Quarterlytics / Financial Services / Banks - Diversified / Bank of Montreal

Bank of Montreal

bmo · TSX Financial Services
Claim this profile
Ticker bmo
Exchange TSX
Sector Financial Services
Industry Banks - Diversified
Employees 10,000+
← All annual reports
FY2021 Annual Report · Bank of Montreal
Sign in to download
Loading PDF…
204th  Annual Report 2021 

BMO Financial Group 

2021  Annual Report  
to Shareholders  

Business Review 

2  

3  

4  

5 

Financial Performance 

2021 Highlights 

Endings and Beginnings 

Chair’s Message 

6   A North American Bank 

7  

 Chief Executive Officer’s 
Message 

10  Net-Zero Ambition 

12   Digital First 

14   Our Bold Commitments 

16  

 Board of Directors and 
Executive Committee 

Financial Review 

17  Enhanced Disclosure  

Task Force 

18  Management’s Discussion  

and Analysis 

122   Supplemental Information 

139    Statement of Management’s 
Responsibility for Financial 
Information 

140  Independent Auditors’  Report 

143    Reports of Independent 

Registered Public Accounting 
Firm 

146 Consolidated Financial 

Statements 

151    Notes to Consolidated 
Financial Statements 

Resources and Directories 

136   Glossary of Financial Terms 

212    Where to Find More 

Information 

IBC   Shareholder Information 

ABOUT BMO 

A purpose-driven bank... 

BMO is a diversified North American financial services 
provider with a proud 204-year history and a clear 
strategy for the future. Guided by our values and 
driven by a deep sense of purpose, we serve more 
than 12 million customers through three integrated 
operating groups: Personal and Commercial Banking, 
BMO Capital Markets and BMO Wealth Management. 

Our bank is focused on being innovative, agile and 
uniquely competitive in a fast-changing world. We’re 
led by more than 12 million customers – individuals, 
families, businesses, institutional clients and 
communities – who inspire us to grow our own 
business, create value for our shareholders and 
advance positive social change. 

12+ 

million 

8th

largest 

customers globally  

bank in North America by assets 

$988 

billion 

1817  

in total assets 

Canada’s first bank, established in 1817 

 
 
 
 
 
 
 
 
  
 
 
 
A future-ready bank 

As the world emerges from a transformative crisis and  
the economy regains traction, BMO has never been better  
positioned for continued growth. Strong operating momentum;  
industry-leading customer loyalty; data-informed risk 
management; the flexibility to leverage our capital strength 
– these are the building blocks of a bank that’s ready for   
the future. 

We help our customers achieve their goals with digitally 
enabled products and services designed for speed, convenience 
and efficiency – and powered by human advice. And we 
foster a winning culture in which people across BMO are 
aligned in our decision-making, empowered to drive 
long-term change and recognized for our efforts to advance 
the bank’s strategic priorities. 

BMO has bold ambitions to accelerate our 
growth as a leading North American bank, 
one that helps to further a more inclusive 
society, a sustainable future, and a thriving 
economy in which everyone benefits. 

BMO Financial Group 204th Annual Report 2021  1 

  
 
 
 
 
 
 Financial Performance 

Medium-term objectives 

2021 financial performance

Reported1 

Adjusted1 

Adjusted EPS growth of 7% to 10% 

Adjusted ROE of 15% or more 

Adjusted net operating leverage of 2%   
or more 

53.3% 

14.9% 

0.4% 

68.0% 

16.7% 

6.1% 

Capital ratios that exceed  
regulatory requirements 

13.7%  
CET1 Ratio2 

Total shareholder return (%)

  BMO 

S&P/TSX Composite Index 

75.9 

38.8 

15.7 15.4 

14.0 

10.6 

1-year 

3-year 

5-year 

Earnings per share growth (%) 

Average annual ROE (%) 

Common Equity  Tier 1 Ratio (%)

  Reported
  Adjusted1

  Reported 
  Adjusted1 

68.0 

53.3 

(12.8) 
(18.2) 

14.3 

10.3 

6.0 

8.3 

3.3 

4.9 

16.7 

14.9 

13.7 

12.6 

10.1 10.3 

2017 

2018 

2019 

2020 

2021 

2019 

2020 

2021 

Reported

13.7 

11.4 

11.9 

2019 

2020 

2021 

Reported Net Revenue1   
by Geography 

Net Revenue1  (C$ billions) 

Net Income (C$ billions)

Reported / Adjusted

  Reported
 Adjusted1 

25.8 

8.7 

7.8 

23.5 

22.8 

6.2 

5.8 

5.1  5.2 

U.S. 
36% 

Other 
6% 

Canada 
58% 

Canadian
 P&C
 34% 

Reported Net Revenue1   
by Operating Group3 

BMO CM 
23% 

BMO WM
 22% 

U.S. P&C 
21% 

2019 

2020 

2021 

2019 

2020 

2021 

1   Net revenue and all adjusted measures are non-GAAP measures. For further information, see the Non-GAAP and 
Other Financial Measures section of Management’s Discussion and Analysis (“MD&A”). Regarding the composition 
of non-GAAP and other financial measures, including supplementary financial measures, refer to the Glossary of 
Financial Terms in the MD&A. 
2  The CET1 ratio is disclosed in accordance with OSFI’s Capital Adequacy Requirements (CAR) Guideline. 
3  Percentages determined excluding results in Corporate Services. 

Certain comparative figures have been reclassified to conform with the current year’s presentation. 

Bank of Montreal brands the organization’s member companies as BMO Financial Group. Note 26 of the financial 
statements lists the intercorporate relationships among Bank of Montreal and its significant subsidiaries. 

2  BMO Financial Group 204th Annual Report 2021 

 
  
 
 
   
2021 Highlights 

Business driven 

A clear 

BMO EMpower  

by purpose 

Four  years in a row on Ethisphere’s World’s 
Most Ethical Companies®; six years in a row  
on Bloomberg’s Gender-Equality Index. 

Leading the banking sector in 

sustainability 

BMO is one of only two North American 
banks on the Dow Jones Sustainability  
World  Index,  and Corporate Knights’ most  
sustainable bank in North America. 

Diversifying 

our senior leadership 

In the U.S., we’ve set a target of increasing  
representation of People of Color in senior  
roles to 30% – and we’re more than two-
thirds of the way there. 

ambition  

We’ve made a 
commitment to a 
sustainable future, 
including the ambition 
to be our clients’ lead 
partner in the transition  
to a net-zero world. 

Finance for a 

better 
society 

From leading the 
City of Toronto’s $100 
million Social Bond to 
acting as sole agent for  
Sandstorm Gold Royalties’  
sustainability-linked loan,  
we are Growing the Good  
in finance.  

US$5billion 

for minority opportunity 

By tackling barriers to financial 
inclusion, we’re creating 
opportunities for success among 
minority businesses, communities 
and families in the United States. 

Affordable 
housing 

We’ve earmarked $12 billion 
to finance housing that meets 
accredited affordable housing 
definitions across Canada – 
supporting CMHC’s aspiration that 
every Canadian be in a home they  
can afford by 2030. 

A 193-Year Dividend Record 
BMO Financial Group has the longest-running dividend payout record 
of any company in Canada, at 193 years. BMO common shares had 
an annual dividend yield of 3.2% at October 31, 2021. 

Compound annual growth rate 

4.3% 

BMO 15-year 

4.5% 

BMO 5-year 

Dividends declared 
($ per share) 

2.71 

2.80 

2.80 

2.80 

2.80 

2.26 

2.82 

2.94 

3.08 

3.24 

3.40 

3.56 

4.06 

3.78 

4.24 

4.24 

2006 

2007 

2008 

2009 

2010 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

2021 

BMO Financial Group 204th Annual Report 2021  3 

  
We are at a special 
moment in time. 

As our lives return to 
something more familiar, 
our generation has the 
chance to build something 
new. We can end barriers 
that hold others back. Turn 
inequity into opportunity. 
Exclusion into inclusion. 

At BMO, we are all coming 
together to ensure that 
as the world rebuilds, 
everyone benefits. 

Vlatka Puljic 
Ambassador, BMO Employee Giving 
Director, Project Management 
NA Business Banking 
Chicago, IL 

Photo: Jacob Hand Photography 

4  BMO Financial Group 204th Annual Report 2021 
4  BMO Financial Group 204th Annual Report 20
21 

 
 
 
 
 
 
 
 
 
 
  
 
  
 
 
 
 
 
 
 
CHAIR’S MESSAGE 

George A. Cope 

Chair of the Board 

RECENTLY, I CHAIRED A MEETING of your Board of Directors 
that was extraordinary for almost being ordinary. 

The directors met in person. 

Though we observed the COVID-19 protocols – vaccinations and 
testing, face coverings, physical distancing, frequent sanitizing – 
and met safely in the spacious auditorium at the BMO Institute  
For Learning, it was the first time in 18 months that we were all 
together, face to face. I was just completing my first full fiscal year 
as Chair and up to that point, since my appointment, all our 
meetings had been held virtually. 

I saw this as a marker of how far we had come and how our world 
had begun to recover from the pandemic. While it is clearly far from 
over, we regard the prospects for a strong economic recovery to be 
good, and that is good for our employees, and good for our customers. 
For some customers, however, we recognize that the recovery may 
take longer – but rest assured that, as we did during the worst days 
of the pandemic, we will be there to stand by BMO’s customers. 
This too is part of Boldly Growing the Good in business and life. 

Changing the way we work 

Much has changed in the past year, but perhaps most significant 
for BMO is the transformation in the way our customers choose  
to do business with us. Long before the pandemic, we had  
begun to establish the infrastructure to transform BMO into a 
Digital First bank and, while the transformation isn’t yet complete, 
it is certainly well advanced. The board is very pleased with the 
energy of the management team and their relentless focus on 
supporting our customers, changing the way we work, and 
accelerating the digital transformation – as Darryl spells out  
in his Message to Shareholders. 

significantly in the past year, and we can expect it will be  
ever-present as the world grapples with climate change and the 
massive transition that will be required of all of us. BMO’s ambition 
is to be our clients’ lead partner in the transition to a net-zero 
world, and the board is well positioned to oversee this priority. 

Adding strength to strength 

There were three important changes to the makeup of the Board 
of Directors in the past year. As I announced in last year’s Annual 
Report, one of our longest-serving directors, Ron Farmer, retired 
from the board at last year’s Annual Meeting. We continue to miss 
his wise counsel and good humour. 

At that same meeting, we welcomed two new directors to our 
boardroom: Madhu Ranganathan from OpenText Corporation,  
who brings not only more than 30 years of financial leadership, 
but also deep understanding of the role of technology in the 
workplace, which is so relevant to businesses today, and Stephen 
Dent, from Birch Hill Equity Partners, who has more than 30 years 
of experience in private equity and deep expertise in capital 
allocation, strategic planning, accounting and finance. Madhu  
and Steve have already proven to be excellent additions to our 
Board of Directors. 

Our 13-member board now comprises six women and seven men, 
in keeping with our commitment to maintain a gender-balanced 
board. In addition, as was the case last year, three of our four 
standing committees are chaired by women. I should also note 
that, as a reflection of our emphasis on competing vigorously on 
both sides of the border, we now have balanced representation  
on the board from both Canada and the United States – six of our 
directors are American and seven are Canadian. BMO generates 
about 40% of its earnings in the United States, which BMO continues 
to regard as a market with significant potential for growth. As it 
stands today, BMO is, by assets, the eighth largest bank on the 
continent, and our U.S. lines of business are the fastest-growing 
areas of the bank. 

BMO’s strategy is succeeding, and our performance last year 
reflects the strength of BMO’s greatest asset: its people. The 
winning culture that prevails at BMO, grounded in our shared 
Purpose, positions us well to achieve our bold ambitions. 

All of us on the board thank you, as shareholders, for the trust  
you have placed in us to represent your interests. Looking back  
on the past year, we are very satisfied with the bank’s financial 
results and the progress we have made to advance our commitment 
to attain a sustainable future. These are a testament to the hard 
work of our management team and our employees, and we thank 
all of them for another successful year. 

Our long-standing focus on sustainability – articulated when we 
first set out our Sustainability Principles – has strengthened 

George A. Cope 

BMO Financial Group 204th Annual Report 2021  5 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
A North 
American Bank 

Since 1818, when we opened our first agency in New York, BMO 
has embraced a North American view on our business and growth 
opportunities. Today, our businesses are unified in strategy, Purpose 
and brand, and we are the only bank that runs all of its operating 
groups on an integrated basis on both sides of the border, driving 
efficiencies, scale and speed to market. 

Fully integrated North American 
Treasury and Payments platform, 
delivering cross-border solutions. 

Digital deposit capabilities in all  
50 states. 

Refocusing the Wealth Management 
business for North American growth. 

Cloud-based architecture and 
technologies, adopted on a North 
American scale for our Transportation 
Finance business, have allowed us 
to innovate quickly, efficiently and 
often. The success of this approach 
is now being leveraged across our 
businesses. 

A culture of Growing the Good 
With 90% participation across the bank, 
employees pledged $23 million this 
past year in support of United Way 
and other charities. 

8th 

 largest 

bank in North America by assets. 

Top 10 
commercial lender  
in North America with an integrated 
platform and broad-based capabilities 
to accelerate the growth of BMO’s 
expertise and market presence in 
key regions. 

36% 

of revenue comes from our U.S. 
businesses, which represent BMO’s 
fastest-growing geographic segment. 
Over 50% of this revenue is from 
outside our core Midwest footprint. 

  BMO Tower  
790 N Water St, Milwaukee, Wisconsin 

Photo: Marty Peters Photography 

6  BMO Financial Group 204th Annual Report 2021 
6  BMO Financial Group 204th Annual Report 2021

 
 
 
 
 
 
 
  
 
 
 
CHIEF EXECUTIVE OFFICER’S MESSAGE 

Darryl White 

Chief Executive Officer 

WE’RE MOVING FORWARD  with energy and confidence  
as we continue to build our high-performing, digitally enabled, 
future-ready bank with leading efficiency, profitability and loyalty  
– all powered by a winning culture and driven by our Purpose. 

We’re optimistic about that future. Around the world, economies 
are reopening as safe and effective vaccines are steadily reaching 
populations, slowing the spread of COVID-19. As the communities 
we serve turn the corner from crisis to recovery, we’re focused on 
helping our customers regain momentum and make real financial 
progress. We’ve witnessed their resilience as they’ve adapted to 
meet the challenges the pandemic has brought. 

And now, the energy of the economic recovery brings with it an 
unprecedented opportunity to make progress. It’s a unique moment, 
and we can harness that energy to build a more equitable economy 
and a fairer world. Every day, our employees are active in their 
communities, supporting our customers through the recovery and 
beyond, with bold ambitions for the future inspired by our Purpose 
to Boldly Grow the Good in business and life for everyone. 

Consistent strength through headwinds 

To fulfill our Purpose, we need to be the strongest bank we can be. 
Strong and sustainable long-term financial performance drives  
our capability to grow the good. On this front, it has been an 
encouraging year. BMO’s superior risk management and strong 
capital position have strategically positioned us for the economic 
recovery in 2021. Despite the volatility caused by the pandemic and 
the extraordinary operational challenges it presented, we delivered 
very competitive performance. Our diversified business mix across 
personal and commercial banking, wealth management and capital 
markets enabled us to deliver solid, well-balanced results. And our 
ongoing investments in digital technology, product innovation and 
advisory capabilities contributed to enhanced customer loyalty. 

We took targeted actions to drive long-term profitability with  
a disciplined approach to expense management and capital 
allocation, and made meaningful investments to position  
BMO for future growth. We’re proud of our achievements in  
significantly improving our efficiency ratio, our return on equity 
and our positive operating leverage over the past three years. 
With continued outperformance in risk management and a  
CET1 Ratio of 13.7%, we are poised for growth and for increasing 
shareholder returns. 

The tapering of monetary support and fiscal stimulus intended  
to ease economic hardship is an encouraging sign of the  
economic rebound. The global economy has shown remarkable 
resilience in an evolving landscape of pandemic-related 
restrictions – and so have our customers. With vaccination rates 
climbing, the Canadian and U.S. economies are experiencing  
their strongest growth in decades. 

In Canada, small businesses – hardest hit by the pandemic – are 
expected to lead the next leg of the recovery. And by the fall  
of 2021, Canada had recovered the three million jobs lost in the 
spring of 2020, with women’s labour force participation growth 
leading the way; while the U.S. economy also saw job numbers 
rebound and unemployment rates continue to decline. 

In 2021, BMO’s U.S. footprint 
is no longer defined as the 
Midwest – it’s the U.S. 

Despite the optimism, growth has also been tempered by 
the pandemic’s effects on labour markets, global supply-chain 
disruptions and surging energy prices. Even with pent-up 
consumer demand and savings driving increased spending,  
many businesses are still struggling to get back to pre-pandemic 
levels of activity. However, as global economies show continued 
resilience, there is reason for optimism as we move forward. 

North American bank 

We have been steadily growing our presence in the United States 
since the acquisition of Harris Bank in 1984, with significant 
acceleration over the past decade. We’ve expanded the breadth  
of our commercial banking business on a national basis across 
13 industry verticals while opening offices in Atlanta, Fort Worth, 
Los Angeles, Denver and Orlando since 2019; all while growing to 
rank among the top 10 commercial banking lenders on a North 
American basis. We have grown our U.S. capital markets business 
revenue by 47% since 2019 and expanded our digital banking 
capabilities to serve customers in all 50 U.S. states. 

Adjusted results in this section are non-GAAP and are discussed in the Non-GAAP and Other Financial Measures section. 

BMO Financial Group 204th Annual Report 2021  7 

  
 
 
 
 
 
 
 
 
 
 
 
  
 
  
 
CHIEF EXECUTIVE OFFICER’S MESSAGE 

In 2021, our U.S. operating segment generated 36% of BMO’s revenue,  
with approximately half of that revenue originating outside the 
U.S. Midwest. Our U.S. operations are our fastest growing segment 
and are now generating returns and efficiency on par  with the rest 
of the bank, with the stage set for further growth as the economy  
rebounds. In 2021, BMO’s U.S. footprint is no longer defined as the 
Midwest – it’s the U.S. 

Digitally enabled 

BMO’s Digital First strategy enables greater integration between 
business and technology, helping us provide our customers greater  
convenience and take advantage of the benefits of digital scale. 
As an early adopter of technology and innovation in banking,  
we see digital as far more than a customer channel; it powers 
everything we do to meet our customers’ needs. We’re well into 
the next stage of digitalization across BMO, and it’s having a 
profound effect as an enabler of both growth and client loyalty. 

We’re embracing the future as a digital first bank, and we have 
aligned our solid technology foundation and significant technology  
investments with our digital agenda to drive efficiency, increase 
our speed to market and enhance the customer experience. This 
has led to faster customer growth, more secure data management,  
and the deployment of leading cloud, data and artificial 
intelligence capabilities. 

In a digital world, customers expect a simple, secure and 
convenient digital experience. We operate with speed and use 

data to deliver a personalized customer experience with  
easy-to-use tools and easy-to-access advice. We are well-recognized  
for our industry-leading customer innovations, such as BMO 
CashTrack, Online Banking for Business, BMO Payment Hub,  
and BMO adviceDirect. 

Our significant fintech and technology partnerships have helped  
us enhance our competitive position, navigate disruption and drive 
business outcomes. We are leveraging digital adoption to expand 
the markets we serve across our lines of business with integrated 
technology partnerships. Digital is how  we do business. 

While the future of banking is digital, a customer-centric approach 
is key as we continue to advance our advisory services and delivery  
channels for emerging North American open banking frameworks. 
We know that an approach that prioritizes security, transparency  
and customer control will enable all financial players to serve the 
full range of banking needs seamlessly. 

Purpose-driven: Growing the good 
across every aspect of ESG 

Our Purpose is why  we do business. We’re committed to creating  
a more inclusive and equitable society, especially for groups  
facing systemic barriers, including Black, Latinx and Indigenous 
colleagues, customers and communities. Last year  we announced 
BMO’s bold new diversity, equity and inclusion strategy, Zero 
Barriers to Inclusion 2025, making significant commitments  
to drive greater access to social and economic opportunities. 

Our purpose commitment 
to double the good 

For a thriving economy 
Increasing support for small businesses, 
and women entrepreneurs and 
Canadian Indigenous and military 
customers 

For a sustainable future 
Being our clients’ lead partner in 
the transition to a net-zero world, 
delivering on our commitments  
to sustainable financing and 
responsible investing 

For an inclusive society 

Committing to zero barriers to 
inclusion, supporting equal  
access to opportunities for our 
colleagues and customers, and  
the communities we serve 

BMO is building a high 
performance, digitally 
enabled bank that’s ready 
for the future. Anchored in 
our Purpose, we are driven 
by our strategic priorities 
for growth, strengthened 
by our approach to 
sustainability and guided 
by our values to build a 
foundation of trust with 
our stakeholders and 
achieve leading customer 
loyalty. 

See MD&A page 20 for a full description  
of our strategy. 

Our strategic priorities 

Our group strategic priorities align 
with and support our enterprise-
wide strategy, positioning us well 
to drive competitive performance. 

World-class client loyalty and 
growth 

Winning culture driven by 
alignment, empowerment and 
recognition 

Digital first for speed, efficiency 
and scale 

Simplify work and eliminate 
complexity 

Superior management of  risk  
and capital  performance 

8  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
  
 
 
 
 
 
 
Just one year in, we’ve made impressive progress, launching 
successful programs focused on increasing equity, including  
BMO EMpower – our US$5 billion five-year commitment aimed at 
breaking down barriers faced by minority businesses, communities 
and families in the United States. In Canada, we announced a 
$12 billion commitment to finance affordable housing over 
10 years, including support for financing affordable housing  
and infrastructure projects for Indigenous peoples, both on- and 
off-reserve. And we expanded BMO for Women – a dedicated 
enterprise-wide program that helps remove barriers to women’s 
empowerment, while promoting an inclusive market – to a  
North America scale. 

We take pride in serving as a leading catalyst for change. The 
challenge of climate change is one that impacts us all and gives 
urgency to our bold commitment to create a sustainable future. 
This past year, we declared our ambition to be our clients’ lead 
partner in the transition to a net-zero world and laid out the steps 
that will drive our financing activities and operations in support of 
this transition. We introduced the BMO Climate Institute – a new 
multi-disciplinary organization harnessing science and analytics, 
powered by innovative technology and industry-leading expertise. 
And reinforcing our commitment to finance the climate transition, 
we joined the Net-Zero Banking Alliance. Convened by the United 
Nations and including six of Canada’s largest banks, this alliance 
supports collaborative approaches between the public and private 
sectors to reach net zero by 2050. 

We are proud to be consistently recognized as a global leader in 
sustainability. Included in the Dow Jones Sustainability Index for 
16 years, we reached new heights in 2021 as one of only five 
companies in Canada – and only two North American banks – to  
be named to the DJSI World Index. In 2020, we were recognized  
by The Wall Street Journal as one of the 100 most sustainably 
managed companies in the world and the only bank ranked 
among the top 50. In addition, we have been named the most 
sustainable bank in North America by Corporate Knights for the 
past two years. This is sustainability in action, and this global 
recognition of our progress strengthens our resolve and confirms 
we are on the right path, enabling us to convene partners and 
drive solutions on the world stage. 

Future-ready 

We’re investing in businesses well-positioned for growth, the 
technologies that enable them, and the people who will deliver 
our market-leading financial advice. It’s all part of our ambition  
to foster a culture of winning and be the strongest, most 
competitive organization we can be. Our winning culture drives  
all of us at BMO to perform at our best; with greater alignment, 
empowerment and recognition than ever before. With culture 
fuelling our performance, it is also changing the way we work – 
and that will accelerate our progress for the long term. 

With a winning culture and a competitive employee value 
proposition, we are well positioned to attract and retain top talent 
in this environment. Our reputation as an employer of choice and 
our focus on the strategic development of our people earned  
BMO Harris Bank recognition as one of the World’s Best Employers 
of 2021 by Forbes magazine. We’re proud of our globally respected 
brand and our award-winning culture, which is inspiring our people 
to live our Purpose, while achieving their goals. 

Our reputation as an employer 
of choice earned BMO Harris 
Bank recognition as one of 
the World’s Best Employers 
of 2021 by Forbes magazine. 

Energized by our winning culture, we are building greater 
synergy and scale to deliver winning performance. Team BMO  
has modelled these behaviours throughout the pandemic, as we 
adapted the way we work to support our customers. Our front-line 
employees, and those who support them, have delivered exceptional 
service, while other teams adjusted to remote work and never 
stopped serving our customers and communities. 

In the face of challenging economic headwinds, we’ve maintained 
our commitment to help our customers make real financial progress 
and deliver on our purpose. As headwind becomes tailwind  
and we transition from a post-pandemic economic reopening to 
what comes next, we must use this moment to do our part to 
strengthen the financial lives of our customers and communities. 
By executing on our strategy and delivering the strong operational 
performance that leads to exceptional financial results, we will 
fuel our capability to grow the good for a thriving economy,  
a sustainable future, and a more inclusive society. 

Darryl White 

BMO Financial Group 204th Annual Report 2021  9 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
  
 
 
 
 
 
Net-Zero Ambition 

BMO’s commitment to climate action is long-standing. We understand the need to play 
our part in driving change, and we were one of the first banks in Canada to become carbon 
neutral in our operations. Our bold commitment to a sustainable future is embedded in 
our Purpose, and we are delivering on that commitment through the BMO Climate Institute 
and such initiatives as our sustainable finance strategy. Our ambition is clear and our 
course has been set. We aim to be our clients’ lead partner in the transition to a net-zero 
world, and we are targeting net zero financed emissions in our lending by 2050. 

BMO’s Net-Zero Ambition 
To be our clients’ lead partner in the transition to a net-zero world 

Commitment 

Capabilities 

Client Partnership 

Acting on our commitment 
to a sustainable future, 
we’re playing our part to 
drive the transformation 
toward a net-zero world. 
This means setting targets 
to reduce greenhouse 
gas emissions from our  
operations and financed 
emissions to advance the 
transition to a net-zero 
world by 2050 and being 
transparent on our progress. 

The BMO Climate Institute 
provides thought leadership 
at the intersection of climate 
adaptation and finance. We’re 
leveraging our sophisticated 
analytical capabilities to 
understand the impacts 
of climate change and 
generate data-driven insights 
that enable our business, 
customers and partners to 
adjust and flourish. 

Across BMO’s operating 
groups, we’re putting 
customers at the centre 
of our strategy, offering 
a tailored suite of green 
advisory, investment and 
lending products and 
services to support their  
transition to a net-zero 
global economy. 

Convening for 
Climate Action 

As a global leader, BMO 
is driving insights and 
bringing together industry, 
government, researchers 
and investors to catalyze 
the climate conversation, 
collaborate on solutions and 
accelerate a socially and 
economically just net-zero 
transition. 

10  BMO Financial Group 204th Annual Report 2021 
10  BMO Financial Group 204th Annual Report 2021

 
 
 
 
 
 
Energy Transition Group 
BMO’s new Energy Transition Group 
helps clients achieve decarbonization by 
providing advisory and financing solutions 
for business and the broader economy in 
the drive to net zero. 

Carbon neutral for 
more than a decade 
BMO first achieved net zero emissions in 
our operations in 2010 – one of the first 
banks in Canada to do so. 

Setting meaningful targets 
We have set a new target to reduce 
greenhouse gas emissions from our 
operations by 30% by 2030, compared to 
a 2019 baseline. This target builds on our 
commitment since 2020 to match 100% 
of the electricity we use globally with 
purchases of renewable electricity. 

United Nations Sustainable 
Development Goals (SDGs) 
BMO became one of the first major  
Canadian banks to sign the UN Principles 
for Responsible Banking (PRB) in  
February 2021 – a key initiative of the 
United Nations Environment Programme 
Finance Initiative (UNEP-FI) that 
accelerates progress on SDGs in the 
banking sector. 

Global Asset Management 
leadership 
As a member of the Net Zero Asset 
Managers initiative, BMO Global Asset 
Management is committed to support 
investing aligned with net zero emissions 
by 2050 or sooner. 

Environmental and 
social risk management 
We serve as North American representative 
on the Equator Principles Association 
Steering Committee and we chair the 
Cross-Sector Biodiversity Initiative, 
advancing strong environmental and social 
risk management practices across the 
financial sector and broader economy. 

Mapping a 
transparent path 
We have targeted net zero financed 
emissions in our lending by 2050 and 
will be establishing intermediate targets 
for 2030, applying the sophisticated 
methodologies of the Partnership 
for Carbon Accounting Financials and 
Net-Zero Banking Alliance. 

Thought leadership 
for climate leadership 
In 2021, BMO’s Sustainability Leaders 
podcast won Gold at the annual 
International Business Awards and 
the American Business Awards. Our 
podcasts are shaping the sustainability 
conversation, especially with a 
younger audience: our largest listener 
demographics are the 28-34 and 35-44 
age groups. 

BMO Financial Group 204th Annual Report 2021  11 
BMO Financial Group 204th Annual Report 2021 11

    
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
Digital First 

BMO is future-ready. Our Digital First strategy is built for speed, efficiency 
and scale, responding to the growth in demand for banking services 
that meet customers where they are. Our significant investment enables 
BMO to provide customers with simple, digital, personalized experiences 
that put them in control. Yet digital isn’t just a channel. It’s the way we 
operate every part of the business, driving loyalty, growth and efficiency, 
enabling our employees to provide insightful service and freeing up 
more time for them to do what they do best: give expert advice. 

Active Mobile Users (000’s) 

Canada 

1,835 

1,599 

+37% 

U.S.

2,183 

2,014 

+78% 

572 

507

464 

322 

2018 

2019 

2020 

2021 

2018 

2019 

2020 

2021 

12  BMO Financial Group 204th Annual Report 2021 
12  BMO Financial Group 204th Annual Report 2021

 
 
 
 
 
 
 
 
Digital First is about 
our customers. 

Digital First drives loyalty, 
efficiency and growth. 

•  Our investments in digital are 

focused on meeting customers 
where they are with simple, 
digital experiences that meet their 
needs. We drive progress through 
continuous improvement and 
value driven innovation. 

-

•  We use data and analytics to offer 
a seamless and secure digital 
experience, underpinned by 
best-in-class personal financial advice. 

•  We are recognized for our 

innovation – through capabilities 
like BMO Insights, which helps our 
customers achieve real financial 
progress, BMO Online Banking for 
Business and BMO Payment Hub – and 
our online brokerage BMO InvestorLine 
continues to be a market leader. 

•  We are relentlessly driving 

simplification, personalization, 
and speed by providing real-time 
information through our North 
American commercial banking 
platforms. By helping clients 
automate their processes, we let 
them spend more time running 
their businesses. 

•   BMO Business Xpress, which is now  
available to customers on both sides 
of the border, uses data analytics and 
best-in-class automatic adjudication 
strategies to reduce in-branch account 
opening to a matter of minutes. Blend, 
a cloud banking software firm, has 
helped reposition our U.S. mortgage 
business to be more profitable and 
contributed to improving efficiency   
in U.S. P&C Banking. 

•   We continue to drive self -service 

capabilities and access to real-time 
information through our  API Developer  
Platform and our single, North American  
digital platform, supported by a state -
of -the -art payment infrastructure. And 
BMO InvestorLine’s new adviceDirect 
Preview assists online investors by  
providing free access to investing 
resources and features that enhance 
our offer. 

•   By investing significantly in security, 
people and platforms, BMO is able to 
grow across businesses and throughout 
North America. 

•   A smaller physical footprint, combined 
with marketing outside our core area, 
creates efficiencies and the opportunity  
to expand our share of wallet. We are 
now able to serve customers in all 50 
U.S. states. 

Digital First is not just 
about systems. It’s how 
we do business. 

•   We operate digitally. From internal 

processes to client interfaces, 
digital shapes everything we do. 
It drives efficiencies and speed to 
market, freeing up time for our  
employees to provide advice and 
create meaningful relationships.

•   We are harnessing data and artificial
intelligence to deliver even more
personalized experiences. By 
leveraging analytics, we can deliver  
a more seamlessly integrated value 
proposition to our customers. 

•   BMO is a leader in advancing the

way business customers make and
receive payments, providing more
options for risk-managed, real-time,
data-enriched transactions. We are
transforming clearing and settlement,
adding real-time payment systems –
such as Canadian Real-Time Rail and 
FedNow – and adopting ISO 20022 
data formatting for a better customer  
experience. 

BMO Financial Group 204th Annual Report 2021  13 
BMO Financial Group 204th Annual Report 2021 13

60%10%JUN30%  
 
 
 
 
  
  
 
  
 
 
 
  
Our Bold Commitments 

BMO’s Purpose drives everything we do. It shapes our business strategies, 
product development, customer relationships and community engagement. 
From laying down the path to net zero emissions to breaking down the 
barriers to economic inclusion, we recognize that social progress and our 
progress are inextricably linked. 

Tamara Littlelight, Branch Manager, Greater Calgary Market and 
Chief Roy Whitney Onespot, Tsuut’ina Nation at the Tsuut’ina Trail 

-

Photo: Daniel Wood 

14  BMO Financial Group 204th Annual Report 2021 
14  BMO Financial Group 204th Annual Report 2021

 
 
 
 
   
 
 
For a 

For a 

For an 

Thriving Economy 

Sustainable Future 

Inclusive Society 

We are leveraging our expertise to 
support different communities with 
tailored initiatives, knowing that 
when they flourish, we flourish. 

BMO has set measurable targets for 
driving climate-change solutions and 
sustainable outcomes, and we are 
leading the conversation on how to 
get there. 

Our continued commitment to a 
more inclusive society is creating 
opportunities for all, and ensuring 
that we reflect the communities 
that sustain us. 

$8 billion in 
Indigenous banking 
We committed to doubling our book 
of Indigenous business to $8 billion by 
2025. By the fall of this year we had 
already reached $6.4 billion – 80% of 
the way there. 

Support for 
Small Business 
We supported Canadian businesses 
throughout the pandemic and in their 
recovery. This resulted in over 54,000 
approved CEBA and HASCAP applications 
putting over $1.3B into the hands of 
entrepreneurs in need of financial relief. 

Serving those who serve 
We’ve set ourselves a target of 
doubling the number of Canadian 
defence community customers by 2025, 
to 100,000. In 2021 we served 81,100 
men and women who serve us. 

Grants for progress 
We expanded our BMO Celebrating 
Women Grant Program, empowering 
women with $200,000 in grants for 
projects that contribute to social, 
environmental and/or economic 
sustainability outcomes. 

Catalyzing climate action 
In March of this year, we launched the 
BMO Climate Institute, a forum that 
will bring together science, analytics, 
expertise and partners to understand 
and manage the financial risks and 
opportunities related to climate change. 
The Institute will be a resource for all 
– business, government, academia – in 
unlocking climate solutions. 

$300 billion for 
sustainable outcomes 
We are well on our way to achieving BMO’s 
2025 goal of mobilizing $300 billion in 
capital for clients pursuing sustainable 
outcomes, through sustainable lending, 
underwriting, and investment and 
advisory services. 

$250 million 

The $250 million BMO Impact 
Investment Fund is aimed at driving 
more sustainable outcomes by 
backing technologies that will help 
BMO and its clients proactively 
address sustainability and create 
positive impact for their stakeholders. 

Zero barriers to inclusion 
We’ve increased access to capital, 
educational resources and partnerships 
for Black and Latinx entrepreneurs. Forty 
percent of our student opportunities 
are directed to BIPOC youth. Over the 
past year, we doubled our hiring of 
Indigenous staff. Colleagues, customers 
and communities are all benefiting from 
our Zero Barriers to Inclusion 2025 
strategy. 

$600,000 

Our Community Giving has always 
been carefully shaped by intention. 
In 2021, we committed $600,000 to 
advance Truth and Reconciliation in 
Canada, working with Indigenous 
partners to move our whole society 
along the road to greater social justice. 

Women in 
senior leadership 
For the last six years, more than 40% 
of our senior leaders have been women. 

BMO Financial Group 204th Annual Report 2021  15 
BMO Financial Group 204th Annual Report 2021 15

    
 
 
 
 
 
  
 
 
  
  
 
 
 
 
 
 
 
  
 
 
 
 
  
  
 
 
 
 
 
 
 Board of Directors1 

Janice M. Babiak, CPA (US),  
CA (UK), CISM, CISA  
Corporate Director  
Board/Committees:  
Audit and Conduct Review (Chair), 
Governance and Nominating 
Director since: 2012 

Sophie Brochu, C.M.  
President and Chief Executive Officer,  
Hydro-Québec 
Board/Committees:  
Governance and Nominating,  
Human Resources  
Director since: 2011 

Craig W. Broderick 
Corporate Director  
Board/Committees:  
Governance and Nominating,  
Risk Review (Chair) 
Director since: 2018 

George A. Cope, C.M.  
Board/Committees:  
Board Chair, 
Governance and Nominating,  
Human Resources  
Director since: 2006 

Stephen Dent 
Managing Director and Co-Founder, 
Birch Hill Equity Partners 
Board/Committees:  
Risk Review  
Director since: 2021 

Christine A. Edwards  
Corporate Director  
Board/Committees:  
Governance and Nominating (Chair),  
Human Resources  
Director since: 2010 

Dr. Martin S. Eichenbaum  
Charles Moskos Professor of  
Economics, Northwestern University  
Board/Committees:  
Audit and Conduct Review,  
Risk Review   
Director since: 2015 

David Harquail 
Chair of the Board, 
Franco-Nevada Corporation 
Board/Committees:  
Audit and Conduct Review,  
Risk Review 
Director since: 2018 

Linda S. Huber  
Chief Financial Officer,  
FactSet Research Systems Inc. 
Board/Committees:  
Audit and Conduct Review,  
Risk Review  
Director since: 2017 

Lorraine Mitchelmore  
Corporate Director 
Board/Committees:  
Governance and Nominating, 
Human Resources (Chair),  
Risk Review  
Director since: 2015 

Madhu Ranganathan  
Executive Vice-President  
and Chief Financial Officer, 
OpenText Corporation 
Board/Committees:  
Audit and Conduct Review  
Director since: 2021  

Eric R. La Flèche   
President and Chief Executive Officer, 
Metro Inc. 
Board/Committees:  
Human Resources 
Director since: 2012 

Darryl White   
Chief Executive Officer, 
BMO Financial Group 
Board/Committees:  
Attends all committee meetings  
as an invitee 
Director since: 2017 

 Executive Committee1 

Darryl White  
Chief Executive Officer,  
BMO Financial Group 

Daniel Barclay  
Group Head,  
BMO Capital Markets 

David Casper  
Chief Executive Officer,  
BMO Financial Corp.  
and Group Head,  
North American  
Commercial Banking 

Patrick Cronin  
Chief Risk Officer,  
BMO Financial Group 

Cameron Fowler  
Chief Strategy and  
Operations Officer, 
BMO Financial Group 

Sharon Haward-Laird  
General Counsel,  
BMO Financial Group 

Ernie (Erminia) Johannson  
Group Head,  
North American Personal  
and Business Banking 

Deland Kamanga  
Group Head,  
BMO Wealth Management 

Mona Malone  
Head, 
People & Culture and Chief  
Human Resources Officer,   
BMO Financial Group 

Steve Tennyson  
Chief Technology   
and Operations Officer, 
BMO Financial Group 

Tayfun Tuzun  
Chief Financial Officer,  
BMO Financial Group 

1  As at November 1, 2021. 

16  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Enhanced Disclosure Task Force 
On October 29, 2012, the Enhanced Disclosure Task Force (EDTF) of the Financial Stability Board published its first report, Enhancing the Risk 
Disclosures of Banks. We support the recommendations issued by EDTF for the provision of high-quality, transparent risk disclosures. 

Disclosures related to the EDTF recommendations are detailed in the index below, as presented in this 2021 Annual Report, the Supplemental 
Financial Information (SFI) or Supplemental Regulatory Capital Information (SRC). Information within the SFI or SRC is not, and should not be 
considered incorporated by reference into this 2021 Annual Report. 

Topic 

EDTF Disclosure 

Annual Report 

Page Number 
SFI 

SRC 

General 

1.  Present all risk-related information in each report, providing an index for 

easy navigation 

74-113 

Index 

Index 

Risk Governance, 
Risk Management & 
Business Model 

Capital Adequacy and 
Risk-Weighted Assets 
(RWA) 

2.  Define the bank’s risk terminology and risk measures and present key 

parameters used 

3.  Discuss top and emerging risks for the bank 
4.  Outline plans to meet new key regulatory ratios once the applicable rules 

84-113,136-138 
74-76 

are finalized 

5.  Summarize the bank’s risk management organization, processes, and key 

functions 

6.  Describe the bank’s risk culture and procedures applied to support the culture 
7.  Describe key risks that arise from the bank’s business model and activities 
8.  Describe the use of stress testing within the bank’s risk governance and 

capital frameworks 

9.  Provide minimum Pillar 1 capital requirements 
10.  Summarize information contained in the composition of capital templates 

and reconciliation of the accounting balance sheet to the regulatory balance 
sheet 
•  A Main Features template can also be found on BMO’s website at 
www.bmo.com under Investor Relations and Regulatory Filings 
11.  Present a flow statement of movements in regulatory capital, including 
changes in Common Equity Tier 1, Additional Tier 1, and Tier 2 capital 
12.  Discuss capital planning within a more general discussion of management’s 

strategic planning 

13.  Provide granular information to explain how RWA relate to business activities 
14.  Present a table showing the capital requirements for each method used for 

calculating RWA 

15.  Tabulate credit risk in the banking book for Basel asset classes and major 

portfolios 

67 

78-83 
83 
81 

82 

66-69 

69 

65 
69-70 
69-70, 
84-87 

16.  Present a flow statement that reconciles movements in RWA by credit risk 

and market risk 

17.  Describe the bank’s Basel validation and back-testing process. Included in 

our SRC information is our estimated and actual loss parameter information 

108 

18.  Describe how the bank manages its potential liquidity needs and the liquidity 

reserve held to meet those needs 

97-103 

19.  Summarize encumbered and unencumbered assets in a table by balance 

sheet category 

99 

38 

Liquidity 

Funding 

M
D
&
A

3-4,10 

3-5 

6 

11 
11,17,18,21-30, 
37-43 

17-30,37-43 

31,57 

58-62 

20.  Tabulate consolidated total assets, liabilities and off-balance sheet 

commitments by remaining contractual maturity 

21.  Discuss the bank’s sources of funding and describe the bank’s funding 

strategy 

Market Risk 

22.  Provide a breakdown of balance sheet positions into trading and non-trading 

market risk measures 

23.  Provide qualitative and quantitative breakdowns of significant trading and 

non-trading market risk measures 

24.  Describe significant market risk measurement model validation procedures 
and back-testing and how these are used to enhance the parameters of the 
model 

25.  Describe the primary risk management techniques employed by the bank 
to measure and assess the risk of loss beyond reported risk measures 

26.  Provide information about the bank’s credit risk profile 
27.  Describe the bank’s policies related to impaired loans and renegotiated loans 
28.  Provide reconciliations of impaired loans and the allowance for credit losses 
29.  Provide a quantitative and qualitative analysis of the bank’s counterparty 

credit risk that arises from its derivative transactions 

30.  Provide a discussion of credit risk mitigation 

Credit Risk 

Other Risks 

31.  Describe other risks and discuss how each is identified, governed, measured 

and managed 

32.  Discuss publicly known risk events related to other risks, where material or 

potentially material loss events have occurred 

104-105 

100-101 

96 

92-96 

92-95,108 

92-93 

84-91,160-166 
161,166 
88-89,164 

84-85,91 
84-85, 
171,177,205 

78-82, 
106-113 
106-113 

23-35 

11-56 

35-48 

16,32,44 

BMO Financial Group 204th Annual Report 2021  17 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Management’s Discussion and Analysis 

BMO’s Chief Executive Officer and Chief Financial Officer have signed a statement outlining management’s responsibility for financial information 
in the annual consolidated financial statements and Management’s Discussion and Analysis (MD&A). The statement also explains the roles of the 
Audit and Conduct Review Committee and Board of Directors in respect of that financial information. 

The MD&A comments on our operations and financial condition for the years ended October 31, 2021 and 2020. The MD&A should be read in 

conjunction with the consolidated financial statements for the year ended October 31, 2021. The MD&A commentary is as at December 3, 2021. 
Unless otherwise indicated, all amounts are stated in Canadian dollars and have been derived from consolidated financial statements prepared in 
accordance with International Financial Reporting Standards (IFRS) as issued by the International Accounting Standards Board. We also comply with 
interpretations of IFRS by our regulator, the Office of the Superintendent of Financial Institutions Canada. References to generally accepted accounting 
principles (GAAP) mean IFRS. 

Effective the first quarter of 2020, we adopted IFRS 16, Leases, recognizing the cumulative effect of adoption in opening retained earnings 
with no changes to prior periods. Certain prior-period results and measures have been reclassified for methodology changes and transfers of certain 
businesses between operating groups. 

A
&
D
M

Index 

19  Caution Regarding Forward-Looking Statements 

58  Review of Fourth Quarter 2021 Performance 

20  About BMO 

59  Summary Quarterly Earnings Trends 

21  Financial Objectives and Value Measures 

61  2020 Financial Performance Review 

23  Supporting a Sustainable and Inclusive Future 

24  Financial Highlights 

25  Non-GAAP and Other Financial Measures 

29  Economic Developments and Outlook 

30  2021 Financial Performance Review 

Summary 
Personal and Commercial Banking 

38  2021 Operating Groups Performance Review 
38 
39 
40 
44 
48 
52 
56 

Canadian Personal and Commercial Banking 
U.S. Personal and Commercial Banking 

BMO Wealth Management 
BMO Capital Markets 
Corporate Services, including Technology and Operations 

63  Financial Condition Review 
63 
65 
72 

Summary Balance Sheet 
Enterprise-Wide Capital Management 
Off-Balance Sheet Arrangements 

74  Enterprise-Wide Risk Management 

114  Accounting Matters and Disclosure and Internal Control 
114 
119 
119 
119 
120 
121 

Critical Accounting Estimates 
Changes in Accounting Policies in 2021 
Future Changes in Accounting Policies 
Transactions with Related Parties 
Shareholders’ Auditors’ Services and Fees 
Management’s Annual Report on Disclosure Controls and Procedures 
and Internal Control over Financial Reporting 

122  Supplemental Information 

136  Glossary of Financial Terms 

Regulatory Filings 
BMO’s continuous disclosure materials, including our interim consolidated financial statements and interim MD&A, audited annual consolidated financial statements and 
annual MD&A, Annual Information Form and Notice of Annual Meeting of Shareholders and Management Proxy Circular, are available on our website at www.bmo.com/ 
investorrelations, on the Canadian Securities Administrators’ website at www.sedar.com and on the EDGAR section of the U.S. Securities and Exchange Commission’s (SEC) 
website at www.sec.gov. BMO’s Chief Executive Officer and Chief Financial Officer certify the appropriateness and fairness of BMO’s annual and interim consolidated 
financial statements, MD&A and Annual Information Form, the effectiveness of BMO’s disclosure controls and procedures and the effectiveness of, and any material 
weaknesses relating to, BMO’s internal control over financial reporting. Information contained in or otherwise accessible through our website (www.bmo.com), or any 
third-party websites mentioned herein, does not form part of this document. 

Caution 
The About BMO, Financial Objectives and Value Measures, and Economic Developments and Outlook sections contain certain forward-looking statements. By their 
nature, forward-looking statements require us to make assumptions and are subject to inherent risks and uncertainties. Refer to the Caution Regarding Forward-Looking 
Statements for a discussion of such risks and uncertainties and the material factors and assumptions related to the statements set forth in such sections. 

18  BMO Financial Group 204th Annual Report 2021 

 
Factors That May Affect Future Results 
As noted in the following Caution Regarding Forward-Looking Statements, all forward-looking statements and information, by their nature, are 
subject to inherent risks and uncertainties, both general and specific, which may cause actual results to differ materially from the expectations 
expressed in any forward-looking statement. The Enterprise-Wide Risk Management section describes a number of risks, including credit and 
counterparty, market, insurance, liquidity and funding, operational non-financial, legal and regulatory, strategic, environmental and social, and 
reputation risk. Should our risk management framework prove ineffective, there could be a material adverse impact on our financial position 
and results. 

Caution Regarding Forward-Looking Statements 
Bank of Montreal’s public communications often include written or oral forward-looking statements. Statements of this type are included in this document, and may be 
included in other filings with Canadian securities regulators or the U.S. Securities and Exchange Commission, or in other communications. All such statements are made 
pursuant to the “safe harbor” provisions of, and are intended to be forward-looking statements under, the United States Private Securities Litigation Reform Act of 1995 
and any applicable Canadian securities legislation. Forward-looking statements in this document may include, but are not limited to, statements with respect to our 
objectives and priorities for fiscal 2022 and beyond, our strategies or future actions, our targets and commitments (including with respect to net zero emissions), 
expectations for our financial condition, capital position or share price, the regulatory environment in which we operate, the results of, or outlook for, our operations or for 
the Canadian, U.S. and international economies, and the COVID-19 pandemic, and include statements made by our management. Forward-looking statements are typically 
identified by words such as “will”, “would”, “should”, “believe”, “expect”, “anticipate”, “project”, “intend”, “estimate”, “plan”, “goal”, “commit”, “target”, “may”, “might”, 
“schedule”, “forecast” and “could” or negative or grammatical variations thereof. 

By their nature, forward-looking statements require us to make assumptions and are subject to inherent risks and uncertainties, both general and specific in nature. 

There is significant risk that predictions, forecasts, conclusions or projections will not prove to be accurate, that our assumptions may not be correct, and that actual results 
may differ materially from such predictions, forecasts, conclusions or projections. The uncertainty created by the COVID-19 pandemic has heightened this risk, given the 
increased challenge in making assumptions, predictions, forecasts, conclusions or projections. We caution readers of this document not to place undue reliance on our 
forward-looking statements, as a number of factors – many of which are beyond our control and the effects of which can be difficult to predict – could cause actual future 
results, conditions, actions or events to differ materially from the targets, expectations, estimates or intentions expressed in the forward-looking statements. 

The future outcomes that relate to forward-looking statements may be influenced by many factors, including, but not limited to: general economic and market 
conditions in the countries in which we operate, including labour challenges; the severity, duration and spread of the COVID-19 pandemic, and possibly other outbreaks 
of disease or illness, and its impact on local, national or international economies, as well as its heightening of certain risks that may affect our future results; information, 
privacy and cyber security, including the threat of data breaches, hacking, identity theft and corporate espionage, as well as the possibility of denial of service resulting 
from efforts targeted at causing system failure and service disruption; benchmark interest rate reforms; technological changes and technology resiliency; political 
conditions, including changes relating to, or affecting, economic or trade matters; climate change and other environmental and social risk; the Canadian housing market 
and consumer leverage; inflationary pressures; global supply-chain disruptions; changes in monetary, fiscal, or economic policy; changes in laws, including tax legislation 
and interpretation, or in supervisory expectations or requirements, including capital, interest rate and liquidity requirements and guidance, and the effect of such changes 
on funding costs; weak, volatile or illiquid capital or credit markets; the level of competition in the geographic and business areas in which we operate; judicial or 
regulatory proceedings; the accuracy and completeness of the information we obtain with respect to our customers and counterparties; failure of third parties to comply 
with their obligations to us; our ability to execute our strategic plans and to complete proposed acquisitions or dispositions, including obtaining regulatory approvals; 
critical accounting estimates and the effects of changes to accounting standards, rules and interpretations on these estimates; operational and infrastructure risks, 
including with respect to reliance on third parties; changes to our credit ratings; global capital markets activities; the possible effects on our business of war or terrorist 
activities; natural disasters and disruptions to public infrastructure, such as transportation, communications, power or water supply; and our ability to anticipate and 
effectively manage risks arising from all of the foregoing factors. 

We caution that the foregoing list is not exhaustive of all possible factors. Other factors and risks could adversely affect our results. For more information, please 
refer to the discussion in the Risks That May Affect Future Results section, and the sections related to credit and counterparty, market, insurance, liquidity and funding, 
operational non-financial, legal and regulatory, strategic, environmental and social, and reputation risk, in the Enterprise-Wide Risk Management section, all of which 
outline certain key factors and risks that may affect our future results. Investors and others should carefully consider these factors and risks, as well as other uncertainties 
and potential events, and the inherent uncertainty of forward-looking statements. We do not undertake to update any forward-looking statements, whether written or 
oral, that may be made from time to time by the organization or on its behalf, except as required by law. The forward-looking information contained in this document is 
presented for the purpose of assisting shareholders and analysts in understanding our financial position as at and for the periods ended on the dates presented, as well as 
our strategic priorities and objectives, and may not be appropriate for other purposes. 

Material economic assumptions underlying the forward-looking statements contained in this document are set out in the Economic Developments and Outlook 

section, as well as in the Allowance for Credit Losses section. Assumptions about the performance of the Canadian and U.S. economies, as well as overall market 
conditions and their combined effect on our business, are material factors we consider when determining our strategic priorities, objectives and expectations for our 
business. In determining our expectations for economic growth, we primarily consider historical economic data, past relationships between economic and financial 
variables, changes in government policies, and the risks to the domestic and global economy. 

M
D
&
A

BMO Financial Group 204th Annual Report 2021  19 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

About BMO 

Established in 1817, BMO Financial Group (BMO, Bank of Montreal, the bank, we, our, us) is a highly diversified provider of financial products and 
services based in North America. We are the eighth largest bank in North America by assets, with total assets of $988.2 billion. Our employees are 
engaged, our workforce is diverse, and our culture is award-winning. BMO provides a broad range of personal and commercial banking, wealth 
management, global markets and investment banking products and services, conducting business through three operating groups: Personal and 
Commercial Banking, BMO Wealth Management and BMO Capital Markets. We serve eight million customers across Canada through our Canadian 
personal and commercial banking segment, BMO Bank of Montreal. In the United States, we serve more than two million personal, business and 
commercial banking customers nationally through BMO Harris Bank, based in the U.S. Midwest. We also serve customers through our wealth 
management businesses – BMO Private Wealth, BMO InvestorLine, BMO Wealth Management U.S., BMO Global Asset Management and 
BMO Insurance. BMO Capital Markets provides a full suite of financial products and services to North American and international corporate, 
institutional and government clients through its Investment and Corporate Banking and Global Markets divisions. 

A
&
D
M

At BMO, we continue to build a high-performance, digitally-enabled, future-ready bank. Anchored in our Purpose, we are driven by our strategic 

priorities for growth, strengthened by our approach to sustainability, and guided by our values to build a foundation of trust with our stakeholders 
and achieve leading customer loyalty. 

Our Purpose: Boldly Grow the Good in business and life 
BMO has a deep sense of purpose – to be a champion for progress and a catalyst for change. We are leveraging our position as a leading financial 
services provider to create opportunities for our communities and our stakeholders to make positive, sustainable change, in the belief that success 
can and must be mutual. Our bold commitments for a sustainable future, a thriving economy and an inclusive society are reflected in our active direct 
response to today’s most pressing challenges. 
•  Thriving economy – Increasing support for small businesses, women entrepreneurs and Canadian Indigenous and military customers. 
•  Sustainable future – Being our clients’ lead partner in the transition to a net zero world, delivering on our commitments to sustainable 

financing and responsible investing. 

• 

Inclusive society – Working toward zero barriers to inclusion, supporting equal access to opportunities for our colleagues, customers and the 
communities we serve. 

Our Strategic Priorities 

Consistent strong performance is essential to achieving our Purpose. We aim to deliver top-tier total shareholder return and achieve our financial 
objectives by aligning our operations with, and executing on, our strategic priorities: 
•  World-class client loyalty and growth 
•  Winning culture driven by alignment, empowerment and recognition 
•  Digital first for speed, efficiency and scale 
•  Simplify work and eliminate complexity 
•  Superior management of risk and capital performance. 

Our group strategic priorities align with and support our enterprise-wide strategy, positioning us well to drive competitive performance. The group 
strategies are outlined in the 2021 Operating Groups Performance Review. 

Our Approach to Sustainability 

Our commitment to sustainability is embedded in our strategy and is fundamental to our Purpose. We identify the most significant effects of our 
business operations, products and services on our stakeholders and the communities in which we operate. We take steps to manage our business in a 
manner that is consistent with our sustainability objectives, and we consider the interests of our stakeholders. We apply a variety of ESG practices to 
capture opportunities and manage risks in key areas such as sustainable finance, climate change, human rights, and diversity, equity and inclusion. 

Our Values 

Four core values shape our culture and underpin our choices and actions: 
• 
Integrity – Do what is right 
•  Diversity – Learn from difference 
•  Responsibility – Make tomorrow better 
•  Empathy – Put others first. 

20  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
M
D
&
A

Financial Objectives and Value Measures 

Results and measures in this section are presented on a reported and an adjusted basis, and management considers both to be useful in assessing 
our performance. It permits readers to assess the impact of certain specified items on results for the periods presented, and to better assess results, 
excluding those items that may not be reflective of ongoing business performance. 

Adjusted results and measures in this section, including earnings per share (EPS), EPS growth, return on equity (ROE), return on tangible common 
equity (ROTCE), net income, revenue, non-interest expense, efficiency ratio and operating leverage, are non-GAAP amounts, measures and ratios, and 
are discussed in the Non-GAAP and Other Financial Measures section. 

We also present reported and adjusted revenue on a basis that is net of insurance claims, commissions and changes in policy benefit liabilities 

(CCPB), and we calculate our efficiency ratio and operating leverage on a similar basis. Insurance revenue can experience variability arising from 
fluctuations in the fair value of insurance assets, caused by movements in interest rates and equity markets, that is largely offset in CCPB. Presenting 
our revenue, efficiency ratio and operating leverage on a net basis allows for a better assessment of operating results. 

Measures and ratios on a net revenue basis are non-GAAP. For more information on CCPB, refer to the Non-GAAP and Other Financial Measures 

section. Information regarding the composition of each of these measures is also provided in the Glossary of Financial Terms. 

Financial Objectives 
BMO’s business planning process is rigorous, sets ambitious goals and considers prevailing economic conditions, our risk appetite, our customers’ 
evolving needs and the opportunities available across our lines of business. It includes clear and direct accountability for annual performance that is  
measured against both internal and external benchmarks and our progress toward our strategic priorities. 

We have established medium-term financial objectives for certain important performance measures, which are set out below. Medium-term is 

generally defined as three to five years, and performance is measured on an adjusted basis. We aim to deliver top-tier total shareholder return 
and achieve our financial objectives by aligning our operations with, and executing on, our strategic priorities. We consider top-tier returns to be 
top-quartile shareholder returns, relative to our Canadian banking peer group. 

These objectives serve as guideposts as we execute on our strategic priorities, and they assume a normal business environment. Our ability to 
meet these objectives in any single period may be adversely affected by extraordinary developments, such as the impacts of the COVID-19 pandemic. 
We recognize that in managing our operations and our exposure to risk, current profitability and our ability to meet these objectives in a single period 
must be balanced with the need to invest in our businesses for long-term sustainability and future growth. 

Our financial objectives and our performance against these objectives are outlined in the table below and described in the sections that follow. 

BMO’s financial results in 2021 reflected continued execution on our strategic priorities, as well as improving economic conditions. Performance in 
fiscal 2020 reflected the negative impacts of the COVID-19 pandemic, including elevated provisions for credit losses. 

Financial Objectives and Metrics 

Financial objectives (adjusted) 

Reported basis 

Adjusted basis (1) 

As at and for the periods ended October 31, 2021 

1-year 

3-year (2) 

5-year (2) 

1-year 

3-year (2) 

5-year (2) 

Total shareholder return (%) 
Earnings per share growth (%) 
Average return on equity (%) 
Net operating leverage (%) (3) 
Common Equity Tier 1 Ratio (%) 

Top-tier 
7-10% 
15% or more 
2% or more 
Exceed regulatory requirement 

75.9 
53.3 
14.9 
0.4 
13.7 

15.7 
12.3 
12.5 
1.4 
na 

14.0 
10.8 
12.8 
2.1 
na 

na 
68.0 
16.7 
6.1 
na 

na 
13.0 
13.5 
3.2 
na 

na 
11.5 
13.8 
2.6 
na 

(1)  Adjusted results and measures in this table are non-GAAP measures and are discussed in the Non-GAAP and Other Financial Measures section. 
(2)  The 3-year and 5-year EPS growth rate and net operating leverage reflect compound annual growth rates (CAGR). 
(3)  Net operating leverage on a reported and adjusted basis presented in this table are non-GAAP measures and are discussed in the Non-GAAP and Other Financial Measures section. 

na – not applicable 

Total Shareholder Return 
The average annual total shareholder return (TSR) is a key measure of shareholder value, and over time, we expect that execution on our strategic 
priorities will drive value creation for our shareholders. The one-year, three-year and five-year average annual TSR was 75.9%, 15.7% and 14.0%, 
respectively, all above our Canadian peer group average (excluding BMO) of 56.1%, 15.3% and 13.6%, respectively. 

The table below summarizes dividends paid on BMO’s common shares over the past five years and the movements in our share price. 
An investment of $1,000 in BMO common shares made at the beginning of fiscal 2017 would have been worth $1,924 as at October 31, 2021, 
assuming reinvestment of dividends, for a total return of 92.4%. 

Dividends declared per common share in fiscal 2021 totalled $4.24, unchanged from the prior year, as the Office of the Superintendent of 

Financial Institutions’ (OSFI’s) restriction on dividend increases by federally regulated financial institutions effective March 13, 2020, remained in place 
throughout the year and was removed effective November 4, 2021. Dividends paid over a five-year period have increased at an average annual 
compound rate of approximately 5%. 

The average annual total shareholder return (TSR) represents the average annual total return earned on an investment in BMO common shares 
made at the beginning of a fixed period. The return includes the change in share price and assumes dividends received were reinvested in 
additional common shares. 

BMO Financial Group 204th Annual Report 2021  21 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Total Shareholder Return 

For the year ended October 31 

2021 

2020 

2019 

2018 

Closing market price per common share ($) 
Dividends paid ($ per share) 
Dividend yield (%) 
Increase (decrease) in share price (%) 
Total annual shareholder return (%) (2) 

134.37 
4.24 
3.2 
69.4 
75.9 

79.33 
4.21 
5.3 
(18.6) 
(14.6) 

97.50 
3.99 
4.2 
(0.9) 
3.2 

98.43 
3.72 
3.8 
(0.4) 
3.3 

2017 

98.83 
3.52 
3.6 
15.8 
20.2 

3-year 
CAGR (1) 

5-year 
CAGR (1) 

10.9 
4.5 
nm 
nm 
15.7 

9.5 
4.8 
nm 
nm 
14.0 

(1)  Compound annual growth rate (CAGR) expressed as a percentage. 
(2)  Total annual shareholder return assumes reinvestment of quarterly dividends and therefore does not equal the sum of dividend and share price returns in the table. 

nm – not meaningful 

A
&
D
M

Earnings per Share Growth 
The year-over-year percentage change in earnings per share (EPS) and in adjusted EPS are our key measures for 
analyzing earnings growth. All references to EPS are to diluted EPS, unless otherwise indicated. 

EPS was $11.58, an increase of $4.03 or 53% from $7.55 in 2020. Adjusted EPS was $12.96, an increase of 
$5.25 or 68% from $7.71 in 2020. The increase in EPS primarily reflected higher earnings. Reported net income 
available to common shareholders increased 55% year-over-year, while the average number of diluted common 
shares outstanding increased 1%. 

Earnings per share (EPS) is calculated by dividing net income, after deducting preferred share dividends and 
distributions on other equity instruments, by the average number of common shares outstanding. Adjusted EPS 
is calculated in the same manner using adjusted net income. Diluted EPS, which is BMO’s basis for measuring 
performance, adjusts for possible conversions of financial instruments into common shares if those conversions 
would reduce EPS, and is more fully explained in Note 23 of the consolidated financial statements. 

Return on Equity 
Reported return on equity (ROE) was 14.9% in 2021 and adjusted ROE was 16.7%, compared with 10.1% and 
10.3%, respectively, in 2020. Reported and adjusted ROE increased due to higher net income, partially offset by 
growth in common equity. There was an increase of $2,660 million or 55% in reported net income available to 
common shareholders and an increase of $3,453 million or 70% in adjusted net income available to common 
shareholders in the current year. Average common shareholders’ equity increased $2.2 billion or 5% from 2020, 
primarily due to growth in retained earnings, partially offset by a decrease in accumulated other comprehensive 
income. The reported return on tangible common equity (ROTCE) was 17.0%, compared with 11.9% in 2020, and 
adjusted ROTCE was 18.9%, compared with 11.9% in 2020. Book value per share increased 4% from the prior 
year to $80.18, reflecting the increase in shareholders’ equity. 

Return on common shareholders’ equity (ROE) is calculated as net income, less preferred dividends and 
distributions on other equity instruments, as a percentage of average common shareholders’ equity. Common 
shareholders’ equity comprises common share capital, contributed surplus, accumulated other comprehensive 
income (loss) and retained earnings. Adjusted ROE is calculated using adjusted net income rather than net 
income. 

Return on tangible common equity (ROTCE) is calculated as net income available to common shareholders, 
adjusted for the amortization of acquisition-related intangible assets, as a percentage of average tangible 
common equity. Tangible common equity is calculated as common shareholders’ equity, less goodwill and 
acquisition-related intangible assets, net of related deferred tax liabilities. Adjusted ROTCE is calculated using 
adjusted net income rather than net income. 

EPS ($)

12.96 

11.58 

9.43

8.66

7.55 7.71 

2019 

2020 

2021 

Reported EPS 

Adjusted EPS 

ROE (%) 

13.7 

12.6 

16.7 

14.9 

10.1 10.3 

2019 

2020 

2021 

Reported ROE 

Adjusted ROE 

ROTCE (%) 

16.1 

15.1 

18.9 

17.0 

11.9 11.9 

2019 

2020 

2021 

Reported ROTCE 

Adjusted ROTCE 

22  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Efficiency Ratio and Operating Leverage 
BMO’s reported gross efficiency ratio was 57.0%, compared with 56.3% in 2020. The adjusted gross efficiency 
ratio was 53.6%, compared with 55.8% in 2020. On a net revenue basis (1), the reported efficiency ratio 
was 60.1%, compared with 60.4% in 2020, and the adjusted efficiency ratio was 56.5%, compared with 59.8% 
in 2020, an improvement of 330 basis points. 

Reported operating leverage was negative 1.5%. On a net revenue basis, reported operating leverage was 

positive 0.4%, and adjusted operating leverage was positive 6.1%. 

(1)  This ratio is calculated using revenue and non-interest expense. Refer to the Revenue section and the Non-Interest Expense section. 

Operating leverage is the difference between revenue and non-interest expense growth rates. 

Operating leverage, net of insurance claims, commissions and changes in policy benefit liabilities 
(CCPB), is the difference between net revenue and non-interest expense growth rates, with net revenue 
comprising revenue excluding CCPB. 

Adjusted net operating leverage is the difference between adjusted revenue, net of adjusted CCPB, and 
adjusted non-interest expense growth rates. The bank evaluates performance using adjusted revenue, net of 
CCPB. 

Efficiency ratio (or expense-to-revenue ratio) is a measure of productivity. It is calculated as non-interest 
expense divided by total revenue (on a taxable equivalent basis in the operating groups), expressed as a 
percentage. 

Efficiency ratio, net of CCPB, is calculated as non-interest expense divided by total revenue, net of CCPB 
(on a taxable equivalent basis in the operating groups), expressed as a percentage. 

Adjusted net efficiency ratio is calculated in the same manner as efficiency ratio, net of CCPB, utilizing 
adjusted revenue, net of adjusted CCPB, and adjusted non-interest expense. 

Common Equity Tier 1 Ratio 
Our Common Equity Tier 1 Ratio was 13.7% as at October 31, 2021, compared with 11.9% as at October 31, 2020. 
The CET1 Ratio increased from the end of fiscal 2020, primarily driven by strong internal capital generation. 

Common Equity Tier 1 (CET1) Ratio is calculated as CET1 capital, which comprises common shareholders’ 
equity, net of deductions for goodwill, intangible assets, pension assets, certain deferred tax assets and other 
items (which may include a portion of expected credit loss provisions), divided by risk-weighted assets. 
The CET1 Ratio is disclosed in accordance with OSFI’s Capital Adequacy Requirements (CAR) Guideline. 

M
D
&
A

Net Efficiency Ratio (%) 

64.2 

61.4 

60.4 

59.8 

60.1 

56.5 

2019 

2020 

2021 

Reported Net Efficiency Ratio 
Adjusted Net Efficiency Ratio 

Net Operating Leverage (%) 

6.2 

6.1 

2.7 

0.8 

0.4 

(2.9) 

2019 

2020 

2021 

Reported Net Operating Leverage 
Adjusted Net Operating Leverage 

CET1 Ratio (%) 

13.7 

11.4 

11.9

2019 

2020 

2021 

Supporting a Sustainable and Inclusive Future 

At BMO, we have a long-standing commitment to support a sustainable future, a thriving economy and an inclusive society, and we are acting on this 
commitment with purpose. In support of our customers, communities and employees, we recently: 
• Deployed more than US$2 billion in loans and investments as part of BMO EMpowerTM, a five-year, US$5 billion commitment to advance an 

inclusive economic recovery and address key barriers faced by minority businesses, communities and families in the United States.

• Assisted customers experiencing financial hardship caused by the COVID-19 pandemic, including facilitating access to relief programs introduced by 
the Canadian and U.S. governments, such as the Canada Emergency Business Account (CEBA) program, the Highly Affected Sector Credit Availability 
Program (HASCAP) and the Trade Expansion Lending Program (TELP) in Canada, and the Paycheck Protection Program (PPP) in the United States.

• Announced a 10-year, $12 billion commitment to finance affordable housing in Canada.
• Released Wîcihitowin

, our first annual Indigenous Partnerships and Progress Report, highlighting the partnership with Indigenous 

communities and BMO’s Indigenous Advisory Council to further education, employment and economic empowerment. 

• Declared our Climate Ambition, which is to be our clients’ lead partner in the transition to a net zero world; launched the BMO Climate Institute to
provide insights and best practices for climate solutions; joined the Net-Zero Banking Alliance; and established a new, innovative Energy Transition
Group.

•

• Ranked among the most sustainable companies on the Dow Jones Sustainability Indices (DJSI) – one of only five companies in Canada included in
the DJSI World Index, earning the highest score in Corporate Governance, Customer Relationship Management, Financial Inclusion, Environmental
Reporting and Social Reporting.
In addition, in 2021 we were:
• Named to Canada’s Best 50 Corporate Citizens Ranking by Corporate Knights
• Recognized as one of the World’s Most Ethical Companies for the fourth consecutive year by the Ethisphere Institute
• Recognized for the sixth consecutive year on the Bloomberg Gender-Equality Index.

BMO Financial Group 204th Annual Report 2021  23 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Financial Highlights 

(Canadian $ in millions, except as noted) 

Summary Income Statement (1) 
Net interest income 
Non-interest revenue 

Revenue 
Insurance claims, commissions and changes in policy benefit liabilities (CCPB) 

Revenue, net of CCPB (2) 

Provision for credit losses on impaired loans 
Provision for (recovery of) credit losses on performing loans 

Total provision for credit losses (PCL) 
Non-interest expense 
Provision for income taxes 

A
&
D
M

Net income 

Adjusted net income 

Common Share Data ($, except as noted) (1) 
Basic earnings per share 
Diluted earnings per share 
Adjusted diluted earnings per share 
Dividends declared per share 
Book value per share 
Closing share price 
Number of common shares outstanding (in millions) 

End of period 
Average basic 
Average diluted 

Market capitalization ($ billions) 
Dividend yield (%) 
Dividend payout ratio (%) 
Adjusted dividend payout ratio (%) 

Financial Measures and Ratios (%) (1) 
Return on equity 
Adjusted return on equity 
Return on tangible common equity 
Adjusted return on tangible common equity 
Efficiency ratio, net of CCPB 
Adjusted efficiency ratio, net of CCPB 
Operating leverage, net of CCPB 
Adjusted operating leverage, net of CCPB 
Net interest margin on average earning assets 
Effective tax rate 
Adjusted effective tax rate 
Total PCL-to-average net loans and acceptances 
PCL on impaired loans-to-average net loans and acceptances 
Liquidity coverage ratio (LCR) (3) 
Net stable funding ratio (NSFR) (3) 

Balance Sheet and Other Information (as at $ millions, except as noted) 
Assets 
Average earning assets 
Gross loans and acceptances 
Net loans and acceptances 
Deposits 
Common shareholders’ equity 
Total risk-weighted assets (4) 
Assets under administration 
Assets under management 

Capital Ratios (%) (4) 
Common Equity Tier 1 Ratio 
Tier 1 Capital Ratio 
Total Capital Ratio 
Leverage Ratio 

Foreign Exchange Rates ($) 
As at Canadian/U.S. dollar 
Average Canadian/U.S. dollar 

2021 

2020 

2019 

14,310 
12,876 

27,186 
1,399 

25,787 

525 
(505) 

20 
15,509 
2,504 

7,754 

8,651 

11.60 
11.58 
12.96 
4.24 
80.18 
134.37 

648.1 
647.2 
648.7 
87.1 
3.2 
36.5 
32.6 

14.9 
16.7 
17.0 
18.9 
60.1 
56.5 
0.4 
6.1 
1.59 
24.4 
22.7 
– 
0.11 
125 
118 

988,175 
897,302 
474,847 
472,283 
685,631 
51,965 
325,433 
634,713 
523,270 

13.7 
15.4 
17.6 
5.1 

13,971 
11,215 

25,186 
1,708 

23,478 

1,522 
1,431 

2,953 
14,177 
1,251 

5,097 

5,201 

7.56 
7.55 
7.71 
4.24 
77.40 
79.33 

645.9 
641.4 
642.1 
51.2 
5.3 
56.1 
54.9 

10.1 
10.3 
11.9 
11.9 
60.4 
59.8 
6.2 
2.7 
1.64 
19.7 
19.8 
0.63 
0.33 
131 
na 

949,261 
853,336 
464,216 
460,913 
659,034 
49,995 
336,607 
653,319 
482,554 

11.9 
13.6 
16.2 
4.8 

12,888 
12,595 

25,483 
2,709 

22,774 

751 
121 

872 
14,630 
1,514 

5,758 

6,249 

8.68 
8.66 
9.43 
4.06 
71.54 
97.50 

639.2 
638.9 
640.4 
62.3 
4.2 
46.8 
43.0 

12.6 
13.7 
15.1 
16.1 
64.2 
61.4 
(2.9) 
0.8 
1.70 
20.8 
21.1 
0.20 
0.17 
138 
na 

852,195 
759,395 
452,427 
450,577 
568,143 
45,728 
317,029 
632,193 
471,160 

11.4 
13.0 
15.2 
4.3 

1.2376 
1.2554 

1.3319 
1.3441 

1.3165 
1.3290 

(1)  Adjusted results remove certain items from reported results and are used to calculate our adjusted measures as presented in the above table. Management assesses performance on a reported basis 
and an adjusted basis, and considers both to be useful. Revenue, net of CCPB, and adjusted results, measures and ratios in this table are non-GAAP. For further information, refer to the Non-GAAP and 
Other Financial Measures section and for a composition of non-GAAP amounts, measures and ratios, as well as supplementary financial measures, refer to the Glossary of Financial Terms. 

(2)  We present revenue, efficiency ratio and operating leverage on a basis that is net of CCPB, which reduces the variability in insurance revenue from changes in fair value that are largely offset by 

changes in the fair value of policy benefit liabilities, the impact of which is reflected in CCPB. 

(3)  LCR and NSFR are disclosed in accordance with OSFI’s Liquidity Adequacy Requirements (LAR) Guideline, as applicable. 
(4)  Capital ratios and risk-weighted assets are disclosed in accordance with OSFI’s Capital Adequacy Requirements (CAR) Guideline, as applicable. 
na – not applicable 

24  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Non-GAAP and Other Financial Measures 

Results and measures in this document are presented on a GAAP basis. Unless otherwise indicated, all amounts are in Canadian dollars and have been 
derived from our audited annual consolidated financial statements prepared in accordance with International Financial Reporting Standards (IFRS). 
References to GAAP mean IFRS. We use a number of financial measures to assess our performance, as well as the performance of our operating 
businesses, including measures and ratios that are presented on a non-GAAP basis, as described below. We believe that these non-GAAP amounts, 
measures and ratios, read together with our GAAP results, provide readers with a better understanding of how management assesses results. 
Non-GAAP amounts, measures and ratios do not have standardized meanings under GAAP. They are unlikely to be comparable to similar 

measures presented by other companies and should not be viewed in isolation from, or as a substitute for, GAAP results. 

For further information regarding the composition of non-GAAP and other financial measures, including supplementary financial measures, 

refer to the Glossary of Financial terms. 

Our non-GAAP measures broadly fall into the following categories: 

Adjusted measures and ratios 
Management considers both reported and adjusted results and measures useful in assessing underlying ongoing business performance. Adjusted 
results and measures remove certain specified items from revenue, non-interest expense and income taxes, as detailed in the following table. 
Adjusted results and measures presented in this document are non-GAAP. Presenting results on both a reported basis and an adjusted basis permits 
readers to assess the impact of certain items on results for the periods presented, and to better assess results excluding those items that may not 
be reflective of ongoing business performance. As such, the presentation may facilitate readers’ analysis of trends. Except as otherwise noted, 
management’s discussion of changes in reported results in this document applies equally to changes in the corresponding adjusted results. 

M
D
&
A

Measures net of insurance claims, commissions and changes in policy benefit liabilities (CCPB) 
We also present reported and adjusted revenue on a basis that is net of insurance claims, commissions and changes in policy benefit liabilities (CCPB), 
and our efficiency ratio and operating leverage are calculated on a similar basis, as reconciled in the Revenue section. Measures and ratios presented 
on a basis net of CCPB are non-GAAP. Insurance revenue can experience variability arising from fluctuations in the fair value of insurance assets, 
caused by movements in interest rates and equity markets. The investments that support policy benefit liabilities are predominantly fixed income 
assets recorded at fair value, with changes in fair value recorded in insurance revenue in the Consolidated Statement of Income. These fair value 
changes are largely offset by changes in the fair value of policy benefit liabilities, the impact of which is reflected in CCPB. The presentation and 
discussion of revenue, efficiency ratios and operating leverage on a net basis reduces this variability, which allows for a better assessment of 
operating results. For more information, refer to the Insurance Claims, Commissions and Changes in Policy Benefit Liabilities section. 

Presenting results on a taxable equivalent basis (teb) 
We analyze consolidated revenue on a reported basis. In addition, we analyze revenue on a taxable equivalent basis (teb) at the operating group 
level, consistent with the Canadian peer group. Revenue and the provision for income taxes in BMO Capital Markets and U.S. P&C are increased on 
tax-exempt securities to an equivalent pre-tax basis. These adjustments are offset in Corporate Services. Presenting results on a teb basis reflects how 
our operating groups manage their business and is useful to facilitate comparisons of income between taxable and tax-exempt sources. The effective 
tax rate is also analyzed on a teb basis for consistency of approach, with the offset to operating segment adjustments recorded in Corporate Services. 

Tangible common equity and return on tangible common equity 
Tangible common equity is calculated as common shareholders’ equity less goodwill and acquisition-related intangible assets, net of related deferred 
tax liabilities. Return on tangible common equity is commonly used in the North American banking industry and is meaningful because it measures 
the performance of businesses consistently, whether they were acquired or developed organically. 

Presenting results on a U.S. dollar basis 
Results and measures that exclude the impact of Canadian/U.S. dollar exchange rate movements on BMO’s U.S. segment are non-GAAP. Refer to the 
Foreign Exchange section for a discussion of the effects of changes in exchange rates on our results. 

We present our U.S. P&C business results, as well as select U.S. segment information for the bank, BMO Wealth Management, BMO Capital 

Markets and Corporate Services, on a U.S. dollar basis. Presenting these results on a U.S. dollar basis is useful in assessing the underlying performance 
without the variability caused by changes in foreign exchange rates. 

BMO Financial Group 204th Annual Report 2021  25 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Non-GAAP and Other Financial Measures 

(Canadian $ in millions, except as noted) 

Reported Results 
Revenue 
Insurance claims, commissions and changes in policy benefit liabilities (CCPB) 

Revenue, net of CCPB 
Provision for credit losses 
Non-interest expense 

Income before income taxes 
Provision for income taxes 

Net Income 
Diluted EPS ($) 

A
&
D
M

Adjusting Items Impacting Revenue (Pre-tax) 
Impact of divestitures (1) 

Adjusting Items Impacting CCPB (Pre-tax) 
Reinsurance adjustment (2) 

Adjusting Items Impacting Non-Interest Expense (Pre-tax) 
Acquisition integration costs (3) 
Amortization of acquisition-related intangible assets (4) 
Impact of divestitures (1) 
Restructuring (costs) reversals (5) 

Impact of adjusting items on non-interest expense (pre-tax) 

Impact of adjusting items on reported net income (pre-tax) 

Adjusting Items Impacting Revenue (After-tax) 
Impact of divestitures (1) 

Adjusting Items Impacting CCPB (After-tax) 
Reinsurance adjustment (2) 

Adjusting Items Impacting Non-Interest Expense (After-tax) 
Acquisition integration costs (3) 
Amortization of acquisition-related intangible assets (4) 
Impact of divestitures (1) 
Restructuring (costs) reversals (5) 

Impact of adjusting items on non-interest expense (after-tax) 

Impact of adjusting items on reported net income (after-tax) 

Impact on diluted EPS ($) 

Adjusted Results 
Revenue 
Insurance claims, commissions and changes in policy benefit liabilities (CCPB) 

Revenue, net of CCPB 
Provision for credit losses 
Non-interest expense 

Income before income taxes 
Provision for income taxes 

Net Income 
Diluted EPS ($) 

2021 

2020 

2019 

27,186 
(1,399) 

25,787 
(20) 
(15,509) 

10,258 
(2,504) 

7,754 
11.58 

25,186 
(1,708) 

23,478 
(2,953) 
(14,177) 

6,348 
(1,251) 

5,097 
7.55 

25,483 
(2,709) 

22,774 
(872) 
(14,630) 

7,272 
(1,514) 

5,758 
8.66 

29 

– 

(9) 
(88) 
(886) 
24 

(959) 

(930) 

22 

– 

(7) 
(66) 
(864) 
18 

(919) 

(897) 

(1.38) 

–

– 

(14) 
(121) 
–
– 

(135) 

(135) 

–

– 

(11) 
(93) 
–
– 

(104) 

(104) 

(0.16) 

– 

(25) 

(13) 
(128) 
– 
(484) 

(625) 

(650) 

– 

(25) 

(10) 
(99) 
– 
(357) 

(466) 

(491) 

(0.77) 

27,157 
(1,399) 

25,758 
(20) 
(14,550) 

11,188 
(2,537) 

8,651 
12.96 

25,186 
(1,708) 

23,478 
(2,953) 
(14,042) 

6,483 
(1,282) 

5,201 
7.71 

25,483 
(2,684) 

22,799 
(872) 
(14,005) 

7,922 
(1,673) 

6,249 
9.43 

(1)  Fiscal 2021 reported net income included a $779 million pre-tax and after-tax write-down of goodwill related to the sale of our EMEA Asset Management business recorded in non-interest expense, 
a $22 million ($29 million pre-tax) net gain on the sale of our Private Banking business in Hong Kong and Singapore recorded in non-interest revenue, and $85 million ($107 million pre-tax) of 
divestiture-related costs for both transactions recorded in non-interest expense. 

(2)  Fiscal 2019 reported net income included a reinsurance adjustment of $25 million (pre-tax and after-tax) in claims, commissions and changes in policy benefit liabilities for the net impact of major 

reinsurance claims incurred after the announced wind-down of the reinsurance business. This reinsurance adjustment is included in BMO Wealth Management. 

(3)  Acquisition integration costs related to KGS-Alpha and Clearpool are recorded in non-interest expense in BMO Capital Markets. 
(4)  Amortization of acquisition-related intangible assets is recorded in non-interest expense in the related operating group. 
(5)  Fiscal 2019 reported net income included a $357 million ($484 million pre-tax) restructuring charge related to severance and a small amount of real estate-related costs. Fiscal 2021 reported net income 

included a partial reversal of restructuring charges related to severance of $18 million ($24 million pre-tax). Restructuring charges and the reversal were recorded in non-interest expense in Corporate Services. 

Certain comparative figures have been reclassified to conform with the current year’s presentation. 

26  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Summary of Reported and Adjusted Results by Operating Segment 

(Canadian $ in millions, except as noted) 

Canadian P&C 

U.S. P&C 

Total P&C 

BMO Wealth 
Management 

BMO Capital 
Markets 

Corporate 
Services 

Total Bank 

U.S. Segment (1) 
(US$ in millions) 

2021 
Reported net income (loss) 

Acquisition integration costs (2) 
Amortization of acquisition-related 

intangible assets (3) 
Impact of divestitures (4) 
Restructuring costs (reversals) (5) 

Adjusted net income (loss) 

2020 
Reported net income (loss) 

Acquisition integration costs (2) 
Amortization of acquisition-related 

intangible assets (3) 

Adjusted net income (loss) 

2019 
Reported net income (loss) 

Acquisition integration costs (2) 
Amortization of acquisition-related 

intangible assets (3) 

Restructuring costs (reversals) (5) 
Reinsurance adjustment (6) 

3,237 
– 

2,189 
– 

5,426 
– 

1,474 
– 

2,140 
7 

(1,286) 
– 

7,754 
7 

1 
– 
– 

24 
– 
– 

25 
– 
– 

24 
– 
– 

17 
– 
– 

– 
842 
(18) 

66 
842 
(18) 

2,593 
6 

37 
27 
(13) 

3,238 

2,213 

5,451 

1,498 

2,164 

(462) 

8,651 

2,650 

2,027 
–

1,277 
 –

3,304 
  –

1,096 
–

1,087 
 11

(390) 
  –

5,097 
 11

2 

39 

41 

34 

18 

– 

93 

2,029 

1,316 

3,345 

1,130 

1,116 

(390) 

5,201 

2,624 
–

1,611 
 –

4,235 
  –

2 
– 
–

43 
– 
 –

45 
– 
  –

1,059 
–

37 
– 
  25

1,121 

1,091 
 10

(627) 
  –

5,758 
 10

17 
– 
  –

– 
357 
  –

99 
357 
 25

M
D
&
A

1,163 
8

49 

1,220 

1,432 
7

53 
– 
86

Adjusted net income (loss) 

2,626 

1,654 

4,280 

1,118 

(270) 

6,249 

1,578 

(1)  U.S. segment results presented in U.S. dollars are non-GAAP amounts. 
(2)  KGS-Alpha and Clearpool pre-tax acquisition integration costs of $9 million in fiscal 2021, $14 million in fiscal 2020 and $13 million in fiscal 2019 are recorded in non-interest expense in BMO Capital 

Markets. 

(3)  Amortization of acquisition-related intangible assets is recorded in non-interest expense in the related operating group. Canadian P&C recorded pre-tax amounts of $2 million in each of fiscal 2021, 
fiscal 2020 and fiscal 2019. U.S. P&C recorded pre-tax amounts of $33 million in fiscal 2021, $53 million in fiscal 2020 and $57 million in fiscal 2019. BMO Wealth Management recorded pre-tax 
amounts of $31 million in fiscal 2021, $43 million in fiscal 2020 and $47 million in fiscal 2019. BMO Capital Markets recorded pre-tax amounts of $22 million in fiscal 2021, $23 million in fiscal 2020 
and $22 million in fiscal 2019. 

(4)  Fiscal 2021 reported net income included a $779 million pre-tax and after-tax write-down of goodwill related to the sale of our EMEA Asset Management business recorded in non-interest expense, 
a $22 million ($29 million pre-tax) net gain on the sale of our Private Banking business in Hong Kong and Singapore recorded in non-interest revenue, and $85 million ($107 million pre-tax) of 
divestiture-related costs for both transactions recorded in non-interest expense. 

(5)  Fiscal 2019 reported net income included a $357 million ($484 million pre-tax) restructuring charge related to severance and a small amount of real estate-related costs. Fiscal 2021 reported net 
income included a partial reversal of restructuring charges related to severance of $18 million ($24 million pre-tax). Restructuring charges and reversal were recorded in non-interest expense in 
Corporate Services. 

(6)  Fiscal 2019 reported net income included a reinsurance adjustment of $25 million (pre-tax and after-tax) in claims, commissions and changes in policy benefit liabilities for the net impact of major 

reinsurance claims incurred after the announced wind-down of the reinsurance business. This reinsurance adjustment is included in BMO Wealth Management. 

Net Revenue, Efficiency Ratio and Operating Leverage 

(Canadian $ in millions, except as noted) 
For the year ended October 31 

Reported 
Revenue 
CCPB 
Revenue, net of CCPB 
Non-interest expense 

Efficiency ratio (%) 

Efficiency ratio, net of CCPB (%) 

Revenue growth (%) 
Revenue growth, net of CCPB (%) 
Non-interest expense growth (%) 

Operating leverage (%) 

Operating leverage, net of CCPB (%) 

Adjusted (1) 
Revenue 
Impact of adjusting items on revenue 
Impact of adjusting items on CCPB 
CCPB 
Revenue, net of CCPB 
Impact of adjusting items on non-interest expense 
Non-interest expense 

Efficiency ratio (%) 

Efficiency ratio, net of CCPB (%) 

Revenue growth, net of CCPB (%) 
Non-interest expense growth (%) 
Operating leverage, net of CCPB (%) 

(1)  Refer to footnotes (1) to (5) in the Non-GAAP and Other Financial Measures table for adjusting items. 

2021 

2020 

2019 

27,186 
1,399 
25,787 
15,509 

57.0 

60.1 

7.9 
9.8 
9.4 

(1.5) 

0.4 

27,157 
(29) 
– 
1,399 
25,758 
(959) 
14,550 

53.6 

56.5 

9.7 
3.6 
6.1 

25,186 
1,708 
23,478 
14,177 

56.3 

60.4 

(1.2) 
3.1 
(3.1) 

1.9 

6.2 

25,186 
– 
–
1,708 
23,478 
(135) 
14,042 

55.8 

59.8 

3.0 
0.3 
2.7 

25,483 
2,709 
22,774 
14,630 

57.4 

64.2 

11.3 
5.7 
8.6 

2.7 

(2.9) 

25,483 
– 
 25
2,684 
22,799 
(625) 
14,005 

55.0 

61.4 

5.8 
5.0 
0.8 

BMO Financial Group 204th Annual Report 2021  27 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Return on Equity and Return on Tangible Common Equity 

(Canadian $ in millions, except as noted) 
For the year ended October 31 

Reported net income 
Dividends on preferred shares and distributions on other equity instruments 

Net income available to common shareholders (A) 
After-tax amortization of acquisition-related intangible assets 

Net income available to common shareholders after adjusting for amortization of acquisition-related intangible assets (B) 
After-tax impact of other adjusting items (1) (2) (3) (4) 

Adjusted net income available to common shareholders (C) 
Average common shareholders’ equity (D) 

Return on equity (%) (= A/D) 
Adjusted return on equity (%) (= C/D) 

Average tangible common equity (E) (5) 

Return on tangible common equity (%) (= B/E) 
Adjusted return on tangible common equity (%) (= C/E) 

A
&
D
M

2021 

2020 

2019 

7,754 
(244) 

7,510 
66 

7,576 
831 

8,407 
50,451 

14.9 
16.7 

5,097 
(247) 

4,850 
93 

4,943 
11 

4,954 
48,235 

10.1 
10.3 

5,758 
(211) 

5,547 
99 

5,646 
392 

6,038 
44,170 

12.6 
13.7 

44,505 

41,484 

37,456 

17.0 
18.9 

11.9 
11.9 

15.1 
16.1

(1)  Fiscal 2021 reported net income included a $779 million pre-tax and after-tax write-down of goodwill related to the sale of our EMEA Asset Management business recorded in non-interest expense, a 

$22 million ($29 million pre-tax) net gain on the sale of our Private Banking business in Hong Kong and Singapore recorded in non-interest revenue, and $85 million ($107 million pre-tax) of 
divestiture-related costs for both transactions recorded in non-interest expense. 

(2)  Fiscal 2019 reported net income included a $357 million ($484 million pre-tax) restructuring charge related to severance and a small amount of real estate-related costs. Fiscal 2021 reported net 

income included a partial reversal of restructuring charges related to severance of $18 million ($24 million pre-tax). Restructuring charges and the reversal were recorded in non-interest expense in 
Corporate Services. 

(3)  Acquisition integration costs related to KGS-Alpha and Clearpool are recorded in non-interest expense in BMO Capital Markets. 
(4)  Amortization of acquisition-related intangible assets is recorded in non-interest expense in the related operating group. 
(5)  Common shareholders’ equity (D above) adjusted for goodwill of $5,836 million ($6,530 million in 2020 and $6,417 million in 2019) and acquisition-related intangible assets of $381 million 

($495 million in 2020 and $573 million in 2019), net of related deferred tax liabilities of $271 million ($274 million in 2020 and $276 million in 2019). 

Capital is allocated to the operating segments based on the amount of regulatory capital required to support business activities. Unallocated capital is 
reported in Corporate Services. Capital allocation methodologies are reviewed annually. 

Return on Equity by Operating Segment 

(Canadian $ in millions, except as noted) 

Canadian P&C 

U.S. P&C 

Total P&C 

2021 

2020 

2019 

BMO Wealth 
Management 

BMO Capital 
Markets 

Corporate 
Services 

Total Bank 

Total Bank 

Total Bank 

Reported 
Net income available to common shareholders 
Total average common equity 

Return on equity (%) 

Adjusted 
Net income available to common shareholders 
Total average common equity 

Return on equity (%) 

na – not applicable 

3,195 

2,150 
11,147  13,522 

5,345 
24,669 

28.7 

15.9 

21.7 

3,196 

2,174 
11,147  13,522 

5,370 
24,669 

28.7 

16.1 

21.8 

1,466 
5,899 

24.9 

1,490 
5,899 

25.3 

2,101 
10,913 

(1,402) 
8,970 

7,510 
50,451 

4,850 
48,235 

5,547 
44,170 

19.2 

na 

14.9 

10.1 

12.6 

2,125 
10,913 

(578) 
8,970 

8,407 
50,451 

4,954 
48,235 

6,038 
44,170 

19.5 

na 

16.7 

10.3 

13.7 

28  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
M
D
&
A

Economic Developments and Outlook 

Economic Developments in 2021 and Outlook for 2022 (1) 
After contracting by 5.2% in 2020, Canada’s economy is expected to grow by 4.5% in 2021, despite supply-chain disruptions and public health 
restrictions that were put in place through the year to suppress a resurgence in COVID-19 cases. The recovery has been supported by substantial fiscal 
and monetary policy stimulus, high levels of household savings, elevated prices for energy and other commodities, robust U.S. demand and strong 
housing market activity. Despite a rise in COVID-19 case counts and a decline in agricultural production due to the severe drought in Western Canada, 
real GDP grew strongly in the third quarter of 2021 after contracting in the previous quarter. While disruptions to transportation and supply chains 
arising from floods in British Columbia and concerns about new virus variants will restrain activity in the near term, the economy is expected to 
experience growth of 4.0% in 2022. Growth will be supported by substantial pent-up demand for travel and in-person activities, and by additional 
government spending. Exports should benefit from rising prices for commodities and a recovering global economy, with the U.S. and Eurozone 
economies expected to strengthen. Housing market activity will likely remain elevated, although some moderation in sales is expected due to the 
continued erosion of affordability. The unemployment rate is projected to fall from 6.7% in October 2021 to below 6.0% at the end of 2022, returning 
to pre-pandemic levels. To support the economic recovery, the Bank of Canada is expected to hold the overnight policy rate near zero for several 
months, before shifting to a tighter policy stance by the middle of 2022. The annual rate of consumer inflation rose to an 18-year high of 4.7% in 
October 2021, due to significant price increases for gasoline, food, motor vehicles and housing. The increase in inflation reflects a temporary rebound 
in prices during the reopening of the economy, as well as supply-chain disruptions and rising commodity prices. Inflation is expected to subside 
in 2022 as supply-chain disruptions abate and energy prices moderate, but will likely remain above pre-pandemic levels. Inflation could remain high 
for longer than expected if wages accelerate in response to labour shortages. The Canadian dollar strengthened in 2021 on rising commodity prices, 
and it is projected to appreciate moderately further in 2022 in response to tighter monetary policy. Industry-wide, residential mortgage balances are 
expected to experience continued robust growth in response to low mortgage rates, higher housing prices and steady gains in employment, although 
the rate of growth will likely moderate alongside housing activity in the coming quarters. While growth in consumer credit balances (excluding 
mortgages) has been limited by restrained consumer spending, it is anticipated to increase in step with spending as most of the remaining pandemic-
related restrictions are lifted. Industry-wide, growth in non-financial corporate credit has moderated as a result of the elevated balances built up early 
in the pandemic, but is expected to increase moderately in the year ahead as business investment rises along with a return of confidence. 

The U.S. economy is expected to grow by 5.5% in 2021 after contracting by 3.4% in 2020, and growth is expected to reach 3.5% in 2022. 

The resurgence in COVID-19 case counts in the summer and a reduction in motor vehicle production due to microchip shortages slowed real GDP 
growth in the third quarter of 2021. However, the economic expansion is well-supported by elevated household savings, higher levels of personal 
wealth and a robust housing market. Federal spending on infrastructure projects, along with proposed spending on childcare, education and climate 
measures, would (if the latter measures are enacted) provide ongoing support to the economy, although this will be partially offset by related tax 
increases and the winding down of income-support programs. Housing market activity is expected to remain healthy in 2022, as a result of low 
interest rates and rising employment. In addition, business spending is on the rise, with non-residential investment surpassing pre-pandemic levels. 
The unemployment rate is projected to fall from 4.6% in October 2021 to 3.5% in late 2022, returning to pre-pandemic levels. To further support the 
recovery in labour markets, the Federal Reserve is expected to hold interest rates steady before raising them in the fall of 2022. After falling through 
mid-2021, longer-term interest rates are projected to rise in response to strong economic growth and a shift toward tighter monetary policy. Rising 
commodity prices, supply-chain bottlenecks and a rebound in travel-related costs and spending propelled the annual consumer price index to a three-
decade high of 6.2% in October 2021. We expect the inflation rate to remain elevated through the turn of the year, before falling below 3% in 
late 2022, as supply shortages subside and energy prices moderate. Industry-wide, residential mortgage growth will likely remain healthy due to 
ongoing housing market activity. Consumer credit growth has been constrained by fiscal support programs, elevated levels of household savings 
and limited consumption of in-person services, but it should benefit from the expected growth in personal spending. Industry-wide, non-financial 
corporate credit growth has been subdued, but is anticipated to pick up as business confidence strengthens. 

The unpredictable course of the COVID-19 pandemic subjects the economic outlook to a high degree of uncertainty, which is likely to persist 
until vaccines are more widely accessible and used across the global population. The Delta variant led to an upturn in COVID-19 case counts in many 
countries, and the emergence of other variants could lead to increased hospitalizations and renewed shutdowns of business activity, potentially 
resulting in a sustained economic contraction. Other risks to the economy stem from recent concerns about the solvency of a large property developer 
in China, a potential flare-up in U.S./China trade tensions, possible turbulence in some emerging market economies as interest rates rise, and the 
possibility of higher inflation due to persistent supply shortages and rising energy costs. Escalating housing prices in Canada and the United States 
could also leave either economy vulnerable to a correction in the housing market. 

This Economic Developments and Outlook section contains forward-looking statements. Please see the Caution Regarding Forward-Looking 

Statements. 

(1)  All periods in this section refer to the calendar year rather than fiscal year. 

BMO Financial Group 204th Annual Report 2021  29 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

2021 Financial Performance Review 

This section provides a review of BMO’s enterprise financial performance for 2021 that focuses on the Consolidated Statement of Income in BMO’s 
consolidated financial statements. A review of the operating groups’ strategies and performance follows the enterprise review. 

We use a number of financial measures to assess our performance, as well as the performance of our operating segments, including amounts, 

measures and ratios that are presented on a non-GAAP basis. We believe that these non-GAAP amounts, measures and ratios, read together with 
our GAAP results, provide readers with a better understanding of how management assesses results. 

Non-GAAP amounts, measures and ratios do not have standardized meanings under GAAP. They are unlikely to be comparable to similar 

measures presented by other companies and should not be viewed in isolation from, or as a substitute for, GAAP results. 

Further discussion of the non-GAAP amounts, measures and ratios is provided in the Non-GAAP and Other Financial Measures section. 
For further information regarding the composition of non-GAAP and other financial measures, including supplementary financial measures, 

refer to the Glossary of Financial Terms. 

A
&
D
M

Foreign Exchange 
The Canadian dollar equivalents of BMO’s U.S. segment results that are denominated in U.S. dollars decreased relative to 2020 due to changes in the 
Canadian/U.S. dollar exchange rate. The table below indicates the relevant average Canadian/U.S. dollar exchange rates and the impact of changes in 
those rates on BMO’s U.S. segment results. References in this document to the impact of the U.S. dollar do not include U.S. dollar-denominated 
amounts recorded outside of BMO’s U.S. segment. 

Economically, our U.S. dollar income stream was not hedged against the risk of changes in foreign exchange rates during 2021, 2020 and 2019. 
We regularly determine whether to enter into hedging transactions in order to mitigate the impact of foreign exchange rate movements on our net 
income. Changes in exchange rates will affect future results measured in Canadian dollars, and the impact on those results is a function of the periods 
in which revenue, expenses, provisions for (recoveries of) credit losses and income taxes arise. 

Refer to the Enterprise-Wide Capital Management section for a discussion of the impact that changes in foreign exchange rates can have on 

BMO’s capital position. 

Effects of Changes in Exchange Rates on BMO’s U.S. Segment Reported and Adjusted Results 

(Canadian $ in millions, except as noted) 

Canadian/U.S. dollar exchange rate (average) 

2021 
2020 
2019 

Effects on U.S. segment reported results 

Increased (Decreased) net interest income 
Increased (Decreased) non-interest revenue 

Increased (Decreased) revenue 
Decreased (Increased) provision for credit losses 
Decreased (Increased) expenses 
Decreased (Increased) income taxes 

Increased (Decreased) reported net income 

Effects on U.S. segment adjusted results 

Increased (Decreased) net interest income 
Increased (Decreased) non-interest revenue 

Increased (Decreased) revenue 
Decreased (Increased) provision for credit losses 
Decreased (Increased) expenses 
Decreased (Increased) income taxes 

Increased (Decreased) adjusted net income 

Adjusted results in this table are on a non-GAAP basis and are discussed in the Non-GAAP and Other Financial Measures section. 

2021 vs. 
2020 

2020 vs. 
2019 

1.2554 
1.3441 

1.3441 
1.3290 

(374) 
(196) 

(570) 
(95) 
(358) 
(21) 

(96) 

(374) 
(196) 

(570) 
(95) 
(351) 
(23) 

(101) 

83 
29 

112 
83 
43 
(5) 

(9) 

83 
29 

112 
83 
51 
(7) 

(15) 

30  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Net Income 
Reported net income was $7,754 million, an increase of $2,657 million or 52% from the prior year, and adjusted net income was $8,651 million, an 
increase of $3,450 million or 66%, reflecting a recovery from the significant adverse impacts of the COVID-19 pandemic on the global economy, our 
customers and our 2020 financial results. Adjusted results in the current year excluded a $779 million pre-tax and after-tax write-down of goodwill 
related to the sale of our EMEA Asset Management business, a $22 million ($29 million pre-tax) net gain on the sale of our Private Banking business 
in Hong Kong and Singapore, and $85 million ($107 million pre-tax) of divestiture-related costs for both transactions, partially offset by an $18 million 
($24 million pre-tax) partial reversal of restructuring charges from 2019 related to severance. In addition, adjusted net income in the current and prior 
years excluded the amortization of acquisition-related intangible assets and acquisition-related integration costs. For further information, refer to the 
Non-GAAP and Other Financial Measures section. 

The increase in net income reflects the impact of lower provisions for credit losses, which were elevated in the prior year due to the impact 
of the COVID-19 pandemic, and revenue growth, partially offset by an increase in expenses and the impact of the weaker U.S. dollar. Net income 
increased in all operating groups, partially offset by a higher net loss in Corporate Services. 

Canadian P&C reported net income increased $1,210 million or 60% from the prior year, and adjusted net income increased $1,209 million 

or 60%, driven by lower provisions for credit losses and strong revenue growth, partially offset by an increase in expenses. U.S. P&C reported net 
income increased $912 million or 71%, and adjusted net income increased $897 million or 68%, primarily driven by lower provisions for credit losses, 
strong revenue growth and a reduction in expenses. BMO Wealth Management reported net income increased $378 million or 34%, and adjusted net 
income increased $368 million or 32%, driven by higher revenue, partially offset by an increase in expenses. BMO Capital Markets reported net 
income increased $1,053 million or 97%, and adjusted net income increased $1,048 million or 94%, with recoveries of provisions for credit losses 
and higher revenue, partially offset by an increase in expenses. Corporate Services reported net loss was $1,286 million and adjusted net loss was 
$462 million, compared with a reported and adjusted net loss of $390 million in the prior year. The higher reported and adjusted net loss reflected 
an increase in expenses, partially offset by higher revenue, driven by higher securities gains and treasury-related activities, and the impact of a less 
favourable tax rate in the prior year. 

Further discussion is provided in the 2021 Operating Groups Performance Review section. 
For further information on non-GAAP amounts, measures and ratios in this Net Income section, refer to the Non-GAAP and Other Financial 

Measures section. 

M
D
&
A

Revenue 
Reported revenue was $27,186 million, an increase of $2,000 million from the prior year, and adjusted revenue 
was $27,157 million, an increase of $1,971 million, both increasing 8% from the prior year. On a basis that nets 
insurance claims, commissions and changes in policy benefit liabilities (CCPB) against insurance revenue (net 
revenue), reported net revenue was $25,787 million, an increase of $2,309 million, and adjusted net revenue was 
$25,758 million, an increase of $2,280 million, both increasing 10% from the prior year. Adjusted revenue and 
adjusted net revenue in the current year excluded the $29 million ($22 million after-tax) net gain on the sale of our 
Private Banking business in Hong Kong and Singapore. The impact of the weaker U.S. dollar reduced revenue by 2%. 
Revenue increased in BMO Capital Markets due to higher Investment and Corporate Banking revenue and higher 

Global Markets revenue; in Canadian P&C due to higher net interest income and non-interest revenue; and in 
BMO Wealth Management primarily due to growth in client assets, including stronger global markets and strong loan 
and deposit growth, partially offset by lower margins. Revenue decreased in U.S. P&C due to the weaker U.S. dollar, 
and increased on a source-currency basis due to higher net interest income and non-interest revenue. Corporate 
Services revenue increased from the prior year, driven by higher securities gains and treasury-related activities. 

BMO analyzes revenue at the consolidated level based on GAAP revenue as reported in the consolidated 
financial statements, and on an adjusted basis. Operating group revenue is presented on a taxable equivalent basis 
(teb), with revenue and the provision for income taxes increased on tax-exempt securities to an equivalent pre-tax 
basis. These teb adjustments for 2021 totalled $315 million, and were $335 million in 2020. 

Further discussion is provided in the 2021 Operating Groups Performance Review section. 
For further information on non-GAAP amounts, measures and ratios, and results presented on a net revenue 

basis in this Revenue section, refer to the Non-GAAP and Other Financial Measures section. 

Reported Net Revenue* 
($ billions) 

22.8

9.9 

23.5

9.5

25.8

11.5

12.9 

14.0 

14.3

2019 

2020 

2021

Reported Net Interest Income 
Reported Net Non-Interest Revenue

*Numbers may not add due to rounding. 

Net interest income comprises earnings on assets, such as loans and securities, including interest and certain dividend income, less interest 
expense paid on liabilities, such as deposits. 

Net interest margin is the ratio of net interest income to average earning assets, expressed as a percentage or in basis points. 

Net non-interest revenue is non-interest revenue, net of insurance claims, commissions and changes in policy benefit liabilities (CCPB). 

Average earning assets represents the daily average balance of deposits at central banks, deposits with other banks, securities borrowed or 
purchased under resale agreements, securities, and loans over a one-year period. 

Taxable equivalent basis (teb) Revenues of operating groups are presented in the MD&A on a taxable equivalent basis (teb). Revenue and the 
provision for income taxes are increased on tax-exempt securities to an equivalent pre-tax basis to facilitate comparisons of income between 
taxable and tax-exempt sources. This adjustment is offset in Corporate Services. 

BMO Financial Group 204th Annual Report 2021  31 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Revenue 

(Canadian $ in millions, except as noted) 
For the year ended October 31 

Net interest income 
Non-interest revenue 

Total revenue 
CCPB (1) 

Revenue, net of CCPB (1) 

Adjusted revenue (2) (3) 
Adjusted CCPB (1) (2) (3) 

Adjusted revenue, net of CCPB (1) (2) (3) 

2021 

2020 

2019 

14,310 
12,876 

27,186 
1,399 

25,787 

27,157 
1,399 

25,758 

13,971 
11,215 

25,186 
1,708 

23,478 

25,186 
1,708 

23,478 

12,888 
12,595 

25,483 
2,709 

22,774 

25,483 
2,684 

22,799 

Change 
from 2020 
(%) 

2 
15 

8 
(18) 

10 

8 
(18) 

10 

A
&
D
M

(1)  Insurance revenue can experience variability arising from fluctuations in the fair value of insurance assets caused by movements in interest rates and equity markets. The investments that support 
policy benefit liabilities are predominantly fixed income assets recorded at fair value, with changes in fair value recorded in insurance revenue in the Consolidated Statement of Income. These fair 
value changes are largely offset by changes in the fair value of policy benefit liabilities, the impact of which is reflected in CCPB. The discussion of revenue on a net of CCPB basis reduces variability in 
results, which allows for a better discussion of operating results. For additional discussion refer to the Insurance Claims, Commissions and Changes in Policy Benefits section. 

(2)  Fiscal 2021 reported revenue included a $29 million ($22 million after-tax) net gain on the sale of our Private Banking business in Hong Kong and Singapore recorded in non-interest revenue. 
(3)  Fiscal 2019 reported revenue included a reinsurance adjustment of $25 million (pre-tax and after-tax) in CCPB for the net impact of major reinsurance claims incurred after the announced 

wind-down of the reinsurance business. This reinsurance adjustment is recorded in BMO Wealth Management. 

Revenue, net of CCPB, and adjusted results in this table are on a non-GAAP basis and are discussed in the Non-GAAP and Other Financial Measures section. 

Net Interest Income 
Net interest income was $14,310 million, an increase of $339 million or 2% from the prior year. Non-trading net 
interest income was $12,457 million, an increase of $417 million or 3%, largely due to higher net interest income 
in Canadian P&C and BMO Wealth Management, primarily reflecting higher balances, and in Corporate Services, 
partially offset by lower net interest income in BMO Capital Markets. Higher source-currency net interest income in 
U.S. P&C was more than offset by the impact of the weaker U.S. dollar. Trading-related interest income was 
$1,853 million, a decrease of $78 million or 4%. 

Average earning assets were $897.3 billion, an increase of $44.0 billion or 5% from the prior year, primarily 
due to higher cash and securities balances and loan growth, partially offset by the impact of the weaker U.S. dollar. 
BMO’s overall net interest margin of 159 basis points decreased 5 basis points from the prior year, primarily 
driven by higher liquidity levels and lower trading-related interest income, partially offset by higher net interest 
margins in our P&C businesses. On a basis that excludes trading-related interest income and earning assets, net 
interest margin of 166 basis points increased 2 basis points, primarily driven by lower balances of low-yielding 
assets in BMO Capital Markets and higher net interest margins in our P&C businesses, partially offset by higher 
liquidity levels. 

Table 3 in the Supplemental Information provides further details on net interest income and net interest 

Average Earning Assets 
and Net Interest Margin

759.4 

1.83 

1.70

853.3 

897.3 

1.64 

1.64

1.66

1.59

2019 

2020 

2021

Average Earning Assets ($ billions) 
Net Interest Margin (%)
Net Interest Margin Excluding Trading Net
Interest Income and Trading Assets (%) 

margin. 

Change in Net Interest Income, Average Earning Assets and Net Interest Margin 

(Canadian $ in millions, except as noted) 
For the year ended October 31 

Canadian P&C 
U.S. P&C 

Net interest income (teb) (1) 

Average earning assets (2) 

Change 

Change 

2021 

2020 

6,561 
4,268 

6,105 
4,345 

% 

7 
(2) 

4 
(1) 

2021 

2020 

248,215 
122,166 

370,381 
526,921 

234,953 
130,190 

365,143 
488,193 

% 

6 
(6) 

1 
8 

5 

Personal and Commercial Banking (P&C) 
All other operating groups and Corporate Services (3) 

10,829 
3,481 

10,450 
3,521 

Total reported 

14,310 

13,971 

2 

897,302 

853,336 

Trading net interest income and earning assets 
Total excluding trading net interest income and earning 

assets 

U.S. P&C (US$ in millions) 

1,853 

1,931 

(4) 

144,865 

121,205 

20 

12,457 

12,040 

3,400 

3,231 

3 

5 

752,437 

732,131 

97,321 

96,810 

3 

1 

Net interest margin 
(in basis points) 

2021 

2020 

Change 

264 
349 

292 

na 

159 

na 

166 

260 
334 

286 

na 

164 

na 

164 

349 

334 

4 
15 

6 

na 

(5) 

na 

2 

15 

(1)  Operating group revenue is presented on a taxable equivalent basis (teb) in net interest income and is non-GAAP. For further information, refer to the Non-GAAP and Other Financial Measures and 

How BMO Reports Operating Group Results sections. 

(2)  Average earning assets represents the daily average balance of deposits with central banks, deposits with other banks, securities borrowed or purchased under resale agreements, securities, and 

loans, over a one-year period. 

(3)  For further information on net interest income for these other operating groups and Corporate Services, refer to the Review of Operating Groups’ Performance section. 

na – not applicable 
Certain comparative figures have been reclassified to conform with the current year’s presentation. 

32  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Non-Interest Revenue 
Non-interest revenue, which comprises all revenue other than net interest income, was $12,876 million on a reported basis, an increase 
of $1,661 million or 15% from the prior year. Adjusted non-interest revenue was $12,847 million, an increase of $1,632 million or 15%, and excluded 
the $29 million net gain on the sale of our Private Banking business in Hong Kong and Singapore. Reported non-interest revenue, net of CCPB, 
was $11,477 million, an increase of $1,970 million or 21% from the prior year, and adjusted non-interest revenue, net of CCPB, was $11,448 million, 
an increase of $1,941 million or 20%. 

Non-interest revenue increased across all categories, including higher securities gains, other than trading, underwriting and advisory fee revenue, 
trading revenue, investment management and custodial fee revenue, mutual fund revenue and lending fee revenue, partially offset by the impact of 
the weaker U.S. dollar. Trading revenue is discussed in the Trading Revenue section that follows. 

Gross insurance revenue decreased from the prior year, primarily due to changes in the fair value of investments, partially offset by higher 
annuity sales. Insurance revenue can experience variability arising from fluctuations in the fair value of insurance assets caused by movements in 
interest rates and equity markets. The investments that support policy benefit liabilities are predominantly fixed income and equity assets recorded at 
fair value, with changes in fair value recorded in insurance revenue in the Consolidated Statement of Income. The impact of these fair value changes 
was largely offset by changes in the fair value of policy benefit liabilities, which are reflected in the Insurance Claims, Commissions and Changes in 
Policy Benefits section. 

We generally focus on analyzing revenue net of CCPB, given the extent to which insurance revenue can vary, and given that this variability is 

largely offset in CCPB. 

Table 3 in the Supplemental Information provides further details on revenue and revenue growth. 

M
D
&
A

Non-Interest Revenue 

(Canadian $ in millions) 
For the year ended October 31 

Securities commissions and fees 
Deposit and payment service charges 
Trading revenue 
Lending fees 
Card fees 
Investment management and custodial fees 
Mutual fund revenue 
Underwriting and advisory fees 
Securities gains, other than trading 
Foreign exchange, other than trading 
Insurance revenue 
Investments in associates and joint ventures 
Other 

Total reported 
CCPB 

Reported non-interest revenue, net of CCPB 

Impact of divestitures (1) 
Adjusted non-interest revenue 

Reinsurance adjustment (2) 
Adjusted CCPB 

Adjusted non-interest revenue, net of CCPB 

Insurance revenue, net of CCPB 
Insurance revenue, net of adjusted CCPB 

2021 

1,107 
1,243 
296 
1,391 
442 
1,982 
1,595 
1,421 
591 
167 
1,941 
248 
452 

12,876 
(1,399) 

11,477 

(29) 
12,847 

– 
(1,399) 

2020 

1,036 
1,221 
15 
1,295 
358 
1,807 
1,417 
1,070 
124 
127 
2,178 
161 
406 

2019 

1,023 
1,204 
298 
1,192 
437 
1,747 
1,419 
975 
249 
166 
3,183 
151 
551 

11,215 
(1,708) 

9,507 

– 
11,215 

12,595 
(2,709) 

9,886 

– 
12,595 

–

 25

(1,708) 

(2,684) 

11,448 

9,507 

9,911 

542 
542 

470 
470 

474 
499 

Change 
from 2020 
(%) 

7 
2 
+100 
7 
23 
10 
13 
33 
+100 
31 
(11) 
54 
11 

15 
(18) 

21 

na 
15 

  – 
(18) 

20 

15 
15 

(1)  Fiscal 2021 included a $29 million ($22 million after-tax) net gain on the sale of our Private Banking business in Hong Kong and Singapore recorded in non-interest revenue. 
(2)  Fiscal 2019 reported revenue included a reinsurance adjustment of $25 million (pre-tax and after-tax) in claims, commissions and changes in policy benefit liabilities for the net impact of major 

reinsurance claims incurred after the announced wind-down of the reinsurance business. This reinsurance adjustment is recorded in BMO Wealth Management. 

Reported and adjusted revenue measures, net of CCPB, in this section are on a non-GAAP basis and are discussed in the Non-GAAP and Other Financial Measures section. 

BMO Financial Group 204th Annual Report 2021  33 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Trading-Related Revenue 
Trading-related revenue is dependent on, among other things, the volume of activities undertaken for clients who enter into transactions with BMO 
to mitigate their risks or to invest, and market conditions. We earn a spread or profit on the net sum of our client positions by profitably managing, 
within prescribed limits, the overall risk of our net positions. On a limited basis, we also earn revenue from our principal trading positions. 

Interest and non-interest trading-related revenue on a teb basis increased $182 million or 8% to $2,434 million in 2021. Equities trading-related 
revenue increased $578 million, due to favourable market conditions. The prior year included negative impacts related to equity linked notes-related 
businesses in the volatile second quarter of 2020. Interest rate trading-related revenue decreased $182 million or 15% and foreign exchange trading-
related revenue decreased $58 million or 12%, as the prior year benefitted from higher levels of client activity driven by the reaction of market 
participants to the COVID-19 pandemic. Commodities trading-related revenue decreased $124 million or 46%, reflecting a decline in client hedging 
activity in the energy sector. Other trading-related revenue decreased $32 million, primarily due to lower fair value gains associated with hedging 
exposures on the structural balance sheet in the current year. 

The Market Risk section provides more information on trading-related revenue. 

A
&
D
M

Trading-related revenue includes net interest income and non-interest revenue earned from on-balance sheet and off-balance sheet positions 
undertaken for trading purposes. The management of these positions typically includes marking them to market on a daily basis. Trading-related 
revenue also includes income (expense) and gains (losses) from both on-balance sheet instruments and interest rate, foreign exchange 
(including spot positions), equity, commodity and credit contracts. BMO analyzes on a teb basis at the operating group level. Revenue and the 
provision for income taxes are increased on tax-exempt securities to an equivalent before-tax basis to facilitate comparisons of income between 
taxable and tax-exempt sources. This adjustment is offset in Corporate Services. 

Interest and Non-Interest Trading-Related Revenue 

(1)

(Canadian $ in millions) 
(taxable equivalent basis) 
For the year ended October 31 

Interest rates 
Foreign exchange 
Equities 
Commodities 
Other 

Total (teb) 
Teb offset 

Reported total 

Reported as: 
Net interest income 
Non-interest revenue – trading revenue 

Total (teb) 
Teb offset 

Reported total, net of teb offset 

2021 

1,017 
416 
852 
147 
2 

2,434 
285 

2,149 

2,138 
296 

2,434 
285 

2,149 

2020 

1,199 
474 
274 
271 
34 

2,252 
306 

1,946 

2,237 
15 

2,252 
306 

1,946 

Change 
from 2020 
(%) 

(15) 
(12) 
+100 
(46) 
(94) 

8 
(7) 

10 

(4) 
+100 

8 
(7) 

10 

2019 

700 
401 
526 
145 
6 

1,778 
257 

1,521 

1,480 
298 

1,778 
257 

1,521 

(1)  Trading-related revenue is presented on a taxable equivalent basis and is a non-GAAP measure, and is discussed in the Non-GAAP and Other Financial Measures section. 

Insurance Claims, Commissions and Changes in Policy Benefit Liabilities 
Insurance claims, commissions and changes in policy benefit liabilities (CCPB) were $1,399 million in 2021, compared with $1,708 million in the 
prior year. CCPB decreased, primarily due to changes in the fair value of policy benefit liabilities, partially offset by the impact of higher annuity sales. 
The changes were largely offset in revenue. 

34  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Total Provision for Credit Losses 
The total provision for credit losses (PCL) was $20 million, compared with $2,953 million in the prior year, primarily 
due to an improving economic outlook and more favourable credit conditions. Total PCL as a percentage of average 
net loans and acceptances was nil basis points, compared with 63 basis points in the prior year. PCL on impaired 
loans was $525 million, a decrease of $997 million from the prior year, largely due to lower provisions in our P&C 
businesses and BMO Capital Markets. PCL on impaired loans as a percentage of average net loans and acceptances 
was 11 basis points, compared with 33 basis points in the prior year. There was a $505 million recovery of the 
provision for credit losses on performing loans in the current year, compared with a $1,431 million provision in the 
prior year. The recovery in the current year largely reflected an improving economic outlook and positive credit 
migration, partially offset by growth in loan balances. 

Provision for 
Credit Losses 
($ millions) 

2,953 

872 

20 

PCL on impaired loans decreased $294 million in Canadian P&C, reflecting lower commercial and consumer 

2019 

2020 

2021 

provisions, and $396 million in U.S. P&C, primarily due to lower commercial provisions. In BMO Capital Markets, PCL on 
impaired loans decreased $299 million from the prior year. All operating groups recorded recoveries of provisions for 
credit losses on performing loans in the current year, compared with the provisions recorded in the prior year. 

Note 4 of the consolidated financial statements provides additional information on PCL, including on a geographic 

basis. Table 15 in the Supplemental Information provides further segmented PCL information. 
For additional information, please refer to the Allowance for Credit Losses section. 

M
D
&
A

Provision for Credit Losses (PCL) is a charge to income that represents an amount deemed adequate by management to fully provide for 
impairment in a portfolio of loans and acceptances and other credit instruments, given the composition of the portfolio, the probability of default, 
the economic environment and the allowance for credit losses already established. PCL can comprise both a provision for credit losses on 
impaired loans and a provision for credit losses on performing loans. For further information, refer to the Credit and Counterparty Risk – Provision 
for Credit Losses and Allowance for Credit Losses sections and Note 4 of the consolidated financial statements. 

Average Net Loans and Acceptances is the daily or monthly average balance of loans and customers’ liability under acceptances, net of the 
allowance for credit losses, over a one-year period. 

Provision for Credit Losses by Operating Group 

(Canadian $ in millions) 

Canadian P&C 

U.S. P&C 

Total P&C 

BMO Wealth 
Management 

BMO Capital 
Markets 

Corporate 
Services 

Total Bank 

2021 
Provision for (recovery of) credit losses on impaired loans 
Provision for (recovery of) credit losses on performing loans 

Total provision for (recovery of) credit losses 

2020 
Provision for (recovery of) credit losses on impaired loans 
Provision for (recovery of) credit losses on performing loans 

Total provision for (recovery of) credit losses 

2019 
Provision for (recovery of) credit losses on impaired loans 
Provision for (recovery of) credit losses on performing loans 

Total provision for (recovery of) credit losses 

493 
(116) 

377 

22 
(166) 

(144) 

515 
(282) 

233 

787 
623 

1,410 

544 
63 

607 

418 
441 

859 

160 
37 

197 

1,205 
1,064 

2,269 

704 
100 

804 

4 
(16) 

(12) 

4 
18 

22 

2 
(2) 

– 

11 
(205) 

(194) 

310 
349 

659 

52 
28 

80 

(5) 
(2) 

(7) 

3 
– 

3 

(7) 
(5) 

(12) 

525 
(505) 

20 

1,522 
1,431 

2,953 

751 
121 

872 

Certain comparative figures have been reclassified to conform with the current year’s presentation. 

Provision for Credit Losses Performance Ratios 

Total PCL-to-average net loans and acceptances (annualized) (%) 
PCL on impaired loans to average net loans and acceptances (annualized) (%) 

Certain comparative figures have been reclassified to conform with the current year’s presentation. 

2021 

– 
0.11 

2020 

0.63 
0.33 

2019 

0.20 
0.17 

BMO Financial Group 204th Annual Report 2021  35 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Non-Interest Expense 
Reported non-interest expense was $15,509 million, an increase of $1,332 million or 9% from the prior year, primarily 
due to the impact of divestitures, including a $779 million write-down of goodwill related to the sale of our EMEA 
Asset Management business and $107 million of divestiture-related costs in the current year. 

Adjusted non-interest expense was $14,550 million, an increase of $508 million or 4% from the prior year. 
Adjusted non-interest expense excluded the impact of divestitures in the current year and a $24 million partial 
reversal of the restructuring charge, as well as the amortization of acquisition-related intangible assets and 
acquisition-related costs in both the current and prior years. The amortization of acquisition-related intangible assets 
was $88 million and $121 million in 2021 and 2020, respectively. Acquisition integration costs were $9 million and 
$14 million in 2021 and 2020, respectively. 

Reported and adjusted non-interest expense increased, due to higher performance-based compensation, 

computer and equipment costs and professional fees, partially offset by the benefits of a continued disciplined 
approach to expense management and the impact of the weaker U.S. dollar, which reduced expenses by 3%. 

The dollar and percentage changes in expense by category are outlined in the Non-Interest Expense and Adjusted 

Non-Interest Expense tables below. Table 4 in the Supplemental Information provides more detail on expenses. 
Performance-based compensation increased $520 million or 20% on a reported basis, and $505 million 
or 19% on an adjusted basis, reflecting improved business performance. Other employee compensation, which 
includes salaries, benefits and severance, decreased $142 million or 3% on a reported basis, and $165 million 
or 3% on an adjusted basis, primarily due to the impact of the weaker U.S. dollar. 

Premises and equipment costs increased $194 million or 6% on a reported basis, and $176 million or 5% on 
an adjusted basis, primarily due to higher technology and real estate costs. Amortization of intangible assets on a 
reported basis increased $14 million or 2%, and increased $37 million or 7% on an adjusted basis, reflecting an 
increase in software amortization. Other expenses increased $746 million or 31% on a reported basis, reflecting 
the impact of divestitures, and decreased $45 million or 2% on an adjusted basis. 

For further information on non-GAAP amounts, measures and ratios in this Non-Interest Expense section, refer to 

A
&
D
M

Non-Interest Expense 
($ billions) 

14.6 

14.0 

14.2 14.0 

15.5 

14.6

2019 

2020 

2021 

Reported Non-Interest Expense 
Adjusted Non-Interest Expense 

the Non-GAAP and Other Financial Measures section. 

Non-Interest Expense 

(Canadian $ in millions, on a pre-tax basis) 
For the year ended October 31 

Performance-based compensation 

Acquisition integration costs 
Impact of divestitures 
Restructuring costs 

Adjusted performance-based compensation 

Other employee compensation 
Acquisition integration costs 
Impact of divestitures 
Restructuring costs 

Adjusted other employee compensation 

Premises and equipment 
Impact of divestitures 
Restructuring costs 

Adjusted premises and equipment 

Amortization of intangible assets 

Amortization of acquisition-related intangible assets 
Impact of divestitures 

Adjusted amortization of intangible assets 

Other 

Acquisition integration costs 
Impact of divestitures 
Restructuring costs 

Adjusted other 

Total reported non-interest expense 

Total adjusted non-interest expense 

Adjusted results in this table are on a non-GAAP basis and are discussed in the Non-GAAP and Other Financial Measures section. 

36  BMO Financial Group 204th Annual Report 2021 

2021 

2020 

2019 

Change 
from 2020 
(%) 

3,152 
(4) 
(14) 
– 

3,134 

5,170 
(5) 
(48) 
24 

5,141 

3,396 
(18) 
– 

3,378 

634 
(88) 
(10) 

536 

3,157 
– 
(796) 
– 

2,361 

2,632 
(3) 
–
– 

2,629 

5,312 
(6) 
–
– 

5,306 

3,202 
–
– 

3,202 

620 
(121) 
– 

499 

2,411 
(5) 
–
–

2,406 

2,610 
– 
– 
(3) 

2,607 

5,813 
(13) 
– 
(439) 

5,361 

2,988 
– 
(41) 

2,947 

554 
(128) 
– 

426 

2,665 
– 
– 
(1)

2,664 

15,509 

14,550 

14,177 

14,042 

14,630 

14,005 

20 
33 
na 
na 

19 

(3) 
(17) 
na 
na 

(3) 

6 
na 
na 

5 

2 
(27) 
na 

7 

31 
+100 
na 
 na 

(2) 

9 

4 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Provision for Income Taxes and Other Taxes 

(Canadian $ in millions, except as noted) 
For the year ended October 31 

Payroll levies 
Property taxes 
Provincial capital taxes 
Business taxes 
Harmonized sales tax, GST, VAT and other sales taxes 
Sundry taxes 

Total government levies other than income taxes (other taxes) (1) 
Provision for income taxes 

Provision for income taxes and other taxes 

Provision for income taxes and other taxes as a % of income before provision for income taxes and other taxes 
Effective tax rate (%) 
Adjusted effective tax rate (%) 

2021 

355 
36 
36 
10 
382 
1 

820 
2,504 

3,324 

30.0 
24.4 
22.7 

2020 

362 
42 
33 
9 
397 
1 

844 
1,251 

2,095 

29.1 
19.7 
19.8 

2019 

354 
37 
35 
9 
384 
1 

820 
1,514 

2,334 

28.8 
20.8 
21.1 

(1)  Other taxes are included in various non-interest expense categories. 
Provision for income taxes and other taxes and the adjusted effective tax rate in this table are on a non-GAAP basis and are discussed in the Non-GAAP and Other Financial Measures section. 

The provision for income taxes and other taxes was $3,324 million in the current year. Of this amount, $2,060 million was incurred in Canada, with 
$1,450 million included in the provision for income taxes, while the remaining $610 million was recorded in total government levies other than 
income taxes (other taxes). The increase from $2,095 million in the prior year primarily reflected a higher provision for income taxes. 

The provision for income taxes presented in the Consolidated Statement of Income is based upon transactions recorded in income, regardless 

of when such transactions are subject to taxation by tax authorities, with the exception of the repatriation of retained earnings from subsidiaries, as 
outlined in Note 22 of the consolidated financial statements. 

Management assesses BMO’s consolidated results and the associated provision for income taxes on a GAAP basis. We assess the performance 

of our operating groups and associated income taxes on a taxable equivalent basis, and we report accordingly. 

The provision for income taxes was $2,504 million, compared with $1,251 million in the prior year. The effective tax rate was 24.4%, compared 

with 19.7% in the prior year. The adjusted provision for income taxes was $2,537 million, compared with $1,282 million in the prior year. 
The adjusted effective tax rate  was 22.7%, compared with 19.8% in the prior year. The effective tax rate and adjusted effective tax rate were lower 
in the prior year primarily due to earnings mix, including the impact of lower pre-tax income in the prior year. The effective tax rate in the current 
year is higher than the adjusted effective tax rate due to the write-down of goodwill related to the sale of our EMEA Asset Management business in 
the current year. 

(1) 

BMO partially hedges, for accounting purposes, the foreign exchange risk arising from investments in foreign operations by funding the 

investments in the corresponding foreign currency. A gain or loss on hedging activities and an unrealized gain or loss on translation of foreign 
operations are charged or credited to other comprehensive income. For income tax purposes, a gain or loss on hedging activities results in an income 
tax charge or credit in the current period that is charged or credited to other comprehensive income, while the associated unrealized gain or loss on 
investments in foreign operations does not incur income taxes until the investments are liquidated. The income tax charge/benefit arising from a 
hedging gain/loss is a function of the fluctuations in exchange rates from period to period. Hedging of investments in foreign operations has given 
rise to an income tax expense in other comprehensive income of $180 million in the current year, compared with a recovery of $35 million in the 
prior year. Refer to Note 22 of the consolidated financial statements for further details. 

Legislative changes and changes in tax policy, including their interpretation by tax authorities and the courts, may impact our earnings. Refer to 
the discussion in the Critical Accounting Estimates section for additional details. In the table above we disclose provision for income taxes and other 
taxes as a percentage of income before the provision for income taxes and other taxes, which is a non-GAAP financial ratio, to reflect the full impact 
of all government levies and taxes as a percentage of our income. 

For further information on non-GAAP amounts, measures and ratios in this Provision for Income Taxes and Other Taxes section, refer to the 

Non-GAAP and Other Financial Measures section. 

(1)  The adjusted effective tax rate is computed using adjusted net income and adjusted provision for income taxes rather than reported net income in the determination of income subject to income tax. 

M
D
&
A

BMO Financial Group 204th Annual Report 2021  37 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

2021 Operating Groups Performance Review 

Summary 
This section includes an analysis of the financial results of BMO’s operating groups and descriptions of their operating segments, businesses, 
strategies, challenges, achievements and outlooks. 

BMO Financial Group 

Operating Groups 

Personal and Commercial (P&C) Banking 

BMO Wealth 
Management 

BMO Capital
Markets 

A
&
D
M

Operating Segments 

Canadian P&C 

U.S. P&C 

Lines of Business 

•  Personal Banking 
•  Commercial Banking 

•  Personal Banking 
•  Commercial Banking 

•  BMO Private Wealth 
• 
BMO InvestorLine 
• 
BMO Wealth Management U.S. 
•  BMO Global Asset Management 
•  BMO Insurance 

• 

Investment and Corporate 
Banking 

•  Global Markets 

Corporate Services, including Technology and Operations 

BMO’s business mix is well diversified by operating segment and by geography. 

Reported Net Income 
by Operating Group* 

2021 

Reported Net Revenue 
by Operating Group* 

2021 

Reported Net Revenue 
by Geography 

2021 

Canadian P&C 36% 
U.S. P&C 24% 
BMO Wealth Management 16% 
BMO Capital Markets 24% 

Canadian P&C 34% 
U.S. P&C 21% 
BMO Wealth Management 22% 
BMO Capital Markets 23% 

Canada 58% 
United States 36% 
Other Countries 6% 

* Percentages determined excluding results in Corporate Services. 
Revenue, net of CCPB, is on a non-GAAP basis and is discussed in the Non-GAAP and Other Financial Measures section. 

38  BMO Financial Group 204th Annual Report 2021 

 
How BMO Reports Operating Group Results 

BMO reports financial results for its three operating groups, one of which comprises two operating segments, all of which are supported by Corporate 
Units and Technology and Operations within Corporate Services. Operating group results include treasury-related allocations in revenue, non-interest 
expense allocations from Corporate Units and Technology and Operations (T&O) and allocated capital. 

BMO employs funds transfer pricing and liquidity transfer pricing between Treasury and the operating groups to assign the appropriate cost 

and credit to funds for the appropriate pricing of loans and deposits, and to help assess the profitability performance of each line of business. 
These practices also capture the cost of holding supplemental liquid assets to meet contingent liquidity requirements and facilitate the management 
of interest rate risk and liquidity risk within our risk appetite framework and regulatory requirements. We review our transfer pricing methodologies 
at least annually, to align with our interest rate, liquidity and funding risk management practices. 

The costs of Corporate Units and Technology and Operations services are largely allocated to the four operating segments, with any remaining 
amounts retained in Corporate Services. Costs directly incurred to support a specific operating group are generally allocated to that operating group. 
Other costs that are not directly attributable to a specific operating group are allocated across the operating groups, reasonably reflective of the level 
of support provided to each operating group. Cost allocation methodologies are reviewed annually. 

Capital is allocated to the operating segments based on the amount of regulatory capital required to support business activities. Unallocated 

capital is reported in Corporate Services. Capital allocation methodologies are reviewed annually. 

Periodically, certain lines of business and units within our organizational structure are realigned to support our strategic priorities. In addition, 

allocations of revenue, provisions for credit losses, expenses and capital are updated periodically to better align with current experience. 

We analyze revenue at the consolidated level based on GAAP revenue as reported in the audited annual consolidated financial statements, rather 
than on a taxable equivalent basis (teb), which is consistent with our Canadian banking peer group. Like many banks, BMO analyzes revenue on a teb 
basis at the operating group level. Revenue and the provision for income taxes are increased on tax-exempt securities to an equivalent pre-tax basis 
in order to facilitate comparisons of income between taxable and tax-exempt sources. The offset to the group teb adjustments is reflected in 
Corporate Services revenue and provision for income taxes. 

M
D
&
A

Personal and Commercial Banking   (1)

(Canadian $ in millions, except as noted) 
As at or for the year ended October 31 

Net interest income (teb) 
Non-interest revenue 

(2)

Total revenue (teb) 
Provision for credit losses on impaired loans 
Provision for (recovery of) credit losses on performing loans 

Total provision for (recovery of) credit losses 
Non-interest expense 

Income before income taxes 
Provision for income taxes (teb) 

Reported net income 

Amortization of acquisition-related intangible assets 

(3)

Canadian P&C 

U.S. P&C 

Total P&C 

2021 

2020 

2019 

2021 

2020 

2019 

2021 

2020 

2019 

6,561 
2,225 

8,786 
493 
(116) 

377 
4,037 

4,372 
1,135 

3,237 
1 

6,105 
1,930 

8,035 
787 
623 

1,410 
3,892 

2,733 
706 

2,027 
2

5,885 
2,099 

7,984 
544 
63 

607 
3,836 

3,541 
917 

2,624 
2 

4,268 
1,243 

5,511 
22 
(166) 

(144) 
2,797 

2,858 
669 

2,189 
24 

4,345 
1,186 

5,531 
418 
441 

859 
3,075 

1,597 
320 

1,277 
39 

4,216 
1,162 

5,378 
160 
37 

197 
3,136 

2,045 
434 

1,611 
43 

10,829 
3,468 

14,297 
515 
(282) 

10,450 
3,116 

13,566 
1,205 
1,064 

233 
6,834 

7,230 
1,804 

5,426 
25 

2,269 
6,967 

4,330 
1,026 

3,304 
41 

10,101 
3,261 

13,362 
704 
100 

804 
6,972 

5,586 
1,351 

4,235 
45 

4,280 

Adjusted net income 

3,238 

2,029 

2,626 

2,213 

1,316 

1,654 

5,451 

3,345 

(1)  Adjusted results and teb amounts in this table are on a non-GAAP basis and are discussed in the Non-GAAP and Other Financial Measures section. 
(2)  Taxable equivalent basis amounts of $24 million in fiscal 2021, $28 million in fiscal 2020 and $34 million in fiscal 2019 are recorded in net interest income. 
(3)  Amortization of acquisition-related intangible assets pre-tax amounts of $35 million in 2021, $55 million in 2020 and $59 million in 2019 are recorded in non-interest expense. 

The Personal and Commercial Banking (P&C) operating group comprises our two retail and commercial banking operating segments, Canadian Personal 
and Commercial Banking (Canadian P&C) and U.S. Personal and Commercial Banking (U.S. P&C). The combined P&C banking business net income was 
$5,426 million, an increase of $2,122 million or 64% from the prior year. Adjusted net income, which excludes the amortization of acquisition-related 
intangible assets, was $5,451 million, an increase of $2,106 million or 63% from the prior year. Increases in reported and adjusted net income were 
primarily driven by lower provisions for credit losses, revenue growth and a reduction in expenses, partially offset by the impact of the weaker U.S. 
dollar. These operating segments are reviewed separately in the sections that follow. 

For further information on non-GAAP amounts, measures and ratios in this 2021 Operating Groups Performance Review section, refer to the 

Non-GAAP and Other Financial Measures section. 

BMO Financial Group 204th Annual Report 2021  39 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Canadian Personal and Commercial Banking 

Canadian Personal and Commercial Banking provides financial products and services to eight million customers. 
Personal Banking helps customers make real financial progress through a network of almost 900 branches, contact 
centres, digital banking platforms and more than 3,300 automated teller machines. Commercial Banking serves clients 
across Canada, and our commercial bankers are trusted advisors and partners to their clients, offering sector and 
industry expertise, local presence and a comprehensive range of commercial products and services. 

A
&
D
M

Lines of Business  
Personal Banking provides customers with a wide range of products 
and services, including chequing and savings accounts, credit cards, 
mortgages, personal loans, small business lending and everyday financial 
and investment advice, with an overall focus on providing customers 
with an exceptional experience in every interaction and helping them 
make real financial progress. 

Commercial Banking provides clients with a wide range of commercial 
products and services, including multiple financing options and treasury 
and payment solutions, as well as risk management products. 
Commercial bankers partner with clients to anticipate their financial 
needs, and share expertise and knowledge to help them manage and 
grow their businesses. 

Strategy and Key Priorities 

2021 Priorities and Achievements 

Key Priority: Continue to improve customer loyalty, deepen primary relationships and support 
customers in the new operating environment 

Achievements 
•  Continued to maintain strong customer loyalty in Personal Banking and 
leading customer loyalty in Commercial Banking, as measured by Net 
Promoter Score 

•  Supported customers experiencing financial hardship since the onset 

of the COVID-19 pandemic through multiple programs 
•  Assisted more than 82,000 small businesses with access to 

approximately $4.5 billion in loans through the Canada Emergency 
Business Account (CEBA) program 

•  Assisted nearly 1,500 clients with access to approximately 

$500 million in non-revolving loans through the Highly Affected 
Sectors Credit Availability Program (HASCAP), in collaboration with 
the Business Development Bank of Canada 

•  Partnered with Export Development Canada to launch the Trade 
Expansion Lending Program (TELP), which assists export-oriented 
small and medium-sized businesses with faster access to working 
capital so that they can expand outside of Canada 

•  Made BMO’s employee Wellness Services program available to 

Canadian business owners and entrepreneurs, offering services and 
resources that support mental, physical, social and financial health, 
at no additional cost 

Key Priority: In Personal Banking, drive customer acquisition, build share of wallet, enhance digital 
capabilities and deliver a leading customer experience 

Achievements 
•  Gained market share in key focus areas, including personal loans, retail 

deposits and credit cards 

•  Introduced a new tailored Small Business Banking bundle as part of our 
Canadian Defence Community Banking Program, aimed at supporting 
entrepreneurs from the Canadian Defence Community from start-up to 
succession planning 

•  Attracted new customers to BMO with the launch of BMO eclipse Visa 
InfiniteTM and Visa Infinite PrivilegeTM  credit cards, designed to meet 
the everyday lifestyle needs of Canadians, offering greater earning 
potential and more flexible rewards 

•  Introduced BMO Family BundleTM, a unique offering in the Canadian 

market, allowing customers and their family members to save on fees 
on their Canadian-dollar or U.S.-dollar chequing accounts 

•  Strengthened our digital sales and service capabilities, with 

more than a third of core banking products now purchased and 
delivered digitally, and more than 90% of service transactions 
completed through self-serve channels, enabling employees to 
focus on providing leading advisory services 

•  Introduced an Automated Digital Enrolment solution to help 

customers enrol quickly and seamlessly for commonly used mobile 
banking features, a first for a major Canadian financial institution. 
This new solution was enhanced with the launch of Selfie ID, which 
enables a simple digital onboarding experience 

•  Launched BMO CashTrackTM Insights, an artificial intelligence-driven 
capability that to date has offered more than 180,000 insights to 
customers through our mobile banking app, helping them avoid cash 
shortfalls or overdraft fees and make real financial progress 

40  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Key Priority: In Commercial Banking, target opportunities for growth and diversification across key 
sectors and businesses, invest in digital and payment capabilities and continue to leverage cross-bank 
collaboration 

Achievements 
•  Named Best Commercial Bank in Canada for the seventh consecutive 
year by World Finance magazine at its 2021 Banking Awards, in 
recognition of our strong regional and industry focus, as well as 
our commitment to building customer relationships and providing 
innovative solutions 

•  Co-led the first labelled Green Loan in Canada to support the 

• 

construction of a new 100% recycled containerboard facility in Ontario 
Continued to enhance our industry-leading Business Banking XpressTM 
(BBX) platform, which has facilitated $1.8 billion in lending 
authorizations, while building out multi-journey functionality to provide 
solutions to business owners quickly, in a single intuitive experience 

•  Launched a new Business Property Finance group to build scale and 

market presence rapidly in this sector 

•  Launched the first commercial real estate synthetic securitization 

offered by a Canadian bank 

•  Continued to advance payments modernization by deploying LynxTM, 
in collaboration with Payments Canada, enabling faster, simpler 
data-rich transactions 

•  Fully integrated our North American wire transfer platform, with 

95% of payments processed without human intervention, resulting 
in higher speed, lower risk of error and a better experience for 
customers and employees 

M
D
&
A

Key Priority: Drive efficiencies by simplifying and streamlining operations and investing in digital 
capabilities, while activating and driving an inclusive, high-performance culture 

Achievements 
•  Recognized for digital innovation with the 2021 Celent Model Bank 

Award for financial wellness; and recognized as a category winner by 
BAI Canada at its 2020 Global Innovation Awards for BMO CashTrackTM 
•  Ranked #1 by Insider Intelligence in its inaugural mobile banking ratings 
for digital money management, security and alerts, and in recognition of 
the positive effects of our digital-first approach on our customers’ 
banking experience 

•  Significantly increased the capacity of our front-line branch 

employees by transforming the cash ecosystem and eliminating, 
simplifying or centralizing key administrative activities 

•  Continued to grow our advice-based roles, strengthening our ability 
to engage with customers on the financial issues that are important 
to them 

2022 Focus 

•  Build on our strong franchise to drive growth and customer loyalty by continuing to invest in differentiating 

capabilities and delivering enhanced client experiences 
•  In Personal Banking, drive top-tier customer acquisition, build leading share of wallet, and enhance the digital 

experience to help customers make real financial progress 

•  In Commercial Banking, strengthen core market presence, accelerate growth in key sectors and continue to build 

share of wallet with strengthened digital capabilities 

•  Drive efficiencies by simplifying and streamlining operations, investing in digital capabilities and through cross-bank 

collaboration 

•  Foster an inclusive, winning culture, focused on alignment, empowerment and recognition, with a commitment 

to a diverse and inclusive workplace 

BMO Financial Group 204th Annual Report 2021  41 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Canadian P&C 

(1)

(Canadian $ in millions, except as noted) 
As at or for the year ended October 31 

Net interest income 
Non-interest revenue 

Total revenue 
Provision for credit losses on impaired loans 
Provision for (recovery of) credit losses on performing loans 

Total provision for credit losses 
Non-interest expense 

Income before income taxes 
Provision for income taxes 

Reported net income 

Amortization of acquisition-related intangible assets 

(2)

A
&
D
M

Adjusted net income 

Adjusted non-interest expense 

Key Performance Metrics and Drivers 

Personal revenue 
Commercial revenue 
Net income growth (%) 
Revenue growth (%) 
Non-interest expense growth (%) 
Adjusted non-interest expense growth (%) 
Return on equity (%) 
(3)
Adjusted return on equity (%) 
Operating leverage (%) 
Adjusted operating leverage (%) 
Efficiency ratio (%) 
Net interest margin on average earning assets (%) 
Average earning assets 
Average gross loans and acceptances 
Average net loans and acceptances 
Average deposits 
Full-time equivalent employees 

(3)

2021 

6,561 
2,225 

8,786 
493 
(116) 

377 
4,037 

4,372 
1,135 

3,237 
1 

3,238 

4,035 

2020 

6,105 
1,930 

8,035 
787 
623 

1,410 
3,892 

2,733 
706 

2,027 
2

2,029 

3,890 

5,325 
3,461 
59.7 
9.4 
3.7 
3.7 
28.7 
28.7 
5.7 
5.7 
45.9 
2.64 
248,215 
261,869 
260,359 
225,555 
14,697 

4,986 
3,049 
(22.7) 
0.6 
1.4 
1.5 
18.1 
18.1 
(0.8) 
(0.9) 
48.4 
2.60 
234,953 
250,223 
248,972 
204,942 
13,701 

2019 

5,885 
2,099 

7,984 
544 
63 

607 
3,836 

3,541 
917 

2,624 
2 

2,626 

3,834 

5,016 
2,968 
2.8 
5.2 
4.1 
4.1 
27.3 
27.3 
1.1 
1.1 
48.1 
2.65 
222,260 
236,889 
236,000 
175,125 
14,638 

(1)  Adjusted results and ratios in this table are non-GAAP amounts or ratios and are discussed in the Non-GAAP and Other 

Financial Measures section. 

(2)  Amortization of acquisition-related intangible assets pre-tax amounts of $2 million in each of fiscal 2021, fiscal 2020 and 

fiscal 2019 are recorded in non-interest expense. 

(3)  Return on equity is based on allocated capital. For further information, refer to the Non-GAAP and Other Financial Measures 

section. 

Revenue by Line of Business 
($ millions)

Personal 

Commercial

7,984 

2,968 

8,035 

3,049 

8,786

3,461 

5,016 

4,986 

5,325 

2019 

2020 

2021 

Average Deposits* 
($ billions) 

112.5 

Personal 

Commercial 

126.6 

130.1

95.4 

78.3 

62.7 

2019 

2020

2021

*Numbers may not add due to rounding. 

Average Gross Loans and Acceptances  *
($ billions) 

236.9 

80.5 

9.0 
46.7 

250.2 

88.7

8.7
48.4

100.8 

104.3

261.9

90.8 

8.2 
51.0 

111.9

2019 

2020

2021

Commercial 
Credit Cards 
Consumer Instalment and Other Personal 
Residential Mortgages 

*Numbers may not add due to rounding. 

42  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Review 
Canadian P&C reported net income was $3,237 million, an increase of $1,210 million or 60% from the prior year, driven by lower provisions for credit 
losses compared with elevated levels in the prior year and strong revenue growth, partially offset by an increase in expenses. 

Total revenue was $8,786 million, an increase of $751 million or 9% from the prior year. Net interest income increased $456 million or 7%, due 

to higher balances and higher loan margins, partially offset by lower deposit margins. Non-interest revenue increased $295 million or 15%, with 
higher revenue across most categories, including higher gains on investments in our commercial business and higher card-related revenue. Personal 
revenue increased $339 million or 7% from the prior year and commercial revenue increased $412 million or 14%, both due to higher net interest 
income and higher non-interest revenue. 

Net interest margin of 2.64% increased 4 basis points, primarily driven by higher loan margins and deposits growing faster than loans, partially 

offset by lower deposit margins that reflect the impact of the lower interest rate environment. 

Total provision for credit losses was $377 million, a decrease of $1,033 million from the prior year. The provision for credit losses on impaired 

loans was $493 million, a decrease of $294 million due to lower commercial and consumer provisions. There was a $116 million recovery of the 
provision for credit losses on performing loans in the current year, compared with a $623 million provision in the prior year. 

Reported non-interest expense was $4,037 million, an increase of $145 million or 4% from the prior year, reflecting investments in the business, 

including employee-related costs, as well as technology and marketing costs. 

Average gross loans and acceptances increased $11.6 billion or 5% from the prior year to $261.9 billion. Personal loan balances increased 7% 

and commercial loan balances increased 2%, while credit card balances decreased 6%. Average deposits increased $20.6 billion or 10% to 
$225.6 billion, reflecting higher levels of liquidity retained by customers, as well as strong customer acquisition. Personal deposits increased 3%, 
with strong growth in chequing and savings account deposits, partially offset by a decline in term deposits. Commercial deposits increased 22%. 
For further information on non-GAAP amounts, measures and ratios in this 2021 Operating Groups Performance Review section, refer to the 

Non-GAAP and Other Financial Measures section. 

M
D
&
A

Business Environment and Outlook 
Canadian P&C recorded strong results in fiscal 2021, demonstrating resilience during the pandemic and an ability to adapt quickly as the economy 
recovers. Our focus on supporting our customers in times of need, delivering exceptional customer service, leveraging digital capabilities by investing 
in new technologies, and diversifying our customer base are all key to successfully delivering on our strategy. 

Canadian banking customers continued to feel the effects of the COVID-19 pandemic, with ongoing lockdowns in the first half of the year and the 

extension of government support programs intended to ease financial hardship. We continued to support our customers as the Canadian economy 
began to recover in fiscal 2021, driven by sharp increases in vaccination rates and the relaxation of public health restrictions. Deposits have continued 
to grow despite rising levels of customer spending, and unsecured consumer and business borrowing volumes began to grow through the year, 
reflected in improved loan growth across our diverse portfolio of credit products. The housing market has experienced elevated activity, resulting 
in strong mortgage growth, further supported by investments in our sales force. The economic recovery is expected to continue in fiscal 2022, 
notwithstanding the ongoing uncertainty surrounding the course of the COVID-19 pandemic and the emergence of variants, with rising levels of 
consumer spending and business investment supporting further growth in our personal and commercial businesses. Housing market activity is 
expected to moderate but remain robust, while supply-chain disruptions, labour shortages and higher inflation rates continue to generate headwinds 
for the industry. Interest rates are expected to remain low in the near term, which could put modest pressure on margins, before rising in the 
medium term and supporting margin improvement. 

The Canadian financial services landscape remains highly competitive, with traditional and non-traditional competitors offering a wide range of 

banking products and services across physical and digital channels. Canadian P&C is well-positioned to compete in this rapidly-evolving landscape. 
With strong market share for our personal and commercial products and services, we continue to focus on building best-in-class customer loyalty by 
enhancing the customer experience with innovative products, services and digital solutions, while also improving efficiency. 

The Canadian economic environment in fiscal 2021 and the outlook for fiscal 2022 are discussed in more detail in the Economic Developments 

and Outlook section. 

Caution 
This Canadian Personal and Commercial Banking section contains forward-looking statements. Please refer to the Caution Regarding Forward-Looking Statements. 

BMO Financial Group 204th Annual Report 2021  43 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

U.S. Personal and Commercial Banking 

U.S. Personal and Commercial Banking serves more than two million customers by providing a banking experience with a 
human touch, while delivering a broad range of financial products and services. U.S. Personal Banking serves customers 
seamlessly across an extensive network of more than 520 branches, dedicated contact centres, digital banking platforms, 
and nationwide access to more than 40,000 automated teller machines. U.S. Commercial Banking serves clients across 
the United States, and our commercial bankers are trusted advisors and partners to their clients, offering sector and 
industry expertise, local presence and a comprehensive range of commercial products and services. 

A
&
D
M

Lines of Business  
Personal Banking offers a variety of products and services, including 
deposits, home lending, consumer credit, small business lending, credit 
cards and other banking services, with an overall focus on providing 
customers with an exceptional experience in every interaction and helping 
them make real financial progress. 

Commercial Banking provides clients with a wide range of commercial 
products and services, including multiple financing options and treasury 
and payment solutions, as well as risk management products. 
Commercial bankers partner with clients to anticipate their financial 
needs, and share expertise and knowledge to help them manage and 
grow their businesses. 

Strategy and Key Priorities 

2021 Priorities and Achievements 

Key Priority: Continue to improve customer loyalty, deepen primary relationships and support 
customers in the new operating environment 

Achievements 
•  Continued to strengthen customer loyalty in Personal Banking and 

maintained best-in-class customer loyalty in Commercial Banking, as 
measured by Net Promoter Score 

•  Supported customers experiencing financial hardship since the onset 
of the COVID-19 pandemic, and provided a total of US$6.5 billion in 
funding for more than 36,000 businesses through the SBA Paycheck 
Protection Program 

•  Reinforced our second-place ranking in market share for deposits in 
the core Chicago and Milwaukee markets, with a top-three position 
across our Midwest footprint 

•  Recognized on Forbes magazine’s World’s Best Banks 2021 list, based 
on a survey of consumers on key attributes, including trust, fees, digital 
services and financial advice 

•  Continued our partnership with 1871, a Chicago-based fintech private 
business incubator, in the WMN•FINtech program for a second year, 
focusing on mentoring women-led start-ups and reflecting our 
commitment to support an entrepreneurial innovation ecosystem 
•  Rated Outstanding by the Office of the Comptroller of the Currency 
on Community Reinvestment Act performance, recognizing our 
commitment to help support low- and moderate-income 
communities 

•  Deployed more than US$2 billion in loans and investments as part 

of BMO EMpowerTM, a five-year US$5 billion commitment to address 
key barriers faced by minority businesses and communities in the 
United States 

Key Priority: In Personal Banking, continue to drive new customer acquisition and deposit growth, 
build a flagship franchise in Small Business Banking and increase digital engagement 

Achievements 
•  Delivered strong core deposit growth, with 25% of transactions 

conducted through digital channels, supported by a robust product 
offering and pricing optimization 

•  Continued to enhance our Business Banking XpressTM (BBX) platform with 
more than 14,000 deposit and credit accounts opened across branch and 
digital channels since its launch 

•  Launched myFinancial CompassTM, a guided conversation tool that has 
seamlessly supported more than 275,000 advice-based conversations 
with high levels of customer satisfaction 

•  BMO Harris Smart MoneyTM  account awarded Bank OnTM  certification by 
the Cities for Financial Empowerment Fund, recognizing it as a safe and 
affordable banking service for financially underserved customers 

44  BMO Financial Group 204th Annual Report 2021 

•  Continued to increase digital engagement with customers, with the 

adoption rate rising by more than 300 basis points year-over-year and 
more than 75% of service transactions conducted through self-serve 
channels 

•  Introduced Savings BuilderTM, a rewards-based program for consumers 

and small businesses to help them build strong and consistent 
savings habits, with more than 90,000 new accounts opened to date 
•  Supported the removal of systemic barriers for small businesses, and 
empowered communities by introducing Black and Latinx and Women 
in Business programs 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Key Priority: In Commercial Banking, strengthen core market presence and continue to build share 
of wallet, strengthen digital capabilities and continue to leverage cross-bank collaboration 

Achievements 
•  Expanded our national presence with the opening of new offices in 
Florida and Colorado, and continued to grow in Texas, Georgia and 
other new markets 

•  Enhanced our offerings in high-value verticals such as healthcare 

by introducing asset-based lending and launching a multi-specialty 
Healthcare Council 

•  Continued to strengthen cross-border capabilities in order to improve 

the customer experience through technology platform changes 
related to wire transfers, receivables and billing processes 
•  Migrated our Transportation Finance business to Amazon Web 
Services (AWS), executing on our digital first strategy and our 
commitment to unlocking the power of machine learning to digitize 
and humanize the employee and customer experience 

Key Priority: Drive efficiencies by simplifying and streamlining operations and investing in digital 
capabilities, while activating and driving an inclusive, high-performance culture 

M
D
&
A

Achievements 
•  Expanded our relationship with financial technology leader FIS in a 

major multi-year modernization program that accelerates mobile digital 
solutions, supporting continued growth across our U.S. market 

•  Partnered with Lively, Inc. to introduce a new Health Savings Account 

experience for our customers, offering multiple investment options and 
providing financial tools that address rising healthcare costs 

•  Optimized our sales and service model to leverage cross-channel 

capacity across branches and contact centres 

•  Named one of the Best Places to Work for Disability Inclusion for 
the sixth consecutive year, achieving a maximum score of 100 on 
the Disability Equality Index 

•  Recognized by Forbes magazine as one of the Best Employers for 
Diversity for the third consecutive year, based on an independent 
survey of more than 50,000 U.S.-based employees 

2022 Focus 

•  Build on our strong franchise to drive growth and customer loyalty by continuing to invest in differentiating 

capabilities and delivering enhanced client experiences 
•  In Personal Banking, continue to drive new customer acquisition, increase digital engagement, and help customers 

make real financial progress 

•  In Commercial Banking, strengthen core market presence, drive growth in expansion markets and continue to build 

share of wallet with strengthened digital capabilities 

•  Drive efficiencies by simplifying and streamlining operations, investing in digital capabilities and through cross-bank 

collaboration 

•  Foster an inclusive, winning culture, focused on alignment, empowerment and recognition, with a commitment 

to a diverse and inclusive workplace 

BMO Financial Group 204th Annual Report 2021  45 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Revenue by Line of Business 
(US$ millions) 

Personal 

Commercial 

4,048 

4,113 

2,689 

2,820 

4,390

3,077 

1,359 

1,293 

1,313 

2019 

2020 

2021 

Average Deposits 
(US$ billions) 

Personal 

Commercial

62.9 

48.8  49.4 

48.0

45.1 

35.2 

2019 

2020 

2021 

Average Gross Loans and Acceptances*
(US$ billions)

85.5 
8.5
6.5

70.5 

92.2 

10.1 

5.7 

92.4

10.6 

4.5

76.4 

77.3

2019 

2020 

2021 

Personal Other Loans 
Personal Mortgages 
Commercial

*Personal Other Loans includes Business Banking, Indirect Auto,
 Credit Cards, Home Equity, Non-Strategic and other personal loans. 

MANAGEMENT’S DISCUSSION AND ANALYSIS 

U.S. P&C 

(1)

(Canadian $ in millions, except as noted) 
As at or for the year ended October 31 

Net interest income (teb) 
Non-interest revenue 

(2)

Total revenue (teb) 
Provision for credit losses on impaired loans 
Provision for (recovery of) credit losses on performing loans 

Total provision for (recovery of) credit losses 
Non-interest expense 

Income before income taxes 
Provision for income taxes (teb) 

Reported net income 

Amortization of acquisition-related intangible assets 

(3)

A
&
D
M

Adjusted net income 

Adjusted non-interest expense 

Average earning assets 
Average gross loans and acceptances 
Average net loans and acceptances 
Average deposits 

(US$ in millions, except as noted) 

Net interest income (teb) 
Non-interest revenue 

(4)

Total revenue (teb) 
Provision for credit losses on impaired loans 
Provision for (recovery of) credit losses on performing loans 

Total provision for (recovery of) credit losses 
Non-interest expense 

Income before income taxes 
Provision for income taxes (teb) 

Reported net income 

Amortization of acquisition-related intangible assets 

(5)

Adjusted net income 

Adjusted non-interest expense 

Key Performance Metrics and Drivers (US$ basis) 

Personal revenue 
Commercial revenue 
Net income growth (%) 
Adjusted net income growth (%) 
Revenue growth (%) 
Non-interest expense growth (%) 
Adjusted non-interest expense growth (%) 
Return on equity (%) 
(6)
Adjusted return on equity (%) 
Operating leverage (teb) (%) 
Adjusted operating leverage (teb) (%) 
Efficiency ratio (teb) (%) 
Adjusted efficiency ratio (teb) (%) 
Net interest margin on average earning assets (teb) (%) 
Average earning assets 
Average gross loans and acceptances 
Average net loans and acceptances 
Average deposits 
Full-time equivalent employees 

(6)

2021 

4,268 
1,243 

5,511 
22 
(166) 

(144) 
2,797 

2,858 
669 

2,189 
24 

2,213 

2,764 

2020 

4,345 
1,186 

5,531 
418 
441 

859 
3,075 

1,597 
320 

1,277 
39 

1,316 

3,022 

2019 

4,216 
1,162 

5,378 
160 
37 

197 
3,136 

2,045 
434 

1,611 
43 

1,654 

3,079 

122,166 
115,025 
116,039 
139,197 

130,190 
123,002 
123,953 
132,041 

119,640 
112,904 
113,620 
106,733 

3,400 
990 

4,390 
15 
(132) 

(117) 
2,229 

2,278 
534 

1,744 
19 

1,763 

2,203 

1,313 
3,077 
83.5 
80.0 
6.7 
(2.5) 
(2.0) 
15.9 
16.1 
9.2 
8.7 
50.8 
50.2 
3.49 
97,321 
92,439 
91,631 
110,910 
6,449 

3,231 
882 

4,113 
310 
328 

638 
2,287 

1,188 
237 

951 
30 

981 

2,248 

1,293 
2,820 
(21.6) 
(21.2) 
1.6 
(3.1) 
(3.0) 
8.3 
8.5 
4.7 
4.6 
55.6 
54.6 
3.34 
96,810 
92,170 
91,462 
98,203 
6,388 

3,173 
875 

4,048 
121 
28 

149 
2,360 

1,539 
327 

1,212 
32 

1,244 

2,317 

1,359 
2,689 
11.7 
11.1 
5.6 
2.6 
2.8 
11.0 
11.3 
3.0 
2.8 
58.3 
57.3 
3.53 
90,035 
85,505 
84,966 
80,316 
6,831 

(1)  Adjusted results and ratios, teb amounts and U.S. dollar amounts and ratios in this table are on a non-GAAP basis and are 

discussed in the Non-GAAP and Other Financial Measures section. 

(2)  Taxable equivalent basis amounts of $24 million in fiscal 2021, $28 million in fiscal 2020 and $34 million in fiscal 2019 are 

recorded in net interest income. 

(3)  Amortization of acquisition-related intangible assets pre-tax amounts of $33 million in 2021, $53 million in 2020 and 

$57 million in 2019 are recorded in non-interest expense. 

(4)  Taxable equivalent basis amounts of US$25 million in fiscal 2021, US$20 million in fiscal 2020 and US$25 million in 

fiscal 2019 are recorded in net interest income. 

(5)  Amortization of acquisition-related intangible assets pre-tax amounts of US$26 million in 2021, US$39 million in 2020 and 

US$43 million in 2019 are recorded in non-interest expense. 

(6)  Return on equity is based on allocated capital. For further information, refer to the Non-GAAP and Other Financial Measures 

section. 

46  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Review 
U.S. P&C reported net income was $2,189 million, an increase of $912 million or 71% from the prior year. The impact of the weaker U.S. dollar 
reduced net income growth by 12%, revenue growth by 7% and expense growth by 6%. U.S. P&C performance and metrics are presented and 
discussed on a U.S. dollar basis, which management views as useful in assessing the underlying performance due to the variability caused by changes 
in the U.S. dollar. All amounts in the remainder of this section are on a U.S. dollar basis. 

Reported net income was $1,744 million, an increase of $793 million or 84% from the prior year, primarily driven by lower provisions for credit 

losses compared with elevated levels in the prior year, strong revenue growth and reduced expenses. 

Total revenue was $4,390 million, an increase of $277 million or 7% from the prior year. Net interest income increased $169 million or 5% due 

to higher loan margins, growth in deposits and accelerated Paycheck Protection Program (PPP) revenue resulting from loan forgiveness, partially 
offset by lower deposit product margins. The PPP was a U.S. government relief program implemented in fiscal 2020 to reduce the financial hardship 
caused by the COVID-19 pandemic. Non-interest revenue increased $108 million or 12%, with higher revenue across most categories, primarily 
reflecting higher commercial lending-related fee revenue, advisory fee revenue and deposit fee revenue. Commercial revenue increased $257 million 
or 9% due to higher net interest income and non-interest income. Personal revenue increased $20 million or 2% due to higher net interest income. 
Net interest margin of 3.49% increased 15 basis points from the prior year, primarily due to higher loan margins, deposits growing faster than 
loans, and accelerated PPP revenue resulting from loan forgiveness, partially offset by lower deposit margins that reflected the impact of the lower 
interest rate environment. 

Total recovery of credit losses was $117 million, compared with a provision of $638 million in the prior year. The provision for credit losses on 

impaired loans decreased $295 million, largely due to lower commercial provisions in the current year. There was a $132 million recovery of the 
provision for credit losses on performing loans in the current year, compared with a $328 million provision in the prior year. 

Reported non-interest expense was $2,229 million, a decrease of $58 million or 3%, primarily due to lower operational costs in line with a 

continued focus on expense management, partially offset by higher employee-related costs, largely reflecting performance-based compensation. 

Average gross loans and acceptances were relatively unchanged at $92.4 billion, with commercial loan growth of 1%, offset by lower personal 

loan balances of 4%. The impact of the reduction in PPP loans reduced average loans and acceptances by $0.6 billion or 1%. Average deposits 
increased $12.7 billion or 13% to $110.9 billion, reflecting higher levels of liquidity retained by customers. Commercial deposits increased 27%, while 
personal deposits decreased 1%, as continued growth in chequing and savings account deposits was more than offset by a decline in term deposits. 
For further information on non-GAAP amounts, measures and ratios in this 2021 Operating Groups Performance Review section, refer to the 

Non-GAAP and Other Financial Measures section. 

M
D
&
A

Business Environment and Outlook 
The footprint of our U.S. P&C core branch network spans eight states (Illinois, Wisconsin, Missouri, Indiana, Minnesota, Kansas, Arizona and Florida). 
In addition, commercial banking offers targeted nationwide coverage of key specialty sectors and has offices in select regional markets, while the 
personal banking digital platform delivers our financial products and services nationally. 

Although still impacted by the COVID-19 pandemic, the U.S. economy began to recover in fiscal 2021, gaining strength as public health 
restrictions were gradually lifted. Consumers and businesses continued to add to their savings, aided by government support programs and rising 
employment rates. Borrowing remained muted, as high levels of savings led to continued strength in deposit growth and slower loan growth. 

The economy is expected to grow at a robust pace in the year ahead, although ongoing uncertainty surrounding the course of the COVID-19 
pandemic, labour shortages and supply-chain disruptions are still a concern. Consumers are benefiting from elevated levels of savings and growing 
employment, and some additional fiscal policy stimulus is also expected. Housing market activity is expected to remain healthy in fiscal 2022, 
supported by rising employment rates. Corporate credit growth is expected to accelerate, as rising business confidence leads to new investments. 
U.S. P&C remains committed to its customers, employees and local communities, and is well-positioned to grow despite a highly competitive 
environment. In commercial banking, our bankers have been working with our clients throughout the pandemic, providing them with a full range of 
deposit, lending and advisory solutions that are timely, relevant and supportive of their business. In personal banking, investments in technology 
continue to deliver improvements in speed, scale and efficiency, and are fuelling growth in digital and mobile adoption. 

The U.S. economic environment in fiscal 2021 and the outlook for fiscal 2022 are discussed in more detail in the Economic Developments and 

Outlook section. 

Caution 
This U.S. Personal and Commercial Banking section contains forward-looking statements. Please refer to the Caution Regarding Forward-Looking Statements. 

BMO Financial Group 204th Annual Report 2021  47 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

BMO Wealth Management 

BMO Wealth Management serves a full range of clients, from individuals and families to business owners and 
institutions, offering a wide spectrum of wealth, asset management and insurance products and services aimed 
at helping clients plan, grow, protect and transition their wealth. Our asset management business is focused on 
making a positive impact and delivering innovative client solutions. 

A
&
D
M

Lines of Business  
BMO Private Wealth provides full-service investing, banking and wealth 
advisory services to high net worth and ultra-high net worth clients, 
leveraging individualized financial planning and advice-based solutions 
such as investment management, business succession planning, trust and 
estate services, and philanthropy. 

BMO InvestorLine leads Wealth Management’s digital investing services, 
offering three ways for Canadian clients to invest: BMO InvestorLine’s self-
directed online trading platform for investors who want to be in control of 
their investments; BMO InvestorLine’s adviceDirect™ for investors who 
want the freedom to make their own investment decisions with 
personalized advice and support; and SmartFolio™ for investors who want 
low-fee, professionally managed portfolios aligned with their investment 
objectives. 

BMO Wealth Management U.S. offers financial solutions to mass 
affluent, high net worth and ultra-high net worth families and 
businesses. 

BMO Global Asset Management provides investment management 
services to institutional, retail and high net worth investors, offering a 
wide range of innovative, client-focused solutions and strategies to 
help clients meet their investment objectives. 

BMO Insurance is a diversified insurance and wealth solutions provider 
and a leader in pension de-risking solutions. It manufactures individual 
life, critical illness and annuity products, as well as segregated funds. 
Group creditor and travel insurance is also available to bank customers 
in Canada through Bank of Montreal. 

Strategy and Key Priorities 

2021 Priorities and Achievements 

Key Priority: Deliver a differentiated client experience, providing outstanding support and working 
together to plan, grow, protect and transition their wealth with confidence 

Achievements 
•  Achieved overall record-high client loyalty scores, affirming the 

responsiveness and expertise of our teams, the value of our holistic 
approach and the results of our proactive outreach in support of clients 
•  BMO Private Banking was named Best Private Bank in Canada by World 
Finance magazine for the 11th consecutive year, in recognition of our 
client-centric approach to navigating the complexity of managing our 
clients’ wealth during times of uncertainty 

•  Continued to evolve our digital capabilities, introducing a new facial 

recognition option in the account opening process for BMO Nesbitt Burns 
clients and simplifying the digital onboarding experience for BMO 
InvestorLine clients, tripling our self-serve application completion rate 
since 2018 

•  BMO Wealth Management U.S. deepened its presence in the Bay Area 
(California), Atlanta and Dallas, continuing to expand its national reach 

•  Integrated our North American ultra-high net worth offerings and 

infrastructure with the bespoke capabilities of the BMO Family Office, 
a focus on alternative investments and curated client experiences 

•  Expanded our digital advisory capabilities with the launch of 

adviceDirect™ Preview and Premium, and offered access to more 
Canadian online investors by lowering minimum balances, allowing 
more commission-free trades and changing our fee structure for 
advisory services 

•  Enhanced our self-directed and adviceDirect™ trading platforms, 

including extended capabilities in research, education and portfolio 
management support, as well as simplified trading procedures 
•  Launched commission-free trading for self-directed clients on more 

than 80 exchange traded funds (ETFs) 

48  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Key Priority: Extend advantage as a solutions provider, delivering innovative asset management 
and insurance offerings that anticipate clients’ evolving needs and exceed their expectations 

Achievements 
•  Maintained our leadership position in Canadian ETFs, continuing to rank 
#1 in net new asset growth, launched a suite of Innovation Index ETFs 
and added to our Environmental, Social and Governance (ESG) ETF line-up 
•  Recognized for the sustained performance of 25 BMO funds and ETFs at 
the annual FundGrade A+® Awards, including 18 ETFs and seven mutual 
funds 

•  Refreshed our Global Asset Management Trading platform with 

improved process automation to enhance overall client experience and 
satisfaction 

•  Enhanced BMO Insurance products and services with a suite of 

ESG investment options for Universal Life Insurance and Segregated 
Funds policyholders and an accelerated underwriting process that 
offers important life insurance protection without requiring tests or 
examinations 

•  Reinforced our leadership position in pension de-risking, securing 
two of our largest transactions to date and doubling total annual 
premiums from the prior year 

Key Priority: Build on a strong foundation and continue to evolve, simplify and digitize our businesses 
to drive value and efficiencies 

M
D
&
A

Achievements 
•  Finalized the sale of our Private Banking business in Hong Kong and 
Singapore and the sale of EMEA Asset Management as we reposition 
and grow our operations across our core North American footprint 
•  Streamlined money management by digitizing the set-up and use of 
electronic fund transfers and introducing real-time cash transfers from 
Personal Banking accounts to BMO Nesbitt Burns accounts 

•  BMO Wealth Management U.S. completed the outsourcing of middle-
and back-office broker dealer functions through a partnership with 
LPL Financial, enhancing our premium brokerage and advisory 
services with a more robust digital platform and innovative solutions 
to meet the evolving needs of our clients 

•  BMO InvestorLine launched a new self-serve option for opening 

margin and registered retirement income fund accounts 

Key Priority: Activate and drive an inclusive, high-performance culture, with a commitment to building 
diverse and inclusive teams to bring the best of BMO to all clients 

Achievements 
•  Launched a collaborative Wealth Sponsorship Program with insights 
from the chairs of the Black Professionals Network and the Latino 
Alliance, as part of the Wealth Racial Equity Action Plan 

•  Ranked first in the Stewardship and Market Education categories at the 
Responsible Investment Association’s 2021 Leadership Awards for our 
efforts to extend Canadian diversity and inclusion beyond gender, as 
well as the development and launch of the MyESGTM  analytics tool 

•  BMO Family Office received the 2021 Diversity in Wealth 

Management Award from the Family Wealth Report, recognizing our 
commitment to diversity in the workplace 

•  Solidified BMO’s position as a premium wealth advisor for business 
owners by continuing the collaboration between Advisory and 
Commercial Banking teams to help clients navigate the uncertainty 
around proposed tax changes in the United States, which led to a 
year-over-year increase of more than 70% in revenue from clients 
referred by Commercial Banking 

2022 Focus 

•  Deliver a top-tier digital wealth management offering, building on our differentiated digital advisory capabilities 

to provide an enhanced client experience 

•  Scale our leadership position in private wealth advisory services across North America to plan, grow, protect and 

transition our clients’ wealth with confidence 

•  Extend our advantage as a solutions provider, expanding asset management and insurance offerings in key 

growth areas 

•  Enhance efficiencies by continuing to evolve, simplify and streamline our businesses to drive value 
•  Foster an inclusive, winning culture, focused on alignment, empowerment and recognition, with a commitment 

to a diverse and inclusive workplace 

BMO Financial Group 204th Annual Report 2021  49 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

BMO Wealth Management 

(1)

(Canadian $ in millions, except as noted) 
As at or for the year ended October 31 

Net interest income 
Non-interest revenue 

Total revenue 
Insurance claims, commissions and changes in policy benefit 

liabilities (CCPB) 

Revenue, net of CCPB 
Provision for credit losses on impaired loans 
Provision for (recovery of) credit losses on performing loans 

Total provision for (recovery of) credit losses 
Non-interest expense 

Income before income taxes 
Provision for income taxes 

Reported net income 

Amortization of acquisition-related intangible assets 
Reinsurance adjustment 
(3)

(2)

Adjusted net income 

Adjusted non-interest expense 

Key Performance Metrics and Drivers 

A
&
D
M

Traditional wealth businesses net income 
Traditional wealth businesses adjusted net income 
Insurance net income 
Insurance adjusted net income 
Net income growth (%) 
Adjusted net income growth (%) 
Revenue growth (%) 
Revenue growth, net of CCPB (%) 
Adjusted CCPB 
Revenue growth, net of adjusted CCPB (%) 
Non-interest expense growth (%) 
Adjusted non-interest expense growth (%) 
Return on equity (%) 
(4)
Adjusted return on equity (%) 
Operating leverage, net of CCPB (%) 
Adjusted operating leverage, net of CCPB (%) 
Efficiency ratio, net of CCPB (%) 
Adjusted efficiency ratio, net of CCPB (%) 
Average common equity 
Average assets 
Average gross loans and acceptances 
Average net loans and acceptances 
Average deposits 
Assets under administration (AUA) 
Assets under management (AUM) 
Full-time equivalent employees 

(5)

(4)

U.S. Business Select Financial Data (US$ in millions) 

Total revenue 
Non-interest expense 
Reported net income 
Adjusted non-interest expense 
Adjusted net income 
Average net loans and acceptances 
Average deposits 

2021 

2020 

2019 

1,474 

Reported Net Income 
($ millions)  

AUA and AUM  *
($ billions) 

1,059 

1,096 

2019 

2020 

2021 

864.7 

471.2 

894.5

482.6 

950.7 

523.3 

393.6 

412.0 

427.4 

2019 

2020 

2021 

AUA 

AUM 

*Numbers may not add due to rounding. 

2021 Net Revenue by Line of Business 
(%) 

11%  BMO Wealth

 Management U.S.

 8%  BMO Insurance 

29%  BMO Global Asset 
Management 

44%  BMO Private Wealth

 8%  BMO InvestorLine 

982 
6,071 

7,053 

1,399 

5,654 
4 
(16) 

(12) 
3,716 

1,950 
476 

1,474 
24 
– 

1,498 

3,685 

1,228 
1,252 
246 
246 
34.4 
32.5 
5.1 
13.1 
1,399 
13.1 
5.6 
6.1 
24.9 
25.3 
7.5 
7.0 
65.7 
65.2 
5,899 
48,232 
28,920 
28,880 
51,030 
427,446 
523,270 
6,329 

625 
489 
104 
482 
109 
4,878 
7,321 

900 
5,808 

6,708 

1,708 

5,000 
4
18 

22 
3,519 

1,459 
363 

1,096 
34 
–

1,130 

3,476 

893 
927 
203 
203 
3.5 
0.8 
(12.4) 
1.0 
1,708 
0.5 
(0.1) 
– 
17.1 
17.7 
1.1 
0.5 
70.4 
69.5 
6,364 
45,573 
26,585 
26,547 
43,660 
411,959 
482,554 
6,193 

935 
6,727 

7,662 

2,709 

4,953 
2 
(2) 

– 
3,523 

1,430 
371 

1,059 
37 
25 

1,121 

3,476 

861 
898 
198 
223 
(1.1) 
0.8 
21.6 
0.1 
2,684 
0.6 
0.2 
0.3 
16.7 
17.7 
(0.1) 
0.3 
71.1 
69.8 
6,321 
40,951 
23,519 
23,487 
36,419 
393,576 
471,160 
6,374 

583 
504 
61 
495 
68 
4,540 
6,471 

613 
512 
77 
501 
85 
4,156 
5,794 

(1)  Revenue measures, net of CCPB, adjusted results and ratios, including operating leverage and efficiency ratio, and U.S. dollar 

amounts in this table are on a non-GAAP basis and discussed in the Non-GAAP and Other Financial Measures section. 
(2)  Amortization of acquisition-related intangible assets pre-tax amounts of $31 million in 2021, $43 million in 2020 and 

$47 million in 2019 are recorded in non-interest expense. 

(3)  Fiscal 2019 reported net income included a reinsurance adjustment of $25 million (pre-tax and after-tax) for the net impact 
of major reinsurance claims incurred after the wind-down of the reinsurance business. This reinsurance adjustment is 
included in CCPB. 

(4)  Return on equity is based on allocated capital. For further information, refer to the Non-GAAP and Other Financial Measures 

section. 

(5)  Certain assets under management that are also administered by BMO are included in assets under administration. 

50  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Review 
BMO Wealth Management reported net income was $1,474 million, an increase of $378 million or 34% from the prior year, primarily driven by revenue 
growth, partially offset by an increase in expenses. 

Traditional Wealth reported net income was $1,228 million, an increase of $335 million or 38% from the prior year. Insurance net income was 

$246 million, an increase of $43 million or 21% from the prior year. 

We also present reported and adjusted revenue on a basis that is net of insurance claims, commissions and changes in policy benefit liabilities 

(CCPB), and we calculate our efficiency ratio and operating leverage on a similar basis. Insurance revenue can experience variability arising from 
fluctuations in the fair value of insurance assets, caused by movements in interest rates and equity markets, that is largely offset in CCPB. Presenting 
our revenue, efficiency ratio and operating leverage on a net basis allows for a better assessment of operating results. 

Revenue was $7,053 million, an increase of $345 million or 5% from the prior year. Revenue, net of CCPB, was $5,654 million, an increase of 
$654 million or 13%. Revenue in Traditional Wealth was $5,178 million, an increase of $585 million or 13% from the prior year, due to higher non-
interest revenue of $503 million resulting from growth in client assets, including the favourable effects of stronger global markets, an increase in 
online brokerage revenue and the impact of a legal provision in the prior year, partially offset by the impact of the weaker U.S. dollar. Net interest 
income increased $82 million, primarily due to strong deposit and loan growth and the impact of a legal provision in the prior year, partially offset by 
lower margins and the impact of the weaker U.S. dollar. Reported insurance revenue was $1,875 million, a decrease of $240 million or 11% from the 
prior year. Insurance revenue, net of CCPB, was $476 million, an increase of $69 million or 17%, primarily due to the impact of more favourable 
market movements in the current year, and business growth, partially offset by lower benefits from changes in investments to improve asset liability 
management and the unfavourable impact of actuarial assumption changes in the current year. 

The total recovery of provisions for credit losses was $12 million, compared with a provision of $22 million in the prior year. The provision for 
credit losses on impaired loans was unchanged from the prior year. There was a $16 million recovery of the provision for credit losses on performing 
loans in the current year, compared with an $18 million provision in the prior year. 

Reported non-interest expense was $3,716 million, an increase of $197 million or 6% from the prior year, primarily due to higher revenue-based 

costs, technology-related investments and a legal provision in the current year, partially offset by the impact of the weaker U.S. dollar. 

Assets under management increased $40.7 billion or 8%, and assets under administration increased $15.5 billion or 4% from the prior year, 
primarily due to higher client assets, including stronger global markets, partially offset by attrition resulting from low-yielding assets and foreign 
exchange rate movements. Average gross loans and average deposits increased 9% and 17%, respectively. 

For further information on non-GAAP amounts, measures and ratios in this 2021 Operating Groups Performance Review section, refer to the 

Non-GAAP and Other Financial Measures section. 

M
D
&
A

Business Environment and Outlook 
The wealth management business remains attractive and highly competitive. We are well-positioned to benefit from emerging industry trends, 
including the accelerated adoption of digital channels, by leveraging our planning and advisory offerings, our integrated business model, strong client 
loyalty and investments in our digital capabilities and sales force. Traditional competitors continue to expand their advisory sales forces and product 
offerings, including exchange traded funds and alternative investment solutions, to meet customers’ evolving needs. Non-traditional competitors 
have continued to gain momentum and are differentiating their offerings by delivering an enhanced digital experience, while also entering niche 
markets. In fiscal 2021, BMO Wealth Management benefitted from growing momentum in both the equity markets and the economy, as continued 
high levels of client trading activity drove robust volume growth. Results were also impacted by the continued low interest rate environment, which 
has put pressure on margins, as well as clients’ preference for investments that carry lower management fees. We continue to provide our clients 
with expert advice, as we assist them in navigating through volatile and uncertain market conditions. We have introduced new and differentiated 
products and enhanced our digital advisory capabilities, all of which led to strong growth in net new assets, deposits, loans and our online brokerage 
client base. 

The outlook for equity markets could shift quickly if the economy is further impacted by supply-chain disruptions, labour shortages, rising 

inflation rates and geopolitical factors, including ongoing uncertainty relating to public health restrictions. Interest rates are expected to remain 
historically low in the near term before rising slowly, which would positively affect margins and insurance revenue. Online brokerage transaction 
levels moderated in the second half of fiscal 2021, but are expected to remain above pre-pandemic levels. BMO InvestorLine continues to attract new 
clients through digital platform enhancements, as well as the launch of adviceDirect™ Preview and Premium, and is expanding access to adviceDirect™ 
for more Canadians with a lower minimum investment balance required for entry. 

The divestiture of our Private Banking business in Hong Kong and Singapore and the sale of our EMEA Asset Management business, which closed 
on November 8, 2021, will reduce revenue and expenses, improve efficiency and return on equity, and are expected to have a modest impact on our 
income in fiscal 2022. 

The Canadian and U.S. economic environment in fiscal 2021 and the outlook for fiscal 2022 are discussed in more detail in the Economic 

Developments and Outlook section. 

Caution 
This BMO Wealth Management section contains forward-looking statements. Please refer to the Caution Regarding Forward-Looking Statements. 

BMO Financial Group 204th Annual Report 2021  51 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

BMO Capital Markets 

BMO Capital Markets is a North American-based financial services provider offering a complete range of products and 
services to corporate, institutional and government clients. BMO Capital Markets has approximately 2,600 
professionals in 32 locations around the world, including 18 offices in North America. 

A
&
D
M

Lines of Business  
Investment and Corporate Banking offers debt and equity capital-raising 
services to clients, as well as loan origination and syndication, balance 
sheet management solutions and treasury management services. 
The division also provides clients with strategic advice on mergers and 
acquisitions (M&A), restructurings and recapitalizations, trade finance and 
risk mitigation services to support international business activities, and a 
wide range of banking and other operating services tailored to North 
American and international financial institutions. 

Global Markets offers research and access to financial markets for 
institutional, corporate and retail clients through an integrated suite of 
sales and trading solutions that include debt, foreign exchange, interest 
rate, credit, equity, securitization and commodities. New product 
development and origination services are also offered, as well as risk 
management advice and services to hedge against fluctuations in a 
variety of key inputs, including interest rates and commodities prices. 
In addition, Global Markets provides funding and liquidity management 
to clients. 

Strategy and Key Priorities 

2021 Priorities and Achievements 

Key Priority: Expand on our strengths and capabilities to deliver value-added solutions and meet client 
needs 

Achievements 
•  Continued a leadership role in M&A with strong global expertise 

across sectors and deep client relationships, advising on landmark 
transactions such as the US$2.5 billion acquisition of Core-Mark by 
Performance Food Group 

•  Supported clients with top-tier market insights and facilitated 

groundbreaking initial public offerings, including Magnet Forensics and 
*
Alphawave IP; ranked #1  in Canadian Equity Capital Markets, leading 
high-profile financings such as Algonquin Power 

•  Advanced our commitment of people and capital to serve as 

our clients’ lead partner in the transition to a net zero world by: 
•  Establishing an Energy Transition Group 
•  Providing expertise and support across industries 
•  Delivering industry-leading, innovative sustainable financing 
solutions, including the first labelled Green Loan and the first 
sustainability-linked bond in Canada, and ranked #1  in Canadian 
sustainable bond underwriting 

*

•  Built out a U.S. Commercial Mortgage-Backed Securities team, 

•  Recognized as a leader with top rankings  in U.S. sovereign, 

*

leveraging both our securitized products platform and our North 
American Real Estate banking coverage, and originated and securitized 
more than US$1.2 billion in commercial real estate loans 

•  Maintained a long-standing global leadership position in the Metals 
& Mining sector, earning recognition as the Best Metals & Mining 
Investment Bank by Global Finance magazine for the 12th consecutive 
year 

supranational and agency (SSA) issuances, Canadian options and 
Canadian structured rates, and maintained BMO’s position at the 
forefront of U.S. secured overnight financing rate (SOFR) debt 
underwriting, ranking #1  since the offering was launched in 2018 

*

•  Recognized at the International Business Awards 2021 for the 

marketing campaigns for our digital series Road to Recovery and 
our podcast series Sustainability Leaders 

*  Rankings as in Bloomberg Professional Services’ league tables. 

52  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Key Priority: Build on a solid foundation to work smarter, simplify and digitize to enhance efficiencies 

Achievements 
•  Expanded electronic foreign exchange (eFX) capabilities, introducing 
new foreign-exchange functionality in our Commercial Banking 
platform and launching an eFX retail platform 

•  With the 2020 acquisition of Clearpool Group, Inc., doubled our 

algorithmic trading market share in Canada, simplified workflow, 
provided clients with a highly differentiated and customized trading 
experience, and expanded electronic trading capabilities to Europe 
•  Partnered with Riskfuel Analytics Inc. to deliver innovative artificial 
intelligence-based solutions that support clients as they prepare to 
make faster, smarter investment decisions 

•  Deployed technology enhancements, workflow tools and process 
automation to increase employee productivity. Over three years, 
our employees achieved real-time efficiencies that led to time 
savings totalling approximately three-quarters of our Million Hour 
Challenge objective 

•  Pivoted conferences to fully digital platforms, with corporate 

attendance at 18 conferences up more than 100% 

Key Priority: Activate an inclusive, high-performance culture focused on clients, strong partnerships 
and alignment, and a commitment to diversity, equity and inclusion 

M
D
&
A

Achievements 
•  Leveraged improvements in technology and real estate to transform 
our workplaces and enhance the client and employee experience 
across our global footprint 

•  Launched innovative programs and sponsorships to drive greater 

equity and inclusion across our workforce, industry and communities 

•  Launched the inaugural BMO Women in Business bond offering, the 
first of its kind in the Canadian market, with proceeds allocated to 
women-owned business lending, including financing for micro, small 
and medium-sized enterprises 

2022 Focus 

•  Accelerate growth in areas where we are well-positioned and have the expertise and capabilities to deliver 

value-added solutions and provide an enhanced client experience 

•  Deploy digital-first capabilities with an increased focus on data, analytics and artificial intelligence to drive 

simplification and scale 

•  Become an industry leader in sustainable finance, providing advice and innovative solutions to help our clients 

reach their environmental, social and governance objectives 

•  Foster and drive an inclusive, winning culture, focused on alignment, empowerment and recognition, with 

a commitment to a diverse and inclusive workplace 

BMO Financial Group 204th Annual Report 2021  53 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reported Net Income 
($ millions)

2,140 

1,091 

1,087 

2019 

2020 

2021 

Revenue by Line of Business 
($ millions)

Global Markets 

Investment and 
Corporate Banking

6,126

2,521 

5,326

2,104 

3,222 

3,605 

4,759

2,055 

2,704 

2019 

2020 

2021

Revenue by Geography 
(%)

Canada and 
Other Countries 

United States 

45% 

47% 

49% 

55% 

53% 

51%

2019 

2020 

2021

A
&
D
M

MANAGEMENT’S DISCUSSION AND ANALYSIS 

BMO Capital Markets 

(1)

(Canadian $ in millions, except as noted) 
As at or for the year ended October 31 

Net interest income (teb) 
Non-interest revenue 

(2)

Total revenue (teb) 
Provision for credit losses on impaired loans 
Provision for (recovery of) credit losses on performing loans 

Total provision for (recovery of) credit losses 
Non-interest expense 

Income before income taxes 
Provision for income taxes (teb) 

Reported net income 

Acquisition integration costs 
Amortization of acquisition-related intangible assets 

(3)

(4)

Adjusted net income 

Adjusted non-interest expense 

Key Performance Metrics and Drivers 

Global Markets revenue 
Investment and Corporate Banking revenue 
Net income growth (%) 
Adjusted net income growth (%) 
Revenue growth (%) 
Non-interest expense growth (%) 
Adjusted non-interest expense growth (%) 
Return on equity (%) 
(5)
Adjusted return on equity (%) 
Operating leverage (teb) (%) 
Adjusted operating leverage (teb) (%) 
Efficiency ratio (teb) (%) 
Adjusted efficiency ratio (teb) (%) 
Average common equity 
Average assets 
Average gross loans and acceptances 
Average net loans and acceptances 
Full-time equivalent employees 

(5)

U.S. Business Select Financial Data (US$ in millions) 

Total revenue (teb) 
Non-interest expense 
Reported net income 
Adjusted net income 
Adjusted non-interest expense 
Average assets 
Average net loans and acceptances 

2021 

3,115 
3,011 

6,126 
11 
(205) 

(194) 
3,436 

2,884 
744 

2,140 
7 
17 

2,164 

3,405 

3,605 
2,521 
96.9 
94.1 
15.0 
6.2 
6.4 
19.2 
19.5 
8.8 
8.6 
56.1 
55.6 
10,913 
372,475 
59,385 
58,909 
2,597 

2,373 
1,288 
857 
876 
1,263 
127,619 
25,249 

2020 

3,320 
2,006 

5,326 
310 
349 

659 
3,236 

1,431 
344 

1,087 
11 
18 

1,116 

3,199 

3,222 
2,104 
(0.4) 
(0.2) 
11.9 
(1.3) 
(1.4) 
9.2 
9.5 
13.2 
13.3 
60.8 
60.1 
11,353 
369,518 
68,698 
68,303 
2,678 

1,865 
1,152 
279 
299 
1,125 
116,307 
26,161 

2019 

2,390 
2,369 

4,759 
52 
28 

80 
3,279 

1,400 
309 

1,091 
10 
17 

1,118 

3,244 

2,704 
2,055 
(5.9) 
(4.7) 
8.5 
13.9 
13.4 
9.9 
10.1 
(5.4) 
(4.9) 
68.9 
68.2 
10,430 
342,626 
60,819 
60,731 
2,772 

1,609 
1,197 
292 
312 
1,171 
107,185 
21,662 

(1)  Adjusted results and ratios, teb amounts and U.S. dollar amounts in this table are on a non-GAAP basis and are discussed in 

the Non-GAAP and Other Financial Measures section. 

(2)  Taxable equivalent basis amounts of $291 million in fiscal 2021, $307 million in fiscal 2020 and $262 million in fiscal 2019 

are recorded in net interest income. 

(3)  KGS-Alpha and Clearpool pre-tax acquisition integration costs of $9 million in 2021, $14 million in 2020 and $13 million 

in 2019 are recorded in non-interest expense. 

(4)  Amortization of acquisition-related intangible assets pre-tax amounts of $22 million in 2021, $23 million in 2020 

and $22 million in 2019 are recorded in non-interest expense. 

(5)  Return on equity is based on allocated capital. For further information, refer to the Non-GAAP and Other Financial Measures 

section. 

54  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Review 
BMO Capital Markets reported net income was $2,140 million, an increase of $1,053 million or 97% from the prior year. Recoveries of provisions for 
credit losses and revenue growth were partially offset by an increase in expenses. 

Revenue was $6,126 million, an increase of $800 million or 15% from the prior year. Global Markets revenue increased $383 million or 12%, 
primarily due to higher equities trading revenue, as well as higher levels of new equity and debt issuances, partially offset by lower interest rate and 
commodities trading revenue and the impact of the weaker U.S. dollar. The prior year included negative impacts from equity linked notes-related 
businesses. Investment and Corporate Banking revenue increased $417 million or 20%, primarily due to higher net securities gains and underwriting 
and advisory revenue, partially offset by lower corporate banking-related revenue and the impact of the weaker U.S. dollar. The prior year was 
impacted by markdowns on the held-for-sale loan portfolio. 

Total recovery of credit losses was $194 million, compared with a provision for credit losses of $659 million in the prior year. The provision for 
credit losses on impaired loans was $11 million, a decrease of $299 million from the prior year. There was a recovery of the provision for credit losses 
on performing loans of $205 million in the current year, compared with a provision of $349 million in the prior year. 

Reported non-interest expense was $3,436 million, an increase of $200 million or 6% from the prior year. The increase was largely due to higher 

performance-based compensation, partially offset by the impact of the weaker U.S. dollar and lower travel and business development costs. 

Average gross loans and acceptances decreased $9.3 billion or 14% from the prior year to $59.4 billion, primarily due to lower loan utilizations, 

the impact of the weaker U.S. dollar and the announced wind-down of our non-Canadian energy portfolio. 

For further information on non-GAAP amounts, measures and ratios in this 2021 Operating Groups Performance Review section, refer to the 

Non-GAAP and Other Financial Measures section. 

M
D
&
A

Business Environment and Outlook 
In fiscal 2021, BMO Capital Markets continued to execute on a strategy that leverages its balanced, diversified and client-focused business model, 
while maintaining disciplined risk management. The business benefitted from ongoing high levels of client activity, robust equity prices and 
favourable conditions for investment banking services, all of which contributed to strong results, despite lingering uncertainty surrounding the 
COVID-19 pandemic and the emergence of new variants, the normalization of market volatility, the low interest rate environment and muted loan 
demand. 

BMO Capital Markets is emerging from the pandemic as a stronger, more efficient and better-integrated organization. Looking ahead to 
fiscal 2022, the pace of economic recovery remains uncertain, despite high rates of vaccination in certain regions. Supply-chain disruptions, labour 
shortages and higher inflation rates continue to generate headwinds for our business. However, mergers and acquisitions activity is expected to 
remain robust, as it benefits from active private equity funds and supportive debt and equity markets. BMO Capital Markets’ strategy remains 
unchanged: a sharp focus on clients, aiming to be their valued financial partner – leveraging talent, innovative solutions and capital to help them 
achieve their goals while deploying digital-first solutions that drive simplification and scale. With a leading position in Canada and strong momentum 
in the United States, our investments in product offerings and capabilities that help us serve clients, particularly where BMO has core strengths and 
opportunities, are building a solid foundation for profitable growth and sustainable returns. In addition, BMO Capital Markets’ disciplined and 
integrated approach to risk management, along with continued investments in technology infrastructure, is expected to position the business well to 
adapt to evolving regulatory and compliance requirements in the coming years. BMO Capital Markets has also made sustainability and sustainable 
finance a core part of its strategy, providing innovative financing solutions and advice to support clients in the accelerating shift to a more sustainable 
economy. 

The Canadian and U.S. economic environment in fiscal 2021 and the outlook for fiscal 2022 are discussed in more detail in the Economic 

Developments and Outlook section. 

Caution 
This BMO Capital Markets section contains forward-looking statements. Please refer to the Caution Regarding Forward-Looking Statements. 

BMO Financial Group 204th Annual Report 2021  55 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Corporate Services, including Technology and Operations 

A
&
D
M

Corporate Services consists of Corporate Units and Technology and Operations (T&O). Corporate Units provide enterprise-wide expertise, governance 
and support in a variety of areas, including strategic planning, risk management, treasury, finance, legal and regulatory compliance, human resources, 
communications, marketing, real estate and procurement. T&O develops, monitors, manages and maintains governance of information technology, 
including data and analytics, and provides cyber security and operations services. 

Corporate Services focuses on enterprise-wide priorities related to maintaining a sound risk and control environment and regulatory compliance, 

including the management, assessment and monitoring of BMO’s investment portfolios, funding, liquidity and capital activities, and credit, foreign 
exchange and interest rate risks. In support of the operating segments, Corporate Services develops and implements enterprise-wide processes, 
systems and controls to maintain operating efficiency and enable our businesses to adapt and meet their customer experience objectives. 

The costs of Corporate Units and T&O services are largely allocated to the four operating segments (Canadian P&C, U.S. P&C, BMO Wealth 
Management and BMO Capital Markets), with any remaining amounts retained in Corporate Services results. As such, Corporate Services results 
largely reflect the impact of residual treasury-related activities, the elimination of taxable equivalent adjustments, and residual unallocated expenses. 

Achievements 
•  Advanced BMO’s digital first operating model by delivering digitally 

driven customer experiences through various initiatives 

•  Continued to advance the capabilities of our Financial Crimes Unit (FCU) 
to respond to a heightened and evolving threat landscape by further 
integrating our cyber, fraud, physical security and crisis management 
functions into a single cohesive security team. Technology, people and 
process areas of focus included enhancing detection and response 
capabilities, improving identity and access management, and ensuring 
resilience against virtual and physical attacks 

•  Supported an accelerated adoption of cloud-based solutions, 

strengthened cloud service delivery partnerships and built out a 
foundational platform to equip BMO with a new generation of security 
and monitoring capabilities and the flexibility to adapt in an ever-
changing security landscape 

•  Further enhanced our artificial intelligence and data and analytics 
capabilities across the bank, and supported business initiatives 
that have earned global recognition and awards. Research and 
exploration focused on emerging technology innovation is 
continuing, as new opportunities are identified 

•  Sustained delivery of critical technology services and operations 
across the enterprise, continuously improving foundational 
capabilities to build resilience and scalability and elevate the overall 
technology-enabled experience for customers and employees 
•  Continued to focus on elevating the employee experience through 
enterprise digital technology tools, and on facilitating a prudent 
return to the workplace 

56  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Corporate Services, including Technology and Operations 

(1)

(Canadian $ in millions, except as noted) 
As at or for the year ended October 31 

Net interest income before group teb offset 
Group teb offset 

Net interest income (teb) 
Non-interest revenue 

Total revenue (teb) 
Provision for (recovery of) credit losses on impaired loans 
Provision for (recovery of) credit losses on performing loans 

Total provision for (recovery of) credit losses 
Non-interest expense 

Income (loss) before income taxes 
Recovery of income taxes (teb) 

Reported net loss 

Impact of divestitures 
Restructuring costs (reversals) 

(2)

(3)

Adjusted net loss 

(4)

Adjusted total revenue (teb) 
(4)
Adjusted non-interest expense 
Full-time equivalent employees 

(4)

U.S. Business Select Financial Data (US$ in millions) 

Total revenue 
Total provision for (recovery of) credit losses 
Non-interest expense 
Recovery of income taxes 

Reported net loss 

Adjusted total revenue 
Adjusted non-interest expense 
Adjusted net loss 

2021 

(301) 
(315) 

(616) 
326 

(290) 
(5) 
(2) 

(7) 
1,523 

(1,806) 
(520) 

(1,286) 
842 
(18) 

(462) 

(319) 
661 
13,791 

(26) 
(6) 
182 
(90) 

(112) 

(26) 
164 
(98) 

2020 

(364) 
(335) 

(699) 
285 

(414) 
3 
– 

3 
455 

(872) 
(482) 

(390) 
–
– 

(390) 

(414) 
455 
14,400 

(116) 
3 
97 
(88) 

(128) 

(116) 
97 
(128) 

2019 

(242) 
(296) 

(538) 
238 

(300) 
(7) 
(5) 

(12) 
856 

(1,144) 
(517) 

(627) 
– 
357 

(270) 

(300) 
372 
14,898 

(37) 
(4) 
192 
(76) 

(149) 

(37) 
76 
(63) 

M
D
&
A

(1)  Adjusted results and ratios, teb amounts and U.S. dollar amounts in this table are on a non-GAAP basis and are discussed in the Non-GAAP and Other Financial Measures section. 
(2)  Fiscal 2021 reported net income included a $779 million pre-tax and after-tax write-down of goodwill related to the sale of our EMEA Asset Management business recorded in non-interest expense, 
a $22 million ($29 million pre-tax) net gain on the sale of our Private Banking business in Hong Kong and Singapore recorded in non-interest revenue, and $85 million ($107 million pre-tax) of 
divestiture-related costs for both transactions recorded in non-interest expense. 

(3)  Fiscal 2019 reported net income included a $357 million ($484 million pre-tax) restructuring charge related to severance and a small amount of real estate-related costs. Fiscal 2021 reported net 

income included a partial reversal of restructuring charges related to severance of $18 million ($24 million pre-tax). Restructuring charges and the partial reversal were recorded in non-interest 
expense. 

(4)  Adjusted results exclude the impact of the items described in footnotes (2) and (3). 

Financial Review 
Corporate Services reported net loss was $1,286 million and adjusted net loss was $462 million, compared with a reported and adjusted net loss 
of $390 million in the prior year. Adjusted results in the current year excluded the impact of divestitures of $842 million ($857 million pre-tax), 
including a $779 million pre-tax and after-tax write-down of goodwill related to the sale of our EMEA Asset Management business, a $22 million 
($29 million pre-tax) net gain on the sale of our Private Banking business in Hong Kong and Singapore, and $85 million ($107 million pre-tax) of 
divestiture-related costs for both transactions, as well as an $18 million ($24 million pre-tax) partial reversal of restructuring charges recorded in 2019 
related to severance. The higher reported and adjusted net loss reflected an increase in expenses, partially offset by higher revenue that was driven 
by higher securities gains and treasury-related activities, and the impact of a less favourable tax rate in the prior year. 

For further information on non-GAAP amounts, measures and ratios in this 2021 Operating Groups Performance Review section, refer to the 

Non-GAAP and Other Financial Measures section. 

BMO Financial Group 204th Annual Report 2021  57 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Review of Fourth Quarter 2021 Performance 

Q4 2021 vs. Q4 2020 
Net Income 
Reported net income was $2,159 million, an increase of $575 million or 36% from the prior year, and adjusted net income was $2,226 million, an 
increase of $616 million or 38%. Adjusted results in the current quarter excluded expenses of $52 million ($62 million pre-tax) from the impact of 
divestitures related to the sale of our EMEA Asset Management business and the sale of our Private Banking business in Hong Kong and Singapore. 
Adjusted results also excluded the amortization of acquisition-related intangible assets and acquisition integration costs in both the current and prior 
years. Reported EPS was $3.23, an increase of $0.86 from the prior year, and adjusted EPS was $3.33, an increase of $0.92. 

Results were driven by strong revenue growth and the impact of lower provisions for credit losses, partially offset by an increase in expenses. All 

operating groups recorded higher net income, while Corporate Services recorded a higher net loss. 

A
&
D
M

Revenue 
Reported revenue was $6,573 million, an increase of $587 million or 10% from the prior year. On a basis that nets insurance claims, commissions and 
changes in policy benefit liabilities (CCPB) against insurance revenue (net revenue), revenue was $6,476 million, an increase of $490 million or 8% 
from the prior year. 

Revenue increased in Canadian P&C due to higher net interest income and higher non-interest revenue, in BMO Wealth Management, largely 
from growth in client assets, including stronger global markets, partially offset by lower insurance revenue, in BMO Capital Markets due to higher 
Investment and Corporate Banking revenue, partially offset by lower Global Markets revenue, and in U.S. P&C due to higher net interest income and 
higher non-interest revenue. Corporate Services revenue decreased from the prior year. The impact of the weaker U.S. dollar decreased total revenue 
by 2%. 

Insurance Claims, Commissions and Changes in Policy Benefit Liabilities 
Insurance claims, commissions and changes in policy benefit liabilities (CCPB) were $97 million, compared with $nil in the prior year. The increase 
was largely due to changes in the fair value of policy benefit liabilities. CCPB decreased $887 million from the prior quarter due to changes in the fair 
value of policy benefit liabilities. The changes were largely offset in revenue. 

Provision for Credit Losses 
Total recovery of the provision for credit losses was $126 million, compared with a provision for credit losses of $432 million in the prior year. 
The total recovery of the provision for credit losses as a percentage of average net loans and acceptances ratio was 11 basis points, compared with 
a provision for credit losses ratio of 37 basis points in the prior year. The provision for credit losses on impaired loans was $84 million, a decrease 
of $255 million from $339 million in the prior year. The provision for credit losses on impaired loans as a percentage of average net loans and 
acceptances ratio was 7 basis points, compared with 29 basis points in the prior year. There was a $210 million recovery of the provision for credit 
losses on performing loans in the current quarter, compared with a $93 million provision in the prior year. The $210 million recovery in the current 
quarter largely reflected an improving economic outlook and positive credit migration, partially offset by growth in loan balances, while the 
$93 million provision in the prior year reflected a more severe adverse scenario, partially offset by an improving economic outlook and reduced 
balances. 

Non-Interest Expense 
Reported non-interest expense was $3,803 million, an increase of $255 million or 7% from the prior year, including $62 million of expenses from 
the impact of divestitures in the current year. Adjusted non-interest expense was $3,720 million, an increase of $205 million or 6%. The increase in 
expenses was primarily due to higher employee-related costs, including performance-based costs, travel and business development costs, computer 
and equipment costs, and professional fees, partially offset by the impact of the weaker U.S. dollar that decreased expenses by 2%. 

Provision for Income Taxes 
The provision for income taxes was $640 million, an increase of $218 million from the prior year, and the effective tax rate was 22.9%, compared 
with 21.1% in the prior year. The adjusted provision for income taxes was $656 million, an increase of $227 million from the prior year, and the 
adjusted effective tax rate was 22.7%, compared with 21.1% in the prior year. The effective tax rate and adjusted effective tax rate were lower in 
the prior year primarily due to earnings mix, including the impact of lower pre-tax income in the prior year. 

Q4 2021 vs. Q3 2021 
Reported net income decreased $116 million or 5% from the prior quarter, and adjusted net income decreased $66 million or 3%. Adjusted results 
in the prior quarter excluded divestiture costs of $18 million ($24 million pre-tax) and a partial reversal of previously recorded restructuring charges 
related to severance of $18 million ($24 million pre-tax), as well as the amortization of acquisition-related intangible assets and acquisition 
integration costs. Results were primarily driven by lower revenue and an increase in expenses, partially offset by the impact of a larger recovery of 
the provision for credit losses. Net income increased in Canadian P&C and was partially offset by decreases in U.S. P&C, BMO Wealth Management and 
BMO Capital Markets. Corporate Services recorded a higher net loss. 

Revenue was $6,573 million, a decrease of $989 million or 13% from the prior quarter. Revenue, net of CCPB, was $6,476 million, a decrease of 

$102 million or 2%. Reported non-interest expense increased $119 million or 3% from the prior quarter. Adjusted non-interest expense increased 
$58 million or 2%. Total recovery of the provision for credit losses was $126 million, compared with a recovery of $70 million in the prior quarter. 

For further information on non-GAAP amounts, measures and ratios in this Review of Fourth Quarter 2021 Performance section, refer to the 

Non-GAAP and Other Financial Measures section. 

58  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Summary Quarterly Earnings Trends 

Summarized Statement of Income and Quarterly Financial Measures 

(1)

(Canadian $ in millions, except as noted) 

Q4-2021 

Q3-2021 

Q2-2021 

Q1-2021 

Q4-2020 

Q3-2020 

Q2-2020 

Q1-2020 

Net interest income (teb) 
Non-interest revenue 

Revenue (teb) 
Insurance claims, commissions and changes in policy benefit liabilities (CCPB) 

Revenue, net of CCPB (teb) 
Provision for credit losses on impaired loans 
Provision for (recovery of) credit losses on performing loans 

Total provision for (recovery of) credit losses 
Non-interest expense 

Income before provision for income taxes 
Provision for income taxes (teb) 

Reported net income (see below) 
Acquisition integration costs 
Amortization of acquisition-related intangible assets 
Impact of divestitures 
Restructuring costs (reversals) 

(2)

(5)

(4)

(3)

Adjusted net income (see below) 

Operating group reported net income 
Canadian P&C reported net income 

Amortization of acquisition-related intangible assets 

(3)

Canadian P&C adjusted net income 

U.S. P&C reported net income 

Amortization of acquisition-related intangible assets 

(3)

U.S. P&C adjusted net income 

BMO Wealth Management reported net income 

Amortization of acquisition-related intangible assets 

(3)

BMO Wealth Management adjusted net income 

BMO Capital Markets reported net income 

Acquisition integration costs 
Amortization of acquisition-related intangible assets 

(2)

(3)

BMO Capital Markets adjusted net income 

Corporate Services reported net loss 

Impact of divestitures 
Restructuring costs (reversals) 
Corporate Services adjusted net loss 

(5)

(4)

(7)

(7)

(6)

Basic earnings per share ($) 
(6)
Diluted earnings per share ($) 
Adjusted diluted earnings per share ($) 
Net interest margin on average earning assets (%) 
PCL-to-average net loans and acceptances (annualized) (%) 
PCL on impaired loans-to-average net loans and acceptances (annualized) (%) 
Effective tax rate (%) 
Adjusted effective tax rate (%) 
Canadian/U.S. dollar average exchange rate ($) 

M
D
&
A

3,756 
2,817 

6,573 
97 

6,476 
84 
(210) 

(126) 
3,803 

2,799 
640 

2,159 
1 
14 
52 
– 

3,521 
4,041 

7,562 
984 

6,578 
71 
(141) 

(70) 
3,684 

2,964 
689 

2,275 
2 
15 
18 
(18) 

3,455 
2,621 

6,076 
(283) 

6,359 
155 
(95) 

60 
4,409 

1,890 
587 

1,303 
2 
18 
772 
– 

3,578 
3,397 

6,975 
601 

6,374 
215 
(59) 

156 
3,613 

2,605 
588 

2,017 
2 
19 
– 
– 

3,530 
2,456 

5,986 
– 

5,986 
339 
93 

432 
3,548 

2,006 
422 

1,584 
3 
23 
– 
– 

3,535 
3,654 

7,189 
1,189 

6,000 
446 
608 

1,054 
3,444 

1,502 
270 

1,232 
4 
23 
– 
– 

2,226 

2,292 

2,095 

2,038 

1,610 

1,259 

921 
– 
921 

512 
6 
518 

369 
4 
373 

536 
1 
4 
541 

815 
– 
815 

553 
6 
559 

401 
5 
406 

558 
2 
4 
564 

764 
1 
765 

542 
5 
547 

346 
7 
353 

563 
2 
5 
570 

737 
– 
737 

582 
7 
589 

358 
8 
366 

483 
2 
4 
489 

647 
1 
648 

324 
9
333 

320 
8 
328 

379 
3 
5 
387 

319 
– 
319 

263 
 10
273 

341 
8 
349 

426 
4 
5 
435 

(179) 
52 
– 
(127) 

(52) 
18
(18) 
(52) 

(912) 
772 
– 
(140) 

(143) 
– 
– 
(143) 

(86) 
–
–
(86) 

(117) 
–
–
(117) 

3,518 
1,746 

5,264 
(197) 

5,461 
413 
705 

1,118 
3,516 

827 
138 

689 
2 
24 
– 
– 

715 

362 
1 
363 

339 
 10
349 

144 
9 
153 

(74) 
2 
4 
(68) 

(82) 
–
–
(82) 

3,388 
3,359 

6,747 
716 

6,031 
324 
25 

349 
3,669 

2,013 
421 

1,592 
2 
23 
– 
– 

1,617 

699 
– 
699 

351 
 10
361 

291 
9 
300 

356 
2 
4 
362 

(105) 
– 
– 
(105) 

3.24 
3.23 
3.33 
1.62 
(0.11) 
0.07 
22.9 
22.7 

3.03 
3.03 
3.06 
1.59 
0.14 
0.19 
22.6 
22.6 
1.2546  1.2316  1.2512  1.2841 

3.42 
3.41 
3.44 
1.57 
(0.06) 
0.06 
23.2 
23.2 

1.91 
1.91 
3.13 
1.59 
0.05 
0.13 
31.1 
22.1 

2.37 
2.37 
2.41 
1.60 
0.37 
0.29 
21.1 
21.1 

2.38 
2.37 
2.41 
1.67 
0.31 
0.29 
20.9 
21.0 
1.3217  1.3584  1.3811  1.3161 

1.00 
1.00 
1.04 
1.69 
0.94 
0.35 
16.6 
16.7 

1.81 
1.81 
1.85 
1.59 
0.89 
0.38 
18.0 
18.2 

(1)  Revenue measures, net of CCPB, adjusted results and ratios teb amounts, and U.S. dollar amounts in this table are on a non-GAAP basis and are discussed in the Non-GAAP and Other Financial 

Measures section. 

(2)  Acquisition integration costs related to the acquired BMO Transportation Finance business are charged to Corporate Services, since the acquisition impacts both Canadian and U.S. P&C businesses. 

Acquisition integration costs related to KGS-Alpha and Clearpool are reported in BMO Capital Markets. Acquisition integration costs are recorded in non-interest expense. 

(3)  Amortization of acquisition-related intangible assets is charged to non-interest expense in the related operating group. 
(4)  Q2-2021 reported net income included the impact of divestitures, comprising a $747 million pre-tax and after-tax write-down of goodwill related to the sale of our EMEA Asset Management business 

recorded in non-interest expense, a $22 million ($29 million pre-tax) net gain on the sale of our Private Banking business in Hong Kong and Singapore recorded in non-interest revenue, and 
$47 million ($53 million pre-tax) of divestiture-related costs for both transactions recorded in non-interest expense. The impact of divestitures for these transactions was $18 million ($24 million 
pre-tax) in Q3-2021 and $52 million ($62 million pre-tax) in Q4-2021 recorded in non-interest expense in Corporate Services. 

(5)  Q3-2021 reported net income included a partial reversal of restructuring charges related to severance of $18 million ($24 million pre-tax). Restructuring charges and reversal were recorded in 

non-interest expense in Corporate Services. 

(6)  Earnings per share (EPS) is calculated using net income after deducting total dividends on preferred shares and distributions on other equity instruments. For more information on EPS, refer to Note 23 

of the consolidated financial statements. 

(7)  Net income and earnings from our business operations are attributable to shareholders by way of EPS and diluted EPS. Adjusted EPS and adjusted diluted EPS are non-GAAP measures. For further 

information, refer to the Non-GAAP and Other Financial Measures section. 

BMO Financial Group 204th Annual Report 2021  59 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

A
&
D
M

Financial performance in recent quarters has generally been trending upward, due to improving economic conditions and good operating momentum 
across our businesses, including lower provisions for credit losses, strong revenue growth and improved efficiency. While results in 2020 were 
negatively impacted by the significant adverse effects of the COVID-19 pandemic on the global economy, a reduction in interest rates and lower 
levels of consumer and business activity and borrowing, economic conditions subsequently rebounded and continue to improve. However, the 
unpredictable course of the COVID-19 pandemic, including the emergence of variants and a possible resurgence of cases globally, contributes to 
ongoing economic uncertainty. 

Reported results in the second quarter of 2021 included a write-down of goodwill related to the sale of our EMEA Asset Management business 

and a net gain on the sale of our Private Banking business in Hong Kong and Singapore. The last three quarters of 2021 reflected the impact of 
divestitures related to these transactions. The third quarter of 2021 also included a partial reversal of a restructuring charge recorded in 2019. 
All periods included the amortization of acquisition-related intangible assets and acquisition integration costs. 

Total revenue growth reflects the benefits of our diversified businesses. Revenue growth in the P&C businesses was initially negatively impacted 
by the COVID-19 pandemic, the low interest rate environment and lower non-interest revenue due to lower levels of client activity, which have been 
rising in the most recent quarters as public health restrictions have been relaxed. Canadian P&C benefitted from strong growth in residential 
mortgages and home equity lines of credit, reflecting higher levels of housing market activity. Revenue in U.S. P&C on a source-currency basis 
rebounded in 2021, driven by higher loan spreads and Paycheck Protection Program revenue, and has remained relatively stable over the last four 
quarters due to more muted industry loan growth. In BMO Wealth Management, Traditional Wealth revenue performance has been supported by 
stronger global markets. Insurance revenue, net of CCPB, is subject to variability, primarily resulting from changes in interest rates and equity 
markets. BMO Capital Markets recorded year-over-year revenue growth in seven of the past eight quarters, primarily reflecting higher trading and 
underwriting revenue due to robust client activity, while the second quarter of 2020 was negatively impacted by volatile market conditions resulting 
from the COVID-19 pandemic. Revenue in the fourth quarter of 2021 reflected good performance in all operating groups. Revenue growth has also 
been impacted by changes in the strength of the U.S. dollar. 

In 2020, we recorded higher provisions for credit losses in all businesses, primarily due to the impact of the COVID-19 pandemic, including higher 

provisions for credit losses on performing loans in the wake of the economic downturn brought on by the pandemic. In 2021, we recorded lower 
provisions for credit losses on impaired loans, as well as recoveries of provisions for credit losses on performing loans, which reflected the improving 
economic outlook and more favourable credit conditions. 

Non-interest expense reflected our focus on expense management and efficiency improvement. In recent quarters, non-interest expense growth 
has been driven by higher performance-based compensation reflecting improved revenue performance, and higher technology and marketing costs, 
partially offset by lower net COVID-19 related costs, as well as lower travel costs due to the continued impact of the pandemic. Expenses were also 
impacted by changes in the strength of the U.S. dollar. 

The effective tax rate has varied with legislative changes; changes in tax policy, including their interpretation by tax authorities and the courts; 

earnings mix, including the relative proportion of earnings attributable to the different jurisdictions in which we operate, the level of pre-tax income, 
and the level of tax-exempt income from securities. The effective tax rate in 2021 was impacted by the write-down of goodwill related to the sale of 
our EMEA Asset Management business. 

For further information on non-GAAP amounts, measures and ratios in this Summary Quarterly Earnings Trends section, refer to the Non-GAAP 

and Other Financial Measures section. 

60  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2020 Financial Performance Review 
The preceding discussions in the MD&A focused on BMO’s performance in fiscal 2021. This section summarizes BMO’s performance in fiscal 2020, 
relative to fiscal 2019. Certain prior-year data has been reclassified to conform with the presentation in 2021, including changes resulting from 
transfers between operating groups. Further information on these reclassifications is provided in the How BMO Reports Operating Group Results 
section. 

(Canadian $ in millions) 

2020 
Net interest income (teb) 
Non-interest revenue 

(1)

Revenue 
Insurance claims, commissions and changes in policy benefit liabilities (CCPB) 

Revenue, net of CCPB 

Provision for credit losses 
Non-interest expense 

Income (loss) before income taxes (teb) 
Provision for (recovery of) income taxes 

(1)

Net income (loss) 

Acquisition integration costs 
Amortization of acquisition-related intangible assets 
Restructuring costs 
Reinsurance adjustment 

Adjusted net income (loss) 

2019 
Net interest income (teb) 
Non-interest revenue 

(1)

Revenue 
Insurance claims, commissions and changes in policy benefit liabilities (CCPB) 

Revenue, net of CCPB 

Provision for (recovery of) credit losses 
Non-interest expense 

Income (loss) before income taxes (teb) 
Provision for (recovery of) income taxes 

(1)

Net income (loss) 

Acquisition integration costs 
Amortization of acquisition-related intangible assets 
Restructuring costs 
Reinsurance adjustment 

M
D
&
A

Canadian P&C  U.S. P&C  Total P&C 

BMO Wealth 
Management 

BMO Capital 
Markets 

Corporate 
Services 

Total Bank 

6,105 
1,930 

8,035 
– 

4,345  10,450 
3,116 
1,186 

5,531  13,566 
– 

– 

8,035 

5,531  13,566 

1,410 
3,892 

2,733 
706 

859 
3,075 

1,597 
320 

2,269 
6,967 

4,330 
1,026 

2,027 

1,277 

3,304 

– 
2 
– 
– 

– 
39 
– 
– 

– 
41 
– 
– 

900 
5,808 

6,708 
1,708 

5,000 

22 
3,519 

1,459 
363 

1,096 

– 
34 
– 
– 

3,320 
2,006 

5,326 
– 

(699) 
285 

(414) 
– 

13,971 
11,215 

25,186 
1,708 

5,326 

(414) 

23,478 

659 
3,236 

1,431 
344 

3 
455 

2,953 
14,177 

(872) 
(482) 

6,348 
1,251 

1,087 

(390) 

5,097 

11 
18 
– 
– 

– 
– 
– 
– 

11 
93 
– 
– 

2,029 

1,316 

3,345 

1,130 

1,116 

(390) 

5,201 

5,885 
2,099 

7,984 
– 

4,216  10,101 
3,261 
1,162 

5,378  13,362 
– 

– 

7,984 

5,378  13,362 

607 
3,836 

3,541 
917 

197 
3,136 

2,045 
434 

804 
6,972 

5,586 
1,351 

2,624 

1,611 

4,235 

– 
2 
– 
– 

– 
43 
– 
– 

– 
45 
– 
– 

935 
6,727 

7,662 
2,709 

4,953 

– 
3,523 

1,430 
371 

1,059 

– 
37 
– 
25 

2,390 
2,369 

4,759 
– 

(538) 
238 

(300) 
– 

12,888 
12,595 

25,483 
2,709 

4,759 

(300) 

22,774 

80 
3,279 

1,400 
309 

(12) 
856 

872 
14,630 

(1,144) 
(517) 

7,272 
1,514 

1,091 

(627) 

5,758 

10 
17 
– 
– 

– 
– 
357 
– 

10 
99 
357 
25 

Adjusted net income (loss) 

2,626 

1,654 

4,280 

1,121 

1,118 

(270) 

6,249 

(1)  BMO analyzes revenue on a teb basis at the operating group level, with the offset to the group teb adjustments recorded in Corporate Services non-interest revenue and provision for income taxes. 
Revenue measures, net of CCPB, adjusted results and ratios, teb amounts and U.S. dollar amounts in this table are on a non-GAAP basis and are discussed in the Non-GAAP and Other Financial 
Measures section. 

Net Income 
Reported net income in 2020 was $5,097 million, a decrease of $661 million or 11% from $5,758 million in 2019. Adjusted net income 
was $5,201 million, a decrease of $1,048 million or 17% from $6,249 million in 2019. Adjusted net income in both 2020 and 2019 excluded the 
amortization of acquisition-related intangible assets and acquisition-related costs. Adjusted net income in 2019 also excluded a restructuring charge, 
primarily severance-related, and the net impact of major reinsurance claims resulting from Japanese typhoons incurred after the announced wind-
down of the reinsurance business. The decline in adjusted net income reflected the impact of higher provisions for credit losses, which increased 
$2,081 million pre-tax or $1,531 million after tax, partially offset by higher revenue, while adjusted expenses were relatively unchanged. Decreases 
in net income were recorded in the P&C businesses, while net income in BMO Capital Markets and BMO Wealth Management was largely unchanged 
from 2019. In Corporate Services, the reported net loss decreased from 2019, while the adjusted net loss increased. 

Return on Equity 
Reported return on equity (ROE) in 2020 was 10.1% and adjusted ROE was 10.3%, compared with 12.6% and 13.7%, respectively, in 2019. Reported 
and adjusted ROE decreased in 2020, primarily due to lower net income and higher common equity. There was a decrease of $697 million or 13% in 
reported net income available to common shareholders, and a decrease of $1,084 million or 18% in adjusted net income available to common 
shareholders from 2019. Average common shareholders’ equity increased $4.1 billion or 9% from 2019, primarily due to growth in retained earnings 
and accumulated other comprehensive income. 

BMO Financial Group 204th Annual Report 2021  61 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Revenue 
Reported revenue in 2020 was $25,186 million, a decrease of $297 million from $25,483 million in 2019. On a basis that nets insurance claims, 
commissions and changes in policy benefit liabilities (CCPB) against insurance revenue (net revenue), revenue was $23,478 million, an increase 
of $704 million or 3%. Revenue, net of adjusted CCPB, increased $679 million or 3% from the prior year, and excluded the $25 million net impact 
of major reinsurance claims in 2019. The increase in revenue was largely driven by strong performance in BMO Capital Markets, primarily due to 
increased trading revenue, and revenue growth in the P&C businesses and BMO Wealth Management, partially offset by a decrease in Corporate 
Services revenue. 

Canadian P&C 
Revenue increased $51 million or 1% from 2019, due to higher average balances across most products, partially offset by lower margins reflecting 
the low interest rate environment, and lower non-interest revenue, largely due to lower credit card fee revenue and deposit fee revenue. 

A
&
D
M

U.S. P&C 
Revenue increased $153 million or 3% from 2019 on a Canadian dollar basis. On a U.S. dollar basis, revenue increased $65 million or 2%, primarily 
due to growth in average deposit and loan balances, as well as higher loan margins and higher non-interest revenue, partially offset by lower deposit 
product margins, reflecting the impact of lower interest rates. 

BMO Wealth Management 
Revenue, net of reported and adjusted CCPB, increased $47 million or 1% on a reported basis and $22 million on an adjusted basis from 2019. 
Revenue in Traditional Wealth increased $38 million, primarily due to higher elevated online brokerage revenue and growth in client assets, net of 
fee pressure, partially offset by a legal provision in 2020 and lower net interest income, as the benefits of strong loan and deposit growth were more 
than offset by lower margins. Insurance revenue, net of reported and adjusted CCPB, increased $9 million on a reported basis and decreased 
$16 million on an adjusted basis, primarily due to higher creditor insurance claims. 

BMO Capital Markets 
Revenue increased $567 million or 12% from 2019. Global Markets revenue increased, primarily due to higher revenue from interest rate trading, 
commodities trading and foreign exchange trading, partially offset by a decrease in equities trading revenue. Investment and Corporate Banking 
revenue increased, primarily due to higher corporate banking-related revenue and equity underwriting revenue, partially offset by lower net 
securities gains and advisory revenue, as well as markdowns on the held-for-sale loan portfolio. 

Corporate Services 
Revenue decreased $114 million from 2019, primarily due to lower treasury-related revenue, reflecting the impact of elevated levels of customer 
deposits. 

Insurance Claims, Commissions and Changes in Policy Benefit Liabilities 
Reported and adjusted insurance claims, commissions and changes in policy benefit liabilities (CCPB) were $1,708 million in 2020, compared with 
reported CCPB of $2,709 million and adjusted CCPB of $2,684 million in the prior year. Adjusted CCPB excluded the $25 million net impact of major 
reinsurance claims in the prior year. CCPB decreased, primarily due to lower increases in the fair value of policy benefit liabilities in 2020 as a result 
of a smaller decrease in long-term interest rates compared with 2019, lower annuity sales, lower underlying business growth and weaker equity 
markets. The decrease related to the fair value of policy benefit liabilities was largely offset in revenue. 

Provision for Credit Losses 
The total provision for credit losses was $2,953 million in 2020, an increase of $2,081 million from $872 million in 2019. The provision for credit 
losses on impaired loans was $1,522 million in 2020, an increase of $771 million from $751 million in 2019, reflecting higher provisions in all of our 
businesses, primarily due to the economic impact of the COVID-19 pandemic. There was a $1,431 million provision for credit losses on performing 
loans in 2020, an increase of $1,310 million from $121 million in 2019. The increase in the provision for credit losses on performing loans in 2020 
largely reflected the impact of the COVID-19 pandemic on the macroeconomic outlook and the impact of a more difficult and uncertain environment 
on credit conditions, as well as a more severe adverse scenario and an increase in the adverse scenario weighting. 

Non-Interest Expense 
Non-interest expense was $14,177 million in 2020, a decrease of $453 million from 2019, primarily due to the impact of the $484 million 
($357 million after-tax) restructuring charge in 2019. Adjusted non-interest expense in 2020 was $14,042 million, relatively unchanged from 2019, 
with the benefits of a disciplined approach to expense management, including the net impact of the COVID-19 pandemic on expenses, and lower 
employee-related expenses largely offsetting higher premises and equipment costs. Adjusted non-interest expense excluded the restructuring charge 
in 2019, as well as the amortization of acquisition-related intangible assets and acquisition integration costs in both 2020 and 2019. The amortization 
of acquisition-related intangible assets was $121 million and $128 million in 2020 and 2019, respectively, and acquisition integration costs 
were $14 million and $13 million in 2020 and 2019, respectively. 

Provision for Income Taxes 
The provision for income taxes was $1,251 million in 2020, compared with $1,514 million in 2019. The effective tax rate in 2020 was 19.7%, 
compared with 20.8% in 2019. The adjusted provision for income taxes was $1,282 million in 2020, compared with $1,673 million in 2019. 
The adjusted effective tax rate in 2020 was 19.8%, compared with 21.1% in 2019. The lower effective tax rate and adjusted effective tax rate in 2020 
were due to earnings mix, including lower pre-tax income. 

For further information on non-GAAP amounts, measures and ratios in this 2020 Financial Performance Review section, refer to the Non-GAAP 

and Other Financial Measures section. 

62  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Condition Review 
Summary Balance Sheet 

(Canadian $ in millions) 
As at October 31 

Assets 
Cash and interest bearing deposits with banks 
Securities 
Securities borrowed or purchased under resale agreements 
Net loans 
Derivative instruments 
Other assets 

Total assets 

Liabilities and Equity 
Deposits 
Derivative instruments 
Securities lent or sold under repurchase agreements 
Other liabilities 
Subordinated debt 
Equity 

Total liabilities and equity 

2021 

2020 

2019 

101,564 
232,849 
107,382 
458,262 
36,713 
51,405 

988,175 

685,631 
30,815 
97,556 
109,757 
6,893 
57,523 

988,175 

66,443 
234,260 
111,878 
447,420 
36,815 
52,445 

949,261 

659,034 
30,375 
88,658 
106,185 
8,416 
56,593 

949,261 

56,790 
189,438 
104,004 
426,984 
22,144 
52,835 

852,195 

568,143 
23,598 
86,656 
115,727 
6,995 
51,076 

852,195 

M
D
&
A

Certain comparative figures have been reclassified to conform with the current year’s presentation. 

Overview 
Total assets of $988.2 billion increased $38.9 billion from October 31, 2020. The weaker U.S. dollar decreased assets by $30.6 billion, excluding the 
impact on derivative assets. Total liabilities of $930.7 billion increased $38.0 billion from the prior year. The weaker U.S. dollar decreased liabilities by 
$28.4 billion, excluding the impact on derivative liabilities. Total equity of $57.5 billion increased $0.9 billion from October 31, 2020. 

Cash and Interest Bearing Deposits with Banks 
Cash and interest bearing deposits with banks increased $35.1 billion, primarily due to higher balances held with central banks, driven by customer 
deposit growth in excess of loan growth, and a change in the mix of liquid assets, with lower securities borrowed or purchased under resale 
agreements and lower securities balances, partially offset by the impact of the weaker U.S. dollar. 

Securities 

(Canadian $ in millions) 
As at October 31 

Trading 
Fair value through profit or loss 
(1)
Fair value through other comprehensive income – Debt and equity 
Amortized cost 
Investments in associates and joint ventures 

(3)

(2)

Total securities 

2021 

104,411 
14,210 
63,123 
49,970 
1,135 

232,849 

2020 

97,834 
13,568 
73,407 
48,466 
985 

2019 

85,903 
13,704 
64,515 
24,472 
844 

234,260 

189,438 

(1)  Comprises $3,038 million mandatorily measured at FVTPL ($2,420 million as at October 31, 2020 and $2,899 million as at October 31, 2019) and $11,172 million designated at fair value 

($11,148 million as at October 31, 2020 and $10,805 million as at October 31, 2019). 

(2)  Includes allowances for credit losses on debt securities recorded at fair value through other comprehensive income of $2 million as at October 31, 2021 ($4 million as at October 31, 2020 and 

$2 million as at October 31, 2019). 

(3)  Net of allowances for credit losses of $2 million ($1 million as at both October 31, 2020 and October 31, 2019). 

Securities decreased $1.4 billion, as higher levels of client activity in BMO Capital Markets were more than offset by the impact of the weaker U.S. 
dollar and treasury activities in Corporate Services. 

Securities Borrowed or Purchased Under Resale Agreements 
Securities borrowed or purchased under resale agreements decreased $4.5 billion, primarily driven by a change in the mix of liquid assets, which 
included an increase in cash and interest bearing deposits with banks, and the impact of the weaker U.S. dollar, partially offset by higher balances in 
BMO Capital Markets as a result of client activity. 

Net Loans 

(Canadian $ in millions) 
As at October 31 

Residential mortgages 
Non-residential mortgages 
Consumer instalment and other personal 
Credit cards 
Businesses and government 

Gross loans 
Allowance for credit losses 

Total net loans 

Certain comparative figures have been reclassified to conform with the current year’s presentation. 

2021 

135,750 
17,195 
77,164 
8,103 
222,614 

460,826 
(2,564) 

458,262 

2020 

127,024 
16,741 
70,148 
7,889 
228,921 

450,723 
(3,303) 

447,420 

2019 

123,740 
15,731 
67,736 
8,859 
212,768 

428,834 
(1,850) 

426,984 

BMO Financial Group 204th Annual Report 2021  63 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Net loans increased $10.8 billion. Residential mortgages increased $8.7 billion, with growth in Canadian P&C driven by an active housing market, 
partially offset by lower balances in U.S. P&C, including the impact of the weaker U.S. dollar. Consumer instalment and other personal loans increased 
$7.0 billion, with growth in the P&C businesses and BMO Wealth Management partially offset by the impact of the weaker U.S. dollar. Business and 
government loans decreased $6.3 billion, as growth in the P&C businesses was more than offset by the impact of the weaker U.S. dollar and lower 
balances in BMO Capital Markets, including the impact of declining balances in the non-Canadian energy portfolio. Non-residential mortgages 
increased $0.5 billion, due to growth in BMO Capital Markets and U.S. P&C, partially offset by the impact of the weaker U.S. dollar. Credit cards 
increased $0.2 billion, reflecting higher balances in Canadian P&C. 

Table 7 in the Supplemental Information provides a comparative summary of loans by geographic location and product. Table 9 provides a 
comparative summary of net loans in Canada by province and industry. Loan quality is discussed in the Credit Quality Information section, and further 
details on loans are provided in Notes 4, 6 and 24 of the consolidated financial statements. 

Derivative Financial Assets 
Derivative financial assets decreased $0.1 billion, due to a decrease in the fair value of interest rate and equity contracts, largely offset by an increase 
in the fair value of commodities and foreign exchange contracts. Further details on derivative financial assets are provided in Note 8 of the 
consolidated financial statements. 

Other Assets 
Other assets primarily includes customers’ liability under acceptances, goodwill and intangible assets, precious metals, premises and equipment, 
current and deferred tax assets, accounts receivable and prepaid expenses. Other assets decreased $1.0 billion, due to a reduction in precious metals 
balances resulting from client activity in BMO Capital Markets, the impact of the weaker U.S. dollar and the write-down of goodwill related to the 
sale of our EMEA Asset Management business, partially offset by an increase in pension assets, as well as growth in insurance-related assets and 
customers’ liability under acceptances. Certain comparative figures have been reclassified to conform with the current year’s presentation. 
Further details on other assets are provided in Notes 11 and 12 of the consolidated financial statements. 

A
&
D
M

Deposits 

(Canadian $ in millions) 
As at October 31 

Banks 
Businesses and government 
Individuals 

Total deposits 

2021 

26,611 
442,248 
216,772 

685,631 

2020 

38,825 
400,679 
219,530 

659,034 

2019 

23,816 
343,157 
201,170 

568,143 

Deposits increased $26.6 billion. Business and government deposits increased $41.6 billion, reflecting growth in customer deposits across all 
operating groups and higher levels of funding requirements for client-driven activity in our trading businesses, partially offset by the impact of the 
weaker U.S. dollar. Deposits by banks decreased $12.2 billion, primarily due to Bank of Canada term repo funding maturities. Deposits by individuals 
decreased $2.8 billion, due to the impact of the weaker U.S. dollar and lower balances in U.S. P&C, partially offset by growth in BMO Wealth 
Management and Canadian P&C. Further details on the composition of deposits are provided in Note 13 of the consolidated financial statements 
and in the Liquidity and Funding Risk section. 

Derivative Financial Liabilities 
Derivative financial liabilities increased $0.4 billion, due to an increase in the fair value of equity and foreign exchange contracts, partially offset by a 
decrease in the fair value of interest rate and commodities contracts. 

Securities Lent or Sold Under Repurchase Agreements 
Securities lent or sold under repurchase agreements increased $8.9 billion, driven by higher levels of client activity in BMO Capital Markets, partially 
offset by the impact of the weaker U.S. dollar and Bank of Canada term repo funding maturities. 

Other Liabilities 
Other liabilities primarily include securities sold but not yet purchased, securitization and structured entities liabilities, acceptances, insurance-related 
liabilities and accounts payable. Other liabilities increased $3.6 billion, primarily reflecting an increase in securities sold but not yet purchased due to 
higher levels of client activity in BMO Capital Markets, and increases in cash collateral received, acceptances and insurance-related liabilities, partially 
offset by the impact of the weaker U.S. dollar and lower securitization liabilities. 

Further details on the composition of other liabilities are provided in Note 14 of the consolidated financial statements. 

Subordinated Debt 
Subordinated debt decreased $1.5 billion from the prior year, reflecting redemptions, net of a new issuance. Further details on the composition of 
subordinated debt are provided in Note 15 of the consolidated financial statements. 

Equity 

(Canadian $ in millions) 
As at October 31 

Share capital 

Preferred shares and other equity instruments 
Common shares 
Contributed surplus 
Retained earnings 
Accumulated other comprehensive income 

Total equity 

64  BMO Financial Group 204th Annual Report 2021 

2021 

2020 

2019 

5,558 
13,599 
313 
35,497 
2,556 

57,523 

6,598 
13,430 
302 
30,745 
5,518 

56,593 

5,348 
12,971 
303 
28,725 
3,729 

51,076 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Total equity increased $0.9 billion, with a $4.8 billion increase in retained earnings and a $0.2 billion increase in common shares, largely offset by 
a $3.0 billion decrease in accumulated other comprehensive income and a $1.0 billion decrease in preferred shares and other equity instruments. 
Retained earnings increased as a result of net income earned in the year, partially offset by dividends and distributions on other equity instruments. 
Accumulated other comprehensive income decreased, primarily due to the impact of higher interest rates on cash flow hedges and the impact of the 
weaker U.S. dollar on the translation of net foreign operations, partially offset by an improvement in the position of our pension and other employee 
future benefit plans due to an increase in the value of pension plan assets and the impact of higher interest rates on the pension liability. Preferred 
shares and other equity instruments decreased due to redemptions in the year. 

The Consolidated Statement of Changes in Equity in the consolidated financial statements provides a summary of items that increase or reduce 
total equity, while Note 16 of the consolidated financial statements provides details on the components of, and changes in, share capital. Details on 
our enterprise-wide capital management practices and strategies can be found below. 

Enterprise-Wide Capital Management 

Capital Management 

Objective 
BMO is committed to a disciplined approach to capital management that balances the interests and requirements of shareholders, regulators, 
depositors, fixed income investors and rating agencies. Our objective is to maintain a strong capital position in a cost-effective structure that: 
•  Is appropriate given BMO’s target regulatory capital ratios and internal assessment of required economic capital 
•  Underpins BMO’s operating groups’ business strategies 
•  Supports depositor, investor and regulator confidence, while building long-term shareholder value 
•  Is consistent with BMO’s target credit ratings. 

Framework 

M
D
&
A

Capital Demand 
Capital required to support 
the risks underlying our 
business activities 

Capital adequacy 
assessment of capital 
demand and supply 

Capital Supply 
Capital available
to support risks

The principles and key elements of our capital management framework are outlined in our Capital Management Corporate Policy and in the annual 
capital plan, which includes the results of the comprehensive Internal Capital Adequacy Assessment Process (ICAAP). 

ICAAP is an integrated process that involves the application of stress testing and other tools to evaluate capital adequacy on both a regulatory 
and an economic capital basis. The results of this process are used in the establishment of capital targets and the implementation of capital strategies 
that take into consideration the strategic direction and risk appetite of the enterprise. The capital plan is developed considering the results of ICAAP 
and in conjunction with the annual business plan, promoting alignment between business and risk strategies, regulatory and economic capital 
requirements and the availability of capital. Enterprise-wide stress testing and scenario analysis are conducted in order to assess the impact of various 
stress conditions on our risk profile and capital requirements. The capital management framework seeks to ensure that the bank is adequately 
capitalized given the risks it takes in the normal course of business, as well as under stress, and supports the determination of limits, targets and 
performance measures that are used to manage balance sheet positions, risk levels and capital requirements at both the consolidated entity and 
operating group levels. We evaluate assessments of actual and forecast capital adequacy against our capital plan throughout the year, and we update 
the plan to reflect changes in business activities, risk profile, the operating environment or regulatory expectations. 

We allocate capital to operating groups in order to evaluate business performance, and we consider capital implications in our strategic, tactical 

and transactional decision-making. By allocating capital to operating groups, setting and monitoring capital limits and metrics, and measuring the 
groups’ performance against these limits and metrics, we seek to optimize risk-adjusted return to shareholders, while maintaining a well-capitalized 
position. This approach aims to protect our stakeholders from the risks inherent in our various businesses, while still allowing the flexibility to deploy 
resources in support of the strategic growth activities of the operating groups. 

Refer to the Enterprise-Wide Risk Management section for further discussion of the risks underlying our business activities. 

Governance 
The Board of Directors, either directly or in conjunction with its Risk Review Committee, provides ultimate oversight and approval of capital 
management, including the bank’s Capital Management Corporate Policy framework, capital plan and capital adequacy assessments. The Board of 
Directors regularly reviews the bank’s capital position and key capital management activities, and the Risk Review Committee reviews the capital 
adequacy assessment results determined by ICAAP. The Capital Management Committee provides senior management oversight, including the review 
of significant capital management policies, issues and activities and, along with the Risk Management Committee, the capital required to support 
the execution of our enterprise-wide strategy. Finance and Risk Management are responsible for the design and implementation of the corporate 
policies and frameworks related to capital and risk management, as well as the ICAAP. The Corporate Audit Division, as the third line of defence, 
verifies adherence to controls and identifies opportunities to strengthen the bank’s processes. Refer to the Enterprise-Wide Risk Management 
Framework section for further discussion. 

BMO Financial Group 204th Annual Report 2021  65 

 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Regulatory Capital Requirements 
Regulatory capital requirements for BMO are determined in accordance with guidelines issued by the Office of the Superintendent of Financial 
Institutions (OSFI), which are based on the Basel III framework developed by the Basel Committee on Banking Supervision (BCBS). The minimum 
risk-based capital ratios set out in OSFI’s Capital Adequacy Requirements (CAR) Guideline are a 4.5% Common Equity Tier 1 (CET1) Ratio, 6% Tier 1 
Capital Ratio and 8% Total Capital Ratio. In addition to the minimum capital requirements, OSFI also requires domestic systemically important banks 
(D-SIBs), including BMO, to hold Pillar 1 and Pillar 2 buffers, which are meant to be used as a normal first response in periods of stress. Pillar 1 buffers 
include a Capital Conservation Buffer of 2.5%, a D-SIB Common Equity Tier 1 surcharge of 1.0%, and a Countercyclical Buffer (which can range 
from 0% to 2.5%, depending on a bank’s exposure to jurisdictions that have activated the buffer). The Domestic Stability Buffer (DSB), a Pillar 2 buffer 
that can range from 0% to 2.5%, is currently set at 2.5% as of October 31, 2021. The minimum Leverage Ratio set out in OSFI’s Leverage 
Requirements (LR) Guideline is 3.0%. OSFI’s capital requirements are summarized in the following table. 

(% of risk-weighted assets or leverage exposures) 

Common Equity Tier 1 Ratio 

A
&
D
M

Tier 1 Capital Ratio 

Total Capital Ratio 

Leverage Ratio 

Minimum capital 
requirements 

Pillar 1 Capital 
Buffers (1) 

Domestic Stability 
Buffer (2) 

OSFI capital requirements 
including capital buffers 

BMO Capital and Leverage 
Ratios as at October 31, 2021 

4.5% 

6.0% 

8.0% 

3.0% 

3.5% 

3.5% 

3.5% 

na 

2.5% 

2.5% 

2.5% 

na 

10.5% 

12.0% 

14.0% 

3.0% 

13.7% 

15.4% 

17.6% 

5.1% 

(1)  The minimum 4.5% CET1 Ratio requirement is augmented by 3.5% in Pillar 1 Capital Buffers, which can absorb losses during periods of stress. Pillar 1 Capital Buffers include a 2.5% Capital 

Conservation Buffer, a 1.0% Common Equity Tier 1 Surcharge for D-SIBs and a Countercyclical Buffer, as prescribed by OSFI (immaterial for the fourth quarter of 2021). If a bank’s capital ratios fall 
within the range of this combined buffer, restrictions on discretionary distributions of earnings (such as dividends, share repurchases and discretionary compensation) would ensue, with the degree of 
such restrictions varying according to the position of the bank’s ratios within the buffer range. 

(2)  OSFI requires all D-SIBs to maintain a DSB against Pillar 2 risks associated with systemic vulnerabilities. The DSB can range from 0% to 2.5% of total RWA and was set at 2.5% as at October 31, 2021. 

Breaches of the DSB will not result in a bank being subject to automatic constraints on capital distributions. 

na – not applicable 

Regulatory Capital and Total Loss Absorbing Capacity Ratios 

The Common Equity Tier 1 Ratio reflects CET1 Capital divided by Risk-Weighted Assets (RWA). 

The Tier 1 Capital Ratio reflects Tier 1 Capital divided by RWA. 

The Total Capital Ratio reflects Total Capital divided by RWA. 

The Leverage Ratio reflects Tier 1 Capital divided by leverage exposures (LE), which consist of on-balance sheet items and specified off-balance 
sheet items, net of specified adjustments. 

The Total Loss Absorbing Capacity (TLAC) Ratio reflects TLAC divided by RWA. 

The TLAC Leverage Ratio reflects TLAC divided by LE. 

Refer to the Glossary of Financial Terms for definitions of ratios and their components. 

Regulatory Capital and Total Loss Absorbing Capacity Elements 
BMO maintains a capital structure that is diversified across instruments and tiers to provide an appropriate mix of loss absorbency. The major 
components of regulatory capital and total loss absorbing capacity are summarized as follows: 

Tier 1 Capital 

Total Capital 

TLAC 

CET1 Capital 

• Common Shareholders’ Equity 
• May include portion of expected credit loss provisions 
• Less regulatory deductions for items such as: 

o Goodwill 
o Intangible assets 
o Defined benefit pension assets 
o Certain deferred tax assets 
o Certain other items 

Additional Tier 1 (AT1) Capital 

• Preferred shares 
• Other AT1 capital instruments 
• Less regulatory deductions 

Tier 2 Capital 

• Subordinated debentures 
• May include portion of expected credit loss provisions 
• Less regulatory deductions 

Other Total Loss Absorbing Capacity (TLAC) 

• Other TLAC instruments (including eligible Bail-in debt) 
• Less regulatory deductions 

66  BMO Financial Group 204th Annual Report 2021 

 
OSFI’s CAR Guideline implemented the non-viability contingent capital (NVCC) provisions set out by the BCBS, which require the conversion of certain 
capital instruments into a variable number of common shares in the event that OSFI announces that a bank is, or is about to become, non-viable, or 
if the federal or a provincial government in Canada publicly announces that the bank has accepted, or has agreed to accept, a capital injection or 
equivalent support to avoid non-viability. 

Under OSFI’s CAR Guideline, non-common share capital instruments that do not meet Basel III requirements, including NVCC requirements, 

will be fully phased out by 2022. The impact on the bank will be nominal. 

Under Canada’s Bank Recapitalization (Bail-In) Regime, eligible senior debt issued on or after September 23, 2018 is subject to statutory 
conversion requirements. Canada Deposit Insurance Corporation has the power to trigger the conversion of bail-in debt into common shares. 
This statutory conversion supplements NVCC securities, which must be converted, in full, prior to the conversion of bail-in debt. The minimum 
TLAC requirements set by OSFI are a risk-based TLAC Ratio of 24.0% of RWA, including a 2.5% DSB, and a TLAC Leverage Ratio of 6.75%, effective 
November 1, 2021. As at October 31, 2021, our TLAC Ratio was 27.8% and our TLAC Leverage Ratio was 9.3%, disclosed in accordance with OSFI’s 
TLAC Guideline. 

Risk-Weighted Assets 
RWA measure a bank’s exposures, weighted for their relative risk and calculated in accordance with OSFI’s regulatory capital rules. RWA are calculated 
for credit, market and operational risks based on OSFI’s prescribed rules. 

We primarily use the Advanced Internal Ratings Based (AIRB) Approach to determine credit RWA in our portfolio. The AIRB Approach utilizes 
sophisticated techniques to measure RWA at the exposure level based on sound risk management principles, including estimates of the probability 
of default, the loss given default and exposure at default risk parameters, term to maturity and asset class type, as prescribed by the OSFI rules. 
These risk parameters are determined using historical portfolio data supplemented by benchmarking, as appropriate, and are updated periodically. 
Validation procedures related to these parameters are in place in order to quantify and differentiate risks appropriately. Credit RWA related to certain 
Canadian and U.S. portfolios are determined under the Standardized Approach, using prescribed risk weights based on external ratings, counterparty 
type or product type. 

Our market risk RWA are primarily determined using the more advanced Internal Models Approach, but the Standardized Approach is used for 

M
D
&
A

some exposures. 

Beginning in fiscal 2020, OSFI required BMO, along with the other banks that have been approved to use the Advanced Measurement Approach, 
to change to the Basel II Standardized Approach for determining enterprise operational risk regulatory capital requirements in the interim period prior 
to implementation of the new Basel III Standardized Measurement Approach, part of the Basel III reforms. 

We are subject to a capital floor as prescribed in OSFI’s CAR Guideline. In calculating regulatory capital ratios, there is a requirement to increase 
RWA when an amount calculated under the Standardized Approach (covering RWA and allowances) is higher than the result of a similar calculation 
under the more risk-sensitive modelled approach. The capital floor was not operative for the bank in fiscal 2021 and fiscal 2020. 

Regulatory Capital Developments 

Domestic Implementation of the Basel III Reforms 
On March 11, 2021, OSFI restarted the implementation of the Basel III reforms by launching an industry consultation on proposed regulatory changes 
reflecting the latest and final round of Basel III reforms in its capital, leverage and related disclosure guidelines for banks. Proposals in the 
consultation include a three-year phase-in of the capital floor factor, starting at 65% in 2023 and increasing 2.5% per year to 72.5% in 2026, and a 
leverage ratio buffer for D-SIBs, set at 50% of the D-SIB Common Equity Tier 1 Surcharge, currently 1.0%, for a minimum Leverage Ratio requirement 
of 3.5% and a minimum TLAC Leverage Ratio requirement of 7.25% when the leverage ratio buffer comes into effect. 

On June 18, 2021, OSFI launched an industry consultation on proposed regulatory changes to the treatment of credit valuation adjustments (CVA) 

and market risk hedges of other valuation adjustments, as part of the ongoing Basel III reforms. 

On November 29, 2021, OSFI announced a deferral in the timing for the domestic implementation of the final Basel III reforms and changes to 

Pillar 3 disclosure requirements by one quarter from the first quarter to the second quarter of fiscal 2023. 

COVID-19 Related Modifications 
As part of a coordinated effort by federal agencies to address the market disruptions posed by the COVID-19 pandemic, OSFI announced a suite of 
modifications to capital requirements, effective the second quarter of 2020, to afford institutions further flexibility in addressing the disruptions, while 
promoting financial resilience and economic stability. During fiscal 2021, OSFI has either unwound, or provided guidance on the unwinding, of these 
temporary modifications. 

Regulatory Expectations on Dividend Increases and Share Repurchases 
Effective November 4, 2021, OSFI announced that institutions may resume regular dividend increases and common share repurchases that have been 
restricted since March 13, 2020. 

Leverage Ratio 
On August 12, 2021, OSFI confirmed that the temporary exclusion of sovereign-issued securities from the leverage ratio exposure measure for 
deposit-taking institutions (DTIs) will end on December 31, 2021. Central bank reserves will continue to be excluded. 

BMO Financial Group 204th Annual Report 2021  67 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Domestic Stability Buffer 
On June 17, 2021, OSFI set the level of the Domestic Stability Buffer (DSB) at 2.5%, an increase from 1.0%, effective October 31, 2021. The increase 
reflects OSFI’s view that key vulnerabilities, such as household and corporate debt levels, remain elevated and in some cases have increased since 
March 2020, while the economic and market disruptions stemming from the COVID-19 pandemic have abated and banks’ capital levels have 
remained resilient. 

Stressed Value-at-Risk (VaR) Multipliers under Market Risk 
Effective May 1, 2021, the SVaR multiplier for market risk capital requirements, which was temporarily reduced to a minimum value of one, returned 
to the pre-pandemic minimum value of three. 

Government of Canada’s Highly Affected Sectors Credit Availability Program 
On January 27, 2021, OSFI advised that loans to businesses through the Government of Canada’s Highly Affected Sectors Credit Availability Program 
(HASCAP) can be treated as exposures to the Government of Canada. DTIs must include the entire amount of the loan in the leverage ratio calculation. 

A
&
D
M

Regulatory Capital Review 
BMO is well capitalized, with capital ratios that exceed OSFI’s published requirements for large Canadian banks, including a 2.5% DSB. Our CET1 Ratio 
was 13.7% as at October 31, 2021, compared with 11.9% as at October 31, 2020. The CET1 Ratio increased from the end of fiscal 2020, primarily 
driven by strong internal capital generation. 

Our Tier 1 Capital and Total Capital Ratios were 15.4% and 17.6%, respectively, as at October 31, 2021, compared with 13.6% and 16.2%, 
respectively, as at October 31, 2020. The Tier 1 Capital and Total Capital Ratios were higher, primarily due to the factors impacting the CET1 Ratio, 
partially offset by the redemptions of Additional Tier 1 and Tier 2 capital instruments, respectively. 

The impact of foreign exchange rate movements on capital ratios was largely offset. Our investments in foreign operations are primarily 

denominated in U.S. dollars, and the foreign exchange impact of U.S.-dollar-denominated RWA and capital deductions may result in variability in the 
bank’s capital ratios. We may manage the impact of foreign exchange rate movements on our capital ratios, and did so during fiscal 2021. Any such 
activities could also impact BMO’s book value and return on equity. 

Our Leverage Ratio was 5.1% as at October 31, 2021, an increase from 4.8% as at October 31, 2020, as higher Tier 1 Capital was partially offset 

by higher leverage exposures. Leverage exposures increased from the prior year, driven by business growth, partially offset by the impact from 
foreign exchange rate movements. 

While the ratios discussed above reflect our consolidated capital base, we conduct business through a variety of corporate structures, including 

subsidiaries. A framework is in place such that capital and funding are managed appropriately at the subsidiary level. 

As a U.S. bank intermediate holding company classified as a Category IV institution, our subsidiary BMO Financial Corp. (BFC) is subject to the 
Comprehensive Capital Analysis and Review (CCAR) and Dodd-Frank Act Stress Test (DFAST) requirements of the Federal Reserve Board (FRB) on a 
biennial basis, beginning with CCAR 2020. 

BFC elected to participate in the FRB’s 2021 CCAR exercise, even though it was not required to as a Category IV institution. On June 24, 2021, the 

FRB released its 2021 CCAR and DFAST results, and on August 5, 2021, announced individual large bank capital requirements, which were effective 
October 1, 2021. The capital requirement for BFC determined by the FRB was a CET1 Ratio of 7.5%, including the 4.5% minimum CET1 Ratio and 
a 3.0% stress capital buffer (SCB), which is significantly reduced from the previous 6.0%. BFC is well capitalized, with a strong CET1 Ratio of 13.9% as 
at September 30, 2021. 

68  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Regulatory Capital (1) 

(Canadian $ in millions) 
As at October 31 

Common Equity Tier 1 Capital: instruments and reserves 

Directly issued qualifying common share capital plus related stock surplus 
Retained earnings 
Accumulated other comprehensive income (and other reserves) 
Goodwill and other intangibles (net of related tax liability) 
Other common equity Tier 1 capital deductions 

Common Equity Tier 1 Capital (CET1) 

Additional Tier 1 Capital: instruments 

Directly issued qualifying Additional Tier 1 instruments plus related stock surplus 
Directly issued capital instruments subject to phase-out from Additional Tier 1 Capital 
Additional Tier 1 instruments (and CET1 instruments not otherwise included) issued by subsidiaries and 

held by third parties (amount allowed in group AT1) 

of which: instruments issued by subsidiaries subject to phase-out 

Total regulatory adjustments applied to Additional Tier 1 Capital 

Additional Tier 1 Capital (AT1) 

Tier 1 Capital (T1 = CET1 + AT1) 

Tier 2 Capital: instruments and provisions 

Directly issued qualifying Tier 2 instruments plus related stock surplus 
Directly issued capital instruments subject to phase-out from Tier 2 Capital 
Tier 2 instruments (and CET1 and AT1 instruments not otherwise included) issued by subsidiaries and 

held by third parties (amount allowed in group Tier 2) 

of which: instruments issued by subsidiaries subject to phase-out 

General allowance 

Total regulatory adjustments to Tier 2 Capital 

Tier 2 Capital (T2) 

Total Capital (TC = T1 + T2) 

Risk-Weighted Assets and Leverage Ratio Exposures 
Risk-Weighted Assets 
Leverage Ratio Exposures 

Capital Ratios (%) 
Common Equity Tier 1 Ratio 
Tier 1 Capital Ratio 
Total Capital Ratio 
Leverage Ratio 

2021 

2020 

13,912 
35,497 
2,556 
(7,130) 
(344) 

44,491 

5,558 
– 

– 
– 

(83) 

5,475 

49,966 

6,747 
141 

– 
– 
398 

(51) 

7,235 

57,201 

325,433 
976,690 

13.7 
15.4 
17.6 
5.1 

M
D
&
A

13,732 
30,745 
5,518 
(8,402) 
(1,516) 

40,077 

5,558 
290 

– 
– 

(85) 

5,763 

45,840 

8,270 
146 

– 
– 
458 

(53) 

8,821 

54,661 

336,607 
953,640 

11.9 
13.6 
16.2 
4.8 

(1)  Disclosed in accordance with OSFI’s CAR Guideline and LR Guideline, as applicable. Non-qualifying Additional Tier 1 and Tier 2 Capital instruments are being phased out at a rate of 10% per year from 

January 1, 2013 to January 1, 2022. 

Our CET1 Capital was $44.5 billion as at October 31, 2021, compared with $40.1 billion as at October 31, 2020. CET1 Capital increased, driven by 
retained earnings growth and a lower goodwill deduction due to the write-down in the second quarter of fiscal 2021 related to the sale of our EMEA 
Asset Management business, partially offset by a decline in accumulated other comprehensive income, primarily from the impact of foreign exchange 
rate movements. 

Tier 1 Capital and Total Capital were $50.0 billion and $57.2 billion, respectively, as at October 31, 2021, compared with $45.8 billion and 

$54.7 billion, respectively, as at October 31, 2020. The increase in Tier 1 Capital was primarily due to the factors impacting CET1 Capital, partially offset 
by preferred share redemptions. Total Capital was higher, primarily due to the factors impacting Tier 1 Capital and an issuance of subordinated notes, 
which was partially offset by redemptions. 

Risk-Weighted Assets 
RWA were $325.4 billion as at October 31, 2021, a decrease from $336.6 billion as at October 31, 2020. Credit Risk RWA were $272.9 billion as at 
October 31, 2021, a decrease from $289.0 billion as at October 31, 2020, primarily due to positive asset quality changes and the impact of foreign 
exchange rate movements, partially offset by increased asset size. As noted above, the impact of foreign exchange rate movements is largely offset 
in the CET1 Ratio. Market Risk RWA were $12.1 billion as at October 31, 2021, an increase from $9.3 billion as at October 31, 2020, primarily 
attributable to the removal of OSFI’s regulatory measures in response to the COVID-19 pandemic, as well as changes in portfolio composition during 
the year. Operational Risk RWA were $40.5 billion as at October 31, 2021, an increase from $38.3 billion as at October 31, 2020, primarily from 
growth in our average gross income. 

BMO Financial Group 204th Annual Report 2021  69 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

(Canadian $ in millions) 
As at October 31 

Credit Risk 

Wholesale 

Corporate, including specialized lending 
Corporate small and medium-sized enterprises 
Sovereign 
Bank 

Retail 

Residential mortgages, excluding home equity line of credit 
Home equity line of credit 
Qualifying revolving retail 
Other retail, excluding small and medium-sized enterprises 
Retail small and medium-sized enterprises 

Equity 
Trading book 
Securitization 
Other credit risk assets – non-counterparty managed assets 
Scaling factor for credit risk assets under AIRB Approach (1) 

A
&
D
M

Total Credit Risk 
Market Risk 
Operational Risk 

Risk-Weighted Assets 

2021 

2020 

117,876 
43,562 
5,369 
4,345 

8,712 
5,241 
6,515 
15,406 
9,544 
3,741 
13,066 
4,570 
22,587 
12,324 

272,858 
12,066 
40,509 

325,433 

131,396 
45,121 
6,259 
4,264 

9,275 
5,430 
5,917 
14,507 
9,689 
2,773 
15,567 
5,761 
20,050 
12,908 

288,917 
9,348 
38,342 

336,607 

(1)  The scaling factor is applied to RWA amounts for credit risk under the Advanced Internal Ratings Based (AIRB) Approach. 

Economic Capital 
Economic capital is an expression of the enterprise’s capital demand requirement relative to its view of the economic risks in its underlying business 
activities. It represents management’s estimation of the likely magnitude of economic losses that could occur should severely adverse situations 
arise. Economic loss is the loss in economic or market value incurred over a specified time horizon at a defined confidence level, relative to the 
expected loss over the same time horizon. Economic capital is calculated for various types of risk, including credit, market (trading and non-trading), 
operational, business and insurance, based on a one-year time horizon using a defined confidence level. 

Economic Capital and RWA by Operating Group and Risk Type 
(As at October 31, 2021) 

BMO Financial Group

Operating Groups 

Personal and 
Commercial 
Banking 

 BMO Wealth 
Management 

BMO Capital 
Markets 

Corporate
Services

Economic Capital by Risk Type (%) 

Credit 

Market 

Operational/Other 

RWA by Risk Type  
(Canadian $ in millions) 

Credit 

Market 

Operational 

76% 

7% 

17% 

172,892 

– 

22,243 

36% 

20% 

44% 

17,563 

42 

6,749 

60% 

25% 

15% 

67,904 

12,024 

11,517 

86% 

14% 

– 

14,499 

– 

– 

Capital Management Activities 
On December 3, 2021, we announced our intention, subject to the approval of OSFI and the Toronto Stock Exchange, to establish a new normal course 
issuer bid (NCIB) for up to 22.5 million common shares. The NCIB is a regular part of our capital management strategy. Once approvals are obtained, 
the share repurchase program will permit us to purchase BMO common shares for the purpose of cancellation. The timing and amount of purchases 
under the NCIB are subject to regulatory approvals and to management discretion, based on factors such as market conditions and capital levels. We 
will consult with OSFI before making purchases under the NCIB. 

During fiscal 2021, we issued approximately 1.6 million common shares through the exercise of stock options. 
During fiscal 2021, we completed Tier 1 and Tier 2 Capital instrument issuances and redemptions, as outlined in the table below. 

70  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Capital Instrument Issuances and Redemptions 

(in millions) 
As at October 31, 2021 

Common shares issued 
Stock options exercised 

Tier 1 Capital 
Redemption of Non-Cumulative Perpetual Class B Preferred Shares, Series 35 
Redemption of Non-Cumulative 5-Year Rate Reset Class B Preferred Shares, Series 36 
Redemption of Non-Cumulative 5-Year Rate Reset Class B Preferred Shares, Series 25 
Redemption of Non-Cumulative Floating Rate Class B Preferred Shares, Series 26 

Tier 2 Capital 
Redemption of Series H Medium-Term Notes, Second Tranche 
Redemption of Series I Medium-Term Notes, First Tranche 
Issuance of Series K Medium-Term Notes, First Tranche 

Issuance 
or redemption date 

Number 
of shares 

Amount 

November 25, 2020 
November 25, 2020 
August 25, 2021 
August 25, 2021 

December 8, 2020 
June 1, 2021 
July 22, 2021 

1.6 

$  122 

6.0 
0.6 
9.4 
2.6 

$  150 
$  600 
$  236 
$  54 

$1,000 
$1,250 
$1,000 

If an NVCC trigger event were to occur, NVCC capital instruments would be converted into BMO common shares pursuant to automatic conversion 
formulas, with a conversion price based on the greater of: (i) a floor price of $5.00; and (ii) the current market price of BMO common shares at the 
time of the trigger event (calculated using a 10-day weighted average). Based on a floor price of $5.00, these NVCC capital instruments would be 
converted into approximately 3.2 billion BMO common shares, assuming no accrued interest and no declared and unpaid dividends. 

Further details on subordinated debt and share capital are provided in Notes 15 and 16 of the consolidated financial statements. 

Outstanding Shares and NVCC Capital Instruments 

M
D
&
A

As at October 31 

Common shares 

Class B Preferred shares 

Series 25 (1) 
Series 26 (1)
Series 27*
Series 29*
Series 31*
Series 33*
Series 35* (2)
Series 36* (2)
Series 38*
Series 40*
Series 42*
Series 44*
Series 46*

Additional Tier 1 Capital Notes*

4.8% Additional Tier 1 Capital Notes 
4.3% Limited Recourse Capital Notes, Series 1 (3)

Medium-Term Notes* (4)

Series I – Second Tranche 
3.803% Subordinated Notes 
4.338% Subordinated Notes 
Series J – First Tranche 
Series J – Second Tranche 
Series K – First Tranche 

Stock options 

Vested 
Non-vested 

Number of shares 
or dollar amount 
(in millions) 

Dividends declared per share 

2021 

2020 

2019 

648 

$  4.24 

$  4.24 

$  4.06 

$  0.34 
$  0.23 
$  0.96 
$  0.91 
$  0.96 
$  0.76 
– 
– 
$  1.21 
$  1.13 
$  1.10 
$  1.21 
$  1.28 

na 
na 

na 
na 
na 
na 
na 
na 

$  0.45 
$  0.52 
$  0.96 
$  0.91 
$  0.96 
$  0.90 
$  1.25 
$58.50 
$  1.21 
$  1.13 
$  1.10 
$  1.21 
$  1.28 

na 
na 

na 
na 
na 
na 
na 
na 

$  0.45 
$  0.70 
$  0.98 
$  0.96 
$  0.95 
$  0.95 
$  1.25 
$58.50 
$  1.21 
$  1.13 
$  1.10 
$  1.44 
$  0.77 

na 
na 

na 
na 
na 
na 
na 
na 

– 
– 
$  500 
$  400 
$  300 
$  200 
– 
– 
$  600 
$  500 
$  400 
$  400 
$  350 

US$  500 
$1,250 

$  850 
US$1,250 
US$  850 
$1,000 
$1,250 
$1,000 

2.6 
3.1 

Convertible into common shares. 

* 
(1)  Redeemed in August 2021. 
(2)  Redeemed in November 2020. 
(3)  Convertible into common shares by virtue of recourse to the Preferred Shares Series 48. Refer to Note 16 of the consolidated financial statements for conversion details. 
(4)  Note 15 of the consolidated financial statements includes details on the NVCC Medium-Term Notes. 

na – not applicable 

Note 16 of the consolidated financial statements includes details on share capital and other equity instruments. 

BMO Financial Group 204th Annual Report 2021  71 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Dividends 
Dividends declared per common share in fiscal 2021 totalled $4.24, unchanged from the prior year. Annual dividends declared represented 36.5% 
of reported net income and 32.6% of adjusted net income available to common shareholders on a last twelve-month basis. 

Our target dividend payout range (common share dividends as a percentage of net income available to shareholders, less preferred share 
dividends and distributions on other equity instruments, based on earnings over the last twelve months) is 40% to 50%, providing shareholders with 
a competitive dividend yield. Our target dividend payout range seeks to provide shareholders with stable income, while retaining sufficient earnings 
to support anticipated business growth, fund strategic investments and support capital adequacy. OSFI’s restriction on dividend increases effective 
March 13, 2020 remained in place throughout the year. Effective November 4, 2021, OSFI advised that institutions may resume regular dividend 
increases and common share repurchases. 

At year-end, our common shares provided a 3.2% annualized dividend yield based on the year-end closing share price. On December 3, 2021, we 
announced that the Board of Directors had declared a quarterly dividend on common shares of $1.33 per share, an increase of $0.27 per share or 25% 
from the prior quarter and prior year. The dividend is payable on February 28, 2022 to shareholders of record on February 1, 2022. 

A
&
D
M

Shareholder Dividend Reinvestment and Share Purchase Plan 
Common shareholders may elect to have their cash dividends reinvested in common shares of BMO, in accordance with the Shareholder Dividend 
Reinvestment and Share Purchase Plan (DRIP). 

During fiscal 2021, common shares to supply the DRIP were purchased on the open market. In the first and second quarters of fiscal 2020, 
common shares to supply the DRIP were purchased on the open market. In the third and fourth quarters of fiscal 2020, common shares to supply the 
dividend reinvestment feature of the DRIP were issued from treasury at a 2% discount from their then-current market price. 

Eligible Dividends Designation 
For the purposes of the Income Tax Act (Canada) and any similar provincial and territorial legislation, BMO designates all dividends paid or deemed 
to be paid on both its common and preferred shares as “eligible dividends”, unless indicated otherwise. 

Caution 
This Enterprise-Wide Capital Management section contains forward-looking statements. Please refer to the Caution Regarding Forward-Looking Statements. 

Off-Balance Sheet Arrangements 
We enter into a number of off-balance sheet arrangements in the normal course of operations, which include Structured Entities (SEs), 
Credit Instruments and Guarantees. 

Structured Entities and Securitization 
We carry out certain business activities through arrangements involving SEs, using them to obtain sources of liquidity by securitizing certain of our 
financial assets, secure customer transactions, or pass our credit risk to holders of the vehicles’ securities. For example, we enter into transactions 
with SEs in which we transfer assets, including mortgage loans, mortgage-backed securities, credit card loans, real estate lines of credit, auto 
loans and equipment loans, in order to obtain alternate sources of funding or as part of our trading activities. Note 6 of the consolidated financial 
statements describes the loan securitization activities carried out through third-party programs such as the Canada Mortgage Bond Program. Note 7 of 
the consolidated financial statements provides further details of our interests in both consolidated and unconsolidated SEs. Under IFRS, we consolidate 
a SE if we control the entity. We consolidate our own securitization vehicles and certain capital and funding vehicles. We do not consolidate our 
Canadian customer securitization vehicles, certain capital vehicles, various BMO-managed funds or various other structured entities where 
investments are held. Effective October 31, 2021, we concluded that we no longer control our U.S. Customer Securitization Vehicle and have therefore 
deconsolidated this vehicle. Further details on U.S. and Canadian customer securitization vehicles are provided below. 

BMO-Sponsored Securitization Vehicles 
We sponsor various vehicles that fund assets originated either by us (which are then securitized through a bank securitization vehicle) or by our 
customers (which are then securitized through three Canadian customer securitization vehicles and one U.S. customer securitization vehicle). The bank 
earns fees for providing services related to these customer securitization vehicles, including liquidity, distribution and financial arrangement fees for 
supporting the ongoing operations of the vehicles. These fees totalled approximately $132 million in 2021 ($117 million in 2020). 

Canadian Customer Securitization Vehicles 
The customer securitization vehicles we sponsor in Canada provide customers with access to financing either from us or from the asset-backed 
commercial paper (ABCP) markets. Customers sell either their assets or an interest in their assets into these vehicles, which then issue ABCP to either 
investors or us in order to fund the purchases. The sellers remain responsible for servicing the transferred assets and are first to absorb any losses 
realized on those assets. We are not responsible for servicing or absorbing the first loss and none of the sellers are affiliated with BMO. 

Our exposure to potential losses arises from the purchase of ABCP issued by the vehicles, any related derivative contracts entered into with the 
vehicles, and the liquidity support provided to the market-funded vehicles. We use the credit adjudication process in deciding whether to enter into 
these arrangements, just as when extending credit in the form of a loan. 

Two of these customer securitization vehicles are market-funded, while the third is funded directly by the bank. We do not control these entities 

and therefore they are not consolidated. Further information on the consolidation of customer securitization vehicles is provided in Note 7 of the 
consolidated financial statements. No losses were recorded on any of our exposures to these vehicles in 2021 and 2020. 

The market-funded vehicles had a total of $3.6 billion of ABCP outstanding as at October 31, 2021 ($4.7 billion in 2020). The ABCP issued by the 

market-funded vehicles is rated R-1(high) by DBRS and P1 by Moody’s. Our purchases of ABCP, as distributing agent of ABCP issued by the market-
funded vehicles, totalled $24 million during the year ended October 31, 2021 ($75 million in 2020). 

We provide committed liquidity support facilities for the market-funded vehicles totalling $4.8 billion as at October 31, 2021 ($5.6 billion 
in 2020). This amount comprises part of the commitments outlined in Note 24 of the consolidated financial statements. All of these facilities remain 
undrawn. The assets of each of these market-funded vehicles consist primarily of exposure to diversified pools of Canadian automobile-related 
receivables and Canadian insured and conventional residential mortgages. These two asset classes represent 62% (76% in 2020) of the aggregate 
assets of these vehicles. 

72  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
M
D
&
A

U.S. Customer Securitization Vehicle 
We sponsor one market-funded customer securitization vehicle in the United States that provides customers with access to financing in the U.S. ABCP 
market. Customers sell either their assets or an interest in their assets into this vehicle, which then issues ABCP to investors in order to fund the 
purchases. The sellers remain responsible for servicing the assets involved in the related financing and are first to absorb any losses realized on those 
assets. We are not responsible for servicing or absorbing the first loss and none of the sellers are affiliated with BMO. 

Our exposure to potential losses arises from the purchase of ABCP issued by the vehicle, any related derivative contracts entered into with 

the vehicle, and the liquidity support provided to the vehicle. We use the credit adjudication process in deciding whether to enter into these 
arrangements, just as when extending credit in the form of a loan. No losses were recorded on any of our exposures to the vehicle in 2021 and 2020. 
Effective October 31, 2021, we concluded that we no longer control this vehicle, and therefore deconsolidated this vehicle, as our involvement 
has changed from principal to agent, as reflected primarily by the change in our exposure to its variable returns. We derecognized US$3,148 million 
($3,896 million) of assets and US$2,967 million ($3,672 million) of liabilities from our consolidated balance sheet on loss of control. We concurrently 
recognized US$176 million ($218 million) in securities, representing the carrying value of our interest in the vehicle’s ABCP (we held US$140 million 
as at October 31, 2020, which was previously eliminated upon consolidation), and US$5 million ($6 million) in other assets. No gain or loss was 
recognized in our consolidated income statement as a result of deconsolidating this vehicle. Further information on the consolidation of customer 
securitization vehicles is provided in Note 7 of the consolidated financial statements. 

The vehicle had US$3.1 billion of ABCP outstanding as at October 31, 2021 (US$2.5 billion in 2020). The ABCP issued by the vehicle is rated A1 

by S&P and P1 by Moody’s. 

We provide committed liquidity support facilities to the vehicle, with the undrawn amount totalling US$6.5 billion as at October 31, 2021 
(US$5.5 billion in 2020). This amount comprises part of the commitments outlined in Note 24 of the consolidated financial statements. The assets of 
this vehicle consist primarily of exposure to diversified pools of U.S. automobile-related receivables and equipment loans and leases. These two asset 
classes represent 82% (85% in 2020) of the aggregate assets of the vehicle. 

Credit Instruments 
In order to meet the financial needs of our clients, we use a variety of off-balance sheet credit instruments. These include guarantees and standby 
letters of credit, which represent our obligation to make payments to third parties on behalf of a customer if the customer is unable to make the 
required payments or meet other contractual requirements. We also write documentary and commercial letters of credit, which represent agreements 
to honour drafts presented by a third party upon completion of specified activities. Commitments to extend credit are off-balance sheet arrangements 
that represent our commitment to customers to grant them credit in the form of loans or other financings for specific amounts and maturities, subject 
to meeting certain conditions. 

There are a large number of credit instruments outstanding at any time. Our customers are broadly diversified, and we do not anticipate events 
or conditions that would cause a significant number of customers to fail to perform in accordance with the terms of their contracts. We use the credit 
adjudication process in deciding whether to enter into these arrangements, just as when extending credit in the form of a loan. We monitor 
off-balance sheet credit instruments in order to avoid undue concentrations in any geographic region or industry. 

The maximum amount payable by BMO in relation to these credit instruments was approximately $202 billion as at October 31, 2021 

($209 billion in 2020). However, this amount is not representative of our likely credit exposure or the liquidity requirements for these instruments, 
as it does not take into account customer behaviour, which suggests that only a portion of customers would utilize the facilities related to these 
instruments, nor does it take into account any amounts that could be recovered under recourse and collateral provisions. 

For the credit commitments outlined in the preceding paragraphs, in the absence of an event that triggers a default, early termination by BMO 

may result in a breach of contract. 

Further information on these instruments can be found in Note 24 of the consolidated financial statements. 

Guarantees 
Guarantees include contracts under which we may be required to make payments to a counterparty based on changes in the value of an asset, 
liability or equity security that the counterparty holds. Contracts under which we may be required to make payments if a third party does not perform 
according to the terms of a contract, and contracts under which we provide indirect guarantees of indebtedness, are also considered guarantees. 
In the normal course of business, we enter into a variety of guarantees, including standby letters of credit, backstop and other liquidity facilities, and 
derivatives contracts or instruments (including, but not limited to, credit default swaps), as well as indemnification agreements. 

The maximum amount payable by BMO in relation to these guarantees was approximately $40 billion as at October 31, 2021 ($31 billion 

in 2020). However, this amount is not representative of our likely exposure, as it does not take into account customer behaviour, which suggests that 
only a portion of the guarantees would require us to make any payments, nor does it take into account any amounts that could be recovered under 
recourse and collateral provisions. 

For a more detailed discussion of these arrangements, refer to Note 24 of the consolidated financial statements. 
Certain comparative figures have been reclassified to conform with the current year’s presentation. 

Caution 
This Off-Balance Sheet Arrangements section contains forward-looking statements. Please refer to the Caution Regarding Forward-Looking Statements. 

BMO Financial Group 204th Annual Report 2021  73 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Enterprise-Wide Risk Management 

As a diversified financial services company providing banking, wealth management, capital markets and insurance services, 
BMO is exposed to a variety of risks that are inherent in its business activities. A disciplined and integrated approach to 
managing risk is fundamental to the success of its operations. Our risk management framework provides independent risk 
oversight across the enterprise and is integral to building competitive advantage. 

Enterprise-Wide Risk Management outlines BMO’s approach to managing the key financial risks and other related risks that it faces, as discussed in 
the following sections: 

A
&
D
M

Risks That May Affect Future Results 
Risk Management Overview 
Enterprise-Wide Risk Management Framework 
Credit and Counterparty Risk 

74 
78 
78 
84 
92  Market Risk 
97 

Insurance Risk 

97 
106 
109 
111 
111 
113 

Liquidity and Funding Risk 
Operational Non-Financial Risk 
Legal and Regulatory Risk 
Strategic Risk 
Environmental and Social Risk 
Reputation Risk 

Text and tables presented in a blue-tinted font in the Enterprise-Wide Risk Management section of the MD&A form an integral part of the 2021 audited annual consolidated 
financial statements. They present required disclosures as set out by the International Accounting Standards Board in IFRS 7, Financial Instruments – Disclosures, which 
permits cross-referencing between the notes to the consolidated financial statements and the MD&A. Refer to Note 1 and Note 5 of the consolidated financial statements. 

Risks That May Affect Future Results 
Top and Emerging Risks That May Affect Future Results 
BMO is exposed to a variety of evolving internal and external events which can have an impact on our overall risk profile. These events can have the 
potential to affect our business, the results of our operations and our financial condition. The integral tasks in the risk management process are to 
proactively identify, assess, manage, monitor and report on a broad spectrum of risks arising from these events. The identification of specific types 
of risk involves several forums for discussion with the Board of Directors, senior management and business thought leaders, and combines both 
bottom-up and top-down approaches. The assessment of risks is supported by scenario analysis and can inform the development of action plans 
related to our exposure to certain events. 

Particular attention has been given to the following risks, reflecting their potential to materially impact the bank’s financial results, strategic 

direction or reputation. 

General Economic Conditions 
Our earnings are affected by the general economic conditions prevailing in Canada, the United States and other jurisdictions in which we conduct 
business. In the past year, as global economies continue to recover from the effects of the COVID-19 pandemic, growth in real GDP in both Canada 
and the United States has been strong, although growth in Canadian GDP in the second quarter of 2021 was hampered by new public health 
restrictions. Businesses and individuals have benefitted from the support of government programs intended to lessen the economic impact of the 
pandemic, and these programs, along with a reopening of the economies, have resulted in positive credit migration. The recovery faces headwinds 
generated by ongoing disruptions to global supply chains, trade and travel, as well as price and wage inflation and labour market challenges. 
The emergence of new variants of the COVID-19 virus also poses a threat to economic recovery. While vaccine efficacy remains high against most 
COVID-19 variants, particularly in limiting more severe cases, vaccination rates in North America are below the level required for general immunity. 

These factors, as well as rising geopolitical tensions (described in Geopolitical Risk and Escalating Trade Disputes below), could cause growth 

rates in North American economies to decline through the coming year. Management continues to review the economic environment in which we 
operate, to identify significant changes in key economic variables. In the event of a significant change in economic conditions, management will 
assess our portfolio and business strategies and develop contingency plans to address any adverse developments. 

Cyber Security Risk 
We are exposed to common banking security risks, given our ever-increasing reliance on internet and cloud technologies, coupled with the remote 
work environment and extensive dependence on advanced digital technologies to process data. Cyber security risks include the threat of data loss 
resulting in potential exposure of customer or employee information, identity theft and fraud. Ransomware or denial of service attacks could result in 
system failure and service disruption. Threat campaigns are becoming increasingly organized and sophisticated, with reported data breaches, often 
through third-party suppliers, that negatively impact the company’s brand and reputation. BMO is keeping pace by investing in the Financial Crimes 
Unit and technological infrastructure. These include a state-of-the-art security hub and a “follow-the-sun” operating model, equipping our team to 
detect and address security threats across North America, Europe and Asia in order to keep our customers’ and employees’ data secure. 

Benchmark Interest Rate Reform 
Interbank offered rates (IBORs) have been the subject of numerous global regulatory proposals and reforms over the past few years. Most 
significantly, the U.K. Financial Conduct Authority (FCA) has announced that it will no longer compel banks to submit to the London Interbank Offered 
Rate (LIBOR) after 2021. As a result, the industry must transition from LIBOR and other IBORs to alternative reference rates (ARRs) in multiple 
jurisdictions, a shift that will impact financial market participants globally across many products and asset classes. 

74  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Transition efforts in connection with these reforms are complex, with significant risks and challenges that could result in increased volatility, 

pricing changes or illiquidity in markets for instruments that currently rely on IBORs. The transition could have adverse consequences for all market 
participants, including BMO as both a holder and an issuer of IBOR-based instruments, such as the potential for heightened exposure to financial, 
operational non-financial, legal and regulatory, and reputation risks. 

BMO has established an enterprise IBOR Transition Office (ITO) to coordinate and oversee the transition from IBORs to ARRs, with a focus on 

managing and mitigating internal risks, while maintaining a positive client experience. The ITO, sponsored and supported by senior management, 
is responsible for running the enterprise-wide transition program across all lines of business and corporate areas. The ITO has a global mandate to 
properly prepare BMO for the discontinuation or unavailability of LIBOR and other IBORs. 

As part of its mandate, the ITO is tracking client, industry and regulatory engagement, financial contract changes, internal and external 
communications, technology and operations modifications, introduction of new products, migration of existing clients, and program strategy and 
governance. In addition, the ITO continues to monitor the development and usage of ARRs across the industry, including the Secured Overnight 
Financing Rate (SOFR). As the market has developed, we have begun to add ARR-based products to our suite of offerings. 

On March 5, 2021, the FCA confirmed that LIBOR settings will no longer be provided by any administrator after December 31, 2021 for all sterling, 

euro, Swiss franc and Japanese yen settings, as well as the one-week and two-month USD LIBOR settings. The remaining USD LIBOR settings will no 
longer be provided after June 30, 2023. The extension of certain USD LIBOR settings to June 30, 2023 applies only to legacy contracts, with new 
issuances transitioning from LIBOR and other IBORs to alternative reference rates by December 31, 2021. This announcement followed the completion 
of the ICE Benchmark Administration consultation regarding the process and timing for the orderly wind-down of LIBOR for legacy contracts. The ITO 
has adjusted the project plan accordingly to align with these extended timelines, and continues to monitor changes and updates from regulators and 
industry working groups in order to facilitate a smooth and timely transition for BMO and its clients. 

M
D
&
A

Technology Resiliency 
We continue to innovate and invest in enhancing our technological capabilities in order to keep customers’ data secure and to meet and exceed their 
expectations, as the adoption of digital banking continues to grow. In addition to existing technology risks, the COVID-19 pandemic has introduced 
new challenges, as our customers, employees and suppliers have come to rely on technology platforms and the Internet of Things to manage and 
support their personal, business and investment banking activities. Given the extent to which BMO’s operations rely on technology, it is important to 
maintain platforms that provide high levels of operational reliability and resiliency, particularly with respect to business-critical systems. Technology 
innovations, such as advanced data management, analytical tools and artificial intelligence, are being leveraged to provide insights that will improve 
the way we do business and serve our customers. 

Geopolitical Risk and Escalating Trade Disputes 
Geopolitical risk remains elevated as a result of strained relations among many countries, including the United States and China and Iran. Heightened 
geopolitical risk can give rise to shifts in global capital flows, which may lead to market disruptions and lower levels of investment, trade and global 
economic growth. Our core banking portfolio has limited direct exposure outside North America; however, our core customers depend on sustained 
economic growth and trade. To mitigate exposure to geopolitical risk, we maintain a diversified portfolio that is continually monitored and tested, in 
addition to contingency plans that we may establish to address any possible adverse developments. 

Rising protectionism and anti-globalization sentiment in the United States and other countries have compounded supply-chain disruptions, 
and may hinder global growth. In particular, despite the Phase One trade agreement between the United States and China reached in early 2020, 
trade tensions between the two countries have remained elevated, which could adversely affect business investment and could prove especially 
problematic for commodity-producing countries such as Canada. Trade disputes have also arisen between Canada and China over the past several 
years. Within North America, the Canada-United States-Mexico Agreement (CUSMA) has reduced, but not eliminated, uncertainty about continental 
trading arrangements and disputes between those nations. 

Although it is difficult to predict and mitigate the potential economic and financial effects of trade-related events on the Canadian and U.S. economies, 

we actively monitor global and North American trends and continually assess our businesses in the context of these trends. We stress test our portfolios, 
business plans and capital adequacy against severely adverse scenarios arising from trade-related shocks, and we establish contingency plans and 
mitigation strategies to address and offset the consequences of possible adverse political and economic developments. 

BMO’s credit exposure by geographic region is set out in Tables 7, 8 and 11 to 13 in the Supplemental Information and in Note 4 of the 

consolidated financial statements. 

Climate Change and Other Environmental and Social Risks 
BMO faces risks related to environmental events and extreme weather conditions that could potentially disrupt our operations, impact customers and 
counterparties, and result in lower earnings and higher losses. Factors contributing to heightened environmental risks include the impacts of climate 
change and the continued intensification of development in areas of greater environmental sensitivity. Business continuity management plans 
provide us with the capability to restore, maintain and manage critical operations and processes in the event of a business disruption. 

BMO also faces risks related to borrowers that experience losses or increases in their operating costs as a result of climate-related litigation or 
policies, such as carbon emissions pricing, or that experience lower revenue as new and emerging technologies disrupt or displace demand for certain 
commodities, products and services. We are playing an active role in helping our clients transition to a net zero world, in part through our new BMO 
Climate Institute and our dedicated Energy Transition Group. 

BMO supports the recommendations of the Financial Stability Board’s Task Force on Climate-related Financial Disclosures (TCFD), and employs the 

TCFD framework to enhance its understanding and disclosure of the evolving impact of risks associated with climate change, together with possible 
mitigation strategies. In October 2021, we joined the Net-Zero Banking Alliance, an industry-led global initiative to support and accelerate concerted 
efforts to address climate change, facilitating collaborative approaches between the public and private sectors. We continue to build our internal 
capacity to conduct climate change scenario analysis in line with the TCFD recommendations, and we are expanding this program to evaluate both 
physical and transition risks across a selection of climate-sensitive portfolios. These efforts will help identify potential material financial risks and will 
inform our business strategy in relation to climate change going forward. 

Material presented in a blue-tinted font above is an integral part of Note 5 to the 2021 audited annual consolidated financial statements. 

BMO Financial Group 204th Annual Report 2021  75 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
A
&
D
M

MANAGEMENT’S DISCUSSION AND ANALYSIS 

Legal and regulatory, business or reputation risks could arise from actual or perceived actions, or inaction, in our operations and those of our 

customers in relation to climate change and other environmental and social risk issues, or our disclosures related to these matters. Risks related to 
these issues could also affect our customers, suppliers or other stakeholders, which could heighten business or reputation risks. Globally, climate-
related litigation or enforcement measures could arise from new and more detailed obligations to manage and report climate-related risks. 

Refer to the Environmental and Social Risk section for further discussion of these risks. 

Canadian Housing Market and Consumer Leverage 
Risks related to household debt and housing affordability have increased with a sharp rise in home prices as the housing market rebounded strongly 
in early 2021, following a decline in activity in the initial phase of the COVID-19 pandemic. The lower interest rate environment should underpin the 
continuing strong demand in housing markets. However, several factors, such as higher unemployment rates and limited affordability, could 
potentially weigh on sales activity and home prices in the future. The housing market is also at risk of a correction if prices continue to rise faster than 
incomes, especially when interest rates begin to move upward. In addition, the pandemic has the potential to drive permanent changes in consumer 
behaviours and preferences, as well as changes in how and where work is performed, including more widespread adoption of remote working 
arrangements. Such changes have the potential to cause structural shifts in the demand for housing based on geographic and other characteristics, 
and could affect the viability of income-generating investment properties. These changes could dampen sales activity, home prices and property 
values within the existing portfolio. 

Household debt levels are at record highs, which could impede new borrowing and increase our exposure to risk across personal lending 
products. In addition, housing affordability continues to be a challenge, especially in the Greater Toronto Area (GTA) and Greater Vancouver Area 
(GVA) and their surrounding regions, which represents an ongoing barrier to entry for potential first-time home buyers. Moderately higher levels of 
unemployment will also weigh on household incomes, especially if current government support programs are wound down or eliminated, which 
would reduce overall household purchasing power. The heightened level of economic uncertainty could also cause households to continue to focus 
on building savings. 

Potential reductions in home sales activity, particularly in the GTA and GVA, would impact mortgage origination volumes and, if property values 
were to decline, reduce the value of collateral backing loans, which could result in higher provisions for credit losses. It is not possible to accurately 
predict the full impact of recent economic and policy changes or any potential future changes, but BMO’s prudent lending practices, which include the 
application of additional underwriting scrutiny on higher-value and higher loan-to-value transactions and the setting and close monitoring of regional, 
property type and customer segment concentration limits, support the soundness of the bank’s Canadian real estate lending portfolio. Further, stress 
test analysis suggests that even significant price declines and extremely challenging economic conditions would result in manageable losses, mainly 
due to insurance coverage and the significant level of equity built up in seasoned loans. 

Inflation 
As the economic recovery from the COVID-19 pandemic continues, inflation rates have seen significant increases in North America, rising above the 
target ranges for the Bank of Canada and the Federal Reserve during 2021. A significant portion of the upward pressure on prices is attributable to the 
rising costs of energy, food, motor vehicles and housing, as well as the challenges involved in reopening the economy and persistent supply-chain 
disruptions. Inflation increases are expected to be largely transitory, assuming supply-chain disruptions ease and commodity prices moderate. 
However, a sustained upward trajectory in the inflation rate would have an impact on BMO’s operations and our clients, and could impact our 
earnings due to higher provisions for credit losses and higher operating costs. We continue to monitor inflationary pressures in North America and 
assess any potential effects on our portfolios, interest margins and operating costs. 

Other Factors That May Affect Future Results 

Fiscal and Monetary Policies and Other Economic Conditions in the Countries in which BMO Conducts Business 
BMO’s earnings are affected by the fiscal and monetary policies and other economic conditions prevailing in Canada, the United States and other 
jurisdictions in which we do business. These policies and conditions may have the effect of reducing profitability and increasing uncertainty in specific 
businesses and markets, which may affect customers and counterparties, and potentially contribute to a greater risk of default. Changes in fiscal and 
monetary policies are difficult to anticipate. Higher levels of government and business debt resulting from the pandemic have the potential to create 
future vulnerabilities that could impact our markets and our business. Fluctuations in interest rates could have an impact on our earnings, the value of 
our investments, the credit quality of our loans to customers and counterparty exposure, and the capital markets that we access. 

Changes in the value of the Canadian dollar relative to the U.S. dollar have affected, and could in the future continue to affect, the results of 

clients with significant foreign earnings or input costs. Our investments in foreign operations are primarily denominated in U.S. dollars, and the 
foreign exchange impact of U.S.-dollar-denominated risk-weighted assets and capital deductions may result in variability in our capital ratios. 
Refer to the Enterprise-Wide Capital Management section. The value of the Canadian dollar relative to the U.S. dollar will also affect the contribution 
of U.S. operations to Canadian-dollar profitability. 

Hedging positions may be taken to manage interest rate exposures and partially offset the effects of Canadian dollar/U.S. dollar exchange rate 

fluctuations on the bank’s financial results. Refer to the Foreign Exchange section and the Market Risk section for a more complete discussion of 
foreign exchange and interest rate risk exposures. 

Regulatory Requirements 
The financial services industry is highly regulated, and BMO has experienced changes and increasing complexity in regulatory requirements, as 
governments and regulators around the world continue to pursue major reforms intended to strengthen the stability of the financial system and 
protect key markets and participants. As a result, there is the potential for higher capital requirements and additional regulatory compliance costs, 
which could lower returns and affect growth. These reforms could also affect the cost and availability of funding and the extent of the bank’s market-
making activities. Regulatory reforms may also impact fees and other revenues for certain operating groups. In addition, differences in laws and 
regulations enacted by various national regulatory authorities may provide advantages to international competitors that could affect our ability to 
compete, and lead to loss of market share. We monitor such developments, and other potential changes, so that we are well-positioned to respond 
and implement any necessary changes. 

76  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Failure to comply with applicable legal and regulatory requirements could result in legal proceedings, financial losses, regulatory sanctions, 
enforcement actions, an inability to execute business strategies, a decline in investor and customer confidence, and damage to our reputation. 
Refer to the Legal and Regulatory Risk section for a more complete discussion of BMO’s management of legal and regulatory risk. 

Tax Legislation and Interpretations 
Legislative changes and changes in tax policy, including their interpretation by tax authorities and the courts, may impact earnings. Tax laws, as well 
as interpretations of tax laws and policy by tax authorities, may change as a result of efforts by the Canadian federal government, other G20 
governments, and the Organisation for Economic Co-operation and Development to increase taxes, broaden the tax base globally and improve 
tax-related reporting. Refer to the Critical Accounting Estimates section for further discussion of income taxes and deferred taxes. 

Changes to Business Portfolio 
BMO may, from time to time, acquire companies, businesses and assets as part of its overall business strategy. We conduct thorough due diligence 
before completing such acquisitions. However, some acquisitions may not perform in line with our financial or strategic objectives or expectations. 
Our ability to successfully complete an acquisition may be subject to regulatory and shareholder approvals, and it may not be possible to determine 
when, if or on what terms the necessary approvals will be granted. Changes in the competitive and economic environment, as well as other factors, 
may result in reductions in revenue or profitability, while higher than anticipated integration costs and failure to realize expected cost savings after 
an acquisition could also adversely affect earnings. Integration costs may increase as a result of regulatory costs related to an acquisition, other 
unanticipated costs that were not identified in the due diligence process, or demands on management time that are more significant than 
anticipated, as well as unexpected delays in implementing certain plans that in turn lead to delays in achieving full integration. Successful post-
acquisition performance depends on retaining the clients and key employees of acquired companies and businesses and on integrating key systems 
and processes without disruption, and there can be no assurance that we will always succeed in doing so. 

BMO also evaluates potential dispositions of assets and businesses that may no longer meet strategic objectives. When we sell assets or 
withdraw from a business, we may encounter difficulty in finding buyers or alternative exit strategies on acceptable terms or in a timely manner, 
which could delay the achievement of strategic objectives. We may also dispose of assets or a business on terms that are less desirable than 
anticipated or result in adverse operational or financial impacts, or greater disruption than expected, and the impact of the divestiture on revenue 
growth may be larger than projected. Dispositions may be subject to the satisfaction of conditions and the granting of governmental or regulatory 
approvals on acceptable terms, which, if not satisfied or obtained, may prevent the completion of a disposition as intended, or at all. 

Critical Accounting Estimates and Accounting Standards 
BMO prepares its consolidated financial statements in accordance with IFRS. Changes that the International Accounting Standards Board makes from 
time to time may materially affect the way we record and report financial results. Significant accounting policies and future changes in accounting 
policies are discussed in the Changes in Accounting Policies in 2021 and Future Changes in Accounting Policies sections, as well as in Note 1 of the 
consolidated financial statements. 

The application of IFRS requires management to make significant judgments and estimates that affect the carrying amounts of certain assets 
and liabilities, certain amounts reported in net income, and other related disclosures. In making these judgments and estimates, we rely on the best 
information available at the time. However, it is possible that circumstances may change, new information may become available or models may 
prove to be imprecise. 

BMO’s financial results could be affected for the period during which any such new information or change in circumstances becomes apparent, 

and the extent of the impact could be significant. More information is included in the Critical Accounting Estimates section. 

Caution 
The Risks That May Affect Future Results section and the remainder of this Enterprise-Wide Risk Management section contain forward-looking statements. Please refer to the Caution Regarding Forward-
Looking Statements. Other factors beyond BMO’s control that may affect its future results are noted in the Caution Regarding Forward-Looking Statements. BMO cautions that the preceding discussion of risks 
that may affect future results is not exhaustive. 

M
D
&
A

BMO Financial Group 204th Annual Report 2021  77 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Risk Management Overview 
BMO’s integrated and disciplined approach to risk management is fundamental to the success of our business. Our Enterprise Risk and Portfolio 
Management (ERPM) group oversees the implementation and operation of the Enterprise-Wide Risk Management Framework (ERMF), and provides 
independent review and oversight across the enterprise on risk-related issues, in order to achieve prudent and measured risk-taking that is integrated 
with business strategy. All elements of the ERMF function together to support informed and effective risk management, while striking an appropriate 
balance between risk and return. 

Enterprise-Wide Risk Management Framework 
The ERMF guides risk-taking activities in order to align them with customer needs, shareholder expectations and regulatory requirements. The ERMF 
also sets out our approach to risk management: maintain strong capital and liquidity, diversify and limit tail risk, optimize risk return, understand 
and manage the risks we face, and protect our reputation. Our approach to risk governance is outlined in the ERMF, which incorporates our Risk 
Management Life Cycle, guiding our efforts to identify, assess, manage, monitor and report on our material risks. The ERMF is supported by our 
people, processes and technology, leveraging tools, including modelling and analytics, stress testing and scenario analysis, and our Risk Taxonomy. 
All elements of the ERMF are supported by our risk culture. The ERMF provides for the direct management of each individual risk type, as well as the 
management of risk on an integrated basis. 

A
&
D
M

Enterprise-Wide Risk Management Framework 

Risk 
Management 
Approach 

Maintain Strong 
Capital and 
Liquidity 

Risk Governance 

Diversify. Limit Tail 
Risk 

Optimize Risk 
Return 

Understand and 
Manage 

Protect our 
Reputation 

Board 
(RRC*, ACRC*) 

Senior Management 
(RMC*, ERC* & Sub-Committees) 

Risk Appetite Framework 
(Statement and Limits) 

Enterprise Policy Framework 

Three-Lines-of-Defence Operating Model 

1st Line 

2nd Line 

Operating Groups, Technology & 
Operations, Corporate Services 

Enterprise Risk & Portfolio Management, 
Legal & Regulatory Compliance 

3rd  Line 

Corporate Audit Division 

Risk 
Management 
Life Cycle 

IDENTIFY 

ASSESS

MANAGE 

MONITOR 

REPORT

Risk Management Enablement 

People 

Process 

Technology

Risk Management Tools 

(For example: Stress Testing & Scenario Analysis, 
Modelling & Analytics, Risk Taxonomy) 

Risk Culture 

Tone from the Top 

Accountability 

Effective Communication and Challenge 

Incentives

* RRC: Risk Review Committee, ACRC: Audit and Conduct Review Committee, RMC: Risk Management Committee, ERC: Enterprise Regulatory Committee 

Risk Governance 
The ERMF outlines a governance approach that includes robust Board of Directors and senior management oversight, a Risk Appetite Framework, 
the Enterprise Policy Framework and the corresponding roles in the three-lines-of-defence operating model. 

Board of Directors and Senior Management Oversight 
Specific Board-approved policies govern our approach to the management of material risks, and oversight is provided at all levels of the enterprise 
through a hierarchy of committees and individual responsibilities, as outlined in the following diagram. The Board seeks to ensure that corporate 
objectives are supported by a sound risk strategy and an effective ERMF that is appropriate to the nature, scale, complexity and risk profile of our 
operations. The Board also has overall responsibility for the bank’s governance framework and corporate culture. Senior management reviews and 
discusses significant risk issues and action plans as they arise in the implementation of the enterprise-wide strategy, providing risk oversight and 
governance of the risks taken across the enterprise and the processes through which such risks are identified, assessed, managed (and mitigated), 
monitored and reported in accordance with policies, and held within limits and risk tolerances. 

78  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The ERMF is reviewed on a regular basis by the Risk Review Committee (RRC) of the Board, in order to provide oversight and guide risk-taking

activities.

Board & Senior Management Oversight

Board of Directors

Risk Review Committee (RRC)

Audit and Conduct Review
Committee (ACRC)

Chief Executive Officer

Chief Risk Officer

Risk Management Committee (RMC)

M
D
&
A

General Counsel

Enterprise Regulatory
Committee (ERC)***

Balance Sheet
Committee*

Capital
Management
Committee*

Reputation
Risk
Management
Committee**

Operational
Risk
Management
Committee

Model Risk
Management
Committee

* The Balance Sheet Committee (BSC) and Capital Management Committee (CMC) are sub-committees of the Asset and Liability Management
Committee (ALCO). However, in matters related to Structural Market Risk, Liquidity & Funding Risk, and the Internal Capital Adequacy
Assessment Process (ICAAP), BSC and CMC report to RMC.

** Committee is chaired by the General Counsel.

*** Committee is co-chaired by the General Counsel and Chief Risk Officer.

In addition to the Board of Directors and senior management oversight, appropriate risk governance, supported by the three lines of defence, is in
place in all material businesses and entities. In each of the operating groups and in Corporate Services, which includes Technology and Operations,
management is the first line of defence, responsible for governance and controls, and the implementation and operation of risk management
processes and procedures that provide effective risk management. ERPM and Legal & Regulatory Compliance, as the second line of defence, oversee
the implementation and operation of risk management processes and procedures, and monitor and test risk outcomes against our risk appetite and
management expectations, in order to determine whether risk outcomes are consistent with return expectations. Corporate Audit Division, as the
third line of defence, provides independent assessment of the effectiveness of internal controls that support the risk management and governance
processes. Individual governance committees establish and monitor further risk limits, consistent with Board-approved limits.

BMO Financial Group 204th Annual Report 2021 79

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
A
&
D
M

MANAGEMENT’S DISCUSSION AND ANALYSIS 

Board of Directors is responsible for supervising the management of 
the business and affairs of BMO. The Board, either directly or through 
its committees, is responsible for oversight in the following areas: 
strategic planning; defining risk appetite; identifying and managing 
risk; managing capital; fostering a culture of integrity; internal 
controls; succession planning and evaluation of senior management; 
communication; public disclosure; and corporate governance. 

Risk Management Committee (RMC) is BMO management’s senior risk 
committee. RMC reviews and discusses significant risk issues and action 
plans as they arise in the implementation of the enterprise-wide 
strategy. RMC provides risk oversight and governance at the highest 
levels of management. This committee is chaired by the CRO, and its 
members include the heads of the operating groups, the CEO, the Chief 
Financial Officer (CFO) and the General Counsel. 

Risk Review Committee of the Board of Directors (RRC) assists the 
Board in fulfilling its risk management oversight responsibilities. 
This includes leading BMO’s risk culture; overseeing the identification 
and management of BMO’s risks; adherence by operating groups to 
risk management corporate policies and standards; compliance with 
risk-related regulatory requirements; and evaluating the Chief Risk 
Officer (CRO), including input into succession planning for the CRO. The 
ERMF is reviewed on a regular basis by the RRC in order to provide 
guidance for the governance of risk-taking activities. 

Audit and Conduct Review Committee of the Board of Directors 
(ACRC) assists the Board in fulfilling its oversight responsibilities for 
the integrity of BMO’s financial reporting; the effectiveness of BMO’s 
internal controls; the qualifications, independence and performance of 
the independent auditors; BMO’s compliance with laws and 
regulations; transactions involving related parties; conflicts of interest 
and confidential information; and standards of business conduct and 
ethics. 

Chief Executive Officer (CEO) is directly accountable to the Board for 
all of BMO’s risk-taking activities. The CEO is supported by the CRO and 
the ERPM group. 

Chief Risk Officer (CRO) reports directly to the CEO and is head of 
ERPM and chair of RMC. The CRO is responsible for providing 
independent review and oversight of enterprise-wide risks and 
leadership on risk issues, developing and maintaining the RMF and 
fostering a strong risk culture across the enterprise. 

RMC Sub-Committees have oversight responsibility for the risk 
implications and balance sheet impacts of management strategies, 
governance practices, risk measurement, model risk management 
and contingency planning. RMC and its sub-committees provide 
oversight of the risks taken across the enterprise and the processes 
through which such risks are identified, assessed, managed, monitored, 
mitigated and reported in accordance with policies, and held within 
limits and risk tolerances. 

Enterprise Risk and Portfolio Management (ERPM), as the risk 
management second line of defence, provides risk management 
oversight, effective challenge and independent assessment of risk 
and risk-taking activities. ERPM supports a disciplined approach to 
risk-taking by fulfilling its responsibilities for independent transactional 
approval and portfolio management, policy formulation, risk reporting, 
stress testing, modelling and risk education. This approach promotes 
consistency in risk management practices and standards across the 
enterprise, and verifies that any accepted risks are consistent with 
BMO’s risk appetite. 

Operating Groups and Corporate Services, including Technology and 
Operations, are responsible for effectively managing risks by 
identifying, assessing, managing, monitoring, mitigating and reporting 
on risk within their respective operations and lines of business in 
accordance with their established risk appetite. They exercise business 
judgment and maintain effective policies, processes and internal 
controls, so that significant risk issues are escalated and reviewed by 
ERPM. Individual governance committees and ERPM establish and 
monitor risk limits that are consistent with, and subordinate to, the 
Board-approved limits. 

Risk Appetite Framework 
BMO’s Risk Appetite Framework consists of its Risk Appetite Statement and the delineation of roles and responsibilities of senior management and 
the Board of Directors, and is supported by corporate policies, standards and guidelines, including related risk limits, concentration levels and controls 
defined therein. Risk appetite defines the amount of risk that the bank is willing to assume given its guiding principles, thereby supporting the pursuit 
of sound business initiatives, appropriate returns and targeted growth. Risk appetite is integrated with strategic and capital planning and performance 
management. The Risk Appetite Statement consists of both qualitative and quantitative specifications of our appetite for material risks. Key risk 
metrics are outlined for material risks, which include specific thresholds that allow senior management and the Board of Directors to monitor the 
current risk profile relative to risk appetite. On an annual basis, the RMC submits the Risk Appetite Statement and key risk metrics to the RRC, which 
in turn reviews and recommends them to the Board of Directors for approval. The Risk Appetite Statement is articulated and applied consistently 
across the enterprise, with operating groups and key businesses and entities developing their own respective risk appetite statements within this 
framework. 

We believe that risk management is every employee’s responsibility. This is guided by five key principles that drive our approach to managing 

risk across the enterprise and comprise our Risk Appetite Statement. 

•  Understand and Manage by only taking risks that are transparent and understood. 
•  Protect BMO’s Reputation by adhering to principles of honesty, integrity, respect and high ethical standards in line with our Code of Conduct. 
•  Diversify. Limit Tail Risk by targeting a business mix that minimizes earnings volatility and exposure to low-probability, high-impact events. 
•  Maintain Strong Capital and Liquidity that meet, or exceed, regulatory requirements and market expectations. 
•  Optimize Risk Return by managing risk-adjusted exposures and making decisions that create value for shareholders. 

80  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk Limits 
Risk limits are set so that risk-taking activities remain within BMO’s risk appetite, and balance risk diversification, exposure to loss and risk-adjusted 
returns. These limits inform business strategies and decisions, and are reviewed and approved by the Board of Directors or management committees, 
as appropriate, based on the level and granularity of the limits. They include: 
• Credit and Counterparty Risk – limits on group and single-name exposures and material country, industry and portfolio/product segments. 
• Market Risk – limits on economic value and earnings exposures to stress scenarios and significant market movements, as well as limits on value 

at risk and stress related to trading and underwriting activities. 
Insurance Risk – limits on policy exposures and reinsurance arrangements. 

•
• Liquidity and Funding Risk – minimum limits governing the internal liquidity stress testing scenario, minimum regulatory liquidity ratio 

requirements, and maximum levels of asset pledging and wholesale funding, as well as limits related to liability diversification and credit and 
liquidity facility exposures. 

• Operational Risk – key metrics for measuring operational and other non-financial risks. 

The Board of Directors, after considering recommendations from the RRC and the RMC, annually reviews and approves key risk limits and then 
delegates overall authority for these limits to the CEO. The CEO in turn delegates more specific authorities to the senior executives of the operating 
groups (first line of defence), who are responsible for the management of risk in their respective operations, and to the CRO. These delegated 
authorities allow risk officers to set risk tolerances, approve geographic and industry sector exposure limits within defined parameters, and establish 
underwriting and inventory limits for trading and investment banking activities. The criteria under which more specific authorities may be delegated 
across the organization, as well as the requirements relating to the documentation, communication and monitoring of those specific delegated 
authorities, are set out in corporate policies and standards. 

M
D
&
A

Enterprise Policy Framework 
The Enterprise Policy Framework includes a comprehensive set of corporate policies, each of which is approved by the RRC, as well as corporate 
standards issued pursuant to those corporate policies that have been reviewed by the RMC and approved by senior management. Corporate policies 
and standards collectively outline the principles, expectations, and roles and responsibilities of senior management for ensuring that key risks are 
identified, assessed, managed (including mitigation), monitored and reported. Corporate policies and standards are reviewed and updated at a 
minimum every two years. 

The Enterprise Policy Framework also includes supporting directives and procedures that apply across the first and second lines of defence to 

operationalize the requirements, roles and responsibilities, and activities outlined in those corporate policies and standards. 

Three-Lines-of-Defence Operating Model 
Our ERMF is operationalized through the three-lines-of-defence approach to managing risk, as described below: 
• Operating groups and Corporate Services, which includes Technology and Operations, are our first line of defence. They are accountable for the 
risks arising from their businesses, operations and exposures. They are expected to pursue business opportunities within their established risk 
appetite and to identify, assess, manage (including mitigation), monitor and report on all risks in, or arising from, their businesses, operations 
and exposures. The first line discharges its responsibilities by applying risk management and reporting methodologies, and is responsible for 
establishing appropriate internal controls in accordance with the ERMF and for monitoring the effectiveness of such controls. These processes and 
controls help ensure businesses act within their delegated risk-taking authority and risk limits, as set out in corporate policies and the Risk Appetite 
Framework. Corporate Services, which includes Technology and Operations, while part of our first line of defence, may also operate in a governance 
capacity when specific roles and responsibilities are assigned to individuals or groups under the Enterprise Policy Framework. 

• The second line of defence comprises ERPM and Legal & Regulatory Compliance. The second line provides independent oversight, effective 

challenge and independent assessment of risks and risk management practices, including transaction, product and portfolio risk management 
decisions, processes and controls in the first line of defence. The second line establishes enterprise-wide risk management policies, infrastructure, 
processes, methodologies and practices that the first and second lines use to identify, assess, manage (including mitigation), monitor and report 
risks across the enterprise. 

• Corporate Audit Division is the third line of defence. It provides an independent assessment of the effectiveness of internal controls across the 

enterprise, including controls that support the risk management and governance processes. 

Risk Taxonomy 
A Risk Taxonomy is maintained to document the key risks to which BMO is exposed. As a key risk management tool, the Risk Taxonomy reflects our 
Tier 1 risks, as set out in the diagram below, and provides foundational support across the risk management life cycle in relation to each of these key 
risks. Our Risk Taxonomy incorporates exposures to financial risks (Credit and Counterparty Risk, Market Risk, Insurance Risk and Liquidity and Funding 
Risk), non-financial risks (Operational Risk and Legal and Regulatory Risk) and transverse risks, which intersect with both financial and non-financial 
risks (Strategic Risk, Environmental and Social Risk and Reputation Risk). We maintain sub-categories under each Tier 1 risk in order to support 
effective risk management practices as part of the overall ERMF. 

Financial Risk 

Non-Financial Risk 

Transverse Risk 

Credit and 
Counterparty 
Risk 

Market 
Risk 

Insurance 
Risk 

Liquidity and 
Funding Risk 

Operational 
Risk 

Legal and 
Regulatory Risk 

Strategic 
Risk 

Environmental 
and Social Risk 

Reputation 
Risk 

BMO Financial Group 204th Annual Report 2021  81 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Risk Management Life Cycle 

Risk Identification, Assessment and Management 
Risk identification is an integral step in recognizing the key inherent risks that BMO faces, assessing the potential for loss and then acting to mitigate 
this potential. Our Risk Taxonomy identifies key risks, supporting the implementation of our Risk Appetite Framework and assisting in identifying the 
primary risk categories for which stress capital consumption is estimated. Risk review and approval processes are established based on the nature, 
size and complexity of the risks involved. Generally, these involve a formal review and approval by either an individual or a committee that is 
independent of the originator. Delegated authorities and approvals by category are outlined below. 
•  Portfolio transactions – transactions are approved through risk assessment processes for all types of transactions at all levels of the enterprise, 

which include operating group recommendations and ERPM approval of credit risk, and transactional and position limits for market risk. 
•  Structured transactions – new structured products and transactions with significant legal and regulatory, accounting or tax implications are 

reviewed by the Global Markets Risk Committee, as appropriate, and are also reviewed through the operational risk management process if they 
involve structural or operational complexity that may give rise to significant operational risk. Transactions that may give rise to reputation risk are 
reviewed by the Reputation Risk Management Committee. 

•  Investment initiatives – documentation of risk assessments is formalized through the investment spending approval process, and is reviewed and 

approved by Corporate Services based on the initiative’s investment spend and inherent risk. 

•  New products and services – procedures for the approval of new or modified products and services offered to customers are the responsibility of 

the first line of defence, including appropriate senior business leaders, and are reviewed and approved by subject matter experts and senior 
managers in Corporate Services, as well as by other senior management committees. 

A
&
D
M

Risk Monitoring and Reporting 

Risk-Based Capital Assessment 
Two measures of risk-based capital are used by BMO: economic capital and advanced-approach regulatory capital. Both are aggregate measures of 
the risk that the bank assumes in pursuit of its financial objectives, and they enable the evaluation of returns on a risk-adjusted basis. Our operating 
model provides for the direct management of each type of risk, as well as the management of all material risks on an integrated basis. Measuring the 
economic profitability of transactions or portfolios involves a combination of both expected and unexpected losses to assess the extent and 
correlation of risk before authorizing new exposures. Both expected and unexpected loss measures for a transaction or a portfolio reflect current 
market conditions, the inherent risk in the position and, as appropriate, its credit quality. Risk-based capital methods and material models are 
reviewed at least annually and updated as appropriate. The risk-based capital models provide a forward-looking estimate of the difference between 
the maximum potential loss in economic (or market) value and expected loss, measured over a specified time interval and using a defined confidence 
level. 

Stress Testing 
Stress testing is a key element of the risk and capital management frameworks. It is integrated into our enterprise and group risk appetite statements 
and embedded in our management processes. To evaluate risks, we regularly test a range of scenarios, which vary in frequency, severity and 
complexity, in portfolios and businesses across the enterprise. In addition, we participate in regulatory stress tests in multiple jurisdictions. 
Governance of the stress testing framework resides with senior management, including the Enterprise Stress Testing Committee. This committee 
comprises business, risk and finance executives, and is accountable for reviewing and challenging enterprise-wide scenarios and stress test results. 
Stress testing and enterprise-wide scenarios associated with the Internal Capital Adequacy Assessment Process (ICAAP), including recommendations 
for actions that the enterprise could take in order to manage the impact of a stress event, are established by senior management and presented to 
the Board of Directors. Stress testing associated with the Horizontal Capital Review (HCR), which is a U.S. regulatory requirement for BMO Financial 
Corp. (BFC), is similarly governed at the BFC level. 

Quantitative models and tools, along with qualitative approaches, are utilized to assess the impact of changes in the macroeconomic 

environment on the income statement and balance sheet and the resilience of the bank’s capital over a forecast horizon. Models utilized for stress 
testing are approved and governed under the Model Risk Management Framework, and are used to establish a better understanding of our risks and 
to test our capital adequacy. 

Enterprise Stress Testing 
Enterprise stress testing supports BMO’s ICAAP and target-setting through analysis of the potential effects of low-frequency, high-severity events on 
earnings, the balance sheet, and liquidity and capital positions. Scenario selection is a multi-step process that considers material and idiosyncratic 
risks and the potential impact of new or emerging trends on risk profiles, as well as the macroeconomic environment. Scenarios may be defined by 
senior management or regulators. The economic impacts are determined by the Economics group, which translates the scenarios into macroeconomic 
and market variables that include, but are not limited to, GDP growth, yield curve estimates, unemployment rates, real estate prices, stock index 
growth and changes in corporate profits. These macroeconomic variables drive stress loss models, tools and qualitative assessments that are applied 
to determine estimated stress impacts. The scenarios are used by operating, risk and finance groups to assess a broad range of financial impacts that 
could arise under a specific stress, as well as the ordinary course and extraordinary actions that would be anticipated in response to that stress. 

Stress test results, including mitigating actions, are benchmarked and challenged by relevant business units and senior management, including 

the Enterprise Stress Testing Committee. 

Targeted Portfolio and Ad Hoc Stress Testing 
BMO’s stress testing framework integrates stress testing at the line of business, portfolio, industry, geographic and product level, and embeds it in 
strategy, business planning and decision-making. Targeted portfolio, industry and geographic analysis is conducted by ERPM and the lines of business 
to test risk appetite, limits, concentration and strategy. Ad hoc stress testing is conducted in response to changing economic or market conditions and 
in order to assess business strategies. 

82  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Climate-Related Scenario Analysis 
We have established a climate-related scenario analysis program to explore climate-specific vulnerabilities in order to enhance our resilience 
to climate-related risks, in line with the Financial Stability Board’s Task Force on Climate-related Financial Disclosures (TCFD) recommendations. 
The climate-related scenario analysis program leverages existing risk capabilities in combination with climate-specific expertise. Evolving industry 
practices are examined and used to inform this work, with the goal of strengthening our ability to evaluate climate-related risks. In the past year, 
we have applied scenario analysis to certain sectors in our portfolios to determine the potential impacts of physical and transition risks. BMO is also 
participating in Phase III of the United Nations Environment Programme Finance Initiative (UNEP-FI) to evaluate and test climate scenario analysis 
methodologies. 

Risk Culture 
The Enterprise Culture and Conduct Framework sets out BMO’s approach to managing and mitigating potential misconduct. Misconduct is behaviour 
that falls short of legal, professional, internal conduct and ethical standards. Similar to BMO’s approach to other non-financial risks, this framework is 
supported by the ERMF and our focus on maintaining a strong risk culture. BMO reports on various metrics related to culture and conduct, and 
engages with other control frameworks across the enterprise and in all of the jurisdictions in which it operates. 

Risk culture is the set of shared norms, attitudes and behaviours related to risk awareness, risk-taking and risk management at BMO. Sound risk 
culture consistently supports appropriate behaviours and judgments about risk-taking and promotes effective risk management and alignment of risk-
taking activities with BMO’s Risk Appetite. Our risk culture informs and supports our overall culture. We have a long-standing commitment to high 
ethical standards, grounded in values of integrity, empathy, diversity and responsibility. Our Purpose – to Boldly Grow the Good in business and life – 
is underpinned by our values. The Purpose defines BMO as an organization and is the foundation of our position and our operations. ERPM is 
responsible for the development and promotion of a healthy, strong risk culture across the enterprise. In pursuing this mandate, ERPM works 
closely with Legal & Regulatory Compliance and its Ethics & Conduct Office, as well as People & Culture. BMO’s risk culture is founded on four guiding 
principles that together reinforce its effectiveness across the bank: Tone from the Top, Accountability, Effective Communication and Challenge, and 
Incentives: 
•  Tone from the Top: Our risk culture is grounded in an approach to risk management that encourages openness, constructive challenge and 

personal accountability. Each member of senior management plays a critical role in fostering this strong risk culture among all employees, by 
effectively communicating this responsibility and by the example of their own actions. The Board of Directors oversees BMO’s corporate objectives, 
and seeks to ensure they are supported by a sound risk strategy and an effective ERMF that is appropriate to the nature, scale, complexity and risk 
profile of our operations. 

•  Accountability: BMO’s ERMF is anchored in the three-lines-of-defence approach to managing risk. Our risk culture also encourages the escalation 

of concerns associated with potential or emerging risks to senior management, so that they can be evaluated and appropriately addressed. 
BMO encourages and supports an environment in which concerns can be raised without retaliation. 

•  Effective Communication and Challenge: Timely and transparent sharing of information is integral to engaging stakeholders in key decisions 

and strategy discussions, bringing added rigour and discipline to BMO’s decision-making. This not only leads to the timely identification, escalation 
and resolution of issues, but also encourages open communication, independent challenge and an understanding of the key risks faced by the 
organization, so that employees are equipped and empowered to make decisions and take action in a coordinated and consistent manner, 
supported by a strong monitoring and control framework. 

•  Incentives: Compensation and other incentives are aligned with prudent risk-taking. These are designed to reward the appropriate use of capital 
and respect for the rules and principles of the ERMF, and do not encourage excessive risk-taking. Risk managers have input into the design of 
incentive programs that may have an effect on risk-taking. We also maintain training programs that are designed to foster a deep understanding 
of BMO’s capital and risk management frameworks across the enterprise, providing employees and management with the tools and insights they 
need to fulfill their responsibilities for independent oversight, regardless of their role in the organization. 

M
D
&
A

BMO Financial Group 204th Annual Report 2021  83 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
A
&
D
M

MANAGEMENT’S DISCUSSION AND ANALYSIS 

Credit and Counterparty Risk 

Credit and counterparty risk is the potential for credit loss due to the failure of an obligor (i.e., a borrower, endorser, guarantor or counterparty) 
to repay a loan or honour another predetermined financial obligation. 

Credit and counterparty risk underlies every lending activity that we enter into, and also arises in the holding of investment securities, transactions 
related to trading and other capital markets products, and activities related to securitization. Credit risk and counterparty risk comprise the most 
significant measurable risk we face. Proper management of credit risk is integral to our success, since failure to effectively manage credit risk could 
have an immediate and significant impact on earnings, financial condition and reputation. 

Credit and Counterparty Risk Governance 
The objective of the Credit Risk Management Framework is to ensure that all material credit risks to which the enterprise is exposed are identified, 
measured, managed, monitored and reported. The Risk Review Committee (RRC) has oversight of the management of all material risks that we face 
at BMO, including the Credit Risk Management Framework. The Credit Risk Management Framework incorporates governing principles that are 
defined in a series of corporate policies and standards and are applied to specific operating procedures. These policies and standards are reviewed on 
a regular basis and modified as necessary to keep them current and consistent with our risk appetite. The structure, limits (both notional and capital-
based), collateral requirements, monitoring, reporting and ongoing management of credit exposures are all governed by these credit risk 
management principles. 

Lending officers in the operating groups are responsible for recommending credit decisions based on the completion of appropriate due 
diligence, and they assume accountability for the related risks. In some instances, relatively small transactions may be assessed by automated 
decision-making, or they may be approved by first-line underwriters with appropriate training, independence and oversight. Credit officers in 
Enterprise Risk Portfolio Management (ERPM) approve larger or higher risk credit transactions and are accountable for providing an objective 
independent assessment of the lending recommendations and risks assumed by the lending officers. All of these individuals in the first and second 
lines of defence are subject to a lending qualification process and operate in a disciplined environment with clear delegation of decision-making 
authority, including individually delegated lending limits where appropriate, which are reviewed annually or more frequently, as needed. The Board 
of Directors annually delegates to the CEO discretionary lending limits for further specific delegation to senior officers. Credit decision-makin g is  
conducted at the management level appropriate to the size and risk of each transaction, in accordance with an extensive range of corporate policies, 
standards and procedures governing the conduct of activities in which credit risk arises. Corporate Audit Division reviews and tests management 
processes and controls and samples credit transactions in order to assess adherence to acceptable lending standards as set out in BMO’s Risk Appetite 
Statement, as well as compliance with all applicable governing policies, standards and procedures. 

For corporate and commercial obligors presenting a higher than normal risk of default, we have in place formal policies that outline the 
framework for managing such accounts and the specialized groups that manage them. We strive to identify borrowers in financial difficulty early, 
and every effort is made to bring such accounts back to an acceptable level of risk through the exercise of good business judgment and the 
implementation of sound and constructive workout solutions. Obligors are managed on a case-by-case basis, which involves the application of 
judgment by the specialized groups. 

All credit risk exposures are subject to regular monitoring. Performing corporate and commercial accounts are reviewed on a regular basis, no 

less frequently than annually, with most subject to internal monitoring triggers that, if breached, result in an interim review. 

The frequency of review increases in accordance with the likelihood and size of potential credit losses, and deteriorating higher-risk situations 

are referred to specialized account management groups for closer attention, as appropriate. In addition, regular portfolio and sector reviews are 
carried out, including stress testing and scenario analysis based on current, emerging or prospective risks, such as the COVID-19 pandemic. Reporting 
is provided at least quarterly, and more frequently where appropriate, to RRC and senior management committees in order to keep them informed of 
credit risk developments in our credit and investment portfolios, including changes in credit risk concentrations, watchlist accounts, impaired loans, 
provisions for credit losses, negative credit migration and significant emerging credit risk issues. This supports RRC and senior management 
committees in any related decisions they may make. 

Counterparty credit risk (CCR) involves a bilateral risk of loss because the market value of a transaction can be positive or negative for either 
counterparty. CCR exposures are subject to the credit oversight, limit framework and approval process outlined above. However, given the nature of 
the risk, CCR exposures are monitored under the market risk framework. In order to reduce our exposure to CCR, exposures are often collateralized, 
and trades may be cleared through a regulated central counterparty (CCP), which reduces overall systemic risk by standing between counterparties, 
maximizing netting across trades and insulating counterparties from each other’s defaults. CCPs mitigate default risk of any member through the use 
of margin requirements (both initial and variation) and a default management process, including a default fund and other provisions. Our exposures 
to CCPs are subject to the same credit risk governance, monitoring and rating framework we apply to all other corporate accounts. 

Credit and Counterparty Risk Management 

Collateral Management 
Collateral is used for credit risk mitigation purposes to minimize losses that would otherwise be incurred in the event of a default. Depending on 
the type of borrower or counterparty, the assets available and the structure and term of the credit obligations, collateral can take various forms. 
For corporate and commercial borrowers, collateral can take the form of pledges of the assets of a business, such as accounts receivable, inventory, 
machinery or real estate, or personal assets pledged in support of guarantees. For trading counterparties, BMO may enter into legally enforceable 
netting agreements for on-balance sheet credit exposures, when possible. In the securities financing transaction business (including repurchase 
agreements and securities lending), we take eligible financial collateral that we control and can readily liquidate. 

Collateral for BMO’s derivatives trading counterparty exposures primarily comprises cash and eligible liquid securities that are monitored 

and revalued on a daily basis. Collateral is obtained under the contractual terms of standardized industry documentation. 

With limited exceptions, we utilize the International Swaps and Derivatives Association Inc. Master Agreement, frequently with a Credit Support 
Annex, to document our collateralized trading relationships with counterparties for over-the-counter (OTC) derivatives that are not centrally cleared. 

Material presented in a blue-tinted font above is an integral part of Note 5 to the 2021 audited annual consolidated financial statements. 

84  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
M
D
&
A

Credit Support Annexes entitle a party to demand a transfer of collateral (or other credit support) when its OTC derivatives exposure to the other 

party exceeds an agreed threshold. Collateral to be transferred can include variation margin or initial and variation margin. Credit Support Annexes 
contain, among other measures, provisions setting out acceptable types of collateral and a method for their valuation (discounts are often applied to 
the market values), as well as thresholds, whether or not the collateral can be re-pledged by the recipient and how interest is to be calculated. 

Many G20 jurisdictions continue to implement new regulations that require certain counterparties with significant exposures to OTC derivatives 
to post or collect prescribed types and amounts of collateral for uncleared OTC derivatives transactions. For additional discussion, refer to Derivatives 
Reform. 

To document our contractual securities financing relationships with counterparties, we utilize master repurchase agreements for repurchase 

transactions, and master securities lending agreements for securities lending transactions. 

On a periodic basis, collateral is subject to revaluation based on the specific asset type. For loans, the value of collateral is initially establishe d at  

the time of origination, and the frequency of revaluation is dependent on the type of collateral. For commercial real estate collateral, a full external 
appraisal of the property is typically obtained at the time of loan origination, unless the exposure is below a specified threshold amount, in which 
case an internal evaluation and a site inspection are conducted. Internal evaluations may consider property tax assessments, purchase prices, real 
estate listings or realtor opinions. The case for an updated appraisal is reviewed annually, with consideration given to the borrower risk rating, 
existing tenants and lease contracts, as well as current market conditions. 

In the event a loan is classified as impaired, and depending on its size, a current external appraisal, evaluation or restricted use appraisal is 
obtained and updated every 12 months while the loan is classified as impaired. In Canada, for residential real estate that has a loan-to-value (LTV) 
ratio of less than 80%, an external property appraisal is routinely obtained at the time of loan origination. We may use an external service provided 
by Canada Mortgage and Housing Corporation or an automated valuation model from a third-party appraisal management provider to assist with 
determining either the current value of a property or the need for a full property appraisal. 

For insured residential mortgages in Canada with an LTV ratio greater than 80%, the default insurer is responsible for confirming the lending 

value. 

Portfolio Management and Concentrations of Credit and Counterparty Risk 
Our credit risk governance policies require an acceptable level of diversification to help ensure we avoid undue concentrations of credit risk. 
Concentrations of credit risk may exist if a number of clients are engaged in similar activities, are located in the same geographic region or have 
similar economic characteristics such that their ability to meet contractual obligations could be similarly affected by changes in economic, political 
or other conditions. Limits may be specified for several portfolio dimensions, including industry, specialty segment (e.g., hedge funds and leveraged 
lending), country, product and single-name concentrations. The diversification of our credit exposure may be supplemented by the purchase or sale 
of credit protection through guarantees, insurance or credit default swaps. 

Our credit assets consist of a well-diversified portfolio representing millions of clients, the majority of them individual consumers and small to 
medium-sized businesses. From an industry viewpoint, on a drawn loans and commitments basis, our most significant exposure as at October 31, 2021 
was to individual consumers, comprising $280,087 million ($259,289 million in 2020). 

Wrong-Way Risk 
Wrong-way risk occurs when our exposure to a counterparty or the magnitude of our potential loss is highly correlated with the counterparty’s 
probability of default. Specific wrong-way risk arises when the credit quality of the counterparty and the market risk factors affecting collateral or 
other risk mitigants display a high correlation, and general wrong-way risk arises when the credit quality of the counterparty, for non-specific 
reasons, is highly correlated with macroeconomic or other factors that affect the value of the risk mitigant. Our procedures require that specific 
wrong-way risk be identified in transactions and accounted for in the assessment of risk, including any heightened level of exposure. 

Credit and Counterparty Risk Measurement 
BMO quantifies credit risk at both the individual borrower or counterparty level and the portfolio level. In order to limit earnings volatility, manage 
expected credit losses and minimize unexpected losses, credit risk is assessed and measured using the following risk-based parameters: 

•  Exposure at Default (EAD) represents an estimate of the outstanding amount of a credit exposure at the time a default may occur. 
•  Loss Given Default (LGD) is a measure of BMO’s economic loss, such as the amount that may not be recovered in the event of a default, presented 

as a proportion of the exposure at default. 

•  Probability of Default (PD) represents the likelihood that a borrower or counterparty will go into default over a one-year time horizon. 
•  Expected Loss (EL) is a measure representing the loss that is expected to occur in the normal course of business in a given period of time. 

EL is calculated as a function of EAD, LGD and PD. 

Under Basel III, the Office of the Superintendent of Financial Institutions (OSFI) permits three approaches for the measurement of credit risk: 
Standardized, Foundation Internal Ratings Based and Advanced Internal Ratings Based (AIRB). BMO primarily uses the AIRB Approach to determine 
credit risk-weighted assets (RWA) in its portfolios, including portfolios of the bank’s subsidiary BMO Financial Corp. Refer to the Supplementary 
Regulatory Capital Information disclosure for details regarding the total EAD of Retail and Wholesale exposures under AIRB capital treatment. 
The remaining exposures reflect waivers and exemptions to the AIRB Approach and are measured under the Standardized Approach, subject to 
OSFI’s approval. We continue to transition all material exposures in this category to the AIRB Approach. For securitization exposures, we apply the 
Basel hierarchy of approaches, including the Securitization Internal Ratings Based Approach and the External Ratings Based Approach, as well 
as the Standardized Approach. 

Material presented in a blue-tinted font above is an integral part of Note 5 to the 2021 audited annual consolidated financial statements. 

BMO Financial Group 204th Annual Report 2021  85 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

BMO’s regulatory capital and economic capital frameworks both use EAD to assess credit and counterparty risk. Exposures are classified as follows: 
•  Drawn exposures include loans, acceptances, deposits with regulated financial institutions and certain securities. For off-balance sheet amounts and 

undrawn amounts, EAD includes an estimate of any further amounts that may be drawn at the time of default. 

•  Undrawn commitments cover all unutilized authorizations associated with the drawn loans noted above, including those which are unconditionally 

cancellable. EAD for undrawn commitments is model-generated, based on internal empirical data. 

•  OTC derivatives are those in proprietary accounts that result in exposure to credit risk in addition to market risk. EAD for OTC derivatives is 

calculated inclusive of collateral. 

•  Other off-balance sheet exposures include items such as guarantees, standby letters of credit and documentary credits. EAD for other off-balance 

sheet items is based on management’s best estimate. 

•  Repo-style transactions include repos, reverse repos and securities lending transactions, which represent both asset and liability exposures. 

EAD for repo-style transactions is the calculated exposure, net of collateral. 

•  Capital is calculated based on exposures that, where applicable, have been redistributed to a more favourable PD band or LGD measure, or a 

different Basel asset class, as a result of the application of credit risk mitigation and a consideration of credit risk mitigants, including collateral 
and netting. 

Total credit exposures at default by industry sector, as at October 31, 2021 and 2020, based on the Basel III classifications, are as follows: 

(Canadian $ in millions) 

Drawn (3)

Commitments 
(undrawn) (3)

OTC derivatives (4) 

Other off-balance 
sheet items (3) 

Repo-style 
transactions (4) (5) 

Total (1) 

2021 

2020 

2021 

2020 

2021 

2020 

2021 

2020 

2021 

2020 

2021 

2020 

A
&
D
M

Financial institutions  187,011  142,254 
78,506 
Governments 
27,789 
Manufacturing 
40,202 
Real estate 
19,835 
Retail trade 
47,468 
Service industries 
15,295 
Wholesale trade 
9,659 
Oil and gas 
224,348  206,370 
Individual 
8,869 
Utilities 
36,446 
Others (2) 

67,207 
27,002 
43,524 
16,270 
44,367 
14,372 
6,075 

7,412 
37,071 

26,933 
1,606 
16,470 
9,830 
4,646 
16,126 
5,199 
5,468 
55,655 
10,864 
17,177 

24,302 
1,579 
16,696 
9,735 
4,809 
15,443 
5,455 
7,212 
52,829 
11,779 
14,900 

16,331 
4,011 
1,649 
1,032 
289 
1,238 
282 
10,281 
– 
1,273 
1,588 

19,611 
4,892 
1,741 
1,383 
487 
2,033 
423 
4,753 
– 
2,259 
1,001 

6,808 
400 
1,784 
1,189 
592 
2,998 
694 
1,377 
84 
2,950 
4,732 

6,520 
590 
1,714 
973 
604 
3,116 
600 
1,792 
90 
2,805 
5,295 

28,968 
3,226 
– 
– 
– 
– 
– 
– 
– 
– 
– 

22,866 
2,624 
– 
– 
– 
– 
– 
– 
– 
– 
– 

76,450 
46,905 
55,575 
21,797 
64,729 
20,547 
23,201 

266,051  215,553 
88,191 
47,940 
52,293 
25,735 
68,060 
21,773 
23,416 
280,087  259,289 
25,712 
57,642 

22,499 
60,568 

Total exposure at 

default (6) 

674,659  632,693 

169,974  164,739 

37,974 

38,583 

23,608 

24,099 

32,194 

25,490 

938,409  885,604 

(1)  Credit exposure excluding equity, securitization and other assets, such as non-significant investments, goodwill, deferred tax asset and intangibles. 
(2)  Includes industries having a total exposure of less than 2%. 
(3)  Represents gross credit exposures without accounting for any collateral. 
(4)  Credit exposure at default is inclusive of collateral. 
(5)  Impact of collateral on the credit exposure for repo-style transactions is $208,635 million ($205,212 million in 2020). 
(6)  Excludes exposures arising from derivative and repo-style transactions that are cleared through CCPs totalling $18,440 million ($16,901 million in 2020). 

Prior-period amounts for certain sectors have been adjusted to align with the current year’s presentation, which better classifies the realigned sectors. 

Risk Rating Systems 
BMO’s risk rating systems are designed to assess and measure the risk of any exposure. 

Credit risk-based parameters are reviewed, validated and monitored regularly. The monitoring is on a quarterly basis for both the wholesale 
and retail models. Refer to the Model Risk section for a discussion of model risk mitigation processes. Since the onset of the COVID-19 pandemic, the bank 
has performed proactive reviews to assess the impact of the pandemic on the retail portfolios and on certain sectors in the wholesale portfolios. 

Retail (Consumer and Small Business) 
The retail portfolios comprise a diversified group of individual customer accounts and include residential mortgages, personal loans, credit cards, 
auto loans and small business loans. These loans are managed in pools of homogeneous risk exposures for risk rating purposes. Decision support 
systems are developed using established statistical techniques and expert systems for underwriting and monitoring purposes. Adjudication models, 
behavioural scorecards, decision trees and expert knowledge are combined to generate optimal credit decisions in a centralized and automated 
environment. 

The retail risk rating system assesses risk based on individual loan characteristics. We have a range of internally developed PD, LGD and EAD 
models for each of the major retail portfolios. The major product lines within each of the retail portfolios are modelled separately, so that the risk-
based parameters capture the distinct nature of each product. The models, in general, are designed based on internal historical data recorded over a 
multi-year period that includes at least one full economic cycle, in compliance with regulatory requirements. Adjustments are incorporated into the 
parameters, as appropriate, to account for uncertainties. The retail parameters are tested and calibrated on an annual basis, if required, to incorporate 
additional data points and recent experience in the parameter estimation process. Our largest retail portfolios are the Canadian mortgage, Canadian 
home equity line of credit and Canadian retail credit card portfolios. Risk drivers used in the retail capital models may include customer attributes such 
as delinquency status and credit scores, and account attributes such as loan amount and utilization. 

A PD estimate is assigned to each homogeneous pool to reflect the long-run average of one-year default rates over the economic cycle. 
An LGD estimate is calculated by discounting future recovery payments to the time of default, including collection costs. 
An EAD estimate is calculated as the balance at default divided by the credit limit at the beginning of the year. For non-revolving products, 

such as mortgages, EAD is equal to 100% of the current outstanding balance and has no undrawn component. 

For capital purposes, the LGD and EAD estimates are calibrated to reflect a downturn scenario. The PD, LGD and EAD estimates are updated 

annually and recalibrated as required, by comparing the estimates to observed historical experience. 

Material presented in a blue-tinted font above is an integral part of Note 5 to the 2021 audited annual consolidated financial statements. 

86  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Retail Credit Probability of Default Bands by Risk Rating 

Risk profile 

Exceptionally low 
Very low 
Low 
Medium 
High 
Default 

Probability of default band 
≤ 0.05% 
> 0.05% to 0.20% 
> 0.20% to 0.75% 
> 0.75% to 7.00% 
> 7.00% to 99.99% 
100% 

Wholesale (Corporate, Commercial, Bank and Sovereign) 
Within our wholesale portfolios, an enterprise-wide risk rating framework is applied to all sovereign, bank, corporate and commercial counterparties. 
One key element of this framework is the assignment of appropriate borrower or counterparty risk ratings (BRRs). We have a range of internally 
designed general and sector-specific BRR models, as well as portfolio-level LGD and EAD models for each of the corporate, commercial, bank and 
sovereign portfolios. 

The BRR models capture the key financial and non-financial characteristics of the borrowers and generate a borrower-level rating that reflects the 

rank order of the default risk. The models are primarily designed by using internal data, supplemented with judgment as necessary, for low-default 
portfolios. 

BRRs are assessed and assigned at the time of loan origination, and reassessed when borrowers request changes to credit facilities or events 

trigger a review, such as an external rating change or covenant breach. BRRs are reviewed no less frequently than annually, and more frequent 
reviews are conducted for borrowers with less acceptable risk ratings. The assigned ratings are mapped to a PD reflecting the likelihood of default 
over a one-year time horizon. As a borrower migrates between risk ratings, the PD associated with the borrower changes. 

We employ a master scale with 14 BRRs above default, and PDs are assigned to each rating within an asset class to reflect the long-run average 

of one-year default rates over the economic cycle, supplemented by external benchmarking, as necessary. 

An LGD estimate captures the priority of claim, collateral, product and sector characteristics of the credit facility extended to a borrower. 

M
D
&
A

LGD estimates are at the facility level. 

An EAD estimate captures the facility type, sector and utilization rate characteristics of the credit facility extended to a borrower. EAD estimates 
are at the facility level. The EAD credit conversion factor is calculated for eligible facilities by comparing amounts drawn at the time of default and one 
year prior to default. The authorization and the drawn amount, one year prior to default, are used to split each facility into its respective drawn and 
undrawn portion, where applicable. 

LGD and EAD models have been developed for each asset class using internal data recorded over a multi-year period that includes at least one 
full economic cycle, in compliance with regulatory requirements. Results are benchmarked using external data when necessary and adjustments are 
incorporated into the parameters, as appropriate, to account for uncertainties. For capital purposes, the LGD and EAD parameters are calibrated to 
reflect downturn conditions. The PD, LGD and EAD estimates are updated annually and recalibrated as required, by comparing the estimates to 
observed historical experience. 

As demonstrated in the table below, our internal risk rating system can be aligned with those of external rating agencies. 

Wholesale Borrower Risk Rating Scale 

BMO rating 

Acceptable 
I-1 to I-7 
S-1 to S-4 

Watchlist 
P-1 to P-3 

Default / Impaired 
D-1 to D-4 

Moody’s Investors Service 
implied equivalent 

Standard & Poor’s 
implied equivalent 

Aaa to Baa3 
Ba1 to B1 

B2 to Ca 

C 

AAA to BBB-
BB+ to B+ 

B to CC 

C to D 

Credit Quality Information 

Portfolio Review 
Total enterprise-wide outstanding credit risk exposures were $938.4 billion as at October 31, 2021, 
with $505.7 billion recorded in Canada, $381.7 billion in the United States and $51.0 billion in 
other jurisdictions. This represents an increase of $52.8 billion or 6% from the prior year (1). 

BMO’s loan book continues to be well-diversified by industry and geographic region. Gross 
loans and acceptances increased $10.6 billion or 2% from the prior year to $474.8 billion as at 
October 31, 2021. The geographic mix of BMO’s Canadian and U.S. portfolios represented 66.0% 
and 32.4% of total loans, respectively, compared with 62.5% and 34.9% in the prior year. The loan 
portfolio is well-diversified, with the consumer loan portfolio representing 46.5% of the total 
portfolio, an increase from 44.2% in the prior year, and business and government loans 
representing 53.5% of the total portfolio, a decrease from 55.8% in the prior year. 

(1)  Certain comparative figures have been reclassified to conform with the current year’s presentation. 

Loans by Geography and Operating Group 
($ billions) 

198.2 

98.4 

102.8

24.6 

21.4 

29.4

Canada and Other Countries 

United States 

P&C/Wealth Management – Consumer 
P&C/Wealth Management – Commercial 
BMO Capital Markets 

Material presented in a blue-tinted font above is an integral part of Note 5 to the 2021 audited annual consolidated financial statements. 

BMO Financial Group 204th Annual Report 2021  87 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
A
&
D
M

MANAGEMENT’S DISCUSSION AND ANALYSIS 

Loan Maturities and Interest Rate Sensitivity 
The following table presents gross loans and acceptances by contractual maturity and by country of ultimate risk: 

(Canadian $ in millions) 

1 year or less 

Over 1 year
to 5 years 

Over 5 years 

Total 

2021 

2020 

2021 

2020 

2021 

2020 

2021 

2020 

Canada 

Consumer 
Commercial and corporate 
(excluding real estate) 

Commercial real estate 

United States 
Other countries 

Total 

45,592 

52,346 

146,158 

122,938 

7,836 

7,381 

199,586 

182,665 

59,141 
11,101 
54,896 
5,449 

71,350 
7,397 
45,575 
10,846 

25,786 
15,050 
72,585 
1,762 

16,724 
10,142 
88,143 
999 

1,508 
1,571 
26,170 
242 

723 
1,275 
28,171 
206 

86,435 
27,722 
153,651 
7,453 

88,797 
18,814 
161,889 
12,051 

176,179 

187,514 

261,341 

238,946 

37,327 

37,756 

474,847 

464,216 

The following table presents net loans and acceptances by interest rate sensitivity: 

(Canadian $ in millions) 

Fixed rate 
Floating rate 
Non-interest sensitive (1) 

Total 

2021 

2020 

234,697 
223,565 
14,021 

237,596 
209,824 
13,493 

472,283 

460,913 

(1)  Non-interest sensitive comprises customers’ liability under acceptances. 
Certain comparative figures have been reclassified to conform with the current year’s presentation. 

Further details on BMO’s loan book, including detailed breakdowns by industry and geographic region, can be found in Tables 7 to 15 in the 
Supplemental Information. Details of our credit exposures are presented in Note 4 of the consolidated financial statements. 

Real Estate Secured Lending 
Residential mortgage and home equity line of credit (HELOC) exposures continue to be of interest in the current environment. We regularly perform 
stress testing on our residential mortgage and HELOC portfolios to evaluate the potential effects of high-impact events. These stress tests incorporate 
scenarios ranging from moderately to severely adverse. The credit losses forecast in these tests vary with the severity of the scenario and are 
currently considered to be manageable. 

Leveraged Finance 
We define leveraged finance loans as loans and mezzanine financing provided to private equity-owned businesses for which our assessment 
indicates a higher level of credit risk. We have some exposure to leveraged finance loans, which represented 1.9% of total assets, with $19.0 billion 
outstanding as at October 31, 2021 (1.7% and $16.4 billion, respectively, in 2020). Of this amount, 27.0% of leveraged finance loans, with $5.2 billion 
outstanding as at October 31, 2021 (26% and $4.3 billion, respectively, in 2020), were well-secured by high-quality assets. In addition, $417 million 
or 2.2% of all leveraged finance loans were classified as impaired as at October 31, 2021 ($786 million or 4.8% in 2020). 

Provision for Credit Losses 
Total provision for credit losses was $20 million in the current year, compared with $2,953 million in the prior year, reflecting an improved 
economic outlook and more favourable credit conditions. Detailed discussions of PCL, including historical PCL trends, are provided in Table 15 in 
the Supplemental Information and in Note 4 of the consolidated financial statements. 

Gross Impaired Loans 
Total gross impaired loans and acceptances (GIL) were $2,169 million in 2021, a decrease of 40% from $3,638 million in 2020. The largest decreases 
in impaired loans were recorded in the oil and gas and retail trade industries. GIL as a percentage of gross loans and acceptances was 0.46% in 2021, 
compared with 0.78% in the prior year. 

Factors contributing to the change in GIL are outlined in the table below. Loans classified as impaired during the year decreased to $1,775 million 

from $4,649 million in 2020, reflecting lower impaired loan formations in the oil and gas, retail trade and service industries. On a geographic basis, 
Canada accounted for most impaired loan formations, comprising 75% of total formations in 2021, compared with 39% in 2020. 

Detailed breakdowns of impaired loans by geographic region and industry can be found in Table 11 in the Supplemental Information and in 

Note 4 of the consolidated financial statements. 

Material presented in a blue-tinted font above is an integral part of Note 5 to the 2021 audited annual consolidated financial statements. 

88  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Changes in Gross Impaired Loans (1) and Acceptances 

(Canadian $ in millions, except as noted) 
For the year ended October 31 

GIL, beginning of year 
Classified as impaired during the year 
Transferred to not impaired during the year 
Net repayments 
Amounts written off 
Recoveries of loans and advances previously written off 
Disposals of loans 
Foreign exchange and other movements 

GIL, end of year 

GIL as a % of gross loans and acceptances 

2021 

2020 

3,638 
1,775 
(821) 
(1,618) 
(584) 
– 
(79) 
(142) 

2,169 

0.46 

2,629 
4,649 
(719) 
(1,728) 
(1,047) 
– 
(147) 
1 

3,638 

0.78 

2019 

1,936 
2,686 
(604) 
(800) 
(528) 
– 
(57) 
(4) 

2,629 

0.58 

M
D
&
A

(1)  GIL excludes purchased credit impaired loans. 
Certain comparative figures have been reclassified to conform with the current year’s presentation. 

Allowance for Credit Losses 
We employ a disciplined approach to provisioning and loan loss evaluation across all loan portfolios, with the prompt identification of problem loans 
being a key risk management objective. We maintain both an allowance on impaired loans and an allowance on performing loans, in accordance with 
IFRS. An allowance on performing loans is maintained to cover impairment in the existing portfolio for loans that have not yet been individually 
identified as impaired. Our approach to establishing and maintaining the allowance on performing loans is based on the requirements of IFRS, 
considering the guideline issued by our regulator, OSFI. Under the IFRS 9 expected credit loss (ECL) methodology, an allowance is recorded for ECL 
on financial assets regardless of whether there has been an actual loss event. We recognize a loss allowance at an amount generally based 
on 12 months of ECL, if the credit risk at the reporting date has not increased significantly since initial recognition (Stage 1). We record ECL over the 
remaining life of performing financial assets that are considered to have experienced a significant increase in credit risk (Stage 2). 

ECL is calculated on a probability-weighted basis, based on three different economic scenarios, and is a function of PD, EAD and LGD estimates 
calibrated to meet the requirements for calculating ECL for a specific financial asset. The timing of the loss is also considered, and ECL is estimated 
by incorporating forward-looking economic information and by applying experienced credit judgment to reflect factors not captured in ECL models. 
An allowance on impaired loans is maintained to reduce the carrying value of individually identified impaired loans (Stage 3) to the expected 
recoverable amount. 

We maintain an allowance for credit losses (ACL) at a level that we consider appropriate to absorb credit-related losses. As at October 31, 2021, 
the total ACL was $2,958 million, a decrease of $856 million from the prior year, reflecting lower allowances on both performing loans and impaired 
loans. The allowance on impaired loans was $511 million as at October 31, 2021, and the allowance on performing loans was $2,447 million. 
These amounts included an allowance on impaired loans of $13 million and an allowance on performing loans of $381 million related to undrawn 
commitments and letters of credit that are considered other credit instruments and recorded in other liabilities. The allowance on impaired loans 
decreased $228 million from $739 million in the prior year, and our coverage ratio remained adequate, with ACL on impaired loans as a percentage of 
GIL of 23.0%, compared with 20.0% in 2020. This ratio can change quarter-over-quarter due to variability in the write-down of loans and the related 
allowance. The allowance on performing loans decreased $628 million to $2,447 million from $3,075 million in the prior year, primarily driven by an 
improving economic outlook, positive credit migration and movements in foreign exchange rates, partially offset by the impact of the uncertain 
environment on future credit conditions, including adoption of a higher adverse scenario weight, as well as a more severe adverse scenario and 
portfolio growth. 

Further details on the continuity in ACL by each product type can be found in Tables 12 and 13 in the Supplemental Information, and in Note 4 of 

the consolidated financial statements. 

BMO Financial Group 204th Annual Report 2021  89 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

European Exposures 
BMO’s geographic exposures are subject to a country risk management framework that incorporates economic and political assessments 
and management of exposures within limits based on product, entity and country of ultimate risk. Our exposure to European countries as at 
October 31, 2021, including Greece, Ireland, Italy, Portugal and Spain (GIIPS), is set out in the tables that follow. 

The table below outlines total net portfolio exposures for funded lending, securities (including credit default swap (CDS) activity), repo-style 
transactions and derivatives. Funded lending is detailed by counterparty type, as well as by total commitments compared with the funded amount, 
in the following tables. 

European Exposure by Country and Counterparty (1) 

Funded lending (2) 

Securities (3) (4) 

Repo-style transactions and derivatives (5) (6) 

Total 

Bank 

Corporate 

Sovereign 

Total 

Bank 

Corporate 

Sovereign 

Total 

(Canadian $ in millions) 
As at October 31, 2021 

Country 

GIIPS 
Greece 
Ireland (7) 
Italy 
Portugal 
Spain 

A
&
D
M

Total – GIIPS 

Eurozone (excluding GIIPS) 
France 
Germany 
Netherlands 
Other (8) 

Total – Eurozone (excluding GIIPS) 

Rest of Europe 
Norway 
Sweden 
Switzerland 
United Kingdom 
Other (8) 

Total – Rest of Europe 

Total – All of Europe (9) 

– 
483 
13 
– 
432 

928 

136 
259 
397 
425 

1,217 

341 
18 
371 
1,773 
– 

2,503 

4,648 

– 
– 
– 
– 
49 

49 

19 
532 
338 
– 

889 

– 
156 
– 
112 
41 

309 

1,247 

– 
– 
– 
– 
3 

3 

– 
44 
– 
1 

45 

– 
4 
– 
246 
– 

250 

298 

– 
– 
– 
– 
– 

– 

– 
– 
– 
– 
52 

52 

596 
772 
– 
74 

615 
1,348 
338 
75 

1,442 

2,376 

123 
336 
– 
4,396 
15 

123 
496 
– 
4,754 
56 

4,870 

5,429 

– 
8 
1 
– 
6 

15 

14 
212 
659 
16 

901 

– 
3 
36 
135 
9 

183 

6,312 

7,857 

1,099 

– 
52 
– 
– 
2 

54 

5 
2 
149 
16 

172 

4 
– 
15 
620 
5 

644 

870 

Total net 
exposure 

– 
543 
14 
– 
492 

1,049 

775 
1,821 
1,543 
536 

– 
60 
1 
– 
8 

69 

24 
214 
808 
36 

1,082 

4,675 

34 
3 
51 
814 
18 

920 

498 
517 
422 
7,341 
74 

8,852 

102 

2,071 

14,576 

– 
– 
– 
– 
– 

– 

5 
– 
– 
4 

9 

30 
– 
– 
59 
4 

93 

As at October 31, 2020 

Funded lending (2) 

Securities (3) 

Repo-style transactions and derivatives (5) (6) 

Country 

Total – GIIPS 

Total – Eurozone (excluding GIIPS) 

Total – Rest of Europe 

Total – All of Europe (9) 

Total 

611 

1,329 

3,185 

5,125 

Bank 

Corporate 

Sovereign 

Total 

Bank 

Corporate 

Sovereign 

Total 

53 

944 

622 

1,619 

1 

77 

710 

788 

– 

54 

1,038 

2,059 

7,212 

8,544 

8,250 

10,657 

8 

111 

779 

898 

225 

306 

593 

1,124 

3 

10 

58 

71 

236 

427 

1,430 

2,093 

Total net 
exposure 

901 

3,815 

13,159 

17,875 

(1)  BMO has the following indirect exposures to Europe as at October 31, 2021: 

–  Collateral of €976 million to support trading activity in securities (€79 million from GIIPS) and €284 million of cash collateral held. 
–  Guarantees of $11 billion ($248 million to GIIPS). 

(2)  Funded lending includes loans. 
(3)  Securities include cash products, insurance investments and traded credit. 
(4)  BMO’s total net notional CDS exposure (embedded as part of the securities exposure in this table) to Europe was $167 million, with no net single-name* CDS exposure to GIIPS as at October 29, 2021 

(*includes a net position of $131 million (bought protection) on a CDS Index, of which 12% comprises GIIPS domiciled entities). 

(5)  Repo-style transactions are primarily with bank counterparties for which BMO holds collateral ($41 billion for Europe as at October 31, 2021). 
(6)  Derivatives amounts are marked-to-market, incorporating transaction netting where master netting agreements with counterparties have been entered into, and collateral offsets for counterparties 

where a Credit Support Annex is in effect. 

(7)  Does not include Irish subsidiary reserves the bank is required to maintain with the Irish Central Bank of $104 million as at October 31, 2021. 
(8)  Other Eurozone exposure includes five countries with less than $300 million net exposure. Other European exposure is distributed across four countries as at October 31, 2021. 
(9)  Of BMO’s total net direct exposure to Europe, approximately 93% was to counterparties in countries with a rating of Aa2/AAA from at least one of Moody’s or S&P. 

90  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
European Lending Exposure by Country and Counterparty (9) 

(Canadian $ in millions) 
Country 

GIIPS 
Greece 
Ireland (7) 
Italy 
Portugal 
Spain 

Total – GIIPS 

Eurozone (excluding GIIPS) 
France 
Germany 
Netherlands 
Other (8) 

Total – Eurozone (excluding GIIPS) 

Rest of Europe 
Norway 
Sweden 
Switzerland 
United Kingdom 
Other (8) 

Total – Rest of Europe 

Total – All of Europe (9) 

Refer to footnotes in the table above. 

Funded lending as at October 31, 2021 

As at October 31, 2021 

As at October 31, 2020 

Bank 

Corporate 

Sovereign 

Commitments 

Funded 

Commitments 

Funded 

Lending (2) 

– 
– 
13 
– 
91 

104 

134 
157 
73 
93 

457 

27 
16 
19 
9 
– 

71 

632 

– 
483 
– 
– 
341 

824 

2 
102 
324 
332 

760 

314 
2 
352 
1,764 
– 

2,432 

4,016 

– 
– 
– 
– 
– 

– 

– 
– 
– 
– 

– 

– 
– 
– 
– 
– 

– 

– 

– 
641 
13 
– 
505 

1,159 

264 
406 
436 
425 

– 
483 
13 
– 
432 

928 

136 
259 
397 
425 

– 
531 
15 
– 
206 

752 

386 
607 
397 
403 

– 
474 
15 
– 
122 

611 

240 
391 
374 
324 

1,531 

1,217 

1,793 

1,329 

665 
76 
429 
2,668 
31 

341 
18 
371 
1,773 
– 

3,869 

2,503 

6,559 

4,648 

1,158 
117 
602 
4,809 
100 

6,786 

9,331 

638 
16 
505 
1,959 
67 

3,185 

5,125 

M
D
&
A

Derivative Transactions 
The following table presents the notional amounts of BMO’s over-the-counter (OTC) derivative contracts, comprising those which are centrally cleared 
and settled through a designated clearing house or central counterparty (CCP) and those which are non-centrally cleared. 

CCPs are established under the supervision of central banks or other similar regulatory authorities and, as financial market infrastructure, 
must satisfy certain financial resilience requirements. Generally speaking, to centrally clear, we acquire a membership in the CCP and, in addition 
to providing collateral to protect the CCP against risk related to BMO, we are exposed to risk as a member for our contribution to a default fund. 
We may also be called on to make additional contributions or provide other support in the event another member defaults. 

The notional amounts of our derivatives represent the amount to which a rate or price is applied in order to calculate the amount of cash that 
must be exchanged under each contract. Notional amounts do not represent assets or liabilities and therefore are not recorded in the Consolidated 
Balance Sheet. The fair values of OTC derivative contracts are recorded in the Consolidated Balance Sheet. 

Over-the-Counter Derivative Contracts (Notional amounts) 

(Canadian $ in millions) 

As at October 31 

Interest Rate Contracts 
Swaps 
Forward rate agreements 
Purchased options 
Written options 

Total interest rate contracts 

Foreign Exchange Contracts 
Cross-currency swaps 
Cross-currency interest rate swaps 
Forward foreign exchange contracts 
Purchased options 
Written options 

Total foreign exchange contracts 

Commodity Contracts 
Swaps 
Purchased options 
Written options 

Total commodity contracts 

Equity Contracts 

Credit Default Swaps 
Purchased 
Written 

Total credit default swaps 

Total 

Non-centrally cleared 

Centrally cleared 

Total 

2021 

2020 

2021 

2020 

2021 

2020 

379,117 
2,919 
69,491 
68,155 

442,727 
2,890 
57,833 
64,728 

3,772,174 
144,738 
– 
– 

3,892,564 
514,442 
– 
– 

4,151,291 
147,657 
69,491 
68,155 

4,335,291 
517,332 
57,833 
64,728 

519,682 

568,178 

3,916,912 

4,407,006 

4,436,594 

4,975,184 

85,912 
513,421 
441,107 
54,051 
54,045 

96,813 
540,688 
449,701 
38,985 
41,286 

1,148,536 

1,167,473 

– 
– 
48,319 
94 
102 

48,515 

– 
– 
44,939 
82 
41 

85,912 
513,421 
489,426 
54,145 
54,147 

96,813 
540,688 
494,640 
39,067 
41,327 

45,062 

1,197,051 

1,212,535 

28,892 
4,526 
3,132 

36,550 

99,471 

778 
179 

957 

30,613 
5,728 
3,704 

40,045 

60,502 

1,386 
510 

1,896 

– 
– 
– 

– 

7 

– 
– 
– 

– 

2 

11,580 
4,979 

16,559 

6,021 
1,285 

7,306 

28,892 
4,526 
3,132 

36,550 

99,478 

12,358 
5,158 

17,516 

30,613 
5,728 
3,704 

40,045 

60,504 

7,407 
1,795 

9,202 

1,805,196 

1,838,094 

3,981,993 

4,459,376 

5,787,189 

6,297,470 

BMO Financial Group 204th Annual Report 2021  91 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Market Risk 

Market risk is the potential for adverse changes in the value of our assets and liabilities resulting from changes in market variables such as 
interest rates, foreign exchange rates, equity and commodity prices and their implied volatilities, and credit spreads, and includes the risk of 
credit migration and default in our trading book. 

Market risk arises from our trading and underwriting activities, as well as our structural banking activities. The magnitude and importance of these 
activities to the enterprise, along with the potential volatility of market variables, call for diligent governance and a robust market risk management 
framework that seeks to provide effective identification, measurement, reporting and control of market risk exposures. 

A
&
D
M

Trading and Underwriting Market Risk Governance 
Our market risk-taking activities are subject to an extensive governance framework. The Risk Review Committee (RRC) provides oversight of the 
management of market risk on behalf of the Board of Directors and approves limits governing market risk exposures that are consistent with our 
risk appetite. The Risk Management Committee (RMC) regularly reviews and discusses significant market risk exposures and positions, and provides 
ongoing senior management oversight of our risk-taking activities. Both of these committees are kept apprised of specific market risk exposures and 
other factors that could expose us to unusual, unexpected or unquantified risks associated with market exposures, as well as other current and 
emerging market risks. In addition, all businesses and individuals authorized to conduct trading and underwriting activities on behalf of BMO are 
required to work within our governance framework and, as part of their first-line-of-defence responsibilities, they must adhere to all relevant 
corporate policies, standards and procedures and maintain and manage market risk exposures within specified limits and risk tolerances. In support 
of our risk governance framework, our market risk management framework comprises processes, infrastructure and supporting documentation, which 
together support the identification, assessment, independent monitoring and control of our market risk exposures. 

Trading and Underwriting Market Risk 
Our trading and underwriting businesses give rise to market risk associated with buying and selling financial products in the course of meeting 
customer needs, including market-making and related financing activities, and assisting clients to raise funds by way of securities issuance. 

Identification and Assessment of Trading and Underwriting Market Risk 
As the first step in the management of market risk, thorough assessment processes are in place to identify market risk exposures associated with 
both new products and the evolving risk profile of existing products, including on- and off-balance sheet positions, trading and non-trading positions, 
and market risk exposures arising from the domestic and foreign operations of our operating groups. 

Reflecting the multi-dimensional nature of market risk, various metrics and techniques are then employed to measure identified market risk 
exposures. These metrics primarily include Value at Risk, Stressed Value at Risk, and regulatory and economic capital attribution, as well as stress 
testing. Other techniques include the analysis of the sensitivity of our trading and underwriting portfolios to various market risk factors and the 
review of position concentrations, notional values and trading losses. 

Value at Risk (VaR) measures the maximum loss likely to be experienced in the trading and underwriting portfolios, measured at a 99% 
confidence level over a one-day holding period. VaR is calculated for specific classes of risk in BMO’s trading and underwriting activities related 
to interest rates, foreign exchange rates, credit spreads, equity and commodity prices and their implied volatilities. 

Stressed Value at Risk (SVaR) measures the maximum loss likely to be experienced in the trading and underwriting portfolios, measured at a 
99% confidence level over a one-day holding period, with model inputs calibrated to historical data from a period of significant financial stress. 
SVaR is calculated for specific classes of risk in BMO’s trading and underwriting activities related to interest rates, foreign exchange rates, credit 
spreads, equity and commodity prices and their implied volatilities. 

Incremental Risk Charge (IRC) complements the VaR and SVaR metrics and represents an estimate of the default and migration risks 
of non-securitization products held in the trading book with exposure to interest rate risk, measured over a one-year horizon at a 99.9% 
confidence level. 

A consistent set of VaR and SVaR models is used for both management and regulatory purposes across all BMO Financial Group legal entities in which 
trading or underwriting activities are conducted. 

We use a variety of methods to verify the integrity of our risk models, including the application of back-testing against hypothetical losses and 

approval by an independent model validation team. This testing is aligned with defined regulatory expectations, and its results confirm the reliability 
of our models. The volatility data and correlations that underpin our models are updated frequently, so that risk metrics reflect current conditions. 
Selection of the period of significant financial stress for SVaR incorporates historical events, including the COVID-19 pandemic. 

Probabilistic stress testing and scenario analysis are used to determine the potential impact of low-frequency, high-severity events on our 

portfolios. The scenarios incorporate hypothetical and historical events, and consider the performance of our portfolios under a variety of market 
conditions. Scenarios are amended, added or removed to refine our risk measurement, for example to reflect the market volatility in 2020 and 2021 
due to the COVID-19 pandemic, and the results are reported to the lines of business, the RMC and the RRC on a regular basis. 

VaR, SVaR, IRC and stress testing should not be viewed as definitive predictors of the maximum amount of losses that could occur in any one 
day, as their results are based on models and estimates and are subject to confidence levels, and the estimates could be exceeded under unforeseen 
market conditions. 

Material presented in a blue-tinted font above is an integral part of Note 5 to the 2021 audited annual consolidated financial statements. 

92  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Back-testing assumes there are no changes in the previous day’s closing positions and then isolates the effects of each day’s price movements 

against those closing positions. Our VaR model is back-tested daily, and the one-day 99% confidence level VaR at the local and consolidated BMO 
levels is compared with the estimated daily profit and loss (P&L) that would be recorded if the portfolio composition remained unchanged. If this P&L 
result is negative and its absolute value is greater than the previous day’s VaR, a back-testing exception occurs. Each exception is investigated, 
explained and documented, and the back-testing results are reviewed by senior management and reported to our regulators. 

Although it is a useful indicator of risk, as with any model-driven metric, VaR has limitations, including the assumption that all positions can 

be liquidated within the assumed one-day holding period, which may not be the case under illiquid market conditions. Generally, market liquidity 
horizons are reviewed for suitability and updated where appropriate for relevant risk metrics. Further limitations of the VaR metric include the 
assumption that historical data can be used as a proxy to forecast future market events, and the fact that VaR calculations are based upon portfolio 
positions at the close of business and do not reflect the impact of intra-day trading activity. 

Monitoring and Control of Trading and Underwriting Market Risk 
Limits are applied to VaR, SVaR and other risk metrics, and the limits are subject to regular monitoring and reporting, with breaches escalated to 
the appropriate level of management. Risk profiles of our trading and underwriting activities are maintained within our risk appetite and supporting 
limits, and are monitored and reported to traders, management, senior executives and Board committees. Other significant controls include the 
independent valuation of financial assets and liabilities, as well as compliance with our Model Risk Management Framework to mitigate model risk. 

Trading Market Risk Measures 

Trading VaR and SVaR 
Average Total Trading VaR was marginally higher year-over-year, as the market impact of the COVID-19 pandemic remained within the historical 
period used for VaR for most of the year, and growth in mortgage trading increased interest rate risk. VaR declined in the second half of 2021, as the 
historical period used for VaR moved past the second and third quarters of 2020 and the market volatility prevailing at that time. Average Total SVaR 
declined year-over-year due to reduced exposure to risk in our equity option books. 

Total Trading Value at Risk (VaR) Summary (1) (2) (3) 

As at or for the year ended October 31 
(pre-tax Canadian $ equivalent in millions) 

2021 

2020 

Year-end 

Average 

High 

Low 

Year-end 

Average 

High 

Low 

M
D
&
A

Commodity VaR 
Equity VaR 
Foreign exchange VaR 
Interest rate VaR (4) 
Debt-specific risk 
Diversification 

Total Trading VaR 

Total Trading SVaR 

1.8 
10.8 
0.5 
15.2 
3.0 
(12.8) 

18.5 

55.8 

2.7 

2.2 

1.1 
6.2 
14.9  24.9  10.0 
0.5 
6.4 
9.8 
27.1  52.5 
1.9 
5.4 
nm 
nm 

3.3 
(19.7) 

30.5  53.5  15.3 

45.7  65.4  36.3 

5.5 
16.4 
4.2 
40.7 
3.9 
(25.5) 

45.2 

45.2 

2.5 
16.0 
3.4 
23.1 
3.8 
(20.3) 

5.8 
37.2 
6.8 
42.0 
7.6 
nm 

28.5 

53.4 

0.6 
4.2 
0.8 
5.4 
1.6 
nm 

8.1 

50.8 

87.1 

29.2 

(1)  One-day measure using a 99% confidence interval. Gains are presented in brackets and losses are presented as positive numbers. 
(2)  Stressed VaR is produced weekly. 
(3)  In Q1-2020, a new measurement approach was introduced for VaR and SVaR, which separated the previously reported credit VaR into interest rate VaR for general credit spread risk and for 

debt-specific risk. Total Trading VaR and SVaR no longer reflect diversification benefits from debt-specific risk. 

(4)  Interest rate VaR includes general credit spread risk. 
nm – not meaningful 

Material presented in a blue-tinted font above is an integral part of Note 5 to the 2021 audited annual consolidated financial statements. 

BMO Financial Group 204th Annual Report 2021  93 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Trading Net Revenue 
The charts below present daily net revenues plotted against Total Trading VaR, along with a representation of daily net revenue distribution. In 2021, 
net trading losses were incurred on two days, and we experienced the largest loss on October 19, 2021. A combination of high market volatility, 
which had a negative impact on some of our positions, and lower than usual customer activity contributed to the losses for the two days. 

Trading Net Revenues versus Value at Risk 
November 1, 2020 to October 31, 2021 (pre-tax basis, Canadian $ in millions) 

A
&
D
M

60 

40 

20 

0 

(20) 

(40) 

(60) 

0
2
-
v
o
N
-
5

0
2
-
v
o
N
-
3
1

0
2
-
v
o
N
-
0
2

0
2
-
v
o
N
-
7
2

0
2
-
c
e
D
-
4

0
2
-
c
e
D
-
1
1

0
2
-
c
e
D
-
8
1

0
2
-
c
e
D
-
9
2

1
2
-
n
a
J
-
6

1
2
-
n
a
J
-
3
1

1
2
-
n
a
J
-
0
2

1
2
-
n
a
J
-
7
2

1
2
-
b
e
F
-
3

1
2
-
b
e
F
-
0
1

1
2
-
b
e
F
-
8
1

1
2
-
b
e
F
-
5
2

1
2
-
r
a
M
-
4

1
2
-
r
a
M
-
1
1

1
2
-
r
a
M
-
8
1

1
2
-
r
a
M
-
5
2

1
2
-
r
p
A
-
1

1
2
-
r
p
A
-
9

1
2
-
r
p
A
-
6
1

1
2
-
r
p
A
-
3
2

1
2
-
r
p
A
-
0
3

1
2
-
y
a
M
-
7

1
2
-
y
a
M
-
4
1

1
2
-
y
a
M
-
1
2

1
2
-
y
a
M
-
1
3

1
2
-
n
u
J
-
7

1
2
-
n
u
J
-
4
1

1
2
-
n
u
J
-
1
2

1
2
-
n
u
J
-
8
2

1
2
-
l
u
J
-
6

1
2
-
l
u
J
-
3
1

1
2
-
l
u
J
-
0
2

1
2
-
l
u
J
-
7
2

1
2
-
g
u
A
-
4

1
2
-
g
u
A
-
1
1

1
2
-
g
u
A
-
8
1

1
2
-
g
u
A
-
5
2

1
2
-
p
e
S
-
1

1
2
-
p
e
S
-
9

1
2
-
p
e
S
-
6
1

1
2
-
p
e
S
-
3
2

1
2
-
p
e
S
-
0
3

1
2
-
t
c
O
-
7

1
2
-
t
c
O
-
5
1

1
2
-
t
c
O
-
2
2

1
2
-
t
c
O
-
9
2

Daily Revenue 

Total Trading VaR 

Frequency Distribution of Daily Net Revenues 
November 1, 2020 to October 31, 2021 (Canadian $ in millions) 

s
y
a
d

f
o

r
e
b
m
u
n

n

i

y
c
n
e
u
q
e
r
F

80 

70 

60 

50 

40 

30 

20 

10 

0 

-5

 0

5 

10

 15

 20

 25

 30

 35

 53

Daily net revenues (pre-tax $ millions) 

Structural (Non-Trading) Market Risk 
Structural market risk comprises interest rate risk arising from our banking activities (such as loans and deposits) and foreign exchange risk arising 
from our foreign currency operations and exposures. 

Structural Market Risk Governance 
BMO’s Corporate Treasury group is responsible for the ongoing management of structural market risk across the enterprise, with independent 
oversight provided by the Market Risk group. In addition to Board-approved limits on earnings at risk and economic value sensitivities to changes 
in interest rates, more granular management limits are in place to guide the daily management of this risk. 

The RRC oversees structural market risk management, regularly reviews structural market risk positions and annually approves the structural 

market risk plan and limits. The RMC and Asset Liability Committee provide regular ongoing senior management oversight of risk positions and 
activity. 

Material presented in a blue-tinted font above is an integral part of Note 5 to the 2021 audited annual consolidated financial statements. 

94  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Structural Market Risk Measurement 

Interest Rate Risk 
Structural interest rate risk arises when changes in interest rates affect the market value, cash flows and earnings of assets and liabilities related 
to our banking activities. The objective of structural interest rate risk management is to maintain high-quality earnings and maximize sustainable 
product spreads, while managing the risk to the economic value of our net assets arising from changes in interest rates. 
Structural interest rate risk primarily comprises interest rate mismatch risk and product embedded option risk. 
Interest rate mismatch risk arises when there are differences in the scheduled maturities, repricing dates or reference rates of assets, liabilities 
and derivatives. The net interest rate mismatch, representing residual assets funded by common shareholders’ equity, is managed to a target profile 
through interest rate swaps and securities. 

Product embedded option risk arises when product features allow customers to alter cash flows, such as scheduled maturity or repricing dates, 

usually in response to changes in market conditions. Product embedded options include loan prepayments, deposit redemption privileges and 
committed rates on unadvanced mortgages. Product embedded options and associated customer behaviours are captured in risk modelling, and 
hedging programs may be used to manage this risk to low levels. 

Structural interest rate risk is measured using simulations, earnings sensitivity and economic value sensitivity analysis, stress testing and gap 

analysis, in addition to other treasury risk metrics. 

Earnings Sensitivity is a measure of the impact of potential changes in interest rates on the projected 12-month pre-tax net income of a 
portfolio of assets, liabilities and off-balance sheet positions in response to prescribed parallel interest rate movements, with interest rates 
floored at zero. 

Economic Value Sensitivity is a measure of the impact of potential changes in interest rates on the market value of a portfolio of assets, 
liabilities and off-balance sheet positions in response to prescribed parallel interest rate movements, with interest rates floored at zero. 

M
D
&
A

The models that measure structural interest rate risk incorporate projected changes in interest rates and predict the likely reaction of our customers 
to these changes. For customer loans and deposits with scheduled maturity and repricing dates (such as mortgages and term deposits), the models 
measure the extent to which customers are likely to use embedded options to alter those scheduled terms. For customer loans and deposits without 
scheduled maturity and repricing dates (such as credit card loans and chequing accounts), exposure is measured using models that adjust for elasticity 
in product pricing and reflect historical and forecasted trends in balances. The results of these structural market risk models, by their nature, have 
inherent uncertainty, as they reflect potential anticipated pricing and customer behaviours, which may differ from actual experience. These models 
have been developed using statistical analysis and are independently validated and periodically updated through regular model performance 
assessment, back-testing and ongoing dialogue with the lines of business. Models developed to predict customer behaviour are also used to support 
product pricing. All models are subject to BMO’s Model Risk Management Framework, which is described in more detail in the Enterprise-Wide Risk 
Management Framework section. 

Structural interest rate earnings sensitivity and economic value sensitivity to an immediate parallel increase or decrease in the yield curve are 
disclosed in the table below. As a result of the low interest rate environment, earnings and economic value sensitivities to declining interest rates 
commencing as at April 30, 2020 are measured using a 25 basis point decline. 

There were no significant changes in the structural market risk management framework during the year. 
Structural economic value sensitivity to rising interest rates primarily reflects a lower market value for fixed rate loans. Structural economic value 

sensitivity to falling interest rates primarily reflects the impact of a higher market value for fixed rate loans and minimum modelled client deposit 
rates. Structural economic value exposure to rising interest rates and the benefits of falling interest rates increased relative to October 31, 2020, 
primarily due to modelled deposit pricing being more rate-sensitive at higher projected interest rate levels, following the increase in term market 
rates during the year. Structural earnings sensitivity quantifies the potential impact of interest rate changes on structural balance sheet pre-tax net 
income over the next 12 months. Structural earnings sensitivity to falling interest rates primarily reflects the risk of fixed and floating rate loans 
repricing at lower rates and the more limited ability to reduce deposit pricing as rates fall. Structural earnings exposure to falling interest rates 
increased in 2021 relative to 2020, largely due to customer deposit growth. The benefits to structural earnings of rising interest rates primarily reflect 
the positive impact of widening deposit margins as interest rates rise, and this exposure increased in 2021 relative to 2020, largely due to customer 
deposit growth. 

Structural Interest Rate Sensitivity (1) 

(Pre-tax Canadian $ 
equivalent in millions) 

100 basis point increase 
25 or 100 basis point decrease (2) 

Economic value sensitivity 

Earnings sensitivity over the next 12 months 

October 31, 2021 

October 31, 2020 

October 31, 2021 

October 31, 2020 

Canada (3) (4)  United States 

Total (4) 

Total (4) 

Canada (3) (4)  United States  Total (4)  Total (4) 

(894.0) 
202.0 

(565.1) 
62.9 

(1,459.1) 
264.9 

(1,085.1) 
100.0 

51.9 
(59.2) 

331.8  383.7 
(82.4)  (141.6) 

285.8 
(98.2) 

(1)  Losses are presented in brackets and gains are presented as positive numbers. 
(2)  Due to the low interest rate environment, starting April 30, 2020, economic value sensitivity and earnings sensitivity to declining interest rates are measured using a 25 basis point decline. 
(3)  Includes Canadian dollar and other currencies. 
(4)  Measures reflect revised modelling assumptions effective January 31, 2021. Prior periods have been updated to reflect the revised approach and to conform with the current year’s presentation. 

Material presented in a blue-tinted font above is an integral part of Note 5 to the 2021 audited annual consolidated financial statements. 

BMO Financial Group 204th Annual Report 2021  95 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Insurance Market Risk 
Insurance market risk includes interest rate and equity market risk arising from our insurance business activities. A 100 basis point increase in interest 
rates as at October 31, 2021 would result in an increase in earnings before tax of $48 million ($39 million as at October 31, 2020). A 25 basis point 
decrease in interest rates as at October 31, 2021 would result in a decrease in earnings before tax of $12 million ($9 million as at October 31, 2020). 
A 10% increase in equity market values as at October 31, 2021 would result in an increase in earnings before tax of $22 million ($51 million as at 
October 31, 2020). A 10% decrease in equity market values as at October 31, 2021 would result in a decrease in earnings before tax of $22 million 
($53 million as at October 31, 2020). We may enter into hedging arrangements to offset the impact of changes in equity market values on our earnings, 
and we did so during the 2021 fiscal year. The impact of insurance market risk on earnings is reflected in insurance claims, commissions and changes in 
policy benefit liabilities in our Consolidated Statement of Income, and the corresponding change in the fair value of BMO’s policy benefit liabilities is 
reflected in other liabilities in our Consolidated Balance Sheet. The impact of insurance market risk is not reflected in the table above. 

Foreign Exchange Risk 
Structural foreign exchange risk arises primarily from translation risk related to our net investment in U.S. operations and from transaction risk 
associated with U.S.-dollar-denominated net income. 

A
&
D
M

Translation risk represents the impact that changes in foreign exchange rates could have on our reported shareholders’ equity and capital ratios. 
We may enter into arrangements to offset the impact of foreign exchange rate movements on our capital ratios, and we did so during the 2021 fiscal 
year. Refer to the Enterprise-Wide Capital Management section for further discussion. 

Transaction risk represents the impact that fluctuations in the Canadian dollar/U.S. dollar exchange rate could have on the Canadian dollar 
equivalent of BMO’s U.S.-dollar-denominated financial results. Exchange rate fluctuations will affect future results measured in Canadian dollars and 
the impact on those results is a function of the periods during which revenues, expenses and provisions for credit losses arise. Hedging positions may 
be taken to partially offset the pre-tax effects of Canadian dollar/U.S. dollar exchange rate fluctuations on financial results, although no hedges were 
executed in the current or prior year. If future results are consistent with results in 2021, each one cent increase (decrease) in the Canadian dollar/U.S. 
dollar exchange rate would be expected to increase (decrease) the Canadian dollar equivalent of U.S. segment net income before income taxes for 
the year by $34 million, in the absence of hedging transactions. Refer to the Foreign Exchange section for a more complete discussion of the effects 
of changes in foreign exchange rates on our results. 

Linkages between Balance Sheet Items and Market Risk Disclosures 
The table below presents items reported on the Consolidated Balance Sheet that are subject to market risk, comprising balances that are subject to 
either traded risk or non-traded risk measurement techniques. 

As at October 31, 2021 

Subject to market risk 

As at October 31, 2020 

Subject to market risk 

Consolidated 
Balance Sheet 

Traded 
risk (1) 

Non-traded 
risk (2) 

Not subject to 
market risk 

Consolidated 
Balance Sheet 

Traded 
risk (1) 

Non-traded 
risk (2) 

Not subject to 
market risk 

(Canadian $ in millions) 

Assets Subject to Market Risk 
Cash and cash equivalents 
Interest bearing deposits with banks 
Securities 

93,261 
8,303 

– 
94 
232,849  104,412 

93,261 
8,209 
128,437 

Securities borrowed or purchased under 

resale agreements 

Loans (net of allowance for credit losses) 

107,382 
458,262 

– 
3,665 

107,382 
454,597 

Derivative instruments 

36,713 

34,350 

2,363 

– 
– 
– 

– 
– 

– 

57,408 
9,035 

– 
217 
234,260  97,723 

57,408 
8,818 
136,537 

111,878 
447,420 

– 
2,416 

111,878 
445,004 

36,815  32,457 

4,358 

– 
– 
– 

– 
– 

– 

Customers’ liability under acceptances 
Other assets 

Total Assets 

Liabilities Subject to Market Risk 
Deposits 

14,021 
37,384 

– 
3,359 

14,021 
16,970 

988,175  145,880 

825,240 

– 
17,055 

17,055 

13,493 
38,952 

– 
5,446 

13,493 
16,105 

949,261  138,259 

793,601 

– 
17,401 

17,401 

685,631 

22,665 

662,966 

Derivative instruments 

30,815 

27,875 

2,940 

Acceptances 
Securities sold but not yet purchased 
Securities lent or sold under repurchase 

agreements 
Other liabilities 
Subordinated debt 

Total Liabilities 

14,021 
32,073 

– 
32,073 

97,556 
63,663 
6,893 

– 
85 
– 

14,021 
– 

97,556 
63,165 
6,893 

930,652 

82,698 

847,541 

– 

– 

– 
– 

– 
413 
– 

413 

659,034  18,074 

640,960 

30,375  26,355 

4,020 

13,493 
– 
29,376  29,376 

88,658 
63,316 
8,416 

– 
118 
– 

13,493 
– 

88,658 
62,964 
8,416 

892,668  73,923 

818,511 

Interest rate, 
foreign exchange 
Interest rate, 
foreign exchange 
Interest rate 

Interest rate 
Interest rate 
Interest rate 

– 

– 

– 
– 

– 
234 
– 

234 

Primary risk factors 
for non-traded 
risk balances 

Interest rate 
Interest rate 
Interest rate, 
credit spread, equity 

Interest rate 
Interest rate, 
foreign exchange 
Interest rate, 
foreign exchange 
Interest rate 
Interest rate 

(1)  Primarily comprises balance sheet items that are subject to the trading and underwriting risk management framework and recorded at fair value through profit or loss. 
(2)  Primarily comprises balance sheet items that are subject to the structural balance sheet insurance risk management framework and secured financing transactions. 

Certain comparative figures have been reclassified to conform with the current year’s presentation. 

Material presented in a blue-tinted font above is an integral part of Note 5 to the 2021 audited annual consolidated financial statements. 

96  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
M
D
&
A

Insurance Risk 

Insurance risk is the potential for loss as a result of actual experience differing from that assumed when an insurance product was designed and 
priced, and comprises claims risk, policyholder behaviour risk and expense risk. 

Insurance risk generally entails the inherent unpredictability that can arise from the assumption of long-term policy liabilities or from uncertainty regarding 
future events. Insurance provides protection against the financial consequences of insured risks by transferring those risks to the insurer (under specific 
terms and conditions) in exchange for premiums. Insurance risk is inherent in all of our insurance products: life insurance, annuities (which includ e the  
pension risk transfer business), accident and sickness insurance, and creditor insurance, as well as the reinsurance business. Insurance risk consists of: 
•   Claims risk – the risk that the actual magnitude or frequency of claims will differ from those assumed in the pricing or underwriting process, 

including mortality risk, morbidity risk, longevity risk and catastrophe risk; 

•   Policyholder behaviour risk – the risk that the behaviour of policyholders in regard to premium payments, withdrawals or loans, policy lapses 

and surrenders, and other voluntary terminations will differ from the behaviour assumed in the pricing process; and 

•   Expense risk – the risk that actual expenses arising from acquiring and administering policies and processing claims will exceed the expenses 

assumed in the pricing process. 

Our risk governance practices provide effective independent oversight and control of risk within BMO Insurance. BMO Insurance’s risk management 
framework addresses the identification, assessment, management and reporting of risks. The framework includes: the Risk Appetite Statement and 
key risk metrics; insurance risk policies and processes, including limits; capital requirements; stress testing; risk reports; the Own Risk and Solvency 
Assessment; and ongoing monitoring of experience. Senior management within the various lines of business uses this framework as the first line of 
defence, and has the primary responsibility for managing insurance risk. Second-line-of-defence oversight is provided by the CRO, BMO Insurance, 
who reports to the Head of Market Risk and Chief Risk Officer, BMO Capital Markets. Internal risk committees, the boards of directors of the BMO 
Insurance subsidiaries and senior management provide senior governance and review. In particular, the Risk Committee of BMO Insurance oversees 
and reports on risk management activities on a quarterly basis to the insurance companies’ boards of directors. In addition, the Audit and Conduct 
Review Committee of the Board acts as the Audit and Conduct Review Committee for BMO Life Insurance Company. 

A robust product approval process is a cornerstone of the BMO Insurance risk management framework, as it identifies, assesses and mitigates 

risks associated with new insurance products or changes to existing products. This process, along with guidelines and practices for underwriting and 
claims management, promotes the effective identification, assessment and management of insurance risk. Reinsurance transactions that transfer 
insurance risk from BMO Insurance to independent reinsurance companies also mitigate exposure to insurance risk by diversifying risk and limiting 
claims. BMO Insurance has exited the Property & Casualty Reinsurance market, with the last remaining treaty having terminated in January 2021, and 
this has significantly reduced our exposure to catastrophic claims. However, a certain portion of our exposure to the risk of catastrophic claims 
remains as the portfolio runs off and until all outstanding claims that were made prior to the treaty termination dates are settled and paid. 

Given that much of the life insurance portfolio is reinsured and that we have a well-balanced portfolio of life insurance products and annuities 
forming a natural hedge for exposures to insurance risk, claims related to the COVID-19 pandemic have not had a material impact on BMO Insurance’s 
financial results to date. As part of our overall Risk Management Framework within BMO Insurance, claims related to the COVID-19 pandemic continue 
to be tracked separately from other types of claims. 

Caution 
This Insurance Risk section contains forward-looking statements. Please refer to the Caution Regarding Forward-Looking Statements. 

Liquidity and Funding Risk 

Liquidity and funding risk is the potential for loss if we are unable to meet our financial commitments in a timely manner at reasonable prices 
as they become due. Financial commitments include liabilities to depositors and suppliers, and lending, investment and pledging commitments. 

Managing liquidity and funding risk is integral to maintaining enterprise soundness and safety, depositor confidence and earnings stability. 
It is BMO’s policy to maintain sufficient liquid assets and funding capacity to meet our financial commitments, even in times of stress. 

Liquidity and Funding Risk Governance 
The Corporate Treasury group and the operating groups, as the first line of defence, are responsible for the ongoing identification, assessment and 
management of liquidity and funding risk. The Corporate Treasury group is responsible for monitoring and reporting liquidity and funding risk acros s the  
enterprise, and develops and recommends for approval the Liquidity and Funding Risk Management Framework and the related risk appetite and limits, 
monitors compliance with relevant corporate policies, and assesses the impact of market events on liquidity and funding requirements on an ongoing basis. 

Enterprise Risk and Portfolio Management, as the second line of defence, provides oversight, independent risk assessment and effective 

challenge of liquidity and funding management frameworks, policies, limits, monitoring and reporting across the enterprise. 

The Risk Management Committee (RMC) and Balance Sheet Committee (BSC) provide senior management oversight and also review and discuss 

significant liquidity and funding policies, issues and developments that arise in the pursuit of BMO’s strategic priorities. The Risk Review Committee 
(RRC) provides oversight of the management of liquidity and funding risk, annually approves the applicable policies, limits and contingency plan, and 
regularly reviews liquidity and funding positions. 

Material presented in a blue-tinted font above is an integral part of Note 5 to the 2021 audited annual consolidated financial statements. 

BMO Financial Group 204th Annual Report 2021  97 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Liquidity and Funding Risk Management 
BMO’s Liquidity and Funding Risk Management Framework is defined and authorized under Board-approved corporate policies and management-
approved standards. These policies and standards set out key management principles, liquidity and funding metrics and related limits, as well as roles 
and responsibilities for the management of liquidity and funding risk across the enterprise. 

We have a robust limit structure in place in order to manage liquidity and funding risk. Limits define the risk appetite for the key Stress Net 
Liquidity Position (Stress NLP) measure, regulatory liquidity ratios, secured and unsecured funding appetite (for both trading and structural activities), 
and enterprise collateral pledging. Limits also establish the tolerance for concentrations of maturities, as well as requirements for counterparty 
liability diversification, business pledging activity, and the size and type of uncommitted and committed credit and liquidity facilities that may be 
outstanding. 

Operating within these limits helps to confirm that liquidity and funding risk is appropriately managed. An enterprise-wide contingency plan 

designed to facilitate effective management in the event of a disruption is also in place. Early warning indicators identified in the contingency plan 
are regularly monitored in order to detect any signs of rising levels of liquidity or funding risk in the market, or other risks specific to BMO. 

BMO legal entities include regulated and foreign subsidiaries and branches, and as a result, movements of funds between entities in the 

A
&
D
M

corporate group are subject to, among other things, the liquidity, funding and capital adequacy requirements of these entities. As such, liquidity and 
funding positions are managed on both a consolidated and key legal entity basis. Liquidity and funding risk management policies and limits, which 
are informed by the laws and regulations that apply to each entity, are in place for key legal entities, and positions are regularly reviewed at the key 
legal entity level to confirm compliance with applicable laws and regulations. 

We managed liquidity and funding risk appropriately during 2021, as customer deposit flows were robust throughout the year, while loan 
volumes increased in the second half of the year, reflecting an increase in our customers’ borrowing activities. Our liquidity metrics, including the 
Liquidity Coverage Ratio (LCR) and Net Stable Funding Ratio (NSFR), exceeded internal and regulatory requirements throughout 2021. 

Liquidity and Funding Risk Measurement 
A key component of liquidity risk management is the measurement of liquidity risk under stress. We use Stress NLP as a key measure of liquidity risk. 
Stress NLP represents the amount by which liquid assets exceed potential funding needs under a severe combined enterprise-specific and systemic 
stress scenario. Potential funding needs may arise from obligations to repay retail, commercial and wholesale deposits that are withdrawn or not 
renewed, or to fund drawdowns on available credit and liquidity lines, as well as from obligations to pledge collateral due to ratings downgrades or 
market volatility, along with the continuing need to fund new assets and strategic investments. Potential funding needs are quantified by applying 
factors to various business activities based on management’s view of the relative level of liquidity risk related to each activity. These factors var y by  
deposit or classification (e.g., retail, small business, non-financial corporate or wholesale counterparties) and deposit type (e.g., insured, uninsured, 
operational or non-operational deposits), as well as by commitment type (e.g., uncommitted or committed credit or liquidity facilities by counterparty 
type). The stress scenario also considers the time horizon over which liquid assets can be monetized and management’s assessment of the liquidity 
value of those assets under conditions of market stress. These funding needs are assessed under severe systemic and enterprise-specific stress 
scenarios, and a combination thereof. 

Stress testing results are evaluated against our stated risk tolerance and are considered in management decisions on limit-setting and internal 
liquidity transfer pricing, and they also help to inform and shape the design of business plans and contingency plans. The Liquidity and Funding Risk 
Management Framework is integrated with enterprise-wide stress testing. 

In addition to Stress NLP, we regularly monitor positions in relation to the limits and liquidity ratios noted in the Liquidity and Funding Risk 

Management section above. These include regulatory metrics such as the LCR, Net Cumulative Cash Flow and NSFR. 

Unencumbered Liquid Assets 
Unencumbered liquid assets include high-quality assets that are marketable, can be pledged as security for borrowings, and can be converted to cash 
in a time frame that meets liquidity and funding requirements. Liquid assets are primarily held in our trading businesses, as well as in supplemental 
liquidity pools that are maintained for contingent liquidity risk management purposes. The liquidity value recognized for different asset classes under 
BMO’s risk management framework reflects management’s assessment of the liquidity value of those assets under a severe stress scenario. Liquid 
assets held in our trading businesses include cash on deposit with central banks, short-term deposits with other financial institutions, highly-rated 
debt securities, equity securities and short-term reverse repurchase agreements. Supplemental liquidity pool assets predominantly comprise cas h on  
deposit with central banks, securities and short-term reverse repurchase agreements of highly-rated Canadian federal and provincial government debt 
and U.S. federal government and agency debt. Substantially all supplemental liquidity pool assets meet the definition of high-quality liquid assets 
under Basel III. Approximately 65% of the supplemental liquidity pool is held at the parent bank level in assets denominated in Canadian dollars or 
U.S. dollars, with the majority of the remaining supplemental liquidity pool held at our U.S. bank entity, BMO Harris Bank, in U.S.-dollar-denominated 
assets. The size of the supplemental liquidity pool is integrated with our assessment of liquidity risk. To meet local regulatory requirements, certain 
legal entities maintain their own minimum liquidity positions. There may be legal and regulatory restrictions on BMO’s ability to use liquid assets held 
at one legal entity to support the liquidity requirements of another legal entity. 

In the ordinary course of business, we may encumber a portion of cash and securities holdings as collateral in support of trading activities and 
participation in clearing and payment systems in Canada and abroad. In addition, we may receive liquid assets as collateral and may re-pledge these 
assets in exchange for cash or as collateral in support of trading activities. Net unencumbered liquid assets, defined as on-balance sheet assets, such 
as BMO-owned cash and securities and securities borrowed or purchased under resale agreements, plus other off-balance sheet eligible collateral 
received, less collateral encumbered, totalled $317.3 billion as at October 31, 2021, compared with $306.1 billion as at October 31, 2020. The increase 
in unencumbered liquid assets was primarily due to higher cash balances, partially offset by lower securities balances. Net unencumbered liquid 
assets are primarily held at the parent bank level, at BMO Harris Bank, and in our broker/dealer operations. In addition to liquid assets, we have 
access to the Bank of Canada’s lending assistance programs, the Federal Reserve Bank discount window in the United States, and European Central 
Bank standby liquidity facilities. We do not rely on central bank facilities as a source of available liquidity when assessing the soundness of our 
liquidity position. 

Material presented in a blue-tinted font above is an integral part of Note 5 to the 2021 audited annual consolidated financial statements. 

98  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
In addition to cash and securities holdings, we may also pledge other assets, including mortgages and loans, to raise long-term secured funding. 
As part of the Liquidity and Funding Risk Management Framework, a Pledging of Assets Corporate Policy sets out the framework and pledging limits 
for financial and non-financial assets. 

BMO’s total encumbered assets and unencumbered liquid assets are summarized in the table below. Refer to Note 24 of the consolidated 

financial statements for further information on pledged assets. 

Liquid Assets 

(Canadian $ in millions) 

Cash and cash equivalents 
Deposits with other banks 
Securities and securities borrowed or purchased under resale agreements 

Sovereigns / Central banks / Multilateral development banks 
NHA mortgage-backed securities and U.S. agency mortgage-backed 
securities and collateralized mortgage obligations 
Corporate and other debt 
Corporate equity 

Total securities and securities borrowed or purchased under 

resale agreements 

NHA mortgage-backed securities (reported as loans at amortized cost) (3) 

Total liquid assets 

As at October 31, 2021 

As at October 31, 2020 

Bank-owned 
assets 

93,261 
8,303 

Other cash 
and securities 
received 

Total gross 
assets (1) 

Encumbered 
assets 

Net 
unencumbered 
assets (2) 

– 
– 

93,261 
8,303 

110 
– 

93,151 
8,303 

Net 
unencumbered 
assets (2) 

57,297 
9,035 

95,213 

98,488  193,701 

117,291 

76,410 

105,295 

54,757 
22,557 
60,322 

60,398 
5,641 
21,513 
44,070 
55,063  115,385 

19,976 
8,740 
66,876 

40,422 
35,330 
48,509 

232,849 
19,645 

180,705  413,554 
19,645 

– 

212,883 
4,519 

200,671 
15,126 

354,058 

180,705  534,763 

217,512 

317,251 

M
D
&
A

36,844 
33,985 
47,465 

223,589 
16,199 

306,120 

(1)  Gross assets include bank-owned assets and cash and securities received from third parties. 
(2)  Net unencumbered liquid assets are defined as total gross assets less encumbered assets. 
(3)  Under IFRS, National Housing Act (NHA) mortgage-backed securities that include mortgages owned by BMO as the underlying collateral are classified as loans. Unencumbered NHA mortgage-backed 
securities have liquidity value and are included as liquid assets under BMO’s Liquidity and Funding Management Framework. This amount is shown as a separate line item, NHA mortgage-backed 
securities. 

Asset Encumbrance 

(Canadian $ in millions) 
As at October 31, 2021 

Cash and deposits with other banks 
Securities (5) 
Loans 
Other assets 

Derivative instruments 
Customers’ liability under acceptances 
Premises and equipment 
Goodwill 
Intangible assets 
Current tax assets 
Deferred tax asset 
Other assets 

Total other assets 

Total assets 

(Canadian $ in millions) 
As at October 31, 2020 

Cash and deposits with other banks 
Securities (5) 
Loans 
Other assets 

Derivative instruments 
Customers’ liability under acceptances 
Premises and equipment 
Goodwill 
Intangible assets 
Current tax assets 
Deferred tax asset 
Other assets 

Total other assets 

Total assets 

Total gross 
assets (1) 

101,564 
433,199 
438,617 

36,713 
14,021 
4,454 
5,378 
2,266 
1,588 
1,287 
22,411 

88,118 

Encumbered (2) 

Net unencumbered 

Pledged as 
collateral 

Other 
encumbered 

Other 
unencumbered (3) 

Available as 
collateral (4) 

– 
180,955 
53,485 

110 
36,447 
1,171 

– 
13,064 
238,283 

101,454 
202,733 
145,678 

– 
– 
– 
– 
– 
– 
– 
6,436 

6,436 

– 
– 
– 
– 
– 
– 
– 
– 

– 

36,713 
14,021 
4,454 
5,378 
2,266 
1,588 
1,287 
15,975 

81,682 

– 
– 
– 
– 
– 
– 
– 
– 

– 

1,061,498 

240,876 

37,728 

333,029 

449,865 

Total gross 
assets (1) 

66,443 
425,777 
425,100 

36,815 
13,493 
4,183 
6,535 
2,442 
1,260 
1,473 
23,059 

89,260 

Encumbered (2) 

Net unencumbered 

Pledged as 
collateral 

Other 
encumbered 

Other 
unencumbered (3) 

Available as 
collateral (4) 

– 
149,955 
58,168 

111 
36,034 
806 

– 
12,766 
227,830 

66,332 
227,022 
138,296 

– 
– 
– 
– 
– 
– 
– 
6,344 

6,344 

– 
– 
– 
– 
– 
– 
– 
– 

– 

36,815 
13,493 
4,183 
6,535 
2,442 
1,260 
1,473 
16,715 

82,916 

– 
– 
– 
– 
– 
– 
– 
– 

– 

1,006,580 

214,467 

36,951 

323,512 

431,650 

(1)  Gross assets include on-balance sheet and off-balance sheet assets. 
(2)  Pledged as collateral refers to the portion of on-balance sheet assets and other cash and securities that is pledged through repurchase agreements, securities lending, derivative contracts, minimum 
required deposits at central banks, and requirements associated with participation in clearing houses and payment systems. Other encumbered assets include assets that are restricted for legal or 
other reasons, such as restricted cash and short sales. 

(3)  Other unencumbered assets include select liquid asset holdings that management believes are not readily available to support BMO’s liquidity requirements. These include securities of $13.1 billion 

as at October 31, 2021, which include securities held at BMO’s insurance subsidiary, significant equity investments and certain investments held at BMO’s merchant banking business. Other 
unencumbered assets include mortgages and loans that may be securitized to access secured funding. 

(4)  Loans included in available as collateral represent loans currently lodged at central banks that could potentially be used to access central bank funding. Loans available for pledging as collateral do not 

include other sources of additional liquidity that may be realized from BMO’s loan portfolio, such as incremental securitization, covered bond issuances and FHLB advances. 

(5)  Includes securities, securities borrowed or purchased under resale agreements and NHA mortgage-backed securities (reported as loans at amortized cost). 

Certain comparative figures have been reclassified to conform with the current year’s presentation. 

Material presented in a blue-tinted font above is an integral part of Note 5 to the 2021 audited annual consolidated financial statements. 

BMO Financial Group 204th Annual Report 2021  99 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Funding Strategy 
BMO’s funding strategy requires that secured and unsecured wholesale funding used to support loans and less liquid assets must have a term (typically 
maturing in two to ten years) that will support the effective term to maturity of these assets. Secured and unsecured wholesale funding for liquid 
trading assets is largely shorter term (maturing in one year or less), is aligned with the liquidity of the assets being funded, and is subject to limits 
on aggregate maturities that are permitted across different periods. Supplemental liquidity pools are funded largely with wholesale term funding. 

We maintain a large and stable base of customer deposits that, in combination with our strong capital base, is a source of strength. This supports 

the maintenance of a sound liquidity position and reduces reliance on wholesale funding. Customer deposits totalled $498.9 billion as at 
October 31, 2021, increasing from $468.0 billion in 2020, with strong growth across both retail and commercial deposits. We also receive 
non-marketable deposits from corporate and institutional customers in support of certain trading activities. These deposits totalled $26.0 billion 
as at October 31, 2021, an increase from $22.8 billion as at October 31, 2020. 

A
&
D
M

Customer Deposits and 
Capital-to-Customer Loans 
Ratio  (%) 

120.0 

124.8 

102.1 

Customer Deposits 
($ billions) 

468 

499

379 

2019 

2020 

2021 

2019 

2020 

2021 

Our large customer base and 
strong capital position reduce 
our reliance on wholesale 
funding. 

Customer deposits provide a 
strong funding base. 

Total secured and unsecured wholesale funding outstanding, which largely consists of negotiable marketable securities, was $190.4 billion as at 

October 31, 2021, with $48.8 billion sourced as secured funding and $141.6 billion sourced as unsecured funding. Total wholesale funding outstanding 
was largely unchanged from the prior year. The mix and maturities of BMO’s wholesale term funding are outlined later in this section. Additional 
information on deposit maturities can be found. We maintain a sizeable portfolio of unencumbered liquid assets, totalling $317.3 billion as at 
October 31, 2021 and $306.1 billion as at October 31, 2020, that can be monetized to meet potential funding requirements, as described in the 
Unencumbered Liquid Assets section. 

Wholesale Funding Maturities (1) 

As at October 31, 2021 

As at October 31, 2020 

(Canadian $ in millions) 

Deposits from banks 
Certificates of deposit and commercial paper 
Bearer deposit notes 
Asset-backed commercial paper (ABCP) 
Senior unsecured medium-term notes 
Senior unsecured structured notes (2) 
Covered bonds and securitizations 

Mortgage and HELOC securitizations 
Covered bonds 
Other asset-backed securitizations (3) 

Subordinated debt 

Less than 
1 month 

1 to 3  
months 

3 to 6  
months 

6 to 12
months 

 Subtotal less 
than 1 year 

1 to 2  
years 

Over 
2 years 

2,861 
6,812 
705 
– 
1,430 
– 

– 
– 
– 
– 

463 
18,006 
659 
– 
593 
– 

352 
2,166 
1,313 
– 

95 
22,399 
1,000 
– 
4,923 
2 

1,275 
– 
– 
– 

2 
24,650 
– 
– 
5,079 
– 

892 
3,596 
73 
– 

3,421 
71,867 
2,364 
– 
12,025 
2 

2,519 
5,762 
1,386 
– 

– 
31 
– 
– 
11,292 
65 

4,466 
10,677 
2,019 
– 

– 
– 
– 
– 
28,520 
5,115 

13,143 
6,966 
1,911 
6,892 

Total 

3,421 
71,898 
2,364 
– 
51,837 
5,182 

20,128 
23,405 
5,316 
6,892 

Total 

6,760 
59,298 
2,502 
3,167 
56,480 
3,221 

20,394 
24,632 
6,255 
8,416 

Total 

Of which: 
Secured 
Unsecured 

Total (4) 

11,808 

23,552 

29,694 

34,292 

99,346 

28,550 

62,547  190,443 

191,125 

– 
11,808 

3,831 
19,721 

1,275 
28,419 

4,561 
29,731 

9,667 
89,679 

17,162 
11,388 

48,849 
22,020 
40,527  141,594 

11,808 

23,552 

29,694 

34,292 

99,346 

28,550 

62,547  190,443 

54,448 
136,677 

191,125 

(1)  Wholesale unsecured funding primarily includes funding raised through the issuance of marketable, negotiable instruments. Wholesale funding excludes deposits and covered bonds issued to access 
central bank programs, repo transactions and bankers’ acceptances, which are disclosed in the Contractual Maturities of Assets and Liabilities and Off-Balance Sheet Commitments section, and also 
excludes ABCP issued by certain ABCP conduits that are not consolidated for financial reporting purposes. Effective Q4-2021, one of the ABCP conduits that we had previously consolidated is no longer 
consolidated and therefore is not included in this table. 

(2)  Primarily issued to institutional investors. 
(3)  Includes credit card, auto and transportation finance loan securitizations. 
(4)  Total wholesale funding consists of Canadian-dollar-denominated funding totalling $47.3 billion and U.S.-dollar-denominated and other foreign-currency-denominated funding totalling $143.1 billion 

as at October 31, 2021. 

Material presented in a blue-tinted font above is an integral part of Note 5 to the 2021 audited annual consolidated financial statements. 

100  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Diversification of our wholesale term funding sources is an important part of our overall liquidity management strategy. Our wholesale term 
funding activities are well-diversified by jurisdiction, currency, investor segment, instrument type and maturity profile. We maintain ready access 
to long-term wholesale funding through various borrowing programs, including a European Note Issuance Program, Canadian, Australian and U.S. 
Medium-Term Note programs, Canadian and U.S. mortgage securitizations, Canadian credit card loans, auto loans and home equity line of credit 
(HELOC) securitizations, U.S. transportation finance loans, covered bonds, and Canadian and U.S. senior unsecured deposits. 

Wholesale Capital Market Term Funding Composition (%) 

2021 

2020 

33% 

23% 

25% 

19% 

31% 

24% 

21% 

24%

Covered Bonds 
Mortgage, Credit Card, Auto Loan, TF and HELOC Securitization, and FHLB Advances 
Senior Debt (Canadian dollar) 
Senior Debt (Global issuances) 

M
D
&
A

Our wholesale term funding plan seeks to ensure sufficient funding capacity is available to execute business strategies. The funding plan 
considers expected maturities, as well as asset and liability growth projected for businesses in our forecasting and planning processes, and assesses 
funding needs in relation to the sources available. The funding plan is reviewed annually by the BSC and RMC and approved by the RRC, and is 
regularly updated to reflect actual results and incorporate updated forecast information. 

In April 2018, the Government of Canada published the final regulations on Canada’s Bank Recapitalization (Bail-In) Regime, which became 

effective on September 23, 2018. Bail-in debt includes senior unsecured debt issued directly by BMO, on or after September 23, 2018, that has an 
original term greater than 400 days and is marketable, subject to certain exceptions. We are required to meet minimum Total Loss Absorbing Capacity 
(TLAC) Ratio requirements effective November 1, 2021. Our TLAC Ratio exceeds the regulatory minimum as at October 31, 2021. For more information 
on Canada’s Bail-In Regime and TLAC requirements, refer to Regulatory Capital Developments under Enterprise-Wide Capital Management. 

Credit Ratings 
The credit ratings assigned to BMO’s short-term and senior long-term debt securities by external rating agencies are important for the bank in 
raising both capital and funding to support its business operations. Maintaining strong credit ratings allows us to access the wholesale markets at 
competitive pricing levels. Should BMO’s credit ratings experience a downgrade, our cost of funding would likely increase and our access to funding 
and capital through the wholesale markets could be reduced. A material downgrade of BMO’s ratings could also have other consequences, including 
those set out in Note 8 of the consolidated financial statements. 

The credit ratings assigned to BMO’s senior debt by rating agencies are indicative of high-grade, high-quality issues. During the third quarter of 
fiscal 2021, Moody’s, Standard & Poor’s (S&P), DBRS and Fitch affirmed their ratings for BMO. Moody’s, S&P and DBRS have a stable outlook on BMO 
and Fitch has a negative outlook. 

As at October 31, 2021 

Rating agency 

Moody’s 
S&P 
Fitch 
DBRS 

Short-term debt 

Senior debt (1) 

P-1 
A-1 
F1+ 
R-1 (high) 

A2 
A-
AA-
AA (low) 

Long-term deposits / 
Legacy senior debt (2) 

Subordinated 
debt (NVCC) 

Aa2 
A+ 
AA 
AA 

Baa1(hyb) 
BBB+ 
A 
A (low) 

Outlook 

Stable 
Stable 
Negative 
Stable 

(1)  Subject to conversion under the Bank Recapitalization (Bail-In) Regime. 
(2)  Long-term deposits / Legacy senior debt includes senior debt issued prior to September 23, 2018 and senior debt issued on or after September 23, 2018 that is excluded from the Bank 

Recapitalization (Bail-In) Regime. 

We are required to deliver collateral to certain counterparties in the event of a downgrade of BMO’s current credit rating. The incremental collateral 
required is based on mark-to-market exposure, collateral valuations and collateral threshold arrangements, as applicable. As at October 31, 2021, 
we would be required to provide additional collateral to counterparties totalling $142 million, $354 million and $762 million as a result of a 
one-notch, two-notch and three-notch downgrade, respectively. 

BMO Financial Group 204th Annual Report 2021  101 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Liquidity Coverage Ratio 
The Liquidity Coverage Ratio (LCR) is calculated in accordance with OSFI’s Liquidity Adequacy Requirements Guideline and is summarized in the 
following table. The average daily LCR for the quarter ended October 31, 2021 was 125%. The LCR is calculated on a daily basis as the ratio of the 
stock of High-Quality Liquid Assets (HQLA) held to total net stressed cash outflows over the next 30 calendar days. The average daily LCR in fiscal 
2021 decreased from 131% in the fourth quarter of the prior year, primarily due to a decrease in HQLA and higher net cash outflows. While banks 
are required to maintain an LCR greater than 100% in normal conditions, they are also expected to be able to utilize HQLA during a period of stress, 
which may result in an LCR of less than 100% during such a period. BMO’s HQLA primarily comprise cash, highly-rated debt issued or backed by 
governments, highly-rated covered bonds and non-financial corporate debt, and non-financial equities that are part of a major stock index. 
Net cash flows include outflows from deposits, secured and unsecured wholesale funding, commitments and potential collateral requirements, offset 
by permitted inflows from loans, securities lending activities and other non-HQLA debt maturing over a 30-day horizon. Weightings prescribed by 
the Office of the Superintendent of Financial Institutions (OSFI) are applied to cash flows and HQLA to arrive at the weighted values and the LCR. 
The LCR is only one measure of a bank’s liquidity position and does not fully capture all of its liquid assets or the funding alternatives that may be 
available during a period of stress. BMO’s total liquid assets are shown in the Liquid Assets table. 

A
&
D
M

(Canadian $ in billions, except as noted) 

High-Quality Liquid Assets 
Total high-quality liquid assets (HQLA) 

Cash Outflows 
Retail deposits and deposits from small business customers, of which: 

Stable deposits 
Less stable deposits 

Unsecured wholesale funding, of which: 

Operational deposits (all counterparties) and deposits in networks of cooperative banks 
Non-operational deposits (all counterparties) 
Unsecured debt 

Secured wholesale funding 
Additional requirements, of which: 

Outflows related to derivatives exposures and other collateral requirements 
Outflows related to loss of funding on debt products 
Credit and liquidity facilities 

Other contractual funding obligations 
Other contingent funding obligations 

Total cash outflows 

Cash Inflows 
Secured lending (e.g., reverse repos) 
Inflows from fully performing exposures 
Other cash inflows 

Total cash inflows 

Total HQLA 
Total net cash outflows 

Liquidity Coverage Ratio (%) 

For the quarter ended October 31, 2020 

Total HQLA 
Total net cash outflows 

Liquidity Coverage Ratio (%) 

For the quarter ended October 31, 2021 

Total unweighted value 
(average) (1) (2) 

Total weighted value 
(average) (2) (3) 

* 

231.3 
114.3 
117.0 
259.2 
128.9 
103.1 
27.2 
* 
178.8 
11.7 
1.9 
165.2 
1.2 
425.0 

* 

138.9 
8.6 
10.6 

158.1 

194.4 

15.4 
3.4 
12.0 
124.0 
32.1 
64.7 
27.2 
22.5 
34.7 
4.4 
1.9 
28.4 
– 
8.1 

204.7 

33.4 
4.7 
10.6 

48.7 

Total adjusted value (4) 

194.4 
156.0 

125 

Total adjusted value (4) 

197.5 
150.7 

131 

* Disclosure is not required under the LCR disclosure standard. 
(1)  Unweighted values are calculated at market value (for HQLA) or as outstanding balances maturing or callable within 30 days (for inflows and outflows). 
(2)  Values are calculated based on the simple average of the daily LCR over 61 business days in the fourth quarter of 2021. 
(3)  Weighted values are calculated after the application of the weightings prescribed under the OSFI Liquidity Adequacy Requirements (LAR) Guideline for HQLA and cash inflows and outflows. 
(4)  Adjusted values are calculated based on total weighted values after applicable caps, as defined in the LAR Guideline. 

102  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Net Stable Funding Ratio 
The Net Stable Funding Ratio (NSFR) is a regulatory liquidity metric that assesses the stability of a bank’s funding profile in relation to the liquidity 
value of its assets and is calculated in accordance with OSFI’s Liquidity Adequacy Requirements Guideline. The NSFR is defined as the ratio between 
the amount of available stable funding (ASF) and the amount of required stable funding (RSF). ASF represents the proportion of own and third-party 
resources that are expected to be reliably available over a one-year horizon (including customer deposits and long-term wholesale funding). Unlike 
the LCR, which is a short-term metric, the NSFR assesses a bank’s medium-term and long-term resilience. The stable funding requirements for each 
institution are set by OSFI based on the liquidity and maturity characteristics of its balance sheet assets and off-balance sheet exposures. Weightings 
prescribed by OSFI are applied to notional asset and liability balances to determine ASF and RSF and the NSFR. Canadian domestic systemically 
important banks (D-SIBs), including BMO, are required to maintain a minimum NSFR of 100%, effective January 1, 2020, and to publicly disclose 
their NSFR, effective in the quarter ended January 31, 2021. BMO’s NSFR was 118% as at October 31, 2021, exceeding the regulatory minimum. 

(Canadian $ in billions, except as noted) 

Available Stable Funding (ASF) Item 
Capital: 

Regulatory capital 
Other capital instruments 

Retail deposits and deposits from small business customers: 

Stable deposits 
Less stable deposits 

Wholesale funding: 

Operational deposits 
Other wholesale funding 

Liabilities with matching interdependent assets 
Other liabilities: 

NSFR derivative liabilities 
All other liabilities and equity not included in the above categories 

Total ASF 

Required Stable Funding (RSF) Item 
Total NSFR high-quality liquid assets (HQLA) 
Deposits held at other financial institutions for operational purposes 
Performing loans and securities: 

Performing loans to financial institutions secured by Level 1 HQLA 
Performing loans to financial institutions secured by non-Level 1 HQLA and unsecured 

M
D
&
A

For the quarter ended October 31, 2021 

Unweighted value by residual maturity 

No 
maturity (1) 

Less than 6 
months 

6 to 12  
months  Over 1 year 

Weighted 
value (2) 

– 
– 
– 
211.3 
105.4 
105.9 
237.8 
131.4 
106.4 
– 
2.0 
* 
2.0 

* 

* 
– 
147.1 
– 

– 
– 
– 
28.4 
13.9 
14.5 
184.9 
– 
184.9 
1.6 
* 
* 
32.6 

* 

* 
– 
133.4 
50.8 

– 
– 
– 
12.1 
6.1 
6.0 
39.3 
– 
39.3 
0.9 
* 
* 
0.2 

* 

* 
– 
46.0 
1.9 

65.2 
65.1 
0.1 
31.0 
6.3 
24.7 
72.3 
– 
72.3 
14.3 
45.8 
8.1 
4.9 

* 

* 
– 
251.8 
– 

65.2 
65.1 
0.1 
263.2 
125.4 
137.8 
201.8 
65.7 
136.1 
– 
5.0 
* 
5.0 

535.2 

22.9 
– 
372.2 
3.5 

performing loans to financial institutions 

24.3 

51.0 

7.7 

10.8 

44.7 

Performing loans to non-financial corporate clients, loans to retail and small business 

customers, and loans to sovereigns, central banks and PSEs, of which: 
With a risk weight of less than or equal to 35% under the Basel II standardized approach for 

credit risk 

Performing residential mortgages, of which: 

With a risk weight of less than or equal to 35% under the Basel II standardized approach for 

credit risk 

Securities that are not in default and do not qualify as HQLA, including exchange-traded equities 

Assets with matching interdependent liabilities 
Other assets: 

Physical traded commodities, including gold 
Assets posted as initial margin for derivative contracts and contributions to default funds 

of CCPs 

NSFR derivative assets 
NSFR derivative liabilities before deduction of variation margin posted 
All other assets not included in the above categories 
Off-balance sheet items 

Total RSF 

Net Stable Funding Ratio (%) 

87.0 

25.6 

25.0 

119.0 

196.7 

– 
12.6 

12.6 
23.2 
– 
15.7 
3.4 

* 
* 
* 
12.3 
* 

* 

*

– 
5.0 

4.7 
1.0 
1.6 
* 
* 

* 
* 
* 
2.4 
* 

* 

 *

– 
11.3 

11.0 
0.1 
0.9 
* 
* 

* 
* 
* 
0.2 
* 

* 

 *

– 
111.2 

108.5 
10.8 
14.3 
36.3 
* 

10.6 
9.8 
0.6 
12.7 
469.7 

– 
97.9 

95.0 
29.4 
– 
41.7 
2.9 

9.0 
1.7 
0.6 
27.5 
16.6 

* 

 *

453.4 

 118

* Disclosure is not required under the NSFR disclosure standard. 
(1)  Items to be reported in the “no maturity” column do not have a stated maturity. These may include, but are not limited to, items such as non-maturity deposits, short positions, open maturity 

positions, non-HQLA equities, physical traded commodities and demand loans. 

(2)  Weighted values are calculated after the application of the weights prescribed under the OSFI LAR Guideline for ASF and RSF. 

BMO Financial Group 204th Annual Report 2021  103 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
A
&
D
M

MANAGEMENT’S DISCUSSION AND ANALYSIS 

Contractual Maturities of Assets and Liabilities and Off-Balance Sheet Commitments 
The tables below show the remaining contractual maturities of on-balance sheet assets and liabilities and off-balance sheet commitments. 
The contractual maturity of financial assets and liabilities is an input to, but is not necessarily consistent with, the expected maturity of assets 
and liabilities that is used in the management of liquidity and funding risk. We forecast asset and liability cash flows, under both normal market 
conditions and a number of stress scenarios, to manage liquidity and funding risk. Stress scenarios include assumptions for loan repayments, deposit 
withdrawals, and credit commitment and liquidity facility drawdowns by counterparty and product type. Stress scenarios also consider the time 
horizon over which liquid assets can be monetized and the related discounts (“haircuts”) and potential collateral requirements that may result from 
both market volatility and credit rating downgrades, among other assumptions. 

(Canadian $ in millions) 

On-Balance Sheet Financial Instruments 
Assets 
Cash and cash equivalents 

Interest bearing deposits with banks 

Securities 

Securities borrowed or purchased under 

resale agreements 

Loans (1) 

Residential mortgages 
Consumer instalment and other personal 
Credit cards 
Business and government 
Allowance for credit losses 

Total loans, net of allowance 

Other Assets 

Derivative instruments 
Customers’ liability under acceptances 
Other 

Total other assets 

Total Assets 

(Canadian $ in millions) 

Liabilities and Equity 
Deposits (2)(3) 

Banks 
Business and government 
Individuals 

Total deposits 

Other liabilities 

0 to 1  
month 

1 to 3  
months 

3 to 6
months 

6 to 9  
months 

9 to 12  
months 

1 to 2  
years 

2 to 5  
years 

Over 
5 years 

No 
maturity 

2021 

Total 

91,736 

3,529 

5,286 

– 

1,440 

4,742 

– 

1,172 

5,116 

– 

1,753 

3,383 

– 

409 

– 

– 

– 

– 

– 

– 

1,525 

93,261 

– 

8,303 

2,692 

17,512 

43,571 

90,225 

60,322 

232,849 

70,080 

22,873 

11,362 

1,602 

766 

699 

– 

– 

– 

107,382 

458 
215 
– 
12,082 
– 

12,755 

2,752 
11,574 
2,002 

16,328 

1,081 
419 
– 
7,667 
– 

2,109 
639 
– 
7,697 
– 

4,373 
1,166 
– 
10,496 
– 

4,879 
1,110 
– 
10,213 
– 

22,170 
5,732 
– 
29,303 
– 

91,146 
31,613 
– 
81,377 
– 

9,396 
13,518 
– 
14,413 
– 

138 
22,752 
8,103 
66,561 
(2,564) 

135,750 
77,164 
8,103 
239,809 
(2,564) 

9,167 

10,445 

16,035 

16,202 

57,205 

204,136 

37,327 

94,990 

458,262 

4,924 
2,428 
461 

7,813 

2,187 
19 
140 

2,346 

1,809 
– 
4 

1,813 

1,634 
– 
3 

1,637 

7,525 
– 
5 

7,530 

8,787 
– 
1 

7,095 
– 
5,097 

– 
– 
29,671 

36,713 
14,021 
37,384 

8,788 

12,192 

29,671 

88,118 

199,714 

46,035 

30,441 

24,586 

21,706 

82,946 

256,495 

139,744 

186,508 

988,175 

0 to 1  
month 

1 to 3  
months 

3 to 6  
months 

6 to 9  
months 

9 to 12  
months 

1 to 2  
years 

2 to 5  
years 

Over 
5 years 

No 
maturity 

2021 

Total 

9,047 
16,894 
3,944 

4,581 
26,861 
6,399 

4,193 
29,665 
8,630 

746 
21,345 
6,766 

389 
16,213 
7,697 

– 
24,249 
9,529 

– 
35,707 
10,022 

26 
17,113 
2,786 

7,629 
254,201 
160,999 

26,611 
442,248 
216,772 

29,885 

37,841 

42,488 

28,857 

24,299 

33,778 

45,729 

19,925 

422,829 

685,631 

Derivative instruments 
Acceptances 
Securities sold but not yet purchased (4) 
Securities lent or sold under repurchase 

agreements (4) 

Securitization and structured entities’ 

2,771 
11,574 
32,073 

3,651 
2,428 
– 

2,379 
19 
– 

1,508 
– 
– 

73,190 

17,199 

3,994 

3,103 

liabilities 

Other 

Total other liabilities 

Subordinated debt 

Total Equity 

21 
10,121 

1,737 
1,632 

129,750 

26,647 

–

– 

 –

– 

1,527 
116 

8,035 

 –

– 

648 
109 

1,444 
– 
– 

70 

486 
162 

5,723 
– 
– 

7,140 
– 
– 

6,199 
– 
– 

– 

– 

– 

– 
– 
– 

– 

30,815 
14,021 
32,073 

97,556 

7,240 
944 

9,791 
1,277 

4,036 
3,509 

– 
20,307 

25,486 
38,177 

5,368 

2,162 

13,907 

18,208 

13,744 

20,307 

238,128 

 –

– 

 –

– 

 –

– 

 25

– 

6,868 

– 

6,893 

– 

57,523 

57,523 

Total Liabilities and Equity 

159,635 

64,488 

50,523 

34,225 

26,461 

47,685 

63,962 

40,537 

500,659 

988,175 

(1)  Loans receivable on demand have been included under no maturity. 
(2)  Deposits payable on demand and payable after notice have been included under no maturity. 
(3)  Deposits totalling $20,991 million as at October 31, 2021 have a fixed maturity date; however, they can be redeemed early (either fully or partially) by customers without penalty. These are classified 

as payable on a fixed date due to their stated contractual maturity date. BMO does not expect a significant amount to be redeemed before maturity. 

(4)  Presented based on their earliest maturity date. 

(Canadian $ in millions) 

Off-Balance Sheet Commitments 
Commitments to extend credit (1) 
Letters of credit (2) 
Backstop liquidity facilities 
Leases 
Securities lending 
Purchase obligations 

0 to 1  
month 

1 to 3  
months 

3 to 6  
months 

6 to 9  
months 

9 to 12  
months 

1 to 2  
years 

2 to 5  
years 

Over 
5 years 

No 
maturity 

2021 

Total 

1,674 
1,196 
189 
–
3,909 
16 

4,935 
4,083 
137 
 –
– 
38 

8,374 
4,358 
293 
 –
– 
47 

13,308 
3,815 
1,073 
 –
– 
44 

14,498 
4,806 
1,578 
 1
– 
60 

33,749 
1,980 
2,709 
 3
– 
139 

99,639 
3,304 
6,088 
 22
– 
217 

4,571 
104 
828 
 222
– 
41 

– 
– 
– 
 –
– 
– 

180,748 
23,646 
12,895 
 248
3,909 
602 

(1)  Commitments to extend credit exclude personal lines of credit and credit cards that are unconditionally cancellable at BMO’s discretion. A large majority of these commitments expire without being 

drawn upon. As a result, the total contractual amounts may not be representative of the funding likely to be required for these commitments. 

(2)  Letters of credit can be drawn down at any time. These are classified based on their stated contractual maturity date. 

Material presented in a blue-tinted font above is an integral part of Note 5 to the 2021 audited annual consolidated financial statements. 

104  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(Canadian $ in millions) 

On-Balance Sheet Financial Instruments 
Assets 
Cash and cash equivalents 

Interest bearing deposits with banks 

Securities 

Securities borrowed or purchased under 

0 to  1  
month 

1 to  3
months 

3 to  6  
months 

6 to  9  
months 

9 to  12  
months 

1 to  2  
years 

2 to  5  
years 

Over 
5 years 

No 
maturity 

2020 

Total 

56,434 

3,901 

4,838 

–

1,673 

5,804 

 –

1,266 

7,817 

 –

1,204 

6,263 

 –

991 

 –

– 

 –

– 

 –

– 

 974

57,408 

– 

9,035 

4,678 

15,730 

54,846 

85,949 

48,335 

234,260 

resale agreements 

79,354 

17,030 

12,111 

2,172 

708 

503 

– 

– 

– 

111,878 

Loans (1) 

Residential mortgages 
Consumer instalment and other personal 
Credit cards 
Business and government 
Allowance for credit losses 

984 
646 
– 
13,708 
– 

2,082 
511 
– 
10,000 
– 

3,500 
963 
– 
9,083 
– 

5,957 
1,107 
– 
15,951 
– 

5,168 
1,014 
– 
9,465 
– 

18,929 
4,642 
– 
34,171 
– 

79,503 
25,538 
– 
76,163 
– 

10,726 
12,211 
– 
14,819 
– 

175 
23,516 
7,889 
62,302 
(3,303) 

127,024 
70,148 
7,889 
245,662 
(3,303) 

Total loans, net of allowance 

15,338 

12,593 

13,546 

23,015 

15,647 

57,742 

181,204 

37,756 

90,579 

447,420 

M
D
&
A

Other Assets 

Derivative instruments 
Customers’ liability under acceptances 
Other 

Total other assets 

Total Assets 

(Canadian $ in millions) 

Liabilities and Equity 
Deposits (2)(3) 

Banks 
Business and government 
Individuals 

Total deposits 

Other liabilities 

3,400 
9,609 
1,873 

14,882 

5,472 
3,633 
580 

9,685 

2,111 
251 
188 

2,550 

1,140 
– 
20 

1,160 

915 
– 
13 

928 

4,369 
– 
16 

4,385 

9,393 
– 
4 

9,397 

10,015 
– 
4,530 

– 
– 
31,728 

36,815 
13,493 
38,952 

14,545 

31,728 

89,260 

174,747 

46,785 

37,290 

33,814 

22,952 

78,360 

245,447 

138,250 

171,616 

949,261 

0 to  1
month 

1 to  3
months 

3 to  6
months 

6 to  9
months 

9 to  12
months 

1 to  2
years 

2 to  5
years 

Over 
5 years 

No 
maturity 

2020 

Total 

13,499 
24,056 
4,295 

3,982 
21,813 
11,509 

13,106 
33,713 
13,019 

455 
13,862 
11,086 

463 
17,567 
10,192 

7 
20,070 
7,778 

– 
45,287 
12,709 

28 
11,129 
2,007 

7,285 
213,182 
146,935 

38,825 
400,679 
219,530 

41,850 

37,304 

59,838 

25,403 

28,222 

27,855 

57,996 

13,164 

367,402 

659,034 

Derivative instruments 
Acceptances 
Securities sold but not yet purchased (4) 
Securities lent or sold under repurchase 

1,374 
9,609 
29,376 

4,499 
3,633 
– 

1,684 
251 
– 

1,171 
– 
– 

1,088 
– 
– 

3,911 
– 
– 

8,588 
– 
– 

8,060 
– 
– 

agreements (4) 

69,142 

10,747 

7,439 

878 

– 

452 

– 

– 

Securitization and structured entities’ 

– 
– 
– 

– 

30,375 
13,493 
29,376 

88,658 

liabilities 

Other 

Total other liabilities 

Subordinated debt 

Total Equity 

30 
10,301 

1,656 
804 

334 
102 

119,832 

21,339 

9,810 

– 

– 

– 

– 

– 

– 

2,810 
109 

4,968 

– 

– 

1,169 
181 

2,438 

– 

– 

4,946 
798 

12,577 
1,326 

3,367 
3,706 

– 
19,100 

26,889 
36,427 

10,107 

22,491 

15,133 

19,100 

225,218 

– 

– 

– 

– 

8,416 

– 

8,416 

– 

56,593 

56,593 

Total Liabilities and Equity 

161,682 

58,643 

69,648 

30,371 

30,660 

37,962 

80,487 

36,713 

443,095 

949,261 

(1)  Loans receivable on demand have been included under no maturity 
(2)  Deposits payable on demand and payable after notice have been included under no maturity. 
(3)  Deposits totalling $27,353 million as at October 31, 2020 have a fixed maturity date; however, they can be redeemed early (either fully or partially) by customers without penalty. These are classified 

as payable on a fixed date due to their stated contractual maturity date. BMO does not expect a significant amount to be redeemed before maturity. 

(4)  Presented based on their earliest maturity date. 

Certain comparative figures have been reclassified to conform with the current year’s presentation. 

(Canadian $ in millions) 

Off-Balance Sheet Commitments 
Commitments to extend credit (1) 
Letters of credit (2) 
Backstop liquidity facilities 
Leases 
Securities lending 
Purchase obligations 

0 to  1  
month 

1 to  3  
months 

3 to  6  
months 

6 to  9  
months 

9 to  12  
months 

1 to  2  
years 

2 to  5  
years 

Over 
5 years 

No 
maturity 

2020 

Total 

1,859 
1,019 
– 
– 
4,349 
14 

5,662 
3,793 
– 
– 
– 
27 

11,251 
4,355 
– 
3 
– 
38 

12,499 
3,708 
– 
3 
– 
38 

14,681 
4,861 
– 
3 
– 
56 

33,239 
2,481 
– 
38 
– 
162 

101,078 
3,849 
5,601 
158 
– 
179 

3,654 
112 
– 
786 
– 
62 

– 
– 
– 
– 
– 
– 

183,923 
24,178 
5,601 
991 
4,349 
576 

(1)  Commitments to extend credit exclude personal lines of credit and credit cards that are unconditionally cancellable at BMO’s discretion. A large majority of these commitments expire without being 

drawn upon. As a result, the total contractual amounts may not be representative of the funding likely to be required for these commitments. 

(2)  Letters of credit can be drawn down at any time. These are classified based on their stated contractual maturity date. 

Certain comparative figures have been reclassified to conform with the current year’s presentation. 

Caution 
This Liquidity and Funding Risk section contains forward-looking statements. Please refer to the Caution Regarding Forward-Looking Statements. 

Material presented in a blue-tinted font above is an integral part of Note 5 to the 2021 audited annual consolidated financial statements. 

BMO Financial Group 204th Annual Report 2021  105 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
A
&
D
M

MANAGEMENT’S DISCUSSION AND ANALYSIS 

Operational Non-Financial Risk 

Operational non-financial risk (ONFR) encompasses a wide range of non-financial risks, including those related to business change, customer 
trust, reputation, and data that can result in financial loss. These losses can stem from inadequate or failed internal processes or systems, human 
error or misconduct, and external events that may directly or indirectly impact our credit or investment portfolios. These risks include technology 
risk, fraud risk, business continuity risk and human resources risk, but exclude legal and regulatory risk, credit risk, market risk, liquidity risk and 
other types of financial risk. 

Operational non-financial risk is inherent in all of our business and banking activities and can lead to significant impacts on our operating and financial 
results, including financial loss, restatements and damage to BMO’s reputation. Like other financial services organizations that operate in multiple 
jurisdictions, we are exposed to a variety of operational risks arising from the potential for failures of our internal processes, technology systems and 
employees, as well as from external threats. Potential losses may result from process and control failures, theft and fraud, unauthorized transactions 
by employees, regulatory non-compliance, business disruption, information security breaches, cyber security threats, exposure to risks related to 
third-party relationships, and damage to physical assets. Given the large volume of transactions that we process on a daily basis, and the complexity 
and speed of our business operations, there is a possibility that certain operational or human errors may be repeated or compounded before they are 
discovered and rectified. 

ONFR is not only inherent in our business and banking activities, it is also inherent in the processes and controls used to manage risks. 

There is the possibility that errors will occur, as well as the possibility that a failure in our internal processes or systems could lead to financial loss 
and reputational harm. Shortcomings or failures of internal processes, systems or employees, or of services and products provided by third parties, 
including any of our financial, accounting or other data processing systems, could lead to financial loss or restatements and damage BMO’s reputation. 
The nature of the business also exposes us to the risk of theft and fraud when we enter into credit transactions with customers or counterparties. 
In extending credit, BMO relies on the accuracy and completeness of any information provided by, and any other representations made by, customers 
and counterparties. While we conduct appropriate due diligence on such customer information and, where practicable and economically feasible, 
engage valuation experts and other experts or sources of information to assist in assessing the value of collateral and other customer risks, our 
financial results may be adversely impacted if the information provided by customers or counterparties is materially misleading and this is not 
discovered during the due diligence process. 

We have established various risk management frameworks to manage and mitigate these risks, including internal controls, limits and 

governance processes. However, despite the contingency plans we have in place to maintain the ability to serve our clients and minimize disruptions 
and adverse impacts, and the contingency plans our third-party service providers have in place, our ability to conduct business may be adversely 
affected by a disruption to the infrastructure that supports both our operations and the communities in which we do business, including but not 
limited to disruption caused by public health emergencies or terrorist acts. 

We regularly review our top and emerging risks, and assess our preparedness to proactively manage the risks we face or could face in the future. 

Consistent with the management of risk across the enterprise, we employ a three-lines-of-defence approach in managing our non-financial risk. 

Refer to the Top and Emerging Risks That May Affect Future Results section for further discussion of these and other risks. 

Operational Non-Financial Risk Governance 
The Operational Risk Committee (ORC), a sub-committee of the Risk Management Committee (RMC), is the primary governance committee exercising 
oversight of all ONFR management matters. As part of its governance responsibilities, the ORC provides effective challenge to the corporate policies, 
standards, directives, operating guidelines, methodologies and tools that comprise the governing principles of the Non-Financial Risk Management 
Framework (NFRMF). The documentation that gives effect to these governing principles is reviewed on a regular basis in order to confirm that it 
incorporates sound governance practices and is consistent with BMO’s risk appetite. Regular analysis and reporting of our enterprise operational risk 
profile to the various committees (ORC, RMC and Risk Review Committee (RRC)) are important elements of our risk governance framework. Enterprise 
operational risk reporting provides an integrated view of top and emerging risks, trends in loss data, capital consumption, key risk indicators and 
operating group profiles. We continue to invest in our reporting platforms and support timely and comprehensive reporting capabilities in order to 
enhance risk transparency and facilitate the proactive management of operational risk exposures. 

Operational Non-Financial Risk Management 
As the first line of defence, the operating groups and Corporate Services, including Technology and Operations, are accountable for the day-to-day 
management of non-financial risk, including the Chief Risk Officers of our businesses, who provide governance and oversight for their respective 
business units, together with Corporate Services, which provides additional governance and oversight in certain targeted areas. Independent risk 
management oversight is provided by the Operational Non-Financial Risk Management (ONFRM) team, which is responsible for ONFR strategy, tools 
and policies, and for second-line oversight, effective challenge and governance. ONFRM establishes and maintains the NFRMF, which defines the 
processes to be used by the first line of defence to identify, assess, manage, mitigate, monitor and report on key operational risk exposures, losses 
and near-miss operational risk events with significant potential impact. In addition, the NFRMF defines the processes by which ONFRM, as the second 
line of defence, guides, supports, monitors, assesses and communicates with the first line in its management of ONFR. Operational Risk Officers 
within ONFRM independently assess group operational risk profiles, identify material exposures and potential weaknesses in processes and controls, 
and recommend appropriate mitigation strategies and actions. Executing the NFRMF strategy also involves continuing to strengthen our risk culture by 
promoting greater awareness and understanding of non-financial risk across all three lines of defence, learning from loss events and near-misses, and 
providing related training and communication, as well as day-to-day execution and oversight of the NFRMF. We also continue to strengthen our 
second-line-of-defence support and oversight with an enhanced Non-Financial Risk Operating Model, which takes a differentiated approach based 
on the nature of the underlying risk and existing organizational structures. 

Through the implementation and oversight of the NFRMF, we seek to maintain an operational risk profile that is consistent with our risk 

appetite and supported by adequate capital, while continuing to adapt to ongoing changes by focusing on enhanced operational resilience. 
Operational resilience is more than recovery from a disaster, it is the ability to identify and monitor risks in order to either prevent any related 
incidents or minimize their impact. It involves BMO’s ability to deal with unpredictable events and adapt to changes in external circumstances. 

106  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Operational resilience is not a defensive strategy, but a positive, forward-looking strategic posture, which allows us to take measured risks with 
confidence and prepares us to withstand challenges in the market arising from both expected and unexpected events. 

The following are the key programs, methodologies and processes set out in the NFRMF that assist us in the ongoing review of our operational 

risk profile: 
•   Risk Control Self-Assessment is an established process used by our operating groups to identify the key risks associated with their businesses 

and the controls required for risk mitigation. It provides a forward-looking view of the impact of the business environment and internal controls on 
operating group risk profiles, supporting the proactive prevention, mitigation and management of risk. 

•   BMO’s Initiative Assessment and Approval Process (IAAP) is used to assess, document and approve qualifying initiatives when a new business, 
service or product is developed, or existing services and products are enhanced. The process addresses requirements for due diligence, approval, 
monitoring and reporting at all levels of the organization. 

•   Material trends, metrics and risk assessments comprising Key Risk Indicators, Issues Management and Internal Loss Data Events are integral 

components of the operational risk profile and are utilized to assess specific risk exposures in relation to BMO’s overall risk appetite. 

•   Scenario analysis assesses the potential impact of severe negative events on key risks and critical business processes in order to inform risk 

management. Scenarios help management identify and understand the impact of large-scale events, including events that have a low frequency of 
occurrence but a high severity of impact, as well as environmental stresses, and develop mitigation measures or controls that will help manage tail 
risk. 

•   Effective business continuity management prepares us to recover, maintain and manage critical operations and processes in the event of a 

M
D
&
A

business disruption, thereby minimizing any adverse effects on our customers and other stakeholders. 

•   BMO’s Corporate Risk & Insurance team provides a second layer of mitigation for certain operational risk exposures. We purchase insurance 

when required by law, regulation or contractual agreement, and when it is economically attractive and practicable to mitigate our risks, in order 
to provide adequate protection against unexpected material loss. 

The following are examples of ONFR that may adversely affect BMO’s business and financial results. As a result of the COVID-19 pandemic and the 
new remote working arrangements that have emerged for employees and third parties, a number of risks remain elevated, such as cyber security, 
information security and privacy risks. For more information, refer to the Top and Emerging Risks That May Affect Future Results section. 

Cyber Security Risk 
Information security is integral to BMO’s business activities, brand and reputation. As technology rapidly evolves and the connectivity of devices 
expands, cyber threats and risks change. These threats and risks include breaches of, or disruptions to, our systems or operations, as well as 
unauthorized access, use or dissemination of our information or information pertaining to our customers or employees. We continue to build out the 
capabilities of our Financial Crimes Unit, demonstrating a commitment to bringing together cyber defence and fraud and physical security functions. 
In addition, we are enhancing processes to make them more resilient, while strengthening our ability to prevent, detect and recover from cyber 
security threats in order to keep our customers’ and employees’ data secure. We continue to examine and benchmark practices across our peer groups 
and other industries, conduct third-party assessments, develop and evaluate the effectiveness of our key controls, and invest in both technology 
and human resources. We also work with various third-party security and software suppliers to bolster our internal resources and technology 
capabilities in order to strengthen our resiliency in a rapidly evolving threat landscape. 

Technology Disruption and Resiliency 
Technology is the backbone of our operations, and we continue to innovate and invest in enhancing our technological capabilities in order to keep 
customers’ data secure and to meet and exceed their expectations, as the adoption of digital banking continues to grow. In addition to existing 
technology risks, the COVID-19 pandemic has introduced unprecedented challenges and new emerging risks, as our clients, employees and suppliers 
have come to rely on technology platforms and the Internet of Things to manage and support their personal, business and investment banking 
activities. Given the extent to which BMO’s operations rely on technology, it is important to maintain platforms that provide high levels of operational 
reliability and resiliency, particularly with respect to business-critical systems. Technology innovations, such as advanced data management, analytical 
tools and artificial intelligence, are being leveraged to provide insights that will improve the way we do business and serve our customers. 

Third-Party Risk 
BMO continues to use third parties in order to gain rapid access to new technologies, increase efficiencies, and improve competitiveness and 
performance. This increases our reliance on third parties and sub-contractors to effectively deliver products and services to our customers, and 
exposes us to the risk of business disruption and financial loss stemming from the breakdown of processes and controls at third parties and their 
sub-contractors. To manage this risk, we have in place an enterprise-wide risk management program designed to identify, assess, manage and report 
on risks stemming from the use of third parties through all stages of the third-party life cycle. This program is underpinned by a robust Third-Party 
Risk Management Framework that establishes minimum requirements for the identification, assessment, management, monitoring and reporting of 
this risk, in line with our organizational strategy and risk appetite. We continue to enhance our third-party risk management capabilities to help 
maintain robust risk management, operational resiliency and compliance with relevant regulatory requirements. 

Anti-Money Laundering 
Compliance with all Anti-Money Laundering, Anti-Terrorist Financing (AML/ATF) and sanctions measures is an integral part of safeguarding BMO, our 
customers and the communities in which we operate. We are committed to managing AML/ATF and sanctions risks effectively, and complying with all 
relevant laws and regulations. Risks related to non-compliance with these requirements can include enforcement action, legal action and damage to 
our reputation. Under the direction of the Chief Anti-Money Laundering Officer (CAMLO), BMO’s AML/ATF and sanctions compliance program promotes 
effective governance and oversight across all of our businesses, and establishes appropriate policies, risk assessments and training, including 
mandatory annual training for all employees. BMO’s AML/ATF and sanctions compliance program applies analytics, technology and professional 
expertise in order to deter, detect and report suspicious activity. The CAMLO regularly reports to the Audit and Conduct Review Committee (ACRC) 
of the Board of Directors and to senior management on the effectiveness of the AML compliance program. Amendments to Canada’s AML/ATF 
regulations that came into effect in June 2021 are intended to improve the effectiveness of Canada’s AML/ATF regime and further align it with 
international standards. We remain committed to effective compliance and the ongoing effort to protect the financial system and the communities 
in which we operate. 

BMO Financial Group 204th Annual Report 2021  107 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Model Risk 

Model risk is the potential for adverse consequences resulting from decisions that are based on incorrect or misused model results. 
These adverse consequences can include financial loss, poor business decision-making and damage to reputation. 

Model risk arises from the use of quantitative analytical tools that apply statistical, mathematical, economic, algorithmic or other advanced 
techniques, such as artificial intelligence (AI) and machine learning (ML), to process input data and generate quantitative estimates. We use these 
analytical tools, which range from very simple models that produce straightforward estimates to highly sophisticated models that value complex 
transactions or generate a broad range of forward-looking estimates. These models produce results that are used to inform business, risk and capital 
management decision-making, and to assist in making daily lending, trading, underwriting, funding, investment and operational decisions. 

These quantitative analytical tools provide important insights and are effective when used within a framework that identifies key assumptions 

and limitations, while controlling and mitigating model risk. In addition to applying judgment to evaluate the reliability of model results, we mitigate 
model risk by maintaining strong controls over the development, validation, implementation and use of all our models across the enterprise. We also 
seek to ensure that qualitative model overlays and non-statistical approaches to evaluating risks are intuitive, experience-based, well-documented 
and subject to effective challenge by those with sufficient expertise and knowledge, in order to deliver reasonable results. 

Model Risk Management Framework 
Risk is inherent in models because model results are estimates which rely on statistical, mathematical or other quantitative techniques that 
approximate reality to transform data into estimates or forecasts of future outcomes. Model risk also arises from the potential for misuse of models 
or model results. Model risk is governed at BMO by the enterprise-wide Model Risk Management Framework. 

A
&
D
M

1 
Model 
Initiation & 
Identification 

Model 
Life Cycle 

2 
Model 
Development 

3 
Model 
Validation 

7 
Model 
Decommission 

6 
Ongoing 
Monitoring & 
Validation 

5 
Model Use & 
Maintenance 

4 
Implementation 

The Model Risk Management Framework sets out an end-to-end approach for model risk governance across the model life cycle and helps manage 
model risk within the limits of our risk appetite. The framework includes BMO’s Model Risk Corporate Policy, Model Risk Guidelines and supporting 
operating procedures, which outline explicit principles for managing model risk, detail model risk management processes, and define the roles and 
responsibilities of all stakeholders across the model life cycle. Model owners, developers and users serve as the first line of defence, while the Model 
Risk group is the second line of defence, and the Corporate Audit Division is the third line of defence. 

Our Model Risk group is responsible for developing and maintaining a risk-based Model Risk Management Framework that meets regulatory 

expectations, as well as for oversight of the effectiveness of model processes, model inventory and the overall aggregation, assessment and 
reporting of model risk. This framework incorporates the management of risks arising from advances in automated decision-making, such as 
algorithmic trading, as well as AI and ML. Our Model Risk Management Committee (MRMC), a sub-committee of the RMC, is a cross-functional group 
representing all key stakeholders across the enterprise. The MRMC meets regularly to help direct BMO’s use of models, to oversee the development, 
implementation and maintenance of the Model Risk Management Framework, to provide effective challenge and to discuss governance of the 
enterprise’s models. 

Outcomes Analysis and Back-Testing 
Once models are validated, approved and in use, they are subject to ongoing monitoring, including outcomes analysis, at varying frequencies. 
As a key component of outcomes analysis, back-testing compares model results against actual observed outcomes. Variances between model 
forecasts and actual observed outcomes are measured against defined risk materiality thresholds and tolerance ranges, which may result in actions 
such as model review and parameter recalibration, as appropriate. This analysis serves to confirm the validity of a model’s performance over time. 
Controls are in place to address identified issues and enhance our models’ overall performance. 

All models used within BMO are subject to validation and ongoing monitoring to confirm that they are being used in accordance with our 
framework. This framework applies to a wide variety of models, ranging from market, credit and non-financial risk models to stress testing, pricing 
and valuation, and anti-money laundering models. 

Non-Financial Risk Measurement 
Beginning in fiscal 2020, the Office of the Superintendent of Financial Institutions permitted BMO, along with other AMA-approved banks, to use 
the Basel II Standardized Approach for determining regulatory capital requirements for enterprise operational risk in the interim period prior to 
implementation of the new Standardized Measurement Approach, as part of the final Basel III reforms. We expect to transition to the new Basel III 
Standardized Measurement Approach for regulatory capital reporting in February 2023. 

Caution 
This Operational Non-Financial Risk section contains forward-looking statements. Please refer to the Caution Regarding Forward-Looking Statements. 

108  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
M
D
&
A

Legal and Regulatory Risk 

Legal and regulatory risk is the potential for loss or harm resulting from a failure to comply with laws or satisfy contractual obligations or 
regulatory requirements. This includes the risk of failure to: comply with the law (in letter or in spirit) or maintain standards of care; implement 
legal or regulatory requirements; enforce or comply with contractual terms; assert non-contractual rights; effectively manage disputes; or act in a 
manner so as to maintain our reputation. 

The success of BMO’s business relies in part on our ability to manage our exposure to legal and regulatory risk. The financial services industry is highly 
regulated and subject to strict enforcement of legal and regulatory requirements. Banks globally continue to be subject to fines and penalties for a 
number of regulatory and conduct issues, and we are exposed to risks in connection with regulatory and governmental inquiries, investigations and 
enforcement actions. As rulemaking and supervisory expectations continue to evolve, we monitor developments to enable BMO to respond and 
implement changes as required. 

Under the direction of BMO’s General Counsel, our Legal & Regulatory Compliance group maintains enterprise-wide frameworks that identify, 

assess, manage, monitor and report on legal and regulatory issues. We identify applicable laws and regulations and potential risks, recommend 
mitigation strategies and actions, conduct internal investigations, and oversee legal proceedings and enforcement actions. BMO is subject to legal 
proceedings, including investigations by regulators, arising in the ordinary course of business, and the unfavourable resolution of any such legal 
proceedings could have a material adverse effect on our business, financial condition, results of operations, cash flows, capital position or credit 
ratings; require material changes in our operations; result in loss of customers; and damage our reputation. The volume of legal proceedings and 
the amount of damages and penalties assessed in such legal proceedings could increase in the future. We are required to disclose material legal 
proceedings to which we are a party. Our disclosure controls and procedures are designed to provide reasonable assurance that all relevant 
information is gathered and reported to senior management on a timely basis so that appropriate decisions can be made regarding public disclosure. 
In assessing the materiality of legal proceedings, factors considered include a case-by-case assessment of specific facts and circumstances, our past 
experience and the opinions of legal experts. However, some legal proceedings may be highly complex, and include novel or untested legal claims 
or theories. The outcome of such proceedings may be difficult to anticipate until late in the proceedings, which may last several years. Certain 
businesses are also subject to fiduciary requirements, including policies and practices that address the responsibilities of a business to a customer 
(such as service requirements and expectations, customer suitability determinations, disclosure obligations and communications). 

Safeguarding our customers, employees, information and assets from exposure to criminal risk is an important priority. Criminal risk is the 
potential for loss or harm resulting from a failure to comply with criminal laws, which could include acts by employees against BMO, acts by external 
parties against BMO and acts by external parties using BMO to engage in unlawful conduct, such as fraud, theft, money laundering, violence, cyber-
crime, bribery and corruption. 

BMO’s Anti-Corruption Office, through its global program, has articulated key principles and procedures necessary for the effective oversight of 

compliance with anti-corruption legislation in the jurisdictions in which we operate. These include guidance on both identifying and avoiding corrupt 
practices and rigorously investigating allegations of corrupt activity. 

Governments and regulators around the world continue to focus on anti-money laundering and related concerns, raising their expectations 

concerning the quality and efficacy of anti-money laundering programs and penalizing institutions that fail to meet these expectations. Under the 
direction of the Chief Anti-Money Laundering Officer (CAMLO), BMO’s Anti-Money Laundering Office is responsible for the governance, oversight and 
assessment of principles and procedures designed to help ensure compliance with laws and regulations and internal risk parameters related to anti-
money laundering, anti-terrorist financing and sanctions measures. For additional discussion regarding BMO’s operational non-financial risk 
management practices with respect to anti-money laundering measures, refer to the Anti-Money Laundering section. 

All of these frameworks reflect the three-lines-of-defence operating model described previously. The operating groups and Corporate Services, 

including Technology and Operations, manage day-to-day risks by complying with corporate policies and standards, while Legal & Regulatory 
Compliance units specifically aligned with each of the operating groups provide advice and independent legal and regulatory risk management 
oversight. 

Heightened regulatory and supervisory scrutiny has a significant impact on the way we conduct business. Working with the operating groups 
and Corporate Services, including Technology and Operations, Legal & Regulatory Compliance assesses and analyzes the implications of regulatory 
and supervisory changes. We devote substantial resources to the implementation of systems and processes required to comply with new regulations, 
which may also help us meet the needs and demands of our customers. Failure to comply with applicable legal and regulatory requirements may 
result in legal proceedings, financial losses, regulatory sanctions, enforcement actions, an inability to execute our business strategies, a decline in 
investor and customer confidence, and damage to our reputation. 

We recognize that our business is built on BMO’s reputation for good conduct. In recognition of this, we have adopted a wide range of practices 
beyond BMO’s Code of Conduct to support the ethical conduct of our employees. BMO’s Ethical Culture and Conduct Framework sets out our approach 
to managing and mitigating potential misconduct. Misconduct is behaviour that falls short of legal, professional, internal conduct and ethical 
standards. Similar to our approach to other non-financial risks, this framework is supported by our Enterprise-Wide Risk Management Framework 
and our focus on maintaining a strong risk culture. For further discussion, refer to the Risk Culture section. 

We continue to respond to other global regulatory developments, including capital and liquidity requirements. Other global regulatory 

developments include over-the-counter (OTC) derivatives reform, consumer protection measures and specific financial reforms, including proposed 
reforms in respect of the assessment, management and disclosure of climate-related financial risk, which are discussed in further detail below. 
For additional discussion of the regulatory developments relating to capital management and liquidity and funding risk, refer to the Enterprise-Wide 
Capital Management section and the Liquidity and Funding Risk section. For a discussion of the impact of certain other regulatory developments, refer 
to: Critical Accounting Estimates – Income Taxes and Deferred Tax Assets; Tax Legislation and Interpretations; Fiscal and Monetary Policies and Other 
Economic Conditions in the Countries in which BMO Conducts Business; and Benchmark Interest Rate Reform. 

BMO Financial Group 204th Annual Report 2021  109 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Consumer and Investor Protection – Regulators around the world continue to focus on consumer protection measures, including with respect to 
seniors and other vulnerable customers, interactions with consumers, and standards of conduct for individuals in the financial services industry. In 
Canada, these measures include amending the Bank Act to implement the Financial Consumer Protection Framework and amending the Financial 
Consumer Agency of Canada Act to strengthen the mandate and powers of the Financial Consumer Agency of Canada. Additionally, investor protection 
reforms to the Canadian securities regulatory regime are also proceeding. Canadian securities regulatory reforms include: client-focused reforms, 
which enhance requirements regarding conflict of interest disclosure, suitability, know-your-product, know-your-client, relationship disclosure, 
training and record-keeping; a ban on trailing commissions paid to dealers that do not make a suitability determination and a ban on deferred sales 
charges; and enhanced protection for older and vulnerable clients. In the United States, banking regulators have heightened focus on matters 
pertaining to racial equity and consumer protection, especially as they relate to the economic recovery of the communities we serve in the aftermath 
of the COVID-19 pandemic. Key consumer concerns, including fair lending, and unfair, deceptive or abusive acts or practices (UDAAP) issues, are the 
subject of heightened regulatory scrutiny in bank examination programs. 

A
&
D
M

U.S. Regulatory Reform – In May 2018, the U.S. Congress passed the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCP), 
which made changes to the Dodd-Frank Wall Street Reform and Consumer Protection Act, including raising the threshold for heightened prudential 
standards. In October 2019, the U.S. federal banking agencies finalized rules pursuant to EGRRCP that modify capital and liquidity requirements, 
single-counterparty credit limits and prudential standards for bank holding companies and foreign banking organizations, including BMO. In two 
separate rulemakings, in November 2019 and June 2020, the U.S. federal banking agencies finalized rules amending the restrictions on proprietary 
trading and the ownership and sponsorship of private investment funds by banks and their affiliates. In 2021, the new U.S. administration appointed 
new leadership at several U.S. federal agencies, and additional appointments are expected. Each such new appointee may initiate or modify future 
regulatory reforms. Furthermore, due to congressional leadership changes as a result of the 2020 U.S. election, there is the possibility that new 
legislation could result in further regulatory changes. We continue to monitor the rulemaking activities at all relevant agencies. 

Other Regulatory Initiatives Impacting Financial Services in Canada – The Department of Finance Canada is undertaking a consultation process 
regarding the merits of open banking, which would allow Canadian consumers and small businesses to direct federally regulated financial institutions 
to disclose their banking information through a secure mechanism to entities that meet information security and other requirements. Effective 
August 31, 2021, a new Pay Equity Act and related regulations require banks to establish a functional pay equity plan within three years. 
Implementing regulations are required for other earlier amendments to the Bank Act that will allow banks to undertake broader financial technology 
activities. As part of the 2021 federal budget process, the Department of Finance Canada launched consultations regarding the reduction of 
interchange fees that would benefit small businesses. These consultations precede any legislative modification to interchange fees, which were 
previously reduced by legislation in 2018. 

Climate Change and Environmental, Social and Governance (ESG) Matters – We continue to monitor rulemaking activities of securities regulatory 
authorities and engage in programs and consultations in respect of risk management and disclosures related to ESG matters, as well as climate-
related litigation trends. Globally, we are also monitoring the emergence of formal supervisory regulatory frameworks governing climate change risk 
analysis and reporting, including in Canada, the United States, the United Kingdom and the European Union. 

Privacy – There is an increasing focus on data privacy regulation related to the use and safeguarding of personal information, and we continue to 
advance our privacy program to comply with these evolving requirements. In Canada, significant reform to federal privacy laws is expected, including 
new regulatory powers and penalties for breaching the digital privacy rights of individuals. In Quebec, Bill 64 has been adopted and will modernize 
the province’s private-sector privacy regime and give new powers to privacy regulators to impose administrative monetary penalties. Ontario is also 
considering private-sector privacy legislation. Outside of Canada, large fines and settlements have been imposed for breaches of privacy rights and for 
failures to comply with regulatory privacy requirements, demonstrating heightened regulatory vigilance and enforcement. The California Consumer 
Privacy Act (CCPA) came into effect on January 1, 2020, and is currently the most comprehensive privacy law at the state level in the United States. 
The CCPA includes new and expanded privacy rights for California residents, including access and deletion rights with respect to their personal 
information. Other states have introduced privacy legislation, leading to a growing patchwork of privacy laws in the United States. In the European 
Union, new standard contractual clauses have been introduced to address the EU Commission’s concerns regarding the transfer of personal data to 
countries lacking adequate privacy protection. In China, data localization and cross-border transfer rules remain complex. For additional discussion 
regarding privacy, refer to the Cyber Security, Information Security and Privacy Risk section and the Operational Non-Financial Risk – Cyber Security 
Risk section. 

Derivatives Reform – G20 jurisdictions continue to implement new regulations as part of the OTC derivatives regulatory reform program. We 
continue to monitor and prepare for the impact of OTC derivatives regulatory changes relating to margin, clearing, execution and business conduct 
rules. 

COVID-19 Pandemic – The COVID-19 pandemic has caused unprecedented disruption to global economies. There have been wide-ranging responses 
to support individuals, businesses and local and national economies through governmental and regulatory actions, emergency orders and regulatory 
relief. We have been engaged with our regulators around the world on the pandemic response, including our participation in various relief programs. 
For additional discussion, refer to the General Economic Conditions section, and the Regulatory Capital Developments – COVID-19 Related Modifications 
section. 

The General Counsel and the Chief Compliance Officer regularly report to the Audit and Conduct Review Committee (ACRC) of the Board of Directors 
and senior management on the effectiveness of our Enterprise Compliance Program. The program uses a risk-based approach to identify, assess and 
manage compliance with applicable laws and regulations. The program directs operating groups and Corporate Services to maintain policies, 
procedures and controls that address these laws and regulations. Under the direction of the Chief Compliance Officer, we identify and report on 
gaps and deficiencies, and we track remedial action plans. The CAMLO also regularly reports to the ACRC. 

All BMO employees must regularly complete legal and regulatory training on topics such as anti-corruption, anti-money laundering and privacy 

policies, standards and procedures. This is done in conjunction with our Code of Conduct training, which tests employees’ knowledge and 
understanding of the behaviour required of employees of BMO. 

Caution 
This Legal and Regulatory Risk section contains forward-looking statements. Please refer to the Caution Regarding Forward-Looking Statements. 

110  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Strategic Risk 

Strategic risk is the potential for loss or harm due to changes in the external business environment and failure to respond appropriately to these 
changes as a result of inaction, ineffective strategies or poor implementation of strategies. Strategic risk also includes business risk, which arises 
from the specific business activities of the enterprise, and the effects these could have on its earnings. 

Strategic risk arises from external risks inherent in the business environment within which BMO operates, as well as from the potential for loss if we 
are unable to address those external risks effectively. While external strategic risks – including economic, geopolitical, regulatory, technological, social 
and competitive risks – cannot be controlled, the likelihood and magnitude of their impact can be limited through an effective strategic management 
framework, and certain of these risks, including economic, geopolitical and regulatory risks, can be assessed through stress testing. 

BMO’s Corporate Strategy team oversees the strategic planning process and works with the lines of business, along with ERPM, Finance and 

Corporate Services, to identify, monitor and mitigate strategic risk across the enterprise. Our rigorous strategic risk management framework 
encourages a consistent approach to developing strategies and incorporates information related to financial commitments. 

The Corporate Strategy team works with the lines of business and key corporate stakeholders during the strategy development process to 
promote consistency and adherence to strategic management standards, including a consideration of the results of stress testing as an input into 
strategic decision-making. The potential impacts of changes in the business environment, including macroeconomic developments, broad industry 
trends and the actions of existing and new competitors, are considered in this process and inform strategic decisions within each line of business. 
Enterprise and group strategies are reviewed with the Executive Committee and the Board of Directors annually in interactive sessions that challenge 
assumptions and strategies in the context of both the current and the potential future business environment. 

Business risk, as a component of strategic risk, encompasses the potential causes of earnings volatility that are distinct from credit, market or 
non-financial risk factors. BMO’s profitability, and hence value, may be eroded by changes in the business environment or by failures of strategy or 
execution due to changing client expectations or relatively ineffective responses to industry changes. Within BMO, each operating group is responsible 
for controlling its respective business risk by assessing, managing and mitigating any risks arising from changes in its business volumes, cost 
structures and potential competitor actions, among other factors. 

The ability to implement the strategic plans developed by management influences our financial performance. Performance objectives established 

through the strategic management process are monitored regularly and reported on quarterly, using both leading and lagging indicators of 
performance, so that strategies can be reviewed and adjusted where necessary. Regular strategic and financial updates are also reviewed closely 
in order to identify any significant emerging risk issues. 

M
D
&
A

Environmental and Social Risk 

Environmental and social risk (E&S risk) is the potential for loss or harm, directly or indirectly, resulting from environmental or social impacts or 
concerns, including climate change, related to BMO, our customers, suppliers or clients, and our impact on the environment and society. 

Environmental and social factors may give rise to the risk of direct and indirect impacts over both the short and long term, including but not limited 
to: climate change; pollution and waste; energy, water and other resource usage; biodiversity and land use; human rights; diversity, equity and 
inclusion; labour standards; community health, safety and security; land acquisition and involuntary resettlement; Indigenous peoples’ rights and 
consultation; and cultural heritage. We may be indirectly exposed to the risk of financial loss or reputational harm if our customers, suppliers or clients 
are affected by environmental or social factors such that they are unable to meet their financial or other obligations to us. Environmental and social 
factors may also give rise to the risk of reputational harm, for instance if we are perceived to not effectively respond to those factors. 

We continue to monitor and respond to the rapidly evolving E&S risk-related regulatory and supervisory frameworks, guidance and consultation, 
including developments in respect of the assessment, management and disclosure of climate-related financial risk in applicable jurisdictions, among 
them Canada, the United States, the United Kingdom and the European Union. For further discussion, refer to the Legal and Regulatory Risk section. 

Governance 
At the Board of Directors level, the Risk Review Committee (RRC) and the Audit and Conduct Review Committee (ACRC) provide oversight of our 
strategic E&S objectives and risk management. The Board meets with the Chief Sustainability Officer and General Counsel as necessary, to review 
key sustainability issues and trends as they relate to us and the financial services industry in general. Climate change risk and disclosure training is 
available to all Board of Directors members, including members of our subsidiaries’ boards. 

The ACRC charter includes a duty to assess the effectiveness of our governance of sustainability issues. The ACRC meets with the Chief 
Sustainability Officer and General Counsel to review and discuss key sustainability topics. A key role of the ACRC is to review and approve our 
Sustainability Report and Public Accountability Statement. The ACRC also provides guidance on the strategy, action plans, performance objectives 
and targets related to our operational footprint and sustainable finance commitments, and works to ensure management is adequately addressing 
opportunities associated with the transition to a lower-carbon economy. 

The RRC assists the Board of Directors in fulfilling its risk management oversight responsibilities, including overseeing the identification, 

assessment and management of our E&S risks. Upon recommendation from the RRC, the Board of Directors annually approves our enterprise E&S risk 
appetite statement and associated key risk metrics. 

BMO’s General Counsel is responsible for our Sustainability program and sits on BMO’s Executive Committee. Our Sustainability Council comprises 
senior leaders from the lines of business and Corporate Services across the organization, and provides oversight and leadership for our sustainability 
strategy, including our Net Zero Ambition (described under E&S Risk Management below). The Sustainability team is responsible for coordinating the 
development and maintenance of an enterprise-wide strategy that meets our overarching environmental and social responsibilities. 

BMO Financial Group 204th Annual Report 2021  111 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
A
&
D
M

MANAGEMENT’S DISCUSSION AND ANALYSIS 

The Chief Risk Officer (CRO) reports to the RRC on E&S risk matters, including climate change. Enterprise Risk and Portfolio Management (ERPM) 
provides risk management oversight, supporting a disciplined approach to risk-taking in independent transaction approval and portfolio management, 
policy formulation, risk reporting, scenario analysis, modelling and risk education. The CRO and the Risk Management team report to the RRC 
periodically on E&S risk matters, including climate change. 

E&S Risk Management 
In recognition of its unique characteristics, E&S risk is classified in BMO’s Risk Taxonomy as a transverse risk. As part of our Enterprise-Wide Risk 
Management Framework and Credit Risk Management Framework, we include provisions for governance and accountabilities, enhanced due 
diligence, and provisions for escalations and exceptions. We have also developed a qualitative risk appetite statement on E&S risks, including climate 
change. 

Led by BMO’s Chief Sustainability Officer, the Sustainability team works in partnership with the lines of business (including the BMO Capital 
Markets Sustainable Finance team and the BMO Global Asset Management team) and Corporate Services (including Risk Management) to manage E&S 
risk within our organization and to make progress toward achieving our sustainability goals. BMO’s Net Zero Ambition is one of those goals. Our Net 
Zero Ambition is to be our clients’ lead partner in the transition to a net zero world, and is supported by four pillars: Commitment, Capabilities, Client 
Partnership and Convening for Climate Action. The team reports quarterly to the Sustainability Council on key developments in sustainability and 
climate change and engages with external stakeholders to better understand the social consequences and environmental impacts of our operations 
and financing decisions. 

BMO is a signatory to the Equator Principles, the United Nations (UN) Principles for Responsible Banking (UNPRB) and the UN Principles for 
Responsible Investment (UNPRI), and is a member of the Partnership for Carbon Accounting Financials (PCAF), as well as the Net-Zero Banking 
Alliance (NZBA). These voluntary frameworks may include process and reporting requirements that are intended to be voluntary, or they may adopt a 
“comply-or-explain” approach. We may also be exposed to reputation risk in the event that we do not fully implement these frameworks, either 
as a result of our own actions or due to external factors. 
•   The Equator Principles serve as a common baseline and framework for financial institutions to identify, assess and manage E&S risks that may arise 

in project financing. We apply this credit risk management framework to identify, assess and manage the E&S risk in these transactions. 

•   UNPRB provides a framework for a sustainable banking system and is the only sustainability framework for banks that is applicable across the 
enterprise, providing guidance at the strategic, portfolio and transaction levels across all lines of business. The UNPRB enables any financial 
institution genuinely committed to sustainable and responsible banking to set targets that are within the context of its capabilities and current 
financial and operational position. 

•   UNPRI is a framework that encourages sustainable investing through the integration of environmental, social and governance considerations into 

investment decision-making and ownership practices. 

•   PCAF is a global partnership of financial institutions working together to develop and implement a harmonized approach to assessing and disclosing 

the greenhouse gas (GHG) emissions associated with loans and investments. 

•   NZBA is an industry-led, UN-convened organization of banks supporting the implementation of decarbonization strategies and the development 
of an internationally coherent framework and guidelines for banks committed to aligning their lending and investment portfolios with net zero 
emissions by 2050. 

E&S factors continue to be integrated into existing risk management frameworks. We evaluate the E&S risks associated with credit and 

counterparty transactions and exposures, and we apply enhanced due diligence processes to transactions with clients operating in higher risk sectors. 
We also avoid doing business with borrowers that have poor track records in E&S risk management. Transactions with significant environmental or 
social concerns may be escalated to BMO’s Reputation Risk Management Committee for consideration. 

Our Sustainability team also partners with the Procurement and Corporate Real Estate groups on operational sustainability. Together these groups 
are responsible for establishing and maintaining an operational environmental management approach, including the application of the framework set 
out in ISO 14001, and for setting objectives and targets that are intended to align our operations with our sustainability performance goals. 

To keep informed of emerging environmental and social risks, we participate in global forums with our peers and maintain an open dialogue 

with our external stakeholders. BMO is a member of, and actively engaged in, sustainability-focused working groups of the United Nations 
Environment Programme – Finance Initiative (UNEP-FI), serves on the Steering Committee of the Equator Principles Association, and chairs the 
Cross-Sector Biodiversity Initiative. 

Climate Change 
We recognize that climate change poses potential risks to our organization, our clients and the communities in which we operate. In response, in 
March 2021, we announced the establishment of the BMO Climate Institute. It brings together our existing internal capabilities and external experts 
and provides a platform for collaboration to accelerate progress in our respective areas of work and to develop climate mitigation and adaptation 
solutions for our clients. 

In line with the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD), we recognize that climate change exposes 

the world to physical risks and transition risks. 

Physical risks are risks associated with a changing climate, resulting in both acute and chronic physical effects. These risks may include an 
increase in the frequency and intensity of weather-related events, such as storms, floods, wildfires and heatwaves, or longer-term changes, such as 
temperature changes, rising sea levels and changes in soil productivity. To date, key climate change indicators, weather-related events and 
associated scientific research indicate that global exposure to climate change risks may be accelerating. 

Transition risks are risks associated with the shift to a net zero carbon economy. These risks may arise from climate-related policy changes, 

technological changes and behavioural changes involving carbon-pricing mechanisms or a shift in consumer preferences toward lower-carbon 
products and services. We continue to closely monitor policy, technological and behavioural changes, some of which may unfold more rapidly than 
others as consumers, clients, investors, governments and communities act to enhance their resiliency to climate-related risks. 

112  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
M
D
&
A

We consider the physical and transition risks arising from climate change to be transverse risk drivers that impact all of the material risks in our 

Risk Taxonomy, namely credit and counterparty risk, market risk, insurance risk, liquidity and funding risk, operational non-financial risk, legal and 
regulatory risk, reputation risk and strategic risk. Accordingly, we are integrating climate change considerations into our Enterprise-Wide Risk 
Management Framework. 

To identify, assess and manage specific climate-related risks arising from our customer and client relationships, we follow internal guidelines that 

outline the scope of E&S risk and establish procedures, including enhanced due diligence, to determine the extent of our exposure to any such risk. 
Our Environmental and Social Risk Financing Guideline includes direction on developing an understanding of specific climate change impacts on 
borrowers and their operations, including regulatory and/or legislative changes. To avoid over-exposure to any one sector or geographic region 
that might be exposed to climate-related risks, we maintain a diversified lending portfolio. We continue to conduct sector-specific reviews across 
our lending portfolio to assess exposure to climate-sensitive industries. As a signatory to the Equator Principles, we have implemented the EP4 
framework, which includes requirements related to climate change for transactions within its scope. 

We are developing a climate change scenario analysis program, in line with the TCFD recommendations, analyzing both physical and transition 
risks for a selection of climate-sensitive lending portfolios. We plan to continue expanding such analyses across sectors and risk types, in line with 
internal policies and any applicable regulatory requirements. Going forward, this evolving scenario analysis program will inform our process for 
climate-related risk assessment. 

The GHG Protocol Corporate Standard classifies a company’s greenhouse gas (GHG) emissions under three scopes. Scope 1 emissions are direct 

emissions from owned or controlled sources, Scope 2 emissions are indirect emissions from the generation of purchased energy and Scope 3 
emissions are indirect emissions (not included in Scope 2) that occur in the value chain of the reporting company. We track and analyze our Scope 1 
and Scope 2 emissions, as well as Scope 3 emissions associated with our waste generation and business travel. We also have an ongoing operational 
approach to GHG emissions quantification and energy efficiency. 

We continue to assess the credibility, reliability, comparability and decision-making usefulness of various measurement, assessment and 

reporting approaches, as well as how they could be incorporated into our climate risk management program and associated disclosures. 

Codes of Conduct and Statement on Human Rights 
BMO’s Board-approved Code of Conduct reflects our commitment to manage our business responsibly. Our Statement on Human Rights describes our 
approach to human rights in the context of the UN Guiding Principles on Business and Human Rights. We report publicly under the United Kingdom 
Modern Slavery Act 2015, and we have in place a Supplier Code of Conduct, which outlines our standards for integrity, fair dealing and sustainability. 
We expect our suppliers to be aware of, understand and respect the principles of our Supplier Code of Conduct. 

Reporting 
We have supported the TCFD since 2018, and we have adopted the framework of the TCFD to guide climate-related financial disclosures, as set out in 
our Climate Report. Our Sustainability Report is prepared in accordance with the Global Reporting Initiative (GRI) Standards (core option) and the GRI 
Financial Services Sector Disclosure, and integrates the disclosure frameworks of the TCFD and the Sustainability Accounting Standards Board. This 
report includes the Public Accountability Statements for Bank of Montreal, Bank of Montreal Mortgage Corporation, BMO Life Assurance Company and 
BMO Life Insurance Company, outlining certain aspects of Bank of Montreal’s contributions, and the contributions of its affiliates with operations in 
Canada, to the Canadian economy and society. These statements meet the requirements of the Canadian federal government’s Public Accountability 
Statement regulations. Selected environmental and social indicators in the Sustainability Report are assured by the shareholders’ auditors. 

Caution 
This Environmental and Social Risk section contains forward-looking statements. Please refer to the Caution Regarding Forward-Looking Statements. 

Reputation Risk 

Reputation risk is the potential for loss or harm to the BMO brand. It can arise even if other risks are managed effectively. 

Our reputation is built on our commitment to high standards of business conduct and is one of our most valuable assets. By protecting and 
maintaining our reputation, we safeguard our brand, increase shareholder value, reduce our cost of capital, improve employee engagement, and 
preserve our customers’ loyalty and trust. 

We manage risks to our reputation by considering the potential reputational impact of all business activities, including strategy development and 

implementation, transactions and initiatives, product and service offerings, and events or incidents impacting BMO, as well as day-to-day decision-
making and conduct. We consider our reputation in everything that we do. 

BMO’s Code of Conduct is the foundation of our ethical culture and it provides employees with guidance on the behaviour that is expected of 
them, so that they can make the right choice in decisions that affect our customers and stakeholders. Continual reinforcement of the principles set out 
in the Code of Conduct minimizes risks to our reputation that may result from poor decisions or behaviour. Recognizing that non-financial risks can 
have a negative effect that is as significant as the effect of financial risks, we actively promote a culture which encourages employees to raise 
concerns and supports them in doing so, with zero tolerance for retaliation. 

In our corporate governance practices and Enterprise-Wide Risk Management Framework, we have put specific controls in place to manage 

risks to our reputation. We seek to identify activities or events that could impact our reputation with customers, regulators or other stakeholders. 
Where we identify a potential risk to our reputation, we take steps to assess and manage that risk. Instances of significant or heightened exposure 
to reputation risk are escalated to BMO’s Reputation Risk Management Committee for review. As misconduct can impact our reputation, the Chief 
Ethics and Conduct Officer, who is responsible for enterprise-wide reporting on employee conduct, escalates instances of misconduct involving 
significant reputation risk to BMO’s Reputation Risk Management Committee, as appropriate. 

BMO Financial Group 204th Annual Report 2021  113 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Accounting Matters and Disclosure and Internal Control 

Critical Accounting Estimates 
The most significant assets and liabilities for which we must make estimates include: allowance for credit losses; financial instruments measured 
at fair value; pension and other employee future benefits; impairment of securities; income taxes and deferred tax assets; goodwill and intangible 
assets; insurance-related liabilities; and provisions, including legal provisions. We make judgments in assessing whether substantially all risks and 
rewards have been transferred in respect of transfers of financial assets and whether we control structured entities (SEs). These judgments are 
discussed in Notes 6 and 7 of the consolidated financial statements. Note 17 of the consolidated financial statements provides further details on 
the estimates and judgments made in determining the fair value of financial instruments. If actual results were to differ from estimates, the impact 
would be recorded in future periods. 

The extent of the continuing impact of the COVID-19 pandemic on the Canadian and U.S. economies remains uncertain and difficult to predict, 
including government and regulatory responses to the pandemic, which could vary by country and region. By their very nature, the judgments and 
estimates that we make for the purposes of preparing financial statements relate to matters that are inherently uncertain. However, we have 
detailed policies and control procedures that are intended to ensure the judgments made in estimating these amounts are well controlled, 
independently reviewed and consistently applied from period to period. We believe that the estimates of the value of our assets and liabilities are 
appropriate. 

For a more detailed discussion of the use of estimates, refer to Note 1 of the consolidated financial statements. 

A
&
D
M

Allowance for Credit Losses 
The allowance for credit losses consists of allowances on impaired loans, which represent estimated losses related to impaired loans in the portfolio 
provided for but not yet written off, and allowances on performing loans, which is our best estimate of impairment in the existing portfolio for loans 
that have not yet been individually identified as impaired. Our approach to establishing and maintaining the allowance on performing loans is based 
on the requirements of IFRS, considering the guideline issued by the Office of the Superintendent of Financial Institutions. Under the IFRS 9 expected 
credit loss (ECL) methodology, an allowance is recorded for expected credit losses on financial assets regardless of whether there has been actual 
impairment. ECL is calculated on a probability-weighted basis, based on the economic scenarios described below, and is calculated for each exposure 
in the portfolio as a function of the probability of default (PD), exposure at default (EAD) and loss given default (LGD), with the timing of the loss also 
considered. Where there has been a significant increase in credit risk, lifetime ECL is recorded; otherwise 12 months of ECL is generally recorded. 
The determination of a significant increase in credit risk considers many different factors and will vary by product and risk segment. The main factors 
considered in making this determination are the change in PD since origination and certain other criteria, such as 30-day past due and watchlist 
status. We may apply experienced credit judgment to reflect factors not captured in the results produced by the ECL models, as we deem necessary. 
We applied experienced credit judgment to reflect the continuing impact of the uncertain environment on credit conditions and the economy as a 
result of the COVID-19 pandemic. We have controls and processes in place to govern the ECL process, including judgments and assumptions used in 
the determination of the allowance on performing loans. These judgments and assumptions will change over time, and the impact of any such 
change will be recorded in future periods. 

In establishing our allowance on performing loans, we attach probability weightings to three economic scenarios, which are representative of our 

view of economic and market conditions – a base scenario, which in our view represents the most probable outcome, as well as benign and adverse 
scenarios, all developed by our Economics group. The adverse scenario is also described below, with the focus on such a scenario, given continued 
economic uncertainty. The allowance on performing loans is sensitive to changes in economic forecasts and the probability weight assigned to each 
forecast scenario. When changes in economic performance in the forecasts are measured, we use real GDP as the basis, which acts as the key driver 
for movements in many of the other economic and market variables used, including the equity volatility index (VIX), corporate BBB credit spreads, 
unemployment rates, housing price indices and consumer credit. In addition, we also consider industry-specific variables, where applicable. Many of 
the variables have a high degree of interdependency and, as such, there is no one single factor to which the allowances as a whole are sensitive. 
Holding all else equal, as economic variables worsen, the allowance on performing loans would increase and conversely, as they improve, the 
allowance would decrease. In addition, assuming all variables are held constant, an increase in loan balances or a deterioration in the credit quality 
of the loan portfolio would both drive an increase in the allowance on performing loans. 

Our total allowance for credit losses as at October 31, 2021 was $2,958 million ($3,814 million as at October 31, 2020) and comprises an 

allowance on performing loans of $2,447 million and an allowance on impaired loans of $511 million ($3,075 million and $739 million, respectively, 
as at October 31, 2020). The allowance on performing loans decreased $628 million year-over-year, primarily driven by an improving economic 
outlook, positive credit migration and movements in foreign exchange rates, partially offset by the impact of the uncertain environment on future 
credit conditions, including adoption of a higher adverse scenario weighting as well as a more severe adverse scenario, and portfolio growth. 

As at October 31, 2021, our base case scenario depicts a stronger economic forecast in both Canada and the United States. In Canada, annual real 

GDP growth averages 4.0% over the next 12 months as a result of policy stimulus, easing of pandemic restrictions, and a reduction in supply-chain 
disruptions, combined with a wave of pent-up demand. Annual real GDP growth is expected to average 3.9% over the following 12 months, as the 
economic recovery continues and spending returns to more normal levels. The Canadian unemployment rate is forecasted to decline steadily, though 
remains elevated, averaging 6.6% over the next 12 months and 5.7% over the following year. The U.S. economy is expected to follow a similar 
trajectory over the next 12 months, albeit with a higher level of growth compared with Canada at 4.8%, given a larger policy stimulus and an initially 
faster vaccine rollout. Real GDP is expected to grow 2.7% in the following 12 months. The U.S. unemployment rate is forecasted to average 4.7% over 
the next 12 months and then fall to 3.7% in the following year. Our base case economic forecast as at October 31, 2020 depicted more moderate 
economic growth in both Canada and the United States over the near-term projection period. If we assume a 100% base case economic forecast and 
include the impact of loan migration by restaging, with other assumptions held constant, including the application of experienced credit judgment, 
the allowance on performing loans would be approximately $1,725 million as at October 31, 2021 ($2,375 million as at October 31, 2020), compared 
with the reported allowance on performing loans of $2,447 million ($3,075 million as at October 31, 2020). 

114  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
As at October 31, 2021, our adverse case economic forecast depicts a contracting economy, with annual average real GDP declining in both 
Canada and the United States over the next 12 months by 2.7% and 1.2%, respectively, with both contracting at a rate of 1.1% in the following 
12 months. The adverse case scenario assumes a sustained large increase in COVID-19 cases, accompanied by renewed restrictions on a broad range 
of activities leading to a decline in consumer and business confidence, and prolonged supply-chain disruptions. Unemployment rates remain elevated 
in both Canada and the United States, increasing from an average of 10.8% over the next 12 months to an average of 12.7% in the following year in 
Canada, and from 8.5% to 11.0% in the United States over the same period. Despite adopting a more severe adverse scenario during fiscal 2021, the 
adverse case economic outlook as at October 31, 2020 depicted a more severe economic contraction in Canada and the United States compared with 
the adverse case as at October 31, 2021, due to the improvement in economic conditions year-over-year. If we assume a 100% adverse economic 
forecast and include the impact of loan migration by restaging, with other assumptions held constant, including the application of experienced credit 
judgment, the allowance on performing loans would be approximately $3,825 million as at October 31, 2021 ($4,875 million as at October 31, 2020), 
compared with the reported allowance on performing loans of $2,447 million ($3,075 million as at October 31, 2020). 

The following tables show the key economic variables used to estimate the allowance on performing loans during the forecast period. The values 

shown represent the national annual average levels or growth rates for the next 12 months and the subsequent 12 months following each reporting 
period for all scenarios. While the values disclosed below are national variables, we use regional variables in the underlying models where 
appropriate. 

All figures are annual average values 

First 12 months  Subsequent 12 months 

First 12 months  Subsequent 12 months 

First 12 months  Subsequent 12 months 

Benign scenario 

As at October 31, 2021 

Base scenario 

Adverse scenario 

M
D
&
A

Real GDP growth rates (1) 

Canada 
United States 

Corporate BBB 10-year spread 

Canada 
United States 

Unemployment rates 

Canada 
United States 

Housing price index (1) 

Canada (2) 
United States (3) 

6.3% 
7.1% 

1.4% 
0.9% 

6.0% 
4.2% 

18.2% 
14.6% 

5.5% 
4.0% 

1.7% 
1.1% 

4.9% 
3.2% 

10.2% 
6.7% 

4.0% 
4.8% 

1.8% 
1.2% 

6.6% 
4.7% 

15.1% 
12.3% 

3.9% 
2.7% 

2.0% 
1.5% 

5.7% 
3.7% 

5.2% 
4.3% 

(2.7)% 
(1.2)% 

3.6% 
4.2% 

10.8% 
8.5% 

(6.4)% 
(6.1)% 

(1.1)% 
(1.1)% 

4.4% 
4.5% 

12.7% 
11.0% 

(18.0)% 
(15.5)% 

Benign scenario 

As at October 31, 2020 

Base scenario 

Adverse scenario 

All figures are annual average values 

First 12 months 

Subsequent 12 months 

First 12 months 

Subsequent 12 months 

First 12 months 

Subsequent 12 months 

Real GDP growth rates (1) 

Canada 
United States 

Corporate BBB 10-year spread 

Canada 
United States 

Unemployment rates 

Canada 
United States 

Housing price index (1) 

Canada (2) 
United States (3) 

3.7% 
1.6% 

1.8% 
1.7% 

7.4% 
6.4% 

10.3% 
4.6% 

6.4% 
6.0% 

1.9% 
1.7% 

6.1% 
4.8% 

7.7% 
4.5% 

1.8% 
(0.4)% 

2.2% 
2.0% 

8.9% 
8.0% 

7.2% 
2.4% 

4.2% 
4.0% 

2.2% 
2.0% 

7.5% 
6.0% 

2.8% 
2.1% 

(4.4)% 
(5.1)% 

3.6% 
3.9% 

12.7% 
11.5% 

(1.2)% 
(2.4)% 

(1.1)% 
(1.2)% 

4.5% 
4.1% 

13.9% 
12.8% 

(8.7)% 
(6.2)% 

(1)  Real gross domestic product and housing price index are four-quarter averages of year-over-year growth rates. 
(2)  In Canada, we use the HPI Benchmark Composite. 
(3)  In the United States, we use the National Case-Shiller House Price Index. 

The table below shows our expectations for the real GDP year-over-year growth rates for the base case in Canada and the United States to trend by 
calendar quarter. In addition, the table includes the real GDP level compared with calendar Q4 2019, which marked the quarterly peak in real GDP 
prior to the beginning of the pandemic in calendar Q1 2020, expressed as a percentage. 

Calendar quarter ended 

Real GDP growth rates year-over-year 

Canada 
United States 

Real GDP level compared to calendar Q4 2019 

Canada 
United States 

December 31, 
2021 

March 31, 
2022 

June 30, 
2022 

September 30, 
2022 

December 31, 
2022 

March 31, 
2023 

June 30, 
2023 

September 30, 
2023 

3.4% 
5.5% 

3.4% 
4.6% 

5.1% 
3.7% 

5.2% 
3.1% 

4.4% 
2.7% 

3.5% 
2.5% 

2.6% 
2.4% 

2.1% 
2.3% 

100.2% 
103.1% 

101.6% 
103.8% 

103.0% 
104.6% 

104.0% 
105.3% 

104.6% 
105.9% 

105.1% 
106.5% 

105.6% 
107.0% 

106.1% 
107.6% 

The ECL approach requires the recognition of credit losses generally based on 12 months of expected losses for performing loans (Stage 1) and the 
recognition of lifetime expected losses for performing loans that have experienced a significant increase in credit risk since origination (Stage 2). 
Under the current probability-weighted scenarios and based on the current risk profile of loan exposures, if all performing loans were in Stage 1, our 
models would generate an allowance on performing loans of approximately $1,775 million ($2,300 million in 2020), compared with the reported 
allowance on performing loans of $2,447 million ($3,075 million in 2020). 

BMO Financial Group 204th Annual Report 2021  115 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Information on the Provision for Credit Losses for the years ended October 31, 2021 and 2020 can be found in the Total Provision for Credit 
Losses section. Additional information on the process and methodology for determining the allowance for credit losses can be found in the discussion 
of Credit and Counterparty Risk, as well as in Note 4 of the consolidated financial statements. 

Financial Instruments Measured at Fair Value 
We record assets and liabilities classified as trading, assets and liabilities designated at fair value, derivatives, certain equity and debt securities and 
securities sold but not yet purchased at fair value. Fair value represents an estimate of the amount we would receive, or would be required to pay in 
the case of a liability, in an orderly transaction between willing parties at the measurement date. We employ a fair value hierarchy to categorize 
the inputs we use in valuation techniques to measure fair value. The extent of our use of quoted market prices (Level 1), internal models with 
observable market information (Level 2) and internal models without observable market information (Level 3) in the valuation of loans, securities, 
derivative assets and liabilities, and liabilities recorded at fair value as at October 31, 2021, as well as a sensitivity analysis of Level 3 financial 
instruments, is disclosed in Note 17 of the consolidated financial statements. For instruments that are valued using models, we consider all 
reasonable available information and maximize the use of observable market data. 

Valuation Product Control (VPC), a group independent of the trading lines of business, seeks to ensure that the fair values at which financial 

A
&
D
M

instruments are recorded are materially accurate by: 
•   Developing and maintaining valuation policies, procedures and methodologies in accordance with regulatory requirements and IFRS 
•   Establishing official rate sources for valuation data inputs, and 
•   Providing independent review of portfolios for which prices supplied by traders are used for valuation 

When VPC determines that adjustments to valuations are needed to better reflect fair value estimates based on data inputs from its official rate 

sources, the adjustments are subject to review and approval by the Valuation Steering Committee (VSC). 

The VSC is our senior management valuation committee. It meets at least monthly to address the more challenging valuation issues related to 

our portfolios, approves valuation methodology changes as needed to enhance fair value estimates, and acts as a key forum for the discussion of 
sources of valuation uncertainty and how these have been addressed by management. 

As at October 31, 2021, the total valuation adjustments were a net decrease in value of $124 million for financial instruments carried at fair 

value on the Consolidated Balance Sheet (a net decrease of $117 million as at October 31, 2020). 

Pension and Other Employee Future Benefits 
Our pension and other employee future benefits expense is calculated by independent actuaries using assumptions determined by management. 
Differences between actual experience and the assumptions used are recognized in other comprehensive income. 

Pension and other employee future benefits expense and the related obligations are sensitive to changes in discount rates. We determine 

discount rates at each year end for all plans, using high-quality corporate bonds with terms matching the plans’ specific cash flows. 

Additional information regarding accounting for pension and other employee future benefits, including a sensitivity analysis for key assumptions, 

is included in Note 21 of the consolidated financial statements. 

Impairment of Securities 
We have investments in associates and joint ventures, which we review at each quarter-end reporting period in order to identify and evaluate those 
that show indications of possible impairment. For these investments, a significant or prolonged decline in the fair value of a security to an amount 
below its cost is objective evidence of impairment. 

Debt securities measured at amortized cost or fair value through other comprehensive income (FVOCI) are assessed for impairment using the 
expected credit loss model. For securities determined to have low credit risk, the allowance for credit losses is measured at a 12-month expected 
credit loss. 

Additional information regarding accounting for debt securities measured at amortized cost or FVOCI, other securities, the related allowance for 

credit losses and the determination of fair value is included in Note 3 and Note 17 of the consolidated financial statements. 

Income Taxes and Deferred Tax Assets 
Our approach to tax is guided by our Statement on Tax Principles, elements of which are described below, and governed by our tax risk management 
framework, which is implemented through internal controls and processes. We operate with due regard to risks, including tax and reputation risks. 
We actively seek to identify, assess, manage (including mitigation), monitor and report any tax risks that may arise in order to understand our financial 
exposure. Our intention is to comply fully with tax laws. We consider all applicable laws in connection with commercial activities, and where tax laws 
change in our business or for our customers, we adapt and make changes accordingly. We monitor applicable tax-related developments, including 
legislative proposals, case law and guidance from tax authorities. When an interpretation or application of tax laws is not clear, we take well-reasoned 
positions based on available case law and administrative positions of tax authorities, and we engage external advisors when necessary. We do not 
engage in tax planning that does not have commercial substance. We do not knowingly work with customers we believe use tax strategies to evade 
taxes. We are committed to maintaining productive relationships and cooperating with tax authorities on all tax matters. We seek to resolve disputes 
in a collaborative manner; however, when our interpretation of tax law differs from that of tax authorities, we are prepared to defend our position. 

The provision for income taxes is calculated based on the expected tax treatment of transactions recorded in either the Consolidated Statement 
of Income or the Consolidated Statement of Changes in Equity. In determining the provision for income taxes, we interpret tax legislation, case law 
and administrative positions in numerous jurisdictions and, based on our judgment, we record the estimate of the amount required to settle tax 
obligations. We also make assumptions about the expected timing of the reversal of deferred tax assets and liabilities. If the interpretations and 
assumptions differ from those of tax authorities or if the timing of reversals is not as expected, the provision for income taxes could increase or 
decrease in future periods. The amount of any such increase or decrease cannot be reasonably estimated. 

Deferred tax assets are recognized only when it is probable that sufficient taxable profit will be available in future periods against which 

deductible temporary differences or unused tax losses and tax credits may be utilized. We are required to assess whether it is probable that deferred 
income tax assets will be realized. Factors used to assess the probability of realization are past experience of income and capital gains, forecasts of 
future net income before taxes, and the remaining expiration period of tax loss carry forwards and tax credits. Changes in assessment of these factors 
could increase or decrease the provision for income taxes in future periods. 

116  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
M
D
&
A

If income tax rates increase or decrease in future periods in a jurisdiction, the provision for income taxes for future periods will increase or 
decrease accordingly. Furthermore, deferred tax assets and liabilities will increase or decrease as income tax rates increase or decrease, respectively, 
and will result in an income tax impact. For example, an increase in the Canadian or U.S. federal tax rate would increase our respective net deferred 
tax asset, which would result in one-time corresponding tax benefits to net income. In addition, an increase in the Canadian or U.S federal tax rate 
would decrease our annual net income. The size of this annual net income decrease and any impact on the respective net deferred tax asset is 
uncertain at this point and will be dependent on many factors, including the tax rates enacted and their timing, phase-in provisions and details 
regarding any legislation and its interpretation. 

Canadian tax authorities have reassessed us for additional income tax and interest in an amount of approximately $1,210 million, to date, in 
respect of certain 2011-2016 Canadian corporate dividends. Those reassessments denied certain dividend deductions on the basis that the dividends 
were received as part of a “dividend rental arrangement”. The tax rules raised by the Canadian tax authorities were prospectively addressed in the 
2015 and 2018 Canadian federal budgets. In October 2021, we filed Notices of Appeal with the Tax Court of Canada and the matter is now in 
litigation. We expect to be reassessed in future years for significant additional income tax for similar activities. We remain of the view that our tax 
filing positions were appropriate and intend to challenge all reassessments. However, if such challenges are unsuccessful, the additional expense 
would negatively impact net income. 

Additional information regarding accounting for income taxes is included in Note 22 of the consolidated financial statements. 

Goodwill and Intangible Assets 
Goodwill is assessed for impairment at least annually. This assessment includes a comparison of the carrying value and the recoverable amount of 
each of our cash-generating units (CGUs) in order to verify that the recoverable amount of the CGU is greater than its carrying value. If the carrying 
value were to exceed the recoverable amount of the CGU, an impairment calculation would be performed. The recoverable amount of a CGU is the 
higher of its fair value less costs to sell and its value in use. 

Fair value less costs to sell was used to perform the impairment test in all periods. In determining fair value less costs to sell, we employ a 
discounted cash flow model, consistent with that used when a business is acquired. This model is dependent on assumptions related to revenue 
growth, discount rates, synergies achieved on acquisition and the availability of comparable acquisition data. Changes in any of these assumptions 
would affect the determination of fair value for each of our CGUs in a different manner. Management must exercise judgment and make assumptions 
in determining fair value. In particular, we have considered the impact of the COVID-19 pandemic in the current year by updating key assumptions 
accordingly, including the estimated cost of capital, discount rates and actual and future business performance of our CGUs. Differences in judgments 
and assumptions could affect the determination of fair value and any resulting impairment write-down. 

During the year, we recognized a goodwill write-down of $779 million ($nil in 2020) due to the implied valuation from the definitive agreement 

to sell our EMEA Asset Management business (part of our Wealth Management CGU) to Ameriprise and our allocation of goodwill to the business 
being sold. As at October 31, 2021, no goodwill impairment was recorded for the other CGUs as the estimated fair value of the CGUs was greater than 
their carrying value. 

Intangible assets with definite lives are amortized to income on either a straight-line or an accelerated basis over a period not exceeding 
15 years, depending on the nature of the asset. We test intangible assets with definite lives for impairment when circumstances indicate that the 
carrying value may not be recoverable. 

Intangible assets with indefinite lives are tested annually for impairment. If an intangible asset is determined to be impaired, it will be written 

down to its recoverable amount, the higher of value in use and fair value less costs to sell, when this is less than the carrying value. 

Additional information regarding the composition of goodwill and intangible assets is included in Note 11 of the consolidated financial 

statements. 

Insurance-Related Liabilities 
Insurance claims and policy benefit liabilities represent current claims and estimates of future insurance policy obligation liabilities. Liabilities for life 
insurance contracts are determined using the Canadian Asset Liability Method, which incorporates best-estimate assumptions for mortality, morbidity, 
policy lapses, surrenders, future investment yields, policy dividends, administration costs and margins for adverse deviation. These assumptions are 
reviewed at least annually and updated to reflect actual experience and market conditions. The most significant potential impact on the valuation of 
these liabilities would result from a change in the assumptions for interest rates and equity market values. If the assumed future interest rates were 
to increase by one percentage point, earnings before tax would increase by approximately $48 million. A reduction of one percentage point would 
lower earnings before tax by approximately $48 million. If the assumed equity market value increased by 10%, earnings before tax would increase 
by approximately $22 million. A reduction of 10% would lower earnings before tax by approximately $22 million. 

Additional information on insurance-related liabilities is provided in Note 14 of the consolidated financial statements, and information on 

insurance risk is provided in the Insurance Risk section. 

BMO Financial Group 204th Annual Report 2021  117 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Provisions 
A provision is recognized if, as a result of a past event, we have a present legal or constructive obligation that can be estimated reliably, and it is 
probable that an outflow of economic benefits will be required to settle the obligation. Provisions are recorded at the best estimate of the amount 
required to settle any obligation as at the balance sheet date, considering the risks and uncertainties surrounding the obligation. For example, BMO 
and its subsidiaries are involved in various legal actions in the ordinary course of business. Factors considered in making the estimate for any 
obligation related to these legal actions include a case-by-case assessment of specific facts and circumstances, past experience and the opinions of 
legal experts. Management and internal and external experts are involved in estimating any amounts that may be required. Certain provisions also 
relate to restructuring initiatives that we have undertaken. These restructuring provisions are recorded at management’s best estimate of the 
amounts that will ultimately be paid out. 

The actual costs of settling some obligations may be substantially higher or lower than the amount of the provisions. 
Additional information regarding provisions is included in the Legal and Regulatory Risk section and in Note 24 of the consolidated financial 

statements. 

A
&
D
M

Leases 
We enter into leases as a lessee for which we recognize a lease liability and a corresponding right-of-use asset. In calculating our lease liability and 
corresponding right-of-use asset, we assess whether a contract is a lease by determining if we have the right to control the asset based on our ability 
to make decisions or direct how and for what purpose the asset is used. In accounting for leases, we must evaluate the lease term based on the 
terms of the lease contract, including any extension or termination options that we are reasonably certain to exercise based on the economic 
rationale underlying the decision. In addition, for leases where the interest cost is explicitly stated, we must estimate our incremental borrowing 
rate to discount the related lease liabilities, based on our expected costs of secured borrowing for the lease term. 

Additional information on leases is provided in Note 9 of the consolidated financial statements. 

Transfer of Financial Assets 
We sell Canadian mortgage loans to third-party Canadian securitization programs, including the Canada Mortgage Bond Program, and directly to 
third-party investors under the National Housing Act Mortgage-Backed Securities program. During 2020, we also participated in programs offered by 
the Canadian and U.S. governments in response to the COVID-19 pandemic to support businesses facing economic hardship, including the Canada 
Emergency Business Account (CEBA) program and the Business Development Bank of Canada (BDC) Co-Lending program. We assess whether 
substantially all of the risks and rewards of the loans have been transferred in order to determine if they qualify for derecognition. Where we 
continue to be exposed to substantially all of the prepayment, interest rate and/or credit risk associated with the securitized loans, they do not 
qualify for derecognition. We continue to recognize the loans, and we recognize the related cash proceeds as secured financing on our Consolidated 
Balance Sheet. 

Additional information concerning the transfer of financial assets is included in the Off-Balance Sheet Arrangements section, as well as in Note 6 

of the consolidated financial statements. 

Consolidation of Structured Entities 
In the normal course of business, we enter into arrangements with SEs, using them to secure customer transactions or transfer assets to obtain 
sources of liquidity by securitizing financial assets, or pass our credit risk to holders of the vehicles’ securities. For example, we enter into transactions 
with SEs where we transfer assets, including mortgage loans, mortgage-backed securities, credit card loans, real estate lines of credit, auto loans and 
equipment loans, in order to obtain alternate sources of funding, or as part of our trading activities. We are required to consolidate a SE if we control 
the SE. We control a SE when we have power over the SE, exposure or rights to variable returns as a result of our involvement, and the ability to 
exercise power to affect the amount of those returns. 

Additional information concerning interests in SEs is included in the Off-Balance Sheet Arrangements section, as well as in Note 7 of the 

consolidated financial statements. 

Caution 
This Critical Accounting Estimates section contains forward-looking statements. Please refer to the Caution Regarding Forward-Looking Statements. 

118  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Changes in Accounting Policies in 2021 

IBOR Reform — Phase 2 amendments 
Effective November 1, 2020, we early adopted Phase 2 amendments to IFRS 9, Financial Instruments, IAS 39, Financial Instruments: Recognition and 
Measurement (IAS 39), IFRS 7, Financial Instruments: Disclosures, and IFRS 4, Insurance Contracts, as well as IFRS 16, Leases. These amendments 
address issues that arise from the implementation of IBOR reform, where IBORs are replaced with alternative benchmark rates. 

For financial instruments at amortized cost, the amendments introduce a practical expedient such that if a change in the contractual cash flows is 

as a result of IBOR reform and occurs on an economically equivalent basis, the change will be accounted for by updating the effective interest rate 
with no immediate gain or loss recognized. The amendments also provide additional temporary relief from the application of specific IAS 39 hedge 
accounting requirements to hedging relationships affected by IBOR reform. For example, there is an exception from the requirement to discontinue 
hedge accounting as a result of changes to hedge documentation required solely by IBOR reform. The amendments also require additional disclosure 
that allows users to understand the impact of IBOR reform on our financial instruments and risk management strategy. 

Further details are provided in Note 1 of the consolidated financial statements. 

Conceptual Framework 
Effective November 1, 2020, we adopted the revised Conceptual Framework (Framework), which sets out the fundamental concepts for financial 
reporting to ensure consistency in standard-setting decisions and that similar transactions are treated in a similar way, so as to provide useful 
information to users of financial statements. The revised Framework had no impact on our accounting policies. 

M
D
&
A

Future Changes in Accounting Policies 

IFRS 17, Insurance Contracts (IFRS 17) 
In June 2020, the IASB issued amendments to IFRS 17, Insurance Contracts (IFRS 17). The amendments include a deferral of the effective date for 
IFRS 17, resulting in a new adoption date for the bank of November 1, 2023 instead of November 1, 2022. They also include amendments to simplify 
and revise certain requirements, and provide additional transition relief. We continue to assess the impact of the standard on our future financial 
results. Further information on these amendments can be found in Note 1 of the consolidated financial statements. 

Caution 
This Future Changes in Accounting Policies section contains forward-looking statements. Please refer to the Caution Regarding Forward-Looking Statements. 

Transactions with Related Parties 
In the ordinary course of business, we provide banking services to key management personnel on the same terms that we offer these services to 
preferred customers. Key management personnel are defined as those persons having authority and responsibility for planning, directing and/or 
controlling the activities of an entity, being the directors and the most senior executives of the bank. Banking services are provided to joint ventures 
and equity-accounted investees on the same terms offered to customers for these services. We also offer employees a subsidy on annual credit 
card fees. 

Details of our investments in joint ventures and associates and the compensation of key management personnel are disclosed in Note 27 of the 

consolidated financial statements. 

BMO Financial Group 204th Annual Report 2021  119 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MANAGEMENT’S DISCUSSION AND ANALYSIS 

Shareholders’ Auditors’ Services and Fees 

Review of Shareholders’ Auditors 
The Audit and Conduct Review Committee (ACRC) is responsible for the appointment, compensation and oversight of the shareholders’ auditors and 
conducts an annual assessment of the performance and effectiveness of the shareholders’ auditors, considering factors such as: the quality of the 
services provided by the engagement team of the shareholders’ auditors during the audit period; the qualifications, experience and geographical 
reach relevant to serving BMO Financial Group; the quality of communications received from the shareholders’ auditors; and the independence, 
objectivity and professional skepticism of the shareholders’ auditors. 

The ACRC believes that it has a robust review process in place to monitor audit quality and oversee the work of the shareholders’ auditors, 

including the lead audit partner, which includes: 
•   Annually reviewing the audit plan in two separate meetings, including a consideration of the impact of business risks on the audit plan and an 

assessment of the reasonableness of the audit fee 

•   Reviewing the qualifications of the senior engagement team members 
•   Monitoring the execution of the audit plan of the shareholders’ auditors, with emphasis on the more complex and challenging areas of the audit 
•   Reviewing and evaluating the audit findings, including in camera sessions 
•   Evaluating audit quality and performance, including recent Canadian Public Accountability Board (CPAB) and Public Company Accounting Oversight 

Board (PCAOB) inspection reports on the shareholders’ auditors and their peer firms 

•   At a minimum, holding quarterly meetings with the chair of the ACRC and the lead audit partner to discuss audit-related issues independently 

A
&
D
M

of management 

•   Performing a comprehensive review of the shareholders’ auditors every five years, and performing an annual review between these 

comprehensive reviews, following the guidelines set out by the Chartered Professional Accountants of Canada (CPA Canada) and the CPAB. 

In 2021, an annual review of the shareholders’ auditors was completed. Input was sought from ACRC members and management on areas such 
as communication effectiveness, industry insights, audit performance, independence and professional skepticism. In addition, the most recent 
comprehensive review was completed in 2020, based on the latest recommendations of CPA Canada and CPAB. These reviews focused on: 
(i) the independence, objectivity and professional skepticism of the shareholders’ auditors; (ii) the quality of the engagement team; and 
(iii) the quality of communications and interactions with the shareholders’ auditors. As a result of the review, the ACRC was satisfied with the 
performance of the shareholders’ auditors. 

Independence of the shareholders’ auditors is overseen by the ACRC in accordance with BMO’s Auditor Independence Standard. The ACRC also 

ensures that the lead audit partner rotates out of that role after five consecutive years and does not return to that role for a further five years. 

Pre-Approval Policies and Procedures 
As part of BMO Financial Group’s corporate governance practices, the ACRC oversees the application of its policy limiting the services provided by 
the shareholders’ auditors that are not related to their role as auditors. All services must comply with our Auditor Independence Standard, as well as 
professional standards and securities regulations governing auditor independence. The ACRC pre-approves the types of services (permitted services) 
that can be provided by the shareholders’ auditors, as well as the annual audit plan, which includes fees for specific types of services. For permitted 
services that are not included in the pre-approved annual audit plan, approval to proceed with the engagement is obtained in accordance with our 
Auditor Independence Standard. 

Shareholders’ Auditors’ Fees 

(Canadian $ in millions) 
Fees (1) 

Audit fees 
Audit-related fees (2) 
Tax services fees (3) 
All other fees (4) 

Total 

2021 

25.2 
3.4 
0.1 
1.3 

30.0 

2020 

22.3 
2.9 
0.1 
1.5 

26.8 

(1)  The classification of fees is based on applicable Canadian securities laws and U.S. Securities and 

Exchange Commission definitions. 

(2)  Includes fees paid for specified procedures on BMO’s Proxy Circular and other services, and French 
translation of financial statements, related continuous disclosures and other public documents 
containing financial information. 

(3)  Includes fees paid for tax compliance services provided to various BMO-managed investment company 

complexes. 

(4)  Includes other fees paid by BMO-managed investment company complexes. 

Certain comparative figures have been reclassified to conform with the current year’s presentation. 

120  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Management’s Annual Report on Disclosure Controls and Procedures
and Internal Control over Financial Reporting 

Disclosure Controls and Procedures 
Disclosure controls and procedures are designed to provide reasonable assurance that all relevant information is gathered and reported to senior 
management, including the Chief Executive Officer (CEO) and the Chief Financial Officer (CFO), on a timely basis, so that appropriate decisions can be 
made regarding public disclosure. 

As at October 31, 2021, under the supervision of the CEO and the CFO, BMO Financial Group’s (BMO) management evaluated the effectiveness of 
the design and operation of its disclosure controls and procedures, as defined in Canada by National Instrument 52-109, Certification of Disclosure in 
Issuers’ Annual and Interim Filings, and in the United States by Rule 13a-15(e) under the Securities Exchange Act of 1934 (the Exchange Act). Based 
on this evaluation, the CEO and the CFO have concluded that the bank’s disclosure controls and procedures were effective as at October 31, 2021. 

Internal Control over Financial Reporting 
Internal control over financial reporting is a process designed under the supervision of the bank’s CEO and CFO, to provide reasonable assurance 
regarding the reliability of financial reporting and the preparation of consolidated financial statements in accordance with IFRS and the requirements 
of the Securities and Exchange Commission (SEC) in the United States, as applicable. Management is responsible for establishing and maintaining 
adequate internal control over financial reporting for BMO. 

M
D
&
A

Internal control over financial reporting at BMO includes policies and procedures that: 
•   Pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of 

BMO 

•   Are designed to provide reasonable assurance that transactions are recorded as necessary to permit preparation of the consolidated financial 
statements in accordance with IFRS and the requirements of the SEC in the United States, as applicable, and that receipts and expenditures of 
BMO are being made only in accordance with authorizations by management and directors of BMO, and 

•   Are designed to provide reasonable assurance that any unauthorized acquisition, use or disposition of BMO’s assets that could have a material 

effect on the consolidated financial statements is prevented or detected in a timely manner 

Because of its inherent limitations, internal control over financial reporting can provide only reasonable assurance and may not prevent or detect 
misstatements. Furthermore, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become 
inadequate because of changes in conditions, or that the degree of compliance with the related policies and procedures may deteriorate. 

BMO’s management, under the supervision of the CEO and the CFO, has evaluated the effectiveness of internal control over financial reporting 
using the framework and criteria established in Internal Control – Integrated Framework, issued by the Committee of Sponsoring Organizations of the 
Treadway Commission in May 2013 (2013 COSO Framework). Based on this evaluation, management has concluded that internal control over financial 
reporting was effective as at October 31, 2021. 

At the request of BMO’s Audit and Conduct Review Committee, KPMG LLP (the shareholders’ auditors), an independent registered public 
accounting firm, has conducted an audit of the effectiveness of our internal control over financial reporting. The audit report states in its conclusion 
that, in KPMG’s opinion, BMO maintained, in all material respects, effective internal control over financial reporting as at October 31, 2021, in 
accordance with the criteria established in the 2013 COSO Framework. 

Changes in Internal Control over Financial Reporting 
There were no changes in our internal control over financial reporting during the year ended October 31, 2021 that have materially affected, or are 
reasonably likely to materially affect, the adequacy and effectiveness of our internal control over financial reporting. 

BMO Financial Group 204th Annual Report 2021  121 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
SUPPLEMENTAL INFORMATION 

Supplemental Information 

Certain comparative figures have been reclassified to conform with the current year’s presentation and for changes in accounting policies. Refer to Note 1 of the 
consolidated financial statements. 

Certain measures and ratios as provided in this section are non-GAAP as indicated. For further information on non-GAAP measures and ratios, please refer to the 
Non-GAAP and Other Financial Measures section. 

For further information regarding the composition of non-GAAP and other financial measures, including supplementary financial measures, refer to the Glossary of 
Financial Terms. 

Table 1: Shareholder Value and Other Statistical Information 

As at or for the year ended October 31 

2021 

2020 

2019 

2018 

2017 

2016 

2015 

2014 

2013 

2012 

Market Price per Common Share ($) 
High 
Low 
Close 

Common Share Dividends 
Dividends declared per share ($) 
Dividend payout ratio (%) (1) 
Dividend yield (%) 
Dividends on common shares ($ millions) 

Total Shareholder Return (%) 
Five-year average annual return 
Three-year average annual return 
One-year return 

Common Share Information 
Number outstanding (in thousands) 

End of year 
Average basic 
Average diluted 

Book value per share ($) 
Market capitalization ($ billions) 
Price-to-earnings multiple 
Price-to-adjusted earnings multiple 
Market-to-book value multiple 

Balances ($ millions) 
Total assets 
Average assets 
Average net loans and acceptances 

n
o
i
t
a
m
r
o
f
n
I

l
a
t
n
e
m
e
l
p
p
u
S

138.67 
78.82 
134.37 

104.75 
55.76 
79.33 

106.51 
86.25 
97.50 

109.00 
93.60 
98.43 

104.15 
83.58 
98.83 

4.24 
36.5 
3.2 
2,746 

4.24 
56.1 
5.3 
2,723 

14.0 
15.7 
75.9 

5.1 
(3.1) 
(14.6) 

4.06 
46.8 
4.2 
2,594 

7.8 
8.6 
3.2 

3.78 
46.1 
3.8 
2,424 

10.5 
13.3 
3.3 

3.56 
44.9 
3.6 
2,312 

15.5 
10.9 
20.2 

87.92 
68.65 
85.36 

3.40 
49.0 
4.0 
2,191 

12.5 
9.9 
17.0 

84.39 
64.01 
76.04 

3.24 
49.2 
4.3 
2,087 

9.5 
13.5 
(3.0) 

85.71 
67.04 
81.73 

3.08 
47.8 
3.8 
1,991 

15.5 
16.7 
17.1 

73.90 
56.74 
72.62 

2.94 
47.5 
4.0 
1,904 

17.0 
11.5 
28.8 

61.29 
53.15 
59.02 

2.82 
46.0 
4.8 
1,820 

4.2 
10.8 
5.2 

648,136 
647,163 
648,676 
80.18 
87.1 
11.6 
10.4 
1.68 

645,889 
641,424 
642,128 
77.40 
51.2 
10.5 
10.3 
1.02 

639,232 
638,881 
640,360 
71.54 
62.3 
11.3 
10.3 
1.36 

639,330 
642,930 
644,913 
64.73 
62.9 
12.0 
10.9 
1.52 

647,816 
649,650 
651,961 
61.91 
64.0 
12.5 
12.1 
1.60 

645,761 
644,049 
646,126 
59.57 
55.1 
12.3 
11.4 
1.43 

642,583 
644,916 
647,141 
56.31 
48.9 
11.6 
10.9 
1.35 

649,050 
645,860 
648,475 
48.18 
53.0 
12.8 
12.4 
1.70 

644,130  650,730 
648,476  644,407 
649,806  648,615 
39.41 
38.4 
9.7 
9.9 
1.47 

43.22 
46.8 
11.8 
11.7 
1.66 

988,175 
981,140 
463,235 

949,261 
942,450 
466,886 

852,195 
833,252 
433,170 

773,293 
754,295 
387,005 

709,604 
722,626 
370,899 

687,960 
707,122 
356,528 

641,881 
664,391 
318,823 

588,659 
593,928 
290,621 

537,044  524,684 
555,431  543,931 
263,596  246,129 

Average common shareholders’ equity (1) 

Goodwill and acquisition-related intangible assets 

50,451 
(5,946) 

48,235 
(6,750) 

44,170 
(6,714) 

39,754 
(6,628) 

38,962 
(6,818) 

36,997 
(7,101) 

34,135 
(6,720) 

29,680 
(5,303) 

26,956 
(4,097) 

24,863 
(4,066) 

Average tangible common equity (1) (2) 

44,505 

41,485 

37,456 

33,126 

32,144 

29,896 

27,415 

24,377 

22,859 

20,797 

Return on Equity and Assets 
Return on equity (%) (1) 
Adjusted return on equity (%) (1) (2) 
Return on tangible common equity (%) (1) (2) 
Adjusted return on tangible common equity (%) (1) (2) 
Return on average assets (%) (1) 
Adjusted return on average assets (%) (1) (2) 
Return on average risk-weighted assets (%) (3) 
Adjusted return on average risk-weighted assets (%) (3) 

14.9 
16.7 
17.0 
18.9 
0.79 
0.88 
2.38 
2.66 

10.1 
10.3 
11.9 
11.9 
0.54 
0.55 
1.51 
1.54 

12.6 
13.7 
15.1 
16.1 
0.69 
0.75 
1.86 
2.01 

13.3 
14.6 
16.2 
17.5 
0.72 
0.79 
1.97 
2.16 

13.2 
13.6 
16.3 
16.4 
0.74 
0.76 
1.98 
2.04 

12.1 
13.1 
15.3 
16.1 
0.65 
0.71 
1.71 
1.85 

12.5 
13.3 
15.8 
16.4 
0.66 
0.70 
1.84 
1.96 

14.0 
14.4 
17.3 
17.4 
0.72 
0.74 
1.85 
1.91 

14.9 
15.0 
17.9 
17.7 
0.74 
0.75 
1.93 
1.94 

15.9 
15.5 
19.4 
18.5 
0.75 
0.73 
1.96 
1.92 

Other Statistical Information 
Employees (4) 
Canada 
United States 
Other 

Total 

Bank branches 

Canada 
United States 
Other 

Total 

Automated banking machines 

Canada 
United States 

Total 

30,350 
12,090 
1,423 

29,296 
12,492 
1,572 

30,438 
13,487 
1,588 

29,982 
13,943 
1,529 

29,647 
14,071 
1,482 

29,643 
14,147 
1,444 

30,669 
14,316 
1,368 

30,587 
14,845 
1,346 

30,303 
14,694 
634 

30,797 
14,963 
512 

43,863 

43,360 

45,513 

45,454 

45,200 

45,234 

46,353 

46,778 

45,631 

46,272 

877 
524 
4 

877 
528 
4 

891 
561 
4 

908 
571 
4 

926 
573 
4 

942 
576 
4 

939 
592 
4 

934 
615 
4 

933 
626 
4 

930 
638 
3 

1,405 

1,409 

1,456 

1,483 

1,503 

1,522 

1,535 

1,553 

1,563 

1,571 

3,312 
1,539 

4,851 

3,268 
1,552 

4,820 

3,370 
1,597 

4,967 

3,387 
1,441 

4,828 

3,315 
1,416 

4,731 

3,285 
1,314 

4,599 

3,442 
1,319 

4,761 

3,016 
1,322 

4,338 

2,900 
1,325 

2,596 
1,375 

4,225 

3,971 

The adoption of new IFRS standards in 2014, 2015, 2018 and 2020 only impacted our results prospectively. 

(1)  For further information regarding the composition of non-GAAP and other financial measures, including supplementary financial measures, refer to the Glossary of Financial Terms. 
(2)  These measures are non-GAAP. Further information on the use of non-GAAP measures and ratios is provided in the Non-GAAP and Other Financial Measures section. 
(3)  Risk-weighted assets are disclosed in accordance with OSFI’s Capital Adequacy Requirements (CAR) Guideline. 
(4)  Reflects full-time equivalent number of employees, comprising full-time and part-time employees and adjustments for overtime hours. 

122  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 2: Summary Income Statement and Growth Statistics 

($ millions, except as noted) 
For the year ended October 31 

2021 

2020 

2019 

2018 

2017 

5-year 
CAGR 

10-year 
CAGR 

Reported Results 
Revenue 
Insurance claims, commissions and changes in policy benefit liabilities (CCPB) 

Revenue, net of CCPB (1) 
Provision for credit losses 
Non-interest expense 

Income before income taxes 
Provision for income taxes 

Net income 

Attributable to equity holders of the bank 
Attributable to non-controlling interest in subsidiaries 

Net income 

Adjusting Items impacting Revenue (Pre-tax) 
Impact of divestitures 

Adjusting Items impacting Provision for Credit Losses (Pre-tax) 
Decrease in the collective allowance for credit losses 

Adjusting Items impacting CCPB (Pre-tax) 
Reinsurance adjustment 

Adjusting Items impacting Non-Interest Expense (Pre-tax) 
Acquisition integration costs 
Amortization of acquisition-related intangible assets 
Impact of divestitures 
Restructuring (costs) reversals 
Benefit from the remeasurement of an employee benefit liability 

Adjusting items included in reported pre-tax income 

Impact on tax of adjusting items 

Total of adjusting items included in reported net income after tax 
Impact on diluted EPS ($) 

Adjusted Results (1) 
Revenue 
Insurance claims, commissions and changes in policy benefit liabilities (CCPB) 

Revenue, net of CCPB 
Provision for credit losses 
Non-interest expense 

Income before income taxes 
Provision for income taxes 

Net income 

Attributable to equity holders of the bank 
Attributable to non-controlling interest in subsidiaries 

Adjusted net income 

Earnings per Share (EPS) ($) 
Basic 
Diluted 
Adjusted diluted (1) 

Year-over-Year Growth-Based Statistical Information (%) 
Net income growth 
Adjusted net income growth (1) 
Diluted EPS growth 
Adjusted diluted EPS growth (1) 

Five-year and ten-year CAGR based on CGAAP in 2011 and IFRS in 2016 and 2021. 

The adoption of new IFRS standards in 2018 and 2020 only impacted our results prospectively. 

27,186 
(1,399) 

25,787 
(20) 
(15,509) 

10,258 
(2,504) 

7,754 

7,754 
– 

7,754 

25,186 
(1,708) 

23,478 
(2,953) 
(14,177) 

6,348 
(1,251) 

5,097 

5,097 
– 

5,097 

25,483 
(2,709) 

22,774 
(872) 
(14,630) 

7,272 
(1,514) 

5,758 

5,758 
– 

5,758 

22,905 
(1,352) 

21,553 
(662) 
(13,477) 

7,414 
(1,961) 

5,453 

5,453 
– 

5,453 

22,107 
(1,538) 

20,569 
(746) 
(13,192) 

6,631 
(1,292) 

5,339 

5,337 
2 

5,339 

5.3 
(1.9) 

5.8 
nm 
3.7 

12.4 
17.9 

10.9 

10.9 
nm 

10.9 

6.1 
2.3 

6.3 
nm 
5.9 

9.9 
11.1 

9.6 

9.8 
nm 

9.8 

– 

na 

na 

 76

 na 

na 

– 

na 

29 

– 

– 

(9) 
(88) 
(886) 
24 
– 

(930) 

33 

(897) 
(1.38) 

27,157 
(1,399) 

25,758 
(20) 
(14,550) 

11,188 
(2,537) 

8,651 

8,651 
– 

8,651 

11.60 
11.58 
12.96 

52.1 
66.3 
53.3 
68.0 

– 

–

– 

(14) 
(121) 
– 
– 
– 

(135) 

31 

(104) 
(0.16) 

25,186 
(1,708) 

23,478 
(2,953) 
(14,042) 

6,483 
(1,282) 

5,201 

5,201 
– 

5,201 

7.56 
7.55 
7.71 

(11.5) 
(16.8) 
(12.8) 
(18.2) 

– 

 –

(25) 

(13) 
(128) 
– 
(484) 
– 

(650) 

159 

(491) 
(0.77) 

– 

 –

– 

(34) 
(116) 
– 
(260) 
277 

(133) 

(396) 

(529) 
(0.82) 

(87) 
(149) 
– 
(59) 
– 

(219) 

61 

(158) 
(0.25) 

25,483 
(2,684) 

22,799 
(872) 
(14,005) 

7,922 
(1,673) 

6,249 

6,249 
– 

6,249 

22,905 
(1,352) 

21,553 
(662) 
(13,344) 

7,547 
(1,565) 

5,982 

5,982 
– 

5,982 

22,107 
(1,538) 

20,569 
(822) 
(12,897) 

6,850 
(1,353) 

5,497 

5,495 
2 

5,497 

8.68 
8.66 
9.43 

5.6 
4.5 
6.0 
4.9 

8.19 
8.17 
8.99 

2.1 
8.8 
3.3 
10.3 

7.93 
7.90 
8.15 

15.3 
9.5 
14.3 
8.3 

S
u
p
p
l
e
m
e
n
t
a
l

I
n
f
o
r
m
a
t
i
o
n

na 

na 
na 
na 
na 
na 

na 

na 

na 
na 

6.2 
2.3 

6.5 
nm 
5.6 

10.3 
10.8 

10.2 

10.2 
nm 

10.2 

9.0 
9.1 
9.8 

na 
na 
na 
na 

na 
na 
na 
na 
na 

na 

na 

na 
na 

5.2 
(1.9) 

5.7 
nm 
3.1 

12.3 
15.2 

11.5 

11.5 
nm 

11.5 

10.8 
10.8 
11.5 

na 
na 
na 
na 

(1)  These measures are non-GAAP. Further information on the use of non-GAAP measures and ratios is provided in the Non-GAAP and Other Financial Measures section. 

nm – not meaningful 

na – not applicable 

BMO Financial Group 204th Annual Report 2021  123 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
SUPPLEMENTAL INFORMATION 

Table 3: Revenue and Revenue Growth 

($ millions, except as noted) 
For the year ended October 31 

Net Interest Income 

Year-over-year growth (%) 

Net Interest Margin (1) 
Average earning assets 
Net interest margin (%) 

Non-Interest Revenue 
Securities commissions and fees 
Deposit and payment service charges 
Trading revenues 
Lending fees 
Card fees 
Investment management and custodial fees 
Mutual fund revenues 
Underwriting and advisory fees 
Securities gains, other than trading 
Foreign exchange, other than trading 
Insurance revenue 
Investments in associates and joint ventures 
Other revenues 

Total Non-Interest Revenue 

Year-over-year non-interest revenue growth (%) 
Non-interest revenue as a % of total revenue 

Adjusted Non-Interest Revenue (2) 

Year-over-year adjusted non-interest revenue growth (%) 
Adjusted non-interest revenue as a % of total adjusted revenue (2) 

2021 

2020 

2019 

2018 

2017 

14,310 
2.4 

13,971 
8.4 

12,888 
12.7 

11,438 
1.4 

11,275 
3.0 

897,302 
1.59 

853,336 
1.64 

759,395 
1.70 

682,991 
1.67 

646,799 
1.74 

1,107 
1,243 
296 
1,391 
442 
1,982 
1,595 
1,421 
591 
167 
1,941 
248 
452 

12,876 
14.8 
47.4 

12,847 
14.5 
47.3 

1,036 
1,221 
15 
1,295 
358 
1,807 
1,417 
1,070 
124 
127 
2,178 
161 
406 

11,215 
(11.0) 
44.5 

11,215 
(11.0) 
44.5 

1,023 
1,204 
298 
1,192 
437 
1,747 
1,419 
975 
249 
166 
3,183 
151 
551 

12,595 
9.8 
49.4 

12,595 
9.8 
49.4 

1,025 
1,134 
705 
997 
428 
1,749 
1,473 
943 
239 
182 
1,879 
167 
546 

11,467 
5.9 
50.1 

11,467 
5.9 
50.1 

964 
1,109 
84 
917 
329 
1,627 
1,411 
1,044 
171 
191 
2,070 
386 
529 

10,832 
8.2 
49.0 

10,832 
7.3 
49.0 

Total Revenue 

Year-over-year total revenue growth (%) 

27,186 
7.9 

25,186 
(1.2) 

25,483 
11.3 

22,905 
3.6 

22,107 
5.5 

Total Revenue, net of CCPB (2) 

Year-over-year total revenue growth, net of CCPB (%) (2) 

25,787 
9.8 

23,478 
3.1 

22,774 
5.7 

Total Adjusted Revenue (2) 

Year-over-year total adjusted revenue growth (%) (2) 

27,157 
7.8 

25,186 
(1.2) 

25,483 
11.3 

Total Adjusted Revenue, net of CCPB (2) 

Year-over-year total adjusted revenue growth, net of CCPB (%) (2) 

25,758 
9.7 

23,478 
3.0 

22,799 
5.8 

21,553 
4.8 

22,905 
3.6 

21,553 
4.8 

20,569 
5.9 

22,107 
5.1 

20,569 
5.5 

5-year 
CAGR 

10-year 
CAGR 

5.5 
na 

7.6 
na 

3.8 
3.1 
20.2 
10.1 
2.2 
4.9 
3.2 
11.5 
47.8 
0.6 
(0.8) 
12.1 
(1.7) 

5.2 
na 
na 

4.9 
na 
na 

5.3 
na 

5.8 
na 

5.2 
na 

5.7 
na 

6.7 
na 

8.3 
na 

(0.9) 
4.1 
(6.0) 
8.9 
(4.3) 
14.9 
9.7 
10.7 
12.1 
2.6 
3.3 
nm 
2.6 

5.4 
na 
na 

5.4 
na 
na 

6.1 
na 

6.3 
na 

6.2 
na 

6.5 
na 

Five-year and ten-year CAGR based on CGAAP in 2011 and IFRS in 2016 and 2021. 

The adoption of new IFRS standards in 2018 and 2020 only impacted our results prospectively. 

(1)  Net interest margin is calculated based on average earning assets, which represents the daily average balance of deposits at central banks, deposits with other banks, securities borrowed or 

purchased under resale agreements, securities, and loans, over a one-year period. 

(2)  These measures are non-GAAP. Further information on the use of non-GAAP measures is provided in the Non-GAAP and Other Financial Measures section. 

na – not applicable 

nm – not meaningful 

n
o
i
t
a
m
r
o
f
n
I

l
a
t
n
e
m
e
l
p
p
u
S

124  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 4: Non-Interest Expense, Expense-to-Revenue Ratio
and Provision for Income Taxes and Other Taxes 

($ millions, except as noted) 
For the year ended October 31 

Non-Interest Expense (1) 
Employee compensation 

Salaries 
Performance-based compensation 
Employee benefits 

Total employee compensation 

Premises and equipment (2) 

Rental of real estate 
Premises, furniture and fixtures 
Property taxes 
Computers and equipment 

Total premises and equipment 

Other expenses 

Travel and business development 
Communications 
Professional fees 
Other 

Total other expenses 

Amortization of intangible assets 

Total Non-Interest Expense 

Year-over-year total non-interest expense growth (%) 

Total Adjusted Non-Interest Expense (3) 

Year-over-year total adjusted non-interest expense growth (%) 

Non-interest expense-to-revenue ratio (Efficiency ratio) (%) (4) 
Adjusted non-interest expense-to-revenue ratio (Adjusted efficiency ratio) (%) (3) (4) 
Efficiency ratio, net of CCPB (%) (3) (4) 
Adjusted efficiency ratio, net of CCPB (%) (3) (4) 

Provision for Income Taxes and Other Taxes 

Payroll levies 
Property taxes 
Provincial capital taxes 
Business taxes 
Harmonized sales tax, GST, VAT and other sales taxes 
Sundry taxes 

Total government levies other than income taxes (other taxes) (1) 

Provision for income taxes 

Provision for Income Taxes and Other Taxes 

Provision for income taxes and other taxes as a % of income before total 

government levies and taxes (1) (3) 

Effective tax rate (%) 
Adjusted effective tax rate (%) (3) 

Five-year and ten-year CAGR based on CGAAP in 2011 and IFRS in 2016 and 2021. 

The adoption of new IFRS standards in 2018 and 2020 only impacted our results prospectively. 

2021 

2020 

2019 

2018 

2017 

5-year 
CAGR 

10-year 
CAGR 

4,041 
3,152 
1,129 

8,322 

231 
794 
36 
2,335 

3,396 

397 
264 
607 
1,889 

3,157 

634 

4,163 
2,632 
1,149 

7,944 

225 
771 
42 
2,164 

3,202 

384 
304 
555 
1,168 

2,411 

620 

4,762 
2,610 
1,051 

8,423 

595 
283 
37 
2,073 

2,988 

545 
296 
568 
1,256 

2,665 

554 

4,176 
2,510 
775 

7,461 

526 
345 
38 
1,844 

2,753 

519 
282 
572 
1,387 

2,760 

503 

3,996 
2,386 
1,086 

7,468 

494 
282 
39 
1,676 

2,491 

540 
286 
569 
1,353 

2,748 

485 

15,509 
9.4 

14,550 
3.6 

14,177 
(3.1) 

14,042 
0.3 

14,630 
8.6 

14,005 
5.0 

13,477 
2.2 

13,344 
3.5 

13,192 
2.1 

12,897 
3.5 

57.0 
53.6 
60.1 
56.5 

355 
36 
36 
10 
382 
1 

820 

56.3 
55.8 
60.4 
59.8 

362 
42 
33 
9 
397 
1 

844 

57.4 
55.0 
64.2 
61.4 

354 
37 
35 
9 
384 
1 

820 

58.8 
58.3 
62.5 
61.9 

328 
38 
29 
8 
350 
1 

754 

59.7 
58.3 
64.1 
62.7 

322 
39 
29 
8 
330 
1 

729 

2,504 

3,324 

1,251 

2,095 

1,514 

2,334 

1,961 

2,715 

1,292 

2,021 

30.0 
24.4 
22.7 

29.1 
19.7 
19.8 

28.8 
20.8 
21.1 

33.3 
26.5 
20.7 

27.5 
19.5 
19.8 

(0.2) 
6.7 
2.0 

2.4 

(13.9) 
18.7 
(3.0) 
8.9 

7.3 

(4.9) 
(2.1) 
2.8 
6.7 

3.2 

7.4 

3.7 
na 

3.1 
na 

na 
na 
na 
na 

1.9 
(3.0) 
3.3 
6.9 
3.8 
nm 

2.5 

17.9 

12.7 

na 
na 
na 

4.3 
7.3 
6.2 

5.6 

(4.4) 
9.9 
1.9 
10.3 

8.0 

0.4 
0.2 
(0.3) 
8.0 

4.0 

10.6 

5.9 
na 

5.6 
na 

na 
na 
na 
na 

5.7 
1.9 
(2.1) 
4.0 
5.0 
nm 

4.6 

11.1 

9.0 

na 
na 
na 

S
u
p
p
l
e
m
e
n
t
a
l

I
n
f
o
r
m
a
t
i
o
n

(1)  Other taxes are included in various non-interest expense categories. Total provision for income taxes and other taxes is a non-GAAP financial measure. Information regarding the usefulness of this 

measure is provided in the Provision for Income and Other Taxes section of the annual MD&A. 

(2)  Effective 2020, the bank adopted IFRS 16. Prior periods have not been restated. Depreciation on the right-of-use assets has been recorded in premises, furniture and fixtures. Previously most of our 

real estate leases were classified as operating leases, with rent expense recorded in rental of real estate. 

(3)  These measures and ratios are non-GAAP. Further information is provided in the Non-GAAP and Other Financial Measures section. A quantitative reconciliation of revenue net of CCPB and all adjusted 

results for all years presented is provided in Table 2. 

(4)  For further information regarding the composition of non-GAAP and other financial measures, including supplementary financial measures, refer to the Glossary of Financial Terms. 

na – not applicable 

nm – not meaningful 

BMO Financial Group 204th Annual Report 2021  125 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
n
o
i
t
a
m
r
o
f
n
I

l
a
t
n
e
m
e
l
p
p
u
S

SUPPLEMENTAL INFORMATION 

Table 5: Average Assets, Liabilities and Interest Rates 

($ millions, except as noted) 
For the year ended October 31 

Assets 
Canadian Dollar 
Deposits with other banks and other interest bearing assets 
Securities 
Securities borrowed or purchased under resale agreements 
Loans 

Residential mortgages 
Non-residential mortgages 
Personal and credit cards 
Business and government 

Total loans 

Total Canadian dollar 

U.S. Dollar and Other Currencies 
Deposits with other banks and other interest bearing assets 
Securities 
Securities borrowed or purchased under resale agreements 
Loans 

Residential mortgages 
Non-residential mortgages 
Personal and credit cards 
Business and government 

Total loans 

2021 

2020 

2019 

Average 
balances 

Average 
interest 
rate (%) 

Interest 
income/ 
expense 

Average 
balances 

Average 
interest 
rate (%) 

Interest 
income/ 
expense 

Average 
balances 

Average 
interest 
rate (%) 

Interest 
income/ 
expense 

34,255 
90,140 
43,375 

122,661 
5,368 
66,247 
82,858 

0.23 
1.79 
0.44 

2.58 
3.19 
4.26 
3.37 

79 
1,618 
190 

13,605 
94,343 
44,460 

3,168  114,374 
5,556 
62,920 
73,596 

171 
2,823 
2,796 

0.33 
2.32 
1.05 

2.88 
3.38 
4.95 
3.79 

45 
2,186 
468 

2,972 
83,042 
39,074 

3,296  109,289 
5,637 
60,680 
62,965 

188 
3,116 
2,787 

2.03 
2.66 
2.10 

3.04 
3.43 
5.49 
4.10 

60 
2,210 
820 

3,317 
194 
3,333 
2,580 

277,134 

3.23 

8,958  256,446 

3.66 

9,387  238,571 

3.95 

9,424 

444,904 

2.44  10,845  408,854 

2.96  12,086  363,659 

3.44  12,514 

68,612 
145,504 
62,250 

8,055 
10,684 
13,344 
141,003 

0.18 
1.61 
0.39 

3.02 
3.18 
3.86 
3.71 

124 

61,050 
2,345  124,567 
66,109 

245 

243 
339 
516 

10,499 
10,792 
13,659 
5,230  155,229 

0.62 
2.24 
0.85 

3.35 
3.71 
4.37 
3.96 

376 

47,001 
2,794  109,072 
65,943 

560 

352 
401 
597 

11,554 
9,356 
11,907 
6,149  139,192 

1.72 
3.05 
2.11 

3.67 
4.75 
4.91 
4.78 

808 
3,331 
1,391 

424 
445 
585 
6,654 

173,086 

3.66 

6,328  190,179 

3.94 

7,499  172,009 

4.71 

8,108 

Total U.S. dollar and other currencies 

449,452 

2.01 

9,042  441,905 

2.54  11,229  394,025 

3.46  13,638 

Other non-interest bearing assets 

Total All Currencies 
Total assets and interest income 

Liabilities 
Canadian Dollar 
Deposits 
Banks 
Business and government 
Individuals 

Total deposits 

Securities sold but not yet purchased and securities lent or sold 

under repurchase agreements (1) 

Subordinated debt and other interest bearing liabilities 

Total Canadian dollar 

U.S. Dollar and Other Currencies 
Deposits 
Banks 
Business and government 
Individuals 

Total deposits 

Securities sold but not yet purchased and securities lent or sold 

under repurchase agreements (1) 

Subordinated debt and other interest bearing liabilities 

Total U.S. dollar and other currencies 

Other non-interest bearing liabilities 

Total All Currencies 
Total liabilities and interest expense 
Shareholders’ equity 

86,784 

91,691 

75,568 

981,140 

2.03  19,887  942,450 

2.47  23,315  833,252 

3.14  26,152 

9,616 
157,226 
142,833 

0.35 
0.69 
0.44 

33 

11,715 
1,091  136,976 
622  135,175 

0.68 
1.24 
0.87 

80 

4,905 
1,704  113,502 
1,181  120,852 

1.02 
1.88 
1.05 

50 
2,133 
1,269 

309,675 

0.56 

1,746  283,866 

1.04 

2,965  239,259 

1.44 

3,452 

55,415 
26,704 

0.91 
2.23 

506 
597 

49,676 
26,387 

1.50 
2.69 

747 
711 

44,815 
25,099 

2.56 
2.70 

1,146 
677 

391,794 

0.73 

2,849  359,929 

1.23 

4,423  309,173 

1.71 

5,275 

24,200 
272,380 
71,795 

0.33 
0.45 
0.22 

80 

22,856 
1,234  244,449 
77,930 

160 

1.05 
0.99 
0.78 

241 

24,534 
2,424  211,970 
71,005 

609 

2.41 
1.79 
1.08 

592 
3,802 
770 

368,375 

0.40 

1,474  345,235 

0.95 

3,274  307,509 

1.68 

5,164 

74,376 
13,593 

1.35 
1.83 

1,005 
249 

80,656 
18,207 

1.54 
2.22 

1,243 
404 

76,889 
19,896 

2.91 
2.96 

2,235 
590 

456,344 

0.60 

2,728  444,098 

1.11 

4,921  404,294 

1.98 

7,989 

76,708 

84,683 

70,916 

924,846 
56,294 

0.60 

5,577  888,710 
53,740 

1.05 

9,344  784,383 
48,869 

1.69  13,264 

Total Liabilities, Interest Expense and Shareholders’ Equity 

981,140 

0.57 

5,577  942,450 

0.99 

9,344  833,252 

1.59  13,264 

Net interest margin 

– based on earning assets 
– based on total assets 

Net interest income 

1.59 
1.46 

1.64 
1.48 

1.70 
1.55 

14,310 

13,971 

12,888 

(1)  For the years ended October 31, 2021, 2020 and 2019, the maximum amount of securities lent or sold under repurchase agreements at any month end amounted to $102,567 million, 

$106,695 million and $96,399 million, respectively. 

126  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 6: Volume/Rate Analysis of Changes in Net Interest Income 

($ millions) 
For the year ended October 31 

Assets 
Canadian Dollar 
Deposits with other banks and other interest bearing assets 
Securities 
Securities borrowed or purchased under resale agreements 
Loans 

Residential mortgages 
Non-residential mortgages 
Personal and credit cards 
Business and government 

Total loans 

Change in Canadian dollar interest income 

U.S. Dollar and Other Currencies 
Deposits with other banks and other interest bearing assets 
Securities 
Securities borrowed or purchased under resale agreements 
Loans 

Residential mortgages 
Non-residential mortgages 
Personal and credit cards 
Business and government 

Total loans 

2021/2020 

2020/2019 

Increase (decrease) due to change in 

Increase (decrease) due to change in 

Average 
balance 

Average 
rate 

Total 

Average 
balance 

Average 
rate 

Total 

69 
(98) 
(11) 

239 
(6) 
165 
350 

748 

708 

46 
469 
(32) 

(82) 
(4) 
(13) 
(564) 

(35) 
(470) 
(267) 

(367) 
(11) 
(458) 
(341) 

(1,177) 

34 
(568) 
(278) 

(128) 
(17) 
(293) 
9 

(429) 

216 
301 
113 

154 
(3) 
123 
436 

710 

(231) 
(325) 
(465) 

(175) 
(3) 
(340) 
(229) 

(747) 

(1,949) 

(1,241) 

1,340 

(1,768) 

(298) 
(918) 
(283) 

(27) 
(58) 
(68) 
(355) 

(252) 
(449) 
(315) 

(109) 
(62) 
(81) 
(919) 

242 
473 
3 

(39) 
68 
86 
767 

(674) 
(1,010) 
(834) 

(33) 
(112) 
(74) 
(1,272) 

(663) 

(508) 

(1,171) 

882 

(1,491) 

(15) 
(24) 
(352) 

(21) 
(6) 
(217) 
207 

(37) 

(428) 

(432) 
(537) 
(831) 

(72) 
(44) 
12 
(505) 

(609) 

Change in U.S. dollar and other currencies interest income 

(180) 

(2,007) 

(2,187) 

1,600 

(4,009) 

(2,409) 

Total All Currencies 
Change in total interest income (a) 

Liabilities 
Canadian Dollar 
Deposits 
Banks 
Business and government 
Individuals 

Total deposits 

Securities sold but not yet purchased and securities lent or sold 

under repurchase agreements 

Subordinated debt and other interest bearing liabilities 

Change in Canadian dollar interest expense 

U.S. Dollar and Other Currencies 
Deposits 
Banks 
Business and government 
Individuals 

Total deposits 

Securities sold but not yet purchased and securities lent or sold 

under repurchase agreements 

Subordinated debt and other interest bearing liabilities 

528 

(3,956) 

(3,428) 

2,940 

(5,777) 

(2,837) 

(15) 
252 
67 

(32) 
(865) 
(626) 

(47) 
(613) 
(559) 

304 

(1,523) 

(1,219) 

86 
9 

(327) 
(123) 

(241) 
(114) 

399 

(1,973) 

(1,574) 

70 
441 
150 

661 

125 
35 

821 

(40) 
(870) 
(238) 

(1,148) 

(524) 
(1) 

(1,673) 

30 
(429) 
(88) 

(487) 

(399) 
34 

(852) 

14 
277 
(48) 

(175) 
(1,467) 
(401) 

(161) 
(1,190) 
(449) 

(40) 
582 
75 

(311) 
(1,960) 
(236) 

(351) 
(1,378) 
(161) 

243 

(2,043) 

(1,800) 

617 

(2,507) 

(1,890) 

(97) 
(102) 

(141) 
(53) 

(238) 
(155) 

109 
(50) 

(1,101) 
(136) 

(992) 
(186) 

Change in U.S. dollar and other currencies interest expense 

44 

(2,237) 

(2,193) 

676 

(3,744) 

(3,068) 

Total All Currencies 
Change in total interest expense (b) 

Change in total net interest income (a – b) 

443 

(4,210) 

(3,767) 

1,497 

(5,417) 

(3,920) 

85 

254 

339 

1,443 

(360) 

1,083 

S
u
p
p
l
e
m
e
n
t
a
l

I
n
f
o
r
m
a
t
i
o
n

BMO Financial Group 204th Annual Report 2021  127 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
SUPPLEMENTAL INFORMATION 

Table 7: Net Loans and Acceptances – 

Segmented Information (1) (2) 

($ millions) 

As at October 31 

Consumer 

Residential mortgages 
Credit cards 
Consumer instalment and 
other personal loans 

Total consumer 
Total business and 
government 

Total loans and acceptances, 
net of allowance for credit 
losses on impaired loans 

Allowance for credit losses 
on performing loans (3) 

Total net loans and 
acceptances 

Canada 

United States 

Other countries 

2021 

2020 

2019 

2018 

2017 

2021 

2020 

2019 

2018 

2017 

2021 

2020 

2019 

2018 

2017 

128,020  117,886  112,448  107,956  106,647 
7,550 

7,642 

7,788 

7,391 

8,289 

7,718 
461 

9,122  11,275  11,645 
541 
570 

498 

8,587 
521 

63,841 

57,288  55,311  52,706  51,637  13,232  12,286  11,752 

9,918 

9,798 

199,503  182,565  176,048  168,450  165,834  21,411  21,906  23,597  22,104  18,906 

– 
– 

– 

– 

– 
– 

–
–

– 
– 

– 
– 

469 

469 

537 

458 

537 

458 

373 

373 

113,895  107,408  106,020  92,927  82,632  132,087  139,573  135,550  110,934  97,478  7,453  11,568  10,212  9,153  11,270 

313,398  289,973  282,068  261,377  248,466  153,498  161,479  159,147  133,038  116,384  7,453  12,037  10,749  9,611  11,643 

(1,143) 

(1,323) 

(740) 

(689) 

(799) 

(910) 

(1,225) 

(630) 

(574) 

(641) 

(13) 

(28) 

(17) 

(6) 

– 

312,255  288,650  281,328  260,688  247,667  152,588  160,254  158,517  132,464  115,743  7,440  12,009  10,732  9,605  11,643 

n
o
i
t
a
m
r
o
f
n
I

l
a
t
n
e
m
e
l
p
p
u
S

Table 8: Net Impaired Loans and Acceptances (NIL) – 

Segmented Information (2) (4) 

($ millions, except as noted) 

Canada 

United States 

Other countries 

As at October 31 

Consumer 

Residential mortgages 
Consumer instalment and 
other personal loans 

Total consumer 

Business and government 

Total impaired loans and 
acceptances, net of 
allowance for credit losses 
on impaired loans 

Condition Ratios (1) 
NIL as a % of net loans 
and acceptances 

NIL as a % of net loans 
and acceptances 
Consumer 
Business and government 

2021 

2020 

2019 

2018 

2017 

2021 

2020 

2019 

2018 

2017 

2021 

2020 

2019 

2018 

2017 

216 

225 

233 

185 

206 

123 

168 

164 

171 

161 

83 

299 
551 

89 

314 
726 

138 

371 
336 

126 

311 
235 

127 

333 
248 

113 

236 
585 

146 

194 

314 
1,487 

358 
1,101 

252 

423 
597 

293 

454 
762 

– 

– 

– 
– 

– 

– 

– 
70 

850 

1,040 

707 

546 

581 

821 

1,801 

1,459 

1,020 

1,216 

– 

70 

0.27 

0.36 

0.25 

0.21 

0.23 

0.54 

1.12 

0.92 

0.77 

1.05 

– 

0.58 

0.15 
0.48 

0.17 
0.68 

0.21 
0.32 

0.18 
0.25 

0.20 
0.30 

1.10 
0.44 

1.43 
1.07 

1.52 
0.81 

1.91 
0.54 

2.40 
0.78 

– 
– 

– 
0.61 

– 

– 

– 
– 

– 

– 

–
– 

– 

– 

– 
– 

– 

– 

– 
30 

– 

30 

– 

0.26 

– 
– 

– 
0.27 

(1)  Aggregate Net Loans and Acceptances balances are net of allowance for credit losses on performing loans and impaired loans (excluding those related to off-balance sheet instruments and undrawn 
commitments). The Consumer and Business and government Net Loans and Acceptances balances are net of allowance for credit losses on impaired loans only (excluding those related to off-balance 
sheet instruments and undrawn commitments). 

(2)  Segmented credit information by geographic area is based upon the country of ultimate risk. 
(3)  Prior periods have not been restated to reflect the adoption of IFRS 9 in 2018. IFRS 9 has been applied prospectively. 
(4)  Net Impaired Loans and Acceptances are net of allowance for credit losses on impaired loans (excluding those related to off-balance sheet instruments and undrawn commitments). 

128  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 9: Net Loans and Acceptances – 
Segmented Information (1) (2) (3) 

Total 

($ millions) 
As at October 31 

2021 

2020 

2019 

2018 

2017 

135,738  127,008  123,723  119,601  115,234 
8,071 

8,103 

8,329 

8,859 

7,889 

77,073  70,043  67,600  63,082  61,808 

Net Loans and Acceptances by Province 
Atlantic provinces 
Quebec 
Ontario 
Prairie provinces 
British Columbia and territories 

2021 

2020 

2019 

2018 

2017 

15,996 
48,090 
136,638 
51,460 
60,071 

15,105 
43,859 
124,526 
50,634 
54,526 

14,601 
42,985 
119,629 
51,639 
52,474 

13,925 
40,177 
109,575 
48,634 
48,377 

13,686 
38,802 
103,152 
46,853 
45,174 

S
u
p
p
l
e
m
e
n
t
a
l

I
n
f
o
r
m
a
t
i
o
n

220,914  204,940  200,182  191,012  185,113 

Total net loans and acceptances in Canada 

312,255 

288,650 

281,328 

260,688 

247,667 

253,435  258,549  251,782  213,014  191,380 

474,349  463,489  451,964  404,026  376,493 

(2,066) 

(2,576) 

(1,387) 

(1,269) 

(1,440) 

472,283  460,913  450,577  402,757  375,053 

Total 

2021 

2020 

2019 

2018 

2017 

339 

393 

397 

356 

367 

Net Business and Government Loans by Industry 
Commercial real estate 
Construction (non-real estate) 
Retail trade 
Wholesale trade 
Agriculture 
Communications 
Financing products 
Manufacturing 
Mining 
Oil and gas 
Transportation 
Utilities 
Forest products 
Service industries 
Financial 
Government 
Other 

43,259 
4,367 
16,924 
14,727 
13,739 
787 
1,084 
28,034 
1,832 
5,905 
12,952 
7,263 
780 
45,019 
52,531 
1,720 
2,512 

39,990 
4,799 
20,480 
15,715 
13,549 
771 
3,927 
28,171 
2,496 
9,445 
12,921 
8,496 
1,012 
47,769 
44,986 
2,121 
1,901 

36,707 
4,943 
23,085 
16,939 
13,268 
840 
4,124 
27,334 
2,524 
10,051 
12,390 
8,153 
1,152 
45,730 
40,880 
1,801 
1,861 

31,028 
3,916 
20,403 
14,814 
12,321 
729 
4,439 
22,870 
1,936 
7,227 
10,973 
5,958 
840 
38,348 
32,463 
1,460 
3,289 

26,479 
3,916 
18,496 
11,612 
11,114 
625 
5,060 
19,824 
1,344 
6,551 
10,496 
4,392 
835 
33,705 
32,265 
1,470 
3,196 

253,435 

258,549 

251,782 

213,014 

191,380 

196 

235 

332 

535 
1,136 

628 
2,283 

729 
1,437 

378 

734 
832 

420 

787 
1,040 

Table 10: Net Impaired Loans and Acceptances – 
Segmented Information (3) (4) 

1,671 

2,911 

2,166 

1,566 

1,827 

0.35 

0.63 

0.48 

0.39 

0.49 

0.24 
0.45 

0.31 
0.88 

0.36 
0.57 

0.38 
0.39 

0.43 
0.54 

($ millions) 
As at October 31 

Net Impaired Business and Government Loans 
Commercial real estate 
Construction (non-real estate) 
Retail trade 
Wholesale trade 
Agriculture 
Communications 
Financing products 
Manufacturing 
Mining 
Oil and gas 
Transportation 
Utilities 
Forest products 
Service industries 
Financial 
Government 
Other 

2021 

2020 

2019 

2018 

2017 

56 
58 
143 
38 
190 
1 
– 
130 
2 
63 
73 
2 
2 
344 
12 
2 
20 

78 
86 
407 
69 
313 
9 
147 
225 
30 
366 
112 
1 
7 
387 
41 
3 
2

49 
21 
56 
76 
291 
6 
– 
191 
– 
356 
119 
2 
2 
240 
28 
– 
 –

1,136 

2,283 

1,437 

45 
18 
50 
42 
193 
– 
– 
77 
1 
57 
90 
2 
– 
191 
66 
– 
 –

832 

45 
39 
36 
97 
238 
– 
– 
70 
1 
143 
156 
6 
2 
181 
2 
3 
 21

1,040 

(1)  Aggregate Net Loans and Acceptances are net of allowance for credit losses on performing loans and impaired loans (excluding those related 
to off-balance sheet instruments and undrawn commitments). The Consumer and Business and government Net Loans and Acceptances 
balances are net of allowance for credit losses on impaired loans only (excluding those related to off-balance sheet instruments and 
undrawn commitments). 

(2)  Segmented credit information by geographic area is based upon the country of ultimate risk. 
(3)  Prior period information for certain sectors has been adjusted to align with the current year’s presentation, which better classifies the realigned 

sectors. 

(4)  Net Impaired Loans and Acceptances are net of allowance for credit losses on impaired loans (excluding those related to off-balance sheet 

instruments and undrawn commitments). 

BMO Financial Group 204th Annual Report 2021  129 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
– 
– 

– 

–
93

93

– 
– 

– 

– 
– 

– 

–
– 

– 

– 
84

84

– 
– 

– 

 – 
 – 

 – 

–
– 

– 
50 

50 

– 
2 

2 

– 
– 

– 

–
56

56

– 
(49) 

– 
(7) 

–
– 

– 

– 
 –

 –

–
– 

– 

– 
(1) 

(1) 

– 
(1) 

(1) 

– 
 –

 –

– 
 50

 50

– 
– 
–  0.44 

–  0.43 

SUPPLEMENTAL INFORMATION 

Table 11: Changes in Gross Impaired Loans – 
Segmented Information (1) (2) 

($ millions, except as noted) 

Canada 

United States 

Other countries 

As at October 31 

2021 

2020 

2019 

2018 

2017 

2021 

2020 

2019 

2018 

2017 

2021 

2020 

2019 

2018 

2017 

414 
929 

1,343 

497 
417 

914 

426 
309 

735 

439 
354 

407 
380 

335 
1,876 

385 
1,330 

470 
731 

585 
508 
869  1,009 

793 

787 

2,211 

1,715  1,201  1,377  1,594 

– 
84 

84 

– 
– 

– 

Total additions 

1,328  1,820  1,218  1,157 

978 

447 

2,736  1,468 

921  1,159 

712 
723 
616  1,097 

895 
323 

836 
321 

697 
281 

134 
313 

165 

244 
2,571  1,224 

274 
647 

360 
799 

(547) 
(636) 

(554) 
(366) 

(586) 
(171) 

(628)  (479) 
(136) 
(282)  (259)  (1,231)  (1,528) 

(162) 

(242) 
(466) 

(212) 
(573) 

(301) 
(692) 

– 
(84) 

–
(9) 

(1,183) 

(920) 

(757) 

(910)  (738)  (1,393)  (1,664) 

(708) 

(785) 

(993) 

(84) 

(9) 

– 

(49) 

(7) 

Gross impaired loans and acceptances 

(GIL), beginning of year 
Consumer 
Business and government 

Total GIL, beginning of year 

Additions to impaired loans 

and acceptances 
Consumer 
Business and government 

Reductions to impaired loans 

and acceptances (3) 
Consumer 
Business and government 

Total reductions due to net 
repayments and other 

Write-offs (4) 
Consumer 
Business and government 

Gross impaired loans and acceptances, 

end of year 
Consumer 
Business and government 

Total GIL, end of year 

Condition Ratios 
GIL as a % of Gross Loans 

Consumer 
Business and government 

n
o
i
t
a
m
r
o
f
n
I

l
a
t
n
e
m
e
l
p
p
u
S

Total write-offs 

(293) 

(471) 

(282) 

(305)  (234) 

(291) 

(576) 

(246) 

(312) 

(383) 

(197) 
(96) 

(252) 
(219) 

(238) 
(44) 

(221)  (186) 
(48) 

(84) 

(51) 
(240) 

(79) 
(497) 

(87) 
(159) 

(100) 
(212) 

(136) 
(247) 

382 
813 

414 
929 

1,195  1,343 

497 
417 

914 

426 
309 

439 
354 

256 
718 

335 

385 
1,876  1,330 

470 
731 

508 
869 

735 

793 

974 

2,211  1,715  1,201  1,377 

Total Loans and Acceptances 

0.38 

0.46 

0.32 

0.28  0.32 

0.19 
0.71 

0.23 
0.86 

0.28 
0.39 

0.25  0.26 
0.33  0.43 

1.19 
0.54 

0.63 

1.53 
1.34 

1.63 
0.98 

2.12 
0.67 

2.69 
0.89 

– 
–
–  0.73 

1.37 

1.08 

0.91 

1.18 

–  0.70 

(1)  GIL excludes Purchased Credit Impaired Loans. 
(2)  Segmented credit information by geographic area is based upon the country of ultimate risk. 
(3)  Includes amounts returning to performing status, sales, repayments, the impact of foreign exchange, and offsets for consumer write-offs that are not recognized as formations. 
(4)  Excludes certain loans that are written off directly and not classified as new formations. 

130  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Total 

2021 

2020 

2019 

2018 

2017 

749 
2,889 

882 
1,747 

896 
1,040 

947 

992 
1,273  1,391 

3,638 

2,629 

1,936 

2,220  2,383 

846 
929 

888 
3,761 

1,139 
1,547 

1,110  1,057 
968  1,136 

1,775 

4,649 

2,686 

2,078  2,193 

(709) 

(690) 
(1,951)  (1,903) 

(828) 
(637) 

(840) 
(904) 

(780) 
(958) 

(2,660)  (2,593)  (1,465)  (1,744)  (1,738) 

(248) 
(336) 

(331) 
(716) 

(325) 
(203) 

(321) 
(297) 

(322) 
(296) 

(584)  (1,047) 

(528) 

(618) 

(618) 

638 
1,531 

749 
2,889 

882 
1,747 

896 

947 
1,040  1,273 

2,169 

3,638 

2,629 

1,936  2,220 

0.29 
0.60 

0.37 
1.11 

0.44 
0.69 

0.47 
0.49 

0.51 
0.66 

0.46 

0.78 

0.58 

0.48 

0.59 

S
u
p
p
l
e
m
e
n
t
a
l

I
n
f
o
r
m
a
t
i
o
n

BMO Financial Group 204th Annual Report 2021  131 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
SUPPLEMENTAL INFORMATION 

Table 12: Changes in Allowance for Credit Losses – 

Segmented Information (1) (2) 

($ millions, except as noted) 

Canada 

United States 

Other countries 

As at October 31 

2021 

2020 

2019 

2018 

2017 

2021 

2020 

2019 

2018 

2017 

2021 

2020 

2019 

2018 

2017 

Other, including foreign exchange 

rate changes 
Consumer 
Business and government 

Total Other, including foreign 
exchange rate changes 

ACL, end of year 

Consumer 
Business and government 

n
o
i
t
a
m
r
o
f
n
I

l
a
t
n
e
m
e
l
p
p
u
S

Allowance for credit losses (ACL), 

beginning of year 
Consumer 
Business and government 

1,073 
782 

749 
303 

725 
255 

705 
317 

217 
595 
471  1,696 

200 
821 

Total ACL, beginning of year 

1,855 

1,052 

980  1,022  1,066  1,913  1,021 

Provision for credit losses (3) 

Consumer 
Business and government 

Total provision for credit losses 

Recoveries 

Consumer 
Business and government 

Total recoveries 

Write-offs 

201 
117 

801 
685 

318 

1,486 

127 
23 

150 

117 
20 

137 

470 
93 

563 

120 
4 

124 

416 
28 

444 

127 
5 

132 

394 
37 

(48) 

86 
(211)  1,336 

431 

(259)  1,422 

134 
10 

144 

64 
19 

83 

63 
52 

115 

230 
648 

878 

1 
302 

303 

104 
62 

166 

301 
566 

254 
793 

867  1,047 

(9) 
243 

234 

75 
51 

74 
220 

294 

81 
40 

126 

121 

Consumer 
Business and government 

(442) 
(96) 

(556) 
(219) 

(551) 
(44) 

(515) 
(84) 

(501) 
(48) 

(72) 
(240) 

(108) 
(497) 

(113) 
(159) 

(125) 
(212) 

(157) 
(247) 

Total write-offs 

(538) 

(775) 

(595) 

(599) 

(549) 

(312) 

(605) 

(272) 

(337) 

(404) 

(52) 
(34) 

(38) 
(7) 

(15) 
(5) 

(8) 
(11) 

(10) 
(27) 

(28) 
(153) 

(24) 
(16) 

(22) 
(32) 

(12) 
– 

(23) 
(114) 

(86) 

(45) 

(20) 

(19) 

(37) 

(181) 

(40) 

(54) 

(12) 

(137) 

– 
46 

46 

– 
(32) 

(32) 

– 
– 

– 

– 
– 

– 

– 
1 

1 

– 
21 

21 

– 
29 

29 

– 
– 

– 

–
– 

– 

–
(4) 

(4) 

– 
46 

46 

– 
12 

12 

– 
9 

9 

– 
– 

– 

–
– 

– 

–
– 

– 

– 
21 

21 

– 
29 

29 

– 
(21) 

(21) 

– 
3 

3 

–
(1) 

(1) 

–
2

2 

– 
12 

12 

– 
1 

1 

– 
21 

21 

– 
– 

– 

– 
(1) 

(1) 

– 
(1) 

(1) 

– 
20 

20 

Total ACL, end of year 

1,699 

1,855  1,052 

980  1,055  1,244  1,913  1,021 

907 
792 

1,073 
782 

749 
303 

725 
255 

133 
612 
217 
443  1,111  1,696 

200 
821 

230 
648 

878 

229 
692 

921 

– 
15 

15 

Net write-offs as a % of average 

loans and acceptances (4) 

un 

un 

un 

un 

un 

un 

un 

un 

un 

un 

un 

un 

un 

un 

un 

Table 13: Allocation of Allowance for Credit Losses – 

Segmented Information (1) (5) 

($ millions, except as noted) 

Canada 

United States 

Other countries 

As at October 31 

Consumer 

Residential mortgages 
Consumer instalment and other 

personal loans 

Total consumer 

Business and government 

Total allowance for credit losses 

on impaired loans 

Allowance for credit losses 
on performing loans (3) 

Allowance for credit losses 

Coverage Ratios 
Allowance for credit losses on 

impaired loans as a % of gross 
impaired loans and acceptances 

Total 
Consumer 
Business and government 

2021 

2020 

2019 

2018 

2017 

2021 

2020 

2019 

2018 

2017 

2021 

2020 

2019 

2018 

2017 

7 

76 

83 
262 

11 

89 

100 
203 

10 

116 

126 
81 

9 

106 

115 
74 

12 

94 

106 
106 

5 

5 

7 

15 

20 
133 

16 

21 
389 

20 

27 
229 

10 

37 

47 
134 

12 

42 

54 
107 

345 

303 

207 

189 

212 

153 

410 

256 

181 

161 

– 

– 

– 
– 

– 

1,143 

1,323 

1,488 

1,626 

740 

947 

689 

799 

910  1,225 

878  1,011  1,063  1,635 

630 

886 

574 

755 

641 

802 

13 

13 

– 

– 

– 
14

14

28 

42 

– 

– 

– 
 –

 –

17 

17 

– 

– 

– 
 –

 –

6 

6 

– 

– 

– 
 20

 20

– 

20 

28.9 
21.7 
32.2 

22.6 
24.2 
21.9 

22.6 
25.4 
19.4 

25.7 
27.0 
23.9 

26.7 
24.1 
29.9 

15.7 
7.8 
18.5 

18.5 
6.3 
20.7 

14.9 
7.0 
17.2 

15.1 
10.0 
18.3 

11.7 
10.6 
12.3 

– 
– 
– 

16.7 
–
16.7 

– 
–
– 

– 
–
– 

40.0 
– 
40.0 

(1)  Segmented credit information by geographic area is based upon country of ultimate risk. 
(2)  Prior periods have not been restated to reflect the adoption of IFRS 9 in 2018. IFRS 9 has been applied prospectively. 
(3)  Excludes provision for credit losses on other assets. 
(4)  Aggregate Net Loans and Acceptances balances are net of allowance for credit losses on performing loans and impaired loans (excluding those related to off-balance sheet instruments). 
(5)  Amounts exclude allowance for credit losses included in Other Liabilities. 

un – unavailable 

132  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Total 

2021 

2020 

2019 

2018 

2017 

1,290 
949 
2,524  1,145 

955  1,006 
915 

849 
912  1,265 

3,814  2,094  1,870  1,918  2,114 

153 
887 
(126)  2,050 

27  2,937 

191 
42 

233 

180 
72 

252 

471 
404 

875 

224 
66 

290 

407 
250 

657 

202 
59 

261 

468 
278 

746 

215 
50 

265 

(514) 
(336) 

(664) 
(716) 

(664) 
(203) 

(640) 
(297) 

(658) 
(296) 

(850)  (1,380) 

(867) 

(937) 

(954) 

(80) 
(186) 

(62) 
(27) 

(37) 
(37) 

(20) 
(9) 

(33) 
(142) 

(266) 

(89) 

(74) 

(29) 

(175) 

1,040  1,290 
949 
1,918  2,524  1,145 

955 
841 
915  1,155 

2,958  3,814  2,094  1,870  1,996 

0.13 

0.24 

0.13 

0.17 

0.19 

Total 

2021 

2020 

2019 

2018 

2017 

12 

91 

103 
395 

16 

17 

19 

24 

105 

121 
606 

136 

153 
310 

143 

162 
208 

136 

160 
233 

498 

727 

463 

370 

393 

2,066  2,576  1,387  1,269  1,440 

2,564  3,303  1,850  1,639  1,833 

23.0 
16.1 
25.8 

20.0 
16.2 
21.0 

17.6 
17.3 
17.7 

19.1 
18.1 
20.0 

17.7 
16.9 
18.3 

S
u
p
p
l
e
m
e
n
t
a
l

I
n
f
o
r
m
a
t
i
o
n

BMO Financial Group 204th Annual Report 2021  133 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
SUPPLEMENTAL INFORMATION 

Table 14: Allowance for Credit Losses on Impaired Loans – 

Segmented Information 

n
o
i
t
a
m
r
o
f
n
I

l
a
t
n
e
m
e
l
p
p
u
S

($ millions) 
As at October 31 

Business and Government 
Allowance for Credit Losses on Impaired Loans by Industry 
Commercial real estate 
Construction (non-real estate) 
Retail trade 
Wholesale trade 
Agriculture 
Communications 
Financing products 
Manufacturing 
Mining 
Oil and gas 
Transportation 
Utilities 
Forest products 
Service industries 
Financial 
Government 
Other 

Total business and government (1) 

Table 15: Provision for Credit Losses – 

Segmented Information (2) 

($ millions) 
For the year ended October 31 

Consumer 
Residential mortgages 
Cards 
Consumer instalment and other personal loans 

Total consumer 

Business and Government 
Commercial real estate 
Construction (non-real estate) 
Retail trade 
Wholesale trade 
Agriculture 
Communications 
Financing products 
Manufacturing 
Mining 
Oil and gas 
Transportation 
Utilities 
Forest products 
Service industries 
Financial 
Government 
Other 

Total business and government 

Total provision for credit losses on impaired loans 
Provision for credit losses on performing loans (3) 

Performance Ratios (%) 
PCL-to-average net loans and acceptances 
PCL on impaired loans to segmented average net loans and acceptances 

Consumer 
Business and government 

PCL on impaired loans-to-average net loans and acceptances 

2021 

2020 

2019 

2018 

2017 

11 
9 
90 
36 
23 
5 
– 
47 
– 
77 
17 
1 
2 
73 
3 
– 
1 

395 

11 
18 
53 
35 
36 
8 
– 
67 
10
184 
32 
– 
5 
132 
7 
1 
7 

606 

9 
8 
11 
52 
22 
7 
– 
35 
 –
48 
30 
– 
– 
79 
3 
1 
5 

8 
16 
17 
23 
16 
– 
– 
20 
 –
17 
31 
– 
1 
46 
1 
– 
12 

15 
14 
14 
17 
11 
– 
– 
51 
 –
42 
13 
2 
1 
51 
2 
– 
– 

310 

208 

233 

2021 

2020 

2019 

2018 

2017 

16 
194 
158 

368 

7 
3 
38 
18 
2 
(2) 
– 
41 
(9) 
18 
11 
1 
2 
30 
(4) 
– 
1 

17 
261 
226 

504 

6
70 
73 
22 
30 
1 
– 
128 
10
293 
116 
1 
6 
243 
(6) 
– 
25 

157 

525 
(505) 

20 

1,018 

1,522 
1,431 

2,953 

16 
246 
201 

463 

 5
1 
(2) 
54 
27 
7 
– 
25 
 –
51 
67 
1 
– 
68 
(35) 
1 
18 

288 

751 
121 

872 

19 
216 
231 

466 

 (2)
– 
10 
18 
37 
– 
– 
20 
 –
(24) 
74 
(3) 
(1) 
87 
(4) 
– 
22 

234 

700 
(38) 

662 

11 
232 
232 

475 

 (4)
25 
29 
24 
31 
(1) 
– 
28 
 –
9 
108 
– 
– 
102 
(3) 
– 
(1) 

347 

822 
(76) 

746 

0.00 

0.63 

0.20 

0.17 

0.20 

0.17 
0.06 
0.11 

0.25 
0.39 
0.33 

0.24 
0.12 
0.17 

0.25 
0.12 
0.18 

0.26 
0.18 
0.22 

(1)  Amounts exclude allowance for credit losses included in Other Liabilities. 
(2)  Prior period information for certain sectors has been adjusted to align with the current year’s presentation, which better classifies the realigned sectors. 
(3)  Prior periods have not been restated to reflect the adoption of IFRS 9 in 2018. IFRS 9 has been applied prospectively. 

134  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 16: Average Deposits 

($ millions, except as noted) 

Deposits Booked in Canada 
Demand deposits – interest bearing 
Demand deposits – non-interest bearing 
Payable after notice 
Payable on a fixed date 

Total deposits booked in Canada 

Deposits Booked in the United States and Other Countries 
Banks located in the United States and other countries (1) 
Governments and institutions in the United States and other countries 
Other demand deposits 
Other deposits payable after notice or on a fixed date 

Total deposits booked in the United States and other countries 

Total average deposits 

2021 

2020 

2019 

Average 
balance 

Average 
rate paid (%) 

Average 
balance 

Average 
rate paid (%) 

Average 
balance 

Average 
rate paid (%) 

48,372 
74,505 
122,916 
173,030 

418,823 

21,237 
8,705 
17,778 
211,507 

259,227 

678,050 

0.58 
– 
0.20 
1.31 

35,643 
56,936 
101,870 
194,456 

0.82 
– 
0.63 
1.86 

24,211 
47,849 
86,531 
173,337 

0.67 

388,905 

1.17  331,928 

0.36 
0.16 
0.08 
0.15 

20,927 
8,852 
16,321 
194,096 

1.07 
0.91 
0.27 
0.69 

23,563 
12,253 
14,484 
164,540 

0.16 

240,196 

0.70 

214,840 

0.47 

629,101 

0.99 

546,768 

1.18 
– 
1.24 
2.33 

1.63 

2.41 
1.97 
0.86 
1.38 

1.49 

1.58 

As at October 31, 2021, 2020 and 2019, deposits by foreign depositors in our Canadian bank offices amounted to $58,396 million, $52,433 million and $46,766 million, respectively. 

(1)  Net interest margin is calculated based on average earning assets, which represents the daily average balance of deposits at central banks, deposits with other banks, securities borrowed or 

purchased under resale agreements, securities, and loans, over a one-year period. 

S
u
p
p
l
e
m
e
n
t
a
l

I
n
f
o
r
m
a
t
i
o
n

BMO Financial Group 204th Annual Report 2021  135 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
GLOSSARY OF FINANCIAL TERMS 

Glossary of Financial Terms 

Adjusted Earnings and Measures 

•  Adjusted Revenue – calculated as revenue 

excluding the impact of certain non-recurring 
items, as set out in the Non-GAAP and Other 
Financial Measures section. 

•  Adjusted Non-Interest Expense – calculated as 
non-interest expense excluding the impact of 
certain non-recurring items, as set out in the 
Non-GAAP and Other Financial Measures 
section. 

•  Adjusted Net Income – calculated as net 

income excluding the impact of certain non-
recurring items, as set out in the Non-GAAP 
and Other Financial Measures section. 

Management considers both reported and 
adjusted results to be useful in assessing 
underlying ongoing business performance. 

Adjusted Effective Tax Rate is calculated as 
adjusted provision for income taxes divided by 
adjusted income before provision for income 
taxes. 

Allowance for Credit Losses represents an 
amount deemed appropriate by management to 
absorb credit-related losses on loans and 
acceptances and other credit instruments, in 
accordance with applicable accounting 
standards. Allowance on Performing Loans is 
maintained to cover impairment in the existing 
portfolio for loans that have not yet been 
individually identified as impaired. Allowance on 
Impaired Loans is maintained to reduce the 
carrying value of individually identified impaired 
loans to the expected recoverable amount. 

Assets under Administration and Assets 
under Management refers to assets 
administered or managed by a financial 
institution that are beneficially owned by clients 
and therefore not reported on the balance sheet 
of the administering or managing financial 
institution. 

Asset-Backed Commercial Paper (ABCP) is a 
short-term investment. The commercial paper is 
backed by assets such as trade receivables, and 
is generally used for short-term financing needs. 

Average annual total shareholder return 
(TSR) represents the average annual total return 
earned on an investment in BMO common 
shares made at the beginning of a fixed period. 
The return includes the change in share price 
and assumes dividends received were 
reinvested in additional common shares. 

Average Earning Assets represents the daily 
average balance of deposits at central banks, 
deposits with other banks, securities borrowed 
or purchased under resale agreements, 
securities, and loans over a one-year period. 

Bail-In Debt is senior unsecured debt subject to 
the Canadian Bail-In Regime. Bail-in debt 
includes senior unsecured debt issued directly 
by the bank on or after September 23, 2018, 

136  BMO Financial Group 204th Annual Report 2021 

which has an original term greater than 400 
days and is marketable, subject to certain 
exceptions. Some or all of this debt may be 
statutorily converted into common shares of the 
bank under the Bail-In Regime if the bank 
enters resolution. 

Bankers’ Acceptances (BAs) are bills of 
exchange or negotiable instruments drawn by a 
borrower for payment at maturity and accepted 
by a bank. BAs constitute a guarantee of 
payment by the bank and can be traded in the 
money market. The bank earns a “stamping 
fee” for providing this guarantee. 

Basis Point is one one-hundredth of a 
percentage point. 

Common Equity Tier 1 (CET1) Capital 
comprises common shareholders’ equity less 
deductions for goodwill, intangible assets, 
pension assets, certain deferred tax assets and 
other items, which may include a portion of 
expected credit loss provisions. 

Common Equity Tier 1 (CET1) Ratio is 
calculated as CET1 Capital, which comprises 
common shareholders’ equity, net of deductions 
for goodwill, intangible assets, pension assets, 
certain deferred tax assets and other items, 
which may include a portion of expected credit 
loss provisions, divided by risk-weighted assets. 
The CET1 Ratio is calculated in accordance with 
OSFI’s Capital Adequacy Requirements (CAR) 
Guideline. 

Common Shareholders’ Equity is the most 
permanent form of capital. For regulatory capital 
purposes, common shareholders’ equity 
comprises common shareholders’ equity, net of 
capital deductions. 

Corporate Services consists of Corporate Units 
and Technology and Operations (T&O). Corporate 
Units provide enterprise-wide expertise, 
governance and support in a variety of areas, 
including strategic planning, risk management, 
finance, legal and regulatory compliance, 
human resources, communications, marketing, 
real estate and procurement. T&O develops, 
monitors, manages and maintains governance 
of information technology, including data and 
analytics, and also provides cyber security and 
operations services. 

Credit and Counterparty Risk is the potential 
for credit loss due to the failure of an obligor 
(i.e., a borrower, endorser, guarantor or 
counterparty) to repay a loan or honour another 
predetermined financial obligation. 

Derivatives are contracts with a value that is 
derived from movements in underlying interest 
or foreign exchange rates, equity or commodity 
prices or other indices. Derivatives allow for the 
transfer, modification or reduction of current or 
expected risks from changes in rates and prices. 

Dividend Payout Ratio represents common 
share dividends as a percentage of net income 

available to common shareholders. It is 
computed by dividing dividends per share by 
basic earnings per share. Adjusted dividend 
payout ratio is calculated in the same manner, 
using adjusted net income. 

Earnings per Share (EPS) is calculated by 
dividing net income, after deducting preferred 
share dividends and distributions on other 
equity instruments, by the average number of 
common shares outstanding. Adjusted EPS is 
calculated in the same manner, using adjusted 
net income. Diluted EPS, which is BMO’s basis 
for measuring performance, adjusts for possible 
conversions of financial instruments into 
common shares if those conversions would 
reduce EPS, and is more fully explained in Note 
23 of the consolidated financial statements. 

Earnings Sensitivity is a measure of the impact 
of potential changes in interest rates on the 
projected 12-month pre-tax net income of a 
portfolio of assets, liabilities and off-balance 
sheet positions in response to prescribed 
parallel interest rate movements, with interest 
rates floored at zero. 

Economic Capital is an expression of the 
enterprise’s capital demand requirement 
relative to its view of the economic risks in its 
underlying business activities. It represents 
management’s estimation of the likely 
magnitude of economic losses that could occur 
should severely adverse situations arise. 
Economic capital is calculated for various types 
of risk, including credit, market (trading and 
non-trading), operational non-financial, business 
and insurance, based on a one-year time 
horizon using a defined confidence level. 

Economic Value Sensitivity is a measure of the 
impact of potential changes in interest rates on 
the market value of a portfolio of assets, liabilities 
and off-balance sheet positions in response to 
prescribed parallel interest rate movements, with 
interest rates floored at zero. 

Efficiency Ratio (or Expense-to-Revenue Ratio) 
is a measure of productivity. It is calculated as 
non-interest expense divided by total revenue, 
expressed as a percentage. The adjusted efficiency 
ratio is calculated in the same manner, utilizing 
adjusted total revenue and non-interest expense. 

Efficiency Ratio, net of CCPB, is calculated as 
non-interest expense divided by total revenue, 
net of insurance claims, commissions and 
changes in policy benefit liabilities (CCPB), 
expressed as a percentage. The adjusted 
efficiency ratio, net of CCPB, is calculated in the 
same manner, utilizing adjusted total revenue, 
net of CCPB, and non-interest expense. 

Environmental and Social Risk (E&S risk) is 
the potential for loss or harm, directly or 
indirectly, resulting from environmental or social 
impacts or concerns, including climate change, 
related to BMO, our customers, suppliers or 
clients, and our impact on the environment and 
society. 

Fair Value is the amount of consideration that 
would be agreed upon in an arm’s- length 
transaction between knowledgeable, willing 
parties who are under no compulsion to act in 
an orderly market transaction. 

Forwards and Futures are contractual 
agreements to either buy or sell a specified 
amount of a currency, commodity, interest-rate-
sensitive financial instrument or security at a 
specified price and date in the future. Forwards 
are customized contracts transacted in the 
over-the-counter market. Futures are transacted 
in standardized amounts on regulated exchanges 
and are subject to daily cash margin 
requirements. 

Gross impaired loans and acceptances(GIL) 
are calculated as the credit impaired balance of 
loans and customers’ liability under 
acceptances, excluding purchased credit 
impaired loans. 

Hedging is a risk management technique used to 
neutralize, manage or offset interest rate, foreign 
currency, equity, commodity or credit risk 
exposures arising from normal banking activities. 

Impaired Loans are loans for which there is no 
longer reasonable assurance of the timely 
collection of principal or interest. 

Incremental Risk Charge (IRC) complements 
the VaR and SVaR metrics and represents an 
estimate of the default and migration risks of 
non-securitization products held in the trading 
book with exposure to interest rate risk, 
measured over a one-year horizon at a 99.9% 
confidence level. 

Insurance Risk is the potential for loss as a 
result of actual experience differing from that 
assumed when an insurance product was 
designed and priced, and comprises claims risk, 
policyholder behaviour risk and expense risk. 

Insurance Revenue, net of CCPB, is insurance 
revenue, net of insurance claims, commissions 
and changes in policy benefit liabilities (CCPB). 

Legal and Regulatory Risk is the potential for 
loss or harm resulting from a failure to comply 
with laws or satisfy contractual obligations or 
regulatory requirements. This includes the risk 
of failure to: comply with the law (in letter or in 
spirit) or maintain standards of care; implement 
legal or regulatory requirements; enforce or 
comply with contractual terms; assert 
non-contractual rights; effectively manage 
disputes; or act in a manner so as to maintain 
our reputation. 

Leverage Exposures (LE) consist of on-balance 
sheet items and specified off-balance sheet 
items, net of specified adjustments. 

Leverage Ratio reflects Tier 1 Capital divided 
by LE. 

and suppliers, and lending, investment and 
pledging commitments. 

Liquidity Coverage Ratio (LCR) is a Basel III 
regulatory metric calculated as the ratio of high-
quality liquid assets to total net stressed cash 
outflows over a thirty-day period under a stress 
scenario prescribed by OSFI. 

Market Risk is the potential for adverse 
changes in the value of our assets and liabilities 
resulting from changes in market variables such 
as interest rates, foreign exchange rates, equity 
and commodity prices and their implied 
volatilities, and credit spreads, and includes the 
risk of credit migration and default in our 
trading book. 

Mark-to-Market represents the valuation of 
financial instruments at fair value (as defined 
above) as of the balance sheet date. 

Model Risk is the potential for adverse 
consequences resulting from decisions that are 
based on incorrect or misused model results. 
These adverse consequences can include 
financial loss, poor business decision-making 
and damage to reputation. 

Net Interest Income comprises earnings on 
assets, such as loans and securities, including 
interest and certain dividend income, less 
interest expense paid on liabilities, such as 
deposits. Net interest income excluding trading, 
is on a basis that excludes trading-related 
interest income and earning assets. 

Net Interest Margin is the ratio of net interest 
income to average earning assets, expressed as 
a percentage or in basis points. Net interest 
margin is sometimes computed using average 
total assets. Net interest margin excluding 
trading, is computed in the same manner 
excluding trading related interest income and 
earning assets. 

Net Non-Interest Revenue is non-interest 
revenue, net of insurance claims, commissions 
and changes in policy benefit liabilities (CCPB). 

Notional Amount refers to the principal 
amount used to calculate interest and other 
payments under derivative contracts. The 
principal amount does not change hands under 
the terms of a derivative contract, except in the 
case of cross-currency swaps. 

Off-Balance Sheet Financial Instruments 
consist of a variety of financial arrangements 
offered to clients, which include credit 
derivatives, written put options, backstop 
liquidity facilities, standby letters of credit, 
performance guarantees, credit enhancements, 
commitments to extend credit, securities 
lending, documentary and commercial letters of 
credit, and other indemnifications. 

Liquidity and Funding Risk is the potential for 
loss if we are unable to meet our financial 
commitments in a timely manner at reasonable 
prices as they become due. Financial 
commitments include liabilities to depositors 

Office of the Superintendent of Financial 
Institutions Canada (OSFI) is the government 
agency responsible for regulating banks, 
insurance companies, trust companies, loan 
companies and pension plans in Canada. 

Operating Leverage is the difference between 
revenue and expense growth rates. Adjusted 
operating leverage is the difference between 
adjusted revenue and adjusted expense growth 
rates. 

Operating Leverage, net of CCPB, is the 
difference between revenue, net of CCPB (net 
revenue), and expense growth rates. Adjusted 
net operating leverage is the difference 
between adjusted revenue, net of CCPB, and 
adjusted expense growth rates. 

Operational Non-Financial Risk (ONFR) 
encompasses a wide range of non-financial risks, 
including those related to business change, 
customer trust, reputation and data that can 
result in financial loss. These losses can stem 
from inadequate or failed internal processes or 
systems, human error or misconduct, and 
external events that may directly or indirectly 
impact our credit or investment portfolios. These 
risks include technology risk, fraud risk, business 
continuity risk and human resources risk, but 
exclude legal and regulatory risk, credit risk, 
market risk, liquidity risk and other types of 
financial risk. 

Options are contractual agreements that convey 
to the purchaser the right but not the obligation 
to either buy or sell a specified amount of a 
currency, commodity, interest-rate-sensitive 
financial instrument or security at a fixed future 
date or at any time within a fixed future period. 

Pre-Provision, Pre-Tax Earnings (PPPT) is 
calculated as income before income taxes and 
provision for credit losses. We use PPPT on both 
a reported and adjusted basis to assess our 
ability to generate sustained earnings growth 
excluding credit losses, which are impacted by 
the cyclical nature of a credit cycle. 

Provision for Credit Losses (PCL) is a charge to 
income that represents an amount deemed 
adequate by management to fully provide for 
impairment in a portfolio of loans and 
acceptances and other credit instruments, given 
the composition of the portfolio, the probability 
of default, the economic environment and the 
allowance for credit losses already established. 
PCL can comprise both a provision for credit 
losses on impaired loans and a provision for 
credit losses on performing loans. For more 
information, refer to the Provision for Credit 
Losses and Allowance for Credit Losses sections 
and Note 4 of the consolidated financial 
statements. 

Reputation Risk is the potential for loss or 
harm to the BMO brand. It can arise even if 
other risks are managed effectively. 

Return on Equity or Return on Common 
Shareholders’ Equity (ROE) is calculated as net 
income, less preferred dividends and 
distributions on other equity instruments, as a 
percentage of average common shareholders’ 
equity. Common shareholders’ equity comprises 
common share capital, contributed surplus, 
accumulated other comprehensive income (loss) 
and retained earnings. Adjusted ROE is 
calculated using adjusted net income rather 
than net income. 

BMO Financial Group 204th Annual Report 2021  137 

Return on Tangible Common Equity (ROTCE) is 
calculated as net income available to common 
shareholders, adjusted for the amortization of 
acquisition-related intangible assets, as a 
percentage of average tangible common equity. 
Adjusted ROTCE is calculated using adjusted net 
income rather than net income. 

Risk-Weighted Assets (RWA) are defined as 
on-balance sheet and off-balance sheet 
exposures that are risk-weighted based on 
guidelines established by OSFI. The measure is 
used for capital management and regulatory 
reporting purposes. 

Securities Borrowed or Purchased under 
Resale Agreements are low-cost, low-risk 
instruments, often supported by the pledge 
of cash collateral, which arise from transactions 
that involve the borrowing or purchasing 
of securities. 

Securities Lent or Sold under Repurchase 
Agreements are low-cost, low-risk liabilities, 
often supported by cash collateral, which arise 
from transactions that involve the lending or 
selling of securities. 

Securitization is the practice of selling pools of 
contractual debts, such as residential 
mortgages, auto loans and credit card debt 
obligations, to third parties or trusts, which then 
typically issue a series of asset-backed 
securities to investors to fund the purchase of 
the contractual debts. 

Strategic Risk is the potential for loss or harm 
due to changes in the external business 
environment and failure to respond 
appropriately to these changes as a result of 
inaction, ineffective strategies or poor 
implementation of strategies. Strategic risk also 
includes business risk, which arises from the 
specific business activities of the enterprise, and 
the effects these could have on its earnings. 

Stressed Value at Risk (SVaR) measures the 
maximum loss likely to be experienced in the 
trading and underwriting portfolios, measured 
at a 99% confidence level over a one-day 
holding period, with model inputs calibrated to 
historical data from a period of significant 
financial stress. SVaR is calculated for specific 
classes of risk in BMO’s trading and underwriting 
activities related to interest rates, foreign 
exchange rates, credit spreads, equity and 
commodity prices and their implied volatilities. 

Structured Entities (SEs) include entities for 
which voting or similar rights are not the 
dominant factor in determining control of the 
entity. BMO is required to consolidate a SE if it 
controls the entity by having power over the 
entity, exposure to variable returns as a result 
of its involvement and the ability to exercise 
power to affect the amount of those returns. 

Structural (Non-Trading) Market Risk comprises 
interest rate risk arising from banking activities 

(loans and deposits) and foreign exchange risk 
arising from foreign currency operations and 
exposures. 

Swaps are contractual agreements between 
two parties to exchange a series of cash flows. 
The various swap agreements that BMO enters 
into are as follows: 

•  Commodity swaps – counterparties generally 

exchange fixed-rate and floating-rate 
payments based on a notional value of a 
single commodity. 

•  Credit default swaps – one counterparty pays 
the other a fee in exchange for an agreement 
by the other counterparty to make a payment 
if a credit event occurs, such as bankruptcy or 
failure to pay. 

•  Cross-currency interest rate swaps – fixed-rate 

and floating-rate interest payments and 
principal amounts are exchanged in different 
currencies. 

•  Cross-currency swaps – fixed-rate interest 

payments and principal amounts are 
exchanged in different currencies. 

•  Equity swaps – counterparties exchange the 
return on an equity security or a group of 
equity securities for a return based on a fixed 
or floating interest rate or the return on 
another equity security or group of equity 
securities. 

•  Interest rate swaps – counterparties generally 
exchange fixed-rate and floating-rate interest 
payments based on a notional value in a single 
currency. 

•  Total return swaps – one counterparty agrees 
to pay or receive from the other cash amounts 
based on changes in the value of a reference 
asset or group of assets, including any returns 
such as interest earned on these assets, in 
exchange for amounts that are based on 
prevailing market funding rates. 

Tangible Common Equity is calculated as 
common shareholders’ equity, less goodwill and 
acquisition-related intangible assets, net of 
related deferred tax liabilities. 

Taxable Equivalent Basis (teb): Revenues of 
operating groups are presented in the MD&A on 
a taxable equivalent basis (teb). Revenue and 
the provision for income taxes are increased on 
tax-exempt securities to an equivalent pre-tax 
basis to facilitate comparisons of income 
between taxable and tax-exempt sources. The 
effective tax rate is also analyzed on a teb basis 
for consistency of approach, with the offset to 
operating segment adjustments recorded in 
Corporate Services. 

Tier 1 Capital comprises CET1 Capital and 
Additional Tier 1 (AT1) Capital. AT1 Capital 
consists of preferred shares and other AT1 
Capital instruments, less regulatory deductions. 

Tier 1 Capital Ratio reflects Tier 1 Capital 
divided by risk-weighted assets. 

Tier 2 Capital comprises subordinated 
debentures and may include certain credit loss 
provisions, less regulatory deductions. 

Total Capital includes Tier 1 and Tier 2 Capital. 

Total Capital Ratio reflects Total Capital divided 
by risk-weighted assets. 

Total Loss Absorbing Capacity (TLAC) 
comprises Total Capital and senior unsecured 
debt subject to the Canadian Bail-In Regime, 
less regulatory deductions. The largest Canadian 
banks are required to meet the minimum TLAC 
Ratio and TLAC Leverage Ratio effective 
November 1, 2021, as calculated under OSFI’s 
TLAC Guideline. 

Total Loss Absorbing Capacity (TLAC) Ratio 
reflects TLAC divided by risk-weighted assets. 

Total Loss Absorbing Capacity (TLAC) 
Leverage Ratio reflects TLAC divided by 
leverage exposures. 

Total Shareholder Return: The three-year and 
five-year average annual total shareholder 
return (TSR) represents the average annual total 
return earned on an investment in BMO 
common shares made at the beginning of a 
three-year and five-year period, respectively. 
The return includes the change in share price 
and assumes dividends received were 
reinvested in additional common shares. The 
one-year TSR also assumes that dividends were 
reinvested in shares. 

Trading and Underwriting Market Risk is 
associated with buying and selling financial 
products in the course of meeting customer 
requirements, including market-making and 
related financing activities, and assisting clients 
to raise funds by way of securities issuance. 

Trading-Related Revenue includes net interest 
income and non-interest revenue earned from 
on-balance sheet and off-balance sheet 
positions undertaken for trading purposes. The 
management of these positions typically 
includes marking them to market on a daily 
basis. Trading-related revenue also includes 
income (expense) and gains (losses) from both 
on-balance sheet instruments and interest rate, 
foreign exchange (including spot positions), 
equity, commodity and credit contracts. 

Value-at-Risk (VaR) measures the maximum 
loss likely to be experienced in the trading and 
underwriting portfolios, measured at a 99% 
confidence level over a one-day holding period. 
VaR is calculated for specific classes of risk in 
BMO’s trading and underwriting activities 
related to interest rates, foreign exchange rates, 
credit spreads, equity and commodity prices and 
their implied volatilities. 

138  BMO Financial Group 204th Annual Report 2021 

Statement of Management’s Responsibility 
for Financial Information 

Management of Bank of Montreal (the bank) is responsible for the preparation and presentation of the annual consolidated financial statements, 
Management’s Discussion and Analysis (MD&A) and all other information in the Annual Report. 

The consolidated financial statements have been prepared in accordance with International Financial Reporting Standards (IFRS) as issued by the 

International Accounting Standards Board and meet the applicable requirements of the Canadian Securities Administrators (CSA) and the Securities 
and Exchange Commission (SEC) in the United States. The financial statements also comply with the provisions of the Bank Act (Canada) and related 
regulations, including interpretations of IFRS by our regulator, the Office of the Superintendent of Financial Institutions Canada. The MD&A has been 
prepared in accordance with the requirements of securities regulators, including National Instrument 51-102 Continuous Disclosure Obligations of the 
CSA. 

The consolidated financial statements and information in the MD&A necessarily include amounts based on informed judgments and estimates 

of the expected effects of current events and transactions with appropriate consideration to materiality. In addition, in preparing the financial 
information we must interpret the requirements described above, make determinations as to the relevancy of information to be included, and make 
estimates and assumptions that affect reported information. The MD&A also includes information regarding the impact of current transactions and 
events, sources of liquidity and capital resources, operating trends, risks and uncertainties. Actual results in the future may differ materially from our 
present assessment of this information because events and circumstances in the future may not occur as expected. 

The financial information presented in the bank’s Annual Report is consistent with that in the consolidated financial statements. 
In meeting our responsibility for the reliability and timeliness of financial information, we maintain and rely on a comprehensive system of 
internal controls, including organizational and procedural controls, disclosure controls and procedures, and internal control over financial reporting. 
Our system of internal controls includes written communication of our policies and procedures governing corporate conduct and risk management; 
comprehensive business planning; effective segregation of duties; delegation of authority and personal accountability; escalation of relevant 
information for decisions regarding public disclosure; careful selection and training of personnel; and accounting policies that we regularly update. 
Our internal controls are designed to provide reasonable assurance that transactions are authorized, assets are safeguarded and proper records are 
maintained and that we are in compliance with all regulatory requirements. The system of internal controls is further supported by a compliance 
function, which is designed to ensure that we and our employees comply with securities legislation and conflict of interest rules, and by an internal 
audit staff, which conducts periodic audits of all aspects of our operations. 

As of October 31, 2021, we, as the bank’s Chief Executive Officer and Chief Financial Officer, have determined that the bank’s internal control 
over financial reporting is effective. We have certified Bank of Montreal’s annual filings with the CSA and with the SEC pursuant to National Instrument 
52-109, Certification of Disclosure in Issuers’ Annual and Interim Filings and the Securities Exchange Act of 1934. 

In order to provide their audit opinions on our consolidated financial statements and on the bank’s internal control over financial reporting, the 
Shareholders’ Auditors audit our system of internal controls over financial reporting and conduct work to the extent that they consider appropriate. 
Their audit opinion on the bank’s internal control over financial reporting as of October 31, 2021 is set forth on page 145. 

The Board of Directors, based on recommendations from its Audit and Conduct Review Committee, reviews and approves the financial 

information contained in the Annual Report, including the MD&A. The Board of Directors and its relevant committees oversee management’s 
responsibilities for the preparation and presentation of financial information, maintenance of appropriate internal controls, compliance with legal 
and regulatory requirements, management and control of major risk areas, and assessment of significant and related party transactions. 
The Audit and Conduct Review Committee, which is comprised entirely of independent directors, is also responsible for selecting the 
Shareholders’ Auditors and reviewing the qualifications, independence and performance of both the Shareholders’ Auditors and internal audit. 
The Shareholders’ Auditors and the bank’s Chief Auditor have full and free access to the Board of Directors, its Audit and Conduct Review Committee 
and other relevant committees to discuss audit, financial reporting and related matters. 

The Office of the Superintendent of Financial Institutions Canada conducts examinations and inquiries into the affairs of the bank as are deemed 
necessary to ensure that the provisions of the Bank Act, with respect to the safety of the depositors, are being duly observed and that the bank is in 
sound financial condition. 

Darryl White 
Chief Executive Officer 

Tayfun Tuzun 
Chief Financial Officer 

Toronto, Canada 
December 3, 2021 

BMO Financial Group 204th Annual Report 2021  139 

INDEPENDENT AUDITORS’ REPORT 

Independent Auditors’ Report 

To the Shareholders of Bank of Montreal 

Opinion 
We have audited the consolidated financial statements of Bank of Montreal (the Bank), which comprise: 
•  the consolidated balance sheets as at October 31, 2021 and October 31, 2020; 
•  the consolidated statements of income for each of the years in the three-year period ended October 31, 2021; 
•  the consolidated statements of comprehensive income for each of the years in the three-year period ended October 31, 2021; 
•  the consolidated statements of changes in equity for each of the years in the three-year period ended October 31, 2021; 
•  the consolidated statements of cash flows for each of the years in the three-year period ended October 31, 2021; 
•  and notes to the consolidated financial statements, including a summary of significant accounting policies 

(Hereinafter referred to as the consolidated financial statements). 

In our opinion, the consolidated financial statements present fairly, in all material respects, the consolidated financial position of the Bank as 
at October 31, 2021 and October 31, 2020, and its consolidated financial performance and its consolidated cash flows for each of the years in the 
three-year period ended October 31, 2021 in accordance with International Financial Reporting Standards (IFRS) as issued by the International 
Accounting Standards Board. 

Basis for Opinion 
We conducted our audit in accordance with Canadian generally accepted auditing standards. Our responsibilities under those standards are further 
described in the Auditors’ Responsibilities for the Audit of the Consolidated Financial Statements section of our auditors’ report. 

We are independent of the Bank in accordance with the ethical requirements that are relevant to our audit of the consolidated financial 

statements in Canada and we have fulfilled our other ethical responsibilities in accordance with these requirements. 

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion. 

Key Audit Matters 
Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the consolidated financial 
statements for the year ended October 31, 2021. These matters were addressed in the context of our audit of the consolidated financial statements 
as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters. 

We have determined the matters described below to be the key audit matters to be communicated in our auditors’ report. 

Assessment of the Allowances for Credit Losses for Loans 
Refer to Notes 1 and 4 to the consolidated financial statements. 

The Bank’s allowance for credit losses (ACL) as at October 31, 2021 was $2,958 million. The Bank’s ACL consists of allowances for impaired loans 
and allowances for performing loans (APL), both calculated under the IFRS 9 Financial Instruments expected credit losses framework. APL is calculated 
for each exposure in the loan portfolio as a function of the key modeled inputs being probability of default (PD), exposure at default (EAD) and loss 
given default (LGD). In establishing APL, the Bank’s methodology attaches probability weightings to three economic scenarios, which represent the 
Bank’s judgment about a range of forecast economic variables – a base case scenario being the Bank’s view of the most probable outcome, as well as 
benign and adverse scenarios. Where there has been a significant increase in credit risk, lifetime APL is recorded; otherwise 12 months of APL is 
generally recorded. The Bank’s methodology for determining significant increase in credit risk is based on the change in PD between the origination 
date and reporting date and is assessed using probability weighted scenarios. The Bank uses experienced credit judgment (ECJ) to reflect factors not 
captured in the results produced by the APL models. 

We identified the assessment of the ACL for loans as a key audit matter. Significant auditor judgment was required because there was a high 

degree of measurement uncertainty in the Bank’s key modeled inputs, methodology and judgments and their resulting impact on the APL, as 
described above, including impacts of the COVID-19 pandemic. Assessing the APL also required significant auditor attention and complex auditor 
judgment to evaluate the results of audit procedures. Further, specialized skills and knowledge, including experience in the industry, were required 
to apply audit procedures and evaluate the results of those procedures. 

The following are the primary procedures we performed to address this key audit matter. We evaluated the design and tested the operating 
effectiveness of certain internal controls over the Bank’s APL process, with the involvement of credit risk, economics, and information technology 
professionals with specialized skills, industry knowledge and relevant experience. This included internal controls related to (1) monitoring and 
periodic validation of the models used to derive the key modeled inputs, (2) monitoring of the methodology for identifying significant increase in 
credit risk, and (3) review of the economic variables, probability weighting of scenarios and ECJ. We also tested the controls over the Bank’s APL 
process related to loan reviews for determination of loan risk grades for wholesale loans. We involved credit risk and economics professionals with 
specialized skills, industry knowledge and relevant experience, who assisted in evaluating the (1) key modeled inputs and APL methodology including 
the determination of significant increases in credit risk by evaluating the methodology for compliance with IFRS 9 and re-calculating model 
monitoring tests in respect of the key modeled inputs and thresholds used for significant increases in credit risk, (2) economic variables and 
probability weighting of scenarios used in the models by assessing the variables and scenarios against external economic data, and (3) ECJ overlays 
to the APL used by the Bank by applying our knowledge of the industry and credit judgment to assess management’s judgments. For a selection of 
wholesale loans, we developed an independent estimate of the loan risk grades using the Bank’s borrower risk rating scale, and compared that to 
the Bank’s assigned loan risk grade. 

140  BMO Financial Group 204th Annual Report 2021 

Assessment of the Measurement of the Fair Value of Certain Securities 
Refer to Notes 1, 3 and 17 to the consolidated financial statements. 

The Bank’s securities portfolio included $181,744 million of securities as at October 31, 2021 that are measured at fair value. Included in these 

amounts are certain securities for which the Bank determines fair value using models and third-party net asset valuations (NAVs) that use significant 
unobservable market information. Unobservable inputs require the use of significant judgment. Certain of the significant unobservable inputs use d in 
the valuation of such securities are NAVs and prepayment rates. 

We identified the assessment of the measurement of the fair value of certain securities as a key audit matter. Significant auditor judgment 
was required because there was a high degree of measurement uncertainty in the significant unobservable inputs. Significant auditor attention and 
complex auditor judgment was required to evaluate the results of audit procedures. Further, specialized skills and knowledge, including experienc e in 
the industry, were required to apply audit procedures and evaluate the results of those procedures. 

The following are the primary procedures we performed to address this key audit matter. We evaluated the design and tested the operating 

effectiveness of certain internal controls over the Bank’s process to determine the fair value of certain securities with the involvement of valuation 
and information technology professionals with specialized skills, industry knowledge and relevant experience. This included controls related to (1) the 
assessment of rate sources used in independent price verification, and (2) segregation of duties and access controls. We also evaluated the design 
and tested the operating effectiveness of the controls related to the 1) review of third-party NAVs, and 2) independent price verification. We tested, 
with involvement of valuation professionals with specialized skills, industry knowledge and relevant experience, the fair value of a selection of 
securities, for which prepayment rates are used in valuation, by developing an independent estimate of fair value and comparing it to the fair value 
determined by the Bank. For a selection of securities, we compared the NAVs to external information. 

Assessment of Income Tax Uncertainties 
Refer to Notes 1 and 22 to the consolidated financial statements. 

In determining the provision for income taxes, the Bank interprets tax legislation, case law and administrative positions, and, based on its 

judgment, records a provision for an estimate of the amount required to settle tax obligations. 

We identified the assessment of income tax uncertainties as a key audit matter. Significant auditor judgment was required because there was 

a high degree of subjectivity in assessing the need to record a provision, based on interpretation of tax legislation, case law and administrative 
positions, for these uncertainties and estimating the amount of such provision, if necessary. This required significant auditor attention and complex 
auditor judgment to evaluate the results of audit procedures. Further, specialized skills and knowledge, including experience in the industry, were 
required to apply audit procedures and evaluate the results of those audit procedures. 

The following are the primary procedures we performed to address this key audit matter. We evaluated the design and tested the operating 

effectiveness of certain internal controls over the Bank’s process for evaluating income tax uncertainties with the involvement of tax professionals 
with specialized skills, industry knowledge and relevant experience. This included controls related to the 1) identification of tax uncertainties based 
on interpretation of tax legislation, case law and administrative positions, and 2) determination of the best estimate of the provision required, if any, 
to settle these uncertainties. We involved tax professionals with specialized skills, industry knowledge and relevant experience, who assisted in 
1) evaluating, based on their knowledge and experience, the Bank’s interpretations of tax legislation, case law and administrative positions and the 
assessment of certain tax uncertainties and expected outcomes, including, if applicable, the measurement thereof, 2) reading advice obtained by the 
Bank from external specialists and evaluating its impact on the Bank’s provision, if necessary, and 3) reading correspondence with taxation 
authorities and evaluating its impact on the Bank’s provision, if necessary. 

Assessment of Insurance-related Liabilities 
Refer to Notes 1 and 14 to the consolidated financial statements. 

The Bank’s insurance-related liabilities as at October 31, 2021 were $12,845 million. The Bank determines the liabilities for life insurance 
contracts by applying the Canadian Asset Liability Method for Insurance Contracts, which incorporates best-estimate assumptions. Certain significant 
assumptions include mortality, policy lapses and future investment yields. 

We identified the assessment of insurance-related liabilities as a key audit matter. Significant auditor judgment was required because there was 

a high degree of measurement uncertainty in the significant assumptions. Significant and complex auditor judgment was required to evaluate the 
results of audit procedures. Further, specialized skills and knowledge, including experience in the industry, were required to apply audit procedures 
and evaluate the results of those audit procedures. 

The following are the primary procedures we performed to address this key audit matter. With the assistance of actuarial professionals with 
specialized skills, industry knowledge and relevant experience, we evaluated the design and tested the operating effectiveness of internal controls 
over assessment of the significant assumptions. We involved these actuarial professionals also in testing the significant assumptions by examining 
the Bank’s internal and external experience studies for policy lapses and mortality, and examining management’s calculations and comparing certain 
inputs into the future investment yields to externally available data. 

Other Information 
Management is responsible for the other information. Other information comprises: 
•  the information included in Management’s Discussion and Analysis filed with the relevant Canadian Securities Commissions. 
•  the information, other than the consolidated financial statements and the auditors’ report thereon, included in a document entitled 

the “Annual Report”. 

Our opinion on the consolidated financial statements does not cover the other information and we do not and will not express any form of assurance 
conclusion thereon. 

In connection with our audit of the consolidated financial statements, our responsibility is to read the other information identified above and, in 
doing so, consider whether the other information is materially inconsistent with the consolidated financial statements or our knowledge obtained in 
the audit and remain alert for indications that the other information appears to be materially misstated. 

We obtained the information included in Management’s Discussion and Analysis and the Annual Report filed with the relevant Canadian Securities 

Commissions as at the date of this auditors’ report. If, based on the work we have performed on this other information, we conclude that there is a 
material misstatement of this other information, we are required to report that fact in the auditors’ report. We have nothing to report in this regard. 

BMO Financial Group 204th Annual Report 2021  141 

INDEPENDENT AUDITORS’ REPORT 

Responsibilities of Management and Those Charged with Governance for the Consolidated Financial Statements 
Management is responsible for the preparation and fair presentation of the consolidated financial statements in accordance with IFRS as issued by 
the International Accounting Standards Board, and for such internal control as management determines is necessary to enable the preparation of 
consolidated financial statements that are free from material misstatement, whether due to fraud or error. 

In preparing the consolidated financial statements, management is responsible for assessing the Bank’s ability to continue as a going concern, 

disclosing as applicable, matters related to going concern and using the going concern basis of accounting unless management either intends to 
liquidate the Bank or to cease operations, or has no realistic alternative but to do so. 

Those charged with governance are responsible for overseeing the Bank’s financial reporting process. 

Auditors’ Responsibilities for the Audit of the Consolidated Financial Statements 
Our objectives are to obtain reasonable assurance about whether the consolidated financial statements as a whole are free from material 
misstatement, whether due to fraud or error, and to issue an auditors’ report that includes our opinion. 

Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with Canadian generally 

accepted auditing standards will always detect a material misstatement when it exists. 

Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected 

to influence the economic decisions of users taken on the basis of the consolidated financial statements. 

As part of an audit in accordance with Canadian generally accepted auditing standards, we exercise professional judgment and maintain 

professional skepticism throughout the audit. 

We also: 

•  Identify and assess the risks of material misstatement of the consolidated financial statements, whether due to fraud or error, design and perform 
audit procedures responsive to those risks, and obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of 
not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, 
intentional omissions, misrepresentations, or the override of internal control. 

•  Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances, but 

not for the purpose of expressing an opinion on the effectiveness of the Bank’s internal control. 

•  Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related disclosures made by 

management. 

•  Conclude on the appropriateness of management’s use of the going concern basis of accounting and, based on the audit evidence obtained, 

whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Bank’s ability to continue as a going 
concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditors’ report to the related disclosures in the 
consolidated financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit evidence 
obtained up to the date of our auditors’ report. However, future events or conditions may cause the Bank to cease to continue as a going concern. 

•  Evaluate the overall presentation, structure and content of the consolidated financial statements, including the disclosures, and whether the 

consolidated financial statements represent the underlying transactions and events in a manner that achieves fair presentation. 

•  Communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and significant audit 

findings, including any significant deficiencies in internal control that we identify during our audit. 

•  Provide those charged with governance with a statement that we have complied with relevant ethical requirements regarding independence, and 
communicate with them all relationships and other matters that may reasonably be thought to bear on our independence, and where applicable, 
related safeguards. 

•  Obtain sufficient appropriate audit evidence regarding the financial information of the entities or business activities within the Bank to express an 
opinion on the consolidated financial statements. We are responsible for the direction, supervision and performance of the group audit. We remain 
solely responsible for our audit opinion. 

•  Determine, from the matters communicated with those charged with governance, those matters that were of most significance in the audit of the 
consolidated financial statements of the current period and are therefore the key audit matters. We describe these matters in our auditors’ report 
unless law or regulation precludes public disclosure about the matter or when, in extremely rare circumstances, we determine that a matter should 
not be communicated in our auditors’ report because the adverse consequences of doing so would reasonably be expected to outweigh the public 
interest benefits of such communication. 

Chartered Professional Accountants, Licensed Public Accountants 
The engagement partner on the audit resulting in this auditors’ report is Reinhard Dotzlaw. 

Toronto, Canada 
December 3, 2021 

142  BMO Financial Group 204th Annual Report 2021 

Report of Independent Registered Public Accounting Firm 

To the Shareholders and the Board of Directors of Bank of Montreal 

Opinion on the Consolidated Financial Statements 
We have audited the accompanying consolidated balance sheets of Bank of Montreal (the Bank) as at October 31, 2021 and 2020, the related 
consolidated statements of income, comprehensive income, changes in equity and cash flows for each of the years in the three-year period ended 
October 31, 2021, and the related notes (collectively, the consolidated financial statements). In our opinion, the consolidated financial statements 
present fairly, in all material respects, the financial position of the Bank as at October 31, 2021 and 2020, and its financial performance and its cash 
flows for each of the years in the three-year period ended October 31, 2021, in conformity with International Financial Reporting Standards (IFRS) as 
issued by the International Accounting Standards Board. 

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), the Bank’s 

internal control over financial reporting as of October 31, 2021, based on criteria established in Internal Control – Integrated Framework (2013) issued 
by the Committee of Sponsoring Organizations of the Treadway Commission, and our report dated December 3, 2021 expressed an unqualified 
opinion on the effectiveness of the Bank’s internal control over financial reporting. 

Basis for Opinion 
These consolidated financial statements are the responsibility of the Bank’s management. Our responsibility is to express an opinion on these 
consolidated financial statements based on our audits. We are a public accounting firm registered with the PCAOB and are required to be independent 
with respect to the Bank in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange 
Commission and the PCAOB. 

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain 

reasonable assurance about whether the consolidated financial statements are free of material misstatement, whether due to error or fraud. Our 
audits included performing procedures to assess the risks of material misstatement of the consolidated financial statements, whether due to error or 
fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts 
and disclosures in the consolidated financial statements. Our audits also included evaluating the accounting principles used and significant estimates 
made by management, as well as evaluating the overall presentation of the consolidated financial statements. We believe that our audits provide a 
reasonable basis for our opinion. 

Critical Audit Matters 
The critical audit matters communicated below are matters arising from the current period audit of the consolidated financial statements that were 
communicated or required to be communicated to the Audit and Conduct Review Committee and that: (1) relate to accounts or disclosures that are 
material to the consolidated financial statements and (2) involved our especially challenging, subjective, or complex judgments. The communication 
of critical audit matters does not alter in any way our opinion on the consolidated financial statements, taken as a whole, and we are not, by 
communicating the critical audit matters below, providing separate opinions on the critical audit matters or on the accounts or disclosures to which 
they relate. 

Assessment of the Allowances for Credit Losses for Loans 
As discussed in Notes 1 and 4 to the consolidated financial statements, the Bank’s allowance for credit losses (ACL) as at October 31, 2021 was 
$2,958 million. The Bank’s ACL consists of allowances for impaired loans and allowances for performing loans (APL), both calculated under the IFRS 9 
Financial Instruments expected credit losses framework. APL is calculated for each exposure in the loan portfolio as a function of the key modeled 
inputs being probability of default (PD), exposure at default (EAD) and loss given default (LGD). In establishing APL, the Bank’s methodology attaches 
probability weightings to three economic scenarios, which represent the Bank’s judgment about a range of forecast economic variables – a base case 
scenario being the Bank’s view of the most probable outcome, as well as benign and adverse scenarios. Where there has been a significant increase 
in credit risk, lifetime APL is recorded; otherwise 12 months of APL is generally recorded. The Bank’s methodology for determining significant increase 
in credit risk is based on the change in PD between the origination date and reporting date and is assessed using probability weighted scenarios. 
The Bank uses experienced credit judgment (ECJ) to reflect factors not captured in the results produced by the APL models. 

We identified the assessment of the ACL for loans as a critical audit matter. Significant auditor judgment was required because there was a 
high degree of measurement uncertainty in the Bank’s key modeled inputs, methodology and judgments and their resulting impact on the APL, 
as described above, including impacts of the COVID-19 pandemic. Assessing the APL also required significant auditor attention and complex auditor 
judgment to evaluate the results of audit procedures. Further, specialized skills and knowledge, including experience in the industry, were required 
to apply audit procedures and evaluate the results of those procedures. 

The following are the primary procedures we performed to address this critical audit matter. We evaluated the design and tested the operating 

effectiveness of certain internal controls over the Bank’s APL process, with the involvement of credit risk, economics, and information technology 
professionals with specialized skills, industry knowledge and relevant experience. This included internal controls related to (1) monitoring and 
periodic validation of the models used to derive the key modeled inputs, (2) monitoring of the methodology for identifying significant increase in 
credit risk, and (3) review of the economic variables, probability weighting of scenarios and ECJ. We also tested the controls over the Bank’s APL 
process related to loan reviews for determination of loan risk grades for wholesale loans. We involved credit risk and economics professionals with 
specialized skills, industry knowledge and relevant experience, who assisted in evaluating the (1) key modeled inputs and APL methodology including 
the determination of significant increases in credit risk by evaluating the methodology for compliance with IFRS 9 and re-calculating model 
monitoring tests in respect of the key modeled inputs and thresholds used for significant increases in credit risk, (2) economic variables and 
probability weighting of scenarios used in the models by assessing the variables and scenarios against external economic data, and (3) ECJ overlays 
to the APL used by the Bank by applying our knowledge of the industry and credit judgment to assess management’s judgments. For a selection of 
wholesale loans, we developed an independent estimate of the loan risk grades using the Bank’s borrower risk rating scale, and compared that to 
the Bank’s assigned loan risk grade. 

BMO Financial Group 204th Annual Report 2021  143 

Assessment of the Measurement of the Fair Value of Certain Securities 
As discussed in Notes 1, 3 and 17 to the consolidated financial statements, the Bank’s securities portfolio included $181,744 million of securities as 
at October 31, 2021 that are measured at fair value. Included in these amounts are certain securities for which the Bank determines fair value using 
models and third-party net asset valuations (NAVs) that use significant unobservable market information. Unobservable inputs require the use of 
significant judgment. Certain of the significant unobservable inputs used in the valuation of such securities are NAVs and prepayment rates. 

We identified the assessment of the measurement of the fair value of certain securities as a critical audit matter. Significant auditor judgment 
was required because there was a high degree of measurement uncertainty in the significant unobservable inputs. Significant auditor attention and 
complex auditor judgment was required to evaluate the results of audit procedures. Further, specialized skills and knowledge, including experienc e in 
the industry, were required to apply audit procedures and evaluate the results of those procedures. 

The following are the primary procedures we performed to address this critical audit matter. We evaluated the design and tested the operating 
effectiveness of certain internal controls over the Bank’s process to determine the fair value of certain securities with the involvement of valuation 
and information technology professionals with specialized skills, industry knowledge and relevant experience. This included controls related to (1) the 
assessment of rate sources used in independent price verification, and (2) segregation of duties and access controls. We also evaluated the design 
and tested the operating effectiveness of the controls related to the 1) review of third-party NAVs, and 2) independent price verification. We tested, 
with involvement of valuation professionals with specialized skills, industry knowledge and relevant experience, the fair value of a selection of 
securities, for which prepayment rates are used in valuation, by developing an independent estimate of fair value and comparing it to the fair value 
determined by the Bank. For a selection of securities, we compared the NAVs to external information. 

Assessment of Income Tax Uncertainties 
As discussed in Notes 1 and 22 to the consolidated financial statements, in determining the provision for income taxes, the Bank interprets tax 
legislation, case law and administrative positions, and, based on its judgment, records a provision for an estimate of the amount required to settle 
tax obligations. 

We identified the assessment of income tax uncertainties as a critical audit matter. Significant auditor judgment was required because there 
was a high degree of subjectivity in assessing the need to record a provision, based on interpretation of tax legislation, case law and administrative 
positions, for these uncertainties and estimating the amount of such provision, if necessary. This required significant auditor attention and complex 
auditor judgment to evaluate the results of audit procedures. Further, specialized skills and knowledge, including experience in the industry, were 
required to apply audit procedures and evaluate the results of those audit procedures. 

The following are the primary procedures we performed to address this critical audit matter. We evaluated the design and tested the operating 
effectiveness of certain internal controls over the Bank’s process for evaluating income tax uncertainties with the involvement of tax professionals 
with specialized skills, industry knowledge and relevant experience. This included controls related to the 1) identification of tax uncertainties based 
on interpretation of tax legislation, case law and administrative positions, and 2) determination of the best estimate of the provision required, if 
any, to settle these uncertainties. We involved tax professionals with specialized skills, industry knowledge and relevant experience, who assisted in 
1) evaluating, based on their knowledge and experience, the Bank’s interpretations of tax legislation, case law and administrative positions and the 
assessment of certain tax uncertainties and expected outcomes, including, if applicable, the measurement thereof, 2) reading advice obtained by the 
Bank from external specialists and evaluating its impact on the Bank’s provision, if necessary, and 3) reading correspondence with taxation 
authorities and evaluating its impact on the Bank’s provision, if necessary. 

Assessment of Insurance-Related Liabilities 
As discussed in Notes 1 and 14 to the consolidated financial statements, the Bank’s insurance-related liabilities as at October 31, 2021 were 
$12,845 million. The Bank determines the liabilities for life insurance contracts by applying the Canadian Asset Liability Method for Insurance 
Contracts, which incorporates best-estimate assumptions. Certain significant assumptions include mortality, policy lapses and future 
investment yields. 

We identified the assessment of insurance-related liabilities as a critical audit matter. Significant auditor judgment was required because there 
was a high degree of measurement uncertainty in the significant assumptions. Significant and complex auditor judgment was required to evaluate 
the results of audit procedures. Further, specialized skills and knowledge, including experience in the industry, were required to apply audit 
procedures and evaluate the results of those audit procedures. 

The following are the primary procedures we performed to address this critical audit matter. With the assistance of actuarial professionals with 
specialized skills, industry knowledge and relevant experience, we evaluated the design and tested the operating effectiveness of internal controls 
over assessment of the significant assumptions. We involved these actuarial professionals also in testing the significant assumptions by examining 
the Bank’s internal and external experience studies for policy lapses and mortality, and examining management’s calculations and comparing certain 
inputs into the future investment yields to externally available data. 

Chartered Professional Accountants, Licensed Public Accountants 
We have served as the Bank’s auditor since 2004 and as joint auditor for the prior 14 years. 

Toronto, Canada 
December 3, 2021 

144  BMO Financial Group 204th Annual Report 2021 

Report of Independent Registered Public Accounting Firm 

To the Shareholders and the Board of Directors of Bank of Montreal 

Opinion on Internal Control over Financial Reporting 
We have audited Bank of Montreal’s internal control over financial reporting as of October 31, 2021, based on the criteria established in Internal 
Control – Integrated Framework (2013) issued by the Committee of Sponsoring Organizations of the Treadway Commission. 

In our opinion, Bank of Montreal (the Bank) maintained, in all material respects, effective internal control over financial reporting as of 

October 31, 2021, based on the criteria established in Internal Control – Integrated Framework (2013) issued by the Committee of Sponsoring 
Organizations of the Treadway Commission. 

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), the 
consolidated balance sheets of the Bank as at October 31, 2021 and 2020, the related consolidated statements of income, comprehensive income, 
changes in equity and cash flows for each of the years in the three-year period ended October 31, 2021, and the related notes (collectively, the 
consolidated financial statements) and our report dated December 3, 2021 expressed an unqualified opinion on those consolidated financial 
statements. 

Basis for Opinion 
The Bank’s management is responsible for maintaining effective internal control over financial reporting and for its assessment of the effectiveness 
of internal control over financial reporting, included in the accompanying Management’s Annual Report on Disclosure Controls and Procedures and 
Internal Control over Financial Reporting, on page 121 of Management’s Discussion and Analysis. Our responsibility is to express an opinion on the 
Bank’s internal control over financial reporting based on our audit. 

We are a public accounting firm registered with the PCAOB and are required to be independent with respect to the Bank in accordance with the 

U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. 

We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain 
reasonable assurance about whether effective internal control over financial reporting was maintained in all material respects. Our audit of internal 
control over financial reporting included obtaining an understanding of internal control over financial reporting, assessing the risk that a material 
weakness exists, and testing and evaluating the design and operating effectiveness of internal control based on the assessed risk. Our audit also 
included performing such other procedures as we considered necessary in the circumstances. We believe that our audit provides a reasonable basis 
for our opinion. 

Definition and Limitations of Internal Control Over Financial Reporting 
A company’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial 
reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A company’s 
internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable 
detail, accurately and fairly reflect the transactions and dispositions of the assets of the company; (2) provide reasonable assurance that transactions 
are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts 
and expenditures of the company are being made only in accordance with authorizations of management and directors of the company; and 
(3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the company’s 
assets that could have a material effect on the financial statements. 

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any 
evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that 
the degree of compliance with the policies or procedures may deteriorate. 

Chartered Professional Accountants, Licensed Public Accountants 
Toronto, Canada 
December 3, 2021 

BMO Financial Group 204th Annual Report 2021  145 

CONSOLIDATED FINANCIAL STATEMENTS 

Consolidated Statement of Income 

For the Year Ended October 31 (Canadian $ in millions, except as noted) 

2021 

2020 

2019 

Interest, Dividend and Fee Income 
Loans 
Securities (Note 3) (1) 
Deposits with banks 

Interest Expense 
Deposits 
Subordinated debt 
Other liabilities (Note 14) 

Net Interest Income 

Non-Interest Revenue 
Securities commissions and fees 
Deposit and payment service charges 
Trading revenues (Note 17) 
Lending fees 
Card fees 
Investment management and custodial fees 
Mutual fund revenues 
Underwriting and advisory fees 
Securities gains, other than trading (Note 3) 
Foreign exchange gains, other than trading 
Insurance revenue 
Investments in associates and joint ventures 
Other 

Total Revenue 

Provision for Credit Losses (Note 4) 

Insurance Claims, Commissions and Changes in Policy Benefit Liabilities (Note 14) 

Non-Interest Expense 
Employee compensation (Notes 20 and 21) 
Premises and equipment (Note 9) 
Amortization of intangible assets (Note 11) 
Travel and business development 
Communications 
Professional fees 
Other (Note 10) 

s
t
n
e
m
e
t
a
t
S

l
a
i
c
n
a
n
i
F
d
e
t
a
d

i
l

o
s
n
o
C

Income Before Provision for Income Taxes 
Provision for income taxes (Note 22) 

Net  Income 

Earnings Per Common Share (Canadian $) (Note 23) 
Basic 
Diluted 
Dividends per common share 

$ 

$ 

$ 

15,727 
3,963 
197 

19,887 

3,220 
195 
2,162 

5,577 

17,945 
4,980 
390 

23,315 

6,239 
265 
2,840 

9,344 

14,310 

13,971 

1,107 
1,243 
296 
1,391 
442 
1,982 
1,595 
1,421 
591 
167 
1,941 
248 
452 

12,876 

27,186 

20 

1,399 

8,322 
3,396 
634 
397 
264 
607 
1,889 

15,509 

10,258 
2,504 

7,754 

11.60 
11.58 
4.24 

$ 

$ 

1,036 
1,221 
15 
1,295 
358 
1,807 
1,417 
1,070 
124 
127 
2,178 
161 
406 

11,215 

25,186 

2,953 

1,708 

7,944 
3,202 
620 
384 
304 
555 
1,168 

14,177 

6,348 
1,251 

5,097 

7.56 
7.55 
4.24 

$ 

$ 

$ 

$ 

19,824 
5,541 
787 

26,152 

8,616 
279 
4,369 

13,264 

12,888 

1,023 
1,204 
298 
1,192 
437 
1,747 
1,419 
975 
249 
166 
3,183 
151 
551 

12,595 

25,483 

872 

2,709 

8,423 
2,988 
554 
545 
296 
568 
1,256 

14,630 

7,272 
1,514 

5,758 

8.68 
8.66 
4.06 

(1) 

Includes interest income on securities measured at fair value through other comprehensive income and amortized cost, calculated using the effective interest rate method, of $889 million for the 
year ended October 31, 2021 ($1,532 million in 2020 and $1,853 million in 2019). 

The accompanying notes are an integral part of these consolidated financial statements. 

Certain comparative figures have been reclassified to conform with the current year’s presentation. 

Darryl White 
Chief Executive Officer 

Jan Babiak 
Chair, Audit and Conduct Review Committee 

146  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
Consolidated Statement of Comprehensive Income 

For the Year Ended October 31 (Canadian $ in millions) 

Net Income 

Other Comprehensive Income (Loss), net of taxes (Note 22) 
Items that may subsequently be reclassified to net income 

Net change in unrealized gains (losses) on fair value through OCI debt securities 

Unrealized gains (losses) on fair value through OCI debt securities arising during the year 
Reclassification to earnings of (gains) in the year 

Net change in unrealized gains (losses) on cash flow hedges 

Gains (losses) on derivatives designated as cash flow hedges arising during the year 
Reclassification to earnings of (gains) losses on derivatives designated as cash flow hedges 

Net gains (losses) on translation of net foreign operations 

Unrealized gains (losses) on translation of net foreign operations 
Unrealized gains (losses) on hedges of net foreign operations 

Items that will not be reclassified to net income 

Unrealized gains on fair value through OCI equity securities arising during the year 
Gains (losses) on remeasurement of pension and other employee future benefit plans 
Gains (losses) on remeasurement of own credit risk on financial liabilities designated at fair value 

Other Comprehensive Income (Loss), net of taxes (Note 22) 

Total  Comprehensive  Income 

The accompanying notes are an integral part of these consolidated financial statements. 

2021 

2020 

2019 

$ 

7,754 

$ 

5,097 

$ 

5,758 

(161) 
(43) 

(204) 

(1,380) 
(414) 

(1,794) 

(2,207) 
496 

(1,711) 

20 
923 
(196) 

747 

(2,962) 

$ 

4,792 

$ 

410 
(81) 

329 

1,513 
(47) 

1,466 

373 
(96) 

277 

– 
(255) 
(28) 

(283) 

1,789 

6,886 

$ 

412 
(72) 

340 

1,444 
143 

1,587 

(11) 
(13) 

(24) 

1 
(552) 
75 

(476) 

1,427 

7,185 

C
o
n
s
o

l
i

d
a
t
e
d
F
i
n
a
n
c
i
a
l

S
t
a
t
e
m
e
n
t
s

BMO Financial Group 204th Annual Report 2021  147 

 
 
 
 
 
 
 
CONSOLIDATED FINANCIAL STATEMENTS 

Consolidated Balance Sheet 

As at October 31 (Canadian $ in millions) 

Assets 
Cash and Cash Equivalents (Note 2) 

Interest Bearing Deposits with Banks (Note 2) 

Securities (Note 3) 
Trading 
Fair value through profit or loss 
Fair value through other comprehensive income 
Debt securities at amortized cost 
Investments in associates and joint ventures 

Securities Borrowed or Purchased Under Resale Agreements (Note 4) 

Loans (Notes 4 and 6) 
Residential mortgages 
Consumer instalment and other personal 
Credit cards 
Business and government 

Allowance for credit losses (Note 4) 

Other Assets 
Derivative instruments (Note 8) 
Customers’ liability under acceptances (Note 12) 
Premises and equipment (Notes 1 and 9) 
Goodwill (Note 11) 
Intangible assets (Note 11) 
Current tax assets 
Deferred tax assets (Note 22) 
Other (Note 12) 

Total  Assets 

Liabilities and Equity 
Deposits (Note 13) 

Other Liabilities 
Derivative instruments (Note 8) 
Acceptances (Note 14) 
Securities sold but not yet purchased (Note 14) 
Securities lent or sold under repurchase agreements (Note 6) 
Securitization and structured entities’ liabilities (Notes 6 and 7) 
Current tax liabilities 
Deferred tax liabilities (Note 22) 
Other (Notes 1 and 14) 

Subordinated Debt (Note 15) 

Total  Liabilities 

Equity 
Preferred shares and other equity instruments (Note 16) 
Common shares (Note 16) 
Contributed surplus 
Retained earnings (Note 1) 
Accumulated other comprehensive income 

Total  Equity 

Total  Liabilities  and  Equity 

The accompanying notes are an integral part of these consolidated financial statements. 

Certain comparative figures have been reclassified to conform with the current year’s presentation. 

148  BMO Financial Group 204th Annual Report 2021 

2021 

2020 

$ 

93,261 

$ 

57,408 

8,303 

9,035 

104,411 
14,210 
63,123 
49,970 
1,135 

232,849 

107,382 

135,750 
77,164 
8,103 
239,809 

460,826 
(2,564) 

458,262 

36,713 
14,021 
4,454 
5,378 
2,266 
1,588 
1,287 
22,411 

88,118 

97,834 
13,568 
73,407 
48,466 
985 

234,260 

111,878 

127,024 
70,148 
7,889 
245,662 

450,723 
(3,303) 

447,420 

36,815 
13,493 
4,183 
6,535 
2,442 
1,260 
1,473 
23,059 

89,260 

$ 

988,175 

$ 

685,631 

$ 

$ 

949,261 

659,034 

30,815 
14,021 
32,073 
97,556 
25,486 
221 
192 
37,764 

238,128 

6,893 

930,652 

5,558 
13,599 
313 
35,497 
2,556 

57,523 

30,375 
13,493 
29,376 
88,658 
26,889 
126 
108 
36,193 

225,218 

8,416 

892,668 

6,598 
13,430 
302 
30,745 
5,518 

56,593 

$ 

988,175 

$ 

949,261 

s
t
n
e
m
e
t
a
t
S

l
a
i
c
n
a
n
i
F
d
e
t
a
d

i
l

o
s
n
o
C

 
 
 
 
 
 
 
Consolidated Statement of Changes in Equity 

For the Year Ended October 31 (Canadian $ in millions) 

Preferred Shares and Other Equity Instruments (Note 16) 
Balance at beginning of year 
Issued during the year 
Redeemed during the year 

Balance at End of Year 

Common Shares (Note 16) 
Balance at beginning of year 
Issued under the Shareholder Dividend Reinvestment and Share Purchase Plan 
Issued under the Stock Option Plan 
Repurchased for cancellation and/or treasury shares sold/purchased 

Balance at End of Year 

Contributed Surplus 
Balance at beginning of year 
Stock option expense, net of options exercised (Note 20) 
Other 

Balance at End of Year 

Retained Earnings 
Balance at beginning of year 
Impact from adopting IFRS 16 (Note 1) 
Net income 
Dividends on preferred shares and distributions payable on other equity instruments (Note 16) 
Dividends on common shares (Note 16) 
Equity issue expense and premium paid on redemption of preferred shares 
Common shares repurchased for cancellation (Note 16) 
Net discount on sale of treasury shares 

Balance at End of Year 

Accumulated Other Comprehensive Income on Fair Value through OCI Securities, net of taxes (Note 22) 
Balance at beginning of year 
Unrealized gains (losses) on fair value through OCI debt securities arising during the year 
Unrealized gains on fair value through OCI equity securities arising during the year 
Reclassification to earnings of (gains) during the year 

Balance at End of Year 

Accumulated Other Comprehensive Income on Cash Flow Hedges, net of taxes (Note 22) 
Balance at beginning of year 
Gains (losses) on derivatives designated as cash flow hedges arising during the year (Note 8) 
Reclassification to earnings of (gains) losses on derivatives designated as cash flow hedges in the year 

Balance at End of Year 

Accumulated Other Comprehensive Income on Translation of Net Foreign Operations, net of taxes (Note 22) 
Balance at beginning of year 
Unrealized gains (losses) on translation of net foreign operations 
Unrealized gains (losses) on hedges of net foreign operations 

Balance at End of Year 

Accumulated Other Comprehensive Income (Loss) on Pension and Other Employee Future Benefit Plans, 

net of taxes (Note 22) 

Balance at beginning of year 
Gains (losses) on remeasurement of pension and other employee future benefit plans (Note 21) 

Balance at End of Year 

Accumulated Other Comprehensive (Loss) on Own Credit Risk on Financial Liabilities Designated at Fair 

Value, net of taxes (Note 22) 

Balance at beginning of year 
Gains (losses) on remeasurement of own credit risk on financial liabilities designated at fair value 

Balance at End of Year 

Total Accumulated Other Comprehensive Income 

Total  Equity 

na – not applicable due to IFRS 16 adoption on November 1, 2019. 

The accompanying notes are an integral part of these consolidated financial statements. 

2021 

2020 

2019 

$ 

6,598  $ 
– 
(1,040) 

5,348  $ 
1,250 
– 

5,558 

6,598 

13,430 
– 
122 
47 

13,599 

302 
10 
1 

313 

30,745 
– 
7,754 
(244) 
(2,746) 
(6) 
– 
(6) 

35,497 

355 
(161) 
20 
(43) 

171 

1,979 
(1,380) 
(414) 

185 

3,980 
(2,207) 
496 

2,269 

(638) 
923 

285 

(158) 
(196) 

(354) 

12,971 
471 
40 
(52) 

13,430 

303 
(1) 
– 

302 

28,725 
(59) 
5,097 
(247) 
(2,723) 
(3) 
– 
(45) 

30,745 

26 
410 
– 
(81) 

355 

513 
1,513 
(47) 

1,979 

3,703 
373 
(96) 

3,980 

(383) 
(255) 

(638) 

(130) 
(28) 

(158) 

4,340 
1,008 
– 

5,348 

12,929 
– 
62 
(20) 

12,971 

300 
– 
3 

303 

25,850 
na 
5,758 
(211) 
(2,594) 
(8) 
(70) 
– 

28,725 

(315) 
412 
1 
(72) 

26 

(1,074) 
1,444 
143 

513 

3,727 
(11) 
(13) 

3,703 

169 
(552) 

(383) 

(205) 
75 

(130) 

2,556 

5,518 

3,729 

$ 

57,523  $ 

56,593  $ 

51,076 

BMO Financial Group 204th Annual Report 2021  149 

C
o
n
s
o

l
i

d
a
t
e
d
F
i
n
a
n
c
i
a
l

S
t
a
t
e
m
e
n
t
s

 
 
 
 
 
 
 
 
 
 
 
CONSOLIDATED FINANCIAL STATEMENTS 

Consolidated Statement of Cash Flows 

For the Year Ended October 31 (Canadian $ in millions) 

2021 

2020 

2019 

Cash Flows from Operating Activities 
Net Income 
Adjustments to determine net cash flows provided by (used in) operating activities 

Provision on securities, other than trading (Note 3) 
Net (gain) on securities, other than trading (Note 3) 
Net (increase) decrease in trading securities 
Provision for credit losses (Note 4) 
Change in derivative instruments – (Increase) decrease in derivative asset 

– Increase (decrease) in derivative liability 

Amortization of premises and equipment (Note 9) 
Amortization of other assets 
Amortization of intangible assets (Note 11) 
Write-down of goodwill (Notes 10 and 11) 
Net decrease in deferred tax asset (Note 22) 
Net increase (decrease) in deferred tax liability (Note 22) 
Net (increase) decrease in current tax asset 
Net increase in current tax liability 
Change in accrued interest – (Increase) decrease in interest receivable 

– Increase (decrease) in interest payable 

Changes in other items and accruals, net 
Net increase in deposits 
Net (increase) in loans 
Net increase (decrease) in securities sold but not yet purchased 
Net increase in securities lent or sold under repurchase agreements 
Net (increase) in securities borrowed or purchased under resale agreements 
Net increase (decrease) in securitization and structured entities’ liabilities 

Net Cash Provided by Operating Activities 

Cash Flows from Financing Activities 
Net increase (decrease) in liabilities of subsidiaries 
Proceeds from issuance of covered bonds (Note 13) 
Redemption/buyback of covered bonds (Note 13) 
Proceeds from issuance of subordinated debt (Note 15) 
Repayment of subordinated debt (Note 15) 
Proceeds from issuance of preferred shares and other equity instruments net of issuance cost (Note 16) 
Redemption of preferred shares (Note 16) 
Net proceeds from issuance (repurchase) of common shares and sale (purchase) of treasury shares 
Common shares repurchased for cancellation (Note 16) 
Cash dividends and distributions paid 
Repayment of lease liabilities (1) 

Net Cash (Used in) Financing Activities 

Cash Flows from Investing Activities 
Net (increase) decrease in interest bearing deposits with banks 
Purchases of securities, other than trading 
Maturities of securities, other than trading 
Proceeds from sales of securities, other than trading 
Premises and equipment – net (purchases) (Note 9) 
Purchased and developed software – net (purchases) (Note 11) 
Acquisitions (Note 10) 
Net proceeds from divestitures (Note 10) 

Net Cash (Used in) Investing Activities 

Effect of Exchange Rate Changes on Cash and Cash Equivalents 

Net increase in Cash and Cash Equivalents 
Cash and Cash Equivalents at Beginning of Year 

Cash and Cash Equivalents at End of Year (Note 2) 

Supplemental Disclosure of Cash Flow Information 
Net cash provided by operating activities includes: 

Interest paid in the year (2) 
Income taxes paid in the year 
Interest received in the year 
Dividends received in the year 

(1)  Prior to adoption of IFRS 16, repayments of lease liabilities were included in Net Cash Provided by Operating Activities. 
(2) 
na – not applicable 

Includes dividends paid on securities sold but not yet purchased. 

The accompanying notes are an integral part of these consolidated financial statements. 

Certain comparative figures have been reclassified to conform with the current year’s presentation. 

150  BMO Financial Group 204th Annual Report 2021 

$ 

7,754 

$ 

5,097 

$ 

5,758 

1 
(592) 
(10,447) 
20 
542 
529 
791 
140 
634 
779 
127 
85 
(539) 
143 
75 
(366) 
723 
52,244 
(23,748) 
3,545 
12,866 
(289) 
(968) 

44,049 

– 
4,396 
(4,074) 
1,000 
(2,250) 
– 
(1,046) 
159 
– 
(2,980) 
(327) 

(5,122) 

144 
(49,620) 
27,377 
22,720 
(484) 
(499) 
– 
63 

(299) 

(2,775) 

35,853 
57,408 

2 
(126) 
(10,276) 
2,953 
(12,229) 
5,614 
801 
197 
620 
– 
111 
26 
(55) 
62 
178 
(352) 
(4,501) 
88,341 
(21,941) 
2,972 
824 
(7,104) 
(378) 

50,836 

(8,113) 
4,425 
(6,231) 
1,250 
– 
1,247 
–
(76) 
– 
(2,475) 
(331) 

(10,304) 

(979) 
(86,659) 
19,982 
36,900 
(399) 
(633) 
(186) 
– 

(31,974) 

47 

8,605 
48,803 

1 
(250) 
13,816 
872 
6,902 
(3,774) 
435 
216 
554 
– 
483 
(15) 
354 
6 
(299) 
313 
(1,255) 
48,009 
(43,381) 
(2,524) 
20,358 
(19,396) 
2,120 

29,303 

(1,227) 
4,168 
(3,765) 
1,000 
(1,000) 
1,000 
– 
54 
(90) 
(2,752) 
na 

(2,612) 

329 
(63,496) 
13,154 
31,561 
(478) 
(650) 
– 
– 

(19,580) 

(450) 

6,661 
42,142 

$ 

93,261 

$ 

57,408 

$ 

48,803 

$ 
$ 
$ 
$ 

5,864 
2,167 
18,323 
1,732 

$ 
$ 
$ 
$ 

9,679 
1,537 
21,576 
1,856 

$ 
$ 
$ 
$ 

12,956 
1,209 
23,966 
1,740 

s
t
n
e
m
e
t
a
t
S

l
a
i
c
n
a
n
i
F
d
e
t
a
d

i
l

o
s
n
o
C

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Note 1: Basis of Presentation 
Bank of Montreal (the bank or BMO) is a chartered bank under the Bank Act (Canada) and is a public company incorporated in Canada. We are a 
highly diversified financial services company, providing a broad range of personal and commercial banking, wealth management and investment 
banking products and services. The bank’s head office is at 129 rue Saint-Jacques, Montreal, Quebec. Our executive offices are at 100 King Street 
West, 1 First Canadian Place, Toronto, Ontario. Our common shares are listed on the Toronto Stock Exchange (TSX) and the New York Stock Exchange. 
We have prepared these consolidated financial statements in accordance with International Financial Reporting Standards (IFRS) as issued by the 

International Accounting Standards Board (IASB). We also comply with interpretations of IFRS by our regulator, the Office of the Superintendent of 
Financial Institutions of Canada (OSFI). 

Our consolidated financial statements have been prepared on a historic cost basis, except for the revaluation of the following items: assets and 

liabilities held for trading; financial assets and liabilities measured or designated at fair value through profit or loss (FVTPL); financial assets measured 
or designated at fair value through other comprehensive income (FVOCI); financial assets and financial liabilities designated as hedged items in 
qualifying fair value hedge relationships; cash-settled share-based payment liabilities; defined benefit pension and other employee future benefit 
liabilities; and insurance-related liabilities. 

These consolidated financial statements were authorized for issue by the Board of Directors on December 3, 2021. 

Basis of Consolidation 
These consolidated financial statements are inclusive of the financial statements of our subsidiaries as at October 31, 2021. We conduct business 
through a variety of corporate structures, including subsidiaries, structured entities (SEs), associates and joint ventures. Subsidiaries are those entities 
where we exercise control through our ownership of the majority of the voting shares. We also hold interests in SEs, which we consolidate when we 
control the SEs. These are more fully described in Note 7. All of the assets, liabilities, revenues and expenses of our subsidiaries and consolidated SEs 
are included in our consolidated financial statements. All intercompany transactions and balances are eliminated on consolidation. 

We hold investments in associates where we exert significant influence over operating and financing decisions (generally companies in which 
we own between 20% and 50% of the voting shares). These are accounted for using the equity method. The equity method is also applied to our 
investments in joint ventures, which are entities where we exercise joint control through an agreement with other shareholders. Under the equity 
method of accounting, investments are initially recorded at cost, and the carrying amount is increased or decreased to recognize our share of investee 
net income or loss, including other comprehensive income or loss. Additional information regarding accounting for investments in associates and joint 
ventures is included in Note 3. 

Significant Accounting Policies 
To facilitate a better understanding of our consolidated financial statements, we have disclosed our significant accounting policies throughout the 
following notes with the related financial disclosures by major caption: 

Note  Topic 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 

Basis of Presentation 
Cash and Interest Bearing Deposits with Banks 
Securities 
Loans and Allowance for Credit Losses 
Risk Management 
Transfers of Financial Assets 
Structured Entities 
Derivative Instruments 
Premises and Equipment 
Acquisitions and Divestitures 
Goodwill and Intangible Assets 
Other Assets 
Deposits 
Other Liabilities 
Subordinated Debt 

Page 
151 
157 
157 
160 
167 
167 
168 
171 
179 
180 
181 
182 
183 
184 
185 

Note  Topic 
Equity 
16 
Fair Value of Financial Instruments and Trading-Related 
17 

Revenue 

Offsetting of Financial Assets and Financial Liabilities 
Capital Management 
Employee Compensation – Share-Based Compensation 
Employee Compensation – Pension and Other Employee 

Future Benefits 

Income Taxes 
Earnings Per Share 
Commitments, Guarantees, Pledged Assets, Provisions 

and Contingent Liabilities 

Operating and Geographic Segmentation 
Significant Subsidiaries 
Related Party Transactions 

18 
19 
20 
21 

22 
23 
24 

25 
26 
27 

Page 
186 

188 
195 
195 
196 

198 
201 
204 

204 
207 
210 
211 

Translation of Foreign Currencies 
We conduct business in a variety of foreign currencies and present our consolidated financial statements in Canadian dollars, which is our functional 
currency. Monetary assets and liabilities, as well as non-monetary assets and liabilities measured at fair value that are denominated in foreign 
currencies, are translated into Canadian dollars at the exchange rate in effect at the balance sheet date. Non-monetary assets and liabilities not 
measured at fair value are translated into Canadian dollars at historical rates. Revenues and expenses denominated in foreign currencies are 
translated using the average exchange rate for the year. 

Unrealized gains and losses arising from translating our net investment in foreign operations into Canadian dollars, net of related hedging 
activities and applicable income taxes, are included in our Consolidated Statement of Comprehensive Income within net gains (losses) on translation 
of net foreign operations. When we dispose of a foreign operation such that control, significant influence or joint control is lost, the cumulative 
amount of the translation gain (loss) and any applicable hedging activities and related income taxes is reclassified to our Consolidated Statement 
of Income as part of the gain or loss on disposition. 

Foreign currency translation gains and losses on equity securities measured at FVOCI that are denominated in foreign currencies are included 

in accumulated other comprehensive income on FVOCI equity securities, net of taxes, in our Consolidated Statement of Changes in Equity. All other 
foreign currency translation gains and losses are included in foreign exchange gains, other than trading, in our Consolidated Statement of Income 
as they arise. 

N
o
t
e
s

BMO Financial Group 204th Annual Report 2021  151 

 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

From time to time, we enter into foreign exchange hedge contracts to reduce our exposure to changes in the value of foreign currencies. 
Realized and unrealized gains and losses that arise on the mark-to-market of foreign exchange contracts related to economic hedges are included in 
non-interest revenue in our Consolidated Statement of Income. Changes in the fair value of derivative contracts that qualify as accounting hedges are 
recorded in our Consolidated Statement of Comprehensive Income within net change in unrealized gains (losses) on derivatives designated as cash 
flow hedges, with the spot/forward differential (the difference between the foreign currency exchange rate at the inception of the contract and the 
rate at the end of the contract) recorded in interest income (expense) over the term of the hedge. 

Revenue 
Dividend Income 
Dividend income is recognized when the right to receive payment is established. This is the ex-dividend date for listed equity securities. 

Fee Income 
Securities commissions and fees are earned in BMO Wealth Management and BMO Capital Markets on brokerage transactions executed for 
customers, generally as a fixed fee per share traded, and the commissions and related clearing expense are recognized on trade date. There are also 
fees based on a percentage of the customer’s portfolio holdings that entitle clients to investment advice and a certain number of trades which are 
recorded over the period to which they relate. 

Deposit and payment service charges are primarily earned in Personal and Commercial Banking and include monthly account maintenance fees 
and other activity-based fees earned on deposit and cash management services. Fees are recognized over time when account maintenance and cash 
management services are provided, or at a point in time when an income-generating activity is performed. 

Card fees arise in Personal and Commercial Banking and primarily include interchange income, late fees and annual fees. Card fees are recorded 
when the related services are provided, except for annual fees, which are recorded evenly throughout the year. Interchange income is calculated as a 
percentage of the transaction amount and/or a fixed price per transaction, as established by the payment network, and is recognized when the card 
transaction is settled. Reward costs for our cards are recorded as a reduction in card fees. 

Investment management and custodial fees are earned in BMO Wealth Management and are based primarily on the balance of assets under 
management or assets under administration, as at the period end, for investment management, custodial, estate and trustee services provided. 
Fees are recorded over the period the services are performed. 

Mutual fund revenues arise in BMO Wealth Management and are earned on fund management services which are primarily calculated and recorded 
based on a percentage of the fund’s net asset value. The fees are recorded over the period the services are performed. 

Underwriting and advisory fees are earned in BMO Capital Markets and arise from securities offerings in which we act as an underwriter or agent, 
structuring and administering loan syndications, and fees earned from providing merger-and-acquisition services and structuring advice. Underwriting 
and advisory fees are generally recognized when the services are completed. 

Leases 
We are lessors in both financing leases and operating leases. Leases are classified as financing leases if they transfer substantially all the risks and 
rewards incidental to ownership of the leased asset to the lessee. Otherwise they are classified as operating leases, as we retain substantially all the 
risks and rewards of asset ownership. 

As lessor in a financing lease, a loan is recognized equal to the investment in the lease, which is calculated as the present value of the minimum 

payments to be received from the lessee, discounted at the interest rate implicit in the lease, plus any unguaranteed residual value we expect 
to recover at the end of the lease. Finance lease income is recognized in interest, dividend and fee income, loans, in our Consolidated Statement 
of Income. 

Assets under operating leases are recorded in other assets in our Consolidated Balance Sheet. Rental income is recognized on a straight-line basis 

over the term of the lease in non-interest revenue, other, in our Consolidated Statement of Income. Depreciation on these assets is recognized on a 
straight-line basis over the life of the lease in non-interest expense, other, in our Consolidated Statement of Income. 

Refer to Note 9 for our policy on lessee accounting. 

Assets Held-for-Sale 
Non-current non-financial assets classified as held-for-sale are measured at the lower of their carrying amount and fair value less costs to sell and are 
presented within other assets in our Consolidated Balance Sheet. Subsequent to its initial classification, a non-current asset is no longer depreciated 
or amortized, and any subsequent write-down in fair value less costs to sell is recognized in non-interest revenue, other, in our Consolidated 
Statement of Income. 

s
e
t
o
N

Changes in Accounting Policies 
Interbank Offered Rate (IBOR) Reform – Phase 2 Amendments 
Effective November 1, 2020, we early adopted the IASB’s IBOR Phase 2 amendments to IFRS 9 Financial Instruments (IFRS 9), IAS 39 Financial 
Instruments: Recognition and Measurement (IAS 39), IFRS 7 Financial Instruments: Disclosures (IFRS 7) and IFRS 4 Insurance Contracts, as well as 
IFRS 16 Leases. These amendments address issues that arise from implementation of IBOR reform, where IBORs will be replaced with alternative 
benchmark rates. 

For financial instruments at amortized cost, the amendments introduce a practical expedient such that if a change in the contractual cash flows is 

as a direct consequence of IBOR reform and occurs on an economically equivalent basis, the change will be accounted for by updating the effective 
interest rate with no immediate gain or loss recognized. The amendments also provide additional temporary relief from applying specific IAS 39 
hedge accounting requirements to hedging relationships affected by IBOR reform. For example, there is an exemption from the requirement to 
discontinue hedge accounting when changes to hedge documentation are solely the result of IBOR reform. 

152  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
With the cessation dates for London Interbank Offered Rate (LIBOR) determined and the transition from IBORs to alternative reference rates 
(ARRs) well underway, and as both a holder and an issuer of IBOR-based instruments, BMO is exposed to increased financial, operational, legal and 
regulatory, and reputational risks. Additionally, other IBORs may be subject to discontinuance, changes in methodology, increased volatility or 
decreased liquidity. These risks arise principally from updating systems and processes to capture new ARRs, amending contracts or existing fallback 
clauses for new ARRs, managing the client transition to ARRs and the resulting impact on economic risk management, as well as updating hedge 
designations as the new ARRs emerge. In order to manage those risks, an enterprise IBOR Transition Office (ITO) has been established to coordinate 
and oversee the transition from IBORs to ARRs, with a focus on managing and mitigating internal risks, as well as managing our client relationships. 
The ITO, sponsored and supported by senior management, is responsible for running the enterprise-wide program, covering all of BMO’s lines of 
business and corporate areas. The ITO has a global mandate to ensure that we properly prepare for the discontinuation or unavailability of LIBOR and 
other IBORs. As part of its mandate, the ITO continues to address the bank’s industry and regulatory engagement, client and financial contract 
changes, internal and external communications, technology and operations modifications, introduction of new products, migration of existing clients, 
program strategy and governance, and to evaluate financial reporting impacts, including impacts on hedge accounting. In addition, the ITO continues 
to monitor the development and usage of ARRs across the industry, including the Alternative Reference Rate Committee’s formal recommendation of 
the CME Group’s forward-looking Secured Overnight Financing Rate (SOFR) Term Rates. As the market continues to develop, we have added and will 
continue to add ARR-based products to our suite of offerings. 

We adhered to the International Swaps and Derivatives Association Fallbacks Protocol (ISDA Protocol), which took effect on January 25, 2021. 
The ISDA Protocol provides specific fallbacks depending on whether the relevant IBOR (for example, USD LIBOR or GBP LIBOR) has been permanently 
discontinued or is temporarily unavailable. It provides an efficient amendment mechanism that allows mutually adhering counterparties to 
incorporate these fallback provisions into legacy derivative contracts. Also, we continue to incorporate contractual fallback provisions in new 
IBOR-based cash products in order to ensure there is an alternative benchmark rate at the time of the relevant IBOR cessation. 

The table below presents quantitative information for financial instruments that referenced certain IBORs as at November 1, 2020, the date of 
adoption for Phase 2 relief, and either were due to mature after December 31, 2021 or are demand facilities that will be subject to remediation to 
amend the benchmark interest rate. Financial instruments that reference rates in multi-rate jurisdictions, including the Canadian Dollar Offered Rate 
(CDOR), the EURO Interbank Offered Rate and Australian Bank Bill Swap Rate, are excluded from both tables below. In the case of CDOR, financial 
instruments indexed to 6-month and 12-month CDOR tenors were discontinued on May 17, 2021, while other tenors of CDOR will continue as a 
benchmark rate. As at November 1, 2020, we did not hold any material positions in either of these CDOR tenors. 

(Canadian $ in millions) 

Non-derivative assets (2) 
Non-derivative liabilities (2) 
Derivative notional amounts (3)(4) 
Authorized and committed loan commitments (5)(6) 

USD LIBOR 

GBP LIBOR 

100,521 
7,435 
1,570,534 
68,449 

868 
692 
20,972 
194 

November 1, 2020 

Other (1) 

1,225 
– 
6,702 
23,633 

(1)  Includes CHF LIBOR, EONIA and JPY LIBOR. 
(2)  All amounts are presented based on contractual amounts outstanding with the exception of securities, recorded in non-derivative assets, which are presented based on carrying value. 
(3)  Notionals amounts represent the amount to which a rate or price is applied in order to calculate the amount of cash that must be exchanged under the contract. Notional amounts do not represent 

assets or liabilities and therefore are not recorded in our Consolidated Balance Sheet. 

(4)  Includes certain cross-currency swap positions where both the pay and receive legs currently reference an IBOR. For those derivatives, the table above includes the notional amounts for both the pay 

and receive legs in the relevant columns aligning with the IBOR exposure. 

(5)  Excludes personal lines of credit and credit cards that are unconditionally cancellable at our discretion. A large majority of these commitments expire without being drawn upon. As a result, the total 

contractual amounts may not be representative of the funding likely to be required for these commitments. 

(6)  Other includes loan commitments where our customers have the option to draw from their facility in multiple currencies. Amounts drawn will be subject to prevailing IBORs for the foreign currency, 

including those that are in scope of IBOR reform. 

On March 5, 2021, the Financial Conduct Authority (FCA) confirmed that LIBOR settings will cease to be provided by any administrator 

immediately after December 31, 2021 for all sterling, euro, Swiss franc and Japanese yen settings as well as the 1-week and 2-month USD LIBOR 
settings. The remaining USD LIBOR settings will cease to be provided immediately after June 30, 2023. U.S. prudential regulators have issued 
supervisory guidance that the extension of these certain USD LIBOR settings to June 30, 2023 applies only to legacy contracts; new issuances of 
LIBOR-based instruments must cease by December 31, 2021. The ITO adjusted all impacted project plans to align with these extended timelines. 
As a result of the extension of the cessation date for certain USD LIBOR settings, more contracts will expire prior to cessation and therefore the 
number and value of contracts that will be subject to remediation efforts have been reduced. 

On November 16, 2021, the FCA confirmed that it will allow the temporary use of synthetic sterling and yen LIBOR rates in all legacy LIBOR 
contracts, excluding cleared derivatives, that have not been changed before December 31, 2021. We are still in the process of remediating our 
contracts but do not expect any material exposure to synthetic LIBOR rates at this time. 

N
o
t
e
s

BMO Financial Group 204th Annual Report 2021  153 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

The following table presents quantitative information for financial instruments that referenced certain IBORs as at October 31, 2021, which were 
either due to mature after June 30, 2023 for USD LIBOR settings other than 1-week and 2-month US LIBOR, or after December 31, 2021 for all other 
in-scope IBORs, or are demand facilities with no maturity date. Changes in our exposures during fiscal 2021 did not result in significant changes to the 
risks arising from transition since adoption of these Phase 2 amendments. In the normal course of business, our exposures may continue to fluctuate 
with no significant impact expected on our IBOR conversion plans. 

(Canadian $ in millions) 

Non-derivative assets (2) 
Non-derivative liabilities (2) 
Derivative notional amounts (3)(4) 
Authorized and committed loan commitments (5)(6)(7) 

USD LIBOR 

GBP LIBOR 

91,991 
3,043 
1,340,121 
62,174 

730 
678 
28,385 
241 

October 31, 2021 

Other (1) 

844 
– 
4,898 
15,047 

(1)  Includes CHF LIBOR, EONIA and JPY LIBOR. 
(2)  All amounts are presented based on contractual amounts outstanding with the exception of securities, recorded in non-derivative assets, which are presented based on carrying value. 
(3)  Notional amounts represent the amount to which a rate or price is applied in order to calculate the amount of cash that must be exchanged under the contract. Notional amounts do not represent 

assets or liabilities and therefore are not recorded in our Consolidated Balance Sheet. 

(4)  Includes certain cross-currency swap positions where both the pay and receive legs currently reference an IBOR. For those derivatives, the table above includes the notional amounts for both the pay 

and receive legs in the relevant columns aligning with the IBOR exposure. 

(5)  Excludes personal lines of credit and credit cards that are unconditionally cancellable at our discretion. A large majority of these commitments expire without being drawn upon. As a result, the total 

contractual amounts may not be representative of the funding likely to be required for these commitments. 

(6)  Other includes loan commitments where our customers have the option to draw from their facility in multiple currencies. Amounts drawn will be subject to prevailing IBORs for the foreign currency, 

including those that are in scope of IBOR reform. 

(7)  Commitments also include backstop liquidity facilities provided by the bank to external parties. 

Conceptual Framework 
Effective November 1, 2020, we adopted the revised Conceptual Framework (Framework), which sets out the fundamental concepts for financial 
reporting to ensure consistency in standard-setting decisions and that similar transactions are treated in a similar way, so as to provide useful 
information to users of financial statements. The revised Framework had no impact on our accounting policies. 

Leases 
Effective November 1, 2019, we adopted IFRS 16 Leases (IFRS 16), whereby lessees are required to recognize a liability for the present value of future 
lease payments and record a corresponding asset on the balance sheet for most leases. There were minimal changes to the accounting from the 
lessor’s perspective. 

The main impact for the bank is that leases related to real estate are now recorded on the balance sheet. Previously, most of our real estate 
leases were classified as operating leases, and we recorded the lease expense over the lease term with no asset or liability recorded on the balance 
sheet other than related leasehold improvements. 

On transition, we calculated the right-of-use asset as if we had always applied IFRS 16 for a selection of leases; for the remaining leases, we set 

the right-of-use asset equal to the lease liability. We will continue to record lease expense for low dollar value leases over the lease term with no 
corresponding right-of-use asset or lease liability. In addition, we combined lease and non-lease components (for example maintenance and utilities 
that have fixed payments) in the calculation of right-of-use assets and lease liabilities when applicable. We elected to exclude intangibles from the 
scope of lease accounting. 

On transition, we recognized the cumulative effect of adopting IFRS 16 in opening retained earnings as at November 1, 2019 with no changes to 

prior periods. The impact to the Consolidated Balance Sheet as at November 1, 2019 was an increase in premises and equipment of $1,965 million, 
an increase in other liabilities of $2,024 million, and a decrease in retained earnings of $80 million ($59 million after tax). 

The following table sets out a reconciliation of our operating lease commitments as disclosed under IAS 17 Leases as at October 31, 2019, which 

were used to derive the lease liabilities as at November 1, 2019. 

(Canadian $ in millions) 

Operating lease commitments at October 31, 2019 as disclosed in our consolidated financial statements 
Discounted using the incremental borrowing rate at November 1, 2019 
Finance lease liabilities recognized as at October 31, 2019 
Exemption for low-value asset leases 
Extension and termination options reasonably certain to be exercised 
Executory costs not included in the lease liability 
Leases signed but not yet started 

Lease liabilities recognized at November 1, 2019 

November 1, 2019 

3,800 
(310) 
41 
(13) 
37 
(166) 
(1,222) 

2,167 

When measuring lease liabilities, we discounted lease payments using our incremental borrowing rate at November 1, 2019. The weighted-

average rate applied was 2.52%. 

Uncertainty Over Income Tax Treatments 
Effective November 1, 2019, we adopted IFRIC 23 Uncertainty Over Income Tax Treatments. The interpretation clarifies the recognition and 
measurement requirements in IAS 12 Income Taxes when there is uncertainty over income tax treatments. The interpretation had no impact on our 
financial results on adoption. 

s
e
t
o
N

Revenue 
Effective November 1, 2018, we adopted IFRS 15 Revenue from Contracts with Customers (IFRS 15). We elected to retrospectively present prior 
periods as if IFRS 15 had always been applied. Under IFRS 15, the primary impact is the reclassification of amounts within the Consolidated Statement 
of Income. As a result, loyalty rewards and cash promotion costs on cards previously recorded in non-interest expense are presented as a reduction in 
non-interest revenue. In addition, when customers reimburse us for certain out-of-pocket expenses incurred on their behalf, we now record the 

154  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
reimbursement in non-interest revenue. Previously, these reimbursements were recorded as a reduction in the related expense. There is minimal 
impact to net income as IFRS 15 does not require discounting of loyalty reward liabilities and we now amortize the costs to obtain card customers, 
which were previously expensed as incurred. 

Use of Estimates and Judgments 
The preparation of the consolidated financial statements requires management to use estimates and assumptions that affect the carrying amounts 
of certain assets and liabilities, certain amounts reported in net income and other related disclosures. 

The most significant assets and liabilities for which we must make estimates and judgments include the allowance for credit losses; financial 
instruments measured at fair value; pension and other employee future benefits; impairment of securities; income taxes and deferred tax assets; 
goodwill and intangible assets; insurance-related liabilities; provisions, including legal proceedings and restructuring charges; transfers of financial 
assets and consolidation of structured entities; and leases. We make judgments in assessing the business model for financial assets as well as 
whether substantially all risks and rewards have been transferred in respect of transfers of financial assets and whether we control SEs, as discussed 
in Notes 6 and 7, respectively. If actual results were to differ from the estimates, the impact would be recorded in future periods. 

The extent of the continuing impact of the COVID-19 pandemic on the Canadian and U.S. economies remains uncertain and difficult to predict, 
including government and regulatory responses to the pandemic, which could vary by country and region. The pandemic’s impact on BMO’s business, 
results of operations, reputation, financial performance and condition, including the potential for credit, counterparty and mark-to-market losses, its 
credit ratings and regulatory capital and liquidity ratios, as well as impacts to its customers and competitors, will depend on future developments, 
which remain uncertain. By their very nature, the judgments and estimates we make for the purposes of preparing our financial statements relate to 
matters that are inherently uncertain. However, we have detailed policies and internal controls that are intended to ensure that these judgments and 
estimates are well controlled and independently reviewed, and that our policies are consistently applied from period to period. We believe that our 
estimates of the value of our assets and liabilities are appropriate as at October 31, 2021. 

Allowance for Credit Losses 
The expected credit loss (ECL) model requires the recognition of credit losses generally based on 12 months of expected losses for performing loans 
and the recognition of lifetime losses on performing loans that have experienced a significant increase in credit risk since origination. 

The determination of a significant increase in credit risk takes into account many different factors and varies by product and risk segment. 
The bank’s methodology for determining significant increase in credit risk is based on the change in probability of default (PD) between origination 
and reporting date, assessed using probability-weighted scenarios as well as certain other criteria, such as 30-day past due and watchlist status. 
The assessment of a significant increase in credit risk requires experienced credit judgment. 

In determining whether there has been a significant increase in credit risk and in calculating the amount of expected credit losses, we must 

rely on estimates and exercise judgment regarding matters for which the ultimate outcome is unknown. These judgments include changes in 
circumstances that may cause future assessments of credit risk to be materially different from current assessments, which could require an increase 
or decrease in the allowance for credit losses. The calculation of expected credit losses includes the explicit incorporation of forecasts of future 
economic conditions. We have developed models incorporating specific macroeconomic variables that are relevant to each portfolio. Key economic 
variables for our retail portfolios include primary operating markets of Canada, the United States (U.S.) and regional markets where considered 
significant. Forecasts are developed internally by our Economics group, considering external data and our view of future economic conditions. We 
exercise experienced credit judgment to incorporate multiple economic forecasts which are probability-weighted in the determination of the final 
expected credit loss. The allowance is sensitive to changes in both economic forecasts and the probability weight assigned to each forecast scenario. 

Additional information regarding the allowance for credit losses is included in Note 4. 

Financial Instruments Measured at Fair Value 
Fair value measurement techniques are used to value various financial assets and financial liabilities, and are also used in performing impairment 
testing on certain non-financial assets. 

Additional information regarding our fair value measurement techniques is included in Note 17. 

Pension and Other Employee Future Benefits 
Our pension and other employee future benefit expense is calculated by our independent actuaries using assumptions determined by management. 
If actual experience were to differ from the assumptions used, we would recognize this difference in other comprehensive income. 

Pension and other employee future benefit expense, plan assets and defined benefit obligations are also sensitive to changes in discount rates. 
We determine discount rates for all of our plans using high-quality AA rated corporate bond yields with terms matching the plans’ specific cash flows. 

Additional information regarding our accounting for pension and other employee future benefits is included in Note 21. 

Impairment of Securities 
We review investments in associates and joint ventures at each quarter-end reporting period to identify and evaluate investments that show 
indications of possible impairment. For these equity securities, a significant or prolonged decline in the fair value of a security below its cost is 
objective evidence of impairment. 

Debt securities measured at amortized cost or FVOCI are assessed for impairment using the expected credit loss model. For securities determined 

to have low credit risk, the allowance for credit losses is measured at a 12-month expected credit loss. 

Additional information regarding our accounting for debt securities measured at amortized cost or FVOCI and investments in associates and joint 

ventures, allowance for credit losses and the determination of fair value is included in Notes 3 and 17. 

N
o
t
e
s

Income Taxes and Deferred Tax Assets 
The provision for income taxes is calculated based on the expected tax treatment of transactions recorded in either our Consolidated Statement of 
Income or Consolidated Statement of Changes in Equity. In determining the provision for income taxes, we interpret tax legislation, case law and 
administrative positions in numerous jurisdictions and, based on our judgment, record our estimate of the amount required to settle tax obligations. 
We also make assumptions about the expected timing of the reversal of deferred tax assets and liabilities. If our interpretations and assumptions 

BMO Financial Group 204th Annual Report 2021  155 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

differ from those of tax authorities or if the timing of reversals is not as expected, our provision for income taxes could increase or decrease in future 
periods. The amount of any such increase or decrease cannot be reasonably estimated. 

Deferred tax assets are recognized only when it is probable that sufficient taxable profit will be available in future periods against which 
deductible temporary differences or unused tax losses and tax credits may be utilized. We are required to assess whether it is probable that our 
deferred tax assets will be realized. The factors used to assess the probability of realization are our past experience of income and capital gains, our 
forecast of future net income before taxes, and the remaining expiration period of tax loss carryforwards and tax credits. Changes in our assessment 
of these factors could increase or decrease our provision for income taxes in future periods. 

Additional information regarding our accounting for income taxes is included in Note 22. 

Goodwill and Intangible Assets 
For the purpose of impairment testing, goodwill is allocated to our groups of cash-generating units (CGUs), which represent the lowest level within 
the bank at which goodwill is monitored for internal management purposes. Impairment testing is performed at least annually, by comparing the 
carrying values and the recoverable amounts of the CGUs to which goodwill has been allocated to determine whether the recoverable amount of 
each group is greater than its carrying value. If the carrying value of the group were to exceed its recoverable amount, an impairment calculation 
would be performed. The recoverable amount of a CGU is the higher of its fair value less costs to sell and value in use. 

In determining fair value less costs to sell, we employ a discounted cash flow model consistent with those used when we acquire businesses. 

This model is dependent on assumptions related to revenue growth, discount rates, synergies achieved on acquisition and the availability of 
comparable acquisition data. Changes in any of these assumptions would affect the determination of fair value for each of the business units in a 
different manner. Management must exercise judgment and make assumptions in determining fair value less costs to sell, and differences in 
judgment and assumptions could affect the determination of fair value and any resulting impairment write-down. 

Intangible assets with a definite life are amortized to income on either a straight-line or an accelerated basis over a period not exceeding 
15 years, depending on the nature of the asset. We test definite-life intangible assets for impairment when circumstances indicate the carrying value 
may not be recoverable. Indefinite-life intangible assets are tested annually for impairment. If any intangible assets are determined to be impaired, 
we write them down to their recoverable amount, the higher of value in use and fair value less costs to sell, when this is less than the carrying value. 

Additional information regarding goodwill and intangible assets is included in Note 11. 

Insurance-Related Liabilities 
Insurance claims and policy benefit liabilities represent current claims and estimates of future insurance policy benefit liabilities. Liabilities for life 
insurance contracts are determined using the Canadian Asset Liability Method, which incorporates best-estimate assumptions for mortality, morbidity, 
policy lapses, surrenders, future investment yields, policy dividends, administration costs and margins for adverse deviation. These assumptions are 
reviewed at least annually and updated to reflect actual experience and market conditions. The most significant impact on the valuation of a liability 
would result from a change in the assumption for future investment yields. 

Additional information regarding insurance-related liabilities is included in Note 14. 

Provisions 
A provision, including for legal proceedings and restructuring charges, is recognized if, as a result of a past event, the bank has a present legal or 
constructive obligation that can be estimated reliably, and it is probable that an outflow of economic benefits will be required to settle the obligation. 
Provisions are recorded at the best estimate of the amounts required to settle the obligation as at the balance sheet date, taking into account the 
risks and uncertainties associated with the obligation. Management and external experts are involved in estimating any provision, as necessary. 
The actual costs of settling some obligations may be substantially higher or lower than the amounts of the provisions. 

Additional information regarding provisions is included in Note 24. 

Transfer of Assets and Consolidation of Structured Entities 
We enter into transactions in which we transfer assets, typically mortgage loans, mortgage-backed securities, and credit card loans, to a structured 
entity or third party to obtain alternate sources of funding or as part of our trading activities. We assess whether substantially all of the risks and 
rewards of or control over the assets have been transferred to determine if they qualify for derecognition. Where we continue to be exposed to 
substantially all of the repayment, interest rate and/or credit risk associated with the securitized assets, they do not qualify for derecognition. 
We continue to recognize the assets and the related cash proceeds as secured financings in our Consolidated Balance Sheet. 

For securitization vehicles sponsored by the bank, the vehicles typically have limited decision-making authority. The structure of these vehicles 
limits the activities they can undertake, the types of assets they can hold and the funding of their activities. We control and consolidate these vehicles 
when we have the key decision-making powers necessary to obtain the majority of the benefits from their activities. 

For certain investments in limited partnerships, we exercise judgment in determining whether we control an entity. Based on an assessment of 
our interests and rights, we have determined that we do not control certain entities, even though we may have an ownership interest greater than 
50%. This may be the case when we are not the general partner in an arrangement and the general partner’s rights most significantly affect the 
returns of the entity. Additionally, we have determined that we control certain entities despite having an ownership interest of less than 50%. 
This may be the case when we are the general partner in an arrangement and the general partner’s rights most significantly affect the returns 
of the entity. 

Transferred assets are discussed in greater detail in Note 6 and structured entities are discussed in greater detail in Notes 7 and 20. 

Leases 
We enter into leases as a lessee for which we recognize a lease liability and a corresponding right-of-use asset. In calculating our lease liability and 
corresponding right-of-use asset, we assess whether a contract is a lease by determining if we have the right to control the asset based on our ability 
to make decisions or direct how and for what purpose the asset is used. We evaluate the lease term based on the terms of the lease contract, 
including any extension or termination options that we are reasonably certain to exercise based on the economic rationale underlying the decision. 
We make estimates in determining the incremental borrowing rate that is used to discount lease liabilities, based on our expected costs of secured 
borrowing for the lease term. 

156  BMO Financial Group 204th Annual Report 2021 

s
e
t
o
N

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Future Changes in IFRS 
Insurance Contracts 
In June 2020, the IASB issued amendments to IFRS 17 Insurance Contracts (IFRS 17), which included a deferral of the effective date, resulting in a new 
adoption date for the bank of November 1, 2023 instead of November 1, 2022. The amendments also simplify some requirements, such as excluding 
certain credit cards from the scope of IFRS 17 and providing a policy choice to exclude certain loan contracts from IFRS 17, allowing us to continue 
accounting for them as we do today. We continue to assess the impact of the standard on our future financial results. 

Note 2: Cash and Interest Bearing Deposits with Banks 
Cash and Cash Equivalents 

(Canadian $ in millions) 

Cash and deposits with banks (1) 
Cheques and other items in transit, net 

Total cash and cash equivalents 

2021 

91,377 
1,884 

93,261 

2020 

55,926 
1,482 

57,408 

(1)  Includes deposits with the Bank of Canada, the U.S. Federal Reserve and other central banks. 

Cheques and Other Items in Transit, Net 
Cheques and other items in transit are recorded at cost and represent the net position of the uncleared cheques and other items in transit between us 
and other banks. 

Cash Restrictions 
Certain of our foreign operations are required to maintain reserves or minimum balances with central banks in their respective countries of operation, 
totalling $110 million as at October 31, 2021 ($111 million as at October 31, 2020). 

Interest Bearing Deposits with Banks 
Deposits with banks are recorded at amortized cost and include acceptances we have purchased that were issued by other banks. Interest income 
earned on these deposits is recorded on an accrual basis. 

Note 3: Securities 
Securities are divided into six types, each with a different purpose and accounting treatment. The types of securities we hold are as follows: 

Trading securities are securities purchased for resale over a short period of time. Trading securities are recorded at fair value through profit or loss. 
Transaction costs and changes in fair value are recorded in our Consolidated Statement of Income in trading revenues. 

Fair value through profit or loss securities are measured at fair value, with changes in fair value and related transaction costs recorded in our 
Consolidated Statement of Income in securities gains, other than trading, except as noted below. This category includes the following: 

Securities Designated at FVTPL 
In order to qualify for this designation, the security must have a reliably measurable fair value, and the designation eliminates or significantly reduces 
the inconsistent treatment that would otherwise arise from measuring the gains and losses on a different basis. Securities must be designated on 
initial recognition, and the designation is irrevocable. If these securities were not designated at FVTPL, they would be accounted for at either FVOC I or 
amortized cost. 

We designate certain securities held by our insurance subsidiaries that support our insurance liabilities at fair value through profit or loss, since 
the actuarial calculation of insurance liabilities is based on the fair value of the investments supporting them. This designation aligns the accounting 
result with the way the portfolio is managed on a fair value basis. The change in fair value of the securities is recorded in non-interest revenue, 
insurance revenue, and the change in fair value of the liabilities is recorded in insurance claims, commissions and changes in policy benefit liabilities. 
The fair value of these investments of $11,172 million as at October 31, 2021 ($11,148 million as at October 31, 2020) is recorded in securities in our 
Consolidated Balance Sheet. The impact of recording these investments at fair value through profit or loss was a decrease of $202 million in 
non-interest revenue, insurance revenue, for the year ended October 31, 2021 (an increase of $281 million and an increase of $1,006 million in 2020 
and 2019, respectively). 

Securities Mandatorily Measured at FVTPL 
Securities managed on a fair value basis, but not held for trading, or debt securities with cash flows that do not represent solely payments of 
principal and interest and equity securities not held for trading or designated at FVOCI are classified as FVTPL. The fair value of these investments 
of $3,038 million as at October 31, 2021 ($2,420 million as at October 31, 2020) is recorded in securities in our Consolidated Balance Sheet. 

Debt securities at FVOCI are debt securities purchased with the objective of both collecting contractual cash flows and selling the securities. 
The securities’ cash flows represent solely payments of principal and interest. These securities may be sold in response to or in anticipation of changes 
in interest rates and any resulting prepayment risk, changes in credit risk, changes in foreign currency risk or changes in funding sources or terms, or 
in order to meet liquidity needs. 

N
o
t
e
s

BMO Financial Group 204th Annual Report 2021  157 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

Debt securities measured at FVOCI are initially recorded at fair value plus transaction costs. They are subsequently measured at fair value, with 

unrealized gains and losses recorded in our Consolidated Statement of Comprehensive Income until the security is sold or impaired. Gains and losses 
on disposal and impairment losses (recoveries) are recorded in our Consolidated Statement of Income in non-interest revenue, securities gains, other 
than trading. Interest income earned is recorded in our Consolidated Statement of Income in interest, dividend and fee income, securities, using the 
effective interest method. 

Equity securities at FVOCI are equity securities for which we have elected to record changes in the fair value of the instrument in other 
comprehensive income as opposed to fair value through profit or loss. Gains or losses recorded on these instruments will never be recognized in 
profit or loss. Equity securities measured at FVOCI are not subject to an impairment assessment. 

Debt securities at amortized cost are debt securities purchased with the objective of collecting contractual cash flows, and those cash flows 
represent solely payments of principal and interest. These securities are initially recorded at fair value plus transaction costs and are subsequently 
measured at amortized cost using the effective interest method. Impairment losses (recoveries) are recorded in our Consolidated Statement of 
Income in non-interest revenue, securities gains, other than trading. Interest income earned and amortization of premiums, discounts and transaction 
costs are recorded in our Consolidated Statement of Income in interest, dividend and fee income, securities. 

Investments in associates and joint ventures are accounted for using the equity method of accounting. Investments in associates are those in 
which we exert significant influence over operating and financing decisions; generally companies in which we own between 20% and 50% of the 
voting shares. Investments in joint ventures are where we have joint control. Our share of the net income or loss, including any impairment losses, 
is recorded in non-interest revenue, investments in associates and joint ventures in our Consolidated Statement of Income. Any other comprehensive 
income amounts are reflected in the relevant sections of our Consolidated Statement of Comprehensive Income. 

We account for all of our securities transactions using settlement date accounting in our Consolidated Balance Sheet. Changes in fair value between 
the trade date and settlement date are recorded in net income, except for those related to securities measured at FVOCI, which are recorded in other 
comprehensive income. 

Impairment Review 
Debt securities at amortized cost or FVOCI are assessed for impairment using the ECL model, with the exception of those determined to have low 
credit risk, where the allowance for credit losses is measured at a 12-month expected credit loss. A debt security is considered to have low credit risk 
if it has a low risk of default, the borrower has a strong capacity to meet its contractual cash flow obligations in the near term and adverse changes in 
economic and business conditions in the longer term may, but will not necessarily, reduce the ability of the borrower to fulfill its contractual cash flow 
obligations. 

Debt securities at amortized cost totalling $49,970 million as at October 31, 2021 ($48,466 million as at October 31, 2020) are net of allowances 

for credit losses of $2 million as at October 31, 2021 ($1 million as at October 31, 2020). 

Debt securities at FVOCI totalling $62,991 million as at October 31, 2021 ($73,314 million as at October 31, 2020) are net of allowances for credit 

losses of $2 million as at October 31, 2021 ($4 million as at October 31, 2020). 

Fair Value Measurement 
For traded securities, quoted market value is considered to be fair value. Quoted market value is based on bid or ask prices, depending on which 
is the most appropriate to measure fair value. Where market quotes are not available, we use estimation techniques to determine fair value. 
Additional information regarding fair value measurement techniques is included in Note 17. 

s
e
t
o
N

158  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Remaining Term to Maturity of Securities 
The following table shows the remaining term to maturities of securities. 

(Canadian $ in millions, except as noted) 

Term to maturity 

Within 1 
year 

1 to 3
years 

3 to 5
years 

5 to 10
years 

Over 10
years

No 
maturity 

Trading Securities 
Issued or guaranteed by: 

Canadian federal government 
Canadian provincial and municipal governments 
U.S. federal government 
U.S. states, municipalities and agencies 
Other governments 

NHA MBS, U.S. agency MBS and CMO (1) 
Corporate debt 
Trading loans 
Corporate equity 
Total trading securities 
FVTPL Securities 
Issued or guaranteed by: 

Canadian federal government 
Canadian provincial and municipal governments 
U.S. federal government 
Other governments 

NHA MBS, U.S. agency MBS and CMO (1) 
Corporate debt 
Corporate equity 
Total FVTPL securities 
FVOCI Securities 
Issued or guaranteed by: 

Canadian federal government 

Canadian provincial and municipal governments 

U.S. federal government 

U.S. states, municipalities and agencies 

Amortized cost 
Fair value 
Yield (%) 

Amortized cost 
Fair value 
Yield (%) 

Amortized cost 
Fair value 
Yield (%) 

Amortized cost 
Fair value 
Yield (%) 

Other governments 
Amortized cost 
Fair value 
Yield (%) 
NHA MBS (1) 

Amortized cost 
Fair value 
Yield (%) 

Amortized cost 
Fair value 
Yield (%) 
Corporate debt 

Amortized cost 
Fair value 
Yield (%) 
Corporate equity 

Cost 
Fair value 

U.S. agency MBS and CMO (1) 

Total cost or amortized cost 
Total fair value 
Yield (%) 
Amortized Cost Securities 
Issued or guaranteed by: 

Canadian federal government 

Amortized cost 
Fair value 

Amortized cost 
Fair value 

U.S. federal government 

Amortized cost 
Fair value 

Other governments 
Amortized cost 
Fair value 

Canadian provincial and municipal governments 

NHA MBS, U.S. agency MBS and CMO (1) 

Amortized cost 
Fair value 
Corporate debt 

Amortized cost 
Fair value 
Total amortized cost 
Total fair value 
Investments in associates and joint ventures 
Carrying value 
Total carrying value or amortized cost of securities 
Total carrying value of securities 
Total by Currency (in Canadian $ equivalent) 
Canadian dollar 
U.S. dollar 
Other currencies 
Total securities 

1,292 
894 
1,733 
259 
525 
23 
1,940 
– 
– 

6,666 

679 
– 
38
– 
– 
226 
– 

943 

4,073 
4,073 
1.40 

1,329 
1,334 
1.02 

997 
1,008 
2.16 

635 
640 
2.06 

2,807 
2,814 
0.89 

87 
87 
1.18 

43 
44 
2.28 

1,231 
1,234 
0.85 

– 
–

11,202 

11,234 

1.27 

277 
283 

527 
539 

851 
857 

375 
388 

90 
93 

256 
257 

2,376 

2,417 

– 

21,187 

21,219 

10,341 
9,034 
1,844 

21,219 

2,039 
843 
3,620 
24 
520 
140 
1,955 
87
– 

9,228 

28 
47 
 – 
66
– 
67 
– 

208 

4,714 
4,740 
1.71 

1,168 
1,189 
1.82 

1,458 
1,477 
1.94 

1,144 
1,171 
2.05 

2,406 
2,443 
1.48 

411 
415 
1.74 

135 
139 
2.56 

683 
706 
2.26 

– 
 –

12,119 

12,280 

1.78 

4,781 
4,799 

1,644 
1,654 

2,278 
2,261 

689 
690 

740 
752 

603 
608 

10,735 

10,764 

– 

32,290 

32,451 

15,845 
16,268 
338 

32,451 

1,669 
583 
1,849 
11 
534 
183 
2,245 
 35
– 

7,109 

– 
5 
– 
 26
– 
310 
– 

341 

4,175 
4,131 
1.29 

166 
163 
1.28 

3,817 
3,951 
2.08 

784 
806 
2.08 

735 
728 
0.93 

603 
602 
0.88 

527 
555 
3.04 

907 
901 
1.04 

– 
 –

11,714 

11,837 

1.62 

1,966 
1,981 

2,230 
2,304 

1,613 
1,576 

283 
278 

2,665 
2,657 

588 
591 

9,345 

9,387 

– 

28,509 

28,632 

13,510 
14,775 
347 

28,632 

1,603 
701 
1,803 
106 
247 
243 
2,695 
 38
– 

7,436 

10 
84 
– 
 – 
9 
969 
– 

1,072 

75 
73 
1.10 

300 
291 
1.95 

12,827 
12,652 
1.12 

707 
724 
2.03 

528 
517 
1.85 

– 
– 
– 

2,040 
2,082 
1.66 

268 
264 
2.14 

– 
 –

16,745 

16,603 

1.28 

60 
57 

1,241 
1,226 

891 
895 

66 
64 

4,031 
4,044 

145 
146 

6,434 

6,432 

– 

31,687 

31,545 

6,225 
25,034 
286 

31,545 

993 
2,817 
577 
58 
72 
13,465 
1,059 
  – 
– 

19,041 

146 
1,244 
– 
– 
– 
6,132 
– 

7,522 

50 
48 
1.60 

10 
10 
2.75 

1,942 
1,938 
1.95 

764 
773 
1.28 

– 
– 
– 

21 
21 
1.56 

8,149 
8,191 
0.96 

58 
56 
3.35 

– 
 –

10,994 

11,037 

1.18 

– 
– 

– 
– 

– 
– 

– 
– 

21,031 
20,761 

49 
49 

21,080 

20,810 

– 

58,637 

58,680 

12,351 
46,207 
122 

58,680 

2021 

Total 

7,596 
5,838 
9,582 
458 
1,898 
14,054 
9,894 
160
54,931 

104,411 

863 
1,380 
38
92
9 
7,704 
4,124 

14,210 

13,087 
13,065 
1.48 

2,973 
2,987 
1.45 

21,041 
21,026 
1.48 

4,034 
4,114 
1.91 

6,476 
6,502 
1.19 

1,122 
1,125 
1.23 

10,894 
11,011 
1.22 

3,147 
3,161 
1.37 

 103
 132

62,877 

63,123 

1.42 

7,084 
7,120 

5,642 
5,723 

5,633 
5,589 

1,413 
1,420 

28,557 
28,307 

1,641 
1,651 

49,970 

49,810 

2020 

Total 

10,900 
8,335 
8,418 
503 
2,516 
12,297 
11,041 
67 
43,757 
97,834 

601 
1,429 
44 
94 
3 
7,897 
3,500 
13,568 

22,240 
22,450 
1.44 

4,628 
4,747 
1.46 

16,881 
17,694 
1.73 

5,132 
5,276 
1.96 

7,222 
7,381 
1.63 

1,583 
1,629 
1.79 

10,600 
10,903 
1.62 

3,153 
3,234 
1.72 

90  
93  
71,529 
73,407 
1.61 

6,238 
6,260 

5,650 
5,706 

8,785 
8,805 

1,480 
1,485 

24,769 
25,198 

1,544 
1,555 
48,466 
49,009 

– 
– 
– 
– 
– 
– 
– 
– 
54,931 

54,931 

– 
– 
– 
– 
– 
– 
4,124 

4,124 

– 
– 
– 

– 
– 
– 

– 
– 
– 

– 
– 
– 

– 
– 
– 

– 
– 
– 

– 
– 
– 

– 
– 
– 

103
 132

103 

132 

– 

– 
– 

– 
– 

– 
– 

– 
– 

– 
– 

– 
– 

– 

– 

1,135 

60,293 

60,322 

27,661 
29,104 
3,557 

60,322 

1,135 

232,603 

232,849 

85,933 
140,422 
6,494 

232,849 

985 
232,382 
234,260 

100,544 
125,795 
7,921 
234,260 

N
o
t
e
s

(1)  These amounts are supported by insured mortgages or issued by U.S. agencies and government-sponsored enterprises. NHA refers to the National Housing Act, MBS refers to mortgage-backed 

securities and CMO refers to collateralized mortgage obligations. 

Yields in the table above are calculated using the cost of the security and the contractual interest rate associated with each security, adjusted for any amortization of premiums and discounts. Tax effects 
are not taken into consideration. The term to maturity included in the table above is based on the contractual maturity date of the security. Actual maturities could differ, as issuers may have the right to 
call or prepay obligations. 

BMO Financial Group 204th Annual Report 2021  159 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

Unrealized Gains and Losses on FVOCI Securities 
The following table summarizes unrealized gains and losses: 

(Canadian $ in millions) 

Cost or 
amortized 
cost 

Gross 
unrealized 
gains 

Gross 
unrealized 
losses 

Issued or guaranteed by: 

Canadian federal government 
Canadian provincial and municipal governments 
U.S. federal government 
U.S. states, municipalities and agencies 
Other governments 

NHA MBS 
U.S. agency MBS and CMO 
Corporate debt 
Corporate equity 

Total 

13,087 
2,973 
21,041 
4,034 
6,476 
1,122 
10,894 
3,147 
103 

62,877 

62 
29 
282 
85 
55 
6 
151 
34 
29 

733 

2021 

Fair 
value 

13,065 
2,987 
21,026 
4,114 
6,502 
1,125 
11,011 
3,161 
132 

Cost or 
amortized 
cost 

Gross 
unrealized 
gains 

Gross 
unrealized 
losses 

22,240 
4,628 
16,881 
5,132 
7,222 
1,583 
10,600 
3,153 
90 

71,529 

211 
119 
844 
147 
168 
46 
307 
91 
3 

1,936 

1 
– 
31 
3 
9 
– 
4 
10 
– 

58 

2020 

Fair 
value 

22,450 
4,747 
17,694 
5,276 
7,381 
1,629 
10,903 
3,234 
93 

73,407 

84 
15 
297 
5 
29 
3 
34 
20 
– 

487 

63,123 

Unrealized gains (losses) may be offset by related (losses) gains on hedge contracts. 

Interest, Dividend and Fee Income 
Interest, dividend and fee income has been included in our Consolidated Statement of Income as follows, excluding investments in associates and 
joint ventures and trading securities. Related income for trading securities is included under Trading-Related Revenue in Note 17. 

(Canadian $ in millions) 

FVTPL 
FVOCI 
Amortized cost 

Total 

2021 

22 
470 
419 

911 

2020 

17 
959 
573 

1,549 

2019 

34 
1,585 
268 

1,887 

Non-Interest Revenue 
Net gains and losses from securities, excluding gains and losses on trading securities, have been included in our Consolidated Statement of Income as 
follows: 

(Canadian $ in millions) 

FVTPL securities 
FVOCI securities (1) 

Gross realized gains 
Gross realized (losses) 

Impairment losses 

Securities gains, other than trading (2) 

2021 

535 

170 
(113) 
(1) 

591 

2020 

30 

109 
(13) 
(2) 

124 

2019 

164 

209 
(123) 
(1) 

249 

(1)  Gains (losses) are net of (losses) gains on hedge contracts. 
(2)  The following amounts of income related to our insurance operations were included in non-interest revenue, insurance revenue, in our Consolidated Statement of Income: Interest, dividend and fee 
income of $379 million, $416 million and $407 million for the years ended October 31, 2021, 2020 and 2019, respectively; securities gains, other than trading, from FVOCI securities of $1 million, 
$19 million and $11 million for the years ended October 31, 2021, 2020 and 2019, respectively; and securities gains (losses), other than trading, from securities designated at FVTPL of $(202) million, 
$281 million and $1,006 million for the years ended October 31, 2021, 2020 and 2019, respectively. 

Gains and losses on trading securities are included in trading-related revenue in Note 17. 

Note 4: Loans and Allowance for Credit Losses 
Loans 
Loans are initially measured at fair value plus directly attributable costs, and are subsequently measured at amortized cost using the effective interest 
method where the cash flows of those loans represent solely payments of principal and interest, otherwise those loans are measured at FVTPL. 
Where the loans are held with the objective of both collecting contractual cash flows and selling the loans, and the cash flows represent solely 
payments of principal and interest, these loans are measured at FVOCI. The effective interest method allocates interest income over the expected 
term of the loan by applying the effective interest rate to the carrying amount of the loan. The effective interest rate is defined as the rate that 
exactly discounts estimated future cash receipts through the expected term of the loan to the net carrying amount of the loan. Under the effective 
interest method, the amount recognized in interest, dividend and fee income, loans, varies over the term of the loan based on the principal 
outstanding. The treatment of interest income for impaired loans is described below. 

s
e
t
o
N

Securities Borrowed or Purchased Under Resale Agreements 
Securities borrowed or purchased under resale agreements represent the amounts we will receive as a result of our commitment to return or resell 
securities that we have borrowed or purchased, back to the original lender or seller, on a specified date at a specified price. We account for these 
instruments as if they were loans. 

160  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Lending Fees 
Lending fees primarily arise in Personal and Commercial Banking and BMO Capital Markets. The accounting treatment for lending fees varies depending 
on the transaction. Some loan origination, restructuring and renegotiation fees are recorded as interest income over the term of the loan, while other 
lending fees are taken into income at the time of loan origination. Commitment fees are calculated as a percentage of the facility balance at the end of 
each period. The fees are recorded as interest income over the term of the loan, unless we believe the loan commitment will not be used. In the latter 
case, commitment fees are recorded as lending fees earned over the commitment period. Loan syndication fees are payable and included in lending 
fees at the time the syndication is completed, unless the yield on any loans we retain is less than that of other comparable lenders involved in the 
financing. In the latter case, an appropriate portion of the syndication fee is recorded as interest income over the term of the loan. 

Impaired Loans 
We classify a loan as impaired (Stage 3) when one or more loss events have occurred, such as bankruptcy, payment default or when collection of the 
full amount of principal and interest is no longer reasonably assured. Generally, consumer loans in both Canada and the U.S. are classified as impaired 
when payment is contractually 90 days past due, or one year past due for residential mortgages if guaranteed by the Government of Canada. Credit 
card loans are immediately written off when principal or interest payments are 180 days past due, and are not reported as impaired. In Canada, 
consumer instalment loans, other personal loans and some small business loans are normally written off when they are one year past due. In the 
U.S., all consumer loans are generally written off when they are 180 days past due, except for non-real estate term loans, which are generally written 
off when they are 120 days past due. For the purpose of measuring the amount to be written off, the determination of the recoverable amount 
includes an estimate of future recoveries. 

Corporate and commercial loans are classified as impaired when we determine there is no longer reasonable assurance that principal or interest 

will be collected in their entirety on a timely basis. Generally, we consider corporate and commercial loans to be impaired when payments are 
90 days past due. Corporate and commercial loans are written off following a review on an individual loan basis that confirms all reasonable recovery 
attempts have been exhausted. 

A loan will be reclassified to performing status when we determine that there is reasonable assurance of full and timely repayment of interest 
and principal in accordance with the terms and conditions of the loan, and that none of the criteria for classification of the loan as impaired continues 
to apply. 

Loans are in default when the borrower is unlikely to pay its credit obligations in full without recourse by the bank, such as realizing security, or 

when the borrower’s payments are more than 90 days past due (180 days for credit card loans). Overdrafts are considered to be past due once the 
customer has breached an advised limit or has been advised of a limit lower than currently outstanding or, in the case of retail overdrafts, has not 
brought the overdraft down to a $nil balance within a specified time period. 

Once a loan is identified as impaired, we continue to recognize interest income based on the original effective interest rate on the loan amount 
net of its related allowance. In the periods following the recognition of impairment, adjustments to the allowance for these loans reflecting the time 
value of money are recognized as interest income. Interest income on impaired loans of $71 million was recognized for the year ended October 31, 
2021 ($96 million in 2020 and $80 million in 2019). 

During the year ended October 31, 2021, we recorded a net loss of $10 million before tax (loss of $46 million in 2020 and gain of $11 million in 

2019) on the sale of impaired and written off loans. 

Allowance for Credit Losses (ACL) 
The allowance for credit losses recorded in our Consolidated Balance Sheet is maintained at a level that we consider adequate to absorb credit-related 
losses on our loans and other credit instruments. The allowance for credit losses amounted to $2,958 million as at October 31, 2021 ($3,814 million in 
2020), of which $2,564 million ($3,303 million in 2020) was recorded in loans and $394 million ($511 million in 2020) was recorded in other 
liabilities in our Consolidated Balance Sheet. 

Significant changes in the gross balances, including originations, maturities and repayments in the normal course of operations, impact the 

allowance for credit losses. 

Allowance on Performing Loans 
We maintain an allowance in order to cover impairment in the existing portfolio for loans that have not yet been individually identified as impaired. 
Our approach to establishing and maintaining the allowance on performing loans is based on the requirements of IFRS, considering guidelines issued 
by OSFI. 

Under the IFRS 9 ECL methodology, an allowance is recorded for expected credit losses on financial assets regardless of whether there has 

been an actual impairment. We recognize a loss allowance at an amount generally equal to 12-month expected credit losses, if the credit risk at 
the reporting date has not increased significantly since initial recognition (Stage 1). We will record expected credit losses over the remaining life 
of performing financial assets which are considered to have experienced a significant increase in credit risk (Stage 2). 

The determination of a significant increase in credit risk takes into account many different factors and varies by product and risk segment. 
The bank’s methodology for determining significant increase in credit risk is based on the change in probability of default (PD) between origination 
and reporting date, assessed using probability-weighted scenarios as well as certain other criteria, such as 30-days past due and watchlist status. 
For each exposure, ECL is a function of PD, exposure at default (EAD) and loss given default (LGD), with the timing of the loss also considered, 
and is estimated by incorporating forward-looking economic information and through the use of experienced credit judgment to reflect factors not 
captured in ECL models. 

PD represents the likelihood that a loan will not be repaid and will go into default in either a 12-month horizon for Stage 1 or a lifetime horizon 

for Stage 2. PD for each individual instrument is modelled based on historical data and is estimated based on current market conditions and 
reasonable and supportable information about future economic conditions. 

EAD is modelled based on historical data and represents an estimate of the amount of credit exposure outstanding at the time a default may 

occur. For off-balance sheet and undrawn amounts, EAD includes an estimate of any further amounts to be drawn at the time of default. 

LGD is the amount that may not be recovered in the event of default and is modelled based on historical data and reasonable and supportable 

information about future economic conditions, where appropriate. LGD takes into consideration the amount and quality of any collateral held. 

BMO Financial Group 204th Annual Report 2021  161 

N
o
t
e
s

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

We consider past events, current market conditions and reasonable supportable forward-looking information about future economic conditions 

in determining the amount of expected losses. In assessing information about possible future economic conditions, we utilize multiple economic 
scenarios, including our base case scenario, which in our view represents the most probable outcome, as well as benign and adverse scenarios, all 
of which are developed by our Economics group. Key economic variables used in the determination of the allowance for credit losses reflect the 
geographic diversity of our portfolios, where appropriate. 

In considering the lifetime of a loan, the contractual period of the loan, including prepayment, extension and other options, is generally used. 

For revolving instruments, such as credit cards, which may not have a defined contractual period, the lifetime is based on historical behaviour. 

Our ECL methodology also requires the use of experienced credit judgment to incorporate the estimated impact of factors that are not captured in 

the modelled ECL results. We applied experienced credit judgment to reflect the continuing impact of the uncertain environment on credit conditions 
and the economy as a result of the COVID-19 pandemic. 

Allowance on Impaired Loans 
We maintain an allowance on individually identified impaired loans (Stage 3) of $498 million as at October 31, 2021 ($727 million as at October 31, 
2020) on our gross impaired loans of $2,169 million as at October 31, 2021 ($3,638 million as at October 31, 2020), to reduce their carrying value to 
an expected recoverable amount of $1,671 million as at October 31, 2021 ($2,911 million as at October 31, 2020). 

We review our loans on an ongoing basis to assess whether any loans should be classified as impaired and whether an allowance or write-off 

should be recorded (excluding credit card loans, which are written off when principal or interest payments are 180 days past due). The review of 
individually significant problem loans is conducted at least quarterly by the account managers, each of whom assesses the ultimate collectability and 
estimated recoveries for a specific loan based on all events and conditions that are relevant to the loan. This assessment is then reviewed and 
approved by an independent credit officer. 

Individually Significant Impaired Loans 
To determine the amount we expect to recover from an individually significant impaired loan, we use the value of the estimated future cash flows 
discounted at the loan’s original effective interest rate. The determination of estimated future cash flows of a collateralized impaired loan reflects the 
expected realization of the underlying security, net of expected costs and any amounts legally required to be paid to the borrower. Security can vary 
by type of loan and may include cash, securities, real estate properties, accounts receivable, guarantees, inventory or other capital assets. 

Individually Insignificant Impaired Loans 
Residential mortgages and consumer instalment and other personal loans are individually insignificant and may be assessed individually or 
collectively for losses at the time of impairment, taking into account historical loss experience and expectations of future economic conditions. 
Collectively assessed loans are grouped together by similar risk characteristics, such as type of instrument, geographic location, industry, type of 
collateral and term to maturity. 

s
e
t
o
N

162  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Loans: Credit Risk Exposure 
The following table sets out our credit risk exposure for all loans carried at amortized cost, FVOCI or FVTPL as at October 31, 2021 and 2020. 
Stage 1 represents those performing loans carried with up to a 12-month expected credit loss, Stage 2 represents those performing loans carried with 
a lifetime expected credit loss, and Stage 3 represents those loans with a lifetime expected credit loss that are credit impaired. 

(Canadian $ in millions) 

Loans: Residential mortgages 
Exceptionally low 
Very low 
Low 
Medium 
High 
Not rated 
Impaired 

Gross residential mortgages 

Allowance for credit losses 

Carrying amount 

Loans: Consumer instalment and other personal 
Exceptionally low 
Very low 
Low 
Medium 
High 
Not rated 
Impaired 

Gross consumer instalment and other personal 

Allowance for credit losses 

Carrying amount 

Loans: Credit cards (1) 
Exceptionally low 
Very low 
Low 
Medium 
High 
Not rated 
Impaired 

Gross credit cards 

Allowance for credit losses 

Carrying amount 

Loans: Business and government (2) 
Acceptable 

Investment grade 
Sub-investment grade 

Watchlist 
Impaired 

Gross business and government 

Allowance for credit losses 

Carrying amount 

Gross total loans and acceptances 

Net total loans and acceptances 

Commitments and financial guarantee contracts 
Acceptable 

Investment grade 
Sub-investment grade 

Watchlist 
Impaired 

Allowance for credit losses 

Carrying amount (3)(4) 

Stage 1 

Stage 2 

Stage 3 

Stage 1 

Stage 2 

Stage 3 

2021 

Total 

4 
94,745 
24,764 
14,316 
473 
1,097 
351 

– 
– 
– 
– 
– 
– 
351 

1 
79,295 
24,490 
11,560 
172 
1,132 
– 

351 

135,750 

116,650 

12 

97 

51 

– 
429 
2,481 
6,461 
446 
148 
– 

9,965 

75 

4 
94,566 
23,471 
12,066 
167 
1,051 
– 

131,325 

46 

– 
179 
1,293 
2,250 
306 
46 
– 

4,074 

39 

131,279 

4,035 

339 

135,653 

116,599 

9,890 

1,487 
30,672 
21,660 
13,336 
661 
3,450 
– 

71,266 

113 

37 
8 
534 
3,607 
1,375 
50 
– 

5,611 

333 

– 
– 
– 
– 
– 
– 
287 

287 

91 

1,524 
30,680 
22,194 
16,943 
2,036 
3,500 
287 

77,164 

537 

1,550 
26,645 
20,935 
10,324 
429 
3,372 
– 

63,255 

134 

71,153 

5,278 

196 

76,627 

63,121 

2,532 
450 
1,801 
1,743 
75 
486 
– 

7,087 

67 

7,020 

– 
– 
66 
663 
287 
– 
– 

1,016 

209 

807 

– 
– 
– 
– 
– 
– 
– 

– 

– 

– 

2,532 
450 
1,867 
2,406 
362 
486 
– 

8,103 

276 

7,827 

2,252 
1,106 
899 
1,611 
58 
524 
– 

6,450 

61 

6,389 

144,807 
85,375 
– 
– 

1,446 
14,534 
6,137 
– 

– 
– 
– 
1,531 

146,253 
99,909 
6,137 
1,531 

230,182 

22,117 

1,531 

253,830 

529 

730 

395 

1,654 

229,653 

21,387 

1,136 

252,176 

439,860 

32,818 

2,169 

474,847 

439,105 

31,507 

1,671 

472,283 

125,216 
88,745 
– 
– 

213,961 

510 

213,451 

400,316 

399,560 

154,975 
46,827 
– 
– 

195 

2,367 
8,164 
2,453 
– 

186 

– 
– 
– 
682 

13 

157,342 
54,991 
2,453 
682 

139,732 
44,443 
– 
– 

394 

211 

31 
37 
585 
4,334 
1,470 
96 
– 

6,553 

429 

6,124 

– 
15 
148 
899 
377 
– 
– 

1,439 

272 

1,167 

3,576 
30,108 
8,621 
– 

42,305 

1,044 

41,261 

60,262 

58,442 

1,935 
20,421 
4,861 
– 

288 

2020 

Total 

1 
79,724 
26,971 
18,021 
618 
1,280 
409 

127,024 

142 

126,882 

1,581 
26,682 
21,520 
14,658 
1,899 
3,468 
340 

70,148 

668 

69,480 

2,252 
1,121 
1,047 
2,510 
435 
524 
– 

7,889 

333 

7,556 

128,792 
118,853 
8,621 
2,889 

259,155 

2,160 

256,995 

464,216 

460,913 

141,667 
64,864 
4,861 
1,261 

511 

– 
– 
– 
– 
– 
– 
409 

409 

16 

393 

– 
– 
– 
– 
– 
– 
340 

340 

105 

235 

– 
– 
– 
– 
– 
– 
– 

– 

– 

– 

– 
– 
– 
2,889 

2,889 

606 

2,283 

3,638 

2,911 

– 
– 
– 
1,261 

12 

201,607 

12,798 

669 

215,074 

183,964 

26,929 

1,249 

212,142 

(1)  Credit card loans are immediately written off when principal or interest payments are 180 days past due, and as a result are not reported as impaired in Stage 3. 
(2)  Includes customers’ liability under acceptances. 
(3)  Represents the total contractual amounts of undrawn credit facilities and other off-balance sheet exposures, excluding personal lines of credit and credit cards that are unconditionally cancellable at 

our discretion. 

(4)  Certain commercial borrower commitments are conditional and may include recourse to parties. 

Certain comparative figures have been reclassified to conform with the current year’s presentation. 

BMO Financial Group 204th Annual Report 2021  163 

N
o
t
e
s

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

The following table shows the continuity in the loss allowance, by product type, for the years ended October 31, 2021 and 2020. Transfers represent 
the amount of ECL that moved between stages during the year, for example, moving from a 12-month (Stage 1) to a lifetime (Stage 2) ECL 
measurement basis. Net remeasurements represent the ECL impact due to transfers between stages, as well as changes in economic forecasts and 
credit quality. Model changes include new calculation models or methodologies. 

(Canadian $ in millions) 

Loans: Residential mortgages 

Balance as at beginning of year 
Transfer to Stage 1 
Transfer to Stage 2 
Transfer to Stage 3 
Net remeasurement of loss allowance 
Loan originations 
Derecognitions and maturities 
Model changes 

Total Provision for Credit Losses (PCL) (1) 
Write-offs (2) 
Recoveries of previous write-offs 
Foreign exchange and other 

Balance as at end of year 

Loans: Consumer instalment and other personal 

Balance as at beginning of year 
Transfer to Stage 1 
Transfer to Stage 2 
Transfer to Stage 3 
Net remeasurement of loss allowance 
Loan originations 
Derecognitions and maturities 
Model changes 

Total PCL (1) 
Write-offs (2) 
Recoveries of previous write-offs 
Foreign exchange and other 

Balance as at end of year 

Loans: Credit cards 

Balance as at beginning of year 
Transfer to Stage 1 
Transfer to Stage 2 
Transfer to Stage 3 
Net remeasurement of loss allowance 
Loan originations 
Derecognitions and maturities 
Model changes 

Total PCL (1) 
Write-offs (2) 
Recoveries of previous write-offs 
Foreign exchange and other 

Balance as at end of year 

Loans: Business and government 
Balance as at beginning of year 
Transfer to Stage 1 
Transfer to Stage 2 
Transfer to Stage 3 
Net remeasurement of loss allowance 
Loan originations 
Derecognitions and maturities 
Model changes 

Total PCL (1) 
Write-offs (2) 
Recoveries of previous write-offs 
Foreign exchange and other 

Balance as at end of year 

Total as at end of year 

Comprised of: Loans 

Other credit instruments (3) 

s
e
t
o
N

Stage 1 

Stage 2 

Stage 3 

51 
62 
(4) 
– 
(93) 
38 
(7) 
– 

(4) 
– 
– 
(1) 

46 

148 
297 
(30) 
(7) 
(289) 
86 
(27) 
(48) 

(18) 
– 
– 
(2) 

128 

110 
194 
(28) 
(1) 
(191) 
39 
(7) 
– 

6 
– 
– 
(2) 

114 

658 
505 
(101) 
(2) 
(549) 
329 
(140) 
(5) 

37 
– 
– 
(33) 

662 

950 

755 
195 

75 
(53) 
21 
(13) 
24 
– 
(12) 
– 

(33) 
– 
– 
(2) 

40 

454 
(287) 
66 
(94) 
247 
– 
(49) 
26 

(91) 
– 
– 
(6) 

357 

321 
(194) 
28 
(172) 
292 
– 
(29) 
– 

(75) 
– 
– 
(1) 

245 

1,258 
(496) 
172 
(97) 
334 
– 
(214) 
(19) 

(320) 
– 
– 
(83) 

855 

1,497 

1,311 
186 

26 
(9) 
(17) 
13 
29 
– 
– 
– 

16 
(12) 
11 
(22) 

19 

105 
(10) 
(36) 
101 
103 
– 
– 
– 

158 
(236) 
86 
(22) 

91 

– 
– 
– 
173 
21 
– 
– 
– 

194 
(266) 
94 
(22) 

– 

608 
(9) 
(71) 
99 
138 
– 
– 
– 

157 
(336) 
42 
(70) 

401 

511 

498 
13 

2021 

Total 

152 
– 
– 
– 
(40) 
38 
(19) 
– 

(21) 
(12) 
11 
(25) 

105 

707 
– 
– 
– 
61 
86 
(76) 
(22) 

49 
(236) 
86 
(30) 

576 

431 
– 
– 
– 
122 
39 
(36) 
– 

125 
(266) 
94 
(25) 

359 

2,524 
– 
– 
– 
(77) 
329 
(354) 
(24) 

(126) 
(336) 
42 
(186) 

1,918 

2,958 

2,564 
394 

Stage 1 

Stage 2 

Stage 3 

15 
25 
(3) 
– 
6
14–
(3) 
(3) 

36 
– 
– 
– 

51 

89 
189 
(25) 
(4) 
(148) 
49
(18) 
16 

59 
– 
– 
– 

148 

80 
152 
(32) 
(1) 
(100) 
18–
(6) 
(1) 

30 
– 
– 
– 

110 

338 
180 
(184) 
(8) 
227 
208 
(85) 
(30) 

308 
– 
– 
12 

658 

967 

756 
211 

33 
(22) 
10 
(5) 
 70

(6) 
(5) 

42 
– 
– 
– 

75 

333 
(180) 
86 
(96) 
315 
 – 
(38) 
33 

120 
– 
– 
1 

454 

225 
(152) 
32 
(178) 
429 

(25) 
(10) 

96 
– 
– 
– 

321 

496 
(172) 
195 
(285) 
1,106 
– 
(128) 
8 

724 
– 
– 
38 

1,258 

2,108 

1,820 
288 

38 
(3) 
(7) 
5 
 2298
 –
– 
– 

17 
(11) 
8 
(26) 

26 

136 
(9) 
(61) 
100 
196 
– 
– 
– 

226 
(320) 
87 
(24) 

105 

– 
– 
– 
179 
82 
 – 
– 
– 

261 
(333) 
85 
(13) 

– 

311 
(8) 
(11) 
293 
744 
– 
– 
– 

1,018 
(716) 
72 
(77) 

608 

739 

727 
12 

2020 

Total 

86 
– 
– 
– 

14
(9) 
(8) 

95 
(11) 
8 
(26) 

152 

558 
– 
– 
– 
363 
49 
(56) 
49 

405 
(320) 
87 
(23) 

707 

305 
– 
– 
– 
411 
18 
(31) 
(11) 

387 
(333) 
85 
(13) 

431 

1,145 
– 
– 
– 
2,077 
208 
(213) 
(22) 

2,050 
(716) 
72 
(27) 

2,524 

3,814 

3,303 
511 

(1)  Excludes PCL on other assets of $(7) million for the year ended October 31, 2021 ($16 million in 2020). 
(2)  Generally, we continue to seek recovery on amounts that were written off during the year, unless the loan is sold, we no longer have the right to collect or we have exhausted all reasonable efforts 

to collect. 

(3)  Other credit instruments, including off-balance sheet items, are recorded in other liabilities in our Consolidated Balance Sheet. 

164  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Loans and allowance for credit losses by geographic region as at October 31, 2021 and 2020 are as follows: 

(Canadian $ in millions) 

2021 

Gross 
amount 

Allowance for 
credit losses on 
impaired loans (2) 

Allowance for 
credit losses on 
performing loans (3) 

Net 
amount 

Gross 
amount 

Allowance for 
credit losses on 
impaired loans (2) 

Allowance for 
credit losses on 
performing loans (3) 

2020 

Net 
amount 

By geographic region (1): 

Canada 
United States 
Other countries 

Total 

299,905 
153,479 
7,442 

460,826 

345 
153 
– 

498 

1,143  298,417 
910  152,416 
7,429 

13 

276,975 
161,725 
12,023 

2,066  458,262 

450,723 

303 
410 
14 

727 

1,323 
1,225 
28 

275,349 
160,090 
11,981 

2,576 

447,420 

(1)  Geographic region is based upon the country of ultimate risk. 
(2)  Excludes allowance for credit losses on impaired loans of $13 million for other credit instruments, which is included in other liabilities ($12 million as at October 31, 2020). 
(3)  Excludes allowance for credit losses on performing loans of $381 million for other credit instruments, which is included in other liabilities ($499 million as at October 31, 2020).

Certain comparative figures have been reclassified to conform with the current year’s presentation. 

Impaired (Stage 3) loans, including the related allowances, as at October 31, 2021 and 2020 are as follows: 

(Canadian $ in millions) 

2021 

2020 

Residential mortgages 
Consumer instalment and other personal 
Business and government (1) 

Total 

By geographic region (2): 

Canada 
United States 
Other countries 

Total 

Gross impaired 
amount (3) 

Allowance for 
credit losses on 
impaired loans (4) 

Net impaired
amount (3)

Gross impaired 
amount (3)

Allowance for 
credit losses on 
impaired loans (4) 

Net impaired
amount (3) 

351 
287 
1,531 

2,169 

1,195 
974 
– 

2,169 

12 
91 
395 

498 

345 
153 
–

498 

339 
196 
1,136 

1,671 

850 
821 
– 

1,671 

409 
340 
2,889 

3,638 

1,343 
2,211 
84 

3,638 

16 
105 
606 

727 

303 
410 
14

727 

393 
235 
2,283 

2,911 

1,040 
1,801 
70 

2,911 

(1)  Includes customers’ liability under acceptances. 
(2)  Geographic region is based upon the country of ultimate risk. 
(3)  Gross impaired loans and net impaired loans exclude purchased credit impaired loans. 
(4)  Excludes allowance for credit losses on impaired loans of $13 million for other credit instruments, which is included in other liabilities ($12 million as at October 31, 2020). 

Loans Past Due Not Impaired 
Loans that are past due but not classified as impaired are loans where our customers have failed to make payments when contractually due but for 
which we expect the full amount of principal and interest payments to be collected, or loans which are held at fair value. The following table presents 
loans that are past due but not classified as impaired as at October 31, 2021 and 2020. Loans less than 30 days past due are excluded as they are not 
generally representative of the borrowers’ ability to meet their payment obligations. 

(Canadian $ in millions) 

Residential mortgages 
Credit card, consumer instalment and other personal 
Business and government 

Total 

30 to 89 days 

90 days or more 

30 to 89 days 

90 days or more 

2021 

Total 

418 
338 
297 

14 
59 
33 

543 
345 
330 

1,218 

404 
279 
264 

947 

2020 

Total 

586 
410 
352 

43 
65 
22 

106 

1,053 

130 

1,348 

Fully secured loans with amounts between 90 and 180 days past due that we have not classified as impaired totalled $36 million and $53 million as at October 31, 2021 and 2020, respectively. 

ECL Sensitivity and Key Economic Variables 
The allowance for performing loans is sensitive to changes in both economic forecasts and the probability-weight assigned to each forecast scenario. 
Many of the factors have a high degree of interdependency, although there is no single factor to which loan impairment allowances as a whole are 
sensitive. 

As at October 31, 2021, our base case scenario depicts a stronger economic forecast in both Canada and the United States compared to the base 

case economic forecast as at October 31, 2020, which depicted more moderate economic growth over the near-term projection period. If we assumed 
a 100% base case economic forecast and included the impact of loan migration by restaging, with other assumptions held constant including the 
application of experienced credit judgment, the allowance for performing loans would be approximately $1,725 million as at October 31, 2021 
($2,375 million as at October 31, 2020) compared to the reported allowance for performing loans of $2,447 million ($3,075 million as at October 31, 
2020). 

As at October 31, 2021, our adverse case economic forecast depicts a contracting economy with annual average real GDP declining in both 

Canada and the United States. Despite adopting a more severe adverse scenario during fiscal 2021, the adverse case economic outlook as at 
October 31, 2020 depicted a more severe economic contraction in Canada and the United States compared with the adverse case as at October 31, 
2021 due to the improvement in economic conditions year over year. If we assumed a 100% adverse economic forecast and included the impact of 
loan migration by restaging, with other assumptions held constant including the application of experienced credit judgment, the allowance for 
performing loans would be approximately $3,825 million as at October 31, 2021 ($4,875 million as at October 31, 2020) compared to the reported 
allowance for performing loans of $2,447 million ($3,075 million as at October 31, 2020). 

N
o
t
e
s

BMO Financial Group 204th Annual Report 2021  165 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

Actual results in a recession will differ as our portfolio will change through time due to migration, growth, risk mitigation actions and other 
factors. In addition, our allowance will reflect the three economic scenarios used in assessing the allowance, with weightings attached to adverse and 
benign scenarios often unequally weighted and the weightings will change through time. 

The following table shows the key economic variables used to estimate the allowance on performing loans during the forecast period. The values 
shown represent the national annual average levels or growth rates for the next 12 months and subsequent 12 months following each reporting 
period for all scenarios. While the values disclosed below are national variables, we use regional variables in the underlying models and consider 
factors impacting particular industries where appropriate. 

As at October 31, 2021 

As at October 31, 2020 

All figures are average 
annual values 

Real GDP growth rates (1) 

Canada 
United States 

Corporate BBB 10-year 

spread 
Canada 
United States 

Unemployment rates 

Canada 
United States 
Housing Price Index 

Canada (2) 
United States (3) 

Benign scenario 

Base scenario 

Adverse scenario 

Benign scenario 

Base scenario 

Adverse scenario 

First 12 
months 

Subsequent 
12 months

First 12
months

Subsequent 
12 months 

First 12 
months 

Subsequent 
12 months 

First 12 
months 

Subsequent 
12 months 

First 12 
months 

Subsequent 
12 months 

First 12 
months 

Subsequent 
12 months 

6.3% 
7.1% 

5.5% 
4.0% 

4.0% 
4.8% 

3.9% 
2.7% 

(2.7)% 
(1.2)% 

(1.1)% 
(1.1)% 

3.7% 
1.6% 

6.4% 
6.0% 

1.8% 
(0.4)% 

4.2% 
4.0% 

(4.4)% 
(5.1)% 

(1.1)% 
(1.2)% 

1.4% 
0.9% 

6.0% 
4.2% 

1.7% 
1.1% 

4.9% 
3.2% 

1.8% 
1.2% 

6.6% 
4.7% 

2.0% 
1.5% 

3.6% 
4.2% 

4.4% 
4.5% 

5.7% 
3.7% 

10.8% 
8.5% 

12.7% 
11.0% 

1.8% 
1.7% 

7.4% 
6.4% 

18.2% 
14.6% 

10.2% 
6.7% 

15.1% 
12.3% 

5.2% 
4.3% 

(6.4)% 
(6.1)% 

(18.0)% 
(15.5)% 

10.3% 
4.6% 

1.9% 
1.7% 

6.1% 
4.8% 

7.7% 
4.5% 

2.2% 
2.0% 

8.9% 
8.0% 

7.2% 
2.4% 

2.2% 
2.0% 

7.5% 
6.0% 

3.6% 
3.9% 

4.5% 
4.1% 

12.7% 
11.5% 

13.9% 
12.8% 

2.8% 
2.1% 

(1.2)% 
(2.4)% 

(8.7)% 
(6.2)% 

(1)  Real gross domestic product (GDP) and housing price index are four quarter averages of year-over-year growth rates. 
(2)  In Canada, we use the HPI Benchmark Composite. 
(3)  In the United States, we use the National Case-Shiller House Price Index. 

The ECL approach requires the recognition of credit losses generally based on 12 months of expected losses for performing loans (Stage 1) and the 
recognition of lifetime expected losses on performing loans that have experienced a significant increase in credit risk since origination (Stage 2). 
Under our current probability-weighted scenarios, if all our performing loans were in Stage 1, our models would generate an allowance for 
performing loans of approximately $1,775 million compared to the reported allowance for performing loans of $2,447 million as at October 31, 2021 
($2,300 million compared to the reported allowance for performing loans of $3,075 million as at October 31, 2020). 

Renegotiated Loans 
From time to time we modify the contractual terms of a loan due to the poor financial condition of the borrower. We assess renegotiated loans 
for impairment consistent with our existing policies for impairment. When renegotiation leads to significant concessions being granted, and the 
concessions are for economic or legal reasons related to the borrower’s financial difficulty that we would not otherwise consider, the loan is classified 
as impaired. We consider one or a combination of the following to be significant concessions: (1) a reduction of the stated interest rate, (2) an 
extension of the maturity date or dates at a stated interest rate lower than the current market rate for a new loan with similar terms, or 
(3) forgiveness of principal or accrued interest. 

Renegotiated loans remain in performing status if the modifications are not considered to be significant or are returned to performing status 

when none of the criteria for classification as impaired continues to apply. 

The carrying value of loans with lifetime allowance for credit losses modified during the year ended October 31, 2021 was $37 million 
($8,649 million in 2020, which included modifications for COVID-19 payment deferrals of $8,485). Modified loans of $21 million ($49 million in 
2020 and $36 million in 2019) were written off during the year ended October 31, 2021. As at October 31, 2021, $29 million ($1,469 million as 
at October 31, 2020) of loans previously modified saw their loss allowance during the year change from lifetime to 12-month expected credit loss. 

Foreclosed Assets 
Property or other assets that we receive from borrowers to satisfy their loan commitments are classified as either held for own use or held for sale 
according to management’s intention, recorded initially at fair value for assets held for own use and at the lower of carrying value or fair value less 
costs to sell for any assets held for sale. Assets held for own use are subsequently accounted for in accordance with the relevant asset classification 
and assets held for sale are assessed for impairment. 

During the year ended October 31, 2021, we foreclosed on impaired loans and received $27 million of real estate properties that we classified 
as held for sale ($44 million in 2020). As at October 31, 2021, real estate properties held for sale totalled $11 million ($27 million as at October 31, 
2020). These properties are disposed of when considered appropriate. 

s
e
t
o
N

Collateral 
Collateral is used to manage credit risk related to securities borrowed or purchased under resale agreements, residential mortgages, consumer 
instalment and other personal loans, and business and government loans. Additional information on our collateral requirements is included in Notes 
14 and 24, as well as in the blue-tinted font in the Enterprise-Wide Risk Management section of Management’s Discussion and Analysis within this 
report. 

166  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Note 5: Risk Management 
We have an enterprise-wide approach to the identification, measurement, monitoring and control of risks faced across our organization. 
The key risks related to our financial instruments are classified as credit and counterparty, market, and liquidity and funding risk. The COVID-19 
pandemic continues to impact certain risks as outlined in the Enterprise Wide Risk Management section of our Management’s Discussion and Analysis 
and where those risks are related to financial instruments, they have been included in the blue-tinted font as referenced below. 

Credit and Counterparty Risk 
Credit and counterparty risk is the potential for loss due to the failure of a borrower, endorser, guarantor or counterparty to repay a loan or honour 
another predetermined financial obligation. Credit risk arises predominantly with respect to loans, over-the-counter and centrally cleared derivatives 
and other credit instruments. This is the most significant measurable risk that we face. 

Our risk management practices and key measures are disclosed in the blue-tinted font in the Enterprise-Wide Risk Management section of 
Management’s Discussion and Analysis within this report. Additional information on credit risk related to loans and derivatives is included in Note s 4 
and 8, respectively. 

Market Risk 
Market risk is the potential for adverse changes in the value of our assets and liabilities resulting from changes in market variables such as interest 
rates, credit spreads, foreign exchange rates, equity and commodity prices and their implied volatilities, and includes the risk of credit migration and 
default in our trading book. We incur market risk in our trading and underwriting activities, as well as in our structural banking activities. 

Our market risk management practices and key measures are disclosed in the blue-tinted font in the Enterprise-Wide Risk Management section 

of Management’s Discussion and Analysis within this report. 

Liquidity and Funding Risk 
Liquidity and funding risk is the potential for loss if we are unable to meet our financial commitments in a timely manner at reasonable prices as 
they become due. It is our policy to ensure that sufficient liquid assets and funding capacity are available to meet financial commitments, including 
liabilities to depositors and suppliers, as well as lending, investment and pledging commitments, even in times of stress. Managing liquidity and 
funding risk is essential to maintaining enterprise soundness and safety, depositor confidence and earnings stability. 

Our liquidity and funding risk management practices and key measures are disclosed in the blue-tinted font in the Enterprise-Wide Risk 

Management section of Management’s Discussion and Analysis within this report. 

Note 6: Transfers of Financial Assets 
Loan Securitization 
We sell Canadian residential mortgages to third-party Canadian securitization programs, including the Canada Mortgage Bond program, directly to 
third-party investors under the National Housing Act Mortgage-Backed Securities (NHA MBS) program and under our own program. In 2020, we also 
participated in the Government of Canada’s Insured Mortgage Purchase Program, launched as part of its response to COVID-19. We assess whether 
substantially all of the risks and rewards of or control over the loans have been transferred to determine whether they qualify for derecognition. 
Under these programs, we are entitled to the payment over time of the excess of the sum of interest and fees collected from customers, in 
connection with the mortgages that were sold, over the yield paid to investors, less credit losses and other costs. We also act as counterparty in 
interest rate swap agreements where we pay the interest due to Canada Mortgage Bond holders and receive the interest on the underlying 
mortgages, which are converted into MBS through the NHA MBS program and sold to Canada Housing Trust. Since we continue to be exposed to 
substantially all the prepayment, interest rate and credit risk associated with the securitized mortgages, they do not qualify for derecognition. 
We continue to recognize the mortgages and the related cash proceeds as secured financing in our Consolidated Balance Sheet. The interest 
and fees collected, net of the yield paid to investors, are recorded in net interest income using the effective interest method over the term of the 
securitization. Credit losses associated with the mortgages are recorded in the provision for credit losses. During the year ended October 31, 2021, 
we sold $7,614 million of mortgages to these programs ($6,644 million in 2020). 

The following table presents the carrying amounts and fair values of transferred assets that did not qualify for derecognition and the associated 
liabilities: 

(Canadian $ in millions) 

Assets 

Trading securities (2) 
Residential mortgages 
Other related assets (3) 

Total 

Associated liabilities (4) 

Carrying amount (1) 

Fair value 

Carrying amount (1) 

Fair value 

2021 

2020 

997 
7,847 
10,009 

18,853 

18,208 

18,859 

18,323 

345
8,453
10,363

19,161 

18,617 

19,357 

19,213 

(1)  Carrying amount of loans is net of allowance, where applicable. 
(2)  Trading securities represent collateralized mortgage obligations issued by third-party sponsored vehicles, where we do not substantially transfer all the risks and rewards of ownership to third-party 

investors. 

(3)  Other related assets represent payments received on account of mortgages pledged under securitization programs that have not yet been applied against the associated liabilities. The payments 

received are held in permitted instruments on behalf of the investors in the securitization vehicles until principal payments are required to be made on the associated liabilities. In order to compare 
all assets supporting the associated liabilities, this amount is added to the carrying amount of the securitized assets in the table above. 

(4)  Associated liabilities are recognized in Securitization and structured entities’ liabilities in our Consolidated Balance Sheet. 

N
o
t
e
s

Continuing Involvement in Transferred Financial Assets that Qualify for Derecognition 
We retain the mortgage servicing rights, representing our continuing involvement, for certain mortgage loans purchased or originated in the U.S. 
which are sold and derecognized. During the year ended October 31, 2021, we sold and derecognized $631 million of these loans ($720 million in 

BMO Financial Group 204th Annual Report 2021  167 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

2020 and $460 million in 2019) and recognized a $32 million gain ($33 million in 2020 and $15 million in 2019) in non-interest revenue, other. 
As at October 31, 2021, the carrying value of the mortgage servicing rights was $29 million ($29 million as at October 31, 2020) and the fair value 
was $28 million ($30 million as at October 31, 2020). 

We retain the residual interests, representing our continuing involvement, for certain commercial mortgage loans purchased or originated in the 
U.S. which are sold and derecognized. During the year ended October 31, 2021, we sold and derecognized $1,252 million of these loans ($56 million 
in 2020 and $nil in 2019) and recognized a gain of $3 million upon transfer ($nil in 2020 and $nil in 2019). The carrying values of our retained 
interests classified as debt securities at amortized cost and loans were $7 million and $7 million, respectively, as at October 31, 2021 ($2 million and 
$nil as at October 31, 2020). Fair value was equal to carrying value on these dates. 

In addition, we hold U.S. government agency collateralized mortgage obligations (CMOs) issued by third-party sponsored vehicles, which we may 

further securitize by packaging them into new CMOs prior to selling to third-party investors. Where we do not substantially transfer all the risks and 
rewards of ownership to third-party investors, we continue to recognize these CMOs and the related cash proceeds as secured financing in our 
Consolidated Balance Sheet. During the year, we sold CMOs that qualified for derecognition, where retained interests represent our continuing 
involvement and are managed as part of larger portfolios held for either trading, liquidity or hedging purposes. Where we sold these CMOs, the 
associated gains and losses are recognized in non-interest revenue, trading revenues. As at October 31, 2021, the fair value of our retained interests 
in these CMOs was $3 million, classified as trading securities in our Consolidated Balance Sheet ($28 million as at October 31, 2020). Refer to Note 3 
for further information. 

Other Transferred Financial Assets 
In the second quarter of 2020, the Canadian Government launched the Canada Emergency Business Account Program as part of its response to 
COVID-19, in which we issued loans that are funded by the government. We determined these loans qualify for derecognition, as substantially all the 
risks and rewards were transferred; therefore, we do not recognize these loans in our Consolidated Balance Sheet. 

Securities Lent or Sold Under Repurchase Agreements 
Securities lent or sold under repurchase agreements represent short-term funding transactions in which we sell securities that we own and 
simultaneously commit to repurchase the same securities at a specified price on a specified date in the future. We retain substantially all the risks and 
rewards associated with the securities and we continue to recognize them in our Consolidated Balance Sheet, with the obligation to repurchase these 
securities recorded as secured borrowing transactions at the amount owing. The carrying value of these securities approximates the carrying value of 
the associated liabilities due to their short-term nature. As at October 31, 2021, the carrying values of securities lent and securities sold under 
repurchase agreements were $9,662 million and $87,894 million, respectively ($7,696 million and $80,962 million, respectively, as at October 31, 
2021). The interest expense related to these liabilities is recorded on an accrual basis in interest expense, other liabilities, in our Consolidated 
Statement of Income. 

Note 7: Structured Entities 
We enter into certain transactions in the ordinary course of business which involve the establishment of SEs to facilitate or secure customer 
transactions and to obtain alternate sources of funding. We are required to consolidate a SE if we control the entity. We control a SE when we have 
power over the SE, exposure to variable returns as a result of our involvement, and the ability to exercise power to affect the amount of our returns. 
In assessing whether we control a SE, we consider the entire arrangement to determine the purpose and design of the SE, the nature of any 

rights held through contractual arrangements, and whether we are acting as principal or agent. 

We perform a reassessment of consolidation if facts and circumstances indicate that there have been changes to one or more of the elements of 
control over the SE. In the event such reassessment results in a loss of control, we will de-recognize the related assets (including goodwill), liabilities, 
and non-controlling interest at their carrying amounts and recognize any consideration received or retained interest at fair value with any differential 
recognized as gain or loss in our Consolidated Statement of Income. Information regarding our basis of consolidation is included in Note 1. 

Consolidated Structured Entities 
Bank Securitization Vehicles 
We use securitization vehicles to securitize our Canadian credit card loans, Canadian real estate lines of credit, Canadian auto loans and U.S. 
equipment loans in order to obtain alternate sources of funding. The structure of these vehicles limits the activities they can undertake and the types 
of assets they can hold, and the vehicles have limited decision-making authority. The vehicles issue term asset-backed securities (ABS) to fund their 
activities. We control and consolidate these vehicles, as we have the key decision-making powers necessary to obtain the majority of the benefits of 
their activities. 

The following table presents the carrying amounts and fair values of transferred assets that did not qualify for derecognition and the associated 
liabilities issued by our bank securitization vehicles: 

s
e
t
o
N

(Canadian $ in millions) 

Assets 

Credit cards 
Consumer instalment and other personal (2) 
Business and government 

Total 

Associated liabilities (3) 

Carrying amount (1) 

Fair value 

Carrying amount (1) 

Fair value 

2021 

2020 

7,106 
5,228 
250 

7,106 
5,238 
253 

6,825 
6,291 
484 

6,825 
6,312 
484 

12,584 

12,597 

13,600 

13,621 

7,278 

7,341 

8,272 

8,416 

(1)  Carrying amount of loans is net of allowance. 
(2)  Includes real estate lines of credit and auto loans. 
(3)  Associated liabilities are recognized in Securitization and structured entities’ liabilities in our Consolidated Balance Sheet. 

168  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
U.S. Customer Securitization Vehicle 
We sponsor one customer securitization vehicle, Fairway Financial Company LLC, (also referred to as a bank-sponsored multi-seller conduit) that 
provides our customers with alternate sources of funding through the securitization of their assets. This vehicle provides clients with access to financing 
in the asset-backed commercial paper (ABCP) markets by allowing them to either sell their assets directly into the vehicle or indirectly by selling an 
interest in the securitized assets into the vehicle, which then issues ABCP to investors in order to fund the purchases. The sellers remain responsibl e for 
servicing the transferred assets and are first to absorb any losses realized on those assets. We are not responsible for servicing or absorbing the first 
loss and none of the sellers are affiliated with BMO. We earn fees for providing services related to the securitizations, including liquidity, distribution and 
financial arrangement fees for supporting the ongoing operations of the vehicle. Effective October 31, 2021, we concluded we no longer control this 
vehicle and have deconsolidated our investment, as our relationship has changed from principal to agent as reflected primarily in the change to our 
exposure to variable returns. We derecognized $3,896 million of assets and $3,672 million of liabilities from our consolidated balance sheet on loss of 
control. We concurrently recognized $218 million in Securities, representing the carrying value of our interest in the vehicle, and $6 million in Other 
Assets. No gain or loss was recognized in our consolidated income statement as a result of deconsolidating this entity. 

We provide committed liquidity support facilities to this vehicle, which may require that we provide additional financing to the vehicle in the 

event that certain events occur. The total committed undrawn amount under these facilities as at October 31, 2021 was $8,095 million 
($7,340 million as at October 31, 2020). 

Our interest in this vehicle as at October 31, 2021 has been included in the Unconsolidated Structured Entities table below. 

Capital and Funding Vehicles 
We sponsor the Trust established in connection with the issuance of $1,250 million 4.3% Limited Recourse Capital Notes Series 1 (LRCN), which holds 
$1,250 million of BMO issued Non-cumulative, 5-year Rate Reset Class B Preferred Shares, Series 48 (Non-Viability Contingent Capital (NVCC)), issued 
concurrently with the LRCN. We determined that we control and therefore consolidate this vehicle as we are exposed to its variable returns and have 
key decision-making powers over its activities. Refer to Note 16 for further information. 

We have a funding vehicle, created under the covered bond program, that was established to guarantee payments due to bondholders on bonds 

issued by us. We sell assets to this funding vehicle in exchange for an intercompany loan. Refer to Note 13 for further information on our covered 
bond deposit liabilities. 

We may also use capital vehicles to transfer our credit exposure on certain loan assets. We purchase credit protection against eligible credit 
events from these vehicles. The vehicles collateralize their obligation through the issuance of guarantee-linked notes. Loan assets are not sold or 
assigned to the vehicles and remain on our Consolidated Balance Sheet. During the year, we redeemed all guaranteed linked notes issued by these 
vehicles. Consequently, as at October 31, 2021, $nil of guaranteed linked notes issued by these vehicles were included in deposits in our Consolidated 
Balance Sheet ($120 million at October 31, 2020). 

For those vehicles that purchase assets from us or are designed to pass on our credit risk, we have determined that, based on the rights of the 

arrangements or through our equity interest, we have significant exposure to the variable returns of the vehicles, and we control and therefore 
consolidate these vehicles. Additional information related to notes issued by, and assets sold to, these vehicles is provided in Notes 13 and 24, 
respectively. 

Other 
We have other consolidated structured entities, created to meet the bank’s and customers needs. Aside from the exposure resulting from our 
involvement as a sponsor, the bank does not have other contractual or non-contractual arrangements to provide financial support to these 
consolidated structured entities. 

Unconsolidated Structured Entities 
The table below presents amounts related to our interests in unconsolidated SEs: 

(Canadian $ in millions) 

2021 

2020 

Interests recorded on our Consolidated Balance Sheet 

Cash and cash equivalents 
Trading securities 
FVTPL securities 
FVOCI securities 
Amortized cost securities 
Derivatives 
Other 

Deposits 
Other 

Exposure to loss (2) 

Total assets of the entities 

Canadian and 
U.S. customer 
securitization 
vehicles (1) (3)

Capital vehicles 

Other 
securitization 
vehicles 

Canadian customer 
securitization 
vehicles (1) 

Capital vehicles

Securitization 
vehicles 

63 
24 
218 
464 
–
2 
5 

776 

63 
–

14,208 

8,116 

1,210 
– 
– 
– 
 –
– 
– 

1,210 

1,210 
 22

– 

1,234 

– 
58 
– 
– 
 93
– 
– 

151 

– 
 –

151 

5,686 

46 
75 
158 
291 
– 
22 
– 

592 

46 
– 

7,015 

5,265 

1,173 
– 
– 
– 
– 
– 
39 

1,212 

1,173 
25 

1 

1,198 

– 
72 
– 
– 
102 
– 
– 

174 

– 
– 

174 

2,560 

N
o
t
e
s

(1)  Securities held that are issued by our Canadian and U.S. customer securitization vehicles are comprised of asset-backed commercial paper and are classified as trading securities, FVTPL securities and 

FVOCI securities. 

(2)  Exposure to loss represents securities held, undrawn liquidity facilities, any remaining unfunded committed amounts to the BMO funded vehicle, derivative assets and other assets. 
(3)  Includes the U.S. customer securitization vehicle, Fairway Financial Company LLC, which was deconsolidated on a prospective basis during fiscal 2021. 

BMO Financial Group 204th Annual Report 2021  169 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

Canadian Customer Securitization Vehicles 
We sponsor customer securitization vehicles (also referred to as bank-sponsored multi-seller conduits) that provide our customers with alternate 
sources of funding through the securitization of their assets. These vehicles provide clients with access to financing either from BMO or in the ABCP 
markets by allowing them to either sell their assets directly into the vehicle or indirectly by selling an interest in the securitized assets into the 
vehicle, which then issues ABCP to either investors or BMO to fund the purchases. The sellers remain responsible for servicing the transferred assets 
and are first to absorb any losses realized on those assets. We are not responsible for servicing or absorbing the first loss and none of the sellers are 
affiliated with BMO. We earn fees for providing services related to the securitizations, including liquidity, distribution and financial arrangement fees 
for supporting the ongoing operations of the vehicles. We have determined that we do not control these entities, as their key relevant activity, the 
servicing of program assets, does not reside with us. 

We provide liquidity facilities to the market-funded vehicles, which may require that we provide additional financing to the vehicles in the event 

that certain events occur. The total committed and undrawn amount under these liquidity facilities and any undrawn amounts of the BMO funded 
vehicle as at October 31, 2021 was $5,400 million ($6,469 million as at October 31, 2020). 

Capital Vehicles 
We also use capital vehicles to pass our credit risk to security holders of the vehicles. In these situations, we are not exposed to significant default 
or credit risk. Our remaining exposure to variable returns is less than that of the note holders in these vehicles, who are exposed to our default and 
credit risk. We are not required to consolidate these vehicles. 

Other Securitization Vehicles 
Other securitization vehicles include holdings in asset-backed securitizations. Where we sponsor SEs that securitize MBS into CMOs, we may have 
interests through our holdings of CMOs but do not consolidate the SEs as we do not have power to direct their relevant activities. These include 
government-sponsored agency securities such as U.S. government agency issuances. In determining whether we are a sponsor of a SE, we consider 
both qualitative and quantitative factors, including the purpose and nature of the entity, and our initial and continuing involvement. Subsequent to 
the securitization, we sell the CMOs to third parties. Our maximum exposure to loss is limited to our on-balance sheet investments in these entities, 
included in the table above. 

Where the asset-backed instruments in these securitizations are transferred to third parties, but we retain substantially all risks and rewards 
related to the transferred assets, we continue to recognize the transferred assets with the related cash proceeds recognized as secured financing in 
our Consolidated Balance Sheet. As at October 31, 2021, these transferred assets were carried at fair value totalling $53 million ($69 million as at 
October 31, 2020) with $nil million ($nil million as at October 31, 2020) recognized in securitization and structured entities’ liabilities, also carried at 
fair value. 

Where the asset-backed instruments in these securitizations are transferred to third parties and qualify for derecognition, we record the 
related gains or losses in non-interest revenue, trading revenues. We may also retain an interest in the CMOs sold, which represents our continuing 
involvement. As at October 31, 2021, we held retained interests of $5 million ($3 million as at October 31, 2020) carried at fair value on our 
Consolidated Balance Sheet. 

During the year ended October 31, 2021, we sold $2,549 million of MBS to these sponsored securitization vehicles ($5,797 million in 2020), 

where we divested all interests in the securitized MBSs and any gains and losses were recorded in non-interest revenue, trading revenues. 

BMO Managed Funds 
We have established a number of funds that we also manage. We assess whether or not we control these funds based on the economic interest 
we have in the funds, including investments in the funds and management fees earned from the funds, and any investors’ rights to remove us as 
investment manager. We only consolidate those funds that we control. Our total interest in unconsolidated BMO managed funds was $1,345 million 
at October 31, 2021 ($1,718 million in 2020), with $321 million included in FVTPL securities and $1,024 million included in trading securities as at 
October 31, 2021 ($444 million and $1,274 million, respectively, in 2020) in our Consolidated Balance Sheet. 

Other Structured Entities 
We purchase and hold investments in a variety of third-party SEs, including exchange-traded funds, mutual funds, limited partnerships investment 
trusts and government-sponsored ABS vehicles, which are recorded in securities in our Consolidated Balance Sheet. We are considered to have an 
interest in these investments through our holdings and because we may act as a counterparty in certain derivatives contracts. We are not the 
investment manager or the sponsor of any of these investments. We are generally a passive investor and do not have power over the key decision-
making activities of these investments. Our maximum exposure to loss from our investments is limited to the carrying amounts of our investments 
and any unutilized commitment we have provided. 

Sponsored Structured Entities 
We may be deemed to be the sponsor of a SE if we are involved in its design, legal set-up or marketing. We may also be deemed to be the sponsor 
of a SE if market participants would reasonably associate the entity with us. Any interests in securitization vehicles we have sponsored are disclosed 
in the interests in unconsolidated structured entities table above. 

Financial Support Provided to Structured Entities 
During the years ended October 31, 2021 and 2020, we did not provide any financial or non-financial support to any consolidated or unconsolidated 
SEs when we were not contractually obligated to do so. Furthermore, we have no intention of providing such support in the future. 

s
e
t
o
N

170  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Note 8: Derivative Instruments 
Derivative instruments are financial contracts that derive their value from underlying changes in interest rates, foreign exchange rates or other 
financial or commodity prices or indices. 

Derivative instruments are either regulated exchange-traded contracts or negotiated over-the-counter contracts. We use these instruments for 

trading purposes, as well as to manage our exposures, mainly to foreign currency and interest rate fluctuations, as part of our asset/liability 
management program. 
Types of Derivatives 
Swaps 
Swaps are contractual agreements between two parties to exchange a series of cash flows. The various swap agreements that we enter into are 
as follows: 
•  Interest rate swaps – counterparties generally exchange fixed and floating rate interest payments based on a notional value in a single currency. 
•  Cross-currency swaps – fixed rate interest payments and principal amounts are exchanged in different currencies. 
•  Cross-currency interest rate swaps – fixed and/or floating rate interest payments and principal amounts are exchanged in different currencies.
• Commodity swaps – counterparties generally exchange fixed and floating rate payments based on a notional value of a single commodity. 
•  Equity swaps – counterparties exchange the return on an equity security or a group of equity securities for the return based on a fixed or floating 

interest rate or the return on another equity security or group of equity securities. 

•  Credit default swaps – one counterparty pays the other a fee in exchange for that other counterparty agreeing to make a payment if a credit event 

occurs, such as bankruptcy or failure to pay. 

•  Total return swaps – one counterparty agrees to pay or receive from the other cash amounts based on changes in the value of a reference asset 
or group of assets, including any returns such as interest earned on these assets, in exchange for amounts that are based on prevailing market 
funding rates. 

Forwards and Futures 
Forwards and futures are contractual agreements to either buy or sell a specified amount of a currency, commodity, interest rate-sensitive financial 
instrument or security at a specified price and date in the future. 

Forwards are customized contracts transacted in the over-the-counter market. Futures are transacted in standardized amounts on regulated 

exchanges and are subject to daily cash margining. 

Options 
Options are contractual agreements that convey to the purchaser the right but not the obligation to either buy or sell a specified amount of a 
currency, commodity, interest-rate-sensitive financial instrument or security at a fixed future date or at any time within a fixed future period. 

For options written by us, we receive a premium from the purchaser for accepting market risk. 
For options purchased by us, we pay a premium for the right to exercise the option. Since we have no obligation to exercise the option, our 

primary exposure to risk is the potential credit risk if the writer of an over-the-counter contract fails to meet the terms of the contract. 

Caps, collars and floors are specialized types of written and purchased options. They are contractual agreements in which the writer agrees to 
pay the purchaser, based on a specified notional amount, the difference between the market rate and the prescribed rate of the cap, collar or floor. 
The writer receives a premium for selling this instrument. 

A swaption is an option granting its owner the right but not the obligation to enter into an underlying swap. 
A futures option is an option contract in which the underlying instrument is a single futures contract. 

The main risks associated with these derivative instruments are related to exposure to movements in interest rates, foreign exchange rates, credit quality, 
value of the underlying financial instrument or commodity, as applicable, and the possible inability of counterparties to meet the terms of the contracts. 
Embedded Derivatives 
From time to time, we purchase or issue financial instruments containing embedded derivatives. The embedded derivative in a financial liability is 
separated from the host contract and carried at fair value if the economic characteristics of the derivative are not closely related to those of the host 
contract, the terms of the embedded derivative are the same as those of a stand-alone derivative, and the combined contract is not measured at fair 
value. To the extent that we cannot reliably identify and measure the embedded derivative, the entire contract is carried at fair value, with changes 
in fair value reflected in income. Embedded derivatives in certain of our equity linked notes are accounted for separately from the host instrument. 
Contingent Features 
Certain over-the-counter derivative instruments contain provisions that link the amount of collateral we are required to post or pay to our credit 
ratings as determined by the major credit rating agencies. If our credit ratings were to be downgraded, certain counterparties to these derivative 
instruments could demand immediate and ongoing collateralization on derivative liability positions or request immediate payment. The aggregate 
fair value of all derivative instruments with collateral posting requirements that were in a liability position as at October 31, 2021 was $4,537 million 
($6,560 million as at October 31, 2020), for which we have posted collateral of $3,921 million ($5,967 million in 2020). 
Risks Hedged 
Interest Rate Risk 
We manage interest rate risk through interest rate futures, interest rate swaps and options, which are linked to and adjust the interest rate sensitivity 
of a specific asset, liability, forecasted transaction or firm commitment, or a specific pool of transactions with similar risk characteristics. 

Foreign Currency Risk 
We manage foreign currency risk through currency futures, foreign currency options, cross-currency swaps, foreign exchange spot transactions, 
forward contracts and deposits denominated in foreign currencies. 

Equity Price Risk 
We manage equity price risk through total return swaps. 

BMO Financial Group 204th Annual Report 2021  171 

N
o
t
e
s

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

Trading Derivatives 
Trading derivatives include derivatives entered into with customers to accommodate their risk management needs, market-making to facilitate customer-
driven demand for derivatives, derivatives transacted on a limited basis to generate trading income from our principal trading positions, and certain 
derivatives that we enter into as part of our risk management strategy tha t do not qualify as hedges for accounting purposes (“economic hedges”). 
We structure and market derivative products to enable customers to transfer, modify or reduce current or expected exposure to risks. 
Principal trading activities include market-making and positioning activities. Market-making involves quoting bid and offer prices to other market 

participants with the intention of generating revenues based on spread and volume. Positioning activities involve managing market risk positions 
with the expectation of profiting from favourable movements in prices, rates or indices. 

Trading derivatives are recorded at fair value. Realized and unrealized gains and losses are generally recorded in non-interest revenue, trading 
revenues, in our Consolidated Statement of Income. Unrealized gains and losses on derivatives used to economically hedge certain exposures may be 
recorded in the Consolidated Statement of Income in the same line as the unrealized gains and losses arising from the exposures. Unrealized gains on 
trading derivatives are recorded as derivative instrument assets and unrealized losses are recorded as derivative instrument liabilities in our 
Consolidated Balance Sheet. 

We may also economically hedge a portion of our U.S. dollar earnings through forward foreign exchange contracts and/or options to minimize 
fluctuations in our consolidated net income due to the translation of our U.S. dollar earnings. These contracts are recorded at fair value, with changes 
in fair value recorded in non-interest revenue, trading revenues, in our Consolidated Statement of Income. 

Fair Value of Trading and Hedging Derivatives 
Fair value represents point-in-time estimates that may change in subsequent reporting periods due to market conditions or other factors. A discussion 
of the fair value measurement of derivatives is included in Note 17. 

Fair values of our derivative instruments are as follows: 

(Canadian $ in millions) 

Trading 
Interest Rate Contracts 
Swaps 
Forward rate agreements 
Purchased options 
Written options 
Futures 
Foreign Exchange Contracts (1) 
Cross-currency swaps 
Cross-currency interest rate swaps 
Forward foreign exchange contracts 
Purchased options 
Written options 
Commodity Contracts 
Swaps 
Purchased options 
Written options 
Futures 
Equity Contracts 
Credit Contracts 
Purchased 
Written 
Total fair value – trading derivatives 
Hedging 
Interest Rate Contracts (2) 
Cash flow hedges – swaps 
Fair value hedges – swaps 
Total swaps 
Foreign Exchange Contracts 
Cash flow hedges 
Fair value hedges 
Net investment hedges 
Total foreign exchange contracts 
Equity Contracts 
Cash flow hedges 
Total equity contracts 
Total fair value – hedging derivatives (3) 
Total fair value – trading and hedging derivatives 
Less: impact of master netting agreements 
Total 

s
e
t
o
N

Gross 
assets 

Gross
liabilities

6,132 
42 
641 
– 
– 

1,438 
8,595 
3,505 
381 
– 

5,916 
1,383 
– 
319 
5,998 

– 
– 

(4,323) 
(105) 
– 
(520) 
(3) 

(1,207) 
(5,827) 
(3,925) 
– 
(384) 

(1,256) 
– 
(815) 
(120) 
(9,383) 

(3) 
(4) 

2021 

Net 

1,809 
(63) 
641 
(520) 
(3) 

231 
2,768 
(420) 
381 
(384) 

4,660 
1,383 
(815) 
199 
(3,385) 

(3) 
(4) 

34,350 

(27,875) 

6,475 

354 
903 

1,257 

1,020 
–
46 

1,066 

40 

40 

2,363 

36,713 

(20,952) 

15,761 

(1,166) 
(662) 

(1,828) 

(1,112) 

–
–

(1,112) 

– 

– 

(2,940) 

(30,815) 

20,952 

(9,863) 

(812) 
241 

(571) 

(92) 
– 
46 

(46) 

40 

40 

(577) 

5,898 

– 

5,898 

Gross 
assets 

Gross
liabilities

10,510 
29 
667 
– 
3 

2,080 
4,151 
3,611 
346 
– 

2,162 
373 
– 
53 
8,461 

11 
– 
32,457 

2,602 
1,118 
3,720 

638 
– 
–

638 

– 
– 
4,358 
36,815 
(19,302) 
17,513 

(7,585) 
(276) 
– 
(714) 
(18) 

(1,428) 
(4,207) 
(2,954) 
– 
(312) 

(1,733) 
– 
(456) 
(144) 
(6,514) 

(6) 
(8) 
(26,355) 

(43) 
(2,257) 
(2,300) 

(1,710) 
(1) 
–

(1,711) 

(9) 
(9) 
(4,020) 
(30,375) 
19,302 
(11,073) 

2020 

Net 

2,925 
(247) 
667 
(714) 
(15) 

652 
(56) 
657 
346 
(312) 

429 
373 
(456) 
(91) 
1,947 

5 
(8) 
6,102 

2,559 
(1,139) 
1,420 

(1,072) 
(1) 
– 
(1,073) 

(9) 
(9) 
338 
6,440 
– 
6,440 

(1)  Gold contracts are included with foreign exchange contracts. 
(2)  We held no bond futures as at October 31, 2021 (the fair value of bond futures designated in fair value hedge relationships rounded down to $nil as at October 31, 2020). 
(3)  The fair values of hedging derivatives wholly or partially offset the changes in fair values of the related on-balance sheet financial instruments. 

Assets are shown net of liabilities to customers where we have a legally enforceable right to offset amounts and we intend to settle contracts on a 
net basis. 

172  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notional Amounts of Trading Derivatives 
The notional amounts of our derivatives represent the amount to which a rate or price is applied in order to calculate the amount of cash that 
must be exchanged under the contract. Notional amounts do not represent assets or liabilities and therefore are not recorded in our Consolidated 
Balance Sheet. 

Exchange traded 

Over-the-counter 

2021 

Total 

Exchange traded 

Over-the-counter 

2020 

Total 

(Canadian $ in millions) 

Interest Rate Contracts 
Swaps 
Forward rate agreements 
Purchased options 
Written options 
Futures 

Total interest rate contracts 

Foreign Exchange Contracts (1) 
Cross-currency swaps 
Cross-currency interest rate swaps 
Forward foreign exchange contracts 
Purchased options 
Written options 
Futures 

Total foreign exchange contracts 

Commodity Contracts 
Swaps 
Purchased options 
Written options 
Futures 

Total commodity contracts 

Equity Contracts 

Credit Contracts 
Purchased 
Written 

Total 

– 
– 
10,611 
3,621 
232,972 

247,204 

– 
– 
– 
1,762 
4,735 
222 

6,719 

– 
10,020 
11,000 
39,448 

60,468 

106,302 

– 
– 

3,976,428 
147,657 
69,491 
68,155 
– 

3,976,428 
147,657 
80,102 
71,776 
232,972 

4,261,731 

4,508,935 

45,482 
506,791 
489,081 
54,145 
54,147 
– 

45,482 
506,791 
489,081 
55,907 
58,882 
222 

1,149,646 

1,156,365 

28,892 
14,546 
14,132 
39,448 

97,018 

28,892 
4,526 
3,132 
– 

36,550 

98,962 

12,358 
5,158 

205,264 

110,274 

12,358 
5,158 

– 
– 

– 
– 
24,683 
3,796 
297,578 

326,057 

– 
– 
– 
1,673 
2,346 
1,608 

5,627 

– 
4,846 
6,514 
39,011 

50,371 

4,148,257 
517,332 
57,833 
64,728 
– 

4,148,257 
517,332 
82,516 
68,524 
297,578 

4,788,150 

5,114,207 

47,805 
534,752 
494,640 
39,067 
41,327 
– 

47,805 
534,752 
494,640 
40,740 
43,673 
1,608 

1,157,591 

1,163,218 

30,613 
5,728 
3,704 
– 

40,045 

60,202 

7,407 
1,795 

30,613 
10,574 
10,218 
39,011 

90,416 

170,476 

7,407 
1,795 

420,693 

5,564,405 

5,985,098 

492,329 

6,055,190 

6,547,519 

(1)  Gold contracts are included with foreign exchange contracts. 

Table excludes loan commitment derivatives with notionals of $5,613 million ($2,603 million as at October 31, 2020). 

Derivatives Used in Hedge Accounting 
In accordance with our risk management strategy, we enter into various derivative contracts to hedge our interest rate, foreign currency and 
equity price exposures. We also use deposits, cross-currency swaps and foreign exchange forwards to hedge foreign currency exposure in our net 
investment in foreign operations. 

When the hedged item is accounted for at FVTPL, there is a natural offset within the income statement with the related derivative. However, 
when we manage risks incumbent in instruments that are accounted for at amortized cost, including loans and deposits, or FVOCI debt securities we 
use hedge accounting in order to eliminate the mismatch between the hedged item and the mark to market derivative. 

To the extent these instruments used to manage risk qualify for hedge accounting, we designate them in accounting hedge relationships. 
Our structural market risk strategies, including our approach to managing interest rate and foreign exchange risk, are included in the blue-tinted font 
in the Structural (Non-Trading) Market Risk section of Management’s Discussion and Analysis within this report. In addition, our exposure to foreign 
exchange rate risk is discussed in the Foreign Exchange Risk section of Management’s Discussion and Analysis. Our exposure to equity price risk and 
our approach to managing it are discussed in the Other Share-Based Compensation, Mid-Term Incentive Plans section of Note 20. 

By using derivatives to hedge exposures to interest rates, foreign currency exchange rates, and equity prices, we are also exposed to the credit 
risk of the derivative counterparty. We mitigate credit risk by entering into transactions with high-quality counterparties, requiring the counterparties 
to post collateral, entering into master netting agreements, or settling through centrally cleared counterparties. 

In order to qualify as an accounting hedge, the hedging relationship must be designated and formally documented at its inception, detailing 

the particular risk management objective and strategy for the hedge and the specific asset, liability or cash flow being hedged, as well as how 
effectiveness is to be assessed. Changes in the fair value of the derivative must be highly effective in offsetting changes in the fair value or changes 
in the amount of future cash flows of the hedged item. We evaluate hedge effectiveness at the inception of the hedging relationship and on an 
ongoing basis, retrospectively and prospectively, primarily using a quantitative statistical regression analysis. We consider a hedging relationship 
highly effective when all of the following criteria are met: correlation between the variables in the regression is at least 0.8; the slope of the 
regression is within a 0.8 to 1.25 range; and the confidence level of the slope is at least 95%. The practice is different for our net investment hedge, 
discussed in the Net Investment Hedges section below. 

Any ineffectiveness in the hedging relationship is recognized as it arises in non-interest revenue, other, in our Consolidated Statement of Income. 

N
o
t
e
s

BMO Financial Group 204th Annual Report 2021  173 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

Under the IASB’s Phase 1 Amendments to IAS 39 and IFRS 7, certain hedge accounting requirements were modified to provide relief from the 
uncertainty arising from IBOR reform during the period prior to replacement of IBORs. These amendments include allowing us to assume the interest 
rate benchmarks which are the basis for cash flows of the hedged item and hedging instrument are not altered as a result of IBOR reform, thereby 
allowing hedge accounting to continue. They also provide an exception from the requirement to discontinue hedge accounting if a hedging 
relationship does not meet the effectiveness requirements solely as a result of IBOR reform. We continue to apply these amendments as at 
October 31, 2021, with application ending at the earlier of the discontinuation of the impacted hedging relationship and when there is no longer 
uncertainty arising from IBOR reform over the timing and amount of IBOR-based cash flows. 

The following table outlines the notional amounts, and average rates of derivatives and the carrying amounts of deposits designated as hedging 
instruments, by term to maturity, hedge type, and risk type, where applicable. 

(Canadian $ in millions, except as noted) 

Within 1 year 

1 to 3 years 

3 to 5 years 

5 to 10 years  Over 10 years 

Remaining term to maturity 

2021 

Total 

2020 

Total 

Cash Flow Hedges 
Interest rate risk – Interest rate swaps 
Notional amount (1) 
Average fixed interest rate 
Foreign exchange risk – Cross-currency swaps 

and foreign exchange forwards (2) 

CAD-USD pair (3) 

CAD-EUR pair 

Other currency pairs 

Notional amount 
Average fixed interest rate 
Average exchange rate: CAD-USD 
Notional amount 
Average fixed interest rate 
Average exchange rate: CAD-EUR 
Notional amount (4) 
Average fixed interest rate 
Average exchange rate: 
CAD-Non USD/EUR 

Equity price risk – Total return swap 
Notional amount 

Fair Value Hedges 
Interest rate risk – Interest rate swaps 
Notional amount (5) 
Average fixed interest rate 
Interest rate risk – Bond futures (exchange-traded 

derivatives) 
Notional amount 
Average price in dollars 
Foreign exchange risk – Cross-currency swaps 
USD-GBP pair 

Notional amount (6) 
Average fixed interest rate 
Average exchange rate: USD-GBP 

Net Investment Hedges 
Foreign exchange risk – Cross-currency swaps 

and foreign exchange forwards 

Notional amount 

CAD-GBP pair 
Foreign exchange risk – Deposit liabilities 
USD denominated deposit – carrying amount 
GBP denominated deposit – carrying amount 

24,639 

24,172 

18,145 

25,733 

0.60% 

1.20% 

1.15% 

1.26% 

1,463 

1.68% 

94,152 

1.06% 

92,296 

1.39% 

6,668 

1.67% 

1.3031 
3,843 

17,446 

2.33% 

1.3283 
8,634 

2.60% 

1.91% 

1.5382 
1,908 

1.5025 
3,673 

7,091 

1.43% 

1.2606 
– 
– 
– 
4,474 

2.51% 

2.76% 

2.03% 

6,836 

1.53% 

1.3420 
1,839 

1.89% 

1.4711 
– 
– 

251 
3.02% 

1.3122 
201 
2.97% 

1.4870 
– 
– 

38,292 

1.91% 

1.3137 
14,517 

2.10% 

1.5078 
10,055 

2.39% 

43,381 

1.92% 

1.3219 
17,299 

2.17% 

1.5008 
7,104 
2.63% 

1.4245 

1.2229 

1.6710 

515

 –

 –

– 

 –

– 

 –

1.4606 

1.2923 

 515

 302 

11,740 

30,534 

19,555 

16,777 

0.97% 

1.30% 

1.18% 

1.20% 

2,105 

1.71% 

80,711 

1.21% 

94,738 

1.47% 

– 
– 

– 
– 
– 

– 
– 

– 
– 
– 

153 

1,132 

5,964 
728

– 
 –

– 
– 

– 
– 
– 

– 

– 
 –

– 
– 

– 
– 
– 

– 

– 
 –

– 
– 

– 
– 
– 

– 

– 
 –

– 
– 

– 
– 
– 

48 
126 

39 
0.66% 

1.3024 

1,285 

5,964 
 728

– 

8,219 
 892 

(1)  The notional amount of the interest rate swaps likely subject to IBOR reform that mature after June 30, 2023 was $35,519 million of USD LIBOR as at October 31, 2021. We had a notional amount of 

$48,825 million as at October 31, 2020, likely subject to IBOR reform that were to mature after December 31, 2021, the cessation date at the time of adoption of the Phase 1 amendments. 
(2)  Under certain hedge strategies using cross-currency swaps, a CAD leg is inserted to create two swaps designated as separate hedges (for example, a EURO-USD cross-currency swap split into 

EURO-CAD and CAD-USD cross-currency swaps). The relevant notional amount is grossed up in this table, as the cross-currency swaps are disclosed by CAD-foreign currency pair. 

(3)  Includes CAD-AUD, CAD-CHF, CAD-CNH, CAD-GBP or CAD-HKD cross-currency swaps where applicable. 
(4)  The notional amount of the cross-currency swaps likely subject to IBOR reform that mature after December 31, 2021 was $718 million of GBP LIBOR as at October 31, 2021 ($718 million as at 

October 31, 2020). 

(5)  The notional amount of the interest rate swaps likely subject to IBOR reform that mature after June 30, 2023 was $43,642 million of USD LIBOR. We had a notional amount of $55,130 million of 

USD LIBOR as at October 31, 2020, likely subject to IBOR reform that were to mature after December 31, 2021, the cessation date at the time of adoption of the Phase 1 amendments. The notional 
amount of GBP LIBOR interest rate swaps that mature after December 31, 2021 was $nil million as at October 31, 2021 ($41 million as at October 31, 2020). 

(6)  The notional amount of the cross-currency swaps likely subject to IBOR reform that mature after June 30, 2023 was $nil million of USD LIBOR as at October 31, 2021. We had a notional amount of 

$39 million of USD LIBOR as at October 31, 2020, likely subject to IBOR reform that were to mature after December 31, 2021, the cessation date at the time of adoption of the Phase 1 amendments. 

s
e
t
o
N

Cash Flow Hedges 
Cash flow hedges modify exposure to variability in cash flows for variable interest rate bearing instruments, foreign currency denominated assets 
and liabilities and certain cash-settled share-based payment grants subject to equity price risk. We use interest rate swaps with or without embedded 
options, cross-currency swaps, and total return swaps to hedge this variability. We hedge the full amount of foreign exchange risk, but interest rate 
risk is hedged only to the extent of benchmark interest rates. The benchmark interest rate is a component of interest rate risk that is observable in 
the relevant financial markets, for example LIBOR or Bankers’ Acceptances (BA) rate. 

We determine the amount of the exposure to which hedge accounting is applied by assessing the potential impact of changes in interest rates, 

foreign exchange rates, and equity prices on the future cash flows of floating rate loans and deposits, foreign currency denominated assets and 
liabilities and certain cash-settled share-based payments. This assessment is performed using analytical techniques, such as simulation, sensitivity 
analysis, stress testing and gap analysis. 

174  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
We record interest that we pay or receive on these cash flow hedge derivatives as an adjustment to net interest income in our Consolidated 

Statement of Income over the life of the hedge. 

The accounting mismatch that would otherwise occur is eliminated by recording changes in the fair value of the derivative that offset changes in 
the fair value of the hedged item for the designated hedged risk in other comprehensive income. Hedge ineffectiveness, the portion of the change in 
fair value of the derivative that does not offset changes in the fair value of the hedged item, is recorded directly in non-interest revenue, other, in our 
Consolidated Statement of Income as it arises. 

For cash flow hedges that are discontinued before the end of the original hedge term, the cumulative unrealized gain or loss recorded in other 

comprehensive income is amortized to our Consolidated Statement of Income in net interest income for interest rate swaps and in employee 
compensation for total return swaps as the hedged item is recorded in earnings. The entire unrealized gain or loss is recognized immediately in net 
interest income in our Consolidated Statement of Income, if the hedged item is sold or settled. In general, we do not terminate our foreign exchange 
hedges before maturity. 

For cash flow hedges, we use a hypothetical derivative to measure the hedged risk of floating rate loans, deposits, foreign currency denominated 

assets and liabilities, or share-based payment grants. This hypothetical derivative matches the critical terms of the hedged items identically, and it 
perfectly offsets the hedged cash flow. 

In our cash flow hedge relationships, the main sources of ineffectiveness are differences in interest rate indices, tenor and reset/settlement 

frequencies between the hedging instrument and the hedged item. 

Net Investment Hedges 
Net investment hedges mitigate our exposure to foreign currency exchange rate fluctuations related to our net investment in foreign operations. 
Deposits denominated in foreign currencies, cross-currency swaps and foreign exchange forwards are designated as a hedging instrument for 
a portion of the net investment in foreign operations. We designate the spot rate component of our hedging instrument in net investment hedge. 
The foreign currency translation of our net investment in foreign operations and the effective portion of the corresponding hedging instrument are 
recorded in unrealized gains (losses) on translation of net foreign operations in other comprehensive income, instead of through the income 
statement in the case of the hedging instrument if hedge accounting were not elected. 

The effectiveness of our net investment hedge is determined using the dollar offset method with spot foreign currency rates. As the notional amount 
of the hedging instruments and the hedged net investment in foreign operations are the same, there is no source of ineffectiveness in these hedging 
relationships. 

For cash flow hedges and net investment hedges, the following tables contain information related to items designated as hedging instruments, 
hedged items and hedge ineffectiveness for the years ended October 31, 2021 and October 31, 2020. 

(Canadian $ in millions) 

2021 

Cash Flow Hedges 
Interest rate risk – Interest rate swaps 
Foreign exchange risk – Cross-currency swaps 

and foreign exchange forwards 
Equity price risk – Total return swaps 

Net Investment Hedges 
Foreign exchange risk – Cross–currency swaps 

and foreign exchange forwards 

Foreign exchange risk – Deposit liabilities 

Total 

Cash Flow Hedges 
Interest rate risk – Interest rate swaps 
Foreign exchange risk – Cross-currency swaps 

and foreign exchange forwards 
Equity price risk – Total return swaps 

Net Investment Hedges 
Foreign exchange risk – Cross-currency swaps 

and foreign exchange forwards 

Foreign exchange risk – Deposit liabilities 

Total 

Carrying amount of 
hedging instruments (1) 

Hedge ineffectiveness 

Gains (losses) on 
hedging derivatives 
used to calculate hedge 
ineffectiveness (2) 

Gains (losses) on 
hypothetical derivatives 
used to calculate hedge 
ineffectiveness (2) 

Ineffectiveness 
recorded in 
non-interest 
revenue – other 

Asset 

Liability

354 

(1,166) 

(2,467) 

1,020 
40 

(1,112) 
– 

276 
313 

1,414 

(2,278) 

(1,878) 

46 
– 

– 
(6,692) 

29 
647 

1,460 

(8,970) 

(1,202) 

2,602 

638 
– 

3,240 

(43) 

(1,710) 
(9) 

(1,762) 

– 

(9,111) 

3,240 

(10,873) 

2,516 

(315) 
(108) 

2,093 

(131) 

1,962 

2,447 

(276) 
(313) 

1,858 

(29) 
(647) 

1,182 

(2,520) 

315 
108 

(2,097) 

131 

(1,966) 

(5) 

– 
– 

(5) 

– 
– 

(5) 

2020 

4 

– 
– 

4 

– 

4 

N
o
t
e
s

(1)  Represents the unrealized gains (losses) recorded as part of the derivative instruments in assets and liabilities, respectively, in our Consolidated Balance Sheet. 
(2)  Represents life to date amounts. 

BMO Financial Group 204th Annual Report 2021  175 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

For cash flow hedges and net investment hedges, the following tables contain information related to impacts in our Consolidated Statement of 
Comprehensive Income, on a pre-tax basis for the years ended October 31, 2021 and October 31, 2020. 

(Canadian $ in millions) 

Cash Flow Hedges 
Interest rate risk 
Foreign exchange risk 
Equity price risk 

Net Investment Hedges 
Foreign exchange risk 

Total 

(Canadian $ in millions) 

Cash Flow Hedges 
Interest rate risk 
Foreign exchange risk 
Equity price risk 

Net Investment Hedges 
Foreign exchange risk 

Total 

Balance
October 31, 2020

Gains / 
(losses) 
recognized 
in OCI 

Amount reclassified to 
net income as the 
hedged item affects 
net income 

Balance 
October 31, 2021 (1) 

Active hedges 

Discontinued hedges 

2021 

Balance in cash flow hedge AOCI / 
net foreign operations AOCI 

3,529 
(759) 
(50) 

2,720 

(2,462) 
266 
313 

(1,883) 

(1,939) 

676 

781 

(1,207) 

(489) 
10 
(84) 

(563) 

– 

(563) 

578 
(483) 
179 

274 

(921) 
(483) 
179 

(1,225) 

(1,263) 

(1,263) 

(989) 

(2,488) 

1,499 
– 
– 

1,499 

– 

1,499 

2020 

Balance 
October 31, 2019 

Gains / 
(losses) 
recognized 
in OCI 

Amount reclassified to 
net income as the 
hedged item affects 
net income 

Balance 
October 31, 2020 (1)

Active hedges 

Discontinued hedges 

Balance in cash flow hedge AOCI / 
net foreign operations AOCI 

1,156 
(444) 
17 

729 

(1,808) 

(1,079) 

2,512 
(350) 
(108) 

2,054 

(131) 

1,923 

(139) 
35 
41 

(63) 

– 

(63) 

3,529 
(759) 
(50) 

2,720 

(1,939) 

781 

2,359 
(759) 
(50) 

1,550 

(1,939) 

(389) 

1,170 
– 
– 

1,170 

– 

1,170 

(1)  Tax balance related to cash flow hedge accumulated other comprehensive income was $(89) million, and $(741) million as at October 31, 2020. 

Fair Value Hedges 
Fair value hedges modify exposure to changes in a fixed rate instrument’s fair value caused by changes in interest rates. These hedges economically 
convert fixed rate assets and liabilities to floating rate. We use cross-currency swaps, interest rate swaps, and bond futures to hedge interest rate risk, 
including benchmark interest rates, inherent in fixed rate securities, a portfolio of mortgages, deposits and subordinated debt and other liabilities. 

The carrying value of fixed rate assets or liabilities that are part of a hedging relationship are adjusted for the change in value of the risk being 

hedged. To the extent that the change in the fair value of the derivative does not offset changes in the fair value of the hedged item for the risk 
being hedged, the net amount (hedge ineffectiveness) is recorded directly in non-interest revenue, other, in our Consolidated Statement of Income. 
For fair value hedges that are discontinued, we cease adjusting the hedged item. The cumulative fair value adjustment of the hedged item is 

then amortized to net interest income over the hedged item’s remaining term to maturity. If the hedged item is sold or settled, the cumulative fair 
value adjustment is included in the gain or loss on sale or settlement. 

In our fair value hedge relationships, the main sources of ineffectiveness are our own credit risk on the fair value of the swap, and the difference 

in terms such as fixed interest rate or reset/settlement frequency between the swap and the hedged item. 

s
e
t
o
N

176  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The amounts relating to derivatives designated as fair value hedging instruments, hedged items and hedge ineffectiveness for the years ended 
October 31, 2021 and 2020 are as follows: 

(Canadian $ in millions) 

Carrying amount of 
hedging derivatives (1) 

Hedge ineffectiveness 

2021 

Accumulated amount of fair value 
hedge gains (losses) on hedged items

Fair Value Hedge (3) 
Interest rate swaps 
Cross-currency swaps 
Securities and loans 
Deposits, subordinated debt

and other liabilities 

Total 

Asset 

Liability 

903
–
– 

– 

903 

(662) 
– 
– 

– 

(662) 

Fair Value Hedge (3) 
Interest rate swaps 
Cross-currency swaps 
Securities and loans 
Deposits, subordinated debt 

and other liabilities 

Total 

1,118 
– 
– 

(2,257) 
(1) 
– 

– 

– 

1,118 

(2,258) 

Gains (losses) on 
hedging derivatives 
used to calculate 
hedge ineffectiveness 

Gains (losses) on 
hedged item used 
to calculate hedge 
ineffectiveness 

Ineffectiveness 
recorded in 
non-interest 
revenue – other 

Carrying amount 
of the hedged 
item (2) 

Active 
hedges 

Discontinued 
hedges 

– 
– 
1,649 

(644) 

1,005 

– 
– 
(1,791) 

622 

(1,169) 

–
–

(1,654) 

638 

(1,016) 

– 
– 
1,794 

(620) 

1,174 

–
–
(5) 

(6) 

(11) 

–
–
49,789 

– 
–
156 

(31,530) 

(121) 

18,259 

35 

– 
– 
3 

2 

5 

– 
– 
58,608 

(39,950) 

18,658 

– 
– 
2,762 

(943) 

1,819 

– 
– 
62 

(91) 

(29) 

2020 

– 
– 
25 

8 

33 

(1)  Represents the unrealized gains (losses) within derivative instruments in assets and liabilities, respectively, in the Consolidated Balance Sheet. 
(2)  Represents the carrying value in the Consolidated Balance Sheet and includes amortized cost, before allowance for credit losses, plus fair value hedge adjustments, except for FVOCI securities that are 

carried at fair value. 

(3)  $nil for bond futures designated in fair value hedge relationships as at October 31, 2021 (all amounts in the table round down to $nil as at October 31, 2020). 

Derivative-Related Market Risk 
Derivative instruments are subject to market risk. Market risk arises from the potential for a negative impact on the balance sheet and/or statement 
of income due to adverse changes in the value of derivative instruments as a result of changes in certain market variables. These variables include 
interest rates, credit spreads, foreign exchange rates, equity and commodity prices and their implied volatilities, credit migration and default. 
We strive to limit market risk by employing comprehensive governance and management processes for all market risk-taking activities. 

Derivative-Related Credit Risk 
Derivative instruments are subject to credit risk arising from the possibility that counterparties may default on their obligations. The credit risk 
associated with a derivative is normally a small fraction of the notional amount of the derivative instrument. Derivative contracts generally expos e us 
to potential credit loss if changes in market rates affect the counterparty’s position unfavourably and the counterparty defaults on payment. The credit 
risk is represented by the positive fair value of the derivative instrument. We strive to limit credit risk by dealing with counterparties that we believe 
are creditworthy, and we manage our credit risk for derivatives using the same credit risk process that is applied to loans and other credit assets. 

We also pursue opportunities to reduce our exposure to credit losses on derivative instruments, through collateral and by entering into master 

netting agreements with counterparties. The credit risk associated with favourable contracts is mitigated by legally enforceable master netting 
agreements to the extent that unfavourable contracts with the same counterparty must be settled concurrently with favourable contracts. 

Exchange-traded derivatives have limited potential for credit exposure, as they are settled net daily with each exchange. 

Terms used in the credit risk tables below are as follows: 

Replacement cost captures the loss that would occur if a counterparty were to default in the present or at a future time, assuming that the closeout 
and replacement of transactions occur instantaneously, assuming no recovery on the value of those transactions in bankruptcy. 

Credit risk equivalent represents the total replacement cost plus an amount representing the potential future credit exposure adjusted by a 
multiplier 1.4, as outlined in OSFI’s Capital Adequacy Guideline. 

Risk-weighted assets represent the credit risk equivalent, weighted on the basis of the creditworthiness of the counterparty, and considering 
collateral, netting and other credit risk mitigants, as prescribed by OSFI. 

N
o
t
e
s

BMO Financial Group 204th Annual Report 2021  177 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

(Canadian $ in millions) 

2021 

2020 

Replacement 
cost (1) 

Credit risk 
equivalent (1) 

Risk-weighted 
assets 

Replacement 
cost (1) 

Credit risk 
equivalent (1) 

Risk-weighted 
assets 

Interest Rate Contracts 
Over-the-counter 
Swaps 
Forward rate agreements 
Purchased options 
Written options 

Exchange traded 
Futures 
Purchased options 
Written options 

Total interest rate contracts 

Foreign Exchange Contracts (2) 
Over-the-counter 
Swaps 
Forward foreign exchange contracts 
Purchased options 
Written options 

Exchange traded 
Futures 
Purchased options 
Written options 

2,636 
667 
16 
20 

3,339 

71 
2 
2 

75 

6,936 
2,545 
72 
105 

9,658 

141 
4 
4 

149 

1,422 
826 
81 
70 

2,399 

3 
– 
– 

3 

5,228 
1,153 
2 
68 

6,451 

22 
45 
3 

70 

10,713 
3,332 
55 
206 

14,306 

83 
66 
4 

153 

3,380 
1,479 
12 
150 

5,021 

2 
1 
– 

3 

3,414 

9,807 

2,402 

6,521 

14,459 

5,024 

1,087 
769 
93 
11 

1,960 

1 
15 
26 

42 

4,609 
6,649 
270 
115 

987 
883 
104 
38 

11,643 

2,012 

2 
22 
37 

61 

– 
– 
1 

1 

872 
1,032 
68 
5 

1,977 

1 
12 
12 

25 

5,581 
7,859 
196 
76 

794 
823 
95 
27 

13,712 

1,739 

2 
17 
18 

37 

– 
– 
– 

– 

Total foreign exchange contracts 

2,002 

11,704 

2,013 

2,002 

13,749 

1,739 

Commodity Contracts 
Over-the-counter 
Swaps 
Purchased options 
Written options 

Exchange traded 
Futures 
Purchased options 
Written options 

Total commodity contracts 

Equity Contracts 
Over-the-counter 
Exchange traded 

Total equity contracts 

Credit Contracts 

Total 

4,357 
1,537 
6 

5,900 

1,829 
474 
463 

2,766 

8,666 

467 
3,873 

4,340 

277 

8,183 
2,601 
175 

10,959 

3,244 
721 
727 

4,692 

2,148 
457 
51 

2,656 

65 
14 
15 

94 

15,651 

2,750 

9,754 
7,938 

17,692 

721 

2,663 
159 

2,822 

79 

1,424 
117 
1 

1,542 

635 
373 
221 

1,229 

2,771 

563 
5,958 

6,521 

272 

4,215 
746 
234 

5,195 

1,612 
562 
363 

2,537 

7,732 

8,010 
10,135 

18,145 

741 

2,119 
257 
74 

2,450 

33 
11 
7 

51 

2,501 

2,399 
203 

2,602 

75 

18,699 

55,575 

10,066 

18,087 

54,826 

11,941 

(1)  Replacement cost and credit risk equivalent are presented after the impact of master netting agreements and calculated using the Standardized Approach for Counterparty Credit Risk (SA-CCR) in 

accordance with the Capital Adequacy Requirements (CAR) Guideline issued by OSFI. Table therefore excludes loan commitment derivatives. 

(2)  Gold contracts are included in foreign exchange contracts. 

s
e
t
o
N

178  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Term to Maturity 
Our derivative contracts have varying maturity dates. The remaining contractual terms to maturity for the notional amounts of our derivative contracts 
are set out below: 

(Canadian $ in millions) 

Term to maturity 

2021 

2020 

Interest Rate Contracts 
Swaps 
Forward rate agreements, futures and options 

Total interest rate contracts 

Foreign Exchange Contracts (1) 
Swaps 
Forward foreign exchange contracts 
Futures 
Options 

Total foreign exchange contracts 

Commodity Contracts 
Swaps 
Futures 
Options 

Total commodity contracts 

Equity Contracts 

Credit Contracts (2) 

Total notional amount 

(1) Gold contracts are included with foreign exchange contracts. 
(2) Under the SA-CCR, excludes loan commitment derivatives. 

Within 1 
year 

1 to 3
years 

3 to 5
years 

5 to 10  
years 

Over 10 
years 

Total notional 
amounts 

Total notional 
amounts 

1,421,335 
350,532 

1,162,256 
138,390 

710,856 
25,879 

657,830 
14,969 

199,014 
2,737 

4,151,291 
532,507 

1,771,867 

1,300,646 

736,735 

672,799 

201,751 

4,683,798 

137,841 
474,834 
213 
104,031 

196,488 
13,016 
9 
8,799 

121,635 
1,341 
– 
1,959 

110,545 
208 
– 
– 

32,824 
27 
– 
– 

599,333 
489,426 
222 
114,789 

4,335,291 
965,998 

5,301,289 

637,501 
494,640 
1,608 
84,413 

716,919 

218,312 

124,935 

110,753 

32,851 

1,203,770 

1,218,162 

12,709 
20,577 
16,358 

49,644 

14,622 
17,258 
11,936 

43,816 

1,495 
1,540 
384 

3,419 

141,028 

48,206 

14,534 

298 

866 

9,635 

66 
73 
– 

139 

1,780 

6,325 

– 
– 
– 

– 

232 

392 

28,892 
39,448 
28,678 

97,018 

205,780 

17,516 

2,679,756 

1,611,846 

889,258 

791,796 

235,226 

6,207,882 

30,613 
39,011 
20,792 

90,416 

170,778 

9,202 

6,789,847 

Note 9: Premises and Equipment 
We record all owned premises and equipment at cost less accumulated depreciation, and less any accumulated impairment, except land, which is 
recorded at cost. Buildings, computer equipment and operating system software, other equipment and leasehold improvements are depreciated on 
a straight-line basis over their estimated useful lives. When the major components of a building have different useful lives, they are accounted for 
separately and depreciated over each component’s estimated useful life. The maximum estimated useful lives we use to depreciate our assets are 
as follows: 

Buildings 
Computer equipment and operating system software 
Other equipment 
Leasehold improvements 

10 to 40 years 
5 to 7 years 
10 years 
Lease term to a maximum of 10 years 

Depreciation methods, useful lives and the residual values of premises and equipment are reviewed annually for any change in circumstances and are 
adjusted if appropriate. At each reporting period, we review whether there are any indications that premises and equipment need to be tested for 
impairment. If there is an indication that an asset may be impaired, we test for impairment by comparing the asset’s carrying value to its recoverable 
amount. The recoverable amount is calculated as the higher of the value in use and the fair value less costs to sell. Value in use is the present value 
of the future cash flows expected to be derived from the asset. An impairment charge is recorded when the recoverable amount is less than the 
carrying value. There were write-downs of premises and equipment of $36 million due to impairment during the year ended October 31, 2021 
($4 million in 2020 and $nil in 2019). Gains and losses on disposal are included in non-interest expense, premises and equipment, in our Consolidated 
Statement of Income. 

Leases 
When we enter into a new arrangement as a lessee, a right-of-use asset is recognized equal to the lease liability, which is calculated based on the 
future lease payments discounted at our incremental borrowing rate over the lease term. The lease term is based on the non-cancellable period and 
includes any options to extend or terminate which we are reasonably certain to exercise. 

The right-of-use asset is depreciated on a straight-line basis, based on the shorter of the useful life of the underlying asset or the lease term, and 

is adjusted for impairment losses, if any. 

The lease liability accretes interest over the lease term, using the effective interest method, with the associated interest expense recognized in 

interest expense, other liabilities, in our Consolidated Statement of Income. The lease liability is remeasured when decisions are made to exercise 
options under the lease arrangement or when the likelihood of exercising an option within the lease changes. Refer to Note 14 for further 
information. 

Amounts relating to leases of low value are expensed when incurred in non-interest expense, premises and equipment, in our Consolidated 

N
o
t
e
s

Statement of Income. 

BMO Financial Group 204th Annual Report 2021  179 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

Prior to the adoption of IFRS 16, net rent expense reported in non-interest expense, premises and equipment, in our Consolidated Statement of 

Income for the year ended October 31, 2019 was $600 million. 

The total cost and associated accumulated depreciation for premises and equipment owned and leased are set out below: 

(Canadian $ in millions) 

2021 

2020 

Land  Buildings

Computer 
equipment 

Other 
equipment 

Leasehold 
improvements 

Right-of-use
assets (1)

  Total  Land  Buildings 

Computer 
equipment 

Other 
equipment 

Leasehold 
improvements 

Right-of-use 

assets (1)  Total 

Cost 
Balance at beginning of year 
Impact from adopting IFRS 16 (1) (2) 
Additions/lease modifications 
Disposals (3) 
Foreign exchange and other 

112 
–
– 
(6) 
(7) 

1,454 
–
52 
(44) 
(108) 

2,481 
–
193 
(349) 
(33) 

904 
– 
53 
(245) 
(27) 

Balance at end of year 

99 

1,354 

2,292 

685 

Accumulated Depreciation and 

Impairment 

Balance at beginning of year 
Impact from adopting IFRS 16 (1) (2) 
Disposals (3) 
Depreciation 
Foreign exchange and other (4) 

Balance at end of year 

Net carrying value 

– 
–
– 
– 
– 

– 

99 

936 
–
(46) 
52 
(75) 

867 

487 

1,888 
–

(345) 
217 
(36) 

1,724 

568 

680 
– 
(245) 
51 
(15) 

471 

214 

1,769 
– 
192 
(44) 
24 

1,941 

1,250 
– 
(41) 
105 
24 

1,338 

–

2,580  9,300  109 
– 
8 
(6) 
1 

– 
731  1,221 
(29)  (717) 
(81)  (232) 

1,534 
(23) 
53 
(116) 
6 

2,470 
(65) 
168 
(104) 
12 

3,201  9,572  112 

1,454 

2,481 

–

363  5,117 
– 
(29)  (706) 
366  791 
(84) 

18 

718  5,118 

– 
– 
– 
– 
– 

– 

961 
–
(93) 
64 
4 

936 

518 

1,786 
(27) 
(100) 
218 
11 

1,888 

593 

603 

2,483  4,454  112 

973 
– 
41 
(122) 
12 

904 

742 
– 
(120) 
52 
6 

680 

224 

1,615 
– 
167 
(28) 
15 

1,769 

1,157 
– 
(25) 
107 
11 

1,250 

na  6,701 
2,053  1,965 
559 
996 
(22)  (398) 
36 
(10)

2,580  9,300 

na  4,646 
27
– 
(22)  (360) 
801 
360 
30 
(2)

363  5,117 

519 

2,217  4,183 

(1)  Effective November 1, 2019, we adopted IFRS 16 Leases, recognizing the cumulative effect of adoption in opening retained earnings with no changes to prior periods (refer to Note 1). 
(2)  Includes net book value of buildings transferred to right-of-use assets. 
(3)  Includes fully depreciated assets written off. 
(4)  Includes impairment charges. 
na - not applicable due to IFRS 16 adoption. 

Note 10: Acquisitions and Divestitures 
Acquisitions 
The cost of an acquisition is measured at the fair value of the consideration transferred, including contingent consideration. Acquisition-related costs 
are recognized as an expense in the period in which they are incurred. The identifiable assets acquired and liabilities assumed and contingent 
consideration are measured at their fair values at the date of acquisition. Goodwill is measured as the excess of the aggregate of the consideration 
transferred over the net of the fair value of identifiable assets acquired and liabilities assumed. The results of operations of acquired businesses are 
included in our consolidated financial statements beginning on the date of acquisition. 

Clearpool Group Inc. 
On April 6, 2020, we completed the acquisition of Clearpool Group Inc. (Clearpool), a New York-based provider of electronic trading solutions, 
operating in the United States and Canada, for cash consideration of US$139 million (CAD$196 million) plus contingent consideration of approximately 
US$7 million (CAD$11 million) based on meeting certain revenue targets over four years. The acquisition was accounted for as a business 
combination, and the acquired business and corresponding goodwill are included in our Capital Markets reporting segment. 

As part of this acquisition, we acquired intangible assets of $85 million and goodwill of $132 million. The intangible assets are being amortized 

over three to eight years. Goodwill related to this acquisition is not deductible for tax purposes. 

The fair values of the assets acquired and liabilities assumed at the date of acquisition are as follows: 

(Canadian $ in millions) 

Goodwill and intangible assets 
Other assets 

Total assets 

Liabilities 

Purchase price 

The purchase price allocation for Clearpool has been completed. 

Clearpool 

217 
44 

261 

54 

207 

s
e
t
o
N

Divestitures 
Non-current non-financial assets (and disposal groups) are classified as held-for-sale if their carrying amount will be recovered principally through 
a sale transaction rather than through continuing use. These assets meet the criteria for classification as held-for-sale if they are available for 
immediate sale in their present condition and their sale is considered highly probable to occur within one year. Non-current non-financial assets 
classified as held-for-sale are measured at the lower of their carrying amount and fair value less costs to sell. Any subsequent write-down to fair 
value less costs to sell is recognized in non-interest expense in our Consolidated Statement of Income. Any subsequent increase in the fair value 
less costs to sell, to the extent this does not exceed the cumulative write-down or impact the impairment previously allocated to goodwill, is also 
recognized in non-interest expense. Gains on disposals are recognized in non-interest income. 

180  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Private Bank, Asia 
On April 30, 2021, we completed the sale of our Private Banking business in Hong Kong and Singapore, part of our BMO Wealth Management 
operating segment, to J. Safra Sarasin Group. The business sold is not considered material to the bank. 

EMEA and U.S. Asset Management 
On November 8, 2021, we completed the sale of our EMEA asset management business, part of our BMO Wealth Management operating segment, 
to Ameriprise Financial Inc. (Ameriprise) for £615 million (CAD$1,042 million) in an all-cash transaction. The transaction with Ameriprise includes the 
opportunity for certain BMO asset management clients in the U.S. to move to Ameriprise, with the transfers expected to be completed in the first 
calendar quarter of fiscal 2022, subject to client consent. As this transaction met the accounting requirements of assets held-for-sale, whereby the 
assets and liabilities are measured at lower of fair value, less costs to sell, and carrying value at each reporting period end until disposal, we 
recognized a write-down of goodwill related to these businesses of $779 million in fiscal 2021. The write-down was included in non-interest expense, 
other, in our Consolidated Statement of Income and was reported in the Corporate Services segment. As at November 8, 2021, assets and liabilities 
of approximately $1,696 million and $527 million, respectively, in relation to our EMEA asset management business have been derecognized. 
In connection with the completion of the sale, we will recognize a loss of $28 million in the first quarter of fiscal 2022 relating to foreign currency 
translation reclassified from accumulated other comprehensive income in equity to net income. 

Taplin, Canida & Habacht LLC 
On July 27, 2021, we entered into an agreement to sell Taplin, Canida & Habacht, LLC, part of our U.S. asset management business to Loop Capital. 
The transaction is expected to close in the first quarter of fiscal 2022, subject to customary closing conditions. The business sold is not considered 
material to the bank. 

Note 11: Goodwill and Intangible Assets 
Goodwill 
When we complete an acquisition, we allocate the purchase price paid to the assets acquired, including identifiable intangible assets, and the 
liabilities assumed. Any portion of the consideration transferred that is in excess of the fair value of those net assets is considered to be goodwill. 
Goodwill is not amortized and is instead tested for impairment annually. 

In performing the impairment test, we utilize the fair value less costs to sell for each group of CGUs based on discounted cash flow projections. 
Cash flows were projected for the first 10 years based on actual operating results, expected future business performance and past experience. Beyond 
10 years, cash flows were assumed to grow at perpetual annual rates of up to 3.0% (2.5% in 2020). The discount rates we applied in determining the 
recoverable amounts in 2021 ranged from 6.8% to 11.0% (6.0% to 10.3% in 2020), and were based on our estimate of the cost of capital for each 
CGU. The cost of capital for each CGU was estimated using the Capital Asset Pricing Model, based on the historical betas of publicly traded peer 
companies that are comparable to the CGU. We use significant judgment to determine inputs to the discounted cash flow model, which are most 
sensitive to changes in future cash flows, discount rates and terminal growth rates applied to cash flows beyond the forecast period. 

The key assumptions described above may change as market and economic conditions change. However, we estimate that reasonably possible 

changes in these assumptions are not expected to cause the recoverable amounts of our CGUs to decline below their carrying amounts. 

We recognized a write-down of goodwill of $779 million during the year ended October 31, 2021 ($nil in 2020) due to the valuation implied from 
the definitive agreement to sell our EMEA asset management business to Ameriprise and management’s allocation of goodwill to the business being 
sold. Refer to Note 10 for further information. 

A continuity of our goodwill by group of CGUs for the years ended October 31, 2020 and 2021 is as follows: 

(Canadian $ in millions) 

Personal and 
Commercial Banking 

BMO Wealth 
Management 

BMO 
Capital Markets 

Total 

Balance – October 31, 2019 
Acquisitions during the year 
Foreign exchange and other (1) 

Balance – October 31, 2020 

Dispositions during the year 
Foreign exchange and other (1) 

Balance – October 31, 2021 

Canadian 
P&C 

97 
– 
– 

97 

– 
– 

U.S. 
P&C 

3,796 
– 
45 

3,841 

– 
(274) 

Traditional 
Wealth 
Management 

Insurance 

2,145 
– 
23 

2,168 

(21) 
(837) 

2 
– 
– 

2 

– 
– 

Total 

3,893 
– 
45 

3,938 

– 
(274) 

Total 

2,147 
– 
23 

2,170 

(21) 
(837) 

300 
132 
(5) 

427 

– 
(25) 

6,340 
132 
63 

6,535 

(21) 
(1,136) 

97  (2) 

3,567  (3) 

3,664 

1,310  (4) 

2  (5) 

1,312 

402  (6) 

5,378 

(1)  Other changes in goodwill included the effects of translating goodwill denominated in foreign currencies into Canadian dollars and purchase accounting adjustments related to prior-year purchases. 
(2)  Relates primarily to bcpbank Canada, Diners Club, Aver Media LP and GE Transportation Finance. 
(3)  Relates primarily to First National Bank & Trust, Ozaukee Bank, Merchants and Manufacturers Bancorporation, Inc., Diners Club, AMCORE, M&I and GE Transportation Finance. 
(4)  Relates to BMO Nesbitt Burns Inc., Guardian Group of Funds Ltd., Pyrford International Limited, LGM Investments Limited, M&I, myCFO, Inc., Stoker Ostler Wealth Advisors, Inc., CTC Consulting LLC, and 
F&C Asset Management plc. Included in Foreign exchange and other is a write-down of $779 million of goodwill attributable to the sale of our EMEA asset management business. Refer to Note 10. 

(5)  Relates to AIG. 
(6)  Relates to Gerard Klauer Mattison, BMO Nesbitt Burns Inc., Paloma Securities L.L.C., M&I, Greene Holcomb Fisher, KGS-Alpha Capital Markets and Clearpool. 

N
o
t
e
s

BMO Financial Group 204th Annual Report 2021  181 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

Intangible Assets 
Intangible assets related to our acquisitions are initially recorded at their fair value at the acquisition date and subsequently at cost less accumulated 
amortization. Software is recorded at cost less accumulated amortization. Amortization expense is recorded in amortization of intangible assets in our 
Consolidated Statement of Income. The following table presents the changes in the balance of these intangible assets: 

(Canadian $ in millions) 

Cost as at October 31, 2019 
Additions (disposals) 
Transfers 
Foreign exchange and other 

Cost as at October 31, 2020 
Additions (disposals) 
Transfers 
Foreign exchange and other 

Cost as at October 31, 2021 

Customer 
relationships 

Core 
deposits 

Software – 
amortizing 

Software under 
development 

Other 

Total 

760 
– 
– 
7 

767 
(9) 
– 
(39) 

951 
– 
– 
11 

962 
– 
– 
(68) 

4,836  (1) 
(20) 
582 
18  (1) 

5,416 
(248) 
498 
(118) 

402 
458 
(582) 
2

280 
426 
(498) 
(4) 

638 
(17) 
– 
 –

621 
2 
– 
(22) 

7,587 
421 
– 
38

8,046 
171 
– 
(251) 

719 

894 

5,548  (1) 

204 

601 

7,966 

(1)  Includes $4,798 million of internally generated software as at October 31, 2021 ($4,458 million as at October 31, 2020). 

The following table presents the accumulated amortization of our intangible assets: 

(Canadian $ in millions)

Accumulated amortization at October 31, 2019 
Amortization 
Disposals 
Foreign exchange and other 

Accumulated amortization at October 31, 2020 
Amortization 
Disposals 
Foreign exchange and other 

Accumulated amortization at October 31, 2021 

Carrying value at October 31, 2021 

Carrying value at October 31, 2020 

Customer 
relationships 

Core 
deposits 

Software – 
amortizing 

Software under 
development 

Other 

Total 

551 
52 
– 
13 

616 
35 
(5) 
(30) 

616 

103 

151 

878 
46 
– 
9 

933 
27 
– 
(66) 

894 

– 

29 

3,361  (1) 
478 
(173) 
15 

3,681  (1) 
530 
(308) 
(82) 

3,821  (1) 

1,727 

1,735 

– 
– 
– 
– 

– 
– 
– 
– 

– 

204 

280 

373 
44 
(38) 
(5) 

374 
42 
(28) 
(19) 

369 

232 

247 

5,163 
620 
(211) 
32 

5,604 
634 
(341) 
(197) 

5,700 

2,266 

2,442 

(1)  Includes $3,231 million of internally generated software as at October 31, 2021 ($2,909 million as at October 31, 2020). 

Intangible assets are amortized to income over the period during which we believe the assets will benefit us, on either a straight-line or an 
accelerated basis, over a period not to exceed 15 years. We have $166 million as at October 31, 2021 ($172 million as at October 31, 2020) in 
intangible assets with indefinite lives that relate primarily to fund management contracts. 

The useful lives of intangible assets are reviewed annually for any changes in circumstances. We test definite-life intangible assets for 

impairment when events or changes in circumstances indicate that their carrying value may not be recoverable. Indefinite-life intangible assets are 
tested annually for impairment. If any intangible assets are determined to be impaired, we write them down to their recoverable amount, the higher 
of value in use and fair value less costs to sell. 

There were write-downs of software-related intangible assets of $9 million during the year ended October 31, 2021 ($5 million in 2020 and 

$10 million in 2019). 

Note 12: Other Assets 
Customers’ Liability Under Acceptances 
Acceptances represent a form of negotiable short-term debt issued by our customers, which we guarantee for a fee. The fees earned are recorded 
in non-interest revenue, lending fees in our Consolidated Statement of Income over the term of the acceptance. The amount potentially due under 
acceptances is recorded in other liabilities in our Consolidated Balance Sheet. We record the bank’s equivalent claim against our customers in the 
event of a call on these commitments in other assets in our Consolidated Balance Sheet. 

Other 
The components of other within other assets are as follows: 

s
e
t
o
N

(Canadian $ in millions) 

Accounts receivable, prepaid expenses and other items 
Accrued interest receivable 
Bank owned life insurance policies 
Leased vehicles, net of accumulated amortization 
Cash collateral 
Due from clients, dealers and brokers 
Insurance-related assets 
Other employee future benefits assets (Note 21) 
Pension asset (Note 21) 
Precious metals (1) 

Total 

(1)  Precious metals are recorded at their fair value based on quoted prices in active markets. 
Certain comparative figures have been reclassified to conform with the current year’s presentation. 

182  BMO Financial Group 204th Annual Report 2021 

2021 

3,302 
1,452 
4,096 
415 
6,436 
353 
2,080 
40 
947 
3,290 

2020 

2,942 
1,586 
4,352 
677 
6,344 
161 
1,507 
38 
124 
5,328 

22,411 

23,059 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Note 13: Deposits 

Payable on demand 

(Canadian $ in millions) 

Interest bearing 

Non-interest 
bearing 

Payable
after notice

Payable on 
a fixed date (3) 

2021 

2020 

Deposits by: 
Banks (1) 
Business and government 
Individuals 

Total (2) (4) 

Booked in: 
Canada 
United States 
Other countries 

Total 

5,009 
50,779 
4,895 

60,683 

51,465 
8,929 
289 

60,683 

1,887 
54,740 
36,679 

93,306 

83,952 
9,284 
70 

93,306 

733 
148,682 
119,425 

268,840 

129,370 
138,267 
1,203 

268,840 

18,982 
188,047 
55,773 

262,802 

162,529 
76,350 
23,923 

262,802 

26,611 
442,248 
216,772 

685,631 

427,316 
232,830 
25,485 

685,631 

38,825 
400,679 
219,530 

659,034 

407,926 
220,292 
30,816 

659,034 

(1)  Includes regulated and central banks. 
(2)  Includes structured notes and metal deposits designated at FVTPL. 
(3)  Includes $35,959 million of senior unsecured debt as at October 31, 2021 subject to the Bank Recapitalization (Bail-In) regime ($25,651 million as at October 31, 2020). The Bail-In regime provides 
certain statutory powers to the Canada Deposit Insurance Corporation, including the ability to convert specified eligible shares and liabilities into common shares if the bank becomes non-viable. 

(4)  Included in deposits as at October 31, 2021 and 2020 are $342,967 million and $322,951 million, respectively, of deposits denominated in U.S. dollars, and $29,937 million and $32,254 million, 

respectively, of deposits denominated in other foreign currencies. 

Deposits payable on demand are comprised primarily of our customers’ chequing accounts, on some of which we pay interest. Our customers need 
not notify us prior to withdrawing money from their chequing accounts. Deposits payable after notice are comprised primarily of our customers’ 
savings accounts, on which we pay interest. Deposits payable on a fixed date are comprised of: 
•  Various investment instruments purchased by our customers to earn interest over a fixed period, such as retail and small business term deposits, 
wholesale funding, and guaranteed investment certificates. Deposits totalling $20,991 million as at October 31, 2021 ($27,353 million as at 
October 31, 2020) can be early redeemed (either fully or partially) by customers without penalty. As we do not expect a significant amount to 
be redeemed before maturity, we have classified them as payable on a fixed date, based on their remaining contractual maturities. 

•  Commercial paper, which totalled $13,834 million as at October 31, 2021 ($8,358 million as at October 31, 2020). 
•  Covered bonds, which totalled $23,495 million as at October 31, 2021 ($24,699 million as at October 31 2020). 

The following table presents the maturity schedule for deposits payable on a fixed date: 

(Canadian $ in millions) 

As at October 31, 2021 
As at October 31, 2020 

Within 1 year 

1 to 2 years 

2 to 3 years 

3 to 4 years 

4 to 5 years 

Over 5 years 

Total 

163,370 
192,617 

33,778 
27,855 

24,826 
30,053 

8,908 
18,260 

11,995 
9,683 

19,925  262,802 
291,632 
13,164 

We have unencumbered liquid assets of $317,251 million to support these and other deposit liabilities ($306,120 million as at October 31, 2020). 

The following table presents deposits payable on a fixed date and greater than one hundred thousand dollars: 

(Canadian $ in millions) 

As at October 31, 2021 
As at October 31, 2020 

Canada 

United States 

Other 

Total 

140,002 
158,475 

72,399 
72,186 

23,921 
27,799 

236,322
258,460

The following table presents the maturity schedule for deposits payable on a fixed date and greater than one hundred thousand dollars, which are 
booked in Canada: 

(Canadian $ in millions) 

As at October 31, 2021 
As at October 31, 2020 

Less than 3 months 

3 to 6 months 

6 to 12 months 

Over 12 months 

Total 

20,626 
18,081 

12,761 
29,679 

20,933 
28,109 

85,682  140,002 
158,475 
82,606 

Structured Note Liabilities 
Most of our structured note liabilities included in deposits have been designated at fair value through profit or loss, which aligns the accounting result 
with the way the portfolio is managed. The change in fair value of these structured notes is recorded in non-interest revenue, trading revenues with 
the changes in fair value due to own credit risk recognized in other comprehensive income. The impact of changes in our own credit risk is measured 
based on movements in our own credit spread year over year. 

The following table presents fair value and changes in fair value of structured note liabilities: 

(Canadian $ in millions) 

As at October 31, 2021 
As at October 31, 2020 

Notional amount 
due at contractual 
maturity 

22,448 
19,175 

Fair value 

22,665 
18,073 

Change in 
fair value 
recorded in the 
Consolidated 
Statement of Income (1) 

Change in 
fair value due to own 
credit risk recorded in 
OCI (before tax) 

Cumulative change in 
fair value due to own 
credit risk recorded in 
AOCI (before tax) 

(1,310) 
1,319 

(240) 
(26) 

(408) 
(168) 

N
o
t
e
s

(1)  Change in fair value may be offset by related change in fair value on hedge contracts. 

BMO Financial Group 204th Annual Report 2021  183 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

Note 14: Other Liabilities 
Acceptances 
Acceptances represent a form of negotiable short-term debt that is issued by our customers, which we guarantee for a fee. The fees earned are 
recorded in non-interest revenue, lending fees in our Consolidated Statement of Income over the term of the acceptance. The amount potentially due 
under acceptances is recorded in other liabilities in our Consolidated Balance Sheet. We record the bank’s equivalent claim against our customers in 
the event of a call on these commitments in other assets in our Consolidated Balance Sheet. 

Securities Lending and Borrowing 
Securities lending and borrowing transactions are generally collateralized by securities or cash. Cash advanced or received as collateral is recorded in 
securities borrowed or purchased under resale agreements, or other liabilities, securities lent or sold under repurchase agreements, respectively. 
Interest earned on cash collateral is recorded in interest, dividend and fee income in our Consolidated Statement of Income, and interest expense 
on cash collateral is recorded in interest expense, other liabilities, in our Consolidated Statement of Income. The transfer of the securities to 
counterparties is only reflected in our Consolidated Balance Sheet if the risks and rewards of ownership have also been transferred. Securities 
borrowed are not recognized in our Consolidated Balance Sheet unless they are then sold to third parties, in which case the obligation to return 
the securities is recorded at fair value in securities sold but not yet purchased, with any gains or losses recorded in non-interest revenue, trading 
revenues. 

Securities Sold But Not Yet Purchased 
Securities sold but not yet purchased represent our obligations to deliver securities that we did not own at the time of sale. These obligations are 
recorded at their fair value. Adjustments to the fair value as at the balance sheet date and gains and losses on the settlement of these obligations are 
recorded in trading revenues in our Consolidated Statement of Income. 

Securitization and Structured Entities’ Liabilities 
Securitization and structured entities’ liabilities include notes issued by our consolidated bank securitization vehicles and liabilities associated with the 
securitization of our Canadian mortgage loans as part of the Canada Mortgage Bond program, the National Housing Act Mortgage-Backed Securities 
program and our own programs. Additional information on our securitization programs and associated liabilities is provided in Notes 6 and 7. 
These liabilities are initially measured at fair value plus any directly attributable costs and are subsequently measured at amortized cost. 
The interest expense related to these liabilities is recorded in interest expense, other liabilities, in our Consolidated Statement of Income. 

Other 
The components of other within other liabilities are as follows: 

(Canadian $ in millions) 

Accounts payable, accrued expenses and other items 
Accrued interest payable 
Allowance for credit losses on off-balance sheet items 
Cash collateral 
Insurance-related liabilities 
Lease liabilities 
Other employee future benefits liability (Note 21) 
Payable to brokers, dealers and clients 
Pension liability (Note 21) 

(1)

Total 

2021 

2020 

9,444 
960 
394 
6,733 
12,845 
2,743 
1,094 
3,413 
138 

37,764 

8,208 
1,359 
511 
6,596 
12,441 
2,409 
1,147 
2,969 
553 

36,193 

(1)  Effective November 1, 2019, we adopted IFRS 16 Leases, recognizing the cumulative effect of adoption in opening retained earnings with no changes to prior periods (Note 1). 

Insurance-Related Liabilities 
We are engaged in insurance businesses related to life insurance, annuities, which includes pension risk, accident and sickness, creditor insurance, 
and reinsurance. We designate the obligation related to certain investment contracts in our insurance business at fair value through profit or loss, 
which eliminates a measurement inconsistency that would otherwise arise from measuring the investment contract liabilities and offsetting changes 
in the fair value of the investments supporting them on a different basis. The change in fair value of these investment contract liabilities is recorded 
in insurance claims, commissions and changes in policy benefit liabilities with the exception of changes in our own credit risk recognized in other 
comprehensive income. The impact of changes in our own credit risk is measured based on movements in our own credit spread year over year. 
Changes in the fair value of investments backing these investment contract liabilities are recorded in non-interest revenue, insurance revenue. 

The following table presents fair value and changes in fair value in our investment contract liabilities. 

s
e
t
o
N

(Canadian $ in millions) 

As at October 31, 2021 
As at October 31, 2020 

Notional amount due at 
contractual maturity 

Change in 
fair value 
recorded in the 
Consolidated 
Statement of Income 

Change in 
fair value due to own 
credit risk recorded 
in OCI (before tax) 

Cumulative change in 
fair value due to own 
credit risk recognized 
in AOCI (before tax) 

1,526 
1,594 

(81) 
88 

(26) 
(12) 

(72) 
(46) 

Fair value 

1,046 
1,168 

Insurance claims and policy benefit liabilities represent current claims and estimates of future insurance policy benefit liabilities. Liabilities for life 
insurance contracts are determined using the Canadian Asset Liability Method, which incorporates best-estimate assumptions for mortality, morbidity, 
policy lapses, surrenders, future investment yields, policy dividends, administration costs and margins for adverse deviation. These assumptions are 
reviewed at least annually and updated to reflect actual experience and market conditions. 

184  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
A reconciliation of the change in insurance-related liabilities is as follows: 

(Canadian $ in millions) 

Insurance-related liabilities, beginning of year 

Increase (decrease) in life insurance policy benefit liabilities from: 

New business 
In-force policies 
Changes in actuarial assumptions and methodology 
Foreign currency 

Net increase in life insurance policy benefit liabilities 
Change in other insurance-related liabilities 

Insurance-related liabilities, end of year 

2021 

2020 

12,441 

11,581 

765 
(306) 
(72) 
(2) 

385 
19 

476 
182 
(58) 
– 

600 
260 

12,845 

12,441 

Reinsurance 
In the ordinary course of business, our insurance subsidiaries reinsure risks to other insurance and reinsurance companies in order to provide greater 
diversification, limit loss exposure to large risks, and provide additional capacity for future growth. These ceding reinsurance arrangements do not 
relieve our insurance subsidiaries of their direct obligation to the insured parties. We evaluate the financial condition of the reinsurers and monitor 
their credit ratings to minimize our exposure to losses from reinsurer insolvency. 

Reinsurance premiums ceded are recorded net against direct premium income and are included in non-interest revenue, insurance revenue, in our 
Consolidated Statement of Income for the years ended October 31, 2021, 2020 and 2019, as shown in the table below: 

(Canadian $ in millions) 

Direct premium income 
Ceded premiums 

2021 

2020 

2019 

2,050 
(408) 

1,642 

1,582 
(154) 

1,428 

1,944 
(158) 

1,786 

Lease Liabilities 
Beginning November 1, 2019, when we enter into leases we record lease liabilities representing the present value of future lease payments over the 
lease term. Interest expense recorded on lease liabilities for the year ended October 31, 2021 was $56 million ($53 million in 2020). Total cash outflow 
for lease liabilities for the year ended October 31, 2021 was $383 million ($384 million in 2020). Variable lease payments (for example maintenance, 
utilities and property taxes) not included in the measurement of lease liabilities for the year ended October 31, 2021 were $236 million ($219 million 
in 2020). 

The maturity profile of our undiscounted lease liabilities is $344 million for 2022, $325 million for 2023, $315 million for 2024, $287 million for 

2025, $252 million for 2026 and $1,600 million for 2027 and thereafter. 

Note 15: Subordinated Debt 
Subordinated debt represents our direct unsecured obligations to our debt holders, in the form of notes and debentures, and forms part of our 
regulatory capital. Subordinated debt is recorded at amortized cost using the effective interest rate method. Where appropriate, we enter into fair value 
hedges to hedge the risks caused by changes in interest rates (see Note 8). The rights of the holders of our notes and debentures are subordinate to the 
claims of depositors and certain other creditors. We require approval from OSFI before we can redeem any part of our subordinated debt. 

The face values, terms to maturity and carrying values of our subordinated debt are as follows: 

(Canadian $ in millions, except as noted) 

Face value 

Maturity date 

Interest rate (%) 

Redeemable at our option 

Debentures Series 20 
Series H Medium-Term Notes, Second Tranche (1) 
Series I Medium-Term Notes, First Tranche (1) 
Series I Medium-Term Notes, Second Tranche (1) 
3.803% Subordinated Notes due 2032 (1) 
4.338% Subordinated Notes due 2028 (1) 
Series J Medium-Term Notes, First Tranche (1) 
Series J Medium-Term Notes, Second Tranche (1) 
Series K Medium-Term Notes, First Tranche (1)(9) 

Total (10) 

150 
1,000 
1,250 
850 
US 1,250 
US 850 
1,000 
1,250 
1,000 

December 2025 to 2040 
December 2025 
June 2026 
June 2027 
December 2032 
October 2028 
September 2029 
June 2030 
July 2031 

8.25 
3.34 
3.32 
2.57 
3.80 
4.34 
2.88 
2.08 
1.93 

Not redeemable 
December 2020 (2) 
June 2021 (3) 
June 2022 (4) 
December 2027 (5) 
October 2023 (6) 
September 2024 (7) 
June 2025 (8) 
July 2026 (9) 

2021 
Total 

146 
– 
– 
843 
1,567 
1,096 
998 
1,248 
995 

2020 
Total 

146 
961 
1,242 
833 
1,771 
1,219 
996 
1,248 
– 

6,893 

8,416 

(1)  These notes include a non-viability contingent capital provision, which is necessary for notes issued after a certain date to qualify as regulatory capital under Basel III. As such, they are convertible 

into a variable number of our common shares if OSFI announces that the bank is, or is about to become, non-viable or if a federal or provincial government in Canada publicly announces that the bank 
has accepted or agreed to accept a capital injection, or equivalent support, to avoid non-viability. In such an event, each note is convertible into common shares pursuant to an automatic conversion 
formula with a multiplier and a conversion price based on the greater of: (i) a floor price of $5.00 and (ii) the current market price of our common shares based on the volume weighted average 
trading price of our common shares on the TSX. The number of common shares issued is determined by dividing the par value of the note (including accrued and unpaid interest on such note) by the 
conversion price and then applying the multiplier. 

(2)  All $1,000 million Series H Medium-Term Notes Second Tranche were redeemed on December 8, 2020 for 100% of the principal amount, plus accrued and unpaid interest to, but excluding, the 

redemption date. 

(3)  All $1,250 million Series I Medium-Term Notes First Tranche were redeemed on June 1, 2021 for 100% of the principal amount, plus accrued and unpaid interest to, but excluding, the 

redemption date. 

(4)  Redeemable at the greater of par and the Canada Yield Price prior to June 1, 2022, and redeemable at par together with accrued and unpaid interest to, but excluding, their redemption date 

commencing June 1, 2022. 

(5)  Redeemable at par on December 15, 2027 together with accrued and unpaid interest to, but excluding, the redemption date. 
(6)  Redeemable at par on October 5, 2023 together with accrued and unpaid interest to, but excluding, the redemption date. 
(7)  Redeemable at par on September 17, 2024 together with accrued and unpaid interest to, but excluding, the redemption date. 
(8)  Redeemable at par on June 17, 2025 together with accrued and unpaid interest to, but excluding, the redemption date. 
(9)  On July 22, 2021, we issued $1,000 million of Series K Medium-Term Notes, First Tranche. These notes are redeemable at par on July 22, 2026 together with accrued and unpaid interest to, but 

excluding, the redemption date. 

(10) Certain amounts of subordinated debt were issued at a premium or discount and include fair value hedge adjustments, which together increased their carrying value as at October 31, 2021 by 

$44 million (increased by $119 million in 2020); see Note 8 for further details on hedge adjustments. The carrying value is also adjusted for our subordinated debt holdings, held for market-making 
purposes. 

N
o
t
e
s

BMO Financial Group 204th Annual Report 2021  185 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

The aggregate remaining maturities of our subordinated debt, based on the maturity dates under the terms of issue, can be found in the blue-tinted 
font in the Contractual Maturities of Assets and Liabilities and Off-Balance Sheet Commitments section of Management’s Discussion and Analysis 
within this report. 

Note 16: Equity 
Preferred and Common Shares Outstanding and Other Equity Instruments 

(Canadian $ in millions, except as noted) 

2021 

2020 

Number of 
shares 

Amount 

Dividends declared 
per share 

Number of 
shares 

Amount 

Dividends declared 
per share 

Preferred Shares – Classified as Equity 
Class B – Series 25 
(1)
Class B – Series 26 (1) 
Class B – Series 27 
Class B – Series 29 
Class B – Series 31 
Class B – Series 33 
Class B – Series 35 
(2)
Class B – Series 36 (2) 
Class B – Series 38 
Class B – Series 40 
Class B – Series 42 
Class B – Series 44 
Class B – Series 46 

Preferred Shares – Classified as Equity 
Other Equity Instruments 
4.8% Additional Tier 1 Capital Notes 
4.3% Limited Recourse Capital Notes, Series 1 

Preferred  Shares  and  Other  Equity  Instruments 

Common Shares 
Balance at beginning of year 
Issued under the Shareholder Dividend 

Reinvestment and Share Purchase Plan 

Issued/cancelled under the Stock Option Plan and 
other stock-based compensation plans (Note 20) 
Repurchased for cancellation and/or treasury shares 

sold/purchased (3)(4) 

Balance  at  End  of  Year 

– 
– 
20,000,000 
16,000,000 
12,000,000 
8,000,000 
– 
– 
24,000,000 
20,000,000 
16,000,000 
16,000,000 
14,000,000 

– 
– 
500 
400 
300 
200 
– 
– 
600 
500 
400 
400 
350 

3,650 

658 
1,250 

5,558 

0.45 
0.52 
0.96 
0.91 
0.96 
0.90 
1.25 
58.50 
1.21 
1.13 
1.10 
1.21 
1.28 

0.34 
0.23 
0.96 
0.91 
0.96 
0.76 
– 
– 
1.21 
1.13 
1.10 
1.21 
1.28 

9,425,607 
2,174,393 
20,000,000 
16,000,000 
12,000,000 
8,000,000 
6,000,000 
600,000 
24,000,000 
20,000,000 
16,000,000 
16,000,000 
14,000,000 

236 
54 
500 
400 
300 
200 
150 
600 
600 
500 
400 
400 
350 

4,690 

658 
1,250 

6,598 

645,889,396 

13,430 

639,232,276 

12,971 

– 

– 

1,630,867 

122 

6,746,237 

563,613 

471 

40 

616,209 

47 

(652,730) 

(52) 

648,136,472 

13,599 

4.24 

645,889,396 

13,430 

4.24 

(1)  Series 25 and Series 26 were redeemed and final dividends were paid on August 25, 2021. 
(2)  Series 35 and Series 36 were redeemed and final dividends were paid on November 25, 2020. 
(3)  Common shares are net of 36,521 treasury shares as at October 31, 2021 (652,730 treasury shares as at October 31, 2020). 
(4)  During fiscal 2021 and 2020, we did not purchase any of our common shares under the normal course issuer bid. 

Preferred Share Rights and Privileges 

(Canadian $, except as noted) 

Redemption amount 

Quarterly non-cumulative dividend 

(1)

Reset premium 

Date redeemable / convertible 

Convertible to 

Class B – Series 27 
Class B – Series 29 
Class B – Series 31 
Class B – Series 33 
Class B – Series 38 
Class B – Series 40 
Class B – Series 42 
Class B – Series 44 
Class B – Series 46 

25.00 
25.00 
25.00 
25.00 
25.00 
25.00 
25.00 
25.00 
25.00 

$  0.24075 
$  0.2265 
$0.240688 
$0.190875 
$0.303125 
$  0.28125 
$  0.2750 
$0.303125 
$  0.31875 

(2)

(2)

(2)

(2)

(2)

(2)

(2)

(2)

(2)

2.33% 
2.24% 
2.22% 
2.71% 
4.06% 
3.33% 
3.17% 
2.68% 
3.51% 

May 25, 2024 
(3)(4)
August 25, 2024  (3)(4) 
November 25, 2024  (3)(4) 
August 25, 2025  (3)(4) 
February 25, 2022  (3)(4) 
May 25, 2022  (3)(4) 
August 25, 2022  (3)(4) 
November 25, 2023  (3)(4) 
May 25, 2024  (3)(4) 

Class B – Series 28  (5)(6) 
Class B – Series 30  (5)(6) 
Class B – Series 32  (5)(6) 
Class B – Series 34  (5)(6) 
Class B – Series 39  (5)(6) 
Class B – Series 41  (5)(6) 
Class B – Series 43  (5)(6) 
Class B – Series 45  (5)(6) 
Class B – Series 47  (5)(6) 

(1)  Non-cumulative dividends are payable quarterly as and when declared by the Board of Directors. 
(2)  The dividend rate will reset on the date redeemable and every five years thereafter at a rate equal to the 5-year Government of Canada bond yield plus the reset premium noted. If converted to a 

floating rate series, the rate will be set as, and when declared, at the 3-month Government of Canada treasury bill yield plus the reset premium noted. 

(3)  Redeemable on the date noted and every five years thereafter. 
(4)  Convertible on the date noted and every five years thereafter if not redeemed. If converted, the shares will become floating rate preferred shares. 
(5)  If converted, the holders have the option to convert back to the original preferred shares on subsequent redemption dates. 
(6)  The shares issued include a non-viability contingent capital provision, which is necessary for the shares to qualify as regulatory capital under Basel III. Refer to the Non-Viability Contingent Capital 

paragraph below for details. 

s
e
t
o
N

On August 25, 2021, we redeemed all of our 9,425,607 issued and outstanding Non-Cumulative 5-Year Rate Reset Class B Preferred Shares, Series 25 
for an aggregate total of approximately $236 million and all of our 2,174,393 issued and outstanding Non-Cumulative Floating Rate Class B Preferred 
Shares, Series 26 for an aggregate total of approximately $54 million. 

186  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
On November 25, 2020, we redeemed all of our 6 million issued and outstanding Non-Cumulative Perpetual Class B Preferred Shares, Series 35 

(Non-Viability Contingent Capital (NVCC)) for an aggregate total of $156 million and all of our 600,000 issued and outstanding Non-Cumulative 5-Year 
Rate Reset Class B Preferred Shares, Series 36 (NVCC) for an aggregate total of $600 million. 

Other Equity Instruments 
The $1,250 million 4.3% Limited Recourse Capital Notes Series 1 (LRCN) (NVCC), are classified as equity and form part of our Additional Tier 1 capital. 
Upon the occurrence of a recourse event, the noteholders will have recourse to assets held in a consolidated trust managed by a third-party trustee. 
The trust assets are currently comprised of $1,250 million of BMO issued Non-Cumulative 5-Year Rate Reset Class B Preferred Shares, Series 48 (NVCC) 
(Preferred Shares Series 48) issued concurrently with the LRCN. As the Preferred Shares Series 48 eliminate on consolidation, they do not currently 
form part of our Additional Tier 1 capital. 

The US$500 million 4.8% Additional Tier 1 Capital Notes (AT1 Notes) (NVCC), are also classified as equity and form part of our Additional Tier 1 capital. 
The LRCN and AT1 Notes are compound financial instruments that have both equity and liability features. On the date of issuance, we assigned 

an insignificant value to the liability components of both types of instrument and, as a result, the full amount of proceeds have been classified as 
equity. Semi-annual distributions on the LRCN and AT1 Notes will be recorded when payable. The LRCN and AT1 Notes are subordinate to the claims 
of the depositors and certain other creditors in right of payment. The following table shows the details of our AT1 Notes and LRCN as at October 31, 
2021 and 2020. 

(Canadian $ in millions, except as noted) 

4.8% Additional Tier 1 Capital Notes 

4.3% Limited Recourse Capital Notes 

Total 

Face value 

Interest rate (%) 

Redeemable at our option 

Convertible to 

US$500 

$1,250 

4.8 

(1)

August 2024 

(2)

4.3 

(4)

November 2025 

(2)

Variable number of 
common shares 
(3)
Variable number of 
common shares 
(4)

2021 

Total 

658 

2020 

Total 

658 

1,250 

1,250 

1,908 

1,908 

(1)  Non-cumulative interest is payable semi-annually in arrears, at the bank’s discretion. 
(2)  The notes are redeemable at a redemption price equal to 100% of the principal amount plus any accrued and unpaid interest, in whole or in part, at our option on any interest payment date on or 

after the first interest reset date or following certain regulatory or tax events. The bank may, at any time, purchase the notes at any price in the open market. 

(3)  The notes issued include a non-viability contingent capital provision, which is necessary for the notes to qualify as regulatory capital under Basel III. Refer to the Non-Viability Contingent Capital 

paragraph below for details. 

(4)  Non-deferrable interest is payable semi-annually on these notes, at the bank’s discretion. Non-payment of interest will result in a recourse event, with the noteholders’ sole remedy being the 

holders’ proportionate share of trust assets comprised of our NVCC Preferred Shares Series 48. In such an event, the delivery of the trust assets will represent the full and complete extinguishment of 
our obligations under the LRCN. In circumstances under which non-viability contingent capital, including the Preferred Shares Series 48, would be converted into common shares of the bank 
(described below), the LRCN would be redeemed, and the noteholders’ sole remedy would be their proportionate share of trust assets, then comprised of common shares of the bank received by the 
trust on conversion of the Preferred Shares Series 48. 

Authorized Share Capital 
We classify financial instruments that we issue as financial liabilities, equity instruments or compound instruments. Financial instruments that will 
be settled by a variable number of our common shares upon conversion by the holders are classified as liabilities in our Consolidated Balance Sheet. 
Dividends and interest payments on financial liabilities are classified as interest expense in our Consolidated Statement of Income. Financial 
instruments are classified as equity instruments when there is no contractual obligation to transfer cash or other financial assets. Issued instruments 
that are not mandatorily redeemable, or that are not convertible into a variable number of our common shares at the holder’s option, are classified as 
equity and presented in share capital. Dividend payments on equity instruments are recognized as a reduction in equity. 

Common Shares 
We are authorized by our shareholders to issue an unlimited number of our common shares, without par value, for unlimited consideration. 
Our common shares are not redeemable or convertible. Dividends are declared by our Board of Directors at their discretion. Historically, the 
Board of Directors has declared dividends on a quarterly basis and the amount can vary from quarter to quarter. 

Preferred Shares 
We are authorized by our shareholders to issue an unlimited number of Class A Preferred Shares and Class B Preferred Shares, without par value, 
in series, for unlimited consideration. Class B Preferred Shares may be issued in a foreign currency. 

Treasury Shares 
When we purchase our common shares as part of our trading business, we record the cost of those shares as a reduction in shareholders’ equity. 
If those shares are resold at a price higher than their cost, the premium is recorded as an increase in contributed surplus. If those shares are resold 
at a price below their cost, the discount is recorded as a reduction first to contributed surplus and then to retained earnings for any amount in 
excess of the total contributed surplus related to treasury shares. 

Non-Viability Contingent Capital 
Class B – Series 27, Class B – Series 29, Class B – Series 31, Class B – Series 33, Class B – Series 38, Class B – Series 40, Class B – Series 42, Class B – 
Series 44 and Class B – Series 46 preferred share issues, the AT1 Notes and, by virtue of the recourse to the Preferred Shares Series 48 the LRCN, 
include a non-viability contingent capital provision which is necessary for them to qualify as regulatory capital under Basel III. As such, they are 
convertible into a variable number of our common shares if OSFI announces that the bank is, or is about to become, non-viable or if a federal or 
provincial government in Canada publicly announces that the bank has accepted, or agreed to accept, a capital injection, or equivalent support, to 
avoid non-viability. In such an event, each preferred share or other equity instrument is convertible into common shares pursuant to an automatic 
conversion formula and a conversion price based on the greater of: (i) a floor price of $5.00 and (ii) the current market price of our common shares 
based on the volume weighted average trading price of our common shares on the TSX. The number of common shares issued is determined by 
dividing the value of the preferred share or other equity instrument issuance, including declared and unpaid dividends on such preferred share or 
other equity instrument issuance, by the conversion price and then applying the multiplier. 

BMO Financial Group 204th Annual Report 2021  187 

N
o
t
e
s

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

Normal Course Issuer Bid 
On December 3, 2021, we announced our intention, subject to the approval of OSFI and the Toronto Stock Exchange, to establish a new normal course 
issuer bid (NCIB) for up to 22.5 million common shares. The NCIB is a regular part of our capital management strategy. Once approvals are obtained, 
the share repurchase program will permit us to purchase BMO common shares for the purpose of cancellation. The timing and amount of purchases 
under the NCIB are subject to regulatory approvals and to management discretion, based on factors such as market conditions and capital levels. We 
will consult with OSFI before making purchases under the NCIB. 

We did not renew our NCIB in 2021 as OSFI’s restriction on common share purchases, effective since March 13, 2020, remained in place until 

November 4, 2021. During fiscal 2021, we did not purchase any of our common shares under the prior NCIB. 

Share Redemption and Dividend Restrictions 
OSFI must approve any plan to redeem any of our preferred share issues or other equity instruments for cash. 

We are prohibited from declaring dividends on our preferred or common shares when we would be, as a result of paying such a dividend, in 
contravention of the capital adequacy, liquidity or any other regulatory directive issued under the Bank Act (Canada). In addition, common share 
dividends cannot be paid unless all dividends declared and payable on our preferred shares have been paid or sufficient funds have been set aside to 
do so and, in certain circumstances Class B Preferred Share dividends cannot be paid unless dividends on our Preferred Shares Series 48 have been 
paid. 

In addition, if the bank does not pay the interest in full on the AT1 Notes, the bank will not declare dividends on its common shares or preferred 

shares or redeem, purchase or otherwise retire such shares until the month commencing after the bank resumes full interest payments on the 
AT1 Notes. 

Currently, these limitations do not restrict the payment of dividends on common or preferred shares. 

Shareholder Dividend Reinvestment and Share Purchase Plan 
We offer a Dividend Reinvestment and Share Purchase Plan (DRIP) for our shareholders. Participation in the plan is optional. Under the terms of the 
DRIP, cash dividends on common shares are reinvested to purchase additional common shares. Shareholders also have the opportunity to make 
optional cash payments to acquire additional common shares. 

During fiscal 2021 and the first half of fiscal 2020, common shares to supply the DRIP were purchased on the open market. In the second half of 

fiscal 2020, common shares to supply the dividend reinvestment feature of the DRIP were issued from treasury at a 2% discount from their then-
current market price. 

Potential Share Issuances 
As at October 31, 2021, we had reserved 33,200,910 common shares (33,200,910 as at October 31, 2020) for potential issuance in respect of the 
DRIP. We have also reserved 5,682,206 common shares (6,446,110 as at October 31, 2020) for the potential exercise of stock options, as further 
described in Note 20. 

Note 17: Fair Value of Financial Instruments and Trading-Related Revenue 
We record trading assets and liabilities, derivatives, certain equity and debt securities and securities sold but not yet purchased at fair value, and 
other non-trading assets and liabilities at amortized cost less allowances or write-downs for impairment. The fair values presented in this note are 
based upon the amounts estimated for individual assets and liabilities and do not include an estimate of the fair value of any of the legal entities or 
underlying operations that comprise our business. For certain portfolios of financial instruments where we manage exposures to similar and offsetting 
risks, fair value is determined on the basis of our net exposure to that risk. 

Fair value represents the amount that would be received to sell an asset or paid to transfer a liability in an orderly transaction between willing 
market participants at the measurement date. The fair value amounts disclosed represent point-in-time estimates that may change in subsequent 
reporting periods due to changes in market conditions or other factors. Some financial instruments are not typically exchangeable or exchanged and 
therefore it is difficult to determine their fair value. Where there is no quoted market price, we determine fair value using management’s best 
estimates based on a range of valuation techniques and assumptions; since these involve uncertainties, the fair values may not be realized in an 
actual sale or immediate settlement of the asset or liability. 

Governance Over the Determination of Fair Value 
Senior executive oversight of our valuation processes is provided through various valuation and risk committees. In order to ensure that all financial 
instruments carried at fair value are reasonably measured for risk management and financial reporting purposes, we have established governance 
structures and controls, such as model validation and approval, independent price verification (IPV) and profit or loss attribution analysis (PAA), 
consistent with industry practice. These controls are applied independently of the relevant operating groups. 

We establish valuation methodologies for each financial instrument that is required to be measured at fair value. The application of valuation 
models for products or portfolios is subject to independent approval to ensure only validated models are used. The impact of known limitations of 
models and data inputs is also monitored on an ongoing basis. IPV is a process that regularly and independently verifies the accuracy and 
appropriateness of market prices or model inputs used in the valuation of financial instruments. This process assesses fair values using a variety of 
different approaches to verify and validate the valuations. PAA is a daily process carried out by management to identify and explain changes in fair 
value positions across all operating lines of business within BMO Capital Markets. This process works in concert with other processes to ensure that 
the fair values being reported are reasonable and appropriate. 

s
e
t
o
N

Securities 
For traded securities, quoted market value is considered to be fair value. Quoted market value is based on bid or ask prices, depending on which is 
the most appropriate to measure fair value. Securities for which no active market exists are valued using all reasonably available market information. 
Our fair value methodologies are described below. 

188  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Government Securities 
The fair value of government issued or guaranteed debt securities in active markets is determined by reference to recent transaction prices, broker 
quotes or third-party vendor prices. The fair value of securities that are not traded in an active market is modelled using implied yields derived from 
the prices of similar actively traded government securities and observable spreads. 

Mortgage-Backed Securities and Collateralized Mortgage Obligations 
The fair value of mortgage-backed securities and collateralized mortgage obligations is determined using prices obtained from independent third-
party vendors, broker quotes and relevant market indices, as applicable. If such prices are not available, fair value is determined using cash flow 
models that make maximum use of observable market inputs or benchmark prices for similar instruments. Valuation assumptions for mortgage-
backed securities and collateralized mortgage obligations include discount rates, default rates, expected prepayments, credit spreads and recoveries. 

Corporate Debt Securities 
The fair value of corporate debt securities is determined using prices observed in the most recent transactions. When observable price quotations 
are not available, fair value is determined based on discounted cash flow models using discounting curves and spreads obtained from independent 
dealers, brokers and third-party vendors. 

Trading Loans 
The fair value of trading loans is determined by referring to current market prices for the same or similar instruments. 

Corporate Equity Securities 
The fair value of corporate equity securities is based on quoted prices in active markets, where available. Where quoted prices in active markets are 
not readily available, fair value is determined using either quoted market prices for similar securities or using valuation techniques, which include 
discounted cash flow analysis and earnings multiples. 

Privately Issued Securities 
Privately issued debt and equity securities are valued using prices observed in recent market transactions, where available. Otherwise, fair value is 
derived from valuation models using a market or income approach. These models consider various factors, including projected cash flows, earnings, 
revenue and other third-party evidence, as available. The fair value of our privately issued securities includes net asset values published by third-party 
fund managers as applicable. 

Prices from dealers, brokers and third-party vendors are corroborated as part of our independent review process, which may include using 
valuation techniques or obtaining consensus or composite prices from other pricing services. We validate the estimates of fair value by independently 
obtaining multiple quotes for external market prices and input values. We review the approach taken by third-party vendors to ensure that vendors 
employ a valuation model that maximizes the use of observable inputs such as benchmark yields, bid-ask spreads, underlying collateral, weighted-
average terms to maturity and prepayment rate assumptions. Fair value estimates from internal valuation techniques are verified, where possible, by 
reference to prices obtained from third-party vendors. 

Loans 
In determining the fair value of our fixed rate performing loans, other than credit card loans, we discount the remaining contractual cash flows, 
adjusted for estimated prepayment, at market interest rates currently offered for loans with similar terms and credit risks. For credit card performing 
loans, fair value is considered to be equal to carrying value, due to their short-term nature. 

For floating rate performing loans, changes in interest rates have minimal impact on fair value since interest rates are repriced or reset 

frequently. On that basis, fair value is assumed to be equal to carrying value. 

The fair value of loans is not adjusted for the value of any credit protection purchased to mitigate credit risk. 

Derivative Instruments 
A number of valuation techniques are employed to estimate fair value, including discounted cash flow analysis, the Black-Scholes model, Monte Carlo 
simulation and other accepted market models. These independently validated models incorporate current market data for interest rates, foreign 
currency exchange rates, equity and commodity prices and indices, credit spreads, recovery rates, corresponding market volatility levels, spot prices, 
correlation levels and other market-based pricing factors. Option implied volatilities, an input into many valuation models, are either obtained directly 
from market sources or calculated from market prices. Multi-contributor pricing sources are used wherever possible. 

In determining the fair value of complex and customized derivatives, we consider all reasonably available information, including dealer and broker 
quotations, multi-contributor pricing sources and any relevant observable market inputs. Our models calculate fair value based on inputs specific to the type 
of contract, which may include stock prices, correlation for multiple assets, interest rates, foreign currency exchange rates, yield curves and volatilities. 

We calculate a credit valuation adjustment (CVA) to recognize the credit risk that the bank’s counterparty may not ultimately be able to fulfill its 

derivative obligations. The CVA is derived from market-observed credit spreads or proxy credit spreads and our assessment of the net counterparty 
credit risk exposure, taking into account credit mitigants such as collateral, master netting agreements and novation to central counterparties. We also 
calculate a funding valuation adjustment (FVA) to recognize the implicit funding costs associated with over-the-counter derivative positions. The FVA 
is determined by reference to our own funding spreads. 

Deposits 
In determining the fair value of our deposits, we incorporate the following assumptions: 
•  For fixed rate, fixed maturity deposits, we discount the remaining contractual cash flows related to these deposits, adjusted for expected 

redemptions, at market interest rates currently offered for deposits with similar terms and risks. The fair value of our senior note liabilities and 
covered bonds is determined by referring to current market prices for similar instruments or using valuation techniques, such as discounted cash 
flow models that use market interest rate yield curves and funding spreads. 

•  For fixed rate deposits with no defined maturities, we consider fair value to equal carrying value, since carrying value is equivalent to the amount 

N
o
t
e
s

payable on the reporting date. 

•  For floating rate deposits, changes in interest rates have minimal impact on fair value, since deposits reprice to market frequently. On that basis, 

fair value is considered to equal carrying value. 

BMO Financial Group 204th Annual Report 2021  189 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

Certain of our structured note liabilities that have coupons or repayment terms linked to the performance of interest rates, foreign currencies, 
commodities or equity securities have been designated at fair value through profit or loss. The fair value of these structured notes is estimated using 
internally validated valuation models and incorporates observable market prices for identical or comparable securities, as well as other inputs, such as 
interest rate yield curves, option volatilities and foreign exchange rates, where appropriate. Where observable prices or inputs are not available, 
management judgment is required to determine the fair value by assessing other relevant sources of information, such as historical data and proxy 
information from similar transactions. 

Securities Sold But Not Yet Purchased 
The fair value of these obligations is based on the fair value of the underlying securities, which can be equity or debt securities. As these obligations 
are fully collateralized, the method used to determine fair value would be the same as that used for the relevant underlying equity or debt securities. 

Securitization and Structured Entities’ Liabilities 
The determination of the fair value of our securitization and structured entities’ liabilities is based on quoted market prices or quoted market prices 
for similar financial instruments, where available. Where quoted prices are not available, fair value is determined using valuation techniques, such as 
discounted cash flow models that maximize the use of observable inputs. 

Subordinated Debt 
The fair value of our subordinated debt is determined by referring to current market prices for the same or similar instruments. 

Financial Instruments with a Carrying Value Approximating Fair Value 
Carrying value is considered to be a reasonable estimate of fair value for our cash and cash equivalents. 

The carrying value of certain financial assets and liabilities, such as interest bearing deposits with banks, securities borrowed or purchased under 

resale agreements, customers’ liability under acceptances, other assets, acceptances, securities lent or sold under repurchase agreements and other 
liabilities, is a reasonable estimate of fair value due to their short-term nature or because they are frequently repriced to current market rates. These 
items are therefore excluded from the below table. 

Fair Value Hierarchy 
We use a fair value hierarchy to categorize financial instruments according to the inputs we use in valuation techniques to measure fair value. 

Fair Value of Financial Instruments Not Carried at Fair Value on the Balance Sheet 
Set out in the following tables are the fair values of financial instruments not carried at fair value in our Consolidated Balance Sheet. 

(Canadian $ in millions) 

Securities 
Amortized cost 

(1)

(1)

Loans 
Residential mortgages 
Consumer instalment and other personal 
Credit cards 
Business and government 

(2)

(3)

Deposits 
Securitization and structured entities’ liabilities (4) 
Subordinated debt 

Carrying 
value 

2021 

Fair 
(5)

value 

Carrying 
value 

2020 

Fair 
value (5) 

49,970 

49,810 

48,466 

49,009 

135,653 
76,627 
7,827 
233,066 

453,173 

662,827 
24,631 
6,893 

135,461 
76,791 
7,827 
233,670 

453,749 

663,558 
24,809 
7,087 

126,882 
69,480 
7,556 
238,239 

442,157 

640,961 
26,889 
8,416 

128,815 
70,192 
7,556 
239,929 

446,492 

643,156 
27,506 
8,727 

(1)  Carrying value is net of allowances for credit losses. 
(2)  Excludes $5,022 million of loans classified as FVTPL ($5,306 million as at October 31, 2020) and $134 million of loans classified as FVOCI ($51 million as at October 31, 2020). 
(3)  Excludes $22,665 million of structured note liabilities ($18,073 million as at October 31, 2020) and $139 million of metal deposits ($nil as at October 31, 2020) designated at FVTPL. 
(4)  Excludes $855 million of securitization and structured entities’ liabilities classified at FVTPL ($nil as at October 31, 2020). 
(5)  If financial instruments not carried at fair value were categorized based on the fair value hierarchy, all of these financial instruments would be categorized as Level 2, except for amortized cost 

securities, which would have $14,117 million categorized as Level 1 ($18,831 million as at October 31, 2020), and $35,693 million categorized as Level 2 ($30,178 million as at October 31, 2020). 

Certain comparative figures have been reclassified to conform with the current year’s presentation. 

Valuation Techniques and Significant Inputs 
We determine the fair value of publicly traded fixed maturity debt and equity securities using quoted prices in active markets (Level 1) when these 
are available. When quoted prices in active markets are not available, we determine the fair value of financial instruments using models such as 
discounted cash flows, with observable market data for inputs, such as yield or broker quotes and other third-party vendor quotes (Level 2). Fair value 
may also be determined using models where significant market inputs are not observable due to inactive markets or minimal market activity 
(Level 3). We maximize the use of observable market inputs to the extent possible. 

Our Level 2 trading securities are primarily valued using discounted cash flow models with observable spreads or broker quotes. The fair value of 

Level 2 FVOCI securities is determined using discounted cash flow models with observable spreads or third-party vendor quotes. Level 2 structured 
note liabilities are valued using models with observable market information. Level 2 derivative assets and liabilities are valued using industry-
standard models and observable market information. 

s
e
t
o
N

190  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The extent of our use of actively quoted market prices (Level 1), internal models using observable market information as inputs (Level 2) and models 
without observable market information as inputs (Level 3) in the valuation of securities, business and government loans classified as FVTPL, and 
FVOCI, other assets, fair value liabilities, derivative assets and derivative liabilities is presented in the following table: 

(Canadian $ in millions) 

2021 

Valued using 
quoted market 
prices 

Valued using 
models (with 
observable 
inputs) 

Valued using 
models (without 
observable 
inputs) 

Valued using 
quoted market 
prices 

Total 

Valued using 
models (with 
observable 
inputs) 

Valued using 
models (without 
observable 
inputs) 

2020 

Total 

Trading Securities 
Issued or guaranteed by: 

Canadian federal government 
Canadian provincial and municipal 

governments 

U.S. federal government 
U.S. states, municipalities and agencies 
Other governments 

NHA MBS and U.S. agency MBS and CMO 
Corporate debt 
Trading loans 
Corporate equity 

FVTPL Securities 
Issued or guaranteed by: 

Canadian federal government 
Canadian provincial and municipal 

governments 

U.S. federal government 
Other governments 

NHA MBS and U.S. agency MBS and CMO 
Corporate debt 
Corporate equity 

FVOCI Securities 
Issued or guaranteed by: 

Canadian federal government 
Canadian provincial and municipal 

governments 

U.S. federal government 
U.S. states, municipalities and agencies 
Other governments 

NHA MBS and U.S. agency MBS and CMO 
Corporate debt 
Corporate equity 

Business and Government Loans 

Other Assets (1) 

Fair Value Liabilities 
Securities sold but not yet purchased 
Structured note liabilities (2) 
Other liabilities (3) 

Derivative Assets 
Interest rate contracts 
Foreign exchange contracts 
Commodity contracts 
Equity contracts 
Credit default swaps 

Derivative Liabilities 
Interest rate contracts 
Foreign exchange contracts 
Commodity contracts 
Equity contracts 
Credit default swaps 

3,123 

4,473 

– 

7,596 

6,529 

4,371 

– 

10,900 

2,183 
6,050 
– 
1,307 
– 
2,231 
– 
54,931 

69,825 

3,655 
3,532 
458 
591 
13,379 
7,656 
160 
– 

33,904 

– 
– 
– 
– 
675 
7 
– 
– 

5,838 
9,582 
458 
1,898 
14,054 
9,894 
160 
54,931 

682  104,411 

1,868 
5,702 
16 
1,021 
7 
3,767 
– 
43,757 

62,667 

6,467 
2,716 
487 
1,495 
11,487 
7,274 
67 
– 

34,364 

– 
– 
– 
– 
803 
– 
– 
– 

8,335 
8,418 
503 
2,516 
12,297 
11,041 
67 
43,757 

803 

97,834 

704 

159 

– 

863 

452 

149 

– 

601 

137 
–
–
– 
160 
1,670 

2,671 

1,243 
 38
 92
9 
7,544 
12 

9,097 

– 
–
–
– 
– 
2,442 

1,380 
 38
 92
9 
7,704 
4,124 

2,442 

14,210 

180 
  – 
  – 
– 
70 
1,587 

2,289 

1,249 
44 
94 
3 
7,827 
10 

9,376 

– 
– 
– 
– 
– 
1,903 

1,429 
44 
94 
3 
7,897 
3,500 

1,903 

13,568 

9,138 

3,927 

– 

13,065 

20,765 

1,685 

– 

22,450 

1,438 
18,873 
– 
2,803 
– 
812 
– 

33,064 

– 

4,392 

17,424 
– 
1,106 

18,530 

6 
3 
642 
1,381 
– 

2,032 

6 
4 
746 
1,581 
– 

2,337 

1,549 
2,153 
4,113 
3,699 
12,136 
2,349 
– 

29,926 

5,150 

85 

14,649 
22,665 
2,125 

39,439 

8,066 
14,982 
6,976 
4,657 
– 

34,681 

6,773 
12,451 
1,445 
7,802 
5 

28,476 

– 
– 
1 
– 
– 
– 
132 

133 

6 

– 

– 
– 
– 

– 

– 
– 
– 
– 
– 

– 

– 
– 
– 
– 
2 

2 

2,987 
21,026 
4,114 
6,502 
12,136 
3,161 
132 

63,123 

5,156 

4,477 

32,073 
22,665 
3,231 

57,969 

8,072 
14,985 
7,618 
6,038 
– 

36,713 

6,779 
12,455 
2,191 
9,383 
7 

30,815 

2,604 
14,852 
8 
3,643 
– 
792 
– 

42,664 

– 

6,117 

19,740 
– 
789 

20,529 

13 
1 
123 
750 
– 

887 

22 
3 
350 
456 
– 

831 

2,143 
2,842 
5,267 
3,738 
12,532 
2,442 
– 

30,649 

3,412 

117 

9,636 
18,073 
1,285 

28,994 

14,916 
10,825 
2,465 
7,711 
11 

35,928 

10,871 
10,609 
1,983 
6,067 
10 

29,540 

– 
– 
1 
– 
– 
– 
93 

94 

1,945 

– 

– 
– 
– 

– 

– 
– 
– 
– 
– 

– 

– 
– 
– 
– 
4 

4 

4,747 
17,694 
5,276 
7,381 
12,532 
3,234 
93 

73,407 

5,357 

6,234 

29,376 
18,073 
2,074 

49,523 

14,929 
10,826 
2,588 
8,461 
11 

36,815 

10,893 
10,612 
2,333 
6,523 
14 

30,375 

N
o
t
e
s

(1)  Other assets include precious metals, segregated fund assets in our insurance business and certain receivables measured at fair value. 
(2)  These structured note liabilities included in deposits have been designated at FVTPL. 
(3)  Other liabilities include investment contract and segregated fund liabilities in our insurance business, certain payables and metals deposits that have been designated at FVTPL as well as certain 

securitization and structured entities’ liabilities measured at FVTPL. 

Certain comparative figures have been reclassified to conform with the current year’s presentation. 

BMO Financial Group 204th Annual Report 2021  191 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

Quantitative Information about Level 3 Fair Value Measurements 
The table below presents the fair values of our significant Level 3 financial instruments, the valuation techniques used to determine their fair values 
and the value ranges of significant unobservable inputs used in the valuations. We have not applied any other reasonably possible alternative 
assumptions to the significant Level 3 categories of private equity investments, as the net asset values are provided by the investment or fund 
managers. 

(Canadian $ in millions, except as noted) 

Private equity (2) 

Reporting line in fair value hierarchy table

Corporate equity 

Loans (3) 
NHA MBS and U.S. agency MBS and CMO 

Business and government loans 
NHA MBS and U.S. agency MBS and CMO 

Fair value 
of assets 

Valuation techniques 

2,442 

Net asset value 
EV/EBITDA 
6  Discounted cash flows 
675  Discounted cash flows 

Significant 
unobservable inputs 

Net asset value 
Multiple 
Discount margin 
Prepayment rate 

Market Comparable  Comparability Adjustment (4) 

Private equity (2) 

Corporate equity 

Loans (3) 
NHA MBS and U.S. agency MBS and CMO 

Business and government loans 
NHA MBS and U.S. agency MBS and CMO 

1,903 

Net asset value 
EV/EBITDA 
1,945  Discounted cash flows 
803  Discounted cash flows 

Net asset value 
Multiple 
Discount margin 
Prepayment rate 

Market Comparable  Comparability Adjustment (4) 

2021 

Range of input values (1) 

Low 

na 
6x 
40bps 
4% 
(5.56) 

na 
5x 
65bps 
6% 
(4.93) 

High 

na 
19x 
40bps 
47% 
5.85 

2020 

na 
17x 
141bps 
62% 
5.74 

(1)  The low and high input values represent the highest and lowest actual level of inputs used to value a group of financial instruments in a particular product category. These input ranges do not reflect 

the level of input uncertainty but are affected by the specific underlying instruments within each product category. The input ranges will therefore vary from period to period based on the 
characteristics of the underlying instruments held at each balance sheet date. 

(2)  Included in private equity is $453 million of U.S. Federal Reserve Bank and U.S. Federal Home Loan Bank shares that we carry at cost ($487 million in 2020), which approximates fair value, and are 

held to meet regulatory requirements. 

(3)  The impact of assuming a 10 basis point increase or decrease in discount margin for business and government loans is $nil ($3 million in 2020). 
(4)  Range of input values represents price per security adjustment. 
na  – not applicable 

Significant Unobservable Inputs in Level 3 Instrument Valuations 
Net Asset Value 
Net asset value represents the estimated value of a security based on valuations received from the investment or fund manager. The valuation of 
certain private equity securities is based on the economic benefit we derive from our investment. 

EV/EBITDA Multiple 
The fair value of certain private equity and merchant banking investments is derived by calculating an enterprise value (EV) using the EV/EBITDA 
multiple and then proceeding through a waterfall of the company’s capital structure to determine the value of the assets or securities we hold. The 
EV/EBITDA multiple is determined using judgment in considering factors such as multiples for comparable listed companies, recent transactions and 
company-specific factors, as well as liquidity discounts that account for the lack of active trading in these assets and securities. 

Discount Margin 
Loan and corporate debt yield is the interest rate used to discount expected future cash flows in the valuation model. The discount margin is the 
difference between an instrument’s yield and a benchmark instrument’s yield. Benchmark instruments, such as government bonds, have high credit 
quality ratings and similar maturities. The discount margin therefore represents a market return that accounts for uncertainty in future cash flows. 
Generally, a higher or lower discount margin will result in a lower or higher fair value. 

Prepayment Rates 
Discounted cash flow models are used to fair value our NHA MBS and U.S. agency MBS and CMOs. The cash flow model includes assumptions related 
to conditional prepayment rates, constant default rates and percentage loss on default. Prepayment rates impact our estimate of future cash flows. 
Changes in the prepayment rate tend to be negatively correlated with interest rates. In other words, an increase in the prepayment rate will result in 
a higher fair value when the asset interest rate is lower than the current reinvestment rate. A decrease in the prepayment rate will result in a lower 
fair value when the asset interest rate is higher than the current reinvestment rate. 

Comparability Adjustment 
Market comparable pricing is used to evaluate the fair value of NHA MBS and U.S. agency MBS and CMOs. This technique involves sourcing prices from 
third parties for similar instruments and applying adjustments to reflect recent transaction prices and instrument specific characteristics. 

Significant Transfers 
Our policy is to record transfers of assets and liabilities between fair value hierarchy levels at their fair values as at the end of each reporting period, 
consistent with the date of the determination of fair value. Transfers between the various fair value hierarchy levels reflect changes in the availability 
of quoted market prices or observable market inputs that result from changes in market conditions. Transfers from Level 1 to Level 2 were due to 
reduced observability of the inputs used to value the securities. Transfers from Level 2 to Level 1 were due to increased availability of quoted prices 
in active markets. 

s
e
t
o
N

192  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The following table presents significant transfers between Level 1 and Level 2 for the years ended October 31, 2021 and October 31, 2020. 

(Canadian $ in millions) 

Trading Securities 
FVTPL Securities 
FVOCI Securities 
Securities sold but not yet purchased 

Level 1 to Level 2 

Level 2 to Level 1 

Level 1 to Level 2 

Level 2 to Level 1 

2021 

2020 

7,863 
871 
11,028 
7,764 

11,421 
902 
13,542 
5,950 

6,582 
667 
12,193 
7,781 

5,930 
334 
13,425 
3,871 

Changes in Level 3 Fair Value Measurements 
The tables below present a reconciliation of all changes in Level 3 financial instruments for the years ended October 31, 2021 and 2020, including 
realized and unrealized gains (losses) included in earnings and other comprehensive income as well as transfers into and out of Level 3. Transfers 
from Level 2 to Level 3 were due to an increase in unobservable market inputs used in pricing the securities. Transfers out of Level 3 to Level 2 were 
due to an increase in observable market inputs used in pricing the securities. 

Change in fair value 

Movements 

Transfers 

Balance 
October 31, 
2020 

Included in 
earnings 

Included 
in other 
compre-
hensive 
(1)

income 

Purchases/ 
Issuances 

Sales 

(2)

Maturities/ 
Settlement 

Transfers 
into 
Level 3 

Transfers 
out of 
Level 3 

Fair value as 
at October 31, 
2021 

Change in 
unrealized gains 
(losses) 
recorded in income 
for instruments 
still held (3) 

803 
– 

803 

1,903 

1,903 

1 
93 

94 

1,945 

– 

4 

4 

(222) 
– 

(222) 

315 

315 

(56) 
– 

1,465 
10 

(1,253) 
(3) 

(56) 

1,475 

(1,256) 

(92) 

(92) 

628 

628 

(276) 

(276) 

––
– 

– 

– 

– 

– 

– 

26 

26 

–  
13 

13 

(150) 

1,812 

– 

– 

– 

– 

– 

– 

–
– 

– 

– 

(13) 

– 

– 

– 
– 

– 

(4) 

(4) 

– 
– 

– 

169 
– 

169 

– 

– 

– 
– 

– 

(231) 
– 

(231) 

(32) 

(32) 

–  
– 

– 

(1,302) 

– 

(2,299) 

– 

– 

– 

13 

– 

– 

– 

(2) 

(2) 

675 
7 

682 

2,442 

2,442 

  1
132 

133 

6 

– 

2 

2 

38 
– 

38 

374 

374 

na
na 

na 

– 

– 

– 

– 

For the year ended October 
(Canadian $ in millions) 

31, 2021 

Trading Securities 
NHA MBS and U.S. agency MBS 

and CMO 
Corporate debt 

Total trading securities 

FVTPL Securities 
Corporate equity 

Total FVTPL securities 

FVOCI Securities 
Issued or guaranteed by: 

U.S. states, municipalities 

and agencies 

Corporate equity 

Total FVOCI securities 

Business and Government 

Loans 

Other Liabilities 

Derivative Liabilities 
Credit default swaps 

Total derivative liabilities 

(1)  Foreign exchange translation on trading securities held by foreign subsidiaries is included in other comprehensive income, net foreign operations. 
(2)  Includes proceeds received on securities sold but not yet purchased. 
(3)  Changes in unrealized gains (losses) on FVTPL securities still held on October 31, 2021 are included in earnings for the year. 
Unrealized gains (losses) recognized on Level 3 financial instruments may be offset by (losses) gains on economic hedge contracts. 
na – not applicable 

N
o
t
e
s

BMO Financial Group 204th Annual Report 2021  193 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

Change in fair value 

Movements 

Transfers 

Balance 
October 31, 
2019 

Included in 
earnings 

Included 
in other 
compre-
hensive 
(1)

income 

Purchases/ 
Issuances 

Sales (2) 

Maturities/ 
Settlement 

Transfers 
into 
Level 3 

Transfers 
out of 
Level 3 

Fair value as 
at October 31, 
2020 

Change in 
unrealized gains 
(losses) 
recorded in income 
for instruments 
still held (3) 

For the year ended October 31, 2020 
(Canadian $ in millions) 

Trading Securities 
NHA MBS and U.S. agency MBS 

and CMO 
Corporate debt 

Total trading securities 

FVTPL Securities 
Corporate equity 

Total FVTPL securities 

FVOCI Securities 
Issued or guaranteed by: 

U.S. states, municipalities 

and agencies 

Corporate equity 

Total FVOCI securities 

538 
7 

545 

1,984 

1,984 

1 
81 

82 

(351) 
10 

(341) 

4 

4 

– 
– 

– 

9 
(2) 

7 

17 

17 

– 
1 

1 

1,338 
50 

1,388 

356 

356 

(715) 
(68) 

(783) 

(459) 

(459) 

– 
11 

11 

– 
– 

– 

– 

– 

– 

– 

– 
– 

– 

– 

– 

– 
– 

– 

(1,747) 

– 

– 

– 

225 
3 

228 

(241) 
– 

(241) 

1 

1 

– 
– 

– 

– 

– 

4 

4 

– 

– 

– 
– 

– 

– 

– 

(1) 

(1) 

803 
– 

803 

1,903 

1,903 

1 
93 

94 

1,945 

– 

4 

4 

(232) 
(1) 

(233) 

35 

35 

na 
na 

na 

– 

– 

– 

– 

Business and Government Loans 

1,736 

(3) 

156 

1,803 

Other Liabilities 

Derivative Liabilities 
Credit default swaps 

Total derivative liabilities 

– 

1 

1 

– 

– 

– 

– 

– 

– 

– 

– 

– 

(1)  Foreign exchange translation on trading securities held by foreign subsidiaries is included in other comprehensive income, net foreign operations. 
(2)  Includes proceeds received on securities sold but not yet purchased. 
(3)  Changes in unrealized gains (losses) on trading securities, derivative assets and derivative liabilities still held on October 31, 2020 are included in earnings for the year. 
Unrealized gains (losses) recognized on Level 3 financial instruments may be offset by (losses) gains on economic hedge contracts. 
na – not applicable 

Trading-Related Revenue 
Trading assets and liabilities, including derivatives, securities and financial instruments designated at fair value through profit or loss, are measured 
at fair value, with gains and losses recognized in trading revenues, non-interest revenue, in our Consolidated Statement of Income. Trading-related 
revenue includes net interest income and non-interest revenue and excludes underwriting fees and commissions on securities transactions, which 
are shown separately in our Consolidated Statement of Income. Net interest income arises from interest and dividends related to trading assets and 
liabilities and is reported net of interest expense associated with funding these assets and liabilities in the following table. 

2021 

1,017 
416 
567 
147 
2 

2,149 

1,853 
296 

2,149 

2020 

1,199 
474 
(32) 
271 
34 

1,946 

1,931 
15 

1,946 

2019 

700 
401 
269 
145 
6 

1,521 

1,223 
298 

1,521 

(Canadian $ in millions) 

Interest rates 
Foreign exchange 
Equities 
Commodities 
Other 

Total trading-related revenue 

Reported as: 
Net interest income 
Non-interest revenue – trading revenues 

Total trading-related revenue 

s
e
t
o
N

194  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Note 18: Offsetting of Financial Assets and Financial Liabilities 
Financial assets and financial liabilities are offset and the net amount is reported in our Consolidated Balance Sheet when there is a legally 
enforceable right to offset the recognized amounts and there is an intention to settle on a net basis or realize the asset and settle the liability 
simultaneously. The following table presents the amounts that have been offset in our Consolidated Balance Sheet, including securities purchased 
under resale agreements, securities sold under repurchase agreements and derivative instruments, generally under a market settlement mechanism 
(e.g. an exchange or clearing house) where simultaneous net settlement can be achieved to eliminate credit and liquidity risk between 
counterparties. Also presented are amounts not offset in the Consolidated Balance Sheet related to transactions where a master netting agreement or 
similar arrangement is in place with a right to offset the amounts only in the event of default, insolvency or bankruptcy, or where the offset criteria 
are otherwise not met. 

(Canadian $ in millions) 

Gross 
amounts 

Amounts offset in 
the balance sheet 

Net amounts 
presented in the 
balance sheet 

Impact of 
master netting 
agreements 

Securities 
received/pledged 
as collateral (1)(2) 

Cash 
collateral 

Net 
amount (3) 

Amounts not offset in the balance sheet 

2021 

Financial Assets 
Securities borrowed or purchased under resale 

agreements 

Derivative instruments 

Financial Liabilities 
Derivative instruments 
Securities lent or sold under repurchase agreements 

Financial Assets 
Securities borrowed or purchased under resale 

agreements 

Derivative instruments 

Financial Liabilities 
Derivative instruments 
Securities lent or sold under repurchase agreements 

108,799 
37,054 

145,853 

31,156 
98,973 

130,129 

115,863 
37,164 

153,027 

30,724 
92,643 

123,367 

1,417 
341 

1,758 

341 
1,417 

1,758 

3,985 
349 

4,334 

349 
3,985 

4,334 

107,382 
36,713 

144,095 

30,815 
97,556 

128,371 

111,878 
36,815 

148,693 

30,375 
88,658 

119,033 

15,779 
20,952 

36,731 

20,952 
15,779 

36,731 

17,302 
19,302 

36,604 

19,302 
17,302 

36,604 

90,389 
2,377 

9 
4,823 

92,766 

4,832 

1,865 
81,411 

1,906 
108 

83,276 

2,014 

92,889 
2,816 

95,705 

1,889 
70,693 

72,582 

194 
4,148 

4,342 

3,108 
263 

3,371 

1,205 
8,561 

9,766 

6,092 
258 

6,350 

2020 

1,493 
10,549 

12,042 

6,076 
400 

6,476 

(1)  Financial assets received/pledged as collateral are disclosed at fair value and are limited to the net balance sheet exposure (i.e. any over-collateralization is excluded from the table). 
(2)  Certain amounts of collateral are restricted from being sold or repledged except in the event of default or the occurrence of other predetermined events. 
(3)  Not intended to represent our actual exposure to credit risk. 

Certain comparative figures have been reclassified to conform with the current year’s presentation. 

Note 19: Capital Management 
Our objective is to maintain a strong capital position in a cost-effective structure that: is appropriate given our target regulatory capital ratios and 
internal assessment of required economic capital; underpins our operating groups’ business strategies; supports depositor, investor and regulator 
confidence, while building long-term shareholder value; and is consistent with our target credit ratings. 

Our approach includes establishing limits, targets and performance measures that are used to manage balance sheet positions, risk levels and 

capital requirements, as well as issuing and redeeming capital instruments to achieve a cost-effective capital structure. 

Regulatory capital requirements for the bank are determined in accordance with guidelines issued by OSFI, which are based on the Basel III 
framework developed by the Basel Committee on Banking Supervision. To address the market disruption posed by the COVID-19 pandemic, OSFI 
announced a suite of modifications to capital requirements in fiscal 2020, with those that were temporary in nature being unwound during the course 
of fiscal 2021, except for the temporary exclusion of certain exposures from the Leverage Ratio exposure measures which expires on December 31, 
2021. Refer to the Enterprise-Wide Capital Management section of Management’s Discussion and Analysis within this report for more details. 

Common Equity Tier 1 (CET1) capital is the most permanent form of capital. It is comprised of common shareholders’ equity and may include a 
portion of expected credit loss provisions, less deductions for goodwill, intangible assets and certain other items. Tier 1 capital is primarily comprised 
of CET1 capital, preferred shares and other equity instruments, less regulatory deductions. 

Tier 2 capital is primarily comprised of subordinated debentures and may include a portion of expected credit loss provisions, less regulatory 
deductions. Total capital includes Tier 1 and Tier 2 capital. Details of the components of our capital position are presented in Notes 11, 12, 15 and 16. 

The primary regulatory capital measures are the CET1 Ratio, Tier 1 Capital Ratio, Total Capital Ratio and Leverage Ratio. 
•  Regulatory capital ratios are calculated by dividing CET1, Tier 1 and Total capital by their respective risk-weighted assets. 
•  The Leverage Ratio is defined as Tier 1 capital divided by leverage exposures, which consists of on-balance sheet items and specified off-balance 

sheet items, net of specified adjustments. 

N
o
t
e
s

BMO Financial Group 204th Annual Report 2021  195 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

As at October 31, 2021, we met OSFI’s required target capital ratios, which include a 2.5% Capital Conservation Buffer, a 1.0% Common Equity Tier 1 
Surcharge for domestic systemically important banks, a Countercyclical Buffer and a 2.5% Domestic Stability Buffer. 

Regulatory Capital Measures, Risk-Weighted Assets and Leverage Exposures (1) 

(Canadian $ in millions, except as noted) 

CET1 Capital 
Tier 1 Capital 
Total Capital 
Risk-Weighted Assets 
Leverage Exposures 
CET1 Ratio 
Tier 1 Capital Ratio 
Total Capital Ratio 
Leverage Ratio 

2021 

2020 

44,491 
49,966 
57,201 
325,433 
976,690 
13.7% 
15.4% 
17.6% 
5.1% 

40,077 
45,840 
54,661 
336,607 
953,640 
11.9% 
13.6% 
16.2% 
4.8% 

(1)  Disclosed in accordance with, as applicable, OSFI’s Capital Adequacy Requirements Guideline and Leverage Requirements Guideline. Reflects modifications to capital requirements announced by OSFI 

in response to the COVID-19 pandemic in fiscal 2020, some of which remain in effect in 2021. 

Note 20: Employee Compensation – Share-Based Compensation 
Stock Option Plan 
We maintain a Stock Option Plan for designated officers and employees. Options are granted at an exercise price equal to the closing price of our 
common shares on the day before the grant date. Stock options granted vest in equal tranches of 50% on the third and fourth anniversaries of their 
grant date. Each tranche is treated as a separate award with a different vesting period. In general, options expire 10 years from their grant date. 

We determine the fair value of stock options on their grant date and record this amount as compensation expense over the period that the stock 
options vest, with a corresponding increase to contributed surplus. When these stock options are exercised, we issue shares and record the amount of 
proceeds, together with the amount recorded in contributed surplus, in share capital. The estimated grant date fair value of stock options granted to 
employees who are eligible to retire is expensed at the date of grant. 

The following table summarizes information about our Stock Option Plan: 

(Canadian $, except as noted) 

Outstanding at beginning of year 
Granted 
Exercised 
Forfeited/cancelled 
Expired 

Outstanding at end of year 
Exercisable at end of year 
Available for grant 

2021 

Weighted-
average 
(1)

exercise price 

81.50 
97.14 
67.88 
97.03 
– 

87.79 
77.34 

2020 

Weighted-
average 
exercise price (1) 

76.59 
101.47 
61.89 
97.10 
82.78 

81.50 
69.16 

2019 

Weighted-
average 
exercise price (1) 

72.19 
89.90 
60.21 
98.96 
103.79 

76.59 
64.57 

Number of 
stock options 

6,095,201 
931,047 
902,651 
4,756 
10,534 

6,108,307 
3,507,803 
2,487,645 

Number of 
stock options 

6,108,307 
976,087 
563,613 
34,052 
40,619 

6,446,110 
3,595,744 
13,575,259 

Number of 
stock options 

6,446,110 
984,943 
1,630,867 
117,980 
– 

5,682,206 
2,616,750 
12,708,296 

(1)  The weighted-average exercise prices reflect the conversion of foreign currency denominated options at the exchange rate as at October 31, 2021, 2020 and 2019, respectively. 

For foreign currency denominated options exercised or expired during the year, the weighted-average exercise prices are translated using the exchange rates as at the settlement date and expiry date, 
respectively. 

Employee compensation expense related to this plan for the years ended October 31, 2021, 2020 and 2019 was $10 million, $9 million and 
$9 million, respectively. 

Options outstanding and exercisable at October 31, 2021 by range of exercise price were as follows: 

Options outstanding 

Weighted-
average remaining 
contractual life (years) 

2021 

Options exercisable 

Weighted-average 
exercise price 

Number of 
stock options 

Weighted-average 
exercise price 

0.1 
1.6 
3.7 
7.1 
7.6 

56.00 
64.58 
77.57 
89.90 
99.16 

107,888 
1,065,947 
691,456 
– 
751,459 

56.00 
64.58 
77.57 
– 
98.27

Number of 
stock options 

107,888 
1,065,947 
691,456 
878,372 
2,938,543 

(Canadian $, except as noted) 

Range of exercise prices 

$50.01 to $60.00 
$60.01 to $70.00 
$70.01 to $80.00 
$80.01 to $90.00 
$90.01 and over 

s
e
t
o
N

196  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The following table summarizes additional information about our Stock Option Plan: 

(Canadian $ in millions, except as noted) 

Unrecognized compensation cost for non-vested stock option awards 
Cash proceeds from stock options exercised 
Weighted-average share price for stock options exercised (in dollars) 

2021 

7 
111 
115.42 

2020 

7 
35 
94.44 

2019 

6 
54 
99.84 

The fair value of options granted was estimated using a binomial option pricing model. The weighted-average fair value of options granted during the 
years ended October 31, 2021, 2020 and 2019 was $10.75, $9.46 and $10.23, respectively. To determine the fair value of the stock option tranches 
on the grant date, the following ranges of values were used for each option pricing assumption: 

Expected dividend yield 
Expected share price volatility 
Risk-free rate of return 
Expected period until exercise (in years) 

2021 

2020 

2019 

4.9% 
20.6% – 20.7% 
1.0% 
6.5 – 7.0 

4.3% 
15.4% 
1.9% – 2.0% 
6.5 – 7.0 

5.7% 
20.0% – 20.1% 
2.5% 
6.5 – 7.0 

Changes to the input assumptions can result in different fair value estimates. 

Expected dividend yield is based on market expectations of future dividends on our common shares. Expected share price volatility is determined 

based on the market consensus implied volatility for traded options on our common shares. The risk-free rate is based on the yields of a Canadian 
swap curve with maturities similar to the expected period until exercise of the options. The weighted-average exercise price on the grant date for the 
years ended October 31, 2021, 2020 and 2019 was $97.14, $101.47 and $89.90, respectively. 

Other Share-Based Compensation 
Share Purchase Plans 
We offer various employee share purchase plans. The largest of these plans provides employees with the option of directing a portion of their gross 
salary toward the purchase of our common shares. We match 50% of employee contributions up to 6% of their individual gross salary to a maximum 
of $75,000 ($100,000 prior to December 31, 2020). Our contributions during the first two years vest after two years of participation in the plan, with 
subsequent contributions vesting immediately. The shares held in the employee share purchase plan are purchased on the open market and are 
considered outstanding for purposes of computing earnings per share. The dividends earned on our common shares held by the plan are used to 
purchase additional common shares on the open market. 

We account for our contributions as employee compensation expense when they are contributed to the plan. 
Employee compensation expense related to these plans for the years ended October 31, 2021, 2020 and 2019 was $46 million, $58 million and 

$54 million, respectively. There were 18.0 million, 19.2 million and 18.0 million common shares held in these plans for the years ended 
October 31, 2021, 2020 and 2019, respectively. 

Compensation Trusts 
We sponsor various share ownership arrangements, certain of which are administered through trusts into which our matching contributions are paid. 
We are not required to consolidate our compensation trusts. The assets held by the trusts are not included in our consolidated financial statements. 

Total assets held under our share ownership arrangements amounted to $2,425 million as at October 31, 2021 ($1,523 million as at October 31, 

2020). 

Mid-Term Incentive Plans 
We offer mid-term incentive plans for executives and certain senior employees. Payment amounts are adjusted to reflect reinvested dividends and 
changes in the market value of our common shares. Depending on the plan, the recipient receives either a single cash payment at the end of the 
three-year period of the plan, or cash payments over the three years of the plan. As the awards are cash-settled, they are recorded as liabilities. 
Amounts payable under such awards are recorded as compensation expense over the vesting period. Amounts related to units granted to employees 
who are eligible to retire are expensed at the time of grant. Subsequent changes in the fair value of the liability are recorded in compensation 
expense in the period in which they arise. 

Mid-term incentive plan units granted during the years ended October 31, 2021, 2020 and 2019 totalled 6.4 million, 5.7 million and 6.3 million, 

respectively. 

The weighted-average fair value of these units granted during the years ended 0ctober 31, 2021, 2020 and 2019 was $91.62, $99.59 and 
$98.52, respectively, and we recorded employee compensation expense of $1,234 million, $363 million and $610 million, respectively. We hedge 
the impact of the change in market value of our common shares by entering into total return swaps. We also enter into foreign currency swaps to 
manage the foreign exchange translation from our U.S. businesses. Gains (losses) on total return swaps and foreign currency swaps recognized for 
the years ended October 31, 2021, 2020 and 2019 were $719 million, $(175) million and $20 million, respectively, resulting in net employee 
compensation expense of $515 million, $538 million and $590 million, respectively. 

A total of 17.6 million, 17.0 million and 17.2 million mid-term incentive plan units were outstanding as at October 31, 2021, 2020 and 2019, 

respectively, and the intrinsic value of those awards which had vested was $1,679 million, $1,019 million and $1,251 million, respectively. 

Deferred Incentive Plans 
We offer deferred incentive plans for members of our Board of Directors, executives and key employees in BMO Capital Markets and Wealth 
Management. Under these plans, fees, annual incentive payments and/or commissions can be deferred as share units of our common shares. 
These share units are either fully vested on the grant date or vest at the end of three years. The value of these share units is adjusted to reflect 
reinvested dividends and changes in the market value of our common shares. 

Deferred incentive plan payments are paid in cash upon the participant’s departure from the bank. 
Employee compensation expense for these plans is recorded in the year the fees, incentive payments and/or commissions are earned. 
Changes in the amount of the incentive plan payments as a result of dividends and share price movements are recorded as increases or decreases 
in employee compensation expense in the period of the change. 

BMO Financial Group 204th Annual Report 2021  197 

N
o
t
e
s

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

Deferred incentive plan units granted during the years ended October 31, 2021, 2020 and 2019 totalled 0.4 million, 0.3 million and 0.3 million, 

respectively, and the weighted-average fair value of these units granted during the years ended October 31, 2021, 2020 and 2019 was $113.08, 
$85.47 and $97.27, respectively. 

Liabilities related to these plans are recorded in other liabilities in our Consolidated Balance Sheet and totalled $609 million and $379 million as 

at October 31, 2021 and 2020, respectively. 

Employee compensation expense related to these plans for the years ended October 31, 2021, 2020 and 2019 was $279 million, $(62) million 
and $17 million, respectively. We have entered into derivative instruments to hedge our exposure related to these plans. Changes in the fair value of 
these derivatives are recorded as employee compensation expense in the period in which they arise. Gains (losses) on these derivatives recognized 
for the years ended October 31, 2021, 2020 and 2019 were $271 million, $(67) million and $4 million, respectively. These gains (losses) resulted in 
net employee compensation expense for the years ended October 31, 2021, 2020 and 2019 of $8 million, $5 million and $13 million, respectively. 
A total of 4.6 million, 4.7 million and 4.8 million deferred incentive plan units were outstanding as at October 31, 2021, 2020 and 2019, 

respectively. 

Note 21: Employee Compensation – Pension and Other Employee Future Benefits 
Pension and Other Employee Future Benefit Plans 
We sponsor a number of arrangements globally that provide pension and other employee future benefits to our retired and current employees. 
The largest of these arrangements, by defined benefit obligation, are the primary defined benefit pension plans for employees in Canada and the 
United States and the primary other employee future benefit plan for employees in Canada. 

Pension arrangements include defined benefit pension plans, as well as supplementary arrangements that provide pension benefits in excess of 
statutory limits. Generally, under these plans we provide retirement benefits based on an employee’s years of service and average annual earnings 
over a period of time prior to retirement. Our pension and other employee future benefit expenses, recorded in employee compensation expense, 
mainly comprise the current service cost plus or minus the interest on net defined benefit assets or liabilities. In addition, we provide defined 
contribution pension plans to our employees. The costs of these plans, recorded in employee compensation expense, are equal to our contributions 
to the plans. 

Effective December 31, 2020, the primary defined benefit pension plan for employees in Canada was closed to new employees hired after that 

date. Employees hired or transferred to BMO Canada on or after January 1, 2021 are eligible to participate in a defined contribution pension plan once 
they have completed the waiting period of six months of continuous service. 

We also provide other employee future benefits, including health and dental care benefits and life insurance, for eligible current and retired 

employees. 

Short-term employee benefits, such as salaries, paid absences, bonuses and other benefits, are accounted for on an accrual basis over the period 

in which the employees provide the related services. 

Investment Policy 
The defined benefit pension plans are administered under a defined governance structure, with oversight resting with the Board of Directors. 

The plans are managed under a framework that considers both assets and liabilities in the development of an investment policy and in 
managing risk. Over the past several years, we have implemented a liability-driven investment strategy for the primary Canadian plan to enhance 
risk-adjusted returns while reducing the plan’s surplus volatility. This strategy has reduced the impact of the plan on our regulatory capital. 

The plans invest in asset classes that include equities, fixed income and alternative strategies, under established investment guidelines. 
Plan assets are diversified across asset classes and by geographic exposure. They are managed by asset management firms that are responsible 
for the selection of investment securities. Derivative instruments are permitted under policy guidelines and are generally used to hedge foreign 
currency exposures, manage interest rate exposures or replicate the return of an asset. 

Asset Allocations 
The asset allocation ranges and weighted-average actual asset allocations of our primary pension plans, based on fair market values at October 31, 
are as follows: 

Equities 
Fixed income investments 
Alternative strategies 

Target range 
2021 

20%  –  40% 
40%  –  55% 
10%  –  35% 

Pension benefit plans 

Actual 
2021 

30% 
47% 
23% 

Actual 
2020 

30% 
47% 
23% 

Our pension and other employee future benefit plan assets are measured at fair value on a recurring basis. 

s
e
t
o
N

Risk Management 
The defined benefit pension plans are exposed to various risks, including market risk (interest rate, equity and foreign currency risks), credit risk, 
operational risk, surplus risk and longevity risk. We follow a number of approaches to monitor and actively manage these risks, including: 
•  monitoring surplus-at-risk, which measures a plan’s risk in an asset-liability framework; 
•  stress testing and scenario analyses to evaluate the volatility of the plans’ financial positions and any potential impact on the bank; 
•  hedging of currency exposures and interest rate risk within policy limits; 
•  controls related to asset mix allocations, geographic allocations, portfolio duration, credit quality of debt securities, sector guidelines, 

issuer/counterparty limits and others; and 

•  ongoing monitoring of exposures, performance and risk levels. 

198  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Pension and Other Employee Future Benefit Liabilities 
Our actuaries perform valuations of our defined benefit obligations for pension and other employee future benefits as at October 31 of each year 
using the projected unit credit method based on management’s assumptions about discount rates, rates of compensation increase, retirement age, 
mortality and health care cost trend rates. 

The discount rates for the primary Canadian and U.S. pension and other employee future benefit plans were selected based on the yields of high-

quality AA rated corporate bonds with terms matching the plans’ cash flows. 

The fair value of plan assets is deducted from the defined benefit obligation to determine the net defined benefit asset or liability. For defined 

benefit pension plans that are in a net defined benefit asset position, the recognized asset is limited to the present value of economic benefits 
available in the form of future refunds from the plan or reductions in future contributions to the plan (the “asset ceiling”). Changes in the asset ceiling 
are recognized in other comprehensive income. Components of the change in our net defined benefit assets or liabilities and our pension and other 
employee future benefit expenses are as follows: 

Current service cost represents benefits earned in the current year. The cost is determined with reference to the current workforce and the amount 
of benefits to which employees will be entitled upon retirement, based on the provisions of our benefit plans. 

Interest on net defined benefit asset or liability represents the increase in the net defined benefit asset or liability that results from the passage 
of time and is determined by applying the discount rate to the net defined benefit asset or liability. 

Actuarial gains and losses may arise in two ways. First, each year our actuaries recalculate the defined benefit obligations and compare them to 
those estimated as at the previous year end. Any differences that result from changes in demographic and economic assumptions or from plan 
member experience being different from management’s expectations at the previous year end are considered actuarial gains or losses. Second, 
actuarial gains and losses arise when there are differences between the discount rate and actual returns on plan assets. Actuarial gains and losses 
are recognized immediately in other comprehensive income as they occur and are not subsequently reclassified to income in future periods. 

Plan amendments are changes in our defined benefit obligations that result from changes to provisions of the plans. The effects of plan 
amendments are recognized immediately in income when a plan is amended. 

Settlements occur when defined benefit obligations for plan participants are settled, usually through lump sum cash payments, and as a result 
we no longer have any obligation to provide such participants with benefit payments in the future. 

Funding of Pension and Other Employee Future Benefit Plans 
We fund our defined benefit pension plans in Canada and the United States in accordance with statutory requirements, and the assets in these plans 
are used to pay benefits to retirees and other employees. Some groups of employees are also eligible to make voluntary contributions in order to 
receive enhanced benefits. Our supplementary pension plan in Canada is funded, while the supplementary pension plan in the U.S. is unfunded. 

Our other employee future benefit plans in Canada and the United States are either funded or unfunded. Benefit payments related to these plans 

are paid either through the respective plan or directly by us. 

We measure the fair value of plan assets for our plans in Canada and the United States as at October 31. In addition to actuarial valuations for 
accounting purposes, we are required to prepare valuations for determining our minimum funding requirements for our pension arrangements in 
accordance with the relevant statutory framework (our “funding valuation”). An annual funding valuation is performed for our plans in Canada and 
the United States. The most recent funding valuation for our primary Canadian pension plan was performed as at October 31, 2021 and the most 
recent funding valuation for our primary U.S. pension plan was performed as at January 1, 2021. 

A summary of plan information for the past three years is as follows: 

(Canadian $ in millions) 

Pension benefit plans 

Other employee future benefit plans 

Defined benefit obligation 
Fair value of plan assets 

Surplus (deficit) and net defined benefit asset (liability) 

Surplus (deficit) is comprised of: 

Funded or partially funded plans 
Unfunded plans 

Surplus (deficit) and net defined benefit asset (liability) 

2021 

9,716 
10,525 

809 

939 
(130) 

809 

2020 

10,493 
10,064 

2019 

9,866 
9,723 

2021 

1,220 
166 

2020 

1,290 
181 

2019 

1,254 
175 

(429) 

(143) 

(1,054) 

(1,109) 

(1,079) 

(266) 
(163) 

(429) 

36 
(179) 

(143) 

40 
(1,094) 

(1,054) 

38 
(1,147) 

(1,109) 

46 
(1,125) 

(1,079) 

Pension and Other Employee Future Benefit Expenses 
Pension and other employee future benefit expenses are determined as follows: 

(Canadian $ in millions) 

Pension benefit plans 

Other employee future benefit plans 

2021 

2020 

2019 

2021 

2020 

2019 

Annual benefits expense 
Current service cost 
Net interest (income) expense on net defined benefit (asset) liability 
Past service cost (income) 
Administrative expenses 
Remeasurement of other long-term benefits 

Benefits expense 
Canada and Quebec pension plan expense 
Defined contribution expense 

Total annual pension and other employee future benefit expenses 

recognized in the Consolidated Statement of Income 

268 
7 
– 
5 
– 

280 
90 
160 

530 

249 
1 
– 
5 
– 

255 
87 
169 

511 

193 
(20) 
(5) 
5 
– 

173 
82 
170 

425 

9 
30 
– 
– 
(11) 

28 
– 
– 

28 

11 
32 
– 
– 
10 

53 
– 
– 

53 

9 
37 
– 
– 
6 

52 
– 
– 

52 

N
o
t
e
s

BMO Financial Group 204th Annual Report 2021  199 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

Weighted-Average Assumptions 

Defined Benefit Expenses 
Discount rate at beginning of year (3)(4) 
Rate of compensation increase 
Assumed overall health care cost trend rate 
Defined Benefit Obligation 
Discount rate at end of year 
Rate of compensation increase 
Assumed overall health care cost trend rate 

Pension benefit plans 

Other employee future benefit plans 

2021 

2020 

2019 

2021 

2020 

2019 

2.7% 
2.1% 
na 

3.2% 
2.2% 
na 

3.0% 
2.1% 
na 

2.7% 
2.1% 
na 

4.0% 
2.4% 
na 

3.0% 
2.1% 
na 

2.7% 
2.0% 
4.8% (2) 

3.3% 

na (5) 
4.8% (2) 

3.0% 
2.0% 
4.9% (1) 

2.7% 
2.0% 
4.8% (1) 

4.1% 
2.0% 
4.9% (1) 

3.0% 
2.0% 
4.9% (1) 

(1)  Trending to 4.1% in 2040 and remaining at that level thereafter. 
(2)  Trending to 4.0% in 2041 and remaining at that level thereafter. 
(3)  The pension benefit current service cost was calculated using a separate discount rate of 3.00%, 3.10% and 4.10% for 2021, 2020 and 2019, respectively. 
(4)  The other employee future benefit plans current service cost was calculated using a separate discount rate of 3.00%, 3.20% and 4.20% for 2021, 2020 and 2019, respectively. 
(5)  Rate of compensation increase is na due to new flat dollar retiree plan benefit no longer being dependent on compensation. 
na  – not applicable 

Assumptions regarding future mortality are based on published statistics and mortality tables calibrated to plan experience, when applicable. 
The current life expectancies underlying the amounts of the defined benefit obligations for our primary plans are as follows: 

(Years) 

Canada 

United States 

Life expectancy for those currently age 65 
Males 
Females 
Life expectancy at age 65 for those currently age 45 
Males 
Females 

2021 

23.8 
24.2 

24.8 
25.1 

2020 

23.8 
24.1 

24.7 
25.1 

2021 

21.8 
23.2 

23.0 
24.4 

2020 

21.7 
23.1 

22.9 
24.3 

Changes in the estimated financial positions of our defined benefit pension plans and other employee future benefit plans are as follows: 

Pension benefit plans 

Other employee future benefit plans 

2021 

2020 

2021 

2020 

(Canadian $ in millions, except as noted) 

Defined benefit obligation 
Defined benefit obligation at beginning of year 
Current service cost 
Interest cost 
Benefits paid 
Employee contributions 
Actuarial (gains) losses due to: 

Changes in demographic assumptions 
Changes in financial assumptions 
Plan member experience 
Foreign exchange and other 

Defined benefit obligation at end of year 

Wholly or partially funded defined benefit obligation 
Unfunded defined benefit obligation 

Total defined benefit obligation 

Fair value of plan assets 
Fair value of plan assets at beginning of year 
Interest income 
Return on plan assets (excluding interest income) 
Employer contributions 
Employee contributions 
Benefits paid 
Administrative expenses 
Foreign exchange and other 

Fair value of plan assets at end of year 

Surplus (Deficit) and net defined benefit asset (liability) at end of year 

Recorded in: 
Other assets 
Other liabilities 

s
e
t
o
N

Surplus (Deficit) and net defined benefit asset (liability) at end of year 

Actuarial gains (losses) recognized in other comprehensive income 
Net actuarial gains (losses) on plan assets 
Actuarial gains (losses) on defined benefit obligation due to: 

Changes in demographic assumptions 
Changes in financial assumptions 
Plan member experience 
Foreign exchange and other 

10,493 
268 
269 
(525) 
17 

11 
(700) 
29 
(146) 

9,716 

9,586 
130 

9,716 

10,064 
262 
542 
298 
17 
(525) 
(5) 
(128) 

10,525 

809 

947 
(138) 

809 

542 

(11) 
700 
(29) 
20 

9,866 
249 
286 
(516) 
17 

16 
484 
59 
32 

10,493 

10,330 
163 

10,493 

9,723 
285 
235 
296 
17 
(516) 
(5) 
29 

10,064 

(429) 

124 
(553) 

(429) 

235 

(16) 
(484) 
(59) 
(6) 

(330) 

1,290 
9 
34 
(50) 
5 

(4) 
(89) 
39 
(14) 

1,220 

126 
1,094 

1,220 

181 
4 
(1) 
40 
5 
(50) 
– 
(13) 

166 

1,254 
11 
37 
(48) 
5 

14 
50 
(35) 
2 

1,290 

143 
1,147 

1,290 

175 
5 
6 
36 
5 
(48) 
– 
2 

181 

(1,054) 

(1,109) 

40 
(1,094) 

(1,054) 

38 
(1,147) 

(1,109) 

(1) 

4 
84 
(45) 
– 

42 

6 

(12) 
(45) 
38 
– 

(13) 

Actuarial gains (losses) recognized in other comprehensive income for the year 

1,222 

200  BMO Financial Group 204th Annual Report 2021 

 
Our pension and other employee future benefit plan assets are measured at fair value on a recurring basis. The fair values of plan assets held by our 
primary plans as at October 31, 2021 and 2020 are as follows: 

(Canadian $ in millions) 

Cash and money market funds 
Securities issued or guaranteed by: 
Canadian federal government 
Canadian provincial and municipal governments 
U.S. federal government 

Pooled funds 
Derivative instruments 
Corporate debt 
Corporate equity 

Quoted 

Unquoted 

144 

26 
191 
297 
1,071 
–
3 
1,655 

3,387 

1 

41 
364 
4 
4,014 
 43
1,391 
– 

5,858 

2021 

Total 

145 

67 
555 
301 
5,085 
 43
1,394 
1,655 

9,245 

Quoted 

Unquoted 

208 

17 
308 
393 
1,331 
  1 
2 
1,255 

3,515 

– 

54 
404 
7 
3,442 
(16) 
1,363 
– 

5,254 

2020 

Total 

208 

71 
712 
400 
4,773 
(15) 
1,365 
1,255 

8,769 

No plan assets are directly invested in the bank’s or related parties’ securities as at October 31, 2021 and 2020. As at October 31, 2021 our primary 
Canadian plan indirectly held, through pooled funds, approximately $11 million ($9 million as at October 31, 2020) of our common shares and fixed 
income securities. The plans do not hold any property we occupy or other assets we use. 

Sensitivity of Assumptions 
Key weighted-average assumptions used in measuring the defined benefit obligations for our primary plans are outlined in the following table. 
The sensitivity analysis provided in the table should be used with caution, as it is hypothetical and the impact of changes in each key assumption may 
not be linear. The sensitivities to changes in each key variable have been calculated independently of the impact of changes in other key variables. 
Actual experience may result in simultaneous changes in a number of key assumptions, which would amplify or reduce certain sensitivities. 

(Canadian $ in millions, except as noted) 

Discount rate (%) 
Impact of: 1% increase ($) 
1% decrease ($) 

Rate of compensation increase (%) 
Impact of: 0.25% increase ($) 
0.25% decrease ($) 

Mortality 
Impact of: 1 year shorter life expectancy ($) 
1 year longer life expectancy ($) 

Assumed overall health care cost trend rate (%) 
Impact of: 1% increase ($) 
1% decrease ($) 

(1)  The change in this assumption is immaterial. 
(2)  Trending to 4.0% in 2041 and remaining at that level thereafter. 
na – not applicable 

Maturity Profile 
The duration of the defined benefit obligation for our primary plans is as follows: 

(Years) 

Canadian pension plans 
U.S. pension plans 
Canadian other employee future benefit plans 

Defined benefit obligation 

Pension benefit plans 

Other employee future benefit plans 

3.2 
(1,019) 
1,287 

2.2 
47 
(46) 

(179) 
176 

na 
na 
na 

3.3 
(111) 
133 

na 

–  (1) 
–  (1) 

(29) 
29 

4.8  (2) 
49 
(49) 

2021 

14.5 
9.5 
13.7 

2020 

15.4 
9.9 
14.3 

Cash Flows 
Cash payments we made during the year in connection with our employee future benefit plans are as follows: 

(Canadian $ in millions) 

Pension benefit plans 

Other employee future benefit plans 

Contributions to defined benefit plans 
Contributions to defined contribution plans 
Benefits paid directly to pensioners 

2021 

254 
160 
44 

458 

2020 

251 
169 
45 

465 

2019 

203 
170 
53 

426 

2021 

2020 

2019 

– 
– 
40 

40 

–
–
36 

36 

– 
– 
40 

40 

Our best estimate of the contributions and benefits to be paid directly to pensioners for the year ending October 31, 2022 is approximately $86 million for our defined benefit pension plans and 
$48 million for our other employee future benefit plans. Benefit payments for the year ending October 31, 2022 are estimated to be $542 million. 

N
o
t
e
s

Note 22: Income Taxes 
We report our provision for income taxes in our Consolidated Statement of Income based upon transactions recorded in our consolidated financial 
statements regardless of when they are recognized for income tax purposes, with the exception of repatriation of retained earnings from our 
subsidiaries, as noted below. 

BMO Financial Group 204th Annual Report 2021  201 

 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

In addition, we record an income tax expense or benefit in other comprehensive income or directly in equity when the taxes relate to amounts 

recorded in other comprehensive income or equity. For example, income tax expense (recovery) on hedging gains (losses) related to our net 
investment in foreign operations is recorded in our Consolidated Statement of Comprehensive Income as part of net gains (losses) on translation of 
net foreign operations. 

Current tax is the amount of income tax recoverable (payable) in respect of the taxable loss (profit) for a period. Deferred tax is recognized on 
temporary differences between the carrying amounts of assets and liabilities for accounting and tax purposes. Deferred tax assets and liabilities are 
measured at the tax rates expected to apply when temporary differences reverse. Changes in deferred tax assets and liabilities related to a change in 
tax rates are recorded in income in the period the tax rate is substantively enacted, except to the extent that the tax arises from a transaction or 
event which is recognized either in other comprehensive income or directly in equity. Current and deferred taxes are offset only when they are levied 
by the same tax authority, on the same entity or group of entities, and when there is a legal right to offset. 

Included in deferred tax assets is $nil million ($20 million as at October 31, 2020) related to Canadian tax loss carryforwards and $9 million 

($75 million as at October 31, 2020) related to both U.S. tax loss carryforwards and tax credits that will expire in various amounts in U.S. taxation 
years from 2021 through 2040. On the evidence available, including management projections of income, we believe that it is probable there will be 
sufficient taxable income generated by our business operations to support these deferred tax assets. The amount of tax on temporary differences, 
unused tax losses and unused tax credits for which no deferred tax asset is recognized in our Consolidated Balance Sheet as at October 31, 2021 is 
$118 million ($113 million in 2020), of which $7 million ($7 million in 2020) is scheduled to expire within five years. Deferred tax assets have not 
been recognized in respect of these items because it is not probable that these assets will be realized. 

Income that we earn through our foreign subsidiaries is generally taxed in the foreign country in which they operate. Income that we earn 
through our foreign branches is also generally taxed in the foreign country in which they operate. Canada also taxes the income we earn through 
foreign branches and a credit is allowed for certain foreign taxes paid on such income. Repatriation of earnings from certain foreign subsidiaries 
would require us to pay tax on certain of these earnings. As repatriation of such earnings is not planned in the foreseeable future, we have not 
recorded a related deferred tax liability. The taxable temporary differences associated with the repatriation of earnings from investments in certain 
subsidiaries, branches, associates and interests in joint ventures for which deferred tax liabilities have not been recognized totalled $17 billion as at 
October 31, 2021 ($16 billion in 2020). 

Provision for Income Taxes 

(Canadian $ in millions) 

Consolidated Statement of Income 
Current 

Provision for income taxes for the current period 
Adjustments for prior periods 

Deferred 

Origination and reversal of temporary differences 
Effect of changes in tax rates 

Other Comprehensive Income and Equity 
Income tax expense (recovery) related to: 

Unrealized gains (losses) on FVOCI debt securities 
Reclassification to earnings of (gains) on FVOCI debt securities 
Gains (losses) on derivatives designated as cash flow hedges 
Reclassification to earnings of (gains) losses on derivatives designated as cash flow hedges 
Unrealized gains (losses) on hedges of net foreign operations 
Gains (losses) on remeasurement of pension and other employee future benefit plans 
Gains (losses) on remeasurement of own credit risk on financial liabilities designated at fair value 
Unrealized gains on FVOCI equity securities 
Share-based compensation 

Total provision for income taxes 

Components of Total Provision for Income Taxes 
(Canadian $ in millions) 

s
e
t
o
N

Canada: Current taxes 

Federal 
Provincial 

Canada: Deferred taxes 

Federal 
Provincial 

Total Canadian 

Foreign: Current taxes 

Deferred taxes 

Total foreign 

Total provision for income taxes 

202  BMO Financial Group 204th Annual Report 2021 

2021 

2020 

2019 

2,334 
(14) 

173 
11 

2,504 

(58) 
(14) 
(504) 
(149) 
180 
341 
(70) 
6 
(10) 

(278) 

1,154 
10 

91 
(4) 

1,251 

143 
(25) 
541 
(16) 
(35) 
(88) 
(10) 
–
3

513 

1,198 
(14) 

327 
3 

1,514 

140 
(26) 
521 
51 
(4) 
(196) 
27 
1 
– 

514 

2,226 

1,764 

2,028 

2021 

2020 

2019 

650 
373 

1,023 

233 
134 

367 

694 
402 

1,096 

(11) 
(6) 

(17) 

1,390 

1,079 

940 
(104) 

836 

450 
235 

685 

791 
465 

1,256 

(113) 
(66) 

(179) 

1,077 

308 
643 

951 

2,226 

1,764 

2,028 

 
Set out below is a reconciliation of our statutory tax rates and income taxes that would be payable at these rates to the effective tax rates and 
provision for income taxes that we have recorded in our Consolidated Statement of Income: 

(Canadian $ in millions, except as noted) 

Combined Canadian federal and provincial income taxes at the statutory tax rate 
Increase (decrease) resulting from: 

Tax-exempt income from securities 
Foreign operations subject to different tax rates 
Write-down of goodwill 
Change in tax rate for deferred taxes 
Income attributable to investments in associates and joint ventures 
Other 

Provision for income taxes in the Consolidated Statement of Income 

and effective tax rate 

2021 

2020 

2019 

2,729 

26.6% 

1,688 

26.6% 

1,934 

26.6% 

(232) 
(137) 
202 
11 
(56) 
(13) 

(2.3) 
(1.3) 
2.0 
0.1 
(0.6) 
(0.1) 

(247) 
(175) 
– 
(4) 
(39) 
28 

(3.9) 
(2.8) 
– 
(0.1) 
(0.6) 
0.5 

(220) 
(158) 
– 
3 
(37) 
(8) 

(3.0) 
(2.2) 
– 
– 
(0.5) 
(0.1) 

2,504 

24.4% 

1,251 

19.7% 

1,514 

20.8% 

Components of Deferred Tax Balances 

(Canadian $ in millions) 

Deferred Tax Asset (Liability) 

Allowance for credit losses 
Employee future benefits 
Deferred compensation benefits 
Other comprehensive income 
Tax loss carryforwards 
Tax credits 
Premises and equipment 
Pension benefits 
Goodwill and intangible assets 
Securities 
Other 

Net deferred tax assets (liabilities) 

Comprising 
Deferred tax assets 
Deferred tax liabilities 

Net deferred tax assets (liabilities) 

(Canadian $ in millions) 

Deferred Tax Asset (Liability) 

Allowance for credit losses 
Employee future benefits 
Deferred compensation benefits 
Other comprehensive income 
Tax loss carryforwards 
Tax credits 
Premises and equipment 
Pension benefits 
Goodwill and intangible assets 
Securities 
Other 

Net deferred tax assets (liabilities) 

Comprising 
Deferred tax assets 
Deferred tax liabilities 

Net deferred tax assets (liabilities) 

Net asset, 
October 31, 2020 

Benefit (expense) 
to income statement 

Benefit (expense) 
to equity 

Translation 
and other 

Net asset, 
October 31, 2021 

849 
337 
416 
(358) 
87 
31 
(361) 
78 
(237) 
11 
512 

1,365 

1,473 
(108) 

1,365 

(194) 
2 
270 
– 
(53) 
(31) 
(39) 
104 
(6) 
(62) 
(175) 

(184) 

– 
(9) 
– 
250 
– 
– 
– 
(330) 
– 
– 
10 

(79) 

(4) 
– 
(1) 
– 
– 
– 
– 
– 
2 
– 
(4) 

(7) 

– 

– 

– 

651 
330 
685 
(108) 
34 
– 
(400) 
(148) 
(241) 
(51) 
343 

1,095 

1,287 
(192) 

1,095 

Net asset, 
November 1, 2019 (1) 

Benefit (expense) 
to income statement 

Benefit (expense) 
to equity 

Translation 
and other 

Net asset, 
October 31, 2020 

511 
325 
483 
(143) 
145 
189 
(282) 
27 
(217) 
50 
441 

1,529 

1,589 
(60) 

1,529 

334 
11 
(69) 
– 
(59) 
(189) 
(78) 
(35) 
(18) 
(39) 
55 

(87) 

– 
1 
– 
(218) 
– 
– 
– 
86 
– 
– 
– 

(131) 

4 
– 
2 
3 
1 
31 
(1) 
– 
(2) 
– 
16 

54 

– 

– 

– 

849 
337 
416 
(358) 
87 
31 
(361) 
78 
(237) 
11 
512 

1,365 

1,473 
(108) 

1,365 

(1)  Includes IFRS 16 adoption adjustment of $21 million (refer to Note 1). 

Canadian tax authorities have reassessed us for additional income tax and interest in an amount of approximately $1,210 million, to date, in respect 
of certain 2011 – 2016 Canadian corporate dividends. Those reassessments denied certain dividend deductions on the basis that the dividends were 
received as part of a “dividend rental arrangement”. The tax rules raised by the Canadian tax authorities were prospectively addressed in the 2015 
and 2018 Canadian federal budgets. In October 2021, we filed Notices of Appeal with the Tax Court of Canada and the matter is now in litigation. 
In the future, we expect to be reassessed for significant income tax for similar activities. We remain of the view that our tax filing positions were 
appropriate and intend to challenge all reassessments. However, if such challenges are unsuccessful, the additional expense would negatively impact 
our net income. 

N
o
t
e
s

BMO Financial Group 204th Annual Report 2021  203 

 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

Note 23: Earnings Per Share 
Basic earnings per share is calculated by dividing net income, after deducting dividends payable on preferred shares and distributions payable on 
other equity instruments, by the daily average number of fully paid common shares outstanding throughout the year. 

Diluted earnings per share is calculated in the same manner, with further adjustments made to reflect the dilutive impact of instruments 

convertible into our common shares. 

The following table presents our basic and diluted earnings per share: 

Basic Earnings Per Common Share 
(Canadian $ in millions, except as noted) 

Net income 
Dividends on preferred shares and distributions on other equity instruments 

Net income available to common shareholders 

Weighted-average number of common shares outstanding (in thousands) 

Basic earnings per common share (Canadian $) 

Diluted Earnings Per Common Share 
Net income available to common shareholders adjusted for impact of dilutive instruments 
Weighted-average number of common shares outstanding (in thousands) 
Effect of dilutive instruments 

Stock options potentially exercisable (1) 
Common shares potentially repurchased 

Weighted-average number of diluted common shares outstanding (in thousands) 

Diluted earnings per common share (Canadian $) 

2021 

7,754 
(244) 

7,510 

2020 

5,097 
(247) 

4,850 

2019 

5,758 
(211) 

5,547 

647,163 

641,424 

638,881 

11.60 

7.56 

8.68 

7,510 
647,163 

4,850 
641,424 

5,547 
638,881 

6,403 
(4,890) 

3,433 
(2,729) 

5,326 
(3,847) 

648,676 

642,128 

640,360 

11.58 

7.55 

8.66 

(1)  In computing diluted earnings per share, we did not exclude any stock options outstanding for the year ended October 31, 2021 as the average share price for the year exceeded the exercise price. 

For the years ended October 31, 2020 and 2019, we excluded average stock options outstanding 3,146,040 and 1,177,152 with a weighted-average exercise price of $99.57 and $101.83, respectively, 
as the average share price for the year did not exceed the exercise price. 

Note 24: Commitments, Guarantees, Pledged Assets, Provisions and Contingent Liabilities 
In the normal course of business, we enter into a variety of contracts under which we may be required to make payments to reimburse a counterparty 
for a loss if a third party does not perform according to the terms of a contract or does not make payments when due under the terms of a debt 
instrument, and contracts under which we provide indirect guarantees of the indebtedness of another party, all of which are considered guarantees. 

Guarantees that qualify as derivatives are accounted for in accordance with the policy for derivative instruments (refer to Note 8). For guarantees 

that do not qualify as derivatives, the liability is initially recorded at fair value, which is generally the fee received. Subsequently, guarantees are 
recorded at the higher of the initial fair value, less amortization to recognize any fee income earned over the period, and our best estimate of the 
amount required to settle the obligation. Any change in the liability is reported in our Consolidated Statement of Income. 

We enter into a variety of commitments, including off-balance sheet credit instruments, such as backstop liquidity facilities, securities lending, 

letters of credit, credit default swaps and commitments to extend credit, as a method of meeting the financial needs of our customers. These 
commitments include contracts where we may be required to make payments to a counterparty, based on changes in the value of an asset, liability 
or equity security that the counterparty holds, due to changes in an underlying interest rate, foreign exchange rate or other variable. The contractual 
amount of our commitments represents our maximum undiscounted potential exposure, before possible recoveries under recourse and collateral 
provisions. Collateral requirements for these instruments are consistent with our collateral requirements for loans. 

A large majority of these commitments expire without being drawn upon. As a result, the total contractual amounts may not be representative of 

the funding likely to be required for these commitments. 

We strive to limit credit risk by dealing only with counterparties that we believe are creditworthy, and we manage our credit risk for these 

instruments using the same credit risk process that is applied to loans and other credit assets. 

The maximum amount payable related to our various commitments is as follows: 

(Canadian $ in millions) 

Financial Guarantees 
Standby letters of credit 
Credit default swaps (1) 
Other Credit Instruments 
Backstop liquidity facilities (2) 
Securities lending 
Documentary and commercial letters of credit 
Commitments to extend credit (3) 
Other commitments (4) 

Total 

s
e
t
o
N

2021 

2020 

22,165 
5,158 

12,895 
3,909 
1,481 
174,327 
8,070 

228,005 

23,144 
1,795 

5,601 
4,349 
1,034 
180,384 
5,302 

221,609 

(1)  The fair value of the related derivatives included in our Consolidated Balance Sheet was $(4) million as at October 31, 2021 ($(8) million as at October 31, 2020). 
(2)  Effective October 31, 2021, we deconsolidated our investment in Fairway Financial Company LLC and the total committed undrawn liquidity facility provided to the vehicle was $8,095 million as at 

October 31, 2021. 

(3)  Commitments to extend credit exclude personal lines of credit and credit cards that are unconditionally cancellable at our discretion. 
(4)  Other commitments include $1,649 million as at October 31, 2021 ($1,763 million as at October 31, 2020) of underwriting commitments that are extended but not yet accepted by the borrower. 
Certain comparative figures have been reclassified to conform with the current year’s presentation. 

204  BMO Financial Group 204th Annual Report 2021 

 
Financial Guarantees 
Standby letters of credit represent our obligation to make payments to third parties on behalf of customers if they are unable to make the required 
payments or meet other contractual requirements. The majority have a term of one year or less. Collateral requirements for standby letters of credit 
and guarantees are consistent with our collateral requirements for loans. Standby letters of credit and guarantees include our guarantee of a 
subsidiary’s debt directly provided to a third party. 

Written credit default swaps require us to compensate a counterparty following the occurrence of a credit event in relation to a specified 
reference obligation, such as a bond or a loan. The terms of these contracts range from less than one year to 10 years. Refer to Note 8 for details. 
Other Credit Instruments 
Backstop liquidity facilities are provided to ABCP programs administered by us as an alternative source of financing when ABCP markets cannot be 
accessed. The terms of the backstop liquidity facilities do not require us to advance money to these programs in the event of insolvency of the 
borrower. The average term of these liquidity facilities is approximately 2 to 5 years. 

We lend eligible customers’ securities to third-party borrowers who have been evaluated for credit risk using the same credit risk process that is 

applied to loans and other credit assets. In connection with these activities, we may provide indemnification to clients against losses resulting from 
the failure of the borrower to return loaned securities when due. All borrowings are fully collateralized with cash or marketable securities. 
As securities are loaned, we require borrowers to maintain collateral that is equal to or in excess of 100% of the fair value of the securities 
borrowed. The collateral is revalued on a daily basis. 

Documentary and commercial letters of credit represent our agreement to honour drafts presented by a third party upon completion of specific 

activities. 

Commitments to extend credit represent our commitment to our customers to grant them credit in the form of loans or other financings for 

specific amounts and maturities, subject to their meeting certain conditions. 

Other commitments include commitments to fund external private equity funds and investments in equity and debt securities at market value 

at the time the commitments are drawn. In addition, we act as underwriter for certain new issuances under which we, alone or together with a 
syndicate of financial institutions, purchase the new issue for resale to investors. 
Indemnification Agreements 
In the normal course of operations, we enter into various agreements that provide general indemnifications. These indemnifications typically occu r in 
connection with sales of assets, securities offerings, service contracts, director contracts, membership agreements, clearing arrangements, derivative 
contracts and leasing transactions. Based on historical experience, we expect the risk of loss to be remote. 
Exchange and Clearinghouse Guarantees 
We are a member of several securities and futures exchanges and central counterparties. Membership in certain of these organizations may require 
us to pay a pro rata share of the losses incurred by the organization in the event of default of another member. It is difficult to estimate our 
maximum exposure under these membership agreements, since this would require an assessment of future claims that may be made against us 
that have not yet occurred. Based on historical experience, we expect the risk of material loss to be remote. 
Pledged Assets and Collateral 
In the ordinary course of business, we enter into trading, lending and borrowing activities that require us to pledge assets or provide collateral. 
Pledging and collateral transactions are typically conducted under terms and conditions that are usual and customary to these activities. If there i s no 
default, the securities or their equivalents must be returned by the pledgee upon satisfaction of the obligation. 

The following table summarizes our pledged assets and collateral, and the activities to which they relate: 

(Canadian $ in millions) 

Bank Assets 
Cash and due from banks 
Securities (1) 
Loans 
Other assets 

Third-party Assets (2) 
Collateral received and available for sale or re-pledging 
Less: Collateral not sold or re-pledged 

(Canadian $ in millions) 

Uses of pledged assets and collateral 
Clearing systems, payment systems and depositories 
Foreign governments and central banks 
Obligations related to securities sold short 
Obligations related to securities sold under repurchase agreements 
Securities borrowing and lending (3) 
Derivatives transactions 
Securitization 
Covered bonds 
Other 

Total pledged assets and collateral 

2021 

2020 

110 
82,975 
54,656 
6,436 

111 
75,104 
58,974 
6,344 

144,177 

140,533 

180,705 
(46,278) 

134,427 

278,604 

169,197 
(58,312) 

110,885 

251,418 

2021 

2020 

9,464 
110 
32,073 
87,894 
77,456 
11,439 
26,075 
26,340 
7,753 

7,550 
111 
29,376 
80,962 
58,791 
9,613 
31,417 
25,948 
7,650 

278,604 

251,418 

N
o
t
e
s

(1)  Includes NHA mortgage-backed securities of $4,519 million, which are included in loans in our Consolidated Balance Sheet ($6,121 million as at October 31, 2020). 
(2)  Includes on-balance sheet securities borrowed or purchased under resale agreements and off-balance sheet collateral received. 
(3)  Includes off-balance sheet securities borrowing and lending. 

BMO Financial Group 204th Annual Report 2021  205 

 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

Lease Commitments 
We have entered into a number of non-cancellable leases for premises and equipment. Our computer and software leases are typically fixed 
for one term. Leases that we have signed but have not yet taken possession of, were $248 million as at October 31, 2021 ($991 million as at 
October 31, 2020). 

Provisions and Contingent Liabilities 
Provisions are recognized when we have a legal or constructive obligation as a result of past events, such as contractual commitments, legal or 
other obligations for which we can reliably estimate the obligation, and it is probable we will be required to settle the obligation. We recognize as 
a provision our best estimate of the amount required to settle the obligations as of the balance sheet date, taking into account the risks and 
uncertainties surrounding the obligations. Provisions are recorded in other liabilities on the Consolidated Balance Sheet. Contingent liabilities are 
potential obligations arising from past events, the existence of which will only be confirmed by the occurrence or non-occurrence of one or more 
future events not wholly within our control, and are not included in the table below. 

Legal Proceedings 
The bank and its subsidiaries are party to legal proceedings, including regulatory investigations, in the ordinary course of business. We review the 
status of these proceedings regularly and establish provisions when in our judgment it becomes probable that we will incur a loss and the amount 
can be reliably estimated. The bank’s provisions represent our best estimates based upon currently available information for proceedings for which 
estimates can be made. However, the bank’s provisions may differ significantly from actual losses as a result of, for example, the inherent 
uncertainty of the various potential outcomes of such proceedings; the varying stages of the proceedings; the existence of multiple defendants whose 
share of liability may not yet be determined; unresolved issues in such proceedings, some of which involve novel legal theories and interpretations; 
the fact that the underlying matters will change from time to time; and such proceedings may involve very large or indeterminate damages. While it 
is inherently difficult to predict the ultimate outcome of these proceedings, based on our current knowledge, we do not expect the outcome of any of 
these proceedings, individually or in the aggregate, to have a material adverse effect on the consolidated financial position or the results of 
operations of the bank. However, because of the factors listed above, as well as other uncertainties inherent in litigation and regulatory matters, 
there is a possibility that the ultimate resolution of legal or regulatory investigations may be material to the bank’s consolidated financial position or 
its results of operations for any particular reporting period. 

BMO and its subsidiaries are named as defendants or are otherwise involved in a substantial number of legal proceedings. BMO Harris Bank N.A. 
(BMO Harris), as successor to M&I Marshall and Ilsley Bank (M&I), has been named as the defendant in a lawsuit filed in the U.S. Bankruptcy Court for 
the District of Minnesota (Bankruptcy Court) in connection with a Ponzi scheme carried out by Thomas J. Petters and certain affiliated individuals and 
entities (collectively, Petters) between 1994 and 2008. The lawsuit, brought by a Trustee in bankruptcy proceedings for certain Petters entities, 
alleges that between 1999 and 2008, M&I (and a predecessor bank) facilitated the Ponzi scheme operated by Petters. BMO denies these allegations 
and continues to defend itself vigorously. The Trustee seeks US$1.9 billion in compensatory damages, plus prejudgment interest, punitive damages, 
and attorneys’ fees. The Bankruptcy Court: (i) denied BMO Harris’s motion for summary judgement; (ii) granted the Trustee’s motion for sanctions 
based on the alleged spoliation of evidence; and (iii) transferred the case to the U.S. District Court for the District of Minnesota (District Court) for trial. 
BMO Harris filed an objection to the spoliation sanctions, which is still pending before the District Court. BMO Harris anticipates that the trial in this 
case will take place no earlier than late 2022. 

In June 2021, the Ontario Superior Court approved the settlement of $100 million relating to a class action involving BMO Nesbitt Burns Inc., 

BMO Investorline Inc. and BMO Trust Company regarding disclosures of foreign exchange conversion spreads when converting foreign exchange in 
registered accounts prior to a system change in 2011. 

Restructuring Charges 
Provisions for restructuring charges as at October 31, 2021 are $136 million ($336 million as at October 31, 2020), which include severance-related 
costs to improve efficiency, and accelerate delivery against key bank-wide initiatives focused on digitization, organizational redesign and 
simplification of the way we do business. This represents our best estimate of the amount that will ultimately be paid out. 

Changes in the provision balance during the year were as follows: 

(Canadian $ in millions) 

Balance at beginning of year 
Additional provisions/increase in provisions 
Provisions utilized 
Amounts reversed 
Foreign exchange and other 

Balance at end of year (1) 

(1)  Balance includes severance obligations, restructuring charges and legal provisions. 

2021 

472 
166 
(340) 
(44) 
(6) 

248 

2020 

680 
141 
(334) 
(16) 
1 

472 

s
e
t
o
N

206  BMO Financial Group 204th Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Note 25: Operating and Geographic Segmentation 
Operating Groups 
We conduct our business through three operating groups, each of which has a distinct mandate. We determine our operating groups based on our 
management structure and therefore these groups, and the results attributed to them, may not be comparable with those of other financial services 
companies. We evaluate the performance of our groups using reported and adjusted measures, such as net income, revenue growth, return on equity, 
and non-interest expense-to-revenue (efficiency) ratio, as well as operating leverage. 

Personal and Commercial Banking 
Personal and Commercial Banking (P&C) is comprised of two operating segments: Canadian Personal and Commercial Banking and U.S. Personal and 
Commercial Banking. 

Canadian Personal and Commercial Banking 
Canadian Personal and Commercial Banking (Canadian P&C) provides a full range of financial products and services to eight million customers. 
Personal Banking provides financial solutions through a network of almost 900 branches, contact centres, digital banking platforms and over 3,300 
automated teller machines. Commercial Banking serves clients across Canada and delivers sector and industry expertise, as well as a local presence. 

U.S. Personal and Commercial Banking 
U.S. Personal and Commercial Banking (U.S. P&C) offers a broad range of products and services. Our retail and small and mid-sized business banking 
customers are served through our branches, contact centres, online and mobile banking platforms, and automated banking machines across eight 
states. Commercial Banking serves clients across the United States and delivers sector and industry expertise and local presence. 

BMO Wealth Management 
BMO’s group of wealth management businesses (BMO WM) serves a full range of client segments, from mainstream to ultra high net worth and 
institutional, with a broad offering of wealth management products and services, including insurance products. 

BMO Capital Markets 
BMO Capital Markets (BMO CM) is a North American-based financial services provider offering a complete range of products and services to corporate, 
institutional and government clients. Through our Investment and Corporate Banking and Global Markets lines of business, we operate in 32 locations 
around the world, including 18 offices in North America. 

Corporate Services 
Corporate Services consists of Corporate Units and Technology and Operations (T&O). Corporate Units provide enterprise-wide expertise, governance 
and support in a variety of areas, including strategic planning, risk management, finance, legal and regulatory compliance, human resources, 
communications, marketing, real estate and procurement. T&O develops, monitors, manages and maintains governance of information technology 
including data and analytics, and also provides cyber security and operations services. 

The costs of these Corporate Units and T&O services are largely transferred to the three operating groups (P&C, BMO WM and BMO CM), with any 

remaining amounts retained in Corporate Services results. As such, Corporate Services results largely reflect the impact of residual treasury-related 
activities, the elimination of taxable equivalent adjustments and residual unallocated expenses. 

Basis of Presentation 
The results of these operating groups are based on our internal financial reporting systems. The accounting policies used in these segments are 
generally consistent with those followed in the preparation of our consolidated financial statements, as disclosed in Note 1 and throughout the 
consolidated financial statements. Income taxes presented below may not be reflective of taxes paid in each jurisdiction in which we operate. 
Income taxes are generally applied to each segment based on a statutory tax rate and may be adjusted for items and activities specific to each 
segment. A notable accounting measurement difference is the taxable equivalent basis adjustment, as described below. 

Periodically, certain business lines and units within the business lines are transferred between client and corporate support groups to more 
closely align our organizational structure with our strategic priorities. In addition, revenue and expense allocations are updated to more accurately 
align with current experience. Results for prior periods are restated to conform with the current year’s presentation. 

Taxable Equivalent Basis 
We analyze revenue on a taxable equivalent basis (teb) at the operating group level. Revenue and the provision for income taxes are increased on 
tax-exempt securities to an equivalent before-tax basis to facilitate comparisons of income between taxable and tax-exempt sources. The offset to 
the operating segments’ teb adjustments is reflected in Corporate Services revenue and provision for income taxes. The teb adjustment for the year 
ended October 31, 2021 was $315 million ($335 million in 2020 and $296 million in 2019). 

Inter-Group Allocations 
Various estimates and allocation methodologies are used in the preparation of the operating groups’ financial information. Overhead expenses are 
allocated to operating groups using allocation formulas applied on a consistent basis. Operating group net interest income reflects internal funding 
charges and credits on the groups’ assets, liabilities and capital at market rates, taking into account relevant terms and currency considerations. 
The offset of the net impact of these charges and credits is reflected in Corporate Services. These inter-group allocations are also applied to the 
geographic segmentation. 

N
o
t
e
s

BMO Financial Group 204th Annual Report 2021  207 

 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

Our results and average assets, grouped by operating segment, are as follows: 

(Canadian $ in millions) 

Net interest income (2) 
Non-interest revenue 

Total Revenue 
Provision for (recovery of) credit losses on impaired loans 
Provision for (recovery of) credit losses on performing loans 

Total provision for (recovery of) credit losses 
Insurance claims, commissions and changes in policy benefit liabilities 
Depreciation and amortization 
Non-interest expense 

Income (loss) before taxes 
Provision for (recovery of) income taxes 

Reported net income (loss) 

Average assets (3) 

Net interest income (2) 
Non-interest revenue 

Total Revenue 
Provision for credit losses on impaired loans 
Provision for credit losses on performing loans 

Total provision for credit losses 
Insurance claims, commissions and changes in policy benefit liabilities 
Depreciation and amortization 
Non-interest expense 

Income (loss) before taxes 
Provision for (recovery of) income taxes 

Reported net income (loss) 

Average assets (3) 

Net interest income (2) 
Non-interest revenue 

Total Revenue 
Provision for (recovery of) credit losses on impaired loans 
Provision for (recovery of) credit losses on performing loans 

Total provision for (recovery of) credit losses 
Insurance claims, commissions and changes in policy benefit liabilities 
Depreciation and amortization 
Non-interest expense 

Income (loss) before taxes 
Provision for (recovery of) income taxes 

Reported net income (loss) 

Average assets (3) 

U.S. P&C 

BMO WM 

BMO CM 

Corporate 
Services (1) 

Canadian 
P&C 

6,561 
2,225 

8,786 
493 
(116) 

377 
– 
526 
3,511 

4,372 
1,135 

3,237 

4,268 
1,243 

5,511 
22 
(166) 

(144) 
– 
487 
2,310 

2,858 
669 

2,189 

982 
6,071 

7,053 
4 
(16) 

(12) 
1,399 
283 
3,433 

1,950 
476 

1,474 

3,115 
3,011 

6,126 
11 
(205) 

(194) 
– 
269 
3,167 

2,884 
744 

2,140 

2021 
Total 

14,310 
12,876 

27,186 
525 
(505) 

20 
1,399 
1,565 
13,944 

10,258 
2,504 

(616) 
326 

(290) 
(5) 
(2) 

(7) 
– 
– 
1,523 

(1,806) 
(520) 

(1,286) 

7,754 

262,953 

129,009 

48,232  372,475 

168,471 

981,140 

Canadian 
P&C 

6,105 
1,930 

8,035 
787 
623 

1,410 
– 
517 
3,375 

2,733 
706 

2,027 

U.S. P&C 

BMO WM 

BMO CM 

Corporate 
Services (1) 

4,345 
1,186 

5,531 
418 
441 

859 
– 
563 
2,512 

1,597 
320 

1,277 

900 
5,808 

6,708 
4 
18 

22 
1,708 
295 
3,224 

1,459 
363 

1,096 

3,320 
2,006 

5,326 
310 
349 

659 
– 
243 
2,993 

1,431 
344 

1,087 

(699) 
285 

(414) 
3 
– 

3 
– 
– 
455 

(872) 
(482) 

(390) 

2020 
Total 

13,971 
11,215 

25,186 
1,522 
1,431 

2,953 
1,708 
1,618 
12,559 

6,348 
1,251 

5,097 

251,471 

137,644 

45,573 

369,518 

138,244 

942,450 

Canadian 
P&C 

5,885 
2,099 

7,984 
544 
63 

607 
– 
355 
3,481 

3,541 
917 

2,624 

U.S. P&C 

BMO WM 

BMO CM 

Corporate 
Services (1) 

4,216 
1,162 

5,378 
160 
37 

197 
– 
459 
2,677 

2,045 
434 

1,611 

935 
6,727 

7,662 
2 
(2) 

– 
2,709 
230 
3,293 

1,430 
371 

1,059 

2,390 
2,369 

4,759 
52 
28 

80 
– 
161 
3,118 

1,400 
309 

1,091 

(538) 
238 

(300) 
(7) 
(5) 

(12) 
– 
– 
856 

(1,144) 
(517) 

(627) 

2019 
Total 

12,888 
12,595 

25,483 
751 
121 

872 
2,709 
1,205 
13,425 

7,272 
1,514 

5,758 

237,742 

126,539 

40,951 

342,626 

85,394 

833,252 

(1)  Corporate Services includes Technology and Operations. 
(2)  Operating groups report on a taxable equivalent basis – see Basis of Presentation section. 
(3)  Included within average assets are average earning assets, which are comprised of deposits with other banks, deposits at central banks, reverse repos, loans and securities. Total average earning 

assets for 2021 are $897,302, including $248,215 for Canadian P&C, $122,166 for U.S. P&C, and $526,921 for all other operating segments including Corporate (2020 - Total: $853,336, Canadian P&C: 
$234,953, U.S. P&C: $130,190 and all other operating segments: $488,193; 2019 - Total: $759,395, Canadian P&C: $222,260, U.S. P&C: $119,640 and all other operating segments: $417,495). 

Certain comparative figures have been reclassified to conform with the current year’s presentation. 

s
e
t
o
N

208  BMO Financial Group 204th Annual Report 2021 

 
Geographic Information 
We operate primarily in Canada and the United States, but we also have operations in the United Kingdom, Europe, the Caribbean and Asia, which are 
grouped in other countries in the table below. We allocate our results by geographic region based on the location of the unit responsible for 
managing the related assets, liabilities, revenues and expenses. 

Our results and average assets, grouped by geographic region, are as follows: 

(Canadian $ in millions) 

Total Revenue 
Income (loss) before taxes 
Reported net income (loss) 
Average Assets 

Total Revenue 
Income before taxes 
Reported net income 
Average Assets 

Total Revenue 
Income before taxes 
Reported net income 
Average Assets 

Canada 

United States 

Other countries 

2021 

Total 

15,983 
6,242 
4,809 
544,652 

14,515 
3,815 
3,021 
522,155 

14,998 
4,218 
3,313 
462,427 

9,242 
4,224 
3,254 
376,102 

8,659 
1,891 
1,554 
361,651 

8,282 
2,367 
1,903 
316,983 

1,961 
(208) 
(309) 
60,386 

27,186 
10,258 
7,754 
981,140 

2,012 
642 
522 
58,644 

2,203 
687 
542 
53,842 

2020 

25,186 
6,348 
5,097 
942,450 

2019 

25,483 
7,272 
5,758 
833,252 

N
o
t
e
s

BMO Financial Group 204th Annual Report 2021  209 

 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 

Note 26: Significant Subsidiaries 
As at October 31, 2021, the bank, either directly or indirectly through its subsidiaries, controls the following significant operating subsidiaries. 

Significant subsidiaries (1)(2) 

Bank of Montreal (China) Co. Ltd. 
Bank of Montreal Europe plc 
Bank of Montreal Holding Inc. and subsidiaries, including: 

Bank of Montreal Mortgage Corporation 

BMO Mortgage Corp. 
BMO Investments Limited 

BMO Reinsurance Limited 

BMO Nesbitt Burns Holdings Corporation 

BMO Nesbitt Burns Inc. 

BMO Investments Inc. 
BMO InvestorLine Inc. 
BMO Capital Markets Limited 
BMO Financial Corp. and subsidiaries, including: 

BMO Asset Management Corp. and subsidiaries 
BMO Capital Markets Corp. 
BMO Family Office, LLC 
BMO Harris Bank National Association and subsidiaries, including: 

BMO Harris Investment Company LLC 
BMO Harris Financing, Inc. and subsidiaries 
BMO Global Asset Management (Asia) Limited (3) 
BMO Global Asset Management (Europe) Limited and subsidiaries (3), including: 

BMO Asset Management (Holdings) plc and subsidiaries (3) 

BMO Life Insurance Company and subsidiaries, including: 

BMO Life Holdings (Canada), ULC 
BMO Life Assurance Company 

BMO Trust Company 
LGM Investments Limited (3) 
Pyrford International Limited (3) 

Head or principal office 

Beijing, China 
Dublin, Ireland 
Toronto, Canada 
Calgary, Canada 
Vancouver, Canada 
Hamilton, Bermuda 
St. Michael, Barbados 
Toronto, Canada 
Toronto, Canada 
Toronto, Canada 
Toronto, Canada 
London, England 
Chicago, United States 
Chicago, United States 
New York, United States 
Palo Alto, United States 
Chicago, United States 
Chicago, United States 
Chicago, United States 
Hong Kong, China 
London, England 
London, England 
Toronto, Canada 
Halifax, Canada 
Toronto, Canada 
Toronto, Canada 
London, England 
London, England 

Book value of shares owned by the 
bank (Canadian $ in millions) 

411 
1,001 
35,384 

310 
26,775 

395 

1,369 

589 
39 
73 

(1)  Each subsidiary is incorporated or organized under the laws of the state or country in which the principal office is situated, except for BMO Financial Corp., BMO Asset Management Corp., BMO Capital 

Markets Corp., BMO Harris Financing, Inc., and BMO Family Office, LLC, which are incorporated under the laws of the state of Delaware, United States. BMO Asset Management (Holdings) plc is 
incorporated under the laws of Scotland. BMO Harris Investment Company LLC is organized under the laws of the state of Nevada, United States. 
(2)  Unless otherwise noted, the bank, either directly or indirectly through its subsidiaries, owns 100% of the outstanding voting shares of each subsidiary. 
(3)  These subsidiaries are part of the sale of our EMEA asset management business which was completed on November 8, 2021. Refer to Note 10 for further information. 

Significant Restrictions 
Our ability to transfer funds between our subsidiaries may be restricted by statutory, contractual, capital and regulatory requirements. 
Restrictions include: 
•  Assets pledged as security for various liabilities we incur. Refer to Note 24 for details. 
•  Assets of our consolidated structured entities that are held for the benefit of the note holders. Refer to Note 7 for details. 
•  Assets held by our insurance subsidiaries. Refer to Note 12 for details. 
•  Regulatory and statutory requirements that reflect capital and liquidity requirements. 
•  Funds required to be held with central banks. Refer to Note 2 for details. 

s
e
t
o
N

210  BMO Financial Group 204th Annual Report 2021 

 
Note 27: Related Party Transactions 
Related parties include subsidiaries, joint ventures, associates, employee future benefit plans and key management personnel and their close family 
members. Close family members include spouses, common-law partners and dependent minors. Transactions with our subsidiaries are eliminated on 
consolidation, and are not disclosed as related party transactions. 

Key Management Personnel Compensation 
Key management personnel is defined as those persons having authority and responsibility for planning, directing and/or controlling the activitie s of 
an entity, being the members of our Board of Directors (directors) and certain senior executives. 

The following table presents the compensation of our key management personnel: 

(Canadian $ in millions) 

Base salary and incentives 
Post-employment benefits 
Share-based payments (1) 

Total key management personnel compensation 

(1)  Amounts included in share-based payments are the fair values of awards granted in the year. 

2021 

2020 

2019 

22 
3 
32 

57 

20 
3 
32 

55 

22 
2 
43 

67 

We offer senior executives market interest rates on credit card balances, a fee-based subsidy on annual credit card fees, and a select suite of 
customer loan and mortgage products at rates normally accorded to preferred customers. At October 31, 2021, loans to key management personnel 
totalled $22 million ($19 million in 2020). We have no provision for credit losses related to these amounts as at October 31, 2021 and 2020. 

Directors receive a specified amount of their annual retainer in deferred stock units. Until a director’s shareholdings (including deferred stock 
units) are eight times greater than their annual retainer, they are required to take 100% of their annual retainer and other fees in the form of either 
our common shares or deferred stock units. Once the shareholding requirements have been met, directors may elect to receive the remainder of such 
retainer fees and other remuneration in cash, common shares or deferred stock units. 

Directors of our wholly owned subsidiary, BMO Financial Corp., are required to take a specified minimum amount of their annual retainer and 

other fees in the form of deferred stock units. 

Joint Ventures and Associates 
We provide banking services to our joint ventures and associates on the same terms offered to our customers for these services. 

The following table presents the carrying amount of our interests in joint ventures and associates accounted for under the equity method as well as 
our share of the income of those entities: 

(Canadian $ in millions) 

Carrying amount 
Share of net income 

We do not have any joint ventures or associates that are individually material to our consolidated financial statements. 

The following table presents transactions with our joint ventures and associates: 

(Canadian $ in millions) 

Loans 
Deposits 
Fees paid for services received 
Guarantees and commitments 

Certain comparative figures have been reclassified to conform with the current year’s presentation. 

Joint ventures 

Associates 

2021 

474 
107 

2020 

412 
99 

2021 

661 
141 

2021 

791 
117 
59 
73 

2020 

573 
62 

2020 

560 
124 
63 
57 

N
o
t
e
s

BMO Financial Group 204th Annual Report 2021  211 

 
Where to Find More Information 

Corporate Governance 
Our website provides information on our 
corporate governance practices, including our 
code of conduct, our director independence 
standards and our board mandate and 
committee charters. 

www.bmo.com/corporategovernance 

Management Proxy Circular 
Our management proxy circular contains  
information on our directors, board committee 
reports and a detailed discussion of our corporate 
governance practices. It will be published in 
March 2022 and will be available on our website. 

www.bmo.com/corporategovernance 

Stock Exchange  
Governance Requirements 
A summary of the significant ways in which 
our corporate governance practices differ 
from the corporate governance practices 
required for U.S. domestic companies under 
New York Stock Exchange Listing Standards  
and NASDAQ Stock Market Rules is posted  
on our website. 

www.bmo.com/corporategovernance 

Sustainability Performance 
BMO’s Sustainability Report and Public 
Accountability Statement (PAS) outlines 
the way we govern, manage, measure and 
disclose the environmental and social risks  
and opportunities related to our business,  
while creating value for our many stakeholders. 
We use the Global Reporting Initiative (GRI) 
Standards as a framework for reporting on our 
sustainability performance, along with other 
internationally recognized standards, including 
those issued by the Sustainability Accounting 
Standards Board (SASB). The 2021 Sustainability 
Report/PAS will be available on our website  
in March 2022. 

www.bmo.com/corporateresponsibility 

Have Your Say 
If you have a question you would like to ask  
at our annual meeting of shareholders, you 
can submit your question during the webcast. 
You can also submit a question to the board  
by writing to the Corporate Secretary at 
Corporate Secretary’s Office, 21st Floor,  
1 First Canadian Place, Toronto, ON  M5X 1A1,  
or by emailing corp.secretary@bmo.com. 

212  BMO Financial Group 204th Annual Report 2021 

Shareholders 
Contact our Transfer Agent and Registrar 
for:• Dividend information 
• Change in share registration or address 
• Lost certificates 
• Estate transfers 
• Duplicate mailings 
• Direct registration 

Computershare Trust Company of Canada 
100 University Avenue, 8th Floor, Toronto, ON  M5J 2Y1 
Email: service@computershare.com 

www.computershare.com/ca/en 

Canada and the United States 
Call: 1-800-340-5021  Fax: 1-888-453-0330 

International 
Call: 514-982-7800  Fax: 416-263-9394 

Computershare Trust Company, N.A. 
Co-Transfer Agent (U.S.) 

Computershare Investor Services PLC is the 
Transfer Agent and Registrar for common shares  
in Bristol, United Kingdom 

Online filing information: 

BMO filings in Canada 
Canadian Securities Administrators 

www.sedar.com 

BMO filings in the United States 
Securities and Exchange Commission 

www.sec.gov/edgar.shtml 

For all other shareholder inquiries: 

Shareholder Services 
BMO Financial Group  
Corporate Secretary’s Office  
21st Floor, 1 First Canadian Place  
Toronto, ON  M5X 1A1 
Email: corp.secretary@bmo.com 
Call: 416-867-6785  Fax: 416-867-6793 

Institutional Investors 
and Research Analysts 
To obtain additional financial information: 

Investor Relations Department 
BMO Financial Group  
10th Floor, 1 First Canadian Place  
Toronto, ON  M5X 1A1 
Email: investor.relations@bmo.com 

Employees 
For information on BMO’s Employee Share  
Ownership Plan: 

Call: 1-877-266-6789 

General 
To obtain printed copies of the  
annual report or make inquiries  
about company news and initiatives: 

Corporate Communications Department 
BMO Financial Group  
100 King Street West, 28th floor 
Toronto, ON  M5X 1A1 

On peut obtenir sur demande  
un exemplaire en français. 

www.bmo.com 

Customers 
For assistance with your investment portfolio  
or other financial needs: 

BMO Bank of Montreal 
English and French: 1-877-225-5266 
Cantonese and Mandarin: 1-800-665-8800 
Outside Canada and the continental United States: 
514-881-3845 
TTY service for hearing impaired customers:  
1-866-889-0889 

www.bmo.com 

BMO InvestorLine: 1-888-776-6886 

www.bmoinvestorline.com 

BMO Harris Bank 
United States: 1-888-340-2265 
Outside the United States: 1-847-238-2265 

www.bmoharris.com 

BMO Nesbitt Burns: 416-359-4000 

www.bmonesbittburns.com 

The following are trademarks of Bank of Montreal or its subsidiaries: 
BMO and the M-bar roundel symbol; BMO Capital Markets; BMO Financial Group; BMO Global Asset Management; 
BMO Harris Bank; Harris Bank; BMO Wealth Management; Boldly Grow the Good; BMO CashTrack; BMO Institute for 
Learning; BMO Payment Hub; BMO Insights; Online Banking for Business; BMO Climate Institute; BMO Business 
Xpress; adviceDirect; BMO EMpower; and InvestorLine. 

The following are trademarks owned by other parties: 
Bloomberg is a trademark of Bloomberg Finance L.P.; The Wall Street Journal is a trademark of Dow Jones & 
Company, Inc.; World’s Most Ethical Companies is a trademark of Ethisphere, LLC; Corporate Knights is a trademark 
of Corporate Knights Inc.; Dow Jones Sustainability is a trademark of S&P Dow Jones Indices LLC; Forbes is a 
trademark of Forbes LLC; Blend is a trademark of Blend Labs, Inc.; FedNow is a service mark of the Federal Reserve 
Banks; The American Business Awards is a trademark of Stevie Awards, Inc.; International Business Awards is a 
trademark of Stevie Awards, Inc.; Sandstorm Gold Royalties is a trademark of Sandstorm Gold Ltd. 

 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Shareholder Information 

Market for Shares of Bank of Montreal 

The common shares of Bank of Montreal are listed on the Toronto Stock Exchange (TSX) and  
New York Stock Exchange (NYSE). The preferred shares of Bank of Montreal are listed on the TSX. 

Common Share Trading in Fiscal 2021 

Primary stock  
exchanges 

TSX 
NYSE 

Ticker 

BMO 
BMO 

Closing price  
October 31, 2021  

High  

Low  

$134.37  
US$108.51 

$137.98  
US$111.48  

$76.03  
US$57.25  

Total volume of  
shares traded 

615.6 million 
50.8 million 

Common Share History 

Date  

March 14, 2001 
March 20, 1993 
June 23, 1967 

Action  

Common share effect 

100% stock dividend 
100% stock dividend 
Stock split 

Equivalent to a 2-for-1 stock split 
Equivalent to a 2-for-1 stock split 
5-for-1 stock split 

Important Dates 

Fiscal Year End 
Annual Meeting  

October 31 
 April 13, 2022 | 9:30 a.m. ET 

Further details will be made available on our website: 

www.bmo.com/investorrelations 

2022 Dividend Payment Dates* 

Common and preferred 
shares record dates 

February 1  
May 2 
August 2 
November 1 

Common shares 
payment dates 

February 28  
May 26 
August 26 
November 28 

Preferred shares 
payment dates 

February 25  
May 25 
August 25 
November 25 

*Subject to approval by the Board of Directors. 

The Bank Act prohibits a bank from declaring or paying a dividend if it is or would thereby be in 
contravention of regulations or an order from the Office of the Superintendent of Financial Institutions 
dealing with adequacy of capital or liquidity. Currently, this limitation does not restrict the payment of 
dividends on Bank of Montreal’s common or preferred shares. 

Managing Your Shares 

Our  Transfer  Agent and Registrar  
Computershare Trust Company of Canada serves  
as Transfer Agent and Registrar for common  
and preferred shares, with transfer facilities in 
Montreal, Toronto, Calgary and Vancouver.  
Computershare Investor Services PLC and 
Computershare Trust Company, N.A. serve as 
Transfer Agents and Registrars for common  
shares in Bristol, United Kingdom and Canton,  
Massachusetts, respect ively. See previous 
page for contact information. 

m
o
c
.
n
g
i
s
e
d
e
v
o
w
w
w

.

n
g
i
s
e
D

|

d
n
a
r
B
e
v
O

:

n
g
i
s
e
d

c
i
g
e
t
a
r
t
S

Reinvesting Your Dividends and  
Purchasing Additional Common Shares 
Through the Shareholder Dividend  
Reinvestment and Share Purchase Plan,  
you can reinvest cash dividends from your 
BMO common shares to purchase additional 
BMO common shares without paying a 
commission or service charge. You can also 
purchase additional common shares in 
amounts up to $40,000 per fiscal year. 
Contact Computershare Trust Company of 
Canada or Shareholder Services for details.  

Your vote  
matters. 
Watch for your  
proxy circular  
in March and 
remember to 
vote. 

Employee Ownership* 
84.7% of our Canadian employees 
participate in the BMO Employee Share 
Ownership Plan – a clear indication of 
their commitment to BMO. 
*As at October 31, 2021. 

Credit Ratings 
Credit rating information appears on page 101 
of this annual report and on our  website. 

www.bmo.com/creditratings 

Direct Deposit 
You can choose to have your dividends deposited  
directly to an account in any financial institution  
in Canada or the United States that provides 
electronic funds transfer services. 

Personal Information Security 
We advise our shareholders to be diligent in 
protecting their personal information. Details 
are available on our  website. 

www.bmo.com/security 

Auditors KPMG LLP 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
To find out more 
about who we are, 
what we do, and 
what matters to us, 
visit us at: 

bmo.com/about 
@BMO 
@lifeatBMO 

Recognition means 
we’re on the right path 

Forbes Magazine: 
The World’s Best 
Banks 

2021 | 2020 

Recognized by customers 
as one of the best banks 
in North America. 

Ethisphere®: 
World’s Most Ethical 
Companies® 

2021 | 2020 | 2019 | 2018 

Included for four years in 
a row, and one of just five 
banks worldwide on the 
2021 list. 

Bloomberg  
Gender-Equality 
Index 

2021 | 2020 | 2019 | 2018 | 
2017 | 2016 

Six consecutive years 
on this prestigious list 
in recognition of our 
commitment to gender 
equality. 

Dow Jones 
Sustainability Index 

2006 to 2021 

Included for 16 years,  
in 2021 we were one of 
only five companies in 
Canada to appear in the 
DJSI World Index. 

Insider Intelligence: 
2021 Canada Mobile 
Banking Benchmark 

2021 

Ranked #1 for digital 
money management, 
security and card controls, 
mobile banking alerts. 

Corporate Knights: 
Global 100  
Most Sustainable 
Corporations in  
the World 

2021 | 2020 

Recognized as the most 
sustainable bank in North 
America two years in a row.