XML 194 R48.htm IDEA: XBRL DOCUMENT

Risk Management

12 Months Ended

Dec. 31, 2019

Disclosure of nature and extent of risks arising from financial instruments [abstract]

Risk Management

42.

Risk Management:

(1)

Introduction

The Bank's risk management is based on specialization, knowledge of the business and the experience of its teams, with professionals specifically dedicated to each different type of risks. Our policy is to maintain an integrated, forward looking approach to risk management, taking into account the current and forecasted economic environment and the risk/return ratio of all products for both the Bank and its subsidiaries.

Our risk management policies are established in order to identify and analyze the risks faced by the Bank, set appropriate risk limits and controls, and to monitor the risks and compliance with the limits. Policies and risk management systems are reviewed regularly. Through its administration policies and procedures, the Bank develops a disciplined and constructive control environment.

(a)

Risk Management Structure

Credit and Market Risk Management are at the all levels of the Organization, with a structure that recognizes the relevance of the different risk areas that exist. The current levels are:

(i)

Board of Directors

The Board is responsible for approving the policies and establishing the structure for the proper administration of the various risks faced by the organization. The Board is permanently informed of the evolution of the different risk areas, participating through its Finance, International and Financial Risk, Credit, Portfolio Risk Committee and Higher Operational Risk Committee, in which the status of credit, market and operational risks are reviewed.

(ii)

Finance, International and Financial Risk Committee

This committee functions are to design policies and procedures related to price and liquidity risk; design a structure of limits and alerts of financial exposures, and ensure a correct and timely measurement, control and reporting thereof; track exposures and financial risks; analyze impacts on the valuation of operations and / or results due to potential adverse movements in the values of market variables or liquidity narrowness; review the stress test assumptions and establish action plans where appropriate ; ensure the existence of independent units that value financial positions, and analyze the results of financial positions; track the international financial exposure of liabilities; review the main credit exposures of Treasury products (derivatives, bonds); ensure that the management guidelines for price and liquidity risks in subsidiaries are consistent with those of the Bank, and be aware of the evolution of their main financial risks.

The Finance, International and Financial Risk Committee, sessions monthly and comprises of the Chairman of the Board, two Directors or Advisors to the Board, General Manager, Corporate Division Manager, Wholesale Credit Risk Division Manager, Treasury Division Manager and Financial Risk Area Manager. If deemed appropriate, the Committee may invite certain persons to participate, on a permanent or occasional basis, in one or more sessions.

(iii)

Credit Committees

The credit approval process is done mainly through various credit committees, which are composed of qualified professionals and with the necessary attributions to take decisions required.

Each committee is responsible for defining the terms and conditions under which the Bank accepts counterparty risks and the Retail Credit Risk and Wholesale Credit Risk Divisions participate independently and autonomously of the commercial areas. They are constituted according to the commercial segments and the amounts to approve and have different meeting periodicities.

Within the risk management structure of the Bank, the maximum approval instance is the Credit Committee of Directors. Sessions weekly and comprises of the Chairman of the Board, regular and alternate directors, Board Advisors, General Manager and the Wholesale Credit Risk Division Manager. This Committee is responsible for knowing, analyzing and resolving all credit operations associated with clients and / or economic groups whose total amount subject for approval is equal to or greater than UF 750,000. It also has to know, analyze and resolve all those credit operations that, in accordance with the established in the Bank's internal rules, must be approved by this Committee, with the exception of the special powers delegated by the Board to the Administration.

(iv)

Portfolio Risk Committee

The main function is to know the evolution of the composition, concentration and risk of the loan portfolio of the different banks and segments. Review the main debtors and the different risk indicators of the portfolio, proposing differentiated management strategies. Approves and proposes to the Board the different credit risk policies. It is responsible for reviewing, approving and recommending to the Board of Directors, for its final approval, the different portfolio evaluation methodologies and provision models. It is also responsible for reviewing and analyzing the adequacy of provisions for the different banks and segments. Also to review the guidelines and methodological advances for the development of internal models of credit risk, together with monitoring the concentration by sectors and segments according to the sectoral limits policy. In general, any matter that involves Credit Risk on which senior management must pronounce.

The Portfolio Risk Committee meets monthly and comprises of the Chairman of the Board, a regular and alternate Director, General Manager, Wholesale Credit Risk Division Manager, Retail Credit Risk Division Manager, Commercial Division Manager, Risk Management and Information Control Manager.

(v)

Corporate Credit Risk Structure

The bank corporate governance considers the active participation of the Board, who establishes the policies and guidelines regarding the accepted risk levels, the Administration being responsible for the control and compliance with the provisions set forth by the Board, together with the setting of standards and procedures related. Likewise, the Board establishes the guidelines for the development and validation of models, approves the provisions models and pronounced about the sufficiency of provisions.

At the administration level, the Retail Credit Risk, Wholesale Credit Risk and Global Risk Control divisions comprise the corporate risk governance structure, which through specialized teams, added to a robust regulatory framework of processes and procedures allow optimal management and effective in the subjects they address. The first two are responsible for the credit risk in the admission, monitoring and recovery phases, in the respective Retail and Wholesale segments. Along with this, in the Retail Credit Risk Division the different methodologies related to regulatory and management aspects are developed. The Wholesale Credit Risk Division, in turn, has a Market Risk Area responsible for measuring, limiting, controlling and reporting said risk along with the valuation standards definition.

The Global Risk Control Division through the Operational and Technological Risk Areas, which incorporates Business Continuity, is responsible for controlling those risks, also has an Internal Validation Area of Risk Models.

Additionally, the Bank has a Cybersecurity Division, focused on protecting and monitoring the most sensitive assets of the organization, being able to provide security and confidence to customers and collaborators, whose main objective is to have a secure bank, cyber-resilient and prepared to face any type of threat that puts the reputation and information of the organization at risk.

These divisions have teams with extensive experience and knowledge in each area associated with credit and market risks, ensuring their integral and consolidated management, including the Bank and its subsidiaries.

(b)

Measurement Methodology

Regarding to Credit Risk, provision levels and portfolio expenses are the basic measures for determining the credit quality of our portfolio.

Banco de Chile permanently evaluates its loan portfolio, timely recognizing the associated level of risk of the loan portfolio. For this comprehensive credit risk assessment, there are policies, standards, procedures, along with models developed in accordance with the instructions issued by the Financial Market Commission ("CMF") and approved by the Board of Directors.

As a result of this evaluation, on both individual and group portfolios, the level of provisions that the bank should constitute is determined, in the event of customers payment default.

The individual evaluation mainly applies to the Bank's portfolio of legal persons that, due to their size, complexity or indebtedness, requires a more detailed level of knowledge and a case-by-case analysis. Each debtor individually assessed is assigned one of the 16 risk categories defined by the CMF, in order to establish the provisions in a timely and appropriate manner. This review of the portfolio risk classifications is carried out permanently considering the financial situation, payment behavior and the environment of each client.

The group evaluation mainly applies to the portfolio of natural persons and smaller companies. These assessments are carried out monthly through statistical models that allow estimating the appropriate level of provisions necessary to cover the portfolio risk. The consistency of the models is analyzed through an independent validation of the unit that develops them and, subsequently, through the analysis of retrospective tests that allow to compare the real losses with the expected ones.

The Bank annually performs a sufficiency test of provisions for the total portfolio of loans, in order to validate the quality and robustness of the risk assessment processes, verifying that the provisions constituted are sufficient to cover the losses that could be derive from the credit operations granted. The result of this analysis is presented to the Board of Directors, who declares on the sufficiency of the provisions in each year.

Banco de Chile constitutes additional provisions with the objective of protecting itself from the risk of unpredictable economic fluctuations that may affect the macroeconomic environment or the situation of a specific economic sector. The amount of additional provisions to be constituted or released is annually proposed to the Portfolio Risk Committee and subsequently to the Board of Directors for approval.

The monitoring and control of risks are carried out mainly based on limits established by the Board of Directors. These limits reflect the Bank's business and market strategy, as well as the level of risk that it is willing to accept, with additional emphasis on the selected industries.

The Bank's General Manager receives on daily basis, and the Finance, International and Financial Risk Committee on a monthly basis, the evolution of the Bank's price and liquidity risk status, both according to internal metrics and those imposed by the regulators.

(2)

Credit Risk

Credit risk considers the likelihood that the counterparty in the credit operation will not meet its contractual obligation due to incapacity or financial insolvency, and this leads to a potential credit loss.

Credit risk management has a relevant focus on the adequate risk-return relation, is permanent and considers the processes of admission, monitoring and recovery of loans granted. In this management, an adequate balance of the risks assumed is taken into account, ensuring the solvency of the Bank over time.

The established credit risk policies and processes recognize the singularities that exist in the different markets and segments, and grant a specialized treatment to each of them.

The above results in the following management principles:

Rigorous evaluation in the admission process applying the defined credit risk policies, their associated rules and procedures, together with the availability of sufficient and accurate information. This implies analyzing the generation of flows and solvency of the client to meet the payment commitments and, when the characteristics of the operation merit it, must constitute adequate collateral that allow mitigating the risk incurred with the client.

	2.	Have permanent and robust portfolio tracking processes, through systems that alert both the potential signs of impairment in relation to the conditions of origin, as well as the possible business opportunities with those clients that present a better payments quality and behavior.
	3.	To develop advanced modeling and data management tools that allow for efficient decision-making at different stages of the credit process.

Have a collection structure with agile and efficient processes that allow carrying out procedures according to the different types of defaults presented by the clients.

Maintain an efficient administration in work teams organization, tools and availability of information that allow an optimal credit risk management.

Credit Risk Divisions continuously manage risk knowledge in order to contribute to the business and anticipate threats that may affect the solvency and quality of the portfolio. Its mission is to establish the Credit Risk management framework for the different segments of the Bank, within the defined regulatory scope and at the risk established by the entity, through a portfolio vision that allows us to manage, resolve and control the process of approval of operations related to the different portfolios of the Bank, in an efficient and proactive manner.

(a)

Retail Segment

Admission management in these segments is mainly carried out through an evaluation that uses scoring tools, accompanied by an adequate model of credit attributions, which are required to approve each operation. These evaluations take into account the level of indebtedness, payment capacity and the maximum acceptable exposure for the client.

In these segments, the Bank has segregated functions, distributed in the following areas:

−

Model Area, has the responsibility of constructing statistical models, establishing the variables and their respective weightings. These models are validated by the Model Validation Area and submitted to the Models Technical Committee before approval in the Portfolio Risk Committee or the Board of Directors, as appropriate.

−

Area of Integration in Management is responsible for incorporating statistical models in credit evaluation processes, ensuring an adequate linkage of the decision.

−

Admission Area performs the evaluation of operations and clients, with specialization by regions and segments, which favors their knowledge of clients and socio-economic background. It also maintains a framework of policies and standards that ensure the quality of the portfolio according to the desired risk, defining guidelines for the admission of clients that are released to commercial and risk areas through programs and continuous training.

−

Model and Portfolio Tracking Area is responsible for evaluating and measuring the performance of the models and the behavior of the portfolios, the latter especially through the monitoring of the main indicators of aggregate portfolio and layers analysis, reported in management reports, generating relevant information for decision making in different defined instances. This Area also ensures proper execution of the strategy, meeting the objectives of risk quality and return.

−

Collection Area performs a cross-collection management in the Bank and centralizes recovery management in retail segments through Socofin, Bank's subsidiary company, defining refinancing criteria and payment agreements with customers, along with the incorporation of robust tools for collection management.

(b)

Wholesale Segment

Admission management in these segments is based on an individual evaluation of the client and if it belongs to a group of companies, the relationship of the rest of the group with the Bank is also considered. This individual and group evaluation, if applicable, considers, among others, the financial capacity with emphasis on equity solvency, generation capacity, exposure levels, industry variables, evaluation of partners and management and aspects of the operation such as financing, term, products and possible collaterals.

This process is supported by a rating model that allows greater homogeneity in the evaluation of the client and his group. Additionally, for the evaluation of clients, there are specialized areas in some segments that, due to their nature, require expert knowledge, such as real estate, construction, agricultural, financial, and international, among others.

The permanent monitoring of the portfolio is carried out in a centralized manner, based on information periodically updated by both the client and the industry. Monitoring of compliance with the special conditions established in the admission stage is carried out, such as controls of financial covenants, coverage of certain collaterals and restrictions imposed at the time of approval. Alerts are also generated through monitoring to ensure the correct classification of the individual portfolio.

Additionally, within the Admission areas, joint tasks are carried out that allow monitoring the development of operations from their gestation to their recovery, in order to ensure that the portfolio's risks are well recognized in a timely manner.

Upon detection of clients that show signs of impairment or default with any condition, the commercial area to which the client belongs together with the Wholesale Credit Risk Division, establish action plans to regularize said situation. In those cases where they present problems in the recovery of their credits, there is the area of Special Asset Management, belonging to the Wholesale Credit Risk Division, in charge of the collection management, establishing action plans and negotiations based on the particular characteristics of each client.

(c)

Derivative Transactions

We produce own models which are used for credit risk management purposes, known as the pre-settlement exposure (PSE). Generally, the PSE is computed as follows:

PSE = Maximum (CMTM + CEF * Notional, 0)

CMTM: Current Mark-to-Market of the transaction

Notional: Transaction notional amount

CEF: Credit Exposure Factor, which reflects the peak exposure within the life of the transaction, under 95% of confidence level.

The portfolio approach is taken into account when computing exposures of several transactions closed with one single counterpart.

Credit mitigating conditions for derivative transactions have become popular in the local financial markets. There are financial institutions that have accepted early termination clauses, and netting is also possible with corporations when appropriate documentation under a regular Master Agreement is signed.

Collateral agreements have been requested by certain banks for inter-banking transactions within other financial institutions, but its effective application under Chilean Law make advisable not to include it in the exposure measurement.

Derivatives transactions closed with counterparts residing abroad (mostly global banks) are documented utilizing ISDA and CSA. Netting and cash collateral above a certain threshold level are the typical credit mitigations schemes in place for this kind of transactions.

This metric is used for measuring, limiting, controlling and reporting credit exposures by counterparty.

(d)

Portfolio Concentration:

The maximum exposure to credit risk, by client or counterparty, without taking into account guarantees or other credit enhancements as of December 31, 2018 and 2019 does not exceed 10% of the Bank's effective equity.

The following tables show credit risk exposure per balance sheet item, including derivatives, detailed by both geographic region and industry sector as of December 31, 2018:

Chile

United States

Brazil

Other

Total

MCh$

Financial Assets

Cash and Due from Banks

773,368

69,343

―

37,370

880,081

Financial Assets held-for-trading

From the Chilean Government and Central Bank of Chile

1,523,472

―

1,523,472

Other instruments issued in Chile

129,607

―

129,607

Instruments issued abroad

―

4,446

―

4,446

Mutual fund investments

87,841

―

87,841

Subtotal

1,740,920

4,446

―

1,745,366

Investments under resale agreements

97,289

―

97,289

Derivative Contracts for Trading Purposes

Forwards

670,595

23,082

―

41,767

735,444

Swaps

453,191

98,414

―

186,525

738,130

Call Options

4,309

―

530

4,839

Put Options

―

120

Futures

―

Subtotal

1,128,151

121,496

―

228,886

1,478,533

Hedge Derivative Contracts

Forwards

―

Swaps

4,547

14,348

―

16,519

35,414

Call Options

―

Put Options

―

Futures

―

Others

―

Subtotal

4,547

14,348

―

16,519

35,414

Loans and advances to Banks (before allowances)

Central Bank of Chile

1,100,831

―

1,100,831

Domestic banks

100,023

―

100,023

Foreign banks

―

209,693

84,849

294,542

Subtotal

1,200,854

―

209,693

84,849

1,495,396

Loans to Customers at amortized cost (before allowances)

Commercial loans

15,344,854

―

354

93,190

15,438,398

Residential mortgage loans

8,052,073

―

8,052,073

Consumer loans

4,436,161

―

4,436,161

Subtotal

27,833,088

―

354

93,190

27,926,632

Financial Assets at Fair Value through OCI

Debt Instruments:

From the Chilean Government and Central Bank

164,222

―

164,222

Other instruments issued in Chile

770,674

―

770,674

Instruments issued abroad

―

108,544

―

108,544

Subtotal

934,896

108,544

―

1,043,440

Equity Instruments:

Other instruments issued in Chile

8,939

―

8,939

Instruments issued abroad

―

812

Subtotal

8,939

―

812

9,751

Total

943,835

108,544

812

1,053,191

Financial Services

Chilean Central Bank

Government

Retail (Individuals)

Trade

Manufacturing

Mining

Electricity, Gas and Water

Agriculture and Livestock

Fishing

Transportation and Telecom

Construction

Services

Other

Total

MCh$

Financial Assets

Cash and Due from Banks

758,274

121,807

―

880,081

Financial Assets held-for-trading

From the Chilean Government and Central Bank of Chile

―

1,434,986

88,486

―

1,523,472

Other instruments issued in Chile

129,607

―

129,607

Instruments issued abroad

4,446

―

4,446

Mutual fund investment

87,841

―

87,841

Subtotal

221,894

1,434,986

88,486

―

1,745,366

Investments under resale agreements

29,031

742

―

37,520

―

5,017

4,466

3,096

15,637

―

985

736

97,289

Derivative Contracts for Trading Purposes

Forwards

374,006

―

7,194

13,328

10,288

4,211

411

455

296

325,117

735,444

Swaps

584,743

―

51,916

7,348

4,026

10,006

2,249

2,235

680

74,250

655

738,130

Call Options

1,669

―

389

―

1,090

1,489

―

4,839

Put Options

―

120

Futures

―

Subtotal

960,482

―

59,550

20,697

15,404

15,706

2,740

2,333

1,194

74,582

325,783

1,478,533

Hedge Derivative Contracts

Forwards

―

Swaps

35,414

―

35,414

Call Options

―

Put Options

―

Futures

―

Subtotal

35,414

―

35,414

Loans and advances to Banks

Central Bank of Chile

―

1,100,831

―

1,100,831

Domestic banks

100,023

―

100,023

Foreign banks

294,542

―

294,542

Subtotal

394,565

1,100,831

―

1,495,396

Loans to Customers at amortized cost

Commercial loans

2,122,599

―

2,324,325

1,579,475

453,549

461,351

1,582,520

156,472

1,498,142

1,752,237

2,109,491

1,398,237

15,438,398

Residential mortgage loans

―

8,052,073

―

8,052,073

Consumer loans

―

4,436,161

―

4,436,161

Subtotal

2,122,599

―

12,488,234

2,324,325

1,579,475

453,549

461,351

1,582,520

156,472

1,498,142

1,752,237

2,109,491

1,398,237

27,926,632

Financial Assets at Fair Value through OCI

Debt Instruments:

From the Chilean Government and Central Bank of Chile

―

135,145

29,077

―

164,222

Other instruments issued in Chile

680,656

―

22,390

―

8,245

―

4,938

―

54,445

770,674

Instruments issued abroad

108,544

―

108,544

Subtotal

789,200

135,145

29,077

―

22,390

―

8,245

―

4,938

―

54,445

1,043,440

Equity Instruments:

Instruments issued in Chile

8,939

―

8,939

Instruments issued abroad

812

―

812

Subtotal

9,751

―

9,751

Total

798,951

135,145

29,077

―

22,390

―

8,245

―

4,938

―

54,445

1,053,191

The following tables show credit risk exposure per balance sheet item, including derivatives, detailed by both geographic region and industry sector as of December 31, 2019:

Chile

United States

Brazil

Other

Total

MCh$

Financial Assets

Cash and Due from Banks

1,144,109

1,145,703

―

102,354

2,392,166

Financial Assets held-for-trading

From the Chilean Government and Central Bank of Chile

1,123,689

―

1,123,689

Other instruments issued in Chile

375,337

―

375,337

Instruments issued abroad

―

Mutual fund investments

373,329

―

373,329

Subtotal

1,872,355

―

1,872,355

Investments under resale agreements

142,329

―

142,329

Derivative Contracts for Trading Purposes

Forwards

872,481

53,923

―

30,228

956,632

Swaps

1,142,174

167,818

―

451,960

1,761,952

Call Options

4,961

―

4,961

Put Options

807

―

258

1,076

Futures

―

Subtotal

2,020,423

221,752

―

482,446

2,724,621

Hedge Derivative Contracts

Forwards

―

Swaps

5,864

25,780

―

29,950

61,594

Call Options

―

Put Options

―

Futures

―

Others

―

Subtotal

5,864

25,780

―

29,950

61,594

Loans and advances to Banks (before allowances)

Central Bank of Chile

630,053

―

630,053

Domestic banks

150,007

―

150,007

Foreign banks

―

244,969

115,162

360,131

Subtotal

780,060

―

244,969

115,162

1,140,191

Loans to Customers at amortized cost (before allowances)

Commercial loans

16,279,527

―

14,685

16,294,212

Residential mortgage loans

9,206,727

―

9,206,727

Consumer loans

4,532,333

―

4,532,333

Subtotal

30,018,587

―

14,685

30,033,272

Financial assets available-for-sale

Debt Instruments:

From the Chilean Government and Central Bank

109,062

―

109,062

Other instruments issued in Chile

1,228,931

―

1,228,931

Instruments issued abroad

―

19,853

Subtotal

1,337,993

―

19,853

1,357,846

Equity Instruments:

Instruments issued in Chile

7,446

―

7,446

Instruments issued abroad

―

1,051

Subtotal

7,446

―

1,051

8,497

Total

1,345,439

―

20,904

1,366,343

Financial Services

Chilean Central Bank

Government

Retail (Individuals)

Trade

Manufacturing

Mining

Electricity, Gas and Water

Agriculture and Livestock

Fishing

Transportation and Telecom

Construction

Services

Other

Total

MCh$

Financial Assets

Cash and Due from Banks

2,213,737

178,429

―

2,392,166

Financial Assets held-for-trading

From the Chilean Government and Central Bank of Chile

―

1,024,525

99,164

―

1,123,689

Other instruments issued in Chile

375,337

―

375,337

Instruments issued abroad

―

Mutual fund investment

373,329

―

373,329

Subtotal

748,666

1,024,525

99,164

―

1,872,355

Investments under resale agreements

66,285

―

18,460

278

40,642

―

2,067

1,533

902

8,665

―

3,441

142,329

Derivative Contracts for Trading Purposes

Forwards

480,269

―

1,532

16,225

2,856

22,903

14,103

642

1,930

277

497

415,319

956,632

Swaps

1,693,048

―

9,813

7,718

14,184

10,232

4,275

12,526

210

―

9,923

1,761,952

Call Options

1,196

―

1,569

280

―

1,433

171

―

190

4,961

Put Options

554

―

522

―

1,076

Futures

―

Subtotal

2,175,067

―

1,536

28,129

8,077

2,875

37,087

25,768

5,088

14,456

571

687

425,280

2,724,621

Hedge Derivative Contracts

Forwards

―

Swaps

61,594

―

61,594

Call Options

―

Put Options

―

Futures

―

Subtotal

61,594

―

61,594

Loans and advances to Banks

Central Bank of Chile

―

630,053

―

630,053

Domestic banks

150,007

―

150,007

Foreign banks

360,131

―

360,131

Subtotal

510,138

630,053

―

1,140,191

Loans to Customers at amortized cost

Commercial loans

2,587,559

―

2,066,372

1,624,972

604,660

325,143

1,623,465

140,709

1,234,087

2,142,699

2,267,869

1,676,677

16,294,212

Residential mortgage loans

―

9,206,727

―

9,206,727

Consumer loans

―

4,532,333

―

4,532,333

Subtotal

2,587,559

―

13,739,060

2,066,372

1,624,972

604,660

325,143

1,623,465

140,709

1,234,087

2,142,699

2,267,869

1,676,677

30,033,272

Financial Assets at Fair Value through OCI

Debt Instruments:

From the Chilean Government and Central Bank of Chile

―

92,824

16,238

―

109,062

Other instruments issued in Chile

994,658

―

9,667

―

178,444

―

46,162

1,228,931

Instruments issued abroad

19,853

―

19,853

Subtotal

1,014,511

92,824

16,238

―

9,667

―

178,444

―

46,162

1,357,846

Equity Instruments:

Instruments issued in Chile

7,446

―

7,446

Instruments issued abroad

1,051

―

1,051

Subtotal

8,497

―

8,497

Total

1,023,008

92,824

16,238

―

9,667

―

178,444

―

46,162

1,366,343

(e)

Collateral and Other Credit Enhancements

The amount and type of collateral required depends on the counterparty's credit risk assessment.

The Bank has guidelines regarding the acceptability of types of collateral and valuation parameters.

The main types of collateral obtained are:

For commercial loans: Residential and non-residential real estate, liens and inventory.

For retail loans: Mortgages loans on residential property.

The Bank also obtains collateral from parent companies for loans granted to their subsidiaries.

Management makes sure its collateral is acceptable according to both external standards and internal policies guidelines and parameters. The Bank has approximately 235,878 collateral assets, the majority of which consist of real estate.

The following table contains guarantees values as of December 31, 2018 and 2019:

			Fair value of collateral and credit enhancements held as of December 31, 2018
	Maximum exposure to credit risk		Mortgages		Pledge (*)		Securities		Warrants		Others		Net collateral		Net exposure
Loans to customers:	MCh$		MCh$		MCh$		MCh$		MCh$		MCh$		MCh$		MCh$
Corporate lending		11,705,859		2,589,429		75,105		423,556		2,263		221,919		3,312,272		8,393,587
Small business lending		3,732,539		2,977,286		31,270		28,974		―		71,140		3,108,670		623,869
Consumer lending		4,436,161		332,030		967		2,244		―		20,090		355,331		4,080,830
Mortgage lending		8,052,073		7,493,073		58		265		―		―		7,493,396		558,677
Total		27,926,632		13,391,818		107,400		455,039		2,263		313,149		14,269,669		13,656,963

			Fair value of collateral and credit enhancements held as of December 31, 2019
	Maximum exposure to credit risk		Mortgages		*Pledge ()**		Securities		Warrants		Others		Net collateral		Net exposure
Loans to customers:	MCh$		MCh$		MCh$		MCh$		MCh$		MCh$		MCh$		MCh$
Corporate lending		12,117,724		2,453,533		82,365		345,246		2,182		207,052		3,090,378		9,027,346
Small business lending		4,176,488		3,133,480		30,466		26,674		―		74,725		3,265,345		911,143
Consumer lending		4,532,333		341,495		966		2,045		―		20,646		365,152		4,167,181
Mortgage lending		9,206,727		8,019,519		51		176		―		―		8,019,746		1,186,981
Total		30,033,272		13,948,027		113,848		374,141		2,182		302,423		14,740,621		15,292,651

(*)

Includes agricultural and industrial pledges, and pledges without conveyance.

The Bank also uses mitigating tactics for credit risk on derivative transactions. To date, the following mitigating tactics are used:

●

Accelerating transactions and net payment using market values at the date of default of one of the parties.

	●	Option for both parties to terminate early any transactions with a counterparty at a given date, using market values as of the respective date.

●

Margins established with time deposits by customers that close FX forwards with subsidiary Banchile Corredores de Bolsa S.A.

The value of the guarantees that the Bank maintains related to the loans individually classified as impaired as of December 31, 2018 and 2019 is Ch$85,721 million and Ch$100,133 million, respectively.

The value of the guarantees that the Bank maintains related to non-impaired loans as of December 31, 2018 and 2019 is Ch$295,634 million and Ch$344,098 million, respectively.

(f)

Credit Quality by Asset Class:

The Bank determines the credit quality of financial assets using internal credit ratings. The rating process is linked to the Bank's approval and monitoring processes and is carried out in accordance with risk categories established by current standards. Credit quality is continuously updated based on any favorable or unfavorable developments to customers or their environments, considering aspects such as commercial and payment behavior as well as financial information.

The Bank also conducts reviews of companies in certain industry sectors that are affected by macroeconomic or sector-specific variables. Such reviews allow the Bank to timely establish any necessary allowance loan losses that are sufficient to cover losses for potentially uncollectable loans.

Analysis of age of portfolio loan, over-due loans by financial asset class. Additionally to the overdue portion, the amounts detailed include remaining balance of the past due credits are featured below:

As of December 31, 2018:

	Default
	1 to 29 days		30 to 59 days		60 to 89 days
	MCh$		MCh$		MCh$
Loans and advances to banks		273		―		―
Subtotal past-due loans and advances to banks		273		―		―
Commercial loans		132,707		40,823		27,527
Import-export financing		13,892		2,194		618
Factoring transactions		44,106		7,540		726
Commercial lease transactions		92,057		6,166		3,230
Other loans and receivables		1,462		777		470
Residential mortgage loans		154,751		67,257		24,653
Consumer loans		217,923		102,752		40,782
Subtotal past-due loans to customers		656,898		227,509		98,006
Total		657,171		227,509		98,006

As of December 31, 2019:

	Default
	1 to 29 days		30 to 59 days		60 to 89 days
	MCh$		MCh$		MCh$
Loans and advances to banks		31,249		―		―
Subtotal past-due loans and advances to banks		31,249		―		―
Commercial loans		213,709		54,366		26,698
Import-export financing		9,562		804		1,207
Factoring transactions		31,972		3,022		336
Commercial lease transactions		53,742		8,073		4,722
Other loans and receivables		1,463		693		521
Residential mortgage loans		152,539		73,801		32,907
Consumer loans		221,162		102,344		51,976
Subtotal past-due loans to customers		684,149		243,103		118,367
Total		715,398		243,103		118,367

As of December 31, the aging analysis of loans is as follows:

			*Past due but not impaired^()**
As of	Neither past due or impaired		Up to 30 days		Over 30 days and up to 60 days		Over 60 days and up to 90 days		Over 90 days		Total
December 31,		MCh$		MCh$		MCh$		MCh$		MCh$		MCh$
2018		26,376,542		538,681		145,130		37,371		2,566		27,100,290
2019		28,320,610		599,833		159,756		57,946		595		29,138,740

^(*)

These amounts include installments that are overdue, plus the remaining balance of principal and interest on such loans.

(g)

Assets Received in Lieu of Payment:

The Bank has received assets in lieu of payment totaling Ch$24,871 million and Ch$18,737 as of December 31, 2018 and 2019, respectively, the majority of which are properties. All of these assets are managed for sale.

(h)

Renegotiated Assets:

The impaired loans are considered to be renegotiated when the corresponding financial commitments are restructured and the Bank assesses the probability of recovery as sufficiently high.

The following table details the book value of loans with renegotiated terms per financial asset class:

	2018		2019
Financial assets	MCh$		MCh$
Loans and advances to banks
Domestic banks		―		―
Foreign banks		―		―
Subtotal		―		―
Loans to Customers at amortized cost
Commercial loans		192,646		220,056
Residential mortgage loans		14,463		11,980
Consumer loans		362,562		366,339
Subtotal		569,671		598,375
Total renegotiated financial assets		569,671		598,375

The Bank calculates ECLs either on a group or an individual basis, which are described in more detail in Note 2(i)(vii).

The renegotiated portfolio of Banco de Chile represents 1.99% of the total loans and the redefault rate of these loans for retail segment is 35.80% as of December 31, 2019 (the Bank does not have this information for other segments for internal purposes).

The most common type of modification is to extend the term of the loan. For payment extensions, depending on the characteristics of each credit, the Bank may change the initial conditions in terms of interest rate and initial grace period for the first payment. With respect to forgiveness of principal, the Bank typically does not give this benefit. The Board of Directors might on rare occasions approve debt forgiveness for a portion of principal on certain credit-operations that have been impaired and provisioned previously. Only those borrowers which are considered viable are renegotiated, and that the average term of renegotiated retail credit segment is 57 months, demonstrating the relatively short payment extensions given. If the debtor is not considered to be financially viable, the Bank proceeds to the legal collection of debts.

The table below includes Stage 2 and 3 assets that were modified and, therefore, treated as forborne during the 2019 period, with the related modification loss suffered by the Bank.

2019

MCh$

Amortized costs of financial assets modified during the period

227,718

Net modification loss

81,974

The Bank does not have information related to the balance of loans modified by type of concession because is not required to record this information by the local banking regulator and this information is much used by our peers. However, the Bank continually monitors its deteriorated portfolio as defined in Note 2(i) (vii). Also, for internal purposes the renegotiated loan portfolio is analyzed and reviewed as part of the impaired portfolio. Therefore, for management and regulatory (local and IFRS) reporting purposes the Bank does not frequently use information on loans modified by types of concession.

The table below shows the gross carrying amount of previously modified financial assets for which loss allowances has changed to 12 month Expected Credit Losses (12mECL) measurement during the 2019 period:

	December 31, 2019
	Post modification				Pre-modification
	Gross carrying amount MCh$		Corresponding ECL MCh$		Gross carrying amount MCh$		Corresponding ECL MCh$
Facilities that have cured since modification and are now measured using 12mECLs (Stage 1)		32,105		3,668		32,870		7,577
Facilities that reverted to (Stage 2/3) lifetime ECLs having once cured		4,043		1,132		3,927		613

The Bank determines the appropriate amount of allowance for loan losses as follows:

The commercial loan renegotiations are always evaluated and approved individually by the credit committee with all the background and history of previous approvals, including financial records, delinquencies or other previous renegotiations of the debtor. Since almost the entire commercial portfolio is individually provisioned, it is in this approval step of the renegotiation where the level of provision for each debtor is determined.

Among the variables that are considered by the credit committee to establish the level of provisions is payment capacity and the collateral coverage. The condition of a new default of a renegotiated credit is considered when the credit committee is establishing the new level of provisions, which in general as a consequence of this higher risk, could increase up to 65% of the loan.

On the other hand, for the portfolio evaluated for provisioning purposes as a group, the models contain past behavior variables, incorporating delinquencies and default prior to renegotiation for six months, recognizing the increased risk and generating a higher level of provisions. The provision can only be decreased if the renegotiated client has good payment behavior (an overdue period of less than 30 days), in a period of over seven months.

Moreover, an operation identified as renegotiation never leaves this classification for purposes of monitoring and provisioning.

(i)

Impairment Testing

The main tools used to test loan impairment include an analysis of whether principal or interest payments are more than 90 days past due or if the counterparty is experiencing any known cash flow problems, reductions in credit ratings or default of the original contractual terms.

(j)

Off balance sheet accounts

In order to meet our customers' financial needs, the Bank has extended several irrevocable commitments and contingent obligations. Even though these obligations are not recognized in the balance sheet, they involve credit risk and thus form part of the Bank's general risk exposure.

Credit risk exposure generated by contingent obligations is disclosed in Note No. 27.

(3)

Market Risk:

Market Risk refers to the loss that the Bank could face due to a liquidity shortage to honor the payments or close financial transactions in a timely manner (Liquidity Risk), or due to adverse movements in the values of market variables (Risk Price).

(a)

Liquidity Risk

Liquidity Risk Measurement and Limits

The Bank manages the Liquidity Risk separately for each sub-category: Trading Liquidity Risk and Funding Liquidity Risk.

Trading Liquidity Risk is the inability to close, at current market prices, the financial positions opened mainly from the Trading Book (which is daily valued at market prices and the value differences instantly reflected in the Income Statement). This risk is controlled by establishing limits on the positions amounts of the Trading Book in accordance with what is estimated to be closed in a short time period. Additionally, the Bank incorporates a negative impact on the Income Statement whenever it considers that the size of a certain position in the Trading Book exceeds the reasonable amount, negotiated in the secondary markets, which would allow the exposure to be offset without altering market prices.

Funding Liquidity Risk refers to the Bank's inability to obtain sufficient cash to meet its immediate obligations. This risk is managed by a minimum amount of highly liquid assets called liquidity buffer, and establishing limits and controls of internal metrics, among which the Market Access Report ("MAR") stands out, which estimates the amount of funding that the Bank would need from wholesale financial counterparties, for the next 30 and 90 days in each of the relevant currencies of the balance sheet, to face a cash need as a result of the operation under business as usual conditions, that is, basically, rollover of the total loans portfolio, the output of a volatile part of the demand deposits accounts and of the retailers term deposits, and the expiration of all the wholesalers term deposits.

The use of MAR within year 2019 is illustrated below (LCCY = local currency; FCCY = foreign currency):

	MAR LCCY + FCCY MMM$				MAR FCCY MMUS$
	1 – 30 days		1 – 90 days		1 – 30 days		1 – 90 days
Maximum		3,352		5,498		1,999		3,254
Minimum		1,705		3,993		1		1,407
Average		2,621		4,841		1,052		2,479

The Bank also monitors the amount of assets denominated in local currency that is funded by liabilities denominated in foreign currency, including all tenors and the cash flows generated by derivatives payments to be made in foreign currency in the future. This metric is referred to as Cross Currency Funding. The Bank oversees and limits this amount in order to take precautions against not only Banco de Chile's event but also against a systemic adverse environment generated by a country risk event that might trigger lack of foreign currency funding.

The use of Cross Currency Funding within year 2019 is illustrated below:

	Cross Currency Funding MMUS$
Maximum		3,339
Minimum		1,742
Average		2,640

Additionally, the Bank establishes thresholds that alert behaviors outside the expected ranges at a normal or prudent level of operation, in order to protect other dimensions of liquidity risk such as the maturities concentration of fund providers and the diversification of sources of funds either by type of counterparty or type of product, among others.

Likewise, the evolution over time of the Bank's financial ratios that can detect structural changes in its balance sheet characteristics is monitored, such as those presented in the following table and whose relevant use values during the year 2019 are shown below:

	Liquid Assets/ Net Funding <30 days			Liabilities>1 year/ Assets >1 year			Deposits/ Loans
Maximum		103	%		82	%		62	%
Minimum		82	%		76	%		58	%
Average		92	%		78	%		60	%

Moreover, some market index, prices and monetary decisions taken by the Central Bank of Chile are monitored to detect structural changes in market conditions that can trigger a liquidity shortage or even a financial crisis.

The Bank measures and controls the mismatch of cash flows under regulatory standards with the C46 index report, which represents the net cash flows expected over time as a result of the contractual maturity of almost all assets and liabilities. Additionally, the Commission for the Financial Market (hereinafter, "CMF") authorized Banco de Chile, among others, to report the adjusted C46 index. This allows the Bank to report, in addition to the regular C46 index, outflow behavior assumptions of certain specific elements of the liability, such as demand deposits and time deposits. In addition, the regulator also requires some rollover assumptions for the loan portfolio.

The CMF establish the following limits for the C46:

Foreign Currency balance sheet items: 1-30 days C46 index < 1 x Tier-1 Capital

All Currencies balance sheet items: 1-30 days C46 index < 1 x Tier-1 Capital

All Currencies balance sheet items: 1-90 days C46 index < 2 x Tier-1 Capital

The use of this index in year 2019 is illustrated below:

	Adjusted C46 All CCYs as part of Tier-1 Capital			Adjusted C46 FCCY as part of Tier-1 Capital
		1 – 30 days	1 – 90 days		1 – 30 days
Maximum		0.56	0.79		0.42
Minimum		0.32	0.55		0.15
Average		0.49	0.69		0.28
Regulatory Limit		1.0	2.0		1.0

Additionally, the regulatory entities have introduced other metrics that the Bank uses in its management, such as the Liquidity Coverage Ratio ("LCR") and Net Stable Funding Ratio ("NSFR"), using assumptions similar to those used in the international banking. Only for the first one, a limit implementation calendar has been established and that during the year 2019 was with a minimum level of 60%. The evolution of the LCR and NSFR metrics during the year 2019 are shown below:

	LCR			NSFR
Maximum		1.17			1.02
Minimum		0.88			0.97
Average		0.99			0.99
Regulatory Limit		0.6	(*)		N/A

(*)

This is the current minimum value for the year 2019 and that increases 0.1 annually until reaching 1.0 in the year 2023.

The contractual maturity profile of the financial liabilities of Banco de Chile and its subsidiaries (consolidated basis), as of 2018 and 2019 end-of-year, is illustrated below:

	Up to 1 month		1 to 3 months		3 to 12 months		1 to 3 years		3 to 5 years		Over 5 years		Total
	MCh$		MCh$		MCh$		MCh$		MCh$		MCh$		MCh$
Liabilities as of December 31, 2018
Current accounts and other demand deposits		9,584,488		―		―		―		―		―		9,584,488
Transactions in the course of payment		44,436		―		―		―		―		―		44,436
Obligations under repurchase agreements		292,231		1,440		5,137		―		―		―		298,808
Savings accounts and time deposits		5,344,294		1,981,221		3,152,103		373,398		619		132		10,851,767
Full delivery derivative transactions		351,496		190,643		648,870		582,628		536,506		592,303		2,902,446
Borrowings from financial institutions		97,661		268,795		946,950		183,206		―		―		1,496,612
Other financial obligations		92,896		730		4,857		18,406		366		35		117,290
Debt instruments issued		101,707		267,665		724,724		1,410,766		1,899,529		4,303,542		8,707,933
Total (excluding non-delivery derivative transactions)		15,909,209		2,710,494		5,482,641		2,568,404		2,437,020		4,896,012		34,003,780
Non - delivery derivative transactions		297,613		604,200		1,028,798		712,286		593,431		1,209,282		4,445,610

		Up to 1 month		1 to 3 months		3 to 12 months		1 to 3 years		3 to 5 years		Over 5 years		Total
		MCh$		MCh$		MCh$		MCh$		MCh$		MCh$		MCh$
Liabilities as of December 31, 2019
Current accounts and other demand deposits		11,326,133		—		—		—		—		—		11,326,133
Transactions in the course of payment		98,869		—		—		—		—		—		98,869
Obligations under repurchase agreements		297,011		8,582		—		—		—		—		305,593
Savings accounts and time deposits		6,421,107		1,985,948		2,250,153		284,073		491		421		10,942,193
Full delivery derivative transactions		378,151		351,351		1,132,429		974,371		669,851		797,191		4,303,344
Borrowings from financial institutions		68,843		348,228		934,144		206,811		—		—		1,558,026
Other financial obligations		142,010		292		17,529		727		167		—		160,725
Debt instruments issued		178,310		190,329		576,309		2,091,841		2,081,579		5,017,172		10,135,540
Total (excluding non-delivery derivative transactions)		18,910,434		2,884,730		4,910,564		3,557,823		2,752,088		5,814,784		38,830,423
Non - delivery derivative transactions		501,461		839,534		1,461,804		796,805		738,830		1,650,402		5,988,836

(b)

Price Risk:

Price Risk Measurement and Limits

The measurement and management of Price Risk are carried out through the use of several metrics developed internally by the Bank, both for the Trading Book and for the Accrual Book (the Accrual Book includes all balance sheet items, even those of the Trading book but in such case these are reported at an interest rate adjustment period of one day, thus not generating accrual interest rate risk). In addition, the Bank reports metrics to regulatory entities according to the models defined by them.

The bank has established internal limits for the exposures of the Trading Book. In fact, FX positions (FX delta), Equity positions (Equity delta), interest rate sensitivities generated by the derivatives and debt securities portfolios (DV01 or also referred as to rho) and the FX volatility sensitivity (vega) are measured, reported and against their limits. Limits are established on an aggregate basis but also for some specific tenor points. The use of these limits is daily monitored, controlled and reported by independent control functions to the senior management of the bank. The internal governance framework also establishes that these limits must be approved by the board and reviewed at least annually.

The Bank measures and controls the risk for the Trading Book portfolios using the Value-at-Risk (VaR). The model uses a 99% confidence level and the most recent one-year observed rates, prices and yields data.

The use of VaR within year 2019 is illustrated below:

	Value-at-Risk
	99% one-day confidence level MMUS$
Maximum		872
Minimum		176
Average		562

Additionally, the Bank performs measuring, limiting, controlling and reporting interest rate exposures and risks for the Accrual Book using internally developed methodologies based on the differences in the amounts of assets and liabilities considering the interest rate repricing dates. Exposures are measured according to the Interest Rate Exposure or IRE metric and their corresponding risks using to the Earnings-at-Risk or EaR metric.

The use of EaR within year 2019 is illustrated below:

	12-months Earnings-at-Risk
	99% confidence level 3 months defeasance period MCh$
Maximum		54,372
Minimum		45,023
Average		47,743

The regulatory risk measurement for the Trading portfolio (C41 report) is produced by utilizing guidelines provided by the regulatory entities (Central Bank of Chile and Commission for the Financial Market, hereafter "CBCh" and "CMF" respectively), which are adopted based on standardized BIS methodologies. The referred methodologies estimate the potential loss that the bank may incur considering standardized fluctuations of the value of market factors such as FX rates, interest rates and volatilities that may adversely impact the value of FX spot positions, interest rate exposures, and volatility exposures, respectively. In addition, correlation factors are included to represent non-parallel changes in the yield curve. The CMF does not set an individual limit for this particular risk, but a global one that includes this risk (also called Market Risk Equivalent or MRE) and the Credit Risk Weighted Assets.

The risk measurement for the Banking Book, according to normative guidelines (C40 report), as a result of interest rate fluctuations is carried out through the use of standardized methodologies provided by regulatory entities (BCCh and CMF). The report includes models for reporting interest rate gaps and standardized adverse interest rate fluctuations. In addition to this, the regulatory entity has requested banks to establish internal limits for this regulatory risk measurement. Limits must be established separately for short-term and long-term balance. The short-term risk limit should be expressed as a percentage of the Net Interest Margin or NIM plus the revenue collected from commissions that depend on the level of the interest rate; the long-term risk limit cannot exceed a specific percentage of the amount of effective equity.

In addition to the above, the Market Risk Policy of Banco de Chile enforces to perform daily stress tests for the Trading Book and monthly for the Accrual Book. The output of the stress testing process is monitored against corresponding trigger levels: in the case those triggers are breached, the senior management is notified in order to implement further actions, if necessary. In addition, the results during the month for the trading activities are controlled against defined loss levels and in case such levels are exceeded, senior management is also notified.

The following table illustrates the interest rate cash-flows of the Banking Book, considering the interest rate repricing dates on an individual basis, as of December 31, 2018 and 2019:

	Up to 1 month		Between 1 and 3 months		Between 3 and 12 months		Between 1 and 3 years		Between 3 and 5 years		More than 5 years		Total
	MCh$		MCh$		MCh$		MCh$		MCh$		MCh$		MCh$
Assets as of December 31, 2018
Cash and due from banks		844,173		―		―		―		―		―		844,173
Transactions in the course of collection		151,701		―		―		―		―		―		151,701
Investment under resale agreements		3,161		―		―		―		―		―		3,161
Derivative instruments under hedge-accounting treatment		20		140,631		253,266		176,330		229,092		717,331		1,516,670
Inter-banking loans		1,262,749		79,199		133,689		24,337		―		―		1,499,974
Customer loans		2,305,334		2,311,297		5,784,455		8,402,372		3,923,096		9,721,138		32,447,692
Financial assets available-for-sale		48,469		153,479		408,390		146,136		58,093		230,003		1,044,570
Total assets		4,615,607		2,684,606		6,579,800		8,749,175		4,210,281		10,668,472		37,507,941

Assets as of December 31, 2019
Cash and due from banks		2,310,055		―		―		―		―		―		2,310,055
Transactions in the course of collection		230,605		―		―		―		―		―		230,605
Investment under resale agreements		45,056		―		―		―		―		―		45,056
Derivative instruments under hedge-accounting treatment		774		36,304		28,302		257,909		348,950		1,069,919		1,742,158
Inter-banking loans		876,508		98,673		167,287		―		―		―		1,142,468
Customer loans		3,179,665		2,524,282		6,473,441		6,979,231		3,980,097		10,744,559		33,881,275
Financial Assets at Fair Value through OCI		26,180		241,326		805,844		115,805		25,219		142,005		1,356,379
Total assets		6,668,843		2,900,585		7,474,874		7,352,945		4,354,266		11,956,483		40,707,996

		Up to 1 month		Between 1 and 3 months		Between 3 and 12 months		Between 1 and 3 years		Between 3 and 5 years		More than 5 years		Total
		MCh$		MCh$		MCh$		MCh$		MCh$		MCh$		MCh$
Liabilities as of December 31, 2018
Current accounts and demand deposits		9,622,073		―		―		―		―		―		9,622,073
Transactions in the course of payment		―		―		―		―		―		―		―
Obligations under repurchase agreements		6,963		―		―		―		―		―		6,963
Savings accounts and interest-bearing deposits		5,273,096		1,981,221		3,152,103		373,398		619		71,330		10,851,767
Derivative instruments under hedge-accounting treatment		115		144,525		243,151		187,522		222,201		715,536		1,513,050
Inter-banking borrowings		97,661		268,795		946,950		183,206		―		―		1,496,612
Long-term debt (*)		101,707		267,665		724,724		1,410,766		1,899,529		4,303,542		8,707,933
Other liabilities		92,896		730		4,857		18,406		366		35		117,290
Total liabilities		15,194,511		2,662,936		5,071,785		2,173,298		2,122,715		5,090,443		32,315,688

Liabilities as of December 31, 2019
Current accounts and demand deposits		11,382,462		―		―		―		―		―		11,382,462
Transactions in the course of payment		3,423		―		―		―		―		―		3,423
Obligations under repurchase agreements		9,068		―		―		―		―		―		9,068
Savings accounts and interest-bearing deposits		6,421,107		1,985,948		2,250,153		284,073		491		421		10,942,193
Derivative instruments under hedge-accounting treatment		156		33,740		23,300		251,136		317,886		1,117,967		1,744,185
Inter-banking borrowings		60,331		348,228		934,144		206,811		―		―		1,549,514
Long-term debt (*)		178,310		190,329		576,309		2,091,841		2,081,579		5,017,172		10,135,540
Other liabilities		142,010		292		17,529		727		167		―		160,725
Total liabilities		18,196,867		2,558,537		3,801,435		2,834,588		2,400,123		6,135,560		35,927,110

(*)

Amounts shown here are different from those reported in the liabilities report which is part of the liquidity analysis, due to differences in the treatment of mortgage bonds issued by the Bank in both reports.

Price Risk Sensitivity Analysis

The Bank uses stress tests as the main sensitivity analysis tool for Price Risk. The analysis is implemented for the Trading Book and the Accrual Book separately. The Bank has adopted this tool as it is considered more useful than fluctuations in business as usual scenario, such as VaR or EaR, given that:

(i)

The financial crisis show market factors fluctuations that are materially larger than those used in the VaR with 99% of confidence level or EaR with 99% of confidence level.

(ii)

The financial crisis also show that correlations between these fluctuations are materially different from those used in the VaR computation, since a crisis precisely indicates severe disconnections between the behaviors of market factors fluctuations respect to the patterns observed under normal conditions.

(iii)

Trading liquidity dramatically diminishes during financial distress and especially in emerging markets. Therefore, the overnight VaR number might not be representative of the loss for trading portfolios in such environment since closing exposures period may exceed one business day. This may also happen when calculating EaR, even considering three months as the closing period.

The impacts are determined by mathematical simulations of fluctuations in the values of market factors, and also, estimating the changes of the economic and / or accounting value of the financial positions.

In order to comply with IFRS 7.40, the following exercise was included illustrating an estimation of the impact of extreme but reasonable fluctuations of interest rates, swaps yields, FX rates and exchange volatility, which are used for valuing Trading and Accrual portfolios. Given that the Bank's portfolio includes positions denominated in nominal and real interest rates, these fluctuations must be aligned with extreme but realistic Chilean inflation changes forecasts.

The exercise is implemented in a simple way: Trading portfolios impacts are estimated by multiplying the sensitivities by the fluctuations obtained as the results of mathematical simulations over a two-week time horizon and using the maximum historical volatility of the last fifteen years in each of the market factors; Accrual portfolios impacts are estimated by multiplying cumulative gaps by forward interest rates fluctuations modeled over a three-month time horizon and using the maximum historical volatility of interest fluctuations but limited by maximum fluctuations and / or levels observed during the last fifteen years. It is relevant to note that the methodology might ignore some portion of the interest rates convexity, since it is not captured properly when large fluctuations are modeled. In any case, given the magnitude of the changes, the methodology may be reasonable enough for the purposes and scope of the analysis.

The following table illustrates the fluctuations resulting from the main market factors in the maximum stress test exercise, or more adverse, for the Trading Book.

The directions or signs of these fluctuations are those that correspond to those that generate the most adverse impact at the aggregate level.

Average Fluctuations of Market Factors for Maximum Stress Scenario Trading Book
	CLP Derivatives (bps)		CLP Bonds (bps)		CLF Derivatives (bps)		CLF Bonds (bps)		USD Offshore Libor Derivatives (bps)		Spread USD On/Off Derivatives (bps)
Less than 1 year		103		47		163		108		-62		-9
Greater than 1 year		38		69		92		123		-73		-2

bps = basis points

The worst impact on the Bank's Trading Book as of December 31, 2019, as a result of the simulation process described above, is as follows:

Most Adverse Stress Scenario P&L Impact Trading Book (MCh$)
CLP Interest Rate			(4,968	)
Derivatives	(3,006	)
Debt instruments	(1,962	)
CLF Interest Rate			(8,694	)
Derivatives	(2,600	)
Debt instruments	(6,094	)
Interest rate USD offshore			(1,963	)
Domestic/offshore interest rate spread USD			(50	)
Total Interest rates			(15,675	)
Total FX			(16	)
Total FX Options			224
Total			(15,467	)

The modeled scenario would generate losses in the Trading Book for approximately MCh$15,500. In any case, such fluctuations would not result in material losses compared to Basic Capital (Tier-1) or to the P&L estimate for the next 12-months.

The impact on the Accrual Book for the next 12 months as of December 31, 2019, which does not necessarily mean a net loss / gain but a greater/lower net income from funds generation (resulting net interest rate generation), is illustrated below:

Most Adverse Stress Scenario 12-Month Revenue Accrual Book (MCh$)
Impact by Base Interest Rate shocks	(164,322	)
Impact due to Spreads Shocks	(67	)
Higher / (Lower) Net revenues	(164,389	)

The main negative impact on the Trading Book would occur as a result of a drastic increase in local interest rates. The lowest potential income in the next 12 months in the Accrual Book would occur in a scenario of sharp fall in inflation. In any case, the impacts would be less than the annual budgeted profits of the Bank.

(4)

Capital Requirements and Capital Management:

The main objectives of the Bank's capital management are to ensure compliance with regulatory requirements, maintain a solid credit rating and sound capital ratios. During 2019, the Bank has successfully met the required capital requirements.

As part of its Capital Management Policy, the Bank has established capital adequacy alerts, which are stricter than those required by the regulator, which are monitored on a monthly basis. During 2019, none of the internal alerts defined in the Capital Management Policy were activated.

The Bank manages capital by making adjustments in light of changes in economic conditions and the risk characteristics of its business. For this purpose, the Bank may modify the amount of dividend payments to its shareholders or issue equity instruments. The capital adequacy of the Bank is monitored using, among other measures, the indexes and rules established by the CMF.

Regulatory Capital

According to the Chilean General Banking Law, Banks must maintain a minimum ratio of 8%, net of required provisions, as a result of dividing the Equity by the sum of the Consolidated Weighted Assets by Risk. In addition, banks must maintain a minimum ratio of Basic Capital to Total Consolidated Assets of 3%, net of required provisions. As a result of the merger of Banco de Chile with Citibank Chile in 2008, the CMF established that the institution was obliged to maintain the first reason Less than 10%. In this way, the regulatory body ratified the validity of the minimum of 10% that it had already set in December 2001 by authorizing the merger by absorption of Banco Edwards into Banco de Chile.

Equity is determined from Capital and Reserves or Basic Capital with the following adjustments: (a) the balance of subordinated bonds issued with a maximum equivalent to 50% of the Basic Capital is added and weighted according to their term at maturity; (b) the additional provisions for loans are added, (c) the balance of the assets corresponding to goodwill or overpaid and investments in companies not included in the consolidation is deducted, and (d) the balance of noncontrolling interest is added.

Assets are weighted according to the risk categories, which are assigned a risk percentage that would reflect the amount of capital needed to support each of those assets. There are 5 risk categories (0%, 10%, 20%, 60% and 100%). For example, cash, deposits in other banks and financial instruments issued by the Central Bank of Chile have 0% risk, which means that, according to current standards, no capital is required to back these assets. Properties and equipment have a 100% risk, which means that they must have a minimum capital equivalent to 8% of the amount of these assets and in the case of the Bank of Chile 10%.

All derivative instruments traded outside of stock exchanges are considered in the determination of risk assets with a conversion factor over the notional values, thus obtaining the amount of exposure to credit risk (or "credit equivalent"). The contingent credits out of balance are also considered by a "credit equivalent", for their weighting.

The risk-weighted assets and TIER 1 and TIER 2 Capital, as of December 31, 2019 and 2018 are the following:

	Consolidated assets				Risk-weighted assets
	2018		2019		2018		2019
	MCh$		MCh$		MCh$		MCh$
Balance sheet assets (net of provisions)
Cash and due from banks		880,081		2,392,166		13,084		38,250
Transactions in the course of collection		289,194		331,420		186,536		167,781
Financial Assets held-for-trading		1,745,366		1,872,355		134,412		462,177
Investment under resale agreements		97,289		142,329		97,289		142,329
Derivative instruments (*)		1,310,262		1,555,749		916,798		1,124,730
Loans and advances to banks		1,494,384		1,140,081		313,524		389,417
Loans to Customers at amortized cost		27,341,254		29,384,039		24,102,808		25,668,329
Financial assets at fair value through OCI		1,053,191		1,366,343		356,568		323,160
Financial assets held to maturity		―		―		―		―
Investments in other companies		42,252		48,442		44,561		50,758
Intangible assets		85,471		91,717		52,061		58,307
Property and equipment		215,872		220,262		215,872		220,262
Leased assets		―		150,665		―		150,665
Investment properties		13,938		13,190		―		―
Current tax assets		677		357		68		36
Deferred tax assets		176,823		231,293		27,792		32,095
Other assets		651,691		843,000		673,380		862,968
Subtotal		35,397,745		39,783,408		27,134,753		29,691,264

Off-balance-sheet assets
Contingent loans		4,266,821		4,365,922		2,559,197		2,616,074
Total		39,664,566		44,149,330		29,693,950		32,307,338

(*)

Financial derivative contracts are presented as an equivalent credit risk for the purposes of calculating consolidated assets.

The amounts and ratios determined for the limit of basic capital and effective equity as of December 2018 and 2019 are:

	As of December 31,
	2018		2019
	MCh$		MCh$

Basic capital () (*)		3,304,152		3,528,222
Effective equity		4,129,999		4,569,090
Total consolidated assets (**)		39,989,595		44,408,789
Total consolidated assets weighted by credit risk		29,693,950		32,307,338

(*)

The Basic Capital corresponds to the equity of the owners of the Bank in the Consolidated Statement of Financial Position.

(**)

The total consolidated assets is presented in accordance with Chilean Generally Accepted Accounting Principles as issued by the Chilean Commission for Financial Market ("CMF"). As a result, it is not directly comparable with this Consolidated Statement of Financial Position.

These ratios as of December 31, 2018 and 2019 were:

	Ratio
	As of December 31,
	2018		2019
	%		%

Basic capital / consolidated assets		8.26		7.94
Effective equity / consolidated assets weighted by risk		13.91		14.14

During 2019, the CMF began the regulatory process for the implementation of the Basel III standards in Chile, in accordance with the established in Law No. 21,130, which modernizes the Banking Legislation. At the date of issuance of these Financial Statements, various regulatory proposals have been published in order to receive comments to systematically identify important banks, methodologies for determining assets weighted by credit and operational risk, and calculations of regulatory capital and additional basic capital requirements. The issuance period for all the regulations necessary to implement Basel III will extend to December 1, 2020.