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:


Title of each class		Name of each exchange on which registered
American Depositary Shares each representing one Ordinary Share		New York Stock Exchange
Ordinary Shares		New York Stock Exchange*
American Depositary Shares each representing one Series A Non-cumulative Preference Share		New York Stock Exchange
Series A Non-cumulative Preference Shares		New York Stock Exchange*

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

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

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

Number of outstanding shares of each of the Registrant's classes of capital or common stock as at December 31, 2014, the close of the period covered by the annual report:

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

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

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

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

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

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

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

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

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

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

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

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

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

All references in this Annual Report (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, all references to "TRY" or to "TL" are to Turkish lira and all references to "ZAR" are to South African rand.

Solely for convenience, this Annual Report contains translations of certain euro amounts into U.S. dollars at specified rates. These are simply convenience translations and you should not expect that a euro amount actually represents a stated U.S. dollar amount or that it could be converted into U.S. dollars at the rate suggested, or any other rate. In this Annual Report, the translations of euro amounts into U.S. dollars, where indicated, have been made at the noon buying rate for cable transfers of euro into U.S. dollars of US$1.00 = 0.8959, as certified for customs by the Federal Reserve Bank of New York (the "Noon Buying Rate") on Thursday, April 30, 2015. The respective rates for the South African rand, Macedonian dinar, Bulgarian leva, Romanian lei, Serbian dinar and Turkish lira are: South African rand 11.9355 per US$1.00, Macedonian dinars 54.9495 per US$1.00, Bulgarian leva 1.7439 per US$1.00, Romanian lei 3.9396 per US$1.00, Serbian dinars 107.4104 per US$1.00 and Turkish lira 2.6585 per US$1.00. The table below sets out the highest and lowest exchange rate between

the euro and the U.S. dollar, for each of the completed six months preceding the filing of this Annual Report:

The following table sets forth the average exchange rates between the euro and the U.S. dollar and the euro and the Turkish lira for each of the five years ended December 31, 2010, 2011, 2012, 2013 and 2014 and for the current annual period through April 30, 2015. 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.

In February 2015, due to the on-going negotiation between the Greek government and the Institutions towards reaching a permanent agreement, the ECB lifted the waiver on the eligibility as collateral for ECB funding of the Greek government and government guaranteed bonds, until persuasive positive signs that the Greek government will reach an agreement with the Institutions. As a consequence, the Bank was forced to reduce its funding from ECB and restart funding from Emergence Liquidity Assistance Mechanism ("ELA") of the Bank of Greece, which as at April 30, 2015 amounted to EUR 9.6 billion and EUR 15.2 billion respectively. This constitutes an increase in ECB and the Bank of Greece (collectively referred to as the "Eurosystem") exposure compared to the respective figure as at December 31, 2013 (EUR 20.7 billion), caused mainly by the significant outflow of Bank's customer deposits since December 1, 2014 and up to April 30, 2015 of EUR 8.3 billion and the non-renewal of repurchase agreements with other financial and non-financial institutions. Despite the increase of the Eurosystem exposure, the Bank retains a significant buffer of ELA eligible collateral of EUR 12.7 billion (cash value) as at April 30, 2015, of which currently EUR 12.3 billion can only be used to increase ELA funding conditional on ECB approval.

The following information as at, and for the years ended, December 31, 2010 through 2014 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, 2013 and 2014 and for the years ended December 31, 2012, 2013 and 2014 (the "U.S. GAAP Financial Statements") included elsewhere in this Annual Report.

	Year ended December 31,

	2010			2011			2012			2013			2014			2014⁽¹⁾
	EUR			EUR			EUR			EUR			EUR			USD
	(in millions, except per share data)
CONSOLIDATED STATEMENT OF INCOME DATA
Continuing operations
Total interest income		6,149			6,260			5,934			5,177			4,972			5,551
Total interest expense		(2,065	)		(2,612	)		(2,734	)		(2,233	)		(2,142	)		(2,391	)

Net interest income before provision for loan losses		4,084			3,648			3,200			2,944			2,830			3,160
Provision for loan losses		(1,205	)		(3,703	)		(2,322	)		(969	)		(2,172	)		(2,424	)

Net interest income after provision for loan losses		2,879			(55	)		878			1,975			658			736

Non-interest income / (loss)
Credit card fees		189			198			228			207			211			236
Service charges on deposit accounts		53			78			97			102			88			98
Other fees and commissions		476			436			456			493			486			542
Net trading loss		(1,246	)		(1,877	)		(1,366	)		297			(1,365	)		(1,524	)
Equity in earnings of investees and realized gains/(losses) on disposals		9			9			15			6			8			9
Income from insurance operations⁽⁴⁾		1,017			777			633			514			508			567
Other income		144			85			284			290			183			204

Total non-interest income / (loss) excluding gains / losses on investment securities		642			(294	)		347			1,909			119			132

Net gains/(losses) on available-for-sale securities		115			(19	)		350			250			100			112
OTTI of available-for-sale securities and held-to-maturity securities (of which NIL was recognised through AOCI)		(89	)		(9,174	)		(410	)		(285	)		(6	)		(7	)

Net gains / (losses) on investment securities		26			(9,193	)		(60	)		(35	)		94			105

Total non-interest income / (loss)		668			(9,487	)		287			1,874			213			237

	Year ended December 31,

	2010			2011			2012			2013			2014			2014
	EUR			EUR			EUR			EUR			EUR			USD
	(in millions, except per share data)
Non-interest expense
Salaries, employee benefits and voluntary early retirement schemes		(1,512	)		(1,426	)		(1,380	)		(1,518	)		(1,166	)		(1,302	)
Depreciation of premises and equipment		(129	)		(122	)		(114	)		(111	)		(114	)		(127	)
Amortization of intangible assets		(80	)		(99	)		(110	)		(100	)		(84	)		(94	)
Impairment of goodwill		(6	)		(419	)		(123	)		(9	)		(58	)		(65	)
Insurance claims, reserves movements, commissions and reinsurance premiums ceded		(942	)		(1,014	)		(470	)		(531	)		(256	)		(286	)
Summary other⁽²⁾		(1,143	)		(1,426	)		(1,316	)		(1,344	)		(1,552	)		(1,733	)

Total non-interest expense		(3,812	)		(4,506	)		(3,513	)		(3,613	)		(3,230	)		(3,607	)

Income / (loss) before income tax		(265	)		(14,048	)		(2,348	)		236			(2,359	)		(2,634	)
Income tax expense		(43	)		(459	)		(169	)		(167	)		(114	)		(127	)

Net income / (loss)		(308	)		(14,507	)		(2,517	)		69			(2,473	)		(2,761	)
Less: Net income attributable to the non-controlling interest		(47	)		(32	)		(20	)		(32	)		(4	)		(4	)

Net income / (loss) attributable to NBG shareholders		(355	)		(14,539	)		(2,537	)		37			(2,477	)		(2,765	)
Net income / (loss) per share from continuing operations
Basic EPS—Net income / (loss)⁽³⁾		(2.82	)		(76.62	)		(13.36	)		0.03			(0.79	)		(0.88	)
Diluted EPS—Net income / (loss)⁽³⁾		(2.82	)		(76.62	)		(13.36	)		0.03			(0.79	)		(0.88	)

	As at December 31,

	2010			2011			2012			2013			2014			2014⁽¹⁾
	EUR			EUR			EUR			EUR			EUR			USD
	(in millions)
CONSOLIDATED BALANCE SHEET DATA
ASSETS
Cash and due from banks		1,436			1,718			2,157			1,968			2,727			3,044
Deposits with Central Bank		2,962			2,899			2,886			3,454			3,583			3,999
Securities purchased under agreements to resell		146			673			833			39			94			105
Interest bearing deposits with banks		6,399			3,768			2,977			3,333			2,776			3,099
Trading assets		2,785			2,964			5,469			3,082			2,405			2,684
Available-for-sale securities		13,689			8,572			7,091			6,385			5,203			5,808
Held to maturity securities		3,598			1,002			356			10,360			10,645			11,882
Loans		79,038			76,003			74,334			73,235			74,908			83,612
Less: Allowance for loan losses		(3,175	)		(6,551	)		(7,318	)		(7,751	)		(9,492	)		(10,595	)

Net loans		75,863			69,452			67,016			65,484			65,416			73,017
Long-lived assets classified as held for sale		—			—			—			134			141			157
Summary other assets⁽²⁾		11,854			12,419			12,371			12,602			15,423			17,216

Total assets		118,732			103,467			101,156			106,841			108,413			121,011

LIABILITIES AND SHAREHOLDERS' EQUITY
Deposits excluding interbank deposits		67,768			58,913			58,568			62,502			64,619			72,127
Interbank deposits		26,127			32,662			32,591			23,092			16,893			18,857

Total deposits		93,895			91,575			91,159			85,594			81,512			90,984
Securities sold under agreements to repurchase		3,538			1,302			1,109			4,738			5,053			5,640
Long-term debt		3,806			2,938			2,116			2,582			4,085			4,560
Liabilities directly associated with long-lived assets classified as held for sale		—			—			—			10			7			8
Summary other liabilities⁽³⁾		8,752			11,556			12,564			11,301			15,319			17,099

Total liabilities		109,991			107,371			106,948			104,225			105,976			118,291

Redeemable non-controlling interest—Temporary equity		266			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)		358			1,358			1,358			1,354			1,354			1,511
Common stock		4,780			4,780			4,780			719			1,060			1,184
Additional paid-in capital		3,884			4,090			4,079			17,859			19,918			22,233
Accumulated other comprehensive income/(loss)		(3,386	)		(1,939	)		(1,283	)		(2,596	)		(2,547	)		(2,844	)
Treasury stock, at cost		(5	)		—			—			(2	)		—			—
Accumulated surplus / (deficit)		2,022			(12,547	)		(15,037	)		(15,007	)		(17,387	)		(19,408	)

Total NBG shareholders' equity / (deficit)		7,653			(4,258	)		(6,103	)		2,327			2,398			2,676

Non-controlling interest		822			71			54			39			39			44

Total liabilities and equity		118,732			103,467			101,156			106,841			108,413			121,011

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".

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

The Group uses the measure "deposits excluding interbank deposits" in order to enhance the comparability of its financial performance between reporting periods, particularly in light of increased funding from the Eurosystem resulting from the pressure experienced by the Hellenic Republic in its public finances. "Deposits excluding interbank deposits" are not financial measures determined in accordance with U.S. GAAP and, accordingly, should not be considered as an alternative to other measures derived in accordance with U.S. GAAP.

This Annual Report also contains a reference to a measure which is not defined under U.S. GAAP, "pre-provision income" ("PPI"). PPI is defined, based on regulatory reporting rules, as the "total operating income", plus the "share of the profit/ loss of investments in subsidiaries, joint ventures and associates", less the "administrative expenses" and "depreciation", with such measures prepared in accordance with IFRS. We use this measure in connection with the measurement of our capital need, as it was initially assessed in the EU-wide Comprehensive Assessment. The PPI presented in this Annual Report is calculated by us and adjusted to reflect our actual performance in 2014. In this Annual Report, we do not present any PPI as calculated in respect of us by the SSM.

PPI is included under Item 3.D, "Risk Factors—We may not successfully complete all elements of our capital plan, which may lead to the application of the new "bail-in" rules for our shareholders and the acquisition of full voting rights by the HFSF", Item 4., "History and Development of the Company—BlackRock", Item 4., "History and Development of the Company—EU-wide Comprehensive Assessment" and Item 5.B "Liquidity and Capital Resources—Capital management".

"Adjusted CET1" is defined as Common Equity Tier 1 capital as at December 31, 2014 in accordance with EU Regulation 575/2013, including the profit for the year attributable to owners of the parent based on regulatory reporting rules, of EUR 66 million.

On May 21, 2010, 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 and the payment of dividends to preferred shareholders as follows:

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 and to the Hellenic Republic, as sole holder of the 70 million preference shares issued as part of our participation in the Hellenic Republic Bank Support Plan, in accordance with the Bank's Articles of Association, 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.

The Bank does not expect to propose the distribution of dividends for the year ended December 31, 2014 to the annual Ordinary General Meeting of the Bank's shareholders, in compliance with provisions of articles 44a, 42c and 43 of Greek Company Law 2190/1920.

If you are considering purchasing our ordinary shares, preference 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, preference shares or ADRs may decline, resulting in a loss of all or a part of any investment in our ordinary shares, preference shares or ADRs. Furthermore, the risks described below are not the only risks we face. Additional risk factors which are not currently known or are currently believed to be immaterial may also have a material adverse effect on our business, results of operations and financial condition.

Uncertainty resulting from the Hellenic Republic's economic crisis has had and will continue to have an adverse impact on our business, results of operations and financial condition.

For the financial year ended December 31, 2014, 45.9% of the Group's net interest income before provision for loan losses and as at December 31, 2014, 64.9% of our loans, were derived from our domestic operations. In addition, our holdings of EUR 2,777 million of Greek government bonds and Greek treasury bills represented, as at December 31, 2014, 2.6% of our total assets and 15.5% of our trading and investment debt securities. Accordingly, the quality of our assets, our financial condition and our results of operations are heavily dependent on macroeconomic and political conditions prevailing in Greece.

Following six consecutive years of recession the Greek economy returned to positive growth in 2014. However, the Greek economy continues to face substantial macroeconomic pressures and the growth trajectory from 2014 is not likely to continue in the immediate term. Over the past five years, the Hellenic Republic has undertaken significant structural measures intended to restore competitiveness and promote economic growth in the country through the financial support program agreed with the IMF, the ECB and the EU (collectively, the "Institutions"). A program had been initially agreed in May 2010 and then has been renewed in March 2012 (the second economic adjustment program or the "Second Program") and offered—through the related financial facility agreements signed between the Hellenic Republic, the participating Eurozone countries, the European Financial Stability Facility ("EFSF") and the IMF—sufficient financing intended to fully cover Hellenic Republic's external financing needs until end-2014 conditioned on the implementation of fiscal adjustment policies and growth enhancing structural reforms. On December 8, 2014, the Eurogroup decided to withhold disbursements due under the Second Program and announced a "technical extension" of the EU side of the Second Program to end-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 Second Program, as extended, is referred to in this Annual Report as the "Program". Pressures arising from the ongoing fiscal effort to achieve a larger primary budget surplus in the Greek government (the "Government") budget, accumulated policy fatigue and potential emergence of social tensions, further delays in the implementation of Eurogroup decisions of November 2012 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) and uncertainty over sufficient medium to long term financing for the country, compounded by remaining structural constraints and deficiencies, have had an adverse effect on economic and financial conditions in Greece. More specifically:

For more information about current conditions and the substantial risks to the Program, see Item 5, "Operating and Financial Review and Prospects—Key Factors Affecting Our Results of Operations—The Hellenic Republic's Economic Crisis" and "—Second Economic Adjustment Program, jointly supported by the IMF and the Member States of the Eurozone-The Second Program".

The conditions set out above have had and continue to have significant adverse consequences on the Bank. If a credit event with respect to Hellenic Republic debt or an additional restructuring of Hellenic Republic debt were to occur, 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 diluting and/or eliminating existing shareholders' interests significantly. Furthermore, there can be no assurance that the Bank could raise all of the required additional capital on acceptable terms.

Recessionary pressures in Greece stemming from the remaining fiscal adjustment effort and from persistently high uncertainty have had and may continue to have an adverse effect on our business, results of operations and financial condition.

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

Following a cumulative output decline of 26.0% during the period 2009 to 2013, economic activity in 2014 increased by 0.8% on an annual basis (Hellenic Statistical Authority ("ELSTAT") data, press release on annual National Accounts, March 2015), in line with the estimates of the latest EU

evaluation report of the Program (source: IMF, July 2014 and Greek State Budget forecasts, November 2014).

The protracted period of poor economic conditions in the Hellenic Republic has materially and adversely affected the liquidity, business activity and financial conditions of our borrowers, which in turn led to further increases in our non-accruing loan ratios, impairment charges on our loans and other financial assets and decreased demand for borrowings in general. Specifically, our non-accruing loan ratio in Greece has increased from 32.2% at December 31, 2013 to 34.4% at December 31, 2014.

Loans to businesses and households declined in 2014, and may decline further. Moreover, our customers may further significantly decrease their risk tolerance to non-deposit investments such as stocks, bonds and mutual funds, which would adversely affect our fee and commission income.

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

Even if a new financial assistance framework on Hellenic Republic financing is achieved with the official sector, which could potentially involve the IMF, the Greek economy may not achieve the sustained and robust growth that is necessary to ease current financial constraints of the Hellenic Republic and its lack of access to the financial markets. In addition, a renewed retrenchment of the Greek economy will have a significant material adverse effect on the Bank's business, financial condition, results of operations and prospects.

We are currently restricted in our ability to obtain funding in the capital markets and are heavily dependent on the ECB and the Bank of Greece, through ELA, for funding, which are affected by changes in 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 has adversely affected our credit risk profile, suspended our return to the markets for funding, 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 in the Greek government agreeing a new financial assistance framework with the Institutions may further delay our ability to obtain funding in the private capital markets in the near and medium term.

The severity of pressure experienced by the Hellenic Republic in its public finances has restricted our access to the capital markets for funding because of concerns by counterparty banks and other lenders, particularly for unsecured funding and funding from the short-term inter-bank market. Until the beginning of 2014, these markets had been effectively closed to all Greek banks since the end of 2009. During 2014, access to financial markets and interbank funding was re-established. However, during December 2014 and between January 1 and April 30, 2015, the uncertainly regarding the financial needs of the Greek government resulted in inter-bank liabilities not been renewed since December 2014. For the same period (December 1, 2015 to April 30, 2015), the Bank incurred significant deposits outflows of EUR 8.3 billion.

Reflecting the loss of access to market funding as well as the sharp decline in deposits, our net Eurosystem funding, including funding from the Bank of Greece, through the ELA facility, which has less strict collateral rules but higher cost, increased considerably, after having declined in 2013 and

2014. As at April 30, 2015, Eurosystem funding totaled to EUR 24.8 billion of which EUR 15.2 billion was through ELA (compared to Eurosystem funding of EUR 14.2 billion (NIL ELA) as at December 31, 2014, EUR 20.7 billion as at December 31, 2013 and EUR 30.9 billion as at December 31, 2012. Financial instruments of a nominal value amounting to EUR 18.4 billion were pledged to ECB as at December 31, 2014 (see Note 19 to the U.S. GAAP Financial Statements for the analysis of instruments pledged). As at December 31, 2014, the Bank maintained a pool of unencumbered financial assets with which it could raise approximately EUR 13.0 billion from the ECB and Bank of Greece (through ELA). As at April 30, 2015, despite the increase of the Eurosystem funding, the Bank retains a significant buffer of eligible collateral of EUR 12.7 billion (cash value), of which currently EUR 12.3 billion can only be used to increase ELA funding conditional on ECB approval. However, there can be no assurance that we will be able to use this collateral to secure Eurosystem funding.

The liquidity we receive from the ECB or the Bank of Greece may be adversely affected by changes in ECB and Bank of Greece rules. The amount of funding available from the ECB or the Bank of Greece is tied to the value of the collateral we provide, which may also 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 correspondingly limited. Further increases in non-accruing loans will also negatively affect the available collateral used for funding purposes. In addition, if the ECB or the Bank of Greece were to revise their 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, the Bank's funding costs could increase and its access to liquidity could be further diminished. On February 4, 2015, the ECB announced its decision to lift the waiver affecting marketable debt instruments issued or fully guaranteed by the Hellenic Republic, which had allowed these instruments to be used in Eurosystem monetary policy operations despite the fact that they did not fulfill minimum credit rating requirements, pending an agreement to be reached between the Hellenic Republic and the Institutions.

A further downgrade of Greek sovereign ratings would also have a material adverse effect on our ability to continue to access current levels of funding from, the Bank of Greece or other sources. A further significant loss of deposits due to uncertainty related to political, economic or other factors would also adversely affect the Bank's liquidity, leading to a prolonged need for additional and increased ELA funding, and might result in the exhaustion of eligible collateral and the ELA ceiling may be reached by the Greek financial institutions, including us.

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

Historically, one of our principal sources of funds has been customer deposits. Since we rely on customer deposits for the majority of our funding, if our depositors withdraw their funds at a rate faster than the rate at which borrowers repay their loans, or if we are unable to obtain the necessary liquidity by other means, we may be unable to maintain our current levels of funding without incurring significantly higher funding costs or having to liquidate certain of our assets, or without increasing access to the ECB and the Bank of Greece under their exceptional terms. As at December 31, 2014 there was an increase in the Group's domestic deposits excluding interbank deposits of 0.4% compared to 2013. However, the Bank incurred outflow of EUR 6.4 billion between January 1, and April 30, 2015.

The ongoing availability of customer deposits to fund our loan portfolio is subject to changes in certain 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. In addition, the risk of implementation of changes in the framework for supporting

credit institutions by requiring the participation of their respective shareholders, creditors and unsecured depositors (the "bail-in" measures) and/or initiatives for taxation of deposits may also reduce the availability of deposits. 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 our operation and meet our minimum liquidity requirements and have a material adverse effect on our results, financial condition and prospects. Unusually high levels of withdrawals could have the result that the Bank or another member of the Group may not be in a position to continue to operate without additional funding support, which it may be unable to secure.

There are risks associated with our need for additional capital and liquidity, which may arise from regulatory changes and increased asset impairment.

The Bank and the Group are required by the SSM (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—ECB Single Supervisory Mechanism") and the regulators in the Hellenic Republic and other countries in which it undertakes regulated activities to maintain minimum levels of capital. To the extent the Group has regulated activities elsewhere in the European Economic Area (the "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 where it has branches, including within the EEA, the Bank is also subject to 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.

Further deterioration of market conditions, in Greece and internationally, may adversely affect the quality of our loan and investment portfolio. The potential deterioration in the credit quality of our assets may exceed expectations, lead to additional impairments in the future and generate need for additional regulatory capital.

In addition to asset impairments, changes in regulatory requirements may require us to raise additional capital. In June 2013, the European Parliament and the Council of Europe issued a new Directive 2013/36/EU and Regulation (EU) No 575/2013 (CRD IV), which incorporate the key amendments that have been proposed by the Basel Committee for Banking Supervision (BCBS) (known as Basel III). The new regulations have 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 (see also risk factor "—Our business is subject to increasingly complex regulation which may increase its regulatory and capital requirements", below).

As at December 31, 2014 the Group's Adjusted CET1 ratio was 13.6%, compared to 10.5% as at December 31, 2013 (adjusted in accordance with EU Regulation 575/2013), mainly due to the completion in May 2014 of the Bank's share capital increase of EUR 2,500 million. 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 Greek Law 4261/2014 and Regulation 1024/2013, including the appointment of a commissioner to the Bank (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece").

If we are required to raise further capital but are unable to do so on acceptable terms, we may be required to further reduce the amount of our risk-weighted assets and engage in the disposition of core and other non-core businesses, which may not occur on a timely basis or achieve prices which would otherwise be attractive to us. 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 our operating results, financial condition and prospects. See Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece" for further details. If we are required to strengthen our capital position, it may not be possible for us to raise additional capital from the financial markets or to dispose of marketable assets. That could potentially lead to further mandatory capital injections from the HFSF pursuant to the provisions of Greek Law 3864/2010 currently applicable, which could dilute or/and eliminate the interests of the ordinary shareholders, increasing the likelihood of HFSF effectively exercising full control over the Bank.

Effective management of our regulatory capital and liquidity is critical to our ability to operate our businesses, to grow organically and to pursue our strategy. Any change that limits our ability to manage our balance sheet and regulatory capital resources effectively, including, for example, reductions in profits and retained earnings as a result of write-downs or otherwise, increases in risk-weighted assets, changes in its asset composition, delays in the disposal of certain assets or an inability to receive loans as a result of market conditions or otherwise to access funding sources could have a material adverse impact on our financial condition and regulatory capital position.

We may not successfully complete all elements of our Restructuring Plan, which may lead to the application of the new "bail-in" rules for our shareholders and the acquisition of full voting rights by the HFSF.

The Bank's restructuring plan (as agreed with the European Commission on July 23, 2014) (the "Restructuring Plan") requires us to undertake specific capital actions, which, among other things, include an obligation to reduce our shareholding in our Turkish subsidiary, Finansbank, so that our share ownership represents no more than 60% by the end of 2015. There is a risk that capital actions required to be implemented under the Restructuring Plan may not be completed on time or that their capital impact may be less than expected, resulting in lower surplus than the EUR 2.0 billion expected by A-DBS and, respectively, the capital plan. Additionally, there can be no assurance that these capital actions will be executed on schedule in accordance with the Restructuring Plan, which may lead to a capital shortfall.

If we fail to cover this capital shortfall by successfully obtaining the required capital from private investors through a subsequent capital raising process and the other voluntary measures provided for in the Restructuring Plan under the recapitalization framework (pursuant to Article 6(a) of Greek Law 3864/2010, as amended by Greek Law 4254/2014 and Cabinet Act 11/2014) the requisite capital will be provided by the HFSF following after the implementation of burden sharing measures. This framework provides that the "bail in" rules can be enforced against:

resulting in losses to and/or elimination of the interests of those classes of investors (see Item 4.A, "History and Development of the Company—Restructuring Plan approved by the Directorate General for Competition on July 23, 2014") 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—Recapitalization Procedures before HFSF Participation"). For a discussion of the bail-in provisions under BRRD see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—Bank Recovery and Resolution Directive".

In addition, in the context of such a recapitalization by the HFSF, the HFSF will acquire full voting rights in respect of ordinary shares held by it and thus effectively exercise full control over us.

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

Alongside other banks across Europe, we participated in the EU-wide Comprehensive Assessment including an Asset Quality Review ("AQR") and Stress Test conducted by the ECB in cooperation with National Competent Authorities ("NCAs"), whose results were announced on October 26, 2014. We may be required to participate in similar "stress tests" in the future.

Under the headline, Adverse Static Balance Sheet Scenario ("A-SBS") assessment which took into account 2013 results (a particularly adverse year for NBG), the Bank was found to have a capital shortfall of EUR 933 million (after taking into account the application of proceeds from the EUR 2.5 billion share capital increase in May 2014). However, under the Adverse Dynamic Balance Sheet Scenario ("A-DBS") assessment which took into account the Bank's Restructuring Plan while applying stress conditions pursuant to the ECB's and the European Banking Authority's ("EBA") methodological guidance, the Bank was found to have a surplus of over EUR 2.0 billion.

Similarly, the Bank's capital plan (the "capital plan") addressing the A-SBS capital shortfall consists of the A-DBS scenario as well as the Bank's incremental first half 2014, against A-DBS forecasts for the financial year 2014, as mandated by the ECB's Single Supervisory Mechanism's ("SSM").

Although the results from the recent ECB stress tests were favorable to us when taking into account our Restructuring Plan under the dynamic scenario (see Item 4A., "History and Development of the NBG Group—EU-wide Comprehensive Assessment") we anticipate that new stress tests analyzing the European banking sector will continue to be published by national and supranational regulatory authorities. Loss of confidence in the banking sector following the announcement of any future stress tests regarding the Bank or the Greek banking system as a whole, or a market perception that any such tests are not rigorous enough, 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 require us to raise additional capital which, if injected by the HFSF or other investors may result in a significant dilution and/or elimination of existing shareholders' interests.

We may not be allowed to maintain the main part of deferred tax assets recognized under IFRS as regulatory capital, which may have an adverse effect on our operating results and financial conditions.

We currently include deferred tax assets ("DTAs") calculated in accordance with IFRS as endorsed by the EU in calculating our capital and capital adequacy ratios.

In addition to introducing new capital requirements, CRD IV 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 capital. This deduction is implemented gradually until 2024.

This deduction introduced by CRD IV has a significant impact on Greek credit institutions, including us. However, as a measure to offset this possible adverse effect, article 27A, (Greek Law 4303/2014, "DTC Law") issued on October 17, 2014 allows, under certain conditions, from 2016 onwards, credit institutions to convert DTAs arising from Private Sector Initiative ("PSI") and from impairment losses and allowance for loan losses for loans existing at December 31, 2014 for IFRS purposes ("Eligible DTA") to a receivable ("Tax Credit") from the Hellenic Republic. The Tax Credit will be calculated as a ratio of IFRS accounting losses over net equity before the year's losses and such ratio will be applied on the remaining eligible DTA in a given year. This new legislation allows credit institutions, including us, to treat such eligible DTA as not "relying on future profitability" according to CRD IV, and as a result such eligible DTA are not deducted from CET1, thereby improving an institution's capital position.

The Tax Credit is offsettable against income taxes payable. Any excess amount of the Tax Credit that cannot be offset against income taxes payable is immediately recognized as a receivable from the Hellenic Republic. In such case the Bank will issue conversion rights on own ordinary shares for an amount of 110% of the Tax Credit receivable in favor of the Hellenic Republic and create a special reserve for an equal amount. The value of the conversion rights will be based on the average price per share of the last 30 days, weighted by the trading volume. Existing shareholders will have, proportionate to their shareholding and for a reasonable time period (to be determined by virtue of a Cabinet Act), a call option on the conversion rights. Following the end of the above call option period, the rights are freely transferable and will be converted to common shares after the completion of a tax audit. Following formation of the above special reserve, a decision by the General Meeting of Shareholders will be taken regarding the share capital increase through the capitalization of the said reserve, with abolition of the pre-emptive rights of existing shareholders.

On November 7, 2014 the Bank held an extraordinary General Shareholders Meeting which resolved upon the application by the Bank of the DTC Law. In order for the Bank to stop applying the provisions of the DTC Law a regulatory approval and a General Shareholders Meeting resolution will be required.

As at December 31, 2014, the amount of the Bank's Eligible DTA was EUR 3.3 billion.

In April 2015, the European Commission announced that it sent requests for information to Spain, Italy, Portugal and Greece regarding their treatment of DTCs 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 our regulatory capital change, whether in recognizing DTAs as part of our capital base or limiting such use of DTAs in calculating our capital base, this may affect our capital base and consequently our capital ratios. 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 finally find illegal the treatment of the DTCs under Greek law and that Greek credit institutions will ultimately be allowed to maintain certain DTAs or DTCs as regulatory capital. If any of these risks materialize, this may negatively affect our ability to maintain sufficient regulatory capital, which may in turn require us 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 our operating results and financial conditions.

If NBG has IFRS (stand alone) accounting losses in any given year from 2015 onwards, and the provisions of article 27A are applied as described above, existing shareholders may be diluted to the extent of the common shares issued to the Hellenic Republic, should they (existing shareholders) not exercise their call option on the conversion rights.

Repayment of the EUR 1,350 million Greek State Preference Shares is subject to the prior approval of the Bank of Greece and the SSM.

Potential repayment of the EUR 1,350 million Greek State Preference Shares issued as a result of our participation in Pillar I of the Hellenic Republic Bank Support Plan, while not a commitment under the Restructuring Plan, would strengthen our flexibility in managing our capital, as these shares will not be recognized as CET1 starting from 2018 on a fully-loaded Basel III basis. Any repayment of the Greek State Preference Shares is subject to the prior approval of the Bank of Greece and the SSM. Furthermore, we may not have sufficient capital to repay the Greek State Preference Shares. Accordingly, we may not be able to realize one benefit of the capital raising announced on April 16, 2014 and completed in May 2014, if the Bank does not obtain the required consent for such repayment. Lastly, to the extent we do not repay the Greek State Preference Shares, a possible conversion of the

Greek State Preference Shares into Ordinary Shares may also significantly alter the type and composition of our shareholder base (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic's Republic Bank Support Plan").

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

In Note 3 of the 2014 U.S. GAAP Financial Statements, reference is made to increased levels of Eurosystem funding during the first four months of 2015, significant deposits outflows from the Greek banking sector, the on-going negotiations between the Greek government and the Institutions towards reaching a permanent agreement and also to the existing uncertainties that could adversely affect our 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 the reaching of an agreement between the Greek government and the Institutions. Our independent auditors have added an explanatory paragraph to their audit opinion issued in connection with the 2014 U.S. GAAP Financial Statements expressing substantial doubt on our ability to continue as a going concern as a result of material uncertainties with respect to our ability to continue to access sufficient liquidity through the ELA as well as the significant deposit outflows during the first four months of 2015.

Deteriorating asset valuations resulting from poor market conditions may adversely affect our future earnings and our capital adequacy.

The mixed global economic recovery, the relatively weak recovery of economies in SE Europe in recent years and the economic crisis in Greece have resulted in an increase in non-accruing loans and significant changes in the fair values of our financial assets.

A substantial portion of our loans to corporate and individual borrowers are secured by collateral such as real estate, securities, vessels, term deposits and receivables. In particular, as mortgage loans are one of our principal assets, we are currently highly exposed to developments in real estate markets, especially in Greece. From 2002 to 2007, demand for housing and mortgage financing in Greece increased significantly driven by, among other things, economic growth, declining unemployment rates, demographic and social trends and historically low interest rates in the Eurozone. In late 2007, the housing market began to adjust in Greece as a result of excess supply, higher interest rates and an accelerated decline in household disposable income. Construction activity started to contract sharply since 2009. The adjustment in residential valuations started in 2009 and continued at a rapid pace in the period 2010 to end 2014 (with prices having fallen by 38.4% by the end of the fourth quarter of 2014 compared to their peak in 2008, according to the "Bulletin of Conjunctural Indicators" published by the Bank of Greece, January to February 2015). The pace of decline of house prices is expected to slow in 2015 as household disposable income has bottomed since the second semester of 2014 (source: ELSTAT Sectoral Accounts data, Q4:2014) but the high stock of unsold houses, weak credit flows and a persistently high unemployment rate 26.0% in January 2015 (source: ELSTAT Press release, Monthly LFS data), will delay market stabilization further, with mortgage delinquencies potential registering a further increase.

A continued decline in the Greek economy, 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. In addition, our failure to recover the expected value of collateral in the case of foreclosure, or our inability to initiate foreclosure proceedings due to national legislation, may expose us to losses which could have a material adverse effect on our business, results of operations and financial condition. For example, since July 1, 2010, certain auctions initiated by banks or their assignees for satisfaction of claims not exceeding EUR 200,000 have been suspended as described under Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—Constraints on the Use of Capital".

In addition, 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 ultimately realized by us will depend on their fair value determined at that time and may be materially different from their current value. Any decrease in the value of such assets and exposures could require us to realize additional impairment charges, which could adversely affect our financial condition and results of operations, as well as our capital adequacy.

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

Since 2009, the Hellenic Republic has undergone a series of credit rating downgrades and, in 2010, moved to 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 Investors 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 on August 1, 2014 and S&P upgraded the Hellenic Republic to B on September 12, 2014.

However, these gradual rating improvements were reversed in end-2014 and early 2015, against a backdrop of sharply increasing uncertainty and deteriorating financial and fiscal conditions. Accordingly, Fitch Ratings revised the Hellenic Republic's sovereign outlook to negative from stable in January 2015 and eventually downgraded Greece's sovereign ratings by two notches to CCC from B on March 27, 2015. S&P lowered Greece's long-term rating by one notch to B- in January 2015 and placed the country on a credit watch negative status which has been renewed in March 2015 citing the government's "increasingly stretched" liquidity position. On April 15, 2015, S&P lowered the Hellenic Republic's (long term) sovereign ratings to CCC+ from B- and removed these ratings from CreditWatch, albeit, maintained the outlook at negative status. Moody's has also placed in February 2015 Greece's sovereign bond rating on review for a possible downgrade because of the uncertain results of negotiations between Greece and its creditors. Finally, Moody's downgraded Greece's government (long-term) bond rating to Caa2 from Caa1 on April 29 2015 maintaining a negative rating outlook. The "high uncertainty over whether Greece's government will reach an agreement with official creditors in time to meet upcoming repayments on marketable debt" and the "significant implementation risks" of a follow-up, medium-term financing program "even if an agreement is reached", given "the weakened economy and a fragile domestic political environment" are stressed as the key factors underlying the downgrade.

A further downgrade of the Hellenic Republic's rating may occur in the event of a failure to reach an agreement with official lenders and/or the Hellenic Republic is unable to service its obligations to the private or official sector. Accordingly, the cost of risk for the Hellenic Republic would increase further, with negative effects on the cost of risk for Greek banks, including the Bank, their and our business, financial condition and results of operations. Further downgrades of the Hellenic Republic's credit rating could result in a corresponding downgrade in the Bank's credit rating and, as a result, increase wholesale borrowing costs and our access to liquidity.

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 4063/2012, 3965/2011, 3844/2010 and 3756/2009, the Bank did not pay any dividends to its

ordinary shareholders in 2014 in respect of the 2013 financial year, nor in 2013 and 2012 in respect of the 2012 and 2011 financial years, respectively. Further, the Bank will not be paying an ordinary share dividend with respect to the 2014 financial year.

In general, as a result of our participation in the Hellenic Republic Bank Support Plan, our dividends are subject to a maximum of 35% of the Bank's distributable profits (on an unconsolidated basis) for as long as the Bank participates in the Hellenic Republic Bank Support Plan, and any decisions regarding distribution of dividends and remuneration can be vetoed by the Hellenic Republic representative who sits on our Board of Directors. In addition, as long as the Bank participates in the recapitalization program pursuant to Greek Law 3864/2010, the HFSF's representative who sits on the Bank's Board of Directors has 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 Board members, General Managers and their deputies.

Pursuant to the commitments undertaken by the Hellenic Republic to the European Commission due to the provision of state aid to Greek credit institutions, the Bank is prohibited from distributing dividends or paying coupons on its own fund instruments or releasing reserves to put itself in such a position until the end of the restructuring period, unless such payment fulfills legal obligation of the Bank or the Directorate General for Competition of the European Commission grants a relevant exception.

The Bank has 12,639,831 U.S. preference shares (the "U.S. Preference Shares") outstanding as of the date of this Annual Report. If the Bank has sufficient distributable funds, each U.S Preference Share is entitled to USD 2.25 per share dividend per annum paid in cash. Payments of dividends U.S. Preference Shares take preference over distributable profits otherwise available to our ordinary shareholders. We have not paid any dividends on the U.S. Preference Shares since March 2011 and will not proceed to such payment in respect of the financial year ended December 31, 2014 in accordance with the Bank's Articles of Association, and the provisions of article 44a in conjunction with articles 42c and 43 of the Greek Company Law 2190/1920, which prohibit the payment of dividends in the absence of sufficient distributable funds.

In addition, under Greek Law, banks participating in the Hellenic Republic Bank Support Plan could distribute dividends to ordinary shareholders in respect of financial years ended December 31, 2008 through December 31, 2012, only in the form of ordinary shares excluding treasury shares. Although there is no law imposing a similar restriction on the payment of dividends for the financial year ended December 31, 2014, such restrictions may be imposed in the future, as they have been in past years (including for the financial year ended December 31, 2013).

Our participation in the Hellenic Republic Bank Support Plan also includes the issuance of Greek State Preference Shares (EUR 350 million in January 2009 and EUR 1,000 million in December 2011). Greek Law 4093/2012 provides that the fixed return of 10% on the Greek State Preference Shares in accordance with Greek Law 3723/2008, is payable in any case, notwithstanding the provisions of Greek Law 2190/1920 (with the exception of article 44a which prohibits the payment of dividends in the absence of sufficient distributable funds and if the payment of the fixed return will lower the capital ratios of the Bank below the minimum required and if the restrictions of article 44a of Greek Company Law 2190/1920 apply, as was the case for the Bank for the year ended December 31, 2014).

If we do not have sufficient capital to repay the Greek State Preference Shares and if the required approval is not obtained and the Greek State Preference Shares are repaid, the Greek State Preference Shares will remain outstanding, and a gradual cumulative increase of 2% per year on the 10% fixed return will be payable by the Bank and the restrictions on the payment of dividends set forth above will continue to apply. For further information on the terms of the Greek State Preference Shares, see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece".

As a recipient of state aid, the Bank's operational autonomy is constrained.

The Group participated in the PSI and, as a result, recorded impairment losses on its Greek government bond portfolio and loans, which adversely affected the capital position of the Group and, as a result, the Bank was compelled to seek support from the HFSF. See also risk factor "—There are risks associated with our need for additional capital and liquidity, which may arise from regulatory changes and increased asset impairment".

In June 2013, the Bank completed its share capital increase, raising EUR 9,756 million from the HFSF and private sector creditors. Following the participation of the HFSF in the Bank's share capital increase, on July 10, 2013, the Bank and the HFSF entered into the relationship framework agreement (the "Relationship Framework Agreement"), which governs the relationship between the Bank and the HFSF (for more information on 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 the HFSF—The Relationship Framework Agreement"). Including the Greek State Preference Shares of EUR 1,350 million, the total amount of state aid received by the Bank, in forms other than guarantees and liquidity assistance, was EUR 10,027 million as at December 31, 2014. In addition, in the event that the Bank is placed under liquidation, the HFSF as shareholder, the Hellenic Republic holding Greek State Preference Shares and the holders of U.S. Preference Shares, are satisfied in priority before the common shareholders.

Under European state aid rules, the Bank's operations are restricted in order to ensure that the state aid provided does not lead to the distortion of competition. Pursuant to the commitments undertaken by the Hellenic Republic vis-à-vis the European Commission due to the provision of state aid to Greek banks, the Bank is prohibited from distributing dividends or paying coupons on own fund instruments or releasing reserves to put itself in such a position until the end of the restructuring period, unless such payment fulfils a legal obligation of the Bank or the Directorate General for Competition of the European Commission grants an exemption. The Bank is also not permitted to acquire any stake in any undertaking, unless the purchase price falls below certain thresholds or the acquisition takes place in the ordinary course of business or is required to take place under laws regarding the consolidation of the Greek banking sector. There are also restrictions on the lending practices that the Bank must follow and risk monitoring requirements that the Bank must fulfill.

Approval of state aid from the Directorate General for Competition of the European Commission required the approval of a restructuring plan, which further constrains the operational autonomy of the Bank. On June 25, 2014 the Hellenic Republic submitted (through the Ministry of Finance) a revised restructuring plan for the Bank to the Directorate General for Competition of the European Commission.

On July 23, 2014, the European Commission in its final decision on the restructuring of the Bank found the Restructuring Plan to be in line with EU state aid rules and in particular with the rules on banking restructuring during the crisis. More specifically, according to the relevant decision of the European Commission, in light of the approved Restructuring Plan and the commitments submitted by the Hellenic Republic to the European Commission in June 2014, the Commission concluded that the state aid received by the Bank was compatible with the internal market. See also Item 4.A, "History and Development of the Company—Restructuring Plan approved by the Directorate General for Competition of the European Commission on July 23, 2014".

The implementation of these measures by the Bank may have a significant impact on its business activity, operating results and financial position. Furthermore, the disposals contemplated by the Restructuring Plan may be undertaken by the Bank at unattractive valuations or during unfavorable market conditions. Failure of the Bank to meet the material terms specified in the Restructuring Plan or to implement the Restructuring Plan may result, depending on the magnitude or nature of the

failure, in the European Commission initiating an investigation into the misuse of the aid, which may result in the partial or entire recovery of state aid and/or the imposition of additional conditions, in line with previous requests to banks in the European Union that have received state aid. 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 and in the future the HFSF could obtain full voting rights in respect of its shareholding in the Bank", below).

Specifically, as part of the approved Restructuring Plan, the Bank has given a number of commitments, both structural (such as the disposal of certain assets and subsidiaries) and behavioural, towards the European Commission. Among other commitments, the Bank is required to reduce its shareholding in Finansbank so that its share ownership represents no more than 60% by the end of 2015.

Furthermore, the commitments of the Hellenic Republic towards the European Commission also provide for, inter alia, the appointment of a 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 6.A, "Board of Directors and Senior Management—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 and in the future the HFSF could obtain full voting rights in respect of its shareholding in the Bank.

Under the Relationship Framework Agreement governing the relations between the Bank and 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—Provision of capital support by the HFSF". Although the 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 Bank's 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 the recapitalization program, the HFSF will be able to exercise significant influence over the operations of the Bank.

Pursuant to the provisions of Greek Law 3864/2010, the HFSF's appointed representative has the power to: (a) veto key corporate decisions of a credit institution's board of directors related to (i) dividend distributions, the remuneration policy relating to the chairman, managing directors and the other Board members, general managers and deputies; (ii) any other matter which may set at risk the rights of depositors or have a material adverse effect on the liquidity, solvency and/or, in general, on the prudent and orderly operation of the credit institution, including its business strategy and asset/liability management); and (iii) decisions referring to matters for which the restriction in the voting rights of the shares held does not apply and which significantly affect the HFSF's shareholding in the credit institution; (b) request an adjournment of a Board meeting for three business days in order to receive instructions from the HFSF Executive Committee, following consultation with the Bank of Greece; (c) call a board meeting; (d) approve the appointment of the chief financial officer; (e) call a general shareholders' meeting for a credit institution within the shortened deadlines provided for in Greek Law 3864/2010; and (f) have free access to all books and records of the credit institution. Accordingly, as a result of the Bank's participation in the recapitalization program, the HFSF will be able to exercise significant influence over the operations of the Bank.

In addition to the provisions of Greek Law 3864/2010, and pursuant to the Relationship Framework Agreement, the HFSF has a series of information rights with respect to matters pertaining

to the Bank. Additionally, the HFSF may appoint at least one member to each of the Audit Committee, Risk Committee, Remuneration Committee and Nomination Committee. Finally, the Bank is obliged to obtain the prior approval of the HFSF on a number of material issues.

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.

In addition, the HFSF could obtain full voting rights in the future and as a consequence the Group may be controlled by the HFSF. Pursuant to Article 7a of Greek Law 3864/2010, the HFSF may obtain full voting rights if it is ascertained, by a decision of the General Council of the HFSF, that our material obligations either provided in the Restructuring Plan, or promoting its implementation, or outlined in the Relationship Framework Agreement between the Bank and the HFSF, are not met. (See Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Financial Stability Fund—The Greek Recapitalization Framework"). If in the future we do not meet our obligations under the Restructuring Plan, the HFSF could obtain full voting rights in respect of its shares in the Bank.

The Hellenic Republic has the ability to exercise and currently exercises significant influence on the Bank in certain areas.

The Hellenic Republic directly owns all 270 million Greek State Preference Shares issued under the Pillar I capital facility of the Hellenic Republic Bank Support Plan (Greek Law 3723/2008) (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic's Bank Support Plan"). The direct stake of the Hellenic Republic in the Bank as described above, provides the Hellenic Republic, among other things, with voting rights at the General Meeting of Preferred Shareholders, the appointment of a representative on the Board of Directors of the Bank who 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, Deputy Chief Executive Officers, 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. Furthermore, the representative of the Hellenic Republic has the right to attend the Ordinary Shareholders' General Meeting and to exercise, during deliberation and decision-taking, a veto over the abovementioned issues and 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.

There is an additional risk that the Hellenic Republic may exercise the rights it has to exert influence over the Bank and may disagree with certain decisions of the Group relating to dividend distributions, benefits policies and other commercial and management decisions which will ultimately limit the operational flexibility of the Group.

We may seek to repay the Greek State Preference Shares, subject to prior approval by the Bank of Greece and the SSM (see "—Repayment of the EUR 1,350 million Greek State Preference Shares is subject to the prior approval of the Bank of Greece and the SSM"). If the required approval is not obtained and the Greek State Preference Shares are not repaid, the Greek State Preference Shares will remain outstanding and the Hellenic Republic will continue to have the ability to exercise significant influence over the Bank, as indicated above, a right which is in addition to those rights of the HFSF (see "—The HFSF as shareholder has certain rights in relation to the operation of the Bank and in the future the HFSF could obtain full voting rights in respect of its shareholding in the Bank".

If economic conditions do not improve or continue to deteriorate, or if the financial position of the Group deteriorates, further government or inter-governmental intervention may occur. Any further government or inter-governmental intervention, including through the HFSF, may have a material adverse effect on the interests of other holders of our securities, results of operations and financial.

Furthermore, the Hellenic Republic and 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 its shareholders.

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

Following a lengthy period of recession in many economies around the world, including Europe, following the financial crisis, global economic growth has returned, although at a relatively modest pace and uneven across the main countries. Most of the economies with which Greece has strong export links, including a number of EU economies, continue to face significant economic headwinds stemming from high levels of private or public debt and elevated unemployment rates. Activity remains greatly dependent on accommodative monetary policy and is subject to downside risks, as fiscal room is limited. Policymakers in many advanced economies have adopted credible strategies to contain public debt and excessive fiscal deficits, and fiscal consolidation is expected to continue, albeit at a more moderate pace. The continuation of these policies may restrict economic recovery, with a corresponding adverse effect on our business, results of operations and financial condition.

In financial markets, the search for yield continued, mainly driven by the ongoing accommodative monetary stance by most major central banks and the expansion of quantitative easing policies in the euro area and Japan, resulting in higher equity and government bond prices in major advanced economies. At the same time, equity price and interest rate volatility has picked up, though from very low levels, reflecting the heightening uncertainty vis-à-vis the pace of the world economic recovery, the steep decline in oil prices and more importantly, the continual uncertainty regarding the first interest rate increase by the US Federal Reserve ("Fed"). Indeed, a rapid reversal of the global search for yield and unforeseen portfolio shifts possibly triggered by a more aggressive-than-expected interest rate hike cycle by the Fed have the potential to throw financial markets into turmoil with a corresponding adverse effect on our business, results of operations and financial condition, including our ability to fund our 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 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, a recurrence of euro area sovereign debt and banking stress triggered by policy uncertainty associated with Greece, as well as further deterioration in the Greek economy. Any of these events may give rise to concerns regarding the ability of the Hellenic Republic to meet its funding needs. These developments could:

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.

The Public Company Accounting Oversight Board is not currently permitted to inspect our independent accounting firm, and you may not therefore benefit from such inspections.

Auditors of public companies in the United States are required by law to undergo periodic Public Company Accounting Oversight Board (or "PCAOB") inspections that assess their compliance with United States law and professional standards in connection with performance of audits of financial statements filed with the SEC. Certain EU countries, including Greece, do not currently permit the PCAOB to conduct inspections of accounting firms established and operating in such EU countries, even if they are part of major international firms. The PCAOB conducted inspections in Greece in 2008 and evaluated our auditor's performance of audits of SEC registrants and our auditor's quality controls. Currently, however, the PCAOB is unable to conduct inspections in Greece until a cooperation agreement between the PCAOB and the Greek Accounting & Auditing Standards Oversight Board is reached. Accordingly, as would not be the case for most public companies in the United States, should the PCAOB again wish to conduct an inspection, it is currently prevented from evaluating our auditor's performance of audits and its quality control procedures, and, unlike shareholders of most public companies in the United States, our shareholders would be deprived of the possible benefits of such inspections.

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 14.6% of the Group's

total assets as at December 31, 2014. Volatility can also lead to losses relating to a broad range of other trading securities and derivatives held, including swaps, futures, options and structured products. For further information on market risk exposures in those portfolios, you should refer to Item 11, "Quantitative and Qualitative Disclosures about Market Risk—Market Risk".

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

Non-accruing loans represented 26.8% of our loan portfolio as at December 31, 2014, while the same ratio for our Greek operations was 34.4% (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, 2014 and December 31, 2013, 58,948 and 40,369 customers, had applied to the court under the provisions of Greek Law 3869/2010,with combined outstanding balances of EUR 2,784 million and EUR 1,838 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.

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

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

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

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

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

Our current senior management team includes a number of executives we believe contribute significant experience and expertise to our management in the banking sectors in which we operate. The continued performance of our business and our ability to execute our business strategy will

depend, in large part, on the efforts of our senior management. For instance a situation of effective control by the HFSF could lead to the departure of certain senior managers. If a substantial portion of our senior management leaves us, our business may be materially adversely affected.

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

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

We, 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.

We are subject to rules and regulations related to combating money laundering and terrorism financing in the jurisdictions where we operate. 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 we believe that our current anti-money laundering and anti-terrorism financing policies and procedures are adequate to ensure compliance with applicable legislation, we cannot guarantee that they will comply at all times with all rules applicable to money laundering and terrorism financing as extended to the whole 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 our 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, 2014 was EUR 337 million, determined by reference to a number of critical assumptions. These include assumptions about movements in interest rates which may not be realized. Potential variation may cause us to incur significantly increased liability in respect of these obligations. For more information on our current obligations under pension plans and the assumptions by reference to which they are determined, please refer to Item 6.D, "Employees" and Note 40 of the U.S. GAAP Financial Statements.

Any amendment in legislation regarding pensions and pension liabilities or other post-employment benefit obligations, including those under the Program, may increase the liability of the Bank or its

subsidiaries with respect to pension and other post-employment benefit plan contributions to cover actuarial or operating deficits of those plans.

The Greek banking sector is subject to strikes, which may adversely affect our operations.

Most of the Bank's employees belong to a union and the Greek banking industry has been subject to strikes over the issues of pensions and wages. Even though, in 2014, Bank employees have gone on strike only two days, largely to express their opposition to the austerity measures implemented in light of the Program, Greek bank unions in general participate in general strikes, which have increased. Prolonged labor unrest could have a material adverse effect on the Bank's operations in the Hellenic Republic, either directly or indirectly, for example by affecting the willingness or ability of the Government to pass the reforms necessary to successfully implement the Program.

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

In establishing the fair value of certain financial instruments, 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 experienced over the past several years can challenge the factual bases of certain underlying assumptions and has made it difficult to value certain of our financial instruments. Valuations in future periods, reflecting prevailing market conditions, may result in changes in the fair values of these instruments, which could have a material adverse effect on 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 result in material adverse effects on our financial performance 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, continuing volatility as a result of market forces out of our control could cause the Bank's liquidity position to deteriorate. Such deterioration would increase funding costs and limit the Bank's capacity to increase its credit portfolio and the total amount of its assets, which could have a material adverse effect on the Bank's business, results of operations and financial condition.

We are exposed to foreign exchange risk, and a possible devaluation of any of the currencies in which we operate could have a material adverse effect on our assets, including our loan portfolio, and our results of operations.

Certain loans granted by us are denominated in currencies other than euro. A devaluation of any such currencies in which we operate or in which we have loan exposure may require us to take an impairment charge. Further, we may incur credit losses as certain borrowers may be exposed to interest payments on loans in foreign currencies while having income in local currencies.

Any significant devaluation in any currency in which we have loan exposure would make it more difficult for our customers to repay their loans, and the credit risk associated with such customers and default rates could increase. In addition, any significant movements in any currency in which we operate, particularly the Turkish Lira, could cause adverse foreign exchange effects on our financial statements particularly affecting our reported results and adversely affecting our balance sheet. Our results of operations and financial position, reported in euro, would also be adversely affected by the relative weakness of the currency of any other country in which we operate compared to the euro.

Conversely, a devaluation of the euro against other currencies in which loans are made to customers would result in an increase in our loan portfolio, resulting in growth in risk-weighted assets and a negative impact on capital ratios. Exchange rate movements could have a significant effect on our balance sheet positions and, over the long term, our results of operations, which are stated in euro.

If any of the variety of instruments and strategies that we use to economically hedge our exposure to market risk is not effective, we may incur losses. Many of our strategies are based on historical trading patterns and correlations. Unexpected market developments therefore may adversely affect the effectiveness of our hedging strategies. Moreover, we do not economically hedge all of our risk exposure in all market environments or against all types of risk. For example, we are exposed to TRY fluctuations and do not always economically hedge this exposure. We have not hedged the sovereign credit risk of the Hellenic Republic.

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.

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

Due to the uncertainty regarding the success of the Program, new taxes may be imposed on the Group, and existing taxes may be increased. Greek Law 4110/2013 provides that for the periods commencing from January 1, 2013 thereon, the nominal corporation tax rate is increased to 26%.

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 and our 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.

As of December 31, 2014, we performed an evaluation, under the supervision and with the participation of our management, including our Chief Executive Officer and our Deputy Chief Executive Officer and Group Chief Financial Officer, of the effectiveness of our disclosure controls and procedures.

Based upon that evaluation, our Chief Executive Officer and our Deputy Chief Executive Officer and Group Chief Financial Officer have concluded that our disclosure controls and procedures are ineffective as of December 31, 2014, due to the fact that management identified material weaknesses in its internal control over financial reporting relating to:

Although we have initiated remedial steps to address these material weaknesses in our internal control over financial reporting, 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 material controls 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 regulatory and capital requirements.

The Group is subject to financial services laws, regulations, administrative actions and policies in each jurisdiction in which it operates. All of these regulatory requirements have been changing and are subject to change, particularly in the current market environment, 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 been implementing significant changes to the existing regulatory frameworks, including those pertaining to capital adequacy, liquidity and scope of banks' operations (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece"). In June 2013, the European Parliament and the Council of Europe adopted a new legislative package (known as CRD IV), which incorporated the amendments that have been proposed by the Basel Committee for Banking Supervision in December 2010 (known as Basel III). Although the new regulations have been directly applicable to all EU Member States since January 1, 2014, changes under CRD IV will be implemented gradually, mainly between 2014 to 2019 (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—Capital Requirements/Supervision"). The full implementation of CRD IV is expected to lead to an increase in the Group's capital requirements and capital costs.

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

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

Implementation of the Bank Recovery and Resolution Directive may affect our operations.

In addition to the capital requirements under CRD IV, Directive 2014/59/EU of May 15, provides for the establishment of an EU-wide framework for the recovery and resolution of credit institutions and investment firms (the "Bank Recovery and Resolution Directive" or "BRRD"). The BRRD is designed to provide authorities with a credible set of tools to intervene sufficiently early and quickly in an unsound or failing institution with the objectives to ensure the continuity of the institution's critical functions, to avoid a significant adverse effect on the financial system, in particular by preventing contagion, including to market infrastructures, and by maintaining market discipline, to protect public funds by minimizing reliance on extraordinary public financial support, to protect depositors and investors and to protect client funds and client assets.

The BRRD provides that it will be applied by Member States from January 1, 2015, except for the general bail-in tool (see below) which is to be applied from January 1, 2016. The BRRD has not yet been transposed into Greek legislation by the Greek Parliament.

The BRRD requires institutions to maintain at all times a sufficient aggregate amount of own funds and "eligible liabilities", expressed as a percentage of the total liabilities and own funds of the institution (known as the "minimum requirement for own funds and eligible liabilities" or "MREL"). See Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Greek Regulatory Framework—Bank Recovery and Resolution Directive".

The BRRD also provides for a Member State as a last resort, after having assessed and exploited the above resolution tools to the maximum extent possible whilst maintaining financial stability, to be able to provide extraordinary public financial support through additional financial stabilization tools. These consist of the public equity support and temporary public ownership tools. Any such extraordinary financial support must be provided in accordance with the EU state aid framework.

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).

In addition to the general bail-in tool, the BRRD provides for resolution authorities to have the power to permanently write-down or convert into equity capital instruments such as subordinated notes at the point of non-viability and before any other resolution action is taken (non-viability loss absorption). Any shares issued to holders of subordinated notes upon any such conversion into equity may also be subject to any application of the general bail-in tool.

converted or extraordinary public support is to be provided and without such support the appropriate authority determines that the institution would no longer be viable.

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, once it is implemented, shareholders and potential investors will not be adversely affected by actions taken under it. In addition, there can be no assurance that, once the BRRD is implemented, its application will not have a significant impact on our results of operations, business, assets, cash flows and financial condition, as well as on our funding activities and the products and services we offer.

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, 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 (subsidiarisation). 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 will 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 regulations provide 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.

The proposed regulation will apply to European banks that will eventually be designated as global systemically important banks ("G-SIBs") or that exceed the following thresholds for three consecutive years: (a) total assets are equal or exceed EUR 30 billion; or (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 its own capital or borrowed money and for the sole purpose of making a profit for own account: (i) acquire or retain units or shares of AIFs as; (ii) invest in derivatives, certificates, indices or any other financial instrument the performance of which is linked to shares or units of AIFs.

Under the current proposals, 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—are not subject to the ban, however they might be subject to separation.

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

Should a mandatory separation be imposed, additional costs at Group level are not ruled out, in terms of higher funding costs, additional capital requirements and operational costs due to the

separation and lack of diversification benefits. Due to a relatively limited trading activity, Greek banks could be penalized and put at a relative disadvantage in comparison with their main European competitors. As a result, the proposal could lead to the creation of an oligopoly where only the biggest players will be able to support the separation of the trading activities and the costs that will be incurred. An additional layer of complexity, leading to uncertainty, is the high risk of diverging approaches throughout Europe on this issue.

On October 15, 2013, the Council of the European Union adopted regulations establishing the SSM for Eurozone banks and other credit institutions, which will give the ECB, in conjunction with the national regulatory authorities of the Eurozone states, direct supervisory responsibility over "significant supervised entities" in the Eurozone. The SSM framework regulation (Regulation 468/2014, ECB/2014/17) setting out the practical arrangements for the SSM was published in April 2014 and entered into force in May 2014 (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—ECB Single Supervisory Mechanism").

The Bank is a significant supervised entity 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.

National regulatory authorities 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, besides supporting the ECB in day-by-day supervision. As at November 4, 2014 the ECB is exclusively responsible for prudential supervision (see Item 4.B, "Business Overview—The Greek Regulatory Framework" for a discussion of the ECB's supervisory responsibilities).

We will be subject to the provisions of the EU Regulation establishing the Single Resolution Mechanism.

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 and a Single Resolution Fund ("SRM Regulation").

The SRM Regulation, which will complement the SSM (as discussed under "—We may be affected by the ECB Single Supervisory Mechanism" above), will apply to all banks supervised by the SSM. Those uniform rules and that uniform procedure shall be applied by a single resolution board (the "Single Resolution Board") together with the Council and the Commission and the national resolution authorities within the framework of the Single Resolution Mechanism established by this Regulation. 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.

A centralized decision-making process will be built around the Single Resolution Board and will involve the European Commission and the Council of the European Union—which will have the possibility to object to Single Resolution Board decisions—as well as the ECB and the national resolution authorities.

The use of the Fund shall be contingent upon the agreement by the participating Member States to transfer to the Fund the contributions that they raise at national level in accordance with this Regulation and with Directive 2014/59.

The provisions relating to the cooperation between the Single Resolution Board and the national resolution authorities for the preparation of the banks' resolution plans apply from January 1, 2015 and the Single Resolution Mechanism should be fully operational from January 1, 2016.

This framework should be able to ensure that, instead of national resolution authorities, there will be a single authority—i.e. the Single Resolution Board—which will take all relevant decisions for banks being part of the European banking union.

On February 14, 2013 the European Commission published a legislative proposal on a new Financial Transactions Tax (the "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. Although implementation was originally envisaged for January 1, 2014, the process has been delayed.

Given the concerns voiced by both the financial sector and business associations, it is unclear how the FTT will proceed and when it will be implemented. If adopted, the impact on the 'real economy' of the FTT as currently envisaged—especially for corporations—could be severe as many financial transactions are made on behalf of businesses that would bear the additional costs of the tax. For example, a transaction tax would raise the cost of the sale and purchase of corporate bonds in a time where it is widely acknowledged that access to capital markets by corporate issuers has to be incentivized. (See also Item 4.B, "Business Overview—EU Regulation Proposals—EU Financial Transactions Tax").

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

Laws governing the bankruptcy of individuals and regulations governing creditors' rights in Greece, Turkey and various SEE countries may limit our ability to receive payments on past due loans.

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. If the current economic conditions persist or worsens, bankruptcies could intensify, or applicable bankruptcy protection laws and regulations may change to limit the impact of the recession on corporate and retail borrowers. Such changes may have an adverse effect on 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, Turkey and other jurisdictions where the Group operates could limit the fees that banks may charge for certain products and services such as mortgages, unsecured loans and credit cards. If introduced, such laws could reduce 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.

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

Turkish operations through Finansbank, our Turkish subsidiary, represented 25.5% of our loans as at December 31, 2014 compared to 21.8% as at December 31, 2013 and accounted for 43.8% net interest income before provisions for loan losses for the year ended December 31, 2014 compared to 48.6% for the year ended December 31, 2013. As a result, the Group is subject to operating risks in Turkey, including the following:

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

Historically, Finansbank's principal sources of funds have included individual deposits. All of Finansbank's individual deposits are effectively short term deposits (the average maturity of individual deposits as at December 31, 2014 was approximately 63.6 days), which could expose Finansbank to liquidity risks if retail customers were to withdraw large amounts of their deposits or do not roll over their term deposits upon maturity. Although customer deposits have increased at December 31, 2014 by 10.1% compared to December 31, 2013 (in TRY terms), any loss in consumer confidence in Finansbank's banking operations could significantly increase the amount of individual deposit withdrawals in a short space of time or result in higher interest rates on individual deposits, which in turn could significantly increase Finansbank's cost of funding. Finansbank also relies heavily upon other types of short term liabilities in addition to individual deposits for its funding. As at December 31, 2014, 55.2% of Finansbank's borrowed funds and issued debt securities had maturity of less than one year. Given such reliance upon short term liquidity, there can be no assurance that, in the event of a sudden or unexpected shortage of funds in the banking system or otherwise, Finansbank will be able to maintain its levels of funding and at commercially reasonable terms.

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

The 2009 economic downturn had an adverse effect on the financial condition of some of Finansbank's corporate and retail customers and, in some instances, ultimately affected their ability to service and repay their obligations. This has led to an increase in Finansbank's loans that are non-accruing, accompanied by increased allowance for loan losses. Over time, Finansbank has grown its loan portfolio significantly, and increased its exposure to retail customers, whose loans generally yield higher interest income but also tend to have higher levels of default than loans of corporate customers. There can be no assurance that continued weakness in consumer spending, high unemployment, decreased profitability of corporate businesses, increasing numbers of insolvencies and/or deterioration of the credit quality of corporate customers will not result in continued increases in the levels of Finansbank's impaired loans in the future. This could in turn, have a material adverse effect on Finansbank's and the Group's business, results of operations and financial condition.

Finansbank's funding costs and its access to the debt capital markets may be affected by credit ratings.

Any reduction in the current long-term ratings of Finansbank or any of its principal subsidiaries by rating agencies may increase Finansbank's funding costs, limit access to the capital markets and trigger additional collateral requirements in derivative contracts and other secured funding arrangements. As a result, such a reduction could have a material adverse effect on Finansbank's ability to obtain financing, and consequently its business, financial condition and results of operations. In addition, any deterioration in NBG's credit rating or any decrease in Turkey's sovereign credit rating could affect Finansbank's ability to obtain financing and, in turn, Finansbank's and the Group's business, financial condition and results of operations.

Finansbank faces intense competition in the Turkish banking sector from private banks and Turkish government-owned financial institutions.

The Turkish banking sector is highly competitive and has in recent years undergone a period of consolidation. As at December 31, 2014, there were a total of 47 banks (excluding the Turkish Central Bank and four "participation banks" (i.e., interest free banking institutions)) licensed to operate in Turkey.

A small number of these banks have a significant presence in the industry. According to the Banks Association of Turkey's published reports, as at December 31, 2014, the top seven private banks in Turkey held 55.9% of the banking sector's total loan portfolio and 55.7% of the total bank assets in Turkey.

The intense competition may increase the pressure for Finansbank to expand the range and sophistication of its products and services currently offered as well as reducing its margins. Increased pricing competition in the Turkish banking markets through the offering of products at significantly lower prices may also impact customer behavior patterns and loyalty. Any failure to maintain customer loyalty or to offer customers a wide range of high quality, competitive products with consistently high levels of service could have a material adverse effect on Finansbank's and the Group's business, financial condition and results of operations. For example, Finansbank may not realize increased business volumes or expected value from the investment in its branch network, which has expanded from 582 branches in 2012 to 674 in 2013 and to 658 in 2014. In addition, state owned banks in Turkey have historically had access to inexpensive funding in the form of significant Turkish Government deposits, which has provided a competitive advantage over private banks.

Finansbank's increased exposure to intense competition in each of its key areas of operation, may, among other things, limit Finansbank's ability to increase its customer base, maintain customer loyalty, reduce its asset growth rate and profit margins on services it provides and increase competition for investment opportunities. There can be no assurance, therefore, that the continuation of existing levels of competition or increased competition will not have a material adverse effect on Finansbank's and the Group's business, financial condition and results of operations.

The Turkish banking sector has experienced significant volatility in the past.

The significant volatility in the Turkish currency and foreign exchange markets experienced in 1994, 1998 and 2001, combined with the short foreign exchange positions held by many Turkish banks at those times, affected the profitability and liquidity of certain Turkish banks. In 2001, this resulted in the collapse of several financial institutions. Following this crisis, the Turkish government made structural changes to the Turkish banking system to strengthen the private (i.e., non-governmental) banking sector and allow it to compete more effectively against the state owned banks. Notwithstanding such changes, the Turkish banking sector remains subject to volatility. If the general macro-economic conditions in Turkey and the Turkish banking sector in particular, were to suffer another period of volatility, there can be no assurance that this would not result in further bank failures, reduced liquidity and weaker public confidence in the Turkish banking system.

If Finansbank is required to hold higher levels of capital than anticipated by the market, this could have a material adverse impact on Finansbank's and the Group's business, results of operations and financial condition.

Finansbank is subject to a number of banking and other regulations in Turkey, in particular those of the Banking Regulation and Supervision Agency ("BRSA"). Under Turkish law, a bank's capital adequacy ratio must be greater than or equal to 8% within the framework of the Regulation regarding the Measurement and Evaluation of Capital Adequacy of Banks. Despite the 8% minimum capital adequacy ratio requirement, the BRSA's approach is, and will continue to be, to prohibit banks having a capital adequacy ratio of less than 12% from opening new branches. In accordance with these guidelines, because Finansbank intends to open new branches from time to time, it must maintain a capital adequacy ratio in excess of 12%. Furthermore, the BRSA is authorized to increase the minimum capital adequacy ratio or to set different ratios for each bank by taking into consideration such banks' internal control systems as well as their asset and financial structures.

Since June 2012, Turkish banks have been required to measure and report their capital adequacy in compliance with Basel II, as adopted in Turkey. Within the framework of Basel III, as adopted in Turkey, requirements regarding regulatory capital, liquidity, leverage and counterparty credit risk measurement are either required to be implemented or expected to be implemented gradually between 2014 and 2019. Although the impact on Finansbank's capital ratios from adopting Basel II was positive, requirements relating to the implementation of Basel III may have an adverse effect on Finansbank's capital ratios. Changes relating to Basel III, as well as any uncertainty in financial markets may change regulations or market expectations, which could have the result of banks having to hold higher capital levels than currently expected. Definitions of capital tiers may also be subject to further change. Any further changes could require Finansbank to maintain a capital adequacy ratio of greater than the 12% that is currently required by the BRSA. This could adversely impact the Finansbank's operational flexibility or ability to implement its growth strategy and could reduce income growth, which, in turn, could have a material adverse effect on Finansbank's and the Group's business, financial condition and results of operations.

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

Apart from our operations in the Hellenic Republic and Turkey, we have built up substantial operations in the SEE countries of Bulgaria, Romania, Serbia, FYROM and Albania ("SEE-5") and other developing economies. The Group's SEE operations accounted for 9.3% of our gross loans as at December 31, 2014 compared to 9.8% as at December 31, 2013 and 10.9% of our net interest income before provisions for loan losses at and for the year ended December 31, 2014 compared to 9.5% for the year ended December 31, 2013. 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.

There can be no assurance that the Bank will continue to satisfy the continued listing eligibility criteria of the listing rules of the ATHEX or the NYSE 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 Athens Exchange ("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.

The New York Stock Exchange ("NYSE") may commence delisting of our ADRs if the Bank fails to meet certain continued listing criteria, in particular the so-called "price condition". According to the "price condition", if the price of the ADRs falls below US$1 over a consecutive 30 trading-day period, the ADRs will be considered to be "below criteria" and subject to potential suspension and delisting procedures by the NYSE.

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

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

The principal trading market for our ordinary shares is the ATHEX. The ATHEX is less liquid than other major stock markets in Western Europe and the United States. As a result, shareholders may have difficulty assessing the past performance of the ordinary shares based on our prior trading record on the ATHEX. In 2014, the average daily trading value on the ATHEX was EUR 127 million, while in the first three months of 2015 it was EUR 116 million.

As at December 31, 2014, the aggregate market value of all shares listed on the ATHEX was EUR 69.4 billion, while as at March 31, 2015 it was EUR 48.8 billion. The market value of our ordinary shares listed on the ATHEX on December 31, 2014 and March 31, 2015 was EUR 5.2 billion and EUR 3.9 billion respectively, representing 7.5% and 8.0%, respectively, of the capitalization of all companies listed on the ATHEX. We cannot make assurances about the future liquidity of the market for our shares.

There may be limited liquidity resulting from the HFSF's concentrated ownership of our ordinary shares.

The HFSF is our most significant shareholder, holding 57.2% of our ordinary shares. This concentration of ownership, together with uncertainty as to whether market conditions will permit the HFSF to dispose, through the exercise of its warrants, of the ordinary shares it holds, may discourage, delay or prevent holders of the warrants from exercising their rights. Due to the potentially low trading volume of our ordinary shares, it may be difficult for you to sell our ordinary shares at the price or time of your choice, which may result in you receiving a lower price for our ordinary shares than would be the case if our ordinary shares were more actively traded on the ATHEX. We cannot assure you that the trading market of our ordinary shares will become more liquid in the future, or that the trading volume of our ordinary shares will not decrease further into the future.

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 report, 245,748,459 warrants issued by the HFSF were outstanding permitting holders to acquire, for each warrant held 8.22923881005499 Ordinary Shares, representing a total of 2,022,323,834 (or 57.2%) of our ordinary shares following the completion of the 2014 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. 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 2014 increase, we have 3,533,149,631 ordinary shares outstanding.

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:

The share price may also be subject to volatility due to the commitment of the HFSF to sell part or all of its shares in the Bank within certain time limits. In addition, brokers' estimates as to the value of our shares may not necessarily reflect the actual value of our shares at any given time, and investors should therefore not place undue reliance on such estimates as indicators of our future growth or profitability.

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

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

Under Greek Law and our Articles of Association, prior to the issuance of any new ordinary shares, 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, as 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 26% or 33% 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—Changes to Taxation—Taxation of Capital Gains from the Sale of Listed Shares). The capital gains of foreign natural 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 share holders are natural 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 174 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 March 15, 2012, the Bank acquired 10.21% of Banca Romaneasca from European Bank for Reconstruction and Development ("EBRD") through put and call arrangements as provided for in the 2005 shareholders agreement, between the Bank and EBRD. The total consideration paid amounted to EUR 26 million.

On October 5, 2012, NBG announced a voluntary share exchange offer (the "Tender Offer") to acquire all the outstanding ordinary registered shares, with a par value of EUR 2.22 per share, issued by Eurobank Ergasias S.A. ("Eurobank") at an exchange ratio of 58 NBG newly issued ordinary registered shares for 100 Eurobank shares. The merger process of the two banks was suspended in April 2013 and was ultimately not consummated.

On November 9, 2012, Finansbank disposed of 51.00% of its shares of its subsidiary Cigna Finans Pension to Cigna Nederland Gamma B.V. for consideration of TRY 203 million. Finansbank retains the remaining 49.00% and continues to operate Cigna Finans Pension through a formation of 51.00% / 49.00% joint venture.

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 is 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 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 (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 ACS 840-40 "Sale-Leaseback Transactions" in combination with the accounting guidance of ACS 360-20 "Real Estate Sales".

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 (the "Process"). Further to the transaction approval by the Council of Audit on June 5, 2014 the Sale and Purchase Agreement was executed on September 17, 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 a Variable Interest Entity ("VIE"), 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 are considering a solution within the context of existing competitive process. 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. (100.00% subsidiary of Astir Palace Vouliagmenis S.A.) continue to be presented as long-lived 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 that 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 owns 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.

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%).

The table below sets out the Group's principal items of capital expenditure for 2012, 2013 and 2014.

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

The table below sets out the Group's principal divestitures for 2012, 2013 and 2014.

Restructuring Plan approved by the Directorate General for Competition of the European Commission on July 23, 2014

The Group is subject to European Commission rules on EU state aid in light of the aid received from the HFSF and the Hellenic Republic. Similarly, the other Greek systemic banks are subject to European Commission rules on EU state aid. Under these rules, the Bank's operations are monitored and limited to the operations approved in the Restructuring Plan, which aims to ensure the Bank's return to long-term viability.

The Group participated in the PSI in 2012 and, as a result, recorded impairment losses on its Greek government bond portfolio and loans and receivables portfolio of EUR 11.8 billion in 2011 and impairment losses on its Greek government bond portfolio of EUR 0.2 billion in 2012. As a result of these losses, the Bank was compelled to seek support from the HFSF. On April 20, 2012, the HFSF provided the Bank with a commitment letter to participate in the share capital increase of the Bank. On May 28, 2012, the Bank entered into the Presubscription Agreement, which replaced the commitment letter and through which the HFSF advanced to the Bank EUR 7,430 million EFSF bonds against the total amount of recapitalization required by the Bank. Furthermore, on December 21, 2012, the HFSF contributed EFSF bonds, with nominal value of EUR 2,326 million as an additional advance for the participation in the Bank's future share capital increase. As at December 31, 2012, the Bank had received total funds of EUR 9,756 million from the HFSF. The amount finally contributed by the HFSF following completion of the 2013 share capital increase was EUR 8,677 million as at December 31, 2013, and together with the issuance of the Greek State Preference Shares, the total amount of state aid received by the Bank, in forms other than guarantees and liquidity assistance, was EUR 10,027 million as at December 31, 2013.

On July 27, 2012, the European Commission temporarily approved the state aid received by several Greek banks, including the Bank, for the recapitalization in the form of a commitment letter from the HFSF and the bridge recapitalization. In addition, the European Commission preliminarily assessed the compatibility of the measures under EU state aid rules in the internal market. Subsequently, the European Commission launched a formal, in-depth investigation into the measures.

In order for the European Commission to formally approve the state aid received, the Hellenic Republic was required to submit a restructuring plan for the Bank. On October 31, 2012 the Hellenic Republic submitted (through the Ministry of Finance) a restructuring plan for the Bank to the Directorate General for Competition of the European Commission in accordance with Greek Law 3864/2010. However, as a consequence of on-going consolidation and structural changes in the Greek banking sector and the Bank's 2013 and 2014 share capital increases, the submitted restructuring plan was required to be amended in order to reflect the Bank's situation. The European Commission thus requested re-submission of the restructuring plan. The amended plan was submitted on June 25, 2014 after the completion of the share capital increase.

The revised restructuring plan was approved by the European Commission on July 23, 2014 (the "Restructuring Plan"). The European Commission assessed the Restructuring Plan under EU state aid rules for the restructuring of banks during the financial crisis and concluded that it was in line with its rules on banking restructuring.

Pursuant to the Restructuring Plan, the Bank gave a number of commitments, both structural (such as the disposal of certain assets and subsidiaries) and behavioural, towards the European Commission. The implementation of the commitments set out in the Restructuring Plan is monitored by the Monitoring Trustee. Among other commitments, the Bank has committedto reduce its shareholding in Finansbank, so that its share ownership represents no more than 60% by the end of 2015. As of the date of this Annual Report, the Bank does not have any intention to reduce its ownership stake in Finansbank to below this level of 60%, though there can be no assurance that the Bank may not in the future determine to further reduce its ownership of Finansbank.

In case the Bank breaches the commitments under the Restructuring Plan, including in respect of the disposals mentioned above, the European Commission may revoke its approval and impose additional measures on the Bank. In addition, under the terms of the Relationship Framework Agreement to which the Bank is a party, the HFSF may, upon any breach by the Bank of any material obligation included in the Restructuring Plan or facilitating its implementation, be able to exercise full shareholder voting rights in respect of its shareholding of the Bank's common shares, 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 after the Amended Recapitalization Framework—The Relationship Framework Agreement" and Item 3.D, "Risk Factors—Risks Relating to Our Recapitalization and Receipt of State Aid".

In July 2013, the Bank of Greece engaged BlackRock, a U.S.-based investment, advisory and risk management company, to conduct an independent diagnostic study on the loan portfolios of the Greek commercial banks, including the Bank, in accordance with the commitment undertaken by the Bank of Greece under the Program. The study was similar in scale to BlackRock's 2012 diagnostic exercise of Greek systemic banks' loan portfolios.

BlackRock's diagnostic assessment comprised four workstreams (namely, Asset Quality Review, Credit Loss Projections, Troubled Assets Review and Foreign Loan Book) and was conducted on June 30, 2013 balances prepared in accordance with IFRS as endorsed by the EU, utilizing assumptions and estimations based upon publicly available information as of the fourth quarter in 2013. In contrast to the mandate received in connection with its 2011 diagnostic exercise, BlackRock was directed to use data from a wider variety of sources and extend the scope of its review, including conducting a diagnostic assessment of seven smaller Greek banks in addition to the four systemic banks that were originally assessed with their Greek and foreign banking subsidiaries). The Bank of Greece sought to align BlackRock's methodology with the anticipated methodologies of the ECB, which began collection information for its asset quality review of banks within the European Union as a part of its comprehensive assessment. BlackRock expanded the scope and methodology of its review by, among other things:

BlackRock completed its diagnostic assessment at the beginning of 2014 and drew conclusions as to the CLPs in either a three-and-a-half-year period or during the receivables' portfolio life under two scenarios, one baseline and one adverse. With respect to the Bank, BlackRock estimated three-and-a-half-year CLPs of EUR 5.2 billion (baseline scenario) and EUR 6.2 billion (adverse scenario) and estimated lifetime CLPs of EUR 8.4 billion (baseline scenario) and EUR 11.2 billion (adverse scenario) for the Bank's Greek loans. All analyses were based on financial statements prepared in accordance with IFRS as endorsed by the EU.

In March 2014, in the context of the Bank of Greece's 2014 Stress Tests, the Bank of Greece disclosed BlackRock's report, together with the Bank of Greece's detailed findings of the capital needs of each bank. This stress test was conducted in the last quarter of 2013 and was based on the banks' financial data as of June 30, 2013 (prepared in accordance with IFRS as endorsed by the EU). The key

drivers of the capital requirements were CLPs on total loans granted in Greece and abroad and estimated pre-provision income of the banks, based on what the Bank of Greece expressed to be a conservative adjustment of restructuring plans submitted by the Greek banks to the Bank of Greece. The capital needs of all Greek banks were estimated on the basis of the baseline scenario at EUR 6.4 billion and on the basis of the adverse scenario at EUR 9.4 billion. The Bank of Greece determined the capital needs of the Bank, under the baseline and adverse scenarios, in a three-and-half-year period, amounted to EUR 2.2 billion and EUR 2.5 billion, respectively. BlackRock estimated that the Bank's lifetime CLPs as a percentage of Greek loan balances as at June 30, 2013, in the baseline scenario, was 18.1%. The CLP for Greek risk, at EUR 8.7 billion, had a coverage ratio of 73.7% as at June 30, 2014, based on a stock of provisions of EUR 6.5 billion as at the same date.

The Bank of Greece used the CLPs calculated in BlackRock's diagnostic assessment to determine the capital needs of the banks subject to the stress test. As a prudential measure, the Bank of Greece adopted what it has indicated is a conservative stance with respect to provisions, requiring that Greek banks, including the Bank, maintain provisions at the end of 2016 sufficient to cover (a) at least 95% of the lifetime losses estimated by BlackRock under the baseline scenario and 85% of the losses estimated under the adverse scenario and (b) at least 52% of the non-performing loans ("NPLs") estimated by BlackRock as at the end of the three-and-a-half-year period under the baseline scenario.

In addition, in relation to DTA, the Bank of Greece maintained its prudential approach consistent with the methodologies it utilized in its 2011 diagnostic assessment, capping existing DTA at 20% of total Core Tier 1 capital and assuming no new DTA creation during the stress test period.

The Bank of Greece estimated the Bank's internal capital generation over the period June 2013 to December 2016, in the baseline scenario, at EUR 1.5 billion (source: Bank of Greece press release published March 6, 2014).

The Bank presented to the Bank of Greece on April 10, 2014, its capital plan with respect to the shortfall determined above which included the completed share capital increase of EUR 2,500 million and certain capital actions amounting to EUR 1,040 million, which was approved by the Bank of Greece on April 11, 2014.

As of November 1, 2014, all significant supervised entities in the Eurozone, including us, are under the direct supervision of the SSM. Before ECB assumed its supervisory responsibilities, we and 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. Results of the EU-wide Comprehensive Assessment 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 AQR was based on financial data presented in accordance with IFRS as endorsed by the EU.

The Adverse Dynamic Balance Sheet stress test, which was based on our 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 to the SSM, as a capital plan the above approved Adverse Dynamic Balance Sheet scenario and the results of operations for the six month period ended June 30, 2014, which result in a capital surplus of more than EUR 2.0 billion and concluded that no further capital action is required.

The detailed results of the Comprehensive Assessment along with actions addressing the shortfall are presented below:

The Adverse Static Balance Sheet stress test resulted in a capital shortfall of EUR 933 million after the application of proceeds from the EUR 2.5 billion share capital increase completed in May 2014. This shortfall has already been covered by NBG's PPI, lower-than-modeled impairment and capital actions completed by December 31, 2014 amounting to EUR 1,057 million. The above figures do not take into account the capital benefit created by the new DTC Law.

PPI for the year ended December 31, 2014, lower-than-modeled impairment and capital actions completed by end-2014, amounting to EUR 1,057 million, comprised:

NBG holds a significant position in Greece's retail banking sector, with 528 branches and 1,414 ATMs as at December 31, 2014. Our core focus outside of Greece is in Turkey and SEE, where we

currently operate in Bulgaria, Serbia, Romania, Albania, Cyprus and FYROM. 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 60.9% of our total assets as at December 31, 2014. The Bank's liabilities represent 67.4% of our total liabilities as at December 31, 2014. While the Bank conducts most of our banking activities, it is supported by eight non-Greek banking subsidiaries: Finansbank A.S. ("Finansbank"), United Bulgarian Bank AD—Sofia ("UBB"), Vojvodjanska Banka A.D. Novi Sad ("Vojvodjanska"), Banca Romaneasca S.A. ("Banca Romaneasca"), Stopanska Banka A.D.—Skopje ("Stopanska Banka"), the National Bank of Greece (Cyprus) Ltd. ("NBG Cyprus"), 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, 2014, we had the largest market share of mortgage loans in Greece, with a percentage of 26.2%, whereas according to our internal analysis of published information of the Bank of Greece, we are second in total deposits with a percentage of 25.3%. We are also third in mutual fund management with a market share of 14.0% 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 64.9% of our total lending activities as at December 31, 2014 (the "Greek Banking Loans") and for the 71.6% 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 deposits as at December 31, 2014:

As at December 31, 2014 we operated in Greece through 528 branches (including one premium branch in Golden Hall) and one private banking unit. As at December 31, 2014, we had 1,414 ATMs, of which at least 561 were situated in key locations such as supermarkets, metro stations, shopping centers, hospitals and airports (57% of our ATMs are equipped with cash deposit devices). During 2014, the total number of ATM transactions reached approximately 112 million with a total value of approximately EUR 16.5 billion. In addition, we have developed alternative distribution channels, such as an e-banking platform targeted at both corporate and retail clients. During 2014, the total number of phone and internet banking users increased by 15%, reaching approximately 870 thousand, out of which 550 thousand were also phone banking users. The total number of electronic transactions during 2014 was approximately 69 million with a total value of approximately EUR 25 billion. We operate a contact center, through which the Bank provides information and transaction services through the use of a voice portal and a manned help desk, which began operation in 2007. In 2012, we launched one 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. As at December 31, 2014, the "i-bank" stores have received more than 550 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, 2014, the Bank operated 258 full banking branches, 269 retail banking branches and one premium banking branch.

We participate in DIAS Interbanking Systems S.A., which currently has 27 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.

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

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".

We offer payment services to our clients participating in all local interbank payment channels. We are also a direct member of the Euro interbank channels of TARGET, TARGET2, EBA for Euro 1, Step 1 and Step 2. As a member of Step 2, the Bank is the main Greek entry point for Eurozone payments. For payments, especially outside the Eurozone, the Bank maintains a global network of correspondent banks. The Bank has completed the centralization of its payment operations. Our Cash Management service offering in Greece is Single Euro Payments Area ("SEPA") and compliant with Directive 2007/64/EC on the Payment Services Directive ("PSD"), and also leverages extensively the Bank's branch network in providing our customers with on-line 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 adopted a more conservative approach to new consumer lending, with a greater emphasis on risk-averse lending criteria. As a result, we experienced a reduction in balances in 2013 and 2014.

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 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 2014 the Bank mainly focused on offering competitive and flexible debt restructuring packages. As a result, the balance of consumer loan portfolio decreased by 9.7% from EUR 6,212 million as at December 31, 2013 to EUR 5,612 million, as at December 31, 2014.

The Bank's efforts are focused on effective management of the existing portfolio in order to prevent further deterioration through the design and implementation of debt restructuring packages, which offer 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 the restructuring, all consumer loan and credit card exposures 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 40 years given an additional collateral is obtained. In addition, the Bank offered to customers still experiencing problems in servicing their restructured debt, new products by offering a fractional payment programs with lower monthly installments.

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 purposed consumer loans such as "auto loans" and "green loans" and on the further growth of debit cards portfolio.

In 2015, the Bank has invested in new technologies especially in the cards business in order to improve its position in the domestic market.

The volume of new mortgage loan disbursements amounted to EUR 44 million in 2014, from EUR 28 million in 2013. Average Loan-to-Value ratio ("LTV") for 2014 new originations stood at 53.8%, compared to 54.5% in 2013 and Payment-to-Income ratio ("PTI") at 24.1% from 21.0% in 2013 (maximum PTI is set at 40% by the Bank of Greece). The approval rate in 2014 was 63% compared to 49% in 2013 and 29% in 2012. Moreover, pricing stood at an average spread of 361 bps, in line with 2013.

The mortgage loan portfolio, before any provision for impairment, was EUR 17.4 billion at December 31, 2014 compared to EUR 17.7 billion at December 31, 2013.

The Bank placed more focus on efficiently managing its existing loan portfolio, following a customer-centric service, with emphasis on delinquent loans by offering viable solutions to customers facing economic difficulties, including the adoption of a fractional payment program, whereby the

borrower pays only a fraction of the installment due for a fixed period of time, adjusted to the borrower's current economic condition. All adopted policies offered the possibility of a maturity extension up to 45 years in total, with the applied spread being increased by 30 bps and the minimum spread set at 200 bps. All facility programs assume no capital relief and also aim at capital amortization.

As at December 31, 2014, EUR 3.1 billion of mortgage loans were reported as restructured. The average duration of the restructured portfolio is 34 years, or 8.5 years more than the non-restructured portfolio, while the average spread is 234 bps, or 49 bps higher than the non-restructured portfolio.

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.

The SBL Unit has created business credit centers in the main three urban centers (Athens, Thessaloniki and Patras) which handle all of the Bank's credit applications in accordance with applicable credit and collection policy and approved authority levels. In 2014, the SBL Unit focused both on new strategic initiatives to support SBL financing and on the active management of the existing portfolio.

The Bank continued to support SBLs who experienced difficulties in servicing their debt obligations—either for the first time or even if they had been placed under a restructuring program before—by agreeing upon more favorable terms and conditions for the restructuring of their debts. The relevant products offered by SBL Unit are rescheduling, restructuring and restructuring over restructuring ("R-O-R") programs, depending on the type and delinquency bucket of SMEs accounts. The main characteristics of restructuring programs are: the granting of a grace period of up to 2 years, during which the borrower pays only interest, the extension of up to 20 years on the maturity of all loan accounts of the customer, and the application of lower interest rates in case that new collaterals are pledged.

As at December 31, 2014, the Bank's gross outstanding SBL portfolio amounted to EUR 3,892 million, decreased by 4.6% compared to EUR 4,080 million at December 31, 2013.

The Bank continued to support timely SBL customers by providing them necessary liquidity. New loans granted to SBL amounted to EUR 141 million for the period ended December 31, 2014.

The SBL Unit offers lending solutions, which cover a full range of business credit needs, either in the form of revolving facilities for the coverage of working capital needs or in the form of short-, medium-or long-term fixed loans for financing investment needs or for the enhancement of business liquidity.

In addition, the Bank continued in 2014 to support SBL customers financing by participating in programs for the improvement of competitiveness and the enhancement of SBL liquidity in the current adverse financial environment in Greece. In particular, the Bank participated in the following new co-financed and other state guarantee and funded programs:

The Bank's commercial loan portfolio in Greece comprises approximately 43,000 active corporate clients, including SMEs, and most of the largest corporate groups in Greece. As a Group, we are able to offer corporate clients a wide range of products and services, including financial and investment advisory services, deposit accounts, loans denominated in euro and other currencies, foreign exchange services, insurance products, custody arrangements and trade finance services.

The Bank lends to all sectors of the economy. As at December 31, 2014, domestic commercial lending (including loans to the public sector) amounted to EUR 25.6 billion and represented 52.7% 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 2.2 billion as at December 31, 2014, representing 4.5% 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 letters of credit and guarantees for its customers, which amount to EUR 3.3 billion as at December 31, 2014.

As a result of the ongoing economic crisis in Greece, the Bank has adopted a more conservative approach to new commercial lending, with a greater focus on larger corporate borrowers having good credit history, satisfactory financial performance and adequate collateral and/or new equity available.

During 2014 the Bank has successfully launched a program of extending new loans of up EUR 3.0 billion of which EUR 718 million was allocated to medium size enterprises, providing financial support to existing and new sustainable investments aimed at enhancing the competitiveness, innovation and outward orientation in business and new jobs creation.

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, 2014, outstanding shipping loans (mainly concerning bulk shipping) were EUR 2.2 billion. Shipping exposure represents 8.7% of the Bank's total commercial loan portfolio.

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

For 2014, the Bank has increased its exposure by participating in new transactions with accredited customers but with strict terms regarding vessel quality and equity contribution. Loan modifications took place, reflecting current market conditions and low freight rates in the dry bulk sector. For 2015 the Bank is expected to follow a similar pattern.

The shipping industry is highly cyclical, experiencing volatility in revenues and cash flows resulting from changes in the demand and supply of vessel capacity. During previous years, freight rates in main shipping segments have been kept in rather low levels. In the last quarter of 2014 the wet sector has showed a significant upward trend due to the fall of oil price. For 2015, the dry bulk shipping is expected to be affected by increased tonnage supply and modest demand for shipping services, while for the wet bulk there seems to be a more optimistic view.

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, the growth rate of Bank's activities in the field of project finance during 2014 remained stable, with the overall size of this portfolio of EUR 413 million as at December 31, 2014, a decrease of 1.0% compared to EUR 417 million as at December 31, 2013.

The voluntary deleveraging effort undertaken by the Bank since the beginning of 2011, regarding its international portfolio, continued in 2014. Therefore no new loans were advanced in 2014 for projects outside Greece, and the concurrent effort to reduce position in loans with low margins resulted in a decrease in the international portfolio of 27.7%. On the contrary, the domestic loan portfolio was increased by 56.6% or EUR 74 million during the year. The bulk of the net increase in domestic loan portfolio during 2014 was due to new placements to energy and Public Private Partnership / Project Finance Initiative ("PFI") factors. Major part of pipeline for the next year consists of PFI projects in the waste management sector.

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). The lots correspond to Attica, Western Greece and Ionian Islands Regions. JESSICA funds, along with the Bank's and other private funds, are 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 2014, 45 investment proposals, of a total budget of EUR 432 million and UDF-requested funds of EUR 173 million. UDF financing of EUR 40 million has been approved and financial close of the respective projects is expected to take place during the first quarter of 2014. Disbursement of UDF funds to signed projects in 2014 amounted to EUR 8 million. The first phase of the evaluation (determination of eligibility for JESSICA financing) was also completed in 2014 for proposals of a total budget of EUR 89 million and UDF-requested funds of EUR 31 million. In 2015, the UDF will focus on the financial evaluation for the approval of financing and the respective commitment of UDF funds for these proposals, as well as on the evaluation of all other outstanding proposals and on the disbursement of UDF funds to final recipients.

Advisory activity in 2014 to the public and private sector developed at a considerably lower pace compared with that of previous years, as the execution of certain projects was postponed and/or suspended by the Greek government in the context of the current economic environment.

In order to effectively manage past-due and non-accruing corporate loans as well as loans for which legal actions have been undertaken by the Bank, while being also compliant 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, we established of the Special Assets Unit which comprises of:

These divisions in co-operation and with the support of the Special Assets Administrative Support Division and the Special Assets Control and Operational Support Division have full responsibility for the management of portfolio transferred to SAU (end-to-end responsibility).

Specifically, SAU proceeds to modifications and restructuring solutions to enterprises which are facing difficulties meeting their obligations and have operational and financial weaknesses. The SAU assesses the companies, taking into consideration a number of factors, including: the company's viability, the company's ability to repay its debt, the market conditions including competition and the industry in which it operates. Following the assessment, SAU proposes loan modification or /and restructuring solutions, so as to achieve a sustainable financial and operational restructuring of these entities.

The total balance of SAU's Troubled Debt Restructuring ("TDR") loans amounted to EUR 1.4 billion as of December 31, 2014.

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, 2014, 75.0% of the finance lease receivables of Ethniki Leasing were to the trading and services sector, 14.0% to industry and mining, 9.9% to construction and real estate and 1.2% to other sectors. As at and for the year ended December 31, 2014, Ethniki Leasing had total assets of EUR 530 million and interest income of EUR 24 million, before elimination of intercompany transactions and balances, compared to EUR 570 million and EUR 19 million, respectively in 2013.

Probank Leasing leases land and buildings, machinery, transport equipment, furniture and appliances, computers and communications equipment. As at December 31, 2014, 41.9% of the finance lease receivables of Probank Leasing were to the trading and services sector, 2.8% to construction and real estate, 36.9% to industry and mining and 18.3% to other sectors. As at and for the year ended December 31, 2014, Probank Leasing had total assets of EUR 155 million and interest income of EUR 8 million, before elimination of intercompany transactions and balances, compared to EUR 211 million and EUR 6 million, respectively in 2013.

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. Additionally, the NBG Group has a strong presence in the provision of factoring services in Southeast Europe and Eastern Mediterranean by the Group's

subsidiaries in Turkey, Bulgaria and Romania. 2014 was the sixth consecutive financial year during which Ethniki Factors continued to focus on enhancing liquidity to NBG 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 of the Greek economy over the last six years.

In 2014, the NBG Securities' Investment Banking Division continued to provide a broad range of services within the areas of Corporate Finance, Equity Capital Markets and Debt Capital Markets and succeeded in increasing its market share within a challenging economic environment despite increased competition. We served as a lead underwriter and advisor to Lamda Development's share capital increase; acted as an advisor, lead underwriter and bookrunner to ELTECH Anemos' initial public offer; acted as a financial advisor a) to Lykos AG in connection with the voluntary tender offer for the shares of Inform Lykos S.A.; and b) to NBG Pangaea REIC in connection with the mandatory tender offer for the shares of MIGRE; provided a fairness opinion to the Board of Directors of Cyclon S.A. in relation to the tender offer launched by Motor Oil S.A.; acted as joint bookrunner in the international bond offerings of Public Power Corporation S.A., Motor Oil S.A., Hellenic Petroleum S.A. and Titan Cement Company S.A..

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 European Stability Mechanism ("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 being while remaining sensitive to scrutinizing and closely monitoring client's risk-return profile.

The Bank offers custody services to foreign institutional clients investing in the Greek and Cypriot markets, in addition to providing clearing services to remote members of the ATHEX and services to domestic institutional clients investing globally. Especially in SEE, the Bank is using, as sub-custodians, its subsidiaries in the region. The Bank also offers custody services to its retail customer base.

The range of services the Bank offers includes trade settlement, safekeeping of securities, corporate action processing, income collection, proxy voting, tax reclamation, paying agency, underwriting, customized reporting and regular market flashes.

As at December 31, 2014, the Bank serviced 59 domestic institutional clients (three mutual funds, four asset management companies, 12 insurance companies, five brokerage companies, 26 pension funds and nine other companies), 25 foreign ones and approximately 308,000 retail 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 for the Greek market, in the Agent Banks Surveys of the "Global Custodian" magazine, for the past six consecutive years.

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

NBG Asset Management offers twenty (20) investment funds under the brand name Delos, two (2) under the NBGAM brand name, one (1) under the N. P. INSURANCE brand name and three (3) under the NBG International SICAV brand name, which are registered in Luxemburg. NBG Asset Management offers a wide range of investment products that provide to institutional and private investors access to significant markets in stocks, bonds and money market products, in Greece and internationally.

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

As at December 31, 2014 NBG Asset Management's total assets under management in mutual funds and discretionary asset management were EUR 1.3 billion. Its market share in mutual funds in Greece was 14.0% as at December 31, 2014, compared to 15.6% as at December 31, 2013. (Source:

Hellenic Fund and Asset Management Association—report of December 31, 2014). The funds belong to a client base comprised of approximately 80 institutional and over 45,000 private investors.

NBG Securities S.A. (formerly, National Securities S.A.) was established in 1988 and constitutes the Bank's brokerage arm. NBG Securities S.A. offers a wide spectrum of investment services to both individual and institutional customers.

As at December 31, 2014, NBG Securities S.A. had a market share of 8.3% of trades brokered by total trading volume on the ATHEX, ranking third in terms of total trading volume, according to www.helex.gr.

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 S.A. network consists of seven branches, three of which are in London, Bucharest and Nicosia.

With offices in London, Paris and Istanbul, NBGI Private Equity Limited ("NBGI Private Equity"), a subsidiary of NBGI International Ltd, manages the private equity funds described below.

NBGI Private Equity had invested amounts of EUR 472 million as at December 31, 2014, compared to EUR 470 million at December 31, 2013.


Fund	Closing Date	Invested amounts	Geographic Focus
		(in millions)
NBG Private Equity Fund LP	August 2000	GBP 25	UK
NBGI Private Equity Fund II LP	June 2007	GBP 50	UK
NBGI Private Equity (Tranche II) LP	August 2011	GBP 34	UK
NBG South Eastern Europe Fund LP	March 2006	EUR 55	SEE
NBGI SEE Development Capital Fund LP	March 2007	EUR 37	SEE
NBGI SEE Real Estate Fund LP	October 2009	EUR 96	SE and Central Europe
NBGI SEE Energy Fund LP	October 2008	EUR 14	Predominantly Central & Eastern Europe, and selectively Western Europe
NBGI Private Equity France Fund LP	December 2009	EUR 32	France and other French speaking countries
NBGI Turkish Private Equity Fund LP	October 2008	EUR 30	Turkey
NBG Technology LP	October 2001	EUR 30	Predominantly Europe
NBGI Technology Fund II LP	October 2009	EUR 35	Predominantly Europe & US

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

We operate, as a Group, in 11 countries outside Greece. As at December 31, 2014, 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.

NBG Group policy over the last decade has been to focus on the Bank's regional position in SEE by strengthening our existing network and expanding into growing markets through acquisitions and greenfield start-ups that present low banking penetration and greater profit margins and also to withdraw from mature markets where growth prospects are limited. In particular, we seek to develop our wholesale banking business by targeting major financial centers to which we can offer Greek and Balkan lending exposure.

In 2014, our Turkish operations contributed EUR 168 million of net income to the Group, compared to EUR 682 million in 2013. Turkish operations' income before income tax was EUR 219 million as at December 31, 2014 and EUR 831 million as at December 31, 2013. As at December 31, 2014, total loans was EUR 19,082 million while total deposits (excluding interbank deposits) reached EUR 14,790 million, compared to EUR 15,968 million and EUR 12,883 million, respectively, as at December 31, 2013. Total assets of our Turkish operations as at December 31, 2014

were EUR 27.4 billion, accounting for 25.3% of our total assets compared to EUR 23.5 billion and 22.0% as at December 31, 2013.

Retail loans of Turkish operations amounted to TRY 23.8 billion as at December 31, 2014, compared to TRY 25.9 billion as at December 31, 2013 whereas retail sector deposits amounted to TRY 25.8 billion compared to TRY 23.4 billion for the same dates.

Corporate and commercial loans of our Turkish operations amounted to TRY 30.6 billion as at December 31, 2014 compared to TRY 21.7 billion as at December 31, 2013, whereas corporate and public sector interest bearing deposits amounted to TRY 13.0 billion compared to TRY 12.1 billion for the same dates.

As at December 31, 2014, loans comprised the largest single component of Finansbank's assets, followed by other assets and securities. Based on BRSA data, as at December 31, 2014, Finansbank had among the second highest proportion of its assets in loans and among the lowest in securities, in each case on a bank-only basis, of five peer banks. For the year ended December 31, 2014, revenue from customer business, comprising interest income from loans, fees and commissions received, and foreign exchange gains or losses, was the predominant source of Finansbank's bank-only revenue, followed by revenues from securities, comprising interest income from securities and securities trading gains or losses but excluding gains or losses from financial derivatives. For the year ended December 31, 2014, based on BRSA data, Finansbank derived the highest proportion of its revenue from revenue from customer business and the smallest proportion from revenue from securities, in each case on a bank-only basis, of five peer banks.

Finansbank's group of companies includes Finans Invest, Finans Leasing, Finans Portfolio Management, Finans Investment Trust, Finans Factoring, IBTech and EFinans. Finansbank was the fifth largest private bank in Turkey in terms of total assets, loans and deposits as at December 31, 2014, 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, 2014, Finansbank operated through a network of 658 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 BRSA. As at December 31, 2014, Finansbank and its subsidiaries had 13,949 employees. The Group intends to significantly increase the size of its loan book by focusing on growth in its SME and corporate and commercial loan portfolio, while selectively growing its retail loan portfolio.

As at December 31, 2014, Finansbank maintained a branch network of 658 branches, consisting of 633 full-service branches, 18 retail-only branches, one corporate-only branch and one commercial-only branch located in 62 commercial centers in Turkey, mainly in Istanbul, Izmir, Ankara and Antalya. The Group also has one branch at the Atatürk Airport Free Trade Zone in Istanbul and one branch in Bahrain. The Group has dedicated certain branches, which are located primarily in upper-middle-income residential areas, to retail customers. The continuous expansion of the Group's branch network until 2014 has allowed the Group to organically grow its customer base.

Finansbank retail banking activities consist primarily of consumer lending, credit and debit card services, mortgages, deposits and investment management and insurance products. The Bank's offerings to retail customers are divided into three main further sub groups: private banking, which serves

individuals with assets under management exceeding TRY 750,000 through customized service offerings; the affluent segment, which serves individuals with assets under management between TRY 100,000 and TRY 750,000 offering features such as dedicated relationship managers and a diverse set of banking and non banking services and benefits; and the mass market segment with more standardized offerings. Retail banking has been one of the principal drivers of Finansbank's growth in recent years and is expected to continue to maintain a central role in its strategy.

Income from Finansbank retail banking activities includes net interest income from loans and advances to retail customers and deposits collected from individuals, as well as fee and commission income received from loan underwriting, asset management services, life insurance and property and casualty insurance products, credit and debit card related services, settlements and cash related transactions with or for individuals.

Finansbank's retail banking operations are divided into two main divisions: Consumer Banking and Credit Cards. Consumer Banking operations are further divided into three sub divisions, namely private banking, affluent banking and mass market banking.

As at December 31, 2014, Finansbank had approximately 9.6 million retail banking customers, compared to approximately 12.1 million retail banking customers as at December 31, 2013. Finansbank's market share in time deposits is 4.6% as at December 31, 2014 and 4.6% as at December 31, 2013, according to statistics published by the BRSA.

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

Finansbank earns interest income on outstanding credit balances, transaction commissions from merchants, cash withdrawal fees, annual membership fees from cardholders and other service based fees such as insurance fees and payment fees from its credit card business. As at December 31, 2014, the number of credit cards issued by Finansbank exceeded 4.5 million, representing 8.5% of the total Turkish credit card market, according to statistics published by the Interbank Card Center ("ICC") and the number of member merchants was approximately 198,378. Within the Turkish credit card market, Finansbank was the third largest Visa card issuer in terms of the number of cards issued, according to statistics published by the ICC. The number of CardFinans commercial credit cards in issue was approximately 489,182 as at December 31, 2014, representing 17% of the total Turkish commercial credit card market, according to statistics published by the ICC. The number of point of sales ("POS") terminals of CardFinans reached 241,556 as at December 31, 2014, representing 7.9% market share, according to statistics published by the ICC.

Finansbank Group's total credit card loan portfolio was TRY 9.6 billion as at December 31, 2014 compared to TRY 12.1 billion as at December 31, 2013. Finansbank Group's fees and commissions from credit card operations amounted to TRY 488 million for the period ended December 31, 2014, compared to TRY 386 million for the period ended December 31, 2013.

Finansbank offers payment services to its corporate, commercial and retail clientele such as payment of invoices, suppliers, utility bills, social security, taxes, foreign exchange transactions, funds transfer as well as cash payments for particular clients.

Private banking helps customers build and preserve their financial wealth through tailored investment strategies and offers its customers time deposits, mutual funds, emerging market bonds, domestic and international equities, government bonds, corporate bonds, currency exchange, forward contracts, futures, options and structured products. The private banking sub-segment supports all of the Group's business lines (retail, corporate and commercial) and cooperates with Finans Portfolio Asset Management and FinansInvest to execute and advise clients' transactions.

Finansbank's SME banking activities consist primarily of revolving credit lines, installment loans, overdrafts, business housing loans and demand deposits. The goal of the SME Banking Department is to achieve sustainable and profitable growth by determining customer needs and providing quick and tailor made solutions. Finansbank's SME banking operations are divided into a medium enterprises department and a small business department.

Finansbank corporate and commercial banking activities include trade finance, traditional lending, project finance, cash management, corporate syndication and secondary market transactions, deposit taking and the issuance of certificated debt instruments. Corporate and commercial banking was the Bank's original focus area and now serves a large number of customers.

Finansbank offers loan facilities predominantly in Turkish Lira, U.S. Dollar and Euro. Turkish Lira loans are generally short term in nature, usually with maturities ranging from overnight to 365 days and are principally for working capital financing. However, Finansbank also extends medium term loans with maturities between 365 and 730 days mainly to finance working capital requirements. Finansbank also extends longer term facilities to corporate customers in Turkey for industrial and manufacturing investment purposes in different sectors and project financing. In relation to both its domestic and foreign operations, Finansbank provides facilities to various industries through letters of guarantee, bid bonds and foreign trade products. Finansbank aims to increase its market share in loans by using conventional banking products as well as cash management products and by applying competitive pricing policies.

Finansbank's Project and Structured Finance Group has taken an active role mainly as lead arranger in financing many projects, including privatizations, acquisitions and infrastructure projects, which have contributed to the growth of the Turkish economy. The Project and Structured Finance Group prepares loan proposals and project evaluation reports including cash flow projections and manages the Credit Committee approval process. Once loans are approved, legal documentation and disbursement phases as well as the bank to bank relations are managed by the Project and Structured Finance Group. Throughout the maturity of all loans under its responsibility, the Project and Structured Finance Group performs the initial evaluation of all waiver/amendment requests before passing them along to the Credits Department should any formal approval be required.

In addition to providing credit facilities, the Group provides cash management services to its corporate, commercial, and retail customers. Cash management services include direct debiting for payment of invoices, supplier finance systems, utility bills, social security, tax payments, cash in transit services and providing foreign exchange transfers and remittance services as well as cash management solutions tailored for individual customers. The Group's trade financing activities consist of pre-export

financing, import financing, issuing, confirming and discounting export and import letters of credit and letters of guarantee, and availing and discounting export and import drafts and promissory notes.

The Bank's international operations (other than those in Turkey) 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 319 million or 11.3% of net interest income before provisions for loan losses of the Group and accounted for EUR 9.2 billion or 8.5% of the Group's total assets as at and for the year ended December 31, 2014. Total loans were EUR 7.2 billion at December 31, 2014, a decrease of 2.3% from EUR 7.4 billion at December 31, 2013, whereas deposits (excluding interbank deposits) increased to EUR 6.7 billion at December 31, 2014, in comparison to EUR 6.5 billion at December 31, 2013.

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, 2014, 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, 2014, net loans of the Bank's Cyprus and Egypt operations were EUR 253 million and EUR 100 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, 2014:

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, 2014 the Bank held a 99.91% interest in UBB. At December 31, 2014, UBB's distribution network included 199 units: 125 "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 30 offices and operated over 744 ATMs and over 10 thousand POS terminals in Bulgaria.

During 2014, the Group has initiated proceedings for the disposal of its shareholding in UBB AIG. UBB owns 30.00% of the entity's share capital. The process is expected to be completed in 2015.

Selected financial information with respect to UBB as at and for the year ended December 31, 2014, 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 115 banking units in Bucharest and other cities in Romania as at the end of 2014. The Bank acquired Banca Romaneasca in October 2003 and as at December 31, 2014 held 99.28% of its share capital.

Selected financial information with respect to Banca Romaneasca as at and for the year ended December 31, 2014, 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, 2014, 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, 2014, Stopanska Banka had 65 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, 2014, 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, 2014, Vojvodjanska's 109 branches serve over 1.3 million private accounts and around 100 thousand company accounts.

Selected financial information with respect to Vojvodjanska as at December 31, 2014, is provided in the table below:

NBG Cyprus, headquartered in Nicosia, had 13 branches, one satellite branch and one foreign exchange bureau as at December 31, 2014. Since 2011, NBG Cyprus operates, also, 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, 2014, is provided in the table below:

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

NBG Malta has attracted significant business volumes from Turkish corporates 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 to Romanian companies and also granted loans to intragroup leasing companies in Romania, Serbia and Bulgaria.

Selected financial information with respect to NBG Malta as at December 31, 2014 is provided in the table below:

NBG Albania, headquartered in Tirana, as at December 31, 2014, 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, 2014, 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. In December 2014, the entity proceeded with a share capital increase of ZAR 86 million.

Selected financial information with respect to SABA as at and for the year ended December 31, 2014, is provided in the table below:

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

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

EH 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, 158 sales bureaus, 2,204 tied agents and 1,461 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 521 million in 2014, from EUR 528 million in 2013. In particular EH's property and casualty insurance businesses gross written premiums decreased to EUR 256 million for the year ended December 31, 2014, compared to EUR 278 million in 2013 while life insurance gross written premiums increased to EUR 264 million for the year ended December 31, 2014 compared to EUR 248 million in 2013.

Bancassurance premiums for life and property & casualty insurance amounted to EUR 235 million and EUR 43 million, respectively, in 2014 compared to EUR 106 million and EUR 42 million, respectively for 2013. The launch of the new "Ethniki Efapax" product resulted in significant increased premiums however is classified as an investment product. Sales of this product amounted to EUR 192 million compared to EUR 64 million, bringing total sales of bancassurance life products to EUR 235 million. 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 ("BRCI").

In Bulgaria, EH operates jointly with UBB and American Life Insurance Company, Inc.: UBB-ALICO Life Insurance Company Co. (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 will proceed, in conjunction with UBB and AIG Central Europe and CIS Insurance Holding Corporation, with the disposal of UBB AIG Insurance Company AD. The disposal is expected to be completed within 2015.

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. ("NBGB") 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, 2014, the Bank owned 1,722 real estate units, 1,161 of which were buildings and 448 were lands that the Bank acquired through seizure of collateral on loan foreclosures. The remaining 113 units were acquired to host and to support its own business purposes. As at December 31, 2014, the carrying value of the 1,609 units that were acquired through foreclosure was EUR 77 million (2013: EUR 86 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, NBG's real estate investment company, owned 314 commercial properties with a net book value of EUR 736 million as at December 31, 2014. The fair value of the properties was EUR 1,410 million at December 31, 2014. The properties have a total leasable area of 47 thousand sq.m. and are mainly located in prime areas throughout Greece. The NBG Pangaea Group also owned as at December 31, 2014 three properties in Italy and two properties in Romania.

In 2014, NBG Pangaea REIC proceeded with the implementation of its investment plan of total investments in real estate of EUR 359 million.

In addition NBG Pangaea REIC proceeded in 2014 with the signing of binding agreements for the acquisition of real estate investments amounting to EUR 264 million.

On February 10, 2014 JERMYN STREET REAL ESTATE FUND IV L.P. ("JERMYN") was nominated as Preferred Investor with regards to the international open competitive process in relation to the acquisition of a majority of the share capital of Astir Palace Vouliagmenis S.A (the "Process") (see NOTE 17 "Long-lived assets held for sale and liabilities directly associated with long-lived assets held for sale" to the U.S. GAAP Financial Statements included in this Annual Report).

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 tables below present the Group's exposure at December 31, 2014 to European countries (other than Greece) that are receiving financial support from the European Union and/or the IMF, or have initiated severe austerity measures in an attempt to improve their fiscal budgets. These are: Albania, Bosnia, Cyprus, Poland, Romania, and Ukraine).

Letters of credit and Letters of guarantee represent unfunded exposure and are summarized in the table below as at December 31, 2014:

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, 2014:

		December 31, 2014

	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	%		2		2
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	%		4		4
9.	Olganos S.A.	Greece		33.60	%		—		—
10.	UBB ALICO Life Insurance Company AD	Bulgaria		59.97	%		6		7
11.	UBB AIG Insurance Company AD	Bulgaria		59.97	%		2		2
12.	Drujestvo za Kasova Deinost A.D.	Bulgaria		19.98	%		1		1
13.	Bantas A.S.	Turkey		33.27	%		2		2
14.	Cigna Finans Pension	Turkey		48.91	%		78		87
15.	NBG Funding Ltd.	U.K.		100.00	%		18		20

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 is expected to be completed within the last quarter of 2015.

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 2014, 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 Citibank, HSBC Bank 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 (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 Greek Law 3864/2010, respectively: Attica Bank SA, Eurobank Ergasias S.A., National Bank of Greece S.A., Piraeus Bank S.A. and Alpha Bank A.E. The Greek banking sector experienced consolidation in 2012 and 2013. 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 October 17, 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 ("CPB") 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 Portugues participated in the share capital increase of Piraeus Bank. In May 2014, Piraeus Bank absorbed its subsidiary Geniki Bank SA (Source: Piraeus Bank press release on May 30, 2014). In July 2013, Eurobank acquired 100% of new Hellenic Postbank and 100% of New Proton Bank (Source: Eurobank press release dated July 15, 2013). Lastly, in July 2013, NBG acquired the healthy parts of First Business Bank and Probank. In December 2013, Alpha Bank undertook the deposits of three cooperative banks, namely, cooperative banks of Western Macedonia, Dodecanese and Evia (Source: Alpha press release dated December 8, 2013).

In December 2014, according to data published by the Bank of Greece, there were 21 foreign owned or incorporated banks that were established in the Greek banking market (including branches of Citibank, HSBC Bank and RBS). In March 2013 Piraeus Bank signed an agreement to acquire the operations of the three Cypriot banks in Greece, further reducing the number of foreign banks in the country. 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 in each of the jurisdictions in which it operates.

In principle, the Group is subject to the regulatory framework of the SSM as well as various EU and Greek laws and regulations and oversight by the ECB (which also administers the monetary policy of the Eurozone) and the Bank of Greece (the Greek central bank).

Regulation 1024/2013 established the SSM for Eurozone banks and other credit institutions. In connection therewith, the ECB has been granted certain supervisory powers as from November 4, 2014, which include:

As such, in Greece, the ECB cooperates with the Bank of Greece. The ECB will directly supervise 123 significant banking groups (including the NBG Group), which represent approximately 82% (by assets) of the euro area banking sector. For all other 3,500 banks the ECB will also set and monitor the supervisory standards and work closely with the national competent authorities in the supervision of these banks.

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 shall be 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 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. The day-to-day supervision is conducted by Joint Supervisory Teams (JSTs), which comprise staff from both NCAs and the ECB. The NCAs continue to conduct the direct supervision of less significant institutions, around 3,500 entities, subject to the oversight of the ECB. The ECB can also take on the direct supervision of less significant institutions if this is necessary to ensure the consistent application of high supervisory standards (source: ECB—Guide to banking supervision November 2014). Finally, under the SSM, the ECB also has the right to impose pecuniary sanctions and set binding regulatory standards.

A supervised entity or a supervised group shall be classified as significant if: (a) it has assets exceeding EUR 30 billion; (b) it has a ratio of total assets over the GDP of the participating Member State of establishment exceeding 20%, unless the total value of its assets is below EUR 5 billion; or (c) in respect of which, following a notification by the relevant NCA that it considers such institution of significant relevance with regard to the domestic economy, the ECB has taken a decision confirming such significance following a comprehensive assessment. Notwithstanding these criteria, the ECB shall consider significant Eurozone banks which have requested or received public financial assistance directly from the European Financial Stability Facility or the European Stability Mechanism or are one of the three most significant banks in a Eurozone or participating Member State. The ECB will have the right to impose pecuniary sanctions and set binding regulatory standards. Notably, the entity 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.

Before ECB assumed its supervisory responsibilities, an EU-wide Comprehensive Assessment was conducted, including an AQR and Stress Test with December 31, 2013 as the reference date. The assessment was carried out by the ECB in collaboration with the NCAs of the Member States that participate in the SSM and was supported by independent third parties at all levels at the ECB and NCAs. The ECB published the results of the comprehensive assessment on October 26, 2014 (see Item 4.A, "History and Development of the Company—EU-wide Comprehensive Assessment"). The Adverse Dynamic Balance Sheet stress test, which is based on NBG's approved Restructuring Plan, resulted in a CET1 ratio of 8.9%, and a capital surplus of EUR 2.0 billion.

As regards the monitoring of financial institutions, the national regulatory authorities 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, besides supporting the ECB in day-to-day supervision. The ECB, on the other hand, will be exclusively responsible for prudential supervision, which includes, among others, the power to: (i) authorize and withdraw authorization from all "banks of systemic importance" in the Eurozone; (ii) assess acquisition and disposal of holdings in other banks; (iii) ensure compliance with all prudential requirements laid down in general EU banking rules; (iv) set, where necessary, higher prudential requirements for certain banks to protect financial stability under the conditions provided by EU law; (v) impose robust corporate governance practices and internal capital adequacy assessment controls; and (vi) intervene at the early stages when risks to the viability of a bank exist, in coordination with the relevant resolution authorities.

In order to foster consistency and efficiency of supervisory practices across the Eurozone, the EBA is continuing to develop the EBA Rulebook, a single supervisory set of rules applicable to EU Member States.

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 Rule Book. A series of Regulations concerning regulatory or implementing technical standards have already been published.

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", December 2010 and "Basel III: International framework for liquidity risk measurement, standards and monitoring", December 2010) which contain the Basel III capital and liquidity reform package ("Basel III"). The Basel III documents were revised in June 2011. The Basel III framework has been implemented in the EU through new banking regulations adopted on June 26, 2013: Directive 2013/36/EU of the European Parliament and of the Council of June 26, 2013 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 Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013 on prudential requirements for credit institutions and investment firms (the "CRD IV Regulation" and together with the CRD IV Directive, "CRD IV"). Implementation began on January 1, 2014, with particular elements being phased in over a period of time (the requirements will be largely fully effective by 2019 and some minor transitional provisions provide for the phase-in until 2024) but it is possible that in practice implementation under national laws may be delayed until after such date.

The CRD IV Regulation is legally binding and directly applicable in all EU Member States. The EBA produces a number of Binding Technical Standards, Guidelines and reports for its implementation. The full implementation of CRD IV and its transposition into Greek law is expected to 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 and Markets in Financial Instruments Regulation. The Basel Committee has also published certain proposed changes to the current securitization framework which may be accepted and implemented in due course.

The Solvency II project aims to review the prudential regime for insurance and reinsurance undertakings in the EU. As a first step, the directive on the undertaking and pursuit of the business of Insurance and Reinsurance "Solvency II" (Directive 2009/138/EC) of November 25, 2009, is a fundamental review of the capital adequacy regime for the European insurance sector business. In December 2013, the Council of the EU adopted Directive 2013/58 scheduling the application date of the Solvency II Directive for January 1, 2016.

Directive 2014/59/EU provides for the establishment of an EU-wide framework for the recovery and resolution of credit institutions and investment firms (the "Bank Recovery and Resolution Directive" or "BRRD"). The BRRD is designed to provide authorities with a credible set of tools to intervene sufficiently early and quickly in an unsound or failing institution with the objectives to ensure the continuity of the institution's critical functions, to avoid a significant adverse effect on the financial system, in particular by preventing contagion, including to market infrastructures, and by maintaining market discipline, to protect public funds by minimizing reliance on extraordinary public financial support, to protect depositors and investors and to protect client funds and client assets.

The BRRD provides that it will be applied by Member States from January 1, 2015, except for the general bail-in tool (discussed below) which will be applied from January 1, 2016. BRRD has not yet been transposed into Greek law.

The BRRD contains four resolution tools and powers which may be used alone or in combination where the relevant resolution authority considers that: (a) an institution is failing or likely to fail, (b) there is no reasonable prospect that any alternative private sector measures would prevent the failure of such institution within a reasonable timeframe, and (c) a resolution action is in the public interest. The resolution tools are the following: (a) sale of business, which enables resolution authorities to direct the sale of the firm or the whole or part of its business on commercial terms; (b) bridge institution, which enables resolution authorities to transfer all or part of the business of the firm to a "bridge institution" (an entity created for this purpose that is wholly or partially in public control); (c) asset separation, which enables resolution authorities to transfer impaired or problem assets rights or liabilities of an institution under resolution or a bridge institution to one or more wholly or partially publicly owned asset management vehicles to allow them to be managed with a view to maximizing their value through eventual sale or orderly wind-down (the asset separation tool may only be used together with another resolution tool); and (d) bail in, which gives resolution authorities the power to write down certain claims of unsecured creditors of a failing institution and to convert certain unsecured debt claims to equity (the general bail-in tool), which equity could also be subject to any future application of the write-down. The bail-in tool may be applied to all liabilities of an institution or entity that are not excluded from the scope of that tool pursuant to Article 44 of the BRRD.

"Eligible liabilities" refers to liabilities and capital instruments that do not qualify as Common Equity Tier 1, Additional Tier 1 or Tier 2 instruments and that are within the scope of the BRRD's bail-in tool. The resolution authority in relation to an institution, after consultation with the relevant competent authority, is responsible for determining the MREL for that institution on the basis of certain criteria to be specified by the EBA, and can require a particular institution to meet its MREL wholly or partially with own funds or with certain types of liabilities.

For the purposes of the application of any non-viability loss absorption measure, the point of non-viability under the BRRD is the point at which the relevant authority determines that the institution meets the conditions for resolution (but no resolution action has yet been taken) or that the institution will no longer be viable unless the relevant capital instruments are written-down or converted or extraordinary public support is to be provided and without such support the appropriate authority determines that the institution would no longer be viable. See also, Item 3.D, "Risk Factors—We may be subject to the provisions of the Recovery and Resolution Directive in the future".

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. See Item 3.D, "Risk Factors- We may be subject to the provisions of the Recovery and Resolution Directive in the future".

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 to:

The circumstances under which the Bank of Greece may implement the aforementioned resolution measures include, among others, the need to stabilize the bank in question or to prevent the risk of financial instability or the need to prevent the creation of systemic risk taking into account the circumstances that prevail to the banking and interbanking market.

Following the implementation of any resolution measures, shareholders or creditors of the bank who believe that their financial position has deteriorated as a result of the resolution measures may request compensation from the Hellenic Republic, in an amount that would restore them to the financial position they would have been in if a special liquidation had taken place.

Apart from the aforementioned resolution measures that may be imposed to a bank in Greece, there are also preventive measures that the ECB, based on the powers conferred to it by Regulation 1024/2013 or Bank of Greece may impose to a bank, such as

With respect, specifically, to the appointment of a commissioner, Greek Law 4261/2014 provides that such measure is imposed if the bank fails or refuses to increase its own funds, or impedes the Bank of Greece in its oversight role in any way; or the bank commits serious or repeated violations of Greek Law 4261/2014 or Bank of Greece decisions, or there are doubts with respect to the sound and prudent management of the bank, such that its solvency, the interests of depositors or the overall financial stability or public confidence in the Greek financial system are put at risk; or the bank has insufficient own funds or is unable to service its obligations (and particularly to secure depositors' and creditors' funds.

The regulatory framework applicable to the Bank has been also affected by the establishment of the HFSF and the recapitalization framework (see Item 5, "Key Factors Affecting Our Results of Operations—The Hellenic Republic's Economic Crisis").

Banking regulations in Turkey are evolving in parallel to the global changes and international regulatory environment. Since June 2012, Turkish banks have been required to measure and report their capital adequacy in compliance with Basel II, as adopted in Turkey. Within the framework of Basel III, requirements regarding regulatory capital, liquidity, leverage and counterparty credit risk measurement are either required to be implemented or expected to be implemented gradually between 2014 and 2019. Although the impact on Finansbank's capital ratios from adopting Basel II was positive, requirements relating to the implementation of Basel III may have an adverse effect on Finansbank's capital ratios. In addition, Serbia fully adopted the Basel II framework as at January 1, 2012. Romania, Bulgaria, Cyprus and Malta in their capacity as EU members, have already adopted the CRD IV framework.

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

During the period of the credit institution's participation in the plan, dividend payouts must be limited to up to 35% of distributable profits (at the parent company level), in accordance with article 1 par.3 of Greek Law 3723/2008. Additionally, article 19 of Greek Law 3965/2011, article 4 of Greek Law 4063/2012, article 78 of Greek Law 4144/2013 and article 168 of Greek Law 4261/2014, prescribed that payment of dividend should only be restricted to distribution of shares (referring to financial years

ended 2010, 2011, 2012 and 2013) where these should not derive from repurchase of own shares. See Item 8.A, "Consolidated Statements and Other Financial Information—Policy on Dividend Distribution".

Also, credit institutions cannot engage in buybacks of their shares to enhance liquidity during their period of participation in the plan, in accordance with Greek Law 3723/2008 as amended by article 28 of Greek Law 3756/2008. However, pursuant to article 4 of Greek Law 4079/2012, this prohibition does not apply to the repurchase of preference equity shares that have been issued as redeemable, if the buyback is intended to strengthen CT1 capital, as determined by the regulatory framework, in accordance with article 28 of Greek Law 3756/2009, as in force.

To monitor the implementation of the Hellenic Republic Bank Support Plan, Greek Law 3723/2008 provides for the establishment of a supervisory council (the "Council"). The Council is chaired by the Minister of Finance. Members include the Governor of the Bank of Greece, the Deputy Minister of Finance, who is responsible for the Greek General Accounting Office, and the state—appointed representative at each of the participating credit institutions. The Council convenes on a monthly basis with a mandate to supervise the correct and effective implementation of the Hellenic Republic's Bank Support Plan and ensure that the resulting liquidity is used for the benefit of the depositors, the borrowers and the Greek economy overall. Participating banks which fail to comply with the terms of the Hellenic Republic's Bank Support Plan will be subject to certain sanctions, while the liquidity support provided according to Law 3723/2008 to them may be revoked in whole or in part. It should be noted that the fact that Preference Shares of a credit institution are rendered to the Hellenic Republic according to Greek Law 3723/2008 does not mean that the credit institution belongs to the Greek public sector.

The plan was revised by several Greek Laws and ministerial decisions, whereunder, among others, the Greek State Preference Shares were rendered not mandatorily redeemable, the return on the Greek State Preference Shares was increased, the prohibition on dividends payment was amended, the total amount that can be provided by the Hellenic Republic under Pillar II referred to above was increased, the veto power of the government appointed representative on the decisions of the Board of Directors was extended, the duration of the period for participation in the Hellenic Republic Bank Support Plan for Pillars II and III was extended until June 30, 2015, and increased the commission paid to the Hellenic Republic for Hellenic Republic guarantees provided for under Pillar II from July 1, 2010 onwards.

For more information concerning the effects of our participation in the Hellenic Republic Bank Support Plan, see Item 4.B, "Business Overview—Relationship with the Hellenic Republic—Hellenic Republic as Shareholder".

The Hellenic Financial Stability Fund—The Greek Recapitalization Framework

The HFSF was established by Greek Law 3864/2010, in the context of the Program, 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 Greek Law 3864/2010, is to maintain the stability of the Greek banking system for the sake of the public interest. The HFSF operates in compliance with the commitments of the Hellenic Republic provided for in Greek Law 4046/2012. In pursuing its objective, the HFSF: (a) provides capital support to credit institutions and to transitional credit institutions established under article 142 of Greek Law 4261/2014; (b) monitors and assesses whether credit institutions to which the HFSF provides capital support comply with their restructuring plans, while safeguarding the credit institutions' business autonomy; (c) exercises its shareholding rights derived from its participation in the credit institutions; (d) disposes of, in whole or in part, financial

instruments issued by the credit institutions in which it participates; and (e) exercises its rights with respect to the transitional credit institutions established under article 142 of Greek Law 4261/2014. The liquidity support provided under the Hellenic Republic Bank Support Plan or under the operating framework of the ECB and the Bank of Greece does not fall under the scope of the HFSF.

The initial duration of the HFSF has been set for seven years, until June 30, 2017, with the possibility of: (a) a one-year extension in case there are still outstanding warrants at June 30, 2017; and (b) a two-year extension following a decision by the Minister of Finance, if deemed necessary or for the achievement of the HFSF's objectives.

HFSF's capital: In accordance with Greek Law 3864/2010, the HFSF's capital is EUR 50 billion, consisting of funds raised by the Program by virtue of Greek Law 3845/2010, and shall be gradually paid in by the Hellenic Republic and evidenced by instruments which shall not be transferable until the expiry of the term of the HFSF (article 3 of the HFSF Law). After the expiry of the HFSF's term and the completion of the liquidation process, the HFSF's capital and assets will be transferred to the Hellenic Republic by operation of law (article 3 par. 5 of the HFSF Law). In the event of the liquidation of a credit institution, the HFSF, in its capacity as a shareholder of such credit institution, will be satisfied preferentially towards any other shareholders together with the Hellenic Republic as holder of Greek State Preference Shares under Greek Law 3723/2008.

Organizational issues: Following the amendment of Greek Law 3864/2010 by Greek Law 4254/2014, the administrative structure of the HFSF was amended such that there are two HFSF administrative bodies with decision making powers: the nine-member General Council (of which one member is a representative of the Bank of Greece and one is a representative of the Ministry of Finance); and the three-member Executive Committee (of which one member is appointed by the Bank of Greece). One appointee of the ECB and one appointee of the EC each have the right to participate in the meetings of the General Council and the Executive Committee as an observer. Except for the appointee of the Ministry of Finance and the appointee of the Bank of Greece, the appointment of the other members sitting on the General Council and the Executive Committee requires the consent of the meeting of all finance ministers of the Eurozone (the "Eurogroup").

The Governor, the Deputy Governor, the members of the collective bodies, the directors, as well as any individuals serving as representatives of to the Bank of Greece, may not become members of the Executive Committee. Until the appointment of the two additional members of the General Council as provided for under the amendment of Greek Law 3864/2010, the HFSF will be managed by the existing seven-member General Council and during this period, four members will constitute a quorum in the meetings of the General Council.

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. Every two months, the General Council shall submit activities reports to the Minister of Finance. The term of the members of the General Council and the Executive Committee is five years, and can be renewed but not to exceed the duration of the HFSF as described above.

The HFSF oversees and evaluates the adequate implementation of the restructuring plan (or the amended restructuring plan, as applicable).

Pursuant to the provisions of article 6 of Greek Law 3864/2010, as currently applicable, a credit institution may request capital support if recommended by the Bank of Greece, following an assessment of its sustainability by the Bank of Greece.

More specifically, the Bank of Greece will seek to assess the credit institution's capital shortfall and request from the latter to submit a restructuring plan (or, with respect to credit institutions that have already received capital support, a revised restructuring plan). The restructuring plan or the revised restructuring plan must list the types of measures that the credit institution will undertake in order to raise funds or to limit its capital needs, the time needed for taking each measure and the expected impact on the credit institution's capital shortfall. Measures to be included in the restructuring plan may consist, among others, in the following:

The restructuring plan must also describe, in light of conservative estimates, by what means the credit institution intends to remain viable over the next three to five years.

Following the assessment of viability, which will also take into consideration the restructuring plan (or the amended restructuring plan, as applicable), the Bank of Greece will recommend that the credit institution submit a request for the provision of capital support to the HFSF.

Following approval by the HFSF, the restructuring plan will be sent to the Ministry of Finance and submitted to the European Commission for approval. Following approval of the restructuring plan (or the amended restructuring plan, as applicable) by the European Commission, the HFSF will provide capital support as provided for in paragraph 7, provided that the Cabinet Act of Article 6 (a) has been published (known as the "Derogation Cabinet Act"), in compliance in any case with the EU legislation in relation to state aid and the relevant practices of the European Commission.

Once capital support is activated, the credit institution may apply for advance payment of the capital support. More specifically, the HFSF, following a decision by the Bank of Greece, shall grant to a bank which has submitted a request for recapitalization and been deemed viable by the Bank of Greece a certificate by which it commits to participate in a share capital increase of the credit institution up to a certain amount determined by the Bank of Greece.

The HFSF, in view of its participation in the capital support of a credit institution that has been assessed and deemed viable by the Bank of Greece, advances its contribution or part of such

contribution and up to the amount determined by the Bank of Greece, in accordance with the procedure of Article 6 and Article 6(a), following a decision of the Bank of Greece, provided that:

Cabinet Act 15 dated May 3, 2012 has defined the minimum terms that must be included in the presubscription agreement to be concluded between HFSF, Greek banks and EFSF pursuant to article 6 of Greek Law 3864/2010 (the "Presubscription Agreement"), which, among others, provides for:

Capital support is provided by the HFSF only upon approval of the capital support by the European Commission and upon publication of the Cabinet Act provided in par. 1 of art. 6(a) of Greek Law 3864/2010. See "—Recapitalization Procedures before HFSF Participation", below.

Until the release of the aforementioned contribution, such contribution shall be exclusively disposed to ensure liquidity through sale and buyback transactions with market counterparties (ensuring the right to buy back the same securities under the terms of the buyback transaction) or via the European Central Bank or the Bank of Greece within the Eurosystem. In such case, the Operation Regulation of the System for Monitoring Transactions in Book-Entry Securities is applied, as in force from time to time.

If the participation of the HFSF is less than the amount advanced, as well as in the event that the share capital increase does not take place, the HFSF shall claim the refund of the residual or the whole amount as appropriate, at a rate set by decision of the Minister of Finance, following recommendation of the Bank of Greece and opinion of the HFSF. See "—Recapitalization Procedures before HFSF Participation", below.

The advance payment procedure laid down above is applied following decision of the Bank of Greece, issued following consent of the European Commission and the European Financial Stability Fund and it is published in the Government Gazette.

During the participation of the HFSF in the share capital of credit institutions, the credit institutions may not purchase treasury shares without the prior approval by the HFSF.

In 2012, credit institutions that had received capital support from the HFSF were required to pay a lump sum amounting to EUR 556 million to the HFSF, according to Greek Law 4093/2012, which amended Greek Law 3864/2010 (Article 16C of the HFSF Law) and in this context the Bank was required to pay the HFSF EUR 116 million.

Article 6(a) of Greek Law 3864/2010, as amended by Greek law 4254/2014, introduces a special procedure for the participation of shareholders and subordinated creditors in the recapitalization of credit institutions prior to or concurrently with the HFSF. The details of the above procedure are set out in a Cabinet Act dated April 11, 2014 ("Act 11/2014").

More specifically, should the voluntary measures provided for in a credit institution's restructuring plan fail to address the total capital shortfall of the credit institution as identified by the Bank of Greece and the license revocation measures under article 19 and/or the resolution measures under articles 139 et seq. of Greek Law 4261/2014 could lead to serious disturbances in the economy with adverse effects upon the public, the Cabinet, in order to ensure that the use of public funds is minimal and following a recommendation by the Bank of Greece, shall issue an act for the application of 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 subordinated liabilities, as may be necessary. According to Act 11/2014, the Bank of Greece appoints an independent evaluator to evaluate the assets and liabilities of the credit institution in question. The evaluation provided to the Bank of Greece forms part of its recommendation to the Cabinet.

The above instruments or liabilities are mandatorily converted into capital instruments in connection with a capital increase of the credit institution, failing which the credit institution should be subject to the measures referred to in article 19 and/or articles 139 et seq. of Greek Law 4261/2014 and to the provisions of Greek Law 3458/2006.

Claims of the same rank will be treated pari passu. 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.

Act 11/2014 determines the specific order of implementation of the above mandatory measures as follows:

More specifically, if the capital required so that the net asset value of the credit institution is equal to zero exceeds the value of the preference shares, then the nominal value of the relevant instruments is decreased to the largest extent possible; if the above required capital does not exceed the value of the preference shares, then the nominal value of the relevant instruments is decreased to the extent necessary to absorb any remaining losses and the remaining value of the relevant titles is converted to ordinary shares.

The value on the basis of which the above-mentioned subordinated instruments are converted varies depending whether the HFSF has already provided capital support to the credit institution in question and such support is considered as state aid. In the latter case each subordinated instrument is converted on the basis of its fair value.

The decreases of the nominal value of shares in cases (a) and (b) will be performed in accordance with the pertinent provisions of Greek Company Law 2190/1920.

In the event that the net asset value of the credit institution is above zero pursuant to the implementation of the voluntary measures included in the restructuring plan of a credit institution, but more capital is needed to meet the capital adequacy ratio set by the Bank of Greece, the Bank of Greece recommends to the Cabinet the conversion in whole or in part of the preference shares and the issued subordinated liabilities of the above credit institution in Greece and abroad at the following order; first, conversion of the preference shares and secondly the conversion of the remainder subordinated liabilities, in accordance with their ranking.

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 "Derogation Cabinet Act").

These risks above represent the objective grounds for derogation from the allocation of the residual amount of the credit institution's capital shortfall, as indicated above, and the pari passu rule. The final assessment of the derogation rests with the European Commission on a case-by-case basis.

The aforementioned measures applicable to credit institutions constitute, for the recapitalization purposes of Greek Law 3864/2010, resolution measures as defined in article 2 of Directive 2001/24/EC of the European Parliament and the Council of April 4, 2001 on the reorganization and winding up of credit institutions that was transposed into Greek law with Law 3458/2006. The implementation of such measures, voluntary or mandatory, cannot in any case be:

The holders of any capital or hybrid capital instrument, or other subordinated liability, including beneficiaries directly or indirectly benefiting from any guarantee ranking as a subordinated liability, of the credit institution 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, such shareholders and subordinated creditors are entitled to compensation from the Hellenic Republic, provided that they prove that their damages arising from the implementation of the mandatory measures are greater than if the credit institution had been put under liquidation.

A valuation is conducted in order to determine the losses that the shareholders and subordinated creditors would have assumed 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 purposes of such evaluation. The valuation will be conducted after implementation of the mandatory measures by an independent valuator to be appointed by the Minister of Finance with a view to assessing whether shareholders, hybrid capital holders and subordinated liability holders would have been in a more favorable financial position if the credit institution had entered into normal insolvency proceedings immediately prior to the implementation of the mandatory measures.

The Cabinet Act for implementation of the mandatory measures is published in the Government Gazette, as well as in the form of a Greek-language summary in the Official Journal of the EU and in two daily newspapers circulated throughout the territory of the Member State in which the credit institution has a branch or directly provides banking and other mutually recognized financial services, in the official language of such Member State. The summary will include the following:

The competent court before which legal remedies against the Cabinet Act may be sought.

Capital support is provided through the HFSF's participation in a share capital increase of the credit institution by issuance of ordinary shares or contingent convertible securities or other instruments that shall be subscribed for by the HFSF. Such share capital increases covered in cash or in EFSF securities or in other financial instruments of the EFSF. Capital support is provided in compliance with state aid rules.

The HFSF is entitled to exercise, dispose or waive its pre-emptive rights in cases of share capital increase or issuance of convertible financial instruments or other financial instruments of the credit institutions requesting the provision of capital support.

The price at which the HFSF subscribes the shares or contingent convertible securities or other financial instruments, is determined by a decision of the General Council. The General Council's decision relies, among others, upon two evaluation reports conducted by two independent financial advisers with reputation and expertise on relevant issues and more specifically on credit institution valuations.

The new shares cannot be disposed to investors at a price lower than the price at which the shares have been subscribed for by the HFSF in the context of the same issuance. The price at which the shares shall be disposed to investors may be lower than the price at which the shares have been previously subscribed for by the HFSF, or than their current market price.

The HFSF shall request from the financial advisers to take into consideration all relevant information, including any evaluation that is available regarding the quality of the credit institution's assets, stress test results, and also market conditions, and shall provide them with any relevant

information. A summary of the selection terms of financial advisers as well as of the data and the methodology that was used, shall be published in the HFSF's official website within 10 days from the completion of the transactions.

Under the current, amended recapitalization framework, the HFSF will acquire shares with full voting rights in the share capital increases in which it will participate, pursuant to Greek Law 3864/2010, as amended by Greek Law 4254/2014.

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 provided for in article 7(a), para. 3 of Greek Law 3864/2010, as currently applicable, (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, 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 (or facilitating the breach) of material obligations for the implementation of the restructuring plan or the agreement entered into between the HFSF and the bank.

The HFSF has the power to appoint up to two members to the board of directors of a bank having received capital from the HFSF according to Greek Law 3864/2010, as its representatives. The HFSF has currently appointed one representative in our Board of Directors. The HFSF representative has certain powers over credit institutions:

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 in the future the HFSF could obtain full voting rights in respect of its shareholding in 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 with the Hellenic Republic holding Greek State Preference Shares and U.S. Preference Shares, before all other shareholders.

Following the participation of the HFSF in the Bank's share capital in 2013, the Bank and the HFSF entered into the Relationship Framework Agreement on July 10, 2013. According to the Relationship Framework Agreement, the HFSF has the duty to monitor (a) the efficient management of its investment in the Bank in a manner that protects the value of its investments and minimizes risks to the Greek citizen; (b) that the Bank operates on market terms; (c) that in due time the Bank returns to private ownership in an open and transparent manner; and (d) that compliance with state aid rules is achieved. Moreover, HFSF monitors compliance of the Bank with the Restructuring Plan that will be agreed with the Directorate General for Competition of the European Commission once an updated version is resubmitted in 2014. The HFSF must provide its consent on the restructuring plan according to article 6, para.5 of Greek Law 3864/2010.

The Relationship Framework Agreement determines the relationship between the Bank and HFSF on certain matters, including, among others: (a) corporate governance of the Bank; (b) development of the approved Restructuring Plan; (c) material obligations of the Restructuring Plan and transition of HFSF voting rights of; (d) monitoring of the implementation of the Restructuring Plan and the Bank's implied risk profile; and (e) HFSF's consent for "material matters" as defined in Clause 3.5a of the Relationship Framework Agreement.

Moreover, the Relationship Framework Agreement states that, subject to its provisions, applicable laws and the Articles of Association of the Bank, the Bank's decision making bodies will continue to determine independently, among other matters, the Bank's commercial strategy and policy (including business plans and budgets) 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.

Under the Relationship Framework Agreement and for the period for which the HFSF holds shares representing at least 33% of the Bank's share capital, the HFSF's appointed representative on our Board of Directors has the power, among other things, to include items on the agenda of the general meeting of our ordinary shareholders and our Board of Directors; and to participate in the following committees of the Bank: Audit Committee, Board Risk Committee, Corporate Governance and Nomination Committee and Human Resources and Remuneration Committee. The HFSF Representative will have the following rights in the committees:

Furthermore, 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 in such agreement, including, among others, our connected borrowers policy and any amendments, revisions or deviations thereof, all material corporate actions (e.g., capital increases, mergers), material investments or transfers of assets, our Restructuring Plan and any amendments thereof, and the appointment of auditors.

In the event that the Bank is in breach of material obligations included in, or facilitating, the implementation of the Restructuring Plan, the HFSF will stipulate a period during which the Bank should remedy such breach. If the breach is still outstanding after the lapse of the remedy period and following a resolution of the members of the General Council of the HFSF, the HFSF's restricted voting rights will be switched to full voting rights pursuant to the provisions of article 7a of Greek Law 3864/2010, as in force.

The template Relationship Framework Agreement is available on the website of the HFSF (http://www.hfsf.gr).

Subject to the limitations on the disposal of shares already held by the HFSF in the recapitalized banks under the terms of the warrants, the HFSF will decide on the way and procedure for disposing its shares at a time it deems appropriate and in any case within five years. The disposal may take place gradually or one-off, at the HFSF's discretion, so long as all shares are disposed of within the time limits referred to above 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 market 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 by the private sector (in case the HFSF waives or disposes its pre-emptive rights) is defined by the General Council of the HFSF. The disposal price or the subscription price may be lower than the price at which the shares were acquired by the HFSF or their current market price.

This also applies in the case of all share capital increases by credit institutions (i.e., including share capital increase not performed under the provisions of Greek Law 3864/2010, as currently amended).

Pursuant to Greek Law 3864/2010 (before its amendment by Greek Law 4254/2014) and Cabinet Acts No. 38/9.11.2012 and 6/2013, the HFSF issued and delivered to private sector investors who participated in the recapitalization share capital increase in 2013 (under Greek Law 3864/2010) one

warrant for each new share acquired in the share capital increase of a bank at no additional charge, on the basis that private sector participation in the capital increase of a credit institution was higher than 10% of the total amount of the capital increase.

Warrants are transferable securities that offer no voting rights to their holders and there are no restrictions as to their transfer. Pursuant to the above mentioned Cabinet Acts, each warrant incorporates the right of its holder to purchase a certain number of shares calculated using the following formula: x=a/b, where (x) is the total number of the shares that the warrant holder is entitled to purchase, (a) is the total number of the ordinary shares that the HFSF acquires in the capital increase and (b) is the total number of ordinary shares that the private sector acquires in the capital increase. At the time of exercise, any fractional shares corresponding to the warrants of the same holder being exercised shall be aggregated and rounded down to the nearest integral number. Pursuant to Cabinet Act No. 38/2012 the number of ordinary shares corresponding to each warrant shall be adjusted accordingly in the case of corporate events.

A Cabinet Act shall determine the methodology for the exchange of warrants issued in accordance with article 3 of Cabinet Act 38/2012, as such exchange is provided for in item (iii) of paragraph 2 of article 8 of Law 3864/2010, and the adjustment of their terms and conditions, in case of increase of the nominal value of the shares with decrease of the total number of existing shares (reverse split), split of existing shares at a ratio determined by the credit institution and adjustment of the nominal value of the new share (split), as well as in case of share capital increase without abolishment of the pre- emption rights of existing shareholders. In the event of a share capital increase without abolishment of the pre-emption rights, an adjustment may be made only to the exercise price of the rights attached to the warrants. The adjustment may be made up to an amount equal to the proceeds of the HFSF from the sale of the pre-emption rights and shall take place after such sale. The aforementioned Cabinet Act shall determine every other detail for the implementation of this paragraph.

Article 3 of Cabinet Act 38/9.11.2012, as amended by Cabinet Act 6/2013, provides that for the purposes of the act and Greek Law 3864/2010 the "General Government Entities" as described under paragraph 2 of Article 1B of Greek Law 2362/1995 and as identified under the aforementioned provisions by the Register of General Government Entities of EL.STAT., do not fall within the meaning of "private investors" or "private sector".

Given that the private sector participation in the 2013 recapitalization share capital increase of the Bank was higher than 10% of the total amount of the increase, the HFSF issued and delivered to the private sector investors having participated in the increase, for no additional charge, one warrant for each new share acquired in the share capital increase of the Bank. Each warrant incorporates its holder's right to purchase from the HFSF at a certain price 8.22923881005499 of ordinary shares acquired by the HFSF as a result of its participation in the share capital increase (call option). The warrants were issued on June 26, 2013. Warrants do not offer voting rights to the beneficiaries or holders thereof.

For a period of thirty-six months from the warrants issue date, the HFSF is not allowed to transfer the shares underlying the warrants, unless such transfer occurs due to the exercise of a warrant. After this period and until the expiration of the warrants, the HFSF shall be entitled to transfer the underlying ordinary shares without being obliged to indemnify the warrant holders that have chosen not to acquire such shares.

Warrants can be exercised by their holders every six months, starting from the date which falls six months from the warrants issue date until the date which falls 54 months from the warrants issue date. Warrants may also be exercised at the date of extraordinary exercise, i.e., when the HFSF exercises its right to transfer the underlying ordinary shares after the thirty-six-month period and not in the regular every-six-month date. Warrants not exercised within the aforementioned period shall ipso iure lapse and shall be cancelled by the HFSF.

The exercise price of the purchase option corresponding to each warrant for the purchase of the shares held by the HFSF shall be equal to EUR 4.29, plus accrued interest calculated by application of an annual interest rate of 3% increased by a spread of:

The following table presents indicative exercise prices for warrants per six month period based on the offer price of EUR 4.29, without taking into account any corporate actions:

The Bank announced on December 30, 2014 (following the December 16, 2014 announcements in relation to the exercise of the certificates evidencing the ownership status) that no Warrant on shares issued by the Bank and owned by the HFSF has been exercised. Following the above, the issued Warrants that remain in force are 245,748,459 representing 2,022,322,834 of the Bank's shares owned by the HFSF.

The procedure for the exercise and settlement of the warrants, as well as any change in the rights and obligations of the warrant holders that may take place while the warrants are valid, are announced by the Bank on its webpage and on the official daily bulleting of the ATHEX. Moreover, according to Act no. 22/12.07.2013 of the Executive Committee of the Bank of Greece, the warrant holders must, prior to the exercise of the warrant, to the extent that such exercise renders them individuals defined in article 23 of Greek Law 4261/2014 (i.e., holding at least 5% of the voting rights of the credit institution), comply with the information and prior Bank of Greece approval obligations to the extent applicable according to chapter B (Submission of the relevant questionnaire), and are subject to the supervisory evaluation process by the Bank of Greece according to Chapter C of the aforementioned Act.

The Presubscription Agreement between the HFSF, the Bank and the EFSF dated May 28, 2012 provided for a lock-up undertaking (the "Lock-up Undertaking") imposed on the Bank, with effect from the date of execution of the Presubscription Agreement until 18 months after the date of completion of the 2013 share capital increase, i.e., the date of delivery of the then offered shares to the purchasers thereof (July 2, 2013). This Lock-up Undertaking was in force until January 2, 2015 and has not been extended.

The Bank submits to the Bank of Greece on a regular basis (e.g. monthly, quarterly, semi-annually, annually) a full set of regulatory reports with information both at Bank level and at Group level, according to the stipulations of the Bank of Greece Governor's Act 2651/2012.

Moreover, EU Implementing Regulation 680/2014, as in force, is laying down implementing technical standards with regard to supervisory reporting of institutions according to EU Regulation 575/2013 (CRR). Specifically, this Regulation lays down uniform requirements in relation to supervisory reporting to competent authorities for the following areas:

Furthermore, the ECB has published a draft regulation on reporting of supervisory financial information for public consultation. This draft regulation lays down the requirements regarding reporting on supervisory financial information to be submitted to national competent authorities ("NCAs") and the ECB by supervised banks. The draft ECB Regulation aims at extending the regular reporting of supervisory financial information to the consolidated reports of banks under national accounting frameworks (national GAAPs), as well as to reports at the solo level (i.e. including a single legal entity). It should be noted that the NCA will be the entry point for supervisory reporting from banks. The NCAs will then transmit the information to the ECB.

The Hellenic Deposit Guarantee Fund (the "HDGF") commenced its operations in September 1995. Pursuant to Greek Law 3746/2009 as currently in force, the Hellenic Deposit and Investment Guarantee Fund (the "HDIGF") operates as a private law entity and a general successor of the HDGF provided for by virtue of article 2 of Greek Law 2832/2000. The HDIGF 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. It is managed by a seven-member board of directors. The Board shall be chaired by one of the Deputy Governors of the Bank of Greece. Of the remaining six members, one comes from the Ministry of Finance, three from the Bank of Greece and two from the Hellenic Bank Association. Members of the above board of directors are appointed by a decision of the Minister of Finance and have a five-year tenure. The initial capital of HDIGF's was paid by the Bank of Greece and the Hellenic Bank Association, with a participation in the fund's constitutive capital at 60% and 40%, respectively.

According to Greek Law 3746/2009, the HDIGF was founded with the objective to indemnify (1) depositors of banks participating in the HDIGF obligatorily or at their own initiative who are unable to fulfill their obligations towards their depositors and (2) 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. Greek Law 4021/2011, which amended Greek Law 3746/2009, expanded the HDIGF's scope, to cover the provision of financing to banks placed under the resolution measures of articles 141 and 142 of Greek Law 4261/2014 (former Articles 63D and 63E of Greek Law 3601/2007). Thus, apart from the already existing Depositors' Coverage Branch and Investors' Coverage Branch, a Resolution Branch was further established and

funded by contributions from banks. All authorized banks in Greece are obliged to participate in the aforementioned branches of the HDIGF.

The maximum coverage level for each depositor at a credit institution under Greek Law 3746/2009 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 euros to each depositor as an indemnity irrespective of the number of accounts, the currency, or the country of operation of the branch in which it holds the deposit. In case of joint bank accounts, as defined by Law 5638/1932 (Government Gazette 307/A), 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 event that the relative proportions of joint account holders in an account have not been specified, for the purposes of compensation, each joint account holder is considered as having an equal share of the value in the account. The deposit of a group of persons without legal personality shall be aggregated and treated as if made by a single depositor for the purpose of calculating the abovementioned limits. 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 3746/2009, 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, as analyzed above. 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. For the purposes of compensation, the claim of a group of persons without legal personality shall be treated as if made by a single investor.

The HDIGF is funded by the following sources: its founding capital, the initial and annual contributions of banks obligatorily participating in the HDIGF and supplementary contributions, as well as special resources coming from donations, liquidation of the HDIGF's claims, and the management of the assets of the HDIGF's Deposit Cover Scheme.

According to article 9 of Greek Law 4051/2012, as amended by Article 165 of Greek Law 4099/2012 and Article 16 of Greek Law 4224/2013, the HFSF is required to pay any amount the HDIGF would pay as per article 63D par. 13 and Article 63E par. 7 of Greek Law 3601/2007 as replaced by Greek Law 4261/2014 Articles 141 and 142, for the fulfilment of the obligations that have been generated or will be generated due to the abovementioned provisions up to 31 December 2014.In this case, the HFSF acquires the claims and privileges of the HDIGF as per article 13A par. 4 of Greek Law 3746/2009.

Directive 2014/49 on deposit guarantee schemes lays down rules and procedures relating to the establishment and the functioning of deposit guarantee schemes. Member States shall bring into force the laws, regulations and administrative provisions necessary to comply with the aforementioned Directive by July 3, 2015.

Directive 2007/64/EC on the Payment Services Directive ("PSD") 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 the new entities called "payment institutions" (e.g., companies of money transfers, retailers, telecommunication companies) to provide payment services in parallel to banks as "payment services providers". The PSD covers any kind of payment through electronic means and no 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 30 European countries.

The PSD was incorporated 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 provided payment services, under specific terms and conditions. The new legislative regime also provides further protection regarding the rights of the users of the payment services.

More specifically, customers receive, free of charge, in paper or in electronic form, the Framework Contract, which describes in detail the terms under which the payment services are provided. These terms are ones mandated by law and applicable to existing contracts with customers, to the extent that these contracts include the provision of payment services, and override any contrary agreement. Customers have the right to raise objections within two months after the notification of the Framework Contract to them, should they not wish to continue trading with the bank without bearing any liability, unless the parties had already agreed to comply with the terms of a preceding contract, which in any case cannot have a duration of more than one (1) month.

Customers are provided with the necessary background information prior and after the signing of the payment services contract. Consequently, customers are able to easily compare the terms offered and choose the option that better satisfies their needs. Customers are not burdened with any costs to be provided with all the mandatory information or the one regarding the resolution and preventive measures that can be taken so as to ensure the proper execution of payment orders.

Customers have the right to reclaim the amount of money transferred in cases where:

Further, it should be noted that a revision of Payment Services Directive is under process. To this end, a new payment Services Directive ("PSD2") and a Regulation on interchange fees for card-based payment transactions have been proposed by the European Commission. The Council adopted on April 20, 2015 a regulation capping interchange fees for payments made with debit and credit cards.

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, Member States shall adopt and publish the laws, regulations and administrative provisions necessary to comply with this Directive. They shall apply the aforementioned measures from September 18, 2016.

Greek Law 3816/2010, passed in January 2010, allowed the settlement of professional and corporate debts, which were either due (from January 1, 2005 onwards) or not due to banks by natural or legal persons. To take advantage of the relevant provisions, an application must have been submitted by the debtor to the relevant bank by April 15, 2010. In particular, the law provides, among other things, that:

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 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, or 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 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 and 4161/2013. The law allows the settlement of amounts, due to credit institutions by individuals evidencing permanent inability to repay their debts, by arranging the partial repayment of their debts and writing off the remainder of their debts, provided the terms of settlement are agreed. All individuals are subject to the provisions of Greek Law 3869/2010, with the exception of individuals already subject to mercantile law.

This regulatory regime allows the settlement of all amounts due to credit institutions as well as those due to third parties with the exception of debts from intentional torts, administrative fines, monetary sanctions, debts from taxes, charges due to the State or levies to Social Security funds and debts from loans granted from Social Security funds under the provisions of articles 15 and 16 of Greek Law 3586/2007. Debts must have been contracted more than one year before the application date and relief may be used only once.

According to Greek Law 3869/2010, the procedure has three steps: (1) a discretionary out of court mediation process; (2) an in-court settlement; and (3) a judicial re-structuring of debts (debts discharge).

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.

Pursuant to Greek Law 4224/2013 and Cabinet Act 6/2014, a governmental council for 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".

Finally, Greek Law 4224/2013 provides that the Consumer Ombudsman will act as mediator between lenders and borrowers for the purpose of settling non-accruing loans mainly in connection with matters relating to the application of the above-mentioned Banks' Code of Conduct for the management of non-accruing loans.

Bank of Greece has published new regulatory framework concerning the management of loans in arrears and non-accruing loans that will enter into force on December 31, 2014 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:

Code of Conduct under Greek Law 4224/2013 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. In dealing with cases of borrowers in arrears or pre-arrears, every institution shall apply a procedure 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 4307/2014, among others, provides for urgent interim measures for the relief of private debt, especially debt of viable small businesses and professionals towards financial institutions, the State and Social Security Institutions, as well as for emergency procedures for the reorganization or liquidation 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 March 31, 2016 and cumulatively meet the following criteria:

(1) they have not submitted an application to be subject to the provisions of Greek Law 3869/2010 or have validly resigned from such application;

(2) they have not stopped their operations or dissolved and (if applicable) they have not submitted an application to be declared bankrupt or have validly resigned from such application; and

(3) they have not been convicted in any capacity for fraud against the Greek State of State Pension Funds or for smuggling.

Law 4307/2014 provides for the write off of specific claims that cumulatively meet the criteria set by the relevant provisions of Greek Law 4307/2014.

For the implementation of the above procedure the Ministerial Decision 4837 (Government Gazette Issue B'66/16.1.2015) was 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 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, it should be noted that 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 currently applicable. 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 (Government Gazette Issue B; 917/23.6.2010) 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.

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.

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 offences as main offences, legalization documents for the verification of client's identity and the 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 amended by Decisions 300/28.7.2010 and by the Governor of Bank of Greece no 2652/29.02.2012 to include 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 95/10/2013) which further strengthen the regulatory framework within which the supervised entities in Greece operate. 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.

The Council on February 10, 2015 approved an agreement with the European Parliament on strengthened rules to prevent money laundering and terrorist financing. The directive and regulation are intended to strengthen EU rules against money laundering and ensure consistency with the approach followed at international level. The draft 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.

Greek Law 4261/2014 (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, to all 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. Currently no such publication has yet been made by the Bank of Greece.

Under the previously applicable Greek Law 3601/2007, the Act of the Governor of Bank of Greece No. 2604/2008, as amended 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.

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 Hellenic Capital Market Committee ("HCMC") and the ATHEX must be notified once certain ownership thresholds are exceeded with respect to listed companies according to Greek Law 3556/2007, the implementing HCMC decisions and the ATHEX Regulation.

Greek Law 4261/2014 (mainly through Articles 23 and 27) establishes a specific procedure for the notification to the Bank of Greece of a natural or legal person's intention to acquire or increase or dispose a holding exceeding certain enumerated thresholds (i.e., 20%, ¹/3 and 50% of voting rights or equity participation in or control of a bank that has been licensed by the Bank of Greece). The applicant acquirer is assessed 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, 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.

As at November 4, 2014, the supervisory tasks described above were conferred to the ECB in cooperation with the Bank of Greece. The relevant procedure for notification of acquisitions of qualifying holdings and notification concerning the relevant decisions are described in 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 the constraints imposed by the banking regulations discussed above, including the constraints pursuant to article 1 of Greek Law 3723/2008 regarding the Hellenic Republic Bank Support Plan and 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 Hellenic Republic Bank Support Plan"), the Relationship Framework Agreement signed with HFSF, following the Bank's recapitalization pursuant to Greek Law 3864/2010 (see "—The Hellenic Financial Stability Fund—The Greek Recapitalization Framework"), the obligations towards the Monitoring Trustee and the Restructuring Plan of the Bank approved by the European Commission on July 23, 2014.

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 Greek Law 4261/2014 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 natural persons.

Moreover, according to Article 150 par.2 of Greek Law 4261/2014 it is prohibited to grant new loans for the repayment of overdue interest.

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.

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 and 1358/2011, 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:

According to Greek Law 4224/2013 which was published on December 31, 2013, from January 1, 2014 until December 31, 2014 enforcement of auctions concerning the primary residence of individuals were suspended provided that they were declared as such in their last income tax and their assessed market value 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; 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 in Greece and abroad as of November 20, 2013 did not exceed the amount of EUR 15,000. 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.

Moreover, enforcement of collateral has been affected by Greek Law 3869/2010, as it was amended by the Greek Law 4161/2013, regarding restructuring of individuals' debt through a court application. As at December 31, 2013 and December 31, 2014, customers that had applied to the court under the provisions of Greek Law 3869/2010 had outstanding balances of EUR 1,838 million and EUR 2,784 million respectively.

Furthermore, according to the Greek Law 4224/2013 a decision of the Bank of Greece concerning the issuance of a Code of Conduct for management of non-accruing private debt was made public and enforced as at December 31, 2014. According to the aforementioned law, forced auction of a primary residence can only proceed after the borrower has been classified as "non-cooperative" following the detailed Arrears Resolution Process established by the Bank, in line with the requirements of the law.

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 contains new rules to stop the biggest and most complex banks from engaging in the activity of proprietary trading. 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 securitisation operations) to separate legal trading entities within the group ("subsidiarisation"). 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 will 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 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.

The proposed regulation will apply to European banks that will eventually be designated as G-SIBs 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 of 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 Financial Transactions Tax (the "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). Although implementation was originally envisaged for January 1, 2014, the process has been delayed.

Given the concerns voiced by both the financial sector and business associations, it is unclear how the FTT will proceed and when it will be implemented. If adopted, the impact on the "real economy" of the FTT as currently envisaged (especially for corporations) could be severe as many financial transactions are made on behalf of businesses that would bear the additional costs of the tax. For example, a transaction tax would raise the cost of the sale and purchase of corporate bonds in a time where it is widely acknowledged that access to capital markets by corporate issuers has to be incentivized.

The Greek income taxation framework was significantly amended by the new Greek Income Tax Code (Greek Law 4172/2013 as amended and in force by Greek Laws 4223/2013, 4254/2014 and 4316/2014, the "New Income Tax Code" or "NITC"), which replaced the previous Income Tax Code (i.e., Greek Law 2238/1994, as in force for income generated within 2013, the "ITC"). The NITC is applicable for income generated for tax years starting as of January 1, 2014.

For income received in 2014 onwards, under the provisions of the NITC the nominal corporate tax rate, applicable to the Bank, continues to be 26%.

Under the NITC, dividends received by a shareholder who is a natural person who is (i) a Greek tax resident, or (ii) a foreign tax resident, are subject to tax imposed on the dividend at a rate of 10% (unless an applicable tax treaty provides otherwise) withheld by the Company, which exhausts the tax liability of the above shareholder with respect to such income. The treaty between Greece and the United States for the avoidance of double taxation and the prevention of fiscal evasion (the "Treaty") does not limit the rate of Greek taxation on dividends. In the case of natural person Greek tax residents, the dividend is characterized under NITC as 'capital income' and is declared in the annual income tax return of the shareholder.

If the shareholder is (i) a legal person or legal entity, tax resident of Greece, or (ii) a foreign tax resident legal person or legal entity with a permanent establishment in Greece and the shares are effectively connected with or held by such Greek permanent establishment, then withholding tax is imposed on the dividend at a rate of 10%. The dividend payment to such shareholder is thereafter treated as "business income" under the NITC and is declared in the annual income tax return. The 10% tax withheld by the Company is credited against the shareholder's annual corporate income tax due for this income, which under the NITC is 26%, and, in case the amount withheld is larger than the amount due under the annual income tax return, then the difference, amounts to a tax credit to the shareholder.

If the shareholder is a foreign tax resident legal person or legal entity (that does not maintain a permanent establishment in Greece with which the shares are effectively connected), the dividend payment is subject to withholding tax at a rate of 10% (or a lower rate provided by an applicable tax treaty) and such withholding shall exhaust the tax liability of such shareholder with respect to such income. It is noted that, based on the participation exemption system provided in the NITC and implementing Directive 2011/96/EU, dividends received by a company which, among other conditions, is a resident of an EU Member State and participates in a Greek company with a minimum 10% participation for an uninterrupted period of at least 2 years, are exempt from taxation.

Natural persons holding less than 0.5% of the share capital of the issuer are not subject to the capital gains tax regardless of whether they are Greek tax residents. Also, listed shares that had been acquired before 01/01/2009 are, when transferred, outside the scope of capital gains tax, irrespective of the percentage of the participation in the share capital of the issuer.

By virtue of the NITC, capital gains realized from the transfer of shares by natural persons, who hold 0.5% or more of the share capital of the issuer and who are tax residents of Greece and do not act in the context of a business, shall be subject to a 15% tax, after setting off losses of the same or previous five fiscal years from the sale of securities (shares, bonds, partnership quotas, treasury bills and derivatives). This tax exhausts the tax liability of the same individuals with respect to such income. Generally, the taxable capital gain equals to the difference between the consideration received from the disposal of the shares and their acquisition price, both prices being determined on the basis of the transaction receipts issued by the relevant intermediary bank or investment services firm.

Pursuant to the NITC, capital gains from the sale of shares generated by natural persons holding 0.5% or more of the share capital of the issuer and that are tax residents of other countries that have tax treaties with Greece are not subject to Greek taxation provided that such individuals file with the Greek tax authorities documentation required under the relevant tax treaty to prove their tax residence.

Capital gains from the disposal of the shares that are realized by legal entities which have their tax residence or maintain a permanent establishment in Greece with which such gains are effectively connected, shall be subject to corporate income tax at a rate of (i) 26%, 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.

Capital gains from the sale of shares generated by legal entities that do not have their tax residence or a permanent establishment in Greece, are not subject to Greek taxation.

The Greek legislation addressing taxation of gains from disposition of shares is new and therefore investors should consult their tax advisors regarding the taxation of disposition of shares in their particular circumstances.

A transaction tax is imposed on the sale of shares listed with ATHEX. Such tax is imposed at a rate of 0.2% on the share transfer price and is borne by the seller, whether the seller is a natural or legal person, regardless of tax residency, and irrespective of any tax exemptions applicable.

The issuance and transfer of shares as well as the payment of dividends is exempt from stamp duty in Greece.

Inheritance or succession taxes are payable in Greece on shares of Greek domiciled companies on a progressive system which depends on the degree of the relationship between the deceased and the beneficiary. The taxable basis for stock exchange listed shares is prescribed in Greek Law 2961/2001, as amended and currently in force.

A similar system of progressive taxation applies to the donation of listed shares.

Article 4(4) of Greek Law 4038/2012 imposes a transaction tax of 0.2% on share lending transactions effected over the counter if such shares are listed on the ATHEX, while no stamp duty applies on the relevant agreement. The 0.2% tax is calculated on the value of the shares lent and is borne by the lender, whether individual or legal entity, regardless of the nationality and tax residency, domicile or registered seat and of whether they are exempt from any other tax or fee prescribed by other laws.

According to the provisions of article 4 of the NITC, an individual is considered a tax resident of Greece if one of the following conditions is met:

Although this paragraph does not exclude application of the above, an individual that is physically present in Greece for a period exceeding 183 days during a calendar year which coincides with the fiscal year, either uninterrupted or at intervals, is considered a tax resident of Greece from the first day of presence, excluding individuals present in Greece only for tourist, medical, curative or other similar reasons for a period not exceeding 365 days (including short intervals abroad).

A legal entity or other entity is considered a tax resident of Greece if one of the following conditions is met:

Companies that are established and operate according to Greek Law 27/1975 (on the taxation of vessels) and Greek Law 2687/1953 (on the investment and protection of foreign capital) are explicitly excluded from the application of the new provisions on tax residence.

Until December 31, 2013, article 21 of Greek Law 3943/2011 and article 4 of Greek Law 4038/2012, were valid. According to those provisions sociétés anonymes and limited liability companies should obtain a tax certificate upon the completion of a tax audit conducted by individual certified auditors and audit firms registered in the public registry of Greek Law 3693/2008. Specifically, the certificate must express an opinion of tax compliance and any tax "infringements" must be explicitly stated in the certificate. The content of the tax certificate issued by certified auditors is subject to examination by the tax authorities, and any omission by the certified auditors may result in penalties and administrative sanctions. If the tax certificate does not include comments and findings of tax violations, the taxpayer company will not be subject to a regular tax audit (unless the provisions of article 80 of Greek Law 3842/2010 apply, which provides for a methodology risk analysis system for selecting taxpayer companies to be audited). Moreover, competent tax authorities will conduct, as priority, investigations for sociétés anonymes and Ltd companies for which tax certificates have not been issued and administrative sanctions will be applied.

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

As at January 1, 2014, the provisions of article 65A of new income tax Greek Law 4174/2013 (as amended by Greek Law 4223/2013) apply. Similar to the previous law provisions, certified auditors and audit firms registered in the public registry of Greek Law 3693/2008 performing mandatory audits on sociétés anonymes, limited liability companies and branches of foreign entities should issue annual tax certificates. Such certificate is issued upon completion of a tax audit performed along with the regular audit and certifies the tax compliance of the tax payer. The tax certificate should made detailed reference of any tax incompliance noticed throughout the tax audit.

Penalties apply for tax payers not obtaining a tax certificate according to the provisions of the above mentioned law, while this (along with certified by the auditors tax law infringements) may constitutes a risk factor for the company to be selected from the Greek tax authorities for -official- additional tax audit. Moreover, penalties and sanctions may apply to the auditors breaking the provisions of the relevant law.

These provisions of article 65A will not apply to tax periods beginning from January 1, 2016 onwards.

Greece has been experiencing significant political volatility since December 2014 due to the uncertainty caused by the announcement of early elections on January 2015. Uncertainty was further extended as the new Government entered a protracted period of negotiations with its official lenders regarding the completion of the Program and the prospect of transition to a new form of financial arrangement with official sector lenders.

This environment of uncertainty has led to a sharp decline of Greek banking system deposits (about EUR 22.6 billion cumulative loss of private sector deposits in the first quarter of 2015—Bank of Greece data). Furthermore, the ECB Governing Council decided to lift the existing waiver of a minimum credit rating requirement for marketable instruments issued or guaranteed by the Hellenic Republic to be used as collateral in Eurosystem monetary policy operations. As a result, Greek banks turned towards the ELA mechanism in order to safeguard liquidity.

Within the above remarkably difficult context, we seek to capitalize on our competitive strengths and position ourselves to actively participate in the eventual recovery of the Greek economy. In addition, we seek to benefit from the diversification and the growth potential of our presence in the Turkish market which is expected to keep providing high interest margins and portfolio growth within a positive economic environment.

Following completion of the share capital increase on May 13, 2014, the HFSF owns 57.2% of the Bank's common share capital. Also, various domestic pension funds owned in total approximately 0.8% of the Bank's common share capital, and other domestic public sector related legal entities and the Church of Greece owned in total approximately 0.2% of the Bank's common share capital. See Item 3.D, "Risk Factors—Risks Relating to the Hellenic Republic Economic Crisis—Uncertainty resulting from the Hellenic Republic's economic crisis has had and will continue to have a significant adverse impact on our business, results of operations and financial condition." and Item 7.A, "Major Shareholders".

Following implementation of the preference share facility of the Hellenic Republic Bank Support Plan, the Hellenic Republic currently owns all of the 270 million redeemable preference shares issued under this facility. These preference shares carry voting rights at the general meeting of preferred shareholders. The Hellenic Republic has also appointed a representative to the Bank's Board of Directors who has veto power relating to corporate decisions both at the Board level and at the General Meeting on resolutions of a strategic nature, or materially affecting the Bank's legal or financial status and requiring approval by the General Meeting of Shareholders of the Bank, relating to distribution of dividends and bonus policy for the Bank's Chairman, Chief Executive Officers, other Board Members, General Managers and their deputies, following a decision by the Minister of Finance and Economics or provided that the Nominated Representative considers that the resolution of the Board of Directors may endanger the interests of depositors or substantially affect the Bank's insolvency and proper operation. For a description of the Bank's dividend policy please refer to Item 8, "Financial Information". In case they are not redeemed within five years from their issuance or no decision has been undertaken by the participating bank's General Meeting of Shareholders on redemption, the Greek Minister of Finance shall impose, pursuant to a recommendation by the Bank of Greece, a gradually cumulative increase of 2% per year on the 10% fixed return provided for, during the first five years from the issuance of the shares to the Hellenic Republic. For more information on the Hellenic Republic Bank Support Plan, please see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic's Bank Support Plan".

For powers vested in the HFSF in case it participates in a Greek credit institution, 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, 2014, 11.2% of the Bank's outstanding loans were to the Hellenic Republic and state-related entities, and 5.4% 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 Item 4.B, "Business Overview—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, 2014.

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⁾	UK	—		—		—
Revolver 2008-1 PLC⁽¹⁾	UK	—		—		—
Spiti PLC⁽¹⁾	UK	—		—		—
Autokinito PLC⁽¹⁾	UK	—		—		—
Agorazo PLC⁽¹⁾	UK	—		—		—
Turkish Operations
Finansbank A.S.	Turkey	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	%
Finans Investment Trust A.S.	Turkey	5.30	%	75.98	%	81.28	%
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	%
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	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	%

Primary Operating Area	Country of incorporation

Interlease E.A.D.	Bulgaria	100.00	%	—		100.00	%
Interlease Auto E.A.D.	Bulgaria	—		100.00	%	100.00	%
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.	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.)	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.	Greece	—		70.00	%	70.00	%
FB Insurance Agency Inc	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) (under liquidation)	Greece	—		100.00	%	100.00	%
Astir Palace Vouliagmenis S.A.	Greece	85.35	%	0.00	%	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	%

As at December 31, 2014, the Group owned 2,962 properties, of which 1,934 are buildings. The Group's real estate portfolio was recorded at a net book value of EUR 1,726 million as at December 31, 2014, compared to EUR 1,023 million as at December 31, 2013, 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 242 million as at December 31, 2014, 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.

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

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

The following tables set forth the average balances of our assets and liabilities for the years ended December 31, 2012, 2013 and 2014, 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,

	2012								2013								2014
	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		492			4		1	%		424			2		1	%		447			1		—
Interest bearing deposits with banks and securities purchased under agreements to resell and money market investments		3,302			18		1	%		2,052			10		1	%		2,240			4		—
Trading, available for sale and held to maturity securities⁽¹⁾		9,961			565		6	%		5,497			260		5	%		4,041			211		5	%
Loans and other interest earning assets⁽²⁾		54,263			2,073		4	%		48,675			1,869		4	%		48,414			1,725		4	%
Less: Allowance for loan losses		(4,437	)		—		—			(5,789	)		—		—			(6,782	)		—		—
Net loans		49,826			—		—			42,886			—		—			41,633			—		—

Total interest earning assets		63,581			2,660		4	%		50,859			2,141		4	%		48,361			1,941		4	%
Total non interest earning assets		13,120								12,426								10,977

Total assets		76,701								63,285								59,338



Liabilities:
Total deposits		72,635			1,242		2	%		68,105			968		1	%		58,741			663		1	%
Securities sold under agreements to repurchase		285			9		3	%		1,012			15		2	%		1,534			15		1	%
Long term debt, other borrowed funds and other interest bearing liabilities		—			—		—			48			3		6	%		55			3		5	%

Total interest bearing liabilities		72,921			1,250		2	%		69,165			986		1	%		60,330			681		1	%
Total non interest bearing liabilities		12,692								8,287								9,055

Total Liabilities		85,612								77,452								69,385

	Year ended December 31,

	2012								2013								2014
	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		2,155			4		0	%		3,114			4		0.1	%		2,985			3		—
Interest bearing deposits with banks and securities purchased under agreements to resell and money market investments		1,791			31		2	%		1,313			15		1.1	%		1,577			24		2	%
Trading, available for sale and held to maturity securities⁽¹⁾		3,617			327		9	%		10,727			316		2.9	%		14,418			407		3	%
Loans and other interest earning assets⁽²⁾		25,863			2,912		11	%		26,778			2,701		10.1	%		23,575			2,597		11	%
Less: Allowance for loan losses		(1,997	)		—		—			(1,104	)		—		0.0	%		(1,226	)		—		—
Net loans		23,866			—		—			25,674			—		0.0	%		22,350			—		—

Total interest earning assets		31,429			3,274		10	%		40,828			3,036		7.4	%		41,330			3,031		7	%
Total non interest earning assets		4,017								3,640								7,052

Total assets		35,446								44,468								48,382



Liabilities:
Total deposits		22,427			1,276		6	%		23,633			1,276		5.4	%		25,693			1,110		4	%
Securities sold under agreements to repurchase		1,168			51		4	%		1,779			51		2.9	%		3,724			82		2	%
Long term debt, other borrowed funds and other interest bearing liabilities		4,305			156		4	%		4,254			156		3.7	%		6,190			269		4	%

Total interest bearing liabilities		27,900			1,483		5	%		29,666			1,483		5.0	%		35,607			1,461		4	%
Total non interest bearing liabilities		2,683								3,320								3,265

		30,583								32,986								38,872

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.

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.

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

On December 31, 2014, the Group's securities had a carrying value of EUR 18.3 billion, representing 16.8% of the Group's total assets and sovereign securities held accounted for EUR 16.9 billion, or 92.8% of the Group's securities portfolio. In preparing the U.S. GAAP Financial Statements, the Group classified its securities as required by U.S. GAAP according to the following categories: trading, AFS and HTM.

The market and book value of Greek government bonds and treasury bills bonds held by the Group (which includes securities held in our trading, AFS and HTM portfolios) on December 31, 2014 was EUR 2,832 million and EUR 2,777 million respectively. The book value of Greek government bonds represents 2.6% of the Group's total assets.

Furthermore, on December 31, 2014, the Group held debt securities rated Aaa to A3 (or equivalent), issued by Germany, the EFSF, ESM and EIB (classified as trading, AFS or HTM) with a market value of EUR 9,584 million and book value of EUR 9,397 million and through its subsidiary Finansbank, held securities issued by the Republic of Turkey (classified as trading, HTM and AFS) with a market and book value of EUR 3.0 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, 2012, 2013 and 2014:

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, 2012, 2013 and 2014:

	Year ended December 31,

	2012									2013									2014
	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		1,641		84		(43	)		1,682		1,843		120		—			1,963		802		46		(111	)		737
Debt securities issued by other governments and public sector entities		3,316		175		(3	)		3,488		2,710		34		(88	)		2,656		2,919		115		(13	)		3,021
Greek treasury bills		—		—		—			—		157		—		—			157		168		—		—			168
Foreign treasury bills		318		—		(1	)		317		340		—		—			340		270		—		(1	)		269
Debt securities issued by companies incorporated in Greece		568		1		(82	)		487		416		27		(34	)		409		398		31		(27	)		402
Debt securities issued by companies incorporated outside Greece		534		15		(42	)		507		463		18		(20	)		461		328		15		(13	)		330
Equity securities issued by companies incorporated in Greece		56		32		—			88		73		35		(1	)		107		35		9		(3	)		41
Equity securities issued by companies incorporated outside Greece		19		8		—			27		9		10		—			19		8		11		—			19
Mutual fund units		460		37		(2	)		495		242		32		(1	)		273		215		6		(5	)		216

Total available-for-sale securities		6,912		352		(173	)		7,091		6,253		276		(144	)		6,385		5,143		233		(173	)		5,203



Held-to-maturity securities
Greek government bonds		120		31		(1	)		150		67		65		—			132		73		55		—			128
Debt securities issued by other governments and public sector entities		92		19		—			111		10,064		101		(57	)		10,108		10,269		260		—			10,529
Foreign treasury bills		144		—		—			144		109		—		—			109		99		—		—			99
Debt securities issued by companies incorporated outside Greece		—		—		—			—		120		2		—			122		204		9		—			213



Total held-to-maturity securities		356		50		(1	)		405		10,360		168		(57	)		10,471		10,645		324		—			10,969

As at December 31, 2013 and 2014, the Group did not hold any U.S. federal debt securities.

	Year ended December 31, 2014

	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		132		3	%		131		121		4	%		121		87		3	%		90		20		3	%		22
Greek treasury bills		1,802		2	%		1,799		—		0	%		—		—		0	%		—		—		0	%		—
Foreign treasury bills		123		0	%		123		10		0	%		10		—		0	%		—		—		0	%		—
Debt securities issued by Greek financial institutions		—		0	%		—		2		5	%		2		—		0	%		—		—		0	%		—
Debt securities issued by foreign financial institutions		16		4	%		16		52		2	%		39		—		0	%		—		—		0	%		—
Debt securities issued by companies incorporated in Greece		8		0	%		9		15		6	%		13		10		4	%		9		—		0	%		—
Debt securities issued by companies incorporated outside Greece		8		1	%		8		1		0	%		1		—		0	%		—		—		0	%		—

Total trading account debt securities		2,089		2	%		2,086		201		3	%		186		97		3	%		99		20		3	%		22



Available-for-sale debt securities:
Greek government and agencies		—		0	%		—		490		5	%		397		25		6	%		22		287		6	%		317
Debt securities issued by other governments and public sector entities		350		7	%		351		1,047		7	%		1,062		1,122		7	%		1,163		400		5	%		444
Greek treasury bills		168		2	%		169		—		0	%		—		—		0	%		—		—		0	%		—
Foreign treasury bills		270		4	%		270		—		0	%		—		—		0	%		—		—		0	%		—
Corporate debt securities issued by companies incorporated in Greece		141		17	%		160		157		13	%		149		100		8	%		93		—		0	%		—
Debt securities issued by companies incorporated outside Greece		60		3	%		58		87		2	%		86		102		2	%		110		79		4	%		76

Total available-for-sale debt securities		989		6	%		1,008		1,781		7	%		1,694		1,349		7	%		1,388		766		5	%		837



Held-to-maturity securities:
Greek government and agencies		—		0	%		—		—		0	%		—		7		16	%		14		66		12	%		114
Debt securities issued by other governments and public sector entities		178		12	%		177		3,200		2	%		3,241		6,869		2	%		7,087		22		5	%		24
Foreign treasury bills		99		3	%		99		—		0	%		—		—		0	%		—		—		0	%		—
Debt securities issued by foreign financial institutions		—		0	%		—		145		5	%		150		46		6	%		51		—		0	%		—
Debt securities issued by companies incorporated outside Greece		—		0	%		—		—		0	%		—		13		6	%		12		—		0	%		—

Total held-to-maturity debt securities		277		9	%		276		3,345		2	%		3,391		6,935		2	%		7,164		88		10	%		138

As at December 31, 2014, the amount of the Group's total net loans equaled EUR 65.4 billion. The Group's loan portfolio consists of 46.0% consumer and 54.0% commercial loans (see Note 13 to the U.S. GAAP Financial Statements). As at December 31, 2014, loans to Greek residents represent 64.3% 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, 2010, 2011, 2012, 2013 and 2014.

	Year ended December 31,

	2010			2011			2012			2013			2014
	(EUR in millions)
Greek residents:
*Consumer:*
Residential mortgages		19,544			18,763			17,985			17,720			17,458
Credit card		1,773			1,527			1,459			1,381			1,317
Auto financing		406			309			209			138			88
Other consumer		4,853			4,763			4,709			4,694			4,207

Total		26,576			25,362			24,362			23,933			23,070

*Commercial:*
Industry and mining		3,675			4,084			5,132			4,725			5,217
Small-scale industry		2,090			1,962			1,779			2,123			1,929
Trade		7,789			7,375			7,038			7,562			7,425
Construction		1,227			1,132			987			1,082			1,098
Tourism		484			480			454			612			607
Shipping and transportation		2,153			2,217			2,182			2,174			2,437
Commercial mortgage		881			775			664			579			529
Public sector		8,861			8,711			5,608			5,848			5,390
Other		247			88			112			655			600

Total		27,407			26,824			23,956			25,360			25,232

Total Greek residents loans		53,983			52,186			48,318			49,293			48,302
Unearned income		(59	)		(93	)		(53	)		(48	)		(67	)

Total Greek residents loans net of unearned income		53,924			52,093			48,265			49,245			48,235

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, 2014, was EUR 4.8 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,

	2010			2011			2012			2013			2014
	(EUR in millions)
Foreign:
*Consumer:*
Residential mortgages		4,726			4,148			4,368			3,889			3,679
Credit card		3,504			3,763			5,190			4,244			3,526
Auto financing		206			144			107			62			39
Other consumer		3,084			2,991			3,888			3,680			4,281

Total		11,520			11,046			13,553			11,875			11,525

*Commercial:*
Industry and mining		2,974			3,020			2,569			2,322			2,894
Small-scale industry		1,449			1,296			1,496			1,721			2,502
Trade		3,785			3,601			3,684			3,722			5,299
Construction		1,598			1,629			1,813			1,999			2,103
Tourism		397			279			277			348			508
Shipping and transportation		781			800			813			786			852
Commercial mortgage		701			647			619			262			228
Public sector		392			281			238			252			232
Other		1,708			1,479			1,186			858			689

Total		13,785			13,032			12,695			12,270			15,307

Total foreign loans		25,305			24,078			26,248			24,145			26,832
Unearned income		(190	)		(168	)		(179	)		(155	)		(159	)

Total foreign loans net of unearned income		25,115			23,910			26,069			23,990			26,673
Total loans net of unearned income		79,038			76,003			74,334			73,235			74,908

Less: Allowance for loan losses		(3,175	)		(6,551	)		(7,318	)		(7,751	)		(9,492	)

Total net loans		75,863			69,452			67,016			65,484			65,416

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, below in Item 4.E, "Selected Statistical Data—Credit Quality and Risk Management—Credit Quality—Risk Management—Loan Approval Process". Greek government-subsidized mortgage loans 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, 2014.

	Year ended December 31, 2014

	Within one year or less			After one year through five years			After five years			Total
	(EUR in millions)
Greek Residents:
*Consumer:*
Residential mortgages		5,520			2,468			9,470			17,458
Credit card		1,317			—			—			1,317
Auto financing		58			29			1			88
Other consumer		2,662			740			805			4,207

Total		9,557			3,237			10,276			23,070

*Commercial:*
Industry and mining		2,699			1,621			897			5,217
Small-scale industry		1,144			533			252			1,929
Trade		4,398			2,036			991			7,425
Construction		747			215			136			1,098
Tourism		347			174			86			607
Shipping and transportation		1,104			908			425			2,437
Commercial mortgages		252			187			90			529
Public sector		442			791			4,157			5,390
Other		478			54			68			600

Total		11,611			6,519			7,102			25,232

Total Greek residents loans		21,168			9,756			17,378			48,302

Foreign:
*Consumer:*
Residential mortgages		133			1,565			1,981			3,679
Credit card		3,074			375			77			3,526
Auto financing		12			26			1			39
Other consumer		671			2,977			633			4,281

Total		3,890			4,943			2,692			11,525

*Commercial:*
Industry and mining		1,448			867			579			2,894
Small-scale industry		1,892			492			118			2,502
Trade		2,421			1,908			970			5,299
Construction		764			651			688			2,103
Tourism		148			265			95			508
Shipping and transportation		245			389			218			852
Commercial mortgages		117			74			37			228
Public sector		53			61			118			232
Other		183			328			178			689

Total		7,271			5,035			3,001			15,307

Total foreign loans		11,161			9,978			5,693			26,832
Unearned income		(113	)		(82	)		(31	)		(226	)

Loans, net of unearned income		32,216			19,652			23,040			74,908
Less: Allowance for loan losses		(9,492	)		—			—			(9,492	)

Total net loans		22,724			19,652			23,040			65,416

Out of the Group's loans outstanding at December 31, 2014 that are due after one year, EUR 16.0 billion had fixed interest rates while EUR 26.7 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 year ended December 31, 2012 was to Turkey, Bulgaria, Romania, Fyrom, and for the years ended December 31, 2013 and 2014 was to Turkey, Bulgaria, Romania, Fyrom and United Kingdom. These foreign country outstandings represent additional economic and political risks. For additional information on the macroeconomic and political risks from operating in Turkey, as well as for the risks of conducting significant international activities and expanding in emerging markets, see Item 3.D, "Risk Factors".

The tables below show the amount of foreign country outstandings as at December 31, 2012, 2013 and 2014, in each foreign country where such outstanding amounts exceeded 1% of the Group's total assets.

The table below shows the amount of foreign country loans, excluding unearned income, by type of borrower for countries where the Group's exposure exceeded 1% of total assets at December 31, 2012, 2013 and 2014.

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

The discussion below relates to the Bank and Finansbank. The loan approval process across our banking subsidiaries (Finansbank, 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 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 customers are rated through the Moody's Risk Analyst™ ("MRA") 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"). Another 28% of corporate customers 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 Risk Officer. Different Credit committees and credit approval authorities apply to Corporate Portfolio.

For the Corporate Portfolio, except for 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 four sub-divisions: Mortgage Lending, Consumer Banking, Credit Cards and Small Business Lending Unit (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 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, 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% of the asset's market value. Average LTV of mortgage loans originated in 2014 stood at 53.8% while in 2013 stood at 54.5%, compared to 62.8% in 2012. As at December 2014, average current LTV of the total Greek mortgage portfolio was 85.7%.

Due to the abovementioned stringent underwriting criteria applied in recent years, our approval rate for mortgage lending has decreased from 80% in 2008 to 33% in 2011, 29% in 2012 and 49% in 2013. As customers' behavior matures in the environment developed by the 2008 crisis, there is a further increase in the approval rate which stands at 63% in 2014, compared to 49% in 2013. 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.

As at December 31, 2014, 10.7% of our 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 mortgages 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 for half of the loan's contractual life with a maximum of 8 to 10 years, depending on the relevant Ministry's decisions. These mortgages follow the same underwriting procedure as all other mortgage loans; however, the borrower has to comply with certain lending criteria imposed by the Hellenic Republic in order to be eligible for a subsidy. These criteria mainly refer to the borrower's financial and family status.

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 is offered for 9 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.

As at December 31, 2014, the total amount of mortgage loans subsidized by the Hellenic Republic or OEK amounted to EUR 709 million, from EUR 1,062 million in December 2013 and EUR 1,541 million in December 2012. As at December 31, 2014 subsidized loans that are over 90dpd in principal or interest amount decrease to EUR 48 million, from EUR 74 million in 2013 and EUR 126 million in 2012.

Mortgages guaranteed by the Hellenic Republic represent loans to victims of natural disasters (e.g. earthquakes, floods, landslides and fires), loans to Greeks repatriated from the former Soviet Union and loans to Greek Roma. The Hellenic Republic guarantees both the principal and the interest of these loans. Loan applications do not follow the Bank's origination process. Instead, all documentation as well as the loan application is submitted to the relevant public authority for approval. The maximum amount per loan is EUR 60,000 with the exception of the loans to victims of natural disasters where the loan amount is determined by the public authority, in accordance with the guidelines set by Greek legislation. These guaranteed mortgages 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, 2014, the total amount of mortgage loans guaranteed by the Hellenic Republic amounted to EUR 1,156 million, from EUR 1,232 million in December 2013 and EUR 1,322 million in December 2012. As at December 31, 2014, guaranteed loans that are over 90 days past due in principal or interest amount to EUR 65 million, compared to EUR 47 million in 2013 and EUR 47 million in 2012. 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, 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 Directive 42.

Collateral values and related trends in Greece are monitored and updated based on independent appraisals, an independent published Greek real property index and official reports prepared by the Bank of Greece.

For the mortgage portfolio, only in very rare cases we expect to recover the outstanding balance through foreclosure taking into consideration the LTV ratio. The average current LTV of our mortgage portfolio at December 31, 2014 was 85.7% up from 74.7% as at December 31, 2013, mainly due to the

fall in property prices. We believe that the possibility of foreclosure deters 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 values 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.

Similar practices are followed by our subsidiary in Turkey, while our SEE subsidiaries, in general, perform appraisals more frequently.

According to the Group impairment methodology, corporate business units that are responsible for the impairment assessment have to ensure that in cases where cash flows are expected from collateral liquidation, collateral value has to be based on a recent (within the current year) independent appraisal from a qualified appraiser, unless loan exposures are significantly lower than the collateral values.

Finansbank follows credit procedures similar to those used by the Bank, from approval to remedial management, follow-up and implementation. The Credit Department approves loans within the framework of its policy and ensures the collectability of the loan through receipt of proper security.

Finansbank's Board of Directors has the right to grant loans within the limits set by Turkish Banking Law and may assign its credit-granting authority to the Credit Committee and Finansbank head office up to 1% and 10% of capital, respectively. Finansbank may delegate this credit-granting authority in its units, regional offices and branches. Finansbank head office and regions are authorized to approve exposures up to TRY 80 million.

Loans between TRY 80 million and TRY 800 million are approved by the Credit Committee, which consists of the General Manager and three permanent and two reserve members of the Finansbank Board of Directors. Extensions of credit in excess of TRY 800 million are approved by the Board of Directors.

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 Group Risk Control and Architecture Division ("GRCAD") along with 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 22-grade scale using calibrated and validated rating systems with each grade corresponding to a probability of default.

The Bank uses a number of obligor rating models, assigning a borrower rating to each Corporate Banking Portfolio customer. This rating is based on quantitative and qualitative criteria. Additionally, the Bank's and its subsidiaries' rating systems considers the borrower's industry risk and relative position within its peer group. As the Group gradually complies with Basel II Internal Ratings Based methods, corporate borrower ratings are mapped to probabilities of default in order to estimate specific expected loss per obligor.

The Bank manages its corporate credit granting function, controls credit exposures and ensures regulatory compliance with a set of obligor, industry and 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 collecting past due amounts for corporate portfolios, ensuring proactive remedial management and reducing costs.

The Bank has completed its estimation of key credit risk measurement variables, including probability of default 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 Law 4224/2013 and Bank of Greece Executive Committee Directive #42. 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 Law 4224/2013 and Bank of Greece Executive Committee Directive #42).

While the underwriting units are responsible for the day to day operations of credit risk, the Credit Policy Committee controls the whole lending process by approving the lending criteria, the credit risk policies and delegating authority depending on the type of product. The establishment of effective and efficient internal policies, procedures and methodologies for the definition, quantification, measurement and control of credit risk is the responsibility of the credit risk management unit.

Finansbank has established maximum concentration limits for specific sectors and industries in order to diversify risk and thereby lessen the impact it has on the value of Finansbank's credit portfolio. In addition to aggregated limits per customer, there are also base limits per product in place. The counterparty credit risk exposure limits cover the potential future exposure calculations that may result from to market fluctuations.

Finansbank actively mitigates risk through collateral management. In doing so, it must meet certain legal and operational requirements with respect to its collateral. Particularly, the enforceability of collateral arrangements must be confirmed through sufficient legal review under the applicable law in all relevant jurisdictions. If the collateral is held by a third party, the collateral should be segregated from the third party's own assets. The market value of the collateral should be appraised annually at a minimum, but appraisal at more frequent intervals may be required whenever there is a reason to believe that the collateral's market value has decreased significantly.

Finansbank has established a sound internal rating system through the use of rating models and processes to ensure robustness across all lending types. The Risk Management unit is responsible for evaluating these rating models and monitoring their performance, stability and, where necessary, making improvements.

Finansbank credit risk process requires the continuous monitoring of customers' credit risk profiles for the life of the credit line. The underwriting department is tasked with maintaining the accuracy and quality of the information flow, with monitoring the financial standing and business risk profiles of customers and with updating corporate ratings and reviewing customer credit limits at least annually.

Finansbank early warning systems ensure that customers' profiles with a significant deterioration in credit quality or payment performance are transferred to watch list and closely monitored. Similarly, restructured and rescheduled loans are monitored with special care in line with the Credit Risk Policy.

In general, for domestic loans the accrual of interest is discontinued at the time the loan is 90 days delinquent unless the credit is well secured and in process of collection. Residential real estate loans are placed on non-accrual status at the time the loan is 180 days delinquent. In addition, 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 20,044 million as at December 31, 2014 compared to EUR 19,573 million as at December 31, 2013. This corresponds to 26.8% of the Group's loans outstanding at the same date. Of the Group's non-accruing loans, EUR 16,450 million or 82.1% were held by the Bank. This amount represented 33.9% 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

divisioins 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 Item 4.E, "Selected Statistical Data—Credit Quality and Risk Management—Credit Quality—Risk Management—Credit Review Policies".

For Turkish and International entities, the accrual of interest is typically discontinued at the time the loan is 90 days delinquent. In addition, 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, 2010, 2011, 2012, 2013 and 2014:

	Year ended December 31,

	2010		2011		2012		2013		2014
	(EUR in millions)
Domestic loans:
Accruing loans:
Past due 90 days—180 days		680		668		639		436		306
Past due 180 days—365 days		51		102		191		146		—

Total accruing loans		731		770		830		582		306

Non-accruing loans:
Past due 0 days—90 days		—		1807		2,159		3,447		2,865
Past due 90 days—180 days		393		881		1,007		925		479
Past due 180 days—365 days		1,052		1,455		1,946		1,397		986
Past due 365 days or more		2,903		4,581		7,619		10,123		12,275

Total non-accruing loans		4,348		8,724		12,731		15,892		16,605



Foreign loans:
Accruing loans:
Past due 90 days—180 days		205		66		23		10		5
Past due 180 days—365 days		64		91		183		—		—

Total accruing loans		269		157		206		10		5



Non-accruing loans:
Past due 0 days—90 days		—		487		465		811		577
Past due 90 days—180 days		445		227		305		302		226
Past due 180 days—365 days		364		402		358		414		607
Past due 365 days or more		1,268		1,627		2,066		2,154		2,029

Total non-accruing loans		2,077		2,743		3,194		3,681		3,439

Non-accruing loans amounted to EUR 20,044 million as at December 31, 2014 compared to EUR 19,573 million and EUR 15,926 million as at December 31, 2013 and 2012, respectively. Total non-accruing loans increased by 38.9%, 22.9% and 2.4% between 2011 and 2012, 2012 and 2013, and 2013 and 2014, respectively with the majority of the increase due to domestic non-accruing loans both in 2012, 2013, and 2014. 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, 2013 and 2014, 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 127 million and EUR 134 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, 2012, 2013 and 2014:

TDR loans granted during the year ended December 31, 2013 amounted to EUR 3,998 million and increased by 5.5% compared to TDR loans granted during the year ended December 31, 2012. The significant amount of loans restructured during 2013 reflected the efforts made by the Bank to propose new and more efficient restructuring products to its customers.

TDR loans granted during the year ended December 31, 2014 amounted to EUR 2,999 million and decreased by 25.0% 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.

Modified not TDR loans and TDRs decreased by 8.8% between 2012 and 2013 and are mainly constituted by Finansbank's loan interest rate modifications, which are offered to customers that can obtain funds from other sources at a market interest rate.

Modified not TDR loans increased by 116.9% between 2013 and 2014 mainly due to the change in Group's estimate described 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, 2014, the percentage of TDRs loans granted during the last 12 months that became past due (+30 dpd) was 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, 2013, the respective percentages were 25.3% for consumer loan portfolio and 19.2% for commercial loan portfolio, and 10.4% and 5.1%, respectively for modified loans.

As at December 31, 2013 and 2014, the percentage of modified loans which were subsequently modified again was 22.5% and 47.7%, respectively; the increase compared to 2013 is due to the revision of estimates regarding the triggers used to determine whether an exposure is TDR. These loans are included in the percentage of TDR granted in the last 12 months that became past due (+30 days past due) after modification only if their last modification occurred during the last 12 months and they have become past due (+30 days past due) subsequent to re-modification.

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, 2013 and 2014.

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, 2014 compared with the year ended December 31, 2013" and Item 5.A, "Operating Results—Results of Operations for the year ended December 31, 2013 compared with the year ended December 31, 2012."

The following table illustrates the activity in the loan loss allowance balance over the previous five years:

	Year ended December 31,

	2010			2011			2012			2013			2014
	(EUR in millions)
Domestic:
Balance at beginning of year		1,325			2,123			5,434			5,797			6,210
Add: Allowances for probable loan losses from continuing operations		878			3,379			1,844			541			1,696
Write-offs		(85	)		(77	)		(126	)		(138	)		(107	)
Recoveries		5			8			3			11			9

Less: Net write-offs		(80	)		(69	)		(123	)		(127	)		(98	)
Loans exchanged in the PSI		—			—			(1,357	)		—			—
Translation differences		—			1			(1	)		(1	)		(20	)

Domestic balance at end of year		2,123			5,434			5,797			6,210			7,788

Foreign:
Balance at beginning of year		740			1,052			1,117			1,521			1,541
Add: Allowances for probable loan losses from continuing operations		327			325			478			428			476
Write-offs		(55	)		(92	)		(94	)		(111	)		(82	)
Recoveries		18			23			16			77			69

Less: Net write-offs		(37	)		(69	)		(78	)		(34	)		(13	)
Sale of impaired loans		—			(107	)		(8	)		(216	)		(330	)
Translation differences		22			(84	)		12			(158	)		30

Foreign balance at end of year		1,052			1,117			1,521			1,541			1,704

Total balance at end of year		3,175			6,551			7,318			7,751			9,492

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, 2010, 2011, 2012, 2013 and 2014.

	2010				2011				2012				2013				2014

	Amount		%⁽¹⁾		Amount		%⁽¹⁾		Amount		%⁽¹⁾		Amount		%⁽¹⁾		Amount		%⁽¹⁾
	(EUR in millions, except percentages)
Greek residents:
Consumer
Residential mortgages		229		25		529		25		894		24		881		25		1,273		23
Credit card		335		2		416		2		536		2		640		2		667		2
Auto financing		—		1		—		—		—		—		—		—		—		—
Other consumer		593		6		1,010		6		1,470		7		1,803		6		1,964		6

Total		1,157		34		1,955		33		2,900		33		3,324		33		3,904		31

Commercial
Industry and mining		263		5		515		5		761		7		771		6		895		7
Small-scale industry		99		3		177		3		217		2		385		3		861		3
Trade		378		10		654		10		960		9		1,122		10		1,422		9
Construction		135		1		153		2		226		1		246		1		314		1
Tourism		24		—		39		1		60		1		41		1		76		1
Shipping and transportation		45		3		55		3		66		3		101		3		162		3
Commercial mortgages		9		1		15		1		20		1		17		1		–33		1
Public sector		—		11		1,855		11		533		8		79		8		63		7
Other		13		—		16		—		54		—		125		1		124		1

Total		966		34		3,479		36		2,897		32		2,887		34		3,884		33

Total Greek residents loans		2,123		68		5,434		69		5,797		65		6,211		67		7,788		64

Foreign:
Consumer
Residential mortgages		51		6		56		5		68		6		77		5		87		5
Credit card		216		4		246		5		371		7		296		6		290		5
Auto financing		—		—		—		—		1		—		—		—		—		—
Other consumer		253		4		304		4		382		5		383		5		379		6

Total		520		14		606		14		822		18		756		16		756		16

Commercial
Industry and mining		144		4		130		4		175		4		211		4		237		4
Small-scale industry		40		2		44		2		133		2		105		2		162		3
Trade		178		5		166		5		119		5		231		6		270		7
Construction		54		2		70		2		107		2		97		3		124		3
Tourism		13		1		14		—		55		—		31		—		39		1
Shipping and transportation		15		1		17		1		15		1		26		1		31		1
Commercial mortgages		4		1		7		1		46		1		41		—		44		—
Other		84		2		63		2		49		2		42		1		41		1

Total		532		18		511		17		699		17		784		17		948		20

Total foreign loans		1,052		32		1,117		31		1,521		35		1,540		33		1,704		36

Unallocated
Total Allowance for loan losses		3,175		100		6,551		100		7,318		100		7,751		100		9,492		100

An analysis of the Group's write-offs and recoveries for non-accruing loans for the years ended 2010, 2011, 2012, 2013 and 2014 is presented in the following table:

	Year ended December 31,

	2010			% of total loans		2011			% of total loans		2012			% of total loans		2013			% of total loans		2014			% of total loans
	(EUR in millions, except percentages)
Write-offs
Greek Residents:
Commercial and industrial		60			0.07		31			0.04		82			0.12		69			0.11		43			0.07
Real estate—construction		4			0.01		11			0.02		3			0.01		29			0.04		—			—
Real estate—mortgage		4			0.01		6			0.01		10			0.01		11			0.02		—			—
Other loans to individuals		17			0.02		29			0.04		31			0.05		29			0.04		64			0.10

Total write-offs for loans to Greek residents		85			0.11		77			0.11		126			0.19		138			0.21		107			0.17

Foreign:
Commercial and industrial		15			0.02		42			0.06		67			0.10		72			0.11		26			0.04
Real estate—construction		7			0.01		1			—		2			—		1			—		2			—
Real estate—mortgage		—			—		4			0.01		1			—		8			0.01		2			—
Other loans to individuals		33			0.04		46			0.07		24			0.04		30			0.05		52			0.08

Total write-offs for foreign loans		55			0.07		93			0.14		94			0.14		111			0.17		82			0.12

Total write-offs		140			0.18		170			0.25		220			0.33		249			0.38		189			0.29



Recoveries
Greek Residents:
Commercial and industrial		—			—		—			—		(1	)		—		—			—		(4	)		0.01
Other loans to individuals		(5	)		0.01		(8	)		0.01		(2	)		—		(11	)		0.02		(5	)		0.01

Total recovery on loans to Greek residents		(5	)		0.01		(8	)		0.01		(3	)		—		(11	)		0.02		(9	)		0.02

Foreign:
Commercial and industrial		(12	)		0.01		(8	)		—		(6	)		0.01		(23	)		0.04		(2	)		—
Real estate—construction		—			—		—			—		—			—		—			—		—			—
Real estate—mortgage		—			—		—			—		—			—		—			—		(1	)		—
Other loans to individuals		(6	)		0.01		(15	)		0.02		(10	)		0.02		(54	)		0.08		(66	)		0.10

Total recovery on foreign loans		(18	)		0.02		(23	)		0.02		(16	)		0.03		(77	)		0.12		(69	)		0.10

Total recoveries		(23	)		0.03		(31	)		0.03		(19	)		0.03		(88	)		0.14		(78	)		0.12

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, 2014, domestic write-offs amount to EUR 107 million

compared to EUR 138 million as at December 31, 2013, 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 South Eastern Europe in which we operate do not face the unprecedented crisis that Greece is currently facing and the enforcement of collateral or exhaustion of legal actions take significantly less time than in Greece and non-accruing loans and write-offs decreased during 2014.

In 2014, foreign write-offs amount to EUR 82 million and mainly constitute of consumer 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, 2012, 2013 and 2014:

	Year ended December 31,

	2012				2013				2014
	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		3,726		0.92		4,596		1.11		5,625		0.78
Savings		16,642		0.25		15,455		0.22		15,592		0.11
Time deposits		16,633		2.85		19,589		3.30		20,864		2.44
Interbank		32,717		1.87		25,781		0.73		15,333		0.14
Other		519		3.59		621		3.09		539		2.51
Non-Greek residents or foreigners:
Demand deposits		449		0.80		353		0.81		818		0.81
Savings		19		0.26		19		0.26		174		0.26
Time deposits		166		2.30		159		2.30		1,034		2.30
Interbank		666		1.07		683		0.37		636		0.22
Deposits in foreign banking offices:
Banks located in foreign countries		4,089		2.17		3,873		1.36		2,925		2.07
Other foreign demand deposits		1,786		0.92		2,079		0.71		2,297		0.52
Other foreign time and savings deposits		17,650		6.89		18,532		5.33		18,597		5.73

Total deposits		95,062		2.65		91,740		2.18		84,434		2.10

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, 2014. 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, 2014.

The table below shows outstanding amounts of short-term borrowings of Group companies for each of the three years ended December 31, 2012, 2013 and 2014.

Of the year-end balance as at December 31, 2014, 99.7% relates to Finansbank borrowings.

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, 2014.

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, 528 branches and 1,414 ATMs as at December 31, 2014. 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.

The Greek economy continued to face significant macroeconomic challenges, originating from the unprecedented effort to correct, since 2010, sizeable fiscal imbalances which were compounded by high uncertainty, an extraordinary contraction of economic activity and deep-rooted structural vulnerabilities which made the achievement of the objectives set out in the Program an enormous challenge.

In 2013, adjustment policies began to bear fruit as a primary surplus of 1.2% of GDP in the general government budget (according to the "Program" definition, Greek Government Budget 2015, Introductory Note)—a year earlier than the Program target. Moreover, a surplus of 0.6% of GDP has been registered in the current account balance of Greece's external transactions, for the first time in sixty years. The current account deficit in Greece's external transactions decreased by 15.5% of GDP between 2008 and 2013. The cyclically adjusted primary balance improved by almost 16% of GDP between 2009 and 2013, and in 2013 it was two time higher than the European average (IMF Fiscal Monitor, October 2014).

In 2014 following six consecutive years of severe contraction, Greece's economy began to grow since the second quarter of 2014 and gained further momentum the second half of 2014 (1.4% year-on-year, ELSTAT data). Real GDP increased by 0.7% year-on-year in 2014 (ELSTAT data), supported mainly by rising private consumption (1.4% year-on-year in 2014), the strong performance of tourism sector (an annual increase of 10.6% year-on-year in tourism revenue, Bank of Greece Data) and positive, albeit relatively slower, growth of goods exports (5.3% in volumes, in 2014). Moreover business investment has picked up offsetting the drag from the continuing sharp drop in residential investment, permitting economy-wide gross fixed capital formation entering positive growth territory since the third quarter of 2014 (3.0% year-on-year in 2014 in constant prices, ELSTAT data).

However, the Greek economy experienced a deterioration of financial market sentiment in the fourth quarter of 2014, reflecting political uncertainty and on-going discussions on the evolution of Greece's relationship with its official lenders and the timing and characteristics of Greece's exit from the current economic support program.

See Item 5. D, "Trend Information" for a detailed discussion of the evolution of Greece's macroeconomic conditions during 2013 and 2014.

The challenges relating to the state of Greek public finances compounded by high uncertainty and rapidly contracting demand and weakening private sector balance sheets, have affected the liquidity and profitability of the financial system in the Hellenic Republic and have resulted in:

Second economic adjustment program, jointly supported by the IMF and the member states of the Eurozone—The Second Program

All data referred to in this sub-section is drawn from the IMF Country Report No. 12/57 (March 2012), and EU Occasional paper on Greece March 2012.

In March 2012, the Government agreed to a second economic adjustment program (the "Second Program"), the term of which extends through 2016 and is 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 73 billion. Of this amount, EUR 52.9 billion has been sourced from Eurozone Member States and EUR 19.9 billion from the IMF. The Second Program has been extended by the Greek government and the Institutions to June 2015 as described below (see "—Macroeconomic developments and progress in fiscal adjustment"), and, as extended, is referred to in this Annual Report as the Program.

Overall, in the Program, for the years 2012-2016, Eurozone Member States through the EFSF and the IMF committed the undisbursed amounts from the original Program, plus an additional EUR 130 billion, intended to cover Greece's expected funding needs fully for the period from 2012 to 2014. During this period, the EFSF could provide an overall amount of EUR 144.7 billion, while the IMF will contribute EUR 28 billion during four years under its Extended Fund Facility ("EFF").

An amount of EUR 75 billion was disbursed by Eurozone Member States in the first half of 2012 in order to fund EUR 35.7 billion of the PSI debt enhancements and accrued interest. Overall, by the end of 2013, Greece had received from the EFSF EUR 133.0 billion (which includes EUR 48.2 billion of HFSF funding, earmarked for bank recapitalization and resolution of which about EUR 38 billion have been utilized) out of the total committed amount of financing of EUR 144.6 billion, under the Second Program, and EUR 8.5 billion of IMF loans. The IMF total contribution of EUR 28 billion is planned to be disbursed in 17 equal tranches until the first quarter of 2016, of which EUR 11.6 billion has been disbursed through May 30, 2014.

The disbursements of financial assistance to Greece are conditional on quarterly reviews for the duration of the arrangement.

The release of the tranches by the lenders will be based on the satisfaction of quantitative performance criteria and a positive evaluation of progress made with respect to policy criteria set by the memorandum of economic and financial policies ("MEFP") and the Memorandum underlying the Second Program and committed to by the Government. Moreover, in April 2012, the Greek parliament passed new legislation prioritizing Government debt service obligations to private and official holders of Greek debt over any other fiscal use of the Second Program funding.

The Second Program's strategy is primarily based on expenditure reduction in order to achieve a primary surplus of 1.5% of GDP in 2014, and 4.5% of GDP by 2016 (source: IMF Country Report No. 13/20, January 2013) and the timely and decisive implementation of growth-enhancing structural reforms. The Second Program also foresees more aggressive nominal wage adjustments and benefit cuts to reduce costs and thus improve price competitiveness, and permit Greece's transition to a more investment and export-led growth model.

The adjustment process also contemplates the successful completion of an ambitious privatization agenda, which has been adapted to economic developments and market conditions domestically and abroad, and the impact of recession on asset valuations. Similarly, the structural reform agenda includes 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 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

The discussion in this section is sourced from the Eurogroup Statement on Greece published on November 27, 2012.

On November 27, 2012, the Eurogroup 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 managed to achieve an agreement 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 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 various debt and other measures to reduce funding needs 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 debt buy-back 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. The buyback entailed exchanging the 20 designated bonds delivered to exchanging holders in the PSI (with a total outstanding value of EUR 62 billion at par) with six-month, zero-coupon, EFSF notes. For each EUR 1,000 principal amount of a designated bond, the bondholder received EFSF notes at purchase prices ranging from 32.2% to 40.1% depending on the maturity of the original PSI bond. The total aggregate amount of EFSF notes issued in the buyback, which closed on December 11, 2012, was EUR 11.3 billion.

Following the settlement of the buyback, Greek debt was reduced by EUR 21.1 billion in net terms. The deal in conjunction with other support measures appeared sufficient (source: IMF Country Report No. 13/241, July 2013) at bringing the Greek debt-to-GDP ratio down from 175.1% of GDP in 2013 (source: ELSTAT Press Release, April 14, 2014), and ensure a trajectory that would bring the debt close to the debt sustainability threshold that Institutions (124% of GDP) has previously defined as sustainable by end 2020 and to below 110% of GDP (source: IMF Country Report No. 13/241, July 2013) in 2022, provided that some additional concession will be made by Eurozone countries along the lines of Eurogroup decisions of November 27, 2012.

On February 20, 2015, the Eurogroup agreed to a four-month extension of the MFFA underpinning the Second Program. Pursuant to the agreement to extend the MFFA, the Greek government presented a list of reform measure proposals, which were to have been agreed with the Institutions by the end of April 2015. The Second Program, as amended, is referred to in this Annual Report as the Program.

As of the date of this Annual Report, no agreement between Greece and its official lenders has been reached as regards the conditions and the timing of disbursement of remaining EFSF and IMF funds to Greece under the Program and the modalities of the transition from the current arrangement to a new financial arrangement, which is likely to provide contingent financing for covering the Hellenic Republic's financing needs for 2015 and 2016.

The continuing delay in the completion of the pending IMF program review (IMF 6th review) and the non-disbursement of about EUR 7.3 billion of related financing from EU and the IMF that is pending since the second half of 2014, create severe financial challenges for the Hellenic Republic in the first half of 2015. Indeed, the Greek Government faces significant short-term liquidity challenges as long as an agreement with official creditors for the disbursement of remaining Program funding is not reached. These challenges are becoming even more acute as redemptions fall due in July and August 2015 of EUR 6.6 billion of Greek Government bonds held by the ECB and national central banks (Greek PDMA and ECB data) which are not likely to be refinanced by domestic financial resources. This fact, compounded by the additional uncertainty surrounding the potential modalities of Greece's exit process from the Program, have weighted negatively on financial market sentiment since early 2015.

Greek Government bond yields increased substantially in 2015, further exacerbating challenging liquidity conditions. In April 2015, yields of 10 year government bonds reached 12.0% (monthly

average, Bloomberg generic Greek government bond yields), about 612 basis points (or 6.1%) higher than their level in September 2014, effectively returning to the Greek government bond yields last seen in the second quarter of 2012. Yields on shorter maturities, which are more telling of the near term debt servicing challenges, are even higher and in April 2015 the yield of 3-year government bonds (Bloomberg generic yields) reached 24.3% (monthly average) increasing by 20.8% compared to its average level in September 2014 (3.5%). Moreover, Greek banks dependence on the ECB and national central banks increased to above EUR 107.2 billion in March 2015 of which EUR 68.5 billion corresponded to the ELA. The respective figures in September 2014 were EUR 42.6 billion of total ECB and national central banks dependence with only EUR 1.6 billion related to ELA.

For the uncertainty relating to the Hellenic Republic economic crisis and the impact it may have to the Bank, please see Item 3.D, "Risk Factors—Risks Relating to the Hellenic Republic Economic Crisis"—Uncertainty resulting from the Hellenic Republic's economic crisis has had and will continue to have an adverse impact on our business, results of operations and financial condition".

For the other-than-temporary impairment assessment of Greek government bonds and the related accounting treatment, see Item 5 "Operating and Financial Review and Prospects—Critical Accounting Policies, Estimates and Judgments—Other-Than-Temporary-Impairment of Greek Government Bonds".

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 and, to a lesser extent, in SEE-5. During 2014, the global economic recovery continued, albeit there were noticeable growth divergences among major advanced and emerging economies. The recovery in the United States gathered pace, whereas the Eurozone economy returned to positive growth in 2014 following two consecutive years of recession. Economic growth prospects in emerging markets lost momentum, mainly reflecting slower growth in China and a much weaker outlook in Brazil, as well as in Russia. For 2015, we expect the global economy to sustain its growth momentum, expanding by 3.5%, from 3.4% in 2014 (according to International Monetary Fund ("IMF") World Economic Outlook forecasts, April 2015). This expectation may change, given potential political and economic negative developments related to tighter global financial market conditions possibly triggered by sooner and faster-than-expected interest rate increases by the U.S. Federal Reserve ("Fed"), renewed sovereign debt market pressures in the euro area, a sharper-than-expected slowdown of the Chinese economy triggered by a deteriorating housing market and policy efforts to reduce vulnerabilities stemming from excessive credit, as well as increased tensions between Ukraine and Russia, in addition to continued geopolitical risks in the Middle East and West Africa.

Global financial markets conditions continued to improve during 2014 amid elevated volatility in the second half of the year due to global growth concerns, the steep decline in oil prices, as well as increasing geopolitical risks. Developed markets equities—particularly in the US and Japan—recorded decent gains mainly on the back of accommodative monetary policy. Government bond yields declined substantially on both sides of the Atlantic, reflecting the fall in market-based measures of inflation expectations triggered by the collapse in oil prices, as well as increased expectations for the ECB to ease its monetary policy further. Indeed, during 2014, the ECB (in two measured steps) reduced its

main refinancing rate by 20 basis points to 0.05% and cut its deposit rate by 20 basis points to –0.2%. In addition, the ECB announced a series of targeted longer-term refinancing operations ("TLTROs") maturing in September 2018 and launched its asset-backed securities ("ABSPP") and covered bank bonds ("CBPP3") asset purchase programs in the fourth quarter of 2014. In the course of 2015 (as of mid-April 2015), developed markets equities continued to edge higher with euro area equities over performing mostly on the back of the ECB's decision to expand its asset purchase program in order to include euro-denominated sovereign, agency and EU institution bonds. Under this expanded asset purchase program ("APP"), the ECB will purchase, with effect from March 2015, EUR 60 billion bonds per month at least until September 2016. In the United States, the Fed terminated, as expected, its asset purchase program in October 2014, albeit will continue to roll-over (thus maintaining an accommodative stance) maturing Treasuries and agency MBSs at least until the first interest rate increase takes place. Looking forward, the Fed is expected to raise the target range for the federal funds interest rate (current 0.0%-0.25%) when it is reasonably confident that inflation will move back to 2.0% and the U.S. labor market demonstrates further signs of improvement, with market participants expecting an increase of the federal funds interest rate from the zero bound in the second half of 2015.

Turkish operations through Finansbank, our Turkish subsidiary, represented 25.5% of our loans as at December 31, 2014 (compared to 21.8% as at December 31, 2013), accounted for 43.8% of our net interest income before provisions for loan losses and contributed EUR 168 million to our net income for the year ended December 31, 2014 (compared to 48.6% and EUR 682 million respectively for the year ended December 31, 2013).

Our level of non-accruing loans increased from 26.7% of our loans portfolio at December 31, 2013 to 26.8% at December 31, 2014. We have made the necessary allowances for non-accruing loans as at December 31, 2014, as appropriate in accordance with our provisioning policy, and having taken into account any collateral with respect to such loans. The effect of the economic crisis in Greece, the implementation of the Program and adverse macroeconomic conditions in the countries in which we operate may result in adverse effects on the credit quality of our borrowers, with increasing delinquencies, and defaults. Provisions will continue to negatively affect net income / (loss) in 2015. 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, thereby removing the decision-making discretion for loan approval from our branches. We have also established special divisions to monitor and strengthen our position with respect to delinquent commercial and consumer loans by working flexibly with clients (i.e., restructuring payments and taking additional collateral) to help them meet their payment obligations. See Item 4.E, "Selected Statistical Data—Credit Quality—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 adversely affected our credit risk profile, 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, have been effectively closed to all Greek banks since the end of 2009. During 2014, access to financial markets and interbank funding was re-established. However, between December 1, 2014 and April 30, 2015, the uncertainly regarding the financial needs of the Greek government resulted in inter-bank liabilities not being renewed, and in addition has led to significant deposits outflows of EUR 8.3 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 Item 5.B "Liquidity and Capital Resources").

The liquidity we receive from the ECB, or from the Bank of Greece through the ELA, may be affected by changes in ECB and Bank of Greece rules (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 the Bank of Greece for funding, which may be affected by changes in 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 amount of funding available from the ECB or the Bank of Greece is tied to the value of the collateral we provide, including the market value of our holdings of Greek government bonds, which may change. If the value of our assets declines, then the value of the funding we can obtain from the ECB or the ELA will also decline. Furthermore, if the ECB or the Bank of Greece revises their collateral standards such that our collateral securities are not eligible to serve as collateral with the ECB or the Bank of Greece, our funding costs would increase, affecting our net interest income and access to liquidity. For example, in the second half of 2012, the ECB revised its collateral standards, which resulted in our not being able to access ECB funding and being forced to use funding from the ELA, which significantly increased our cost of funding in 2012 due to the higher interest rate of ELA funding compared to ECB funding. The above also had an impact on our cost of funding in 2013, although to a lesser extent, due to the decrease in ELA funding during 2013 and to NIL funding from ELA in 2014.

Furthermore, in February 2015, due to the on-going negotiation between the new Greek government and the Institutions towards reaching a permanent agreement, the ECB lifted the waiver on the eligibility as collateral for ECB funding of the Greek government and government guaranteed bonds, until persuasive positive signs that the new Greek government will reach an agreement with the Institutions. As a consequence, the Bank was forced to reduce its funding from ECB and restart funding from ELA, which as at April 30, 2015 amounted to EUR 9.6 billion and EUR 15.2 billion respectively. This constitutes an increase in Eurosystem exposure compared to the respective figure as at December 31, 2013 (EUR 20.7 billion), caused mainly by the significant outflow of customer deposits since January 1, and up to April 30, 2015 of EUR 6.4 billion and the non-renewal of repurchase agreements with other financial and non-financial institutions. Despite the increase of the Eurosystem exposure, the Bank retains a significant buffer of ELA eligible collateral of EUR 12.7 billion (cash value) as at April 30, 2015, of which currently EUR 12.3 billion can only be used to increase ELA funding conditional on ECB approval.

We engage in both customer deposit gathering and wholesale funding activities to finance our assets. We offer various kinds of retail and corporate deposit products, which in turn represent the majority of our interest expense. The interest expense depends on the size of our customer deposit base relative to our 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 6.4 billion occurred between January 1, and April 30, 2015. 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 to the Greek banks in the future and therefore higher funding cost (see Item 3.D "Risk Factors—An accelerated outflow of funds from customer deposits could cause an increase in our costs of funding and have a material adverse effect on our operating results, financial condition and liquidity prospects").

As at December 31, 2014, the Group's deposits made by Greek residents and foreign customers (excluding interbank deposits) were EUR 64,619 million, an increase of 3.4% compared to December 31, 2013 (EUR 62,502 million). However, as noted above, the Group's deposits in Greece have deteriorated since January 1, 2015.

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, voluntary retirement schemes have been implemented. On December 19, 2013, the Bank announced of the implementation of a 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 OTOE in May 14, 2013 (the Federation of Greek Banks Employees), 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, 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 that 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, up to 24 monthly salaries. In case of dismissal the additional monthly salary is restricted to EUR 2,000.

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".

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.

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 1 July 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.

The applicable Greek statutory corporation income tax rate was 20% for 2011 and 2012 and 26% for 2013 and 2014.

On July 23, 2013 the Greek Parliament approved a tax bill (Greek Law 4172/2013, as changed by Greek Laws 4223/2013 and 4254/2014) that replaced the existing Code of Income Taxation (codified by Greek Law 2238/1994) on January 1, 2014. The certain changes were as follows:

According to the Income Tax Code (Greek Law 4172/2013) any difference (loss) arising from the PSI exchange which is considered deductible for tax purposes is amortized in 30 annual equal installments instead of over the life of the new Greek government bonds.

On November 15, 2014 Greek Law 4307/2014 was enacted and added to article 27 of Greek New Income Tax Code ("ITC") the par 3 under which any difference (loss), due to credit risk arising to the creditors supervised by the Bank of Greece by writing off their debtors' debts under the same law, is deductible from the gross revenues in fifteen equal installments starting from period of the write-off.

On October 17, 2014 Greek Law 4303/2014 was enacted and amended the article 27A of ITC that previously had been introduced by the Greek Law 4302/2014. According to this article deferred tax assets arising in 2016, on temporary differences of a legal entity, will be subject to optional conversion to final and settled claims against Greek Public. See also Item 3.D, "Risk Factors—We may not be allowed to maintain the main part of deferred tax assets recognized for IFRS purposes and hence accepted as regulatory capital".

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 2012, EUR 1 million in 2013 and EUR 18 million in 2014 from disposals of various real estate property holdings. We expect to continue divestitures of non-core assets in the future when circumstances permit.

The preparation of financial statements in accordance with U.S. GAAP requires management to make a number of judgments, estimates and assumptions that affect the reported amount of assets, liabilities, income and expense in our U.S. GAAP Financial Statements and accompanying notes. We believe that the judgments, estimates and assumptions used in the preparation of our U.S. GAAP Financial Statements are appropriate given the factual circumstances as of December 31, 2014.

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.

As at December 31, 2014, NBG's collateralized funding from the ECB amounted to EUR 14.2 billion of which NIL through ELA. This funding was collateralized in part by Greek government and Greek government-guaranteed bonds.

As a result of the on-going negotiations between the new Greek government and the Institutions towards reaching a permanent agreement, the ECB lifted the waiver on the eligibility of these bonds as collateral for ECB funding until persuasive positive signs that the new Greek government will reach an agreement with the Institutions. Consequently, an increased reliance is placed on the Bank of Greece via its ELA facility which is under strict control by the ECB.

The uncertainty regarding the financing needs of the Greek government led for the Bank to significant deposits outflows during December 2014 of EUR 1.9 billion. A further net outflow in the amount of EUR 6.4 billion occurred between January 1 and April 30, 2015. The 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 to the Greek banks in the future.

As a result, although NBG's reliance on Eurosystem funding has decreased from EUR 34.7 billion in the second quarter of 2012, when it reached the highest amount, to EUR 20.7 billion at December 31, 2013 and to EUR 14.2 billion at December 31, 2014, as of April 30, 2015 it has increased again to EUR 24.8 billion, of which EUR 15.2 billion is provided through ELA. Furthermore, as of April 30, 2015, additional financial assets of cash value EUR 12.7 billion were available for further liquidity.

From a capital adequacy perspective, following the two successful share capital increases in 2013 for EUR 9.8 billion and in 2014 for EUR 2.5 billion the Group's Adjusted CET1 ratio at December 31, 2014 was 13.6%, excluding the impact of Greek Law 4303/2014 ("DTC Law"). Moreover, all planned capital actions are expected to further increase the Group's CET1 ratio.

Furthermore, the Bank successfully passed the EU-wide Comprehensive Assessment including an AQR and Stress Test. The Adverse Dynamic Balance Sheet stress test, which is based on the Bank's approved Restructuring Plan resulted in a CET1 ratio of 8.9%, and a capital surplus of EUR 2.0 billion. See Item 4.A, "History and Developments of the NBG Group—EU-wide Comprehensive Assessment". In addition, the Bank's Extraordinary General Meeting held on November 7, 2014 resolved to opt-in for the provisions of the DTC Law, which increases the capital surplus, under this scenario, by a further EUR 0.7 billion.

The access to adequate funds depends to a large extent on to a new agreement to be reached between the Greek government and the Institutions. To this end the Eurogroup decided on February 20, 2015 to extend the MFFA for Greece and the availability of EFSF funds for Greece (albeit transferred from HFSF to EFSF) by four months until June 2015, in order to allow time for an agreement to be negotiated and concluded by the so called "Brussels Group" comprising the above Institutions and representatives of ESM/EFSF.

Going concern conclusion. Management concluded that the Bank is going concern after considering (a) the Bank's capital ratios at December 31, 2014 above the thresholds required (see Note 36 to the U.S. GAAP Financial Statements), (b) its current access to the Eurosystem facilities and (c) the EUR 10.9 billion currently held by the ESM and available to be re-borrowed by the Hellenic Republic for the recapitalization of the Greek banks (if needed).

Nevertheless, as the ability of the Bank of Greece to continue to fund the operations of the Greek banks, including NBG, is limited and conditional on ECB approvals, there is a substantial doubt about the Group's ability to continue as a going concern which depends on whether NBG will be able to continue to access sufficient liquidity through ELA or other bank borrowing facilities and whether the outflow of deposits will continue, that may adversely affect the Group's and the Bank's ability to continue as a going concern.

The resolution of this substantial doubt depends, among other factors, in an agreement between the Greek government and the Institutions, which results, for example, in the re-establishment of the waiver by the ECB to the use of Greek government and government-guaranteed bonds in the Eurosystem more broadly and a solution for the financing needs of the Greek government 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 "Loans and allowance for loan losses", Note 20 "Deposits", Note 25 "Long-term debt" and Note 37 "Fair Value of Financial Instruments" to the U.S. GAAP Financial Statements.

The Group's management exercises judgment in determining the fair value of financial assets and liabilities. For exchange traded financial instruments, fair value is based generally on quoted market prices for the specific instrument. Where no active market exists, or where quoted prices are not otherwise available, we determine fair value using a variety of valuation techniques. These include present value methods, models based on observable input parameters, and models where some of the input parameters are unobservable. The Group considers the impact of both the credit risk of its counterparties, as well as its own creditworthiness in determining fair value of financial instruments, including over-the-counter derivative instruments and financial liabilities designated at fair value in accordance with ASC 825. For over-the-counter derivative instruments, this impact is estimated by calculating a separate CVA for each counterparty, to which the Group has exposure. The calculation considers expected exposures generated using simulation techniques, as well as netting agreements and collateral postings. Furthermore, the CVA is based on expected loss rates derived from CDS rates observed in the market. If these are not available then we apply the regulatory risk weight that corresponds to the internal rating of the counterparty, or to unrated counterparties, if no internal rating is available. With respect to own credit risk, the Group estimates a debit value adjustment ("DVA") by applying a methodology symmetric to the one applied for CVA. The bilateral CVA recognized by the Group at December 31, 2013 and 2014 amounted to a cumulative gain of EUR 30 million and a cumulative gain of EUR 81 million, respectively. The increase is mainly attributed to the increase of the expected negative exposure on derivatives with the Hellenic Republic as a result of the significant decrease of interest rates between December 2014 and December 2013. The Group seeks to reduce counterparty risk by standardizing relationships with counterparties through International Swaps and Derivatives Association, Inc. ("ISDA") and Global Master Repurchase Agreement ("GMRA") contracts, which encompass all necessary netting and margining clauses. Additionally, for almost all active counterparties in over-the-counter transactions, Credit Support Annexes (CSAs) have been put into effect, so that net current exposures are managed through margin accounts on a daily basis, through the exchange of cash collateral. For a further discussion on the management of counterparty credit risk and the effect of a change in interest rates and foreign exchange rates on our portfolio see Item 11, "Quantitative and Qualitative Disclosures about Market Risk", in this document.

Valuation models are used primarily to value debt instruments, for which quoted market prices are not available and derivatives transacted in the over-the-counter market. The fair value for such instruments is estimated using discounted cash flow analysis based on contractual cash flows discounted at the corresponding market rates, quoted prices for instruments with similar characteristics or other pricing models. All valuation models are validated before they are used as a basis for financial reporting, and periodically reviewed thereafter by qualified personnel independent of the area that created the model. Wherever possible, we compare valuations derived from models with quoted prices of similar financial instruments, and with actual values when realized, in order to further validate and calibrate our models. A variety of factors are incorporated into our models, including actual or estimated market prices and rates, time value and volatility, and market depth and liquidity.

We apply our models consistently from one period to the next, ensuring comparability and continuity of valuations over time, but estimating fair value inherently involves a significant degree of judgment. Management therefore establishes valuation adjustments to cover the risks associated with the estimation of unobservable input parameters and the assumptions within the models themselves.

Financial assets and liabilities whose values are based on prices or valuation techniques that require inputs that are both unobservable and are significant to the overall fair value measurement are classified as Level 3 under the fair value hierarchy established in ASC 820 "Fair Value Measurements and Disclosures". Inputs to valuation models are considered unobservable if they are supported by little or no market activity. In periods of extreme volatility, lessened liquidity or in illiquid markets, there may be more variability in market pricing or a lack of market data to use in the valuation process. An illiquid market is one in which little or no observable activity has occurred or one that lacks willing buyers or willing sellers.

As of December 31, 2014, Level 3 assets amounted to EUR 356 million, which included EUR 15 million in trading assets, EUR 28 million in derivative assets and EUR 260 million in AFS securities, EUR 42 million in Loans at FVTPL and EUR 11 million in other assets. Level 3 assets represent 2.5% of assets measured at fair value (or 0.3% of total assets). As of December 31, 2014 Level 3 liabilities amounted to EUR 5 million, which included EUR 5 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, 2014 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, 2014.

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.

Recognition and measurement of intangibles recognized upon business combinations

We account for acquired businesses using the purchase method of accounting which requires that the assets acquired and liabilities assumed be recorded at the date of acquisition at their respective fair values.

The application of the purchase method requires certain estimates and assumptions especially concerning the determination of the fair values of the acquired intangible assets and property, plant and equipment as well as the liabilities assumed at the date of the acquisition. Moreover the useful lives of the acquired intangible assets, property, plant and equipment have to be determined. The judgments made in the context of the purchase price allocation can materially impact our future results of operations. Accordingly, for significant acquisitions, we have obtained assistance from third party valuation specialists. The valuations are based on information available at the acquisition date.

Significant judgments and assumptions made regarding the purchase price allocations in the course of the acquisitions of Finansbank and Vojvodjanska include the following:

For the valuation of core deposits, the alternative source of funds method was applied. The value of Core Deposit Intangibles ("CDI") is measured by the present value of the difference, or spread, between the CDI's ongoing cost and the cost of a market alternative replacement. Acquired core deposit accounts typically provide a low-cost source of funds to the buyer. To replace these established, low-cost deposit accounts in a timely manner, any potential buyer's alternative would be to utilize higher-cost funds at current market rates. The valuation results were also subject to sensitivity analysis.

For the valuation of customer relationships, the multi-period excess of earnings method was applied. Excess earnings can be defined as the difference between the net operating profit attributable to the existing customers at the acquisition date and the required cost of invested capital on all the other assets (contributory assets such as fixed assets, CDI, trade name, assembled workforce and software) used in order to deliver a product or maintain the customer relationship. Value is estimated through the sum of the discounted future excess earnings attributable to these customers over the remaining life span of the customer relationship. The valuation results were also subject to sensitivity analysis.

For the valuation of brands, the relief-from-royalty method was applied which is based on hypothetical royalty income attributable to an asset. In particular, it estimates the expected annual royalty cost savings that result from the company's ownership of trademarks and licenses on which it does not have to pay royalties to a licensor. The intangible asset is then recognized at the present value of these savings. The valuation results were also subject to sensitivity analysis. The corporate brands used by Finansbank and Vojvodjanska were assessed to have an indefinite life based on their qualitative characteristics (history, strength, market awareness, etc.), as well as the circumstances of the trade name in relation to the specific acquisition.

For the valuation of software, the cost approach method was applied. The cost approach is based upon the economic principles of substitution and price equilibrium. The cost approach suggests that a prudent investor would not pay, for an intangible, more than the cost to acquire a comparable intangible on the market. Software intangibles were valued using the reproduction cost methodology, which is based on the assumption that the value of any intangible asset is the cost incurred to reconstruct or purchase an exact replica of the given intangible asset.

Under applicable accounting guidance, goodwill is reviewed at the reporting unit level for potential impairment 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 employs a capital asset pricing model in estimating the discount rate (i.e., cost of equity financing) for each reporting unit. The inputs to this model include: risk-free rate of return; beta, a measure of the level of non-diversifiable risk associated with comparable companies for each specific reporting unit; market equity risk premium; and in certain cases an unsystematic (company-specific) risk factor. The unsystematic risk factor is the input that specifically addresses uncertainty related to our projections of earnings and growth, including the uncertainty related to loss expectations. We use our internal forecasts to estimate future cash flows and actual results may differ from forecasted results. Cash flows were discounted using a discount rate based on expected equity return rates. We utilized discount rates that we believe adequately reflected the risk and uncertainty in the financial markets generally and specifically in our internally developed forecasts. Expected rates of equity returns were estimated based on historical market returns and risk/return rates for similar industries and geographies of the reporting unit. For purposes of the market approach, valuations of reporting units were based on actual comparable market transactions and market earnings multiples for similar industries and geographies of the reporting unit. Determination of fair value requires management to make assumptions and use estimates. We believe that the assumptions and estimates used are reasonable and supportable in the existing market environment and commensurate with the risk profile of the assets valued. However, different ones could be used which would lead to different results.

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 is allocated is the Turkish banking operations. The goodwill relates to the acquisition of Finansbank.

Goodwill 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 units was estimated using the income approach and in particular the Dividend Discount Model ("DDM") because (a) the reporting units consist of subsidiaries of the Group, and therefore their operations are directed by the Group, (b) the DDM incorporates the earnings variability associated with the restructuring of these subsidiaries operations following their acquisition, and (c) the DDM incorporates management's views of the near and medium term as well as detailed views of current and near future market conditions and strategy.

The DDM is based on management's forecasts, long-term growth rates based on the respective country GDP rates adjusted for inflation and discount rates based on observable market long term government bond yields and average industry betas.

Underlying assumptions to the valuation models are: that the entities comprising these reporting units will remain subsidiaries of the Group, that the general macroeconomic and political conditions in the respective markets will remain stable, that economic activity will continue to grow in the medium term and that the reporting units will continue to be able to fund their operations. If any of these conditions changes in the future, it may reduce the value of the reporting units and cause an impairment charge with respect to goodwill. The estimated cash flows were updated to reflect the current management estimates and market conditions.

For the Turkish banking operations reporting unit the DDM was based on a 6.2% (2013: 5.5%) terminal growth rate and 16.6% (2013: 18.6%) 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, 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 approximately EUR 0.2 billion (2013: EUR 0.2 billion) and EUR 0.2 billion (2013: EUR 0.4 billion) respectively. In addition, a 5% decrease in the forecast amounts available for dividends would decrease the fair value by approximately EUR 0.2 billion (2013: EUR 0.2 billion).

In 2014 we recognized an additional EUR 58 million (2013: EUR 9 million) impairment charges in relation to the private equity business of the Group.

In 2013 the Group recognized a goodwill impairment charge of EUR 9 million relating to the private equity business. In 2012 the Group recognized impairment losses of EUR 123 million for goodwill relating to the Serbian operations (EUR 103 million), and to the private equity business of the Group (EUR 20 million).

Further details on this subject are given in Note 3 and Note 14 to the U.S. GAAP Financial Statements.

The amount of the allowance set aside for loan losses is based upon management's ongoing assessments of the probable estimated losses inherent in the loan portfolio. Assessments are conducted by members of management responsible for various types of loans employing a methodology and guidelines that are continually monitored and improved. We assess whether objective evidence of impairment exists for all loans that are individually significant (i.e., specific allowances), and collectively for loans that are not considered individually significant (i.e. coefficient and homogeneous analysis).

Individually significant loans are subject to an impairment test when interest and/or capital is in arrears for a certain period and/or qualitative indications exist, at the assessment date, which demonstrate that the borrower will not be able to meet its obligations. Usually such indications include, but are not restricted to, significant financial difficulty, deterioration of credit rating and the probability of bankruptcy, renegotiation or other financial reorganization procedures. A specific impairment loss is recognized for loans evaluated individually for impairment and is based upon management's best estimate of the present value of the cash flows which are expected to be received. In estimating these cash flows, management makes judgments about the counterparty's financial situation and the net realizable value of any underlying collateral or guarantees in our favor. Each impaired loan is assessed

on its merits, and the workout strategy and estimate of cash flows considered recoverable are independently reviewed.

In assessing the need for collective loan loss allowances, management considers factors such as credit quality, portfolio size, concentrations and economic factors. In order to estimate the required allowance, we make assumptions both to define the way we model inherent losses and to determine the required input parameters, based on historical experience and current economic conditions. Allowances for loan losses made by our foreign subsidiaries are estimated by the subsidiary using similar criteria as the Bank uses in Greece.

The accuracy of the allowances and provisions we make depends on how well we estimate future cash flows for specific counterparty allowances and provisions and the model assumptions and parameters used in determining collective allowances. While this necessarily involves judgment, we believe that our allowances and provisions are reasonable and supportable. As the process for determining the adequacy of the allowance requires subjective and complex judgment by management about the effect of matters that are inherently uncertain, subsequent evaluations of the loan portfolio, in light of the factors then prevailing, may result in changes in the allowance for loan losses. The methodology for each component, the estimates and judgments are described in further detail in Item 4.E, "Selected Statistical Data—Credit Quality—Allowance for Loan Losses—Methodology".

Insurance reserves for our 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 2.2 billion in 2014 compared to EUR 2.5 billion in 2013 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 2014 net periodic pension cost was 3.6% compared to 3.2% for

2013. The rate of compensation increases decreased from 2.4% in 2013 to 2.1% in 2014. The discount rate increased from 3.6% in 2013 to 3.9% in 2014. The change in assumptions and the difference between actual outcomes and assumptions resulted in a net actuarial losses of EUR 60 million in 2014. 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.

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.

At December 31, 2014 the Greek government bonds held by the Group in the available-for-sale investment securities were in an unrealized loss position, based on quoted market prices of these bonds. The unrealized losses of EUR 111 million representing 13.9% of the amortized cost basis, was recognized in other comprehensive income.

The Group has conducted an assessment of whether the decline in fair value below amortized cost is an other-than-temporary impairment. The Group did not recognize any OTTI because it 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, and that, 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.

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 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), 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.

With respect to debt securities issued by other governments and public sector entities the unrealized losses over one year of EUR 11 million relate to debt securities issued by the Republic of Turkey, held by our subsidiary in Turkey, Finansbank. We consider that the Republic of Turkey 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.

In 2014 the Group recognized EUR 1 million OTTI charges in relation to corporate debt securities for which the Group considered that a credit loss existed with respect to such securities, due to the financial difficulties faced by the issuers.

With respect to corporate securities issued by companies incorporated in Greece, the unrealized losses outstanding for 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 all three Greek financial institutions during 2014.

With respect to corporate securities issued by companies incorporated outside Greece the loss outstanding for over one year of EUR 11 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, 2014.

During 2014, the Group recognized an OTTI charge of EUR 5 million in relation to its equity securities held with significant and prolonged unrealized losses.

As at December 31, 2014, the Group had unrealized losses in AFS equity and debt instruments of EUR 8 million and EUR 54 million, respectively. There were no unrecognized losses in HTM debt instruments.

Where cash flows related to an investment are readily determinable, a low level of judgment may be involved. However, where determination of estimated future cash flows requires consideration of a number of variables, some of which may be unobservable, more significant judgment is required. The most significant judgment applied by management relates to OTTI for certain debt securities issued by Greek financial institutions. No OTTI has been recognized for these positions based on management's assessment that the Group neither has the intention to sell nor expects it will be required to sell these securities before the recovery of their respective amortized cost bases, and that the issuers' payment obligations associated with these positions will be met on time and the full amount will be recovered. A key factor considered in this assessment was the successful completion of the share capital increases of the Greek banks that significantly improved the capital position of the Greek banks.

It is reasonably possible that outcomes in the next financial year could be different from the assumptions and estimates used in identifying OTTI. The recognition of OTTI charges would reduce the net income for the year by the amount disclosed above.

We are subject to income taxes in various jurisdictions. Significant judgment is required in determining the Group-wide provision for income taxes. We consider many factors including statutory, judicial and regulatory guidance in estimating the appropriate accrued income taxes for each jurisdiction. There are many transactions and calculations for which the ultimate tax determination is uncertain during the ordinary course of business. We recognize liabilities for anticipated tax audit issues based on estimates of whether additional taxes will be due. Where the final tax outcome of these matters is different from the amounts that were initially recorded, such differences will impact the current and deferred income tax assets and liabilities in the period in which the final outcome is determined.

Realization of deferred tax assets is dependent on generating sufficient taxable income. Although realization is not assured, the Group believes that the realization of the net deferred tax assets after valuating allowance of EUR 194 million at December 31, 2014 (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 and 2014 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 5 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, 2014 Management concluded that due to the existence of history of tax losses it is more appropriate to recognize a valuation allowance of EUR 6,003 million until the Bank returns to profitability.

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 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 continuing challenging economic conditions and the losses on derivatives. Turkish operations, despite the adverse effect from the depreciation of the local currency, continued to support the Group's profitability though to a lesser extent than in previous years. More specifically, in 2014 Turkish operations contributed EUR 168 million of net income to the Group, compared to EUR 682 million in 2013. The lower contribution is mainly attributed to losses on derivatives due to the gradual decline in Turkish interest rates over 2014.

Net Interest Income before provision for loan losses. Net interest income before provision for loan losses for 2014 was EUR 2,830 million, a decrease of 3.9% compared to EUR 2,944 million in 2013.

However, net interest margin remained stable at 3.2% 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		4,545			4,303			(5.3	)
Securities available for sale		364			357			(1.9	)
Securities held-to-maturity		88			195			121.6
Trading assets		124			66			(46.8	)
Securities purchased under agreements to resell		6			16			166.7
Interest-bearing deposits with banks		19			13			(31.6	)
Other		31			22			(29.0	)

Total interest income		5,177			4,972			(4.0	)

Interest Expense:
Deposits		(2,004	)		(1,773	)		(11.5	)
Securities sold under agreements to repurchase		(58	)		(97	)		67.2
Other borrowed funds		(105	)		(88	)		(16.2	)
Long-term debt		(55	)		(128	)		132.7
Other		(11	)		(56	)		409.1

Total interest expense		(2,233	)		(2,142	)		(4.1	)

Net interest income before provision for loan losses		2,944			2,830			(3.9	)
Provision for loan losses		(969	)		(2,172	)		124.1

Net interest income after provision for loan losses		1,975			658			(66.7	)

Our total interest income decreased by 4.0% to EUR 4,972 million for 2014, from EUR 5,177 million for 2013. Group interest income from loans in 2014 showed a decrease of 5.2% compared with 2013, reflecting mainly the reduction in the borrowed 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 4.1% to EUR 2,142 million for 2014, from EUR 2,233 million for 2013, mainly due to the decrease of the reliance on the Eurosystem funding through ELA as compared to ECB funding and due to the lower deposit yields. Interest expense on deposits decreased by 11.5% for 2014 compared with 2013.This is mainly attributed to the significant outflow of customer deposits and the lower rates paid to interest bearing deposits in 2014 compared with 2013, as a result of the continued repricing of domestic deposits throughout the year. Total deposits decreased to EUR 81.5 billion as at December 31, 2014, from EUR 85.6 billion as at December 31, 2013. This fluctuation was a result of the reduction in interbank balances, which decreased from EUR 23.1 billion in 2013 to EUR 16.9 billion in 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, as at December 31, 2014, interbank deposits represented 20.7% of the total deposits compared to 27.0% as December 31, 2013.

Our provision for loan losses charged to the income statement increased from EUR 969 million as at December 31, 2013 to EUR 2,172 million as at December 31, 2014 or an increase of 124.1%. 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 provision for foreign loans losses charged to the income statement amounted to EUR 476 million as at December 31, 2014 compared to EUR 428 million as at December 31, 2013. The increase is mainly attributable to the worse than anticipated trend in the Greek economy and the increased financial uncertainty affecting the domestic portfolio.

Total impaired loans as at December 31, 2014 amounted to EUR 22,629 million, an increase of EUR 497 million from EUR 22,132 million at December 31, 2013. Domestic impaired loans amounted to EUR 18,661 million and foreign impaired loans amounted to EUR 3,968 million, increasing by 6.2% and decreasing by 12.9% 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 140 million to EUR 7,311 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% is due 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 3,439 million, decreased by EUR 242 million or 6.6% compared to December 31, 2013.

Foreign impaired loans as at December 31, 2014 amounted to EUR 3,968 million, decreased by EUR 589 million or 12.9% compared to December 31, 2013.

Total write-offs as at December 31, 2014 amounted to EUR 189 million, a decrease of EUR 60 million compared to 2013. Domestic write-offs as at December 31, 2014 amounted to EUR 107 million and foreign write-offs amounted to EUR 82 million, a decrease of 22.5% and a decrease of 26.1% respectively, from the same period in 2013.

Total allowance for loan losses (impaired and non-impaired loans) at December 31, 2014, amounted to EUR 9,492 million, an increase of EUR 1,741 million, or 22.5% 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 1,584 million respectively, an increase of 24.9% and 6.6% respectively, compared to December 31, 2013.

The allowance for loan losses as a percentage of total loans increased from 10.6% as at December 31, 2013, to 12.6% 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 40.8%, higher by 641 basis points from the ratio of 34.4% at December 31, 2013. In the domestic portfolio, the impaired coverage ratio increased by 613 basis points from 34.9% at December 31, 2013 to 41.0% at December 31, 2014. This increase is due to the the increased balance of impaired and non-accruing loans and the higher loss rates 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 46.1%, higher by 717 basis points from the ratio of 38.9% at December 31, 2013.

The impaired coverage ratio for the foreign portfolio at December 31, 2014, decreased by 731 basis points since December 31, 2013, and the non-accruing coverage ratio for the foreign portfolio decreased by 569 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.

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, therefore keeping only the secured balance on balance sheet, or in total.

Non-interest Income. Non-interest income in 2014 was EUR 213 million, compared to EUR 1,874 million for 2013. The following table summarizes the principal components of non-interest income during each of the two years ended December 31, 2013 and 2014:

Our net trading gains/(losses) consist of valuation losses in our bond portfolio and derivative positions. Net trading losses increased to EUR (1,365) million in 2014 from gains of EUR 297 million in 2013. This decrease is mostly attributed to the decline of interest rates in 2014 as compared to 2013. 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 1 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. However, the downward trend in the income from insurance operations has nearly halted, showing signs of an eminent recovery.

Non-interest Expense. Non-interest expense in 2014 was EUR 3,230 million, decreased by 10.6% compared with EUR 3,613 million for 2013.

Salaries, employee benefits and voluntary early retirement schemes decreased by 23.2% and amounted to EUR 1,166 million in 2014 from EUR 1,518 million in 2013. This decrease is mainly attributed to the solid results of the broad voluntary retirement scheme that took place 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 loss before income tax of EUR 2,359 million compared to income before income tax of EUR 236 million in 2013.

Income Tax Expense. In 2014, we recognized a current tax expense of EUR 85 million and a deferred tax expense of EUR 29 million compared to a current tax expense of EUR 133 million and a deferred tax benefit of EUR 34 million in 2013. Our total tax expense in 2014 amounted to EUR 114 million compared to EUR 167 million in 2013. The applicable Greek statutory corporation income tax rate for 2014 and 2013 was 26%.

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. The Group is an active participant in the foreign exchange markets and also grants loans denominated in currencies other than the euro. The Group's goal in managing exchange rate exposure is to minimize the effect of exchange rate fluctuations on profitability. The Group adheres to central Bank guidelines and other guidelines applicable to the Group and actively manages its foreign currency position. To the extent that foreign currency denominated assets are not matched with liabilities denominated in the same currencies, the Group engages in swaps and other economic hedging transactions in order to reduce the effects of these imbalances. Furthermore, through Finansbank's operations in Turkey, the Group's exposure to TRY has increased. The Group closely monitors its exposure to the TRY arising from the net investment in Finansbank and when necessary it engages in swap and other economic hedging transactions in order to reduce the volatility in the

Group's equity arising on the translation of Finansbank's net assets from TRY to Euro. As at December 31, 2014, 26.9% of the Group's liabilities and 31.6% of the Group's assets were denominated in currencies other than euro, before taking into account economic hedging transactions. For more information on foreign exchange risk see Item 11, "Quantitative and Qualitative Disclosures About Market Risk".

Results of Operations for the year ended December 31, 2013 compared with the year ended December 31, 2012

Overview. In 2013, the Group reported a net income attributable to NBG shareholders of EUR 37 million compared to a net loss attributable to NBG shareholders of EUR 2,537 million in 2012. Our net income for the year ended December 31, 2013 is mainly attributed to the decrease in provision for loan losses, unlike 2012 where the deterioration in the quality of the domestic loan portfolio as a result of the intense political uncertainty as well as the continuing volatile condition of the economy of the SEE countries led to a high level of provision for loan losses. Turkish operations, despite the adverse effect from the depreciation of the local currency, continued to support the Group's profitability. More specifically, in 2013 Turkish operations contributed EUR 682 million of net income to the Group, compared to EUR 632 million in 2012.

Net Interest Income before provision for loan losses. Net interest income before provision for loan losses for 2013 was EUR 2,944 million, a decrease of 8.0% compared to EUR 3,200 million in 2012. Net interest margin was at 3.2% in 2013 compared to 3.4% in 2012. This generally reflects the pressure from competition in domestic deposit gathering and the higher rates paid for wholesale funding. The components of our net interest income after provision for loan losses for 2012 and 2013 are reflected in the following table:

	Year ended December 31,

	Year ended December 31,						2012/2013 Change
	2012			2013			2012/2013 Change
	(EUR in millions)						(%)
Interest Income:
Loans		4,966			4,545			(8.5	)
Securities available for sale		650			364			(44.0	)
Securities held-to-maturity		58			88			51.7
Trading assets		184			124			(32.6	)
Securities purchased under agreements to resell		19			6			(68.4	)
Interest-bearing deposits with banks		30			19			(36.7	)
Other		27			31			14.8

Total interest income		5,934			5,177			(12.8	)

Interest Expense:
Deposits		(2,517	)		(2,004	)		(20.4	)
Securities sold under agreements to repurchase		(60	)		(58	)		(3.3	)
Other borrowed funds		(71	)		(105	)		47.9
Long-term debt		(81	)		(55	)		(32.1	)
Other		(5	)		(11	)		175.0

Total interest expense		(2,734	)		(2,233	)		(18.3	)

Net interest income before provision for loan losses		3,200			2,944			(8.0	)
Provision for loan losses		(2,322	)		(969	)		(58.3	)

Net interest income/(loss) after provision for loan losses		878			1,975			124.9

Our total interest income decreased by 12.8% to EUR 5,177 million for 2013, from EUR 5,934 million for 2012. Group interest income from loans in 2013 showed a decrease of 8.5% compared with 2012, reflecting mainly the decrease in the balance of the Group's Loans before allowance for loan losses of EUR 1.1 billion as a result of the deleveraging strategy and the adverse effect of the sharp reduction in the borrowed rates linked to Euribor, despite the repricing efforts that continued in 2013. 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.

Total interest expense decreased by 18.3% to EUR 2,233 million for 2013, from EUR 2,734 million for 2012, mainly due to the decrease of the reliance on the Eurosystem funding through ELA as compared to ECB. Interest expense on deposits decreased by 20.4% for 2013 compared with 2012. This is due to the lower rates paid to interest bearing deposits in 2013 compared with 2012. In 2012, there was increased domestic market competition following the liquidity shortage in the domestic market. Total deposits decreased to EUR 85.6 billion as at December 31, 2013, from EUR 91.2 billion as at December 31, 2012. This fluctuation resulted in part due to the reduction in interbank balances, which decreased from EUR 32.6 billion in 2012 to EUR 23.1 billion in 2013. The balances include the Eurosystem funding which amounted to EUR 30.9 billion and EUR 20.7 billion in 2012 and 2013 respectively. Indicatively, as at December 31, 2013, interbank deposits represented 27.0% of the total deposits compared to 35.8% as December 31, 2012.

The Group's net interest margin is dependent on disciplined deposit pricing and asset repricing efforts. In the domestic market, retail deposits and more specifically savings deposits which are considered as a cheap funding source became less available for the Bank given the prevailing adverse economic conditions. This negatively affected net interest margin along with the contribution of costly time deposits in our total deposit mix. However, there was a positive effect from the decreased reliance on funding from the ELA facility (NIL as at December 31, 2013 compared to EUR 30.9 billion as at December 31, 2012), which has a higher cost almost similar to a time deposit.

On the other hand, increased loans spreads charged to retail and corporate lending customers reflecting the scarcity of funds and heightened credit risk compensated for the margin compression on the liability side. Furthermore, our net interest margin is also dependent on the increased weight the foreign activities have over the reducing domestic balance sheet. Lastly, the increase of non accruing balances continued to have a negative impact on our net interest margin during 2013.

Our provision for loan losses charged to the income statement decreased from EUR 2,322 million as at December 31, 2012, to EUR 969 million as at December 31, 2013, or a decrease of 58.3%. Excluding the reversal of provision for loan losses relating to the loan to the Hellenic Republic, amounting to EUR 415 million, the decrease in our provision for loan losses charged to the income statement was 40.0%. As at December 31, 2013, the probability of default of the Hellenic Republic had significantly declined and therefore did not qualify as an impairment trigger. Consequently, the Group reversed the allowance for loan losses relating to the Hellenic Republic where deemed appropriate and reclassified those respective balances to non impaired. The domestic provision for loan losses charged to the income statement amounted to EUR 541 million in 2013 compared to EUR 1,844 million in 2012, or a decrease of 70.7%. Excluding the provision for loan losses relating to the loan to the Hellenic Republic the domestic provision for loan losses decreased by 47.8%. The provision for foreign loan losses charged to the income statement amounted to EUR 428 million as at December 31, 2013 compared to EUR 478 million as at December 31, 2012. The decrease is mainly attributable to the improvement of the asset quality of the foreign portfolio.

Total impaired loans as at December 31, 2013 amounted to EUR 22,132 million, a decrease of EUR 1,192 million from EUR 23,324 million as at December 31, 2012. Domestic impaired loans

amounted to EUR 17,575 million and foreign impaired loans amounted to EUR 4,557 million, decreasing by 10.0% and increasing by 20.3% respectively since December 31, 2012. Excluding the effect of the loan to the Hellenic Republic which at December 31, 2012 amounts EUR 5,040 million and is no longer impaired, total impaired loans increased by 21.0% and Domestic impaired loans by 21.2% during 2013 (see Note 13 to the U.S. GAAP Financial Statements).

Domestic impaired loans, excluding the loans to the Hellenic Republic that were reclassified as non impaired, and non accruing loans, increased as at December 31, 2013, as a consequence of the economic downturn in the Hellenic Republic, which continued through 2013. However, domestic non accruing new inflows showed a slowing annual pace. (see also, Item 4.B, "Business Overview—The Hellenic Republic's Economic Crisis, Second Economic Adjustment Program for Greece and Recent Macroeconomic Developments")

Domestic impaired loans for the year ended December 31, 2013, decreased from EUR 19,537 million as at December 31, 2012 to EUR 17,575 million as at December 31, 2013, or 10.0%. The residential mortgages portfolio of our domestic portfolio deteriorated significantly in 2013, with impaired balances increasing by EUR 1,768 million to EUR 7,171 million as at December 31, 2013 compared to EUR 5,403 million as at December 31, 2012, mainly due to the substantial impact of the recession on the debt servicing and the increase in loan modifications which qualified as TDRs, amounting to EUR 1,737 million in 2013. Domestic other commercial impaired loans amounted to EUR 4,071 million as at December 31, 2013.

The increase in non accruing domestic loans as at December 31, 2013, by EUR 3,161 million from EUR 12,731 million as at December 31, 2012 to EUR 15,892 million as at December 31, 2013 or 24.8% is due to the deterioration of the quality of our portfolio. Foreign non accruing loans as at December 31, 2013, amounted to EUR 3,681 million, increased by EUR 486 million or 15.2% compared to December 31, 2012.

Foreign impaired loans as at December 31, 2013, amounted to EUR 4,557 million, increased by EUR 770 million or 20.3% compared to December 31, 2012, mainly due to the continuing volatile economic conditions prevailing, since 2009, in the SEE 5 countries in which we operate. The continued unfavorable economic environment directly affected the ability of retail and corporate borrowers to repay loans.

Total write offs as at December 31, 2013, amounted to EUR 249 million, an increase of EUR 28 million compared to 2012. Domestic write offs as at December 31, 2013, amounted to EUR 138 million and foreign write offs amounted to EUR 111 million, an increase of 9.5% and an increase of 18.1% respectively, from the same period in 2012.

Total allowance for loan losses (impaired and non impaired loans) at December 31, 2013, amounted to EUR 7,751 million, an increase of EUR 433 million, or 5.9% compared to December 31, 2012. As at December 31, 2013, allowance for impaired domestic and foreign loans losses amounted to EUR 6,127 million and EUR 1,486 million respectively, an increase of 7.8% and 0.7% respectively, compared to December 31, 2012.

The allowance for loan losses as a percentage of total loans increased from 9.8% as of December 31, 2012, to 10.6% as of December 31, 2013. The above stated 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, 2013, was 34.4%, higher by 371 basis points from the ratio of 30.7% at December 31, 2012. In the domestic portfolio, the impaired coverage ratio increased by 578 basis points from 29.1% at December 31, 2012 to 34.9% at December 31, 2013. This increase is due to the higher loss rates 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, 2013, was 38.9%, lower by 605 basis points from the ratio of 44.9% at December 31, 2012.

The impaired coverage ratio for the foreign portfolio at December 31, 2013, has decreased to 32.6% from 39.0% at December 31, 2012 or by 637 basis points, and the non accruing coverage ratio for the foreign portfolio to 40.4% from 46.2% at December 31, 2012 or by 584 basis points as a result of the sale of non accruing and impaired loans in Turkey, which were provided for at 100%.

All components of our loan allowances for loan losses, except specific allowance, have increased during 2013.

The most significant increase is noted within the homogeneous allowance, which increased from EUR 3,589 million as at December 31, 2012 to EUR 4,159 million as at December 31, 2013. This is in line with the increase of our retail non accruing loans during the same period.

Specific allowances decreased during 2013 from EUR 1,973 million as at December 31, 2012, to EUR 1,808 million as at December 31, 2013. Excluding the provision for loan losses relating to the loan to the Hellenic Republic, specific allowances increased by EUR 250 million or by 16.0% during 2013. Specific allowances mainly include corporate loans, as well as SBLs to a lesser extent. This decrease is mainly attributable to the reversal of provision for loan losses relating to the loan to the Hellenic Republic that amounted to EUR 415 million.

Coefficient allowances increased from EUR 235 million as at December 31, 2012, to EUR 242 million as at December 31, 2013, reflecting both the increase of customers provided for using this methodology (i.e. corporate loans with a balance of less than EUR 750 thousand, see Note 3, to the U.S. GAAP Financial Statements) as well as a slight downgrading of customers to a credit rating requiring higher loan loss allowances.

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, therefore keeping only the secured balance on balance sheet, or in total.

Non-interest Income. Non-interest income in 2013 was EUR 1,874 million, compared to EUR 286 million for 2012. The following table summarizes the principal components of non interest income during each of the two years ended December 31, 2012 and 2013:

Our net trading gains/(losses) consist of valuation losses in our bond portfolio and derivative positions. Net trading gains increased to EUR 297 million in 2013 from losses of EUR 1,366 million in 2012. Other Than Temporary Impairment in 2013 showed a loss of EUR 285 million positively affected by the write back of provisions against claims on the Hellenic Republic following the improved spreads on Greek government bonds, while in 2012 the Group showed losses of EUR 411 million due the additional impairment with respect to the loans exchanged through PSI (see Note 11 to the U.S. GAAP Financial Statements). The decrease in income from insurance operations reflects the decrease in new policies written in the life insurance single premium bancassurance business, as a result of the lower savings rate caused by the austerity measures and the decrease in the production of the motor business, as a result of both the financial crisis and the streamlining of the motor policy portfolio.

Non-interest Expense. Non-interest expense in 2013 was EUR 3,613 million, increased by 2.8% compared with EUR 3,513 million for 2012.

Salaries, employee benefits and voluntary early retirement schemes increased by 10.1% and amounted to EUR 1,518 million in 2013 from EUR 1,380 million in 2012. This increase is mainly due to the cost of the broad voluntary retirement scheme that took place in Greece during December 2013, in which more than 2,500 employees participated, and is expected to deliver a substantial benefit on an annual basis in future years. Other than the above, the personnel expense line reflects the effect of the Group's cost cutting measures. Occupancy and equipment expense decreased by 13.4% in 2013 compared with 2012, due to the ongoing initiatives to reduce non interest expenses such as rentals in Greece. Efforts to cut back on operating costs continued in SEE 5 as well, while the increase in non interest expense in Turkey, remained moderate and was commensurated with the rate of inflation and the expansion of the branch network.

Impairment of goodwill amounted to EUR 9 million in 2013, compared to EUR 123 million in 2012. In 2013 we recognized an impairment of EUR 9 million in relation to our private equity business, while in 2012, we recognized an impairment of EUR 103 million in relation to Vojvodjanska Banka in our SEE 5 banking operations and EUR 20 million in relation to our private equity business.

Insurance claims, reserves movement, commissions and reinsurance premium ceded increased by 13.0% in 2013, compared to 2012, primarily due to the increase in insurance reserves caused by the decrease in interest rate levels.

Income/(Loss) Before Income Tax. As a result of the above, in 2013, the Group reported income before income tax of EUR 236 million compared to losses before income tax of EUR 2,348 million in 2012.

Income Tax Expense. In 2013, we recognized a current tax expense of EUR 133 million and a deferred tax expense of EUR 34 million compared to a current tax expense of EUR 205 million and a deferred tax benefit of EUR 36 million in 2012. Our total tax expense in 2013 amounted to EUR 167 million compared to EUR 169 million in 2012. The applicable Greek statutory corporation income tax rate for 2013 and for 2012 was 26% and 20% respectively.

Net Income/Loss Attributable to NBG Shareholders. For the reasons discussed above, net income attributable to NBG shareholders was EUR 37 million for 2013, compared to net losses attributable to NBG shareholders of EUR 2,537 million for 2012

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), the Bank established a SAU, which has the overall responsibility for the management of EUR 5.7 billion loans to legal entities (end-to-end responsibility).

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 and an associate in Turkey.

The Group's international banking activities, other than its Turkish operations, include a wide range of traditional commercial banking services, such as commercial and retail credit, trade financing, foreign exchange and taking of deposits. In addition, the Group offers shipping finance, investment banking and brokerage services through certain of its foreign branches and subsidiaries.

The Group's banking activities in Turkey through Finansbank and its subsidiaries, include a wide range of traditional commercial banking services, such as commercial and retail credit, trade financing, foreign exchange and taking of deposits.

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, 2014	Retail Banking

	(EUR in millions)
Net interest income		573		743		189		55		315		1,139		115		3,129
Net fee and commission income		72		98		(125	)	5		93		393		(5	)	531
Other		23		(63	)	(106	)	103		14		(24	)	(43	)	(96	)

Total operating income		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, 2014
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

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
Deferred tax assets and Current income tax advance																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

12-month period ended December 31, 2012	Retail Banking

	(EUR in millions)
Net interest income		940		745		(106	)	71		312		1,265		138		3,365
Net fee and commission income / (loss)		88		85		(177	)	6		90		400		3		495
Other		(9	)	(49	)	(469	)	156		17		169		(148	)	(333	)

Total operating income / (loss)		1,019		781		(752	)	233		419		1,834		(7	)	3,527

Direct costs		(615	)	(51	)	(59	)	(116	)	(272	)	(748	)	(20	)	(1,881	)
Allocated costs and provisions		(1,736	)	(654	)	(247	)	(31	)	(258	)	(286	)	(409	)	(3,621	)
Share of profit of equity method investments		—		—		—		—		—		2		—		2

Profit / (loss) before tax		(1,332	)	76		(1,058	)	86		(111	)	802		(436	)	(1,973	)



Segment assets as at 31 December, 2012
Segment assets		25,694		14,377		19,584		3,136		9,429		24,615		6,295		103,130
Tax assets																1,668

Total assets																104,798



Segment liabilities as at December 31, 2012
Segment liabilities		35,241		1,008		37,790		2,855		6,657		20,117		3,044		106,712
Deferred tax liabilities and Current income tax advance																128

Total liabilities																106,840



Other Segment items
Depreciation and amortization⁽¹⁾		13		2		3		9		32		65		107		231
Credit provisions and other impairment charges		1,436		608		227		29		255		286		312		3,153
Non- current assets additions		12		29		6		5		17		96		79		244

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 +90dpd 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 +90dpd, 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.

Profit before tax from our Turkish banking operations decreased to EUR 398 million for the year ended December 31, 2014 from EUR 544 million for the year ended December 31, 2013. The decrease is principally attributed to the depreciating TRY against EUR during 2014, which resulted in decreased net interest income compared to 2013. Moreover, unfavourable market conditions resulted to trading loss in Other of EUR (24) million for the year ended December 31, 2014 compared to trading gain of EUR 44 million for the period ended December 31, 2013. Direct costs reduced by EUR 95 million due to efficient cost containment. Despite the fact that credit provisions and other impairment charges increased at local currency, in EUR terms these items remained stable to EUR 342 million in 2014 from EUR 339 million in 2013 due to depreciating TRY against EUR in 2014. Moreover although the +90 dpd ratio decreased to 5.3% in 2014 compared to 6.1% in 2013 the coverage ratio increased to 75.0% in 2014 compared to 67.5% in 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.

Segment analysis for year ended December 31, 2013 compared to the year ended December 31, 2012 based on IFRS

The Group's overall decrease in loss before tax for the year ended December 31, 2013, compared with the year ended December 31, 2012, primarily reflects the improvement in the domestic economic climate that reduced the growth in +90dpd, the write-back of provisions taken in 2012 against claims on the Hellenic Republic, and the elimination of the high trading losses of the previous year.

Finansbank made a significant contribution (although below the levels of 2012) despite the adverse circumstances prevailing in the Turkish market in the second half of 2013, while the international business posted profits before tax for the year compared to losses before tax in 2012.

Loss before tax in our retail banking segment for the year ended December 31, 2013, decreased significantly to EUR 989 million compared to EUR 1,332 million for the year ended December 31, 2012. The decrease of the loss before tax is due to the decrease of new loans +90 dpd and hence lower impairment charges for credit losses. The improvement was despite a decrease in total income in our retail banking segment by EUR 325 million is mainly attributable to the decrease of EUR 213 million in consumer lending and products which outpaced the increase in mortgage lending and lending to small medium and small sized companies of EUR 77 million and EUR 35 million, respectively. The deleveraging of the retail portfolio continued in 2013. The Bank continued its restructuring efforts relating to mortgages and consumer loans by introducing flexible terms in performing loans, such as interest-only periods, installment ceilings, interest rate caps and extended loan maturities. Credit provisions and other impairment charges decreased to EUR 796 million in 2013, from EUR 1,436 million in 2012, as the economic climate in Greece gradually began to improve.

The profit before tax in our corporate and investment banking segment amounted to EUR 269 million in 2013 compared to profit before tax of EUR 76 million in 2012. The increase is mainly attributable to the decrease in credit provisions and other impairment charges from EUR 608 million in 2012 to EUR 375 million in 2013 which more than offset the decrease in net interest income which fell from EUR 745 million in 2012 to EUR 696 million in 2013. The Bank still retains its conservative approach to new commercial lending, with a greater focus on larger corporate borrowers that it perceives to be lower-risk.

Profit before tax from global markets and asset management segment was EUR 256 million in the year ended December 31, 2013, compared to the loss before tax of EUR 1,058 million for the year ended December 31, 2012. This increase in 2013, was principally due to the write-back of provisions taken in 2012 against claims on the Hellenic Republic and to the impairment of the investment securities due to the PSI that took place in 2012.

The profit before tax in our insurance segment was EUR 110 million in the year ended December 31, 2013 compared to EUR 86 million in the year ended December 31, 2012. The increase was predominantly a result of 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. Despite the increase in profit before tax, total income decreased to EUR 193 million in the year ended December 31, 2013 compared to EUR 233 million in the year ended December 31, 2012, mainly reflecting a decrease in production for the property and casualty business line as a result of the continuing recession in the Greek economy.

Profit before tax from our International banking operations of EUR 28 million in 2013, an improvement from a loss before tax of EUR 111 million in 2012, is principally attributed to the stabilization in the growth rate of +90dpd, reflecting the normalization of economic activity in the region, as well as improved loan recoveries. Therefore, credit provisions and other impairment charges decreased to EUR 114 million in 2013, from EUR 255 million in 2012. During the year ended December 31, 2013 a decrease was achieved in direct costs, which amounted to EUR 260 million, as compared to EUR 272 million for the year ended December 31, 2012.

Profit before tax from our Turkish banking operations decreased to EUR 544 million for the year ended December 31, 2013 from EUR 802 million for the year ended December 31, 2012. The decrease was principally due to changes in the regulatory framework for the country's banking sector and due to an increase in interest rates. This decrease was principally due to the decrease in other income in 2013, as 2012 included the significant contribution of EUR 157 million from the sale of a 51.00% stake of

Cigna Finans Pension. In addition, the direct costs increased due to the expansion in the Turkish market through the opening of 93 new branches in 2013. Impairment charges for credit losses increased to EUR 339 million in 2013, from EUR 286 million in 2012, as a result of Finansbank's loan portfolio growth focus on high margin products and due to Finansbank's conservative provisioning policy.

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, 2013 of EUR 397 million (2012: EUR 436 million) is mainly due to the increase in direct costs in 2013, which increased to EUR 286 million in 2013 from EUR 20 million in 2012, due to the VRS that took place in December 2013 with total cost of EUR 183 million.

Currently, the Group's principal sources of liquidity are its deposit base, Eurosystem funding in the form of repurchase agreements with the ECB and the ELA of the Bank of Greece, repurchase agreements in the interbank market and long-term debt. As at December 31, 2014, ECB funding was collateralized mainly by EFSF bonds received from HFSF and 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 at December 31, 2014, funding from ECB amounted to EUR 14.2 billion and there was no funding from ELA.

Regarding the Group's subsidiaries, Finansbank is mostly self-funded through customer deposits, repurchase agreements with the Central Bank of Turkey and funds borrowed through the capital markets. The rest of the subsidiaries are also mostly self-funded, except for Banca Romaneasca, which receives around EUR 340 million from the Bank, through interbank transactions.

Deposits decreased from EUR 91.2 billion on December 31, 2012 to EUR 85.6 billion on December 31, 2013 and EUR 81.5 billion on December 31, 2014. Interbank deposits, including funding from the ECB and central banks, decreased from EUR 32.6 billion on December 31, 2012 to EUR 23.1 billion on December 31, 2013 and to EUR 16.9 billion on December 31, 2014. However, deposits excluding interbank funding (which includes funding from the ECB and central banks), increased from EUR 58.6 billion on December 31, 2012 to EUR 62.5 billion on December 31, 2013 and to EUR 64.6 billion on December 31, 2014.

As discussed in Item 5.A. "Operating Results-Results of operations for the year ended December 31, 2014 compared with the year ended December 31, 2013-Net Interest Income before provision for loan losses", the decrease in customer deposits during 2014 resulted in decreased funding cost due to the lower reliance in Eurosystem funding and more specifically the funding through ELA (see Item 4.E. "Selected Statistical Data-Liabilities-Deposits" for an analysis of our funding rates per type of deposit). As at December 31, 2014, collateral with nominal value of EUR 18.4 billion (December 31, 2013: EUR 27.0 billion) was used for funding through the Eurosystem. This relates to debt securities, trading assets, customer loans and bonds issued from our participation in the Hellenic Republic Bank Support Plan. As at December 31, 2014 the nominal value of the available collateral for central bank funding was EUR 18.6 billion (December 31, 2013: EUR 29.7 billion) relating to covered bonds, securitizations and loans.

The reduced access to interbank and wholesale markets during 2012 to 2014 and combined with stagnation in domestic deposits has affected all Greek banks and resulted to an increased reliance on the ECB repo facilities. During 2014, the situation showed signs of improvement. As at December 31, 2014, ECB funding and funding from other central banks amounted to EUR 14.2 billion (see Note 19 to the U.S. GAAP Financial Statements for the analysis of instruments pledged). As at December 31,

2013 and 2012, ECB funding and funding from other central banks amounted to EUR 20.7 billion and EUR 30.9 billion, respectively. However, due to the ongoing negotiation between the Greek government and the Institutions towards reaching a permanent agreement, in February 2015, the ECB lifted the waiver on the eligibility as collateral for ECB funding of the Greek government and government guaranteed bonds, until persuasive positive signs that the Greek government will reach an agreement with the Institutions. As a consequence, the Bank was forced to reduce its funding from ECB and restart funding from ELA, which as at April 30, 2015 amounted to EUR 9.6 billion and EUR 15.2 billion respectively. This constitutes an increase in Eurosystem exposure compared to the respective figure as of December 31, 2013 (EUR 20.7 billion), caused mainly by the significant outflow of customer deposits since January 1 and up to April 30, 2015 of EUR 6.4 billion and the non-renewal of repurchase agreements with other financial and non-financial institutions. Despite the increase of the Eurosystem exposure, the Bank retains a significant buffer of ELA eligible collateral of EUR 12.7 billion (cash value) as at April 30, 2015, of which currently EUR 12.3 billion can only be used to increase ELA funding and is conditional on ECB approval.

The following table provides a summary of our interest bearing interbank borrowing activity for each of the three years ended December 31, 2012, 2013 and 2014.

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, 2012, 2013 and 2014, as well as the period end balance for each of these quarters and the maximum balance at any month-end.

The following table provides a summary of our cash flows for each of the three years ended December 31, 2012, 2013 and 2014.

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 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.

During 2013, compared to the corresponding period ended on December 31, 2012, our cash inflows in investing activities increased from inflows of EUR 2,546 million in 2012 to inflows of EUR 3,667 million in 2013, mainly due to a) the net cash inflows from our loan portfolio amounted to EUR 3,630 million in the period ended on December 31, 2012, while in the corresponding period ended on December 31, 2012, there was a net cash outflow of EUR 322 million, because the loan repayment exceeded new lending due to the decrease in the domestic credit expansion b) the net cash inflows from securities purchased under agreements to resell in 2013 amounted to EUR 795 million while in the corresponding period ended December 31, 2012, there was a net cash outflow of EUR 160 million and c) a cash inflow in 2013 of EUR 561 million from the HFSF for the funding gap arising from the acquisition of selected assets and liabilities of PROBANK. These cash inflows were netted off with a) the net cash outflows from interest bearing deposits with banks which amounted to EUR 340 million in the period ended on December 31, 2013, while in the corresponding period ended December 31, 2012, there was a net cash inflow of EUR 791 million, b) a cash outflow to the central bank of EUR 525 million and c) the acquisition of premises and equipment and intangibles of EUR 200 million.

Moreover, during 2013, compared to the corresponding period ended December 31, 2012, our net cash outflows from financing activities increased from outflows of EUR 406 million in 2012 to outflows of EUR 4,820 million in 2013, mainly due to a) the outflow relating to the repayment of Eurosystem

funding of EUR 10,202 million, b) the Bank's net cash proceeds in 2013 of EUR 840 million from the share capital increase of EUR 9,756 million, c) the Bank's net cash outflows for the repurchase part of its preference shares which amounted to EUR 119 million. These cash outflows were netted off with a) an inflow in 2013 in securities sold under agreements to repurchase of EUR 3,629 million compared to the outflow of EUR 194 million in 2012, b) an inflow arising from the increase of deposits by EUR 588 million, c) a net cash inflow of EUR 544 million mainly from the sale of real estate accounted for as a financing obligation.

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.

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 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). These regulations have 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.

On December 31, 2010, the Group had EUR 8,959 million of Tier I capital and EUR 9,311 million of total capital, as calculated in accordance with Basel II. On December 31, 2011, the Group had EUR (2,367) million of Tier I capital and EUR (1,664) million of total capital, as calculated in accordance with Basel II. 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, 2010, 2011 and 2012.

As at March 31, 2013, Act 13/28.03.2013 of the Executive Committee of the Bank of Greece established new additional 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:

The Group's capital adequacy ratios as at December 31, 2013 and 2014, according to EU Regulation 575/2013, are presented in the table below:

On March 6, 2014 Bank of Greece announced the results of the BlackRock stress-test exercise as extended by Bank of Greece, and Bank of Greece's conservative assessment of the pre-provision income based on the draft Restructuring Plan. Bank of Greece assessed the 3.5 years capital requirements (using June 30, 2013 as relevant reference date) at EUR 2,185 million, with the bulk stemming from a pessimistic and loss-making stressed scenario for Finansbank. The Bank presented a capital plan to the Bank of Greece, describing the actions it intends to take to address the capital shortfall, within the timing and other constraints set in April 2014 by Bank of Greece. The Bank of Greece approved this plan on April 11, 2014. This capital plan included the completed share capital increase of EUR 2,500 million and certain capital actions amounting to EUR 1,040 million.

In May 2014, we strengthened our capital base through a share capital increase of EUR 2,500 million (see below "—Sources of Capital and Liquidity—Common stock and Preference shares").

As of November 1, 2014, all systemic Eurozone banks are under the direct supervision of the ECB through the SSM. Before ECB assumed its supervisory responsibilities, the Bank, as all systemic European banks was subject to an EU-wide Comprehensive Assessment including an AQR and Stress Test with December 31, 2013 as the reference date. The 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 is based on our 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 (under IFRS) for the six month period ended June 30, 2014, which result in a capital surplus of more than EUR 2.0 billion and no further capital action is required.

Article 27A, issued on October 17, 2014 (Law 4303/2014, "DTC Law") allows, under certain conditions, and from 2016 onwards Credit Institutions to convert DTA (under IFRS) arising from PSI losses and accumulated provisions for credit losses on loans existing at December 31, 2014 ("Eligible DTA") to a receivable (Tax Credit) from the Hellenic Republic. The Tax Credit will be calculated as a ratio of IFRS accounting losses over net equity before the year's losses and such ratio will be applied on the remaining eligible DTA in a given year. The Tax Credit is offsettable against income taxes payable. Any excess amount of the Tax Credit that cannot be offset against income taxes payable is immediately recognized as a receivable from the Hellenic Republic. In such case the Bank will issue conversion rights for an amount of 110% of the Tax Credit receivable in favor of the Hellenic Republic and create a specific reserve for an equal amount. Common shareholders have pre-emption rights on these rights. The reserve will be capitalized with the issuance of common shares in favor of the Hellenic Republic. This new legislation allows Credit Institutions to treat such DTA as not "relying on future profitability" according to CRD IV, and as a result such DTA are not deducted from CET1, hence improving their capital position.

On November 7, 2014 the Bank convened an extraordinary General Shareholders Meeting which resolved upon the inclusion of the Bank in the DTC Law. In order for the Bank to exit the provisions of the DTC Law it requires regulatory approval and a General Shareholders meeting resolution.

As of December 31, 2014, the amount of DTA (under IFRS) that was eligible for conversion to a receivable from the Hellenic Republic subject to the DTC Law was EUR 3.3 billion.

The table below sets forth the credit ratings that have currently been assigned to the Bank by Moody's, Standard & Poor's and Fitch.

As at December 31, 2014, total assets were EUR 108.4 billion, an increase of 1.5% from the Group's total assets of EUR 106.9 billion, as at December 31, 2013, which in turn was a 5.6% increase from the Group's total assets of EUR 101.2 billion as at December 31, 2012. Deposits with the Central Bank were EUR 3.6 billion in 2014, EUR 3.5 billion in 2013 and EUR 2.9 billion in 2012. Securities purchased under agreements to resell were EUR 94 million as at December 31, 2014, EUR 39 million as at December 31, 2013 and EUR 833 million as at December 31, 2012. Interest bearing deposits with banks were EUR 2.8 billion in 2014, EUR 3.3 billion in 2013 and EUR 3.0 billion in 2012. The Group's securities portfolio was EUR 18.3 billion as at December 31, 2014, EUR 19.8 billion as at December 31, 2013 and EUR 12.9 billion as at December 31, 2012.

The Group's loan portfolio decreased from EUR 74.3 billion at December 31, 2012 to EUR 73.2 billion at December 31, 2013 and increased to EUR 74.9 billion at December 31, 2014. At December 31, 2014, the Group's loan portfolio accounted for 69.1% of total assets. Allowance for loan

losses increased from EUR 7.3 billion in 2012 to EUR 7.8 billion in 2013 and to EUR 9.5 billion in 2014. See Item 4.E, "Selected Statistical Data—Assets—Loan Portfolio".

Deposits decreased from EUR 91.2 billion on December 31, 2012 to EUR 85.6 billion on December 31, 2013 and decreased to EUR 81.5 billion on December 31, 2014. Of these, interbank funding, including funding from the ECB and central banks, decreased from EUR 32.6 billion in 2012 to EUR 23.1 billion in 2013 and then to EUR 16.9 billion in 2014.

For further discussion of Liquidity and Capital Resources, including the maturity profile, currency and interest rate structure of debt, see Note 22 and Note 25 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 2014 include mainly costs relating to reallocation of existing branches. Capital expenditure for the Group, excluding such interests in other companies, amounted to EUR 957 million in 2014. 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 4 million for the year ended December 31, 2014. 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 shares from EUR 5.00 to EUR 1.00 per share, as per article 4 para 4a of the 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 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.

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.

Following the above common stock increases the total number of ordinary shares as at December 31, 2014 and December 31, 2013 was 3,533,149,631 and 2,396,785,994 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 preference shares (the "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). The total proceeds of the offering amounted to USD 625 million or EUR 403 million. The annual dividend rate is set to USD 2.25 per preference share. On May 31, 2013, the Bank announced an offer to purchase for cash 22,500,000 out of the 25,000,000 outstanding American Depository 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. Based on the results of the Offer, the aggregate purchase cost for the tendered ADSs was USD 155 million. On July 3, 2013, the purchase of the 12,360,169 ADSs was settled by the Bank. Following the purchase of the ADSs, 12,639,831 ADSs remain outstanding. The Bank cancelled the 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.

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 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 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 Preference Shares at a nominal value of EUR 5.00 each in favor of the Greek government.

The Bank, through its VIE, has the following securitized notes in issue as at December 31, 2014:

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 bps
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 bps
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 bps
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 bps
Autokinito Plc	Asset Backed Variable Rate Notes—Class B	Auto loans	September 23, 2011	September 2023	97	⁽¹⁾	Paid semi-annually at a rate of six month Euribor plus a margin of 350 bps
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 bps
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 bps

Moreover, Revolver 2008-1 Plc, by April 15, 2014, proceeded with the full redemption of the remaining EUR 265 million Class A Notes and the EUR 269 million Class B Notes and from January 29, 2015 is under liquidation.

Under the covered bond Programs I and II, the Bank has the following covered bond series in issue as at December 31, 2014:

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	⁽³⁾	Paid annually at a fixed coupon rate of 3.875%
Program II⁽²⁾	1st Series	Residential mortgage loans	June 24, 2010	June 2021⁽⁵⁾	1,150	⁽⁵⁾	Paid quarterly at rate of three month Euribor plus a margin of 250 bps⁽⁵⁾
Program II⁽²⁾	2nd Series	Residential mortgage loans	June 24, 2010	June 2020⁽⁶⁾	1,200	⁽⁶⁾	Paid quarterly at rate of three month Euribor plus a margin of 240 bps⁽⁶⁾
Program II⁽²⁾	3rd Series	Residential mortgage loans	June 24, 2010	June 2019	1,350	⁽⁷⁾	Paid quarterly at rate of three month Euribor plus a margin of 230 bps⁽⁷⁾
Program II⁽²⁾	4th Series	Residential mortgage loans	November 25, 2010	December 2018	1,100	⁽⁴⁾	Paid quarterly at rate of three month Euribor plus a margin of 210 bps

On April 9, 2014, the 6th series of Program II of EUR 1,300 million was cancelled.

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 25 U.S. GAAP Financial Statements.

Issuer	Type	Issue date	Maturity date	Currency				Interest rate

NBG	Fixed rate covered bonds—3rd Series	October 7, 2009	October 2016	EUR	846	⁽¹⁾	—	Paid annually at a fixed coupon rate of 3.875%
NBG Finance Plc⁽⁴⁾	Fixed Rate Notes—Lower Tier II	August 3, 2010	August 2020 (Early redemption 2015)	EUR	18		—	Paid annually at a rate of 7.0% for the first 5 years and 9.5% thereafter.
Finansbank	Senior Unsecured Notes	May 11, 2011	May 2016	USD	500		71	Paid semi-annually at fixed interest rate of 5.5%
Finansbank	Eurobond Fixed Rate Notes	November 1, 2012	November 2017	USD	350		29	Paid semi-annually at fixed interest rate of 5.15%
Finansbank	Variable Rate Bonds⁽²⁾	April 9, 2014	March 2015	TRY	311		78	Paid quarterly Dibs plus 1.15%
Finansbank	Senior Unsecured Notes	April 25, 2014	April 2019	USD	500		24	Paid semi-annually at fixed interest rate of 6.25%
NBG Finance Plc	Notes Senior Unsecured Notes	April 30, 2014	April 2019	EUR	750		—	Paid annually at fixed interest rate of 4.375%
Finansbank	Variable Rate Bonds⁽²⁾	June 4, 2014	April 2015	TRY	223		49	Paid quarterly Dibs plus 1.15%
NBG Pangaea REIC	Variable rate bond	August,20, 2014	July 2019	EUR	238		—	Paid quarterly Euribor plus 4.85%
Finansbank	Variable Rate Bonds⁽²⁾	September 3, 2014	September 2015	TRY	204		71	Paid quarterly Dibs plus 1.00%
Finansbank	Variable Rate Bonds⁽²⁾	October 1, 2014	October 2015	TRY	138		25	Paid quarterly Dibs plus 1.20%
Finansbank	Variable Rate Bonds⁽²⁾	November 10, 2014	May 2015	TRY	384		2	Principal amount and interest will be paid at maturity at variable interest rate of Dibs plus 1.10%
Finansbank	Variable Rate Bonds⁽²⁾	November 14, 2014	February 2015	TRY	142		—	Principal amount and interest will be paid at maturity at variable interest rate of Dibs plus 0.80%
Finansbank	Variable Rate Bonds⁽²⁾	November 18, 2014	February 2015	TRY	148		17	Principal amount and interest will be paid at maturity at variable interest rate of Dibs plus 0.60%
Finansbank	Variable Rate Bonds⁽²⁾	November 21, 2014	February 2015	TRY	126		—	Principal amount and interest will be paid at maturity at variable interest rate of Dibs plus 0.80%

Issuer	Type	Issue date	Maturity date	Currency				Interest rate

Finansbank	Amended Facility Agreement	November 26, 2014	November 2015	USD	396	⁽⁴⁾	—	Paid semi-annually at Libor plus 1%.
Finansbank	Amended Facility Agreement	November 27, 2014	November 2015	EUR	353	⁽⁴⁾	—	Paid semi-annually at Euribor plus 1%.
Finansbank	Variable Rate Bonds⁽²⁾	December 4, 2014	April 2015	TRY	300		6	Principal amount and interest will be paid at maturity at variable interest rate of Dibs plus 0.60%
Finansbank	Variable Rate Bonds⁽²⁾	December 8, 2014	April 2015	TRY	108		—	Principal amount and interest will be paid at maturity at variable interest rate of Dibs plus 0.80%
Finansbank	Variable Rate Bonds⁽²⁾	December 24, 2014	November 2015	TRY	244		1	Principal amount and interest will be paid quarterly at variable interest rate of Dibs plus 1.20%

Issuer	Type	Issue date	Redemption date	Currency

Finansbank	Fixed Rate Bonds⁽¹⁾	September 14, 2012	March 2013	TRY	400
Finansbank	Fixed Rate Bonds⁽¹⁾	September 21, 2012	March 2013	TRY	500
Finansbank	Fixed Rate Bonds⁽¹⁾	November 15, 2012	May 2013	TRY	750
Finansbank	Fixed Rate Bonds⁽¹⁾	December 14, 2012	June 2013	TRY	650
Finansbank	Fixed Rate Bonds⁽¹⁾	December 27, 2012	April 2013	TRY	600
Finansbank	Fixed Rate Bonds⁽¹⁾	March 20, 2013	September 2013	TRY	400
Finansbank	Fixed Rate Bonds⁽¹⁾	April 4, 2013	September 2013	TRY	476
Finansbank	Fixed Rate Bonds⁽¹⁾	June 26, 2013	December 2013	TRY	525
Finansbank	Fixed Rate Bonds⁽¹⁾	July 11, 2013	December 2013	TRY	125
Finansbank	Fixed Rate Bonds⁽¹⁾	July 18, 2013	October 2013	TRY	105
Finansbank	Fixed Rate Bonds⁽¹⁾	July 25, 2013	November 2013	TRY	266
Finansbank	Fixed Rate Bonds⁽¹⁾	August 29, 2013	November 2013	TRY	578
Finansbank	Fixed Rate Bonds⁽¹⁾	April 19, 2013	April 2014	TRY	124
Finansbank	Fixed Rate Bonds⁽¹⁾	October 11, 2013	January 2014	TRY	750
Finansbank	Fixed Rate Bonds⁽¹⁾	October 25, 2013	February 2014	TRY	150
Finansbank	Fixed Rate Bonds⁽¹⁾	November 25, 2013	March 2014	TRY	245
Finansbank	Fixed Rate Bonds⁽¹⁾	December 12, 2013	April 2014	TRY	899
Finansbank	Fixed Rate Bonds⁽¹⁾	December 24, 2013	April 2014	TRY	116
Finansbank	Fixed Rate Bonds⁽¹⁾	February 11, 2014	May 2014	TRY	244
Finansbank	Fixed Rate Bonds⁽¹⁾	February 28, 2014	May 2014	TRY	171
Finansbank	Fixed Rate Bonds⁽¹⁾	April 16, 2014	July 2014	TRY	187
Finansbank	Fixed Rate Bonds⁽¹⁾	April 30, 2014	October 2014	TRY	500
Finansbank	Fixed Rate Bonds⁽¹⁾	May 12, 2014	August 2014	TRY	295
Finansbank	Fixed Rate Bonds⁽¹⁾	May 30, 2014	August 2014	TRY	218
Finansbank	Fixed Rate Bonds⁽¹⁾	June 24, 2014	September 2014	TRY	125
Finansbank	Variable Rate Bonds⁽¹⁾	July 16, 2014	October 2014	TRY	148
Finansbank	Variable Rate Bonds⁽¹⁾	August 11, 2014	November 2014	TRY	210
Finansbank	Variable Rate Bonds⁽¹⁾	August 29, 2014	November 2014	TRY	223
Finansbank	Variable Rate Bonds⁽¹⁾	September 23, 2014	December 2014	TRY	124

The Bank participated in the Hellenic Republic Bank Support Plan of Greek Law 3723/2008 as follows:

Following the Extraordinary General Meeting of the Bank's Shareholders held on January 22, 2009, the Bank issued on May 21, 2009, 70 million 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 Hellenic Republic, in accordance with Greek Law 3723/2008.

On November 26, 2010, at an Extraordinary General Meeting of the Bank's Shareholders, the shareholders approved the repurchase by the Bank of the Greek State Preference Shares of a nominal value of EUR 350 million through payment in cash, subject to obtaining Bank of Greece and other statutory approvals.

Furthermore, on December 22, 2011, the Extraordinary General Meeting of the Bank's Shareholders approved a) the preferred stock increase by EUR 1,000 million through the issue of an additional 200 million 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 Hellenic Republic, in accordance with Greek Law 3723/2008 and b) the revocation of the decision of the Extraordinary General Meeting of the Bank's Shareholders held on November 26, 2010 regarding the repurchase by the Bank of the 70 million Redeemable Greek State Preference Shares in favor of the Hellenic Republic, in accordance with Greek Law 3723/2008.

On December 30, 2011, following the above decision, the Bank issued the 200 million Greek State Preference Shares at a nominal value of EUR 5.00 each. Please also refer to Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic's Bank Support Plan" and Note 18 to the U.S. GAAP Financial Statement.

Under the government-guaranteed borrowings facility, the Bank participated in the second pillar of Greek Law 3723/2008 "Hellenic Republic's Bank Support Plan" as follows:

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 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.

The major debt securities in issue issued after December 31, 2014 are as follows:

On February 20, 2015, Finansbank issued TRY 150 million Dibs plus 0.80% variable rate notes, maturing in May 2015.

On March 6, 2015, Finansbank issued TRY 150 million Dibs plus 0.90% variable rate notes, maturing in June 2015.

On March 24, 2015, Finansbank issued TRY 101 million Dibs plus 0.60% variable rate notes, maturing in June 2015.

On April 10, 2015, Finansbank issued TRY 258 million Dibs plus 0.60% variable rate notes, maturing in September 2015.

On April 30, 2015, Finansbank issued TRY 115 million Dibs plus 0.80% variable rate notes, maturing in July 2015.

We consider effective risk management to be a key factor in our ability to deliver sustained returns to our shareholders. We allocate substantial resources to upgrading our policies, methods and infrastructure to ensure compliance with best international practices and the guidelines of the Basel

Committee for Banking Supervision. For a discussion of management's specific risks, see Item 11, "Quantitative and Qualitative Disclosures About Market Risk".

The Group aims to adopt practices regarding risk management governance, taking into account all relevant guidelines and regulatory requirements, as set by the Basel Committee on Banking Supervision, the EBA, the Bank of Greece and the HCMC, as well as any decisions of the competent authorities supervising the Group's entities.

The Group's risk governance framework comprises a number of different constituents. In particular, the Board of Directors has established the Board Risk Committee ("BRC") overseeing all risk management functions across the Group. All risk management units report to the NBG Group Risk Control and Architecture Division ("GRCAD") and to the NBG Group Market and Operational Risk Management Division ("GMORMD"), which are supervised by the Group Chief Risk Officer (the "CRO"). A separate compliance function, the Compliance Division, oversees all internal and external compliance matters, such as applicable Greek and EU, laws and regulations, as well as accounting standards. The Internal Audit—Inspection Division 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 the 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 & 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 adequately 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. 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 (at Group level) of the Risk Management Council, the New Product Committee and the Compliance & 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 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 is comprised of 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.

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.

Internal Audit of the NBG Group 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 Group 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 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 Bank's Board of Directors has approved the amendment of GIAD's Charter, incorporating in it the updated Basel Guidelines and IIA standards and upgrading the IT Audit Unit into a separate Sector, reporting directly to the Group Chief Audit Executive.

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 on reasonable terms.

The Bank's Senior Executive Committee has the responsibility to implement the liquidity risk strategy approved by the 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 Senior Executive Committee 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 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. On a long term perspective, the Group also monitors its Loans-to-Deposits ratio, which as at December 31, 2014, stood at 93.8%.

Since liquidity risk management seeks to ensure that the respective risk of the Group is measured properly and is maintained within acceptable levels and that, even under adverse conditions, the Group must has access to funds necessary to cover customer needs, maturing liabilities and other capital needs by maintaining the counterbalancing capacity.

For a discussion on the principal sources of liquidity of the Bank and the Group's subsidiaries, see Item 5.B, "Liquidity and Capital Resources—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 and shareholders' equity by those denominated in EUR and those denominated in other currencies for the Group under U.S. GAAP on December 31, 2012, 2013 and 2014. 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,

	2012									2013									2014
	EUR			Other Currency			Total			EUR			Other Currency			Total			EUR			Other Currency			Total
	(in millions)
Assets:
Cash and due from banks		1,053			1,104			2,157			1,113			855			1,968			1,734			993			2,727
Deposits with central bank		1,194			1,692			2,886			1,562			1,892			3,454			988			2,595			3,583
Securities purchased under agreements to resell		33			800			833			36			3			39			1			93			94
Interest bearing deposits with banks		2,536			441			2,977			3,013			320			3,333			2,368			408			2,776
Trading assets		5,204			265			5,469			2,732			350			3,082			2,145			260			2,405
Derivative assets		3,232			461			3,693			2,415			1,256			3,671			4,592			1,351			5,943
Available-for-sale securities, at fair value		3,470			3,621			7,091			3,859			2,526			6,385			2,702			2,501			5,203
Held to maturity securities		345			11			356			9,376			984			10,360			9,342			1,303			10,645
Equity method investments		75			113			188			62			90			152			70			90			160
Loans		52,310			22,024			74,334			52,703			20,533			73,236			51,374			23,534			74,908
Less: Allowance for loan losses		(6,317	)		(1,001	)		(7,318	)		(6,802	)		(950	)		(7,752	)		(8,290	)		(1,202	)		(9,492	)

Net loans		45,993			21,023			67,016			45,901			19,583			65,484			43,084			22,332			65,416
Goodwill, software and other intangibles		283			2,840			3,123			234			2,285			2,519			2,008			588			2,596
Premises and equipment		932			350			1,282			1,072			346			1,418			1,454			674			2,128
Accrued interest receivable		465			278			743			532			297			829			487			340			827
Other assets		2,763			579			3,342			3,537			476			4,013			3,170			599			3,769
Assets classified as held for sale		—			—			—			134			—			134			118			23			141

Total assets		67,578			33,578			101,156			75,578			31,263			106,841			74,263			34,150			108,413

We have not engaged in any significant research and development activities during any of the last three financial years.

Following the Hellenic Republic's sovereign debt crisis beginning in 2009 and the sharp deterioration in financial and macroeconomic conditions, a financial support mechanism was activated in May 2010, jointly supported by the IMF and Eurozone Member States with terms extending through 2015 conditioned on the implementation of a very demanding economic adjustment program (see Item 5, "Operating and Financial Review and Prospects—Key Factors Affecting Our Results of

Operations—Overview of the Crisis, Recent Market and Regulatory Developments—The Hellenic Republic's Economic Crisis—Second Economic Adjustment Program, jointly supported by the IMF and the Member States of the Eurozone—The Second Program"). Following the government debt restructuring in February 2012, the Second Program, conditioned on the imposition of fiscal and structural adjustment policies.

The impact of the economic adjustment programs in terms of losses in production, employment and disposable income, has been very high by historical standards, as the existing structural inflexibilities and the short period over which the adjustment policies have been implemented have amplified the recessionary impact and social costs of the austerity measures. The intensity of economic adjustment had also been compounded by a high level of uncertainty, resulting in a sharp contraction of GDP that reached (26.0)% in the 2008-2013 period.

In 2013, adjustment policies began to bear fruit as a primary surplus of 1.2% of GDP in the general government budget (according to the Second Program definition, Greek Government Budget 2015, Introductory Note)—a year earlier than the Second Program target. Moreover, a surplus of 0.6% of GDP has been registered in the current account balance of Greece's external transactions, for the first time in sixty years. The current account deficit in Greece's external transactions decreased by 15.5% of GDP between 2008 and 2013. The cyclically adjusted primary balance improved by almost 16% of GDP between 2009 and 2013, and in 2013 it was two time higher than the European average (IMF Fiscal Monitor, October 2014).

Moreover, notable progress in structural reforms was achieved between 2009 and 2013 especially in key areas such as the pension system, network industries and the labor market. These reforms are increasing the competitiveness of the economy—reversing much of the imbalances accumulated over the previous decade—and augmenting the credibility and the sustainability of Greek economic adjustment. The above developments contributed to a gradual recovery of economic sentiment and the establishment of investors' and markets' trust with respect to the growth potential and prospects of the Greek economy; indicatively, from the peak of the crisis in June 2012 to the end of 2013, the following developments occurred:

In 2014, following six consecutive years of severe contraction, Greece's economy began to grow as real GDP increased by 0.7% year-on-year in 2014 (ELSTAT data), supported mainly by rising private consumption (1.4% year-on-year in 2014), the strong performance of the tourism sector (an annual increase of 10.6% year-on-year in tourism revenue, Bank of Greece Data) and positive, albeit relatively slower, growth of goods exports (5.3% in volumes, in 2014). Moreover, business investment picked up offsetting the drag from the continuing sharp drop in residential investment, permitting economy-wide gross fixed capital formation to enter positive growth territory as from the third quarter of 2014 (3.0% year-on-year in 2014 in constant prices, ELSTAT data).

The positive GDP growth trend remained firm in the second half of 2014 (1.4% year-on-year), although uncertainty about the modalities of a potential exit from the Second Program in conjunction with the early election in January 2015 took a negative toll on business sentiment in late 2014 and early 2015 (EU Commission data).

Overall, private consumption was a key contributor to GDP growth (1.4% year-on-year in 2014 compared to (2.2)% year-on-year in 2013), supported by the gradual improvement in labor market conditions (employment growth of 0.6% in2014, ELSTAT data), the notable slowing in wage adjustment following a sharp cumulative decline in economy-wide nominal average wage of (23)% since 2009 (Bank of Greece estimates, November 2014) and steadily improving consumer confidence for the most part of the year. Employment growth entered positive territory in second quarter of 2014 and gained traction in second half of 2014 supported by the buoyancy of demand in tourism sector and related activities. Unemployment rate remains very high but has followed a downward trend since October 2013 falling to 26.0% in December 2014 (ELSTAT data).

Business investment (excluding residential construction) showed a significant improvement increasing by 18.4% year-on-year (ELSTAT data) in 2014 supported by the pick up in consumption, accelerating tourism activity and improving external demand (especially in second half of 2014). On the other hand, the free fall in residential investment continued ((51.5)% year-on-year in 2014, from (27.7)% year-on-year in 2013) and the annual drop in house prices reached (7.4)%, on average, in 2014 Bank of Greece, Bulletin of conjunctural indicators).

External adjustment gained additional traction with the current account balance (Bank of Greece Bulletin of conjunctural indicators) registering the second consecutive surplus of 0.9% of GDP on the back of strong tourism receipts (10.6% year-on-year in 2014) and positive goods exports (4.9% year-on-year in 2014). The fall in oil import bill and higher current transfers (mainly from EU) have also supported external adjustment. The solid gains in cost competitiveness following six years of sharp adjustment in average nominal wages of almost (24)%, are reflected at the cumulative decline of unit labour cost by 17% in the period 2010-2014 (Source: Bank of Greece, Governor's Annual Report, February 2015).

Inflation remained negative (CPI: (1.3)% year-on-year and GDP deflator (2.6)% in 2014, ELSTAT data) with falling oil and other commodity prices in the second half of 2014 feeding into the continuing disinflationary process that begun in 2013. Nominal GDP declined by 1.9% in 2014 as the 2.6% decline in GDP deflator offset the 0.7% increase in real GDP.

The fiscal adjustment achieved in recent years has been unprecedented—an adjustment of 11.5% of GDP in government budget primary surplus—and brought Greece to the top three of Eurozone countries with the highest primary surpluses (in 2013) and the largest cyclically adjusted primary surplus (higher than 5.0% of GDP, EU Commission Winter Forecasts 2015).

Government budget implementation remained broadly on track for the most part of 2014 (Greek Ministry of Finance monthly press releases), however an increasing revenue shortfall due to the delayed implementation of a new law for settlement of tax and social security contributions' arrears and moral hazard related to the snap election of January 2015, have weakened fiscal performance since September 2014. In 2014 the weaker than budgeted revenue performance and continued tensions in social security system financing, have been only partly offset by further cuts in primary spending. Annual Fiscal data disseminated from ELSTAT to Eurostat in April 2015 indicate a primary surplus of 0.4% of GDP in general government budget in FY 2014 on the basis of Eurostat's European System of National and Regional Accounts ("ESA") 2010 regulation (not fully aligned with Program definition).

The general government's debt-to-GDP ratio reached 177.1% in 2014 (ELSTAT Press release on 2011-2014 Fiscal Data, April 2015), and is expected to peak at 180.2% of GDP in 2015 and decline to 173.5% of GDP in 2016 to below 172% (EU Commission forecasts, Spring 2015), on the back of a

higher primary surplus and assuming acceleration of economic growth (EU Commission estimates, Spring 2015). Favorable interest rates together with the back-loaded payment schedule for loans from the EFSF will help to keep interest expenditure low for a long period, despite the still high stock of debt. However the prospective downward revision of the Program target for a primary surplus of 2.9% of GDP in 2015 to 1-1¹/2% of GDP along the lines of the Eurogroup agreement of February 20, 2015 in conjunction with lower growth in nominal GDP could delay the return of public debt to a sustainable downward trajectory by about one year.

Liquidity conditions had shown signs of improvement until October 2014, especially in the deposit segment (increase of private deposits of 9.2% or EUR 16.2 billion from the lows of June 2012) while 10-year Greek Government bond yields fell to below 6.0% in September 2014 for the first time in 5¹/2 years supported by a further loosening of monetary policy conditions in the euro area.

The deleveraging process continued at a slowing pace during 2014, with business and household lending declining by 3.3% and 2.9%, respectively, in December 2014 (source: Bank of Greece, Bulletin of Conjunctural Indicators), and the peak-to-date adjustment in outstanding private-sector credit in gross terms amounting to (18.1)% since 2009 (source: Bank of Greece, Bulletin of Conjunctural Indicators). However, the Greek economy experienced a deterioration of financial market sentiment in the fourth quarter of 2014, reflecting political uncertainty and on-going discussions on the evolution of Greece's relationship with its official lenders and the timing and characteristics of Greece's exit from the current economic support program.

On December 8, 2014, the Eurogroup agreed to withhold the disbursements due under the Hellenic Program and announced a "technical extension" of the EU side of the Hellenic Program, initially set to be completed by the end of 2014, to end February 2015.

Greek parliamentary elections held on January 25, 2015 resulted in the formation of a new coalition government, with a parliamentary majority comprising the left wing party Syriza (149 seats) and the right wing party Independent Greeks (13 seats). The new Greek government has expressed its intention to attempt a renegotiation of Greece's relation with its official creditors, and to negotiate additional debt relief from the official sector, in conjunction with lower debt servicing costs.

On February 4, 2015, the ECB announced its decision to lift the waiver affecting marketable debt instruments issued or fully guaranteed by the Hellenic Republic, which had allowed these instruments to be used in ECB and National Central Banks monetary policy operations despite the fact that they did not fulfill minimum credit rating requirements.

As of the date of this Annual Report, no agreement between Greece and its official lenders has been reached as regards the conditions and the timing of disbursement of remaining EFSF and IMF funds to Greece under the Second Program and the modalities of the transition from the current arrangement to a new financial arrangement—which is likely to provide contingent financing for covering the Hellenic Republic's financing needs for 2015 and 2016.

Such an agreement between the Greek government and the Institutions on the framework and conditionality that is going to underlie their relation in the near term as well as in following years is a precondition for:

The continuing delay in reaching an agreement as regards the conditions underlying the disbursement of about EUR 7.3 billion of related financing from the EU and the IMF, in conjunction with uncertainty surrounding the potential modalities of Greece's exit from the current financial support agreement, have resulted in weakening financial market sentiment in the first fourth months of 2015.

Accordingly, Greek 10-year government bond yields climbed to above 12% in early April 2015 from 5.9% in September 2014 (monthly average, Bloomberg generic Greek government bond yields) and total deposits in the Greek banking system declined by EUR 30.1 billion between November 2014 and March 2015 (Bank of Greece, banking system database). As a result, Greek banks dependence on the Eurosystem climbed rapidly to above EUR 107.2 billion in March 2015 of which EUR 68.5 billion corresponded to the ELA. The respective figures in September 2014 were EUR 42.6 billion of total Eurosystem dependence with only EUR 1.6 billion related to ELA.

Uncertainty regarding the coverage of the financing needs of the Hellenic Republic in 2015 and 2016—provided that conditions as of April 2015 are prohibitive for the Hellenic Republic to access the capital markets—in conjunction with continuing fiscal effort, slow recovery of disposable income in the private sector and exogenous factors have exerted, and may continue to exert, significant downward pressure and/or excessive volatility on asset prices and on the availability and cost of credit for financial institutions, including the Group. Furthermore, the above factors will continue to impact adversely the credit quality of the Group's customers and counterparties weighing on their financing and income positions, weakening further collateral valuations and giving rise to additional moral hazard effects i.e. undermining borrowers' incentives to service their debts. These conditions, alone or in combination with regulatory changes or actions of other market participants, may cause the Group to incur significant losses or experience further reductions in business activity, increased funding costs and funding pressures, lower share prices, decreased asset values, additional write downs and impairment charges and lower profitability.

Additional risks and challenges during 2015 relate to the persistence of high unemployment rates in Greece, the effect of the anticipated income and property tax reforms, as well as the success of the major structural reforms in Greece and their impact on the economy.

The Macroeconomic Environment in South Eastern Europe-5 ("SEE-5", comprising Albania, Bulgaria, FYROM, Romania, and Serbia) and Turkey⁽¹⁾

The economies and banking sectors of Turkey and SEE-5 performed relatively well in 2014.

The Turkish economy and banking sector performed relatively well in 2014, despite a weakened global risk appetite for emerging market assets and a heightened domestic political uncertainty, due to the ongoing long electoral cycle (local and presidential elections were held in March and August 2014, respectively, and legislative elections are set to take place in June 2015). Economic activity slowed down, with real GDP growth moderating to 2.9% in 2014 from 4.2% in 2013, mainly due to weaker domestic demand, following the sharp hike of the Central Bank of the Republic of Turkey's ("CBRT's") key policy rate (the 1-week repo rate) by 550 bps to 10.0% at end-January 2014, and the implementation of macro-prudential measures to contain credit activity growth at 15.0%. The sharp

increase of the CBRT's 1-week repo rate at end-January 2014 aimed at halting a disorderly depreciation of the domestic currency (by 7.9% against the USD in the first three weeks of 2014 and by 22.7% since mid-May 2013), driven by adverse external financial conditions and increasing volatility ahead of the 2014 local and national elections. As a result, the CBRT's average effective funding rate rose from 5.8% in 2013 to 9.5% in the first five months of 2014 before easing to around 8.6% in the rest of the year.

On a positive note, the current account deficit, the "Achilles heel" of the economy, narrowed significantly to 5.7% of GDP (USD 45.8 billion) in 2014 from 7.9% of GDP (USD 60.0 billion) in 2013, on the back of not only a gradual normalization of the gold balance (which posted its worst ever performance in 2013) but also a significant improvement in the underlying balance (excluding oil and gold). Importantly, despite adverse external financial conditions in 2014, net FDI inflows reached USD 5.5 billion ; net portfolio inflows stood at USD 20.0 billion; and banks and non-bank companies were net borrowers of USD 12.2 billion and USD 5.8 billion, respectively. Moreover, the long-term loan rollover ratio of banks and non-bank companies stood at 190.9% and 124.6%, respectively, in 2014. As a result, foreign exchange reserves remained broadly unchanged from 2013, standing at the comfortable level of USD 106.9 billion (covering around 5 months of imports of goods and non-factor services).

Despite a backdrop of weak economic growth and tight liquidity conditions, the Turkish banking sector posted a relatively good performance in 2014. Specifically, the (annualized) return on average equity ratio edged down to 12.2% in 2014 from 14.2% in 2013, due, inter alia, to a faster repricing of deposits and moderating lending activity (up 18.5% year-on-year in December 2014 against 32.2% year-on-year in December 2013). Moreover, the loans +90 dpd-to-total loans ratio inched up to 2.9% in December 2014 from 2.8% in December 2013. Finally, the capital adequacy ratio strengthened to 16.3% in December 2014 from 15.3% in December 2013—well above the statutory threshold of 8.0%.

Turkey remains dependent on external financing, and its economy is highly exposed to turnarounds in global activity and investor sentiment. Turkish assets will continue to be vulnerable to sudden shifts in global investor sentiment. As a result, there can be no assurance that Turkey will not experience volatility in domestic financial markets. Such likelihood would increase if international market turbulence continues and would have a negative impact on Finansbank's business and could adversely affect the Group's business, results of operations or financial condition.

SEE-5 economies and banking sectors also performed relatively well in 2014. Economic activity slowed down, with real GDP growth easing to an estimated 2.0% in 2014 from 2.8% in 2013, mainly reflecting a base effect from a surge in agricultural output in the third quarter of 2013 and a contraction in Serbia's GDP due to devastating floods last May. The relatively strong growth performance in 2014 was supported by external demand. Exports gained steam, mainly due to increasing penetration in non-EU fast-growing regions and broadening export base (especially in the automotive sector, which currently comprises approximately 40.0% of Romania's total exports of goods). The current account deficit remained at 1.7% of GDP for the second successive year in 2014, well below the pre-crisis all-time high of 15.0% of GDP, supported by subdued domestic demand, reflecting, among other factors, a tight fiscal policy stance (the fiscal deficit stood at 3.1% of GDP in 2014, broadly in line with the EU threshold of 3.0%) and weak credit activity, mainly as a result of limited financing of the primarily foreign-owned banking sector by parent banks and banks' tight credit standards. On another positive note, non-debt generating foreign direct investments more than covered the current account deficit for the second year in a row in 2014 (around 150%).

Against this backdrop, the SEE-5 banking sector's fundamentals strengthened and its performance improved in 2014. In particular, excluding Romania, where massive provisioning for bad loans continued for a third consecutive year, the profit is estimated to have increased to EUR 658 million in 2014 from EUR 366 million in 2013, underpinned by lower provisions for bad loans, in line with the

stabilization of the ratio of problematic loans to total gross loans (ranging between 11.3% in FYROM and 22.8% in Albania at end-2014 and 11.5% in FYROM and 23.2% in Albania at end-2013). Moreover, the capital adequacy ratio stabilized at high levels (ranging between 15.7% in FYROM and 21.9% in Bulgaria at end-2014 and 15.5% in Romania and 20.9% in Serbia at end-2013), boding well for a rebound in lending activity in the near future, in view of the region's low penetration rate (loan-to-GDP ratios in SEE-5 ranged between 31.3% and 60.8% at end-2014), especially in the retail segment (retail lending-to-GDP ratios in SEE-5 ranged between 10.7% and 21.6% at end-2014) and adequate liquidity ratio (the SEE-5 average loan-to-deposit ratio returned, for the first time in eight years, to below the 100.0% threshold at end-2014). Note that the Bulgarian banking sector came under stress in mid-2014, with runs on two large domestically-owned banks (Corporate Commercial Bank and First Investment Bank). However, the situation normalized rapidly, as the authorities put into administration one of the banks and secured a large emergency liquidity support to the banking sector (equivalent to more than 40% of the sector's capital) through a precautionary credit line of EUR 1.7 billion from the European Union and the issuance of a special bond worth EUR 0.7 billion.

In SEE-5, real GDP growth is expected to turn higher in 2015 than in 2014 but remain below its long-term potential of 3.5%, supported by reviving domestic demand. Indeed, strengthening real disposable income, on the back of improving labour market conditions and weak inflation, should boost private consumption, while better absorption of EU funds should strengthen further investments. This benign operating environment, along with the expected slowdown in non-performing loans formation, should help improve further the profitability of the banking sector.

There are, however, downside risks to the SEE-5 positive outlook, stemming from renewed political uncertainty (a fragile majority Government in Bulgaria and continued boycott of Parliament by the opposition in FYROM) and weaker-than-expected economic activity in the region's main trading partner—the euro area.

In Turkey, real GDP growth is also expected to move up in 2015 from 2.9% in 2014 but remain below its long-term average of 4%, on the back of stronger domestic demand, reflecting lower interest rates and global oil prices. Moreover, the current account deficit is expected to narrow further, due to a large improvement in the oil balance. In this benign operating environment, the banking sector's profitability should improve, mainly on the back widening net interest margins, reflecting lower interest rates and inflation, as well as a resilient credit activity.

The macroeconomic and banking sector performance in Turkey would, however, be weaker than expected in 2015, should global liquidity conditions deteriorate, on the back of an earlier-than-anticipated or more aggressive-than-expected normalization of the Fed interest rate, and/or geopolitical risks (emanating from the middle-east and Russia-Ukraine) intensify.

Overall, our ability to foresee market conditions in the markets in which we operate remains constrained by risk factors and potential exogenous impulses, and therefore long-term targets continue to be surrounded by a significant degree of uncertainty.

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 financial instruments, whose contract amounts represent credit risk, as at December 31, 2013 and 2014:

Our contractual obligations as at December 31, 2014, can be summarized as follows:

See "Special Note Regarding Forward-Looking Statements" in the introduction to this Annual Report.

The Bank is managed by the Board of Directors, which is responsible for ensuring strategic direction, management supervision and adequate control of the Bank, with the ultimate goal of increasing the long-term value of the Bank and protecting the corporate interest at large, in compliance with the current legislation and regulatory framework, including the provisions of the 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 Shareholders for a term that cannot exceed three years and ends at the ordinary General Meeting of Shareholders of the year in which such term expires. All members are eligible for re-election. The General Meeting of Shareholders determines each time the exact number of the members of the Board of Directors (the Board of Directors may consist of a minimum of 9 up to a maximum of 15 members and must always be an odd number) and its independent members. One representative of the Greek government, as per Greek Law 3723/2008 and one representative of the HFSF, as per Greek Law 3864/2010, are members of the Board of Directors (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic's Bank Support Plan"). The Corporate Governance Code specifically defines the minimum number of executive, as well as independent and non-executive directors (see Item 10.B, "Additional information—Memorandum and Articles of Association" and Item 16.E, "Purchases of equity securities by the issuer and affiliated purchasers").

The General Meeting of Shareholders may, at any time, remove members of the Board of Directors. In the event that as a result of resignation, death or forfeiture for whatever reason a Director ceases to be on the Board, and his replacement by substitute Directors elected by the General Meeting is not feasible, the remaining Directors may either provisionally elect another Director to fill the vacancy for the remaining term of office of the Director replaced, or continue to manage and represent the Bank without replacing the missing Director(s), provided that the number of the remaining Directors shall be at least nine. In the event that a new Director is provisionally elected, the election 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 elected, even if no relevant item is included in the agenda. Under all circumstances, the remaining Directors, irrespective of number, may call a General Meeting solely for electing a new Board.

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 and Deputy Chief Executive Officer. The Chairman and the Chief Executive Officer may be the same person, and the same applies for the Vice Chairman and the Deputy Chief Executive Officers. However, the Bank, remaining abreast of international developments in corporate governance issues while continuously updating its corporate governance framework, distinguishes the role of the Chairman from 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 meets as required by Greek legislation, the Bank's Articles of Association and Corporate Governance Code, as well as the stipulations of the Relationship Framework Agreement

and the obligations of the Bank towards the Monitoring Trustee and is convened (a) by the Chairman, by means of an invitation to the Board at least three business days prior to the meeting (the invitation must clearly specify the items on the agenda, otherwise resolutions may not be adopted at the meeting unless all of the Board are present or represented and no director objects to such resolutions); or (b) by the Chairman or his substitute at the request of at least two directors, and within seven days of such request being filed with the Chairman or his substitute; or (c) by the Chairman at the request of the HFSF Representative and within seven days of such request being filed in writing with the Chairman and including the proposed items on the agenda. If the Chairman of the Board does not proceed, at the request of two Directors or the HFSF Representative, to the convocation of the Board within the above deadline (or does not include all the items proposed by the HFSF in the invitation) then the two Directors or the HFSF Representative, respectively, shall be entitled to convoke the Board within five days as at the expiry of the above seven days period. Such invitation shall be notified to all the members of the Board.

Any director may request that the Chairman includes one or more items on the next Board meeting agenda. Two or more directors may require the Chairman to include one or more items on the next Board meeting agenda. The HFSF representative can also include items on the agenda of a scheduled Board meeting and for this purpose, he shall send to the Chairman of the Board, in writing, the desired/additional items at least two working days prior to the date of the meeting. The Chairman of the Board must include these items in the agenda of the scheduled Board meeting.

The Board of Directors forms a quorum and validly deliberates when the absolute majority of the Directors is 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.

The Bank's Board is supported by competent Committees, which have been established and operate for this purpose (see Item 6.C, "Board Practices—Board Committees"), the operation of which is in accordance with legislation and the regulatory framework, including the provisions of the Relationship Framework Agreement between the Bank and the HFSF and the obligations of the Bank towards the Monitoring Trustee.

Moreover, pursuant to article 1 of Greek Law 3723/2008, article 10 of Greek Law 3864/2010, and the Relationship Framework Agreement with the HFSF, the representatives of the Greek Government and the HFSF can, inter alia, veto the decision making process of the Board in relation to dividend appropriation and remuneration of the Chairman of the Board and Board members, the Chief Executive Officer, the Deputy Chief Executive Officers as well as the General Managers and their substitutes. See also "Monitoring Trustee", below and Item 7., "Major Shareholders and Related Party Transactions", while further information may also be found in the Bank's Articles of Association and the NBG Group Corporate Governance Code, which are available on the Bank's website at https://www.nbg.gr/english/the-group/corporate-governance/regulations-principles.

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.

According to article 9.1.b of the Bank's Articles of Association, the General Meeting of Shareholders is the sole corporate body vested with the authority to elect the members and substitute members of the Board of Directors, as well as to determine the independent non-executive members. Exceptionally, the provisions of article 18.3 of the Bank's Articles of Association and pursuant to article 18.7 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 the appointment of the director replaced, or continue to manage and represent the Bank without replacing the missing director(s), provided that the number of the remaining directors shall be at least nine. Furthermore, according to Greek Company Law 2190/1920, any shareholder may propose a candidate for Board of Directors membership at the General Meeting of Shareholders and this right (that is to propose a candidate at the General Meeting) is also given to the Board of Directors. To this end, the Board of Directors, assisted by the Board of Directors' Corporate Governance and Nomination Committee, proposes to the General Meeting candidates for Board of Directors membership on the basis of the Director's Nomination Policy that requires them to meet specific qualifying criteria ("fit and proper"), according to the Bank's Corporate Governance Code. It is not required for the Board of Directors to submit a separate proposal for the positions of the Chairman of the Board of Directors and the Chief Executive Officer. Following the election of the new members of the Board of Directors by the General Meeting of Shareholders, the new Board of Directors in its inaugurating session elects, from its members, the Chairman of the Board of Directors and the Chief Executive Officer who manages the Bank. Moreover, the Board of Directors may elect Vice Chairman and Deputy Chief Executive

Officers. In discharging their nomination responsibilities and proposals to the General Meeting of Shareholders or in appointing new members in replacement of retired members, the Board of Directors proposes candidates to be appointed as Directors or replace members of the Board of Directors that have submitted their resignation, who possess a particular profile, in compliance with the NBG Directors' Nomination Policy and whose nomination ensures that the Board of Directors as a collective body presents the following profile:

The NBG Group Corporate Governance Code (as described below), as well as the Directors' Nomination Policy (as described below) provide for specific qualifying criteria ("fit and proper") for the nomination of candidates; professional capacities that are incompatible with the position of the Board of Director at NBG; criteria for non-executive directors' independence; and finally cases of conflicts of interest and maximum number of allowed other directorships of a Board member. All the above aim to ensure and the best composition for the Board of Directors of NBG.

Evaluation of the Chief Executive Officer, the Board of Directors and the Board Committees

The Board has a self evaluation system for assessing the effectiveness of its work and that of its committees, based on a methodology developed and approved by the Corporate Governance & Nominations Committee. Every three years, an in depth evaluation is carried out by an external consultant whose selection and oversight are the responsibility of the Corporate Governance & Nominations Committee. In 2014 the Board of Directors conducted an in-depth self-assessment through questionnaires and personal interviews, with the assistance of an external consulting firm, based on an evaluation methodology examined and proposed by the Board's Corporate Governance and Nomination Committee. The Board was informed of the results of its self-assessment procedure by the Chairman of the Board and the external consultant.

The Board of Directors develops a proposal on the remuneration of its members for the services they provide, which is submitted to the General Meeting. This proposal is formulated in line with the Bank's 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 promotes 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.

Moreover, pursuant to para. 3c, article 1 of Greek Law 3723/2008 and para. 3b, article 10 of Greek Law 3864/2010, the representatives of the Greek government and HFSF can, amongst others, veto the decision making process of the Board of Directors in relation to dividend appropriation and remuneration of the Chairman of the Board of Directors and Board members, the Chief Executive Officer, the Deputy Chief Executive Officer as well as the General Managers and Deputy General Managers. Under the terms of the Hellenic Republic Bank Support Plan, as currently applicable, the Bank is prohibited from paying bonuses to the members of the Board of Directors, the Chief Executive Officer, the Deputy Chief Executive Officer 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.

Regarding, specifically, the executive members of the Board of Directors, the Bank, as mentioned above, has adopted a Remuneration Policy for the determination of their compensation within the broader context of determining senior executives' remuneration so as to promote meritocracy and shape a performance based culture. Furthermore, Board remuneration is subject to the undertakings of the Bank to the Monitoring Trustee. In 2014 no variable remuneration was awarded to the Chairman and the executive members of the Board of Directors, while the remuneration of the non-executive Board members did not include bonuses, in accordance with the Remuneration Policy of the Bank.

New directors participate in an induction program/session provided by the Bank in which they are informed about risk management, financial management of the Bank's business plan, its key financial and accounting issues its compliance and corporate governance functions, its Code of Conduct, its management structure and executive officers, and its internal and external auditors. New directors are also provided with training documentation, which includes a description of their rights and responsibilities within the Bank. The induction program may also include visits to key branches of the Bank and its Group companies. The Bank develops professional training programs for all members of the Board so as to enhance the Board's supervisory capabilities; such programs/sessions fall within the framework of their ongoing training and updating in all the aforesaid matters related to the Bank's normal operations.

In July 2014, the Board was informed on the new obligations of Board members as per the provisions of Greek Law 4261/2014, which transposed Directive 2013/36 / EC (CRD IV), and Regulation (EU) 575/2013. Among others, article 91 of CRD IV, as of July 1, 2014 imposes a maximum number of directorships that may be held at the same time by each member of the Board of Directors (excluding the representative of the Greek government), while additional provisions on combinations of directorships and exceptions are also provided (e.g. holding more directorships within the same group, participating in Boards entities which do not pursue predominantly commercial objectives, authorization to hold additional directorship, etc).

The current Board of Directors, whose term expires on June 30, 2016, constituted into a body on March 23, 2015 and its members have been elected on the dates mentioned under 'Start of Term' in the table presented below. The current Board of Directors of the Bank is composed of four executive members, and nine non-executive members, of whom four members are independent in accordance with the provisions of Greek Law 3016/2002, and two are the Hellenic Republic's representative pursuant to Greek Law 3723/2008 and the terms of our participation in the Hellenic Republic Bank Support Plan and the HFSF's representative on the Bank's Board of Directors pursuant to Greek

Law 3864/2010, respectively. The quorum for a Board of Directors meeting is a majority of all Directors. Resolutions are adopted by majority vote of those present and those who have submitted proxies. Each Director has one vote but may also represent one other Director by proxy.

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 Katseli	Chair of the Board and non-executive member	March 23, 2015
Executive Members
Leonidas Fragkiadakis	Chief Executive Officer	March 23, 2015
Dimitrios Dimopoulos	Deputy Chief Executive Officer	June 26, 2014
Paul Mylonas	Deputy Chief Executive Officer	June 26, 2014
Paula Hadjisotiriou	Deputy Chief Executive Officer	June 26, 2014
Non-Executive Members
Efthymios C. Katsikas	Employees' representative	November 23, 2012
Stavros A. Koukos	Employees' representative, Chairman of Federation of Greek Banks Employees (OTOE)	November 23, 2012
Independent Non-Executive Members
Dimitrios N. Afendoulis	Economist	February 20, 2014
Spyridon J. Theodoropoulos	Chief Executive Officer, Chipita S.A.	November 23, 2012
Alexandra T. Papalexopoulou-Benopoulou	Member of the Board of Directors, TITAN Cement S.A.	November 23, 2012
Petros K. Sabatacakis	Economist	November 23, 2012
Hellenic Republic Representative
Angeliki Skandaliari	Economist	March 23, 2015
Hellenic Financial Stability Fund Representative
Charalampos A. Makkas	Economist	June 11, 2012

Pursuant to the Bank's participation in the Hellenic Republic Bank Support Plan for the liquidity of the Greek economy as per Greek Law 3723/2008, the Hellenic Republic has the right to participate in the Board of Directors through the appointment of a representative. Mr. Alexandros Makridis was appointed as the Hellenic Republic's representative on the Bank's Board of Directors on February 26, 2009 and in replacement Mrs. Angeliki Skandaliari, on March 4, 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, in the context of the recapitalization of Greek banks, the HFSF appointed on June 11, 2012 Mr. Charalampos Makkas as its representative in the Bank's Board of Directors. 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".

In the context of the recapitalization of Greek banks, the HFSF acquired 84.4% of the Bank's share capital, though its shares have restricted voting rights. Following the participation of the HFSF in the Bank's share capital, the Bank and the HFSF entered into the RFA in effect as at July 10, 2013 to govern their relationship.

Subject to the Relationship Framework Agreement, 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 (including business plans and budgets) 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 as a shareholder, the Hellenic Republic does not have other powers or control over the appointment of any other member of the Bank's Board of Directors.

In early 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 appointed by the Bank after being 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 Commission, the ECB and IMF staff. Grant Thornton was appointed as the Bank's Monitoring Trustee on January 16, 2013.

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—Restructuring Plan approved by the Directorate General for Competition on July 23, 2014".

These commitments were updated as part of the commitments the Bank undertook under its restructuring plan, which was approved by the European Commission on July 23, 2014. 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 oversees the Bank's compliance with such commitments and submits relevant reports to the Institutions on a quarterly basis (ad-hoc reports may also be submitted, if needed, at the request of Institutions). Following the submission of the report to the Institutions, the Monitoring Trustee will send a copy of the report to the HFSF, the Hellenic Republic (Ministry of Finance) and to the Bank. The Bank is currently not subject to further commitments towards the Directorate General of Competition, other than those discussed above.

The Bank is in compliance with its commitments, as reported by the Monitoring Trustee on a quarterly basis. According to the last report issued by the Monitoring Trustee and communicated to the Bank, there are no material deviations from the Bank's commitments.

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 T. Katseli, born 1952, is, from March 23, 2015 the Chair of the Board of Directors of the National Bank of Greece and the Chair of the Hellenic Bank 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). She is member of the Steering Committee of the European Association of Development Research and Training Institutes (E.A.D.I.) since 2005 and a member of the Euro 50 Group since 2000. 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). 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 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, was on March 23, 2015 appointed as the Chief Executive Officer of the National Bank of Greece. He is a member of the Board of Directors of NBG Securities and the Chairman of the Hellenic Chapter of Forex Club/ACI. He is a member of the Committee of Primary Dealers Supervision & Control. Moreover, he is a member of ALCO. He obtained his Bachelor's Degree in Economics from Trinity College, Cambridge University and his MBA from the Wharton School of the University of Pennsylvania. Prior to joining the Bank, he was employed by Credit Suisse First Boston, New York.

Dimitrios G. Dimopoulos, born 1947, was elected Executive Member of the Board of Directors and Deputy Chief Executive Officer of the NBG in June 2014. As Deputy CEO he's responsible for the Corporate, Investment and Retail Banking areas of the bank. He's also Member of the Executive Committee.

He joined NBG in 1975 in the Large Corporate Division and has mainly been involved in corporate financing as well as project financing of investments in infrastructure, energy and tourism sectors.

He is, also, Chairman of the Board of Directors of Ethniki Insurance Co and member of the Board of Directors of NBG Securities S.A., Astir Palace Vouliagmeni S.A., Ethniki Leasing S.A. and Ethniki Factors S.A., as well as the permanent representative of the Bank at the Board of Directors of the Athens Chamber of Commerce and Industry.

Dimitrios Dimopoulos 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 CEO of NBG Group in June 2014 and Chief Risk Officer in December 2013. He is a Member of the Senior 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 Vojvodjanska Banka, non-executive Chairman of the Board of Directors of NBG Cyprus Ltd and serves on the Boards of Directors of: Finansbank, Astir Palace, NBG Asset Management, NBG Securities and UBB. 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 NBG 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). Mr. Mylonas holds a Master of Arts and PhD from Princeton University and a BSc from Brown University.

Paula Hadjisotiriou, born 1957, is Deputy CEO and Group Chief Financial Officer at National Bank of Greece since June 2014. Until then, since July 2013, she was Group Chief Financial Officer responsible for Strategy, Group Financial Services, Group Taxation, Management Information Systems and Treasury Back Office.

During the period 1990 - 2013, she worked in Eurobank Group, where she held the position of General Manager Finance & Strategy—Group Chief Financial Officer and she was a member of Executive Committee, Strategy Planning Group and Board Secretary. She has served as Deputy General Manager and Chief Financial Officer (Eurobank), Head of Finance and Control and Head of Internal Audit (Euromerchant Bank), Deputy General Manager of Internal Audit (John S. Latsis Group of Companies), Senior Auditor (Price Waterhouse & Co., Pannel Fitzpatrick & Co.).

Mrs Hadjisotiriou is a Chartered Accountant and a member of the Institute of Chartered Accountants of England and Wales (ICAEW).

Dr. Omer A. Aras, born 1954, is Chairman and Executive Member of Finansbank A.Ş. and Chief Executive Officer of the Finansbank Group. Dr. Aras graduated from the Academy of Economic and Commercial Sciences, Department of Economics, in 1975. He received an MBA in 1978 and a PhD in Business Administration in 1981 from Syracuse University. Over the next three years, he was a faculty member at the Business Administration Department of Ohio State University. Between 1984 and 1987, he served as Credit Marketing Manager and Credit Committee Member at Citibank, and worked as the Head of Yapı Kredi Securities. Dr. Aras participated in the founding of Finansbank in 1987, and served as an Assistant General Manager for two years and as the General Manager for six years and as an Executive Board Member of Finansbank and Vice Chairman of Fiba Holding from 1989 to 2006. Between 2003 and 2007 he held the Board Member position in TUSIAD (Turkish Industrialists' Businessmen's Association). Dr. Aras served as Vice Chairman of Finansbank A.Ş. and Group CEO of Finansbank Group of Financial Companies (Finans Leasing, Finans Invest and Finans Portfolio Asset Management) between November 2006 and April 2010. Dr. Aras was appointed as Chairman of the Board of Directors in April 2010. He is also the Chairman of Cigna Finans Pension, Member of the High Advisory Council of TUSIAD and Member to Board of Trustees of Özyeğin University

Spiridon Mavrogalos, born 1968, was appointed CEO of EH in October 2013. He is also member of the Board of Directors of Europe Insurance Co S.A., National Insurance Brokers S.A., Ethnodata S.A., Ethniki Insurance (Cyprus) Ltd, Garanta S.A., UBB AIG & UBB MET LIFE and Stopanska Banka. He held the position of Deputy General Manager of Group Procurement and Administrative Support in the Bank from February 2008 to September 2013. He is a certified chartered accountant (ACCA) and holds an MBA in Finance from the University of Nottingham and a BSc in Computer Information Systems from Deree College. Before joining the Bank he served as General Manager of Group Operations in Cosmote Group. He has also worked for six years in Eurobank in their Integration Office, Risk Management and Internal Audit divisions, as well as at ABN Amro Bank N.V. and at KPMG.

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. He joined UBB in 1993 after serving in several managerial positions at the Bulgarian National Bank. He is also a Chairman of the of the Boards of Directors of Interlease A.D., Interlease Auto A.D. and a member of the Boards of Directors of UBB Insurance Broker EOOD and Bankservice Borika A.D. Mr. Vatev is the Chairman of the Management Boards of UBB—MetLife Life Insurance Company A.D. and UBB—AIG Insurance Company A.D. 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 Greek Economic Chamber and the Institute of Chartered Accountants.

Cenk Kahraman, 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:

Miltiadis Stathopoulos, born 1944, was appointed General Counsel at National Bank of Greece in February 2010, while in July 2012 he was also appointed General Manager of Corporate Governance. He is a Member of the Bank's Executive Committee and attends the meetings of the Board as legal counsel. Mr. Stathopoulos is a member of the Legal Committee of the Hellenic Bank Association and a founding member of the Banking and Stock Exchange Law Society, on the committee of which he also serves. From February 2013 he is a member of the Council of National Bequests. He is also Vice Chairman of the Boards of Directors of Ektenepol and NBG Bancassurance and member of the Board of Directors of Larco, Astir Palace S.A. and EH. He participates in NBG's Legal Council, all the Board Committees (Corporate Governance & Nominations, Human Resources & Remuneration, Risk Management, Strategy and Audit), the Bank's Credit Committees, its Supreme Disciplinary Council and its Procurements Committee. In addition, he is Vice Chairman of the Crisis Management Committee and the Disclosure & Transparency Committee, as well as Chairman of the AML/CFT Committee. From 1998 to 2010 he was Director of Legal Services at National Bank of Greece. In 1995 he was appointed Director of Legal Services at National Mortgage Bank until 1998 when National Mortgage Bank merged with NBG. For a number of years he was Vice Chairman and Board member of the brokerage firm DELPHI. He has been a lawyer since 1970 and has published in leading law journals. Mr. Stathopoulos holds a Bachelor's degree from the Law School of the Aristotle University of Thessaloniki.

Nelly Tzakou-Lambropoulou, born 1962, is General Manager of Retail Banking at National Bank of Greece 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 NBGB, Vice Chairman of the Board of Directors at DIAS S.A. (Greek ACH) and NBG Securities and a member of the Board of Directors of the Athens Chamber of Commerce and Industry, Ethnodata and Ethniki Factors. Moreover, she is a member of the Euro Banking Association (EBA—Paris) and SEPA High Level Meeting (ECB), a council member of EFMA Operational Excellence Advisory

Council, as well as a BoD member of "Junior Achievement Greece". Before joining the Bank, Mrs. Tzakou worked at Eurobank between 1990 and 2007, where she held the position of General Manager, responsible for Group Operations and the Global Transaction Services business unit. Mrs. Tzakou holds a Bachelor's Degree in Economics from the University of Piraeus and an MBA from the University of Wales & Manchester Business School.

Damianos Charalampidis, born 1964, was appointed Group Chief Operating Officer at National Bank of Greece in September 2012. He is a member of the Senior Executive Committee and he is Chairman of the Group Project Approval, the IT Steering and the Procurement Committees. Moreover, among others, he is Member of Crisis Management and Advertising Committees. He has more than 20 years of experience in the field of telecommunications, 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 Greece. 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 (a subsidiary of Deutsche Telecom) 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. (a telecom equipment manufacturer) in the division of Research & Development and Marketing and Sales later. From 2003 2010, Mr. Charalampidis served as the Chairman of the Greek section of IET (Institute of Electrical and Technical Engineers) of which he is still a Member of the Board of Directors. Throughout his career he has been a Board of Directors Member on various companies like OTENET (ISP provider), Tellas (fixed line operator), Zelitron (M2M solution provider). Currently, he is Chairman of PAEGAE (3PL Logistics Company), Member of PANGAEA (Real Estate Investment Company) Investment Committee, as well as a Board of Directors Member in Ethnodata (IT service provider) and 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).

Panos Goutakis, born 1958, is a General Manager of NBG, responsible for Investment Banking and concurrently Chairman and CEO of NBG Securities. Before joining NBG Securities, he was Advisor to the CEO of Piraeus Bank, responsible for strategic planning. Between 1990 and 2009 he served as Managing Director of Morgan Stanley & Co Ltd., Country Head of Greece. Mr. Goutakis holds an MBA from the University of Rochester and a Bachelor's Degree in Business Administration from the Athens University of Economics and Business.

Telemachos Palaiologos, born 1950, was appointed General Manager of Procurement & Security at NBG Group in September 2013; since December 2010 he was Assistant General Manager of Security of NBG. He is Chairman of the Board of Directors of Ethniki Leasing and a member of the Board of Directors of EH. In addition, he is a member of the Senior Purchasing Committee of the Group and the Crisis Management Committee. From May 2010 until December 2010 he served as Assistant General Manager responsible for the Board of Directors Secretariat and Shareholder Services and the Management Office. During the period 1999-2009 he served as General Director and CEO at Ethniki Leasing S.A. From December 1993 until March 2002 he was a member of the Board of Directors of Ethniki Kefalaiou S.A. Before joining the NBG Group he worked as chief executive in leading organizations and enterprises. Mr. Palaiologos holds a Bachelor's degree in Economics from the National and Kapodistrian University of Athens. He also holds Master's degrees in Development Economics from the University of Bath and in Business Administration from the University of Birmingham.

Theofanis Panagiotopoulos, born 1955, was appointed General Manager of Corporate Branches of NBG in September 2013, following his years as Deputy General Manager of Corporate Banking in NBG, a position he has held since May 2008. He was a member of the Board of Directors of NBG Securities S.A. since September 2012 and was appointed Deputy CEO of the company in September 2013. He is a member of the Board of Directors of the companies Ethniki Leasing and NBG Factors.

During the period 2002-2008, he was Director of Commercial Lending at the bank, running four Business Centers. From 2000 until 2002 he was Head of the Business Center for Commercial Companies, while between 1998 and 2000 he was Head of the Center for Small Medium Enterprises. He joined National Bank of Greece in 1973 and has worked in the field of corporate lending in several positions in the bank's branches. Th. Panagiotopoulos holds a bachelor's degree in Business Administration from the University of Piraeus and has attended business education seminars mainly in Banking Operations field.

Marianna Politopoulou, born 1969, has been the General Manager of Group Retail Collections of NBG since July 2010. She is a member of the Risk Management Council and of several Committees such as the Delinquency Monitoring, the New Products', the Retail Restructuring, the Operational Risk, the Crisis Management and the Group Project Approval. She has been extensively involved in the fields of general management, finance and strategy for banks and corporations in Greece and abroad. Before joining the Bank, she held senior positions including Head of e Banking/Private Banking at Credit Agricole Luxembourg, General Manager at Eurolease and CEO at Eurobank FPS. She holds a MSc in Civil Engineering from the National Technical University of Athens with distinction and an MBA in Finance from the Wharton School, University of Pennsylvania.

Marinis S. Stratopoulos, born 1964, was appointed General Manager of International Activities in April 2014. He has also been appointed as the Chairman of the Board of Directors of Banca Romaneasca, the Chairman of the Board of Directors of NBG Leasing IFN, as Deputy Chairman of the Board of Directors of National Bank of Greece (Cyprus) Ltd, as member of the Board of Directors of United Bulgarian Bank AD and he is elected as Deputy Chairman of Hellenic-Romanian Bilateral Chamber of Commerce. He started his career in banking in 1993 in Xiosbank and then served in several managerial positions in Piraeus Bank Group, Egnatia Bank Romania, Egnatia Bank, National Bank of Greece a.d. Beograd and as President of the Executive Board of Vojvodjanska since 2007. He also served as the Chief Executive Officer and Deputy Chairman of the Board of Directors of Banca Romaneasca since August 2010. In parallel to his banking career, he worked from 1993 to 2000 as a part time instructor in Accounting, Mathematics of Finance, Business Administration and Business Finance at the American College of Greece. He holds a Deck Officer Diploma from the Merchant Marine, a BSc in Business Administration from the American College of Greece and an MSc in Finance from the University of Lancaster.

Petros Fourtounis, born 1955, former Group Chief Audit Executive at NBG since July 2010, has been appointed General Manager of Corporate Special Assets of the Bank in January 2014. He is a member of the Economic Chamber of Greece and the Institute of Internal Auditors (IIA). He has been extensively involved in the fields of audit, corporate—project financing and international credit. From August 2002 to July 2010, he held the position of Director in the NBG Divisions of Corporate Banking, Structured and International Finance and Group International Credit. During 1984 1999, he worked as Internal Auditor of the Bank. He joined NBG in 1975. He has been a member of the Board of Directors or Executive Credit Committees of several NBG subsidiaries and he was actively involved in the due diligence procedures of foreign bank acquisitions by NBG. Mr. Fourtounis 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 in Greece. He also headed 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 the Chairman of the Board of Directors of Ethnodata and member of the Board of Directors of Banca Romaneasca. Mr Christodoulou 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.

Anthony Antonopoulos, born 1955, was appointed Deputy General Manager of Group Human Resources of NBG in December 2012. From 2008 to 2012 he held the position of Director and Section Head of the Division of Centralized Operations of the Bank. From 2002 to 2008 he served as Bank's Regional Branch Director for the Peloponnese area. Since he was first employed by the Bank in 1973, he has worked in many branches as Deputy Manager and Manager. He is a graduate of the Thessaloniki University of Economics and he has participated in many training seminars on a wide variety of banking related issues.

Constantinos Vossikas, born 1968, was appointed Deputy General Manager and Chief Credit Risk Officer of NBG in December 2013. 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. He is a member of the Senior Credit Committee and Risk Management Council. He has been a member of Supervisory Boards of NBG Group International Subsidiaries and NBG Executive 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.

Nikolaos Voutychtis, born 1970, was appointed Assistant General Manager of Group Finance (Deputy Group CFO) at National Bank of Greece in August 2014. He joined the Bank in 2010 as Deputy Country Manager (CFO and COO) in NBG Egypt. He is a member of Disclosure and Transparency Committee, Crisis Management Committee, Stress Test Committee, NPLs Management Committee, New Products Committee, Procurement Committee, Strategic Infrastructure and IT Projects Committee. Prior to NBG, he served as CFO in T Bank (former Aspis Bank). During the period from 2005 to 2008, he held the position of Head of Group Accounting Policy Division in Eurobank EFG. From 1997 to 2005, he worked for PricewaterhouseCoopers as Financial Services Senior Manager supervising various audit and consultancy projects in the banking sector. N.Voutychtis is a Certified Chartered Accountant (ACCA) and holds an MSc. in International Banking and Financial Services from University of Reading, UK and a BSc. (Hons) in Business and Management from University of Bradford, UK.

Panagiotis Georgiou, born 1956, was appointed Deputy General Manager responsible for the NBG Branch Network in December 2012. Since April 2013, he is also an elected member of the Ethniki Insurance co (a subsidiary of NBG) and a Chairman of its Audit Committee.

He is a participant in various Committees of the Bank (Security, Crisis Management, Branch Classification, Management of Account for Assistance of the Personnel of NBG etc.). He is also a member of the Board of Directors of the NBG Training Center, of the Board of Nomination and of the Promotion and Transfer Board. He holds the Certified Fraud Examiner (CFE) accreditation and the Certification in Risk Management Assurance (CRMA) and he is a member of the Association of Certified Fraud Examiners (ACFE) and the Institute of Internal Auditors (IIA). In 2011 he was elected as President of the Hellenic Association of Certified Fraud Examiners. He is also a member of the Economic Chamber of Athens.

Mr. Georgiou has worked for the NBG Group since 1973 and during his career he has held several different positions, both in the Branch Network and Head Offices, at all levels of the Bank's hierarchy. He has extensive experience in all aspects of Internal Audit, but his expertise lies primarily in Fraud Investigations and Special Audits. He also designed and implemented the NBG Fraud Awareness Training Program aiming to promote a zero tolerance culture to Fraud at the NBG Group.

He holds a Bachelor's degree in Business Administration and Master's degree in Banking from the Hellenic Open University. He is also a member of the Scientific Committee for the "Postgraduate Level Program in Internal Audit" of National and Kapodistrian University of Athens.

Panos Dasmanoglou, born 1963, was appointed Deputy General Manager—Group Chief Compliance Officer in September 2013,was elected Secretary of the Bank's Board of Directors and of its Committees in January 2014 and since December 2014 is also responsible for corporate governance activities. Since he joined NBG Group in 1990, he handled, through various positions as a lawyer in the Bank, significant issues regarding the integration of European banking legislation in the Bank's processes, domestic and international credit operations, and M&A activity; and in 2009, he was appointed Head of the Group Compliance Division responsible for the Group's compliance with the legislative and regulatory framework. He is a member of the Disclosure and Transparency Committee, the I.T. Steering Committee, the AML/CFT Committee, the Compliance and Reputational Risk Committee, the Operational Risk Management Committee, the New Product Committee, as well as the Crisis Management Committee of the Bank. Additionally, Mr. Dasmanoglou is Vice Chairman of the Board of Directors at NBG Asset Management and serves on the Boards of Directors of NBG Securities and Ethniki Factors. Furthermore, he is also a member of the Board of Directors of the Hellenic Ombudsman for Banking and Investment Services. Mr. Dasmanoglou holds a BA from the Law School of the University of Athens and a Master's degree in European Law from the University of Brussels, as well as international certifications in international banking law, compliance and banking management (Inter Alpha Banking Management Program—Module I & II, INSEAD Graduate Business School).

Andreas Exarhos, born 1954, was appointed Deputy General Manager, Retail Collections in September 2013. He holds a degree in Business Administration from Athens University of Economics and Business and has participated in many seminars held in Greece and at overseas Universities, such as City University and INSEAD. Mr. Exarhos joined the Bank in March 1978. He has worked and served as Manager in several full banking branches and given presentations on trade finance in various seminars held by the National Bank of Greece and the Hellenic Bank Association.

Georgios Kaloritis, born 1964, was appointed Assistant General Manager and Chief Audit Executive of the Group in January 2014. He joined National Bank of Greece in 2006 as a Director of Internal Audit responsible for the areas of operations, compliance, information systems and several other support functions of the NBG Group. He was in charge of the project team responsible for the integration of NBG 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 NBG Group he served as the Corporate Security Officer at Eurobank (2003-2006) and as a Partner responsible for the Enterprise Risk Services at Deloitte Greece (1996-2003). He started his career in the United States of America where he served at various managerial positions at Price Waterhouse and AT&T (1990-1996). He holds an MBA degree in Executive Management from Saint John's University of New York, an MA in Management Information Systems and a BA Degree 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). He is currently the President of the Board of the Hellenic Chapter of the Institute of Internal Auditors and he also served as the Vice President of the Hellenic Chapter of the Information Systems Audit and Control Association (2002-2004).

Dimitrios Kapotopoulos, born 1951, was appointed Deputy General Manager of Troubled Assets Strategy Unit NBG in February 2014. Mr. Kapotopoulos, joined NBG in 1978, at the Branch Network. From 1982 until 1992, he served as credit analyst and played a constructive role in setting up the Large Corporate Division of NBG in 1993, for which he was appointed as Deputy Director in May 2008. He has been Director of Structured and International Finance Division of NBG since October 2010. Prior to joining NBG, he held financial positions in commercial enterprises. Mr Kapotopoulos holds a Bachelor's Degree in Economics from the Aristotle University of Thessaloniki.

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.

Angelos Katsikas, born 1956, was appointed Deputy General Manager of Business Processes in NBG, in December 2012. He is a member of the following Management Committees: Crisis Management Committee; I.T. Steering Committee; Group Processes; IT & Technical Projects Portfolio Approval Committee; Group Security Committee; Anti-money Laundering & Counter-Terrorism Financing Committee.

He joined NBG in 1975 after starting his career at Branch network in various positions in the Divisions of Business Processes, Branch Network, HR and Housing Loans. From 2006 until December 2012, he was NPL Division's Head of the Corporate Banking Section. He holds a Bachelor's Degree in Economics from the National and Kapodistrian University of Athens, a Master's Degree from the Hellenic National Defense College and he is a member of the Economic Chamber of Greece.

Dimitrios Kolimanis, born 1955, was appointed as an Assistant General Manager of Special Assets Unit at National Bank of Greece in May 2014. During the period August 2013 to April 2014 he worked for the incorporation of Probank into NBG and the establishment of Special Assets Unit. From 2001 until 2013, he held the following positions in Probank: General Manager, Executive Member of Board of Directors as well as member of the Audit Committee, the Assets and Liabilities Management Committee (ALCO) and the Credit Committee. During the same period, he was President and Chief Executive Officer of Probank's subsidiaries that are specialized in Mutual Funds, Leasing & Financial Services. During the period 1981 - 2001 he worked in Ergo Bank as an Executive Staff in the fields of Treasury, Financial Services, Investment Banking and Internal Audit. From 2000 to 2001 he worked as a Chief Accountant in a Commercial Company. Dimitrios Kolimanis has graduated from Athens University of Economics and Business and he is accountant with A class statutory signing rights.

George Koutsoudakis, born 1965, was appointed Deputy General Manager of Corporate Banking in NBG in January 2014. Just before joining NBG 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 2007-2012 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 2002-2007 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 (Group of NBG) 1996 2001 and Alpha Finance (Group of Alpha Bank) 1990-1996. He has held various positions on Boards of

Directors, while currently he is non executive member on the Board of Directors of the Finans, Probank Leasing, Ethniki Factors & Apivita. Mr. Koutsoudakis holds a BSc Economics Honors Degree.

George Maligiannis, born 1961, was appointed Deputy General Manager of Household Lending in NBG in July 2013; he is responsible for Mortgage Credit, Consumer Finance and Credit Cards. Since November 2011, he held the position of the Director of Mortgage Credit Division of NBG. He has been with NBG since 1999 and has more than 30 years of banking experience. Before joining NBG Group, he worked for the Mortgage Bank of Greece in the IT Department, in the branch network and from 1989 to 1998 as a manager in the Vancouver Representative Office in Canada. Mr. Maligiannis 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.

Vassilis Mitrakos, born 1952, was appointed Deputy General Manager responsible for matters of Social Security for the Insurance Fund in NBG in December 2012. Since July 2009 he has been serving as the acting Director of the Insurance Fund of National Bank of Greece Personnel. From June 2004 to July 2009 he was responsible for matters of Public Relations of the Bank. Between the years 2001 and 2006 he served as the Vice Chairman of the Mutual Health Fund of National Bank of Greece Personnel (T.Y.P.E.T.). Between the years 2004 and 2007 he served as a Board member of the Onassis Cardiac Surgery Center (O.C.S.C.). He has also served as a member of the Administration of the Greek Chamber of Economics, a Board member of the Federation of Greek Mutualities (O.A.T.Y.E.) as well as a member of the Parnassus Literary Society. Since he joined the Bank in 1978 he has worked in various positions in both the Branch Network and Administration. He holds a bachelor's degree in Business Administration from the University of Piraeus and a master's degree (MSc) in Management from the National School of Public Health. He has also participated in many training seminars on Banking and Social Security.

Alexandros Benos, born 1966, was appointed Deputy General Manager for NBG Group Risk Management in September 2013. Since 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 NBG Group. He serves on the Board of Directors of NBG Asset Management M.F.M.C. He is a member of the ALCO of Ethniki Asfalistiki Insurance Co and a member of the Board Risk Committee of UBB. He previously held academic positions in the US, France, Switzerland and Greece, and he continues to serve as a Visiting Professor at the Ecole des Hautes Etudes Commerciales in Paris. Dr. Benos holds a PhD in Finance from the Graduate Business School of Stanford University and a BA and MA degrees in Economics from Cambridge University. He published at major international refereed journals and is a frequent speaker in Risk Management conferences.

Konstantinos Bratos, born 1956, was appointed Deputy General Manager of International Activities in NBG in December 2013, having served as a manager of this Division since April 2012. Mr. Bratos has been the Chairman of NBG Malta Holdings Ltd and NBG Bank Malta Ltd since 2009, of Banka NBG Albania since 2012 and Chairman of the Supervisory Board of NBG Egypt and Stopanska Banka since 2012. He is also Deputy Chairman of the Board of Directors of Banca Romaneasca and Vojvodjanska and 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 NBG. 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 NBG 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 NBG which he joined in 1975 and until 1984 he worked in the branch network of the Bank. Mr. Bratos 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).

George Frangou, born 1964, was appointed Deputy General Manager of Group Real Estate in NBG in February 2014. He possesses long standing experience in Financial Services and FMCG sectors through key positions in Real Estate, Operations and Finance. Before joining NBG, he has held senior positions within Eurobank Group, including Head of Real Estate with participation in numerous Boards of Directors, has been member of the Executive Committee of Johnson & Johnson Hellas and has held Finance positions in Diageo (Grand Metropolitan/Metaxa S.A.). Mr. Frangou holds a degree (BSc) in economics from Athens Economic University and a master's degree in Business Administration (MBA) from California State University, Bakersfield.

During 2014, 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 17 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 directed by the requirements of the EU framework, Greek legislation (namely the provisions of Greek Law 4261/2014, Greek Law 3016/2002, the decision of the Board of Directors of the HCMC no 5/204/2000, as currently applicable, Greek Law 3693/2008 and Greek Law 3873/2010), the decrees of the HCMC and the Bank's Articles of Association as well as by the stipulations of the Relationship Framework Agreement between the Bank and the HFSF, and the obligations of the Bank towards the Monitoring Trustee. The Bank, being listed on the NYSE, is also subject to the U.S. legal and regulatory framework (Sarbanes Oxley Act), the US Securities and Exchange Commission ("SEC") rules and the NYSE regulations.

In February 2006, the Bank's 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 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 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. In December 2014, the Bank updated its Corporate Governance Code with a view to incorporate the recent changes in the regulatory framework (especially Greek Law 4261/2014, which transposed CRD IV into Greek law), to further adopt international best practices, such as the Senior Independent Director, as well as to better reflect the Bank's organizational structure.

The Bank has adopted the Corporate Governance Code and provides explanations for any exceptions identified in accordance with the "comply or explain" principle of the above mentioned laws.

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 Director's 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 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.

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 is available on the Bank's website www.nbg.gr (section: The Group/Corporate Governance/Regulations & Principles).

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 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 aims at further enhancing 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 Remuneration Policy was adopted by the Board, following the recommendation of the Board's Human Resources and Remuneration Committee (the "HRRC"), in accordance with the provisions of Bank of Greece Governor's Act 2650/January 19, 2012. The Remuneration Policy is consistent with the Bank's business strategy, risk profile and risk appetite and does not encourage excessive and short-term risk taking. The Policy is also in accordance with the recommendations of European statutory bodies and international best practices, and it is consistent with Greek Laws 3723/2008 and 3864/2010, the Relationship Framework Agreement between the Bank and the HFSF and the Bank's obligations towards the Monitoring Trustee. In any case, the remuneration of the Chairman, the 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. No additional remuneration (including bonus) of the aforementioned persons is permitted for the period during which the Bank participates in the Recapitalization Plan of Greek Law 3864/2010. 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 new Commitments towards the Bank's Monitoring Trustee.

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 Policy that reflects the keystones of the CSR framework, determines the CSR Action framework for the Bank and the Group and provides guidelines to NBG and its subsidiaries for the delegation of authorities and responsibilities for the planning, implementation and control of these Actions.

The CSR policy is posted on the Bank's website, at www.nbg.gr (section: The Group/Corporate Social Responsibility/CSR framework).

In compliance with the provisions of the Corporate Governance Code, the Bank has entered into a multi insurance contract in order to cover the civil liability of the Directors and Executives of all the Group entities, the civil liability for claims against the Bank and its subsidiaries arising from negligence, error or oversight by Executives and employees, and damages arising from fraud, including electronic fraud.

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 (Mr. 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 current Audit Committee members were elected, as per the requirements of Greek Law 3693/2008, by the Annual General Meeting of Shareholders on June 26, 2014, following the consent of the Corporate Governance & Nominations Committee and the Board. The Committee's term of office was set for one year.

In 2014, the Audit Committee convened fourteen times. During the course of the year, the Committee appointed the new Chief Internal Auditor, evaluated and submitted to the Board for approval the new NBG Group Policy on Connected Borrowers, and updated and approved the Charter of the NBG Group Internal Audit Division, in accordance with the new Basel Committee and IIA standards. In addition, the Committee reviewed the quarterly and annual financial statements of the Bank and its Group, monitored on a quarterly basis and evaluated on an annual basis the operations of the NBG Group Internal Audit Division and the NBG Group Compliance Division, and assessed the

adequacy of the internal audit systems in line with Bank of Greece Governor's Act No. 2577/2006, carried out the external auditor selection process for the Bank and its Group, ensuring the independence, objectivity and effectiveness of its operation, and submitted to the Board the proposal for the appointment of the external auditor to be elected by the General Meeting. In addition, the Committee was updated on a regular basis regarding the scope of evaluation and progress of work in the framework of the Bank's compliance with the legal requirements of Sarbanes Oxley Act (articles 404 and 302), the progress in the organization and IT projects of the Group, the Conflict of Interest Policy for Senior Executives of the Bank, the governance of compliance risk, and the Whistle Blowing Policy of the Bank and the Group. Finally, the Committee prepared on a quarterly and annual basis performance reports, in line with the approved monthly rolling agenda of the Committee for 2014.

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).

On March 23, 2015, Mr. Stefanos Vavalidis resigned as member of the Board's Audit Committee. On June 26, 2014, Mr. Alexandros N. Makridis resigned as member of the Board's Audit Committee.

The Committee members receive remuneration for their participation in the Committee.

In 2014, the HRRC convened seven times. The Committee reviewed the HRRC 's charter with regard to the new Greek Law 4261/2014 (CRD IV). The updated charter was approved by the Board on December 18, 2014. The Committee is composed exclusively of non executive Board members, at least three in number, of which half are independent members of the Board, in accordance with the definition of independence specified in the Bank's Corporate Governance Code. In 2014, among others, the HRRC approved the Board of Directors and Committees members' remuneration for the fiscal year 2013 and set the remuneration of the Chairman, the CEO, Deputy CEOs and of the non executive members of the Board until the General Meeting of 2015. Lastly, among others, the HRRC dealt with the contracts, 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 which are appointed by the Board. All members are non executive, of which the majority are independent members of the Board, in accordance with the definition of independence specified in the Bank's Corporate Governance Code. In 2014, the CGNC convened six times. The Committee updated its charter in order to incorporate provisions of the new Greek Law 4261/2014 (which transposed into Greek law the new EU Directive 2013/36 (CRD IV)). The updated Charter was approved by the Board on December 18, 2014. During the course of the year, the CGNC worked on the implementation and alignment of the Bank with the recent changes in the regulatory framework particularly regarding corporate governance issues and international corporate governance best practices, among others by updating the Bank's Corporate Governance Code, the Director's Nomination Policy and the Board evaluation procedure, reappointing members of Board Committees and evaluating the methodology for measuring Board performance and effectiveness. In addition, the CGNC was updated regarding the new regulatory framework introduced by Greek Law 4261/2014 (CRD IV), as well as regarding the obligations of Board members according to Greek Law 4261/2014.

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).

Mr. Ioannis Giannidis resigned as member of the Board and its Corporate Governance and Nomination Committee on February 20, 2014.

Mrs. Maria (Marily) A. Frangista resigned as member of the Board and the Board's Corporate Governance and Nominations Committee on June 26, 2014.

On June 26, 2014, Mr. Alexandros N. Makridis resigned as member of the Board's Corporate Governance and Nomination Committee.

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.

In 2014, the Board Risk Committee convened twelve times. In 2014, the Committee was informed in detail on a regular basis and consulted concerning the risk appetite of the Bank, reviewed the Risk Management Annual Report 2013 and gave relevant information to the Board of Directors. Furthermore, the Committee updated the Corporate Credit Policy, received and assessed significant methodologies which fall within its scope of work, such as the Risk Appetite Framework, and advised on important decisions that affect the Bank's business plan under its risk appetite. The Committee is 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 & Nominations Committee.

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).

On June 26, 2014 the Chairman of the Board Risk Committee Mr. Panagiotis-Aristeides Thomopoulos resigned as member of the Board and Mr. Stefanos C. Vavalidis was elected Chairman of the Board Risk Committee. On March 23, 2015 Mr. Stefanos Vavalidis, resigned as independent non-executive director. Further, on April 30, 2015 Mr Petros Christodoulou, resigned as independent non-executive director.

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).

In 2014, the Strategy Committee convened seven times. During the course of the year, the Committee examined the strategic restructuring of the Bank and the Group, including the Capital Plan which was submitted to the Single Supervisory Mechanism (SSM) within the context of the Comprehensive Assessment, strategic decision making regarding NBG Group companies and the 2014

Budget. Finally, the Committee evaluated and submitted to the Board for approval the NBG Group Restructuring Plan, which was submitted to the DGComp.

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).

Mr. Stefanos Vavalidis, resigned as independent non-executive director on March 23, 2015.

Mr. Dimitrios Dimopoulos, Mr. Paul Mylonas and Mrs. Paula Hadjisotiriou were appointed as members of the Board's Strategy Committee at the meeting of the Board of Directors held on June 26, 2014.

Further, on April 30, 2015 Mr Petros Christodoulou, resigned as independent non-executive director.

The Committee members receive remuneration for their participation in the Committee.

The Senior Executive Committee was established in 2004 and 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.

Also, Mr. Omer Aras, Chairman and Group Chief Executive Officer of Finansbank, is invited every two months so as to inform the 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 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 General Counsel & General Manager of Corporate Governance is also present at the meetings of the Executive Credit Committee.

The Committee members do not receive any remuneration for their participation in the Committee.

The Disclosure and Transparency Committee was established in 2003 in order to be aligned with the U.S. legal requirements for the financial markets. Its purpose is to monitor the accuracy and completeness of the information included in public announcements and in any publications issued by the Bank to the SEC.

The Committee is convened at the invitation of its Chairman, at least twice per annum and ad hoc as deemed 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 Bank claims of any nature, which are considered by the Committee to be liable of a loss in value.

The Committee members do not receive any remuneration for their participation in the Committee.

The Council was established in 2013 and is responsible for overseeing and managing all risks. It is also responsible for the establishment of policies relating to credit risk, market risk, operational risk and reputational risk and to comply with these policies. The Risk Management Council also determines the overall risk management framework.

The General Manager of Treasury & Global Markets and the General Counsel & General Manager of Corporate Governance attend the meetings as observers.

The Committee members do not receive any remuneration for their participation in the Committee.

The Crisis Management Committee was established in 2012. Through the Crisis Management Committee, the Bank aims to effectively coordinate the actions necessary to deal with unforeseen situations which may jeopardize the smooth operation of the Bank; inform, mobilize and coordinate the Bank's relevant units, taking into account the nature, extent and the size of the crisis; and solve problems that require immediate attention.

Following a decision by the Committee Chairman, depending on the subject in each case, further executives of the Bank may be invited to attend the Committee. Additionally the Chief Internal Auditor is informed so as to determine whether he should attend the Committee meeting or not.

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 Chairman can invite other executives of the Bank and Group to attend, if necessary. The Committee is convened at least quarterly and ad hoc as deemed necessary at the invitation of its Chairman.

The Committee members do not receive any remuneration for their participation in the Committee.

As at December 31, 2014, the Bank employed a total of 10,205 staff of which 258 are occupied in the Bank's foreign branches, compared to 12,527 and 252 respectively, as at December 31, 2013 and 11,493 and 263 respectively, as at December 31, 2012. Additionally, the Group's subsidiaries in Greece and abroad employed approximately 23,924 employees as at December 31, 2014, compared to 25,064 as at December 31, 2013 and 23,388 as at December 31, 2012. As at December 31, 2014 Group-wide temporary employees were 307. The table below sets forth the average number of our employees by geographic location for 2014:

The table below sets forth the main categories of activity in which our employees were engaged, during 2014:

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.

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%. 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.

The cumulative percentage of total common shares outstanding stated above, as at March 31, 2014 is 0.0013%.

As at April 30, 2015, the Bank's outstanding issued share capital consisted of 3,533,149,631 common shares, 12,639,831 Series A non-cumulative non-voting redeemable preference shares offered in the form of ADRs in the United States and 270 million preference shares issued to the Hellenic Republic pursuant to the Hellenic Republic Bank Support Plan.

The following table sets forth certain information regarding holders of the Bank's common shares, based on information known to or ascertainable by the Bank.

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 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 Greek Law 3864/2010, as currently applicable, and Cabinet Act no 38/2012 (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 recapitalization share capital increase of the Bank under Greek Law 3864/2010, 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 traded in the NYSE in the form of ADRs. On April 30, 2015, 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 11.1%.

Subject to certain conditions, Greek law allows a Greek company to acquire and own its own shares and also allows subsidiaries to acquire and own shares of their parent company. Treasury shares in our financial statements represent shares of the Bank owned by our subsidiaries. Due to its participation in the Hellenic Republic liquidity support plan (see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic's Bank Support Plan") the Bank has not purchased any of its own shares from January 1, 2009 to the date of this Annual Report. Greek law does not also permit the purchase of own shares for as long as the HFSF participates in the share capital of the relevant bank.

Following implementation of the preference share facility of the Hellenic Republic Bank Support Plan, the Hellenic Republic currently owns all of the 270 million redeemable preference shares issued under this facility. See Item 4.B, "Business Overview—Relationship with the Hellenic Republic—Hellenic Republic as Shareholder".

Furthermore, in the context of the recapitalization of the Greek banks in 2013, the HFSF acquired 84.4% of the Bank's share capital though holding shares with restricted voting rights (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")

Following the share capital increase completed on May 13, 2014, the HFSF owns 57.2% of the Bank's ordinary share capital.

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, except for the following transactions:

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, 2013 and 2014 the Group has accrued for cases under litigation the amount of EUR 70 million and EUR 67 million, respectively, for those litigations for which the Group believes that this loss is probable and reasonably estimated. For the cases for which an accrual has not been recognized, management is not able to estimate reasonable possible losses, because the proceedings may last for many years, many of the proceedings are in early stages, there is uncertainty of the likelihood of the final result, there is uncertainty as to the outcome of pending appeals and there are significant issues to be resolved. However, in the opinion of the management, after consultation with legal counsel, the ultimate disposition of these matters is not expected to have a material adverse effect on the consolidated balance sheet, results of operation or cash flows of the Group.

As and when we are permitted to pay dividends, under Greek Company Law 2190/1920 and our Articles of Association, our profit for the period is to be allocated as follows:

Subject to the provisions regulating a share capital decrease, no profits may be distributed to shareholders if at the end of the previous financial year, the Bank's total equity is, or as a result of the said distribution will be, less than the Bank's share capital plus reserves, whose distribution is prohibited by law or our Articles of Association.

The distributable profits shall not exceed the profits for the last financial year on an unconsolidated basis net of tax, plus retained earnings and reserves the distribution of which is allowed (and has been approved at the annual General Meeting), less any losses carried forward and any amounts required by law or our Articles of Association to be allocated towards the formation of reserves. The profits to be distributed are payable to the shareholders within two months from the approval of the annual financial statements at the annual General Meeting. A shareholder's claim to a declared dividend is subject to a five-year statute of limitations, after which the dividend passes to the Hellenic Republic. The five-year period begins as at the end of the year during which its distribution was approved by the annual General Meeting.

Pursuant to the 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 the demand to the Minister of Development an accounting statement of the Bank, which must be published in the Government Gazette and one daily newspaper or be posted on our website. In addition, the relevant registry must be immediately notified. Interim dividends may not exceed one-half of the net profits as stated in such accounting statements.

Restrictions on dividends arise from our participation in the Hellenic Republic Bank Support Plan. Under Greek Law 3723/2008 setting forth the terms of the Hellenic Republic Bank Support Plan, participating banks will be subject to a maximum dividend distribution of 35% of profits otherwise set at the minimum dividend distribution by article 3, par. 1 of Greek Law 148/1967. For more information on the Hellenic Republic Bank Support Plan, see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic Bank Support Plan". Moreover, under the law, the representative of the government appointed to our Board of Directors or attending the annual General Meeting may veto any resolution relating to our dividend policy, pursuant to a decision of the

Minister of Finance, or if it is determined that such policy may jeopardize the interests of our depositors or materially affect our solvency and orderly operation.

Furthermore, pursuant to the terms of the Greek State Preference Shares, we are required to allocate dividends to the Hellenic Republic as our preference shareholder prior to the allocation of any dividends to our ordinary shareholders (for further information on the terms of the Greek State Preference Shares see Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic Bank Support Plan".). Any dividend payment to the Hellenic Republic will reduce the amount of distributable dividends that may be allocated to our ordinary shareholders in any financial years.

According to existing legislation, banks participating in the Hellenic Republic Bank Support Plan could distribute dividends to ordinary shareholders only in the form of ordinary shares for financial years 2008 through 2012, excluding treasury shares. As of today, there is no restriction on dividend payments made in the form of Ordinary Shares for 2013 and 2014. However, such prohibition may be imposed by applicable legislation, as it has been in past years.

The restrictions of Greek Law 3723/2008 regarding the distribution of dividends to a maximum of 35% apply by analogy to the Bank as a result of its participation in the recapitalization program of Greek Law 3864/2010 and for so long as the HFSF is a shareholder of the Bank. In addition, for so long as the Bank participates in the recapitalization program of Greek Law 3864/2010, the HFSF's representative who sits on the Bank's Board of Directors has the power to veto any decision of the Board of Directors of the Bank regarding, among others, the distribution of dividends and remunerations.

In addition pursuant to the commitments undertaken by the Hellenic Republic vis-à-vis the European Commission due to the provision of state-aid to Greek credit institutions, the Bank is prohibited from distributing dividends or paying coupons on own fund instruments or releasing reserves to put itself in such a position until the end of the restructuring period, unless such payment fulfills a legal obligation of the Bank or the Directorate General for Competition of the European Commission grants a relevant exception.

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, 2014, the date of the last audited financial statements included in this Annual Report, please see Note 44 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. Since October 1999, the Bank's shares have also been listed on the New York Stock Exchange and traded in the form of ADRs. Each ADR currently represents one share.

The annual high and low market prices of the Bank's shares on the ATHEX for the five most recent financial years and up to May 7, 2015 are shown below, expressed in Euro.

The Bank's share price in each period is adjusted to reflect the share-for-share merger with Eurobank (adjustment effective as at February 27, 2013), the two-for-nine rights issue that took place in July 2009 (adjustment effective at July 2, 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 (adjustment effective at September 21, 2010), the thirty five-for-two rights issue that took place in May 2013 (adjustment effective at May 24,2013) and new shares issued in June 2009 and January 2010 following the exercise of the employees stock option rights. For more information see: Item 14.A, "General Effect of the Modifications on the Rights of Security Holders".

The quarterly high and low market prices of the Bank's shares on the ATHEX for the two most recent financial years are shown below, expressed in Euro.

The high and low market prices of the Bank's shares on the ATHEX for the first quarter of 2015 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 7, 2015 are presented in the table below, expressed in euro.

On May 15, 2008 the Bank's General Meeting of Shareholders approved the share capital increase of up to EUR 1.5 billion through the issue of redeemable preference shares, with exclusion of the

preemptive right in favor of existing shareholders that were made available to private investors in the U.S. As a result, the Bank's share capital increased by EUR 750 million through payment in cash of EUR 403 million and the issue of 25 million redeemable preference shares without voting right or cumulative dividend, of a par value of EUR 0.30 and a selling price of USD 25 each. The preference shares were sold in the form of ADSs and each ADS represents one preference share. On May 31, 2013 the Bank announced a cash tender offer for 22.5 million ADSs, through which it acquired 12.4 million securities. The outstanding amount of ADSs stands at 12.6 million currently, following the aforementioned transaction.

The high and low market prices of the Bank's preference share ADSs on the New York Stock Exchange for the five most recent years and up to May 7, 2015, are shown below, expressed in USD.

The quarterly high and low market prices of the Bank's preference share ADSs on the New York Stock Exchange for the most recent two financial years are shown below, expressed in USD.

The high and low market prices of the Bank's preference share ADSs on the New York Stock Exchange for the first quarter of 2015 are shown below, expressed in USD.

The monthly high and low market prices of the Bank's preference share ADSs on the New York Stock Exchange for the most recent months and up to May 7, 2015 are shown below, expressed in USD.

The annual high and low market prices of the Bank's ADRs evidencing ordinary shares on the New York Stock Exchange are shown below, expressed in U.S. dollars, for the five most recent financial years and up to May 7, 2015:

The quarterly high and low market prices of the Bank's ADRs evidencing ordinary shares on the New York Stock Exchange for the two most recent financial years are shown below, expressed in USD.

The high and low market prices of the Bank's ADRs evidencing common shares on the New York Stock Exchange for the first quarter of 2015 are shown below, expressed in USD.

The monthly high and low market prices of the Bank's ADRs evidencing ordinary shares on the New York Stock Exchange for the six most recent months and up to May 7, 2015 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 February 21, 2011, in anticipation of the announcement of the merger with Alpha Bank, 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, nor have there been any trading suspensions with respect to the Bank's ADRs on the New York Stock Exchange since the Bank's listing thereon in October 1999.

The Bank's shares are listed on the ATHEX. In addition, the Bank's Global Depositary Receipts are listed on the London Stock Exchange and its ADRs and preference shares are listed on the New York Stock Exchange.

The ATHEX, formerly known as the Athens Stock Exchange, was established in 1876. Since 1995, the ATHEX has progressively been privatized, and its privatization is now complete. Today, 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 "ATHEXclear") and of the Hellenic Central Securities Depository, S.A. (the "HSCD") 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.

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 16, 2015) and governs the relationships between the ATHEX and its Members, the companies that have listed securities for trading or have submitted an application for the listing of their securities on the ATHEX, as well as any other person towards which the ATHEX Regulation introduces rights and obligations.

Today, the ATHEX operates two regulated markets: the Securities Market and the Derivatives Market and the Securities Lending Facility. The securities of companies listed on the Securities Market are classified into one of the following eight categories: (a) General (which is the Main Market); (b) Fixed Income Securities; (c) Warrants (d) Synthetic Financial Instruments; (e) Exchange Traded Funds; and the Special Categories of (f) Low Dispersion, (g) Under Surveillance; and (h) To Be Delisted. When securities, other than units in listed mutual funds, debts securities and synthetic financial instruments, are listed for the first time on the Securities Market of the ATHEX 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 ATHEX Regulation the relevant decisions issued by the Board of

Directors of the ATHEX and the ATHEX Regulation which 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.

In 2014, the average daily trading value on the ATHEX was EUR 127 million, compared with EUR 87 million in 2013, which represents an increase of 46.7%. From January 2, 2015 to March 31, 2015, the average daily value traded on the ATHEX was EUR 116 million.

On March 31, 2015, 233 companies had shares listed on the Cash Market of the ATHEX. On March 31, 2015, the total market capitalization of the ATHEX was EUR 45.3 billion, with the top 25 companies accounting for 82.1% of the total market capitalization, and the Bank's market capitalization was 24.6%, 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%.

There are no exchange controls in Greece that would restrict the payment of dividends or other capital distributions to a holder of ordinary shares outside Greece or that would affect the right of a non-Greek holder of ordinary shares to dispose of his or her ordinary shares and receive the proceeds of such disposal outside Greece.

The Hellenic Central Securities Depositary S.A. ("HCSD") charges a levy (currently at 0.0325%) to the buyer and the seller to cover settlement costs. The sale and transfer of shares listed on the ATHEX over the counter is also subject to a levy currently at 0.0325% (min EUR 20) plus EUR 1 if it is Delivery Versus Payment ("DVP") (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) and charged to the buyer and the seller by the HCSD to cover settlement costs. Each of the buyer and the seller also pays a freely negotiable commission to the brokers.

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.

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 the Collateral Directive (Directive 2002/47/EC), thereby facilitating the use of securities listed on the ATHEX as collateral for entities falling within its scope, in particular simplifying the procedure for the enforcement of such collateral. 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 on June 2014, 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".
	(c)	The Bank's Articles of Association do not contain any provisions with respect to borrowing powers exercisable by the Bank's Board of Directors, or how such borrowing powers can be varied.
	(d)	The Bank's Articles of Association do not contain any provision with respect to the retirement or non-retirement of Directors under an age limit requirement.
	(e)	The Bank's Articles of Association do not contain any provision with respect to the number of shares required for Director's qualification.

At the date of this 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 Relationship Framework Agreement with the HFSF dated July 10, 2013 (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").

The following is a summary of material U.S. federal income tax consequences of the purchase, ownership and disposition of ordinary shares, preference shares or ADRs by a U.S. Holder.

For the purposes of this summary, a "U.S. Holder" is a beneficial owner of ordinary shares, preference shares or ADRs that is, for U.S. federal income tax purposes, (i) a citizen of or an individual resident in the United States, (ii) a corporation created in or organized under the laws of the United States or any state thereof or the District of Columbia, (iii) an estate, the income of which is subject to U.S. federal income taxation regardless of its source, or (iv) a trust that is subject to U.S. tax on its worldwide income regardless of its source. If a partnership holds ordinary shares, preference shares or ADRs, the consequences to a partner will generally depend upon the status of the partner and the activities of the partnership. A partner of a partnership holding shares, preference shares or

ADRs should consult its tax advisor regarding the associated tax consequences. This summary does not purport to be a comprehensive description of all of the tax consequences of the ownership or disposition of ordinary shares, preference shares or ADRs. In particular, this summary deals only with U.S. Holders that will hold ordinary shares, preference shares or ADRs as capital assets and does not address the tax treatment of special classes of U.S. Holders, such as financial institutions, tax-exempt entities, insurance companies, retirement plans, persons holding ordinary shares, preference shares or ADRs as part of a "straddle" or as part of a "synthetic security" or a hedging or conversion transaction or other integrated transaction, real estate investment trusts, regulated investment companies, partnerships, pass-through entities or persons who hold through partnerships or other pass-through entities, U.S. expatriates, dealers or traders in securities, currencies or notional principal contracts, persons that own (or are deemed to own for U.S. federal income tax purposes) 10% or more of the voting stock of the Bank, holders who hold ordinary shares, preference shares or ADRs in connection with a trade, profession or vocation carried on in Greece (whether through a branch, agency or otherwise) and holders whose "functional currency" is not the U.S. dollar. Further, this discussion does not address any tax consequences applicable to holders of equity interests in a holder of ordinary shares, preference shares or ADRs. This summary is based upon current U.S. federal income tax law, including the U.S. Internal Revenue Code of 1986 (the "Code"), its legislative history, existing, temporary and proposed regulations thereunder, published rulings and court decisions, all of which are subject to change (possibly with retroactive effect); and the Convention Between the United States of America and the Kingdom of Greece (now the Hellenic Republic) for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, with effect from December 30, 1953 (the "Treaty").

Prospective purchasers should consult their tax advisors as to the 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, preference shares and ADRs.

Holders of ADRs will generally be treated for U.S. federal income tax purposes as owners of the ordinary shares or preference shares underlying the ADRs. Accordingly, except as noted, the U.S. federal income tax consequences discussed below apply equally to holders of ordinary shares, preference shares and ADRs.

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, preference shares or ADRs held for a minimum holding period (generally, 61 days during the 121-day period beginning 60 days before the ex-dividend date). The Bank expects to be considered a qualified foreign corporation for this purpose.

The gross amount of dividends paid in Euros will be included in the income of the relevant U.S. Holder in a U.S. dollar amount calculated by reference to the spot exchange rate in effect on the day the dividends are received by the U.S. Holder (or, in the case of the ADRs, by The Bank of New York Mellon, in its capacity as depositary) regardless of whether the payment is in fact converted into U.S. dollars. A U.S. Holder will have a basis in any Euros distributed equal to their U.S. dollar value on the date they are received by the U.S. Holder (or, in the case of the ADRs, by The Bank of New York Mellon in its capacity as depositary). Any gain or loss recognized upon a subsequent disposition of Euros will generally be U.S. source ordinary income or loss. If Euros are converted into U.S. dollars on the date of the receipt, the U.S. Holder should not be required to recognize any foreign currency gain or loss in respect of the receipt of Euros as dividends.

The 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 ordinary shares, preference shares or ADRs generally will constitute "passive category income" or "general category income". For purposes of calculating a U.S. Holder's foreign tax credit limitation, the amount of foreign source dividend income subject to the reduced dividend income tax rate that is taken into account for purposes of calculating the U.S. Holder's U.S. foreign tax credit limitation must be reduced by the "rate differential portion" of such dividend. The rules relating to foreign tax credits and the timing thereof are complex. U.S. Holders should consult their tax advisors regarding the availability of foreign tax credits under their particular circumstances.

Subject to the discussion below under this Item 10.E, "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 ordinary shares, preference shares or ADRs will be subject to U.S. federal income taxation as capital gain or loss in an amount equal to the difference between the U.S. Holder's adjusted tax basis in the ordinary shares, preference shares or ADRs and the amount realized on the disposition. Such gain or loss generally will be treated as long-term capital gain or loss if the ordinary shares, preference shares or ADRs have been held for more than one year. Capital gains of non-corporate U.S. Holders derived from capital assets held for more than one year are eligible for reduced rates of taxation. The deductibility of capital losses is subject to significant limitations. Any gain or loss realized will generally be treated as derived from U.S. sources.

Except as otherwise provided in the next paragraph, the Bank believes that for U.S. federal income tax purposes, U.S. Holders should generally recognize gain or loss upon the redemption or mandatory repurchase of their preference shares or the related ADRs in an amount equal to the excess, if any, of the cash and the fair market value of any property received in the redemption (other than amounts attributable to accrued but otherwise unpaid dividends) over the U.S. Holder's adjusted tax basis in the preference shares or the underlying ADRs surrendered. That capital gain or loss will be long-term capital gain or loss if the U.S. Holder's holding period in respect of such preference shares or the underlying ADRs is more than one year. Any cash and the fair market value of any property received that is attributable to accrued dividends not previously recognized in income should be taxed as ordinary income.

Although the matter is not free from doubt, if the preference shares or the underlying ADRs are redeemed or mandatorily repurchased by the Bank, a portion of the redemption amount equal to the liquidation preference reduction amount may be characterized for U.S. federal income tax purposes attributable to declared but otherwise unpaid dividends. In such an event, it is possible that U.S. Holders will recognize in a redemption or mandatory repurchase additional dividend income equal to the liquidation preference reduction amount, and a capital loss of the same amount. Under current law,

any redemption or repurchase proceeds characterized as dividends for U.S. federal income tax purposes would be eligible for taxation at the reduced income tax rates available for foreign source dividend income as discussed above under Item 10.E, "U.S. Federal Income Taxation—Dividends".

The U.S. federal income tax consequences of a redemption or mandatory repurchase for U.S. Holders that own, actually or constructively, other classes of stock of the Bank in addition to preference shares or the related ADRs may differ from that described above.

The surrender of ADRs in exchange for ordinary shares or preference shares (or vice versa) will not be a taxable event for U.S. federal income tax purposes and U.S. Holders will not recognize any gain or loss upon such an exchange.

If a U.S. Holder receives any foreign currency on the sale, exchange or disposition of ordinary shares or preference shares, such U.S. Holder generally will realize an amount equal to the U.S. dollar value of such foreign currency on the settlement date of such sale, exchange or disposition if (i) such U.S. Holder is a cash basis or electing accrual basis taxpayer and the ordinary shares are treated as being "traded on an established securities market" or (ii) such settlement date is also the date of such sale, exchange or disposition. If the foreign currency so received is converted to U.S. dollars on the settlement date, such U.S. Holder should not recognize foreign currency gain or loss on such conversion. If the foreign currency so received is not converted into U.S. dollars on the settlement date, such U.S. Holder will have a basis in such foreign currency equal to its U.S. dollar value on the settlement date. Any gain or loss on a subsequent conversion or other disposition of such foreign currency generally will be treated as ordinary income or loss to such U.S. Holder and generally will be income or loss from sources within the United States for U.S. foreign tax credit purposes. Each U.S. Holder should consult their tax advisor regarding the U.S. federal income tax consequences of receiving foreign currency from the sale, exchange or other disposition of ordinary shares or preference shares.

The foregoing discussion of dividends and capital gains assumes that the Bank is not a passive foreign investment company (a "PFIC") for U.S. federal income tax purposes. Based upon (i) U.S. Treasury Regulations (the "Regulations") and (ii) the regulatory status of the Bank under local laws, its banking activities performed in the ordinary course of business (including lending, accepting deposits and depositing money in other banks), the proportion of its income derived from activities that are "bona fide" banking activities for U.S. federal income tax purposes and its securities activities performed in the ordinary course of business (including selling debt instruments to customers in a dealer capacity), the Bank believes that it was not a PFIC for the taxable year ending December 31, 2014 (the latest period for which the determination can be made) and, based further on its present regulatory status under local laws, the present nature of its activities, and the present composition of its assets and sources of income, the Bank does not expect to be a PFIC for the current year or for any future years. However, because PFIC status is a factual determination made annually and because there are uncertainties in the application of the relevant rules, there can be no assurances that the Bank will not be considered to be a PFIC for any particular year.

If for any year in which a U.S. Holder held ordinary shares, preference shares or ADRs, the Bank were to qualify as a PFIC, the U.S. Holder would be subject to special rules with respect to (i) any gain realized on the sale or other disposition (including a pledge) of the ordinary shares, preference shares or ADRs and (ii) any "excess distribution" by the Bank to the U.S. Holder (generally, any distributions to the U.S. Holder in respect of the ordinary shares, preference shares or ADRs during a single taxable year to the extent the distributions exceed 125% of the average annual distributions received by the U.S. Holder in respect of the ordinary shares, preference shares or ADRs during the three preceding taxable years or, if shorter, the U.S. Holder's holding period for the ordinary shares, preference shares or ADRs). Under these rules, (i) the gain or excess distribution would be allocated ratably over the

U.S. Holder's holding period for the ordinary shares, preference shares or ADRs, (ii) the amount allocated to the taxable year in which the gain or excess distribution was realized would be taxable as ordinary income, (iii) the amount allocated to each prior year, with certain exceptions, would be subject to tax at the highest tax rate in effect for that year and (iv) the interest charge generally applicable to underpayments of tax would be imposed in respect of the tax attributable to each such year.

U.S. Holders can avoid the interest charge by making a "mark to market election" with respect to the ordinary shares, preference shares and ADRs, provided that the relevant ordinary shares, preference shares or ADRs are "marketable" within the meaning of the relevant U.S. Treasury Regulations. The ordinary shares, preference shares and ADRs will not be considered "marketable" for purposes of this election unless the exchange or market on which the relevant ordinary shares, preference shares or ADRs are regularly traded is a qualified stock exchange or other market. Under the Regulations, a stock exchange is a "qualified stock exchange" if it is either one of the recognized U.S. stock 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 ordinary shares, preference shares or ADRs cease to be marketable. A U.S. Holder that makes a mark to market election generally will, subject to certain limitations, be required to take into account the difference, if any, between the fair market value and the adjusted tax basis of its ordinary shares, preference shares or ADRs at the end of a taxable year, as ordinary income (or, subject to certain limitations, ordinary loss) in calculating its income for such year. In the case of a mark to market election, gains from an actual sale or other disposition of the ordinary shares, preference shares or ADRs will be treated as ordinary income, and any losses incurred on a sale or other disposition of the ordinary shares, preference shares or ADRs will be treated as ordinary loss to the extent of any net mark to market gains for prior years.

Special rules apply with respect to the calculation of the amount of the foreign tax credit with respect to excess distributions by a PFIC. If the ordinary shares, preference shares or ADRs constitute equity interests in a PFIC, a U.S. Holder will be required to make an annual return on IRS Form 8621 regarding its investment in a PFIC.

U.S. Holders may be subject to the information reporting requirements of the Code, as well as to backup withholding on the payment of dividends on, and the proceeds received from the disposition of, ordinary shares, preference shares or ADRs. Backup withholding may apply if a U.S. Holder (i) fails to furnish its taxpayer identification number ("TIN"), which, in the case of an individual, is his or her social security number; (ii) fails to provide certification of exempt status; (iii) is notified by the IRS that he or she has failed properly to report payments of interest and dividends; (iv) under certain circumstances, fails to certify, under penalty of perjury, that he or she has furnished a correct TIN or the Bank has been notified by the IRS that such U.S. Holder is subject to backup withholding for failure to furnish a correct TIN; or (v) otherwise fails to comply with the applicable requirements of the backup withholding rules.

U.S. Holders should consult their tax advisors regarding their qualification for exemption from backup withholding and the procedure for obtaining such an exemption, if applicable. The amount withheld from a payment to a U.S. Holder under the backup withholding rules generally will be allowed as a credit against such holder's U.S. federal income tax liability and may entitle such holder to a refund, provided that the required information is timely furnished to the IRS.

Certain U.S. Holders may be required to report to the IRS certain information with respect to their beneficial ownership of the ordinary shares, preference shares and ADRs 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, preference shares or ADRs.

The information set out above is a summary only and U.S. and other taxation may change from time to time. Prospective investors should consult their tax advisors as to the consequences of the purchase, ownership and disposition of ordinary shares, preference shares and ADRs including, in particular, the effects of the tax laws of any other jurisdiction

Provisions of law commonly known as FATCA were enacted in 2010 by the U.S. Congress as part of the Hiring Incentives to Restore Employment Act, and have added Chapter 4 of Subtitle A, comprised of sections 1471 through 1474, to the U.S. Internal Revenue Code of 1986 ("Code"). FATCA imposes a new reporting regime and potentially a 30% withholding tax with respect to certain payments to (i) any non-U.S. financial institution (a "foreign financial institution", or "FFI" (as defined by FATCA)) that does not enter into an agreement with the U.S. Internal Revenue Service ("IRS") to provide the IRS with certain information in respect of its account holders and investors or is not otherwise exempt from or in deemed compliance with FATCA and (ii) any investor or account holder (unless otherwise exempt from FATCA) that does not provide information sufficient to determine whether the investor is a U.S. person or should otherwise be treated as holding a "United States account" at the Bank (a "Recalcitrant Holder").

The withholding regime under FATCA became effective July 1, 2014 for payments from sources within the United States and will apply to "foreign pass thru payments" (a term not yet defined) no earlier than January 1, 2017.

In order to facilitate compliance with the provisions of FATCA, the United States has entered into intergovernmental agreements (each an "IGA") with a number of other jurisdictions. Pursuant to FATCA and the "Model 1" and "Model 2" IGAs released by the United States, an FFI in an IGA signatory country that is treated as in compliance with the requirements of the relevant IGA would not be subject to withholding under FATCA on any payments it receives. Further, an FFI in an IGA jurisdiction 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.

Greece has as of November 30, 2014 reached an agreement in substance with the U.S. on the terms of a Model 1A IGA, and as such, the country is currently treated as having a Model 1 IGA in effect. Additionally, the Bank is registered with the IRS as a Registered Deemed-Compliant Financial Institution (including a Reporting Financial Institution under a Model 1 IGA).

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 ordinary shares, preference shares and ADRs.

NBG is subject to the informational requirements of the U.S. Securities Exchange Act of 1934, as amended (the "Exchange Act"), applicable to foreign private issuers. In accordance with these requirements, NBG files reports and other information with the Securities and Exchange Commission ("SEC"). These materials may be obtained, upon written request, from The Bank of New York Mellon, as depositary, at its Corporate Trust Office located at 101 Barclay Street, New York, New York 10286. Such reports and other information can be inspected without charge and copied at prescribed rates at the public reference room maintained by the SEC at 100 F Street, N.W., Washington, D.C. 20549. Copies of such material and any part thereof will also be available by mail from the Public Reference Section of the SEC at 100 F Street, N.W., Washington, D.C. 20549, at prescribed rates. Also, certain reports and other information concerning NBG will be available for inspection at the offices of the NYSE at 20 Broad Street, New York, New York 10005.

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.

More specifically, the Bank retains a portfolio of EFSF bonds, Greek T-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.

Another entity that is a significant contributor to market risk in the Group is Finansbank, through its trading and available-for-sale portfolios. Finansbank is mostly exposed to interest rate risk that arises from the positions it retains in Turkish government bonds, denominated mainly in TRY, USD and EUR and enters into swap transactions either for hedging the interest rate risk of its bond portfolio, or for proprietary trading.

Moreover, Finansbank draws liquidity in US dollars which are then converted into TRY through Cross Currency Interest Rate Swaps, in order to offer loans to its clients. These Cross Currency Interest Rate Swaps also act as a hedge of the interest rate risk of Finansbank's installment loan portfolio.

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.

Foreign exchange risk on a Group level is mainly attributed to Turkish Lira exposure, due to the investment in Finansbank, whereas the foreign exchange risk undertaken by the rest of other 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 estimates the market risk of its trading and available-for-sale portfolios using the VaR methodology. This has been implemented through RiskWatch by Algorithmics (currently IBM). In particular, due to the 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 VaR is calculated on a daily basis for the Bank's trading and available-for-sale portfolios, along with the VaR per risk type (interest rate, equity and foreign exchange risk). The whole framework and the VaR calculations have been thoroughly examined and approved by the Bank of Greece, as well as by external consultants. Also, 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 1,120. 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 to worldwide best practices. They refer not only to specific types of market risk, such as interest rate, foreign exchange and equity risk, but also to the overall market risk of the Bank's trading and available-for-sale portfolios.

The tables below present the Bank's VaR (99%, 1-day) for the years ended on December 31, 2014 and 2013 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 nine months of 2014, the Bank's interest rate (IR) and total VaR had minor fluctuations, which are mostly attributed to the changes of the underlying interest rates and their volatilities. In the beginning of the fourth quarter, there was a sharp rise in the Greek government bond yields that led to a substantial increase of the respective volatilities and to higher VaR estimates for the Bank. Then, since interest rates remained at almost the same level, the volatilities gradually decreased, resulting to lower IR and total VaR estimates. However, near the end of the year, mainly due to political concerns, the spreads between the Greek and the German government bond yields suddenly widened, which in turn caused the IR and total VaR to increase significantly.

On a Group level, Finansbank is the other main contributor to market risk, through its positions held in the trading and available-for-sale portfolios. In order to monitor and efficiently manage market risk, Finansbank calculates VaR on a daily basis for its trading and available-for-sale portfolios, as well as the VaR per risk type (interest rate, equity and foreign exchange risk). These calculations are based on a 99% confidence interval and 1-day holding period and made through RiskWatch.

Finansbank has also established a framework of VaR limits, similar to the one that the Bank has in place.

The table below presents Finansbank's VaR (99%, 1-day) for the years ending on December 31, 2014 and 2013 respectively:

The change in Finansbank's Total VaR is mainly attributed to the change in the interest rate risk. During 2014, the Turkish interest rates and the respective volatilities gradually decreased, leading to lower VaR estimates. However, in December, due to concerns about the economic developments in Turkey, interest rates suddenly jumped, which resulted to significantly higher IR and Total VaR estimates for the subsidiary as compared to previous months.

Moreover, the Bank calculates the Group VaR on a daily basis, taking into account both its own portfolios and the respective portfolios of Finansbank.

The tables below present the VaR on a Group level (99%, 1-day) for the years ended December 31, 2014 and 2013 respectively:

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 by the Bank of Greece, the calculations only incorporate 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 Bank of Greece within five business days. During 2014, there were three (3) cases in which the back-testing result exceeded the respective VaR calculation.

Finansbank also performs back-testing on a daily basis, following a similar procedure. During 2014, the back-testing result exceeded the respective VaR calculation in two instances.

The VaR model is based on certain theoretical assumptions, which do not fully capture the potential "tail events" in the markets.

To enhance the predictability of our VaR model and minimize the effect of the aforementioned limitations, we perform stress testing on a weekly basis. The aim of stress testing is to evaluate the gains or losses that may occur under extreme market conditions. Stress testing applies on both, trading and available-for-sale portfolios and the scenarios used have been approved by the relevant regulatory authorities. These scenarios are presented in the following tables:

Stress test analysis is performed by Finansbank on its trading and banking portfolios, on a monthly basis. The scenarios refer to extreme movements of interest rates and foreign exchange prices and are based on the recent financial crises which have taken place in Turkey. These scenarios 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 Turkey, the countries of South East Europe, Cyprus, Egypt, Malta and South Africa, where the Group has presence.

Counterparty risk for the Group is due to OTC derivative transactions and other interbank secured and unsecured funding transactions and it arises from the obligor's failure to meet its contractual obligations. For the efficient management of counterparty risk, the Bank has established a framework of counterparty limits. The GMORMD is responsible for 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 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.

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, 2014, which are not included in the VaR model developed by the Bank. The analysis below was performed based on the following assumptions:

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:

The Bank of New York Mellon is the depositary of the Bank's preference shares and ordinary shares in the form of ADRs traded on the NYSE. The depositary collects its fees for delivery and surrender of ADSs directly from investors depositing shares or surrendering ADSs for the purpose of withdrawal or from intermediaries acting for them. The depositary collects fees for making distributions to investors by deducting those fees from the amounts distributed or by selling a portion of distributable property to pay the fees. In the case of preference shares, the depositary may collect its annual fee for depositary services by deductions from cash distributions or by directly billing investors

or by charging the book-entry system accounts of participants acting for them. The depositary may generally refuse to provide fee-attracting services until its fees for those services are paid.

For the year ended December 31, 2014, 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 (the "Tendered 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 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 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 ADS (the "Offer to Purchase") 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 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. Based on the results of the Offer, the aggregate purchase cost for the tendered ADSs was USD155 million.

On July 3, 2013, the purchase of the 12,360,169 ADSs was settled by the Bank. Therefore, following the purchase of the ADSs, 12,639,831 ADSs remain outstanding. The Bank cancelled any

ADSs purchased pursuant to the Offer, and canceled the Preference Shares represented thereby, following the completion of the requisite corporate approvals for cancellation of the Preference Shares.

On July 3, 2013 the Bank cancelled 12,360,169 ADSs purchased pursuant to the Offer announced on May 31, 2013. See Item 16.E, "Purchases of Equity Securities by the Issuer and Affiliated Purchasers".

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 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 share capital while the remaining EUR 2,159 million less expenses was credited to the share premium account.

As at December 31, 2014, the total paid-up share capital of the Bank amounted to EUR 2,414 million divided into a) 3,533,149,631 ordinary shares of a nominal value of EUR 0.30 each, b) 12,639,831 non-cumulative, non-voting, redeemable preference shares, of a nominal value of EUR 0.30 each, and c) 270,000,000 redeemable preference shares of the Hellenic Republic of a nominal value of EUR 5.00 each, in accordance with Greek Law 3723/2008. See Item 4.B, "Business Overview—Regulation and Supervision of Banks in Greece—The Hellenic Republic's Bank Support Plan" for a detailed description of the current plan.

As of December 31, 2014, we performed an evaluation, under the supervision and with the participation of our Management, including our Chief Executive Officer and our 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 and 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 and the Deputy Chief Executive Officer and Group Chief Financial Officer have concluded that our disclosure controls and procedures are ineffective as of December 31, 2014 due to the material weaknesses described in Item 15 (b) below. Our efforts to remediate the significant deficiencies that aggregate to 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".

The 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 officers, 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, 2014, 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, 2014, 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 internal control over financial reporting, 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 internal controls over financial reporting relating to:

The effectiveness of the Group's internal control over financial reporting as of December 31, 2014, 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, 2014.

To the Board of Directors and Shareholders of
National Bank of Greece S.A. and subsidiaries

We have audited National Bank of Greece S.A. and its subsidiaries (the "Group") internal control over financial reporting as of December 31, 2014 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, 2014, 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 76,892 million (EUR 27,151million) as of December 31, 2014, net interest income of TRY 3,192 million (EUR 1,100 million) and profit for the year of TRY 950 million (EUR 328 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 adverse 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. Management identified and included in its assessment, two material weaknesses related to:

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, 2014 of the Group and this report does not affect our report on such 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 effective internal control over financial reporting as of December 31, 2014, 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, 2014, of the Group and our report dated May 15, 2015 expressed an unqualified opinion on those financial statements based on our audit and the report of the other auditor and included an explanatory paragraph regarding substantial doubt about the Group's ability to continue as a going concern and an emphasis of matter paragraph relating to the translation of Euro amounts into U.S. dollar amounts for the convenience of the readers in the United States.

We have audited Finansbank A.S. (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, 2014, 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.S'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.S'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.

A material weakness is a deficiency, or 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. Finansbank A.S's Management has identified a material weakness in the process for allowance for loan losses where the design of relevant controls did not sufficiently consider validation procedures for certain delinquent loans, estimated future cash flows of certain loans within the restructured corporate portfolio and recovery rates of non-performing retail loan portfolios.

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, 2014, 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. This material weakness

described in the preceding paragraph was considered in determining the nature, timing and extent of audit tests applied in our audit of the consolidated financial statements, and this report does not affect our report dated May 15, 2015, which expressed an unqualified opinion on those consolidated financial statements.

In our opinion, because of the effect of the material weakness described above on the achievement of the objectives of the control criteria, the Finansbank Group has not maintained effective 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, 2014, 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).

/s/ Güney Bagımsız Denetim ve Serbest Muhasebeci Mali Müsavirlik Anonim Sirketi

Based on Management's assessment as of December 31, 2013, the Group's internal control over financial reporting was ineffective due to a material weakness identified in its internal control over financial reporting. This material weakness related to the financial statement closing process, which continued also in 2014 to produce significant control deficiencies that lead to adjustments and revisions of the spreadsheet-based supporting calculations. This is due to the fact that the Bank still relies to a great extent on several complex manual processes to extract and process high volumes of information from the core banking systems in order to generate the U.S. GAAP financial statements. Throughout 2014, the Bank undertook a number of remediation actions in order to address the internal control deficiencies that contributed to this material weakness. Our efforts to remediate the significant deficiencies that aggregated to the material weakness are described as follows:

While the previous steps have been taken towards remediating the material weakness, Management has determined that as of December 31, 2014, this material weakness remained. The remediation efforts will continue during 2015 and our plan includes further increasing the headcount of qualified finance personnel with U.S. GAAP knowledge, continuing our IT projects and exploring further opportunities for automation improvements in the reporting process.

Other than those changes described above, during the year ended December 31, 2014, there have been no changes in our internal control over financial reporting, that have materially affected, or are reasonably likely to materially affect our internal control over financial reporting.

On January 28, 2010, the Bank's Board of Directors appointed Mr. Petros Sabatacakis, an independent non-executive member of the Board of Directors, as the Audit Committee financial expert. Since that time, Mr. Sabatacakis has been reappointed as the Audit Committee financial expert by the Bank's General Meeting of Shareholders. On June 26, 2014 the Annual General Meeting of Shareholders reappointed Mr. Sabatacakis as the Audit Committee financial expert until the date of the Annual General Meeting of 2015.

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 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, 2013 and 2014. For Finansbank, our major subsidiary in Turkey, Ernst & Young was appointed as the independent public accountant for the year ended December 31, 2014.

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, 2013 and 2014 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 year ended December 31, 2014 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 the year ended December 31, 2013 referred to the tax compliance audits of Finansbank and its subsidiaries.

Fees billed for audit related services for the years ended December 31, 2013 and 2014 consisted primarily of comfort letter fees, other audit and attest services and system and application control reviews provided either repeatedly or on adhoc basis.

Fees billed for tax services for the years ended December 31, 2013 and 2014 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, as well as for services to NBG Private Equity Ltd regarding the performance of standard agreed upon procedures to audit the exit calculations of Fund investments. These services may be approved by the Group Chief Financial Officer or its delegate and the Audit Committee's approval is obtained at the next Audit Committee meeting. All other allowable audit and non-audit services to be offered by the Group's statutory

auditors are approved, on a case-by-case basis, in accordance with the rules and regulations concerning auditor independence promulgated by the SEC to implement the Sarbanes-Oxley Act of 2002.

All "Audit fees", "Audit related fees" and "Tax fees" for 2013 and 2014 were specifically approved by the Audit Committee. "Audit related fees" and "Tax fees" constituted 16.5% and 2.6%, respectively, of total fees paid to Deloitte and Ernst & Young in 2013, and 25.1% and 4.0%, respectively, of total fees paid to Deloitte and Ernst & Young in 2014.

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 2012 amounted to 6,071,162 shares and (6,076,383) shares respectively. Therefore, the balance of as at December 31, 2012 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 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.

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 ADS upon the terms and subject to the conditions set forth in the Offer to Purchase. On July 3, 2013, the Bank purchased 12,360,169 ADSs further to the Offer to Purchase. Following the purchase of these ADSs, 12,639,831 ADSs remain outstanding. The Bank cancelled the ADSs purchased pursuant to the Offer, and the Preference Shares represented thereby.

On December 19, 2013 our Board of Directors, in light of mandatory rules regarding auditor rotation in accordance with the Independent Audit By-Law announced by Public Oversight, Accounting, and Auditing Standards Authority in Turkey and based on the recommendation from our audit committee, approved the rotation of DRT BAGIMSIZ DENETIM VE SERBEST MUHASEBECI MALI MUSAVIRLIK A.S., the Turkish member firm of DELOITTE TOUCHE TOHMATSU LIMITED (referred to in this Item 16F as "Deloitte Turkey") as independent registered public accounting firm and the engagement of Güney Bagımsız Denetim ve Serbest Muhasebeci Mali Musavirlik Anonim Sirketi, a member firm of Ernst&Young Global Limited, Istanbul, Turkey (referred to in this Item 16F as "EY Turkey") to serve as the new independent registered public accounting firm for our significant subsidiary Finansbank A.S. for the fiscal year ended December 31, 2014. This

appointment was effective as of January 1, 2014. The appointment of EY Turkey was also approved by the General Meeting of Finansbank A.S. on March 27, 2014. The independent audit report of EY Turkey issued in accordance with the PCAOB auditing standards in respect of the consolidated financial statements of Finansbank A.S. as of and for the year ended December 31, 2014 prepared in accordance with International Financial Reporting Standards, as issued by the International Accounting Standards Board is included in this Annual Report. Deloitte Hadjipavlou, Sofianos & Cambanis S.A. ("Deloitte Greece") continues to be our principal accountant.

During the two fiscal years preceding the rotation of Deloitte Turkey, there were no disagreements between Finansbank A.S. and Deloitte Turkey on any matters of accounting principles or practices, or auditing scope or procedure, which disagreements, if not resolved to the satisfaction of Deloitte Turkey, could have caused our principal accountants Deloitte Greece to make reference to the subject matter of the disagreement in its report on our consolidated financial statements. During the two fiscal years preceding the rotation of Deloitte Turkey, there were no "reportable events" as that term is defined in Item 16F(a)(1)(v) of Form 20-F.

We have provided Deloitte Turkey with a copy of the foregoing statements and have requested and received from Deloitte Turkey a letter addressed to the Securities and Exchange Commission stating whether or not Deloitte Turkey agrees with the above statements. A copy of the letter from Deloitte Turkey is attached as Exhibit 15.1 to this Annual Report.

During the two fiscal years preceding the rotation of Deloitte Turkey neither we nor anyone acting on our behalf, consulted EY regarding any of the matters or events set forth in Item 16F(a)(2) of Form 20-F.

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.

The registrant hereby certifies that it meets all of the requirements for this filing on Form 20-F and that it has duly caused and authorized the undersigned to sign this Annual Report on its behalf.

Consolidated Financial Statements as of
December 31, 2013 and 2014 and for the
years ended December 31, 2012, 2013 and
2014 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, 2014 and 2013, 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, 2014. 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 year ended December 31, 2014, which statements reflect total assets of TRY 76,892 million (EUR 27,151 million) as of December 31, 2014, net interest income of TRY 3,192 million (EUR 1,100 million) and profit for the year of TRY 950 million (EUR 328 million) for the year then ended. 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 year ended December 31, 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, 2014 and 2013, and the results of their operations and their cash flows for each of the three years in the period ended December 31, 2014, 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, the Group's ability to continue to access sufficient liquidity through Emergency Liquidity Assistance facility as well as the significant deposits outflow between January 1, 2015 and April 30, 2015 raise substantial doubt about its ability to continue as a going concern. Management's plans concerning these matters are also discussed in Note 3 to the consolidated financial statements. The consolidated financial statements do not include any adjustments that might result from the outcome of this uncertainty.

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, 2014, 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 15, 2015 expressed an adverse opinion on the Group's internal control over financial reporting based on our audit and the report of the other auditors because of material weaknesses.

We have audited the consolidated statement of financial position of Finansbank A.S. (a 99.81% owned subsidiary of National Bank of Greece S.A.) as of December 31, 2014, and the related consolidated statements of profit or loss, other comprehensive income, changes in equity and cash flows and notes thereto for the year ended December 31, 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 76,892 million and shareholders equity of TL 10,100 million as of December 31, 2014, respectively, and profit for the year of TL 950 million for the year then ended. These consoldiated 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.S. and its subsidiaries at December 31, 2014 and the consolidated results of their operations and their cash flows for the year ended December 31, 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.S.'s internal control over financial reporting as of December 31, 2014, 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 15, 2015 expressed an adverse opinion thereon.

/s/ Güney Bagimsız Denetim ve Serbest Muhasebeci Mali Musavirlik Anonim Sirketi
A member firm of Ernst&Young Global Limited
Istanbul, Turkey

			As of December 31,

	Note		2013			2014			2014
			(EUR in millions)						(USD in millions) (Note 2)
									Unaudited
ASSETS
Cash and due from banks		5		1,968			2,727			3,044
Deposits with Central Bank		6		3,454			3,583			3,999
Securities purchased under agreements to resell		7		39			94			105
Interest bearing deposits with banks		8		3,333			2,776			3,099
Trading assets		9		3,082			2,405			2,684
Derivative assets		10		3,671			5,943			6,634
Available-for-sale securities		11		6,385			5,203			5,808
Held-to-maturity securities		11		10,360			10,645			11,882
Equity method investments		12		152			160			179
Loans (include EUR 76 million and EUR 42 million at December 31, 2013 and 2014, respectively, measured at fair value)		13		73,235			74,908			83,612
Less: Allowance for loan losses				(7,751	)		(9,492	)		(10,595	)

Net loans				65,484			65,416			73,017
Goodwill		14		2,186			2,243			2,504
Software and other intangibles		14		333			353			394
Premises and equipment		15		1,418			2,128			2,375
Accrued interest receivable				829			827			923
Other assets (include EUR 382 million and EUR 568 million at December 31, 2013 and 2014, respectively, measured at fair value)		16		4,013			3,769			4,207
Long-lived assets held for sale		17		134			141			157

TOTAL ASSETS				106,841			108,413			121,011



LIABILITIES AND SHAREHOLDERS' EQUITY
Interest bearing deposits (include EUR 282 million and EUR 16 million at December 31, 2013 and 2014, respectively, measured at fair value)		20		82,175			77,902			86,954
Non-interest bearing deposits		20		3,419			3,610			4,030

Total deposits		20		85,594			81,512			90,984
Securities sold under agreements to repurchase		21		4,738			5,053			5,640
Derivative liabilities		10		3,032			6,263			6,991
Other borrowed funds		22		1,678			2,310			2,578
Accounts payable, accrued expenses and other liabilities (includes EUR 2 million and EUR 4 million at December 31, 2013 and 2014, respectively, measured at fair value)		23		4,087			4,498			5,021
Insurance reserves		24		2,504			2,248			2,509
Long-term debt (includes EUR 810 million and EUR 872 million at December 31, 2013 and 2014, respectively, measured at fair value)		25		2,582			4,085			4,560
Liabilities directly associated with long-lived assets held- for-sale		17		10			7			8

Total liabilities				104,225			105,976			118,291

Redeemable non-controlling interest—Temporary equity		34		250			—			—
PERMANENT EQUITY:
NBG shareholders' equity
Preferred stock (12,639,831 shares of par value EUR 0.30 each at December 31, 2013 and 2014 and 270,000,000 shares of par value EUR 5.00 each at December 31, 2013 and 2014)				1,354			1,354			1,511
Common stock, par value of EUR 0.30 (shares authorized, issued and outstanding: 2,396,785,994 and 3,533,149,631 at December 31, 2013 and 2014 respectively)				719			1,060			1,184
Additional paid-in capital		33		17,859			19,918			22,233
Accumulated surplus / (deficit)				(15,007	)		(17,387	)		(19,408	)
Accumulated other comprehensive loss		42		(2,596	)		(2,547	)		(2,844	)
Treasury stock, at cost (397,655 and 1,076 shares at December 31, 2013 and 2014 respectively)				(2	)		—			—

Total NBG shareholders' equity				2,327			2,398			2,676

Non-controlling interest				39			39			44

Total permanent equity				2,366			2,437			2,720

TOTAL LIABILITIES AND EQUITY				106,841			108,413			121,011

The accompanying notes are an integral part of these consolidated financial statements.

			Year ended December 31,

	Note		2012			2013			2014			2014
			(EUR in millions)									(USD in millions) (Note 2) Unaudited
Interest Income:
Loans				4,966			4,545			4,303			4,803
Securities available-for-sale				650			364			357			398
Securities held-to-maturity				58			88			195			218
Trading assets				184			124			66			74
Securities purchased under agreements to resell				19			6			16			18
Interest-bearing deposits with banks				30			19			13			15
Other				27			31			22			25

Total interest income				5,934			5,177			4,972			5,551

Interest Expense:
Deposits				(2,517	)		(2,004	)		(1,773	)		(1,979	)
Securities sold under agreements to repurchase				(60	)		(58	)		(97	)		(108	)
Other borrowed funds				(71	)		(105	)		(88	)		(98	)
Long-term debt				(81	)		(55	)		(128	)		(143	)
Other				(5	)		(11	)		(56	)		(63	)

Total interest expense				(2,734	)		(2,233	)		(2,142	)		(2,391	)

Net interest income before provision for loan losses				3,200			2,944			2,830			3,160
Provision for loan losses		13		(2,322	)		(969	)		(2,172	)		(2,424	)

Net interest income/(loss) after provision for loan losses				878			1,975			658			736

Non-interest income /(loss):
Credit card fees				228			207			211			236
Service charges on deposit accounts				97			102			88			98
Other fees and commissions		27		456			493			486			542
Net trading gain/(loss)		28		(1,366	)		297			(1,365	)		(1,524	)
Equity in earnings of investees and realized gains/(losses) on disposal of equity method investments		12		15			6			8			9
Other non-interest income		29		917			804			691			771

Total non-interest income / (loss) excluding gains / (losses) on investment securities				347			1,909			119			132

Net realized gains/(losses) on sales of available-for-sale securities		11		350			250			100			112
Other-Than-Temporary-Impairment (of which NIL was recognized in OCI)				(410	)		(285	)		(6	)		(7	)

Net gains / (losses) on available for sale and held to maturity securities				(60	)		(35	)		94			105

Total non-interest income / (loss)				287			1,874			213			237

Non-interest expense:
Salaries				(1,176	)		(1,159	)		(1,022	)		(1,141	)
Employee benefits				(204	)		(359	)		(144	)		(161	)
Occupancy expenses				(83	)		(70	)		(64	)		(71	)
Equipment expenses				(59	)		(53	)		(60	)		(68	)
Depreciation of premises and equipment				(114	)		(111	)		(114	)		(127	)
Amortization of intangible assets				(110	)		(100	)		(84	)		(94	)
Impairment of goodwill				(123	)		(9	)		(58	)		(65	)
Deposit insurance premium				(49	)		(87	)		(93	)		(104	)
Other non-interest expense		30		(1,595	)		(1,665	)		(1,591	)		(1,776	)

Total non-interest expense				(3,513	)		(3,613	)		(3,230	)		(3,607	)

Income / (loss) before income tax				(2,348	)		236			(2,359	)		(2,634	)
Income tax expense		31		(169	)		(167	)		(114	)		(127	)

Net income / (loss)				(2,517	)		69			(2,473	)		(2,761	)

Less: Net income attributable to the non-controlling interest				(20	)		(32	)		(4	)		(4	)



NET INCOME / (LOSS) attributable to NBG shareholders				(2,537	)		37			(2,477	)		(2,765	)



Earnings / (loss) per share
Basic EPS		35		(13.36	)		0.03			(0.79	)		(0.88	)
Diluted EPS		35		(13.36	)		0.03			(0.79	)		(0.88	)

The accompanying notes are an integral part of these consolidated financial statements.

		Year ended December 31,

	Note	2012			2013			2014			2014
		(EUR in millions)									(USD in millions) (Note 2) Unaudited
Net income / (loss)			(2,517	)		69			(2,473	)		(2,761	)
Other comprehensive income / (loss) net of tax:
Foreign currency translation adjustments			134			(1,326	)		239			267
Net (losses)/gains on available-for-sale securities:
Net unrealized holding (losses)/gains during the period (net of tax expense/(benefit) of: EUR 133 million in 2012, EUR (4) million in 2013 and EUR (15) million in 2014)			596			(6	)		11			12
Less: reclassification adjustment for net (gains)/losses included in net income (net of tax (expense)/benefit of: EUR (70) million in 2012, EUR (38) million in 2013 and EUR (28) million in 2014)			(280	)		(212	)		(95	)		(106	)
Less: Reclassification adjustment for impairment of available-for-sale securities (net of tax benefit of EUR 61 million in 2012, EUR 49 million in 2013 and EUR 1 million in 2014)			251			146			4			4

Total net (losses)/gains on available-for-sale securities			567			(72	)		(80	)		(90	)

Pension (liability)/asset (net of tax expense/(benefit) of EUR (1) million in 2012, EUR 3 million in 2013 and EUR (6) million in 2014)			(32	)		36			(43	)		(48	)

Total other comprehensive income / (loss), net of tax			669			(1,362	)		116			129

Comprehensive loss			(1,848	)		(1,293	)		(2,357	)		(2,632	)

Less: Comprehensive income attributable to the non-controlling interest			(34	)		17			(13	)		(15	)
Comprehensive loss attributable to NBG shareholders			(1,882	)		(1,276	)		(2,370	)		(2,647	)

The accompanying notes are an integral part of these consolidated financial statements.

			Year ended December 31,

	Note		2012			2013			2014			2014
			(EUR in millions)			(EUR in millions)			(EUR in millions)			(USD in millions) (Note 2)
												Unaudited
Common Stock:
Balance at beginning of year (956,090,482 of par value EUR 5.00 each at 2012 and 2013 and 2,396,785,994 at 2014 of par value EUR 0.30 each)				4,780			4,780			719			803
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							(1,190	)		—			—
Issuance of 2,274,125,874 shares of par value EUR 0.30 at 2013 and 1,136,363,637 shares of par value EUR 0.30 at 2014, through a rights issue and a non-rights issue, respectively		33		—			682			341			381

Balance at end of year (956,090,482 shares in 2012 of par value EUR 5.00 each, 2,396,785,994 in 2013 of par value EUR 0.30 each and 3,533,149,631 in 2014 of par value EUR 0.30 each)				4,780			719			1,060			1,184

Preferred stock
Balance at beginning of year (25,000,000 shares of par value EUR 0.30 each at 2012 and 2013 and 12,639,831 shares of par value EUR 0.30 each at 2014 and 270,000,000 shares of par value EUR 5.00 each at 2012, 2013 and 2014)				1,358			1,358			1,354			1,511
Purchase of the 12,360,169 preference shares				—			(4	)		—			—

Balance at end of year (25,000,000 shares of par value EUR 0.30 each at 2012 and 12,639,831 shares of par value EUR 0.30 each at 2013 and 2014 and 270,000,000 shares of par value EUR 5.00 each at 2012, 2013 and 2014)				1,358			1,354			1,354			1,511

Additional Paid-in Capital:
Balance at beginning of year				4,090			4,079			17,859			19,934
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			2,410
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			—			—
Repurchase of 12,360,169 preference shares							(135	)		—			—
Gain / (Loss) on sales of treasury stock (net of tax (expense)/benefit				(1	)		—			1			1
Issue costs net of tax in 2014 from the issuance of 1,136,363,637 shares				—			—			(55	)		(61	)
Purchase of subsidiaries shares from non-controlling interest		4		(10	)		1			(46	)		(51	)

Balance at end of year				4,079			17,859			19,918			22,233

Accumulated Surplus/(deficit):
Balance at beginning of year				(12,547	)		(15,037	)		(15,007	)		(16,751	)
New redeemable non-controlling interest, redemption of redeemable non-controlling interest and changes in the redemption amount of redeemable non-controlling interests		34		47			(7	)		97			108
Net income /(loss) attributable to NBG shareholders				(2,537	)		37			(2,477	)		(2,765	)

Balance at end of year				(15,037	)		(15,007	)		(17,387	)		(19,408	)

The accompanying notes are an integral part of these consolidated financial statements.

			Year ended December 31,

	Note		2012			2013			2014			2014
			(EUR in millions)			(EUR in millions)			(EUR in millions)			(USD in millions) (Note 2)
												Unaudited
Accumulated Other Comprehensive Income/ (Loss)—net of tax:		42
Balance at beginning of year				(1,939	)		(1,283	)		(2,596	)		(2,898	)
Net change in fair value of securities available-for-sale				557			(64	)		(82	)		(92	)
Foreign currency translation adjustments				130			(1,285	)		233			260
Pension liability				(31	)		36			(43	)		(48	)
Acquistion and disposal of subsidiaries shares from / to non-controlling interest				—			—			(59	)		(66	)

Balance at end of year				(1,283	)		(2,596	)		(2,547	)		(2,844	)

Treasury Stock, at Cost:
Balance at beginning of year (6,297, 1,076 and 397,655 shares at 2012, 2013 and 2014 respectively)				—			—			(2	)		(2	)
Sale of treasury stock (6,076,383, 9,770,521 and 33,095,326 shares during 2012, 2013 and 2014 respectively)				121			45			83			93
Purchase of treasury stock (6,071,162, 10,167,100 and 32,698,747 shares during 2012, 2013 and 2014 respectively)				(121	)		(47	)		(81	)		(91	)

Balance at end of year (1,076, 397,655 and 1,076 shares at 2012, 2013 and 2014 respectively)				—			(2	)		—			—

Total NBG shareholders' equity				(6,103	)		2,327			2,398			2,676



Non-controlling interest (NCI)—net of tax:
Balance at beginning of year				71			54			39			44
Net income/(loss)				(7	)		(1	)		(2	)		(2	)
Foreign currency translation adjustments				1			(2	)		—			—
Changes of non-controlling interest due to acquisitions, establishments, capital contributions and changes in subsidiaries shareholding				(11	)		(12	)		2			2

Balance at end of year				54			39			39			44

Total permanent equity				(6,049	)		2,366			2,437			2,720



Redeemable non-controlling interest—Temporary equity:
Balance at beginning of year				283			257			250			279
Net income				27			33			6			7
Net change in fair value of securities available-for-sale				10			(8	)		2			2
Foreign currency translation adjustments				4			(39	)		6			7
Redemption of redeemable NCI				(25	)		—			(167	)		(187	)
Changes in the redemption amount of redeemable NCI				(42	)		7			(97	)		(108	)

Balance at end of year				257			250			—			—

Total temporary equity				257			250			—			—

The accompanying notes are an integral part of these consolidated financial statements.

	Year ended December 31

	2012			2013			2014			2014
				(EUR in millions)						(USD in millions) (Note 2)
										Unaudited
Cash flows from Operating Activities:
Net income / (loss)		(2,517	)		69			(2,473	)		(2,761	)
Adjustments to reconcile net income / (loss) to net cash provided by/(used in) operating activities:
Provision for loan losses		2,322			969			2,172			2,424
Net (gain)/loss on sale of premises and foreclosed assets		12			—			2			2
Net realized (gain) / loss on sales of available-for-sale securities		(350	)		(250	)		(123	)		(137	)
Other Than Temporary Impairment of AFS and HTM securities		410			285			6			7
Equity in earnings of equity method investees		(15	)		1			(8	)		(9	)
Depreciation of premises and equipment		114			111			114			127
Amortization of software and other intangibles		110			100			84			94
Impairment of goodwill		123			9			58			65
Impairment of equity method investments		1			5			—			—
Pension liability		33			220			32			36
Provision for deferred income taxes		(36	)		(34	)		28			31
Net gains on the disposal of subsidiaries		(158	)		—			—			—
Net (gain) / loss from changes in the fair value of financial instruments designated at fair value		15			217			63			70
Gain on debt extinguishment		(9	)		—			—			—
Gain from bargain purchase on business combination		—			(208	)		(3	)		(3	)
Interest on financing obligation from sale of real estate		—			—			48			54
Other non cash items including provisions for contingencies and impairment of other assets		(27	)		(39	)		245			273
Changes in assets and liabilities
Trading assets, derivative instruments and financial assets market-to-market through the profit and loss		(787	)		658			1,387			1,548
Accrued interest receivable		32			(86	)		2			2
Other assets		(327	)		(398	)		(32	)		(36	)
Accounts payable, accrued expenses and other liabilities		(461	)		(550	)		360			402
Insurance reserves		(196	)		(13	)		(256	)		(286	)

Cash flows provided by/(used in) operating activities		(1,711	)		1,066			1,706			1,903
Cash Flows from Investing Activities:
Activities in available-for-sale securities:
Purchases		(7,611	)		(7,622	)		(4,828	)		(5,389	)
Sales proceeds		7,863			5,192			2,517			2,809
Maturities, prepayments and calls		2,226			2,534			3,956			4,416
Activities in held to maturity securities:
Purchases		(637	)		(983	)		(1,112	)		(1,241	)
Maturities, prepayments and calls		600			604			916			1,022
Acquisition of subsidiaries		—			561			(54	)		(60	)
Disposal of subsidiaries		37			19			—			—
Purchases of premises and equipment and intagibles		(133	)		(200	)		(849	)		(948	)
Proceeds from sales of premises and equipment and intagibles		4			2			12			13
Disposals/(acquisitions) of equity investments		(14	)		—			16			18
Net cash provided by (used in):
Deposits with central bank		13			(525	)		(129	)		(144	)
Loan origination and principal collections		(322	)		3,630			(2,114	)		(2,360	)
Securities purchased under agreements to resell		(160	)		795			(56	)		(63	)
Interest bearing deposits with banks		791			(340	)		556			621
Other		(111	)		—			—			—

Cash flows provided by / (used in) investing activities		2,546			3,667			(1,169	)		(1,306	)

The accompanying notes are an integral part of these consolidated financial statements.

	Year ended December 31

	2012			2013			2014			2014
	(EUR in millions)			(EUR in millions)			(EUR in millions)			(USD in millions) (Note 2)
										Unaudited
Cash flows from Financing Activities:
Proceeds from issuance of long-term debt		519			480			3,225			3,600
Principal repayments and retirements of long-term debt		(1,033	)		(274	)		(1,963	)		(2,191	)
Proceeds from issuance of common and preferred stock (net of issue costs of EUR 10 million in 2012, EUR 239 million in 2013 and EUR 74 million in 2014)		(10	)		840			2,426			2,708
Repurchase of preference shares		—			(119	)		—			—
Purchases of treasury stock		(121	)		(47	)		(81	)		(90	)
Proceeds from sales of treasury stock		120			45			84			94
Acquisition of and increase of controlling interest in subsidiary companies		(38	)		(8	)		(278	)		(310	)
Sale of Real Estate accounted for as financing obligation		—			544			43			48
Deposits		(750	)		(9,925	)		(4,084	)		(4,559	)
Securities sold under agreements to repurchase		(194	)		3,629			316			353
Other borrowed funds		1,101			15			509			568

Cash flows provided by /(used in) financing activities		(406	)		(4,820	)		197			221
Effect of exchange rate change on cash and due from banks		9			(102	)		25			29
Net increase/(decrease) in cash and due from banks		438			(189	)		759			847
Cash and due from banks at beginning of year		1,719			2,157			1,968			2,197

Cash and due from banks at end of year		2,157			1,968			2,727			3,044
Supplemental Disclosure of Cash Flow Information:
Cash paid for:
Income taxes		124			203			139			155
Interest		2,625			2,101			1,910			2,132
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			—			—
Fair value of interest retained (49.00%) in the former subsidiary Cigna Finans Pension (see Note 4)		104			—			—			—

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 of December 31, 2014, 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 Thursday, April 30, 2015 which was EUR 0.8959 to USD 1.00 (EUR 0.8237 to USD 1.00 on December 31, 2014).

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 and the Bank of Greece regulations (collectively, Greek GAAP), except for foreign subsidiaries which maintain their accounting records in accordance with the legislation and regulations of the country in which they operate. Necessary adjustments are made, for financial reporting purposes, in order to comply with US GAAP.

Going concern—As at December 31, 2014, NBG's collateralized funding from the European Central Bank ("ECB") amounted to EUR 14.2 billion of which NIL through Emergency Liquidity Assistance ("ELA"). This funding was collateralized in part by Greek government and Greek government-guaranteed bonds.

As a result of the on-going negotiations between the new Greek government and the European Commission, the ECB and International Monetary Fund ("IMF") (collectively the "Institutions") towards reaching a permanent agreement, the ECB lifted the waiver on the eligibility of these bonds as collateral for ECB funding until persuasive positive signs that the new Greek government will reach an agreement with the Institutions. Consequently, an increased reliance is placed on the Bank of Greece via its ELA facility which is under strict control by the ECB.

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 6.4 billion occurred between January 1 and April 30, 2015. The 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 to the Greek banks in the future.

From a capital adequacy perspective, following the two successful share capital increases in 2013 for EUR 9.8 billion and in 2014 for EUR 2.5 billion the Group's "Adjusted CET 1" ratio at December 31, 2014 was 13.6%, excluding the impact of Greek Law 4303/2014 ("DTC Law"), see Note 36. Moreover, the planned capital actions are expected to further increase the CET1 ratio.

Furthermore, the Bank successfully passed the EU-wide Comprehensive Assessment including an Asset Quality Review ("AQR") and Stress Test. The Adverse Dynamic Balance Sheet stress test, which is based on the Bank's approved Restructuring Plan resulted in a CET1 ratio of 8.9%, and a capital surplus of EUR 2.0 billion. In addition, the Bank's Extraordinary General Meeting held on November 7, 2014 resolved to opt-in for the provisions of the DTC Law, which increases the capital surplus, under this scenario, by a further EUR 0.7 billion.

The access to adequate funds depends to a large extent on to a new agreement to be reached between the Greek government and the Institutions. To this end the Eurogroup decided on February 20, 2015 to extend the Master Financial Assistance Facility Agreement ("MFFA") for Greece and the availability of EFSF funds for Greece (albeit transferred from HFSF to EFSF) by four months until June 2015, in order to allow time for an agreement to be negotiated and concluded by the so called "Brussels Group" comprising the above Institutions and representatives of European Supervisory Mechanism ("ESM")/EFSF.

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 those amounts included in the balance sheet caption "Cash and due from banks".

Securities: Trading, Available-for-Sale (AFS), Held-to-Maturity (HTM)—Debt securities are classified as trading, available-for-sale or held-to-maturity and equity securities are classified as trading or

available-for-sale, based on management's intention on the date of purchase. Debt securities which management has the positive intent and ability to hold to maturity are classified as held-to-maturity and are reported at amortized cost. Debt and equity securities that are bought and held principally for the purpose of resale in the near term are classified as trading instruments and are stated at fair value with realized and unrealized gains and losses included in net trading 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 2013 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 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 22 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 six 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.

Assets that are classified as "foreclosed assets" are included in other assets upon actual foreclosure or when physical possession of the collateral is taken, through mutual agreement or court action. These assets are reported as held for sale in accordance with ASC 360-10-45-9. Foreclosed properties are initially measured at the fair value of the property less estimated costs to sell. Prior to foreclosure, any write-downs, if necessary, are charged to the allowance for loan losses. Subsequent to foreclosure, gains or losses on the sale of, and losses on the periodic revaluation of, foreclosed properties are recorded in "Net other income/(expense)".

Discontinued operations—A discontinued operation is a component of the Group that comprises operations and cash flows that can be clearly distinguished, operationally and for financial reporting purposes, from the rest of the entity. Classification as discontinued operations occurs upon disposal or when the operations meet the criteria to be classified as held for sale. Discontinued operations are presented on the face of the consolidated statement of income and comprehensive income.

Dividend policy—The Bank, on the basis of its statutory financial statements prepared in accordance with IFRS as endorsed by the European Union ("EU"), pays dividends out of:

Each year the Bank is required, by Greek Company Law 2190/1920, to declare and distribute a minimum dividend out of its net profits, if any, equal to 35% of the net profits for the year less statutory reserves, any profits resulting from the sale of equity participations that represent at least 20% of the paid up share capital of a subsidiary company in which the Bank has held an equity participation for at least ten years and unrealized net gains from financial instruments.

Any distribution of the remainder of the distributable profits must be approved by a General Meeting of the Shareholders with the ordinary quorum and majority voting requirements. No distribution can be effected if, on the closing date of the last financial year, the total shareholders' equity is, or will become after that distribution, lower than the sum of share capital and the reserves, the distribution of which is prohibited by Greek Law or the Bank's Articles of Association.

A majority representing at least 65% of the paid-up share capital may vote to waive this. The undistributed dividend (up to 35% minimum dividend) must then be transferred to a special reserve which must, within four years following the General Meeting of the Shareholders be distributed in the form of a stock dividend. Furthermore, a majority representing at least 70% of the Bank's paid-up capital may vote to waive this stock dividend.

According to the provisions of article 28 of Greek Law 3756/2009 and decision 20708/B/1175/23.4.2009 of the Minister of Finance, banks participating in the Hellenic Republic Bank Support Plan were allowed to distribute dividends to ordinary shareholders only in the form of shares, but excluding treasury shares, for the financial year ended on December 31, 2008. Also, pursuant to the provisions of article 39 of Greek Law 3844/2010, article 28 of Greek Law 3576/2009 was modified to provide that the restriction of dividends distribution to ordinary shareholders only in the form of shares, but excluding treasury shares, was applicable and for the financial year ended on December 31, 2009. This restriction did not include any dividend or fixed return on preference shares that are being

traded in foreign organized markets, as well as any interim dividend paid which, however, is included in the calculation of the minimum dividend of 35%.

Normally, dividends are declared and paid in the year subsequent to the reporting period. Banks participating in the plan were allowed to distribute dividends, for 2010 and 2011, only in the form of shares; however, these could not be treasury shares, in accordance with Greek Law 3965/2011 and Greek Law 4063/2012, respectively. 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.

The restrictions of Greek Law 3723/2008 regarding the distribution of dividends apply by analogy to the Bank as a result of its participation in the recapitalization framework of Greek Law 3864/2010. In addition, for so long as the Bank participates in the recapitalization framework of Greek Law 3864/2010, HFSF's representative who sits on the Bank's Board of Directors has the power to veto any decision of the Board of Directors of the Bank regarding, inter alia, the distribution of dividends and remunerations.

In addition, pursuant to the commitments undertaken by the Hellenic Republic vis-à-vis the European Commission due to the provision of state-aid to Greek banks, the Bank is prohibited from distributing dividends or paying coupons on own fund instruments or releasing reserves to put itself in such a position until the end of the restructuring period, unless such payment fulfills legal obligation of the Bank or the Directorate General for Competition of the European Commission grants a relevant exception.

Resale and repurchase agreements—The Group enters into securities purchases under agreements to resell (resale agreements) and securities sales under agreements to repurchase (repurchase agreements) of substantially identical securities. Resale agreements and repurchase agreements are accounted for as secured lending and secured borrowing transactions, respectively.

The amounts advanced under resale agreements and the amounts borrowed under repurchase agreements are carried on the 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 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 February 2013, the FASB issued ASU 2013-04, "Obligations Resulting from Joint and Several Liability Arrangements for Which the Total Amount of the Obligation Is Fixed at the Reporting Date (a consensus of the FASB Emerging Issues Task Force)", which requires an entity to measure obligations resulting from joint and several liability arrangements for which the total amount of the obligation within the scope of this guidance is fixed at the reporting date, as the sum of the following:

The guidance in this ASU also requires an entity to disclose the nature and amount of the obligation as well as other information about these obligations. These amendments are effective for fiscal years, and interim periods within those years, beginning after December 15, 2013. 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 March 2013, the FASB issued ASU 2013-05, "Parent's Accounting for the Cumulative Translation Adjustment upon Derecognition of Certain Subsidiaries or Groups of Assets within a Foreign Entity or of an Investment in a Foreign Entity". According to these amendments, when a reporting entity (parent) ceases to have a controlling financial interest in a subsidiary or group of assets that is a nonprofit activity or a business (other than a sale of in substance real estate or conveyance of oil and gas mineral rights) within a foreign entity, the parent is required to apply the guidance in Subtopic 830-30 to release any related cumulative translation adjustment into net income. Accordingly, the cumulative translation adjustment should be released into net income only if the sale or transfer results in the complete or substantially complete liquidation of the foreign entity in which the subsidiary or group of assets had resided.

For an equity method investment that is a foreign entity, the partial sale guidance in Section 830-30-40 still applies. As such, a pro rata portion of the cumulative translation adjustment should be released into net income upon a partial sale of such an equity method investment. However, this treatment does not apply to an equity method investment that is not a foreign entity. In those instances, the cumulative translation adjustment is released into net income only if the partial sale represents a complete or substantially complete liquidation of the foreign entity that contains the equity method investment.

Additionally, the amendments in this Update clarify that the sale of an investment in a foreign entity includes both (1) events that result in the loss of a controlling financial interest in a foreign entity (that is, irrespective of any retained investment) and (2) events that result in an acquirer obtaining control of an acquiree in which it held an equity interest immediately before the acquisition date (sometimes also referred to as a step acquisition). Accordingly, the cumulative translation adjustment should be released into net income upon the occurrence of those events. These amendments are effective prospectively for fiscal years (and interim reporting periods within those years) beginning after December 15, 2013. 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 July 2013, the FASB issued ASU 2013-11 "Income Taxes (Topic 740) Presentation of an Unrecognized Tax Benefit When a Net Operating Loss Carry- forward, a Similar Tax Loss, or a Tax Credit Carry-forward Exists". An unrecognized tax benefit, or a portion of an unrecognized tax benefit, should be presented in the financial statements as a reduction to a deferred tax asset for a net operating loss carryforward, a similar tax loss, or a tax credit carry- forward, except as follows. To the extent a net operating loss carry-forward, a similar tax loss, or a tax credit carry-forward is not available at the reporting date under the tax law of the applicable jurisdiction to settle any additional income taxes that would result from the disallowance of a tax position or the tax law of the applicable jurisdiction does not require the entity to use, and the entity does not intend to use, the deferred tax asset for such purpose, the unrecognized tax benefit should be presented in the financial statements as a liability and should not be combined with deferred tax assets. The assessment of whether a deferred tax asset is available is based on the unrecognized tax benefit and deferred tax asset that exist at the

reporting date and should be made presuming disallowance of the tax position at the reporting date. For example, an entity should not evaluate whether the deferred tax asset expires before the statute of limitations on the tax position or whether the deferred tax asset may be used prior to the unrecognized tax benefit being settled. The amendments in this Update are effective for fiscal years, and interim periods within those years, beginning after December 15, 2013. Early adoption is permitted. The amendments should be applied prospectively to all unrecognized tax benefits that exist at the effective date. Retrospective application is permitted. 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 November 2014, the FASB issued ASU 2014-17 "Business Combinations (Topic 805), Pushdown Accounting". The amendments in this Update provide an acquired entity with an option to apply pushdown accounting in its separate financial statements upon occurrence of an event in which an acquirer obtains control of the acquired entity. An acquired entity may elect the option to apply pushdown accounting in the reporting period in which the change-in-control event occurs. An acquired entity should determine whether to elect to apply pushdown accounting for each individual change-in-control event in which an acquirer obtains control of the acquired entity. If pushdown accounting is not applied in the reporting period in which the change-in-control event occurs, an acquired entity will have the option to elect to apply pushdown accounting in a subsequent reporting period to the acquired entity's most recent change-in-control event. An election to apply pushdown accounting in a reporting period after the reporting period in which the change-in-control event occurred should be considered a change in accounting principle in accordance with Topic 250, Accounting Changes and Error Corrections. If pushdown accounting is applied to an individual change-in-control event, that election is irrevocable. If an acquired entity elects the option to apply pushdown accounting in its separate financial statements, it should disclose information in the current reporting period that enables users of financial statements to evaluate the effect of pushdown accounting. Effective immediately (November 18, 2014). The implementation of these amendments by the Group did not have impact on the Group's financial position and results of operations.

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. Early adoption 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 2014-14 "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 amendments in this Update are effective for annual periods, and interim periods within those annual periods, beginning after December 15, 2014. 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 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". The amendments in this Update change the requirements for reporting discontinued operations in Subtopic 205-20. The amendments in this Update improve the definition of discontinued operations by limiting discontinued operations reporting to disposals of components of an entity that represent strategic shifts that have (or will have) a major effect on an entity's operations and financial results. Under U.S. GAAP, many disposals, some of which may be routine in nature and not a change in an entity's strategy, are reported in discontinued operations. A discontinued operation may include a component of an entity or a group of components of an entity, or a business or nonprofit activity. A disposal of a component of an entity or a group of components of an entity is required to be reported in discontinued operations if the disposal represents a strategic shift that has (or will have) a major effect on an entity's operations and financial results when any of the following occurs:

The amendments in this Update are effective prospectively to both of the following:

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 guidance in this Update supersedes the revenue recognition requirements in Topic 605, Revenue Recognition, and most industry-specific guidance throughout the Industry Topics of the Codification. Additionally, this Update supersedes some cost guidance included in Subtopic 605-35, Revenue Recognition—Construction-Type and Production-Type Contracts.

The core principle of the guidance is that an entity should recognize revenue to depict the transfer of promised goods or services to customers in an amount that reflects the consideration to which the entity expects to be entitled in exchange for those goods or services. To achieve that core principle, an entity should apply the following steps:

The amendments in this Update are effective for annual reporting periods beginning after December 15, 2016, including interim periods within that reporting period. Early application is not permitted. On April 29, 2015 FASB issued a proposed ASU with comments due on May 29, 2015 to defer for one year the effective date of the new revenue standard (ASU 2014-09) for public and non public entities reporting under U.S. GAAP. Early adoption would be permitted as of the original effective date in ASU 2014-09 (i.e. annual reporting beginning after December 15, 2016 including interim reporting periods within the annual periods). 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 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 amendments in this Update are effective for the first interim or annual period beginning after December 15, 2014. The Group has not applied these amendments and has not yet determined their impact on the Group's disclosures.

In August 2014, the FASB issued ASU 2014-13 "Measuring the Financial Assets and the Financial Liabilities of a Consolidated Collateralized Financing Entity". A reporting entity that consolidates a collateralized financing entity within the scope of this Update may elect to measure the financial assets and the financial liabilities of that collateralized financing entity using either the measurement alternative included in this Update or Topic 820 on fair value measurement. When the measurement alternative is not elected for a consolidated collateralized financing entity within the scope of this Update, the amendments clarify that (1) the fair value of the financial assets and the fair value of the financial liabilities of the consolidated collateralized financing entity should be measured using the

requirements of Topic 820 and (2) any differences in the fair value of the financial assets and the fair value of the financial liabilities of that consolidated collateralized financing entity should be reflected in earnings and attributed to the reporting entity in the consolidated statement of income (loss). When a reporting entity elects the measurement alternative included in this Update for a collateralized financing entity, the reporting entity should measure both the financial assets and the financial liabilities of that collateralized financing entity in its consolidated financial statements using the more observable of the fair value of the financial assets and the fair value of the financial liabilities. If the fair value of the financial assets of the collateralized financing entity is more observable, those financial assets should be measured at fair value and the financial liabilities should be measured in consolidation as (1) the sum of the fair value of the financial assets and the carrying value of any nonfinancial assets held temporarily, less (2) the sum of the fair value of any beneficial interests retained by the reporting entity (other than those that represent compensation for services) and the reporting entity's carrying value of any beneficial interests that represent compensation for services. The resulting amount should be allocated to the individual financial liabilities (other than the beneficial interests retained by the reporting entity) using a reasonable and consistent methodology. If the fair value of the financial liabilities of the collateralized financing entity is more observable, those financial liabilities should be measured at fair value and the financial assets should be measured in consolidation as (1) the sum of the fair value of the financial liabilities (other than the beneficial interests retained bythe reporting entity), the fair value of any beneficial interests retained by the reporting entity (other than those that represent compensation for services), and the reporting entity's carrying value of any beneficial interests that represent compensation for services, less (2) the carrying value of any nonfinancial assets held temporarily. The resulting amount should be allocated to the individual financial assets using a reasonable and consistent methodology. The amendments in this Update 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. Beneficial interests retained by the reporting entity that represent compensation for services (for example, management fees or servicing fees) and nonfinancial assets that are held temporarily by a collateralized financing entity should be measured in accordance with other applicable Topics. The amendments in this Update 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).

Management's evaluation should be based on relevant conditions and events that are known and reasonably knowable at the date that the financial statements are issued (or at the date that the financial statements are available to be issued when applicable).

Substantial doubt about an entity's ability to continue as a going concern exists when relevant conditions and events, considered in the aggregate, indicate that it is probable that the entity will be unable to meet its obligations as they become due within one year after the date that the financial statements are issued (or available to be issued). The term probable is used consistently with its use in Topic 450, Contingencies. When management identifies conditions or events that raise substantial doubt about an entity's ability to continue as a going concern, management should consider whether its plans that are intended to mitigate those relevant conditions or events will alleviate the substantial doubt. The mitigating effect of management's plans should be considered only to the extent that (1) it is probable that the plans will be effectively implemented and, if so, (2) it is probable that the plans will mitigate the conditions or events that raise substantial doubt about the entity's ability to continue as a going concern.

If conditions or events raise substantial doubt about an entity's ability to continue as a going concern, but the substantial doubt is alleviated as a result of consideration of management's plans, the entity should disclose information that enables users of the financial statements to understand all of the following (or refer to similar information disclosed elsewhere in the footnotes):

If conditions or events raise substantial doubt about an entity's ability to continue as a going concern, and substantial doubt is not alleviated after consideration of management's plans, an entity should include a statement in the footnotes indicating that there is 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 available to be issued). Additionally, the entity should disclose information that enables users of the financial statements to understand all of the following:

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 and has not yet determined their impact on the Group's 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 GAAP for determining when separation of certain embedded derivative features in a hybrid

financial instrument is required. That is, an entity will continue to evaluate whether the economic characteristics and risks of the embedded derivative feature are clearly and closely related to those of the host contract, among other relevant criteria. The amendments clarify how current 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. Specifically, the assessment of the substance of the relevant terms and features should incorporate a consideration of (1) the characteristics of the terms and features themselves (for example, contingent versus non-contingent, in-the-money versus out-of-the-money), (2) the circumstances under which the hybrid financial instrument was issued or acquired (for example, issuer-specific characteristics, such as whether the issuer is thinly capitalized or profitable and well-capitalized), and (3) the potential outcomes of the hybrid financial instrument (for example, the instrument may be settled by the issuer issuing a fixed number of shares, the instrument may be settled by the issuer transferring a specified amount of cash, or the instrument may remain legal-form equity), as well as the likelihood of those potential outcomes.

The amendments in this Update are effective for public business entities for fiscal years, and interim periods within those fiscal years, beginning after December 15, 2015. 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 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 effective date is the same for both public business entities and all other entities. The Group has not applied these amendments and has not yet determined their impact on the presentation of the Group's results of operations and disclosures.

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.

An entity should apply the new guidance on a retrospective basis, wherein the balance sheet of each individual period presented should be adjusted to reflect the period-specific effects of applying the new guidance. Upon transition, an entity is required to comply with the applicable disclosures for a change in an accounting principle. These disclosures include the nature of and reason for the change in accounting principle, the transition method, a description of the prior-period information that has been retrospectively adjusted, and the effect of the change on the financial statement line items (that is, debt issuance cost asset and the debt liability). 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. 2015-04—"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 the Group.

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 Update will 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 will be effective for public business entities for annual periods, including interim periods within those annual periods, beginning after December 15, 2015. Early adoption is permitted for all entities. An entity can elect to adopt the amendments either (1) prospectively to all arrangements entered into or materially modified after the effective date or (2) retrospectively. For prospective transition, the only disclosure requirements at transition are the nature of and reason for the change in accounting principle, the transition method, and a qualitative description of the financial statement line items affected by the change. For retrospective transition, the disclosure requirements at transition include the requirements for prospective transition and quantitative information about the effects of the accounting change. 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 Accounting Standards Update No. 2015-07—Fair Value Measurement (Topic 820). Topic 820, Fair Value Measurement, permits a reporting entity, as a practical expedient, to measure the fair value of certain investments using the net asset value per share of the investment. Currently, investments valued using the practical expedient are categorized within the fair value hierarchy on the basis of whether the investment is redeemable with the investee at net asset value on the measurement date, never redeemable with the investee at net asset value, or redeemable with the investee at net asset value at a future date.

To address the diversity in practice related to how certain investments measured at net asset value with future redemption dates are categorized, the amendments in this Update remove the requirement to categorize investments for which fair values are measured using the net asset value per share practical expedient. It also limits disclosures to investments for which the entity has elected to measure the fair value using the practical expedient.

This Accounting Standards Update is the final version of Proposed Accounting Standards Update EITF-14B—Fair Value Measurement—Disclosures for Investments in Certain Entities that Calculate Net Asset Value per Share (or Its Equivalent) (Topic 820), which has been deleted.

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. The retrospective approach requires that an investment for which fair value is measured using the net asset value per share practical expedient be removed from the fair value hierarchy in all periods presented in an entity's financial statements. 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 Accounting Standards Update No. 2015-08—Business Combinations (Topic 805). This Accounting Standards Update amends various SEC paragraphs pursuant to the issuance of Staff Accounting Bulletin No. 115. This ASU is applicable to all entities and is effective upon issuance (issuance date May 8, 2015).

NOTE 4: MERGERS, ACQUISITIONS, DISPOSALS AND NEW ENTITIES ESTABLISHED (Continued)

The following table summarises the fair value of assets and liabilities acquired of Picasso—Fondo as of 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".

NOTE 4: MERGERS, ACQUISITIONS, DISPOSALS AND NEW ENTITIES ESTABLISHED (Continued)

The following tables summarise 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:

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 finalised 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 recognised directly in the income statement within the "Other non-interest income" line item.

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 finalised 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 recognised 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 recognised in the consolidated statement of income and comprehensive income within the "Other-Than-Temporary-Impairment (of which NIL was recognised 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 of December 31,2013.

The following table summarises the fair value of assets and liabilities of KARELA S.A. as of the date of acquisition which is February 15, 2013.

NOTE 4: MERGERS, ACQUISITIONS, DISPOSALS AND NEW ENTITIES ESTABLISHED (Continued)

The gain is included in the caption of the income statement "Other non-interest income".

The portion of the gain related to the remeasurement of the investment retained in the former subsidiary amounted to EUR 89 million and was determined as follows:

The fair value of the 49.00% interest retained in Cigna Finans Pension, was determined by reference to the cash consideration received for the 51.00% disposed of, taking also into consideration the fact that Finansbank is entitled to dividends from Cigna Finans Pension in excess of its 49.00% shareholding, provided certain performance thresholds are achieved.

NOTE 4: MERGERS, ACQUISITIONS, DISPOSALS AND NEW ENTITIES ESTABLISHED (Continued)

The schedule below presents the effect of changes in NBG Group's ownership interest in its subsidiaries on NBG Group's equity at December 31, comprised:

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, 2014 while the corresponding deposits of Finansbank, UBB and certain other subsidiaries are non-interest bearing.

The Group enters into purchases of securities under agreements to resell substantially identical securities. These agreements are classified as lending arrangements. Agreements with third parties specify the Group's rights to request collateral, based on its monitoring of the fair value of the underlying securities on a daily basis. Securities accepted as collateral may be sold or re-pledged. The Group has sold or re-pledged as at December 31, 2013 and 2014, EUR 72 million and NIL, respectively, 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 60 million, EUR 126 million and EUR 13 million were included in net trading gains/(loss) during 2012, 2013 and 2014, respectively.

Trading assets include securities that are pledged as collateral of EUR 2,470 million and EUR 931 million as at December 31, 2013 and 2014, respectively.

Derivative instruments that the Group may use as part of its interest rate risk management strategy include interest rate swaps, interest rate floors, interest rate caps, forward rate agreements and options. Interest rate swap contracts are exchanges of interest payments, such as fixed-rate payments for floating-rate payments, based on a stated notional amount and maturity date. Interest rate floors protect against declining rates, while interest rate caps protect against rising interest rates. Forward rate agreements are contracts in which the buyer agrees to purchase, and the seller agrees to make delivery of, a specific financial instrument at a predetermined price or yield. Options provide the purchaser with the right, but not the obligation, to purchase or sell a contracted item during a specified period at an agreed upon price.

Foreign currency volatility occurs as the Group enters into transactions involving certain assets and liabilities denominated in foreign currencies, as well as a result of the Group's international operations, particularly of Finansbank in Turkey. Derivative instruments that the Group may use to economically hedge these foreign denominated assets and liabilities include foreign exchange swaps and outright foreign exchange forwards. The Group closely monitors its exposure to the Turkish lira arising from the net investment in Finansbank and when necessary it engages in foreign exchange swaps and other economic hedging transactions in order to reduce the volatility in the Group's equity arising on the translation of Finansbank's net assets from TRY to EUR.

The following tables present the contract or notional amounts and the fair value amounts (which include the maximum exposure to credit risk) at December 31, 2013 and 2014 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.

Credit derivative liabilities at December 31, 2013 and December 31, 2014 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, 2012, 2013 and 2014 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 well 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, 2013 and 2014, the potential maximum loss for the credit contracts sold amounted to EUR 693 million and EUR 457 million against which the Group held cash collateral equal to NIL and NIL respectively. As at December 31, 2014, credit contracts sold comprise of a written guarantee of EUR 322 million 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. Therefore, the disclosed notional amount overstates the Group's realistic exposure. As at December 31, 2014, the fair value of the respective derivative liability amounted to EUR 4 million with a remaining time to maturity of around 25 years.

As at December 31, 2013 and 2014, "Other" under derivative assets includes a warrant instrument linked to Greek GDP that was received in the context of the PSI (see Note 11). The fair value of the respective instrument at December 31, 2013 and 2014, amounted to EUR 41 million and EUR 20 million and corresponded to an outstanding notional amount of EUR 3.5 billion and EUR 2.9 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, 2012, 2013, and 2014.

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, 2012, 2013 and 2014 amounted to a cumulative gain of EUR 77 million, EUR 30 million and EUR 81 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, 2013 and at December 31, 2014, the Group held cash and securities collateral of EUR 941 million and EUR 1,351 million and posted cash and securities collateral of EUR 1,447 million and EUR 1,590 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, 2014, has triggered this provision in the contract. In such an event, the amount that would be required to settle the position depends on the contract and is usually the market value of the exposure on that day less any amount that has already been posted as collateral under CSAs. Therefore, for derivatives subject to CSAs that are executed on a daily margin basis, the additional amount that would be required to settle the position is a two day change in the mark to market of the instrument which as of December 31, 2013 and 2014, amounted to EUR 7 million and EUR 17 million, respectively.

The amortized cost of available-for-sale securities and their fair values at December 31, comprised:

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, 2013. The table also discloses whether these securities have had unrealized losses for periods less than 12 months or for 12 months or longer.

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.

The scheduled maturities of available-for-sale securities at December 31, 2013 and 2014 were as follows:

Available for sale securities include securities that are pledged as collateral of EUR 3,229 million and EUR 1,621 million as at December 31, 2013 and 2014, 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 2012, 2013 and 2014.

	2012

	(EUR in millions)
Gross realized gains on sales of available for sale securities
Greek government bonds		382		12		17
Debt securities issued by other governments and public sector entities		31		72		13
Corporate debt securities		8		109		15
Equity securities		2		57		30
Mutual fund units		15		49		39

Total gross realized gains on sales of available for sale securities		438		299		114

Gross realized losses on sales of available for sale securities
Greek government bonds		(73	)	(3	)	(8	)
Debt securities issued by other governments and public sector entities		(11	)	(3	)	(3	)
Corporate debt securities		—		(15	)	—
Equity securities		(1	)	(23	)	(3	)
Mutual fund units		(3	)	(5	)	—

Total gross realized losses on sales of available for sale securities		(88	)	(49	)	(14	)

Net realized gains / (losses) on sales of available for sale securities		350		250		100



Other-Than-Temporary-Impairment
OTTI of Greek government bonds		(378	)	—		—
Debt securities issued by other governments and public sector entities		(6	)	—		—
Corporate debt securities		(10	)	(11	)	(1	)
Equity securities		(16	)	(274	)	(5	)

Total Other-Than-Temporary-Impairment		(410	)	(285	)	(6	)

Net gains / (losses) on available for sale and held to maturity securities		(60	)	(35	)	94

Other than temporary impairment charges for 2012 included charges related to Greek government bonds eligible for the PSI of EUR 352 million.

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 9,091 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). 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 unrecognized losses of held-to-maturity securities in an unrecognized loss position as at December 31, 2013. The table also

discloses whether these securities have had unrecognized losses for periods less than 12 months or for 12 months or longer.

There are no unrecognized losses of held-to-maturity securities as at December 31, 2014.

The scheduled maturities of held-to-maturity securities at December 31, 2013 and 2014 were as follows:

Held to maturity securities include securities that are pledged as collateral of EUR 9,723 million and EUR 9,440 million as at December 31, 2013 and 2014, 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

Other than the OTTI charges recognized for the Greek government bonds due to the PSI, as discussed above, the Group recognized OTTI charges in relation to all the bonds held that are issued by the Cyprus Republic, Bank of Cyprus and Cyprus Popular Bank because, as at December 31, 2012, the Group considered that a credit loss existed with respect to these securities due to the financial difficulties faced by the issuers.

During 2012 the Group recognized OTTI charges in relation to the majority of its equity securities and mutual fund units held with significant and prolonged unrealized losses. In particular, the Group recognized OTTI charges for all equity securities and mutual fund units for which an OTTI was recognized in previous periods and, as at December 31, 2012, were in an unrealized loss position. As at December 31, 2012, gross unrealized losses existing for twelve months or more for equity securities and mutual fund units are not material and were not considered impaired as the losses were not significant to the respective investments held.

For other debt securities issued by Greek financial institutions no OTTI has been recognized based on management's assessment that the Group neither has the intention to sell nor expects it will be required to sell these securities before the recovery of their respective amortized cost bases, and that the issuers' payment obligations associated with these positions will be met on time and the full amount will be recovered. A key factor considered in this assessment was the existence of the recapitalization plan for the Greek banks and that the recapitalization process was progressing and was expected to be completed by June 2013.

With respect to debt securities issued by companies incorporated outside Greece the loss of EUR 42 million relates to debt securities issued mainly by major European and American banks and insurance companies. We consider that these banks and insurance companies would 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, 2012.

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 debt securities issued by other governments and public sector entities the unrealized losses over one year of EUR 11 million relate to debt securities issued by the Republic of Turkey, held by our subsidiary in Turkey, Finansbank. We consider the unrealized losses insignificant, as they represent on average only 3.1% of the corresponding amortized cost basis and that the Republic of Turkey 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.

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.

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.

Loans granted by the Group according to type of loan, which represents the Group's concentration of credit risk, at December 31, 2013 and 2014 comprised:

	2013									2014

	Greek residents			Foreign			Total			Greek residents			Foreign			Total
	(EUR in millions)
Consumer:
Residential mortgages		17,720			3,889			21,609			17,458			3,679			21,137
Credit card		1,381			4,244			5,625			1,317			3,526			4,843
Auto financing		138			62			200			88			39			127
Other consumer		4,694			3,680			8,374			4,207			4,281			8,488

Total consumer		23,933			11,875			35,808			23,070			11,525			34,595

Commercial:
Industry and mining		4,725			2,322			7,047			5,217			2,894			8,111
Small scale industry		2,123			1,721			3,844			1,929			2,502			4,431
Trade		7,562			3,722			11,284			7,425			5,299			12,724
Construction		1,082			1,999			3,081			1,098			2,103			3,201
Tourism		612			348			960			607			508			1,115
Shipping and transportation		2,174			786			2,960			2,437			852			3,289
Commercial mortgages		579			262			841			529			228			757
Public sector		5,848			252			6,100			5,390			232			5,622
Other		655			858			1,513			600			689			1,289

Total commercial		25,360			12,270			37,630			25,232			15,307			40,539

Total loans		49,293			24,145			73,438			48,302			26,832			75,134
Unearned income		(48	)		(155	)		(203	)		(67	)		(159	)		(226	)

Loans, net of unearned income		49,245			23,990			73,235			48,235			26,673			74,908
Less: Allowance for loan losses		(6,211	)		(1,540	)		(7,751	)		(7,788	)		(1,704	)		(9,492	)

Net Loans		43,034			22,450			65,484			40,447			24,969			65,416

Included in the above table for 2013 and 2014 are loans that are economically hedged for interest rate risk, for which the Group elected the fair value option. The fair value and outstanding principal balance of these loans at December 31, 2014 was EUR 42 million and EUR 41 million respectively (EUR 76 million and EUR 75 million respectively at December 31, 2013). Net gains / (losses) resulting from changes in the fair value of these loans of EUR (12) million and NIL in 2013 and 2014 respectively were recorded in net interest income before provision for loan losses.

Also, included in the above tables are loans for lease financing amounting to EUR 1,524 million and EUR 1,564 million in 2013 and 2014 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, 2013 and 2014:

	December 31, 2013

													Of which:
	Past due 31-90 days		Past due greater than 90 days		Total Past due loans		Current loans⁽¹⁾		Loans measured at Fair value		Total		+90 days and accruing loans		Non accruing loans
	(EUR in millions)
Greek
Residential mortgages		1,039		4,770		5,809		11,911		—		17,720		466		5,808
Credit card		35		678		713		668		—		1,381		17		661
Other consumer		253		2,337		2,590		2,242		—		4,832		52		2,822
Small business loans		152		2,000		2,152		1,995		—		4,147		—		2,335
Other commercial loans		631		3,243		3,874		17,339		—		21,213		48		4,266

Total Greek loans		2,110		13,028		15,138		34,155		—		49,293		583		15,892



Foreign
Residential mortgages		181		209		390		3,423		76		3,889		—		248
Credit card		118		409		527		3,717		—		4,244		—		728
Other consumer		152		480		632		3,110		—		3,742		—		572
Small business loans		100		565		665		2,482		—		3,147		2		634
Other commercial loans		132		1,217		1,349		7,774		—		9,123		8		1,499

Total Foreign loans		683		2,880		3,563		20,506		76		24,145		10		3,681



Total loans		2,793		15,908		18,701		54,661		76		73,438		593		19,573

	December 31, 2014

													Of which:
	Past due 31-90 days		Past due greater than 90 days		Total Past due loans		Current loans⁽¹⁾		Loans measured at Fair value		Total		+90 days and accruing loans		Non accruing loans
	(EUR in millions)
Greek
Residential mortgages		779		5,227		6,006		11,452		—		17,458		257		6,346
Credit card		27		729		756		561		—		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		3,618		3,895		17,370		—		21,265		40		4,410

Total Greek loans		1,311		14,046		15,357		32,945		—		48,302		305		16,605



Foreign
Residential mortgages		171		215		386		3,250		43		3,679		2		255
Credit card		116		371		487		3,039		—		3,526		—		496
Other consumer		170		467		637		3,683		—		4,320		—		508
Small business loans		106		600		706		3,027		—		3,733		—		645
Other commercial loans		146		1,214		1,360		10,214		—		11,574		3		1,535

Total Foreign loans		709		2,867		3,576		23,213		43		26,832		5		3,439



Total loans		2,020		16,913		18,933		56,158		43		75,134		310		20,044

According to the Group's credit policy, all corporate customers are rated on a 22-grade scale. This rating is based on quantitative and qualitative criteria and is reviewed at least annually. Additionally, each of the Bank's and its subsidiaries' rating systems consider the borrower's industry risk and its relative position within its peer group. Small Business loans are rated through a behavioral model on a 14-grade scale. The ratings scale for corporate and Small Business customers corresponds to likelihood of default. Customers classified as "Satisfactory" have low likelihood of default, customers classified as "Watchlist" have medium to high likelihood of default and customers classified as Substandard have already defaulted.

The following table presents commercial loans credit quality information as at December 31, 2013 and 2014:

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, 2013 and 2014:

	At and for the year ended December 31, 2013

	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		330		—			217		8		—
Other consumer loans		254		—			201		20		—
Small business loans		65		—			56		5		—
Other commercial loans		766		—			595		6		18
With related allowance:
Residential mortgages		6,841		(846	)		6,127		16		26
Credit cards		678		(628	)		657		4		—
Other consumer loans		2,876		(1,791	)		2,766		10		24
Small business loans		2,460		(974	)		2,229		5		8
Other commercial loans		3,305		(1,889	)		6,437		23		14

Total Greek impaired loans		17,575		(6,128	)		19,285		97		90

Foreign
With no related allowance:
Residential mortgages		10		—			11		—		—
Credit cards		257		—			75		30		—
Other consumer loans		17		—			19		2		—
Small business loans		24		—			27		1		—
Other commercial loans		226		—			168		4		—
With related allowance:
Residential mortgages		347		(72	)		206		6		4
Credit cards		466		(291	)		660		8		16
Other consumer loans		569		(359	)		512		35		20
Small business loans		867		(288	)		608		26		2
Other commercial loans		1,774		(476	)		1,424		21		29

Total Foreign impaired loans		4,557		(1,486	)		3,710		133		71

	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		223		—			239		9		9
Small business loans		214		—			140		1		1
Other commercial loans		403		—			557		4		4
With related allowance:
Residential mortgages		6,708		(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		18,661		(7,650	)		17,824		180		113

Foreign
With no related allowance:
Residential mortgages		5		—			9		—		—
Credit cards		56		—			117		1		—
Other consumer loans		32		—			36		1		—
Small business loans		16		—			21		—		—
Other commercial loans		152		—			260		8		—
With related allowance:
Residential mortgages		366		(82	)		373		7		—
Credit cards		437		(257	)		399		1		14
Other consumer loans		492		(332	)		543		38		13
Small business loans		693		(329	)		565		18		—
Other commercial loans		1,719		(584	)		1,548		12		10

Total Foreign impaired loans		3,968		(1,584	)		3,871		86		37

The following table presents the roll-forward of impaired loans for the years ended, December 31, 2013 and 2014:

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 "Mergers, Acquisitions, Disposals and New Entities Established).

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.

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. As a result TDR balances presented in the disclosures "financing receivables modified as troubled debt restructuring during the period" and "troubled debt restructuring by modification programs" are lower than those reported in 2013.

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, 2012, 2013 and 2014.

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 to 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, 2012, 2013 and 2014.

The following table discloses the ageing of financing receivables modified as troubled debt restructurings at December 31, 2012, 2013 and 2014.

An analysis of the change in the allowance for loan losses by portfolio segment for the years ended December 31, follows:

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 31,2013, and 2014 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, 2014, the Group considered (a) the fact that there was 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, 2013.

The following table provides the allowance for loan losses by portfolio segment and the respective recorded investment at December 31, 2014.

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, 2014, 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 2014 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, 2014, 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, 2014 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, 2014, the worse than anticipated trends and the political uncertainty, were reflected in our allowance for loan losses estimated as of December 31, 2014, 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, 2014, 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 2013 and 2014 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, 2013 and December 31, 2014

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 1,398 million and EUR 1,337 million at December 31, 2013 and December 31, 2014, 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 Turkey and South Eastern Europe enforcement of collateral or exhaustion of legal actions take significantly less time than in Greece.

The majority of these loans are secured with properties, for which foreclosure was probable and the impairment was measured based on the fair value of the collateral. These measurements are classified as Level 3 in the fair value hierarchy.

The fair value of the properties was estimated by qualified external or internal appraisers using one or more of the market approach, the income approach or the replacement cost approach. The key inputs, upon which these estimates are based, are market prices of similar properties, market yields and cost estimates. According to the Group impairment methodology, corporate business units that are responsible for the impairment assessment have to ensure that in cases where cash flows are expected from collateral liquidation, collateral value has to be based on a recent (within the current year) independent appraisal from 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 2014, the securitized loans from the VIE Revolver 2008—1 Plc were repurchased by the Bank.

The Bank, through its VIEs, has the following securitized notes in issue as at December 31, 2014:

Revolver 2008—1 Plc, by April 15, 2014 proceeded with the full redemption of the remaining EUR 265 million Class A Notes and the EUR 269 million Class B Notes and from January 29, 2015 is under liquidation.

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, 2014:

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 25).

Furthermore, the Bank has, during 2014, partially or wholely cancelled the following covered bonds issued under Programme II:

The change in International relates to net additions in other private equity business activities of the Group as well as to foreign exchange differences amounting to EUR (32) million and EUR (1) million respectively and to impairment of EUR 9 million in relation to the private equity business of the Group. The decrease in Turkish Operations is due to the foreign exchange differences amounting to EUR 487 million.

The change in International relates to net additions in other private equity business activities of the Group as well as to foreign exchange differences amounting to EUR 22 million and EUR 6 million respectively and to impairment of EUR 58 million in relation to the private equity business of the Group. The increase in Turkish Operations is due to the foreign exchange differences amounting to EUR 87 million.

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, 2014 was the Turkish operations and the goodwill relates to the acquisition of Finansbank.

Goodwill 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") because (a) the reporting unit consists of subsidiaries of the Group, and therefore its operations are directed by the Group, (b) the DDM incorporates the earnings variability associated with the restructuring of the subsidiary operations following its acquisition, and (c) the DDM incorporates management's views of the near and medium term as well as detailed views of current and near future market conditions and strategy.

Underlying assumptions to the valuation models are that the entity comprising the reporting unit will remain subsidiary of the Group, that the general macroeconomic and political conditions in the respective market will remain stable, that economic activity will continue to grow in the medium term and that the reporting units will continue to be able to fund their operations. If any of these conditions changes in the future, it may reduce the value of the reporting units and cause an impairment charge

with respect to the goodwill. The estimated cash flows were updated to reflect the current management estimates and market conditions.

For the Turkish banking operations reporting unit the DDM was based on a 6.2% (2013: 5.5%) terminal growth rate and 16.6% (2013: 18.6%) pretax 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, 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 (2013: EUR 0.2 billion) and EUR 0.2 billion (2013: EUR 0.4 billion) respectively. In addition, a 5% decrease in the forecast amounts available for dividends would decrease the fair value by EUR 0.2 billion (2013: EUR 0.2 billion).

The gross carrying amount and accumulated amortization relating to software and other intangibles at December 31 are presented below:

As at December 31, 2014, other intangibles include intangibles identified upon the acquisition of acquired entities and consist of core deposits of EUR 4 million (2013: EUR 5 million), customer relationships of EUR 5 million (2013: EUR 6 million), software of EUR 1 million (2013: EUR 4 million), all of which have finite lives and trade names of EUR 110 million (2013: EUR 106 million) and mutual funds contracts of EUR 2 million (2013: EUR 2 million) which have indefinite lives. The estimated useful lives of core deposits and customer relationships are 6-11 years, while that of software is for a period not exceeding 20 years.

Amortization expense on software and other intangibles amounted to EUR 110 million, EUR 100 million and EUR 84 million in 2012, 2013 and 2014 respectively. The Group estimates that aggregate amortization expense for the five succeeding fiscal years will be EUR 72 million, EUR 57 million, EUR 36 million, EUR 20 million and EUR 10 million for years 2015 through 2019 respectively.

Certain Group premises and equipment are leased under various operating leases. Rental expense amounted to EUR 123 million, EUR 121 million and EUR 119 million for the years ended December 31, 2012, 2013 and 2014, respectively.

Future minimum lease commitments under non-cancellable operating leases are presented below. The Group did not enter into any material capital leases.

Included in the above table are investments on behalf of policyholders who bear the investment risk, classified as Insurance related assets amounting to EUR 382 million and EUR 568 million at December 31, 2013 and 2014 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.

NOTE 17: LONG-LIVED ASSETS HELD FOR SALE AND LIABILITIES DIRECTLY ASSOCIATED WITH LONG-LIVED ASSETS HELD FOR SALE

NOTE 17: LONG-LIVED ASSETS HELD FOR SALE AND LIABILITIES DIRECTLY ASSOCIATED WITH LONG-LIVED ASSETS HELD FOR SALE (Continued)

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 a VIE, 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 are considering a solution within the context of existing competitive process. 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 long-lived 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.

In December 2013, the Bank entered into a binding pre-agreement to dispose of its 100.00% participation on its subsidiary Grand Hotel Summer Palace S.A. and classified the subsidiary as held for sale. As at September 30, 2014, since the criteria for the classification were no longer met because the disposal has not taken place and as a result the pre-agreement is no longer valid, the Group ceased to classify the subsidiary as held for sale. The assets and liabilities of the subsidiary, for the current period, were reclassified to the corresponding line items of the consolidated balance sheet from the lines "Long-lived assets held for sale" and "Liabilities directly associated with long-lived assets held for sale" of the Group (i.e. premises and equipment EUR 8 million, other assets EUR 3 million and other liabilities EUR 1 million). The reclassification of the Grand Hotel Summer Palace S.A. subsidiary out of long-lived assets classified as held for sale had no effect on the results and equity of the Group for the current and prior periods.

Long-lived assets held for sale and the liabilities directly associated with long-lived assets at December 31, comprised:

In "Goodwill, software, other intangibles and premises and equipment" are included premises of Finansbank, amounted to EUR 23 million, which were disposed of by the end of April 2015.

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 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 the Law 3723/2008 and b) the revocation of the decision of the Extraordinary General Meeting of the Bank's Shareholders held on November 26, 2010 regarding the repurchase by the Bank of the 70 million redeemable preference shares in favor of the Greek State, in accordance with the 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. For the redeemable preference shares in favor of the Greek State, please also refer to Note 33.

Under the government-guaranteed borrowings facility, we participated in the second pillar of Greek Law 3723/2008 as follows:

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.

At December 31, 2013 and 2014, the Group pledged mainly for funding purposes with the Eurosystem, the European Investment Bank, other central banks and financial institutions, the amount of EUR 16,327 million and EUR 12,636 million, respectively. The corresponding liabilities are presented in Note 20 within interbank interest bearing deposits.

The pledged amounts as at December 31, 2014 relate to the following instruments:

Additionally to the amounts above, the Bank has pledged off-balance sheet assets for funding purposes with the Eurosystem:

As at December 31, 2014 the Group has pledged to the ECB financial instruments of a nominal value amounting to EUR 18.4 billion.

The aggregate amount of short-term certificates of deposit, each with a minimum denomination of EUR 89,590, which approximates USD 100,000, was EUR 136 million at December 31, 2014 (2013: EUR 268 million). At December 31, 2014, interest-bearing deposits with scheduled maturities in excess of one year were EUR 690 million (2013: EUR 555 million).

Deposits made by Greek residents and foreign customers at December 31, comprised:

	2013						2014

	Greek residents		Foreign		Total		Greek residents		Foreign		Total
	(EUR in millions)						(EUR in millions)
Interest bearing:
Public sector		2,618		525		3,143		2,932		64		2,996
Private sector:
Corporations		5,185		5,187		10,372		5,046		5,910		10,956
Individuals		34,361		11,324		45,685		34,246		12,884		47,130
Interbank		20,915		2,060		22,975		14,667		2,153		16,820

Total interest bearing deposits		63,079		19,096		82,175		56,891		21,011		77,902

Non-interest bearing:
Public sector		313		105		418		228		120		348
Private sector:
Corporations		657		936		1,593		885		1,021		1,906
Individuals		143		1,148		1,291		92		1,191		1,283
Interbank		78		39		117		45		28		73

Total non-interest bearing deposits		1,191		2,228		3,419		1,250		2,360		3,610

Total:
Public sector		2,931		630		3,561		3,160		184		3,344
Private sector:
Corporations		5,842		6,123		11,965		5,931		6,931		12,862
Individuals		34,504		12,472		46,976		34,338		14,075		48,413
Interbank		20,993		2,099		23,092		14,712		2,181		16,893

Total deposits		64,270		21,324		85,594		58,141		23,371		81,512

Included in the above table are interest bearing deposits of EUR 282 million and EUR 16 million for 2013 and 2014 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 2013 gains of EUR 5 million and during 2014 losses of

EUR (1) 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 ECB amounting to EUR 20,700 million and EUR 14,240 million for 2013 and 2014 respectively.

Information concerning securities sold under agreements to repurchase is summarized as follows:

Securities sold under agreements to repurchase are recorded at the amount of cash received in connection with the transaction. Maturities of such agreements to repurchase are typically overnight to six months.

Included in other borrowed funds are facilities with a maturity of one year or less. These borrowings had a balance of EUR 1,678 million and EUR 2,310 million at December 31, 2013 and 2014, respectively.

The weighted average interest rate of other borrowed funds was 6.74% and 4.48% in 2013 and 2014 respectively.

The financial conditions of the major short-term of other borrowed funds as at December 31, 2014, are as follows:

Issuer	Type	Issue date	Maturity date	Currency	Nominal amount			Own held by the Group		Interest rate	Interest payment

					(in million)			(nominal amount in million)
Variable rate notes
Finansbank	Variable Rate Bonds⁽¹⁾	April 9, 2014	March 2015	TRY		311			78	Dibs plus 1.15%	Quarterly
Finansbank	Variable Rate Bonds⁽¹⁾	June 4, 2014	April 2015	TRY		223			49	Dibs plus 1.15%	Quarterly
Finansbank	Variable Rate Bonds⁽¹⁾	November 10, 2014	May 2015	TRY		384			2	Dibs plus 1.10%	Single payment at maturity including capital amount
Finansbank	Variable Rate Bonds⁽¹⁾	November 14, 2014	February 2015	TRY		142			—	Dibs plus 0.80%	Single payment at maturity including capital amount
Finansbank	Variable Rate Bonds⁽¹⁾	November 18, 2014	February 2015	TRY		148			17	Dibs plus 0.60%	Single payment at maturity including capital amount
Finansbank	Variable Rate Bonds⁽¹⁾	November 21, 2014	February 2015	TRY		126			—	Dibs plus 0.80%	Single payment at maturity including capital amount
Finansbank	Variable Rate Bonds⁽¹⁾	December 4, 2014	April 2015	TRY		300			6	Dibs plus 0.60%	Single payment at maturity including capital amount
Finansbank	Variable Rate Bonds⁽¹⁾	December 8, 2014	April 2015	TRY		108			—	Dibs plus 0.80%	Single payment at maturity including capital amount
Finansbank	Variable Rate Bonds⁽¹⁾	December 24, 2014	November 2015	TRY		244			1	Dibs plus 1.20%	Quarterly
Finansbank	Amended Facility Agreement	November 26, 2014	November 2015	USD		396	⁽²⁾		—	Libor plus 1%.	Semi-annually
Finansbank	Amended Facility Agreement⁽²⁾	November 27, 2014	November 2015	EUR		353	⁽²⁾		—	Euribor plus 1%.	Semi-annually

The financial conditions of the major short-term of other borrowed funds after December 31, 2014, are as follows:

Accounts payable, accrued expenses and other liabilities at December 31, comprised:

Included in the above table under "Other" are liabilities carried at fair value, relating to short positions in shares amounting to EUR 2 million and EUR 4 million at December 31, 2013 and 2014 respectively as well as investment products from insurance operations carried at fair value amounting to EUR 64 million and EUR 253 million at December 31, 2013 and December 31, 2014 respectively.

The sale of Real Estate, accounted for as financing obligation of EUR 743 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).

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:

The share of reinsurers in property and casualty insurance reserves amounted to EUR 588 million and EUR 330 million at December 31, 2013 and 2014 respectively.

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.

Interest assumptions used in estimating insurance contract liabilities are based on estimates of investment yields, net of related investment expenses, expected at the time the insurance contracts are made, and include a risk of adverse deviation. Interest assumptions are adjusted in the event that a premium deficiency exists. The interest rate used to estimate 2014 insurance contract liabilities was 3.75%.

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 2012, 2013 and 2014 are premiums assumed of NIL, 1 and NIL respectively.

Net premiums earned on long-duration life insurance contracts amounted to EUR 87 million, EUR 151 million and EUR 94 million for 2012, 2013 and 2014 respectively.

Long-term debt (original maturities of more than one year) at December 31, comprised:

Certain debt instruments were issued by 100% owned "finance subsidiaries" of the Bank, NBG Funding Ltd (unconsolidated) and NBG Finance Plc (consolidated), NBG Finance (Sterling) Plc (consolidated) and NBG Finance (Dollar) Plc (consolidated) (the "finance subsidiaries"). The Bank has fully and unconditionally guaranteed all securities issued by these companies. There are no restrictions on the ability of these "finance subsidiaries" to transfer funds to the Bank in the form of cash dividends, loans and advances.

The Group does not consolidate NBG Funding Ltd as the Group is not deemed to be the primary beneficiary of the entity. The Group does not have the obligation to absorb losses or the right to receive benefits as the only assets of NBG Funding Ltd are loans to and deposits with NBG.

The proceeds of the instruments issued by NBG Funding Ltd were lent to NBG Finance Plc, NBG Finance (Sterling) Plc and NBG Finance (Dollar) Plc through Eurobond issues and ultimately lent to the Bank under loan agreements with the same terms as each of the instruments referred to above but with a 31 year maturity.

Long-term debt Senior Notes and the related rates and maturity dates at December 31, comprise:

The financial conditions of the major long-term senior fixed rate debt as of December 31, 2014, are as follows:

Issuer	Type	Issue date	Maturity date	Currency	Nominal amount			Own held by the Group		Interest rate	Interest payment

					(in million)			(nominal amount in million)
Covered bonds
NBG	Fixed rate covered bonds—Third Series	October 7, 2009	October 2016	EUR		846	⁽¹⁾		—	Fixed coupon rate of 3.875%	Annually
Fixed rate notes
Finansbank	Senior Unsecured Notes	May 11, 2011	May 2016	USD		500			71	Fixed interest rate of 5.5%	Semi-annually
Finansbank	Eurobond Fixed Rate Notes	November 1, 2012	November 2017	USD		350			29	Fixed interest rate of 5.15%	Semi-annually
NBG	Fixed Rate Notes	December 20, 2012	December 2024	EUR		50	⁽²⁾		—	Fixed interest rate of 2.535%	Quarterly
NBG	Fixed Rate Notes	August 5, 2013	August 2023	EUR		50	⁽²⁾		—	Fixed interest rate of 2.519%	Quarterly
NBG	Fixed Rate Notes	December 23, 2013	December 2023	EUR		70	⁽²⁾		—	Fixed interest rate of 2.68%	Semi-annually
NBG	Fixed Rate Notes	January 29, 2014	January 2026	EUR		70	⁽²⁾		—	Fixed interest rate of 2.96%	Semi-annually
Finansbank	Senior Unsecured Notes	April 25, 2014	April 2019	USD		500			24	Fixed interest rate of 6.25%	Semi-annually
NBG Finance Plc	Senior Unsecured Notes	April 30, 2014	April 2019	EUR		750			—	Fixed interest rate of 4.375%	Annually

The financial conditions of the major long-term senior variable rate debt as of December 31, 2014, are as follows:

Major long-term senior fixed/variable rate debt redeemed in 2014 are as follows:

Issuer	Type	Issue date	Redemption date	Currency

Fixed/Variable rate loans
Finansbank	Fixed Rate Bonds	April 19, 2013	April 2014	TRY⁽¹⁾	124
Finansbank	Fixed Rate Bonds	October 11, 2013	January 2014	TRY⁽¹⁾	750
Finansbank	Fixed Rate Bonds	October 25, 2013	February 2014	TRY⁽¹⁾	150
Finansbank	Fixed Rate Bonds	November 25, 2013	March 2014	TRY⁽¹⁾	245
Finansbank	Fixed Rate Bonds	December 12, 2013	April 2014	TRY⁽¹⁾	899
Finansbank	Fixed Rate Bonds	December 24, 2013	April 2014	TRY⁽¹⁾	116
Finansbank	Fixed Rate Bonds	February 11, 2014	May 2014	TRY⁽¹⁾	244
Finansbank	Fixed Rate Bonds	February 28, 2014	May 2014	TRY⁽¹⁾	171
Finansbank	Fixed Rate Bonds	April 16, 2014	July 2014	TRY⁽¹⁾	187
Finansbank	Fixed Rate Bonds	April 30, 2014	October 2014	TRY⁽¹⁾	500
Finansbank	Fixed Rate Bonds	May 12, 2014	August 2014	TRY⁽¹⁾	295
Finansbank	Fixed Rate Bonds	May 30, 2014	August 2014	TRY⁽¹⁾	218
Finansbank	Variable Rate Bonds	June 24, 2014	September 2014	TRY⁽¹⁾	125
Finansbank	Variable Rate Bonds	July 16, 2014	October 2014	TRY⁽¹⁾	148
Finansbank	Variable Rate Bonds	August 11, 2014	November 2014	TRY⁽¹⁾	210
Finansbank	Variable Rate Bonds	August 29, 2014	November 2014	TRY⁽¹⁾	223
Finansbank	Variable Rate Bonds	September 23, 2014	December 2014	TRY⁽¹⁾	124

Long-term Subordinated debt Senior Notes and the related rates and maturity dates at December 31, comprise:

The financial conditions of the long-term subordinated fixed and variable rate debt as of December 31, 2014, are as follows:

Issuer	Type		Maturity date	Currency	Nominal amount		Own held by the Group		Interest rate	Interest payment

					(in million)		(nominal amount in million)
Subordinated fixed rate notes
NBG Funding Ltd⁽¹⁾	Guaranteed Fixed/Variable Rate Subordinated Callable Notes due 2037—Series E	November 8, 2006	November 2037	GBP		375		—	6.2889% fixed per annum until November 8, 2016 and thereafter variable of three month Libor plus 2.08%	Annually up to November 8, 2016
NBG Finance Plc	Fixed Rate Notes—Lower Tier II	August 3, 2010	August 2020 (Early redemption 2015)	EUR		18		—	7.0% for the first five years and 9.5% thereafter.	Annually
Subordinated variable rate notes
NBG Funding Ltd⁽¹⁾	Guaranteed Variable Rate Subordinated Callable Notes due 2034—Series A	July 11, 2003	July 2034	EUR		350		—	Three-month Euribor plus 175 bps until July 11, 2013 and three-month Euribor plus 275 bps thereafter	Quarterly
NBG Funding Ltd⁽¹⁾	Guaranteed CMS-Linked Subordinated Callable Notes due 2035—Series B	November 3, 2004	November 2035	EUR		350		—	The 10-year EUR CMS mid swap rate plus 12.5 bps reset every six months and capped at 8%	Semi annually
NBG Funding Ltd⁽¹⁾	Guaranteed CMS-Linked Subordinated Callable Notes due 2035-Series C	November 3, 2004	November 2035	USD		180		—	The 10 year EUR CMS mid swap rate plus 12.5 bps reset every six months and capped at 8.5%	Semi annually
NBG Funding Ltd⁽¹⁾	Guaranteed CMS-Linked Subordinated Callable Notes due 2035—Series D	February 16, 2005	February 2036	EUR		230		—	The difference of the 10-year EUR CMS mid swap rate minus the two-year mid swap rate multiplied by four subject to a minimum rate of 3.25% and capped at 10%	Annually

"Other" primarily includes fixed rate borrowings of Finansbank and Finans Leasing amounting to EUR 271 million (of which EUR 112 million, EUR 63 million and EUR 96 million denominated in EUR, TRY and USD respectively) and variable rate borrowings of the above mentioned companies, amounting to EUR 206 million (of which EUR 90 million, and EUR 116 million denominated in EUR and USD).

Additionally, variable rate borrowings of NBG Pangaea REIC subsidiaries amounted to EUR 40 million, all denominated in EUR.

Moreover, fixed rate borrowings of Banca Romaneasca amounted to EUR 2 million, all denominated in EUR and fixed rate borrowings of Stopanska Banka amounted to EUR 13 million (of which EUR 11 million, and EUR 2 million denominated in EUR and MKD) and variable rate borrowings amounting to EUR 2 million all denominated in MKD.

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, 2013 and 2014 the Group has accrued for cases under litigation the amount of EUR 70 million and EUR 67 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 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 25, respectively), net trading gain/loss in 2012, 2013 and 2014 also includes gains from the re-purchase by the Group from the open market of debt securities issued by the Group of EUR 9 million, EUR 1 million and EUR 5 million respectively.

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.

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, 2012, 2013 and 2014 are as follows:

The differences between the nominal statutory income tax and the effective income tax are summarized as follows:

The significant components of deferred income tax assets and liabilities at December 31 comprised:

	2013

	(EUR in millions)
Deferred Tax Assets:
Allowance for loan losses		1,299		1,825
Mark to market valuation of securities and derivatives		597		562
Pension and other post retirement benefits		92		105
Insurance reserves		143		71
Revaluation of land and buildings		168		169
Intangibles recognized upon acquisition and other assets		1		1
Tax free reserves		11		—
Tax loss carried forward		490		1,033
Other		302		300
PSI tax losses		2,303		2,221

Gross deferred tax assets		5,406		6,287
Deferred tax assets / liabilities for netting		(79	)	(90	)

Net deferred tax assets		5,327		6,197
Valuation allowance for deferred tax assets		(5,085	)	(6,003	)

Net deferred tax assets after valuation allowance		242		194



Deferred Tax Liabilities:
Allowance for loan losses		(32	)	(16	)
Mark to market valuation of securities and derivatives		(20	)	(36	)
Insurance reserves		—		(1	)
Revaluation of land and buildings		(1	)	(1	)
Intangibles recognized upon acquisition and other assets		(32	)	(31	)
Tax free reserves		(94	)	(17	)
Other		(21	)	(21	)

Gross deferred tax liabilities		(200	)	(123	)
Deferred tax liabilities / assets for netting		79		90

Net deferred tax liabilities		(121	)	(33	)

Reconciliation of the movement of valuation allowance for deferred tax assets:

A significant piece of objective negative evidence evaluated was the cumulative loss incurred over the years ended December 31, 2010, 2012, 2013 and 2014 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, 2014 has a deferred tax asset of EUR 1,033 million on the tax losses carry-forward of EUR 4,093 million which expire as follows:

The applicable Greek statutory corporation income tax rate was 20% for 2012 and 26% for 2013 and 2014. 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%.

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, 2012, 2013 and 2014, was an expense of NIL, EUR (1,069) million and NIL respectively which was offset by an equivalent amount of valuation allowance resulting in a total net effect of NIL for the years 2012, 2013 and 2014.

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 amounts cannot be determined, it is not expected to have a material effect on the consolidated statement of financial position of the Group and the Bank. The Bank has been audited by the Greek tax authorities up to and including the year 2008. The tax audit for the years 2009 and 2010, by the Greek Tax Authorities, was finalized 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. The Bank intends to initiate court action and expects that will be vindicated. The financial years 2011, 2012 and 2013 were audited and 2014 is currently being audited by the independent auditor, Deloitte Hadjipavlou Sofianos & Cambanis S.A., in accordance with article 82 of Greek Law 2238/1994. The tax audit certificates for the years 2011, 2012 and 2013 were unqualified and issued on July 27, 2012, September 27, 2013 and July 10, 2014, respectively. Based on article 6 of Ministerial Decision 1159/7.22.2011, the years 2011 and 2012 are considered final for tax audit purposes and 2013 and 2014 financial years will be considered final for tax audit purposes 18 months after the issue of the tax audit certificates during which period, the tax authorities are entitled to re-examine the tax books of the Bank.

The open tax years of the major companies of the Group at December 31, 2014, are as follows:

The nature of the significant transactions entered into by the Group with related parties during the year ended December 31, 2014 and 2013 and the significant balances outstanding at December 31, 2014 and 2013 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, except for the following transactions:

The Bank grants loans to its employees on preferential terms compared to customers that are not employees. This policy, which is common practice for banks in Greece, applies only to employees and not to close members of family and entities controlled by them. The preferential terms mainly refer to a lower fixed interest rate of currently 2.1% for mortgage loans, while collateral is required as in the ordinary course of business. As such, as of December 31, 2014, certain General Managers and members of the Executive Committees of the Bank have taken loans of total amount EUR 6 million (December 31, 2013: EUR 6 million) with reduced interest rates. The aggregate amount of loans, deposits and letters of guarantee to related parties, at Group level, totaled EUR 108 million, EUR 16 million and EUR 15 million respectively as at December 31, 2014 (December 31, 2013: EUR 88 million, EUR 12 million and EUR 16 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, 2014, the aggregate amount of receivables from affiliates totaled EUR 16 million, the amount of payables to affiliates totaled EUR 145 million and the amount of letters of guarantee to affiliates totaled EUR 2 million (December 31, 2013: EUR 8 million, EUR 460 million and EUR 8 million respectively). For the year ended December 31, 2014, the aggregate amount of income from affiliates totaled EUR 38 million and the amount of expense to affiliates totaled EUR 13 million (December 31, 2013: EUR 34 million and EUR 15 million respectively).

The total receivables of the Group from the employee benefits related funds as at December 31, 2014, amounted to EUR 674 million (December 31, 2013: EUR 582 million). The total payables of the Group to the employee benefits related funds as at December 31, 2014, amounted to EUR 142 million (December 31, 2013: EUR 134 million).

In the context of Greek Law 3864/2008 regarding the recapitalization of the Greek banks and subject to a pre-subscription agreement, the HFSF, which is considered by the Bank to be a related party as defined in ASC 850 "Related Party Disclosures", had contributed an amount of EUR 9,756 million EFSF bonds as an advance for the participation in the Bank's share capital increase that was completed in June 2013.

An amount of EUR 1,079 million was covered by private investors. The HFSF contribution in the share capital increase eventually amounted to EUR 8,677 million and the excess amount out of the advance was returned to the HFSF. Furthermore, the Bank paid EUR 90 million to HFSF as underwriting fees.

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 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 included in the "Additional paid-in capital", and (ii) the increase in the Bank's common stock with the issuance of new common shares that was subscribed in kind, that is, 466,397,790 common voting shares of Eurobank Ergasias S.A. ("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.

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 common 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 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 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.

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.

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 aforementioned capital increase of the Bank according to Law 3864/2010 and Cabinet Act 38/2012. Trading of the warrants on the Athens Stock Exchange began on June 27, 2013.

In particular, warrants are transferable securities with no restrictions concerning their transfer. Each warrant incorporates the right of its holder to purchase from HFSF 8.22923881005499 new shares, acquired by HFSF due to its participation in the above capital increase of Bank. 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 exercise price of the call option for each warrant in order to acquire new shares held by HFSF, will be equal to EUR 4.29 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 third exercise period (December 29, 2014), the warrants currently remaining in force are 245,748,459, whereas the shares of the Bank upon which they are drawn and which are held by HFSF are 2,022,322,834.

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 held by HFSF and are subject to the provisions of article 8 of Law 3864/2010 and article 3 par.7 of Cabinet Act 38/2012.

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. 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 the stipulations of paragraphs 7 - 11 of Article 3 of Law 3864/2010.

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.

The redeemable preference shares issued by the Bank to the Hellenic Republic are not transferable and embody the following privileges:

The Ministry of Economy and Finance, through its letter to the Bank of Greece (Protocol Number 39389/B2038/7.8.2009) clarified that the funds provided by the Greek State to the financial institutions through the issuance of preference shares, are for the support of the capital adequacy of the Greek banking sector and not for medium term funding. In this respect the Government enacted Greek Law 3844/2010 under which, the preference shares are not mandatorily redeemable. However, if not redeemed after five years following their issuance and if the participating bank's General Meeting of Shareholders has not approved their redemption, the Greek Minister of Finance will impose, pursuant to a recommendation by the Bank of Greece, a gradual cumulative increase of 2% per year on the 10% fixed return provided for during the first five years from the issuance of the shares to the Hellenic Republic.

In accordance with Ministerial Decision 2/98029/0023A/17-01-2012, the redemption of the preference shares issued to the Greek State, will, from December 31, 2011 onwards, be effected at the original par value of the preference shares through the exchange of Greek government bonds or treasury bills. At any redemption date the Greek government bonds or treasury bills to be exchanged should have the following characteristics:

On 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.

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 USD155 million.

Therefore, following the purchase of the ADSs, 12,639,831 ADSs remain 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.

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".

A similar put and call arrangement with the EBRD with respect to 10.21% of Banca Romaneasca's share capital was settled in March 2012.

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).

On April 29, 2013, the 2nd Repeat Extraordinary General Meeting of the Bank's shareholders approved the reverse split of the ordinary shares at a ratio of 10 existing shares of 1.00 Euro per share exchanged for 1 new share of 10.00 Euro per share. This adjustment is applied retrospectively to all periods presented. The adjustment for the effect of the bonus element of the share capital increase which represents the difference between the discounted issue price per share (see Note 33) and its market price upon the recent capital increase, corresponds to a factor of 1.9863, and it has been applied retrospectively to all periods presented.

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 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.

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). The new regulations have 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.

timing and other constraints set in April 2014 by Bank of Greece. The Bank of Greece approved this plan on April 11, 2014. This capital plan included the completed share capital increase of EUR 2,500 million (see Note 33) and certain capital actions amounting to EUR 1,040 million.

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, 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 is 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 (under IFRS) for the six month period ended June 30, 2014, which result in a capital surplus of more than EUR 2.0 billion and no further capital action is required.

The capital ratios for the Group for 2013 in accordance with the 2013 applicable regulatory framework were as follows:

The capital adequacy ratios for the Group, according to the CRD IV transitional provisions in 2014, are presented in the table below:

On July 23, 2014, the European Commission announced the approval of the Bank's restructuring plan (the "Restructuring Plan") as submitted to the EC by the Ministry of Finance on June 25, 2014. This Restructuring Plan includes, inter alia, the sale of a minority stake in Finansbank, the sale of the Astir hotel complex, and the sale of 100% of NBGI (Private Equity).

Article 27A, issued on October 17, 2014 (DTC Law) allows, under certain conditions, and from 2016 onwards Credit Institutions to convert Deferred Tax Asset ("DTA") (under IFRS) arising from the PSI losses and accumulated provisions for credit losses on loans existing at December 31, 2014 ("Eligible DTA") to a receivable (Tax Credit) from the Hellenic Republic. The Tax Credit will be calculated as a ratio of IFRS accounting losses over net equity before the year's losses and such ratio will be applied on the remaining eligible DTA in a given year. The Tax Credit is offsettable against income taxes payable. Any excess amount of the Tax Credit that cannot be offset against income taxes payable is immediately recognized as a receivable from the Hellenic Republic. In such case the Bank will issue conversion rights for an amount of 110% of the Tax Credit receivable in favor of the Hellenic Republic and create a specific reserve for an equal amount. Common shareholders have pre-emption rights on these rights. The reserve will be capitalized with the issuance of common shares in favor of the Hellenic Republic. This new legislation allows Credit Institutions to treat such DTA as not "relying on future profitability" according to CRD IV, and as a result such DTA are not deducted from CET1, hence improving their capital position.

As of December 31, 2014, the amount of DTA (under IFRS) that was eligible for conversion to a receivable from the Greek State subject to the DTC Law was EUR 3.3 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, 2013 and 2014:

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.

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, 2013	Level 1		Level 2		Level 3		Total assets/ liabilities at fair value
	(EUR in millions)
Assets
Trading assets		334		2,724		24		3,082
Debt securities issued by other governments and public sector entities		237		218		—		455
Greek treasury bills		—		2,086		—		2,086
Foreign treasury bills		52		74		—		126
Debt securities issued by foreign financial institutions		5		313		24		342
Corporate debt securities issued by Greek companies		—		20		—		20
Corporate debt securities issued by foreign companies		—		13		—		13
Equity securities issued by Greek companies		26		—		—		26
Equity securities issued by foreign companies		7		—		—		7
Mutual fund units		7		—		—		7
Derivative assets		1		3,649		21		3,671
Available-for-sale securities		2,459		3,646		280		6,385
Greek government bonds		—		1,698		265		1,963
Debt securities issued by other governments and public sector entities		2,053		603		—		2,656
Greek treasury bills		—		157		—		157
Foreign treasury bills		7		333		—		340
Debt securities issued by companies incorporated in Greece		—		407		2		409
Debt securities issued by companies incorporated outside Greece		—		448		13		461
Equity securities issued by companies incorporated in Greece		107		—		—		107
Equity securities issued by companies incorporated outside Greece		19		—		—		19
Mutual Fund units		273		—		—		273
Loans at fair value⁽¹⁾		—		—		76		76
Other assets		301		70		11		382

Total Assets		3,095		10,089		412		13,596



Liabilities
Deposits at fair value⁽²⁾		—		282		—		282
Derivative liabilities		4		3,024		4		3,032
Long-term debt at fair value⁽¹⁾		—		810		—		810
Accounts payable, accrued expenses and other liabilities (Securities short position)		2		64		—		66

Total liabilities		6		4,180		4		4,190

	Fair value measurement using

	Fair value measurement using						Total asset/ liability at fair value
At December 31, 2014	Level 1		Level 2		Level 3		Total asset/ liability at fair value
	(EUR in millions)
Assets
Trading assets		142		2,249		15		2,405
Debt securities issued by other governments and public sector entities		67		297		—		364
Greek treasury bills		—		1,799		—		1,799
Foreign treasury bills		61		72		—		133
Debt securities issued by Greek financial institutions		—		2		—		2
Debt securities issued by foreign financial institutions		2		38		15		55
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		7		—		—		7
Mutual fund units		3		—		—		3
Derivative assets		3		5,912		28		5,943
Available-for-sale securities		2,652		2,291		260		5,203
Greek government bonds		—		501		236		737
Debt securities issued by other governments and public sector entities		2,377		644		—		3,021
Greek treasury bills		—		168		—		168
Foreign treasury bills		—		269		—		269
Debt securities issued by companies incorporated in Greece		—		401		1		402
Debt securities issued by companies incorporated outside Greece		—		307		23		330
Equity securities issued by companies incorporated in Greece		41		—		—		41
Equity securities issued by companies incorporated outside Greece		18		1		—		19
Mutual Fund units		216		—		—		216
Loans at fair value⁽¹⁾		—		—		42		42
Other assets		266		291		11		568

Total Assets		3,063		10,743		356		14,161



Liabilities
Deposits at fair value⁽²⁾		—		16		—		16
Derivative liabilities		1		6,257		5		6,263
Long-term debt at fair value⁽¹⁾		—		872		—		872
Accounts payable, accrued expenses and other liabilities (Securities short position and Other insurance liabilities)		4		253		—		257

Total Liabilities		5		7,398		5		7,408

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, 2013 and 2014 including realized and unrealized gains/(losses) included in earnings and OCI.

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 2 million for the year ended December 31, 2013 and to EUR 1 million for the year ended December 31, 2014 which is reported in Net interest income before provision for loan losses.

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 EUR (1) million and EUR (1) million for trading assets and net derivatives respectively.

For the year ended December 31, 2013, changes in unrealized gains/(losses) of Level 3 financial instruments still held at the reporting date amounted to NIL and EUR 28 million for trading assets and net derivatives respectively.

The Group conducts a review of the fair value hierarchy classifications on a periodic basis. During 2013, loans for which the Group has elected the fair value option, were transferred from Level 2 to Level 3.

Other transfers from Level 2 into Level 3, during 2013 and 2014, include derivative instruments for which the bilateral CVA adjustment is significant to the base fair value of the respective instruments.

The transfer out of Level 3 in 2013 mainly relates to debt securities in issue which were valued based on market observable data instead of the price at which the Bank completed a tender offer.

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.

For Loans to customers which the Group has elected the fair value option, the valuation includes a parameter which is not observable in the market, i.e. the credit spread of the client. A reasonable increase in the respective credit spreads used would not have a significant effect to their fair value 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, 2013 and 2014, 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.

a. Financial assets subject to offsetting, enforceable netting arrangements and similar agreements

b. Financial liabilities subject to offsetting, enforceable netting arrangements and similar agreements

We measure the performance of each of our business segments primarily in terms of "profit before tax". Profit before tax and the business segment information of the Group, set forth below, is derived from the internal management reporting system used by management to measure the performance of the business segments. Unlike financial accounting, there is no authoritative body of guidance for management accounting. The business segment information, set forth below, is based on the financial information prepared in accordance with IFRS. Accordingly, the format and information is presented primarily on the basis of IFRS and is not consistent with the consolidated financial statements prepared on the basis of US GAAP. A reconciliation is provided for the total amounts of segments' total profit/(loss) before tax with income/(loss) before income tax.

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"), which has the overall responsibility for the management of EUR 5.7 billion loans to legal entities (end-to-end responsibility).

Global Markets and Asset Management includes all treasury activities, private banking, asset management (mutual funds and closed end funds), custody services, private equity and brokerage.

The Group offers a wide range of insurance products through its subsidiary company, EH and other subsidiaries in SE Europe and an associate in Turkey.

12-month period ended December 31, 2012	Retail Banking

	(EUR in millions)
Net interest income		940		745		(106	)	71		312		1,265		138		3,365
Net fee and commission income/(loss)		88		85		(177	)	6		90		400		3		495
Other		(9	)	(49	)	(469	)	156		17		169		(148	)	(333	)

Total operating income/(loss)		1,019		781		(752	)	233		419		1,834		(7	)	3,527

Direct costs		(615	)	(51	)	(59	)	(116	)	(272	)	(748	)	(20	)	(1,881	)
Allocated costs and provisions		(1,736	)	(654	)	(247	)	(31	)	(258	)	(286	)	(409	)	(3,621	)
Share of profit of equity method investments		—		—		—		—		—		2		—		2

Profit/(loss) before tax		(1,332	)	76		(1,058	)	86		(111	)	802		(436	)	(1,973	)



Segment assets as at December 31, 2012
Segment assets		25,694		14,377		19,584		3,136		9,429		24,615		6,295		103,130
Deferred tax assets and Current income tax advance																1,668

Total assets																104,798
IFRS to U.S. GAAP differences																(3,642	)

U.S. GAAP total assets																101,156



Other Segment items
Depreciation & amortization⁽¹⁾		13		2		3		9		32		65		107		231
Credit provisions and other impairment charges		1,436		608		227		29		255		286		312		3,153
Non- current assets additions		12		29		6		5		17		96		79		244

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
Deferred tax assets and Current income tax advance																2,855

Total assets																110,930
IFRS to U.S. GAAP differences																(4,089	)

U.S. GAAP total assets																106,841



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		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, 2014
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
IFRS to U.S. GAAP differences																(7,051	)

U.S. GAAP total assets																108,413



Other Segment items
Depreciation & 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

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

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% 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 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 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 2013 and 2014 were EUR 315 million and EUR 271 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 for Finansbank amounting to EUR 3 million and 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 approximately EUR 183 million. Additionally, losses / (income) on curtailments / settlements and other expense / (income) includes the additional cost of extra benefits in excess of the benefits provided for Finansbank amounting to EUR 2 million.

In 2012, losses / (income) on curtailments / settlements and other expense / (income) mainly relates to the change in the provision for retirement indemnities in accordance with Greek Law 4093/2012 as described above, which eliminates the retirement indemnity benefit accruals for employees with more than 17 years of service. Additionally, all employees with less than 17 completed years of service as at November 2012 will cease to accrue future benefits upon the completion of 17 years, instead of 28 years as was the case before the enactment of Greek Law 4903/2012.

Also, losses / (income) on curtailments / settlements and other expense / (income) includes the cost of additional benefits in excess of the benefits provided for Finansbank amounting to EUR 4 million and the amount of EUR 5 million for NBG Cyprus, as in 2012 the plan changed from defined benefit plan to defined contribution plan.

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:

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.

In 2013, Settlements/Terminations/Curtailments mainly included the additional cost of the voluntary retirement scheme for the Bank's employees. In 2012, the adjustment for disposal and other mainly relates to the implementation by the Bank of Greek Law 4046/2012 of amount EUR 170 million.

Employer contributions paid by the Group, are in excess of the EUR 6 million total expected contributions for funded plans for 2014.

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 2015 are NIL of prior service cost and EUR 13 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 are as follows:

In 2015, the Group is expected to make EUR 8 million in contributions to funded plans and pay EUR 36 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:

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, 2012

NOTE 42: ACCUMULATED OTHER COMPREHENSIVE INCOME ATTRIBUTABLE TO NBG SHAREHOLDERS (Continued)

Reclassifications out of accumulated other comprehensive income for the period ended December 31, 2013

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

At December 31, 2014, the EUR equivalent of the assets and liabilities, which are denominated in foreign currency, amounted to EUR 34,150 million (EUR 31,263 million for 2013 and EUR 33,578 million for 2012) and EUR 28,498 million (EUR 25,370 million for 2013 and EUR 26,121 million for 2012), respectively.


(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, 2014
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	272
C.	Material Contracts	278
D.	Exchange Controls	278
E.	U.S. Federal Income Taxation	278
F.	Dividends and Paying Agents	284
G.	Statements by Experts	284
H.	Documents on Display	284
I.	Subsidiary Information	284
Item 11	QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK	284
Item 12	DESCRIPTION OF SECURITIES OTHER THAN EQUITY SECURITIES	294
PART II		296
Item 13	DEFAULTS, DIVIDEND ARREARAGES AND DELINQUENCIES	296
Item 14	MATERIAL MODIFICATIONS TO THE RIGHTS OF SECURITY HOLDERS AND USE OF PROCEEDS	296
A.	General Effect of the Modifications on the Rights of Security Holders	296
Item 15	CONTROLS AND PROCEDURES	297
(a)	Disclosure Controls and Procedures	297
(b)	Management's Annual Report on Internal Control over Financial Reporting	298
(c)	Report of Independent Registered Public Accounting Firm	300
(d)	Changes in Internal Control over Financial Reporting	304
Item 16A	AUDIT COMMITTEE FINANCIAL EXPERT	304
Item 16B	CODE OF ETHICS	305
Item 16C	PRINCIPAL ACCOUNTANT FEES AND SERVICES	305
Item 16D	EXEMPTIONS FROM THE LISTING STANDARDS FOR AUDIT COMMITTEES	307
Item 16E	PURCHASES OF EQUITY SECURITIES BY THE ISSUER AND AFFILIATED PURCHASERS	307
Item 16F	CHANGE IN REGISTRANT'S CERTIFYING ACCOUNTANT	307
Item 16G	CORPORATE GOVERNANCE	308
PART III		309
Item 17	FINANCIAL STATEMENTS	309
Item 18	FINANCIAL STATEMENTS	309
Item 19	EXHIBITS	309
CONSOLIDATED FINANCIAL STATEMENTS AS OF DECEMBER 31, 2013 AND 2014 AND FOR THE YEARS ENDED DECEMBER 31, 2012, 2013 AND 2014		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 2014		0.8068		0.7966
December 2014		0.8264		0.7997
January 2015		0.8866		0.8323
February 2015		0.8931		0.8724
March 2015		0.9502		0.8919
April 2015		0.9450		0.8949

Annual Period

2010	0.7540	0.5009
2011	0.7178	0.4278
2012	0.7777	0.4322
2013	0.7530	0.3947
2014	0.7520	0.3441
2015 (up to April 30, 2015)	0.8982	0.3575

	Reported⁽²⁾			Static						Dynamic

	2013			2016						2014⁽³⁾			2016			2016
Comprehensive Assessment Results⁽¹⁾ (In millions EUR, except for percentages)				Baseline			Adverse			Baseline			Baseline			Adverse
CET1⁽⁴⁾		6,058			3,260			(246	)		8,030			9,486			5,325
RWAs⁽⁴⁾		56,685			56,730			57,940			60,303			58,626			60,001
CET1 (%)⁽⁴⁾		10.7	%		5.7	%		(0.4	)%		13.3	%		16.2	%		8.9	%
Minimum Threshold⁽⁴⁾					8.0	%		5.5	%		8.0	%		8.0	%		5.5	%
Capital surplus/ (shortfall)⁽⁴⁾					(1,278	)		(3,433	)		3,206			4,796			2,025
Actions addressing the shortfall
Capital surplus/ (shortfall) post EUR 2.5 billion share capital increase					1,222			(933	)		3,206	⁽⁵⁾		4,796	⁽⁵⁾		2,025	⁽⁵⁾
12-month 2014 PPI and actions completed (refer below)								1,057
Capital surplus including profitability and actions by December 2014								124


		UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 20-F

		Page

Introduction		1
PART I		6
Item 1	IDENTITY OF DIRECTORS, SENIOR MANAGEMENT AND ADVISERS	6
Item 2	OFFER STATISTICS AND EXPECTED TIMETABLE	6
Item 3	KEY INFORMATION	6
A.	Selected Financial Data	6
B.	Capitalization and Indebtedness	10
C.	Reasons for the Offer and Use of Proceeds	10
D.	Risk Factors	11
Item 4	INFORMATION ON THE COMPANY	46
A.	History and Development of the Company	46
B.	Business Overview	53
C.	Organizational Structure	121
D.	Property, Plant and Equipment	123
E.	Selected Statistical Data	123
Item 4A	UNRESOLVED STAFF COMMENTS	160
Item 5	OPERATING AND FINANCIAL REVIEW AND PROSPECTS	161
A.	Operating Results	181
B.	Liquidity and Capital Resources	199
C.	Research and Development, Patents and Licenses	219
D.	Trend Information	219
E.	Off-balance Sheet Arrangements	225
F.	Tabular Disclosure of Contractual Obligations	226
G.	Safe Harbor	226
Item 6	DIRECTORS, SENIOR MANAGEMENT AND EMPLOYEES	227
A.	Board of Directors and Senior Management	227
B.	Compensation	245
C.	Board Practices	245
D.	Employees	257
E.	Share Ownership	259
Item 7	MAJOR SHAREHOLDERS AND RELATED PARTY TRANSACTIONS	260
A.	Major Shareholders	260
B.	Related Party Transactions	261
C.	Interests of Experts and Counsel	262
Item 8	FINANCIAL INFORMATION	262
A.	Consolidated Statements and Other Financial Information	262
B.	Significant Changes	264
Item 9	THE OFFER AND LISTING	264
A.	Offer and Listing Details	264
B.	Plan of Distribution	268
C.	Markets	268
D.	Selling Shareholders	272
E.	Dilution	272
F.	Expenses of the Issue	272
Item 10	ADDITIONAL INFORMATION	272
A.	Share Capital	272

	Year ended December 31,

Type of Capital Expenditure	2012			2013			2014
	(EUR in millions)
Interests in other companies		71	⁽²⁾		17	⁽¹⁾		4	⁽¹⁾
Information technology and other electronic equipment		84			63			82
Land and buildings		35			258	⁽³⁾		757	⁽⁵⁾
Leasehold improvements		23			25			12
Furniture, fixtures, machinery and vehicles⁽⁴⁾		91			95			106

Total		304			458			961

	Year ended December 31,

Type of Divestiture	2012		2013		2014
	(EUR in millions)
Investments⁽¹⁾		37		19		—
Real estate⁽²⁾		1		1		18

	As at December 31,

	2013			2014
Mortgage lending (balances)		26.1	%		26.2	%
Consumer loans and credit cards (balances)		21.1	%		21.7	%
Core deposits⁽¹⁾		34.6	%		32.9	%

	EUR		USD⁽¹⁾

	(in millions)		(in millions)
Total Assets		504		563
Net Loans		322		359
Total Deposits		286		320
Net Income		3		3

	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		130		38		5		2		1		—		577		99		15		102		969
Romania		242		—		—		2		5		2		321		—		—		—		572
Albania		46		2		—		—		—		—		—		—		15		—		63
Bosnia		—		—		—		1		—		—		—		—		—		—		1
Poland		—		—		—		—		—		2		—		—		—		—		—

		418		40		5		5		6		4		898		99		30		102		1,605

Warrant Exercise period	Months

1	6	3.0	%	1.0	%	180	4.3758
2	12	3.0	%	1.0	%	360	4.4616
3	18	3.0	%	2.0	%	180	4.5689
4	24	3.0	%	2.0	%	360	4.6761
5	30	3.0	%	3.0	%	180	4.8048
6	36	3.0	%	3.0	%	360	4.9335
7	42	3.0	%	4.0	%	180	5.0837
8	48	3.0	%	4.0	%	360	5.2338
9	54	3.0	%	5.0	%	180	5.4054

Primary Operating Area	Country of incorporation

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	%
Fondo Picasso	Italy	—		100.00	%	100.00	%
MIG Real Estate REIC	Greece	—		96.90	%	96.90	%
Egnatia Properties S.A	Romania	—		96.87	%	96.87	%
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 vs. 2012									2013 vs. 2012
	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	)		—			2			(2	)
Interest bearing deposits with banks, securities purchased under agreements to resell and money market investments		(8	)		(7	)		(1	)		(16	)		(8	)		(7	)
Trading, available for sale and held to maturity securities		(304	)		(253	)		(51	)		(11	)		643			(655	)
Loans		(204	)		(213	)		9			(212	)		103			(315	)

Total Assets		(517	)		(474	)		(44	)		(239	)		740			(979	)
LIABILITIES
Total deposits		(273	)		(77	)		(196	)		(240	)		69			(309	)
Securities sold under agreements to repurchase		6			22			(16	)		(8	)		27			(35	)
Long term debt and other borrowed funds		3			—			3			12			(2	)		14

Total Liabilities		(264	)		(55	)		(209	)		(236	)		94			(330	)

	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)
	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		(6	)		1			(7	)		9			3			6
Trading, available for sale and held to maturity securities		(49	)		(69	)		20			91			109			(18	)
Loans		(144	)		(10	)		(134	)		(104	)		(323	)		219

Total Assets		(200	)		(78	)		(122	)		(5	)		(211	)		206
LIABILITIES
Total deposits		(305	)		(133	)		(172	)		74			90			(16	)
Securities sold under agreements to repurchase		—			8			(8	)		39			47			(8	)
Long term debt and other borrowed funds		—			—			—			101			77			24

Total Liabilities		(305	)		(125	)		(180	)		214			214			—

	Year ended December 31, 2012

	Country
	Turkey		Bulgaria		Romania		FYROM
	(EUR in millions)
Loans		17,436		3,030		1,813		826
Interest bearing deposits with banks		803		80		23		—
Other investments		2,821		248		225		257
Other monetary assets		2,263		380		246		97

Total		23,323		3,738		2,307		1,180

			Year ended December 31, 2012

	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 90 days		Accruing, less than 90 days		Total
			(EUR in millions)
Residential mortgage		1		207		2		211		822		368		745		1,935
Credit cards		—		183		—		183		79		—		—		79
Other consumer		—		139		1		140		503		130		128		761
Small business loans		—		7		—		7		255		81		60		396
Other commercial		2		115		—		116		390		95		134		619

Total		3		651		3		657		2,049		674		1,067		3,790

	Year ended December 31, 2014

	(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		19,444
Over 3 through 6 months		3,091
Over 6 through 12 months		2,771
Over 12 months		2,992

Total time certificates of deposit and other deposits in amount of US$0.1 million or more		28,298



Foreign Operations:
Time certificates of deposit in amounts US$0.1 million or more:
3 months or less		131
Over 6 through 12 months		1
Over 12 months		4
Other time deposits of US$0.1 million or more by time remaining until maturity:
3 months or less		8,478
Over 3 through 6 months		527
Over 6 through 12 months		493
Over 12 months		305

Total time certificates of deposit and other deposits in amount of US$0.1 million or more		9,939

	2013

	(EUR in millions)
Balance at beginning of year		7,318		7,751
Provision for loan losses		969		2,172
Write-offs		(249	)	(189	)
Recoveries		88		78

Net Write-offs		(161	)	(111	)
Sale of impaired loans		(216	)	(330	)
Translation differences		(159	)	10

Balance at end of year		7,751		9,492

	Year ended December 31,

Components of allowances for loan losses	2013		2014		2013/2014 Change
	(EUR in millions)						%
Specific allowances		1,808		2,330		522		28.9
Coefficient analysis		242		330		88		36.4
Homogeneous analysis		4,159		5,128		969		23.3
Foreign loans		1,542		1,704		162		10.5

Total loan loss allowances		7,751		9,492		1,741		22.5

	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⁽²⁾			2014 Adjusted⁽³⁾
Common Equity Tier 1		10.5	%		13.5	%		13.6	%
Tier I		10.5	%		13.5	%		13.6	%
Total		10.6	%		13.6	%		13.7	%

Rating agency		Long-term foreign currency deposit rating⁽¹⁾	Short-term foreign currency deposit rating⁽¹⁾	Outlook for the Bank's ratings	Financial strength of the Bank— Individual⁽¹⁾	Subordinated debt of the Bank⁽¹⁾	Preferred stock of the Bank⁽¹⁾

Moody's	April 30, 2015	Caa3	Not prime	Negative	WR	Ca	Ca
Standard & Poor's	April 20, 2015	CCC+	C	CreditWatch negative	—	C	NR
Fitch	April 1, 2015	CCC	C	—	CCC	C	C

Description				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 bps per annum
Variable Rate Notes	June 26, 2013	June 26, 2015	4,266	Paid quarterly at a rate of three-month Euribor plus 800 bps per annum

Total			8,766

Description	Issue date	Maturity date		Interest rate

Variable Rate Notes	January 7, 2015	April 7, 2015	4,100	Paid quarterly at a rate of three-month Euribor plus 600 bps per annum
Variable Rate Notes	January 23, 2015	May 23, 2015	1,900	Paid monthly at a rate of one-month Euribor plus 600 bps per annum
Variable Rate Notes	April 15, 2015	October 15, 2015	4,100	Paid semi-annually at a rate of six-month Euribor plus 800 bps per annum

Total as of April 30, 2015			6,000

Description	Issue date	Maturity date

Variable Rate Notes	June 7, 2011	June 7, 2014	1,925
Variable Rate Notes	December 12, 2013	December 12, 2014	4,108



Chairman	Paula Hadjisotiriou	Deputy CEO—Group CFO
Member	Paul Mylonas	Deputy CEO—CRO
Member	Dimitrios Dimopoulos	Deputy CEO—Business
Member	—	General Manager of Treasury and Global Markets
Member	Nelly Tzakou-Lampropoulou	General Manager of Retail Banking

	2013

	(EUR in millions)
Financial instruments whose contract amounts represent credit risk:
Commitments to extend credit:⁽¹⁾
Residential real estate		10	6
Commercial letters of credit		593	796
Standby letters of credit and financial guarantees written		5,665	6,503

Total		6,268	7,305

	Less than 1 year

	(EUR in millions)
Time deposits⁽¹⁾		38,364	554	176	5	39,099
Long-term debt⁽¹⁾		574	2,094	1,577	462	4,707
Operating lease obligations		95	158	113	110	476
Insurance reserves⁽²⁾		309	364	291	1,284	2,248
Pension liability⁽³⁾		36	35	29	237	337

Total		39,378	3,205	2,186	2,098	46,867



Chairman		Petros Sabatacakis (Financial expert)
Member		Dimitrios Afendoulis
Member		Charalampos Makkas (HFSF representative)



Chair		Alexandra Papalexopoulou-Benopoulou (Risk management and control activities expert)
Member		Louka Katseli*
Member		Dimitrios Afendoulis
Member		Spyridon Theodoropoulos
Member		Charalampos Makkas (HFSF representative)



Chairman	Leonidas Fragkiadakis*	CEO
Member	Dimitrios Dimopoulos	Deputy CEO
Member	Paul Mylonas	Deputy CEO
Member	Paula Hadjisotiriou	Deputy CEO
Member	Damianos Charalampidis	Chief of Operations
Member	Nelly Tzakou-Lambropoulou	General Manager of Retail Banking
Member without voting rights	Miltiadis Stathopoulos	General Counsel & General Manager of Corporate Governance

Country		Average number of Group employees for the year-ended December 31, 2014⁽¹⁾

Greece			11,954
Turkey			14,659
Bulgaria			2,682
Serbia			1,756
Romania			1,462
FYROM			1,042
Cyprus			336
Albania			279
Egypt			209
South Africa			159
United Kingdom			64
Malta			26

Total			34,628

		Average number of Group employees for the year-ended December 31, 2014

Commercial and retail banking			32,313
Insurance			1,030
Investment banking			192
Asset management			57
Other Group companies			1,036

Total			34,628