the Hellenic Republic of a nominal value of EUR 5.00 each, in accordance with Greek Law 3723/2008. See Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic Bank Support Plan" for a detailed description of the current plan.

As of December 31, 2011, we performed an evaluation, under the supervision and with the participation of our management, including our Chief Executive Officer, Deputy Chief Executive Officer and Chief Financial Officer, of the effectiveness of our disclosure controls and procedures. Our disclosure controls and procedures are designed to provide reasonable assurance that material financial and non-financial information required to be disclosed in this annual report is recorded, processed, summarized and reported in a timely manner, and that it is accumulated and communicated to our management, including our Chief Executive Officer, Deputy Chief Executive Officer and Chief Financial Officer, as appropriate to allow timely decisions regarding required disclosure. There are inherent limitations to the effectiveness of any system of disclosure controls and procedures including the possibility of human error and the circumvention or overriding of the controls and procedures. Accordingly, even effective disclosure controls and procedures can only provide reasonable assurance of achieving their control objectives.

Based upon that evaluation, the Chief Executive Officer, the Deputy Chief Executive Officer and the Chief Financial Officer have concluded that our disclosure controls and procedures are not effective as of December 31, 2011, solely because of the deficiencies described in Item 15 (b) below.

Due to these deficiencies, we performed additional analysis and compensating procedures that go beyond the Bank's routine procedures to support the reliability of financial reporting and related disclosures. Accordingly, our management believes that the financial statements and other financial information included in this annual report, fairly present in all material respects our financial condition, results of operations and cash flows for the periods presented in this Annual Report.

In June 2003, the Bank's management established the Disclosure and Transparency Committee. The purpose of the committee is to monitor the accuracy and adequacy of the information included in public announcements, and generally, in any kind of publications made by the Bank, especially information submitted to the SEC.

For information in relation to the composition of the Disclosure and Transparency Committee, see Item 6.A, "Board of Directors and Senior Management—Disclosure and Transparency Committee".

The management of the National Bank of Greece S.A. is responsible for establishing and maintaining adequate internal control over financial reporting for National Bank of Greece S.A. and its subsidiaries ("the Group").

The Group's internal control over financial reporting ("ICFR") is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with accounting principles generally accepted in the United States of America. The Group's internal control over financial reporting includes those policies and procedures that:

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

Management assessed the effectiveness of the Group's internal control over financial reporting as of December 31, 2011, based on the framework set forth by the Committee of Sponsoring Organizations of the Treadway Commission in Internal Control - Integrated Framework (COSO). Based on this assessment, management concluded that, as of December 31, 2011, the Group's internal control over financial reporting is ineffective, due to a material weakness identified in its internal control over financial reporting.

Specifically, management identified control deficiencies in its internal controls associated with the methodology for computing bilateral CVA that constitute a material weakness.

More specifically, management during the current year has revisited the assumptions and computation methodology relating to the impact on the Group of credit risk on derivatives for counterparty and own credit risk. In particular, the Group changed its methodology to include the impact of credit risk on derivatives with (i) the Hellenic Republic as we now believe the losses associated with the PSI completion changed the risk profile of the Hellenic Republic, and (ii) counterparties with which we had in place CSAs under ISDA agreements that require daily placement of collateral, and the ISDA agreement provides for netting of asset and liability positions in case of default.

For the purposes of the 2011 financial statements the bilateral CVA calculation has been properly and timely calculated, nevertheless the revised methodology was not timely designed and implemented as of December 31, 2011. This revealed the absence of effective controls regarding the timely assessment of the appropriateness of the bilateral CVA calculation methodology used.

Management has also examined the reasons which led to the restatement of its prior years financial statements, as described in Note 43, as strong indicators for material weaknesses, and has concluded that these restatements were not due to any material weakness in the Group's prior years ICFR.

Furthermore, in addition to the above, the Group has a restatement relating to the reversal of multiple reclassifications of securities out of trading category made in the first half of 2010, which were made in response to the single rare event of the Hellenic Republic economic crisis, of securities out of the trading category. As we have changed our accounting policy, not to allow more than one reclassification in response to a single rare event, the 2010 financial statements have also been restated in this respect. However, we are of the opinion that management exercised reasonable judgment in reaching the conclusion that it is possible to effect more than one reclassification, in response to the single rare event of the Hellenic Republic economic crisis, and for this reason management has concluded that this restatement does not have an impact on our prior years' assessment of ICFR.

Management following the identification of the material weakness has already enhanced the CVA related controls, by establishing periodic reviews of the appropriateness of the bilateral CVA methodology, and enhancing the documentation of the CVA related policies, procedures and methodology.

The effectiveness of the Group's internal control over financial reporting as of December 31, 2011, has been audited by Deloitte Hadjipavlou Sofianos & Cambanis S.A., an independent registered public accounting firm as stated in their report which appears herein.

To the Board of Directors and Shareholders of
National Bank of Greece S.A. and subsidiaries
Athens, Greece

We have audited the internal control over financial reporting for National Bank of Greece S.A and subsidiaries' (the "Group's"), as of December 31, 2011 based on criteria established in Internal Control—Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission. The Group's management is responsible for maintaining effective internal control over financial reporting and for its assessment of the effectiveness of internal control over financial reporting, included in the accompanying Management's Annual Report on Internal Control over Financial Reporting. Our responsibility is to express an opinion on the Group's internal control over financial reporting based on our audit.

We conducted our audit in accordance with the standards of the Public Company Accounting Oversight Board (United States). Those standards require that we plan and perform the audit to obtain reasonable assurance about whether effective internal control over financial reporting was maintained in all material respects. Our audit included obtaining an understanding of internal control over financial reporting, assessing the risk that a material weakness exists, testing and evaluating the design and operating effectiveness of internal control based on that risk, and performing such other procedures as we considered necessary in the circumstances. We believe that our audit provides a reasonable basis for our opinion.

A company's internal control over financial reporting is a process designed by, or under the supervision of, the company's principal executive and principal financial officers, or persons performing similar functions, and effected by the company's board of directors, management, and other personnel to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A company's internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the company; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorizations of management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the company's assets that could have a material effect on the financial statements.

Because of the inherent limitations of internal control over financial reporting, including the possibility of collusion or improper management override of controls, material misstatements due to error or fraud may not be prevented or detected on a timely basis. Also, projections of any evaluation of the effectiveness of the internal control over financial reporting to future periods are subject to the risk that the controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

A material weakness is a deficiency, or a combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of the company's annual financial statements will not be prevented or detected on a timely basis. Subsequent to the year ended December 31, 2010, the Group identified a material weakness relating to the lack of incorporation of a valuation adjustment for credit risk for certain of in its derivative contracts. This material weakness was considered in determining the nature, timing and extent of audit tests applied in our audit of the consolidated financial statements as of and for the year ended December 31, 2011 of the Group and this report does not affect our report on such financial statements.

In our opinion, because of the effect of the material weakness identified above on the achievement of the objectives of the control criteria, the Group has not maintained effective internal control over financial reporting as of December 31, 2011, based on the criteria established in Internal Control—Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission.

We have also audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States), the consolidated financial statements as of and for the year ended December 31, 2011, of the Group and our report dated May 15, 2012 expressed an unqualified opinion on those financial statements which includes explanatory paragraphs relating to (a) the translation of Euro amounts into U.S. dollar amounts for the convenience of the readers in the United States in accordance with Note 2 to the consolidated financial statements, (b) the disclosures made in Note 3 to the consolidated financial statements, which refer to the going concern uncertainties derived from the impact of the impairment losses resulting from the Greek sovereign debt restructuring on the Group's regulatory and accounting capital and the planned actions to restore the capital adequacy of the Group, (c) the restatement of the 2010 and 2009 financial statements as described in Note 43.

Other than those changes described above, during the year ended December 31, 2011, there have been no changes in our internal control over financial reporting, that have materially affected, or are reasonably likely to materially affect our internal control over financial reporting.

On January 28, 2010, the Bank's Board of Directors appointed Mr. Petros Sabatacakis, an independent non-executive member of the Board of Directors, as the Audit Committee Financial Expert to replace Mr. Stefanos Pantzopoulos whose term was to end on the date of the Annual General Meeting of 2010. On June 23, 2011, Mr. Sabatacakis was reappointed by the Bank's Board of Directors as the Audit Committee's Financial Expert until the date of the Annual General Meeting of 2012.

Mr. Sabatakakis is independent, as that term is defined in the New York Stock Exchange's manual for listed companies. Between 1999 and 2004, Mr. Sabatacakis was Chief Risk Manager for Citigroup Inc. During that time, he was responsible for all the financial services of the company's businesses as a member of the Management Committee and a member of the Citicorp Board. All credit, market, and operational risk activities of the Group reported to him. From 1992 to 1997, he was in charge of the financial services subsidiaries of the American International Group, its treasury operations as well as the market and credit risk activities. He was a member of the Executive Committee and a C.V. Starr partner. Prior to that, he was the Head of Global Treasury and Capital Markets at Chemical Bank (now JP Morgan Chase), which he joined in 1973 in Economic Research. Among his positions at Chemical Bank were oversight of the international branches, foreign exchange and securities trading and the management of its funding and investments division. In addition, he had the responsibility for the management of the corporation's overall interest rate risk and investment portfolios. Mr. Sabatacakis, who was born in Greece, earned three degrees from Columbia University: Bachelor of Science, Masters of Business Administration and a Doctor of Philosophy degree in Economics. He has been the chairman of Plan International and Child Reach (child-sponsor non-profit), a Trustee of Athens College in Greece, and a Director Emeritus of the Gennadius Library.

The Bank's Board of Directors approved a Code of Ethics for Financial Professionals on February 12, 2004, which covers all Group companies. The Code of Ethics for Financial Professionals covers the activities of the Executive Members of the Board of Directors of each Group company, the Chief Executive Officer and Chief Financial Officer of each Group company as well as all persons responsible for the preparation of financial statements and those dealing with investor relations. The Code of Ethics for Financial Professionals, among other matters, includes provisions for compliance with applicable rules and regulations, demonstrating personal integrity, engaging in honest and ethical conduct, and ensuring that public communications by the Bank are complete, accurate, timely and understandable. A copy of the Code of Ethics for Financial Professionals has been posted on the Bank's website: www.nbg.gr.

Furthermore, our Board of Directors approved a Group Code of Ethics (the "Code of Ethics") on November 26, 2006. All Group companies either adopted the Code of Ethics or adjusted any existing ethics code to comply with the Group Code of Ethics. The Code of Ethics was sent to each Group employee in early 2007. It appropriately covers issues relating to employee integrity, professionalism and conflict of interests, ethical behavior, business conduct with third parties and compliance with rules and regulations. A copy of the Group Code of Ethics is available on the Bank's website: www.nbg.gr.

Deloitte Hadjipavlou Sofianos & Cambanis S.A. has served as our principal independent public accountant for each of the past two years ended December 31, 2010 and 2011. The following table presents the aggregate fees for professional audit services and other services rendered by the Group's principal accounting firm Deloitte Hadjipavlou Sofianos & Cambanis S.A., the other member firms of Deloitte Hadjipavlou Sofianos & Cambanis S.A., and their respective affiliates (collectively, "Deloitte").

Fees billed for audit services for the years ended December 31, 2010 and 2011 consisted primarily of the audit of the Group's consolidated IFRS and U.S. GAAP Financial Statements, the audit of statutory and subsidiary financial statements and of services provided for compliance with the Sarbanes-Oxley Act requirements.

Fees billed for audit related services for the years ended December 31, 2010 and 2011 consisted primarily of comfort letter fees for the Bank and its subsidiary's share capital increase in 2010 fiscal year, other audit and attest services and system and application control reviews.

Fees billed for tax services for the years ended December 31, 2010 and 2011 consisted primarily of tax compliance, advisory, and planning services and preparation of tax returns.

The Audit Committee has implemented a policy as of May 6, 2003 to approve, on a case-by-case basis, all audit related services, tax services, and other services in accordance with the rules and regulations concerning auditor independence promulgated by the SEC to implement the Sarbanes-Oxley Act of 2002. Following its decision on January 30, 2006, the Audit Committee has adopted pre-approval guidelines for all allowable non-audit services to be offered by the Group's statutory auditors for which the fee is not higher than the equivalent of EUR 20,000, as well as for services to NBG Private Equity Ltd regarding the performance of standard agreed upon procedures to audit the exit calculations of Fund investments. These services may be approved by the Chief Financial Officer and the Audit Committee's approval is obtained at the next Audit Committee meeting. All other allowable audit and non-audit services to be offered by the Group's statutory auditors are approved, on a case-by-case basis, in accordance with the rules and regulations concerning auditor independence promulgated by the SEC to implement the Sarbanes-Oxley Act of 2002.

All "Audit fees", "Audit related fees" and "Tax fees" for 2010 and 2011 were specifically approved by the Audit Committee.

ITEM 16E PURCHASES OF EQUITY SECURITIES BY THE ISSUER AND AFFILIATED PURCHASERS

From January 1, 2009 to the date of this Annual Report, due to its participation in the Hellenic Republic liquidity support plan (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic Bank Support Plan") the Bank has not purchased any of its own shares. Out of the 6,456,504 treasury shares held on January 1, 2009, representing 1.3% of the paid-up share capital, on April 15, 2009 the Bank disposed of 5,954,000 of its own shares at a price of EUR 13.50 per share and the remaining were disposed of on September 15, 2009 at a price of EUR 21.40 per share. The proceeds from this sale have been used to strengthen the Bank's capital base.

The purchases and (sales) of own shares by the affiliated purchasers (National Securities S.A.) for the year 2010 amounted to 15,620,293 shares and (15,213,954) shares respectively. Therefore, the balance of as at December 31, 2010 of own shares amounted to 743,689 shares.

The purchases and (sales) of own shares by the affiliated purchasers (National Securities S.A.) for the year 2011 amounted to 41,381,705 shares and (42,062,422) shares respectively. Therefore, the balance of as at December 31, 2011 of own shares amounted to 62,972 shares.

NBG Corporate Governance Practices follow the Requirements imposed by the laws and regulations of the Hellenic Republic. Striving to raise corporate governance standards to global best

practice, NBG has adopted a Corporate Governance Code which is currently very close to NYSE listing standards and which the Board of Directors is in the process of implementing fully. In terms of actual practice, the most significant differences that still remain between the Bank's Corporate Governance practices and those followed by U.S. based companies under the NYSE listing standards are currently the following:

For more information on the Bank's Corporate Governance Practices see Item 6, "Directors, Senior Management and Employees".

See our consolidated financial statements and the notes thereto beginning on page F-1, which we incorporate herein by reference.

Exhibit Number			Description of Exhibits

	1		An English translation of the Articles of Association of the Bank, as amended with effect from December 2011.
	2.1		Deposit Agreement dated as of May 28, 1998, as amended and restated as of January 22, 2010, among National Bank of Greece S.A., The Bank of New York Mellon as Depositary, and all Owners and Beneficial Owners from time to time of American Depositary Shares issued thereunder (incorporated by reference to Exhibit 1 to the registration statement on Form F-6 (File No. 333-167117) filed May 27, 2010).
	2.2		Form of Deposit Agreement dated as of May 29, 2008, among National Bank of Greece S.A., The Bank of New York Mellon as Depositary, and all Owners and Beneficial Owners from time to time of American Depositary Shares issued thereunder (incorporated by reference to Exhibit 1 to the registration statement on Form F-6 (File No. 333-151199) filed May 28, 2008).
	8		Subsidiaries of the Bank.
	12.1		Certification of the Chief Executive Officer, the Deputy Chief Executive Officer and the Chief Financial Officer pursuant to Rule 13a-14(a) under the Securities Exchange Act of 1934.
	13.1		Certification of the Chief Executive Officer, the Deputy Chief Executive Officer and the Chief Financial Officer pursuant to Rule 13a-14(b) under the Securities Exchange Act of 1934 and 18 U.S.C. Section 1350 as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002.
	15.1		Consent of Independent Registered Public Accounting Firm.

The registrant hereby certifies that it meets all of the requirements for this filing on Form 20-F and that it has duly caused and authorized the undersigned to sign this Annual Report on its behalf.

Consolidated Financial Statements as of
December 31, 2010 (as restated) and 2011 and for the
years ended December 31, 2009, 2010 (both as restated) and
2011 and Report of Independent Registered
Public Accounting Firm

To the Board of Directors and Shareholders of
National Bank of Greece S.A. and subsidiaries
Athens, Greece

We have audited the accompanying balance sheets of National Bank of Greece S.A and subsidiaries (the "Group") as of December 31, 2011 and 2010, and the related consolidated statements of income and comprehensive income, shareholders' equity, and cash flows for each of the three years in the period ended December 31, 2011. These financial statements are the responsibility of the Group's management. Our responsibility is to express an opinion on these financial statements based on our audits.

We conducted our audits in accordance with the standards of the Public Company Accounting Oversight Board (United States). Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement. An audit includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements. An audit also includes assessing the accounting principles used and significant estimates made by management, as well as evaluating the overall financial statement presentation. We believe that our audits provide a reasonable basis for our opinion.

In our opinion, such consolidated financial statements present fairly, in all material respects, the financial position of National Bank of Greece S.A. and subsidiaries at December 31, 2011 and 2010, and the results of their operations and their cash flows for each of the three years in the period ended December 31, 2011, in conformity with accounting principles generally accepted in the United States of America.

Our audits also comprehend the translation of the Euro amounts into U.S. dollar amounts and, in our opinion, such translation has been made in conformity with the basis stated in Note 2. Such U.S. dollar amounts are presented solely for the convenience of readers in the United States.

The accompanying financial statements have been prepared assuming that the Group will continue as a going concern. We draw attention to the disclosures made in Note 3 to the consolidated financial statements, which refer to the impact of the impairment losses resulting from the Greek sovereign debt restructuring on Group's regulatory and accounting capital. Such conditions raise substantial doubt about the Group's ability to continue as a going concern. Management's plans in regard to this matter are also discussed in Note 3 to the financial statements. The financial statements do not include any adjustments that might result from the outcome of this uncertainty.

As discussed in Note 43 to the consolidated financial statements, the accompanying consolidated financial statements as of December 31, 2010 and for each of the two years in the period ended December 31 2010 have been restated to correct misstatements.

We have also audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States), the Group's internal control over financial reporting as of December 31, 2011, based on the criteria established in Internal Control—Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission and our report dated May 15, 2012, expressed an adverse opinion on the Company's internal control over financial reporting because of a material weakness.

			As of December 31,

	Note		2010			2011			2011
			As restated⁽¹⁾						(USD in thousands) (Note 2)
			(EUR in thousands)						(USD in thousands) (Note 2)
ASSETS
Cash and due from banks		5		1,436,157			1,717,736			2,272,438
Deposits with Central Bank		6		2,961,828			2,898,998			3,835,161
Securities purchased under agreements to resell		7		146,302			673,187			890,577
Interest bearing deposits with banks		8		6,398,767			3,767,624			4,984,289
Trading assets		9		2,785,322			2,964,088			3,921,270
Derivative assets		10		1,634,270			3,605,965			4,770,426
Available-for-sale securities		11		13,688,510			8,571,724			11,339,759
Held-to-maturity securities		11		3,598,285			1,002,202			1,325,839
Equity method investments		12		50,094			59,139			78,237
Loans (includes EUR 559,107 thousand in 2010 and 277,247 thousand in 2011 measured at fair value)		13		79,038,440			76,002,857			100,546,179
Less: Allowance for loan losses				(3,175,405	)		(6,550,635	)		(8,666,007	)

Net loans				75,863,035			69,452,222			91,880,172
Goodwill		14		3,499,078			2,690,864			3,559,815
Software and other intangibles		14		459,891			398,992			527,837
Premises and equipment, net		15		1,221,989			1,273,455			1,684,687
Accrued interest receivable				1,195,730			1,156,229			1,529,606
Other assets (includes EUR 233,576 thousand in 2010 and EUR 168,360 thousand in 2011 measured at fair value)		16		3,792,620			3,234,810			4,279,415

TOTAL ASSETS				118,731,878			103,467,235			136,879,528

LIABILITIES AND SHAREHOLDERS' EQUITY
Interest bearing deposits (includes EUR 1,240,756 thousand in 2010 and EUR 1,779,727 thousand in 2011 measured at fair value)		19		91,298,832			88,993,351			117,731,646
Non-interest bearing deposits		19		2,596,649			2,581,951			3,415,731

Total deposits		19		93,895,481			91,575,302			121,147,377
Securities sold under agreements to repurchase		20		3,538,289			1,302,239			1,722,766
Derivative liabilities		10		1,782,470			4,320,488			5,715,687
Other borrowed funds		21		1,111,663			925,971			1,224,991
Accounts payable, accrued expenses and other liabilities		22		3,326,010			3,548,336			4,694,187
Insurance reserves		23		2,531,344			2,760,841			3,652,389
Long-term debt (includes EUR 1,261,100 thousand in 2010 and EUR 1,059,297 in 2011 measured at fair value)		24		3,805,950			2,937,371			3,885,925

Total liabilities				109,991,207			107,370,548			142,043,322

Redeemable non-controlling interest—Temporary equity		33		265,982			283,368			374,875
PERMANENT EQUITY:
NBG shareholders' equity
Preferred stock (25,000,000 shares of par value EUR 0.30 each at 2010 and 2011 and 70,000,000 and 270,000,000 shares of par value EUR 5.00 each at 2010 and 2011, respectively)				357,500			1,357,500			1,795,872
Common stock, par value of EUR 5.00 (shares authorized, issued and outstanding: 956,090,482 at 2010 and 2011 respectively)				4,780,452			4,780,452			6,324,186
Additional paid-in capital		32		3,883,461			4,090,184			5,411,012
Accumulated surplus/(deficit)				2,022,142			(12,547,110	)		(16,598,901	)
Accumulated other comprehensive loss		40		(3,385,596	)		(1,938,578	)		(2,564,595	)
Treasury stock, at cost (743,689 and 62,972 shares at 2010 and 2011 respectively)				(4,901	)		(110	)		(146	)

Total NBG shareholders' equity/(deficit)				7,653,058			(4,257,662	)		(5,632,572	)

Non-controlling interest				821,631			70,981			93,903

Total permanent equity/(deficit)				8,474,689			(4,186,681	)		(5,538,669	)

TOTAL LIABILITIES AND EQUITY				118,731,878			103,467,235			136,879,528

The accompanying notes are an integral part of these consolidated financial statements.

NATIONAL BANK OF GREECE S.A. AND SUBSIDIARIES

CONSOLIDATED STATEMENTS OF INCOME AND COMPREHENSIVE INCOME

			Year ended December 31,

	Note		2009			2010			2011			2011
			As restated⁽¹⁾			As restated⁽¹⁾						(USD in thousands) (Note 2)
			(EUR in thousands)
Interest Income:
Loans				5,039,925			5,007,064			5,050,455			6,681,380
Securities available-for-sale				844,074			700,962			760,414			1,005,972
Securities held-to-maturity				9,425			94,895			123,281			163,092
Trading assets				197,704			229,200			191,441			253,262
Securities purchased under agreements to resell				28,553			13,510			31,646			41,865
Interest-bearing deposits with banks				63,515			61,532			63,367			83,830
Other				48,184			41,673			39,046			51,655

Total interest income				6,231,380			6,148,836			6,259,650			8,281,056

Interest Expense:
Deposits				(2,133,507	)		(1,821,966	)		(2,264,935	)		(2,996,342	)
Securities sold under agreements to repurchase		20		(90,052	)		(75,712	)		(122,017	)		(161,419	)
Other borrowed funds		21		(34,244	)		(25,391	)		(24,914	)		(32,959	)
Long-term debt		24		(184,144	)		(139,450	)		(197,381	)		(261,121	)
Other				(3,168	)		(2,716	)		(2,252	)		(2,979	)

Total interest expense				(2,445,115	)		(2,065,235	)		(2,611,499	)		(3,454,820	)

Net interest income before provision for loan losses				3,786,265			4,083,601			3,648,151			4,826,236
Provision for loan losses		13		(998,448	)		(1,204,995	)		(3,703,269	)		(4,899,152	)

Net interest income after provision for loan losses				2,787,817			2,878,606			(55,118	)		(72,916	)

Non-interest income/(loss):
Credit card fees				200,939			188,771			198,411			262,483
Service charges on deposit accounts				49,005			52,722			78,342			103,641
Other fees and commissions		26		502,140			475,692			435,421			576,030
Net trading loss		27		(267,131	)		(1,245,322	)		(1,877,038	)		(2,483,183	)
Equity in earnings of investees and realized gains/(losses) on disposal		12		(27,879	)		9,245			8,661			11,458
Other non-interest income		28		1,090,790			1,161,253			862,365			1,140,845

Total non-interest income / (loss) excluding gains / (losses) on investment securities				1,547,864			642,361			(293,838	)		(388,726	)

Net realized gains / (losses) on sales of available for sale securities		11		349,929			114,959			(19,466	)		(25,752	)
Other-Than-Temporary-Impairment (of which nil was recognized in OCI)		11		(358,328	)		(89,497	)		(9,173,713	)		(12,136,146	)

Net gains / (losses) on available for sale and held to maturity securities		11		(8,399	)		25,462			(9,193,179	)		(12,161,898	)

Total non-interest income / (loss)				1,539,465			667,823			(9,487,017	)		(12,550,624	)

Non-interest expense:
Salaries				(1,254,610	)		(1,233,593	)		(1,183,294	)		(1,565,411	)
Employee benefits				(278,615	)		(273,013	)		(243,134	)		(321,648	)
Voluntary early retirement schemes				(24,559	)		(5,269	)		—			—
Occupancy expenses				(103,297	)		(105,431	)		(88,658	)		(117,288	)
Equipment expenses				(63,088	)		(66,488	)		(60,804	)		(80,439	)
Depreciation of premises and equipment				(122,765	)		(129,310	)		(121,652	)		(160,937	)
Amortization of intangible assets				(65,260	)		(79,906	)		(98,930	)		(130,877	)
Impairment of goodwill				—			(6,320	)		(418,676	)		(553,877	)
Deposit insurance premium				(57,028	)		(54,964	)		(57,611	)		(76,215	)
Other non-interest expense		29		(1,728,190	)		(1,857,828	)		(2,233,240	)		(2,954,412	)

Total non-interest expense				(3,697,412	)		(3,812,122	)		(4,505,999	)		(5,961,104	)

Income / (loss) before income tax				629,870			(265,693	)		(14,048,134	)		(18,584,644	)
Income tax (expense) / benefit		30		(176,586	)		(42,311	)		(459,345	)		(607,679	)

Net income / (loss)				453,284			(308,004	)		(14,507,479	)		(19,192,323	)

Less: Net income attributable to the non-controlling interest				(62,232	)		(46,768	)		(32,189	)		(42,584	)

NET INCOME / (LOSS) attributable to NBG shareholders				391,052			(354,772	)		(14,539,668	)		(19,234,907	)

The accompanying notes are an integral part of these consolidated financial statements.

			Year ended December 31,

	Note		2009			2010			2011			2011
			As restated⁽¹⁾			As restated⁽¹⁾						(USD in thousands) (Note 2)
			(EUR in thousands)									(USD in thousands) (Note 2)
Net income/(loss)				453,284			(308,004	)		(14,507,479	)		(19,192,323	)
Other comprehensive income/(loss) net of tax:
Foreign currency translation adjustments				(56,969	)		191,304			(950,373	)		(1,257,273	)
Net (losses)/gains on available-for-sale securities:
Net unrealized holding (losses)/gains during the period (net of tax expense/(benefit) of: EUR 104,131 thousand in 2009, EUR (431,278) thousand in 2010 and EUR (874,733) thousand in 2011				212,057			(2,038,388	)		(3,256,680	)		(4,308,347	)
Less: reclassification adjustment for net (gains)/losses included in net income (net of tax (expense)/benefit of: EUR (74,959) thousand in 2009, EUR (20,987) thousand in 2010 and EUR 4,209 thousand in 2011)				(274,969	)		(93,972	)		15,257			20,184
Less: Reclassification adjustment for impairment of available-for-sale securities (net of tax benefit of EUR 84,835 thousand in 2009, EUR 18,984 thousand in 2010 and EUR 1,353,700 thousand in 2011)				273,493			70,513			5,608,128			7,419,140

Total net (losses)/gains on available-for-sale securities				210,581			(2,061,847	)		2,366,705			3,130,977

Pension (liability)/asset (net of tax expense/(benefit) of EUR 5,807 thousand in 2009, EUR (74) thousand in 2010 and EUR 1,450 thousand in 2011)		39		24,232			14,605			29,356			38,836

Total other comprehensive income/(loss), net of tax				177,844			(1,855,938	)		1,445,688			1,912,540

Comprehensive income/(loss)				631,128			(2,163,942	)		(13,061,791	)		(17,279,783	)

Less: Comprehensive (income)/loss attributable to the non-controlling interest				(60,364	)		(59,299	)		(1,817	)		(2,404	)
Comprehensive income/(loss) attributable to NBG shareholders				570,764			(2,223,241	)		(13,063,608	)		(17,282,187	)
Earnings/(loss) per share:
Basic EPS		34		0.53			(0.56	)		(15.22	)		(20.13	)
Diluted EPS		34		0.53			(0.56	)		(15.22	)		(20.13	)

The accompanying notes are an integral part of these consolidated financial statements.

NATIONAL BANK OF GREECE S.A. AND SUBSIDIARIES

CONSOLIDATED STATEMENTS OF SHAREHOLDERS' EQUITY

		Year ended December 31,

	Note	2009			2010			2011			2011
		As restated⁽¹⁾			As restated⁽¹⁾						(USD in thousands) (Note 2)
		(EUR in thousands)									(USD in thousands) (Note 2)
Common Stock:
Balance at beginning of year (496,654,269 of par value EUR 5.0 each, 607,041,577 of par value EUR 5.0 each and 956,090,482 shares of par value EUR 5.0 each at 2009, 2010 and 2011 respectively)			2,483,271			3,035,208			4,780,452			6,324,186
Issuance of 110,367,615 shares of par value EUR 5.0 through a rights issue			551,838			—			—			—
Issuance of 121,408,315 shares of par value EUR 5.0 through a rights issue			—			607,041			—			—
Issuance of 227,640,590 shares of par value EUR 5.0 through a rights issue by conversion of 227,640,590 convertible bonds			—			1,138,203			—			—
Share options exercised for 19,693 shares of par value EUR 5.0 each			99			—			—			—

Balance at end of year (607,041,577, 956,090,482 and 956,090,482 shares at 2009, 2010 and 2011 respectively) of par value EUR 5.0 each			3,035,208			4,780,452			4,780,452			6,324,186

Preferred stock
Balance at beginning of year (25,000,000 of par value EUR 0.3 each at 2009, 25,000,000 of par value EUR 0.3 each and 70,000,000 of par value EUR 5.0 each at 2010 and 25,000,000 of par value EUR 0.3 each and 70,000,000 of par value EUR 5.0 each at 2011)			7,500			357,500			357,500			472,946
Issuance of preference shares (70,000,000 of par value EUR 5.0 each)			350,000			—			—			—
Issuance of preference shares (200,000,000 of par value EUR 5.0 each)			—			—			1,000,000			1,322,926

Balance at end of year (25,000,000 shares of par value EUR 0.3 each and 70,000,000 shares of par value EUR 5.0 each at 2009 and 2010 and 25,000,000 shares of par value EUR 0.3 each and 270,000,000 shares of par value EUR 5.0 each at 2011)			357,500			357,500			1,357,500			1,795,872

Additional Paid-in Capital:
Balance at beginning of year			3,267,770			3,878,079			3,883,461			5,137,533
Issuance of 110,367,615 shares in 2009 through a rights issue of EUR 695,316 thousand less of issue costs of EUR (41,798) thousand, net of tax			653,518			—			—			—
Issuance of 121,408,315 shares in 2010 through a rights issue			—			24,282			—			—
Issuance of 227,640,590 shares through a rights issue by conversion of 227,640,590 convertible bonds			—			45,528			—			—
Issue costs for the issuance of 121,408,315 and 227,640,590 shares in 2010, net of tax			—			(77,951	)		—			—
Share options exercised (19,693 shares above par of EUR 15.9 each in 2009)			313			—			—			—
Share based payments			12,707			12,306			—			—
Loss on sales of treasury stock (net of tax (expense)/benefit of EUR (957) thousand, EUR 715 thousand and EUR 990 thousand in 2009, 2010 and 2011 respectively)			(52,512	)		(2,861	)		(3,961	)		(5,240	)
Issue costs net of tax in 2009 from the issuance of 70,000,000 preference shares			(3,420	)		—			—			—
Issue costs net of tax in 2011 from the issuance of 200,000,000 preference shares			—			—			(8,800	)		(11,642	)
Purchase of subsidiaries shares from non-controlling interest			(297	)		4,078			219,484			290,361

Balance at end of year			3,878,079			3,883,461			4,090,184			5,411,012

The accompanying notes are an integral part of these consolidated financial statements.

			Year ended December 31,

	Note		2009			2010			2011			2011
			As restated⁽¹⁾			As restated⁽¹⁾						(USD in thousands) (Note 2)
			(EUR in thousands)									(USD in thousands) (Note 2)
Accumulated Surplus:
Balance at beginning of year (restated see note 43)				2,078,160			2,450,025			2,022,142			2,675,143
New redeemable non-controlling interest, redemption of redeemable non-controlling interest and changes in the redemption amount of redeemable non-controlling interests		33		23,005			(1,553	)		(29,584	)		(39,137	)
Net income (as restated, see note 43)				391,052			(354,772	)		(14,539,668	)		(19,234,907	)
Preferred dividend, net of EUR 7.7 million tax in 2010				(42,192	)		(71,558	)		—			—

Balance at end of year (as restated)				2,450,025			2,022,142			(12,547,110	)		(16,598,901	)

Accumulated Other Comprehensive Income/(Loss)—net of tax:		40
Balance at beginning of year				(1,696,839	)		(1,517,127	)		(3,385,596	)		(4,478,895	)
Net change in fair value of securities available-for-sale (as restated, see note 43)				211,144			(2,065,236	)		2,372,126			3,138,148
Foreign currency translation adjustments (as restated, see note 43)				(55,790	)		182,099			(925,522	)		(1,224,396	)
Pension liability				24,358			14,668			29,456			38,968
Purchase and sale of subsidiaries shares from non-controlling interest				—			—			(29,042	)		(38,420	)

Balance at end of year (as restated)				(1,517,127	)		(3,385,596	)		(1,938,578	)		(2,564,595	)

Treasury Stock, at Cost:
Balance at beginning of year (6,456,504 and 337,350 and 743,689 shares at 2009, 2010 and 2011 respectively)				(145,277	)		(10,626	)		(4,901	)		(6,484	)
Sale of treasury stock (17,624,305, 15,213,954 and 42,062,422 shares during 2009, 2010 and 2011 respectively)				363,117			163,101			172,848			228,665
Purchase of treasury stock (11,505,151, 15,620,293 and 41,381,705 shares during 2009, 2010 and 2011 respectively)				(228,466	)		(157,376	)		(168,057	)		(222,327	)

Balance at end of year (337,350, 743,689 and 62,972 shares at 2009, 2010 and 2011 respectively)				(10,626	)		(4,901	)		(110	)		(146	)

Total NBG shareholders' equity				8,193,059			7,653,058			(4,257,662	)		(5,632,572	)

Non-controlling interest (NCI)—net of tax:
Balance at beginning of year				798,549			844,727			821,631			1,086,957
Net income (as restated, see note 43)				40,412			25,604			19,107			25,277
Net change in fair value of securities available-for-sale (as restated, see note 43)				(2,530	)		2,438			19			25
Foreign currency translation adjustments (as restated, see note 43)				1,181			6,097			(2,738	)		(3,621	)
Pension liability				5			94			37			49
Changes of non-controlling interest due to acquisitions, establishments, capital contributions and changes in subsidiaries shareholding				7,110			(57,329	)		(767,075	)		(1,014,784	)

Balance at end of year (as restated)				844,727			821,631			70,981			93,903

Total permanent equity				9,037,786			8,474,689			(4,186,681	)		(5,538,669	)

Redeemable non-controlling interest—Temporary equity:
Balance at beginning of year				256,208			254,499			265,982			351,875
Net income				21,820			21,164			13,082			17,307
Net change in fair value of securities available-for-sale				1,967			951			(5,440	)		(7,197	)
Foreign currency translation adjustments				(2,360	)		3,108			(22,113	)		(29,254	)
Pension liability				(131	)		(157	)		(137	)		(181	)
Capital Contribution				—			13,218			2,410			3,188
Redemption of redeemable NCI				—			(33,253	)		—			—
Changes in the redemption amount of redeemable NCI				(23,005	)		6,452			29,584			39,137

Balance at end of year				254,499			265,982			283,368			374,875

Total temporary equity				254,499			265,982			283,368			374,875

The accompanying notes are an integral part of these consolidated financial statements.

NATIONAL BANK OF GREECE S.A. AND SUBSIDIARIES

CONSOLIDATED STATEMENTS OF CASH FLOWS

	Year ended December 31

	2009			2010			2011			2011
	As restated⁽¹⁾			As restated⁽¹⁾						(USD in thousands) (Note 2)
	(EUR in thousands)									(USD in thousands) (Note 2)
Cash flows from Operating Activities:
Net income / (loss)		453,284			(308,004	)		(14,507,479	)		(19,192,323	)
Adjustments to reconcile net income / (loss) to net cash provided by/(used in) operating activities:
Provision for loan losses		998,448			1,204,995			3,703,269			4,899,152
Net (gain)/loss on sale of premises and foreclosed assets		(1,753	)		841			(9,155	)		(12,111	)
Net realized (gain)/loss on sales of available-for-sale securities		(349,929	)		(114,959	)		19,466			25,752
Other Than Temporary Impairment of AFS and HTM securities		358,328			89,497			9,173,713			12,136,146
Equity in earnings of equity method investees		18,550			(9,245	)		(8,661	)		(11,458	)
Depreciation of premises and equipment		122,765			129,310			121,652			160,937
Amortization of software and other intangibles		65,260			79,906			98,930			130,877
Impairment of goodwill		—			6,320			418,415			553,532
Impairment of equity method investments		—			—			1,675			2,216
Share based payments		12,707			12,306			—			—
Pension liability		30,039			14,531			30,806			40,754
Provision for deferred income taxes		12,838			(217,867	)		305,706			404,426
Net losses on the disposal of equity investments		9,329			—			—			—
Net gains from changes in the fair value of financial instruments designated at fair value		(131,079	)		(239,649	)		(37,429	)		(49,516	)
Gain on debt extinguishment		(224,683	)		(10,855	)		(7,651	)		(10,122	)
Other non cash items including provisions for contingencies and impairment of other assets		24,472			(11,364	)		181,132			239,624
Changes in assets and liabilities
Trading assets, derivative instruments and financial assets market-to-market through the profit and loss		(2,265,213	)		1,415,211			384,594			508,790
Accrued interest receivable		227,707			(165,495	)		39,501			52,257
Other assets		(667,092	)		124,515			(356,537	)		(471,672	)
Accounts payable, accrued expenses and other liabilities		645,167			(878,344	)		(125,197	)		(165,627	)
Insurance reserves		288,616			209,971			229,497			303,608

Cash flows provided by/(used in) operating activities		(372,239	)		1,331,621			(343,753	)		(454,758	)

Cash Flows from Investing Activities:
Activities in available-for-sale securities:
Purchases		(23,945,291	)		(16,243,881	)		(10,021,825	)		(13,258,136	)
Sales proceeds		20,570,594			13,883,742			7,679,578			10,159,516
Maturities, prepayments and calls		283,371			732,727			3,963,796			5,243,810
Activities in held-to-maturity securities:
Purchases		(759,760	)		(1,290,903	)		(200,554	)		(265,318	)
Maturities, prepayments and calls		797,924			8,614			321,362			425,138
Purchases of premises and equipment		(196,406	)		(165,567	)		(143,859	)		(190,315	)
Proceeds from sales of premises and equipment		7,641			7,684			21,246			28,107
Disposals/(acquisitions) of equity investments		(6,072	)		(11,249	)		(2,438	)		(3,225	)
Net cash provided by (used in):
Deposits with central bank		(38,866	)		(40,482	)		62,830			83,119
Loan origination and principal collections		(5,523,616	)		(3,309,256	)		2,683,047			3,549,473
Securities purchased under agreements to resell		124,959			385,809			(526,885	)		(697,030	)
Interest bearing deposits with banks		(1,327,437	)		(3,320,814	)		2,542,254			3,363,215
Other		(76,081	)		(91,645	)		(76,492	)		(101,193	)

Cash flows provided by/(used in) investing activities		(10,089,040	)		(9,455,221	)		6,302,060			8,337,161

The accompanying notes are an integral part of these consolidated financial statements.

	Year ended December 31

	2009			2010			2011			2011
	As restated⁽¹⁾			As restated⁽¹⁾						(USD in thousands) (Note 2)
	(EUR in thousands)									(USD in thousands) (Note 2)
Cash flows from Financing Activities:
Proceeds from issuance of long-term debt		2,456,075			2,826,537			196,409			259,835
Principal repayments and retirements of long-term debt		(3,127,780	)		(2,220,735	)		(1,144,844	)		(1,514,544	)
Proceeds from issuance of common and preferred stock (net of issue costs of EUR 58,002 thousand in 2009, EUR 98,995 thousand in 2010 and EUR 1,000 thousand in 2011)		1,189,564			1,716,059			(1,000	)		(1,323	)
Purchases of treasury stock		(228,466	)		(157,376	)		(168,057	)		(222,327	)
Proceeds from sales of treasury stock		311,562			159,525			167,897			222,115
Acquisition of and increase of controlling interest in subsidiary companies		—			(88,351	)		(43,400	)		(57,415	)
Disposal of subsidiary shareholding without loss of control		—			1,375			2,055			2,719
Capital contribution by non-controlling interest holders		—			14,321			2,452			3,244
Dividends paid		(42,835	)		(63,789	)		(23,980	)		(31,724	)
Net cash provided by/(used in):
Deposits		7,298,163			6,080,178			(2,175,477	)		(2,877,996	)
Securities sold under agreements to repurchase		2,728,287			(947,151	)		(2,236,050	)		(2,958,129	)
Other borrowed funds		(226,531	)		800,879			(185,692	)		(245,657	)

Cash flows provided by /(used in) financing activities		10,358,039			8,121,472			(5,609,687	)		(7,421,202	)
Effect of exchange rate change on cash and due from banks		(6,559	)		7,904			(67,041	)		(88,693	)
Net increase/(decrease) in cash and due from banks		(109,799	)		5,776			281,579			372,508
Cash and due from banks at beginning of year		1,540,180			1,430,381			1,436,157			1,899,930

Cash and due from banks at end of year		1,430,381			1,436,157			1,717,736			2,272,438

Supplemental Disclosure of Cash Flow Information:
Cash paid for:
Income taxes		76,392			207,817			128,083			169,444
Interest		3,113,625			2,360,704			2,352,184			3,111,766
Supplemental schedule of non cash investing and financing activities:
Issuance of 70,000,000 preference shares of par value EUR 5.0 each (see Note 32)		350,000			—			—			—
Issuance of 200,000,000 preference shares of par value EUR 5.0 each (see Note 32)		—			—			1,000,000			1,322,926

The accompanying notes are an integral part of these consolidated financial statements.

NATIONAL BANK OF GREECE S.A. AND SUBSIDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

The National Bank of Greece S.A. (the "Bank") was incorporated in the Hellenic Republic in 1841. The National Bank of Greece S.A. and subsidiaries (the "Group") provide a wide range of financial services activities including retail and commercial banking, global investment management, investment banking, insurance, investment activities and securities trading. The Group's non-financial service activities include hotels, warehouse management and real estate investments. The Group operates in Greece, Turkey, UK, South Eastern Europe, Cyprus, Malta, Egypt and South Africa.

The accompanying consolidated financial statements as of December 31, 2011, are expressed in Euro (EUR). The translation of EUR amounts into US dollar amounts is presented solely for the convenience of the reader and should not be construed as representations that the amounts stated in EUR have been or could have been or could be now or at any time in the future converted into US dollars at this or any other rate of exchange. The exchange rate used for the purpose of this disclosure is the noon buying rate in New York City for cable transfers in foreign currencies, as certified for customs by the Board of Governors of the Federal Reserve Bank of New York on Monday, April 30, 2012 which was EUR 0.7559 to USD 1.00 (EUR 0.7729 to USD 1.00 on December 31, 2011).

The following is a summary of the significant accounting policies followed by the Group in preparing these financial statements.

Basis of preparation—The accompanying consolidated financial statements have been prepared in accordance with accounting principles generally accepted in the United States of America ("U.S. GAAP").

The accounting records of the Group are maintained in accordance with the provisions of the Greek Company Law, the Greek Banking Chart of Accounts, the Greek Books and Records Code and the Bank of Greece regulations (collectively, Greek GAAP), except for foreign subsidiaries which maintain their accounting records in accordance with the legislation and regulations of the country in which they operate. Necessary adjustments are made, for financial reporting purposes, in order to comply with US GAAP.

Reclassifications—Certain reclassifications have been made to prior year amounts to conform to the current year presentation. See Note 43 for disclosure of the respective impacts.

Going concern—The crisis in the Greek economy resulted in impairment losses recorded in several classes of assets, such as Greek government bonds and other loans in Greece (see Note 11 and Note 13). These have adversely impacted the financial position, the results of operations, cash flows and regulatory ratios of the Bank, and consequently of the Group. Furthermore, the crisis has limited the Bank's access to liquidity from other financial institutions.

In addition, during 2011 the Bank has relied on liquidity facilities provided by the Eurosystem liquidity facilities.

Article 47 of Greek Law 2190/1920 requires that any entity whose total equity is less than 50% of its share capital is obliged to convene shareholders' meeting within six months after its prior year end in order to approve actions for improving this ratio. In addition, article 48 of Greek Law 2190/1920

provides that an entity, whose total equity is less than 10% of its share capital and whose shareholders' meeting fails to take any decision for the restoration of the equity ratio, may be liquidated following a court decision, which may be requested by anyone who has a legitimate interest.

At December 31, 2011, the Group's capital adequacy ratio was below the minimum threshold of 8% (negative 2.6%). The amount required for the restoration of the capital adequacy ratio to 8% is estimated by the Bank of Greece at EUR 6.9 billion.

The Program, which has already been approved by the IMF, the European Central Bank (the "ECB") and the European Commission (collectively referred to as the "Troika") along with a specific sequence of disbursements, commits funds for the recapitalization plan, amounting up to EUR 50.0 billion and is now in the implementation phase under the auspices of the Bank of Greece. The main features of this Program are:

The Directors consider that it is appropriate to continue to adopt the going concern basis in preparing the financial statements for the Group and the Bank because:

In fact, in its letter to the Bank on April 20, 2012, the HFSF stated that, on April 19, 2012, the Bank of Greece replied to HFSF with the following:

Principles of consolidation—The consolidated financial statements of the Group include the accounts of the Bank and its direct and indirect subsidiaries, other than variable interest entities ("VIEs"), in which it holds, directly or indirectly, more than 50% of the voting rights or where it exercises control, for entities in which the equity holders have substantive voting interests. The Group also consolidates VIEs where the Group is the primary beneficiary. The Group consolidates a VIE when it has both the power to direct the activities that most significantly impact the VIE's economic success and a right to receive benefits or absorb losses of the entity that could be potentially significant to the VIE. The effects of inter-company transactions and balances have been eliminated.

Subsequent events—All material events that occurred after the date of the consolidated financial statements and before these were issued, have been either recognized or disclosed in the Notes to the consolidated financial statements.

The Group evaluated events from the date of these consolidated financial statements on December 31, 2011, through the issuance of these consolidated financial statements.

Redeemable non-controlling interest—Non-controlling interests (NCI) that are subject to put options held by third parties are accounted for as redeemable equity instruments. Redeemable NCI is presented outside "Permanent equity" as "Temporary equity". Such redeemable NCI is measured initially at fair value and subsequently at the higher of the cumulative amount that would result from applying the measurement guidance in ASC 810-10 or the redemption value, with any subsequent changes recognized immediately as they occur, and adjust the carrying amount of the instrument to equal the redemption value at the end of each reporting period. This adjustment is determined after the attribution of net income or loss of the subsidiary, pursuant to ASC 810-10. Such changes are recognized directly in "Accumulated Surplus".

Foreign currency translation—Assets, liabilities and operations of foreign branches and subsidiaries are recorded based on the functional currency of each entity. The functional currency is the local currency for the majority of the foreign operations. The assets, liabilities and equity are translated, for consolidation purposes, from the other local currencies to the reporting currency, EUR, at the current exchange rates. The resulting gains or losses are reported as a component of other comprehensive income and losses within shareholder's equity. Transactions executed in other than local currencies are first translated into the local reporting currency. Any related currency exchange adjustments are included in net trading profit/(loss).

Statement of cash flows—For the purposes of the consolidated statements of cash flows, cash and cash equivalents are defined as those amounts included in the balance sheet caption "Cash and due from banks".

Securities: Trading, Available-for-Sale (AFS), Held-to-Maturity (HTM)—Debt securities are classified as trading, available-for-sale or held-to-maturity and equity securities are classified as trading or available-for-sale, based on management's intention on the date of purchase. Debt securities which management has the positive intent and ability to hold to maturity are classified as held-to-maturity and are reported at amortized cost. Debt and equity securities that are bought and held principally for the purpose of resale in the near term are classified as trading instruments and are stated at fair value with realized and unrealized gains and losses included in net trading profit or loss. All other debt and equity securities are classified as available for sale and carried at fair value with net unrealized gains and losses included in accumulated other comprehensive income/(loss) on a net of tax basis. Interest and dividends on securities, including amortization of premiums and accretion of discounts are included in interest income. An unrealized loss exists when the current fair value of an individual security is less than its amortized cost basis determined using the average cost method at the individual security level. Unrealized losses that are determined to be temporary in nature are recorded, net of tax, in accumulated other comprehensive income/(loss) for available-for-sale securities, while such losses related to held-to-maturity securities are not recorded, as these investments are carried at their amortized cost (less any other-than-temporary impairment).

The Group conducts and documents periodic reviews of all securities with unrealized losses to evaluate whether an Other-than-Temporary-Impairment (OTTI) exists. Any credit related OTTI related to debt securities that the Group does not plan to sell and is not likely to be required to sell, is recognized in earnings as unrealized losses, with the non-credit related OTTI retained in accumulated other comprehensive income/(loss). For other impaired debt securities and equity securities, the entire OTTI is recognized in earnings as unrealized losses.

Factors considered in determining whether a loss is temporary include (a) the length of time for which fair value has been below cost; (b) the severity of the impairment; (c) the cause of the impairment and the financial condition and near-term prospects of the issuer; (d) activity in the market of the issuer which may indicate adverse credit conditions; and (e) the Group's ability and intent to hold the investment for a period of time sufficient to allow for any anticipated recovery.

For investments in equity securities (including mutual fund units), the Group considers the various factors described above, including its intent and ability to hold the equity security for a period of time sufficient for recovery of cost. In general, a significant and prolonged unrealized loss is an OTTI unless significant and robust evidence to the contrary exists.

When the Group lacks that intent or ability, the security's decline in fair value is deemed to be other than temporary and is recorded in earnings. Available-for-sale equity securities deemed to be other-than-temporarily impaired are written down to fair value, with the full difference between fair value and cost recognized in earnings.

Reclassifications between categories of investments—When rare circumstances cause significant deterioration in the trading activity or substantially affect the observable prices of investment securities classified in the trading category, the Group reclassifies such securities out of the trading category and into the held-to-maturity or available-for-sale categories, provided the securities meet definition of the respective category at the date of reclassification. Such reclassifications can occur only once in response to a single rare event.

If there is a change in intention or ability to hold a debt security to maturity, the Group reclassifies such securities out of the available-for-sale category and into the held-to-maturity category, provided the instruments meet the definition of the latter, at the date of reclassification.

For securities reclassified as described above, the fair value at the date of reclassification becomes the new amortized cost at that date.

When the securities reclassified out of the trading category include embedded derivatives, the Group reassesses at the reclassification date, whether the embedded derivatives need to be separated from the host contract, on the basis of the circumstances that existed when the Group became a party to the contract.

Derivatives—The Group maintains an overall risk management strategy that incorporates the use of derivative instruments to reduce certain risks related to interest rate and foreign currency volatility. On the date the Group enters into a derivative contract, the Group designates the derivative instrument as either hedging or as a freestanding derivative instrument. At December 31, 2011 and 2010 the Group did not have any of its derivative instruments designated as hedging instruments. For freestanding derivative instruments, changes in fair values are reported in current period net income and included in the net trading profit/(loss).

All derivatives are recognized on the consolidated balance sheet at fair value, without taking into consideration the effects of legally enforceable master netting agreements that allow the Group to settle positive and negative positions and offset cash collateral held with the same counterparty on a net basis. Derivatives are recorded as derivative assets or liabilities. The Group's management exercises judgment in determining the fair value of financial assets and liabilities. For exchange traded contracts, fair value is based on quoted market prices. For non-exchange traded contracts, fair value is based on

dealer quotes, pricing models, discounted cash flow analysis or quoted prices for instruments with similar characteristics. Valuations of derivative assets and liabilities reflect the value of the instrument including the values associated with counterparty risk. These values also take into account the Group's own credit standing, thus the valuation of the derivative instruments includes the value of the net credit differential between the counterparties to the derivative contract.

The Group occasionally purchases or issues financial instruments containing embedded derivatives. The embedded derivative is separated from the host contract and carried at fair value if the economic characteristics and risks of the derivative are not clearly and closely related to the economic characteristics of the host contract.

Equity method investments—Equity investments in which the Group exercises significant influence but does not control, are initially recorded at cost and the carrying amount of the investments is adjusted to recognize the Group's share of the earnings or losses of investees after the date of acquisition. The amount of the adjustment, after elimination of any intercompany gains and losses and impairment of goodwill, if any, is included in the determination of the Group's net income. Dividends received by the Group from its equity method investments reduce the carrying amount of those investments.

The excess of the cost of acquisition of the investments and the Group's equity in the investee's underlying net assets represents purchased goodwill. Equity method investment goodwill is not amortized but all equity investments are reviewed for impairment annually.

Loans and leases—Loans are included at their outstanding unpaid principal balances adjusted for charge-offs, the allowance for loan losses, and any deferred fees or costs on originated loans. Interest income is accrued on the unpaid principal balance. Discounts and premiums are amortized to income using the effective interest rate method.

Loan origination fees, net of certain direct origination costs, are deferred and recognized as an adjustment to the yield of the related loans.

There are no loans that have been originated which are intended for sale in the secondary market.

Loans include aggregate rentals on lease financing transactions and residual values net of related unearned income. Lease financing transactions represent direct financing leases. Unearned income is amortized under a method that results in an approximate level rate of return when related to the unrecovered lease investment.

A loan is determined to be past due when any amount with respect to the loan is not collected when contractually due.

The Group has identified two portfolio segments in accordance with ASC 310-10-20 and its internal policies, consumer loans and commercial loans. Consumer loans consist of a large number of homogeneous loans of small amounts given to individuals. Therefore, the consumer loans portfolio is diversified and more resilient to specific risks associated with individual borrowers, but may be more severely affected by changes in macroeconomic conditions (e.g. GDP evolution, unemployment and disposable income). Commercial loans in general consist of large exposures to fewer borrowers to cover their business financing needs. The commercial loans portfolio is less diversified, and therefore, more vulnerable to risks associated with individual borrowers.

As described in Note 13 the Group has elected fair value accounting for certain loans.

Write-offs—The Group's write-off policy prescribes which loans and receivables fall into its scope and the criteria that must be met for each type of asset in order for each write-off to be approved by the relevant competent committee.

Loan amounts to be written off for accounting purposes are individually identified and fully provided for.

For all loan amounts written-off for accounting purposes, documentation is retained and is available to evidence and support the reasoning for the write-off and that the appropriate actions have been taken.

The following factors are taken into consideration when qualifying a loan for write-off:

Written-off loans, either retail or corporate, are monitored until completion and exhaustion of legal actions having taken into consideration of the efforts and cost required.

Write-offs are approved by each competent committee in accordance with its authority limits prescribed in its charter.

Non-accruing loans—In general, for domestic loans the accrual of interest is discontinued at the time the loan is 90 days delinquent unless the credit is well secured and in process of collection. Residential real estate loans are placed on non-accrual status at the time the loan is 180 days delinquent. For foreign loans the accrual of interest is typically discontinued at the time the loan is 90 days delinquent. In all cases, loans are placed on non-accrual status, or written-off at an earlier date, if collection of principal or interest is considered doubtful.

The interest on these loans is accounted for on a cash-basis, until qualifying for return to accrual. Interest income is recognized upon receipt of the cash. Loans are returned to accrual status when all the principal and interest amounts contractually due are reasonably assured of repayment within a reasonable time frame (except for loans that the agreement has been terminated), or when the loans are modified (see below).

Modifications and Troubled Debt Restructurings ("TDRs")—Modifications are considered TDRs if, for economic or legal reasons related to the debtor's financial difficulties, a concession is granted to the customer that the Group would not otherwise consider. The concession granted typically involves the reduction of interest accrued off-balance sheet or the prolongation of maturity, without receiving additional collateral.

Each modified loan resets the number of days past due. TDRs that were non-accruing at the time of the restructuring remain non-accruing until a minimum number of payments are made by the borrower, ranging from 4 to 12 depending on the loan product.

TDRs are considered impaired and a loan loss allowance is estimated for these loans that take into consideration the fact that the loans were not accruing before the restructuring.

Allowance for loan losses—The allowance for loan losses is management's estimate of probable incurred loan losses in the lending portfolios. A loan is considered impaired when, based on current information and events, it is probable that the Group will be unable to collect all amounts due, including principal and interest, according to the contractual terms of the agreement.

Individually significant exposures are considered those which, if impaired would have a material impact on profit. Specifically, individually significant exposures are those customer exposures that, for each NBG Group entity, exceed the lower of 0.1% of the entity's equity and EUR 750,000.

Once a loan has been identified as individually impaired, management measures impairment in accordance with ASC 310-10-35. Individually impaired loans are measured based on the present value of payments expected to be received, or for loans that are solely dependent on the collateral for repayment, the estimated fair value of the collateral. If the recorded investment in impaired loans exceeds the measure of estimated fair value, a specific allowance is established as a component of the allowance for loan losses.

The Group performs periodic and systematic detailed reviews of its lending portfolios to identify inherent risks and to assess the overall collectability of those portfolios. Specifically, our methodology has three primary components: specific allowances, coefficient analysis and homogeneous analysis.

Specific allowance: For individually significant commercial loans, specific allowances are recorded based on: historical loss experience, current economic conditions and performance trends within specific industry sectors, payment history, cash flow analysis, collateral value and any other pertinent

information. Future expected cash flows take into consideration the customer's risk profile, historical information for similar customers as well as an estimate of the impact of current economic conditions and negative credit trends existing at the time of the assessment. These estimates are management's best estimates regarding the probable impact of the current economic environment on credit losses. If necessary, an allowance for loan losses is established for loans subject to specific allowance. Loss is measured as the difference between the loan's carrying amount and the present value of estimated future cash flows expected to be received.

Coefficient analysis: Most non-significant commercial loans are subject to coefficient analysis. A coefficient analysis is performed on commercial loans, for which no specific allowance is calculated, as described above and the related allowance is calculated using internal credit ratings and loss rates. Individual loans are grouped into 22 risk categories based on common characteristics such as industry, payment history (including delinquency), collateral values and other factors. The rating of each individual corporate customer is re-assessed at least once a year (and more frequently if necessary) and its rating may change based on the customer's financial position and prospects, qualitative criteria and current market conditions. Allowance percentages, or coefficients, based on historic loss rates among these groupings are then applied to determine the allowance for loan losses to be recorded. Our coefficient analysis for the commercial portfolio uses historical data to estimate the default rate assigned to each credit rating. Our rating model was first validated in 2005 by an internationally recognized and independent advisor, and optimized for use in Greece. Since then, it is monitored regularly and its predictive ability is back-tested on an annual basis by our Group Risk Management Division following the Basel II guidelines on monitoring of rating models. The back testing has shown that the predictive ability of the model is strong, so no change in criteria and weights was necessary. Loss rates are estimated at least annually as at the reporting date.

Homogeneous analysis: The allowance on certain homogeneous loan portfolios, which generally consist of mortgage loans, credit cards and other consumer loans in the consumer loans portfolio segment, and certain non-significant commercial loans is based on the valuation of aggregated portfolios of homogeneous loans, generally by loan type, products or channel of distribution.

Loss forecast models are utilized for portfolios of homogeneous loans which consider a variety of factors including, but not limited to, historical loss experience, anticipated defaults or foreclosures based on portfolio trends, delinquencies and credit scores, and expected loss factors by loan type. In addition, in calculating our homogeneous allowances for loan losses we consider the current economic conditions and trends and changes in lending policies and procedures (see Note 13). The period analyzed for the estimation of the loss rates takes into consideration the long recovery periods historically observed in Greece, and is six years for credit cards and consumer loans and twelve years for mortgage loans. These longer recovery periods follow from Greek legislation and judicial system, as well as business practices.

Additions to the allowance for loan losses are made by charges to the provision for loan losses, credit exposures deemed to be uncollectible are charged against the allowance for loan losses. Recoveries of amounts previously charged as uncollectible are credited to the allowance for loan losses.

Subject to compliance with tax laws in each jurisdiction, a loan which is deemed to be uncollectible or forgiven is written off against the related provision for loans impairment. Subsequent recoveries are credited to provision for loan losses in the Income statement.

Under Greek regulations, loans cannot be written off until legal remedies for recovery, which can be a very lengthy process, have been exhausted. Similar regulations apply to our subsidiaries outside Greece, however the legal process takes, in general, significant less time than in Greece. Historical loss amounts are based on recoveries relating both to balances written off and to balances not written off because not all legal actions for recovery have been fully exhausted.

In addition to the allowance for loan losses, the Group also estimates probable losses related to unfunded commitments, such as commercial letters of credit, standby letters of credit and financial guarantees written. The allowance is estimated using the methodology applied to commercial loans.

Fair Value—The Group measures the fair market values of its financial instruments in accordance with ASC 820 "Fair Value Measurements and Disclosures", which establishes a framework for measuring fair value and also provides certain disclosure requirements. Also in accordance with ASC 820, the Group categorizes its financial instruments, based on the priority of inputs to the valuation technique, into a three-level hierarchy, as discussed below. Trading account assets and liabilities, derivative assets and liabilities, AFS debt and marketable equity securities, and certain other assets are carried at fair value. The Group has also elected to carry certain assets and liabilities at fair value in accordance with ASC 825 "Financial Instruments", including certain loans and long-term debt. ASC 825 allows an entity the irrevocable option to elect fair value for the initial and subsequent measurement for certain financial assets and liabilities on a contract-by-contract basis.

The fair value disclosures are presented in Note 36 . The levels of hierarchy with respect to the fair values are the following:

Level 1: Quoted prices in active markets for identical assets or liabilities. Level 1 assets and liabilities include debt and equity securities and derivative contracts that are traded in an active exchange market.

Level 2: Observable inputs other than Level 1 prices, such as quoted prices for similar assets or liabilities, quoted prices in markets that are not active, or other inputs that are observable or can be corroborated by observable market data for substantially the full term of the assets or liabilities. Level 2 assets and liabilities include debt securities with quoted prices that are traded less frequently than exchange-traded instruments, as well as debt securities without quoted prices and certain derivative contracts whose values are determined using pricing models, discounted cash flow methodologies, or similar techniques with inputs that are observable in the market or can be derived principally from or corroborated by observable market data. This category generally includes government and corporate debt securities with prices in markets that are not active and over-the-counter derivative contracts.

Level 3: Unobservable inputs that are supported by little or no market activity and that are significant to the fair value of the assets or liabilities. Level 3 assets and liabilities include financial instruments whose value is determined using pricing models, discounted cash flow methodologies, or similar techniques, as well as instruments for which the determination of fair value requires significant management judgment or estimation.

Transfers into or out of Level 3 are made if the inputs used in the financial models measuring the fair values of the assets and liabilities become unobservable or observable, respectively, in the current marketplace.

Goodwill, software and other intangibles—Net assets of companies acquired in purchase transactions are recorded at fair value at the date of the acquisition. As such, the historical cost basis of individual assets and liabilities are adjusted to reflect their fair value. The Group accounts for changes in an ownership interest in a subsidiary that does not result in deconsolidation as an equity transaction if it retains its controlling financial interest in the subsidiary. Identified intangibles are amortized on a straight-line basis over the period benefited. Goodwill is not amortized, but is reviewed at the reporting unit level for potential impairment at least on an annual basis at the end of the reporting period, or more frequently if events or circumstances indicate a potential impairment. The impairment test is performed in two phases. The first step of the goodwill impairment test compares the fair value of the reporting unit with its carrying amount, including goodwill. If the fair value of the reporting unit exceeds its carrying amount, goodwill of the reporting unit is considered not impaired; however, if the carrying amount of the reporting unit exceeds its fair value, an additional procedure must be performed. That additional procedure compares the implied fair value of the reporting unit's goodwill with the carrying amount of that goodwill. An impairment loss is recorded to the extent that the carrying amount of goodwill exceeds its implied fair value. Intangible assets subject to amortization are evaluated for impairment if events and circumstances indicate a possible impairment. Intangible assets that are not subject to amortization are tested for impairment annually or more frequently if events or changes in circumstances indicate that the assets might be impaired. Intangible assets are amortized using an estimated range of anticipated lives, which are 3 to 12 years for software and 6 to 11 years for intangibles arising on acquisitions such as customer relationships and core deposits. Trade names have indefinite useful lives.

Premises and equipment—Premises and equipment, including buildings, are stated at cost less accumulated depreciation, except for land, which is stated at cost. Depreciation is provided on a straight-line depreciation basis over the estimated useful lives of individual assets and classes of assets. Maintenance, repairs and minor alterations are expensed as incurred.

Long-lived assets, including those that are to be disposed of, are evaluated for impairment when events or changes in circumstances indicate that the carrying amount may not be recoverable. Recoverability is evaluated by determining if the difference between the expected undiscounted future cash flows of a long-lived asset is lower than its carrying value. If not recoverable, the Group recognizes an impairment loss for the difference between the carrying amount and the estimated fair value of the asset. The impairment loss, if any, is reflected in non-interest expense.

Variable Interest Entities—The Group is involved with VIEs in the normal course of business. The primary use of VIEs is to obtain sources of liquidity for the Group. The Group is also involved in VIEs used for the securitization of certain loans as discussed below.

VIEs are entities defined in ASC 810 "Consolidation" as entities which either have a total equity investment at risk that is insufficient to permit the entity to finance its activities without additional subordinated financial support or whose equity investors lack the characteristics of a controlling financial interest (i.e., ability to make significant decisions through voting rights, right to receive the

expected residual returns of the entity, and obligation to absorb the expected losses of the entity). Investors that finance the VIE through debt or equity interests, or other counterparties that provide other forms of support, such as guarantees, or subordinated fee arrangements, are variable interest holders in the entity.

The Group is deemed to have a controlling financial interest and is the primary beneficiary of a VIE if it has both the power to direct the activities that most significantly impact the VIE's economic success and a right to receive benefits or absorb losses of the entity that could be potentially significant to the VIE. The Group continually reassess whether it is the primary beneficiary of a VIE.

Securitization—The Group securitizes, sells and services interests in residential mortgage loans, credit cards, consumer and commercial loans. In general the loans are sold to VIEs, which issue securities collateralized with these assets. The accounting for these activities is governed by ASC 860 "Transfers and Servicing". When a financial asset is transferred, the Group assesses whether the transferor and its consolidated affiliates have surrendered control over the transferred financial assets, determining first whether the transferee should be consolidated. A transfer of an entire financial asset, or a portion of a financial asset that meets the definition of a participating interest, in which the Group has surrendered control over those financial assets shall be accounted for as a sale if and only if all of the following conditions are met:

For transfers of financial assets recorded as sales, the Group recognizes and initially measures at fair value all assets obtained (including beneficial interests) and liabilities incurred. The Group recognizes a gain or loss in net trading profit/(loss) for the difference between the carrying amount and the fair value of the assets sold.

Income taxes—Income tax payable on profits, based on the applicable tax laws in each jurisdiction, is recognized as an expense in the period in which profits arise. The Group accounts for deferred income taxes under the asset and liability method, which requires the recognition of deferred tax assets and liabilities for the expected future tax consequences of events that have been included in the financial statements.

Deferred income tax assets and liabilities are determined using the asset and liability (or balance sheet) method based on enacted income tax rates/laws expected to apply upon reversal. Under this

method, the net deferred tax asset or liability is determined based on the tax effects of the differences between the book and tax bases of the balance sheet assets and liabilities. The impact on changes in tax laws and rates are recognized in their entirety within income tax expense in the period that includes the date of enactment in the respective jurisdiction.

Recognition of deferred tax assets is based on management's belief that it is more likely than not that the tax benefit associated with certain temporary differences, such as tax operating loss carry forward and tax credits, will be realized, based on all available evidence. A valuation allowance is recorded to reduce the amount of the deferred tax assets to that amount that is at least more likely than not to be realized. In making such determination, the Group considers all available positive and negative evidence, including future reversals of existing taxable temporary differences, projected future taxable income, tax planning strategies and recent financial results. In the event the Group was to determine that it would be able to realize its deferred income tax assets in the future in excess of their net recorded amount, it would make an adjustment to the valuation allowance which would reduce the provision for income taxes.

The Group does not recognize in its financial statements tax benefits for tax positions unless it has met the recognition and measurement principles contained in ASC 740 "Income taxes". A benefit can only be recognized if it is "more likely than not" that the benefit will be sustained on audit by the taxing authority based solely on the technical merits of the associated tax position. In this evaluation, the Group assumes that the position (1) will be examined by a taxing authority that has full knowledge of all relevant information and (2) will be resolved in the court. If the recognition threshold is not met, no benefit is recognized, even when the Group believes that a certain amount of benefit will ultimately be realized. Tax benefits for positions meeting the recognition criteria, are recognized in the financial statements in the amount that is at least more likely than not to be sustained upon settlement with the tax authorities. The Group recognizes interest accrued related to unrecognized tax benefits and penalties as income tax expense.

Insurance operations—Insurance operations include both life and general (property and casualty) insurance underwriting operations. Life insurance underwriting operations include traditional and universal life-type contracts. Traditional basic individual life insurance policies as well as endowment and annuity policies offered through the Group's network, are accounted for as long-duration contracts whereas group life insurance policies, including optional life and disability and payment protection policies offered with the Group's mortgage loans and supplementary coverage in individual life insurance policies, are accounted for as short-duration contracts. Property and Casualty insurance policies are accounted for as short-duration contracts.

The insurance liability related to such contracts (outstanding claims reserve and provision for claims incurred but not reported ("IBNR")) is included in Insurance Reserves in the Balance Sheet. Income and expenses from insurance operations are included in other non-interest income and expenses. In particular, premiums from life insurance and mortgage payment insurance plans are included in "Other non-interest income", whereas claims, reserve movement and commissions are included in "Other non-interest expense".

Premium revenues from traditional life insurance policies (long-duration contracts) are recognized as revenue as and when they become due from policyholders. Variable costs incurred in the acquisition of such policies are capitalized and expensed proportionately with the recognition of premium

revenues. Premiums collected on universal life-type contracts are not reported as revenue. Revenues from such contracts represent amounts assessed against policy holders and are reported in the period that the amounts are assessed. Premium income from short duration contracts, including reinsurance assumed, is recognized over the life of the policy. Income and costs on policies, which relate to subsequent periods are deferred and recognized in the period to which they relate. Claims relating to property and casualty policies are recognized as and when these become known based on the information available.

Insurance reserves for expected costs relating to life insurance policies are accrued over the current and expected renewal periods of the contracts. The present value of estimated future policy benefits payable, less the present value of estimated future net premiums to be collected is estimated using approved actuarial methods that use assumptions about future investment yields, mortality, expenses, options and guarantees, morbidity and termination rates at the time of inception of insurance contracts. Original assumptions are adjusted to reflect actual experience and any premium deficiency estimated is charged off to income for the period. Revised assumptions reflect estimates of future monetary inflation, medical inflation, the swap rate of bonds as at the end of each reporting period and recent experience concerning risk factors mentioned above. An appropriate discount factor is used.

Insurance reserves for property and casualty insurance include, apart from an unearned premium reserve, a provision for outstanding claims and IBNR. Loss estimates rely on observations of loss experience for similar historic events that relate to cumulative gross paid claim amount, settled claim amount, incurred claim amount and claim number developments. Such observations are periodically revised and any premium deficiency is charged to income for the period. Projections are based on historical development patterns. The development ratios are adjusted in a small number of cases to remove the effect of claim developments, which appear to be of an exceptional nature. Projections of reinsurance recoveries are also undertaken. Allowance is made for claim adjustment expenses and an appropriate discount factor is used.

Pensions—The Group sponsors both defined contribution and defined benefit pension plans, including defined benefit plans for children of Group personnel. The Group also provides termination indemnities to its retiring staff, depending on the Group company and the jurisdiction in which it operates.

Contributions to defined contribution plans are charged to the income statement as employee benefits when the employee renders service to the Group.

With regards to defined benefit pension plans, the Group calculates the projected benefit obligation at the end of each reporting period as the actuarial present value of all benefits attributed to employee service rendered based on the respective plan's benefit formula. This obligation less the fair value of any plan assets represents the funded status of the Group's plans and is recognized in the consolidated balance sheet under accounts payable, accrued expenses and other liabilities. Key assumptions used for the actuarial calculation are determined by the Group through future projections, which are based on historical trends, current market data and agreements between Group companies and their staff. Net periodic pension cost is recognized in the Group's income statement under employee benefits and includes service cost (the actuarial present value of benefits attributed to services rendered by employees), expected return on plan assets, amortization of prior service cost or credit and actuarial gains or losses. Net gains and losses are amortized to net periodic pension cost if,

as of the beginning of the year, that net gain or loss exceeds 10 percent of the greater of the projected benefit obligation or the market related value of plan assets. Amortization of net gains and losses and prior service cost is performed over the average remaining service period of active employees expected to receive benefits under the plan.

Other assets and other liabilities—Other assets includes, among other items, assets acquired through foreclosure proceedings, accounts receivable of non-financial services sector subsidiaries, deferred tax assets and taxes withheld.

Other liabilities includes, among other items, accrued expenses and deferred income, deferred tax liabilities, accrued interest and commissions, pension liabilities, dividends payable and other accounts payable.

Foreclosed assets—Foreclosed assets arise when the Group initiates legal actions for debt collection upon the recognition that repayment or restructuring of the debt cannot be achieved. In case the exposures are collateralized with assets, legal actions involve the initiation of an auction program that targets the repayment of the loans through the collateral liquidation value.

Assets that are classified as "foreclosed assets" are included in other assets upon actual foreclosure or when physical possession of the collateral is taken, through mutual agreement or court action. These assets are reported as held for sale in accordance with ASC 360-10-45-9. Foreclosed properties are initially measured at the fair value of the property less estimated costs to sell. Prior to foreclosure, any write-downs, if necessary, are charged to the allowance for loan losses. Subsequent to foreclosure, gains or losses on the sale of, and losses on the periodic revaluation of, foreclosed properties are recorded in "Net other income/(expense)".

Discontinued operations—A discontinued operation is a component of the Group that comprises operations and cash flows that can be clearly distinguished, operationally and for financial reporting purposes, from the rest of the entity. Classification as discontinued operations occurs upon disposal or when the operations meet the criteria to be classified as held for sale. Discontinued operations are presented on the face of the income statement.

Dividend policy—The Bank, on the basis of its statutory financial statements prepared in accordance with IFRS as endorsed by the EU, pays dividends out of:

Each year the Bank is required, by Greek Law 2190/1920, to declare and distribute a minimum dividend out of its net profits, if any, equal to 35% of the net profits for the year less statutory reserves, any profits resulting from the sale of equity participations that represent at least 20% of the paid up share capital of a subsidiary company in which the Bank has held an equity participation for at least ten years and unrealized net gains from financial instruments.

Any distribution of the remainder of the distributable profits must be approved by a General Meeting of the Shareholders with the ordinary quorum and majority voting requirements. No distribution can be effected if, on the closing date of the last financial year, the total shareholders' equity is, or will become after that distribution, lower than the sum of share capital and the reserves, the distribution of which is prohibited by Greek law or the Bank's Articles of Association.

A majority representing at least 65% of the paid-up share capital may vote to waive this. The undistributed dividend (up to 35% minimum dividend) must then be transferred to a special reserve which must, within four years following the General Meeting, be distributed in the form of a stock dividend. Furthermore, a majority representing at least 70% of the Bank's paid-up capital may vote to waive this stock dividend.

According to the provisions of article 28 of Greek Law 3756/2009 and decision 20708/B/1175/23.4.2009 of the Minister of Economy and Finance, banks participating in the plan to strengthen the liquidity of the Greek banking sector and economy (the "Hellenic Republic bank support plan") are allowed to distribute dividends to ordinary shareholders up to 35% of distributable profits at the parent company level. Moreover, pursuant to Greek Law 3723/2008, article 28 of Greek Law 3756/2009 and article 39 of Greek Law 3844/2010, for 2008 and 2009, banks participating in the plan were allowed to distribute dividends to ordinary shareholders only in the form of shares, which cannot be treasury shares. As it is clearly stipulated in the above law and decision, the above restrictions, do not apply to any dividend or fixed return on preference shares that are being traded in foreign organized markets.

In accordance with Greek Law 3965/2011, banks participating in the plan are allowed to distribute dividends, for 2010, only in the form of shares, however, these cannot be treasury shares.

Normally, dividends are declared and paid in the year subsequent to the reporting period. For 2011, the Group approved the non-distribution of dividends to any class of shares, that is, to the redeemable preference shares held by the Greek State, the non-cumulative, non-voting redeemable preference shares and the ordinary shares.

Resale and repurchase agreements—The Group enters into securities purchases under agreements to resell (resale agreements) and securities sales under agreements to repurchase (repurchase agreements) of substantially identical securities. Resale agreements and repurchase agreements are accounted for as secured lending and secured borrowing transactions, respectively.

The amounts advanced under resale agreements and the amounts borrowed under repurchase agreements are carried on the balance sheet at the amount advanced or borrowed plus accrued interest. The market value of these securities is monitored and the level of collateral is adjusted accordingly.

Repurchase of own debt—Repurchase of own debt is accounted for as a derecognition in accordance with ASC 405-20 "Liabilities—Extinguishment of liabilities". On the date of extinguishment the difference between the carrying value (which includes amortization of any premium/discount and issue costs up to the re-acquisition date) and the acquisition price is recorded as a gain in the income statement.

Share-based payment transactions—The Bank has approved Group-wide share options plans for the executive members of the Board of Directors ("BoD"), management and staff of the Group. The fair value of the employee services received in exchange for the grant of the options is recognized as a compensation cost, with the corresponding credit recognized in equity. The total amount to be expensed over the requisite period, which is determined by reference to the fair value of the share options granted, is calculated with the graded vesting attribution method. The fair value of the options is determined using an option-pricing model that takes into account the stock price at the grant date,

the exercise price, the expected life of the options, the expected volatility of and the expected dividends on the underlying stock, and the risk-free interest rate over the expected life of the option.

When the options are exercised and new shares are issued, the proceeds received net of any transaction costs are credited to common stock and additional paid-in capital.

Accumulated other comprehensive income/(loss) (Accumulated OCI)—The Group records unrealized gains and losses on AFS Securities, unrecognized actuarial gains and losses, transition obligation and prior service costs on Pension and Postretirement plans and foreign currency translation adjustments in Accumulated OCI, net of tax. Gains and losses on AFS Securities are reclassified to Net income/(loss) as the gains or losses are realized upon sale of the securities. Other-than-temporary impairment charges are reclassified to Net income/(loss) at the time of the charge. Translation gains or losses on foreign currency translation adjustments are reclassified to Net income/(loss) upon the substantial sale or liquidation of investments in foreign operations.

Treasury stock—The Group parent company's common stock, owned by the Group entities, is considered to be treasury stock and is recorded at cost. Gains and losses on disposal of treasury stock are recorded in equity.

Earnings per share—Basic earnings per share is computed by dividing income available to common shareholders by the weighted average number of common shares outstanding for the period. Diluted earnings per share reflects the potential dilution that could occur if securities or other contracts were exercised and is computed after giving consideration to the weighted average dilutive effect of these common stock equivalents.

Adjustments to the carrying amount of redeemable non-controlling interest in the form of a common stock instrument with a fair value redemption feature do not impact earnings per share.

For the purpose of the earnings per share calculations, shares owned by entities within the Group are not included in the calculations of the denominators.

Use of estimates—In preparing these consolidated financial statements, management is required to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities as of the date of the consolidated balance sheets and the reported amounts of income and expenses during the reporting periods. Actual results could differ from those estimates.

In July 2010, the FASB issued ASU 2010-20, "Disclosures about the Credit Quality of Financing Receivables and the Allowance for Credit Losses" (ASU 2010-20), an update to ASC Topic 310—Receivables. The amendments in ASU 2010-20 enhance disclosures about the credit quality of financing receivables and the allowance for credit losses. As a result of the update, entities are required to provide a greater level of disaggregated information about the credit quality of financing receivables and the allowance for credit losses. Entities are also required to disclose credit quality indicators, past due information, and modifications of its financing receivables. The enhanced disclosures are designed to help financial statement users assess an entity's credit risk exposures and its allowance for credit losses. The disclosures as of the end of a reporting period were effective for the first interim or annual

reporting period ending after December 15, 2010. The disclosures about activity that occurred during a reporting period are effective for the first annual reporting period beginning after December 15, 2010 and the disclosures regarding Troubled Debt Restructurings will be effective for the for the first interim or annual reporting period beginning on or after June 15, 2011. ASU 2010-20 is an update only for disclosures and as such did not impact the Group's financial position, results of operations or cash flows. The Group adopted ASU 2010-20 on December 31, 2010 and provided the disclosures under this ASU that were effective for the first annual reporting period ending after December 15, 2010 in the Group's consolidated financial statements in the Group's Annual Report 2010. Disclosures about activity that occurred during the reporting period were provided for the year ended December 31, 2011 for the first time. For further information, refer to Note 13.

In January 2010, the FASB issued ASU 2010-06, "Improving Disclosures about Fair Value Measurements" (ASU 2010-06), an update to ASC Topic 820—Fair Value Measurement. ASU 2010-06 requires both new and clarifies existing fair value measurement disclosures. The new requirements include disclosure of significant transfers in and out of Level 1 and 2 and gross presentation of purchases, sales, issuances, and settlements in the reconciliation of beginning and ending balances of Level 3 instruments. The clarifications required by ASU 2010-06 include the level of disaggregation in the fair value hierarchy and Level 3 reconciliation of assets and liabilities by class of financial instrument. In addition, the ASU expanded disclosures about the valuation techniques and inputs used to measure fair value for both recurring and nonrecurring fair value measurements included in Levels 2 and 3 of the fair value hierarchy.

The new disclosures and clarifications were effective for interim and annual periods beginning after December 15, 2009, except the disclosures about purchases, sales, issuances, and settlements in reconciliation of beginning and ending balances of Level 3 instruments, which are effective for interim and annual periods beginning after December 15, 2010. ASU 2010-06 is an update only for disclosures and as such did not impact the Group's financial position, results of operations or cash flows. For further information, refer to Note 36.

In December 2010, the FASB issued ASU 2010-28 "When to Perform Step 2 of the Goodwill Impairment Test for Reporting Units with Zero or Negative Carrying Amounts". The amendments in this ASU modify Step 1 so that for those reporting units, an entity is required to perform Step 2 of the goodwill impairment test if it is more likely than not that a goodwill impairment exists. In determining whether it is more likely than not that a goodwill impairment exists, an entity should consider whether there are any adverse qualitative factors indicating that an impairment may exist. The qualitative factors are consistent with existing guidance, which requires that goodwill of a reporting unit be tested for impairment between annual tests if an event occurs or circumstances change that would more likely than not reduce the fair value of a reporting unit below its carrying amount. These amendments were effective for the Group's consolidated financial statements for the year ended December 31, 2011 and did not have an impact on the consolidated statements of income and consolidated balance sheets.

In April 2010, the FASB issued ASU 2010-15, "How Investments Held through Separate Accounts Affect an Insurer's Consolidation Analysis of Those Investments". This ASU clarifies that an insurance entity should not consider any separate account interests held for the benefit of policy holders in an investment to be the insurer's interests and should not combine those interests with its general account interest in the same investment when assessing the investment for consolidation, unless the separate account interests are held for the benefit of a related party policy holder as defined in the Variable

Interest Entities Subsections of Subtopic 810-10 and those Subsections require the consideration of related parties. This ASU also amends Subtopic 944-80 to clarify that for the purpose of evaluating whether the retention of specialized accounting for investments in consolidation is appropriate, a separate account arrangement should be considered a subsidiary. The amendments do not require an insurer to consolidate an investment in which a separate account holds a controlling financial interest if the investment is not or would not be consolidated in the standalone financial statements of the separate account. The amendments also provide guidance on how an insurer should consolidate an investment fund in situations in which the insurer concludes that consolidation is required. These amendments were effective for the Group's consolidated financial statements for the year ended December 31, 2011 and did not have an impact on the consolidated statements of income and consolidated balance sheets.

In April 2010, the FASB issued ASU 2010-13, "Effect of Denominating the Exercise Price of a Share-Based Payment Award in the Currency of the Market in Which the Underlying Equity Security Trades". This ASU clarifies that an employee share-based payment award with an exercise price denominated in the currency of a market in which a substantial portion of the entity's equity securities trades should not be considered to contain a condition that is not a market, performance, or service condition. Therefore, an entity would not classify such an award as a liability if it otherwise qualifies as equity. This ASU was effective for the Group's consolidated financial statements for the year ended December 31, 2011 and did not have an impact on the consolidated statements of income and consolidated balance sheets.

In December 2010, the FASB issued ASU 2010-29, "Disclosure of Supplementary Pro Forma Information for Business Combinations". The amendments in this ASU specify that if a public entity presents comparative financial statements, the entity should disclose revenue and earnings of the combined entity as though the business combination(s) that occurred during the current year had occurred as of the beginning of the comparable prior annual reporting period only. The amendments also expand the supplemental pro forma disclosures to include a description of the nature and amount of material, nonrecurring pro forma adjustments directly attributable to the business combination included in the reported pro forma revenue and earnings. The amendments affect any public entity as defined by Topic 805 that enters into business combinations that are material on an individual or aggregate basis. These amendments were effective for the Group's consolidated financial statements for the year ended December 31, 2011 and had no impact on the Group's disclosures since no new business combination occurred during the year.

In September 2011, FASB issued ASU 2011-09 "Disclosures about an Employer's Participation in a Multiemployer Plan", requiring companies participating in multiemployer pension plans to disclose more information about their involvement in those plans. Multiemployer pension plans are typically defined benefit plans to which two or more unrelated employers contribute, usually in accordance with one or more collective bargaining agreements. However, because the assets and obligations of different employers are commingled, employers record an expense only for contributions due to the plan each reporting period, as they would for a defined contribution plan. Companies do not have to record a liability for future benefit payments to employees, even though future contributions represent significant potential obligations for some companies that participate in the plans, including those in the construction, entertainment, trucking and maritime, and retail food industries. This ASU was effective for the Group's consolidated financial statements for the year ended December 31, 2011 and did not have an impact on the consolidated statements of income and consolidated balance sheets.

In December, 2011, the FASB issued ASU 2011-11, "Disclosures about Offsetting Assets and Liabilities", which requires the disclosure of information about offsetting and related arrangements to enable users of its financial statements to understand the effect of those arrangements on its financial position. Entities are required to disclose both gross information and net information about both instruments and transactions eligible for offset in the statement of financial position and instruments and transactions subject to an agreement similar to a master netting arrangement. This scope would include derivatives, sale and repurchase agreements and reverse sale and repurchase agreements, and securities borrowing and securities lending arrangements. The amendments are effective for annual and interim for annual reporting periods beginning on or after January 1, 2013, and interim periods within those annual periods. The Group has not yet determined the impact of this guidance on the Group's financial position or results of operations.

In September, 2011, the FASB issued ASU 2011-08, "Testing Goodwill for Impairment", which amends the guidance in ASC 350-202 on testing goodwill for impairment. Under the revised guidance, entities testing goodwill for impairment have the option of performing a qualitative assessment before calculating the fair value of the reporting unit (i.e., step 1 of the goodwill impairment test). If entities determine, on the basis of qualitative factors, that the fair value of the reporting unit is more likely than not less than the carrying amount, the two-step impairment test would be required. The ASU does not change how goodwill is calculated or assigned to reporting units, nor does it revise the requirement to test goodwill annually for impairment. In addition, the ASU does not amend the requirement to test goodwill for impairment between annual tests if events or circumstances warrant; however, it does revise the examples of events and circumstances that an entity should consider. The amendments are effective for annual and interim goodwill impairment tests performed for fiscal years beginning after December 15, 2011. Early adoption is permitted. The implementation of this guidance is not expected to have a significant impact on the Group's financial position or results of operations.

In June 2011, FASB issued ASU 2011-05, "Presentation of Comprehensive Income". This amendment requires comprehensive income to be reported in either a single statement or in two consecutive statements reporting net income and other comprehensive income. The amendments do not change what items are reported in other comprehensive income or the requirement to report classification of items from other comprehensive income to net income. These amendments are effective prospectively for the Group's consolidated financial statements for the year beginning January 1, 2012, involves disclosures only, and is not expected to have a significant impact on the consolidated statements of income and consolidated balance sheets. In December 2011, FASB issued ASU 2011-12 which deferred certain aspects of ASC 2011-05. These deferred aspects did not include the requirement to report comprehensive income in either a single statement or in two consecutive statements reporting net income and other comprehensive income. The deferral period will begin for the Group on January 1, 2012 and would remain in effect indefinitely.

In May 2011, FASB issued ASU 2011-04, "Amendments to Achieve Common Fair Value Measurement and Disclosure Requirements in U.S. GAAP and IFRSs". These amendments result in common fair value measurement and disclosure requirements in U.S. GAAP and IFRSs. Consequently, the amendments change the wording used to describe many of the requirements in U.S. GAAP for measuring fair value and for disclosing information about fair value measurements. For many of the requirements, the amendments in this ASU do not result in a change in the application of the

requirements in Topic 820. Some of the amendments clarify the application of existing fair value measurement requirements. Other amendments change a particular principle or requirement for measuring fair value or for disclosing information about fair value measurements. These amendments are effective prospectively for the Group's consolidated financial statements for the year beginning January 1, 2012. The implementation of this guidance is not expected to have a significant impact on the Group's financial position or results of operations.

In April 2011, FASB issued ASU 2011-03, "Reconsideration of Effective Control for Repurchase Agreements". The ASU removes from the assessment of effective control the criterion requiring the transferor to have the ability to repurchase or redeem the financial assets on substantially the agreed terms, even in the event of default by the transferee. The ASU does not change the other criteria in ASC 860. Accordingly, a transferor in a repo transaction is deemed to have effective control if the following conditions are met: (1) the financial assets to be repurchased or redeemed are the same or substantially the same as those transferred; (2) the agreement is to repurchase or redeem them before maturity, at a fixed or determinable price; and (3) the agreement is entered into contemporaneously with, or in contemplation of, the transfer. The guidance is effective prospectively for transactions, or modification of existing transactions, of the Group that occur on or after January 1, 2012, and is not expected to have an impact on the consolidated statements of income and consolidated balance sheets.

In April 2011, FASB issued ASU 2011-02, "A Creditor's Determination of whether a Restructuring Is a Troubled Debt Restructuring", to help creditors in determining whether a creditor has granted a concession and whether a debtor is experiencing financial difficulties for purposes of determining whether a restructuring constitutes a troubled debt restructuring. The new guidance requires for creditors to evaluate modifications and restructurings of receivables using a more principles-based approach, which may result in more modifications and restructurings being considered troubled debt restructurings. In addition, the amendments to Topic 310 clarify that a creditor is precluded from using the effective interest rate test in the debtor's guidance on restructuring of payables when evaluating whether a restructuring constitutes a troubled debt restructuring. These amendments are effective for the Group's consolidated financial statements for the year beginning January 1, 2012 and are not expected to have an impact on the consolidated statements of income and consolidated balance sheets.

In October 2010, the FASB issued ASU 2010-26 "Accounting for Costs Associated with Acquiring or Renewing Insurance Contracts". The amendments in this ASU specify that certain costs incurred in the successful acquisition of new and renewal contracts should be capitalized. Those costs include incremental direct costs of contract acquisition that result directly from and are essential to the contract transaction(s) and would not have been incurred by the insurance entity had the contract transaction(s) not occurred. Additionally, advertising costs are only to be capitalized as deferred acquisition costs if the capitalization criteria for direct-response advertising in Subtopic 340-20 are met. All other acquisition-related costs—including costs incurred by the insurer for soliciting potential customers, market research, training, administration, unsuccessful acquisition or renewal efforts, and product development—should be charged to expense as incurred. Administrative costs, rent, depreciation, occupancy, equipment, and all other general overhead costs are considered indirect costs and should also be charged to expense as incurred. These amendments are effective for the Group's consolidated financial statements for the year for the year beginning January 1, 2012. The Group is currently assessing the potential impact from the adoption of this ASU on the consolidated statements of income and consolidated balance sheets.

NOTE 4: MERGERS, ACQUISITIONS, DISPOSALS AND NEW ENTITIES ESTABLISHED (Continued)

The schedule below presents effects of changes in NBG Group's ownership interest in its subsidiaries on NBG Group's equity:

The Bank and the other banks of the Group are required to maintain a current account with the respective central banks of their countries, to facilitate interbank transactions with the central banks, its member banks and other financial institutions through the Trans-European Automated Real-Time Gross Settlement Express Transfer system (TARGET).

The Bank of Greece is the primary regulator of depository institutions in Greece. Bank of Greece requires all banks established in Greece to maintain deposits equal to 2% of total customer deposits as these are defined by the ECB. Similar requirements apply to the other banking subsidiaries of the Group. The Bank's deposits bear interest at the refinancing rate as set by the ECB (1% at December 31, 2011) while the corresponding deposits of Finansbank, UBB and certain other subsidiaries are non-interest bearing.

The Group enters into purchases of securities under agreements to resell substantially identical securities. These agreements are classified as lending arrangements. Agreements with third parties specify the Group's rights to request collateral, based on its monitoring of the fair value of the underlying securities on a daily basis. Securities accepted as collateral may be sold or re-pledged. The Group has sold or re-pledged as at December 31, 2010 and 2011, EUR 98,500 thousand and EUR 328,031 thousand, respectively, of the securities accepted as collateral.

Fair value of debt and equity assets held for trading purposes at December 31, comprised:

	2010

	As restated⁽¹⁾
	(EUR in thousands)
Greek government bonds		797,377	259,233
Debt securities issued by other governments and public sector entities		177,333	219,807
Debt securities issued by Greek financial institutions		300,041	44,395
Debt securities issued by foreign financial institutions		398,845	110,026
Corporate debt securities issued by Greek companies		16,956	10,876
Corporate debt securities issued by foreign companies		110,448	5,547
Equity securities issued by Greek companies		6,082	7,767
Equity securities issued by foreign companies		10,272	8,750
Greek treasury bills		934,552	2,268,222
Foreign treasury bills		13,562	24,057
Mutual fund units		19,854	5,408

Total		2,785,322	2,964,088

Net unrealized losses on trading assets (debt and equity) of EUR 78,316 thousand, EUR 288,545 thousand and EUR 713,711 thousand were included in net trading loss during 2009, 2010 and 2011, respectively.

During 2010, the Group, in accordance with its policy regarding transfers of investments between categories (see Note 3), and due to the crisis in the Greek bond markets, transferred certain trading securities to available-for-sale securities and to held-to-maturity securities with fair value at the date of reclassification as presented in the following table:

Trading assets include securities that are pledged as collateral of EUR 1,564.5 million and EUR 927.3 million as at December 31, 2010 and 2011, respectively.

Derivative instruments that the Group may use as part of its interest rate risk management strategy include interest rate swaps, interest rate floors, interest rate caps, forward rate agreements, and options. Interest rate swap contracts are exchanges of interest payments, such as fixed-rate payments for floating-rate payments, based on a stated notional amount and maturity date. Interest rate floors protect against declining rates, while interest rate caps protect against rising interest rates. Forward rate agreements are contracts in which the buyer agrees to purchase, and the seller agrees to make delivery of, a specific financial instrument at a predetermined price or yield. Options provide the purchaser with the right, but not the obligation, to purchase or sell a contracted item during a specified period at an agreed upon price.

Foreign currency volatility occurs as the Group enters into transactions involving certain assets and liabilities denominated in foreign currencies, as well as a result of the Group's international operations, particularly of Finansbank in Turkey. Derivative instruments that the Group may use to economically hedge these foreign denominated assets and liabilities include foreign exchange swaps and outright foreign exchange forwards. The Group closely monitors its exposure to the Turkish lira arising from the net investment in Finansbank and when necessary it engages in foreign exchange swaps and other economic hedging transactions in order to reduce the volatility in the Group's equity arising on the translation of Finansbank's net assets from TL to euro.

The following tables present the contract or notional amounts and the fair value amounts (which include the maximum exposure to credit risk) at December 31, 2010 and 2011 of the Group's derivative asset and liability positions held for trading and economic hedging purposes. These derivative positions are primarily executed in the over-the-counter market. The amounts presented below do not consider the value of any collateral held.

	2010				2011

	As restated⁽²⁾
	Contract/ Notional amount		Fair Value		Contract/ Notional amount		Fair Value
	(EUR in thousands)				(EUR in thousands)
Cross currency interest rate swaps		3,454,366		181,275		6,736,338		792,046
Financial futures		3,335,302		3,252		346,708		8,142
Foreign exchange swaps		3,706,230		142,146		3,003,201		55,768
Forward rate agreements		70,070		1,334		69,865		608
Interest rate swaps		31,524,946		1,209,336		22,598,883		2,594,929
Options		3,431,994		87,433		4,794,160		114,378
Outright foreign exchange forwards		352,532		7,932		889,417		39,744
Credit Derivatives		—		—		7,803		65
Commodity swaps and other		22,041		1,562		1,293		285

Total		45,897,481		1,634,270		38,447,668		3,605,965

	2010				2011

	As restated⁽²⁾
	Contract/ Notional amount		Fair Value		Contract/ Notional amount		Fair Value
	(EUR in thousands)				(EUR in thousands)
Cross currency interest rate swaps		3,624,583		372,528		4,328,113		542,310
Financial futures		814,882		10,014		1,433,408		8,369
Foreign exchange swaps		2,257,001		86,943		1,643,232		27,359
Forward rate agreements		23,968		6,020		80,441		2,463
Interest rate swaps		22,884,544		1,202,172		26,376,089		3,580,272
Options		2,687,135		90,202		3,033,158		108,859
Outright foreign exchange forwards		402,030		12,668		1,422,942		47,114
Credit Derivatives		—		—		46,820		3,503
Commodity swaps and other		22,571		1,923		1,444		239

Total		32,716,714		1,782,470		38,365,647		4,320,488

Gains and losses on derivative instruments are presented within Net trading income/(loss) in the Statement of Income and Comprehensive Income and for the year ended December 31, 2009, 2010 and 2011 and are analyzed as follows:

The Group considers the impact of both the credit risk of its counterparties, as well as its own creditworthiness in determining fair value of financial instruments, including over-the-counter derivative instruments and financial liabilities designated at fair value in accordance with ASC 825. This impact is estimated by calculating a separate credit value adjustment ("CVA") for each counterparty to which the Group has exposure. The calculation considers expected exposures generated using simulation techniques, as well as netting agreements and collateral postings. Furthermore, the CVA is based on expected loss rates derived from Credit Default Swaps ("CDS") rates observed in the market. If these are not available then we apply the regulatory risk weight that corresponds to the internal rating of the counterparty, or to unrated counterparties, if no internal rating is available. With respect to own credit risk, the Group estimates a debit value adjustment ("DVA") by applying a methodology symmetric to the one applied for CVA. The bilateral CVA recognized by the Group at December 31, 2009, 2010 and 2011 amounted to a cumulative loss of EUR 97.1 million and EUR 92.0 million and a cumulative gain of EUR 158.7 million, respectively. The gain in 2011 is attributed mainly to the high DVA due to the Bank's increased CDS rate. The Group seeks to reduce counterparty risk by standardizing relationships with counterparties through International Swaps and Derivatives Association, Inc. ("ISDA") and Global Master Repurchase Agreement ("GMRA") contracts, which encompass all necessary netting and margining clauses. Additionally, for almost all active counterparties in over-the-counter transactions, apart from Hellenic Republic, Credit Support Annexes (CSAs) have been put into effect, so that net current exposures are managed through margin accounts on a daily basis, through the exchange of cash collateral.

A portion of the derivative activity involves exchange-traded instruments. Exchange-traded instruments conform to standard terms and are subject to policies set by the exchange involved, including counterparty approval, margin requirements and security deposit requirements. Management believes the credit risk associated with these types of instruments is minimal.

Substantially all of the Group's derivative contracts contain credit risk-related contingent features, primarily in the form of ISDA master agreements that enhance the creditworthiness of these instruments compared to other obligations of the respective counterparty with whom the Group has transacted. These contingent features may be for the benefit of the Group as well as its counterparties with respect to changes in the Group's creditworthiness. At December 31, 2010 and at December 31, 2011, the Group held cash and securities collateral of EUR 179.1 million and EUR 501.7 million and posted cash and securities collateral of EUR 1,189.8 million and EUR 2,178.3 million in the normal course of business under derivative agreements.

In connection with certain over-the-counter derivative contracts and other trading agreements, the Group could be required to terminate transactions with certain counterparties at their request since the Bank's credit rating as at December 31, 2011, has triggered this provision in the contract. In such an event, the amount that would be required to settle the position depends on the contract and is usually the market value of the exposure on that day less any amount that has already been posted as collateral under CSAs. Therefore, for derivatives subject to CSAs that are executed on a daily margin basis, the additional amount that would be required to settle the position is a two day change in the mark to market of the instrument which as of December 31, 2010 and 2011, amounted to EUR 38.7 and 27.0 million, respectively.

The disclosure information with respect to available-for-sale securities and held-to-maturity securities as of December 31, 2010 and for the years ended December 31, 2009 and 2010 has been restated to reflect the impact discussed in Note 43.

The amortized cost of available-for-sale securities and their fair values at December 31, comprised:

	2010

	As restated
	Amortized Cost		Gross Unrealized Gains		Gross Unrealized (Losses)			Fair Value
	(EUR in thousands)
Available-for-sale securities
Greek government bonds		9,581,861		—		(2,925,797	)		6,656,064
Debt securities issued by other governments and public sector entities		3,671,148		92,991		(3,433	)		3,760,706
Corporate debt securities issued by companies incorporated in Greece		1,093,095		3		(254,310	)		838,788
Corporate debt securities issued by companies incorporated outside Greece		1,414,465		66,649		(58,822	)		1,422,292
Equity securities issued by companies incorporated in Greece		145,444		1,535		(483	)		146,496
Equity securities issued by companies incorporated outside Greece		145,022		4,394		(2,918	)		146,498
Foreign treasury bills		220,121		2		(1,803	)		218,320
Mutual Fund units		510,566		6,296		(17,516	)		499,346

Total available-for-sale securities		16,781,722		171,870		(3,265,082	)		13,688,510

	2011

	Amortized Cost		Gross Unrealized Gains		Gross Unrealized (Losses)			Fair Value
	(EUR in thousands)
Available-for-sale securities
Greek government bonds		3,730,682		—		(33,304	)		3,697,378
Debt securities issued by other governments and public sector entities		3,154,367		7,840		(108,456	)		3,053,751
Corporate debt securities issued by companies incorporated in Greece		701,889		685		(242,048	)		460,526
Corporate debt securities issued by companies incorporated outside Greece		715,904		32,653		(93,675	)		654,882
Equity securities issued by companies incorporated in Greece		56,968		817		(165	)		57,620
Equity securities issued by companies incorporated outside Greece		42,107		6,121		(3,273	)		44,955
Foreign treasury bills		181,130		53		(733	)		180,450
Mutual Fund units		452,200		2,254		(32,292	)		422,162

Total available-for-sale securities		9,035,247		50,423		(513,946	)		8,571,724

The following table presents the fair value and the associated unrealized losses of available-for-sale securities in an unrealized loss position as at December 31, 2010. The table also discloses whether these securities have had unrealized losses for periods less than 12 months or for 12 months or longer.

	2010

	As restated
	Less than 12 months					12 months or longer					Total
	Fair Value		Unrealized Losses			Fair Value		Unrealized Losses			Fair Value		Unrealized Losses
	(EUR in thousands)
Available-for-sale securities
Greek government bonds		2,359,733		(688,778	)		3,944,167		(2,237,019	)		6,303,900		(2,925,797	)
Debt securities issued by other governments and public sector entities		149,404		(2,966	)		46,623		(467	)		196,027		(3,433	)
Corporate debt securities issued by companies incorporated in Greece		203,619		(12,047	)		632,081		(242,263	)		835,700		(254,310	)
Corporate debt securities issued by companies incorporated outside Greece		112,656		(4,294	)		417,257		(54,528	)		529,913		(58,822	)
Equity securities issued by companies incorporated in Greece		1,334		(453	)		127		(30	)		1,461		(483	)
Equity securities issued by companies incorporated outside Greece		14,829		(2,040	)		2,024		(878	)		16,853		(2,918	)
Foreign treasury bills		54,026		(1,803	)		—		—			54,026		(1,803	)
Mutual Fund units		248,259		(4,209	)		131,327		(13,307	)		379,586		(17,516	)

Total available-for-sale securities		3,143,860		(716,590	)		5,173,606		(2,548,492	)		8,317,466		(3,265,082	)

The following table presents the fair value and the associated unrealized losses of available-for-sale securities in an unrealized loss position as at December 31, 2011. The table also discloses whether these securities have had unrealized losses for periods less than 12 months or for 12 months or longer.

	December 31, 2011

	Less than 12 months					12 months or longer					Total
	Fair Value		Unrealized Losses			Fair Value		Unrealized Losses			Fair Value		Unrealized Losses
	(EUR in thousands)
Available-for-sale securities in unrealized loss position
Greek government bonds		1,327,674		(33,304	)		—		—			1,327,674		(33,304	)
Debt securities issued by other governments and public sector entities		2,403,878		(91,797	)		60,037		(16,659	)		2,463,915		(108,456	)
Corporate debt securities issued by companies incorporated in Greece		17,900		(9,467	)		335,976		(232,581	)		353,876		(242,048	)
Corporate debt securities issued by companies incorporated outside Greece		137,609		(16,698	)		216,391		(76,977	)		354,000		(93,675	)
Equity securities issued by companies incorporated in Greece		506		(165	)		—		—			506		(165	)
Equity securities issued by companies incorporated outside Greece		3,274		(3,063	)		1,121		(210	)		4,395		(3,273	)
Foreign treasury bills		29,322		(733	)		—		—			29,322		(733	)
Mutual Fund units		231,391		(23,362	)		74,011		(8,930	)		305,402		(32,292	)

Total available-for-sale securities		4,151,554		(178,589	)		687,536		(335,357	)		4,839,090		(513,946	)

The scheduled maturities of available-for-sale securities at December 31, 2010 and 2011 were as follows:

During 2010, the Group, in accordance with its policy regarding transfers of investments between categories (see Note 3), and due to the current crisis in the Greek bond markets, transferred certain trading securities with fair value at the date of the reclassification EUR 200.4 million to available-for-sale and certain available-for-sale securities with fair value at the date of the reclassification EUR 1,912.6 million into held-to-maturity because it now intends to hold these bonds until maturity.

Available for sale securities include securities that are pledged as collateral of EUR 6,483.0 million and EUR 4,923.7 million as at December 31, 2010 and 2011, respectively.

The following table presents the net gains/(losses) on available-for-sale and held-to-maturity securities for 2009, 2010 and 2011.

	2009			2010

	As restated			As restated
	(EUR in thousands)
Gross realized gains on sales of available for sale securities
Greek government bonds		222,052			3,138		83,573
Debt securities issued by other governments and public sector entities		125,462			177,592		21,607
Corporate debt securities		19,041			4,666		13,108
Equity securities		12,924			4,388		1,716
Mutual Fund units		18,670			8,226		11,832

Total gross realized gains on sales of available for sale securities		398,149			198,010		131,836

Gross realized losses on sales of available for sale securities
Greek government bonds		(16,153	)		(68,507	)	(142,205	)
Debt securities issued by other governments and public sector entities		(3,439	)		(12,387	)	(7,410	)
Corporate debt securities		(20,512	)		(2,143	)	(316	)
Equity securities		(7,738	)		—		(1,284	)
Mutual Fund units		(378	)		(14	)	(87	)

Total gross realized losses on sales of available for sale securities		(48,220	)		(83,051	)	(151,302	)

Net realized gains / (losses) on sales of available for sale securities		349,929			114,959		(19,466	)

Other-Than-Temporary-Impairment
OTTI of Greek government bonds due to Private Sector Involvement		—			—		(8,770,914	)
Corporate debt securities		(151,474	)		—		(142,973	)
Equity securities		(187,142	)		(85,198	)	(223,366	)
Mutual Fund units		(19,712	)		(4,299	)	(36,460	)

Total Other-Than-Temporary-Impairment		(358,328	)		(89,497	)	(9,173,713	)

Net gains / (losses) on available for sale and held to maturity securities		(8,399	)		25,462		(9,193,179	)

The amortized cost of held-to-maturity securities and their approximate fair values at December 31, comprised:

The following table presents the fair value and the associated unrecognized losses of held-to-maturity securities in an unrecognized loss position as at December 31, 2011. The table also discloses whether these securities have had unrecognized losses for periods less than 12 months or for 12 months or longer.

The scheduled maturities of held-to-maturity securities at December 31, 2010 and 2011 were as follows:

During 2010, the Group, in accordance with its policy regarding transfers of investments between categories (Note 3), and due to the current crisis in the Greek bond markets, transferred certain Greek government bonds from trading and available-for-sale into held-to-maturity because it now intends to hold these bonds until maturity. The fair value of these bonds at the date of transfer was EUR 2,176.4 million and became the new amortized cost at that date. The transfers did not affect the length of the period that these securities are in an unrealized loss position. Excluded from the unrecognized losses presented in the table above, as at December 31, 2011 are EUR 16.7 million

unrealized losses, which relate to the unamortized balance of the unrealized losses (before tax) that have been recorded in OCI prior to the reclassification (2010: EUR 171.0 million). These losses relate to securities that have been in an unrealized loss position for 12 months or longer (2010: EUR 169.1 million).

Held to maturity securities include securities that are pledged as collateral of EUR 1,963.5 million and EUR 780.0 million as at December 31, 2010 and 2011, respectively.

Other-Than-Temporary-Impairment assessment of available-for-sale and held-to-maturity securities

The assessment for Other-Than-Temporary-Impairment ("OTTI") of available-for-sale and held-to-maturity debt securities and available-for-sale marketable equity securities and mutual fund units is based on a variety of factors, including the length of time and extent to which the market value has been less than cost, the financial condition of the issuer of the security, and our intent and ability to hold the security to recovery. For debt securities, the evaluation is based upon factors such as the creditworthiness of the issuers and/or guarantors, the underlying collateral, if applicable, and the continuing performance of the securities. Regarding equity securities and mutual fund units, as part of our impairment analysis, we frequently update our expectations based on actual historical evidence that recovery has not yet occurred. Specifically, when unrealized losses persist, we obtain greater and more detailed objective evidence regarding the future earnings potential and the underlying business economics of the issuers and the share price trend.

The assessment of impairment for the eligible Greek government bonds as at December 31, 2011 has been performed based on the provisions of ASC 310-20—Investments in Debt and Equity Securities indicating that if the fair value of an investment is less than its amortized cost basis at the balance sheet date of the reporting period for which impairment is assessed, the impairment is either temporary or other than temporary. The Group assessed whether its investment in the eligible Greek government bonds is impaired by comparing the fair value with the amortized cost of these debt instruments. This comparison has indicated that all eligible Greek government bonds are impaired and consequently the Group assessed whether the impairment is other than temporary.

At the European Summit on October 26, 2011, the Heads of States of Eurozone agreed on a comprehensive set of measures, including a voluntary bond exchange with a nominal discount of 50% on notional Greek debt held by private investors. Together with an ambitious reform program for the Greek economy, supporting growth, the PSI is expected to secure the reduction of the Greek debt to GDP ratio to 120% by 2020.

On February 24, 2012, the Hellenic Republic Ministry of Finance (the "MiFin") published the invitation memoranda (the "Memoranda") whereby it invited the holders of the Greek government bonds that were eligible for the PSI (the "eligible Greek government bonds") to offer to exchange their eligible Greek government bonds subject to the terms described in the Memoranda (the "Offer").

The Group participated in the Offer under the terms of the Memoranda. The exchange of the Greek government bonds that were subject to Greek law took place on March 12, 2012, while the exchange of Greek government bonds subject to foreign law and the loans that were included in the PSI (see Note 13) took place in April 2012.

The Offer was considered an adjusting event after the reporting period in relation to the annual financial statements for the year ended December 31, 2011, because it provided evidence of conditions

that existed at the end of the reporting period, and therefore, the Group estimated the fair value at December 31, 2011 based on the contractual cash flows of the new Greek government bonds, a discount rate of 12% and appropriate market information.

The discount rate was based on the new fundamentals regarding the Hellenic Republic debt (the successful implementation of the PSI, together with the financial assistance under the Program agreed by the Eurozone members and IMF, which is expected to improve Hellenic Republic's debt sustainability aiming at the reduction of the Hellenic Republic debt to GDP ratio to 120% by 2020, the new reform effort and the escrow account arranged for the new PSI bonds that raises their seniority). Specifically, to arrive at this estimate, we have considered the yields of similarly rated sovereign and corporate entities, and we have analyzed the relationship of credit ratings and public debt with the bond yields for other European countries.

At December 31, 2011 Greek government bonds held by the Group that were not eligible for exchange comprised of:

likely than not to be required to sell them before the recovery of their amortized cost basis. Furthermore, the Group expects to recover the entire amortized cost basis of these bonds, because there is no evidence at the date these financial statements were authorized that there is a loss event that has an impact on the estimated future cash flows associated with these bonds, hence that the future cash flows will not be recovered in accordance with the contractual terms. Accordingly the unrealized losses of these bonds are included within AOCI.

In particular for the bond received in settlement of the Redeemable Preference Shares issued to the Greek State (see (a) above), the Bank also considered that this transaction formed an integral part of the public policy of the Official Sector to support the regulatory capital of the Greek banks in an effort to sustain the systemic stability of the financial sector in Greece. The Hellenic Republic would not benefit from defaulting on this bond since such action would not result to any reduction of the public debt, merely would be more than offset by the increased capitalization needs of the Greek banks and would therefore increase the Greek public debt. This result would have been in clear contradiction to the basic aim of the new Program for economic support for Greece, which was approved by the heads of state of the eurozone states and is supervised by the IMF, the ECB and the EU. Additionally, subject to obtaining Bank of Greece and other statutory approvals for the repurchase of the Redeemable Preference shares of a nominal value of EUR 1,350.0 million, the Bank could elect to exchange this bond at its maturity in May 2014 with the Redeemable Preference shares.

For the bond issued by TANEO (see (b) above), the Group also considered that the fair value of the company's investments and the cash and cash equivalents held by TANEO exceeds the total

outstanding bond issue and therefore the probability of TANEO defaulting on the bonds it has issued is very small.

Finally, it is expected that the successful implementation of the PSI together with the financial assistance under the Program agreed by the eurozone members and the IMF will improve Greece's debt sustainability aiming at the reduction of the Greek debt to GDP ratio to 120% by 2020 (see above). This conclusion is also supported by the statements issued by the Euro summit and the EU Heads of State or Government on October 26, 2011, the Eurogroup statement on February 21, 2012, the press release of the Institute of International Finance (the "IIF") on March 3, 2012 and the statement by the IMF managing director on March 9, 2012.

During 2009 the Group recognized OTTI charges in relation to certain debt securities that the Group intended to sell, in accordance with ASC 320-10-35-33A, and in relation to the majority of its equity securities and mutual fund units held with significant and prolonged unrealized losses, in accordance with ASC 320-10-35-33.

As at December 31, 2009, gross unrealized losses existing for twelve months or more for equity securities relate to minor investments. For the majority of these investments the unrealized loss is less than 20% and for the remaining it is marginally above 20%. All mutual fund units with unrealized losses existing for twelve months or more have losses of less than 20%.

During 2010 the Group recognized OTTI charges in relation to the majority of its equity securities and mutual fund units held with significant and prolonged unrealized losses. In particular, the Group recognized an OTTI charge for all equity securities and mutual fund units for which an OTTI charge was recognized in previous years and as at December 31, 2010 were in an unrealized loss position.

As at December 31, 2010, gross unrealized losses existing for twelve months or more for equity securities are not material and all mutual fund units with unrealized losses existing for twelve months or more were not considered impaired as the losses were not significant to the respective investments held.

Other than the OTTI charges recognized for the Greek government bonds due to the PSI, as discussed above, the Group recognized OTTI charges in relation to certain corporate debt securities issued by Greek financial institutions in an unrealized loss position because, as at December 31, 2011, the Group considered that a credit loss existed with respect to these securities.

During 2011 the Group recognized OTTI charges in relation to the majority of its equity securities and mutual fund units held with significant and prolonged unrealized losses. In particular, the Group recognized OTTI charges for all equity securities and mutual fund units for which an OTTI was recognized in previous periods and, as at December 31, 2011, were in an unrealized loss position. As at December 31, 2011, gross unrealized losses existing for twelve months or more for equity securities are

not material and all mutual fund units with unrealized losses existing for twelve months or more were not considered impaired as the losses were not significant to the respective investments held.

For other debt securities issued by Greek financial institutions no OTTI has been recognized based on management's assessment that the Group neither has the intention to sell nor expects it will be required to sell these securities before the recovery of their respective amortized cost bases, and that the issuers' payment obligations associated with these positions will be met on time and the full amount will be recovered. A key factor considered in this assessment was the existence of the recapitalization plan for the Greek banks (see Note 3).

The Group has investments that are accounted for using the equity method of accounting. The summarized financial information below represents an aggregation of the Group's non-subsidiary investees.

	2009

	(EUR in thousands)
Equity method investments		25,327		50,094	59,139
Revenue		258,841		127,630	77,406
Gross profit		(19,054	)	40,056	29,804
Net earnings		(128,247	)	12,510	6,774
Group's equity in net earnings		(18,550	)	9,245	8,661
Dividends received by the Group		389		1,541	2,785
Balance Sheet data as at December 31
Current assets		177,876		79,766	91,871
Non-current assets		696,071		486,486	511,932
Current liabilities		235,615		28,696	30,077
Non-current liabilities		642,407		461,376	488,387
Net assets		(4,075	)	76,180	85,339
Group's equity in net assets		23,136		47,695	38,974

The increase in equity method investments during 2010 and 2011 mainly relates to investments made by our private equity funds.

On December 31, 2011, the Group recognized EUR 1.7 million impairment loss for its investment in Planet S.A.

On September 15, 2009, the Group disposed of its investment in Phosphoric Fertilizers Industry S.A. The loss realized upon disposal amounted to EUR 10.0 million.

On July 10, 2009 the Bank disposed of half of its participation in Social Securities Funds Management S.A. reducing its participation from 40% to 20%. The consideration agreed, amounted to EUR 1.3 million. The gain realized upon disposal of 20% amounted to EUR 0.6 million.

Loans granted by the Group according to type of loan, which represents the Group's concentration of credit risk, at December 31, 2010 and 2011 comprised:

	2010									2011

	Greek residents			Foreign			Total			Greek residents			Foreign			Total
	(EUR in thousands)
Consumer:
Residential mortgages		19,544,275			4,725,702			24,269,977			18,762,689			4,148,062			22,910,751
Credit card		1,773,156			3,503,593			5,276,749			1,527,119			3,763,261			5,290,380
Auto financing		405,734			205,996			611,730			308,598			144,085			452,683
Other consumer		4,852,444			3,084,471			7,936,915			4,763,063			2,990,411			7,753,474

Total consumer		26,575,609			11,519,762			38,095,371			25,361,469			11,045,819			36,407,288

Commercial:
Industry and mining		3,675,468			2,974,037			6,649,505			4,084,213			3,020,134			7,104,347
Small scale industry		2,090,239			1,449,556			3,539,795			1,962,344			1,295,509			3,257,853
Trade		7,788,532			3,784,789			11,573,321			7,374,620			3,600,619			10,975,239
Construction		1,226,936			1,597,771			2,824,707			1,131,868			1,629,284			2,761,152
Tourism		484,394			396,622			881,016			479,955			279,303			759,258
Shipping and transportation		2,152,631			780,670			2,933,301			2,216,777			799,940			3,016,717
Commercial mortgages		880,697			700,715			1,581,412			774,709			647,331			1,422,040
Public sector		8,860,862			392,521			9,253,383			8,711,152			280,712			8,991,864
Other		247,319			1,707,828			1,955,147			88,376			1,479,101			1,567,477

Total commercial		27,407,078			13,784,509			41,191,587			26,824,014			13,031,933			39,855,947

Total loans		53,982,687			25,304,271			79,286,958			52,185,483			24,077,752			76,263,235
Unearned income		(58,824	)		(189,694	)		(248,518	)		(92,749	)		(167,629	)		(260,378	)

Loans, net of unearned income		53,923,863			25,114,577			79,038,440			52,092,734			23,910,123			76,002,857
Less: Allowance for loan losses		(2,122,803	)		(1,052,602	)		(3,175,405	)		(5,433,828	)		(1,116,807	)		(6,550,635	)

Total Net Loans		51,801,060			24,061,975			75,863,035			46,658,906			22,793,316			69,452,222

Included in the above table for 2010 and 2011 are loans that are economically hedged for interest rate risk, for which the Group elected the fair value option. The fair value and outstanding principal balance of these loans at December 31, 2011 was EUR 277,247 thousand and EUR 266,258 thousand respectively (2010: EUR 559,107 thousand and EUR 517,210 thousand respectively). Net gains/(losses) resulting from changes in the fair value of these loans of EUR (9,947) thousand and EUR (25,757) thousand in 2010 and 2011 respectively were recorded in net interest income before provision for loan losses.

Also, included in the above tables are loans for lease financing amounting to EUR 1,847,008 thousand and EUR 1,634,225 thousand in 2010 and 2011 respectively.

The Group actively monitors the credit quality of its loan portfolio using several credit quality indicators. The credit quality indicators considered to be the most significant are the delinquency status for all loans, and the credit rating for commercial loans. The days past due is the credit quality indicator the most relevant to the loans in our consumer loans portfolio. In accordance with our policies, the number of days past due is the key factor the Group considers when determining the appropriate course of action. For instance, the actions to pursue collection increase as the number of days past due increases. Furthermore, days past due is also a key factor considered in determining the loans that are eligible for our restructuring programs.

The following tables provide details of delinquent and non-accruing loans by loan class at December 31, 2010 and 2011:

	December 31, 2010

													Of which:
	Past due 31-89 days		Past due greater than 90 days		Total Past due loans		Current loans⁽¹⁾		Loans measured at Fair value		Total		+90 days and accruing loans		Non accruing loans
	(EUR in thousands)
Greek
Residential mortgages		932,421		1,804,213		2,736,634		16,807,641		—		19,544,275		582,407		1,221,806
Credit card		106,041		490,398		596,439		1,176,717		—		1,773,156		46,866		443,532
Other consumer		286,487		1,145,713		1,432,200		3,825,978		—		5,258,178		36,534		1,109,179
Small business loans		197,777		745,299		943,076		3,279,205		—		4,222,281		23,482		721,817
Other commercial loans		281,222		893,968		1,175,190		22,009,607		—		23,184,797		41,997		851,971

Total Greek loans		1,803,948		5,079,591		6,883,539		47,099,148		—		53,982,687		731,286		4,348,305

Foreign
Residential mortgages		204,578		158,984		363,562		3,811,916		550,224		4,725,702		97		158,887
Credit card		77,014		327,366		404,380		3,099,213		—		3,503,593		—		327,366
Other consumer		140,375		351,502		491,877		2,798,590		—		3,290,467		780		350,722
Small business loans		150,102		403,044		553,146		1,168,265		—		1,721,411		67,684		335,360
Other commercial loans		494,221		1,104,962		1,599,183		10,455,032		8,883		12,063,098		200,315		904,646

Total Foreign loans		1,066,290		2,345,858		3,412,148		21,333,016		559,107		25,304,271		268,876		2,076,981

Total loans		2,870,238		7,425,449		10,295,687		68,432,164		559,107		79,286,958		1,000,162		6,425,286

	December 31, 2011

													Of which:
	Past due 31-89 days		Past due greater than 90 days		Total Past due loans		Current loans⁽¹⁾		Loans measured at Fair value		Total		+90 days and accruing loans		Non accruing loans
	(EUR in thousands)
Greek
Residential mortgages		1,180,533		2,629,140		3,809,673		14,953,016		—		18,762,689		591,445		2,798,058
Credit card		64,609		540,059		604,668		922,451		—		1,527,119		22,561		517,498
Other consumer		326,768		1,669,764		1,996,532		3,075,129		—		5,071,661		71,133		1,994,051
Small business loans		213,343		1,094,178		1,307,521		2,562,702		—		3,870,223		15,488		1,477,372
Other commercial loans		285,165		1,753,830		2,038,995		20,914,796		—		22,953,791		69,278		1,936,790

Total Greek loans		2,070,418		7,686,971		9,757,389		42,428,094		—		52,185,483		769,905		8,723,769

Foreign
Residential mortgages		203,456		177,586		381,042		3,492,116		274,904		4,148,062		174		248,797
Credit card		116,981		341,014		457,995		3,305,266		—		3,763,261		—		360,289
Other consumer		169,789		398,985		568,774		2,565,722		—		3,134,496		253		505,627
Small business loans		98,124		511,061		609,185		1,648,877		—		2,258,062		677		582,707
Other commercial loans		339,631		984,436		1,324,067		9,447,461		2,343		10,773,871		155,977		1,045,752

Total Foreign loans		927,981		2,413,082		3,341,063		20,459,442		277,247		24,077,752		157,081		2,743,172

Total loans		2,998,399		10,100,053		13,098,452		62,887,536		277,247		76,263,235		926,986		11,466,941

According to the Group's credit policy, all corporate customers are rated on a 22-grade scale. This rating is based on quantitative and qualitative criteria and is reviewed at least annually. Additionally, each of the Bank's and its subsidiaries' rating systems consider the borrower's industry risk and its relative position within its peer group. Small business loans are rated through a behavioral model on a 14-grade scale. The ratings scale for corporate and small business customers corresponds to likelihood of default. Customers classified as "Satisfactory" have low likelihood of default, customers classified as "Watchlist" have medium to high likelihood of default and customers classified as Substandard are already defaulted.

The following table presents commercial loans credit quality information as at December 31, 2010 and 2011:

	December 31, 2010						December 31, 2011

	Small business loans		Other commercial loans		Total commercial loans		Small business loans		Other commercial loans		Total commercial loans
	(EUR in thousands)						(EUR in thousands)
Greek
Satisfactory		1,317,834		20,428,464		21,746,298		906,577		11,283,505		12,190,082
Watchlist		1,889,368		2,021,343		3,910,711		1,528,817		9,486,380		11,015,197
Substandard		1,015,079		734,990		1,750,069		1,434,829		2,183,906		3,618,735

		4,222,281		23,184,797		27,407,078		3,870,223		22,953,791		26,824,014

Foreign
Satisfactory		1,121,790		10,529,810		11,651,600		1,156,800		9,800,548		10,957,348
Watchlist		192,343		819,501		1,011,844		687,173		769,048		1,456,221
Substandard		407,278		713,787		1,121,065		414,089		204,275		618,364

		1,721,411		12,063,098		13,784,509		2,258,062		10,773,871		13,031,933

Total		5,943,692		35,247,895		41,191,587		6,128,285		33,727,662		39,855,947

The increase in Greek watchlisted loans also includes EUR 6,939.8 million, which relates to the Greek State and loans exchanged in the PSI.

Impaired loans are those loans where the Group believes it is probable that it will not collect all amounts due according to the original contractual terms of the loan. Impaired loans include loans whose terms have been modified in troubled debt restructuring due to borrower's financial difficulties and to which the Group has granted a concession to the borrower.

The following table presents information about total impaired loans at and for the period ending December 31, 2010 and 2011:

	At and for the year ended December 31, 2010

	Total recorded balance		Related allowance			Average recorded balance		Interest income recognized during the period the loan was impaired		Interest income recognized on a cash basis
	(EUR in thousands)
Greek
With no related allowance:
Other commercial loans		39,691		—			40,342		—		—
With related allowance:
Residential mortgages		1,733,171		(201,261	)		1,251,762		3,623		3,857
Credit cards		490,513		(318,815	)		423,935		9,594		46
Other consumer loans		1,413,059		(564,400	)		983,960		9,914		9,117
Small business loans		1,060,754		(362,827	)		745,503		4,960		67
Other Commercial loans		893,384		(572,631	)		758,007		10,982		10,982

Total Greek impaired loans		5,630,572		(2,019,934	)		4,203,509		39,073		24,069

Foreign
With no related allowance:
Residential mortgages		58		—			58		—		—
Other consumer loans		172		—			87		—		—
Small business loans		175,366		—			146,531		17,616		—
Other Commercial loans		195,032		—			188,933		16,562		—
With related allowance:
Residential mortgages		122,052		(39,052	)		106,753		8		586
Credit cards		318,868		(211,212	)		288,394		—		15,344
Other consumer loans		305,615		(189,702	)		279,818		4,536		15,853
Small business loans		373,159		(101,364	)		216,889		6,367		39
Other Commercial loans		1,265,081		(367,743	)		1,164,736		32,353		30,851

Total Foreign impaired loans		2,755,403		(909,073	)		2,392,199		77,442		62,673

	At and for the year ended December 31, 2011

	Total recorded balance		Related allowance			Average recorded balance		Interest income recognized during the period the loan was impaired		Interest income recognized on a cash basis
	(EUR in thousands)
Greek
With no related allowance:
Residential mortgages		20,749		—			20,469		—		—
Other consumer loans		35,760		—			34,810		1,899		—
Small business loans		2,770		—			—		—		—
Other commercial loans		300,323		—			107,137		2,344		—
With related allowance:
Residential mortgages		2,798,057		(464,239	)		2,264,525		—		20,433
Credit cards		540,059		(398,737	)		511,309		5,251		40
Other consumer loans		1,994,087		(983,433	)		1,709,580		3,447		17,347
Small business loans		1,493,055		(555,348	)		1,250,425		2,247		68
Other Commercial loans		9,366,605		(2,886,287	)		3,046,392		30,264		5,529

Total Greek impaired loans		16,551,465		(5,288,044	)		8,944,647		45,452		43,417

Foreign
With no related allowance:
Residential mortgages		299		—			—		—		—
Other consumer loans		208		—			14		—		—
Small business loans		3,866		—			479		—		—
Other Commercial loans		92,174		—			54,508		—		113
With related allowance:
Residential mortgages		234,935		(50,065	)		199,139		7,378		810
Credit cards		354,851		(243,331	)		322,110		5		18,329
Other consumer loans		502,651		(283,580	)		444,415		12,408		17,824
Small business loans		609,818		(170,255	)		551,683		20,032		337
Other Commercial loans		1,591,724		(330,580	)		1,318,137		65,680		26,756

Total Foreign impaired loans		3,390,526		(1,077,811	)		2,890,485		105,503		64,169

The increase in Greek impaired loans also includes EUR 6,939.8 million, which relates to the Greek State and loans exchanged in the PSI.

The following table presents the roll-forward of impaired loans for the years ended December 31, 2010 and 2011:

The increase in new impaired loans also includes EUR 6,939.8 million, which relates to the Greek State and loans exchanged in the PSI.

An analysis of the change in the allowance for loan losses for the years ended December 31, follows:

	2009			2010									2011

	Total			Consumer			Commercial			Total			Consumer			Commercial			Total
	(EUR in thousands)
Balance at beginning of year		1,232,626			1,004,147			1,061,031			2,065,178			1,677,340			1,498,065			3,175,405
Provision for loan losses		998,448			711,805			493,190			1,204,995			999,000			1,384,529			2,383,529
Provision for loans eligible to PSI⁽¹⁾		—			—			—			—			—			1,319,740			1,319,740
Write-offs		(196,312	)		(53,743	)		(86,628	)		(140,371	)		(85,451	)		(84,061	)		(169,512	)
Recoveries		29,663			11,078			12,171			23,249			23,635			7,565			31,200

Net Write-offs		(166,649	)		(42,665	)		(74,457	)		(117,122	)		(61,816	)		(76,496	)		(138,312	)
Sale of impaired loans		—			—			—			—			—			(107,244	)		(107,244	)
Translation differences		753			4,053			18,301			22,354			(53,496	)		(28,987	)		(82,483	)

Allowance at end of year		2,065,178			1,677,340			1,498,065			3,175,405			2,561,028			3,989,607			6,550,635

In addition to loans eligible to PSI, the Group has granted a loan to the Greek State, loans to Greek public sector entities, which are guaranteed by the Greek State and loans to corporate and individuals guaranteed by the Greek State at December 31, 2011.

The Group has conducted impairment assessment individually or collectively, for all its exposures related to the Greek State. Allowances for loan losses have been accounted where deemed appropriate.

Total exposure to the Greek State and its related allowance at December 31, 2011, are the following:

The following table provides the allowance for credit losses by portfolio segment and the respective recorded investment at December 31, 2010.

	Consumer loans

	(EUR in thousands)
Greek
Allowance for loan losses at year end		1,157,423	965,380	2,122,803
of which:
for impaired loans		1,084,476	935,458	2,019,934
for non-impaired loans		72,947	29,922	102,869
Impaired loans		3,636,743	1,993,829	5,630,572
Non-impaired loans		22,938,866	25,413,249	48,352,115
Foreign
Allowance for loan losses at year end		519,917	532,685	1,052,602
of which:
for impaired loans		439,966	469,107	909,073
for non-impaired loans		79,951	63,578	143,529
Impaired loans		746,765	2,008,638	2,755,403
Non-impaired loans		10,222,773	11,766,988	21,989,761

The following table provides the allowance for loan losses by portfolio segment and the respective recorded investment at December 31, 2011.

	Consumer loans

	(EUR in thousands)
Greek
Allowance for loan losses at year end		1,954,921	3,478,907	5,433,828
of which:
for impaired loans		1,846,409	3,441,635	5,288,044
for non-impaired loans		108,512	37,272	145,784
Impaired loans		5,388,712	11,162,753	16,551,465
Non-impaired loans		19,972,757	15,661,261	35,634,018
Foreign
Allowance for loan losses at year end		606,107	510,700	1,116,807
of which:
for impaired loans		576,975	500,836	1,077,811
for non-impaired loans		29,132	9,864	38,996
Impaired loans		1,092,944	2,297,582	3,390,526
Non-impaired loans		9,677,971	10,732,008	20,409,979

As discussed in Note 3 our methodology for estimating the allowance for loan losses has three primary components, specific allowances, coefficient analysis and homogeneous analysis, while the methodologies applied by our foreign subsidiaries and branches are similar to those employed by the Group for loans in Greece.

Loss forecast models utilized for portfolios of homogeneous loans consider a variety of factors including, but not limited to, historical loss experience, anticipated defaults or foreclosures based on portfolio trends, delinquencies and credit scores, and expected loss factors by loan type. In addition, in calculating our homogeneous allowances for loan losses we consider the current economic conditions and trends and changes in lending policies and procedures. The current macroeconomic conditions affect our default and recovery models gradually as more information regarding the performance and behavior of loan customers is gathered. Based on this information we adjust the "Loss-given-default" and "Probability of Default" parameters used for the estimation of allowance for loan losses, keeping the fundamental methodology intact, that is, we continue to calculate recoveries (and losses) based on realized cash inflows ("workout approach").

As at December 31, 2011, we did not believe an adjustment to historical loss experience for changes in trends, conditions, and other relevant factors that affect repayment of the loans was necessary beyond the incorporation of current information in the data used to estimate the

homogeneous allowances. In calculating our homogeneous allowances for loan losses we considered the following key factors:

The higher volume and severity of past due and non-accruing loans in 2011 automatically fed into the calculation of the allowance for loan losses by: (a) increasing the underlying pools on which we calculate a significant portion of the total loss allowances, (b) adjusting the loss rates by incorporating the most recent available information and (c) adjusting upwards the probability of default, which is estimated using data from the previous twelve months. The worsening of the quality of our loan portfolio in terms of delinquencies was the primary cause of the significant increase in of the allowance for loan losses based on homogeneous analysis.

As at December 31, 2011, we concluded that the incorporation of the current market conditions at that time in our methodology as described above was sufficient to estimate the allowance for probable loan losses as at December 31, 2011 and therefore did not further adjust historical loss experience.

We believe that changes in national, regional and local economic business conditions impact repayment of loans. Specifically, at December 31, 2011, there was deterioration in Greek economic conditions as a result of the recession of the Greek economy and the adverse developments regarding the Greek public debt and fiscal deficit. That deterioration in economic conditions was reflected in our allowance for loan losses estimated as of December 31, 2011, in three ways: firstly, it resulted in an increase in the level of past due and non-accruing loans which affected the provisions as described above, secondly, it increased the probability of default in our assessment for incurred but not identified impairment in homogeneous loans and thirdly the decline in real estate prices was incorporated in our analysis, where applicable.

Therefore, as at December 31, 2011, we concluded that no further adjustment to the historical loss rates was necessary due to the current economic conditions, since the loss rates applied are long term averages based on long recovery periods for all portfolios assessed using the homogeneous analysis.

In response to the higher volume and severity of past due loans, we reviewed and tightened our credit approval criteria during 2010 and 2011, for example by lowering both the loan-to-value and the payment-to-income acceptable ratios. As a result, we expected that the quality of new loans granted after 2009 will be improved. However, the loans originated during 2010 and 2011 were not significant enough to cause a change in observed probabilities of default or loss given defaults. Accordingly, we did not adjust those variables as at December 31, 2011.

The following tables set forth the allowances for loan losses by portfolio segment and by methodology and the respective recorded investment as at December 31, 2010 and December 31, 2011:

The increase of loans for which a specific allowance has been accounted for also includes EUR 6,939.8 million, which relates to the Greek State and loans exchanged in the PSI.

The most common practice we use to mitigate credit risk is the taking of security for funds advances. We implement guidelines on the acceptability of specific classes of collateral. The principal collateral types for loans and advances are:

Longer-term finance and lending to corporate entities are generally secured; revolving credit facilities to individuals are generally unsecured. In addition, in order to mitigate the potential credit loss the Group will seek additional collateral from the counterparty as soon as impairment indicators are noticed for the relevant individual loans and advances.

Impaired loans net of allowance for loan losses include collateral dependent loans of EUR 538,316 thousand and EUR 1,216,833 thousand at December 31, 2010 and December 31, 2011, respectively. In general, a loan is classified as collateral dependent when the loan agreement is terminated, foreclosure is probable and as a result the impairment is measured based on the fair value of the collateral. The time between the termination of the agreement and the loan being classified as collateral dependent may vary significantly because the timing of both actions is determined on a case by case basis. In Greece, the typical length of time between classification of the loan as collateral dependent and foreclosure is about 4 years, however there are a number of cases in which this period can be prolonged because either injunctions to the foreclosure procedure are raised by the customer or third parties, or the procedure has been postponed due to a settlement or repayment. In Turkey and South Eastern Europe enforcement of collateral or exhaustion of legal actions take significantly less time than in Greece.

The majority of these loans are secured with properties, for which foreclosure was probable and the impairment was measured based on the fair value of the collateral. These measurements are classified as Level 3 in the fair value hierarchy.

The fair value of the properties was estimated by qualified external or internal appraisers using one or more of the market approach, the income approach or the replacement cost approach. The key inputs, upon which these estimates are based, are market prices of similar properties, market yields and cost estimates. According to the Group impairment methodology, corporate business units that are responsible for the impairment assessment have to ensure that in cases where cash flows are expected from collateral liquidation, collateral value has to be based on a recent (within the current year) independent appraisal from qualified appraiser, unless loan exposures are significantly lower than the collateral values.

Loans include securitized loans and loans used as collateral in the covered bonds programs as follows:

The Bank, through its VIEs, has the following securitized notes in issue as at December 31, 2011:

Issuer	Description	Type of collateral	Issue date	Maturity date			Interest rate

Revolver 2008—1 Plc⁽¹⁾	Secured Floating Rate Notes—Class A	Consumer loans and credit card accounts	December 12, 2008	September 2020	1,000.0	^(1),(2)	Paid monthly at a fixed rate of 2.6% per annum
Revolver 2008—1 Plc⁽¹⁾	Secured Floating Rate Notes—Class B	Consumer loans and credit card accounts	December 12, 2008	September 2020	268.9	⁽²⁾	Paid monthly at a fixed rate of 2.9% per annum
Titlos Plc	Floating Rate Asset Backed Notes	Receivables from Public sector	February 26, 2009	September 2039	5,100.0	⁽³⁾	Paid semi-annually at a rate of six-month Euribor plus 50 bps per annum
Spiti Plc	Asset Backed Floating Rate Notes—Class A	Residential mortgages	September 20, 2011	September 2058	1,500.0	⁽²⁾	Paid semi-annually at a rate of six-month Euribor plus a margin of 400 bps
Spiti Plc	Asset Backed Floating Rate Notes—Class B	Residential mortgages	September 20, 2011	September 2058	249.5	⁽²⁾	Paid semi-annually at a rate of six-month Euribor plus a margin of 700 bps
Autokinito Plc	Asset Backed Floating Rate Notes—Class A	Auto loans	September 23, 2011	September 2023	400.0	⁽²⁾	Paid semi-annually at a rate of six-month Euribor plus a margin of 200 bps
Autokinito Plc	Asset Backed Floating Rate Notes—Class B	Auto loans	September 23, 2011	September 2023	96.5	⁽²⁾	Paid semi-annually at a rate of six-month Euribor plus a margin of 350 bps
Agorazo Plc	Asset Backed Floating Rate Notes—Class A	Consumer loans	September 23, 2011	September 2033	1,250.0	⁽²⁾	Paid semi-annually at a rate of six month Euribor plus a margin of 300 bps
Agorazo Plc	Asset Backed Floating Rate Notes—Class B	Consumer loans	September 23, 2011	September 2033	412.8	⁽²⁾	Paid semi-annually at a rate of six-month Euribor plus a margin of 450 bps

With respect to all the above securitization transactions, the Bank has sold and assigned certain of its loans to VIEs. The VIEs have paid for the receivables acquired from the Bank with the proceeds from the issuance of the secured notes, which have been acquired by the Bank. Since the Bank has purchased and continuously owns all issued secured notes and, therefore, is the primary beneficiary of the above VIEs, we have not applied sales accounting at Group level for the above transactions. That is, in our consolidated financial statements, the loans are not derecognized and continue to be presented within "Loans" on our consolidated balance sheets. For the same reason we do not record a liability with respect to the notes issued or a servicing asset or liability.

Additionally, the following transaction was unwound with the loans being sold back to the transferor in exchange for the notes:

All of the above notes issued were not presented within "Long-term debt" and the loans were not derecognized as the Bank is the owner of the issued secured notes and primary beneficiary of the above VIEs.

Under the covered bond Programs I and II, the Bank has the following covered bond series in issue as at December 31, 2011:

Program	Series number	Type of collateral	Issue date	Maturity date		Interest rate

Program I⁽¹⁾	Third Series⁽³⁾	Residential mortgage loans	October 7, 2009	October 2016	1,500.0	Paid annually at a fixed coupon rate of 3.875%
Program II⁽²⁾	First Series⁽⁴⁾	Residential mortgage loans	June 24, 2010	June 2015 (with an additional ten-year extension option)	1,500.0	Paid quarterly at the ECB's refinancing rate plus a margin of 170 bps
Program II⁽²⁾	Second Series⁽⁴⁾	Residential mortgage loans	June 24, 2010	June 2017 (with an additional ten-year extension option)	1,500.0	Paid quarterly at the ECB's refinancing rate plus a margin of 200 bps
Program II⁽²⁾	Third Series⁽⁴⁾	Residential mortgage loans	June 24, 2010	June 2019 (with an additional ten-year extension option)	1,500.0	Paid quarterly at the ECB's refinancing rate plus a margin of 230 bps
Program II⁽²⁾	Fourth Series	Residential mortgage loans	November 25, 2010	November 2018 (with an additional ten-year extension option)	1,500.0	Paid quarterly at the ECB's refinancing rate plus a margin of 210 bps
Program II⁽²⁾	Fifth Series⁽⁵⁾	Residential mortgage loans	May 6, 2011	September 2013 (with an additional ten-year extension option)	1,500.0	Paid quarterly at the ECB's refinancing rate plus a margin of 230 bps
Program II⁽²⁾	Sixth Series	Residential mortgage loans	May 6, 2011	September 2014 (with an additional ten-year extension option)	1,300.0	Paid quarterly at the ECB's refinancing rate plus a margin of 250 bps

Other than the third Series of Program I, all the above issues have not been sold to investors, are held by the Bank and therefore are not presented within "Long-term debt" (see Note 24).

Information regarding covered bonds can be found at the Bank's website (www.nbg.gr) under "Investor Relations\Debt Investors".

Furthermore, the Bank, in 2010 and 2011, has cancelled the following issues under the covered bond Program I of EUR 10.0 billion:

The change in International relates to net additions in other private equity business activities of the Group as well as to negative foreign exchange differences amounting to EUR 6.1 million and EUR 18.6 million respectively. The increase in Turkish Operations is due to the positive foreign

exchange differences amounting to EUR 107.1 million. The Group recognized EUR 6.3 million impairment losses for goodwill relating to private equity investments.

The change in International relates to additions in other private equity business activities of the Group as well as to positive foreign exchange differences amounting to EUR 20.6 million and EUR 3.6 million respectively and to impairment of EUR 125.1 million mainly relating to Vojvodjanska Banka, Banca Romaneasca and NBG Leasing IFN. The decrease in Turkish Operations is due to the foreign exchange differences amounting to EUR 414.0 million. Finally the change in insurance relates to impairment of the total amount of goodwill relating to Ethniki Hellenic General Insurance S.A. ("EH") of EUR 236.7 million due to the continuing adverse developments in the Greek economy and the profound effect of the PSI on the subsidiary's equity. Finally, the Group wrote-off EUR 56.5 million of goodwill relating to certain other domestic operations.

The reporting units utilized for goodwill impairment tests are the business segments or one level below the business segments, based on the level at which discrete financial information is available and management regularly reviews the operating results of that unit. The reporting units where significant goodwill is allocated are the Turkish banking operations and the Serbian operations within the International banking segment. The goodwill relates to the acquisitions of Finansbank and Vojvodjanska Banka, respectively.

The result of the DDM is cross-checked with other valuation methods, such as book value and earnings market multiples. These multiples corroborate the result or the DDM.

Underlying assumptions to the valuation models are that the entities comprising these reporting units will remain subsidiaries of the Group, that the general macroeconomic and political conditions in the respective markets will remain stable, that economic activity will continue to grow in the medium term and that the reporting units will continue to be able to fund their operations. If any of these conditions changes in the future, it may reduce the value of the reporting units and cause an impairment charge with respect to the goodwill.

The methodology applied has not changed since the previous assessment; however, the estimated cash flows were updated to reflect the current management estimates and market conditions.

The fair value of Serbian operations, based on a 8.0% (2010: 8.0%) terminal growth rate and 13.5% (2010: 13.7%) pre tax discount rate, was less than the carrying amount by EUR 80.8 million (2010: greater by EUR 169.2 million). A 1% increase in the discount rate or a 1% decrease in the terminal growth rate would decrease the fair value by EUR 57.1 million (2010: EUR 95.1 million) and EUR 47.4 million (2010: EUR 77.8 million) respectively. In addition, a 5% decrease in the forecast pre-tax earnings would decrease the fair value by EUR 16.8 million (2010: EUR 29.7 million). Based on the results of step 1 of the impairment test for Serbian operations, we performed step 2 of the impairment test and concluded to recognize an impairment charge of EUR 100.0 million. Since the DDM is based on management's forecasts that are unobservable inputs, the measurement of the goodwill impairment charge relating Serbian operations is classified as a Level 3 fair value measurement.

The gross carrying amount and accumulated amortization relating to software and other intangibles at December 31 are presented below:

As at December 31, 2011, other intangibles include intangibles identified upon the acquisition of acquired entities and consist of core deposits of EUR 12,060 thousand (2010: EUR 18,990 thousand), customer relationships of EUR 37,049 thousand (2010: EUR 59,917 thousand), software of EUR 7,052 thousand (2010: EUR 9,264 thousand), all of which have finite lives and trade names of EUR 127,061 thousand (2010: EUR 148,185 thousand) and mutual funds contracts of

EUR 2,191 thousand (2010: EUR 2,587 thousand) which have indefinite lives. The estimated useful lives of core deposits and customer relationships are 6-11 years and software 11-14 years.

Amortization expense on software and other intangibles amounted to EUR 65,260 thousand, EUR 79,906 thousand and EUR 98,930 thousand in 2009, 2010 and 2011 respectively. The Group estimates that aggregate amortization expense for the five succeeding fiscal years will be EUR 81,214 thousand, EUR 60,375 thousand, EUR 35,429 thousand, EUR 23,660 thousand and EUR 16,276 thousand for years 2012 through 2016 respectively.

Certain Group premises and equipment are leased under various operating leases. Rental expense amounted to EUR 110,296 thousand, EUR 120,386 thousand and EUR 119,226 thousand for the years ended December 31, 2009, 2010 and 2011, respectively.

Future minimum rental commitments under non-cancellable operating leases are presented below. The Group did not enter into any material capital leases.

	2010

	As restated
	(EUR in thousands)
Insurance related assets		808,429	620,383
Deferred tax assets		1,087,276	259,092
Prepaid income taxes		191,821	282,275
Assets acquired through foreclosure proceedings		175,541	184,790
Brokerage auxiliary funds		10,378	10,156
Private equity: Investees Assets		87,289	127,150
Prepaid expenses		165,246	139,105
Advances to employees		27,037	17,826
Unlisted equity securities		94,222	101,070
Hellenic Deposit and Investment Guarantee Fund		227,078	288,090
Receivables from Greek State		204,282	361,204
Checks and credit card transactions under settlement		221,922	176,312
Securities transactions under settlement		16,082	9,177
Trade and other receivables		112,164	113,256
Other		363,853	544,924

Total		3,792,620	3,234,810

In accordance with article 6 of Greek Law 3714/2008, the amount of deposits guaranteed by the Hellenic Deposit and Investment Guarantee Fund (HDIGF) is EUR 100 thousand per client. Accordingly, the contributions paid by banks to HDIGF increased from 2008 onwards. The Greek Law 3746/2009 concerning HDIGF provides that the excess of annual contributions calculated in accordance with the above article 6 of Greek Law 3714/2008, are included in a special reserve which will be jointly owned by the credit institutions in proportion to their participation.

In accordance with article 10 of Greek Law 3746/2009, HDIGF guarantees up to an amount of EUR 30 thousand per client for investing activities. In 2010, the participating credit institutions paid the first contributions relating to article 10 of Greek Law 3746/2009 which provides that the said contributions are included in a special reserve which will be jointly owned by the credit institutions in proportion to their participation.

On January 22, 2009, an Extraordinary General Meeting of the Bank's Shareholders was held, which approved the issue of 70 million redeemable preference shares at a par value of EUR 5.00 each with the cancellation of the pre-emptive rights of the existing shareholders in favor of the Greek State in accordance with Greek Law 3723/2008 for the Bank's participation in the part (1) of the Hellenic Republic Bank Support Plan. On May 21, 2009, the Bank's Board of Directors certified that the Greek State fully covered the said issue of preferred shares. This increase was covered through the transfer to

the Bank of an equal market value Greek government bond with a coupon rate of six-month Euribor plus 130 basis points. On May 25, 2009, the Board of Directors' minutes for the above mentioned certification were filed with the Ministry of Development (resolution K2-5300/Registrar of Companies). Following the above the Bank's share capital increased by EUR 350 million.

On December 22, 2011, the Extraordinary General Meeting of the Bank's Shareholders approved a) the share capital increase by EUR 1,000.0 million through the issue of additional 200 million Redeemable Preference Shares at a nominal value of EUR 5.00 each with the cancellation of the pre-emptive rights of the existing shareholders in favor of the Greek State, in accordance with the Law 3723/2008 and b) the revocation of the decision of the Extraordinary General Meeting of the Bank's Shareholders held on November 26, 2010 regarding the repurchase by the Bank of the 70 million Redeemable Preference Shares in favor of the Greek State, in accordance with the Law 3723/2008.

On December 30, 2011, following the above decision, the Bank issued the 200 million Redeemable Preference Shares at a nominal value of EUR 5.00 each. For the redeemable preference shares in favor of the Greek State, please also refer to Note 32.

Under the government-guaranteed borrowings facility, we participated in the second pillar of Greek Law 3723/2008 as follows:

The notes described above are held by the Bank and therefore, are not presented as liabilities on the Consolidated Balance sheet. Additionally, the notes are currently rated Caa2 by Moody's and B- by Fitch.

On April 12, 2010, the Bank obtained from Public Debt Management Agency, Greek government bonds having a nominal value of EUR 787.0 million collateralized with shipping and mortgage loans.

These bonds can only be used as collateral for financing and therefore are reflected in off-balance sheet items.

At December 31, 2010 and 2011, the Group pledged to central banks and other third parties for funding purposes, bonds, loans and other securities, of EUR 24,811.3 million and EUR 32,665.5 million, respectively.

The aggregate amount of short-term certificates of deposit, each with a minimum denomination of EUR 75,590, which approximates USD 100,000, was EUR 132,190 thousand at December 31, 2011 (2010: EUR 539,376 thousand). At December 31, 2011, interest-bearing deposits with scheduled maturities in excess of one year were EUR 650,187 thousand (2010: EUR 656,107 thousand).

Deposits made by Greek residents and foreign customers at December 31, comprised:

	2010						2011

	Greek residents		Foreign		Total		Greek residents		Foreign		Total
	(EUR in thousands)						(EUR in thousands)
Interest bearing:
Public sector		3,221,218		131,267		3,352,485		1,740,647		56,266		1,796,913
Private sector:
Corporations		3,268,323		6,687,729		9,956,052		2,773,259		4,802,960		7,576,219
Individuals		42,006,925		10,113,819		52,120,744		34,977,371		12,159,912		47,137,283
Interbank		24,261,740		1,607,811		25,869,551		31,576,223		906,713		32,482,936

Total interest bearing deposits		72,758,206		18,540,626		91,298,832		71,067,500		17,925,851		88,993,351

Non-interest bearing:
Public sector		132,164		47,256		179,420		353,244		18,353		371,597
Private sector:
Corporations		666,511		721,179		1,387,690		561,296		763,524		1,324,820
Individuals		261,623		510,278		771,901		158,755		547,265		706,020
Interbank		55,005		202,633		257,638		118,616		60,898		179,514

Total non-interest bearing deposits		1,115,303		1,481,346		2,596,649		1,191,911		1,390,040		2,581,951

Total:
Public sector		3,353,382		178,523		3,531,905		2,093,891		74,619		2,168,510
Private sector:
Corporations		3,934,834		7,408,908		11,343,742		3,334,555		5,566,484		8,901,039
Individuals		42,268,548		10,624,097		52,892,645		35,136,126		12,707,177		47,843,303
Interbank		24,316,745		1,810,444		26,127,189		31,694,839		967,611		32,662,450

Total deposits		73,873,509		20,021,972		93,895,481		72,259,411		19,315,891		91,575,302

Included in the above table are interest bearing deposits of EUR 1,240,756 thousand and EUR 1,779,727 thousand for 2010 and 2011 respectively for which the Group has elected the fair value option. Such instruments are accounted for at fair value because they have embedded derivatives and the Group elected to account for them at fair value rather than separating the embedded derivatives, or because they are managed on a fair value basis and the Group elected to apply the fair value option provided by ASC 825 "Financial Instruments". During 2010 and 2011 losses of EUR (12,389) thousand and EUR (48,979) thousand, respectively, relating to fair value changes of these deposits were included in net trading loss, of which EUR NIL and a gain of EUR 10,973 thousand, respectively, relate to credit risk.

Interest bearing interbank deposits under "Greek residents" mainly include the funding from the ECB and ELA type facility (through the Bank of Greece) amounting to EUR 24,214,517 thousand and EUR 31,307,746 thousand for 2010 and 2011 respectively.

Information concerning securities sold under agreements to repurchase is summarized as follows:

	2010

	(EUR in thousands)
Securities sold under agreements to repurchase		3,538,289	1,302,239
Securities sold under agreements to repurchase:
Average outstanding during the year		5,120,716	3,221,314
Weighted average interest rate during the year		1.48%	3.79%
Weighted average interest rate at year end		3.15%	3.63%
Amount outstanding at month end:
January		9,861,416	5,125,395
February		8,549,200	4,698,535
March		8,192,043	5,187,643
April		4,910,773	4,360,673
May		3,992,152	2,976,276
June		4,318,192	2,606,337
July		4,517,778	2,661,253
August		4,279,021	2,309,891
September		4,004,623	1,930,242
October		3,218,453	3,144,079
November		2,701,563	2,036,228

Securities sold under agreements to repurchase are recorded at the amount of cash received in connection with the transaction. Maturities of such agreements to repurchase are typically overnight to six months.

Included in other borrowed funds are facilities with a maturity of one year or less. These borrowings had a balance of EUR 1,111,663 thousand and EUR 925,971 thousand in 2010 and 2011, respectively.

The weighted average interest rate of other borrowed funds was 2.29% and 2.61% in 2010 and 2011 respectively.

The financial conditions of the major short-term of other borrowed funds as of December 31, 2011, are as follows:

Accounts payable, accrued expenses and other liabilities at December 31, comprised:

	2010

	As restated
	(EUR in thousands)
Accrued expenses and deferred income		129,436	96,689
Amounts due to re-insurers		23,391	23,820
Income and other taxes payable		165,153	153,236
Accounts payable		349,991	218,651
Payroll related accruals		52,192	57,365
Private equity: liabilities of investee entities		134,028	208,064
Unsettled transactions on debt securities		1,065	2,727
Accrued interest and commissions		357,546	420,999
Deferred tax liability (Note 39)		138,012	62,213
Amounts due to third-parties under collection agreements		28,277	82,205
Pension liability		299,933	224,743
Dividends payable		30,923	4,080
Amounts due to government agencies		145,379	180,043
European Re-development Fund		27,612	19,960
Liabilities relating to deposit administration funds (DAF)		232,337	198,040
Checks and credit card transactions under settlement		676,610	1,010,478
Other		534,125	585,023

Total		3,326,010	3,548,336

EH has consistently made a provision for loss reserves by estimating the potential liability on a claim-by-claim basis. Activity in the liability for unpaid claims and claim adjustment expenses for the year ended December 31, comprises of:

	2010

	(EUR in thousands)
Property and casualty reserves
Reserve for unpaid claims and claim adjustment expenses as at January 1,		700,711		735,476
Incurred claims and claim adjustment expenses:
Provision for insured events of the current year		293,974		245,894
Change in provision for insured events of prior years		(33,644	)	16,079

Total incurred claims and claim adjustment expenses		260,330		261,973
Payments:
Claims and claim adjustment expenses attributable to insured events of the current year		(121,149	)	(83,739	)
Claims and claim adjustment expenses attributable to insured events of prior years		(103,082	)	(118,257	)

Total payments		(224,231	)	(201,996	)
Changes in unearned premium reserves		(1,334	)	(45,657	)

Reserves for unpaid claims and claim adjustment expenses as at December 31,		735,476		749,796

The reinsurance program of EH is designed to minimize the Group's exposure to large claims and reduce accumulation against catastrophic risks. The level of risk retained by the Group is determined by the levels of Shareholder Equity, Gross Written Premia and Possible Maximum Loss per type of risk underwritten.

We assume and cede reinsurance with other insurance companies, mainly in the property and casualty lines of business.

Our reinsurance program consists of non-proportional treaties in motor and property, per risk and catastrophe business, which are our main lines of property and casualty business. Other lines of business are covered mainly by proportional treaties.

The effect of reinsurance on premiums written and earned for the years ended December 31, was as follows:

Included in premiums earned for 2009, 2010 and 2011 are premiums assumed of EUR 1.0 million, EUR 1.3 million and EUR 0.4 million respectively.

Premiums earned on long-duration life insurance contracts amounted to EUR 216.6 million, EUR 172.0 million and EUR 86.3 million for 2009, 2010 and 2011 respectively.

Long-term debt (original maturities of more than one year) at December 31, comprised:

Certain debt instruments were issued by 100% owned "finance subsidiaries" of the Bank, NBG Funding Ltd (unconsolidated) and NBG Finance Plc (consolidated), NBG Finance (Sterling) Plc (consolidated) and NBG Finance (Dollar) Plc (consolidated) (the "finance subsidiaries"). The Bank has fully and unconditionally guaranteed all securities issued by these companies. There are no restrictions on the ability of these "finance subsidiaries" to transfer funds to the Bank in the form of cash dividends, loans and advances.

The Group does not consolidate NBG Funding Ltd as the Group is not deemed to be the primary beneficiary of the entity. The Group does not have the obligation to absorb losses or the right to receive benefits as the only assets of NBG Funding Ltd are loans to and deposits with NBG.

The proceeds of the instruments issued by NBG Funding Ltd were lent to NBG Finance Plc, NBG Finance (Sterling) Plc and NBG Finance (Dollar) Plc through Eurobond issues and ultimately lent to the Bank under loan agreements with the same terms as each of the instruments referred to above but with a 31 year maturity.

Long-term debt Senior Notes and the related rates and maturity dates at December 31, comprise:

The financial conditions of the long-term senior fixed rate debt as of December 31, 2011, are as follows:

The financial conditions of the major long-term senior variable rate debt as of December 31, 2011, are as follows:

Long-term Subordinated debt Senior Notes and the related rates and maturity dates at December 31, comprise:

The financial conditions of the long-term subordinated fixed and variable rate debt as of December 31, 2011, are as follows:

Issuer	Type		Maturity date	Currency	Nominal amount		Own held by the Group		Interest rate	Interest payment

					(in million)		(nominal amount in million)
Subordinated fixed rate notes
NBG Funding Ltd⁽¹⁾	Guaranteed Fixed/Floating Rate Subordinated Callable Notes due 2037— Series E	November 8, 2006	November 2037	GBP		375.0		—	6.2889% fixed per annum until November 8, 2016 and thereafter floating of three month Libor plus 2.08%	Quarterly
NBG Finance Plc⁽²⁾	Fixed Rate Notes—Lower Tier II	August 3, 2010	August 2020 (Early redemption 2015)	EUR		450.0		20.0	7.0% for the first five years and 9.5% thereafter	Annually
Subordinated variable rate notes
NBG Funding Ltd⁽¹⁾	Guaranteed Floating Rate Subordinated Callable Notes due 2034— Series A	July 11, 2003	July 2034	EUR		350.0		—	Three-month Euribor plus 175 bps until July 11, 2013 and three-month Euribor plus 275 bps thereafter	Quarterly
NBG Funding Ltd⁽¹⁾	Guaranteed CMS-Linked Subordinated Callable Notes due 2035— Series B	November 3, 2004	November 2035	EUR		350.0		—	The difference of the 10-year EUR CMS mid swap rate plus 12.5 bps reset every six months and capped at 8%	Semi annually
NBG Funding Ltd⁽¹⁾	Guaranteed CMS-Linked Subordinated Callable Notes due 2035— Series C	November 3, 2004	November 2035	USD		180.0		—	The 10 year EUR CMS mid swap rate plus 12.5 bps reset every six months and capped at 8%	Semi annually

"Other" primarily includes fixed rate borrowings of Finansbank and Finans Leasing amounting to EUR 127,722 thousand (of which EUR 73,806 thousand, EUR 5,154 thousand and EUR 48,762 thousand denominated in EUR, TL and USD respectively) and floating rate borrowings of the above mentioned companies, amounting to EUR 101,670 thousand (of which EUR 92,818 thousand, and EUR 8,852 thousand denominated in EUR and USD).

In the normal course of business, the Group enters into a number of off-balance sheet commitments to meet the financing needs of its customers, through the use of commitments to extend credit and commercial and standby letters of credit.

The following table summarizes the Group's off-balance-sheet financial instruments, whose contract amounts represent credit risk, as of December 31:

Commitments to Extend Credit. Commitments to extend credit are agreements to lend to a customer, as long as there is no violation of any condition established in the contract. Commitments generally have fixed expiration dates or other termination clauses and may require payment of a fee. Since many of the commitments are expected to expire without being drawn upon, the total commitment amounts do not necessarily represent future cash requirements. Management evaluates each customer's credit worthiness in determining the amount of collateral to obtain. Collateral held varies and may include accounts receivable, inventory, property, plant and equipment and real estate.

Commercial Letters of Credit. Commercial letters of credit ensure payment by a bank to a third party for a customer's foreign or domestic trade transactions, generally to finance a commercial contract for the shipment of goods. A significant portion of commercial letters of credit is on an immediate payment basis. The Group's credit risk in these transactions is limited since the contracts are collateralized by the merchandise being shipped and are generally of short duration.

Standby Letters of Credit and Financial Guarantees Written. Standby letters of credit and financial guarantees written are conditional commitments issued by the Group to guarantee the performance of a customer to a third party. Those guarantees are primarily issued to support the financing needs of the Bank's commercial customers, and are short-term in nature. The credit risk involved in issuing letters of credit is essentially the same as that involved in extending loan facilities to customers.

Legal Contingencies. The Group and certain of its subsidiaries is defendant in certain claim and legal actions and proceedings arising in the ordinary course of business. These actions and proceedings are generally based on alleged violations of consumer protection, banking, employment and other laws. None of these actions and proceedings is individually material. In accordance with ASC 450 the Group establishes accruals for all litigations, for which it believes it is probable that a loss has been incurred and the amount of the loss can be reasonably estimated. These accruals may change from time to time, as appropriate, in light of additional information. At December 31, 2010 and 2011 the Group has accrued for cases under litigation the amount of EUR 43.6 million and EUR 85.4 million respectively for those litigations for which the Group believes that this loss is probable and reasonably estimated. For the cases for which an accrual has not been recognized, management is unable to estimate a range of reasonably possible losses because the proceedings may last for many years, many of the proceedings are in early stages, there is uncertainty of the likelihood of the final result, there is uncertainty as to the outcome of pending appeals and there are significant issues to be resolved. However, in the opinion of the management, after consultation with legal counsel, the ultimate disposition of these matters is not expected to have a material adverse effect on the consolidated balance sheet, results of operation or cash flows.

Staff leaving indemnity contingencies. In accordance with Greek Law 4046/2012 and Board of Ministers' Decision (6/28.2.2012), from February 14, 2012 onwards, the employment contracts that lapse on attainment of the normal retirement age or based on the particular retirement conditions, are considered as indefinite duration employment contracts and therefore, the provisions for employees statutory retirement indemnity of Greek Law 2112/1920, are applied. During the years 2010 and 2011 the Group has been subject to litigation claims in relation to the benefits available to employees under the finite duration employment contracts reliant on interpretation of certain clauses of Greek Law 2112/1920. Such claims have been upheld by the court. As a result the Group concluded that based on the available evidence the obligation for the remaining populous of employees under the finite employment contracts is both probable and the amount of the obligation is reasonable estimable under the provisions of Greek Law 2112/1920 based on an actuarial valuation carried out in accordance with ASC 715-30. Following the above, the Group recognized in the income statement as at December 31, 2011, an amount of EUR 169.9 million which is included under "Other non-interest expense". The estimates included in this amount are based on the Group's analysis of currently available information, and as new information is obtained the Group may change its estimates. Prior to 2011, the Bank concluded that the obligation with respect to employment contracts with its employees as finite duration contracts was remote, therefore no provision for staff leaving indemnity was recognized.

On December 31, 2010 the Bank's wholly owned subsidiary EH completed the voluntary retirement scheme, that had been announced on November 25, 2008, whereby employees fulfilling certain criteria had the opportunity to leave service receiving additional benefits to those provided by law, subject to the approval of the Voluntary Retirement Scheme Committee which included representatives of the company and its employees. A total of 237 employees have left service taking advantage of the provisions of the scheme (not including those who had subscribed to the scheme and subsequently withdrew their interest). The Group has recognized a total expense of EUR 46.7 million in respect of this scheme (EUR 16.8 million in 2008, EUR 24.6 million in 2009 and EUR 5.3 million in 2010). No further cost in respect of this scheme is expected to be incurred.

In addition to the losses on derivative instruments (see Note 10), the losses on deposits and the gains on long-term debt at fair value (see Note 19 and Note 24, respectively), net trading loss in 2009, 2010 and 2011 also includes gains from the re-purchase by the Group from the open market of debt securities issued by the Group of EUR 224,683 thousand, EUR 10,855 thousand and EUR 7,651 thousand respectively.

Insurance claims, reserves movement, commissions and reinsurance premia ceded for the years ended December 31, comprised:

The income tax information as at December 31, 2010 and for the years ended December 31, 2009 and 2010 has been restated to reflect the impact discussed in Note 43.

The significant components of the income tax (expense)/benefit for the years ended December 31, 2009, 2010 and 2011 are as follows:

The allocation of income before income tax between domestic and foreign is presented in Note 37.

The differences between the nominal statutory income tax and the effective income tax are summarized as follows:

	2009			2010

	As restated			As restated
	(EUR in thousands)
Tax calculated based on statutory income tax rate of 20% (2009: 25% & 2010: 24%)		157,468			(63,766	)	(2,809,627	)
Effect of tax exempt income		(141,447	)		(35,029	)	(18,132	)
Effect of different tax rates in other countries		(59,068	)		(60,839	)	10,535
Non deductible expenses		26,456			52,769		120,968
Statutory revaluation of fixed assets		89,768			—		—
Effect of change in income tax rate		26,330			43,987		9,851
General allowance for loans losses recognized only for tax purposes		(2,638	)		—		—
Valuation allowance for deferred tax assets		—			—		3,115,613
Non-offsettable income taxes with current year income taxes		22,754			14,059		12,740
Tax audit settlement		—			2,494		8,223
Other		9,227			9,535		9,174

Income tax expense/(benefit) before additional income taxes		128,850			(36,790	)	459,345

Additional tax under Greek tax laws 3808/2009 and 3845/2010		47,736			26,126		—
Non-offsettable income taxes in accordance with Law 3842/2010		—			52,975		—

Income tax expense/(benefit) after additional income taxes		176,586			42,311		459,345

In 2011, the increase in the effect on taxes of the expenses non-deductible for tax purposes is mainly due to the impairment of goodwill of investments in subsidiaries (see Note 14).

The significant components of deferred income tax assets and liabilities at December 31 comprised:

	2010

	As restated
	(EUR in thousands)
Deferred Tax Assets:
Allowance for loan losses		6,980		477,575
Mark to market valuation of securities and derivatives		683,246		2,433,242
Pension and other post retirement benefits		53,117		53,519
Insurance reserves		18,867		93,940
Revaluation of land and buildings		140,875		137,640
Intangibles recognized upon acquisition and other assets		311		192
Tax free reserves		17		—
Tax loss carried forward		289,134		210,461
Other		51,728		98,340

Gross deferred tax assets		1,244,275		3,504,909
Deferred tax assets/liabilities for netting		(156,999	)	(130,204	)

Net deferred tax assets		1,087,276		3,374,705
Valuation allowance for deferred tax assets		—		(3,115,613	)

Net deferred tax assets after valuation allowance		1,087,276		259,092

Deferred Tax Liabilities:
Allowance for loan losses		(39,971	)	(22,455	)
Mark to market valuation of securities and derivatives		(43,134	)	(31,477	)
Revaluation of land and buildings		(1,351	)	(1,358	)
Intangibles recognized upon acquisition and other assets		(49,515	)	(37,644	)
Tax free reserves		(95,202	)	(92,556	)
Other		(65,838	)	(6,927	)

Gross deferred tax liabilities		(295,011	)	(192,417	)
Deferred tax liabilities/assets for netting		156,999		130,204

Net deferred tax liabilities		(138,012	)	(62,213	)

The Group as at December 31, 2011 has a deferred tax asset of EUR 210,461 thousand on the tax losses carry-forward of EUR 1,102,083 thousand which expire as follows:

The applicable Greek statutory corporation income tax rate was 25% for 2009, 24% for 2010 and 20% for 2011. The Greek Law 3943/2011 which was enacted in March 2011 provides that for the periods commencing from January 1, 2011 thereon, the nominal corporation tax rate is reduced to 20%. Furthermore, upon profit distribution a 25% withholding tax is imposed on distributed profits.

Based on the above, the Group examined the timing of the reversal of the temporary differences for all Greek entities and adjusted the deferred tax asset/liability amounts accordingly in order to reflect the reduction in the nominal tax rates. The total effect, for the years ended December 31, 2009, 2010 and 2011, was an expense of EUR 26.3 million, EUR 44.0 million and EUR 9.9 million respectively.

In accordance with paragraph 3, article 10 of Greek Law 3842/2010 regarding tax issues, the receivable amount of withholding taxes which is reflected in the Bank's corporate income tax returns for the year 2009 is not refunded provided that it relates to taxes withheld on bond interest income. In this respect the Bank recognized in 2010 the amount of EUR 53.0 million in the income statement and reserved its legal rights on this issue.

In accordance with Greek Law 3845/2010 "Measures for the implementation of the support mechanism of the Greek economy through the eurozone Member-States and the International Monetary Fund", a non-recurring tax was imposed on legal entities for social responsibility purposes and is calculated on the total net income for the year 2009, provided that it exceeded EUR 100 thousand. In 2010, the Group recognized a tax expense of EUR 26.1 million.

On December 10, 2009, a tax law (Greek Law 3808/2009) was enacted, according to which entities with profits exceeding EUR 5.0 million in 2008, were required to pay a special tax levy calculated on the higher of the taxable profits or IFRS profits reported for that year. The tax levy accrued to the Group's income statement of 2009 amounted to EUR 47.7 million.

Non-offsettable income taxes relate to the excess amount of withholding taxes over the capacity to absorb tax credits in the current year.

The reconciliation of the movement of the Group's unrecognized tax benefits is presented in the following table. If recognized, these benefits would affect the Group's effective tax rate.

During 2009, 2010 and 2011, the Group recognized within income tax the amount of EUR 44 thousand, EUR 50 thousand and EUR 11 thousand respectively, relating to interest. As of December 2009, 2010 and 2011, the Group's cumulative interest related to income taxes was EUR 199 thousand, EUR 57 thousand and EUR 68 thousand respectively.

The Group companies file income tax returns in the jurisdictions in which they conduct business. We do not expect the total amounts of unrecognized tax benefits to significantly change within 12 months of the reporting date.

The financial year 2011 of the Bank and certain of its Greek subsidiaries, according to amended article 82 of Greek Law 2238/1994, will be audited for tax purposes by the certified auditors of the Bank and it's Greek subsidiaries, Deloitte Hadjipavlou, Sofianos and Cambanis S.A. The previous open tax years, up to and including the year 2010, will be audited by the tax authorities.

During 2011, the tax settlement of "open" tax years of certain branches and subsidiaries amounted to EUR 185 thousand.

The open tax years of the major companies of the Group at December 31, 2011, are as follows:

The Group has entered into transactions with the members of the Board of Directors of the Bank, the General Managers and the members of the Executive Committees of the Bank, the key management of other Group companies, as well as with the close members of family and entities controlled or jointly controlled by those persons.

The aggregate amount of loans, deposits and letters of guarantee to such related parties totaled EUR 26.2 million, EUR 10.9 million and EUR 0.2 million respectively as at December 31, 2011 (2010: EUR 256.3 million, EUR 22.2 million and EUR 13.6 million respectively). The Group has also entered into transactions with its affiliates, which are accounted for by the equity method (see Note 12). The aggregate amount of receivables from affiliates totaled EUR 3.8 million, the amount of payables to affiliates totaled EUR 776.2 million and the amount of letters of guarantee to affiliates totaled EUR 14.9 million as at December 31, 2011 (2010: EUR 8.8 million, EUR 766.6 million and EUR 13.4 million respectively). The aggregate amount of income from affiliates totaled EUR 1.6 million and the amount of expense to affiliates totaled EUR 31.7 million (2010: EUR 2.6 million and EUR 32.9 million respectively).

The total receivables of the Group from the employee benefits related funds as at December 31, 2011, amounted to EUR 413.7 million (2010: EUR 298.1 million). The total payables of the Group to the employee benefits related funds as at December 31, 2011, amounted to EUR 116.0 million (2010: EUR 87.6 million).

On January 22, 2009, an Extraordinary General Meeting of the Bank's Shareholders was held, which approved the issue of 70.0 million redeemable preference shares at a par value of EUR 5.00 each with the cancellation of the pre-emptive rights of the existing shareholders in favor of the Greek State in accordance with Greek Law 3723/2008 for the Bank's participation in the part (1) of the Hellenic Republic Bank Support Plan. On May 21, 2009, the Bank's Board of Directors certified that the Greek State fully covered the said issue of preference shares. This increase was covered through the transfer to the Bank of an equal market value Greek government bond with a coupon rate of 6-month Euribor plus 130 basis points. On May 25, 2009, the Board of Directors' minutes for the above mentioned certification were filed with the Ministry of Development (resolution K2-5300/Registrar of Companies). Following the above the Bank's share capital increased by EUR 350.0 million.

The preference shares issued by the Bank in favor of the Greek State are not transferable and embody the following privileges:

The Ministry of Economy and Finance, through its letter to the Bank of Greece (Protocol Number 39389/B2038/7.8.2009) clarified that the funds provided by the Greek State to the financial institutions through the issuance of preference shares, are for the support of the capital adequacy of the Greek banking sector and not for medium term funding. In this respect the Government issued Greek Law 3844/2010 under which, the preference shares are not mandatorily redeemable. However, if not redeemed after five years following their issuance and if the participating bank's general meeting of shareholders has not approved their redemption, the Greek Minister of Finance will impose, pursuant to a recommendation by the Bank of Greece, a gradual cumulative increase of 2% per year on the 10% fixed return provided for during the first five years from the issuance of the shares to the Hellenic Republic.

In accordance with Ministerial Decision 2/98029/0023A/17-01-2012, the redemption of the preference shares issued in favor to the Greek State, will, from December 31, 2011 onwards, be

effected at the original par value of the preference shares through the exchange of Greek government bonds or treasury bills. At any redemption date the Greek government bonds or treasury bills to be exchanged should have the following characteristics:

On November 26, 2010, the Bank's Shareholders Extraordinary General Meeting approved the repurchase by the Bank of the Greek Law 3723/2008 preference shares of a nominal value of EUR 350.0 million through payment in cash, subject to obtaining Bank of Greece and other statutory approvals.

On December 22, 2011, the Extraordinary General Meeting of the Bank's Shareholders approved a) the share capital increase by EUR 1,000.0 million through the issue of additional 200.0 million Redeemable Preference Shares at a nominal value of EUR 5.00 each with the cancellation of the pre-emptive rights of the existing shareholders in favor of the Greek State, in accordance with Greek Law 3723/2008 and b) the revocation of the decision of the Extraordinary General Meeting of the Bank's Shareholders held on November 26, 2010 regarding the repurchase by the Bank of the 70.0 million Redeemable Preference Shares in favor of the Greek State, in accordance with Greek Law 3723/2008.

On December 30, 2011, following the above decision, the Bank issued the 200.0 million Redeemable Preference Shares at a nominal value of EUR 5.00 each.

On February 18, 2010, the 2nd Repeat General Meeting of the Bank's shareholders approved the assignment to the Board of Directors of the right to issue bonds convertible to shares, as per the provisions of articles 3a and 13 of the Companies Act and Article 5 of the Bank's Articles of Association, for a period of five years, up to an amount corresponding to 50% of the paid-up share capital of the Bank as at the time of the assignment of the said right, that is EUR 1,696.0 million. The Meeting authorized the Board of Directors to decide the particular terms and details of such issuance, as well as the procedure by which the bonds will be converted to shares.

The Annual General Meeting of the Bank's Shareholders held on May 15, 2008, authorized the Board of Directors to increase the Bank's share capital through the issue of common shares with a pre-emptive right in favor of existing shareholders within a period of three years as of the date of the said Annual General Meeting and up to the amount that corresponds to 50% of the Bank's paid up share capital.

On September 10, 2010, following the above authorizations, the Board of Directors, approved the increase of the Bank's ordinary share capital through a rights issue by offering:

On December 22, 2009, the Board of Directors of the Bank approved the share capital increase by EUR 99 thousand through the issue of 19.693 ordinary shares derived from the exercise of stock options under Programs A and B.

In July 2009, following the Board of Directors' resolution on June 18, 2009, the Bank increased its ordinary share capital by offering 110,367,615 new ordinary shares of nominal value of EUR 5.00 each and subscription price of EUR 11.30 each through a rights issue. The shares were initially offered to existing ordinary shareholders at a ratio of 2 new shares for every 9 shares held. The total capital raised amounted to EUR 1,247,154 thousand, EUR 551,838 thousand of which was credited to common stock and the remaining amount less expenses incurred of EUR 653,518 thousand was credited to additional paid-in-capital.

Of the redeemable NCI outstanding as at December 31, 2011, EUR 257.4 million relates to the fair value of the arrangement with the IFC regarding 5% of Finansbank ordinary shares (December 31, 2010, EUR 242.1 million). In April 2007, the Bank disposed of 5% of Finansbank ordinary shares to IFC for USD 259.2 million. The price per share received from the IFC was determined to be the price per share paid by the Bank to the Finansbank shareholders during the Mandatory Tender Offer. This stake is subject to put and call arrangements, as provided for in the shareholders' agreement between the Bank and IFC, exercisable after 5 and 7 years, respectively. The put option price is the higher of (i) the fair market value of the shares as determined by independent valuation specialists and (ii) the price received compounded semiannually with 6-month Libor plus 25 basis points. These put and call agreements are neither legally detachable nor separately exercisable from the respective shares held by IFC.

The remaining redeemable NCI outstanding as at December 31, 2011 and 2010 relates to similar put and call arrangements with the EBRD with respect to 10.21% of Banca Romaneasca's share capital. These arrangements were settled in January 2012.

Similar put/call agreements that existed with the EBRD and the IFC with respect to 10.8% each of Stopanska Banka's share capital were settled in August 2010 following the exercise by EBRD and IFC of their put options.

Based on the terms of the above agreements, the ordinary shares subject to the put options described above are accounted for as redeemable non-controlling interest as described in note 3, in accordance with ASU 2009-04 (EITF Topic D-98). The redeemable NCI are currently or probably redeemable as of each balance sheet date presented. The amount presented as "Non-controlling interest—Temporary equity" relates to the redemption amount as estimated at each reporting date. Any changes in the redemption amount are recognized in "Accumulated Surplus".

Basic earnings per share is computed by dividing net income for the year attributable to ordinary shareholders after deducting dividends declared to preferred shareholders by the weighted average number of ordinary shares outstanding during the year (amounts are presented in EUR thousands, except share and per share data).

The per-share computations above reflect the additional shares relating to the stock dividend and the effect of the bonus element (i.e. issue of common stock at discount to market price) in the share capital increase took place in 2010, as described in Note 32. The adjustment, which corresponds to the factor of 1.1769 is applied retrospectively to all periods presented.

Common shares from stock options were not included in the computation of the dilutive EPS for 2009, 2010 and 2011 because their impact was anti dilutive based on current market prices. In 2011 all stock options lapsed.

Quantitative measures established by regulation to ensure capital adequacy require the Bank to maintain minimum amounts and ratios determined on a risk-weighted basis, capital (as defined) to

assets, certain off-balance sheet items, and the notional credit equivalent arising from the total capital requirements against market risk, of at least 8%. At least half of the required capital must consist of "Tier I" capital (as defined), and the rest of "Tier II" capital (as defined). The framework applicable to Greek banks conforms to European Union requirements, in particular the Own Funds, the Solvency Ratio and the Capital Adequacy Directives. However, under the relevant European legislation, supervisory authorities of the member states have some discretion in determining whether to include particular instruments as capital guidelines and to assign different weights, within a prescribed range, to various categories of assets.

The unique events that occurred during 2011, such as the continuation, for a third year in a row, of the crisis in the Greek economy and the impairment losses recognized due to the completion of the PSI (see Note 11), have adversely impacted the regulatory capital of the Group and the Bank which has been reduced significantly, and there is need for recapitalization. The recapitalization plan for Greek banks forms an integral part of the financial assistance under the Program.

The Program, which has already been approved by the Troika along with a specific sequence of disbursements, commits funds for the recapitalization plan, amounting up to EUR 50.0 billion and is now in the implementation phase under the auspices of the Bank of Greece. The main features of this Program are:

All Greek banks are required to achieve a Core Tier I capital ratio of 9% by September 2012 and 10% by June 2013. In addition, banks' capital needs will be determined on the basis of a requirement to maintain a 7% Core Tier I capital ratio under a three-year adverse stress scenario;

From January 1, 2012 until the Group achieves the minimum level of capital required, the Bank of Greece will allow the Bank to operate at a Core Tier I ratio lower than 9%;

The Bank of Greece, with the support of external consultants, is undertaking a comprehensive assessment of the banks' capital needs and viability. This assessment will be based, inter alia, on a stress-test exercise built on the results from an independent loan diagnostic exercise, the PSI impact, and the business and capital plans that banks have already submitted, and will be revised in accordance with Bank of Greece comments;

Banks which are deemed viable based on their business and capital raising plans, as assessed by the Bank of Greece, will be given the opportunity to raise capital in the market, prior to September 30, 2012. Residual capital needs will be met from public support from the HFSF through common shares with restricted voting rights or contingent convertible bonds, in a manner that preserves private sector incentives to inject capital;

The actual capital amounts and ratios (based on IFRS figures) for the Group are presented in the table below:

							For Capital Adequacy Purposes

	Actual						Minimum Required
	Amount			Ratio			Amount		Ratio
	(EUR in thousands)						(EUR in thousands)
As of December 31, 2011:
Total Capital		(1,664,113	)		(2.6	)%		5,139,827		8.0%
(to Risk-Weighted Assets)
Tier I Capital		(2,367,343	)		(3.7	)%		3,212,392		5.0%
(to Risk-Weighted Assets)
As of December 31, 2010:
Total Capital		9,311,414			13.7	%		5,455,878		8.0%
(to Risk-Weighted Assets)
Tier I Capital		8,958,703			13.1	%		3,409,922		5.0%
(to Risk-Weighted Assets)
As of December 31, 2009:
Total Capital		7,590,412			11.3	%		5,392,548		8.0%
(to Risk-Weighted Assets)
Tier I Capital		7,590,412			11.3	%		3,370,343		5.0%
(to Risk-Weighted Assets)

In accordance with the Bank of Greece directives (Governor's Act 2630/29.10.2010) the Group's capital base includes all types of regulatory eligible Own Funds, among others, the share capital, the share premium account, the reserves and retained earnings, preferred securities and subordinated debt issues.

However, at December 31, 2011, the Group's capital adequacy ratio was below the minimum threshold of 8% required (negative 2.6%) due to the recognition of losses from the Groups' participation in the PSI, and to this extend the Tier I and Total capital have been calculated before the application of the regulatory limits prescribed in the Bank of Greece Governor's Act 2630/2010. Specifically, in case of negative regulatory equity the recognition of minority rights as well as Lower Tier I capital and Tier II is prohibited and certain investments in financial institutions are deducted from Tier I capital.

In the context of actions designed to fortify the Bank's capital position, in December 2011 the Bank raised EUR 1 billion through the issue of redeemable preference shares that were taken up in full by the Hellenic Republic and in January 2012 completed a tender offer to repurchase all or part of the covered bonds and hybrid securities issued by the Group in the past. This move enabled the Bank to strengthen its Core Tier I and Tier I capital by EUR 302 million and EUR 77 million respectively.

By including the amount of EUR 6.9 billion of capital confirmed by the HFSF (see Note 42) and the amount of EUR 77.0 million of capital created on January 17, 2012 from the voluntary tender offer

for the acquisition of the preferred securities issued by NBG Funding Ltd and for the EUR 1,500.0 million Third Series fixed rate covered bonds due in 2016 (see Note 24), the Tier I and Total capital ratios for the Group are calculated at 7.2% and 8.3% respectively.

The following information should not be interpreted as an estimate of the fair value of the entire Group. A fair value calculation is only provided for a limited portion of the Group's assets. Due to a wide range of valuation techniques and the degree of subjectivity used in making the estimates, comparisons between the Group's disclosures and those of other companies may not be meaningful.

The fair value information as at December 31, 2010 has been restated to reflect the impact discussed in Note 43.

The following methods and assumptions were used to estimate the fair value of the Group's financial assets and liabilities, which are not recorded on the Group's balance sheet at fair value at December 31, 2010 and 2011:

Cash, deposits, repos: The carrying amount of cash, deposits with central bank and other banks and repurchase and resale agreements approximates their fair value.

Loans: Except for the loans designated at fair value (see (b) below), loans are not recorded at fair value on a recurring basis and their fair value is estimated for disclosure purposes only. The fair value of loans is estimated using discounted cash flow models. The discount rates are based on current market interest rates for loans with similar terms to borrowers of similar credit quality. For variable rate commercial loans that re-price frequently (within a relatively short time frame) and have no significant change in credit risk, fair value is based on carrying amount. Impaired loans secured with collateral are not considered to be "collateral dependent" if foreclosure is not probable and repayment is not expected to be provided solely by the underlying collateral, therefore such loans are not disclosed as Level 3 fair value measurements on a non-recurring basis. For impaired loans secured with collateral for which foreclosure is probable, the impairment was measured based on the fair value of the collateral. These measurements are classified as Level 3 in the fair value hierarchy (see Note 13).

Held to maturity securities: The fair value of held to maturity investment securities is estimated using market prices, or if such are not available, using discounted cash flow models. The discount rates are based on current market interest rates offered for instruments with similar terms to the same borrowers or borrowers of similar credit quality. In particular, for Greek government bonds classified as held-to-maturity securities that were exchanged in the context of the PSI (see Note 11).

Deposits: The fair value for demand deposits and deposits with no defined maturity is determined to be the amount payable on demand at the reporting date. The fair value for fixed-maturity deposits is estimated using discounted cash flow models based on rates currently offered for the relevant product types with similar remaining maturities.

Other borrowed funds and Long-term debt: Fair value is estimated using market prices, or if such are not available, using a discounted cash flow analysis, based on current market rates of similar maturity debt securities.

The table below presents the carrying amount and fair value of those financial assets and liabilities not recorded on the Group's balance sheet at fair value and whose fair value is materially different from the carrying amount.

The table below presents the fair value of those financial assets and liabilities that are measured at fair value on a recurring basis, analyzed by fair value measurement level as described in note 3.

	Fair value measurement using

	Fair value measurement using						Total assets/ liabilities at fair value
At December 31, 2010 As restated	Level 1		Level 2		Level 3		Total assets/ liabilities at fair value
	(EUR in thousands)
Assets
Trading assets		1,106,670		1,641,790		36,862		2,785,322
Greek government bonds		—		797,377		—		797,377
Debt securities issued by other governments and public sector entities		128,347		48,986		—		177,333
Debt securities issued by Greek financial institutions		—		299,962		79		300,041
Debt securities issued by foreign financial institutions		1,000		361,062		36,783		398,845
Corporate debt securities issued by Greek companies		—		16,956		—		16,956
Corporate debt securities issued by foreign companies		—		110,448		—		110,448
Equity securities issued by Greek companies		6,082		—		—		6,082
Equity securities issued by foreign companies		10,272		—		—		10,272
Greek treasury bills		934,552		—		—		934,552
Foreign treasury bills		6,563		6,999		—		13,562
Mutual fund units		19,854		—		—		19,854
Derivative assets		3,448		1,592,588		38,234		1,634,270
Available-for-sale securities		4,169,976		9,326,970		191,564		13,688,510
Greek government bonds		—		6,583,084		72,980		6,656,064
Debt securities issued by other governments and public sector entities		3,359,284		401,422		—		3,760,706
Corporate debt securities issued by companies incorporated in Greece		—		824,442		14,346		838,788
Corporate debt securities issued by companies incorporated outside Greece		27,016		1,291,038		104,238		1,422,292
Equity securities issued by companies incorporated in Greece		138,480		8,016		—		146,496
Equity securities issued by companies incorporated outside Greece		145,850		648		—		146,498
Foreign treasury bills		—		218,320		—		218,320
Mutual Fund units		499,346		—		—		499,346
Loans at fair value⁽¹⁾		—		559,107		—		559,107
Other assets		200,009		33,567		—		233,576

Total Assets		5,480,103		13,154,022		266,660		18,900,785

Liabilities
Deposits at fair value⁽²⁾		—		1,240,133		623		1,240,756
Derivative liabilities		10,214		1,760,160		12,096		1,782,470
Long-term debt fair value⁽¹⁾		—		1,261,100		—		1,261,100

Total liabilities		10,214		4,261,393		12,719		4,284,326

	Fair value measurement using

	Fair value measurement using						Total assets/ liabilities at fair value
At December 31, 2011	Level 1		Level 2		Level 3		Total assets/ liabilities at fair value
	(EUR in thousands)
Assets
Trading assets		198,857		2,472,853		292,378		2,964,088
Greek government bonds		—		—		259,233		259,233
Debt securities issued by other governments and public sector entities		176,932		42,875		—		219,807
Debt securities issued by Greek financial institutions		—		44,025		370		44,395
Debt securities issued by foreign financial institutions		—		77,251		32,775		110,026
Corporate debt securities issued by Greek companies		—		10,876		—		10,876
Corporate debt securities issued by foreign companies		—		5,547		—		5,547
Equity securities issued by Greek companies		7,767		—		—		7,767
Equity securities issued by foreign companies		8,750		—		—		8,750
Greek treasury bills		—		2,268,222		—		2,268,222
Foreign treasury bills		—		24,057		—		24,057
Mutual fund units		5,408		—		—		5,408
Derivative assets		9,349		3,523,423		73,193		3,605,965
Available-for-sale securities		3,272,302		1,425,813		3,873,609		8,571,724
Greek government bonds		—		—		3,697,378		3,697,378
Debt securities issued by other governments and public sector entities		2,706,134		347,617		—		3,053,751
Corporate debt securities issued by companies incorporated in Greece		—		365,645		94,881		460,526
Corporate debt securities issued by companies incorporated outside Greece		16,469		557,063		81,350		654,882
Equity securities issued by companies incorporated in Greece		57,620		—		—		57,620
Equity securities issued by companies incorporated outside Greece		44,343		612		—		44,955
Foreign treasury bills		25,574		154,876		—		180,450
Mutual Fund units		422,162		—		—		422,162
Loans at fair value⁽¹⁾		—		277,247		—		277,247
Other assets		137,190		21,829		9,341		168,360

Total Assets		3,617,698		7,721,165		4,248,521		15,587,384

Deposits at fair value⁽²⁾		—		1,779,727		—		1,779,727
Derivative liabilities		8,371		4,301,180		10,937		4,320,488
Other liabilities		5,009		—		—		5,009
Long-term debt at fair value⁽¹⁾		—		1,059,297		—		1,059,297

Total liabilities		13,380		7,140,204		10,937		7,164,521

In 2010, Greek government bonds amounting to EUR 6.3 million in financial assets at fair value through profit and loss and EUR 5,600.4 million in available-for-sale investment securities were transferred from Level 1 to Level 2, due to the significant reduction or disappearance of trading activity. For the same reason, long term debt for which the Group has elected the fair value option were also transferred from Level 1 to Level 2. The deteriorating macroeconomic conditions during 2010 in Greece, the severe recession of Greek economy, the unprecedented pressure on the public finances of the Hellenic Republic and the tensions related to Greek public finance have affected the liquidity of Greek government bonds traded on HDAT (the electronic dealing platform for Greek government bonds). As a result of this significant reduction in liquidity the Bank has reclassified the Greek government bonds from Level 1 to Level 2.

The fair value of trading assets and AFS debt securities are generally based on quoted market prices. For certain debt securities, market price quotes may not be readily available, or trading activity has slowed significantly or ceased. Some of these instruments are valued using a discounted cash flow model, which estimates the fair value of the securities using key inputs such as credit and interest rate risk. Principal and interest cash flows are discounted using an observable discount rate for similar instruments with adjustments that management believes a market participant would consider in determining fair value for the specific security. In particular, available for sale securities valued using valuation techniques with significant unobservable inputs principally comprise of securities that require correlation between various interest indices.

The fair values of derivative assets and liabilities traded in the over-the-counter market are determined using quantitative models that utilize multiple market inputs including interest rates, prices and indices to generate continuous yield or pricing curves and volatility factors to value the position. The majority of market inputs are actively quoted and can be validated through external sources, including brokers, market transactions and third-party pricing services. Estimation risk is greater for derivative asset and liability positions that are option-based where observable market inputs are less readily available or are unobservable. In particular, derivative products valued using valuation techniques with significant unobservable inputs include certain correlation products, such as correlation between various interest indices or correlation between various currencies. They also include products where implied volatility represents a significant input.

The tables below present a reconciliation of all financial assets and liabilities measured at fair value on a recurring basis using significant unobservable inputs (Level 3) during the years ended December 31, 2010 and December 31, 2011 including realized and unrealized gains/(losses) included in earnings and OCI.

	2010

	Balance at beginning of year		Gain/(losses) included in earnings			Gain/(losses) included in OCI			Purchases, issuances, and settlements			Transfer into/(out of) level 3			Balance at end of year
	As restated (EUR in thousands)
Trading assets		63,117		(6,921	)		—			(10,568	)		(8,766	)		36,862
Greek government bonds		8,766		—			—			—			(8,766	)		—
Debt securities issued by Greek financial institutions		—		(57	)		—			136			—			79
Debt securities issued by foreign financial institutions		53,689		(6,906	)		—			(10,000	)		—			36,783
Corporate debt securities issued by foreign companies		662		42			—			(704	)		—			—
Net Derivatives		28,309		38,415			—			(28,534	)		(12,052	)		26,138
Available-for-sale securities		578,402		(14,015	)		(48	)		(294,348	)		(78,427	)		191,564
Greek government bonds		146,230		3			(29,470	)		1,027			(44,810	)		72,980
Debt securities issued by other governments and public sector entities		328,074		(15,360	)		5,573			(284,670	)		(33,617	)		—
Corporate debt securities issued by companies incorporated in Greece		14,886		9			(549	)		—			—			14,346
Corporate debt securities issued by companies incorporated outside Greece		89,212		1,333			24,398			(10,705	)		—			104,238
Deposits at fair value		4,893		241			—			(4,511	)		—			623

	2011

	Balance at beginning of year		Gain/(losses) included in earnings			Gain/(losses) included in OCI			Purchases		Settlements			Transfer into/(out of) level 3		Balance at end of year
	(EUR in thousands)
Trading assets		36,862		(4,053	)		—					—			259,569		292,378
Greek government bonds		—		—			—					—			259,233		259,233
Debt securities issued by Greek financial institutions		79		(45	)		—					—			336		370
Debt securities issued by foreign financial institutions		36,783		(4,008	)		—					—			—		32,775
Net Derivatives		26,138		4,242			—			2,994		(13,136	)		42,018		62,256
Available-for-sale securities		191,564		(12,875	)		(46,274	)				—			3,741,194		3,873,609
Greek government bonds		72,980		(12,884	)		(23,766	)				—			3,661,048		3,697,378
Debt securities issued by other governments and public sector entities		—		—			—					—			—		—
Corporate debt securities issued by companies incorporated in Greece		14,346		—			389					—			80,146		94,881
Corporate debt securities issued by companies incorporated outside Greece		104,238		9			(22,897	)				—			—		81,350
Other Assets		—		—			—			9,341					—		9,341
Deposits at fair value		623		114			—					(737	)		—		—

Gains and losses included in net income/loss are reported in Net trading loss, except for bonds' amortization of premium/discount which amounts to EUR 381 thousand for the year ended December 31, 2010 and to EUR 27 thousand for the year ended December 31, 2011 which is reported in Net interest income before provision for loan losses.

For the year ended December 31, 2011, changes in unrealized gains/(losses) of Level 3 financial instruments still held at the reporting date amounted to Nil, EUR 2,232 thousand and EUR 114 thousand for trading assets, derivatives and deposits respectively.

For the year ended December 31, 2010, changes in unrealized gains/(losses) of Level 3 financial instruments still held at the reporting date amounted to EUR (7,578) thousand, EUR 37,329 thousand and EUR 10 thousand for trading assets, derivatives and deposits respectively.

The transfers out of Level 3 in 2010 relate to securities that have been reclassified in the held-to-maturity portfolio and therefore are no longer measured at fair value.

We measure the performance of each of our business segments primarily in terms of "profit before tax". Profit before tax and the business segment information of the Group, set forth below, is derived from the internal management reporting system used by management to measure the performance of the business segments. Unlike financial accounting, there is no authoritative body of guidance for management accounting. The business segment information, set forth below, is based on the financial information prepared in accordance with IFRS. Accordingly, the format and information is presented primarily on the basis of IFRS and is not consistent with the consolidated financial statements prepared on the basis of US GAAP. A reconciliation is provided for the total amounts of segments' total profit/(loss) before tax with income/(loss) before income tax.

Retail banking includes all individual customers, professionals, small-medium and small sized companies (companies with annual turnover of up to EUR 2.5 million) in Greece. The Bank, through its extended network of branches, offers to its retail customers various types of loan, deposit and investment products as well as a wide range of other traditional services and products.

Global Markets and Asset management includes all treasury activities, private banking, asset management (mutual funds and closed end funds), custody services, private equity and brokerage.

The Group offers a wide range of insurance products through its subsidiary company, EH and other subsidiaries in SE Europe and Turkey.

The Group's banking activities in Turkey through Finansbank and its subsidiaries, include a wide range of traditional commercial banking services, such of commercial and retail credit, trade financing, foreign exchange and taking of deposits.

Includes proprietary real estate management, hotel and warehousing business as well as unallocated income and expense of the Group (interest expense of subordinate debt, loans to personnel etc.) and intersegment eliminations.

12-month period ended December 31, 2009	Retail Banking

	(EUR in thousands)
Net interest income		1,402,316		536,138		584,022		48,832		488,762		968,856		(62,611	)	3,966,315
Net fee and commission income/(loss)		166,243		72,270		95,488		3,872		94,040		228,546		(71	)	660,388
Other		(26,448	)	(67,169	)	268,099		149,498		17,873		96,860		11,679		450,392

Total operating income/(loss)		1,542,111		541,239		947,609		202,202		600,675		1,294,262		(51,003	)	5,077,095

Direct costs		(670,025	)	(53,509	)	(79,390	)	(182,192	)	(302,526	)	(523,994	)	(255,232	)	(2,066,868	)
Allocated costs and provisions		(798,813	)	(207,704	)	(190,290	)	(70,431	)	(189,914	)	(250,085	)	(51,042	)	(1,758,279	)
Share of profit of associates		—		—		(1,429	)	560		783		(190	)	393		117

Profit/(loss) before tax		73,273		280,026		676,500		(49,861	)	109,018		519,993		(356,884	)	1,252,065

Segment assets as at December 31, 2009
Segment assets		31,961,306		18,639,070		26,859,396		2,851,745		11,446,389		15,819,570		5,453,008		113,030,484
Tax assets																363,699

Total assets																113,394,183

Other Segment items
Depreciation, amortization⁽¹⁾		20,096		1,021		3,538		9,127		32,688		42,186		104,784		213,440

Credit provisions and other impairment charges		442,576		151,257		171,804		69,813		189,914		250,085		28,196		1,303,645
Non-current assets additions		14,814		634		11,741		8,289		62,445		58,782		115,725		272,430

12-month period ended December 31, 2010	Retail Banking

	(EUR in thousands)
Net interest income		1,368,231		621,918		472,177		54,066		461,836		1,053,634		116,095		4,147,957
Net fee and commission income/(loss)		127,788		77,841		37,556		8,054		102,260		262,723		(6,297	)	609,925
Other		(25,223	)	(73,770	)	(205,549	)	101,146		28,456		47,939		8,595		(118,406	)

Total operating income/(loss)		1,470,796		625,989		304,184		163,266		592,552		1,364,296		118,393		4,639,476

Direct costs		(683,711	)	(53,058	)	(77,823	)	(159,653	)	(300,583	)	(659,239	)	(160,099	)	(2,094,166	)
Allocated costs and provisions		(1,155,003	)	(259,477	)	(60,472	)	(37,603	)	(209,568	)	(144,586	)	(42,569	)	(1,909,278	)
Share of profit of associates		—		—		310		903		1,055		289		(959	)	1,598

Profit/(loss) before tax		(367,918	)	313,454		166,199		(33,087	)	83,456		560,760		(85,234	)	637,630

Segment assets as at December 31, 2010
Segment assets		30,079,448		18,957,278		29,793,880		3,052,124		10,506,104		20,619,183		7,129,220		120,137,237
Tax assets																607,368

Total assets																120,744,605

Other Segment items
Depreciation, amortization⁽¹⁾		19,746		1,291		5,968		9,698		35,483		53,633		101,441		227,260

Credit provisions and other impairment charges		796,593		204,037		39,865		36,987		209,528		144,586		18,731		1,450,327
Non-current assets additions		8,730		13,254		4,093		5,137		52,360		67,704		105,934		257,212

12-month period ended December 31, 2011	Retail Banking

	(EUR in thousands)
Net interest income		1,203,449		775,789		371,353		62,831		387,197		903,357		138,832		3,842,808
Net fee and commission income/(loss)		101,398		81,691		(106,766	)	6,935		94,218		313,622		2,751		493,849
Other		(25,192	)	(61,766	)	8,674		178,720		5,824		35,646		(106,603	)	35,303

Total operating income/(loss)		1,279,655		795,714		273,261		248,486		487,239		1,252,625		34,980		4,371,960

Direct costs		(687,823	)	(52,153	)	(65,095	)	(135,460	)	(293,350	)	(656,414	)	(249,029	)	(2,139,324	)
Allocated costs and provisions		(1,514,674	)	(2,151,714	)	(10,723,025	)	(633,054	)	(202,164	)	(147,058	)	(282,246	)	(15,653,935	)
Share of profit of associates		—		—		(2,592	)	1,051		1,193		94		1,433		1,179

Profit/(loss) before tax		(922,842	)	(1,408,153	)	(10,517,451	)	(518,977	)	(7,082	)	449,247		(494,862	)	(13,420,120	)

Segment assets as at December 31, 2011
Segment assets		27,368,430		16,195,725		24,903,725		2,041,287		9,856,192		20,671,864		4,280,798		105,318,021
Tax assets																1,551,968

Total assets																106,869,989

Other Segment items
Depreciation, amortization⁽¹⁾		18,759		1,688		4,848		8,895		36,261		54,593		101,187		226,231

Provision for loans impairment & advances		1,180,171		2,101,421		10,702,049		631,329		200,322		147,058		259,932		15,222,282
Non-current assets additions		5,517		10,805		35,736		3,112		18,872		80,175		66,134		220,351

Reconciliation of Profit before tax per IFRS reported for the segments to Income / (loss) before income tax expense per US GAAP

	2009

	(EUR in thousands)
Profit/(loss) before tax		1,252,065		637,630		(13,420,120	)
Dividend paid and transactions on financial instruments classified within equity under IFRS		186,289		(369	)	(39,252	)
Hedging of Interest Rate Risk and Net Investment Hedge		(430,170	)	(693,471	)	(68,125	)
Fixed assets measurement difference		26,810		8,733		38,322
Effective Interest Rate income recognition method		(88,820	)	(40,776	)	(12,457	)
Redeemable non-controlling interests		(1,282	)	29,636		15,117
Foreign exchange differences on AFS debt securities		28,800		(78,220	)	103,584
Difference of equity in earnings of investees		(21,515	)	1,797		16,074
Insurance reserves		(1,272	)	(67,508	)	(307,243	)
Impairment of goodwill		—		—		(298,241	)
Impairment of AFS securities		(120,538	)	(23,979	)	127,793
Bond's portfolio classification		—		—		(187,722	)
Other		(20,462	)	76,175		(15,864	)
US GAAP restatements		(180,035	)	(115,341	)	—

Income/(loss) before income tax		629,870		(265,693	)	(14,048,134	)

Breakdown of total assets, total revenue, income/(loss) before income tax expense and net income/(loss) attributable to NBG shareholders by geographical location

	Total assets

	(EUR in thousands)
12-month period ended December 31, 2009—As restated
Domestic		81,933,706	4,638,099		62,868		(56,499	)
Foreign		31,181,173	3,132,746		567,002		447,551

Group		113,114,879	7,770,845		629,870		391,052

12-month period ended December 31, 2010—As restated
Domestic		83,757,213	3,666,315		(896,685	)	(863,141	)
Foreign		34,974,665	3,150,344		630,992		508,369

Group		118,731,878	6,816,659		(265,693	)	(354,772	)

12-month period ended December 31, 2011
Domestic		71,599,902	(6,399,383	)	(14,511,072	)	(14,888,328	)
Foreign		31,867,333	3,172,016		462,938		348,660

Group		103,467,235	(3,227,367	)	(14,048,134	)	(14,539,668	)

In accordance with Greek Law 3655/2008, applicable from April 2008, the Bank's main pension plan, which was a defined-contribution plan, has been incorporated into the main pension branch of the state sponsored social security fund IKAE - TAM as of August 1, 2008. Pursuant to Greek Law 3655/2008, the Bank will contribute EUR 25.5 million per annum into IKA - ETAM for 15 years starting from December 2009. This legislation also prescribes that employer contributions made by the Bank will be reduced every three years in equal increments starting from 2013 from 26.5% until they reach 13.3% for employees who joined any social security plan prior to January 1, 1993. Employer contributions for employees who joined any social security fund post January 1, 1993, will remain at 13.3%.

In 2005 and 2006, the Hellenic Republic passed legislation permitting bank employee auxiliary pension schemes to merge with the new Insurance Fund of Bank Employees ("ETAT"). The relevant legislation provides that, in connection with the merger of auxiliary schemes with ETAT, the relevant employer shall make a payment to ETAT solely in an amount to be determined by an independent financial report commissioned by the Ministry of Finance pursuant to this legislation. Subsequently, in April 2006 the Bank applied under Greek Law 3371/2005, as amended, to merge its Auxiliary Pension Fund, a defined-contribution plan, into ETAT. Consequently, the Bank may have to contribute a significant amount to ETAT in relation to this merger.

The Bank's employees' Auxiliary Pension Plan provides for defined contributions to be made by the Bank at a rate of 9% of the employee's salary. Benefits paid are determined by years of service with the Bank and the employee's final pensionable pay. Under Greek Law 3371/2005 employees hired after January 1, 2005 are insured in the auxiliary social security fund IKA - ETAM. The Bank pays its contributions to IKA - ETAM since May 1, 2007.

As for the Bank's main pension plan, following legislation passed in April 2008, the post-retirement and health plan of EH has been incorporated into the main pension branch of the state sponsored social security fund IKA - ETAM as of August 1, 2008. Employer contributions made by EH will be reduced every three years in equal increments starting from 2013, until they reach 13.3%. Employer contributions for employees who joined any social security fund post January 1, 1993, will remain at 13.3%.

The London branch of the Bank and Group companies among which UBB, SABA, NBG Ethniki Asset Management Mutual Funds, EH, NBGI Private Equity Ltd and NBGI Private Equity Funds also make contributions to other defined contribution pension plans and funds for their employees.

Contributions by the Bank to the National Bank of Greece Health Plan (T.Y.P.E.T.) amount to 6.25% of employees' salaries. Employees' contributions amount to 2.5% of their salaries. Additional contributions are paid for insured members of the employees' families (such as spouse that does not work and children), and are increased further in the event that the insured spouse is employed or that members of the paternal family are also insured. Contributions of retired employees amount to 4% of their pensions, while additional contributions are paid for other insured members of their families. T.Y.P.E.T. offers health benefits to employees before and after their retirement, and to insured members of their families.

Total contributions to social security funds, state run plans and defined contribution plans for 2010 and 2011 were EUR 371.3 million and EUR 353.1 million respectively. As mentioned above, as of August 1, 2008, the Bank's pension plan and the pension branch of EH post-retirement and health plan were incorporated into IKA - ETAM and therefore ceased to exist as separate defined contribution plans.

Most NBG Group companies are required by local law to offer retirement indemnities to employees leaving service to retire. Such retirement indemnities are in the form of a lump-sum based usually on final salary and years of service, the calculation of which depends on the jurisdiction in which the company operates and the employee's profession (e.g. Greek law provides for different indemnities for salaried employees, wage earners and lawyers). In some cases, Group company regulations provide for additional benefits to employees above the statutory minimum.

Most EH and former Ethnokarta employees are entitled to benefits from Deposit Administration Fund (DAF) type policies, which offer lump sum benefits and pension benefits additional to those offered by social security funds or main pension plans. Such benefits are usually based on the employees' salary and years of service, and vary depending on the provisions of each policy. NBG Cyprus sponsors a Gratuity Plan for its employees, offering lump sum benefits based on final pay and years of service.

Benefits to employees' children are lump sum and are also based on the parents' salary and pension where applicable and on the age at which the child receives the benefits. Such benefits are offered to former Ethnokarta employees' children through a DAF type policy, as well as to the Bank's employees' children through a separate fund. Net periodic pension cost for these defined benefit plans

and termination indemnities includes the following components which are recognized in the income statement for the periods ended:

Cost of additional benefits in 2009 and 2010 include the voluntary retirement schemes of EH amounting to EUR 24.6 million and EUR 5.3 million, respectively. The amount in 2011 mainly relates to the additional cost of extra benefits in excess of the benefits provided for Finansbank and Vojvodjanska, amounting to EUR 3.4 million and EUR 2.9 million, respectively.

Weighted average assumptions used to determine the net periodic pension cost for the years ended December 31:

To set the expected long-term rate of return assumptions the Group uses forward looking assumptions. In particular, as regards Greek equities, the Group used the return on 10-year government bonds as at the end of the reporting period plus an equity risk premium based on a basket of company shares listed on the ATHEX. As regards Deposit Administration Fund assets, the guaranteed return interest rate was used.

The aggregated funding status recognized in the consolidated balance sheet is reconciled below as follows for the years ended December 31:

	2009

	(EUR in thousands)
Change in Projected Benefit obligation ("PBO"):
PBO, beginning of year		482,069		472,896		402,143
Service cost		15,918		17,546		14,010
Interest cost		21,695		22,519		19,434
Employee contributions		6,752		6,353		5,065
Actuarial loss/(gain)		14,016		(30,682	)	(37,680	)
Adjustment for disposal and other		(1,566	)	1,291		(3,137	)
Benefits paid from the Fund		(56,795	)	(68,744	)	(85,684	)
Benefits paid directly by the Group		(25,610	)	(25,552	)	(18,694	)
Settlements/Terminations/Curtailments		15,085		6,418		5,649
Prior service cost arising over last period		1,332		98		—

PBO, end of year		472,896		402,143		301,106

Employer contributions paid by the Group, are in excess of the EUR 15.8 million total expected contributions for funded plans for 2011.

The amounts recognized in the consolidated balance sheet as at December 31, are as follows:

The weighted-average assumptions used in determining the benefit obligation of such plans at December 31, are as follows:

Additional year-end information for pension plans with accumulated benefit obligations in excess of plan assets at December 31, are as follows:

The amounts recognized in accumulated "Other Comprehensive Income" at December 31, are as follows:

Other Changes in Plan Assets and Benefit Obligations recognized in Other comprehensive income / (loss) at December 31, are as follows:

The estimated amounts to be amortized from accumulated other comprehensive income into net periodic benefit cost during financial year 2012 are EUR 0.1 million of prior service cost and EUR 11.5 million of net actuarial loss.

The following table indicates actual and targeted plan asset allocation for the Group's funded defined benefit pension plans:

All equity securities are the Bank's own equity securities and "other" relate to deposits and assets of deposit administration fund policies issued by the Group's main insurance company EH. Equity securities are measured based on closing prices in an active market as at the measurement date (Level 1) and deposit administration fund assets and deposits are measured at the fund balance plus any accrued return to policyholders.

Benefit payments projected to be made from the defined benefit plans are as follows:

In 2012, the Group is expected to make EUR 8.7 million in contributions to funded plans and EUR 11.1 million in retirement indemnities.

on January 1 of the financial year during which such rights were granted until and including the first exercise date.

At the repeat General Meeting held on June 28, 2007, the shareholders of the Bank approved a new Group-wide stock option program for the Bank's executive directors, executive management and personnel of the Group (Program C). Program C is set to last eight years and expires in 2015. The stock options were to be granted up until 2010. The maximum number of new ordinary shares to be issued under Program C was originally set at 12.0 million and adjusted to approximately 12.5 million as a consequence of four for every hundred shares held issue as stock dividend, in accordance with the resolution passed at the repeat General Meeting held on May 15, 2008. The maximum number of options that could have been granted per year could not exceed 1% of the total number of ordinary shares outstanding. The strike price should be within the range of EUR 5.0 to 85% of the average market price of the ordinary shares within the time period from January 1 of the year the options are granted until October 31 of that same year. No stock options have been granted under this program.

The total number of share options granted, exercised and cancelled per Program, are analyzed as follows:

At December 10, 2010 the outstanding options of Program A 1st and 2nd grant expired.

All outstanding options of Program B would have been exercised between June 1, 2011 and June 10, 2011. After June 10, 2011, the unexercised options expired.

Details of the share options outstanding during the period to December 31, 2011 and December 31, 2010 are as follows:

The weighted average remaining contractual term of options outstanding is 0.5 and NIL years for 2010 and 2011 respectively.

No new options were granted in 2010 or 2011. The total fair value of options vested during 2010 and 2011 was EUR 4,814 thousand and EUR NIL.

The total expense recognized during 2009, 2010 and 2011 amounted to, EUR 8.3 million, EUR 10.5 million and EUR NIL respectively.

On May 25, 2007, the Annual General Meeting of the Shareholders of the Bank approved the distribution to the staff of 350,000 bonus shares to derive from the Bank's share capital increase by EUR 1,750 thousand through capitalization of profits. For a period of three years following their issuance (up to October 6, 2010), such new ordinary shares may be transferred only pursuant to approval granted at the General Meeting. The total expense recognized during 2009, 2010 and 2011 amounted to EUR 4,433 thousand, EUR 1,847 thousand and EUR NIL respectively.

NOTE 40: ACCUMULATED OTHER COMPREHENSIVE INCOME ATTRIBUTABLE TO NBG SHAREHOLDERS

The components of accumulated other comprehensive income, net of taxes, comprise:

At December 31, 2011, the EUR equivalent of the assets and liabilities, which are denominated in foreign currency, amounted to EUR 29,678,928 thousand (EUR 31,173,624 thousand for 2010 and EUR 27,067,368 thousand for 2009) and EUR 22,768,716 thousand (EUR 23,830,041 thousand for 2010 and EUR 20,759,384 thousand for 2009), respectively.

In our 2011 U.S. GAAP Financial Statements, certain comparative information has been restated as follows:

During 2010, in accordance with our policy, at that time, regarding transfers of investments between categories, and due to the crisis in the Greek bond markets, we reclassified certain trading securities to available-for-sale and to held-to-maturity at three different dates during the first five months of 2010 (January 1, March 31 and June 1, 2010). Although we are of the opinion that management exercised reasonable judgment in reaching the conclusion that it is possible to effect more than one reclassification in response to the single rare event of the Greek crisis, in 2011, we changed our policy to not allow more than one reclassification in response to a single rare event in line with industry practice in the United States of America (see Note 3). As such, we assessed the impact of reversing the reclassifications made after the initial reclassification in 2010. The reversal of these subsequent reclassifications resulted in a EUR 97.8 million increase of our net loss for the year ended December 31, 2010, including EUR 147.0 thousand related to foreign currency translation adjustment, which we believe is material and as a result, we restated our financial statements for the year ended December 31, 2010 to reverse all reclassifications performed after the initial reclassification in 2010.

As part of our work on the December 31, 2011 financial statements, we have revisited our assumptions and computation methodology relating to the impact on the Group of credit risk on derivatives (for both counterparty and own credit risk). In particular, we have changed our methodology to include the impact of credit risk on derivatives with (i) the Hellenic Republic, and (ii) counterparties with which we had in place CSAs under ISDA agreements that require daily placement of collateral, and the ISDA agreement provides for netting of asset and liability positions in case of default.

This has resulted in the identification of an adjustment of EUR 62.2 million, EUR (136.0) million and EUR 1.8 million in the net income/(loss) for the year ended December 31, 2008, 2009 and 2010, respectively, and an adjustment of EUR 62.2 million, EUR (73.8) million and EUR (71.9) million in total permanent equity. As a result, we restated our financial statements for the years ended December 31, 2009 and 2010, respectively, to record the bilateral CVA.

In addition, we have also made certain reclassifications to prior year amounts in order to conform to current year presentation.

The tables below present the impact of the above restatements on the balance sheets as at December 31, 2010 and statements of income and comprehensive income for the years ended December 31, 2009 and 2010.

	As of December 31, 2010

	As reported			Restatements			Reclassifications			As restated
	(EUR in thousands)
ASSETS
Money market investments		1,180,274			—			(1,180,274	)		—
Trading assets		774,374			1,062,834			948,114			2,785,322
Derivative assets		1,731,192			(96,922	)		—			1,634,270
Available-for-sale securities		14,512,870			(1,042,680	)		218,320			13,688,510
Held-to-maturity securities		3,611,797			(27,352	)		13,840			3,598,285
Other assets		3,771,924			20,696			—			3,792,620
TOTAL ASSETS		118,815,302			(83,424	)		—			118,731,878
LIABILITIES AND SHAREHOLDERS' EQUITY
Derivative liabilities		1,787,351			(4,881	)		—			1,782,470
Accounts payable, accrued expenses and other liabilities		3,327,044			(1,034	)		—			3,326,010
Total liabilities		109,997,122			(5,915	)		—			109,991,207
PERMANENT EQUITY:
NBG shareholders' equity
Accumulated surplus		2,182,661			(160,519	)		—			2,022,142
Accumulated other comprehensive loss		(3,468,821	)		83,225			—			(3,385,596	)
Total NBG shareholders' equity		7,730,352			(77,294	)		—			7,653,058
Non-controlling interest		821,846			(215	)		—			821,631
Total permanent equity		8,552,198			(77,509	)		—			8,474,689
TOTAL LIABILITIES AND EQUITY		118,815,302			(83,424	)		—			118,731,878

	Year ended December 31, 2009												Year ended December 31, 2010

	As reported			Restatements			Reclassif- ications			As restated			As reported			Restatements			Reclassif- ications			As restated
	(EUR in thousands)												(EUR in thousands)
Interest Income:
Securities available-for-sale		836,080			—			7,994			844,074			749,990			(63,966	)		14,938			700,962
Securities held-to-maturity		9,425			—			—			9,425			95,304			(1,218	)		809			94,895
Trading assets		185,720			—			11,984			197,704			134,356			60,586			34,258			229,200
Other		68,162			—			(19,978	)		48,184			91,678			—			(50,005	)		41,673
Total interest income		6,231,380			—			—			6,231,380			6,153,434			(4,598	)		—			6,148,836
Interest Expense:
Net interest income before provision for loan losses		3,786,265			—			—			3,786,265			4,088,199			(4,598	)		—			4,083,601
Net interest income after provision for loan losses		2,787,817			—			—			2,787,817			2,883,204			(4,598	)		—			2,878,606
Non-interest income/(loss):
Net trading loss		(87,096	)		(180,035	)		—			(267,131	)		(1,085,160	)		(160,162	)		—			(1,245,322	)
Total non-interest income/(loss) excluding gains/(losses) on investment securities		1,727,899			(180,035	)		—			1,547,864			802,523			(160,162	)		—			642,361
Net realized gains/(losses) on available-for-sale securities		(8,399	)		—			358,328			349,929			(23,957	)		49,419			89,497			114,959
Other-Than-Temporary-Impairment (of which NIL was recognized in OCI)		—			—			(358,328	)		(358,328	)		—			—			(89,497	)		(89,497	)
Net gains/(losses) on available for sale and held to maturity securities		(8,399	)		—			—			(8,399	)		(23,957	)		49,419			—			25,462
Total non-interest income/(loss)		1,719,500			(180,035	)		—			1,539,465			778,566			(110,743	)		—			667,823
Income/(loss) before income tax		809,905			(180,035	)		—			629,870			(150,352	)		(115,341	)		—			(265,693	)
Income tax (expense)/benefit		(220,624	)		44,038			—			(176,586	)		(61,634	)		19,323			—			(42,311	)
Net income/(loss)		589,281			(135,997	)		—			453,284			(211,986	)		(96,018	)		—			(308,004	)
Less: Net income attributable to the non-controlling interest		(62,232	)		—			—			(62,232	)		(56,075	)		9,307			—			(46,768	)
NET INCOME/(LOSS) attributable to NBG shareholders		527,049			(135,997	)		—			391,052			(268,061	)		(86,711	)		—			(354,772	)

	Year ended December 31, 2009									Year ended December 31, 2010

	As reported			Restatements			As restated			As reported			Restatements			As restated
	(EUR in thousands)									(EUR in thousands)
Net income/(loss)		589,281			(135,997	)		453,284			(211,986	)		(96,018	)		(308,004	)
Other comprehensive income/(loss) net of tax:
Foreign currency translation adjustments		(56,969	)		—			(56,969	)		191,150			154			191,304
Net (losses)/gains on available-for-sale securities:
Net unrealized holding (losses)/gains during the period, net of tax		212,057			—			212,057			(2,169,098	)		130,710			(2,038,388	)
Less: reclassification adjustment for net (gains)/losses included in net income, net of tax		(274,969	)		—			(274,969	)		(55,425	)		(38,547	)		(93,972	)
Total net (losses)/gains on available-for-sale securities		210,581			—			210,581			(2,154,010	)		92,163			(2,061,847	)
Total other comprehensive income / (loss), net of tax		177,844			—			177,844			(1,948,255	)		92,316			(1,855,938	)
Comprehensive income / (loss)		767,125			(135,997	)		631,128			(2,160,241	)		(3,701	)		(2,163,942	)
Less: Comprehensive (income) / loss attributable to the non-controlling interest		(60,364	)		—			(60,364	)		(59,514	)		215			(59,299	)
Comprehensive income / (loss) attributable to NBG shareholders		706,761			(135,997	)		570,764			(2,219,755	)		(3,486	)		(2,223,241	)
Earnings / (loss) per share
Basic EPS		0.73			(0.20	)		0.53			(0.45	)		(0.11	)		(0.56	)
Diluted EPS		0.73			(0.20	)		0.53			(0.45	)		(0.11	)		(0.56	)


(Mark One)
o		REGISTRATION STATEMENT PURSUANT TO SECTION 12(b) OR (g) OF THE SECURITIES EXCHANGE ACT OF 1934
OR
ý		ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934 For the fiscal year ended December 31, 2011
OR
o		TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934 For the transition period from to
OR
o		SHELL COMPANY REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934 Date of event requiring this shell company report

Title of each class		Name of each exchange on which registered

American Depositary Shares each representing one Ordinary Share		New York Stock Exchange
Ordinary Shares		New York Stock Exchange*
American Depositary Shares each representing one Series A Non-cumulative Preference Share		New York Stock Exchange
Series A Non-cumulative Preference Shares		New York Stock Exchange*

		Page

B.	Memorandum and Articles of Association	253
C.	Material Contracts	262
D.	Exchange Controls	262
E.	Taxation	263
F.	Dividends and Paying Agents	267
G.	Statements by Experts	267
H.	Documents on Display	268
I.	Subsidiary Information	268
J.	Relationship with the Hellenic Republic	268
Item 11	QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK	269
Item 12	DESCRIPTION OF SECURITIES OTHER THAN EQUITY SECURITIES	279
PART II		281
Item 13	DEFAULTS, DIVIDEND ARREARAGES AND DELINQUENCIES	281
Item 14	MATERIAL MODIFICATIONS TO THE RIGHTS OF SECURITY HOLDERS AND USE OF PROCEEDS	281
A.	General Effect of the Modifications on the Rights of Security Holders	281
Item 15	CONTROLS AND PROCEDURES	283
(a)	Disclosure Controls and Procedures	283
(b)	Management's Annual Report on Internal Control over Financial Reporting	284
(c)	Report of Independent Registered Public Accounting Firm	286
(d)	Changes in Internal Control over Financial Reporting	287
Item 16A	AUDIT COMMITTEE FINANCIAL EXPERT	287
Item 16B	CODE OF ETHICS	288
Item 16C	PRINCIPAL ACCOUNTANT FEES AND SERVICES	288
Item 16D	EXEMPTIONS FROM THE LISTING STANDARDS FOR AUDIT COMMITTEES	289
Item 16E	PURCHASES OF EQUITY SECURITIES BY THE ISSUER AND AFFILIATED PURCHASERS	289
Item 16F	CHANGE IN REGISTRANT'S CERTIFYING ACCOUNTANT	289
Item 16G	CORPORATE GOVERNANCE	289
PART III		291
Item 17	FINANCIAL STATEMENTS	291
Item 18	FINANCIAL STATEMENTS	291
Item 19	EXHIBITS	291
CONSOLIDATED FINANCIAL STATEMENTS AS OF DECEMBER 31, 2010 (AS RESTATED) AND 2011 AND FOR THE YEARS ENDED DECEMBER 31, 2009, 2010 (BOTH AS RESTATED) AND 2011		F-1
INDEX TO FINANCIAL STATEMENTS		F-2
REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM		F-3
Consolidated Balance Sheets		F-4
Consolidated Statements of Income and Comprehensive Income		F-5
Consolidated Statements of Shareholders' Equity		F-7
Consolidated Statements of Cash Flows		F-9
Notes to Consolidated Financial Statements		F-11

	Euro

Month	High		Low
November 2011		0.7551		0.7245
December 2011		0.7736		0.7415
January 2012		0.7885		0.7580
February 2012		0.7641		0.7428
March 2012		0.7678		0.7499
April 2012 (up to April 30, 2012)		0.7655		0.7498

Annual Period

2007	0.7297	0.5598
2008	0.6790	0.5246
2009	0.7170	0.4623
2010	0.7540	0.5009
2011	0.7178	0.4278
2012 (up to April 30, 2012)	0.7616	0.4247


		UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 20-F

		Page

Introduction		4
PART I		10
Item 1	IDENTITY OF DIRECTORS, SENIOR MANAGEMENT AND ADVISERS	10
Item 2	OFFER STATISTICS AND EXPECTED TIMETABLE	10
Item 3	KEY INFORMATION	10
A.	Selected Financial Data (Restated)	10
B.	Capitalization and Indebtedness	16
C.	Reasons for the Offer and Use of Proceeds	16
D.	Risk Factors	16
Item 4	INFORMATION ON THE COMPANY	41
A.	History and Development of the Company	41
B.	Business Overview	44
C.	Organizational Structure	109
D.	Property, Plant and Equipment	111
E.	Selected Statistical Data	112
Item 4A	UNRESOLVED STAFF COMMENTS	150
Item 5	OPERATING AND FINANCIAL REVIEW AND PROSPECTS	150
A.	Operating Results (Restated)	170
B.	Liquidity and Capital Resources	188
C.	Research and Development, Patents and Licenses	208
D.	Trend Information (Restated)	208
E.	Off-balance Sheet Arrangements	210
F.	Tabular Disclosure of Contractual Obligations	211
G.	Safe Harbor	211
Item 6	DIRECTORS, SENIOR MANAGEMENT AND EMPLOYEES	212
A.	Board of Directors and Senior Management	212
B.	Compensation	229
C.	Board Practices	229
D.	Employees	238
E.	Share Ownership	240
Item 7	MAJOR SHAREHOLDERS AND RELATED PARTY TRANSACTIONS	241
A.	Major Shareholders	241
B.	Related Party Transactions	243
C.	Interests of Experts and Counsel	243
Item 8	FINANCIAL INFORMATION (Restated)	243
A.	Consolidated Statements and Other Financial Information (Restated)	243
B.	Significant Changes	245
Item 9	THE OFFER AND LISTING	245
A.	Offer and Listing Details	245
B.	Plan of Distribution	248
C.	Markets	248
D.	Selling Shareholders	253
E.	Dilution	253
F.	Expenses of the Issue	253
Item 10	ADDITIONAL INFORMATION	253
A.	Share Capital	253

	Year ended December 31,

	2007 As restated		2008 As restated		2009 As restated		2010 As restated			2011
	(%)
Return on assets⁽¹⁾		1.66		0.97		0.41		(0.26	)		(12.27	)
Return on equity⁽²⁾		22.04		13.68		5.51		(4.48	)		—
Average equity to average assets⁽³⁾		7.19		6.45		6.45		6.60			1.44

	Year ended December 31,

Type of Capital Expenditure	2009			2010			2011
	(EUR in millions)
Interests in other companies		19.6	⁽¹⁾		133.3	⁽²⁾		104.8	⁽³⁾
Information technology and other electronic equipment		70.8			86.9			60.7
Land and buildings		41.1			60.2			96.5
Leasehold improvements		27.5			21.1			25.3
Furniture, fixtures, machinery and vehicles⁽⁴⁾		144.3			100.2			101.0

Total		303.3			401.7			388.3

	Year ended December 31,

Type of Divestiture	2009		2010		2011
	(EUR in millions)
Investments⁽¹⁾		17.9		0.1		—
Real estate⁽²⁾		21.0		6.8		15.5

	As at December 31,

	2010			2011
Mortgage lending (balances)		25.4	%		25.1	%
Consumer loans and credit cards (balances)		19.6	%		19.2	%
Core deposits⁽¹⁾		29.5	%		30.8	%

	As at

Interest rate on:	June 20, 2011			June 30, 2011			August 8, 2011			September 30, 2011
Prime lending rate for working capital		7.50	%		7.50	%		7.50	%		7.50	%
Prime lending rate for fixed assets		7.75	%		7.75	%		7.75	%		7.75	%
Personal loans		12.67	%		12.98	%		12.98	%		12.99	%
Open revolving credit facility		9.35-14.20	%		9.35-14.20	%		9.60-14.45	%		9.60-14.45	%

	As at

Interest rate on:	December 30, 2011			January 20, 2012			March 30, 2012
Prime lending rate for working capital		7.50	%		7.50	%		7.50	%
Prime lending rate for fixed assets		7.75	%		7.75	%		7.75	%
Personal loans		12.84	%		12.84	%		12.24	%
Open revolving credit facility		9.60-14.45	%		9.10-13.95	%		9.10-13.95	%

Funded exposure	Portugal

	(EUR in thousands)
Interest bearing deposits with banks⁽¹⁾		14,416	20,445	9,334	—	44,195
Loans⁽¹⁾		—	—	2,186	21,388	23,574

Total		14,416	20,445	11,520	21,388	67,769

Total exposure⁽¹⁾	Portugal

	(EUR in thousands)
Total funded exposure		14,416	54,592	23,309	11,520	27,061	130,898
Unfunded exposure to corporate and financial institutions		2,836	20	12,647	15,701	—	31,204

Total		17,252	54,612	35,956	27,221	27,061	162,102

	As at December 31, 2011

Banks	Loans to customers		Customer deposits
	(EUR millions)
1. National Bank of Greece		58,660		44,025
2. EFG Eurobank Ergasias		38,831		26,864
3. Alpha Bank		40,337		23,749
4. Piraeus Bank		30,896		18,334

	Year ended December 31, 2010

	Modified not TDR								TDRs
	Non- accruing		Accruing, less than 90 dpd		Accruing, more than 90 dpd		Total		Non- accruing		Accruing, less than 90 dpd		Accruing, more than 90 dpd		Total
	(EUR in thousands)
Residential mortgage		5,669		438,031		43,732		487,432		17,639		452,413		92,529		562,581
Credit cards		—		—		—		—		—		30		—		30
Other consumer		26,041		96,859		5,610		128,510		36,402		342,064		—		378,466
Small business loans		1,211		118,989		—		120,200		25,451		345,348		—		370,799
Other commercial		582		13,118		—		13,700		12,641		94,642		—		107,283

Total		33,503		666,997		49,342		749,842		92,133		1,234,497		92,529		1,419,159

	Year ended December 31,

	2010						2011
	Total consumer loans		Total commercial loans		Total PPLs		Total consumer loans		Total commercial loans		Total PPLs
	(EUR in thousands)
Domestic loans		1,162,795		3,676,780		4,839,575		1,234,742		3,687,659		4,922,401
Foreign loans		321,575		740,337		1,061,912		426,861		836,366		1,263,227

		1,484,370		4,417,117		5,901,487		1,661,603		4,524,025		6,185,628

	Year ended December 31,

Components of allowances for loan losses	2010		2011		2010/2011 Change
	(EUR in thousands)						%
Specific allowances		564,598		2,811,450		2,246,852		398.0
Coefficient analysis		106,415		198,160		91,745		86.2
Homogeneous analysis		1,451,790		2,424,218		972,428		67.0
Foreign loans		1,052,602		1,116,807		64,205		6.1

Total loan loss allowance		3,175,405		6,550,635		3,375,230		106.3

Rating agency	Long-term foreign currency deposit rating⁽¹⁾	Short-term foreign currency deposit rating⁽¹⁾	Outlook for the Bank's ratings	Financial strength of the Bank— Individual⁽¹⁾	Subordinated debt of the Bank⁽¹⁾	Preferred stock of the Bank⁽¹⁾

Moody's	Caa2	Not Prime	Negative	E	Ca	Ca
Standard & Poor's	CCC	C	Negative	—	CC	—
Fitch	B-	B	Stable	WD	—	C

Issuer	Description	Type of collateral	Issue date	Maturity date	Cancelled date		Interest rate

Eterika Plc	Asset Backed Floating Rate Notes—Class A	Commercial loans	July 31, 2008	June 2035	May 2010	975.0	Paid quarterly at a rate of three month Euribor plus 30 bps
Eterika Plc	Asset Backed Floating Rate Notes—Class B	Commercial loans	July 31, 2008	June 2035	May 2010	365.0	Paid quarterly at a rate of three month Euribor plus 250 bps

Series number	Issue date	Cancellation date	Original nominal amount EUR

Fourth Series	March 18, 2010	November 30, 2010	1.5 billion	1,000.0
First Series	November 28, 2008	May 6, 2011	1 billion	650.0
Second Series	November 28, 2008	May 6, 2011	1 billion	800.0
Fifth Series	May 11, 2010	May 6, 2011	1 billion	350.0
Second Series	November 28, 2008	June 2, 2011	1 billion	150.0
First Series	November 28, 2008	June 20, 2011	1 billion	300.0
Fifth Series	May 11, 2010	June 20, 2011	1 billion	650.0
First Series	November 28, 2008	August 3, 2011	1 billion	50.0	⁽¹⁾
Second Series	November 28, 2008	August 3, 2011	1 billion	50.0	⁽¹⁾

Issuer	Type	Issue date	Maturity date	Currency			Interest rate

Finansbank	Amended Facility Agreement⁽⁵⁾	November 30, 2011	November 2012	EUR	210.6	—	Paid quarterly at LIBOR plus 0.7%.
Finansbank	Amended Facility Agreement⁽⁵⁾	November 30, 2011	November 2012	USD	220.5	—	Paid quarterly at LIBOR plus 0.7%.



Chairman	Apostolos Tamvakakis	Chief Executive Officer
Member	Alexandros Tourkolias	Deputy CEO
Member	Anthimos Thomopoulos	Deputy CEO
Member	Leonidas Theoklitos	Deputy CEO
Member	Paul Mylonas	G.M. of Strategy and Governance
Member	Agis Leopoulos	G.M. of International Activities
Member	Michael Oratis	G.M. of Risk Management
Member	Leonidas Fragkiadakis	G.M. of Treasury and Global Markets
Member	Charalampos (Babis) Mazarakis	Chief Financial Officer

	2010

	(EUR in thousands)
Financial instruments whose contract amounts represent credit risk:
Commitments to extend credit:⁽¹⁾
Commercial and personal		17,878,471	14,584,516
Commercial real estate		3,472	—
Residential real estate		326,940	94,602
Commercial letters of credit		539,790	589,924
Standby letters of credit and financial guarantees written		6,684,876	5,970,422

Total		25,433,549	21,239,464

	Less than 1 year

	(EUR in thousands)
Time deposits⁽¹⁾		33,274,251	659,820	15,139	8,031	33,957,241
Long-term debt⁽¹⁾		376,665	733,971	2,537,978	90,252	3,738,866
Operating lease obligations		87,842	146,038	114,112	140,856	488,848
Insurance reserves⁽²⁾		581,983	407,555	337,254	1,434,049	2,760,841
Pension liability⁽³⁾		36,497	29,346	36,931	121,969	224,743
Put options of non-controlling interest holdings⁽⁴⁾		26,006	261,065	—	—	287,071
Purchase obligations⁽⁵⁾		5,103	—	—	—	5,103

Total		34,388,347	2,237,795	3,041,414	1,795,157	41,462,713



Chairman	Petros Sabatacakis	Financial expert
Vice chairperson	Alexandra Papalexopoulou Benopoulou
Member	Stefanos Vavalidis
Member	Georgios Zanias
Member	Maria (Marily) Frangista



Chairperson		Alexandra Papalexopoulou Benopoulou
Member		Vassilios Rapanos
Member		H.E. the Metropolitan of Ioannina Theoklitos
Member		Spyridon Theodoropoulos

Country		Average number of Group employees for the year-ended December 31, 2011⁽¹⁾

Greece			14,419
Turkey			12,615
Bulgaria			2,990
Serbia			2,133
Romania			1,567
FYROM			1,048
Cyprus			311
Albania			275
Egypt			224
South Africa			172
United Kingdom			99
Malta			23

Total			35,876

Division		Average number of Group employees for the year-ended December 31, 2011

Commercial and retail banking			33,260
Insurance			1,241
Investment banking			216
Asset management			94
Other Group companies			1,065

Total			35,876

	Group

	Program A 1^st grant			Program A 2^nd grant			Program B
Total share options granted per Program		2.992.620			496.500			3.014.100
Adjustments due to share capital increases		120.315			35.632			162.720
Number of share options exercised		(1.426.883	)		(53.475	)		(798.590	)
Number of share options expired and cancelled		(1.686.052	)		(478.657	)		(2.378.230	)

Outstanding balance		—			—			—

Stock options			Weighted average exercise price			Aggregate Intrinsic value

			(EUR)			(EUR)
Outstanding at January 1, 2011	1,998,496			20.45	—		—
Expired during the year	(1,998,496	)		20.45	—		—

Outstanding at December 31, 2011	—			—	—		—

Vested but not exercised at December 31, 2011	—			—	—		—

	As at April 27, 2012

	Common shares			Total shares
Legal Entities and Individuals Outside Greece		27.4	%		21.4	%
Domestic Private Investors		48.6	%		37.9	%
Domestic pension funds		16.4	%		12.8	%
Other domestic public sector related legal entities and Church of Greece		7.5	%		5.8	%
Treasury shares		0.1	%		0.0	%

Total common shares		100.0	%		77.9	%

Series A Preference shares listed on the NYSE					0.1	%
Greek government preference shares (Greek Law 3723/2008)					22.0	%

Total Share Capital					100.0	%

Year	High (date)	Low (date)

2007	42.65 (on October 31)	31.93 (on January 2)
2008	42.13 (on January 8)	10.74 (on December 22)
2009	27.79 (on October 15)	8.26 (on March 9)
2010	17.09 (on January 8)	6.04 (on December 27)
2011	7.76 (on February 9)	1.47 (on November 1)
2012 (until April 30)	2.97 (on February 8)	1.31 (on January 10)

Quarter	High (date)	Low (date)

Q1 2010	17.09 (on January 8)	10.96 (on February 9)
Q2 2010	12.82 (on April 1)	7.48 (on June 29)
Q3 2010	10.28 (on August 4)	7.17 (on September 30)
Q4 2010	8.58 (on October 13)	6.04 (on December 27)
Q1 2011	7.76 (on February 9)	5.64 (on January 10)
Q2 2011	6.39 (on April 7)	4.38 (on June 16)
Q3 2011	5.36 (on July 7)	2.58 (on September 26)
Q4 2011	2.55 (on October 3)	1.47(on November 1)