Obbligazione Montepaschi Siena S.p.A. 8% ( XS2106849727 ) in EUR

Montepaschi Siena S.p.A.

100 EUR ▲

Italia

XS2106849727 ( in EUR )

8% per anno ( pagato 1 volta l'anno)

21/01/2030

Prospetto opuscolo dell'obbligazione Banca Monte dei Paschi di Siena S.p.A XS2106849727 en EUR 8%, scadenza 21/01/2030

100 000 EUR

400 000 000 EUR

22/01/2026 ( In 145 giorni )

Banca Monte dei Paschi di Siena S.p.A. è una banca italiana con una lunga storia, tra le più antiche del mondo, attualmente impegnata in un processo di ristrutturazione e risanamento.

The Obbligazione issued by Montepaschi Siena S.p.A. ( Italy ) , in EUR, with the ISIN code XS2106849727, pays a coupon of 8% per year.
The coupons are paid 1 time per year and the Obbligazione maturity is 21/01/2030

BASE PROSPECT US dated 8 March 2019

Banca Monte dei Paschi di Siena S.p.A.
50,000,000,000
Debt Issuance Programme
Under this 50,000,000,000 Debt Issuance Programme (the " Programme"), Banca Monte dei Paschi di Siena S.p.A. (the " Issuer" or " BMPS"
or " Bank") may from time to time issue notes (the " Notes") denominated in any currency agreed between the Issuer and the relevant Dealer (as
defined below).
The maximum aggregate nominal amount of all Notes from time to time outstanding under the Programme will not exceed 50,000,000,000 (or
its equivalent in other currencies calculated as described herein), subject to increase as described herein.
The Notes may be issued on a continuing basis to one or more of the Dealers specified under " General Description of the Programme" and any
additional Dealer appointed under the Programme from time to time by the Issuer (each a " Dealer" and together the " Dealers"), which
appointment may be for a specific issue or on an ongoing basis. References in this Base Prospectus t o the " relevant Dealer" shall, in the case of
an issue of Notes being (or intended to be) subscribed by more than one Dealer, be to all Dealers agreeing to purchase such N otes.
An investment in Notes issued under the Programme involves certain risks. For a discussion of these risks see " Risk Factors".
Application for approval has been made to the Commission de Surveillance du Secteur Financier (the " CSSF") in its capacity as competent
authority under the Luxembourg Act dated 10 July 2005 on prospectus for securities (the " Prospectus Act 2005") to approve this document as a
Base Prospectus. By approving this Base Prospectus, the CSSF shall give no undertaking as to the economic and financial sound ness of the
operation or the quality or solvency of the Issuer in accordance with Article 7(7) of the Prospectus Act 2005. Application has also been made to
the Luxembourg Stock Exchange for Notes issued under the Programme to be admitted to trading on the Luxembourg Stock Exchange's
regulated market and to be listed on the Official List of the Luxembourg Stock Exchange.
References in this Base Prospectus to Notes being " listed" (and all related references) shall mean that such Notes have been admitted to trading
on the Luxembourg Stock Exchange's regulated market and have been admitted to the Official List of the Luxembourg Stock Exchange. The
Luxembourg Stock Exchange's regulated market is a regulated market for the purposes of the Markets in Financial Instruments D irective
(Directive 2014/65/EU).
The requirement to publish a prospectus under the Prospectus Directive (as defined under " Important Information" below) only applies to Notes
which are to be admitted to trading on a regulated market in the European Economic Area and/or offered to the public in the E uropean Economic
Area other than in circumstances where an exemption is available under Article 3.2 of the Prospectus Directive. References i n this Base
Prospectus to " Exempt Notes" are to Notes for which no prospectus is required to be published under the Prospectus Directive. The CSSF has
neither approved nor reviewed information contained in this Base Prospectus in connection with Exempt Notes.
Notice of the aggregate nominal amount of Notes, interest (if any) payable in respect of Notes, the issue price of Not es and certain other
information which is applicable to each Tranche (as defined under " Terms and Conditions of the Notes") of Notes will (other t han in the case of
Exempt Notes, as defined above) be set out in a final terms document (the " Final Terms") which will be filed with the CSSF. Copies of Final
Terms in relation to Notes to be listed on the Luxembourg Stock Exchange will also be published on the website of the Luxembo urg Stock
Exchange (www.bourse.lu). In the case of Exempt Notes, notice of the aggregate nominal amount of Notes, interest (if any) payable in respect of
Notes, the issue price of Notes and certain other information which is applicable to each Tranche will be set out in a pricin g supplement
document (the " Pricing Supplement").

The Programme provides that Notes may be listed or admitted to trading, as the case may be, on such other or further stock exchanges o r markets
as may be agreed between the Issuer and the relevant Dealer. The Issuer may also issue unlisted Notes and/or Notes not ad mitted to trading on
any market.
In certain circumstances, payments of interest relating to the Notes are subject to a deduction by way of " imposta sostitutiva" or withholding tax
as more fully set out in Condition 6 (Taxation) of the Terms and Conditions and in " Italian Taxation".
The rating of certain Series of Notes to be issued under the Programme may be specified in the Form of Final Terms. Whether o r not each credit
rating applied for in relation to relevant Series of Notes will be issued by a credit rating agency established in the European Union and registered
under Regulation (EC) No 1060/2009 (as amended) (the " CRA Regulation") will be disclosed in the Final Terms. Such credit rating agency will
be included in the list of credit rating agencies published by the European Securities and Markets Authority on its website ( at
http://www.esma.europa.eu/page/List-registered-and-certified-CRAs) in accordance with the CRA Regulation. A credit rating is not a
recommendation to buy, sell or hold securities and may be subject to revision, suspension or withdrawal at any time by the as signing Rating
Agency. Please also refer to " Ratings of the Notes" in the " Risk Factors" section of this Base Prospectus.
Amounts payable under the Floating Rate Notes and/or the Reset Notes may be calculated by reference to EURIBOR or LIBOR, as specified in
the relevant Final Terms. As at the date of this Base Prospectus, the ICE Benchmark Adminis tration (as administrator of LIBOR) is included in
the register of administrators maintained by the European Securities and Markets Authority (" ESMA") under Article 36 of the Regulation (EU)
No. 2016/1011 (the " Benchmarks Regulation"). As at the date of this Base Prospectus, the European Money Markets Institute (as administrator
of EURIBOR) is not included in the ESMA's register of administrators under Article 36 of the Benchmarks Regulation.
As far as the Issuer is aware, the transitional provisions in Article 51 of the Benchmarks Regulation apply, such that the administrator of
EURIBOR is not currently required to obtain authorisation or registration (or, if located outside the European Union, recogni tion, endorsement
or equivalence).
ARRANGER
NatWest Markets
DEALERS
Barclays
BofA Merrill Lynch
Citigroup
Crédit Agricole CIB
Credit Suisse
Deutsche Bank
Goldman Sachs International
HSBC
J.P. Morgan
Mediobanca - Banca di Credito Finanziario S.p.A.
Morgan Stanley
MPS Capital Services Banca per le Imprese S.p.A.
NatWest Markets
Société Générale Corporate & Investment Banking
UBS Investment Bank

0011398-0005128 RM:6298262.31
2

IMPORTANT INFORMATION
Responsibility Statement
The Issuer accepts responsibility for the information contained in this Base Prospectus and the Final
Terms for each Tranche of Notes issued under the Programme. To the best of the knowledge of the
Issuer (having taken all reasonable care to ensure that such is the case) the information contained in
this Base Prospectus is in accordance with the facts and does not omit anything likely to affect the
import of such information.
This Base Prospectus constitutes a base prospectus for the issuance of Notes under the Programme by
BMPS. This base prospectus constitutes a base prospectus in respect of all Notes other than Exempt
Notes issued under the Programme for the purposes of Article 5.4 of the Prospectus Directive. When
used in this Base Prospectus, Prospectus Directive means Directive 2003/71/EC (as amended or
superseded) and includes any relevant implementing measures in a relevant Member State of the
European Economic Area).
This Base Prospectus is to be read in conjunction with all documents which are deemed to be
incorporated herein by reference (see "Documents Incorporated by Reference" below). This Base
Prospectus shall be read and construed on the basis that such documents incorporated by reference and
form part of this Base Prospectus.
Save for the Issuer, no party has independently verified the information contained herein. Accordingly,
no representation, warranty or undertaking, express or implied, is made and no responsibility or
liability is accepted by the Dealers as to the accuracy or completeness of the information contained or
incorporated in this Base Prospectus or any other information provided by the Issuer in connection
with the Programme. No Dealer accepts any liability in relation to the information contained or
incorporated by reference in this Base Prospectus or any other information provided by the Issuer in
connection with the Programme.
No person is or has been authorised by the Issuer to give any information or to make any representation
not contained in or not consistent with this Base Prospectus or any other information supplied in
connection with the Programme or the Notes and, if given or made, such information or representation
must not be relied upon as having been authorised by the Issuer or any of the Dealers.
Neither this Base Prospectus nor any other information supplied in connection with the Programme or
any Notes (i) is intended to provide the basis of any credit or other evaluation or (ii) should be
considered as a recommendation by the Issuer or any of the Dealers that any recipient of this Base
Prospectus or any other information supplied in connection with the Programme or any Notes should
purchase any Notes. Each investor contemplating purchasing any Notes should make its own
independent investigation of the financial condition and affairs, and its own appraisal of the
creditworthiness, of the Issuer and/or the Group. "Group" means BMPS and its Subsidiaries (as
defined in the Agency Agreement). Neither this Base Prospectus nor any other information supplied in
connection with the Programme or the issue of any Notes constitutes an offer or invitation by or on
behalf of the Issuer or any of the Dealers to any person to subscribe for or to purchase any Notes.
Neither the delivery of this Base Prospectus nor the offering, sale or delivery of any Notes shall in any
circumstances imply that the information contained herein concerning the Issuer is correct at any time
subsequent to the date hereof or that any other information supplied in connection with the Programme
is correct as of any time subsequent to the date indicated in the document containing the same. The
Dealers expressly do not undertake to review the financial condition or affairs of the Issuer during the
life of the Programme or to advise any investor in the Notes of any information coming to their
attention. Investors should review, inter alia, the most recently published documents incorporated by
reference into this Base Prospectus when deciding whether or not to purchase any Notes .

0011398-0005128 RM:6298262.31
3

IMPORTANT EEA RETAIL INVESTORS  If the Final Terms in respect of any Notes (or Pricing
Supplement, in the case of Exempt Notes) includes a legend entitled "Prohibition of Sales to EEA Retail
Investors", the Notesare not intended to be offered, sold or otherwise made available to and should not be
offered, sold or otherwise made available to any retail investor in the European Economic Area ("EEA"). For
these purposes, a retail investor means a person who is one (or more) of: (i) a retail client as defined in point
(11) of Article 4(1) of Directive 2014/65/EU (as amended, "MiFID II"); (i ) a customer within the meaning of
Directive 2002/92/EC (as amended or superseded, "IMD"), where that customer would not qualify as a
professional client as defined in point (10) of Article 4(1) of MiFID II; or (iii) not a qualified investor as
defined in Directive 2003/71/EC (as amended or superseded, the "Prospectus Directive"). Consequently no
key information document required by Regulation (EU) No 1286/2014 (as amended, the "PRIIPs
Regulation") for offering or sel ing the Notes or otherwise making them available to retail investors in the
EEA has been prepared and therefore offering or selling the Notes or otherwise making them available to any
retail investor in the EEA may be unlawful under the PRIIPs Regulation.
MIFID II product governance / target market The Final Terms in respect of any Notes (or Pricing
Supplement, in the case of Exempt Notes) wil include a legend entitled "MiFID II Product Governance"
which will outline the target market assessment in respect of the Notes and which channels for distribution of
the Notes are appropriate. Any person sub sequently offering, selling or recommending the Notes (a
"distributor") should take into consideration the target market assessment; however, a distributor subject to
MiFID II is responsible for undertaking its own target market assessment in respect of th e Notes (by either
adopting or refining the target market assessment) and determining appropriate distribution channels.
A determination will be made in relation to each issue about whether, for the purpose of the MiFID Product
Governance rules under EU Delegated Directive 2017/593 (the "MiFID Product Governance Rules "), any
Dealer subscribing for any Notes is a manufacturer in respect of such Notes, but otherwise neither the
Arranger nor the Dealers nor any of their respective affiliates will be a manufac turer for the purpose of the
MiFID Product Governance Rules.

IMPORTANT INFORMATION RELATING TO THE USE OF THIS BASE PROSPECTUS AND
OFFERS OF NOTES GENERALLY
This Base Prospectus does not constitute an offer to sell or the solicitation of an offer to buy any Notes
in any jurisdiction to any person to whom it is unlawful to make the offer or solicitation in such
jurisdiction. The distribution of this Base Prospectus and the offer or sale of Notes may be restricted by
law in certain jurisdictions. The Issuer and the Dealers do not represent that this Base Prospectus may
be lawfully distributed, or that any Notes may be lawfully offered, in compliance with any applicable
registration or other requirements in any such jurisdiction, or pursuant to an exemption available
thereunder, or assume any responsibility for facilitating any such distribution or offering. In particular,
no action has been taken by the Issuer or the Dealers which is intended to permit a public offering of
any Notes or distribution of this document in any jurisdiction where action for that purpose is required.
Accordingly, no Notes may be offered or sold, directly or indirectly, and neither this Base Prospectus
nor any advertisement or other offering material may be distributed or published in any jurisdiction,
except under circumstances that will result in compliance with any applicable laws and regulations.
Persons into whose possession this Base Prospectus or any Notes may come must inform themselves
about, and observe, any such restrictions on the distribution of this Base Prospectus and the offering
and sale of Notes. In particular, there are restrictions on the distribution of this Base Prospectus and
the offer or sale of Notes in the United States, the European Economic Area (including the United
Kingdom and the Republic of Italy ("Italy")) and Japan, see "Subscription and Sale".
SUITABILITY OF INVESTMENT
The Notes may not be a suitable investment for all investors. Each potential investor in the Notes must
determine the suitability of that investment in light of its own circumstances. In particular, each

0011398-0005128 RM:6298262.31
4

potential investor may wish to consider, either on its own or with the help of its financial and other
professional advisers, whether it:
(i)
has sufficient knowledge and experience to make a meaningful evaluation of the Notes, the
merits and risks of investing in the Notes and the information contained or incorporated by
reference in this Base Prospectus or any applicable supplement;
(ii)
has access to, and knowledge of, appropriate analytical tools to evaluate, in the context of its
particular financial situation, an investment in the Notes and the impact the Notes will have on
its overall investment portfolio;
(iii)
has sufficient financial resources and liquidity to bear all of the risks of an investment in the
Notes, including Notes with principal or interest payable in one or more currencies, or where
the currency for principal or interest payments is different from the potential investor's
currency;
(i v)
understands thoroughly the terms of the Notes and is familiar with the behaviour of any
relevant indices and financial markets; and
(v)
is able to evaluate possible scenarios for economic, interest rate and other factors that may
affect its investment and its ability to bear the applicable risks.
Legal investment considerations may restrict certain investments. The investment activities of certain
investors are subject to legal investment laws and regulations, or review or regulation by certain
authorities. Each potential investor should consult its legal advisers to determine whether and to what
extent (1) Notes are legal investments for it, (2) Notes can be used as collateral for various types of
borrowing and (3) other restrictions apply to its purchase or pledge of any Notes. Financial institutions
should consult their legal advisers or the appropriate regulators to determine the appropriate treatment
of Notes under any applicable risk-based capital or similar rules.
The Notes have not been and will not be registered under the U.S. Securities Act of 1933, as amended,
(the "Securities Act") and are subject to U.S. tax law requirements. Subject to certain exceptions, Notes
may not be offered, sold or delivered within the United States or to or for the account or benefit of U.S.
persons (see "Subscription and Sale" below).
PRESENTATION OF INFORMATION
All references in this document to "U.S. dollars", "U.S.$" and "$" refer to the currency of the United
States of America and references to "euro", "" and "Euro" refer to the currency introduced at the
start of the third stage of European economic and monetary union pursuant to the Treaty on the
Functioning of the European Union, as amended.
Unless otherwise indicated, the financial information contained in this Base Prospectus has been
prepared in accordance with International Financial Reporting Standards as adopted by the European
Union ("IFRS").
Unless otherwise indicated, any reference in this Base Prospectus to "Consolidated Financial
Statements" is to the consolidated financial statements of the Group as at and for the years ended 31
December 2017 and 2016 audited by EY S.p.A., independent accountant, and incorporated by reference
in this Base Prospectus.
The Consolidated Financial Statements are denominated in euro.

0011398-0005128 RM:6298262.31
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TABLE OF CONTENTS
Page
Risk Factors ................................................................................................................................ 8
Documents Incorporated by Reference ........................................................................................ 110
General Description of the Programme ........................................................................................ 114
Form of the Notes .................................................................................................................... 120
Form of Final Terms................................................................................................................. 122
Applicable Pricing Supplement .................................................................................................. 134
Terms and Conditions of the Notes ............................................................................................. 145
Use of Proceeds ....................................................................................................................... 183
Banca Monte dei Paschi di Siena S.P.A. ...................................................................................... 184
Management of the Bank........................................................................................................... 257
Taxation ................................................................................................................................. 269
Subscription and Sale ............................................................................................................... 277
General Information ................................................................................................................. 281

0011398-0005128 RM:6298262.31
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STABILISATION
In connection with the issue of any Tranche of Notes, the Dealer or Dealers (if any) named as the
Stabilisation Manager(s) (or persons acting on behalf of any Stabilisation Manager(s)) in the Form of
Final Terms or Pricing Supplement may over-allot Notes or effect transactions with a view to
supporting the market price of the Notes at a level higher than that which might otherwise prevail.
However stabilisation may not necessarily occur. Any stabilisation action may begin on or after the date
on which adequate public disclosure of the terms of the offer of the relevant Tranche of Notes is made
and, if begun, may cease at any time, but it must end no later than the earlier of 30 days after the issue
date of the relevant Tranche of Notes and 60 days after the date of the allotment of the relevant Tranche
of Notes.
Any stabilisation action or over-allotment must be conducted by the relevant Stabilisation Manager(s)
(or persons acting on behalf of any Stabilisation Manager(s)) in accordance with all applicable laws and
rules.

0011398-0005128 RM:6298262.31
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RISK FACTORS
In purchasing Notes, investors assume the risk that BMPS may become insolvent or otherwise be unable to
mak e all payments due in respect of the Notes. There is a wide range of factors which individually or
together could result in BMPS becoming unable to mak e all payments due in respect of the Notes. It is not
possible to identify all such factors or to determine which factors are most lik ely to occur, as BMPS may
not be aware of all relevant factors and certain factors which it currently deems not to be material may
become material as a result of the occurrence of events outside the control of BMPS. BMPS has identified
in this Base Prospectus a number of factors which could materially adversely affect its businesses and
ability to mak e payments due under the Notes. In addition, factors which are material for the purpose of
assessing the mark et risk s associated with Notes issued under the Programme are also described below.
Any reference in the Risk Factors to "Form of Final Terms" or "Final Terms" shall be deemed to include
a reference to "applicable Pricing Supplement" or "Pricing Supplement" where relevant in the case of
Exempt Notes.
RISK FACTORS RELATING TO THE ISSUER AND THE GROUP
Risks associated with the failed realisation of the Restructuring Plan
The approval of the Restructuring Plan 2017 2021 (the "Restructuring Plan") of the Bank by the
European Commission on 4 July 2017 allowed the precautionary recapitalisation of the Bank in
compliance with the legislation applicable to banks in the matter of "State aid".
The precautionary recapitalisation has been implemented through the Italian Ministry of Economy and
Finance ("MEF")'s publication of the decrees aimed also at executing the Burden Sharing (as defined in
"Risks associated with the application of Burden Sharing in the context of precautionary recapitalisation
intervention" below).
The Restructuring Plan groups together common risks of an industrial plan, such as (i) those reporting in
quantitative and qualitative terms the directors' purposes related to competitive strategies of a company
and the actions that will be implemented for the purpose of achieving the strategic goals and (ii)
assumptions of formal commitments given to the European Commission consistent with the limits
provided for the purpose of "State aid" by the European Commission concerning the compliance with
certain objectives whose grade of achievement will be periodically monitored by an independent subject
(monitoring trustee) (the "Commitments"). The Issuer proposed with favourable opinion of the ECB
Directorate General Competition ("DG Comp") the appointment of Degroof Petercam Finance as
monitoring trustee (that acted as monitoring trustee for the Commitments of the BMPS' restructuring plan
2013-2017 as well). The first monitoring was carried out during the last quarter of 2017 with reference to
the data available as at 30 September 2017; subsequently, the monitoring activity has been, and continues
to be, carried out quarterly.
In summary, the Restructuring Plan provides for:
a)
the Bank's return to an adequate profitability level, after the losses over the last financial years
with a target return on equity (ROE) exceeding 10 per cent. in 2021 based on the following
pillars:
(i)
enhancement of retail and small business customers ' sectors, thanks to a new simplified
and highly digitalised business model;

8

(ii)
renewed operational model, with constant focus on efficiency, which will lead to a
cost/income ratio target lower than 51 per cent. in 2021 and to a reallocation to the
commercial activities of the resources engaged in administrative activities;
(iii)
radically improved management of credit risk, with a new organisational structure of the
chief lending officer, which wil al ow the strengthening of the Bank's early detection
processes and improve the cure rate, which will lead to a risk cost lower than 60 basis
points and a ratio between the gross value of the Impaired Loans (as defined below) and
the total amount of the receivables ("Gross NPE ratio") lower than 13 per cent. in 2021;
and
(iv)
enhanced capital and liquidity position, with targets in 2021 including a CET1 higher than
14 per cent., a loan to deposit ratio lower than 90 per cent. and an LCR (as defined below)
higher than 150 per cent., with, at the same time, a significant reduction of the cost of
funding; and
b)
the disposal of almost the entire Doubtful Loan portfolio as at 31 December 2016 for gross Euro
28.6 billion, which as of the date of this Base Prospectus has been completed.
The Restructuring Plan, by means of the planned improvement guidelines and after the reduction trend of
the Bank's market share on the main aggregate assets, aims at stabilising the commercial penetration level
as effect of a progressive re-approaching of the performance to those realised by the main competitors.
Therefore, there is a risk that the Bank may not be able to keep pace with said competitors' gro wth; if the
performance misalignment with respect to the main competitors ' performance is such as to involve the
failure to comply with one or more Commitments of the Restructuring Plan, the adjustment mechanisms
described below may be activated.
Furthermore, the Restructuring Plan is consistent with and reflects the Commitments given to the European
Commission and is in line with the parameters set out in the letter relating to the annual review and
supervisory assessment (the "Supervisory Review and Evaluation Process" or "SREP") received on 19
June 2017 ("SREP Decision 2017"). In said document, the European Central Bank ("ECB") required the
Bank to comply, starting from 2018, with a level of Total SREP Capital Requirement ("TSCR") on a
consolidated basis equal to 11 per cent., including the minimum requirement of Common Equity Tier 1
("Pillar I") equal to 8 per cent. and an additional requirement equal to 3 per cent. ("Pillar II"), entirely
based on Common Equity Tier 1. Consequently, the Group is required to comply with the following
requirements at consolidated level as of 1 January 2018: with a CET1 ratio on a transitional basis equal to
9.44 per cent. and a total capital ratio, again on a transitional basis, equal to 12.94 per cent., including, in
addition to Pillar I and Pillar II, a capital conservation buffer equal to 1.875 per cent. and an Other
Systemically Important Institutions Buffer ("O-SII Buffer") equal to 0.06 per cent. As from 1 January
2019, the capital conservation buffer is equal to 2.5 per cent. It should be noted that, starting from 1
January 2019, the Group is not required to comply with the O-SII Buffer since it has not been qualified by
the Bank of Italy as a national systemically important institution authorised to operate in Italy. For more
information on the capital adequacy requirements which the Bank has to comply with, please see "Risk
associated with capital adequacy".
In this respect, it should be noted that, on 5 December 2018, BMPS received a draft decision from the
supervisory authority which sets out the prudential requirements, based on the revision and evaluation
process (Supervisory Review and Evaluation Process SREP) carried out according to article 4, par. 1,
letter f), of Regulation (EU) no. 1024/2013, with reference date as of 31 December 2017 (the "Draft
SREP Decision"). Based on the results arising from the SREP 2018 (as defined below), the Draft SREP

9

Decision sets out the prudential requirements both quantitative (own funds) and qualitative for BMPS, and
provides the Bank with some recommendations.
With specific reference to the coverage of the non-performing loans, BMPS has received some
recommendations from the ECB aiming at ensuring constant improvements in the reduction of pre -existing
risks in the Euro Area and to accomplish the same coverage level for the amounts and flows of the non -
performing loans in the mid-term. With a press release published last year (11 July 2018), the ECB
announced that it would have communicated with each bank for determining the in dividual supervisory
expectations, on the basis of a comparative evaluation (benchmarking) between similar banks, taking into
account the current level of NPL ratio and other financial indicators of each bank. In this context, BMPS
has been advised to develop, in the next years (up to the end of 2026), a gradual increase of the coverage
levels over the stock of the non-performing loans resulting as such at the end of March 2018, according to
a collateral logic to the indications provided in the addendum to the ECB Guidelines for banks on non-
performing loans issued starting from April 2018.
The Bank received the final version of the letter on 8 February 2019 further to the completion of the SREP
process with reference date as of 31 December 2017 (respectively, the "2018 SREP Decision" and the
"SREP 2018"). The 2018 SREP Decision confirmed the prudential requirements and the recommendations
for BMPS contained in the Draft SREP Decision.
For further information relating to the Draft SREP Decision, reference is made to "Risks associated with
the investigations of supervisory authorities" below.
In March 2018, the ECB published the addendum to the guidance to banks on non -performing loans dated
20 March 2017. Said document, which was being consulted on from 4 Octo ber 2017, provides further
guidance on the non-performing loans ("NPLs") by specifying the ECB's supervisory expectations when
assessing a bank's prudential provisioning levels for impaired exposures. In light of the above, for
exposures that will be at default from 1 April 2018, the ECB will assess, among several aspects, the period
of time during which the exposure has been classified as impaired (i.e. its "seniority"), as well as the
collaterals held (where applicable). The ECB's expectations have no acc ounting impact, but concern the
assessment of capital adequacy. During the supervisory consultation, which takes place at least once a year
within the scope of the SREP, the ECB shall discuss with banks any inconsistencies between the coverage
level adopted and the expectations on prudential provisioning levels, starting with the evaluation process of
2021. Since the addendum was consulted on at a later date with respect to the approval of the Restructuring
Plan and, therefore, the Restructuring Plan does n ot consider the possible effects of the addendum, from
2021 the Bank's SREP target may have to take into account additional capital requirements (consistent
with the provisions of the aforementioned addendum).
Furthermore, it should be noted that, on 7 February 2019, the Board of Directors of the Bank reviewed and
approved the consolidated results as at 31 December 2018 in the context of which the Bank has updated its
multiannual internal estimates of income statement and balance sheet figures. Such estima tes are lower
than those contained in the Restructuring Plan, but nonetheless show capital ratios which are above the
relevant regulatory requirements. Please refer to "Banca Monte dei Paschi di Siena S.P.A. Major Events
 Recent developments Other events relating to 2017-2019" of this Base Prospectus.
The Restructuring Plan is consistent with the Commitments given by the Italian government to the
European Commission, concerning various aspects of the plan, such as, inter alia:
(i)
Burden Sharing: the full realisation of burden sharing measures, as provided for by art. 23 of
Decree 237 (as defined below);

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