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:

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

American Depositary Shares, each representing one ordinary share
Ordinary shares*

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

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, 2015, the close of the period covered by the annual report:

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 (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 and all references in this Annual Report to the "Greek government" or "Hellenic Republic" are to the Hellenic Republic. In addition, no part of any website, except as expressly incorporated, forms part of this Annual Report.

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", "Euro" 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 at 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 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 = 0.8740, as certified for customs by the Federal Reserve Bank of New York (the "Noon Buying Rate") on Friday, April 29, 2016. The respective rates for the South African rand, Macedonian dinar, Bulgarian leva, Romanian Lei and Serbian dinar are: South African rand 14.2355 per US$1.00, Macedonian dinars 54.8420 per US$1.00, Bulgarian leva 1.7365 per US$1.00, Romanian lei 3.9262 per US$1.00 and Serbian dinars 107.2553 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 for each of the five years ended December 31, 2011, 2012, 2013, 2014 and 2015 and for the current annual period through April 29, 2016. 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.

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. The following factors are among those that may cause actual results to differ materially from our forward-looking statements.

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 at the date of this Annual Report.

Progress in finalizing the first review of the Third Program was made in the Eurogroup meeting of May 9, 2016 following the introduction of legislation by the Greek government consisting of a policy package of new fiscal measures amounting to 3 per cent. of GDP, including pension and personal income tax reforms (source: Eurogroup Statement on Greece, May 9, 2016), and a further agreement with the Eurogroup on additional legislation and additional actions to be taken by the Greek government for completing the review by the end of May 2016. The Eurogroup stated that "it stands ready to support the disbursement of the second tranche of the ESM program" amounting to EUR 5.7 billion in June 2016 and/or early in the third quarter of 2016 following full implementation of the actions agreed between the Greek government and the Eurogroup. These developments are expected to contribute to an improvement in financial conditions in Greece in the third quarter of 2016. The Eurogroup has also stated that it stands ready to consider, if necessary, "possible additional debt measures aiming at ensuring that Greece's refinancing needs are kept at sustainable levels in the long-run. These measures will be conditional upon full implementation of measures agreed in the context of the Third Program, and will be considered after the completion of the first review, once all prior actions have been fully implemented" (Eurogroup Statement on Greece, May 9, 2016).

The following information as at, and for the years ended, December 31, 2011 through 2015 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. generally accepted accounting principles ("U.S. GAAP") financial statements and the notes thereto as at December 31, 2014 and 2015 and for the years ended December 31, 2013, 2014 and 2015 (the "U.S. GAAP Financial Statements") included elsewhere in this Annual Report.

Our selected financial and operating data for the twelve months ended December 31, 2015 have been prepared stating separately continuing operations from discontinued operations, the latter relating to Finansbank in accordance with ASC 205-20 "Discontinued Operations". The selected historical financial data for the years 2014, 2013, 2012 and 2011 have been restated accordingly. Long lived assets held for sale and the liabilities directly associated with long lived assets comprise Finansbank A.S., the NBGI Private Equity Funds and Astir Palace Vouliagmenis S.A and Astir Marina Vouliagmenis S.A.:

	Year ended December 31,

	2011			2012			2013			2014			2015			2015⁽¹⁾
	EUR			EUR			EUR			EUR			EUR			USD
	(in millions, except per share data)
CONSOLIDATED STATEMENT OF INCOME DATA
Continuing operations
Total interest income		4,232			3,400			2,824			2,580			2,256			2,580
Total interest expense		(1,645	)		(1,598	)		(1,262	)		(979	)		(760	)		(870	)

Net interest income before provision for loan losses		2,587			1,802			1,562			1,601			1,496			1,710
Provision for loan losses		(3,555	)		(2,059	)		(633	)		(1,835	)		(3,298	)		(3,773	)

Net interest income after provision for loan losses		(968	)		(257	)		929			(234	)		(1,802	)		(2,063	)

Non-interest income / (loss)
Credit card fees		50			45			40			39			48			55
Service charges on deposit accounts		26			26			28			29			26			30
Other fees and commissions		304			288			311			312			274			314
Net trading loss		(1,711	)		(1,105	)		114			(1,091	)		215			246
Equity in earnings of investees and realized gains/(losses) on disposals		9			13			10			8			5			6
Income from insurance operations⁽⁵⁾		728			580			514			508			477			546
Other income		322			83			277			165			129			147

Total non-interest income / (loss) excluding gains / losses on investment securities		(272	)		(70	)		1,294			(30	)		1,174			1,344

Net gains/(losses) on available-for-sale securities		(50	)		318			189			96			2			2
OTTI of available-for-sale securities and held-to-maturity securities (of which NIL was recognized through AOCI)		(9,174	)		(410	)		(286	)		(6	)		(36	)		(41	)

Net gains / (losses) on investment securities		(9,224	)		(92	)		(97	)		90			(34	)		(39	)

Total non-interest income / (loss)		(9,496	)		(162	)		1,197			60			1,140			1,305

	Year ended December 31,

	2011			2012			2013			2014			2015			2015
	EUR			EUR			EUR			EUR			EUR			USD
	(in millions, except per share data)
Non-interest expense
Salaries, employee benefits and voluntary early retirement schemes		(1,108	)		(1,021	)		(1,128	)		(818	)		(806	)		(922	)
Depreciation of premises and equipment		(85	)		(74	)		(69	)		(67	)		(65	)		(74	)
Amortization of intangible assets		(62	)		(67	)		(58	)		(53	)		(59	)		(68	)
Impairment of goodwill		(419	)		(123	)		(9	)		(58	)		(221	)		(253	)
Insurance claims, reserves movements, commissions and reinsurance premiums ceded		(999	)		(457	)		(531	)		(256	)		(306	)		(350	)
Summary other⁽²⁾		(1,352	)		(901	)		(890	)		(1,153	)		(1,183	)		(1,354	)

Total non-interest expense		(4,025	)		(2,643	)		(2,685	)		(2,405	)		(2,640	)		(3,021	)

Income / (loss) before income tax		(14,489	)		(3,062	)		(559	)		(2,579	)		(3,302	)		(3,779	)
Income tax expense		(354	)		(50	)		(20	)		(63	)		(42	)		(48	)

Income / (loss) from continuing operations		(14,843	)		(3,112	)		(579	)		(2,642	)		(3,344	)		(3,827	)
Income / (loss) from discontinuing operations		336			595			648			169			(5,123	)		(5,862	)

Net income / (loss)		(14,507	)		(2,517	)		69			(2,473	)		(8,467	)		(9,689	)
Less: Net income attributable to the non-controlling interest		(32	)		(20	)		(32	)		(4	)		3			3

Net income / (loss) attributable to NBG shareholders		(14,539	)		(2,537	)		37			(2,477	)		(8,464	)		(9,686	)
Basic and diluted EPS—Net income / (loss) from continuing operations⁽³⁾⁽⁴⁾		(1,174.64	)		(245.66	)		(6.24	)		(12.67	)		(2.89	)		(3.31	)
Basic and diluted EPS—Net income / (loss)⁽³⁾⁽⁴⁾		(1,149.32	)		(200.46	)		0.40			(11.90	)		(9.41	)		(10.77	)

	As at December 31,

	2011			2012			2013			2014			2015			2015⁽¹⁾
	EUR			EUR			EUR			EUR			EUR			USD
							Restated			Restated
	(in millions)
CONSOLIDATED BALANCE SHEET DATA
ASSETS
Cash and due from banks		1,283			1,674			1,343			2,107			1,436			1,643
Deposits with Central Bank		2,037			1,063			1,204			1,065			1,059			1,212
Securities purchased under agreements to resell		386			75			38			24			10			11
Interest bearing deposits with banks		3,284			2,831			3,240			2,711			2,432			2,783
Trading assets		2,922			5,406			3,008			2,386			2,484			2,842
Available-for-sale securities		5,821			4,096			4,480			3,319			6,227			7,125
Held to maturity securities		1,002			356			9,376			9,337			9,292			10,632
Loans		62,681			57,760			57,664			56,068			54,996			62,924
Less: Allowance for loan losses		(6,105	)		(6,650	)		(7,137	)		(8,792	)		(11,775	)		(13,473	)

Net loans		56,576			51,110			50,527			47,276			43,221			49,451
Long-lived assets classified as held for sale		21,678			25,970			25,082			29,286			24,759			28,328
Summary other assets⁽²⁾		8,478			8,575			8,479			10,650			9,012			10,312

Total assets		103,467			101,156			106,777			108,161			99,932			114,339

LIABILITIES AND SHAREHOLDERS' EQUITY
Deposits excluding interbank deposits		47,164			45,127			50,087			50,329			42,785			48,953
Interbank deposits		32,259			32,106			22,049			15,777			24,779			28,351

Total deposits		79,423			77,233			72,136			66,106			67,564			77,304
Securities sold under agreements to repurchase		742			375			3,499			3,587			101			116
Long-term debt		2,244			1,199			1,460			2,385			1,596			1,826
Contingently convertible debt		—			—			—			—			2,040			2,334
Liabilities directly associated with long-lived assets classified as held for sale		15,649			19,077			19,032			22,719			23,650			27,060
Summary other liabilities⁽³⁾		9,314			9,064			8,034			10,927			9,311			10,653

Total liabilities		107,372			106,948			104,161			105,724			104,262			119,293

Redeemable non-controlling interest—Temporary equity		283			257			250						—			—
PERMANENT EQUITY
Preferred stock, (25,000,000 shares of par value of EUR 0.30 each at 2010, 2011 and 2012 and 12,639,831 shares of par value of EUR 0.30 each at 2013 and 2014 and 70,000,000 shares of par value EUR 5.00 at 2010 and 270,000,000 shares of par value EUR 5.00 each at 2011, 2012, 2013 and 2014, respectively)		1,358			1,358			1,354			1,354			—			—
Common stock		4,780			4,780			719			1,060			2,744			3,140
Additional paid-in capital		4,090			4,079			17,858			19,918			21,740			24,874
Accumulated other comprehensive income/(loss)		(1,940	)		(1,283	)		(2,596	)		(2,547	)		(2,994	)		(3,426	)
Treasury stock, at cost		—			—			(2	)		—			(1	)		(1	)
Accumulated surplus / (deficit)		(12,547	)		(15,037	)		(15,006	)		(17,387	)		(25,851	)		(29,578	)

Total NBG shareholders' equity / (deficit)		(4,259	)		(6,103	)		2,327			2,398			(4,362	)		(4,991	)

Non-controlling interest		71			54			39			39			32			37

Total liabilities and equity		103,467			101,156			106,777			108,161			99,932			114,339

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 "deposits excluding interbank deposits", "total assets excluding long-lived assets classified as held for sale" and "total liabilities excluding liabilities directly associated with long-lived assets classified as held for sale".

The Group defines "deposits excluding interbank deposits" as "Total deposits" deducting "Interbank deposits". The Group uses this non-GAAP financial measure in order to enhance the comparability of its financial performance between reporting periods, particularly in light of increased funding from the Eurosystem resulting from the pressure experienced by the Hellenic Republic in its public finances.

The Group defines "total assets excluding long-lived assets classified as held for sale" as "Total assets" deducting "Long lived assets classified as held for sale" and "total liabilities excluding liabilities directly associated with long-lived assets classified as held for sale" as "Total liabilities" deducting "Liabilities directly associated with long-lived assets classified as held for sale".

The Group uses the non-GAAP financial measures "total assets excluding long-lived assets classified as held for sale" and "total liabilities excluding liabilities directly associated with long-lived assets classified as held for sale" in order to enhance the comparability of its financial performance between reporting periods and because excluded long-lived assets classified as held for sale and liabilities directly associated with those assets are not indicative of Group's future performance.

These financial measures are not 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. For a reconciliation of these metrics to the reported assets and liabilities, see the table below.

	As at December 31,

EUR (in millions)	2013		2014		2015
Total deposits		72,136		66,106		67,564
Less: Interbank deposits		22,049		15,777		24,779
Deposits excluding interbank deposits		50,087		50,329		42,785
Total assets		106,777		108,161		99,932
Less: Long lived assets classified as held for sale		25,082		29,286		24,759
Total assets excluding long-lived assets classified as held for sale		81,695		78,875		75,173
Total liabilities		104,161		105,724		104,262
Less: Liabilities directly associated with long-lived assets classified as held for sale		19,032		22,719		23,650
Total liabilities excluding liabilities directly associated with long-lived assets classified as held for sale		85,129		83,005		80,612

On June 23, 2011, the Bank's General Meeting of Shareholders 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 (the "U.S. 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 (the "Greek State Preference Shares"), in accordance with the Bank's Articles of Association, Greek Law 3965/2011 and the provisions of article 44a in combination with articles 42c and 43 of the Company Law 2190/1920, which prohibit the payment of dividends in the absence of sufficient distributable funds.

No dividend distribution to any class of shares was approved by the annual Ordinary General Meeting of the Bank's Shareholders held on June 28, 2012, in compliance with the provisions of articles 44a, 42c and 43 of Greek Company Law 2190/1920.

No dividend distribution to any class of shares was approved by the repeat annual Ordinary General Meeting of the Bank's Shareholders held on July 12, 2013, in compliance with the provisions of articles 44a, 42c and 43 of Greek Company Law 2190/1920.

No dividend distribution to any class of shares was approved by the annual Ordinary General Meeting of the Bank's Shareholders held on June 26, 2014, in compliance with the provisions of articles 44a, 42c and 43 of Greek Company Law 2190/1920.

No dividend distribution to any class of shares was approved by the annual Ordinary General Meeting of the Bank's Shareholders held on June 19, 2015, in compliance with the provisions of articles 44a, 42c and 43 of Greek Company Law 2190/1920.

The Bank does not expect to propose the distribution of dividends for the year ended December 31, 2015 to the annual Ordinary General Meeting of the Bank's Shareholders, in compliance with provisions of articles 44a of Greek Company Law 2190/1920.

Following the issuance of the CoCos on December 9, 2015 (see Note 25), the Bank is not allowed to pay dividends to holders of its ordinary shares if the Bank's Management has decided not to pay interest to holders of the CoCos on the previous interest payment date.

If you are considering purchasing our ordinary shares or American Depositary Receipts ("ADRs"), you should carefully read and consider 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 or ADRs may decline, resulting in a loss of all or a part of any investment in our ordinary 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.

Recessionary pressure and uncertainty resulting from the Hellenic Republic's economic crisis have had and may continue to have an adverse impact on our business, results of operations and financial condition.

For the financial year ended December 31, 2015, 79.0% of our net interest income before provision for loan losses and as at December 31, 2015, 87.0% of our loans, were derived from our domestic operations. In addition, our holdings of EUR 3.2 billion of Greek government bonds and Greek treasury bills represented, as at December 31, 2015, 4.3% of our total assets excluding long-lived assets classified as held for sale and 18.4% of our trading and investment debt securities. Accordingly, our financial condition and our results of operations are heavily dependent on macroeconomic and political conditions prevailing in Greece. Additionally, as we are in the process of disposing of our 99.81% stake in Finansbank A.S. together with our 29.87% stake in Finans Leasing S.A. (together, the "Turkish Operations") (see "—Risks Relating to Our Business—The sale of Finansbank pursuant to the Revised Restructuring Plan will result in the loss of a business which has historically represented a significant portion of our consolidated operations and profit"), our future operations will be less diversified and our remaining operations will have a significantly greater exposure to Greece as a percentage of our overall business.

Following seven years of recession in the period 2008-2015, the still challenging economic and business environment in Greece has had and continues to have significant adverse consequences on the Group. The Greek economy re-entered recession in 2015 following a mild recovery in 2014, mainly due to uncertainty, the significant external liquidity shortages and the need for implementing new fiscal adjustment measures following the agreement on a new program for financial support in August 2015. In view of the severe economic uncertainty that appeared to threaten the continued membership of the Hellenic Republic in the European Monetary Union and the EU, the Greek government officially requested financial assistance from the European Union on July 10, 2015 (Source: European Commission's proposal for a council implementation decision on granting short term European Union financial assistance to Greece under a new program from the European Stability Mechanism ("ESM"). On August 19, 2015 the Hellenic Republic entered into a Memorandum of Understanding ("MoU") with the European Commission and the ESM for the provision of further stability support accompanied by a third economic adjustment program (the "Third Program").While the Third Program was intended to set the groundwork for a sustainable reduction in uncertainty—by effectively minimizing the "Grexit risk" in the summer of 2015—and a gradual normalization of liquidity conditions, the short-term

implementation challenges and macroeconomic risks remain significant. The Greek economy showed signs of considerable weakening in the second half of 2015, with tight liquidity conditions and additional fiscal drag from a first set of fiscal measures implemented in this period weighing on economic performance. Recent surveys of coincident and forward looking indicators suggest a bottoming out of business confidence at the very low levels experienced during the third quarter of 2015, but consumer confidence showed further signs of significant weakening (Source: EL.STAT. and European Commission Business and Consumer Surveys, April 2016), exemplifying the downside risk for economic activity in early 2016.

In particular, economic and financial conditions in Greece have been particularly challenging in 2015 and continue to affect economic performance in the first months of 2016 as:

Such conditions have resulted in and continue to exert pressures on private sector consumption, delay investments and capital spending decisions and, together with capital controls, weaken liquidity-generation capacity of the economy and discourage the return of withdrawn bank deposits to the system. Our business activities are dependent on the level of banking, finance and financial products and services it offers, as well as customers' capacity to repay their liabilities. In particular, the levels of savings and credit demand are heavily dependent on customer confidence, employment trends and the availability and cost of funding. 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.

Prospective new fiscal revenue generating measures and an increase in effective burden from value added, personal and corporate taxes could impose further constraints on economic activity and result in weakening prospects for growth in future years as a result of conditions imposed by the Institutions as part of the first review of the Third Program. For example, reforms adopted by the Greek government pursuant to the Third Program include increases in value-added tax ("VAT") rates applicable to a range of goods and services since July 2015 and higher effective corporate and personal income taxes, which are generally associated with a dampening of economic and consumer behavior and may have the effect of slowing growth when fully applied in 2016, and the introduction of a contingency adjustment mechanism, to be implemented by the end of -May 2016, that is intended to result in automatic spending cuts if there is objective evidence of a failure to meet the annual primary surplus targets in the program (3.5% of GDP in the medium-term).

The above measures and/or other fiscal measures—such as increases indirect taxes, increases in employers and employees social security contributions, additional government spending cuts and raising of other financial levies—which are going to be implemented under medium-term fiscal strategy for 2016-2018 could have an adverse effect on the Group and the financial sector as a whole. For further information, see "—The implementation of the Third Program may not lead to the intended return of the economy to sustainable growth, which could result in weakening prospects for the Group." These risks are compounded by a significant tightening in liquidity conditions and the impact of capital controls on the banking system, as described under "—Low liquidity and the imposition of capital controls in Greece has had, and may continue to have, a material adverse impact on the economy and the banking sector, including our business and prospects" and "—Domestic political uncertainty has weighed on financial and economic conditions generally, and there can be no assurances that further developments will not further exacerbate political uncertainty", respectively.

The implementation of the Third Program may not lead to the intended return of the economy to sustainable growth, which could result in weakening prospects for the Group.

Over the past five years, the Hellenic Republic has undertaken significant structural measures intended to restore competitiveness and promote economic growth in Greece through the financial support programs agreed with the International Monetary Fund (the "IMF"), the ECB and the EU (collectively, the "Institutions"). A program was initially agreed in May 2010 (the "First Program") and was renewed by way of a second economic adjustment program in March 2012 and further amended pursuant to Eurogroup decisions of November 2012 (the "Second Program"). The First Program and the Second Program established, through related financial facility agreements signed between the Hellenic Republic, the participating Eurozone countries, the European Financial Stability Facility ("EFSF") and the IMF, financing intended to fully cover the Hellenic Republic's external financing needs until the end of 2014, conditioned on the implementation of a number of fiscal adjustment policies and growth enhancing structural reforms. On December 8, 2014, the Eurogroup announced a "technical extension" of the EU side of the Second Program to the end of February 2015. On February 20, 2015, the Eurogroup agreed to a four month extension of the Master Financial Assistance Facility Agreement ("MFFA") underpinning the Second Program.

The First Program and the Second Program were conditional on the adoption by the Hellenic Republic of fiscal austerity measures designed to significantly reduce public spending that were widely perceived as leading to rising social and political opposition, while failing to achieve the long-term sustainability of Greece's debt burden. The success of these measures has been questioned as government debt as a percentage of GDP was projected to remain very high (approaching 179% of GDP in 2015) according to the latest preliminary projections of European Commission (Source: European Commission, Winter, February 2016, forecasts). Pressures arising from the fiscal effort to achieve a large primary budget surplus in the Greek government budget, accumulated policy fatigue and potential emergence of social tensions, delays in the implementation of the structural reform

agenda of these programs as regards the provision of additional concessions to ensure public debt sustainability (such as lower interest rate and longer maturities of EFSF and bilateral loans from other Eurozone member states to Greece), delays in the implementation of official creditors' commitments and uncertainty over sufficient medium-to-long term financing for the country have had an increasingly adverse effect on economic and financial conditions in Greece over the past five years leading up to the summer of 2015.

The inability of the Greek government and the Institutions to agree on a modified version of economic conditions with less austerity and the provision of additional financing under a revised version of the Second Program, culminated in the expiry of the Second Program on June 30, 2015, without a replacement financial assistance program in place to secure necessary funding for the Hellenic Republic to be able to meet its imminent external payment obligations in July and August 2015. On June 30, 2015, the Hellenic Republic defaulted on its payment obligations to the IMF in respect of a EUR 1.5 billion repayment, which has since been paid.

In response to the fear of an outright bank run the Greek government imposed a "bank holiday" on June 28, 2015 that lasted until July 19, 2015 and applied specific restrictions on banking and other financial transactions (jointly referred to as "capital controls" (Source: Bank of Greece, Act of Legislation, June 28, 2015), with a view to protecting financial and macroeconomic stability. On August 19, 2015 the Hellenic Republic entered the MoU with the European Commission and the ESM for the provision of further stability support accompanied by the Third Program.

The Third Program is intended to cover the Hellenic Republic's external financing needs until mid-2018 and to encourage the return to a sustainable growth path for the country. Nevertheless, it remains uncertain whether the Greek economy will grow sufficiently to ease the financing constraints of the Hellenic Republic without further debt relief from the EU and the IMF. Such debt relief would likely involve a significant degree of direct or indirect official sector involvement, to reduce Greece's debt obligations to the IMF and the Eurozone. However, as the provision of additional debt relief to the Hellenic Republic by the official borrowers is conditioned on successful progress in program implementation (Eurogroup Statement on Greece, May 9, 2016), delays or inefficiencies in implementation of agreed measures and reforms could increase economic and financial uncertainty, and/or increase the risk of a default on the Hellenic Republic's debt and lead to the reemergence of scenarios of suspension of Greece's participation in the euro area.

Even if the Third Program framework successfully leads to debt relief, confidence may not be restored in the Greek banking sector, and the Greek economy may not achieve the sustained and robust growth that is necessary to ease the current financial constraints of the Hellenic Republic, restore the internal liquidity generation capacity of the Greek economy or re-open the private financial markets in the near-to-medium term. Consequently, the application of the Third Program may not result in returning the Greek economy to a path of sustainable growth or bring the ongoing domestic deleveraging and deflation processes to an end. For example, pursuant to the initiative to close the fiscal gap for the period from 2015 to 2018, an increase in VAT rates was effected in the third quarter of 2015 across a range of goods and services. As sales tax increases generally have the effect of subduing spending and consumption, this is expected to impose additional downside risks on the economic outlook and financial conditions in Greece. Additionally, it is possible that various interest groups and factions may raise objections to measures of the Third Program with which they disagree—for instance, changes to sales tax rates—and such disagreement may cause delays or deviations from the measures that have been agreed in principle under the Third Program.

If the Third Program fails to restore growth to the Greek economy or proves to temper economic growth as a result of austerity policies or measures which are more stringent than is optimal to facilitate sustainable growth, the resultant low or negative economic growth could have a material adverse impact on the Bank's business, results of operations, financial condition or prospects.

Moreover, if additional corrective measures are required to close Greece's fiscal gap, this could impose further constraints on economic activity and result in weakening prospects for growth in future years. In this context in the Eurogroup meeting of May 9, 2016 the Greek government agreed with the euro area partners the introduction of a contingency adjustment mechanism, which is planned to be legislated by end-May to ensure that spending cuts would be automatically implemented if there is objective evidence of a failure to meet the annual primary surplus targets in the program (3.5% of GDP, in the medium-term). Activation of such spending cuts in the future could give rise to further recessionary pressure and political tensions.

Domestic political uncertainty has weighed on financial and economic conditions generally, and there can be no assurances that further developments will not further exacerbate political uncertainty.

Economic and financial conditions in Greece remain very sensitive to the progress in implementation of the Third Program and to international financial conditions, as evidenced by the increase in Greek government bond yields since late 2015. A significant driver of this deterioration in mid-2015 was the protracted and ultimately unsuccessful series of renegotiations of the Second Program between the Hellenic Republic and the Institutions that took place from the third quarter of 2014 to the second quarter of 2015.

After a presidential election held by the Greek parliament on December 29, 2014, in which no presidential candidate was able to secure the majority vote required to become elected, the parliament was dissolved and a "snap" parliamentary election was held on January 25, 2015. This election resulted in the formation of a new coalition government led by Syriza. The newly-elected Greek government attempted to renegotiate Greece's relationship with its official creditors, agree a more gradual fiscal adjustment, with less austerity measures, and secure additional debt relief from the official sector. These negotiations delayed the implementation of remaining structural reforms under the Second Program and the disbursement of related official financing and contributed to an increase of uncertainty.

In June 2015, the Greek Government announced that a public referendum would be held on July 5, 2015, on a provisional draft financial assistance plan proposed by the Eurogroup. In combination with a standstill in the negotiations with lenders and the Hellenic Republic being in arrears on its indebtedness held by the IMF from the end of June 2015, the Institutions decided to let the Second Program expire on June 30, 2015, while the ECB imposed a freeze on the Greek banking system's level of access to the Eurosystem liquidity provision mechanisms, including the ELA. Capital controls were imposed from June 28, 2015 in conjunction with a bank holiday that lasted until July 19, 2015 while a final round of negotiations with official lenders ultimately led to the agreement on, and signing of, the Third Program. In September 2015, a new snap election—the second in 2015—led again to a coalition Government led by Syriza.

The above developments translated into downward pressure on economic activity indicated by GDP trends in the second half of 2015, including a contraction of 1.2% year-over-year (source: EL.STAT, Quarterly National Accounts Press Release, February 2016). Moreover negotiations for the conclusion of the first review of the Third Program that started in January 2016 were not completed by the date of this Annual Report and consequently, related program financing has not been disbursed according to the original planning.

Uncertainty about the Hellenic Republic's ability to meet the medium-term conditions to assistance under the Third Program and attain debt sustainability and economic growth remains high. This in turn has continued to exert pressures on the liquidity position of the Greek banking system, as well as on Greek banks' portfolio quality, and this uncertainty is likely to continue for some time, which could have a material adverse effect on the Bank and other financial institutions whose profits are derived from the country's banking sector. See "—Continuing high outflows of funds from customer deposits

could cause an increase in the Group's costs of funding and if such outflows were to continue it could have a material adverse effect on our operating results, financial condition and liquidity prospects."

The Third Program also includes objectives designed to restore fiscal sustainability, restore growth, competitiveness and investment and modernize the efficiency of the public sector and the governance of institutions. As of the date of this Annual Report, it is uncertain whether the majority of these measures will be timely implemented or on what terms, as described under Item 5.D., "Trend Information—The Macroeconomic Environment in Our Markets—Private Sector Initiative and Economic Stabilization and Support Programs—The Third Program." Failure to implement the agreements made by the government under the Third Program (for example, if required measures are not passed in the Greek parliament), or continuing uncertainty relating to the Hellenic Republic's ability to implement necessary reforms or to meet other commitments related to the conditionality of the Third Program, may lead to termination of financial support provided by the EU and increase again the risk of sovereign default and/or reactivate scenarios of a potential suspension of Greece's euro membership.

Furthermore, the potential occurrence of a new round of political uncertainty in the event of a standstill in program implementation or the emergence of new difficulties in finalizing future reviews of the economic program or providing the additional debt relief outlined in the agreement between Greece and its official creditors /or delays or deficiencies in program implementation may revive strains in the relationship between the Greek government and the Institutions, which would in turn have a material adverse impact on the implementation of the Third Program and its ability to facilitate economic and financial stability and eventual economic growth in Greece.

Low liquidity and the imposition of capital controls in Greece has had, and may continue to have, a material adverse impact on the economy and the banking sector, including our business and prospects.

The liquidity position in the Greek banking system remains weak, reflecting a sizeable contraction of the domestic deposit base between November 2014 and July 2015 of EUR 52.7 billion which led to a sharp increase in reliance on ECB and national central bank funding (together comprising the "Eurosystem"), Eurosystem funding for Greek banks peaked at EUR 126.6 billion in July 2015 and stood at EUR 107.5 billion and EUR 101.5 billion as at December 31, 2015 and March 31, 2016, accordingly (EUR 56.0 billion as at December 31, 2014).

In part as a response to the substantial contraction in deposits, on June 28, 2015, a bank holiday was declared for all credit institutions operating in Greece. This bank holiday was in place until July 19, 2015, during which time the Hellenic Capital Market Committee ("HCMC") also declared the temporary closure of the ATHEX for trading in securities. The Greek government imposed numerous restrictions on financial transactions during and after this period, many of which—including capital controls—continue to apply. The currently applicable capital controls involve, among other limitations, a maximum cumulative weekly withdrawal limit of EUR 420 per depositor, continued prohibitions on the transfer of capital and cash outside of Greece, the prohibition on the opening of new accounts except for specified permitted purposes and restrictions on the unwinding of certain financial arrangements (such as the prepayment of loans or accounts not established to serve certain specified purposes). See Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—Capital Controls applying to banks operating in Greece". The imposition of such controls had a negative impact on the perceived health of the banking system, and the continuation and eventual lifting of the remaining restrictions pose risks to Greek banks, including the Bank, and the Greek banking sector, notably increased capital outflows.

The imposition of capital controls and the bank holiday led to increased economic and business uncertainty, which has reduced business activity in Greece as firms have been restricted in their ability to import, receive loans from banks, conduct other commercial activities and maintain their creditworthiness and business activities abroad. In addition, consumers and businesses have been and

continue to be reluctant to make large purchases or investments, which has contributed and continues to contribute to a further devaluation of financial and real estate assets. These events have and could continue to have a material adverse effect on our financial condition, results of operations or prospects, as our results are dependent upon levels of stability in the Greek economy, a return to growth of the Greek banking sector and increased levels of lending, in particular business lending.

If the capital controls prove ineffective in containing capital outflows or generating domestic liquidity—if for example non-financial firms and individuals exhaust their monthly withdrawal limits or take advantage of existing liquidity limits for external trade financing and transfer their remaining liquid assets abroad—and/or if the capital controls are withdrawn too soon, there can be no assurance that we and other Greek banks would not experience high and increasing outflows of funds from depositors and businesses. Eventual lifting of the capital controls, even if timely, may create the conditions for significant outflows of deposits from the Greek banking system, which could threaten our ability to continue as a going concern, and could result in systemic instability across the Greek banking system.

The continued imposition of capital controls harms our prospects, as such controls restrict the ability of our customers to produce and accumulate savings and/or reduce further their debt servicing capacity, weaken healthy demand for credit, and discourages private capital inflows to the economy—including the repatriation of profits from Greek business activity abroad. Households have been deferring spending and hoarding cash for precautionary purposes, which have created and will continue to create further pressure on domestically-oriented industries, especially in discretionary categories of goods and services. The contraction in domestic demand is creating additional risks for the performance of domestically-oriented micro- and small-size businesses in the near future, including manufacturers, retailers, providers of services to domestic businesses and households. This risk is particularly high for more cyclical industries and in business segments which are more dependent on domestic demand and operating in discretionary and capital goods production. Although we have taken steps to address and limit the impact of the bank holiday and related capital controls on our customers and continue the provision of liquidity to the extent permitted, there can be no assurance that our response will be sufficient. The consequences of the continued application of capital controls could have a material adverse effect on our business, financial condition or results of operations, could result in our customers being unable to service their debts, may further reduce liquidity in the market and may increase the our level of loans past due by more than 90 days.

The Greek capital controls and other restrictions, including ATHEX trading holiday in June and July of 2015, have also had an impact on the price, liquidity and volatility of the common shares, as described further under "Risks Relating to the Markets and the ordinary shares—Our share price has been, and may continue to be, volatile".

We are currently restricted in our ability to obtain funding in the capital markets and are heavily dependent on the ECB and Bank of Greece, through the ELA, for funding, which access could be affected by changes in the ECB and the Bank of Greece rules relating to the eligibility and valuation of collateral used for funding such as Greek government bonds and guarantees.

The ongoing economic crisis in Greece has adversely affected our credit risk profile, preventing us from obtaining funding in the capital markets, and increased the cost of such funding and the need for additional collateral requirements in repo contracts and other secured funding arrangements, including those with the ECB and the Bank of Greece. Concerns relating to the ongoing impact of current economic conditions and difficulties and delays in the implementation of the Third Program by the Greek government are expected to continue to restrict our ability to obtain funding in the capital markets in the near and medium term. See Item 5.B "Liquidity and Capital Resources—Credit Rating".

On February 4, 2015, the ECB announced its decision to revoke the waiver affecting marketable debt instruments issued or fully guaranteed by the Hellenic Republic, which had previously allowed these instruments to be used in Eurosystem monetary policy operations, despite the fact that they did not fulfill minimum credit rating requirements. As of the date of this Annual Report the waiver has not been reinstated. There can be no assurance if and when the waiver will be reinstated. As a holder of Greek government debt, the revocation of this waiver has limited our eligible ECB collateral pool and therefore our access to ECB funding.

Reflecting the loss of access to the capital markets as well as the sharp decline in deposits, we were required to increase our Eurosystem funding, including ELA funding from the Bank of Greece, considerably during the first half of 2015. As at June 30, 2015, Eurosystem funding was EUR 27.6 billion, of which EUR 17.6 billion was ELA, an increase of EUR 13.3 billion over Eurosystem funding of EUR 14.2 billion (NIL ELA) as at December 31, 2014. Our liquidity position improved during the second half of 2015, primarily as a result of our share capital increase and related transactions (the "2015 Recapitalization") that were completed in December 2015 (described further in Item 5.B., "Liquidity and Capital Resources—Sources of Capital and Liquidity—2015 Recapitalization"), and as a result we are less reliant on Eurosystem funding. As at December 31, 2015, our Eurosystem funding totaled EUR 24.0 billion, of which EUR 11.5 billion was ELA, and total eligible collateral amounted to EUR 8.4 billion (cash value), of which EUR 0.1 billion was collateral eligible for funding with the ECB and EUR 8.3 billion was collateral that could be posted in order to draw liquidity from ELA. Furthermore, as at May 4, 2016, Eurosystem funding has decreased to EUR 22.1 billion, of which EUR 11.1 billion was ELA, while additional financial assets of an estimated cash value EUR 6.2 billion (cash value) were available for further liquidity of which EUR 0.1 billion was collateral eligible for funding with the ECB and EUR 6.1 billion was collateral that could be posted in order to draw liquidity from ELA. However, although we have continued to decrease our Eurosystem funding since December 31, 2015, there can be no assurance that our funding needs will continue to be met by or that we will continue to have access to Eurosystem funding in the future. In addition, if the Greek government decides to lift the capital controls, deposit outflows could have a material impact on our deposit base and on the amount of our ECB and ELA eligible collateral, which could have a material adverse impact on our liquidity and our ability to access Eurosystem funding in the future, which may in turn threaten our ability to continue as a going concern.

Furthermore, the liquidity we are able to access from the ECB or ELA may be adversely affected by changes in ECB and Bank of Greece rules relating to collateral. If the ECB or the Bank of Greece were to revise their respective collateral standards, remove asset classes from being accepted, or increase the rating requirements for collateral securities such that these instruments were not eligible to serve as collateral with the ECB or the Bank of Greece, our access to these facilities could be further diminished and the cost of obtaining such funds could increase. In addition the amount of funding available from the ECB or the Bank of Greece is tied to the value of the collateral we have provided, which may decline. If the value of our assets declines, then the amount of funding we can obtain from the ECB or the Bank of Greece will be proportionally limited. Further increases in past due loans will also negatively affect the available collateral used for funding purposes (see also below"—Deteriorating asset valuations resulting from poor market conditions may adversely affect our business, results of operations and financial condition and may limit our ability to post collateral for funding purposes from Eurosystem").

Deteriorating asset valuations resulting from poor market conditions may adversely affect our business, results of operations and financial condition and may limit our ability to post collateral for funding purposes from Eurosystem.

We are a large provider of loans in Greece and we have significant exposure to the financial performance and creditworthiness of companies and individuals in Greece and South East Europe and

the mixed global economic recovery, the economic crisis in Greece and the relatively weak recovery of economies in South East Europe in recent years has resulted in an increase in our past due loans and significant changes in the fair values of our financial assets.

A substantial portion of our loans and advances 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. Significant adjustment in residential valuations started in 2009 and continued at a rapid pace from 2010 to the end of 2015 (with prices having fallen by 41.5% by the end of the fourth quarter of 2015) compared to their peak in 2008, according to the Bulletin of Conjectural Indicators published by the Bank of Greece, January to February 2016. The average pace of decline in house prices slowed during 2015 to 5.1% year-over-year in 2015 from 7.4% year-over-year in 2014, but downside risks remain significant against a relatively high effective tax burden and a still sizeable backlog of unsold houses. Household disposable income stabilized in 2014 and the first half of 2015 but showed signs of new weakening in the second half of 2015 (source: ELSTAT Sectoral Accounts data fourth quarter of 2014 and fourth quarter 2015). The pressure on prices from the high stock of unsold houses, weak credit flows and a still high unemployment rate of 24% in December 2015 (ELSTAT Press release, Monthly LFS data, December 2015) are likely to delay market stabilization further leading to a new reduction of residential and commercial valuations and may increase mortgage delinquencies further in 2016. According to Bank of Greece data (Source: Governor's Annual Report, February 2016), the non-performing exposures ("NPE") ratio of mortgage portfolios at a banking system level increased to 39.8% in September 2015 from 35.6% in December 2014.

A further decline in economic activity, or a deterioration of economic conditions in any industry in which our borrowers operate or in the market of the collateral, may result in the value of collateral falling below the outstanding principal balance for some loans, particularly those disbursed in the years prior to the crisis. A decline in the value of collateral, or our inability to obtain additional collateral, may require us to establish additional allowance for loan losses. The ongoing pressures on financial and real estate asset valuations means that the value of assets collateralizing our secured loans, including residential and other real estate, is likely to decline further. Such a decline could result in further impairment of the value of our loan assets or an increase in the level of our past due loans, either of which will limit our ability to post collateral to obtain ELA and ECB funding. Furthermore, a protracted period of poor economic conditions will materially and adversely affect the liquidity, business activity and financial condition of our borrowers, which in turn will led to further increases in our past due loan ratios, impairment charges on loans and other financial assets, and decreased demand for borrowings in general and additional pressure on financial and real estate asset valuations could translate into a further deterioration of the economy. Our non-accruing loans ratio has increased from 31.2% at December 31, 2013, to 34.4% at December 31, 2014 and to 18.3% at December 31, 2015. See "Risks Relating to Our Business—The increase of non-accruing loans may have a negative impact on our operations in the future." If the financial performance and creditworthiness of our borrowers worsens or does not improve, the quality of our loan portfolio will continue to deteriorate, which would have a material adverse impact on our financial condition and results of operations.

In addition, any failure to recover the expected value of collateral in the case of foreclosure, or our inability to initiate foreclosure proceedings due to national legislation, may expose us to losses which could have a material adverse effect on our business, results of operations and financial condition. While the Greek suspension of every enforcement action due to capital controls was lifted by the October 29, 2015 official announcement of Ministry of Justice, Transparency and Human Rights on November 2, 2015 a prolonged lawyers', bailiffs' and notaries' strike commencing in January 12, 2016 has restrained us from proceeding to enforcement, seizures and auctions of any real estate.

An increase in financial market volatility or adverse changes in the marketability of our assets could impair our ability to value certain of our assets and exposures. The value we ultimately realize

will depend on the fair value determined at that time and may be materially different from 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 adequacy.

Continuing high outflows of funds from customer deposits could cause an increase in our costs of funding and if such outflows were to continue it could have a material adverse effect on our operating results, financial condition and liquidity prospects.

Historically, our principal source of funds has been customer deposits, the majority of which are from our Greek depositor base. However, during the first half of 2015, the Bank suffered significant deposit outflows, which were stopped by the imposition of the bank holiday and the capital controls as from June 28, 2015. 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 and the Bank of Greece under their exceptional terms. As at December 31, 2015 there was a decrease in the Group's domestic deposits excluding interbank deposits of 15.9% compared to 2014. More specifically, the Group in Greece incurred a net outflow of EUR 8.4 billion between January 1, and December 31, 2015. Furthermore, future deposit levels in Greece may be adversely affected as a result of the transposition of the BRRD in Greece, which, inter alia, require the participation of a financial institution's unsecured depositors in case of resolution proceedings of such institution.

The ongoing availability of customer deposits to fund our loan portfolio is subject to changes due to factors outside our 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 reducing the availability of funds for deposits and the availability and extent of deposit guarantees. 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. Any of these factors separately or in combination could lead to a sustained reduction in our ability to access customer deposit funding on appropriate terms in the future, which would impact our ability to fund its operations and meet its minimum liquidity requirements and have a material adverse effect on our results of operations, financial condition and prospects.

We intend to redeem the contingent convertible securities (the "CoCos") issued to the HFSF as part of the 2015 Recapitalization, with the proceeds from the sale of Finansbank, but there can be no assurance that the sale of Finansbank will close or that regulatory approval for the repayment of the CoCos will be obtained.

On November 3, 2015, the Board of Directors approved a capital action plan to address the capital shortfall identified by the 2015 Comprehensive Assessment. These capital actions included, among others, the disposal of our entire stake in Finansbank A.S. and was subsequently also included as a commitment in our Revised Restructuring Plan. On December 21, 2015, the Board of Directors approved the divestiture to Qatar National Bank of the Group's Turkish Operations). The Finansbank Transaction was approved by our shareholders at an Extraordinary General Meeting on January 18, 2016. Closing of the Finansbank Transaction is subject to approval from: (i) the Turkish Banking Regulation and Supervision Agency (already received); (ii) the Qatar Central Bank (already received); (iii) the Turkish Competition Board (already received approval; reasoned decision pending to be received); (iv) the Turkish Capital Markets Board (already received) and (v) the Turkish Treasury (already received). The Finansbank Transaction is expected to close on or before June 30, 2016.

As part of the 2015 Recapitalization, we issued EUR 2,029 million of CoCos to the HFSF, which bear an interest rate of 8.00% per annum. We announced on December 22, 2015 our intention to repay the full principal amount of the CoCos with proceeds from the disposal of Finansbank. The agreed consideration for the transaction amounts to EUR 2,750 million. In addition, QNB will repay upon closing the USD 910 million of subordinated debt that NBG has extended to Finansbank. As repayment of the CoCos is subject to the rules and regulations governing the recapitalization by the HFSF of the Bank and other relevant regulatory approvals we can provide no assurance that such approvals will be obtained in a timely fashion or at all. In addition, there can be no assurance that the Finansbank Transaction will close on the expected timeline or at all, which could result in further delays in repayment of the CoCos. The CoCos bear interest at a rate of 8.00% per annum for seven years, and at a floating rate thereafter, which is significantly higher than our historical average cost of borrowing. As a result, any inability to repay, within our contemplated timetable or at all, the CoCos following the closing of the Finansbank Transaction will require us to pay high rates of interest on a significant part of our capital, which could have a material adverse impact on our results of operations, financial condition and capital. In addition, while the CoCos are outstanding, we may not pay any dividends on our ordinary shares unless we have already paid interest on the CoCos in respect of the most recent coupon payment (see "—The Bank does not currently pay dividends to its shareholders and may not be able to pay dividends in the future"). Furthermore, in the event that our Common Equity Tier 1 capital ratio ("CET1 Ratio"), calculated on a consolidated basis or a solo basis, falls below 7%, we will be required to convert the CoCos into ordinary shares (see Item 4.B., "Business Overview—Regulation and Supervision of Banks in Greece—Provision of Capital Support by HFSF—Provision of Capital Support"), which would result in the dilution or elimination of the interests of ordinary shareholders and would grant the HFSF majority control over us.

Although the Bank successfully raised the capital it needed in December 2015, there can be no assurance that this level of capital will be sufficient if economic conditions in Greece do not improve or if they deteriorate further.

Although we completed the 2015 Recapitalization, there can be no assurance that we will not require further capital in future periods in order to continue to meet our capital adequacy requirements. This would be the case particularly if business conditions in Greece do not improve or if they deteriorate further. Further deterioration of market conditions in Greece and internationally may continue to adversely affect the quality of our loan and investment portfolio, which will comprise primarily Greek loans following the disposal of Finansbank. The potential deterioration in the credit quality of our assets may exceed current expectations, lead to additional impairments in the future and generate the need for additional capital which may significantly dilute our ordinary shareholders. There can be no assurance that any future capital increase will not be executed by means of a rights offering which would further dilute our ordinary shareholders or that it will not be accompanied by a recapitalization in reliance on the HFSF Law or the BRR Law, each of which may also result in the bail-in of our ordinary shareholders.

Furthermore, we anticipate that new stress tests analyzing the strength and resilience of the European banking sector will continue to be carried out by national and supranational regulatory authorities in future periods. Loss of confidence in the European banking sector following the announcement of any future stress tests, a market perception that any such tests are not sufficiently rigorous or capital shortfalls identified by such stress tests in respect of us or the Greek banking sector as a whole, could also have a negative effect on our cost of funding and may thus have a material adverse effect on our results of operations and financial condition. Furthermore, the results of any future stress tests may result in a requirement for us to raise additional capital.

In December 2015, in connection with the Capital Plan and our application for State Aid (see Item 4.A "History and Development of the Company—The Capital Plan"), burden sharing measures were

applied to convert into ordinary shares outstanding classes of certain of our then existing debt instruments issued or guaranteed by us, all subordinated liabilities (including preference shares issued by us) and certain senior unsecured liabilities which were not mandatorily preferred by law pursuant to the HFSF Bail-in Tool. This mandatory conversion resulted in significant dilution to our ordinary shareholders. Should further capital be required in the future and, if we are unable to raise such capital, the Greek National Resolution Authority or other relevant authorities may, if the relevant conditions set out in the BRR Law are satisfied at the relevant time, exercise the BRRD Point of Non Viability Power ("BRRD PONV Power") and/or the BRRD Bail-in Tool and/or any other resolution tool as determined by the Greek National Resolution Authority or other relevant authorities at the relevant time. As a result of the 2015 Recapitalization, the CoCos, which are convertible into ordinary shares, are currently our only outstanding capital instruments that could be subject to conversion at the point of non viability or in resolution. Therefore, the exercise of the BRRD PONV Power and/or the BRRD Bail-in Tool or any other resolution tools would result in significant dilution or elimination of the interests of ordinary shareholders.

The Group may need additional capital and liquidity as a result of regulatory changes.

The Bank and the Group are required by the SSM and the regulators in the Hellenic Republic and other countries in which they undertake regulated activities to maintain minimum levels of capital and liquidity. To the extent the Group has regulated activities elsewhere in the European Economic Area ("EEA") it will remain subject to the minimum capital requirements prescribed by the regulatory authority in the Hellenic Republic, except in jurisdictions where it has regulated subsidiaries, which will be subject to the capital requirements prescribed by local regulatory authorities. In jurisdictions in which it has branches, including within the EEA, the Bank is also subject to the regulatory capital and liquidity requirements of such jurisdictions. The Bank, its regulated subsidiaries 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 may increase in the future, or the methods of calculating capital resources may change. Likewise, liquidity requirements may have come under heightened scrutiny, and may place additional stress on the Group's liquidity demands in the jurisdictions in which it operates. Changes in regulatory requirements may require the Group to raise additional capital. Directive 2013/36/EU (the "CRD IV Directive") and the EU Capital Requirements Regulation (together, the "CRD IV") which incorporate the key amendments that have been proposed by the Basel Committee on Banking Supervision (known as "Basel III") have been directly applicable to all EU member states (the "EU Member States") since January 1, 2014, but some changes under CRD IV will be implemented gradually (see "—Our business is subject to increasingly complex regulation which may increase our compliance costs and capital requirements", below). Implementing regulations in Greece under the CRD IV may impose higher capital requirements, such as higher prudential buffers, which may require the Group to raise further capital. See Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—Capital Requirements/Supervision."

As of 2016 European banks must comply with the rules under the BRRD relating to the Minimum Requirement for Own Funds and Eligible Liabilities ("MREL"). These rules require that a financial institution hold at all times sufficient loss absorbing instruments to ensure that shareholders and creditors primarily bear losses in the event of the resolution of the financial institution in order to facilitate the orderly resolution of the institution. MREL includes own funds (including, for the avoidance of doubt, ordinary shares) as well as eligible liabilities (as defined in the BRRD) and is expressed as a percentage of the total liabilities and own funds of the institution. The BRRD does not mandate a minimum for MREL, but instead provides for a case by case assessment of the MREL for each institution or group, against a minimum set of criteria prescribed by the rules made under the BRRD and applied by the national resolution authorities in the case of financial institutions which are not part of the European Union banking union (the "Banking Union") or by the Single Resolution

Board (the "SRB") in the case of financial institutions which are part of the Banking Union. The European Banking Authority ("EBA") published draft regulatory technical standards which further define the way in which resolution authorities/the SRB are to calculate MREL but there remains significant uncertainty as to how these will be operationally implemented or the amount of MREL banks will be required to hold. In addition, the BRRD requires the EBA to prepare and submit a report reviewing the implementation of MREL at national level by the end of 2016, which might lead to further changes in the rules and levels set by national authorities. The Group may not hold sufficient MREL as at the date such requirement becomes effective and/or raising such levels could be prohibitively costly, which could have a material adverse effect on the Group's financial condition. Although a breach of the MREL rules will not trigger automatic penalties, such a limitations on distributions, the consequences of such a breach are uncertain as the relevant supervisory authorities will assess the appropriate response which may range from extensive discussions with the regulators to the application of certain of the tools available under the BRRD (in the event the breach is such that the bank is non-viable or enters into resolution).

As at December 31, 2015, the Group's CET1 Ratio was 14.5%. If the Group does not satisfy the minimum capital ratio requirements in the future, it may be subject to the measures that the Bank of Greece or the SSM can take pursuant to the CRD Law and Regulation 1024/2013, including appointment of a commissioner to the Bank (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—Bank Recovery and Resolution Directive").

If the Bank is required to raise further capital but is unable to do so on acceptable terms, the Group may be required to further reduce the amount of the Bank's risk-weighted assets and engage in further disposal of core and other non-core businesses, which may not occur on a timely basis or achieve prices which would otherwise be attractive to the Bank. Any failure to maintain minimum regulatory capital ratios could result in administrative actions or other sanctions, which in turn may have a material adverse effect on the Bank's operating results, financial condition and prospects. If the Bank is required to strengthen its capital position, it may not be possible for the Bank to raise additional capital from the financial markets or to dispose of marketable assets. That could potentially lead to further requests for State Aid pursuant to the provisions of Greek Law 3864/2010, as amended by Greek Law 4340/2015 (the "HFSF Law") in the circumstances permitted under the BRR Law and the HFSF Law, which could result in the dilution or elimination of the interests of ordinary shareholders, and which may result in the HFSF exercising full control over the Bank.

The Bank's wholesale borrowing costs and access to liquidity and capital may be negatively affected by, and there may be further material adverse consequences of, any future 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 a below-investment-grade rating. The credit rating of the Hellenic Republic was lowered by all three major 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 February 2012. Specifically, the Hellenic Republic's credit rating was lowered to Selective Default-SD by Standard & Poor's ("S&P") (February 27, 2012), to Restricted Default-RD by Fitch Ratings Ltd. ("Fitch") (March 9, 2012) and to C by Moody's Investor Services, Inc. ("Moody's") (March 2, 2012).

In 2013 and 2014, all three rating agencies upgraded the Hellenic Republic's ratings in view of improvements in the general economic outlook; on May 23, 2014, Fitch upgraded the Hellenic Republic to B, while Moody's upgraded the Hellenic Republic to Caa1 (August 1, 2014) and S&P upgraded the Hellenic Republic to B on September 12, 2014. However, these gradual rating improvements were reversed in the end of 2014 and early 2015, against a backdrop of sharply increasing uncertainty and deteriorating financial and fiscal conditions. A number of rating actions were taken by each of Fitch, S&P and Moody's during 2014 and 2015.

The Greek sovereign rating was last reduced by S&P on June 29, 2015, to CCC. Similarly, on June 30, 2015, Fitch downgraded Greece's sovereign rating to 'CC' and on July 1, 2015, Moody's downgraded Greece's government bond rating to 'Caa3' from 'Caa2' and placed the rating on review for further downgrade assigning a continuing high probability of Greece's default on its privately-held debt without ongoing support from official creditors. The completion of the agreement on the Third Program and the progress in its implementation led to a sequence of sovereign upgrades by the main rating agencies: S&P raised Greece's rating by two notches to 'CCC+' on July 21, 2015, while Fitch upgraded Greek debt by one notch to 'CCC', on August 18, 2015. On September 25, 2015, Moody's maintained Greece's sovereign rating at 'Caa3' but changed the outlook to stable from negative as it had placed the country's rating on review for further downgrade since July 1, 2015. Finally, S&P Ratings upgraded the creditworthiness of the Hellenic Republic by one notch to 'B-' on January 22, 2016 with a stable outlook (Source: Bloomberg database).

A new downgrade of the Hellenic Republic's rating could occur if the sovereign fails to meet its commitments to official sector lenders or becomes unable to service its obligations to the private or official sector. A downgrade may also occur if official sector lenders do not timely provide necessary additional relief from Greece's debt servicing costs. Accordingly, the financing costs of the Hellenic Republic would increase further (if it is able to access the capital markets at all), with negative effects on the cost of capital for Greek banks (including the Bank) and the Bank's business, financial condition and results of operations. Further downgrades of the Hellenic Republic's credit rating could also result in a corresponding downgrade in the Bank's credit rating and, as a result, increase wholesale borrowing costs and the Bank's access to liquidity.

For details relating to the Bank's credit ratings, see Item 5B., "Liquidity and Capital Resources—Credit Ratings".

A default of the Hellenic Republic would have a material adverse effect on the Group's business and could lead to a higher cost of funding or the inability of the Bank to raise capital.

The ability of the Hellenic Republic to repay and reduce its outstanding indebtedness depends on a variety of factors, including the overall health of the Greek economy, the growth rate that can be achieved in future years, especially as relates to the impact of the Third Program on long-term debt sustainability, and levels of taxes collected from Greek taxpayers. If an additional restructuring of Hellenic Republic debt were to occur due to adverse scenarios arising from the foregoing or other influences, the Bank's regulatory capital would be severely affected due to its direct exposure to Hellenic Republic debt, as well as due to the indirect effects of the credit event on the Bank's borrowers (and thus asset quality) and on investor confidence, requiring the Bank to raise additional capital and thus significantly diluting and/or eliminating existing shareholders' interests. In addition, if the Hellenic Republic were to default on its debt obligations to the Bank, the Bank could suffer losses and require further capital. Furthermore, there can be no assurance that the Bank could raise all or any of the required additional capital on acceptable terms.

Failure to implement a credible program of reforms and measures to restore long-term debt sustainability and cover possible additional needs (even if due to factors outside the control of the Hellenic Republic) of Greece in upcoming years may also result in a credit event with respect to Hellenic Republic debt or lead to a default by the Hellenic Republic on its domestic and/or external debt, which could include marketable instruments, official sector loans from the Eurozone countries and/or the IMF and other obligations of the Hellenic Republic.

Moreover, if the Third Program does not achieve its intended results or the Hellenic Republic and the Institutions are not otherwise able to continue to agree on a sustainable fiscal path for Greece, it is possible that investors may again fear the exit of Greece from the Eurozone and the common currency of the euro, or be forced to repay its domestic and/or external indebtedness with a parallel or

alternative currency. The exit from the Eurozone by Greece would have a significant adverse effect on the Group's business, financial condition and results of operations, including a higher cost of funding and a devaluation or redenomination of significant portions of its assets.

The Group may not be allowed to continue to recognize the main part of deferred tax assets under IFRS as regulatory capital, which may have an adverse effect on its operating results and financial condition.

The Group currently includes deferred tax assets calculated in accordance with IFRS as endorsed by the EU ("DTAs") in calculating the Group's capital and capital adequacy ratios. As at December 31, 2015, the Group DTAs was EUR 5.1 billion, compared to EUR 3.3 billion as at December 31, 2014.

The Bank reviews the carrying amount of its DTAs at each reporting date, and such review may lead to a reduction in the value of the DTAs on the Bank's statement of financial position, and therefore reduce the value of the DTAs as included in the regulatory capital.

CRD IV (EU Directive 2013/36 and European Parliament Regulation 575/2013) provides that DTAs recognized for IFRS purposes that rely on the future profitability of a credit institution and exceed certain thresholds must be deducted from its CET1 (Common Equity Tier 1) capital. This deduction is implemented gradually until 2024.

The deduction introduced by CRD IV has a significant impact on Greek credit institutions, including the Group. However, as a measure to mitigate the effects of the deduction, article 27A of Greek Law 4172/2013, as amended by paragraph 1 of article 23 of Greek Law 4302/2014 and further amended by article 4 of Greek law 4340/2015 (the "DTC Law") allows, under certain conditions, credit institutions to convert DTAs arising from the Private Sector Initiative ("PSI") unamortized losses, as well as accumulated provisions and other losses due to credit risk recognized as at June 30, 2015, for IFRS purposes, (the "Eligible DTAs" or "DTCs") to final and settled claims against the Hellenic Republic (the "Tax Credits"). As at December 31, 2015 Group's eligible DTAs amounted to EUR 4.9 billion (2014: EUR 3.3 billion). Eligible DTAs may increase in future periods due to the recognition of unrecognized DTAs on accumulated provisions and other losses due to credit risk existing as at June 30, 2015. Eligible DTAs may increase in future periods due to increases in applicable income tax rates. The main condition for the creation of Tax Credits is the existence of an accounting loss for a respective year, starting from accounting year 2016 and onwards, for which Tax Credits can be created in the following year, i.e., from 2017. The Tax Credits will be calculated as a ratio of IFRS accounting losses to net equity (excluding the year's losses) and such ratio will be applied to the remaining Eligible DTAs in a given year to calculate the Tax Credit that will be converted in that year, in respect of the prior tax year. This new legislation allows credit institutions, including the Group, to treat such Eligible DTAs as not "relying on future profitability" according to CRD IV, and as a result such Eligible DTAs are not deducted from CET1, thereby improving an institution's capital position.

In April 2015, the European Commission announced that it had sent requests for information to Spain, Italy, Portugal and Greece regarding their treatment of deferred tax credits for financial institutions under national law. Even though the European Commission had not launched a formal investigation, there can be no assurance that the tax provisions implemented by the law as described above, which was fashioned after the Portuguese DTC regulation, will not be challenged by the European Commission as illegal state aid.

If the regulations governing the use of DTCs as part of the Group's regulatory capital should change, this may affect the Group's capital base and consequently its capital ratios. As at December 31, 2015, 54.7% of the Group's CET1 capital was comprised of DTC. Additionally, there can be no assurance that any final interpretation of the amendments described above will not change or that the European Commission will not conclude the treatment of the DTCs under Greek law illegal and as a

result Greek credit institutions will ultimately not be allowed to maintain certain DTCs as regulatory capital. If any of these risks materialize, this could have a material adverse effect on the Group's ability to maintain sufficient regulatory capital, which may in turn require the Group to issue additional instruments qualifying as regulatory capital, to liquidate assets, to curtail business or to take any other actions, any of which may have a material adverse effect on the Group's operating results and financial condition and prospects.

If the Bank recognizes accounting losses in future years, its DTCs will be converted into Tax Credits and the Bank will be required to issue a material number of additional ordinary shares to the Hellenic Republic, which may result in high dilution of existing shareholders in 2017 and future periods.

The Group has significant DTAs as part of its assets, calculated in accordance with IFRS. The amount of the Bank's Eligible DTAs was EUR 4.9 billion as at December 31, 2015. DTAs that arise from the PSI unamortized losses, as well as accumulated provisions and other losses due to credit risk recognized as at June 30, 2015 for IFRS purposes are Eligible DTAs, and may be converted into final and settled claims (Tax Credits) against the Hellenic Republic, as set out in "—The Group may not be allowed to continue to recognize the main part of deferred tax assets under IFRS as regulatory capital, which may have an adverse effect on its operating results and financial condition". These Tax Credits shall give rise to a direct repayment claim against the Hellenic Republic. From 2017 onwards, the relevant credit institution shall issue and deliver, for free, warrants to the Greek State (conversion rights), which can be converted into ordinary shares of the credit institution at a total market value equal to 100% of such Tax Credits as standing before the offset, at a market price equal to the weighted average market price over the 30 business days preceding the conversion (which 30-day period will take place preceding the Annual General Meeting usually held in May or June), and shall form a special reserve of an equal amount, solely for the purpose of its capitalization in the context of the share capital increase arising from the exercise of the relevant conversion rights. Such 30 day average price could be materially below the issue price for the New Shares. The warrants shall be freely transferrable, without prejudice to the call option of the common shareholders of the credit institution for the purchase of the warrants in proportion to their shareholding participation in the credit institution within a reasonable timeframe.

On November 7, 2014, the Bank convened an extraordinary General Shareholders Meeting which resolved upon the Bank's submission to the DTC Law, the issuance of warrants to the Hellenic Republic and the formation of a special reserve. As a result, if the Bank has IFRS accounting losses in any given year from 2016 onwards, and the provisions of article 27A of Greek Law 4172/2013 are applied as described above, existing shareholders may be diluted to the extent of the ordinary shares issued to the Hellenic Republic, should existing shareholders not exercise their call option on the conversion rights.

If the Bank were to recognize an accounting loss in 2016, for example, due to higher provisions for loan losses or asset impairments, the Bank's Eligible DTAs would convert into Tax Credits, which, depending on the amount of the IFRS loss, could lead to the issuance of a significant number of new ordinary shares to the Hellenic Republic, in particular if the market value of the Bank's ordinary shares is low during the 30-day period preceding the conversion, which could result in very significant dilution for holders of existing ordinary shares.

There is uncertainty about the Bank's ability to continue as a "going concern".

Significant deposits outflows during the first half of 2015 from the Greek banking sector, including from the Bank, resulted in increased levels of Eurosystem funding, a large part of which was through the ELA. Eurosystem funding currently remains significant (EUR 22.1 billion as at May 4, 2016, of which EUR 11.1 billion is through ELA) and therefore could adversely affect the Bank's ability to continue as a going concern. The going concern basis of the Bank is dependent on continued access to Eurosystem funding, whether the outflow of deposits continues, and whether and when the number of

new fiscal measures resulting from the Third Program will be successfully implemented. In addition, as at December 31, 2015 our shareholders equity was negative EUR 4,362 million, as a result of the increased loans impairment and the impairment of Finansbank, although our CET1 ratio, following the 2015 Recapitalization, stood at 14.5%. Our independent registered public accounting firm has added an explanatory paragraph to their audit opinion issued in connection with the 2015 U.S. GAAP Financial Statements emphasizing the disclosures of material uncertainties in Note 3 of the 2015 U.S. GAAP Financial Statements.

Pursuant to Article 131 of the CRD Law (which transposed into Greek Law article 141 of the CRD IV Directive) (the "CRD Law"), the Bank may not make discretionary payments (as defined in the CRD Law), including dividend payments, if and to the extent that such payment, when aggregated with other distributions of the kind referred to in paragraph 1 of Article 131 of the CRD Law, would exceed a cap or maximum distributable amount (the "Maximum Distributable Amount") required to be calculated in accordance with the CRD Law if any, then applicable to the Bank, to be exceeded.

Under Article 131 of the CRD Law, credit institutions that fail to meet the "combined buffer requirement" will be subject to restricted "discretionary payments", which are defined broadly by the CRD Law as payments relating to CET1 (including payment of dividends, variable remuneration and payments on Additional Tier 1 instruments). The restrictions will be scaled according to the extent of the breach of the "combined buffer requirement" and calculated as a percentage of the profits of the institution since the last distribution of profits or "discretionary payment".

Such calculation will result in a Maximum Distributable Amount in each relevant period. As an example, the scaling is such that in the first (that is the lowest) quartile of the "combined buffer requirement", no "discretionary distributions" will be permitted to be paid. In the event of a breach of the "combined buffer requirement", the Bank will be required to calculate its Maximum Distributable Amount, and as a consequence it may be necessary for the Bank to reduce discretionary payments, including by exercising its discretion to cancel (in whole or in part) dividend payments. The "combined buffer requirements" will be breached if the Bank fails to meet one of the minimum capital ratios applicable to the Bank, as well as, in certain other circumstances. In addition, the Bank will have the discretion to determine how to allocate the Maximum Distributable Amount, if any, among the different types of payments contemplated in Article 131(1) of the CRD Law.

Moreover, payments made earlier in the relevant period will reduce the remaining Maximum Distributable Amount available for payments later in the relevant period, and the Bank will have no obligation to preserve any portion of the Maximum Distributable Amount for payments scheduled to be made later in a given period. Even if the Bank attempts to do so, there can be no assurance that it will be successful, because the Maximum Distributable Amount will depend on the amount of Net Income earned during the course of the relevant period, which will necessarily be difficult to predict and may have a material adverse effect on the Bank's results of operations.

The Bank does not currently pay dividends to its shareholders and may not be able to pay dividends in the future.

In accordance with the provisions of Greek Law 3723/2008, in conjunction with Greek Laws 4261/2014, 4144/2013, 4063/2012, 3965/2011, 3844/2010 and 3756/2009, we did not pay any dividends to our ordinary shareholders in 2015 in respect of the 2014 financial year, nor in 2014, 2013 and 2012 in respect of the 2013, 2012 and 2011 financial years, respectively. In addition, for the reasons discussed below, we do not expect to be able to pay dividends in the near future.

Greek Law 2190/1920 and Greek Law 4261/2014, as in force, prescribes the conditions applying over distribution of dividends for Sociétés Anonymes and for credit institutions respectively, including

the maximum distributable amount, in line with the provisions of Directive 2013/36/EU (CRD IV Directive) which has been transposed by Greek Law 4261/2014. (See also, Item 8. A., "Consolidated Statements and Other Financial Information—Policy on Dividend Distributions").

Furthermore, in accordance with the commitments included in our Revised Restructuring Plan (see Item 4.A "History and Development of the Company—Revised Restructuring Plan approved by the Directorate General for Competition on December 4, 2015"), which was approved by the European Commission in December 2015, we may not pay dividends on our ordinary shares until the earlier of December 31, 2017 or the repayment of the CoCos. The HFSF Law provides that, while the CoCos are outstanding, we may not pay any dividends on our ordinary shares unless we have already paid interest on the CoCos in respect of the most recent coupon payment.

As a result of the Bank's recapitalization by the HFSF in accordance with the HFSF Law, the restrictions on dividend payments applicable due to participation in the Hellenic Republic Bank Support Plan continue to apply. In particular, the Bank's dividends are subject to a maximum of 35% of the Bank's distributable profits (on an unconsolidated basis). In addition, as long as the Bank participates in the recapitalization program pursuant to the HFSF Law and the Hellenic Republic Bank Support Plan, the HFSF's and the Hellenic Republic's representatives who sit on the Board of Directors have the power to veto any decision of the Board of Directors of the Bank regarding the distribution of dividends and remunerations to the Chairman, Chief Executive Officer, other members of the Board of Directors, General Managers and their deputies.

As a recipient of State Aid, the Bank's operational autonomy is constrained.

As a result of recapitalizations in 2013 and 2015, each of which included State Aid within the meaning of applicable EU legislation, and in order for the HFSF to fulfill its objectives under the HFSF Law, exercise its rights and obligations and comply with the commitments undertaken through the Financial Assistance Facility Agreement⁽¹⁾ ("FFA") and the Memorandum of Understanding⁽²⁾ ("MoU"), the HFSF and the Bank entered to a revised Relationship Framework Agreement dated December 3, 2015 (the "Amended Relationship Framework Agreement"), which amended the initial Relationship Framework Agreement dated July 10, 2013 between the Bank and the HFSF (the "Relationship Framework Agreement") (See Item 4.B.,"Business overview—Regulation and Supervision of Banks in Greece—The Hellenic Financial Stability Fund—The Greek Recapitalization Framework—Provision of Capital Support by HFSF—The Relationship Framework Agreement"). The total amount of State Aid we received in forms other than guarantees and liquidity assistance was approximately EUR 12.7 billion as at December 31, 2015.

Under European State Aid rules, the Bank has undertaken certain Commitments (as defined below) and has submitted a Revised Restructuring Plan (see below). In line with the Commitments undertaken, among others, the Bank is not permitted to acquire any stake in any undertaking unless the purchase price is below certain thresholds or the acquisition takes place in the ordinary course of business or following relevant approval by the European Commission, according to the particular provisions of the Commitments. The Commitments also provide for certain procedures, that the Bank has to follow with respect to lending towards connected borrowers and risk monitoring requirements that the Bank must fulfill. Finally, in the event that the Bank is placed under liquidation, according to the legal framework concerning the HFSF, the HFSF (as shareholder) is satisfied in priority before the common shareholders.

On December 4, 2015, the Directorate General for Competition of the European Commission approved the Bank's Revised Restructuring Plan. (See Item 4. A., "History and Development of the Company—Revised Restructuring Plan approved by the Directorate General for Competition on December 4, 2015").

The implementation of the Revised Restructuring Plan by the Bank may have a significant impact on its business activity, operating results and financial position. Specifically, as part of the Revised Restructuring Plan, the Bank has undertaken a number of Commitments, both structural (such as the disposal of certain assets and subsidiaries) and behavioral, towards the European Commission. Among other Commitments, as part of its Revised Restructuring the Bank is proceeding, subject to customary regulatory and corporate approvals, to dispose of its entire stake in Finansbank (see "—The sale of Finansbank pursuant to the Revised Restructuring Plan will result in the loss of a business which has historically represented a significant portion of our consolidated operations and profit"). The other disposals contemplated by the Revised Restructuring Plan, which have not yet taken place, may be undertaken by the Bank at unattractive valuations or during unfavorable market conditions. The Bank may not succeed in complying with all the Commitments given by the Hellenic Republic in the Revised Restructuring Plan for the Bank. This may lead to the European Commission re-opening an in-depth investigation (so-called "misuse of aid proceedings") at the end of which it may find that additional restructuring measures are required in order to find the State Aid received compatible with the internal market. In addition, it may result in the HFSF exercising full voting rights in respect of its shares in the Bank (see "—The HFSF, as shareholder, has certain rights in relation to the operation of the Bank").

Furthermore, the Commitments of the Hellenic Republic towards the European Commission also provide for, inter alia, the appointment of a monitoring trustee (the "Monitoring Trustee") for each bank under restructuring. The Monitoring Trustee acts on behalf of the European Commission and aims to ensure the compliance of the Bank with such Commitments, and oversees the implementation of restructuring plans and the Bank's compliance with the applicable State Aid rules. See Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—Reporting Requirements for Banks—Monitoring Trustee". Grant Thornton was appointed as the Bank's Monitoring Trustee on January 16, 2013. The Monitoring Trustee's powers affect management's discretion by imposing further supervision on the Bank, which may affect business decisions and development strategies and limit the operational flexibility of the Group.

The HFSF, as shareholder, has certain rights in relation to the operation of the Bank.

Under the Amended Relationship Framework Agreement governing the relationship between the Bank and the HFSF, the HFSF, as shareholder, has certain rights in relation to the operation of the Bank. See 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Financial Stability Fund—The Greek Recapitalization Framework—Provision of Capital Support by HFSF—Powers of the HFSF". Although the Amended Relationship Framework Agreement provides that the Bank's decision making bodies will continue to determine independently, among other things, the Bank's commercial strategy and policy, the monitoring and veto powers held by the HFSF representative appointed to the Board of Directors (appointed since June 2012 under Greek Law 3864/2010) restrict the discretion of the Bank's management. Accordingly, as a result of the Bank's participation in recapitalization programs, the HFSF is able to exercise significant influence over the operations of the Bank. These restrictions arise from, among others, the Amended Relationship Framework Agreement with the HFSF entered into by the Bank in December 2015 in connection with its receipt of State Aid as part of its recapitalization in December 2015 (similar restrictions applied prior to December 2015 in accordance with the initial Relationship Framework Agreement of July 2013 between the Bank and the Hellenic Republic) (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Financial Stability Fund—The Greek Recapitalization Framework—Provision of Capital Support by the HFSF—The Relationship Framework Agreement").

Pursuant to the provisions of the HFSF Law, the HFSF's appointed representative has enumerated powers to veto key corporate decisions of the Bank and exercise other powers relating to corporate governance, as set out in Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Financial Stability Fund-The Greek Recapitalization Framework—Provision of Capital Support by HFSF—Powers of the HFSF." Additionally, in accordance with the provisions of the HFSF Law and the provisions of the Amended Relationship Framework Agreement, HFSF, among others, will perform its own evaluation of the corporate governance and of the Board of Directors and its Committees, through independent consultants of international reputation and established experience and expertise. This review will be in line with prudent international practices by applying criteria that go beyond supervisory fit and proper requirements. In the case that a review or evaluation determines that the subject of the review does not meet the relevant criteria, HFSF will follow the procedure described in par. 9 of art. 10 the HFSF Law, including communication of the results to the Board of Directors of the Bank and informing of the General Meeting of Shareholders in case the Board of Directors does not take measures to implement proposed recommendations, while the HFSF may recommend replacement of members of the Board of Directors or Board Committee. In addition to the provisions of the HFSF Law, and pursuant to the Amended Relationship Framework Agreement, the HFSF has a series of information rights with respect to matters pertaining to the Bank. Additionally, as prescribed by the Amended Relationship Framework Agreement, the HFSF representative shall be appointed as member in all Board Committees, while the HFSF observer (participates in the Board without voting rights) will also be appointed in all Committees. Finally, the Bank is obliged to obtain the prior approval of the HFSF on a number of material matters, determined in detail within the Amended Relationship Framework Agreement.

Consequently, there is a risk that the HFSF may exercise the rights it has to exert influence over the Bank and may disagree with certain of the Bank's decisions relating to dividend distributions, benefits policies and other commercial and management decisions which will ultimately limit the Group's operational flexibility. Depending on the outcome of the evaluation of our corporate governance currently underway, as contemplated by the HFSF Law and the Amended Relationship Framework Agreement, there may be changes to the composition of our Board of Directors.

Additionally, following its participation in the Bank's share capital increase completed in December 2015, the HFSF acquired 2,254,869,160 shares of the Bank, and as part of the recapitalization, Greek State Preference Shares previously held by the Hellenic Republic were converted into common shares and acquired by the HFSF by operation of law. Accordingly, as at April 20, 2016, the HFSF holds 3,559,869,160 common shares having full voting rights, representing 38.92% of the Bank's share capital, while it also holds 1.47% of the Bank's share capital consisting of common shares with restrictions on the exercise of the voting rights as per Article 7a of the HFSF Law as in force, which could be lifted upon certain conditions, i.e. in case the HFSF General Council concludes that there is a breach of material obligations which are included in the restructuring plan or which promote its implementation or which are described in the Amended Relationship Framework Agreement.

In addition, in the context of the 2015 Recapitalization HFSF subscribed for EUR 2,029 million CoCos (see also Item 4.A, "History and Development of the Company—2015 Recapitalization "). Any subsequent conversion of such securities into common shares according to the provisions of Cabinet Act no 36/2015, may result in further control over the Bank by the HFSF as well as the potential for additional dilution of shareholders in the future. See also "—Shareholder composition could substantially change due to the HFSF's and the Hellenic Republic's current or future participation in our share capital, and shareholders may be subject to substantial dilution". While we intend to repay the CoCos with the proceeds of the sale of Finansbank, there can be no assurance that the Finansbank Transaction will close or that this repayment will receive the required regulatory approvals (see "—We intend to redeem the contingent convertible securities (the "CoCos") issued to the HFSF as part of the 2015 Recapitalization,

with the proceeds from the sale of Finansbank, but there can be no assurance that the sale of Finansbank will close or that regulatory approval for the repayment of the CoCos will be obtained").

Furthermore, the HFSF also have 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 those of its shareholders.

The HFSF and the Hellenic Republic have and will continue to have the ability to exercise significant influence over our operations.

In the context of the Bank's recapitalization completed in December 2015, the 270 million Greek State Preference Shares previously owned by the Hellenic Republic (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic's Bank Support Plan"), were mandatorily converted into ordinary shares as a result of the application of Cabinet Act 36/2.11.2015, and by the operation of law acquired by the HFSF. Accordingly, the previously held stake of the Hellenic Republic in the Bank, (see "—The HFSF, as shareholder, has certain rights in relation to the operation of the Bank") as converted is now held by the HFSF.

In addition, in accordance with Article 2 of Greek Law 3723/2008, the Hellenic Republic, as long as the Bank retains the benefit of the Greek government guarantees issued under Greek Law 3723/2008, is entitled to the appointment of a representative to the Board of Directors of the Bank. The Hellenic Republic representative to the Board has the ability to veto decisions relating to strategic issues or decisions that could have a material impact on the legal or financial status of the Bank and for which the approval of the General Meeting is required, or decisions referring to the distribution of dividends and the remuneration of the Chairman, Chief Executive Officer, the remaining members of the Board of Directors, the General Managers and their deputies, under the relevant decision of the Ministry of Finance, or, in case of decisions that the representative considers detrimental to the interests of the depositors or that may materially affect the Bank's solvency and operation. The Hellenic Republic Representative has free access to the Bank's books, data and reports on restructuring and viability, plans for medium-term financing needs of the Bank, as well as data relating to the level of funding of the economy.

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

Non-accruing loans represented 39.7% of our loan portfolio as at December 31, 2015, while the same ratio for our Greek operations was 41.3% (see Item 4.E, "Selected Statistical Data—Credit Quality and Risk Management—Allowance for Loan Losses—Methodology" and Item 5, "Operating and Financial Review and Prospects—Key Factors Affecting our Results of Operations"). 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, individuals 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"). As at December 31, 2015 and December 31, 2014, 71,960 and 58,948 customers, had applied to the court under the provisions of Greek Law 3869/2010,with combined outstanding balances of EUR 3,411 million and EUR 2,784 million, respectively. In addition, we may not be able to enforce certain collateral in enforcement proceedings for real estate used as the main residence of the debtors, subject to certain conditions as described in Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—Constraints on the Use of Capital—Restrictions on Enforcement of Granted Collateral". Future provisions for non-accruing loans could have a materially adverse effect on our profitability.

The sale of Finansbank pursuant to the Revised Restructuring Plan will result in the loss of a business which has historically represented a significant portion of our consolidated operations and net income.

On November 3, 2015, the Board of Directors approved the Capital Plan (see Item 4.A, "History and Development of the Company—Capital Plan", which among others, included the disposal of our Turkish Operations. On December 21, 2015, the Board of Directors approved the divestiture to Qatar National Bank of the Turkish Operations. The Finansbank Transaction was approved by our shareholders at an Extraordinary General Meeting on January 18, 2016. Closing of the Finansbank Transaction is subject to approval from: (i) the Turkish Banking Regulation and Supervision Agency (already received); (ii) the Qatar Central Bank (already received); (iii) the Turkish Competition Board (already received approval; reasoned decision pending to be received); (iv) the Turkish Capital Markets Board (already received) and (v) the Turkish Treasury (already received). The Finansbank Transaction is expected to close on or before June 30, 2016.

For the years ended December 31, 2013, 2014 and 2015, the Turkish Operations contributed 648 million, 169 million and 355 million, respectively, to our net income/(loss) from discontinuing operations before impairments. As the Turkish Operations have historically formed a significant portion of our consolidated business and operations, its disposal will have a significant impact on our financial condition, results of operations, liquidity, capital position and prospects in future reporting periods. In addition, as Turkey represented our largest foreign market, our future operations will be less diversified and our remaining operations will have a significantly greater exposure to Greece as a percentage of our overall business. As a result of the foregoing factors, the disposal of the Turkish Operations could have a material adverse effect on our business, results of operations, financial condition and prospects and may have an adverse impact on the value of the ordinary shares.

The Group is vulnerable to disruptions and volatility in the global financial markets.

Following a lengthy period of recession in many economies around the world, including Europe, in the wake of the financial crisis, global economic growth has returned, although at a relatively modest pace and unevenly across countries. Most of the economies with which Greece has strong export links, including a number of European economies, continue to face significant economic headwinds stemming from weak GDP growth, high levels of private or public debt and elevated unemployment rates. Increasing downside risks on the back of a weaker external environment and heightened geopolitical risks may restrict the sluggish European economic recovery, which remains greatly dependent on accommodative monetary policy, with a corresponding adverse effect on the Group's business, results of operations and financial condition.

Financial markets have shown elevated volatility in January and the first half of February 2016. Equity prices in many advanced economies and high-rated sovereign bond yields have declined, and corporate credit spreads widened due to heightening uncertainty vis-à-vis the pace of the world economic recovery, the steep decline in oil and commodity prices and the continual uncertainty regarding Chinese foreign exchange policy. However, global equity markets have showed tentative signs of improvement since mid-February 2016 recovering a part of their losses since the start of the year amid cautious global monetary policy by major central banks and improved economic data. Still, a significant deterioration in the emerging markets growth outlook, alongside disruptive renminbi devaluations by the People's Bank of China, has the potential to cause further financial market turmoil with a corresponding material adverse effect on the Group's business, results of operations and financial condition, including the Group's ability to fund its operations.

Results of operations, both in Greece and abroad, 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 funding; inflation; the stability and solvency of financial institutions and other companies; investor sentiment and confidence in the financial markets; or a combination of the above factors.

Adverse developments could also be triggered by significant deterioration of global economic conditions amid the ongoing deceleration in emerging market economies, and especially in China, a recurrence of euro area sovereign debt and banking stress triggered, inter alia, by political and fiscal uncertainty associated with Greece, Spain and the referendum on the United Kingdom's membership of the European Union, stalling reform efforts in euro area periphery economies, as well as a sharper-than-expected deterioration in the Greek economy.

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. Given the high level of interdependence between financial institutions, we are and will continue to be subject to the risk of deterioration of the commercial and financial soundness, or perceived soundness, of other financial services institutions. 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.

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 available-for-sale, 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 investment securities portfolios could lead to additional impairment losses, including our holdings of Greek government bonds. The investment securities portfolios accounted for 15.5% of the Group's total assets excluding long-lived assets classified as held for sale as at December 31, 2015. 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".

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, domestic and international economic and political conditions, as well as other factors. There can be no assurance that further events will not alter the interest rate environment in Greece and the other markets in which we operate. Cost of funding is especially at risk for the Bank due to increased ELA and Eurosystem funding and the tight liquidity conditions in the domestic deposit market.

In the current interest rate climate, central banks of the major developed economies (including the Federal Reserve ("Fed"), the ECB, the Bank of England and the Bank of Japan, among others) are widely perceived to have an abnormally significant influence on the volatility and direction of short term rates. The method and rate at which central banks adjust their target rates cannot be predicted, nor can the effects that changes in such rates will have, be anticipated.

There are risks involved in both an increase of rates and a prolonged period of low or negative interest rates. Variations in short-term interest rates could affect the Group's net interest income, reducing its growth rate and potentially resulting in losses. When interest rates rise, the Group may be required to pay higher interest on floating-rate borrowings while interest earned on fixed-rate assets does not rise as quickly, which could cause profits to grow at a reduced rate or decline.

Conversely, increases in interest rates may reduce the volume of loans the Group originates. Sustained high interest rates have historically discouraged customers from borrowing and have resulted in increased delinquencies in outstanding loans and deterioration in the quality of assets. Increases in interest rates may also reduce the propensity of the Group's customers to prepay or refinance fixed-rate loans, reduce the value of its financial assets and reduce gains or require it to record losses on sales of loans or securities.

If interest rates decrease, although this is likely to reduce the Group's funding costs, it is likely to compress the Group's interest margin, as well as adversely impact income from investments in securities and loans with similar maturities, which could have a negative effect on the Group's operating results, financial condition and prospects.

Changes in market interest rates may affect the interest rates the Group charges on its interest-earning assets differently from the interest rates it pays on its interest-bearing liabilities. This difference could reduce the Group's net interest income. Since the majority of the Group's loan portfolio effectively re-prices within a year, rising interest rates may also result in an increase in the Group's allowance for loan losses if customers cannot refinance in a higher interest rate environment. Further, an increase in interest rates may reduce the Group's clients' capacity to repay in the current economic circumstances.

The general scarcity of wholesale funding since the onset of the economic crisis, as well as the imposition of capital controls in 2015, has led to a significant increase in competition for retail deposits in Greece among the four largest banks (including the Bank) and other smaller banks, which means

that the Bank may have to pay higher rates to attract equivalent levels of deposits. This has been exacerbated by the sharp decline in deposits that have left the Greek banking system over the past several months due to the imposition of capital controls. The Bank faces competition from foreign banks in our banking operations outside of Greece, some of which may have resources greater than that of the Bank. The Bank may not be able to continue to compete successfully with domestic and international banks in the future. These competitive pressures may have a material adverse effect on its business, financial condition and results of operations. The Group's exposure to Greece will increase significantly as a result of the sale of Finansbank. See also "—The sale of Finansbank pursuant to the Revised Restructuring Plan will result in the loss of a business which has historically represented a significant portion of our consolidated operations and profit".

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

The Group's current senior management team includes a number of executives the Group believes contribute significant experience and expertise to its management in the banking sectors in which the Bank operates. The continued performance of the Group's business and its ability to execute its business strategy will depend, in large part, on the efforts of the senior management of the Group. For instance, a change in government or a situation of effective control by the HFSF could lead to the departure of certain senior managers. If a substantial number of the Group's senior management team leave the Group, its business may be materially adversely affected. In addition, as described under "—The HFSF, as shareholder, has certain rights in relation to the operation of the Bank", our Board of Directors is currently subject to an evaluation of our corporate governance, as contemplated by the HFSF Law and the Amended Relationship Framework Agreement. Depending on the outcome of this evaluation, there may be changes to the composition of our Board of Directors.

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

The Group's competitive position depends, in part, on its ability to continue to attract, retain and motivate qualified and experienced banking and management personnel. Competition in the Greek and 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, the Group provides compensation packages consistent with evolving standards in the relevant labor markets. Under the terms of the Hellenic Republic's Bank Support Plan, as currently applicable, the Bank is prohibited from paying bonuses to the members of the Board of Directors, the Chairman, the Chief Executive Officer, the Deputy Chief Executive Officers and any general managers or their deputies. In any case, remuneration of the abovementioned personnel should not exceed the Bank of Greece Governor's remuneration. Furthermore, as a result of the economic crisis and regulatory restrictions on bonus payments, the Group is limiting or restricting the bonuses it pays to personnel, which may inhibit the retention and recruitment of qualified and experienced personnel. The inability to recruit and retain qualified and experienced personnel in the Hellenic Republic and SEE, or manage the Group's current personnel successfully, could have a material adverse effect on its business, results of operations, financial condition and prospects.

We, like any other credit institution, are exposed to the risk of fraud and illegal activities of any form, which, if not dealt with in a timely manner and successfully, could have negative effects on our business, financial condition, results of operations and prospects.

The Group is subject to rules and regulations related to combating money laundering and terrorism financing in the jurisdictions where it operates. Compliance with anti-money laundering and anti-terrorist financing rules entails significant cost and effort. Non-compliance with these rules may have serious consequences, including adverse legal and reputational consequences. Although the Group believes that its current anti-money laundering and anti-terrorism financing policies and procedures are

adequate to ensure compliance with applicable legislation, it cannot guarantee that they will comply at all times with all rules applicable to money laundering and terrorism financing as extended to the entire Group and applied to its staff in all circumstances. A possible violation, or even any suspicion of a violation of these rules, may have serious adverse legal and financial impacts, which could have a material adverse effect on the Group's business, financial condition, results of operations and prospects.

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

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 at December 31, 2015 was EUR 273 million, determined by reference to a number of critical assumptions. These include assumptions about movements in interest rates which may not be realized. Potential variations 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 Item 6.D, "Employees" and Note 40 to the U.S. GAAP Financial Statements.

The recent amendments pursuant to the Third Program or any future amendments in legislation regarding pensions and pension liabilities or other post-employment benefit obligations 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 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, we rely 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, our internal valuation models require us 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 we are often required to make 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 our earnings and financial condition. Also, market volatility and illiquidity such as that experienced over the past several years can challenge the factual bases of certain underlying assumptions and has made it difficult to value certain of the Group's 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 our 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 have a material adverse effect on the Group's results of operations, financial condition, prospects and reputation.

Although management believes that its risk management and risk mitigation policies are adequate, our risk management processes may not prevent all instances of fraud or otherwise allow us to mitigate or fully manage the above risks. In addition, the weak Greek economy and the need to implement the Third Program as well as 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.

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 hedging 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. In the Group's view, the principal market risk to which it is exposed, which is not fully economically hedged, is the sovereign credit risk of the Hellenic Republic, in respect of which the Group does not maintain any hedging positions (such as, for example, credit default swaps).

Our operational systems and networks have been, and will continue to be, vulnerable to an increasing risk of continually evolving cyber-security or other technological risks which could result in the disclosure of confidential client or customer information, damage to our reputation, additional costs to us, regulatory penalties and financial losses.

A significant portion of our operations rely 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. We store 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.

Our 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 our reputation with its clients and the market, additional costs to us (such as repairing systems or adding new personnel or protection technologies), regulatory penalties and financial losses to both us and our clients. Such events could also cause interruptions or malfunctions in our operations (such as the lack of availability of our online banking systems), as well as the operations of our clients, customers or other third parties. Given the volume of our transactions, 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 we do business under stringent contractual agreements may also be sources of cyber security or other technological risks. We outsource 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 we adopt 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 us as those discussed above.

While we maintain 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.

Since December 31, 2013 the Group's Greek residents net loans has declined from EUR 43.0 billion to EUR 36.7 billion as at December 31, 2015. As the Greek economy has fallen into recession, 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, capital controls imposed on Greek banks and the Third Program. The continuing decline in our loan portfolio, in combination with non-accruing loans, could further reduce our net interest income, and this could have a material adverse effect on our business, results of operations, financial condition and prospects.

Due to the uncertainty regarding the successful implementation of the Third Program, new taxes may be imposed on the Group, and existing taxes may be increased. Greek Law 4334/2015 provides that for the periods commencing from January 1, 2015 thereon, the nominal corporation tax rate has increased to 29% from 26% in 2014.

Any additional taxes imposed on us in the future, or any increases in tax rates, may have a material adverse effect on our business, results of operations and financial condition.

Material weaknesses in our disclosure controls and procedures and internal control over financial reporting ("ICFR") under U.S. GAAP could negatively affect shareholder and customer confidence towards our financial reporting and other aspects of our business.

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, our Deputy Chief Executive Officer and our Group 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.

As of December 31, 2015, we performed an evaluation, under the supervision and with the participation of our management, including our Chief Executive Officer, our Deputy Chief Executive Officer and our Group Chief Financial Officer, of the effectiveness of our disclosure controls and procedures.

Based upon that evaluation, our Chief Executive Officer, our Deputy Chief Executive Officer and our Group Chief Financial Officer have concluded that our disclosure controls and procedures are ineffective as of December 31, 2015, due to the fact that management identified material weaknesses in its ICFR relating to:

Although we have initiated remedial steps to address these material weaknesses in our ICFR, the existence of these material weaknesses 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 ICFR could 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.

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

Group is subject to financial services laws, regulations, administrative actions and policies in each jurisdiction in which it operates. All of these regulatory requirements have changed, are continuing to change, and are subject to further change following the unprecedented levels of government intervention and changes to the regulations governing financial institutions, as a result of the financial crisis. In response to the global financial crisis, national governments as well as supranational groups, such as the EU, have implemented significant changes to the existing regulatory frameworks for financial institutions, including those pertaining to supervision, capital adequacy, liquidity, resolution and the scope of banks' operations (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—Capital Requirements/Supervision").

Since November 4, 2014, the Group has been a significant supervised entity under the SSM in the Eurozone and is subject to continuous evaluation of its capital adequacy by the SSM, and could be requested to operate with higher than minimum regulatory capital and/or liquidity ratios. The supervisory regime applicable to European banks is undergoing a period of change since the SSM took responsibility for the prudential supervision of banks in the Eurozone in November 2014. The SSM might impose new compliance, governance or system and control mandates that will increase compliance costs for the Bank. Furthermore, it is unclear yet whether this new supervisory regime shall require the Bank (and other banks) to significantly increase its minimum required capital.

As a result of these and other ongoing and possible future changes in the financial services regulatory framework (including requirements imposed by virtue of the Group's participation in any Greek government or regulator-led initiatives, such as the Hellenic Republic Bank Support Plan), the Group will face greater regulation in the Hellenic Republic and SEE. Current and future regulatory requirements may be different across each of these locations and even requirements with European Economic Area ("EEA")-wide application may be implemented or applied differently in different jurisdictions.

Compliance with these new requirements will increase the Group's regulatory capital and liquidity requirements and may increase its compliance costs and disclosure requirements, restrict certain types of transactions, affect its strategy and limit or require the modification of rates or fees that it charges on certain loans and other products, any of which could lower the return on the Group's investments, assets and equity. The Group may also face increased compliance costs and limitations on its 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 the Group's business, including increasing competition, increasing general uncertainty in the markets or favoring or disfavoring certain lines of business. In addition, changes in law to address tax compliance issues such as compliance with the U.S. Foreign Account Tax Compliance Act under sections 1471 through 1474 of the U.S. Internal Revenue Code of 1986 ("FATCA") may increase the Group's compliance costs. The Group cannot predict the effect of any such changes on its business, financial condition, cash flows or future prospects.

The Group is subject to the European resolution framework which has been implemented and may result in additional compliance or capital requirements and will dictate the procedure for the resolution of the Group.

The BRRD provides for the establishment of an EU-wide framework for the recovery and resolution of credit institutions and investment firms. The BRRD is designed to provide authorities with a credible set of resolution tools and powers to intervene sufficiently early and quickly to avoid a significant adverse effect on the financial system, to prevent threats to market infrastructures, to protect depositors and investors and to minimize reliance on public financial support.

The BRRD was implemented in Greek law by Greek Law 4335/2015. The BRRD's broad range of resolution tools and powers may be used alone or in combination where the relevant National Resolution Authority considers that certain required conditions are met, namely, that an institution is failing or likely to fail, that no alternative private sector measure, or supervisory action, would prevent the failure of the institution within a reasonable timeframe and that the taking of a resolution action is necessary to the public interest. The resolution tools include the power to sell or transfer assets (or ownership thereof) to another institution and a general bail-in tool (the "BRRD Bail-in Tool"), which provides for the write-down or conversion of any obligations of the institution that meet relevant conditions. In certain circumstances, the use of resolution tools may require that the institution in question be made subject to liquidation. In certain cases, extraordinary public financial support may be provided either outside of resolution or in addition to the application of one or more resolution tools, in accordance with the EU state aid framework, as a last resort and subject to additional conditions, including mandatory burden-sharing rules whenever public support is provided in the context of resolution. For further information, see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—Reporting Requirements for Banks—Bank Recovery and Resolution Directive".

An institution will be considered as failing or likely to fail when: it is, or is likely in the near future to be, in breach of its requirements for continuing authorization; its assets are, or are likely in the near future to be, less than its liabilities; it is, or is likely in the near future to be, unable to pay its debts or other liabilities as they fall due; or it requires extraordinary public financial support (except in limited circumstances). Although there are proposed pre-conditions for the exercise of the bail-in power, there remains uncertainty regarding the specific factors which the relevant National Resolution Authority would consider in deciding whether to exercise the bail-in power with respect to the relevant financial institution and/or securities issued by that institution. In particular, in determining whether an institution is failing or likely to fail, the relevant National Resolution Authority may consider a number of factors, including, but not limited to, an institution's capital and liquidity position, governance arrangements and any other elements affecting the institution's continuing authorization. Moreover, as the final criteria that the relevant National Resolution Authority would consider in exercising any bail-in power is likely to provide it with discretion, it will be difficult to predict when, if at all, the exercise of any bail-in power by the relevant Resolution Authority, may occur which would result in a principal write off or conversion to equity. Accordingly, the threat of bail-in may affect trading behavior, including prices and volatility, of the securities of any institution which the market perceives to be potentially considered as failing or likely to fail by the relevant National Resolution Authority.

In addition to the BRRD Bail-in Tool which is available for an institution in resolution, the BRRD provides for resolution authorities with pre-resolution powers to permanently write-down or convert into equity capital instruments of the financial institution, including "CET1 instruments", "Additional Tier 1 instruments" and "Tier 2 instruments" (each as defined under the CRD IV) at the point of non-viability of the institution and before any other resolution action is taken (non-viability loss absorption), as further described under the Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—Bank Recovery and Resolution Directive". The capital instruments write-down and conversion power may be exercised independently of, or in combination with, the exercise of a resolution tool (other than the bail-in power, which would be used instead of the capital instruments write-down and conversion power). These measures could be applied to certain of the Group's instruments; the occurrence of circumstances in which write down powers would need to be exercised would be likely to have a material adverse impact on the Group's business, financial condition and results of operations. Furthermore, in circumstances where capital instruments are converted into equity securities by application of the mandatory write-down tool, those equity securities may be subjected to the bail-in powers in resolution, resulting in their cancellation, significant dilution or transfer away from the investors therein.

The powers set out in the BRRD will impact how credit institutions and investment firms are managed as well as, in certain circumstances, the rights of creditors. As such, it is too early to anticipate the full impact of the BRRD, and there can be no assurance that shareholders and potential investors will not be adversely affected by actions taken under it. In addition, there can be no assurance that its application will not have a significant impact on the Group's results of operations, business, assets, cash flows and financial condition, as well as on its funding activities and the products and services offered (see also "—Although the Bank successfully raised the capital it needed in December 2015, there can be no assurance that this level of capital will be sufficient if economic conditions in Greece deteriorate further").

In addition, Regulation 806/2014 establishes uniform rules and a uniform procedure for the resolution of credit institutions and certain investment firms in the framework of a Single Resolution Mechanism ("SRM") and a Single Resolution Fund (the "SRM Regulation").

The SRM Regulation, which will complement the SSM (as discussed under "—The Group may need additional capital and liquidity as a result of regulatory changes" above), applies to all banks supervised by the SSM, including the Bank. These uniform rules and uniform procedure established under the SRM Regulation will be applied by a single resolution board (the "Single Resolution Board") together with the EU Council and the European Commission and the national resolution authorities within the framework of the Single Resolution Mechanism. The Single Resolution Board shall have available the same range of tools as are available under the BRRD and described above. The Single Resolution Mechanism will be supported by a single resolution fund (the "Fund"). The Single Resolution Board will be responsible for the effective and consistent functioning of the Single Resolution Mechanism and shall use the Fund only for the purpose of ensuring the efficient application of the resolution tools and exercise of the resolution powers. The owner of the Fund shall be the Single Resolution Board.

The provisions relating to the cooperation between the SRB and the national resolution authorities for the preparation of the banks' resolution plans apply from January 1, 2015 and the Single Resolution Mechanism is fully operational from January 1, 2016. On February 22, 2016, the SRB, acting through the national resolution authorities of the Banking Union Member States, has started to collect the data required for resolution planning and the determination of MREL from all banking groups under its direct responsibility, including the Group.

We may be subject to a proposed EU regulation on mandatory separation of certain banking activities.

On January 29, 2014, the European Commission adopted a proposal for a new regulation following the recommendations released on October 31, 2012 by the High Level Expert Group (the "Liikanen Group") on the mandatory separation of certain banking activities. The proposed regulation, which remains subject to change and review and approval by the relevant European institutions, contains new rules to stop the biggest and most complex banks from engaging in the activity of proprietary trading in financial instruments and commodities. The new rules would also give supervisory authorities the power and, in certain instances, the obligation to require the transfer of other high-risk trading activities (such as market-making, complex derivatives and securitization operations) to separate legal trading entities within the group ("ring-fencing"). Should a mandatory separation be imposed, additional costs at Group level cannot be ruled out, including higher funding costs, additional capital requirements and operational cost which could have a material adverse impact on the Group's results of operations, business, assets and capital position.

On February 14, 2013, the European Commission published a proposal for a Directive for a common financial transactions tax (the "FTT") in certain participating member states of the European Union (the "Participating Member States"), including Greece (see Item 4.B, "Business Overview—EU Regulation Proposals—EU Financial Transactions Tax" for more information).

The European Commission's Proposal could, if introduced, apply to certain dealings in the ordinary shares as well as apply to persons both within and outside of the Participating Member States. Generally, it would apply to certain dealings in the ordinary shares where at least one party is a financial institution, and at least one party is established in a Participating Member State.

Holders of the ordinary shares are advised to seek their own professional advice in relation to the FTT. Any additional taxes imposed on or transactions carried out by us in the future, or any increases in tax rates, may have a material adverse effect on our business, results of operations or financial condition.

Laws governing the bankruptcy of individuals and regulations governing creditors' rights in Greece and various SEE countries may limit our ability to receive payments on past due loans, and anticipated changes to such laws may not have the desired effect.

Laws governing the bankruptcy of individuals who are not merchants (including Greek Law 3869/2010, regarding the debt arrangement of debts for over-indebted individuals) and other laws and regulations governing creditors' rights generally vary significantly within the region in which we operate. In some countries, the laws offer significantly less protection for creditors than the bankruptcy regimes in Western Europe and the United States. In Greece, foreclosures and auctions of all properties were prohibited until October 31, 2015. Although the Greek suspension of every enforcement action due to capital controls was lifted by the October 29, 2015 official announcement of Ministry of Justice, Transparency and Human Rights on November 2, 2015, a prolonged lawyers', bailiffs' and notaries' strike commencing in January 12, 2016 has restrained us from proceeding to enforcement, seizures and auctions of any real estate.

Although measures under the Third Program are in principle designed to address certain of the foregoing concerns in respect of creditors' rights in Greece, and reduce legal impediments to, and the tax consequences of, the enforcement of such rights, these measures may not be enacted as proposed or may not provide any of the protections to creditors that are hoped for. As a consequence, the Bank may continue to encounter difficulties recovering or enforcing collateral on past due loans, which could have a material adverse effect on its financial condition and results of operations.

If the current economic conditions persist or worsen, 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 our business, results of operations and financial condition.

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

Changes in consumer protection laws in Greece and other jurisdictions where the Group operates could limit the fees that banks may charge for certain products and services such as mortgage loans, unsecured loans and credit cards. If introduced, such laws could reduce our profit for the period, 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.

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

Apart from our continuing operations in the Hellenic Republic and discontinuing operations in Turkey, we have built up substantial operations in the SEE countries of Bulgaria, Romania, Serbia, Former Yugoslav Republic of Macedonia ("FYROM") and Albania ("SEE-5") and other developing economies. The Group's SEE operations accounted for 12.3% of our gross loans as at December 31, 2015 and 21.5% of our net interest income before provisions for loan losses from continuing operations at and for the year ended December 31, 2015. Our SEE-5 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-5 operations also expose us to foreign currency risk. A decline in the value of the currencies in which our SEE-5 subsidiaries receive their income or value their assets relative to the value of the Euro may have an adverse effect on our results of operations and financial condition.

The materialization of any of the above factors, individually or in combination, may have a material adverse effect on the Group's business, results of operations, financial condition or prospects.

There can be no assurance that the Bank will continue to satisfy the continued listing eligibility criteria of the listing rules of the ATHEX if additional capital is provided by HFSF.

There can be no assurance that the Bank will continue to satisfy the free float eligibility criteria of the listing rules of the ATHEX in case additional capital support is provided by the HFSF and the free float eligibility criteria may not be satisfied and the ATHEX may reclassify the Bank's share into another listing segment, namely the "Low Free Float Segment" or even the "To be Delisted Segment".

If the free float eligibility criteria remain unsatisfied for a period of circa one year the ATHEX may commence delisting proceedings against the Bank's ordinary shares listed on the ATHEX.

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 trading in ADSs representing the ordinary shares has been in greater volume than the trading on the ATHEX. The ATHEX is less liquid than the 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 2015, the average daily trading value on the ATHEX was EUR 86 million, while in the first four months of 2016 it was EUR 68 million (data as at 28 April 2016).

As at December 31, 2015, the aggregate market value of all shares listed on the ATHEX was EUR 46.7 billion, while as at March 23, 2016 it was EUR 39.3 billion. The market value of our ordinary shares listed on the ATHEX on December 31, 2015 and March 23, 2016 was EUR 3.1 billion and EUR 2.0 billion respectively, representing 6.7% and 5.1%, respectively, of the capitalization of all companies listed on the ATHEX. We cannot make assurances about the future liquidity of the market for our ordinary shares.

Exercise of the warrants or future sales of ordinary shares could cause the price of our ordinary shares to decline.

As at the date of this Annual Report, 245,745,725 warrants issued by the HFSF were outstanding permitting holders to acquire, for each warrant held 0.54861592129144 ordinary shares, representing a total of 134,820,022 (or 1.5%) of our ordinary shares following the completion of the 2015 share capital increase. The warrants must be exercised within a period of 54 months following their issuance on June 26, 2013. In addition, following a 36 month lock up period from the date of issuance of the warrants, the HFSF may sell or transfer the ordinary shares underlying the warrants, provided it gives applicable notice to the warrant holders. Pursuant to the HFSF's founding law, the HFSF must dispose of the ordinary shares within an initial period of five years of the date of issuance on June 26, 2013. See Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Financial Stability Fund—The Greek Recapitalization Framework". If any of the outstanding warrants are exercised or if the HFSF sells or indicates an intention to sell substantial amounts of our ordinary shares, the trading price of our ordinary shares could decline significantly. We cannot predict the effect, if any, that the exercise of warrants or future sales of our ordinary shares by the HFSF or the availability of these ordinary shares for sale will have on the market price of our ordinary shares. Following the completion of the 2015 share capital increase, we have 9,147,151,527 ordinary shares outstanding.

Shareholder composition could substantially change due to the HFSF's participation in our share capital and potential future issuance of ordinary shares pursuant to DTC Law and the conversion of CoCos.

The HFSF is our most significant shareholder, holding 40.4% of our ordinary shares outstanding as at April 20, 2016.

The disposal of the ordinary shares held by the HFSF, either on its own initiative or, where applicable, as a consequence of the exercise of the warrants held by it, may significantly alter the type and composition of our shareholder base and may lead to the concentration of significant percentages of ordinary shares and voting rights in the hands of particular investors, which may confer to such investors full control of us.

Furthermore, we may issue, starting in 2017 in respect of the fiscal year 2016, further ordinary shares to the Hellenic Republic in respect of tax credits receivable from the Hellenic Republic pursuant to the DTC Law. See "—We may not be allowed to continue to recognize the main part of deferred tax assets under IFRS as regulatory capital, which may have an adverse effect on our operating results and financial condition". Based on current law, the number of ordinary shares to be issued in respect of such tax credits will be equal to the volume weighted average price for the ordinary shares for the 30 business days preceding the conversion. This conversion of the tax credit into ordinary shares may lead to dilution of shareholders who do not, or cannot, exercise their call option on the conversion rights arising in connection with the tax credit, and their dilution may be substantial (see "—As a recipient of State Aid, our operational autonomy is constrained").

Lastly, pursuant to the terms of the CoCos, we may be required to convert CoCos and issue ordinary shares to the HFSF in the event our CET1 ratio, on a solo or a consolidated basis, falls below 7%, or if we fail to make a second interest payment (not necessarily consecutive with the first missed interest payment), or if we choose to make certain interest payments in ordinary shares or if the CoCos are outstanding on the seventh anniversary of their date of issue.

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:

In addition, our share capital may also be subject to significant dilution in the future as a result of any conversion rights issued with respect to any Tax Credits from 2017 onwards, in respect of the relevant preceding fiscal year, in accordance with the DTC Law, and the extent of such dilution will be in very large part determined by the quantum of the Tax Credit and the average market price of our ordinary shares at the time the Tax Credit is used. See "—If the Bank recognizes accounting losses in future years, its DTCs will be converted into Tax Credits and the Bank will be required to issue a material number of additional ordinary shares to the Hellenic Republic, which may result in high dilution of existing shareholders in 2017 and future periods".

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".

Our common share ADS were delisted from the NYSE, resulting in reduced liquidity for our common share ADSs.

Our ADRs representing the ordinary shares were suspended from trading on the NYSE on November 27, 2015 due to abnormally low price levels of the Company's American Depositary Shares, pursuant to Section 802.01D of the NYSE Listed Company Manual, and were delisted from the NYSE as at December 17, 2015. The ADRs are currently traded only in the U.S. over-the-counter market ("OTC") under the symbol "NBGGY". Since the delisting from the NYSE, there has been significantly lower trading volume in our ADSs in the OTC market, which may introduce further volatility into the price of our ADSs in the OTC markets and this volatility may continue into the future.

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

Under Greek Law and our Articles of Association, prior to the issuance of any new ordinary shares or convertible notes, and unless this requirement is waived by our shareholders in a shareholders meeting, 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 share capital increase 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, amended (the "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.

Non-Greek individuals and legal entity shareholders, including U.S. shareholders, may be subject to Greek tax on gains arising on the sale of shares.

Legal entity shareholder with a permanent establishment in Greece will be subject to Greek tax at a rate of (i) 29%, if the legal entity maintains double entry fiscal accounting books in Greece or (ii) 26% for the first EUR 50,000 and 33% thereafter, if the legal entity keeps single entry fiscal accounting books in Greece on gains arising from the disposition of shares if this income is effectively connected to the permanent establishment in Greece (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—EU Regulation Proposals—Taxation of Common Shares—Greek Taxation"). The capital gains of foreign physical person residents in double tax treaty countries are exempted from Greek taxation provided that they have given a tax residence certificate to their depositary. Capital gains derived from the sale of listed securities based on the date of acquisition (i.e. for listed securities acquired before January 1, 2009) and for capital gains from the disposal of listed shares based on holding percentage (i.e. when the seller holds less than 0.5% of the underlying entity's stock) are not subject to the Greek capital gains tax provided that the relevant shareholders are physical persons. Because capital gains are generally U.S. source for U.S. foreign tax credit purposes, a U.S. entity shareholder may not be able to credit any such Greek tax if it were required to be paid against its U.S. tax liability unless it has sufficient foreign source income from other sources in the appropriate basket for foreign tax credit purposes. See also Item 10.E, "U.S. Federal Income Taxation."

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 has operated a commercial banking business for 175 years. Since our founding, our business has expanded to become a large, diversified financial services group. As part of our diversification, the Bank founded Ethniki Hellenic General Insurance S.A. ("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.

On November 3, 2015, the Board of Directors approved the Capital Plan (as defined below, see "—Capital Plan"), which included the disposal of our entire stake in our Turkish subsidiary, Finansbank A.S. together with our stake in Finans Leasing, thereby disposing of all of our operations in Turkey. This transaction is expected to close within the first half of 2016, subject to customary regulatory and corporate approvals. As a result, our financial and operating data for the twelve months ended December 31, 2015 have been prepared stating separately continuing operations from discontinued operations, the latter relating to Finansbank A.S. in accordance with ASC 205-20 "Discontinued Operations". The historical financial data for the years 2014, 2013, 2012 and 2011 have been restated accordingly. Long lived assets held for sale and the liabilities directly associated with long lived assets comprise Finansbank A.S., the Private Equity Funds and Astir Palace Vouliagmenis S.A and Astir Marina Vouliagmenis S.A.

On February 15, 2013, NBG Pangaea REIC acquired 100.00% of the share capital of KARELA S.A., which owns a building in Paiania in Attica, as part of its investment policy. The consideration paid amounted to EUR 56 million in cash.

On May 10, 2013 the Bank, acquired, free of any consideration, selected assets and liabilities of First Business Bank S.A. ("FBB") which was under special liquidation following the decision 10/1/10.05.2013 of the Bank of Greece Resolution Measures Committee. The difference between the transferred assets and liabilities (the "funding gap") amounted to EUR 457 million and was covered by the HFSF by contributing to the Bank's EFSF bonds of nominal value equal to the funding gap.

On July 26, 2013 the Bank acquired, free of any consideration, selected assets and liabilities of Probank S.A. ("Probank") which was under special liquidation following decision 12/1/26.7.2013 of the Bank of Greece Resolutions Measures Committee. The funding gap amounted to EUR 563 million and was covered by the HFSF by contributing to the Bank cash equal to the funding gap.

As the Bank acquired FBB's and Probank's network of 19 and 112 branches, respectively, with the personnel and operations includes customers transactions, deposits and loans, each transaction is considered as an acquisition of an integrated set of activities and assets that is capable of being conducted and managed for the purpose of providing a return to the Bank, therefore meets the definition of a business combination of ASC 805 "Business combinations".

On December 30, 2013, the Bank, transferred to Invel Real Estate (Netherlands) II BV the 66.00% of its participation interest out of the 100.00% held in subsidiary NBG Pangaea REIC at current valuations (net asset value ("NAV")) for a total consideration of EUR 653 million. However, NBG continues to consolidate NBG Pangaea REIC by 100.00%, following the accounting guidance of ASC 840-40 "Sale-Leaseback Transactions" in combination with the accounting guidance of ASC 360-20 "Real Estate Sales".

On February 10, 2014 JERMYN was nominated as Preferred Investor pursuant to the international open competitive process for the acquisition of a majority of the share capital of Astir Palace Vouliagmenis S.A. Further to the transaction approval by the Council of Audit on June 5, 2014 the Astir SPA was executed on September 17, 2014 between NBG, the HRADF in their capacity as sellers, Apollo Investment Hold Co in its capacity as the buyer, and JERMYN in its capacity as Guarantor. Apollo Investment Hold Co is an SPV, 100.00% owned by JERMYN. The transaction is intended to close following the fulfillment of relevant conditions precedent. These include, among others, the issuance and publication of the applicable Plan in the Government Gazette. In March 2015, the Council of State reached a negative decision regarding the submitted Plan. Following these developments NBG, HRADF and the Preferred Investor initiated consultations within the context of existing competitive process, applying the relevant provisions of the Astir SPA. The relevant consultation period (as per the current Astir SPA terms) began on May 11, 2015 and was extended to

December 31, 2015 in agreement with the Preferred Investor. The consultations between the Parties resulted in an agreement which was included in an Addendum to the Astir SPA dated December 31, 2015 by means of which the original plan is substituted by a new draft Special Public Real Estate Area Development Plan. Given that the delay is caused by events and circumstances beyond NBG's control and that NBG remains committed to its plan to sell the subsidiary, the assets and liabilities of Astir Palace Vouliagmenis S.A. and Astir Marina Vouliagmenis S.A. (an 100.00% subsidiary of Astir Palace Vouliagmenis S.A.) continue to be presented as non-current assets held for sale in accordance with ASC 360 10 45 11 "Long Lived Assets Classified as Held for Sale", as the requirements and conditions specified by the standard are met.

On March 20, 2014, NBG Pangaea REIC acquired 100.00% of mutual fund "Picasso—Fondo Comune di Investimento Immobiliare Speculativo di Tipo Chiuso Riservato ad Investitori Qualificati" (Picasso—Closed End Real Estate Investment Fund Reserved to Qualified Investors). Picasso—Fondo owns building offices of a total area of 33,000 m², which are located in Rome and Milan. The consideration of the acquisition amounted to EUR 38 million of which EUR 37 million was paid in cash and EUR 1 million was recognized as payable. The acquisition was part of NBG Pangaea REIC investment policy and within the normal course of its business in order to increase its presence in the real estate market.

On April 24, 2014, the dissolution of our 100.00% subsidiary, CPT Investments Ltd was completed.

On April 24, 2014 the Bank disposed of its participation (35.00%) in the equity method investment Aktor Facility Management S.A. for a consideration of EUR 1 million.

On August 12, 2014, NBG Pangaea REIC purchased 11,654,011 shares in MIG Real Estate REIC ("MIGRE") which represented 82.81% of MIGRE's total paid-up share capital and voting rights. The consideration paid amounted to EUR 33 million which consisted of EUR 12 million cash and of 3,348,651 new redeemable common shares issued by NBG Pangaea REIC of fair value EUR 21 million.

On September 23, 2014 NBG disposed of its 100.00% subsidiary Anthos Properties S.A.

On September 26, 2014 NBG acquired 5.00% of the voting common shares of its Turkish bank subsidiary Finansbank A.S. from International Finance Corporation ("IFC") pursuant to an exercise by IFC of its put option right in accordance with the agreement between NBG and IFC dated March 29, 2007. The total consideration paid amounted to USD 343 million calculated in accordance with the pricing formula set out in the aforementioned agreement. After this transaction the Group owned 99.81% of Finansbank.

Following the preliminary agreement dated September 30, 2014 with "Sterling Properties Bulgaria EOOD", member of the Marinopoulos S.A. Group, NBG Pangaea REIC, on February 27, 2015, acquired 100.00% of the share capital of the newly established company "PLAZA WEST A.D.", which owns approximately 9,000 m² of West Plaza shopping mall in Sofia, Bulgaria. The acquisition price (as determined by an independent appraiser) amounted to EUR 11 million. As certain terms of the agreement were not met by the Seller by September 30, 2015, Pangaea proceeded with the unwinding of the acquisition, as provided for in the agreement, for a total consideration of EUR 12 million (i.e. the initial consideration EUR 11 million plus compensation of EUR 1 million). The amount of EUR 12 million was settled as a deposit to companies, members of the Marinopoulos S.A. Group, within the context of new preliminary contracts, for the acquisition by Pangaea of properties in Bulgaria and Cyprus subject to various terms and conditions being satisfied by the Sellers.

On October 22, 2014, NBG Pangaea REIC completed its mandatory tender offer to the shareholders of MIGRE, and acquired 1,951,053 shares (13.86%) of MIGRE's share capital at EUR 3.10 per share, increasing its stake in MIGRE to 96.67%. Because NBG Pangaea REIC held shares representing at least 90% of the voting rights of MIGRE after completion of the mandatory tender offer, NBG Pangaea REIC was required to acquire all the shares that were offered by the

shareholders that did not initially accept the mandatory tender offer within a period of three months from the publication of the results of the mandatory tender offer (i.e., until January 27, 2015) at a price of EUR 3.10 per share (exit right). Following that, the stake in MIGRE increased to 96.94% (stake in MIGRE as at December 31, 2014, 96.90%).

On October 1, 2015, the merger by absorption of the company NBG Pangaea REIC by the company MIG Real Estate REIC, according to the provisions of Company Law 2190/1920 and Greek Law 2166/1993, was completed by virtue of the no. 100279/1.10.2015 announcement issued by the Ministry of Economy, Infrastructure, Shipping and Tourism. The company has been renamed to "NBG Pangaea Real Estate Investment Company", with distinctive title "NBG Pangaea REIC".

On November 3, 2015, the Bank's Board of Directors approved the plan to proceed with the Finansbank Transaction. On December 21, 2015, the Bank's Board of Directors approved the sale to QNB of the Turkish Operations. Furthermore, on January 18, 2016, the Extraordinary General Meeting of the Bank's Shareholders approved the transaction, which is also in line with the relevant commitment included in the Revised Restructuring Plan (see Item 4.A, "History and Development of the Company—Revised Restructuring Plan approved by the Directorate General for Competition on December 4, 2015"). The agreed consideration for the transaction amounts to EUR 2,750 million. In addition, QNB will repay upon closing the USD 910 million of subordinated debt that NBG has extended to Finansbank. The disposal is consistent with the Group's capital action plan to address the capital shortfalls identified by the 2015 Comprehensive Assessment carried out by the ECB and satisfies the relevant commitment in the Restructuring Plan approved by the Directorate General for Competition on December 4, 2015. The closing of the transaction is subject to customary regulatory and corporate approvals and is expected within the first semester of 2016. As a result, the investment in Finansbank qualifies to be classified as a disposal group held for sale on November 3, 2015. Furthermore, Finansbank meets the definition of a discontinued operation because in accordance with ASC 205-20 "Discontinued Operations" it represents a strategic shift that has a major effect on the Group's operations and financial results.

On December 21, 2015, the Bank's Board of Directors approved the plan to proceed with the disposal of the Private Equity Funds. On February 2, 2016 the Bank entered into a definitive agreement to sell the 100% of its interests in Funds to funds managed by Deutsche Bank Private Equity and Goldman Sachs Asset Management. The agreed consideration for the transaction amounts to EUR 288 million. The disposal is consistent with the Group's capital action plan to address the capital shortfalls identified by the 2015 Comprehensive Assessment carried out by the ECB and satisfies the relevant commitment in the Revised Restructuring Plan (see Item 4.A, "History and Development of the Company—Revised Restructuring Plan approved by the Directorate General for Competition on December 4, 2015"). Closing of the transaction is expected within the first semester of 2016, subject to the approval from the Financial Conduct Authority, and antitrust authorities. As a result, the investment in the Private Equity Funds qualifies to be classified as held for sale on December 21, 2015 in accordance with ASC 360-10-45-11 "Long-Lived Assets Classified as Held for Sale", as the requirements and conditions specified by the Standard are met.

The table below sets out the Group's principal items of capital expenditure for 2013, 2014 and 2015.

Also, as part of our strategy to streamline our operations and to comply with our obligations under the Revised Restructuring Plan, 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 2013, 2014 and 2015.

As at November 1, 2014, all systemic Eurozone banks are under the direct supervision of the ECB (Single Supervision Mechanism—SSM). Before ECB assumed its supervisory responsibilities, the Bank, as all systemic European banks, was subject to an EU-wide comprehensive assessment including an Asset Quality Review ("AQR") and Stress Test with December 31, 2013 as the reference date, whose results were announced on October 26, 2014. The AQR and baseline stress test (the "Baseline Stress Test") required a minimum CET1 Ratio of 8% and the adverse stress test a minimum CET1 Ratio of 5.5% (the "Adverse Stress Test").

The adverse dynamic balance sheet stress test, which was based on the Bank's approved 2014 Restructuring Plan resulted in a CET1 ratio of 8.9%, and a capital surplus of EUR 2.0 billion (the "Adverse Dynamic Balance Sheet"). In line with ECB's guidelines, the Bank submitted on November 7, 2014 as a capital plan the Adverse Dynamic Balance Sheet scenario and the result for the nine month period ended September 30, 2014, which resulted in a capital surplus of more than EUR 2.0 billion and no further capital action was required at that time.

In accordance with the Euro Summit Statement of July 12, 2015 and ECB Decision of August 5, 2015, the ECB conducted a comprehensive assessment of the four systemic Greek banks, the results of which were announced on October 31, 2015.

The 2015 Comprehensive Assessment consisted of an Asset Quality Review ("AQR") and a Stress Test ("Stress Test") including a baseline and an adverse scenario. The AQR was conducted by reference to a static balance sheet as at June 30, 2015. The Stress Test was a forward looking exercise, following AQR adjustments, assessing the resilience of NBG's financial position to further significant deterioration of the economic environment from June 2015 to the end of 2017.

Under the baseline scenario (including AQR adjustments), the Stress Test generated an additional negative impact on NBG's regulatory capital, resulting in a stressed CET1 ratio of 6.8% relative to the minimum CET1 ratio threshold set by the ECB at 9.5% for the baseline scenario. Therefore the Baseline Stress Test implied a capital shortfall of EUR 1,576 million. Taking into account the positive impact stemming from the third 2015 quarter results, the ECB reduced the capital needs under both the baseline and the adverse scenarios by EUR 120 million. Consequently the capital shortfall for the baseline scenario was reduced to EUR 1,456 million (the "Baseline Scenario Shortfall").

Under the adverse scenario, the Stress Test (including AQR adjustments) identified a capital shortfall of EUR 4,482 million (the "Adverse Scenario Shortfall") after the reduction of EUR 120 million (an additional EUR 3,026 million compared to the baseline scenario) relative to a CET1 ratio threshold of 8.0% (compared with 5.5% in the adverse scenario of the 2014 Stress Test).

The 2015 Comprehensive Assessment, identified a Baseline Scenario Shortfall of EUR 1,456 million and accordingly, an Adverse Scenario Shortfall of EUR 4,482 million.

To address these capital shortfalls, the Bank undertook a number of capital actions to raise its CET1 capital. These capital actions were set out in a capital action plan (the "Capital Plan"), which was approved by the Board of Directors on November 3, 2015, and SSM on November 13, 2015.

In connection with the Capital Plan, the following actions were completed in December 2015 (see "—2015 Recapitalization" below):

Additionally, the Capital Plan includes the sale of the Group's Turkish Operations (although the sale was not required to be and the Bank did not expect to be completed by December 11, 2015). For the Finansbank Transaction see Item 4.A, "History and Development of the Company—Acquisitions, Capital Expenditures and Divestitures—Sale of Finansbank A.S. to Qatar National Bank S.A.Q".

On November 2, 2015, the Bank commenced the LME Offers, which were addressed to eligible holders of seven series of its outstanding debt and capital securities ("Target Securities") to purchase

such securities, in consideration for subscription of new shares in the share capital increase as part of the Capital Plan. The LME Offers expired on November 11, 2015. Settlement of the LME Offers occurred on the settlement date of the recapitalization pursuant to the Capital Plan, being December 1, 2015, raising EUR 694,906,185. Target Securities that were not tendered (or tendered and not accepted by the Bank in accordance with the terms of the LME Offers) were subject to Burden Sharing Measures (as described below) because State Aid was received by the Bank as part of the recapitalization.

On November 12, 2015, the Bank commenced a private placement outside of Greece of its new shares to be offered as part of the recapitalization pursuant to the Capital Plan (the "International Offering"), raising EUR 452,455,543.30. The International Offering closed on November 19, 2015.

On December 2, 2015, the Bank completed a public offering of new shares in Greece (the "Greek Public Offer"), raising EUR 299,955,738.30. The Greek Public Offering closed on December 2, 2015.

The 2015 recapitalization, encompassing (a) the completion of certain Capital Plan actions (being the LME Offers, the International Offering and the Greek Public Offer), (b) the subscription by the HFSF of CoCos and newly issued ordinary shares of the Bank, and (c) the Burden Sharing Measures (as set out below) mandated by the publication of Cabinet Act no 36/2015 enabled the Bank to raise capital required to satisfy the capital shortfall under the adverse scenario of EUR 4,482 million through the issuance of an aggregate of 8,911,608,218 new ordinary shares of the Bank and the issuance of 20,292 CoCos. The legal steps through which each of these elements were effected are set out below.

The Capital Plan actions in the aggregate did not fully address the Adverse Scenario Shortfall, the Bank made a formal application for State Aid on December 3, 2015. This State Aid consisted of the subscription by the HFSF of CoCos (in a principal amount equal to 75% of the amount of State Aid provided) and newly issued ordinary shares of the Bank (in respect of the remaining 25%). Consistent with EU State Aid rules, State Aid was provided by the HFSF after the application of the Burden Sharing Measures (as described below).

Since State Aid was requested by the Bank following the completion of the above-mentioned measures as part of the Capital Plan, prior to the receipt of such State Aid, the HFSF Bail-in Tool was required to be applied to convert into ordinary shares outstanding classes of the Bank's hybrid capital instruments, all subordinated liabilities and certain senior unsecured liabilities which were not mandatorily preferred by law (together, the "Burden Sharing Measures"). These Burden Sharing Measures comprised the securities issued by the Bank not subject to the LME Offers, and Target Securities that were not purchased by the Bank pursuant to the terms of the LME Offers. Cabinet Act no 45/7.12.2015, published following the recommendation by the Bank of Greece, determined by class, type, rate and amount of participation, the instruments or the liabilities that were subject to the Burden Sharing Measures.

Target Securities that were not tendered and not purchased by the Bank pursuant to the terms of the LME Offers, as well as the preference shares issued by the Bank (including both the U.S. Preference Shares and the Greek State Preference Shares) and outstanding at that time were included in the Burden Sharing Measures which resulted in the mandatory conversion into ordinary shares of the preference shares issued by the Bank and outstanding at that time, outstanding debt instruments, all subordinated liabilities and certain senior unsecured liabilities which are not mandatorily preferred by law. More specifically, as per Art 6a of the HFSF Law, the Cabinet Act no 45/2015 set out, inter alia the terms under which: (a) the guarantees written by NBG to the holders of the debt instruments issued by NBG Funding Ltd were converted to NBGs' common shares, and (b) the total amounts of the notes issued by NBG and held by NBG Funding Ltd were written down in

full due to the above capitalization of the Guarantees. Therefore, according to Cabinet Act 45/7.12.2015 the contingent liabilities assumed by NBG by providing subordinated guarantees to third parties in connection with the issuance of each of the debt instruments issued by NBG Funding Ltd were converted to new common shares of NBG. The value of the equity shareholding in NBG delivered to the holders of the debt instruments was equivalent to 30% of the par value they hold. (See also Note 24 to the U.S. GAAP Financial Statements)

The Burden Sharing Measures, applying on the terms set out in Cabinet Act no 45/7.12.2015, resulted in the mandatory conversion into newly issued ordinary shares of the Bank of the U.S. Preference Shares at the rate of conversion determined by the Cabinet Act no 45/7.12.2015, being 100 newly issued ordinary shares per EUR 100.00 in outstanding nominal amount (liquidation preference) of the U.S. Preference Shares. As the U.S. Preference Shares were denominated in U.S. Dollars, an exchange rate of 1.0579, the ECB euro/U.S. Dollar exchange reference rate as at November 30, 2015, was applied. As a result, each U.S. Preference Share, having a nominal amount (liquidation preference) USD 25.00, was converted into 23.631723 newly issued ordinary shares of the Bank.

The Burden Sharing Measures also resulted in the mandatory conversion, on the terms set out in Cabinet Act no 47/7.12.2015 of the Greek State Preference Shares, issued under Pillar I of the Hellenic Republic Bank Support Program, into 1,603,700,987 newly issued ordinary shares of the Bank, which were transferred to the HFSF by operation of law.

The result of the LME Offer and the Burden Sharing Measures in respect of the Target Securities were as follows:

Issuer			Currency

			Amounts in millions
Senior Unsecured Notes:
NBG Finance Plc	100	%	EUR	701	667	34
Subordinated fixed rate notes:
NBG Finance Plc	75	%	EUR	18	1	17
NBG Funding Ltd—Series A	30	%	EUR	18	7	11
NBG Funding Ltd—Series B	30	%	EUR	19	6	13
NBG Funding Ltd—Series C	30	%	USD	14	8	6
NBG Funding Ltd—Series D	30	%	EUR	23	9	14
NBG Funding Ltd—Series E	30	%	GBP	9	1	8

In the context of the implementation of the Capital Plan, as stated above, on November 17, 2015, the Extraordinary General Meeting of the Bank's Shareholders approved, among other matters:

On December 9, 2015 the Bank's Board of Directors confirmed that the total share capital increase was partially covered, in accordance with art. 13a of Company Law 2190/1920, i.e. it was covered by EUR 2,192,372,169.30 through the issuance of 7,307,907,231 new shares. In the same meeting the Bank's Board of Directors further certified that the aforementioned partial coverage is divided as follows:

In accordance with the terms of Cabinet Act no 45/7.12.2015 all of the Bank's preference shares were mandatorily converted (in accordance with the relevant provisions of article 6a of the HFSF Law) to 1,603,700,987 ordinary shares of the Bank. All the outstanding non-cumulative, non-voting, redeemable U.S. Preference Shares (i.e. 12,639,831 U.S. Preference Shares outstanding as at December 12, 2015) were converted into 298,700,987 ordinary shares and all the 270,000,000 outstanding Greek State Preference Shares issued in favor of the Hellenic Republic, in accordance with the Greek Law 3723/2008 were converted into 1,305,000,000 ordinary shares acquired by the HFSF by operation of law.

The Bank's Board of Directors in its meeting on December 9, 2015, decided, acting within the context of the relevant decision of the November 17, 2015 Extraordinary General Meeting of the Bank's Shareholders, the issuance of a convertible bond loan of a total amount of EUR 2,029,200,000 by issuing 20,292 CoCos, at a nominal value and subscription price of EUR 100,000 each, which were all acquired by the HFSF, in accordance with par. 2 and 5c of the HFSF Law, Cabinet Act no 36/2015 and Greek Law 3156/2003, each as currently applicable. Following the execution of the relevant subscription agreement and the Bond Loan Program concluded between the Bank and the HFSF, the Bank's Board of Directors in its meeting on December 9, 2015 certified the contribution of ESM Notes

valued at EUR 2,029,200,000 that fully covered the amount of the aforementioned bond loan, pursuant to the evaluation of such notes, in accordance with art. 7 par. 3 of the HFSF Law, as applicable. The terms and conditions of the CoCos issued by the Bank to the HFSF are as prescribed in Cabinet Act no 36/2015.

Revised Restructuring Plan approved by the Directorate General for Competition on December 4, 2015

The Group is subject to EU state aid rules in light of the aid rules and regulations received from the HFSF and the Hellenic Republic. These rules are administered by the Directorate General for the Competition of the European Commission. Under these rules, the Bank's operations are monitored and constrained pursuant to the terms of the Revised Restructuring Plan, which aims to ensure the Bank's return to long-term viability.

In 2014, the European Commission approved a Restructuring Plan (the "2014 Restructuring Plan") regarding the Bank as a result of the State Aid measures taken in favor of the Bank, after the severe losses it suffered due to its participation in the PSI. Further to the worsening of the economic climate in Greece during the first semester of 2015 and as a result of ECB's subsequent 2015 Comprehensive Assessment resulting in NBG's need for new State Aid, NBG was required to submit to the European Commission a Revised Restructuring Plan.

As set out above (see "—2015 Comprehensive Assessment"), the Comprehensive Assessment carried out by the ECB for the four systemic Greek banks, the results of which were announced on October 31, 2015, identified a total capital shortfall for NBG (after taking into account the positive impact of the third quarter 2015 results) under the baseline and adverse scenarios of EUR 1,776 million and EUR 4,482 million, respectively.

NBG succeeded in covering an amount of EUR 1,776 million of its capital needs by private means (the LME Offers, International Offering and Greek Public Offer), with the remaining amount being covered as a result of the Burden Sharing Measures implemented by the Cabinet Act no 45/2015. The remaining balance of its capital needs against the Adverse Scenario Shortfall amounting to EUR 2,706 million was covered by State Aid through the HFSF in the form of a combination of subscription for ordinary shares and CoCos, as prescribed by the HFSF Law. The additional State Aid in the amount of EUR 2,706 million to NBG was approved on December 4, 2015, by the European Commission, under EU state aid rules, on the basis of the Revised Restructuring Plan.

The Revised Restructuring Plan includes a number of commitments to implement certain measures and actions which have to be completed during the period 2015–2018 (the "Commitments"). The Commitments relate both to domestic and foreign operations of the NBG Group. Compared to NBG's previous Restructuring Plan (approved in July 2014), these Commitments to extended operational restructuring, amendments to the Commitment's deadlines, and include commitments for further disposals of foreign operations.

For domestic operations, the Commitments relate to constraining operating expenses (including the number of employees and branches), decreasing the cost of deposits and maintaining a level of loans-to-deposits ratio below a maximum ratio. Other Commitments relate to adhering to an investment policy and the divestment from certain domestic as well as international operations.

The implementation of the Commitments set out in the Revised Restructuring Plan is monitored by the Monitoring Trustee.

We are one of the four systemically significant banks in Greece and we hold a significant position in Greece's retail banking sector, with 526 branches and one premium banking branch, and 1,444 ATMs as at December 31, 2015. We offer our customers a wide range of integrated financial services, including:

In addition, we are involved in various other businesses, including hotel and property management.

The Bank is our principal operating company, representing 81.3% of our total assets, excluding long-lived assets classified as held for sale, as at December 31, 2015. The Bank's liabilities represent (85.3)% of our total liabilities, excluding liabilities directly associated with long-lived assets held for sale, as at December 31, 2015. While the Bank conducts most of our banking activities, it is supported by eight non-Greek banking subsidiaries: 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"), Banka NBG Albania Sh.a. ("NBG Albania"), South African Bank of Athens Ltd. ("SABA") and NBG Bank (Malta) Ltd. ("NBG Malta").

We hold top positions in many financial services products in Greece. As at December 31, 2015, we had significant market share of mortgage loans in Greece, with a percentage of 26.1%, whereas according to our internal analysis of published information of the Bank of Greece, we hold a significant position in core⁽³⁾ deposits, with a market share of 32.3%. We are also third in mutual fund management with a market share of 12.6% 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. Banking activities in Greece include the Bank's domestic operations, Ethniki Leasing, Probank Leasing S.A. ("Probank Leasing") and Ethniki Factors S.A. ("Ethniki Factors"). The Group's Greek banking operations account for 86.9% of our total lending activities as at December 31, 2015 (the "Greek Banking Loans") and for the 90.0% of our deposits (the "Greek Banking Deposits"). 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 Greek Banking Deposits as at December 31, 2015:

As at December 31, 2015 we operated in Greece through 527 branches (including one premium banking branch). As at December 31, 2015, we had 1,444 ATMs, of which at least 589 were situated in key locations such as supermarkets, metro stations, shopping centers, hospitals and airports (56% of our ATMs are equipped with cash deposit devices). During 2015, the total number of ATM transactions reached approximately 130 million with a total value of approximately EUR 17.3 billion compared with approximately 112 million transactions in 2014, with a total value of approximately EUR 16.5 billion. In addition, we have developed further alternative distribution channels, such as an e-banking platform targeted at both corporate and retail clients. During 2015, the total number of internet banking users reached 1 million. The total number of electronic transactions during 2015 was approximately 17 million with a total value of approximately EUR 25.8 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. We also operate an "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 the Group level in all countries in which we operate, which is intended to create convergence across our distribution channels through the utilization of a common platform for cross border products and services. In 2012, we launched a new "i-bank" store. Currently, we operate four "i-bank" stores (two in Athens and two 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. Moreover, the Bank proceeded with the commercial launch of a new "i -bank" store during 2015 located in the center of Larissa, the largest city of the Thessaly region of Greece. During 2015, the Bank launched the new i-bank Internet Banking for businesses, while in February a fully updated application of i-bank Mobile Banking for smartphones and tablets was introduced. As at December 31, 2015, the "i-bank" stores have received more than 780 thousand visitors.

The Bank's branches are located in almost every major city and town in Greece. Approximately 48% of the Bank's branches are located in the 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, 2015, the Bank operated 255 full banking branches, 271 retail banking branches and one premium banking branch.

We participate in DIAS Interbanking Systems S.A., which currently has 25 banks as shareholders and direct members, 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 the customers of its members.

We use a variety of marketing channels to maintain and enhance our market position, including radio, television, press and internet advertising and the distribution of 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.

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.

Savings and investment products of the Bank are offered both in euro and in other currencies. In addition to other products, the Bank offers investment products with yields that are higher than our basic deposit products, including capital-guaranteed principal products, Greek government bonds and other bonds from the Bank's proprietary portfolio, repurchase agreements between the Bank and our clients 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 Investment & Asset Management".

The Bank offers payment services to clients participating in all local interbank payment channels. The Bank is 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. The Bank's Cash Management service offering in Greece is Single Euro Payments Area compliant with Directive 2007/64/EC on Payment Services ("PSD"), and also leverages extensively the Bank's branch network in providing customers with online transaction processing to facilitate cash gathering.

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 continued to apply a 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 2014 and 2015.

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 a diverse depositor base in Greece, providing the Bank with a large, stable and low-cost source of funding.

Since 2010, the Bank has sought to address the continued deterioration of its lending portfolio, and to assist customers willing to repay their loans by offering more competitive modification programs depending on each customer's need and repayment ability.

In 2015 the Bank mainly focused on offering competitive and flexible debt restructuring solutions. As a result, the balance of its consumer loan portfolio (auto financing, other, consumer and credit cards) decreased by 3.7% from EUR 5,612 million as at December 31, 2014 to EUR 5,403 million as at December 31, 2015.

The Bank's efforts are focused on effective management of its existing loan portfolio in order to prevent further deterioration through the design and implementation of debt restructuring packages to existing customers, which offer a fractional payment program with lower installments adjusted to the borrowers' financial status for a pre-agreed period of time. 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 a restructuring, all consumer loan and credit card exposures of a customer are consolidated into a single fixed-term consumer loan. 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 exposure with real estate property or provide an additional down payment. The maturity of these restructured products varies and can reach 45 years if additional collateral is obtained. For further detail regarding restructured loans, see Item 4.E., "Selected Statistical and Other Information—Credit Quality and Risk Management—Risk Management—Credit Review Policies—Non-accruing Loans, Allowance for Loan Losses, and Loan Loss Experience—Modifications and TDRs".

Consumer credit products proposed by the Bank mainly consist of special purpose loans where customers are encouraged to offer collateral (such as registration of mortgage prenotation, deposits in euro or retention of ownership) in order to improve the terms of their loans. Applications are approved under a strict set of underwriting criteria, which indicatively include stringent application entry requirements, examination of customer's depository or investment relationship within the Bank and pursuit of additional security (guarantor and/or collateral) if necessary.

Regarding new business development, the Bank is focused on the promotion of special purpose consumer loans such as "auto loans" and "green loans" for energy improvements at home or for purchases of hybrid cars, as well as on the further growth of its debit and prepaid cards portfolio and the strengthening of its position in the card clearing market.

Due to the recession, house prices have declined since 2008 through the fourth quarter of 2015 cumulatively by 41.2%⁽⁴⁾, with a decelerating trend during 2015. Capital controls applied as from June 29, 2015 as well as the austerity measures introduced by the Greek Government had a negative impact on the economic environment in 2015. In particular, the negative impact on new mortgages still remains despite the partial lifting of the capital control measures.

In the year ended December 31, 2015 new lending amounted to EUR 57 million compared to EUR 44 million in 2014 and EUR 28 million in 2013. Despite the adverse macroeconomic conditions the increase of new lending in 2015 is close to 29.5% compared to 2014. Average Loan-to-Value ratio ("LTV") for 2015 new originations was 55.8%, compared to 53.8% in 2014 and 54.5% in 2013 (maximum LTV suggested by the Bank of Greece at 75%), and Payment-to-Income ratio ("PTI") at 23.1%, compared to 24.1% in 2014 and 21.0% in 2013 (maximum PTI recommended at 40% by the Bank of Greece). Approval rate for mortgage applications in 2015 was 75%, higher than in 2014 (63%)

and 2013 (49%), due to the higher quality of submitted applications and better screening at early stage of applications. Pricing in 2015 stood at an average spread of 365 basis points compared to 361 basis points in 2014 and similar spread in 2013.

As at December 31, 2015, the residential mortgage loan portfolio, before any provision for impairment, was EUR 16.7 billion, compared to EUR 17.4 billion at December 31, 2014 and EUR 17.7 billion at December 31, 2013. In 2015, past due loans continued to rise from 34.4% at December 2014 to 36.4% at December 31, 2015 mainly due to the deleverage of the mortgage portfolio. Although capital controls had a temporary impact on the quality of the Bank's mortgage portfolio this was less pronounced at year-end 2015. Moreover, some of the amendments applied by Greek Laws 4335 and 4336 / 2015 (relating to foreclosure / auction procedure, stricter eligibility criteria in the bankruptcy law, waive of the privileged ranking of public sector in auctions) are expected to have a gradually positive effect on the banking sector.

During 2015, the Bank continued its efforts to efficiently manage its existing loan portfolio and contain delinquencies by applying a customer-centric approach. This effort resulted in a decline of past due loans formation through 2015 and the first two months of 2016. The solutions offered include term extension up to 45 years, interest-only payment period and fractional payment adjusted to the borrowers' economic capacity. No capital relief is offered and consistency in loan repayment is rewarded. All aforementioned options are intended to secure debt viability and smooth loan repayment. The "split & freeze" product, which was introduced in 2015, provides longer term mortgage solutions for borrowers with weak economic background.

The Code of Conduct which came into force in 2015 following Greek Law 4224/2013 provides a comprehensive approach towards restructuring, putting a specific framework and a set of rules around the restructuring process, covering communication and provision of information to borrowers, supporting organizational structure, offering suitable and sustainable solutions and reporting requirements to supervisory authorities. Borrowers' sustainability is an essential factor in the restructuring policy, with the introduction of the minimum living standards requirement, playing a key role in defining borrowers' capacity to pay and thus choosing the most appropriate solution. Additionally, the notion of "cooperative borrower" is expected to assist in finding a mutually acceptable and suitable mortgage solution.

Restructuring measures occur in situations in which the borrower is unable to meet the terms and conditions of a contract due to financial difficulties. Taking into consideration these difficulties, the Bank decides to modify the terms and conditions of the contract to provide the borrower the ability to service the debt or refinance the contract, either totally or partially.

As at December 31, 2015, residential mortgage loans modified in troubled debt restructuring amounted to EUR 6.1 billion from EUR 3.1 billion as at December 31, 2014. The average duration for this portfolio is 34 years, or eight years more than the non-restructured portfolio, with average spread of 234 basis points (47 basis points higher than the non-restructured portfolio). A strong impetus in mortgage forbearance programs is expected due to full application of the Code of Conduct with favorable results in reducing past due loans.

As a result of the implementation of the Third Program signed in 2015, mortgage activity is expected to remain weak, as we expect incomes to further decline due to higher taxation and pension cuts. We estimate that house prices are expected to keep falling in 2016, possibly stabilizing by the end of the year.

The Small Business Lending Unit ("SBL Unit") constitutes a division of retail banking and manages credit provision to small businesses with annual turnover of up to EUR 2.5 million and total exposure up to EUR 1 million. SBL Unit operates through three business credit centers in the main

urban centers (Athens, Thessaloniki and Patras), which handle credit applications, in accordance with the Bank's applicable Credit and Collection policy and approved authority levels.

As at December 31, 2015, the Bank's Small Business Lending gross outstanding portfolio amounted to EUR 3,774 million, decreased by 3.0% compared to EUR 3,892 million at December 31, 2014.

With effect from the second half of 2015, in accordance with Greek Law 4224/2013 and Bank of Greece Executive Committee Directive #42, requests from individuals applying for modifications to be handled by a newly established individuals restructuring division, as part of the Retail Collections Unit.

The SBL Unit in 2015 continued to offer lending solutions, covering a full range of business credit needs, either in the form of revolving facilities for the coverage of working capital needs (liabilities linked to Small Medium Enterprises ("SME's") trading cycle) or in the form of short-, medium- or long- term fixed loans for financing investment needs or for the enhancement of business liquidity. New loans granted to SMEs totaled to EUR 166 million for the year ended December 31, 2015.

In addition, the SBL Unit participated in initiatives for the improvement of competitiveness and the enhancement of SME liquidity and specifically in the following co-financed and other state guarantee and funded programs:

Furthermore, recognizing the dynamic and growth potential of the agricultural sector, NBG has prepared a special "Contract Farming" financing program that modernizes the entire production and trade cycle of buyers and suppliers of agricultural and livestock products.

This program aims at financing farmers and livestock breeders to cover part of the production cost of their products under the condition that they have concluded sale contracts with selected trading and manufacturing businesses. Under this program, EUR 3 million were granted to more than 1.000 producers of primary production sector.

SBL Unit also supported SBLs who experienced difficulties in early stages,—by agreeing more favorable terms and conditions for the rescheduling of their debts⁽⁵⁾. The main characteristics of such programs are: the granting of a grace period of up to two years, during which the borrower pays only interest, the extension of up to 20 years on the maturity of loan accounts and the application of lower interest rates in case that new collateral is pledged. In addition, the SBL Unit has formulated all necessary procedures in order to comply with newly established Code of Conduct of Greek Law 4224/2013.

As at December 31, 2015, the SBL Unit's customers that had been settled under any relevant program with a balance of EUR 560⁽⁶⁾ million.

Finally, in the period immediately after the imposition of the bank holiday and the capital controls by Greek Government (June 29, 2015), NBG put in force several measures in order to facilitate bank transactions, mitigate negative impacts for its customers and, at the same time, safeguard its liquidity. The SBL Unit has participated actively in the abovementioned activities.

The Retail Collections Unit ("RCU") was established in 2010 as the independent unit of the Bank responsible for the management of past due and troubled retail loans clients. It is a centralized function with end-to-end responsibility for the management of past due loans, from the first day of delinquency all the way to the eventual write-off. As at December 31, 2015, 1,536 staff were employed on a full-time equivalent ("FTE") basis in connection with the management of the retail past due loan portfolio, including 592 FTEs in the branch network and 333 FTEs in external collection agencies and external law firms. As at December 31, 2015, the retail past due loan portfolio under RCU management amounted to EUR 14.1 billion.

RCU's strategy for managing delinquent retail clients is performed through a combination of channels, such as the internal collections center ("ICC"), dedicated personnel in the Bank's branch network, external debt collection agencies and external law firms. It makes extensive use of information technology, call strategy and monitoring tools in ICC to perform rigorous collections in the early stages of delinquency, while outsourcing certain (typically smaller, consumer credit) cases to external agencies which are given incentive based remuneration. It utilizes a set of key performance indicators to implement restructuring solutions in respect of borrowers, which involve an analysis of such factors as the income and living expenses of the borrower, the presence and amount of collateral and the days past due of the loan. Depending on the risk profile and delinquency status of the loan, RCU determines the strategy in accordance with a statistically driven framework. Tools employed by the RCU in respect of restructurings include collateral addition, incentives to remain current (such as forgiveness of interest or capital at maturity), maturity extension, monthly payment reduction for 3–6 years, or partial debt freezes ("split balance"). In the case of late delinquencies, settlements may be implemented, which include forgiving of off-balance-sheet interest as well as a percent of capital depending on the collateral and duration of the repayment schedule.

For the period ended December 31, 2015, the RCU conducted restructurings in the amounts of EUR 1,582 million, EUR 329 million and EUR 166 million related to mortgage, consumer and small business loans, respectively.

The Group offers 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.

The Bank extends financing to all sectors of the economy. As at December 31, 2015, domestic commercial lending amounted to EUR 25.9 billion and represented 54.1% 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 2.6 billion as at December 31, 2015, representing 5.5% of its domestic loan portfolio.

The Bank lends primarily in the form of short term credit lines and medium/long term loans. Apart from financing, the Bank provides standby letters of credit and financial guarantees for its customers, which amount to EUR 3.0 billion as at December 31, 2015.

During 2015, the Bank provided the necessary liquidity to existing and new sustainable investments aimed at enhancing the competitiveness, innovation and outward orientation in business and new jobs creation. As a result of the ongoing economic crisis in Greece, the Bank also provided modification solutions to viable borrowers facing temporary difficulties due to the crisis, always on the basis of availability of additional collateral, new equity participation on behalf of the shareholders as well as adequate loan pricing.

The Bank in 2016 will maintain its support of the development of Greek entrepreneurship, providing liquidity to viable SMEs, through the available financial engineering instruments, contributing to the utilization of the National Strategic Reference Framework ("NSRF") 2007-2013 and also attempts to broaden partnerships with existing international and European development organizations, with a view to exploit any potential source available for the financial support of SMEs, derived either from the resources of the new programming period 2014 - 2020, or by the European Fund for Strategic Investment, among others.

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 key participants in Greek shipping finance. The Bank's shipping finance activities are carried out almost exclusively through its dedicated Piraeus-based unit.

As at December 31, 2015, outstanding shipping loans (mainly concerning wet and dry bulk shipping) were EUR 2.4 billion. Shipping exposure represents 9.1% of the Bank's total commercial loan portfolio.

The Bank has traditionally provided bilateral and syndicated long-term financing, mainly to dry bulk, wet bulk and, to a lesser extent, liner business with a consistent view to minimize risk and enhance the portfolio's profitability. Nearly all of the Bank's shipping loans are fully secured by vessels.

For 2015, the Bank maintained its exposure by participating in new transactions with accredited customers with the same strict terms as in 2014 regarding vessel quality and equity contribution. Loan modifications were implemented, reflecting current market conditions and low freight rates in the dry bulk sector. During 2016 the Bank will again focus on reprofiling credit facilities taking into account the continuing unfavorable market conditions in the dry bulk sector and is aiming for the conclusion of the restructuring of the main Greek ferry companies.

The shipping industry is highly cyclical, experiencing volatility in revenues and cash flows resulting from changes in the demand and supply of vessel capacity. Over the past several years, freight rates in main shipping segments have remained at relatively low levels with the dry markets suffering the most. The dry bulk shipping is heavily affected by increased tonnage supply and modest demand for shipping services, which is expected to continue in 2016 as well. On the tankers side, after a strong fourth quarter of 2014, the wet markets gained further momentum in 2015 and crude tanker rates rose to their highest levels since 2008 with the outlook for the near term being encouraging.

The Bank's project finance loan portfolio includes loans to large infrastructure projects both in Greece and abroad (mainly in Europe). Due to the current economic environment, there has been limited activity in the field of project finance, with the overall size of the relevant portfolio reducing

marginally at EUR 408 million as at December 31, 2015, compared to EUR 413 million as at December 31, 2014.

The voluntary deleveraging effort undertaken by the Bank since the beginning of 2011 continued in relation to its international portfolio for the period of January 1, 2015 to December 31, 2015, during which no new loans were advanced for projects outside Greece, while during the same period the effort to reduce positions in loans with low margins resulted in a decrease of the international loan portfolio by 2.4% in EUR denominated basis. During the same period, the domestic loan portfolio remained practically stable at EUR 206 million (0.1%).

Through an operational agreement signed in December 2011 between the Bank and the European Investment Bank ("EIB"), the Bank, acting as an Urban Development Fund ("UDF"), has been awarded the management of EU Structural Funds under the Joint European Support for Sustainable Investment in City Areas initiative—(the "JESSICA")—for three lots (out of ten lots in total for Greece) and an operational Program "Environment and Sustainable Development" amounting to a total of EUR 83 million (32.9% of total JESSICA funds for Greece). JESSICA funds, along with the Bank's and other private funds, were intended to be used during the period of 2012 to 2015 to make repayable investments in the respective regions. In May 2012 the UDF issued a Call for Proposals for selecting final recipients to be financed by the UDF. Following this call, the UDF received until the end of 2015, 48 investment proposals, of a total budget of EUR 442 million and UDF-requested funds of EUR 176 million. On December 31, 2015 the project portfolio amounted to four projects with total construction budget of EUR 131 million and UDF-requested funds of EUR 41 million. Total disbursements to signed projects during 2015 amounted to EUR 23 million with total loans outstanding on December 31, 2015 amounting to EUR 31 million. All aforementioned projects as at December 31, 2015 were in the construction phase. During 2015 credit approval was received for one more project with a total budget of EUR 9 million and UDF requested funds of EUR 6 million. The UDF is currently focusing on the completion of disbursements to signed projects as well as on the signing and full disbursement of UDF funds to the fifth project.

The Bank has established the SAU, in order to effectively manage troubled and past due corporate loans and have full responsibility for managing such loans. Since the first quarter of 2015, the SAU has been reported as a separate segment and maintains a management structure independent of other Group businesses.

The corporate loan portfolio managed by the SAU amounted to EUR 5.8 billion as at December 31, 2015 with additional EUR 0.5 billion of leasing and factoring facilities as well as exposures relating to letters of guarantee/ credit.

The SAU proposes customized loan modification and Troubled Debt Restructuring ("TDR") solutions to enterprises that are facing difficulties meeting their obligations and have operational and financial weaknesses.

There is a clear prioritization strategy per portfolio managed, based on ageing, size, collateralization levels and status of legal actions. The SAU assesses the creditworthiness of the borrower using analytical tools and metrics, taking into consideration a number of factors, including but not limited to: cooperativeness of the borrower, the size of exposure, the borrower's viability and debt repayment capacity, collateral levels, market and competitive conditions and the industry in which it operates. Based on the results of its assessment, the SAU proposes customized loan modification and restructuring solutions for the borrowers' loans, also taking into consideration the results of a "net present value" tool. A number of restructuring products and debt settlement solutions for small non-denounced and denounced customers respectively are also in place.

As at December 31, 2015, total TDR loans and advances to customers amounting to EUR 1,828 million are under SAU management.

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, 2015, 38.5% of the finance lease receivables of Ethniki Leasing were to the trading and services sector, 51.3% to industry and mining, 9.1% to construction and real estate and 1.1% to other sectors. As at and for the year ended December 31, 2015, Ethniki Leasing had total assets of EUR 473 million and interest income of EUR 22 million, before elimination of intercompany transactions and balances, compared to EUR 530 million and EUR 24 million, respectively in 2014.

Probank Leasing leases land and buildings, machinery, transport equipment, furniture and appliances, computers and communications equipment. As at December 31, 2015, 77.2% of the finance lease receivables of Probank Leasing were to the trading and services sector, 2.7% to construction and real estate, 7.3% to industry and mining and 12.8% to other sectors. As at and for the year ended December 31, 2015, Probank Leasing had total assets of EUR 114 million and interest income of EUR 8 million, before elimination of intercompany transactions and balances, compared to EUR 155 million and EUR 8 million, respectively in 2014.

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 its strategic decision to expand its factoring operations in Greece. The year 2015 was the seventh consecutive financial year during which Ethniki Factors continued to focus on enhancing liquidity to the Group corporate customers maximizing synergies with the Bank. Portfolio performance remained strong despite adverse economic environment. Ethniki Factors offers a comprehensive range of factoring services to provide customers with the flexibility they need to cope with recession difficulties Greek economy faces over the last seven years.

In 2015, the NBG Securities' Investment Banking Division continued to provide services mainly focused on corporate finance and equity capital markets as the challenging economic conditions in Greece (slowdown of the domestic activity, impact of capital controls, political uncertainty etc.) have adversely affected the volume of announced transactions while debt capital markets have borne the brunt of this crisis. In that context, we served as financial advisor for the merger by absorption by MIG Real Estate of NBG Pangaea REIC and its indirect listing on ATHEX.

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 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 its subsidiaries enter into derivatives transactions for economic hedging purposes or in response to specific customer requirements.

The Bank is active in the primary and secondary trading of Greek government securities, as well as in the international Eurobond market, especially EFSF and ESM issues. 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 and of the Group of EFSF-ESM Securities Primary Dealers which was established in 2010.

NBG Private Banking ("Private Banking") is the Bank's dedicated arm that responds to the needs of high net worth and ultra-high net worth clients. We operate out of 8 different locations in Greece and two international Private Banking centers in London and Malta. Our products and services cover a wide spectrum, from traditional banking all the way to different tailor made investment mandates. An independent team of 5 investment specialists equipped with an extended open architecture platform, along with a highly trained team of 35 experienced client relationship officers, are committed to offering first-class services that maximize client aspirations.

Our Private Banking operations leverage the expertise, resources, know-how and capabilities of the NBG Group to service client needs and generate benefits in managing their wealth. Our commitment focuses in delivering value to our clients while remaining sensitive to and scrutinizing and closely monitoring our client's risk-return profile.

The Bank offers custody services to domestic and foreign institutional clients, as well as to its retail customer base, covering the Greek and most foreign markets. For the coverage of international markets the Bank cooperates with top global custody providers, while in countries of SEE where it has a presence, the Bank is using as sub-custodians its subsidiaries in the region.

The range of services the Bank offers includes: trade settlement, safekeeping of securities, corporate actions processing, income collection, proxy voting, tax reclamation, customized reporting, as well as underwriting and paying agent services.

Since June 2015, when Bank of Greece, in its capacity as Central Securities Depository for debt instruments issued by the Hellenic Republic, migrated to T2S, the Bank has adjusted systems and processes accordingly and is fully operative in the new environment.

The Bank is also in the process of broadening its activities, oriented to provide innovative high quality services to domestic investment services companies.

As at December 31, 2015, the Bank serviced 60 domestic institutional clients (three mutual funds, four asset management companies, 12 insurance companies, five brokerage companies, 27 pension funds and nine other companies), 21 foreign customers and approximately 314,000 retail customers.

Within the context of the long lasting economic crisis and capital controls implementation, custody business, especially that of Greek local providers, has been considerably impacted. Thus, there was negative impact on the Bank's custody, due to significant downsizing of the relevant transactions, decrease of securities values, as well as transfer of the relevant business to other international custodians affected by specific foreign customers.

In recognition of the quality custody services offered, to both cross border/non-affiliated and domestic clients, the Bank is positioned between the top providers in the Greek market, in the Agent Banks Surveys of the "Global Custodian" magazine, for many consecutive years.

The Group's domestic fund management business is operated by NBG Asset Management S.A., 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.

NBG Asset Management offers 19 investment funds under the brand name Delos, two under the NBGAM brand name, one under the N.P. Insurance brand name and three under the NBG International SICAV brand name which are registered in Luxembourg. 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 at December 31, 2015 NBG Asset Management's total assets under management in mutual funds and discretionary asset management were EUR 1.4 billion. Its market share in mutual funds in Greece was 12.6% as at December 31, 2015, compared to 14.0% as at December 31, 2014. (Source: Hellenic Fund and Asset Management Association—report of December 31, 2015). The funds belong to a client base comprised of approximately 83 institutional and over 45,000 private investors.

National Securities S.A. ("NBG Securities") was established in 1988 and constitutes the brokerage and investment banking arm of NBG Group. NBG Securities offers a wide spectrum of investment services to both individual and institutional customers.

In 2015, NBG Securities had a market share of 8.37% of trades brokered on the ATHEX, ranking third in terms of total trading value, according to data from the Athens Stock Exchange.

The provision of investment services in Greece has become increasingly competitive, with a number of banks and brokerage houses participating actively in this area. NBG Securities network consists of seven branches, three of which are in London, Bucharest and Nicosia.

We operate, as a Group, in 11 countries outside Greece. As at December 31, 2015, our international network comprised 1,218 branches (including foreign subsidiaries and Bank branches in the United Kingdom, Egypt and Cyprus), which offer traditional banking services and financial products and services. The Bank has nine commercial banking subsidiaries in Turkey, Bulgaria, Romania, FYROM, Serbia, Albania, Malta, Cyprus and South Africa. The Bank's subsidiaries in Turkey are expected to be sold is expected to close on or before June 30, 2016, as discussed further in 4.A, "History and Development of the Company—Acquisitions, Capital Expenditures and Divestitures".

The Bank's international operations include the Bank's branches in Egypt and Cyprus, as well as banking subsidiaries in eight countries. UBB in Bulgaria, Banca Romaneasca in Romania, Stopanska Banka in FYROM, Vojvodjanska in Serbia, NBG Cyprus in Cyprus, NBG Malta Ltd ("NBG Malta") in Malta, NBG Albania in Albania and SABA in South Africa, along with other subsidiaries, primarily in the leasing sector. Our international operations contributed EUR 333 million or 22.2% of net interest income before provisions for loan losses of the Group and accounted for EUR 9.3 billion or 12.4% of the Group's total assets excluding long-lived assets classified as held for sale as at and for the year ended December 31, 2015. Total loans were EUR 7.0 billion at December 31, 2015, a decrease of 3.0% from EUR 7.2 billion at December 31, 2014, whereas deposits (excluding interbank deposits) decreased to EUR 6.3 billion at December 31, 2015, in comparison to EUR 6.7 billion at December 31, 2014.

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, 2015, the Bank had 19 foreign branches in three countries, including one in the United Kingdom, one in Cyprus and 17 in Egypt. At December 31, 2015, net loans of the Bank's Cyprus and Egypt operations were EUR 175 million and EUR 107 million, respectively. The table below provides selected financial information of the Bank's foreign branches (excluding the United Kingdom branch) as at and for the year ended December 31, 2015:

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 other international operations.

UBB is a commercial bank with headquarters in Sofia, which provides retail and corporate finance services in Bulgaria. The entity was acquired in 2000 and as at December 31, 2015 the Bank held a 99.91% interest in UBB. At December 31, 2015, UBB's distribution network included 198 units: 124 "Type 1" (retail business), 27 "Type 2" (retail and micro business), 17 "Type 3" (retail, micro and SME business), 9 "Type 4" (SME business) and 21 offices and operated 696 ATMs and 9,097 POS terminals in Bulgaria.

During 2014, the Group has initiated proceedings for the disposal of its shareholding in UBB AIG. UBB owned 30.00% of the entity's share capital as at December 31, 2015. The disposal was completed on January 4, 2016.

Selected financial information with respect to UBB as at and for the year ended December 31, 2015, 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 110 banking units in Bucharest and other cities in Romania as at the end of 2015. The Bank acquired Banca Romaneasca in October 2003 and as at December 31, 2015 held 99.28% of its share capital.

Selected financial information with respect to Banca Romaneasca as at and for the year ended December 31, 2015, is provided in the table below:

Stopanska Banka is a commercial bank registered in FYROM and headquartered in Skopje that provides a wide range of retail and corporate banking services. The Bank acquired Stopanska Banka in 2000 and as at December 31, 2015, held a 94.64% stake, while the remaining 5.36%, is held by minority shareholders.

Stopanska Banka operates one of the largest branch networks in FYROM, with a dense nationwide network of ATMs and POS terminals. As at December 31, 2015, Stopanska Banka had 64 branches, and continues to strive to maintain its leadership position in e-banking within FYROM,

including by promoting internet and mobile banking and offering its clients electronic payment facilities. Stopanska Banka aims to continue to improve its loan portfolio by targeting high quality customers in the SMEs and large companies segments.

Selected financial information with respect to Stopanska Banka as at and for the year ended December 31, 2015, is provided in the table below:

In December 2006, the Bank acquired a 99.40% stake in Vojvodjanska and in October 2007 it became the sole shareholder. As at December 31, 2015, Vojvodjanska's 105 branches serve over 1.2 million private accounts and around 71 thousand company accounts.

Selected financial information with respect to Vojvodjanska as at December 31, 2015, is provided in the table below:

NBG Cyprus, headquartered in Nicosia, had 13 branches, one satellite branch, three Business Centers and two international business units as at December 31, 2015. Since 2011, NBG Cyprus also operates a representative office in Moscow. The bank provides a wide range of commercial and retail banking services, focusing on corporate lending and international business.

Selected financial information with respect to NBG Cyprus as at and for the year ended December 31, 2015, is provided in the table below:

NBG Albania, headquartered in Tirana, as at December 31, 2015, operates through a network of 27 branches and provides a wide range of commercial and retail banking services. NBG Albania has expanded beyond its original activity of lending primarily to certain of the Bank's established Greek corporate clients operating in Albania and gradually started lending to local corporate clients with significant liquid assets as well as individuals, mainly focusing in the secured product of housing loans.

Selected financial information with respect to NBG Albania as at and for the year ended December 31, 2015, is provided in the table below:

NBG Malta has attracted significant business volumes from Turkish corporates and provides a full range of financial products and services to meet the constantly changing needs of corporate customers and private individuals. In 2013, the Bank acquired a portfolio of loans of Romanian companies and also granted loans to intragroup leasing companies in Romania, Serbia and Bulgaria.

By the end of the first half of 2016, NBG Bank Malta intends to finalize the procedures for establishment of custody operations and will commence offering custodian services.

Selected financial information with respect to NBG Malta as at December 31, 2015 is provided in the table below:

SABA, which the Bank founded in 1947, has seven business suites, primarily in urban centers, across South Africa. It offers traditional commercial and business banking services, as well as non-traditional sponsored or alliance banking services in the South African market. During 2015, SABA proceeded with the issuance of debenture agreements of ZAR 50 million.

Selected financial information with respect to SABA as at and for the year ended December 31, 2015, 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 Ethniki Insurance Group ("EH").

Ethniki Insurance Group offers a full range of products including life, accident and health insurance for individuals and groups, fire, catastrophe, motor, marine hull and cargo insurance, and general third party liability insurance.

EH operates through a network of 13 branches, 150 sales bureaus, 2,180 tied agents and 1,443 independent insurance brokers, in addition to selling bancassurance products through the Bank's network and also by direct selling.

Income from insurance operations decreased to EUR 491 million in 2015, from EUR 521 million in 2014. In particular EH's property and casualty insurance businesses gross written premiums decreased to EUR 221 million for the year ended December 31, 2015, compared to EUR 256 million in 2014 while life insurance gross written premiums increased to EUR 269 million for the year ended December 31, 2015 compared to EUR 264 million in 2014.

Bancassurance premiums for life and property & casualty insurance amounted to EUR 36 million and EUR 43 million, respectively, in 2015 compared to EUR 43 million and EUR 43 million, respectively for 2014. For more information on our bancassurance business, see "—Bancassurance" below.

EH operates two subsidiaries in Cyprus in collaboration with NBG Cyprus which are active in both 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 insurance products through the network of two banks: Piraeus Bank Romania and Banca Romana de Credite si Investitii.

In Bulgaria, EH operates jointly with UBB and METLIFE EU Holding Co Ltd: UBB METLIFE AD (life insurance) and jointly with UBB and AIG Central Europe & CIS Insurance Holding Corporation: UBB AIG Insurance Company A.D. (non-life insurance). These companies promote bancassurance products in the Bulgarian market. Additionally, in partnership with UBB, EH operates UBB Insurance Broker AD, holding 20.00% of the share capital.

According to the EH Board of Directors' resolution on June 13, 2014, EH proceeded, in conjunction with UBB and AIG Central Europe and CIS Insurance Holding Corporation, with the disposal of UBB AIG Insurance Company AD. The disposal completed in January 2016.

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.

We offer the following bancassurance products through our insurance brokerage subsidiary NBG Bancassurance S.A. and the Bank's extensive network in Greece.

We engage in real estate management activities, including warehousing and third-party property management. As at December 31, 2015, the Bank owned 1,735 real estate units, 1,163 of which were buildings and 449 were lands that the Bank acquired through seizure of collateral on loan foreclosures. The remaining 123 units were acquired to host and to support its own business purposes. As at December 31, 2015, the carrying value of the 1,612 units that were acquired through foreclosure was EUR 69 million (2014: EUR 77 million). We report these items in other assets, under the line "Assets acquired through foreclosure proceedings" and is currently explores opportunities for sales of those properties.

We have established guidelines and procedures relating to the disposal of properties, including properties acquired through foreclosure, in order to support 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 REIC, the Group's real estate investment company, owned 316 commercial properties with a net book value of EUR 810 million as at December 31, 2015. The fair value of the properties was EUR 1,473 million at December 31, 2015. The properties have a total leasable area of 880 thousand sq.m. and are mainly located in prime areas throughout Greece. The NBG Pangaea Group also owned as at December 31, 2015 five properties in Italy and two properties in Romania.

In 2015, NBG Pangaea REIC made total investments in real estate of EUR 86 million.

In addition NBG Pangaea REIC in 2015 also signed binding agreements for the acquisition of real estate investments amounting to EUR 84 million.

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.

The Group's discontinued operations include the Finansbank group of companies. On November 3, 2015, the Board of Directors approved the plan to proceed with the disposal of our entire stake in Finansbank A.S. together with our stake in Finans Leasing (which completed in February 1, 2016), thereby disposing of all of our operations in Turkey. This transaction is expected to close within the first half of 2016, subject to customary regulatory and corporate approvals. As a result, our financial and operating data for the twelve months ended December 31, 2015 have been prepared stating separately continuing operations from discontinued operations, the latter relating to Finansbank A.S. in accordance with ASC 205-20 "Discontinued Operations". The historical financial data for the years 2014, 2013, 2012 and 2011 have been restated accordingly. Long lived assets held for sale and the liabilities directly associated with long lived assets comprise Finansbank A.S., the Private Equity Funds and Astir Palace Vouliagmenis S.A and Astir Marina Vouliagmenis S.A.

In 2015, the net interest income before provision for loan losses from discontinued operations was EUR 1,421 million, compared to EUR 1,226 million in 2014. As at December 31, 2015, net loans included in long-lived assets classified as held for sale was EUR 18,481 million while total deposits included in liabilities directly associated with long-lived assets classified as held for sale reached EUR 16,199 million, compared to EUR 18,140 million and EUR 15,406 million, respectively, as at December 31, 2014. Total assets of long-lived assets classified as held for sale as at December 31, 2015 were EUR 24.8 billion, accounting for 24.8% of our total assets compared to EUR 29.3 billion and 27.1% as at December 31, 2014.

Finansbank's group of companies includes Finans Invest, Finans Leasing, Finans Portfolio Management, Finans Investment Trust, Finans Factoring, IBTech, PSA Finansman A.S. and EFinans. Finansbank is the fifth largest private bank in Turkey in terms of total assets, loans and deposits as at December 31, 2015, 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 and portfolio management. As at December 31, 2015, Finansbank operated through a network of 643 branches in 62 commercial centers in Turkey, making it the sixth largest private bank in Turkey by size of branch network according to statistics published by the Banking Regulation and Supervisions Agency of Turkey (the "BRSA"). As at December 31, 2015, Finansbank and its subsidiaries had 14,141 employees. Over

the past two years, Finansbank has continued to increase its focus on SME customers, corporate and commercial loan portfolio, while selectively growing its retail loan portfolio. See also Item 3.D, "Risk Factors—The sale of Finansbank pursuant to the Revised Restructuring Plan will result in the loss of a business which has historically represented a significant portion of our consolidated operations and profit".

The tables below present the Group's exposure at December 31, 2015 to European countries (other than Greece) that were benefiting from the support of the European Union and/or the IMF in the context of an adjustment program, aimed at putting their public finances on good footing and address their structural deficiencies. These are: Albania, Cyprus, Romania and Serbia.

Letters of credit and Letters of guarantee represent unfunded exposure and are summarized in the table below as at December 31, 2015:

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, 2015:

		December 31, 2015

	Name	Country of incorporation	(%) Interest held by Group			Reported book value⁽¹⁾
						(EUR in millions)		(USD in millions)⁽²⁾
1.	Planet S.A.	Greece		36.99	%		2		2
2.	Eviop Tempo S.A.	Greece		21.21	%		3		3
3.	Social Securities Funds Management S.A.	Greece		20.00	%		1		1
4.	Teiresias S.A.	Greece		39.93	%		—		—
5.	Hellenic Spining Mills of Pella S.A.	Greece		20.89	%		—		—
6.	Pyrrichos Real Estate S.A.	Greece		21.83	%		—		—
7.	Larco S.A.	Greece		33.36	%		—		—
8.	SATO S.A.	Greece		23.74	%		—		—
9.	Olganos S.A.	Greece		33.60	%		—		—
10.	UBB Metlife Life Insurance Company AD	Bulgaria		59.97	%		7		8
11.	UBB AIG Insurance Company AD	Bulgaria		59.97	%		2		2
12.	Drujestvo za Kasovi Uslugi A.D.	Bulgaria		19.98	%		1		1
13.	Bantas A.S.⁽³⁾	Turkey		33.27	%		—		—
14.	Cigna Finans Pension⁽³⁾	Turkey		48.91	%		—		—
15.	NBG Funding Ltd.	U.K.		100.00	%		20		23

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 AIG, UBB ALICO Life Insurance Company AD and UBB AIG 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.

On June 13, 2014, the Board of Directors of EH and UBB decided to proceed, jointly with AIG Central Europe & CIS Insurance Holding Corporation, with the disposal of UBB-AIG Insurance Company AD. The disposal completed in January 2016.

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.

As at December 2015, the date of the most recent available information from the Bank of Greece, there were 40 banks in Greece: 9 Greek commercial banks, 10 cooperative banks and 21 foreign banks (including branches of HSBC and RBS), as well as one specialized credit institution (source: Bank of Greece site, Statistics, List of MFIs).

Traditionally, commercial banks have dominated the Greek financial services market. However, specialized banks 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 (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, in contrast to institutions that are unable to draw on such deposit bases.

As at the date hereof, there are five banks in which the Hellenic Republic (also through public funds) and the HFSF participate under the Hellenic Republic Support Plan and the recapitalization framework of the HFSF Law, respectively: Alpha Bank S.A., Attica Bank SA, Eurobank Ergasias S.A., National Bank of Greece S.A. and Piraeus Bank S.A.

Since 2012, the Greek banking sector has undergone significant consolidation. In July 2012, Piraeus Bank absorbed the healthy part of ATE Bank, which was controlled by the Hellenic Republic following its resolution (source: Piraeus Bank press release on July 27, 2012). In 2013, Alpha Bank acquired Emporiki Bank from Crédit Agricole (source: Alpha Bank press release on 17 October 2012), and in December 2012, Piraeus Bank acquired a 99.08% stake in General Bank from Société Générale (source: Piraeus Bank press releases on December 14, 2012 and March 1, 2013). In March 2013, Piraeus Bank also acquired all of the Greek deposits, loans and branches of Bank of Cyprus, Cyprus Popular Bank and Hellenic Bank, including loans and deposits of their Greek subsidiaries (leasing, factoring and the Investment Bank of Greece) (source: Piraeus Bank press release on March 26, 2013). In April 2013, Piraeus Bank fully acquired Millennium Bank (Source: Piraeus Bank press release on April 22, 2013) and Banco Comercial Português participated in the share capital increase of Piraeus Bank. In July 2013, NBG acquired the healthy parts of First Business Bank and Probank, whilst Eurobank acquired the 100% of new Hellenic Postbank and the 100% of New Proton Bank (Source: Eurobank press release dated July 15, 2013). In December 2013, Alpha Bank undertook the deposits of three cooperative banks: Western Macedonia, Dodecanese and Evia (Source: Alpha press release dated December 8, 2013). In May 2014, Piraeus Bank absorbed its subsidiary Geniki Bank SA (Source: Piraeus Bank press release on May 30, 2014).In April 2015, Piraeus Bank absorbed the healthy assets of Panellinia Bank (source: Piraeus Bank press release dated April 17, 2015). Lastly, in December 2015,

the deposits of Cooperative Bank of Peloponnese were transferred to NBG, after a relevant decision by the Bank of Greece (source: Bank of Greece press release dated December 18, 2015).

In December 2015, according to data published by the Bank of Greece, there were 21 foreign banks that were established in the Greek banking market. 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 bank 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.

Since 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 Group is subject to financial services laws, regulations, administrative acts and codes applying in each jurisdiction in which it operates.

Further to this, the Group is subject to the regulatory framework of the SSM as well as various EU and Greek laws and regulations and to supervision by the ECB (which also administers the monetary policy of the Eurozone) and the Bank of Greece.

Regulation 1024/2013 established the SSM for Eurozone banks and other credit institutions. The SSM maintains an important distinction between significant and non-significant entities, which will be subject to differing supervisory regimes. National Bank of Greece is included in the list of significant supervised entities published by the ECB. As a result, the ECB has been granted certain supervisory powers as from November 4, 2014, which include:

The SSM framework Regulation 468/2014 (ECB/2014/17) sets out the practical arrangements for the SSM, while Regulation 1163/2014 lays down the methodology and procedure regarding the annual supervisory fees which are born by the supervised credit institutions.

The ECB exercises its supervisory responsibilities in cooperation with the national central banks in the various Member States whose currency is the euro (such as for Greece) or a Member State whose currency is not the euro which has established a close cooperation agreement with the ECB in line with the provisions of Decision ECB/2014/510. The ECB is responsible for the effective and consistent functioning of the SSM and exercises oversight over the functioning of the system, based on the distribution of responsibilities between the ECB and National Competent Authorities ("NCAs"). To ensure efficient supervision, credit institutions are categorized as "significant" or "less significant": the ECB directly supervises significant banks, whereas the NCAs are in charge of supervising less significant banks, with the ECB exercising indirect supervision. The day-to-day supervision is conducted by Joint Supervisory Teams, which comprise staff from both NCAs and the ECB.

Notably, the entity is subject to continuous evaluation of its capital adequacy in the context of the SSM and could be requested to operate with higher than minimum regulatory capital and/or liquidity ratios.

As regards the monitoring of financial institutions, the NCA, in addition to supporting the ECB in day-to-day supervision, will continue to be responsible for supervisory matters not conferred on the ECB, such as consumer protection, money laundering, payment services, and branches of third country banks. The ECB, on the other hand, will be exclusively responsible for prudential supervision of credit institutions with the abovementioned supervisory powers.

The CRD IV contains specific mandates for the EBA to develop draft regulatory or implementing technical standards as well as guidelines and reports, in order to enhance regulatory harmonization in Europe through the Single RuleBook. A series of Regulations concerning regulatory or implementing technical standards have already been published.

ECB Banking Supervision conducted a comprehensive assessment of the four significant Greek banks (Alpha Bank, Eurobank, National Bank of Greece and Piraeus Bank) in line with the decision by the Euro Summit on July 12, 2015 and the Memorandum of Understanding between the European Commission, acting on behalf of the European Stability Mechanism, the Hellenic Republic and the Bank of Greece, signed on August 19, 2015.

This assessment comprised an asset quality review (AQR) and a forward-looking stress test, including a baseline and an adverse scenario, in order to assess the specific recapitalization needs of

the individual banks under the third economic adjustment program for Greece. (see Item 4.A, "History and Development of the Company—2015 Comprehensive Assessment")

The AQR resulted in aggregate adjustments of EUR 9.2 billion to participating banks' asset carrying values as at June 30, 2015. Also, non-performing exposure (NPE) stocks were increased by approximately EUR 7 billion across the four banks, with the corresponding provisions already considered in the aforementioned AQR adjustments. In addition to adjustments made directly to current carrying values, the AQR result was also reflected in the projection of banks' capital adequacy under hypothetical scenarios performed in the stress test. Overall, the stress test identified a capital shortfall across the four participating banks of EUR 4.4 billion under the baseline scenario and EUR 14.4 billion under the adverse scenario, including AQR adjustments, after comparing the projected solvency ratios against the thresholds defined for the exercise.

The four banks had submitted capital plans to ECB Banking Supervision explaining how they intend to cover their shortfalls. This started a recapitalization process under the economic adjustment program that concluded before the end of 2015.

The EBA released on February 2016 the methodology and macroeconomic scenarios for the 2016 EU-wide stress test. The stress test is designed to provide supervisors, banks and other market participants with a common analytical framework to consistently compare and assess the resilience of EU banks to economic shocks. According to the relevant methodological note, National Bank of Greece S.A. was considered to be covered by the ECB's Comprehensive Assessment of 2015 and therefore not to be assessed in the 2016 EU-wide stress test.

The SRM Regulation establishes uniform rules and a uniform procedure for the resolution of credit institutions and certain investment firms in the framework of a Single Resolution Mechanism and a Single Resolution Fund.

The SRM Regulation, which complements the SSM (as discussed under "—Single Supervisory Mechanism" above) and applies to all banks supervised by the SSM, including the Bank.

The Single Resolution Mechanism was proposed by the European Commission on July 10, 2013. Regulation (EU) No 806/2014 establishing a SRM for the Banking Union entered into force on August 19, 2014.

In December 2010, the Basel Committee issued two prudential framework documents ("Basel III: A global regulatory framework for more resilient credit institutions and banking systems", and "Basel III: International framework for liquidity risk measurement, standards and monitoring",) which contain the Basel III capital and liquidity reform package ("Basel III").

The Basel III framework has been implemented in the EU through new banking regulations adopted on June 26, 2013: a) Directive 2013/36/EU of the European Parliament and of the Council on access to the activity of credit institutions and the prudential supervision of credit institutions and investment firms (the "CRD IV Directive"), which has been transposed into Greek law by Greek Law 4261/2014, and b) Regulation (EU) No 575/2013 of the European Parliament and of the Council on prudential requirements for credit institutions and investment firms (the "CRR" and together with the CRD IV Directive, "CRD IV") which is legally binding and directly applicable in all EU Member States. Implementation began on January 1, 2014, with particular elements being phased in over a period of time. The requirements are intended to be effective by 2019 and some minor transitional provisions provide for the phase-in until 2024.

In addition to CRD IV, the EBA produces a number of binding technical standards, guidelines and recommendations for its implementation. The full implementation of CRD IV will lead to an increase in our capital requirements and capital costs.

Together with Directive 2014/59/EU of the European Parliament and of the Council of May 15, 2014 (see below "—Bank Recovery and Resolution Directive") CRD IV forms the common financial regulatory framework in the EU, also known as 'the Single Rulebook'.

In addition to the substantial changes in capital and liquidity requirements introduced by Basel III and CRD IV, there are several new global initiatives, in various stages of finalization, which represent additional regulatory pressure over the medium term and will impact the EU's future regulatory direction. These initiatives include, among others, a revised Markets in Financial Instruments Directive (Directive 2014/65/EU) and Markets in Financial Instruments Regulation (Regulation (EU) No 600/2014), with a new deadline for transposition into national law of January 3, 2018.

As at January 1, 2016 Greek Law 4364/2016, which was issued in February 2016, came into force retrospectively, replacing the previously existing Greek Law 400/70 and established in Greece the new Solvency II framework as detailed in Directive 2009/038/EC.

The new Solvency II framework is a fundamental revision of the capital adequacy regime for the European insurance sector business. Ethniki Insurance and its insurance company subsidiaries have submitted all the preparatory phase qualitative and quantitative information required by the European Insurance and Occupational Pensions Authority to the local regulators. Ethniki Insurance and its insurance company subsidiaries have taken actions to address the impact of Solvency II and do not expect to face any issues in their Solvency II Day 1 reporting as at January 1, 2016.

On May 15, 2014, the European Parliament and the Council of the European Union adopted Directive 2014/59/EU establishing a framework for the recovery and resolution of credit institutions and investment firms (the "BRRD"). The BRRD entered into force on July 2, 2014. It establishes a harmonized framework for the recovery and resolution of credit institutions and investments firms incorporated under the laws and licensed by the competent authorities of any of the Member States of the European Union, relying on a network of national authorities and resolution funds to resolve banks.

By virtue of Greek Law 4335/2015 (the "BRR Law"), and in particular Article 2 "Recovery and resolution of credit institutions and investment firms and other provisions", the BRRD was transposed into Greek Law and the Bank of Greece has been designated as the national resolution authority (the "National Resolution Authority"). Greek Law 4335/2015 provides among others for the following:

Before proceeding to resolution measures, the National Resolution Authority shall ensure that a fair, prudent and realistic valuation of the assets and liabilities of the institution is carried out.

The resolution measures that may be implemented by the National Resolution Authority, either individually or in conjunction (save for the asset separation tool, which may only be applied in conjunction with another resolution tool), are the following:

Further to the above resolution tools, the National Resolution Authority is entitled to exercise the write-down or conversion powers in respect of Additional Tier 1 and Tier 2 capital instruments of the institution, either independently from the resolution tools implemented by the National Resolution Authority or in combination with the resolution tools implemented by the National Resolution Authority or in combination at the point of non-viability with the public financial stabilization tools described hereunder, under the circumstances provided by the law, for example when it is established that the conditions for resolution are met or when the competent authority establishes that if the said power is not exercised, the institution will cease to be viable. If an institution meets the requirements for resolution and the National Resolution Authority decides to implement a resolution tool, then the exercise of the above power is required.

In cases of an exceptional systemic crisis, extraordinary public financial support may be provided, as long as certain conditions are met. Extraordinary public financial support is provided by virtue of a decision of the Minister of Finance, following a recommendation of the Systemic Stability Board and a consultation with the resolution authority, through public financial stabilization tools as a last resort and only after having assessed and utilized, to the maximum extent, the other resolution tools, in order to avoid, through the direct intervention, the winding-up of the said institutions and in order for the resolution purposes to be accomplished. The public financial stabilization tools are:

The following conditions must be cumulatively met in order for the public financial stabilization tools to be implemented:

In addition to the above, for the provision of public financial support, one of the following conditions must be met:

By way of exception, extraordinary public financial support may be granted to a credit institution in the form of an injection of own funds or purchase of capital instruments without the involvement of resolution measures, under the following cumulative conditions:

The CRD IV framework, comprising CRD IV Directive (as transposed into Greek law by way of Greek Law 4261/2014, the "CRD Law") on access to the activity of credit institutions and the Capital Requirements Regulation known as "CRR" on the prudential supervision of credit institutions and investment firms establishes the regulatory framework which governs the operation and supervision of credit institutions in the European Union.

The CRD Law replaced Greek Law 3601/2007. According to Article 166 of Greek Law 4261/2014, regulatory decisions issued by ministers or competent authorities by virtue of Greek Law 3601/2007 remain in force as long as they are not contrary to the provisions of the CRD Law or Regulation No. 575/2013/EC and until replaced by new regulatory acts under Greek Law 4261/2014.

Under the current regulatory framework, credit institutions operating in Greece are, among others, required to:

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, among others, to:

In the context of the Single Supervisory Mechanism (SSM) of the European Central Bank and the National Competent Authorities (Bank of Greece), Regulation 1024/13 stipulates the supervisory tasks conferred upon the SSM and Regulation 468/14 determines the framework of cooperation within the SSM.

The regulatory framework applicable to the Bank has been also affected by the establishment of the HFSF and the recapitalization framework (see Item 5. D., "Trend information—The Macroeconomic Environment in the Group's Markets—The Hellenic Republic's Economic Crisis").

The Hellenic Republic Bank Support Plan consisted of the following three pillars:

For more information concerning the Bank's participation in the Hellenic Republic Bank Support Plan under Pillars II and III, see Item 5.B," Liquidity and Capital Resources—Sources of Capital and Liquidity—Financings under the Hellenic Republic Bank Support Plan".

The Hellenic Financial Stability Fund—The Greek Recapitalization Framework

The HFSF was established by Greek Law 3864/2010, as a private law entity with capital funded by the Greek government out of the resources made available by the EU and the IMF to ensure adequate capitalization of the Greek banking system.

The purpose of the HFSF, according to the HFSF Law, is to maintain the stability of the Greek banking system for protection of the public interest. The duration of the HFSF has been set until and including June 30, 2020 and it may be extended upon decision of the Minister of Finance, provided that such extension is necessary for the fulfillment of its purposes.

Organizational issues: The administrative structure of the HFSF is comprised of two administrative bodies with decision making powers: (i) the nine-member General Council (of which one member is appointed by the Bank of Greece and one is appointed by the Ministry of Finance); and (ii) the three-member Executive Committee (of which one member is appointed by the Bank of Greece). One member of the Executive Committee shall be responsible for the reinforcement of the HFSF's role in facilitating the management of non-performing loans of the credit institutions in which the HFSF holds participation. Each of ECB, the EC and the ESM may appoint a non-voting observer to participate in the meetings of the General Council and the Executive Committee. Except for the Ministry of Finance and the Bank of Greece appointees, the appointment, renewal and salary of the other members sitting on the General Council and the Executive Committee requires the consent of the Eurogroup.

Selection Panel: The members of the General Council and the Executive Committee shall be selected by the selection panel which has already been formed by virtue of article 4A of the HFSF Law. The Governor, the Deputy Governors, the members of the collective bodies, the advisors, as well as any other Bank of Greece staff, may not become members of the Executive Committee. Par. 7 of Article 4 of the HFSF Law, stipulates all the positions for which there is incompatibility with being a member of the General Council and also of the Executive Committee.

The members of the General Council and the Executive Committee, except for the representative of the Ministry of Finance, shall, in the performance of their duties, enjoy full autonomy and shall not seek or receive instructions from the Hellenic Republic or any other state body or institution, or financial institution supervised by the Bank of Greece, and shall not be subject to influence of any nature. At least, every two months, the General Council shall submit activities reports to the Minister of Finance.

Pursuant to the provisions of article 6 of the HFSF Law, in the event that a credit institution is faced with a capital shortfall that has been identified as such by the competent authority, the credit institution may request capital support from the HFSF up to the amount of the capital shortfall. Such request to the HFSF shall be accompanied by:

The draft restructuring plan, or the draft revised restructuring plan, as the case may be, must also describe, in light of conservative estimates, by what means the credit institution shall return to sufficient profitability over the next three to five years. Following any amendments to the draft restructuring plan, or the draft revised restructuring plan, suggested by the HFSF, the latter approves the draft restructuring plan or the draft revised restructuring plan, it forwards the same to the Ministry of Finance and the Ministry of Finance submits it to the European Commission for approval.

For the realization of the objectives and the exercise of the rights of the HFSF, the HFSF determines the framework of the relationship framework agreement or of the amended relationship framework agreement, as the case may be, with all credit institutions that are or have been beneficiaries of financial assistance provided by the EFSF and the ESM. The credit institutions shall sign the above mentioned relationship framework agreement.

HFSF may provide the credit institution with a letter by which it commits to participate in the share capital increase of such credit institution up to the amount of the capital shortfall, provided that the credit institution falls under the exemption of article 32, par. 3 (d) (cc) of internal article 2 of the BRR Law (Greek Law 4335/2016) (the "Precautionary Recapitalization").

In accordance with article 6A of the HFSF Law, should the voluntary measures provided for in a credit institution's restructuring plan or revised restructuring plan fail to address the total capital shortfall of the credit institution as identified by the competent authority and in order to avoid serious disturbances in the economy with adverse effects upon the public and in order to ensure that the use of public funds is minimal, the Cabinet, following a recommendation by the Bank of Greece, shall issue an act (the "Cabinet Act") for the application of mandatory measures (the "Mandatory Measures") aimed at allocating the residual amount of the capital shortfall of the credit institution to the holders of its capital instruments and other liabilities, as may be necessary.

In case of conversion of preference shares issued in accordance with Greek Law 3723/2008 into ordinary shares of the credit institution, the HFSF shall become the owner of such ordinary shares. Claims of the same ranking will be treated pari passu. Differentiations in the ranking order, in accordance with the mandatory provisions of Greek Banking Law regarding hierarchy of claims in case of special liquidation of credit institutions (i.e. article 145A of Greek Law 4261/2014, as in force) and the relevant agreements, between claims that fall within the same class of the ranking order are taken into account during the above allocation. Deviations from both the above hierarchy of claims and the pari passu principle can be justified, however, when there are objective reasons to do so.

The Cabinet Act, following recommendation by the Bank of Greece, determines by class, type, rate and amount of participation, the instruments or the liabilities that are subject to the mandatory measures, on the basis, if needed, of a valuation of an independent auditor, appointed by the Bank of Greece. The conduct of such valuation is considered to exhaust any obligation to obtain an independent valuation provided for in any other applicable law. A valuation that meets the requirements of article 36 of BRR Law may act as a valuation for purposes of such requirements.

The instruments or liabilities referenced in the Cabinet Act as described immediately above are mandatorily converted into capital instruments within the context of a share capital increase decided by the credit institution in accordance with article 7 of the HFSF Law.

By way of derogation and subject to a positive decision of the European Commission in accordance with articles 107 to 109 of the Treaty on the Functioning of the European Union, the above measures may not apply, either fully or to individual instruments, in the event that the Cabinet concludes, upon recommendation by the Bank of Greece, that such measures would endanger financial stability or lead to disproportionate results, such as when the amount of capital support to be provided by the HFSF is small in comparison to that of the credit institution's risk weighted assets, and/or a significant portion of the capital shortfall has been covered by the private sector.

The final assessment of the derogation rests with the European Commission on an ad hoc basis.

The holders of any capital instruments, or other liabilities, including unsecured senior liabilities not preferred by mandatory provisions of law of the credit institution that is subject to recapitalization measures, shall not, following the implementation of the measures described above, be in a worse financial position than if the credit institution had been placed under liquidation (no creditor worse-off principle).

In the event that the no creditor worse-off principle is not observed, holders of any capital instrument, or other liabilities, including unsecured senior liabilities not preferred by mandatory provisions of law, are entitled to compensation by the Hellenic Republic, provided that they prove that their damages directly arising from the implementation of the mandatory measures are greater than if the credit institution had been put under special liquidation.

A valuation is conducted in order to determine the losses that the holders of any capital instrument, or other liabilities, including unsecured senior liabilities non-preferred by mandatory provisions of law, if instead of applying the mandatory measures, the credit institution had been liquidated. Any form of public financial support to the credit institution is disregarded for the purposes of such valuation. The valuation will be conducted after implementation of the mandatory measures by an independent valuator to be appointed by the Bank of Greece with a view to assessing whether shareholders and subordinated creditors falling under the aforementioned measures would have been in a more favorable financial position if the credit institution had entered into special liquidation immediately prior to the implementation of the mandatory measures.

The 2015 Recapitalization was a precautionary recapitalization pursuant to Article 32, paragraph 3(d) of the BRR Law.

Application of the public financial stabilization measures of article 57 of the BRR Law

If the Minister of Finance decides, in accordance with paragraph 4 of article 56 of the BRR Law, the application of the public financial stabilization measures (the "Public Financial Stabilization Measures"), the HFSF is appointed as the implementing body of article 57 of the BRR Law, following a decision by the Minister of Finance. In such case, the HFSF participates in the recapitalization of the credit institution and receives in exchange ordinary shares (CET1 instruments) or instruments as prescribed by Article 57, par. 1 of the BRR Law.

The HFSF participates in the share capital increase and receives in exchange the above capital instruments after the application of whichever measures are decided in accordance with the BRR Law.

The HFSF provides capital support exclusively for the purpose of covering the credit institution's capital shortfall, as it has been determined by the competent authority and up to the residual amount, subject to the prior implementation of the measures of the capital raising plan of the credit institution, any participation of investors of private sector and the approval of the restructuring plan by the European Commission and:

the relationship framework agreement between the HFSF and the relevant credit institution must have been duly executed before the provision of the capital support.

Without prejudice to the aforementioned conditions and procedures, capital support is provided through the HFSF's participation in a share capital increase of the credit institution by issuance of ordinary shares with voting rights or CoCos or other convertible financial instruments that shall be subscribed for by the HFSF.

The HFSF may exercise, dispose of or waive its pre-emptive rights in cases of share capital increase or of issuance of contingent convertible securities or other convertible financial instruments of the credit institutions that request the provision of capital support. The share capital increases are settled by the HFSF in cash or in EFSF or ESM securities. Capital support is provided in compliance with state-aid rules.

Any decision of the credit institution concerning a share capital increase in accordance with the foregoing rules, including decisions concerning CoCos or other convertible financial instruments must be taken following a resolution of the General meeting of the shareholders according to article 7 of the HFSF Law, as in force.

The decision of the general meeting of the shareholders may, instead of the maximum number of shares, provide for the maximum amount of capital which shall be covered and provide the Board of Directors of the credit institution the power to decide, inter alia, the remaining amount following the implementation of the measures set out in article 6a of the HFSF Law, the exact number of shares and the allocation of shares. The time period for the convocation of the general meeting which will decide the share capital increase for the issuance of the ordinary shares, convertible securities or the other financial instruments is ten (10) calendar days, as provided under paragraph 2 of internal article 115 of article 2 of the BRR Law. The time period for the convocation of any repeat or upon postponement meeting and for the submission of documentation before the supervisory authorities is shortened to one third (1/3) of the time periods set out in the Corporate Law 2190/1920, as in force. The previous passage applies in every general meeting convened within the context of the HFSF Law. Subject to the restriction set out in the Corporate Law 2190/1920 not to issue shares below par, the subscription price is determined as the market price resulting by the book building procedure followed by the credit institution. By means of a decision of its General Council, the HFSF accepts this price provided that it has commissioned and received an opinion from an independent financial advisor who opines that the book building procedure complies with the international best practice in the particular circumstances.

The offering price of the new shares to the private sector shall not be lower than the subscription price of those shares subscribed of by the HFSF in the context of the same issuance. The offer price may be lower than the price of the shares already subscribed by the HFSF or than the current stock market price.

The processes described under the two previous paragraphs do not apply in case that the HFSF is required to subscribe for the residual amount that has not been subscribed for through private placement in share capital increases of credit institutions which do not have a restructuring plan already approved by the European Commission at the time of submission of request for capital support or by applying article 6B (Application of the public financial stabilization tools) of the HFSF Law.

The Greek cabinet act 36/02.11.2015 (the "Allocation Cabinet Act") sets out, inter alia, the terms under which the CoCos may be issued by the credit institutions and subscribed for by the HFSF, as well as the terms of conversion thereof into ordinary shares of the relevant credit institution. The CoCos shall qualify as equity capital of the credit institution and their regulatory treatment shall be governed by the applicable legal framework. The terms and conditions of the CoCos are described in the Allocation Cabinet Act and shall be included in a detailed program for their issuance. The CoCos shall have a nominal value of EUR 100,000 each, shall be issued at par and shall be perpetual without a fixed repayment date. The CoCos shall constitute direct, unsecured and subordinated investments in the credit institution ranking at all times pari passu without any preference among themselves.

In the event the CET1 Ratio of the credit institution, calculated on a consolidated basis or a solo basis, falls below 7%, the credit institution shall convert the CoCos by issuing to each holder of CoCos conversion shares determined by dividing 116% of the nominal value of the then outstanding CoCos by the subscription price of the ordinary shares of the credit institution, as determined in the share capital increase of the credit institution of article 7 of the HFSF Law, divided by the relevant holder's participation in the aggregate amount of CoCos.

The CoCos will bear interest at (i) a rate of 8 per cent per annum (the "Initial Interest Rate") from and including the date of issuance of the CoCos to the 7^th annual anniversary after their issue date (the "7^th Anniversary") and (ii) thereafter, if not repaid, at the applicable readjustment interest rate, namely the sum of (a) the 7-year Mid-Swap Rate for such readjustment period plus (b) a margin

equal to the difference between the Initial Interest Rate and the 7-year Mid-Swap Rate at their issue date. Interest will be payable on an annual basis accrued, each on interest payment date. The CoCos shall automatically convert into ordinary shares of the credit institution if, for any reason whatsoever, the credit institution does not pay all or any part of any scheduled interest payments on two interest payment dates, which for the avoidance of doubt, do not need to be consecutive.

Payment of Interest (whether in whole or in part) is entirely at the discretion of the Board of Directors of the credit institution, but if paid, interest will be paid in cash. Any such interest elected not to be paid shall be cancelled and shall not accumulate. The Board of Directors of the credit institution shall have the option, at its full discretion, to pay the interest in the form of ordinary shares of the credit institution, to be newly issued for such purpose. If the Board of Directors of the credit institution so decides, the share capital increase shall take place automatically and without any further procedural requirements or corporate decisions (including without any need for consent of the shareholders) and the corresponding ordinary shares shall be automatically issued.

For the avoidance of doubt, any interest payment shall be subject to any applicable Maximum Distributable Amount as stands in accordance with article 131 of the CRD Law (Greek Law 4261/2014). No dividend shall be paid on the credit institution's ordinary shares if the credit institution has decided not to pay interest on the previous interest payment date.

The credit institution may, in its sole discretion, elect to repay all or some of the CoCos at any time at their initial nominal value plus any accrued and unpaid interest (excluding any interest which has been cancelled), subject to the following conditions:

In addition, holders of CoCos shall have the right on the 7^th Anniversary to convert their CoCos into ordinary shares.

The CoCos shall only be transferable with the consent of the credit institution (which is not to be unreasonably withheld) and the consent of the competent regulatory authority.

When the HFSF provides the Precautionary Recapitalization, the capital support shall be provided as follows:

When the HFSF provides the capital support through the Public Financial Stabilization Measures, the capital support shall be be provided as follows:

The CoCos issued by the Bank as part of its 2015 Recapitalization have the terms and conditions as prescribed in Cabinet Act no 36/2.12.2015 and summarized above.

The HFSF will acquire ordinary shares with full voting rights in the share capital increases in which it will participate.

For shares acquired by the HFSF under the previous recapitalization framework, where the minimum private sector participation condition had been met, the HFSF shall continue to exercise its voting rights with restrictions (i.e., the HFSF may exercise its voting rights only on matters relating to resolutions amending the bank's articles of association, including share capital increases or decreases or granting a relevant authorization to the Board of Directors, mergers, divisions, conversions, revivals, extensions of the term or dissolution of the company and transfers of assets, including sales of subsidiaries or any other matter requiring an increased majority, in accordance with Greek Company Law 2190/1920), unless it is concluded, following a decision of the members of the General Council of the HFSF, that the bank is in breach of material obligations which are included in or promote the implementation of the restructuring plan or which are described in the agreement entered into between the HFSF and the bank. The HFSF is represented by one director to the board of directors of a bank having received capital from the HFSF according to the HFSF Law, as its representative. The HFSF has currently appointed one representative in the Bank's Board of Directors. Additionally, the HFSF appoints one observer to the Board (without voting rights), and both the representative and the observer participate in Board Committees (see below—Relationship Framework Agreement).

In exercising his rights, the HFSF's representatives in the Board of Directors shall respect the credit institution's business autonomy.

HFSF shall have free access to the credit institution's books and records using employees or consultants of its choice.

The remuneration of the Chairman, the Managing Director and the other members of the Board of Directors, as well as those who have the position or perform general manager's tasks and their deputies may not exceed the total remuneration of the Governor of the Bank of Greece. For the period during which the credit institution participates in the capital support program under the HFSF Law, no bonuses shall be granted to the aforementioned persons and dividend payouts must be limited to up to 35% of distributable profits.

The HFSF, with the assistance of an independent advisor of international reputation and established experience and expertise, will assess the corporate governance framework of the credit institutions with which the HFSF has executed a Relationship Framework Agreement and establish criteria for such assessment in line with the international best practices, in addition to the criteria set out in the HFSF Law. The assessment shall include the size, organization, structure and the allocation of tasks and responsibilities within the board of directors and its committees according to the business needs of the credit institutions, as well as the members of the board of directors and its committees.

The above evaluation will involve all committees of the board of directors as well as any other committee of these credit institutions which the HFSF deems necessary to evaluate for the fulfillment of its objectives. The HFSF with the assistance of an independent consultant will develop criteria for the evaluation of the above elements and the members of the boards and committees of these credit institutions along best international practices. Based on this evaluation the HFSF will develop specific recommendations for improvements and changes, if needed, in the corporate governance of each credit institution. The members of the boards and committees shall cooperate with the HFSF and its consultants in conducting the review and provide necessary information for the purposes of the review.

Beyond the criteria established by the HFSF with the assistance of the independent consultant, the evaluation shall include certain minimum criteria as set out below:

Additional criteria defining specific skills needed for specific tasks within the board will be determined by the HFSF in cooperation with the independent consultant under the corporate governance review. The criteria will be updated at least once every two years and more often if there is material change in the financial position of the credit institution.

The size and collective knowledge of the boards and committees shall reflect the business model and the financial condition of the credit institution and the review of the members should ensure the right size and composition.

The evaluation of the structure and composition of the Boards and Committees shall have the following minimum criteria:

In the case that a review or evaluation determines that the subject of the review does not meet the relevant criteria, the HFSF will inform the board of directors and, if the board of directors does not take action to implements the recommendations, will call a General Assembly of shareholders to inform them and recommend the necessary changes. The HFSF will send the findings of the review to the competent authorities. In the case of a board or committee member does not meet the relevant criteria, or if the board collectively does not satisfy the recommended structure with respect to the size, allocation of tasks and expertise within the board and the necessary changes cannot be achieved otherwise, these recommendations shall include that certain board or committee members need to be replaced.

In the event that the General Assembly of shareholders does not agree within three months to replace board members who fail to meet these criteria, the HFSF shall publish a report on its website within four weeks naming the credit institution, the recommendations and the number of board members that do not meet the relevant criteria and specify the criteria the board and its individual members do not meet.

Each of the Bank of Greece and European Central Bank, in their capacity as the competent authority for the supervision of credit institutions, and the HFSF will be authorized to exchange confidential information with one another to the fullest extent permitted by law. (see Item 3.D, "Risk Factors—Risks Relating to Our Recapitalization and Receipt of State Aid—The HFSF, as shareholder, has certain rights in relation to the operation of the Bank" and Item 4.B, "Business Overview—Relationship with the Hellenic Republic—Hellenic Republic as Shareholder" for further detail).

In the event that the Bank is placed under liquidation, the HFSF as shareholder is satisfied in priority before all other shareholders.

Following the participation of the HFSF in the Bank's share capital in 2013, the Bank and the HFSF entered the Relationship Framework Agreement. In connection with its receipt of State Aid as part of its recapitalization in December 2015, the Bank entered into an Amended Relationship Framework Agreement ("Amended Relationship Framework Agreement") with the HFSF on December 3, 2015. This Amended Relationship Framework Agreement replaced the earlier Relationship Framework Agreement entered into by the Bank in 2013.

According to the Amended Relationship Framework Agreement, the HFSF should, among others (i) monitor and assess how the Bank complies with the applicable restructuring plan of the Bank, (ii) exercise its shareholding rights in compliance with the rules of prudent management of its assets and in compliance with State Aid and competition rules of the European Union, (iii) ensure that the Bank operates on market terms, and (iv) that in due time the Bank returns to private ownership in an open and transparent manner. The Amended Relationship Framework Agreement determines the relationship between the Bank and HFSF certain matters relating to, amongst others: (a) the corporate governance of the Bank, (b) the Restructuring Plan and its monitoring, (c) the monitoring of the implementation of the Bank's NPL management framework and of the Bank's performance on NPL resolution. In addition, the Amended Relationship Framework Agreement deals with (d) the obligations that are defined as material for the purposes of the Relationship Framework Agreement, including for the switch to full voting rights, (e) the monitoring of Bank's actual risk profile against the approved risk and capital strategy (f) the HFSF's consent for matters that are defined as material for

the purposes of the Amended Relationship Framework Agreement and, in particular, for the HFSF's consent request, (g) litigation and other proceedings that are defined as material for the purposes of the Amended Relationship Framework Agreement and concern the Group, and (h) the duties, rights and obligations of HFSF's representative on the Board. Moreover, the Amended Relationship Framework Agreement states that, subject to its provisions, the applicable law, and the charter documents, the Bank's decision making bodies will continue to determine independently, amongst others, the Bank's commercial strategy and policy in compliance with the currently applicable restructuring plan and the decisions on the day-to-day operation of the Bank will continue to rest with the Bank's competent bodies and officers, as the case may be, in accordance with their statutory, legal and fiduciary responsibilities.

The Amended Relationship Framework Agreement prescribes the appointment of the HFSF Representative to the Board of Directors and the appointment of an Observer (without voting rights) also participating at the Board of Directors. Additionally, as prescribed by the Relationship Framework Agreement, both the representative and the observer participate in the Board Committees.

According to the provisions of the applicable framework as outlined previously, the HFSF Representative's rights as prescribed within the Amended Relationship Framework Agreement include the following:

Additionally, as per the Relationship Framework Agreement, the HFSF Representative has the following rights in Board Committees:

Further, the Amended Relationship Framework Agreement prescribes in detail requirements for the Bank to inform the HFSF Representative and the HFSF observer, including on the activities and decisions of Board committees in which they participate.

Under the Relationship Framework Agreement, the Bank has the obligation to obtain the prior written consent of the HFSF for all material matters set forth within the agreement, including, among others, the Restructuring Plan, including any amendment, extension or revision of the Plan, the Bank Group policy governing relations with connected borrowers and any amendment, extension, revision or deviation thereof, the Bank Group Risk and Capital strategy document(s) especially the risk appetite statements and risk governance and any amendment, extension, revision or deviation thereof, the Bank Group Investment/Divestment Policy regarding participations, real estate and loan portfolios and any amendment, extension, revision or deviation thereof, and other matters particularly prescribed within the Amended Relationship Framework Agreement as material materials requiring prior-written consent and according to the exceptions the Amended Relationship Framework Agreement prescribes.

If the Bank breaches or defaults in performing or complying with or fails to perform or comply with any of its material obligations, the HFSF shall give to the Bank a default notice specifying such breach, default or failure and, in the case of a breach, default or failure capable of remedy, stipulating a period during which such breach, default or failure shall be remedied. Provided that such period is accepted by the HFSF, and if such event is still outstanding after a remedy period has been provided by the HFSF, whenever such period is applicable, and without prejudice to any other rights of the HFSF under the Law and the Relationship Framework Agreement, restrictions of the HFSF's voting rights concerning the portion of shares to which these apply, shall be lifted and the HFSF shall have full voting rights with respect to the particular shares now subject to restrictions in accordance with Article 7A of Law 3864/2010, upon notification to the Bank of the respective decision of the General Council of the HFSF.

The Amended Relationship Framework Agreement shall remain in force for as long the HFSF holds shares or contingent convertible bonds issued by the Bank, irrespective of its participation percentage. However, if its participation percentage falls below 15% of the Bank's share capital (for this calculation any CoCos held by the HFSF are assumed to be fully converted), only certain clauses of the Amended Relationship Framework Agreement shall remain in force, as particularly prescribed within the Relationship Framework Agreement.

The Amended Relationship Agreement is available at HFSF's website www.hfsf.gr/en/agreements_2015.htm (section: agreements). The information on this website is not incorporated by reference in this Annual Report.

The HFSF will decide on the way and procedure for disposing its shares at a time it deems appropriate, whether in a single transaction or a series of transactions, and in any case within five years from entry into force of Greek Law 4340/2015 and in compliance with the EU state aid rules. The disposal of shares within the time limits stipulated above may not be made to any entity belonging directly or indirectly to the Hellenic Republic, in accordance with Greek law. The Minister of Finance, following a proposal by the HFSF, can extend the above mentioned periods.

In order to reach such decision, the General Council of the HFSF will take into account a report prepared by an internationally accredited independent financial expert of recognized experience in such

issues. This report should be accompanied by a comprehensive time schedule for the disposal of shares. The prerequisites and the method of disposal of the shares as well as the acts necessary for the completion of the process and compliance with the time schedule must be sufficiently explained in the report.

Subject to the provisions of Greek Law 3401/2005, the shares may be disposed either by the sale of the relevant shares to the public or to specific investor(s) or group of investors through: (a) open tender procedures or calls for expressions of interest to eligible investors; (b) market orders; (c) public offers of the shares for cash or in exchange of other securities; and (d) book building exercises.

The HFSF may decrease its participation in credit institutions through a share capital increase of the credit institution by waiving or disposing of its pre-emptive rights.

The price at which the shares will be disposed by the HFSF and the minimum price at which the shares shall be subscribed are described in Article 8 par. 4 of HFSF Law.

In the event that shares of the credit institution held by the HFSF are disposed to a specific investor or group of investors, or in the event that the participation of the HFSF is decreased pursuant to paragraph 3, of Article 8 of HFSF Law, in favor of a specific investor or group of investors:

This also applies in the case of share capital increases by credit institutions under Greek Law 2190/1920.

According to article 7 par.4 of Law 3864/2010 and the Cabinet Act 38/2012 (as amended by Cabinet Act 6/2013) issued on June 26, 2013, 245,779,626 warrants were granted to private investors participating in the capital increase of the Bank in 2013 according to Law 3864/2010 and Cabinet Act 38/2012. Trading of the warrants on the Athens Stock Exchange began on June 27, 2013.

Warrants are transferable securities with no restrictions concerning their transfer. Each warrant incorporates the right of its holder to purchase HFSF shares, the corresponding number of which is determined based on the provisions of Cabinet Act 38/2012, while relevant terms are adjusted in case of corporate actions according to the provisions of the relevant legal and regulatory framework. In line with Cabinet Act 43/2015 which amended Cabinet Act 38/2012, the warrants exercise terms and

conditions were adjusted in 2015, to each warrant incorporating the right of its holder to purchase from HFSF 0.54861592129144 shares, acquired by HFSF due to its participation in the above capital increase of Bank, while based on Cabinet Act 43/2015 the exercise prices applying to each exercise period were also adjusted in 2015. The warrants do not provide voting rights to holders or owners thereof.

The warrants may be exercised every six months, with the first exercise date being six months following their issuance and the last exercise date being fifty-four (54) months following their issuance. Call options not exercised until the last aforementioned exercise date will automatically cease to exist and the corresponding warrants will be cancelled by HFSF. The procedure for the exercise of the call option and their settlement, as well as any change in the rights and obligations of the holders of warrants that may occur during the term that the warrants are in force, is announced by the Bank on its website and in the Daily Bulletin of the Athens Stock Exchange at least 10 days prior to each date of exercise of the warrants. The last exercise date (December 27, 2017) is the date of expiry of the warrants.

Following the reverse split in November 2015, the exercise price of the call option for each warrant in order to acquire new shares held by HFSF, will be equal to EUR 64.35 plus accrued interest at an annual rate of 3% plus the margin:

on the number of new shares that the holder of the warrant is entitled to acquire upon exercise of his right. The exercise price will be adjusted accordingly in the event of corporate actions and is announced by the Bank on its website and in the Daily Bulletin of the Athens Stock Exchange. The last exercise date (December 27, 2017) is the date of expiry of the warrants.

After 36 months from the issuance of the warrants, HFSF may, under certain conditions, transfer the underlying common shares to third parties without any compensation being owed to holders of warrants that decide not to acquire those shares.

After the end of the fifth exercise period (December 28, 2015), outstanding warrants were 245,745,725, whereas the shares of the Bank upon which they are drawn and which are held by HFSF are 134,820,022 (after the reverse split).

The reporting requirements for financial institutions are governed by the CRD IV framework. EU Implementing Regulation 680/2014, as in force, has established implementing technical standards with regard to supervisory reporting of institutions according to EU Regulation 575/2013 (CRR). Specifically, the said Regulation lays down uniform requirements in relation to supervisory reporting to competent authorities for the following areas:

The Bank submits to the Bank of Greece / ECB (SSM) a full set of regulatory reports both at Bank and at Group level on a quarterly basis. Some of the above information is submitted on a monthly basis.

In addition to the above reporting requirements, the SSM set up in 2014 a quarterly structured data collection process, the "Short Term Exercise (STE)", comprising reports regarding credit risk, profitability, concentration risk, market risk, liquidity risk, sovereign risk and banking book interest rate risk at Group level. This data collection process is effective up to the end of 2016 and forms a part of SSM's broader "Supervisory Review and Evaluation Process (SREP)" aiming, among other things, to assess the capital and liquidity needs of EU banks.

ECB published Regulation 2015/534 on reporting of supervisory financial information. The Regulation lays down the rules and procedures for the reporting of supervisory financial information by supervised entities to National Competent Authorities and the ECB.

Finally, the Bank submits to the Bank of Greece on a regular basis a full set of regulatory reports with information (e.g. for capital structure related parties, internal control systems, AML/CFT, information technology systems, branches of the Bank etc.) both at Bank level and at Group level, according to the stipulations of the Bank of Greece Governor's Act 2651/2012, as in force.

The Hellenic Deposit Guarantee Fund commenced its operations in September 1995. Greek Law 4370/2016 on Deposit Guarantee Schemes and the Hellenic Deposit and Investment Guarantee Fund (the "HDIGF") transposes Directive 2014/49/EU into Greek legislation.

According to Greek Law 4370/2016, the HDIGF is a private law legal entity, has its registered seat in Athens, is supervised by the Minister of Finance, is not a public organization or a state owned legal entity and does not belong to the Greek public sector.

Greek Law 4370/2016, which replaces Law 3746/2009, previously in force, defines, among others, the scope and certain aspects of the operation of the HDIGF, the terms of participation of credit institutions as well as the process for determining and paying contributions to its Schemes. According to Greek Law 4370/2016, the HDIGF objectives are (1) to indemnify depositors of banks participating in the HDIGF who are unable to fulfill their obligations towards their depositors and to fund

resolution measures of the banks through the deposits cover scheme (the "Deposit Cover Scheme") in accordance to article 104 of Greek Law 4335/2015 (BRR Law), (2) to indemnify investors—clients of banks, in relation to the provision of investment services from these banks in case the latter are unable to fulfill their obligations from the provision of covered investment services through the investments cover scheme (the "Investment Cover Scheme") and (3) to provide for the provision of financing to banks placed under the resolution measures through the resolution scheme (the "Resolution Scheme") in its role as Resolution Fund. All authorized banks in Greece, with certain exemptions, and the local branches of credit institutions which have been established in non-EU Member States and are not covered by a guarantee scheme equivalent to that of the HDIGF, are obliged to participate in the aforementioned schemes of the HDIGF. Greek branches of foreign credit institutions established in EU Member States may also become members of the investments cover scheme of HDIGF at their discretion.

A credit institution shall not take deposits unless it is a member of the aforementioned Deposit Cover Scheme.

The maximum coverage level for each depositor at a credit institution under Greek Law 4370/2016 is EUR 100,000, taking into account the total amount of its deposits with a bank minus any due and payable obligations towards the latter. This amount is paid in the currency of the State where the account is located, to each depositor as an indemnity irrespective of the number of accounts held in a credit institution, the currency, or the place within the EU where the deposit is held. In case of joint bank accounts, each depositor's share shall be taken into account for the purposes of the calculation of the maximum indemnification amount as a separate deposit and is entitled to cover up to the aforementioned limit with his or her other deposits, as analyzed above. In the absence of special provisions or in the event that the relative proportions of joint account holders in an account have not been specified, for the purposes of compensation, such an account shall be divided equally among the depositors. In case of so-called temporary high deposit balance—stemming from real estate transactions (e.g. sale of property) as well as from some specific life events (such as compensations due to divorce, retirement, etc.)—depositors will be entitled to coverage up to EUR 300,000. However, such coverage will be limited in time up to maximum three months after the determination by the competent authority or a judge that deposits are unavailable and after a relevant petition of the depositor towards HDIGF.

Depositors must be able to access their funds within seven working days after the determination by the competent authority or a judge that deposits are unavailable.

Covered deposits are explicitly excluded from the bail-in regime. Certain deposits are excluded from coverage by the Deposit Cover Scheme, such as deposits made by other credit institutions, financial institutions, investment firms, collective investment undertakings and public authorities.

The HDIGF also indemnifies the investors-clients of banks participating in the HDIGF with respect to claims from investment services falling within the scope of Greek Law 4370/2016, up to the amount of EUR 30,000 for the total of claims of such investor, irrespective of covered investment services, number of accounts, currency and place of provision of the relevant investment services. In case the investors of HDIGF member credit institutions are co-beneficiaries of the same claim to guaranteed investment services, each investor's share in the claim shall be taken into account for the purposes of the calculation of the maximum indemnification amount as a separate claim and is entitled to cover up to the aforementioned limit in aggregate with his or her other investment claims. If the part of the claim corresponding to each co-beneficiary is not specified in the agreement signed by the co-beneficiaries and the HDIGF member credit institution, for the purposes of compensation each co-beneficiary is considered as having an equal share in the investment.

Certain investors are excluded from coverage by the Investment Cover Scheme, such as claims made by other credit institutions, financial institutions, investment firms, collective investment undertakings.

Pursuant to Greek Law 4370/2016, all, credit institutions licensed to operate by the competent authority in Greece must participate in the Resolution Scheme. Pursuant to Greek Law 4335/2015, the Resolution Scheme is empowered to collect from participating credit institutions, including the local branches of credit institutions established in non-EU Member States, ex ante contributions and, under certain circumstances, extraordinary ex post contributions. Ex ante contributions are calculated taking into account the risk profile of the relevant credit institutions whereas ex post contributions are calculated pursuant to a decision of the competent authority which imposes the contribution.

Credit institutions, apart from contributions paid to each of the three schemes of the HDIGF at least on an annual basis, must pay on an annual basis contributions to HDIGF for its operational and investment expenses.

In order to protect the Greek financial system and the Greek economy in general from the lack of liquidity, Legislative Act of June 28, 2015 introduced a short term bank holiday period starting on June 28, 2015 and imposed capital controls, which apply to all credit institutions operating in Greece in any form. As prescribed by the aforementioned Act, credit institutions were required to remain closed to the public during the bank holiday period, although specific bank branches were subsequently permitted to open in order to perform certain transactions as contemplated by the relevant legislative provisions.

Within the context of the capital controls regime, a Bank Transactions Approval Committee was established at the Ministry of Finance, with the responsibility of examining and approving transactions in view of the capital controls framework.

Following a decision of the above Committee, each credit institution was able to establish a special subcommittee for the approval of transactions in the context of the capital controls framework. The Bank Transactions Approval Committee is responsible for determining the conditions of operation of these subcommittees and any other procedural and operational detail, including the amount and breakdown by credit institution of the daily limit on individual types of transactions and the reevaluation of such limits.

Pursuant to Legislative Act of July 18, 2015 ("Act"), the short term bank holiday period ended on Monday, July 20, 2015, while the capital controls and restrictions on banking activities were extended. Moreover, it was prescribed that the Bank Transactions Approval Committee would continue its operation. The capital controls regime continues to apply as of the date of this Annual Report.

The aforementioned framework and the above Act, as amended and in force, impose the following restrictions on bank transactions:

Transactions carried out by the Hellenic Republic and the Bank of Greece are excluded from the restrictive measures set out above.

Transactions in financial instruments traded on Greek regulated markets were subject to the provisions of Minister of Finance Decision published in the Official Gazette of the Greek Republic, Issue B' number 1617/31.7.2015 on "Lifting of the restrictions of the Legislative Act regarding transactions in financial instruments on Greek regulated markets". A basic prerequisite determined by this Decision, was that transactions on financial instruments of Article 5 of Greek Law 3606/2007 (MiFID) traded on Greek regulated markets and multilateral trading facilities ("MTF") in Greece ("Financial Instruments") would be conducted with "new money", as defined in the Ministerial Decision (e.g. money deriving from the sale of financial instruments of Article 5 of Greek Law 3606/2007 excluding units in collective investment undertakings).

The above decision was subsequently overturned by the Decision of Minister of Finance published in the Official Gazette of the Greek Republic, Issue B number 2625/7.12.2015 on "Lifting of the restrictions of the Legislative Act regarding transactions in financial instruments on Greek regulated markets".

In addition, the proceeds from the clearing and settlement of transactions on Financial Instruments, as well as the amount of the cash distributions from the issuers to the beneficiaries of the financial instruments of article 5 of Greek Law 3606/2007, can be credited to a bank account up to the end beneficiary, even outside the Greek banking system, on the condition that the clearing and settlement of transactions of the relevant investment account was made through such account before the commencement of the bank holiday period (i.e. before June 28, 2015).

Finally, according to Decision no. 743/07.12.2015 of the HCMC, short selling of shares of the credit institutions admitted to trading on the ATHEX and comprising the FTSE/ATHEX Banks Index (the "FTSE/ATHEX Banks Index"), irrespective of the venue where the transaction is executed (regulated market, MTF or OTC) were prohibited. The short selling prohibition included sales which are covered by subsequent intraday purchases. The short selling prohibition applied to all depository receipts (ADRs, Global Depository Receipt ("GDRs")) and warrants representing the above shares. The measure was in force from and including the entire day of December 8, 2015 to and including the entire day of December 21, 2015.

From January to February 2013, monitoring trustees (each, a "Monitoring Trustee"), acting on behalf of the European Commission, were appointed in all banks under restructuring—including the Bank, in accordance with the commitments undertaken by the Hellenic Republic towards the European Commission in 2012, regarding banks under restructuring, in the Memorandum of Economic and Financial Policies, contained in the First Review of the Second Economic Adjustment Program for Greece.

The Monitoring Trustees are respected international auditing or consulting firms approved by the European Commission on the basis of their competence, their independence from the banks and the absence of any potential conflict of interest. In each credit institution under restructuring, the Monitoring Trustees work on behalf and under the direction of the European Commission, within the

terms of reference agreed with the European Committee ("EC"), the European Central Bank ("ECB") and International Monetary Fund ("IMF") staff.

The commitments undertaken in 2012 were updated and included as an Annex in the 2014 Restructuring Plan. The commitments were further updated in December 2015 and included as an Annex in the Revised Restructuring Plan.

In addition to the appointment of Monitoring Trustees, the commitments undertaken by the Greek government see to the Item 4.A, "History and Development of the Company—Revised Restructuring Plan approved by the Directorate General for Competition on December 4, 2015".

The commitments include the commitments regarding the implementation of the restructuring plan and the commitments on corporate governance and commercial operations. The restructuring period shall end on December 31, 2018. The commitments apply throughout the restructuring period unless the individual commitment states otherwise. The Monitoring Trustee has the duty to monitor the Bank's compliance with the Commitments.

The Monitoring Trustee submits relevant reports to the EC/ECB/IMF on a quarterly basis.

The Trustee monitors closely the Bank's commercial practices, participates as an observer in meetings of the Board of Directors and certain Board/Executive Committees and has full access to any of the Bank's records including board minutes.

Directive 2007/64/EC on Payment Services provides for common rules on electronic payments (e.g., payments through the use of debit card or money transfers) in 31 countries (i.e., countries of the EU, Iceland, Norway and Lichtenstein). The PSD regulates in detail the information that must be provided to the users of the payment services and renders the payments faster and more secure. It also permits to 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 PSD covers any kind of payment through electronic means and not payments made in cash, from transfer of credit and direct charge orders to payments through the use of a card (including credit cards), wire transfers and payments through the use of a mobile phone and internet, excluding the payments with cash and checks. Payments in every European currency, not only euro, are covered, under the condition that the payment service providers of both the payer and the payee are located in one of the 31 European countries.

The PSD, together with Directives 2007/44/EC and 2010/16/EU were transposed into Greek law by Greek Law 3862/2010, in accordance with which every payment service provider, including the Bank, is obliged to ensure in an accessible form a minimum level of information and transparency regarding the payment services provided, under specific terms and conditions. The relevant framework also provides further protection regarding the rights of the users of the payment services.

A new payment services directive 2015/2366 (the "PSD 2") has been published, incorporating and repealing the PSD. The PSD 2 is expected to improve the functioning of the internal market for payment services and more broadly for all goods and services given the need for innovative, efficient and secure means of payments. The PSD 2 entered into force on January 12, 2016 and the PSD is repealed with effect from January 13, 2018. By January 13, 2018, Member States shall adopt, publish and apply the measures necessary to comply with this revised directive. The European Council has also adopted Regulation 2015/751 on interchange fees for card-based payment transactions.

Directive 2014/92/EU provides for the comparability of fees related to payment accounts, payment account switching and access to payment accounts with basic features.

By September 18, 2016, EU Member States shall adopt and publish the laws, regulations and administrative provisions necessary to comply with this Directive. Subject to certain derogations, they shall apply the aforementioned measures from September 18, 2016.

Greek Law 3816/2010, passed in January 2010, allowed borrowers who are physical or legal persons to apply for the settlement of professional and corporate debts, whether or not due (from January 1, 2005 onwards) to lending banks. To take advantage of the relevant provisions, an application must have been submitted by the debtor to the relevant bank by April 15, 2010. The law provided, among other things, that settled debts may be treated as follows:

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

Greek Law 3816/2010 also allowed the settlement of debts from loans for corporate, professional or agricultural purposes 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, a two-year suspension of the capital payment with a corresponding extension of the contractual term of the loan or a three-year extension of the contractual term of the loan.

On August 3, 2010, Greek Law 3869/2010 (see also "Constraints on the Use of Capital—Restrictions on Enforcement of Granted Collateral") was put in force with respect to the "settlement of amounts due by indebted individuals" and was modified mainly by Greek Laws 3996/2011, 4019/2011, 4161/2013,4336/2015, 4346/2015 and 4366/2016. The law allows the settlement of amounts due by individuals evidencing permanent and general inability to repay their debts, by submitting an application for a three-year settlement of their debts and writing off the remainder of their debts, in accordance with the terms of the settlement agreed. All individuals, consumers and professionals are subject to the provisions of Greek Law 3869/2010, with the exception of individuals already subject to mercantile law. Applicants having submitted applications prior to Greek Law 4336/2015 but not yet been heard or settled may reapply in order to benefit from the provisions of Greek Law 4336/2015.

All the debts of the abovementioned to private individuals fall within the law, including all debts to banks (consumer, mortgage, business loans), except for debts due to an offense committed by the

borrower with intention or gross negligence, administrative fines, monetary sanctions and debts related to the obligation for child or spousal support. By virtue of Greek Law 4336/2015, Greek Law 3869/2010 was amended and its scope was also expanded to the settlement of debts owed to the Hellenic Republic, tax authorities, local authorities of grade A' and B' and to social security funds. In addition, the debtor may opt to include debts which at the date of filing of the petition are subject to an administrative, judicial or legal suspension or have been included in a restructuring or facilitation of partial payment which is still valid at the time of filing of the petition. Debts must have been contracted more than one year before the application date and relief may be used only once.

The amendments effected by Greek Law 4346/2015, among others, lay out the conditions for: (a) the protection of the primary residence of a debtor from forced sale, and (b) the partial funding by the Hellenic Republic of the amount of monthly payments set by court decision. In addition, it is provided that the debtor's obligation to act as a cooperating borrower also applies throughout the settlement plan period. These amendments became effective as from January 1, 2016.

Before the submission of the application, the parties may have recourse to the preliminary settlement procedure. After the submission of the application, the hearing date of the application (compulsory within six-months from the completion of submission of the application) and the day of validation (within two months from the completion of the submission of the application) are set. During the day of validation, the court either validates any preliminary settlement or issues a preliminary injunction (with maximum duration six-months) by virtue of which the court may order, inter alia, the suspension of prosecuting measures against the borrower and determines the amount of the monthly installments which the borrower has to pay to its creditors until the issuance of the decision. Following the day of validation and until the hearing date of the application, the parties may reach to a settlement at any stage of the procedure.

If creditors having claims exceeding half of the total claims' amount, including collateral secured creditors and creditors having claims exceeding half of any labor claims, are included in the debts settlement plan proposed by the borrower, the court substitutes in any procedural stage the lack of the consent of any creditor, who is abusively opposed to the settlement, except where a. the claim of such creditor is not proportionally satisfied, compared to the other creditors; or b. in case of implementation of the plan, such creditor proves that its financial position shall be less favorable than the one it would have been in case of continuation of the procedure for the debtor's relief; or c. a claim is disputed by the borrower or any other creditor.

During the hearing date of the application, if the creditors do not accept the debtors' settlement plan, or if objections are submitted by some creditors and not substituted according to the above, the court confirms the existence of the disputed claims, the fulfillment of the conditions for settlement of debts and the borrower's relief. If the borrower's real estate property is not sufficient, after deducting the required amount for the coverage of the reasonable living expenses of the borrower and the members protected by the latter, including social security expenses borne by the borrower, the court orders the monthly payment of the remaining amount for the satisfaction of creditors' claims, pro rata distributed and for a period of three (3) years, pursuant to the borrowers' income and its real estate property.

Greek Law 4336/2015 introduced an accelerated settlement process regarding minor debts of particular indebted individuals. Indebted individuals are given a temporary relief for their debts and an eighteen-month period of supervision is granted, after the expiration of which, and only if the real estate property or income situation of the borrower remain unchanged, the borrower is discharged from the remainder of its debts.

If there are assets that can be liquidated and their liquidation is deemed necessary, a liquidator is appointed by the court. Special provisions are set for the protection of the main residence of the debtor. In case that the debtor does not fulfill the obligations under the settlement plan or intentionally

delays four consecutive monthly payments on a yearly basis or payments so that the due amount cumulatively exceeds the value of four (4) monthly installments annually, the court allows the creditor to commence liquidation procedures against the debtor and his only residence. 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.

Code of Conduct for the management of non-accruing loans and loans in arrears

Pursuant to Greek Law 4224/2013 and Cabinet Act 6/2014, a governmental council for private debt management (the "Council") has been created with the following objectives:

Moreover, according to the provisions of Greek Law 4224/2013, the Council provided a definition of "cooperating borrower" specifying when a borrower is classified as cooperating towards his/her lenders and assessed a methodology for determining "reasonable living expenses".

Greek Law 4224/2013, in conjunction with ministerial decision no. 5921/2015, provides that the consumer ombudsman will act extra judicially as mediator solely for the amicable settlement of the dispute between lenders and borrowers for the purpose of settling non- accruing loans within the framework of the Bank's Code of Conduct for the management of non- accruing loans.

Greek Law 4224/2013 was further amended by Greek Law 4336/2015, introducing the following:

Bank of Greece has published new regulatory framework concerning the management of loans in arrears and non-accruing loans and specifically:

Executive Committee Act No. 42/30.5.2014, as in force, lays down a special framework of requirements for credit institutions' management of past due and non-accruing loans, in the framework of the provisions of Law 4261/2014, EU Regulation 575/2013 and the relevant Bank of Greece decisions. This framework imposes, among others, the following obligations on credit institutions:

In order to ensure an objective and impartial approach to ANPLM and the application of modifications to distressed debtors, credit institutions shall ensure that the ANPLM function enjoys an appropriate degree of independence from other functions, in particular the lending and management of performing loans functions. This function shall be clearly defined, separate and subject to control and monitoring by the internal audit function of the credit institution.

Code of Conduct under Greek Law 4224/2013, as amended by virtue of no. 129/2/16.2.2015 and no. 148/10/05.10.2015 decision of the Credit and Insurance Committee of the Bank of Greece, lays down general principles of conduct and introduces best practices, aimed to strengthen the climate of confidence, ensure engagement and information exchange between borrowers and lending institutions, so that each party can weigh the benefits or consequences of alternative forbearance or resolution and closure solutions for loans in arrears for which the loan agreement has not been terminated, with the ultimate goal of working out the most appropriate solution for the case in question.

Each institution falling within the framework of the Code of Conduct of law 4224/2013 has to implement, inter alia, an Arrears Resolution Procedure (hereinafter "ARP"), a detailed record with categorization of loans and borrowers, to which the examination procedure of the objections is recorded with details, as well as to establish an Objections Committee composed by at least three of its senior executives.

In dealing with cases of borrowers in arrears or pre-arrears, every institution shall apply an ARP involving the following steps:

It should be noted that the Bank of Greece will not deal with individual cases of disputes between creditors and borrowers that may arise from the implementation of the Code of Conduct.

Greek Law 4281/2014, among others, amended Article 1 of Greek Law 4224/2013, currently laying down the following:

In accordance with Credit and Insurance Committee Decisions 129/2/16.2.2015 and 148/10/05.10.2015 provisions of Credit and Insurance Committee Decision 116/1/25.8.2014 "Introduction of a Code of Conduct under Greek Law 4224/2013" is amended, prescribing specific timeframes and procedures for notifications to borrowers.

The above amendment does not defer the entry in force of the rest of the obligations following the application of the Code of Conduct under Greek Law 4224/2013 for credit institutions, since, save for those amendments, the provisions of Credit and Insurance Committee Decision 116/1/25.8.2014, as amended by Credit and Insurance Committee Decisions no. 129/2/16.2.2015, still apply. Notably, among those obligations is the consistent application of the procedures set out by the Code, before the incidental termination of the contractual relationship, in the cases where no use of the above transitional provision is made.

Furthermore, Greek Law 4354/2015, as amended by Greek Laws 4366/2016 and 4371/2016 and 4380/2016 (art.2), as well as Executive Committee Act 82/8.3.2016 establish the framework for the management and transfer of claims from non-performing loans by setting the requirements for the operation of credit servicing or credit acquiring firms. Articles 1 to 3 of Greek Law 4354/2015 incorporate provisions regarding the establishment and operation of two types of companies: Non-performing Loans Management Companies (N.P.L.M.C.) and Non-performing Loans Transfer Companies (N.P.L.T.C.)

The management and transfer of claims from non-performing loans and credit shall be undertaken, exclusively by Societe Anonymes having their registered offices:

Bank of Greece is the competent authority for the issuance of the respective license for such companies.

Furthermore, the aforementioned companies, following a relevant authorization by Bank of Greece, may grant loans or credit to debtors whose loans and/or credit have been purchased by them, aiming exclusively at the refinancing of the debtors' loans. The management companies (N.P.L.M.C.) may grant new loans on condition that they have the prior consent of the claims' owner.

In relation to the agreements for the assignment of claims' management from non-performing loans, Greek Law 4354/2015 lays down that Non-performing Loans Management Companies may undertake the management of claims from loans and/or credit, which are non-performing for a period exceeding ninety (90) days as well as the management of claims from performing loans. The latter shall be assigned along with claims from non-performing loans of the same debtor. Said management companies are entitled to initiate any legal proceedings and to proceed with any other judicial measures for the collection of claims.

In relation to the agreements for the sale and transfer of claims from non-performing loans, Greek Law 4354/2015 lays down that the credit institutions which are licensed by Bank of Greece, the branches of foreign credit institutions in Greece, the special purpose companies of article 10 of Greek Law 3156/2006 and the N.P.L.T.C. may sell or transfer their claims arising from any kind of loan and credit agreements, which are non-performing for a period exceeding ninety (90) days, to financial and credit institutions as well as to other N.P.L.T.C. In case of sale of a group of claims against the same debtor, performing claims may also be included in the said group. The latter would apply if non-performing loans of the same debtor are part of that group as well.

In accordance with Greek Law 4354/2015 regarding the sale and transfer of non-performing loans, as in force, the following claims are excluded until May 15, 2016:

It is noted that, in the context of a draft law submitted for discussion to the Hellenic Parliament, the relevant exclusion based on the draft law is to be extended until June 15, 2016.

Greek Law 4307/2014, as amended by Greek Laws 4374/2016 and 4380/2016 (art. 2) and in force, among others, provides for urgent interim measures for the relief of private debt, especially debt of viable small businesses and professionals towards financial institutions (namely credit institutions, leasing and factoring companies, provided they are under the supervision of the Bank of Greece), the Hellenic Republic and Social Security Institutions, as well as for emergency procedures for the reorganization or liquidation of operating indebted but viable businesses, provided that the aforementioned persons are considered as "eligible debtors" under the relevant provisions, namely, they have submitted the relevant application by June 30, 2016 and cumulatively meet the following criteria:

For the implementation of the above procedure the Ministerial Decision 4837 (Government Gazette Issue B'66/16.1.2015) has been issued.

Greek Law 4161/2013 established a facilitation program allowing individuals in financial distress to service their loans by paying reduced monthly installments for a prescribed period of time. The facilitation program applies exclusively to loans contracts entered into no later than June 30, 2010 and which have not fallen due, are secured on residential property and owed to credit institutions, financial institutions and credit companies.

Those eligible for the facilitation program are individuals whose total household income at the time of submission of the application has fallen by at least 20% since 2009. The provisions of Greek Law 4161/2013 set forth additional eligibility criteria relating, among others, to the value of the debtor's primary residence over which the bank has collateral and total immovable property, as well as to the total annual household income. Debtors who benefit from the facilitation program are subject to an ongoing duty of disclosure of their financial status, and failure to comply with that duty results in the debtor's removal from the scheme. Moreover, the facilitation program is granted only once and for a maximum grace period of 48 months. After the grace period, the facilitation program is automatically terminated and the debtor, if not otherwise agreed, fulfills his contractual obligations as agreed prior to the facilitation program and the duration for performing the contract is prolonged for a period equal to the grace period.

Credit institutions in Greece cannot terminate the contracts of individuals who have joined the facilitation program and must refrain from pursuing any enforcement proceedings against the debtor and its guarantor.

The original deadline for submission of applications for participation in the facilitation program was January 16, 2014. However, according to Ministerial Decision Z1-32/2014, this deadline has been extended for three more months.

Credit institutions in Greece are also subject to various legislation that seeks to protect consumers from abusive terms and conditions, most notably Greek Law 2251/1994 as in force. Such legislation sets forth rules on the marketing and advertisement of consumer financial services, prohibits unfair and misleading commercial practices and includes penalties for violations of such rules and prohibitions.

At the same time, numerous consumer protection issues are regulated through administrative decisions, such as Decision No. Z1 798/2008 of the Minister of Development on the prohibition of general terms which have been found to be abusive by final court decisions, as amended by Ministerial Decisions Z1-21/2011 and Z1-74/2011. Also, the Governor of the Bank of Greece Act No. 2501/2002, as in force, includes fundamental disclosure obligations of credit institutions operating in Greece vis- à-vis any type of contracting party.

Ministerial Decision Z1-699/2010 (Government Gazette Issue B; 917/.2010) transposed into Greek Law Directive 2008/48/EC on credit agreements for consumers and repealing Council Directive 87/102/EEC, as amended and currently applicable. The aforementioned decision provides for increased consumer protection in the context of consumer credit transactions and prescribes, among others, the inclusion of standard information in advertising and the provision of pre contractual and contractual information to consumers. Ministerial Decision Z1-699/2010 was amended by Ministerial Decision Z1-111/07.03.2012 (Government Gazette Issue B'27/2012) that transposed into Greek Law European Directive 2011/90 providing additional assumptions for the calculation of the annual percentage rate of charge.

Most recently, Ministerial Decision 56885/2014 set a code of conduct for the protection of consumers during sales, offer periods and promotional actions while Joint Ministerial Decision 70330/2015 transposed Directive 2013/11/EU on alternative dispute resolution for consumer disputes and introduced supplementary measures for the application of Regulation EU 524/2013 on online dispute resolution for consumer disputes.

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 relating to the prevention of money laundering and terrorist financing.

More specifically Greek Parliament adopted Greek Law 3691/2008, as in force, on the prevention and suppression of money laundering and terrorist funding, which implemented EU Council Directives 2005/60/EC and 2006/70/EC. The main provisions of Greek legislation on money laundering and terrorist financing are as follows:

Following the amendments of the Greek Law 3691/2008 provisions were added about the tax evasion, smuggling and non-payment of debts to the State as main offences, as well as provisions regarding the necessary legalization documents for the verification of client's identity and provisions for law infringement.

The Banking and Credit Committee of the Bank of Greece, has also issued Decision No. 281/5/17.3.2009 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 Decision 285/6/09.07.2009, which sets an indicative typology of unusual or suspicious transactions within the meaning of Greek Law 3691/2008 as well as Decision 290/12/11.11.2009. Both the aforementioned decisions 281/5/17.3.2009 and 290/12/11.11.2009 were supplemented by Decision 300/30/28.7.2010, while Bank of Greece Governor's Act no 2652/29.02.2012, by amending Decision 281/5/17.3.2009 and supplementing Decision 285/6/09.07.2009 included therein:

Decision No. 281/5/2009 takes into account the principle of proportionality, and includes the obligations of all credit and financial institutions and FATF recommendations. This decision also reflects the common understanding of the obligations imposed by European Regulation 1781/2006 on the "Information on the Payer Accompanying Transfers of Funds".

Since 2012, the FATF standards have been revised to strengthen the requirements for higher risk situations, and to allow financial institutions to take a more focused approach in areas, where high risks remain or implementation could be enhanced. Banks should first identify, assess and understand the risks of money laundering and terrorist finance that they face, and then adopt appropriate measures to mitigate the risk. The risk-based approach allows them, within the framework of the FATF requirements, to adopt a more flexible set of measures, in order to target their resources more effectively and apply preventive measures that are commensurate to the nature of risks, in order to focus their efforts in the most effective way.

In view of the above, the Bank of Greece issued two Decisions (No. 94/23/2013 and 95/10/22.11.2013) which further strengthen the regulatory framework within which the supervised entities in Greece operate. Decision no. 95/10/22.11.2013 on information to be periodically disclosed by supervised institutions to the Bank of Greece was further amended by Decision no. 108/1/04.04.2014, enhancing the frequency of reporting. The amendments mainly harmonize the applicable regulations to the revised FATF recommendation with respect to Politically Exposed Persons ("PEPs") by categorizing local PEPs as high-risk customers; introduce criteria for the use of simplified due diligence by electronic money institutions; and impose additional obligations for suspicious transactions reporting to the supervised banks, pertaining to the cross-border transfer of funds as well as data on high- risk banking products and customers.

Directive (EU) 2015/849 (required to be transposed into national law on or before June 26, 2017) on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 and repealing Directive 2005/60/EC and Directive 2006/70/EC, as well as Regulation 847/2015 (which will come in to force on June 26, 2017) on information accompanying transfers of funds, repealing Regulation (EC) No 1781/2006, are intended to strengthen EU rules against money laundering and ensure consistency with the approach followed at international level. The Regulation deals more specifically with information accompanying transfers of funds. The texts implement recommendations by the Financial Action Task Force (FATF), which is

considered a global reference for rules against money laundering and terrorist financing. On some issues, the new EU rules expand on the FATF's requirements and provide additional safeguards.

The CRD Law (which has replaced Greek Law 3601/2007 in its entirety) does not contain any provision regulating equity participations by Greek credit institutions in other companies.

Regulation 575/2013, which applies directly since January 1, 2014 (with the exception of specific articles), to all EU Member States (including Greece) provides in article 89 that competent authorities of EU Member States shall publish their choice on the requirements applicable to acquisitions by credit institutions of qualifying holdings in other companies, based on the choices made available in article 89 of Regulation 575/2013. Pursuant to Decision 114/2014 of its Credit and Insurance Affairs Committee, the Bank of Greece has elected option (a) as referred in paragraph 3 of article 89. In particular, in respect of (i) a qualifying holding exceeding 15% of the eligible capital of a bank in undertakings outside the financial sector and (ii) a total amount of qualifying holdings exceeding 60% of the eligible capital of a bank in undertakings outside the financial sector, Bank of Greece elected the option by virtue of which for the purpose of calculating the capital requirement in accordance with the provisions of the Regulation 575/2013, banks shall apply a risk weight of 1.250% to the greater of the amount of qualifying holdings referred to under (i) above in excess of 15% of eligible capital of the bank and the total amount of qualifying holdings referred to under (ii) above that exceed 60% of the eligible capital of the bank.

Under the previously applicable Greek Law 3601/2007, the Act of the Governor of Bank of Greece No. 2604/2008, as clarified by decision 281/10/17.03.2009 of the Banking and Credit Committee, had been issued regarding the conditions for the acquisition or increase in a qualifying holding in the share capital of banks, financial institutions, insurance and reinsurance 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. Following the enactment of Greek Law 4261/2014, it is not clear whether the aforementioned Act still applies or the extent to which it is applicable. Under article 166 of Greek Law 4261/2014, such regulatory decisions that have been issued pursuant to articles of Greek Law 3601/2007 remain in force until their replacement by new regulatory decisions, as long as they are not contradictory to the provisions of the CRD Law or the Regulation 575/2013.

Subject to EU regulations, new and significant holdings (concentrations) must be reported to the Greek Competition Commission according to Greek Law 3959/2011, as currently in force, and the European Commission must be notified, provided that they have community dimension within the meaning of Regulation no. 139/2004 on the control of concentrations between undertakings (as supplemented by Commission Regulation (EC) 802/2004).

The HCMC and the ATHEX must be notified once certain ownership thresholds are exceeded with respect to listed companies according to Greek Law 3556/2007, as in force, the implementing HCMC decisions and the ATHEX Regulation.

The CRD Law (mainly through Articles 23 and 27) and relevant Bank of Greece acts, establish a specific procedure for the notification to the Bank of Greece of a physical or legal person's intention to, directly or indirectly, acquire or increase or dispose a holding exceeding certain enumerated thresholds according to article 23 of the CRD Law (i.e., 20%, 1/3 and 50% of voting rights or equity

participation in or control of a bank). The applicant acquirer is assessed by the Bank of Greece on the basis of a series of criteria set out in article 24 of the CRD Law and, approval is required in line with the provisions of the law for the intended acquisition.

Executive Committee Act No. 22 of Bank of Greece, issued on July 12, 2013, as in force, codifies the provisions regarding the authorization of credit institutions in Greece and the acquisition of a qualifying holding in a credit institution. Furthermore, this act specifies the necessary information for the prudential assessment of the proposed shareholders, the proposed members of the management body and the proposed key function holders of a credit institution by the Bank of Greece under the EBA guidelines. Moreover, according to Executive Committee Act No. 48 of Bank of Greece, issued on March 24, 2015, the aforementioned information should be accompanied by appropriate privacy statements included in this Act concerning personal data processing. Given that: (a) no other implementing act(s) of the relevant provisions of Greek Law 4261/2014 has been issued and (b) that the provisions of this Act, do not appear to be at any point contradictory to the relevant provisions of the CRD Law, the provisions of the Executive Committee Act No. 22 of Bank of Greece shall be considered as applicable and in force, pursuant to article 166 para. 2 of the CRD Law.

As at November 4, 2014, the supervisory tasks described above were conferred to the ECB in cooperation with the Bank of Greece, according to the provisions of Regulation 468/2014.

There are no constraints on the use of capital that have or may have a significant impact, directly or indirectly, on the Group's activities, except for constraints discussed above, including based on article 28 of Greek Law 3756/2009 (prohibition of acquiring own shares for the whole period the Bank is participating in the Hellenic Republic Bank Support Plan—see Item 8.A, "Consolidated Statements and other Financial Information—Policy on Dividend Distributions and the Amended Relationship Framework Agreement signed with HFSF, following the Bank's recapitalization pursuant to the HFSF Law (see "—The Hellenic Financial Stability Fund—The Greek Recapitalization Framework") and the obligations towards the Monitoring Trustee and the Revised Restructuring Plan approved by the Directorate General for Competition on December 4, 2015. Additionally, pursuant to Article 131 of the CRD Law, the Bank may not make discretionary payments (as defined in the CRD IV), beyond the Maximum Distributable Amount, as described under Item 8.A, "Consolidated Statements and other Financial Information—Policy on Dividend Distributions".

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. Specifically, Governor of the Bank of Greece Act No. 2501/31.10.2002 and Decision No. 178/19.7.2004 of the Banking and Credit Committee of the Bank of Greece provide that credit institutions operating in Greece should, among others, determine their interest rates in the context of the open market and free competition rules, taking into consideration the risks undertaken on a case-by-case basis, as well as potential changes in the financial conditions and data and information specifically provided by parties for this purpose.

Limitations apply to the compounding of interest under Greek Law. 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 in force and article 39 of Greek Law 3259/2004, as in force. Greek credit institutions must also apply article 150 of the CRD Law on interest rates of loans and other credits pursuant to which credit institutions are precluded from accounting for interest income from loans which are overdue for more than a three

month period or a six-month period in case of loans fully secured by real estate which are given to physical persons.

Moreover, according to Article 150 par.2 of the CRD Law it is prohibited to grant new loans for the repayment of overdue interest or to enter into debt settlement having a similar result, unless such actions are taken in the context of an agreement for the settlement of the entirety of the debts of the borrower, which shall be based on a detailed examination of the borrower's capacity to fulfill the undertaken obligations under specific time frames. Default interest may not exceed the aggregate of annual, contractual interest plus a maximum percentage determined by the Bank of Greece over and above the normally applicable interest rate.

According to Greek Law 4261/2014, Article 11, among the activities that Greek credit institutions are permitted to engage is lending including, inter alia: consumer credit, credit agreements relating to immovable property, factoring, with or without recourse, financing of commercial transactions (including forfeiting).

The provisions of legislative decree 17.7/13.08.1923 regulate issues regarding the granting of loans secured by in rem rights and Greek Law 3301/2004 regulates issues regarding financial collateral arrangements.

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.

European Directive 2014/17 on credit agreements for consumers relating to residential immovable property lays down a common framework for certain aspects of the laws, regulations and administrative provisions of the EU Member States concerning agreements covering credit for consumers secured by a mortgage or otherwise relating to residential immovable property, including an obligation to carry out a creditworthiness assessment before granting a credit, as a basis for the development of effective underwriting standards in relation to residential immovable property in the EU Member States, and for certain prudential and supervisory requirements, including for the establishment and supervision of credit intermediaries, appointed representatives and non-credit institutions. As prescribed by the Directive, Member States would have to adopt and publish, by March 21, 2016 the laws, regulations and administrative provisions necessary to comply with this Directive and the provisions of this directive shall not apply to credit agreements existing before March 21, 2016. In Greece, the aforementioned Directive has not yet been transposed into Greek legislation.

The compulsory reserve requirement framework has been amended in accordance with Eurosystem regulations. As from January 2012 according to ECB Regulation 1745/2003 as amended by the Regulations 1052/2008, 1358/2011 and 1376/2014, the compulsory reserve requirement ratio set by Eurosystem regulation is 1% for all categories of liabilities (such as deposits and debt securities issued) to clients comprising the commitment base, with the exception of the following categories, to which a zero ratio applies:

Hellenic Bank Association on July 21, 2015 announced that banks operating in Greece will continue until the end of 2015, to provide protection of primary residence to borrowers under the provisions of Greek Law 4224/2013. According to Greek Law 4224/2013 enforcement of auctions concerning the primary residence of individuals was suspended from January 1, 2014 until December 31, 2014 provided that the relevant property was declared as such in the last income tax declaration of those individuals and the assessed market value of such property did not exceed the amount of EUR 200,000, under the condition that the following criteria were cumulatively met: (a) the debtor's family annual declared net income was lower than EUR 35,000 (excluding, however, any social security funds' contributions, income tax and social solidarity contribution); and (b) the total value of the debtor's assets and property did not exceed the amount of EUR 270,000 of which the total value of the debtor's deposits and securities in Greece and abroad as at November 20, 2013 did not exceed the amount of EUR 15,000 (excluding however any periodic benefits from social security or pension schemes). Those properties that did not fall under the criteria of that law were no longer protected from foreclosure and auction proceedings. During the aforementioned suspensions, debtors were obliged to pay monthly installments. Nevertheless, in exceptional cases (e.g., debtors with no income), there was an option of zero amount payments.

Furthermore, due to the difficulties caused by the imposition of the capital controls, any enforcement action and primarily auctions, seizures, evictions, were suspended from July 21 to July 31, 2015 by virtue of the ministerial decision no. 49214/21.07.2015. The validity of this ministerial decision was further extended, through successive ministerial decisions, until October 31, 2015 Further to an announcement of the Ministry of Justice, Transparency and Human Rights, dated October 29, 2015, as from November 2, 2015 any enforcement actions and primarily auctions, seizures, evictions and relevant enforcement procedures are reinstated.

Moreover, enforcement of collateral has been affected by Greek Law 3869/2010 (see "—Reporting Requirements for Banks in Greece—Settlement of Amounts Due by Indebted Individuals"), as in force, regarding restructuring of individuals' debt through a court application. Within August 2015 Greek Law 4336/2015, amended the Greek Law 3869/2010 and included in the settlement, debts to public sector, such as tax authorities, municipalities and social security organizations. As at December 31, 2015 and December 31, 2014, 71,960 and 58,948 customers that had applied to the court under the provisions of Greek Law 3869/2010 had outstanding balances of EUR 3,411 million and EUR 2,784 million respectively. So far 21% were rejected and 79% were accepted. Greek Law 3869/2010 was further amended by Greek Laws 4346/2015 and 4366/2016, referring among others to the necessary criteria for the protection of primary residence (e.g. cooperative borrower, income and residential property value thresholds) and to the possibility of partial state subsidy for three years for vulnerable borrowers under certain conditions.

Proposed EU regulation on mandatory separation of certain banking activities

On January 29, 2014, the European Commission adopted a proposal for a new regulation following the recommendations released on October 31, 2012 by the Liikanen Group on the mandatory separation of certain banking activities. The proposed regulation, which remains subject to change and review and approval by the European institutions, contains new rules to stop the biggest and most complex banks from engaging in the activity of proprietary trading in financial instruments and commodities. The new rules would also give supervisors the power and, in certain instances, the obligation to require the transfer of other high-risk trading activities (such as market-making, complex

derivatives and securitization operations) to separate legal trading entities within the group ("subsidiarization"). This aims to avoid the risk that banks would get around the ban on the prohibition of certain trading activities by engaging in hidden proprietary trading activities which become too significant or highly leveraged and potentially put the whole bank and wider financial system at risk. Banks would have the possibility of not separating activities if they can show to the satisfaction of their supervisor that the risks generated are mitigated by other means. Moreover, the proposed Regulation provides rules on the economic, legal, governance, and operational links between the separated trading entity and the rest of the banking group. Alongside this proposal, the European Commission has adopted accompanying measures aimed at increasing transparency of certain transactions in the shadow banking sector in order to prevent banks from attempting to circumvent these rules by shifting parts of their activities to the less- regulated shadow banking sector.

Under the proposed regulation, the requirements would apply to European banks that have been designated as global systemically important banks or that exceed the following thresholds for three consecutive years: a) total assets are equal or exceed EUR 30 billion; b) total trading assets and liabilities are equal or exceed EUR 70 billion or 10% of their total assets. The banks that meet either one of the aforementioned conditions will be automatically banned from engaging in proprietary trading, defined narrowly as activities with no hedging purposes or no connection with customer needs. In addition, such banks will also be prohibited from holding any units or shares in an entity that engages in proprietary trading or acquires units or shares in Alternative Investment Funds ("AIFs"). Moreover, such banks shall not with their own capital or borrowed money and for the sole purpose of making a profit for own account: (a) acquire or retain units or shares of AIFs as; (b) invest in derivatives, certificates, indices or any other financial instrument the performance of which is linked to shares or units of AIFs.

Other trading and investment banking activities—including market-making, lending to venture capital and private equity funds, investment and sponsorship of complex securitization, sales and trading of derivatives—do not seem to be subject to the ban, however they might be subject to separation.

The proprietary trading ban would apply as at January 1, 2017 and the effective separation of other trading activities would apply as of July 1, 2018.

On February 14, 2013 the European Commission published a legislative proposal on a new FTT. The proposal followed the Council's authorization to proceed with the adoption of the FTT through enhanced cooperation (i.e. adoption limited to 11 countries, including Greece). On December 8, 2015 a statement by ten of the participating Member States (Austria, Belgium, France, Germany, Greece, Italy, Portugal, Slovakia, Slovenia, Spain) was published, describing an agreement on certain features that the FTT shall have. In their statement, among others, it was mentioned that, on the basis of the features already determined and outlined in the 3435th Council meeting Outcome statement dated December 8, 2015, in order to prepare the next step, experts in close coordination with the European Commission will determine adequate tax rates for the different transactions, with a decision on these open issues to be not expected before the end of June 2016.

Following the recent amendment of the Greek income tax framework, dividends deriving from the shares of the Bank and paid to investors from fiscal year 2016 onwards will be subject to a 15% withholding tax, with the principal exception of physical persons and legal entities who/which are not tax resident in Greece and have no permanent establishment in Greece, if between Greece and their

jurisdiction of tax residency there has been concluded a double taxation avoidance treaty whereby dividends are not subjected to tax in Greece.

As a matter of Greek tax law, capital gains from the sale of shares are not subjected to tax in Greece, if realized by:

Physical persons not falling within the scope of any of the above exemptions will be called upon to pay tax over the gains realized with a tax rate of 15%. Additionally, the capital gains realized, even if exempted from tax, will be included in the calculation of their total income for the purposes of the so-called solidarity contribution, which is calculated on the basis of the total income, exempted or not from taxation.

For legal entities which are tax resident in Greece, or which are not tax resident in Greece, but hold the shares through a permanent establishment in Greece, any gains realized through their sale are not taxed separately, but are included in the calculation of their total profits, which will then be subjected to income tax.

Any sale of shares will be subject to a transaction tax imposed on sales of shares listed on the ATHEX at a rate of 0.2% on the share transfer price. This tax is borne by the seller, whether the seller is a physical or legal person, regardless of tax residency, and irrespective of any tax exemptions applicable. This tax is also applicable to over-the-counter sales. It is also applicable to over-the-counter lending transactions, in which case it is borne by the lender.

The transfer of the shares as well as the payment of dividends is exempt from stamp duty in Greece. The same applies for the lending of shares.

Inheritance or succession taxes are payable in Greece on shares of companies having their registered seat in Greece on a progressive system with tax rates ranging from 0% to 40%, depending on the degree of the relationship between the deceased and the beneficiary and the value of the estate being inherited. The above are subject to any double taxation avoidance conventions available.

The above apply, mutatis mutandis, to donations, in which case the recipient of the donation is liable for the payment of the tax.

Combining its strong brand name with its capital position, following the execution of the Capital Plan, the Bank believes it is well positioned to support the Greek economy and benefit from any Greek recovery. Within this environment, the Bank intends to leverage its strengths towards its primary goal to support Greece's economic recovery and growth. The Group strategy will consist of the following pillars:

The Bank's capital base was significantly strengthened through the capital enhancing initiatives of its recapitalization in December 2015, following ECB's Comprehensive Assessment, including the LME Offers, the International Offering, the Greek Public Offer together with the share capital and CoCos received from the HFSF. In the near-term the sale of its Turkish subsidiary, Finansbank is expected to further enhance our capital position through the significant decrease of risk weighted assets. On completion of the sale of Finansbank, the Bank intends to repay the CoCos issued in connection with having received State Aid, subject to corporate and regulatory approvals. In the medium term we expect to further improve our capital position through the implementation of the commitments in the Restructuring Plan relating to the disposal of certain international and Greek non-banking operations.

The uncertainty in the Greek banking sector and the high level of deposit outflows during late 2014 and the first half of 2015 led to a significant increase in the Group's use of ELA funding which reached EUR 17.6 billion at the peak in June 2015 from NIL at 31 December 2014. Following NBG's recapitalization in December 2015, ELA funding decreased to EUR 11.5 billion as at December 31, 2015 and EUR 11.1 billion as at May 4, 2016. This source of funding, which has been the main available source of new liquidity since the ECB lifted the waiver allowing use of Greek government bonds as collateral for ECB funding, is much costlier than other funding sources. It is the Group's ambition to target a reduction/full substitution of ELA funding as soon as possible and any return of deposits to the banking system along with proceeds from sale of assets is expected to greatly assist this transition.

Due to its significant market share in deposits, the Bank is well positioned to benefit from any return of deposits, expected to occur in time with the normalization of the economic environment.

Leveraging on its liquidity position, the Bank expects to resume extending credit as soon as the economic situation in Greece normalizes. The Bank intends to focus such new credit disbursement on the corporate segment, which benefits from higher spreads and better asset quality which should translate into improved lending margins and profitability.

Due to current economic conditions, the Group's net fees and commissions are significantly below their pre-crisis level as well as the European average (on a fee and commission/ total assets basis). The Group believes that there is significant potential for increasing fee income as the macroeconomic environment gradually recovers. The improving economic conditions should increase transaction activity which carries the potential for a major uplift in income through attractive and diversified fee sources:

The Group will continue to focus on developing a strategy to improve its cost structure by reducing both staff as well as general and administrative expenses in alignment with the Bank's overall strategic ambitions. Future staff cost savings will emerge from a number of sources, including:

General and administrative cost reductions are targeted to come from digitalization of banking operations, rationalization of IT investments and projects, and further centralization of branch operations.

As the economic backdrop recovers, the Group expects a decline in loans past due formation. In combination with the increased provisions recognized during 2015, will likely lead to a reduction of cost

of risk levels excluding recoveries over the medium term. Due to capital controls, domestic 90 days past due formation spiked in July 2015, yet this trend was only temporary and reversed to a large extent in August 2015 and September 2015.

In addition, the Bank took the step to put into place active management structures for past due and troubled loans, establishing two distinct, vertical, specialized units with end-to-end responsibility for Retail Collections and Corporate Special Assets handling, respectively. These two specialized units operate not only in compliance with Bank of Greece guidelines with respect to organization, staffing and processes, but ensure through frequent benchmarking studies conducted by independent experts that best international practices are being followed.

The active management of non performing exposures ("NPE") will be a key target for the Greek banking sector and the Group, being closely monitored by the competent supervisory authorities. Enhanced strategy on NPE management accompanied by specific KPIs, an improving legal framework, along with the already established infrastructure for the Bank (Special Asset Unit and Retail Collections Unit) is expected to gradually improve the key metrics relating to the domestic asset quality.

Furthermore, the Bank has designed and implemented a number of products and solutions designed to facilitate customer payment, even for the most troubled (yet cooperative) customers it is the Bank's intention to constantly update its debt restructuring solutions so that it is able to offer realistic and targeted solutions.

Following completion of the recapitalization in December 2015, the HFSF owns 40.4% of the Bank's common share capital. Also, various domestic pension funds owned in total 0.2% of the Bank's common share capital, and other domestic public sector related legal entities and the Church of Greece owned in total 0.1% of the Bank's common share capital. See Item 3.D, "Risk Factors—Risks Relating to the Hellenic Republic Economic Crisis—Recessionary pressure and uncertainty resulting from the Hellenic Republic's economic crisis have had and may continue to have an adverse impact on our business, results of operations and financial condition—Risks Relating to our Recapitalization and Receipt of State Aid", "—Risks Relating to Our Recapitalization and Receipt of State Aid—The HFSF, as shareholder, has certain rights in relation to the operation of the Bank" and "—The HFSF and the Hellenic Republic have and will continue to have the ability to exercise significant influence over our operations" and Item 7.A, "Major Shareholders".

As a result of the Bank's participation in the Hellenic Republic's Bank Support Plan, a Hellenic Republic representative participates as a member in the Bank's Board of Directors, having the rights of Greek Law 3723/2008 and, among others, veto power on any decision of a strategic nature, or materially affecting the Bank's legal or financial status and requiring General Meeting of the Shareholders' approval, or related to dividend distribution and to the compensation of the Bank's Chairman, the Chief Executive Officer and the other Board of Directors members as well as the General Managers and the Deputy General Managers, or any decision that may put depositors' interests at risk or materially affect the Bank's credit standing and smooth operation. For a description of the Bank's dividend policy please refer to Item 8, "Financial Information". 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".

For powers vested in the HFSF as it participates our Bank, please also see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Financial Stability Fund".

The Hellenic Republic, including state-related entities, is a large customer of the Bank in terms of loans and deposits. At December 31, 2015, 11.1% of the Bank's outstanding loans were to the Hellenic Republic and state-related entities, and 4.9% 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 Bank'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 "—Regulation and Supervision of Banks in Greece".

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, 2015.

Primary Operating Area	Country of incorporation

Corporate & Investment Banking
Ethniki Leasing S.A.	Greece	100.00	%	—		100.00	%
Ethniki Factors S.A.	Greece	100.00	%	—		100.00	%
Probank Leasing S.A.	Greece	84.52	%	0.19	%	84.71	%
Titlos Plc⁽¹⁾	UK	—		—		—
Retail Banking
Revolver APC Limited^(1),⁽²⁾	UK	—		—		—
Revolver 2008-1 PLC^(1),⁽²⁾	UK	—		—		—
Spiti PLC⁽¹⁾	UK	—		—		—
Autokinito PLC⁽¹⁾	UK	—		—		—
Agorazo PLC⁽¹⁾	UK	—		—		—
Turkish Operations
Finansbank A.S.	Turkey	82.23	%	17.58	%	99.81	%
Finans Leasing A.S.	Turkey	29.87	%	68.91	%	98.78	%
Finans Invest A.S.	Turkey	0.20	%	99.61	%	99.81	%
Finans Portfolio Management A.S.	Turkey	0.02	%	99.79	%	99.81	%
IB Tech A.S.	Turkey	—		99.81	%	99.81	%
Finans Factoring A.S.	Turkey	—		99.81	%	99.81	%
E-Finans Elektronik Ticaret Ve Bilisim Hizmetleri A.S.	Turkey	—		50.90	%	50.90	%
PSA Finansman A.Ş.	Turkey	—		99.81	%	99.81	%
International
The South African Bank of Athens Ltd	South Africa	76.21	%	23.58	%	99.79	%
National Bank of Greece (Cyprus) Ltd.	Cyprus	100.00	%	—		100.00	%
National Securities Co (Cyprus) Ltd⁽²⁾	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	%

Primary Operating Area	Country of incorporation

Hotel Perun—Bansko EOOD	Bulgaria	—		100.00	%	100.00	%
Banca Romaneasca S.A.	Romania	99.28	%	—		99.28	%
NBG Leasing IFN S.A.	Romania	6.43	%	92.90	%	99.33	%
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	%
Banca NBG Albania Sh.a.	Albania	100.00	%	—		100.00	%
NBG (Malta) Holdings Ltd	Malta	—		100.00	%	100.00	%
NBG Bank Malta Ltd	Malta	—		100.00	%	100.00	%
Global Markets & Asset Management
NBG Securities S.A.	Greece	100.00	%	—		100.00	%
NBG Asset Management Mutual Funds S.A.	Greece	98.10	%	1.90	%	100.00	%
Probank M.F.M.C.	Greece	95.00	%	5.00	%	100.00	%
Profinance S.A.⁽²⁾	Greece	99.90	%	0.10	%	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.)⁽³⁾	Romania	73.12	%	26.88	%	100.00	%
NBG Asset Management Luxembourg S.A.	Luxemburg	94.67	%	5.33	%	100.00	%
NBGI Private Equity Funds	UK	—		100.00	%	100.00	%
Insurance
NBG Bancassurance S.A.	Greece	100.00	%	—		100.00	%
Ethniki Hellenic General Insurance S.A.	Greece	100.00	%	—		100.00	%
National Insurance Brokers S.A.	Greece	—		95.00	%	95.00	%
NBG Insurance Brokers S.A.	Greece	99.90	%	0.08	%	99.98	%
Audatex Hellas S.A.⁽²⁾	Greece	—		70.00	%	70.00	%
FB Insurance Agency Inc⁽²⁾	Greece	99.00	%	—		99.00	%
Ethniki Insurance (Cyprus) Ltd	Cyprus	—		100.00	%	100.00	%
Ethniki General Insurance (Cyprus) Ltd	Cyprus	—		100.00	%	100.00	%
National Insurance Agents & Consultants Ltd	Cyprus	—		100.00	%	100.00	%
S.C. Garanta Asigurari S.A.	Romania	—		94.96	%	94.96	%
Other
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)⁽²⁾	Greece	—		100.00	%	100.00	%
Astir Palace Vouliagmenis S.A.	Greece	85.35	%	—		85.35	%
Astir Marina 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	%
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	%
Karela S.A.	Greece	—		100.00	%	100.00	%
Nash S.r.L.	Italy	—		100.00	%	100.00	%

As at December 31, 2015, the Group owned 3,012 properties, of which 1,935 are buildings. The Group's real estate portfolio was recorded at a net book value of EUR 1,312 million as at December 31, 2015, compared to EUR 1,726 million as at December 31, 2014, which is included in the U.S. GAAP Financial Statements under "premises and equipment". These properties are, for the most part, held free of encumbrances. Most of our properties are occupied by our branches and offices and so are where 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. 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 165 million as at December 31, 2015, are included under "Other assets" in the Group's U.S. GAAP Financial Statements and are accounted for as held for sale. 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 estimates that the book value of its property approximates its fair value. For any new property acquired from foreclosure procedure, the Group performs valuations by applying internationally recognized valuation methodologies (valuation reports are conducted in accordance with the European Valuation Standards (EVS 2012), as defined by TEGoVA and International Valuation Standards (IVS 2013) as defined by IVSC). The valuations are performed either internally by qualified appraisers or externally by international certified valuation companies or qualified appraisers certified by TEGoVA and /or RICS. Additionally, valuations are back tested for outliers through a standardized statistical process. The validity of the valuation report is generally the twelve months period from its completion date under normal market conditions. In exceptional cases, due to adverse economic conditions, the assets' revaluation can be conducted in less than twelve months period. 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. 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 excluding discontinued operations only. The comparative figures were restated to exclude discontinued operations. 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, 2013, 2014 and 2015, 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,

	2013								2014								2015
	Average Balance			Interest		Average Rate			Average Balance			Interest		Average Rate			Average Balance			Interest		Average Rate
	(EUR in millions, except percentages)
Domestic:
Assets:
Deposits with central bank		424			2		0	%		447			1		0	%		387			—		0	%
Interest bearing deposits with banks and securities purchased under agreements to resell and money market investments		2,052			10		0	%		2,240			4		0	%		1,958			1		0	%
Trading, available for sale and held to maturity securities⁽¹⁾		5,497			300		5	%		4,041			253		6	%		3,771			206		5	%
Loans and other interest earning assets⁽²⁾		48,675			1,869		4	%		48,414			1,725		4	%		48,617			1,524		3	%
Less: Allowance for loan losses		(5,789	)		—		—			(6,781	)		—		—			(9,406	)		—		—
Net loans		42,886			—		—			41,633			—		—			39,211			—		—

Total interest earning assets		50,859			2,181		4	%		48,361			1,983		4	%		45,327			1,731		4	%
Total non interest earning assets		12,426								10,977								11,650

Total assets		63,285								59,338								56,977



Liabilities:
Total deposits		68,105			968		1	%		58,741			663		1	%		60,979			539		1	%
Securities sold under agreements to repurchase		1,012			15		1	%		1,534			15		1	%		46			1		2	%
Long term debt, other borrowed funds and other interest bearing liabilities		48			3		6	%		55			3		5	%		425			30		7	%

Total interest bearing liabilities		69,165			986		1	%		60,330			681		1	%		61,450			570		1	%
Total non interest bearing liabilities		8,287								9,055								9,781

Total Liabilities		77,452								69,385								71,231

	Year ended December 31,

	2013								2014								2015
	Average Balance			Interest		Average Rate			Average Balance			Interest		Average Rate			Average Balance			Interest		Average Rate
	(EUR in millions, except percentages)
Foreign:
Assets:
Deposits with central bank		695			4		1	%		532			1		0	%		587			2		0	%
Interest bearing deposits with banks and securities purchased under agreements to resell and money market investments		1,161			10		1	%		1,351			7		1	%		511			7		1	%
Trading, available for sale and held to maturity securities⁽¹⁾		7,738			116		1	%		11,384			118		1	%		11,877			87		1	%
Loans and other interest earning assets⁽²⁾		9,202			513		6	%		7,482			470		6	%		8,081			429		5	%
Less: Allowance for loan losses		(437	)		—		—			(569	)		—		0	%		(796	)		—		—
Net loans		8,765			—		—			6,913			—		0	%		7,285			—		—

Total interest earning assets		18,359			643		4	%		20,180			596		3	%		20,260			525		3	%
Total non interest earning assets		1,259								3,913								2,685

Total assets		19,618								24,093								22,945



Liabilities:
Total deposits		8,949			251		3	%		10,955			194		2	%		6,998			106		2	%
Securities sold under agreements to repurchase		619			3		0	%		2,449			6		0	%		364			1		0	%
Long term debt, other borrowed funds and other interest bearing liabilities		625			22		4	%		1,910			98		5	%		1,069			83		8	%

Total interest bearing liabilities		10,193			276		3	%		15,314			298		2	%		8,431			190		2	%
Total non interest bearing liabilities		800								547								548

		10,993								15,861								8,979

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,

	2014 vs. 2013									2014 vs. 2013
	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 millions, except percentages)
	Domestic:									Foreign:
ASSETS
Deposits with central bank		(1	)		—			(1	)		(1	)		(1	)		—
Interest bearing deposits with banks, securities purchased under agreements to resell		(6	)		1			(7	)		(4	)		2			(6	)
Trading, available for sale and held to maturity securities		(47	)		(79	)		32			2			55			(53	)
Loans		(144	)		(10	)		(134	)		(42	)		(96	)		54

Total Assets		(198	)		(88	)		(110	)		(45	)		(40	)		(5	)
LIABILITIES
Total deposits		(305	)		(133	)		(172	)		(58	)		56			(114	)
Securities sold under agreements to repurchase		—			8			(8	)		3			11			(8	)
Long term debt and other borrowed funds		(7	)		1			(8	)		84			30			54

Total Liabilities		(312	)		(124	)		(188	)		29			97			(68	)

	Year ended December 31,

	2015 vs. 2014									2015 vs. 2014
	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 millions)
	Domestic:									Foreign:
ASSETS
Deposits with central bank		(1	)		—			(1	)		(1	)		—			(1	)
Interest bearing deposits with banks, securities purchased under agreements to resell and money market investments		(3	)		—			(3	)		5			(3	)		8
Trading, available for sale and held to maturity securities		(47	)		(17	)		(30	)		(31	)		5			(36	)
Loans		(201	)		7			(208	)		(46	)		37			(83	)

Total Assets		(252	)		(10	)		(242	)		(73	)		39			(112	)
LIABILITIES
Total deposits		(124	)		25			(149	)		(88	)		(70	)		(18	)
Securities sold under agreements to repurchase		(13	)		(14	)		1			(5	)		(5	)		—
Long term debt and other borrowed funds		20			68			(48	)		(9	)		(41	)		32

Total Liabilities		(117	)		79			(196	)		(102	)		(116	)		14

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,

	2013			2014			2015
	(EUR in millions, except percentages)
Domestic:
Average interest earning assets		50,859			48,361			45,327
Total interest income		2,181			1,983			1,731
Average interest bearing liabilities		69,165			60,330			61,450
Total interest expense		986			681			570
Net interest income		1,195			1,302			1,161
Net interest margin⁽¹⁾		2.3	%		2.7	%		2.6	%
Foreign:
Average interest earning assets		18,359			20,180			20,260
Total interest income		643			596			525
Average interest bearing liabilities		10,193			15,314			8,431
Total interest expense		276			298			190
Net interest income		367			298			335
Net interest margin⁽¹⁾		2.0	%		1.5	%		1.7	%

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

	Year ended December 31,

	2013			2014			2015
	(EUR in millions, except percentages)
Net interest income before provision for loan losses		1,562			1,600			1,496
Net income / (loss) from continuing operations		(579	)		(2,642	)		(3,344	)
Net income / (loss) from continuing operations attributable to NBG shareholders		(611	)		(2,646	)		(3,341	)
Average total assets		82,903			83,431			79,922
Average NBG shareholders' equity⁽¹⁾		(1,888	)		2,363			(982	)
Net interest income before provision for loan losses as a percentage of:
Average total assets		1.9	%		1.9	%		1.9	%
Average NBG shareholders' equity⁽¹⁾		—			68	%		—
Net income / (loss) as a percentage of:
Average total assets		(0.70	)%		(3.17	)%		(4.18	)%
Net income / (loss) attributable to NBG shareholders as a percentage of:
Average NBG shareholders' equity⁽¹⁾		—			(111.98	)%		—
Average NBG shareholders' equity to average total assets⁽²⁾		—			2.83	%		—

On December 31, 2015, the Group's securities had a carrying value of EUR 18.0 billion, representing 23.9% of the Group's total assets excluding long-lived assets classified as held for sale and sovereign securities held accounted for EUR 17.1 billion, or 94.9% of the Group's securities portfolio excluding long-lived assets classified as held for sale. 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, available for sale ("AFS") and held to maturity ("HTM").

The market and book value of Greek government bonds and treasury bills held by the Group (which includes securities held in our trading, AFS and HTM portfolios) on December 31, 2015 was EUR 3.3 billion and EUR 3.2 billion respectively. The book value of Greek government bonds represents 4.3% of the Group's total assets excluding long-lived assets classified as held for sale.

Furthermore, on December 31, 2015, the Group held debt securities rated Aaa to A3 (or equivalent), issued by Germany, the EFSF, ESM and the EIB (classified as trading, AFS and HTM) with a market and book value of EUR 12.3 billion.

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, 2013, 2014 and 2015:

	Year ended December 31,

	2013				2014				2015
	Amortized Cost		Fair Value		Amortized Cost		Fair Value		Amortized Cost		Fair Value
	(EUR in millions)
Trading Account Securities
Debt securities issued by other governments and public sector entities		388		390		347		352		384		389
Greek treasury bills		2,083		2,086		1,803		1,799		1,859		1,858
Foreign treasury bills		127		126		133		133		84		85
Debt securities issued by companies incorporated in Greece		19		20		33		32		39		38
Debt securities issued by companies incorporated outside Greece		381		349		73		60		111		95
Equity securities issued by companies incorporated in Greece		56		26		4		2		1		6
Equity securities issued by foreign companies		75		5		2		5		2		5
Mutual funds		4		6		3		3		5		8

Total		3,133		3,008		2,398		2,386		2,485		2,484

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, 2013, 2014 and 2015:

	Year ended December 31,

	2013									2014									2015
	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 millions)
Available-for-sale securities
Greek government bonds		1,843		120		—			1,963		802		46		(111	)		737		746		92		(6	)		832
Debt securities issued by other governments and public sector entities		746		18		–1			763		1,090		66		(1	)		1,155		3,867		71		(7	)		3,931
Greek treasury bills		156		—		—			157		169		—		—			169		471		—		(1	)		470
Foreign treasury bills		339		—		—			339		270		—		(1	)		269		229		—		—			229
Debt securities issued by companies incorporated in Greece		416		27		–34			409		398		31		(27	)		402		143		1		(5	)		139
Debt securities issued by companies incorporated outside Greece		461		18		–20			458		319		15		(12	)		322		219		11		(7	)		223
Equity securities issued by companies incorporated in Greece		73		35		–1			107		35		9		(3	)		41		57		8		(5	)		60
Equity securities issued by companies incorporated outside Greece		9		10		—			20		8		11		—			19		8		48		—			56
Mutual fund units		232		32		–1			263		205		5		(5	)		205		280		10		(3	)		287

Total available-for-sale securities		4,275		260		(57	)		4,479		3,296		183		(160	)		3,319		6,020		241		(34	)		6,227



Held-to-maturity securities
Greek government bonds		67		65		—			132		73		55		—			128		78		69		—			147
Debt securities issued by other governments and public sector entities		9,199		97		—			9,296		9,165		206		—			9,371		9,130		235		—			9,365
Foreign treasury bills		110		—		—			110		99		—		—			99		84		—		—			84

Total held-to-maturity securities		9,376		162		—			9,538		9,337		261		—			9,598		9,292		304		—			9,596

As at December 31, 2014 and 2015, the Group did not hold any U.S. federal debt securities.

	Year ended December 31, 2015

	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 millions, except percentages)
Trading account debt securities:
Debt securities issued by other governments and public sector entities		2		1	%		2		164		2	%		167		207		2	%		210		11			5	%		10
Greek treasury bills		1,859		3	%		1,858		—		0	%		—		—		0	%		—		—			0	%		—
Foreign treasury bills		84		0	%		85		—		0	%		—		—		0	%		—		—			0	%		—
Debt securities issued by foreign financial institutions		56		3	%		57		33		4	%		18		—		0	%		—		—			0	%		—
Debt securities issued by companies incorporated in Greece		17		4	%		17		23		4	%		21		—		0	%		—		—			0	%		—
Debt securities issued by companies incorporated outside Greece		18		3	%		18		2		0	%		1		—		0	%		—		1			0	%		1

Total trading account debt securities		2,036		3	%		2,037		222		2	%		207		207		2	%		210		12			4	%		11



Available-for-sale debt securities:
Greek government and agencies		—		0	%		—		442		7	%		440		31		8	%		31		273			7	%		361
Debt securities issued by other governments and public sector entities		106		3	%		107		3,209		0	%		3,225		281		4	%		302		272			3	%		297
Greek treasury bills		471		2	%		470		—		0	%		—		—		0	%		—		—			0	%		—
Foreign treasury bills		228		3	%		229		—		0	%		—		—		0	%		—		—			0	%		—
Corporate debt securities issued by companies incorporated in Greece		35		10	%		34		108		5	%		105		—		0	%		—		—			0	%		—
Debt securities issued by companies incorporated outside Greece		11		0	%		11		82		2	%		84		86		1	%		94		40			3	%		34

Total available-for-sale debt securities		851		3	%		851		3,841		1	%		3,854		398		4	%		427		585			5	%		692



Held-to-maturity securities:
Greek government and agencies		—		0	%		—		—		0	%		—		13		17	%		25		65			14	%		122
Debt securities issued by other governments and public sector entities		—		0	%		—		4,539		1	%		4,593		4,591		1	%		4,771		(1	)		0	%		—
Foreign treasury bills		85		1	%		85		—		0	%		—		—		0	%		—		—			0	%		—

Total held-to-maturity debt securities		85		1	%		85		4,539		1	%		4,593		4,604		1	%		4,796		64			14	%		122

As at December 31, 2015, the amount of the Group's total net loans equaled EUR 43.2 billion. The Group's loan portfolio consists of 45.6% consumer and 54.4% commercial loans (see Note 13 to the U.S. GAAP Financial Statements). As at December 31, 2015, loans to Greek residents represent 86.3% 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, 2011, 2012, 2013, 2014 and 2015.

	Year ended December 31,

	2011			2012			2013			2014			2015
	(EUR in millions)
Greek residents:
*Consumer:*
Residential mortgages		18,763			17,985			17,720			17,458			16,664
Credit card		1,527			1,459			1,381			1,317			1,244
Auto financing		309			209			138			88			64
Other consumer		4,763			4,709			4,694			4,207			4,095

Total		25,362			24,362			23,933			23,070			22,067

*Commercial:*
Industry and mining		4,084			5,132			4,725			5,217			5,564
Small-scale industry		1,962			1,779			2,123			1,929			1,765
Trade		7,375			7,038			7,562			7,425			7,559
Construction		1,132			987			1,082			1,098			1,061
Tourism		480			454			612			607			451
Shipping and transportation		2,217			2,182			2,174			2,437			2,556
Commercial mortgage		775			664			579			529			759
Public sector		8,711			5,608			5,848			5,390			5,218
Other		88			112			655			600			574

Total		26,824			23,956			25,360			25,232			25,507

Total Greek residents loans		52,186			48,318			49,293			48,302			47,574
Unearned income		(93	)		(53	)		(48	)		(67	)		(80	)

Total Greek residents loans net of unearned income		52,093			48,265			49,245			48,235			47,494

The Bank has on its balance sheet under the line item "Commercial loans—Public sector" an amortizing loan with a fixed rate interest and a final maturity in September 2037. This loan relates to an agreement with the Hellenic Republic the Bank entered into in August 2005, relating to a hybrid financial instrument consisting of a loan issued at a cost of EUR 5.1 billion with an embedded derivative. The embedded derivative would normally have to be bifurcated, but, instead, the Group elected to account for the combined instrument at fair value under applicable guidance. On December 30, 2008 that instrument was settled and a new loan was recognized at a fair value of EUR 5.4 billion. The carrying amount of this loan, net of allowance for loan losses, as at December 31,

2015, was EUR 4.7 billion. The agreement with the Hellenic Republic relating to this loan also includes an embedded derivative that has been bifurcated and accounted for as a separate derivative.

	Year ended December 31,

	2011			2012			2013			2014			2015
	(EUR in millions)
Foreign:
*Consumer:*
Residential mortgages		1,717			1,674			1,661			1,631			1,593
Credit card		155			160			159			162			157
Auto financing		69			52			29			23			21
Other consumer		1,358			1,281			1,264			1,299			1,309

Total		3,299			3,167			3,113			3,115			3,080

*Commercial:*
Industry and mining		1,469			1,038			793			758			783
Small-scale industry		334			341			399			377			413
Trade		1,409			1,288			1,044			1,015			927
Construction		1,244			1,246			1,276			1,079			985
Tourism		158			135			142			128			144
Shipping and transportation		447			415			348			312			270
Commercial mortgage		573			517			263			228			212
Public sector		226			185			202			174			106
Other		1,494			1,209			857			665			601

Total		7,354			6,374			5,324			4,736			4,441

Total foreign loans		10,653			9,541			8,437			7,851			7,521
Unearned income		(65	)		(46	)		(20	)		(18	)		(19	)

Total foreign loans net of unearned income		10,588			9,495			8,417			7,833			7,502
Total loans net of unearned income		62,681			57,760			57,663			56,068			54,996

Less: Allowance for loan losses		(6,105	)		(6,650	)		(7,137	)		(8,792	)		(11,775	)

Total net loans		56,576			51,110			50,526			47,276			43,221

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 variable 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 "—Credit Quality and Risk Management—Credit Quality—Risk Management—Loan Approval Process". Greek government-subsidized mortgage loans were 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.

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 and other governments, public utilities and entities governed by the public law of Greece or other governments.

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, 2015.

	Year ended December 31, 2015

	Within one year or less			After one year through five years			After five years			Total
	(EUR in millions)
Greek Residents:
*Consumer:*
Residential mortgages		5,830			2,088			8,746			16,664
Credit card		1,244			—			—			1,244
Auto financing		44			19			1			64
Other consumer		2,893			795			407			4,095

Total		10,011			2,902			9,154			22,067

*Commercial:*
Industry and mining		2,950			1,603			1,011			5,564
Small-scale industry		986			495			284			1,765
Trade		4,325			2,029			1,205			7,559
Construction		778			165			118			1,061
Tourism		372			34			45			451
Shipping and transportation		1,248			837			471			2,556
Commercial mortgages		439			202			118			759
Public sector		439			806			3,973			5,218
Other		309			157			108			574

Total		11,846			6,328			7,333			25,507

Total Greek residents loans		21,857			9,230			16,487			47,574

Foreign:
*Consumer:*
Residential mortgages		111			74			1,408			1,593
Credit card		81			5			71			157
Auto financing		11			9			1			21
Other consumer		316			410			583			1,309

Total		519			498			2,063			3,080

*Commercial:*
Industry and mining		349			199			235			783
Small-scale industry		233			72			108			413
Trade		386			257			284			927
Construction		248			375			362			985
Tourism		44			50			50			144
Shipping and transportation		136			88			46			270
Commercial mortgages		108			38			66			212
Public sector		1			9			96			106
Other		168			153			280			601

Total		1,673			1,241			1,527			4,441

Total foreign loans		2,192			1,739			3,590			7,521
Unearned income		(22	)		(51	)		(26	)		(99	)

Loans, net of unearned income		24,027			10,918			20,051			54,996
Less: Allowance for loan losses		(11,775	)		—			—			(11,775	)

Total net loans		12,252			10,918			20,051			43,221

Out of the Group's loans outstanding at December 31, 2015 that are due after one year, EUR 5.5 billion had fixed interest rates while EUR 24.9 billion had variable 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 years ended December 31, 2013, 2014 and for the year ended December 31, 2015 was to Bulgaria, Romania, FYROM and Serbia. These foreign country outstandings represent additional economic and political risks. For additional information, 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, 2013, 2014 and 2015, in each foreign country where such outstanding amounts exceeded 1% of the Group's total assets excluding long-lived assets classified as held for sale.

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 excluding long-lived assets classified as held for sale at December 31, 2013, 2014 and 2015.

	Year ended December 31, 2013

	Country
	Bulgaria		Romania		Serbia		FYROM
	(EUR in millions)
Consumer:
Residential mortgages		588		608		112		132
Credit card		85		8		10		53
Auto financing		16		—		—		9
Other consumer		458		297		134		321

Total		1,147		913		256		515

Commercial:
Industry and mining		265		116		2		144
Small-scale industry		253		9		81		—
Trade		413		126		108		91
Construction		314		323		45		31
Tourism		54		42		5		11
Shipping and transportation		79		29		61		13
Mortgages		18		144		—		—
Public sector		14		—		71		—
Other		287		19		69		72

Total		1,697		808		442		362

Total loans		2,844		1,721		698		877

	Year ended December 31, 2014

	Country
	Bulgaria		Romania		Serbia		FYROM
	(EUR in millions)
Consumer:
Residential mortgages		551		612		110		140
Credit card		81		8		9		59
Auto financing		14		—		—		5
Other consumer		447		276		160		350

Total		1,093		896		279		554

Commercial:
Industry and mining		281		114		3		156
Small-scale industry		253		6		70		—
Trade		399		91		137		98
Construction		360		279		23		28
Tourism		44		39		8		10
Shipping and transportation		74		22		48		16
Mortgages		—		139		1		—
Public sector		14		—		56		—
Other		280		18		84		74

Total		1,705		708		430		382

Total loans		2,798		1,604		709		936

	Year ended December 31, 2015

	Country
	Bulgaria		Romania		Serbia		FYROM
	(EUR in millions)
Consumer:
Residential mortgages		500		628		112		143
Credit card		73		8		8		64
Auto financing		15		—		—		3
Other consumer		410		263		173		385

Total		998		899		293		595

Commercial:
Industry and mining		273		87		72		157
Small-scale industry		251		15		97		—
Trade		278		92		127		112
Construction		319		252		27		30
Tourism		74		29		4		15
Shipping and transportation		72		17		20		19
Mortgages		—		140		—		—
Public sector		10		2		—		—
Other		292		10		97		75

Total		1,569		644		444		408

Total loans		2,567		1,543		737		1,003

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 loan approval process across our banking subsidiaries (UBB, Banca Romaneasca, Vojvodjanska, Stopanska Banka, NBG Cyprus, NBG Albania and SABA) is substantially similar, differing primarily in the thresholds applied for different approval levels. Approval levels are driven by local regulations as well as adjustments to reflect the size of our operations in a given subsidiary and material exposures will require approval by NBG's Senior Credit Committee, NBG's International Corporate Credit Committee and/or the NBG International Credit Division.

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 including those handled by the SAU, established in 2014. The SAU has incorporated previous Work-out and NPL divisions and is responsible for handling the part of the portfolio which requires special treatment (less strong credit standing, in need of restructuring, non performing etc.). 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 exposures are rated through the Moody's Risk Analyst™ platform. The platform comprises four rating models for companies, according to the existence of full financial statements by the firm and to the specificity of the obligor's business. More than 70% 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 Group Risk Control and Architecture Division ("GRCAD"). The rest of corporate exposures are assessed 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 and financially weaker 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 require compliance with selected financial ratios and undertakings and we also obtain security depending on their credit standing and debt repayment capacity.

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 Officer. Different Credit committees and credit approval authorities apply to Corporate Portfolio.

According to the Corporate Credit Policy (revised as of March 2016), for the Corporate Portfolio, apart from the SAU, there are 11 levels of credit approval authority as follows:

The Bank offers a full range of retail credit products ranging from credit cards to SME financing. Retail Banking is organized into three sub-divisions: Household Lending (Mortgage and Consumer loans), 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 Risk Management 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. The Group Retail Credit Risk Division monitors and reviews the Retail Credit Policies, the Product Programs and the approved Policy amendments. In addition the Division cooperates closely with the Retail Banking Collection Division for the correct application of regulatory and legal adjustments (including Law 4224/2013 and Bank of Greece Executive Committee Directive #42).

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). The risk profile of each loan is assessed first at origination, using product-specific application scorecards and then is monitored throughout its life, using bespoke behavioral scorecards. These models allow the Bank to internally estimate key credit risk parameters, such as probabilities of default and loss given default for major retail portfolios. The aforementioned behavioral scores are combined to produce a bank rating, taking into account the customer's behavior across retail products.

Apart from the application score, the Bank has 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-eyes principle is implemented throughout the underwriting process. In addition, periodic post approval reviews are conducted to ensure quality and completeness.

Finally, the development of portfolio models allows 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—Asset/Liability, Internal Audit and Risk Management—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 residential 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 Bank has gradually increased the rejection score since February 2010. In addition, customer own funding, 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. Since 2010, the Bank gradually decreased maximum PTI which currently stands at the level of 35% for property acquisition and 30% for repairs and improvements.

Generally, approval LTV cannot exceed 75%. Average LTV of residential mortgage loans originated in 2015 stood at 55.8%, in 2014 at 53.8% while in 2013 at 54.5%. As at December 2015, average current LTV of the total Greek mortgage portfolio was 94.2%.

Although the Bank has applied the abovementioned stringent underwriting criteria in recent years, customers' behavior matures in the environment developed by the 2008 crisis, leading to an improvement in the quality of applications and an increase in the Bank's approval rate for mortgage lending, from 49% in 2013, to 63% in 2014 and 75% in 2015. Customers have become conscious of the reduced availability of funding across banks and are willing to comply with additional terms placed by the underwriting teams in order to obtain funding. At the same time Bank's network service toward customers has been improved leading to more efficient applications. 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. 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 to both owner-occupiers and investors with variable, fixed, or a combination of fixed and variable interest rates, secured by a mortgage over the subject property or other acceptable collateral. Variable 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 (15 years in case of repairs or improvements), subject to an individual's age. 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. The Bank abstains from this type of market and focuses only to prime mortgages.

As at December 31, 2015, 9.3% of the Bank's mortgage portfolio in terms of balances 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 mortgage loans subsidized by the Hellenic Republic. The subsidies are available solely for mortgages extended to fund the purchase or construction of the borrower's primary residence. These subsidized mortgages are offered only in Greece, and are therefore not offered by any of our banking subsidiaries operating outside the Hellenic Republic.

The subsidy is calculated as a percentage on the loan's interest rate and is offered to the borrower for half of the loan's contractual life with a maximum of eight to ten years, depending on the relevant ministerial decisions of the Hellenic Republic. 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.

The housing program subsidized by Greek Worker Housing Association ("OEK") has been discontinued since mid-2010. The subsidy was calculated as a percentage of the loan's interest rate and depended on the borrower's family status and was offered for nine years. The underwriting procedure was the one followed for a "typical" mortgage loan with the exception that the applicant had to submit to the Bank a certificate from OEK, that verified his/her eligibility as well as the property evaluation conducted by OEK. Under Law 4305/2014, borrowers facing financial difficulties are offered the possibility of term extension, without any increase in the amount of subsidy.

As at December 31, 2015, the total amount of mortgage loans subsidized by the Hellenic Republic or OEK amounted to EUR 475 million, from EUR 709 million in December 2014 and EUR 1,062 million in December 2013. As at December 31, 2015 subsidized loans that are over 90dpd in principal or interest amount decreased to EUR 27 million, from EUR 48 million in 2014 and EUR 74 million in 2013.

Mortgage loans guaranteed by the Hellenic Republic consist of 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 principal and interest of these loans. Loan applications do not follow the Bank's origination process. Instead, all documentation as well as loan application is submitted to the relevant public authority for approval. The maximum amount per loan is EUR 60,000 with the exception of loans to victims of natural disasters where loan amount is determined by the public authority, in accordance with guidelines set by Greek legislation. These guaranteed mortgage loans are offered only in Greece, and are therefore not offered by any of our banking subsidiaries operating outside the Hellenic Republic.

As at December 31, 2015, the total amount of mortgage loans guaranteed by the Hellenic Republic amounted to EUR 1,072 million, from EUR 1,156 million in December 2014 and EUR 1,232 million, in December 2013. As at December 31, 2015, guaranteed loans that are over 90 days past due in principal or interest amount to EUR 68 million, compared to EUR 65 million in 2014 and EUR 47 million in 2013. 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.

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 frequencies. Consumer loans are generally not collateralized, with the exception of car loans.

The SBL Unit is organized into three small business credit centers in Athens, Thessaloniki and Patras. This geographical segmentation has been implemented in order to optimize administration procedures and maximize SBL portfolio management efficiency. The credit centers handle all of the Bank's credit applications from entrepreneurs or small businesses in their respective area of responsibility.

The credit centers are staffed by lending teams under the supervision of a Team Leader, who in turn report to the Credit Center Head. Credit underwriters use an internal risk rating system to assist in their credit decisions when reviewing and making credit decisions on applications forwarded by branches. The input parameters are validated and calibrated in alignment with the macroeconomic environment. The model improves the quality of decision-making and reduces the time required for the credit evaluation process. In addition, an, internally developed, behavioral scoring model is embedded into the SME risk rating system in order to continually assess repayment behavior and performance and further enhance the quality of credit decisions regarding to the existing portfolio.

There are four credit approval authority levels applicable to SBL lending. However, SBL credit exposures above EUR 1.5 million and up to EUR 3 million must also be approved by the Group Retail Credit Manager and the SBL's Head while SBL credit exposures in excess of EUR 3 million have to be approved jointly by the Group Credit Risk Officer and the General Manager of Retail Banking.

In September 2014, and in accordance with Greek Law 4224/2013 and Bank of Greece Executive Committee Directive #42 and #47, the Bank put into effect the SBL Special Asset Division, which is responsible for the management of troubled SBL exposures. The SBL Special Asset Division operates independently from the SBL Unit under a specific Credit Policy Manual and Executive Directives and with distinct credit authority levels management structure and reporting lines.

The SBL Special Asset Division can offer a range of short, medium and long term solutions (including rescheduling, restructuring, etc) as well as solutions aiming at definitive resolution of troubled loan assets. The overall framework is outlined in the respective Credit Policy manual which is in line with the provisions of Greek Law 4224/2013 and Bank of Greece Executive Committee Directives 42 and 47.

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.

The average current LTV of the Bank's mortgage portfolio at December 31, 2015 was 94.2%, up from 85.7% at December 31, 2014 and 74.7% at December 31, 2013, mainly due to the steep fall in property prices (–41.2% during the period 2008 - 2015). The possibility in the future of foreclosure actions in combination with the notion of "cooperative borrower" introduced by the Code of Conduct adopted by Greek Law 4224/2013, as well as the amendments defined in the Greek Law 4335/2015 concerning foreclosures and auction procedures are expected to deter customers from missing payments. 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 value of collateral.

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.

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.

The NBG Group has implemented a systematic control and monitoring framework for credit risk whereby the Bank and each of its subsidiaries conduct the credit risk process separately. Credit risk policies are established at the level of the NBG Group and are applied by each banking subsidiary, subject to adjustments as may be required by national banking regulators. The GRCAD along with the NBG International Credit Division 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—Risk Management Governance".

The Credit Policy determines the contents of credit proposals for the Corporate Banking Portfolio, which are evaluated at least annually depending on the classification of the obligor and on 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 21-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. The Group fully complies with Basel II Internal Ratings Based methods, hence corporate borrower ratings are mapped to probabilities of default in order to estimate 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 concentration 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 SAU Division is responsible for monitoring and managing (restructuring and collection) corporate portfolios of non-performing and denounced customers. For further information, see Item 4.B "Business Overview—Banking Activities in Greece—Special Assets Unit".

The Bank has completed its estimation of key credit risk measurement variables, including probability of default and loss given default for all retail portfolios. Hence, expected loss is internally estimated for all of 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.

Furthermore, the Retail Banking Collection Division is responsible for implementing and monitoring the correct application of the provisions as outlined in Greek Law 4224/2013 and Bank of Greece Executive Committee Directive #42 and #47. In this context, short, medium and long term solutions have been developed as well as solutions aiming at definitive resolution of troubled loan

assets. The overall framework is comprehensively outlined in relative specific product programs (which include decision-tree approaches) and executive directives.

The Group Retail Credit Risk Division monitors the correct implementation and review of the Retail Credit Policies, the Product Programs and the approved Policy Amendments. In addition the Division cooperates closely with the Retail Banking Collection Division for the correct application of regulatory and legal adjustments (including Greek Law 4224/2013 and Bank of Greece Executive Committee Directive #42 and #47).

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 mortgage loans are placed on non-accrual status at the time the loan is 180 days delinquent. In addition, 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. 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 21,852 million as at December 31, 2015 compared to EUR 18,831 million as at December 31, 2014. This corresponds to 39.7% of the Group's loans outstanding at the same date. Of the Group's non-accruing loans, EUR 20,381 million or 93.3% were held by the Bank. This amount represented 42.2% 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 divisions responsible for the collection of non-accruing loans in coordination with Corporate and Retail Banking.

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 "—Credit Quality and Risk Management—Credit Quality—Risk Management—Credit Review Policies".

For International entities, the accrual of interest is typically discontinued at the time the loan is 90 days delinquent. In addition, 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. 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 and Risk Management—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, 2011, 2012, 2013, 2014 and 2015:

	Year ended December 31,

	2011		2012		2013		2014		2015
	(EUR in millions)
Domestic loans:
Accruing loans:
Past due 90 days–180 days		668		639		436		306		243
Past due 180 days–365 days		102		191		146		—		—

Total accruing loans		770		830		582		306		243

Non-accruing loans:
Past due 0 days–90 days		1,807		2,159		3,447		2,865		4,830
Past due 90 days–180 days		881		1,007		925		479		893
Past due 180 days–365 days		1,455		1,946		1,397		986		1,172
Past due 365 days or more		4,581		7,619		10,123		12,275		12,752

Total non-accruing loans		8,724		12,731		15,892		16,605		19,647



Foreign loans:
Accruing loans:
Past due 90 days–180 days		67		23		8		2		—
Past due 180 days–365 days		91		182		—		—		2

Total accruing loans		158		205		8		2		2



Non-accruing loans:
Past due 0 days–90 days		805		182		279		306		435
Past due 90 days–180 days		150		181		158		69		48
Past due 180 days–365 days		278		160		177		363		104
Past due 365 days or more		1,136		1,435		1,631		1,488		1,618

Total non-accruing loans		2,369		1,958		2,245		2,226		2,205

Non-accruing loans amounted to EUR 21,852 million as at December 31, 2015 compared to EUR 18,831 million and EUR 18,137 million as at December 31, 2014 and 2013, respectively. Total non-accruing loans increased by 23.5%, 3.8% and 16.0% between 2012 and 2013, 2013 and 2014, and 2014 and 2015, respectively with the majority of the increase due to domestic non-accruing loans both in 2013, 2014, and 2015. The increase is due to the deterioration of the quality of our portfolio due to the worse than anticipated trend in the Greek economy and the increased political uncertainty.

For the year ended December 31, 2014 and 2015, the amount of loans that have been modified in the past and were removed from non-accruing status and returned to accruing status amounted to EUR 134 million and EUR 247 million, respectively.

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, 2012, 2013 and 2014 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 customer'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 customer.

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 discounted using the original effective interest rate of the loan considering all available evidence at the time of the assessment.

Modified loans that are not TDRs are assessed similarly to non-modified loans when determining the amount of the allowance for loan loss through homogenous assessment based on credit risk parameters depending on the allowance for loan loss methodology.

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 days and accruing and more than 90 days as at December 31, 2013, 2014 and 2015:

TDR loans granted during the year ended December 31, 2014 amounted to EUR 2,763 million and decreased by 21.9% compared to TDR loans granted during the year ended December 31, 2013. The decrease is due to the revision of estimates regarding the triggers used to determine whether an exposure is TDR. More specifically, the Group updated the criteria applied in order to estimate if a borrower is in financial difficulty or not, taking into consideration the credit quality indicators of its loans' portfolio i.e., the delinquency status of its consumer segment and the delinquency status and credit rating for its commercial segment.

TDR loans granted during the year ended December 31, 2015 amounted to EUR 4,041 million and increased by 46.3% compared to TDR loans granted during the year ended December 31, 2014. The significant amount of loans restructured during 2015 is a consequence of the worse than anticipated macroeconomic trend in Greek economy and the increased efforts made by the Bank to propose new and more efficient restructuring products to its customers.

Modified not TDR loans increased by 159.3% between 2013 and 2014 mainly due to the change in Group's estimate described above.

Modified not TDR loans decreased by 66.6% between 2014 and 2015 mainly due to the significant increase of TDRs mentioned above.

The Group has loan modification policies for all loans portfolios, which describe the eligible population based on certain criteria considered in determining which loans to modify and whether a given loan will subsequently re-default. The main criteria considered when modifying retail loans remain the number of days past due and the ability of the borrower to provide additional collateral. For corporate loans, in addition to the above we also consider the payment history of the borrower and the reasons for the deterioration of the borrower's financial condition. Especially for corporate loans modification programs, it is important to note that, when modifying a loan, the new terms reflect the borrower's financial condition, its ability to make future payments, the current and projected market conditions, as well as the factors discussed in Item 4.B, "Business Overview—Banking Activities in Greece—Corporate and Investment Banking". All modification programs are subject to credit committee approval and follow the lending approach described in the Credit Policies.

Modified and TDRs loans are separately monitored by dedicated teams. Special reports are produced for modified and TDR loans and in case of non-payment, they are subject to more intensive collection actions.

As at December 31, 2015, the percentage of TDRs loans granted during the last 12 months that became past due (+30 dpd) was 14.5% for consumer loan portfolio and 34.4% for commercial loan portfolio, and 6.9% and 9.6%, respectively for modified loans. As at December 31, 2014, the respective percentages were 28.2% for consumer loan portfolio and 22.2% for commercial loan portfolio, and 27.1% and 20.6%, respectively for modified loans.

As at December 31, 2014 and 2015, the percentage of modified loans which were subsequently modified again was 47.7% and 43.3%, respectively.

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, 2014 and 2015.

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, the Provision and Write-Off Committee has 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.

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 five years

after the loan agreement is legally terminated. Therefore, for this portion of past due loans a 100% loan loss allowance is recorded, which represents a full reserve. A write-off may not be made since legal actions may still be pending.

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, 2015 compared with the year ended December 31, 2014" and Item 5.A, "Operating Results—Results of Operations for the year ended December 31, 2014 compared with the year ended December 31, 2013."

The following table illustrates the activity in the loan loss allowance balance over the previous five years:

	Year ended December 31,

	2011			2012			2013			2014			2015
	(EUR in millions)
Domestic:
Balance at beginning of year		2,123			5,434			5,797			6,210			7,788
Add: Allowances for loan losses from continuing operations		3,379			1,844			541			1,696			3,158
Write-offs		(77	)		(126	)		(138	)		(107	)		(157	)
Recoveries		8			3			11			9			2

Less: Net write-offs		(69	)		(123	)		(127	)		(98	)		(155	)
Loans exchanged in the PSI					(1,357	)
Translation differences		1			(1	)		(1	)		(20	)		8

Domestic balance at end of year		5,434			5,797			6,210			7,788			10,799

Foreign:
Balance at beginning of year		537			671			852			927			1,004
Add: Allowances for loan losses from continuing operations		174			215			92			139			140
Write-offs		(47	)		(41	)		(34	)		(38	)		(169	)
Recoveries		13			10			23						7

Less: Net write-offs		(34	)		(31	)		(11	)		(38	)		(162	)
Sale of impaired loans		(0	)								(25	)
Translation differences		(5	)		(3	)		(6	)		1			(6	)

Foreign balance at end of year		671			852			927			1,004			976

Total balance at end of year		6,105			6,649			7,137			8,792			11,775

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, 2011, 2012, 2013, 2014 and 2015.

	2011				2012				2013				2014				2015

	Amount		%⁽¹⁾		Amount		%⁽¹⁾		Amount		%⁽¹⁾		Amount		%⁽¹⁾		Amount		%⁽¹⁾
	(EUR in millions, except percentages)
Greek residents:
Consumer
Residential mortgages		529		30		894		31		881		31		1,273		32		1,946		31
Credit card		416		2		536		3		640		2		667		2		689		2
Other consumer		1,010		8		1,470		8		1,803		8		1,964		7		2,252		7

Total		1,955		40		2,900		42		3,324		41		3,904		41		4,887		40

Commercial
Industry and mining		515		6		761		9		771		8		895		9		1,446		11
Small-scale industry		177		3		217		3		385		4		861		3		1,175		3
Trade		654		12		960		12		1,122		13		1,422		13		2,160		15
Construction		153		2		226		2		246		2		314		2		321		2
Tourism		39		1		60		1		41		1		76		1		60		1
Shipping and transportation		55		4		66		4		101		4		162		4		272		5
Commercial mortgages		15		1		20		1		17		1		–33		1		198		1
Public sector		1,855		14		533		10		79		10		63		10		91		9
Other		16		—		54		—		125		2		124		2		189		1

Total		3,479		43		2,897		42		2,887		45		3,884		45		5,912		48

Total Greek residents loans		5,434		83		5,797		84		6,211		86		7,788		86		10,799		88

Foreign:
Consumer
Residential mortgages		50		3		61		3		71		3		85		3		75		3
Credit card		19		—		21		—		17		—		16		—		11		—
Other consumer		166		2		178		2		189		2		196		2		166		2

Total		235		5		260		5		277		5		297		5		252		5

Commercial
Industry and mining		118		2		157		2		196		1		216		1		179		1
Small-scale industry		33		1		111		1		45		1		53		1		58		1
Trade		146		2		91		2		176		2		182		2		172		2
Construction		44		2		75		2		67		2		90		2		180		2
Tourism		11		—		49		—		14		—		16		—		28		—
Shipping and transportation		12		1		6		1		13		1		15		1		17		—
Commercial mortgages		3		1		14		1		11		—		14		—		19		—
Other		69		3		89		2		127		2		121		2		71		1

Total		436		12		592		11		649		9		707		9		724		7

Total foreign loans		671		17		852		16		926		14		1,004		14		976		12

Total Allowance for loan losses		6,105		100		6,649		100		7,137		100		8,792		100		11,775		100

An analysis of the Group's write-offs and recoveries for non-accruing loans for the years ended 2011, 2012, 2013, 2014 and 2015 is presented in the following table:

	Year ended December 31,

	2011			% of total loans		2012			% of total loans		2013			% of total loans		2014			% of total loans		2015			% of total loans
	(EUR in millions, except percentages)
Write-offs
Greek Residents:
Commercial and industrial		31			0.05		82			0.14		69			0.12		43			0.08		110			0.20
Real estate—construction		11			0.02		3			0.01		29			0.05		—			—		—			—
Real estate—mortgage		6			0.01		10			0.02		11			0.02		—			—		9			0.02
Other loans to individuals		29			0.05		31			0.05		29			0.05		64			0.11		38			0.07

Total write-offs for loans to Greek residents		77			0.13		126			0.22		138			0.24		107			0.19		157			0.29

Foreign:
Commercial and industrial		13			—		35			0.06		18			0.03		22			0.05		106			0.19
Real estate—construction		1			—		2			—		1			—		2			—		—			—
Real estate—mortgage		4			0.01		1			—		7			0.01		1			—		20			0.04
Other loans to individuals		29			0.06		3			0.01		8			0.01		13			0.02		43			0.08

Total write-offs for foreign loans		47			0.07		41			0.07		34			0.06		38			0.07		169			0.31

Total write-offs		124			0.20		167			0.29		172			0.30		145			0.26		326			0.59



Recoveries
Greek Residents:
Commercial and industrial							(1	)		—							(4	)		—					—
Other loans to individuals		(8	)		0.01		(2	)		—		(11	)		0.02		(5	)		0.02		(2	)		—

Total recovery on loans to Greek residents		(8	)		0.01		(3	)		—		(11	)		0.02		(9	)		0.02		(2	)		—

Foreign:
Commercial and industrial		(8	)		0.01		(3	)		0.01		(13	)		0.02					—					—
Other loans to individuals		(5	)		0.01		(7	)		0.01		(10	)		0.02					—		(7	)		0.01

Total recovery on foreign loans		(13	)		0.02		(10	)		0.02		(23	)		0.04					—		(7	)		0.01

Total recoveries		(21	)		0.03		(13	)		0.02		(34	)		0.06		(9	)		0.02		(9	)		0.02

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 days past due 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 2015, domestic write-offs amount to EUR 157 million compared to EUR 107 million as at December, 31 2014, 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, 2013 and 2014, unsecured consumer and credit card exposures whose agreement has been terminated for more than 3 years and SBL exposures that are fully provided for but yet not written off amounted to EUR 1,328 million and EUR 1,805 million, respectively. The write-off of these loans would result in a reduction of the allowance for loan losses on the balance sheet by EUR 1,265 million in 2013 and EUR 1,657 million in 2014, respectively. Had we written-off these loans, the non-accruing loans ratio as at December 31, 2013 and 2014 would have been 25.4% instead of 26.7% and 24.9% instead of 26.8%, respectively. Furthermore, the non-accruing loans coverage ratio as at December 31, 2013 and 2014 would have been 35.5% instead of 39.6% and 43.0% instead of 47.4%, respectively.

Turkey and the countries in SEE 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 and non-accruing loans and write-offs decreased during 2014.

In 2015, foreign write-offs amount to EUR 169 million and mainly constitute 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, 2013, 2014 and 2015:

	Year ended December 31,

	2013				2014				2015
	Average Balance		Average rate (%)		Average balance		Average rate (%)		Average balance		Average rate (%)
	(EUR in millions, except percentages)
Domestic Operations:
Deposits by Greek residents:
Demand deposits		4,596		1.11		5,625		0.77		5,891		0.69
Savings		15,455		0.22		15,592		0.11		15,742		0.06
Time deposits		19,589		3.31		20,864		2.44		15,280		1.87
Interbank		25,781		0.73		15,333		0.14		23,248		0.80
Other		621		3.09		539		2.51		446		1.11
Non-Greek residents or foreigners:
Demand deposits		353		0.81		818		0.81		320		0.81
Savings		19		0.26		174		0.26		26		0.25
Time deposits		159		1.63		1,034		2.30		326		2.29
Interbank		683		0.37		636		0.22		100		0.01
Deposits in foreign banking offices:
Banks located in foreign countries		3,076		1.13		1,806		2.39		233		2.14
Other foreign demand deposits		1,132		1.31		1,305		0.91		1,908		0.46
Other foreign time and savings deposits		5,590		3.94		5,969		2.78		4,457		2.09

Total deposits		77,054		1.58		69,695		1.23		67,977		0.95

The table below shows the amount outstanding of customer time certificates of deposit and other time deposits (including interbank deposits) in amounts of US$ 0.1 million or more of the Group's operations by remaining maturity at December 31, 2015. Determination of whether certain time deposits in currencies other than the U.S. dollar are in amounts of US$ 0.1 million or more has been based on exchange rates at December 31, 2015.

	Year ended December 31, 2015

	(EUR in millions)
Domestic Operations:⁽¹⁾
Other time deposits of US$0.1 million or more by time remaining until maturity:
3 months or less		26,342
Over 3 through 6 months		1,271
Over 6 through 12 months		709
Over 12 months		3,542

Total time certificates of deposit and other deposits in amount of US$0.1 million or more		31,864



Foreign Operations:
Time certificates of deposit in amounts US$0.1 million or more:
3 months or less		4
Over 3 through 6 months		2
Over 6 through 12 months		1
Over 12 months		17
Other time deposits of US$0.1 million or more by time remaining until maturity:
3 months or less		372
Over 3 through 6 months		133
Over 6 through 12 months		177
Over 12 months		214

Total time certificates of deposit and other deposits in amount of US$0.1 million or more		920

The table below shows outstanding amounts of short-term borrowings of Group companies for each of the three years ended December 31, 2013, 2014 and 2015.

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, 2015.

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 one of the largest financial institutions in Greece by market capitalization, holding a significant position in Greece's retail banking sector, with more than 10 million deposit accounts, 2 million lending accounts, 527 branches (including the one premium banking branch) and 1,444 ATMs as at December 31, 2015. 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 and, since the beginning of 2015, from the ELA of the Bank of Greece.

On November 3, 2015, the Board of Directors approved the plan (see Item 4.A, "History and Development of the Company—Capital Plan") to proceed with the disposal of our entire stake in our Turkish subsidiary, Finansbank A.S. together with our stake in Finans Leasing, thereby disposing of all of our operations in Turkey. This transaction is expected to close within the first half of 2016, subject to customary regulatory and corporate approvals. As a result, our financial and operating data for the twelve months ended December 31, 2015 have been prepared stating separately continuing operations from discontinued operations, the latter relating to Finansbank A.S. in accordance with ASC 205-20 "Discontinued Operations". The historical financial data for the years 2014, 2013, 2012 and 2011 have been restated accordingly. Long lived assets held for sale and the liabilities directly associated with long lived assets comprise Finansbank A.S., the Private Equity Funds and Astir Palace Vouliagmenis S.A and Astir Marina Vouliagmenis S.A.

The Hellenic Republic's economic crisis and related challenges relating to the state of Greek public finances have been and will continue to be a key factor affecting the Group's results of operations. For further information, see Item 5.D., "Trend Information—The Macroeconomic Environment in the Group's Markets—The Hellenic Republic's Economic Crisis".

For the other-than-temporary impairment assessment of Greek government bonds and the related accounting treatment, see "—Critical Accounting Policies, Estimates and Judgments—Other-Than-Temporary—Impairment assessment of Greek Government Bonds as at December 31, 2014".

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" and Item 5.B, "Liquidity and Capital Resources—Financing Under the Hellenic Republic Bank Support Plan", respectively.

Our performance has been and will continue to be influenced by the difficult economic conditions in Greece, in South Eastern Europe ("SEE") and globally. The global economic recovery experienced a downturn in 2015. Global growth decelerated to 3.1% year-over-year in 2015, from 3.4% year-over-year in 2014 (according to International Monetary Fund ("IMF") World Economic Outlook, April 2016) mostly reflecting a recessionary environment in some emerging economies, notably Brazil and Russia, and the gradual transition of the Chinese economy toward a more sustainable, albeit lower, pace of growth. Specifically, Chinese real Gross Domestic Product ("GDP") growth moderated to 6.9% year-over-year, from 7.3% year-over-year in 2014.

Growth in advanced economies strengthened slightly. Specifically, in the United States ("US"), activity remained resilient with real GDP increasing by 2.4% year-over-year in 2015, the same pace as in 2014, mainly driven by consumer spending. The euro area economy continued to recover as domestic demand found support from lower oil prices, rising employment and improving bank credit conditions. As a result, euro area real GDP accelerated to 1.6% year-over-year in 2015 from 0.9% year-over-year in 2014. Finally, growth in Japan picked up pace due to the gradual improvement in labor income and accommodative financial conditions, with real GDP increasing to 0.5% year-over-year in 2015, from 0.0% year-over-year in 2014.

Global financial market conditions remained favorable in the beginning of 2015 on the back of accommodative monetary policy, albeit deteriorated significantly in the second half of the year on the back of the unexpected depreciation of the renminbi by the People's Bank of China in August 2015, which intensified concerns vis-à-vis the pace of the Chinese growth slowdown and the efficiency of the Chinese authorities' policies. These concerns contributed to a sharp decline in energy and industrial prices that in turn, impacted the currencies of commodity exporting economies. Developed markets equity indices edged significantly lower since the beginning of the summer, whereas nominal long-term government bond yields declined in major advanced economies (US, Germany, and Japan) due to renewed deflation concerns that more than offset the first interest-rate increase by the US Federal Reserve ("Fed").

The beginning of 2016 (January–mid February) saw a significant increase in risk aversion as the People's Bank of China allowed the renminbi to depreciate further against the US Dollar and concerns were mounting that tighter financial conditions could signal a significant slowing in the US and euro area economies. As a result, global equities moved sharply lower amid a massive sell-off in bank equity and debt, government bond yields in core markets declined further and corporate bond spreads widened significantly. However, since their mid-February 2016 lows, global equity markets have recovered, as less negative dataflow regarding China and the rebound in oil prices, coupled with the prospect of a gradual only interest rate tightening cycle by the Fed and new policy measures by the ECB (March 2016) supported risk appetite.

In 2016, the growth rate of the global economy is expected to accelerate only slightly to 3.2% year-over-year (IMF, April 2016). This estimate may change given potential negative economic and political developments, such as a sharper-than-expected slowdown of the Chinese economy that could have negative repercussions in both emerging and advanced economies through confidence and currency channels, as well as commodity prices. Tighter global financial conditions could result in rising risk premia across major asset classes, leading to a persistently higher financial market volatility. In such a case, emerging markets, particularly those with sizeable external imbalances, are exposed, as they could face a sharp reversal in capital flows. Moreover, the euro area economy continues to be constrained by a still stubbornly high unemployment rate, as well as elevated private and government debt levels. Thus, adverse geopolitical (refugees crisis) and/or political (Spain, the UK referendum) risks—if they were to materialize—could harm business and consumer confidence rapidly and derail the

fragile euro area recovery. Increased tensions between Ukraine and Russia, in addition to continued geopolitical risks in the Middle East and West Africa cloud the global economic outlook, as well.

The Fed increased the target for the federal funds interest rate by 25 basis points to 0.25%–0.5% in December 2015, albeit it communicated a gradual and data-dependent tightening path going forward. Increased market turbulence, despite moderating recently, and signs of decelerating global growth is expected to keep the Fed on hold in the short-term. Moreover, the Fed will continue the policy of reinvesting principal payments and to roll-over maturing bonds and agency mortgage-backed securities ("MBSs") thus maintaining an accommodative monetary policy stance. In Europe, the ECB decided, in January 2015, to expand the eligibility of its asset purchase program in order to include euro-denominated sovereign, agency and European Union "EU" institution bonds, on top of asset-backed securities and covered bank bonds. Under this expanded program, the ECB has started purchasing, effectively from March 2015, EUR 60 billion bonds per month. In March 2016, amid heightened deflationary pressures, the ECB lowered its main refinancing rate by 5 basis points to 0.0%, its marginal lending facility rate by 5 basis points to 0.25% and its deposit rate by 10 basis points to –0.4%. In addition, the monthly purchases under the asset purchase program will be expanded to EUR 80 billion until at least March 2017, including also investment grade euro-denominated bonds issued by non-bank corporations. At the same time, the ECB announced a new series of four Targeted Longer-term Refinancing Operations ("TLTROs") conducted quarterly between June 2016 and March 2017 with a four-year maturity in order to revive bank lending toward the private sector (excluding mortgages). Finally, the Bank of Japan ("BoJ") continued the aggressive expansion of its balance sheet mainly through purchases of Japanese Government bonds at an annual pace of JPY 80 trillion. In January 2016, the BoJ cut interest rates into negative territory, adopting a three-tiered interest rate structure which determines the amount of banks' reserves subject to negative rates.

Our level of non-accruing loans increased from 33.5% of our loans portfolio at December 31, 2014 to 39.7% at December 31, 2015. We have recorded allowances for loan losses for non-accruing loans as at December 31, 2015, 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 Third Program and adverse macroeconomic conditions in the countries in which we operate will continued to result in adverse effects on the credit quality of our borrowers, with increasing delinquencies, and defaults and increasing levels of allowances for loan losses. Provisions will continue to negatively affect our net income / (loss) in 2016. We have also provided for other probable losses inherent to the portfolio to the extent such losses are reasonably estimable. See Item 4.E, "Selected Statistical Data—Credit Quality and Risk Management—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 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 are intended to 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 (see Item 4. B., "Business Overview—Corporate and Investment Banking—Special Assets Unit ("SAU")", 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. B., "Business Overview—Retail Banking—Retail Collections Unit ("RCU")"and also Item 4.E, "Selected Statistical Data—Credit Quality—Risk Management—Loan Approval Process—National Bank of Greece—Corporate Banking".

Outside of Greece, we are in the process of fully harmonizing credit approval and credit review policies throughout the Group's lending operations. See Item 4.E, "Selected Statistical Data—Credit Quality—Risk Management—Loan Approval Process".

The economic conditions in Greece since 2008 have restricted our access to the international capital markets for funding, increased the cost of such funding and the need for additional collateral requirements in repurchase contracts and other secured funding arrangements, including those with the Eurosystem. The capital markets, particularly for unsecured funding and funding from the short term interbank market, had been effectively closed to all Greek banks since the end of 2009. During 2014, access to financial markets and interbank funding was briefly re-established. However, between December 1, 2014 and June 22, 2015 (just before the implementation of the capital controls), the

uncertainty regarding the financial needs of the Greek government resulted in inter bank liabilities not being renewed, and in addition led to significant deposit net outflows of EUR 10.6 billion and the capital markets once again closing to Greek banks. As a result, maturing inter bank liabilities were not renewed, or renewed only at higher costs (for details, see also Item 5.B "Liquidity and Capital Resources"). This resulted in the increase by EUR 9.8 billion in Eurosystem exposure as of December 31, 2015.

As the Group was principally reliant on the Eurosystem for new funding in 2015, this reliance had an impact on its cost of funding affecting its net interest income for period ended December 31, 2015, due to the increase in ELA funding during 2015(see Item 3.D "Risk Factors—We are currently restricted in our ability to obtain funding in the capital markets and are heavily dependent on the ECB and Bank of Greece, through the ELA, for funding, which access could be affected by changes in the ECB and the Bank of Greece rules relating to the eligibility and valuation of collateral used for funding such as Greek government bonds and guarantees"). On July 6, 2015, ECB decided to increase the haircuts on the notes issued or guaranteed by the Hellenic Republic that were posted as collateral to ELA, subsequently lowering the buffer held by the Bank for funding purposes through the ELA mechanism. Furthermore, as at December 31, 2015, the total eligible collateral amounted to EUR 8.4 billion (cash value), of which EUR 0.1 billion was collateral eligible for funding with the ECB and EUR 8.3 billion was collateral eligible for funding under ELA. Moreover, as at May 4, 2016, the total eligible collateral amounted to EUR 6.2 billion (cash value), of which EUR 0.1 billion was collateral eligible for funding with the ECB and EUR 6.1 billion was collateral eligible for funding under ELA.

See also Item 5.A.,"Operating Results—Results of Operations for the year ended December 31, 2015 compared with the year ended December 31, 2014—Net Interest Income before provision for loan losses".

The Group engages in both customer deposit gathering and wholesale funding activities to finance its assets. The Group offers various kinds of retail and corporate deposit products, which in turn represent the majority of its interest expense. The interest expense depends on the size of its customer deposit base relative to its wholesale debt base, as they are priced independently. Wholesale deposit funding includes interbank borrowing, repurchase agreements, debt issues and bank loan placements.

Despite the reversals of deposit trends and increases in the Group's customer deposits during 2014, the uncertainty regarding the financing needs of the Greek government led to significant deposits outflows during December 2014. A further net outflow in the amount of EUR 8.7 billion occurred between January 1 and June 22, 2015 (just before the implementation of the capital controls). The ongoing crisis in the Greek economy, in conjunction with the strict international supervisory rules, continue to restrict the Bank's access to liquidity from other financial institutions and therefore the Eurosystem remains a major source of liquidity for the Bank. The transfer of responsibility of financing from ECB to ELA with reducing funding limits has created and may continue to create serious liquidity problems for the Greek banks, including NBG, in the future and therefore higher funding cost (see Item 3.D "Risk Factors—Risks Relating to the Hellenic Republic Economic Crisis—Continuing high outflows of funds from customer deposits could cause an increase in our costs of funding and if such outflows were to continue it could have a material adverse effect on our operating results, financial condition and liquidity prospects").

As at December 31, 2015, the Group's deposits made by Greek residents and foreign customers (excluding interbank deposits) were EUR 42,785 million, a decrease of 15.0% compared to December 31, 2014 (EUR 50,329 million). The Group's deposits in Greece have decreased from EUR 43,429 million as at December 31, 2014 to EUR 36,368 million as at December 31, 2015, a decrease of 16.3%.

For our deposit base and the funding from the Eurosystem, see Item 5.B "Liquidity and Capital Resources".

In light of the Group's strategy to streamline its operations and maximize efficiency, a Voluntary Retirement Scheme ("VRS") has been implemented. On December 19, 2013, the Bank announced the implementation of the VRS. The deadline for employee applications to participate in the VRS was December 30, 2013. Approximately 2,500 employees participated in the VRS (see Note 40 to the U.S. GAAP Financial Statements). By taking into account the unpaid leave for these employees, the total VRS expense amounted to EUR 183 million. It is also estimated that the decrease in the Bank's payroll base on a yearly basis will be approximately EUR 155 million.

On September 12, 2014, EH announced the implementation of a voluntary retirement scheme VRS. The deadline for employee applications to participate in the VRS was September 22, 2014. 29 employees participated in the VRS. By taking into account the untaken leave for these employees, the additional VRS expense amounted to EUR 4 million. It is also estimated that the decrease in the Company's payroll base on an annual basis will be approximately EUR 2.5 million.

Additionally, due to the fact that banks intensified their efforts to contain operating costs, especially staff costs, a new collective agreement was signed with the Union of Greek bank employees ("OTOE"), leading to a further cut of about 9% (6% effective in July 2013 and 3% effective in the first quarter of 2014 following the termination of an extra half salary).

Furthermore, the Bank has committed under the Revised Restructuring (see Item 4.A, "History and Development of the Company—Revised Restructuring Plan approved by the Directorate General for Competition on December 4, 2015")to decrease its Total Full Time Equivalent personnel ("FTEs") in Greece to a maximum of 10,250 at the end of 2017 and 9,950 at the end of 2018. Based on this commitment, as at December 31, 2015 the Group and the Bank recognized a provision of EUR 118 million, which is presented within "Other Provisions" (see Note 30 to the to the U.S. GAAP Financial Statements)

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 at August 1, 2008. Pursuant to Greek Law 3655/2008, the Bank will contribute EUR 26 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 accordance with Greek Law 4052/2012 (GG A' 41) a new auxiliary fund called Integrated Auxiliary Pension Fund ("ETEA") was established and started on July 1, 2012. ETEA includes, among others, ETEAM and according to transitional provisions of the same law (GG A' 256/2012), from January 1, 2013, the ETAT regarding the auxiliary schemes is mandatorily included.

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 expects to incur a substantial one-time expense, in accordance with an actuarial estimate, which will be commissioned at that time.

As part of our strategy to streamline our operations, we are disposing of certain investments in non-core businesses. The Group received proceeds of EUR 1 million in 2013, EUR 18 million in 2014 and NIL in 2015 million from disposals of various real estate property holdings. In accordance with the Revised Restructuring Plan we entered in December 2015, we expect to continue divestitures of non-core assets in the future when circumstances permit.

Our selected financial and operating data for the twelve months ended December 31, 2015 have been prepared stating separately continuing operations from discontinued operations, the latter relating to Finansbank in accordance with ASC 205-20 "Discontinued Operations". The historical financial data for the years 2014, 2013, 2012 and 2011 have been restated accordingly. Long lived assets held for sale and the liabilities directly associated with long lived assets comprise Finansbank A.S., the NBGI Private Equity Funds and Astir Palace Vouliagmenis S.A and Astir Marina Vouliagmenis S.A. Our discontinued operations are described in further detail below.

Consequently, the discussion of our financial performance for 2015 and outlook mainly focuses on the results of the continuing operations.

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 at December 31, 2015.

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.

During the first half of 2015, as a result of the negotiations between the new Greek government and the European Commission, the European Central Bank ("ECB") and International Monetary Fund ("IMF") (collectively the "Institutions") towards reaching a permanent agreement regarding Hellenic Republic's financing needs, the uncertainty regarding the financing needs of the Hellenic Republic increased and led to significant deposits outflows from the Greek banks. Liquidity in the Greek banking system declined significantly, reflecting a sizeable contraction of the domestic deposit base between November 2014 and July 2015 of EUR 52.7 billion, accompanied by a sharp increase in reliance on ECB and Emergency Liquidity Assistance ("ELA") to above EUR 125.3 billion in July 2015

from EUR 56.0 billion in December 2014, although such funding obligations declined to EUR 107.5 billion in December 2015.

In part as a response to the substantial contraction in deposits, on June 28, 2015, a bank holiday was declared for all credit institutions operating in Greece. This bank holiday was in place until July 19, 2015. The Greek government imposed numerous restrictions on financial transactions during and after this period, many of which currently continue to apply. The initial capital controls involved maximum daily withdrawal limits of 60 Euros from individual deposit accounts and limitations on transfers of funds abroad were imposed, with certain exceptions. The presently operational capital controls involve, among other limitations, a maximum cumulative weekly withdrawal limit of 420 Euros per depositor, per bank, continued certain prohibitions on the transfer of capital and cash outside of Greece, the prohibition on the opening of new accounts except for specified permitted purposes and a ban on the unwinding of certain financial arrangements (such as the prepayment of loans or accounts not established to serve certain specified purposes).

During the first half of 2015, the structure of the Bank's liquidity position changed substantially. The reasons for this change were the economic turbulence and the uncertainty in the Greek banking sector that was caused by the ongoing negotiations between the Greek government and the Institutions. More specifically, the Bank faced significant deposit outflows of EUR 8.4 billion, as well as the cancellation of approximately EUR 3.6 billion of repurchase agreements with financial institutions. This in turn caused an increased dependence on Eurosystem funding and a commensurate deterioration of the Bank's counterbalancing capacity. Furthermore, in February 2015, ECB lifted the waiver on accepting notes issued or guaranteed by the Hellenic Republic as collateral for repurchase agreements, which forced the Bank to cover its increasing funding shortfall through the ELA. In the height of the liquidity crisis, on June 29, 2015 due to the termination of the negotiations and ECB's decision to freeze the level of ELA, Greek authorities imposed capital controls, in order to prevent a widespread bank run and to preserve the sustainability of the Greek banking system. Moreover, on July 7, 2015, ECB raised the haircuts on the notes issued or guaranteed by the Hellenic Republic, which subsequently further lowered the Bank's buffer for ELA refinancing. As a result of the above developments, the Bank's Eurosystem funding increased in the first half of 2015 by EUR 13.3 billion and reached EUR 27.6 billion as at June 30, 2015. However, even at that point, the Bank retained adequate buffer of ELA eligible collateral, of around EUR 5.5 billion, in order to cover further outflows.

During the second half of 2015, while the capital controls remained in force, the liquidity position of the Bank was improved. Eurosystem funding was reduced by approximately EUR 3.5 billion and ELA funding decreased by approximately EUR 6.1 billion. The main driver for these developments was the Bank's successful share capital increase that was completed in December 2015. The Bank not only enhanced its capital base, but also increased the amount of its ECB eligible collateral by receiving an amount of EUR 2.7 billion of ESM bonds, under the relevant subscription agreement. Additionally, the Bank further reduced its liabilities through the LME Offers, by replacing all of its long-term debt, except for the covered bonds, with equity. Finally, the Bank's liquidity profile was further strengthened by an increase of approximately EUR 1 billion in its customer deposits and by further deleveraging. In this context, on December 31, 2015, the ECB funding stood at EUR 12.5 billion, while ELA funding was EUR 11.5 billion, amounting to a total exposure to the Eurosystem of EUR 24.0 billion, whereas the Bank's liquidity buffer stood at EUR 8.4 billion (cash value), of which EUR 0.1 billion was collateral eligible for funding with the ECB and EUR 8.3 billion was collateral that could be posted in order to draw liquidity from ELA. Total Eurosystem funding amounted to EUR 14.2 billion at December 31, 2014, EUR 20.7 billion at December 31, 2013 and EUR 34.7 billion at June 30, 2012, when it reached the highest amount. Furthermore, as of May 4, 2016, Eurosystem funding has decreased to EUR 22.1 billion, of which EUR 11.1 billion through ELA, while additional financial assets of an estimated cash value EUR 6.2 billion (cash value) were available for further liquidity.

In view of the severe economic and financial disturbance that appeared to threaten the participation of Greece in the European Monetary Union ("EMU") and the EU, the Greek government officially requested financial assistance from the European Union on July 10, 2015 with a view to restoring confidence and enabling the return of the economy to sustainable growth, and safeguarding the country's financial stability. The Greek request received consent, in principle, from the Eurogroup for a new three-year loan program via the ESM.

On August 19, 2015—and following the Eurogroup Statement of August 14, 2015—the Board of Governors of the ESM approved the proposal for a Financial Assistance Facility Agreement ("FFA") with Greece, as well as adopted a Memorandum of Understanding ("MoU") with Greece. On August 20, 2015, the first sub-tranche of EUR 13 billion of the new Program (the "Program") was disbursed for covering budget financing and debt servicing needs of the Hellenic Republic, EUR 10 billion in ESM notes, were made immediately available for bank recapitalization and resolution purposes. Following the agreement and legislation of two additional sets of prior actions, the Greek government received another EUR 3 billion related to the first Program installment, in two sub-tranches in November and December 2015. This funding has been used to cover external debt servicing needs and contributed to a normalization of government spending and to the clearance of about EUR 0.5 billion of Government arrears to the domestic private sector (Source: ESM, December 2015 and Ministry of Finance).

The above developments resulted in the upgrade of Greek sovereign debt by the main rating agencies: S&P raised their rating by two notches to 'CCC+' on July 21, 2015, while Fitch upgraded Greek debt by one notch to 'CCC', on August 18, 2015. On September 25, 2015, Moody's maintained Greece's sovereign rating at 'Caa3' but changed the outlook to stable from negative as it had placed the country's rating on review for further downgrade since July 1, 2015. Finally, S&P Ratings upgraded Greek debt by one notch to 'B–' on January 22, 2016 with a stable outlook, referring to the milder than expected recession and progress made in fiscal and reform targets of the Program as the key determinants of its rating decision (Source: Bloomberg).

As regards, developments in the Greek sovereign bond yields, the intensifying international headwinds since end-2015 and the delayed completion of the pending first review of the Program in late-2015 and early 2016 pushed the yields on Greek 10-year sovereign bond yields higher in January–February 2016 (by 143 bps to 10.4% on average, in February 2016), following a steady decline between July 2015 and December 2015 (a cumulative fall in 10-year Greek Government Bonds yields of 520 bps) (Source: Bloomberg database).

The Group's CET1 ratio at December 31, 2015 increased to 14.5% (see Note 36 to the U.S. GAAP Financial Statements). Furthermore, on November 13, 2015 the ECB approved the Bank's 2015 Capital Plan targeted to address the Bank's capital shortfall under both the Baseline and the Adverse scenarios of the ECB's 2015 Comprehensive Assessment, as announced on October 31, 2015 (see Note 36 to the U.S. GAAP Financial Statements). Part of the 2015 Capital Plan was the recapitalization completed in December 2015.

Management concluded that the Bank is a going concern after considering (a) its current access to the Eurosystem facilities, (b) agreement reached between the Institutions and the Hellenic Republic in July/August 2015, (c) the Bank's and the Group's CET1 ratio of December 31, 2015 and (d) the expected positive impact on the Bank's and the Group's CET1 ratio from the remaining actions included in the 2015 Capital Plan, and in particular the completion of the disposal of Finansbank, expected by June 30, 2016.

Nevertheless, any significant deterioration of the economic environment due to, for example, adverse developments in the completion of the first review of the Program for the financing of the Hellenic Republic, could have a negative impact on the Bank, including its ability to raise funding through ELA, which may adversely affect the Group's and the Bank's ability to continue as a going concern.

The resolution of these material uncertainties depend, among other factors, on the successful completion of the first review of the Program, a solution for the financing needs of the Greek government, and the re-establishment of the waiver by the ECB to the use of Greek government bonds as collateral for Eurosystem funding, which would likely result in a positive flow of deposits to the banking system, including NBG, and access to the international financial markets.

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, Note 20, Note 24 and Note 37 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. For over-the-counter derivative instruments, 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 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 Debt Value Adjustment ("DVA") by applying a methodology symmetric to the one applied for CVA. The bilateral CVA recognized by the Group at December 31, 2014 and 2015 amounted to a cumulative gain of EUR 79 million and a cumulative gain of EUR 201 million, respectively. The increase is mainly attributed to a deterioration of the Bank's credit worthiness during the period December 2015 and December 2014. 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 Measurement". 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 at December 31, 2015, Level 3 assets amounted to EUR 349 million, which included EUR 13 million in trading assets, EUR 11 million in derivative assets and EUR 325 million in AFS securities. Level 3 assets represent 2.7% of assets measured at fair value (or 0.3% of total assets). As at December 31, 2015 Level 3 liabilities amounted to EUR 6 million, which included EUR 6 million 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, 2015 include:

See Note 37 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, 2015.

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 37 to the U.S. GAAP Financial Statements.

Under applicable accounting guidance, goodwill is reviewed at the reporting unit level for potential impairment 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 intangible assets 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 employed 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 included: 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 used 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 as of the date the assessment was carried out. 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 were reasonable and supportable in the

then current 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.

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 was available, and management regularly reviewed the operating results of that unit in 2014. The reporting unit where significant goodwill was allocated in 2014 was the Turkish banking operations. The goodwill related to the acquisition of Finansbank.

Goodwill was tested as at December 31, 2014. 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 consisted of subsidiaries of the Group, and therefore their operations were directed by the Group, (b) the DDM incorporated the earnings variability associated with the restructuring of these subsidiaries operations following their acquisition, and (c) the DDM incorporated management's views of the then current near and medium term as well as detailed views of the then current and near future market conditions and strategy.

The DDM was 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.

Underlying assumptions to the valuation models were: that the entities comprising these reporting units would remain subsidiaries of the Group, that the general macroeconomic and political conditions in the respective markets would remain stable, that economic activity would continue to grow in the medium term and that the reporting units would continue to be able to fund their operations. The estimated cash flows were updated to reflect the then current management estimates and market conditions.

For the Turkish banking operations reporting unit the DDM was based on a 6.2% terminal growth rate and 16.6% pre-tax discount rate.

Based on the results of Step 1 of the impairment test, we determined that the fair value of the Turkish banking operations reporting unit exceeded the carrying amount by EUR 0.2 billion. The result of the DDM was corroborated with other valuation methods, such as book value, market and transaction multiples. Based on these multiples, the implied value of the Turkish banking operations reporting unit, approximated the value derived from the DDM. A 1% increase in the pre-tax discount rate or a 1% decrease in the terminal growth rate would have decreased the fair value by approximately EUR 0.2 billion and EUR 0.2 billion respectively. In addition, a 5% decrease in the forecast amounts available for dividends would have decreased the fair value by approximately EUR 0.2 billion.

In 2014 we recognized an additional EUR 58 million impairment charges in relation to the private equity business of the Group.

Further details on this subject are given in Note 3 and Note 17 to the U.S. GAAP Financial Statements.

Impairment of discontinued operations and long-lived assets held for sale as at December 31, 2015

On November 3, 2015, the Bank's Board of Directors approved the plan to proceed with the disposal of its entire stake in Finansbank. On 21 December 2015, the Bank's Board of Directors approved the sale to Qatar National Bank ("QNB") of NBG Group's 99.81% stake in Finansbank A.S. together with NBG's 29.87% direct stake in Finans Leasing. Furthermore, on January 18, 2016, the Extraordinary General Meeting of the Shareholders approved the transaction, which is also in line with

the relevant commitment included in the Revised Restructuring Plan. The agreed consideration for the transaction amounts to EUR 2,750 million. In addition, QNB will repay upon closing the USD 910 million of subordinated debt that NBG has extended to Finansbank. The disposal is consistent with the Group's capital action plan to address the capital shortfalls identified from the 2015 Comprehensive Assessment carried out by the ECB and satisfies the relevant commitment in the Restructuring Plan approved by the Directorate General for Competition on December 4, 2015. The closing of the transaction is subject to customary regulatory and corporate approvals and is expected within the first semester of 2016. As a result, the investment in Finansbank qualifies to be classified as a disposal group held for sale on November 3, 2015. Furthermore, Finansbank meets the definition of a discontinued operation because in accordance with ASC 205-20 "Discontinued Operations" represents a strategic shift that has a major effect on the Group's operations and financial results. Details of the assets and liabilities to be disposed of are disclosed in Note 17 to the U.S. GAAP Financial Statements.

Following the decision to dispose its entire stake in Finansbank, the Group, based on the agreed consideration, measured the assets and liabilities of the discontinued operation at the lower of carrying value or fair value less cost to sell and recognized an impairment loss of EUR 5,478 million during the period ended December 31, 2015 of which EUR 1,763 million related to the goodwill and EUR 96 million to intangibles recognized in the Group's consolidated financial statements. For the remaining amount of EUR 3,619 million, a valuation allowance was recorded against long-lived assets held for sale. The carrying amount of the Group's investment in Finansbank for impairment measurement purposes, included the cumulative unrealized foreign currency translation losses of EUR 2,930 million, as required by ASC 830-30-45-13 through 45-15. Once the investment is sold, the cumulative translation loss adjustment will be derecognised from AOCI, thus increasing equity by EUR 2,930 million, with no impact in the income statement.

On December 21, 2015, the Bank's Board of Directors approved the plan to proceed with the disposal of its entire stake in eleven Limited Partnerships ("the Funds") located in UK and held directly or indirectly by NBG and managed by NBGI PE Limited. On February 2, 2016 the Bank entered into a definitive agreement to sell the 100% of its interests in Funds to funds managed by Deutsche Bank Private Equity and Goldman Sachs Asset Management. The agreed consideration for the transaction amounts to EUR 288 million. The disposal is consistent with the Group's capital action plan to address the capital shortfalls identified from the 2015 Comprehensive Assessment carried out by the ECB and satisfies the relevant commitment in the Revised Restructuring Plan. Closing of the transaction is expected within the first semester of 2016, subject to the approval from the Financial Conduct Authority, and antitrust and competition authorities. As a result, the investment in Funds qualifies to be classified as held for sale on December 21, 2015 in accordance with ASC 360-10-45-11 "Long-Lived Assets Classified as Held for Sale", as the requirements and conditions specified by the Standard are met. Details of the assets and liabilities to be disposed of are disclosed in Note 17 to the U.S. GAAP Financial Statements.

Following the decision to dispose its entire stake to the Funds, the Group, based on the agreed consideration, measured the assets and liabilities of the Funds at the lower of carrying value of fair value less cost to sell and recognized an impairment loss of EUR 104 million during the period ended December 31, 2015.

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 long-duration life insurance contracts are estimated using approved actuarial methods that include assumptions about future investment yields, mortality, expenses, options and guarantees, morbidity and terminations. Insurance reserves on short duration life insurance contracts (certain health contracts) are estimated on an unexpired risk basis.

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 are regularly reassessed, with the support of qualified actuaries, in order to reflect recent trends from company's experience and management views. Any additional future losses anticipated from the revision of assumptions and estimates are charged to the income statement. Insurance reserves slightly decreased at EUR 2.1 billion in 2015 compared to EUR 2.2 billion in 2014 following the favorable assumptions for long-duration health contracts.

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.

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 2015 net periodic pension cost was 2.0% compared to 3.6% for 2014. The rate of compensation decreased from 1.8% in 2014 to 1.6% in 2015. The discount rate decreased from 3.6% in 2014 to 2.0% in 2015. The change in assumptions and the difference between actual outcomes and assumptions resulted in a net actuarial losses of EUR 23 million in 2015. 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 40, "Employee Benefit Plans", to the U.S. GAAP Financial Statements.

Other-Than-Temporary-Impairment assessment of Greek government bonds as at December 31, 2015

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. The Group has conducted an assessment of whether the decline in fair value below amortized cost is an OTTI.

During 2015 the Group recognized OTTI charges for Greek government bonds of EUR 23 million, that were in an unrealized loss position as at December 31, 2015 because the Group sold a portion of these debt securities after year end. The unrealized losses for over one year on the remaining Greek government bonds amounted to EUR 6 million and no OTTI was recognized because the Group has neither the intention nor the expectation that it will be required to sell these securities before recovery of their amortized cost basis and the issuer is expected to continue meeting its contractual obligations.

Other-Than-Temporary-Impairment of other available-for-sale and held-to-maturity financial assets

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 to the U.S. GAAP financial statements 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.

For the purposes of assessing the credit quality and collectability of the debt instruments, the Group segregates those securities classified as available-for-sale and held-to-maturity first by issuer type between sovereign, financial institutions and other corporate entities. Each issuer type is then further disaggregated by region to Eurozone, European Union (non-Eurozone) and outside the European Union and emerging market (countries that have been labeled by the IMF as "emerging economies"). Corporate entities are further disaggregated into listed and non-listed. Evidence considered is dependent on the category of the debt.

At December 31, 2015 the Group has recognized in total EUR 36 million in respect of OTTI charges in the consolidated income statement with respect to debt and equity securities and mutual funds (see Note 11 of the U.S. GAAP Financial Statements), of which an amount of EUR 23 million

related to Greek government bonds and EUR 13 million to other available-for-sale and held-to-maturity securities. With respect to the remaining unrealized losses for debt securities, we concluded that the unrealized losses are not other than temporary. To arrive at this conclusion the Group considered that it neither intends nor expects it will be required to sell these securities before the recovery of their amortized cost basis. Furthermore, no credit loss event occurred in respect of the issuers of these debt securities and the issuers are meeting the obligations as per the contractual terms of the securities, therefore we concluded that an OTTI has not occurred.

For corporate debt securities OTTI charges of EUR 1 million were recognized in relation to a security, for which the Group considered that a credit loss existed, with respect to such security, due to the financial difficulties faced by the issuer. With respect to debt securities issued by other governments and public entities the unrealized losses for over one year of EUR 6 million relate to debt securities issued by the Bulgarian Government, held by our subsidiary in Bulgaria. We consider the unrealized losses insignificant as they represent on average only 2.3% of the amortized cost basis, and that Bulgarian Government will continue to pay in accordance with the contractual terms, and as such an OTTI was not considered necessary as at December 31, 2015.

With respect to corporate debt securities issued by companies incorporated outside Greece the unrealized losses for over one year of EUR 8 million mainly relate to debt securities issued by large foreign financial institutions for which we consider that they will continue to pay in accordance with the contractual terms. Furthermore, the Group has no intention nor expects to sell these securities before we recover our investment and therefore an OTTI was not considered necessary.

With respect to debt securities issued by companies incorporated in Greece, the unrealized losses for over one year of EUR 4 million relate to large Greek corporates for which we have concluded that the unrecognized losses are not other than temporary.

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 the Greek and Bulgarian government and by companies incorporated in Greece. For equity securities and mutual funds with significant and prolonged unrealized losses or with an OTTI recognized in previous periods, which were in an unrealized loss position as at December 31, 2015, the Group recognized OTTI charges of EUR 8 million and EUR 4 million respectively.

It is reasonably possible that outcomes in the next financial year could be different from the assumptions and estimates used in identifying OTTI.

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 198 million at December 31, 2015 (see Note 31 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 tax loss incurred over the years ended December 31, 2008, 2009, 2010, 2012, 2013, 2014 and 2015 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 4110/2013 effectively extended 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 of 30 annual equal installments.

Each year management assesses whether the recognition of the deferred tax asset is appropriate to the extent that future taxable profit will be available to absorb these tax losses and other deductible temporary differences. At December 31, 2015 management concluded that due to the existence of history of tax losses it is more appropriate to recognize a valuation allowance of EUR 7,057 million until the Bank returns to profitability.

Results of Operations for the year ended December 31, 2015 compared with the year ended December 31, 2014

Overview. For the year ended December 31, 2015 we reported a net loss attributable to NBG shareholders of EUR 8,464 million compared to a net loss of EUR 2,477 million for the year ended December 31, 2014. The increase in the net loss for the year ended December 31, 2015 is mainly attributed to the increase in provision for loan losses due to the deterioration in the quality of the domestic loan portfolio as a result of the intense political uncertainty and adverse economic conditions, to the impairment loss from discontinuing operations which was calculated as the difference between the agreed consideration and the carrying amount of the Group's investment in Finansbank which, for impairment purposes, includes the cumulative translation adjustment of EUR 2,930 million and other impairments relating to goodwill associated with our Private Equity Funds operations and the investment in Bulgaria. These losses were partially offset by the significantly improved Net trading gain.

Net Interest Income before provision for loan losses. Net interest income before provision for loan losses for 2015 was EUR 1,496 million, a decrease of 6.6% compared to EUR 1,601 million in 2014.

However, net interest margin remained stable at 2.3% for 2015 and 2014. The components of our net interest income after provision for loan losses for 2014 and 2015 are reflected in the following table:

	Year ended December 31,

	Year ended December 31,						2014/2015 Change
	2014			2015			2014/2015 Change
	(EUR in millions)						(%)
Interest Income:
Loans		2,176			1,938			(10.9	)
Securities available for sale		193			134			(30.6	)
Securities held-to-maturity		116			93			(19.8	)
Trading assets		63			66			4.8
Securities purchased under agreements to resell		1			1			—
Interest-bearing deposits with banks		10			7			(30.0	)
Other		21			17			(19.0	)

Total interest income		2,580			2,256			(12.6	)

Interest Expense:
Deposits		(856	)		(645	)		(24.6	)
Securities sold under agreements to repurchase		(21	)		(2	)		(90.5	)
Other borrowed funds		—			(1	)		—
Long-term debt		(48	)		(59	)		22.9
Other		(54	)		(53	)		(1.9	)

Total interest expense		(979	)		(760	)		(22.4	)

Net interest income before provision for loan losses		1,601			1,496			(6.6	)
Provision for loan losses		(1,835	)		(3,298	)		79.7

Net interest income after provision for loan losses		(234	)		(1,802	)		670.1

Our total interest income decreased by 12.6% to EUR 2,256 million for 2015, from EUR 2,580 million for 2014. Group interest income from loans in 2015 showed a decrease of 10.9% compared with 2014, reflecting mainly the reduction in lending rates linked to Euribor, the deleveraging of our retail portfolio and the increase in non-accruing loans. Interest income from securities available for sale has significantly decreased, mainly due to decreased yields on floating rate instruments linked to Euribor. The significant increase in the available for sale portfolio mainly derives from the ESM bonds received in the context of the recapitalization of the bank, completed in December 2015, with marginally negative yields resulting in a negligible effect in the net interest income of the Group. Interest income from trading securities has increased in line with the slight increase in the trading portfolio.

Total interest expense decreased by 22.4% to EUR 760 million for 2015, from EUR 979 million for 2014 due to both lower volumes and deposit yields during the current year. Interest expense on deposits decreased by 24.6% for 2015 compared with 2014. This is mainly attributed to the significant outflow of customer deposits, due to political uncertainty that prevailed in the Greek economy during the year and until the end of June 2015 when capital controls were imposed and to the lower rates paid in 2015 compared with 2014, as a result of the continued downwards repricing of domestic deposits throughout the year. Total deposits increased to EUR 67.6 billion as at December 31, 2015, from EUR 66.1 billion as at December 31, 2014. Deposits from public and private sector excluding interbank, decreased drastically, for the reasons outlined above to EUR 42.8 billion from EUR 50.3 billion representing a decrease of 15.0%. This decrease was counterbalanced by a significant increase in interbank balances of EUR 9.0 billion, to EUR 24.8 billion in 2015 from EUR 15.8 billion in 2014, which includes mainly Eurosystem and ELA funding of EUR 24.0 billion in 2015 from

EUR 14.2 billion in 2014. The decreased interest expense of the Group due to lower volumes and rates paid to customer deposits was abated, by the increased interest expense the Group had as a result of increased ELA funding during the year ended December 31, 2015.

Indicatively interbank deposits represent 36.7% of total deposits in 2015 from 23.9% in 2014.

Our provision for loan losses charged to the income statement increased from EUR 1,835 million in 2014 to EUR 3,298 million in 2015 or an increase of 79.7%. The domestic provision for loan losses charged to the income statement amounted to EUR 3,158 million in 2015 compared to EUR 1,696 million in 2014, or an increase of 86.2%. The increase is due to the deterioration of the quality of our portfolio due to the worse than anticipated performance of the Greek economy and increased political uncertainty. The provision for foreign loans losses charged to the income statement amounted to EUR 140 million in 2015 compared to EUR 139 million in 2014.

Total impaired loans as at December 31, 2015 amounted to EUR 24,861 million, an increase of EUR 3,621 million from EUR 21,240 million at December 31, 2014. Domestic impaired loans amounted to EUR 22,356 million and foreign impaired loans amounted to EUR 2,505 million, increased by 19.8% and decreased by 2.7% respectively since December 31, 2014 (see Note 13 to the U.S. GAAP Financial Statements).

Domestic impaired loans, increased as at December 31, 2015 as a consequence of the worse than anticipated macroeconomic trend in 2015 (see also, Item 5.D, "Trend Information").

The residential mortgages portfolio of our domestic portfolio deteriorated significantly in 2015, with impaired balances increasing by EUR 1,625 million to EUR 8,937 million as at December 31, 2015 from EUR 7,312 million as at December 31, 2014, mainly due to the substantial impact of the recession on borrowers' debt servicing. Domestic other commercial impaired loans amounted to EUR 6,869 million as at December 31, 2015. Foreign impaired loans as at December 31, 2015 amounted to EUR 2,505 million, decreased by EUR 70 million or 2.7% compared to December 31, 2014.

The increase in non-accruing domestic loans as at December 31, 2015, by EUR 3,042 million to EUR 19,647 or 18.3% is due to the deterioration of the quality of our portfolio given the aforementioned factors. Foreign non-accruing loans as at December 31, 2015 amounted to EUR 2,205 million, decreased by EUR 21 million or 0.9% compared to December 31, 2014.

Total write-offs as at December 31, 2015 amounted to EUR 326 million, a decrease of EUR 181 million compared to 2014. Domestic write-offs as at December 31, 2015 amounted to EUR 157 million and foreign write-offs amounted to EUR 169 million, a decrease of 46.7% and a decrease of 344.7% respectively, from the same period in 2014.

Total allowance for loan losses (impaired and non-impaired loans) at December 31, 2015, amounted to EUR 11,775 million, an increase of EUR 2,983 million, or 33.9% compared to December 31, 2014. As at December 31, 2015, allowance for impaired domestic and foreign loans losses amounted to EUR 10,571 million and EUR 973 million respectively, an increase of 38.2% and 0.2% respectively, compared to December 31, 2014.

The allowance for loan losses as a percentage of total loans increased from 15.7% as at December 31, 2014, to 21.4% as at December 31, 2015. This 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 due to the deterioration in economic conditions.

The ratio of allowance for loan losses for impaired loans to impaired loans ("impaired coverage ratio") at December 31, 2015, was 46.4%, higher by 585 basis points from the ratio of 40.6% at December 31, 2014. In the domestic portfolio, the impaired coverage ratio increased by 630 basis points from 41.0% at December 31, 2014 to 47.3% at December 31, 2015. This increase is due to the increased balance of impaired and non-accruing loans and the higher loss rates applied to the impaired domestic portfolio. The impaired coverage ratio for the foreign portfolio at December 31, 2015, decreased by 117 basis points since December 31, 2014, from 38.8% to 37.7%.

The ratio of allowance for loan losses for impaired loans to non-accruing loans ("non-accruing coverage ratio") at December 31, 2015, was 52.8%, higher by 705 basis points from the ratio of 45.8% at December 31, 2014.

The non-accruing coverage ratio for the foreign portfolio decreased by 51 basis points since December 31, 2014.

All domestic components of our loan allowances for loan losses have increased during 2015, except Foreign loans.

Homogeneous allowances increased from EUR 5,128 million as at December 31, 2014 to EUR 6,351 million as at December 31, 2015. This is in line with the increase of our retail non-accruing loans during the same period.

Specific allowances increased during 2015 from EUR 2,330 million as at December 31, 2014, to EUR 3,708 million as at December 31, 2015. Specific allowances mainly include corporate loans, as well as small business loans to a lesser extent. This increase is mainly attributable to updated, lower collateral valuations and downward revision of expected cash flows from borrowers' operating activities.

Coefficient allowances increased from EUR 330 million as at December 31, 2014, to EUR 740 million as at December 31, 2015, also reflecting the increase of our non-accruing loans and increased loss rates.

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 the foreclosure of any type of collateral (if any). A write-off might not have been made since legal actions may still be pending.

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 for the domestic portfolio we collect insignificant amounts from the unsecured portion of our portfolio after a period of five years after the loan agreement is legally terminated. Therefore, for this portion of past due loans a 100% allowance for loan losses is recorded, which represents a full reserve. A write-off might not have been made since legal actions may still be pending.

Domestic write-offs mainly consist of corporate and small business loans individually assessed which have been written-off partially and amounts written off based on restructuring agreements that the obligors adhered to, therefore keeping only the secured balance on balance sheet, or in total.

Non-interest Income. Non-interest income in 2015 was EUR 1,140 million, compared to non-interest loss of EUR 60 million for 2014. The following table summarizes the principal components of non-interest income during each of the two years ended December 31, 2014 and 2015:

	Year ended December 31,

	Year ended December 31,						2014/2015 Change
	2014			2015			2014/2015 Change
	(EUR in millions)						(%)
Credit card fees		39			48			23.1
Service charges on deposit accounts		29			26			(10.3	)
Other fees and commissions		312			274			(12.2	)
Net trading gains / (losses)		(1,091	)		215			119.7
Equity in earnings of investees and realized gains/(losses) on disposals		8			5			(37.5	)
Income from insurance operations		508			477			(6.1	)
Other		165			129			(21.8	)

Total non-interest income / (loss) excluding gains / (losses) on investment securities		(30	)		1,174			4,013.3

Net realized gains/(losses) on sales of available-for-sale securities		96			2			(97.9	)
Other-Than-Temporary Impairment (of which NIL was recognized in OCI)		(6	)		(36	)		500.0

Net gains / (losses) on available for sale and held to maturity securities		90			(34	)		(137.8	)

Total non-interest income / (loss)		60			1,140			1,800.0

The Group engages mainly in vanilla interest rate swaps in order to hedge economically its exposure to interest rates in the long term. The loss of EUR 1,091 million in 2014 was mainly due to the fact that during 2014, interest rates, especially in the long end of the curve (10 to 25 year tenors) declined significantly resulting in a significant loss in our derivatives positions. The gain of EUR 215 million for the year ended December 31, 2015 was mainly due to the fact that the respective tenors of yield curves increased slightly during the current year, creating a moderate gain for the year then ended. Additionally net trading income for 2015 includes significant gains from the bilateral CVA on our derivative positions (net derivative liability position), as a result of the deterioration of NBG creditworthiness during 2015.

Other-Than-Temporary-Impairment in 2015 consists of OTTI charges of EUR 23 million for Greek government bonds, which as at December 31, 2015 were in an unrealized loss position and the Group sold a portion of these bonds subsequent to year end. Furthermore, in 2015 EUR 8 million OTTI was recognized for all equity securities for which either prolonged and significant unrealized losses existed as at December 31, 2015 or an OTTI was recognized in previous periods and as at December 31, 2015 were in an unrealized loss position, as well as OTTI charges of EUR 1 million for a corporate debt security for which the Group considered that a credit loss existed, due to the financial difficulties faced by the issuer (see Note 11 to the U.S. GAAP Financial Statements). Additionally, an OTTI of EUR 4 million in the current period was recognized for mutual funds which presented prolonged and significant unrealized losses as at December 31, 2015. Income from insurance operations has slightly decreased in 2015, to EUR 477 million from EUR 508 million compared to 2014, mainly due to lower gross written premiums in the motor line of business, as a result of the difficulties that the Greek economy faces.

Non-interest Expense. Non-interest expense in 2015 was EUR 2,640 million, decreased by 9.8% compared with EUR 2,405 million for 2014.

Salaries, employee benefits and voluntary early retirement schemes decreased slightly by 1.5% and amounted to EUR 806 million in 2015 from EUR 818 million in 2014. This slight decrease is attributed to the continuous efforts of the Group for effectively controlling wages and related employee benefits costs.

Impairment of goodwill of EUR 221 million in 2015 and EUR 58 million in 2014, relates mainly to our private equity business (see Note 17 to the U.S. GAAP Financial Statements) and to our operations in Bulgaria (see note 14 to the U.S. GAAP Financial Statements).

Insurance claims, reserves movement, commissions and reinsurance premium ceded increased by 19.5% in 2015, compared to 2014, primarily due to the lower insurance reserves in health compared to 2014, resulting from the decrease of the related portfolio and the revision of the assumptions.

Income/(Loss) Before Income Tax. As a result of the above, in 2015, the Group reported loss before income tax of EUR 3,302 million compared to loss before income tax of EUR 2,579 million in 2014.

Income Tax Expense. In 2015, we recognized a current tax expense of EUR 77 million and a deferred tax benefit of EUR 35 million compared to a current tax expense of EUR 2 million and a deferred tax expense of EUR 61 million in 2014. Our total tax expense in 2015 amounted to EUR 42 million compared to EUR 63 million in 2014. The applicable Greek statutory corporation income tax rate for 2015 increased to 29% from 26% for 2014.

Net Income/(Loss) Attributable to from continuing operations. For the reasons discussed above, net loss from continuing operations was EUR 3,344 million for 2015, compared to net income loss of EUR 2,642 million for 2014.

Net Income/(Loss) Attributable to from discontinuing operations. Net loss from discontinued operations for the year ended December 31, 2015 amounted to EUR 5,123 million while for the year ended December 31, 2014 net income from discontinued operations amounted to EUR 169 million. For the year ended December 31, 2015, the loss from discontinuing operations included an impairment loss of EUR 5,478 million which was calculated as the difference between the agreed consideration and the carrying amount of the Group's investment in Finansbank which, for impairment purposes, includes the cumulative translation adjustment of EUR 2,930 million.

Net Income/(Loss) Attributable to NBG Shareholders. For the reasons discussed above, net loss attributable to NBG shareholders was EUR 8,464 million for 2015, compared to EUR 2,477 million for 2014.

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. As at December 31, 2015, 9.3% of the Group's liabilities, excluding liabilities directly associated with long-lived assets classified as held for sale and 11.4% of the Group's assets excluding long-lived assets classified as held for sale 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, 2014 compared with the year ended December 31, 2013

Overview. In 2014, the Group reported a net loss attributable to NBG shareholders of EUR 2,477 million compared to a net income of EUR 37 million in 2013. Our net loss for the year ended December 31, 2014 is mainly attributed to the significant increase in provision for loan losses due to the intense political uncertainty and continuing challenging economic conditions and the significant losses on derivatives. Income from discontinued operations contributed positively to Group's net income for the year 2014, albeit to a significant lesser extent than in 2013, mainly due to losses on derivatives due to the gradual decline in Turkish interest rates over 2014 and the adverse effect from the depreciation of the local currency.

Net Interest Income before provision for loan losses. Net interest income before provision for loan losses for 2014 was EUR 1,601 million, showing an increase of 2.5% compared to EUR 1,562 million in

2013. Net interest margin remained stable at 2,3% for 2014 and 2013. The components of our net interest income after provision for loan losses for 2013 and 2014 are reflected in the following table:

	Year ended December 31,

	Year ended December 31,						2013/2014 Change
	2013			2014			2013/2014 Change
	(EUR in millions)						(%)
Interest Income:
Loans		2,357			2,176			(7.7	)
Securities available for sale		204			193			(5.4	)
Securities held-to-maturity		95			116			22.1
Trading assets		117			63			(46.2	)
Securities purchased under agreements to resell		3			1			(66.7	)
Interest-bearing deposits with banks		17			10			(41.2	)
Other		31			21			(32.3	)

Total interest income		2,824			2,580			(8.6	)

Interest Expense:
Deposits		(1,219	)		(856	)		(29.8	)
Securities sold under agreements to repurchase		(18	)		(21	)		16.7
Long-term debt		(18	)		(48	)		166.7
Other		(7	)		(54	)		671.4

Total interest expense		(1,262	)		(979	)		(22.4	)

Net interest income before provision for loan losses		1,562			1,601			2.5
Provision for loan losses		(633	)		(1,835	)		189.9

Net interest income after provision for loan losses		929			(234	)		(125.2	)

Our total interest income decreased by 8.6% to EUR 2,580 million for 2014, from EUR 2,824 million for 2013. Group interest income from loans in 2014 showed a decrease of 7.7% compared with 2013, reflecting mainly the reduction in the lending rates linked to Euribor and the increase in non-accruing loans. Furthermore, the decrease in our interest income from securities available for sale and trading assets derives mainly from the decrease in our position in Greek government bonds and the decrease in the yields of treasury bills.

Total interest expense decreased by 22.4% to EUR 979 million for 2014, from EUR 1,262 million for 2013, mainly due to the decrease of the reliance on Eurosystem funding through ELA as compared to ECB funding and due to the lower deposit yields. Interest expense on deposits decreased by 29.8% for 2014 compared with 2013. This is mainly attributed to lower rates paid to interest bearing deposits in 2014 compared with 2013, as a result of the continued downwards repricing of domestic deposits throughout the year. Total deposits decreased to EUR 66.1 billion as at December 31, 2014, from EUR 72.1 billion as at December 31, 2013. This fluctuation was a result of the reduction in interbank balances, which decreased from EUR 22.0 billion in 2013 to EUR 15.8 billion as at December 31, 2014. The balances include the Eurosystem funding which amounted to EUR 20.7 billion and EUR 14.2 billion in 2013 and 2014 respectively. Indicatively interbank deposits represented 23.9% of total deposits, as at December 31, 2014 compared to 30.6% as at 31 December 31, 2013.

Our provision for loan losses charged to the income statement increased from EUR 633 million in 2013, to EUR 1,835 million in 2014, or 189.9%. The domestic provision for loan losses charged to the income statement amounted to EUR 1,696 million in 2014 compared to EUR 541 million in 2013, or an increase of 213.5%. The increase is mainly attributable to the worse than anticipated trend in the

Greek economy and the increased financial uncertainty affecting the domestic portfolio. The provision for foreign loans losses charged to the income statement amounted to EUR 139 million as at December 31, 2014 compared to EUR 92 million as at December 31, 2013.

Total impaired loans as at December 31, 2014 amounted to EUR 21,240 million, an increase of EUR 563 million from EUR 20,677 at December 31, 2013. Domestic impaired loans amounted to EUR 18,665 million and foreign impaired loans amounted to EUR 2,575 million, increasing by 6.2% and decreasing by 16.9% respectively since December 31, 2013 (see Note 13 to the U.S. GAAP Financial Statements).

Domestic impaired loans, increased as at December 31, 2014 as a consequence of the worse than anticipated macroeconomic trend in 2014 (see also, Item 5.D, "Trend information").

The residential mortgages portfolio of our domestic portfolio deteriorated significantly in 2014, with impaired balances increasing by EUR 141 million to EUR 7,312 million as at December 31, 2014 from EUR 7,171 million as at December 31, 2013, mainly due to the substantial impact of the recession on borrowers' debt servicing. Domestic other commercial impaired loans amounted to EUR 5,108 million as at December 31, 2014.

The increase in non-accruing domestic loans as at December 31, 2014, by EUR 713 million or 4.5%, as to the deterioration of the quality of our portfolio given the aforementioned factors. Foreign non-accruing loans as at December 31, 2014, amounted to EUR 2,226 million, decreased by EUR 19 million or 0.8% compared to December 31, 2013.

Foreign impaired loans as at December 31, 2014, amounted to EUR 2,575 million, decreased by EUR 522 million or 16.9% compared to December 31, 2013.

Total write-offs as at December 31, 2014, amounted to EUR 145 million, a decrease of EUR 27 million compared to 2013. Domestic write-offs as at December 31, 2014, amounted to EUR 107 million and foreign write-offs amounted to EUR 38 million, a decrease of 22.5% and an increase of 11.8% respectively, from the same period in 2013.

Total allowance for loan losses (impaired and non-impaired loans) at December 31, 2014, amounted to EUR 8,792 million, an increase of EUR 1,654 million, or 23.2% compared to December 31, 2013. As at December 31, 2014, allowance for impaired domestic and foreign loans losses amounted to EUR 7,650 million and EUR 970 million respectively, an increase of 24.8% and 8.9% respectively, compared to December 31, 2013.

The allowance for loan losses as a percentage of total loans increased from 12.4% as at December 31, 2013, to 15.6% as at December 31, 2014. This 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 loan losses for impaired loans to impaired loans ("impaired coverage ratio") at December 31, 2014, was 40.6%, higher by 663 basis points from the ratio of 34.0% at December 31, 2013. In the domestic portfolio, the impaired coverage ratio increased by 611 basis points from 34.9% at December 31, 2013 to 41.0% at December 31, 2014. This increase is due to the increased balance of impaired and non-accruing loans and the higher loss rate applied to the impaired domestic portfolio.

The ratio of allowance for loan losses for impaired loans to non-accruing loans ("non-accruing coverage ratio") at December 31, 2014, was 45.8%, higher by 708 basis points from the ratio of 38.7% at December 31, 2013.

The impaired coverage ratio for the foreign portfolio at December 31, 2014 increased by 894 basis points since December 31, 2013, and the non-accruing coverage ratio for the foreign portfolio increased by 393 basis points since December 31, 2013, as a result of the higher loss rates applied to foreign impaired and non-accruing loans.

All components of our loan allowances for loan losses have increased during 2014.

The most significant increase is noted within the homogeneous allowances, which increased from EUR 4,159 million as at December 31, 2013 to EUR 5,128 million as at December 31, 2014. This is in line with the increase of our retail non-accruing loans during the same period.

Specific allowances increased during 2014 from EUR 1,808 million as at December 31, 2013, to EUR 2,330 million as at December 31, 2014. Specific allowances mainly include corporate loans, as well as small business loans to a lesser extent. This increase is mainly attributable to updated, lower collateral valuations and downward revision of expected cash flows from borrowers' operating activities.

Coefficient allowances increased from EUR 242 million as at December 31, 2013, to EUR 330 million as at December 31, 2014, also reflecting the increase of our retail non-accruing loans and increased loss rates.

When we determine 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 for the domestic portfolio we collect insignificant amounts from the unsecured portion of our portfolio after a period of five years after the loan agreement is legally terminated. Therefore, for this portion of

past due loans a 100% allowance for loan losses is recorded, which represents a full reserve. A write-off might not have been made since legal actions may still be pending.

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 in 2014 was EUR 60 million, compared to EUR 1,197 million for 2013, driven primarily by a net trading loss in 2014 resulting from valuation of our interest rate swaps. The following table summarizes the principal components of non-interest income during each of the two years ended December 31, 2013 and 2014:

	Year ended December 31,

	Year ended December 31,						2013/2014 Change
	2013			2014			2013/2014 Change
	(EUR in millions)						(%)
Credit card fees		40			39			(2.5	)
Service charges on deposit accounts		28			29			3.6
Other fees and commissions		311			312			0.3
Net trading gains / (losses)		114			(1,091	)		(1,057.0	)
Equity in earnings of investees and realized gains / (losses) on disposals		10			8			(20.0	)
Income from insurance operations		514			508			(1.2	)
Other		277			165			–40.4
Total non-interest income / (loss) excluding gains / (losses) on investment securities		1,294			(30	)		(102.3	)
Net realized gains / (losses) on sales of available-for-sale securities		189			96			(49.2	)
Other-Than-Temporary Impairment (of which NIL was recognized in OCI)		(286	)		(6	)		(97.9	)
Net gains / (losses) on available for sale and held to maturity securities		(97	)		90			(192.8	)
Total non-interest income / (loss)		1,197			60			(95.0	)

Net trading losses increased to EUR 1,091 million in 2014 from gains of EUR 114 million in 2013. The Group engages mainly in vanilla interest rate swaps in order to hedge economically its exposure to interest rates in the long term. The loss of EUR 1,091 million in 2014 was mainly due to the fact that during 2014, interest rates, especially in the long end of the curve (10 to 25 year tenors) declined significantly resulting in a significant loss in our derivatives positions. Other-Than-Temporary-Impairment in 2014 consists of OTTI charges of EUR 5 million for all equity securities for which an OTTI was recognized in previous periods and as at December 31, 2014, were in an unrealized loss position as well as OTTI charges of EUR 1 million for a corporate debt security for which the Group considered that a credit loss existed, due to the financial difficulties faced by the issuer (see Note 11 to the U.S. GAAP Financial Statements). Income from insurance operations has stabilized in 2014, decreasing only slightly by EUR 6 million to EUR 508 million compared to 2013, due mainly to the lower gross written premiums in the motor line of business, as a result of the difficulties that the Greek economy faces.

Non-interest Expense. Non-interest expense in 2014 was EUR 2,405 million, decreased by 10.4% compared to EUR 2,685 million for 2013.

Salaries, employee benefits and voluntary early retirement schemes decreased by 27.5% and amounted to EUR 818 million in 2014 from EUR 1,128 million in 2013. This decrease is mainly attributed to the savings in 2014 from the results of the voluntary retirement scheme that the Group implemented in Greece during December 2013, in which more than 2,500 employees participated and the cost of the VRS of EUR 183 million being included in 2013.

Impairment of goodwill of EUR 58 million and EUR 9 million in 2014 and 2013 respectively, relates exclusively to our private equity business.

Insurance claims, reserves movement, commissions and reinsurance premium ceded decreased by 51.8% in 2014, compared to 2013, primarily due to the decrease in insurance reserves in health, as a result of the decrease of the assumption for medical inflation from 6% in 2013 to 4% in 2014.

Income/(Loss) Before Income tax. As a result of the above, in 2014 the Group reported a net loss of EUR 2,579 million compared to EUR 559 million in 2013.

Income Tax Expense. In 2014, we recognized a current tax expense of EUR 2 million and a deferred tax expense of EUR 61 million compared to a current tax expense of EUR 35 million and a deferred tax benefit of EUR 15 million in 2013. Our total tax expense in 2014 amounted to EUR 63 million compared to EUR 20 million in 2013. The applicable Greek statutory corporation income tax rate for 2014 and 2013 was 26%.

Income/(Loss) from continuing operations. As a result of the above, in 2014, the Group reported loss of EUR 2,642 million compared to income before income tax of EUR 579 million in 2013.

Income/(Loss) from discontinuing operations. Net income from discontinued operations decreased in the year ended December 31, 2014 to EUR 169 million from EUR 648 for the year ended December 31, 2013.

Net Income/(Loss) Attributable to NBG Shareholders. For the reasons discussed above, net loss attributable to NBG shareholders was EUR 2,477 million for 2014, compared to net income of EUR 37 million for 2013.

Exchange Rate Exposure. As at December 31, 2014, 10.4% of the Group's liabilities excluding liabilities directly associated with long-lived assets classified as held for sale and 11.2% of the Group's assets excluding long-lived assets classified as held for sale 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".

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) in Greece. The Bank, through its extensive 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.

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.

In order to (a) manage more effectively delinquent, non-performing and denounced loans to legal entities, and (b) ensure compliance with the provisions of Bank of Greece Executive Committee Act 42/30.5.2014 and Act 47/9.2.2015 and the Code of Conduct (referred to in Article 1(2) of Greek Law 4224/2013), in 2014 the Bank established a Special Assets Unit division.

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 SEE.

The Group's international banking activities, 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.

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, 2015	Retail Banking

	(EUR in millions)
Net interest income		521		601		176		101		45		332		—	129		1,905
Net fee and commission income		81		83		7		(175	)	4		95		—	(2	)	93
Other		10		(13	)	(12	)	(72	)	80		14		—	(33	)	(26	)

Total operating income		612		671		171		(146	)	129		441		—	94		1,972

Direct costs		(436	)	(47	)	(9	)	(46	)	(83	)	(259	)	—	(42	)	(922	)
Allocated costs and provisions		(1,829	)	(1,106	)	(848	)	(127	)	(28	)	(167	)	—	(537	)	(4,642	)
Share of profit of equity method investments		—		—		—		1		1		1		—	—		3

Profit / (Loss) before tax		(1,653	)	(482	)	(686	)	(318	)	19		16		—	(485	)	(3,589	)



Segment assets as at December 31, 2015
Segment assets		19,972		11,684		1,824		13,000		2,756		9,557		—	18,997		77,790
Deferred tax assets and Current income tax advance																	5,675
Discontinued Operations and Long Lived Assets held for Sale																	27,767

Total assets																	111,232



Segment liabilities as at December 31, 2015
Segment liabilities		35,240		120		79		24,925		2,259		6,963		—	8,160		77,746
Deferred tax liabilities and Current income tax advance																	19
Liabilities associated with Long Lived assets held for sale																	23,643

Total liabilities																	101,408



Other Segment items
Depreciation and amortization⁽¹⁾		10		3		—		1		9		21		—	77		121
Credit provisions and other impairment charges		1,548		1,069		826		(10	)	34		155		—	641		4,263
Non-current assets additions		7		9		—		4		5		20		—	134		179

Presentation of SAU segment incorporated into the retail and corporate business segments.

12-month period ended December 31, 2015	Retail Banking

	(EUR in millions)
Net interest income		559		739		—	101		45		332			129		1,905
Net fee and commission income		82		89		—	(175	)	4		95			(2	)	93
Other		5		(20	)	—	(72	)	80		14			(33	)	(26	)

Total operating income		646		808		—	(146	)	129		441		—	94		1,972

Direct costs		(440	)	(52	)	—	(46	)	(83	)	(259	)		(42	)	(922	)
Allocated costs and provisions		(2,022	)	(1,761	)	—	(127	)	(28	)	(167	)		(537	)	(4,642	)
Share of profit of equity method investments		—		—		—	1		1		1					3

Profit / (Loss) before tax		(1,816	)	(1,005	)	—	(318	)	19		16		—	(485	)	(3,589	)



Segment assets as at December 31,
Segment assets		20,453		13,027		—	13,000		2,756		9,557			18,997		77,790
Deferred tax assets and Current income tax advance																5,675
Discontinued Operations and Long Lived Assets held for Sale																27,767

Total assets																111,232



Segment liabilities as at December 31, 2015
Segment liabilities		35,250		189		—	24,925		2,259		6,963			8,160		77,746
Deferred tax liabilities and Current income tax advance																19
Liabilities associated with Long Lived assets held for sale																23,643

Total liabilities																101,408



Other Segment items
Depreciation and amortization⁽¹⁾		10		3		—	1		9		21			77		121
Credit provisions and other impairment charges		1,734		1,709		—	(10	)	34		155			641		4,263
Non-current assets additions		7		9		—	4		5		20			134		179

12-month period ended December 31, 2014	Retail Banking

	(EUR in millions)
Net interest income		573		743		—	189		55		319		—	119		1,998
Net fee and commission income / (loss)		72		98		—	(125	)	5		93		—	(4	)	139
Other		23		(63	)	—	(105	)	103		14		—	(45	)	(73	)

Total operating income / (loss)		668		778		—	(41	)	163		426		—	70		2,064

Direct costs		(456	)	(47	)	—	(50	)	(90	)	(253	)	—	(52	)	(948	)
Allocated costs and provisions		(1,569	)	(755	)	—	(66	)	(9	)	(128	)	—	(405	)	(2,932	)
Share of profit of equity method investments		—		—		—	(2	)	1		1		—	1		1

Profit / (Loss) before tax		(1,357	)	(24	)	—	(159	)	65		46		—	(386	)	(1,815	)



Segment assets as at December 31, 2014
Segment assets		22,227		12,177		2,587	11,261		2,613		9,427		27,220	23,154		110,666
Deferred tax assets and Current income tax advance																4,546

Total assets																115,212



Segment liabilities as at December 31, 2014
Segment liabilities		37,913		909		101	25,127		2,092		7,582		22,754	8,149		104,627
Deferred tax liabilities and Current income tax advance																119

Total liabilities																104,746



Other Segment items
Depreciation and amortization⁽¹⁾		14		3		—	1		8		24		—	79		129
Credit provisions and other impairment charges		1,287		694		—	—		59		127		—	356		2,523
Non-current assets additions		5		13		—	32		4		37		418	340		849

To facilitate the comparison of the segment analysis for the year ended December 31, 2014 with the year ended December 31, 2013 we present the 2014 segment including discontinued operations.

12-month period ended December 31, 2014	Retail Banking

	(EUR in millions)
Net interest income		573		743		—	189		55		315		1,139		115		3,129
Net fee and commission income / (loss)		72		98		—	(125	)	5		93		393		(5	)	531
Other		23		(63	)	—	(106	)	103		14		(24	)	(43	)	(96	)

Total operating income / (loss)		668		778		—	(42	)	163		422		1,508		67		3,564

Direct costs		(456	)	(47	)	—	(50	)	(90	)	(253	)	(764	)	(52	)	(1,712	)
Allocated costs and provisions		(1,569	)	(755	)	—	(66	)	(9	)	(125	)	(347	)	(404	)	(3,275	)
Share of profit of equity method investments		—		—		—	(2	)	1		1		1		—		1

Profit / (Loss) before tax		(1,357	)	(24	)	—	(160	)	65		45		398		(389	)	(1,422	)



Segment assets as at December 31,
Segment assets		22,821		14,170		—	11,261		2,865		9,427		27,220		23,154		110,918
Deferred tax assets and Current income tax advance																	4,546

Total assets																	115,464



Segment liabilities as at December 31, 2014
Segment liabilities		38,014		909		—	25,127		2,344		7,582		22,754		8,149		104,879
Deferred tax liabilities and Current income tax advance																	119

Total liabilities																	104,998



Other Segment items
Depreciation and amortization⁽¹⁾		14		3		—	1		8		24		75		81		206
Credit provisions and other impairment charges		1,287		694		—	—		61		128		342		353		2,865
Non-current assets additions		5		13		—	32		4		37		418		340		849

Business Segments for the year ended December 31, 2013 have not been restated to exclude discontinued operations, because these were not presented under IFRS for comparison purposes.

12-month period ended December 31, 2013	Retail Banking

	(EUR in millions)
Net interest income		619		696		(101	)	84		299		1,299		261		3,157
Net fee and commission income / (loss)		75		90		(140	)	7		90		401		6		529
Other		—		(46	)	28		102		15		44		(58	)	85

Total operating income / (loss)		694		740		(213	)	193		404		1,744		209		3,771

Direct costs		(569	)	(50	)	(55	)	(98	)	(260	)	(859	)	(286	)	(2,177	)
Allocated costs and provisions		(1,114	)	(421	)	528		14		(117	)	(338	)	(320	)	(1,768	)
Share of profit of equity method investments		—		—		(4	)	1		1		(3	)	—		(5	)

Profit / (loss) before tax		(989	)	269		256		110		28		544		(397	)	(179	)



Segment assets as at December 31, 2013
Segment assets		24,901		14,115		16,048		3,365		9,505		23,373		16,768		108,075
Tax assets																2,855

Total assets																110,930



Segment liabilities as at December 31, 2013
Segment liabilities		37,724		1,252		31,758		2,916		7,055		19,641		2,611		102,957
Deferred tax liabilities and Current income tax advance																99

Total liabilities																103,056



Other Segment items
Depreciation and amortization⁽¹⁾		17		3		2		8		27		67		102		226
Credit provisions and other impairment charges		796		375		(548	)	(17	)	114		339		314		1,373
Non- current assets additions		4		27		—		3		22		102		54		212

Segment analysis for year ended December 31, 2015 compared to the year ended December 31, 2014 based on IFRS

The Group's overall increase in loss before tax for the year ended December 31, 2015 is primarily attributed to the significantly increased credit provisions and other impairment charges of EUR 4,263 million in 2015 compared to EUR 2,523 million in 2014, driven mainly by the political uncertainty and the resulting difficulties that the Greek economy faced during 2015 which has adversely affected the credit quality of our loan portfolio and real estate valuations.

Loss before tax in our retail banking segment for the year ended December 31, 2015 increased significantly to EUR 1,816 million from EUR 1,357 million. The increase in the loss before tax is mainly due to increased credit provisions which amounted to EUR 1,734 million for the year ended December 31, 2015 compared to EUR 1,287 million in 2014. On the other hand, costs were slightly improved to EUR 440 million in 2015 from EUR 456 in 2014, reflecting efforts of the Group for controlling costs and fully offsetting respective decrease in Net Interest Income which amounted to EUR 559 million for the year ended December 31, 2015 from EUR 573 million in 2014. The deleveraging of the retail portfolio also continued in 2015. The Bank continued its restructuring efforts relating to mortgages and consumer loans by introducing flexible terms in performing loans, such as interest-only periods, instalment ceilings, interest rate caps and extended loan maturities.

The loss before tax in our Corporate & Investment banking segment increased to EUR 1,005 million for the year ended December 31, 2015 from EUR 24 million in 2014. The increase is mainly attributable to the increase in credit provisions from EUR 686 million in 2014 to EUR 1,695 million in 2015, as a result of the political uncertainty and the resulting unfavourable macroeconomic conditions for the Greek economy. Net Interest Income has remained stable during the year ended December 31, 2015 and amounted to EUR 739 million compared to EUR 743 million for the year ended December 31, 2014. The Bank still retains its conservative approach to new commercial lending, with a

greater focus on healthy and larger corporate borrowers that it perceives to be lower-risk. Costs increased for the year ended December 31, 2015 by 10.6% amounting to EUR 52 million from EUR 47 million for the year ended December 31, 2014, reflecting efforts of the Group to continue to control costs over all its segments.

Loss before tax from global markets and asset management segment amounted to EUR 318 million in the year ended December 31, 2015, compared to EUR 159 million for the year ended December 31, 2014. This is mainly attributed to increased ELA funding cost during 2015 which on average amounted to 1.32% when compared to ECB funding used during 2014 with an average cost of 0.05%. This resulted in significantly decreased Net Interest Income which amounted to EUR 101 million in 2015 from EUR 189 million in 2014. Increased impairment charges from our asset management business relating mainly to the disposal of our private equity business which amounted to EUR 104 million for the year 2015 also contribute to the deteriorated performance on a year- on-year basis.

The profit before tax in our insurance segment was EUR 19 million in the year ended December 31, 2015 compared to EUR 65 million in the year ended December 31, 2014. The decrease is primarily attributed to the decrease in net interest income reflecting mainly lower yields of treasury bills and the decreased yields on floating rate instruments linked with Euribor. Additionally, one-off litigation claims of the particular segment have further deteriorated the insurance business annual performance.

Profit before tax in our International banking operations decreased to EUR 16 million in 2015, from profit before tax of EUR 46 million in 2014 mainly due to increased provision and other impairment charges. Credit provisions for the year ended December 31, 2015 amounted to EUR 147 million compared to EUR 121 million for the year ended December 31, 2014 despite the marginal reduction of +90dpd loans, thereby increasing our coverage ratio by 3.00 percentage points to 57.4% from 54.4% in 2014. The marginal increase in our Net interest income to EUR 332 million in 2015 from EUR 319 million in 2014, cannot offset the increased credit provision charges.

The business segment "Other" comprises proprietary real estate management, hotel and warehousing business, and other unallocated income and expenses of the Group. The loss before tax in this segment for the year ended December 31, 2015 amounted to EUR 485 million and to EUR 386 million for the year ended in December 31, 2014.

Segment analysis for year ended December 31, 2014 compared to the year ended December 31, 2013 based on IFRS

The Group's overall increase in loss before tax for the year ended December 31, 2014 primarily reflects the increase in credit provisions and other impairment charges of EUR 2,865 million compared to EUR 1,373 million for the year ended December 31, 2013 despite the reduced growth rate in +90 dpd during 2014.

Loss before tax in our retail banking segment for the year ended December 31, 2014, increased significantly to EUR 1,357 million compared to EUR 989 million for the year ended December 31, 2013. The increase in the loss before tax is due to the increase in credit provisions and other impairment charges which amounted to EUR 1,287 million for the year ended December 31, 2014 compared to EUR 796 million in 2013. On the other hand, costs excluding credit provisions and other impairment charges and depreciation and amortisation, were reduced by EUR 146 million as a result of cost containment policy by the large scale voluntary retirement scheme and the streamlining of the network by closing of 12 branches. The deleveraging of the retail portfolio also continued in 2014. The Bank continued its restructuring efforts relating to mortgages and consumer loans by introducing flexible terms in performing loans, such as interest-only periods, instalment ceilings, interest rate caps and extended loan maturities.

The loss before tax in our corporate and investment banking segment amounted to EUR 24 million in 2014 compared to profit before tax of EUR 269 million in 2013. The decrease is mainly attributable to the increase in credit provisions and other impairment charges from EUR 375 million in 2013 to EUR 694 million in 2014 which more than offset the increase in net interest income which increased from EUR 696 million in 2013 to EUR 743 million in 2014. The Bank still retains its conservative approach to new commercial lending, with a greater focus on healthy and larger corporate borrowers that it perceives to be lower-risk.

Loss before tax from global markets and asset management segment was EUR 160 million in the year ended December 31, 2014, compared to the profit before tax of EUR 256 million for the year ended December 31, 2013. This variation is mainly due to the release in 2013 of provisions taken in previous years of EUR 548 million against claims on the Hellenic Republic and losses on derivatives. In addition, Net Interest Income in 2014 was positively affected by reduced funding from ECB together with lower ECB rates (shift from ELA to ECB funding, thus reduced total cost of funding).

The profit before tax in our insurance segment was EUR 65 million in the year ended December 31, 2014 compared to EUR 110 million in the year ended December 31, 2013. The decrease was principally due to decreasing interest rates and time deposits balances for the year ended December 31, 2014 resulting in reduced interest income, which is partially compensated by increased Insurance result. The increased Insurance result was driven by the control of claims costs primarily in the Life and Motor lines of business, the effective management of the investments portfolio, the development and promotion of new products, the reinforcement of the sales network and the effective containment of operating expenses by developing synergies with the Bank. Furthermore the one-off impairment charge reversal on corporate debt securities resulted in EUR 14 million in allocated costs and provisions for the period ended December 31, 2013 compared to EUR 9 million for the year ended December 31, 2014.

Profit before tax in our International banking operations increased to EUR 45 million in 2014, from profit before tax of EUR 28 million in 2013, due to increased total income by EUR 18 million from EUR 404 million in 2013 to EUR 422 million in 2014. Credit provisions and other impairment charges increased to EUR 128 million in 2014, from EUR 114 million in 2013 despite the marginal reduction in the growth rate of +90 dpd, increasing the coverage ratio by 2.5 percentage points to 54.4%. Also, during the year ended December 31, 2014 a further decrease was achieved in costs excluding credit provisions and other impairment charges and depreciation and amortisation, which amounted to EUR 226 million, as compared to EUR 236 million for the year ended December 31, 2013.

The business segment "Other" comprises proprietary real estate management, hotel and warehousing business, and other unallocated income and expenses of the Group. The loss before tax in this segment for the year ended December 31, 2014 amounted to EUR 389 million which is in line with the previous year.

Currently, the Group's principal sources of liquidity are its deposit base, Eurosystem funding via the Main Refinancing Operations and the TLTROs with ECB as well as through ELA mechanism with

the Bank of Greece, repurchase agreements in the interbank market and long term debt, excluding liabilities directly associated with long-lived assets classified as held for sale and summarized as follows:

ECB funding is collateralized mainly by EFSF/ESM bonds received from HFSF, whereas ELA funding is collateralized mainly by notes issued by the Bank and guaranteed by the Hellenic Republic, in the context of the Bank's participation in the Hellenic Republic Bank Support Plan, as well as by Greek government bonds, treasury bills and loans. As at December 31, 2015, collateral with nominal value of EUR 12.9 billion (December 31, 2014: EUR 18.4 billion) was used for funding through the Eurosystem (see Note 19 to the U.S. GAAP Financial Statements for the analysis of instruments pledged).

As discussed in Item 5.A. "Operating Results—Results of operations for the year ended December 31, 2015 compared with the year ended December 31, 2014—Net Interest Income before provision for loan losses", the decrease in customer deposits during 2015 resulted in reliance in Eurosystem funding and more specifically the funding through ELA, thus giving rise to increased funding cost (see Item 4.E. "Selected Statistical Data—Liabilities—Deposits" for an analysis of our funding rates per type of deposit).

During the first half of 2015, the structure of the Bank's liquidity position has changed substantially. The reasons for this change were the economic turbulence and the uncertainty in the Greek banking sector that was caused by the ongoing negotiations between the Greek government and the Institutions. More specifically, the Bank faced significant deposit outflows of EUR 8.4 billion, as well as the cancellation of approximately EUR 3.6 billion of repurchase agreements with financial institutions. This in turn caused an increased dependence on Eurosystem funding and a commensurate deterioration of the Bank's counterbalancing capacity. Furthermore, ECB lifted the waiver based on which it accepted notes issued or guaranteed by the Hellenic Republic as collateral for repurchase agreements, which forced the Bank to cover its increasing funding shortfall through the ELA mechanism. At the height of the liquidity crisis, on June 29, 2015 due to the termination of the negotiations and ECB's decision to freeze the level of ELA, Greek authorities imposed capital controls, in order to prevent a widespread bank run and to preserve the sustainability of the Greek banking system. Moreover, on July 7, 2015, ECB raised the haircuts on the notes issued or guaranteed by the Hellenic Republic, which subsequently further lowered the Bank's buffer for ELA refinancing. In order to mitigate all the above developments, the Bank's Eurosystem funding increased in the first half of the year by EUR 13.3 billion and reached EUR 27.6 billion as at June 30, 2015. However, even at that point, the Bank retained adequate buffer of ELA eligible collateral, of around EUR 5.5 billion, in order to cover further outflows.

eligible collaterals by receiving an amount of EUR 2.7 billion of ESM bonds, under the Bond Loan Program (Item 4.A., "History and Development of the Company—2015 Recapitalization—Bank of Directors approval relating to the issuance of CoCos to the HFSF". Additionally, the Bank further reduced its liabilities through the LME Offers, by replacing a significant part of its long-term debt, except for the covered bonds, with equity. Finally, the Bank's liquidity profile was further strengthened by an increase of approximately EUR 1 billion in its customer deposits and by further deleveraging. In this context, on December 31, 2015, the ECB funding amounted to EUR 12.5 billion, while ELA funding was EUR 11.5 billion, amounting to a total exposure to the Eurosystem of EUR 24.0 billion, whereas the Bank's liquidity buffer amounted to EUR 8.4 billion. Furthermore, as at May 4, 2016, Eurosystem funding has decreased to EUR 22.1 billion, of which EUR 11.1 billion through ELA, while additional financial assets of an estimated cash value EUR 6.2 billion (cash value) were available for further liquidity, of which EUR 0.1 billion was collateral eligible for funding with the ECB and EUR 6.1 billion was collateral that could be posted in order to draw liquidity from ELA.

The Group's subsidiaries are mostly self-funded, except for Banca Romaneasca, which receives around EUR 450 million from the Bank, through interbank transactions.

Deposits decreased from EUR 72.1 billion on December 31, 2013 to EUR 66.1 billion on December 31, 2014 and increased to EUR 67.6 billion on December 31, 2015. Interbank deposits, including funding from the ECB and central banks, decreased from EUR 22.0 billion on December 31, 2013 to EUR 15.8 billion on December 31, 2014 and increased to EUR 24.8 billion on December 31, 2015. However, deposits excluding interbank funding (which includes funding from the ECB and central banks), increased from EUR 50.1 billion on December 31, 2013 to EUR 50.3 billion on December 31, 2014 and decreased to EUR 42.8 billion on December 31, 2015.

The following table provides a summary of our interest bearing interbank borrowing activity for each of the three years ended December 31, 2013, 2014 and 2015.

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, 2013, 2014 and 2015, as well as the period end balance for each of these quarters and the maximum balance at any month-end.

	Year ended December 31,

	2013		2014		2015
	(EUR in millions)
Average balance Q.1.		1,122		3,901		1,119
Period end balance Q.1.		1,954		4,244		121
Maximum balance Q.1.		1,954		4,244		637
Average balance Q.2.		1,521		4,037		151
Period end balance Q.2.		905		4,188		254
Maximum balance Q.2.		1,714		4,940		254
Average balance Q.3.		990		4,308		219
Period end balance Q.3.		1,273		3,833		199
Maximum balance Q.3.		1,273		4,942		267
Average balance Q.4.		2,173		3,849		129
Period end balance Q.4.		3,499		3,587		101
Maximum balance Q.4.		3,499		4,334		116

The following table provides a summary of our cash flows for each of the three years ended December 31, 2013, 2014 and 2015.

During 2015, compared to the corresponding period ended on December 31, 2014, our cash flows from investing activities switched from cash outflows of EUR 1,169 million in 2014 to cash inflows of EUR 429 million in 2015, mainly due to: a) the net cash inflows from our loan portfolio, which amounted to EUR 118 million, while in the corresponding period ended on December 31, 2014, there was a net cash outflow of EUR 2,114 million, because loan repayments exceeded new lending due to the decrease in domestic credit expansion, b) the net cash inflows from our investment securities, which amounted to EUR 191 million, while in the corresponding period ended on December 31, 2014, there was a net cash inflow of EUR 1,449 million, c) the cash inflows of EUR 252 million from the reduction of the Interest bearing deposits with banks, mainly in Greece and d) the cash inflows of EUR 85 million from the reduction of the Securities purchased under agreement to resell, mainly in Turkey. These cash inflows were netted off mainly with the net cash outflows of EUR 216 million for investments in premises both in Greece and Turkey, while in the corresponding period ended on December 31, 2014, the net cash outflows amounted to EUR 849 million.

Moreover, during 2015, compared to the corresponding period ended December 31, 2014, our cash flows from financing activities switched from cash inflows EUR 197 million in 2014 to cash outflows of EUR 1,052 million in 2015, mainly due to a) the repayment, mainly by the Bank, of EUR 3,488 million of Securities sold under agreements to repurchase, which cash outflow was funded by the cash inflows from the Eurosystem (see below), and b) the net cash outflows of EUR 1,130 million from the

borrowing of the Group of which amount of EUR 678 million was repaid in the context of the LME Offers, while in the corresponding period ended on December 31, 2014, there was a net cash inflow of EUR 1,771 million. These cash outflows were netted off with a) the Bank's net cash proceeds of EUR 1,421 million from common stock issuance while the corresponding amount in 2014 was EUR 2,426 million, and b) the net cash inflows of EUR 2,219 million from deposits which mainly consists of the increase by EUR 9,789 million of the Eurosystem funding and cash outflows of EUR 7,570 million from deposits.

During 2014, compared to the corresponding period ended on December 31, 2013, our cash inflows from investing activities switched from inflows of EUR 3,667 million in 2013 to outflows of EUR 1,169 million in 2014, mainly due to a) the net cash outflows in our loan portfolio of EUR 2,114 million due to credit expansion of our Turkish operations, b) the net cash outflows of EUR 849 million in 2014 due to significant investments of the Group in premises both in Greece and internationally by NBG Pangaea REIC and Finansbank and c) the net cash outflows from deposits with the central bank of EUR 129 million, although reduced from prior year which reached EUR 525 million. These cash outflows were netted off mainly with a) the net cash inflows from our AFS and held to maturity bond portfolio of EUR 1,449 million.

Moreover, during 2014, compared to the corresponding period ended December 31, 2013, our net cash outflows from financing activities switched from outflows of EUR 4.820 million in 2013 to inflows of EUR 197 million in 2014, mainly due to a) the Bank's net cash proceeds in 2014 of EUR 2,426 million from common stock issuance while the corresponding amount in 2013 was EUR 840 million, b) the net proceeds from issuance of long-term debt and other borrowed funds of EUR 3,734 million despite the increased repayment in the same period of long-term debt of EUR 1,963 million. These cash inflows were netted off with the net outflows in our deposits of EUR 4,084 million which mainly includes the repayment of Eurosystem funding of EUR 6,460 million.

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 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.

On November 6, 2015 the Bank, according to ECB's guidelines, submitted a capital plan to the SSM (the "Capital Plan"), targeted to addressing both the baseline capital shortfall as well as the additional needs arising from the adverse scenario as included in 2015 Comprehensive Assessment results (see Item 4.A., "History and Development of the Company—2015 Comprehensive Assessment). The Capital Plan, approved on November 13, 2015 (see Item 4.A., "History and Development of the Company—Capital Plan"), included the LME Offer completed on December 1, 2015 (see "—Sources of Capital and Liquidity—2015 Recapitalization—Liability Management Exercise ("LME") and mandatory conversion"), a share capital increase completed in December 2015 (see, "—Sources of Capital and Liquidity—2015 Recapitalization"), the 100% disposal of Finansbank (see Item 5, "Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic's Bank Support Plan—Discontinued operations") and the request for State Aid through the HFSF (which triggered mandatory

conversion of the Greek State Preference Shares, the US Preference Shares and other eligible liabilities) completed in December 2015.

Additionally, as a result of the Finansbank Transaction, our liquidity will improve from the agreed consideration by EUR 2,750 million and by USD 910 million from the repayment of subordinated debt that NBG has extended to Finansbank.

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. On December 31, 2012 the Group had EUR 5,464 million of Tier I capital and EUR 5,819 million of total capital.

The following table shows the EU capital adequacy ratios for the Group as at December 31, 2011 and 2012.

As at March 31, 2013, Act 13/28.03.2013 of the Executive Committee of the Bank of Greece established limits of 9% and 6% for CT1 and Common Equity, respectively. As at December 31, 2013, Act 36/23.12.2013 of the Executive Committee, removed the cap on the recognition of DTA up to 20% of the CT1.

The Group's capital adequacy ratios as at December 31, 2012 and 2013, according to above acts, are presented in the table below:

In June 2013, the European Parliament and the Council of Europe issued a new Directive 2013/36/EU and Regulation (EU) No 575/2013 (known as CRD IV), which incorporate the key amendments that have been proposed by the Basel Committee on Banking Supervision (known as Basel III). Directive 2013/36/EU has been transposed into Greek law by virtue of Greek Law 4261/5.5.2014 and Regulation (EU) no. 575/2013 has been directly applicable to all EU Member States since January 1, 2014, but some changes under CRD IV will be implemented gradually, mainly between 2014 and 2019. CRD IV revised the definition of regulatory capital and its components at each level.

The Group's capital adequacy ratios as at December 31, 2013, 2014 and 2015, according to EU Regulation 575/2013, are presented in the table below:

Article 27A of Greek Law 4172/2013, ("DTC Law"), allows, under certain conditions, credit institutions to convert Eligible Deferred Tax Asset ("Eligible DTAs") (under IFRS) to Tax Credits. Eligible DTAs may increase in future periods due to the recognition of unrecognized DTAs on accumulated provisions and other losses due to credit risk existing as at June 30, 2015. Eligible DTAs may also increase in future periods due to increases in applicable income tax rates. The main condition for the creation of Tax Credits is the existence of an accounting loss for a respective year, starting from accounting year 2016 and onwards, for which Tax Credits can be created in the following year, i.e., from 2017. The Tax Credits will be calculated as a ratio of IFRS accounting losses to net equity (excluding the year's losses), and such ratio will be applied to the remaining Eligible DTAs in a given year to calculate the Tax Credits that will be converted in that year, in respect of the prior tax year.

The Tax Credits shall be offset against the corporate income tax liability of credit institutions. In the event that the income tax liability is not sufficient to offset the Tax Credits available for such year in full, the remaining non-offsetable Tax Credits held by the relevant credit institution shall give rise to a direct repayment claim against the Hellenic Republic. From 2017 onwards, the relevant credit institution shall issue and deliver, for free, warrants to the Hellenic Republic (conversion rights), which can be converted into ordinary shares of the credit institution at a total market value equal to 100% of such Tax Credits as standing before the offset, at a market price equal to the weighted average market price over the 30 business days preceding the conversion (which 30-day period will take place preceding the Annual General Meeting usually held in May or June), and shall form a special reserve of an equal amount, solely for the purpose of its capitalization in the context of the share capital increase arising from the exercise of the relevant conversion rights. The warrants shall be freely transferrable, without prejudice to the call option of the common shareholders of the credit institution for the purchase of the warrants in proportion to their shareholding participation in the credit institution within a reasonable timeframe.

The submission to the special regime of article 27A of Greek law 4172/2013 is optional and is subject to the approval of the General Meeting of the Shareholders of the relevant credit institution, following special recommendation of its Board of Directors. Such resolution shall be notified to the competent tax and regulatory authority. Similarly, the same authorization is required for the Bank to opt out of the special regime of article 27A of Greek law 4172/2013, except that, in this case, a pre-approval by the competent regulatory authority is further required. On November 7, 2014 the Bank convened an extraordinary General Meeting of the Shareholders which resolved upon the Bank's submission to the DTC Law, the issuance of warrants to the Hellenic Republic and the formation of a special reserve.

A Cabinet Act shall be issued to address specific issues relating to the implementation of the aforementioned conversion mechanism, such as the monitoring and certification of the yearly non-offsetable Tax Credits, and its method of collection of payment, which would be either in cash or cash equivalents.

This legislation allows credit institutions to treat such DTAs as "not relying on future profitability" according to CRD IV, and as a result such DTAs are not deducted from CET1, hence improving their capital position.

As at December 31, 2015, the amount of DTAs (recognized in accordance with IFRS) that was eligible for conversion to a receivable from the Greek State subject to the DTC Law was EUR 4.9 billion.

Our capital management may also be affected by the BRRD, which has been transposed into Greek Law. (See Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Greek Regulatory Framework—Bank Recovery and Resolution Directive").

Pursuant to the provisions of the HFSF Law, in the event that a credit institution is faced with a capital shortfall that has been identified as such by the competent authority, the credit institution may request capital support from the HFSF up to the amount of the capital shortfall, subject to certain conditions. See Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Greek Regulatory Framework—The Hellenic Financial Stability Fund". The 2105 Recapitalization was effected as a precautionary recapitalization pursuant to article 32 paragraph 3(d) of the BRR Law.

The table below sets forth the credit ratings that have currently been assigned to the Bank by Moody's, Standard & Poor's Fitch and Dominion Bond Rating Service ("DBRS").

As at December 31, 2015, total assets were EUR 99.9 billion, a decrease of 7.7% from the Group's total assets of EUR 108.2 billion as at December 31, 2014, which in turn was a 1.2% increase from the Group's total assets of EUR 106.8 billion as at December 31, 2013. As at December 31, 2015, total assets excluding long-lived assets classified as held for sale were EUR 75.2 billion, a decrease of 4.7% from the Group's total assets of EUR 78.9 billion, as at December 31, 2014, which in turn was a 3.5% decrease from the Group's total assets of EUR 81.8 billion as at December 31, 2013. Deposits with the Central Bank, were EUR 1.1 billion in 2015, EUR 1.1 billion in 2014 and EUR 1.2 billion in 2013. Securities purchased under agreements to resell were EUR 10 million as at December 31, 2015, EUR 24 million as at December 31, 2014 and EUR 38 million as at December 31, 2013. Interest bearing deposits with banks were EUR 2.4 billion in 2015, EUR 2.7 billion in 2014 and EUR 3.2 billion in 2013. The Group's securities portfolio was EUR 18.0 billion as at December 31, 2015, EUR 15.0 billion as at December 31, 2014 and EUR 16.9 billion as at December 31, 2013.

The Group's loan portfolio decreased from EUR 57.7 billion at December 31, 2013 to EUR 56.1 billion at December 31, 2014 and decreased to EUR 55.0 billion at December 31, 2015. At December 31, 2015, the Group's loan portfolio accounted for 73.1% of total assets excluding long-lived assets classified as held for sale. Allowance for loan losses increased from EUR 7.1 billion in 2013 to EUR 8.8 billion in 2014 and to EUR 11.8 billion in 2015. See Item 4.E, "Selected Statistical Data—Assets—Loan Portfolio".

Deposits decreased from EUR 72.1 billion on December 31, 2013 to EUR 66.1 billion on December 31, 2014 and increased to EUR 67.6 billion on December 31, 2015. Of these, interbank funding, including funding from the ECB and central banks, decreased from EUR 22.0 billion in 2013 to EUR 15.8 billion in 2014 and then to EUR 24.8 billion in 2015.

For further discussion of Liquidity and Capital Resources, including the maturity profile, currency and interest rate structure of debt, see 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 2015 include mainly costs relating to reallocation of existing branches. Capital expenditure for the Group, excluding such interests in other companies, amounted to EUR 170 million in 2015. 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 8 million for the year ended December 31, 2015. See Item 4.A, "History and Development of the Company—Acquisitions, Capital Expenditures and Divestitures".

On November 23, 2012, the 2nd Repeat Extraordinary General Meeting of the Bank's shareholders approved (i) the reduction in the Bank's common stock through a reduction in the nominal value of the ordinary shares from EUR 5.00 to EUR 1.00 per share, as per article 4 para 4a of the Greek Company Law 2190/1920 as amended, with the formation of a special reserve of an equal amount, and (ii) the increase in the Bank's common stock with the issuance of new ordinary shares that will be subscribed in kind, that is, shares of Eurobank Ergasias S.A. ("Eurobank"), up to 552,948,427 ordinary voting shares of Eurobank, of nominal value EUR 2.22 per share. This common stock increase was covered exclusively by the shareholders of Eurobank, who accepted the tender offer, with abolition of the preemptive rights of existing shareholders. The Ministry of Development approved the above decision on February 12, 2013. This increase was partially covered (84.4%) through the contribution of 466,397,790 Eurobank shares.

At its meeting of February 22, 2013 the Bank's Board of Directors certified the increase, pursuant to partial coverage thereof. As a result the Bank's common stock increased by EUR 271 million by issuing 270,510,718 ordinary shares with nominal value of 1.00 Euro per share. The fair value of these shares issued as the consideration paid for Eurobank amounted to EUR 273 million and was based on the closing price of Bank's share on the ATHEX on February 15, 2013.

On April 29, 2013, in the context of the recapitalization, the 2nd Repeat Extraordinary General Meeting of the Bank's shareholders approved a) the reverse split of the ordinary shares at a ratio of 10 existing shares of EUR 1.00 per share to be exchanged for 1 new share of EUR 10.00 per share, b) the reduction in the nominal value from EUR 10.00 per share to EUR 0.30 per share as per article 4 Para 4a of the Greek Company Law 2190/1920 as amended, with the formation of a special

reserve of an equal amount and c) the common stock increase by EUR 9,756 million in the context of recapitalization of the Greek systemic banks.

On June 19 2013, the Board of Directors certified that EUR 1,079 million was covered by private investors in cash and EUR 8,677 million by HFSF through the EFSF bonds already advanced to the Bank in 2012 and the Bank issued 2,274,125,874 ordinary shares of EUR 0.30 per share.

From the amount of EUR 9,756 million, EUR 682 million was credited to the common stock whereas the remaining amount of EUR 9,074 million less expenses was credited to the additional paid-in capital.

On May 10, 2014, the Extraordinary General Meeting of the Bank's shareholders approved the common stock increase by EUR 2,500 million by issuing 1,136,363,637 ordinary shares of a par value of 0.30 Euro per share, through cancellation of the pre-emptive rights for existing shareholders, which was completed on May 13, 2014. The subscription price was set at 2.20 Euro per share as it was determined by the international book-building process outside Greece to institutional and other eligible investors.

On May 12, 2014, the Board of Directors certified that EUR 2,500 million was covered in cash. From the amount of EUR 2,500 million, EUR 341 million was credited to the common stock while the remaining EUR 2,159 million less expenses was credited to the additional paid-in capital.

In the context of the implementation of the Capital Plan (see Item 4.A, "History and Development of the Company—History and Development of the NBG Group—The Capital Plan"), on November 17, 2015, the Extraordinary General Meeting of the Bank's shareholders approved, among other matters:

On December 9, 2015 the Bank's Board of Directors confirmed that the total share capital increase was partially covered, in accordance with art. 13a of Greek Company Law 2190/1920, i.e. it was covered by EUR 2,192,372,169.30 through the issuance of 7,307,907,231 new shares. In the same meeting the Bank's Board of Directors further certified that the aforementioned partial coverage is divided as follows:

It should also be noted that due to the issuance of Cabinet Act no 45/7.12.2015 all of the Bank's preference shares were mandatorily converted (in accordance with the relevant provisions of article 6a of the HFSF Law) to 1,603,700,987 common shares of the Bank. More specifically, all the outstanding non-cumulative, non-voting, redeemable U.S. Preference Shares (i.e. 12,639,831) were converted into 298,700,987 ordinary shares and all the 270,000,000 outstanding Greek State Preference Shares issued in favor of the Hellenic Republic, in accordance with the Greek Law 3723/2008 were converted into 1,305,000,000 ordinary shares acquired by the HFSF by operation of law.

Following the above increases, the total number of ordinary shares as at December 31, 2015 and December 31, 2014 was 9,147,151,527 and 3,533,149,631 respectively, with a nominal value of EUR 0.30 per share.

On June 6, 2008, the Board of Directors of the Bank approved the issuance of 25 million non-cumulative non-voting redeemable U.S. 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). On May 31, 2013, the Bank announced an offer to purchase for cash 22,500,000 out of the 25,000,000 outstanding American Depositary Shares ("ADSs") at USD 12.50 per ADS upon the terms and subject to the conditions set forth in the offer to purchase. As at June 28, 2013, which was the expiration time of the Offer, 12,360,169 ADSs were validly tendered, representing approximately 49.4% of the ADSs outstanding at the expiration time. On July 3, 2013, the purchase of the 12,360,169 ADSs was settled by the Bank. The Bank cancelled the ADSs purchased pursuant to the Offer, and cancelled the U.S. Preference Shares represented thereby, following the completion of the requisite corporate approvals for cancellation of the U.S. Preference Shares.

As a result of Cabinet Act 45/07.12.2015 (see above), all the outstanding U.S. Preference Shares (i.e. 12,639,831) were converted into 298,700,987 ordinary shares.

On December 22, 2011, the Extraordinary General Meeting of the Bank's Shareholders approved: the common stock increase by EUR 1,000 million through the issue of additional 200,000,000 redeemable Greek State 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 government, in accordance with the Greek Law 3723/2008, and 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 70,000,000 redeemable Greek State Preference Shares in favor of the Greek government, in accordance with the Greek Law 3723/2008.

On December 30, 2011, following the above decision, the Bank issued the 200,000,000 redeemable Greek State Preference Shares at a nominal value of EUR 5.00 each in favor of the Greek government.

As a result of Cabinet Act 45/07.12.2015 (see above), all the 270,000,000 outstanding Greek State Preference Shares issued in favor of the Greek State, in accordance with the Law 3723/2008 were converted into 1,305,000,000 ordinary shares, which were received by the HFSF.

Therefore, following the above there are no under Greek Law 3723/2008 Greek State Preference Shares outstanding.

The Bank, through its VIE, has the following securitized notes in issue as at December 31, 2015:

Issuer	Description	Type of collateral	Issue date	Maturity date			Interest rate

Titlos Plc	Variable Rate Asset Backed Notes	Receivables from Public sector	February 26, 2009	September 2039	5,100	⁽²⁾	Paid semi-annually at a rate of six month Euribor plus 50 basis points
Spiti Plc	Asset Backed Variable Rate Notes—Class A	Residential mortgages	September 20, 2011	September 2058	1,500	⁽¹⁾⁽³⁾	Paid semi-annually at a rate of six month Euribor plus a margin of 200 basis points
Spiti Plc	Asset Backed Variable Rate Notes—Class B	Residential mortgages	September 20, 2011	September 2058	250	⁽¹⁾	Paid semi-annually at a rate of six month Euribor plus a margin of 400 basis points
Autokinito Plc	Asset Backed Variable Rate Notes—Class A	Auto loans	September 23, 2011	September 2023	400	⁽¹⁾⁽³⁾	Paid semi-annually at a rate of six month Euribor plus a margin of 200 basis points
Autokinito Plc	Asset Backed Variable Rate Notes—Class B	Auto loans	September 23, 2011	September 2023	97	⁽¹⁾⁽³⁾	Paid semi-annually at a rate of six month Euribor plus a margin of 350 basis points
Agorazo Plc	Asset Backed Variable Rate Notes—Class A	Consumer loans	September 23, 2011	September 2033	1,250	⁽¹⁾⁽⁴⁾	Paid semi-annually at a rate of six month Euribor plus a margin of 300 basis points
Agorazo Plc	Asset Backed Variable Rate Notes—Class B	Consumer loans	September 23, 2011	September 2033	413	⁽¹⁾	Paid semi-annually at a rate of six month Euribor plus a margin of 450 basis points

Under the covered bond Programs I and II, the Bank has the following covered bond series in issue as at December 31, 2015:

Program	Series number	Type of collateral	Issue date	Maturity date		Interest rate

Program I⁽¹⁾	3rd Series	Residential mortgage loans	October 7, 2009	October 2016	846	Paid annually at a fixed coupon rate of 3.875%
Program II⁽²⁾⁽³⁾	1st Series	Residential mortgage loans	June 24, 2010	June 2021	900	Paid quarterly at rate of three month Euribor plus a margin of 250 basis points
Program II⁽²⁾	2nd Series	Residential mortgage loans	June 24, 2010	June 2020	900	Paid quarterly at rate of three month Euribor plus a margin of 240 basis points
Program II⁽²⁾	3rd Series	Residential mortgage loans	June 24, 2010	June 2019	1,350	Paid quarterly at rate of three month Euribor plus a margin of 230 basis points
Program II⁽²⁾	4th Series	Residential mortgage loans	November 25, 2010	December 2018	850	Paid quarterly at rate of three month Euribor plus a margin of 210 basis points

Other than the third Series of Program I, all the above issues have not been sold to institutional investors, are held by the Bank and therefore are not presented within Note 24 to the U.S. GAAP Financial Statements.

Issuer	Type	Issue date	Maturity date	Currency				Interest rate

NBG	Variable Rate Notes	September 1, 2009	September 2016	EUR	95	⁽²⁾	—	Paid quarterly, Three-month Euribor plus 0.576%
NBG	Fixed rate covered bonds—3rd Series	October 7, 2009	October 2016	EUR	846	⁽¹⁾	4	Paid annually at a fixed coupon rate of 3.875%
NBG	Fixed Rate Notes	December 20, 2012	December 2024	EUR	45	⁽²⁾	—	Paid quarterly at fixed interest rate of 2.535%
NBG	Fixed Rate Notes	August 5, 2013	August 2023	EUR	45	⁽²⁾	—	Paid quarterly at fixed interest rate of 2.519%
NBG	Fixed Rate Notes	December 23, 2013	December 2023	EUR	66	⁽²⁾	—	Paid semi-annually at fixed interest rate of 2.68%
NBG	Fixed Rate Notes	January 29, 2014	January 2026	EUR	63	⁽²⁾	—	Paid semi-annually at fixed interest rate of 2.96%
NBG Pangaea REIC	Variable rate bond	August 20, 2014	July 2019	EUR	232		—	Paid quarterly Euribor plus 4.85%
NBG	Variable Rate Notes	December 29, 2014	December 2022	EUR	33	⁽¹⁾	—	Paid semi- annually Six-month Euribor plus 1.674%

As at December 31, 2015, the Bank participated in the Hellenic Republic Bank Support Plan of Greek Law 3723/2008 as follows:

Under the government-guaranteed borrowings facility, the Bank participated in the second pillar of Greek Law 3723/2008 "Hellenic Republic's Bank Support Plan" as follows:

Description	Issue date	Maturity date		Interest rate

Variable Rate Notes	May 2, 2013	May 3, 2016	4,500	Paid quarterly at a rate of three-month Euribor plus 1,200 basis points per annum
Variable Rate Notes	July 27, 2015	January 27, 2016	1,075	Paid semi-annually at a rate of six-month Euribor plus 800 basis points
Variable Rate Notes	October 19, 2015	January 19, 2016	1,500	Paid quarterly at a rate of three-month Euribor plus 800 basis points
Variable Rate Notes	October 19, 2015	April 19, 2016	2,600	Paid semi-annually at a rate of six-month Euribor plus 800 basis points

Total			9,675

Subsequent to December 31, 2015, under the same Pillar the Bank issued the following note:

Additionally, on April 15, 2016, under the same Pillar the Bank partially cancelled the following note:

The notes described above are held by the Bank and, therefore, are not presented as liabilities on the Consolidated Balance sheet.

On August 6, 2013, September 16, 2013 and July 17, 2014 the Bank received from Public Debt Management Agency, new three-year zero coupon special Greek Government bonds of EUR 787 million, EUR 60 million and EUR 1,262 million, respectively, collateralized with customer loans. These bonds can only be used as collateral for financing and therefore are reflected in off-balance sheet items.

On March 30, 2016, the Bank cancelled the aforementioned notes under Pillar III.

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 on 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 on Banking Supervision, the EBA and the Bank of Greece (jointly the Single Supervisory Mechanism—"SSM") and the HCMC, as well as any decisions of the competent authorities supervising the Group's entities (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece").

The Group's risk governance framework comprises a number of different constituents. In particular, the Board of Directors has established the Board Risk Committee ("BRC") overseeing all risk management functions across the Group. All risk management units report to the GRCAD and to the Group Market and Operational Risk Management Division ("GMORMD"), which are supervised by the Group Chief Risk Officer (the "CRO"). Separate compliance functions, namely the Group Compliance and Corporate Governance Division and the Group Regulatory Supervision of Banking Activities Division, oversee all internal and external compliance matters, such as applicable Greek and EU laws and regulations. The Internal Audit—Inspection Division,of the Bank and the Group, 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 BRC forms and submits for approval to the Board of Directors the risk appetite 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 risk management and monitors the implementation and outcome of these policies.

Since December 19, 2013 the BRC has been composed exclusively of non-executive Board members, at least three in number, of which the majority (including the Chairman) are independent members of the Board, in accordance with the definition of independence specified in the Bank's Corporate Governance Code. The members and the Chairman of the Committee are elected by the Board of the Bank, following recommendation by the Board's Corporate Governance and Nominations Committee.

The BRC 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 risk strategy and the business plan of the Group. The proposals to the BRC are submitted by the CRO. For a further description of the BRC and a list of its current members, see Item 6.C, "Board Practices—Board Committees".

The Bank acknowledges the need for enhanced risk management and has established two specialized units, the GRCAD and the 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.

Each Division has distinct responsibilities and covers specific types of risk. The GRCAD consists of:

Both Divisions report to the Assistant General Manager for Group Risk Management ("CRO").

During 2013, the Senior Executive Committee decided to reform the architecture of the management level risk committees of the Bank, by providing its approval for the establishment (as committees of the Group Board) of the New Product Committee and the Compliance and Reputational Risk Committee.

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 ALCO sets the general guidelines for asset and liability management. ALCO determines the Bank's and Group'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 at least once a month and comprise the CEO, the Deputy CEOs and the General Managers of the Bank involved in the asset allocation and risk management 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.



Chairman	Leonidas Fragkiadakis*	CEO
Deputy Chairman and Member	Paul Mylonas	Deputy CEO
Member	Dimitrios Dimopoulos	Deputy CEO
Member	Nelly Tzakou-Lambropoulou	General Manager of Retail Banking
Member	Ioannis Kyriakopoulos	General Manager, Group CFO
Member	Alexander Benos	Assistant General Manager, Group Risk Management, CRO
Member	Vasileios Kavalos	Assistant General Manager, Group Treasurer

The Committee is convened at the invitation of its Chairman, once per month and ad hoc as deemed necessary. The Chairman can invite other executives of the Bank and Group to attend, if necessary.

The Chairman can invite other executives of the Bank and Group, to attend, if necessary.

The Committee members do not receive any remuneration for their participation in the Committee.

NBG Group's Internal Audit is an independent function, whose objective is to provide assurance and consulting services, designed to add value by making feasible and cost effective recommendations

that improve the Group's operational effectiveness. Internal Audit contributes to the achievement of corporate objectives by (a) bringing a systematic, disciplined approach to the evaluation of the effectiveness of the corporate governance framework, risk management and internal controls, (b) recommending appropriate measures to minimize risk and improve the efficiency and effectiveness of the policies and procedures of the Group's Units, and (c) monitoring the implementation of corrective actions agreed by management.

Group Internal Audit Division (GIAD) is administratively independent from other Bank and Group units. The Chief Audit Executive is assigned and discharged by the Bank's Board of Directors, on the recommendation of the Audit Committee and the Bank's CEO. Any appointment, dismissal or replacement of the Chief Audit Executive is communicated to the Bank of Greece. The Group Chief Audit Executive reports functionally, through the Audit Committee, to the Bank's Board of Directors and administratively, directly to the CEO.

According to the GIAD's Charter, which has been approved by the Bank's Board of Directors, GIAD is authorized to operate at Group level and to coordinate and supervise the activities of the internal audit units (IAUs) of the Group subsidiaries. Since 2010, the Bank's GIAD has undertaken the Internal Audit activities of key domestic subsidiaries, aiming to improve quality of service and achieve economies of scale.

Bank's GIAD is periodically assessed by qualified external evaluators in relation to the IIA's international best practices.

In June 2014, the Board of Directors approved the amendment of GIAD's Charter, incorporating in it, the updated Basel Guidelines and IIA standards.

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 between incoming and outgoing payments, taking into account unexpected delays in repayments (term liquidity risk) or unexpectedly high outflows (withdrawal/call risk). Liquidity risk involves both the risk of unexpected increases in the cost of funding of the portfolio of assets at appropriate maturities and rates, and the risk of being unable to liquidate a position in a timely manner and on reasonable terms.

The Bank's executive and senior management have the responsibility to implement the liquidity risk strategy approved by the Board Risk Committee ("BRC") and to develop 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 informed on a daily basis about current liquidity risk exposures ensuring that the Group's liquidity risk profile stays within approved levels. In addition, management receives, a liquidity report, on a daily basis, which presents a detailed analysis of the Group's funding sources and counterbalancing capacity. Moreover, the Asset Liability Committee ("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.

Since liquidity risk management seeks to ensure that the respective risk of the Group is measured properly and is maintained within acceptable levels then, even under adverse conditions, the Group must have access to funds necessary to cover customer needs, maturing liabilities and other capital needs, while simultaneously maintaining the appropriate counterbalancing capacity to ensure the above. In addition to the Bank's liquidity pool, the rest of the Group's subsidiaries maintain a ratio of available funds through repurchase agreements over total deposits at a minimum level of 9%.

For a discussion on the principal sources of liquidity of the Bank and the Group's subsidiaries, see above "Liquidity Management".

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 amortised 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 by those denominated in EUR and those denominated in other currencies for the Group under U.S. GAAP on December 31, 2013, 2014 and 2015. As described above, at the end of any day, the open currency position ("OCP") has to comply with the limits set by the Treasury Division and the GMORMD. Compliance is achieved by entering

into appropriate offsetting positions. Consequently, the net exposure to each foreign currency is maintained at low levels and within the pre-approved limits.

	Year ended December 31,

	2013									2014									2015
	EUR			Other Currency			Total			EUR			Other Currency			Total			EUR			Other Currency			Total
	(in millions)
Assets:
Cash and due from banks		990			353			1,343			1,604			503			2,107			887			549			1,436
Deposits with central bank		833			371			1,204			724			341			1,065			844			215			1,059
Securities purchased under agreements to resell		36			2			38			1			23			24			6			4			10
Interest bearing deposits with banks		2,950			290			3,240			2,365			346			2,711			1,816			616			2,432
Trading assets		2,732			276			3,008			2,146			240			2,386			2,164			320			2,484
Derivative assets		2,381			206			2,587			4,581			215			4,796			3,691			204			3,895
Available-for-sale securities, at fair value		3,820			660			4,480			2,606			713			3,319			5,611			616			6,227
Held to maturity securities		9,376						9,376			9,337						9,337			9,292			—			9,292
Equity method investments		63			9			72			70			10			80			25			11			36
Loans		51,557			6,107			57,664			49,624			6,444			56,068			48,474			6,522			54,996
Less: Allowance for loan losses		(6,801	)		(336	)		(7,137	)		(8,290	)		(502	)		(8,792	)		(10,908	)		(867	)		(11,775	)

Net loans		44,756			5,771			50,527			41,334			5,942			47,276			37,566			5,655			43,221
Goodwill, software and other intangibles		406			31			437			398			29			427			137			18			155
Premises and equipment		1,124			115			1,239			1,509			114			1,623			1,315			118			1,433
Accrued interest receivable		532			48			580			487			49			536			439			37			476
Other assets		3,511			116			3,627			2,913			275			3,188			2,840			177			3,017

Total assets excluding long-lived assets classified as held for sale		73,510			8,248			81,758			70,075			8,800			78,875			66,633			8,540			75,173

	Year ended December 31,

	2013						2014						2015
	EUR		Other Currency		Total		EUR		Other Currency		Total		EUR		Other Currency		Total
	(in millions)
Liabilities:
Total deposits		64,243		7,893		72,136		58,173		7,933		66,106		60,757		6,807		67,564
Securities sold under agreements to repurchase		3,437		62		3,499		3,545		42		3,587		46		55		101
Other borrowed funds						—		6				6		3		—		3
Accounts payable, accrued expenses, derivative and other liabilities		4,959		635		5,594		8,051		622		8,673		6,610		604		7,214
Long-term debt		1,421		39		1,460		2,354		31		2,385		1,577		19		1,596
Insurance reserves		2,494		10		2,504		2,244		4		2,248		2,090		4		2,094
Contigently convertible debt		—		—		—		—		—		—		2,040		—		2,040

Total liabilities excluding liabilities directly associated with long-lived assets classified as held for sale		76,554		8,639		85,193		74,373		8,632		83,005		73,123		7,489		80,612

We have not engaged in any significant research and development activities during any of the last three financial years.

For the financial year ended December 31, 2015, 79.0% of our net interest income before provision for loan losses and as at December 31, 2015, 87.0% of our loans, were derived from our domestic operations. In addition, our holdings of EUR 3.2 billion of Greek government bonds and Greek treasury bills represented, as at December 31, 2015, 4.3% of our total assets excluding long-lived assets classified as held for sale and 18.4% of our trading and investment debt securities. Accordingly, our financial condition and our results of operations are heavily dependent on macroeconomic and political conditions prevailing in Greece. Additionally, as we are in the process of disposing of our Turkish operations (see Item 3.D., "Risk factors—The sale of Finansbank pursuant to the Revised Restructuring Plan will result in the loss of a business which has historically represented a significant portion of our consolidated operations and profit"), our future operations will be less diversified and our remaining operations will have a significantly greater exposure to Greece as a percentage of our overall business.

Greece has been receiving financial support from the euro area member States and the IMF to cope with financial difficulties and economic challenges, since May 2010. See "—Private Sector Initiative (PSI) for Greek Government Debt restructuring and effort for Economic Stabilization and in the context of financial Support Programs" below. The extremely intensive fiscal adjustment on the back of a significant increase in tax burden and broad-based government spending cuts in a very limited time period, in conjunction with uncertainty and structural deficiencies of the economy, translated in into a deep and protracted recession which has been accompanied by a sharp drop in Greek financial and real asset valuations. The progress in fiscal consolidation, the gradual recovery in economic sentiment and the easing in fiscal pressure ultimately led to a moderate pick up in economic activity in 2014, which was the first year with positive GDP growth since 2007 (Source: EL.STAT, Quarterly National Accounts Press Release, February 2015). However uncertainty started to build up since the third quarter of 2014 when there were increasing signs of difficulties in reaching an agreement with official creditors on the completion of the pending review of the Second Program of financial support which was followed by the holding of early elections in January 2015.

Uncertainty has been on an upward trend and macroeconomic conditions deteriorated in the first half of 2015, following protracted negotiations between the new Greek Government (elected on January 25, 2015) and official creditors on the continuation of, or transition to, a new program of financial support. Rising domestic liquidity constraints and the absence of external financing to the Hellenic Republic amplified uncertainty over the Greek Government's ability to meet its domestic obligations, including sizeable upcoming repayments on both official (IMF and ECB) and marketable debt in the period June–August 2015. Uncertainty peaked in late-June 2015, when an agreement with the official lenders had still not been reached and, as a result, the Program expired and a referendum called in the relation to the conditions underlying the agreement on the activation of a new program of financial support.

Financial markets, pushed Greek Government bond yields into "credit event" territory in late-June and early-July when the Greek governments delayed the repayment of maturing debt to the IMF (EUR 1.5 billion to the IMF on June 30, which was subsequently cleared) and the absence of sufficient external financing. Accordingly, the Governing Council of the ECB decided to maintain the ELA ceiling for the Greek banking sector unchanged (at the June 26, level) (Source: ECB, Press Release, June 28, 2015), effectively inhibiting any additional access by Greek banks to the Eurosystem financing in a period of accelerating deposit withdrawals.

In response to the fear of an outright bank run the Greek government imposed a "bank holiday" on June 29, 2015 that lasted until July 20, and applied specific restrictions on banking and other financial transactions of Greek citizens and legal entities (jointly referred to as "capital controls" (Source: Bank of Greece, Act of Legislation, June 28, 2015)), with a view to protecting financial and macroeconomic stability. Moreover, in view of the severe economic and financial disturbance that appeared to threaten the continued membership of the Hellenic Republic in the European Monetary Union and the EU, the Greek government officially requested financial assistance from the European Union on July 10, 2015 (Source: European Commission's proposal for a council implementing decision on granting short term European Union financial assistance to Greece under a new program from the ESM). A Third Program was subsequently agreed with its creditors in August 2015, in order to restore the sustainability of public finances and to continue participating in the Eurozone and Greece pledged to implement an ambitious program of structural and fiscal reforms. The Eurogroup on July 16, 2015 (Source: Eurogroup statement, July 16, 2015) on the basis of a positive assessment by the Institutions decided to grant "in principle" a three-year ESM-based program of financial support to Greece.

The challenges relating to the state of Greek public finances (compounded by high uncertainty, declining demand, weakening private sector balance sheets, protracted capital flight, increasing risk premium and credit downgrades) have affected the liquidity and profitability of the financial system in the Hellenic Republic in 2015 and have resulted in:

As a consequence of the preceding developments, the Bank has experienced higher costs of funding (in particular in the first half of 2015, relative to the comparable period in 2014), increased provisions for loan losses and increasing level of past due loans.

Private Sector Initiative (PSI) for Greek Government Debt restructuring and effort for Economic Stabilization and in the context of financial Support Programs

A private sector initiative for Greek debt restructuring took place in February 2012 due to the insufficiency of the first intensive round of fiscal adjustment achieved under the First Program of financial support (Source: IMF Country Report No. 10/110, May 2010) to bring the Greek sovereign debt to a sustainable level. The completion of the PSI in April 2012 contributed to a significant reduction of the Greek debt burden and debt servicing needs through lower interest rates on the bonds issued as part of an exchange process and a substantial extension of the average debt maturity and deferral of a significant part of the effective debt servicing costs on loans provided by the EU and the EFSF.

A commitment to a future intervention of the official sector with a view to improving the public debt sustainability was decided by the Eurogroup of November 27, 2012 (Source: Eurogroup Statement on Greece, November 27, 2012). This intervention, inter alia includes debt repurchases by the Hellenic Republic, new changes in official loan conditions (interest rate reduction on bilateral loans and deferral of interest payments on EFSF loans) and a refund to Greece of income and profits related to Eurosystem holdings of Greek bonds. For more details see section below "Eurogroup decisions of November 27, 2012 on the disbursement of pending financing for 2012 under the Second Program, the coverage of medium-term funding gap and the provision of additional sovereign debt relief".

In March 2012, following the effective completion of the sovereign debt restructuring, the Government agreed to a second economic adjustment program, jointly supported by the IMF and the member states of the Eurozone (the "Second Program"), the term of which extended through 2016 and which was jointly supported by the IMF and Eurozone Member States. The Second Program replaced the original program of EUR 110 billion, agreed in May 2010, for the period of 2010–2013 in the form of a cooperative package of IMF and Eurozone Member State funding. The international assistance loans disbursed under the original program amounted to EUR 72.8 billion. Of this amount, EUR 52.9 billion was sourced from Eurozone Member States and EUR 19.9 billion from the IMF.

The adjustment process also contemplated the successful completion of an ambitious privatization agenda. Similarly, the structural reform agenda included measures to increase fiscal efficiency, strengthen Greece's institutional capacity and improve efficiency of the labor, product and service markets.

Eurogroup decisions of November 27, 2012 (Source: Eurogroup Statement on Greece, November 27, 2012) on the disbursement of pending financing for 2012 under the Second Program, the coverage of medium-term funding gap and the provision of additional sovereign debt relief.

On November 27, 2012, the Eurogroup's finance ministers and the IMF Managing Director provisionally agreed to disburse EUR 43.7 billion of the pending EU tranches (for 2012) of the Second Program for Greece and agreed to offer Greece some additional debt relief with a view to counteracting the adverse impact of sharper-than-expected macroeconomic conditions and the slower build-up of a primary surplus of 4.5% of GDP (estimated according to updated program assumptions to be achieved in 2016 or two years later than envisaged in the original program of economic support for Greece). The agreement involved a combination of additional measures to reduce the debt servicing burden and related funding needs of the Hellenic Republic including: interest rate cuts on bilateral loans; a 10-year interest payments deferral on EFSF loans; and refund to Greece of ECB/national central banks' profits on Greek bond holdings. These measures aimed at providing sufficient liquidity to the Government to fully cover the funding gap until mid-2014—following the use of about EUR 10 billion of funding for the financing of the repurchase by the Hellenic Republic of its own debt securities in December 2012 (Source: IMF Country Report No. 13/20, January 2013). In this context, the deadline for the achievement of a primary surplus of 4.5% of GDP was extended from 2014 to 2016.

In addition, a debt buyback was introduced as part of the debt-reduction strategy, resulting in a reduction in Greek government debt of EUR 21.1 billion in net terms. The PSI and the debt-buyback were the key building blocks of the Greek sovereign debt reduction strategy in conjunction with the official creditors' commitment in the Eurogroup of November 27, 2012 to provide additional debt relief to the Greek State which has been conditioned on the progress in program implementation and the achievement of the respective fiscal targets. These developments provided a considerable boost to the economic sentiment (Source: European Commission, Indicators of confidence and economic sentiment, October 2014) and have been accompanied by a gradual improvement in economic conditions in 2013 and most part of the first half of 2014 (when the economy showed positive annual economic growth of +0.7% year-over-year in full year 2014, Source: EL.STAT, Quarterly National Accounts Press Release, February 2015).

However, by the end of the second quarter of 2014 significant delays occurred in the completion of the pending since mid-2014, second program review, attributed to delays in implementation of structural reform and fatigue in fiscal adjustment effort (Source: Ministry of Finance, General Government Monthly Data, December 2014), which inhibited the disbursement of related financing of up to EUR 7.2 billion according to the original funding plan. The unsuccessful conclusion of the Presidential Election—ahead of the termination of the President's term in March 2015—led to a snap Parliamentary election on January 25, 2015 which resulted in the formation of a new coalition government with a stable parliamentary majority.

On December 8, 2014, (Source: Eurogroup statement, December 8, 2014), the Eurogroup agreed to withhold the disbursements due under the Second Program of financial support of the Hellenic Republic and announced a "technical extension" of this program to end February 2015 of the EU side of the Second Program, initially set to be completed by the end of 2014.

On February 20, 2015, the Eurogroup agreed to a four-month extension of the Master Financial Assistance Facility Agreement ("MFFA") underpinning the Second Program (Source: Eurogroup statement, 20 February 2015). Pursuant to the agreement to extend the MFFA, the Greek government presented a list of new reform proposals, which had been planned to be discussed with official creditors and agreed with the Institutions by the end of April 2015, with a view to set the groundwork for policy conditionality which could support a further extension of the existing program or related to the

transition to a new program of financial support. However, the agreement with the Institutions was not finalized and the pending review of the financial assistance program was not completed by June 2015. This resulted in further weakening of economic sentiment and intensifying financing shortages for the Hellenic Republic. Rising liquidity constraints and the absence of any external financing amplified uncertainty over the Greek government's ability to meet its domestic obligations as well as upcoming repayments on both official and marketable debt in the period June–August 2015.

The Greek government called a referendum on June 26, 2015 which took place on July 5, 2015, in which Greek citizens voted not to accept a set conditionality terms imposed by lenders for extending a new financing agreement. On June 30, 2015, the MFFA and the Second Program, which had already been extended twice, expired without an agreement on a follow-up program. As a result, Greece had to forfeit access to the remaining EUR 12.7 billion of available funding through the EFSF (including the remaining EUR 10.9 billion buffer earmarked for bank resolution and recapitalization) (Source: EFSF Statement, June 30, 2015). Consequently, Greece did not repay EUR 1.5 billion in payments due to the IMF on June 30, 2015 and the IMF's Executive Board declared that Greece was in arrears with the fund (Source: IMF, Press Release, June 30, 2015).

In response to escalating Greek sovereign risk the ECB Governing Council decided to maintain the ELA ceiling for the Greek banking sector at an unchanged level of approximately EUR 89 billion (since June 26, 2015, Source: ECB, Press Release, June 28, 2015), limiting any additional access of Greek banks to ELA financing in a period of extremely high cash withdrawals from Greek banks (Source: Bank of Greece, Monthly Balance Sheet, June 2015). Against this backdrop, confidence in the banking system evaporated, leading to the decision for the imposition of a bank holiday on June 28, 2015. Although the bank holiday terminated on July 19, 2015, the capital controls remain in place. See Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—Capital Controls applying to banks operating in Greece".

In view of the severe economic and financial disturbance that appeared to threaten the continued membership of the Hellenic Republic in the European Monetary Union and the EU, the Greek government officially requested financial assistance from the European Union on July 10, 2015 (Source: European Commission's proposal for a council implementation decision on granting short term European Union financial assistance to Greece under a new program from the ESM), with a view to restoring confidence and enabling the return of the economy to sustainable growth, and safeguarding the country's financial stability. The Greek government submitted a draft proposal of the new economic and financial adjustment program to the European Commission and the Council on July 14, 2015. The Eurogroup on July 16, 2015 (Source: Eurogroup statement, July 16, 2015) on the basis of a positive assessment by the Institutions decided to grant "in principle" a three-year ESM stability support to Greece.

On August 19, 2015—and following the Eurogroup Statement of August 14, 2015 (Source: Eurogroup statement, August 14, 2015)—the Board of Governors of the ESM approved the proposal for a Financial Assistance Facility Agreement (FFA, Source: ESM Statement, August 19, 2015) with Greece, and adopted a Memorandum of Understanding with Greece (Source: European Commission, August 19, 2015). The MoU and FFA together constitute the "Third Program" and specify the relevant deliverables that must be successfully implemented and on which the total amount of financial assistance will depend.

On August 20, 2015, the first sub-tranche of EUR 13 billion of the Third Program was disbursed to cover budget financing and debt servicing needs of the Hellenic Republic, EUR 10 billion in ESM notes were made immediately available for bank recapitalization and resolution purposes but have not been used until October 2015 and another EUR 3 billion are planned to be disbursed (in two sub-tranches) by November 2015 following the completion of a set of prior actions (Source: ESM

Statement, August 20, 2015). The preliminary agreement in July 2015 and eventual activation of the Third Program on August 19, 2015, was intended to secure Greece's solvency until 2018 (Source: European Commission, August 19, 2015).

The Third Program aims to achieve sustainable fiscal consolidation and promote key structural reforms—predominantly designed by the Greek Government—that enhance Greece's long-term growth potential and promote social cohesion. The program is accompanied by a new financial assistance agreement that provides financing of up to EUR 86 billion to cover the external financing needs of the Hellenic Republic until 2015—including potential State contribution to bank recapitalization, if needed. The disbursement of this financing is conditional on periodic reviews of Greece's progress in implementing agreed measures and reforms. As of the date of this Annual Report, the participation of the IMF in the funding relating to the Third Program is not known. The financing of up to EUR 86 billion is only indicative, and may be significantly lower if bank recapitalization funding from the Third Program resources is significantly lower than anticipated at the time the agreement on the Third Program. In this respect the comprehensive assessment of Greek systemic banks released on 30 October 2015 identified a system-wide shortfall of EUR 4.4 billion in the baseline scenario and EUR 14.4 billion in the adverse scenario of the stress test. The official sector has participated in the recapitalization through the HFSF with only EUR 5.4 billion—compared with a total financing that has been earmarked of up to EUR 25 billion under the Greek financial support program—with the participation of private investors limiting further the use of earmarked program funding. Accordingly the funding need of the Greek Program for the period 2016–2018 are limited to below EUR 70 billion compared to the initial estimate of EUR 86 billion (Source: ESM, December 2015).

The prospective deterioration in macroeconomic conditions in 2015 and 2016 due to higher uncertainty, the further pressure on liquidity conditions from the capital flight and the imposition of capital controls, were taken into account in designing the fiscal adjustment strategy. The planned fiscal adjustment path under the new program is more gradual compared to the previous program, with the targeted annual improvement in primary balance of the general government budget set at 0.75% of GDP in 2016, 1.25% in 2017, and 1.75% in 2018 that correspond to primary surplus levels of 0.5% of GDP in 2016, 1.75% in 2017 and 3.5% of GDP in 2018 and beyond (Source: Memorandum of Understanding, August 19, 2015). In this regard, the recessionary impact of the program in 2016–2018 is expected to be milder than in the previous two programs (Source: National Bank of Greece ("NBG"), Economic analysis estimates, Greece Macro View, October 2015). However, delays in the implementation of measures planned to be implemented since January 2016, and a potential frontloading of the fiscal adjustment effort, which is going to be agreed with the official creditors for the period 2016–2018 in the context of the ongoing first review of the new program could lead to further recessionary pressures, especially in the first semester of 2016.

The fiscal adjustment strategy is planned to be achieved primarily through a combination of upfront fiscal reforms and new interventions in the pension system. The cornerstones of the adjustment on the revenue side are: a) an effective increase of about 2% in the effective VAT rate through the transition of almost one-fifth of goods and services to the higher VAT rate of 23% (since July 20, 2015) and b) parametric and qualitative changes in 2016 of the tax system that involve an increase personal income tax progressivity, reforms in the taxation of farmers, self-employed, corporates and other sources of non-wage income and sustainable gains in tax efficiency. Most of these measures are planned to be fully implemented in 2016. Government revenue is also expected to be supported by structural fiscal reforms aimed at strengthening tax compliance and fighting tax evasion by capitalizing on the increasing technical capabilities for verifying wealth profiles and income flows.

New savings from further interventions on the pension system correspond to a core aspect of the fiscal strategy for 2016–18 with a view to ensuring the medium-to-longer term sustainability of the

social security system and minimizing near-term financing gaps of social security entities through additional parametric changes in conjunction with measures to increase the efficiency and the incentives structure provided by the system. In this respect, the Third Program also outlines a new round of changes in the pension system, primarily focusing on the complete implementation of provisions of the relevant laws of 2010–2011 and new amendments focusing on minimizing the impact of remaining exemptions, increasing disincentives for early retirement and further rationalizing wage replacement ratios for new retirees. These changes aim at minimizing fiscal pressures and improving the efficiency and long-term viability of the system.

Moreover, a fiscal council is planned to be established and become fully operational in 2016 which will, inter alia, be responsible for suggesting the imposition of automatic breaks in government spending (Source: Euro Summit Statement, July 12, 2015).

Safeguarding financial stability is one of the four pillars under the Third Program, acknowledging the critical role that a stable and sound banking system must play during the recovery process. The 2015 Comprehensive Assessment was finalized on 30 October 2015 specifying the additional capital needs of systemically significant Greek banks at EUR 4.4 billion in the baseline scenario and EUR 14.4 billion in the adverse scenario of the stress test. In turn, the banks undertook capital raising exercises during the fourth quarter of 2015, with the recapitalization process completed by the end of 2015 (Source: ESM Statement, December 8, 2015).

Moreover, a comprehensive strategy for addressing non-performing loans and related changes in the legal framework is planned to be finalized in 2016, permitting banks to cope more effectively with problematic loans, protect the weakest income groups and, at the same time, release vital financial resources to finance the economy during the recovery process. Finally, a number of measures intended to improve the governance of the HFSF and the Greek banks have been legislated and are expected to be implemented during the first half of 2016.

Structural reforms in labor, product and services markets to enhance competitiveness and growth and sustainable progress in privatization strategy

The third pillar of the Third Program focuses on a number of wide ranging reforms in labour and product markets to enhance competitiveness along with the growth-enhancing implications of the ambitious privatization strategy. In recent years, major changes have been made to Greek labor market institutions and wage bargaining systems to make the labor market more flexible and efficient. On this basis, the Greek authorities have announced their commitment to launching a consultation process to review a number of existing labor market frameworks, including collective dismissal, industrial action and collective bargaining, taking into account best practices internationally and in Europe. Furthermore, an integrated action plan is scheduled to be adopted by mid-2016, to fight undeclared and under-declared work in order to strengthen the competitiveness of legal companies and protect workers, as well as raise tax and social security revenue.

The Greek government authorities also intend to improve public administration and judicial system efficiency. The latter aims at effective implementation of the new Code of Civil Procedure (adopted in July 2015), rationalization of court fees and implementation of measures to reduce the backlog of cases in administrative and civil courts.

The Greek Government has also committed to facilitate the privatization process and complete all needed Government actions to allow tenders to be successfully executed. In line with the statement of the Euro Summit of July 12, 2015, a new independent fund will be established and have in its possession Greek assets to be privatized. The "overarching objective of the fund is to manage valuable Greek assets; and to protect, create and ultimately maximize their value which it will monetize through privatizations and other means" (Source: Memorandum of Understanding, August 19, 2015). The

privatizations fund would be established in Greece and be managed by the Greek authorities under the supervision of the relevant European institutions and is expected to fulfill its objective by adhering to international best practices in terms of governance, oversight and transparency of reporting standards, and compliance.

For risks relating to the Hellenic Republic economic crisis and the impact it may have on the Bank, see Item 3.D. "Risk Factors—Recessionary pressure and uncertainty resulting from the Hellenic Republic's economic crisis have had and may continue to have an adverse impact on our business, results of operations and financial condition" and "—Deteriorating asset valuations resulting from poor market conditions may adversely affect our business, results of operations and financial condition and may limit our ability to post collateral for funding purposes from Eurosystem".

Greek depositors (especially households) withdrew more than EUR 50 billion of bank deposits between November 2014 and June 2015 (of which EUR 32 billion were household deposits, EUR 5.2 billion were general government deposits and around EUR 4.0 billion non-resident deposits), with withdrawals peaking in late-June 2015 when the standstill in negotiations had become evident. The cumulative reduction in the banking system's deposit base of EUR 52.7 billion between end-November 2014 and July 2015 and the loss of access to private funding markets were covered by a net increase in Eurosystem financing (including the ELA) of EUR 80.4 billion in the same period. Total dependence peaked at EUR 126.6 billion in June 2015, of which EUR 86.8 billion corresponded to ELA.

However due to the further deterioration liquidity conditions in the Greek banking sector, the non-timely servicing of a maturing loan to the IMF and the termination of the Second Program on June 30 2015, without agreement on a new program, the ECB Governing Council decided to maintain the ELA ceiling for the Greek banking sector unchanged at around 89 billion (at the June 26 level) effectively inhibiting any additional access by Greek banks to the Eurosystem financing in a period of accelerating deposit withdrawals (especially in cash form).

Against this backdrop, the Greek Government imposed a "bank holiday" on June 28, 2015 that lasted until July 19, 2015, and applied specific restrictions on banking and other financial transactions of Greek citizens and legal entities (jointly referred to as "capital controls").

Accordingly, liquidity tensions eased somewhat in the second half of 2015, permitting a reduction in Greek banks' Eurosystem reliance by EUR 19.1 billion, to EUR 107.5 billion in December 2015 (Source: Bank of Greece, Monthly Balance Sheet, December 2015), despite the concurrent loosening of capital controls on enterprises, through higher approvals at the respective committees. Eurosystem funding declined further to EUR 104.2 billion in February 2016 (Source: Bank of Greece, Monthly Balance Sheet, February 2016).

Although the Third Program is being implemented, as noted above, macroeconomic conditions remain challenging due to the intensification of fiscal adjustment effort, the slow improvement in liquidity conditions and the lagged impact of uncertainty and the capital controls on private sector spending decisions. Moreover, the fiscal drag is expected to increase in the second quarter of 2016 due to the implementation of the new fiscal measures negotiated with official creditors for completing the pending review of the financial support program.

The Greek economy has proved resilient in 2015, to a combination of several adverse factors that included: i) heightened uncertainty related to prolonged negotiations with official lenders; ii) an intensifying liquidity squeeze of the public and private sector due to significant external financing shortages and capital flight, which have been compounded by a revival of Grexit scenarios in the

second quarter of 2015 and iii) the imposition of capital controls since June 29, and the announcement of snap elections in September 2015.

In this very challenging environment, economic activity expanded by 0.6% in the first half of 2015 and contracted by –1.2% in the second half of 2015, with full year contraction of real GDP of –0.3% (Source: EL.STAT., Quarterly National Accounts Press Release, February 2016),) following the imposition of capital controls and the three week bank holiday in July 2015. This resilience reflected, to a significant extent, the fact that capital controls had been anticipated by Greek households and firms, permitting them to pre-emptively draw up contingency plans to cushion their near-term impact (i.e., about EUR 41 billion of domestic private sector deposits had been withdrawn between November 2014 and June 2015 (Source: Bank of Greece, Bulletin of Conjunctural Indicators, January–February 2016)). Furthermore, it reflected the advanced stage of economic rebalancing in Greece following a painful multi-year economic adjustment, which made it far more resilient to external shocks. Moreover, the upsurge in cashless transactions (an almost 100% increase in terms of value, Source: Hellenic banks Association data) following the imposition of capital controls, has also supported official economic activity—mainly private consumption—prompting a shift of activity from the shadow to the official economy. This shift reflected an increase in demand for goods and services provided by business entities operating in the official economy, in conjunction with increasing compliance by a number of firms formerly operating in the shadow economy, and included a shift in activity to larger enterprises, to the detriment of SMEs. The progress in loosening of capital control restrictions for businesses since August 2015 has ameliorated their negative impact, especially for medium-to-large sized enterprises (Source: NBG, Greece Macro View, October 2015 and February 2016).

Private consumption increased by 0.3%, in 2015 (Source: EL.STAT., Quarterly National Accounts Press Release, February 2016), based primarily on the continued improvement of labor market conditions (annual employment growth of 2.0% in 2015, (Source: EL.STAT., Labour Force Survey Press Release, March 2016) and the positive impact of lower cost imports (mainly low oil prices) on households' disposable income, while tourism showed strong momentum (average annual increase of 6.0% (Source: Bank of Greece, Bulletin of Conjunctural Indicators, January–February 2016), directly and indirectly supporting economic activity. The decline in oil prices (–36.4% year-over-year, in euro terms, Source: Federal Reserve Economic Data) have also supported activity by driving domestic energy prices to lower levels (–13.9% year-over-year, Source: Bank of Greece, Bulletin of Conjunctural Indicators, January–February 2016) and, thus, supporting private sector's disposable income, while tourism activity remained solid with arrivals increasing by 7.1% year-over-year in 2015, and revenue by 6.0% in 2015 (Source: Bank of Greece, Bulletin of Conjunctural Indicators, January–February 2016).

Fixed capital formation increased by 0.9% in 2015 (Source: EL.STAT., Quarterly National Accounts Press Release, February 2016), mainly supported by the resilient momentum of business investment in the first half of 2015 and higher public investment in the fourth quarter of 2015. Downside pressures on investment emerged in the second half of the year, mainly due to lagged effects of uncertainty, and a very slow improvement in liquidity conditions (Source: EL.STAT., Quarterly National Accounts Press Release, February 2016). Business investment increased by 3.3% year-over-year, in 2015, whereas residential construction decreased by 23.3% year-over-year in 2015; however, both business investment and residential construction weakened in the second half of 2015 (–0.7% year-over-year and –26.3% year-over-year, respectively, in the second half of 2015, Source: EL.STAT., Quarterly National Accounts Press Release, February 2016). House price valuations dropped by 5.1% in the full year 2015 compared with 4.5% in the first half of 2015 (Source: Bank of Greece, Bulletin of Conjunctural Indicators, January–February 2016), with a sizeable supply of unsold houses weighing further on valuations. Labor market trends remained positive in 2015, with employment expanding by 2.0% year-over-year and unemployment declining to a three and a half-year low of 24.0% in December 2015 from 24.9% in June 2015 and 25.9% in January 2015) (Source: EL.STAT., Labor Force Survey Press Release, March 2016).

Nonetheless, increasing fiscal pressure from the back-loaded structure of tax obligations in the second half of 2015 and the new fiscal measures implemented in this period, as well as, in the first half of 2016 are estimated to weigh on private consumption, investment and labor market conditions in the first half of 2016 (Source: NBG, Greece Macro View, February 2016, European Commission Spring Forecasts, May 2016). In this context the prospective agreement on the completion of the pending first review of the Third Program is conditioned on the legislation and implementation of additional fiscal measures sufficient to lead the economy to a sustainable surplus in government budget by 2018, sufficient large to support the long-term reduction of the debt.

Fiscal trends showed a notable improvement in the second half of 2015, following a stressed first half of 2015, along with a decline in uncertainty and the imposition of new fiscal measures in July 2015. The State budget primary balance over performed compared with the revised targets for 2015 (included in the 2016 Government Budget) by 1.5% of GDP (excluding the impact of ECB's Securities markets program and Agreement on Net Financial Assets revenue) supported by a pick-up in revenue in the second half of 2015 (an increase in tax revenue of +3.7% year-over-year in the second half of 2015 (Source: Ministry of Finance, State Budget Execution, Monthly Bulletin, June 2015 and December 2015) and further spending restraint. According to European Commission estimates, this over performance appears sufficient to meet the Government Budget 2016 estimates for a small primary deficit of 0.3% in 2015 budget (Source: European Commission, Autumn Forecasts, October 2015), despite the accumulation of new arrears of EUR 1.6 billion in the private sector in 2015 (Source: Ministry of Finance, General Government Monthly Bulletin, December 2015). State Budget continues to over perform in the first two months of 2016, with primary balance exceeding target by EUR 2.0 billion (Source: Ministry of Finance, State Budget Execution, Monthly Bulletin, February 2016). The debt-to-GDP ratio is estimated by the European Commission to reach 179% in 2015 and peak at 185% in 2016 (Source: European Commission, Winter Forecasts, February 2016). These figures are lower than estimates contained in the preliminary debt sustainability analysis ("DSA") published in July (Source: IMF, Greece: Preliminary Draft Debt Sustainability Analysis, June 26, 2015), since the actual costs of bank recapitalization were only EUR 5.4 billion versus an earmarked envelope of EUR 25 billion (Source: European Stability Mechanism "ESM", Press Releases, December 1, 2015 and December 8, 2015).

The Greek banking system remained in deleveraging mode with the pace of annual contraction in lending to private sector accelerating moderately in the second half of 2015 to 2.0% year-over-year in December, with loans to households contracting by 3.1% year-over-year (compared with a decline of total credit to private sector of 1.7% year-over-year in June 2015). Corporate credit declined by 1.2% year-over-year in December 2015 compared with –0.7% year-over-year in June 2015 (Source: Bank of Greece, Bulletin of Conjunctural Indicators, January–February 2016). Bank credit to the domestic private sector, June 2015 and December 2015). Credit growth to private sector weakened further in the first two months of 2016 (–2.3% year-on-year), mainly due to deterioration in credit to non-financial corporations (–1.6% year-on-year), while the contraction in credit to households slowed down to –2.9% year-on year in February 2016 vs. –3.1% in December 2015 (Source: Bank of Greece, Press Release, Bank credit to the domestic private sector, February 2016).

Uncertainty remained high for the most part of the year and started to subside, gradually, following the official activation of the Third financial support program and the disbursement of related funding in August 2015, in conjunction with the resolution of political uncertainty following the timely formation of a new coalition government in September 2015. However, risks surrounding the financial environment effectively lasted until the fourth quarter of 2015, when the conclusion of the Greek banks comprehensive assessment and the timely completion of the recapitalization contributed to a gradual restoration of confidence in the Greek banking system. In this challenging environment, the cumulative withdrawals of bank deposits reached EUR 47.6 billion during the first seven months of 2015 (Source: Bank of Greece, Bulletin of Conjunctural Indicators, January–February 2016) and a significant deterioration in the valuations of government bonds occurred, with the yield of the 10-year Greek

government bond peaking at 19.2% in early July 2015 (Source: Bloomberg database). The liquidity gap from deposit outflows and the closing of market financing has been offset by an increase in funding that banks raised from the Eurosystem (including ELA), which increased by EUR 51.5 billion, since the beginning of 2015, reaching a peak of EUR 126.6 billion, in late-June 2015 (Source: Bank of Greece, Monthly Balance Sheet, June 2015 and December 2016).

After the imposition of restrictions to the movement of capital from June 28, 2015 and especially the finalization of the country's new financial support agreement on July 13, 2015, pressures on deposits and the bond market subsided, with deposits showing marginal recovery by EUR 1.2 billion in August–December 2015 (Source: Bank of Greece, Bulletin of Conjunctural Indicators, January–February 2016). The average yield on the 10-year Greek government bond declined to 8.5%, in August–December 2015, from 12.7%,in June–July 2015 (Source: Bloomberg database). In addition, interest rates on new time deposits fell to 1.0% in December 2015, from 1.8% in June 2015 and 1.8% in December 2014.

The pace of deleveraging showed a mild acceleration with the credit growth rate of the private sector contracting by –2.0% in December 2015, from –1.7% in June 2015 and –3.1% in December 2014 (Source: Bank of Greece, Bulletin of Conjunctural Indicators, January–February 2016). Total bank deposits have stabilized since the imposition of capital controls in July 2015 and increased by EUR 1.2 billion, cumulatively, until December 2015, supported by a normalization in government spending, which had been partly transmitted to the private sector, inflows of EU funds and favorable seasonal factors. However, total bank deposits remain EUR 46.4 billion lower than their level of December 2014 (Source: Bank of Greece, Bulletin of Conjunctural Indicators, January–February 2016) and continued to decline in the first two months of 2016 by EUR 2.1 billion (Source: Bank of Greece, Statistics database). Accordingly, the Greek banking system's financing from the Eurosystem decreased to EUR 107.5 billion in December 2015 and by EUR 19.1 billion cumulatively since June 2015, with ELA dependence contracting by EUR 17.9 billion, in this period (Source: Bank of Greece, Monthly Balance Sheet, June 2015 and December 2015) and decreases further by EUR 0.9 billion in January–February 2016 (Source: Bank of Greece, Monthly Balance Sheet, February 2016).

Following the agreement and legislation of two additional sets of prior actions, the Greek government received another EUR 3 billion related to the first Program installment, in two sub-tranches in November and December 2015. (Source: ESM Statements, November 23, December 22, 2015). This funding has been used to cover external debt servicing needs and contributed to a normalization of government spending and to the clearance of about EUR 0.5 billion of Government arrears to the domestic private sector (Source: Ministry of Finance, December 2015).

The Eurogroup of May 9, 2016, welcomed the completion of a policy package comprised of 3 per cent of GDP of new fiscal measures (including pension and personal income tax reforms, source: Eurogroup Statement on Greece, May 9, 2016), which was a key precondition for the completion of the first review of the Third Program, and requested the legislation and implementation of an additional set of agreed prior actions by end-May 2016 for ensuring a successful conclusion of the pending review. These additional actions include:

Upon full implementation of the prior actions by the Greek authorities and following national procedures where necessary, the "Eurogroup stands ready to support the disbursement of the second tranche of the ESM programme" amounting to EUR 5.7 billion in June 2016 and/or early in the third quarter of 2016. The disbursed funding could be significantly higher from the above amount if includes program funding earmarked for the clearance of government arrears that amounts to, approximately, EUR 5.0 billion until June 2016.

The Eurogroup also stated in the same meeting that it stands ready to consider, if necessary, "possible additional debt measures aiming at ensuring that Greece's refinancing needs are kept at sustainable levels in the long-run. These measures will be conditional upon full implementation of measures agreed in the context of the Third Program, and will be considered after the completion of the first review, once all prior actions have been fully implemented" (Eurogroup Statement on Greece, May 9, 2016). In this context, the Eurogroup on the following general guiding principles for the possible additional debt measures: (a) facilitating market access; (b) smoothing the repayment profile; (c) incentivizing the country's adjustment process even after the program ends; and (d) flexibility to accommodate uncertain GDP growth and interest rate developments in the future.

The Eurogroup also agreed to establish a benchmark for assessing sustainability of the Greek debt, based on gross financing needs related to the debt servicing costs of the Hellenic Republic. The Eurogroup statement foresees a sequenced approach, whereby a package of debt measures could be phased in progressively, as necessary to meet the agreed benchmark on gross financing needs and subject to the pre-defined conditionality of the ESM programme. The Eurogroup reconfirms that nominal haircuts are excluded, and that all measures taken will be in line with existing EU law and the ESM and EFSF legal frameworks. In this context of this strategy, euro area counties are going to consider:

Looking forward, the better than officially expected GDP outcome in 2015 (deflated GDP contraction of 0.3% compared to official estimates made in the third quarter 2015 for a recession of 2.3%, Sources: EL.STAT., Quarterly National Accounts Press Release, February 2016 and European Commission, Debt Sustainability Analysis, July 2015, respectively), and the continuing improvement in business survey data until early 2016 set the stage for a milder recession in 2016 (European Commission revised its annual GDP growth forecast to –0.3% in May 2016, from –1.3% in November 2015, Sources: European Commission, Spring 2016 Forecast, May 2016 and European Commission, Autumn Forecast, November 2015, respectively). The frontloaded intensification of the

fiscal effort with a new set of measures being under negotiation with official lenders for the achievement of the fiscal targets of the period 2016–2018 is likely to exert additional downward pressures on economic activity as exemplified by the decline in consumer confidence to a 30 month low in March 2016 (Source: European Commission, Business and Consumer Survey results, March 2016). The increasing probability of a successful completion of the first review of the Third Program following the significant progress made in the Eurogroup of May, could provide and significant confidence boost which in conjunction with the disbursement of significant amounts of funding could reduce downside pressures on activity and pave the way for positive GDP growth in the second half of 2016 (Source: European Commission, Spring Forecasts, May 2016).

In this environment, the contraction of bank credit to private sector is expected to continue, while deposits are expected to recover very gradually under the direct and implicit constraints of capital controls.

In 2016, economic activity in Greece will continue to be affected, at least in the first half of the year, by the downside pressures on growth from the GDP contraction in the second half of 2015, and the additional fiscal drag from the implementation of new fiscal measures to support the achievement of a targeted primary surplus in Government budget (Source: Ministry of Finance, State Budget 2016, November 2015). Moreover the slow improvement of liquidity conditions is expected to weigh on activity in most part of 2016. Accordingly, GDP is estimated to decline further (–0.3% year-over-year in 2016, in constant prices, Source: European Commission, Spring Forecast, May 2016) with the economy returning in positive growth in the second half of 2016 supported by: i) lower energy prices; ii) improving sentiment compared to the previous year; iii) positive tourism and export trends, iv) a gradual normalization of liquidity conditions (reflecting, inter alia, a gradual clearance of government arrears), v) supportive base effects and vi) a prospective further easing of capital controls.

The timely completion of the pending first review of the Program for Greece, in the first months of 2016 is expected to allow the release of more than EUR 5 billion of official funding and contribute to sustainable recovery in economic sentiment and a faster improvement in liquidity conditions especially if supported by a reinstatement of the ECB waiver on Greece's financial assets and, eventually, the eligibility in the ECB's quantitative easing. Accordingly, a significant delay in the completion of the review which could be seen as a step backwards following the significant progress made in the Eurogroup of May 9, 2016 could give rise to negative confidence and liquidity effects, delay the relaxation of capital controls and exert additional downward pressures on collateral valuations and ultimately create debt servicing tensions for the Hellenic Republic and the private sector, and impose significant downside risks for economic activity.

Overall, capital controls and restrictions on cash transactions in Greece are expected to affect domestic demand and small business activity in the near term, but the recessionary impact is expected to be mitigated by a prospective reduction in uncertainty and gradual normalization of liquidity conditions (Source: European Commission, Spring Forecast, May 2016). See also Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—Capital Controls applying to banks operating in Greece".

Capital controls and constraints on cash withdrawals in Greece have created downward pressures on economic activity albeit less severe than initially expected, contributed to an increase of cashless transactions (higher use of credit, debit cards and electronic money transfers which registered an increase of 80% year-over-year in the second half of 2015, according to estimates of the Hellenic Banks Association) and stabilized bank deposits (Source: Bank of Greece Bulletin of conjunctural indicators, February 2016). The negative impact on domestic demand from the three-week bank holiday in July

and restrictive limits on financial transactions has been partially offset by the pre-emptive adjustment of the business sector (liquidity and inventory hoarding since the first half of 2015) and the near-doubling in the use of cashless payments in economy-wide transactions. Moreover falling energy prices and a strong tourism season (increase in tourism revenue of 6.0% year-over-year in 2015 or 0.5% of GDP annualized excluding second round effects, Source: Bank of Greece, Bulletin of Conjunctural Indicators, January–February 2016) also absorbed a considerable part of the recessionary shock due to uncertainty and the capital controls. The progress in program implementation in the second half of 2015 has been accompanied by the disbursement of EUR 3 billion of program funding in October–November which contributed to a mild improvement in liquidity conditions and contributed into a considerable rebound in business sentiment.

The Macroeconomic Environment and the Banking Services Sector in South Eastern Europe-5 ("SEE-5", comprising Albania, Bulgaria, FYROM, Romania, and Serbia)⁽⁸⁾

The performance of the economies and banking sectors of SEE-5 improved across the board in 2015.

Economic activity gained momentum, inflation retreated, fiscal deficit receded, external adjustment continued, and banking sector profitability strengthened.

Real GDP growth is estimated to have accelerated to a seven-year high of 3.2% in 2015 from 2.1% a year earlier, despite a tighter fiscal stance (the fiscal deficit narrowed to 2.2% of GDP in 2015 from 3.0% a year earlier). The acceleration was supported by private consumption and, to a lesser extent, by fixed investment. Stronger real disposable income, reflecting, inter alia, improving labor market conditions and weaker inflation (down to –0.4% year-on-year in 2015 from 0.6% a year earlier) along with favorable global oil prices boosted private consumption, while better absorption of EU funds, especially in Romania and Bulgaria, strengthened further investments.

Despite the rebound in domestic private demand, the current account deficit remained at 1.6% of GDP for the third successive year in 2015, well below the pre-crisis all-time high and unsustainable level of 15.0% of GDP. In fact, a offset the negative impact of increasing prices of non-energy related-imports on the current account. Encouragingly, the quality of financing of the current account deficit remains sound, with non-debt generating foreign direct investments more than covering the current account deficit for the third year in a row in 2015 (172.9%).

Amid a favourable operating environment, the fundamentals and the performance of the SEE-5 banking sector improved significantly in 2015. Indeed, the 2015 net profit of the sector stood at an estimated multi-year high of EUR 2.0 billion reversing the loss of EUR 0.5 billion a year earlier; underpinned by lower provisions for bad loans, in line with the moderation of the ratio of problematic loans to total gross loans (ranging between 11.7% in FYROM and 22.0% in Serbia at end-September 2015 versus 11.3% in FYROM and 22.8% in Albania at end-2014). Moreover, the capital adequacy ratio strengthened (ranging between 15.8% in Albania and 22.5% in Bulgaria at end-September 2015 versus 15.7% in FYROM and 21.9% in Bulgaria at end-2014), supporting an expectation of loan growth in lending activity in the near future, in view of the region's low lending penetration (loan-to-GDP ratios in SEE-5 ranged between 31.3% and 60.8% at end-2015), especially in the retail segment (retail lending-to-GDP ratios in SEE-5 ranged between 10.7% and 21.6% at end-2015) and adequate liquidity ratios (the SEE-5 average loan-to-deposit ratio eased to 90.0% at end-2015 from 96.0% at end-2014, after having remained above the 100% threshold for eight years).

The macroeconomic outlook and the performance of the banking sector is expected to improve further in SEE-5 in 2016.

Real GDP is expected to expand at a faster pace, on the back of stronger domestic demand, supported inter alia by improving labour market conditions, an expansionary fiscal policy, favourable global commodity prices, and a buoyant credit activity.

There are, however, downside risks to the SEE-5 positive outlook, stemming from renewed political uncertainty and policy slippage, mainly due to a heavy election calendar in 2016 (in Romania: local elections (June) and legislative elections (December); in Bulgaria: presidential elections (October); in Serbia: local elections and legislative elections (April); and in FYROM: legislative elections (June)) and weaker-than-expected economic activity in the region's main trading partner—the euro area.

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 the 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 26 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 arrangements, whose contract amounts represent credit risk, as at December 31, 2014 and 2015:

Our contractual obligations as at December 31, 2015, can be summarized as follows:

The information disclosed in the table does not include the CoCos which are perpetual. Further, discontinued operations and liabilities directly associated with long lived assets held for sale are not included in the table because the related obligations will not be settled by the Group in accordance with their contractual maturities, due to their planned disposal.

Derivative liabilities were not included to this table because it was not reasonably possible to determine the contractual undiscounted cash flows by segregating cash receipts from cash outflows.

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 current legislation and regulatory framework, including the provisions of the Amended Relationship Framework Agreement between the Bank and the HFSF and the obligations of the Bank towards the Monitoring Trustee.

The members of the Board of Directors are elected by the Bank's General Meeting of the Shareholders for a term that cannot exceed three years and shall end at the ordinary General Meeting of the Shareholders of the year in which such term expires. All members can be re-elected. The General Meeting of the Shareholders determines each time the exact number of the members of the Board of Directors, within the range prescribed by the applicable framework and the Bank's by-laws (must always be an odd number) and its independent members.

A representative of the Hellenic Republic, and an HFSF Representative also participate in the Bank's Board of Directors, in line with Greek Laws 3723/2008 and 3864/2010 respectively, as in force. Additionally, as prescribed by the Amended Relationship Framework Agreement between the Bank and the HFSF, a further HFSF Observer (without voting rights) was appointed to the Board of Directors of the Bank and all its committees. (see Item 4.B., "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic's Bank Support Plan").

Additionally, given the participation of the International Finance Corporation ("IFC") and the European Bank for Reconstruction and Development ("EBRD") in the 2015 Recapitalization, the IFC holds 66,666,667 shares of the Bank, (0.7% of our total share capital) and the EBRD holds 166,666,666 shares, (1.8% of our total share capital), and the Bank has signed an agreement with each of IFC and EBRD which grants each the right to propose a candidate Board member, which may be elected to sit on the Board, subject to applicable law, the Bank's relevant internal policies and shareholders' approval.

The Corporate Governance Code specifically defines the minimum number of executive, as well as independent and non- executive directors (see Item 10.B, "Memorandum and Articles of Association" and Item 16.E, "Purchases of equity securities by the issuer and affiliated purchasers").

The Board of Directors' members can be removed at any time by the General Meeting. In the event that a member ceases to participate in the Board of Directors, due to resignation, disease or having forfeited for whatever reason, and in case its replacement by deputy members, that have potentially been elected by the General Meeting is impossible, the rest of the members may either provisionally elect another member to cover the unoccupied seat for the period of time that remains until the replaced member's term of office ends, or may continue to manage and represent the Bank without replacing the missing Director(s), provided that the number of the remaining Directors shall remain within the range prescribed by the applicable framework and the Bank's by-laws. In the event that a new Director is provisionally elected, the election shall be valid for the remaining term of office of the Director replaced and is announced by the Board of Directors at the immediately following General Meeting, which may replace the Directors even if no relevant item is included on the agenda. Under all circumstances, the remaining Directors, irrespective of number, may call a General Meeting solely for electing a new Board.

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 one or more Vice Chairman(en) and Deputy Chief Executive Officer(s). In accordance with the applicable regulatory framework and best practices in corporate governance, the Bank distinguishes the role of the Chairman from that of the Chief Executive Officer.

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 convenes as prescribed by the Greek legislation, the Bank's Articles of Association and Corporate Governance Code, as well as according to the provisions of the Amended Relationship Framework Agreement between the Bank and the HFSF and the obligations of the Bank towards the Monitoring Trustee. The Board is convened (a) by the Chairman, upon invitation send by the Board of Directors Secretary to the Board members at least three business days before the meeting. The invitation must clearly specify the items on the agenda, otherwise decisions cannot be reached unless all members of the Board of Directors' are present or represented at the meeting and no member objects to decision-making or (b) by the Chairman upon request by two members, within seven days from the submission of the request, which should clearly specify the agenda of the Board meeting requested or (c) by the Chairman upon request of the HFSF representative within seven days

from the submission of the request to the Chairman. In case the Board of Directors Chairman does not proceed with convocation of the Board upon request of two members or the HFSF representative within the above deadline, then the two members or the HFSF representative respectively are able to convene the Board within five days from expiry of the above deadline of seven days. The invitation shall be notified to all Directors and to the HFSF observer.

Any Director may request that the Chairman include one or more items on the agenda of the next Board meeting. Two or more Directors may require that the Chairman include one or more items on the agenda of the next Board meeting. The HFSF representative also has the right to include items on the agenda and, to that end, must send to the Chairman of the Board of Directors in writing, the proposed/additional items at least two business days prior to the date of the Board meeting. The Chairman of the Board must include those items on the agenda of the scheduled Board meeting.

The Board of Directors forms a quorum and validly deliberates when one half plus one of the Directors are present or represented, but under no circumstances may the number of Directors present be less than five. The Articles of Association describe in detail the requirements of Directors' representations for valid resolutions adoption.

In the context of further enhancing the efficient operation of the Board of Directors, in 2015 the Bank proceeded with the implementation of a special Board Secretariat system to further support operation of the Board of Directors. The use of this system is expected to enhance procedures for providing Board members with appropriate information and notifications, and facilitate exchange of opinions and commenting on issues placed under consideration of the Board of Directors and Board Committees and better monitoring of issues discussed by the Board of Directors and its Committees.

Pursuant to Greek Law 3723/2008 and the HFSF Law, both as in force, as well as according to the Amended Relationship Framework Agreement entered into with the HFSF, the representatives of the Hellenic Republic and the HFSF may, inter alia, veto the decision making process of the Board of Directors in relation to dividend allocation and remuneration of the Chairman of the Board of Directors and Board members, the Chief Executive Officer, the Deputy Chief Executive Officers as

well as the General Managers and their substitutes. (See Item 4.B., "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic's Bank Support Plan" for further information on the powers of the representative of the Hellenic Republic under the Hellenic Republic Support Plan and Item 4.B., "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Financial Stability Fund—The Greek Recapitalization Framework—Provision of Capital Support by HFSF—Powers of the HFSF" for the HFSF's powers).

The Bank's Board is supported by five Board Committees, which have been established and operate for this purpose, namely the Strategy Committee, the Board Risk Committee, the Audit Committee, the Corporate Governance and Nominations Committee, and the Human Resources and Remuneration Committee. (See Item 6.C., "Board Practices—Board Committees").

The nomination procedure and the qualification criteria for Directors are specifically provided for in the Bank's internal corporate governance rules and in particular: a) the Bank's Articles of Association, b) the NBG Corporate Governance Code, c) the Board's Corporate Governance and Nomination Committee Charter and d) 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 line with the provisions of the Bank's Articles of Association, the General Meeting of the Shareholders is the sole corporate body vested with the authority to elect the members of the Board of Directors, as well as to determine the independent non-executive members. Exceptionally, the provisions of para. 3 of Article 18 of the Bank's Articles of Association and para. 7 of Article 18 of the Greek Company Law 2190/1920, in the event that as a result of resignation, death or forfeiture for whatever reason a Director ceases to be on the Board 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 within the range prescribed by the applicable framework.

Based on agreements the Bank has in place with the International Finance Corporation and the European Bank for Reconstruction of Development, following the participation of the two organizations in the Bank's share capital increase completed in December 2015, which remain in force while shares of the Bank are held by the two organizations, each organization is entitled to propose a candidate Director, which may be elected to sit on the Board, subject to applicable law, the Bank's relevant internal policies and shareholders' approval.

According to the Bank's Corporate Governance Code, the Board of Directors, assisted by the Board of Directors' Corporate Governance and Nomination Committee, proposes to the General Meeting candidate Directors on the basis of the Nomination Policy which requires them to meet the "fit and proper" criteria and not have any systematic conflict of interest with the Bank. It is not necessary for the Board of Directors to submit a separate proposal for the positions of Chairman of the Board and Chief Executive Officer.

Following the election of the new members of the Board of Directors by the General Meeting of the Shareholders, the Board of Directors in its first meeting elects its Chairman and the Chief Executive Officer who manages the Bank, by absolute majority among its members. According to the Bank's Corporate Governance Code, the Bank distinguishes the role of the Chairman of the Board and the role of the Chief Executive Officer. Moreover, the Board of Directors has the authority to elect Vice Chairman (men) and Deputy Chief Executive Officer(s).

In selecting and proposing to the General Meeting of the Shareholders potential members of the Board, or in appointing new members in replacement of members who for whatever reason cease to be on the Board, the Board shall endeavor to propose candidates who meet the fit and proper requirements, as set out in the applicable framework, who do not have any systematic conflict of interest with the Bank and whose nomination ensures that the Board as a collective body presents especially the following basic profile:

The Bank's Corporate Governance Code, as well as the Directors' Nomination Policy describe specific suitability criteria that shall be met by candidates as regards professional competencies that are incompatible with the position of Board member at the Bank, criteria concerning independence of non-executive members, participation of candidates in other Boards, as well as other cases that are incompatible with the position of Board member. All the above aim to ensure the best composition for the Board of Directors.

Finally, following the new provisions of the HFSF Law and the Amended Relationship Framework Agreement between the Bank and the HFSF, the amendment of internal rules, including the Bank's Corporate Governance Code, are currently underway. (See Item 4.B., "Business overview—Regulation and Supervision of Banks in Greece—The Hellenic Financial Stability Fund—The Greek Recapitalization Framework").

Evaluation of the Chief Executive Officer, the Board of Directors and the Board Committees

According to the Bank's Corporate Governance Code, the Board of Directors has a self-assessment system to evaluate the effectiveness of its work and that of its committees, based on a methodology formulated and approved by the Corporate Governance and Nominations Committee.

Further, according to the HFSF Law, as amended, the HFSF, with the assistance of an independent advisor, shall evaluate the Bank's corporate governance arrangements. In particular, the evaluation shall include the size, structure and allocation of responsibilities within the board of directors and its committees, according to the business needs of the Bank. The evaluation will also include individual members of the Board and Board committees. The HFSF, with the assistance of an independent advisor, will also establish criteria for the evaluation of the corporate governance

framework and the evaluation of members of the Board and its Committees, in line with international best practices. Based on that assessment, the HFSF, may make proposals for improvement and modifications of the Bank's corporate governance framework.

The Board of Directors formulates a proposal on the remuneration of its members for the services they provide, which is submitted to the General Meeting. This proposal is formulated in line with the current regulatory framework and the relevant undertakings of the Bank to the Monitoring Trustee and in line with the Bank's Remuneration Policy (the "Remuneration Policy"), the regulation of the Human Resources and Remuneration Committee of the Board, as well as industry best practices, in a way that adequately reflects the time and effort the members are expected to contribute to the work of the Board of Directors, while at the same time promoting effectiveness of the Board of Directors' operations. The remuneration of the Board's Chairman, the Chief Executive Officer and the Deputy Chief Executive Officer(s) are determined by non-executive members of the Board of Directors.

According to Greek Law 3723/2008 and the HFSF Law, as in force, the representatives of the Hellenic Republic and the HFSF can exercise their veto right in the Board decision making process with regards to the distribution of dividends and the remuneration policy for the Chairman of the Board of Directors, the Chief Executive Officer and other Board members, the General Managers and their deputies. Compensation of the aforementioned persons shall in no case exceed compensation of the Governor of the Bank of Greece. For NBG, which received a capital injection from HFSF in 2015, the remuneration cap will be re-evaluated in line with the European Commission Banking Communication of August 1, 2013, point 38 and shall be prolonged until the end of the restructuring period. According to the HFSF Law as in force, it is prohibited for the Bank to award variable remuneration (bonuses) to the Chair of the Board, the Chief Executive Officer and other Board members or General Managers and their deputies, while the Bank participates in recapitalization programs. With regards to executive members of the Board, the Bank has adopted a Remuneration Policy which determines their remuneration within the broader context of determining senior executives' remuneration, and with the aim of promoting meritocracy and creating a culture and mentality of focusing on performance, while being aligned with the applicable framework. During 2015, no variable remuneration was granted to the Chairman of the Board and the executive members of the Board, while the remuneration of the non-executive Directors does not include bonuses according to the Bank's Remuneration Policy.

On June 19, 2015, on a proposal of the Board of Directors following the recommendation of the Human Resources and Remuneration Committee, the Annual General Meeting of the Shareholders approved the remuneration of the members of the Board of Directors for the fiscal year 2014 according to article 24, paragraph. 2 of Greek Company Law 2190/1920, and determined the remuneration of the Chairman of the Board, the Chief Executive Officer, the Deputy Chief Executive Officers and the non-executive members of the Board of Directors until the Annual General Meeting of 2016. Additionally, the Annual General Meeting approved for the fiscal year 2014, the remuneration of the members of the Board of Directors for their participation at the Audit Committee, the Corporate Governance and Nominations Committee, the Human Resources and Remuneration Committee, the Board Risk Committee and the Strategy Committee, and determined their remuneration until the Annual General Meeting of 2016, as per the relevant regulatory framework.

The Directors receive information on all important areas concerning the Group's activities, including on regulatory compliance, corporate governance, risk management, financial management, key financial and accounting issues and Group Policies among others, so as to ensure that on a constant basis they possess knowledge and information required to ensure informed decision-making and

effective conduct of their duties and responsibilities as Board members. Further, the Bank has developed a manual particularly addressed to new Board members, which includes, in accordance with the applicable legal and regulatory framework, detailed information about their obligations as Board members.

Pursuant to the Bank's participation in the Hellenic Republic Bank Support Plan as per Greek Law 3723/2008, the Hellenic Republic has the right to participate in the Board through the appointment of a representative, who has veto powers on corporate decisions relating to dividend appropriation and remuneration of the Chairman of the Board, the Chief Executive Officer and other Board members, as well as the General Managers and their substitutes. The Hellenic Republic representative may also influence the Group's strategic decisions. Mrs. Angeliki Skandaliari was appointed as the Hellenic Republic representative on the Bank's Board in accordance with the said law, in replacement of Mr. Alexandros Makridis.

Furthermore, pursuant to the HFSF Law and the Amended Relationship Framework Agreement between the Bank and the HFSF, the HFSF has appointed Mr. Charalampos Makkas as its representative on the Bank's Board. Additionally, in line with the Amended Relationship Framework Agreement, the HFSF appointed an observer to the Bank's Board (without voting rights). The HFSF representative and the observer are also appointed in the Board Committees, as prescribed by the Amended Relationship Framework Agreement.

In the context of overseeing adherence to the Commitments undertaken by the Hellenic Republic and implementation of the restructuring plan of the Bank, Grant Thornton has been appointed as "Monitoring Trustee". (See also below "—Monitoring Trustee" and Item 4.A, "History and Development of the Company—Revised Restructuring Plan approved by the Directorate General for Competition on December 4, 2015"). The Monitoring Trustee participates as an observer in meetings of the Board of Directors and certain Board/Executive Committees and has full access to any of the Bank's records including board minutes.

Regarding the rights of the representative of the Hellenic Republic and the rights of the representative of HFSF, see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic's Bank Support Plan" and Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Financial Stability Fund—The Greek Recapitalization Framework".

The current Board of Directors, whose term expires in 2018, constituted into a body at the meeting of Board of Directors on June 19, 2015.

The following table sets forth, for each of the Directors, their names, professional activities and the dates on which their respective term began:

Name	Activities	Start of Term

Louka P. Katseli	Chair of the Board and non-executive member	June 19, 2015
Executive Members
Leonidas E. Fragkiadakis	Chief Executive Officer	June 19, 2015
Dimitrios G. Dimopoulos	Deputy Chief Executive Officer	June 19, 2015
Paul K. Mylonas	Deputy Chief Executive Officer	June 19, 2015
Non-Executive Members
Efthymios C. Katsikas	Employees' representative	June 19, 2015
Stavros A. Koukos	Employees' representative, Chairman of Federation of Greek Banks Employees (OTOE)	June 19, 2015
Independent Non-Executive Members
Dimitrios N. Afendoulis	Economist, Assistant General Manager at the Latsis Group in Greece & Member of Executive Board of the John S. Latsis Public Benefit Foundation	June 19, 2015
Spyridon J. Theodoropoulos	Chief Executive Officer, Chipita S.A.	June 19, 2015
Petros K. Sabatacakis	Economist	June 19, 2015
Hellenic Republic Representative
Angeliki I. Skandaliari	Economist	March 23, 2015
Hellenic Financial Stability Fund Representative
Charalampos A. Makkas	Economist	June 11, 2012
Secretary of Board of Directors & Board Committees
Panagiotis A. Dasmanoglou	Assistant General Manager—Group Chief Compliance & Corporate Governance Officer	January 28, 2014

Pursuant to the Bank's participation in the Hellenic Republic Bank Support Plan, the Greek Government has the right to participate in the Board through the appointment of a representative, who has veto powers on corporate decisions relating to the remuneration of the Chairman, Chief Executive Officer, the remaining members of the Board of Directors, the General Managers and their deputies compensation, as well as regarding dividend policy. The Greek Government representative may also influence the Group's strategic decisions. Mrs. Angeliki Skandaliari was appointed as the Hellenic Republic's representative on the Bank's Board in accordance with the said law, in replacement of Mr. Alexandros Makridis who submitted his resignation from the Board on February 25, 2015, which was accepted by the Hellenic Republic Finance Minister on March 2, 2015. See Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic's Bank Support Plan" for further information on the powers of the representative of the Hellenic Republic under the Hellenic Republic Support Plan.

Furthermore, pursuant to the HFSF Law and the Presubscription Agreement dated May 28, 2012, as amended and restated on December 21, 2012, the HFSF appointed Mr. Charalampos Makkas as its representative on the Bank's Board. The HFSF representative, according also to the stipulations of the Amended Relationship Framework Agreement between the Bank and the HFSF, participates in the Board Committees. Additionally, according the provisions of the Amended Relationship Framework Agreement between the Bank and the HFSF, the HFSF also appoints an Observer to the Board and Board Committees (without voting rights). For the HFSF's powers see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Financial Stability Fund—The Greek Recapitalization Framework—Provision of Capital Support by HFSF—Powers of the HFSF".

Pursuant to the 2015 Recapitalization, the HFSF participated in the Bank's recapitalization by contributing ESM notes and acquiring in exchange common shares with full voting rights representing 38.92% of the share capital of the Bank, and CoCos. Additionally, the HFSF retains common shares with restrictions on the exercise of voting rights, as per article 7a of the HFSF Law as in force, corresponding to 1.47% of the share capital of the Bank, which could have full voting rights shares upon certain conditions.

Subject to the Amended Relationship Framework Agreement applicable law and the Bank's Articles of Association, the Bank's decision making bodies will continue to determine independently, amongst others, the Bank's commercial strategy and policy in compliance with the Restructuring Plan and the decisions on the day to day operation of the Bank will continue to rest with the Bank's competent bodies and officers, as the case may be, in accordance with their statutory, legal and fiduciary responsibilities.

Apart from their above representatives and the rights of the Hellenic Republic and the HFSF as shareholders, the Hellenic Republic does not have other powers or control over the appointment of any other member of the Bank's Board of Directors.

From January to February 2013, monitoring trustees (each, a "Monitoring Trustee"), acting on behalf of the European Commission, were appointed in respect of all banks under restructuring—including the Bank, in accordance with the commitments undertaken by the Hellenic Republic towards the European Commission in 2012 in the Memorandum of Economic and Financial Policies, contained in the First Review of the Second Economic Adjustment Program for Greece.

The Monitoring Trustees are international auditing or consulting firms approved by the European Commission on the basis of their competence, their independence from the banks and the absence of any potential conflict of interest. In each credit institution under restructuring, the Monitoring Trustees work on behalf and under the direction of the European Commission, within the terms of reference agreed with the European Committee ("EC"), the European Central Bank ("ECB") and International Monetary Fund ("IMF") staff.

In addition to the appointment of Monitoring Trustees, the commitments undertaken by the Greek government refer to the Item 4.A, "History and Development of the Company—Revised Restructuring Plan approved by the Directorate General for Competition on December 4, 2015".

The Monitoring Trustee submits relevant reports to the EC/ECB/IMF on a quarterly basis.

Below are the curriculum vitae of the Chairman, the Chief Executive Officer and the Deputy Chief Executive Officers, as well as those of the principal managers of various business lines of the Bank.

Louka Katseli, born 1952, is, from March 2015 the Chair of the Board of Directors of the National Bank of Greece and from April 2015 the Chair of the Hellenic Banking Association. She has served as Greece's Minister of Labor and Social Security (2010–2011), Minister of Economy, Competitiveness and Shipping (2009–2010) and a member of the Hellenic Parliament (2007–2012).

Director of the OECD Development Centre in Paris between 2003–2007, she has been a member of several prominent international and European Committees including the UN Committee of Development Policy (1996–2003), the European Commission's Economic and Monetary Policy Committees and the "Comité des Sages" on the Reform of the European Social Charter (1995–1997). She was member of the team that conducted the European Report on Development 2015 "Combining Finance and Policies to Implement a Transformative post-2015 Development Agenda". Prof. Katseli has also served as Director General of the Center of Planning and Economic Research (KEPE)

(1982–1986) and as International Economic Advisor to the Greek Prime Minister (1993–1996). She is a member of the Steering Committee of the European Association of Development Research and Training Institutes (E.A.D.I.) since 2005 and member of the Euro 50 Group since 2000.

Prof. Katseli holds a Ph.D. (1978) in International and Development Economics from Princeton University (Distinguished Dissertation in Economics), an MPA in Public Affairs(1974) from the Woodrow Wilson School for Public and International Affairs, an MA in Economics (1975) from Princeton University and a BA in Economics (1972, cum laude and Phi Beta Kappa) from Smith College.

She is Professor of International Economics and Development at the Department of Economics of the National Kapodistrian University of Athens (1987–present) and has served as Assistant and Associate Professor of Economics at Yale University's Department of Economics and the School of Organization and Management (1977–1985). She is the recipient of numerous distinctions and fellowships, including that of the Best Young Professor at Yale (1980). She has published extensively in the areas of development economics and finance, migration management, investment and trade, exchange rate policy and institution-building in European and developing countries.

Leonidas Fragkiadakis, born 1966, is the Chief Executive Officer of the National Bank of Greece Group since March 2015. He joined the National Bank of Greece in 1996 and he was responsible for the Derivatives Division. He served as the Group Treasurer since 2003 and in 2009 was also appointed General Manager of Treasury and Global Markets. Prior to joining the Bank, he worked at Credit Suisse First Boston, New York, as a Trader with extensive experience in Derivative Products on Foreign Exchange, Interest Rates and Emerging Market bonds. He holds a Bachelor's Degree in Economics from Trinity College, Cambridge University and an MBA from the Wharton School of the University of Pennsylvania.

Dimitrios Dimopoulos, born 1947, was elected Executive Member of the Board of Directors and Deputy CEO of the National Bank of Greece (NBG) in June 2014, overseeing its Corporate, Retail and Investment Banking, as well as Group Marketing & Communication. He is also Member of NBG's Executive Committee. He was appointed General Manager of Corporate Banking at NBG in February 2008 also served as Chairman of the Board of Directors at Ethniki Insurance Co from July 2012 until March 2016. He joined NBG in 1975 and as Director of the Large Corporate Division, he was involved in corporate financing as well as project financing of investments in infrastructure, energy and tourism sectors. He is also member of the Board of Directors of Astir Palace Vouliagmeni S.A. and the permanent representative of NBG on the Board of Directors of the Athens Chamber of Commerce and Industry. He holds a Bachelor's degree in Economics and Political Sciences from the Aristotle University of Thessaloniki and a postgraduate degree in Economics from the University of East Anglia, United Kingdom.

Paul Mylonas, born 1958, was appointed Deputy Chief Executive Officer of the Group in June 2014. Direct reports are the CFO and COO and the Troubled Assets Units. From December 2013 to June 2015, he also acted as Chief Risk Officer for the Group. He is a Member of the Executive Committee and of the ALCO. He is Vice Chairman of the Board of Directors at Ethniki Insurance Co, Chairman of the Board of Directors of Astir Palace and NBG Asset Management, and serves as a member of the Board of Directors of Finansbank, NBG Cyprus Ltd, NBGI Private Equity Ltd, NBG International Ltd and NBG GP Ltd. Moreover, he is a member of the Economic Advisory Board of the Hellenic Banks' Association. In July 2012 he was appointed General Manager of Strategy and International Operations. From December 2010 until July 2012 he served as General Manager of

Strategy and Governance. From April 2004 to December 2010 he was General Manager of Strategy and Research, Head of Investor Relations and Chief Economist of the Group, which he joined in 2000. Before joining the Bank, he worked as Senior Economist in the Economics Department of the OECD (1995–2000) and the IMF (1987–1995) and taught at Boston University (1985–1987). He holds a Master of Arts and a PhD in Economics from Princeton University and a BSc in Applied Mathematics-Economics (Magna cum Laude and Phi Beta Kappa) from Brown University.

Stavros Konstantas, born 1966, was appointed Deputy CEO, acting as CEO, of Ethniki Insurance Co S.A in March 2016. From December 2011 to February 2016, he held the position of CFO in Ethniki Insurance Co S.A. He is also member of the Board of Directors of Europe Insurance Co S.A., National Insurance Brokers S.A., Ethniki Insurance (Cyprus) Ltd, Garanta Asigurari S.A., UBB MET LIFE and UBB Insurance Brokers (Bulgaria). During the period 1991–1998, he worked in ING Life of Greece, where he served in several responsible positions in the Actuarial Department. In 1999, he was appointed Chief Actuary and Operations Manager and from 2002 to 2008 he held the position of CFO. In 2009, he was appointed Chief Bancassurance officer, responsible for the Bancassurance agreement with Piraeus Bank. He was also Deputy CEO in ING Life and ING Non Life and member of the Board of Directors of ING Brokerage and ING Piraeus JV. In 2010, he worked in International Life where he held the position of General Manager (OPS, Finance, Risk). He holds a Bachelor and a postgraduate degree in Mathematics from the University of Athens and he is a certified Actuary since 1994.

Marinos Vathis, born 1957, has been the President of the Executive Board of Vojvodjanska since July 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, initially as Head of Corporate Banking and later as Head of Consumer and Retail Banking. In 2002, he joined NBG 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 was the Member of the Board of Directors of Egnatia Securities from 1997 until 2002. Between 2005 and 2010, he served as a Board Member in the Association of European Banks in the UK, representing Greece. He was appointed as President of the Board of Directors of NBG Leasing d.o.o. in Belgrade in May 2012. He has also actively participated in several organizations in the past four years as a Member of Hellenic Business Association Serbia and Foreign Investors Council. 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.

Stilian Vatev, born 1956, is the Chairman and a member of the Board of Directors and Chief Executive Officer of UBB AD. He joined UBB in 1993 after serving in several managerial positions at the Bulgarian National Bank. He is also a Chairman of the Boards of Directors of Interlease EAD., Interlease Auto EAD. and a member of the Boards of Directors of UBB Insurance Broker EOOD and of Bankservice Borika AD. Mr. Vatev is the Chairman of the Management Board of UBB—MetLife Life Insurance Company. He is a member of the SEE Regional Advisory Board of MasterCard—Europe, and a Plenary Member of the European Payment Council. Mr. Vatev holds a 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.

Nicholas Beis, born 1952, is the Managing Director of NBG 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, General Manager at Piraeus Bank, Corporate Manager at ABN AMRO Bank NV, Athens and Relationship Manager at Barclays Bank PLC, Athens. Mr. 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.

Diomidis Nikoletopoulos, born 1964, is the Chief Executive Officer and Chairman of the Board of Directors of Stopanska Banka. He joined the Bank in 2009, after having a successful career in top managerial positions in Laiki Bank, AspisBank, EFG Eurobank, as well as a long term career in KPMG Athens. Diomidis Nikoletopoulos holds an MSc in Marketing Management (Derby University, UK) and a BS in Business Administration (Athens University of Economics and Business). He has attended various seminars and training courses in many countries and in different business subjects and he is also a member of the Management Board of the Academy of Banking and IT, as well as member of Greek Economic Chamber and the Institute of Chartered Accountants

Cenk Kahraman, born, 1975, 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 is also a Board member in NBG Malta Holdings Ltd., Board 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 1965, has been the Chief Executive Officer of NBG Asset Management since February 2012. His prior appointments include the position of Chief Executive Officer at Bank of Cyprus Asset Management Company and the positions of Interest Rate Swaps and Options Trader, in London, at Merrill Lynch and Barclays and Proprietary Trader at Citibank. Mr. Sarantinos holds a Ph. D. in Computer Science—Artificial Intelligence from Queen Mary College, University of London and a B.Sc. (Hons) in Computer Science from the University of Cardiff.

Mr. Ioannis Kougionas, born 1959 was appointed CEO and Member of the Board of Directors of Banca Romaneasca in December 2014, previously holding the position of Chief Executive Officer at Banka NBG Albania Sh.A. (member of NBG Bank Group). He started his banking career in 1994 at Alpha Bank Greece S.A., and then served in several managerial positions in Alpha Bank Romania S.A, Bancpost S.A. and Banka NBG Albania SH. A. In parallel to his banking career, he was involved from 1982 to 2013 in academic activities, such as researching and lecturing in various institutions from England, Greece and Albania. He holds a BA Diploma in Economics at University of Macedonia, in Greece and a Ph.D. in Credit and Agriculture, at Bradford University, England.

The General Managers, currently 15 in number, each report to the Chief Executive Officer and Deputy Chief Executive Officers and are responsible for:

Dimitrios Kapotopoulos, born 1951, was appointed General Manager of the Corporate Banking Division of the National Bank of Greece in July 2015. He is also a member of the Executive Committee. He has under his supervision the Bank's Shipping Department and he has been appointed member of the Board of Directors of Ethniki Leasing. He joined NBG in 1978, initially at the Branch Network. From 1982 until 1992, he served as credit analyst and has played a constructive role in setting

up the Large Corporate Division of the Group in 1993; he was appointed Deputy Director of the Division in May 2008. Since October 2010, he was Director of the Structured and International Finance Division of NBG. Since February 2014 he served as Assistant General Manager of Corporate Special Assets at National Bank of Greece. He has been extensively involved in the fields of credit analysis, corporate banking and international credit. He holds a Bachelor's Degree in Economics from the Aristotle University of Thessaloniki and has attended several business seminars and workshops in finance and in banking operations.

Ioannis Kyriakopoulos, born 1959, was appointed Chief Financial Officer of the Group in September 2015. He is member of the Executive Committee and the ALCO. He has also been appointed as member of the Board of Directors of the Hellenic Exchanges-Athens Stock Exchanges SA and the Astir Palace Vouliagmeni SA. He worked at the Bank from 1977 until January 2012 when he joined the HFSF as its Chief Financial and Operating Officer. At the Bank he served as Deputy General Manager of International Activities from April 2011 to January 2012 and as Deputy Chief Financial Officer from April 2009 until April 2011 while from August 2002 to April 2009, he was the Director of the Financial and Management Accounting Division. He holds a BSc in Mathematics and a BSc in Economics from the University of Athens and an MSc in Statistics and Operational Research from Loughborough University in the United Kingdom.

Nelly Tzakou Lambropoulou, born 1962, is General Manager of Retail Banking at the Bank since July 2013. She is responsible for Retail Banking, the Branch Network and e Business & Alternative Channels of the Bank and is a Member of the Senior Executive Committee of NBG and the ALCO. Since December 2012, she held the position of General Manager, Group Head of Operations, Business Processes and IT at the Bank. She is Chairman of the Board of Directors at NBG Securities and NBG Bancassurance, Vice Chairman of the Board of Directors at DIAS S.A. (Greek ACH), member of the Board of Directors of the Athens Chamber of Commerce and Industry, Ethniki Factors and member of Innovation—Education- Entrepreneurship Committee of the American-Hellenic Chamber of Commerce. Moreover, she is a member of the Euro Banking Association (EBA—Paris), council member of EFMA Operational Excellence Advisory Council, as well as a Board of Directors member of "Junior Achievement Greece". Before joining the Bank, she worked at Eurobank between 1990 and 2007, where she held the position of General Manager, responsible for Group Operations and Global Transaction Services. She holds a Bachelor's Degree in Economics from the University of Piraeus and an MBA from the University of Wales & Manchester Business School.

Damianos Charalampidis, born 1964, was appointed Group Chief Operating Officer at the Bank in September 2012. He is Chairman of the Board of Directors of PAEGAE (Logistics Company) and Member of the Investment Committee of PANGAIA (Real Estate Investment Company). He is a Member of the Executive Committee of NBG. He has 20 years of experience in the field of Telecommunications and particularly in the area of Operations, serving as a C-level Executive at all three mobile operators in Greece. More specifically, from 2009 until 2012 he was the Chief Operating Officer at Vodafone Hellas. During 2005–2009 he joined WIND Hellas as Chief Commercial Officer, while later he assumed the responsibilities of the Chief Operating Officer. From 1998 until 2005 he worked at Cosmote as a Product and Services Manager and then he assumed the General Management of the sector. He started his career in 1991 at Intracom S.A. in the division of Research & Development and Marketing and Sales later. From 2003–2010, he served as the Chairman of the Board of Directors of the Greek section of IET (Institute of Electrical and Technical Engineers), of which he remains a Member. Moreover, he has served as Member of the Board of Directors in OTENET (ISP Provider), TELLAS S.A. (Fixed Line Operator), ZELITRON (IoT Internet of Things). He is currently a Member of the Board of Directors of CosmoONE (B2B e-Auction service provider). He holds a BSc in Electrical and Electronic Engineering from John Moores University in Liverpool as well as an MSc in Digital Electronics from the University of Manchester Institute of Science and Technology (UMIST).

Marinis Stratopoulos, born in 1964, was appointed General Manager of International Activities at the National Bank of Greece in April 2014. He was also Managing Director (CEO) and Chairman of the Board of Directors of NBG's subsidiary in Romania, Banca Romaneasca S.A. since August 2010. From February 2007 until August 2010 he served as CEO and Chairman of the Executive Board of the subsidiary Bank Vojvodjanska Banka A.D. During 2005–2007 he worked as General Manager at the National Bank of Greece A.D. Beograd. From 2001 to 2005 he worked as Chief Executive Officer and Chairman of the Board of Egnatia Bank (Romania) S.A. and Chairman of the Board of Directors of Egnatia Leasing (Romania) S.A., while in the period January–June 2005 he was Deputy General Manager at Egnatia Bank S.A. During the years 1999–2000 he held managerial positions in Piraeus Bank S.A. and Prime Bank S.A. From 1993 and for the next 6 years he worked at Xiosbank S.A. as Director in the Corporate Banking Department. He is Chairman of the Board of Directors of Banca Romaneasca S.A., Vojvodjanska Banka A.D., Stopanska Banka A.D Skopje and NBG Leasing IFN S.A and member of the Board of Directors of United Bulgarian Bank A.D. and NBG Cyprus L.T.D. He holds a degree in Business Administration from the American College of Greece (Deree College) and a Master of Science in Finance from Lancaster University UK.

Petros Fourtounis, born 1955, was appointed Group Human Resources General Manager at National Bank of Greece in June 2015. Previously, he was Group Chief Audit Executive at the Bank from July 2010 until January 2014, when he was appointed General Manager of Corporate Special Assets of the Bank. He is a member of the Economic Chamber of Greece and the Institute of Internal Auditors. He has been extensively involved in the fields of audit, corporate—project financing and international credit. From 2002 to 2010, he held the position of Director in the NBG Divisions of Corporate Banking, Structured and International Finance and Group International Credit. In the time period 1984–1999 he worked as Internal Auditor for branches, administration units and subsidiaries of the Bank in Greece and abroad. He joined NBG in 1975 and until 1984 he worked in the branch network of the bank. 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. He holds a Bachelor's Degree in Economics from the University of Macedonia, Economic and Social Sciences and a Certification in Risk Management Assurance (CRMA) from the Institute of Internal Auditors Global (IIA Global).

Nikolaos Christodoulou, born 1965, was appointed Group Chief Information Officer of NBG in November 2011. Before joining NBG, he was a Partner at Accenture, the global consulting and technology firm, where he headed the Management Consulting Unit and the Financial Services Unit in Greece. He is a member of the Board of Hellenic Management Association and a member of Technical Chamber of Greece. He is also member of the Board of Directors of Banca Romaneasca. 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.

Yiannis Vagionitis, born 1960, was appointed Chief Credit Officer in July 2015. He is also member of the Board of Directors of Finansbank since January 2014 and member of the Risk Committee, the Audit Committee and Loans Committee of Finansbank as well. From October 2010 up to November 2013 he was Head of Corporate Banking-Large Corporate Division of NBG. Also, he was member of the Board of Directors of NBG Factors. From May 2008 up to October 2010 he was Head of Credit Division and International Credit Division of the Group, whereas from October 2006 up to May 2008 he was Head of Credit Division of National Bank of Greece. Moreover, he was member of the Executive Credit Committees of National Bank of Greece, Banka Romaneaska, United Bulgarian Bank, Stopanska Banka, Vojvodanska Banka, NBG Albania, NBG Cyprus, NBG Leasing Serbia, NBG

Leasing Romania and NBG Leasing Bulgaria. He joined National Bank of Greece in 2004 under the Group Risk Management Division. Between 1992 and 2003 he worked for the HSBC Bank and between 2003 and 2004, at positions of responsibility in the area of corporate banking of the Bank of Cyprus. He holds a BSc and a Master of Science in Mechanical Engineering from the University of Manchester Institute of Science & Technology (UMUST) and also an MBA from Manchester Business School.

Constantinos Vossikas, born 1968, was appointed Assistant General Manager of Corporate Special Assets in July 2015. He joined NBG in 2005 as a Credit Risk Manager for Group Risk Management and subsequently as a Senior Credit Officer for Credit Division. Since 2010, he served as Director of NBG Group International Credit and in 2013 he was appointed Assistant General Manager and Chief Credit Risk Officer. He has been a member of Supervisory Boards of NBG Group International Subsidiaries and NBG Group Senior Credit Committees. Before joining NBG, during the period from 1994 to 2005, he worked in the Corporate Banking Departments of Midland Bank as a Credit Officer and Egnatia Bank, where he held the position of Head of Corporate and Investment Banking. During the period from 1990 to 1994 he worked in the audit departments of Moore Stephens and Arthur Andersen, participating in external and internal audits for companies operating in various sectors of the Greek economy, valuations, feasibility studies etc. Mr. Vossikas is a Certified Public Accountant, member of the Institute of Certified Public Accountants in Ireland, holds a degree in Accounting and Finance from Deree College and has participated in many seminars held in Greece and abroad.

Panagiotis Dasmanoglou, born 1963, was appointed Assistant General Manager of Group Compliance & Corporate Governance at the Bank in June 2015 and is also a member of the Executive Committee. He was elected Secretary of the Board of Directors and of its Committees in January 2014. Since September 2013 he was Assistant General Manager of Group Compliance at the Bank. Previously, since July 2009 he served as Director of the Group Compliance Division, and he was responsible for the Group's compliance with the legislative and regulatory framework. In his various positions as a lawyer at the Bank in the past, he handled significant matters concerning integration of European banking legislation in the Bank's processes, domestic and international credit operations, and M&A activity, thereby gaining substantial experience across a broad spectrum of banking operations. For a number of years, he has been an active participant in the workings of the Hellenic Bank Association and the European Banking Federation, and specifically on the Committees for international banking issues, compliance, consumer issues, anti-money laundering, derivatives and repos. Mr. Dasmanoglou serves on the board of the Hellenic Ombudsman for Banking and Investment Services and on the boards of directors of several NBG Group companies, including as Vice President at National (Ethniki) General Insurance, at NBG Securities S.A., Ethniki Factors S.A. and NBG Asset Management S.A. He holds a law degree (LL.B) from the University of Athens Law School and a postgraduate (Master's) degree in European Law from the University of Brussels, as well as international executive certifications in international banking law, compliance and banking management from the INSEAD Graduate Business School.

Georgios Kaloritis, born 1964, was appointed Assistant General Manager and Chief Audit Executive of the Group in January 2014. He joined the Bank in 2006 as a Director of Internal Audit responsible for the areas of operations, compliance, information systems and several other support functions of the Group. He was in charge of the project team responsible for the integration of the Group's Internal Audit Units, the development of a common methodology according to the IIA standards and the implementation of a fully integrated system (EGRC) for the automation of the audit activities. Before joining the Group he served as the Corporate Security Officer at Eurobank (2003–2006) and as a Partner responsible for the Enterprise Risk Services practice at Deloitte Greece (1996–2003). He started his career in the USA where he served at various managerial positions at Price Waterhouse's Management Consulting Practice in New York and at AT&T's Information Technology Strategy & Data Architecture Unit (1990–1996) in New Jersey. He served as the President of the Board of the Hellenic

Institute of Internal Auditors (2013–2015) and has also served as the Vice President of the Hellenic Information Systems Audit and Control Association (2002–2004). He holds an MBA degree in Executive Management form Saint John's University of New York, an MA in Management Information Systems and a BA in Computer Science and Economics as a second major from Queens College of the City University of New York. He is a Certified Internal Auditor (CIA) and a Certified Information Systems Auditor (CISA).

Ioanna Katzilieri Zour, born 1961, was appointed Deputy General Manager in Group Communications and Marketing in December 2012. Among other committees, she is a member of the Compliance and Reputation Risk Committee. She joined the Bank in 2006 as Deputy General Manager in Retail Banking after having served as Deputy General Manager of Strategic Marketing at Eurobank. She has also worked for Millennium Bank as Deputy General Manager, responsible for various divisions including Branch Network, Mortgage Lending, Alternative Channels and Marketing (1999–2004). She has also served as Marketing Director in Wind Telecommunications (1998–1999) and Pepsico Ivi (1995–1998) and started her career working at Procter & Gamble in 1989. She holds an MSc in Economics from the London School of Economics and a BSc in Economics from Bristol University.

Vassilis Kavalos, born 1958, was promoted to Group Treasurer in June 2015. Since last June he is also the Bank's Liaison to the Committee for Approval of Banking Transactions that oversees the enforcement of the Capital Controls Legislative Act, as well as the chairman on the Bank's Subcommittee authorized for approving capital outflows for commercial purposes. From 2011 to 2015 he was the Corporate Treasurer with the primary task of ensuring the necessary liquidity and its efficient allocation within the Group while prior to that he was the Deputy Manager of trading since 2008. From 1999 until 2005, following the request of Ministry of Finance, he was detached to the Public Management Debt Agency where he participated in the instituting and operating of the Funding Department. In 1997 he became the Head of sovereign bond trading desk in the Group's Dealing Room, of which he was a staff member, through a selection process, since 1991. He joined the Group in 1981, after passing a public examination, and the following years he worked at the international trade and credit departments. He holds a BSc in Business Administration of Deree College of the American College of Greece and is a certified Portfolio Manager by Bank of Greece.

George Koutsoudakis, born 1965, was appointed Deputy General Manager of Corporate Banking in the Group in January 2014. Just before joining the Group during 2013 (between January and May) he was Advisor to the management of Alpha Bank and from May onwards, he was Deputy Commissioner of Probank. During the period from 2007 to 2012 he worked at Emporiki Bank (Group Credit Agricole). From 2007 to 2009 he was Deputy General Manager of Corporate and Investment banking and from 2009 to 2012 he was General Manager, Head of Enterprises, Investment & Private Banking. During the period 2002 to 2007 he was Deputy General Manager at Geniki Bank (Group Societe Generale). Prior to that he had worked in the field of investment banking for ETEBA (within the Group) from 1996 to 2001 and Alpha Finance (of the Alpha Bank banking group) from 1990 to 1996. He has held various positions on Boards of Directors, while currently he is non-executive member on the Board of Directors of the FinansBank Group, Probank Leasing, Ethniki Factors and Apivita S.A. He holds a BSc Economics Honors Degree from Queen Mary College (University of London).

George Maligiannis, born in 1961, was appointed Deputy General Manager of Retail Collection Unit, in April 2016. Since July 2013 he held the position of Deputy General Manager of Household Lending in NBG Group and was responsible for Mortgage Credit, Consumer Finance and Credit Cards. Since November 2011, he held the position of Manager in the Mortgage Credit Division. He has been with NBG Group since 1999 and has more than 30 years of banking experience. Before joining the Group, he worked for the Mortgage Bank of Greece in the IT Department, in the Branch network and from 1989 to 1998 as Manager in the Vancouver Representative Office, in Canada. He is a graduate in Economics from the University of Athens and holds a Masters' Degree in Business

Administration from Simon Fraser University, Canada. He is also an Associate with the Institute of Canadian Bankers.

Vasileios Mastrokalos, born 1963, was appointed Assistant General Manager of Group Strategy in June 2015. He started his professional career at the Group in February 1984. Initially, he worked at the branch network and from 1991 to 2008 at various Desks of the Group Treasury (FX, money markets, capital markets, derivatives), reaching to the position of Head of Trading. During the period 2009–2012 he served as Deputy Director General of the Public Debt Management Agency and from January 2013 to May 2015 he was Head of the Group Debt Issuance and Management Sector. He holds a Bachelor's degree in Economics from the University of Athens and a Master's degree in Economics from the University of Essex (UK).

Alexandros Benos, born 1966, was appointed Chief Risk Officer of the Group in June 2015. Since September 2013 he was Deputy General Manager for the Group Risk Management and from 2010 he was Director of Group Risk Control & Architecture Division at the Bank. After joining the Bank in 2000, he first set up the Value at Risk estimation framework for Market Risk, then worked on the development of an obligor rating system for corporate clients and finally headed the "Basel II" implementation program throughout the Group. He serves on the Board of Directors and as Chairman of the Board Risk Committee of United Bulgarian Bank. He is member of the Board of Directors at NBG Asset Management M.F.M.C. and also at the Asset Liability Committee of Ethniki Asfalistiki Insurance Co. He previously held academic positions in the US, France, Switzerland and Greece, and he continues to serve as a Visiting Professor at the École des Hautes Études Commerciales in Paris. He holds a degree in Economic Sciences from Athens University, a B.A. and a M.A. in Economics from the University of Cambridge in the UK and a Ph.D. in Finance from the Graduate School of Business of Stanford University in the USA.

Konstantinos Bratos, born 1956, was appointed Deputy General Manager of International Activities in the Group in December 2013, having served as a manager of this Division since April 2012. He has been the Chairman of NBG Malta Holdings Ltd and NBG Bank Malta Ltd since 2009, of Banka NBG Albania since 2012. He is also Deputy Chairman of the Board of Directors of Banca Romaneasca and Vojvodjanska Banka and of the Supervisory Board of Stopanska Banka as well Board Member of UBB. From 2010 to 2012, he held the position of Executive Manager for Corporate & Business Banking at UBB. From 2005 to 2010 he was Manager of International Network Division A' at the Group. From 2002 to 2005 he held the position of Second General Manager at Stopanska Banka. From 1992 to 2002 he also served as Deputy Manager at the Group branch in Boston and after that he became Manager at the NBG branches in Belgrade, Sofia and Bucharest. From 1984 to 1992 he worked in the Audit Division at the Group which he joined in 1975 and until 1984 he worked in the branch network of the Bank. He holds a BSc in Economics from the University of Piraeus, as well as a MSc in Economic Management, specialization in Marketing Management from Burgas University (Bulgaria).

Vasileios Skiadiotis, born 1961, was appointed Assistant General Manager of Retail Banking in June 2015; he is responsible for Private Banking, Retail Customer Development Team, Investment Products and Deposits, Institutional Customer Service, Small-to-Medium Business Corporate Credit and Bancassurance S.A. (subsidiary of National Bank of Greece Group). From 2011 to 2015, headed the Global Markets Division. He joined the Group in 1984. Until 1991 he served in the retail network holding different positions at various departments. During the years 1991–2015 he was selected to work for the Group Treasury, General Division. In 2004 participated in the INSEAD Inter Alpha Banking Program as member of NBG's representatives. He participates in the Committee of NBG Asset Management (Mutual Fund Management Company), NBG Insurance Brokers, as well as in Banking Transaction Approval Subcommittee and in Youth Innovative Entrepreneurship and Extrovert Greek Business Development Committee. He holds a Bachelor's Degree in Civil Engineering from National Technical University of Athens and a postgraduate degree in banking. He is a certified Portfolio Manager by Bank of Greece.

George Triantafillakis, born 1957, was appointed Assistant General Manager of Legal Services in June 2015, with responsibilities for the supervision and coordination of activities of Legal Services Division and external lawyers providing services to the Bank. Since 2012 he held the position of Director of Legal Services Division, since 2006 he is Member of the Legal Council of National Bank of Greece and since 2010 he is Member of the Legal Council of Hellenic Bank Association. Since 1992 he is Attorney-at-law practicing before Supreme Court of Justice. During his long term service in the Legal Services, he represented the Bank before high Courts, arbitration tribunals and Authorities, with respect to significant legal cases in Greece and foreign jurisdictions, involving matters of banking law, criminal law, capital markets law, competition law, European and commercial law. He is Professor of Law in DUTH and Professor in National School of Judges. He was member of Competition Commission (for 10 years), member of legislative committees and legal science societies. He has published monographs, scholarly and university books, series of articles in particular sectors of commercial law and he was elected as Vice chairman in the board of Association of Greek commercialists. He is graduate of the University of Athens Law School (with honors) and holds a doctoral degree in commercial law from the German University of Tübingen Law School.

George Frangou, born 1964, was appointed Deputy General Manager—Head of Group Real Estate at the Bank in March 2014. From March 2000 to December 2013, has held several management positions within Eurobank EFG Group, where he served as Finance & Administration Director of at EFG e-Solutions (e-Banking, e-commerce b2c), h Head of Real Estate—Greece and later for the Group's International Activities. During the period 1993–2000 has held various managerial positions for at Johnson & Johnson and METAXA S.A. He has extensive experience in the areas of Real Estate, Operations & Project Management, Finance and IT. Has led reorganizations, with a long track record in leading teams, and setting-up new units and ventures in Greece and South Eastern Europe (green field operations). He holds a Bachelor of Science in Economics from the Athens University of Economics & Business and a Master Degree in Business Administration (MBA) from California State University, Bakersfield (USA).

During 2015, 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 21 million.

For more information on related party transactions, see Note 32 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. In the case of the executive members of the Board of Directors and the highly ranked officers, the Bank reserves the right for groundless termination of their fixed-term employment contracts by paying specific levels of compensation. The compensation may reflect the entitled salaries for the remaining period of the contract. Especially as to the Executive Members of the Board of Directors, it may not exceed the salaries of one year.

The Bank's corporate governance framework is aligned with the requirements of Greek and European legislation and the rules the Hellenic Capital Market Commission ("HCMC"), as incorporated in the Bank's Articles of Association, the Corporate Governance Code and other internal regulations/charters. Additionally, the stipulations of the Amended Relationship Framework Agreement between the Bank and the HFSF, and the obligations of the Bank towards the Monitoring Trustee are applied, while finally, considering the fact that NBG remains registered with the US Securities and Exchange Commission ("SEC"), the Bank is also subject to US legal and regulatory framework (Sarbanes Oxley Act and SEC rules).

In February 2006, the Board of Directors adopted a directional 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 also the governance of the Bank and the Group. In March 2011, in compliance with the provisions of the corporate governance framework, the Board of Directors adopted the Corporate Governance Code of the Bank, which was thereinafter amended in November 2013, with a view to bringing it into line with the Relationship Framework Agreement between the Bank and the HFSF as well as with the Bank's obligations towards the Monitoring Trustee and in December 2014 in order to incorporate the changes in the regulatory framework (especially Law 4261/2014, which transposed CRD IV into Greek law), to further adopt international best practices, as well as to better reflect the Bank's organizational structure. In 2015, an annual review and update of the Bank's Corporate Governance Code took place and was amended in part in September 2015. Finally, following the recent amendments in HFSF Law and the Amended Relationship Framework Agreement with the HFSF signed in December 2015, a further amendment of the Bank's Corporate Governance Code is already underway.

The Bank is in compliance with 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 process of developing a high level Chart of Authorities and Responsibilities of the Management at Group level, which is expected to be adopted by the Board in 2016, along with the relevant software.

As prescribed by the Corporate Governance Code, the Board conducts an annual Board effectiveness review to evaluate its own performance as a collective body and its members' contribution in line with the Board evaluation procedure formulated by the Corporate Governance and Nominations Committee. The evaluation is carried out every three years by an external consultant whose oversight is the responsibility of the Corporate Governance and Nominations Committee. Additionally, as detailed in the Chapters particularly referring to the HFSF and the applicable framework, the Board and its Committees are evaluated by the HFSF with the assistance of an independent advisor.

The Corporate Governance Code can be viewed on the Bank's website: www.nbg.gr (section: The Group/Corporate Governance/Regulations & Principles).

In its endeavor to maintain corporate governance excellence and enhance its existing risk management framework, the Bank has adopted the following main corporate governance policies and practices, which are aligned with its activities and ensure the transparency and effectiveness of its operations.

The Directors' Nomination Policy is based on the Corporate Governance Code and the Corporate Governance & Nominations Committee Charter. In December 2014, the Directors' Nomination Policy has been updated, in order to incorporate the relevant provisions of Greek Law 4261/2014, which transposed into Greek law Directive 2013/36/EU (CRD IV), as well as international best practices, taking into account the EBA Guidelines on the assessment of the suitability of members of the management body and key function holders (EBA / GL / 2012/06), while it also reaffirms the important role of the Board's Corporate Governance and Nomination Committee ("CGNC") and its Chairman in the selection of candidate members for the Bank's Board. The policy is to be updated in 2016 in the context of the new provisions of HFSF Law and the Amended Relationship Framework Agreement with the HFSF.

The Conflict of Interest Policy for Senior Executives aims at enhancing the Bank's Internal Controls System, as well as preventing and managing potential conflicts of interest between the Bank and its Senior Executives, which could potentially have an adverse impact on the reputation and interests of the Bank as well as its clients, shareholders and employees.

In accordance with the provisions of the Amended Relationship Framework Agreement with the HFSF and the commitments that the Bank is required to observe and which are monitored by the Monitoring Trustee, taking into account the current legal and regulatory framework, the Policy for Connected Borrowers of the Bank and the Group in Greece has been adopted.

The Policy aims to ensure that connected borrowers are not treated preferentially in comparison to non-connected borrowers, i.e. the same criteria as those stipulated by the relevant Credit Policies of the Bank shall apply for connected borrowers. The Policy establishes the basic rules applying in extending credits and in the treatment of forbearance and restructuring requests concerning loans of connected borrowers, while monitoring of appropriate implementation of the Policy is facilitated through special functionality that has been developed in the Bank's system for this purpose.

The Code of Ethics has been formulated on the basis of the fundamental ethical values that the Bank applies in the course of its business activities and the provisions of national, European and international legislation and regulations which, accordingly, concern management and employees throughout the Bank and its Group in order to protect the interests of employees, clients and shareholders, ensure the proper operation of the Group, and maintain and enhance the reliability, solvency and reputation of the Bank and its Group. The Code of Ethics was updated in December 2015.

The Code of Ethics is available on the Bank's website www.nbg.gr (section: The Group/Corporate Governance/Regulations & Principles)

In compliance with the provisions of the Corporate Governance Code, the Bank has entered into a multi insurance contract in order to cover the Directors and Executives of all the Group entities, with respect to the civil liability for claims against the Bank and its subsidiaries arising from negligence, error or oversight by Directors, Executives and employees, and damages arising from fraud, including electronic fraud.

The Code of Ethics for Financial Professionals 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 is complete, accurate, timely and comprehensive, and that all such information is presented in accordance with applicable rules and regulations.

The Code of Ethics for Financial Professionals is available on the Bank's website www.nbg.gr (section: The Group/Corporate Governance/Regulations & Principles).

The Bank, in compliance with the U.S. legal and regulatory framework and SEC rules as well as the relevant provisions of Bank of Greece Governor's Act 2577/March 9, 2006, as amended, has established a Whistleblowing Policy that sets out procedures for the submission of confidential reports or comments 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 about irregular or illegal actions related to accounting and auditing matters, which are inconsistent with international practices and regulations. The policy also covers the provisions of Greek Law 4261/2014.

The Audit Committee of the Bank is responsible for the adoption and ongoing monitoring of the implementation of these procedures, which safeguard the confidentiality and anonymity of the received reports or comments.

The Bank's website at www.nbg.gr (section: The Group/Corporate Governance/Contact Information/Contact Audit Committee), provides the contact information for the submission of confidential reports.

The Bank and Group Anti-Bribery Policy further enhances the corporate governance procedures of the Bank and Group, and in particular, the framework that sets out the various rules adopted in order to address bribery issues, as stipulated in the relevant provisions of the Code of Ethics and the Bank's Labor Regulation.

The Bank's website www.nbg.gr (section: NBG Group Compliance) provides additional information on the Anti-Bribery Policy.

The Bank's and the Group's Remuneration Policy was adopted in 2010, in accordance with Management Act No 7/ June 9, 2010 of the Department for the Supervision of Credit and Financial Institutions of the Bank of Greece and was amended in 2012 to become fully aligned with the provisions of Bank of Greece Governor's Act 2650/January 19, 2012, while it is in accordance with the applicable framework to which the Bank is subject and best practices. Remuneration of the Chairman, the Chief Executive Officer ("CEO") as well as other members of the Board of Directors, the General Managers and their deputies should not exceed the Bank of Greece Governor's remuneration. Any other type of additional remuneration (bonus) of the aforementioned persons is abolished for the period during which the Bank participates in the Recapitalization Plan of the HFSF Law. The Bank's remuneration practices are in compliance with all applicable regulatory framework (especially Greek Law 4261/2014, which transposed European Directive 2013/36/EU (CRD IV)), while also complying with the Commitments towards the Bank's Monitoring Trustee. The amendment of the Policy has

already been scheduled to be completed within 2016, taking into consideration among others the recent Guidelines on remuneration issued by the European Banking Authority in December 2015 which are applicable from January 2017.

Information on the Bank and Group Remuneration Policy and general remuneration practices is available on the Bank's website at www.nbg.gr (section: The Group/Investor Relations/Annual Reports and Offering Circulars).

The Bank has adopted a Corporate Social Responsibility (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. In 2016 its amendment has been programmed in the context of international best practices and principles.

The CSR policy is posted on the Bank's website, at www.nbg.gr (section: The Group/Corporate Social Responsibility/CSR framework).

The Bank complies with the applicable Corporate Governance framework, which it has adopted and implemented, as same is provided for under the provisions of Greek legislation (mainly the provisions of Codified Greek Company Law 2190/1920, of Laws 3016/2002, 3693/2008 and 3873/2010, Hellenic Capital Market Commission decision No 5/204/2000, and Bank of Greece Governor's Act 2577/2006), the Bank's regulations and Articles of Association, and international corporate governance best practices.

Five Committees have been set up and operate at Board level. Respective charters have been posted on the Bank's website, at www.nbg.gr (section: The Group / Corporate Governance / Board of Directors / Committees). The Committee members are remunerated annually for their participation in each. Furthermore, in the context of the HFSF Law, as in force, a Board of Directors Committee responsible for monitoring of Non-Performing Loans ("NPL's") will be established.

It shall be noted that, an update of the Board Committees' Charters where this is deemed appropriate in line with the new provisions of the HFSF Law and the Amended Relationship Framework Agreement between the Bank and the HFSF is in progress.

The Audit Committee was established in 1999 and operates in accordance with the provisions of the Bank of Greece Governor's Act No. 2577/2006, Greek Law 3693/2008 (article 37) and the Sarbanes Oxley Act.

The members of the Committee are elected by the General Assembly upon recommendation of the Corporate Governance & Nominations Committee to the Board Chairman. The Chairman and the Vice Chairman of the Committee are appointed by the Board. The Committee is currently composed of three non-executive Directors, two of whom are independent and one of whom (Petros Sabatacakis) is the financial expert, advisor on issues related to the US Securities and Exchange Commission. The Committee's members are appointed for a one-year term of office, which can be renewed indefinitely. The Committee employs a specialized consultant who reports directly to the Chairman of the Committee. The Committee convenes regularly at least six times per annum or extraordinarily, whenever deemed necessary, keeps minutes of its meetings and reports to the Board every three months or more frequently if deemed necessary.

The election of the members of the Committee in accordance with the provisions of Greek Law 3693/2008 was carried out by decision of the GM of June 19, 2015, following recommendation by the Board's Corporate Governance & Nominations Committee and the Board. The members were appointed for a one-year term of office.

During 2015, the Audit Committee convened sixteen times. During the course of the year, the Committee updated its Charter, which was submitted and approved by the Board on January 29, 2015. In June 2015, the Committee reviewed the Annual NBG Group Compliance Report, in accordance with the provisions of the Bank of Greece Governor's Act No. 2577/2006, while the Audit Committee was also informed about the activities of the Audit Committees of NBG Group subsidiaries, in compliance with the Sarbanes-Oxley Act ("SOX"). Furthermore, the Committee reviewed the quarterly and annual financial statements of the Bank and the Group, monitored on a quarterly basis and evaluated on an annual basis the operations of the NBG Group Internal Audit and Compliance Divisions, and assessed the adequacy of the Internal Control System in line with Bank of Greece Governor's Act No. 2577/2006. Furthermore, the Committee was informed concerning developments in the International Accounting Standards, the US Securities and Exchange Commission, the Public Company Accounting Oversight Board principles as well as the SOX controls process. The Committee approved the Internal Audit Division Work Programme for 2016. Lastly, the Committee made recommendations to the Board regarding the appointment of the Bank's external auditors for the annual and semi-annual Financial Statements for the year ended 2015, approved their audit and non-audit fees and had regular meetings with them in order to discuss their audit findings.

Detailed information on the responsibilities, composition and modus operandi of the Committee are included in the Committee's charter on the Bank's website, at www.nbg.gr (section: The Group/Corporate Governance/Board of Directors/Committees).

The Committee members receive remuneration for their participation in the Committee.

The Human Resources and Remuneration Committee ("HRRC") was established by Board decision (meeting no. 1259/May 5, 2005).

The Committee solely consists of non-executive members of the Board, which are at least three in number, and in their majority (including the Chairman) are independent Board members, in accordance with the definition of independence specified in the Bank's Corporate Governance Code. The Committee composition includes members possessing experience in the financial sector, while at least one member possesses significant expertise, skills and professional experience in risk management and audit activities, in order to be able to contribute to the alignment of remuneration with the risk and capital profile of the Bank.

The members and Chairman of the Committee are elected by the Board of the Bank, following recommendation by the Board's Corporate Governance & Nominations Committee. The Committee members shall be selected on the basis of their competence and experience.

The Committee convenes at least three times a year and keeps minutes of its meetings.

In 2015, the HRRC convened four times. During the year, the HRRC approved the Board of Directors and Board of Directors Committee members' remuneration for fiscal year 2014 and determined remuneration of the Chairman, the Chief Executive Officer, Deputy Chief Executive Officers and non-executive members of the Board until the General Meeting of 2016. Further, the Committee dealt with the contracts, renewals, promotions and appointments of General Managers and Assistant General Managers of the Bank.

Detailed information on the responsibilities, composition and modus operandi of the HRRC are included in the charter of the HRRC posted on the Bank's website, at www.nbg.gr (section: The Group/Corporate Governance/Board of Directors/Committees).

The Committee members receive remuneration for their participation in the Committee.

The Committee is composed of at least three Board members. The members and Chairman of the Committee are elected by the Board of the Bank. All members of the Committee are non-executive Board members and in their majority independent members of the Board, in accordance with the definition of independence specified in the Bank's Corporate Governance Code. The Committee's members are appointed for a one—year term of office, which can be renewed indefinitely. The Committee convenes at least three times per annum and keeps minutes of its meetings.

In 2015, the CGNC convened seven times. During the year, the Committee updated the Bank's Corporate Governance Code as regards the procedures for convocation of the Board and its Committees, which was approved by the Board at its meeting held on September 24, 2015. Furthermore, the Committee reviewed the current composition of the Board in line with the existing legal and regulatory framework, especially with Greek Laws 3016/2002, 4261/2014 and the Relationship

Framework Agreement between the Bank and the HFSF, as well as in line with the internal regulations of the Bank on corporate governance.

Detailed information on the responsibilities, composition and modus operandi of the CGNC are included in the CGNC's charter posted on the Bank's website, at www.nbg.gr (section: The Group/Corporate Governance/Board of Directors/Committees).

The Committee members receive remuneration for their participation in the Committee.

The Board Risk Committee was established by Board decision (meeting no. 1308/July 20, 2006) in accordance with the requirements of Bank of Greece Governor's Act No. 2577/March 9, 2006.

The Committee is composed exclusively of non-executive Board members, at least three in number, the majority of which (including the Chairman) are independent members of the Board, in accordance with the definition of independence specified in the Bank's Corporate Governance Code. The members and the Chairman of the Committee are elected by the Board of the Bank, following recommendation by the Board's Corporate Governance & Nominations Committee. All members should have adequate knowledge and prior experience in banking and financial services, while at least one member as an expert (Mr Sabatacakis and Mr Makkas) should have significant experience in risk and capital management, as well as knowledge of the local and international regulatory framework.

The Committee convenes regularly at least on a monthly basis, as well as extraordinarily, whenever deemed necessary by its Chairman.

During 2015, the BRC convened eleven times. In 2015 the Committee was informed in detail on a regular basis, and consulted, concerning the risk appetite of the Bank, reviewed the Risk Appetite Statement & Metrics for the year 2015, as well as the Risk Strategy of the Group and provided relevant information to the Board of Directors. Furthermore, the Committee approved the Risk Management Report concerning the Internal Capital Adequacy Assessment Process" 2014, as well as the Internal Liquidity Adequacy Assessment Process 2014, which were approved by the Board meeting held on April 30, 2015.

Detailed information on the responsibilities, composition and modus operandi of the Committee are included in the Charter of the Committee (which was last updated by the Board on November 27, 2013) available on the Bank's website at www.nbg.gr (section: The Group/Corporate Governance/Board of Directors/Committees).

The Committee members receive remuneration for their participation in the Committee.

The Strategy Committee was established by Board decision (meeting no. 1387/September 29, 2009). The Committee supports the executive Board members in developing the Group's strategic options, assists the Board in taking decisions on all issues related to NBG Group strategy and regularly reviews the implementation of the Group's strategy by the Group's management team. The Committee is composed of seven members, of which three are independent non-executive Board members. The Chief Executive Officer participates ex officio as a member in the Committee. The Committee is chaired by the Chair of the Board of Directors.

The Committee members are appointed by the Board upon recommendation of its Chairman, who consults with the Corporate Governance & Nominations Committee to this effect. The Committee members shall be selected on the basis of their competence and experience and appointed for a one-year term of office, which can be renewed indefinitely. The Committee convenes at least three times per annum and as regularly as deemed necessary in order for matters to be discussed prior to their assessment by the Board and reports regularly to the Board.

In 2015, the Strategy Committee convened six times. During the year, the Committee was involved in matters such as strategic restructuring, decisions concerning NBG Group companies, and the 2015 budget. Furthermore, the Committee was involved in matters such as organization and management of IT projects, the IT master plan, IT projects of subsidiaries, compliance with the Capital Controls framework, and in further designing and project planning. The Committee reviewed and updated the Group's strategic pillars in connection to the recapitalization of Greek banks in 2015. Lastly, in accordance with current developments, the Committee proceeded with strategic planning of the Management's next actions.

Detailed information on the responsibilities, composition and modus operandi of the Committee are included in the Committee's charter has been posted on the Bank's website, at www.nbg.gr (section: The Group/Corporate Governance/Board of Directors/Committees).

The Committee members receive remuneration for their participation in the Committee.

The Senior Executive Committee was established in 2004 and operates according to its Charter. It is the supreme executive body that supports the Chief Executive Officer of the Bank in his duties. The Senior Executive Committee has strategic and executive powers in regard to the more efficient operation of the Group and the monitoring of the execution of the Bank's business plan, as well as approval authority that cannot be delegated to other members of the Bank's management or to other collective bodies of the Bank. In April 2015 it was determined that the Senior Executive Committee will carry out the activities of the Risk Management Council.

The Committee is convened at the invitation of its Chairman and meets regularly at least two times every calendar month and ad hoc, whenever deemed necessary by its Chairman.

At the invitation of its Chairman, it is possible for General Managers as well as other Bank executives to attend the meetings of the Senior Executive Committee, the presence of which is deemed necessary, while in the event of discussion of risk management issues, the Assistant General Manager of Risk Management of the Bank and the Group and Chief Risk Officer participates in the meetings. Furthermore, Mr. Omer Aras, Chairman and Group Chief Executive Officer of Finansbank, is invited every two months so as to inform the Senior Executive Committee on issues related to international activities and Finansbank.

Members' short CVs have been posted on the Bank's website www.nbg.gr (section: The Group/ Corporate Governance/Management and Organizational structure/Members).

The Committee members do not receive any remuneration for their participation in the Committee.

ALCO was established in 1993. The Committee's key purpose is to establish the Bank's and its Group financial sector entities' strategy and policy as to matters relating to the structuring and management of assets and liabilities, taking into account the current regulatory framework and market

conditions, as well as the risk limits set by the Bank. The Committee is currently comprised of the following members:

The Committee is convened at the invitation of its Chairman, once per month and ad hoc as deemed necessary. The Chairman can invite other executives of the Bank and Group to attend, if necessary.

The Committee members do not receive any remuneration for their participation in the Committee.

The Executive Credit Committee was established in 2008 and its purpose is the optimization and the sound operation of the risk taking limits. The Committee is comprised of the following members:

The Assistant General Manager of Legal Services, Mr. Georgios Triantafillakis, is invited and attends the meetings of the Committee.

The Committee is convened at the invitation of its Chairman, at least twice per month and ad hoc as deemed necessary by its Chairman. The Chairman can invite other executives of the Bank and the Group to attend, if necessary.

The Committee members do not receive any remuneration for their participation in the Committee.

The Disclosure and Transparency Committee was established in 2003. Its purpose is to monitor the accuracy and completeness of the information included in public announcements and in any publications issued by the Bank, especially those included in the informative documents submitted to SEC, monitoring and submission of proposals for the improvement of the procedures carried out for the collection, assessment and timely disclosure of information required by the relevant legal framework, and generally for compliance with the legal and regulatory framework concerning the obligations for accurate and timely disclosure of information.

The Committee is convened at the invitation of its Chairman, at least twice per annum and ad hoc as deemed necessary.

The Chairman can invite other executives of the Bank and Group to attend, if necessary.

The Committee members do not receive any remuneration for their participation in the Committee.

The Committee was established in 2010. Its purpose is the decision making process on the provisions and write-offs of NBG Group claims of any nature, which are considered by the Committee to be liable of a loss in value in accordance with the relevant "Provisions and Write Offs Policy" of NBG Group.

The Chairman can invite other executives of the Bank and Group to attend, if necessary.

The Committee members do not receive any remuneration for their participation in the Committee.

The Crisis Management Committee was established in 2012 and is the executive body with responsibilities over the Business Continuity Plan ("BCP"). The Committee acts upon every sudden and unforeseen change of conditions (relating to operational, business, environmental and personnel issues) which can lead to a crisis that may have strategic impact consequences, and aims to effectively coordinate the actions necessary to deal with unforeseen situations which may jeopardize the smooth operation of the Bank. Specifically, it is in charge of informing, mobilizing and coordinating the Bank's relevant units, taking into account the nature, extent and the size of the crisis; and solving problems that require immediate attention.

At the invitation of its Chairman and depending on the issues discussed, it is possible for General Managers, Assistant General Managers, the General BCP Coordinator as well as other Bank executives, the presence of which is deemed necessary, to attend the meetings of the Committee.

The Committee members do not receive any remuneration for their participation in the Committee.

The Compliance & Reputational Risk Committee was established in 2013. The Committee ensures the adequacy of the Bank's and the Group's controls that enable compliance with the regulatory framework as well as with the Policies of the Bank and the Group. Additionally, the Committee ensures that the management of reputational risk is in accordance with the risk appetite that has been approved by the Board of Directors and with the creation of long-term value for shareholders.

The Committee is convened at least quarterly and ad hoc as deemed necessary at the invitation of its Chairman.

The Chairman can invite other executives of the Bank and Group to attend, if necessary.

The Committee members do not receive any remuneration for their participation in the Committee.

As at December 31, 2015, the Bank employed a total of 10,723 staff of which 253 are occupied in the Bank's foreign branches, compared to 10,205 and 258 respectively, as at December 31, 2014 and 12,527 and 252 respectively, as at December 31, 2013. Additionally, the Group's subsidiaries in Greece and abroad employed approximately 23,252 employees as at December 31, 2015, compared to 23,924 as at December 31, 2014 and 25,064 as at December 31, 2013. As at December 31, 2015 Group-wide

temporary employees were 61. The table below sets forth the average number of our employees by geographic location for 2015:

The table below sets forth the main categories of activity in which our employees were engaged, during 2015:

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 companies. 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. A new collective labor agreement was entered into on July 1, 2013.

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 2 days in 2014, largely to express their opposition to the new austerity measures implemented in light of the Program.

In light of the Group's strategy to streamline its operations and maximize efficiency, voluntary retirement schemes have been implemented. On December 19, 2013, the Bank announced the implementation of a VRS. The deadline for applications was on December 20, 2013 up to December 30, 2013. Approximately, 2,500 employees participated (see Note 40 to the U.S. GAAP Financial Statements).

Moreover, on September 12, 2014, EH announced of the implementation of a VRS. The deadline for employee applications to participate in the VRS was September 22, 2014. Approximately 29 employees participated in the VRS. By taking into account the untaken leave for these employees, the additional VRS expense amounted to EUR 4 million. It is also estimated that the decrease in the Company's payroll base on an annual basis will be approximately EUR 2.5 million.

In accordance with Greek Law 3655/2008, applicable from April 2008, the Bank's main pension plan and the main pension branch of EH's post-employment and health plan, both of which are defined-contribution plans, have been incorporated into the main pension branch of the Hellenic Republic sponsored social security fund IKA—ETAM as at August 1, 2008. Pursuant to this legislation, the Bank will contribute EUR 26 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% on the basis of an employee's gross salary. 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 starting from 2013, until they reach 13.3% (from 20.0%) for employees 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 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.

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 salary. Under Greek Law 3371/2005 employees hired after January 1, 2005 are insured in the single auxiliary social security fund ("ETEAM"). The Bank has been paying contributions to ETEAM since May 1, 2007.

In accordance with Greek Law 4052/2012 (GG A' 41), a new auxiliary fund called the Integrated Auxiliary Pension Fund ("ETEA") was established on July 1, 2012. ETEA includes, among others, ETEAM and, according to transitional provisions of the same law (GG A' 256/2012), from January 1, 2013, the ETAT Fund is mandatorily included as regards only auxiliary schemes. However according to the Legislative Act of the Greek Cabinet (GG A' 256/31.12.2012) the ETAT Fund retains the obligation to grant pension allowances (which pertain to the period prior to the main pension of an employee) to the beneficiaries of the auxiliary pension schemes which have been integrated into ETAT under Greek Law 3371/2005. Moreover, the ETAT Fund, according to the provisions of its charter as provided for by Greek Law 3371/2005 maintains the capacity to act as a fund into which auxiliary social security pension funds could be assimilated.

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 either to ETAT or to ETEA in relation to this merger depending on which of the two aforementioned funds is part of the planned merger. 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".

Furthermore, Greek Law 3863/2010, as further implemented by Greek Law 4033/2012 and 4254/2014, substantially amended 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.

At the repeat General Meeting of the Shareholders 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. No stock options have been granted under this program.



Louka P. Katseli	—	—
Leonidas E. Fragkiadakis	170,705	5,585
Dimitrios Dimopoulos	35,222	2,307
Paul Mylonas	33,416	—
Stavros A. Koukos	37	387
Efthymios C. Katsikas	107	1.112
Dimitrios N. Afendoulis	—	—
Spiridon J. Theodoropoulos	—	—
Petros K. Sabatacakis	—	—
Angeliki Skandaliari	7,523	244
Charalampos A. Makkas	—	—
Damianos Charalampidis	241,900	31,045
Nelly Tzakou-Lambropoulou	30,103	267
Dimitrios Kapotopoulos	26,686	211
Ioannis Kyriakopoulos	—	—
Panagiotis Dasmanoglou (non-voting right)	800	—
Georgios Triantafillakis (non-voting right)	17,435	7,212
Total	563,934	48,370

The cumulative percentage of total common shares outstanding stated above, as at April 20, 2016 is 0.0062%.

As at April 20, 2016, the Bank's outstanding issued share capital consisted of 9,147,151,527 common shares of a nominal value of EUR 0.30 each.

The following table sets forth certain information regarding holders of the Bank's common shares, based on information known to or ascertainable by the Bank.

The Bank's ordinary shares are listed for trading on the Athens Exchange (ATHEX).

The Bank's Articles of Association do not impose restrictions on the transfer of the common shares of the Bank. The disposal of the common shares (134,820,022) in the Bank that the HFSF has acquired in the context of participating in the Bank's 2013 recapitalization share capital increase is subject to the restriction and process provided for by the HFSF Law, article 8, as currently applicable, and Cabinet Act no 38/2012, article 3 par.7 (See Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Financial Stability Fund—The Greek Recapitalization Framework—Provision of Capital Support by HFSF").

For powers vested in the HFSF pursuant to its participation in the 2013 and 2015 Recapitalization share capital increase of the Bank under the HFSF Law, also see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Financial Stability Fund—The Greek Recapitalization Framework—Provision of Capital Support by HFSF—Powers of HFSF".

Other than the above, 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 apart from HFSF beneficially owns 5% or more of the Bank's common shares.

The Bank of New York Mellon is the depositary of the Bank's ordinary shares represented by ADRs. On April 20, 2016, the portion of the Bank's common shares held in the United States in the form of ADRs as a percentage of total shares outstanding was approximately 4.05%.

Article 16 of Greek Company Law 2190/1920, prescribes provisions for the acquisition of own shares, pursuant to a General Meeting resolution. However, as long the Bank participates in the Hellenic Republic's Bank Support Plan (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic's Bank Support Plan")and pursuant to the restrictions imposed by the related Greek Law 3723/2008 (article 1, as amended by Greek Law 3756/2009), the

Bank is not allowed to repurchase any own shares. Moreover, according to article 16C of the HFSF Law during the period of HFSF participation in the capital of the Bank, it is prohibited for the Bank to purchase own shares without HFSF approval.

In the context of the Recapitalization, the HFSF acquired 40.4% or 3,694,689,182 of the Bank's share capital though holding shares of which 134,820,022 falling under the restrictions of article 7a par. 2 of the HFSF Law (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Financial Stability Fund—The Greek Recapitalization Framework—Provision of Capital Support by the HFSF—Powers of the HFSF").

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 32 to the U.S. GAAP Financial Statements for details.

All loans granted to related parties (except for the loans granted to employee benefits related funds) (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 collectability or present other unfavorable features.

Please refer to Item 18 to the U.S. GAAP 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.

The Bank 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, 2014 and 2015 the Group has accrued for cases under litigation the amount of EUR 67 million and EUR 62 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.

Current provisions applying to the Bank under the Hellenic Republic Support Plan and the HFSF recapitalization framework

Under Greek Law 3723/2008 setting forth the terms of the Hellenic Republic Bank Support Plan, the representative of the Hellenic Republic appointed to the Board of Directors may veto any resolution relating to dividend distribution, pursuant to a decision of the Minister of Finance, or if it is determined that such resolution may jeopardize the interests of the Bank's depositors or materially affect its solvency and orderly operation. In addition, pursuant to the HFSF Law, and in line with the provisions of the Amended Relationship Framework Agreement with the HFSF, the HFSF's representative who sits on the Board of Directors also has the veto right over decisions regarding the distribution of dividends.

In line with the provisions of the HFSF Law, while the Bank participates in the recapitalization program under the said Law, as currently applies, distribution of dividends may not exceed 35% of net profits, as these are particularly determined within Greek Law 148/1967, as in force.

In addition, because the Bank has issued CoCos to the HFSF as part of the recapitalization completed in December 2015, as described under Item 3D.,"Risk Factors—The Bank may be legally restricted from paying dividends", and in line with the provisions of Cabinet Act 36/2015, no dividend shall be paid on the Bank's shares, in case the Bank has elected not to pay interest on the CoCos during the previous interest payment date.

Finally, according to Article 16C of the HFSF Law, as long as the HFSF participates in the capital of credit institutions, the latter are not allowed to purchase own shares without the HFSF's prior approval, while also, within the context of Greek Law 3723/2008 as in force, it is prescribed that as long as credit institutions participate in the Hellenic Republic Bank Support Plan, purchase of own shares is prohibited, according to the particular provisions of the said Law as supplemented by Article 28 of Greek Law 3756/2009, as in force.

Provisions on Payments of Dividends in line with the Capital Requirements Directive and Greek Company Law

Payment of dividends by the Bank is also subject to compliance with the Capital Requirements Directive (Directive 2013/36/EU transposed into Greek Law 4261/2014), Greek Company Law 2190/1920, and its Articles of Association.

In particular, the Bank's profit for a relevant period would 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 mandatory reserves, whose distribution is prohibited by law or its Articles of Association.

The distributable profits shall not exceed the results of 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 by the General Meeting), less any losses carried forward and any amounts required by law or its 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.

Pursuant to relevant legislation, the Bank may also distribute interim dividends at the discretion of its Board of Directors, so long as it submits at least 20 days before the distribution of such dividends to the Ministry of Economy, Development and Tourism an accounting statement of the Bank, and while fulfilling publicity requirements in line with article 46 of Greek Company Law 2190/1920. Interim dividends may not exceed one-half of the net profits, as stated in such accounting statements.

Pursuant to Article 131 of the CRD Law (which transposed into Greek Law article 141 of the CRD IV Directive), the Bank may not make, inter alia, dividend payments, if and to the extent that such payment, when aggregated with other distributions in connection with CET1 referred to in paragraph 1 of Article 131 of the CRD would exceed the Maximum Distributable Amount. In particular, under Article 131 of the CRD Law, credit institutions that meet the combined buffer requirement, are prohibited from making a distribution in connection with CET1 to an extent that would decrease its CET1 capital to a level where the combined buffer requirement is no longer met, whereas credit institutions that fail to meet the "combined buffer requirement" must determine a Maximum Distributable Amount to be calculated in accordance with the provisions of the CRD Law and notify such Maximum Distributable Amount to the Bank of Greece. In the latter case, the credit institution shall not undertake any of the following actions before it has calculated the Maximum Distributable Amount: (a) make a distribution in connection with CET1 capital; (b) create an obligation to pay variable remuneration or discretionary pension benefits or pay variable remuneration if the obligation to pay was created at a time when the institution failed to meet the combined buffer

requirements; (c) make payments on Additional Tier 1 instruments While an institution fails to meet or exceed its combined buffer requirement, it shall not distribute through any action referred to in the preceding paragraph more than the Maximum Distributable Amount calculated in accordance with article 131 of Greek Law 4261/2014. The above requirement for restrictions on distributions shall apply during the transitional period between January 1, 2016 and December 31, 2018 where institutions fail to meet the combined buffer requirement.

The restrictions will be scaled according to the extent of the breach of the "combined buffer requirement" and calculated as a percentage of the profits of the institution since the last distribution of profits or "discretionary payment". Such calculation will result in a Maximum Distributable Amount in each relevant period. As an example, the scaling is such that in the first (that is the lowest) quartile of the "combined buffer requirement", no "discretionary distributions" will be permitted to be paid. In the event of a breach of the "combined buffer requirement", the Bank will be required to calculate its Maximum Distributable Amount, and as a consequence it may be necessary for the Bank to reduce discretionary payments, including by exercising its discretion to cancel (in whole or in part) dividend payments. The "combined buffer requirements" will be breached if the Bank fails to meet one of the minimum capital ratios applicable to the Bank, as well as, in certain other circumstances.

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, 2015, the date of the last audited financial statements included in this Annual Report, see Note 45 to the U.S. GAAP Financial Statements which describes post-balance sheet events.

The Bank's shares have been listed on the ATHEX since the foundation of the exchange in 1880.

From October 1999 to November 27, 2015, the Bank's shares had also been listed on the NYSE and traded in the form of ADRs. The Bank's ADRs representing the ordinary shares were suspended from trading on the NYSE on November 27, 2015 due to abnormally low price levels of the Company's American Depositary Shares, pursuant to Section 802.01D of the NYSE Listed Company Manual, and were delisted from the NYSE as of December 17, 2015. The ADRs are currently traded only in the U.S. over-the-counter market under the symbol "NBGGY". Each ADR represents one share.

The annual high and low market prices of the Bank's shares on the ATHEX for the five most recent completed financial years and the year 2016 (through May 12, 2016) are shown below, expressed in Euro.

The price of the ordinary shares in each period is adjusted to reflect the two-for-nine rights issue that took place in July 2009, the twenty three-for-forty rights issue (through common shares and convertible bonds mandatorily converted into new common shares) that took place in September 2010,

the share-for-share merger with Eurobank that took place in February 2013, the ten-to-one reverse split that took place in May 2013, the rights issue that took place in June 2013, the rights issue that took place in May 2014 without pre-emptive rights, the rights issue that took place in November 2015 without pre-emptive rights and the fifteen-to-one reverse spit that took place in December 2015.

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 until May 12 2016 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 and up to May 12, 2016, are presented in the table below, expressed in Euro.

Other than the suspension of trading of shares on the ATHEX in anticipation of the announcement of the acquisition of Finansbank in 2006 and the reverse split, during the 2013 rights issue, and the general suspension of trading of securities on the ATHEX from and including June 29 to and including July 31, 2015, there have been no trading suspensions with respect to the Bank's shares on the ATHEX in the years ending December 31, 2013, 2014 and 2015 or the year 2016 up to May 12.

The Bank's ADRs representing the ordinary shares were suspended from trading on the NYSE on November 27, 2015 and were delisted from the NYSE as of December 17, 2015. The ADRs are currently traded only in the U.S. over-the-counter market under the symbol "NGBBY". Therefore the information presented below, for the period November 25, 2015 up to May 12, 2016 include prices derived from the over-the-counter market.

The annual high and low market prices of the Bank's ADRs, expressed in U.S. dollars, for the five most recent financial years and up to April 20, 2016:

The quarterly high and low market prices of the Bank's ADRs, expressed in U.S dollars for the two most recent financial years are shown below,

The high and low market prices, of the Bank's ADRs evidencing common shares for the first quarter of 2016, expressed in U.S dollars are shown below,

The monthly high and low market prices of the Bank's ADRs, expressed in U.S dollars, for the six most recent months and up to May 12, 2016 are shown below, expressed in USD.

The trading of the Bank's shares on the ATHEX and of ADRs on the New York Stock Exchange was suspended on October 5, 2012, in anticipation of the announcement of the Eurobank acquisition and from May 24, 2013 to May 29, 2013 in order to incorporate the Bank's share reverse split.

Other than the aforementioned suspensions there have been no trading suspensions with respect to the Bank's shares on the ATHEX.

Pursuant to a Cabinet Act dated December 7, 2015, all the non-cumulative U.S. Preference Shares, issued by the Bank were converted into newly issued ordinary shares of National Bank of Greece S.A.

Consequently, American Depositary Shares, Series A were mandatorily converted into American Depositary Shares, each representing one ordinary share of National Bank of Greece S.A. On December 17, 2015, the American Depositary Receipts representing the U.S. Preference Shares were delisted from 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. The Hellenic Exchanges—Athens Exchange S.A. Holding (the "HELEX") is the company licensed by the HCMC to operate the ATHEX, and owns 100% of the "ATHENS EXCHANGE CLEARING HOUSE" (the "ATHEX clear") and of the Hellenic Central Securities Depository, S.A. and is listed on the ATHEX.

On May 31, 2001, the ATHEX was upgraded by the Morgan Stanley Composite Index from emerging to developed markets status. On November 26, 2013, ATHEX was downgraded by the Morgan Stanley Composite Index from developed to emerging market status. During its September 2015 annual review, FTSE demoted Greece from Developed to Advanced Emerging due to the extended market closure in the summer of 2015, imposition of capital controls on domestic investors and continued economic instability. The demotion was implemented on March 21, 2016.

ATHEX is regulated among others by the first edition of the Athens Exchange Regulation (the "ATHEX Regulation"), which was issued following its authorization by Greek Law 3152/2003, and came into force on June 16, 2004. Under Greek Law 3606/2007, which transposed into Greek Law the Markets in Financial Instruments Directive (the "MiFID Law" and the "MiFID", respectively), a revised ATHEX Regulation was issued and came into force on July 22, 2008. The currently applicable Codified ATHEX (the latest amendment being effective from February 9, 2015) 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 person towards which the ATHEX Regulation introduces rights and obligations.

The ATHEX operates two regulated markets: the securities market and the derivatives market. The securities of companies listed on the securities market are classified into one of the following eight segments: (a) the general segment (which is the "Main Market"); (b) the fixed income securities trading segment; (c) the warrants trading segment (d) the SFP (Structured Financial Products) Trading Segment; (e) the exchange traded funds segment; and the special categories of (f) low free float, (g) under surveillance; and (h) to be delisted. When securities, other than units in listed mutual funds, debts securities and structured financial products, are listed for the first time on the securities market they will fall within the general category, which is the Main Market.

The 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 HELEX 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 to regulated markets and impose strict admission and ongoing requirements do not apply to EN.A. EN.A. is supervised by the HCMC.

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 relevant decisions issued by the Board of Directors of the ATHEX and the ATHEX Regulation.

In 2015, the average daily trading value on the ATHEX was EUR 86 million, compared with EUR 127million in 2014, which represents a decrease of 32.5%.

From January 4, 2016 up to April 20, 2016 the average trading value on the ATHEX was EUR 68 million.

At the end of March 2016, 219 companies had shares listed on the Main Market of the ATHEX. On April 20, 2016, the total market capitalization of the ATHEX was EUR 41.7 billion, with the top 25 companies accounting for 80.6% of the total market capitalization, and the Bank's market capitalization was 5.8% of the total.

Effectively, the last day when trades took place during the first half of 2015 was June 26, 2015, as a short-term bank holiday was imposed by emergency decree (Government Gazette A' 65/28.6.2015) from June 29 up to and including July 17, 2015. The bank holiday was terminated on July 20, 2015 (Government Gazette A' 84/18.7.2015) while restrictions on bank transactions remained in effect. The Athens Exchange Market (ATHEX) remained closed (from June 29, 2015) up to and including July 31, 2015. ATHEX resumed trading on Monday August 3 (Government Gazette B' 1617/31.7.2015).

As of December 31, 2015, 229 companies had shares listed on the cash market of the ATHEX. On December 31, 2015, the total market capitalization of the ATHEX was EUR 46.7 billion, with the top 25 companies accounting for 80.6% of the total market capitalization, and the Bank's market capitalization was 6.7% of the total.

Membership is required for investment services firms ("ISF") and for banks 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 bank). 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.

Members of the ATHEX 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 ATHEX Regulation, ISFs established in the EU or the European Economic Area 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 60 leading Greek companies, listed today under the large cap category.

Other ATHEX composite indices are the FTSE/ATHEX large cap index which tracks the movements of the 25 largest companies by capitalization and the FTSE/ASE MidCap which tracks the movements of medium sized companies by capitalization.

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, as amended and currently applicable: for the Main Market, the pre-trading session is from 10:15 to between 10:29 and 10:30, continuous trading from 10:30 to 17:00, the closing auction session from 17:00 to between 17:09 and 17:10 and trading at the closing session from 17:10 to 17:20. The Intraday Auction of the Main Market occurs only every 3rd Friday of each month. The auction session is from 13:45 to between 13:59 and 14:00. The ATHEX Regulation and the Decision 22/2008 of the Board of Directors of the ATHEX, as amended and currently applicable, contain 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 traded on the Main Market are eligible for maximum +/–30% fluctuations from the "opening price" (as defined in the ATHEX Regulation) and Decision 22/2008 of the Board of Directors of the ATHEX, as amended and currently applicable). The rights on shares of this category fluctuate freely, i.e., without restrictions. All market prices of shares traded under the special categories mentioned above are eligible for maximum +/–20% fluctuations from the "opening price" (as defined in the ATHEX Regulation and Decision 22/2008 of the Board of Directors of the ATHEX, as amended and currently applicable). Rights on shares of these categories also fluctuate freely, i.e., without restrictions. Finally, securities traded under the fixed income securities category are allowed to fluctuate freely, i.e., without restrictions, while units traded in the exchange traded funds category are allowed to fluctuate up to +/–30% from the "opening price" (as defined in the ATHEX regulation, as currently applicable, and Decision 22/2008 of the Board of Directors of the ATHEX, as amended and currently applicable). Moreover, pursuant to the ATHEX Regulation and Decision 22/2008 of the Board of Directors of the ATHEX, as amended and currently applicable, the ATHEX introduced volatility interrupters to check abrupt share price changes on shares traded on the Main Market. In general, volatility interrupters allow for the imposition of limits on the prices at which transactions are performed, the automated cessation of trading of a share and the carrying out of a call auction, when the following limits are exceeded: (i) the share price changes 10% or more from the opening price; and (ii) the transaction to be carried out represents a variation of 3% 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 Decision 22/2008 of the Board of Directors of the ATHEX, as amended and currently applicable.

In simple block trades of shares with an "average daily turnover" (as defined in the ATHEX Regulation) that is:

The aforementioned provisions regarding block trades became effective as at 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 OTC transaction is effected, on the transfer value applies for both parties, currently varying between 0.0325% and 0.08%.

Subject to the restrictions applicable in Greece regarding the transfer of funds abroad or acquiring shares listed on the ATHEX, (please refer to Item 4.B "Business Overview—Regulation and Supervision of Banks in Greece"), there are no other 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.

The "HCSD" charges a settlement fee (currently at 0.0325%) with minimum fee at EUR 20.0 for over the counter transactions on shares listed on the ATHEX to the buyer and the seller to cover settlement costs, plus EUR 1.0 if it is delivery versus payment (calculated on the basis of the higher of the price agreed by the parties to the relevant transaction and the closing market price for the relevant shares at the trade date of the relevant transaction). The ATHEX Clear charges a trading fee and a clearing fee for transactions performed on the market on shares listed on the ATHEX on each of the buyer and the seller; currently the above trading fee amounts at 0.0125% and the above clearing fee amounts at 0.02% on the value of the transaction. Each of the buyer and the seller also pays a freely negotiable commission to the brokers (to the extent that a broker has been used in the transaction).

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" was organized as a corporate entity. In 2002, by virtue of Greek Law 2937/2001, ADEX S.A. merged with ATHEX and now constitutes one of the two regulated markets of the ATHEX.

In connection with the development of the Greek capital markets, the ATHEX, in cooperation with the ATHEXClear and the Hellenic Central Securities Depository SA (both currently under the administration of 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 ATHEXClear. The stock lending from the ATHEXClear is made through an

agreement of purchase of shares with a stock reverse repo through trading of the corresponding product.

With respect specifically to short selling transactions, Regulation 236/2012 on short selling and credit default swaps, which entered into force on November 1, 2012, and other relevant legal acts issued for its implementation introduce, among others, disclosure obligations to investors holding significant short positions on shares, sovereign debt securities, uncovered positions on sovereign credit default swaps, when relevant restrictions are lifted.

Pursuant to decision No 2/652/11.7.2013 of the HCMC the prohibition of short selling on shares and any related securities of credit institutions trading on the ATHEX was lifted.

Pursuant to decision No 743/07.12.2015, HCMC decided to continue a prohibition on the short selling of shares only in respect of the shares of credit institutions admitted to trading on the Athens Exchange and comprising the FTSE/Athex Banks Index until December 21, 2015, irrespective of the venue where the transaction is executed or OTC transactions. The temporary prohibition of short selling applied to all depository receipts (ADRs, GDRs) and warrants representing shares of credit institutions admitted to trading on the Athens Exchange and comprising the FTSE/Athex Banks Index.

Pursuant to decision No 747/11.1.2016, HCMC decided to continue a prohibition on the short selling of shares only of Attica Bank until 25 January 2016, irrespective of the venue where the transaction is executed or OTC transactions. The temporary prohibition of short selling applied to all depository receipts (ADRs, GDRs) and warrants representing shares of credit institutions admitted to trading on the Athens Exchange and comprising the FTSE/Athex Banks Index.

According to Greek Law 4141/2013 and the relevant regulatory decisions, 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.

Pursuant to Act No. 2474/31.5.2001, of the Governor of the Bank of Greece, as in force, the initial margin is set at a minimum of 40% of the market value of the investor's collateral portfolio while 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 Directive 2002/47/EC (the "Collateral Directive"), 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. Greek Law 3301/2004 has been amended to incorporate Directive 2009/44/EC which has amended Directive 98/26/EC on settlement finality in payment and securities settlement systems and the Collateral Directive as regards linked systems and credit claims.

The Bank's Articles of Association (and English translation thereof), as amended in December 2015, are included as Exhibit 1 to this Annual Report. The required information regarding the Bank's Articles of association is stated below.


2.	(a)	Article 26 of the Bank's Articles of Association defines the general voting powers of the Bank's Board of Directors. There is no specific provision in the Articles of Association that speaks directly to a Director's power to vote on a proposal, arrangement or contract in which the Director is materially interested. However, Article 28 of the Bank's Articles of Association provides, in governing remunerative relationships between the Bank and members of its Board of Directors, that: subject to the provisions governing the legality of transactions between the Bank and members of its Board of Directors, all fees or remuneration paid to a member of the Board of Directors for whatever reason shall be considered legal and shall be borne by the Bank only if approved by a special resolution of the Annual General Meeting; and
	(b)	there is no specific provision in the Bank's Articles of Association with respect to the Directors' power, in the absence of an independent quorum, to vote compensation to themselves or any members of their body. However, pursuant to Greek Company Law 2190/1920, compensation to a company's board member out of the company's net profits is to be paid after deductions for ordinary reserves and the amount required for distribution to shareholders as dividend for the relevant financial year. Any other compensation must be approved by a special resolution of the ordinary general meeting of its shareholders. The amount of such compensation granted to a company's board member, or members, may be reduced by a Greek court if an objection is raised by shareholders representing at least one-tenth of the company's share capital and if the court finds such compensation to be "exorbitant".

At the date of this Annual Report, neither the Bank nor any other Group company is a party to a commercial or financial contract, by virtue of which the Bank's operations or earnings would be affected, except for the Amended Relationship Framework Agreement (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Financial Stability Fund—The Greek Recapitalization Framework—Provision of Capital Support by the HFSF—The Relationship

Framework Agreement") and the share purchase agreement (the "Finansbank SPA")) dated December 21, 2015 between the Bank and QNB in respect of the sale of the Turkish Operations.

Pursuant to the Finansbank SPA, dated December 21, 2015, we have agreed to sell and QNB has agreed to purchase our 99.81% stake in Finansbank A.S. together with our 29.87% direct stake in Finans Leasing for an agreed consideration of EUR 2,750 million and repayment by QNB upon closing of USD 910 million of subordinated debt extended to Finansbank upon assignment of the subordinated debt to QNB. The purchase price includes an escrow condition in favor of QNB. In addition, the Finansbank SPA includes a non-competition restriction in favour of QNB preventing us from carrying out competitive business in Turkey for a period of three years. The closing of the transaction is expected within the first semester of 2016 and is subject to customary regulatory and corporate approvals, including approval of the Turkish Banking Regulation and Supervision Agency (already received), the Qatar Central Bank (already received), the Turkish Competition Board (already received approval; reasoned decision pending to be received), the Turkish Capital Markets Board (already received) and the Turkish Treasury (already received).

A Greek Legislative Act of June 28, 2015 introduced a short term bank holiday period starting on June 28, 2015 and imposed capital controls, which applied to all credit institutions operating in Greece in any form. The capital controls were extended beyond the period of the short term bank holiday pursuant to a Greek Legislative Act of July 18, 2015. For further information on the capital controls, (see Item 4.B, "Business Overview—"Regulation and Supervision of Banks in Greece—Capital Controls applying to banks operating in Greece").

As a result, capital controls in Greece restrict the payment of dividends or other capital distributions to holders of ordinary shares outside Greece and 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 disposition outside of Greece.

According to Ministerial Decision G.D.O.P.0001608 EX 2015 of December 7, 2015 (Gov. Gazette B', Bul. 2625/7.12.2015), the proceeds of clearing and settlement of transactions in financial instruments and the payment of cash distributions from issuers to holders of financial instruments (as defined in the MiFID), whether as a result of payment at maturity or corporate or similar actions (payment of interest, dividends and other relevant distributions) may be credited to a bank account of the end beneficiary outside Greece, provided that the clearing and settlement proceeds for the relevant investment account have been credited to such bank account before the entry into force of the capital controls on June 28, 2015.

The following is a summary of material U.S. federal income tax consequences of the purchase, ownership and disposition of ordinary 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 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 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 or ADRs should consult its tax advisor regarding the associated tax consequences. This summary does not purport to be a comprehensive description of all of the tax consequences of the ownership or disposition of ordinary shares or ADRs. In particular, this summary

deals only with U.S. Holders that will hold ordinary 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 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, 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 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 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.

Prospective purchasers should consult their tax advisors as to the application of the Medicare tax on net investment income, alternative minimum tax considerations, as well as the consequences under U.S. federal, estate, gift, state, local and applicable foreign tax laws of the purchase, ownership and disposition of ordinary shares and ADRs.

Holders of ADRs will generally be treated for U.S. federal income tax purposes as owners of the ordinary shares underlying the ADRs. Accordingly, except as noted, the U.S. federal income tax consequences discussed below apply equally to holders of ordinary shares and ADRs, referred to herein as "Shares".

Subject to the discussion below under this Item 10.E, "U.S. Federal Income Taxation—Passive Foreign Investment Company Status", 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 (including additional amounts paid pursuant to any gross up obligation) 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 will be subject to a maximum income tax rate of 20%. 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 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 gross amount of any dividends paid by the Bank (including additional amounts paid pursuant to any gross up obligation) 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 Shares 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, "U.S. Federal Income Taxation—Passive Foreign Investment Company Status", gain or loss realized by a U.S. Holder on the sale or other disposition of Shares 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 Shares and the amount realized on the disposition. Such gain or loss generally will be treated as long-term capital gain or loss if the Shares 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.

If a U.S. Holder receives any foreign currency on the sale, exchange or disposition of 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 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 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 the taxable year ending December 31, 2015 (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 Shares, 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 Shares 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 Shares 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 Shares during the three preceding taxable years or, if shorter, the U.S. Holder's holding period for the Shares). Under these rules, (i) the gain or excess distribution would be allocated ratably over the U.S. Holder's holding period for the Shares, (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 Shares, provided that the relevant Shares are "marketable" within the meaning of the relevant U.S. Treasury Regulations. The Shares will not be considered "marketable" for purposes of this election unless the exchange or market on which the relevant Shares 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 relevant U.S. Treasury 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 relevant U.S. Treasury Regulations. The mark to market election will remain in effect unless the IRS consents to revocation, or until the relevant Shares 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 Shares 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 Shares will be treated as ordinary income, and any losses incurred on a sale or other disposition of the Shares 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 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 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.

Certain U.S. Holders may be required to report to the IRS certain information with respect to their beneficial ownership of the Shares not held through an account with a financial institution. U.S. Holders who fail to report required information could be subject to substantial penalties.

A U.S. Holder that participates in any "reportable transaction" (as defined in U.S. Treasury 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 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 and ADRs including, in particular, the effects of the tax laws of any other jurisdiction.

Provisions of U.S. law commonly known as FATCA were enacted in 2010 by the U.S. Congress as part of the Hiring Incentives to Restore Employment (HIRE) Act. FATCA requires foreign financial institutions ("FFIs" (as defined by FATCA)), such as the Bank and many entities in the Group, to report to the U.S. Internal Revenue Service ("IRS") information about financial accounts held by U.S. taxpayers or by foreign entities in which U.S. taxpayers hold a substantial ownership interest.

In order to avoid withholding and to be treated as compliant under FATCA, participating FFIs generally may enter into an agreement with the IRS to: (a) identify U.S. accounts, (b) report certain information to the IRS regarding U.S. accounts and (c) potentially withhold 30% on certain U.S.-connected payments to non-participating FFIs and account holders who are unwilling to provide the required information. In particular, certain U.S. source payments to FFIs that are not treated as compliant with, or exempt from, FATCA are subject to a 30% withholding and reporting to the IRS.

The U.S. Department of the Treasury collaborated with foreign governments to develop two alternative model intergovernmental agreements ("IGAs") that facilitate FATCA implementation and further reduce burdens on FFIs in partner jurisdictions. Under a Model 1 IGA, reporting Model 1 FFIs report specified information about U.S. accounts to their government, followed by the exchange of that information on a government-to-government basis with the United States. Under a Model 2 IGA, reporting Model 2 FFIs report specified information about U.S. accounts directly to the IRS in a manner consistent with the FATCA regulations in accordance with the provisions of the Model 2 IGA.

Greece has reached an agreement in substance with the United States on the terms of a Model 1 intergovernmental agreement (IGA) to implement FATCA, and is currently treated as having an IGA in effect as of November 30, 2014. National Bank of Greece is registered with the IRS under FATCA

as a Registered—Deemed Compliant Financial Institution (as a Reporting Financial Institution under a Model 1 IGA). Additionally, NBG Group entities falling within the scope of FATCA are also registered with the IRS under FATCA. An FFI in an IGA jurisdiction that is treated as a Reporting Financial Institution would generally not be required to withhold under FATCA from payments it makes. Under each Model IGA, FFIs are still required to report certain information in respect of their account holders and investors to the IRS, either directly or through their home government.

Even if withholding would be required pursuant to FATCA or an IGA with respect to payments on instruments such as the Shares, such withholding would not apply prior to January 1, 2019. Holders should consult their own tax advisors regarding how these rules may apply to their investment in the Shares. In the event any withholding would be required pursuant to FATCA or an IGA with respect to payments on the Shares, no person will be required to pay additional amounts as a result of the withholding.

FATCA is particularly complex and its application is dependent on particular regulations and guidance issued as well as individual circumstances in the country of operation of each FFI. The above description is based in part on regulations, official guidance and model IGAs, all of which are subject to change or may be implemented in a materially different form. Prospective investors should consult their tax advisers on how these rules may apply to payments they may receive in connection with the Shares.

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.

Market risk is the current or prospective risk to earnings and capital arising from adverse movements in interest rates, equity and commodity prices and exchange rates, and their levels of volatility. The Group engages in moderate trading activities in order to enhance profitability and service its clients. These trading activities create market risk, which the Group seeks 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, equity 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 its trading and available-for-sale bond portfolios, as well as from the interest rate exchange traded and over-the-counter ("OTC") derivative transactions.

The most significant contributor to market risk in the Group is the Bank. More specifically, the Bank retains a portfolio of EFSF bonds, Greek treasury bills and government bonds and other EU sovereign debt, as well as moderate positions in Greek and international corporate bonds. Additionally, the Bank is active in the swap market and engages in vanilla and more sophisticated transactions for hedging and proprietary purposes and it maintains positions in bond and interest rate futures, mainly as a means of hedging and to a lesser extent for speculative purposes.

Equity risk is the risk related to the potential loss due to adverse movements in the prices of stocks and equity indices. The Group holds a limited portfolio of stocks, the majority of which are traded on the Athens Exchange (the "ATHEX") and retains positions in stock and equity index derivatives traded on the ATHEX, as well as, on international exchanges. The cash portfolio comprises of trading (i.e. short-term) and available-for-sale (i.e. long-term) positions. The portfolio of equity derivatives is used for proprietary trading, as well as, for the hedging of equity risk arising from the Group's cash position and equity-linked products offered to its clients. In the same context and to a lesser extent, the Group enters into OTC equity derivative 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 OCP of the Bank primarily arises from foreign exchange spot and forward transactions. The OCP is distinguished between Trading and Structural. The Structural OCP contains all of the Bank's assets and liabilities in foreign currency (for example loans, deposits, etc.), along with the foreign exchange transactions performed by the Treasury Division. Apart from the Bank, the foreign exchange risk undertaken by the rest of the Group's subsidiaries is insignificant.

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, the OCP should remain within the limits set by the Treasury Division and the GMORMD at the end of each trading day. The same policy applies to all of the Group's subsidiaries.

Market risk on trading and available-for-sale portfolios—Value-at-Risk ("VaR")

The Bank, in order to ensure the efficient management of market risk, calculates the Value at Risk (VaR) of its trading and available-for-sale portfolios on a daily basis, along with the VaR per risk type (interest rate, equity and foreign exchange risk). This has been implemented through RiskWatch by Algorithmics (currently IBM). In particular, due to the predominantly linear nature of its portfolio, the Bank has adopted the variance-covariance ("VCV") methodology, with a 99% confidence interval and 1-day holding period. The whole framework and the VaR calculations have been examined and approved by the Bank of Greece, as well as by internal auditors and external consultants. Also, the Internal Audit assesses the effectiveness of the relevant internal controls on a regular basis.

The VaR estimates are used internally as a risk management tool, as well as for regulatory purposes. For internal use, the GMORMD calculates the VaR of the Bank's trading and available-for-sale portfolios, on a daily basis, using the latest 75 exponentially weighted daily observations to construct the VCV matrices. The risk factors relevant to the financial products in the Bank'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 around 1,144. Additionally, the GMORMD 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 the risks to which it is exposed in a more efficient way. These limits have been determined by reference based on the risk appetite framework of the Bank; 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 available-for-sale portfolios.

The tables below present the Bank's VaR (99%, 1-day) for the years ended on December 31, 2015 and 2014 respectively:

The most significant type of market risk to which the Bank is exposed, is interest rate risk. It arises mainly from the Bank's trading and available- for-sale bond portfolios, as well as from interest rate derivatives, both exchange traded and over-the-counter. The level of interest rate risk VaR mostly depends on the level and volatility of the underlying interest rates as well as on the positions of the Bank's portfolio.

During the first six months of 2015, due to the ongoing negotiations between the Greek government and the Institutions which led to an economic turbulence in the country, the spread between the Greek and the German government bond yields widened significantly and climbed to its highest level in the beginning of July, after the negotiations between the Greek government and the Institutions were terminated. This led to an increase in the volatilities of the Greek government bond yields and to higher interest rate and total VaR estimates for the Bank. Since the middle of July, when an agreement was reached between Greece and the rest of the Eurozone, the spread between the Greek and the German government bond yields narrowed and dropped back to the levels that were observed in the beginning of the year, which in turn caused the respective volatilities to decrease and led to lower VaR estimates for the Bank.

The Bank performs back-testing on a daily basis, in order to verify the predictive power of the VaR model. In accordance with the guidelines set out in the Capital Requirements Regulation 575/2013, the calculations incorporate only the Bank's trading portfolio and involve the comparison of the hypothetical and actual daily gains/losses of the portfolio with the respective estimates of the VaR model used for regulatory purposes. The hypothetical gains/losses, is the change in the value of the portfolio between days t and t+1, assuming that the portfolio remains the same between the two days. In the same context, the actual gains/losses,is the change in the value of the portfolio between days t and t+1, including all the transactions that took place in day t+1, excluding fees, commissions and net interest income.

Any excess of the hypothetical / actual losses over the VaR estimate is reported to the regulatory authorities within five business days. During 2015, there were no cases in which the back-testing result exceeded the respective VaR calculation.

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, the GMORMD performs 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 and applies on both, trading and available-for-sale portfolios. The scenarios used are presented in the following tables:

The VaR model is based on certain theoretical assumptions, which under extreme market conditions might not capture the maximum loss the Bank may suffer. The restrictions of this methodology are summarized as follows:

Country risk is the current or prospective risk to earnings and capital, caused by events in a particular country which are at least to some extent under the control of the government but definitely not under the control of a private enterprise or individual. The main categories of country risk consist of sovereign risk, convertibility risk and transfer risk. Sovereign risk stems from a foreign government's lack of capacity and/or 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 or a retail client.

The on and off 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, Cyprus, Egypt, Malta and South Africa, where the Group has presence.

On November 3, 2015, the Bank's Board of Directors approved the plan to proceed with the disposal of its entire stake in Finansbank. On 21 December 2015, the Bank's Board of Directors approved the sale to Qatar National Bank ("QNB") of NBG Group's 99,81% stake in Finansbank A.S. together with NBG's 29.87% direct stake in Finans Leasing (see Item 3.A "Selected Financial Data"). Therefore, the Bank and the Group will no longer exposed to Turkey country risk.

Counterparty risk for the Group is due to OTC derivative transactions and other interbank secured and unsecured funding transactions in the event of an obligor's failure to meet her contractual obligations. For the efficient management of counterparty risk, the Bank has established a framework of counterparty limits. The GMORMD is responsible for setting and monitoring these limits.

Counterparty limits are based on the credit rating of the financial institutions as well as the product type. The credit ratings are provided by internationally recognized rating agencies, in particular by Moody's and Standard & Poor's. According to the Bank's policy, if the agencies diverge on the creditworthiness of a financial institution, the lowest credit rating is considered.

Counterparty limits apply to all financial instruments in which the Treasury is active in the interbank market. The limits framework is annually 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 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 transaction. In over-the-counter transactions, the exposure is calculated based on credit equivalent factors, according to the type of transaction, its maturity, netting and collateralization.

The Group seeks to reduce counterparty risk by standardizing the terms of the agreements with counterparties through ISDA and GMRA contracts, which encompass all necessary netting and margining clauses. Additionally, for almost all active counterparties, Credit Support Annexes ("CSAs") have been signed, so that net current exposures are managed through margin accounts, on a daily basis, by exchanging cash or debt securities as 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 (wrong-way-risk).

We made certain assumptions in calculating fair values for presentation in the U.S. GAAP Financial Statements. These assumptions are stated in Note 37 "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, 2015, which are not included in the VaR model developed by the Bank. The analysis below was performed based on the following assumptions:

	December 31, 2015				Market Value Change					Market Value Change

	Carrying Amount		Fair value		+100bps			–100bps		+50bps			–50bps
	(EUR in millions)
Assets
Deposits with central bank		1,059		1,059		(1	)		—		—			—
Securities purchased under agreements to resell		10		10		—			—		—			—
Interest bearing deposits with banks		2,432		2,428		(1	)		5		—			5
Held to Maturity securities		9,292		9,596		(24	)		27		(29	)		27
Net loans		43,221		41,715		(122	)		230		(74	)		164

Total interest rate sensitive assets		56,014		54,808		(148	)		262		(103	)		196



Liabilities
Total deposits		67,564		67,546		(148	)		63		(35	)		(6	)
Securities sold under agreements to repurchase		101		101		—			—		1			(1	)
Other borrowed funds		3		3		—			—		—			—
Long term debt		1,596		1,597		30			46		37			43

Total interest rate sensitive liabilities		69,264		69,247		(118	)		109		3			36



Total interest rate balance sheet sensitivity						(30	)		153		(106	)		160

	December 31, 2014				Market Value Change					Market Value Change

	Carrying Amount		Fair value		+100bps			–100bps		+50bps			–50bps
	(EUR in millions)
Assets
Deposits with central bank		1,065		1,065		(5	)		4		(6	)		6
Securities purchased under agreements to resell		24		24		—			—		—			—
Interest bearing deposits with banks		2,711		2,711		(4	)		5		(5	)		7
Held to Maturity securities		9,337		9,599		(62	)		65		(48	)		53
Net loans		47,276		48,120		(165	)		156		(143	)		139

Total interest rate sensitive assets		60,413		61,519		(236	)		230		(202	)		205



Liabilities
Total deposits		66,106		66,114		(202	)		60		(75	)		21
Securities sold under agreements to repurchase		3,587		3,587		(2	)		—		(1	)		—
Other borrowed funds		6		6		—			—		—			—
Long term debt		2,385		2,215		(45	)		36		(21	)		16

Total interest rate sensitive liabilities		72,084		71,922		(249	)		96		(97	)		37



Total interest rate balance sheet sensitivity						13			134		(105	)		168

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, 2015				Market Value Change

	Carrying amount		Fair value		+10%			–10%
	(EUR in millions)
Assets
Cash and due from banks		1,436		1,436		61			(50	)
Deposits with central bank		1,059		1,059		24			(20	)
Securities purchased under agreements to resell		10		10		—			—
Interest bearing deposits with banks		2,432		2,428		68			(56	)
Held to Maturity securities		9,292		9,596		—			—
Net loans		43,221		41,715		628			(514	)
Accrued interest receivable		476		476		4			(3	)

Total foreign exchange sensitive assets		57,926		56,720		785			(643	)



Liabilities
Total deposits		67,564		67,546		(756	)		619
Securities sold under agreements to repurchase		101		101		(6	)		5
Other borrowed funds		3		3		—			—
Long-term debt		1,596		1,597		(2	)		2

Total foreign exchange sensitive liabilities		69,264		69,247		(762	)		624



Total foreign exchange balance sheet sensitivity						23			(19	)

	December 31, 2014				Market Value Change

	Carrying amount		Fair value		+10%			–10%
	(EUR in millions)
Assets
Cash and due from banks		2,107		2,107		56			(46	)
Deposits with central bank		1,065		1,065		38			(31	)
Securities purchased under agreements to resell		24		24		3			(2	)
Interest bearing deposits with banks		2,711		2,711		38			(31	)
Held to Maturity securities		9,337		9,599		—			—
Net loans		47,276		48,120		660			(540	)
Accrued interest receivable		536		536		5			(4	)

Total foreign exchange sensitive assets		63,056		64,162		800			(654	)



Liabilities
Total deposits		66,106		66,114		(881	)		721
Securities sold under agreements to repurchase		3,587		3,587		(5	)		4
Other borrowed funds		6		6		—			—
Long-term debt		2,385		2,215		(3	)		3

Total foreign exchange sensitive liabilities		72,084		71,922		(891	)		727



Total foreign exchange balance sheet sensitivity						(91	)		73

The Bank of New York Mellon is the depositary of the Bank's ordinary shares in the form of ADRs. 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. 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

For the year ended December 31, 2015, we did not have any fee arrangements in place with the depository, and we did not receive any fees from the depository throughout this period.

ITEM 14 MATERIAL MODIFICATIONS TO THE RIGHTS OF SECURITY HOLDERS AND USE OF PROCEEDS

On November 23, 2012, the 2nd Repeat Extraordinary General Meeting of the Bank's Shareholders approved (i) the reduction in the Bank's share capital through a reduction in the nominal value of the shares from EUR 5.00 to EUR 1.00 per share, as per article 4 para 4a of the Greek Company Law 2190/1920 as amended, with the formation of a special reserve of an equal amount, and (ii) the increase in the Bank's share capital with the issuance of new ordinary shares that will be subscribed in kind, that is, shares of Eurobank Ergasias S.A. ("Eurobank"), up to 552,948,427 ordinary voting shares of Eurobank, of nominal value EUR 2.22 per share. This share capital increase was covered exclusively by the shareholders of Eurobank, who accepted the tender offer, with abolition of the preemptive rights of existing shareholders. The Ministry of Development approved the above decision on February 12, 2013. This increase was partially covered (84.4%) through the contribution of 466,397,790 Eurobank shares.

At its meeting of February 22, 2013 the Bank's Board of Directors certified the increase, pursuant to partial coverage thereof. As a result the Bank's share capital increased by EUR 271 million by issuing 270,510,718 ordinary shares with nominal value of EUR 1.00 per share. The fair value of these shares issued as the consideration paid for Eurobank amounted to EUR 273 million and was based on the closing price of Bank's share on the ATHEX on February 15, 2013.

On April 29, 2013, the 2nd Repeat Extraordinary General Meeting of the Bank's Shareholders approved a) the reverse split of the ordinary shares at a ratio of 10 existing shares of EUR 1.00 per share to be exchanged for one (1) new share of EUR 10.00 per share, b) the reduction in the nominal value from EUR 10.00 per share to EUR 0.30 per share as per article 4 Para 4a of the Greek Company Law 2190/1920 as amended, with the formation of a special reserve of an equal amount and c) the share capital increase by EUR 9,756 million in the context of recapitalization of the Greek systemic banks.

From the amount of EUR 9,756 million, EUR 682 million was credited to the share capital whereas the remaining amount of EUR 9,074 million less expenses was credited to the share premium account.

On May 10, 2014, the extraordinary General Meeting of the Bank's Shareholders approved the share capital increase by EUR 2,500 million by issuing 1,136,363,637 ordinary shares of a par value of EUR 0.30 per share, through cancellation of the pre-emptive rights for existing shareholders, which was completed on May 13, 2014. The subscription price was set at EUR 2.20 per share as it was determined by the international book-building process outside Greece to institutional and other eligible investors.

On May 12, 2014, the Board of Directors certified that EUR 2,500 million was covered in cash. From the amount of EUR 2,500 million, EUR 341 million was credited to the share capital while the remaining EUR 2,159 million less expenses was credited to the share premium account.

On December 9, 2015 the Bank's Board of Directors confirmed that the total share capital increase forming part of the 2015 Recapitalization was partially covered, in accordance with art. 13a of Greek Company Law 2190/1920, i.e. it was covered by EUR 2,192,372,169.30 through the issuance of 7,307,907,231 new shares further to the LME Offers, International Offering, the Greek Public Offer and to the HFSF. As a result of the publication of Cabinet Act no 45/7.12.2015 all of the Bank's preference shares were mandatorily converted (in accordance with the relevant provisions of article 6a of the HFSF Law) to 1,603,700,987 common shares of the Bank. See Item 4.A., "History and Development of the Company—2015 Recapitalization" for the description of the 2015 recapitalization.

As at December 31, 2015, the total paid-up share capital of the Bank amounted to EUR 2,744 million divided into 9,147,151,527 ordinary shares of a nominal value of EUR 0.30 each.

As of December 31, 2015, we performed an evaluation, under the supervision and with the participation of our Management, including our Chief Executive Officer, Deputy Chief Executive Officer and Group Chief Financial Officer, of the effectiveness of our disclosure controls and procedures as required by Rules 13a-15(e) and 15d-15(e) of the Securities Exchange Act of 1934. 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 Group 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 Group Chief Financial Officer have concluded that our disclosure controls and procedures are ineffective as of December 31, 2015 due to the material weaknesses described in Item 15 (b) below. Our efforts to remediate the material weaknesses are described in Item 15(d) below.

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 publications made by the Bank, including such information submitted to the SEC.

For information in relation to the composition of the Disclosure and Transparency Committee, see Item 6.C, "Board Practices—Executive Committees—Disclosure and Transparency Committee".

Management is responsible for establishing and maintaining adequate internal control over financial reporting ("ICFR") for the Group.

The Group's ICFR is a process designed by, or under the supervision of, the Bank's principal executive officers and principal financial officer, or persons performing similar functions, and effected by the Bank'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 U.S. GAAP. The Group's ICFR includes those policies and procedures that:

Because of the inherent limitations of ICFR, 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 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 ICFR as of December 31, 2015, based on the framework set forth by the Committee of Sponsoring Organizations of the Treadway Commission in Internal Control—Integrated Framework (2013). Based on this assessment, Management concluded that, as of December 31, 2015, the Group's ICFR was ineffective, due to the material weaknesses identified in its ICFR as noted below.

A material weakness is a deficiency, or a combination of deficiencies, in ICFR, such that there is a reasonable possibility that a material misstatement of the Group's annual or interim financial statements will not be prevented or detected on a timely basis.

Management identified the following material weaknesses in its ICFR relating to:

The effectiveness of the Group's internal control over financial reporting as of December 31, 2015, has been audited by Deloitte Hadjipavlou, Sofianos & Cambanis S.A., the Group's independent registered public accounting firm as stated in their report appearing in section (c) below, which expressed an adverse opinion on the effectiveness of the Group's ICFR as of December 31, 2015.

To the Board of Directors and Shareholders of
National Bank of Greece S.A. and subsidiaries

We have audited the internal control over financial reporting of National Bank of Greece S.A. and its subsidiaries (the "Group") as of December 31, 2015 based on criteria established in Internal Control—Integrated Framework (2013) 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 did not examine the effectiveness of internal control over financial reporting of Finansbank A.S. (a 99.81% subsidiary of the Group) with respect to its financial statements as of and for the year ended December 31, 2015, which statements, expressed in Turkish Lira ("TRY") and prepared in accordance with International Financial Reporting Standards as issued by the International Accounting Standards Board ("IFRS"), reflect total assets of TRY 87,951 million (EUR 27,666 million) as of December 31, 2015 and profit for the year of TRY 788 million (EUR 322 million) for the year then ended. The effectiveness of Finansbank A.S.'s internal control over financial reporting with respect to its IFRS financial statements was audited by other auditors whose report (which expressed an unqualified opinion on the effectiveness of Finansbank A.S.'s internal control over financial reporting) has been furnished to us, and our opinion, insofar as they relate to the effectiveness of Finansbank A.S.'s internal control over financial reporting with respect to its IFRS financial statements, are based solely on the report of the other auditors.

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 the assessed risk, and performing such other procedures as we considered necessary in the circumstances. We believe that our audit and the report of the other auditors provide 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 or interim financial statements will not be prevented or detected on a timely basis. The following material weaknesses have been identified and included in management's assessment:

The material weaknesses were 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, 2015 of the Group and this report does not affect our report on such consolidated financial statements.

In our opinion, based on our audit and the report of the other auditors, because of the effect of the material weaknesses identified above on the achievement of the objectives of the control criteria, the Group has not maintained, in all material respects, effective internal control over financial reporting as of December 31, 2015, based on the criteria established in Internal Control—Integrated Framework (2013) 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, 2015, of the Group and our report dated May 16, 2016 expressed an unqualified opinion on those financial statements based on our audit and the report of the other auditors and included an explanatory paragraph regarding the material uncertainties that could adversely affect the Group's going concern assumption as discussed in Note 3 and an explanatory paragraph relating to the translation of Euro amounts into U.S. dollar amounts in conformity with the basis stated in Note 2 and that such U.S dollar amounts are presented solely for the convenience of the readers in the United States.

We have audited Finansbank A.Ş. (the "Bank") and its subsidiaries (together the "Finansbank Group"), internal control over financial reporting in respect of its consolidated financial statements prepared in accordance with International Financial Reporting Standards, as issued by the International Accounting Standards Board as of December 31, 2015, based on criteria established in Internal Control—Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (2013 framework) (the COSO criteria) ("COSO criteria"). Finansbank A.Ş'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 Finansbank A.Ş's Management Assessment on Internal Control over Financial Reporting. Our responsibility is to express an opinion on the Finansbank Group's internal control over financial reporting based on our audit.

A company's internal control over financial reporting 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 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 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.

In our opinion, Finansbank A.Ş. (the "Bank") and its subsidiaries (together the "Finansbank Group") maintained, in all material respects, effective internal control over financial reporting as of December 31, 2015, based on the COSO criteria.

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States), the consolidated statement of financial position of the Finansbank Group at December 31, 2015, and the related consolidated statements of profit or loss, other comprehensive income, changes in equity and cash flows for the year then ended and notes thereto prepared in accordance with International Financial Reporting Standards and our report dated May 16, 2016 expressed an unqualified opinion thereon.

Güney Bağımsız Denetim ve Serbest Muhasebeci Mali Müşavirlik Anonim Şirketi
A member firm of Ernst&Young Global Limited
İstanbul, Turkey

Based on Management's assessment as of December 31, 2014, the Group's ICFR was ineffective due to certain material weaknesses. These material weaknesses related to the financial statement closing process and the loan loss allowance processes. Throughout 2015, the Bank continued the remediation actions in order to address the ICFR significant deficiencies that contributed to these material weaknesses. Our efforts to remediate the significant deficiencies that aggregated to the material weaknesses are described as follows:

While the above steps have been taken towards remediating the material weaknesses, Management has determined that as of December 31, 2015, the material weaknesses over the financial reporting and the loan impairment assessment processes remained. The remediation process will continue during 2016 and our plan includes going "live" with our financial reporting application and exploring further opportunities for both process and control level improvements in the ICFR.

Other than those changes described above, during the year ended December 31, 2015, 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.

Mr. Petros Sabatacakis, an independent non executive member of the Board of Directors, serves as the Audit Committee financial expert since 2010. On June 19, 2015 the Annual General Meeting of the Shareholders reappointed Mr. Sabatacakis as the Audit Committee financial expert until the date of the Annual General Meeting of 2016.

Mr. Sabatacakis 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, in compliance with the U.S. legal and regulatory framework and the decrees of SEC, from February 2004 has approved a separate Code of Ethics for Financial Professionals, which aims at preventing situations where conflict of interest may arise when 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 is complete, accurate, timely and comprehensive, and that all such information is presented in accordance with applicable rules and regulations.

The Code of Ethics for Financial Professionals was updated in 2012 and is available on the Bank's website www.nbg.gr (section: The Group/Corporate Governance/Regulations & Principles).

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 policies 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, European and international legislation which, accordingly, concern management and employees throughout the Bank and its Group.

The Code of Ethics applies to all Management and employees of the Bank and the Group, including Independent Associates and Consultants.

The Code of Ethics was updated in 2015 and is available on the Bank's website www.nbg.gr (section: The Group/Corporate Governance/Regulations & Principles).

Deloitte Hadjipavlou Sofianos & Cambanis S.A. has served as our principal independent public accountant for each of the past two years ended December 31, 2014 and 2015. For Finansbank, our major subsidiary in Turkey, Ernst & Young was appointed as the independent public accountant for the years ended December 31, 2014 and 2015.

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., their respective affiliates (collectively, "Deloitte"). Also, the table below presents the aggregate fees for professional audit services and other services rendered by Ernst & Young in Turkey to the Finansbank Group.

Fees billed by Deloitte for audit services for the years ended December 31, 2014 and 2015 consisted primarily of the audit of the Group's IFRS and the integrated audit of its U.S. GAAP consolidated Financial Statements, including the audit for compliance with the section 404 of Sarbanes Oxley Act, the audit of subsidiaries' statutory Financial Statements, and the tax compliance audits of the Bank and its subsidiaries.

Fees billed by Ernst & Young for audit services for the years ended December 31, 2014 and 2015 consisted primarily of the statutory and IFRS audit of the Financial Statements of Finansbank and its subsidiaries, including the audit for compliance with the section 404 of Sarbanes Oxley Act, and the tax compliance audits of Finansbank and its subsidiaries.

Fees billed for audit related services for the years ended December 31, 2014 and 2015 consisted primarily of comfort letter fees, other audit and attest services and system and application control reviews provided either repeatedly or on ad-hoc basis.

Fees billed for tax services for the years ended December 31, 2014 and 2015 consisted primarily of tax advisory, tax planning services and preparation of tax returns.

The Audit Committee has implemented a policy as at 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 thousand. These services may be approved by the Group Chief Financial Officer or its delegate and the Audit Committee is notified 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.

"Audit related fees" and "Tax fees" constituted 25.1% and 4.0%, respectively, of total fees paid to Deloitte and Ernst & Young in 2014, and 18.9% and 3.0%, respectively, of total fees paid to Deloitte and Ernst & Young in 2015.

Mr Charalampos Makkas, who is a member of the Audit Committee, is relying on the exemption available under Rule 10A 3(b)(iv)(E), as he is a representative of the HFSF, which is an affiliate to the Bank.

ITEM 16E PURCHASES OF EQUITY SECURITIES BY THE ISSUER AND AFFILIATED PURCHASERS

From January 1, 2010 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 Regulatory Framework—The Hellenic Republic's Bank Support Plan") the Bank has not purchased any of its own shares.

The purchases and (sales) of own shares by the affiliated purchasers (NBG Securities S.A.) for the year 2013 amounted to 10,167,100 shares and (9,770,521) shares respectively. Therefore, the balance of as at December 31, 2013 of own shares amounted to 397,655 shares.

The purchases and (sales) of own shares by the affiliated purchasers (NBG Securities S.A.) for the year 2014 amounted to 32,698,747 shares and (33,095,326) shares respectively. Therefore, the balance of as at December 31, 2014 of own shares amounted to 1,076 shares.

The purchases and (sales) of own shares by the affiliated purchasers (NBG Securities S.A.) for the year 2015 amounted to 67,825,104 shares and (65,824,717) shares respectively. Therefore, the balance of as at December 31, 2015 of own shares amounted to 2,001,463 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 practices, NBG has adopted a Corporate Governance Code which is currently similar to NYSE listing standards. However, the Bank's corporate governance and board composition has also been directly impacted by the re-capitalization processes that the Bank, like other Greek banks, went through as a result of the financial and Eurozone crises. 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 2015.
	2.1		Deposit Agreement dated as at May 28, 1998, as amended and restated as at 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).
	4.1		Share Sale and Purchase Agreement between National Bank of Greece S.A. and Qatar National Bank S.A.Q. dated December 21, 2015*^¥.
	4.2		Bond Issuance Programme of Contingently Convertible Securities, dated December 9, 2015.
	8		Subsidiaries of the Bank.
	12.1		Certification of the Chief Executive Officer, the Deputy Chief Executive Officer and the Group 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 Group 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.

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 at
December 31, 2014 and 2015 and for the
years ended December 31, 2013, 2014 and
2015 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 consolidated balance sheets of National Bank of Greece S.A. and its subsidiaries (the "Group") as of December 31, 2015 and 2014, 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, 2015. These financial statements are the responsibility of the Group's management. Our responsibility is to express an opinion on the financial statements based on our audits. We did not audit the financial statements of Finansbank A.S. (a 99.81% subsidiary of the Group) as of and for the years ended December 31, 2015 and 2014, which statements reflect total assets of TRY 87,951 million (EUR 27,666 million) as of December 31, 2015 (2014—TRY 76,892 million (EUR 27,151 million)) and profit for the year of TRY 788 million (EUR 322 million) for the year then ended (2014—TRY 950 million (EUR 328 million)). Those statements expressed in Turkish Lira ("TRY") were prepared in accordance with International Financial Reporting Standards as issued by the International Accounting Standards Board ("IFRS") and were audited by other auditors whose report has been furnished to us, and our opinion, insofar as it relates to the amounts included for Finansbank A.S., on the basis of IFRS and expressed in Turkish Lira, as of and for the years ended December 31, 2015 and 2014, is based on the report of the other auditors. We have applied auditing procedures on the conversion adjustments to the financial statements of Finansbank A.S., which conform those financial statements to accounting principles generally accepted in the United States of America and Euro amounts.

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 and the report of the other auditors provide a reasonable basis for our opinion.

In our opinion, based on our audits and the report of the other auditors, such consolidated financial statements present fairly, in all material respects, the financial position of National Bank of Greece S.A. and its subsidiaries as of December 31, 2015 and 2014, and the results of their operations and their cash flows for each of the three years in the period ended December 31, 2015, in conformity with accounting principles generally accepted in the United States of America.

The accompanying financial statements have been prepared assuming that the Group will continue as a going concern. As discussed in Note 3 to the consolidated financial statements, referring to material uncertainties associated with the current economic conditions in Greece and the ongoing developments that may affect the Group's access to certain liquidity facilities and could adversely affect its going concern assumption. Management's plans concerning these matters are also discussed in Note 3 to the consolidated financial statements.

Our audits also comprehended the translation of the Euro amounts into U.S. dollar amounts and, in our opinion, such translations have been made in conformity with the basis stated in Note 2 to the consolidated financial statements. Such U.S. dollar amounts are presented solely for the convenience of readers in the United States.

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, 2015, based on the criteria established in Internal Control—Integrated Framework (2013)

issued by the Committee of Sponsoring Organizations of the Treadway Commission and our report dated May 16, 2016 expressed an adverse opinion on the Group's internal control over financial reporting based on our audit and the report of the other auditors.

We have audited the consolidated statement of financial position of Finansbank A.Ş. (a 99.81% owned subsidiary of National Bank of Greece S.A.) as of December 31, 2015 and 2014, and the related consolidated statements of profit or loss, other comprehensive income, changes in equity and cash flows and notes thereto for the years ended December 31, 2015 and 2014 prepared in accordance with International Financial Reporting Standards, as issued by the International Accounting Standards Board. These consolidated financial statements reflect total assets of TL 87,951 million (2014—TL 76,892 million) and shareholders' equity of TL 10,726 million (2014—TL 9,918 million) as of December 31, 2015, respectively, and profit for the year of TL 788 million for the year then ended (2014—TL 950 million). These consolidated financial statements are the responsibility of the Bank's Management. Our responsibility is to express an opinion on these consolidated financial statements 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 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 audit provided a reasonable basis for our opinion.

In our opinion, the consolidated financial statements referred to above present fairly, in all material respects, the consolidated financial position of Finansbank A.Ş. and its subsidiaries at December 31, 2015 and 2014 and the consolidated results of their operations and their cash flows for the years ended December 31, 2015 and 2014, in conformity with International Financial Reporting Standards, as issued by the International Accounting Standards Board.

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States), Finansbank A.Ş.'s internal control over financial reporting as of December 31, 2015, based on criteria established in Internal Control-Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (2013 framework) (the COSO criteria) and our report dated May 16, 2016 expressed an unqualified opinion thereon.

Güney Bağımsız Denetim ve Serbest Muhasebeci Mali Müşavirlik Anonim Şirketi
A member firm of Ernst &Young Global Limited
İstanbul, Turkey

			As of December 31,

	Note		2014			2015			2015
			(EUR in millions)						(USD in millions) (Note 2)
			Restated						(USD in millions) (Note 2)
ASSETS
Cash and due from banks		5		2,107			1,436			1,643
Deposits with Central Bank		6		1,065			1,059			1,212
Securities purchased under agreements to resell		7		24			10			11
Interest bearing deposits with banks		8		2,711			2,432			2,783
Trading assets		9		2,386			2,484			2,842
Derivative assets		10		4,796			3,895			4,457
Available-for-sale securities		11		3,319			6,227			7,125
Held-to-maturity securities		11		9,337			9,292			10,632
Equity method investments		12		80			36			41
Loans		13		56,068			54,996			62,924
Less: Allowance for loan losses				(8,792	)		(11,775	)		(13,473	)

Net loans				47,276			43,221			49,451
Goodwill		14		264			10			11
Software and other intangibles		14		163			145			166
Premises and equipment		15		1,623			1,433			1,640
Accrued interest receivable				536			476			545
Other assets (include EUR 316 million and EUR 307 million at December 31, 2014 and 2015, respectively, measured at fair value)		16		3,188			3,017			3,452
Long-lived assets held for sale		17		29,286			24,759			28,328

TOTAL ASSETS				108,161			99,932			114,339



LIABILITIES AND SHAREHOLDERS' EQUITY
Interest bearing deposits (include EUR 16 million and EUR 2 million at December 31, 2014 and 2015, respectively, measured at fair value)		20		64,561			65,905			75,406
Non-interest bearing deposits		20		1,545			1,659			1,898

Total deposits		20		66,106			67,564			77,304
Securities sold under agreements to repurchase		21		3,587			101			116
Derivative liabilities		10		5,699			4,641			5,310
Other borrowed funds				6			3			3
Accounts payable, accrued expenses and other liabilities (includes EUR 4 million and NIL at December 31, 2014 and 2015, respectively, measured at fair value)		22		2,974			2,573			2,944
Insurance reserves		23		2,248			2,094			2,396
Long-term debt (includes EUR 872 million and EUR 826 million at December 31, 2014 and 2015, respectively, measured at fair value)		24		2,385			1,596			1,826
Contingently convertible debt		25		—			2,040			2,334
Liabilities directly associated with long-lived assets held-for-sale		17		22,719			23,650			27,060

Total liabilities				105,724			104,262			119,293

PERMANENT EQUITY:
NBG shareholders' equity
Preferred stock (12,639,831 shares of par value EUR 0.30 each at December 31, 2014 and NIL at December 31, 2015 and 270,000,000 shares of par value EUR 5.00 each at December 31, 2014 and NIL at December 31, 2015)		33		1,354			—			—
Common stock, par value of EUR 0.30 (shares authorized, issued and outstanding: 3,533,149,631 and 9,147,151,527 at December 31, 2014 and 2015 respectively)		33		1,060			2,744			3,140
Additional paid-in capital		33		19,918			21,740			24,874
Accumulated surplus / (deficit)				(17,387	)		(25,851	)		(29,578	)
Accumulated other comprehensive loss		42		(2,547	)		(2,994	)		(3,426	)
Treasury stock, at cost (1,076 and 2,001,463 shares at December 31, 2014 and 2015 respectively)				—			(1	)		(1	)

Total NBG shareholders' equity / accumulated deficit				2,398			(4,362	)		(4,991	)

Non-controlling interest				39			32			37

Total permanent equity / accumulated deficit				2,437			(4,330	)		(4,954	)

TOTAL LIABILITIES AND EQUITY				108,161			99,932			114,339

The accompanying notes are an integral part of these consolidated financial statements.

			Year ended December 31,

	Note		2013			2014			2015			2015
			(EUR in millions)									(USD in millions) (Note 2)
Interest Income:
Loans				2,357			2,176			1,938			2,217
Securities available-for-sale				204			193			134			153
Securities held-to-maturity				95			116			93			106
Trading assets				117			63			66			76
Securities purchased under agreements to resell				3			1			1			1
Interest-bearing deposits with banks				17			10			7			8
Other				31			21			17			19

Total interest income				2,824			2,580			2,256			2,580

Interest Expense:
Deposits				(1,219	)		(856	)		(645	)		(738	)
Securities sold under agreements to repurchase				(18	)		(21	)		(2	)		(2	)
Other borrowed funds				—			—			(1	)		(1	)
Long-term debt				(18	)		(48	)		(59	)		(68	)
Other				(7	)		(54	)		(53	)		(61	)

Total interest expense				(1,262	)		(979	)		(760	)		(870	)

Net interest income before provision for loan losses				1,562			1,601			1,496			1,710
Provision for loan losses		13		(633	)		(1,835	)		(3,298	)		(3,773	)

Net interest income/(loss) after provision for loan losses				929			(234	)		(1,802	)		(2,063	)

Non-interest income /(loss):
Credit card fees				40			39			48			55
Service charges on deposit accounts				28			29			26			30
Other fees and commissions		27		311			312			274			314
Net trading gain/(loss)		28		114			(1,091	)		215			246
Equity in earnings of investees and realized gains/(losses) on disposal of equity method investments		12		10			8			5			6
Other non-interest income		29		791			673			606			693

Total non-interest income / (loss) excluding gains / (losses) on investment securities				1,294			(30	)		1,174			1,344

Net realized gains/(losses) on sales of available-for-sale securities		11		189			96			2			2
Other-Than-Temporary-Impairment (of which NIL was recognized in OCI)				(286	)		(6	)		(36	)		(41	)

Net gains / (losses) on available for sale and held to maturity securities				(97	)		90			(34	)		(39	)

Total non-interest income / (loss)				1,197			60			1,140			1,305

Non-interest expense:
Salaries				(781	)		(686	)		(676	)		(773	)
Employee benefits				(347	)		(132	)		(130	)		(149	)
Occupancy expenses				(57	)		(54	)		(53	)		(61	)
Equipment expenses				(39	)		(42	)		(40	)		(46	)
Depreciation of premises and equipment				(69	)		(67	)		(65	)		(74	)
Amortization of intangible assets				(58	)		(53	)		(59	)		(68	)
Impairment of goodwill				(9	)		(58	)		(221	)		(253	)
Deposit insurance premium				(65	)		(64	)		(106	)		(121	)
Other non-interest expense		30		(1,260	)		(1,249	)		(1,290	)		(1,476	)

Total non-interest expense				(2,685	)		(2,405	)		(2,640	)		(3,021	)

Income / (loss) before income tax				(559	)		(2,579	)		(3,302	)		(3,779	)
Income tax expense		31		(20	)		(63	)		(42	)		(48	)

Income / (loss) from continuing operations				(579	)		(2,642	)		(3,344	)		(3,827	)

Income / (loss) from discontinuing operations		17		648			169			(5,123	)		(5,862	)

Net income / (loss)				69			(2,473	)		(8,467	)		(9,689	)

Less: Net income attributable to the non-controlling interest				(32	)		(4	)		3			3



NET INCOME / (LOSS) attributable to NBG shareholders				37			(2,477	)		(8,464	)		(9,686	)



Earnings / (loss) per share
Basic and diluted EPS from continuing operations		35		(6.24	)		(12.67	)		(2.89	)		(3.31	)
Basic and diluted EPS from continuing and discontinued operations		35		0.40			(11.90	)		(9.41	)		(10.77	)

The accompanying notes are an integral part of these consolidated financial statements.

		Year ended December 31,

	Note	2013			2014			2015			2015
		(EUR in millions)									(USD in millions) (Note 2)
Net income / (loss)			69			(2,473	)		(8,467	)		(9,689	)
Other comprehensive income / (loss) net of tax:
Foreign currency translation adjustments			(1,326	)		239			(604	)		(691	)
Net (losses)/gains on available-for-sale securities:
Net unrealized holding (losses)/gains during the period (net of tax expense/(benefit) of: EUR (4) million in 2013, EUR (15) million in 2014 and EUR 27 million in 2015)			(6	)		11			108			124
Less: reclassification adjustment for net (gains)/losses included in net income (net of tax (expense)/benefit of: EUR (38) million in 2013, EUR (28) million in 2014 and EUR (4) million in 2015)			(212	)		(95	)		(9	)		(10	)
Less: Reclassification adjustment for other-than-temporary impairment of available-for-sale securities (net of tax benefit of EUR 49 million in 2013, EUR 1 million in 2014 and EUR 10 million in 2015)			146			4			26			30

Total net (losses)/gains on available-for-sale securities			(72	)		(80	)		125			144

Pension (liability)/asset (net of tax expense/(benefit) of EUR 3 million in 2013, EUR (6) million in 2014 and EUR 6 million in 2015)			36			(43	)		31			35

Total other comprehensive income / (loss), net of tax			(1,362	)		116			(448	)		(512	)

Comprehensive loss			(1,293	)		(2,357	)		(8,915	)		(10,201	)

Less: Comprehensive income attributable to the non-controlling interest			17			(13	)		(4	)		(5	)
Comprehensive loss attributable to NBG shareholders			(1,276	)		(2,370	)		(8,919	)		(10,206	)

The accompanying notes are an integral part of these consolidated financial statements.

			Year ended December 31,

	Note		2013			2014			2015			2015
			(EUR in millions)			(EUR in millions)			(EUR in millions)			(USD in millions) (Note 2)
Common Stock:
Balance at beginning of year (956,090,482 of par value EUR 5.00 each at 2013, 2,396,785,994 at 2014 of par value EUR 0.30 each and 3,533,149,631 at 2015 of par value EUR 0.30 each)				4,780			719			1,060			1,213
Reduction of par value of the shares from EUR 5.00 to EUR 1.00 per share				(3,824	)		—			—			—
Issuance of 270,510,718 shares of par value EUR 1.00 through a non-rights issue		33		271			—			—			—
Reverse split of the common stock at a ratio of 10 existing shares of EUR 1.00 per share to be exchanged for 1 new share of EUR 10.00 per share and reduction of the par value of the shares from EUR 10.00 per share to EUR 0.30 per share		33		(1,190	)		—			—			—
Reverse split of the common stock at a ratio of 15 existing shares of EUR 0.30 per share to be exchanged for 1 new share of EUR 4.50 per share and reduction of the par value of the shares from EUR 4.50 per share to EUR 0.30 per share		33		—			—			(989	)		(1,131	)
Issuance of 2,274,125,874 shares of par value EUR 0.30 in 2013 through a rights issue, 1,136,363,637 shares of par value EUR 0.30 in 2014, and 7,307,907,231 shares of par value EUR 0.30 in 2015 through a non-rights issue		33		682			341			2,192			2,508
Conversion of 12,639,831 preference shares of par value EUR 0.30 and of 270,000,000 preference shares of par value EUR 5.00 to 1,603,700,987 common shares of par value EUR 0.30		33		—			—			481			550

Balance at end of year (2,396,785,994 shares at 2013 of par value EUR 0.30 each and 3,533,149,631 shares at 2014 of par value EUR 0.30 each and 9,147,151,527 shares at 2015 of par value EUR 0.30 each)				719			1,060			2,744			3,140

Preferred stock
Balance at beginning of year (25,000,000 shares of par value EUR 0.30 each at 2013 and 12,639,831 shares of par value EUR 0.30 each at 2014 and 2015 and 270,000,000 shares of par value EUR 5.00 each at 2013, 2014 and 2015)				1,358			1,354			1,354			1,549
Purchase of the 12,360,169 preference shares				(4	)		—			—			—
Conversion of 12,639,831 preference shares of par value EUR 0.30 and of 270,000,000 preference shares of par value EUR 5.00 to 1,603,700,987 common shares of par value EUR 0.30		33		—			—			(1,354	)		(1,549	)

Balance at end of year (12,639,831 shares of par value EUR 0.30 each at 2013 and 2014 and NIL at 2015 and 270,000,000 shares of par value EUR 5.00 each at 2013 and 2014 and NIL at 2015)				1,354			1,354			—			—

Additional Paid-in Capital:
Balance at beginning of year				4,079			17,859			19,918			22,789
Issuance of 270,510,718 shares through a non-rights issue				2			—			—			—
Issuance of 2,274,125,874 shares in 2013 and 1,136,363,637 shares in 2014, through a rights issue and a non-rights issue respectively.		33		9,074			2,159			—			—
Issue costs for the issuance of 270,510,718 and 2,274,125,874 shares in 2013, net of tax				(176	)		—			—			—
Reduction of par value per share				5,014			—			989			1,131
Conversion of 12,639,831 preference shares of par value EUR 0.30 and of 270,000,000 preference shares of par value EUR 5.00 to 1,603,700,987 common shares of par value EUR 0.30				—			—			873			999
Repurchase of 12,360,169 preference shares				(135	)		—			—			—
Gain / (Loss) on sales of treasury stock (net of tax (expense)/benefit				—			1			—			—
Issue costs net of tax in 2014 from the issuance of 1,136,363,637 shares				—			(55	)		—			—
Issue costs net of tax in 2015 from the issuance of 8,911,608,218 shares				—			—			(44	)		(50	)
Purchase of subsidiaries shares from non-controlling interest		4		1			(46	)		4			5

Balance at end of year				17,859			19,918			21,740			24,874

The accompanying notes are an integral part of these consolidated financial statements.

			Year ended December 31,

	Note		2013			2014			2015			2015
			(EUR in millions)			(EUR in millions)			(EUR in millions)			(USD in millions) (Note 2)
Accumulated Surplus/(deficit):
Balance at beginning of year				(15,037	)		(15,007	)		(17,387	)		(19,894	)
New redeemable non-controlling interest, redemption of redeemable non-controlling interest and changes in the redemption amount of redeemable non-controlling interests		33		(7	)		97			—			—
Net income /(loss) attributable to NBG shareholders				37			(2,477	)		(8,464	)		(9,684	)

Balance at end of year				(15,007	)		(17,387	)		(25,851	)		(29,578	)

Accumulated Other Comprehensive Income/ (Loss)—net of tax:		42
Balance at beginning of year				(1,283	)		(2,596	)		(2,547	)		(2,914	)
Net change in fair value of securities available-for-sale				(64	)		(82	)		125			143
Foreign currency translation adjustments				(1,285	)		233			(603	)		(690	)
Pension liability				36			(43	)		31			35
Acquistion and disposal of subsidiaries shares from / to non-controlling interest				—			(59	)		—			—

Balance at end of year				(2,596	)		(2,547	)		(2,994	)		(3,426	)

Treasury Stock, at Cost:
Balance at beginning of year (1,076, 397,655 and 1,076 shares at 2013, 2014 and 2015 respectively)				—			(2	)		—			—
Sale of treasury stock (9,770,521, 33,095,326 and 65,824,717 shares during 2013, 2014 and 2015 respectively)				45			83			66			76
Purchase of treasury stock (10,167,100, 32,698,747 and 67,825,104 shares during 2013, 2014 and 2015 respectively)				(47	)		(81	)		(67	)		(77	)

Balance at end of year (397,655, 1,076 and 2,001,463 shares at 2013, 2014 and 2015 respectively)				(2	)		—			(1	)		(1	)

Total NBG shareholders' equity				2,327			2,398			(4,362	)		(4,991	)



Non-controlling interest (NCI)—net of tax:
Balance at beginning of year				54			39			39			45
Net income/(loss)				(1	)		(2	)		(3	)		(3	)
Foreign currency translation adjustments				(2	)		—			(1	)		(1	)
Changes of non-controlling interest due to acquisitions, establishments, capital contributions and changes in subsidiaries shareholding				(12	)		2			(3	)		(4	)

Balance at end of year				39			39			32			37

Total permanent equity				2,366			2,437			(4,330	)		(4,954	)



Redeemable non-controlling interest—Temporary equity:
Balance at beginning of year				257			250			—			—
Net income				33			6			—			—
Net change in fair value of securities available-for-sale				(8	)		2			—			—
Foreign currency translation adjustments				(39	)		6			—			—
Redemption of redeemable NCI				—			(167	)		—			—
Changes in the redemption amount of redeemable NCI				7			(97	)		—			—

Balance at end of year				250			—			—			—

Total temporary equity				250			—			—			—

The accompanying notes are an integral part of these consolidated financial statements.

	Year ended December 31

	2013			2014			2015			2015
	(EUR in millions)									(USD in millions) (Note 2)
Cash flows from Operating Activities:
Net income / (loss)		69			(2,473	)		(8,467	)		(9,689	)
Adjustments to reconcile net income / (loss) to net cash provided by/(used in) operating activities:
Provision for loan losses		969			2,172			3,688			4,220
Net (gain)/loss on sale of premises and foreclosed assets		—			2			(64	)		(73	)
Net realized (gain) / loss on sales of available-for-sale securities		(250	)		(123	)		(17	)		(19	)
Other Than Temporary Impairment of AFS and HTM securities		285			6			36			41
Equity in earnings of equity method investees		1			(8	)		11			13
Depreciation of premises and equipment		111			114			106			121
Amortization of software and other intangibles		100			84			192			220
Impairment of goodwill		9			58			1,983			2,269
Impairment of equity method investments		5			—			22			25
Pension liability		220			32			36			41
Provision for deferred income taxes		(34	)		28			(35	)		(40	)
Net (gain) / loss from changes in the fair value of financial instruments designated at fair value		217			63			(41	)		(47	)
Gain on debt extinguishment		—			—			(27	)		(31	)
Gain from bargain purchase on business combination		(208	)		(3	)		—			—
Interest on financing obligation from sale of real estate		—			48			37			42
Impairment of assets classified as held for sale								3,619			4,141
Other non cash items including provisions for contingencies and impairment of other assets		(39	)		245			341			390
Changes in assets and liabilities
Trading assets, derivative instruments and financial assets marked-to-market through the profit and loss		658			1,387			(635	)		(727	)
Accrued interest receivable		(86	)		2			37			42
Other assets		(334	)		157			(204	)		(233	)
Accounts payable, accrued expenses and other liabilities		(614	)		171			(331	)		(379	)
Insurance reserves		(13	)		(256	)		(154	)		(176	)

Cash flows provided by/(used in) operating activities		1,066			1,706			133			151
Cash Flows from Investing Activities:
Activities in available-for-sale securities:
Purchases		(7,622	)		(4,828	)		(3,384	)		(3,872	)
Sales proceeds		5,192			2,517			1,181			1,351
Maturities, prepayments and calls		2,534			3,956			2,303			2,635
Activities in held-to-maturity securities:
Purchases		(983	)		(1,112	)		(449	)		(514	)
Maturities, prepayments and calls		604			916			540			618
Acquisition of subsidiaries		561			(54	)		—			—
Disposal of subsidiaries		19			—			—			—
Purchases of premises and equipment and intagibles		(200	)		(849	)		(316	)		(362	)
Proceeds from sales of premises and equipment and intagibles		2			12			104			119
Disposals/(acquisitions) of equity investments		—			16			(1	)		(1	)
Net cash provided by (used in):
Deposits with central bank		(525	)		(129	)		(4	)		(5	)
Loan origination and principal collections		3,630			(2,114	)		118			135
Securities purchased under agreements to resell		795			(56	)		85			97
Interest bearing deposits with banks		(340	)		556			252			288

Cash flows provided by / (used in) investing activities		3,667			(1,169	)		429			489

The accompanying notes are an integral part of these consolidated financial statements.

	Year ended December 31

	2013			2014			2015			2015
	(EUR in millions)			(EUR in millions)			(EUR in millions)			(USD in millions) (Note 2)
Cash flows from Financing Activities:
Proceeds from issuance of long-term debt		480			3,225			1,195			1,367
Principal repayments and retirements of long-term debt		(274	)		(1,963	)		(1,034	)		(1,183	)
Proceeds from issuance of common and preferred stock (net of issue costs of EUR 239 million in 2013, EUR 74 million in 2014 and EUR 32 million in 2015)		840			2,426			1,421			1,626
Repurchase of preference shares		(119	)		—			—			—
Purchases of treasury stock		(47	)		(81	)		(67	)		(77	)
Proceeds from sales of treasury stock		45			84			66			76
Acquisition of and increase of controlling interest in subsidiary companies		(8	)		(278	)		—			—
Sale of Real Estate accounted for as financing obligation		544			43			(74	)		(85	)
Disposal of subsidiary shareholding without loss of control		—			—			1			1
Net cash provided by/(used in):
Deposits		(9,925	)		(4,084	)		2,219			2,539
Securities sold under agreements to repurchase		3,629			316			(3,488	)		(3,991	)
Other borrowed funds		15			509			(1,291	)		(1,477	)

Cash flows provided by /(used in) financing activities		(4,820	)		197			(1,052	)		(1,204	)
Effect of exchange rate change on cash and due from banks		(102	)		25			(68	)		(77	)
Net increase/(decrease) in cash and due from banks		(189	)		759			(558	)		(641	)
Cash and due from banks at beginning of year		2,157			1,968			2,727			3,120

Cash and due from banks at end of year		1,968			2,727			2,169			2,479
Supplemental Disclosure of Cash Flow Information:
Cash paid for:
Income taxes		203			139			255			292
Interest		2,101			1,910			1,955			2,237
Supplemental schedule of non cash investing and financing activities:
Share capital increase of EUR 271 million through share exchange (see Note 33)		271			—			—			—
Share capital increase of EUR 9,756 million out of which EUR 8,677 million through subscription in kind (see Note 33)		8,677			—			—			—
Acquisition of business (see Note 4)		462			—			—			—
Common share capital increase of EUR 2,673 million out of which EUR 676 million through subscription in kind (see Note 33)		—			—			676			773
Common share capital increase of EUR 2,673 million out of which EUR 64 million through mandatory conversion of long term debt securities (see Note 33)		—			—			64			73
Common share capital increase of EUR 2,673 million out of which EUR 481 million through conversion of preference shares (see Note 33)		—			—			481			550
Contribution by HFSF of bonds issued by ESM in return for the convertible securities issued by the Bank (see Note 33)								2,029			2,322

The accompanying notes are an integral part of these consolidated financial statements.

The National Bank of Greece S.A. (the "Bank" or "NBG") is a commercial bank and was incorporated in the Hellenic Republic in 1841. The National Bank of Greece S.A. and its subsidiaries (the "Group" or "NBG 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 which includes Bulgaria, Romania, Albania, Serbia and FYROM, Cyprus, Malta, Egypt and South Africa.

The accompanying consolidated financial statements as at December 31, 2015, 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 Friday, April 29, 2016 which was EUR 0.8740 to USD 1.00 (EUR 0.9185 to USD 1.00 on December 31, 2015).

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 Code for the Tax Recording of Transactions in accordance with Greek Law 4308/2014 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 U.S. GAAP.

The Group's consolidated income statement for the twelve month period ended December 31, 2015 has been prepared stating separately continuing operations from discontinued operations, the latter relating to Finansbank in accordance with ASC 205-20 "Discontinued Operations". The comparative income statements for the years 2014 and 2013 have been restated accordingly. Group's consolidated balance sheet for the twelve month period ended December 31, 2014 has also been restated for discontinued operations i.e. Finansbank A.S. Long lived assets held for sale and the liabilities directly associated with long lived assets in the balance sheet for the year 2015, comprise Finansbank A.S., the Private Equity Funds and Astir Palace Vouliagmenis S.A and Astir Marina Vouliagmenis S.A. as follows:

In part as a response to the substantial contraction in deposits, on June 28, 2015, a bank holiday was declared for all credit institutions operating in Greece. This bank holiday was in place until July 19, 2015. The Greek government imposed numerous restrictions on financial transactions during and after this period, many of which currently continue to apply. The initial capital controls involved maximum daily withdrawal limits of 60 Euros from individual deposit accounts and limitations on transfers of funds abroad were imposed, with certain exceptions. The presently operational capital controls involve, among other limitations, a maximum cumulative weekly withdrawal limit of 420 Euros per depositor, per bank, continued certain prohibitions on the transfer of capital and cash outside of Greece, the prohibition on the opening of new accounts except for specified permitted purposes and a ban on the unwinding of certain financial arrangements (such as the prepayment of loans or accounts not established to serve certain specified purposes).

accepting notes issued or guaranteed by the Hellenic Republic as collateral for repurchase agreements, which forced the Bank to cover its increasing funding shortfall through the ELA. In the height of the liquidity crisis, on June 29, 2015 due to the termination of the negotiations and ECB's decision to freeze the level of ELA, Greek authorities imposed capital controls, in order to prevent a widespread bank run and to preserve the sustainability of the Greek banking system. Moreover, on July 7, 2015, ECB raised the haircuts on the notes issued or guaranteed by the Hellenic Republic, which subsequently further lowered the Bank's buffer for ELA refinancing. As a result of the above developments, the Bank's Eurosystem funding increased in the first half of 2015 by EUR 13.3 billion and reached EUR 27.6 billion as at June 30, 2015. However, even at that point, the Bank retained adequate buffer of ELA eligible collateral, of around EUR 5.5 billion, in order to cover further outflows.

During the second half of 2015, while the capital controls remained in force, the liquidity position of the Bank was improved. Eurosystem funding was reduced by about EUR 3.5 billion and ELA funding decreased by about EUR 6.1 billion. The main driver for these developments was the Bank's successful share capital increase that was completed in December 2015. The Bank not only enhanced its capital base, but also increased the amount of its ECB eligible collateral by receiving an amount of EUR 2.7 billion of ESM bonds, under the relevant subscription agreement. Additionally, the Bank further reduced its liabilities through the LME, by replacing all of its long-term debt, except for the covered bonds, with equity. Finally, the Bank's liquidity profile was further strengthened by a moderate increase of about EUR 1 billion in its customer deposits and by further deleveraging. In this context, on December 31, 2015, the ECB funding stood at EUR 12.5 billion, while ELA funding was EUR 11.5 billion, amounting to a total exposure to the Eurosystem of EUR 24.0 billion, whereas the Bank's liquidity buffer stood at EUR 8.4 billion (cash value), of which EUR 0.1 billion was collateral eligible for funding with the ECB and EUR 8.3 billion was collateral that could be posted in order to draw liquidity from ELA. Total Eurosystem funding amounted to EUR 14.2 billion at December 31, 2014, EUR 20.7 billion at December 31, 2013 and EUR 34.7 billion at June 30, 2012, when it reached the highest amount. Furthermore, as of May 4, 2016, Eurosystem funding has decreased to EUR 22.1 billion, of which EUR 11.1 billion through ELA, while additional financial assets of an estimated cash value EUR 6.2 billion (cash value) were available for further liquidity. In addition, if the Greek government decides to lift the capital controls, deposit outflows could have a material impact on our deposit base and on the amount of our ECB and ELA eligible collateral, which could have a material adverse impact on our liquidity and our ability to access Eurosystem funding in the future, which may in turn threaten our ability to continue as a going concern.

In view of the severe economic and financial disturbance that appeared to threaten the participation of the country to the European Monetary Union ("EMU") and the EU, the Greek government officially requested financial assistance from the European Union on July 10, 2015 with a view to restore confidence and enable the return of the economy to sustainable growth, and safeguarding the country's financial stability. The Greek request received consent, in principle, from the Eurogroup for a new three-year loan program via the ESM.

Indeed, on August 19, 2015—and following the Eurogroup Statement of August 14, 2015—the Board of Governors of the ESM approved the proposal for a Financial Assistance Facility Agreement ("FFA") with Greece, as well as adopted a Memorandum of Understanding ("MoU") with Greece. On

August 20, 2015, the first sub-tranche of EUR 13 billion of the new Program (the "Program") was disbursed for covering budget financing and debt servicing needs of the Hellenic Republic, EUR 10 billion in ESM notes, have been made immediately available for bank recapitalization and resolution purposes. Following the agreement and legislation of two additional sets of prior actions, the Greek government received another EUR 3 billion related to the first Program installment, in two sub-tranches in November and December 2015. This funding has been used to cover external debt servicing needs and contributed to a normalization of government spending and to the clearance of about EUR 0.5 billion of Government arrears to the domestic private sector (Source: ESM, December 2015 and Ministry of Finance).

As regards, developments in the Greek sovereign bond yields, the intensifying international headwinds since end-2015 and the delayed completion of the pending first review of the Program in late-2015 and early 2016 pushed the yields on Greek 10-year sovereign bond yields higher in January-February 2016 (by 143 bps to 10.4% on average, in February 2016), following a steady decline between July 2015 and December 2015 (a cumulative fall in 10-year Greek government bond yields of 520 bps) (Source: Bloomberg database).

The Group's Common Equity Tier 1 ("CET1") ratio at December 31, 2015 increased to 14.5% (see Note 36). Furthermore, on November 13, 2015 the ECB approved the Bank's Capital Plan targeted to address the Bank's capital shortfall under both the Baseline and the Adverse scenarios of the ECB's 2015 Comprehensive Assessment, as announced on October 31, 2015 (see Note 36). Part of the Capital Plan was the share capital increase completed in December 2015.

Management concluded that the Bank is going concern after considering (a) its current access to the Eurosystem facilities, (b) agreement reached between the Institutions and the Hellenic Republic in July/August 2015, (c) the Bank's and the Group's CET1 ratio of December 31, 2015 and (d) the expected positive impact on the Bank's and the Group's CET1 ratio from the remaining actions included in the Capital Plan, and in particular the completion of the disposal of Finansbank, expected by June 30, 2016.

The resolution of these material uncertainties depend, among other factors, on the successful completion of the first review of the Program, a solution for the financing needs of the Greek government, and the re-establishment of the waiver by the ECB to the use of Greek government bonds in the Eurosystem, which would likely result in a positive flow of deposits to the banking system, including NBG, and access to the international financial markets.

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. Changes in an ownership interest in a subsidiary that does not result in the Group losing control over the subsidiary are accounted for as equity transactions.

Subsequent events—All material events that occurred after the latest balance sheet date and before the financial statements were issued, have been either recognized or disclosed in the Notes to the 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 the sum of the amounts included in the balance sheet line item "Cash and due from banks" and line item "Cash and due from banks" of discontinued operations and long-lived assets held for sale (see Note 17).

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 gain/(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 income statement 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. 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 income statement. In general, a significant and prolonged unrealized loss is an OTTI unless significant and robust evidence to the contrary exists.

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, 2014 and 2015 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 gain/(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 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.

Offsetting—Financial assets and liabilities are offset and the net amount is reported in the consolidated balance sheet when, and only when there is a legally enforceable right to offset the recognised amounts and there is an intention to realize the asset and settle the liability simultaneously or on a net basis.

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 profit 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 reported 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.

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.

Investments in purchased loans or group of loans include the amount paid to the seller plus any fees paid or less any fees received. All other costs incurred in connection with acquiring purchased loans or committing to purchase loans are charged to expense as incurred. When the initial investment differs from the related loan's principal amount at the date of purchase, the difference is recognized as an adjustment of yield over the life of the loan.

Purchased loans with evidence of credit quality deterioration for which it is probable that the Group will not receive all contractually required payments receivable are accounted for as purchased credit impaired loans ("PCI loans"). The excess of the cash flows expected to be collected on PCI loans, measured as of the acquisition date, over the estimated fair value is referred to as the accretable yield and is recognized in interest income over the remaining life of the loan using a level yield methodology.

Loans also 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 individual borrowers. 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. Such loans are carried at fair value with changes in fair value reported in income statement.

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 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 customer's financial difficulties, a concession is granted to the customer that the Group would not otherwise consider. The concession granted typically involves a modification of terms such as the change of the interest rate, or the reduction of the principal, or the interest accrued off-balance sheet of the loan or the extension of maturity at a stated interest rate lower than the current market rate for a new loan with similar risk.

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. Loans classified as TDRs are considered impaired.

Allowance for loan losses and reserves for unfunded lending commitments—The allowance for loan losses is management's estimate of probable incurred losses, including probable incurred losses related to loans modified in a trouble debt restructuring. 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 or when it has been classified as TDR.

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 statutory 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 rating model. Individual loans are classified by the rating model into 21 risk categories, as described in the Corporate Credit Policy document. The rating class stems from the model algorithm taking into account both quantitative and qualitative factors like industry sector, payment history (including delinquency), capital structure etc. 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 launched in the beginning of 2007. It was optimized for its use in Greece and validated and calibrated by an internationally recognized and independent advisor. Since then, it is monitored regularly by our Group Risk Management Division, following the Basel II guidelines on monitoring of rating models. The accuracy statistics has shown a slight deterioration in the predictive ability but still the model performs well within the accepted limits, 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.

Loss forecast models are utilized for portfolios of homogeneous loans which consider a variety of factors including, but not limited to, historical loss experience, 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 seven years for credit cards and consumer loans and over 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 and credit exposures deemed to be uncollectible are charged against the provision 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 of amounts previously charged as uncollectible 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, significantly 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 lending commitments, such as commercial letters of credit, standby letters of credit and financial guarantees written. Additions to the reserve for unfunded lending commitments are made by charges to the provision for credit losses. 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 37. The levels of hierarchy with respect to the fair values are the following:

Level 1: Unadjusted 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, as well as certain government securities that are highly liquid and are actively traded in over-the-counter (OTC) markets.

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. 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 Group has an option to assess qualitative factors to determine if it is necessary to perform the goodwill impairment test. If, after assessing the totality of events or circumstances, the Group determines that it is not more-likely-than-not that the fair value of a reporting unit is less than its carrying amount, no further testing is necessary. If, however, the Group determines that it is more-likely-than-not that the fair value of a reporting unit is less than its carrying amount, then the Group is required to perform the first step of the two-step goodwill impairment test. 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 subject to amortization are amortized on a straight-line basis over the period benefited, using an estimated range of anticipated lives not exceeding a period of 20 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 held for sale, 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 expected undiscounted future cash flows of a long-lived asset are 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.

Sale and leaseback transactions—We account for sale-leaseback transactions as financings. Accordingly, we record certain of the assets subject to these transactions on our consolidated balance sheets in property and equipment and the related sales proceeds as financing obligations. Payments on the leases are recognized as interest expense and a reduction of the related obligations.

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 reassesses 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 gain/(loss) for the difference between the carrying amount and the fair value of the assets sold.

Income taxes—Income taxes payable on profits, based on the applicable tax laws in each jurisdiction, are 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 the highest amount that is 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 of last resort. 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 life insurance policies with regular and single premium mode are accounted for as long-duration and limited-payment contracts respectively. Riders attached to basic life policies distinguished by the ability of the Group to apply premium increases in order to absorb adverse claims experience. Property and Casualty insurance policies are accounted for as short duration contracts and their corresponding liabilities (Unearned premium reserves, Unexpired risk reserve, Outstanding claims reserve and Provision for claims incurred but not reported ("IBNR")) are included in Insurance Reserves in the accompanying Consolidated Balance Sheets. Income from insurance operations and expenses such as insurance claims, reserves movement, commissions and reinsurance premium ceded are included in other non-interest income and expenses, respectively. 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. Premiums collected on universal life-type contracts are not reported as revenue. Revenues from such contracts represent amounts assessed against policyholders 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. Liabilities for outstanding claims and claim adjustment expenses are estimates of payments to be made for reported claims and claim adjustment expenses and estimates of claim and claim adjustment expenses incurred but not reported. These liabilities are determined using case basis evaluations and statistical analyses of historical loss patterns and represent estimates of the ultimate cost of all losses incurred but not paid. These estimates are continually reviewed and adjusted as necessary; adjustments are recognized in the period in which the adjustments occur.

The Group establishes liabilities for amounts payable under insurance policies. Generally, amounts are payable over an extended period of time and related liabilities are calculated as the present value of future expected benefits to be paid reduced by the present value of future expected premiums. Such liabilities are established based on methods and underlying assumptions in accordance with U.S.GAAP and applicable actuarial standards. For long duration contracts, principal assumptions used in the establishment of liabilities for future policy benefits are 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 may require the establishment of premium deficiency reserve. 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. Premium deficiency reserve may also be established for short duration contracts to provide for expected future losses. These reserves are based on actuarial estimates of the amount of loss inherent in that period, including losses incurred for which claims have not been reported. Changes in the premium deficiency reserve are recognized in the period in which the changes occur. The liability for policy benefits for universal life type contracts is calculated as the balance accrued to the benefit of the policyholders at the reporting date and the amount necessary to cover any loss expected to incur due to guarantees offered to policyholders at maturity of the contract.

The Group incurs costs in connection with acquiring new and renewal insurance business. Costs that are related directly to the successful acquisition or renewal of insurance contracts, including commissions and other incremental direct costs of contract acquisition, are capitalized recognized in other assets. All other acquisition-related costs, including those related to general advertising and solicitation, market research, agent training, product development, unsuccessful sales and underwriting efforts, as well as all indirect costs, are expensed as incurred. Deferred acquisition costs are amortized over the terms of the insurance policies.

For each of its reinsurance agreements, the Group determines whether the agreement provides indemnification against loss or liability relating to insurance risk in accordance with applicable accounting standards. Cessions under reinsurance agreements do not discharge the Group's obligations as the primary insurer. The Group reviews all contractual features, particularly those that may limit the amount of insurance risk to which the reinsurer is subject or features that delay the timely reimbursement of claims. Ceded policyholder and contract related liabilities, other than those currently due, are reported gross on the Consolidated Balance Sheets. Amounts currently recoverable under reinsurance agreements are included in Other Assets and amounts currently payable are included in Other Liabilities. Assets and liabilities relating to reinsurance agreements with the same reinsurer may be recorded net on the balance sheet, if a right of offset exists within the reinsurance agreement. In the event that reinsurers do not meet their obligations to the Group under the terms of the reinsurance agreements, reinsurance recoverable balances could become uncollectible. In such instances, reinsurance recoverable balances are stated net of allowances for uncollectible reinsurance.

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 include, among other items, assets acquired through foreclosure proceedings, accounts receivable of non-financial services sector subsidiaries, deferred tax assets and taxes withheld.

Other liabilities include, 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.

The Group, under certain government-sponsored loan guarantee programs, can extend mortgage loans to borrowers with a guarantee that entitles the Group to recover all or a portion of the unpaid principal balance from the government if the borrower defaults. A mortgage loan is derecognized and a separate other receivable is recognized upon foreclosure if the following conditions are met: (1) The loan has a government guarantee that is not separable from the loan before foreclosure. (2) At the time of foreclosure, the Group has the intent to convey the real estate property to the guarantor and make a claim on the guarantee, and the Group has the ability to recover under that claim and (3) At the time of foreclosure, any amount of the claim that is determined on the basis of the fair value of the real estate is fixed. Upon foreclosure, the separate other receivable is measured based on the amount of the loan balance (principal and interest) expected to be recovered from the guarantor.

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.

Particularly, a disposal of a component of the Group or a group of components of the Group is reported in discontinued operations if the disposal represents a strategic shift that has (or will have) a major effect on the Group's operations and financial results when any of the following occurs:

Discontinued operations are presented on the face of the consolidated statement of income and comprehensive income.

Current provisions applying to the bank under the Hellenic Republic Support plan and the HFSF recapitalization framework

determined that such resolution may jeopardize the interests of the Bank's depositors or materially affect its solvency and orderly operation. In addition, pursuant to the HFSF Law, and in line with the provisions of the Amended Relationship Framework Agreement with the HFSF, the HFSF's representative who sits on the Board of Directors also has the veto right over decisions regarding the distribution of dividends.

In addition, because the Bank has issued CoCos to the HFSF as part of the recapitalization completed in December 2015, as described in Note 25, and in line with the provisions of Cabinet Act 36/2015, no dividend shall be paid on the Bank's shares, in case the Bank has elected not to pay interest on the CoCos during the previous interest payment date.

Provisions on Payments of Dividends in line with the Capital Requirements Directive and Greek Company Law

In particular, the Bank's profit for a relevant period would be allocated as follows:

Pursuant to Article 131 of the CRD Law (which transposed into Greek Law article 141 of the CRD IV Directive), the Bank may not make, inter alia, dividend payments, if and to the extent that such payment would cause, when aggregated with other distributions in connection with CET1 referred to in paragraph 1 of Article 131 of Greek law 4261/2014 (which transposed into Greek law Article 141(2) of the CRD IV Directive) the Maximum Distributable Amount to be exceeded. In particular, under Article 131 of Greek Law 4261/2014, credit institutions that meet the combined buffer requirement, are prohibited from making a distribution in connection with CET1 to an extent that would decrease its CET1 capital to a level where the combined buffer requirement is no longer met, whereas credit institutions that fail to meet the "combined buffer requirement" must determine a Maximum Distributable Amount to be calculated in accordance with the provisions of the CRD Law and notify such Maximum Distributable Amount to the Bank of Greece. In the latter case, the credit institution shall not undertake any of the following actions before it has calculated the Maximum Distributable Amount: (a) make a distribution in connection with Common Equity Tier 1 capital; (b) create an obligation to pay variable remuneration or discretionary pension benefits or pay variable remuneration if the obligation to pay was created at a time when the institution failed to meet the

combined buffer requirements; (c) make payments on Additional Tier 1 instruments While an institution fails to meet or exceed its combined buffer requirement, it shall not distribute through any action referred to in the preceding paragraph more than the Maximum Distributable Amount calculated in accordance with article 131 of Greek Law 4261/2014. The above requirement for restrictions on distributions shall apply during the transitional period between January 1, 2016 and December 31, 2018 where institutions fail to meet the combined buffer requirement.

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 Group, as a secured party, generally has the right to require the counterparties to provide collateral, including letters of credit, cash, securities and other financial assets.

The amounts advanced under resale agreements and the amounts borrowed under repurchase agreements are carried on the consolidated 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-to-maturity transactions—A repurchase agreement in which the settlement date of the agreement to repurchase a transferred financial asset is at the maturity date of that financial asset and the agreement does not require the transferor to reacquire the financial asset is accounted for as secured borrowing as if the transferor maintains effective control.

Repurchase financing arrangements—An initial transfer of a financial asset and a contemporaneous repurchase agreement repurchase agreement with the same counterparty are accounted for separately. The repurchase agreement is recognized as secured borrowing.

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 income statement as the gains or losses are realized upon sale of the securities. Other-than-temporary impairment charges are reclassified to income statement at the time of the charge. Translation gains or losses on foreign currency translation adjustments are reclassified to income statement upon the substantial sale or liquidation of investments in foreign operations.

Treasury stock—The Group's 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 ordinary 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 January 2014, the FASB issued ASU 2014-04 "Receivables—Troubled Debt Restructurings by Creditors (Subtopic 310-40) Reclassification of Residential Real Estate Collateralized Consumer Mortgage Loans upon Foreclosure". The amendments in this Update clarify that an in substance repossession or foreclosure occurs, and a creditor is considered to have received physical possession of residential real estate property collateralizing a consumer mortgage loan, upon either (1) the creditor

obtaining legal title to the residential real estate property upon completion of a foreclosure or (2) the borrower conveying all interest in the residential real estate property to the creditor to satisfy that loan through completion of a deed in lieu of foreclosure or through a similar legal agreement. Additionally, the amendments require interim and annual disclosure of both (1) the amount of foreclosed residential real estate property held by the creditor and (2) the recorded investment in consumer mortgage loans collateralized by residential real estate property that are in the process of foreclosure according to local requirements of the applicable jurisdiction. The amendments in this Update are effective for annual periods, and interim periods within those annual periods, beginning after December 15, 2014. An entity can elect to adopt the amendments in this Update using either a modified retrospective transition method or a prospective transition method. Under the modified retrospective transition method, an entity should apply the amendments in this Update by means of a cumulative-effect adjustment to residential consumer mortgage loans and foreclosed residential real estate properties existing as of the beginning of the annual period for which the amendments are effective. Assets reclassified from real estate to loans as a result of adopting the amendments in this Update should be measured at the carrying value of the real estate at the date of adoption. Assets reclassified from loans to real estate as a result of adopting the amendments in this Update should be measured at the lower of the net amount of loan receivable or the real estate's fair value less costs to sell at the time of adoption. For prospective transition, an entity should apply the amendments in this Update to all instances of an entity receiving physical possession of residential real estate property collateralized by consumer mortgage loans that occur after the date of adoption. The implementation of these amendments by the Group did not have a significant impact on the Group's financial position and results of operations.

In June 2014, the FASB issued ASU 2014-11 "Transfers and Servicing (Topic 860) Repurchase-to-Maturity Transactions, Repurchase Financings, and Disclosures". The amendments in this Update require two accounting changes. First, the amendments in this Update change the accounting for repurchase-to-maturity transactions to secured borrowing accounting. Second, for repurchase financing arrangements, the amendments require separate accounting for a transfer of a financial asset executed contemporaneously with a repurchase agreement with the same counterparty, which will result in secured borrowing accounting for the repurchase agreement.

The amendments in this Update require disclosures for certain transactions comprising (1) a transfer of a financial asset accounted for as a sale and (2) an agreement with the same transferee entered into in contemplation of the initial transfer that results in the transferor retaining substantially all of the exposure to the economic return on the transferred financial asset throughout the term of the transaction. For those transactions outstanding at the reporting date, the transferor is required to disclose the following by type of transaction (for example, repurchase agreements, securities lending arrangements, and a sale with a total return swap):

The amendments in this Update also require the following disclosures for repurchase agreements, securities lending transactions, and repurchase-to-maturity transactions that are accounted for as secured borrowings:

The implementation of these amendments by the Group did not have a significant impact on the Group's financial position and results of operations.

In August 2014, the FASB issued ASU 2014-14 "Receivables—Troubled Debt Restructurings by Creditors (Subtopic 310-40) Classification of Certain Government-Guaranteed Mortgage Loans upon Foreclosure". Under certain government-sponsored loan guarantee programs, qualifying creditors can extend mortgage loans to borrowers with a guarantee that entitles the creditor to recover all or a portion of the unpaid principal balance from the government if the borrower defaults.

The amendments in this Update require that a mortgage loan be derecognized and that a separate other receivable be recognized upon foreclosure if the following conditions are met: (1) The loan has a government guarantee that is not separable from the loan before foreclosure. (2) At the time of foreclosure, the creditor has the intent to convey the real estate property to the guarantor and make a claim on the guarantee, and the creditor has the ability to recover under that claim and (3) At the time of foreclosure, any amount of the claim that is determined on the basis of the fair value of the real estate is fixed.

Upon foreclosure, the separate other receivable should be measured based on the amount of the loan balance (principal and interest) expected to be recovered from the guarantor. The implementation of these amendments by the Group did not have a significant impact on the Group's financial position and results of operations.

In April 2014, the FASB issued ASU 2014-08 "Presentation of Financial Statements (Topic 205) and Property, Plant, and Equipment (Topic 360) Reporting Discontinued Operations and Disclosures of Disposals of Components of an Entity". ASU 2014-08 changes the criteria for reporting discontinued operations while enhancing disclosures. Under the ASU, only disposals representing a strategic shift having a major effect on an entity's operations and financial results, such as a disposal of a major geographic area, a major line of business or a major equity method investment, may be presented as discontinued operations. Additionally, the ASU requires entities to separately present assets and liabilities of a discontinued operation for all comparative periods on the face of the balance sheet. Before these amendments, ASC 205-20 neither required nor prohibited such presentation.

The Group's consolidated income statement for the twelve months period ended December 31, 2013 and 2014 and balance sheet as at December 31, 2014 and respective disclosures have been restated in order to exclude the impact of discontinued operations (i.e. Finansbank A.S.). See Note 17 for an analysis of the discontinued operations and long-lived assets held for sale and liabilities directly associated with long-lived assets held for sale.

In May 2015, the FASB issued ASU 2015-08 "Business Combinations (Topic 805)". This Update amends various SEC paragraphs pursuant to the issuance of Staff Accounting Bulletin No. 115, Topic 5: Miscellaneous Accounting, regarding various pushdown accounting issues. This ASU is applicable to all entities and is effective upon issuance (issuance date May 8, 2015). The implementation of these amendments by the Group did not have a significant impact on the Group's financial position, results of operations and disclosures.

In November 2014, the FASB issued ASU 2014-16 "Derivatives and Hedging (Topic 815)". Determining Whether the Host Contract in a Hybrid Financial Instrument Issued in the Form of a Share Is More Akin to Debt or to Equity". The amendments in this Update do not change the current criteria in U.S. GAAP for determining when separation of certain embedded derivative features in a hybrid financial instrument is required. That is, an entity should consider all relevant terms and features, including the embedded derivative feature being evaluated for bifurcation, in evaluating the nature of the host contract.. The amendments clarify how current U.S. GAAP should be interpreted in evaluating the economic characteristics and risks of a host contract in a hybrid financial instrument that is issued in the form of a share. Specifically, the amendments clarify that an entity should consider all relevant terms and features—including the embedded derivative feature being evaluated for bifurcation—in evaluating the nature of the host contract. Furthermore, the amendments clarify that no single term or feature would necessarily determine the economic characteristics and risks of the host contract. Rather, the nature of the host contract depends upon the economic characteristics and risks of the entire hybrid financial instrument.

In addition, the amendments in this Update clarify that, in evaluating the nature of a host contract, an entity should assess the substance of the relevant terms and features (that is, the relative strength of the debt-like or equity-like terms and features given the facts and circumstances) when considering how to weight those terms and features. The assessment of the substance of the relevant terms and features should incorporate a consideration of the characteristics of the terms and features themselves; the circumstances under which the hybrid financial instrument was issued or acquired; and the potential outcomes of the hybrid financial instrument, as well as the likelihood of those potential outcomes.

The Group early adopted this ASU in 2015 prospectively and applied its guidance for determining the nature of the host contract when evaluating each embedded feature of the contingently convertible securities issued by the Bank on December 9, 2015. See Note 25. The impact of adopting the ASU was not material on the Group's financial position and results of operations.

In May 2014, the FASB issued ASU 2014-09 "Revenue from Contracts with Customers (Topic 606)". The guidance in this Update affects any entity that either enters into contracts with customers to transfer goods or services or enters into contracts for the transfer of nonfinancial assets unless those contracts are within the scope of other standards (for example, insurance contracts or lease contracts). The ASU will replace most existing revenue recognition guidance in U.S. GAAP when it becomes effective on January 1, 2018. Early application is permitted for annual periods beginning after December 15, 2016; however, the Group does not expect to early adopt. The ASU is not applicable to financial instruments and, therefore, is not expected to impact a majority of the Group's revenue, including net interest income. Further, in April 2016, the FASB issued ASU 2016-10 "Revenue

from Contracts with Customers (Topic 606): Identifying Performance Obligations and Licensing". This Update clarifies guidance related to identifying performance obligations and licensing implementation guidance contained in the new revenue recognition standard. The Group is evaluating the effect that ASU 2014-09 and ASU 2016-10 will have on its financial position and results of operations.

In August 2014, the FASB issued ASU 2014-13 "Measuring the Financial Assets and the Financial Liabilities of a Consolidated Collateralized Financing Entity". The amendments in ASU 2014-13 provide an alternative to Topic 820, Fair Value Measurement, for measuring the financial assets and the financial liabilities of a consolidated collateralized financing entity to eliminate the difference in the fair value of the financial assets of a collateralized financing entity, as determined under U.S. GAAP, when they differ from the fair value of its financial liabilities even when the financial liabilities have recourse only to the financial assets. When the measurement alternative is elected, both the financial assets and the financial liabilities of the collateralized financing entity should be measured using the more observable of the fair value of the financial assets or the fair value of the financial liabilities. The amendments clarify that when the measurement alternative is elected, a reporting entity's consolidated net income (loss) should reflect the reporting entity's own economic interests in the collateralized financing entity, including: (1) changes in the fair value of the beneficial interests retained by the reporting entity, and (2) beneficial interests that represent compensation for services. The amendments in this ASU are effective for annual periods and interim periods within those annual periods beginning after December 15, 2015. Early application is permitted. The Group has not applied these amendments and has not yet determined their impact on the Group's financial position and results of operations.

In August 2014, the FASB issued ASU 2014-15 "Presentation of Financial Statements—Going Concern (Subtopic 205-40) Disclosure of Uncertainties about an Entity's Ability to Continue as a Going Concern". The amendments in this Update require that in connection with preparing financial statements for each annual and interim reporting period, an entity's management should evaluate whether there are conditions or events, considered in the aggregate, that raise substantial doubt about the entity's ability to continue as a going concern within one year after the date that the financial statements are issued (or within one year after the date that the financial statements are available to be issued when applicable). The amendments in ASU 2014-15 are intended to define management's responsibility to evaluate whether there is substantial doubt about an organization's ability to continue as a going concern and to provide related footnote disclosures. The amendments in this Update are effective for the annual period ending after December 15, 2016, and for annual periods and interim periods thereafter. Early application is permitted. The Group has not applied these amendments but the ASU is not expected to have an impact on the Group's financial position and results of operations.

In January 2015, the FASB issued ASU No. 2015-1 "Income Statement—Extraordinary and Unusual Items (Subtopic 225-20)". The objective of this Update is to simplify the income statement presentation requirements in Subtopic 225-20 by eliminating the concept of extraordinary items. Extraordinary items are events and transactions that are distinguished by their unusual nature and by the infrequency of their occurrence. Eliminating the extraordinary classification simplifies income statement presentation by altogether removing the concept of extraordinary items from consideration. The amendments in this Update are effective for fiscal years, and interim periods within those fiscal years, beginning after December 15, 2015. A reporting entity may apply the amendments prospectively. A reporting entity also may apply the amendments retrospectively to all prior periods presented in the financial statements. Early adoption is permitted provided that the guidance is applied from the

beginning of the fiscal year of adoption. The Group has not applied these amendments but the ASU is not expected to have an impact on the Group's financial position and results of operations.

In February 2015, the FASB issued ASU No. 2015-02 "Consolidation (Topic 810)". The amendments in this Update affect reporting entities that are required to evaluate whether they should consolidate certain legal entities. All legal entities are subject to reevaluation under the revised consolidation model. Specifically, the amendments:

The amendments in this Update are effective for public business entities for fiscal years, and for interim periods within those fiscal years, beginning after December 15, 2015. For all other entities, the amendments in this Update are effective for fiscal years beginning after December 15, 2016, and for interim periods within fiscal years beginning after December 15, 2017. Early adoption is permitted, including adoption in an interim period. A reporting entity also may apply the amendments retrospectively. The Group has not applied these amendments and has not yet determined their impact on the Group's financial position, results of operations and disclosures.

In April 2015, the FASB issued ASU No. 2015-03—"Interest—Imputation of Interest (Subtopic 835-30)". To simplify presentation of debt issuance costs, the amendments in this Update require that debt issuance costs related to a recognized debt liability be presented in the balance sheet as a direct deduction from the carrying amount of that debt liability, consistent with debt discounts. The recognition and measurement guidance for debt issuance costs are not affected by the amendments in this Update. For public business entities, the amendments in this Update are effective for financial statements issued for fiscal years beginning after December 15, 2015. Early adoption of the amendments in this Update is permitted for financial statements that have not been previously issued. In August 2015, the FASB issued ASU 2015-15—Interest—Imputation of Interest (Subtopic 835-30): Presentation and Subsequent Measurement of Debt Issuance Costs Associated with Line-of-Credit Arrangements. This ASU adds SEC paragraphs pursuant to the SEC Staff Announcement at the June 18, 2015 Emerging Issues Task Force (EITF) meeting about the presentation and subsequent measurement of debt issuance costs associated with line-of-credit arrangements.

In April 2015, the FASB issued ASU No. 2015-04—"Compensation—Retirement Benefits (Topic 715)". The amendments in this Update provide a practical expedient for employers with fiscal year-ends that do not fall on a month-end by permitting those employers to measure defined benefit plan assets and obligations as of the month-end that is closest to the entity's fiscal year-end. For public business entities, the amendments in the ASU are effective for financial statements issued for fiscal

years beginning after December 15, 2015, and interim periods within those fiscal years. This ASU is not applicable and will have no effect on the Group's financial position and results of operations.

In April 2015, the FASB issued ASU No. 2015-05—"Intangibles—Goodwill and Other—Internal-Use Software (Subtopic 350-40)". The objective of the amendments in this Update is to address the concerns of stakeholders that the lack of guidance about a customer's accounting for fees in a cloud computing arrangement leads to unnecessary cost and complexity when evaluating the accounting for those fees, as well as some diversity in practice. The amendments in this ASU help entities evaluate the accounting for fees paid by a customer in a cloud computing arrangement by providing guidance as to whether an arrangement includes the sale or license of software. The amendments are effective for public business entities for annual periods, including interim periods within those annual periods, beginning after December 15, 2015. Early adoption is permitted. The Group has not applied these amendments and has not yet determined their impact on the Group's financial position, results of operations and disclosures.

In May 2015, the FASB issued ASU 2015-07 "Fair Value Measurement (Topic 820)", which is intended to reduce diversity in practice related to the categorization of investments measured at NAV within the fair value hierarchy. The ASU removes the current requirement to categorize investments for which fair value is measured using the NAV per share practical expedient within the fair value hierarchy. The amendments also remove the requirement to make certain disclosures for all investments that are eligible to be measured at fair value using the net asset value per share practical expedient. Rather, those disclosures are limited to investments for which the entity has elected to measure the fair value using that practical expedient. The amendments in this Update are effective for public business entities for fiscal years beginning after December 15, 2015, and interim periods within those fiscal years. A reporting entity should apply the amendments retrospectively to all periods presented. Earlier application is permitted. The Group has not applied these amendments and has not yet determined their impact on the Group's financial position, results of operations and disclosures.

In May 2015, the FASB issued ASU 2015-09 "Financial Services—Insurance (Topic 944) Disclosures about Short-Duration Contracts". The amendments in ASU 2015-09 require insurance entities to disclose for annual reporting periods information about the liability for unpaid claims and claim adjustment expenses. The amendments also require insurance entities to disclose information about significant changes in methodologies and assumptions used to calculate the liability for unpaid claims and claim adjustment expenses, including reasons for the change and the effects on the financial statements. In addition, the amendments require insurance entities to disclose for annual and interim reporting periods a roll-forward of the liability for unpaid claims and claim adjustment expenses. For health insurance claims, the amendments require the disclosure of the total of incurred-but-not-reported liabilities and expected development on reported claims included in the liability for unpaid claims and claim adjustment expenses. The amendments in this Update are effective for annual periods beginning after December 15, 2015, and interim periods within annual periods beginning after December 15, 2016. The Group has not applied these amendments and has not yet determined their impact on the Group's financial position, results of operations and disclosures.

In May 2015, the FASB issued ASU 2015-10 "Technical Corrections and Improvements". The amendments in this Update cover a wide range of Topics in the Codification. The amendments in this Update represent changes to make minor corrections or minor improvements to the Codification that are not expected to have a significant effect on current accounting practice or create a significant

administrative cost to most entities. The amendments in this Update that require transition guidance are effective for fiscal years, and interim periods within those fiscal years, beginning after December 15, 2015. Early option is permitted. The Group has not applied these amendments and has not yet determined their impact on the Group's financial position, results of operations and disclosures.

In September 2015, the FASB issued ASU 2015-16 "Business Combinations (Topic 805): Simplifying the Accounting for Measurement-Period Adjustments". The amendments in this Update require that an acquirer recognize adjustments to provisional amounts that are identified during the measurement period in the reporting period in which the adjustment amounts are determined. The amendments in this Update require that the acquirer record, in the same period's financial statements, the effect on earnings of changes in depreciation, amortization, or other income effects, if any, as a result of the change to the provisional amounts, calculated as if the accounting had been completed at the acquisition date. The amendments in this Update require an entity to present separately on the face of the income statement or disclose in the notes the portion of the amount recorded in current-period earnings by line item that would have been recorded in previous reporting periods if the adjustment to the provisional amounts had been recognized as at the acquisition date. The amendments in this Update are effective for fiscal years beginning after December 15, 2015, including interim periods within those fiscal years. The amendments in this Update should be applied prospectively to adjustments to provisional amounts that occur after the effective date of this Update with earlier application permitted for financial statements that have not been issued. The Group has not applied these amendments and has not yet determined their impact on the Group's financial position, results of operations and disclosures.

In January 2016, the FASB issued ASU 2016-01 "Financial Instruments—Overall (Subtopic 825-10): Recognition and Measurement of Financial Assets and Financial Liabilities". The amendments in this Update make targeted improvements to generally accepted accounting principles (GAAP) as follows:

The amendments in this ASU are effective for fiscal years beginning after December 15, 2017, including interim periods within those fiscal years. The ASU permits early adoption of the own credit provision. The Group has not applied these amendments and has not yet determined their impact on the Group's financial position, results of operations and disclosures.

In January 2016, the FASB issued ASU 2016-02 "Leases (Topic 842)", which is intended to increase transparency and comparability of accounting for lease transactions. The ASU will require all leases to be recognized on the balance sheet as lease assets and lease liabilities and will require both quantitative and qualitative disclosures regarding key information about leasing arrangements. Lessor accounting is largely unchanged. The amendments in this ASU are effective for fiscal years beginning after December 15, 2018. Early application of the amendments in this Update is allowed. The Group has not applied these amendments and has not yet determined their impact on the Group's financial position, results of operations and disclosures.

In March 2016, the FASB issued ASU 2016-05 "Derivatives and Hedging (Topic 815), Effect of Derivative Contract Novations on Existing Hedge Accounting Relationships". The amendments in this Update clarify that a change in the counterparty to a derivative instrument that has been designated as the hedging instrument under Topic 815 does not, in and of itself, require dedesignation of that hedging relationship provided that all other hedge accounting criteria (including those in paragraphs 815-20-35-14 through 35-18) continue to be met. the amendments in this Update are effective for financial statements issued for fiscal years beginning after December 15, 2016, and interim periods within those fiscal years. An entity has an option to apply the amendments in this Update on either a prospective basis or a modified retrospective basis. The Group has not applied these amendments but the ASU is not expected to have an impact on the Group's financial position and results of operations.

In March 2016, the FASB issued ASU 2016-06 "Derivatives and Hedging (Topic 815), Contingent Put and Call Options in Debt Instruments". The amendments in this Update clarify the requirements for assessing whether contingent call (put) options that can accelerate the payment of principal on debt instruments are clearly and closely related to their debt hosts. An entity performing the assessment under the amendments in this Update is required to assess the embedded call (put) options solely in accordance with the four-step decision sequence and it does not have to assess whether the event that triggers the ability to exercise a call (put) option is related to interest rates or credit risks. The amendments in this Update are effective for financial statements issued for fiscal years beginning after December 15, 2016, and interim periods within those fiscal years. The Group has not applied these amendments and has not yet determined their impact on the Group's financial position, results of operations and disclosures.

In March 2016, the FASB issued ASU 2016-07 "Investments—Equity Method and Joint Ventures (Topic 323), Simplifying the Transition to the Equity Method of Accounting". The amendments in this Update eliminate the requirement that when an investment qualifies for use of the equity method as a result of an increase in the level of ownership interest or degree of influence, an investor must adjust the investment, results of operations, and retained earnings retroactively on a step-by step basis as if the equity method had been in effect during all previous periods that the investment had been held.

The amendments require that the equity method investor add the cost of acquiring the additional interest in the investee to the current basis of the investor's previously held interest and adopt the equity method of accounting as at the date the investment becomes qualified for equity method accounting. Therefore, upon qualifying for the equity method of accounting, no retroactive adjustment of the investment is required. The amendments in this Update require that an entity that has an available-for sale equity security that becomes qualified for the equity method of accounting recognize through earnings the unrealized holding gain or loss in accumulated other comprehensive income at the date the investment becomes qualified for use of the equity method. The amendments in this Update are effective for all entities for fiscal years, and interim periods within those fiscal years, beginning after December 15, 2016. The amendments should be applied prospectively upon their effective date to increases in the level of ownership interest or degree of influence that result in the adoption of the equity method. Earlier application is permitted. No additional disclosures are required at transition. The Group has not applied these amendments and has not yet determined their impact on the Group's financial position, results of operations and disclosures.

In March 2016, the FASB issued ASU 2016-08 "Revenue from Contracts with Customers (Topic 606), Principal versus Agent Considerations (Reporting Revenue Gross versus Net)". The amendments in this Update clarify the implementation guidance on principal versus agent considerations. The amendments in this Update are effective for annual reporting periods beginning after December 15, 2017. The Group has not applied these amendments and has not yet determined their impact on the Group's financial position, results of operations and disclosures.

In March 2016, the FASB issued ASU 2016-09 "Compensation—Stock Compensation (Topic 718), Improvements to Employee Share-Based Payment Accounting". The areas for simplification in this Update involve several aspects of the accounting for share-based payment transactions, including the income tax consequences, classification of awards as either equity or liabilities, and classification on the statement of cash flows. Some of the areas for simplification apply only to nonpublic entities. The amendments in this Update are effective for annual periods beginning after December 15, 2016, and interim periods within those annual periods. Early adoption is allowed. The Group has not applied these amendments and has not yet determined their impact on the Group's financial position, results of operations and disclosures.

In May 2016, the FASB issued ASU 2016-11—"Revenue Recognition (Topic 605) and Derivatives and Hedging (Topic 815) Rescission of SEC Guidance Because of Accounting Standards Updates 2014-09 and 2014-16 Pursuant to Staff Announcements at the March 3, 2016 EITF Meeting". This ASU amends various SEC paragraphs of ASC 605 and ASC 815 pursuant to the issuance of ASU 2014-09 and ASU 2014-16. The implementation of these amendments by the Group did not have a significant impact on the Group's financial position, results of operations and disclosures.

NOTE 4: MERGERS, ACQUISITIONS, DISPOSALS AND NEW ENTITIES ESTABLISHED (Continued)

The following table summarizes the fair value of assets and liabilities acquired of Picasso—Fondo as at the date of acquisition which is March 20, 2014.

NOTE 4: MERGERS, ACQUISITIONS, DISPOSALS AND NEW ENTITIES ESTABLISHED (Continued)

As the Bank acquired Probank's and FBB's network of 112 and 19 branches, respectively, with the personnel and operations, that is customers transactions, deposits and loans, each transaction is considered as an acquisition of an integrated set of activities and assets that is capable of being conducted and managed for the purpose of providing a return to the Bank, therefore meets the definition of a business combination of ASC 805 "Business combinations".

The following tables summarize the fair value of assets acquired, liabilities assumed, as determined by the Bank, and the non-controlling interest at the acquisition date of Probank and FBB:

Probank	July 26, 2013 (EUR in millions)

	Group
ASSETS
Cash and balance with central bank		60
Due from banks		22
Loans and advances to customers		2,152
Investment securities		240
Property and equipment		30
Other assets		148
Cash received from HFSF (funding gap)		563

Total assets		3,215



LIABILITIES
Due to banks		18
Due to customers		2,983
Other liabilities		26

Non-controlling interest		3

Total liabilities & non-controlling interest		3,030



Negative goodwill		185

The gross contractual amounts of loans and advances to customers, at the acquisition date, amounted to EUR 2,447 million. At the acquisition date, the amount not expected to be collected was EUR 422 million.

The Bank of Greece with its decision 15/30.12.2013 finalized the valuation of the transferred assets and liabilities of Probank and determined the difference (funding gap) to EUR 563 million. HFSF covered the aforesaid difference by contributing to the Bank cash equal to the funding gap. The gain "negative goodwill" of EUR 185 million, which is calculated as the difference between the fair value of

NOTE 4: MERGERS, ACQUISITIONS, DISPOSALS AND NEW ENTITIES ESTABLISHED (Continued)

the transferred assets and liabilities at the acquisition date and the cash received, was recognized directly in the income statement within the "Other non-interest income" line item.

FBB	May 10, 2013

	(EUR in millions)
ASSETS
Due from banks (Central Bank included)		46
Loans and advances to customers		779
Investment securities		58
Property and equipment		8
Other assets		49
Fair value of EFSF bonds received from HFSF (funding gap)		462

Total assets		1,402



LIABILITIES
Due to banks (Central Bank included)		309
Due to customers		1,066
Other liabilities		4

Total liabilities		1,379



Negative goodwill		23

The gross contractual amounts of loans and advances to customers, at the acquisition date, amounted to EUR 1,093 million. At the acquisition date the amount not expected to be collected was EUR 314 million.

The Bank of Greece with its decision 13/7.11.2013 finalized the valuation of the transferred assets and liabilities of FBB and determined the difference (funding gap) to EUR 457 million. HFSF covered the aforesaid difference by contributing to the Bank EFSF bonds of nominal value equal to the funding gap. The fair value of the EFSF bonds amounted to EUR 462 million. The gain "negative goodwill" of EUR 23 million, which is calculated as the difference between the fair value of the transferred assets and liabilities at the acquisition date and the fair value of EFSF bonds received, was recognized directly in the income statement within the "Other non-interest income" line item.

NOTE 4: MERGERS, ACQUISITIONS, DISPOSALS AND NEW ENTITIES ESTABLISHED (Continued)

As a result of the above, the Bank's investment in Eurobank was accounted for as AFS investment. The fair value of the investment in Eurobank immediately after recapitalization amounted to EUR 181 million and was the initial balance of Eurobank as an AFS investment. The difference between the initial balance of Eurobank as an AFS investment and the fair value of NBG shares issued to acquire Eurobank amounted to loss of EUR 92 million and was recognized in the consolidated statement of income and comprehensive income within the "Other-Than-Temporary-Impairment (of which NIL was recognized in OCI)" line item. The subsequent decrease in the fair value of the investment in Eurobank amounted to EUR 173 million and has also been recognized in the income statement as OTTI as at December 31, 2013.

NOTE 4: MERGERS, ACQUISITIONS, DISPOSALS AND NEW ENTITIES ESTABLISHED (Continued)

The following table summarizes the fair value of assets and liabilities of KARELA S.A. as at the date of acquisition which is February 15, 2013.

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 1% 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 at 0.05% as at December 31, 2015 while the corresponding deposits of 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 not sold or re-pledged as at December 31, 2014 and 2015 any of the securities accepted as collateral.

Fair value of debt and equity assets held for trading purposes at December 31, comprised:

Net unrealized losses on trading assets (debt and equity) of EUR (125) million, EUR (13) million and EUR (1) million were included in net trading gains/(loss) during 2013, 2014 and 2015, respectively.

Trading assets include securities that are pledged as collateral of EUR 931 million and EUR 1,109 million as at December 31, 2014 and 2015, 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. 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 following tables present the contract or notional amounts and the fair value amounts at December 31, 2014 and 2015 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 or posted.

Credit derivative liabilities at December 31, 2014 and December 31, 2015 relate to a guarantee for the non-payment risk of the Hellenic Republic.

Gains and losses on derivative instruments are presented within Net trading gain / (loss) in the Statement of Income and Comprehensive Income and for the year ended December 31, 2013, 2014 and 2015 and are analyzed as follows:

Occasionally, the Group uses credit derivatives such as Credit Default Swaps ("CDS") and total return swaps in managing risks of the Group's bond portfolio and other cash instruments. CDS contracts are governed by standard International Swaps and Derivatives Association, Inc. ("ISDA") documentation which defines trigger events which result in settlement payouts. Examples of these triggers include bankruptcy of the reference entity, failure of the reference entity to meeting contractual obligations and debt restructuring of the reference entity. These triggers also apply to credit default protection sold. The Group uses credit derivatives to mitigate borrower-specific exposure as part of the Group's portfolio risk management techniques. The credit, legal and other risks associated with these transactions are controlled through established procedures. The Group's policy is to enter into these transactions with investment grade financial institutions. Credit risk to these counterparties is managed through the same approval, limit and monitoring processes that is used for all counterparties to which the Group has credit exposure. As at December 31, 2014 and 2015, the potential maximum loss for the credit contracts sold amounted to EUR 457 million and EUR 481 million respectively against which the Group held cash collateral equal to NIL and NIL respectively. This potential loss derives exclusively from surrendering of the collateral and the holder is not entitled to claim from the Group any amount exceeding the carrying value of the collateral as of the date that the contract is triggered for payment. Credit contracts sold comprise solely of a written guarantee of EUR 322 million and EUR 323 million as at December 31, 2014 and 2015 respectively, with respect to the non-payment risk of the Hellenic Republic. The management of the Bank believes the probability of the respective contract on which the Group provides protection will default is remote. As at December 31, 2015, the fair value of the respective derivative liability amounted to EUR 2 million with a remaining time to maturity of around 24 years.

As at December 31, 2014 and 2015, "Other" under derivative assets includes a warrant instrument linked to Greek GDP that was received in the context of the PSI. The fair value of the respective instrument at December 31, 2014 and 2015, amounted to EUR 20 million and EUR 12 million and

corresponded to an outstanding notional amount of EUR 2.9 billion and EUR 3.0 billion respectively. The holders of the specific instrument are not entitled to receive principal whereas any payments, made on October 15 of every year, starting from 2015 with the final payment date in 2042, are contingent upon and determined on the basis of the performance of the GDP of the Hellenic Republic. Payments cannot exceed 1% of the notional held for any reference date.

Cash inflows and outflows related to derivative instruments are included in the cash flows from operating activities in the consolidated statement of cash flows for the years ended December 31, 2013, 2014, and 2015.

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 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, 2013, 2014 and 2015 amounted to a cumulative gain of EUR 28 million, EUR 79 million and EUR 201 million, respectively. The Group seeks to reduce counterparty risk by standardizing relationships with counterparties through 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 the 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, 2014 and at December 31, 2015, the Group held cash and securities collateral of EUR 750 million and EUR 518 million and posted cash and securities collateral of EUR 1,558 million and EUR 1,369 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, 2015, 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 at December 31, 2014 and 2015, amounted to EUR 15 million and EUR 14 million, respectively.

The amortized cost of available-for-sale securities and their fair values at December 31, comprised:

	2014

	Amortized Cost		Gross Unrealized Gains		Gross Unrealized (Losses)			Fair Value
	(EUR in millions)
Available-for-sale securities
Greek government bonds		802		46		(111	)		737
Debt securities issued by other governments and public sector entities		1,090		66		(1	)		1,155
Greek treasury bills		169		—		—			169
Foreign treasury bills		270		—		(1	)		269
Debt securities issued by companies incorporated in Greece		398		31		(27	)		402
Debt securities issued by companies incorporated outside Greece		319		15		(12	)		322
Equity securities issued by companies incorporated in Greece		35		9		(3	)		41
Equity securities issued by companies incorporated outside Greece		8		11		—			19
Mutual Fund units		205		5		(5	)		205

Total available-for-sale securities		3,296		183		(160	)		3,319

	2015

	Amortized Cost		Gross Unrealized Gains		Gross Unrealized (Losses)			Fair Value
	(EUR in millions)
Available-for-sale securities
Greek government bonds		746		92		(6	)		832
Debt securities issued by other governments and public sector entities		3,867		71		(7	)		3,931
Greek treasury bills		471		—		(1	)		470
Foreign treasury bills		229		—		—			229
Debt securities issued by companies incorporated in Greece		143		1		(5	)		139
Debt securities issued by companies incorporated outside Greece		219		11		(7	)		223
Equity securities issued by companies incorporated in Greece		57		8		(5	)		60
Equity securities issued by companies incorporated outside Greece		8		48		—			56
Mutual Fund units		280		10		(3	)		287

Total available-for-sale securities		6,020		241		(34	)		6,227

As at December 31, 2014 and 2015, the Group did not hold any US Federal debt securities.

Available for Sale Debt securities issued by other governments and public entities include EUR 2,706 million ESM bonds received from the HFSF in the context of the Bank's recapitalization completed in December 2015.The Bank is not allowed to sell these bonds, but the Bank is allowed to use them as collateral for repo financing from the Eurosystem or other market counterparties.

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, 2014. The table also discloses whether these securities have had unrealized losses for periods less than 12 months or for 12 months or longer.

	2014

	Less than 12 months					12 months or longer					Total
	Fair Value		Unrealized Losses			Fair Value		Unrealized Losses			Fair Value		Unrealized Losses
	(EUR in millions)
Available-for-sale securities in unrealized loss position
Greek government bonds		501		(111	)		—		—			501		(111	)
Debt securities issued by other governments and public sector entities		30		—			40		(1	)		70		(1	)
Foreign treasury bills		43		(1	)		—		—			43		(1	)
Debt securities issued by companies incorporated in Greece		72		(4	)		105		(23	)		177		(27	)
Debt securities issued by companies incorporated outside Greece		1		(2	)		105		(10	)		106		(12	)
Equity securities issued by companies incorporated in Greece		9		(3	)		2		—			11		(3	)
Mutual Fund units		66		(5	)		1		—			67		(5	)

Total available-for-sale securities		722		(126	)		253		(34	)		975		(160	)

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, 2015. 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, 2015

	Less than 12 months					12 months or longer					Total
	Fair Value		Unrealized Losses			Fair Value		Unrealized Losses			Fair Value		Unrealized Losses
	(EUR in millions)
Available-for-sale securities in unrealized loss position
Greek government bonds		—		—			108		(6	)		108		(6	)
Debt securities issued by other governments and public sector entities		38		(1	)		256		(6	)		294		(7	)
Greek treasury bills		411		(1	)		—		—			411		(1	)
Debt securities issued by companies incorporated in Greece		37		(1	)		77		(4	)		114		(5	)
Debt securities issued by companies incorporated outside Greece		1		—			33		(8	)		34		(7	)
Equity securities issued by companies incorporated in Greece		20		(4	)		—		—			20		(5	)
Mutual Fund units		73		(2	)		32		(1	)		105		(3	)

Total available-for-sale securities		580		(9	)		506		(25	)		1,086		(34	)

The scheduled maturities of available-for-sale securities at December 31, 2014 and 2015 were as follows:

Available for sale securities include securities that are pledged as collateral of EUR 570 million and EUR 3,349 million as at December 31, 2014 and 2015, respectively.

The following tables present the net gains / (losses) on available-for-sale securities and OTTI on available-for-sale and held-to-maturity securities for 2013, 2014 and 2015.

	2013

	(EUR in millions)
Gross realized gains on sales of available for sale securities
Greek government bonds		12		17		1
Debt securities issued by other governments and public sector entities		6		10		6
Corporate debt securities		109		15		9
Equity securities		57		30		6
Mutual fund units		49		39		6

Total gross realized gains on sales of available for sale securities		233		111		28

Gross realized losses on sales of available for sale securities
Greek government bonds		(3	)	(8	)	(12	)
Debt securities issued by other governments and public sector entities		(3	)	(3	)	(3	)
Corporate debt securities		(15	)	—		(2	)
Equity securities		(23	)	(3	)	(8	)
Mutual fund units		—		(1	)	(1	)

Total gross realized losses on sales of available for sale securities		(44	)	(15	)	(26	)

Net realized gains / (losses) on sales of available for sale securities		189		96		2



Other-Than-Temporary-Impairment
Corporate debt securities		(11	)	(1	)	(24	)
Equity securities		(275	)	(5	)	(8	)
Mutual fund units		—		—		(4	)

Total Other-Than-Temporary-Impairment		(286	)	(6	)	(36	)

Net gains / (losses) on available for sale and held to maturity securities		(97	)	90		(34	)

The amortized cost of held-to-maturity securities and their fair values at December 31, comprised:

Held-to-maturity Debt securities issued by other governments and public entities include EUR 9,060 million EFSF bonds received from the HFSF for the Bank's recapitalization in June 2013 and to cover the funding gap from the acquisition of FBB (see Note 4). As at December 31, 2015, the Bank was not allowed to sell these bonds, but the Bank is allowed to use them as collateral for repo financing from the Eurosystem or other market counterparties. Since April 14, 2016, the EFSF has allowed the Bank to sell the EFSF bonds to the members of the Eurosystem in the context of the Public Sector Asset Purchase Programme established by ECB Governing Council Decision 2015/774 on a secondary markets public sector asset purchase programme (the "PSPP") and strictly in accordance with the conditions applicable to the PSPP as amended by the ECB Governing Council decision of March 10, 2016, including but not limited to issue and issuer share limit applicable to EFSF. Following this decision by the EFSF on April 14, 2016 the Bank has decided to re-assess its intention to hold these bonds until maturity and concluded that these bonds do not meet the definition of Held to Maturity as the intention changed within 2016. The Bank, from April 14, 2016 until May 13, 2016, sold to members of the Eurosystem EFSF bonds of nominal amount EUR 915 million. As a result the Group's held-to-maturity portfolio will be tainted for 2016 and within that year any remaining held-to-maturity investments will be reclassified to available-for-sale portfolio.

As at December 31, 2014 and 2015, the Group did not hold any US Federal debt securities.

There are no unrecognized losses of held-to-maturity securities as at December 31, 2015 and 2014.

The scheduled maturities of held-to-maturity securities at December 31, 2014 and 2015 were as follows:

Held to maturity securities include securities that are pledged as collateral of EUR 8,891 million and EUR 9,060 million as at December 31, 2014 and 2015, 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.

Impairment of other debt securities, equity securities and mutual funds units

During 2013 the Group recognized OTTI charges of its equity securities held with significant and prolonged unrealized losses. In particular, the Group recognized OTTI charges for all equity securities for which an OTTI was recognized in previous periods and, as at December 31, 2013, were in an unrealized loss position. As at December 31, 2013, OTTI charges recognized for our investment in Eurobank were EUR 274 million.

For debt securities OTTI charges were recognised mainly in relation to all the bonds held that are issued by the Bank of Cyprus and Cyprus Popular Bank of to EUR 6 million because, as at December 31, 2013, the Group considered that a credit loss existed with respect to these securities due to the financial difficulties faced by the issuers.

With respect to corporate securities issued by companies incorporated in Greece the unrealized losses over one year of EUR 33 million relates to debt securities issued mainly by Greek banks. We consider that these banks will continue to pay in accordance with the contractual terms and as such an other-than-temporary-impairment was not considered necessary as at December 31, 2013. A key factor considered in this assessment was the successful completion of the share capital increases performed by Piraeus Bank and Alpha Bank in April, 2014 and of Eurobank in May, 2014.

With respect to corporate securities issued by companies incorporated outside Greece the unrealized losses over one year of EUR 17 million relates to debt securities issued mainly by major European and American banks and insurance companies. We consider that these banks and insurance companies will continue to pay in accordance with the contractual terms and as such an other-than-temporary-impairment was not considered necessary as at December 31, 2013.

During 2014 the Group recognized OTTI charges of its equity securities held with significant and prolonged unrealized losses. In particular, the Group recognized OTTI charges of EUR 5 million for all equity securities for which an OTTI was recognized in previous periods and, as at December 31, 2014, were in an unrealized loss position.

For corporate debt securities OTTI charges of EUR 1 million were recognised in relation to a security, for which the Group considered that a credit loss existed, with respect to such security, due to the financial difficulties faced by the issuer.

With respect to the unrealized losses of EUR 111 million for less than a year on Greek government bonds, we did not recognize any OTTI because we have concluded that the unrealized or unrecognized losses are not other-than-temporary. To arrive at this conclusion the Group considered that it neither intends nor expects it will be required to sell these securities before the recovery of their amortized cost basis, and no credit loss event has occurred, as evidenced by the fact that the issuer is meeting the contractual obligations to the IMF and other debtors.

With respect to corporate securities issued by companies incorporated in Greece the unrealized losses over one year of EUR 23 million relate to debt securities issued mainly by Greek banks. We consider that these banks will continue to pay in accordance with the contractual terms, the unrealized losses have decreased compared to December 31, 2013 and as such an other-than-temporary-impairment was not considered necessary as at December 31, 2014. A key factor considered in this assessment was the successful completion of the share capital increases performed by Piraeus Bank and Alpha Bank in April, 2014 and of Eurobank in May, 2014.

With respect to corporate securities issued by companies incorporated outside Greece the unrealized losses over one year of EUR 11 million relate to debt securities issued mainly by major European and American banks and insurance companies. We consider that these banks and insurance companies will continue to pay in accordance with the contractual terms and as such an other-than-temporary-impairment was not considered necessary as at December 31, 2014.

During 2015 the Group recognized OTTI charges for Greek government bonds of EUR 23 million, that were in an unrealized loss position as at December 31, 2015 and the Group sold a portion of these bonds after year end. With regards to remaining unrealized losses of EUR 6 million for over one year on Greek government securities, OTTI charges were not recognized because the Group has neither the intention nor it expects to sell the securities before the recovery of their amortized cost basis and the issuer is continuing to meet its contractual obligations.

For equity securities and mutual funds securities with significant and prolonged unrealized losses or with an OTTI recognized in previous periods and, as at December 31, 2015, were in an unrealized loss position, the Group recognized OTTI charges of EUR 8 and 4 million respectively.

With regards to debt securities issued by other governments and public entities the unrealized losses for over one year of EUR 6 million relate to debt securities issued by Bulgarian Government, held by our subsidiary in Bulgaria. We consider the unrealized losses insignificant as they represent on average only 2.3% of the amortized cost basis, and that Bulgarian Government will continue to pay in accordance with the contractual terms, and as such on other-than-temporary-impairment was not considered necessary as at December 31, 2015

With regards to corporate debt securities issued by companies incorporated outside Greece the unrealized losses for over one year of EUR 8 million relate mainly to debt securities issued by large foreign financial institutions for which we consider that they will continue to pay in accordance with the contractual terms. Furthermore, the Group has no intention nor it expects to sell these securities before we recover our investment and therefore an other-than-temporary-impairment was not considered necessary.

With regards to debt securities issued by companies incorporated in Greece the unrealized losses for over one year of EUR 4 million relate to large Greek corporates for which we have concluded that the unrecognized losses are not other-than-temporary. To arrive at this conclusion the Group considered it neither intends nor it expects to sell these securities before the recovery of their amortized cost basis and that the issuers will continue to meet their obligations in accordance with the contractual terms of the securities.

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.

On January 4, 2016 the Group completed the disposal of the 60% shareholding in UBB AIG Insurance Company A.D. to Bulstrad A.D. for the amount of EUR 2 million.

Loans granted by the Group according to type of loan, which represents the Group's concentration of credit risk, at December 31, 2014 and 2015 comprised:

	2014									2015

	Greek residents			Foreign			Total			Greek residents			Foreign			Total
	(EUR in millions)
Consumer:
Residential mortgages		17,458			1,631			19,089			16,664			1,593			18,257
Credit card		1,317			162			1,479			1,244			157			1,401
Auto financing		88			23			111			64			21			85
Other consumer		4,207			1,299			5,506			4,095			1,309			5,404

Total consumer		23,070			3,115			26,185			22,067			3,080			25,147

Commercial:
Industry and mining		5,217			758			5,975			5,564			783			6,347
Small scale industry		1,929			377			2,306			1,765			413			2,178
Trade		7,425			1,015			8,440			7,559			927			8,486
Construction		1,098			1,079			2,177			1,061			985			2,046
Tourism		607			128			735			451			144			595
Shipping and transportation		2,437			312			2,749			2,556			270			2,826
Commercial mortgages		529			228			757			759			212			971
Public sector		5,390			174			5,564			5,218			106			5,324
Other		600			665			1,265			574			601			1,175

Total commercial		25,232			4,736			29,968			25,507			4,441			29,948

Total loans		48,302			7,851			56,153			47,574			7,521			55,095
Unearned income		(67	)		(18	)		(85	)		(80	)		(19	)		(99	)

Loans, net of unearned income		48,235			7,833			56,068			47,494			7,502			54,996
Less: Allowance for loan losses		(7,788	)		(1,004	)		(8,792	)		(10,799	)		(976	)		(11,775	)

Net Loans		40,447			6,829			47,276			36,695			6,526			43,221

Included in the above table are loans for lease financing amounting to EUR 995 million and EUR 941 million in 2014 and 2015 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, 2014 and 2015:

	December 31, 2014

											Of which:
	Past due 31-90 days		Past due greater than 90 days		Total Past due loans		Current loans⁽¹⁾		Total		+90 days and accruing loans		Non accruing loans
	EUR in millions
Greek
Residential mortgages		779		5,227		6,006		11,452		17,458		257		6,346
Credit card		27		728		755		562		1,317		8		720
Other consumer		163		2,289		2,452		1,843		4,295		—		2,638
Small business loans		65		2,183		2,248		1,719		3,967		—		2,491
Other commercial loans		277		3,619		3,896		17,369		21,265		40		4,410

Total Greek loans		1,311		14,046		15,357		32,945		48,302		305		16,605



Foreign
Residential mortgages		91		206		297		1,334		1,631		2		242
Credit card		2		18		20		142		162		—		18
Other consumer		42		241		283		1,040		1,323		—		262
Small business loans		30		448		478		624		1,102		—		475
Other commercial loans		107		1,009		1,116		2,517		3,633		—		1,229

Total Foreign loans		272		1,922		2,194		5,657		7,851		2		2,226



Total loans		1,583		15,968		17,551		38,602		56,153		307		18,831

	December 31, 2015

											Of which:
	Past due 31-90 days		Past due greater than 90 days		Total Past due loans		Current loans⁽¹⁾		Total		+90 days and accruing loans		Non accruing loans
	EUR in millions
Greek
Residential mortgages		618		5,444		6,062		10,602		16,664		159		8,246
Credit card		20		705		725		519		1,243		50		655
Other consumer		121		2,425		2,546		1,613		4,159		—		3,172
Small business loans		46		2,368		2,414		1,443		3,857		—		2,623
Other commercial loans		910		4,117		5,027		16,623		21,651		34		4,951

Total Greek loans		1,715		15,059		16,774		30,800		47,574		243		19,647



Foreign
Residential mortgages		77		188		265		1,328		1,593		—		270
Credit card		2		15		17		140		157		—		15
Other consumer		42		203		245		1,085		1,330		1		274
Small business loans		35		537		572		821		1,393		—		675
Other commercial loans		65		829		894		2,154		3,048		1		971

Total Foreign loans		221		1,772		1,993		5,528		7,521		2		2,205



Total loans		1,936		16,831		18,767		36,328		55,095		245		21,852

According to the Group's credit policy, all corporate customers are rated on a 21 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 have already defaulted.

The following table presents commercial loans credit quality information as at December 31, 2014 and 2015:

	December 31, 2014						December 31, 2015

	Small business loans		Other commercial loans		Total commercial loans		Small business loans		Other commercial loans		Total commercial loans
	(EUR in millions)						(EUR in millions)
Greek
Satisfactory		573		7,555		8,128		659		12,884		13,543
Watchlist		382		9,777		10,159		837		4,269		5,106
Substandard		3,013		3,932		6,945		2,361		4,497		6,858

		3,968		21,264		25,232		3,857		21,650		25,507

Foreign
Satisfactory		603		2,422		3,025		826		1,793		2,619
Watchlist		181		539		720		101		598		699
Substandard		318		673		991		466		657		1,123

		1,102		3,634		4,736		1,393		3,048		4,441

Total		5,070		24,898		29,968		5,250		24,698		29,948

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 also include loans whose terms have been modified in troubled debt restructuring.

The following table presents information about total impaired loans at and for the years ended December 31, 2014 and 2015:

	At and for the year ended December 31, 2014

	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 millions)
Greek
With no related allowance:
Residential mortgages		603		—			467		6		6
Other consumer loans		226		—			239		9		9
Small business loans		214		—			140		1		1
Other commercial loans		403		—			557		4		4
With related allowance:
Residential mortgages		6,709		(1,238	)		6,775		34		30
Credit cards		729		(644	)		703		—		—
Other consumer loans		2,665		(1,942	)		2,771		24		23
Small business loans		2,411		(1,413	)		2,403		21		7
Other commercial loans		4,705		(2,413	)		3,769		81		33

Total Greek impaired loans		18,665		(7,650	)		17,824		180		113

Foreign
With no related allowance:
Residential mortgages		3		—			7		—		—
Credit cards		3		—			3		—		—
Other consumer loans		24		—			24		—		—
Small business loans		1		—			1		—		—
Other commercial loans		151		—			162		4		—
With related allowance:
Residential mortgages		355		(78	)		363		7		—
Credit cards		18		(15	)		18		—		—
Other consumer loans		258		(182	)		313		36		—
Small business loans		534		(238	)		416		17		—
Other commercial loans		1,228		(457	)		1,366		10		1

Total Foreign impaired loans		2,575		(970	)		2,673		74		1

	At and for the year ended December 31, 2015

	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 millions)
Greek
With no related allowance:
Residential mortgages		1,553		—			1,078		24		24
Other consumer loans		368		—			298		13		13
Small business loans		171		—			192		2		2
Other commercial loans		422		—			412		6		6
With related allowance:
Residential mortgages		7,384		(1,869	)		7,046		95		84
Credit cards		705		(673	)		717		—		—
Other consumer loans		2,774		(2,243	)		2,719		68		59
Small business loans		2,532		(1,675	)		2,439		15		10
Other commercial loans		6,447		(4,111	)		5,366		111		68

Total Greek impaired loans		22,356		(10,571	)		20,267		334		266

Foreign
With no related allowance:
Residential mortgages		2		—			3		—		—
Credit cards		3		—			3		—		—
Other consumer loans		25		—			25		—		—
Other commercial loans		65		—			79		—		—
With related allowance:
Residential mortgages		350		(70	)		327		15		—
Credit cards		12		(13	)		14		—		—
Other consumer loans		272		(162	)		213		15		1
Small business loans		686		(282	)		607		19		—
Other commercial loans		1,090		(446	)		1,045		2		1

Total Foreign impaired loans		2,505		(973	)		2,316		51		2

The following table presents the roll-forward of impaired loans for the years ended, December 31, 2014 and 2015:

PCI loans are acquired loans with evidence of credit quality deterioration since origination for which it is probable at purchase date that NBG will be unable to collect all contractually required payments. The following table provides details on PCI loans acquired in connection with the May 10, 2013 and July 26, 2013 acquisition of FBB and Probank respectively (see Note 4).

The table below shows activity for the accretable yield on PCI loans, which includes the FBB and Probank portfolio.

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 a modification of terms such as the modification of the stated interest, or reduction of principal of the loan, or reduction of interest accrued off-balance sheet or the extension of maturity at stated interest rate lower than the current market rate for a new loan with similar risk.

TDR balances presented in the disclosures "financing receivables modified as troubled debt restructuring during the period" and "troubled debt restructuring by modification programs" for 2015 have increased in comparison to 2014, as a consequence of the deterioration of the quality of our portfolio due to the worse than anticipated trend in the Greek economy, the increased political uncertainty and the increased efforts made by the Bank to propose new and more efficient restructuring products to its customers.

During 2014, the Group revised its estimates regarding the triggers used to determine whether an exposure is TDR. More specifically, the Group updated the criteria applied in order to estimate if a borrower is in financial difficulty or not, taking into consideration the credit quality indicators of its loans' portfolio i.e. the delinquency status of its consumer segment and the delinquency status and credit rating for its commercial segment.

Forbearance programs applied in the consumer loan portfolio (mortgages, consumer credit, credit cards) mainly comprise of extension of the loan term combined with a reduction of the installment either through fractional payment scheme, whereby the customer pays a proportion, ranging from 10% to 70%, of the installment due for the first years of the forbearance, or through an interest only payment period of a maximum of 24 months. Those programs also offer a reduction of the off balance sheet interest accounted for.

Specifically, for consumer loans the interest rate on the new loan may be reduced and/or the duration may be extended if the customers are willing and able to secure their consumer loan and credit card debt with real estate property or provide an additional down payment.

For SBL customers, the restructuring product generally includes the granting of a grace period of up to 24 months during which the customer pays only interest, the extension of the maturity of the loan up to 20 years and the option to the customer to make a down payment, which if the loan is repaid in accordance with the renegotiated terms will be returned as a discount or the application of lower interest rate in case the customer provides new collaterals. In addition, restructuring over restructuring ("R-O-R") programs are addressed to those customers having difficulty in servicing their restructured loans.

Troubled debt restructuring programs are also offered to corporate customers who have been affected by the current market conditions. The types of modification are usually a mix of new amortization schedule tailored to current conditions and the customer's projected cash flow, the extension or not of tenor, depending on the customer and its needs, as well as shift from short-term to long-term financing.

TDRs are considered impaired loans. TDRs are separately monitored and assessed within each portfolio for the purposes of allowance for loan loss calculation. Allowance for loan loss is calculated based on a present value of expected future cash flows discounted using the original effective interest rate of the loan considering all available evidence at the time of the assessment. At the time of the restructuring, the loans are remeasured to reflect the impact, if any, on projected cash flows or collateral value resulting from the modified terms. If there was no principal forgiveness or the interest rate was increased, the modification may have a little impact or no impact on the allowance for loan loss. If a portion of the loans is deemed uncollectible, an allowance for loan loss is recorded at the time of restructuring or may have been already recorded in a previous period.

Typically, allowance for loan loss for TDR Consumer loans is calculated using the average of yearly default frequencies of those specific products. Upon restructuring if several customer's loans are consolidated into a single loan, then the aggregate loan balance, which may also include loans previously accruing, is assessed for impairment. In addition, restructured loans under Greek Law 3869/2010 are considered TDRs and are pooled into a separate group when calculating allowance for loan losses.

Allowance for loan loss for TDR Commercial loans is usually calculated on an individual basis for customers with significant exposures based on the present value of expected cash flows discounted at the loan's original effective interest rate, or based on the fair value of the collateral, less costs to sell, if those are collateral dependent loans. For TDR Commercial customers that do not satisfy the quantified criterion for individual assessment (that is, the individually non-significant customers), allowance for loan loss is calculated through our coefficient or homogeneous analysis using the probability of default corresponding to their internal credit rating.

The trends of re-default are closely monitored and analyzed in order to identify the drivers for the re-defaults. In addition, trends of re-default are considered when calculating the appropriate level of the allowance for loan loss by adjusting the probabilities of default relating to both Consumer and Commercial TDR loans.

The following table discloses financing receivables modified as troubled debt restructurings during the reporting period ended December 31, 2013, 2014 and 2015.

The following table discloses financing receivables modified in a TDR which became delinquent thirty days or greater during the reporting period and for which payment default occurred within 12 months after the modification.

The Group offers a number of modifications to customers. The modification programs that the Group offers its customers can generally be described in the following categories:

Payment modification—A modification in which the principal and interest payment are lowered from the original contractual terms.

Term modification—A modification which changes the maturity date, timing of payments or frequency of payments.

Interest only modification—A modification in which the loan is converted to interest only payments for a period of time.

Combination modification—Any other type of modification, including the use of multiple categories above.

The following table discloses financing receivables modified as troubled debt restructurings by modification programs as at December 31, 2013, 2014 and 2015.

The following table discloses the ageing of financing receivables modified as troubled debt restructurings at December 31, 2013, 2014 and 2015.

An analysis of the change in the allowance for loan losses by portfolio segment for the years ended December 31, follows:

	2013									2014									2015

	Consumer			Commercial			Total			Consumer			Commercial			Total			Consumer			Commercial			Total
	(EUR in millions)
Balance at beginning of year		3,158			3,492			6,650			3,599			3,539			7,138			4,199			4,593			8,792
Provision for loan losses		485			148			633			640			1,195			1,835			1,042			2,256			3,298
Write-offs		(58	)		(114	)		(172	)		(49	)		(96	)		(145	)		(109	)		(217	)		(326	)
Recoveries		14			20			34			8			1			9			9			—			9

Net Write-offs		(44	)		(94	)		(138	)		(41	)		(95	)		(136	)		(100	)		(217	)		(317	)
Sale of impaired loans		—			—			—			—			(25	)		(25	)		—			—			—
Translation differences		—			(7	)		(7	)		1			(21	)		(20	)		(4	)		6			2

Allowance at end of year		3,599			3,539			7,138			4,199			4,593			8,792			5,137			6,638			11,775

The Group's exposure to the Hellenic Republic comprises of a loan granted to the Hellenic Republic, loans to Hellenic public sector entities, loans guaranteed by the Hellenic Republic and loans to corporate and individuals guaranteed by the Hellenic Republic.

Exposure to the Hellenic Republic and its related allowance at December 31,2014, and 2015 are as follows:

With regards to the above exposure the Group has consistently applied its provisioning policy and has recognized allowance for loan losses, where deemed appropriate. As at December 31, 2015, the Group considered (a) the fact that no specific loss event in relation to the Hellenic Republic had occurred, (b) the fact that Hellenic Republic serviced the aforementioned exposures, and concluded that the exposure to Hellenic Republic did not qualify for impairment assessment.

The following table provides the allowance for loan losses by portfolio segment and the respective recorded investment at December 31, 2014.

The following table provides the allowance for loan losses by portfolio segment and the respective recorded investment at December 31, 2015.

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, 2015, 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 2015 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 on recoveries 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 the allowance for loan losses based on homogeneous analysis.

As at December 31, 2015, 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, 2015 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, 2015, the worse than anticipated trends and the political uncertainty, were reflected in our allowance for loan losses estimated as of December 31, 2015, 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, 2015, 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 since 2010, 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 would be improved. However, the loans originated during 2014 and 2015 were not significant enough to cause a change in observed probabilities of default or loss given defaults.

'The following tables set forth the allowances for loan losses by portfolio segment and by impairment methodology and the respective recorded investment as at December 31, 2014 and December 31, 2015

The most common practice we use to mitigate credit risk is requiring collateral for loans originated. We implement guidelines on the acceptability of specific classes of collateral. The principal collateral types for loans 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.

Impaired loans net of allowance for loan losses include collateral dependent loans of EUR 1,281 million and EUR 732 million at December 31, 2014 and December 31, 2015, respectively. In general, a loan is classified as collateral dependent when repayment is expected to be provided solely by the underlying collateral and the Group anticipates foreclosing on the loan and as a result the impairment is measured based on the fair value of the collateral. 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 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 a qualified appraiser, unless loan exposures are significantly lower than the collateral values.

Loans include securitized loans and loans used as collateral in the Covered Bond Programmes, as follows:

During the current period the Group identified that the amount of Receivables from Public Sector (Titlos Plc-February 2009) for the year ended December 31, 2014 inadvertently included an amount not relating to the securitization. The amount was originally reported at EUR 6,579 million, but it has been restated to reflect correction of the error. This error only affects the specific item in the above table and does not have an impact on the balance sheet, income statement or retained earnings.

The Bank, through its VIEs, has the following securitized notes in issue as at December 31, 2015:

Issuer	Description	Type of collateral	Issue date	Maturity date		Interest rate

Titlos Plc⁽²⁾	Variable Rate Asset Backed Notes	Receivables from Public sector	February 26, 2009	September 2039	5,100	Paid semi-annually at a rate of six-month Euribor plus 50 bps
Spiti Plc^(1),(3)	Asset Backed Variable Rate Notes—Class A	Residential mortgages	September 20, 2011	September 2058	1,500	Paid semi-annually at a rate of six-month Euribor plus a margin of 200 bps
Spiti Plc^(1),(3)	Asset Backed Variable Rate Notes—Class B	Residential mortgages	September 20, 2011	September 2058	250	Paid semi-annually at a rate of six-month Euribor plus a margin of 400 bps
Autokinito Plc^(1),(3)	Asset Backed Variable Rate Notes—Class A	Auto loans	September 23, 2011	September 2023	400	Paid semi-annually at a rate of six-month Euribor plus a margin of 200 bps
Autokinito Plc^(1),(3)	Asset Backed Variable Rate Notes—Class B	Auto loans	September 23, 2011	September 2023	97	Paid semi-annually at a rate of six-month Euribor plus a margin of 350 bps
Agorazo Plc^(1),(4)	Asset Backed Variable Rate Notes—Class A	Consumer loans	September 23, 2011	September 2033	1,250	Paid semi-annually at a rate of six month Euribor plus a margin of 300 bps
Agorazo Plc^(1),(4)	Asset Backed Variable Rate Notes—Class B	Consumer loans	September 23, 2011	September 2033	413	Paid semi-annually at a rate of six-month Euribor plus a margin of 450 bps

(1): The Bank retains the option to call the notes on any interest payment date and issue new notes, or sell them as is to investors.
(2): The Bank retains the option to call the notes on any re-novation date or on any optional redemption date and issue new notes or sell them to investors. The outstanding balance of Titlos Plc as at December 31, 2015 is EUR 4,418 million and has been rated Caa3 by Moody's.
(3): On March 20, 2015, Spiti Plc proceeded with the partial redemption of class A notes of EUR 81 million. Autokinito Plc proceeded with the full redemption of class A notes of EUR 1 million and the partial redemption of class B notes of EUR 28 million. On September 21 2015, Spiti Plc and Autokinito Plc proceeded with the partial redemption of class A notes of EUR 70 million and class B notes of EUR 20 million, respectively. The outstanding amounts of Spiti Plc and Autokinito Plc as at December 31, 2015 are EUR 854 million and EUR 49 million respectively.
(4): Agorazo Plc proceeded with the partial redemption of class A notes of EUR 89 million on March 16, 2015 and EUR 65 million on September 15, 2015. The outstanding amount of Agorazo Plc as at December 31, 2015 amounts to EUR 392 million.

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.

All of the above notes issued are 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 Programmes I and II, the Bank has the following covered bonds series in issue as at December 31, 2015:

Other than the Series 3 of Programme I, all the above covered bonds have not been sold to investors and are held by the Bank and therefore are not presented within "Long-term debt" (see Note 24).

Furthermore, the Bank, in 2015, has cancelled the following covered bonds issued under Programme II:

The change in International relates to impairment of EUR 105 million in relation to UBB. Furthermore, additional impairment of goodwill of EUR 104 million has been recorded in relation to the Private Equity Funds which was reclassified as held for sale (see Note 17).

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 unit where significant goodwill was allocated prior to our impairment test at December 31, 2015 was the International operations and the goodwill relates to the acquisition of UBB.

As at December 31, 2015, the Group concluded that there were indicators of potential impairment of the goodwill recognized on the Group's investment in UBB, as a result of the Bank's Restructuring Plan approved by the Directorate General for Competition on 4 December 2015, which includes a commitment for divestment from international operations, including Bulgaria. Based on our analysis performed, as of December 31, 2015, it was determined that the carrying value of the Group's investment in UBB including goodwill exceeded the fair value of the investment, requiring the Group to perform Step 2 of the goodwill impairment test, to measure the amount of impairment loss, if any. In performing Step 2 of the goodwill impairment test, the Group compared the implied fair value of goodwill recognized on the Group's investment in UBB to its carrying value of goodwill. For the determination of the fair value of the Group's investment in UBB, a valuation technique consistent with the market approach was applied with market multiples (i.e. Price to Tangible Book Value and Price to Earnings) from a set of comparable listed Central Eastern European financial institutions. The fair value assessed from the market multiples was then adjusted with other significant unobservable factors (i.e. control premium and marketability discount) and is categorized in Level 3 of the fair value hierarchy. This test resulted in the write-off of goodwill and an impairment loss of EUR 105 million was recognized in the income statement, within "Other non-interest expense" line item.

The gross carrying amount and accumulated amortization relating to software and other intangibles at December 31 are presented below:

As at December 31, 2015, intangibles identified upon the acquisition of acquired entities were fully impaired. The corresponding amounts as at December 31, 2014 amounted to EUR 13 million and consisted of core deposits of EUR 3 million customer relationships of EUR 2 million and trade names of EUR 8 million.

Amortization expense on software and other intangibles amounted to EUR 58 million, EUR 53 million and EUR 59 million in 2013, 2014 and 2015 respectively. The Group estimates that aggregate amortization expense for the five succeeding fiscal years will be EUR 46 million, EUR 35 million, EUR 23 million, EUR 16 million and EUR 16 million for years 2016 through 2020 respectively.

Certain Group premises and equipment are leased under various operating leases. Rental expense amounted to EUR 57 million, EUR 53 million and EUR 52 million for the years ended December 31, 2013, 2014 and 2015, respectively.

Future minimum lease commitments under non-cancellable operating leases are presented below. The Group did not enter into any material capital leases.

	2014

	Restated⁽²⁾
	(EUR in millions)
Insurance related assets		516	597
Deferred tax assets		189	198
Prepaid income taxes		537	588
Assets acquired through foreclosure proceedings		194	165
Brokerage auxiliary funds		23	3
Private equity: Investees Assets⁽¹⁾		116	—
Prepaid expenses		52	56
Advances to employees		18	8
Unlisted equity securities		86	32
Hellenic Deposit and Investment Guarantee Fund		469	478
Receivables from Greek State		511	521
Checks and credit card transactions under settlement		19	21
Trade and other receivables		70	134
Other		388	216

Total		3,188	3,017

Included in the above table are investments on behalf of policyholders who bear the investment risk, classified as Insurance related assets amounting to EUR 316 million and EUR 307 million at December 31, 2014 and 2015 respectively, which are carried at fair value.

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 is 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 is jointly owned by the credit institutions in proportion to their participation.

In accordance with article 13A of Law 3746/16.2.2009, all financial institutions participating in HDIGF's Resolution Section are liable for contributions at a rate of 0.09% calculated on their June average balance of total liabilities. In case that a financial institution is considered as not viable by the BoG, may decide that the institution's assets and liabilities to be transferred to a transferee institution. Following such decision, HDIGF's Resolution Section will cover any funding gap from the said transfer.

NOTE 17: DISCONTINUED OPERATIONS AND LONG-LIVED ASSETS HELD FOR SALE AND LIABILITIES DIRECTLY ASSOCIATED WITH LONG-LIVED ASSETS HELD FOR SALE

Long lived assets held for sale and liabilities directly associated with long lived assets held for sale at December 31, 2015 comprise, Finansbank A.S., the NBGI Private Equity Funds and Astir Palace Vouliagmenis S.A and Astir Marina Vouliagmenis S.A.

On November 3, 2015, the Bank's Board of Directors approved the plan to proceed with the disposal of its entire stake in Finansbank (the "Finansbank Transaction"). On December 21, 2015, the Bank's Board of Directors approved the sale to Qatar National Bank ("QNB") of NBG Group's 99.81% stake in Finansbank A.S. together with NBG's 29.87% direct stake in Finans Leasing. Furthermore, on January 18, 2016, the Extraordinary General Meeting of the Bank approved the transaction, which is also in line with the relevant commitment included in the Revised Restructuring Plan. The transaction was approved on March 3, 2016 by the Qatar Central Bank and on April 7, 2016 by BRSA. The agreed consideration for the transaction amounts to EUR 2,750 million. In addition, QNB will repay upon closing the USD 910 million of subordinated debt that NBG has extended to Finansbank. The disposal is consistent with the Group's capital action plan to address the capital shortfalls identified by the 2015 Comprehensive Assessment carried out by the ECB and satisfies the relevant commitment in the Revised Restructuring Plan. The closing of the transaction is subject to customary regulatory and corporate approvals and is expected within the first semester of 2016. As a result, the investment in Finansbank qualifies to be classified as a disposal group held for sale on November 3, 2015. Furthermore, Finansbank meets the definition of a discontinued operation because in accordance with ASC 205-20 "Discontinued Operations" represents a strategic shift that has a major effect on the Group's operations and financial results.

Following the decision to dispose its entire stake in Finansbank, the Group, based on the agreed consideration, measured the assets and liabilities of the discontinued operation at the lower of carrying value or fair value less cost to sell and recognized an impairment loss of EUR 5,478 million during the period ended December 31, 2015 of which EUR 1,763 million related to the goodwill and EUR 96 million to intangibles recognized in the Group's consolidated financial statements. For the remaining amount of EUR 3,619 million, a valuation allowance was recorded against long-lived assets held for sale. The carrying amount of the Group's investment in Finansbank for impairment measurement purposes, included the cumulative translation loss adjustment of EUR 2,930 million, as required by ASC 830-30-45-13 through 45-15. Once the investment is sold, the cumulative translation loss adjustment will be derecognized from AOCI, thus increasing equity by EUR 2,930 million with no impact in the income statement.

Goodwill relates to the acquisition of Finansbank and is tested for impairment annually, at December 31. In 2014, in Step 1 of the goodwill impairment test the fair value of the above reporting unit was estimated using the income approach and in particular the Dividend Discount Model ("DDM"). 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. For the Turkish banking operations reporting unit the DDM was based on a 6.2% terminal growth rate and 16.6% pretax discount rate.

Based on the results of Step 1 of the impairment test, the Group determined that the fair value of the Turkish banking operations reporting unit exceeded the carrying amount by EUR 0.2 billion. The

NOTE 17: DISCONTINUED OPERATIONS AND LONG-LIVED ASSETS HELD FOR SALE AND LIABILITIES DIRECTLY ASSOCIATED WITH LONG-LIVED ASSETS HELD FOR SALE (Continued)

result of the DDM was corroborated with other valuation methods, such as book value, market and transaction multiples. Based on these multiples, the implied value of the Turkish banking operations reporting unit, approximates the value derived from the DDM. A 1% increase in the pre tax discount rate or a 1% decrease in the terminal growth rate would decrease the fair value by EUR 0.2 billion and EUR 0.2 billion respectively. In addition, a 5% decrease in the forecast amounts available for dividends would decrease the fair value by EUR 0.2 billion.

On December 21, 2015, the Bank's Board of Directors approved the plan to proceed with the disposal of its entire stake in eleven Limited Partnerships ("the Private Equity Funds") located in UK and held directly or indirectly by NBG and managed by NBGI PE Limited. On February 2, 2016 the Bank entered into a definitive agreement to sell the 100% of its interests in the Private Equity Funds to funds managed by Deutsche Bank Private Equity and Goldman Sachs Asset Management. The agreed consideration for the transaction amounts to EUR 288 million. The disposal is consistent with the Group's capital action plan to address the capital shortfalls identified by the 2015 Comprehensive Assessment carried out by the ECB and satisfies the relevant commitment in the Revised Restructuring Plan. Closing of the transaction is expected within the first semester of 2016, subject to the approval from the Financial Conduct Authority, and antitrust authorities. As a result, the investment in the Private Equity Funds qualifies to be classified as held for sale on December 21, 2015 in accordance with ASC 360-10-45-11 "Long-Lived Assets Classified as Held for Sale", as the requirements and conditions specified by the Standard are met.

Following the decision to dispose its entire stake to the Private Equity Funds, the Group, based on the agreed consideration, measured the assets and liabilities of the Funds at the lower of carrying value of fair value less cost to sell and recognized an impairment loss of EUR 104 million during the period ended December 31, 2015.

On February 10, 2014 Jermyn Street Real Estate Fund IV L.P. ("JERMYN") was nominated as Preferred Investor pursuant to the international open competitive process for the acquisition of a majority of the share capital of Astir Palace Vouliagmenis S.A. Further to the transaction approval by the Council of Audit on June 5, 2014 the Sale and Purchase Agreement (the "Astir SPA") was executed on 17 September, 2014 between NBG, the Hellenic Republic Asset Development Fund S.A. ('HRADF') in their capacity as sellers, Apollo Investment Hold Co in its capacity as the buyer, and JERMYN in its capacity as Guarantor. Apollo Investment Hold Co is an SPV, 100.00% owned by JERMYN. The transaction is intended to close following the fulfillment of relevant conditions precedent. These include, among others, the issuance and publication of the applicable Special Public Real Estate Area Development Plan (the "Plan") in the Government Gazette. In March 2015, the Council of State reached a negative decision regarding the submitted Plan. Following these developments NBG, HRADF and the Preferred Investor initiated consultations within the context of existing competitive process, applying the relevant provisions of the Astir SPA. The relevant Consultation Period (as per the current Astir SPA terms) began on May 11, 2015 and was extended to December 31, 2015 in agreement with the Preferred Investor. The consultations between the Parties

NOTE 17: DISCONTINUED OPERATIONS AND LONG-LIVED ASSETS HELD FOR SALE AND LIABILITIES DIRECTLY ASSOCIATED WITH LONG-LIVED ASSETS HELD FOR SALE (Continued)

resulted in an agreement which was included in an Addendum to the Astir SPA dated December 31, 2015 by means of which the original plan is substituted by a new draft Special Public Real Estate Area Development. Given that the delay is caused by events and circumstances beyond NBG's control and that NBG remains committed to its plan to sell the subsidiary, the assets and liabilities of Astir Palace Vouliagmenis S.A. and Astir Marina Vouliagmenis S.A. (an 100.00% subsidiary of Astir Palace Vouliagmenis S.A.) continue to be presented as non-current assets held for sale in accordance with ASC 360-10-45-11 "Long-Lived Assets Classified as Held for Sale", as the requirements and conditions specified by the Standard are met.

NOTE 17: DISCONTINUED OPERATIONS AND LONG-LIVED ASSETS HELD FOR SALE AND LIABILITIES DIRECTLY ASSOCIATED WITH LONG-LIVED ASSETS HELD FOR SALE (Continued)

Discontinued operations, long-lived assets held for sale and the liabilities directly associated with long-lived assets at December 31, comprised:

	As of December 31,

	2014			2015
	(EUR in millions)
ASSETS
Cash and due from banks		620			684
Deposits with Central Bank		2,518			2,528
Securities purchased under agreements to resell		71			—
Interest bearing deposits with banks		66			93
Trading assets		19			26
Derivative assets		1,146			1,723
Available-for-sale securities		1,884			1,675
Held-to-maturity securities		1,307			1,210
Equity method investments		80			35
Loans		18,840			19,441
Less: Allowance for loan losses		(700	)		(960	)

Net loans		18,140			18,481
Goodwill		1,981			—
Software and other intangibles		190			86
Premises and equipment		505			485
Accrued interest receivable		291			314
Other assets		350			345
Valuation allowance related to assets of the discontinued operations		—			(3,619	)

Total assets of the discontinued operations		29,168			24,066

Total assets of disposal groups classified as held for sale		118			693

TOTAL ASSETS		29,286			24,759



LIABILITIES AND SHAREHOLDERS' EQUITY
Interest bearing deposits		13,342			13,829
Non-interest bearing deposits		2,064			2,370

Total deposits		15,406			16,199
Securities sold under agreements to repurchase		1,467			1,464
Derivative liabilities		564			768
Other borrowed funds		2,303			972
Accounts payable, accrued expenses and other liabilities		1,273			1,234
Long-term debt		1,699			2,718

Total liabilities of the discontinued operations		22,712			23,355

Total liabilities of disposal groups classified as held for sale		7			295

Total liabilities		22,719			23,650

NOTE 17: DISCONTINUED OPERATIONS AND LONG-LIVED ASSETS HELD FOR SALE AND LIABILITIES DIRECTLY ASSOCIATED WITH LONG-LIVED ASSETS HELD FOR SALE (Continued)

	Year ended December 31,

	2013			2014			2015
	(EUR in millions)
Net interest income before provision for loan losses		1,393			1,226			1,421
Provision for loan losses		(336	)		(337	)		(391	)
Net interest income/(loss) after provision for loan losses		1,057			889			1,030
Total non-interest income / (loss) excluding gains / (losses) on investment securities		604			151			283
Net realized gains/(losses) on sales of available-for-sale securities		62			4			9
Net gains / (losses) on available for sale and held to maturity securities		62			4			9
Total non-interest income / (loss)		666			155			292
Total non-interest expense		(928	)		(825	)		(907	)
Income / (loss) before income tax		795			219			415
Income tax expense		(147	)		(50	)		(60	)
Net Income / (loss) from discontinuing operations before impairments		648			169			355
Impairment of goodwill and PPA's		—			—			(1,859	)
Impairment of assets classified as discontinued operations		—			—			(3,619	)
Net Income / (loss) from discontinuing operations after impairments		648			169			(5,123	)
Less: Net income attributable to the non-controlling interest		(34	)		(7	)		(1	)
NET INCOME / (LOSS) attributable to NBG shareholders		614			162			(5,124	)

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 5.00 Euro 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 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 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 Greek State, in accordance with the 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 5.00 Euro each.

As a result of Cabinet Act 45/07.12.2015 (see also Note 33), all the 270,000,000 outstanding preference shares issued in favor of the Greek State, in accordance with the Greek Law 3723/2008 were converted into 1,305,000,000 ordinary shares, which were received by the HFSF.

Therefore, following the above there are no under Greek Law 3723/2008 preference shares outstanding. Please also refer to Note 33.

Under the government-guaranteed borrowings facility, as of December 31, 2015 we participated in the second pillar of Greek Law 3723/2008 as follows:

Subsequent to December 31, 2015, under the same Pillar the Bank issued the following note:

Additionally, on April 15, 2016, under the same Pillar the Bank partially cancelled the following note:

The notes described above have been issued by the Bank, are guaranteed by the Hellenic Republic and are held by the Bank and therefore, are not presented as liabilities on the consolidated balance sheet. For the guarantees provided by the Hellenic Republic, an annual fee is payable by the Bank to the Hellenic Republic. This fee ranges from 104 to 115 basis points (depending on the notes) and is calculated on the nominal amount of the notes issued, prorated for the period the notes are outstanding.

On August 6, 2013, September 16, 2013 and July 17, 2014 the Bank received from Public Debt Management Agency, new three-year zero coupon special Greek government bonds of EUR 787 million, EUR 60 million and EUR 1,262 million, respectively, collateralized with customer loans. These bonds can only be used as collateral for financing and therefore are reflected in off-balance sheet items.

On March 30, 2016, the Bank cancelled the aforementioned notes under Pillar III.

At December 31, 2014 and 2015, the Group pledged mainly for funding purposes with the Eurosystem, the European Investment Bank, other central banks and financial institutions, the amount of EUR 11,036 million and EUR 30,302 million, respectively. The corresponding liabilities are presented in Note 20 within interbank interest bearing deposits.

The pledged amounts as at December 31, 2015 relate to the following instruments:

Additionally to the amounts above, the Bank has pledged off-balance sheet assets for funding purposes with the Eurosystem:

In addition to the pledged items presented above, as at December 31, 2015, the Group has pledged Hellenic Republic Treasury bills of EUR 181 million for trade finance purposes.

The aggregate amount of short-term certificates of deposit, each with a minimum denomination of EUR 87,400, which approximates USD 100,000, was EUR 24 million at December 31, 2015 (2014: EUR 136 million). At December 31, 2015, interest-bearing deposits with scheduled maturities in excess of one year were EUR 477 million (2014: EUR 653 million).

Deposits made by Greek residents and foreign customers at December 31, comprised:

	2014						2015

	Greek residents		Foreign		Total		Greek residents		Foreign		Total
	(EUR in millions)						(EUR in millions)
Interest bearing:
Public sector		2,932		38		2,970		2,825		32		2,857
Private sector:
Corporations		5,046		1,752		6,798		3,661		1,633		5,294
Individuals		34,246		4,840		39,086		28,605		4,418		33,023
Interbank		14,667		1,040		15,707		24,162		569		24,731

Total interest bearing deposits		56,891		7,670		64,561		59,253		6,652		65,905

Non-interest bearing:
Public sector		228		4		232		165		2		167
Private sector:
Corporations		885		92		977		966		147		1,113
Individuals		92		174		266		146		185		331
Interbank		45		25		70		22		26		48

Total non-interest bearing deposits		1,250		295		1,545		1,299		360		1,659

Total:
Public sector		3,160		42		3,202		2,990		34		3,024
Private sector:
Corporations		5,931		1,844		7,775		4,627		1,780		6,407
Individuals		34,338		5,014		39,352		28,751		4,603		33,354
Interbank		14,712		1,065		15,777		24,184		595		24,779

Total deposits		58,141		7,965		66,106		60,552		7,012		67,564

Included in the above table are interest bearing deposits of EUR 16 million and EUR 2 million for 2014 and 2015 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 2014 losses of EUR (1) million and during 2015 losses of NIL million, relating to fair value changes of these deposits were included in net trading gain/(loss).

Interest bearing interbank deposits under "Greek residents" mainly include the funding from the Eurosystem amounting to EUR 14,240 million (of which ECB funding EUR 14,240 million and ELA funding NIL) and EUR 24,029 million (of which ECB funding EUR 12,529 million and ELA funding EUR 11,500 million) for 2014 and 2015 respectively.

On December 18, 2015, following the Resolution Measures Committee of the Bank of Greece (meeting no 28/18.12.2015), the deposits of the credit institution under resolution "Cooperative Bank of Peloponnese Coop Ltd" were transferred to the Bank. The decision was also published in the Government Gazette "N.2762/18.12.2015". The amount transferred was EUR 95 million.

Information concerning securities sold under agreements to repurchase is summarized as follows:

	2014

	(EUR in millions)
Securities sold under agreements to repurchase		3,587		101
Securities sold under agreements to repurchase:
Average outstanding during the year		4,010		454
Weighted average interest rate during the year		0.52	%	0.49	%
Weighted average interest rate at year end		0.22	%	1.48	%
Amount outstanding at month end:
January		4,004		637
February		3,857		129
March		4,244		121
April		4,940		140
May		2,776		90
June		4,188		254
July		4,270		267
August		4,942		157
September		3,833		199
October		4,334		116
November		3,642		101

Securities sold under agreements to repurchase are recorded at the amount of cash received in connection with the transaction.

Accounts payable, accrued expenses and other liabilities at December 31, comprised:

	2014

	Restated⁽²⁾
	(EUR in millions)
Accrued expenses and deferred income		113	110
Amounts due to re-insurers		17	56
Income and other taxes payable		79	69
Accounts payable		230	245
Payroll related accruals		27	17
Private equity: liabilities of investee entities⁽¹⁾		290	—
Unsettled transactions on debt securities		1	—
Accrued interest and commissions		262	229
Deferred tax liability		21	22
Amounts due to third-parties under collection agreements		124	16
Pension liability		291	273
Amounts due to government agencies		151	168
Liabilities relating to deposit administration funds (DAF)		200	177
Checks and credit card transactions under settlement		224	128
Sale of Real Estate accounted for as financing obligation		743	707
Other		201	356

Total		2,974	2,573

NOTE 22: ACCOUNTS PAYABLE, ACCRUED EXPENSES AND OTHER LIABILITIES (Continued)

Included in the above table under "Other" are liabilities carried at fair value, relating to short positions in shares amounting to EUR 4 million and NIL at December 31, 2014 and 2015 respectively.

The sale of Real Estate, accounted for as financing obligation of EUR 707 million relates to the transfer of 66.00% of the participation interest to Invel Real Estate which is treated as a sale of real estate accounted for as financing obligation (see Notes 3 and 4).

The Group has committed under the Revised Restructuring Plan, to decrease its Total Full Time Equivalent personnel ("FTEs") in Greece to a maximum of 10,250 at the end of 2017 and 9,950 at the end of 2018. Based on this commitment, as of December 31, 2015 the Group recognized a provision of EUR 118 million, which is presented within "Other" line item.

Ethniki Hellenic General Insurance S.A. ("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 outstanding claims and claim adjustment expenses for the year ended December 31, comprises of:

	2014

	(EUR in millions)
Property and casualty reserves
Reserve for outstanding claims and claim adjustment expenses as at January 1,		603		578
Incurred claims and claim adjustment expenses:
Provision for insured events of the current year		110		114
Change in provision for insured events of prior years		(36	)	(61	)

Total incurred claims and claim adjustment expenses		74		53
Payments:
Claims and claim adjustment expenses attributable to insured events of the current year		(32	)	(27	)
Claims and claim adjustment expenses attributable to insured events of prior years		(68	)	(64	)

Total payments		(100	)	(91	)
Changes in unearned premium reserves		1		(11	)

Reserves for outstanding claims and claim adjustment expenses as at December 31,		578		529

The share of reinsurers in property and casualty insurance reserves amounted to EUR 330 million and EUR 288 million at December 31, 2014 and 2015 respectively.

Acquisition costs amortized for the year ended December 31, 2015 amounted to EUR 22 million.

The change in the provision for insured events of prior years is due to the adjustment of the case reserves as new information becomes available.

The interest rate curve used in estimating insurance contract liabilities is the ECB AAA curve plus a spread based on estimates of investment yields, net of related investment expenses, expected at the time the insurance contracts are made, and including a risk of adverse deviation. Interest assumptions are adjusted in the event that a premium deficiency exists.

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 Premium 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 2013, 2014 and 2015 are reinsurance premiums assumed of EUR 1 million, NIL and NIL respectively.

Net premiums earned on long-duration life insurance contracts amounted to EUR 151 million, EUR 94 million and EUR 110 million for 2013, 2014 and 2015 respectively.

Long-term debt (original maturities of more than one year) at December 31, comprised:

Long-term debt Senior Notes and the related rates and maturity dates at December 31, comprise:

The financial conditions of the major long-term senior fixed rate debt as of December 31, 2015, are as follows:

Issuer	Type	Issue date	Maturity date	Currency				Interest rate	Interest payment

Covered bonds
NBG	Fixed rate covered bonds- Third Series	October 7, 2009	October 2016	EUR	846	⁽¹⁾	4	Fixed coupon rate of 3.875%	Annually
Fixed rate notes
NBG	Fixed Rate Notes	December 20, 2012	December 2024	EUR	45	⁽²⁾	—	Fixed interest rate of 2.535%	Quarterly
NBG	Fixed Rate Notes	August 5, 2013	August 2023	EUR	45	⁽²⁾	—	Fixed interest rate of 2.519%	Quarterly
NBG	Fixed Rate Notes	December 23, 2013	December 2023	EUR	66	⁽²⁾	—	Fixed interest rate of 2.68%	Semi-annually
NBG	Fixed Rate Notes	January 29, 2014	January 2026	EUR	63	⁽²⁾	—	Fixed interest rate of 2.96%	Semi-annually

The financial conditions of the major long-term senior variable rate debt as of December 31, 2015, are as follows:

Issuer	Type	Issue date	Maturity date	Currency				Interest rate	Interest payment

Variable rate corporate bonds
NBG Pangaea Reic	Variable rate bond	August 20, 2014	July 2019	EUR	232		—	Euribor plus 4.85%.	Quarterly
Variable rate notes
NBG	Variable Rate Notes	September 1, 2009	September 2016	EUR	95	⁽¹⁾	—	Three-month Euribor plus 0.576%	Quarterly
NBG	Variable Rate Notes	December 29, 2014	December 2022	EUR	33	⁽¹⁾	—	Six-month Euribor plus 1.674%	Semi-annually

Long-term Subordinated debt Senior Notes and the related rates and maturity dates at December 31, comprise:

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 had fully and unconditionally guaranteed all securities issued by these companies. There were 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 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.

The Group does not consolidate NBG Funding Ltd as the Group is not deemed to be the primary beneficiary of the entity. Therefore, the Group did not have the obligation to absorb losses or the right to receive benefits as the only assets of NBG Funding Ltd were loans to and deposits with NBG.

The capital plan approved from SSM (see Note 36), among other actions, included offerings to eligible holders of debt instruments.

In this context, on December 1, 2015, the Bank announced the results of the LME offers which commenced on November 2, 2015 and expired on December 1, 2015 for the buy back of up to the total amount of the debt securities issued the finance subsidiaries, in consideration for subscription of new ordinary shares in the share capital increase, as approved on November 17, 2015 by the Extraordinary General Meeting of the Bank's shareholders.

The remaining debt instruments that were not tendered in the LME Offers, were included in the Burden Sharing Measures specified in the context of the provision of state aid to the Bank as descripted in Note 33 which provided the mandatory conversion into ordinary shares of the outstanding debt instruments, all subordinated liabilities and certain senior unsecured liabilities which are not mandatorily preferred by law. More specifically, as per Art 6a of Greek Law 3864/2010, the Act sets out, inter alia the terms under which: (a) the guarantees written by NBG to the holders of the certain debt instruments issued by NBG Funding Ltd were converted to NBGs' common shares, and (b) the total amounts of the notes (Eurobonds) issued by NBG and held by NBG Funding Ltd were written down in full due to the above capitalization of the Guarantees. Therefore, according to the Act the contingent liabilities assumed by NBG by providing subordinated guarantees to third parties in connection with the issuance of each of the certain debt instruments issued by NBG Funding Ltd were converted to new common shares of NBG. The value of the equity shareholding in NBG delivered to the holders of the certain debt instruments was equivalent to 30% of the par value they hold. As a result the value of the certain debt instruments on NBG's Statement of Financial Position has been reduced to nil.

The result of the LME Offer and the Burden Sharing Measures in respect of the Target Securities were as follows:

Issuer			Currency

			Amounts in million
Senior Unsecured Notes:
NBG Finance Plc	100	%	EUR	701	667	34
Subordinated fixed rate notes:
NBG Finance Plc	75	%	EUR	18	1	17
NBG Funding Ltd-Series A	30	%	EUR	18	7	11
NBG Funding Ltd-Series B	30	%	EUR	19	6	13
NBG Funding Ltd-Series C	30	%	USD	14	8	6
NBG Funding Ltd-Series D	30	%	EUR	23	9	14
NBG Funding Ltd-Series E	30	%	GBP	9	1	8

On December 9, 2015 the Bank announced the mandatory conversion into ordinary shares, of the instruments not offered in the context of the LME Offer. The amount used for the share capital increase amounted to EUR 64 million by issuing 211,979,849 ordinary shares. The gain that resulted from the LME offer and Burden Sharing Measures amounted to EUR 16 million and was recognized in Net trading gain/loss (see Note 28).

Variable rate borrowings of NBG Pangaea REIC subsidiaries amounted to EUR 106 million, all denominated in EUR.

Moreover, borrowings of Stopanska Banka amounted to EUR 14 million, denominated in Makedonian Dinar and Euro (of which fixed rate borrowings amounted to EUR 12 million and variable rate borrowings amounted to EUR 2 million) and variable rate borrowings of Vojvodjanska Banka amounted to EUR 2 million all denominated in Euro.

On December 9, 2015, within the context of the 2015 Recapitalisation, the Bank issued Non-Cumulative Perpetual Contingently Convertible securities ("CoCos"). The Hellenic Financial Stability Fund ("HFSF") subscribed these CoCos for the amount of EUR 2,029 million in exchange for part of the debt securities issued by the ESM (see Note 11).

The CoCos bear interest at 8% per annum for the first seven years and thereafter, the interest rate is set to the sum of: (a) the 7-year Mid-Swap Rate plus (b) the difference between the initial interest rate of 8% and the 7-year Mid-Swap Rate at the CoCos' issue date. Payment of interest (whether in whole or in part) is entirely at the discretion of the Bank. However, if the Bank does not pay all or any part of any scheduled interest payments more than once, or the CET1 ratio of the Bank, calculated on a consolidated or a solo basis, is lower than 7%, then the CoCos are automatically converted into ordinary shares of the Bank determined by dividing 116% of the nominal value of the then outstanding CoCos by the subscription price of the 2015 Recapitalisation (i.e. EUR 0.30 per share). Based on the total amount of CoCos currently outstanding, the number of ordinary shares that would be issued is 7,846,240,000. The Bank's Board of Directors has the option, at its full discretion, to pay interest in the form of newly issued ordinary shares of the Bank based on the then current market price of these shares.

HFSF can convert the CoCos into 7,846,240,000 ordinary shares of the Bank in December 2022. The Bank has the option to repay in cash all or some of the CoCos at any time at their initial nominal value plus any accrued and unpaid interest, provided that all necessary regulatory approvals are obtained.

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 and guarantees.

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 Bank and certain of its subsidiaries are defendants in certain claims 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, 2014 and 2015 the Group has accrued for cases under litigation the amount of EUR 67 million and EUR 62 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 reasonably estimate possible losses, since 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.

In addition to the net unrealized losses on trading assets (see Note 9), the losses on derivative instruments (see Note 10), the losses on deposits and the losses on long-term debt at fair value (see Note 20 and Note 24, respectively), net trading gain/loss in 2014 also includes gains from the re-purchase by the Group from the open market of debt securities issued by the Group of EUR 5 million. The remaining amount in net trading gain/loss in 2015 mainly relates to gains of EUR 4 million that resulted from the LME offer and from the Burden Sharing Measures on the Long-term Debt and gains of EUR 16 million from the LME offer and the Burden Sharing Measures relating to the Preferred securities (see Note 24).

	2013

	(EUR in millions)
Insurance claims, reserves movement, commissions and reinsurance premium ceded		531	256	306
Credit card costs		14	16	18
Hotel running costs		28	24	20
Broker costs		5	5	4
Rental expense		57	53	52
Taxes and duties other than income tax		74	38	34
Promotion and advertising		26	28	22
Third party fees		75	118	104
Commissions on issues of Hellenic Republic Bank Support Plan—Pillar II & III & ELA		185	161	197
Other provisions		44	325	340
Other		221	225	193

Total		1,260	1,249	1,290

Commissions on issues of Hellenic Republic Bank Support Plan—Pillar II & III relate to the fees payable to the Hellenic Republic with respect to the notes issued by the Bank and guaranteed by the Hellenic Republic, in the context of Pillar II & III of the Hellenic Republic Bank Support Plan and commissions on ELA funding, as described in Note 18.

The Group has committed under the Revised Restructuring Plan, to decrease its FTEs in Greece to a maximum of 10,250 at the end of 2017 and 9,950 at the end of 2018. Based on this commitment, as of December 31, 2015 the Group recognized a provision of EUR 118 million, which is presented within "Other Provisions".

Insurance claims, reserves movement, commissions and reinsurance premium ceded for the years ended December 31 comprised:

The allocation of income / (loss) before income tax between domestic and foreign is as follows:

The significant components of the income tax/(expense) for the years ended December 31, 2013, 2014 and 2015 are as follows:

The differences between the nominal statutory income tax and the effective income tax are summarized as follows:

	2013

	(EUR in millions)
Income tax calculated based on statutory income tax rate of 29% (2013: 26%, 2014: 26%)		(145	)	(670	)	(958	)
Adjustments relating to income taxes from prior years		—		—		(9	)
Effect of tax exempt income		(155	)	(165	)	(168	)
Effect of different tax rates in other countries		37		(20	)	2
Non deductible expenses		26		37		133
Statutory revaluation of fixed assets		11		—		—
Effect of change in income tax rate		(1,069	)	—		(697	)
Valuation allowance for deferred tax assets		1,297		918		1,080
Non-offsettable income taxes with current year income taxes		1		2		18
Effect from offsetting of prior year carry forward tax losses		—		—		598
Income tax audit settlement		(7	)	—		27
Other		24		(39	)	16

Income tax expense / (benefit)		20		63		42

The significant components of deferred income tax assets and liabilities at December 31 comprised:

	2014

	(EUR in millions)
Deferred Tax Assets:
Allowance for loan losses		1,821		2,956
Mark to market valuation of securities and derivatives		549		519
Pension and other post retirement benefits		97		104
Insurance reserves		71		55
Revaluation of land and buildings		152		163
Intangibles recognized upon acquisition and other assets		1		1
Tax loss carried forward		1,024		798
Other		288		317
PSI tax losses		2,221		2,385

Gross deferred tax assets		6,224		7,298
Deferred tax assets / liabilities for netting		(58	)	(43	)

Net deferred tax assets		6,166		7,255
Valuation allowance for deferred tax assets		(5,977	)	(7,057	)

Net deferred tax assets after valuation allowance		189		198



Deferred Tax Liabilities:
Allowance for loan losses		(11	)	(10	)
Mark to market valuation of securities and derivatives		(16	)	(10	)
Insurance reserves		(1	)	—
Revaluation of land and buildings		—		(5	)
Intangibles recognized upon acquisition and other assets		(13	)	(13	)
Tax free reserves		(17	)	(18	)
Other		(21	)	(9	)

Gross deferred tax liabilities		(79	)	(65	)
Deferred tax liabilities / assets for netting		58		43

Net deferred tax liabilities		(21	)	(22	)

Reconciliation of the movement of valuation allowance for deferred tax assets:

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 189 million and EUR 198 million, at December 31, 2014 and 2015

respectively, is more likely than not based upon all available positive and negative evidence in Greece and the other countries where the Group operates.

A significant piece of objective negative evidence evaluated was the cumulative loss incurred over the years ended December 31, 2014 and 2015 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. However, Greek Law 4110/2013 amended the said provision so that, any difference (loss) arising from the said exchange is amortised in 30 annual equal instalments.

Each year Management assesses whether the recognition of the deferred tax asset is appropriate to the extent that future taxable profit will be available to absorb these tax losses and other deductible temporary differences.

The Group as at December 31, 2015 has a deferred tax asset of EUR 798 million on the tax losses carry-forward of EUR 2,835 million which expire as follows:

The applicable Greek statutory corporation income tax rate was 26% for 2013 and for 2014 and 29% for 2015. In January 2013, Greek Law 4110/2013 provided that for the periods commencing from January 1, 2013 thereon, the nominal corporation tax rate was increased to 26%. Furthermore, for profit distributions approved from January 1, 2014 onwards the withholding tax is reduced to 10% from 25%.

On July 16, 2015, a new Law 4334/2015 was voted, relating to immediate prerequisites for negotiation and agreement with European Stability Mechanism (ESM), by which the corporation tax rate is increased to 29%. The increase is effective from January 1, 2015 onwards.

Following the recent tax law, the withholding tax on dividends distributed from January 1, 2016 onwards, is increased from 10% to 15%.

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 increase in the nominal tax rates. The total effect, for the years ended December 31, 2013, 2014 and 2015, was an expense of EUR (1,069) million, NIL and EUR (697) million respectively which

was offset by an equivalent amount of valuation allowance resulting in a total net effect of NIL for the years 2013, 2014 and 2015.

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.

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.

Tax authorities have not yet audited all subsidiaries for certain financial years and accordingly their tax obligations for those years may not be considered final. Additional taxes and penalties may be imposed as a result of such tax audits; although the amount cannot be determined, it is not expected to have a material effect on the consolidated or separate Statement of Financial Position of the Group and the Bank. The Bank has been audited by the tax authorities up to and including the year 2014 while 2015 is currently being audited by the independent auditor, Deloitte Hadjipavlou Sofianos & Cambanis S.A. in the framework of the tax audit certificate according to art. 65A of Law 4174/2013. Tax audit for the years 2009 and 2010 was finalized by the Greek Tax Authorities on February 4, 2015. According to the tax assessment notice received on March 11, 2015, an additional tax of EUR 36 million was levied to the Bank. An amount of EUR 27 million was paid to the tax authorities and the remaining amount of EUR 9 million (penalties and interests) was permanently waived by the tax authorities in accordance with the provisions of Law 4321/2015. The Bank has appealed the decision. The tax audit certificates for the years 2011, 2012, 2013 and 2014 were unqualified and issued by the independent auditor, Deloitte Hadjipavlou Sofianos & Cambanis S.A., on July 27, 2012, September 27, 2013, July 10, 2014 and October 30, 2015 respectively in accordance with article 82 of law 2238/1994 and article 65A of law 4174/2013. Based on Ministerial Decision 1006/05.01.2016 there is no exception from tax audit by the tax authorities to those entities that have been tax audited by the independent auditor and its tax audit certificate was unqualified. Therefore, the tax authorities may re-audit the tax books of the Bank for previous years 2011, 2012, 2013 and 2014, for which a tax audit certificate has been issued by the independent auditor.

The open tax years of the major companies of the Group at December 31, 2015, are as follows:

The nature of the significant transactions entered into by the Group with related parties during the year ended December 31, 2015 and 2014 and the significant balances outstanding at December 31, 2015 and 2014 are presented below.

The Group has entered into transactions with the members of the Board of Directors, 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.

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 collectability or present other unfavorable features.

The aggregate amount of loans, deposits and letters of guarantee to related parties, at Group level, totaled EUR 100 million, EUR 25 million and EUR 10 million respectively as at December 31, 2015 (December 31, 2014: EUR 108 million, EUR 16 million and EUR 15 million respectively).

The Group has also entered into transactions with its affiliates, which are accounted for by the equity method (see Note 12). As at December 31, 2015, the aggregate amount of receivables from affiliates totaled EUR 16 million, the amount of payables to affiliates totaled EUR 65 million and the amount of letters of guarantee to affiliates totaled EUR 2 million (December 31, 2014: EUR 16 million, EUR 145 million and EUR 2 million respectively). For the year ended December 31, 2015, the aggregate amount of income from affiliates totaled EUR 38 million and the amount of expense to affiliates totaled EUR 11 million (December 31, 2014: EUR 38 million and EUR 13 million respectively).

The total receivables of the Group from the employee benefits related funds as at December 31, 2015, amounted to EUR 781 million (December 31, 2014: EUR 674 million). The total payables of the Group to the employee benefits related funds as at December 31, 2015, amounted to EUR 149 million (December 31, 2014: EUR 142 million).

Taking into consideration the HFSF Law, the Amended Relationship Framework Agreement between the Bank and the HFSF, the fact that HFSF holds 40.39% of the Bank's ordinary shares, of which 38.92% with full voting rights and that HFSF has representation in the Bank's Board of Directors and other Board Committees of the Bank, HFSF is considered a related party of the Group. Other than the ordinary shares and CoCos issued by the Bank and held by HFSF, no transactions or balances exist with HFSF.

On November 17, 2015, the Extraordinary General Meeting of the Shareholders approved a) the reverse split of the ordinary shares at a ratio of 15 existing shares of 0.30 Euro per share to be exchanged for 1 new share of 4.50 Euro per share and the reduction of the number of shares from 3,533,149,631 to 235,543,309, b) the reduction in the nominal value from 4.50 Euro per share to 0.30 Euro per share, with the formation of a special reserve of an equal amount for offsetting losses and c) the share capital increase by EUR 4,482 million in the context of recapitalization of the banks pursuant to the provisions of Law 3864/2010, as amended, and Cabinet Act 36/02.11.2015 through cancellation of the pre-emptive rights to existing shareholders, by issuing new ordinary shares, through In-Cash Contribution and/or In-Kind Contribution including the issuance of a convertible bond loan through the issuance of unsecured, perpetual and subordinated bonds, contingently convertible into ordinary shares of the Bank.

Specifically, the amount of capital increase was determined after the publication of the results of the Comprehensive Assessment ("CA") conducted by the ECB, following the Euro Summit Statement of July 12, 2015 and the ECB's decision of August 5, 2015. The CA resulted in a total capital shortfall of EUR 4,482 million, EUR 1,456 million of which was due to the baseline scenario and EUR 3,026 million was due to the adverse scenario. The Bank submitted its capital plan to the SSM, which among other actions, included a private placement to qualified investors abroad (Offer Abroad), a public offering in Greece (Public Offer), and offerings to eligible holders of debt and capital instruments (collectively, the "Private Capital Raising Measures") which were intended to raise at least an amount of capital sufficient to cover the baseline scenario shortfall of EUR 1,456 million and State Aid through HFSF. Any capital raised through the Private Capital Raising Measures in excess of the baseline scenario shortfall was to be applied towards covering of the adverse scenario shortfall of EUR 3,026 million.

As regards the In-Cash Contribution, the offer of shares was to be incurred through the Offer Abroad and through the Public Offer.

The allocation between the Offer Abroad and the Public Offer decided to be as follows (subject to increased demand):

On December 8, 2015, the Board of Directors certified that the capital raised through the Offer Abroad amounted to EUR 457 million with the issuance of 1,524,851,811 new shares whereas the capital raised through the Public Offer amounted to EUR 300 million with the issuance of 999,852,461 new shares. The subscription price was set at 0.30 Euro per share as it was determined by the international book-building process outside Greece to institutional and other eligible investors.

The In-Cash Contribution also included the Liability Management Exercise ("LME") which related to the offer for purchase of the Bank's outstanding debt and capital instruments (see Note 24).

Following the above, on November 2, 2015, the Bank announced the offer for purchase of the outstanding senior and subordinated debt instruments together with the offer for purchase of the outstanding preferred securities (5 Series) and the participation of the holders of the securities in the share capital increase by an amount equal to the consideration obtained from the buyback of the said securities.

On December 9, 2015, the Bank announced that following the above offers, the buyback of the said securities amounted to EUR 695 million, which was used for the share capital increase by issuing 2,316,353,950 shares.

The In-Kind Contribution included, the implementation of burden sharing measures (the mandatory conversion into ordinary shares of all of the Bank's outstanding debt and capital instruments the holders of which were not voluntarily offered its securities in the above offers) following the Bank's request for State Aid to cover the remaining adverse scenario capital shortfall. Such shortfall was to be covered through the issuance in favour of the HFSF of new shares for 25% of the remaining capital shortfall and CoCos for 75% of the remaining capital shortfall, as defined in the Cabinet Act 36/02.11.2015.

Based on the Cabinet Act 45/07.12.2015, the Bank announced on December 9, 2015, that the mandatory conversion of the securities not offered in the LME into ordinary shares amounted to

EUR 64 million, which was used for the share capital increase by issuing 211,979,849 shares (see Note 24). Also, the preference shares issued in USA and the preference shares issued in favour of the Greek State, in accordance with the Law 3723/2008 were also converted to ordinary shares by issuing 298,700,987 and 1,305,000,000 ordinary shares respectively. The 1,305,000,000 ordinary shares that resulted from the mandatory conversion of the preference shares issued in favour of the Greek state were received by the HFSF.

Finally, the In-Kind Contribution included the participation of HFSF in share capital increase with the amount of EUR 676 million by issuing 2,254,869,160 ordinary shares.

Following the above, the total capital increase amounted to EUR 2,673 million with the issuance of 8,911,608,218 shares.

On May 10, 2014, the Extraordinary General Meeting of the Shareholders approved the common stock increase by EUR 2,500 million by issuing 1,136,363,637 ordinary shares of a par value of 0.30 Euro per share, through cancellation of the pre-emptive rights for existing shareholders, which was completed on May 13, 2014. The subscription price was set at 2.20 Euro per share as it was determined by the international book-building process outside Greece to institutional and other eligible investors.

On April 29, 2013, the 2nd Repeat Extraordinary General Meeting of the Shareholders approved a) the reverse split of the common shares at a ratio of 10 existing shares of EUR 1.00 per share to be exchanged for 1 new share of EUR 10.00 per share, b) the reduction in the nominal value from EUR 10.00 per share to EUR 0.30 per share as per article 4 Para 4a of the Greek Company Law 2190/1920 as amended, with the formation of a special reserve of an equal amount included in the "Additional paid-in capital" and c) the common stock increase by EUR 9,756 million in the context of recapitalization of the Greek systemic banks.

On June 19, 2013, the Board of Directors certified that EUR 1,079 million was covered by private investors in cash and EUR 8,677 million by HFSF through the EFSF bonds already advanced to the Bank in 2012 and the Bank issued 2,274,125,874 common shares of EUR 0.30 per share. The HFSF has restricted voting rights by law. If the shares are sold by the HFSF, the new shareholders will have the same rights as other NBG common shareholders.

According to Article 7a par.1 of the Greek Law 3864/2010, the common shares held by HFSF give the right to HFSF to exercise its voting rights in the General Meeting of Shareholders only for decisions regarding amendments to the Articles of Association, including increase or reduction of capital or provision of proxy powers to the Board of Directors to that effect, merger, division, conversion, revival, extension of duration or dissolution of the company, transfer of assets, including the sale of subsidiaries or any other issue requiring an increased majority as provided by Greek Company Law 2190/1920 on "sociétés anonyms". Specifically, in order to calculate quorum and majority at the General Meeting, the shares of HFSF are not taken into account regarding decisions on matters other

than those mentioned above. According to Article 7a of Greek Law 3864/2010, HFSF exercises its full voting rights without the aforementioned limitations if it is concluded, by decision of the HFSF General Council, that there is a breach of material obligations which are included in the restructuring plan or which promote its implementation.

From the amount of EUR 9,756 million, EUR 682 million was credited to the common stock whereas the remaining amount of EUR 9,074 million less expenses was credited to the additional paid-in capital account.

In particular, warrants are transferable securities with no restrictions concerning their transfer. Following the reverse split in November 2015, each warrant incorporates the right of its holder to purchase from HFSF 0,54861592129144 new shares, acquired by HFSF due to its participation in the capital increase of Bank in 2013. The warrants do not provide voting rights to holders or owners thereof.

Following the reverse split in November 2015, the exercise price of the call option for each warrant in order to acquire new shares held by HFSF, will be equal to 64.35 Euros plus accrued interest at an annual rate of 3% plus the margin:

After the end of the fifth exercise period (December 28, 2015), the warrants currently remaining in force are 245,745,725, whereas the shares of the Bank upon which they are drawn and which are held by HFSF are 134,820,022 (after the reverse split).

Transfers of the Bank's shares are carried out as prescribed by law and are not subject to any restrictions pursuant to the Bank's Articles of Association, except for the ordinary shares acquired by HFSF in the context of the 2013 recapitalization which are subject to the provisions of article 8 of Law 3864/2010 and article 3 par.7 of Cabinet Act 38/2012. Following the 2015 recapitalization, such shares represent 1.47% out of the total 40.39% HFSF shareholding

In particular, according to article 8 of Law 3864/2010, HFSF decides on the way and procedure for disposing its shares at a time it deems appropriate and in any case within five years from its participation in the Bank's capital increase, provided that par.1 of article 7a of Law 3864/2010 applies. The disposal may take place gradually or one-off, at HFSF's discretion, so long as all shares are disposed of within the time limits referred to above. The disposal of shares within the time limits stipulated above may not be made to any entity belonging directly or indirectly to the Hellenic Republic, in accordance with Greek Law. Furthermore, disposal shall be carried out with a view to protecting the interests of the Hellenic Republic, taking into consideration also to strengthen the financial stability and ensure a level-playing field in the financial sector.

Additionally, according to article 3 par. 7 of Cabinet Act 38/2012, without prejudice to the transfers which will take place due to exercise of the call option embedded in the Warrants, HFSF will not be able to transfer the shares which carry call option, for a period of 36 months after the issue date of the securities i.e. until June 26, 2016. After the expiry of the aforementioned period and until the final date of exercise of the call option, according to the same article of Cabinet Act 38/2012, HFSF may dispose its shares which carry call option according to paragraphs 7-11 of Article 3 of Cabinet Act 38/2012.

More specifically, further to the share capital increase decided by Extraordinary General Meeting of Shareholders November 17, 2015, the HFSF (a) injected capital of EUR 676 million and received in exchange 2,254,869,160 and (b) received 1,305,000,000 common shares with nominal value EUR 392 million, which resulted from the mandatory conversion of the preference shares issued in the favor of the Greek State (see above). The aforementioned common shares embody full voting rights and represent 38.92% of the share capital of the Bank. Furthermore, HFSF received 20,292 CoCos of EUR 100,000 each equal to an amount of EUR 2,029 million issued by the Bank (see Note 25). HFSF retains also common shares with restricted voting rights corresponding to 1.47% of the share capital of the Bank.

However under the previous recapitalization that took place in 2013 and in accordance to Article 7a par.1 of the Greek Law 3864/2010, the 134,820,022 (or 1,47% of the Bank's total share

capital) common shares held by HFSF give the right to HFSF to exercise its voting rights in the General Meeting of Shareholders only for decisions regarding amendments to the Articles of Association, including increase or reduction of capital or provision of proxy powers to the Board of Directors to that effect, merger, division, conversion, revival, extension of duration or dissolution of the company, transfer of assets, including the sale of subsidiaries or any other issue requiring an increased majority as provided by Company Law 2190/1920 on "sociétés anonymes". Specifically, in order to calculate quorum and majority at the General Meeting, the shares of HFSF are not taken into account regarding decisions on matters other than those mentioned above. According to Article 7a of Greek Law 3864/2010, HFSF exercises its full voting rights without the aforementioned limitations if it is concluded, by decision of the HFSF General Council, that there is a breach of material obligations which are included in the restructuring plan or which promote its implementation.

On January 22, 2009, at an Extraordinary General Meeting, the Bank's shareholders approved the issue of 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 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 minutes of the Board of Directors' meeting covering the above mentioned certification were filed with the Ministry of Development (resolution K2-5300/Registrar of Companies). Following the above the Bank's preferred stock increased by EUR 350 million.

On December 22, 2011, the Extraordinary General Meeting of the Bank's Shareholders approved 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 preemptive rights of the existing shareholders 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 million Redeemable Preference Shares at a nominal value of EUR 5.00 each which embody the same privileges and characteristics as the 70 million redeemable preference shares described above.

Following the Cabinet Act 45/07.12.2015, all the 270,000,000 outstanding preference shares issued in favour of the Greek State, in accordance with the Law 3723/2008 were converted into 1,305,000,000 ordinary shares, which were received by the HFSF. Therefore, following the above there are no L3723/2008 preference shares outstanding.

On May 31, 2013, the Bank announced an offer to purchase for cash 22,500,000 out of the 25,000,000 outstanding American Depositary Shares at 12.50 Dollar per American Depositary Share ("ADS") upon the terms and subject to the conditions set forth in the Offer to Purchase. The Offer aimed to generate Core Tier I capital for the Bank and to further strengthen the quality of its capital base.

As of June 28, 2013, which was the expiration time of the Offer, 12,360,169 ADSs were validly tendered, representing approximately 49.4% of the ADSs outstanding at the expiration time. Based on the results of the Offer, the aggregate purchase cost for the tendered ADSs was USD 155 million.

Therefore, following the purchase of the ADSs in 2013, 12,639,831 ADSs remained outstanding. The Bank cancelled any ADSs purchased pursuant to the Offer, and cancelled the Preference Shares represented thereby, following the completion of the requisite corporate approvals for cancellation of the Preference Shares.

Following the Cabinet Act 45/07.12.2015, all the outstanding preference shares (i.e. 12,639,831) were converted into 298,700,987 ordinary shares.

On September 26, 2014 NBG acquired the 5.00% of the voting common shares of its Turkish bank subsidiary Finansbank A.S. from IFC pursuant to an exercise by IFC of its put option right in accordance with the agreement between NBG and IFC dated March 29, 2007. The total consideration paid amounted to USD 343 million calculated in accordance with the pricing formula set out in the aforementioned agreement.

Based on the terms of the above agreement, the ordinary shares subject to the put option described above were accounted for as a redeemable non-controlling interest as described in Note 3, in accordance with ASU 2009-04 (EITF Topic D-98). The change in the redemption amount up to the date of exercise of the put option was recognized in "Accumulated Surplus/Deficit".

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 millions, except share and per share data).

	2013			2014

	Restated⁽¹⁾			Restated⁽¹⁾
Net income / (loss) from continuing operations attributable to NBG shareholders		(577	)		(2,639	)	(3,340	)
Gain on redemption of preference shares		—			—		1,067

Net income / (loss) from continuing operations attributable to ordinary shareholders		(577	)		(2,639	)	(2,273	)
Net income / (loss) from disontinued operations attributable to NBG shareholders		614			162		(5,124	)

Net income / (loss) from continuing and discontinued operations attributable to ordinary shareholders		37			(2,477	)	(7,397	)
Weighted average ordinary shares outstanding for basic and diluted earnings per share		92,460,180			208,228,138		786,381,893



Basic and diluted earnings / (losses) per share from continuing operations		(6.24	)		(12.67	)	(2.89	)
Basic and diluted earnings / (losses) per share from continuing and discontinued operations		0.40			(11.90	)	(9.41	)

On November 17, 2015, the Extraordinary General Meeting of the Shareholders approved the reverse split of the ordinary shares at a ratio of 15 existing shares of 0.30 Euro per share to be exchanged for 1 new share of 4.50 Euro per share.

Quantitative measures established by regulation to ensure capital adequacy require the Group and the Bank to maintain minimum amounts and ratios, 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. In June 2013, the European Parliament and the Council of Europe issued a new Directive 2013/36/EU and Regulation (EU) No 575/2013, (known as CRD IV), which incorporate the key amendments that have been proposed by the Basel Committee for Banking Supervision (known as Basel III). Directive 2013/36/EU has been transposed into Greek Law by virtue of Greek Law 4261/5.5.2014 and Regulation (EU) no. 575/2013 has been directly applicable to all EU Member States since January 1, 2014, but some changes under CRD IV will be implemented gradually, mainly between 2014 and 2019. CRD IV revised the definition of regulatory capital and its components at each level.

As of November 1, 2014, all systemic Eurozone banks are under the direct supervision of the European Central Bank ECB (Single Supervision Mechanism—SSM). Before ECB assumed its supervisory responsibilities, NBG as all systemic European banks were subject to an EU-wide Comprehensive Assessment including an Asset Quality Review ("AQR") and Stress Test with December 31, 2013 as the reference date, whose results were announced on October 26, 2014. The AQR and Baseline Stress Test required a minimum CET1 Ratio of 8% and the Adverse Stress Test a minimum CET1 Ratio of 5.5%.

The Adverse Dynamic Balance Sheet stress test, which was based on NBG's approved Restructuring Plan resulted in a CET1 ratio of 8.9%, and a capital surplus of EUR 2.0 billion. In line with ECB's guidelines, the Bank submitted on November 7, 2014 as a capital plan the above approved Adverse Dynamic Balance Sheet scenario and the result for the six month period ended June 30, 2014, which resulted in a capital surplus of more than EUR 2.0 billion and no further capital action was required.

In accordance with the Euro Summit Statement of July 12, 2015 and ECB Decision of August 5, 2015, the ECB conducted a comprehensive assessment ("CA") of the four systemic Greek banks.

The CA consisted of an AQR and a Stress Test ("ST") including a baseline and an adverse scenario. The AQR exercise was conducted by reference to a static balance sheet as of June 30, 2015. The ST was a forward looking exercise, following AQR adjustments, assessing the resilience of NBG's financial position to further significant deterioration of the economic environment from June 2015, until the end of 2017.

Under the baseline scenario (including AQR adjustments), the ST generated an additional negative impact on NBG's regulatory capital, resulting in a stressed CET1 ratio of 6.8% relative to the minimum CET1 ratio threshold set by the SSM at 9.5% for the baseline scenario. Therefore the Baseline ST implied a capital shortfall of EUR 1,576 million. Taking into account the positive impact stemming from the third quarter results, the SSM reduced the capital needs under both the baseline and the adverse scenarios by EUR 120 million. Consequently the capital shortfall for the baseline scenario has been reduced to EUR 1,456 million.

Under the adverse scenario, the ST (including AQR adjustments) identified a capital shortfall of EUR 4,482 million after the reduction of EUR 120 million (an additional EUR 3,026 million compared to the Baseline) relative to a CET1 ratio threshold of 8.0% (compared with 5.5% in the adverse scenario of the 2014 ST).

The capital adequacy ratios for the Group, according to the CRD IV transitional provisions, are presented in the table below:

Article 27A of Law 4172/2013, ("DTC Law"), allows, under certain conditions, Credit Institutions to convert Eligible Deferred Tax Asset ("Eligible DTAs") (under IFRS, as endorsed by the EU) to Tax Credits. Eligible DTAs may increase in future periods due to the recognition of unrecognized DTAs on accumulated provisions and other losses due to credit risk existing as of June 30, 2015. Eligible DTAs may also increase in future periods due to increases in applicable income tax rates. The main condition for the creation of Tax Credits is the existence of an accounting loss for a respective year, starting from accounting year 2016 and onwards, for which Tax Credits can be created in the following year, i.e., from 2017. The Tax Credits will be calculated as a ratio of IFRS accounting losses to net equity (excluding the year's losses), and such ratio will be applied to the remaining Eligible DTAs in a given year to calculate the Tax Credits that will be converted in that year, in respect of the prior tax year.

The Tax Credits shall be offset against the corporate income tax liability of Credit Institutions. In the event that the income tax liability is not sufficient to offset the Tax Credits available for such year in full, the remaining non-offsetable Tax Credits held by the relevant credit institution shall give rise to a direct repayment claim against the Hellenic Republic. From 2017 onwards, the relevant credit institution shall issue and deliver, for free, warrants to the Greek State (conversion rights), which can be converted into ordinary shares of the credit institution at a total market value equal to 100% of such Tax Credits as standing before the offset, at a market price equal to the weighted average market price over the 30 business days preceding the conversion (which 30-day period will take place preceding the Annual General Meeting usually held in May or June), and shall form a special reserve of an equal amount, solely for the purpose of its capitalization in the context of the share capital increase arising from the exercise of the relevant conversion rights. The warrants shall be freely transferrable, without prejudice to the call option of the common shareholders of the credit institution for the purchase of the warrants in proportion to their shareholding participation in the credit institution within a reasonable timeframe.

The submission to the special regime of article 27A of Greek law 4172/2013 is optional and is subject to the approval of the general meeting of shareholders of the relevant credit institution, following special recommendation of its Board of Directors. Such resolution shall be notified to the competent tax and regulatory authority. Similarly, the same authorization is required for the Bank to opt out of the special regime of article 27A of Greek law 4172/2013, except that, in this case, a pre-approval by the competent regulatory authority is further required. On November 7, 2014 the Bank convened an extraordinary General Shareholders Meeting which resolved upon the Bank's submission to the DTC Law, the issuance of warrants to the Hellenic Republic and the formation of a special reserve.

As of December 31, 2015, the amount of DTA (recognized in accordance with IFRS) that was eligible for conversion to a receivable from the Greek State subject to the DTC Law was EUR 4.9 billion.

The following information should not be interpreted as an estimate of the fair value of the entire Group. Fair value information 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 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, 2014 and 2015:

Cash, deposits, repos, and other assets: The carrying amount of cash and due from banks, deposits with central bank, securities purchased under agreements to resell, securities sold under agreements to repurchase, interest bearing deposits with banks, and receivables from the Greek State and trade and other receivables included in other assets 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.

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.

Deposits: The fair value for demand deposits and deposits with no specified 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: Except for the long-term debt designated at fair value (see (b) below), fair value is estimated using market prices, or if such are not available, either based on

the prices with which we completed tender offers with respect to these instruments, or using a discounted cash flow analysis, based on current market rates of similar maturity debt securities.

Contingently Convertible debt: The CoCos were issued at par in December 2015, therefore the fair value of the liability approximates its carrying amount as at December 31, 2015.

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, 2014 Restated⁽³⁾	Level 1		Level 2		Level 3		Total assets/ liabilities at fair value
	(EUR in millions)
Assets
Trading assets		126		2,245		15		2,386
Debt securities issued by other governments and public sector entities		55		297		—		352
Greek treasury bills		—		1,799		—		1,799
Foreign treasury bills		61		72		—		133
Debt securities issued by Greek financial institutions		—		1		—		1
Debt securities issued by foreign financial institutions		—		36		15		51
Corporate debt securities issued by Greek companies		—		31		—		31
Corporate debt securities issued by foreign companies		—		9		—		9
Equity securities issued by Greek companies		2		—		—		2
Equity securities issued by foreign companies		5		—		—		5
Mutual fund units		3		—		—		3
Derivative assets		3		4,765		28		4,796
Available-for-sale securities		776		2,283		260		3,319
Greek government bonds		—		501		236		737
Debt securities issued by other governments and public sector entities		512		643		—		1,155
Greek treasury bills		—		169		—		169
Foreign treasury bills		—		269		—		269
Debt securities issued by companies incorporated in Greece		—		401		1		402
Debt securities issued by companies incorporated outside Greece		—		299		23		322
Equity securities issued by companies incorporated in Greece		41		—		—		41
Equity securities issued by companies incorporated outside Greece		18		1		—		19
Mutual Fund units		205		—		—		205
Other assets		266		39		11		316

Total Assets		1,171		9,332		314		10,817



Liabilities
Deposits at fair value⁽²⁾		—		16		—		16
Derivative liabilities		1		5,693		5		5,699
Long-term debt at fair value⁽¹⁾		—		872		—		872
Accounts payable, accrued expenses and other liabilities (Securities short position)		4		—		—		4

Total liabilities		5		6,581		5		6,591

	Fair value measurement using

	Fair value measurement using						Total asset/ liability at fair value
At December 31, 2015	Level 1		Level 2		Level 3		Total asset/ liability at fair value
	(EUR in millions)
Assets
Trading assets		157		2,314		13		2,484
Debt securities issued by other governments and public sector entities		120		269		—		389
Greek treasury bills		—		1,858		—		1,858
Foreign treasury bills		23		62		—		85
Debt securities issued by foreign financial institutions		—		62		13		75
Corporate debt securities issued by Greek companies		—		38		—		38
Corporate debt securities issued by foreign companies		—		20		—		20
Equity securities issued by Greek companies		6		—		—		6
Equity securities issued by foreign companies		—		5		—		5
Mutual fund units		8		—		—		8
Derivative assets		1		3,883		11		3,895
Available-for-sale securities		903		4,999		325		6,227
Greek government bonds		—		561		271		832
Debt securities issued by other governments and public sector entities		543		3,388		—		3,931
Greek treasury bills		—		470		—		470
Foreign treasury bills		8		221		—		229
Debt securities issued by companies incorporated in Greece		—		139		—		139
Debt securities issued by companies incorporated outside Greece		—		200		23		223
Equity securities issued by companies incorporated in Greece		57		3		—		60
Equity securities issued by companies incorporated outside Greece		8		17		31		56
Mutual Fund units		287		—		—		287
Other assets		205		102		—		307

Total Assets		1,266		11,298		349		12,913



Liabilities
Deposits at fair value⁽²⁾		—		2		—		2
Derivative liabilities		1		4,634		6		4,641
Long-term debt at fair value⁽¹⁾		—		826		—		826

Total Liabilities		1		5,462		6		5,469

The tables below, present the fair values for discontinued operations and long-lived assets held for sale and liabilities directly associated with long-lived assets held for sale, measured at fair value on a recurring basis

	Fair value measurement using

	Fair value measurement using						Total assets/ liabilities at fair value
At December 31, 2014	Level 1		Level 2		Level 3		Total assets/ liabilities at fair value
	(EUR in millions)
Assets
Trading assets		17		2		—		19
Debt securities issued by other governments and public sector entities		12		—		—		12
Debt securities issued by foreign financial institutions		2		2		—		4
Equity securities issued by foreign companies		2		—		—		2
Mutual fund units		1		—		—		1
Derivative assets		—		1,146		—		1,146
Available-for-sale securities		1,875		9		—		1,884
Debt securities issued by other governments and public sector entities		1,865		—		—		1,865
Debt securities issued by companies incorporated outside Greece				9		—		9
Mutual Fund units		10		—		—		10
Net loans⁽¹⁾		—		—		42		42

Total Assets		1,892		1,157		42		3,091



Liabilities
Derivative liabilities				564				564

Total liabilities		—		564		—		564

	Fair value measurement using

	Fair value measurement using						Total asset/ liability at fair value
At December 31, 2015	Level 1		Level 2		Level 3		Total asset/ liability at fair value
	(EUR in millions)
Assets
Trading assets		25		1		—		26
Debt securities issued by other governments and public sector entities		21		—		—		21
Debt securities issued by foreign financial institutions		—		1		—		1
Mutual fund units		4		—		—		4
Derivative assets		—		1,723		—		1,723
Available-for-sale securities		1,624		10		41		1,675
Debt securities issued by other governments and public sector entities		1,624		—		—		1,624
Debt securities issued by companies incorporated outside Greece				10				10

Equity Securities issued by companies incorporated outside Greece:		—		—		41		41
Net Loans⁽¹⁾		—		—		18		18

Total Assets		1,649		1,734		59		3,442



Liabilities
Derivative liabilities		—		768		—		768

Total Liabilities		—		768				768

The Group has various processes in place to ensure that the fair values of its assets and liabilities are reasonably estimated and has established a control framework which is designed to ensure that fair values are validated by functions independent of the risk-taker. To that end, the Group utilizes various sources for determining the fair values of its financial instruments and uses its own independent functions to validate these results where possible.

Fair values of debt securities are determined either by reference to prices for traded instruments in active markets, to external quotations or widely accepted financial models, which are based on market observable or unobservable information where the former is not available, as well as relevant market-based parameters such as interest rates, option volatilities, currency rates etc.

The Group may, sometimes, also utilize third-party pricing information and perform validating procedures on this information or base its fair value on the latest transaction prices available, given the

absence of an active market or similar transactions. All such instruments are categorized within the lowest level of fair value hierarchy (i.e Level 3).

Generally, fair values of debt securities, including significant inputs on the valuation models are independently checked and validated by the Middle Office and Risk Management function on a systematic basis.

Fair values of derivatives are determined by management using valuation models which include discounted cash-flow models, option pricing models or other appropriate models. Adequate control procedures are in place for the validation of these models, including the valuation inputs, on a systematic basis. Risk Management function and Middle Office department provide the control valuation framework necessary to ensure that the fair values are reasonably determined, reflecting current market circumstances and economic conditions. Furthermore, over-the-counter derivatives are also compared on a daily basis with counterparties' valuations, under the daily collateral management process.

Counterparty credit risk-adjustments are applied to all over-the-counter derivatives. Own credit-risk adjustments are applied to reflect the Group's own credit risk when valuing derivatives. Bilateral credit-risk adjustments consider the expected cash flows between the Group and its counterparties under the relevant terms of the derivative instruments and the effect of the credit-risk profile of the counterparties on the valuation of these cashflows. Where appropriate, we take into consideration the credit-risk mitigating arrangements including collateral agreements and master netting arrangements into estimating own and counterparty credit risk valuation adjustments.

The fair value of trading assets and available-for-sale 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.

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 is 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.

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, 2014 and 2015 including realized and unrealized gains/(losses) included in earnings and OCI.

	2014

	Balance at beginning of year		Gain/(losses) included in earnings			Gain/(losses) included in OCI			Purchases		Sales			Settlements			Transfer into level 3		Transfer out of level 3		Balance at end of year
	(EUR in millions)
Trading assets		24		18			—			—		—			(27	)		—		—		15
Debt securities issued by foreign financial institutions		24		18			—			—		—			(27	)		—		—		15
Net Derivatives		17		(10	)		—			4		—			—			12		—		23
Available-for-sale securities		280		3			(31	)		14		(6	)		—			—		—		260
Greek government bonds		266		1			(31	)		—		—			—			—		—		236
Debt securities issued by companies incorporated in Greece		7		—			—			—		(6	)		—			—		—		1
Debt securities issued by companies incorporated outside Greece		7		2			—			14		—			—			—		—		23
Other assets		11		—			—			—		—			—			—		—		11

	2015

	Balance at beginning of year		Gain/(losses) included in earnings			Gain/(losses) included in OCI		Purchases		Sales		Settlements			Transfer into level 3		Transfer out of level 3			Balance at end of year
Trading assets		15		(1	)		—		—		—		(1	)		—		—			13
Debt securities issued by foreign financial institutions		15		(1	)		—		—		—		(1	)		—		—			13
Net Derivatives		23		(10	)		—		1		—		2			11		(22	)		5
Available-for-sale securities		260		(9	)		44		—		—		(1	)		31		—			325
Greek government bonds		236		(9	)		44		—		—		—			—		—			271
Debt securities issued by companies incorporated in Greece		1		—			—		—		—		(1	)		—		—			—
Debt securities issued by companies incorporated outside Greece		23		—			—		—		—		—			—		—			23
Equity securities issued by companies incorporated outside Greece		—		—			—		—		—		—			31		—			31
Other assets		11		—			—		—		—		(11	)		—		—			—

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 1 million for the year ended December 31, 2014 and to EUR (9) million for the year ended December 31, 2015 which is reported in Net interest income before provision for loan losses.

For the year ended December 31, 2015, changes in unrealized gains/(losses) of Level 3 financial instruments still held at the reporting date amounted to EUR (1) million and EUR (1) million for trading assets and net derivatives respectively.

For the year ended December 31, 2014, changes in unrealized gains/(losses) of Level 3 financial instruments still held at the reporting date amounted to (1) and EUR (1) million for trading assets and net derivatives respectively.

Other transfers from Level 2 into Level 3, during 2014 and 2015, include derivative instruments for which the bilateral CVA adjustment is significant to the base fair value of the respective instruments.

						Range of Inputs

				Valuation Technique	Significant Unobservable Input	Range of Inputs
Financial Instrument	Fair Value			Valuation Technique	Significant Unobservable Input	Low	High
	(EUR in millions)
ASSETS
*Debt Securities*
Trading debt securities issued by foreign financial institutions		15		Price Based	Price	28.90	103.01
Available-for-sale Greek Government bonds		236		Discounted Cash Flows	Credit Spread over 30 years	612 bps	612 bps
Available-for-sale debt securities issued by companies incorporated in Greece		1		Price Based	Price	100.5	100.5
Available-for-sale debt securities issued by companies incorporated outside Greece		23		Price based	Price	77.2	100.4
				Collateral Based	Factor of Collateral Realization	42.0%	65.0%
Net Derivatives
Interest Rate Swaps		18		Discounted Cash Flows—Internal Model for CVA/DVA	Credit Spread	80 bps	1000 bps
		4		Discounted Cash Flows	Constant Maturity Swap correlation between different tenors (eg 2yr 10 yr)	0.68	0.95
Credit Derivative		(4	)	Internal Model	Expected Loss Rate	1.3%	1.3%
Other Derivatives		4		Market Standard Black Scholes Model	FX pair correlation	–0.37	0.89
		1		Discounted Cash Flows—Internal Model for CVA/DVA	Credit Spread	80 bps	1000 bps
Other assets		11		Price Based	Price	100.3	100.3

					Range of Inputs

			Valuation Technique	Significant Unobservable Input	Range of Inputs
Financial Instrument	Fair Value		Valuation Technique	Significant Unobservable Input	Low	High
	(EUR in millions)
ASSETS
*Debt Securities*
Trading debt securities issued by foreign financial institutions		13	Price Based	Price	23.51	100.87
Available-for-sale Greek Government bonds		271	Discounted Cash Flows	Credit Spread over 30 years	556 bps	556 bps
Available-for-sale Corporate debt securities issued by companies incorporated outside Greece		23	Price Based	Price	93.76%	100.37%
			Collateral Based	Factor of Collateral Realization	42.00%	65.00%
Equity securities issued by companies incorporated outside Greece		31	Agreed Buyout Consideration	Share of proceeds calculation	n/a	n/a
Net Derivatives
Interest Rate Swaps		7	Discounted Cash Flows—Internal Model for CVA/DVA	Credit Spread	1000 bps	1000 bps
		1	Discounted Cash Flows	Constant Maturity Swap correlation between different tenors (eg 2yr 10 yr)	67.79%	90.00%
		3	Discounted Cash Flows	FX pair correlation	–50.00%	94.64%
Credit Derivative		–2	Internal Model	Expected Loss Rate	0.75%	0.75%
Other Derivatives		–4	Discounted Cash Flows—Internal Model for CVA/DVA	Credit Spread	322 bps	505 bps

For structured interest rate derivatives a significant change in the correlation inputs (e.g. the degree of correlation between two different interest rates, or between interest rates and foreign exchange rates) would result in a significant impact to the fair value of the individual instrument; however the magnitude and the direction of the impact depends, among other factors, on whether the Group's exposure is long or short. Due to the limited exposure of the Group to these instruments a reasonable change in the above unobservable inputs would not be significant to the Group. Additionally, interest rate derivatives include interest rate swaps for which the bilateral credit risk adjustment is significant in comparison to the fair value. The counterparty credit-risk adjustment in these cases is mainly driven by the internal ratings of the counterparty. A reasonable increase in the credit spread of these entities would result in an insignificant change in the fair value of the Group's financial instruments.

Within Other Derivatives are derivatives whose valuation is dependent on an FX pair correlation or on the volatility of an index. A reasonable increase in the correlation or the volatility of the index would not result in a material change in the financial instruments fair value for the Group.

For Credit Derivatives the calculated fair value includes estimated expected loss rates as significant unobservable input. A reasonable increase in this input would result in an insignificant fair value change for the Group.

The available-for-sale portfolio consists of a Greek Government debt security for which the credit spread up to its maturity is not market observable. A reasonable increase in the credit spread of the Hellenic Republic would result in a significantly lower market value for this financial instrument (see Note 11).

Financial assets and liabilities are offset and the net amount is reported in the balance sheet only if the Group holds a legally enforceable right to set-off the recognized amounts and there is an intention to settle on a net basis or realize the asset and settle the liability simultaneously. The Group uses master netting agreements to mitigate counterparty credit risk in certain transactions, including derivative contracts, repurchase and reverse repurchase agreements, and securities borrowed and loaned agreements. A master netting agreement is a single contract with a counterparty that permits multiple transactions governed by that contract to be terminated and settled through a single payment in a single currency in the event of a default (such as bankruptcy, failure to make a required payment or securities transfer or deliver collateral or margin when due after expiration of any grace period).

The following table provides information on the impact of offsetting on the balance sheet of the Group, as at December 31, 2014 and 2015, as well as the financial impact of netting of instruments subject to an enforceable master netting arrangement or similar agreement as well as available cash and financial instrument collateral.

	December 31, 2014									December 31, 2015

	Derivative instruments⁽¹⁾			Reverse repurchase agreements and securities lending transactions			Total			Derivative instruments⁽¹⁾			Reverse repurchase agreements and securities lending transactions			Total
Gross amounts of recognised financial assets		4,746			24			4,770			3,876			6			3,882
Gross amounts of recognised financial liabilities set off in the balance sheet		—			—			—			—			—			—

Net amounts of financial assets presented in the balance sheet		4,746			24			4,770			3,876			6			3,882
Related amounts not set off in the balance sheet
Financial instruments		(949	)		(24	)		(973	)		(2,108	)		(6	)		(2,114	)
Cash collateral received		(745	)		—			(745	)		(513	)		—			(513	)

Net amount		3,052			—			3,052			1,255			—			1,255

	December 31, 2014									December 31, 2015

	Derivative instruments⁽¹⁾			Repurchase agreements and securities borrowing transactions⁽²⁾			Total			Derivative instruments⁽¹⁾			Repurchase agreements and securities borrowing transactions⁽²⁾			Total
Gross amounts of recognised financial liabilities		5,704			3,590			9,294			4,623			101			4,724
Gross amounts of recognised financial assets set off in the balance sheet		—			—			—			—			—			—

Net amounts of financial liabilities presented in the balance sheet		5,704			3,590			9,294			4,623			101			4,724
Related amounts not set off in the balance sheet
Financial instruments		(1,430	)		(3,590	)		(5,020	)		(1,296	)		(100	)		(1,396	)
Cash collateral pledged		(1,218	)		—			(1,218	)		(995	)		—			(995	)

Net amount		3,056			—			3,056			2,332			1			2,333

In order to (a) manage more effectively delinquent, non-performing and denounced loans to legal entities, and (b) ensure compliance with the provisions of Bank of Greece Executive Committee Act 42/30.5.2014 and Act 47/9.2.2015 and the Code of Conduct (referred to in Article 1(2) of Greek Law 4224/2013, the Bank established a Special Assets Unit ("SAU").

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.

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.

12-month period ended December 31, 2013⁽²⁾	Retail Banking

	(EUR in millions)
Net interest income		619		696		—	(101	)	84		299		1,299		261		3,157
Net fee and commission income / (loss)		75		90		—	(140	)	7		90		401		6		529
Other		—		(46	)	—	28		102		15		44		(58	)	85

Total operating income / (loss)		694		740		—	(213	)	193		404		1,744		209		3,771

Direct costs		(569	)	(50	)	—	(55	)	(98	)	(260	)	(859	)	(286	)	(2,177	)
Allocated costs and provisions		(1,114	)	(421	)	—	528		14		(117	)	(338	)	(320	)	(1,768	)
Share of profit of equity method investments		—		—			(4	)	1		1		(3	)	—		(5	)

Profit / (loss) before tax		(989	)	269		—	256		110		28		544		(397	)	(179	)



Segment assets as at December 31, 2013
Segment assets		24,901		14,115		—	16,048		3,365		9,505		23,373		16,768		108,075
Deferred tax assets and Current income tax advance																	2,855

Total assets																	110,930
IFRS to U.S. GAAP differences																	(4,153	)

U.S. GAAP total assets																	106,777



Other Segment items
Depreciation & amortization⁽¹⁾		17		3		—	2		8		27		67		102		226
Credit provisions and other impairment charges		796		375		—	(548	)	(17	)	114		339		314		1,373
Non-current assets additions		4		27		—	—		3		22		102		54		212

12-month period ended December 31, 2014	Retail Banking

	(EUR in millions)
Net interest income		573		743		—	189		55		319		—	119		1,998
Net fee and commission income / (loss)		72		98		—	(125	)	5		93		—	(4	)	139
Other		23		(63	)	—	(105	)	103		14		—	(45	)	(73	)

Total operating income / (loss)		668		778		—	(41	)	163		426		—	70		2,064

Direct costs		(456	)	(47	)	—	(50	)	(90	)	(253	)	—	(52	)	(948	)
Allocated costs and provisions		(1,569	)	(755	)	—	(66	)	(9	)	(128	)	—	(405	)	(2,932	)
Share of profit of equity method investments		—		—			(2	)	1		1		—	1		1

Profit / (loss) before tax		(1,357	)	(24	)	—	(159	)	65		46		—	(386	)	(1,815	)



Segment assets as at December 31, 2014
Segment assets		22,227		12,177		2,587	11,261		2,613		9,427		27,220	23,154		110,666
Deferred tax assets and Current income tax advance																4,546

Total assets																115,212
IFRS to U.S. GAAP differences																(7,051	)

U.S. GAAP total assets																108,161



Other Segment items
Depreciation & amortization⁽¹⁾		14		3		—	1		8		24		—	79		129
Credit provisions and other impairment charges		1,287		694		—	—		59		127		—	356		2,523
Non-current assets additions		5		13		—	32		4		37		418	340		849

12-month period ended December 31, 2015	Retail Banking

	(EUR in millions)
Net interest income		521		601		176		101		45		332		—	129		1,905
Net fee and commission income / (loss)		81		83		7		(175	)	4		95		—	(2	)	93
Other		10		(13	)	(12	)	(72	)	80		14		—	(33	)	(26	)

Total operating income / (loss)		612		671		171		(146	)	129		441		—	94		1,972

Direct costs		(436	)	(47	)	(9	)	(46	)	(83	)	(259	)	—	(42	)	(922	)
Allocated costs and provisions		(1,829	)	(1,106	)	(848	)	(127	)	(28	)	(167	)	—	(537	)	(4,642	)
Share of profit of equity method investments		—		—		—		1		1		1		—	—		3

Profit / (loss) before tax		(1,653	)	(482	)	(686	)	(318	)	19		16		—	(485	)	(3,589	)



Segment assets as at December 31, 2015
Segment assets		19,972		11,684		1,824		13,000		2,756		9,557		—	18,997		77,790
Deferred tax assets and Current income tax advance																	5,675
Non-current assets held for sale																	27,767

Total assets																	111,232
IFRS to U.S. GAAP differences																	(11,300	)

U.S. GAAP total assets																	99,932



Other Segment items
Depreciation & amortization⁽¹⁾		10		3		—		1		9		21		—	77		121
Credit provisions and other impairment charges		1,548		1,069		826		(10	)	34		155		—	641		4,263
Non-current assets additions		7		9		—		4		5		20		—	134		179

Presentation of SAU segment incorporated into the retail and corporate business segments

12-month period ended December 31, 2015	Retail Banking

	(EUR in millions)
Net interest income		559		739		—	101		45		332		—	129		1,905
Net fee and commission income / (loss)		82		89		—	(175	)	4		95		—	(2	)	93
Other		5		(20	)	—	(72	)	80		14		—	(33	)	(26	)

Total operating income / (loss)		646		808		—	(146	)	129		441		—	94		1,972

Direct costs		(440	)	(52	)	—	(46	)	(83	)	(259	)	—	(42	)	(922	)
Allocated costs and provisions		(2,022	)	(1,761	)	—	(127	)	(28	)	(167	)	—	(537	)	(4,642	)
Share of profit of equity method investments		—		—		—	1		1		1		—	—		3

Profit / (loss) before tax		(1,816	)	(1,005	)		(318	)	19		16		—	(485	)	(3,589	)



Segment assets as at December 31, 2015
Segment assets		20,453		13,027		—	13,000		2,756		9,557		—	18,997		77,790
Deferred tax assets and Current income tax advance																5,675
Non-current assets held for sale																27,767

Total assets																111,232
IFRS to U.S. GAAP differences																(11,300	)

U.S. GAAP total assets																99,932



Other Segment items
Depreciation & amortization⁽¹⁾		10		3		—	1		9		21		—	77		121
Credit provisions and other impairment charges		1,734		1,709		—	(10	)	34		155		—	641		4,263
Non-current assets additions		7		9		—	4		5		20		—	134		179

Reconciliation of Loss before tax per IFRS reported for the segments to Income / (loss) before income tax per US GAAP

Breakdown of total assets, total revenue, income / (loss) before income tax and net income/ (loss) attributable to NBG shareholders by geographical location

	Total assets

	(EUR in millions)
12-month period ended December 31, 2013
Domestic		72,477	3,349	(579	)	(623	)
Other International		9,322	672	20		12
Turkish operations (Discontinued)		24,978	—	—		648

Group		106,777	4,021	(559	)	37



12-month period ended December 31, 2014
Domestic		69,876	1,997	(2,537	)	(2,624	)
Other International		9,103	643	(42	)	(22	)
Turkish operations (Discontinued)		29,183	—	—		169

Group		108,161	2,640	(2,579	)	(2,477	)



12-month period ended December 31, 2015
Domestic		65,751	2,806	(3,357	)	(3,376	)
Other International		9,874	590	55		33
Turkish operations (Discontinued)		24,307	—	—		(5,121	)

Group		99,932	3,396	(3,302	)	(8,464	)

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 26 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% on the basis of an employee's gross salary 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 a special financial report commissioned by the Ministry of Finance pursuant to this legislation.

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 singe auxiliary social security fund ("ETEAM"). The Bank pays its contributions to ETEAM since May 1, 2007.

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 ETEA in relation to this merger.

As for the Bank's main pension plan, following legislation passed in April 2008, the post-retirement 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% from 20.0%. 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 Finansbank, UBB, SABA, NBG Asset Management Mutual Funds, EH, NBGI Private Equity Ltd, NBGI Private Equity Funds and NBG Cyprus, 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 2014 and 2015 were EUR 271 million and EUR 223 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.

Up to 2013, the Bank did not contribute to the aforementioned plan. Following the amendment of the aforementioned plan's regulation, from January 1, 2014 the Bank pays contribution of 2% only for the active employees as of December 31, 2013.

Most 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 payment 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.

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.

Prior to the enactment of the above Law, the Bank considered the employment contracts with its employees as finite duration contracts therefore no provision for staff leaving indemnity was

recognized. As a result the Group concluded that based on the available evidence the obligation for the remaining population of employees under the finite employment contracts is both probable and the amount of the obligation is reasonably estimable under the provisions of Greek Law 2112/1920 based on an actuarial valuation carried out in accordance with ASC 715-30.

On November 12, 2012, the new Greek Law 4093/2012 (GG A' 222) decreased the Greek Law 2112/1920 statutory indemnity scale in case of employee dismissal or normal retirement. The new law restricts the maximum indemnity payable to an employee upon dismissal or retirement, to 12 monthly salaries instead of 24.

The transitional provisions of the law state that for employees who on November 12, 2012 had 17 or more full years of service to the same employer there is an additional monthly salary as indemnity per year and up to 24 monthly salaries. In case of dismissal the additional monthly salary is restricted to EUR 2,000.

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.

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 costs for these defined benefit plans and termination indemnities includes the following components which are recognized in the income statement for the periods ended:

In 2014, losses / (income) on curtailments / settlements and other expense / (income) includes mainly the additional cost of extra benefits in excess of the benefits provided of EUR 5 million from EH VRS that took place in the third quarter of 2014, while income of EUR 4 million relates to the Bank's VRS actual benefits paid adjustment.

In 2013, losses / (income) on curtailments / settlements and other expense / (income) mainly include the cost of the voluntary retirement scheme for the Bank's employees. More specifically, on December 19, 2013, the Bank announced to its employees terms of the VRS. The deadline for employee applications to participate in the VRS was December 30, 2013. Approximately 2,500 employees participated in the VRS and the total expense amounted to EUR 178 million. By taking into account the unpaid leave for these employees, the total voluntary retirement expense amounted to EUR 183 million.

Weighted average assumptions used to determine the net periodic pension cost for the years ended December 31:

The aggregated funding status recognized in the consolidated balance sheet is reconciled below as follows for the years ended December 31:

	2013

	(EUR in millions)
Change in Projected Benefit obligation ("PBO"):
PBO, beginning of year		419		564		354
Service cost		7		8		9
Interest cost		13		11		7
Employee contributions		4		3		3
Actuarial loss/(gain)		(38	)	60		(22	)
Adjustment for disposal and other		(1	)	1		1
Benefits paid from the Fund		(21	)	(24	)	(9	)
Benefits paid directly by the Group		(7	)	(272	)	(3	)
Settlements/Terminations/Curtailments		188		2		1
Prior service cost arising over last period		—		1		—

PBO, end of year		564		354		341

In 2014, the Bank paid benefits of EUR 258 million for indemnities as part of the VRS for the Bank's employees that took place in 2013.

Employer contributions paid by the Group, are in excess of the EUR 8 million total expected contributions for funded plans for 2015.

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:

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 2016 are NIL of prior service cost and EUR 10 million of net actuarial loss.

The following table indicates actual and targeted plan asset allocation for the Group's funded defined benefit pension plans:

Other relates mainly to assets of Deposit administration fund ("DAF") policies issued by the Group's main insurance company EH. DAF 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, excluding Finansbank S.A., are as follows:

In 2016, the Group is expected to make EUR 9 million in contributions to funded plans and pay EUR 38 million in retirement indemnities.

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 5.00 per share 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.

NOTE 42: ACCUMULATED OTHER COMPREHENSIVE INCOME ATTRIBUTABLE TO NBG SHAREHOLDERS

The components of accumulated other comprehensive income attributable to NBG shareholders, net of taxes, comprise:

	Foreign Currency Items

	(EUR in millions)
Balance, January 1, 2013		(1,394	)	248		(137	)	(1,283	)
Other comprehensive income before reclassifications		(1,285	)	(1	)	(155	)	(1,441	)
Amounts reclassified from accumulated other comprehensive income		—		(63	)	191		128

Net current-period other comprehensive income		(1,285	)	(64	)	36		(1,313	)

Balance, December 31, 2013		(2,679	)	184		(101	)	(2,596	)
Other comprehensive income before reclassifications		174		9		(54	)	129
Amounts reclassified from accumulated other comprehensive income		—		(91	)	11		(80	)

Net current-period other comprehensive income		174		(82	)	(43	)	49

Balance, December 31, 2014		(2,505	)	102		(144	)	(2,547	)
Other comprehensive income before reclassifications		(603	)	108		23		(472	)
Amounts reclassified from accumulated other comprehensive income		—		17		8		25

Net current-period other comprehensive income		(603	)	125		31		(447	)

Balance, December 31, 2015		(3,108	)	227		(113	)	(2,994	)

NOTE 42: ACCUMULATED OTHER COMPREHENSIVE INCOME ATTRIBUTABLE TO NBG SHAREHOLDERS (Continued)

Reclassifications out of accumulated other comprehensive income attributable to NBG shareholders for the period ended December 31, 2013

Details about Accumulated Other Comprehensive Income Components	Amount reclassified from Accumulated Other Comprehensive Income			Affected Line in the Statement Where Net Income is Presented

	(EUR in millions)
Unrealised gains and losses on available-for-sale securities		250		Net realised gains / (losses) on sale of available-for-sale securities
		(195	)	Other-Than-Temporary-Impairment

		55		Total before tax
		12		Income tax benefit

		67		Net of tax



Amortization of defined benefit pension items
Prior service costs		(178	)
Actuarial loss		(13	)

		(191	)	Total before tax

		(191	)	Net of tax



Income / (loss) from discontinued operations		(4	)



Total reclassifications for the period		(128	)

NOTE 42: ACCUMULATED OTHER COMPREHENSIVE INCOME ATTRIBUTABLE TO NBG SHAREHOLDERS (Continued)

Reclassifications out of accumulated other comprehensive income for the period ended December 31, 2014

Details about Accumulated Other Comprehensive Income Components	Amount reclassified from Accumulated Other Comprehensive Income			Affected Line in the Statement Where Net Income is Presented

	(EUR in millions)
Unrealised gains and losses on available-for-sale securities		23		Interest income: Securities available-for-sale
		96		Net realised gains / (losses) on sale of available-for- sale securities
		(6	)	Other-Than-Temporary-Impairment

		113		Total before tax
		(26	)	Income tax expense

		87		Net of tax



Amortization of defined benefit pension items
Prior service costs		(1	)
Actuarial loss		(10	)

		(11	)	Total before tax

		(11	)	Net of tax



Income / (loss) from discontinued operations		4



Total reclassifications for the period		80

NOTE 42: ACCUMULATED OTHER COMPREHENSIVE INCOME ATTRIBUTABLE TO NBG SHAREHOLDERS (Continued)

Reclassifications out of accumulated other comprehensive income for the period ended December 31, 2015

Details about Accumulated Other Comprehensive Income Components	Amount reclassified from Accumulated Other Comprehensive Income			Affected Line in the Statement Where Net Income is Presented

	(EUR in millions)
Unrealised gains and losses on available-for-sale securities		3		Interest income: Securities available-for-sale
		2		Net realised gains / (losses) on sale of available-for- sale securities
		(36	)	Other-Than-Temporary-Impairment

		(31	)	Total before tax
		8		Income tax benefit

		(23	)	Net of tax



Amortization of defined benefit pension items
Actuarial loss		(12	)

		(12	)	Total before tax
		3		Income tax benefit

		(9	)	Net of tax



Income / (loss) from discontinued operations		7



Total reclassifications for the period		(25	)

At December 31, 2015, the EUR equivalent of the assets and liabilities, which are denominated in foreign currency, amounted to EUR 8,540 million (EUR 8,800 million for 2014 and EUR 8,248 million for 2013) and EUR 7,489 million (EUR 8,632 million for 2014 and EUR 8,639 million for 2013), respectively.

During the current period the Group identified that certain intra-group balances recognized in the Group's consolidated financial statements for the year ended 31 December 2014 were not fully eliminated. These balances relate to deposits placed by the insurance subsidiary with the Bank and are presented within "insurance related assets" grouped in "other assets" line item and in "liabilities relating to unit linked investment products" grouped in "accounts payable accrued expenses and other liabilities account" line item of the Group's statement of financial position. The Group's consolidated

financial statements for the year ended 31 December 2014 were restated to correct this error as follows:

Greek Law 4370/2016 was voted by the Greek Parliament on March 7, 2016, which incorporates into Greek Law Directive 2014/49/EU of April 16, 2014 governing deposit guarantee schemes and replaces the provisions of Law 3746/2009. The new Law retains the coverage limit of EUR 100 thousand per depositor per institution and the target level of the available funds held by HDIGF's Deposit Leg is set to at least 0.8% of guaranteed deposits by July 3, 2024.

As of January 1, 2016 Law 4364/2016 on insurance undertakings is in force (published in the Government Gazette on February 5, 2016). The new Law replaces the previous Law 400/1970 on insurance undertakings and brings into force the requirements of the Solvency II Directive 2009/138/EC.

The Bank, from April 14, 2016 until May 13, 2016, sold to members of the Eurosystem EFSF bonds of nominal amount EUR 915 million, which were classified as held-to-maturity at December 31, 2015 (see Note 11).


(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, 2015
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

		Page

B.	Memorandum and Articles of Association	288
C.	Material Contracts	293
D.	Exchange Controls	294
E.	U.S. Federal Income Taxation	294
F.	Dividends and Paying Agents	299
G.	Statements by Experts	299
H.	Documents on Display	299
I.	Subsidiary Information	299
Item 11	QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK	299
Item 12	DESCRIPTION OF SECURITIES OTHER THAN EQUITY SECURITIES	307
PART II		309
Item 13	DEFAULTS, DIVIDEND ARREARAGES AND DELINQUENCIES	309
Item 14	MATERIAL MODIFICATIONS TO THE RIGHTS OF SECURITY HOLDERS AND USE OF PROCEEDS	309
A.	General Effect of the Modifications on the Rights of Security Holders	309
Item 15	CONTROLS AND PROCEDURES	310
(a)	Disclosure Controls and Procedures	310
(b)	Management's Annual Report on Internal Control over Financial Reporting	311
(c)	Report of Independent Registered Public Accounting Firm	313
(d)	Changes in Internal Control over Financial Reporting	316
Item 16A	AUDIT COMMITTEE FINANCIAL EXPERT	317
Item 16B	CODE OF ETHICS	317
Item 16C	PRINCIPAL ACCOUNTANT FEES AND SERVICES	318
Item 16D	EXEMPTIONS FROM THE LISTING STANDARDS FOR AUDIT COMMITTEES	319
Item 16E	PURCHASES OF EQUITY SECURITIES BY THE ISSUER AND AFFILIATED PURCHASERS	319
Item 16F	CHANGE IN REGISTRANT'S CERTIFYING ACCOUNTANT	319
Item 16G	CORPORATE GOVERNANCE	320
Item 16H	MINE SAFETY DISCLOSURE	320
PART III		321
Item 17	FINANCIAL STATEMENTS	321
Item 18	FINANCIAL STATEMENTS	321
Item 19	EXHIBITS	321
CONSOLIDATED FINANCIAL STATEMENTS AS OF DECEMBER 31, 2014 AND 2015 AND FOR THE YEARS ENDED DECEMBER 31, 2013, 2014 AND 2015		F-1
INDEX TO FINANCIAL STATEMENTS		F-2
REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM		F-3
Consolidated Balance Sheets		F-6
Consolidated Statements of Income and Comprehensive Income		F-7
Consolidated Statements of Shareholders' Equity		F-9
Consolidated Statements of Cash Flows		F-11
Notes to Consolidated Financial Statements		F-13

	Euro

Month	High		Low
November 2015		0.9468		0.9069
December 2015		0.9458		0.9070
January 2016		0.9308		0.9121
February 2016		0.9201		0.8801
March 2016		0.9221		0.8780
April 2016		0.8898		0.8740

Annual Period		US$1.00= Euro

2011			0.7178
2012			0.7777
2013			0.7530
2014			0.7520
2015			0.9012
2016 (up to April 2016)			0.8998

	Greek Banking

	Loans		Deposits
	Amount		Amount
	(EUR in millions)
Commercial and Retail⁽¹⁾		42,596		33,287
Public Sector		5,218		2,989


		UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 20-F

		Page

Introduction		1
PART I		5
Item 1	IDENTITY OF DIRECTORS, SENIOR MANAGEMENT AND ADVISERS	5
Item 2	OFFER STATISTICS AND EXPECTED TIMETABLE	5
Item 3	KEY INFORMATION	5
A.	Selected Financial Data	5
B.	Capitalization and Indebtedness	11
C.	Reasons for the Offer and Use of Proceeds	11
D.	Risk Factors	11
Item 4	INFORMATION ON THE COMPANY	48
A.	History and Development of the Company	48
B.	Business Overview	58
C.	Organizational Structure	132
D.	Property, Plant and Equipment	134
E.	Selected Statistical Data	134
Item 4A	UNRESOLVED STAFF COMMENTS	167
Item 5	OPERATING AND FINANCIAL REVIEW AND PROSPECTS	168
A.	Operating Results	186
B.	Liquidity and Capital Resources	204
C.	Research and Development, Patents and Licenses	224
D.	Trend Information	225
E.	Off-balance Sheet Arrangements	239
F.	Tabular Disclosure of Contractual Obligations	240
G.	Safe Harbor	240
Item 6	DIRECTORS, SENIOR MANAGEMENT AND EMPLOYEES	240
A.	Board of Directors and Senior Management	240
B.	Compensation	258
C.	Board Practices	259
D.	Employees	272
E.	Share Ownership	275
Item 7	MAJOR SHAREHOLDERS AND RELATED PARTY TRANSACTIONS	276
A.	Major Shareholders	276
B.	Related Party Transactions	277
C.	Interests of Experts and Counsel	277
Item 8	FINANCIAL INFORMATION	277
A.	Consolidated Statements and Other Financial Information	277
B.	Significant Changes	280
Item 9	THE OFFER AND LISTING	280
A.	Offer and Listing Details	280
B.	Plan of Distribution	283
C.	Markets	283
D.	Selling Shareholders	287
E.	Dilution	287
F.	Expenses of the Issue	288
Item 10	ADDITIONAL INFORMATION	288
A.	Share Capital	288

	Year ended December 31,

Type of Capital Expenditure	2013			2014			2015
	Continuing Operations
	(EUR in millions)
Interests in other companies		17	⁽¹⁾		4	⁽¹⁾		8	⁽¹⁾
Information technology and other electronic equipment		30			43			32
Land and buildings		256	⁽²⁾		409	⁽⁴⁾		112	⁽⁵⁾
Leasehold improvements		5			6			4
Furniture, fixtures, machinery and vehicles⁽³⁾		47			80			22

Total		355			542			178

	Year ended December 31,

Type of Divestiture	2013		2014		2015
	(EUR in millions)
Investments⁽¹⁾		19		—		—
Real estate⁽²⁾		1		18		—

	As at December 31,

	2014			2015
Mortgage lending (balances)		26.2	%		26.1	%
Consumer loans and credit cards (balances)		21.7	%		21.6	%
Core deposits⁽¹⁾		32.9	%		32.3	%

	EUR		USD⁽¹⁾

	(in millions)		(in millions)
Total Assets		452		517
Net Loans		282		323
Total Deposits		185		212
Net Income		6		7

	Sovereign		Financial Institutions								Corporate Institutions								Retail

Country	Bonds		Money market placements		Bonds		Letters of credit		Letters of guarantee		Bonds		Loans		Letters of credit		Letters of guarantee		Loans		Total exposure
	(EUR in millions)
Cyprus		92		38		—		—		1		—		546		81		22		98		878
Romania		211		24		—		—		2		2		215		—		—		—		454
Serbia		92		—		—		—		—		—		28				—		—		120
Albania		38		1		—		—		—		—		—				—		—		39

		433		63		—		—		3		2		789		81		22		98		1,491

Primary Operating Area	Country of incorporation

Fondo Picasso	Italy	—		100.00	%	100.00	%
Egnatia Properties S.A	Romania	—		100.00	%	100.00	%
QUADRATIX LTD	Cyprus	—		100.00	%	100.00	%
NBG International Holdings BV	The Netherlands	100.00	%	—		100.00	%
ARC Management One SRL⁽¹⁾	Romania	—		100.00	%	100.00	%
ARC Management Two EAD⁽¹⁾	Bulgaria	—		100.00	%	100.00	%

	Year ended December 31, 2013

	Modified not TDR								TDRs
	Non- accruing		Accruing, less than 90 dpd		Accruing, more than 90 dpd		Total		Non Accruing, less than 90 days		Non accruing more than 90days		Accruing, less than 90 days		Total
	(EUR in millions)
Residential mortgage		2		279		6		287		1,046		163		553		1,762
Other consumer		2		93		—		95		414		61		66		541
Small business loans		—		4		—		4		223		27		129		379
Other commercial		—		5		—		5		761		94		—		855

Total		4		381		6		391		2,444		345		748		3,537

	Year ended December 31,

Components of allowances for loan losses	2014		2015		2014/2015		Change
	(EUR in millions)						%
Specific allowances		2,330		3,708		1,378		59.1
Coefficient analysis		330		740		410		124.2
Homogeneous analysis		5,128		6,351		1,223		23.8
Foreign loans		1,004		976		–28		(2.8	)

Total loan loss allowances		8,792		11,775		2,983		33.9

	Year ended December 31,

	2011						2012
	Tier I			Total			Tier I			Total
Group		(3.7	)%		(2.6	)%		8.5	%		9.0	%

	Year ended December 31,

	2012 Adjusted⁽¹⁾			2013
Common Equity		7.8	%		10.3	%
Core Tier I		7.8	%		10.3	%
Total		9.2	%		11.2	%

	Year ended December 31,

	2013 Adjusted⁽¹⁾			2014			2015
Common Equity Tier 1		10.5	%		13.5	%		14.5	%
Tier 1		10.5	%		13.5	%		14.5	%
Total		10.6	%		13.6	%		14.6	%

Rating agency	Date of ratings	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	February 19, 2016	Caa3	Not prime	Stable	WR	Caa3	—
Standard & Poor's	December 11, 2015	SD	SD	—	—	CC	—
Fitch	June 29, 2015	RD	RD	—	—	C	C
DBRS	July 7, 2015	D	R-5	—	—	—	—

Description	Issue date	Maturity date		Interest rate	Interest payment

Variable Rate Notes	April 21, 2016	April 21, 2017	3,000	Three-month Euribor plus 900 basis points	Quarterly

Total as at April 30, 2016			3,000

	2014

	(EUR in millions)
Financial instruments whose contract amounts represent credit risk:
Commitments to extend credit:⁽¹⁾
Residential real estate		6	6
Commercial letters of credit		474	224
Standby letters of credit and financial guarantees written		3,598	3,257

Total		4,078	3,487

	Less than 1 year

	(EUR in millions)
Time deposits⁽¹⁾		14,809	469	13	3	15,294
Long-term debt⁽¹⁾		1,010	112	344	269	1,735
Operating lease obligations		32	49	37	35	153
Insurance reserves⁽²⁾		226	330	279	1,259	2,094
Pension liability⁽³⁾		38	27	29	179	273

Total		16,115	987	702	1,745	19,549



Chairman		Petros Sabatacakis (Financial expert)
Member		Dimitrios Afendoulis
Member		Charalampos Makkas (HFSF representative)



Chairman		Spiridon Theodoropoulos**
Member		Louka Katseli*
Member		Dimitrios Afendoulis***
Member		Petros Sabatacakis****
Member		Charalampos Makkas (HFSF representative)



Chairman		Dimitrios Afendoulis**
Member		Louka Katseli*
Member		Petros Sabatacakis**
Member		Spyridon Theodoropoulos***
Member		Charalampos Makkas (HFSF representative)



Chair		Louka Katseli*
Member		Leonidas Fragkiadakis**
Member		Dimitrios Dimopoulos
Member		Paul Mylonas
Member		Spyridon Theodoropoulos
Member		Dimitrios Afendoulis***
Member		Petros Sabatacakis



Chairman	Leonidas Fragkiadakis*	CEO
Deputy Chairman & Member	Paul Mylonas	Deputy CEO
Member	Dimitrios Dimopoulos	Deputy CEO
Member	Nelly Tzakou-Lambropoulou	General Manager of Retail Banking
Member	Ioannis Kyriakopoulos	General Manager, Group CFO
Member	Alexander Benos	Assistant General Manager, NBG Group Risk Management, CRO
Member	Vasileios Kavalos	Assistant General Manager, Group Treasurer



Chairman	Leonidas Fragkiadakis*	CEO
Deputuy Chair & Member	Panagiotis Dasmanoglou	Assistant General Manager—Group Chief Compliance and Corporate Governance Officer
Member	Paul Mylonas	Deputy CEO
Member	Dimitrios Dimopoulos	Deputy CEO
Member	Damianos Charalampidis	Chief of Operations
Member	Nelly Tzakou-Lambropoulou	General Manager of Retail Banking
Member	Dimitrios Kapotopoulos	General Manager of Corporate Banking
Member	Georgios Triantafillakis	Assistant General Manager of Legal Services
Member	Ioanna Katzilieri-Zour	Assistant General Manager of Group Marketing and Communications

Country		Average number of Group employees for the year-ended December 31, 2015⁽¹⁾

Greece			12,108
Bulgaria			2,621
Serbia			1,721
Romania			1,306
FYROM			1,050
Cyprus			337
Albania			303
Egypt			213
South Africa			153
United Kingdom			45
Malta			29

Total			19,886

		Average number of Group employees for the year-ended December 31, 2015

Commercial and retail banking			18,085
Insurance			1,017
Investment banking			162
Asset management			56
Other Group companies			566

Total			19,886

	April 20, 2016

	Number of common shares		Percentage holding
HFSF (with restricted voting rights)		134,820,022		1.5	%
HFSF (with full voting rights)		3,559,869,160		38.9	%
Legal entities and individuals outside of Greece		4,465,735,477		48.8	%
Domestic private investors		957,520,910		10.5	%
Domestic pension funds		21,475,123		0.2	%
Other domestic public sector related legal entities and Church of Greece		7,730,835		0.1	%
Private placement by investors		—		—

Total common shares		9,147,151,527		100.00	%

Year	High (date)	Low (date)

2011	585.88 (on February 9)	110.98 (on November 1)
2012	224.23 (on February 8)	69.08 (on June 5)
2013	138.16 (on May17)	30.60 (on July 4)
2014	63.90 (on January 9)	21.45 (on December 29)
2015	25.20 (on February 24)	0.25 (on December 14)
2016 (up to May 12)	0.33 (on January 4)	0.12 (on February 11)

Quarter	High (date)	Low (date)

Q1 2014	63.90 (on January 9)	47.40 (on January 29)
Q2 2014	61.35 (on April 2)	31.65 (on May 19)
Q3 2014	42.30 (on July 3)	33.15 (on August 8)
Q4 2014	35.10 (on October 1)	21.45 (on December 29)
Q1 2015	25.20 (on February 24)	12.53 (on January 28)
Q2 2015	18.90 (on May 7)	13.20 (on June 19)
Q3 2015	12.60 (on August 3)	5.37 (on August 24)
Q4 2015	11.55 (on October 27)	0.25 (on December 14)

Quarter	High (date)	Low (date)

Q1 2016	0.33 (on January 4)	0.12 (on February 11)
Q2 2016 (up to May 12)	0.31 (on May 12)	0.22 (on April 13)

Month	High (date)	Low (date)

November 2015	10.95 (on November 2)	1.22 (on November 27)
December 2015	1.22 (on December 1)	0.25 (on December 14)
January 2016	0.33 (on January 4)	0.23 (on January 21)
February 2016	0.25 (on February 1)	0.12 (on February 11)
March 2016	0.25 (on March 31)	0.20 (on March 1)
April 2016	0.30 (on April 22)	0.22 (on April 13)
May 2016 (up to May 12)	0.31 (on May 12)	0.27 (on May 4)