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POPULAR, INC. (BPOP) FY 2023 MD&A

Verbatim Item 7 Management's Discussion and Analysis from POPULAR, INC.'s 10-K for fiscal year 2023. Filing date: 2024-02-29. Report date: 2023-12-31. Accession: 0001193125-24-053017.

This page reproduces the company's own Item 7 MD&A text from the linked SEC filing. It is filer text, not grepcent analysis, scoring, or investment advice.

Extracted from a substantive MD&A body after the formal Item 7 span was a TOC or reference stub. Confidence: high.

Company profile: BPOP · All MD&A years: index · Previous year: FY 2022 · Next year: FY 2024

results of

operations

and

capital

position.

These

risks

could

cause

our

actual

results

to

differ

materially

from

our

historical

results

or

the

results

contemplated by the forward-looking statements contained

in this report.

The risks described in

this report are not the

only risks we face. Additional

risks and uncertainties not currently

known by

us

or

that

we

currently

deem

to

be

immaterial,

or

that

are

generally

applicable

to

all

financial

institutions,

may

also

materially

adversely affect our business, financial condition, liquidity, results of operations or capital

position.

ECONOMIC AND MARKET RISKS

Weakness in

the economy,

particularly in

Puerto Rico,

where a

significant portion

of our

business is

concentrated, has

adversely impacted us in the past and may adversely

impact us in the future.

We have been, and will continue to be, impacted by global and local

economic and market conditions, including weakness

in the

economy,

disruptions and

volatility in

the financial

markets, inflation,

monetary and

fiscal policies,

public policy,

geopolitical

conflicts, business and consumer sentiment and unemployment. A significant portion of our business is concentrated

in Puerto Rico,

which accounted for approximately 77% of

our assets and 81% of

our deposits as of December 31,

2023 and 78% of our

revenues

for the

year ended

December 31,

2023. As

a result,

our financial

condition and

results of

operations are

highly dependent

on the

general

trends

of

the

Puerto

Rico

economy

and

other

conditions

affecting

Puerto

Rico

consumers

and

businesses.

The

concentration of

our operations in

Puerto Rico

exposes us to

greater risks than

other banking companies

with a

wider geographic

base.

Puerto Rico

has faced significant

economic and fiscal

challenges in the

past, including a

severe recession that

began in

2007 and

persisted for

over a

decade and

an acute

fiscal crisis

that led

the Puerto

Rico government

to file

for a

form

of federal

bankruptcy protection

in 2017.

Puerto Rico’s

fiscal and

economic challenges

have in

the past

adversely affected

our customers,

resulting

in

higher

delinquencies,

charge-offs

and

increased

losses

for

us.

While

Puerto

Rico’s

economy

has

been

gradually

recovering

and

the

Puerto

Rico

government

emerged

from

bankruptcy

in

2022,

Puerto

Rico

still

faces

economic

and

fiscal

challenges.

Moreover,

Puerto

Rico

has

historically

received

a

significant

amount

of

federal

funds

through

non-recurring

appropriations, particularly to cover costs associated with its health insurance program, and Puerto Rico’s recent economic recovery

has

been partially

driven by

significant federal

disaster relief

and stimulus

funding. Therefore,

the Puerto

Rico economy

is highly

susceptible

to

changes

in

federal

public

policy

towards

Puerto

Rico.

Public

policy

changes

that

result

in

a

reduction

of

federal

funding for Puerto

Rico, or in

delays in the

receipt of such funding,

could significantly impact Puerto

Rico’s economy.

A weakening

of the Puerto

Rico economy or other

adverse economic conditions affecting

Puerto Rico consumers and

businesses could result in

25

decreased demand

for our

products or services,

deterioration in the

credit quality

of our

customers, higher

delinquencies, charge-

offs or increased losses, all of which could adversely affect

our financial condition and results of operations.

We are

also exposed

to risks

related to

the state

of the

local economies

of the

other markets

in which

we do

business,

such as New York and Florida, and to the state of the global and U.S. economy and financial

markets. Global financial markets have

recently

experienced periods

of

extraordinary disruption

and volatility,

exacerbated by

geopolitical conflicts,

the

U.S.

debt-ceiling

situation,

high

levels

of

inflation

and

rapid

increases

in

interest

rates.

Inflationary

pressures

increased

certain

of

our

expenses

(including our

personnel expenses)

and adversely

affected consumer

sentiment. Central

bank responses

to inflationary

pressures

led to higher

market interest rates

and, in turn,

lower activity levels across

U.S. and global financial

markets. These circumstances

resulted in,

and could

continue to

result in,

reductions in

the value

of

our investments.

If these

conditions persist

or worsen,

our

results of operations, financial position and liquidity

could be materially and adversely affected.

Changes

in

interest

rates

and

credit

spreads

can

adversely

impact

our

financial

condition,

including

our

investment

portfolio,

since

a

significant

portion

of

our

business involves

borrowing

and

lending

money,

and

investing in

financial

instruments.

Our business

and financial

performance are

impacted by

market interest

rates and

movements in

those rates.

Since a

high percentage of our assets and liabilities are interest bearing or otherwise sensitive in value to changes in interest rates, changes

in interest rates, in the shape of the yield curve or in spreads between different types of rates, have had and could in the future have

a material impact on our results

of operations and the values of our

assets and liabilities, including our investment portfolio.

Interest

rates are

highly sensitive

to many

factors over

which we

have no

control and

which we

may not

be able

to anticipate

adequately,

including general

economic conditions

and the

monetary and

tax policies

of various

governmental bodies,

particularly the

Federal

Reserve Board.

Increasing levels of inflation, driven

by pent-up demand and supply-chain disruptions caused

by the COVID-19 pandemic

and the war in Ukraine, led

the Federal Market Committee of the Federal Reserve Board

(the “FOMC”) to execute a series of sharp

benchmark interest

rate increases

beginning in

the first

quarter of

2022. While

the

FOMC has

indicated that

it

may conclude

its

interest rate hike cycle, the amount and pace of any reduction in interest rates remains uncertain. Higher interest rates could lead to

fewer originations of

commercial and residential

real estate loans,

loss of deposits,

a misalignment in

the pricing of

short-term and

long-term

borrowings,

less

liquidity

in

the

financial

markets

and

higher

funding

costs.

Furthermore,

higher

interest

rates

could

negatively affect

the payment

performance on

loans linked

to variable

interest rates

to the

extent borrowers

are unable

to afford

higher interest

payments, which

could result

in higher

delinquencies. Inflationary

pressure arising

from increases

in interest

rates

may also affect

borrowers’ financial condition and

their ability to

pay their debts

when due. Additionally,

if the interest

rates we pay

on

our

deposits

and

other

borrowings

were

to

increase

at

a

faster

rate

than

the

interest

rates

we

receive

on

loans

and

other

investments,

our

net

interest

income,

and,

therefore,

our

earnings,

could

be

adversely

affected.

All

of

these

outcomes

could

adversely affect our earnings, liquidity and capital levels.

The

rapid

rise

in

interest

rates

in

2022

resulted

in

approximately

$2.5

billion

in

unrealized

mark-to-market

losses

on

available-for-sale securities held in our investment securities portfolio. In October 2022, we transferred U.S. Treasury securities with

a fair value of approximately $6.5 billion (par value of

$7.4 billion), and with accumulated unrealized losses of $873 million, from our

available-for-sale portfolio to

our held-to-maturity portfolio.

While the size

of our unrealized

mark-to-market losses on

available-for-

sale

securities

had

been

reduced

to

$1.4

billion

as

of

December

31,

2023,

if

interest

rates

were

to

again

rise

rapidly

or

for

a

prolonged period, we may accumulate significant additional mark-to-market

losses on investment securities in our available-for-sale

portfolio, which may adversely affect our tangible capital

and impact our ability to return capital to our

stockholders.

For a discussion of the Corporation’s

interest rate sensitivity, please refer

to the “Risk Management” section of the MD&A

in this Form 10-K.

BUSINESS RISKS

Negative

changes

in

the

financial

condition

of

our

clients

have

adversely

impacted

us

in

the

past

and

may

adversely

impact us in the future.

A significant portion of

our business involves lending money,

which exposes us to

credit risk and

risk of loss if

borrowers

do

not

repay

their

loans,

leases, credit

cards

or

other

credit

obligations.

The

performance of

these

credit

portfolios

significantly

affects our

financial condition

and results

of operations.

We have

in the

past been

adversely affected

by negative

changes in

the

financial condition of our clients due to weakness in

the Puerto Rico and U.S. economy. If the current economic environment were to

26

deteriorate, more customers may have difficulty in repaying their credit obligations, which may result in higher levels

of credit losses

and reserves for credit losses.

We are exposed to

increased credit risks and credit losses

to the extent our clients are

concentrated by industry segment

or type of client.

Our credit risk and credit

losses can increase to the extent

our loans are concentrated in borrowers engaged in

the same

or similar

activities or

in borrowers

who as

a group

may be

uniquely or

disproportionately affected

by certain

economic or

market

conditions. We have significant

exposure to borrowers in certain

economic sectors, such as residential

and commercial real estate,

hospitality and healthcare. Challenging economic or market conditions that affect

the industries or types of clients to

which we have

significant exposure could result in higher credit

losses and adversely affect our financial condition

and results of operations.

We also

have direct

lending and

investment exposure

to Puerto

Rico government

entities, which

have faced

significant

fiscal challenges.

At December

31, 2023,

our exposure

to the

Puerto Rico

government consisted

of $362

million in

direct lending

exposure to Puerto

Rico municipalities and

$238 million in

loans insured or

securities issued by

Puerto Rico governmental

entities

but for

which the

principal source

of repayment

is non-governmental.

We also

have indirect

lending exposure

to the

Puerto Rico

government in the

form of loans

to private borrowers

who are service

providers, lessors, suppliers

or have other

relationships with

the Puerto Rico government. While the overall fiscal situation

of the Puerto Rico government has improved in recent years,

including

as

result

of

the

government

and

certain

of

its

instrumentalities

having

restructured

their

debt

obligations,

some

Puerto

Rico

government entities, including certain municipalities, still face significant

fiscal challenges. A deterioration in the fiscal situation of the

Puerto Rico

government and its

instrumentalities, and in

particular in the

fiscal situation

of the

Puerto Rico

municipalities to

which

we have direct lending exposure, could result in

higher credit losses and reserves for credit losses. For

a discussion of risks related

to the Corporation’s credit exposure to the Puerto Rico

and USVI governments, see the Geographic and

Government Risk section in

the MD&A section of this Form 10-K.

Deterioration in the

values of real

properties securing our commercial, mortgage

loan and construction portfolios

have in

the past resulted, and may in the future result,

in increased credit losses and harm our results

of operations.

As of

December 31,

2023, approximately

55% of

our loan

portfolio consisted

of loans

secured by

real estate

collateral

(comprised of 30% in commercial loans, 22% in residential

mortgage loans and 3% in construction loans). The

value of the collateral

securing such loans is dependent upon economic conditions in the area in which the collateral is located. Weakness in the economy

of some of the

markets we serve has in

the past resulted in significant

declines in the value of

the real properties securing our

loan

portfolio, leading to increased credit losses. If the value of

the real estate properties securing our loan portfolio declines again in

the

future, we may be

required to increase our

provisions for loan losses

and allowance for loan

losses. Any such increase could

have

an adverse effect on

our financial condition and results of

operations. For more information on the credit

quality of our construction,

commercial and mortgage portfolio, see the Credit

Risk section of the MD&A included in this

Form 10-K.

We

are

exposed

to

credit

risk

from

mortgage

loans

that

have

been

sold

or

are

being

serviced

subject

to

recourse

arrangements.

Popular

is

generally

at

risk

for

mortgage

loan

defaults

from

the

time

it

funds

a

loan

until

the

time

the

loan

is

sold

or

securitized into a

mortgage-backed security.

However, we

have retained part

of the credit

risk on sales

of mortgage loans

through

recourse

arrangements,

and

we

also

service

certain

mortgage

loan

portfolios

with

recourse.

At

December

31,

2023,

we

were

exposed to credit risk with respect to $0.6 billion in residential mortgage loans sold

or serviced subject to credit recourse provisions,

consisting principally of loans associated with the Fannie Mae and

Freddie Mac programs. Pursuant to such recourse provisions,

we

are required to repurchase the loan or reimburse the third-party investor for the incurred loss in the event of a customer default. The

maximum potential amount of future payments that

we would be required to make

under the recourse arrangements in the event

of

nonperformance

by

the

borrowers

is

equivalent

to

the

total

outstanding balance

of

the

residential mortgage

loans

serviced

with

recourse

and

interest, if

applicable. In

the

event

of

nonperformance by

the borrower,

we

have

rights

to

the

underlying collateral

securing the

mortgage loan.

During 2023,

we repurchased

approximately $2

million in

mortgage loans

subject to

credit recourse

provisions. As

of December

31, 2023,

our liability

established to

cover the

estimated credit

loss exposure

related to

loans sold

or

serviced with credit recourse amounted to $4 million. We may suffer losses on these loans if the proceeds from a foreclosure sale of

the property underlying

a defaulted mortgage

loan are less

than the outstanding

principal balance of

the loan plus

any uncollected

interest advanced and the costs of holding and disposing

of the related property.

Defective and repurchased loans may harm our business

and financial condition.

27

In

connection

with

the

sale

and

securitization

of

mortgage

loans,

we

are

required

to

make

a

variety

of

customary

representations

and

warranties regarding

Popular

and

the

loans

being

sold

or

securitized.

Our

obligations with

respect to

these

representations and warranties are generally outstanding for the

life of the loan, and they

relate to, among other things, compliance

with

laws

and

regulations,

underwriting

standards,

the

accuracy

of

information

in

the

loan

documents

and

loan

file

and

the

characteristics

and

enforceability of

the

loan.

A

loan

that

does

not

comply

with

the

secondary

market’s

requirements

may

take

longer to

sell, impact

our ability

to securitize

the loans

or pledge

the loans

as collateral

for borrowings,

or be

unsalable or

salable

only

at

a

significant

discount.

Moreover,

if

any

such

loan

is

sold

before

we

detect

non-compliance,

we

may

be

obligated

to

repurchase the loan and bear any associated loss directly,

or we may be obligated to indemnify the purchaser against any loss.

We

seek to

minimize repurchases and

losses from defective

loans by correcting

flaws, if possible,

and selling or

re-selling such loans.

However,

if

we

were

to

suffer

significant

losses

from

defective

and

repurchased

loans,

our

results

of

operations

and

financial

condition could be materially impacted.

If we are

unable to maintain

or grow our

deposits, we may

be subject to

paying higher funding costs

and our net

interest

income may decrease.

We rely primarily

on bank deposits as

a low cost and

stable source of funding

for our lending activities

and the operation

of

our

business.

Therefore,

our

funding

costs

are

largely

dependent

on

our

ability

to

maintain

and

grow

our

deposits.

As

our

competitors have raised the

interest rates they pay

on deposits, our

funding costs have increased,

as we have

needed to increase

the rates we

pay to our depositors

to avoid losing deposits

and to procure new

ones. Rising interest rates

have also led customers

to move their funds to alternative investments that

pay higher interest rates.

Additionally, periods of market stress

or lack of market

or customer confidence in financial institutions may result in

a loss of customer deposits, especially to the

extent those deposits are

in excess of the FDIC-insured limit of $250,000. As of

December 31, 2023, we had $14.6 billion of deposits (other

than collateralized

public funds, which represent public deposit balances from governmental entities in the U.S. and its territories, including Puerto Rico

and the United States Virgin Islands, that are collateralized based on such jurisdictions’

applicable collateral requirements) in excess

of the FDIC-insured limit. As deposits decrease, we

may need to rely on more

expensive sources of funding. Furthermore, we have

a

significant

amount

of

deposits

from

the

Puerto

Rico

government,

its

instrumentalities

and

municipalities

($18.1

billion,

or

approximately 28% of our

total deposits, as of

December 31, 2023), and

the amount of these

deposits may fluctuate depending on

the financial

condition and

liquidity of

these entities,

as well

as on

our ability

to maintain

these customer

relationships. Under

the

terms of

BPPR’s deposit

pricing agreement

with Puerto

Rico public

sector,

public fund

deposit rates

are market

linked with

a lag

minus a

specified spread.

Therefore, as

market rates

rise, we

are required

to sequentially

increase the

rates we

pay our

public

deposits. If

we are unable

to maintain or

grow our deposits

for any

reason, we may

be subject to

paying higher funding

costs and

our net interest income may decrease.

OPERATIONAL RISKS

We

and our

third-party providers

have been,

and expect

in the

future to

continue to

be, subject

to cyber-attacks,

which

could cause substantial harm and have an adverse

effect on our business and results of operations.

Cybersecurity

risks

for

large

financial

institutions

such

as

Popular

have

increased

significantly

in

recent

years

in

part

because of

the proliferation

of new

technologies, such

as mobile

banking, artificial

intelligence and

the ability

to conduct

instant

financial transactions anywhere

globally, growing

geo-political threats, such

as the ongoing

wars in Ukraine

and in the

Gaza Strip,

and the increased sophistication and activities of

organized crime, hackers, terrorists, nation-states, hacktivists and other parties. In

the ordinary

course of

business, we

rely on

electronic communications

and information

systems to

conduct our

operations and

to

transmit

and

store

sensitive

data.

We

employ

a

layered

defensive approach

that

employs

people, processes

and

technology

to

manage and

maintain cybersecurity

controls through

a variety

of preventative

and detective

tools that

monitor, block,

and provide

alerts

regarding suspicious

activity

and

identify suspected

advanced persistent

threats.

Notwithstanding our

defensive measures

and

the

significant

resources

we

devote

to

protect

the

security

of

our

systems,

there

is

no

assurance

that

all

of

our

security

measures will be effective at all times, especially as the threats from cyber-attacks are continuous and severe. The risk of a security

breach due

to a

cyber-attack could

increase in

the future

as we

continue to

expand our

mobile banking

and other

internet-based

product

offerings,

the

use

of

the

cloud

for

system

development

and

hosting

and

internal

use

of

internet-based

products

and

applications.

We

continue to

detect and

identify attacks

that are

becoming more

sophisticated and

increasing in

volume, as

well as

attackers

that

respond

rapidly

to

changes

in

defensive

countermeasures. The

most

significant

cyber-attack

risks

that

we

or

our

critical service providers may face include, but are not limited to,

e-fraud, denial-of-service (DDoS), ransomware, computer intrusion

and

the

exploitation of

software zero-day

vulnerabilities that

might result

in

disruption of

services

and in

the

exposure or

loss of

customer

or

proprietary

data.

Loss

from

e-fraud

occurs

when

cybercriminals

compromise

our

systems

or

the

systems

of

our

28

customers and extract

funds from customer’s

credit cards or

bank accounts, including

through brute force,

password spraying and

credential

stuffing

attacks

directed

at

gaining

unauthorized

access

to

individual

accounts.

Denial-of-service

attacks

intentionally

disrupt

the

ability

of

legitimate

users,

including

customers

and

employees,

to

access

networks,

websites

and

online

resources.

Computer intrusion attempts either direct or through social engineering (pretext calls), supply chain compromise, email, text or voice

messages, including using brand impersonation (regularly referred

to as phishing, vishing, smishing

and quishing), have resulted in

and may continue to result in the compromise of sensitive customer data, such as account numbers, credit cards and social security

numbers,

and

could

present

significant

reputational, legal

and

regulatory costs

to

Popular

if

successful.

The

emergence of

new

technologies such as artificial intelligence and quantum

computing are further expected to exacerbate

the risk of cyber-attacks.

Our

customer-facing

platforms

are

also

routinely

attacked

by

threat

actors

aiming

to

gain

unauthorized

access

to

our

clients’ accounts.

Popular has

recently implemented

certain defensive

measures in

response to

brute force

attacks on

one of

our

platforms which resulted in certain

of our customers log-in credentials

and information being exposed. As

a result, Popular notified,

as required

or otherwise

deemed appropriate,

customers identified

as affected

by the

incident. We

have to

date not

experienced

material losses in connection with these attacks. Cyber-security risks have also been recently exacerbated by the discovery of zero-

day vulnerabilities in widely distributed third party software,

such as the vulnerability identified in the Apache

log4j in December 2021

and in the MOVEit file transfer application in

May 2023, which could affect Popular’s or any

of its service provider’s systems.

The

increased

use

of

remote

access

and

third-party

video

conferencing

solutions

to

enable

work-from-home

arrangements for employees and facilitate

the use of digital

channels by our customers,

has also increased our

exposure to cyber-

attacks. In

addition, a

third party

could misappropriate

confidential information

obtained by

intercepting signals

or communications

from mobile devices

used by Popular’s customers

or employees. Recent events,

including the wars

in Ukraine and

the Gaza Strip,

have also

illustrated increased

geo-political factors

and the

risks related

to supply-chain

compromises and

de-stabilizing activities

linked to

nation-state sponsored

activity as

an increasing

trend to

monitor actively.

Risks and

exposures related

to cyber

security

attacks are expected to remain high for the foreseeable future due to

the rapidly evolving nature and sophistication of these threats,

including the

rise in

the use

of cyber-attacks

as geopolitical

weapons. Although

we are

regularly targeted

by unauthorized

threat-

actor activity, including denial-of-service attacks, we have not, to date, experienced

any material losses as a result of cyber-attacks.

A material compromise or circumvention of the security of our systems could

have serious negative consequences for us,

including

significant

disruption

of

our

operations

and

those

of

our

clients,

customers

and

counterparties,

misappropriation

of

confidential information

of us

or that

of our

clients, customers,

counterparties or

employees, or

damage to

computers or

systems

used

by

us

or

by

our

clients,

customers

and

counterparties,

and

could

result

in

violations

of

applicable

privacy

and

other

laws,

financial loss

to us

or to

our customers,

loss of

confidence in

our security

measures, customer

dissatisfaction, significant litigation

exposure and harm to

our reputation, all of

which could have a

material adverse effect

on us. For example,

if personal, non-public,

confidential

or

proprietary

information

in

our

possession

were

to

be

mishandled,

misused

or

stolen,

we

could

suffer

significant

regulatory consequences, reputational damage

and financial loss.

Such mishandling, misuse

or misappropriation could include,

for

example, if such information

were provided to parties

who are not permitted

to have the

information, either by fault

of our systems,

by our employees

or counterparties, or

where such information

is intercepted or

otherwise inappropriately taken by

our employees

or third parties.

The

extent

of

a

particular

cyber-attack

and

the

steps

that

we

may

need

to

take

to

investigate

the

attack

may

not

be

immediately

clear,

and

it

may

take

a

significant

amount

of

time

before

such

an

investigation

can

be

completed.

While

such

an

investigation is ongoing, Popular may not necessarily know the full extent

of the harm caused by the cyber-attack, and that

damage

may continue to spread.

These factors may inhibit

our ability to provide

rapid, full and reliable

information about the cyber-attack to

our clients,

customers, counterparties

and regulators,

as well

as the

public. Moreover,

new regulations may

require us

to disclose

information about a cybersecurity event before

it has been resolved or

fully investigated. Furthermore, it may not

be clear how best

to

contain

and

remediate

the

potential

harm

caused

by

the

cyber-attack,

and

certain

errors

or

actions

could

be

repeated

or

compounded before they are discovered and remediated. Cyber-attacks could cause interruptions

in our operations and result in the

incurrence

of

significant

costs,

including those

related

to

forensic analysis

and

legal counsel,

each of

which may

be

required to

ascertain the extent

of any potential

harm to our

customers, or employees, or

damage to our information

systems and any

legal or

regulatory obligations that

may result therefrom.

Any cyber incidents

could also result

in, among other

things, increased regulatory

scrutiny

and adverse

regulatory or

civil

litigation consequences.

For a

discussion of

the guidance

and rules

that federal

banking

regulators

have

released

or

proposed

regarding

cybersecurity

and

cyber

risk

management

standards,

see

“Regulation

and

Supervision” in

Part

I,

Item

1 —

Business,

included in

the

Form 10-K

for the

year

ended December

31,

2023. Any

or

all

of

the

foregoing factors could further increase the impact

of the incident and thereby the costs and consequences

of a cyber-attack.

We also

rely on

third parties

for the

performance of

a significant

portion of

our information

technology functions and

the

29

provision of information security,

technology and business process services. As a result, a

successful compromise or circumvention

of

the security

of

the systems

of these

third-party service

providers could

have serious

negative consequences

for us,

including

compromise

of

our

systems,

misappropriation of

our

confidential

information

or

that

of

our

clients,

customers,

counterparties

or

employees,

or

other

negative

implications

identified

above

with

respect

to

a

cyber-attack

on

our

systems,

which

could

have

a

material

adverse effect

on

us.

Cyber-attacks at

third-party service

providers

are

also

becoming increasingly

common,

and,

as

a

result, cybersecurity risks relating to our vendors have

increased. The most important of these third-party service providers

for us is

Evertec. Certain risks particular to Evertec and

our dependence on third parties are discussed

under “We rely on other companies to

provide key components of our business infrastructure, including certain of our core financial transaction processing and information

technology and

security services, which

exposes us

to a

number of operational

risks that

could have

a material

adverse effect

on

us”

in

the

Operational

Risks

section

of

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