The Dodd-Frank Wall Street Reform Act - An UpdateImplications for energy companies, utilities and other non-financial entities

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Swaps Reforms Benefit End-users “Each component of swaps market reform has been done with an eye toward ensuring they work for end-users, America’s job providers. It’s the end-users in the non-financial side of our economy that provide 94 percent of private sector jobs.

Congress provided in the Dodd-Frank Act that end-users should be able to choose whether or not to clear swaps that hedge or mitigate commercial risks. Last summer, the Commission finalized rules to implement this exception, including for small financial institutions.

As the Chamber calls for in your Financial Regulatory Reform 2013 Report Card, the Commission’s proposed rule on margin provides that end-users will not have to post margin for uncleared swaps. We also continue to advocate with global regulators for an approach consistent with that of the CFTC.

Non-financial companies, other than those genuinely making markets in swaps, will not have to register as swap dealers.”

Source: www.cftc.gov, SPEECHES & TESTIMONY Remarks of Chairman Gary Gensler, before the U.S. Chamber of Commerce Seventh Annual Capital Markets Summit April 10, 2013

Recent News

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We believe that Dodd-Frank is essentially requiring companies to redefine their enterprise risk management (ERM) capabilities. Key principles for energy market participants to consider for compliance include:

• Risk management infrastructure – from governance to technology – to support requirements.

• A robust set of policies and procedures which can help comply with Dodd-Frank.

• Implementing a standardized and consistent approach across the enterprise to meet the Dodd-Frank requirements.

• Implementating a fit for purpose compliance system to enable the transparency and reporting required to comply with Dodd-Frank.

Energy companies may want to consider:

1) Assessing the potential impact of Dodd-Frank on their objectives and their organization, especially with regard to swaps clearing, data and reporting, position limits and business conduct rules;

2) Assessing their governance, people, processes and technology to identify any potential gaps between their current capabilities and the requirements and opportunities presented by Dodd-Frank; and

3) Finally, creating a roadmap to capture opportunities and close any gaps to compliance.

Nearly three years after the passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”) Pub. L. 111-203, H.R. 4173, market participants have made initial assessments as to the practical impacts, costs and constraints the new regulations impose on Over-the-Counter (OTC) derivative activity. While the Commodity Futures Trading Commission (CFTC) recently issued additional “no-action” guidance providing some relief to compliance dates, it is critical that companies finalize implementation strategically to identify opportunities which strengthen their risk management practices.

The Goals of Dodd-Frank

The new or altered agencies are granted explicit power over certain financial markets. They are required to report annually or biannually to Congress on current progress and future goals.

• Improving accountability and transparency to the financial system

• Ending “Too Big to Fail”

• Protecting the American taxpayer by ending bailouts

• Creating new oversight agencies and combining others

• Increasing transparency

• Increasing oversight of institutions deemed to be systemically risky

Source: Accenture

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To help evaluate the attitudes and preparedness of companies affected by Dodd-Frank, Accenture recently concluded a quantitative global online survey of 132 company executives in Europe and North America regarding the Dodd-Frank regulation.1 Respondents included over 100 financial services executives and over 30 resources industry executives.

While there are significant differences from industry to industry in how companies view these challenges, more than half (57 percent) of energy respondents strongly agree that Dodd-Frank presents competitive challenges for them in the global market as opposed to just 32 percent of capital markets respondents. At the same time, 90% of non-financial companies surveyed agreed that the Dodd-Frank Act would help to reduce their overall risks.

Other interesting study findings include:

• In the energy industry, 57 percent of respondents named OTC derivatives regulation as very challenging, much more than any other industry.

• An even larger percentage of energy industry respondents (64 percent) saw potential difficulties with enhanced capital standards.

• Resources companies (including energy, mining, utilities and chemicals companies) generally saw Dodd-Frank as more challenging than did their counterparts in financial services. This is particularly evident in some specific areas such as credit risk retention for securitized debt, which 41 percent of resources companies viewed as very challenging.

• The energy industry respondents anticipated spending the most on Dodd-Frank with 50 percent of respondents expecting to spend $51 to $100 million and 13 percent expect to spend from $101 to $200 million.

• Despite the significant costs imposed by Dodd-Frank, energy industry respondents were most optimistic about how the Act would increase their company’s profitability. Forty-four percent indicated that Dodd-Frank would increase their profitability by a margin of 11 to 20 percent and 6 percent of the respondents anticipated a profit increase of more than 20 percent.

• Of the Industries responding to the survey, companies in the energy industry are most likely to be planning or have ongoing changes regarding cost reductions, change management programs and a focus on core competencies. Among those surveyed, 44 percent of energy companies plan to focus more on core competencies in the next two years, and 69 percent plan to implement cost reductions during that same period.

Energy companies may want to consider an effective firm-wide approach to an enterprise risk management program. This can help efficiently fulfill regulatory obligations while simultaneously strengthening enterprise risk management core capabilities and processes, especially with regard to credit and liquidity risk management.

Market participants whose swaps must now be cleared through a central counterparty clearing house will likely incur increased costs to support OTC activities in terms of the cash required to post margin and collateral for cleared swaps. Other organizations may need to invest in corporate governance and leading enterprise risk management practices in order to comply with the new regulations. All participants may benefit from accessing existing technology for compliance with data and reporting requirements.2

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Challenges for Implementing Dodd-Frank

The Dodd-Frank Act poses competitive challenges for my company in the global market

The Dodd-Frank Act will help my company reduce its overall risks

Strongly disagreeDisagreeAgreeStrongly agree

Survey question: Indicate the degree to which you agree or disagree with the following statements:

14%

29%57%

Energy industry

19%

37%

44% Energy/Utilities/Chemicals/Mining

industry

6%13%

62%

19%

3%

7%

73%

17%

14%

Energy/Utilities/Chemicals/Mining

industry

Energy industry

Source: Accenture Global online survey, March 20121

What is Dodd-Frank?

Far reaching impacts across non-financial industries

“The Wall Street reform bill will—for the first time—bring comprehensive regulation to the swaps marketplace.”(Comments on the enactment of Wall Street Reform and Consumer Protection Act, CFTC Chairman Gary Gensler, July 21, 2010).

• Energy Companies• Supermajors• Independent Oil & Gas• Refining & Marketing

• Electric and Natural Gas Utilities

• Chemical

• Mining and Mineral

• Agribusiness

• Airlines

• Consumer Products

Impact Dimensions

Technology

Strategy

People ProcessRisk Management

Capabilities

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Close regulatory gaps The 2008 financial crisis has been blamed on irresponsible risk-taking by financial institutions investing in credit default swaps traded in the largely opaque and unregulated OTC market. The Act provides the Securities and Exchange Commission (SEC) and the CFTC with new authority to regulate OTC commodity derivatives.

Central clearing and exchange tradingThe legislation sets up a mechanism for clearing OTC transactions through designated swaps exchange facilities and clearing organizations. The argument for clearing through central counterparties (CCPs) is that this pooling of credit risks will reduce systemic risk in the U.S. financial system. This applies to standardized swaps that have been approved by the CFTC for clearing through these types of organization.

Market transparencyThe law requires data collection and publication through clearing houses or swap data repositories (SDRs) to improve market transparency. Another key objective for the CFTC is to provide greater price transparency and, therefore, liquidity for all market participants. It also provides regulators with important tools, such as the establishment of position limits, for monitoring and responding to risks.

Financial safeguardsIn the absence of clearing, safeguards are added to the system by requiring that OTC commodity market participants have adequate resources to meet financial obligations due under the swap. Indeed, additional duties to counterparties are required of swap dealers and major swap participants such as verifying a counterparty’s eligibility to transact in the swap market, providing a daily mid-market value of uncleared swaps to a counterparty and obtaining documentation from an end-user exercising its right for an exception from clearing.

Higher standard of conductA standard code of conduct is established for all registered swap dealers and major swap participants. The Act provides for an enhanced internal risk management governance structure and focus within the organization from the front/ middle/ back office all the way to the Board of Directors.

The Goals of Derivative Reform2

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Preparing for Dodd-Frank – 2013 Timeline

We believe that all swap market participants will be affected by some aspect of Dodd-Frank regulation. Whether the company is large or small, a significant player who makes markets, manages a large swaps position, trades speculatively and enters into OTC transactions on behalf of others, or a small user who enters into a few transactions a year to hedge risk, the Act’s requirements apply. The CFTC has granted some relief to compliance deadlines – in part due to industry requesting delays and in part due to the technical complexities surrounding the data capture and management. Organizations on schedule to comply with the Act are likely now completing initial phases of implementation.

What does all of this mean? Simply put, business conduct standards, whether internal or external, will likely be more rigorous for major swap participants and swap dealers. Similar to the implementation of Sarbanes-Oxley6, companies may wish to implement processes, organizational changes, new roles and responsibilities, and new technologies in order to comply.

Source: www.cftc.gov - Division of Market Oversight / CFTC Letter No. 13-10 / No-Action / April 9, 2013

Date Counterparty Type Type of Swap Obligation

4/10/13 All Non-SD/MSP Counterparties

CICI/LEI Obtained

4/10/13 All Non-SD/MSP Counterparties

All swaps entered into prior to 4/10/13 Swap Data Recordkeeping – CFTC Req. Part 46

4/10/13 All Non-SD/MSP Counterparties

All swaps entered into after 4/10/13 Swap Data Recordkeeping – CFTC Req. Parts 43/45

7/1/13 Non-financial entities Interest rate and credit swaps Swap Data Reporting Obligations – CFTC Req. Parts 43/45

8/1/13 Non-financial entities Interest rate and credit swaps for the period 4/10/2013 - 7/1/2013

Swap Data Reporting Obligations – CFTC Req. Part 45

8/19/13 Non-financial entities Equity, Fx, Other Commodity Swaps Swap Data Reporting Obligations – CFTC Req. Parts 43/45

9/19/13 Non-financial entities Equity, Fx, Other Commodity Swaps for the period 4/10/2013 - 8/19/2013

Swap Data Reporting Obligations – CFTC Req. Part 45

10/31/13 Non-financial entities Historical swaps data for all swap asset classes

Historical Swaps Data – CFTC Part 46

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One of the critical aspects of derivative reform is the requirement that all swaps, which are clearable, be cleared through a designated clearing organization or swaps exchange facility, unless those swaps can be exempted for bona fide hedging purposes.7 Clearable swaps are those that have been approved by the CFTC for clearing and are standardized. This rule applies to all market participants, regardless of size and market penetration.

The clearing rule has significant impacts on market participants. First, because swaps will be cleared, margin and collateral must be posted to the clearing house to protect it in the event of default. This is much the same as posting margin on futures transactions today. But it is in contrast to OTC collateral provisions now in existence, which generally only require posting of collateral in the event of a credit downgrade or another adverse credit event on the part of one of the participants. And, even in the event that collateral is required, collateral other than cash is often offered and accepted. Taken in the extreme, the funding implications of this rule could change entire business models.

A second impact of the derivative reform is the increased organizational support that will likely be needed to track and pay/receive margin amounts which were previously un-margined. This means additional resources with specialized knowledge and, likely, additional software to support the margining activity.

A third impact of clearing is reserved for those entities seeking the end-user exception.8 Under derivative reform, an entity may claim an exception from

clearing if the swaps are used to hedge or mitigate commercial risk. The definition of hedging includes any swaps position that meets the bona fide hedge rules under the Commodity Exchange Act, meets hedge qualifications of the Financial Accounting Standards Board Standards Codification Topic 815, Derivatives and Hedging (formerly known as Statement No. 133), or is appropriate to reducing the risks from the ordinary course of business.

A high level of expertise will be required to prove that hedges are, in fact, hedges. Companies may wish to implement processes to ensure that, at the time a swap is executed, information regarding the methods used to mitigate counterparty credit risk in the absence of clearing is provided to the swap data repository along with the other information about the swap itself. Pertinent facts to be included would be whether an affiliate or financial entity is involved, the identity of the end-user, and a statement that the swap is being used for hedging purposes.

The rule requiring that swaps be cleared will mean all market participants will likely incur costs as they implement changes to people, processes, and technology. Additionally, market participants whose swaps may now be cleared will find that significant margin and collateral postings will be required to support their derivatives activity.

At the time of this writing, despite active dialogue between market participants and the CFTC, rules for capital and margin requirements for uncleared swaps have not yet been published. In the absence of certainty, markets will move to efficient

solutions. Not without controversy, a few market participants are now offering future-like swap products cleared on exchanges (“futurization of swaps”) and non-financial market applicants are re-evaluating risk management options available. We believe that the move to manage OTC derivatives credit exposure by either method requires greater flexibility, communication and focus between corporate finance and trading middle and back office functions on accurate daily cash forecasting and monthly cash management strategies. Indeed, Accenture believes that high performing organizations exposed to energy commodity volatility successfully use enterprise risk management programs to effectively integrate working capital management, capital cost structure and strategic capital investments, thereby achieving better financial outcomes compared to their peers.

Swaps Clearing

DerivativeReform Goals

Achieved through:

Capital& Margin

Requirements

Recordkeeping& Reporting

Requirements

End-UserDesignation

Real TimePublic

Reporting

BusinessConduct

Standards

PositionLimits

The following are a few of the Act’s rulemaking areas regulating the swaps marketplace in the legislation.7

8

CME Energy Trades

90%

50%

40%

30%

20%

100%

0%

10%

80%

70%

60%

Energy Futures Other

Prior to October 15th After October 15th

"This roundtable also provides an opportunity to hear from market participants on the recent actions of the two largest exchanges. Last fall, Intercontinental Exchange converted power and natural gas-related swaps into futures contracts. In addition, the CME Group’s ClearPort products, which were cleared as futures, including those that were executed bilaterally as swaps, are now being offered for trading on Globex or on the trading floor. CME also adopted new block trading rules for its ClearPort energy contracts, as well as began trading a futures contract where the underlying product is an interest rate swaps contract.

It’s important to note that whether one calls a product a standardized swap or a future, both markets now benefit from central clearing.”

Source: Chairman Gary Gensler’s Opening Remarks at CFTC Roundtable January 31, 2013. Access at: http://www.cftc.gov/PressRoom/SpeechesTestimony/opagensler-130

Source: Chairman Gary Gensler’s Opening Remarks at CFTC Roundtable January 31, 2013 Access at: http://www.cftc.gov/PressRoom/SpeechesTestimony/opagensler-130

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DataThe legislation includes a group of rules governing data collection and transaction reporting.9 These rules apply to all market participants, with special provisions for participants classified as swap dealers and major swap participants.

First, the rules establish a new registered entity, the swap data repository, to collect and maintain data and information related to swap transactions. The data collected by this entity will be made available directly and electronically to regulators. Second, the CFTC has prescribed standards for swap data recordkeeping and reporting, applicable to both registered entities and counterparties involved with swaps.9

A swap dealer and major swap participant will be required to “make such reports as are required by the Commission by rule or regulation regarding the transactions, positions and financial condition of the registered swap dealer or major swap participant;”3 keep all books and records open to inspection and examination by any representative of the Commission; and maintain a “complete audit trail for conducting comprehensive and accurate trade reconstructions” including daily trading records of the swaps identifiable by counterparty and all related records (including records of related cash and forward transactions) and recorded communications, including electronic mail, instant messages, and recordings of telephone calls. “The rule does not establish an affirmative new requirement to create recordings of all telephone conversations if the required recordkeeping is met through other means.”10

For all swap participants, the final rule calls for the reporting of swap data from each of two important stages of the existence of a swap: the creation of the swap, and the continuation of the swap over its existence until its termination or expiration.9

Registered entities and swap counterparties must report required swap creation data electronically to an SDR. Required swap creation data means all primary economic terms data and all confirmation data for a swap. Swap counterparties must also report required swap continuation data electronically to SDRs over the swap’s existence until final termination or expiration.9

ReportingReal-time reporting of certain swap transaction pricing and volume data is required by all participants.11 The rules require that the “reporting” parties report swap data to a registered swap data repository (SDR). Such a report must be made as soon as technologically practicable.

Meeting the demands of the data and reporting rules will likely require investment in technology, data warehouses and processes, not only to capture the data required, but also to report the data in the time and fashion required by the CFTC.

Position LimitsThe limits have implications in two areas. First, a swap participant may find that activity conducted today may be limited in the future. This could lead to changes in business strategies due to market limitations. It could also mean potential organizational changes to allow for segregating positions among

legal entities to facilitate business objectives. Second, a participant will be required to create internal oversight and compliance functions to monitor compliance with CFTC limits.12 In some organizations, risk management in conjunction with the back office will validate bona fide hedge positions which are deducted from any position limit imposed as well as respond to calls for information from the CFTC.

Spot month position limits on 28 exchange traded futures contracts and price linked swaps and other derivatives were scheduled to become enforceable on October 12, 2012; however, on September 28, 2012, the U.S. District Court for the District of Columbia vacated the Positions Limit Rule and remanded it back to the CFTC.13

The Commodity Futures Trading Commission (CFTC) will move forward with an appeal of a federal district court’s decision vacating the position limits rule. The Commission approved the appeal on a 3-2 vote.

“As part of the Dodd-Frank Act, Congress directed the Commission to limit promptly speculative positions in physical commodity futures and options contracts and economically equivalent swaps. The rule addresses Congress’ concern that no single trader be permitted to obtain too large a share of the market, and that derivatives markets remain fair and competitive. I believe it is critically important that these position limits be established as Congress required. I support the Commission’s continued efforts to put in place position limits on speculative positions by appealing the September ruling,” said CFTC Chairman Gary Gensler.14

Data and Reporting

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Business Conduct RulesA swap dealer and major swap participant will be subject to conduct standards in dealing with counterparties as well as in internal business practices. New duties and obligations include: verification of a counterparty’s eligibility to enter into a swap transaction; disclosure of the risks, characteristics, incentives and conflicts of interest related to a particular swap; provision of a daily mid-market value of uncleared swaps to their counterparties; and notification to the counterparty of its clearing rights.15

New verifications and additional disclosures will likely require changes to the deal-making process. Creating and negotiating new master trading agreements will likely require additional legal, contract administration and commercial efforts. ISDA (International Swaps and Derivatives Association) has responded to this requirement by issuing DF Protocol 2.0.5

The DF Protocol 2.0 is intended to facilitate industry compliance with three final rulemakings by allowing market participants to (i) supplement the terms of existing written agreements under which parties may execute Swaps or (ii) enter into an agreement to apply selected Dodd-Frank compliance provisions to their trading relationship in respect of Swaps. The DF Protocol 2.0 adds notices, representations and covenants responsive to Dodd-Frank requirements that must be satisfied at or prior to the time that Swap transactions are offered and executed. Also, the DF Protocol 2.0 includes additional bilateral delivery requirements, including a Protocol Questionnaire, to allow counterparties to make certain elections related to their Swap trading relationship under Dodd-Frank.5

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Have you identified all Dodd-Frank swap activity as defined by the CFTC?

Will any part of the organization register as a swap dealer or major swap participant?

• If so, how well would the existing enterprise risk management governance structure comply with the additional external and internal business conduct standards for swap dealers and major swap participants?

Will your organization claim the End-User Exception from clearing? If so, which entities?

• Can those entities validate hedge positions at trade execution and excluded from the aggregate portfolio by derivative product?

What portion of the OTC derivative portfolio is currently traded and cleared on exchanges?

• How much uncleared OTC activity will move to clearing and be subject to margin requirements?

Have you identified what additional processes or technology will be required to meet reporting, record-keeping requirements for uncleared swap activity?

• Can futures, options, swap and swaptions data be aggregated for position limit reporting requirement?

How well do existing credit risk management practices measure daily counterparty exposure for the purposes of determining capital and margin requirements, where applicable?

Organizations which institute enhanced or leading industry risk management practices will likely have less difficulty transitioning to the new regime. Furthermore, energy and utility companies may wish to consider improving their

overall data capture and management. Enhanced credit support for derivative transactions will likely require greater integration between corporate finance and the business use of derivatives, as daily margining puts greater constraints on cash management. To manage external reporting requirements going forward, companies may wish to give thought to applying a higher level of focus and rigor to the quality and maintenance of data across the full suite of enterprise risk management activities from front to back office, across business units and upward to the corporate finance and compliance functions.

How companies may want to respondEnergy and utility companies engaged in the OTC commodity market may ease the burden of compliance to the Dodd-Frank Wall Street Reform Act by considering assessing, sooner rather than later, current business objectives and organizational model against the new regulatory requirements. A key objective is to determine where new regulations impose constraints on current operating models and where new regulation may provide opportunities for better risk-adjusted strategic decisions.

For each of the areas affecting all OTC commodity market participants – clearing, data and reporting, position limits and new business conduct rules – companies may consider starting the process by asking the following questions to understand what gaps currently exist in order to plan for a logical transition to a desired end state.

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1. Accenture Risk Management, “Coming to Terms with Dodd-Frank – Balancing Strategic Considerations and Tactical Implications.” January 2013. Access at: http://www.accenture.com/us-en/Pages/insight-dodd-frank-act-strategic-tactical-implications.aspx

2. Accenture Risk Management, “The Dodd-Frank Wall Street Reform Act – Implications for energy companies, utilities and other over-the-counter market participants.” April 2011. Access at: http://www.accenture.com/us-en/Pages/insight-dodd-frank-wall-street-reform-act-summary.aspx

3. www.cftc.gov

4. http://www.institutionalinvestor.com/Article/3183658/Changes-to-Swaps-Market-Have-Corporate-Users-Fuming-about-Costs-and-Risks.html

5. ISDA March 2013 DF Protocol. Access at http://www2.isda.org/functional-areas/protocol-management/protocol/12

6. The Sarbanes–Oxley Act of 2002 (Pub. L. 107–204, 116 Stat. 745, enacted July 30, 2002)

7. Commodity Futures Trading Commission, 17 CFR Parts 39 and 50 RIN 3038-AD86 Clearing Requirement Determination Under Section 2(h) of the CEA, AGENCY: Commodity Futures Trading Commission. ACTION: Final rule

8. Commodity Futures Trading Commission, 17 CFR Part 39 RIN 3038-AD10 End-User Exception to the Clearing Requirement for Swaps, AGENCY: Commodity Futures Trading Commission. ACTION: Final rule

9. Commodity Futures Trading Commission, 17 CFR Part 45, RIN 3038-AD19, Swap Data Recordkeeping and Reporting Requirements, AGENCY: Commodity Futures Trading Commission. ACTION: Final rule

10. http://www.cftc.gov/ucm/groups/public/@newsroom/documents/file/bcs_qas_final.pdf

11. Commodity Futures Trading Commission, 17 CFR Part 43, RIN 3038-AD08, Real-Time Public Reporting of Swap Transaction Data, AGENCY: Commodity Futures Trading Commission. ACTION: Final rule

12. Commodity Futures Trading Commission, 17 CFR Part 151, RIN 3038-AD82, Aggregation, Position Limits for Futures and Swaps, AGENCY: Commodity Futures Trading Commission. [[Page 31768]] ACTION: Notice of proposed rulemaking

13. International Swaps and Derivatives Association v. United States Commodity Futures Trading Commission, No. 11-cv-2146 (RLW), 2012 WL 4466311 (D.D.C. Sept. 28, 2012)

14. http://www.cftc.gov/PressRoom/PressReleases/pr6413-12

15. Commodity Futures Trading Commission, 17 CFR Parts 4 and 23, RIN 3038-AD25, Business Conduct Standards for Swap Dealers and Major Swap Participants With Counterparties, AGENCY: Commodity Futures Trading Commission. ACTION: Final rules

References

Shelley HurleyShelley is executive director – Risk Management, and Global Resources lead. Based in Austin, Texas, Shelley has over 30 years of global, industry and consultancy experience in the energy, resources and metal sectors as a trader, managing director and NYMEX seat holder. Her previous roles as Chief Risk Officer and founder of the Committee of Chief Risk Officers in the resources sector and extensive experience in risk management, credit risk management, operational risk management, trading

and performance management helps executives from multinationals across the energy and resource sectors become high performance businesses.

Margarita JannaschMargarita is principal – Risk Management, based in Houston, Texas. Margarita brings 20 years of combined industry experience in energy upstream planning and economics, wholesale energy merchant mid-office risk controls, international energy project risk management and integrated electric utility enterprise risk

management, governance and strategy. Margarita has served in Risk Management executive leadership roles where she implemented and managed formal Risk Committees, risk processes and standards. As Accenture’s Resources Risk Management subject matter expert in regulatory reform and compliance, she helps companies become high performance businesses.

The authors would like to thank Accenture employee Vicki L. Wilson for her contribution to this piece.

About the Authors

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About Accenture Management ConsultingAccenture is a leading provider of management consulting services worldwide. Drawing on the extensive experience of its 16,000 management consultants globally, Accenture Management Consulting works with companies and governments to achieve high performance by combining broad and deep industry knowledge with functional capabilities to provide services in Strategy, Analytics, Customer Relationship Management, Finance & Enterprise Performance, Operations, Risk Management, Sustainability, and Talent and Organization.

About Accenture Risk ManagementAccenture Risk Management consulting services work with clients to create and implement integrated risk management capabilities designed to gain higher economic returns, improve shareholder value and increase stakeholder confidence.

About AccentureAccenture is a global management consulting, technology services and outsourcing company, with approximately 261,000 people serving clients in more than 120 countries. Combining unparalleled experience, comprehensive capabilities across all industries and business functions, and extensive research on the world’s most successful companies, Accenture collaborates with clients to help them become high-performance businesses and governments. The company generated net revenues of US$27.9 billion for the fiscal year ended Aug. 31, 2012. Its home page is www.accenture.com.

DisclaimerThis document is intended for general informational purposes only and does not take into account the reader’s specific circumstances, and may not reflect the most current developments. Accenture disclaims, to the fullest extent permitted by applicable law, any and all liability for the accuracy and completeness of the information in this document and for any acts or omissions made based on such information. Accenture does not provide legal, regulatory, audit, or tax advice. Readers are responsible for obtaining such advice from their own legal counsel or other licensed professionals.

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