Riggs National Corporation & Subsidiaries (f.k.a. Riggs National Bank and Subsidiaries) - Page 6

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          term for foreign loans which varied from 5 to 12 years.  Although           
          the Brazilian Government sought to decrease the effects of                  
          inflation through an indexing system, in taking out a long-term             
          foreign loan, a Brazilian borrower incurred a substantial risk that         
          a decline in the exchange rate for the cruzeiro as a result of              
          domestic inflation could increase the cost of the loan.                     
               To increase foreign borrowing, the Brazilian Government                
          provided incentives to Brazilian borrowers in order to overcome             
          their reluctance to take out foreign loans.  These incentives               
          included the pecuniary benefit, the Resolution 63 loan program, and         
          the Resolution 432 loan program, all of which are more fully                
          discussed infra.                                                            
               Until about 1982, lending to Brazilian borrowers was quite             
          profitable for many foreign lenders, including some major U.S.              
          banks.  The interest rate spreads (i.e., the interest rate charged          
          on a loan, less the cost of the loan funds to the lender) on                
          Brazilian loans were higher than the interest rate spreads on loans         
          made in many other countries.  In addition, the ability to claim            
          foreign tax credits significantly enhanced the after-tax income             
          some foreign lenders derived with respect to their Brazilian loans.         
          C.  Brazilian Regulation of Foreign Lending                                 
               Brazil imposes restrictions on the receipt and exchange of             
          foreign currency.  By law, all loans from foreign lenders to                
          Brazilian borrowers must be registered with and approved by the             
          Central Bank.  Through the registration process, the Central Bank           




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