my banking sector neutral - i3investormar 18, 2014  · march 18, 2014 ia or h islamic | see page 15...

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March 18, 2014 Malaysia SECTOR RESEARCH | SEE PAGE 15 FOR IMPORTANTDISCLOSURES AND ANALYST CERTIFICATIONS PP16832/01/2013 (031128) MY Banking Sector NEUTRAL (unchanged) Mudarabah: Deposit or investment? Latest EDs could raise operating costs for Islamic banks. But we expect a muted impact (<1%) to financial groups - Islamic operations account for just 9-16% of group earnings. Impact on BIMB’s pretax profit (estd -4%) could be less than earlier estimated. Maintain HOLD for now. What’s New Bank Negara had earlier issued various Islamic banking exposure drafts and a guideline on investment accounts. The more relevant one pertains to the treatment of Mudarabah accounts as “investments” rather than “deposits”. Discussions are ongoing between Bank Negara and the Islamic banks on possible routes to take and there are still various issues to be ironed out. What’s Our View Some consequences of compliance could include (i) a slight reduction in balance sheet size if restricted investment accounts are taken off-balance sheet, (ii) higher operating costs if bankers switch to Commodity Murabahah, and (iii) opportunity costs if depositors decide to opt for conventional banks instead. The financial impact will vary from bank to bank depending on the strategy they adopt and the frequency of deposit churn. Based on very general parameters, however, we guesstimate that the additional transaction costs would average just about 5% of pretax profit for Islamic banks. Since these banks account for less than 16% of their respective financial groups’ earnings, the impact at the group level is even more marginal at <1%. Our BUYs continue to be AMMB, HL Bank and HL Financial Group. The impact to BIMB Holdings would be larger since Bank Islam accounts for 81% of group pretax profit. Even so, we think the impact would still be manageable at just -4%. Our current forecasts already impute higher operating costs and we maintain our HOLD on BIMB pending further update. Analyst Desmond Ch’ng, ACA (603) 2297 8680 [email protected] Banking sector – Peer valuation summary Stock Rec Shrpx Marketca p TP PER (x) PER (x) P/BV (x) P/BV (x) ROAE (%) ROAE (%) Yield (%) Yield (%) (MYR) (MYR m) (MYR) CY14E CY15E CY14E CY15E CY14E CY15E CY14E CY15E AMMB BUY 6.99 21,069 8.60 10.9 10.0 1.5 1.4 14.3 14.3 3.8 4.1 CIMB HOLD 7.00 57,605 8.00 12.3 11.0 1.6 1.4 14.0 13.7 3.3 3.6 HL Bank BUY 14.20 25,543 16.40 11.8 10.8 1.7 1.5 15.1 14.9 2.7 3.0 Maybank * NR 9.55 84,653 NR 12.0 11.4 1.7 1.5 14.6 14.1 5.8 6.1 Public Bank SELL 19.04 66,680 18.00 15.4 14.2 2.9 2.5 19.8 19.1 2.9 3.2 RHB Cap HOLD 8.00 20,375 8.40 10.1 9.2 1.1 1.0 11.4 11.2 2.3 2.5 Simple avg 275,926 12.1 11.1 1.7 1.6 14.9 14.5 3.4 3.7 MC-wtd 12.7 11.7 1.9 1.7 15.5 15.1 3.9 4.2 BIMB HOLD 4.03 6,019 4.30 11.7 10.4 2.0 1.8 18.6 18.6 3.2 3.6 HLFG BUY 15.22 16,024 17.30 9.9 9.2 1.4 1.2 14.2 13.9 2.5 2.8 Source: Maybank KE * Based on consensus

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Page 1: MY Banking Sector NEUTRAL - I3investorMar 18, 2014  · March 18, 2014 ia OR H Islamic | SEE PAGE 15 FOR IMPORTANTDISCLOSURES AND ANALYST CERTIFICATIONS PP16832/01/2013 (031128) MY

March 18, 2014

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SEE PAGE 15 FOR IMPORTANTDISCLOSURES AND ANALYST CERTIFICATIONS PP16832/01/2013 (031128)

MY Banking Sector NEUTRAL (unchanged)

Mudarabah: Deposit or investment? Latest EDs could raise operating costs for Islamic banks.

But we expect a muted impact (<1%) to financial groups -

Islamic operations account for just 9-16% of group earnings.

Impact on BIMB’s pretax profit (estd -4%) could be less than

earlier estimated. Maintain HOLD for now.

What’s New

Bank Negara had earlier issued various Islamic banking exposure

drafts and a guideline on investment accounts. The more relevant

one pertains to the treatment of Mudarabah accounts as

“investments” rather than “deposits”. Discussions are ongoing

between Bank Negara and the Islamic banks on possible routes to

take and there are still various issues to be ironed out.

What’s Our View

Some consequences of compliance could include (i) a slight

reduction in balance sheet size if restricted investment accounts

are taken off-balance sheet, (ii) higher operating costs if bankers

switch to Commodity Murabahah, and (iii) opportunity costs if

depositors decide to opt for conventional banks instead.

The financial impact will vary from bank to bank depending on the

strategy they adopt and the frequency of deposit churn. Based on

very general parameters, however, we guesstimate that the

additional transaction costs would average just about 5% of pretax

profit for Islamic banks. Since these banks account for less than

16% of their respective financial groups’ earnings, the impact at

the group level is even more marginal at <1%. Our BUYs continue to

be AMMB, HL Bank and HL Financial Group.

The impact to BIMB Holdings would be larger since Bank Islam

accounts for 81% of group pretax profit. Even so, we think the

impact would still be manageable at just -4%. Our current

forecasts already impute higher operating costs and we maintain

our HOLD on BIMB pending further update.

Analyst

Desmond Ch’ng, ACA

(603) 2297 8680

[email protected]

Banking sector – Peer valuation summary

Stock Rec Shrpx Marketcap

TP PER (x) PER (x)

P/BV (x)

P/BV (x)

ROAE (%)

ROAE (%)

Yield (%)

Yield (%)

(MYR) (MYR m) (MYR) CY14E CY15E CY14E CY15E CY14E CY15E CY14E CY15E

AMMB BUY 6.99 21,069 8.60 10.9 10.0 1.5 1.4 14.3 14.3 3.8 4.1

CIMB HOLD 7.00 57,605 8.00 12.3 11.0 1.6 1.4 14.0 13.7 3.3 3.6

HL Bank BUY 14.20 25,543 16.40 11.8 10.8 1.7 1.5 15.1 14.9 2.7 3.0

Maybank * NR 9.55 84,653 NR 12.0 11.4 1.7 1.5 14.6 14.1 5.8 6.1

Public Bank SELL 19.04 66,680 18.00 15.4 14.2 2.9 2.5 19.8 19.1 2.9 3.2

RHB Cap HOLD 8.00 20,375 8.40 10.1 9.2 1.1 1.0 11.4 11.2 2.3 2.5

Simple avg 275,926 12.1 11.1 1.7 1.6 14.9 14.5 3.4 3.7

MC-wtd 12.7 11.7 1.9 1.7 15.5 15.1 3.9 4.2

BIMB HOLD 4.03 6,019 4.30 11.7 10.4 2.0 1.8 18.6 18.6 3.2 3.6

HLFG BUY 15.22 16,024 17.30 9.9 9.2 1.4 1.2 14.2 13.9 2.5 2.8

Source: Maybank KE * Based on consensus

Page 2: MY Banking Sector NEUTRAL - I3investorMar 18, 2014  · March 18, 2014 ia OR H Islamic | SEE PAGE 15 FOR IMPORTANTDISCLOSURES AND ANALYST CERTIFICATIONS PP16832/01/2013 (031128) MY

March 18, 2014 2

Malaysian Banks

Deposit account or investment account?

Common Shariah principles

Before discussing the proposed changes in guidelines pertaining to Islamic

deposits, we would like to provide a brief summary of some of the more

common Shariah principles that are applied to Islamic deposits, which are:

Islamic principles applied to term deposits and CASA

Term deposits Current account/savings accounts (CASA)

Mudarabah (profit sharing) Mudarabah (profit sharing)

Murabahah (cost plus) Wadiah (custody or safekeeping)

Wakalah (agency) Qard (benevolent loan)

Source: Various

A summary of the various principles

Mudarabah Murabahah Wakalah Wadiah Qard

Concept of: Profit sharing Cost plus Agency Safekeeping/Custody Benevolent loan

Definition: A contract between a capital

provider (rabbul mal) and

entrepreneur (mudarib).

The rabbul mal provides

capital to be managed by the

mudarib.

Any profit is shared, with the

profit sharing ratio (PSR)

determined upfront.

Financial losses are borne

solely by the rabbul mal

(depositor) unless the mudarib

(bank) is negligent.

Customer purchases

an asset from the

vendor on a cost-plus

mark-up basis.

The mark-up or profit

margin has to be

agreed upfront.

The asset must exist

and be identifiable in

terms of its location,

quantity and quality.

Assets under

construction are not

eligible.

A contract in which a

party (muwakkil)

authorizes another

party as his agent

(wakil) to perform a

particular task.

As an agent, the bank

receives wakalah

(agency) fees.

The wakalah fee may

be determined based

on a percentage of a

reference rate eg the

BFR/BLR, KLIBOR or

cost of funds.

A contract by which

an owned asset is

placed with another

party on the basis of

trusteeship (amanah)

for safekeeping

purposes. Wadiah Yad

Dhamanah is applied

in Malaysia where the

custodian guarantees

the asset placed in

custody.

Bank may charge a

fee for safekeeping

the asset.

A contract of lending

a fungible asset to a

party who will benefit

from it and who will

return an equivalent

replacement.

Any pre-determined

amount (cash, kind or

benefit) over and

above the principal

qard amount, is

deemed riba.

The bank may give

hibah (a gift) to the

depositor at its own

discretion, provided it

is not pre-conditional.

Types: General Investment Account

(GIA): the most common form

of Islamic term deposits for

the mass market.

Special Investment Account

(SIA): Large deposits usually

from corporate depositors.

The depositor can negotiate

the PSR.

Specific Investment Account

(CIA): Depositor can negotiate

the PSR and decide which

projects it wants to

participate in. Profits placed

in a special pool which the

bank shares solely with that

depositor.

Bai Al-Inah;

underlying asset is

normally the bank’s

own assets eg floor

space, company car

etc.

Commodity

Murabahah:

underlying asset is a

commodity eg palm

oil or metal.

Source: BNM, Various

Page 3: MY Banking Sector NEUTRAL - I3investorMar 18, 2014  · March 18, 2014 ia OR H Islamic | SEE PAGE 15 FOR IMPORTANTDISCLOSURES AND ANALYST CERTIFICATIONS PP16832/01/2013 (031128) MY

March 18, 2014 3

Malaysian Banks

Deposits of an Islamic bank

In Malaysia, just to illustrate how the principles are applied, what we have

below is a breakdown of CIMB Islamic Bank’s customer deposits by product

type for illustration purposes, given that it has a more comprehensive

breakdown of its deposits than most of the other banks.

As we can see from the breakdown below, the principles of Wadiah, Qard

and Mudarabah are applied to savings and demand deposits. For term

deposits, the principles of Mudarabah, Murabahah, Wakalah are the most

common. The common feature between all three accounts is the

application of the Mudarabah principle.

CIMB Islamic Bank’s deposit breakdown by product type (Dec 2013)

Savings deposits MYR’m

Wadiah 1,734.3

Mudarabah 711.6

Demand deposits

Wadiah 3,439.7

Qard 11.9

Mudarabah 4,793.2

Term deposits

Commodity Murabahah 5,652.8

Negotiable Islamic Debt Certificate (NIDC)

- Mudarabah 414.6

- Hybrid (Bai Bithamin Ajil and Bai al-Dayn) 5,519.4

Short-term money market deposit-i

- Wakalah 14,841.9

- Wadiah 502.9

General investment account

- Mudarabah 3,200.2

Specific investment account

- Mudarabah 337.6

- Murabahah 0.4

Others

- Qard 25.4

Total deposits from customers 41,186.1

Source: Company

Page 4: MY Banking Sector NEUTRAL - I3investorMar 18, 2014  · March 18, 2014 ia OR H Islamic | SEE PAGE 15 FOR IMPORTANTDISCLOSURES AND ANALYST CERTIFICATIONS PP16832/01/2013 (031128) MY

March 18, 2014 4

Malaysian Banks

Treatment of Mudarabah Accounts

Differentiating between deposit and investment accounts

Bank Negara’s Islamic Financial Services Act 2013 (IFSA) sets out the

definition of “Islamic deposits” and “Investment accounts” as follows:

Islamic deposit: A sum of money accepted or paid in accordance with

Shariah:

a) On terms under which it will be repaid in full, with or without any

gains, return or any other consideration in money or money’s

worth, either on demand or at a time or in circumstances agreed

by or on behalf of the person making the payment and person

accepting it; or

b) Under an arrangement on terms whereby the proceeds under the

arrangement to be paid to the person paying the sum of money

shall not be less than such sum of money.

Investment account: An account under which money is paid and accepted

for the purposes of investment, including for the provision of finance, in

accordance with Shariah on terms that there is no express or implied

obligation to repay the money in full and:

a) Either only the profits, or both the profits or losses, thereon shall

be shared between the person paying the money and the person

accepting the money; or

b) With or without any return.

Mudarabah accounts cannot be deposits

By virtue of the definitions above, to be deemed a deposit, the capital

amount has to be protected.

Mudarabah accounts, which are based on the concept of profit sharing,

should not be deemed to be deposit accounts, as is the current practice,

because under this principle, there can be no guarantee that the principal

amount will be protected.

In fact, under Mudarabah, the capital provider/depositor stands to bear all

losses unless there is negligence on the part of the bank. As such,

Mudarabah deposits should be treated as investments.

Mudarabah accounts to be taken off-balance sheet?

In adhering strictly to the Mudarabah definition, Mudarabah account

holders cannot be treated as depositors because the capital is not

guaranteed and they stand to absorb all losses. Neither are they

shareholders because they do not have voting rights and are entitled to

profit distribution prior to dividend distributions. As such, Mudarabah

accounts are neither deposits nor equity and have to be reclassified as

investment accounts. But if they are investment accounts, where should

they appear in the balance sheet?

Page 5: MY Banking Sector NEUTRAL - I3investorMar 18, 2014  · March 18, 2014 ia OR H Islamic | SEE PAGE 15 FOR IMPORTANTDISCLOSURES AND ANALYST CERTIFICATIONS PP16832/01/2013 (031128) MY

March 18, 2014 5

Malaysian Banks

One possible treatment is to take these investment accounts off-balance

sheet, a treatment which is illustrated in this excerpt from Al Rajhi

Banking & Investment Corporation’s (Al-Rajhi) latest financial statements

(2013). What we can see from the illustration below is that the Mudarabah

investment accounts are classified as a separate note to the accounts as an

off-balance sheet item.

Al Rajhi’s notes to the accounts (Dec 2013)

Source: Company

Whether an investment account has to be taken off-balance sheet or not

has not been clearly spelt out just yet by Bank Negara. We think it will

eventually depend on whether the account is a “restricted investment

account (RIA)” or “unrestricted investment account (URIA)”. Bank Negara

defines these two accounts as follows:

A restricted investment account (RIA) refers to a type of investment

account where the investment account holder provides a specific

investment mandate to the bank with regards to the purpose, asset

class, economic sector and period of investment.

An unrestricted investment account (URIA) refers to a type of

investment account where the investment account holder allows the

bank to make the ultimate investment decision without specifying any

particular restriction or condition.

RIAs, which are more akin to Mudarabah Specific Investment Accounts, may

have to be taken off-balance sheet, in our view. These currently account

for just a small portion of total deposits.

As for URIAs eg Mudarabah General and Special Investment Accounts, the

option may be to have these classified as a balance sheet line item that is

separate to customer deposits, but at least they could potentially be left

on-balance sheet.

Page 6: MY Banking Sector NEUTRAL - I3investorMar 18, 2014  · March 18, 2014 ia OR H Islamic | SEE PAGE 15 FOR IMPORTANTDISCLOSURES AND ANALYST CERTIFICATIONS PP16832/01/2013 (031128) MY

March 18, 2014 6

Malaysian Banks

The implications and options to a bank

In light of the above, banks essentially have two main options: (i) to either

keep the Mudarabah status of their accounts, or (ii) to consider alternative

Islamic principle treatments to these accounts.

Option 1: To keep the Mudarabah status of the accounts

If banks opt to maintain the Mudarabah status their accounts, they will

have to reclassify these accounts as investment accounts rather than

deposits. There are several implications to this treatment:

1. Asset size may see a slight reduction. As discussed above, it has not

been decided just yet as to what extent investment accounts have to

be taken off-balance sheet – this in turn would determine the extent to

which a bank’s asset size would contract. The impact is likely to be

quite mild if only RIA are taken off-balance sheet.

2. These deposits may no longer be guaranteed by PIDM. All depositors

(whether business or individuals) are insured by Perbadanan Insurans

Deposit Malaysia (PIDM) to the tune of MYR250,000 per depositor per

member financial institution. Mudarabah deposits, once classified as

investment accounts, may no longer be guaranteed by PIDM. Whether

banks have to compensate for this higher risk via higher profit rates,

remains to be seen.

3. Increased administrative procedures, possible impact to Basel III

ratios? As an investment account product, banks will have to prepare

product disclosure sheets and provide regular updates on the

performance of the underlying investments. Moreover, the

management and maintenance of investment accounts has to be

separated from other funds and assets managed by the bank.

It is not clear at this stage as to whether Basel III ratios such as the

liquidity coverage ratio or net stable funding ratio would be impacted

by having removed these deposits from the balance sheet.

4. Third party guarantees? We understand that another possible way of

keeping the Mudarabah accounts on-balance sheet is to have these

accounts carry third party guarantees, but this would entail additional

costs. This could possibly be feasible for term deposits, but would be

costly for CASA.

Page 7: MY Banking Sector NEUTRAL - I3investorMar 18, 2014  · March 18, 2014 ia OR H Islamic | SEE PAGE 15 FOR IMPORTANTDISCLOSURES AND ANALYST CERTIFICATIONS PP16832/01/2013 (031128) MY

March 18, 2014 7

Malaysian Banks

Option 2a: to apply an alternative Islamic principle - Wadiah

In a bid to keep the deposits on balance sheet, banks could opt to apply an

alternative Islamic principle to these deposits. At this point in time, the

two most obvious choices would be either (i) Wadiah or (ii) Murabahah, or

more specifically, Commodity Murabahah.

Applying the Wadiah principle

The most obvious alternative would be to convert the Mudarabah deposits

to Wadiah deposits. However, in Dec 2013, Bank Negara issued an Exposure

Draft (ED) on Wadiah, which places various conditions on such accounts,

thus complicating the conversion from Mudarabah to Wadiah.

A quick review of two principles:

Wadiah employs the concept of trusteeship whereby the depositor

places his funds with the bank for safekeeping. In Malaysia, the

Shariah principle employed is Wadiah Yad Dhamanah, which extends

the safekeeping concept to include custodianship. The bank, as a

custodian, guarantees the asset placed in custody and must act to

safeguard the asset.

Qard is a benevolent loan and refers to a contract of lending a

fungible asset to a party who will benefit from it and who will

subsequently return an equivalent replacement.

Wadiah to be treated as similar to Qard

According to Bank Negara’s ED on Wadiah:

“Under Wadiah Yad Dhamanah involving money, the asset placed in

custody is in monetary form and the custodian is allowed to utilize the

money subject to the permission of the asset owner. Money is regarded as

a form of fungible asset. Therefore, it is construed as a Qard contract and

shall adhere to the rules related to Qard”

What this implies is that Wadiah Yad Dhamanah is similar in nature to Qard

if it involves money and therefore should adhere to rules relating to Qard.

The ED goes on to define the requirements of Qard, of which the key ones

are as follows:

“Any-predetermined additional in the form of cash, kind or benefit

over and above the principal Qard amount, either imposed by the

lender or promised by the borrower, is deemed riba.”

This implies that there should be no promise of a profit or return on

Wadiah deposits, which may otherwise be construed as riba (interest).

Technically, this implies that banks cannot offer a predetermined

profit rate on Wadiah deposits.

“Incentives promised to a lender to enter into a Qard contract with a

borrower may result in implicit benefit to the lender, which is

tantamount to riba.”

We take this to mean that banks will not be allowed to do marketing

or promotional campaigns to promote their Wadiah products.

Page 8: MY Banking Sector NEUTRAL - I3investorMar 18, 2014  · March 18, 2014 ia OR H Islamic | SEE PAGE 15 FOR IMPORTANTDISCLOSURES AND ANALYST CERTIFICATIONS PP16832/01/2013 (031128) MY

March 18, 2014 8

Malaysian Banks

“The borrower may give hibah, either in monetary or non-monetary

form, to the lender at its own discretion provided that it is not pre-

conditional at the time of entering into the Qard contract and that

such practice does not become a customary practice (urf)….the

practice of giving hibah is considered as customary if the hibah is given

to the majority of borrower’s lenders.”

By definition, a “hibah” is essentially a gift at the discretion of the

bank to the depositor who has placed his funds with the bank for

safekeeping. If this gift is given to the majority, or all, of the

depositors, it could be construed as riba.

Several issues

The adherence to the refined definition of hibah may limit the banks’

ability to offer a return to depositors and they cannot advertise the profit

rates on their Wadiah accounts. Depositors, as such, cannot be assured of a

recurrent profit on their deposits.

Banks will be restricted in their ability to run marketing activities or offer

promotional products to attract new Wadiah depositors. This could place

the Islamic banks at a disadvantage to conventional banks in terms of

deposit gathering activity.

We think the implications of the above are that it is:

Possible to still convert Mudarabah current accounts to Wadiah

current accounts. We think it would still be possible to convert

Mudarabah current accounts, especially those used for transactional

purposes such as cash management, to Wadiah accounts, since there is

typically no expectation of a return on such deposits.

Tougher for savings accounts and term deposit accounts. Converting

savings accounts and term deposit accounts from Mudarabah to Wadiah

could be difficult, given that there is typically the expectation of some

return on such accounts.

Option 2b: To apply an alternative Islamic principle –

Commodity Murabahah

The alternative to Wadiah would be the Commodity Murabahah principle,

whereby the customer purchases an asset from the vendor on a cost-plus

mark-up basis, and the mark-up or profit margin has to be agreed upfront.

In this case, the asset has to be a commodity.

Most viable alternative at this stage. Having spoken to several industry

players, the conversion of Mudarabah accounts to Commodity Murabahah is

the most viable at this stage.

Where Commodity Murabahah is concerned, it requires the bank to

physically purchase an asset or commodity for on-sell to the depositor on a

cost-plus basis. In Malaysia, the banks use the funds received from

depositors to buy commodities either from the London Metal Exchange

(LME) or from Bursa Malaysia.

Page 9: MY Banking Sector NEUTRAL - I3investorMar 18, 2014  · March 18, 2014 ia OR H Islamic | SEE PAGE 15 FOR IMPORTANTDISCLOSURES AND ANALYST CERTIFICATIONS PP16832/01/2013 (031128) MY

March 18, 2014 9

Malaysian Banks

In the case of Bursa Malaysia, it was in August 2009 that it launched its

multi-commodity, multi-currency Bursa Suq Al-Sila (which means

“commodities market” in Arabic), an international commodity platform to

facilitate commodity-based Islamic financing and investment transactions.

This commodity facilitates trading on several commodities, the more

predominant ones being crude palm oil and plastic resin (PE).

Commodities on Bursa Suq Al-Sila can purchased/sold throughout the day

in cycles of 2-3 hours each, during which time the price is fixed, to cap

fluctuations in commodity prices. We understand that LME is a cheaper

alternative as trading can also be done on-line.

The downside to Commodity Murabahah is that it is a slightly more

expensive alternative to Mudarabah because a transaction fee of MYR15 is

levied on every MYR1m transaction on both the buy and sell side. This as

such, increases the operating costs to a bank that decides to pursue this

route. This transaction fee will be treated as an operating expense.

Moving away from Bai’ ‘Inah financing as well

Turning our attention away from deposits to financing, Bank Negara has

also issued an ED on Bai’ ‘Inah, which is one of several Islamic principles

applied to financing activity such as credit card or personal financing.

According to the Islamic Banking & Finance Institute Malaysia:

Bai’ ‘Inah is a financing facility involving two separate contracts. In the

first contract a financier sells an asset to a customer on deferred

payment terms. Immediately after, the financier repurchases the same

asset from the customer on cash terms at a price lower than that of

the deferred payment sale.

It can also be applied vice versa where a financier buys an asset from a

customer on cash terms. Immediately after, the financier sells back

the same asset to the customer on deferred payment terms at a price

higher than that of the cash sale

The issue of inter-conditionality or the lack thereof

The complication arises in that the ED prescribes that “neither contracting

party in the Bai’ ‘Inah arrangement must provide either a written or verbal

promise to repurchase or resell the asset.”

In short, there can no longer be an inter-conditionality that if a bank sells

the asset to the customer, that the customer MUST sell the asset back to

the bank. This creates an issue over asset ownership for banks.

Likely to move to Commodity Murabahah as well

The options here would be to either (i) adhere to the new guideline with

additional safeguards in place or (ii) shift to Commodity Murabahah as well

for such transactions. From our discussion with the banks, the latter seems

to be the more preferred choice at this stage.

Page 10: MY Banking Sector NEUTRAL - I3investorMar 18, 2014  · March 18, 2014 ia OR H Islamic | SEE PAGE 15 FOR IMPORTANTDISCLOSURES AND ANALYST CERTIFICATIONS PP16832/01/2013 (031128) MY

March 18, 2014 10

Malaysian Banks

What are banks likely to do?

From our enquiries, most banks are still in discussion with Bank Negara and

have been fairly reluctant to divulge the route that they plan to take just

yet. It is our view that:

For Bai’ ‘Inah financing, the deadline for compliance was end-Dec 2013

and banks would either have (i) complied with the stricter

requirements of the new regulation or (ii) stopped providing Bai’ ‘Inah

financing already. We expect the banks to start offering Commodity

Murabahah financing as an alternative instead.

For Mudarabah term deposits, it is most likely that banks will covert

these to Commodity Murabahah deposits.

For Wadiah current accounts, we think that maintaining status quo

would be the cheaper option. Arguably, hibah, if any, is only offered to

corporate clients and not so much to retail clients so it is on a

selective basis already.

For Mudarabah current accounts, conversion to Wadiah could be a

possibility. The alternative would be to leave these as Mudarabah

investment accounts. There will, however, be more administrative

work involved.

For Mudarabah and Wadiah savings deposits, we think it is likely that

these may be converted to Commodity Murabahah deposits as well.

The alternative would be to reclassify these as investment accounts.

What are the overall implications to a bank?

The implementation of the new guidelines will have several implications to

Islamic banks:

Balance sheets could reduce marginally in size

If Mudarabah/wakalah accounts are taken off-balance sheet, banks’ asset

size would contract. Mudarabah/wakalah accounts make up about 43% of

total assets of the Islamic banks. HOWEVER, as we have discussed on page

5, the impact is likely very marginal if only restricted investment accounts

(RIA) are taken off-balance sheet, for these make up a much smaller

proportion of deposits (negligible at this stage).

Mudarabah deposits as % of total deposits and total assets

Affin Alliance AM Bk Islam CIMB HL Maybank Public RHB

Savings 38 460 33 - 4,793 44 9,222 95 538

Demand 137 130 6 2,295 712 1,168 742 64 156

General investment 4,575 581 15,378 2,012 3,538 2,423 15,055 3,206 897

Special investment 574 573 54 18,436 415 268 143 - 12,734

Mudarabah deposits 5,323 1,745 15,471 22,744 9,458 3,903 25,162 3,364 14,325

Wakalah deposits - 2,204 - - 14,842 - - 16,612 4

Mudarabah/wakalah deps 5,323 3,949 15,471 22,744 24,300 3,903 25,162 19,976 14,329

As % of total deposits 57% 62% 68% 62% 59% 23% 30% 70% 68%

As % of total assets 43% 54% 47% 53% 41% 18% 20% 58% 49%

Source: Company

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Additional operating costs

Additional operating costs could take several forms:

(i) If Mudarabah accounts are converted to investment accounts,

there is the cost of issuing investment prospectuses and preparing

regular updates on the performance of the assets.

(ii) If Commodity Murabahah is the preferred route, there is the

transaction cost of MYR15 that has to be incurred for every MYR1m

transaction.

(iii) IT systems may have to be upgraded to ensure the proper tagging

of assets to liabilities, and additional personnel may have to be

employed to cope with the increase in transactional activity.

Potential opportunity costs?

Given that much is still preliminary, it is unclear as to how retail customers

in particular would react to the conversion of their Mudarabah deposit

accounts to investment accounts, particularly with the knowledge that the

latter may not carry a PIDM guarantee.

As for Wadiah accounts, the restrictions on promotional activity and rate

advertising may place Islamic banks at a disadvantage to conventional

banks especially in terms of their CASA gathering efforts.

That Malaysia runs a parallel banking system does mean that Islamic banks

would have to compete even more aggressively with the conventional

banks for funds.

An attempt at quantifying the cost

In attempting to quantify the cost of compliance to a bank, we have to

stress upfront that this is purely a theoretical exercise with standard

parameters applied across all banks.

In reality, the actual overall impact will very much depend on factors such

as (i) the compliance route a bank decides to take, and (ii) the frequency

of churn on the individual deposit accounts.

Our primary assumptions Our primary assumptions include the following:

Current accounts remain status quo, either as Wadiah or Mudarabah;

Mudarabah and non-Mudarabah savings accounts are converted to

Commodity Mudarabah and are churned every two days

Mudarabah and wakalah term deposits are converted to Commodity

Murabahah and are churned every month

Bai’ ’ínah accounts are replaced with Commodity Murabahah accounts

Commodity Murabahah accounts incur a total fee of MYR30 per MYR1m

transaction for both purchase and sale.

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Estimating the transaction costs pertaining to Commodity Murabahah conversion

Total deposits (2013) Affin Alliance AM Bk Islam CIMB HL Maybank Public RHB

Non-Mudarabah Demand 2,718 1,529 3,439 9,790 3,452 2,204 8,179 2,959 2,090

Savings 228 172 1,806 2,379 1,734 937 8,878 4,823 780

Wakalah - 2,204 - - 14,842 - - 16,612 4

Others 1,022 739 1,930 2,014 11,701 10,154 41,157 643 3,835

3,967 4,644 7,175 14,183 31,728 13,295 58,214 25,037 6,709

Mudarabah

Demand 38 460 33 - 4,793 44 9,222 95 538

Savings 137 130 6 2,295 712 1,168 742 64 156

General investment 4,575 581 15,378 2,012 3,538 2,423 15,055 3,206 897

Special investment 574 573 54 18,436 415 268 143 - 12,734

5,323 1,745 15,471 22,744 9,458 3,903 25,162 3,364 14,325

FV changes (16)

Total deposits 9,291 6,389 22,645 36,927 41,186 17,182 83,376 28,401 21,034

Bai'Ínah accounts - 646 - 1,282 12,398 - - 2,500 3,573

Churn assumptions (days)

Non-Mudarabah savings 2 2 2 2 2 2 2 2 2

Non-Mudarabah wakalah 30 30 30 30 30 30 30 30 30

Mudarabah savings 2 2 2 2 2 2 2 2 2

Mudarabah GIA 30 30 30 30 30 30 30 30 30

Mudarabah SIA 30 30 30 30 30 30 30 30 30

Bai' 'inah 365 365 365 365 365 365 365 365 365

Transaction costs

Non-Mudarabah savings 1.2 0.9 9.9 13.0 9.5 5.1 48.6 26.4 4.3

Non-Mudarabah wakalah - 0.8 - - 5.4 - - 6.1 0.0

Mudarabah savings 0.7 0.7 0.0 12.6 3.9 6.4 4.1 0.3 0.9

Mudarabah GIA 1.7 0.2 5.6 0.7 1.3 0.9 5.5 1.2 0.3

Mudarabah SIA 0.2 0.2 0.0 6.7 0.2 0.1 0.1 - 4.6

Bai' 'inah - 0.0 - 0.0 0.4 - - 0.1 0.1

Total transaction costs 3.9 2.9 15.6 33.1 20.6 12.5 58.2 34.1 10.2

Islamic bank pretax (FY13) 87.3 55.4 233.7 677.3 860.5 139.2 1,474.1 473.2 329.0

Transaction costs as a % 4.4% 5.2% 6.7% 4.9% 2.4% 9.0% 3.9% 7.2% 3.1%

Group pretax profit (FY13) 863.9 541.6 1,866.7 833.1 5,541.0# 1,362.7 8,869.6 5,310.0 2,470.8

Transaction costs as a % 0.4% 0.5% 0.8% 4.0% 0.4% 0.9% 0.7% 0.6% 0.4%

Islamic pretax as % of group 10.1% 10.2% 12.5% 81.3% 15.5% 10.2% 16.6% 8.9% 13.3%

Source: Company, Maybank KE # Adjusted for sale of CIMB Aviva and MSS

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Key observations – minimal financial impact

As it stands, we do think that the churn rates that we have applied are

fairly stringent and that the actual impact could be less than we have

computed. Nevertheless, some observations would be that:

The estimated transaction costs average about 5% of pretax profit for

the Islamic banks, ranging from 2% for CIMB Islamic Bank to potentially

9% for Hong Leong Islamic Bank.

The impact to the group earnings of these financial institutions,

however, is very negligible, overshadowed in large part by the sizeable

contributions of their respective conventional banks. Public Islamic

Bank, for instance, accounted for just 9% of Public Bank group’s pretax

profit in FY13, while Maybank Islamic Bank accounted for 17% of

Maybank group’s pretax profit. The impact of higher transaction costs

to group earnings is thus very negligible at less than 1% for all banking

groups.

The exception, unsurprisingly, is Bank Islam, whose pretax profit in

FY13 accounted for 81% of BIMB Holdings’ earnings, given that it is one

of only two standalone Islamic banks in the country (the other being

Bank Muamalat). Syarikat Takaful accounts for the remaining portion

of BIMB Holdings’ earnings. The impact of higher transaction costs to

BIMB’s group earnings is thus estimated to be a larger, but still very

manageable 4%, of group pretax profit.

Timeline for implementation

The deadline for compliance with the new framework for Mudarabah

accounts depends on whether banks intend to (i) comply with the new

Investment Account framework, or (ii) opt for alternative products eg

Commodity Murabahah.

If the intention is to comply with the new Investment Account framework,

banks will be allowed to continue booking Mudarabah deposits until June

2015 and will only need to reclassify these as investments after June 2015.

If banks are looking to apply alternative Islamic principle treatment, eg

Commodity Murabahah, Mudarabah deposits must be reclassified as

investments after June 2014. The alternative deposit product must be

made available to the public by April 1, 2014 for term deposits or July 1,

2014 for CASA.

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Research Offices

REGIONAL

WONG Chew Hann, CA

Regional Head of Institutional Research (603) 2297 8686 [email protected]

ONG Seng Yeow

Regional Head of Retail Research

(65) 6432 1453 [email protected]

Alexander GARTHOFF

Institutional Product Manager

(852) 2268 0638 [email protected]

ECONOMICS

Suhaimi ILIAS

Chief Economist

Singapore | Malaysia

(603) 2297 8682 [email protected]

Luz LORENZO

Philippines

(63) 2 849 8836 [email protected]

Tim LEELAHAPHAN

Thailand (662) 658 1420 [email protected]

JUNIMAN

Chief Economist, BII

Indonesia

(62) 21 29228888 ext 29682 [email protected]

Josua PARDEDE

Economist / Industry Analyst, BII

Indonesia

(62) 21 29228888 ext 29695 [email protected]

MALAYSIA

WONG Chew Hann, CA Head of Research (603) 2297 8686 [email protected] • Strategy • Construction & Infrastructure

Desmond CH’NG, ACA (603) 2297 8680 [email protected] • Banking & Finance

LIAW Thong Jung (603) 2297 8688 [email protected] • Oil & Gas - Regional • Shipping

ONG Chee Ting, CA (603) 2297 8678 [email protected] • Plantations - Regional

Mohshin AZIZ (603) 2297 8692 [email protected] • Aviation - Regional • Petrochem

YIN Shao Yang, CPA (603) 2297 8916 [email protected] • Gaming – Regional • Media

TAN Chi Wei, CFA (603) 2297 8690 [email protected] • Power • Telcos

WONG Wei Sum, CFA (603) 2297 8679 [email protected] • Property & REITs

LEE Yen Ling (603) 2297 8691 [email protected] • Building Materials • Glove Producers

CHAI Li Shin (603) 2297 8684 [email protected] • Plantation • Construction & Infrastructure

KANG Chun Ee (603) 2297 8675 [email protected] • Consumer

Ivan YAP (603) 2297 8612 [email protected] • Automotive

LEE Cheng Hooi Regional Chartist (603) 2297 8694 [email protected]

Tee Sze Chiah Head of Retail Research (603) 2297 6858 [email protected]

HONG KONG / CHINA

Howard WONG Head of Research (852) 2268 0648 [email protected] • Oil & Gas - Regional

Alexander LATZER (852) 2268 0647 [email protected] • Metals & Mining - Regional

Jacqueline KO, CFA (852) 2268 0633 [email protected] • Consumer

Karen KWAN (852) 2268 0640 [email protected] • Property & REITs

Osbert TANG, CFA (852) 21 5096 8370 [email protected] • Transport & Industrials

Philip TSE, CFA FRM (852) 2268 0643 [email protected] • Property & REITs

Ricky WK NG, CFA (852) 2268 0689 [email protected] • Utilities & Renewable Energy

Simon QIAN, CFA (852) 2268 0634 [email protected] • Telecom & Internet

Steven ST CHAN (852) 2268 0645 [email protected] • Banking & Financials

Warren LAU (852) 2268 0644 [email protected] • Technology – Regional

William YANG (852) 2268 0675 [email protected] • Technology – Regional

INDIA

Jigar SHAH Head of Research

(91) 22 6623 2601

[email protected]

• Oil & Gas • Automobile • Cement

Anubhav GUPTA

(91) 22 6623 2605

[email protected]

• Metal & Mining • Capital Goods • Property

Urmil SHAH

(91) 22 6623 2606 [email protected]

• Technology • Media

SINGAPORE

NG Wee Siang Head of Research (65) 6432 1467 [email protected] • Banking & Finance

Gregory YAP (65) 6432 1450 [email protected] • SMID Caps – Regional • Technology & Manufacturing • Telcos

Wilson LIEW (65) 6432 1454 [email protected] • Property Developers

ONG Kian Lin (65) 6432 1470 [email protected] • S-REITs

James KOH (65) 6432 1431 [email protected] • Consumer - Regional

YEAK Chee Keong, CFA (65) 6432 1460 [email protected] • Offshore & Marine

Derrick HENG (65) 6432 1446 [email protected] • Transport (Land, Shipping & Aviation)

WEI Bin (65) 6432 1455 [email protected] • Commodity • Logistics • S-chips

John CHEONG (65) 6432 1461 [email protected] • Small & Mid Caps • Healthcare

INDONESIA

Wilianto IE Head of Research (62) 21 2557 1125 [email protected] • Strategy

Rahmi MARINA (62) 21 2557 1128 [email protected] • Banking & Finance

Aurellia SETIABUDI (62) 21 2953 0785 [email protected] • Property

Anthony YUNUS (62) 21 2557 1136 [email protected] • Consumer • Poultry

Isnaputra ISKANDAR (62) 21 2557 1129 [email protected] • Metals & Mining • Cement

Pandu ANUGRAH (62) 21 2557 1137

[email protected] • Infrastructure • Construction • Transport

Janni ASMAN (62) 21 2953 0784 [email protected] • Cigarette • Healthcare • Retail

PHILIPPINES

Luz LORENZO Head of Research (63) 2 849 8836 [email protected] • Strategy

Laura DY-LIACCO (63) 2 849 8840 [email protected] • Utilities • Conglomerates • Telcos

Lovell SARREAL (63) 2 849 8841 [email protected] • Consumer • Media • Cement

Rommel RODRIGO (63) 2 849 8839 [email protected] • Conglomerates • Property • Gaming • Ports/ Logistics

Katherine TAN (63) 2 849 8843 [email protected] • Banks • Construction

Ramon ADVIENTO (63) 2 849 8845 [email protected] • Mining

THAILAND

Maria LAPIZ Head of Institutional Research Dir (66) 2257 0250 | (66) 2658 6300 ext 1399 [email protected] • Consumer / Materials

Jesada TECHAHUSDIN, CFA (66) 2658 6300 ext 1394 [email protected] • Financial Services

Kittisorn PRUITIPAT, CFA, FRM (66) 2658 6300 ext 1395 [email protected] • Real Estate

Sittichai DUANGRATTANACHAYA (66) 2658 6300 ext 1393 [email protected] • Services Sector

Sukit UDOMSIRIKUL Head of Retail Research (66) 2658 6300 ext 5090 [email protected]

Mayuree CHOWVIKRAN (66) 2658 6300 ext 1440 [email protected] • Strategy

Padon VANNARAT (66) 2658 6300 ext 1450 [email protected] • Strategy

Surachai PRAMUALCHAROENKIT (66) 2658 6300 ext 1470 [email protected] • Auto • Conmat • Contractor • Steel

Suttatip PEERASUB (66) 2658 6300 ext 1430 [email protected] • Media • Commerce

Sutthichai KUMWORACHAI (66) 2658 6300 ext 1400 [email protected] • Energy • Petrochem

Termporn TANTIVIVAT (66) 2658 6300 ext 1520 [email protected] • Property

Woraphon WIROONSRI (66) 2658 6300 ext 1560 [email protected] • Banking & Finance

Jaroonpan WATTANAWONG (66) 2658 6300 ext 1404 [email protected] • Transportation • Small cap

Chatchai JINDARAT (66) 2658 6300 ext 1401 [email protected] • Electronics

VIETNAM

LE Hong Lien, ACCA Head of Institutional Research (84) 844 55 58 88 x 8181 [email protected] • Strategy • Consumer • Diversified • Utilities

THAI Quang Trung, CFA, Deputy Manager, Institutional Research (84) 844 55 58 88 x 8180 [email protected] • Real Estate • Construction • Materials

TRUONG Thanh Hang (84) 844 55 58 88 x 8085 [email protected] • Consumer

Le Nguyen Nhat Chuyen (84) 844 55 58 88 x 8082 [email protected] • Oil & Gas NGUYEN Thi Ngan Tuyen, Head of Retail Research (84) 8 44 555 888 x 8081 [email protected] • Food & Beverage • Oil&Gas • Banking

NGUYEN Trung Hoa, Dy Head of Retail Research (84) 8 44 555 888 x 8088 [email protected] • Macro • Steel • Real estate

TRINH Thi Ngoc Diep (84) 4 44 555 888 x 8208 [email protected] • Technology • Utilities • Construction

TRUONG Quang Binh (84) 4 44 555 888 x 8087 [email protected] • Rubber plantation • Tyres and Tubes • Oil&Gas

PHAM Nhat Bich (84) 8 44 555 888 x 8083 [email protected] • Consumer • Manufacturing • Fishery

NGUYEN Thi Sony Tra Mi (84) 8 44 555 888 x 8084 [email protected] • Port operation • Pharmaceutical

• Food & Beverage

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APPENDIX I: TERMS FOR PROVISION OF REPORT, DISCLAIMERS AND DISCLOSURES

DISCLAIMERS

This research report is prepared for general circulation and for information purposes only and under no circumstances should it be considered or intended as an offer to sell or a solicitation of an offer to buy the securities referred to herein. Investors should note that values of such securities, if any, may fluctuate and that each security’s price or value may rise or fall. Opinions or recommendations contained herein are in form of technical ratings and fundamental ratings. Technical ratings may differ from fundamental ratings as technical valuations apply different methodologies and are purely based on price and volume-related information extracted from the relevant jurisdiction’s stock exchange in the equity analysis. Accordingly, investors’ returns may be less than the original sum invested. Past performance is not necessarily a guide to future performance. This report is not intended to provide personal investment advice and does not take into account the specific investment objectives, the financial situation and the particular needs of persons who may receive or read this report. Investors should therefore seek financial, legal and other advice regarding the appropriateness of investing in any securities or the investment strategies discussed or recommended in this report.

The information contained herein has been obtained from sources believed to be reliable but such sources have not been independently verified by Maybank Investment Bank Berhad, its subsidiary and affiliates (collectively, “MKE”) and consequently no representation is made as to the accuracy or completeness of this report by MKE and it should not be relied upon as such. Accordingly, MKE and its officers, directors, associates, connected parties and/or employees (collectively, “Representatives”) shall not be liable for any direct, indirect or consequential losses or damages that may arise from the use or reliance of this report. Any information, opinions or recommendations contained herein are subject to change at any time, without prior notice.

This report may contain forward looking statements which are often but not always identified by the use of words such as “anticipate”, “believe”, “estimate”, “intend”, “plan”, “expect”, “forecast”, “predict” and “project” and statements that an event or result “may”, “will”, “can”, “should”, “could” or “might” occur or be achieved and other similar expressions. Such forward looking statements are based on assumptions made and information currently available to us and are subject to certain risks and uncertainties that could cause the actual results to differ materially from those expressed in any forward looking statements. Readers are cautioned not to place undue relevance on these forward-looking statements. MKE expressly disclaims any obligation to update or revise any such forward looking statements to reflect new information, events or circumstances after the date of this publication or to reflect the occurrence of unanticipated events.

MKE and its officers, directors and employees, including persons involved in the preparation or issuance of this report, may, to the extent permitted by law, from time to time participate or invest in financing transactions with the issuer(s) of the securities mentioned in this report, perform services for or solicit business from such issuers, and/or have a position or holding, or other material interest, or effect transactions, in such securities or options thereon, or other investments related thereto. In addition, it may make markets in the securities mentioned in the material presented in this report. MKE may, to the extent permitted by law, act upon or use the information presented herein, or the research or analysis on which they are based, before the material is published. One or more directors, officers and/or employees of MKE may be a director of the issuers of the securities mentioned in this report.

This report is prepared for the use of MKE’s clients and may not be reproduced, altered in any way, transmitted to, copied or distributed to any other party in whole or in part in any form or manner without the prior express written consent of MKE and MKE and its Representatives accepts no liability whatsoever for the actions of third parties in this respect.

This report is not directed to or intended for distribution to or use by any person or entity who is a citizen or resident of or located in any locality, state, country or other jurisdiction where such distribution, publication, availability or use would be contrary to law or regulation. This report is for distribution only under such circumstances as may be permitted by applicable law. The securities described herein may not be eligible for sale in all jurisdictions or to certain categories of investors. Without prejudice to the foregoing, the reader is to note that additional disclaimers, warnings or qualifications may apply based on geographical location of the person or entity receiving this report.

Malaysia

Opinions or recommendations contained herein are in the form of technical ratings and fundamental ratings. Technical ratings may differ from fundamental ratings as technical valuations apply different methodologies and are purely based on price and volume-related information extracted from Bursa Malaysia Securities Berhad in the equity analysis.

Singapore

This report has been produced as of the date hereof and the information herein may be subject to change. Maybank Kim Eng Research Pte. Ltd. (“Maybank KERPL”) in Singapore has no obligation to update such information for any recipient. For distribution in Singapore, recipients of this report are to contact Maybank KERPL in Singapore in respect of any matters arising from, or in connection with, this report. If the recipient of this report is not an accredited investor, expert investor or institutional investor (as defined under Section 4A of the Singapore Securities and Futures Act), Maybank KERPL shall be legally liable for the contents of this report, with such liability being limited to the extent (if any) as permitted by law.

Thailand

The disclosure of the survey result of the Thai Institute of Directors Association (“IOD”) regarding corporate governance is made pursuant to the policy of the Office of the Securities and Exchange Commission. The survey of the IOD is based on the information of a company listed on the Stock Exchange of Thailand and the market for Alternative Investment disclosed to the public and able to be accessed by a general public investor. The result, therefore, is from the perspective of a third party. It is not an evaluation of operation and is not based on inside information. The survey result is as of the date appearing in the Corporate Governance Report of Thai Listed Companies. As a result, the survey may be changed after that date. Maybank Kim Eng Securities (Thailand) Public Company Limited (“MBKET”) does not confirm nor certify the accuracy of such survey result.

Except as specifically permitted, no part of this presentation may be reproduced or distributed in any manner without the prior written permission of MBKET. MBKET accepts no liability whatsoever for the actions of third parties in this respect.

US

This research report prepared by MKE is distributed in the United States (“US”) to Major US Institutional Investors (as defined in Rule 15a-6 under the Securities Exchange Act of 1934, as amended) only by Maybank Kim Eng Securities USA Inc (“Maybank KESUSA”), a broker-dealer registered in the US (registered under Section 15 of the Securities Exchange Act of 1934, as amended). All responsibility for the distribution of this report by Maybank KESUSA in the US shall be borne by Maybank KESUSA. All resulting transactions by a US person or entity should be effected through a registered broker-dealer in the US. This report is not directed at you if MKE is prohibited or restricted by any legislation or regulation in any jurisdiction from making it available to you. You should satisfy yourself before reading it that Maybank KESUSA is permitted to provide research material concerning investments to you under relevant legislation and regulations.

UK

This document is being distributed by Maybank Kim Eng Securities (London) Ltd (“Maybank KESL”) which is authorized and regulated, by the Financial Services Authority and is for Informational Purposes only. This document is not intended for distribution to anyone defined as a Retail Client under the Financial Services and Markets Act 2000 within the UK. Any inclusion of a third party link is for the recipients convenience only, and that the firm does not take any responsibility for its comments or accuracy, and that access to such links is at the individuals own risk. Nothing in this report should be considered as constituting legal, accounting or tax advice, and that for accurate guidance recipients should consult with their own independent tax advisers.

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Disclosure of Interest

Malaysia: MKE and its Representatives may from time to time have positions or be materially interested in the securities referred to herein and may further act as market maker or may have assumed an underwriting commitment or deal with such securities and may also perform or seek to perform investment banking services, advisory and other services for or relating to those companies.

Singapore: As of March 18, 2014, Maybank KERPL and the covering analyst do not have any interest in any companies recommended in this research report.

Thailand: MBKET may have a business relationship with or may possibly be an issuer of derivative warrants on the securities /companies mentioned in the research report. Therefore, Investors should exercise their own judgment before making any investment decisions. MBKET, its associates, directors, connected parties and/or employees may from time to time have interests and/or underwriting commitments in the securities mentioned in this report.

Hong Kong: KESHK may have financial interests in relation to an issuer or a new listing applicant referred to as defined by the requirements under Paragraph 16.5(a) of the Hong Kong Code of Conduct for Persons Licensed by or Registered with the Securities and Futures Commission.

As of March 18, 2014, KESHK and the authoring analyst do not have any interest in any companies recommended in this research report.

MKE may have, within the last three years, served as manager or co-manager of a public offering of securities for, or currently may make a primary market in issues of, any or all of the entities mentioned in this report or may be providing, or have provided within the previous 12 months, significant advice or investment services in relation to the investment concerned or a related investment and may receive compensation for the services provided from the companies covered in this report.

OTHERS

Analyst Certification of Independence

The views expressed in this research report accurately reflect the analyst’s personal views about any and all of the subject securities or issuers; and no part of the research analyst’s compensation was, is or will be, directly or indirectly, related to the specific recommendations or views expressed in the report.

Reminder

Structured securities are complex instruments, typically involve a high degree of risk and are intended for sale only to sophisticated investors who are capable of understanding and assuming the risks involved. The market value of any structured security may be affected by changes in economic, financial and political factors (including, but not limited to, spot and forward interest and exchange rates), time to maturity, market conditions and volatility and the credit quality of any issuer or reference issuer. Any investor interested in purchasing a structured product should conduct its own analysis of the product and consult with its own professional advisers as to the risks involved in making such a purchase.

No part of this material may be copied, photocopied or duplicated in any form by any means or redistributed without the prior consent of MKE.

Definition of Ratings

Maybank Kim Eng Research uses the following rating system

BUY Return is expected to be above 10% in the next 12 months (excluding dividends)

HOLD Return is expected to be between - 10% to +10% in the next 12 months (excluding dividends)

SELL Return is expected to be below -10% in the next 12 months (excluding dividends)

Applicability of Ratings

The respective analyst maintains a coverage universe of stocks, the list of which may be adjusted according to needs. Investment ratings are only applicable to the stocks which form part of the coverage universe. Reports on companies which are not part of the coverage do not carry investment ratings as we do not actively follow developments in these companies.

DISCLOSURES

Legal Entities Disclosures

Malaysia: This report is issued and distributed in Malaysia by Maybank Investment Bank Berhad (15938-H) which is a Participating Organization of Bursa Malaysia Berhad and a holder of Capital Markets and Services License issued by the Securities Commission in Malaysia. Singapore: This material is issued and distributed in Singapore by Maybank KERPL (Co. Reg No 197201256N) which is regulated by the Monetary Authority of Singapore. Indonesia: PT Kim Eng Securities (“PTKES”) (Reg. No. KEP-251/PM/1992) is a member of the Indonesia Stock Exchange and is regulated by the BAPEPAM LK. Thailand: MBKET (Reg. No.0107545000314) is a member of the Stock Exchange of Thailand and is regulated by the Ministry of Finance and the Securities and Exchange Commission. Philippines:Maybank ATRKES (Reg. No.01-2004-00019) is a member of the Philippines Stock Exchange and is regulated by the Securities and Exchange Commission. Vietnam: Maybank Kim Eng Securities JSC (License Number: 71/UBCK-GP) is licensed under the State Securities Commission of Vietnam.Hong Kong: KESHK (Central Entity No AAD284) is regulated by the Securities and Futures Commission. India: Kim Eng Securities India Private Limited (“KESI”) is a participant of the National Stock Exchange of India Limited (Reg No: INF/INB 231452435) and the Bombay Stock Exchange (Reg. No. INF/INB 011452431) and is regulated by Securities and Exchange Board of India. KESI is also registered with SEBI as Category 1 Merchant Banker (Reg. No. INM 000011708) US: Maybank KESUSA is a member of/ and is authorized and regulated by the FINRA – Broker ID 27861. UK: Maybank KESL (Reg No 2377538) is authorized and regulated by the Financial Services Authority.

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Malaysian Banks

Malaysia Maybank Investment Bank Berhad

(A Participating Organisation of

Bursa Malaysia Securities Berhad)

33rd Floor, MenaraMaybank,

100 JalanTun Perak,

50050 Kuala Lumpur

Tel: (603) 2059 1888;

Fax: (603) 2078 4194

Singapore Maybank Kim Eng Securities Pte Ltd

Maybank Kim Eng Research Pte Ltd

9 Temasek Boulevard

#39-00 Suntec Tower 2

Singapore 038989

Tel: (65) 6336 9090

Fax: (65) 6339 6003

London Maybank Kim Eng Securities

(London) Ltd

6/F, 20 St. Dunstan’s Hill

London EC3R 8HY, UK

Tel: (44) 20 7621 9298

Dealers’ Tel: (44) 20 7626 2828

Fax: (44) 20 7283 6674

New York Maybank Kim Eng Securities USA

Inc

777 Third Avenue, 21st Floor

New York, NY 10017, U.S.A.

Tel: (212) 688 8886

Fax: (212) 688 3500

Stockbroking Business:

Level 8, Tower C, DataranMaybank,

No.1, JalanMaarof

59000 Kuala Lumpur

Tel: (603) 2297 8888

Fax: (603) 2282 5136

Hong Kong Kim Eng Securities (HK) Ltd

Level 30,

Three Pacific Place,

1 Queen’s Road East,

Hong Kong

Tel: (852) 2268 0800

Fax: (852) 2877 0104

Indonesia PT Maybank Kim Eng Securities

Plaza Bapindo

Citibank Tower 17th Floor

Jl Jend. Sudirman Kav. 54-55

Jakarta 12190, Indonesia

Tel: (62) 21 2557 1188

Fax: (62) 21 2557 1189

India Kim Eng Securities India Pvt Ltd

2nd Floor, The International 16,

Maharishi Karve Road,

Churchgate Station,

Mumbai City - 400 020, India

Tel: (91).22.6623.2600

Fax: (91).22.6623.2604

Philippines Maybank ATR Kim Eng Securities Inc.

17/F, Tower One & Exchange Plaza

Ayala Triangle, Ayala Avenue

Makati City, Philippines 1200

Tel: (63) 2 849 8888

Fax: (63) 2 848 5738

Thailand Maybank Kim Eng Securities

(Thailand) Public Company Limited

999/9 The Offices at Central World,

20th - 21st Floor,

Rama 1 Road Pathumwan,

Bangkok 10330, Thailand

Tel: (66) 2 658 6817 (sales)

Tel: (66) 2 658 6801 (research)

Vietnam In association with

Maybank Kim Eng Securities JSC

1st Floor, 255 Tran Hung Dao St.

District 1

Ho Chi Minh City, Vietnam

Tel : (84) 844 555 888

Fax : (84) 838 38 66 39

Saudi Arabia In association with

Anfaal Capital

Villa 47, Tujjar Jeddah

Prince Mohammed bin Abdulaziz

Street P.O. Box 126575

Jeddah 21352

Tel: (966) 2 6068686

Fax: (966) 26068787

South Asia Sales Trading Kevin FOY

[email protected]

Tel: (65) 6336-5157

US Toll Free: 1-866-406-7447

North Asia Sales Trading Alex TSUN

[email protected]

Tel: (852) 2268 0228

US Toll Free: 1 877 837 7635

www.maybank-ke.com | www.maybank-keresearch.com