TITLE: Montenegro's Central Bank Establishes Reporting Requirements for Credit Institutions on Minimum Capital and Resolution Planning BODY: On 17 April 2025, the Council of the Central Bank of Montenegro passed a decision establishing comprehensive reporting requirements for credit institutions operating in the jurisdiction. The decision, which entered into force on 25 April 2025, prescribes the types, format, content, and submission deadlines for reports that credit institutions must submit to fulfil resolution planning and capital adequacy monitoring obligations. The decision requires credit institutions to submit quarterly reports to the Central Bank of Montenegro no later than 20 days after the end of each quarter. These reports include: the minimum requirement for own funds and eligible liabilities (MREL1 template); own funds and liabilities (RKO template); own funds and liabilities presented according to reverse priority ranking in bankruptcy proceedings (ORP template); structure of eligible liabilities qualified for internal MREL requirements (IM template); and structure of eligible liabilities (KO template). Additionally, credit institutions must submit annual reports by 15 April each year reflecting the status as of 31 December of the preceding year. These reports detail all valid hedging agreements, real estate leases, service agreements with third parties, borrowing agreements, subordinated debt agreements, intra-group financing and guarantee agreements, correspondent banking relationships, and agreements governed by non-Montenegrin law. All contracts not concluded in Montenegrin must be accompanied by certified translations from sworn translators. Reports must be submitted electronically to sanacija@cbcg.me using the prescribed templates provided in the decision's annex. The decision applies mutatis mutandis to other legal persons defined under the Law on Resolution of Credit Institutions.

CRITICAL BEHAVIORAL RULES (these override all other instructions): - Always generate an update. Never refuse, never ask for more information, and never say you cannot produce output. - If the source content is in a non-English language, translate and summarise it into English. - If the source content is sparse, administrative, procedural, or lacks expected regulatory elements, extract and present whatever information is available. This includes personnel appointments, cabinet changes, institutional restructures, and any official government action. - Never include disclaimers or meta-commentary about source quality, translation limitations, or content gaps. - If you cannot determine a piece of information, simply omit it rather than noting its absence. - Content scope is broad: generate updates for all government and official publications including regulatory changes, legislation, consultations, decrees, personnel appointments, institutional announcements, administrative decisions, and any other government or authority action. Do not filter by topic relevance. You are an AI assistant generating Horizon scanning updates for government, regulatory, and institutional content. GROUND RULES FOR HORIZON SCANNING UPDATES: Title Requirements: - The jurisdiction must appear in the update title - For PC/FS updates, use title case - Titles must be declarative statements (not questions) Body Text Requirements: - Target 200-250 words, but shorter is acceptable when source material is limited - Include as many of the following as the source material supports: jurisdiction, authority, brief description of the development or action, relevant dates (effective dates, announcement dates, enforcement dates) - Include links to relevant legislation where applicable - Reference all initialisms in full on first use (e.g., "Financial Conduct Authority (FCA)") - Must be factual only - no speculation or sweeping statements - When information is unavailable, simply omit it rather than noting its absence Format your response as: TITLE: [Your declarative title with jurisdiction] BODY: [Your factual summary with all required elements]

Horizon Scanning Outline. Purpose of Analyst writing Horizon Scanning Updates Distil the key points of the development for clients to quickly see what is changing without reading the whole source. Provide updates to key events from government and regulatory bodies, including consultations, legislation, decrees, appointments, and institutional changes. Simplify complex updates and sources so that they’re succinct, concise and clear to read. Consistently structure and write updates in the same format. Structure of Horizon Scanning Updates Always think about: Who (Authority) is publishing/enforcing the content/regulation? Where (Jurisdiction)? What type of document or announcement is it (e.g., consultation, regulation, decree, appointment, institutional change)? What is changing/being informed? Who is this update applicable to (credit, e-money institutions, etc.)? Why is this update noteworthy? What is its significance? When is the update applicable? Title Describe what the update is about. Include the jurisdiction (where); subject (authority - who); and a verb (doing word such as issues, publishes, launches, etc.- what). All titles should be written in present tense. Avoid using acronyms Approx 10 - 20 words Example Turkey’s Personal Data Protection Authority Publishes Data Protection Guidance Paragraph 1 Open with the date of the update (When) Name the authority that released the update (Who) Summarise the release (What) Example On June 20, 2025, the Securities and Exchange Board of India (SEBI) launched a consultation on guidelines for responsible usage of artificial intelligence (AI) and machine learning (ML) in Indian securities markets. Paragraph 2 Summarise key points. The change/amendment aiming to achieve (what) What is its objective, why is it happening? Why is it significant? (why) Who does it impact or concern? (Who) The aim is to summarise large source documents so the reader doesn’t need to do it themselves. DO NOT just copy the first few sentences of the document. Example SEBI aims to produce guidelines providing high-level principles for market participants to establish reasonable procedures and control systems for the supervision and governance of AI/ML applications and tools. To develop this, SEBI created a working group to: Study Indian and global best practices. Prepare the guidelines. Address the concerns and issues arising from AI/ML usage. SEBI is consulting on the following principles to develop the guidelines: Model governance: Market participants should have an internal team with adequate skills and experience to monitor and oversee the use of AI/ML-based models. Investor protection and disclosure: Market participants using AI/ML that impacts their customers should disclose such usage. Relevant use cases include algorithmic trading, asset management, advisory, and support services. The disclosure must include product features, purpose, risks, limitations, and other relevant information. Testing framework: Market participants should adequately test and continuously monitor AI/ML-based models to validate their results. Fairness and bias: AI/ML models should not favour or discriminate against any group of clients. Data privacy and cybersecurity: As AI/ML systems rely on data processing, market participants should maintain a clear policy for data security. Paragraph 3 Acts as a “Call To Action”. Provide forward looking context: What actions need to be taken? Who needs to take action? Next steps to the development. Include any relevant dates (When) Response dates - should always be provided for consultations Effective dates - should be used if we know definitively that the act/reg is coming into effect on a specific date, i.e., it has been passed/adopted. Example The comment period ends on February 2, 2026, at 11:59pm and responses can be submitted here. The comment response is expected to be published in April 2026. References Should always be included, and should come from a primary source, i.e., an authority, not a news source. General Style Notes: 200-250 words Active voice Authorities and companies referenced as a single entity (“It”, not “they”) Titles in title case Internal Vixio vocabulary guide Content Style Guide Spelling should generally be in UK English, except for North American-facing (US/Canada/Caribbean) content. A Acronyms - should be spelt out in first instance with acronym in brackets. For example, Financial Conduct Authority (FCA). Act - when just referring to “the act”, it does not need a capital a. Active prose - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE)) Advise/advice - advise (verb) - to offer suggestions (for example, I advised them to sell). - advice (noun) - give formal suggestions (for example, I gave them advice). Advisor NOT adviser Affect - verb - “have an effect on something, make a difference” Alternate/Alternative - Alternate (adjective) - means every other - Alternative (noun) - strictly one out of two - Alternative (adjective) - the other of two things. Although - not to be interchanged with “while” - means “in spite of” NOT “at the same time”. AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT Among/while NOT Amongst/whilst API - application programming interface Apostrophes - to be used in possessives, i.e. an operator’s licence NOT an operators licence (for plurals, should appear after the s, with no second s). Article/Part/Section - should be capitalised when referring to a specific article - e.g., Article 4 of the Gambling Act. Assure/ensure - not to be confused - assure means “tell someone something positively to dispel doubts”, ensure means “makes certain something will occur”. B Between - should always appear with “and” NOT “to” - for example, between this summer and next summer. Big tech - two words, breaks convention of other tech words Bills - U.S. bill names should appear without full points and a space between the letters and numbers (i.e. SB 522 NOT SB522 or S.B. 522). Brackets - square brackets should be used to denote deletions or additions in quotes. Buy now, pay later - no hyphens Bullet points - see Lists C Capitalisation - all important words should have a capital in titles (i.e. just not joining words such as and/of/the/a) Cardrooms not card rooms Cases - legal cases should appear in italics, with a v for versus. Casino-resorts NOT casino resorts or resort-casinos Chief executive NOT chief executive officer Colons (:) - used between independent clauses when the second clause explains, illustrates or expands on the first (i.e. to introduce lists, quotes) Commas - to be used in figures to denote thousands to avoid confusion with years (i.e, $2,000 NOT $2000) Comparisons - compare with (highlighting differences) - compare to (highlighting similarities) Companies/organisations - singular entities (it NOT they) should be followed by “which/that” rather than “who” Ltd, not Limited Complement - to accompany something/add value Compliment - give praise (complimentary = free) Compound adjectives - should be hyphenated (sports-betting operators / first-quarter earnings) Comprise/comprising - should NOT be followed with “of”, as it means to “consist of” Conjunctions - should appear with a semi-colon before and a comma afterwards (; however, / ; therefore,) Continually - if something occurs repeatedly/regularly in the same way Continuously - if something occurs without interruption or gaps Contractions - don’t, can’t, won’t, etc. to be avoided in copy (except in marketing material and depending on tone) Contrast - by contrast - when comparing one thing to another - in contrast - simply noting a difference Counsel/Council - counsel = advice, guidance; council = an advisory group or meeting Court of Justice of the European Union (CJEU) rather than ECJ Cryptocurrency - one word, not hyphenated. Crypto-assets - hyphenated Cybersecurity - one word, not hyphenated CTF - counter-terrorism financing - NOT CFT/countering the financing of terrorism Currencies - if not using common symbols (£, $, €), then three-letter code should be used before the figure (no spaces) - for example, PLN50,000. Full term lower case (eg euro, baht, pound, dollar) m for million, bn for billion, trn for trillion. D Date format - Month, Day, Year (e.g., March 7, 2019) For Insights & Analysis summary text: can just say “today”, e.g., “Today a bill was passed for…” For Insights & Analysis body text: dates should always accompany days of the week in brackets, e.g., “On Wednesday (June 8) a bill was passed...” For NIBs: always use dates rather than days. Department for Digital, Culture, Media & Sport - ampersand Directives - for commonly used directives, style is 4th Anti-Money Laundering Directive (4th AMLD), revised Payment Services Directive (PSD2) - try to use widely known titles rather than just numbers to ensure the directives are more easily recognised. DLT - distributed ledger technology E Effect - noun - “cause something to happen”. Em dash (—) - should be used as a conjunction, not a hyphen or en dash (–). Ensure/assure - not to be confused - ensure means “makes certain something will occur”, assure means “tell someone something positively to dispel doubts”. esports NOT eSports or e-sports Euros - should be denoted with a “€” (CNTRL+ALT+4) NOT “EUR”. F fintech NOT FinTech Footnotes - avoid where possible, if necessary write them into the text or add links. G GGR - “gross gaming revenues” Government - does not need a capital g. Governor - should be written out in full, NOT Gov. Guidance (singular and plural) - does NOT need to be preceded by “a” (Guide/guides, Guideline/guidelines) H Headlines - all words should begin with a capital Horseracing NOT horse racing Hyphenation - DO: land-based, fixed-odds, cross-border, invitation-only, fast-tracked (if “a fast-tracked application”), match-fixing, year-on-year, up-to-date, whistle-blowers, six-month period, non-fungible tokens, crypto-assets, e-money - DON’T: email, blocklist, whitelist, whitelisted, cybersecurity, cryptocurrency, white paper I Impact - should be used as a noun - i.e. the new act will have an impact on… - verb means “come into forcible contact with something else”. - using “affect” as a verb is more accurate. J Judgment - legal decision Judgement - one’s own opinion Jargon - avoid using confusing terms or tabloidese, e.g. use players rather than punters. Job titles - should appear in commas after a name - for example, Neil McArthur, Gambling Commission chief executive. OR before a name with no commas - for example, Gambling Commission chief executive Neil McArthur DON’T need capitals unless a figure of importance (i.e., Prime Minister, President) Italics - whole chunks of text from legislation should be italicised; however, short quotes do not need to be. Justice Department - U.S. Department of Justice - to appear with caps (as requested by US team). K KYC - know your customer L Legislature - does not need a capital l. Less than - NOT to be confused with “fewer than” when referring to a number of something. i.e. fewer than 100 gambling tables. Licence - noun (UK), i.e. a driver’s licence License - verb/noun (US) Lists - bulleted lists should generally begin with a cap and end with a full stop (make sure they are consistent). M MONEYVAL NOT Moneyval More than - to be used instead of “over”. i.e., more than 20 players rather than over 20 players. N Names - should appear before job titles in commas - for example, Neil McArthur, Gambling Commission chief executive. Names - should be written in full in first instance and then the surname used throughout. Numbers - 1-10 should be written out (except for percentages and measurements); should always be written out at the start of sentences. Non-fungible tokens - all lowercase (non-fungible tokens) O Offence - noun (UK), i.e. commit an offence Offense - noun (US) Organisations/companies - singular entities (it NOT they) should be followed by “which/that” rather than “who” Oxford comma - (appears before “and” or “or”) - to be used sparingly and only when necessary to avoid any confusion in a sentence (i.e., where more than one “and/or” appears). Over - should not be used as a replacement for “more than”. P Parliament - does not need a capital p. Part/Section/Article - should be capitalised when referring to a specific part - e.g., Part 4 of the Gambling Act Passive voice - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE)) Past/passed - past is a noun/adverb/adjective - “in the past”, “past experience”. - passed is the past tense of “to pass” - “the law was passed in government”. Prepaid, not pre-paid Percentages - numbers should always be written as figures percent NOT per cent or % Figures should appear with a full point between them NOT comma (for example, 5.7 percent NOT 5,7 percent) Possessives - require an apostrophe and should not be confused with plurals - i.e., an operator’s licence NOT an operators licence (for plurals, should appear after the s, with no second s). Prepositions - keep an eye out for missing prepositions - according “to”/ in accordance “with”/ in relation “to” / with regard “to” Principal - main, most important Principle - a fundamental source or basis of something Programme (UK) Program (US, UK - for computer program, Australian English) Q Quotes - speaker should be referenced in the past tense (said NOT says) Quote marks - double quote marks should be used for speech - single quote marks should only be used for titles and within quotes. (See Quote reference sheet for more information on how to use quotes.) R regtech NOT RegTech Repetition - avoid using words that mean the same thing (“and also” / “include, among others” / VLT terminals / ATM machines) Racetracks not race tracks S Seasons - when referencing a specific season of a year should be treated like a proper noun, i.e. should include a capital - Winter 2018. Section/Article/Part - should be capitalised when referring to a specific section - e.g., Section 4 of the Gambling Act. Semi-colons (;) - should be used to link two independent clauses that are closely related; or in lists without bullet points. (Do not overuse - often a full stop and new sentence will be better.) Sports betting NOT sportsbetting Sports team names Storey (pl. storeys) - level of a building (UK English) (story/stories - US English) T That defines, which informs Third person - “you” - avoid where possible. Titles - all important words should begin with a capital (i.e. just not joining words such as and/of/the/a) Tenses - content should generally be written in past tense - present tense should be used for something that has just happened and will be continuing into the future. U United States abbreviated to U.S. (Americas-focused stories on GC) / US in international content when mentioned in passing or across PC USA PATRIOT Act - should be kept as such, i.e. with caps, as it’s an acronym for “Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act”) U.S. Department of Justice - Justice Department (with capitals as requested) V Vixio GamblingCompliance / Vixio PaymentsCompliance Vixio (to be used on its own after first instance) W Which informs, that defines While/among NOT Whilst/amongst While - not to be interchanged with “although” - means “at the same time” NOT “in spite of”. X Y Year quarters - Q1, Q2, H1, H2, etc. Z Acronyms AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT API - application programming interface DLT - distributed ledger technology --- Now, given the above instructions and style guide, please generate a horizon scanning update based on the following webpage content. Generate the update regardless of the source language, content type, or level of detail available — this includes administrative decrees, personnel appointments, institutional changes, and any other official content. Use whatever information is present. [Unofficial translation] Pursuant to Article 44 paragraph (2) item 3) of the Central Bank of Montenegro Law (OGM 40/10, 6/13, 70/17, 125/23) and Article 33b paragraph (2) of the Law on Resolution of Credit Institutions (OGM 72/19, 8/21, 113/24), the Council of the Central Bank of Montenegro, at its meeting held on 17 April 2025, passed the following DECISION ON REPORTING TO THE CENTRAL BANK OF MONTENEGRO FOR THE PURPOSE OF PURSUING RESOLUTION FUNCTION Subject matter Article 1 This Decision shall prescribe the types, format, and content of reports and data that credit institutions submit to the Central Bank of Montenegro (hereinafter: the Central Bank), for the purpose of determining and monitoring the minimum requirement for own funds and eligible liabilities, as well as for fulfilling the resolution function of the Central Bank, including the deadlines for their submission. Mutatis Mutandis Article 2 The provisions of this Decision shall apply mutatis mutandis to legal persons referred to in Article 3, items 2), 3), and 4) of the Law on Resolution of Credit Institutions (hereinafter: the Law). Reports for Determining and Monitoring the Minimum Requirement for Own Funds and Eligible Liabilities Article 3 (1) A credit institution shall submit the following quarterly reports to the Central Bank: 1) report on minimum requirement for own funds and eligible liabilities (MREL1 template); 2) report on own funds and liabilities (RKO template); 3) report on own funds and liabilities presented in accordance with the reverse priority ranking in bankruptcy proceedings (ORP template); 4) report on the structure of eligible liabilities qualified for the internal minimum requirement for own funds and eligible liabilities (IM template); and 5) report on the structure of eligible liabilities (KO template). (2) The reports referred to in paragraph (1) of this Article shall be submitted to the Central Bank no later than 20 days after the end of the quarter to which they relate. Reports for the Purpose of Fulfilling the Resolution Function of the Central Bank Article 4 (1) A credit institution shall submit to the Central Bank annual reports for the purpose of fulfilling the resolution function of the Central Bank, which shall in particular include: 1) report on all valid hedging agreements concluded by the credit institution with other counterparties (swaps, options, and other derivatives); if the credit institution has not entered into such agreements but has purchased derivatives for hedging purposes, documentation of such purchases shall be submitted for all existing hedges (S-UZKR template); 2) list of all valid real estate lease agreements used for business purposes by the credit institution (S-UZ template); 3) list of all valid service agreements with third parties, including service agreements with group members (S-UD template); 4) list of all valid agreements on borrowings under which the credit institution has borrowed from other legal persons (S-UP template); 5) list of all valid subordinated debt agreements (S-USD template); 6) list of all valid intra-group financing agreements as well as intra group guarantee agreements (S-UFG template); 7) list of all valid agreements with foreign correspondent credit institutions with which the credit institution has concluded cooperation agreement (S-UKB template); 8) list of all valid agreements constituting financial liability of the credit institution (deposits, borrowings, subordinated debt, or other financial liabilities) in which the governing law is not the law of Montenegro, but the law of another country (S-PTZ template). (2) Agreements subject to reporting in line with paragraph (1) of this Article shall be submitted by the credit institution in electronic form. (3) Contracts referred to in paragraph (1) of this Article which are not concluded in a language in official use in Montenegro shall be accompanied by a certified translation into Montenegrin by a sworn translator. (4) Reports referred to in paragraph (1) of this Article shall reflect the status as of 31 December of the year preceding the year of submission and shall be submitted no later than 15th of April of the current year. Reporting Templates Article 5 The reports referred to in this Decision shall be submitted by credit institutions using the templates provided in the Annex attached to this decision and making integral part thereof, in electronic format to the e-mail address: sanacija@cbcg.me. _____________________________________________________________________________________________ Decision on reporting to the Central Bank of Montenegro for the purpose of pursuing resolution function (OGM 040/25) 2 Entry into force Article 6 This Decision shall enter into force on the eighth day following that of its publication in the Official Gazette of Montenegro. THE COUNCIL OF THE CENTRAL BANK OF MONTENEGRO CHAIRPERSON Decision number: 0101- 3417 - 3/2025 G OV E R N O R, Podgorica, 17 April 2025 Irena Radović, m.p. _____________________________________________________________________________________________ Decision on reporting to the Central Bank of Montenegro for the purpose of pursuing resolution function (OGM 040/25) 3 ANNEX Reporting Templates MINIMUM REQUIREMENT FOR OWN FUNDS AND MREL1 TEMPLATE ELIGIBLE LIABILITIES (thousand euros) AMOUNT 0010 0100 TOTAL RISK EXPOSURE AMOUNT (TREA) 0200 TOTAL EXPOSURE MEASURE (TEM) 0300 MREL REQUIREMENT AS % OF TREA 0310 MREL REQUIREMENT AS % OF TEM 0400 OWN FUNDS AND ELIGIBLE LIABILITIES 0410 Of which: own funds and subordinated liabilities 0420 Of which: governed by third country law Of which: containing a write down and 0430 conversion clause as referred to in Article 108 of the Law on Resolution of Credit Institutions 0450 OTHER BAIL-INABLE LIABILITIES 0460 Of which: governed by third country law Of which: containing a write down and 0470 conversion clause as referred to in Article 108 of the Law on Resolution of Credit Institutions 0480 Residual maturity of < 1 year 0485 Residual maturity of >= 1 year and < 2 years 0490 Residual maturity of >= 2 years OWN FUNDS AND ELIGIBLE LIABILITIES AS A 0500 PERCENTAGE OF THE TREA 0510 Of which: own funds and subordinated liabilities OWN FUNDS AND ELIGIBLE LIABILITIES AS A 0520 PERCENTAGE OF THE TEM 0530 Of which: own funds and subordinated liabilities _________________________________________________________________________________________________________________________________ Decision on reporting to the Central Bank of Montenegro for the purpose of pursuing resolution function (OGM 040/25) 4 OWN FUNDS AND LIABILITIES OF THE BANK RKO TEMPLATE (thousand euros) MONTENEGRO FOREIGN COUNTRIES Structure of liabilities Code Natural persons Mic e r n o m t , ( e e S s r d M m p i r u E a i m ) s ll e a s nd L u a n rg d e e r b ta u k si i n n e g s s s ins C ti r t e u d ti i o t ns c p o e m I n n p s s a i u o n r n a ie n f s u c n e a d n s d Ot i h n e s r t i f t i u n t a io n n c s ial g O r f o w up h i e c x h p : o In s t u r r a e -go c v e e n C r t n r e a m n l t e b ra n a l t n a k n s d Other li j n u L e ri i s a w d b i i i t c l h i t t i i o E e n U s / / l E i a n E w A l L i j n u ia e ri b s w i d li i i t t c i h e ti s o E n U n / o / l E a t E w in A Total 010 020 030 040 050 060 070 080 090 100 110 120 T C O O T N A V L E R L S IA IO BI N L I P T O IE W S E N R O S T SUBJECT TO WRITE-DOWN AND 100 0 0 0 0 0 0 0 0 0 0 0 0 Covered deposits (Law Article 94 paragraph (3) item 1)) 110 0 Secured liabilities (Law Article 94 paragraph (3) item 2)) 120 0 Liabilities towards clients (Law Article 94 paragraph (3) item 3)) 130 0 Liabilities secured by virtue of a fiduciary relationship (Law Article 94 paragraph (3) item 4)) 135 0 Liabilities to credit institutions < 7 days (Law Article 94 paragraph (3) item 5)) 140 0 Liabilities owed to the settlement systems, operators of these systems or their participants < 7 days (Law Article 94 150 0 paragraph (3) item 6)) Liabilities towards employees (Law Article 94 paragraph (3) item 7) indent 1) 160 0 Liabilities towards creditors (Law Article 94 paragraph (3) item 7) indent 2) 170 0 Liabilities towards tax authorities and authorities competent for health insurance, pension insurance and other benefits under 180 0 the umbrella of social insurance (Law Article 94 paragraph (3) item 7) indent 3) Liabilities towards Deposit Protection Fund (Law Article 94 paragraph (3) item 7) indent 4) 190 0 TOTAL LIABILITIES SUBJECT TO WRITE-DOWN AND CONVERSION POWERS 200 0 0 0 0 0 0 0 0 0 0 0 0 Deposits that are not guaranteed deposits 210 0 0 0 0 0 0 0 0 0 0 0 0 Residual maturity of < 1 year 211 0 Residual maturity of >= 1 year 212 0 Market value of liabilities arising from derivatives* 220 0 S pr u u m de o n f t i n a e l t n p e o tt s in it g io r n u l o e f s liabilities taking into account 221 0 Structured notes 230 0 0 0 0 0 0 0 0 0 0 0 0 Residual maturity of < 1 year 231 0 Residual maturity of >= 1 year 232 0 Unsecured senior liabilities 240 0 0 0 0 0 0 0 0 0 0 0 0 Residual maturity of < 1 year 241 0 Residual maturity of >= 1 year 242 0 Claims of shareholders holding 10% or more of the capital or voting2 r5ig0hts 0 0 0 0 0 0 0 0 0 0 0 0 Residual maturity of < 1 year 251 0 Residual maturity of >= 1 year 252 0 Senior non-preferred liabilities 260 0 0 0 0 0 0 0 0 0 0 0 0 Residual maturity of < 1 year 261 0 Residual maturity of >= 1 year 262 0 Subordinated liabilities (not recognised as part of own funds) 270 0 0 0 0 0 0 0 0 0 0 0 0 Residual maturity of < 1 year 271 0 Residual maturity of >= 1 year 272 0 Non-financial liabilities 280 0 Remaining liabilities 290 0 OWN FUNDS 300 0 Common Equity Tier 1 capital 310 Additional Tier 1 capital 320 Tier 2 capital 330 TOTAL OWN FUNDS AND LIABILITIES INCLUDING LIABILITIES FROM DERIVATIVES 400 0 TOTAL CAPITAL 500 TOTAL ASSETS 600 COMMENT ON DERIVATIVE LIABILITIES *This category includes liabilities arising from derivatives, based on their market value and counterparty rights. If the value is reported as zero, the following should be stated in this comment section: a. The bank has no derivatives b. The net derivative position is reported on the asset side of the balance sheet _________________________________________________________________________________________________________________________________ Decision on reporting to the Central Bank of Montenegro for the purpose of pursuing resolution function (OGM 040/25) 5 _________________________________________________________________________________________________________________________________ Decision on reporting to the Central Bank of Montenegro for the purpose of pursuing resolution function (OGM 040/25) 6 N o. 0 1 0012345678910 11 1213 14 O W N FU N D S A N D LIA B ILITIES P R ES EN TED IN LIN E W ITH TH E R EV ER S E P R IO R ITY R A N K IN G IN B A N K R U P TC Y P P riority ranking (reverse priority ranking in bankruptcy proceedings) 0 2 0 Am ount of balance sheet capital not included in ow n funds C om m on Equity Tier 1 capital Additional Tier 1 capital Tier 2 capital and am ortised Tier 2 capital instrum ents Subordinated debt not included in ow n funds Internal M REL External (subordinated) M REL C laim s that no longer m eet the conditions for external M REL from item 6), but rem ain subordinated C laim s of bank’s shareholders C laim s of other creditors (including eligible liabilities that are not subordinated) C laim s based on covered deposits not included under no. 11 and 12 C laim s of natural and legal persons classified under the accounting law as m icro, sm all, or m edium -sized enterprises, based on covered deposits exceeding the guaranteed deposit am ount C laim s of the D eposit Protection Fund C laim s of the C entral Bank in accordance w ith the Bank Bankruptcy and Liquidation Law C laim s secured up to the value of their collateral O W N FU N D S A N D LIA B ILITIES TO TA L O W N FU N D S A N D LIA B ILITIES A N D B A LA N C E S H EET C A P ITA L N O T IN C LU D ED IN O W N FU N D S R O C EED IN G S O w n funds and liabilities of w hich: liabilities excluded from bail- in instrum ent 0 3 0 0 4 0` 00 0 00 0 0 0 0 0 0 5 000000000000 0 00 00 0 O w n funds and liabilities m inus liabilities excluded from bail-in instrum ent of w hich: w ith residual m aturity of w hich: ow n funds and eligible liabilities that can be used for ≥ 1 year ≥ 2 years ≥ 5 years fulfilling M R EL ≥ 1 0 years < 2 years < 5 years < 1 0 years requirem ent 0 6 0 0 7 0 0 8 0 0 9 0 1 0 0 0000000000 0 0 0 0 0 0 0 0 0 0 0 O RP TEM PLA TE thousand euros W ithout m aturity 1 1 0 0 0 0 INTERNAL MREL IM TEMPLATE (thousand euros) AMOUNT 0010 0100 TOTAL RISK EXPOSURE AMOUNT (TREA) 0110 TOTAL EXPOSURE MEASURE (TEM) 0200 OWN FUNDS AND ELIGIBLE LIABILITIES 0210 ELIGIBLE OWN FUNDS 0220 Common Equity Tier 1 capital (CET1) 0230 Eligible Additional Tier 1 capital 0240 Eligible Tier 2 capital 0250 Eligible liabilities and guarantees 0260 Eligible liabilities (excluding guarantees) Guarantees provided by the resolution entity and permitted by the 0270 resolution authority 0280 Of which: Collateralised part of the guarantee (-) Own funds instruments and eligible liabilities instruments issued by 0290 non-resolution entities of the same resolution group 0293 (-) Of which: Own funds instruments issued by liquidation entities 0295 Excess of deductions from eligible liabilities over eligible liabilities RATIOS OF ELIGIBLE OWN FUNDS AND ELIGIBLE LIABILITIES OWN FUNDS AND ELIGIBLE LIABILITIES AS A PERCENTAGE OF THE 0400 TREA 0410 of which: permitted guarantees 0420 OWN FUNDS AND ELIGIBLE LIABILITIES AS A PERCENTAGE OF THE TEM 0430 of which: permitted guarantees 0440 CET1 (%) available after meeting the entity’s requirements BAIL-INABLE LIABILITIES 0550 Other bail-inable liabilities 0560 Of which: governed by third country law Of which: containing a write down and conversion clause as referred to 0570 in Article 108 of the Law on Resolution of Credit Institutions 0580 Residual maturity of < 1 year 0590 Residual maturity of >= 1 year and < 2 years 0600 Residual maturity of >= 2 years Own funds and eligible liabilities issued by liquidation entities of the 0620 same resolution group Ratio of own funds instruments issued by liquidation entities over 0630 eligible own funds and eligible liabilities _________________________________________________________________________________________________________________________________ Decision on reporting to the Central Bank of Montenegro for the purpose of pursuing resolution function (OGM 040/25) 7 STRUCTURE OF ELIGIBLE LIABILITIES KO TEMPLATE (thousand euros) AMOUNT 0100 ELIGIBLE LIABILITIES 0200 Non-covered and non-preferential deposits >= 1 year 0210 Of which: residual maturity of >= 1 year and < 2 years 0220 Of which: Residual maturity of >= 2 years 0230 Of which: issued by dependent legal persons 0300 Liabilities secured and not covered by collateral >= 1 year 0310 Of which: residual maturity of >= 1 year and < 2 years 0320 Of which: residual maturity of >= 2 years 0330 Of which: issued by dependent legal persons 0400 Structured notes >= 1 year 0410 Of which: residual maturity of >= 1 year and < 2 years 0420 Of which: residual maturity of >= 2 years 0430 Of which: issued by dependent legal persons 0500 Unsecured senior liabilities >= 1 year 0510 Of which: residual maturity of >= 1 year and < 2 years 0520 Of which: residual maturity of >= 2 years 0530 Of which: issued by dependent legal persons 0600 Non-preferred unsecured senior liabilities >= 1 year 0610 Of which: residual maturity of >= 1 year and < 2 years 0620 Of which: residual maturity of >= 2 years 0630 Of which: issued by dependent legal persons 0700 Subordinated liabilities (not recognised as part of own funds) >= 1 year 0710 Of which: residual maturity of >= 1 year and < 2 years 0720 Of which: residual maturity of >= 2 years 0730 Of which: issued by dependent legal persons 0800 Other eligible liabilities >= 1 year 0810 Of which: residual maturity of >= 1 year and < 2 years 0820 Of which: residual maturity of >= 2 years 0830 Of which: issued by dependent legal persons _________________________________________________________________________________________________________________________________ Decision on reporting to the Central Bank of Montenegro for the purpose of pursuing resolution function (OGM 040/25) 8 _________________________________________________________________________________________________________________________________ Decision on reporting to the Central Bank of Montenegro for the purpose of pursuing resolution function (OGM 040/25) 9 N o 1 2 3 4 5 . C o u n t 0 e 1 r 0 p a r t y C R E D I T R I S K H E D C G o n I N t r G a C O c t n 0 2 0 N u m T R b A e C r T S C o n t r a 0 c 3 t 0 d a t e S - U Z K N 0 R o 4 T t e 0 E M P L A T E S-UD CONTRACTS WITH SUPPLIERS TEMPLATE Subject Payment Organisational Contract Validity of the Amoun Applicabl Supplier (monthly/annually Note unit date date contrac t e law No. ) t 010 020 030 040 050 060 070 080 090 1 2 3 4 5 _________________________________________________________________________________________________________________________________ Decision on reporting to the Central Bank of Montenegro for the purpose of pursuing resolution function (OGM 040/25) 10 N o 1 2 3 4 5 . C re 0 d 1 ito 0 r L o a n re c e 0 2 ip 0 t d a te In te re s t ra 0 3 0 te % B O R A R p O p W ro IN v e 0 G S C d a m 4 0 O o N T R u n t A C T B S a la n c th e p e a s a re v io t 3 1 D e u s c a le 0 5 0 cn ed ma b e r (O r y e a r) f M a tu rity 0 6 0 d a te A p p lic a b le 0 7 0 la w S -U P N o 0 8 T E te 0 M P L A T E _________________________________________________________________________________________________________________________________ Decision on reporting to the Central Bank of Montenegro for the purpose of pursuing resolution function (OGM 040/25) 11 N N o 1 2 3 4 5 o 1 2 3 4 5 . . C o u C r e d 0 1 n te rp 0 1 0 it o r 0 a rty C o n C o n t r a c 0 tra c t n u m 0 2 0 t n 2 0 b e u r m b e r C o n S U B O R D IN A T E C o n t r a c t d a t e 0 3 0 IN T R A -G R O U P tra c t d a te 0 3 0 D F D E B IN A N A m 0 T C C IN o u n 4 0 O G t N C T R A C T S A m o u n t 0 4 0 O N T A C T S In te re s t ra 0 5 0 te % In t e r C e s t r a t e 0 5 0 o n tra c t e % x p 0 6 ira 0 C tio o n n d t r a a te c t e x p ir a t io n 0 6 0 A p p lic a b le 0 7 0 d a t la w e S - U S S D T E M N o t e 0 7 0 -U F G T E N o te 0 8 0 M P L A P L A T T E E _________________________________________________________________________________________________________________________________ Decision on reporting to the Central Bank of Montenegro for the purpose of pursuing resolution function (OGM 040/25) 12 N o 1 2 3 4 5 . C o u n t 0 e 1 r 0 p a r t y C C O N u r r e n 0 2 0 T c R y A C T S W IT H C O R A R c c E o S u P O N n t n 0 3 0 D u E m N b T e B r A N K S C o n t r a c 0 t n 4 0 u m b e r C o n t r a c t 0 5 0 d a t e S - U K N 0 B o 6 T t e 0 E M P L A T E CONTRACTS REPRESENTING BANK'S FINANCIAL LIABILITY SUBJECT TO THIRD-COUNTRY LAW S-UO TEMPLATE Contractual liability under Article 42, Contractual liability paragraph (1) items Contract expiration under Article 108 16) to 18) and Counterparty Contract number Contract date Amount Interest rate % Applicable law Note No. date paragraph (1) of the Article 55 paragraph Law (1) items 13) to 15) of the Decision on Capital Adequacy 010 020 030 040 050 060 070 080 090 100 1 2 3 4 5 6 7 8 9 10

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