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Morgan Stanley

ms · NYSE Financial Services
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FY2019 Annual Report · Morgan Stanley
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Table of Contents

 UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM 10-K 
ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934
For the year ended December 31, 2019 
Commission File Number 1-11758 

(Exact name of Registrant as specified in its charter)

Delaware
(State or other jurisdiction of
incorporation or organization)

1585 Broadway
New York, NY 10036
(Address of principal executive
offices, including zip code)

Securities registered pursuant to Section 12(b) of the Act:

Title of each class

Common Stock, $0.01 par value

36-3145972
(I.R.S. Employer Identification No.)

(212) 761-4000
(Registrant’s telephone number,
including area code)

Trading
Symbol(s)

MS

Name of exchange on 
which registered

New York Stock Exchange

Depositary Shares, each representing 1/1,000th interest in a share of Floating Rate

Non-Cumulative Preferred Stock, Series A, $0.01 par value

MS/PA

New York Stock Exchange

Depositary Shares, each representing 1/1,000th interest in a share of Fixed-to-Floating Rate

Non-Cumulative Preferred Stock, Series E, $0.01 par value

MS/PE

New York Stock Exchange

Depositary Shares, each representing 1/1,000th interest in a share of Fixed-to-Floating Rate

Non-Cumulative Preferred Stock, Series F, $0.01 par value

MS/PF

New York Stock Exchange

Depositary Shares, each representing 1/1,000th interest in a share of Fixed-to-Floating Rate

Non-Cumulative Preferred Stock, Series I, $0.01 par value

MS/PI

New York Stock Exchange

Depositary Shares, each representing 1/1,000th interest in a share of Fixed-to-Floating Rate

Non-Cumulative Preferred Stock, Series K, $0.01 par value

MS/PK

New York Stock Exchange

Depositary Shares, each representing 1/1,000th interest in a share of 4.875%

Non-Cumulative Preferred Stock, Series L, $0.01 par value 

Global Medium-Term Notes, Series A, Fixed Rate Step-Up Senior Notes Due 2026

of Morgan Stanley Finance LLC (and Registrant’s guarantee with respect thereto)

Market Vectors ETNs due March 31, 2020 (two issuances)

Market Vectors ETNs due April 30, 2020 (two issuances)

Morgan Stanley Cushing® MLP High Income Index ETNs due March 21, 2031

MS/PL

New York Stock Exchange

MS/26C

URR/DDR

CNY/INR

MLPY

New York Stock Exchange

NYSE Arca, Inc.

NYSE Arca, Inc.

NYSE Arca, Inc.

Indicate by check mark if Registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act.  Yes  ý No  ¨

Indicate by check mark if Registrant is not required to file reports pursuant to Section 13 or 15(d) of the Act.  Yes  ¨  No  ý

Indicate by check mark whether Registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the
preceding 12 months (or for such shorter period that Registrant was required to file such reports), and (2) has been subject to such filing requirements for the past
90 days.  Yes  ý  No  ¨

Indicate by check mark whether the Registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of Regulation
S-T during the preceding 12 months (or for such shorter period that the Registrant was required to submit such files).  Yes  ý  No  ¨

Indicate by check mark whether the Registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting company or an emerging
growth company. See the definitions of “large accelerated filer,” “accelerated filer,” “smaller reporting company” and “emerging growth company” in Rule 12b-2 of
the Exchange Act. (Check one):

Large accelerated filer

ý

Accelerated filer ¨

Non-accelerated filer ¨

Smaller reporting company ¨

Emerging growth company ¨

If an emerging growth company, indicate by check mark if the Registrant has elected not to use the extended transition period for complying with any new or revised
financial accounting standards provided pursuant to Section 13(a) of the Exchange Act.                ¨

Indicate by check mark whether Registrant is a shell company (as defined in Exchange Act Rule 12b-2).  Yes  ¨  No  ý

As of June 30, 2019, the aggregate market value of the common stock of Registrant held by non-affiliates of Registrant was approximately $69,733,657,018. This
calculation does not reflect a determination that persons are affiliates for any other purposes.

As of January 31, 2020, there were 1,599,276,515 shares of Registrant’s common stock, $0.01 par value, outstanding.

Documents Incorporated by Reference: Portions of Registrant’s definitive proxy statement for its 2020 annual meeting of shareholders are incorporated by reference
in Part III of this Form 10-K.

Table of Contents

ANNUAL REPORT ON FORM 10-K
For the year ended December 31, 2019 

Table of Contents
Business

Overview

Business Segments

Competition

Supervision and Regulation

Information about our Executive Officers

Risk Factors

Selected Financial Data

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Introduction

Executive Summary

Business Segments

Supplemental Financial Information

Other Matters

Accounting Development Updates

Critical Accounting Policies

Liquidity and Capital Resources

Balance Sheet

Regulatory Requirements

Quantitative and Qualitative Disclosures about Risk

Risk Management

Market Risk

Credit Risk

Country and Other Risks

Financial Statements and Supplementary Data

Report of Independent Registered Public Accounting Firm

Consolidated Income Statements

Consolidated Comprehensive Income Statements

Consolidated Balance Sheets

Consolidated Statements of Changes in Total Equity

Consolidated Cash Flow Statements

Notes to Consolidated Financial Statements

1. Introduction and Basis of Presentation

2. Significant Accounting Policies

3. Fair Values

4. Fair Value Option

5. Derivative Instruments and Hedging Activities

6. Investment Securities

7. Collateralized Transactions

8. Loans, Lending Commitments and Allowance for Credit Losses

9. Goodwill and Intangible Assets

i

Part

Item Page

I

1

1A

6

7

II

7A

8

1

1

1

1

2

9

11

23

24

24

25

29

40

40

41

42

44

44

50

58

58

61

65

70

75

75

77

78

79

80

81

82

82

83

93

103

104

109

112

114

117

Table of Contents

Table of Contents

Part

Item Page

10. Other Assets—Equity Method Investments and Leases

11. Deposits

12. Borrowings and Other Secured Financings

13. Commitments, Guarantees and Contingencies

14. Variable Interest Entities and Securitization Activities

15. Regulatory Requirements

16. Total Equity

17. Interest Income and Interest Expense

18. Deferred Compensation Plans and Carried Interest Compensation

19. Employee Benefit Plans

20. Income Taxes

21. Segment, Geographic and Revenue Information

22. Parent Company

23. Quarterly Results (Unaudited)

24. Subsequent Event

Financial Data Supplement (Unaudited)

Glossary of Common Terms and Acronyms

Changes in and Disagreements with Accountants on Accounting and Financial Disclosure

Controls and Procedures

Other Information

Unresolved Staff Comments

Properties

Legal Proceedings

Mine Safety Disclosures

Market for Registrant’s Common Equity, Related Stockholder Matters and Issuer Purchases of

Equity Securities

Directors, Executive Officers and Corporate Governance

Executive Compensation

Security Ownership of Certain Beneficial Owners and Management and Related Stockholder

Matters

Certain Relationships and Related Transactions and Director Independence

Principal Accountant Fees and Services

Exhibits and Financial Statement Schedules

Form 10-K Summary

Signatures

118

119

119

121

126

131

133

136

136

138

142

143

146

148

150

151

155

157

157

159

159

159

159

163

164

164

164

164

165

165

165

169

S-1

9

9A

9B

1B

2

3

4

5

10

11

12

13

14

15

16

I

II

III

IV

ii

Table of Contents

Forward-Looking Statements

We have included in or incorporated by reference into this report, and from time to time may make in our public filings, press releases
or other public statements, certain statements, including (without limitation) those under “Management’s Discussion and Analysis of
Financial Condition and Results of Operations”, “Quantitative and Qualitative Disclosures about Risk” and “Legal Proceedings” that
may constitute “forward-looking statements” within the meaning of the safe harbor provisions of the Private Securities Litigation Reform
Act of 1995. In addition, our management may make forward-looking statements to analysts, investors, representatives of the media
and others. These forward-looking statements are not historical facts and represent only our beliefs regarding future events, many of
which, by their nature, are inherently uncertain and beyond our control.

The  nature  of  our  business  makes  predicting  the  future  trends  of  our  revenues,  expenses,  and  net  income  difficult.  The  risks  and
uncertainties involved in our businesses could affect the matters referred to in such statements, and it is possible that our actual results
may differ, possibly materially, from the anticipated results indicated in these forward-looking statements. Important factors that could
cause actual results to differ from those in the forward-looking statements include (without limitation):

• the effect of market conditions, particularly in the global equity, fixed income, currency, credit and commodities markets, including

corporate and mortgage (commercial and residential) lending and commercial real estate and energy markets;

• the level of individual investor participation in the global markets as well as the level of client assets;
• the flow of investment capital into or from assets under management or supervision;
• the level and volatility of equity, fixed income and commodity prices, interest rates, inflation and currency values and other market

indices;

• the availability and cost of both credit and capital as well as the credit ratings assigned to our unsecured short-term and long-term

debt;

• technological changes instituted by us, our competitors or counterparties and technological risks, business continuity and related
operational risks, including breaches or other disruptions of our or a third party’s (or third parties thereof) operations or systems;

• risk associated with cybersecurity threats, including data protection and cybersecurity risk management;
• our ability to manage effectively our capital and liquidity, including non-objections to our capital plans by our banking regulators;
• the impact of current, pending and future legislation or changes thereto, regulation (including capital, leverage, funding, liquidity and

recovery and resolution requirements) and our ability to address such requirements; 

• uncertainty concerning fiscal or monetary policies established by central banks and financial regulators, government shutdowns, debt

ceilings or funding;

• changes to global trade policies, tariffs, interest rates, reforms of LIBOR and other interest rate benchmarks; 
• legal and regulatory actions, including litigation and enforcement, in the U.S. and worldwide;
• changes in tax laws and regulations globally;
• the effectiveness of our risk management processes;
• our ability to effectively respond to an economic downturn, or other market disruptions;
• the effect of social, economic and political conditions and geopolitical events, including the U.K.’s withdrawal from the E.U. ("Brexit"),

and sovereign risk; 

• the actions and initiatives of current and potential competitors as well as governments, central banks, regulators and self-regulatory

organizations;

• our ability to provide innovative products and services and execute our strategic initiatives, and costs related thereto, including with

respect to the operational or technological integration related to such innovative and strategic initiatives;

• the performance and results of our acquisitions, divestitures, joint ventures, strategic alliances, or other strategic arrangements and

related integrations;

• investor, consumer and business sentiment and confidence in the financial markets;
• our reputation and the general perception of the financial services industry;
• climate-related incidents, pandemics and acts of war or terrorism; and
• other risks and uncertainties detailed under “Business—Competition”, “Business—Supervision and Regulation”, “Risk Factors” and

elsewhere throughout this report.

Accordingly, you are cautioned not to place undue reliance on forward-looking statements, which speak only as of the date on which
they  are  made.  We  undertake  no  obligation  to  update  publicly  or  revise  any  forward-looking  statements  to  reflect  the  impact  of
circumstances or events that arise after the dates they are made, whether as a result of new information, future events or otherwise except
as required by applicable law. You should, however, consult further disclosures we may make in future filings of our annual reports on
Form 10-K, quarterly reports on Form 10-Q and current reports on Form 8-K and any amendments thereto or in future press releases
or other public statements.

iii

Table of Contents

Available Information

We file annual, quarterly and current reports, proxy statements and other information with the SEC. The SEC maintains a website,
www.sec.gov, that contains annual, quarterly and current reports, proxy and information statements and other information that issuers
file electronically with the SEC. Our electronic SEC filings are available to the public at the SEC’s website.

Our website is www.morganstanley.com. You can access our Investor Relations webpage at www.morganstanley.com/about-us-ir.
We make available free of charge, on or through our Investor Relations webpage, our proxy statements, annual reports on Form 10-
K, quarterly reports on Form 10-Q, current reports on Form 8-K and any amendments to those reports filed or furnished pursuant to
the  Securities  Exchange Act  of  1934,  as  amended  (“Exchange Act”),  as  soon  as  reasonably  practicable  after  such  material  is
electronically filed with, or furnished to, the SEC. We also make available, through our Investor Relations webpage, via a link to the
SEC’s website, statements of beneficial ownership of our equity securities filed by our directors, officers, 10% or greater shareholders
and others under Section 16 of the Exchange Act.

You can access information about our corporate governance at www.morganstanley.com/about-us-governance and our sustainability
initiatives at www.morganstanley.com/about-us/sustainability-at-morgan-stanley. Our webpages include:

• Amended and Restated Certificate of Incorporation;
• Amended and Restated Bylaws;
• Charters  for  our  Audit  Committee,  Compensation,  Management  Development  and  Succession  Committee,  Nominating  and

Governance Committee, Operations and Technology Committee, and Risk Committee;

• Corporate Governance Policies;
• Policy Regarding Corporate Political Activities;
• Policy Regarding Shareholder Rights Plan;
• Equity Ownership Commitment;
• Code of Ethics and Business Conduct;
• Code of Conduct;
• Integrity Hotline Information; 
• Environmental and Social Policies; and
• Sustainability Report.

Our Code of Ethics and Business Conduct applies to all directors, officers and employees, including our Chief Executive Officer,
Chief Financial Officer and Deputy Chief Financial Officer. We will post any amendments to the Code of Ethics and Business Conduct
and any waivers that are required to be disclosed by the rules of either the SEC or the New York Stock Exchange LLC (“NYSE”)
on  our  website.  You  can  request  a  copy  of  these  documents,  excluding  exhibits,  at  no  cost,  by  contacting  Investor  Relations,
1585 Broadway, New York, NY 10036 (212-761-4000). The information on our website is not incorporated by reference into this
report.

iv

Table of Contents

Business

Overview

We  are  a  global  financial  services  firm  that,  through  our
subsidiaries  and  affiliates,  advises,  and  originates,  trades,
manages and distributes capital for, governments, institutions
and individuals. We were originally incorporated under the laws
of the State of Delaware in 1981, and our predecessor companies
date back to 1924. We are an FHC regulated by the Board of
Governors of the Federal Reserve System (“Federal Reserve”)
under  the  Bank  Holding  Company Act  of  1956,  as  amended
(“BHC Act”). We conduct our business from our headquarters
in and around New York City, our regional offices and branches
throughout the U.S. and our principal offices in London, Tokyo,
Hong  Kong  and  other  world  financial  centers.  As  of
December 31,  2019,  we  had  60,431  employees  worldwide.
Unless  the  context  otherwise  requires,  the  terms  “Morgan
Stanley,”  the  “Firm,”  “us,”  “we,”  and  “our”  mean  Morgan
Stanley (the “Parent Company”) together with its consolidated
subsidiaries.  See  the  “Glossary  of  Common  Terms  and
Acronyms” for the definition of certain terms and acronyms used
throughout the 2019 Form 10-K.

Financial information concerning us, our business segments and
geographic regions for each of the years ended December 31,
2019, December 31, 2018 and December 31, 2017 is included
in “Financial Statements and Supplementary Data.”

Business Segments

We are a global financial services firm that maintains significant
market  positions 
in  each  of  our  business  segments—
Institutional  Securities,  Wealth  Management  and  Investment
Management.  Through  our  subsidiaries  and  affiliates,  we
provide a wide variety of products and services to a large and
including
diversified  group  of  clients  and  customers, 
corporations,  governments, 
and
individuals.  Additional  information  related  to  our  business
segments, respective clients, and products and services provided
is included under “Management’s Discussion and Analysis of
Financial Condition and Results of Operations.”

institutions 

financial 

Competition

All aspects of our businesses are highly competitive, and we
expect them to remain so. We compete in the U.S. and globally
for clients, market share and human talent. Operating within the
financial services industry on a global basis presents, among
other  things,  technological,  risk  management,  regulatory  and
other  infrastructure  challenges  that  require  effective  resource
allocation in order for us to remain competitive. Our competitive
position  depends  on  a  number  of  factors,  including  our
reputation,  the  quality  and  consistency  of  our  long-term
investment  performance,  innovation,  execution  and  relative
pricing.  Our  ability  to  sustain  or  improve  our  competitive
position also depends substantially on our ability to continue to

attract and retain highly qualified employees while managing
compensation  and  other  costs. We  compete  with  commercial
banks,  brokerage  firms,  insurance  companies,  exchanges,
electronic  trading  and  clearing  platforms,  financial  data
repositories, sponsors of mutual funds, hedge funds and private
equity funds, energy companies, financial technology firms and
other companies offering financial or ancillary services in the
U.S., globally and digitally, including through the internet. In
addition, restrictive laws and regulations applicable to certain
financial  services  institutions,  which  may  prohibit  us  from
engaging  in  certain  transactions  and  impose  more  stringent
capital and liquidity requirements, can put us at a competitive
disadvantage to competitors in certain businesses not subject to
these  same 
requirements.  See  also  “Supervision  and
Regulation” herein and “Risk Factors.”

Institutional Securities and Wealth Management

We  compete  directly  in  the  U.S.  and  globally  with  other
securities and financial services firms and broker-dealers and
with others on a regional or product basis. Additionally, there is
increased competition driven by established firms as well as the
emergence  of  new  firms  and  business  models  (including
innovative uses of technology) competing for the same clients
and assets or offering similar products and services to customers.

Our  ability  to  access  capital  at  competitive  rates  (which  is
generally  impacted  by  our  credit  ratings),  to  commit  and  to
deploy capital efficiently, particularly in our capital-intensive
underwriting and sales, trading, financing and market-making
activities,  also  affects  our  competitive  position.  We  expect
corporate clients to continue to request that we provide loans or
lending  commitments  in  connection  with  certain  investment
banking activities.

It is possible that competition may become even more intense
as we continue to compete with financial or other institutions
that may be larger, or better capitalized, or may have a stronger
local  presence  and  longer  operating  history  in  certain
geographies or products. Many of these firms have the ability
to offer a wide range of products and services, and on different
platforms,  that  may  enhance  their  competitive  position  and
could result in pricing pressure on our businesses. 

We continue to experience intense price competition in some of
our  businesses.  In  particular,  the  ability  to  execute  securities
trades electronically on exchanges and through other automated
trading  markets  has  increased  the  pressure  on  trading
commissions  and  fees.  The  trend  toward  direct  access  to
automated, electronic markets will likely increase as additional
trading moves to more automated platforms. It is also possible
that we will experience competitive pressures in these and other
areas in the future as some of our competitors seek to obtain
market  share  by  reducing  prices,  including  in  the  form  of
commissions or fees.

1

December 2019 Form 10-K

Table of Contents

Investment Management

Our ability to compete successfully in the asset management
industry is affected by several factors, including our reputation,
investment  objectives,  quality  of  investment  professionals,
performance  of  investment  strategies  or  product  offerings
relative to peers and appropriate benchmark indices, advertising
and sales promotion efforts, fee levels, the effectiveness of and
access to distribution channels and investment pipelines, and
the  types  and  quality  of  products  offered.  Our  investment
products,  including  alternative  investment  products,  may
compete with investments offered by other investment managers
with passive investment products or who may be subject to less
stringent legal and regulatory regimes than us.

Supervision and Regulation

As a major financial services firm, we are subject to extensive
regulation  by  U.S.  federal  and  state  regulatory  agencies  and
securities exchanges and by regulators and exchanges in each
of  the  major  markets  where  we  conduct  our  business. These
include  legislative  and  regulatory  responses  to  the  financial
crisis,  both  in  the  U.S.  and  worldwide,  including:  the  Dodd-
Frank  Wall  Street  Reform  and  Consumer  Protection  Act
(“Dodd-Frank Act”); risk-based capital, leverage and liquidity
standards adopted or being developed by the Basel Committee
on Banking Supervision (“Basel Committee”), including Basel
III, and the national implementation of those standards; capital
planning  and  stress  testing  requirements;  and  recovery  and
resolution  regimes  in  the  U.S.  and  other  jurisdictions.  Some
areas of post-financial crisis regulation are still subject to final
rulemaking, transition periods, or revisions.

We  continue  to  monitor  the  changing  political,  tax  and
regulatory  environment;  it  is  likely  that  there  will  be  further
changes in the way major financial institutions are regulated in
both the U.S. and other markets in which we operate, although
it remains difficult to predict the exact impact these changes will
have on our business, financial condition, results of operations
and cash flows for a particular future period. We expect to remain
subject to extensive supervision and regulation.

Financial Holding Company

Consolidated Supervision.    We have operated as a BHC and
FHC under the BHC Act since September 2008. As a BHC, we
are  subject 
to  comprehensive  consolidated  supervision,
regulation and examination by the Federal Reserve. The Federal
Reserve has authority to examine, prescribe regulations and take
action with respect to all of our subsidiaries. In particular, we
are subject to (among other things): significantly revised and
expanded regulation and supervision; intensive scrutiny of our
businesses  and  plans  for  expansion  of  those  businesses;
limitations  on  activities;  a  systemic  risk  regime  that  imposes
heightened  capital  and  liquidity  requirements;  restrictions  on
activities and investments imposed by a section of the BHC Act
added by the Dodd-Frank Act referred to as the “Volcker Rule”;

December 2019 Form 10-K

2

and  comprehensive  derivatives  regulation.  In  addition,  the
Consumer Financial Protection Bureau has primary rulemaking,
enforcement  and  examination  authority  over  us  and  our
subsidiaries with respect to federal consumer protection laws,
to the extent applicable.

Scope  of  Permitted  Activities.    The  BHC  Act  limits  the
activities of BHCs and FHCs and grants the Federal Reserve
authority to limit our ability to conduct activities. We must obtain
the  Federal  Reserve’s  approval  before  engaging  in  certain
banking  and  other  financial  activities  both  in  the  U.S.  and
internationally.

The BHC Act grandfathers “activities related to the trading, sale
or  investment  in  commodities  and  underlying  physical
properties,”  provided  that  we  were  engaged  in  “any  of  such
activities as of September 30, 1997 in the U.S.” and provided
that  certain  other  conditions  that  are  within  our  reasonable
control are satisfied. We currently engage in our commodities
activities  pursuant  to  the  BHC Act  grandfather  exemption  as
well as other authorities under the BHC Act.

Activities  Restrictions  under  the  Volcker  Rule.    The  Volcker
Rule prohibits banking entities, including us and our affiliates,
from  engaging  in  certain  proprietary  trading  activities,  as
defined  in  the  Volcker  Rule,  subject  to  exemptions  for
underwriting, market-making-related activities, risk-mitigating
hedging  and  certain  other  activities.  The  Volcker  Rule  also
prohibits  certain  investments  and  relationships  by  banking
entities with covered funds, as defined in the Volcker Rule, with
a number of exemptions and exclusions. The Volcker Rule also
requires that deductions be made from a BHC’s Tier 1 capital
for  permissible  investments  in  certain  covered  funds.  In
addition,  the  Volcker  Rule  requires  banking  entities  to  have
comprehensive  compliance  programs  reasonably  designed  to
ensure and monitor compliance with the Volcker Rule. We have
brought all of our activities and investments into conformance,
subject to a June 2017 approval by the Federal Reserve for a
five-year  extension  of  the  transition  period  to  conform
investments in certain legacy covered funds that are also illiquid
funds.  The  approval  covers  essentially  all  of  our  non-
conforming  investments  in,  and  relationships  with,  legacy
covered funds subject to the Volcker Rule. 

The  federal  financial  regulatory  agencies  responsible  for  the
Volcker  Rule’s  implementing  regulations  have  finalized
revisions to certain elements of those regulations. The changes
simplify  the  application  of  the  Volcker  Rule,  and  focus  on
proprietary  trading  and  certain  requirements  imposed  in
connection  with  permitted  market  making,  underwriting  and
risk-mitigating hedging activities. As part of the changes, the
deduction for certain covered fund positions held in connection
with permitted market-making and underwriting activities is no
longer required. These revisions became effective on January
1,  2020.  We  were  permitted  to  voluntarily  comply  with  the
revised regulations, in whole or in part, beginning on that date,
with  full  compliance  required  by  January  1,  2021.  These

Table of Contents

revisions simplify elements of our compliance obligations and
we do not expect these revisions to have a material impact on
the way we conduct business under the current rule. 

Capital  Standards.    The  Federal  Reserve  establishes  capital
requirements,  including  well-capitalized  standards,  for  large
BHCs and evaluates our compliance with such requirements.
The OCC establishes similar capital requirements and standards
for  Morgan  Stanley  Bank,  N.A.  (“MSBNA”)  and  Morgan
Stanley  Private  Bank,  National  Association  (“MSPBNA”)
(collectively, our “U.S. Bank Subsidiaries”).

Regulatory  Capital  Framework.    The  regulatory  capital
requirements for us and our U.S. Bank Subsidiaries are largely
based on the Basel III capital standards established by the Basel
Committee, as supplemented by certain provisions of the Dodd-
Frank  Act.  We  are  subject  to  various  risk-based  capital
requirements  with  various  transition  provisions,  measured
against our Common Equity Tier 1 capital, Tier 1 capital and
Total  capital  bases,  leverage-based  capital  requirements,
including  the  SLR,  and  additional  capital  buffers  above
generally applicable minimum standards for BHCs.

The  Basel  Committee  has  published  a  comprehensive  set  of
revisions to its Basel III Framework. The revised requirements
are expected to take effect starting January 2022, subject to U.S.
banking  agencies 
implementation  proposals. The
impact on us of any revisions to the Basel Committee’s capital
standards is uncertain and depends on future rulemakings by the
U.S. banking agencies.

issuing 

capital 

including 

Regulated  Subsidiaries.  In  addition,  many  of  our  regulated
subsidiaries are, or are expected to be in the future, subject to
regulatory 
regulated
requirements, 
subsidiaries  registered  as  swap  dealers  with  the  CFTC  or
security-based swap dealers with the SEC (collectively, “Swaps
Entities”) or registered as broker-dealers or futures commission
merchants.  Specific  regulatory  capital  requirements  vary  by
regulated subsidiary, and in many cases these standards are still
in proposed form, not yet effective or are subject to ongoing
rulemakings that could substantially modify requirements.

For more information about the specific capital requirements
applicable  to  us  and  our  U.S.  Bank  Subsidiaries,  see
“Management’s Discussion and Analysis of Financial Condition
and Results of Operations—Liquidity and Capital Resources—
Regulatory Requirements.”

and 

Tests 

Stress 

Planning, 

Capital
Capital 
Distributions.    Pursuant  to  the  Dodd-Frank Act,  the  Federal
Reserve  has  adopted  capital  planning  and  stress 
test
requirements for large BHCs, including Morgan Stanley. For
more  information  about  the  capital  planning  and  stress  test
requirements, 
those
requirements  that  would  integrate  them  with  certain  ongoing
regulatory capital requirements, see “Management’s Discussion
and Analysis of Financial Condition and Results of Operations

including  proposed 

changes 

to 

and 

Capital 

—Liquidity 
Resources—Regulatory
Requirements” and “Management’s Discussion and Analysis of
Financial Condition and Results of Operations—Liquidity and
Capital  Resources—Regulatory  Developments—Proposed
Stress Buffer Requirements.”

In  addition  to  capital  planning  requirements,  the  Federal
Reserve, the OCC and the FDIC have the authority to prohibit
or to limit the payment of dividends by the banking organizations
they supervise, including us and our U.S. Bank Subsidiaries, if,
in the banking regulator’s opinion, payment of a dividend would
constitute an unsafe or unsound practice in light of the financial
condition of the banking organization. All of these policies and
other requirements could affect our ability to pay dividends and/
or repurchase stock, or require us to provide capital assistance
to our U.S. Bank Subsidiaries under circumstances which we
would not otherwise decide to do so.

Liquidity  Standards.    In  addition  to  capital  regulations,  the
U.S. banking agencies and the Basel Committee have adopted,
or are in the process of adopting, liquidity and funding standards.
We  and  our  U.S.  Bank  Subsidiaries  are  subject  to  the  U.S.
banking agencies’ LCR requirements, which generally follow
Basel Committee standards. Similarly, if the proposed NSFR
requirements are adopted by the U.S. banking agencies, we and
our  U.S.  Bank  Subsidiaries  will  become  subject  to  NSFR
requirements,  which  generally  follow  Basel  Committee
standards.

In addition to the LCR and NSFR, we and many of our regulated
subsidiaries, including those registered as Swaps Entities with
the CFTC or SEC, are, or are expected to be in the future, subject
to other liquidity standards, including liquidity stress-testing and
associated liquidity reserve requirements.

For  more  information,  see  “Management’s  Discussion  and
Analysis of Financial Condition and Results of Operations—
Liquidity  and  Capital  Resources—Regulatory  Liquidity
Framework.”

Systemic Risk Regime.    The Dodd-Frank Act, as amended by
the  Economic  Growth,  Regulatory  Relief  and  Consumer
Protection  Act  (“EGRRCPA”),  establishes  a  systemic  risk
regime to which certain large BHCs, including Morgan Stanley,
are  subject.  Under  rules  issued  by  the  Federal  Reserve  to
implement  certain  requirements  of  the  Dodd-Frank  Act’s
enhanced prudential standards, such large BHCs must conduct
internal  liquidity  stress  tests,  maintain  unencumbered  highly
liquid assets to meet projected net cash outflows for 30 days
over the range of liquidity stress scenarios used in internal stress
tests,  and  comply  with  various  liquidity  risk  management
requirements. These large BHCs also must comply with a range
of risk management and corporate governance requirements.

The  Federal  Reserve  adopted  a  framework  to  impose  single-
counterparty  credit 
large  banking
organizations, for which compliance was required by January

limits  (“SCCL”)  for 

3

December 2019 Form 10-K

Table of Contents

1, 2020. U.S. G-SIBs, including us, are subject to a limit of 15%
of Tier 1 capital for aggregate net credit exposures to any “major
counterparty” (defined to include other U.S. G-SIBs, foreign G-
SIBs, and nonbank systemically important financial institutions
supervised by the Federal Reserve). In addition, we are subject
to  a  limit  of  25%  of  Tier  1  capital  for  aggregate  net  credit
exposures to any other unaffiliated counterparty. 

The Federal Reserve has proposed rules that would create a new
early  remediation  framework  to  address  financial  distress  or
material management weaknesses. The Federal Reserve also has
the ability to establish additional prudential standards, including
those regarding contingent capital, enhanced public disclosures
and  limits  on  short-term  debt,  including  off-balance  sheet
exposures.  See  “Management’s  Discussion  and  Analysis  of
Financial Condition and Results of Operations—Liquidity and
Capital  Resources—Regulatory  Requirements—Total  Loss-
Absorbing  Capacity,  Long-Term  Debt  and  Clean  Holding
Company Requirements.”

Under the systemic risk regime, if the Federal Reserve or the
Financial Stability Oversight Council determines that a BHC
with $250 billion or more in consolidated assets poses a “grave
threat” to U.S. financial stability, the institution may be, among
other things, restricted in its ability to merge or offer financial
products and/or required to terminate activities and dispose of
assets.

See also “Capital Standards” and “Liquidity Standards” herein
and “Resolution and Recovery Planning” below.

Resolution and Recovery Planning. Pursuant to the Dodd-Frank
Act,  we  are  required  to  periodically  submit  to  the  Federal
Reserve  and  the  FDIC  a  resolution  plan  that  describes  our
strategy  for  a  rapid  and  orderly  resolution  under  the  U.S.
Bankruptcy Code in the event of our material financial distress
or failure. Our preferred resolution strategy, which is set out in
our 2019 resolution plan, is an SPOE strategy, which generally
contemplates the provision of adequate capital and liquidity by
the Parent Company to certain of its subsidiaries so that such
subsidiaries  have  the  resources  necessary  to  implement  the
resolution  strategy  after  the  Parent  Company  has  filed  for
bankruptcy.

Under a final rule issued by the Federal Reserve and the FDIC,
we  are  now  required  to  file  resolution  plans  once  every  two
years,  with  interim  updates  required  in  certain  limited
circumstances.  The  rule  also  allows  us  to  alternate  between
submitting  a  full,  detailed  resolution  plan  and  a  streamlined,
targeted resolution plan. Our next resolution plan submission is
expected to be a targeted resolution plan in 2021. The rule also
clarifies the information required to be included in our resolution
plan. 

Further,  we  submit  an  annual  recovery  plan  to  the  Federal
Reserve that outlines the steps that management could take over

December 2019 Form 10-K

4

time  to  generate  or  conserve  financial  resources  in  times  of
prolonged financial stress.

Certain of our domestic and foreign subsidiaries are also subject
to  resolution  and  recovery  planning  requirements  in  the
jurisdictions  in  which  they  operate.  For  example  the  FDIC
requires  certain 
institutions  (“IDI”),
including  our  U.S.  Bank  Subsidiaries,  to  submit  an  annual
resolution plan that describes the IDI’s strategy for a rapid and
orderly resolution in the event of material financial distress or
failure of the IDI.

insured  depository 

In addition, certain financial companies, including BHCs such
as the Firm and certain of its subsidiaries, can be subjected to a
resolution proceeding under the orderly liquidation authority in
Title II of the Dodd-Frank Act with the FDIC being appointed
as receiver, provided that certain procedures are met, including
certain  extraordinary  financial  distress  and  systemic  risk
determinations by the U.S. Treasury Secretary in consultation
with  the  U.S.  President.  The  orderly  liquidation  authority
rulemaking is proceeding in stages, with some regulations now
finalized and others not yet proposed. If we were subject to the
orderly liquidation authority, the FDIC would have considerable
powers, including: the power to remove directors and officers
responsible  for  our  failure  and  to  appoint  new  directors  and
officers; the power to assign our assets and liabilities to a third
party or bridge financial company without the need for creditor
consent or prior court review; the ability to differentiate among
our creditors, including by treating certain creditors within the
same class better than others, subject to a minimum recovery
right on the part of disfavored creditors to receive at least what
they would have received in bankruptcy liquidation; and broad
powers  to  administer  the  claims  process  to  determine
distributions from the assets of the receivership. The FDIC has
been  developing  an  SPOE  strategy  that  could  be  used  to
implement the orderly liquidation authority.

Regulators  have  also  taken  and  proposed  various  actions  to
facilitate an SPOE strategy under the U.S. Bankruptcy Code,
the orderly liquidation authority or other resolution regimes.

For example, the Federal Reserve and the OCC have established
rules that impose contractual requirements on certain qualified
financial  contracts  (“covered  QFCs”)  to  which  U.S.  G-SIBs,
including  us,  and  their  subsidiaries  including  our  U.S.  Bank
Subsidiaries, are parties (together, the “covered entities”). Under
these rules, covered QFCs must expressly provide that transfer
restrictions and default rights against covered entities are limited
to the same extent as they would be under the Federal Deposit
Insurance  Act  and  Title  II  of  the  Dodd-Frank  Act  and  their
implementing  regulations,  and  they  may  not,  among  other
things,  permit  the  exercise  of  any  cross-default  right  against
covered  entities  based  on  an  affiliate’s  entry  into  insolvency,
resolution  or  similar  proceedings,  subject  to  certain  creditor
protections. The final compliance date was January 1, 2020.

Table of Contents

For  more  information  about  our  resolution  plan-related
submissions  and  associated  regulatory  actions,  see  “Risk
Factors—Legal,  Regulatory 
and  Compliance  Risk”,
“Management’s Discussion and Analysis of Financial Condition
and Results of Operations—Liquidity and Capital Resources—
Regulatory  Requirements—Total  Loss-Absorbing  Capacity,
Long-Term Debt and Clean Holding Company Requirements”
and  “Management’s  Discussion  and  Analysis  of  Financial
Condition  and  Results  of  Operations—Liquidity  and  Capital
and
Resources—Regulatory  Requirements—Resolution 
Recovery Planning.”

Cyber  and  Information  Security  Risk  Management  and
Protection of Client Information

information  security 

regarding  cyber  and 

The financial services industry faces increased global regulatory
focus 
risk
management  practices.  Many  aspects  of  our  businesses  are
subject  to  cybersecurity  legal  and  regulatory  requirements
enacted by U.S. federal and state governments and other non-
U.S.  jurisdictions  in  the Americas,  Europe,  the  Middle  East,
Africa  and  Asia.  These  laws  are  aimed  at  codifying  basic
cybersecurity  protections  and  mandating  data  breach
notification requirements.

Our businesses are also subject to privacy and data protection
information security legal requirements concerning the use and
protection  of  certain  personal  information.  For  example,  the
General  Data  Protection  Regulation  (“GDPR”)  became
effective  in  the  E.U.  on  May  25,  2018  and  the  California
Consumer Privacy Act (“CCPA”) became effective on January
1, 2020. The GDPR and CCPA impose mandatory privacy and
data  protection obligations, including providing for individual
rights, enhanced governance and accountability requirements
and significant fines and litigation risk for noncompliance. In
addition,  other  jurisdictions  have  adopted  or  are  proposing
GDPR or similar standards, such as Australia, Singapore, Japan,
Argentina, India, Brazil, Switzerland and the Cayman Islands.

Many aspects of our businesses are subject to legal requirements
concerning  the  use  and  protection  of  certain  customer
information.  These  include  those  adopted  pursuant  to  the
Gramm-Leach-Bliley  Act  and  the  Fair  and  Accurate  Credit
Transactions Act of 2003 in the U.S., the GDPR and CCPA and
various  laws  in  Asia,  including  the  Japanese  Personal
Information  Protection  Law,  the  Hong  Kong  Personal  Data
(Protection) Ordinance and the Australian Privacy Act. We have
adopted measures designed to comply with these and related
applicable requirements in all relevant jurisdictions.

U.S. Bank Subsidiaries

U.S.  Bank  Subsidiaries.    MSBNA,  primarily  a  wholesale
commercial bank, offers commercial lending and certain retail
securities-based lending services in addition to deposit products.

MSPBNA  offers  certain  mortgage  and  other  secured  lending
products,  including  retail  securities-based  lending  products,
primarily  for  customers  of  our  affiliate  retail  broker-dealer,
Morgan Stanley Smith Barney LLC (“MSSB”). MSPBNA also
offers  certain  deposit  products  and  prime  brokerage  custody
services.

Both MSBNA and MSPBNA are FDIC-insured national banks
subject to supervision, regulation and examination by the OCC.
They are both subject to the OCC’s risk governance guidelines,
which establish heightened standards for a large national bank’s
risk governance framework and the oversight of that framework
by the bank’s board of directors.

Prompt  Corrective  Action.    The  Federal  Deposit  Insurance
Corporation Improvement Act of 1991 provides a framework
for  regulation  of  depository  institutions  and  their  affiliates,
including parent holding companies, by their federal banking
regulators. Among other things, it requires the relevant federal
banking regulator to take prompt corrective action with respect
to a depository institution if that institution does not meet certain
capital adequacy standards. These regulations generally apply
only to insured banks and thrifts such as MSBNA or MSPBNA
and not to their parent holding companies. The Federal Reserve
is, however, separately authorized to take appropriate action at
the holding company level, subject to certain limitations. Under
the systemic risk regime, as described above, we also would
become subject to an early remediation protocol in the event of
financial distress. In addition, BHCs, such as Morgan Stanley,
are required to serve as a source of strength to their U.S. bank
subsidiaries and commit resources to support these subsidiaries
in the event such subsidiaries are in financial distress.

Transactions with Affiliates.    Our U.S. Bank Subsidiaries are
subject to Sections 23A and 23B of the Federal Reserve Act,
which impose restrictions on covered transactions, as defined
in  the  Federal  Reserve  Act,  with  any  affiliates.  Covered
transactions include any extension of credit to, purchase of assets
from, and certain other transactions by insured banks with an
affiliate.  These  restrictions  limit  the  total  amount  of  credit
exposure that our U.S. Bank Subsidiaries may have to any one
affiliate  and  to  all  affiliates.  Sections  23A  and  23B  also  set
collateral requirements and require all such transactions to be
made  on  market  terms.  Derivative,  securities  borrowing  and
securities 
transactions  between  our  U.S.  Bank
Subsidiaries and their affiliates are subject to these restrictions.
The  Federal  Reserve  has  indicated  that  it  will  propose  a
rulemaking to implement changes to these restrictions made by
the Dodd-Frank Act.

lending 

In  addition,  the  Volcker  Rule  generally  prohibits  covered
transactions  between  (i) us  or  any  of  our  affiliates  and
(ii) covered funds for which we or any of our affiliates serve as
the investment manager, investment adviser, commodity trading
advisor or sponsor, or other covered funds organized and offered
by us or any of our affiliates pursuant to specific exemptions in

5

December 2019 Form 10-K

Table of Contents

the  Volcker  Rule.  See  also  “Financial  Holding  Company—
Activities Restriction under the Volcker Rule” above.

FDIC Regulation.    An FDIC-insured depository institution is
generally liable for any loss incurred or expected to be incurred
by  the  FDIC  in  connection  with  the  failure  of  an  insured
depository institution under common control by the same BHC.
As commonly controlled FDIC-insured depository institutions,
each of MSBNA and MSPBNA could be responsible for any
loss to the FDIC from the failure of the other. In addition, both
institutions  are  exposed  to  changes  in  the  cost  of  FDIC
insurance.

Institutional Securities and Wealth Management

Broker-Dealer  and  Investment  Adviser  Regulation.    Our
primary U.S. broker-dealer subsidiaries, Morgan Stanley & Co.
LLC  (“MS&Co.”)  and  MSSB,  are  registered  broker-dealers
with the SEC and in all 50 states, the District of Columbia, Puerto
Rico and the U.S. Virgin Islands, and are members of various
self-regulatory  organizations,  including  FINRA,  and  various
securities exchanges and clearing organizations. Broker-dealers
are subject to laws and regulations covering all aspects of the
securities  business,  including  sales  and  trading  practices,
securities  offerings,  publication  of  research  reports,  use  of
customers’  funds  and  securities,  capital  structure,  risk
management  controls  in  connection  with  market  access,
recordkeeping and retention, and the conduct of their directors,
officers, representatives and other associated persons. Broker-
dealers are also regulated by securities administrators in those
states  where  they  do  business.  Violations  of  the  laws  and
regulations governing a broker-dealer’s actions could result in
censures,  fines,  the  issuance  of  cease-and-desist  orders,
revocation  of  licenses  or  registrations,  the  suspension  or
expulsion from the securities industry of such broker-dealer or
its officers or employees, or other similar consequences by both
federal  and  state  securities  administrators.  Our  broker-dealer
subsidiaries  are  also  members  of  the  Securities  Investor
Protection Corporation, which provides certain protections for
customers of broker-dealers against losses in the event of the
insolvency of a broker-dealer.

MSSB  is  also  a  registered  investment  adviser  with  the  SEC.
MSSB’s  relationship  with  its  investment  advisory  clients  is
subject  to  the  fiduciary  and  other  obligations  imposed  on
investment advisers under the Investment Advisers Act of 1940,
and the rules and regulations promulgated thereunder as well as
various  state  securities  laws.  These  laws  and  regulations
generally  grant  the  SEC  and  other  supervisory  bodies  broad
administrative powers to address non-compliance, including the
power to restrict or limit MSSB from carrying on its investment
advisory and other asset management activities. Other sanctions
that  may  be  imposed  include  the  suspension  of  individual
employees,  limitations  on  engaging  in  certain  activities  for
specified periods of time or for specified types of clients, the
revocation of registrations, other censures and significant fines.

December 2019 Form 10-K

6

The Firm is subject to various regulations that affect broker-
dealer sales practices and customer relationships. For example,
the SEC has released a package of final rules and interpretations
relating  to  the  provision  of  advice  by  broker-dealers  and
investment  advisers.  The  package  includes  new  rules  on  the
standards of conduct and required disclosures for broker-dealers
when  making  securities-related  recommendations  to  retail
investors, and a new formal interpretation of the fiduciary duty
owed by investment advisers. One of the final rules, entitled
“Regulation Best Interest,” requires broker-dealers to act in the
“best interest” of retail customers at the time a recommendation
is made without placing the financial or other interests of the
broker-dealer  ahead  of  the  interest  of  the  retail  customer.
Another  new  rule  requires  that  both  broker-dealers  and
investment advisers provide to retail investors a brief summary
document  containing  information  about  the  relationship
between  the  parties  (“Form  CRS”). The  compliance  date  for
Regulation Best Interest and Form CRS is June 30, 2020. Certain
states  have  enacted  laws  or  rules,  or  are  considering  laws  or
rules, subjecting broker-dealers to a fiduciary duty when dealing
with retail customers under a variety of circumstances.

Margin lending by broker-dealers is regulated by the Federal
Reserve’s restrictions on lending in connection with customer
and proprietary purchases and short sales of securities, as well
as securities borrowing and lending activities. Broker-dealers
are also subject to maintenance and other margin requirements
imposed under FINRA and other self-regulatory organization
rules.  In  many  cases,  our  broker-dealer  subsidiaries’  margin
policies are more stringent than these rules.

As registered U.S. broker-dealers, certain of our subsidiaries are
subject  to  the  SEC’s  net  capital  rule  and  the  net  capital
requirements of various exchanges, other regulatory authorities
and  self-regulatory  organizations.  These  rules  are  generally
designed  to  measure  the  broker-dealer  subsidiary’s  general
financial  integrity  and/or  liquidity  and  require  that  at  least  a
minimum amount of net and/or liquid assets be maintained by
the  subsidiary.  See  also  “Financial  Holding  Company—
Consolidated Supervision” and “Financial Holding Company
—Liquidity Standards” above. Rules of FINRA and other self-
regulatory  organizations  also 
limitations  and
requirements on the transfer of member organizations’ assets.

impose 

have 

regulations 

Research.    Research-related 
been
implemented in many jurisdictions, including in the U.S., where
FINRA has adopted rules that cover research relating to both
equity  and  debt  securities.  Regulators  continue  to  focus  on
research  conflicts  of  interest  and  may  impose  additional
regulations. See also “Business—Supervision and Regulation
—Non-U.S. Regulation” herein.  

Regulation  of  Futures  Activities  and  Certain  Commodities
Activities.    MS&Co., as a futures commission merchant, and
MSSB,  as  an  introducing  broker,  are  subject  to  net  capital
requirements of, and certain of their activities are regulated by,
the CFTC, the NFA, the Joint Audit Committee (including the

Table of Contents

Chicago  Mercantile  Exchange  &  Chicago  Board  of  Trade
(“CME Group”) in its capacity as MS&Co.'s designated self-
regulatory  organization),  and  various  commodity  futures
exchanges. MS&Co. and MSSB and certain of their affiliates
are registered with the CFTC and are members of the NFA in
various capacities. Rules and regulations of the CFTC, NFA,
the  Joint  Audit  Committee  (including  the  CME  Group)  and
commodity  futures  exchanges  address  obligations  related  to,
among  other  things,  customer  protections,  the  segregation  of
customer funds and the holding of secured amounts, the use by
futures commission merchants of customer funds, the margining
of customer accounts and documentation entered into by futures
commission merchants with their customers, recordkeeping and
reporting  obligations  of  futures  commission  merchants  and
introducing  brokers,  risk  disclosure,  risk  management  and
discretionary trading.

Our commodities activities are subject to extensive and evolving
energy,  commodities,  environmental,  health  and  safety,  and
other governmental laws and regulations in the U.S. and abroad.
Intensified scrutiny of certain energy markets by U.S. federal,
state  and  local  authorities  in  the  U.S.  and  abroad  and  by  the
legal
public  has  resulted 
enforcement  and  remedial  proceedings  involving  companies
conducting the activities in which we are engaged.

increased  regulatory  and 

in 

Derivatives Regulation.    The commodity futures, commodity
options and swaps industry in the U.S. is subject to regulation
under the U.S. Commodity Exchange Act (“CEA”). The CFTC
is the U.S. federal agency charged with the administration of
the CEA. In addition, the SEC is the U.S. federal agency charged
with  the  regulation  of  security-based  swaps.  The  rules  and
regulations of various self-regulatory organizations also govern
derivatives.

Under the U.S. regulatory regime for swaps and security-based
swaps  (collectively,  “Swaps”)  implemented  pursuant  to  the
Dodd-Frank Act, we are subject to comprehensive regulation of
our  derivatives  businesses,  including  regulations  that  impose
margin requirements, public and regulatory reporting, central
clearing  and  mandatory  trading  on  regulated  exchanges  or
execution facilities for certain types of Swaps. 

CFTC  rules  require  registration  of  swap  dealers,  mandatory
clearing and execution of interest rate and certain credit default
swaps and real-time public reporting and adherence to business
conduct standards for all in-scope Swaps. We also anticipate that
the CFTC will adopt capital requirements for swap dealers and
major swap participants that are not subject to the capital rules
of a prudential regulator. We have registered a number of U.S.
and non U.S. CFTC swap dealers.

SEC  rules  govern  the  registration  and  regulation  of  security-
based swap dealers. Though compliance with a number of these
rules is not expected to be required until 2021, they will trigger
numerous obligations for entities that register as security-based
swap  dealers,  including  capital,  margin  and  segregation

requirements. We anticipate registering one or more entities as
a security-based swap dealer.

The  specific  parameters  of  some  of  these  requirements  for
Swaps have been and continue to be developed through CFTC,
SEC and bank regulator rulemakings. For example, the rules for
variation  margin  are  presently  effective,  and  those  for  initial
margin will continue to phase-in based on activity levels of the
swap dealer and the relevant counterparty with the final phase
currently  expected  to  occur  in  September  2021,  subject  to
finalization of various proposed rule makings by the CFTC and
bank  regulators.  Margin  rules  with  the  same  or  similar
compliance dates have been adopted or are in the process of
being finalized by regulators outside the U.S., and certain of our
subsidiaries may be subject to such rules. 

Although  a  significant  number  of  areas  within  the  global
derivatives  regulatory  framework  have  been  finalized,
additional changes are expected. As the derivatives regulatory
framework continues to evolve, we expect to continue to face
increased  costs  and  regulatory  oversight.  Complying  with
registration and other regulatory requirements has required, and
is expected to require in the future, systems and other changes
to our derivatives businesses. Compliance with Swaps-related
regulatory capital requirements may also require us to devote
more  capital  to  our  businesses  that  engage  in  swaps.  Our
Institutional  Securities  and  Wealth  Management  business
segments activities are also regulated in jurisdictions outside the
U.S. See “Non-U.S. Regulation” herein.

Investment Management

Many  of  the  subsidiaries  engaged  in  our  asset  management
activities are registered as investment advisers with the SEC.
Many aspects of our asset management activities are also subject
to federal and state laws and regulations primarily intended to
benefit  the  investor  or  client.  These  laws  and  regulations
generally  grant  supervisory  agencies  and  bodies  broad
administrative powers, including the power to limit or restrict
us from carrying on our asset management activities in the event
that we fail to comply with such laws and regulations. Sanctions
that may be imposed for such failure include the suspension of
individual employees, limitations on our engaging in various
asset  management  activities  for  specified  periods  of  time  or
specified types of clients, the revocation of registrations, other
censures  and  significant  fines.  Morgan  Stanley  Distribution,
Inc., a U.S. broker-dealer subsidiary, acts as distributor to the
Morgan Stanley mutual funds and as placement agent to certain
investment  funds  managed  by  our  Investment
private 
Management business segment.

Our asset management activities are subject to certain additional
laws and regulations, including, but not limited to, additional
reporting  and  recordkeeping  requirements  (including  with
respect  to  clients  that  are  private  funds)  and  restrictions  on
sponsoring  or  investing  in,  or  maintaining  certain  other
relationships with, covered funds, as defined in the Volcker Rule,

7

December 2019 Form 10-K

Table of Contents

subject  to  certain  limited  exemptions.  See  also  “Financial
Holding Company—Activities Restrictions under the Volcker
Rule.”

In addition, certain of our affiliates are registered as commodity
trading  advisors  and/or  commodity  pool  operators,  or  are
operating  under  certain  exemptions  from  such  registration
pursuant to CFTC rules and other guidance, and have certain
responsibilities with respect to each pool they advise. Violations
of the rules of the CFTC, the NFA or the commodity exchanges
could  result  in  remedial  actions,  including  fines,  registration
restrictions or terminations, trading prohibitions or revocations
of commodity exchange memberships. See also “Institutional
Securities  and  Wealth  Management—Broker-Dealer  and
Investment Adviser Regulation,” “Institutional Securities and
Wealth  Management—Regulation  of  Futures  Activities  and
Certain Commodities Activities,” and “Institutional Securities
and Wealth Management—Derivatives Regulation” above and
“Non-U.S.  Regulation,”  below  for  a  discussion  of  other
regulations that impact our Investment Management business
activities, including MiFID II.

Non-U.S. Regulation

All  of  our  businesses  are  regulated  extensively  by  non-U.S.
regulators, 
including  governments,  securities  exchanges,
commodity  exchanges,  self-regulatory  organizations,  central
banks and regulatory bodies, especially in those jurisdictions in
which we maintain an office. Certain regulators have prudential,
business conduct and other authority over us or our subsidiaries,
as well as powers to limit or restrict us from engaging in certain
businesses  or  to  conduct  administrative  proceedings  that  can
result in censures, fines, the issuance of cease-and-desist orders,
or  the  suspension  or  expulsion  of  a  regulated  entity  or  its
affiliates.

Some  of  our  subsidiaries  are  regulated  as  broker-dealers,
investment advisers or other types of regulated entities under
the laws of the jurisdictions in which they operate. Subsidiaries
engaged in banking and trust activities and advisory activities
outside the U.S. are regulated by various government agencies
in  the  particular  jurisdiction  where  they  are  chartered,
incorporated and/or conduct their business activity. For instance,
the PRA, the U.K. Financial Conduct Authority (“FCA”) and
several securities and futures exchanges in the U.K., including
the London Stock Exchange and ICE Futures Europe, regulate
für
our  activities 
Finanzdienstleistungsaufsicht 
Financial
Supervisory Authority)  and  the  Deutsche  Börse AG  regulate
certain of our activities in the Federal Republic of Germany; the
European Central Bank supervises certain subsidiaries in our
post-Brexit  structure;  the  Financial  Services  Agency,  the
Securities and Exchange Surveillance Commission, the Bank of
Japan,  the  Japan  Securities  Dealers  Association  and  several
Japanese  securities  and  futures  exchanges  and  ministries
regulate  our  activities  in  Japan;  the  Securities  and  Futures
Commission  of  Hong  Kong,  the  Hong  Kong  Monetary

the  Bundesanstalt 

the  U.K.; 

Federal 

(the 

in 

December 2019 Form 10-K

8

Authority and the Hong Kong Exchanges and Clearing Limited
regulate  our  business  in  Hong  Kong;  and  the  Monetary
Authority of Singapore and the Singapore Exchange Limited
regulate our business in Singapore; other similar bodies regulate
our activities in Ireland, China, Korea, Australia, India and other
countries.

Our  largest  non-U.S.  entity,  MSIP,  is  subject  to  extensive
regulation and supervision by the PRA, which has broad legal
authority to establish prudential and other standards applicable
to  MSIP  that  seek  to  ensure  its  safety  and  soundness  and  to
minimize adverse effects on the stability of the U.K. financial
system. MSIP is also regulated and supervised by the FCA with
respect to business conduct matters.

Non-U.S. policymakers and regulators, including the European
Commission  and  European  Supervisory  Authorities  (among
others,  the  European  Banking  Authority  and  the  European
Securities  and  Markets  Authority),  continue  to  propose  and
adopt  numerous  reforms,  including  those  that  may  further
impact the structure of banks or subject us to new prudential
requirements,  and  to  formulate  regulatory  standards  and
measures  that  will  be  of  relevance  and  importance  to  our
European operations.

In June 2019, the European Commission published a package
of  reforms  including  various  risk  reduction  measures.  These
include amendments to the Capital Requirements Directive and
Regulation  providing  updates  to  risk-based  capital,  liquidity
(including introducing a net stable funding ratio), leverage and
other  prudential  standards  on  a  consolidated  basis  that  are
consistent with final Basel standards. In addition, the reforms
will require certain large, non-E.U. financial groups with two
or more financial subsidiaries established in the E.U. to establish
an E.U. IHC. The E.U. IHC will be subject to direct supervision
and authorization by the European Central Bank or the relevant
national E.U. regulator. Further amendments to the E.U. bank
recovery and resolution regime under the E.U. Bank Recovery
and Resolution Directive (“BRRD”) were also published. 

The amendments to the BRRD build on previous proposals by
regulators  in  the  U.K.,  E.U.  and  other  major  jurisdictions  to
finalize  recovery  and  resolution  planning  frameworks  and
related regulatory requirements that will apply to certain of our
subsidiaries that operate in those jurisdictions. For instance, the
BRRD established a recovery and resolution framework for E.U.
credit institutions and investment firms, including MSIP (under
the U.K. version of the BRRD which is expected to be adopted
after  the  Brexit  transition  period).  In  addition,  certain
jurisdictions, including the U.K. and other E.U. jurisdictions,
have  implemented,  or  are  in  the  process  of  implementing,
changes to resolution regimes to provide resolution authorities
with the ability to recapitalize a failing entity organized in such
jurisdictions  by  reducing  certain  unsecured  liabilities  or
converting certain unsecured liabilities into equity.

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Regulators in the U.K., E.U. and other major jurisdictions have
also finalized other regulatory standards applicable to certain of
our subsidiaries that operate in those jurisdictions. For instance,
the  European  Market  Infrastructure  Regulation  introduced
requirements  regarding  the  central  clearing  and  reporting  of
derivatives,  as  well  as  margin  requirements  for  uncleared
derivatives.  MiFID  II  introduced  comprehensive  and  new
trading and market infrastructure reforms in the E.U., including
new  trading  venues,  enhancements  to  pre-  and  post-trading
transparency, additional investor protection requirements, and
requirements  relating  to  the  unbundling  of  research  and
execution  services  among  others,  and  we  have  had  to  make
extensive  changes  to  our  operations,  including  systems  and
controls in order to comply with MiFID II.

Financial Crimes Program

Our Financial Crimes program is coordinated on an enterprise-
wide basis and supports our financial crime prevention efforts
across  all  regions  and  business  units  with  responsibility  for
governance,  oversight  and  execution  of  our AML,  economic
sanctions (“Sanctions”) and anti-corruption programs.

subsidiaries,  broker-dealers, 

In  the  U.S.,  the  Bank  Secrecy Act,  as  amended  by  the  USA
PATRIOT  Act  of  2001,  imposes  significant  obligations  on
financial institutions to detect and deter money laundering and
terrorist financing activity, including requiring banks, BHCs and
commission
their 
merchants, introducing brokers and mutual funds to implement
AML programs, verify the identity of customers that maintain
accounts,  and  monitor  and  report  suspicious  activity  to
appropriate law enforcement or regulatory authorities. Outside
the U.S., applicable laws, rules and regulations similarly require
designated  types  of  financial  institutions  to  implement AML
programs.

futures 

We have implemented policies, procedures and internal controls
that are designed to comply with all applicable AML laws and
regulations.  Regarding  Sanctions,  we  have  implemented
policies, procedures and internal controls that are designed to
comply with the regulations and economic sanctions programs
administered by the U.S. Treasury’s Office of Foreign Assets
Control (“OFAC”), which target foreign countries, entities and
individuals  based  on  external  threats  to  U.S.  foreign  policy,
national  security  or  economic  interests,  and  to  comply,  as
applicable, with similar sanctions programs imposed by foreign
governments  or  global  or  regional  multilateral  organizations
such  as  the  United  Nations  Security  Council  and  the  E.U.
Council.

We are also subject to applicable anti-corruption laws, such as
the U.S. Foreign Corrupt Practices Act and the U.K. Bribery
Act, in the jurisdictions in which we operate. Anti-corruption
laws  generally  prohibit  offering,  promising,  giving  or
authorizing others to give anything of value, either directly or
indirectly, to a government official or private party in order to
influence official action or otherwise gain an unfair business

advantage,  such  as  to  obtain  or  retain  business.  We  have
implemented policies, procedures and internal controls that are
designed to comply with such laws, rules and regulations.

Information about our Executive Officers

The executive officers of Morgan Stanley and their age and titles
as of February 27, 2020 are set forth below. Business experience
is provided in accordance with SEC rules.

Jeffrey S. Brodsky (55).  Executive Vice President and Chief
Human  Resources  Officer  of  Morgan  Stanley  (since  January
2016). Vice President and Global Head of Human Resources
(January  2011  to  December  2015).  Co-Head  of  Human
Resources (January 2010 to December 2011). Head of Morgan
Stanley Smith Barney Human Resources (June 2009 to January
2010).

James P. Gorman (61).  Chairman of the Board of Directors
and Chief Executive Officer of Morgan Stanley (since January
2012). President and Chief Executive Officer (January 2010 to
December 2011) and member of the Board of Directors (since
January  2010).  Co-President  (December  2007  to  December
2009)  and  Co-Head  of  Strategic  Planning  (October  2007  to
December  2009).  President  and  Chief  Operating  Officer  of
Wealth Management (February 2006 to April 2008).

Eric F. Grossman (53).  Executive Vice President and Chief
Legal Officer of Morgan Stanley (since January 2012). Global
Head of Legal (September 2010 to January 2012). Global Head
of Litigation (January 2006 to September 2010) and General
Counsel  of  the  Americas  (May  2009  to  September  2010).
General Counsel of Wealth Management (November 2008 to
September  2010).  Partner  at  the  law  firm  of  Davis  Polk &
Wardwell LLP (June 2001 to December 2005).

Keishi  Hotsuki  (57).    Executive  Vice  President  (since  May
2014) and Chief Risk Officer of Morgan Stanley (since May
2011). Interim Chief Risk Officer (January 2011 to May 2011)
and  Head  of  Market  Risk  Department  (March  2008  to April
2014).  Global  Head  of  Market  Risk  Management  at  Merrill
Lynch (June 2005 to September 2007).

Edward N. Pick (51).  Head of Institutional Securities (since
July 2018). Global Head of Sales and Trading (October 2015 to
July 2018). Head of Global Equities (March 2011 to October
2015). Co-Head of Global Equities (April 2009 to March 2011).
Co-Head of Global Capital Markets (July 2008 to April 2009).
Co-Head of Global Equity Capital Markets (December 2005 to
July 2008).

Jonathan M. Pruzan (51).  Executive Vice President and Chief
Financial Officer of Morgan Stanley (since May 2015) and Head
of  Corporate  Strategy  (since  December  2016).  Co-Head  of
Global  Financial  Institutions  Group  (January  2010  to  April
2015). Co-Head of North American Financial Institutions Group

9

December 2019 Form 10-K

Table of Contents

M&A (September 2007 to December 2009). Head of the U.S.
Bank Group (April 2005 to August 2007).

Robert P. Rooney (52).  Head of Technology, Operations and
Firm  Resilience  (since  April  2019).  Head  of  Technology
(January  2017  to  April  2019).  Chief  Executive  Officer  of
Morgan Stanley International and Head of Europe, the Middle
East and Africa (January 2016 to May 2018). Global Co-Head
of Fixed Income Sales and Trading (May 2013 to January 2016).
Head of Fixed Income for Europe, the Middle East and Africa
and Global Head of Fixed Income Sales (September 2009 to
May 2013).

Andrew  M.  Saperstein  (53).   Head  of  Wealth  Management
(since April 2019). Co-Head of Wealth Management (January
2016 to April 2019). Co-Chief Operating Officer of Institutional
Securities  (March  2015  to  January  2016).  Head  of  Wealth
Management Investment Products and Services (June 2012 to
March 2015).

Daniel A. Simkowitz (54).  Head of Investment Management
of Morgan Stanley (since October 2015). Co-Head of Global
Capital Markets (March 2013 to September 2015). Chairman of
Global  Capital  Markets  (November  2009  to  March  2013).
Managing Director in Global Capital Markets (December 2000
to November 2009).

December 2019 Form 10-K

10

Table of Contents

Risk Factors

For a discussion of the risks and uncertainties that may affect
our  future  results  and  strategic  objectives,  see  “Forward-
Looking  Statements”  immediately  preceding  “Business”  and
“Return on Equity and Tangible Common Equity Targets” under
“Management’s Discussion and Analysis of Financial Condition
and Results of Operations.”

Market Risk

Market risk refers to the risk that a change in the level of one or
more market prices, rates, indices, volatilities, correlations or
other  market  factors,  such  as  market  liquidity,  will  result  in
losses  for  a  position  or  portfolio  owned  by  us.  For  more
information on how we monitor and manage market risk, see
“Quantitative and Qualitative Disclosures about Risk—Market
Risk.”

Our results of operations may be materially affected by market
fluctuations and by global and economic conditions and other
factors, including changes in asset values.

Our results of operations have been in the past and may, in the
future,  be  materially  affected  by  market  fluctuations  due  to
global  financial  markets,  economic  conditions,  changes  to
global trade policies and tariffs and other factors, including the
level  and  volatility  of  equity,  fixed  income  and  commodity
prices, the level and term structure of interest rates, inflation and
currency values, and the level of other market indices.

The  results  of  our  Institutional  Securities  business  segment,
particularly results relating to our involvement in primary and
secondary markets for all types of financial products, are subject
to substantial market fluctuations due to a variety of factors that
we  cannot  control  or  predict  with  great  certainty.  These
fluctuations  impact  results  by  causing  variations  in  business
flows and activity and in the fair value of securities and other
financial products. Fluctuations also occur due to the level of
global market activity, which, among other things, affects the
size,  number  and  timing  of  investment  banking  client
assignments and transactions and the realization of returns from
our principal investments.

During periods of unfavorable market or economic conditions,
the  level  of  individual  investor  participation  in  the  global
markets, as well as the level of client assets, may also decrease,
which  would  negatively  impact  the  results  of  our  Wealth
Management business segment.

Substantial market fluctuations could also cause variations in
the value of our investments in our funds, the flow of investment
capital into or from AUM, and the way customers allocate capital
among money market, equity, fixed income or other investment
alternatives,  which  could  negatively  impact  our  Investment
Management business segment.

The  value  of  our  financial  instruments  may  be  materially
affected  by  market  fluctuations.  Market  volatility,  illiquid
market  conditions  and  disruptions  in  the  credit  markets  may
make it extremely difficult to value and monetize certain of our
financial  instruments,  particularly  during  periods  of  market
displacement. Subsequent valuations in future periods, in light
of factors then prevailing, may result in significant changes in
the  values  of  these  instruments  and  may  adversely  impact
historical or prospective fees and performance-based fees (also
known  as  incentive  fees,  which  include  carried  interest)  in
respect of certain businesses. In addition, at the time of any sales
and  settlements  of  these  financial  instruments,  the  price  we
ultimately realize will depend on the demand and liquidity in
the market at that time and may be materially lower than their
current fair value. Any of these factors could cause a decline in
the  value  of  our  financial  instruments,  which  may  have  an
adverse effect on our results of operations in future periods.

In addition, financial markets are susceptible to severe events
evidenced by rapid depreciation in asset values accompanied by
a reduction in asset liquidity. Under these extreme conditions,
hedging and other risk management strategies may not be as
effective  at  mitigating  trading  losses  as  they  would  be  under
more  normal  market  conditions.  Moreover,  under  these
conditions,  market  participants  are  particularly  exposed  to
trading  strategies  employed  by  many  market  participants
simultaneously and on a large scale. Our risk management and
monitoring processes seek to quantify and mitigate risk to more
extreme  market  moves.  However,  severe  market  events  have
historically  been  difficult  to  predict  and  we  could  realize
significant losses if extreme market events were to occur.

Holding large and concentrated positions may expose us to
losses.

Concentration of risk may reduce revenues or result in losses in
our  market-making,  investing,  underwriting,  including  block
trading,  and  lending  businesses  in  the  event  of  unfavorable
market  movements,  or  when  market  conditions  are  more
favorable for our competitors. We commit substantial amounts
of capital to these businesses, which often results in our taking
large positions in the securities of, or making large loans to, a
particular issuer or issuers in a particular industry, country or
region.  For  further  information  regarding  our  country  risk
exposure,  see  also  “Quantitative  and  Qualitative  Disclosures
about Risk—Country Risk.”

Credit Risk

Credit risk refers to the risk of loss arising when a borrower,
counterparty or issuer does not meet its financial obligations to
us. For more information on how we monitor and manage credit
risk, see “Quantitative and Qualitative Disclosures about Risk
—Credit Risk.”

11

December 2019 Form 10-K

Table of Contents

We are exposed to the risk that third parties that are indebted
to us will not perform their obligations.

A default by a large financial institution could adversely affect
financial markets.

We  incur  significant  credit  risk  exposure  through  our
Institutional Securities business segment. This risk may arise
from a variety of business activities, including, but not limited
to:  extending  credit  to  clients  through  various  lending
commitments; entering into swap or other derivative contracts
under which counterparties have obligations to make payments
to us; providing short- or long-term funding that is secured by
physical  or  financial  collateral  whose  value  may  at  times  be
insufficient to fully cover the loan repayment amount; posting
margin  and/or  collateral  and  other  commitments  to  clearing
houses,  clearing  agencies,  exchanges,  banks,  securities  firms
and other financial counterparties; and investing and trading in
securities and loan pools, whereby the value of these assets may
fluctuate  based  on  realized  or  expected  defaults  on  the
underlying obligations or loans.

We also incur credit risk in our Wealth Management business
segment lending to mainly individual investors, including, but
not limited to, margin- and securities-based loans collateralized
by securities, residential mortgage loans and HELOCs.

Our  valuations  related  to,  and  reserves  for  losses  on,  credit
exposures rely on complex models, estimates, and subjective
judgments about the future. While we believe current valuations
and reserves adequately address our perceived levels of risk,
future economic conditions that differ from or are more severe
than  forecast,  inaccurate  models  or  assumptions,  or  external
factors  such  as  natural  disasters,  could  lead  to  inaccurate
measurement  of  or  deterioration  of  credit  quality  of  our
borrowers and counterparties or the value of collateral and result
in  unexpected  losses.  In  addition,  we  may  incur  higher  than
anticipated credit losses in periods of market illiquidity or as a
result  of  disputes  with  counterparties  over  the  valuation  of
collateral during periods of economic stress.

Certain  of  our  credit  exposures  are  concentrated  by  product,
industry or country. Although our models and estimates account
for correlations among related types of exposures, a change in
the market environment for a concentrated product or an external
factor impacting a concentrated industry or country may result
in credit losses in excess of amounts forecast. Concentrations
of credit risk are managed through the Firm’s comprehensive
and global Credit Limits Framework. 

In  addition,  as  a  clearing  member  of  several  central
counterparties, we are responsible for the defaults or misconduct
of our customers and could incur financial losses in the event
of default by other clearing members. Although we regularly
review our credit exposures, default risk may arise from events
or circumstances that are difficult to detect or foresee.

December 2019 Form 10-K

12

the 

institutions. 

relationships  among 

The commercial soundness of many financial institutions may
be closely interrelated as a result of credit, trading, clearing or
other 
Increased
centralization of trading activities through particular clearing
houses, central agents or exchanges as required by provisions
of the Dodd-Frank Act may increase our concentration of risk
with respect to these entities. As a result, concerns about, or a
default or threatened default by, one institution could lead to
significant market-wide liquidity and credit problems, losses or
defaults by other institutions. This is sometimes referred to as
systemic risk and may adversely affect financial intermediaries,
such  as  clearing  houses,  clearing  agencies,  exchanges,  banks
and securities firms, with which we interact on a daily basis and,
therefore, could adversely affect us. See also “Systemic Risk
Regime”  under  “Business—Supervision  and  Regulation—
Financial Holding Company.”

Operational Risk

Operational risk refers to the risk of loss, or of damage to our
reputation,  resulting  from  inadequate  or  failed  processes  or
systems, from human factors or from external events (e.g., fraud,
theft, legal and compliance risks, cyber attacks or damage to
physical assets). We may incur operational risk across the full
scope of our business activities, including revenue-generating
activities (e.g., sales and trading) and support and control groups
(e.g.,  information  technology  and  trade  processing).  Legal,
regulatory  and  compliance  risk  is  included  in  the  scope  of
operational  risk  and  is  discussed  below  under  “Legal,
Regulatory  and  Compliance  Risk.”  For  more  information  on
how we monitor and manage operational risk, see “Quantitative
and Qualitative Disclosures about Risk—Operational Risk.”

We are subject to operational risks, including a failure, breach
or other disruption of our operations or security systems or
those of our third parties (or third parties thereof), as well as
human error or malfeasance, which could adversely affect our
businesses or reputation.

Our businesses are highly dependent on our ability to process
and report, on a daily basis, a large number of transactions across
numerous  and  diverse  markets  in  many  currencies.  We  may
introduce  new  products  or  services  or  change  processes  or
reporting,  including  in  connection  with  new  regulatory
requirements, resulting in new operational risk that we may not
fully appreciate or identify. 

The trend toward direct access to automated, electronic markets
and the move to more automated trading platforms has resulted
in the use of increasingly complex technology that relies on the
continued effectiveness of the programming code and integrity
of the data to process the trades. We rely on the ability of our
employees,  consultants,  our  internal  systems  and  systems  at
technology centers maintained by unaffiliated third parties to

Table of Contents

operate our different businesses and process a high volume of
transactions.  Additionally,  we  are  subject  to  complex  and
evolving laws and regulations governing cybersecurity, privacy
and data protection, which may differ and potentially conflict,
in various jurisdictions.

As a major participant in the global capital markets, we face the
risk of incorrect valuation or risk management of our trading
positions due to flaws in data, models, electronic trading systems
or processes or due to fraud or cyber attack.

We also face the risk of operational failure or disruption of any
of  the  clearing  agents,  exchanges,  clearing  houses  or  other
financial  intermediaries  we  use  to  facilitate  our  lending,
securities  and  derivatives  transactions.  In  the  event  of  a
breakdown or improper operation of our or a direct or indirect
third party’s systems (or third parties thereof) or processes or
improper  or  unauthorized  action  by  third  parties,  including
consultants  and  subcontractors  or  our  employees,  we  could
suffer financial loss, an impairment to our liquidity position, a
disruption of our businesses, regulatory sanctions or damage to
our reputation. 

the 

In  addition, 
interconnectivity  of  multiple  financial
institutions with central agents, exchanges and clearing houses,
and the increased importance of these entities, increases the risk
that an operational failure at one institution or entity may cause
an industry-wide operational failure that could materially impact
our ability to conduct business. Furthermore, the concentration
of company and personal information held by a handful of third
parties increases the risk that a breach at a key third party may
cause  an  industry-wide  data  breach  that  could  significantly
increase the cost and risk of conducting business.

There can be no assurance that our business contingency and
security response plans fully mitigate all potential risks to us.
Our ability to conduct business may be adversely affected by a
disruption in the infrastructure that supports our businesses and
the communities where we are located, which are concentrated
in the New York metropolitan area, London, Hong Kong and
Tokyo, as well as Baltimore, Glasgow, Frankfurt, Budapest and
Mumbai. This may include a disruption involving physical site
access;  cybersecurity  incidents;  terrorist  activities;  political
unrest; disease pandemics; catastrophic events; climate-related
incidents and natural disasters (such as earthquakes, tornadoes,
hurricanes  and  wildfires);  electrical  outage;  environmental
hazard; computer servers; communications or other services we
use;  our  employees  or  third  parties  with  whom  we  conduct
business.

Although we employ backup systems for our data, those backup
systems may be unavailable following a disruption, the affected
data may not have been backed up or may not be recoverable
from the backup, or the backup data may be costly to recover,
which could adversely affect our business.

Notwithstanding  evolving  technology  and  technology-based
risk  and  control  systems,  our  businesses  ultimately  rely  on
people, including our employees and those of third parties with
which  we  conduct  business.  As  a  result  of  human  error  or
engagement in violations of applicable policies, laws, rules or
procedures,  certain  errors  or  violations  are  not  always
discovered immediately by our technological processes or by
our controls and other procedures, which are intended to prevent
and  detect  such  errors  or  violations.  These  can  include
calculation  errors,  mistakes  in  addressing  emails  or  other
communications, errors in software or model development or
implementation,  or  errors  in  judgment,  as  well  as  intentional
efforts to disregard or circumvent applicable policies, laws, rules
or procedures. Human errors and malfeasance, even if promptly
discovered  and  remediated,  can  result  in  material  losses  and
liabilities for us.

We conduct business in various jurisdictions outside the U.S.,
including jurisdictions that may not have comparable levels of
protection for their corporate assets such as intellectual property,
trademarks, trade secrets, know-how and customer information
and records. The protection afforded in those jurisdictions may
be less established and/or predictable than in the U.S. or other
jurisdictions in which we operate. As a result, there may also be
heightened risks associated with the potential theft of their data,
technology and intellectual property in those jurisdictions by
domestic or foreign actors, including private parties and those
affiliated with or controlled by state actors. Any theft of data,
technology or intellectual property may negatively impact our
operations  and  reputation,  including  disrupting  the  business
activities of our subsidiaries, affiliates, joint ventures or clients
conducting business in those jurisdictions.

A cyber attack, information or security breach or a technology
failure  could  adversely  affect  our  ability  to  conduct  our
business, manage our exposure to risk or result in disclosure
or  misuse  of  confidential  or  proprietary  information  and
otherwise adversely impact our results of operations, liquidity
and financial condition, as well as cause reputational harm.

We maintain a significant amount of personal information on
our customers, clients, employees and certain counterparties that
we  are  required  to  protect  under  various  state,  federal  and
international data protection and privacy laws. These laws may
be in conflict with one another, or courts and regulators may
interpret  them  in  ways  that  we  had  not  anticipated  or  that
adversely affect our business.

technologies, 

the  use  of 

Cybersecurity risks for financial institutions have significantly
increased in recent years in part because of the proliferation of
new 
internet,  mobile
telecommunications and cloud technologies to conduct financial
transactions, and the increased sophistication and activities of
organized crime, hackers, terrorists and other external extremist
parties, including foreign state actors, in some circumstances as
a means to promote political ends. In addition to the growing
sophistication of certain parties, the commoditization of cyber

the 

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December 2019 Form 10-K

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tools  which  are  able  to  be  weaponized  by  less  sophisticated
actors has led to an increase in the exploitation of technological
vulnerabilities. Global events and geopolitical instability may
lead to increased nation state targeting of financial institutions
in the U.S. and abroad. Foreign state actors have become more
sophisticated over time, increasing the risk of such an attack.
Any of these parties may also attempt to fraudulently induce
employees, customers, clients, vendors or other third parties or
users of our systems to disclose sensitive information in order
to gain access to our data or that of our employees or clients. 

Cybersecurity risks may also derive from human error, fraud or
malice on the part of our employees or third parties, including
third  party  providers,  or  may  result  from  accidental
technological failure. In addition, third parties with whom we
do business, their service providers, as well as other third parties
with whom our customers do business, may also be sources of
cybersecurity risks, particularly where activities of customers
are  beyond  our  security  and  control  systems.  There  is  no
guarantee  that  the  measures  we  take  will  provide  absolute
security  or  recoverability  given  the  techniques  used  in  cyber
attacks are complex and frequently change, and may not be able
to be anticipated. 

Like  other  financial  services  firms,  the  Firm,  its  third  party
providers,  and  its  clients  continue  to  be  the  subject  of
unauthorized  access  attacks,  mishandling  or  misuse  of
information,  computer  viruses  or  malware,  cyber  attacks
designed  to  obtain  confidential  information,  destroy  data,
disrupt  or  degrade  service,  sabotage  systems  or  cause  other
damage,  denial  of  service  attacks,  data  breaches  and  other
events. There can be no assurance that such unauthorized access,
mishandling or misuse of information, or cyber incidents will
not occur in the future, and they could occur more frequently
and on a more significant scale.

A cyber attack, information or security breach or a technology
failure of ours or of a third party could jeopardize our or our
clients’,  employees’,  partners’,  vendors’  or  counterparties’
information
personal,  confidential,  proprietary  or  other 
processed and stored in, and transmitted through, our and our
third parties’ computer systems. Furthermore, such events could
cause  interruptions  or  malfunctions  in  our,  our  clients’,
employees’, partners’, vendors’, counterparties’ or third parties’
operations,  as  well  as  the  unauthorized  release,  gathering,
monitoring,  misuse,  loss  or  destruction  of  confidential,
proprietary and other information of ours, our employees, our
customers or of other third parties. Any of these events could
result in reputational damage with our clients and the market,
client  dissatisfaction,  additional  costs  to  us  to  maintain  and
update our operational and security systems and infrastructure,
regulatory 
litigation  or  enforcement,  or
regulatory fines or penalties, any of which could adversely affect
our business, financial condition or results of operations.

investigations, 

Given our global footprint and the high volume of transactions
we process, the large number of clients, partners, vendors and

December 2019 Form 10-K

14

counterparties with which we do business, and the increasing
sophistication of cyber attacks, a cyber attack, information or
security breach could occur and persist for an extended period
of time without detection. We expect that any investigation of
a  cyber  attack  would  be  inherently  unpredictable  and  that  it
would take time before the completion of any investigation and
before  there  is  availability  of  full  and  reliable  information.
During such time we would not necessarily know the extent of
the harm or how best to remediate it, and certain errors or actions
could be repeated or compounded before they are discovered
and remediated, all or any of which would further increase the
costs and consequences of a cyber attack.

While  many  of  our  agreements  with  partners  and  third  party
vendors include indemnification provisions, we may not be able
to  recover  sufficiently,  or  at  all,  under  such  provisions  to
adequately offset any losses we may incur. In addition, although
we maintain insurance coverage that may, subject to policy terms
and conditions, cover certain aspects of cyber and information
security risks, such insurance coverage may be insufficient to
cover all losses.

We  continue  to  make  investments  with  a  view  toward
maintaining and enhancing its cybersecurity posture. The cost
of managing cyber and information security risks and attacks
along  with  complying  with  new,  increasingly  expansive,  and
evolving  regulatory  requirements  could  adversely  affect  our
results of operations and business.

Liquidity Risk

Liquidity risk refers to the risk that we will be unable to finance
our operations due to a loss of access to the capital markets or
difficulty  in  liquidating  our  assets.  Liquidity  risk  also
encompasses  our  ability  (or  perceived  ability)  to  meet  our
financial obligations without experiencing significant business
disruption or reputational damage that may threaten our viability
as  a  going  concern  as  well  as  the  associated  funding  risks
triggered by the market or idiosyncratic stress events that may
negatively affect our liquidity and may impact our ability to raise
new  funding.  For  more  information  on  how  we  monitor  and
manage  liquidity  risk,  see  “Management’s  Discussion  and
Analysis of Financial Condition and Results of Operations—
Liquidity  and  Capital  Resources”  and  “Quantitative  and
Qualitative Disclosures about Risk—Liquidity Risk.”

Liquidity is essential to our businesses and we rely on external
sources to finance a significant portion of our operations.

Liquidity is essential to our businesses. Our liquidity could be
negatively affected by our inability to raise funding in the long-
term or short-term debt capital markets, our inability to access
the secured lending markets, or unanticipated outflows of cash
or  collateral  by  customers  or  clients.  Factors  that  we  cannot
control, such as disruption of the financial markets or negative
views about the financial services industry generally, including

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concerns  regarding  fiscal  matters  in  the  U.S.  and  other
geographic areas, could impair our ability to raise funding.

Incremental Collateral or Terminating Payments upon Potential
Future Rating Downgrade.”

In  addition,  our  ability  to  raise  funding  could  be  impaired  if
investors or lenders develop a negative perception of our long-
term or short-term financial prospects due to factors such as an
incurrence of large trading losses, a downgrade by the rating
agencies,  a  decline  in  the  level  of  our  business  activity,  if
regulatory authorities take significant action against us or our
industry,  or  we  discover  significant  employee  misconduct  or
illegal activity.

likely  need 

to  finance  or 

If we are unable to raise funding using the methods described
above,  we  would 
liquidate
unencumbered  assets,  such  as  our  investment  portfolios  or
trading assets, to meet maturing liabilities or other obligations.
We may be unable to sell some of our assets or we may have to
sell assets at a discount to market value, either of which could
adversely  affect  our  results  of  operations,  cash  flows  and
financial condition.

Our borrowing costs and access to the debt capital markets
depend on our credit ratings.

The cost and availability of unsecured financing generally are
impacted by our long-term and short-term credit ratings. The
rating agencies continue to monitor certain company-specific
and industry-wide factors that are important to the determination
of our credit ratings. These include governance, the level and
quality of earnings, capital adequacy, liquidity and funding, risk
appetite  and  management,  asset  quality,  strategic  direction,
business  mix,  regulatory  or  legislative  changes,  macro-
economic environment, and perceived levels of support, and it
is possible that they could downgrade our ratings and those of
similar institutions.

Our credit ratings also can have a significant impact on certain
trading revenues, particularly in those businesses where longer
term counterparty performance is a key consideration, such as
OTC  and  other  derivative  transactions,  including  credit
derivatives and interest rate swaps. In connection with certain
OTC  trading  agreements  and  certain  other  agreements
associated with our Institutional Securities business segment,
we  may  be  required  to  provide  additional  collateral  to,  or
immediately  settle  any  outstanding  liability  balance  with,
certain counterparties in the event of a credit ratings downgrade.

Termination of our trading and other agreements could cause us
to sustain losses and impair our liquidity by requiring us to find
other sources of financing or to make significant cash payments
or  securities  movements.  The  additional  collateral  or
termination payments which may occur in the event of a future
credit rating downgrade vary by contract and can be based on
ratings by either or both of Moody’s Investors Service, Inc. and
S&P Global Ratings. See also “Management’s Discussion and
Analysis of Financial Condition and Results of Operations—
and  Capital  Resources—Credit  Ratings—
Liquidity 

We are a holding company and depend on payments from our
subsidiaries.

The  Parent  Company  has  no  operations  and  depends  on
dividends, distributions and other payments from its subsidiaries
to  fund  dividend  payments  and  to  fund  all  payments  on  its
obligations, including debt obligations. Regulatory restrictions,
tax restrictions or elections and other legal restrictions may limit
our  ability  to  transfer  funds  freely,  either  to  or  from  our
subsidiaries. In particular, many of our subsidiaries, including
our  bank  and  broker-dealer  subsidiaries,  are  subject  to  laws,
regulations and self-regulatory organization rules that limit, as
well as authorize regulatory bodies to block or reduce, the flow
of funds to the Parent Company, or that prohibit such transfers
or dividends altogether in certain circumstances, including steps
to “ring fence” entities by regulators outside of the U.S. to protect
clients and creditors of such entities in the event of financial
difficulties involving such entities.

These  laws,  regulations  and  rules  may  hinder  our  ability  to
access  funds  that  we  may  need  to  make  payments  on  our
obligations. Furthermore, as a BHC, we may become subject to
a prohibition or to limitations on our ability to pay dividends.
The Federal Reserve, the OCC, and the FDIC have the authority,
and under certain circumstances the duty, to prohibit or to limit
the  payment  of  dividends  by  the  banking  organizations  they
supervise, including us and our U.S. Bank Subsidiaries.

Our liquidity and financial condition have in the past been,
and  in  the  future  could  be,  adversely  affected  by  U.S.  and
international markets and economic conditions.

Our ability to raise funding in the long-term or short-term debt
capital  markets  or  the  equity  markets,  or  to  access  secured
lending markets, has in the past been, and could in the future
be, adversely affected by conditions in the U.S. and international
markets and economies.

In particular, our cost and availability of funding in the past have
been, and may in the future be, adversely affected by illiquid
credit markets and wider credit spreads. Significant turbulence
in  the  U.S.,  the  E.U.  and  other  international  markets  and
economies  could  adversely  affect  our  liquidity  and  financial
condition  and  the  willingness  of  certain  counterparties  and
customers to do business with us.

Legal, Regulatory and Compliance Risk

Legal, regulatory and compliance risk includes the risk of legal
or regulatory sanctions, material financial loss, including fines,
penalties,  judgments,  damages  and/or  settlements,  or  loss  to
reputation we may suffer as a result of our failure to comply
with 
self-regulatory
organization standards and codes of conduct applicable to our

regulations, 

related 

rules, 

laws, 

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December 2019 Form 10-K

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business  activities.  This  risk  also  includes  contractual  and
commercial  risk,  such  as  the  risk  that  a  counterparty’s
performance obligations will be unenforceable. It also includes
compliance with AML, anti-corruption and terrorist financing
rules and regulations. For more information on how we monitor
and  manage  legal,  regulatory  and  compliance  risk,  see
“Quantitative and Qualitative Disclosures about Risk—Legal
and Compliance Risk.”

The  financial  services  industry  is  subject  to  extensive
regulation,  and  changes  in  regulation  will  impact  our
business.

Like  other  major  financial  services  firms,  we  are  subject  to
extensive  regulation  by  U.S.  federal  and  state  regulatory
agencies  and  securities  exchanges  and  by  regulators  and
exchanges in each of the major markets where we conduct our
business. These laws and regulations significantly affect the way
we  do  business  and  can  restrict  the  scope  of  our  existing
businesses and limit our ability to expand our product offerings
and pursue certain investments.

The  Firm  and  its  employees  are,  or  will  become,  subject  to
(among other things) wide-ranging regulation and supervision,
intensive scrutiny of our businesses and any plans for expansion
of  those  businesses,  limitations  on  new  activities,  a  systemic
risk regime that imposes heightened capital and liquidity and
funding requirements and other enhanced prudential standards,
resolution  regimes  and  resolution  planning  requirements,
requirements for maintaining minimum amounts of TLAC and
external 
long-term  debt,  restrictions  on  activities  and
investments  imposed  by  the  Volcker  Rule,  comprehensive
derivatives  regulation,  market  structure  regulation, 
tax
regulations,  antitrust  laws,  trade  and  transaction  reporting
obligations, and broadened fiduciary obligations.

In  some  areas,  regulatory  standards  are  subject  to  final
rulemaking or transition periods or may otherwise be revised in
whole  or  in  part.  Ongoing  implementation  of,  or  changes  in,
laws and regulations could materially impact the profitability of
our businesses and the value of assets we hold, expose us to
additional costs, require changes to business practices or force
us to discontinue businesses, adversely affect our ability to pay
dividends and repurchase our stock or require us to raise capital,
including in ways that may adversely impact our shareholders
or creditors.

In addition, regulatory requirements that are being imposed by
foreign  policymakers  and  regulators  may  be  inconsistent  or
conflict with regulations that we are subject to in the U.S. and
may  adversely  affect  us.  Legal  and  regulatory  requirements
continue to be subject to ongoing change, which may result in
significant  new  costs  to  comply  with  new  or  revised
requirements as well as to monitor for compliance on an ongoing
basis.

December 2019 Form 10-K

16

The application of regulatory requirements and strategies in
the  U.S.  or  other  jurisdictions  to  facilitate  the  orderly
resolution of large financial institutions may pose a greater
risk of loss for our security holders, and subject us to other
restrictions.

Pursuant to the Dodd-Frank Act, we are required to periodically
submit to the Federal Reserve and the FDIC a resolution plan
that  describes  our  strategy  for  a  rapid  and  orderly  resolution
under  the  U.S.  Bankruptcy  Code  in  the  event  of  material
financial distress or failure. If the Federal Reserve and the FDIC
were to jointly determine that our resolution plan submission
was not credible or would not facilitate an orderly resolution,
and if we were unable to address any deficiencies identified by
the regulators, we or any of our subsidiaries may be subject to
more  stringent  capital,  leverage,  or  liquidity  requirements  or
restrictions on our growth, activities, or operations, or after a
two-year  period,  we  may  be  required  to  divest  assets  or
operations.

In addition, provided that certain procedures are met, we can be
subject to a resolution proceeding under the orderly liquidation
authority under Title II of the Dodd-Frank Act with the FDIC
being appointed as receiver. The FDIC’s power under the orderly
liquidation authority to disregard the priority of creditor claims
and  treat  similarly  situated  creditors  differently  in  certain
circumstances,  subject  to  certain  limitations,  could  adversely
impact  holders  of  our  unsecured  debt.  See  “Business—
Supervision  and  Regulation”  and  “Management’s  Discussion
and Analysis of Financial Condition and Results of Operations
—Liquidity 
Regulatory
Requirements.”

Resources— 

Capital 

and 

Further, because both our resolution plan contemplates an SPOE
strategy  under  the  U.S.  Bankruptcy  Code  and  the  FDIC  has
proposed  an  SPOE  strategy  through  which  it  may  apply  its
orderly  liquidation  authority  powers,  we  believe  that  the
application of an SPOE strategy is the reasonably likely outcome
if either our resolution plan were implemented or a resolution
proceeding  were  commenced  under  the  orderly  liquidation
authority.  An  SPOE  strategy  generally  contemplates  the
provision  of  adequate  capital  and  liquidity  by  the  Parent
Company to certain of its subsidiaries so that such subsidiaries
have  the  resources  necessary  to  implement  the  resolution
strategy,  and  the  Parent  Company  has  entered  into  a  secured
amended  and  restated  support  agreement  with  its  material
entities, as defined in our resolution plan, pursuant to which it
would provide such capital and liquidity to such entities.

In further development of our SPOE strategy, we have created
a  wholly  owned,  direct  subsidiary  of  the  Parent  Company,
Morgan Stanley Holdings LLC (“Funding IHC”), to serve as a
resolution  funding  vehicle.  The  Parent  Company  has
transferred,  and  has  agreed  to  transfer  on  an  ongoing  basis,
certain assets to the Funding IHC. In the event of a resolution
scenario, the Parent Company would be obligated to contribute
all of its material assets that can be contributed under the terms

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of  the  amended  and  restated  support  agreement  (other  than
shares in subsidiaries of the Parent Company and certain other
assets)  (“Contributable  Assets”),  to  the  Funding  IHC.  The
Funding IHC would be obligated to provide capital and liquidity,
as applicable, to our material entities.

The obligations of the Parent Company and the Funding IHC
under the amended and restated support agreement are in most
cases  secured  on  a  senior  basis  by  the  assets  of  the  Parent
Company  (other  than  shares  in  subsidiaries  of  the  Parent
Company and certain other assets), and the assets of the Funding
IHC. As a result, claims of our material entities, including the
Funding IHC, against the assets of the Parent Company with
respect to such secured assets are effectively senior to unsecured
obligations of the Parent Company.

Although an SPOE strategy, whether applied pursuant to our
resolution plan or in a resolution proceeding under the orderly
liquidation authority, is intended to result in better outcomes for
creditors overall, there is no guarantee that the application of an
SPOE strategy, including the provision of support to the Parent
Company’s material entities pursuant to the secured amended
and restated support agreement, will not result in greater losses
for holders of our securities compared to a different resolution
strategy for us.

Regulators have taken and proposed various actions to facilitate
an SPOE strategy under the U.S. Bankruptcy Code, the orderly
liquidation authority and other resolution regimes. For example,
the  Federal  Reserve  requires  top-tier  BHCs  of  U.S.  G-SIBs,
including the Firm, to maintain minimum amounts of equity and
eligible  long-term  debt  TLAC  in  order  to  ensure  that  such
institutions have enough loss-absorbing resources at the point
of failure to be recapitalized through the conversion of debt to
equity or otherwise by imposing losses on eligible TLAC where
the  SPOE  strategy  is  used. The  combined  implication  of  the
SPOE resolution strategy and the TLAC requirement is that our
losses will be imposed on the holders of eligible long-term debt
and other forms of eligible TLAC issued by the Parent Company
before  any  losses  are  imposed  on  the  holders  of  the  debt
securities of our operating subsidiaries or before putting U.S.
taxpayers at risk.

In addition, certain jurisdictions, including the U.K. and other
E.U. jurisdictions, have implemented, or are in the process of
implementing,  changes  to  resolution  regimes  to  provide
resolution authorities with the ability to recapitalize a failing
entity organized in such jurisdiction by writing down certain
unsecured liabilities or converting certain unsecured liabilities
into equity. Such “bail-in” powers are intended to enable the
recapitalization of a failing institution by allocating losses to its
shareholders and unsecured creditors. Non-U.S. regulators are
also considering requirements that certain subsidiaries of large
financial institutions maintain minimum amounts of TLAC that
would  pass  losses  up  from  the  subsidiaries  to  the  Parent
Company  and,  ultimately,  to  security  holders  of  the  Parent
Company in the event of failure.

We may be prevented from paying dividends or taking other
capital  actions  because  of  regulatory  constraints  or  revised
regulatory capital standards.

We  are  subject  to  comprehensive  consolidated  supervision,
regulation  and  examination  by  the  Federal  Reserve,  which
requires  us  to  submit,  on  an  annual  basis,  a  capital  plan
describing  proposed  dividend  payments  to  shareholders,
proposed  repurchases  of  our  outstanding  securities  and  other
proposed  capital  actions  that  we  intend  to  take.  The  Federal
Reserve may object to, or otherwise require us to modify, such
plan, or may object or require modifications to a resubmitted
capital plan, any of which would adversely affect shareholders.

In addition, beyond review of the plan, the Federal Reserve may
impose other restrictions or conditions on us that prevent us from
paying or increasing dividends, repurchasing securities or taking
other capital actions that would benefit shareholders.

Finally,  the  Federal  Reserve  may  change  regulatory  capital
standards to impose higher requirements that restrict our ability
to take capital actions or may modify or impose other regulatory
standards that increase our operating expenses and reduce our
ability to take capital actions.

The financial services industry faces substantial litigation and
is  subject  to  extensive  regulatory  and  law  enforcement
investigations, and we may face damage to our reputation and
legal liability.

As  a  global  financial  services  firm,  we  face  the  risk  of
investigations  and  proceedings  by  governmental  and  self-
regulatory organizations in all countries in which we conduct
our business. Investigations and proceedings initiated by these
authorities may result in adverse judgments, settlements, fines,
penalties, injunctions or other relief. In addition to the monetary
consequences, these measures could, for example, impact our
ability  to  engage  in,  or  impose  limitations  on,  certain  of  our
businesses.

industry  and  certain  U.S.  and 

These investigations and proceedings, as well as the amount of
penalties  and  fines  sought,  continue  to  impact  the  financial
services 
international
governmental entities have brought criminal actions against, or
have sought criminal convictions, pleas or deferred prosecution
agreements from, financial institutions. Significant regulatory
or law enforcement action against us could materially adversely
affect our business, financial condition or results of operations
or cause us significant reputational harm, which could seriously
harm our business.

The  Dodd-Frank  Act  also  provides  compensation 
to
whistleblowers who present the SEC or CFTC with information
related to securities or commodities law violations that leads to
a  successful  enforcement  action.  As  a  result  of 
this
compensation, it is possible we could face an increased number
of investigations by the SEC or CFTC.

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We have been named, from time to time, as a defendant in various
legal  actions,  including  arbitrations,  class  actions  and  other
litigation, as well as investigations or proceedings brought by
regulatory agencies, arising in connection with our activities as
a global diversified financial services institution. Certain of the
actual or threatened legal or regulatory actions include claims
for substantial compensatory and/or punitive damages, claims
for  indeterminate  amounts  of  damages,  or  may  result  in
penalties, fines, or other results adverse to us.

In some cases, the issuers that would otherwise be the primary
defendants in such cases are bankrupt or are in financial distress.
In other cases, including antitrust litigation, we may be subject
to claims for joint and several liability with other defendants for
treble  damages  or  other  relief  related  to  alleged  conspiracies
involving other institutions. Like any large corporation, we are
also  subject  to  risk  from  potential  employee  misconduct,
including  non-compliance  with  policies  and  improper  use  or
disclosure  of  confidential  information,  or  improper  sales
practices or conduct.

We  may  be  responsible  for  representations  and  warranties
associated with residential and commercial real estate loans
and may incur losses in excess of our reserves.

We  originate  loans  secured  by  commercial  and  residential
properties. Further, we securitize and trade in a wide range of
commercial  and  residential  real  estate  and  real  estate-related
whole loans, mortgages and other real estate and commercial
assets  and  products,  including  residential  and  CMBS.  In
connection with these activities, we have provided, or otherwise
agreed  to  be  responsible  for,  certain  representations  and
warranties. Under certain circumstances, we may be required to
repurchase such assets or make other payments related to such
assets if such representations and warranties were breached. We
have  also  made  representations  and  warranties  in  connection
with our role as an originator of certain commercial mortgage
loans that we securitized in CMBS. For additional information,
see also Note 13 to the financial statements.

We currently have several legal proceedings related to claims
for alleged breaches of representations and warranties. If there
are decisions adverse to us in those legal proceedings, we may
incur losses substantially in excess of our reserves. In addition,
our  reserves  are  based,  in  part,  on  certain  factual  and  legal
assumptions. If those assumptions are incorrect and need to be
revised, we may need to adjust our reserves substantially.

Our  commodities  activities  and  investments  subject  us  to
extensive regulation, and environmental risks and regulation
that may expose us to significant costs and liabilities.

In connection with the commodities activities in our Institutional
Securities business segment, we execute transactions involving
the  storage,  transportation  and  market-making  of  several
commodities,  including  metals,  natural  gas,  electric  power,
environmental  attributes  and  other  commodity  products.  In

December 2019 Form 10-K

18

addition, we are an electricity power marketer in the U.S. These
activities  subject  us  to  extensive  energy,  commodities,
environmental, health and safety and other governmental laws
and regulations.

Although we have attempted to mitigate our environmental risks
by,  among  other  measures,  limiting  the  scope  of  activities
involving  storage  and  transportation,  adopting  appropriate
policies and procedures, and implementing emergency response
programs, these actions may not prove adequate to address every
contingency. In addition, insurance covering some of these risks
may not be available, and the proceeds, if any, from insurance
recovery may not be adequate to cover liabilities with respect
to  particular  incidents.  As  a  result,  our  financial  condition,
results of operations and cash flows may be adversely affected
by these events.

During  the  past  several  years,  intensified  scrutiny  of  certain
energy markets by federal, state and local authorities in the U.S.
and abroad and by the public has resulted in increased regulatory
and  legal  enforcement,  litigation  and  remedial  proceedings
involving companies conducting the activities in which we are
engaged. In addition, enhanced regulation of OTC derivatives
markets in the U.S. and the E.U., as well as similar legislation
proposed or adopted elsewhere, will impose significant costs
and requirements on our commodities derivatives activities.

We may incur substantial costs or loss of revenue in complying
with  current  or  future  laws  and  regulations  and  our  overall
businesses  and  reputation  may  be  adversely  affected  by  the
current legal environment. In addition, failure to comply with
these laws and regulations may result in substantial civil and
criminal fines and penalties.

A failure to address conflicts of interest appropriately could
adversely affect our businesses and reputation.

financial 

As a global financial services firm that provides products and
services to a large and diversified group of clients, including
and
corporations,  governments, 
individuals, we face potential conflicts of interest in the normal
course of business. For example, potential conflicts can occur
when there is a divergence of interests between us and a client,
among clients, between an employee on the one hand and us or
a client on the other, or situations in which we may be a creditor
of a client.

institutions 

We have policies, procedures and controls that are designed to
identify and address potential conflicts of interest, and we utilize
various measures, such as the use of disclosure, to manage these
potential  conflicts.  However,  identifying  and  mitigating
potential conflicts of interest can be complex and challenging
and  can  become  the  focus  of  media  and  regulatory  scrutiny.
Indeed, actions that merely appear to create a conflict can put
our reputation at risk even if the likelihood of an actual conflict
has been mitigated. It is possible that potential conflicts could
give rise to litigation or enforcement actions, which may lead

Table of Contents

to  our  clients  being  less  willing  to  enter  into  transactions  in
which  a  conflict  may  occur  and  could  adversely  affect  our
businesses and reputation.

Our regulators have the ability to scrutinize our activities for
potential  conflicts  of  interest,  including  through  detailed
examinations of specific transactions. For example, our status
as a BHC supervised by the Federal Reserve subjects us to direct
Federal Reserve scrutiny with respect to transactions between
our  U.S.  Bank  Subsidiaries  and  their  affiliates.  Further,  the
Volcker Rule subjects us to regulatory scrutiny regarding certain
transactions between us and our clients.

Risk Management

Our risk management strategies, models and processes may
not be fully effective in mitigating our risk exposures in all
market environments or against all types of risk, which could
result in unexpected losses.

We  have  devoted  significant  resources  to  develop  our  risk
management capabilities and expect to continue to do so in the
future. Nonetheless, our risk management strategies, models and
processes, including our use of various risk models for assessing
market exposures and hedging strategies, stress testing and other
analysis,  may  not  be  fully  effective  in  mitigating  our  risk
exposure in all market environments or against all types of risk,
including risks that are unidentified or unanticipated.

As our businesses change and grow, and the markets in which
we operate evolve, our risk management strategies, models and
processes may not always adapt with those changes. Some of
our methods of managing risk are based upon our use of observed
historical market behavior and management’s judgment. As a
result,  these  methods  may  not  predict  future  risk  exposures,
which could be significantly greater than the historical measures
indicate.

In addition, many models we use are based on assumptions or
inputs  regarding  correlations  among  prices  of  various  asset
classes  or  other  market  indicators  and  therefore  cannot
anticipate  sudden,  unanticipated  or  unidentified  market  or
economic movements, which could cause us to incur losses.

Management  of  market,  credit,  liquidity,  operational,  model,
legal,  regulatory  and  compliance  risks  requires,  among  other
things, policies and procedures to record properly and verify a
large number of transactions and events, and these policies and
procedures  may  not  be  fully  effective.  Our  trading  risk
management strategies and techniques also seek to balance our
ability  to  profit  from  trading  positions  with  our  exposure  to
potential losses.

While we employ a broad and diversified set of risk monitoring
and  risk  mitigation  techniques,  those  techniques  and  the
judgments that accompany their application cannot anticipate
every economic and financial outcome or the timing of such

outcomes. For example, to the extent that our trading or investing
activities involve less liquid trading markets or are otherwise
subject to restrictions on sales or hedging, we may not be able
to reduce our positions and therefore reduce our risk associated
with such positions. We may, therefore, incur losses in the course
of our trading or investing activities. For more information on
how we monitor and manage market and certain other risks and
related strategies, models and processes, see “Quantitative and
Qualitative Disclosures about Risk—Market Risk.”

Planned replacement of London Interbank Offered Rate and
replacement or reform of other interest rate benchmarks could
adversely affect our business, financial condition and results
of operations.

Central banks around the world, including the Federal Reserve,
have commissioned working groups of market participants and
official sector representatives to replace LIBOR and replace or
reform  other  interest  rate  benchmarks  (collectively,  the
“IBORs”). A transition away from the widespread use of such
rates  to  alternative  rates  and  other  potential  interest  rate
benchmark reforms has begun and will continue over the course
of the next few years. For example, the FCA, which regulates
LIBOR,  has  announced  that  it  has  commitments  from  panel
banks to continue to contribute to LIBOR through the end of
2021, but that it will not use its powers to compel contributions
beyond such date. As a result, there is considerable uncertainty
regarding  the  publication  of  LIBOR  beyond  2021,  and
regulators globally have continued to emphasize the need for
the industry to plan accordingly.

The Federal Reserve Bank of New York now publishes three
reference  rates  based  on  overnight  U.S.  Treasury  repurchase
agreement  transactions,  including  the  Secured  Overnight
Financing Rate, which had been recommended as the alternative
to  U.S.  dollar  LIBOR  by  the  Alternative  Reference  Rates
Committee convened by the Federal Reserve and the Federal
Reserve Bank of New York. Further, the Bank of England is
publishing  a  reformed  Sterling  Overnight  Index  Average,
comprised of a broader set of overnight Sterling money market
transactions, which has been selected by the Working Group on
Sterling  Risk-Free  Reference  Rates  as  the  alternative  rate  to
Sterling LIBOR. Central bank-sponsored committees in other
jurisdictions,  including  Europe,  Japan  and  Switzerland,  have
selected  alternative  reference  rates  denominated  in  other
currencies.

The market transition away from IBORs to alternative reference
rates is complex and could have a range of adverse impacts on
our business, financial condition and results of operations. In
particular, such transition or reform could:

• Adversely impact the pricing, liquidity, value of, return on
and trading for a broad array of financial products, including
any  IBOR-linked  securities,  loans  and  derivatives  that  are
included in our financial assets and liabilities;

19

December 2019 Form 10-K

Table of Contents

• Require extensive changes to documentation that governs or
references  IBOR  or  IBOR-based  products,  including,  for
example,  pursuant  to  time-consuming  renegotiations  of
existing documentation to modify the terms of outstanding
securities and related hedging transactions;

• Result in a population of products with documentation that
governs or references IBOR or IBOR-based products but that
cannot  be  amended  due  to  an  inability  to  obtain  sufficient
consent from counterparties or product owners;

• Result in inquiries or other actions from regulators in respect
of  our  (or  the  market’s)  preparation  and  readiness  for  the
replacement  of  an  IBOR  with  one  or  more  alternative
reference rates;

• Result  in  disputes,  litigation  or  other  actions  with  clients,
counterparties  and  investors,  in  various  scenarios,  such  as
regarding the interpretation and enforceability of provisions
in IBOR-based products such as fallback language or other
related provisions, including in the case of fallbacks to the
alternative reference rates, any economic, legal, operational
or other impact resulting from the fundamental differences
between the IBORs and the various alternative reference rates;

• Require  the  transition  and/or  development  of  appropriate
systems  and  analytics  to  effectively  transition  our  risk
management processes from IBORs to those based on one or
more alternative reference rates in a timely manner, including
by quantifying value and risk for various alternative reference
rates, which may prove challenging given the limited history
of the proposed alternative reference rates; and

• Cause us to incur additional costs in relation to any of the

above factors.

Other factors include the pace of the transition to the alternative
reference rates, timing mismatches between cash and derivative
markets,  the  specific  terms  and  parameters  for  and  market
acceptance of any alternative reference rate, market conventions
for the use of any alternative reference rate in connection with
a particular product (including the timing and market adoption
of any conventions proposed or recommended by any industry
or other group), prices of and the liquidity of trading markets
for products based on alternative reference rates, and our ability
to transition and develop appropriate systems and analytics for
one or more alternative reference rates.

Competitive Environment

We face strong competition from financial services firms and
others,  which  could  lead  to  pricing  pressures  that  could
materially adversely affect our revenue and profitability.

The financial services industry and all aspects of our businesses
are intensely competitive, and we expect them to remain so. We
compete  with  commercial  banks,  brokerage  firms,  insurance
trading  and  clearing
companies,  exchanges,  electronic 

December 2019 Form 10-K

20

platforms, financial data repositories, sponsors of mutual funds,
hedge funds, energy companies, financial technology firms and
other companies offering financial or ancillary services in the
U.S., globally and digitally or through the internet. We compete
on the basis of several factors, including transaction execution,
capital or access to capital, products and services, innovation,
technology, reputation, risk appetite and price.

Over time, certain sectors of the financial services industry have
become more concentrated, as institutions involved in a broad
range of financial services have left businesses, been acquired
by or merged into other firms, or have declared bankruptcy. Such
changes  could  result  in  our  remaining  competitors  gaining
greater capital and other resources, such as the ability to offer a
broader range of products and services and geographic diversity,
or new competitors may emerge.

We have experienced and may continue to experience pricing
pressures  as  a  result  of  these  factors  and  as  some  of  our
competitors seek to obtain market share by reducing prices or
providing more favorable terms of business. In addition, certain
of  our  competitors  may  be  subject  to  different,  and,  in  some
cases, less stringent, legal and regulatory regimes, than we are,
thereby  putting  us  at  a  competitive  disadvantage.  Some  new
competitors in the financial technology sector have sought to
target  existing  segments  of  our  businesses  that  could  be
susceptible to disruption by innovative or less regulated business
models.  For  more  information  regarding  the  competitive
environment 
in  which  we  operate,  see  “Business—
Competition” and “Business—Supervision and Regulation.”

Automated  trading  markets  and  the  introduction  and
application  of  new  technologies  may  adversely  affect  our
business and may increase competition.

the 

trading  platforms  and 

We have experienced intense price competition in some of our
businesses in recent years. In particular, the ability to execute
securities,  derivatives  and  other  financial  instrument  trades
electronically  on  exchanges,  swap  execution  facilities,  other
introduction  and
automated 
application of new technologies has increased the pressure on
bid-offer spreads, commissions, markups or comparable fees.
The trend toward direct access to automated, electronic markets
will likely continue and will likely increase as additional markets
move 
trading  platforms.  We  have
experienced and it is likely that we will continue to experience
competitive pressures in these and other areas in the future as
some of our competitors may seek to obtain market share by
reducing bid-offer spreads, commissions, markups or fees.

to  more  automated 

Our ability to retain and attract qualified employees is critical
to the success of our business and the failure to do so may
materially adversely affect our performance.

Our people are our most important resource and competition for
qualified employees is intense. If we are unable to continue to
attract and retain highly qualified employees, or do so at levels

Table of Contents

or in forms necessary to maintain our competitive position, or
if compensation costs required to attract and retain employees
become  more  expensive,  our  performance,  including  our
competitive  position  and  results  of  operations,  could  be
materially adversely affected.

stringent 

The  financial  industry  has  experienced  and  may  continue  to
experience  more 
employee
compensation, including limitations relating to incentive-based
compensation,  clawback  requirements  and  special  taxation,
which could have an adverse effect on our ability to hire or retain
the most qualified employees.

regulation 

of 

International Risk

We  are  subject  to  numerous  political,  economic,  legal,  tax,
operational,  franchise  and  other  risks  as  a  result  of  our
international  operations  which  could  adversely  impact  our
businesses in many ways.

We  are  subject  to  numerous  political,  economic,  legal,  tax,
operational,  franchise  and  other  risks  that  are  inherent  in
operating  in  many  countries,  including  risks  of  possible
nationalization, expropriation, price controls, capital controls,
exchange  controls,  increased  taxes  and  levies,  and  other
restrictive  governmental  actions,  as  well  as  the  outbreak  of
hostilities  or  political  and  governmental  instability.  In  many
countries, the laws and regulations applicable to the securities
and financial services industries are uncertain and evolving, and
it may be difficult for us to determine the exact requirements of
local laws in every market.

Our  inability  to  remain  in  compliance  with  local  laws  in  a
particular market could have a significant and negative effect
not only on our business in that market but also on our reputation
generally. We are also subject to the risk that transactions we
structure might not be legally enforceable in all cases.

financial  disruptions, 

Various  emerging  market  countries  have  experienced  severe
political,  economic  or 
including
significant devaluations of their currencies, defaults or potential
defaults  on  sovereign  debt,  capital  and  currency  exchange
controls, high rates of inflation and low or negative growth rates
in their economies. Crime and corruption, as well as issues of
security  and  personal  safety,  also  exist  in  certain  of  these
countries.  These  conditions  could  adversely  impact  our
businesses and increase volatility in financial markets generally.

The emergence of a disease pandemic, such as the coronavirus,
or  other  widespread  health  emergencies,  natural  disasters,
terrorist  activities  or  military  actions,  or  social  or  political
tensions,  could  create  economic  and  financial  disruptions  in
emerging markets or in other areas of the global economy that
could  adversely  affect  our  businesses,  or  could  lead  to
operational difficulties (including travel limitations) that could
impair our ability to manage or conduct our businesses around
the world.

As a U.S. company, we are required to comply with the economic
sanctions and embargo programs administered by OFAC and
similar  multi-national  bodies  and  governmental  agencies
worldwide,  as  well  as  applicable  anti-corruption  laws  in  the
jurisdictions  in  which  we  operate,  such  as  the  U.S.  Foreign
Corrupt Practices Act and the U.K. Bribery Act. A violation of
a  sanction,  embargo  program,  or  anti-corruption  law  could
subject  us,  and 
to  a  regulatory
individual  employees, 
enforcement  action  as  well  as  significant  civil  and  criminal
penalties.

The U.K.’s withdrawal from the E.U. could adversely affect
us.

It is difficult to predict the future of the U.K.’s relationship with
the E.U., the uncertainty of which may increase the volatility in
the global financial markets in the short- and medium-term and
may negatively disrupt regional and global financial markets.
Additionally, depending on the outcome, such uncertainty may
adversely affect the manner in which we operate certain of our
businesses in Europe.

On January 31, 2020, the U.K. withdrew from the E.U. under
the terms of a withdrawal agreement between the U.K. and the
E.U. The withdrawal agreement provides for a transition period
to the end of December 2020, during which time the U.K. will
continue to apply E.U. law as if it were a member state, and U.K.
firms' passporting rights to provide financial services in E.U.
jurisdictions will continue. Under the terms of the withdrawal
agreement the U.K. and the E.U. may agree to an extension of
the  transition  period  for  up  to  two  years,  although  the  U.K.
Government has signaled that it will not seek any extension.

With  respect  to  financial  services,  the  withdrawal  agreement
provides that the U.K. and the E.U. will endeavor to conclude
by June 2020 whether they will grant each other equivalence
under  European  financial  regulations.  Equivalence  would
provide a degree of access to E.U. markets for U.K. financial
firms, although the extent and duration of such access remains
subject to negotiation.

If equivalence (or any alternative arrangement) is not agreed,
our U.K. licensed entities may be unable to provide regulated
services  in  a  number  of  E.U.  jurisdictions  from  the  end  of
December 2020, absent further regulatory relief. 

Potential effects of the U.K. exit from the E.U. and potential
mitigation  actions  may  vary  considerably  depending  on  the
nature of the future trading arrangements between the U.K. and
the E.U. 

While we have taken steps to make changes to our European
operations in an effort to ensure that we can continue to provide
cross-border banking and investment and other services in E.U.
member  states  without  the  need  for  separate  regulatory
authorizations in each member state, as a result of the political
uncertainty described above, it is currently unclear what the final

21

December 2019 Form 10-K

For more information regarding the regulatory environment in
which  we  operate,  see  also  “Business—Supervision  and
Regulation.”

Table of Contents

post-Brexit structure of our European operations will be. Given
the potential negative disruption to regional and global financial
markets,  and  depending  on  the  extent  to  which  we  may  be
required to make material changes to our European operations
beyond those implemented or planned, our results of operations
and business prospects could be negatively affected. See also
“Management’s Discussion and Analysis of Financial Condition
and Results of Operations—Liquidity and Capital Resources—
Regulatory Requirements—Regulatory Developments.”

Acquisition, Divestiture and Joint Venture Risk

We may be unable to fully capture the expected value from
acquisitions,  divestitures,  joint  ventures,  minority  stakes  or
strategic alliances.

In connection with past or future acquisitions, divestitures, joint
ventures, minority stakes or strategic alliances (including with
MUFG), we face numerous risks and uncertainties combining,
transferring,  separating  or  integrating  the  relevant  businesses
and  systems,  including  the  need  to  combine  or  separate
accounting  and  data  processing  systems  and  management
controls  and  to  integrate  relationships  with  clients,  trading
counterparties and business partners. Certain of these strategic
initiatives,  and  integration  thereof,  may  cause  us  to  incur
incremental  expenses  and  may  also  require  incremental
financial, management and other resources. 

In the case of joint ventures and minority stakes, we are subject
to  additional  risks  and  uncertainties  because  we  may  be
dependent upon, and subject to liability, losses or reputational
damage relating to systems, controls and personnel that are not
under our control. 

In addition, conflicts or disagreements between us and any of
our joint venture partners may negatively impact the benefits to
be achieved by the relevant joint venture.

There is no assurance that any of our acquisitions, divestitures
or investments will be successfully integrated or disaggregated
or yield all of the positive benefits and synergies anticipated. If
we are not able to integrate or disaggregate successfully our past
and future acquisitions or dispositions, there is a risk that our
results of operations, financial condition and cash flows may be
materially and adversely affected.

Certain  of  our  business  initiatives,  including  expansions  of
existing  businesses,  may  bring  us  into  contact,  directly  or
indirectly, with individuals and entities that are not within our
traditional client and counterparty base and may expose us to
new  asset  classes,  services,  competitors,  and  new  markets.
These business activities expose us to new and enhanced risks,
greater regulatory scrutiny of these activities, increased credit-
related,  sovereign  and  operational  risks,  and  reputational
concerns regarding the manner in which these assets are being
operated or held, or services are being delivered.

December 2019 Form 10-K

22

Table of Contents

Selected Financial Data

Income Statement Data

Financial Measures

2019

2018

2017

2016

2015

2019

2018

2017

2016

2015

$ in millions

Revenues

Total non-interest

revenues1

Interest income

Interest expense

Net interest

Net revenues

Non-interest expenses

Compensation and

benefits

Non-compensation

expenses1

Total non-interest

expenses

Income from continuing

operations before
income taxes

Provision for (benefit
from) income taxes

Income from continuing

operations

Income (loss) from

discontinued
operations, net of
income taxes

Net income

Net income applicable to
noncontrolling interests

Net income applicable to

Morgan Stanley

Preferred stock dividends

and other

Earnings applicable to

Morgan Stanley
common
shareholders

$ 36,725

$ 36,301

$ 34,645

$ 30,933

$ 32,062

17,098

13,892

12,404

10,086

4,694

3,806

8,997

5,697

3,300

7,016

3,318

3,698

5,835

2,742

3,093

41,419

40,107

37,945

34,631

35,155

18,837

17,632

17,166

15,878

16,016

11,281

11,238

10,376

9,905

10,644

30,118

28,870

27,542

25,783

26,660

11,301

11,237

10,403

8,848

8,495

2,064

2,350

4,168

2,726

2,200

9,237

8,887

6,235

6,122

6,295

—

(4)

(19)

1

(16)

$ 9,237

$ 8,883

$ 6,216

$ 6,123

$ 6,279

195

135

105

144

152

$ 9,042

$ 8,748

$ 6,111

$ 5,979

$ 6,127

530

526

523

471

456

$ 8,512

$ 8,222

$ 5,588

$ 5,508

$ 5,671

Amounts applicable to Morgan Stanley

Income from continuing

operations

Income (loss) from

discontinued operations

Net income applicable
to Morgan Stanley

Effective income tax

rate from continuing
operations

$ 9,042

$ 8,752

$ 6,130

$ 5,978

$ 6,143

—

(4)

(19)

1

(16)

$ 9,042

$ 8,748

$ 6,111

$ 5,979

$ 6,127

18.3%

20.9%

40.1%

30.8%

25.9%

ROE2
ROTCE2, 3

11.7%

13.4%

11.8%

13.5%

8.0%

9.2%

8.0%

9.3%

8.5%

9.9%

Common Share-Related Data

Per common share
Earnings (basic)4
Earnings (diluted)4
Book value5

Tangible book

value3, 5

Dividends declared

2019

2018

2017

2016

2015

$

5.26 $

4.81 $

3.14 $

2.98 $

5.19

45.82

40.01

1.30

4.73

42.20

36.99

1.10

3.07

38.52

33.46

0.90

2.92

36.99

31.98

0.70

2.97

2.90

35.24

30.26

0.55

Common shares outstanding

in millions

At December 31

Annual average:

Basic

Diluted

Balance Sheet Data

1,594

1,700

1,788

1,852

1,920

1,617

1,640

1,708

1,738

1,780

1,821

1,849

1,887

1,909

1,953

$ in millions
GLR6
Loans7

Total assets

Deposits

Borrowings

Morgan Stanley

shareholders’ equity

Common

2019

2018

2017

2016

2015

$217,457 $249,735 $192,660 $202,297 $203,264

130,637

115,579

104,126

94,248

85,759

895,429

853,531

851,733

814,949

787,465

190,356

187,820

159,436

155,863

156,034

192,627

189,662

192,582

165,716

155,941

81,549

80,246

77,391

76,050

75,182

shareholders’ equity

73,029

71,726

68,871

68,530

67,662

Tangible common
shareholders’
equity3

63,780

62,879

59,829

59,234

58,098

1. Effective  January 1,  2018,  the  Firm  adopted  new  accounting  guidance  related  to
Revenue from Contracts with Customers, which, among other things, requires a gross
presentation of certain costs that were previously netted against net revenues. Prior
period results have not been restated pursuant to this guidance. 

2. ROE  and  ROTCE  represent  earnings  applicable  to  Morgan  Stanley  common
shareholders  as  a  percentage  of  average  common  equity  and  average  tangible
common equity, respectively.

3. Represents a non-GAAP measure. See “Executive Summary—Selected Non-GAAP

Financial Information.”

4. For further information on basic and diluted earnings (loss) per common share, see

Note 16 to the financial statements.

5. Book  value  per  common  share  and  tangible  book  value  per  common  share  equal
common shareholders’ equity and tangible common shareholders’ equity, respectively,
divided by common shares outstanding.

6. For a discussion of the GLR, see “Liquidity and Capital Resources—Liquidity Risk

Management Framework—Global Liquidity Reserve” herein.

7. Amounts include loans held for investment (net of allowance) and loans held for sale
but exclude loans at fair value, which are included in Trading assets in the balance
sheets (see Note 8 to the financial statements).

23

December 2019 Form 10-K

 
Table of Contents

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Introduction

Wealth  Management  provides  a  comprehensive  array  of
financial services and solutions to individual investors and
small to medium-sized businesses and institutions covering:
brokerage  and  investment  advisory  services;  financial  and
wealth planning services; stock plan administration services;
annuity  and  insurance  products;  securities-based  lending,
residential  real  estate  loans  and  other  lending  products;
banking; and retirement plan services.

include  equity,  fixed 

Investment Management provides a broad range of investment
strategies and products that span geographies, asset classes,
and public and private markets to a diverse group of clients
across institutional and intermediary channels. Strategies and
products, which are offered through a variety of investment
liquidity  and
vehicles, 
alternative/other  products.  Institutional  clients 
include
defined  benefit/defined  contribution  plans,  foundations,
endowments,  government  entities,  sovereign  wealth  funds,
fund  sponsors  and
third-party 
insurance  companies, 
corporations. Individual clients are generally served through
intermediaries, 
including  affiliated  and  non-affiliated
distributors.

income, 

The results of operations in the past have been, and in the future
may continue to be, materially affected by: competition; risk
factors;  legislative,  legal  and  regulatory  developments;  and
other factors. These factors also may have an adverse impact on
our ability to achieve our strategic objectives. Additionally, the
discussion  of  our  results  of  operations  herein  may  contain
forward-looking  statements.  These  statements,  which  reflect
management’s beliefs and expectations, are subject to risks and
uncertainties that may cause actual results to differ materially.
For a discussion of the risks and uncertainties that may affect
our  future  results,  see  “Forward-Looking  Statements,”
“Business—Competition,” 
and
Regulation,”    “Risk  Factors”  and  “Liquidity  and  Capital
Resources—Regulatory Requirements” herein.

“Business—Supervision 

Morgan Stanley is a global financial services firm that maintains
significant market positions in each of its business segments—
Institutional  Securities,  Wealth  Management  and  Investment
Management.  Morgan  Stanley,  through  its  subsidiaries  and
affiliates, provides a wide variety of products and services to a
large and diversified group of clients and customers, including
and
corporations,  governments, 
individuals.  Unless  the  context  otherwise  requires,  the  terms
“Morgan Stanley,” “Firm,” “us,” “we” or “our” mean Morgan
Stanley (the “Parent Company”) together with its consolidated
subsidiaries.  See  the  “Glossary  of  Common  Terms  and
Acronyms” for the definition of certain terms and acronyms used
throughout  this  Form  10-K.  For  an  analysis  of  2018  results
compared with 2017 results, see Part II, Item 7, “Management's
Discussion and Analysis of Financial Condition and Results of
Operations” in the 2018 Form 10-K.

institutions 

financial 

A description of the clients and principal products and services
of each of our business segments is as follows:

Institutional  Securities  provides  investment  banking,  sales
and  trading,  lending  and  other  services  to  corporations,
governments, financial institutions and high to ultra-high net
worth clients. Investment banking services consist of capital
raising  and  financial  advisory  services,  including  services
relating  to  the  underwriting  of  debt,  equity  and  other
securities,  as  well  as  advice  on  mergers  and  acquisitions,
restructurings,  real  estate  and  project  finance.  Sales  and
trading services include sales, financing, prime brokerage and
market-making activities in equity and fixed income products,
including  foreign  exchange  and  commodities.  Lending
activities include originating corporate loans and commercial
real  estate  loans,  providing  secured  lending  facilities,  and
extending  financing  to  sales  and  trading  customers.  Other
activities 
include  Asia  wealth  management  services,
investments and research.

December 2019 Form 10-K

24

Table of Contents
Management's Discussion and Analysis

Executive Summary

Overview of Financial Results

Consolidated Results

Net Revenues1
($ in millions)

Net Income Applicable to Morgan Stanley
($ in millions)

Earnings per Common Share2

Net Income Applicable to Morgan Stanley and Diluted EPS on
a U.S. GAAP and Adjusted Basis

$ in millions, except per share data

2019

2018

2017

Net income applicable to Morgan Stanley

U.S. GAAP
Adjusted—Non-GAAP3
Earnings per diluted common share
U.S. GAAP2
Adjusted—Non-GAAP3

$

9,042 $

8,748 $

6,111

8,694

8,545

7,079

$

5.19 $

4.73 $

4.98

4.61

3.07

3.60

1. Effective  January  1,  2018,  the  Firm  adopted  new  accounting  guidance  related  to
Revenue from Contracts with Customers, which among other things, requires a gross
presentation of certain costs that were previously netted against net revenues. 2017
results have not been restated pursuant to this guidance. 

2. For  further  information  on  basic  and  diluted  EPS,  see  Note  16  to  the  financial

statements.

3. Represents a non-GAAP measure, see “Selected Non-GAAP Financial Information”
herein.  Adjusted  amounts  exclude  net  discrete  tax  provisions  (benefits)  that  are
intermittent  and  include  those  that  are  recurring.  Provisions  (benefits)  related  to
conversion of employee share-based awards are expected to occur every year and,
as such, are considered recurring discrete tax items. For further information on the
net  discrete  tax  provisions  (benefits),  see  “Supplemental  Financial  Information—
Income Tax Matters” herein.

2019 Compared with 2018 

• We  reported  net  revenues  of  $41,419  million  in  2019
compared with $40,107 million in 2018. For 2019, net income
applicable to Morgan Stanley was $9,042 million, or $5.19
per diluted common share, compared with $8,748 million, or
$4.73 per diluted common share, in 2018.

• Results for 2019 and 2018 include intermittent net discrete
tax benefits of $348 million and $203 million or $0.21 and
$0.12  per  diluted  common  share,  respectively,  primarily
associated  with  remeasurement  of  reserves  and  related
interest  as  a  result  of  new  information  pertaining  to  the
resolution of multi-jurisdiction tax examinations.

• Excluding the intermittent net discrete tax items, net income
applicable to Morgan Stanley was $8,694 million, or $4.98
per  diluted  common  share  in  2019,  compared  with  $8,545
million,  or  $4.61  per  diluted  common  share,  in  2018  (see
“Selected Non-GAAP Financial Information” herein).

25

December 2019 Form 10-K

 
 
Table of Contents
Management's Discussion and Analysis

Non-interest Expenses1, 2
($ in millions)

Business Segment Results

Net Revenues by Segment1, 2
($ in millions)

Net Income Applicable to Morgan Stanley by Segment1
($ in millions)

1. The percentages on the bars in the chart represent the contribution of compensation

and benefits expenses and non-compensation expenses to the total.

2. Effective  January  1,  2018,  the  Firm  adopted  new  accounting  guidance  related  to
Revenue from Contracts with Customers, which among other things, requires a gross
presentation of certain costs that were previously netted against net revenues. 2017
results have not been restated pursuant to this guidance. 

2019 Compared with 2018 

• Compensation and benefits expenses of $18,837 million in
2019 increased 7% from $17,632 million in 2018. The 2019
results  reflect  increases  in  the  fair  value  of  investments  to
which  certain  deferred  compensation  plans  are  referenced,
carried interest, salaries, and severance-related costs. These
increases were partially offset by decreases in discretionary
incentive compensation and the roll-off of certain acquisition-
related employee retention loans.

• Non-compensation expenses of $11,281 million in 2019 were
relatively  unchanged  from  $11,238  million  in  2018,  with
increased 
lower
professional services expenses.

technology  offset  by 

investment 

in 

1. The percentages on the bars in the charts represent the contribution of each business
segment to the total of the applicable financial category and may not total to 100%
due to intersegment eliminations. See Note 21 to the financial statements for details
of intersegment eliminations.

2. Effective  January  1,  2018,  the  Firm  adopted  new  accounting  guidance  related  to
Revenue from Contracts with Customers, which among other things, requires a gross
presentation of certain costs that were previously netted against net revenues. This
new  guidance  had  the  effect  of  increasing  revenues  reported  in  the  Institutional
Securities and Investment Management business segments. 2017 results have not
been restated pursuant to this guidance.

December 2019 Form 10-K

26

Table of Contents
Management's Discussion and Analysis

2019 Compared with 2018

Financial Measures

• Institutional  Securities  net  revenues  of  $20,386  million  in
2019 were relatively unchanged from 2018, reflecting a mixed
market backdrop, with lower revenues from Equity sales and
trading and Investment banking offset by higher Fixed income
and Other sales and trading revenues.

• Wealth Management net revenues of $17,737 million in 2019
increased  3%  from  2018,  primarily  reflecting  higher
Transactional  revenues  due  to  gains  related  to  investments
associated with certain deferred compensation plans.

• Investment Management net revenues of $3,763 million in
2019 increased 37% from 2018, primarily reflecting higher
Investments  revenues,  principally  driven  by  an  underlying
investment's  initial  public  offering  within  an  Asia  private
equity fund.

Net Revenues by Region1, 2
($ in millions)

1. The percentages on the bars in the charts represent the contribution of each region

to the total. 

2. For a discussion of how the geographic breakdown for net revenues is determined,

see Note 21 to the financial statements.

Consolidated financial measures

ROE
Adjusted ROE1, 2
ROTCE1
Adjusted ROTCE1, 2
Expense efficiency ratio3
Pre-tax margin4
Worldwide employees
Pre-tax margin by segment4
Institutional Securities

Wealth Management

Investment Management

Capital ratios5

Common Equity Tier 1 capital

Tier 1 capital

Total capital

Tier 1 leverage

SLR

2019

2018

2017

11.7%

11.2%

13.4%

12.9%

72.7%

27.3%

11.8%

11.5%

13.5%

13.2%

72.0%

28.0%

8.0%

9.4%

9.2%

10.8%

72.6%

27.4%

60,431

60,348

57,633

27%

27%

26%

30%

26%

17%

30%

26%

18%

At
December 31,
2019

At
December 31,
2018

16.4%

18.6%

21.0%

8.3%

6.4%

16.9%

19.2%

21.8%

8.4%

6.5%

1. Represents a non-GAAP measure. See “Selected Non-GAAP Financial Information”

herein.

2. Adjusted amounts exclude net discrete tax provisions (benefits) that are intermittent
and include those that are recurring. Provisions (benefits) related to conversion of
employee share-based awards are expected to occur every year and, as such, are
considered recurring discrete tax items. For further information on the net discrete tax
provisions (benefits), see “Supplemental Financial Information—Income Tax Matters”
herein.

3. The expense efficiency ratio represents total non-interest expenses as a percentage

of net revenues.

4. Pre-tax margin represents income from continuing operations before income taxes

as a percentage of net revenues.

5. At  December  31,  2019  and  2018,  our  risk-based  capital  ratios  are  based  on  the
Standardized Approach rules. For a discussion of our capital ratios, see "Liquidity and
Capital Resources—Regulatory Requirements" herein.

Selected Non-GAAP Financial Information

We prepare our financial statements using U.S. GAAP. From
time  to  time,  we  may  disclose  certain  “non-GAAP  financial
measures”  in  this  document  or  in  the  course  of  our  earnings
releases,  earnings  and  other  conference  calls,  financial
presentations, definitive proxy statement and otherwise. A “non-
GAAP financial measure” excludes, or includes, amounts from
the most directly comparable measure calculated and presented
in  accordance  with  U.S.  GAAP. We  consider  the  non-GAAP
financial  measures  we  disclose  to  be  useful  to  us,  investors,
analysts  and  other  stakeholders  by  providing 
further
transparency  about,  or  an  alternate  means  of  assessing,  our
financial  condition,  operating  results,  prospective  regulatory
capital requirements or capital adequacy.

These measures are not in accordance with, or a substitute for,
U.S. GAAP and may be different from or inconsistent with non-
GAAP financial measures used by other companies. Whenever
we  refer  to  a  non-GAAP  financial  measure,  we  will  also
generally  define  it  or  present  the  most  directly  comparable

27

December 2019 Form 10-K

 
Table of Contents
Management's Discussion and Analysis

financial measure calculated and presented in accordance with
U.S.  GAAP,  along  with  a  reconciliation  of  the  differences
between the U.S. GAAP financial measure and the non-GAAP
financial measure.

The principal non-GAAP financial measures presented in this
document are set forth in the following tables.

Reconciliations  from  U.S.  GAAP  to  Non-GAAP  Consolidated
Financial Measures

$ in millions, except per share data

2019

2018

2017

Net income applicable to Morgan 

Stanley

Impact of adjustments

Adjusted net income applicable to 
Morgan Stanley—non-GAAP1

$ 9,042

$ 8,748

$ 6,111

(348)

(203)

968

$ 8,694

$ 8,545

$ 7,079

Earnings per diluted common share

$

5.19

$

4.73

$ 3.07

Impact of adjustments

(0.21)

(0.12)

0.53

Adjusted earnings per diluted common 

share —non-GAAP1

Effective income tax rate

Impact of adjustments

Adjusted effective income tax 

rate—non-GAAP1

$

4.98

$

4.61

$ 3.60

18.3%

20.9%

40.1 %

3.0%

1.8%

(9.3)%

21.3%

22.7%

30.8 %

$ in millions

Tangible equity

Average Monthly Balance
2017
2018
2019

Morgan Stanley shareholders’ equity

$ 81,240 $ 78,497 $ 78,230

Less: Goodwill and net intangible assets

(9,140)

(8,985)

(9,158)

Tangible Morgan Stanley shareholders’ 

equity

$ 72,100 $ 69,512 $ 69,072

Non-GAAP Financial Measures by Business Segment

$ in billions
Average common equity4, 5

Institutional Securities

Wealth Management

Investment Management

Average tangible common equity4, 5

Institutional Securities

Wealth Management

Investment Management
ROE6

Institutional Securities

Wealth Management

Investment Management

ROTCE6

Institutional Securities

Wealth Management

Investment Management

2019

2018

2017

$

40.4

$

40.8

$

40.2

18.2

2.5

16.8

2.6

17.2

2.4

$

39.9

$

40.1

$

39.6

10.2

1.5

9.2

1.7

9.3

1.6

10.4%

11.0%

7.8%

19.8%

20.0%

12.9%

28.9%

14.2%

10.1%

10.5%

35.6%

46.6%

11.2%

36.6%

22.2%

7.9%

23.8%

14.8%

1. Adjusted amounts exclude net discrete tax provisions (benefits) that are intermittent
and include those that are recurring. Provisions (benefits) related to conversion of
employee share-based awards are expected to occur every year and, as such, are
considered recurring discrete tax items. For further information on the net discrete tax
provisions (benefits), see “Supplemental Financial Information—Income Tax Matters”
herein.

2. ROE  and  ROTCE  represent  earnings  applicable  to  Morgan  Stanley  common
shareholders  as  a  percentage  of  average  common  equity  and  average  tangible
common equity, respectively. When excluding intermittent net discrete tax provisions
(benefits), both the numerator and average denominator are adjusted.

3. The calculations used in determining our “ROE and ROTCE Targets” referred to in
the following section are the Adjusted ROE and Adjusted ROTCE amounts shown in
this table.

4. Average  common  equity  and  average  tangible  common  equity  for  each  business
segment  is  determined  using  our  Required  Capital  framework  (see  "Liquidity  and
Capital  Resources—Regulatory  Requirements—Attribution  of  Average  Common
Equity According to the Required Capital Framework” herein).

5. The sums of the segments' Average common equity and Average tangible common

Common shareholders' equity

$ 72,720 $ 69,977 $ 69,787

equity do not equal the Consolidated measures due to Parent equity.

Less: Goodwill and net intangible assets

(9,140)

(8,985)

(9,158)

Tangible common shareholders' equity

$ 63,580 $ 60,992 $ 60,629

6. The calculation of ROE and ROTCE by segment uses net income applicable to Morgan
Stanley  by  segment  less  preferred  dividends  allocated  to  each  segment  as  a
percentage  of  average  common  equity  and  average  tangible  common  equity,
respectively, allocated to each segment.

$ in billions

Average common equity

Unadjusted—GAAP
Adjusted1—Non-GAAP

ROE2

Unadjusted—GAAP
Adjusted1, 3—Non-GAAP

2019

2018

2017

$

72.7

$

70.0

$

69.8

72.6

69.9

69.9

11.7%

11.2%

11.8%

11.5%

8.0%

9.4%

Average tangible common equity—Non-GAAP

Unadjusted
Adjusted1

ROTCE2—Non-GAAP

Unadjusted
Adjusted1, 3

$

63.6

$

61.0

$

60.6

63.5

60.9

60.7

13.4%

12.9%

13.5%

13.2%

9.2%
10.8% 

December 2019 Form 10-K

28

 
Table of Contents
Management's Discussion and Analysis

Return on Equity and Tangible Common Equity Targets

We previously established an ROE Target of 10% to 13%, and
an ROTCE Target of 11.5% to 14.5%. Excluding the impact of
intermittent net discrete tax items, we generated an 11.2% ROE
and a 12.9% ROTCE for 2019.

In January 2020, we established a new ROTCE Target of 13%
to 15% to be achieved over the next two years.

Our ROTCE Target is a forward-looking statement that may be
materially  affected  by  many  factors,  including,  among  other
things: macroeconomic and market conditions; legislative and
regulatory  developments;  industry  trading  and  investment
rate
banking  volumes;  equity  market 
environment; outsized legal expenses or penalties; the ability to
maintain a reduced level of expenses; and capital levels. See
“Forward-Looking  Statements”  and  “Risk  Factors”  for
additional information.

interest 

levels; 

For  non-GAAP  measures  (ROTCE  and  ROE  excluding
intermittent net discrete tax items), see “Selected Non-GAAP
Financial Information” herein. For information on the impact
of  intermittent  net  discrete  tax  items,  see  “Supplemental
Financial Information—Income Tax Matters” herein.

Business Segments

Substantially  all  of  our  operating  revenues  and  operating
expenses  are  directly  attributable  to  our  business  segments.
Certain  revenues  and  expenses  have  been  allocated  to  each
business segment, generally in proportion to its respective net
revenues, non-interest expenses or other relevant measures. See
Note  21  to  the  financial  statements  for  information  on
intersegment transactions.

Net Revenues

Investment Banking 

Investment  banking  revenues  are  derived  from  client
engagements  in  which  we  act  as  an  adviser,  underwriter  or
distributor of capital.

Within  the  Institutional  Securities  business  segment,  these
revenues  are  primarily  composed  of  fees  earned  from
underwriting  equity  and  fixed  income  securities,  syndicating
loans and advisory services in relation to mergers, acquisitions
and restructurings.

Within  the  Wealth  Management  business  segment,  these
revenues  are  derived  from  the  distribution  of  newly  issued
securities.

Trading

Trading  revenues  include  the  realized  gains  and  losses  from
transactions in financial instruments, unrealized gains and losses

from ongoing changes in the fair value of our positions and gains
and  losses  from  financial  instruments  used  to  economically
hedge  compensation  expense  related  to  certain  employee
deferred compensation plans.

Within  the  Institutional  Securities  business  segment, Trading
revenues  arise  from  transactions  in  cash  instruments  and
derivatives in which we act as a market maker for our clients.
In this role, we stand ready to buy, sell or otherwise transact
with  customers  under  a  variety  of  market  conditions  and  to
provide  firm  or  indicative  prices  in  response  to  customer
requests. Our liquidity obligations can be explicit in some cases,
and in others, customers expect us to be willing to transact with
them.  In  order  to  most  effectively  fulfill  our  market-making
function,  we  engage  in  activities  across  all  of  our  trading
businesses that include, but are not limited to:

• taking  positions  in  anticipation  of,  and  in  response  to,
customer  demand  to  buy  or  sell  and—depending  on  the
liquidity of the relevant market and the size of the position—
to hold those positions for a period of time;

• building,  maintaining  and  rebalancing  inventory  through

trades with other market participants;

• managing  and  assuming  basis  risk  (risk  associated  with
imperfect hedging) between customized customer risks and
the  standardized  products  available  in  the  market  to  hedge
those risks;

• trading in the market to remain current on pricing and trends;

and

• engaging in other activities to provide efficiency and liquidity

for markets.

In many markets, the realized and unrealized gains and losses
from purchase and sale transactions will include any spreads
between bids and offers. Certain fees received on loans carried
at  fair  value  and  dividends  from  equity  securities  are  also
recorded  in  Trading  revenues  since  they  relate  to  positions
carried at fair value.

Within  the  Wealth  Management  business  segment,  Trading
revenues primarily include revenues from customers’ purchases
and  sales  of  fixed  income  instruments  in  which  we  act  as
principal, and gains and losses related to investments associated
with certain employee deferred compensation plans.

Investments

Investments revenues are composed of realized and unrealized
gains  and  losses  derived  from  investments,  including  those
associated  with  employee  deferred  compensation  and  co-
investment plans. Estimates of the fair value of the investments
that produce these revenues may involve significant judgment
and may fluctuate significantly over time in light of business,

29

December 2019 Form 10-K

Table of Contents
Management's Discussion and Analysis

market,  economic  and  financial  conditions,  generally  or  in
relation to specific transactions.

performance  criteria.  These  performance  fees  are  generally
recognized annually.

Within the Institutional Securities segment, gains and losses are
primarily 
investments.  Certain
investments are subject to sale restrictions. Typically, there are
no fee revenues from these investments.

from  business-related 

Within 
the  Investment  Management  business  segment,
Investments  revenues,  in  addition  to  gains  and  losses  from
investments,  include  performance-based  fees  in  the  form  of
carried interest, a portion of which is subject to reversal. The
business is entitled to receive carried interest when the return in
targets.
certain 
Investment
Additionally, 
Management  funds  consolidated  by  us  where  revenues  are
primarily attributable to holders of noncontrolling interests. 

specified  performance 

there  are  certain 

funds  exceeds 

sponsored 

Commissions and Fees 

Commissions and fees result from arrangements in which the
client  is  charged  a  fee  for  executing  transactions  related  to
securities, services related to sales and trading activities, and
sales of other products. 

the 

Institutional  Securities  business 

Within 
segment,
commissions  and  fees  include  fees  earned  from  trading
activities, such as executing and clearing client transactions on
major  stock  and  derivative  exchanges,  as  well  as  from  OTC
derivatives. 

Within the Wealth Management business segment, commissions
and  fees  primarily  arise  from  client  transactions  in  equity
securities,  insurance  products,  mutual  funds,  futures  and
options. 

Asset Management 

Asset management revenues include fees associated with the
management and supervision of assets, and the distribution of
funds and similar products.

Within  the  Wealth  Management  business  segment,  Asset
management revenues are associated with advisory services and
management of assets, account service and administration, as
well as distribution of products. These revenues are generally
based on the net asset value of the account in which a client is
invested. 

Within  the  Investment  Management  business  segment, Asset
management revenues are primarily composed of fees received
from mutual fund daily average net assets or based on monthly
or  quarterly  invested  equity  for  other  vehicles.  Performance-
based  fees,  not  in  the  form  of  carried  interest,  are  earned  on
certain  products  and  separately  managed  accounts  as  a
percentage of appreciation generally earned by those products
and,  in  certain  cases,  are  based  upon  the  achievement  of

December 2019 Form 10-K

30

Net Interest

Interest income and Interest expense are functions of the level
and mix of total assets and liabilities, including Trading assets
and  Trading  liabilities,  Investment  securities  (which  include
AFS and HTM securities), Securities borrowed or purchased
under  agreements  to  resell,  Securities  loaned  or  sold  under
agreements to repurchase, Loans, Deposits and Borrowings. 

Within the Institutional Securities business segment, Net interest
is a function of market-making strategies, customer activity in
the  prime  brokerage  business,  and  the  prevailing  level,  term
structure and volatility of interest rates. Net interest is impacted
by market-making activities as securities held by the Firm earn
interest, while securities that are loaned, borrowed, sold with
agreements  to  repurchase  and  purchased  with  agreements  to
resell incur interest expense. 

Within  the  Wealth  Management  business  segment,  Interest
income is driven by Investment securities, Loans and margin
loans. Interest expense is driven by Deposits and other funding.

Other

Other revenues for Institutional Securities include revenues and
losses from equity method investments, lending commitments,
fees  earned  in  association  with  lending  activities  and  the
provision for loan losses.

Other  revenues  for  Wealth  Management  are  derived  from
realized gains and losses on AFS securities, the provision for
loan  losses,  account  handling  fees,  referral  fees  and  other
miscellaneous revenues.

Institutional Securities—Sales and Trading Revenues

Sales  and  trading  net  revenues  are  composed  of  Trading
revenues, Commissions and fees, Asset management revenues
and Net interest. These revenues, which can be impacted by a
variety of interrelated market factors, including volumes, bid-
offer  spreads  and  inventory  prices,  as  well  as  the  impact  of
hedging activity, are viewed in the aggregate when assessing
the  performance  and  profitability  of  our  sales  and  trading
activities.  We  make  transaction-related  decisions  based  on,
among other things, an assessment of the potential gain or loss
associated  with  a  transaction,  including  any  associated
commissions and fees, dividends, or net interest income, any
costs  associated  with  financing  or  hedging  our  positions  and
other related expenses.

Following  is  a  description  of  the  sales  and  trading  activities
within our equity and fixed income businesses, as well as how
their results impact the income statement line items.

Table of Contents
Management's Discussion and Analysis

Equity—Financing. We provide financing, prime brokerage and
fund administration services to our clients active in the equity
markets through a variety of products, including margin lending,
securities  lending  and  swaps.  Results  from  this  business  are
largely  driven  by  the  difference  between  financing  income
earned and financing costs incurred, which are reflected in Net
interest  for  securities  and  equity  lending  products,  and  in
Trading  revenues  for  derivative  products.  Fees  for  providing
fund administration services are reflected in Asset management
revenues.

Equity—Execution services. A significant portion of the results
for  this  business  is  generated  by  commissions  and  fees  from
executing and clearing client transactions on major stock and
derivative  exchanges,  as  well  as  from  OTC  transactions. We
make  markets  for  our  clients  in  equity-related  securities  and
derivative products, including those that provide liquidity and
are utilized for hedging. Market making also generates gains
and losses on positions held in inventory, which are reflected in
Trading revenues.

Fixed  income—Within  fixed  income,  we  make  markets  in
various flow and structured products in order to facilitate client
activity as part of the following products and services:

• Global macro products. We make markets for our clients in
interest rate, foreign exchange and emerging market products,
including exchange-traded and OTC securities and derivative
instruments. The results of this market-making activity are
primarily driven by gains and losses from buying and selling
positions to stand ready for and satisfy client demand and are
recorded in Trading revenues.

• Credit  products.  We  make  markets  in  credit-sensitive
products, such as corporate bonds and mortgage securities and
other securitized products, and related derivative instruments.
The  values  of  positions  in  this  business  are  sensitive  to
changes in credit spreads and interest rates, which result in
gains and losses reflected in Trading revenues. We undertake
lending  activities,  which  include  commercial  mortgage
lending,  asset-backed  lending  and  financing  extended  to
customers. Due to the amount and type of the interest-bearing
securities  and  loans  making  up  this  business,  a  significant
portion of the results is also reflected in Net interest revenues.

• Commodities products and Other. We make markets in various
commodity products related primarily to electricity, natural
gas, oil and metals. Other activities primarily include results
from  the  centralized  management  of  our  fixed  income
derivative counterparty exposures and managing derivative
counterparty  risk  on  behalf  of  clients.  These  activities  are
primarily recorded in Trading revenues.

Other sales and trading revenues include impacts from certain
treasury functions, such as liquidity costs and gains and losses
on  economic  hedges  related  to  certain  borrowings,  certain
activities associated with corporate lending, as well as gains and

losses from financial instruments used to economically hedge
compensation  expense  related  to  certain  employee  deferred
compensation plans.

Compensation Expense

Compensation and benefits expenses include base salaries and
fixed allowances, formulaic programs, discretionary incentive
compensation, amortization of deferred cash and equity awards,
changes in the fair value of investments to which certain deferred
compensation plans are referenced, carried interest allocated to
employees, severance costs, and other items such as health and
welfare benefits.

The  factors  that  drive  compensation  for  our  employees  vary
from period  to period, from segment to segment and within a
segment.  For  certain  revenue-producing  employees  in  the
Wealth  Management  and  Investment  Management  business
segments, compensation is largely paid on the basis of formulaic
payouts  that  link  employee  compensation  to  revenues.
Compensation  for  other  employees, 
including  revenue-
producing  employees  in  the  Institutional  Securities  business
segment, include base salary and benefits, and may also include
incentive  compensation  that  is  determined  following  the
assessment  of  the  Firm’s,  business  unit’s  and  individual’s
performance. 

Compensation expense for deferred cash-based compensation
plans  is  recognized  over  the  relevant  vesting  period  and  is
adjusted  based  on  the  notional  earnings  of  the  referenced
investments  until  distribution.  Although 
in
compensation expense resulting from changes in the fair value
of the referenced investments will generally be offset by changes
in  the  fair  value  of  investments  made  by  the  Firm,  there  is
typically a timing difference between the immediate recognition
of  gains  and  losses  on  the  Firm's  investments  and  the
compensation expense recognized over the vesting period.

changes 

Income Taxes

The income tax provision for our business segments is generally
determined  based  on  the  revenues,  expenses  and  activities
directly  attributable  to  each  business  segment. Certain  items
have  been  allocated  to  each  business  segment,  generally  in
proportion  to  its  respective  net  revenues  or  other  relevant
measures.

31

December 2019 Form 10-K

Table of Contents
Management's Discussion and Analysis

Institutional Securities

Income Statement Information

Investment Banking

Investment Banking Revenues

14,896

14,322

13,169

4 %

9 %

1. Includes  transactions  of  $100 million  or  more.  Based  on  full  credit  to  each  of  the

$ in millions

Advisory

Underwriting:

Equity

Fixed Income

Total Underwriting

% Change

2019

2018

2017

2019

2018

$ 2,116 $ 2,436 $ 2,077

(13)% 17 %

1,708

1,910

3,618

1,726

1,926

3,652

1,484

1,976

3,460

(1)% 16 %

(1)%

(1)%

(3)%

6 %

Total Investment banking

$ 5,734 $ 6,088 $ 5,537

(6)% 10 %

Investment Banking Volumes

$ in billions
Completed mergers and acquisitions1
Equity and equity-related offerings2, 3
Fixed income offerings2, 4

2019

2018

2017

$

818 $ 1,114 $

61

270

64

241

753

65

307

Source: Refinitiv (formerly Thomson Reuters Financial & Risk), data as of January 2,
2020. Transaction volumes may not be indicative of net revenues in a given period. In
addition, transaction volumes for prior periods may vary from amounts previously reported
due  to  the  subsequent  withdrawal,  change  in  value  or  change  in  timing  of  certain
transactions.

advisors in a transaction.

2. Based on full credit for single book managers and equal credit for joint book managers.
3. Includes  Rule  144A  issuances  and  registered  public  offerings  of  common  stock,

convertible securities and rights offerings.

4. Includes Rule 144A and publicly registered issuances, non-convertible preferred stock,
mortgage-backed and asset-backed securities, and taxable municipal debt. Excludes
leveraged loans and self-led issuances.

2019 Compared with 2018

Investment  banking  revenues  of  $5,734  million  in  2019
decreased 6% from 2018, reflecting lower results in our advisory
business.

• Advisory revenues decreased primarily as a result of lower

volumes of completed M&A activity.

• Equity underwriting revenues were relatively unchanged as
lower revenues in initial public offerings were offset by higher
revenues in secondary block share trades.

• Fixed  income  underwriting  revenues  were  essentially
unchanged as lower non-investment grade loan issuance fees
were offset by higher fees from bond and investment grade
loan issuances.

$ in millions

Revenues

2019

2018

2017

2019

2018

% Change

Investment banking

$ 5,734 $ 6,088 $ 5,537

Trading

Investments

10,318

11,191

10,295

325

182

368

79 % (51)%

Commissions and fees

2,484

2,671

2,433

(6)%

(8)%

10 %

9 %

(7)%

(2)%

10 %

17 %

18 % (15)%

413

632

421

535

359

630

Asset management

Other

Total non-interest

revenues

Interest income

Interest expense

Net interest

Net revenues

Compensation and

benefits

Non-compensation

expenses

Total non-interest

expenses

Income from continuing 

operations before
income taxes

Provision for income

taxes

Income from continuing

operations

Income (loss) from 

discontinued operations, 
net of income taxes

19,906

21,088

19,622

12,193

11,713

9,271

9,777

5,377

6,186

(6)%

32 %

20 %

480

(506)

(809)

195 %

20,386

20,582

18,813

(1)%

7 %

72 %

58 %

37 %

9 %

7,433

6,958

6,625

7 %

5 %

7,463

7,364

6,544

1 %

13 %

5,490

6,260

5,644

(12)%

11 %

769

1,230

1,993

(37)% (38)%

4,721

5,030

3,651

(6)%

38 %

Net income

4,721

5,024

3,632

(6)%

—

(6)

(19)

100 %

68 %

38 %

Net income applicable 

to noncontrolling interests

Net income applicable 
to Morgan Stanley

122

118

96

3 %

23 %

$ 4,599 $ 4,906 $ 3,536

(6)%

39 %

December 2019 Form 10-K

32

Table of Contents
Management's Discussion and Analysis

Sales and Trading Net Revenues

2019 Compared with 2018

By Income Statement Line Item

Equity

Commissions and fees

2,484

2,671

2,433

$ in millions

Trading

Asset management

Net interest

Total

By Business

$ in millions

Equity

Fixed income

Other

Total

2019

2018

2017

2019

2018

% Change

$ 10,318 $ 11,191 $ 10,295

413

480

421

(506)

359

(809)

195 %

$ 13,695 $ 13,777 $ 12,278

(1)%

(8)%

(7)%

(2)%

9%

10%

17%

37%

12%

% Change

2019

2018

2017

2019

2018

$ 8,056 $ 8,976 $ 7,982

(10)%

5,546

5,005

4,928

11 %

93

(204)

(632) 146 %

$ 13,695 $ 13,777 $ 12,278

(1)%

12%

2%

68%

12%

Sales and Trading Revenues—Equity and Fixed Income

$ in millions

Financing

Execution services

Total Equity

Total Fixed income

$ in millions

Financing

Execution services

Total Equity

Total Fixed income

$ in millions

Financing

Execution services

Total Equity

Total Fixed income

2019

Trading

Fees1

Net
Interest2

Total

4,225 $

372 $

(514) $

4,083

1,986

2,202

(215)

3,973

6,211 $

2,574 $

(729) $

8,056

5,171 $

324 $

51 $

5,546

2018

Trading

Fees1

Net
Interest2

Total

4,841 $

394 $

(661) $

4,574

2,362

2,376

(336)

4,402

7,203 $

2,770 $

(997) $

8,976

4,793 $

322 $

(110) $

5,005

2017

Trading

Fees1

Net
Interest2

Total

4,140 $

363 $

(762) $

3,741

2,294

2,191

(244)

4,241

6,434 $

2,554 $

(1,006) $

7,982

4,453 $

238 $

237 $

4,928

$

$

$

$

$

$

$

$

$

1. Includes Commissions and fees and Asset management revenues.
2. Includes funding costs, which are allocated to the businesses based on funding usage.

Equity sales and trading net revenues of $8,056 million in 2019
decreased 10% from 2018, reflecting lower results in both our
financing and execution services businesses.

• Financing  decreased  from  2018,  primarily  due  to  lower
realized spreads and commissions, reflected in lower Trading
revenues.

• Execution  services  decreased  from  2018,  reflecting  lower
Trading  revenues  as  a  result  of  less  favorable  inventory
management in derivatives products due to lower levels of
volatility. In addition, Commissions and fees decreased driven
by changes in market volumes and commission mix in cash
equities products.

Fixed Income

Fixed income net revenues of $5,546 million in 2019 were 11%
higher than 2018, primarily driven by higher results in credit
products,  partially  offset  by  lower  results  in  global  macro
products.

• Global macro products Trading revenues decreased primarily
due  to  inventory  management  losses  in  certain  foreign
exchange  and  rates  products  as  a  result  of  movements  in
foreign exchange volatility and a decline in interest rates. 

• Credit products Trading revenues increased, primarily due to
improved  inventory  management  in  corporate  credit  and
securitized products and higher client activity in securitized
products. 

• Commodities products and Other Trading revenues increased
as gains from counterparty risk management were offset by
lower client activity in commodities.

Fixed  income  Net  interest  increased  compared  with  2018,
primarily reflecting changes in funding mix, partially offset by
lower net spreads in securitized products.

Other

• Other  sales  and  trading  revenues  of  $93  million  in  2019
increased from 2018, reflecting an increase in the fair value
of investments to which certain deferred compensation plans
are referenced and changes in funding mix, partially offset by
higher losses on hedges associated with corporate loans.

33

December 2019 Form 10-K

Table of Contents
Management's Discussion and Analysis

Investments,  Other  Revenues,  Non-interest  Expenses  and
Income Tax Items

2019 Compared with 2018

Investments

• In 2019, net investment gains of $325 million were higher
compared with 2018, primarily as a result of realized gains
associated with an investment's initial public offering in 2019.

Other Revenues

• Other revenues of $632 million in 2019 increased from 2018,
primarily  as  a  result  of  mark-to-market  gains  in  2019
compared  with  losses  in  2018  on  loans  held  for  sale. This
increase was partially offset by a higher provision for loan
losses, which in 2018 included the recovery of a previously
charged  off  loan,  and  lower  results  in  our  Japanese  joint
venture Mitsubishi UFJ Morgan Stanley Securities Co., Ltd.
(“MUMSS”).

Non-interest Expenses

Non-interest  expenses  of  $14,896  million  in  2019  increased
from  2018,  reflecting  a  7%  increase  in  Compensation  and
benefits  expenses  and  a  1%  increase  in  Non-compensation
expenses.

• Compensation  and  benefits  expenses  increased  in  2019,
primarily due to an increase in the fair value of investments
to which certain deferred compensation plans are referenced,
higher salaries and severance-related costs, partially offset by
decreases in discretionary incentive compensation.

• Non-compensation  expenses  increased  in  2019,  reflecting
higher  investments  in  technology,  partially  offset  by  lower
professional services expenses.

Income Tax Items

Intermittent net discrete tax benefits of $317 million and $182
million were recognized in Provision for income taxes in 2019
and  2018, 
information,  see
“Supplemental  Financial  Information—Income  Tax  Matters”
herein.

respectively.  For 

further 

December 2019 Form 10-K

34

 
Table of Contents
Management's Discussion and Analysis

Wealth Management

Income Statement Information

Transactional Revenues

$ in millions

Revenues

2019

2018

2017

2019

2018

$ in millions

2019

2018

2017

2019

2018

% Change

% Change

Investment banking

$ 509

$ 475

$ 533

7 % (11)%

Investment banking

$

509 $

475 $

Trading

Investments

734

2

279

1

533

848

7 % (11)%

Trading

734

279

848

163 % (67)%

163 % (67)%

Commissions and fees

1,726

1,804

1,737

(4)%

4 %

3

100 % (67)%

Total

$2,969

$2,558

$3,118

16 % (18)%

Commissions and fees

1,726

1,804

1,737

(4)%

Asset management

10,199

10,158

9,342 — %

4 %

9 %

Other

345

248

268

39 % (7)%

Total non-interest revenues

13,515

12,965

12,731

4 %

2 %

Transactional revenues as a

% of Net revenues

17%

15%

19%

2019 Compared with 2018 

Interest income

Interest expense

Net interest

Net revenues

Compensation and benefits

Non-compensation expenses

5,467

1,245

4,222

5,498

1,221

4,277

17,737

17,242

16,836

9,774

3,131

9,507

3,214

9,360

3,177

Total non-interest expenses

12,905

12,721

12,537

4,591

(1)% 20 %

486

2 % 151 %

Net Revenues

4,105

(1)%

3 %

3 %

(3)%

1 %

4 %

2 %

2 %

1 %

1 %

Transactional Revenues

Transactional  revenues  of  $2,969  million  in  2019  increased
16%, primarily as a result of higher Trading revenues, partially
offset by lower Commissions and fees.

4,832

1,104

4,521

1,049

4,299

1,974

7 %

5 %

5 % (47)%

• Investment banking revenues increased in 2019, primarily due

to higher revenues from closed-end fund issuances.

Income from continuing

operations before income
taxes

Provision for income taxes

Net income applicable to

Morgan Stanley

$ 3,728 $ 3,472 $ 2,325

7 % 49 %

Financial Information and Statistical Data

$ in billions, except employee data

Client assets
Fee-based client assets1

Fee-based client assets as a percentage of

total client assets

Client liabilities2

Investment securities portfolio

Loans and lending commitments

At
December 31,
2019

At
December 31,
2018

$

$

$

$

$

2,700

1,267

47%

90

67.2

93.2

$

$

$

$

$

2,303

1,046

45%

83

68.6

82.9

Wealth Management representatives

15,468

15,694

Per representative:

Revenues ($ in thousands)3
Client assets ($ in millions)4

Fee-based asset flows ($ in billions)5

2019

2018

2017

$ 1,136 $ 1,100 $ 1,068

$

$

175 $

147 $

151

64.9 $

65.9 $

75.4

1. Fee-based client assets represent the amount of assets in client accounts where the

fee for services is calculated based on those assets.

2. Client liabilities include securities-based and tailored lending, residential real estate

loans and margin lending.

• Trading revenues increased in 2019, primarily due to gains
related  to  investments  associated  with  certain  employee
deferred compensation plans, partially offset by lower fixed
income revenues driven by product mix.

• Commissions and fees decreased in 2019, primarily due to
changes in the mix of client activity in equities, partially offset
by increased client activity in alternative products.

Asset Management

Asset management revenues of $10,199 million in 2019 were
relatively unchanged compared with 2018, reflecting the effect
of  higher  fee-based  client  assets  levels  due  to  market
appreciation in 2019 and positive net flows, partially offset by
the effect of lower fee-based client assets levels at the beginning
of the year due to significant market declines in the fourth quarter
of 2018, and lower average fee rates predominantly driven by
shifts in the mix of fee-based client assets.

See “Fee-Based Client Assets Rollforwards” herein.

3. Revenues per representative equal Wealth Management’s net revenues divided by

the average number of representatives.

4. Client assets per representative equal total period-end client assets divided by period-

Other

end number of representatives.

5. For a description of the Inflows and Outflows included in Fee-based asset flows, see
Fee-based  client  assets  herein.  Excludes  institutional  cash  management-related
activity.

Other  revenues  of  $345  million  in  2019  increased  39%,
primarily due to higher realized gains from the AFS securities
portfolio.

35

December 2019 Form 10-K

 
Table of Contents
Management's Discussion and Analysis

Net Interest

Net interest of $4,222 million in 2019 was relatively unchanged
compared  with  2018,  as  higher  costs  due  to  changes  in  our
funding  mix  and  higher  prepayment  amortization  expense
related to mortgage-backed securities were offset by the impact
of higher balances of and higher interest rates on Loans, and
higher investment portfolio yields. 

In addition, we centralized certain internal treasury activities as
of January 1, 2019, which partially offset Interest income and
Interest expense compared with the prior periods. The effect on
Net interest income was not significant in 2019.

Non-interest Expenses

Non-interest  expenses  of  $12,905  million  in  2019  were
relatively  unchanged  compared  with  2018,  as  higher
Compensation and benefits expenses were offset by lower Non-
compensation expenses.

• Compensation  and  benefits  expenses  increased  in  2019,
primarily due to increases in the fair value of investments to
which certain deferred compensation plans are referenced and
salaries, partially offset by the roll-off of certain acquisition-
related employee retention loans. 

• Non-compensation expenses decreased in 2019, primarily as
a  result  of  lower  professional  services  expenses  and  lower
deposit insurance expense. 

Fee-Based Client Assets Rollforwards

$ in billions
Separately managed1

Unified managed2

Advisor

Portfolio manager

Subtotal

Cash management

Total fee-based
client assets

At
December 31,
2018

Inflows Outflows

Market
Impact

At
December 31,
2019

$

$

$

279 $

53 $

(19) $

9 $

257

137

353

48

27

75

(39)

(32)

(48)

47

23

55

322

313

155

435

1,026 $

203 $

(138) $

134 $

1,225

20

36

(14)

—

42

1,046 $

239 $

(152) $

134 $

1,267

$ in billions
Separately managed1

Unified managed2

Advisor

Portfolio manager

Subtotal

Cash management

Total fee-based client

assets

At
December 31,
2017

Inflows Outflows

Market
Impact

At
December 31,
2018

$

$

$

252 $

40 $

(18) $

5 $

271

149

353

48

29

71

(34)

(28)

(42)

(28)

(13)

(29)

279

257

137

353

1,025 $

188 $

(122) $

(65) $

1,026

20

16

(16)

—

20

1,045 $

204 $

(138) $

(65) $

1,046

$ in billions
Separately managed1

Unified managed2

Advisor

Portfolio manager

Subtotal

Cash management

Total fee-based client

assets

At
December 31,
2016

Inflows Outflows

Market
Impact

At
December 31,
2017

$

$

$

222 $

39 $

(21) $

12 $

225

125

285

49

34

74

(34)

(25)

(41)

31

15

35

252

271

149

353

857 $

196 $

(121) $

93 $

1,025

20

13

(13)

—

20

877 $

209 $

(134) $

93 $

1,045

Average Fee Rates

Fee rate in bps

Separately managed
Unified managed2

Advisor

Portfolio manager

Subtotal

Cash management

Total fee-based client assets

2019

2018

2017

15

100

86

95

74

6

73

16

99

84

95

76

6

74

17

101

86

97

77

6

76

1. Includes non-custody account values reflecting prior quarter-end balances due to a

lag in the reporting of asset values by third-party custodians.

2. Prior periods have been recast to conform to current period presentation.

• Inflows—include new accounts, account transfers, deposits,

dividends and interest.

• Outflows—include  closed  or  terminated  accounts,  account

transfers, withdrawals and client fees.

• Market impact—includes realized and unrealized gains and

losses on portfolio investments.

• Separately  managed—accounts  by  which  third-party  and
affiliated asset managers are engaged to manage clients’ assets
with investment decisions made by the asset manager. Only
one  third-party  asset  manager  strategy  can  be  held  per
account.

• Unified managed—accounts that provide the client with the
ability to combine separately managed accounts, mutual funds
and  exchange-traded  funds  all  in  one  aggregate  account.
Investment  decisions  and  discretionary  authority  may  be
exercised by the client, financial advisor or portfolio manager.
Also  includes  accounts  that  give  the  client  the  ability  to
systematically allocate assets across a wide range of mutual
funds, for which the investment decisions are made by the
client.

• Advisor—accounts where the investment decisions must be
approved by the client and the financial advisor must obtain
approval  each  time  a  change  is  made  to  the  account  or  its
investments.

December 2019 Form 10-K

36

Table of Contents
Management's Discussion and Analysis

• Portfolio manager—accounts where a financial advisor has
discretion  (contractually  approved  by  the  client)  to  make
ongoing investment decisions without the client’s approval
for each individual change.

• Cash  management—accounts  where  the  financial  advisor
provides  discretionary  cash  management  services 
to
institutional  clients,  whereby  securities  or  proceeds  are
invested  and  reinvested  in  accordance  with  the  client’s
investment criteria. Generally, the portfolio will be invested
in short-term fixed income and cash equivalent investments.

37

December 2019 Form 10-K

Table of Contents
Management's Discussion and Analysis

Investment Management

Income Statement Information

$ in millions

Revenues

Trading

Investments

Commissions and fees

Asset management

Other

2019

2018

2017

2019

2018

% Change

$

(8) $

25 $ (22)

(132)% N/M

1,213

1

254

—

449

—

N/M (43)%

N/M

— %

2,629

2,468 2,196

7 % 12 %

(46)

(30)

(37)

(53)% 19 %

Total non-interest revenues

3,789

2,717 2,586

39 %

5 %

Interest income

Interest expense

Net interest

Net revenues

20

46

(26)

57

28

29

4

4

(65)% N/M

64 % N/M

— (190)% N/M

3,763

2,746 2,586

37 %

6 %

Compensation and benefits

1,630

1,167 1,181

40 % (1)%

Non-compensation expenses

1,148

1,115

949

3 % 17 %

2019 Compared with 2018 

Net Revenues

Investments

Investments revenues of $1,213 million in 2019 compared with
$254 million in 2018 reflect higher unrealized carried interest
and investment gains primarily from an Asia private equity fund,
principally driven by the initial public offering of an underlying
investment, which is subject to certain sales restrictions.

Asset Management

Asset management revenues of $2,629 million in 2019 increased
7% compared with 2018, primarily as a result of higher average
AUM and higher performance-based fees driven by real estate
funds and the monetization of a client asset in 2019.

Total non-interest expenses

2,778

2,282 2,130

22 %

7 %

See “Assets Under Management or Supervision” herein.

Income from continuing 

operations before income 
taxes

Provision for income taxes

Income from continuing 

operations

Income from discontinued 

operations, net of income taxes

Net income

Net income applicable to 
noncontrolling interests

Net income applicable to 

Morgan Stanley

985

193

464

73

456

201

112 %

2 %

164 % (64)%

Other

792

391

255

103 % 53 %

—

792

2

— (100)%

N/M

393

255

102 % 54 %

73

17

9

N/M

89 %

$ 719 $ 376 $ 246

91 % 53 %

Other losses were $46 million in 2019 and $30 million in 2018,
primarily reflecting impairments of two distinct equity method
investments in third-party asset managers, one in each year.

Non-interest Expenses

Non-interest expenses of $2,778 million in 2019 increased 22%
from 2018, primarily as a result of higher Compensation and
benefits expenses.

• Compensation  and  benefits  expenses  increased  in  2019,
primarily due to higher compensation associated with carried
interest.

• Non-compensation expenses increased in 2019, primarily as
a result of higher fee sharing driven by higher average AUM.

December 2019 Form 10-K

38

Table of Contents
Management's Discussion and Analysis

Assets Under Management or Supervision

Rollforwards 

$ in billions

Equity

Fixed income

Alternative/
Other

Long-term AUM

subtotal

Liquidity

Total AUM

Shares of

minority stake
assets

$ in billions

Equity

Fixed income

Alternative/
Other

Long-term AUM

subtotal

Liquidity1

Total AUM

Shares of

minority stake
assets

$ in billions

Equity

Fixed income

Alternative/
Other

Long-term AUM

subtotal

Liquidity

Total AUM

Shares of

minority stake
assets

At
December 31,
2018

Inflows Outflows

Market
Impact Other

At
December 31,
2019

$

103 $

39 $

(31) $

28 $

(1) $

68

128

299

164

25

22

86

(20)

(17)

(68)

1,315

(1,283)

5

10

43

2

1

(4)

(4)

(2)

$

463 $ 1,401 $ (1,351) $

45 $

(6) $

7

138

79

139

356

196

552

6

At
December 31,
2017

Inflows Outflows

Market
Impact Other

At
December 31,
2018

$

105 $

38 $

(32) $

(8) $ — $

73

128

306

176

25

22

85

(27)

(19)

(78)

1,351

(1,362)

(2)

(1)

(11)

2

(1)

(2)

(3)

(3)

$

482 $ 1,436 $ (1,440) $

(9) $

(6) $

7

103

68

128

299

164

463

7

At
December 31,
2016

Inflows Outflows

Market
Impact Other

At
December 31,
2017

$

79 $

23 $

(21) $

23 $

1 $

60

115

254

163

27

24

74

(21)

(18)

(60)

1,239

(1,227)

4

8

35

1

3

(1)

3

—

$

417 $ 1,313 $ (1,287) $

36 $

3 $

8

105

73

128

306

176

482

7

1. Included in Liquidity products outflows in 2018 is $18 billion related to the redesign of

our brokerage sweep deposits program.

Average AUM

$ in billions

Equity

Fixed income

Alternative/Other

Long-term AUM subtotal

Liquidity

Total AUM

Shares of minority stake assets

Average Fee Rates

Fee rate in bps

Equity

Fixed income

Alternative/Other

Long-term AUM

Liquidity

Total AUM

2019

2018

2017

$

124 $

111 $

71

134

329

171

71

131

313

158

$

500 $

471 $

6

7

93

66

122

281

157

438

7

2019

2018

2017

76

32

64

61

17

46

76

33

66

62

17

47

73

33

70

62

17

46

• Inflows—represent  investments  or  commitments  from  new
and existing clients in new or existing investment products,
including reinvestments of client dividends and increases in
invested  capital.  Inflows  exclude  the  impact  of  exchanges,
whereby a client changes positions within the same asset class.

• Outflows—represent  redemptions  from  clients’  funds,
transition of funds from the committed capital period to the
invested  capital  period  and  decreases  in  invested  capital.
Outflows exclude the impact of exchanges, whereby a client
changes positions within the same asset class.

• Market impact—includes realized and unrealized gains and
losses  on  portfolio  investments.  This  excludes  any  funds
where market impact does not impact management fees.

• Other—contains  both  distributions  and  foreign  currency
impact for all periods and the impact of the Mesa West Capital,
LLC acquisition in 2018. Distributions represent decreases in
invested capital due to returns of capital after the investment
period of a fund. It also includes fund dividends that the client
has not reinvested. Foreign currency impact reflects foreign
currency changes for non-U.S. dollar dominated funds.

• Alternative/Other—includes products in fund of funds, real
assets, private equity and credit strategies, as well as multi-
asset portfolios.

• Shares  of  minority  stake  assets—represent  the  Investment
Management business segment’s proportional share of assets
managed  by  third-party  asset  managers  in  which  we  hold
investments accounted for under the equity method.

• Average fee rate—based on Asset management revenues, net
of waivers, excluding performance-based fees and other non-
management fees. For certain non-U.S. funds, it includes the
portion of advisory fees that the advisor collects on behalf of
third-party  distributors.  The  payment  of  those  fees  to  the
distributor is included in Non-compensation expenses in the
income statements.

39

December 2019 Form 10-K

 
Table of Contents
Management's Discussion and Analysis

Supplemental Financial Information 

U.S. Bank Subsidiaries’ Supplemental Financial Information1

21.3% 22.7% 30.8%

Total investment securities

Income Tax Matters

Effective Tax Rate from Continuing Operations

$ in millions

U.S. GAAP

Adjusted effective income
tax rate—non-GAAP1

2019

2018

2017

18.3% 20.9% 40.1%

Net discrete tax provisions/(benefits)
Recurring2
Intermittent3

(127)

(348)

(165)

(203)

(155)

968

1. The  adjusted  effective  income  tax  rate  is  a  non-GAAP  measure  that  excludes  net
discrete  tax  provisions  (benefits)  that  are  intermittent  and  includes  those  that  are
recurring. For further information on non-GAAP measures, see “Selected Non-GAAP
Financial Information” herein.

2. Provisions  (benefits)  related  to  conversion  of  employee  share-based  awards  are
expected to occur every year and, as such, are considered recurring discrete tax items.
3. Includes all tax provisions (benefits) that have been determined to be discrete, other

than Recurring items as defined above.

The effective tax rates for 2019 and 2018 include intermittent
net  discrete 
tax  benefits  primarily  associated  with
remeasurement of reserves and related interest as a result of new
information pertaining to the resolution of multi-jurisdiction tax
examinations.

The effective tax rate reflects our current assumptions, estimates
and interpretations related to the U.S. Tax Cuts and Jobs Act
enacted on December 22, 2017 (“Tax Act”) and other factors.
For  a  further  discussion  of  the  Tax  Act,  see  Note  20  to  the
financial statements.

U.S. Bank Subsidiaries

(collectively, 

(“MSPBNA”) 

Our  U.S.  bank  subsidiaries,  Morgan  Stanley  Bank  N.A.
(“MSBNA”)  and  Morgan  Stanley  Private  Bank,  National
Association 
“U.S.  Bank
Subsidiaries”)  accept  deposits,  provide  loans  to  a  variety  of
customers, from large corporate and institutional clients to high
net worth individuals, and invest in securities. Lending activity
recorded  in  the  U.S.  Bank  subsidiaries  from  the  Institutional
Securities  business  segment  primarily  includes  loans  and
lending  commitments  to  corporate  clients.  Lending  activity
recorded  in  the  U.S.  Bank  subsidiaries  from  the  Wealth
Management  business  segment  primarily  includes  securities-
based lending, which allows clients to borrow money against
the  value  of  qualifying  securities,  and  residential  real  estate
loans.

We expect our lending activities to continue to grow through
further  market  penetration  of  our  client  base.  For  a  further
discussion of our credit risks, see “Quantitative and Qualitative
Disclosures about Risk—Credit Risk.” For a further discussion
about loans and lending commitments, see Notes 8 and 13 to
the financial statements.

December 2019 Form 10-K

40

$ in billions

Assets

Investment securities portfolio:

Investment securities—AFS

Investment securities—HTM

Deposits2

Wealth Management Loans

Securities-based lending and
other3

Residential real estate

Total

Institutional Securities Loans4
Corporate5:

Corporate relationship and

event-driven lending

Secured lending facilities

Securities-based lending and

other

Commercial and residential real

estate

Total

At
December 31,
2019

At
December 31,
2018

$

$

$

$

$

$

$

219.6 $

216.9

42.4

26.1

68.5 $

189.3 $

49.9 $

30.2

80.1 $

5.6 $

26.8

5.4

12.0

49.8 $

45.5

23.7

69.2

187.1

44.7

27.5

72.2

7.4

17.5

6.0

10.5

41.4

1. Amounts  exclude  transactions  between  the  bank  subsidiaries,  as  well  as

deposits from the Parent Company and affiliates.

2. For  further  information  on  deposits,  see  “Liquidity  and  Capital  Resources—

Funding Management—Unsecured Financing” herein.

3. Other loans primarily include tailored lending.
4. Prior periods have been conformed to the current presentation.
5. For a further discussion of corporate loans in the Institutional Securities business
segment, see “Credit Risk—Institutional Securities Corporate Loans” herein.

Other Matters

Deferred Cash-Based Compensation

The Firm sponsors a number of employee deferred cash-based
compensation programs. For eligible employees, a portion of
their year-end discretionary incentive compensation is awarded
in the form of deferred cash-based compensation. Such deferred
compensation  awards  generally  contain  vesting,  clawback,
forfeiture  and  cancellation  provisions. Additionally,  there  are
certain  other  deferred  cash-based  programs 
that  allow
employees  to  defer  the  receipt  of  current  compensation  to  a
future date. 

Employees are permitted to allocate the notional value of their
deferred  awards  among  a  menu  of  investments,  whereby  the
notional value of their awards will track the performance of the
referenced  investments.  The  menu  of  investments,  which  is
selected by the Firm, includes fixed income, equity, commodity
and money market funds.

 
 
Table of Contents
Management's Discussion and Analysis

Compensation expense for deferred cash-based compensation
awards is calculated based on the notional value of the award
granted, adjusted for changes in the fair value of the referenced
investments  that  employees  select.  Compensation  expense  is
recognized over the relevant vesting period for each separate
vesting portion of deferred awards.

its  obligations  under 

Correspondingly,  the  Firm  invests  directly,  as  a  principal,  in
financial  instruments  and  other  investments  to  economically
hedge 
these  deferred  cash-based
compensation plans. Changes in the value of such investments
made  by  the  Firm  are  recorded  in  Trading  and  Investments
revenues. Although changes in compensation expense resulting
from changes in the fair value of the referenced investments will
generally be offset by changes in the fair value of investments
made by the Firm, there is typically a timing difference between
the  immediate  recognition  of  gains  and  losses  on  the  Firm’s
investments  and  the  deferred  recognition  of  the  related
compensation expense over the vesting period. While this timing
difference is generally not material to Income from continuing
operations before income taxes in any individual period, it may
impact Firm reported ratios (e.g., the Expense efficiency ratio)
in certain periods.

Amounts Recognized in Compensation Expense

$ in millions

2019

2018

2017

Deferred cash-based awards

$

1,233 $

1,174 $

1,039

Return on referenced investments

645

(48)

499

Total recognized in compensation

expense

$

1,878 $

1,126 $

1,538

Amounts Recognized in Compensation Expense by Segment

$ in millions

Institutional Securities

Wealth Management

Investment Management

2019

2018

2017

$

916 $

611 $

760

202

346

169

771

564

203

Total recognized in compensation

expense

$

1,878 $

1,126 $

1,538

A  rollforward  of  the  Firm's  estimated  projected  future
compensation  obligation  for  existing  deferred  cash-based
compensation  awards,  exclusive  of  any  assumptions  about
future market conditions with respect to referenced investments
is set forth below.

Projected Future Compensation Obligation

$ in millions
Award liabilities at December 31, 20191, 2

Fully vested amounts to be distributed by the end of

February 20203

Unrecognized portion of prior awards at December 31,

20192

2019 performance year awards granted in 20202
Total4

$

$

5,376

(1,042)

1,092

1,050

6,476

1. Balance is reflected in Other liabilities and accrued expenses in the balance sheet as

of December 31, 2019.

2. Amounts  do  not 

forfeitures,  cancellations,
accelerations  or  assumptions  about  future  market  conditions  with  respect  to
referenced investments.

include  assumptions 

regarding 

3. Distributions after February of each year are generally immaterial.
4. Of the total projected future compensation obligation, approximately 40% relates to
Institutional  Securities,  approximately  50%  relates  to  Wealth  Management  and
approximately 10% relates to Investment Management.

An  estimate  of  compensation  expense  associated  with  the
Projected  Future  Compensation  Obligation  presented  in  the
previous table is as follows:

Projected Future Compensation Expense

$ in millions

Estimated to be recognized in:

2020

2021

Thereafter
Total1

$

$

1,169

469

504

2,142

1. Amounts  do  not 

forfeitures,  cancellations,
accelerations  or  assumptions  about  future  market  conditions  with  respect  to
referenced investments.

include  assumptions 

regarding 

Our projected future compensation obligation and expense for
deferred cash-based compensation awards are forward-looking
statements  subject  to  uncertainty.   Actual  results  may  be
materially affected by various factors, including, among other
things:  the  performance  of  each  participant’s  referenced
investments;  changes  in  market  conditions;  participants’
allocation of their deferred awards; and participant forfeitures,
cancellations,  or  accelerations.  See  “Forward-Looking
Statements” and “Risk Factors” for additional information.

For further information on the Firm's deferred stock-based plans
and carried interest compensation, which are excluded from the
previous tables, see Notes 2 and 18 to the financial statements.

Accounting Development Updates

The Financial Accounting Standards Board has issued certain
accounting  updates  that  apply  to  us. Accounting  updates  not
listed  below  were  assessed  and  either  determined  to  be  not
applicable or are not expected to have a significant impact on
our financial statements.

The  following  accounting  update  was  adopted  on  January  1,
2020:

41

December 2019 Form 10-K

Table of Contents
Management's Discussion and Analysis

• Financial  Instruments—Credit  Losses.  This  accounting
update  impacts  the  impairment  model  for  certain  financial
assets  measured  at  amortized  cost  by  requiring  a  CECL
methodology to estimate expected credit losses over the entire
life of the financial asset, recorded at inception or purchase.
CECL replaces the loss model currently applicable to loans
held  for  investment,  HTM  securities  and  other  receivables
carried at amortized cost, such as employee loans.

• Certain Securities purchased under agreements to resell;

• Certain Deposits, primarily certificates of deposit;

• Certain Securities sold under agreements to repurchase;

• Certain Other secured financings; and

• Certain Borrowings.

The  update  also  eliminates  the  concept  of  other-than-
temporary impairment for AFS securities and instead requires
impairments on AFS securities to be recognized in earnings
through  an  allowance  when  the  fair  value  is  less  than
amortized cost and a credit loss exists or the securities are
expected to be sold before recovery of amortized cost.

For certain portfolios, we have determined that there are no
expected  credit  losses;  for  example,  based  on  collateral
arrangements for lending and financing transactions, such as
Securities borrowed, Securities purchased under agreements
to resell and certain other portfolios. Also, we have a zero loss
expectation  for  certain  financial  assets  based  on  the  credit
quality of the borrower or issuer, such as U.S. government
and agency securities.

At  transition  on  January  1,  2020,  the  adoption  of  this
accounting standard resulted in an increase in the allowance
for  credit  losses  of  $131  million  with  a  corresponding
reduction in Retained earnings of $100 million, net of tax.
The increase in the allowance for credit losses was primarily
attributable to employee loans, commercial real estate loans
and securities, and residential real estate loans, partially offset
by a decrease primarily in secured lending facilities within
corporate loans. Prior period amounts will not be restated.

Critical Accounting Policies

Our financial statements are prepared in accordance with U.S.
GAAP, which requires us to make estimates and assumptions
(see Note 1 to the financial statements). We believe that of our
significant  accounting  policies  (see  Note  2  to  the  financial
statements), the following policies involve a higher degree of
judgment and complexity.

Fair Value

Financial Instruments Measured at Fair Value

A significant number of our financial instruments are carried at
fair value. We make estimates regarding the valuation of assets
and liabilities measured at fair value in preparing the financial
statements.  These  assets  and  liabilities  include,  but  are  not
limited to:

• Trading assets and Trading liabilities;

• Investment Securities—AFS securities;

Fair value is defined as the price that would be received to sell
an asset or paid to transfer a liability (i.e., the exit price) in an
orderly 
the
measurement date.

transaction  between  market  participants  at 

In determining fair value, we use various valuation approaches.
A  hierarchy  for  inputs  is  used  in  measuring  fair  value  that
maximizes  the  use  of  observable  prices  and  inputs  and
minimizes the use of unobservable prices and inputs by requiring
that the relevant observable inputs be used when available. The
hierarchy  is  broken  down  into  three  levels,  wherein  Level 1
represents quoted prices in active markets, Level 2 represents
valuations based on quoted prices in markets that are not active
or for which all significant inputs are observable, and Level 3
consists  of  valuation  techniques  that  incorporate  significant
unobservable inputs and, therefore, require the greatest use of
judgment. 

In periods of market disruption, the observability of prices and
inputs may be reduced for many instruments, which could cause
an instrument to be recategorized from Level 1 to Level 2 or
from  Level 2  to  Level 3.  In  addition,  a  downturn  in  market
conditions  could  lead  to  declines  in  the  valuation  of  many
instruments.  For  further  information  on  the  definition  of  fair
value,  Level 1,  Level 2,  Level 3  and  related  valuation
techniques, and quantitative information about and sensitivity
of  significant  unobservable  inputs  used  in  Level 3  fair  value
measurements, see Notes 2 and 3 to the financial statements.

Where appropriate, valuation adjustments are made to account
for various factors such as liquidity risk (bid-ask adjustments),
credit quality, model uncertainty, concentration risk and funding
in  order  to  arrive  at  fair  value.  For  a  further  discussion  of
valuation adjustments that we apply, see Note 2 to the financial
statements.

Goodwill and Intangible Assets

Goodwill

We test goodwill for impairment on an annual basis as of July 1
and on an interim basis when certain events or circumstances
exist. Evaluating goodwill for impairment requires management
to make significant judgments. Goodwill impairment tests are
performed at the reporting unit level, which is generally at the
level of or one level below our business segments. Goodwill no
longer retains its association with a particular acquisition once
it has been assigned to a reporting unit. As such, all the activities

December 2019 Form 10-K

42

Table of Contents
Management's Discussion and Analysis

of a reporting unit, whether acquired or organically developed,
are available to support the value of the goodwill.

For  both  the  annual  and  interim  tests,  we  have  the  option  to
either  (i) perform  a  quantitative  impairment  test  or  (ii) first
perform a qualitative assessment to determine whether it is more
likely than not that the fair value of a reporting unit is less than
its carrying amount, in which case the quantitative test would
be performed.

When performing a quantitative impairment test, we compare
the  fair  value  of  a  reporting  unit  with  its  carrying  amount,
including goodwill. If the fair value of the reporting unit is less
than its carrying amount, the goodwill impairment loss is equal
to the excess of the carrying value over the fair value, limited
by the carrying amount of goodwill allocated to that reporting
unit.

The estimated fair value of the reporting units is derived based
on valuation techniques we believe market participants would
use for each of the reporting units. The estimated fair value is
generally  determined  by  utilizing  a  discounted  cash  flow
methodology or methodologies that incorporate price-to-book
and  price-to-earnings  multiples  of  certain  comparable
companies. At each annual goodwill impairment testing date,
each of our reporting units with goodwill had a fair value that
was substantially in excess of its carrying value.

Intangible Assets

Amortizable intangible assets are amortized over their estimated
useful lives and are reviewed for impairment on an interim basis
when  certain  events  or  circumstances  exist.  An  impairment
exists when the carrying amount of the intangible asset exceeds
its  fair  value.  An  impairment  loss  will  be  recognized  if  the
carrying amount of the intangible asset is not recoverable and
exceeds its fair value. The carrying amount of the intangible
asset is not recoverable if it exceeds the sum of the expected
undiscounted cash flows.

For  both  goodwill  and  intangible  assets,  to  the  extent  an
impairment loss is recognized, the loss establishes the new cost
basis of the asset. Subsequent reversal of impairment losses is
not permitted. For amortizable intangible assets, the new cost
basis is amortized over the remaining useful life of that asset.
Adverse market or economic events could result in impairment
charges in future periods.

See Notes 2, 3 and 9 to the financial statements for additional
information about goodwill and intangible assets.

Legal and Regulatory Contingencies

In the normal course of business, we have been named, from
time to time, as a defendant in various legal actions, including
arbitrations,  class  actions  and  other  litigation,  arising  in
connection with our activities as a global diversified financial
services institution.

Certain of the actual or threatened legal actions include claims
for substantial compensatory and/or punitive damages or claims
for  indeterminate  amounts  of  damages.  In  some  cases,  the
entities that would otherwise be the primary defendants in such
cases are bankrupt or in financial distress.

We  are  also  involved,  from  time  to  time,  in  other  reviews,
investigations and proceedings (both formal and informal) by
governmental  and  self-regulatory  agencies  regarding  our
business and involving, among other matters, sales and trading
investment  management  services,
activities,  wealth  and 
financial products or offerings sponsored, underwritten or sold
by us, and accounting and operational matters, certain of which
may result in adverse judgments, settlements, fines, penalties,
injunctions or other relief.

Accruals for litigation and regulatory proceedings are generally
determined  on  a  case-by-case  basis.  Where  available
information  indicates  that  it  is  probable  a  liability  had  been
incurred  at  the  date  of  the  financial  statements  and  we  can
reasonably  estimate  the  amount  of  that  loss,  we  accrue  the
estimated  loss  by  a  charge  to  income.  In  many  proceedings,
however, it is inherently difficult to determine whether any loss
is probable or even possible or to estimate the amount of any
loss.

For  certain  legal  proceedings  and  investigations,  we  can
estimate  possible  losses,  additional  losses,  ranges  of  loss  or
ranges  of  additional  loss  in  excess  of  amounts  accrued.  For
certain other legal proceedings and investigations, we cannot
reasonably  estimate  such  losses,  particularly  for  proceedings
and investigations where the factual record is being developed
or  contested  or  where  plaintiffs  or  government  entities  seek
substantial or indeterminate damages, restitution, disgorgement
or penalties.

through  potentially 

Numerous  issues  may  need  to  be  resolved  before  a  loss  or
additional loss or range of loss or additional range of loss can
be  reasonably  estimated  for  a  proceeding  or  investigation,
lengthy  discovery  and
including 
determination  of  important  factual  matters,  determination  of
issues  related  to  class  certification  and  the  calculation  of
damages or other relief, and addressing novel or unsettled legal
questions  relevant  to  the  proceedings  or  investigations  in
question.

Significant judgment is required in deciding when and if to make
these accruals, and the actual cost of a legal claim or regulatory
fine/penalty  may  ultimately  be  materially  different  from  the
recorded accruals.

See  Note  13  to  the  financial  statements  for  additional
information on legal contingencies.

43

December 2019 Form 10-K

Table of Contents
Management's Discussion and Analysis

Income Taxes

We are subject to the income and indirect tax laws of the U.S.,
its states and municipalities and those of the foreign jurisdictions
in which we have significant business operations. These tax laws
are  complex  and  subject  to  different  interpretations  by  the
taxpayer and the relevant governmental taxing authorities. We
must make judgments and interpretations about the application
of  these  inherently  complex  tax  laws  when  determining  the
provision for income taxes and the expense for indirect taxes
and must also make estimates about when certain items affect
taxable income in the various tax jurisdictions.

Disputes over interpretations of the tax laws may be settled with
the taxing authority upon examination or audit. We periodically
evaluate the likelihood of assessments in each taxing jurisdiction
resulting from current and subsequent years’ examinations, and
unrecognized tax benefits related to potential losses that may
arise  from  tax  audits  are  established  in  accordance  with  the
relevant accounting guidance. Once established, unrecognized
tax  benefits  are  adjusted  when  there  is  more  information
available or when an event occurs requiring a change.

Our  provision  for  income  taxes  is  composed  of  current  and
deferred taxes. Current income taxes approximate taxes to be
paid or refunded for the current period. Deferred income taxes
reflect the net tax effects of temporary differences between the
financial reporting and tax bases of assets and liabilities and are
measured using the applicable enacted tax rates and laws that
will be in effect when such differences are expected to reverse.

Our  deferred  tax  balances  may  also  include  deferred  assets
related  to  tax  attribute  carryforwards,  such  as  net  operating
losses and tax credits that will be realized through reduction of
future tax liabilities and, in some cases, are subject to expiration
if not utilized within certain periods. We perform regular reviews
to  ascertain  whether  deferred  tax  assets  are  realizable. These
reviews  include  management’s  estimates  and  assumptions
regarding  future  taxable  income  and  incorporate  various  tax
planning strategies, including strategies that may be available
to tax attribute carryforwards before they expire.

Once the deferred tax asset balances have been determined, we
may record a valuation allowance against the deferred tax asset
balances to reflect the amount we estimate is more likely than
not to be realized at a future date. Both current and deferred
income 
to  our
taxes  may  reflect  adjustments  related 
unrecognized tax benefits.

Significant judgment is required in estimating the consolidated
provision for (benefit from) income taxes, current and deferred
tax balances (including valuation allowance, if any), accrued
interest or penalties and uncertain tax positions. Revisions in
estimates  and/or  the  actual  costs  of  a  tax  assessment  may
ultimately be materially different from the recorded accruals and
unrecognized tax benefits, if any.

December 2019 Form 10-K

44

See Note 2 to the financial statements for additional information
on our significant assumptions, judgments and interpretations
associated with the accounting for income taxes and Note 20 to
the financial statements for additional information on our tax
examinations.

Liquidity and Capital Resources

Senior  management,  with  oversight  by  the  Asset/Liability
Management Committee and the Board of Directors (“Board”),
establishes  and  maintains  our  liquidity  and  capital  policies.
Through  various 
risk  and  control  committees,  senior
management  reviews  business  performance  relative  to  these
policies,  monitors  the  availability  of  alternative  sources  of
financing, and oversees the liquidity, interest rate and currency
sensitivity  of  our  asset  and  liability  position.  The  Treasury
department, 
Firm  Risk  Committee,  Asset/Liability
Management  Committee,  and  other  committees  and  control
groups  assist  in  evaluating,  monitoring  and  controlling  the
impact that our business activities have on our balance sheet,
liquidity and capital structure. Liquidity and capital matters are
reported regularly to the Board and the Risk Committee of the
Board.

Balance Sheet

We monitor and evaluate the composition and size of our balance
sheet on a regular basis. Our balance sheet management process
includes  quarterly  planning,  business  segment  thresholds,
monitoring of business-specific usage versus key performance
metrics and new business impact assessments.

We establish balance sheet thresholds at the consolidated and
business segment levels. We monitor balance sheet utilization
and  review  variances  resulting  from  business  activity  and
market  fluctuations.  On  a  regular  basis,  we  review  current
performance versus established thresholds and assess the need
to re-allocate the balance sheet based on business unit needs.
We also monitor key metrics, including asset and liability size
and capital usage.

Total Assets by Business Segment

At December 31, 2019

$ in millions

IS

WM

IM

Total

Assets
Cash and cash equivalents1

$ 67,657 $ 14,247 $

267 $ 82,171

Trading assets at fair value

293,477

47

3,586

297,110

Investment securities

38,524

67,201

— 105,725

Securities purchased under 

agreements to resell

Securities borrowed

Customer and other 

receivables

Loans, net of allowance2
Other assets3

80,744

106,199

39,743

50,557

14,300

7,480

350

15,190

80,075

13,092

—

88,224

— 106,549

713

55,646

5

130,637

1,975

29,367

Total assets

$ 691,201 $ 197,682 $

6,546 $ 895,429

Table of Contents
Management's Discussion and Analysis

$ in millions

IS

WM

IM

Total

should be diversified; and

At December 31, 2018

• Source, counterparty, currency, region and term of funding

Assets
Cash and cash equivalents1

$ 69,526 $ 17,621 $

49 $ 87,196

Trading assets at fair value

263,870

60

2,369

266,299

Investment securities

23,273

68,559

Securities purchased under 

agreements to resell

80,660

17,862

—

—

91,832

98,522

Securities borrowed

Customer and other 

receivables

Loans, net of allowance2
Other assets3

116,207

106

— 116,313

35,777

43,380

13,734

16,865

72,194

9,125

656

53,298

5

115,579

1,633

24,492

Total assets

$ 646,427 $ 202,392 $

4,712 $ 853,531

IS—Institutional Securities
WM—Wealth Management
IM—Investment Management
1. Cash  and  cash  equivalents  includes  Cash  and  due  from  banks,  Interest  bearing

deposits with banks and Restricted cash.

2. Amounts include loans held for investment (net of allowance) and loans held for sale
but exclude loans at fair value, which are included in Trading assets in the balance
sheets (see Note 8 to the financial statements).

3. Other assets primarily includes Goodwill and Intangible assets, premises, equipment
and  software,  ROU  assets  related  to  leases,  other  investments  and  deferred  tax
assets.

A substantial portion of total assets consists of liquid marketable
securities and short-term receivables arising principally from
sales  and  trading  activities  in  the  Institutional  Securities
business  segment.  Total  assets  increased  to  $895  billion  at
December 31,  2019  compared  with  $854  billion  at
December 31,  2018,  driven  by  the  Institutional  Securities
business segment. Within Institutional Securities, the primary
increases were: Trading assets, primarily corporate equities in
line  with  market  conditions;  Investment  securities,  primarily
U.S. Treasuries; and continued Loan growth. These increases
were partially offset by reduced Securities borrowed resulting
from lower funding requirements. Wealth Management assets
were  lower  primarily  due  to  decreased  Securities  purchased
under agreements to resell as a result of lower deposits in this
segment, partially offset by continued Loan growth.

Liquidity Risk Management Framework

The  primary  goal  of  our  Liquidity  Risk  Management
Framework is to ensure that we have access to adequate funding
across a wide range of market conditions and time horizons. The
framework  is  designed  to  enable  us  to  fulfill  our  financial
obligations and support the execution of our business strategies.

The following principles guide our Liquidity Risk Management
Framework:

• Sufficient  liquid  assets  should  be  maintained  to  cover
maturing  liabilities  and  other  planned  and  contingent
outflows;

• Liquidity  Stress  Tests  should  anticipate,  and  account  for,

periods of limited access to funding.

The  core  components  of  our  Liquidity  Risk  Management
Framework  that  support  our  target  liquidity  profile  are  the
Required Liquidity Framework, Liquidity Stress Tests and the
GLR.

Required Liquidity Framework

Our Required Liquidity Framework establishes the amount of
liquidity we must hold in both normal and stressed environments
to ensure that our financial condition and overall soundness are
not adversely affected by an inability (or perceived inability) to
meet our financial obligations in a timely manner. The Required
Liquidity Framework considers the most constraining liquidity
requirement  to  satisfy  all  regulatory  and  internal  limits  at  a
consolidated and legal entity level.

Liquidity Stress Tests

We  use  Liquidity  Stress  Tests  to  model  external  and
intercompany liquidity flows across multiple scenarios and a
range  of  time  horizons.  These  scenarios  contain  various
combinations  of  idiosyncratic  and  systemic  stress  events  of
different 
duration.  The  methodology,
implementation, production and analysis of our Liquidity Stress
Tests  are  important  components  of  the  Required  Liquidity
Framework.

severity 

and 

The assumptions used by us in our various Liquidity Stress Test
scenarios include, but are not limited to, the following:

• No government support;

• No access to equity and unsecured debt markets;

• Repayment of all unsecured debt maturing within the stress

horizon;

• Higher  haircuts  for  and  significantly  lower  availability  of

secured funding;

• Additional  collateral  that  would  be  required  by  trading
counterparties, certain exchanges and clearing organizations
related to credit rating downgrades;

• Additional collateral that would be required due to collateral
substitutions, collateral disputes and uncalled collateral;

• Discretionary unsecured debt buybacks;

• Maturity profile of assets and liabilities should be aligned,

with limited reliance on short-term funding;

• Drawdowns  on  lending  commitments  provided  to  third

parties; and

45

December 2019 Form 10-K

Table of Contents
Management's Discussion and Analysis

• Client  cash  withdrawals  and  reduction  in  customer  short

GLR Managed by Bank and Non-Bank Legal Entities

At
December 31,
2019

At
December 31,
2018

Average Daily Balance
Three Months Ended
December 31, 2019

$ in millions

Bank legal entities

Domestic

Foreign

Total Bank legal

entities

$

75,565 $

88,809 $

5,317

4,896

80,882

93,705

Non-Bank legal entities

Domestic:

Parent Company

53,042

64,262

Non-Parent
Company

Total Domestic

Foreign

Total Non-Bank
legal entities

Total

29,656

82,698

53,877

40,936

105,198

50,832

136,575

156,030

$

217,457 $

249,735 $

73,107

5,661

78,768

58,955

31,188

90,143

54,654

144,797

223,565

GLR may fluctuate from period to period based on the overall
size and composition of our balance sheet, the maturity profile
of  our  unsecured  debt  and  estimates  of  funding  needs  in  a
stressed environment, among other factors. 

Regulatory Liquidity Framework

Liquidity Coverage Ratio

We  and  our  U.S.  Bank  Subsidiaries  are  subject  to  LCR
requirements, including a requirement to calculate each entity’s
LCR on each business day. The requirements are designed to
ensure  that  banking  organizations  have  sufficient  HQLA  to
cover net cash outflows arising from significant stress over 30
calendar days, thus promoting the short-term resilience of the
liquidity risk profile of banking organizations. 

The regulatory definition of HQLA is substantially the same as
our GLR, with the primary difference being the treatment of
certain cash balances and unencumbered securities. 

As of December 31, 2019, we and our U.S. Bank Subsidiaries
are compliant with the minimum required LCR of 100%.

positions that fund long positions.

Liquidity Stress Tests are produced and results are reported at
different  levels,  including  major  operating  subsidiaries  and
major currencies, to capture specific cash requirements and cash
availability across the Firm, including a limited number of asset
sales  in  a  stressed  environment.  The  Liquidity  Stress  Tests
assume that subsidiaries will use their own liquidity first to fund
their  obligations  before  drawing  liquidity  from  the  Parent
Company  and  that  the  Parent  Company  will  support  its
subsidiaries and will not have access to subsidiaries’ liquidity
reserves.  In  addition  to  the  assumptions  underpinning  the
Liquidity Stress Tests, we take into consideration settlement risk
related  to  intraday  settlement  and  clearing  of  securities  and
financing activities.

At December 31, 2019 and December 31, 2018, we maintained
sufficient  liquidity  to  meet  current  and  contingent  funding
obligations as modeled in our Liquidity Stress Tests.

Global Liquidity Reserve

We maintain sufficient liquidity reserves to cover daily funding
needs  and  to  meet  strategic  liquidity  targets  sized  by  the
Required Liquidity Framework and Liquidity Stress Tests. The
size  of  the  GLR  is  actively  managed  by  us  considering  the
following components: unsecured debt maturity profile; balance
sheet  size  and  composition;  funding  needs  in  a  stressed
environment, inclusive of contingent cash outflows; legal entity,
regional  and  segment  liquidity  requirements;  regulatory
requirements; and collateral requirements. 

In addition, our GLR includes a discretionary surplus based on
risk tolerance and is subject to change depending on market and
Firm-specific  events.  The  GLR  is  held  within  the  Parent
Company  and  its  major  operating  subsidiaries.  The  GLR
consists  of  cash  and  unencumbered  securities  sourced  from
trading assets, investment securities and securities received as
collateral.

GLR by Type of Investment

$ in millions
Cash deposits with banks1
Cash deposits with central banks1

Unencumbered highly liquid securities:

At
December 31,
2019

At
December 31,
2018

$

9,856 $

34,922

10,441

36,109

U.S. government obligations

88,665

119,138

U.S. agency and agency mortgage-

backed securities

 Non-U.S. sovereign obligations2

Other investment grade securities

50,054

31,460

2,500

41,473

39,869

2,705

Total

$

217,457 $

249,735

1. Included in Cash and due from banks and Interest bearing deposits with banks in the

balance sheets.

2. Primarily composed of unencumbered U.K., Japanese, French, German and Brazilian

government obligations.

December 2019 Form 10-K

46

 
Table of Contents
Management's Discussion and Analysis

HQLA by Type of Asset and LCR

$ in millions

HQLA

Cash deposits with central banks
Securities1

Total

LCR

Average Daily Balance
Three Months Ended

December 31,
2019

September 30,
2019

$

$

29,597

$

148,221

177,818

$

33,053

141,806

174,859

134%

140%

1. Primarily  includes  U.S.  Treasuries,  U.S.  agency  mortgage-backed  securities,

sovereign bonds and investment grade corporate bonds.

The  decrease  in  the  LCR  in  the  quarter  ended  December 31,
2019  is  primarily  due  to  higher  outflows  related  to  secured
funding and lower inflows related to secured lending.

Net Stable Funding Ratio

The  NSFR  requires  banking  organizations  to  maintain
sufficiently stable sources of funding over a one-year horizon.
In  2016,  the  U.S.  banking  agencies  issued  a  proposal  to
implement the NSFR in the U.S.; however, a final rule has not
yet been issued. If adopted, the requirements would apply to us
and  our  U.S.  Bank  Subsidiaries,  and  we  expect  to  be  in
compliance by the effective date of any final rule.

Funding Management

We manage our funding in a manner that reduces the risk of
disruption  to  our  operations.  We  pursue  a  strategy  of
diversification of secured and unsecured funding sources (by
product, investor and region) and attempt to ensure that the tenor
of our liabilities equals or exceeds the expected holding period
of the assets being financed.

We fund our balance sheet on a global basis through diverse
sources. These sources include our equity capital, borrowings,
securities  sold  under  agreements  to  repurchase,  securities
lending, deposits, letters of credit and lines of credit. We have
active  financing  programs  for  both  standard  and  structured
products targeting global investors and currencies.

Secured Financing

The liquid nature of the marketable securities and short-term
receivables arising principally from sales and trading activities
in the Institutional Securities business segment provides us with
flexibility in managing the composition and size of our balance
sheet. Our goal is to achieve an optimal mix of durable secured
and  unsecured 
investors
principally focus on the quality of the eligible collateral posted.
Accordingly, we actively manage our secured financings based
on the quality of the assets being funded.

financing.  Secured 

financing 

We have established longer tenor secured funding requirements
for less liquid asset classes, for which funding may be at risk in
the event of a market disruption. We define highly liquid assets

as government-issued or government-guaranteed securities with
a high degree of fundability and less liquid assets as those that
do not meet these criteria. 

To further minimize the refinancing risk of secured financing
for less liquid assets, we have established concentration limits
to diversify our investor base and reduce the amount of monthly
maturities  for  secured  financing  of 
liquid  assets.
Furthermore,  we  obtain  term  secured  funding  liabilities  in
excess of less liquid inventory as an additional risk mitigant to
replace  maturing  trades  in  the  event  that  secured  financing
markets,  or  our  ability  to  access  them,  become  limited. As  a
component of the Liquidity Risk Management Framework, we
hold a portion of our GLR against the potential disruption to our
secured financing capabilities.

less 

We  generally  maintain  a  pool  of  liquid  and  easily  fundable
securities,  which  takes  into  account  HQLA  classifications
consistent  with  LCR  definitions,  and  other  regulatory
requirements, and provides a valuable future source of liquidity.

Collateralized Financing Transactions

$ in millions

Securities purchased under agreements to

resell and Securities borrowed

Securities sold under agreements to
repurchase and Securities loaned

Securities received as collateral1

$ in millions

At
December 31,
2019

At
December 31,
2018

$

$

$

194,773 $

214,835

62,706 $

13,022 $

61,667

7,668

Average Daily Balance
Three Months Ended

December 31,
2019

December 31,
2018

Securities purchased under agreements to

resell and Securities borrowed

Securities sold under agreements to
repurchase and Securities loaned

$

$

210,257 $

213,974

64,870 $

57,677

1. Securities received as collateral are included in Trading assets in the balance sheets.

See "Total Assets by Business Segment" herein for more details
on the assets shown in the previous table and Notes 2 and 7 to
the  financial  statements  for  more  details  on  collateralized
financing transactions.

In addition to the collateralized financing transactions shown in
the  previous  table,  we  engage  in  financing  transactions
collateralized  by  customer-owned  securities,  which  are
segregated 
in  accordance  with  regulatory  requirements.
Receivables  under  these  financing  transactions,  primarily
margin loans, are included in Customer and other receivables
in  the  balance  sheets,  and  payables  under  these  financing
transactions,  primarily  to  prime  brokerage  customers,  are
included in Customer and other payables in the balance sheets.
Our risk exposure on these transactions is mitigated by collateral
maintenance policies. We also hold related liquidity reserves.

47

December 2019 Form 10-K

Table of Contents
Management's Discussion and Analysis

Unsecured Financing

We view deposits and borrowings as stable sources of funding
for  unencumbered  securities  and  non-security  assets.  Our
unsecured  financings  include  borrowings  and  certificates  of
deposit carried at fair value, which are primarily composed of:
instruments whose payments and redemption values are linked
to  the  performance  of  a  specific  index,  a  basket  of  stocks,  a
specific  equity  security,  a  commodity,  a  credit  exposure  or
basket  of  credit  exposures;  and  instruments  with  various
interest-rate-related  features,  including  step-ups,  step-downs
and zero coupons. When appropriate, we typically use derivative
products to conduct asset and liability management and to make
adjustments to our interest rate and borrowings risk profile (see
Notes 5 and 12 to the financial statements).

Deposits

$ in millions

Savings and demand deposits:
Brokerage sweep deposits1

Savings and other

Total Savings and demand deposits

Time deposits

Total

At
December 31,
2019

At
December 31,
2018

$

121,077 $

141,255

28,388

149,465

40,891

13,642

154,897

32,923

$

190,356 $

187,820

1. Amounts represent balances swept from client brokerage accounts.

Deposits are primarily sourced from our Wealth Management
clients  and  are  considered  to  have  stable,  low-cost  funding
characteristics.  Total  deposits  increased  in  2019,  primarily
driven  by  increases  in  preferred  Savings  and  Time  deposits.
These were partially offset by a reduction in Brokerage sweep
deposits due to net outflows into investment products and higher
client tax payments.

Borrowings by Remaining Maturity at December 31, 20191

$ in millions

Original maturities of one year or

less

Parent
Company

Subsidiaries

Total

$

500 $

2,067 $

2,567

Original maturities greater than one year

2020

2021

2022

2023

2024

Thereafter

Total

Total Borrowings

$

15,228 $

5,174 $

21,439

16,084

11,779

15,388

67,377

4,646

3,804

2,836

5,718

20,587

20,402

26,085

19,888

14,615

21,106

87,964

$

$

147,295 $

42,765 $

190,060

147,795 $

44,832 $

192,627

1. Original  maturity  in  the  table  is  generally  based  on  contractual  final  maturity.  For
borrowings with put options, remaining maturity represents the earliest put date.

Borrowings  of  $193  billion  as  of  December 31,  2019  were
relatively  unchanged  compared  with  $190  billion  at
December 31, 2018.

December 2019 Form 10-K

48

We  believe  that  accessing  debt  investors  through  multiple
distribution  channels  helps  provide  consistent  access  to  the
unsecured markets. In addition, the issuance of borrowings with
original  maturities  greater  than  one  year  allows  us  to  reduce
reliance on short-term credit sensitive instruments. Borrowings
with  original  maturities  greater  than  one  year  are  generally
managed  to  achieve  staggered  maturities,  thereby  mitigating
refinancing  risk,  and  to  maximize  investor  diversification
through  sales  to  global  institutional  and  retail  clients  across
regions, currencies and product types.

The availability and cost of financing to us can vary depending
on market conditions, the volume of certain trading and lending
activities, our credit ratings and the overall availability of credit.
We also engage in, and may continue to engage in, repurchases
of our borrowings in the ordinary course of business.

For  further  information  on  Borrowings,  see  Note  12  to  the
financial statements.

Credit Ratings

We rely on external sources to finance a significant portion of
our  daily  operations.  The  cost  and  availability  of  financing
generally are impacted by our credit ratings, among other things.
In  addition,  our  credit  ratings  can  have  an  impact  on  certain
trading revenues, particularly in those businesses where longer-
term counterparty performance is a key consideration, such as
certain OTC derivative transactions. When determining credit
ratings,  rating  agencies  consider  both  company-specific  and
industry-wide factors. These include regulatory or legislative
changes, the macroeconomic environment and perceived levels
of  support,  among  other  things.  See  also  "Risk  Factors—
Liquidity Risk."

Parent Company and U.S. Bank Subsidiaries' Issuer Ratings at
February 19, 2020

DBRS, Inc.

Fitch Ratings, Inc.

Moody’s Investors Service, Inc.

Rating and Investment Information,

Inc.

S&P Global Ratings

Parent Company

Short-Term
Debt

Long-Term
Debt

R-1 (middle)

A (high)

F1

P-2

a-1

A-2

A

A3

A

BBB+

MSBNA

Short-Term
Debt

Long-Term
Debt

Fitch Ratings, Inc.

Moody’s Investors Service, Inc.

S&P Global Ratings

F1

P-1

A-1

A+

A1

A+

Rating
Outlook

Stable

Stable

Positive

Stable

Stable

Rating
Outlook

Stable

Positive

Stable

Table of Contents
Management's Discussion and Analysis

MSPBNA

Short-Term
Debt

Long-Term
Debt

Moody’s Investors Service, Inc.

S&P Global Ratings

P-1

A-1

A1

A+

Rating
Outlook

Positive

Stable

For a description of our capital plan, see “Liquidity and Capital
Resources—Regulatory  Requirements—Capital  Plans  and
Stress Tests.”

Common Stock Dividend Announcement

Announcement date

Amount per share

Date paid

Shareholders of record as of

Preferred Stock Dividend Announcement

Announcement date

Date paid

Shareholders of record as of

January 16, 2020

$0.35

February 14, 2020

January 31, 2020

December 16, 2019

January 15, 2020

December 31, 2019

For additional information on common and preferred stock, see
Note 16 to the financial statements.

Off-Balance  Sheet  Arrangements  and  Contractual
Obligations

Off-Balance Sheet Arrangements

We enter into various off-balance sheet arrangements, including
through  unconsolidated  SPEs  and  lending-related  financial
instruments (e.g., guarantees and commitments), primarily in
connection  with  the  Institutional  Securities  and  Investment
Management business segments.

We  utilize  SPEs  primarily  in  connection  with  securitization
activities. For information on our securitization activities, see
Note 14 to the financial statements.

For information on our commitments, obligations under certain
guarantee  arrangements  and  indemnities,  see  Note  13  to  the
financial  statements.  For  further  information  on  our  lending
commitments,  see  “Quantitative  and  Qualitative  Disclosures
about Risk—Credit Risk—Loans and Lending Commitments.”

On February 21, 2020, Moody’s Investors Service, Inc. placed
the Parent Company and U.S. Bank Subsidiaries on review for
possible  upgrade,  changing  their  outlooks  from  Positive  to
Ratings Under Review.

Incremental Collateral or Terminating Payments

In  connection  with  certain  OTC  derivatives  and  other
agreements  where  we  are  a  liquidity  provider  to  certain
financing vehicles associated with the Institutional Securities
business  segment,  we  may  be  required  to  provide  additional
collateral, immediately settle any outstanding liability balances
with  certain  counterparties  or  pledge  additional  collateral  to
certain  clearing  organizations  in  the  event  of  a  future  credit
rating downgrade irrespective of whether we are in a net asset
or net liability position. See Note 5 to the financial statements
for additional information on OTC derivatives that contain such
contingent features.

While  certain  aspects  of  a  credit  rating  downgrade  are
quantifiable  pursuant  to  contractual  provisions,  the  impact  it
would have on our business and results of operations in future
periods is inherently uncertain and would depend on a number
of  interrelated  factors,  including,  among  other  things,  the
magnitude of the downgrade, the rating relative to peers, the
rating  assigned  by  the  relevant  agency  pre-downgrade,
individual  client  behavior  and  future  mitigating  actions  we
might  take.  The  liquidity  impact  of  additional  collateral
requirements is included in our Liquidity Stress Tests.

Capital Management

We view capital as an important source of financial strength and
actively manage our consolidated capital position based upon,
among  other  things,  business  opportunities,  risks,  capital
availability  and  rates  of  return  together  with  internal  capital
policies, regulatory requirements and rating agency guidelines.
In  the  future,  we  may  expand  or  contract  our  capital  base  to
address the changing needs of our businesses.

Common Stock Repurchases

in millions, except for per share data

2019

2018

2017

Number of shares

Average price per share

Total

121

97

80

$

$

44.23 $

50.08 $

47.01

5,360 $

4,860 $

3,750

For further information on our common stock repurchases, see
Note 16 to the financial statements.

49

December 2019 Form 10-K

Table of Contents
Management's Discussion and Analysis

Contractual Obligations

Regulatory Capital Requirements

At December 31, 2019

Payments Due in:

2020

2021-2022 2023-2024 Thereafter

Total

$20,402 $

45,973 $

35,721 $

87,964 $190,060

1,663

1,337

2,667

813

6,480

4,252

6,872

5,128

14,541

30,793

20,762

14,082

5,708

622

41,174

763

662

1,349

1,117

2,845

6,074

659

225

288

1,834

We are required to maintain minimum risk-based and leverage-
based capital, and TLAC ratios. For additional information on
TLAC, see “Total Loss-Absorbing Capacity, Long-Term Debt
and Clean Holding Company Requirements” herein.

Risk-Based  Regulatory  Capital.  Minimum  risk-based  capital
ratio requirements apply to Common Equity Tier 1 capital, Tier
1 capital and Total capital (which includes Tier 2 capital). Capital
standards require certain adjustments to, and deductions from,
capital for purposes of determining these ratios.

In  addition 
requirements, we are subject to the following buffers:

the  minimum  risk-based  capital  ratio

to 

$48,504 $

70,272 $

50,566 $ 107,073 $276,415

• A  greater  than  2.5%  Common  Equity  Tier  1  capital

$ in millions
Borrowings1

Other secured
financings1

Contractual
interest
payments2

Time deposits—
principal and
interest
payments

Operating leases
— premises3

Purchase

obligations4

Total5

1. Amounts presented for Borrowings and Other secured financings are financings with
original maturities greater than one year. For further information on Borrowings and
Other secured financings, see Note 12 to the financial statements.

2. Amounts represent estimated future contractual interest payments related to certain
unsecured  borrowings  with  original  maturities  greater  than  one  year  based  on
applicable interest rates at December 31, 2019. These amounts exclude borrowings
carried at fair value. For additional information on borrowings carried at fair value, see
Note 12 to the financial statements.

3. For further information on operating leases covering premises and equipment, see

Note 10 to the financial statements.

4. Purchase obligations for goods and services include payments for, among other things,
consulting, outsourcing, computer and telecommunications maintenance agreements,
and  certain  transmission,  transportation  and  storage  contracts  related  to  the
commodities business.

5. Amounts exclude unrecognized tax benefits, as the timing and amount of future cash
payments are not determinable at this time (see Note 20 to the financial statements
for further information).

Regulatory Requirements

Regulatory Capital Framework

requirements.  Regulatory  capital 

We are an FHC under the Bank Holding Company Act of 1956,
as amended (“BHC Act”), and are subject to the regulation and
oversight  of  the  Federal  Reserve.  The  Federal  Reserve
establishes  capital  requirements  for  us,  including  “well-
capitalized” standards, and evaluates our compliance with such
requirements
capital 
established by the Federal Reserve are largely based on the Basel
III capital standards established by the Basel Committee and
also implement certain provisions of the Dodd-Frank Wall Street
Reform and Consumer Protection Act (“Dodd-Frank Act”). The
OCC establishes similar capital requirements and standards for
our U.S. Bank Subsidiaries. For us to remain an FHC, we must
remain  well-capitalized 
in  accordance  with  standards
established  by  the  Federal  Reserve,  and  our  U.S.  Bank
Subsidiaries must remain well-capitalized in accordance with
standards established by the OCC. For additional information
on  regulatory  capital  requirements  for  our  U.S.  Bank
Subsidiaries, see Note 15 to the financial statements.

conservation buffer;

• The Common Equity Tier 1 G-SIB capital surcharge, currently

at 3%; and

• Up to a 2.5% Common Equity Tier 1 CCyB, currently set by

U.S. banking agencies at zero.

In 2018, the requirement for each of these buffers was 75% of
the fully phased-in 2019 requirement noted above. For a further
discussion of the G-SIB capital surcharge, see “G-SIB Capital
Surcharge” herein.

Risk-Weighted  Assets.  RWA  reflects  both  our  on-  and  off-
balance sheet risk, as well as capital charges attributable to the
risk of loss arising from the following:

• Credit risk: The failure of a borrower, counterparty or issuer

to meet its financial obligations to us;

• Market  risk: Adverse  changes  in  the  level  of  one  or  more
market prices, rates, indices, volatilities, correlations or other
market factors, such as market liquidity; and

• Operational risk: Inadequate or failed processes or systems,
from human factors or from external events (e.g., fraud, theft,
legal  and  compliance  risks,  cyber  attacks  or  damage  to
physical assets).

Our  risk-based  capital  ratios  for  purposes  of  determining
regulatory  compliance  are  the  lower  of  the  capital  ratios
computed under (i) the standardized approaches for calculating
credit risk and market risk RWA (“Standardized Approach”) or
(ii) the applicable advanced approaches for calculating credit
risk,  market  risk  and  operational  risk  RWA  (“Advanced
Approach”). The credit risk RWA calculations between the two
approaches differ in that the Standardized Approach requires
calculation of RWA using prescribed risk weights, whereas the
Advanced  Approach  utilizes  models  to  calculate  exposure
amounts and risk weights. At December 31, 2019 and 2018, our

December 2019 Form 10-K

50

Table of Contents
Management's Discussion and Analysis

ratios for determining regulatory compliance are based on the
Standardized Approach rules.

Leverage-Based Regulatory Capital. Minimum leverage-based
capital requirements include a Tier 1 leverage ratio and an SLR.
We are required to maintain a Tier 1 SLR of 5%, inclusive of an
enhanced SLR capital buffer of at least 2%.

Regulatory Capital Ratios

$ in millions

Risk-based capital

At December 31, 2019

Required
Ratio1

Standardized

Advanced

Common Equity Tier 1 capital

$

64,751

$

Tier 1 capital

Total capital

Total RWA

Common Equity Tier 1 capital 

ratio

Tier 1 capital ratio

Total capital ratio

$ in millions

Leverage-based capital
Adjusted average assets2

Tier 1 leverage ratio
Supplementary leverage exposure3

SLR

73,443

82,708

64,751

73,443

82,423

394,177

382,496

10.0%

11.5%

13.5%

16.4%

18.6%

21.0%

16.9%

19.2%

21.5%

Required
Ratio1

At
December 31,
2019

$

889,195

4.0%

8.3%

$ 1,155,177

5.0%

6.4%

$ in millions

Risk-based capital

At December 31, 2018

Required
Ratio1

Standardized

Advanced

Common Equity Tier 1 capital

$

62,086

$

Tier 1 capital

Total capital

Total RWA

Common Equity Tier 1 capital 

ratio

Tier 1 capital ratio

Total capital ratio

$ in millions

Leverage-based capital
Adjusted average assets2

Tier 1 leverage ratio
Supplementary leverage exposure3

SLR

70,619

80,052

62,086

70,619

79,814

367,309

363,054

8.6%

10.1%

12.1%

16.9%

19.2%

21.8%

17.1%

19.5%

22.0%

Required
Ratio1

At
December 31,
2018

$

843,074

4.0%

8.4%

$ 1,092,672

5.0%

6.5%

1. Required ratios are inclusive of any buffers applicable as of the date presented. For
2018,  the  required  regulatory  capital  ratios  for  risk-based  capital  are  under  the
transitional rules. Failure to maintain the buffers would result in restrictions on our
ability  to  make  capital  distributions,  including  the  payment  of  dividends  and  the
repurchase of stock, and to pay discretionary bonuses to executive officers.

2. Adjusted average assets represents the denominator of the Tier 1 leverage ratio and
is composed of the average daily balance of consolidated on-balance sheet assets
for the quarters ending on the respective balance sheet dates, reduced by disallowed
goodwill,  intangible  assets,  investments  in  covered  funds,  defined  benefit  pension
plan assets, after-tax gain on sale from assets sold into securitizations, investments
in our own capital instruments, certain deferred tax assets and other capital deductions.
3. Supplementary leverage exposure is the sum of Adjusted average assets used in the
Tier 1 leverage ratio and other adjustments, primarily: (i) for derivatives, potential future
exposure and the effective notional principal amount of sold credit protection offset
by qualifying purchased credit protection; (ii) the counterparty credit risk for repo-style
transactions; and (iii) the credit equivalent amount for off-balance sheet exposures.

51

December 2019 Form 10-K

Table of Contents
Management's Discussion and Analysis

Regulatory Capital

RWA Rollforward1

$ in millions

Common Equity Tier 1 capital

At
December 31,
2019

At
December 31,
2018

Change

$ in millions

Credit risk RWA

2019

Standardized

Advanced

Common stock and surplus

$

5,228 $

9,843 $

(4,615)

Balance at December 31, 2018

$

305,531 $

190,595

Retained earnings

AOCI

Regulatory adjustments and deductions:

Net goodwill

Net intangible assets

Other adjustments and 

deductions1

Total Common Equity Tier 1

capital

Additional Tier 1 capital

Preferred stock

Noncontrolling interests

Additional Tier 1 capital

Deduction for investments 

in covered funds

Total Tier 1 capital

Standardized Tier 2 capital

Subordinated debt

Noncontrolling interests

Eligible allowance for credit 

losses

Other adjustments and 

deductions

Total Standardized Tier 2 

capital

Total Standardized capital

Advanced Tier 2 capital

Subordinated debt

Noncontrolling interests

Eligible credit reserves

Other adjustments and 

deductions

Total Advanced Tier 2 

capital

Total Advanced capital

$

$

$

$

$

$

$

$

$

$

70,589

(2,788)

(7,081)

(2,012)

64,175

(2,292)

(6,661)

(2,158)

6,414

(496)

(420)

146

815

(821)

1,636

64,751 $

62,086 $

2,665

8,520 $

8,520 $

607

454

9,127 $

8,974 $

(435)

(441)

—

153

153

6

73,443 $

70,619 $

2,824

8,538 $

8,923 $

(385)

143

590

(6)

107

440

(37)

36

150

31

Change related to the following items:

Derivatives

Securities financing transactions

Securitizations

Investment securities

Commitments, guarantees and 

loans

Cash

Equity investments
Other credit risk2

Total change in credit risk RWA

Balance at December 31, 2019

Market risk RWA

Balance at December 31, 2018

Change related to the following items:

Regulatory VaR

Regulatory stressed VaR

Incremental risk charge

Comprehensive risk measure

Specific risk:

Non-securitizations

Securitizations

9,265 $

9,433 $

(168)

Total change in market risk RWA

82,708 $

80,052 $

2,656

Balance at December 31, 2019

Operational risk RWA

8,538 $

8,923 $

(385)

Balance at December 31, 2018

$

$

$

$

$

143

305

(6)

107

202

(37)

36

103

31

8,980 $

9,195 $

(215)

82,423 $

79,814 $

2,609

7,526

10,631

469

2,115

12,423

(753)

2,352

2,390

17,008

(844)

722

5,217

11,859

(141)

2,484

2,027

37,153 $

342,684 $

38,332

228,927

61,778 $

61,857

(1,100)

(6,947)

(6,125)

(243)

1,609

2,521

(10,285) $

51,493 $

N/A $

N/A

N/A $

(1,100)

(6,947)

(6,125)

(218)

1,609

2,521

(10,260)

51,597

110,602

(8,630)

101,972

382,496

Change in operational risk RWA

Balance at December 31, 2019

Total RWA

$

394,177 $

Regulatory VaR—VaR for regulatory capital requirements
1. The RWA for each category reflects both on- and off-balance sheet exposures, where

appropriate.

2. Amounts reflect assets not in a defined category, non-material portfolios of exposures

and unsettled transactions, as applicable.

Credit risk RWA increased in 2019 under the Standardized and
Advanced Approaches primarily due to increased exposures in
lending commitments, Derivatives and Investment securities, as
well  as  an  increase  in  Other  credit  risk  driven  by  the  Firm’s
adoption of the Leases accounting update on January 1, 2019.
RWA under the Standardized Approach also increased due to
higher  exposures  for  Securities  financing  transactions,  while
under  the  Advanced  Approach,  in  Derivatives,  increased
exposure also led to increased RWA related to CVA.

Market risk RWA decreased in 2019 under the Standardized and
Advanced Approaches, primarily due to a decrease in Stressed
VaR  driven  by  reduced  equity  and  interest  rate  risk,  and  a
decrease in the Incremental risk charge, mainly as a result of the
improved alignment of hedges and reduced exposures in credit
products.

1. Other adjustments and deductions used in the calculation of Common Equity Tier 1
capital primarily includes net after-tax DVA, the credit spread premium over risk-free
rate for derivative liabilities, defined benefit pension plan assets, after-tax gain on sale
from assets sold into securitizations, investments in our own capital instruments and
certain deferred tax assets.

December 2019 Form 10-K

52

Table of Contents
Management's Discussion and Analysis

The  decrease  in  operational  risk  RWA  under  the  Advanced
Approach  in  2019  reflects  a  continued  reduction  in  the
magnitude  and  frequency  of  internal  losses  utilized  in  the
operational risk capital model related to litigation.

requirement equal to the greater of (i) total RWA multiplied by
the sum of 6% plus the higher of the Method 1 or Method 2 G-
SIB capital surcharge applicable to the Parent Company, or (ii)
4.5% of its total leverage exposure. 

G-SIB Capital Surcharge

Required and Actual TLAC and Eligible LTD Ratios

the  G-SIB’s 

first  method 

We and other U.S. G-SIBs are subject to a risk-based capital
surcharge. A G-SIB must calculate its G-SIB capital surcharge
under two methods and use the higher of the two surcharges.
size,
considers 
The 
interconnectedness,  cross-jurisdictional  activity,  complexity
and  substitutability,  which  is  generally  consistent  with  the
methodology developed by the Basel Committee (“Method 1”).
inputs  but  replaces
The  second  method  uses  similar 
substitutability  with  the  use  of  short-term  wholesale  funding
(“Method 2”) and generally results in higher surcharges than the
first  method.  The  G-SIB  capital  surcharge  must  be  satisfied
using  Common  Equity  Tier  1  capital  and  functions  as  an
extension of the capital conservation buffer. As of December 31,
2019, our fully phased-in G-SIB surcharge is 3%. In 2018, the
requirement  was  based  on  a  phase-in  amount  of  75%  of  the
applicable  surcharge  (see  “Risk-Based  Regulatory  Capital”
herein).

Total Loss-Absorbing Capacity, Long-Term Debt and Clean
Holding Company Requirements

The Federal Reserve has established external TLAC, long-term
debt (“LTD”) and clean holding company requirements for top-
tier  BHCs  of  U.S.  G-SIBs  (“covered  BHCs”),  including  the
Parent Company. These requirements are designed to ensure that
covered BHCs will have enough loss-absorbing resources at the
point of failure to be recapitalized through the conversion of
eligible  LTD  to  equity  or  otherwise  by  imposing  losses  on
eligible LTD or other forms of TLAC where an SPOE resolution
strategy is used (see “Business—Supervision and Regulation—
Financial  Holding  Company—Resolution  and  Recovery
Planning”  and  “Risk  Factors—Legal,  Regulatory  and
Compliance Risk”).

These  TLAC  and  eligible  LTD  requirements  include  various
restrictions, such as requiring eligible LTD to: be issued by the
covered BHC and be unsecured; have a maturity of one year or
more  from  the  date  of  issuance;  and  not  contain  certain
embedded features, such as a principal or redemption amount
subject to reduction based on the performance of an asset, entity
or  index,  or  a  similar  feature.  In  addition,  the  requirements
provide permanent grandfathering for debt instruments issued
prior to December 31, 2016 that would be eligible LTD but for
having impermissible acceleration clauses or being governed by
foreign law. 

A covered BHC is also required to maintain minimum external
TLAC equal to the greater of (i) 18% of total RWA or (ii) 7.5%
of its total leverage exposure (the denominator of its SLR). In
addition,  covered  BHCs  must  meet  a  separate  external  LTD

$ in millions
External TLAC2

At December 31, 2019

Regulatory
Minimum

Required
Ratio1

Actual
Amount/
Ratio

$

196,888

External TLAC as a % of RWA

18.0%

21.5%

49.9%

External TLAC as a % of

leverage exposure

Eligible LTD3

Eligible LTD as a % of RWA

Eligible LTD as a % of leverage

exposure

7.5%

9.5%

17.0%

9.0%

4.5%

$

113,624

9.0%

28.8%

4.5%

9.8%

1. Required ratios are inclusive of applicable buffers. The final rule imposes TLAC buffer
requirements on top of both the risk-based and leverage exposure-based external
TLAC minimum requirements. The risk-based TLAC buffer is equal to the sum of 2.5%,
the covered BHC's Method 1 G-SIB surcharge and the CCyB, if any, as a percentage
of total RWA. The leverage exposure-based TLAC buffer is equal to 2% of the covered
BHC's  total  leverage  exposure.  Failure  to  maintain  the  buffers  would  result  in
restrictions  on  our  ability  to  make  capital  distributions,  including  the  payment  of
dividends and the repurchase of stock, and to pay discretionary bonuses to executive
officers.

2. External TLAC consists of Common Equity Tier 1 capital and Additional Tier 1 capital

(each excluding any noncontrolling minority interests), as well as eligible LTD.

3. Consists of TLAC-eligible LTD reduced by 50% for amounts of unpaid principal due
to be paid in more than one year but less than two years from December 31, 2019.

Furthermore, under the clean holding company requirements of
the final rule, a covered BHC is prohibited from incurring any
external debt with an original maturity of less than one year or
certain other liabilities, regardless of whether the liabilities are
fully secured or otherwise senior to eligible LTD, or entering
into certain other prohibited transactions. Certain other external
liabilities, including those with certain embedded features noted
above, are subject to a cap equal to 5% of the covered BHC’s
outstanding external TLAC amount. We are in compliance with
all relevant TLAC requirements as of December 31, 2019. 

The  Federal  Reserve  has  proposed  modifications  to  the
enhanced SLR that would also make corresponding changes to
the  calibration  of  the TLAC  leverage-based  requirements,  as
well as certain other technical changes to the TLAC rule. For a
further  discussion  of  the  enhanced  SLR,  see  “Regulatory
Developments—Proposed Modifications to the Enhanced SLR
and  to  the  SLR  Applicable  to  Our  U.S.  Bank  Subsidiaries”
herein.

Capital Plans and Stress Tests

Pursuant  to  the  Dodd-Frank  Act,  the  Federal  Reserve  has
adopted capital planning and stress test requirements for large
BHCs, including us, which form part of the Federal Reserve’s
annual CCAR framework.

We must submit an annual capital plan to the Federal Reserve,
taking  into  account  the  results  of  separate  annual  stress  tests
designed  by  us  and  the  Federal  Reserve,  so  that  the  Federal

53

December 2019 Form 10-K

 
including us, by June 30, 2020. We are required to disclose a
summary of the results of our company-run stress tests within
15 days of the date the Federal Reserve discloses the results of
the supervisory stress tests. 

Attribution of Average Common Equity According to the
Required Capital Framework

Our required capital (“Required Capital”) estimation is based
on the Required Capital framework, an internal capital adequacy
measure. Common equity attribution to the business segments
is based on capital usage calculated under the Required Capital
framework,  as  well  as  each  business  segment’s  relative
contribution to our total Required Capital.

The Required Capital framework is a risk-based and leverage
use-of-capital measure, which is compared with our regulatory
capital to ensure that we maintain an amount of going concern
capital after absorbing potential losses from stress events, where
applicable, at a point in time. The amount of capital allocated
to the business segments is generally set at the beginning of each
year and remains fixed throughout the year until the next annual
reset  unless  a  significant  business  change  occurs  (e.g.,
acquisition or disposition). We define the difference between
our total average common equity and the sum of the average
common equity amounts allocated to our business segments as
Parent  common  equity.  We  generally  hold  Parent  common
equity for prospective regulatory requirements, organic growth,
acquisitions and other capital needs.

The Required Capital framework is expected to evolve over time
in  response  to  changes  in  the  business  and  regulatory
environment,  for  example,  to  incorporate  changes  in  stress
testing  or  enhancements  to  modeling  techniques.  We  will
continue to evaluate the framework with respect to the impact
of future regulatory requirements, as appropriate.

Average Common Equity Attribution1

$ in billions

Institutional Securities

Wealth Management

Investment Management

Parent

Total

2019

2018

2017

$

40.4 $

40.8 $

18.2

2.5

11.6

16.8

2.6

9.8

$

72.7 $

70.0 $

40.2

17.2

2.4

10.0

69.8

1. The attribution of average common equity to the business segments is a non-GAAP

financial measure. See "Selected Non-GAAP Financial Information" herein. 

Table of Contents
Management's Discussion and Analysis

Reserve may assess our systems and processes that incorporate
forward-looking projections of revenues and losses to monitor
and maintain our internal capital adequacy. As banks with less
than $250 billion of total assets, our U.S. Bank Subsidiaries are
not subject to company-run stress-test regulatory requirements.

The capital plan must include a description of all planned capital
actions  over  a  nine-quarter  planning  horizon,  including  any
issuance or redemption of a debt or equity capital instrument,
any  capital  distribution  (i.e.,  payments  of  dividends  or  stock
repurchases)  and  any  similar  action  that  the  Federal  Reserve
determines could impact our consolidated capital. The capital
plan must include a discussion of how we will maintain capital
above  the  minimum  regulatory  capital  ratios,  including  any
requirements that may be phased in over the planning horizon,
and how we will serve as a source of strength to our U.S. Bank
Subsidiaries under supervisory stress scenarios. In addition, the
Federal Reserve has issued guidance setting out its heightened
expectations  for  capital  planning  practices  at  certain  large
financial institutions, including us.

The  capital  plan  rule  requires  that  large  BHCs  receive  no
objection  from  the  Federal  Reserve  before  making  a  capital
distribution. In addition, even with a capital plan that has not
been objected to, the BHC must seek the non-objection of the
Federal Reserve before making a capital distribution if, among
other reasons, the BHC would not meet its regulatory capital
requirements after making the proposed capital distribution. A
BHC’s  ability  to  make  capital  distributions  (other  than
scheduled  payments  on Additional  Tier  1  and  Tier  2  capital
instruments) is also limited if its net capital issuances are less
than the amount indicated in its capital plan. 

We  submitted  our  2019  Capital  Plan  (“Capital  Plan”)  and
company-run stress test results to the Federal Reserve on April
5,  2019.  On  June  21,  2019,  the  Federal  Reserve  published
summary results of the Dodd-Frank Act supervisory stress tests
of each large BHC, including us. On June 27, 2019, the Federal
Reserve published summary results of CCAR and announced it
did not object to our 2019 Capital Plan. Our 2019 Capital Plan
includes  the  repurchase  of  up  to  $6.0  billion  of  outstanding
common stock for the period beginning July 1, 2019 through
June 30, 2020, and an increase in our quarterly common stock
dividend to $0.35 per share from $0.30 per share, beginning with
the common stock dividend announced on July 18, 2019. We
disclosed a summary of the results of our company-run stress
tests on June 21, 2019 on our Investor Relations webpage. In
addition, we submitted the results of our mid-cycle company-
run stress test to the Federal Reserve and on October 28, 2019
disclosed a summary of the results on our Investor Relations
webpage.

For  the  2020  capital  planning  and  stress  test  cycle,  we  are
required to submit our capital plan and company-run stress test
results  to  the  Federal  Reserve  by April  5,  2020. The  Federal
Reserve is expected to publish summary results of the CCAR
and Dodd-Frank Act supervisory stress tests of each large BHC,

December 2019 Form 10-K

54

Table of Contents
Management's Discussion and Analysis

Resolution and Recovery Planning

Regulatory Developments

Pursuant to the Dodd-Frank Act, we are required to periodically
submit to the Federal Reserve and the FDIC a resolution plan
that  describes  our  strategy  for  a  rapid  and  orderly  resolution
under the U.S. Bankruptcy Code in the event of our material
financial distress or failure. We submitted our 2019 resolution
plan on June 28, 2019.

Our preferred resolution strategy is an SPOE strategy. In line
with our SPOE strategy, the Parent Company has transferred,
and has agreed to transfer on an ongoing basis, certain assets to
its wholly owned, direct subsidiary Morgan Stanley Holdings
LLC (the “Funding IHC”). In addition, the Parent Company has
entered into an amended and restated support agreement with
its  material  entities  (including  the  Funding  IHC)  and  certain
other  subsidiaries.  In  the  event  of  a  resolution  scenario,  the
Parent  Company  would  be  obligated  to  contribute  all  of  its
Contributable Assets to the material entities and/or the Funding
IHC. The Funding IHC would be obligated to provide capital
and liquidity, as applicable, to the material entities. 

The obligations of the Parent Company and the Funding IHC
under the amended and restated support agreement are in most
cases  secured  on  a  senior  basis  by  the  assets  of  the  Parent
Company  (other  than  shares  in  subsidiaries  of  the  Parent
Company and certain other assets), and the assets of the Funding
IHC. As a result, claims of our material entities, including the
Funding IHC, with respect to the secured assets, are effectively
senior to unsecured obligations of the Parent Company.

In  December  2019,  we  received  joint  feedback  on  our  2019
resolution plan from the Federal Reserve and the FDIC. The
feedback confirmed that there are no deficiencies in our 2019
resolution plan and that we had successfully addressed a prior
shortcoming identified by the agencies in the review of our 2017
resolution plan. The agencies noted one shortcoming in our 2019
resolution  plan  related  to  certain  mechanisms  intended  to
facilitate our SPOE strategy which must be addressed prior to
our next resolution plan submission in 2021.

For more information about resolution and recovery planning
requirements  and  our  activities  in  these  areas,  including  the
implications  of  such  activities  in  a  resolution  scenario,  see
“Business—Supervision  and  Regulation—Financial  Holding
Company—Resolution  and  Recovery  Planning”  and  “Risk
Factors—Legal, Regulatory and Compliance Risk.”

Proposed Rule to Amend the Covered Fund Provisions of the
Volcker Rule

The Federal financial regulatory agencies responsible for the
Volcker Rule’s implementing regulations have proposed a rule
that  would  revise  the  prohibition  on  certain  investments  by
banking entities with defined covered funds. The proposed rule
would add certain new exclusions from the definition of covered
fund, while streamlining others. It would also simplify certain
restrictions on inter-affiliate relationships with covered funds. 

Final Rule on Standardized Approach for Counterparty Credit
Risk

The U.S. banking agencies have issued a final rule to incorporate
the  standardized  approach  for  counterparty  credit  risk  (“SA-
CCR”), a new derivatives counterparty exposure methodology,
into  the  regulatory  capital  framework  and  related  regulatory
standards. SA-CCR replaces the current exposure method, on a
mandatory  basis,  in  our  and  our  U.S.  Bank  Subsidiaries’
Standardized Approach RWA, Supplementary Leverage Ratio
exposure  calculations,  and  in  all  central  counterparty  default
fund  contribution  calculations  in  the  regulatory  capital
framework. SA-CCR is available as an alternative in our and
our U.S. Bank Subsidiaries’ Advanced Approach RWA for trade
exposures, in single counterparty credit limits applicable to us,
and  in  bank  lending  limits  applicable  to  our  U.S.  Bank
Subsidiaries.  The  final  rule  requires  us  and  our  U.S.  Bank
Subsidiaries to implement SA-CCR by January 1, 2022, with
early adoption permitted.

Proposed Revisions to the Regulatory Capital Treatment for
Investments in Certain Unsecured Debt Instruments Issued
by G-SIBs

The  Federal  Reserve,  the  OCC  and  the  FDIC  have  issued  a
proposed  rule  that  would,  among  other  things,  modify  the
regulatory capital framework for Advanced Approach banking
organizations, including us. Such firms would be required to
make  certain  deductions  from  regulatory  capital  for  their
investments  in  certain  unsecured  debt  instruments  (including
eligible  LTD  in  the  TLAC  framework)  issued  by  the  Parent
Company and other G-SIBs.

Proposed Stress Buffer Requirements

The Federal Reserve issued a proposal in 2018 to integrate its
annual  capital  planning  and  stress  testing  requirements  with
existing  applicable  regulatory  capital  requirements.  The
proposal,  which  would  apply  to  certain  BHCs,  including  us,
would  introduce  a  stress  capital  buffer  and  a  stress  leverage
buffer (collectively, “Stress Buffer Requirements”) and related
changes  to  the  capital  planning  and  stress  testing  processes.
Under the proposal, Stress Buffer Requirements would apply
only with respect to Standardized Approach risk-based capital

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Management's Discussion and Analysis

requirements  and  Tier  1 
requirements. 

leverage 

regulatory  capital

Proposed Modifications to the Enhanced SLR and to the SLR
Applicable to Our U.S. Bank Subsidiaries 

The  Federal  Reserve  has  proposed  modifications  to  the
enhanced SLR that would replace the current 2% enhanced SLR
buffer applicable to U.S. G-SIBs, including us, with a leverage
buffer equal to 50% of our G-SIB capital surcharge.

Under the proposal, our enhanced SLR buffer would become
1.5%, for a total enhanced SLR requirement of 4.5%, assuming
that our current G-SIB capital surcharge remains the same when
the proposal becomes effective. 

The Federal Reserve and the OCC have also proposed to modify
the well-capitalized SLR standard applicable to our U.S. Bank
Subsidiaries. The requirement would change from the current
6% to 3% plus 50% of our current G-SIB capital surcharge, for
a total well-capitalized SLR requirement of 4.5% for our U.S.
Bank Subsidiaries, assuming that our G-SIB capital surcharge
remains the same when the proposal becomes effective.

Other Matters

U.K. Withdrawal from the E.U.

On January 31, 2020, the U.K. withdrew from the E.U. under
the terms of a withdrawal agreement between the U.K. and the
E.U. The withdrawal agreement provides for a transition period
to the end of December 2020, during which time the U.K. will
continue to apply E.U. law as if it were a member state, and U.K.
firms’ rights to provide financial services in E.U. member states
will  continue. Access  to  the  E.U.  market  after  the  transition
period remains subject to negotiation.

We have prepared the structure of our European operations for
a range of potential outcomes, including for the possibility that
U.K. financial firms’ access to E.U. markets after the transition
period is limited, and we expect to be able to continue to serve
our  clients  and  customers  under  each  of  these  potential
outcomes.

For more information on the U.K.’s withdrawal from the E.U.,
our  related  preparations  and  the  potential  impact  on  our
operations, see “Risk Factors—International Risk.” For further
information  regarding  our  exposure  to  the  U.K.,  see  also
“Quantitative and Qualitative Disclosures about Risk—Country
and Other Risks.”

Under Standardized Approach risk-based capital requirements,
the  stress  capital  buffer  would  replace  the  existing  Common
Equity Tier 1 capital conservation buffer, which is 2.5%. The
Standardized Approach  stress  capital  buffer  would  equal  the
greater of (i) the maximum decline in our Common Equity Tier
1  capital  ratio  under  the  severely  adverse  scenario  over  the
supervisory stress test measurement period plus the sum of the
ratios  of  the  dollar  amount  of  our  planned  common  stock
dividends to our projected RWA for each of the fourth through
seventh quarters of the supervisory stress test projection period
or  (ii)  2.5%.  Regulatory  capital  requirements  under  the
Standardized Approach would include the stress capital buffer,
as summarized above, as well as our Common Equity Tier 1 G-
SIB capital surcharge and any applicable Common Equity Tier
1 CCyB.

Like the stress capital buffer, the stress leverage buffer would
be  calculated  based  on  the  results  of  our  annual  supervisory
stress tests. The stress leverage buffer would equal the maximum
decline in our Tier 1 leverage ratio under the severely adverse
scenario, plus the sum of the ratios of the dollar amount of our
planned common stock dividends to our projected leverage ratio
denominator for each of the fourth through seventh quarters of
the supervisory stress test projection period. No floor would be
established for the stress leverage buffer, which would apply in
addition to the current minimum Tier 1 leverage ratio of 4%. 

The proposal would make related changes to capital planning
and stress testing processes for BHCs subject to the Stress Buffer
Requirements. In particular, for purposes of determining the size
of Stress Buffer Requirements, the proposal would include only
projected capital actions to planned common stock dividends in
the fourth through seventh quarters of the stress test projection
period and would assume that BHCs maintain a constant level
of  assets  and  RWA  throughout  the  supervisory  stress  test
projection period.

The proposal does not change regulatory capital requirements
under the Advanced Approach or the SLR, although the Federal
Reserve and the OCC have separately proposed to modify the
enhanced  SLR  requirements,  as  summarized  below.  If  the
proposal is adopted in its current form, limitations on capital
distributions  and  discretionary  bonus  payments  to  executive
officers would be determined by the most stringent limitation,
if any, as determined under Standardized Approach risk-based
capital requirements or the Tier 1 leverage ratio, inclusive of
Stress Buffer Requirements, or the Advanced Approach or SLR
or TLAC requirements, inclusive of applicable buffers. 

The  Federal  Reserve  has  not  yet  taken  action  to  finalize  or
implement Stress Buffer Requirements.

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Management's Discussion and Analysis

Planned Replacement of London Interbank Offered Rate and
Replacement or Reform of Other Interest Rates

Central banks around the world, including the Federal Reserve,
have commissioned committees and working groups of market
participants and official sector representatives to replace LIBOR
interest  rate  benchmarks
and  replace  or  reform  other 
(collectively, the “IBORs”). 

Accordingly,  we  have  established  and  are  undertaking  a
Firmwide  IBOR  transition  plan  to  promote  the  transition  to
alternative  reference  rates,  which  takes  into  account  the
considerable uncertainty regarding the availability of LIBOR
beyond 2021. Our transition plan includes a number of key steps,
including continued engagement with central bank and industry
working  groups  and  regulators  (including  participation  and
leadership  on  key  committees),  active  client  engagement,
internal  operational  readiness,  and  risk  management,  among
other things.  Our transition plan is overseen by a global steering
committee, with senior management oversight. As part of our
Firmwide 
identifying,  assessing  and
monitoring risks associated with the expected discontinuation
or unavailability of one or more of the IBORs. 

initiative,  we  are 

We are a party to a significant number of IBOR-linked contracts,
many  of  which  extend  beyond  2021,  comprising  derivatives,
securitizations and floating rate notes, loans and mortgages. Our
review  of  these  contracts  includes  assessing  the  impact  of
applicable fallbacks and any amendments that may be warranted
or appropriate. We are also taking steps to update operational
processes  (including  to  support  alternative  reference  rates),
models, and associated infrastructure, as well as planning for
certain  client  outreach  to  amend  fallbacks  or  seek  voluntary
conversions of outstanding IBOR products where practicable. 

In addition, as part of the transition to alternative reference rates,
we  are  making  markets  in  products  linked  to  such  rates,
including  SOFR,  the  alternative  rate  to  U.S.  dollar  LIBOR
selected  by  the  Alternative  Reference  Rates  Committee
convened by the Federal Reserve Board and the Federal Reserve
Bank of New York, and also began issuing debt linked to SOFR.

For  a  further  discussion  of  the  expected  replacement  of  the
IBORs and/or reform of interest rate benchmarks, and the related
risks  and  our  transition  plan,  see  “Risk  Factors—Legal,
Regulatory and Compliance Risk.”

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Quantitative and Qualitative Disclosures about Risk 

Risk Management

Overview

Risk  is  an  inherent  part  of  our  businesses  and  activities.  We
believe effective risk management is vital to the success of our
business  activities. Accordingly,  we  have  an  Enterprise  Risk
Management (“ERM”) framework to integrate the diverse roles
of risk management into a holistic enterprise structure and to
facilitate  the  incorporation  of  risk  assessment  into  decision-
making processes across the Firm.

We have policies and procedures in place to identify, measure,
monitor,  advise,  challenge  and  control  the  principal  risks
involved in the activities of the Institutional Securities, Wealth
Management and Investment Management business segments,
as  well  as  at  the  Parent  Company  level.  The  principal  risks
involved  in  our  business  activities  include  market  (including
non-trading  risks),  credit,  operational,  model,  compliance,
cybersecurity, liquidity, strategic, reputational and conduct risk.
Strategic risk is integrated into our business planning, embedded
in the evaluation of all principal risks and overseen by the Board.

The  cornerstone  of  our  risk  management  philosophy  is  the
pursuit of risk-adjusted returns through prudent risk taking that
protects  our  capital  base  and  franchise.  This  philosophy  is
implemented through the ERM framework. Five key principles
underlie 
integrity,  comprehensiveness,
independence, accountability and transparency. To help ensure
the  efficacy  of  risk  management,  which  is  an  essential
component  of  our  reputation,  senior  management  requires

this  philosophy: 

thorough  and  frequent  communication  and  the  appropriate
escalation  of  risk  matters.  The  fast-paced,  complex  and
constantly evolving nature of global financial markets requires
us  to  maintain  a  risk  management  culture  that  is  incisive,
knowledgeable  about  specialized  products  and  markets,  and
subject to ongoing review and enhancement.

Our risk appetite defines the types of risk that the Firm is willing
to accept in pursuit of our strategic objectives and business plan,
taking into account the interests of clients and fiduciary duties
to  shareholders,  as  well  as  capital  and  other  regulatory
requirements. This risk appetite is embedded in our risk culture
and linked to our short-term and long-term strategic, capital and
financial  plans,  as  well  as  compensation  programs. This  risk
appetite and the related Board-level risk limits and risk tolerance
statements are reviewed and approved by the Risk Committee
of the Board (“BRC”) and the Board on at least an annual basis.

Risk Governance Structure

Risk management at the Firm requires independent Firm-level
oversight, accountability of our business divisions, and effective
communication  of  risk  matters  across  the  Firm,  to  senior
management and ultimately to the Board. Our risk governance
structure is set forth in the following chart and also includes risk
managers, committees, and groups within and across business
segments  and  operating  legal  entities.  The  ERM  framework,
composed  of 
independent  but  complementary  entities,
facilitates efficient and comprehensive supervision of our risk
exposures and processes.

RRP—Resolution and Recovery Planning
1. Committees include the Capital Commitment Committee, Global Large Loan Committee, Equity Underwriting Committee, Leveraged Finance Underwriting Committee and Municipal

Capital Commitment Committee.

2. Committees include the Securities Risk Committee, Wealth Management Risk Committee and Investment Management Risk Committee.

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Risk Disclosures

Morgan Stanley Board of Directors

The  Board  has  oversight  of  the  ERM  framework  and  is
responsible for helping to ensure that our risks are managed in
a  sound  manner.  The  Board  has  authorized  the  committees
within the ERM framework to help facilitate our risk oversight
responsibilities.  As  set  forth  in  our  Corporate  Governance
Policies, the Board also oversees, and receives reports on, our
financial performance, strategy and business plans, as well as
our  practices  and  procedures  relating  to  reputational  and
franchise risk, and culture, values and conduct.

Risk Committee of the Board

The  BRC  assists  the  Board  in  its  oversight  of  the  ERM
framework; oversees major risk exposures of the Firm, including
market, credit, model and liquidity risk, against established risk
measurement  methodologies  and  the  steps  management  has
taken to monitor and control such exposures; oversees our risk
appetite statement, including risk limits and tolerances; reviews
capital, liquidity and funding strategy and related guidelines and
policies;  reviews  the  contingency  funding  plan  and  capital
planning process; oversees our significant risk management and
the
risk  assessment  guidelines  and  policies;  oversees 
performance of the Chief Risk Officer; reviews reports from our
Strategic Transactions Committee, CCAR Committee and RRP
Committee;  reviews  new  product  risk,  emerging  risks  and
regulatory matters; and reviews the Internal Audit Department
reports on the assessment of the risk management, liquidity and
capital functions. The BRC reports to the Board on a regular
basis and coordinates with other Board committees with respect
to oversight of risk management and risk assessment guidelines.

Audit Committee of the Board

The  Audit  Committee  of  the  Board  (“BAC”)  oversees  the
integrity of our financial statements, compliance with legal and
regulatory  requirements,  and  system  of  internal  controls;
oversees  risk  management  and  risk  assessment  guidelines  in
coordination with the Board, the BRC, and the Operations and
Technology  Committee  of  the  Board  (“BOTC”);  reviews  the
major legal and compliance risk exposures of the Firm and the
steps  management  has  taken  to  monitor  and  control  such
exposures;  selects,  determines  the  fees,  evaluates  and,  when
appropriate,  replaces  the  independent  auditor;  oversees  the
qualifications, 
independence  and  performance  of  our
independent auditor and pre-approves audit and permitted non-
audit services; oversees the performance of our Global Audit
Director;  and,  after  review,  recommends  to  the  Board  the
acceptance  and  inclusion  of  the  annual  audited  financial
statements in the Firm’s annual report on Form 10-K. The BAC
reports to the Board on a regular basis.

Operations and Technology Committee of the Board

The BOTC oversees our operations and technology strategy and
significant investments in support of such strategy; operations,

technology and operational risk, including information security,
fraud,  vendor,  data  protection,  business  continuity  and
cybersecurity  risks,  and  the  steps  management  has  taken  to
monitor and control such exposures; and risk management and
risk assessment guidelines in coordination with the Board, BRC
and  BAC,  and  policies  regarding  operations,  technology  and
operational risk. The BOTC reports to the Board on a regular
basis.

Firm Risk Committee

The  Board  has  also  authorized  the  Firm  Risk  Committee
(“FRC”), a management committee appointed and chaired by
the  Chief  Executive  Officer,  which  includes  the  most  senior
officers  of  the  Firm,  including  the  Chief  Risk  Officer,  Chief
Financial Officer and Chief Legal Officer, to help oversee the
ERM framework. The FRC’s responsibilities include: oversight
of our risk management principles, procedures and limits; the
monitoring  of  capital  levels  and  material  market,  credit,
operational, model, liquidity, legal, compliance and reputational
risk  matters,  and  other  risks,  as  appropriate;  and  the  steps
management has taken to monitor and manage such risks. The
FRC  also  establishes  and  communicates  risk  tolerance,
including aggregate Firm limits and tolerances, as appropriate.
The  Governance  Process  Review  Subcommittee  of  the  FRC
oversees governance and process issues on behalf of the FRC.
The FRC reports to the Board, the BAC, the BOTC and the BRC
through  the  Chief  Risk  Officer,  Chief  Financial  Officer  and
Chief Legal Officer.

Functional Risk and Control Committees

Functional risk and control committees and other committees
within 
facilitate  efficient  and
comprehensive supervision of our risk exposures and processes.

the  ERM 

framework 

Each business segment has a risk committee that is responsible
for helping to ensure that the business segment, as applicable,
adheres to established limits for market, credit, operational and
other  risks;  implements  risk  measurement,  monitoring,  and
management policies, procedures, controls and systems that are
consistent with the risk framework established by the FRC; and
reviews, on a periodic basis, our aggregate risk exposures, risk
exception experience, and the efficacy of our risk identification,
measurement,  monitoring  and  management  policies  and
procedures, and related controls.

Chief Risk Officer

The Chief Risk Officer, who is independent of business units,
reports to the BRC and the Chief Executive Officer. The Chief
Risk Officer oversees compliance with our risk limits; approves
exceptions  to  our  risk  limits;  independently  reviews  material
market,  credit,  liquidity,  model  and  operational  risks;  and
reviews results of risk management processes with the Board,
the BRC and the BAC, as appropriate. The Chief Risk Officer
also  coordinates  with  the  Chief  Financial  Officer  regarding

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Risk Disclosures

capital  and  liquidity  management  and  works  with  the
Compensation,  Management  Development  and  Succession
Committee of the Board to help ensure that the structure and
design  of  incentive  compensation  arrangements  do  not
encourage unnecessary and excessive risk taking.

internal  factors  or  regulatory  requests.  In  addition  to  regular
reports  to  the  BAC,  the  Global  Audit  Director,  who  reports
functionally  to  the  BAC  and  administratively  to  the  Chief
Executive Officer, periodically reports to the BRC and BOTC
on risk-related control issues.

Independent Risk Management Functions

Culture, Values and Conduct of Employees

The  risk  management  functions  (Market  Risk,  Credit  Risk,
Operational Risk, Model Risk and Liquidity Risk Management
departments) are independent of our business units and report
to  the  Chief  Risk  Officer.  These  functions  assist  senior
management and the FRC in monitoring and controlling our risk
through a number of control processes. Each function maintains
its own risk governance structure with specified individuals and
committees responsible for aspects of managing risk. Further
discussion  about  the  responsibilities  of  the  risk  management
functions may be found under “Market Risk,” “Credit Risk,”
“Operational Risk,” “Model Risk” and “Liquidity Risk” herein.

Support and Control Groups

Our  support  and  control  groups  include  the  Legal  and
Compliance  Division,  the  Finance  Division,  Technology
Division,  Operations  Division, 
the  Human  Resources
Department,  Corporate  Services  and  Firm  Resilience.  Our
support and control groups coordinate with the business segment
control  groups  to  review  the  risk  monitoring  and  risk
management policies and procedures relating to, among other
things,  controls  over  financial  reporting  and  disclosure;  each
business segment’s market, credit and operational risk profile;
liquidity risks; model risks; sales practices; reputational, legal
enforceability,  compliance,  conduct  and  regulatory  risk;  and
technological risks. Participation by the senior officers of the
Firm and business segment control groups helps ensure that risk
policies and procedures, exceptions to risk limits, new products
and  business  ventures,  and  transactions  with  risk  elements
undergo thorough review.

Internal Audit Department

The Internal Audit Department provides independent risk and
control assessment. The Internal Audit Department provides an
independent assessment of the design and effectiveness of our
control  environment  and  risk  management  processes  using  a
risk-based  audit  coverage  model  and  audit  execution
methodology developed from professional auditing standards.
The  Internal  Audit  Department  also  reviews  and  tests  our
compliance  with  internal  guidelines  set  for  risk  management
and risk monitoring, as well as external rules and regulations
governing the industry. It effects these responsibilities through
periodic  reviews  (with  specified  minimum  frequency)  of  our
processes, activities, products or information systems; targeted
reviews of specific controls and activities; pre-implementation
or initiative reviews of new or significantly changed processes,
activities,  products  or  information  systems;  and  special
investigations and retrospective reviews required as a result of

Employees  of  the  Firm  are  accountable  for  conducting
themselves in accordance with our core values: Putting Clients
First, Doing the Right Thing, Leading with Exceptional Ideas
and  Giving  Back.  We  are  committed  to  reinforcing  and
confirming adherence to our core values through our governance
framework,  tone  from  the  top,  management  oversight,  risk
management and controls, and three lines of defense structure
(business,  control  functions  such  as  Risk  Management  and
Compliance, and Internal Audit).

The Board is responsible for overseeing the Firm’s practices and
procedures relating to culture, values and conduct, as set forth
in  the  Firm’s  Corporate  Governance  Policies.  Our  Culture,
Values  and  Conduct  Committee  is  the  senior  management
committee  that  oversees  the  Firmwide  culture,  values  and
conduct program. A fundamental building block of this program
is the Firm’s Code of Conduct, which establishes standards for
employee conduct that further reinforce the Firm’s commitment
to  integrity  and  ethical  conduct. Every  new  hire  and  every
employee annually must certify to their understanding of and
adherence to the Code of Conduct. The Firm’s Global Conduct
Risk  Management  Policy  also  sets  out  a  consistent  global
framework  for  managing  Conduct  Risk  (i.e.,  the  risk  arising
from  misconduct  by  employees  or  contingent  workers)  and
Conduct Risk incidents at the Firm.

The  employee  annual  performance  review  process  includes
evaluation  of  employee  conduct  related  to  risk  management
practices  and  the  Firm’s  expectations.  We  also  have  several
mutually  reinforcing  processes  to  identify  employee  conduct
that may have an impact on employment status, current year
compensation and/or prior year compensation. For example, the
Global  Incentive  Compensation  Discretion  Policy  sets  forth
standards  for  managers  when  making  annual  compensation
decisions and specifically provides that managers must consider
whether their employees effectively managed and/or supervised
risk control practices during the performance year. Management
committees from control functions periodically meet to discuss
employees whose conduct is not in line with our expectations.
These  results  are  incorporated  into  identified  employees’
performance  reviews  and  compensation  and  promotion
decisions.

The  Firm’s  clawback  and  cancellation  provisions  apply  to
deferred  incentive  compensation  and  cover  a  broad  scope  of
employee  conduct,  including  any  act  or  omission  (including
with  respect  to  direct  supervisory  responsibilities)  that
constitutes  a  breach  of  obligation  to  the  Firm  or  causes  a
restatement of the Firm’s financial results, constitutes a violation

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Risk Disclosures

of the Firm’s global risk management principles, policies and
standards, or causes a loss of revenue associated with a position
on  which  the  employee  was  paid  and  the  employee  operated
outside of internal control policies.

Risk Limits Framework

Risk  limits  and  quantitative  metrics  provide  the  basis  for
monitoring risk taking activity and avoiding outsized risk taking.
Our  risk-taking  capacity  is  sized  through  the  Firm’s  capital
planning process where losses are estimated under the Firm’s
BHC Severely Adverse stress testing scenario. We also maintain
a comprehensive suite of risk limits and quantitative metrics to
support  and  implement  our  risk  appetite  statement.  Our  risk
limits support linkages between the overall risk appetite, which
is  reviewed  by  the  Board,  and  more  granular  risk-taking
decisions and activities.

Risk limits, once established, are reviewed and updated on at
least an annual basis, with more frequent updates as necessary.
Board-level  risk  limits  address  the  most  important  Firmwide
aggregations  of  risk,  including,  but  not  limited  to,  stressed
market,  credit  and  liquidity  risks.  Additional  risk  limits
approved by the FRC address more specific types of risk and
are bound by the higher-level Board risk limits.

Risk Management Process

In subsequent sections, we discuss our risk management policies
and procedures for our primary risks. This discussion primarily
focuses  on  our  Institutional  Securities  business  segment's
trading activities and corporate lending and related activities.
We believe that these activities generate a substantial portion of
our primary risks. These sections and the estimated amounts of
our  risk  exposure  generated  by  our  statistical  analyses  are
forward-looking  statements.  However,  the  analyses  used  to
assess such risks are not predictions of future events, and actual
results may vary significantly from such analyses due to events
in  the  markets  in  which  we  operate  and  certain  other  factors
described in the following paragraphs.

Market Risk

Market risk refers to the risk that a change in the level of one or
more market prices, rates, indices, volatilities, correlations or
other  market  factors,  such  as  market  liquidity,  will  result  in
losses for a position or portfolio. Generally, we incur market
risk  as  a  result  of  trading,  investing  and  client  facilitation
activities, principally within the Institutional Securities business
segment where the substantial majority of our VaR for market
risk exposures is generated. In addition, we incur non-trading
market  risk  within  the  Wealth  Management  and  Investment
Management  business  segments.  The  Wealth  Management
business segment primarily incurs non-trading market risk from
lending  and  deposit-taking  activities.  The 
Investment
Management  business  segment  primarily  incurs  non-trading

market  risk  from  capital  investments  in  alternative  and  other
funds.

Market risk includes non-trading interest rate risk. Non-trading
interest rate risk in the banking book (amounts classified for
regulatory  capital  purposes  under  the  banking  book  regime)
refers to the exposure that a change in interest rates will result
in prospective earnings changes for assets and liabilities in the
banking book.

Sound market risk management is an integral part of our culture.
The various business units and trading desks are responsible for
ensuring  that  market  risk  exposures  are  well-managed  and
prudent.  The  control  groups  help  ensure  that  these  risks  are
measured and closely monitored and are made transparent to
senior management. The Market Risk Department is responsible
for ensuring transparency of material market risks, monitoring
compliance  with  established 
limits  and  escalating  risk
concentrations to appropriate senior management.

To execute these responsibilities, the Market Risk Department
monitors  our  risk  against  limits  on  aggregate  risk  exposures,
performs  a  variety  of  risk  analyses,  routinely  reports  risk
summaries,  and  maintains  our  VaR  and  scenario  analysis
systems.  Market  risk  is  also  monitored  through  various
measures:  by  use  of  statistics  (including  VaR  and  related
analytical measures); by measures of position sensitivity; and
through routine stress testing, which measures the impact on the
value  of  existing  portfolios  of  specified  changes  in  market
factors and scenarios designed by the Market Risk Department
in  collaboration  with  the  business  units.  The  material  risks
identified  by  these  processes  are  summarized  in  reports
produced by the Market Risk Department that are circulated to
and discussed with senior management, the FRC, the BRC and
the Board.

Trading Risks

Primary  Market  Risk  Exposures  and  Market  Risk
Management

During 2019, we had exposures to a wide range of interest rates,
equity prices, foreign exchange rates and commodity prices—
and the associated implied volatilities and spreads—related to
the global markets in which we conduct our trading activities.

We are exposed to interest rate and credit spread risk as a result
of our market-making activities and other trading in interest rate-
sensitive financial instruments (e.g., risk arising from changes
in the level or implied volatility of interest rates, the timing of
mortgage prepayments, the shape of the yield curve and credit
spreads). The activities from which those exposures arise and
the markets in which we are active include, but are not limited
to,  the  following:  derivatives,  and  corporate  and  government
debt across both developed and emerging markets and asset-
backed debt, including mortgage-related securities.

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December 2019 Form 10-K

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Risk Disclosures

We are exposed to equity price and implied volatility risk as a
result of making markets in equity securities and derivatives and
maintaining other positions, including positions in non-public
entities. Positions in non-public entities may include, but are not
limited to, exposures to private equity, venture capital, private
partnerships, real estate funds and other funds. Such positions
are less liquid, have longer investment horizons and are more
difficult to hedge than listed equities.

We are exposed to foreign exchange rate and implied volatility
risk  as  a  result  of  making  markets  in  foreign  currencies  and
foreign  currency  derivatives,  from  maintaining  foreign
exchange  positions  and  from  holding  non-U.S.  dollar-
denominated financial instruments.

We are exposed to commodity price and implied volatility risk
as a result of market-making activities in commodity products
related  primarily  to  electricity,  natural  gas,  oil  and  precious
metals.  Commodity  exposures  are  subject  to  periods  of  high
price  volatility  as  a  result  of  changes  in  supply  and  demand.
These changes can be caused by weather conditions; physical
production and transportation; or geopolitical and other events
that affect the available supply and level of demand for these
commodities.

We manage our trading positions by employing a variety of risk
mitigation strategies. These strategies include diversification of
risk exposures and hedging. Hedging activities consist of the
purchase or sale of positions in related securities and financial
instruments,  including  a  variety  of  derivative  products  (e.g.,
futures, forwards, swaps and options). Hedging activities may
not always provide effective mitigation against trading losses
due to differences in the terms, specific characteristics or other
basis risks that may exist between the hedge instrument and the
risk exposure that is being hedged.

We manage the market risk associated with our trading activities
on a Firmwide basis, on a worldwide trading division level and
on  an  individual  product  basis.  We  manage  and  monitor  our
market risk exposures in such a way as to maintain a portfolio
that we believe is well-diversified in the aggregate with respect
to  market  risk  factors  and  that  reflects  our  aggregate  risk
tolerance as established by our senior management.

Aggregate market risk limits have been approved for the Firm
across all divisions worldwide. Additional market risk limits are
assigned  to  trading  desks  and,  as  appropriate,  products  and
regions. Trading  division  risk  managers,  desk  risk  managers,
traders and the Market Risk Department monitor market risk
measures against limits in accordance with policies set by our
senior management.

Value-at-Risk

The statistical technique known as VaR is one of the tools we
use to measure, monitor and review the market risk exposures
of  our  trading  portfolios.  The  Market  Risk  Department

December 2019 Form 10-K

62

calculates  and  distributes  daily  VaR-based  risk  measures  to
various levels of management.

Beginning July 1, 2019, we estimate VaR using a model based
on a one-year equal weighted historical simulation for general
market risk factors and name-specific risk in corporate shares
and related derivatives, and Monte Carlo simulation for name-
specific risk in bonds, loans and related derivatives. The model
constructs  a  distribution  of  hypothetical  daily  changes  in  the
value of trading portfolios based on historical observation of
daily changes in key market indices or other market risk factors,
and information on the sensitivity of the portfolio values to these
market risk factor changes.

Prior to July 1, 2019, our VaR model used four years of historical
data  with  a  volatility  adjustment  to  reflect  current  market
conditions. 

VaR  for  risk  management  purposes  (“Management  VaR”)  is
computed  at  a  95%  level  of  confidence  over  a  one-day  time
horizon, which is a useful indicator of possible trading losses
resulting from adverse daily market moves. The 95%/one-day
VaR corresponds to the unrealized loss in portfolio value that,
based on historically observed market risk factor movements,
would have been exceeded with a frequency of 5%, or five times
in every 100 trading days, if the portfolio were held constant for
one day.

Our VaR  model  generally  takes  into  account  linear  and  non-
linear exposures to equity and commodity price risk, interest
rate  risk,  credit  spread  risk  and  foreign  exchange  rates.  The
model  also  takes  into  account  linear  exposures  to  implied
volatility risks for all asset classes and non-linear exposures to
implied  volatility  risks  for  equity,  commodity  and  foreign
exchange  referenced  products.  The  VaR  model  also  captures
certain implied correlation risks associated with portfolio credit
derivatives, as well as certain basis risks (e.g., corporate debt
and related credit derivatives).

We use VaR as one of a range of risk management tools. Among
their  benefits, VaR  models  permit  estimation  of  a  portfolio’s
aggregate market risk exposure, incorporating a range of varied
market risks and portfolio assets. One key element of the VaR
model  is  that  it  reflects  risk  reduction  due  to  portfolio
diversification or hedging activities. However, VaR has various
limitations, which include, but are not limited to: use of historical
changes  in  market  risk  factors,  which  may  not  be  accurate
predictors  of  future  market  conditions  and  may  not  fully
incorporate the risk of extreme market events that are outsized
relative  to  observed  historical  market  behavior  or  reflect  the
historical  distribution  of  results  beyond  the  95%  confidence
interval; and reporting of losses in a single day, which does not
reflect the risk of positions that cannot be liquidated or hedged
in  one  day.  A  small  proportion  of  market  risk  generated  by
trading positions is not included in VaR.

Table of Contents
Risk Disclosures

The modeling of the risk characteristics of some positions relies
on  approximations  that,  under  certain  circumstances,  could
produce  significantly  different  results  from  those  produced
using more precise measures. VaR is most appropriate as a risk
measure  for  trading  positions  in  liquid  financial  markets  and
will understate the risk associated with severe events, such as
periods of extreme illiquidity. We are aware of these and other
limitations and, therefore, use VaR as only one component in
our  risk  management  oversight  process.  This  process  also
incorporates stress testing and scenario analyses and extensive
risk monitoring, analysis and control at the trading desk, division
and Firm levels.

Our VaR model evolves over time in response to changes in the
composition  of  trading  portfolios  and  to  improvements  in
modeling 
techniques  and  systems  capabilities.  We  are
committed  to  continuous  review  and  enhancement  of  VaR
methodologies  and  assumptions  in  order  to  capture  evolving
risks associated with changes in market structure and dynamics.
As  part  of  our  regular  process  improvements,  additional
systematic  and  name-specific  risk  factors  may  be  added  to
improve the VaR model’s ability to more accurately estimate
risks to specific asset classes or industry sectors.

Since  the  reported  VaR  statistics  are  estimates  based  on
historical data, VaR should not be viewed as predictive of our
future  revenues  or  financial  performance  or  of  our  ability  to
monitor and manage risk. There can be no assurance that our
actual losses on a particular day will not exceed the VaR amounts
indicated in the following tables and paragraphs or that such
losses will not occur more than five times in 100 trading days
for a 95%/one-day VaR. VaR does not predict the magnitude of
losses that, should they occur, may be significantly greater than
the VaR amount.

VaR statistics are not readily comparable across firms because
of  differences  in  the  firms’  portfolios,  modeling  assumptions
and methodologies. These differences can result in materially
different VaR estimates across firms for similar portfolios. The
impact of such differences varies depending on the factor history
assumptions,  the  frequency  with  which  the  factor  history  is
updated and the confidence level. As a result, VaR statistics are
more useful when interpreted as indicators of trends in a firm’s
risk  profile  rather  than  as  an  absolute  measure  of  risk  to  be
compared across firms.

24

11

6

10

30

13

high and low basis. To further enhance the transparency of the
traded market risk, the Credit Portfolio VaR has been disclosed
as a separate category from the Primary Risk Categories. The
Credit Portfolio includes counterparty CVA and related hedges,
as  well  as  loans  that  are  carried  at  fair  value  and  associated
hedges.

95%/One-Day Management VaR 

$ in millions

2019

Period
End

Average

High2

Low2

Interest rate and credit spread

$

26 $

29 $

43 $

Equity price

Foreign exchange rate

Commodity price
Less: Diversification benefit1

11

10

10

15

13

14

22

20

22

(27)

(35)

N/A

 N/A

Primary Risk Categories

$

30 $

36 $

47 $

Credit Portfolio
Less: Diversification benefit1

15

(10)

16

(11)

19

 N/A

 N/A

Total Management VaR

$

35 $

41 $

51 $

33

$ in millions

20183

Period
End

Average

High2

Low2

Interest rate and credit spread

$

44 $

34 $

53 $

25

Equity price

Foreign exchange rate

Commodity price
Less: Diversification benefit1

12

11

13

14

10

10

18

16

18

9

6

6

(27)

(29)

N/A

N/A

Primary Risk Categories

$

53 $

39 $

64 $

Credit Portfolio
Less: Diversification benefit1

14

(12)

11

(8)

16

N/A

Total Management VaR

$

55 $

42 $

62 $

31

8

N/A

34

1. Diversification benefit equals the difference between the total Management VaR and
the sum of the component VaRs. This benefit arises because the simulated one-day
losses  for  each  of  the  components  occur  on  different  days;  similar  diversification
benefits also are taken into account within each component.

2. The high and low VaR values for the total Management VaR and each of the component
VaRs might have occurred on different days during the quarter, and therefore, the
diversification benefit is not an applicable measure.

3. 2018 amounts have been revised to present the results of the new VaR model, in
conformance with the 2019 presentation. The difference between the VaR measures
produced by the new and old models was not significant. 

Average total Management VaR remained relatively unchanged
from  2018. Average  Management  VaR  for  the  Primary  Risk
Categories  decreased  from  2018  as  reduced  interest  rate  and
credit  spread  risk  was  offset  by  increased  Commodity  and
Foreign Exchange risk within the Fixed Income Division.

Our regulators have approved the same VaR model we use for
risk management purposes for use in regulatory calculations.

Distribution of VaR Statistics and Net Revenues

The  portfolio  of  positions  used  for  Management  VaR  differs
from that used for Regulatory VaR. Management VaR contains
certain  positions  that  are  excluded  from  Regulatory  VaR.
Examples include counterparty CVA and related hedges, as well
as loans that are carried at fair value and associated hedges.

The  following  table  presents  the  Management  VaR  for  the
Trading portfolio, on a period-end, annual average, and annual

One method of evaluating the reasonableness of our VaR model
as  a  measure  of  our  potential  volatility  of  net  revenues  is  to
compare  VaR  with  corresponding  actual  trading  revenues.
Assuming  no  intraday  trading,  for  a  95%/one-day  VaR,  the
expected number of times that trading losses should exceed VaR
during the year is 13, and, in general, if trading losses were to
exceed VaR more than 21 times in a year, the adequacy of the
VaR model would be questioned.

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December 2019 Form 10-K

Table of Contents
Risk Disclosures

We evaluate the reasonableness of our VaR model by comparing
the potential declines in portfolio values generated by the model
with corresponding actual trading results for the Firm, as well
as individual business units. For days where losses exceed the
VaR  statistic,  we  examine  the  drivers  of  trading  losses  to
evaluate the VaR model’s accuracy relative to realized trading
results. There  were  no  days  in  2019  on  which  trading  losses
exceeded VaR.

Daily 95%/One-Day Total Management VaR for 2019
($ in millions)

Daily Net Trading Revenues for 2019
($ in millions)

The  previous  histogram  shows  the  distribution  of  daily  net
trading revenues for 2019. Daily net trading revenues include

December 2019 Form 10-K

64

profits and losses from Interest rate and credit spread, Equity
price,  Foreign  exchange  rate,  Commodity  price,  and  Credit
Portfolio positions and intraday trading activities for our trading
businesses.  Certain  items  such  as  fees,  commissions  and  net
interest income are excluded from daily net trading revenues
and  the  VaR  model.  Revenues  required  for  Regulatory  VaR
backtesting further exclude intraday trading.

Non-Trading Risks

that  sensitivity  analysis 

is  an  appropriate
We  believe 
representation  of  our  non-trading  risks.  The  following
sensitivity  analyses  cover  substantially  all  of  the  non-trading
risk in our portfolio.

Credit Spread Risk Sensitivity1

$ in millions

Derivatives
Funding liabilities2

At
December 31,
2019

At
December 31,
2018

$

6 $

42

6

34

1. Amounts represent the potential gain for each 1 bps widening of our credit spread.
2. Relates to Borrowings carried at fair value.

Credit  spread  risk  sensitivity  for  funding  liabilities  as  of
December 31, 2019 has increased compared with December 31,
2018,  primarily  as  a  result  of  new  issuances  of  Borrowings
carried  at  fair  value  in  the  Fixed  Income  Division  of  the
Institutional Securities business segment.

U.S. Bank Subsidiaries’ Net Interest Income Sensitivity Analysis

$ in millions

Basis point change

+100

-100

At
December 31,
2019

At
December 31,
2018

$

151 $

(642)

182

(428)

The previous table presents an analysis of selected instantaneous
upward  and  downward  parallel  interest  rate  shocks  on  net
interest  income  over  the  next  12  months  for  our  U.S.  Bank
Subsidiaries. These shocks are applied to our 12-month forecast,
which incorporates market expectations of interest rates and our
forecasted business activity.

We do not manage to any single rate scenario but rather manage
net interest income in our U.S. Bank Subsidiaries to optimize
across a range of possible outcomes, including non-parallel rate
change scenarios. The sensitivity analysis assumes that we take
no action in response to these scenarios, assumes there are no
changes in other macroeconomic variables normally correlated
with  changes  in  interest  rates,  and  includes  subjective
assumptions regarding customer and market re-pricing behavior
and  other  factors.  The  change  in  sensitivity  to  interest  rates
between  December 31,  2019  and  December 31,  2018  is
primarily driven by lower market rates and changes in our asset-
liability profile.

Table of Contents
Risk Disclosures

Investments Sensitivity, Including Related Performance Fees

$ in millions

Investments related to Investment 

Management activities

Other investments:

MUMSS

Other Firm investments

Loss from 10% Decline

At
December 31,
2019

At
December 31,
2018

$

367 $

169

195

298

165

179

MUMSS—Mitsubishi UFJ Morgan Stanley Securities Co., Ltd.

We  have  exposure  to  public  and  private  companies  through
direct investments, as well as through funds that invest in these
assets. These investments are predominantly equity positions
with long investment horizons, a portion of which is for business
facilitation  purposes.  The  market  risk  related  to  these
investments is measured by estimating the potential reduction
in net income associated with a 10% decline in investment values
and related impact on performance-based fees, as applicable.
The  change  in  investments  sensitivity  related  to  Investment
Management  activities  between  December 31,  2019  and
December 31,  2018  is  primarily  driven  by  higher  unrealized
carried interest and investment gains, primarily from an Asia
private equity fund.

Equity Market Sensitivity

In  the  Wealth  Management  and  Investment  Management
business segments, certain fee-based revenue streams are driven
by  the  value  of  clients’  equity  holdings. The  overall  level  of
revenues for these streams also depends on multiple additional
factors that include, but are not limited to, the level and duration
of  the  equity  market  increase  or  decline,  price  volatility,  the
geographic  and  industry  mix  of  client  assets,  the  rate  and
magnitude  of  client  investments  and  redemptions,  and  the
impact of such market increase or decline and price volatility
on client behavior. Therefore, overall revenues do not correlate
completely with changes in the equity markets.

Credit Risk

Credit risk refers to the risk of loss arising when a borrower,
counterparty or issuer does not meet its financial obligations to
us. We primarily incur credit risk to institutions and individuals
through  our  Institutional  Securities  and  Wealth  Management
business segments. 

We  incur  credit  risk  in  our  Institutional  Securities  business
segment through a variety of activities, including, but not limited
to, the following:

• extending  credit  to  clients  through  loans  and  lending

commitments;

• entering into swap or other derivative contracts under which
counterparties may have obligations to make payments to us;

• providing  short-  or  long-term  funding  that  is  secured  by
physical or financial collateral whose value may at times be
insufficient to fully cover the repayment amount;

• posting margin and/or collateral to clearinghouses, clearing
agencies,  exchanges,  banks,  securities  firms  and  other
financial counterparties;

• placing  funds  on  deposit  at  other  financial  institutions  to

support our clearing and settlement obligations; and

• investing or trading in securities and loan pools, whereby the
value  of  these  assets  may  fluctuate  based  on  realized  or
expected defaults on the underlying obligations or loans.

We  incur  credit  risk  in  our  Wealth  Management  business
segment, primarily through lending to individuals and entities,
including, but not limited to, the following:

• margin loans collateralized by securities;

• securities-based  lending  and  other  forms  of  secured  loans,

including tailored lending, to high net worth clients;

• single-family residential mortgage loans in conforming, non-
conforming  or  HELOC  form,  primarily  to  existing  Wealth
Management clients; and

• employee  loans  granted  primarily  to  recruit  certain Wealth

Management  representatives.

Monitoring and Control

In  order  to  help  protect  us  from  losses,  the  Credit  Risk
Management  Department  (“CRM”)  establishes  Firmwide
practices  to  evaluate,  monitor  and  control  credit  risk  at  the
transaction,  obligor  and  portfolio  levels.  CRM  approves
extensions  of  credit,  evaluates  the  creditworthiness  of  the
counterparties and borrowers on a regular basis, and helps ensure
that  credit  exposure  is  actively  monitored  and  managed. The
evaluation  of  counterparties  and  borrowers  includes  an
assessment of the probability that an obligor will default on its
financial  obligations  and  any  losses  that  may  occur  when  an
obligor  defaults.  In  addition,  credit  risk  exposure  is  actively
managed by credit professionals and committees within CRM
and  through  various  risk  committees,  whose  membership
includes individuals from CRM. A comprehensive and global
Credit Limits Framework is utilized to manage credit risk levels
across  the  Firm.  The  Credit  Limits  Framework  is  calibrated
within our risk tolerance and includes single-name limits and
portfolio concentration limits by country, industry and product
type.

CRM  helps  ensure  timely  and  transparent  communication  of
material  credit  risks,  compliance  with  established  limits  and
escalation  of  risk  concentrations 
to  appropriate  senior
management. CRM also works closely with the Market Risk
Department  and  applicable  business  units  to  monitor  risk

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December 2019 Form 10-K

Table of Contents
Risk Disclosures

exposures and to perform stress tests to identify, analyze and
control  credit  risk  concentrations  arising  from  lending  and
trading  activities. The  stress  tests  shock  market  factors  (e.g.,
interest rates, commodity prices, credit spreads), risk parameters
(e.g., default probabilities and loss given default), recovery rates
and expected losses in order to assess the impact of stresses on
exposures, profit and loss, and our capital position. Stress tests
are conducted in accordance with our established policies and
procedures.

Credit Evaluation

The evaluation of corporate and institutional counterparties and
borrowers  includes  assigning  credit  ratings,  which  reflect  an
assessment of an obligor’s probability of default and loss given
default. Credit evaluations typically involve the assessment of
financial statements; leverage; liquidity; capital strength; asset
composition and quality; market capitalization; access to capital
markets; adequacy of collateral, if applicable; and, in the case
of  certain  loans,  cash  flow  projections  and  debt  service
requirements.  CRM  also  evaluates  strategy,  market  position,
industry  dynamics,  management  and  other  factors  that  could
affect the obligor’s risk profile. Additionally, CRM evaluates
the relative position of our exposure in the borrower’s capital
structure  and  relative  recovery  prospects,  as  well  as  other
structural elements of the particular transaction.

The evaluation of consumer borrowers is tailored to the specific
type of lending. Securities-based loans are evaluated based on
factors that include, but are not limited to, the amount of the
loan and the amount, quality, diversification, price volatility and
liquidity of the collateral. The underwriting of residential real
estate loans includes, but is not limited to, review of the obligor’s
debt-to-income  ratio,  net  worth,  liquidity,  collateral,  loan-to-
value ratio and industry standard credit scoring models (e.g.,
FICO scores). Subsequent credit monitoring for individual loans
is  performed  at  the  portfolio  level,  and  collateral  values  are
monitored on an ongoing basis.

Credit  risk  metrics  assigned  to  our  borrowers  during  the
evaluation process are incorporated into CRM maintenance of
the allowance for loan losses for loans held for investment. Such
allowance serves as a reserve for probable inherent losses, as
well as probable losses related to loans identified as impaired.
For more information on the allowance for loan losses, see Notes
2 and 8 to the financial statements.

Risk Mitigation

We may seek to mitigate credit risk from our lending and trading
activities  in  multiple  ways,  including  collateral  provisions,
guarantees  and  hedges.  At  the  transaction  level,  we  seek  to
mitigate risk through management of key risk elements such as
size,  tenor,  financial  covenants,  seniority  and  collateral.  We
actively hedge our lending and derivatives exposures. Hedging
activities consist of the purchase or sale of positions in related
securities  and  financial  instruments,  including  a  variety  of
derivative products (e.g., futures, forwards, swaps, and options).
Additionally, we may sell, assign or syndicate loans and lending
commitments to other financial institutions in the primary and
secondary loan markets.

In  connection  with  our  derivatives  trading  activities,  we
generally  enter  into  master  netting  agreements  and  collateral
arrangements with counterparties. These agreements provide us
with  the  ability  to  demand  collateral,  as  well  as  to  liquidate
collateral and offset receivables and payables covered under the
same master agreement in the event of a counterparty default.
A  collateral  management  group  monitors  collateral  levels
against  requirements  and  oversees  the  administration  of  the
collateral function. See Note 7 to the financial statements for
additional information about our collateralized transactions.

Loans and Lending Commitments

$ in millions

Corporate

Consumer

Residential real estate

Commercial real estate

Loans held for investment,

gross of allowance

Allowance for loan losses

Loans held for investment, net

of allowance

Corporate

Residential real estate

Commercial real estate

Loans held for sale

Corporate

Residential real estate

Commercial real estate

Loans held at fair value

Total loans
Lending commitments2

Total loans and lending

commitments2

At December 31, 2019

IS

WM

IM1

Total

$ 30,431 $ 18,320 $

5 $ 48,756

— 31,610

— 30,184

7,859

—

38,290

80,114

(297)

(52)

37,993

80,062

10,515

—

2,049

12,564

7,785

1,192

2,098

11,075

—

13

—

13

—

—

—

—

61,632

80,075

—

—

—

5

—

5

—

—

—

—

251

—

—

251

256

31,610

30,184

7,859

118,409

(349)

118,060

10,515

13

2,049

12,577

8,036

1,192

2,098

11,326

141,963

106,886

13,161

21

120,068

$ 168,518 $ 93,236 $

277 $ 262,031

December 2019 Form 10-K

66

Table of Contents
Risk Disclosures

$ in millions

Corporate

Consumer

Residential real estate
Commercial real estate3

Loans held for investment,

gross of allowance

Allowance for loan losses

Loans held for investment, net

of allowance

Corporate

Residential real estate
Commercial real estate3

Loans held for sale

Corporate

Residential real estate
Commercial real estate3

Loans held at fair value

Total loans
Lending commitments2

Total loans and lending

commitments2

At December 31, 2018

IS

WM

IM1

Total

$ 20,020 $ 16,884 $

5 $ 36,909

— 27,868

— 27,466

7,810

—

27,830

72,218

(193)

(45)

27,637

72,173

13,886

1

1,856

15,743

9,150

1,153

601

10,904

—

21

—

21

—

—

—

—

54,284

72,194

—

—

—

5

—

5

—

—

—

—

21

—

—

21

26

27,868

27,466

7,810

100,053

(238)

99,815

13,886

22

1,856

15,764

9,171

1,153

601

10,925

126,504

loans  and 

Credit  exposure  arising  from  our 
lending
commitments is measured in accordance with our internal risk
management standards. Risk factors considered in determining
the aggregate allowance for loan and commitment losses include
the  borrower’s  financial  strength,  industry,  facility  structure,
loan-to-value ratio, debt service ratio, collateral and covenants.
Qualitative  and  environmental  factors  such  as  economic  and
business  conditions,  nature  and  volume  of  the  portfolio  and
lending terms, and volume and severity of past due loans may
also be considered.

The  aggregate  allowance  for  loans  and  lending  commitment
losses increased during 2019, primarily within the Institutional
Securities  business  segment  due 
lending
commitment growth, deterioration of select credits and certain
environmental  factors.  See  Notes  8  and  13  to  the  financial
statements for further information.

loan  and 

to 

Status of Loans Held for Investment

95,065

10,663

— 105,728

$ 149,349 $ 82,857 $

26 $ 232,232

Current
Nonaccrual1

At December 31, 2019

At December 31, 2018

IS

WM

IS

WM

99.0%

1.0%

99.9%

0.1%

99.8%

0.2%

99.9%

0.1%

1. Investment Management business segment loans are related to certain of our activities
as an investment advisor and manager. At December 31, 2019, loans held at fair value
are the result of the consolidation of a CLO, managed by Investment Management,
composed primarily of senior secured corporate loans.

2. Lending commitments represent the notional amount of legally binding obligations to
provide funding to clients for lending transactions. Since commitments associated with
these business activities may expire unused or may not be utilized to full capacity,
they do not necessarily reflect the actual future cash funding requirements.

3. Beginning in 2019, loans previously referred to as Wholesale real estate are referred

to as Commercial real estate.

We  provide  loans  and  lending  commitments  to  a  variety  of
customers, from large corporate and institutional clients to high
net  worth  individuals.  In  addition,  we  purchase  loans  in  the
secondary market. Loans and lending commitments are either
held for investment, held for sale or carried at fair value. For
more information on these loan classifications, see Note 2 to the
financial  statements.  In  2019,  total  loans  and  lending
commitments increased by approximately $30 billion, primarily
in Corporate within the Institutional Securities business segment
due to growth in secured lending facilities and increases in event-
driven lending commitments. Also contributing to the increase
was growth in Consumer securities-based lending, Residential
real  estate  loans  and  tailored  lending  within  the  Wealth
Management business segment.

See Notes 3, 4, 8 and 13 to the financial statements for further
information.

Allowance  for  Loans  and  Lending  Commitments  Held  for
Investment

$ in millions

Loans

Lending commitments

Total allowance for loans and 

lending commitments

At
December 31,
2019

At
December 31,
2018

$

$

349 $

241

590 $

238

203

441

1. These loans are on nonaccrual status because the loans were past due for a period

of 90 days or more or payment of principal or interest was in doubt.

Institutional Securities Loans and Lending Commitments1 

$ in millions

Loans

AA

A

BBB

NIG
Unrated2
Total loans

Lending commitments

AAA

AA

A

BBB

NIG
Unrated2
Total lending

commitments

At December 31, 2019

Contractual Years to Maturity

Less than 1

1-3

3-5

Over 5

Total

$

7 $

50 $

— $

5 $

62

955

2,297

923

5,589

516

3,592

13,051

16,824

12,047

117

82

131

16,427

23,468

16,286

—

2,838

6,461

7,548

4,657

—

50

908

7,287

13,780

10,351

9

—

2,509

9,371

20,560

15,395

107

277

949

2,592

1,628

5,451

—

—

298

753

3,997

7

2,671

12,427

44,514

1,958

61,632

50

6,255

23,417

42,641

34,400

123

21,504

32,385

47,942

5,055

106,886

Total exposure

$

37,931 $ 55,853 $ 64,228 $10,506 $ 168,518

67

December 2019 Form 10-K

Table of Contents
Risk Disclosures

At December 31, 2018

Contractual Years to Maturity

Less than 1

1-3

3-5

Over 5

Total

$

7 $

430 $

— $

19 $

456

565

3,775

7,151

88

1,580

4,697

12,882

95

858

4,251

9,313

160

11,586

19,684

14,582

90

2,491

2,892

2,993

1,681

8

75

1,177

6,006

—

2,863

9,895

11,825

19,461

10,604

16,075

5,751

—

38

—

267

495

5,889

1,762

8,432

—

—

502

638

3,270

13,218

35,235

2,105

54,284

165

6,531

19,295

34,917

34,111

46

$ in millions

Loans

AA

A

BBB

NIG
Unrated2

Total loans

Lending commitments

AAA

AA

A

BBB

NIG
Unrated2

Total lending

commitments

Total exposure

$

21,741 $ 49,371 $ 62,914 $15,323 $ 149,349

10,155

29,687

48,332

6,891

95,065

collateralized loans and lending commitments generally provide
for overcollateralization. Credit risk with respect to these loans
and lending commitments arises from the failure of a borrower
to perform according to the terms of the loan agreement and/or
a decline in the underlying collateral value. The Firm monitors
collateral levels against the requirements of lending agreements.
In addition, we participate in securitization activities whereby
we transfer certain loans, primarily Commercial real estate, to
an SPE, which in turn securitizes the loans. See Note 14 to the
financial  statements  for  information  about  our  securitization
activities.

Institutional Securities Corporate Loans1

$ in millions

Corporate relationship and
event-driven lending2
Secured lending facilities3
Securities-based lending and other4
Total Corporate

At
December 31,
2019

At
December 31,
2018

$

$

11,638 $

29,654

7,439

48,731 $

13,317

21,408

8,331

43,056

NIG–Non-investment grade
1. Counterparty credit ratings are internally determined by CRM.
2. Unrated  loans  and  lending  commitments  are  primarily  trading  positions  that  are
measured at fair value and risk managed as a component of market risk. For a further
discussion of our market risk, see “Quantitative and Qualitative Disclosures about Risk
—Market Risk” herein.

Institutional  Securities  Loans  and  Lending  Commitments  by
Industry

1. Amounts include loans held for investment, gross of allowance, loans held for sale
and loans measured at fair value. Loans at fair value are included in Trading assets
in the balance sheets.

2. Relationship and event-driven loans typically consist of revolving lines of credit, term
loans  and  bridge  loans.  For  additional  information  on  event-driven  loans,  see
“Institutional Securities Event-Driven Loans and Lending Commitments” herein.
3. Secured  lending  facilities  includes  loans  provided  to  clients  to  warehouse  loans

secured by underlying real estate and other assets.

4. Securities-based lending and other includes financing extended to sales and trading

customers and corporate loans purchased in the secondary market.

$ in millions

Financials

Real estate

Healthcare

Industrials

Communications services

Utilities

Consumer staples

Consumer discretionary

Energy

Information technology

Materials

Insurance

Other

Total

At
December 31,
2019

At
December 31,
2018

Institutional  Securities  Event-Driven  Loans  and  Lending
Commitments

$

40,992 $

28,348

14,113

13,136

12,165

9,905

9,724

9,589

9,461

9,201

5,577

3,755

2,552

32,655

24,133

10,158

13,701

11,244

9,856

7,921

8,314

9,847

9,896

5,969

3,744

1,911

$

168,518 $

149,349

At December 31, 2019

Contractual Years to Maturity

$ in millions

Loans

Lending commitments

Total loans and lending

commitments

Less than 1

1-3

3-5

Over 5

Total

$

$

1,194 $ 1,024 $

839 $

390 $ 3,447

7,921

5,012

2,285

3,090

18,308

9,115 $ 6,036 $ 3,124 $ 3,480 $21,755

At December 31, 2018

Contractual Years to Maturity

$ in millions

Loans

Lending commitments

Total loans and lending

commitments

Less than 1

1-3

3-5

Over 5

Total

$

$

2,582 $

287 $

656 $ 1,618 $ 5,143

1,506

2,456

2,877

3,658

10,497

4,088 $ 2,743 $ 3,533 $ 5,276 $15,640

The principal Institutional Securities business segment lending
activities include Corporate and Commercial real estate loans.
Our loans and lending commitments may have varying terms;
may be senior or subordinated; may be secured or unsecured;
are generally contingent upon representations, warranties and
contractual conditions applicable to the borrower; and may be
syndicated, traded or hedged by us. 

Event-driven loans and lending commitments, which comprise
a  portion  of  corporate  loans  and  lending  commitments,  are
associated  with  a  particular  event  or  transaction,  such  as  to
support  client  merger,  acquisition,  recapitalization  or  project
finance  activities.  Balances  may  fluctuate  as  such  lending  is
related to transactions that vary in timing and size from period
to period. 

We also extend short- and long-term secured lending facilities
with various types of collateral, including residential real estate,
commercial  real  estate,  corporate  and  financial  assets. These

December 2019 Form 10-K

68

    
Table of Contents
Risk Disclosures

Wealth Management Loans and Lending Commitments

At December 31, 2019

Contractual Years to Maturity

$ in millions

Less than 1

1-3

3-5

Over 5

Total

In 2019, Loans and Lending commitments associated with the
increased  by
Wealth  Management  business 
approximately 13%, primarily due to growth in Securities-based
lending, Residential real estate loans, and tailored lending.

segment 

Securities-based lending

and other loans

Residential real estate

loans

Total loans

$

41,863 $ 3,972 $ 2,783 $ 1,284 $49,902

Customer and Other Receivables

13

11

— 30,149

30,173

Margin Loans

$

41,876 $ 3,983 $ 2,783 $31,433 $80,075

Lending commitments

10,219

2,564

71

307

13,161

Total loans and lending 

commitments

$

52,095 $ 6,547 $ 2,854 $31,740 $93,236

$ in millions

Customer receivables representing margin 

loans

$ 22,216 $ 9,700 $ 31,916

At December 31, 2019

IS

WM

Total

At December 31, 2018

Contractual Years to Maturity

$ in millions

At December 31, 2018

IS

WM

Total

$ in millions

Less than 1

1-3

3-5

Over 5

Total

Securities-based lending

and other loans

Residential real estate

loans

Total loans

$

38,144 $ 3,573 $ 2,004 $ 1,006 $44,727

—

30

1

27,436

27,467

$

38,144 $ 3,603 $ 2,005 $28,442 $72,194

Lending commitments

9,197

1,151

42

273

10,663

Total loans and lending 

commitments

$

47,341 $ 4,754 $ 2,047 $28,715 $82,857

The  principal Wealth  Management  business  segment  lending
activities include securities-based lending and residential real
estate loans.

Securities-based lending allows clients to borrow money against
the  value  of  qualifying  securities,  generally  for  any  purpose
other than purchasing securities. We establish approved credit
lines against qualifying securities and monitor limits daily and,
pursuant  to  such  guidelines,  require  customers  to  deposit
additional collateral, or reduce debt positions, when necessary.
These credit lines are primarily uncommitted loan facilities, as
we reserve the right to not make any advances or may terminate
these credit lines at any time. Factors considered in the review
of these loans include, but are not limited to, the loan amount,
the  client’s  credit  profile,  the  degree  of  leverage,  collateral
diversification, price volatility and liquidity of the collateral.

Residential  real  estate  loans  consist  of  first  and  second  lien
mortgages,  including  HELOCs.  Our  underwriting  policy  is
designed  to  ensure  that  all  borrowers  pass  an  assessment  of
capacity  and  willingness  to  pay,  which  includes  an  analysis
utilizing  industry  standard  credit  scoring  models  (e.g.,  FICO
scores), debt-to-income ratios and assets of the borrower. Loan-
to-value ratios are determined based on independent third-party
property appraisals and valuations, and security lien positions
are  established  through  title  and  ownership  reports. The  vast
majority of mortgage loans, including HELOCs, are held for
investment in the Wealth Management business segment’s loan
portfolio.

Customer receivables representing margin 

loans

$ 14,842 $ 11,383 $ 26,225

The Institutional Securities and Wealth Management business
segments provide margin lending arrangements, which allow
customers to borrow against the value of qualifying securities.
Margin lending activities generally have minimal credit risk due
to  the  value  of  collateral  held  and  their  short-term  nature.
Amounts may fluctuate from period to period as overall client
balances change as a result of market levels, client positioning
and leverage.

Employee Loans

$ in millions

Balance

Allowance for loan losses

Balance, net

Remaining repayment term, weighted

average in years

At
December 31,
2019

At
December 31,
2018

$

$

2,980 $

(61)

2,919 $

4.8

3,415

(63)

3,352

4.3

In 2019, the balance of employee loans decreased as a result of
the  roll-off  of  certain  acquisition-related  employee  retention
loans and repayments, partially offset by new note issuances.
Employee  loans  are  granted  in  conjunction  with  a  program
established  primarily  to  recruit  certain  Wealth  Management
representatives, are full recourse and generally require periodic
repayments. We establish an allowance for loan amounts we do
not consider recoverable, and the related provision is recorded
in Compensation and benefits expense.

69

December 2019 Form 10-K

Table of Contents
Risk Disclosures

Derivatives

Fair Value of OTC Derivative Assets

Counterparty Credit Rating1

$ in millions

AAA

AA

A

BBB

NIG

Total

At December 31, 2019

<1 year

1-3 years

3-5 years

Over 5 years

Total, gross

$

371 $

9,195 $ 31,789 $ 22,757 $

6,328 $ 70,440

378

502

5,150

4,448

17,707

11,495

9,903

6,881

9,016

3,421

43,746

25,155

3,689

24,675

70,765

40,542

14,587

154,258

$

4,940 $ 43,468 $ 130,164 $ 81,675 $ 33,352 $ 293,599

Counterparty netting

(2,172)

(33,521)

(103,452)

(62,345)

(19,514)

(221,004)

Cash and securities

collateral

(2,641)

(8,134)

(22,319)

(14,570)

(10,475)

(58,139)

Total, net

$

127 $

1,813 $

4,393 $

4,760 $

3,363 $ 14,456

Counterparty Credit Rating1

$ in millions

AAA

AA

A

BBB

NIG

Total

At December 31, 2018

<1 year

1-3 years

3-5 years

Over 5 years

Total, gross

$

878 $

7,430 $ 38,718 $ 15,009 $

7,183 $ 69,218

664

621

3,535

2,362

2,096

9,725

22,239

10,255

11,673

6,014

7,097

2,751

42,617

23,155

67,166

36,087

11,112

127,625

$

5,698 $ 21,613 $ 139,796 $ 67,365 $ 28,143 $ 262,615

Counterparty netting

(2,325)

(13,771)

(113,045)

(49,658)

(16,681)

(195,480)

Cash and securities

collateral

(3,214)

(5,766)

(21,931)

(12,702)

(8,269)

(51,882)

Total, net

$

159 $

2,076 $

4,820 $

5,005 $

3,193 $ 15,253

$ in millions

Industry

Utilities

Financials

Healthcare

Industrials

Regional governments

Information technology

Not-for-profit organizations

Energy

Sovereign governments

Communications services

Consumer discretionary

Materials

Real estate

Insurance

Consumer staples

Other

Total

At
December 31,
2019

At
December 31,
2018

$

4,275 $

3,448

991

914

791

659

657

524

403

381

370

325

315

214

129

60

4,324

4,480

787

1,335

779

695

583

199

385

373

188

275

283

235

216

116

$

14,456 $

15,253

1. Counterparty credit ratings are determined internally by CRM.

We incur credit risk as a dealer in OTC derivatives. Credit risk
with respect to derivative instruments arises from the possibility
that a counterparty may fail to perform according to the terms
of the contract. For a description of our risk mitigation strategies,
see “Credit Risk—Risk Mitigation” herein.

December 2019 Form 10-K

70

Credit Derivatives

A credit derivative is a contract between a seller and buyer of
protection against the risk of a credit event occurring on one or
more debt obligations issued by a specified reference entity. The
buyer  typically  pays  a  periodic  premium  over  the  life  of  the
contract and is protected for the period. If a credit event occurs,
the seller is required to make payment to the beneficiary based
on the terms of the credit derivative contract. Credit events, as
defined in the contract, may be one or more of the following
defined  events:  bankruptcy,  dissolution  or  insolvency  of  the
referenced  entity,  failure  to  pay,  obligation  acceleration,
repudiation, payment moratorium and restructuring.

We  trade  in  a  variety  of  credit  derivatives  and  may  either
purchase or write protection on a single name or portfolio of
referenced  entities.  In  transactions  referencing  a  portfolio  of
entities or securities, protection may be limited to a tranche of
exposure or a single name within the portfolio. We are an active
market  maker  in  the  credit  derivatives  markets. As  a  market
maker, we work to earn a bid-offer spread on client flow business
and manage any residual credit or correlation risk on a portfolio
basis. Further, we use credit derivatives to manage our exposure
to  residential  and  commercial  mortgage  loans  and  corporate
lending exposures. The effectiveness of our CDS protection as
a hedge of our exposures may vary depending upon a number
of factors, including the contractual terms of the CDS.

We actively monitor our counterparty credit risk related to credit
derivatives. A majority of our counterparties are composed of
banks, broker-dealers, insurance and other financial institutions.
Contracts  with  these  counterparties  may  include  provisions
related to counterparty rating downgrades, which may result in
the counterparty posting additional collateral to us. As with all
derivative contracts, we consider counterparty credit risk in the
valuation of our positions and recognize CVAs as appropriate
within Trading revenues in the income statements.

For  additional  credit  exposure  information  on  our  credit
derivative portfolio, see Note 5 to the financial statements.

Country Risk

Country risk exposure is the risk that events in, or that affect, a
foreign  country  (any  country  other  than  the  U.S.)  might
adversely affect us. We actively manage country risk exposure
through  a  comprehensive  risk  management  framework  that
combines  credit  and  market  fundamentals  and  allows  us  to
effectively identify, monitor and limit country risk.

Our obligor credit evaluation process may also identify indirect
exposures, whereby an obligor has vulnerability or exposure to
another country or jurisdiction. Examples of indirect exposures
include mutual funds that invest in a single country, offshore
companies whose assets reside in another country to that of the
offshore  jurisdiction  and  finance  company  subsidiaries  of
corporations.  Indirect  exposures  identified  through  the  credit

Table of Contents
Risk Disclosures

evaluation process may result in a reclassification of country
risk.

We  conduct  periodic  stress  testing  that  seeks  to  measure  the
impact on our credit and market exposures of shocks stemming
from negative economic or political scenarios. When deemed
appropriate  by  our  risk  managers,  the  stress  test  scenarios
include possible contagion effects and second order risks. This
analysis,  and  results  of  the  stress  tests,  may  result  in  the
amendment of limits or exposure mitigation.

Our  sovereign  exposures  consist  of  financial  contracts  and
obligations entered into with sovereign and local governments.
Our non-sovereign exposures consist of financial contracts and
obligations  entered  into  primarily  with  corporations  and
financial institutions. Index credit derivatives are included in
the following country risk exposure table. Each reference entity
within an index is allocated to that reference entity’s country of
risk. Index exposures are allocated to the underlying reference
entities in proportion to the notional weighting of each reference
entity  in  the  index,  adjusted  for  any  fair  value  receivable  or
payable  for  that  reference  entity.  Where  credit  risk  crosses
multiple jurisdictions, for example, a CDS purchased from an
issuer in a specific country that references bonds issued by an
entity in a different country, the fair value of the CDS is reflected
in the Net Counterparty Exposure row based on the country of
the CDS issuer. Further, the notional amount of the CDS adjusted
for the fair value of the receivable or payable is reflected in the
Net  Inventory  row  based  on  the  country  of  the  underlying
reference entity.

Top 10 Non-U.S. Country Exposures at December 31, 2019 

United Kingdom

$ in millions
Net inventory1
Net counterparty exposure2

Loans

Lending commitments

Exposure before hedges
Hedges3

Net exposure

Japan

$ in millions
Net inventory1
Net counterparty exposure2

Loans

Lending commitments

Exposure before hedges
Hedges3

Net exposure

Sovereigns Non-sovereigns

Total

$

(1,106) $

1,958 $

852

—

—

—

(1,106)

(312)

10,583

10,583

2,845

5,452

2,845

5,452

20,838

19,732

(1,350)

(1,662)

$

(1,418) $

19,488 $ 18,070

Sovereigns Non-sovereigns

Total

$

2,175 $

776 $

2,951

26

—

—

2,201

(93)

3,657

3,683

730

2

730

2

5,165

7,366

(131)

(224)

$

2,108 $

5,034 $

7,142

Germany

$ in millions
Net inventory1
Net counterparty exposure2

Loans

Lending commitments

Exposure before hedges
Hedges3

Net exposure

Spain

$ in millions
Net inventory1
Net counterparty exposure2

Loans

Lending commitments

Exposure before hedges
Hedges3

Net exposure

China

$ in millions
Net inventory1
Net counterparty exposure2

Loans

Lending commitments

Exposure before hedges
Hedges3

Net exposure

France

$ in millions
Net inventory1
Net counterparty exposure2

Loans

Lending commitments

Exposure before hedges
Hedges3

Net exposure

Canada

$ in millions
Net inventory1
Net counterparty exposure2

Loans

Lending commitments

Exposure before hedges
Hedges3

Net exposure

Sovereigns Non-sovereigns

Total

$

(352) $

228 $

(124)

100

—

—

(252)

(230)

2,383

1,610

3,685

7,906

2,483

1,610

3,685

7,654

(869)

(1,099)

$

(482) $

7,037 $

6,555

Sovereigns Non-sovereigns

Total

$

182 $

—

—

—

182

—

(80) $

270

102

270

3,828

3,828

745

745

4,763

4,945

(137)

(137)

$

182 $

4,626 $

4,808

Sovereigns Non-sovereigns

Total

$

(637) $

1,007 $

47

—

—

(590)

(82)

370

247

1,950

1,716

4,283

200

1,950

1,716

4,873

(80)

(162)

$

(672) $

4,793 $

4,121

Sovereigns Non-sovereigns

Total

$

(1,720) $

181 $ (1,539)

—

—

—

(1,720)

(6)

2,070

2,070

620

3,375

6,246

620

3,375

4,526

(600)

(606)

$

(1,726) $

5,646 $

3,920

Sovereigns Non-sovereigns

Total

$

(490) $

236 $

(254)

109

—

—

(381)

—

2,000

2,109

182

1,439

3,857

182

1,439

3,476

(152)

(152)

$

(381) $

3,705 $

3,324

71

December 2019 Form 10-K

Table of Contents
Risk Disclosures

Netherlands

$ in millions
Net inventory1
Net counterparty exposure2

Loans

Lending commitments

Exposure before hedges
Hedges3

Net exposure

Australia

$ in millions
Net inventory1
Net counterparty exposure2

Loans

Lending commitments

Exposure before hedges
Hedges3

Net exposure

India

$ in millions
Net inventory1
Net counterparty exposure2

Loans

Sovereigns Non-sovereigns

Total

$

46 $

545 $

—

—

—

46

748

946

1,103

3,342

591

748

946

1,103

3,388

(32)

14 $

$

(158)

(190)

3,184 $

3,198

Sovereigns Non-sovereigns

Total

$

761 $

293 $

1,054

17

—

—

778

—

632

291

978

649

291

978

2,194

2,972

(103)

(103)

$

778 $

2,091 $

2,869

Sovereigns Non-sovereigns

Total

$

1,273 $

556 $

1,829

—

—

518

247

518

247

Exposure before hedges

1,273

1,321

2,594

Net exposure

$

1,273 $

1,321 $

2,594

1. Net  inventory  represents  exposure  to  both  long  and  short  single-name  and  index
positions (i.e., bonds and equities at fair value and CDS based on a notional amount
assuming zero recovery adjusted for the fair value of any receivable or payable).
2. Net counterparty exposure (e.g., repurchase transactions, securities lending and OTC
derivatives) is net of the benefit of collateral received and also is net by counterparty
when  legally  enforceable  master  netting  agreements  are  in  place.  For  more
information,  see  “Additional  Information—Top  10  Non-U.S.  Country  Exposures”
herein.

3. Amounts  represent  net  CDS  hedges  (purchased  and  sold)  on  net  counterparty
exposure and lending executed by trading desks responsible for hedging counterparty
and lending credit risk exposures. Amounts are based on the CDS notional amount
assuming zero recovery adjusted for any fair value receivable or payable. For further
description of the contractual terms for purchased credit protection and whether they
may  limit  the  effectiveness  of  our  hedges,  see  “Quantitative  and  Qualitative
Disclosures about Risk—Credit Risk—Derivatives" herein.

Additional  Information—Top  10  Non-U.S.  Country
Exposures

Collateral Held against Net Counterparty Exposure1

$ in millions

Counterparty credit exposure

Collateral2

At
December 31,
2019

Germany

United Kingdom

Other

Italy and Germany

$

U.K., U.S. and Spain

Japan, U.S. and France

11,478

9,374

17,312

1. The benefit of collateral received is reflected in the Top 10 Non-U.S. Country Exposures

at December 31, 2019.

2. Collateral primarily consists of cash and government obligations.

December 2019 Form 10-K

72

Country Risk Exposures Related to the U.K.

At December 31, 2019, our country risk exposures in the U.K.
included net exposures of $18,070 million (as shown in the Top
10 Non-U.S. Country Exposures table) and overnight deposits
of $6,378 million. The $19,488 million of exposures to non-
sovereigns were diversified across both names and sectors and
include  $6,804  million  to  U.K.-focused  counterparties  that
generate  more  than  one-third  of  their  revenues  in  the  U.K.,
$4,817 million to geographically diversified counterparties, and
$5,946 million to exchanges and clearinghouses.

In addition to our country risk exposure, we disclose our cross-
in  “Financial  Statements  and
border 
Supplement
Data 
Supplementary 
(Unaudited).” 

Data—Financial 

risk  exposure 

Operational Risk

Operational risk refers to the risk of loss, or of damage to our
reputation,  resulting  from  inadequate  or  failed  processes  or
systems, from human factors or from external events (e.g., fraud,
theft, legal and compliance risks, cyber attacks or damage to
physical assets). We may incur operational risk across the full
scope of our business activities, including revenue-generating
activities (e.g., sales and trading) and support and control groups
(e.g., information technology and trade processing).

We have established an operational risk framework to identify,
measure,  monitor  and  control  risk  across  the  Firm.  Effective
operational risk management is essential to reducing the impact
of operational risk incidents and mitigating legal, regulatory and
reputational  risks.  The  framework  is  continually  evolving  to
account for changes in the Firm and to respond to the changing
regulatory and business environment.

We  have  implemented  operational  risk  data  and  assessment
systems to monitor and analyze internal and external operational
risk events, to assess business environment and internal control
factors,  and  to  perform  scenario  analysis.  The  collected  data
elements are incorporated in the operational risk capital model.
The  model  encompasses  both  quantitative  and  qualitative
elements.  Internal  loss  data  and  scenario  analysis  results  are
direct  inputs  to  the  capital  model,  while  external  operational
incidents, business environment and internal control factors are
evaluated as part of the scenario analysis process.

In addition, we employ a variety of risk processes and mitigants
to  manage  our  operational  risk  exposures.  These  include  a
governance  framework,  a  comprehensive  risk  management
program and insurance. Operational risks and associated risk
exposures are assessed relative to the risk tolerance reviewed
and confirmed by the Board and are prioritized accordingly.

The breadth and range of operational risk are such that the types
of mitigating activities are wide-ranging. Examples of activities
include:  continuous  enhancement  of  defenses  against  cyber

Table of Contents
Risk Disclosures

limit  operational 

attacks; use of legal agreements and contracts to transfer and/
risk  exposures;  due  diligence;
or 
implementation  of  enhanced  policies  and  procedures;
technology 
exception
management processing controls; and segregation of duties.

change  management 

controls; 

Primary responsibility for the management of operational risk
is  with  the  business  segments,  the  control  groups  and  the
business  managers  therein.  The  business  managers  maintain
processes  and  controls  designed  to  identify,  assess,  manage,
mitigate  and  report  operational  risk.  Each  of  the  business
segments  has  a  designated  operational  risk  coordinator.  The
operational risk coordinator regularly reviews operational risk
issues  and  reports  to  our  senior  management  within  each
business. Each control group also has a designated operational
risk  coordinator  and  a  forum  for  discussing  operational  risk
matters with our senior management. Oversight of operational
risk is provided by the Operational Risk Oversight Committee,
legal entity risk committees, regional risk committees and senior
management. In the event of a merger; joint venture; divestiture;
reorganization; or creation of a new legal entity, a new product,
or a business activity, operational risks are considered, and any
necessary changes in processes or controls are implemented.

The  Operational  Risk  Department  provides  independent
oversight  of  operational  risk  and  assesses,  measures  and
monitors  operational  risk  against  tolerance.  The  Operational
Risk Department works with the divisions and control groups
to  help  ensure  a  transparent,  consistent  and  comprehensive
framework for managing operational risk within each area and
across the Firm.

The Operational Risk Department scope includes oversight of
technology risk, cybersecurity risk, information security risk,
the fraud risk management and prevention program, and third-
party risk management (supplier and affiliate risk oversight and
assessment).

Cybersecurity

security 

cybersecurity 

Our 
policies,
and information 
procedures, and technologies are designed to protect our own,
our  client  and  our  employee  data  against  unauthorized
disclosure,  modification  or  misuse  and  are  also  designed  to
address regulatory requirements. These policies and procedures
cover a broad range of areas, including: identification of internal
and  external  threats,  access  control,  data  security,  protective
controls,  detection  of  malicious  or  unauthorized  activity,
incident response and recovery planning.

Business Continuity Management and Disaster Recovery

operations, technology, suppliers and/or facilities. The business
continuity management program’s core functions are business
continuity planning and crisis management. As part of business
continuity  planning,  our  business  units  maintain  business
continuity plans, identifying processes and strategies to continue
business-critical processes during a business continuity event.
Crisis management is the process of identifying and managing
our  operations  during  business  continuity  events.  Disaster
recovery plans supporting business continuity are in place for
critical technology assets and systems across the Firm. 

Third Party Risk Management

In  connection  with  our  ongoing  operations,  we  utilize  the
services  of  third  party  suppliers,  which  we  anticipate  will
continue and may increase in the future. These services include,
for example, outsourced processing and support functions and
other  professional  services. Our  risk-based  approach 
to
managing exposure to these services includes the performance
of  due  diligence,  implementation  of  service  level  and  other
contractual agreements, consideration of operational risks and
ongoing monitoring of third-party suppliers’ performance. We
maintain  and  continue  to  enhance  our  third-party  risk
management program which includes appropriate governance,
policies,  procedures  and  technology  that  supports  alignment
with  our  risk  tolerance  and  is  designed  to  meet  regulatory
third-party  risk  management  program
requirements. The 
includes the adoption of appropriate risk management controls
and  practices  through  the  supplier  management  life  cycle,
including, but not limited to, assessment of information security,
service  failure,  financial  stability,  disaster  recoverability,
reputational  risk,  contractual  risk  and  safeguards  against
corruption.

Model Risk

Model risk refers to the potential for adverse consequences from
decisions based on incorrect or misused model outputs. Model
risk  can  lead  to  financial  loss,  poor  business  and  strategic
decision making or damage to our reputation. The risk inherent
in  a  model  is  a  function  of  the  materiality,  complexity  and
uncertainty around inputs and assumptions.

Model  risk  is  generated  from  the  use  of  models  impacting
financial  statements,  regulatory  filings,  capital  adequacy
assessments and the formulation of strategy.

Sound model risk management is an integral part of our Risk
Management  Framework.  The  Model  Risk  Management
Department  (“MRM”)  is  a  distinct  department  in  Risk
Management responsible for the oversight of model risk.

We  maintain  global  programs  for  business  continuity
management  and  technology  disaster  recovery  that  facilitate
activities  designed  to  mitigate  our  risk  during  a  business
continuity event. A business continuity event is an interruption
with potential impact to normal business activity of our people,

MRM establishes a model risk tolerance in line with our risk
appetite.  The  tolerance  is  based  on  an  assessment  of  the
materiality of the risk of financial loss or reputational damage
due to errors in design, implementation and/or inappropriate use
of models. The tolerance is monitored through model-specific

73

December 2019 Form 10-K

funding  risk  across  the  Firm.  See  also  “Management’s
Discussion and Analysis of Financial Condition and Results of
Operations—Liquidity and Capital Resources.”

Legal and Compliance Risk

Legal and compliance risk includes the risk of legal or regulatory
sanctions,  material  financial  loss,  including  fines,  penalties,
judgments,  damages  and/or  settlements,  or  loss  to  reputation
that we may suffer as a result of failure to comply with laws,
regulations, rules, related self-regulatory organization standards
and codes of conduct applicable to our business activities. This
risk also includes contractual and commercial risk, such as the
risk  that  a  counterparty’s  performance  obligations  will  be
unenforceable. It also includes compliance with AML, terrorist
financing,  and  anti-corruption  rules  and  regulations.  We  are
generally  subject  to  extensive  regulation  in  the  different
jurisdictions  in  which  we  conduct  our  business  (see  also
“Business—Supervision and Regulation” and “Risk Factors”).

statutory  and 

We have established procedures based on legal and regulatory
requirements on a worldwide basis that are designed to facilitate
regulatory
compliance  with  applicable 
requirements and to require that our policies relating to business
conduct, ethics and practices are followed globally. In addition,
we  have  established  procedures  to  mitigate  the  risk  that  a
counterparty’s performance obligations will be unenforceable,
including  consideration  of  counterparty  legal  authority  and
capacity, adequacy of legal documentation, the permissibility
of a transaction under applicable law and whether applicable
bankruptcy  or  insolvency  laws  limit  or  alter  contractual
remedies.  The  heightened  legal  and  regulatory  focus  on  the
financial  services  and  banking  industries  globally  presents  a
continuing business challenge for us.

Table of Contents
Risk Disclosures

and aggregate business-level assessments, which are based upon
qualitative and quantitative factors.

A guiding principle for managing model risk is the “effective
challenge”  of  models.  The  effective  challenge  of  models  is
defined as critical analysis by objective, informed parties who
can  identify  model  limitations  and  assumptions  and  drive
appropriate  changes.  MRM  provides  effective  challenge  of
models, independently validates and approves models for use,
annually recertifies models, identifies and tracks remediation
plans for model limitations and reports on model risk metrics.
The department also oversees the development of controls to
support a complete and accurate Firmwide model inventory.

Liquidity Risk

Liquidity risk refers to the risk that we will be unable to finance
our operations due to a loss of access to the capital markets or
difficulty  in  liquidating  our  assets.  Liquidity  risk  also
encompasses  our  ability  (or  perceived  ability)  to  meet  our
financial obligations without experiencing significant business
disruption or reputational damage that may threaten our viability
as  a  going  concern.  Liquidity  risk  also  encompasses  the
associated funding risks triggered by the market or idiosyncratic
stress events that may negatively affect our liquidity and may
impact  our  ability  to  raise  new  funding.  Generally,  we  incur
liquidity  and  funding  risk  as  a  result  of  our  trading,  lending,
investing and client facilitation activities.

Our  Liquidity  Risk  Management  Framework  is  critical  to
helping ensure that we maintain sufficient liquidity reserves and
durable funding sources to meet our daily obligations and to
withstand  unanticipated  stress  events.  The  Liquidity  Risk
Department is a distinct area in Risk Management responsible
for the oversight and monitoring of liquidity risk. The Liquidity
Risk Department ensures transparency of material liquidity and
funding  risks,  compliance  with  established  risk  limits  and
escalation  of  risk  concentrations 
to  appropriate  senior
management.

To execute these responsibilities, the Liquidity Risk Department
establishes limits in line with our risk appetite, identifies and
analyzes emerging liquidity and funding risks to ensure such
risks  are  appropriately  mitigated,  monitors  and  reports  risk
exposures  against  metrics  and  limits,  and  reviews  the
methodologies  and  assumptions  underpinning  our  Liquidity
Stress Tests to ensure sufficient liquidity and funding under a
range of adverse scenarios. 

responsibility 

The Treasury Department and applicable business units have
primary 
for  evaluating,  monitoring  and
controlling  the  liquidity  and  funding  risks  arising  from  our
business activities and for maintaining processes and controls
to manage the key risks inherent in their respective areas. The
Liquidity  Risk  Department  coordinates  with  the  Treasury
Department and these business units to help ensure a consistent
and  comprehensive  framework  for  managing  liquidity  and

December 2019 Form 10-K

74

Table of Contents

Financial Statements and Supplementary Data

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Shareholders and the Board of Directors of Morgan Stanley:

Opinion on the Financial Statements

We have audited the accompanying consolidated balance sheets
of Morgan Stanley and subsidiaries (the “Firm”) as of December
31, 2019 and 2018, the related consolidated income statements,
comprehensive  income  statements,  cash  flow  statements  and
statements of changes in total equity for each of the three years
ended December 31, 2019, 2018, and 2017, and the related notes
(collectively referred to as the “financial statements”). In our
opinion, the financial statements present fairly, in all material
respects, the financial position of the Firm as of December 31,
2019  and  2018,  and  the  results  of  its  operations  and  its  cash
flows  for  each  of  the  three  years  ended  December  31,  2019,
2018,  and  2017,  in  conformity  with  accounting  principles
generally accepted in the United States of America. 

We have also audited, in accordance with the standards of the
Public Company Accounting Oversight Board (United States)
(PCAOB), the Firm’s internal control over financial reporting
as  of  December 31,  2019,  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 February 27, 2020, expressed
an  unqualified  opinion  on  the  Firm’s  internal  control  over
financial reporting. 

Basis for Opinion

These financial statements are the responsibility of the Firm’s
management. Our responsibility is to express an opinion on the
Firm’s 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 Firm 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 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  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 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  financial  statements.  We  believe  that  our
audits provide a reasonable basis for our opinion. 

Critical Audit Matter

The critical audit matter communicated below is a matter arising
from  the  current-period  audit  of  the  financial  statements  that
was communicated or required to be communicated to the audit
committee and that (1) relates to accounts or disclosures that are
material  to  the  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 financial statements, taken as a whole,
and  we  are  not,  by  communicating  the  critical  audit  matter
below, providing a separate opinion on the critical audit matter
or on the accounts or disclosures to which it relates.

Valuation of Level 3 Financial Assets and Liabilities Carried
at Fair Value - Refer to Note 3 to the financial statements

Critical Audit Matter Description

The Firm’s trading and financing activities result in the Firm
carrying  material  financial  instruments  having  limited  price
transparency. These financial instruments can span a broad array
of product types and generally include derivative, security and
lending positions, as well as borrowings carried at fair value.
These financial instruments are generally classified as Level 3
financial  assets  or  liabilities  in  conformity  with  accounting
principles generally accepted in the United States of America.

therefore  more  easily 

Unlike financial instruments whose values or inputs are readily
observable  and 
independently
corroborated, the valuation of financial instruments classified
as Level 3 is inherently subjective, and often involves the use of
proprietary valuation models whose underlying algorithms and
valuation methodologies are complex.

75

December 2019 Form 10-K

 
 
Table of Contents

Given the Firm uses complex valuation models and model inputs
that are not observable in the marketplace to determine the fair
value of Level 3 financial assets and liabilities carried at fair
value,  performing  audit  procedures 
the
appropriateness  of  these  models  and  inputs  involved  a  high
degree of auditor judgment, specialized skills, and an increased
extent of testing.

to  evaluate 

 How the Critical Audit Matter Was Addressed in the Audit

• We 

• We tested the design and operating effectiveness of the Firm’s
valuation  controls,  including  model  review  and  price
verification for the appropriateness of valuation methodology
including inputs and assumptions used.
independently  evaluated 

the  appropriateness  of
management’s 
valuation  methodologies,
including  the  input  assumptions,  considering  the  expected
assumptions of other market participants, and external data,
when available.

significant 

• We  developed  independent  valuation  estimates  for  certain
financial  instrument  selections,  using  externally  sourced
inputs  and  independent  valuation  models,  and  used  such
estimates  to  further  evaluate  management’s  fair  value
measurement  by  investigating  the  differences  exceeding
established thresholds between our estimate and that of the
Firm,  including;  comparing  the  fair  value  estimate  with
similar transactions; and, evaluating the Firm’s assumptions
inclusive of the inputs.

• We tested the revenues arising from the valuation estimate on
trade date for certain structured transactions involving Level
3 financial instruments. In performing such procedures, we
also  developed  independent  valuation  estimates  for  certain
structured  transaction  selections,  as  well  as  tested  the
valuation  assumptions  and  methodologies  used  by  the
Company.  Those  procedures  also  included  evaluating
whether the methods were consistent with relevant Company
valuation  policies  and  agreeing  relevant  cash  flows  to
underlying support.

• We  assessed  the  consistency  by  which  management  has
applied significant and unobservable valuation assumptions.
• We performed a retrospective assessment of management’s
valuation  estimates  for  a  sample  of  financial  instrument
selections  by  comparing  such  estimates 
to  relevant
transactions.

/s/ Deloitte & Touche LLP 
New York, New York
February 27, 2020 

We have served as the Firm’s auditor since 1997.

December 2019 Form 10-K

76

Table of Contents
Consolidated Income Statements

in millions, except per share data

Revenues

Investment banking

Trading

Investments

Commissions and fees

Asset management

Other

Total non-interest revenues

Interest income

Interest expense

Net interest

Net revenues

Non-interest expenses

Compensation and benefits

Occupancy and equipment

Brokerage, clearing and exchange fees

Information processing and communications

Marketing and business development

Professional services

Other

Total non-interest expenses

Income from continuing operations before income taxes

Provision for income taxes

Income from continuing operations

Income (loss) from discontinued operations, net of income taxes

Net income

Net income applicable to noncontrolling interests

Net income applicable to Morgan Stanley

Preferred stock dividends and other

Earnings applicable to Morgan Stanley common shareholders

Earnings per basic common share

Income from continuing operations

Income (loss) from discontinued operations

Earnings per basic common share

Earnings per diluted common share

Income from continuing operations

Income (loss) from discontinued operations

Earnings per diluted common share

Average common shares outstanding

Basic

Diluted

2019

2018

2017

$

6,163 $

6,482 $

11,095

1,540

3,919

13,083

925

36,725

17,098

12,404

4,694

41,419

11,551

437

4,190

12,898

743

36,301

13,892

10,086

3,806

40,107

6,003

11,116

820

4,061

11,797

848

34,645

8,997

5,697

3,300

37,945

18,837

17,632

17,166

1,428

2,493

2,194

660

2,137

2,369

30,118

11,301

2,064

9,237

—

1,391

2,393

2,016

691

2,265

2,482

28,870

11,237

2,350

8,887

(4)

9,237 $

8,883 $

195

135

9,042 $

8,748 $

530

526

8,512 $

8,222 $

5.26 $

—

5.26 $

5.19 $

—

5.19 $

4.81 $

—

4.81 $

4.73 $

—

4.73 $

1,329

2,093

1,791

609

2,169

2,385

27,542

10,403

4,168

6,235

(19)

6,216

105

6,111

523

5,588

3.15

(0.01)

3.14

3.08

(0.01)

3.07

1,617

1,640

1,708

1,738

1,780

1,821

$

$

$

$

$

$

$

See Notes to Consolidated Financial Statements

77

December 2019 Form 10-K

Table of Contents
Consolidated Comprehensive Income Statements

$ in millions

Net income

Other comprehensive income (loss), net of tax:

Foreign currency translation adjustments

Change in net unrealized gains (losses) on available-for-sale securities

Pension, postretirement and other

Change in net debt valuation adjustment

Total other comprehensive income (loss)

Comprehensive income

Net income applicable to noncontrolling interests

Other comprehensive income (loss) applicable to noncontrolling interests

Comprehensive income applicable to Morgan Stanley

2019

2018

2017

9,237 $

8,883 $

6,216

3 $

(90) $

1,137

(66)

(1,639)

(565) $

8,672 $

195

(69)

(272)

137

1,517

1,292 $

10,175 $

135

87

8,546 $

9,953 $

251

41

(117)

(588)

(413)

5,803

105

4

5,694

$

$

$

$

$

December 2019 Form 10-K

78

See Notes to Consolidated Financial Statements

Table of Contents
Consolidated Balance Sheets

$ in millions, except share data

Assets

Cash and cash equivalents:

Cash and due from banks

Interest bearing deposits with banks

Restricted cash

Trading assets at fair value ($128,386 and $120,437 were pledged to various parties)

Investment securities (includes $62,223 and $61,061 at fair value)

Securities purchased under agreements to resell (includes $4 and $— at fair value)

Securities borrowed

Customer and other receivables

Loans:

Held for investment (net of allowance of $349 and $238)

Held for sale

Goodwill

Intangible assets (net of accumulated amortization of $3,204 and $2,877)

Other assets

Total assets

Liabilities

Deposits (includes $2,099 and $442 at fair value)

Trading liabilities at fair value

Securities sold under agreements to repurchase (includes $733 and $812 at fair value)

Securities loaned

Other secured financings (includes $7,809 and $5,245 at fair value)

Customer and other payables

Other liabilities and accrued expenses

Borrowings (includes $64,461 and $51,184 at fair value)

Total liabilities

Commitments and contingent liabilities (see Note 13)

Equity

Morgan Stanley shareholders’ equity:

Preferred stock

Common stock, $0.01 par value:

Shares authorized: 3,500,000,000; Shares issued: 2,038,893,979; Shares outstanding: 1,593,973,680 and

1,699,828,943

Additional paid-in capital

Retained earnings

Employee stock trusts

Accumulated other comprehensive income (loss)

Common stock held in treasury at cost, $0.01 par value (444,920,299 and 339,065,036 shares)

Common stock issued to employee stock trusts

Total Morgan Stanley shareholders’ equity

Noncontrolling interests

Total equity

Total liabilities and equity

At 
December 31, 
 2019

At 
December 31, 
 2018

$

4,293 $

45,366

32,512

297,110

105,725

88,224

106,549

55,646

118,060

12,577

7,143

2,107

20,117

895,429 $

190,356 $

133,356

54,200

8,506

14,698

197,834

21,155

192,627

812,732

$

$

30,541

21,299

35,356

266,299

91,832

98,522

116,313

53,298

99,815

15,764

6,688

2,163

15,641

853,531

187,820

126,747

49,759

11,908

9,466

179,559

17,204

189,662

772,125

8,520

8,520

20

23,935

70,589

2,918

(2,788)

(18,727)

(2,918)

81,549

1,148

82,697

20

23,794

64,175

2,836

(2,292)

(13,971)

(2,836)

80,246

1,160

81,406

$

895,429 $

853,531

See Notes to Consolidated Financial Statements

79

December 2019 Form 10-K

Table of Contents
Consolidated Statements of Changes in Total Equity

$ in millions

Preferred Stock

Beginning Balance

Issuance of preferred stock
Redemption of preferred stock1

Ending balance

Common Stock

Beginning and ending balance

Additional Paid-in Capital

Beginning balance
Cumulative adjustments for accounting changes2

Share-based award activity

Issuance of preferred stock

Other net increases (decreases)

Ending balance

Retained Earnings

Beginning balance
Cumulative adjustments for accounting changes2

Net income applicable to Morgan Stanley
Preferred stock dividends3
Common stock dividends3

Other net increases (decreases)

Ending balance

Employee Stock Trusts

Beginning balance

Share-based award activity

Ending balance

Accumulated Other Comprehensive Income (Loss)

Beginning balance
Cumulative adjustments for accounting changes2

Net change in Accumulated other comprehensive income (loss)

Ending balance

Common Stock Held In Treasury at Cost

Beginning balance

Share-based award activity

Repurchases of common stock and employee tax withholdings

Ending balance

Common Stock Issued to Employee Stock Trusts

Beginning balance

Share-based award activity

Ending balance

Noncontrolling Interests

Beginning balance

Net income applicable to noncontrolling interests

Net change in Accumulated other comprehensive income (loss)

Other net increases (decreases)

Ending balance

Total Equity

2019

2018

2017

$

8,520 $

8,520 $

500

(500)

8,520

—

—

8,520

7,520

1,000

—

8,520

20

20

20

23,794

23,545

23,271

—

131

(3)

13

—

249

—

—

45

306

(6)

(71)

23,935

23,794

23,545

64,175

63

9,042

(524)

(2,161)

(6)

70,589

2,836

82

2,918

(2,292)

—

(496)

(2,788)

(13,971)

1,198

(5,954)

(18,727)

(2,836)

(82)

(2,918)

1,160

195

(69)

(138)

1,148

57,577

306

8,748

(526)

(1,930)

—

64,175

2,907

(71)

2,836

(3,060)

(437)

1,205

(2,292)

(9,211)

806

(5,566)

(13,971)

(2,907)

71

(2,836)

1,075

135

87

(137)

1,160

$

82,697 $

81,406 $

53,679

(35)

6,111

(523)

(1,655)

—

57,577

2,851

56

2,907

(2,643)

—

(417)

(3,060)

(5,797)

878

(4,292)

(9,211)

(2,851)

(56)

(2,907)

1,127

105

4

(161)

1,075

78,466

1. See Note 16 for information regarding the notice of redemption and reclassification of Series G Preferred Stock.
2. See Notes 2 and 16 for further information regarding cumulative adjustments for accounting changes.
3. See Note 16 for information regarding dividends per share for each class of stock.

December 2019 Form 10-K

80

See Notes to Consolidated Financial Statements

Table of Contents
Consolidated Cash Flow Statements

$ in millions

Cash flows from operating activities

Net income

Adjustments to reconcile net income to net cash provided by (used for) operating activities:

2019

2018

2017

$

9,237 $

8,883 $

6,216

Deferred income taxes

Stock-based compensation expense

Depreciation and amortization

Provision for (Release of) credit losses on lending activities

Other operating adjustments

Changes in assets and liabilities:

Trading assets, net of Trading liabilities

Securities borrowed

Securities loaned

Customer and other receivables and other assets

Customer and other payables and other liabilities

Securities purchased under agreements to resell

Securities sold under agreements to repurchase

Net cash provided by (used for) operating activities

Cash flows from investing activities
Proceeds from (payments for):

Other assets—Premises, equipment and software, net

Changes in loans, net

Investment securities:

Purchases
Proceeds from sales
Proceeds from paydowns and maturities

Other investing activities

Net cash provided by (used for) investing activities

Cash flows from financing activities
Net proceeds from (payments for):

Other secured financings

Deposits

Proceeds from:

Issuance of preferred stock, net of issuance costs
Issuance of Borrowings

Payments for:
Borrowings

Repurchases of common stock and employee tax withholdings

Cash dividends

Other financing activities

Net cash provided by (used for) financing activities

Effect of exchange rate changes on cash and cash equivalents

Net increase (decrease) in cash and cash equivalents

Cash and cash equivalents, at beginning of period

Cash and cash equivalents, at end of period

Cash and cash equivalents:

Cash and due from banks

Interest bearing deposits with banks

Restricted cash

Cash and cash equivalents, at end of period

Supplemental Disclosure of Cash Flow Information

Cash payments for:

Interest
Income taxes, net of refunds

165

1,153

2,643

162

(195)

(13,668)

9,764

(3,402)

233

19,942

10,298

4,441

40,773

(1,826)

(17,359)

(42,586)
17,151
12,012

(953)

(33,561)

3,695

2,513

497
30,605

449

920

1,844

(15)

199

23,732

7,697

(1,684)

(728)

(13,063)

(14,264)

(6,665)

7,305

(1,865)

(8,794)

(27,800)
3,208
12,668

(298)

(22,881)

(1,226)

28,384

—
40,059

(40,548)

(34,781)

(5,954)

(2,627)
(147)

(11,966)

(271)

(5,025)

87,196

(5,566)

(2,375)
(290)

24,205

(1,828)

6,801

80,395

82,171 $

87,196 $

4,293 $

30,541 $

45,366

32,512
82,171 $

21,299

35,356
87,196 $

2,747

1,026

1,753

29

153

(27,588)

1,226

(2,252)

(9,315)

2,007

17,697

1,796

(4,505)

(1,629)

(12,125)

(23,962)
18,131
7,445

(251)

(12,391)

(1,573)

3,573

994
55,416

(35,825)

(4,292)

(2,085)
53

16,261

3,670

3,035

77,360

80,395

24,816

21,348

34,231
80,395

12,511 $
1,908

9,977 $
1,377

5,377
1,390

$

$

$

$

See Notes to Consolidated Financial Statements

81

December 2019 Form 10-K

Table of Contents
Notes to Consolidated Financial Statements

1. Introduction and Basis of Presentation 

The Firm

Morgan Stanley is a global financial services firm that maintains
significant market positions in each of its business segments—
Institutional  Securities,  Wealth  Management  and  Investment
Management.  Morgan  Stanley,  through  its  subsidiaries  and
affiliates, provides a wide variety of products and services to a
large and diversified group of clients and customers, including
corporations,  governments, 
and
individuals.  Unless  the  context  otherwise  requires,  the  terms
“Morgan  Stanley”  or  the  “Firm”  mean  Morgan  Stanley  (the
“Parent Company”) together with its consolidated subsidiaries.
See the “Glossary of Common Terms and Acronyms” for the
definition of certain terms and acronyms used throughout this
Form 10-K.

institutions 

financial 

A description of the clients and principal products and services
of each of the Firm’s business segments is as follows:

Institutional  Securities  provides  investment  banking,  sales
and  trading,  lending  and  other  services  to  corporations,
governments, financial institutions and high to ultra-high net
worth clients. Investment banking services consist of capital
raising  and  financial  advisory  services,  including  services
relating  to  the  underwriting  of  debt,  equity  and  other
securities,  as  well  as  advice  on  mergers  and  acquisitions,
restructurings,  real  estate  and  project  finance.  Sales  and
trading services include sales, financing, prime brokerage and
market-making activities in equity and fixed income products,
including  foreign  exchange  and  commodities.  Lending
activities include originating corporate loans and commercial
real  estate  loans,  providing  secured  lending  facilities,  and
extending  financing  to  sales  and  trading  customers.  Other
activities 
include  Asia  wealth  management  services,
investments and research.

Wealth  Management  provides  a  comprehensive  array  of
financial services and solutions to individual investors and
small to medium-sized businesses and institutions covering:
brokerage  and  investment  advisory  services;  financial  and
wealth planning services; stock plan administration services;
annuity  and  insurance  products;  securities-based  lending,
residential  real  estate  loans  and  other  lending  products;
banking; and retirement plan services.

Investment Management provides a broad range of investment
strategies and products that span geographies, asset classes,
and public and private markets to a diverse group of clients
across institutional and intermediary channels. Strategies and
products, which are offered through a variety of investment
liquidity  and
vehicles, 
alternative/other  products.  Institutional  clients 
include
defined  benefit/defined  contribution  plans,  foundations,
endowments,  government  entities,  sovereign  wealth  funds,

include  equity,  fixed 

income, 

December 2019 Form 10-K

82

insurance  companies, 
fund  sponsors  and
third-party 
corporations. Individual clients are generally served through
intermediaries, 
including  affiliated  and  non-affiliated
distributors.

Basis of Financial Information

The financial statements are prepared in accordance with U.S.
GAAP,  which  requires  the  Firm  to  make  estimates  and
assumptions  regarding  the  valuations  of  certain  financial
instruments, the valuations of goodwill and intangible assets,
compensation, deferred tax assets, the outcome of legal and tax
matters, allowance for credit losses, and other matters that affect
its  financial  statements  and  related  disclosures.  The  Firm
believes  that  the  estimates  utilized  in  the  preparation  of  its
financial statements are prudent and reasonable. Actual results
could differ materially from these estimates. 

Certain  reclassifications  have  been  made  to  prior  periods  to
conform to the current presentation. The Notes are an integral
part of the Firm's financial statements. The Firm has evaluated
subsequent  events  for  adjustment  to  or  disclosure  in  these
financial statements through the date of this report and has not
identified  any  recordable  or  disclosable  events  not  otherwise
reported in these financial statements or the notes thereto.

Consolidation

The financial statements include the accounts of the Firm, its
wholly owned subsidiaries and other entities in which the Firm
has a controlling financial interest, including certain VIEs (see
Note  14).  Intercompany  balances  and  transactions  have  been
eliminated.  For  consolidated  subsidiaries  that  are  not  wholly
owned, the third-party holdings of equity interests are referred
to  as  noncontrolling  interests. The  net  income  attributable  to
noncontrolling interests for such subsidiaries is presented as Net
income  applicable  to  noncontrolling  interests  in  the  income
statements.  The  portion  of  shareholders’  equity  that  is
attributable to noncontrolling interests for such subsidiaries is
presented  as  noncontrolling  interests,  a  component  of  Total
equity, in the balance sheets.

For entities where the total equity investment at risk is sufficient
to enable the entity to finance its activities without additional
subordinated financial support and the equity holders bear the
economic residual risks and returns of the entity and have the
power to direct the activities of the entity that most significantly
affect its economic performance, the Firm consolidates those
entities it controls either through a majority voting interest or
otherwise.  For  VIEs  (i.e.,  entities  that  do  not  meet  the
aforementioned  criteria),  the  Firm  consolidates  those  entities
where  it  has  the  power  to  make  the  decisions  that  most
significantly affect the economic performance of the VIE and
has the obligation to absorb losses or the right to receive benefits
that could potentially be significant to the VIE.

 
Table of Contents
Notes to Consolidated Financial Statements

For investments in entities in which the Firm does not have a
controlling financial interest but has significant influence over
operating and financial decisions, it applies the equity method
of accounting with net gains and losses recorded within Other
revenues (see Note 10) unless the Firm has elected to measure
the investment at fair value, in which case net gains and losses
are recorded within Investments revenues (see Note 3).

Equity and partnership interests held by entities qualifying for
accounting purposes as investment companies are carried at fair
value.

The  Firm’s  significant  regulated  U.S.  and  international
subsidiaries include Morgan Stanley & Co. LLC (“MS&Co.”),
Morgan Stanley Smith Barney LLC (“MSSB”), Morgan Stanley
&  Co.  International  plc  (“MSIP”),  Morgan  Stanley  MUFG
Securities  Co.,  Ltd.  (“MSMS”),  Morgan  Stanley  Bank,  N.A.
(“MSBNA”)  and  Morgan  Stanley  Private  Bank,  National
Association (“MSPBNA”).

the relevant non-interest expenses line items when the related
underwriting revenues are recorded.

Advisory fees are recognized as advice is provided to the client,
based on the estimated progress of work and when revenues are
not  probable  of  a  significant  reversal.  Advisory  costs  are
recognized as incurred in the relevant non-interest expenses line
items, including those reimbursed.

Commissions and Fees

Commission  and  fee  revenues  result  from  transaction-based
arrangements  in  which  the  client  is  charged  a  fee  for  the
execution of transactions. Such revenues primarily arise from
transactions in equity securities; services related to sales and
trading activities; and sales of mutual funds, alternative funds,
futures, insurance products and options. Commission and fee
revenues are recognized on trade date when the performance
obligation is satisfied.

Consolidated Cash Flow Statements Presentation

Asset Management Revenues

For  purposes  of  the  cash  flow  statements,  cash  and  cash
equivalents consist of Cash and due from banks, Interest bearing
deposits  with  banks  and  Restricted  cash.  Cash  and  cash
equivalents  includes  highly  liquid  investments  with  original
maturities of three months or less that are held for investment
purposes and are readily convertible to known amounts of cash.

Restricted  cash  includes  cash  in  banks  subject  to  withdrawal
restrictions, restricted deposits held as compensating balances
and  cash  segregated  in  compliance  with  federal  or  other
regulations.

2. Significant Accounting Policies 

Revenue Recognition

Revenues are recognized when the promised goods or services
are delivered to our customers, in an amount that is based on the
consideration the Firm expects to receive in exchange for those
goods  or  services  when  such  amounts  are  not  probable  of
significant  reversal.  These  policies  reflect  the  adoption  of
Revenue from Contracts with Customers on January 1, 2018.
Please see “Accounting Updates Adopted” herein for the more
significant differences in policies applied in prior periods.

Investment Banking

Revenues  from  investment  banking  activities  consist  of
revenues earned from underwriting, primarily equity and fixed
income  securities  and  loan  syndications,  and  advisory  fees,
primarily for mergers, acquisitions and restructurings. 

Underwriting revenues are generally recognized on trade date
if there is no uncertainty or contingency related to the amount
to be paid. Underwriting costs are deferred and recognized in

Asset  management,  distribution  and  administration  fees  are
generally based on related asset levels being managed, such as
the AUM of a customer’s account or the net asset value of a
fund.  These  fees  are  generally  recognized  when  services  are
performed and the fees become known. Management fees are
reduced  by  estimated  fee  waivers  and  expense  caps,  if  any,
provided to the customer.

Performance-based fees not in the form of carried interest are
recorded  when  the  annual  performance  target  is  met  and  the
revenues are not probable of a significant reversal.

Sales commissions paid by the Firm in connection with the sale
of certain classes of shares of its open-end mutual fund products
are accounted for as deferred commission assets and amortized
to  expense  over  the  expected  life  of  the  contract.  The  Firm
periodically tests deferred commission assets for recoverability
based on cash flows expected to be received in future periods.
Other asset management and distribution costs are recognized
as incurred in the relevant non-interest expenses line items.

Carried Interest

The Firm is entitled to receive performance-based fees in the
form of carried interest when the return in certain funds exceeds
specified  performance  targets.  When  the  Firm  earns  carried
interest from funds as specified performance thresholds are met,
that carried interest and any related general or limited partner
interest is accounted for under the equity method of accounting
and measured based on the Firm’s claim on the NAV of the fund
at the reporting date, taking into account the distribution terms
applicable to the interest held.

See  Note  21  for  information  regarding  the  net  cumulative
unrealized amount of performance-based fee revenues at risk of

83

December 2019 Form 10-K

Table of Contents
Notes to Consolidated Financial Statements

reversal. See Note 13 for information regarding general partner
guarantees,  which  include  potential  obligations  to  return
performance fee distributions previously received.

Other Items

commodities, is presented in the accompanying balance sheets
on a net-by-counterparty basis, when appropriate. Additionally,
the Firm nets the fair value of cash collateral paid or received
against  the  fair  value  amounts  recognized  for  net  derivative
positions executed with the same counterparty under the same
master netting agreement.

Revenues  from  certain  commodities-related  contracts  are
recognized as the promised goods or services are delivered to
the customer.

Fair Value Option

Receivables from contracts with customers are recognized in
Customer and other receivables in the balance sheets when the
underlying performance obligations have been satisfied and the
Firm has the right per the contract to bill the customer. Contract
assets are recognized in Other assets when the Firm has satisfied
its  performance  obligations  but  customer  payment 
is
conditional.  Contract  liabilities  are  recognized  in  Other
liabilities when the Firm has collected payment from a customer
based  on  the  terms  of  the  contract,  but  the  underlying
performance obligations are not yet satisfied.

For contracts with a term of less than one year, incremental costs
to obtain the contract are expensed as incurred. Revenues are
not discounted when payment is expected within one year.

The Firm presents, net within revenues, all taxes assessed by a
governmental authority that are both imposed on and concurrent
with a specific revenue-producing transaction and collected by
the Firm from a customer.

Fair Value of Financial Instruments

Instruments  within  Trading  assets  and  Trading  liabilities  are
measured  at  fair  value,  either  as  required  or  allowed  by
accounting  guidance. These  financial  instruments  primarily
represent  the  Firm’s  trading  and  investment  positions  and
include both cash and derivative products. In addition, securities
classified as AFS are measured at fair value.

Gains and losses on instruments carried at fair value are reflected
in  Trading  revenues,  Investments  revenues  or  Investment
banking  revenues  in  the  income  statements,  except  for AFS
securities  (see  “Investment  Securities—AFS  and  HTM
securities” section herein and Note 6) and derivatives accounted
for as hedges (see “Hedge Accounting” herein and Note 5). 

Interest  income  and  interest  expense  are  recorded  within  the
income statements depending on the nature of the instrument
and related market conventions. When interest is included as a
component  of  the instruments’  fair value, interest  is  included
within Trading revenues or Investments revenues. Otherwise, it
is included within Interest income or Interest expense. Dividend
income is recorded in Trading revenues or Investments revenues
depending on the business activity.

The  fair  value  of  OTC  financial  instruments,  including
derivative  contracts  related  to  financial  instruments  and

The Firm has elected to measure certain eligible instruments at
fair value, including Securities purchased under agreements to
resell,  Loans  and  lending  commitments,  equity  method
investments and certain other assets, Deposits, Securities sold
under agreements to repurchase, Other secured financings and
Borrowings.

Fair Value Measurement—Definition and Hierarchy

Fair value is defined as the price that would be received to sell
an asset or paid to transfer a liability (i.e., the “exit price”) in an
orderly 
the
measurement date.

transaction  between  market  participants  at 

Fair  value  is  a  market-based  measure  considered  from  the
perspective of a market participant rather than an entity-specific
measure.  Therefore,  even  when  market  assumptions  are  not
readily available, assumptions are set to reflect those that the
Firm believes market participants would use in pricing the asset
or liability at the measurement date. Where the Firm manages
a group of financial assets, financial liabilities, and nonfinancial
items accounted for as derivatives on the basis of its net exposure
to either market risks or credit risk, the Firm measures the fair
value of that group of financial instruments consistently with
how market participants would price the net risk exposure at the
measurement date.

In  determining  fair  value,  the  Firm  uses  various  valuation
approaches  and  establishes  a  hierarchy  for  inputs  used  in
measuring fair value that requires the most observable inputs be
used when available.

Observable inputs are inputs that market participants would use
in pricing the asset or liability that were developed based on
market  data  obtained  from  sources  independent  of  the  Firm.
Unobservable inputs are inputs that reflect assumptions the Firm
believes other market participants would use in pricing the asset
or  liability  that  are  developed  based  on  the  best  information
available in the circumstances. The fair value hierarchy is broken
down into three levels based on the observability of inputs as
follows, with Level 1 being the highest and Level 3 being the
lowest level:

Level 1.    Valuations based on quoted prices in active markets
that  the  Firm  has  the  ability  to  access  for  identical  assets  or
liabilities. Valuation adjustments, block discounts and discounts
for entity-specific restrictions that would not transfer to market
participants  are  not  applied  to  Level 1  instruments.  Since

December 2019 Form 10-K

84

Table of Contents
Notes to Consolidated Financial Statements

valuations  are  based  on  quoted  prices  that  are  readily  and
regularly  available  in  an  active  market,  valuation  of  these
products does not entail a significant degree of judgment.

Level 2.    Valuations  based  on  one  or  more  quoted  prices  in
markets that are not active or for which all significant inputs are
observable, either directly or indirectly.

Level 3.    Valuations based on inputs that are unobservable and
significant to the overall fair value measurement.

The availability of observable inputs can vary from product to
product and is affected by a wide variety of factors, including
the  type  of  product,  whether  the  product  is  new  and  not  yet
established in the marketplace, the liquidity of markets and other
characteristics  particular  to  the  product.  To  the  extent  that
valuation is based on models or inputs that are less observable
or unobservable in the market, the determination of fair value
requires more judgment. Accordingly, the degree of judgment
exercised by the Firm in determining fair value is greatest for
instruments categorized in Level 3 of the fair value hierarchy.

The Firm considers prices and inputs that are current as of the
measurement  date,  including  during  periods  of  market
dislocation. In periods of market dislocation, the observability
of prices and inputs may be reduced for many instruments. This
condition  could  cause  an  instrument  to  be  reclassified  from
Level 1 to Level 2 or from Level 2 to Level 3 of the fair value
hierarchy.

In certain cases, the inputs used to measure fair value may fall
into different levels of the fair value hierarchy. In such cases,
the total fair value amount is disclosed in the level appropriate
for the lowest level input that is significant to the total fair value
of the asset or liability.

Valuation Techniques

Many cash instruments and OTC derivative contracts have bid
and ask prices that can be observed in the marketplace. Bid prices
reflect the highest price that a party is willing to pay for an asset.
Ask prices represent the lowest price that a party is willing to
accept for an asset. The Firm carries positions at the point within
the bid-ask range that meets its best estimate of fair value. For
offsetting positions in the same financial instrument, the same
price within the bid-ask spread is used to measure both the long
and short positions.

Fair  value  for  many  cash  instruments  and  OTC  derivative
contracts is derived using pricing models. Pricing models take
into  account  the  contract  terms,  as  well  as  multiple  inputs,
including, where applicable, commodity prices, equity prices,
rate  yield  curves,  credit  curves,  correlation,
interest 
creditworthiness  of  the  counterparty,  creditworthiness  of  the
Firm, option volatility and currency rates.

Where appropriate, valuation adjustments are made to account
for various factors such as liquidity risk (bid-ask adjustments),
credit  quality,  model  uncertainty  and  concentration  risk  and
funding. Adjustments  for  liquidity  risk  adjust  model-derived
mid-market  amounts  of  Level 2  and  Level 3  financial
instruments  for  the  bid-mid  or  mid-ask  spread  required  to
properly reflect the exit price of a risk position. Bid-mid and
mid-ask spreads are marked to levels observed in trade activity,
broker quotes or other external third-party data. Where these
spreads are unobservable for the particular position in question,
spreads are derived from observable levels of similar positions.

The  Firm  applies  credit-related  valuation  adjustments  to  its
Borrowings for which the fair value option was elected and to
OTC derivatives. The Firm considers the impact of changes in
its own credit spreads based upon observations of the secondary
bond  market  spreads  when  measuring  the  fair  value  for
Borrowings.

For OTC derivatives, the impact of changes in both the Firm’s
and  the  counterparty’s  credit  rating  is  considered  when
measuring fair value. In determining the expected exposure, the
Firm  simulates  the  distribution  of  the  future  exposure  to  a
counterparty, then applies market-based default probabilities to
the future exposure, leveraging external third-party CDS spread
data.  Where  CDS  spread  data  are  unavailable  for  a  specific
counterparty, bond market spreads, CDS spread data based on
the counterparty’s credit rating or CDS spread data that reference
a  comparable  counterparty  may  be  utilized.  The  Firm  also
considers collateral held and legally enforceable master netting
agreements that mitigate its exposure to each counterparty.

Adjustments for model uncertainty are taken for positions whose
underlying  models  are  reliant  on  significant  inputs  that  are
neither  directly  nor  indirectly  observable,  hence  requiring
reliance on established theoretical concepts in their derivation.
These adjustments are derived by making assessments of the
possible degree of variability using statistical approaches and
market-based information where possible.

The Firm may apply concentration adjustments to certain of its
OTC derivative portfolios to reflect the additional cost of closing
out  a  particularly  large  risk  exposure. Where  possible,  these
adjustments  are  based  on  observable  market information, but
in many instances, significant judgment is required to estimate
the costs of closing out concentrated risk exposures due to the
lack of liquidity in the marketplace.

The Firm applies an FVA in the fair value measurements of OTC
uncollateralized  or  partially  collateralized  derivatives  and  in
collateralized derivatives where the terms of the agreement do
not permit the reuse of the collateral received. In general, FVA
reflects a market funding risk premium inherent in the noted
derivative instruments. The methodology for measuring FVA
leverages the Firm’s existing credit-related valuation adjustment
calculation  methodologies,  which  apply  to  both  assets  and
liabilities.

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Notes to Consolidated Financial Statements

See Note 3 for a description of valuation techniques applied to
the major categories of financial instruments measured at fair
value.

Assets  and  Liabilities  Measured  at  Fair  Value  on  a  Non-
recurring Basis

Certain of the Firm’s assets and liabilities are measured at fair
value on a non-recurring basis. The Firm incurs losses or gains
for any adjustments of these assets or liabilities to fair value.

For  assets  and  liabilities  measured  at  fair  value  on  a  non-
recurring  basis,  fair  value  is  determined  by  using  various
valuation  approaches.  The  same  hierarchy  for  inputs  as
described above, which requires that observable inputs be used
when available, is used in measuring fair value for these items.

For further information on financial assets and liabilities that
are measured at fair value on a recurring and non-recurring basis,
see Note 3.

Offsetting of Derivative Instruments

In connection with its derivative activities, the Firm generally
enters into master netting agreements and collateral agreements
with its counterparties. These agreements provide the Firm with
the right, in the event of a default by the counterparty, to net a
counterparty’s rights and obligations under the agreement and
to liquidate and set off cash collateral against any net amount
owed by the counterparty. Derivatives with enforceable master
netting agreements are reported net of cash collateral received
and posted.

However, in certain circumstances, the Firm may not have such
an agreement in place; the relevant insolvency regime may not
support the enforceability of the master netting agreement or
collateral  agreement;  or  the  Firm  may  not  have  sought  legal
advice to support the enforceability of the agreement. In cases
where  the  Firm  has  not  determined  an  agreement  to  be
enforceable, the related amounts are not offset (see Note 5).

The  Firm’s  policy  is  generally  to  receive  securities  and  cash
posted as collateral (with rights of rehypothecation), irrespective
of the enforceability determination regarding the master netting
and collateral agreement. In certain cases, the Firm may agree
for such collateral to be posted to a third-party custodian under
a  control  agreement  that  enables  it  to  take  control  of  such
collateral  in  the  event  of  a  counterparty  default.  The
enforceability  of  the  master  netting  agreement  is  taken  into
account in the Firm’s risk management practices and application
of counterparty credit limits.

For information related to offsetting of derivatives and certain
collateralized transactions, see Notes 5 and 7, respectively.

December 2019 Form 10-K

86

Hedge Accounting

The  Firm  applies  hedge  accounting  using  various  derivative
financial instruments for the following types of hedges: hedges
of changes in the fair value of assets and liabilities due to the
risk  being  hedged  (fair  value  hedges);  and  hedges  of  net
investments in foreign operations whose functional currency is
different from the reporting currency of the Parent Company
(net  investment  hedges).  These  financial  instruments  are
included within Trading assets—Derivative and other contracts
or  Trading  liabilities—Derivative  and  other  contracts  in  the
balance  sheets.  For  hedges  where  hedge  accounting  is  being
applied,  the  Firm  performs  effectiveness  testing  and  other
procedures.

Fair Value Hedges—Interest Rate Risk

The Firm’s designated fair value hedges consist of interest rate
swaps designated as hedges of changes in the benchmark interest
rate of certain fixed rate AFS securities and senior borrowings.
In the fourth quarter of 2019, the Firm also began designating
interest  rate  swaps  as  fair  value  hedges  of  changes  in  the
benchmark interest rate of certain fixed rate deposits. The Firm
is permitted to hedge the full, or part of the, contractual term of
the  hedged  instrument.  The  Firm  uses  regression  analysis  to
perform an ongoing prospective and retrospective assessment
of the effectiveness of these hedging relationships. A hedging
relationship is deemed effective if the change in fair value of
the hedging instrument (derivative) and the change in fair value
of the hedged item (AFS security, deposit liability or borrowing),
due to changes in the benchmark interest rate, offset within a
range  of  80%  to  125%.  The  Firm  considers  the  impact  of
valuation adjustments related to counterparty credit spreads and
its own credit spreads to determine whether they would cause
the hedging relationship to be ineffective.

For qualifying fair value hedges of benchmark interest rates, the
change in the fair value of the derivative, offset by the change
in  the  fair  value  attributable  to  the  change  in  the  benchmark
interest rate risk of the hedged asset (liability), is recognized in
earnings  each  period  as  a  component  of  Interest  income
(expense). For AFS securities, the change in fair value of the
hedged item due to changes other than the risk being hedged
will continue to be reported in OCI. When a derivative is de-
designated as a hedge, any basis adjustment remaining on the
hedged asset (liability) is amortized to Interest income (expense)
over the remaining life of the asset (liability) using the effective
interest method.

Net Investment Hedges

The Firm uses forward foreign exchange contracts to manage a
portion of the currency exposure relating to its net investments
in foreign operations. To the extent that the notional amounts of
the hedging instruments equal the portion of the investments
being hedged and the underlying exchange rate of the derivative
hedging instrument is the same as the exchange rate between

Table of Contents
Notes to Consolidated Financial Statements

the  functional  currency  of  the  investee  and  the  intermediate
parent  entity’s  functional  currency,  it  is  considered  to  be
perfectly  effective,  with  no  income  statement  recognition.  If
these exchange rates are not the same, the Firm uses regression
analysis to assess the prospective and retrospective effectiveness
of  the  hedge  relationships.  The  gain  or  loss  from  revaluing
hedges of net investments in foreign operations at the spot rate
is  reported  within AOCI. The  forward  points  on  the  hedging
instruments are excluded from hedge effectiveness testing and
changes  in  the  fair  value  of  this  excluded  component  are
recorded currently in Interest income.

For further information on derivative instruments and hedging
activities, see Note 5.

Investment  Securities—Available-for-Sale  and  Held-to-
Maturity

AFS securities are reported at fair value in the balance sheets
with unrealized gains and losses reported in AOCI, net of tax,
unless  such  securities  are  designated  in  a  fair  value  hedge.
Interest  income,  including  amortization  of  premiums  and
accretion  of  discounts,  is  included  in  Interest  income  in  the
income statements. Realized gains and losses on sales of AFS
securities  are  classified  within  Other  revenues  in  the  income
statements (see Note 6). The Firm utilizes the “first-in, first-out”
method as the basis for determining the cost of AFS securities.

HTM securities are reported at amortized cost in the balance
sheets. Interest income, including amortization of premiums and
accretion of discounts on HTM securities, is included in Interest
income in the income statements.

OTTI

AFS securities and HTM securities with a current fair value less
than  their  amortized  cost  are  analyzed  as  part  of  the  Firm’s
periodic assessment of temporary versus OTTI at the individual
security level. A temporary impairment is recognized in AOCI
for AFS securities. OTTI is recognized in the income statements
with the exception of the non-credit portion related to a security
that the Firm does not intend to sell and is not likely to be required
to sell, which is recognized in AOCI.

For AFS securities that the Firm either has the intent to sell or
that the Firm is likely to be required to sell before recovery of
its amortized cost basis, the impairment is considered OTTI.

For those AFS securities that the Firm does not have the intent
to sell or is not likely to be required to sell, and for all HTM
securities, the Firm evaluates whether it expects to recover the
entire amortized cost basis of the security. If the Firm does not
expect to recover the entire amortized cost of those AFS or HTM
securities,  the  impairment  is  considered  OTTI,  and  the  Firm
determines what portion of the impairment relates to a credit
loss and what portion relates to non-credit factors.

A credit loss exists if the present value of cash flows expected
to  be  collected  (discounted  at  the  implicit  interest  rate  at
acquisition of the security or discounted at the effective yield
for  securities 
in  prepayment
assumptions) is less than the amortized cost basis of the security.
Changes in prepayment assumptions alone are not considered
to result in a credit loss.

incorporate  changes 

that 

When  determining  if  a  credit  loss  exists,  the  Firm  considers
relevant information, including:

• the length of time and the extent to which the fair value has

been less than the amortized cost basis;

• adverse  conditions  specifically  related  to  the  security,  its

industry or geographic area;

• changes in the financial condition of the issuer of the security,
the presence of explicit or implicit guarantees of repayment
by the U.S. Government for U.S. Government and Agency
securities  or,  in  the  case  of  an  asset-backed  debt  security,
changes  in  the  financial  condition  of  the  underlying  loan
obligors;

• the historical and implied volatility of the fair value of the

security;

• the payment structure of the debt security and the likelihood
of the issuer being able to make payments that increase in the
future;

• failure of the issuer of the security to make scheduled interest

or principal payments;

• the current rating and any changes to the rating of the security

by a rating agency;

• recoveries or additional declines in fair value after the balance

sheet date.

When  estimating  the  present  value  of  expected  cash  flows,
information utilized includes the remaining payment terms of
the security, prepayment speeds, financial condition of the 
issuer(s),  expected  defaults  and  the  value  of  any  underlying
collateral.

Loans

The Firm accounts for loans based on the following categories:
loans held for investment; loans held for sale; and loans at fair
value.

Loans Held for Investment

Loans held for investment are reported at outstanding principal
adjusted for any charge-offs, the allowance for loan losses, any
unamortized deferred fees or costs for originated loans, and any
unamortized premiums or discounts for purchased loans.

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Notes to Consolidated Financial Statements

Interest Income.    Interest income on performing loans held for
investment is accrued and recognized as interest income at the
contractual  rate  of  interest.  Purchase  price  discounts  or
premiums,  as  well  as  net  deferred  loan  fees  or  costs,  are
amortized into interest income over the life of the loan to produce
a level rate of return.

Allowance  for  Loan  Losses.    The  allowance  for  loan  losses
represents  an  estimate  of  probable  losses  related  to  loans
specifically identified for impairment in addition to the probable
losses inherent in the held-for-investment loan portfolio.

The  Firm  utilizes  the  U.S.  banking  agencies’  definition  of
criticized  exposures,  which  consist  of  the  Special  Mention,
Substandard,  Doubtful  and  Loss  categories  as  credit  quality
indicators.  For  further  information  on  the  credit  quality
indicators, see Note 8. Substandard loans are regularly reviewed
for  impairment.  Factors  considered  by  management  when
determining impairment include payment status, fair value of
collateral, and probability of collecting scheduled principal and
interest payments when due. The impairment analysis required
depends  on  the  nature  and  type  of  loans.  Loans  classified  as
Doubtful or Loss are considered impaired.

There are two components of the allowance for loan losses: the
specific  allowance  component  and  the  inherent  allowance
component.

The  specific  allowance  component  of  the  allowance  for  loan
losses is used to estimate probable losses for exposures that have
been specifically identified for impairment analysis by the Firm
and  determined  to  be  impaired.  When  a  loan  is  specifically
identified for impairment, the impairment is measured based on
the present value of expected future cash flows discounted at
the loan’s effective interest rate or the observable market price
of the loan or the fair value of the collateral if the loan is collateral
dependent. A loan is collateral dependent if the repayment of
the loan is expected to be provided solely by the sale or operation
of the underlying collateral. If the present value of the expected
future cash flows (or alternatively, the observable market price
of the loan or the fair value of the collateral) is less than the
recorded investment in the loan, then the Firm recognizes an
allowance and a charge to the provision for loan losses within
Other revenues.

The inherent allowance component of the allowance for loan
losses represents an estimate of the probable losses inherent in
the loan portfolio and includes loans that have not been identified
as impaired. The Firm maintains methodologies by loan product
for calculating an allowance for loan losses that estimates the
inherent losses in the loan portfolio. Generally, inherent losses
in  the  portfolio  for  non-impaired  loans  are  estimated  using
statistical  analysis  and  judgment  regarding  the  exposure  at
default, the probability of default and the loss given default.

Qualitative  and  environmental  factors  such  as  economic  and
business  conditions,  nature  and  volume  of  the  portfolio,  and

December 2019 Form 10-K

88

lending terms and volume and severity of past due loans may
also be considered in the calculations. The allowance for loan
losses  is  maintained  at  a  level  to  ensure  that  it  is  reasonably
likely  to  adequately  absorb  the  estimated  probable  losses
inherent  in  the  portfolio.  When  the  Firm  recognizes  an
allowance, there is also a charge to the provision for loan losses
within Other revenues.

Troubled  Debt  Restructurings.    The  Firm  may  modify  the
terms of certain loans for economic or legal reasons related to
a  borrower’s  financial  difficulties  by  granting  one  or  more
concessions that the Firm would not otherwise consider. Such
modifications are accounted for and reported as a TDR. A loan
that has been modified in a TDR is generally considered to be
impaired and is evaluated for the extent of impairment using the
Firm’s  specific  allowance  methodology.  TDRs  are  also
generally classified as nonaccrual and may be returned to accrual
status only after considering the borrower’s sustained repayment
performance for a reasonable period.

Nonaccrual  Loans.    The  Firm  places  loans  on  nonaccrual
status if principal or interest is past due for a period of 90 days
or more or payment of principal or interest is in doubt unless
the obligation is well-secured and in the process of collection.
A loan is considered past due when a payment due according to
the contractual terms of the loan agreement has not been remitted
by the borrower. Substandard loans, if identified as impaired,
are categorized as nonaccrual, as are loans classified as Doubtful
or Loss.

Payments received on nonaccrual loans held for investment are
applied  to  principal  if  there  is  doubt  regarding  the  ultimate
collectibility  of  principal.  If  collection  of  the  principal  of
nonaccrual loans held for investment is not in doubt, interest
income is realized on a cash basis. If neither principal nor interest
collection  is  in  doubt,  loans  are  placed  on  accrual  status  and
interest  income  is  recognized  using  the  effective  interest
method. Loans that are on nonaccrual status may not be restored
to accrual status until all delinquent principal and/or interest has
been brought current after a reasonable period of performance,
typically a minimum of six months.

Charge-offs.    The Firm charges off a loan in the period that it
is deemed uncollectible and records a reduction in the allowance
for loan losses and the balance of the loan. In general, any portion
of  the  recorded  investment  in  a  collateral  dependent  loan
(including  any  capitalized  accrued  interest,  net  deferred  loan
fees or costs, and unamortized premium or discount) in excess
of  the  fair  value  of  the  collateral  that  can  be  identified  as
uncollectible,  and  is  therefore  deemed  a  confirmed  loss,  is
charged off against the allowance for loan losses. In addition,
for loan transfers from loans held for investment to loans held
for sale, at the time of transfer any reduction in the loan value
is reflected as a charge-off of the recorded investment, resulting
in a new cost basis.

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Notes to Consolidated Financial Statements

Lending  Commitments.    The  Firm  records  the  liability  and
related expense for the credit exposure related to commitments
to fund loans that will be held for investment in a manner similar
to  outstanding  loans  discussed  above.  The  analysis  also
incorporates a credit conversion factor, which is the expected
utilization  of  the  undrawn  commitment.  The  liability  and
expense for the credit exposure are recorded in Other liabilities
and  accrued  expenses  in  the  balance  sheets,  and  Other  non-
interest  expenses  in  the  income  statements,  respectively.  For
more information regarding loan commitments, standby letters
of credit and financial guarantees, see Note 13.

Loans Held for Sale

Loans held for sale are measured at the lower of cost or fair
value, with valuation changes recorded in Other revenues. The
Firm determines the valuation allowance on an individual loan
basis,  except  for  residential  mortgage  loans  for  which  the
valuation allowance is determined at the loan product level. Any
decreases in fair value below the initial carrying amount and
any recoveries in fair value up to the initial carrying amount are
recorded in Other revenues. Increases in fair value above initial
carrying value are not recognized.

Interest income on loans held for sale is accrued and recognized
based on the contractual rate of interest. Loan origination fees
or costs and purchase price discounts or premiums are deferred
as an adjustment to the loan’s cost basis until the related loan is
sold and, as such, are included in the periodic determination of
the lower of cost or fair value adjustments and the gain or loss
recognized at the time of sale.

Lending Commitments. Commitments to fund mortgage loans
held for sale are derivatives and are reported in Trading assets
or  Trading  liabilities  in  the  balance  sheets  with  an  offset  to
Trading revenues in the income statements.

For commitments to fund non-mortgage loans the Firm records
the liability and related expense for the fair value exposure below
cost  of  such  commitments  in  Other  liabilities  and  accrued
expenses in the balance sheets with an offset to Other revenues
in the income statements.

Loans and lending commitments held for sale are subject to the
nonaccrual  policies  described  above  in  the  Loans  Held  for
Investment—Nonaccrual  Loans  section.  Because  loans  and
lending commitments held for sale are recognized at the lower
of cost or fair value, the allowance for loan losses and charge-
off policies does not apply to these loans.

Loans at Fair Value

Loans for which the fair value option is elected are carried at
fair value, with changes in fair value recognized in earnings.
Loans  carried  at  fair  value  are  not  evaluated  for  purposes  of
recording an allowance for loan losses. For further information

on loans carried at fair value and classified as Trading assets and
Trading liabilities, see Note 3.

Lending Commitments. The Firm records the liability and related
expense for the fair value exposure related to commitments to
fund loans that will be measured at fair value. The liability is
recorded  in  Trading  liabilities  in  the  balance  sheets,  and  the
expense  is  recorded  in  Trading  revenues  in  the  income
statements.

Loans and lending commitments at fair value are subject to the
nonaccrual  policies  described  above  in  the  Loans  Held  for
Investment—Nonaccrual  Loans  section.  Because  such  loans
and  lending  commitments  are  reported  at  fair  value,  the
allowance for loan losses and charge-off policies do not apply
to these loans.

For further information on loans, see Note 8.

Transfers of Financial Assets

Transfers of financial assets are accounted for as sales when the
Firm has relinquished control over the transferred assets. Any
related gain or loss on sale is recorded in Net revenues. Transfers
that are not accounted for as sales are treated as collateralized
financings. Securities borrowed or purchased under agreements
to  resell  and  securities  loaned  or  sold  under  agreements  to
repurchase are treated as collateralized financings (see Note 7).

Securities  purchased  under  agreements  to  resell  (“reverse
repurchase agreements”) and Securities sold under agreements
to  repurchase  (“repurchase  agreements”)  are  carried  in  the
balance  sheets  at  the  amount  of  cash  paid  or  received,  plus
accrued  interest,  except  for  certain  reverse  repurchase  and
repurchase agreements for which the Firm has elected the fair
value  option  (see  Note  4).  Where  appropriate,  repurchase
agreements and reverse repurchase agreements with the same
counterparty are reported on a net basis. Securities borrowed
and  securities  loaned  are  recorded  at  the  amount  of  cash
collateral advanced or received.

In  instances  where  the  Firm  is  the  lender  in  securities-for-
securities transactions and is permitted to sell or repledge these
securities, the fair value of the collateral received is reported in
Trading assets, and the related obligation to return the collateral
is reported in Trading liabilities in the balance sheets. Securities-
for-securities transactions where the Firm is the borrower are
not included in the balance sheets.

Premises, Equipment and Software Costs

Premises, equipment and software costs consist of buildings,
leasehold  improvements,  furniture,  fixtures,  computer  and
communications  equipment,  power  generation  assets  and
software (externally purchased and developed for internal use).
Premises, equipment and software costs are stated at cost less
accumulated depreciation and amortization and are included in

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Notes to Consolidated Financial Statements

in 

Other  assets 
the  balance  sheets.  Depreciation  and
amortization are provided by the straight-line method over the
estimated useful life of the asset.

Estimated Useful Lives of Assets

in years

Buildings

Leasehold improvements—Building

Leasehold improvements—Other

Furniture and fixtures

Computer and communications equipment

Power generation assets

Software costs

Estimated Useful Life

39

term of lease to 25

term of lease to 15

7

3 to 9

15 to 29

2 to 10

Premises,  equipment  and  software  costs  are  tested  for
impairment  whenever  events  or  changes  in  circumstances
suggest  that  an  asset’s  carrying  value  may  not  be  fully
recoverable.

Goodwill and Intangible Assets

The Firm tests goodwill for impairment on an annual basis and
on an interim basis when certain events or circumstances exist.
The  Firm  tests  goodwill  for  impairment  at  the  reporting  unit
level, which is generally at the level of or one level below its
business segments. For both the annual and interim tests, the
Firm  has  the  option  to  either  (i) perform  a  quantitative
impairment test or (ii) first perform a qualitative assessment to
determine whether it is more likely than not that the fair value
of a reporting unit is less than its carrying amount, in which case
the quantitative test would be performed.

When  performing  a  quantitative  impairment  test,  the  Firm
compares  the  fair  value  of  a  reporting  unit  with  its  carrying
amount, including goodwill. If the fair value of the reporting
unit is less than its carrying amount, the goodwill impairment
loss is equal to the excess of the carrying value over the fair
value, limited to the carrying amount of goodwill allocated to
that reporting unit.

The estimated fair values of the reporting units are derived based
on valuation techniques the Firm believes market participants
would use for each respective reporting unit. The estimated fair
values are generally determined by utilizing a discounted cash
flow methodology or methodologies that incorporate price-to-
book  and  price-to-earnings  multiples  of  certain  comparable
companies.

Intangible assets are amortized over their estimated useful lives
and  are  reviewed  for  impairment  on  an  interim  basis  when
impairment  indicators  are  present.  Impairment  losses  are
recorded within Other expenses in the income statements.

Earnings per Common Share

Basic EPS is computed by dividing earnings available to Morgan
Stanley common shareholders by the weighted average number

December 2019 Form 10-K

90

of common shares outstanding for the period. Earnings available
to Morgan Stanley common shareholders represents net income
applicable  to  Morgan  Stanley  reduced  by  preferred  stock
dividends. Common shares outstanding include common stock
and  vested  RSUs  where  recipients  have  satisfied  either  the
explicit  vesting  terms  or  retirement-eligibility  requirements.
Diluted  EPS  reflects  the  assumed  conversion  of  all  dilutive
securities.

Share-based  awards  that  pay  dividend  equivalents  subject  to
vesting are included in diluted shares outstanding (if dilutive)
under the treasury stock method.

The Firm has granted PSUs that vest and convert to shares of
common stock only if predetermined performance and market
goals are satisfied. Since the issuance of the shares is contingent
upon  the  satisfaction  of  certain  conditions,  the  PSUs  are
included in diluted EPS based on the number of shares (if any)
that would be issuable if the end of the reporting period was the
end of the contingency period.

For further information on diluted earnings (loss) per common
share, see Note 16 to the financial statements.

Deferred Compensation

Stock-Based Compensation

The  Firm  measures  compensation  expense  for  stock-based
awards at fair value. The Firm determines the fair value of RSUs
(including  PSUs  with  non-market  performance  conditions)
based on the grant-date fair value of its common stock, measured
as  the  volume-weighted  average  price  on  the  date  of  grant
(“VWAP”). The fair value of RSUs not entitled to dividends
until conversion is measured at VWAP reduced by the present
value of dividends expected to be paid on the underlying shares
prior to scheduled conversion date. PSUs that contain market-
based  conditions  are  valued  using  a  Monte  Carlo  valuation
model.

Compensation expense is recognized over the relevant vesting
period  for  each  separate  vesting  portion  of  the  award.
Compensation expense for awards with performance conditions
is recognized based on the probable outcome of the performance
condition  at  each  reporting  date.  Compensation  expense  for
awards with market-based conditions is recognized irrespective
of the probability of the market condition being achieved and is
not  reversed  if  the  market  condition  is  not  met.  The  Firm
accounts for forfeitures as they occur.

Stock-based  awards  generally  contain  claw  back  and
cancellation  provisions. Certain  awards  provide  the  Firm
discretion to claw back or cancel all or a portion of the award
under specified circumstances. Compensation expense for those
awards is adjusted for changes in the fair value of the Firm’s
common stock or the relevant model valuation, as appropriate,
until conversion, exercise or expiration.

Table of Contents
Notes to Consolidated Financial Statements

Employee Stock Trusts

Carried Interest Compensation

In connection with certain stock-based compensation plans, the
Firm, at its discretion, has established employee stock trusts to
provide common stock voting rights to certain employees who
hold outstanding RSUs. The assets of the employee stock trusts
are  consolidated  with  those  of  the  Firm  and  are  generally
accounted for in a manner similar to treasury stock, where the
shares of common stock outstanding reported in Common stock
issued to employee stock trusts are offset by an equal amount
reported in Employee stock trusts in the balance sheets.

The  Firm  uses  the  grant-date  fair  value  of  stock-based
compensation as the basis for recognition of the assets in the
employee stock trusts. Subsequent changes in the fair value are
not recognized as the Firm’s stock-based compensation plans
must be settled by delivery of a fixed number of shares of the
Firm’s common stock.

Deferred Cash-Based Compensation

Compensation expense for deferred cash-based compensation
plans  is  calculated  based  on  the  notional  value  of  the  award
granted, adjusted for changes in the fair value of the referenced
investments  that  employees  select.  Compensation  expense  is
recognized over the relevant vesting period for each separate
vesting portion of deferred awards. Compensation expense for
these  awards  is  adjusted  based  on  notional  earnings  of  the
referenced investments until distribution.

The Firm invests directly, as a principal, in financial instruments
or other investments to economically hedge its obligations under
its  deferred  cash-based  compensation  plans.  Changes  in  the
value  of  such  investments  made  by  the  Firm  are  recorded  in
Trading revenues and Investments revenues. Although changes
in compensation expense resulting from changes in the fair value
of the referenced investments will generally be offset by changes
in  the  fair  value  of  investments  made  by  the  Firm,  there  is
typically a timing difference between the immediate recognition
of gains and losses on the Firm’s investments and the deferred
recognition  of  the  related  compensation  expense  over  the
vesting period.

Retirement-Eligible Employee Compensation

For  year-end  stock-based  awards  and  deferred  cash-based
compensation awards anticipated to be granted to retirement-
eligible  employees  under  award  terms  that  do  not  contain  a
future service requirement, the Firm accrues the estimated cost
of the awards over the course of the calendar year preceding the
grant  date,  which  reflects  the  period  over  which  the
compensation is earned.

The Firm generally recognizes compensation expense for any
portion of carried interest (both realized and unrealized) that is
allocated to employees. For information on performance-based
fees in the form of carried interest, which are directly related to
carried  interest  compensation,  see  “Revenue  Recognition—
Carried Interest” herein.

Income Taxes

Deferred tax assets and liabilities are recorded based upon the
temporary  differences  between  the  financial  statement  and
income tax bases of assets and liabilities using currently enacted
tax  rates  in  effect  for  the  year  in  which  the  differences  are
expected  to  reverse.  The  effect  of  a  change  in  tax  rates  on
deferred tax assets and liabilities is recognized in income tax
expense (benefit) in the period that includes the enactment date.
Such effects are recorded in income tax expense (benefit) from
continuing operations regardless of where deferred taxes were
originally recorded.

The Firm recognizes net deferred tax assets to the extent that it
believes these assets are more likely than not to be realized. In
making such a determination, the Firm considers all available
positive  and  negative  evidence,  including  future  reversals  of
existing taxable temporary differences, projected future taxable
income, tax planning strategies and results of recent operations.
When performing the assessment, the Firm considers all types
of deferred tax assets in combination with each other, regardless
of the origin of the underlying temporary difference. If a deferred
tax asset is determined to be unrealizable, a valuation allowance
is established. If the Firm subsequently determines that it would
be  able  to  realize  deferred  tax  assets  in  excess  of  their  net
recorded amount, it would make an adjustment to the deferred
tax asset valuation allowance, which would reduce the provision
for income taxes.

The  Firm  recognizes  tax  expense  associated  with  GILTI
included in the Tax Cuts and Jobs Act (“Tax Act”) as it is incurred
as part of the current income taxes to be paid or refunded for the
current period.

Uncertain tax positions are recorded on the basis of a two-step
process,  whereby  (i)  the  Firm  determines  whether  it  is  more
likely than not that the tax positions will be sustained on the
basis of the technical merits of the position and (ii) for those tax
positions that meet this threshold, the Firm recognizes the largest
amount of tax benefit that is more likely than not to be realized
upon ultimate settlement with the related tax authority. Interest
and penalties related to unrecognized tax benefits are recognized
as a component of the provision for income taxes.

Foreign Currencies

Assets  and  liabilities  of  operations  with  non-U.S.  dollar
functional  currencies  are  translated  at  year-end  rates  of

91

December 2019 Form 10-K

Table of Contents
Notes to Consolidated Financial Statements

exchange.  Gains  or  losses  resulting  from  translating  foreign
currency financial statements, net of hedge gains or losses and
related tax effects, are reflected in AOCI in the balance sheets.
Gains  or  losses  resulting  from  remeasurement  of  foreign
currency transactions are included in net income, and amounts
recognized in the income statement are translated at the rate of
exchange on the respective date of recognition for each amount.

redesignated hedging relationships. This update did not impact
the Firm’s pre-existing hedges.

Accounting Update Adopted in 2018

See Note 16 for a summary of the Retained earnings impact of
this adoption. 

Accounting Updates Adopted in 2019

Revenue Recognition

The  Firm  adopted  Revenues  from  Contracts  with  Customers
using 
the  modified  retrospective  method.  Our  revenue
recognition policies are reflective of this update since adoption,
while 2017 revenues and expenses remain as presented under
the prior accounting policy.

The  more  significant  differences  to  the  accounting  policy  in
place prior to adoption were: (i) the presentation of certain costs
related to underwriting and advisory activities in that such costs
were recorded net of Investment Banking revenues versus the
current  practice  of  recording  the  costs  in  the  relevant  non-
compensation expense line item; (ii) the presentation of certain
costs related to the selling and distribution of investment funds
in  that  such  costs  were  recorded  net  of  Asset  Management
revenues versus the current practice of recording the costs in the
relevant  non-compensation  expense 
the
recognition  of  certain  performance-based  fees  from  fund
management activities not in the form of carried interest that
were  recognized  quarterly  versus  the  current  practice  of
deferring  the  revenues  until  the  fees  are  not  probable  of  a
significant reversal, and; (iv) the timing of the recognition of
advisory fees in that such fees were recorded when realizable
versus the current practice of recognizing the fees as advice is
provided to the client, based on the estimated progress of work
and when the revenue is not probable of a significant reversal.

item;  (iii) 

line 

See Note 16 for a summary of the Retained earnings impact of
these adoptions. 

Leases

Upon the adoption of Leases, the Firm began recognizing in the
balance sheet leases with terms exceeding one year as right-of-
use (“ROU”) assets and corresponding liabilities. The adoption
resulted in an increase to Retained earnings of approximately
$63  million,  net  of  tax,  related  to  deferred  revenue  from
previously recorded sale-leaseback transactions. At transition
on January 1, 2019, the adoption also resulted in a balance sheet
gross-up of approximately $4 billion reflected in Other assets
and Other liabilities and accrued expenses. See Note 10 for lease
disclosures, including amounts reflected in the December 31,
2019 balance sheet. Prior period amounts were not restated.

As allowed by the guidance, the Firm elected not to reassess the
following at transition: whether existing contracts are or contain
leases;  and  for  existing  leases,  lease  classification  and  initial
direct  costs.  In  addition,  the  Firm  continues  to  account  for
existing land easements as service contracts.

Both at transition and for new leases thereafter, ROU assets and
lease  liabilities  are  initially  recognized  based  on  the  present
value of the future minimum lease payments over the lease term,
including  non-lease  components  such  as  fixed  common  area
maintenance costs and other fixed costs such as real estate taxes
and insurance.

The  discount  rates  used  in  determining  the  present  value  of
leases are the Firm’s incremental borrowing rates, developed
based upon each lease’s term and currency of payment. The lease
term includes options to extend or terminate the lease when it
is reasonably certain that the Firm will exercise that option. For
operating leases, the ROU assets also include any prepaid lease
payments and initial direct costs incurred and are reduced by
lease incentives. For these leases, lease expense is recognized
on a straight-line basis over the lease term if the ROU asset has
not been impaired or abandoned.

Derivatives and Hedging (ASU 2018-16)

The amendments in this update permit use of the OIS rate based
on the Secured Overnight Financing Rate as a U.S. benchmark
interest rate for hedge accounting purposes. The Firm adopted
this  update  on  a  prospective  basis  for  qualifying  new  or

December 2019 Form 10-K

92

Table of Contents
Notes to Consolidated Financial Statements

3. Fair Values

Recurring Fair Value Measurements

Assets and Liabilities Measured at Fair Value on a Recurring
Basis

$ in millions

Assets at fair value

Trading assets:

U.S. Treasury and
agency securities

Other sovereign
government
obligations

State and municipal

securities

MABS

Loans and lending
commitments2

Corporate and other

debt

Corporate equities3

Derivative and other

contracts:

Interest rate

Credit

Foreign exchange

Equity

Commodity and

other
Netting1

Total derivative and
other contracts

Investments4

Physical

commodities
Total trading assets4

Investment securities

—AFS

Securities purchased

under agreements to
resell

Total assets at fair

value

At December 31, 2019

At December 31, 2019

Level 1

Level 2

Level 3 Netting1

Total

$ in millions

Level 1

Level 2

Level 3 Netting1

Total

$ 36,866 $ 28,992 $

22 $

— $ 65,880

23,402

4,347

5

1

438

2,790

1,690

—

—

—

6,253

5,073

— 22,124

1,396

—

—

—

—

—

27,754

2,791

2,128

11,326

23,520

123,942

652

97

— 124,691

1,265

182,977

1,239

— 185,481

—

15

6,658

64,260

1,219

48,927

654

145

922

1,079

7,255

2,924

—

—

—

—

7,312

64,420

51,068

11,258

(2,794)

(235,947)

(993)

(47,804)

(287,538)

$

— $ 1,920 $

179 $

— $

2,099

Liabilities at fair value

Deposits

Trading liabilities:

U.S. Treasury and
agency securities

Other sovereign
government
obligations

Corporate and other

debt

Derivative and other

contracts:

Interest rate

Credit

Foreign exchange

Equity

Commodity and

other
Netting1

Total derivative and
other contracts

Securities sold under

agreements to
repurchase

11,191

34

21,837

1,332

—

7,410

Corporate equities3

63,002

79

—

1

—

36

462

530

176

—

11,225

—

—

—

23,170

7,410

63,117

— 172,631

—

—

—

—

7,921

67,655

52,868

9,624

1,144

171,025

—

6

7,391

67,473

1,200

49,062

2,606

1,194

7,118

1,312

(2,794) (235,947)

(993)

(42,531)

(282,265)

750

66,122

4,093

(42,531)

28,434

Total trading liabilities

96,780

74,977

4,130

(42,531)

133,356

74,130

4,891

(47,804)

32,001

784

481

252

858

—

1,907

—

—

—

1,591

1,907

Other secured
financings

Borrowings

—

—

733

—

7,700

109

— 60,373

4,088

—

—

—

733

7,809

64,461

185,475

143,137

12,781

(47,804)

293,589

Total liabilities at fair

value

$ 96,780 $145,703 $ 8,506 $ (42,531) $ 208,458

32,902

29,321

—

4

—

—

—

62,223

—

4

$218,377 $172,462 $12,781 $ (47,804) $ 355,816

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December 2019 Form 10-K

 
 
 
Table of Contents
Notes to Consolidated Financial Statements

$ in millions

Assets at fair value

Trading assets:

U.S. Treasury and
agency securities

Other sovereign
government
obligations

State and municipal

securities

MABS

Loans and lending
commitments2

Corporate and other

debt

Corporate equities3

Derivative and other

contracts:

Interest rate

Credit

Foreign exchange

Equity

Commodity and

other
Netting1

Total derivative and
other contracts

Investments4

Physical

commodities
Total trading assets4

Investment securities

—AFS

Intangible assets

Total assets at fair

value

At December 31, 2018

At December 31, 2018

Level 1

Level 2

Level 3 Netting1

Total

$ in millions

Level 1

Level 2

Level 3 Netting1

Total

$ 38,767 $ 29,594 $

54 $

— $ 68,415

28,395

5,529

17

—

—

—

—

3,161

2,154

148

354

4,055

6,870

18,129

1,076

93,626

522

95

—

—

—

—

—

—

33,941

3,309

2,508

10,925

19,205

94,243

2,793

155,027

1,045

— 158,865

—

62

5,707

63,023

421

161

1,256

45,596

1,022

963

8,517

2,992

—

—

—

—

6,128

63,246

47,874

12,472

(4,151)

(210,190)

(896)

(44,175)

(259,412)

Liabilities at fair value

Deposits

Trading liabilities:

U.S. Treasury and
agency securities

Other sovereign
government
obligations

Corporate and other

debt

Corporate equities3

Derivative and other

contracts:

Interest rate

Credit

Foreign exchange

Equity

Commodity and

other
Netting1

Total derivative and
other contracts

$

— $

415 $

27 $

— $

442

11,272

543

21,391

1,454

—

56,064

8,550

199

2,927

142,746

—

41

5,772

63,379

—

—

1

15

427

381

86

1,042

47,091

2,507

1,228

6,872

940

—

11,815

—

—

—

22,845

8,551

56,278

— 146,100

—

—

—

—

6,153

63,506

50,640

9,040

(4,151)

(210,190)

(896)

(32,944)

(248,181)

1,087

55,670

3,445

(32,944)

27,258

Total trading liabilities

89,814

66,416

3,461

(32,944)

126,747

Securities sold under

agreements to
repurchase

67,680

4,745

(44,175)

29,173

923

412

293

757

—

536

—

—

—

1,462

Other secured
financings

536

Borrowings

—

—

—

812

—

5,037

208

47,378

3,806

—

—

—

812

5,245

51,184

162,123

131,653

14,116

(44,175)

263,717

Total liabilities at fair

value

$89,814 $ 120,058 $ 7,502 $ (32,944) $ 184,430

36,399

24,662

—

5

—

—

—

—

61,061

5

$198,522 $ 156,320 $14,116 $ (44,175) $ 324,783

MABS—Mortgage- and asset-backed securities
1. For positions with the same counterparty that cross over the levels of the fair value
hierarchy, both counterparty netting and cash collateral netting are included in the
column titled “Netting.” Positions classified within the same level that are with the same
counterparty  are  netted  within  that  level.  For  further  information  on  derivative
instruments and hedging activities, see Note 5.

2. For  a  further  breakdown  by  type,  see  the  following  Detail  of  Loans  and  Lending

Commitments at Fair Value table.

3. For trading purposes, the Firm holds or sells short equity securities issued by entities

in diverse industries and of varying sizes.

4. Amounts exclude certain investments that are measured based on NAV per share,
which are not classified in the fair value hierarchy. For additional disclosure about such
investments, see “Net Asset Value Measurements” herein.

Detail of Loans and Lending Commitments at Fair Value

$ in millions

Corporate

Residential real estate

Commercial real estate

Total

At
December 31, 
 2019

At
December 31, 
 2018

$

$

8,036 $

1,192

2,098

9,171

1,153

601

11,326 $

10,925

Unsettled Fair Value of Futures Contracts1

$ in millions

At
December 31, 
 2019

At
December 31, 
 2018

Customer and other receivables, net

$

365 $

615

1. These contracts are primarily Level 1, actively traded, valued based on quoted prices
from the exchange and are excluded from the previous recurring fair value tables.

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Notes to Consolidated Financial Statements

Valuation Techniques for Assets and Liabilities Measured at Fair Value on a Recurring Basis

Asset and Liability/Valuation Technique

U.S. Treasury and Agency Securities

U.S. Treasury Securities
• Fair value is determined using quoted market prices.

U.S. Agency Securities
• Non-callable agency-issued debt securities are generally valued using quoted market prices, and callable
agency-issued debt securities are valued by benchmarking model-derived prices to quoted market prices
and trade data for comparable instruments.

• The fair value of agency mortgage pass-through pool securities is model-driven based on spreads of

comparable to-be-announced securities.

• CMOs are generally valued using quoted market prices and trade data adjusted by subsequent changes

in related indices for comparable instruments.

Other Sovereign Government Obligations

• Fair value is determined using quoted prices in active markets when available. When not available, quoted
prices in less-active markets are used. In the absence of position-specific quoted prices, fair value may
be determined through benchmarking from comparable instruments.

State and Municipal Securities

• Fair value is determined using recently executed transactions, market price quotations or pricing models
that factor in, where applicable, interest rates, bond or CDS spreads, adjusted for any basis difference
between cash and derivative instruments.

Valuation Hierarchy
Classification

• Level 1

• Level 1 - on-the-run agency

issued debt securities if actively
traded and inputs are observable

• Generally Level 2 - all other

agency issued debt securities,
agency mortgage pass-through
pool securities and CMOs if
actively traded and inputs are
observable

• Level 3 - in instances where the

trading activity is limited or inputs
are unobservable

• Generally Level 1
• Level 2 - if the market is less
active or prices are dispersed
• Level 3 - in instances where the

prices are unobservable

• Generally Level 2 - if value based

on observable market data for
comparable instruments
• Level 3 in instances where

market data is not observable

RMBS, CMBS, ABS (collectively known as Mortgage- and Asset-backed securities (“MABS”))

• Generally Level 2 - if value based

• Mortgage- and asset-backed securities may be valued based on price or spread data obtained from

observed transactions or independent external parties such as vendors or brokers.

• When position-specific external price data are not observable, the fair value determination may require
benchmarking to comparable instruments, and/or analyzing expected credit losses, default and recovery
rates, and/or applying discounted cash flow techniques. When evaluating the comparable instruments
for use in the valuation of each security, security collateral-specific attributes, including payment priority,
credit  enhancement  levels,  type  of  collateral,  delinquency  rates  and  loss  severity,  are  considered.  In
addition, for RMBS borrowers, FICO scores and the level of documentation for the loan are considered.
• Market standard cash flow models may be utilized to model the specific collateral composition and cash
flow  structure  of  each  transaction.  Key  inputs  to  these  models  are  market  spreads,  forecasted  credit
losses, and default and prepayment rates for each asset category.

• Valuation levels of RMBS and CMBS indices are used as an additional data point for benchmarking

on observable market data for
comparable instruments

• Level 3 - if external prices or
significant spread inputs are
unobservable, or if the
comparability assessment
involves significant subjectivity
related to property type
differences, cash flows,
performance or other inputs

purposes or to price outright index positions.

Loans and Lending Commitments

• Fair value of corporate loans is determined using recently executed transactions, market price quotations
(where observable), implied yields from comparable debt, market observable CDS spread levels obtained
from  independent  external  parties  adjusted  for  any  basis  difference  between  cash  and  derivative
instruments,  along  with  proprietary  valuation  models  and  default  recovery  analysis  where  such
transactions and quotations are unobservable.

• Fair value of contingent corporate lending commitments is determined by using executed transactions
on comparable loans and the anticipated market price based on pricing indications from syndicate banks
and customers. The valuation of loans and lending commitments also takes into account fee income that
is considered an attribute of the contract.

• Fair value of mortgage loans is determined using observable prices based on transactional data or third-

party pricing for comparable instruments, when available.

• Where position-specific external prices are not observable, fair value is estimated based on benchmarking
to prices and rates observed in the primary market for similar loan or borrower types or based on the
present  value  of  expected  future  cash  flows  using  the  Firm’s  best  available  estimates  of  the  key
assumptions, including forecasted credit losses, prepayment rates, forward yield curves and discount
rates commensurate with the risks involved or a methodology that utilizes the capital structure and credit
spreads of recent comparable securitization transactions.

• Fair value of equity margin loans is determined by discounting future interest cash flows, net of estimated
credit  losses.  The  estimated  credit  losses  are  derived  by  benchmarking  to  market  observable  CDS
spreads, implied debt yields or volatility metrics of the loan collateral.

Corporate and Other Debt

Corporate Bonds
• Fair value is determined using recently executed transactions, market price quotations, bond spreads
and CDS spreads obtained from independent external parties, such as vendors and brokers, adjusted
for any basis difference between cash and derivative instruments.

• The spread data used are for the same maturity as the bond. If the spread data do not reference the
issuer, then data that reference comparable issuers are used. When position-specific external price data
are not observable, fair value is determined based on either benchmarking to comparable instruments
or cash flow models with yield curves, bond or single-name CDS spreads and recovery rates as significant
inputs.

• Level 2 - if value based on
observable market data for
comparable instruments

• Level 3 - in instances where

prices or significant spread inputs
are unobservable

• Generally Level 2 - if value based
on  observable  market  data  for
comparable instruments

• Level 3 - in instances where prices
or  significant  spread  inputs  are
unobservable

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Notes to Consolidated Financial Statements

Asset and Liability/Valuation Technique

CDO
• The Firm holds cash CDOs that typically reference a tranche of an underlying synthetic portfolio of single-
name CDS spreads collateralized by corporate bonds (CLN) or cash portfolio of ABS/loans (“asset-backed
CDOs”).

• Credit correlation, a primary input used to determine the fair value of CLNs, is usually unobservable and
derived using a benchmarking technique. Other model inputs such as credit spreads, including collateral
spreads, and interest rates are typically observable.

• Asset-backed CDOs are valued based on an evaluation of the market and model input parameters sourced
from  comparable  instruments  as  indicated  by  market  activity.  Each  asset-backed  CDO  position  is
evaluated  independently  taking  into  consideration  available  comparable  market  levels,  underlying
collateral performance and pricing, deal structures and liquidity.

Corporate Equities

• Exchange-traded equity securities are generally valued based on quoted prices from the exchange. To

the extent these securities are actively traded, valuation adjustments are not applied.

• Unlisted equity securities are generally valued based on an assessment of each security, considering
rounds  of  financing  and  third-party  transactions,  discounted  cash  flow  analyses  and  market-based
information, including comparable transactions, trading multiples and changes in market outlook, among
other factors.

• Listed fund units are generally marked to the exchange-traded price if actively traded, or NAV if not.

Unlisted fund units are generally marked to NAV.

Derivative and Other Contracts
Listed Derivative Contracts
• Listed derivatives that are actively traded are valued based on quoted prices from the exchange.
• Listed derivatives that are not actively traded are valued using the same techniques as those applied to

OTC derivatives as noted below.

OTC Derivative Contracts

• OTC derivative contracts include forward, swap and option contracts related to interest rates, foreign

currencies, credit standing of reference entities, equity prices or commodity prices.

• Depending on the product and the terms of the transaction, the fair value of OTC derivative products can
be modeled using a series of techniques, including closed-form analytic formulas, such as the Black-
Scholes option-pricing model, simulation models or a combination thereof. Many pricing models do not
entail material subjectivity as the methodologies employed do not necessitate significant judgment since
model inputs may be observed from actively quoted markets, as is the case for generic interest rate
swaps, many equity, commodity and foreign currency option contracts, and certain CDS. In the case of
more established derivative products, the pricing models used by the Firm are widely accepted by the
financial services industry.

•  More  complex  OTC  derivative  products  are  typically  less  liquid  and  require  more  judgment  in  the
implementation of the valuation technique since direct trading activity or quotes are unobservable. This
includes  certain  types  of  interest  rate  derivatives  with  both  volatility  and  correlation  exposure,  equity,
commodity or foreign currency derivatives that are either longer-dated or include exposure to multiple
underlyings, and credit derivatives, including CDS on certain mortgage- or asset-backed securities and
basket CDS. Where required inputs are unobservable, relationships to observable data points, based on
historical  and/or  implied  observations,  may  be  employed  as  a  technique  to  estimate  the  model  input
values.  

For further information on the valuation techniques for OTC derivative products, see Note 2.

Investments

• Investments include direct investments in equity securities, as well as various investment management
funds, which include investments made in connection with certain employee deferred compensation plans.
•  Exchange-traded  direct  equity  investments  are  generally  valued  based  on  quoted  prices  from  the

exchange.

• For direct investments, initially, the transaction price is generally considered by the Firm as the exit price

and is its best estimate of fair value.

• After initial recognition, in determining the fair value of non-exchange-traded internally and externally
managed funds, the Firm generally considers the NAV of the fund provided by the fund manager to be
the best estimate of fair value. These investments are included in the Fund Interests table in the "Net
Asset Value Measurements" section herein.

• For non-exchange-traded investments either held directly or held within internally managed funds, fair
value  after  initial  recognition  is  based  on  an  assessment  of  each  underlying  investment,  considering
rounds  of  financing  and  third-party  transactions,  discounted  cash  flow  analyses  and  market-based
information, including comparable Firm transactions, trading multiples and changes in market outlook,
among other factors.

Physical Commodities

• The Firm trades various physical commodities, including natural gas and precious metals.
• Fair value is determined using observable inputs, including broker quotations and published indices.

Valuation Hierarchy
Classification

• Level 2 - when either comparable

market transactions are
observable, or credit correlation
input is insignificant

• Level 3 - when either comparable

market transactions are
unobservable, or the credit
correlation input is significant

• Generally Level 1 - exchange-

traded securities and fund units if
actively traded

• Level 2 - exchange-traded

securities if not actively traded, or
if undergoing a recent M&A event
or corporate action

• Level 3 - exchange-traded

securities if not actively traded, or
if undergoing an aged M&A event
or corporate action

• Level 1 - listed derivatives that are

actively traded

• Level 2 - listed derivatives that are

not actively traded

• Generally Level 2 - OTC

derivative products valued using
observable inputs, or where the
unobservable input is not deemed
significant

• Level 3 - OTC derivative products
for which the unobservable input
is deemed significant

• Level 1 - exchange-traded direct
equity investments in an active
market

• Level 2 - non-exchange-traded
direct equity investments and
investments in various investment
management funds if valued
based on rounds of financing or
third-party transactions;
exchange-traded direct equity
investments if not actively traded

• Level 3 - non-exchange-traded
direct equity investments and
investments in various investment
management funds where rounds
of financing or third-party
transactions are not available

• Level 2

December 2019 Form 10-K

96

Table of Contents
Notes to Consolidated Financial Statements

Asset and Liability/Valuation Technique

Investment Securities—AFS Securities

• AFS securities are composed of U.S. government and agency securities (e.g., U.S. Treasury securities,
agency-issued  debt,  agency  mortgage  pass-through  securities  and  CMOs),  CMBS,  ABS,  state  and
municipal securities, and corporate bonds.

For further information on the determination of fair value, refer to the corresponding asset/liability Valuation
Technique described herein for the same instruments.

Deposits

Certificates of Deposit
• The Firm issues FDIC-insured certificates of deposit that pay either fixed coupons or that have repayment
terms linked to the performance of debt or equity securities, indices or currencies. The fair value of these
certificates of deposit is determined using valuation models that incorporate observable inputs referencing
identical or comparable securities, including prices to which the deposits are linked, interest rate yield
curves, option volatility and currency rates, equity prices, and the impact of the Firm’s own credit spreads,
adjusted for the impact of the FDIC insurance, which is based on vanilla deposit issuance rates.

Valuation Hierarchy
Classification

• For further information on the

determination of valuation
hierarchy classification, see the
corresponding Valuation
Hierarchy Classification described
herein.

• Generally Level 2
• Level 3 - in instances where the
unobservable input is deemed
significant

Securities Purchased under Agreements to Resell and Securities Sold under Agreements to Repurchase

• Generally Level 2

• Fair value is computed using a standard cash flow discounting methodology.
• The inputs to the valuation include contractual cash flows and collateral funding spreads, which are the
incremental spread over the OIS rate for a specific collateral rate (which refers to the rate applicable to
a specific type of security pledged as collateral).

Other Secured Financings

• Other secured financings are composed of short-dated notes secured by Corporate equities, agreements
to repurchase Physical commodities, the liabilities related to sales of Loans and lending commitments
accounted for as financings, and contracts which are not classified as OTC derivatives because they fail
net investment criteria.

For further information on the determination of valuation hierarchy classification, see the corresponding
Valuation Hierarchy Classification described herein.

Borrowings

• The Firm carries certain borrowings at fair value which are primarily composed of: instruments whose
payments and redemption values are linked to the performance of a specific index, a basket of stocks, a
specific equity security, a commodity, a credit exposure or basket of credit exposures; and instruments
with various interest-rate-related features including step-ups, step-downs, and zero coupons.

• Fair value is determined using valuation models for the derivative and debt portions of the instruments.
These models incorporate observable inputs referencing identical or comparable securities, including
prices to which the instruments are linked, interest rate yield curves, option volatility and currency rates,
and commodity or equity prices.

• Independent, external and traded prices are considered as well as the impact of the Firm’s own credit

spreads which are based on observed secondary bond market spreads.

• For further information on the

determination of valuation
hierarchy classification, see the
corresponding Valuation
Hierarchy Classification described
herein.

• Generally Level 2
• Level 3 - in instances where the
unobservable inputs are deemed
significant

97

December 2019 Form 10-K

Table of Contents
Notes to Consolidated Financial Statements

Rollforward of Level 3 Assets and Liabilities Measured at Fair
Value on a Recurring Basis

$ in millions
$ in millions

2019
2019

2018
2018

2017
2017

U.S. Treasury and agency securities
U.S. Treasury and agency securities

Beginning balance
Beginning balance

$
$

54 $
54 $

— $
— $

$ in millions
$ in millions

Corporate equities
Corporate equities

Beginning balance
Beginning balance

Realized and unrealized gains (losses)
Realized and unrealized gains (losses)

Purchases
Purchases

Sales
Sales

Net transfers
Net transfers

Ending balance
Ending balance

Unrealized gains (losses)
Unrealized gains (losses)

Investments
Investments

Beginning balance
Beginning balance

Realized and unrealized gains (losses)
Realized and unrealized gains (losses)

Purchases
Purchases

Sales
Sales

Settlements
Settlements

Net transfers
Net transfers

Ending balance
Ending balance

Unrealized gains (losses)
Unrealized gains (losses)

Net derivatives: Interest rate
Net derivatives: Interest rate

Beginning balance
Beginning balance

4
4

17
17

(54)
(54)

1
1

1
1

53
53

—
—

—
—

22 $
22 $

4 $
4 $

54 $
54 $

1 $
1 $

17 $
17 $

1 $
1 $

(3)
(3)

7
7

(6)
(6)

(10)
(10)

—
—

41
41

(26)
(26)

1
1

5 $
5 $

(3) $
(3) $

17 $
17 $

— $
— $

74
74

(1)
(1)

—
—

(240)
(240)

167
167

—
—

—
—

6
6

—
—

—
—

(5)
(5)

—
—

1
1

—
—

148 $
148 $

8 $
8 $

250
250

Realized and unrealized gains (losses)
Realized and unrealized gains (losses)

—
—

—
—

(147)
(147)

—
—

—
—

147
147

(9)
(9)

2
2

1 $
1 $

148 $
148 $

— $
— $

— $
— $

354 $
354 $

423 $
423 $

(16)
(16)

132
132

(175)
(175)

(44)
(44)

187
187

82
82

177
177

(338)
(338)

(17)
(17)

27
27

438 $
438 $

354 $
354 $

3
3

6
6

(83)
(83)

(168)
(168)

8
8

—
—

217
217

47
47

289
289

(158)
(158)

(37)
(37)

65
65

423
423

Purchases
Purchases

Issuances
Issuances

Settlements
Settlements

Net transfers
Net transfers

Ending balance
Ending balance

Unrealized gains (losses)
Unrealized gains (losses)

Net derivatives: Credit
Net derivatives: Credit

Beginning balance
Beginning balance

Realized and unrealized gains (losses)
Realized and unrealized gains (losses)

Purchases
Purchases

Issuances
Issuances

Settlements
Settlements

Net transfers
Net transfers

Ending balance
Ending balance

(57) $
(57) $

(9) $
(9) $

(7)
(7)

Unrealized gains (losses)
Unrealized gains (losses)

Net derivatives: Foreign exchange
Net derivatives: Foreign exchange

Realized and unrealized gains (losses)
Realized and unrealized gains (losses)

Purchases
Purchases

Sales
Sales

Net transfers
Net transfers

Ending balance
Ending balance

Unrealized gains (losses)
Unrealized gains (losses)

Other sovereign government obligations
Other sovereign government obligations

Beginning balance
Beginning balance

Realized and unrealized gains (losses)
Realized and unrealized gains (losses)

Purchases
Purchases

Sales
Sales

Net transfers
Net transfers

Ending balance
Ending balance

Unrealized gains (losses)
Unrealized gains (losses)

State and municipal securities
State and municipal securities

Beginning balance
Beginning balance

Realized and unrealized gains (losses)
Realized and unrealized gains (losses)

Purchases
Purchases

Sales
Sales

Net transfers
Net transfers

Ending balance
Ending balance

Unrealized gains (losses)
Unrealized gains (losses)

MABS
MABS

Beginning balance
Beginning balance

Realized and unrealized gains (losses)
Realized and unrealized gains (losses)

Purchases
Purchases

Sales
Sales

Settlements
Settlements

Net transfers
Net transfers

Ending balance
Ending balance

Unrealized gains (losses)
Unrealized gains (losses)

Loans and lending commitments
Loans and lending commitments

Beginning balance
Beginning balance

$
$

$
$

$
$

$
$

$
$

$
$

$
$

$
$

$
$

$
$

$
$

$
$

6,870 $
6,870 $

5,945 $
5,945 $

5,122
5,122

Beginning balance
Beginning balance

Realized and unrealized gains (losses)
Realized and unrealized gains (losses)

38
38

(100)
(100)

182
182

Realized and unrealized gains (losses)
Realized and unrealized gains (losses)

Purchases
Purchases

Sales
Sales

Settlements
Settlements

Net transfers
Net transfers

Ending balance
Ending balance

Unrealized gains (losses)
Unrealized gains (losses)

Corporate and other debt
Corporate and other debt

Beginning balance
Beginning balance

Realized and unrealized gains (losses)
Realized and unrealized gains (losses)

Purchases
Purchases

Sales
Sales

Settlements
Settlements

Net transfers
Net transfers

Ending balance
Ending balance

Unrealized gains (losses)
Unrealized gains (losses)

2,337
2,337

5,746
5,746

3,616
3,616

(1,268)
(1,268)

(2,529)
(2,529)

(1,561)
(1,561)

(2,291)
(2,291)

(2,281)
(2,281)

(1,463)
(1,463)

(613)
(613)

89
89

49
49

5,073 $
5,073 $

6,870 $
6,870 $

5,945
5,945

(9) $
(9) $

(137) $
(137) $

131
131

$
$

$
$

$
$

1,076 $
1,076 $

701 $
701 $

418
418

650
650

(729)
(729)

(7)
(7)

(12)
(12)

106
106

734
734

(251)
(251)

(11)
(11)

(203)
(203)

$
$

$
$

1,396 $
1,396 $

1,076 $
1,076 $

361 $
361 $

70 $
70 $

475
475

82
82

487
487

(420)
(420)

(9)
(9)

86
86

701
701

23
23

Purchases
Purchases

Issuances
Issuances

Settlements
Settlements

Net transfers
Net transfers

Ending balance
Ending balance

Unrealized gains (losses)
Unrealized gains (losses)

Net derivatives: Equity
Net derivatives: Equity

Beginning balance
Beginning balance

Realized and unrealized gains (losses)
Realized and unrealized gains (losses)

Purchases
Purchases

Issuances
Issuances

Settlements
Settlements
Net transfers1
Net transfers1

Ending balance
Ending balance

Unrealized gains (losses)
Unrealized gains (losses)

December 2019 Form 10-K

98

2019
2019

2018
2018

2017
2017

$
$

95 $
95 $

166 $
166 $

(161)
(161)

(632)
(632)

(8)
(8)

32
32

(271)
(271)

249
249

97 $
97 $

1 $
1 $

29
29

13
13

48
48

95 $
95 $

17 $
17 $

757 $
757 $

1,020 $
1,020 $

78
78

40
40

(41)
(41)

—
—

24
24

(25)
(25)

149
149

(212)
(212)

—
—

(175)
(175)

446
446

(54)
(54)

173
173

233
233

166
166

(6)
(6)

958
958

96
96

102
102

(57)
(57)

(78)
(78)

(1)
(1)

858 $
858 $

757 $
757 $

1,020
1,020

67 $
67 $

(27) $
(27) $

88
88

618 $
618 $

1,218 $
1,218 $

17
17

98
98

(16)
(16)

1
1

59
59

111
111

63
63

(19)
(19)

(172)
(172)

(583)
(583)

420
420

322
322

29
29

(18)
(18)

608
608

(143)
(143)

777 $
777 $

618 $
618 $

1,218
1,218

87 $
87 $

140 $
140 $

341
341

40 $
40 $

41 $
41 $

(373)
(373)

(24)
(24)

144
144

(190)
(190)

111
111

43
43

33
33

13
13

(95)
(95)

56
56

(8)
(8)

124 $
124 $

(17) $
(17) $

40 $
40 $

23 $
23 $

75 $
75 $

(112) $
(112) $

(295)
(295)

179
179

2
2

—
—

7
7

180
180

3
3

(1)
(1)

2
2

4
4

(43)
(43)

—
—

(1)
(1)

455
455

3
3

41
41

(18)
(18)

(43)
(43)

(108)
(108)

—
—

(1)
(1)

31
31

9
9

(31) $
(31) $

75 $
75 $

(112)
(112)

(187) $
(187) $

118 $
118 $

(89)
(89)

$
$

$
$

$
$

$
$

$
$

$
$

$
$

$
$

$
$

$
$

$
$

$
$

$
$

$
$

$ (1,485) $
$ (1,485) $

1,208 $
1,208 $

(260)
(260)

155
155

305
305

122
122

184
184

136
136

988
988

(643)
(643)

(1,179)
(1,179)

(524)
(524)

242
242

307
307

314
314

(2,255)
(2,255)

396
396

28
28

$ (1,684) $ (1,485) $
$ (1,684) $ (1,485) $

1,208
1,208

$
$

(194) $
(194) $

211 $
211 $

159
159

Table of Contents
Notes to Consolidated Financial Statements

$ in millions

2019

2018

2017

Net derivatives: Commodity and other

Beginning balance

$

2,052 $

1,446 $

1,600

Realized and unrealized gains (losses)

Purchases

Issuances

Settlements

Net transfers

Ending balance

Unrealized gains (losses)

Deposits

Beginning balance

Realized and unrealized losses (gains)

Issuances

Settlements

Net transfers

Ending balance

Unrealized losses (gains)

Nonderivative trading liabilities

Beginning balance

Realized and unrealized losses (gains)

Purchases

Sales

Net transfers

Ending balance

Unrealized losses (gains)

$

$

$

$

$

$

$

$

Securities sold under agreements to repurchase

Beginning balance

Issuances

Net transfers

Ending balance

Unrealized losses (gains)

Other secured financings

Beginning balance

Realized and unrealized losses (gains)

Issuances

Settlements

Net transfers

Ending balance

Unrealized losses (gains)

Borrowings

Beginning balance

$

$

$

$

$

$

73

152

(92)

(611)

38

500

34

(18)

(81)

171

515

24

(57)

(343)

(293)

1,612 $

2,052 $

1,446

(113) $

272 $

20

27 $

47 $

20

101

(15)

46

(1)

9

(2)

(26)

179 $

20 $

27 $

(1) $

16 $

25 $

(21)

(65)

38

69

(6)

(18)

9

6

37 $

(21) $

16 $

(7) $

42

3

12

(3)

(7)

47

3

71

(1)

(139)

20

74

25

—

— $

150 $

149

—

—

— $

— $

—

(150)

— $

— $

1

—

150

—

208 $

239 $

434

5

—

(8)

(96)

(39)

8

(17)

17

109 $

208 $

5 $

(39) $

35

64

(251)

(43)

239

28

in  the  previous  tables  do  not  reflect  the  related  realized  and
unrealized gains (losses) on hedging instruments that have been
classified  by  the  Firm  within  the  Level  1  and/or  Level  2
categories.

The unrealized gains (losses) during the period for assets and
liabilities within the Level 3 category may include changes in
fair  value  during  the  period  that  were  attributable  to  both
observable  and  unobservable  inputs.  Total  realized  and
unrealized  gains  (losses)  are  primarily  included  in  Trading
revenues in the income statements.

Additionally, in the previous tables, consolidations of VIEs are
included in Purchases and deconsolidations of VIEs are included
in Settlements.

Significant  Unobservable  Inputs  Used  in  Recurring  and
Nonrecurring Level 3 Fair Value Measurements

Valuation Techniques and Unobservable Inputs

Balance / Range (Average1)

$ in millions,except

inputs

At December 31, 2019

At December 31, 2018

Assets at Fair Value on a Recurring Basis

$

$

$

$

U.S. Treasury and

agency securities

Comparable pricing:

Bond price

State and 

municipal 
securities

Comparable pricing:

Bond price

MABS

Comparable pricing:

Bond price

Loans and lending 

commitments

Margin loan model:

Discount rate

Volatility skew

Credit Spread

Comparable pricing:

22

$

54

N/M

100 to 104 points 
(100 points)

1

$

148

N/M 94 to 100 points (96 points)

438

$

354

0 to 96 points (47 points)

0 to 97 points (38 points)

5,073

$

6,870

1% to 9% (2%)

1% to 7% (2%)

15% to 80% (28%)

19% to 56% (28%)

9 to 39 bps (19 bps)

14 to 90 bps (36 bps)

$

3,806 $

2,984 $

2,014

Loan price

69 to 100 points (93 points)

60 to 101 points (95 points)

Realized and unrealized losses (gains)

728

(385)

196

Issuances

Settlements

Net transfers

Ending balance

Unrealized losses (gains)

Portion of Unrealized losses (gains)

recorded in OCI—Change in net DVA

1,181

1,554

1,968

(950)

(677)

(274)

(73)

(424)

(770)

$

$

4,088 $

3,806 $

2,984

600 $

(379) $

173

182

(184)

76

1. During  2018,  the  Firm  transferred  from  Level 3  to  Level 2  $2.4  billion  of  Equity
Derivatives due to a reduction in the significance of the unobservable inputs relating
to volatility.

Level 3 instruments may be hedged with instruments classified
in Level 1 and Level 2. The realized and unrealized gains (losses)
for assets and liabilities within the Level 3 category presented

Corporate and 
other debt

$

Comparable pricing:

1,396

$

1,076

Bond price

11 to 108 points (84 points)

12 to 100 points (72 points)

Discounted cash flow:

Recovery rate

Discount rate

Option model:

At the money
volatility

35%

N/M

20%

15% to 21% (16%)

21%

24% to 78% (50%)

99

December 2019 Form 10-K

Table of Contents
Notes to Consolidated Financial Statements

$ in millions,except
$ in millions,except

inputs
inputs

Corporate equities
Corporate equities

Comparable pricing:
Comparable pricing:

Equity price
Equity price

Investments
Investments

Discounted cash flow:
Discounted cash flow:

$
$

$
$

WACC
WACC

Exit multiple
Exit multiple

Market approach:
Market approach:

EBITDA multiple
EBITDA multiple

Comparable pricing:
Comparable pricing:

Equity price
Equity price

Bond volatility
Bond volatility

Inflation volatility
Inflation volatility

IR curve
IR curve

Credit
Credit

$
$

Credit default swap model:
Credit default swap model:

Cash-synthetic 
Cash-synthetic 

basis
basis

Bond price
Bond price

Credit spread
Credit spread

Funding spread
Funding spread

Correlation model:
Correlation model:

Credit correlation
Credit correlation

Foreign exchange2
Foreign exchange2

$
$

Option model:
Option model:

$
$

$
$

IR curve
IR curve

Contingency 
Contingency 
probability
probability

Equity2
Equity2

Option model:
Option model:

At the money 
At the money 

volatility
volatility

Volatility skew
Volatility skew

Equity correlation
Equity correlation

FX correlation
FX correlation

IR correlation
IR correlation

Commodity and
Commodity and

other
other

Option model:
Option model:

Forward power 
Forward power 

price
price

Commodity volatility
Commodity volatility

Cross-commodity 
Cross-commodity 

correlation
correlation

Balance / Range (Average1)
Balance / Range (Average1)

Balance / Range (Average1)
Balance / Range (Average1)

At December 31, 2019
At December 31, 2019

At December 31, 2018
At December 31, 2018

$ in millions,except
$ in millions,except

inputs
inputs

At December 31, 2019
At December 31, 2019

At December 31, 2018
At December 31, 2018

95
95

Liabilities Measured at Fair Value on a Recurring Basis
Liabilities Measured at Fair Value on a Recurring Basis

97
97

$
$

100%
100%

858
858

$
$

100%
100%

757
757

8% to 17% (15%)
8% to 17% (15%)

9% to 15% (10%)
9% to 15% (10%)

7 to 16 times (11 times)
7 to 16 times (11 times)

7 to 10 times (10 times)
7 to 10 times (10 times)

Discounted cash flow:
Discounted cash flow:

Deposits
Deposits

Option model:
Option model:

At the money
At the money
volatility
volatility

Other secured 
Other secured 
financings
financings

Funding spread
Funding spread

Option model:
Option model:

Volatility skew
Volatility skew

At the money
At the money
volatility
volatility

Borrowings
Borrowings

Option model:
Option model:

At the money
At the money
volatility
volatility

Volatility skew
Volatility skew

$
$

$
$

$
$

179
179

$
$

16% to 37% (20%)
16% to 37% (20%)

109
109

$
$

27
27

N/M
N/M

208
208

111 to 124 bps (117 bps)
111 to 124 bps (117 bps)

103 to 193 bps (148 bps)
103 to 193 bps (148 bps)

N/M
N/M

N/M
N/M

-1%
-1%

10% to 40% (25%)
10% to 40% (25%)

4,088
4,088

$
$

3,806
3,806

5% to 44% (21%)
5% to 44% (21%)

5% to 35% (22%)
5% to 35% (22%)

-2% to 0% (0%)
-2% to 0% (0%)

-2% to 0% (0%)
-2% to 0% (0%)

Equity correlation
Equity correlation

38% to 94% (78%)
38% to 94% (78%)

45% to 98% (85%)
45% to 98% (85%)

Equity - FX 
Equity - FX 
correlation
correlation

IR Correlation
IR Correlation

-75% to 26% (-25%)
-75% to 26% (-25%)

-75% to 50% (-27%)
-75% to 50% (-27%)

N/M
N/M

58% to 97% (85% / 91%)
58% to 97% (85% / 91%)

IR FX Correlation
IR FX Correlation

-26% to 10% (-7% / -7%)
-26% to 10% (-7% / -7%)

28% to 58% (44% / 44%)
28% to 58% (44% / 44%)

Nonrecurring Fair Value Measurement
Nonrecurring Fair Value Measurement

7 to 24 times (11 times)
7 to 24 times (11 times)

6 to 24 times (12 times)
6 to 24 times (12 times)

75% to 100% (99%)
75% to 100% (99%)

75% to 100% (96%)
75% to 100% (96%)

Net derivative and other contracts:
Net derivative and other contracts:

Interest rate
Interest rate

Option model:
Option model:

$
$

777
777

$
$

618
618

IR volatility skew
IR volatility skew

24% to 156% (63% / 59%)
24% to 156% (63% / 59%)

22% to 95% (48% / 51%)
22% to 95% (48% / 51%)

IR curve correlation
IR curve correlation

47% to 90% (72% / 72%)
47% to 90% (72% / 72%)

4% to 15% (13% / 14%)
4% to 15% (13% / 14%)

N/M
N/M

N/M
N/M

24% to 63% (44% / 41%)
24% to 63% (44% / 41%)

23% to 65% (44% / 40%)
23% to 65% (44% / 40%)

1%
1%

124
124

$
$

1%
1%

40
40

6 points
6 points

8 to 9 points (9 points)
8 to 9 points (9 points)

Loans
Loans

$
$

1,500
1,500

$
$

1,380
1,380

0 to 104 points (45 points)
0 to 104 points (45 points)

0 to 75 points (26 points)
0 to 75 points (26 points)

Corporate loan model:
Corporate loan model:

9 to 469 bps (81 bps)
9 to 469 bps (81 bps)

246 to 499 bps (380 bps)
246 to 499 bps (380 bps)

47 to 117 bps (84 bps)
47 to 117 bps (84 bps)

47 to 98 bps (93 bps)
47 to 98 bps (93 bps)

Credit spread
Credit spread

Warehouse model:
Warehouse model:

Credit spread
Credit spread

69 to 446 bps (225 bps)
69 to 446 bps (225 bps)

97 to 434 bps (181 bps)
97 to 434 bps (181 bps)

287 to 318 bps (297 bps)
287 to 318 bps (297 bps)

223 to 313 bps (247 bps)
223 to 313 bps (247 bps)

29% to 62% (36%)
29% to 62% (36%)

36% to 69% (44%)
36% to 69% (44%)

(31) $
(31) $

75
75

IR - FX correlation
IR - FX correlation

32% to 56% (46% / 46%)
32% to 56% (46% / 46%)

53% to 56% (55% / 55%)
53% to 56% (55% / 55%)

IR volatility skew
IR volatility skew

24% to 156% (63% / 59%)
24% to 156% (63% / 59%)

22% to 95% (48% / 51%)
22% to 95% (48% / 51%)

Points—Percentage of par
IR—Interest rate
FX—Foreign exchange
1. A  single  amount  is  disclosed  for  range  and  average  when  there  is  no  significant
difference  between  the  minimum,  maximum  and  average.  Amounts  represent
weighted averages except where simple averages and the median of the inputs are
more relevant.

10% to 11% (10% / 10%)
10% to 11% (10% / 10%)

N/M
N/M

2. Includes derivative contracts with multiple risks (i.e., hybrid products).

85% to 95% (94% / 95%)
85% to 95% (94% / 95%)

90% to 95% (93% / 95%)
90% to 95% (93% / 95%)

(1,684) $
(1,684) $

(1,485)
(1,485)

9% to 90% (36%)
9% to 90% (36%)

17% to 63% (38%)
17% to 63% (38%)

-2% to 0% (-1%)
-2% to 0% (-1%)

-2% to 0% (-1%)
-2% to 0% (-1%)

5% to 98% (70%)
5% to 98% (70%)

5% to 96% (71%)
5% to 96% (71%)

-79% to 60% (-37%)
-79% to 60% (-37%)

-60% to 55% (-26%)
-60% to 55% (-26%)

-11% to 44% (18% / 16%)
-11% to 44% (18% / 16%)

-7% to 45% (15% / 12%)
-7% to 45% (15% / 12%)

1,612
1,612

$
$

2,052
2,052

$3 to $182 ($28) per MWh
$3 to $182 ($28) per MWh

$3 to $185 ($31) per MWh
$3 to $185 ($31) per MWh

7% to 183% (18%)
7% to 183% (18%)

7% to 187% (17%)
7% to 187% (17%)

43% to 99% (93%)
43% to 99% (93%)

5% to 99% (93%)
5% to 99% (93%)

The  previous  tables  provide  information  on  the  valuation
techniques, significant unobservable inputs, and the ranges and
averages  for  each  major  category  of  assets  and  liabilities
measured  at  fair  value  on  a  recurring  and  nonrecurring  basis
with a significant Level 3 balance. The level of aggregation and
breadth of products cause the range of inputs to be wide and not
evenly distributed across the inventory of financial instruments.
Further, the range of unobservable inputs may differ across firms
in the financial services industry because of diversity in the types
of  products  included  in  each  firm’s  inventory.  There  are  no
predictable 
significant
relationships  between  multiple 
unobservable inputs attributable to a given valuation technique.

An increase (decrease) to the following significant unobservable
inputs would generally result in a higher (lower) fair value.

• Comparable bond or loan price: A pricing input used when
prices  for  the  identical  instrument  are  not  available.
Significant subjectivity may be involved when fair value is
determined  using  pricing  data  available  for  comparable

December 2019 Form 10-K

100

Table of Contents
Notes to Consolidated Financial Statements

instruments. Valuation using comparable instruments can be
done by calculating an implied yield (or spread over a liquid
benchmark) from the price of a comparable bond or loan, then
adjusting that yield (or spread) to derive a value for the bond
or loan. The adjustment to yield (or spread) should account
for relevant differences in the bonds or loans such as maturity
or credit quality. Alternatively, a price-to-price basis can be
assumed between the comparable instrument and the bond or
loan being valued in order to establish the value of the bond
or loan.

• Comparable equity price: A price derived from equity raises,
share  buybacks  and  external  bid  levels,  etc. A  discount  or
premium may be included in the fair value estimate.

• Contingency  probability:  Probability  associated  with  the
realization of an underlying event upon which the value of an
asset is contingent.

• EBITDA multiple / Exit multiple: The ratio of Enterprise Value
to EBITDA, where Enterprise Value is the aggregate value of
equity  and  debt  minus  cash  and  cash  equivalents.  The
EBITDA multiple reflects the value of the company in terms
of its full-year EBITDA, whereas the exit multiple reflects
the value of the company in terms of its full-year expected
EBITDA at exit. Either multiple allows comparison between
companies from an operational perspective as the effect of
capital  structure,  taxation  and  depreciation/amortization  is
excluded.

• Recovery rate: Amount expressed as a percentage of par that

is expected to be received when a credit event occurs.

An increase (decrease) to the following significant unobservable
inputs would generally result in a lower (higher) fair value.

• Cash-synthetic  basis: The  measure  of  the  price  differential
between  cash  financial  instruments  and  their  synthetic
derivative-based  equivalents.  The  range  disclosed  in  the
previous table signifies the number of points by which the
synthetic bond equivalent price is higher than the quoted price
of the underlying cash bonds.

• Credit spread: The credit spread reflects the additional net
yield an investor can earn from a security with more credit
risk relative to one with less credit risk. The credit spread of
a particular security is often quoted in relation to the yield on
a  credit  risk-free  benchmark  security  or  reference  rate,
typically either U.S. Treasury or LIBOR.

• Funding  spread:  The  cost  of  borrowing  defined  as  the
incremental spread over the OIS rate for a specific collateral
rate (which refers to the rate applicable to a specific type of
security pledged as collateral).

• WACC:  WACC  represents  the  theoretical  rate  of  return
required to debt and equity investors. The WACC is used in
a discounted cash flow model that calculates the value of the

equity. The model assumes that the cash flow assumptions,
including projections, are fully reflected in the current equity
value, while the debt to equity ratio is held constant.

An increase (decrease) to the following significant unobservable
inputs would generally result in an impact to the fair value, but
the  magnitude  and  direction  of  the  impact  would  depend  on
whether the Firm is long or short the exposure.

• Correlation: A pricing input where the payoff is driven by
more than one underlying risk. Correlation is a measure of
the relationship between the movement of two variables (i.e.,
how the change in one variable influences a change in the
other variable).

• Interest  rate  curve:  The  term  structure  of  interest  rates
(relationship between interest rates and the time to maturity)
and a market’s measure of future interest rates at the time of
observation. An interest rate curve is used to set interest rate
and foreign exchange derivative cash flows and is a pricing
input used in the discounting of any OTC derivative cash flow.

• Volatility: The measure of variability in possible returns for
an  instrument  given  how  much  that  instrument  changes  in
value over time. Volatility is a pricing input for options and,
generally, the lower the volatility, the less risky the option.
The level of volatility used in the valuation of a particular
option depends on a number of factors, including the nature
of the risk underlying that option, the tenor and the strike price
of the option.

• Volatility  skew:  The  measure  of  the  difference  in  implied
volatility for options with identical underliers and expiry dates
but with different strikes.

Net Asset Value Measurements

Fund Interests

$ in millions

Private equity

Real estate
Hedge1

Total

At December 31, 2019

At December 31, 2018

Carrying
Value

Commitment

Carrying
Value

Commitment

$

$

2,078 $

450 $

1,374 $

1,349

94

150

4

1,105

103

3,521 $

604 $

2,582 $

316

161

4

481

1. Investments in hedge funds may be subject to initial period lock-up or gate provisions,
which restrict an investor from withdrawing from the fund during a certain initial period
or restrict the redemption amount on any redemption date, respectively.

Amounts  in  the  previous  table  represent  the  Firm’s  carrying
value  of  general  and  limited  partnership  interests  in  fund
investments, as well as any related performance-based fees in
the form of carried interest. The carrying amounts are measured
based on the NAV of the fund taking into account the distribution
terms applicable to the interest held. This same measurement
applies whether the fund investments are accounted for under
the equity method or fair value.

101

December 2019 Form 10-K

Table of Contents
Notes to Consolidated Financial Statements

Private  Equity.    Funds 
that  pursue  multiple  strategies,
including  leveraged  buyouts,  venture  capital,  infrastructure
growth capital, distressed investments and mezzanine capital.
In addition, the funds may be structured with a focus on specific
geographic regions.

Real  Estate.    Funds  that  invest  in  real  estate  assets  such  as
commercial  office  buildings,  retail  properties,  multi-family
residential properties, developments or hotels. In addition, the
funds may be structured with a focus on specific geographic
regions.

Investments in private equity and real estate funds generally are
not  redeemable  due  to  the  closed-end  nature  of  these  funds.
Instead,  distributions  from  each  fund  will  be  received  as  the
underlying investments of the funds are disposed and monetized.

Hedge.    Funds  that  pursue  various  investment  strategies,
including long-short equity, fixed income/credit, event-driven
and multi-strategy.

See  Note  13  for  information  regarding  general  partner
guarantees,  which  include  potential  obligations  to  return
performance fee distributions previously received. See Note 21
for information regarding carried interest at risk of reversal.

Nonredeemable Funds by Contractual Maturity

$ in millions

Less than 5 years

5-10 years

Over 10 years

Total

Carrying Value at December 31, 2019

Private Equity

Real Estate

$

$

1,205 $

842

31

2,078 $

1,041

202

106

1,349

December 2019 Form 10-K

102

Nonrecurring Fair Value Measurements

Carrying and Fair Values

$ in millions

Assets

Loans

Other assets—Other investments

Total

Liabilities

Other liabilities and accrued

expenses—Lending commitments

Total

$ in millions

Assets

Loans

Other assets—Other investments

Total

Liabilities

Other liabilities and accrued

expenses—Lending commitments

Total

At December 31, 2019
Level 31

Total

Level 2

$

$

$

$

$

$

$

$

1,543 $

1,500 $

3,043

—

113

113

1,543 $

1,613 $

3,156

132 $

132 $

69 $

69 $

201

201

At December 31, 2018
Level 31

Level 2

Total

2,307 $

1,380 $

3,687

14

100

114

2,321 $

1,480 $

3,801

292 $

292 $

65 $

65 $

357

357

1. For significant Level 3 balances, refer to “Significant Unobservable Inputs Used in
Recurring  and  Nonrecurring  Level 3  Fair  Value  Measurements”  section  herein  for
details  of  the  significant  unobservable  inputs  used  for  nonrecurring  fair  value
measurement.

Gains (Losses) from Fair Value Remeasurements1

$ in millions

2019

2018

2017

Assets
Loans2
Other assets—Other investments3

Other assets—Premises, equipment

and software4

Total

Liabilities

Other liabilities and accrued

expenses—Lending commitments2

Total

$

$

$

$

18 $

(56)

(22)

(68) $

(56)

(46)

(60) $

(170) $

87 $

87 $

(48) $

(48) $

18

(66)

(25)

(73)

75

75

1. Gains and losses for Loans and Other assets—Other investments are classified in
Other revenues. For other items, gains and losses are recorded in Other revenues if
the item is held for sale; otherwise, they are recorded in Other expenses.

2. Nonrecurring  changes  in  the  fair  value  of  loans  and  lending  commitments  were
calculated as follows: for the held-for-investment category, based on the value of the
underlying collateral; and for the held-for-sale category, based on recently executed
transactions,  market  price  quotations,  valuation  models  that  incorporate  market
observable inputs where possible, such as comparable loan or debt prices and CDS
spread  levels  adjusted  for  any  basis  difference  between  cash  and  derivative
instruments, or default recovery analysis where such transactions and quotations are
unobservable.

3. Losses related to Other assets—Other investments were determined using techniques
that included discounted cash flow models, methodologies that incorporate multiples
of certain comparable companies and recently executed transactions.

4. Losses related to Other assets—Premises, equipment and software generally include

write-offs related to the disposal of certain assets.

Table of Contents
Notes to Consolidated Financial Statements

Financial Instruments Not Measured at Fair Value

Carrying
Value

$ in millions

Financial assets

Cash and cash equivalents:

At December 31, 2019

Fair Value

Level 1

Level 2

Level 3

Total

$ in millions

At December 31, 2018

Fair Value

Level 1

Level 2

Level 3

Total

Carrying
Value

$

4,293 $ 4,293 $

— $

— $ 4,293

45,366

45,366

32,512

32,512

—

—

— 45,366

— 32,512

Financial assets

Cash and cash equivalents:

Cash and due from

banks

Interest bearing

deposits with banks

Restricted cash

Investment securities—

$

30,541 $ 30,541 $

— $

— $ 30,541

21,299

21,299

35,356

35,356

—

—

— 21,299

— 35,356

43,502

30,661

12,683

789

44,133

HTM

30,771

17,473

12,018

474

29,965

88,220

106,549

51,134

130,637

— 86,794

1,442

88,236

— 106,551

— 106,551

— 48,215

2,872

51,087

— 22,293 108,059

130,352

495

—

495

—

495

Securities purchased 
under agreements to
resell

Securities borrowed

Customer and other

receivables1

Loans2

Other assets

Financial liabilities

98,522

116,313

47,972

115,579

— 97,611

866

98,477

— 116,312

— 116,312

— 44,620

3,219

47,839

— 25,604

90,121

115,725

461

—

461

—

461

53,467

— 53,486

— 53,486

—

—

8,506

6,800

—

92

8,506

6,892

— 195,035

— 195,035

8,506

6,889

195,035

128,166

Commitment
Amount

— 133,563

10

133,573

Borrowings

Securities sold under

agreements to
repurchase

Securities loaned

Other secured financings

Customer and other

payables1

48,947

11,908

4,221

176,561

138,478

Commitment
Amount

— 48,385

525

48,910

— 11,906

— 11,906

—

3,233

994

4,227

— 176,561

— 176,561

— 140,085

30

140,115

Cash and due from

banks

Interest bearing

deposits with banks

Restricted cash

Investment securities—

HTM

Securities purchased 
under agreements to
resell

Securities borrowed

Customer and other

receivables1

Loans2

Other assets

Financial liabilities

Securities sold  under

agreements to
repurchase

Securities loaned

Other secured financings

Customer and other

payables1

Borrowings

Deposits

$

188,257 $

— $188,639 $

— $188,639

Deposits

$

187,378 $

— $187,372 $

— $187,372

Lending

commitments3

$

119,004 $

— $

748 $

338 $ 1,086

Lending 

commitments3

$

104,844 $

— $ 1,249 $

321 $ 1,570

1. Accrued interest and dividend receivables and payables have been excluded. Carrying

value approximates fair value for these receivables and payables.
2. Amounts include loans measured at fair value on a nonrecurring basis.
3. Represents Lending commitments accounted for as Held for Investment and Held for

Sale. For a further discussion on lending commitments, see Note 13.

The previous tables exclude certain financial instruments such
as equity method investments and all non-financial assets and
liabilities such as the value of the long-term relationships with
the Firm’s deposit customers.

4. Fair Value Option 

The Firm has elected the fair value option for certain eligible
instruments that are risk managed on a fair value basis to mitigate
income  statement  volatility  caused  by  measurement  basis
differences between the elected instruments and their associated
risk management transactions or to eliminate complexities of
applying certain accounting models.

103

December 2019 Form 10-K

 
Table of Contents
Notes to Consolidated Financial Statements

Borrowings Measured at Fair Value on a Recurring Basis

Difference between Contractual Principal and Fair Value1

$ in millions

At
December 31, 
 2019

At
December 31, 
 2018

Business Unit Responsible for Risk Management

Equity

Interest rates

Commodities

Credit

Foreign exchange

Total

$

$

30,214 $

27,298

4,501

1,246

1,202

24,494

22,343

2,735

856

756

64,461 $

51,184

Net Revenues from Borrowings under the Fair Value Option

$ in millions

Trading revenues

Interest expense
Net revenues1

2019

2018

2017

$ (6,932) $

2,679 $ (4,507)

375

321

443

$ (7,307) $

2,358 $ (4,950)

$ in millions
Loans and other debt2
Nonaccrual loans2 

Borrowings3

At
December 31, 
 2019

At
December 31, 
 2018

$

13,037 $

10,849

(1,665)

13,094

10,831

2,657

1. Amounts indicate contractual principal greater than or (less than) fair value.
2. The majority of the difference between principal and fair value amounts for loans and
other debt relates to distressed debt positions purchased at amounts well below par.
3. Excludes borrowings where the repayment of the initial principal amount fluctuates

based on changes in a reference price or index.

tables  exclude  non-recourse  debt 

The  previous 
from
consolidated  VIEs,  liabilities  related  to  transfers  of  financial
assets treated as collateralized financings, pledged commodities
and  other  liabilities  that  have  specified  assets  attributable  to
them.

1. Amounts do not reflect any gains or losses from related economic hedges.

Fair Value Loans on Nonaccrual Status

Gains (losses) from changes in fair value are recorded in Trading
revenues  and  are  mainly  attributable  to  movements  in  the
reference price or index, interest rates or foreign exchange rates.

Gains (Losses) Due to Changes in Instrument-Specific Credit
Risk

$ in millions

2019

Borrowings
Loans and other debt1

Lending commitments

Other

2018

Borrowings
Loans and other debt1

Lending commitments

Other

2017

Borrowings
Loans and other debt1

Lending commitments

Other

Trading
Revenues

OCI

$

$

$

(11) $

(2,140)

223

(2)

—

—

—

(30)

(24) $

1,962

165

(3)

(32)

(12) $

159

(2)

—

—

—

41

(903)

—

—

(7)

$ in millions

Cumulative pre-tax DVA 

gain (loss) recognized in 
AOCI

At
December 31,
2019

At
December 31,
2018

$

(1,998) $

172

1. Loans and other debt instrument-specific credit gains (losses) were determined by

excluding the non-credit components of gains and losses.

$ in millions

Nonaccrual loans

Nonaccrual loans 90 or more 

days past due

At
December 31, 
 2019

At
December 31, 
 2018

$

$

1,100 $

330 $

1,497

812

5. Derivative Instruments and Hedging Activities

The Firm trades and makes markets globally in listed futures,
OTC  swaps, 
forwards,  options  and  other  derivatives
referencing,  among  other  things,  interest  rates,  equities,
currencies, 
investment  grade  and  non-investment  grade
corporate  credits,  loans,  bonds,  U.S.  and  other  sovereign
securities,  emerging  market  bonds  and  loans,  credit  indices,
ABS indices, property indices, mortgage-related and other ABS,
and real estate loan products. The Firm uses these instruments
for  market-making,  foreign  currency  exposure  management,
and asset and liability management.

The Firm manages its market-making positions by employing
a variety of risk mitigation strategies. These strategies include
diversification of risk exposures and hedging. Hedging activities
consist of the purchase or sale of positions in related securities
and  financial  instruments,  including  a  variety  of  derivative
products (e.g., futures, forwards, swaps and options). The Firm
manages  the  market  risk  associated  with  its  market-making
activities on a Firmwide basis, on a worldwide trading division
level and on an individual product basis.

December 2019 Form 10-K

104

Table of Contents
Notes to Consolidated Financial Statements

Derivative Fair Values
At December 31, 2019 

At December 31, 2018 

Assets

Assets

$ in millions

Bilateral
OTC

Cleared
OTC

Exchange-
Traded

Total

$ in millions

Bilateral
OTC

Cleared
OTC

Exchange-
Traded

Total

Designated as accounting hedges

Designated as accounting hedges

Interest rate

Foreign exchange

Total

$

673 $

— $

— $

41

714

1

1

—

—

673

42

715

Interest rate

Foreign exchange

Total

$

512 $

1 $

— $

27

539

8

9

—

—

513

35

548

Not designated as accounting hedges

Not designated as accounting hedges

Interest rate

Credit

Foreign exchange

Equity

Commodity and other

Total

179,450

4,895

62,957

27,621

9,306

4,839

2,417

1,399

—

—

519

184,808

Interest rate

—

22

7,312

64,378

Credit

Foreign exchange

23,447

51,068

Equity

1,952

11,258

Commodity and other

153,768

4,630

61,846

24,590

10,538

3,887

1,498

1,310

—

—

697

158,352

—

55

6,128

63,211

23,284

47,874

1,934

12,472

284,229

8,655

25,940

318,824

Total

255,372

6,695

25,970

288,037

Total gross derivatives

$ 284,943 $ 8,656 $

25,940 $ 319,539

Total gross derivatives

$ 255,911 $ 6,704 $

25,970 $ 288,585

Amounts offset

Counterparty netting

Cash collateral netting

Total in Trading assets
Amounts not offset1

Amounts offset

(213,710)

(7,294)

(24,037)

(245,041)

Counterparty netting

(190,220)

(5,260)

(24,548)

(220,028)

(41,222)

(1,275)

— (42,497)

Cash collateral netting

(38,204)

(1,180)

— (39,384)

$ 30,011 $

87 $

1,903 $ 32,001

Total in Trading assets
Amounts not offset1

$ 27,487 $

264 $

1,422 $ 29,173

Financial instruments collateral

(15,596)

—

—

— (15,596)

Financial instruments collateral

(12,467)

—

(46)

Other cash collateral

(31)

—

—

— (12,467)

—

(31)

(46)

Other cash collateral

Net amounts

$ 14,369 $

87 $

1,903 $ 16,359

Net amounts

$ 14,989 $

264 $

1,422 $ 16,675

Net amounts for which master netting or collateral agreements

are not in place or may not be legally enforceable

$

1,900

are not in place or may not be legally enforceable

$

2,206

Net amounts for which master netting or collateral agreements 

Liabilities

Liabilities

$ in millions

Bilateral
OTC

Cleared
OTC

Exchange-
Traded

Total

$ in millions

Bilateral
OTC

Cleared
OTC

Exchange-
Traded

Total

Designated as accounting hedges

Designated as accounting hedges

Interest rate

Foreign exchange

Total

$

1 $

— $

— $

121

122

38

38

—

—

1

159

160

Interest rate

Foreign exchange

Total

$

176 $

— $

— $

62

238

24

24

—

—

176

86

262

Not designated as accounting hedges

Not designated as accounting hedges

Interest rate

Credit

Foreign exchange

Equity

Commodity and other

Total

168,597

4,798

65,965

30,135

7,713

3,597

3,123

1,492

—

—

436

172,630

Interest rate

—

39

7,921

67,496

Credit

Foreign exchange

22,733

52,868

Equity

1,911

9,624

Commodity and other

142,592

4,545

62,099

27,119

6,983

2,669

1,608

1,302

—

—

663

145,924

—

19

6,153

63,420

23,521

50,640

2,057

9,040

277,208

8,212

25,119

310,539

Total

243,338

5,579

26,260

275,177

Total gross derivatives

$ 277,330 $ 8,250 $

25,119 $ 310,699

Total gross derivatives

$ 243,576 $ 5,603 $

26,260 $ 275,439

Amounts offset

Counterparty netting

Cash collateral netting

Total in Trading liabilities
Amounts not offset1

Financial instruments collateral

Other cash collateral

Net amounts

Amounts offset

(213,710)

(7,294)

(24,037)

(245,041)

Counterparty netting

(190,220)

(5,260)

(24,548)

(220,028)

(36,392)

(832)

— (37,224)

Cash collateral netting

(27,860)

(293)

— (28,153)

$ 27,228 $

124 $

1,082 $ 28,434

Total in Trading liabilities
Amounts not offset1

$ 25,496 $

50 $

1,712 $ 27,258

(7,747)

(14)

—

—

(287)

(8,034)

Financial instruments collateral

—

(14)

Other cash collateral

(4,709)

(53)

—

(1)

(766)

(5,475)

—

(54)

$ 19,467 $

124 $

795 $ 20,386

Net amounts

$ 20,734 $

49 $

946 $ 21,729

Net amounts for which master netting or collateral agreements 

are not in place or may not be legally enforceable

$

3,680

are not in place or may not be legally enforceable

$

4,773

Net amounts for which master netting or collateral agreements 

1. Amounts relate to master netting agreements and collateral agreements that have
been determined by the Firm to be legally enforceable in the event of default but where
certain other criteria are not met in accordance with applicable offsetting accounting
guidance.

105

December 2019 Form 10-K

 
Table of Contents
Notes to Consolidated Financial Statements

See Note 3 for information related to the unsettled fair value of
futures contracts not designated as accounting hedges, which
are excluded from the previous tables.

$ in billions

Liabilities

Bilateral
OTC

Cleared
OTC

Exchange-
Traded

Total

Derivative Notionals
At December 31, 2019

$ in billions

Bilateral
OTC

Cleared
OTC

Exchange-
Traded

Total

Designated as accounting hedges

Assets

Interest rate

Credit

Not designated as accounting hedges

$

14 $

94 $

— $

108

Foreign exchange

2

16

—

94

—

—

2

110

Equity

Commodity and other

Total

Interest rate

Foreign exchange

Total

Interest rate

Credit

Foreign exchange

Equity

Commodity and other

Total

136

2,667

429

99

79

91

—

—

—

10

419

61

215

2,768

848

160

7,561

7,568

1,222

16,351

Total gross derivatives

$

7,577 $ 7,662 $

1,222 $ 16,461

$ in billions

Liabilities

Bilateral
OTC

Cleared
OTC

Exchange-
Traded

Total

Designated as accounting hedges

Designated as accounting hedges

Interest rate

Foreign exchange

Total

$

2 $

107 $

— $

109

5

7

1

108

—

—

6

115

Not designated as accounting hedges

4,946

5,735

781

11,462

162

2,451

389

72

73

114

—

—

—

17

602

65

235

2,582

991

137

8,020

5,922

1,465

15,407

its  exposure. 

The  Firm  believes  that  the  notional  amounts  of  derivative
contracts  generally  overstate 
In  most
circumstances, notional amounts are used only as a reference
point from which to calculate amounts owed between the parties
to the contract. Furthermore, notional amounts do not reflect the
benefit  of  legally  enforceable  netting  arrangements  or  risk
mitigating transactions.

Gains (Losses) on Accounting Hedges

4,230

7,398

732

12,360

Total gross derivatives

$

8,027 $ 6,030 $

1,465 $ 15,522

Interest rate

Foreign exchange

Total

$

— $

71 $

— $

9

9

2

73

—

—

71

11

82

Not designated as accounting hedges

2019
$ in millions
Fair value hedges—Recognized in Interest income1

2018

2017

Interest rate contracts

Investment Securities—AFS

$

(10) $

10

(4) $

4

—

—

Interest rate

Credit

Foreign exchange

Equity

Commodity and other

Total

4,185

6,866

666

11,717

Fair value hedges—Recognized in Interest expense

153

2,841

455

85

84

91

—

—

—

14

515

61

237

2,946

970

146

Interest rate contracts
Deposits2

Borrowings

$

4,212 $ (1,529) $ (1,591)

7

—

—

(4,288)

1,511

1,393

Net investment hedges—Foreign exchange contracts

7,719

7,041

1,256

16,016

Recognized in OCI

$

14 $

295 $

(365)

Total gross derivatives

$

7,728 $ 7,114 $

1,256 $ 16,098

Forward points excluded from hedge 

effectiveness testing—Recognized in 
Interest income

136

68

(20)

At December 31, 2018 

Assets

$ in billions

Bilateral
OTC

Cleared
OTC

Exchange-
Traded

Total

Designated as accounting hedges

Interest rate

Foreign exchange

Total

$

15 $

52 $

— $

5

20

1

53

—

—

67

6

73

Not designated as accounting hedges

Interest rate

Credit

Foreign exchange

Equity

Commodity and other

Total

4,807

6,708

1,157

12,672

162

2,436

373

97

74

118

—

—

—

14

371

67

236

2,568

744

164

7,875

6,900

1,609

16,384

Total gross derivatives

$

7,895 $ 6,953 $

1,609 $ 16,457

December 2019 Form 10-K

106

Table of Contents
Notes to Consolidated Financial Statements

Fair Value Hedges—Hedged Items

$ in millions
Investment securities—AFS1
Carrying amount3 currently or previously

hedged

Basis adjustments included in carrying

amount4
Deposits2
Carrying amount3 currently or previously

hedged

Basis adjustments included in carrying

amount4

Borrowings
Carrying amount3 currently or previously

hedged

Basis adjustments included in carrying

amount4

$

$

$

$

$

$

At
December 31, 
 2019

At
December 31, 
 2018

event of one-notch or two-notch downgrade scenarios based on
the relevant contractual downgrade triggers.

Maximum Potential Payout/Notional of Credit Protection Sold1

917 $

201

$ in billions

< 1

1-3

3-5

Over 5

Total

Years to Maturity at December 31, 2019

14 $

5,435 $

(7) $

4

—

—

102,456 $

102,899

Single-name CDS

Investment grade

Non-investment grade

Total

Index and basket CDS

Investment grade

Non-investment grade

Total

Total CDS sold

2,593 $

(1,689)

Other credit contracts

$

$

$

$

$

$

16 $

17 $

33 $

9 $

9

9

16

1

75

35

25 $

26 $

49 $

10 $

110

4 $

7 $

46 $

11 $

7

4

17

10

68

38

11 $

11 $

63 $

21 $

106

36 $

37 $

112 $

31 $

216

—

—

—

—

—

36 $

37 $

112 $

31 $

216

1. The Firm began designating interest rate swaps as fair value hedges of certain AFS

securities in the third quarter of 2018.

2. The  Firm  began  designating  interest  rate  swaps  as  fair  value  hedges  of  certain

Deposits in the fourth quarter of 2019.

3. Carrying amount represents amortized cost basis.
4. Hedge accounting basis adjustments for AFS securities, Deposits and Borrowings are

primarily related to outstanding hedges.

Derivatives with Credit Risk-Related Contingencies

Net Derivative Liabilities and Collateral Posted

$ in millions

Net derivative liabilities with credit risk-

related contingent features

Collateral posted

At
December 31, 
 2019

At
December 31, 
 2018

$

21,620 $

17,392

16,403

11,981

The previous table presents the aggregate fair value of certain
derivative contracts that contain credit risk-related contingent
features that are in a net liability position for which the Firm has
posted collateral in the normal course of business.

Incremental  Collateral  and  Termination  Payments  upon
Potential Future Ratings Downgrade

$ in millions

One-notch downgrade

Two-notch downgrade

Bilateral downgrade agreements included in the amounts

above1

At
December 31, 
 2019

$

$

254

328

498

1. Amount represents arrangements between the Firm and other parties where upon the
downgrade of one party, the downgraded party must deliver collateral to the other
party. These bilateral downgrade arrangements are used by the Firm to manage the
risk of counterparty downgrades.

The additional collateral or termination payments that may be
called in the event of a future credit rating downgrade vary by
contract and can be based on ratings by either or both of Moody’s
Investors Service, Inc. (“Moody’s”) and S&P Global Ratings.
The previous table shows the future potential collateral amounts
and termination payments that could be called or required by
counterparties  or  exchange  and  clearing  organizations  in  the

Total credit protection sold

CDS protection sold with identical protection purchased

$

187

$ in billions

Single-name CDS

Investment grade

Non-investment grade

Total

Index and basket CDS

Investment grade

Non-investment grade

Total

Total CDS sold

Other credit contracts

Total credit protection sold

Years to Maturity at December 31, 2018

< 1

1-3

3-5

Over 5

Total

$

$

$

$

$

$

22 $

24 $

19 $

8 $

10

11

9

1

73

31

32 $

35 $

28 $

9 $

104

5 $

10 $

61 $

7 $

5

6

13

13

83

37

10 $

16 $

74 $

20 $

120

42 $

51 $

102 $

29 $

224

—

—

—

—

—

42 $

51 $

102 $

29 $

224

CDS protection sold with identical protection purchased

$

210

Fair Value Asset (Liability) of Credit Protection Sold1

$ in millions

Single-name CDS

Investment grade

Non-investment grade

Total

Index and basket CDS

Investment grade

Non-investment grade

Total

Total CDS sold

Other credit contracts

Total credit protection sold

At
December 31, 
 2019

At
December 31, 
 2018

$

$

$

$

$

$

1,057 $

(540)

517 $

1,052 $

134

1,186 $

1,703 $

(17)

1,686 $

118

(403)

(285)

314

(1,413)

(1,099)

(1,384)

(14)

(1,398)

1. Investment grade/non-investment grade determination is based on the internal credit
rating  of  the  reference  obligation.  Internal  credit  ratings  serve  as  the  Credit  Risk
Management  Department’s  assessment  of  credit  risk  and  the  basis  for  a
comprehensive  credit  limits  framework  used  to  control  credit  risk.  The  Firm  uses
quantitative models and judgment to estimate the various risk parameters related to
each obligor.

107

December 2019 Form 10-K

 
 
Table of Contents
Notes to Consolidated Financial Statements

Protection Purchased with CDS

$ in billions

Single name

Index and basket

Tranched index and basket

Total

$ in millions

Single name

Index and basket

Tranched index and basket

Total

Notional

At
December 31,
2019

At
December 31,
2018

$

$

118 $

103

15

236 $

116

117

14

247

Fair Value Asset (Liability)

At
December 31,
2019

At
December 31,
2018

$

$

(723) $

(1,139)

(450)

(2,312) $

277

1,333

(251)

1,359

The Firm enters into credit derivatives, principally CDS, under
which  it  receives  or  provides  protection  against  the  risk  of
default on a set of debt obligations issued by a specified reference
entity  or  entities. A  majority  of  the  Firm’s  counterparties  for
these derivatives are banks, broker-dealers, and insurance and
other financial institutions.

The fair value amounts as shown in the previous tables are prior
to cash collateral or counterparty netting.

The purchase of credit protection does not represent the sole
manner in which the Firm risk manages its exposure to credit
derivatives. The Firm manages its exposure to these derivative
contracts through a variety of risk mitigation strategies, which
include managing the credit and correlation risk across single-
name, non-tranched indices and baskets, tranched indices and
baskets, and cash positions. Aggregate market risk limits have
been established for credit derivatives, and market risk measures
are routinely monitored against these limits. The Firm may also
recover  amounts  on  the  underlying  reference  obligation
delivered to the Firm under CDS where credit protection was
sold.

Single-Name CDS.    A CDS protects the buyer against the loss
of principal on a bond or loan in case of a default by the issuer.
The  protection  buyer  pays  a  periodic  premium  (generally
quarterly) over the life of the contract and is protected for the
period. The Firm, in turn, performs under a CDS if a credit event
as  defined  under  the  contract  occurs.  Typical  credit  events
include bankruptcy, dissolution or insolvency of the referenced
entity, failure to pay and restructuring of the obligations of the
referenced entity.

Index and Basket CDS.    Index and basket CDS are products
where credit protection is provided on a portfolio of single-name
CDS. Generally, in the event of a default on one of the underlying
names,  the  Firm  pays  a  pro  rata  portion  of  the  total  notional
amount of the CDS.

The Firm also enters into tranched index and basket CDS where
credit  protection  is  provided  on  a  particular  portion  of  the
portfolio loss distribution. The most junior tranches cover initial
defaults, and once losses exceed the notional of the tranche, they
are  passed  on  to  the  next  most  senior  tranche  in  the  capital
structure.

Other Credit Contracts.    The Firm has invested in CLNs and
CDOs,  which  are  hybrid  instruments  containing  embedded
derivatives, in which credit protection has been sold to the issuer
of  the  note.  If  there  is  a  credit  event  of  a  reference  entity
underlying the instrument, the principal balance of the note may
not be repaid in full to the Firm.

December 2019 Form 10-K

108

 
 
Table of Contents
Notes to Consolidated Financial Statements

6. Investment Securities 

AFS and HTM Securities

$ in millions

AFS securities

At December 31, 2019

Amortized
Cost

Gross
Unrealized
Gains

Gross
Unrealized
Losses

Fair
Value

$ in millions

AFS securities

At December 31, 2018

Amortized
Cost

Gross
Unrealized
Gains

Gross
Unrealized
Losses

Fair
Value

U.S. government and agency securities:

U.S. government and agency securities:

$ 32,465 $

224 $

111 $ 32,578

$

36,268 $

40 $

656 $ 35,652

U.S. Treasury securities
U.S. agency securities1

Total U.S. government and

agency securities

Corporate and other debt:

Agency CMBS

Corporate bonds

State and municipal 

securities

FFELP student loan 

ABS2

Total corporate and other 

debt

Total AFS securities

HTM securities

U.S. Treasury securities
U.S. agency securities1

Total U.S. government and

agency securities

Corporate and other debt:

Non-agency CMBS

Total HTM securities

Total investment 

securities

20,725

53,190

4,810

1,891

481

1,580

8,762

61,952

30,145

12,589

42,734

768

43,502

249

473

55

17

22

1

95

568

568

151

719

22

741

100

20,874

211

53,452

57

1

—

28

4,808

1,907

503

1,553

86

297

8,771

62,223

52

57

30,661

12,683

109

43,344

1

789

110

44,133

$ 105,454 $

1,309 $

407 $106,356

U.S. government and agency securities:

U.S. Treasury securities
U.S. agency securities1

Total U.S. government and

agency securities

Corporate and other debt:

Agency CMBS

Non-agency CMBS

Corporate bonds

State and municipal

securities

FFELP student loan 

ABS2

Total corporate and other 

debt

Total AFS securities

HTM securities

U.S. Treasury securities
U.S. agency securities1

Total U.S. government and

agency securities

Corporate and other debt:

Non-agency CMBS

Total HTM securities

Total investment 

securities

U.S. government and agency securities:

20,740

57,008

1,054

461

1,585

200

1,967

5,267

62,275

17,832

12,456

30,288

483

30,771

10

50

—

—

—

2

10

12

62

44

8

52

—

52

497

20,253

1,153

55,905

62

14

32

—

15

992

447

1,553

202

1,962

123

5,156

1,276

61,061

403

446

17,473

12,018

849

29,491

9

474

858

29,965

$

93,046 $

114 $

2,134 $ 91,026

1. U.S. agency securities consist mainly of agency-issued debt, agency mortgage pass-

through pool securities and CMOs.

2. Underlying loans are backed by a guarantee, ultimately from the U.S. Department of

Education, of at least 95% of the principal balance and interest outstanding.

109

December 2019 Form 10-K

 
Table of Contents
Notes to Consolidated Financial Statements

Investment Securities in an Unrealized Loss Position

$ in millions

AFS securities

U.S. government and agency securities:

U.S. Treasury securities

U.S. agency securities

Total U.S. government and agency securities

Corporate and other debt:

Agency CMBS

Corporate bonds

FFELP student loan ABS

Total corporate and other debt

Total AFS securities

HTM securities

U.S. government and agency securities:

U.S. Treasury securities

U.S. agency securities

Total U.S. government and agency securities

Corporate and other debt:

Non-agency CMBS

Total HTM securities

Total investment securities

$ in millions

AFS securities

U.S. government and agency securities:

U.S. Treasury securities

U.S. agency securities

Total U.S. government and agency securities

Corporate and other debt:

Agency CMBS

Non-agency CMBS

Corporate bonds

FFELP student loan ABS

Total corporate and other debt

Total AFS securities

HTM securities

U.S. government and agency securities:

U.S. Treasury securities

U.S. agency securities

Total U.S. government and agency securities

Corporate and other debt:

Non-agency CMBS

Total HTM securities

Total investment securities

At December 31, 2019

Less than 12 Months

12 Months or Longer

Total

Fair Value

Gross
Unrealized
Losses

Fair Value

Gross
Unrealized
Losses

Fair Value

Gross
Unrealized
Losses

$

4,793 $

28 $

7,904 $

83 $

12,697 $

2,641

7,434

2,294

194

91

2,579

10,013

6,042

2,524

8,566

167

8,733

20

48

26

1

—

27

75

52

18

70

1

71

7,697

15,601

681

44

1,165

1,890

17,491

651

2,420

3,071

65

3,136

80

163

31

—

28

59

222

—

39

39

—

39

10,338

23,035

2,975

238

1,256

4,469

6,693

4,944

11,637

232

11,869

27,504

297

111

100

211

57

1

28

86

52

57

109

1

110

407

$

18,746 $

146 $

20,627 $

261 $

39,373 $

At December 31, 2018

Less than 12 Months

12 Months or Longer

Total

Fair Value

Gross
Unrealized
Losses

Fair Value

Gross
Unrealized
Losses

Fair Value

Gross
Unrealized
Losses

$

19,937 $

541 $

5,994 $

115 $

25,931 $

12,904

32,841

808

—

470

1,366

2,644

383

924

62

—

7

15

84

35,485

1,008

—

410

410

206

616

—

1

1

1

2

4,142

10,136

—

446

1,010

—

1,456

11,592

11,161

10,004

21,165

216

21,381

114

229

—

14

25

—

39

17,046

42,977

808

446

1,480

1,366

4,100

268

47,077

403

445

848

8

856

11,161

10,414

21,575

422

21,997

656

497

1,153

62

14

32

15

123

1,276

403

446

849

9

858

$

36,101 $

1,010 $

32,973 $

1,124 $

69,074 $

2,134

December 2019 Form 10-K

110

 
Table of Contents
Notes to Consolidated Financial Statements

that  are  other-than-temporarily 

The Firm believes there are no securities in an unrealized loss
impaired  after
position 
performing the analysis described in Note 2. For AFS securities,
the Firm does not intend to sell the securities and is not likely
to  be  required  to  sell  the  securities  prior  to  recovery  of  the
amortized  cost  basis.  Furthermore,  for  both  AFS  and  HTM
securities, the securities have not experienced credit losses as
the unrealized losses reported in the previous table are primarily
due to higher interest rates since those securities were purchased.

See Note 14 for additional information on securities issued by
VIEs, including U.S. agency mortgage-backed securities, non-
agency CMBS and FFELP student loan ABS.

Investment Securities by Contractual Maturity

$ in millions
$ in millions

AFS securities
AFS securities

At December 31, 2019
At December 31, 2019

Amortized
Amortized
Cost
Cost

Fair
Fair
Value
Value

Annualized
Annualized
Average
Average
Yield
Yield

U.S. government and agency securities:
U.S. government and agency securities:

U.S. Treasury securities:
U.S. Treasury securities:

Due within 1 year
Due within 1 year

$
$

2,293 $
2,293 $

2,302
2,302

After 1 year through 5 years
After 1 year through 5 years

After 5 years through 10 years
After 5 years through 10 years

Total
Total

U.S. agency securities:
U.S. agency securities:
Due within 1 year
Due within 1 year

After 1 year through 5 years
After 1 year through 5 years

After 5 years through 10 years
After 5 years through 10 years

After 10 years
After 10 years

Total
Total

Total U.S. government and agency
Total U.S. government and agency

securities
securities

Corporate and other debt:
Corporate and other debt:

Agency CMBS:
Agency CMBS:

After 1 year through 5 years
After 1 year through 5 years

After 5 years through 10 years
After 5 years through 10 years

After 10 years
After 10 years

Total
Total

Corporate bonds:
Corporate bonds:

Due within 1 year
Due within 1 year

After 1 year through 5 years
After 1 year through 5 years

After 5 years through 10 years
After 5 years through 10 years

Total
Total

State and municipal securities:
State and municipal securities:

After 1 year through 5 years
After 1 year through 5 years

After 5 years through 10 years
After 5 years through 10 years

After 10 years
After 10 years

Total
Total

FFELP student loan ABS:
FFELP student loan ABS:

After 1 year through 5 years
After 1 year through 5 years

After 5 years through 10 years
After 5 years through 10 years

After 10 years
After 10 years

Total
Total

Total corporate and other debt
Total corporate and other debt

Total AFS securities
Total AFS securities

25,919
25,919

4,253
4,253

32,465
32,465

310
310

362
362

1,380
1,380

18,673
18,673

20,725
20,725

26,037
26,037

4,239
4,239

32,578
32,578

310
310

359
359

1,373
1,373

18,832
18,832

20,874
20,874

2.2%
2.2%

1.8%
1.8%

1.7%
1.7%

1.0%
1.0%

1.4%
1.4%

1.8%
1.8%

2.4%
2.4%

53,190
53,190

53,452
53,452

2.0%
2.0%

606
606

3,280
3,280

924
924

4,810
4,810

43
43

1,448
1,448

400
400

1,891
1,891

36
36

71
71

374
374

481
481

71
71

377
377

1,132
1,132

1,580
1,580

8,762
8,762

603
603

3,305
3,305

900
900

4,808
4,808

43
43

1,462
1,462

402
402

1,907
1,907

37
37

72
72

394
394

503
503

69
69

367
367

1,117
1,117

1,553
1,553

8,771
8,771

61,952
61,952

62,223
62,223

1.8%
1.8%

2.5%
2.5%

2.0%
2.0%

1.7%
1.7%

2.6%
2.6%

2.9%
2.9%

3.1%
3.1%

2.2%
2.2%

4.7%
4.7%

0.8%
0.8%

0.8%
0.8%

1.2%
1.2%

2.2%
2.2%

2.0%
2.0%

$ in millions
$ in millions

HTM securities
HTM securities

At December 31, 2019
At December 31, 2019

Amortized
Amortized
Cost
Cost

Fair
Fair
Value
Value

Annualized
Annualized
Average
Average
Yield
Yield

U.S. government and agency securities:
U.S. government and agency securities:

U.S. Treasury securities:
U.S. Treasury securities:

Due within 1 year
Due within 1 year

$
$

2,436 $
2,436 $

2,452
2,452

After 1 year through 5 years
After 1 year through 5 years

18,026
18,026

18,254
18,254

After 5 years through 10 years
After 5 years through 10 years

After 10 years
After 10 years

Total
Total

U.S. agency securities:
U.S. agency securities:

After 5 years through 10 years
After 5 years through 10 years

After 10 years
After 10 years

Total
Total

Total U.S. government and agency
Total U.S. government and agency

securities
securities

Corporate and other debt:
Corporate and other debt:

Non-agency CMBS:
Non-agency CMBS:

Due within 1 year
Due within 1 year

After 1 year through 5 years
After 1 year through 5 years

After 5 years through 10 years
After 5 years through 10 years

After 10 years
After 10 years

Total corporate and other debt
Total corporate and other debt

8,600
8,600

1,083
1,083

8,842
8,842

1,113
1,113

30,145
30,145

30,661
30,661

46
46

12,543
12,543

12,589
12,589

45
45

12,638
12,638

12,683
12,683

91
91

125
125

514
514

38
38

768
768

91
91

125
125

532
532

41
41

789
789

Total HTM securities
Total HTM securities

43,502
43,502

44,133
44,133

Total investment securities
Total investment securities

$
$

105,454 $
105,454 $

106,356
106,356

42,734
42,734

43,344
43,344

2.3%
2.3%

2.5%
2.5%

2.1%
2.1%

2.2%
2.2%

2.5%
2.5%

1.8%
1.8%

2.6%
2.6%

4.9%
4.9%

5.5%
5.5%

5.3%
5.3%

2.1%
2.1%

4.0%
4.0%

2.3%
2.3%

2.2%
2.2%

Gross Realized Gains (Losses) on Sales of AFS Securities

$ in millions

Gross realized gains

Gross realized (losses)
Total1

2019

2018

2017

$

$

113 $

12 $

(10)

103 $

(4)

8 $

46

(11)

35

1. Realized gains and losses are recognized in Other revenues in the income statements.

111

December 2019 Form 10-K

Table of Contents
Notes to Consolidated Financial Statements

7. Collateralized Transactions 

Offsetting of Certain Collateralized Transactions

The Firm enters into securities purchased under agreements to
resell, securities sold under agreements to repurchase, securities
borrowed  and  securities  loaned  transactions  to,  among  other
things, acquire securities to cover short positions and settle other
securities obligations, to accommodate customers’ needs and to
finance its inventory positions.

The  Firm  manages  credit  exposure  arising  from  such
transactions  by,  in  appropriate  circumstances,  entering  into
master netting agreements and collateral agreements with  its
counterparties.  These  agreements  provide  the  Firm  with  the
right,  in  the  event  of  a  default  by  the  counterparty,  to  net  a
counterparty's  rights and obligations under the agreement and
to liquidate and set off collateral held by the Firm against the
net amount owed by the counterparty.

The Firm’s policy is generally to take possession of securities
purchased or borrowed in connection with securities purchased
under agreements to resell and securities borrowed transactions,
respectively, and to receive cash and securities delivered under
securities  sold  under  agreements  to  repurchase  or  securities
loaned transactions (with rights of rehypothecation). 

The Firm also monitors the fair value of the underlying securities
as compared with the related receivable or payable, including
accrued  interest,  and,  as  necessary,  requests  additional
collateral, as provided under the applicable agreement to ensure
such transactions are adequately collateralized, or the return of
excess collateral.

The risk related to a decline in the market value of collateral
pledged or received is managed by setting appropriate market-
based margin requirements. Increases in collateral margin calls
on  secured  financing  due  to  market  value  declines  may  be
mitigated by increases in collateral margin calls on securities
purchased under agreements to resell and securities borrowed
transactions  with  similar  quality  collateral.  Additionally,  the
Firm may request lower quality collateral pledged be replaced
with  higher  quality  collateral  through  collateral  substitution
rights in the underlying agreements.

The Firm actively manages its secured financings in a manner
that reduces the potential refinancing risk of secured financings
of less liquid assets and also considers the quality of collateral
when negotiating collateral eligibility with counterparties. The
Firm utilizes shorter term secured financing for highly liquid
assets  and  has  established  longer  tenor  limits  for  less  liquid
assets, for which funding may be at risk in the event of a market
disruption. 

At December 31, 2019

Gross
Amounts

Amounts
Offset

Balance
Sheet Net
Amounts

Amounts
Not Offset1

Net
Amounts

$247,545 $ (159,321) $ 88,224 $ (85,200) $ 3,024

109,528

(2,979)

106,549

(101,850)

4,699

$213,519 $ (159,319) $ 54,200 $ (44,549) $ 9,651

$ in millions

Assets

Securities

purchased under
agreements to
resell

Securities
borrowed

Liabilities

Securities sold

under
agreements to
repurchase

Securities loaned

11,487

(2,981)

8,506

(8,324)

182

Net amounts for which master netting agreements are not in place or

may not be legally enforceable

Securities purchased under agreements to resell

Securities borrowed

Securities sold under agreements to repurchase

Securities loaned

$ 2,255

1,181

8,033

101

At December 31, 2018

Gross
Amounts

Amounts
Offset

Balance
Sheet Net
Amounts

Amounts
Not Offset1

Net
Amounts

$262,976 $ (164,454) $ 98,522 $ (95,610) $ 2,912

134,711

(18,398)

116,313

(112,551)

3,762

$214,213 $ (164,454) $ 49,759 $ (41,095) $ 8,664

$ in millions

Assets

Securities

purchased under
agreements to
resell

Securities
borrowed

Liabilities

Securities sold

under
agreements to
repurchase

Securities loaned

30,306

(18,398)

11,908

(11,677)

231

Net amounts for which master netting agreements are not in place or

may not be legally enforceable

Securities purchased under agreements to resell

Securities borrowed

Securities sold under agreements to repurchase

Securities loaned

$ 2,579

724

6,762

191

1. Amounts relate to master netting agreements that have been determined by the Firm
to be legally enforceable in the event of default but where certain other criteria are not
met in accordance with applicable offsetting accounting guidance.

For information related to offsetting of derivatives, see Note 5.

December 2019 Form 10-K

112

Table of Contents
Notes to Consolidated Financial Statements

Gross Secured Financing Balances by Remaining Contractual
Maturity

Carrying  Value  of  Assets  Loaned  or  Pledged  without
Counterparty Right to Sell or Repledge

$ in millions

Securities sold under

agreements to
repurchase

At December 31, 2019

Overnight
and Open

Less than
30 Days

30-90
Days

Over
90 Days

Total

$ in millions

Trading assets

Loans (gross of allowance for loan losses)

$ 67,158 $ 81,300 $26,904 $ 38,157 $213,519

Total

At
December 31, 
 2019

At
December 31, 
 2018

$

$

41,201 $

39,430

750

—

41,951 $

39,430

Securities loaned

2,378

3,286

516

5,307

11,487

Total included in the

offsetting disclosure

Trading liabilities—

Obligation to return
securities received
as collateral

$ 69,536 $ 84,586 $27,420 $ 43,464 $225,006

23,877

—

—

— 23,877

Total

$ 93,413 $ 84,586 $27,420 $ 43,464 $248,883

$ in millions

Securities sold under

agreements to
repurchase

At December 31, 2018

Overnight
and Open

Less than
30 Days

30-90
Days

Over
90 Days

Total

$ 56,503 $ 93,427 $35,692 $ 28,591 $214,213

Securities loaned

18,397

3,609

1,985

6,315

30,306

Total included in the

offsetting disclosure

Trading liabilities—

Obligation to return
securities received
as collateral

$ 74,900 $ 97,036 $37,677 $ 34,906 $244,519

17,594

—

—

— 17,594

Total

$ 92,494 $ 97,036 $37,677 $ 34,906 $262,113

The  Firm  pledges  certain  of  its  trading  assets  and  loans  to
collateralize  securities  sold  under  agreements  to  repurchase,
securities loaned, other secured financings and derivatives and
to cover customer short sales. Counterparties may or may not
have the right to sell or repledge the collateral.

Pledged financial instruments that can be sold or repledged by
the secured party are identified as Trading assets (pledged to
various parties) in the balance sheets.

Fair Value of Collateral Received with Right to Sell or Repledge

$ in millions

Collateral received with right to sell

or repledge

Collateral that was sold or repledged1

539,412

$

679,280 $

639,610

487,983

At
December 31, 
 2019

At
December 31, 
 2018

Gross  Secured  Financing  Balances  by  Class of  Collateral
Pledged

dealers.

Restricted Cash and Segregated Securities

1. Does not include securities used to meet federal regulations for the Firm’s U.S. broker-

$ in millions

At
 December 31, 
 2019

At
 December 31, 
 2018

Securities sold under agreements to repurchase

U.S. Treasury and agency securities

$

68,895 $

68,487

State and municipal securities

905

925

Other sovereign government obligations

109,414

120,432

$ in millions

Restricted cash
Segregated securities1

Total

At
December 31, 
 2019

At
December 31, 
 2018

$

$

32,512 $

25,061

57,573 $

35,356

26,877

62,233

ABS

Corporate and other debt

Corporate equities

Other

Total

Securities loaned

Other sovereign government obligations

Corporate equities

Other

Total

Total included in the offsetting disclosure

2,218

6,066

25,563

458

3,017

8,719

12,079

554

213,519 $

214,213

3,026 $

8,422

39

19,021

10,800

485

11,487 $

30,306

225,006 $

244,519

$

$

$

$

Trading liabilities—Obligation to return securities received as collateral

Corporate equities

Other

Total

Total

$

$

$

23,873 $

17,594

4

—

23,877 $

17,594

248,883 $

262,113

1. Securities segregated under federal regulations for the Firm’s U.S. broker-dealers are
sourced from Securities purchased under agreements to resell and Trading assets in
the balance sheets.

The  Firm  receives  collateral  in  the  form  of  securities  in
connection with securities purchased under agreements to resell,
securities  borrowed,  securities-for-securities 
transactions,
derivative transactions, customer margin loans and securities-
based lending. In many cases, the Firm is permitted to sell or
repledge  this  collateral  to  secure  securities  sold  under
agreements to repurchase, to enter into securities lending and
derivative transactions or for delivery to counterparties to cover
short positions.

113

December 2019 Form 10-K

Table of Contents
Notes to Consolidated Financial Statements

Concentration Based on the Firm’s Total Assets

At
 December 31, 
 2019

At
 December 31, 
 2018

U.S. government and agency securities

and other sovereign government
obligations
Trading assets1
Off balance sheet—Collateral received2

10%

12%

12%

17%

1. Other sovereign government obligations included in Trading assets primarily consist
of the U.K., Japan and Australia at December 31, 2019, and UK., Japan and Brazil at
December 31, 2018.

2. Collateral received is primarily related to Securities purchased under agreements to

resell and Securities borrowed.

The  Firm  is  subject  to  concentration  risk  by  holding  large
positions in certain types of securities, loans or commitments to
purchase  securities  of  a  single  issuer,  including  sovereign
governments and other entities, issuers located in a particular
country or geographic area, public and private issuers involving
developing countries or issuers engaged in a particular industry.

Positions taken and underwriting and financing commitments,
including  those  made  in  connection  with  the  Firm’s  private
equity, principal investment and lending activities, often involve
substantial  amounts  and  significant  exposure  to  individual
issuers  and  businesses,  including  investment  grade  and  non-
investment grade issuers.

Customer Margin Lending

$ in millions

At
 December 31, 
 2019

At
 December 31, 
 2018

Customer receivables representing margin 

loans

$

31,916 $

26,225

The Firm provides margin lending arrangements which allow
customers to borrow against the value of qualifying securities.
Receivables under margin lending arrangements are included
within Customer and other receivables in the balance sheets.
Under  these  agreements  and  transactions,  the  Firm  receives
collateral,  which  includes  U.S.  government  and  agency
securities,  other  sovereign  government  obligations,  corporate
and  other  debt,  and  corporate  equities.  Customer  receivables
generated from margin lending activities are collateralized by
customer-owned securities held by the Firm. The Firm monitors
required margin levels and established credit terms daily and,
pursuant  to  such  guidelines,  requires  customers  to  deposit
additional collateral, or reduce positions, when necessary.

Margin loans are extended on a demand basis and generally are
not  committed  facilities.  Factors  considered  in  the  review  of
margin loans are the amount of the loan, the intended purpose,
the degree of leverage being employed in the account and the
amount  of  collateral,  as  well  as  an  overall  evaluation  of  the
portfolio  to  ensure  proper  diversification  or,  in  the  case  of
concentrated positions, appropriate liquidity of the underlying
collateral  or  potential  hedging  strategies  to  reduce  risk.
Underlying collateral for margin loans is reviewed with respect

December 2019 Form 10-K

114

to the liquidity of the proposed collateral positions, valuation of
securities,  historic  trading  range,  volatility  analysis  and  an
evaluation  of  industry  concentrations.  For  these  transactions,
adherence to the Firm’s collateral policies significantly limits
its credit exposure in the event of a customer default. The Firm
may  request  additional  margin  collateral  from  customers,  if
appropriate, and, if necessary, may sell securities that have not
been paid for or purchase securities sold but not delivered from
customers.

Other Secured Financings

Other  secured  financings  include  the  liabilities  related  to
transfers of financial assets that are accounted for as financings
rather than sales, consolidated VIEs where the Firm is deemed
to  be  the  primary  beneficiary,  and  certain  ELNs  and  other
secured borrowings. These liabilities are generally payable from
the cash flows of the related assets, which are accounted for as
Trading assets (see Notes 12 and 14).

8. Loans, Lending Commitments and Allowance
for Credit Losses 

The  Firm’s  loan  portfolio  consists  of  the  following  types  of
loans:

• Corporate.    Corporate loans primarily include commercial
and industrial lending used for general corporate purposes,
working  capital  and  liquidity,  event-driven  loans,  secured
lending facilities, and securities-based lending. Event-driven
loans support client merger, acquisition, recapitalization or
project finance activities. Corporate loans are structured as
revolving lines of credit, letter of credit facilities, term loans
and bridge loans. Risk factors considered in determining the
allowance for corporate loans include the borrower’s financial
strength, industry, facility structure, collateral and covenants
along with other qualitative factors.

• Consumer.    Consumer  loans  include  unsecured  loans  and
securities-based  lending,  which  allows  clients  to  borrow
money  against  the  value  of  qualifying  securities  for  any
suitable purpose other than purchasing, trading, or carrying
securities  or  refinancing  margin  debt.  The  majority  of
consumer loans are structured as revolving lines of credit. The
allowance  methodology  for  unsecured  loans  considers  the
specific attributes of the loan, as well as the borrower’s source
of  repayment.  The  allowance  methodology  for  securities-
based lending considers the collateral type underlying the loan
(e.g.,  diversified  securities,  concentrated  securities  or
restricted stock).

• Residential Real Estate.    Residential real estate loans mainly
include non-conforming loans and HELOC. The allowance
methodology for non-conforming residential mortgage loans
considers several factors, including, but not limited to, loan-
to-value ratio, FICO score, home price index and delinquency
status. The methodology for HELOC considers credit limits

 
Table of Contents
Notes to Consolidated Financial Statements

and utilization rates in addition to the factors considered for
non-conforming residential mortgages.

• Commercial  Real  Estate.    Commercial  real  estate  loans
include owner-occupied loans and income-producing loans.
The principal risk factors for determining the allowance for
commercial real estate loans are the underlying collateral type,
loan-to-value ratio and debt service ratio.

Loans by Type

$ in millions

Corporate

Consumer

Residential real estate
Commercial real estate1

Total loans, gross

Allowance for loan losses

At December 31, 2019

Loans Held
for Investment

Loans Held
for Sale

Total Loans

$

48,756 $

10,515 $

31,610

30,184

7,859

118,409

(349)

—

13

2,049

12,577

—

59,271

31,610

30,197

9,908

130,986

(349)

Total loans, net

$

118,060 $

12,577 $

130,637

Fixed rate loans, net

Floating or adjustable rate loans, net

Loans to non-U.S. borrowers, net

$

22,716

107,921

21,617

$ in millions

Corporate

Consumer

Residential real estate
Commercial real estate1

Total loans, gross

Allowance for loan losses

At December 31, 2018

Loans Held
for Investment

Loans Held
for Sale

Total Loans

$

36,909 $

13,886 $

27,868

27,466

7,810

100,053

(238)

—

22

1,856

15,764

—

50,795

27,868

27,488

9,666

115,817

(238)

Total loans, net

$

99,815 $

15,764 $

115,579

Fixed rate loans, net

Floating or adjustable rate loans, net

Loans to non-U.S. borrowers, net

$

15,632

99,947

17,568

1. Beginning in 2019, loans previously referred to as Wholesale real estate are referred

to as Commercial real estate. 

See Note 3 for further information regarding Loans and lending
commitments held at fair value. See Note 13 for details of current
commitments to lend in the future.

Credit Quality

CRM  evaluates  new  obligors  before  credit  transactions  are
initially approved and at least annually thereafter for corporate
and  commercial  real  estate  loans. For  corporate  loans,  credit
evaluations  typically  involve  the  evaluation  of  financial
statements, assessment of leverage, liquidity, capital strength,
asset composition and quality, market capitalization and access
to  capital  markets,  cash  flow  projections  and  debt  service
requirements, and the adequacy of collateral, if applicable. CRM
also  evaluates  strategy,  market  position,  industry  dynamics,
obligor’s  management  and  other  factors  that  could  affect  an
obligor’s risk profile. 

For commercial real estate loans, the credit evaluation is focused
on property and transaction metrics, including property type,
loan-to-value  ratio,  occupancy  levels,  debt  service  ratio,
prevailing capitalization rates and market dynamics. 

For residential real estate and consumer loans, the initial credit
evaluation typically includes, but is not limited to, review of the
obligor’s income, net worth, liquidity, collateral, loan-to-value
ratio  and  credit  bureau 
information.  Subsequent  credit
monitoring for residential real estate loans is performed at the
portfolio level. Consumer loan collateral values are monitored
on an ongoing basis.

The Firm utilizes the following credit quality indicators, which
are  consistent  with  U.S.  banking  agencies’  definitions  of
criticized  exposures,  as  applicable,  in  its  credit  monitoring
process for loans held for investment: 

• Pass.    A  credit  exposure  rated  Pass  has  a  continued
expectation  of  timely  repayment,  all  obligations  of  the
borrower are current, and the obligor complies with material
terms and conditions of the lending agreement.

• Special  Mention.    Extensions  of  credit  that  have  potential
weakness that deserve management’s close attention and, if
left  uncorrected,  may,  at  some  future  date,  result  in  the
deterioration of the repayment prospects or collateral position.

• Substandard.    Obligor  has  a  well-defined  weakness  that
jeopardizes  the  repayment  of  the  debt  and  has  a  high
probability  of  payment  default  with  the  distinct  possibility
that the Firm will sustain some loss if noted deficiencies are
not corrected.

• Doubtful.    Inherent  weakness  in  the  exposure  makes  the
collection  or  repayment  in  full,  based  on  existing  facts,
conditions  and  circumstances,  highly  improbable,  and  the
amount of loss is uncertain.

• Loss.    Extensions of credit classified as loss are considered

uncollectible and are charged off.

Loans considered as Doubtful or Loss are considered impaired.
Substandard loans are regularly reviewed for impairment. For
further information, see Note 2.

115

December 2019 Form 10-K

Table of Contents
Notes to Consolidated Financial Statements

Loans Held for Investment before Allowance by Credit Quality1

$ in millions

Corporate Consumer

Residential
Real Estate

Commercial
Real Estate

Total

$ in millions

Loans

At December 31, 2019

$ 47,681 $

31,605 $

30,060 $

7,664 $117,010

With allowance

Pass

Special

mention

Substandard

Doubtful

Total

464

605

6

—

5

—

28

96

—

3

192

—

495

898

6

$ 48,756 $

31,610 $

30,184 $

7,859 $118,409

At December 31, 2018

$ in millions

Corporate Consumer

Residential
Real Estate

Commercial
Real Estate

Total

Pass

Special

mention

Substandard

Doubtful

Total

$ 36,217 $

27,863 $

27,387 $

7,378 $ 98,845

492

200

—

5

—

—

—

79

—

312

120

—

809

399

—

$ 36,909 $

27,868 $

27,466 $

7,810 $100,053

1. There were no loans held for investment considered Loss as of December 31, 2019

and 2018.

Impaired Loans and Lending Commitments before Allowance

At December 31, 2019

Corporate Consumer

Residential
Real Estate

Commercial
Real Estate Total

$ in millions

Loans

With allowance

$

268 $

— $

— $

85 $ 353

Without

allowance1

Total impaired

loans

UPB

Lending

commitments

32

$

300 $

309

5

5 $

5

87

— 124

87 $

90

85 $ 477

85

489

With allowance

$

4 $

— $

— $

14 $ 18

32

—

—

—

32

Without

allowance1

Total impaired

lending
commitments

At December 31, 2018

Corporate Consumer

Residential
Real Estate

Commercial
Real Estate Total

$

$

$

24 $

— $

— $

— $ 24

32

—

69

— 101

56 $

63

— $

—

69 $

70

— $ 125

— 133

19 $

— $

— $

— $ 19

34

—

—

—

34

$

53 $

— $

— $

— $ 53

Without

allowance1

Total impaired

loans

UPB

Lending

commitments

With allowance

Without

allowance1

Total impaired

lending
commitments

1. At December 31, 2019 and December 31, 2018, no allowance was recorded for these
loans and lending commitments as the present value of the expected future cash flows
or value of the collateral held equaled or exceeded the carrying value.

Loans and lending commitments in the previous table have been
evaluated  for  a  specific  allowance.  All  remaining  loans  and
lending commitments are assessed under the inherent allowance
methodology.

Impaired Loans and Total Allowance by Region

$ in millions

Impaired loans

Total Allowance for loan

losses

At December 31, 2019

Americas

EMEA

Asia

Total

$

392 $

85 $

— $

477

270

76

3

349

$ in millions

Impaired loans

Total Allowance for loan

losses

At December 31, 2018

Americas

EMEA

Asia

Total

$

125 $

— $

— $

125

193

42

3

238

$

36 $

— $

— $

14 $ 50

Troubled Debt Restructurings

$ in millions

Loans

Lending commitments

Allowance for loan losses and lending 

commitments

At
December 31, 
 2019

At
December 31, 
 2018

$

92 $

32

16

38

45

4

Impaired loans and lending commitments classified as held for
investment  within  corporate  loans  include  TDRs.  These
restructurings typically include modifications of interest rates,
collateral  requirements,  other  loan  covenants  and  payment
extensions.

December 2019 Form 10-K

116

Table of Contents
Notes to Consolidated Financial Statements

Allowance for Loan Losses Rollforward

Allowance for Lending Commitments Rollforward

$ in millions

Corporate Consumer

Residential
Real Estate

Commercial
Real Estate

Total

$ in millions

Corporate Consumer

Residential
Real Estate

Commercial
Real Estate

Total

December 31,

2018

Gross 

charge-offs

Recoveries

Net recoveries
(charge-offs)

Provision
(release)

Other

December 31,

2019

Inherent

Specific

$

144 $

7 $

20 $

67 $ 238

—

—

—

104

(7)

241 $

212 $

29

$

$

—

—

—

1

—

8 $

8 $

—

(2)

—

(2)

7

—

25 $

25 $

—

—

—

—

8

—

(2)

—

(2)

120

(7)

75 $ 349

73 $ 318

2

31

$ in millions

Corporate Consumer

Residential
Real Estate

Commercial
Real Estate

Total

December 31,

2017

Gross charge-

offs

Recoveries

Net recoveries
(charge-offs)

Provision

(release)1

Other

December 31,

2018

Inherent

Specific

$

126 $

4 $

24 $

70 $ 224

(5)

54

49

(29)

(2)

—

—

—

3

—

$

$

144 $

139 $

5

7 $

7 $

—

(1)

—

(1)

(3)

—

20 $

20 $

—

—

—

—

5

(8)

(6)

54

48

(24)

(10)

67 $ 238

67 $ 233

—

5

December 31,

2018

Provision
(release)

Other

December 31,

2019

Inherent

Specific

$

198 $

2 $

— $

3 $ 203

38

(4)

232 $

230 $

2

$

$

—

—

2 $

2 $

—

—

—

— $

— $

—

4

—

42

(4)

7 $ 241

7 $ 239

—

2

$ in millions

Corporate Consumer

Residential
Real Estate

Commercial
Real Estate

Total

December 31,

2017

Provision
(release)

Other

December 31,

2018

Inherent

Specific

$

194 $

1 $

— $

3 $ 198

7

(3)

198 $

193 $

5

$

$

1

—

2 $

2 $

—

—

—

— $

— $

—

1

(1)

9

(4)

3 $ 203

3 $ 198

—

5

$ in millions

Corporate Consumer

Residential
Real Estate

Commercial
Real Estate

Total

December 31,

2016

Provision
(release)

Other

December 31,

2017

Inherent

Specific

$

185 $

1 $

— $

4 $ 190

8

1

194 $

192 $

2

$

$

—

—

1 $

1 $

—

—

—

— $

— $

—

(1)

—

7

1

3 $ 198

3 $ 196

—

2

$ in millions

Corporate Consumer

Residential
Real Estate

Commercial
Real Estate

Total

Employee Loans

December 31,

2016

Gross charge-

offs

Recoveries

Net recoveries
(charge-offs)

Provision
(release)

Other

December 31,

2017

Inherent

Specific

$

195 $

4 $

20 $

55 $ 274

(75)

1

(74)

5

—

—

—

—

—

—

—

—

—

4

—

—

—

—

13

2

(75)

1

(74)

22

2

$

$

126 $

119 $

7

4 $

4 $

—

24 $

24 $

—

70 $ 224

70 $ 217

—

7

1. During  2018,  the  release  was  primarily  due  to  the  recovery  of  an  energy  industry

related loan charged off in 2017.

$ in millions

Balance

Allowance for loan losses

Balance, net

Remaining repayment term, weighted

average in years

At
December 31, 
 2019

At
December 31, 
 2018

$

$

2,980 $

(61)

2,919 $

4.8

3,415

(63)

3,352

4.3

Employee  loans  are  granted  in  conjunction  with  a  program
established  primarily  to  recruit  certain  Wealth  Management
representatives, are full recourse and generally require periodic
repayments. These loans are recorded in Customer and other
receivables  in  the  balance  sheets.  The  Firm  establishes  an
allowance for loan amounts it does not consider recoverable,
and  the  related  provision  is  recorded  in  Compensation  and
benefits expense.

117

December 2019 Form 10-K

Table of Contents
Notes to Consolidated Financial Statements

9. Goodwill and Intangible Assets 

Goodwill Rollforward

$ in millions

IS

WM

IM

Total

At December 31, 2017¹

$

295 $ 5,533 $

769 $ 6,597

Foreign currency and other

Acquired

(21)

—

—

—

—

112

(21)

112

At December 31, 2018¹

$

274 $ 5,533 $

881 $ 6,688

$ in millions

Investments

Foreign currency and other
Acquired2
At December 31, 20191
Accumulated impairments3

(13)

—

(1)

469

—

—

(14)

469

$ in millions
Income (loss)1

$

$

261 $ 6,001 $

881 $ 7,143

673 $

— $

27 $

700

10.  Other  Assets—Equity  Method  Investments
and Leases 

Equity Method Investments

At
December 31, 
 2019

At
December 31, 
 2018

$

2,363 $

2,432

2019

2018

2017

$

(81) $

20 $

(34)

IS—Institutional Securities
WM—Wealth Management
IM—Investment Management
1. Balances represent the amount of the Firm’s goodwill after accumulated impairments.
2. Amounts  reflect the impact of the Firm's acquisition of Solium Capital Inc. in the second

quarter of 2019.

3. Accumulated impairments were recorded prior to the periods shown. There were no

impairments recorded in 2019, 2018 or 2017.

The  Firm's  annual  goodwill  impairment  testing  as  of  July 1,
2019 and 2018 did not indicate any goodwill impairment, as
reporting  units  with  goodwill  had  a  fair  value  that  was
substantially in excess of carrying value.

1. Includes  impairments  of  the  Investment  Management  business  segment’s  equity
method  investments  as  follows:  in  2019,  $41  million  related  to  a  third-party  asset
manager; in 2018 and 2017, $46 million and $53 million, respectively, related to a
separate third-party asset manager. 

Equity method investments, other than investments in certain
fund interests, are summarized above and are included in Other
assets in the balance sheets with related income or loss included
in  Other  revenues  in  the  income  statements.  See  "Net Asset
Value Measurements—Fund Interests" in Note 3 for the carrying
value of certain of the Firm’s fund interests, which are composed
of general and limited partnership interests, as well as any related
carried interest. 

Net Amortizable Intangible Assets Rollforward1

Japanese Securities Joint Venture

$ in millions

IS

WM

IM

Total

At December 31, 2017

$

349 $ 2,092 $

4 $ 2,445

$ in millions

2019

2018

2017

Income from investment in MUMSS

$

17 $

105 $

123

Acquired

Disposals

Amortization expense

Other

At December 31, 2018
Acquired2

Disposals

Amortization expense

Other

—

(6)

(70)

(3)

—

—

(264)

—

66

—

(10)

—

66

(6)

(344)

(3)

$

270 $ 1,828 $

60 $ 2,158

3

(29)

(35)

18

270

—

(271)

1

—

—

(8)

—

273

(29)

(314)

19

At December 31, 2019

$

227 $ 1,828 $

52 $ 2,107

Gross Amortizable Intangible Assets by Type1

At December 31, 2019

At December 31, 2018

Gross
Carrying
Amount

Accumulated
Amortization

Gross
Carrying
Amount

Accumulated
Amortization

$ in millions

Tradenames

Customer relationships

Management contracts

Other

Total

$

291 $

71 $

286 $

4,321

482

217

2,703

4,067

327

103

507

175

$

5,311 $

3,204 $

5,035 $

Estimated annual amortization expense for the next five years

$

60

2,446

311

60

2,877

307

1. Amounts exclude $5 million of mortgage servicing rights in 2018.
2. Amounts principally reflect the impact of the Firm's acquisition of Solium Capital Inc.

in the second quarter of 2019.

December 2019 Form 10-K

118

The Firm and Mitsubishi UFJ Financial Group, Inc. (“MUFG”)
formed  a  joint  venture  in  Japan  comprising  their  respective
investment banking and securities businesses by forming two
joint  venture  companies,  Mitsubishi  UFJ  Morgan  Stanley
Securities Co., Ltd. (“MUMSS”) and Morgan Stanley MUFG
Securities Co., Ltd. (“MSMS”) (the “Joint Venture”). The Firm
owns a 40% economic interest in the Joint Venture and MUFG
owns the other 60%.

The  Firm’s  40%  voting  interest  in  MUMSS  is  accounted  for
under  the  equity  method  within  the  Institutional  Securities
business  segment,  and  is  included  in  the  equity  method
investment balances above. The Firm consolidates MSMS into
the Institutional Securities business segment, based on its 51%
voting interest.

The  Firm  engages  in  transactions  in  the  ordinary  course  of
business with MUFG and its affiliates; for example, investment
banking,  financial  advisory,  sales  and  trading,  derivatives,
investment  management,  lending,  securitization  and  other
financial  services  transactions.  Such  transactions  are  on
substantially the same terms as those that would be available to
unrelated third parties for comparable transactions.

 
Table of Contents
Notes to Consolidated Financial Statements

Leases

Minimum Future Lease Commitments (under Previous GAAP)

The Firm’s leases are principally non-cancelable operating real
estate leases.

Balance Sheet Amounts Related to Leases

$ in millions

Other assets—ROU assets

Other liabilities and accrued expenses—Lease liabilities

Weighted average:

Remaining lease term, in years

Discount rate

Lease Liabilities

$ in millions

2020

2021

2022

2023

2024

Thereafter

Total undiscounted cash flows

Imputed interest

Amount on balance sheet

Committed leases not yet commenced

Lease Costs

$ in millions

Fixed costs
Variable costs1

Less: Sublease income

Total lease cost, net

At 
December 31, 
 2019

$

3,998

4,778

9.7

3.6%

At 
December 31, 
 2019

$

$

$

$

$

763

703

646

593

524

2,845

6,074

(1,296)

4,778

55

2019

670

152

(6)

816

1. Includes common area maintenance charges and other variable costs not included in

$ in millions

the measurement of ROU assets and lease liabilities.

Cash Flows Statement Supplemental Information

$ in millions

Cash outflows—Lease liabilities

Non-cash—ROU assets recorded for new and modified

leases

2019

$

685

514

2020

2021

2022

2023

2024

Thereafter

Total

$ in millions

2019

2020

2021

2022

2023

Thereafter

Total

Total minimum rental income to be received in the future

under non-cancelable operating subleases

$ in millions

Rent expense

At
December 31,
2018

$

$

$

677

657

602

555

507

2,639

5,637

7

2018

2017

753

704

Occupancy  lease  agreements,  in  addition  to  base  rentals,
generally  provide  for  rent  and  operating  expense  escalations
resulting from increased assessments for real estate taxes and
other charges.

11. Deposits 

Deposits

$ in millions

Savings and demand deposits

Time deposits

Total

Deposits subject to FDIC insurance

Time deposits that equal or exceed the 

FDIC insurance limit

Time Deposit Maturities

At
December 31, 
 2019

At
December 31, 
 2018

$

$

$

$

149,465 $

154,897

40,891

190,356 $

149,966 $

32,923

187,820

144,515

12 $

11

At
December 31, 
 2019

$

20,481

10,567

3,507

3,231

2,465

640

$

40,891

119

December 2019 Form 10-K

  
Table of Contents
Notes to Consolidated Financial Statements

12. Borrowings and Other Secured Financings 

Maturities and Terms of Borrowings

Parent Company

Subsidiaries

$ in millions

Fixed 
Rate

Variable 
Rate1

Fixed 
Rate

Variable 
Rate1

Original maturities of one year or less:

At
December 31, 
 2019

At
December 31, 
 2018

Next 12

months2

$

500

$

— $ — $ 2,067 $

2,567

$

1,545

Original maturities greater than one year:

$

— $

— $ — $

— $

— $

2019

2020

2021

2022

2023

2024

10,909

13,616

6,576

8,632

13,360

4,319

7,823

9,508

3,147

2,028

14

18

16

14

14

5,160

4,628

3,788

2,822

5,704

20,402

26,085

19,888

14,615

21,106

87,964

24,694

21,280

24,642

16,785

13,938

16,405

70,373

options used to economically hedge the embedded features are
derivatives and also are carried at fair value. Changes in fair
value related to the notes and economic hedges are reported in
Trading revenues. See Notes 2 and 4 for further information on
borrowings carried at fair value.

Senior Debt Subject to Put Options or Liquidity Obligations

$ in millions

At
December 31, 
 2019

At
December 31, 
 2018

Put options embedded in debt agreements
Liquidity obligations1

$

$

290 $

1,344 $

520

1,284

1. Includes obligations to support secondary market trading.

Subordinated Debt

Thereafter

52,941

14,436

125

20,462

Total

Total

$106,034

$41,261

$201

$ 42,564 $

190,060

borrowings

$106,534

$41,261

$201

$ 44,631 $

192,627

$

$

188,117

189,662

Contractual weighted average coupon

4.5%

4.5%

2019

2018

Subordinated  debt  generally  is  issued  to  meet  the  capital
requirements  of  the  Firm  or  its  regulated  subsidiaries  and
primarily is U.S. dollar denominated. Maturities of subordinated
notes range from 2022 to 2027. 

Rates for Borrowings with Original Maturities Greater than One
Year

Contractual weighted average coupon1
Effective weighted average coupon after swaps

At December 31,

2019

2018

2017

3.4% 3.5% 3.3%

2.9% 3.6% 2.5%

1. Weighted average coupon was calculated utilizing U.S. and non-U.S. dollar interest
rates and excludes financial instruments for which the fair value option was elected.

In  general,  other  than  securities  inventories  and  customer
balances financed by secured funding sources, the majority of
the Firm’s assets are financed with a combination of deposits,
short-term funding, floating rate long-term debt or fixed rate
long-term debt swapped to a floating rate. The Firm uses interest
rate  swaps  to  more  closely  match  these  borrowings  to  the
duration, holding period and interest rate characteristics of the
assets being funded and to manage interest rate risk. These swaps
effectively convert certain of the Firm’s fixed rate borrowings
into floating rate obligations. In addition, for non-U.S. dollar
currency borrowings that are not used to fund assets in the same
currency,  the  Firm  has  entered  into  currency  swaps  that
effectively convert the borrowings into U.S. dollar obligations.

The  Firm’s  use  of  swaps  for  asset  and  liability  management
affects its effective average borrowing rate.

Weighted
average
coupon at
period end3

3.6%

2.1% 6.6%

N/M

3.4%

3.5%

1. Variable rate borrowings bear interest based on a variety of indices, including LIBOR,
federal funds rates and SOFR. Amounts include notes carried at fair value with various
payment provisions, including notes linked to the performance of a specific index, a
basket of stocks, a specific equity security, a commodity, a credit exposure or basket
of  credit  exposures,  and  instruments  with  various  interest-rate-related  features,
including step-ups, step-downs and zero coupons.

2. The amount shown for the Parent Company represents amounts due to holders of
the Firm's Series G preferred stock for which a notice of redemption was issued. See
Note 16 for further information.

3. Only  includes  borrowings  with  original  maturities  greater  than  one  year.  Weighted
average  coupon  is  calculated  utilizing  U.S.  and  non-U.S.  dollar  interest  rates  and
excludes financial instruments for which the fair value option was elected. Virtually all
of the variable rate notes issued by subsidiaries are carried at fair value so a weighted
average coupon is not meaningful.

Borrowings with Original Maturities Greater than One Year

$ in millions

Senior

Subordinated

Total

At
December 31, 
 2019

At
December 31, 
 2018

$

$

179,519 $

178,027

10,541

10,090

190,060 $

188,117

Weighted average stated maturity, in years

6.9

6.5

Certain senior debt securities are denominated in various non-
U.S. dollar currencies and may be structured to provide a return
that is linked to equity, credit, commodity or other indices (e.g.,
the consumer price index). Senior debt also may be structured
to be callable by the Firm or extendible at the option of holders
of the senior debt securities.

The Firm’s Borrowings also include notes carried and managed
on a fair value basis. These include instruments whose payments
and redemption values are linked to the performance of a specific
index, a basket of stocks, a specific equity security, a commodity,
a credit exposure or basket of credit exposures, and instruments
with various interest-rate-related features, including step-ups,
step-downs and zero coupons. To minimize the exposure from
such  instruments,  the  Firm  has  entered  into  various  swap
contracts  and  purchased  options  that  effectively  convert  the
borrowing costs into floating rates. The swaps and purchased

December 2019 Form 10-K

120

 
 
Table of Contents
Notes to Consolidated Financial Statements

Other Secured Financings

$ in millions

Original maturities:

One year or less

Greater than one year

Transfers of assets accounted for as

secured financings

At
December 31, 
 2019

At
December 31, 
 2018

7,103

6,480

1,115

2,036

6,772

658

9,466

Total

$

14,698 $

Maturities and Terms of Other Secured Financings

$ in millions

At December 31, 2019

Fixed
Rate

Variable
Rate1

Total

At
December 31,
2018

Original maturities of one year or less:

Next 12 months

$

2,785

$

4,318

$ 7,103

$

2,036

Original maturities greater than one year:

2019

2020

2021

2022

2023

2024

Thereafter

Total

Weighted average 

coupon at 
period-end2

$

— $

— $

— $

764

698

227

—

—

356

899

412

—

2,655

12

457

1,663

1,110

227

2,655

12

813

$

2,045

$

4,435

$ 6,480

$

5,900

599

1

86

26

12

148

6,772

0.8%

2.5%

2.4%

2.5%

1. Variable  rate  other  secured  financings  bear  interest  based  on  a  variety  of  indices,
including LIBOR and federal funds rates. Amounts include notes carried at fair value
with various payment provisions, including notes linked to equity, credit, commodity
or other indices.

2. Includes only other secured financings with original maturities greater than one year.
Weighted average coupon is calculated utilizing U.S. and non-U.S. dollar interest rates
and excludes other secured financings that are linked to non-interest indices and for
which the fair value option was elected.

Other secured financings include the liabilities related to certain
ELNs,  transfers  of  financial  assets  that  are  accounted  for  as
financings rather than sales, pledged commodities, consolidated
VIEs where the Firm is deemed to be the primary beneficiary
and  other  secured  borrowings.  These  liabilities  are  generally
payable from the cash flows of the related assets accounted for
as Trading assets. See Note 14 for further information on other
secured financings related to VIEs and securitization activities.

Maturities  of  Transfers  of  Assets  Accounted  for  as  Secured
Financings1 

$ in millions

2019

2020

2021

2022

2023

2024

Thereafter

Total

At
December 31, 
 2019

At
December 31, 
 2018

$

— $

208

225

46

334

—

302

$

1,115 $

40

62

29

33

—

—

494

658

1. Excludes Securities sold under agreements to repurchase and Securities loaned.

For transfers of assets that fail to meet accounting criteria for a
sale, the Firm continues to record the assets and recognizes the
associated liabilities in the balance sheets.

13. Commitments, Guarantees and Contingencies

Commitments

$ in millions

Lending:

Corporate

Consumer

Residential and

Commercial real
estate

Forward-starting

secured financing
receivables

Underwriting

Investment activities

Letters of credit and

other financial
guarantees

Years to Maturity at December 31, 2019

Less
than 1

1-3

3-5

Over 5

Total

$ 23,507 $ 34,542 $ 47,924 $

5,110 $ 111,083

7,835

28

379

378

63,313

637

706

186

223

—

275

2

4

88

—

—

60

—

—

7,867

273

1,118

11,601

75,137

—

262

637

1,303

2

190

Total

$ 96,563 $ 35,448 $ 48,076 $ 17,248 $ 197,335

Corporate lending commitments participated to third parties

$

8,003

Forward-starting secured financing receivables settled within three

business days of the balance sheet date

$ 52,438

Since  commitments  associated  with  these  instruments  may
expire unused, the amounts shown do not necessarily reflect the
actual future cash funding requirements.

Types of Commitments

Lending  Commitments.  Lending  commitments  primarily
represent the notional amount of legally binding obligations to
provide funding to clients for different types of loan transactions.
This category also includes commitments in loan form provided
to clearinghouses or associated depositories of which the Firm
is  a  member  and  are  contingent  upon  the  default  of  a
clearinghouse member or other stress event. For syndications
that are led by the Firm, the lending commitments accepted by
the borrower but not yet closed are net of the amounts agreed

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to by counterparties that will participate in the syndication. For
syndications  that  the  Firm  participates  in  and  does  not  lead,
lending  commitments  accepted  by  the  borrower  but  not  yet
closed include only the amount that the Firm expects it will be
allocated from the lead syndicate bank. Due to the nature of the
Firm’s  obligations  under  the  commitments,  these  amounts
include certain commitments participated to third parties.

Forward-Starting  Secured  Financing  Receivables.  This
amount includes securities purchased under agreements to resell
and securities borrowed that the Firm has entered into prior to
the balance sheet date that will settle after the balance sheet date.
Also  included  are  commitments  to  enter  into  securities
purchased under agreements to resell that are provided to certain
clearinghouses or associated depositories of which the Firm is
a member and are contingent upon the default of a clearinghouse
member or other stress event. These transactions are primarily
secured by collateral from U.S. government agency securities
and  other  sovereign  government  obligations  when  they  are
funded.

Guarantees

Obligations  under  Guarantee Arrangements  at  December  31,
2019

Maximum Potential Payout/Notional

Years to Maturity

$ in millions

Less
than 1

1-3

3-5

Over 5

Total

Credit derivatives

$

36,334 $ 37,080 $ 111,758 $ 30,547 $ 215,719

Other credit contracts

—

—

—

117

117

Non-credit derivatives

1,590,947 1,240,195

393,248

699,043

3,923,433

Standby letters of credit
and other financial
guarantees issued1

Market value guarantees

Liquidity facilities

Whole loan sales

guarantees

Securitization

representations and
warranties

General partner
guarantees

1,282

76

4,599

—

—

59

Client clearing guarantees

18,565

836

1,386

4,201

82

—

—

—

128

—

—

—

—

—

12

—

7,705

158

4,599

—

—

23,196

23,196

67,928

67,928

71

—

270

18,565

Underwriting Commitments.  The Firm provides underwriting
commitments in connection with its capital raising sources to a
diverse group of corporate and other institutional clients.

$ in millions
Credit derivatives2

Investment  Activities.  The  Firm  sponsors  several  non-
consolidated  investment  management  funds  for  third-party
investors  where  it  typically  acts  as  general  partner  of,  and
investment  advisor  to,  these  funds  and  typically  commits  to
invest a minority of the capital of such funds, with subscribing
third-party  investors  contributing  the  majority.  The  Firm  has
contractual capital commitments, guarantees and counterparty
arrangements  with  respect  to  these  investment  management
funds.

Other credit contracts
Non-credit derivatives2
Standby letters of credit and other financial guarantees issued1

Market value guarantees

Liquidity facilities

Whole loan sales guarantees
Securitization representations and warranties3

General partner guarantees

Client clearing guarantees

Carrying
Amount
Asset
(Liability)

$

1,703

(17)

(45,794)

226

—

6

—

(42)

(42)

—

third-party  banks 

Letters of Credit and Other Financial Guarantees.  The Firm
has outstanding letters of credit and other financial guarantees
issued  by 
the  Firm’s
counterparties. The Firm is contingently liable for these letters
of  credit  and  other  financial  guarantees,  which  are  primarily
used to provide collateral for securities and commodities traded
and to satisfy various margin requirements in lieu of depositing
cash or securities with these counterparties.

to  certain  of 

1. These amounts include certain issued standby letters of credit participated to third
parties, totaling $0.7 billion of notional and collateral/recourse, due to the nature of
the Firm’s obligations under these arrangements.

2. The carrying amounts of derivative contracts that meet the accounting definition of a

guarantee are shown on a gross basis. 

3. Primarily related to residential mortgage securitizations.

Types of Guarantees

Derivative  Contracts.  Certain  derivative  contracts  meet  the
accounting definition of a guarantee, including certain written
options,  contingent  forward  contracts  and  CDS  (see  Note  5
regarding credit derivatives in which the Firm has sold credit
protection  to  the  counterparty).  All  derivative  contracts  that
could meet this accounting definition of a guarantee are included
in  the  previous  table,  with  the  notional  amount  used  as  the
maximum potential payout for certain derivative contracts, such
as written interest rate caps and written foreign currency options.
The Firm evaluates collateral requirements for all derivatives,
including derivatives that do not meet the accounting definition
of a guarantee. For the effects of cash collateral and counterparty
netting, see Note 5.

In certain situations, collateral may be held by the Firm for those
contracts that meet the definition of a guarantee. Generally, the

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Firm  sets  collateral  requirements  by  counterparty  so  that  the
collateral covers various transactions and products and is not
allocated specifically to individual contracts. Also, the Firm may
recover amounts related to the underlying asset delivered to the
Firm under the derivative contract.

Standby  Letters  of  Credit  and  Other  Financial  Guarantees
Issued. In connection with its corporate lending business and
other corporate activities, the Firm provides standby letters of
credit  and  other  financial  guarantees  to  counterparties.  Such
arrangements represent obligations to make payments to third
parties if the counterparty fails to fulfill its obligation under a
borrowing  arrangement  or  other  contractual  obligation.  A
majority of the Firm’s standby letters of credit are provided on
behalf  of  counterparties  that  are  investment  grade.  If  the
counterparty fails to fulfill its contractual obligation, the Firm
has access to collateral or recourse that would approximate its
obligation.

Market Value Guarantees. Market value guarantees are issued
to guarantee timely payment of a specified return to investors
in certain affordable housing tax credit funds. These guarantees
are designed to return an investor’s contribution to a fund and
the investor’s share of tax losses and tax credits expected to be
generated by a fund.

Liquidity Facilities. The Firm has entered into liquidity facilities
with  SPEs  and  other  counterparties,  whereby  the  Firm  is
required to make certain payments if losses or defaults occur.
Primarily, the Firm acts as liquidity provider to municipal bond
securitization  SPEs  and  for  standalone  municipal  bonds  in
which the holders of beneficial interests issued by these SPEs
or the holders of the individual bonds, respectively, have the
right  to  tender  their  interests  for  purchase  by  the  Firm  on
specified dates at a specified price. The Firm often may have
recourse to the underlying assets held by the SPEs in the event
payments are required under such liquidity facilities, as well as
make-whole or recourse provisions with the trust sponsors. The
recourse amount often exceeds the maximum potential payout
amount  of  the  guarantee.  Substantially  all  of  the  underlying
assets  in  the  SPEs  are  investment  grade.  Liquidity  facilities
provided to municipal tender option bond trusts are classified
as derivatives.

Whole  Loan  Sales  Guarantees.  The  Firm  has  provided,  or
otherwise  agreed  to  be  responsible  for,  representations  and
warranties  regarding  certain  whole  loan  sales.  Under  certain
circumstances,  the  Firm  may  be  required  to  repurchase  such
assets  or  make  other  payments  related  to  such  assets  if  such
representations  and  warranties  are  breached.  The  Firm’s
maximum potential payout related to such representations and
warranties is equal to the current UPB of such loans. Since the
Firm no longer services these loans, it has no information on the
current  UPB  of  those  loans,  and  accordingly,  the  amount
included in the previous table represents the UPB at the time of
the whole loan sale or at the time when the Firm last serviced
any  of  those  loans.  The  current  UPB  balances  could  be

substantially lower than the maximum potential payout amount
included  in  the  previous  table. The  related  liability  primarily
relates to sales of loans to the federal mortgage agencies.

business 

Institutional 

Securitization Representations and Warranties. As part of the
segment’s
Securities 
Firm’s 
securitizations and related activities, the Firm has provided, or
otherwise  agreed  to  be  responsible  for,  representations  and
warranties regarding certain assets transferred in securitization
transactions sponsored by the Firm. The extent and nature of the
representations  and  warranties,  if  any,  vary  among  different
securitizations. Under certain circumstances, the Firm may be
required to repurchase certain assets or make other payments
related to such assets if such representations and warranties are
breached. The maximum potential amount of future payments
the Firm could be required to make would be equal to the current
outstanding  balances  of,  or  losses  associated  with,  the  assets
subject to breaches of such representations and warranties. The
amount included in the previous table for the maximum potential
payout  includes  the  current  UPB  or  historical  losses  where
known, and the UPB at the time of sale when the current UPB
is not known.

General  Partner  Guarantees. As  a  general  partner  in  certain
investment  management  funds,  the  Firm  receives  certain
distributions  from  the  partnerships  when  the  return  exceeds
specified performance targets according to the provisions of the
partnership agreements. The Firm may be required to return all
or a portion of such distributions to the limited partners in the
event  the  limited  partners  do  not  achieve  a  certain  return  as
specified  in  the  various  partnership  agreements,  subject  to
certain limitations.

Client  Clearing  Guarantees.  In  2019,  the  Firm  became  a
sponsoring member of the Government Securities Division of
the FICC's Sponsored Clearing Model. Clients of the Firm, as
sponsored  members,  can  transact  in  overnight  securities
repurchase and resale agreements, which are cleared through
FICC. As sponsoring member, the Firm guarantees to FICC the
prompt  and  full  payment  and  performance  of  its  clients’
obligations.  The  amount  included  in  the  previous  table
represents  the  maximum  potential  payout  the  Firm  could  be
responsible  for  through  the  guarantee  it  provides.  The  Firm
minimizes credit exposure under this guarantee by obtaining a
security interest in its sponsored member clients’ collateral and
their contractual rights under sponsored member transactions.
Therefore,  the  Firm's  exposure  is  estimated  to  be  an  amount
substantially lower than the maximum potential payout amount.
The collateral amount in which the Firm has a security interest
is approximately equal to the maximum potential payout amount
of the guarantee.

Other Guarantees and Indemnities

In the normal course of business, the Firm provides guarantees
and  indemnifications  in  a  variety  of  transactions.  These

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provisions generally are standard contractual terms. Certain of
these guarantees and indemnifications are described below:

arrangements is remote given the level of its due diligence in
its role as investment banking advisor.

• Indemnities.  The  Firm  provides  standard  indemnities  to
counterparties  for  certain  contingent  exposures  and  taxes,
including U.S. and foreign withholding taxes, on interest and
other  payments  made  on  derivatives,  securities  and  stock
lending  transactions,  certain  annuity  products  and  other
financial arrangements. These indemnity payments could be
required  based  on  a  change  in  the  tax  laws,  a  change  in
interpretation of applicable tax rulings or a change in factual
circumstances.  Certain  contracts  contain  provisions  that
enable  the  Firm  to  terminate  the  agreement  upon  the
occurrence of such events. The maximum potential amount
of future payments that the Firm could be required to make
under these indemnifications cannot be estimated.

• Exchange/Clearinghouse Member Guarantees. The Firm is
a member of various exchanges and clearinghouses that trade
and  clear  securities  and/or  derivative  contracts. Associated
with its membership, the Firm may be required to pay a certain
amount as determined by the exchange or the clearinghouse
in case of a default of any of its members or pay a proportionate
share of the financial obligations of another member that may
default on its obligations to the exchange or the clearinghouse.
While 
rules  governing  different  exchange  or
clearinghouse memberships and the forms of these guarantees
may vary, in general the Firm’s obligations under these rules
would  arise  only  if  the  exchange  or  clearinghouse  had
previously exhausted its resources.

the 

In  addition,  some  clearinghouse  rules  require  members  to
assume  a  proportionate  share  of  losses  resulting  from  the
clearinghouse’s investment of guarantee fund contributions
and initial margin, and of other losses unrelated to the default
of  a  clearing  member,  if  such  losses  exceed  the  specified
resources allocated for such purpose by the clearinghouse.

The maximum potential payout under these rules cannot be
estimated. The Firm has not recorded any contingent liability
in its financial statements for these agreements and believes
that any potential requirement to make payments under these
agreements is remote.

• Merger and Acquisition Guarantees. The Firm may, from time
to time, in its role as investment banking advisor be required
to  provide  guarantees  in  connection  with  certain  European
merger  and  acquisition  transactions.  If  required  by  the
regulating authorities, the Firm provides a guarantee that the
acquirer in the merger and acquisition transaction has or will
have sufficient funds to complete the transaction and would
then be required to make the acquisition payments in the event
the acquirer’s funds are insufficient at the completion date of
the transaction. These arrangements generally cover the time
frame from the transaction offer date to its closing date and,
therefore, are generally short term in nature. The Firm believes
the  likelihood  of  any  payment  by  the  Firm  under  these

In  addition,  in  the  ordinary  course  of  business,  the  Firm
guarantees the debt and/or certain trading obligations (including
obligations  associated  with  derivatives,  foreign  exchange
contracts and the settlement of physical commodities) of certain
subsidiaries. These guarantees generally are entity or product
specific and are required by investors or trading counterparties.
The  activities  of  the  Firm’s  subsidiaries  covered  by  these
guarantees (including any related debt or trading obligations)
are included in the financial statements.

Contingencies

Legal

In addition to the matters described below, in the normal course
of business, the Firm has been named, from time to time, as a
defendant in various legal actions, including arbitrations, class
actions  and  other  litigation,  arising  in  connection  with  its
activities as a global diversified financial services institution.
Certain of the actual or threatened legal actions include claims
for substantial compensatory and/or punitive damages or claims
for  indeterminate  amounts  of  damages.  In  some  cases,  the
entities that would otherwise be the primary defendants in such
cases are bankrupt or are in financial distress. These actions have
included, but are not limited to, residential mortgage and credit
crisis-related matters.

While the Firm has identified below any individual proceedings
where the Firm believes a material loss to be reasonably possible
and reasonably estimable, there can be no assurance that material
losses will not be incurred from claims that have not yet been
asserted or are not yet determined to be probable or possible and
reasonably estimable losses.

The  Firm  contests  liability  and/or  the  amount  of  damages  as
appropriate 
in  each  pending  matter.  Where  available
information  indicates  that  it  is  probable  a  liability  had  been
incurred at the date of the financial statements and the Firm can
reasonably estimate the amount of that loss, the Firm accrues
the estimated loss by a charge to income.

$ in millions

Legal expenses

2019

2018

2017

$

221 $

206 $

342

The Firm’s future legal expenses may fluctuate from period to
period,  given  the  current  environment  regarding  government
investigations and private litigation affecting global financial
services firms, including the Firm.

In  many  proceedings  and  investigations,  however,  it  is
inherently difficult to determine whether any loss is probable or
even possible or to estimate the amount of any loss. In addition,
even where a loss is possible or an exposure to loss exists in
excess  of  the  liability  already  accrued  with  respect  to  a

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previously recognized loss contingency, it is not always possible
to reasonably estimate the size of the possible loss or range of
loss.

For certain legal proceedings and investigations, the Firm cannot
reasonably  estimate  such  losses,  particularly  for  proceedings
and investigations where the factual record is being developed
or  contested  or  where  plaintiffs  or  government  entities  seek
substantial or indeterminate damages, restitution, disgorgement
or  penalties.  Numerous  issues  may  need  to  be  resolved,
lengthy  discovery  and
including 
determination  of  important  factual  matters,  determination  of
issues  related  to  class  certification  and  the  calculation  of
damages or other relief, and by addressing novel or unsettled
legal questions relevant to the proceedings or investigations in
question,  before  a  loss  or  additional  loss  or  range  of  loss  or
additional  range  of  loss  can  be  reasonably  estimated  for  a
proceeding or investigation.

through  potentially 

For certain other legal proceedings and investigations, the Firm
can  estimate  reasonably  possible  losses,  additional  losses,
ranges of loss or ranges of additional loss in excess of amounts
accrued but does not believe, based on current knowledge and
after  consultation  with  counsel,  that  such  losses  will  have  a
material adverse effect on the Firm’s financial statements as a
whole,  other  than  the  matters  referred  to  in  the  following
paragraphs.

On  July 15,  2010,  China  Development  Industrial  Bank
(“CDIB”)  filed  a  complaint  against  the  Firm,  styled  China
Development  Industrial  Bank  v.  Morgan  Stanley  &  Co.
Incorporated et al., which is pending in the Supreme Court of
the State of New York, New York County ("Supreme Court of
NY”). The complaint relates to a $275 million CDS referencing
the  super  senior  portion  of  the  STACK  2006-1  CDO.  The
complaint  asserts  claims  for  common  law  fraud,  fraudulent
inducement  and  fraudulent  concealment  and  alleges  that  the
Firm misrepresented the risks of the STACK 2006-1 CDO to
CDIB, and that the Firm knew that the assets backing the CDO
were of poor quality when it entered into the CDS with CDIB.
The  complaint  seeks  compensatory  damages  related  to  the
approximately $228 million that CDIB alleges it has already lost
under  the  CDS,  rescission  of  CDIB’s  obligation  to  pay  an
additional $12 million, punitive damages, equitable relief, fees
and costs. On February 28, 2011, the court denied the Firm’s
motion to dismiss the complaint. On December 21, 2018, the
court  denied  the  Firm’s  motion  for  summary  judgment  and
granted  in  part  the  Firm’s  motion  for  sanctions  relating  to
spoliation of evidence. On January 24, 2019, CDIB filed a notice
of  appeal  from  the  court’s  December  21,  2018  order,  and  on
January 25, 2019, the Firm filed a notice of appeal from the same
order. On March 7, 2019, the court denied the relief that CDIB
sought in a motion to clarify and resettle the portion of the court’s
December  21,  2018  order  granting  spoliation  sanctions.  On
December  5,  2019,  the Appellate  Division,  First  Department
(“First Department”) heard the parties’ cross appeals. Based on
currently available information, the Firm believes it could incur

a loss in this action of up to approximately $240 million plus
pre- and post-judgment interest, fees and costs. 

On July 8, 2013, U.S. Bank National Association, in its capacity
as trustee, filed a complaint against the Firm styled U.S. Bank
National Association,  solely  in  its  capacity  as  Trustee  of  the
Morgan  Stanley  Mortgage  Loan  Trust  2007-2AX  (MSM
2007-2AX) v. Morgan Stanley Mortgage Capital Holdings LLC,
Successor-by-Merger to Morgan Stanley Mortgage Capital Inc.
and  GreenPoint  Mortgage  Funding,  Inc.,  pending  in  the
Supreme Court of NY. The complaint asserts claims for breach
of contract and alleges, among other things, that the loans in the
trust, which had an original principal balance of approximately
$650 million, breached various representations and warranties.
The complaint seeks, among other relief, specific performance
of  the  loan  breach  remedy  procedures  in  the  transaction
documents, unspecified damages and interest. On November 24,
2014, the court granted in part and denied in part the Firm’s
motion to dismiss the complaint. On April 4, 2019, the court
denied the Firm’s motion to renew its motion to dismiss. Based
on  currently  available  information,  the  Firm  believes  that  it
could incur a loss in this action of up to approximately $240
million, the total original unpaid balance of the mortgage loans
for which the Firm received repurchase demands that it did not
repurchase, plus pre- and post-judgment interest, fees and costs,
but plaintiff is seeking to expand the number of loans at issue
and the possible range of loss could increase.

On  September  23,  2014,  Financial  Guaranty  Insurance
Company (“FGIC”) filed a complaint against the Firm in the
Supreme  Court  of  NY  styled  Financial  Guaranty  Insurance
Company v. Morgan Stanley ABS Capital I Inc. et al. relating to
the Morgan Stanley ABS Capital I Inc. Trust 2007-NC4. The
complaint asserts claims for breach of contract and fraudulent
inducement and alleges, among other things, that the loans in
the trust breached various representations and warranties and
defendants made untrue statements and material omissions to
induce  FGIC  to  issue  a  financial  guaranty  policy  on  certain
classes  of  certificates  that  had  an  original  balance  of
approximately $876 million. The complaint seeks, among other
relief,  specific  performance  of  the  loan  breach  remedy
procedures  in  the  transaction  documents,  compensatory,
consequential  and  punitive  damages,  attorneys’  fees  and
interest. On January 23, 2017, the court denied the Firm’s motion
to  dismiss  the  complaint.  On  September  13,  2018,  the  First
Department  affirmed  in  part  and  reversed  in  part  the  lower
court’s  order  denying  the  Firm’s  motion  to  dismiss.  On
December  20,  2018,  the  First  Department  denied  plaintiff’s
motion for leave to appeal its decision to the New York Court
of Appeals ("Court of Appeals") or, in the alternative, for re-
argument. Based on currently available information, the Firm
believes  that  it  could  incur  a  loss  in  this  action  of  up  to
approximately $277 million, the total original unpaid balance
of the mortgage loans for which the Firm received repurchase
demands from a certificate holder and FGIC that the Firm did
not repurchase, plus pre- and post- judgment interest, fees and

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costs, as well as claim payments that FGIC has made and will
make in the future. In addition, plaintiff is seeking to expand the
number of loans at issue and the possible range of loss could
increase.

On January 23, 2015, Deutsche Bank National Trust Company,
in its capacity as trustee, filed a complaint against the Firm styled
Deutsche Bank National Trust Company solely in its capacity
as Trustee of the Morgan Stanley ABS Capital I Inc. Trust 2007-
NC4  v.  Morgan  Stanley  Mortgage  Capital  Holdings  LLC  as
Successor-by-Merger to Morgan Stanley Mortgage Capital Inc.,
and Morgan Stanley ABS Capital I Inc., pending in the Supreme
Court of NY. The complaint asserts claims for breach of contract
and alleges, among other things, that the loans in the trust, which
had an original principal balance of approximately $1.05 billion,
breached various representations and warranties. The complaint
seeks,  among  other  relief,  specific  performance  of  the  loan
breach  remedy  procedures  in  the  transaction  documents,
compensatory, consequential, rescissory, equitable and punitive
damages, attorneys’ fees, costs and other related expenses, and
interest. On December 11, 2015, the court granted in part and
denied in part the Firm’s motion to dismiss the complaint. On
October 19, 2018, the court granted the Firm’s motion for leave
to amend its answer and to stay the case pending resolution of
Deutsche Bank National Trust Company’s appeal to the Court
of Appeals in another case, styled Deutsche Bank National Trust
Company v. Barclays Bank PLC, regarding the applicable statute
of  limitations.  On  January  17,  2019,  the  First  Department
reversed the trial court’s order to the extent that it had granted
in part the Firm’s motion to dismiss the complaint. On June 4,
2019, the First Department granted the Firm’s motion for leave
to appeal to the Court of Appeals. Based on currently available
information, the Firm believes that it could incur a loss in this
action of up to approximately $277 million, the total original
unpaid  balance  of  the  mortgage  loans  for  which  the  Firm
received  repurchase  demands  from  a  certificate  holder  and  a
monoline insurer that the Firm did not repurchase, plus pre- and
post-judgment interest, fees and costs, but plaintiff is seeking to
expand the number of loans at issue and the possible range of
loss could increase.

Tax

In  matters  styled  Case  number  15/3637  and  Case  number
15/4353,  the  Dutch  Tax  Authority  (“Dutch  Authority”)  has
challenged, in the District Court in Amsterdam, the prior set-off
by the Firm of approximately €124 million (approximately $139
million) plus accrued interest of withholding tax credits against
the Firm’s corporation tax liabilities for the tax years 2007 to
2013. The Dutch Authority alleges that the Firm was not entitled
to receive the withholding tax credits on the basis, inter alia, that
a Firm subsidiary did not hold legal title to certain securities
subject  to  withholding  tax  on  the  relevant  dates.  The  Dutch
Authority has also alleged that the Firm failed to provide certain
information to the Dutch Authority and keep adequate books
and records. On April 26, 2018, the District Court in Amsterdam

December 2019 Form 10-K

126

issued a decision dismissing the Dutch Authority’s claims. On
June 4, 2018, the Dutch Authority filed an appeal before the
Court of Appeal in Amsterdam in matters re-styled Case number
18/00318 and Case number 18/00319. On June 26 and July 2,
2019, a hearing of the Dutch Authority’s appeal was held. Based
on  currently  available  information,  the  Firm  believes  that  it
could incur a loss in this action of up to approximately €124
million (approximately $139 million) plus accrued interest.

14.  Variable  Interest  Entities  and  Securitization
Activities 

Overview

The Firm is involved with various SPEs in the normal course of
business. In most cases, these entities are deemed to be VIEs.

The Firm’s variable interests in VIEs include debt and equity
interests, commitments, guarantees, derivative instruments and
certain fees. The Firm’s involvement with VIEs arises primarily
from:

• Interests  purchased  in  connection  with  market-making
activities, securities held in its Investment securities portfolio
and  retained  interests  held  as  a  result  of  securitization
activities, including re-securitization transactions.

• Guarantees 

issued  and  residual 
connection with municipal bond securitizations.

interests  retained 

in

• Loans made to and investments in VIEs that hold debt, equity,

real estate or other assets.

• Derivatives entered into with VIEs.

• Structuring of CLNs or other asset-repackaged notes designed

to meet the investment objectives of clients.

• Other structured transactions designed to provide tax-efficient

yields to the Firm or its clients.

The Firm determines whether it is the primary beneficiary of a
VIE upon its initial involvement with the VIE and reassesses
whether it is the primary beneficiary on an ongoing basis as long
as  it  has  any  continuing  involvement  with  the  VIE.  This
determination is based upon an analysis of the design of the VIE,
including the VIE’s structure and activities, the power to make
significant economic decisions held by the Firm and by other
parties, and the variable interests owned by the Firm and other
parties.

The power to make the most significant economic decisions may
take a number of different forms in different types of VIEs. The
Firm considers servicing or collateral management decisions as
representing the power to make the most significant economic
decisions in transactions such as securitizations or CDOs. As a
result, the Firm does not consolidate securitizations or CDOs
for which it does not act as the servicer or collateral manager

Table of Contents
Notes to Consolidated Financial Statements

unless  it  holds  certain  other  rights  to  replace  the  servicer  or
collateral manager or to require the liquidation of the entity. If
the Firm serves as servicer or collateral manager, or has certain
other  rights  described  in  the  previous  sentence,  the  Firm
analyzes the interests in the VIE that it holds and consolidates
only  those  VIEs  for  which  it  holds  a  potentially  significant
interest in the VIE.

For  many  transactions,  such  as  re-securitization  transactions,
CLNs and other asset-repackaged notes, there are no significant
economic decisions made on an ongoing basis. In these cases,
the Firm focuses its analysis on decisions made prior to the initial
closing  of  the  transaction  and  at  the  termination  of  the
transaction. The Firm concluded in most of these transactions
that  decisions  made  prior  to  the  initial  closing  were  shared
between the Firm and the initial investors based upon the nature
of  the  assets,  including  whether  the  assets  were  issued  in  a
transaction  sponsored  by  the  Firm  and  the  extent  of  the
information available to the Firm and to investors, the number,
nature and involvement of investors, other rights held by the
Firm  and 
legal
documentation and the level of continuing involvement by the
Firm, including the amount and type of interests owned by the
Firm  and  by  other  investors.  The  Firm  focused  its  control
decision on any right held by the Firm or investors related to the
termination  of  the  VIE.  Most  re-securitization  transactions,
CLNs  and  other  asset-repackaged  notes  have  no  such
termination rights.

the  standardization  of 

investors, 

the 

Consolidated VIE Assets and Liabilities by Type of Activity

$ in millions

VIE Assets VIE Liabilities VIE Assets VIE Liabilities

At December 31, 2019

At December 31, 2018

OSF
MABS1
Other2

Total

$

696 $

391 $

267 $

265

987

4

66

59

809

$

1,948 $

461 $

1,135 $

—

38

48

86

OSF—Other structured financings
1. Amounts  include  transactions  backed  by  residential  mortgage  loans,  commercial
mortgage loans and other types of assets, including consumer or commercial assets.
and may be in loan or security form. The value of assets is determined based on the
fair value of the liabilities and the interests owned by the Firm in such VIEs as the fair
values for the liabilities and interests owned are more observable.

2. Other  primarily  includes  operating  entities,  investment  funds  and  structured

transactions.

Consolidated  VIE  Assets  and  Liabilities  by  Balance  Sheet
Caption

$ in millions

Assets

Cash and cash equivalents:

At
December 31, 
 2019

At
December 31, 
 2018

Cash and due from banks

$

315 $

Restricted cash

Trading assets at fair value

Customer and other receivables

Goodwill

Intangible assets

Other assets

Total

Liabilities

Other secured financings

Other liabilities and accrued expenses

Total

Noncontrolling interests

173

943

18

—

111

388

77

171

314

25

18

128

402

$

$

$

$

1,948 $

1,135

422 $

39

461 $

192 $

64

22

86

106

Consolidated  VIE  assets  and  liabilities  are  presented  in  the
previous  tables  after  intercompany  eliminations.  Generally,
most  assets  owned  by  consolidated VIEs  cannot  be  removed
unilaterally by the Firm and are not available to the Firm while
the  related  liabilities  issued  by  consolidated  VIEs  are  non-
recourse to the Firm. However, in certain consolidated VIEs,
the  Firm  either  has  the  unilateral  right  to  remove  assets  or
provides additional recourse through derivatives such as total
return swaps, guarantees or other forms of involvement.

In general, the Firm’s exposure to loss in consolidated VIEs is
limited to losses that would be absorbed on the VIE net assets
recognized in its financial statements, net of amounts absorbed
by third-party variable interest holders.

Non-consolidated VIEs

At December 31, 2019

$ in millions

MABS1

CDO

MTOB

OSF

Other2

VIE assets (UPB)
Maximum exposure to loss3

$ 125,603 $ 2,976 $

6,965 $ 2,288 $ 51,305

Debt and equity

interests

Derivative and other

contracts

Commitments,

guarantees and
other

$ 16,314 $

240 $

— $ 1,009 $ 11,977

—

—

4,599

—

2,995

631

—

—

—

266

Total

$ 16,945 $

240 $

4,599 $ 1,009 $ 15,238

Carrying value of variable interests—Assets

Debt and equity

interests

Derivative and other

contracts

$ 16,314 $

240 $

— $ 1,008 $ 11,977

—

—

6

—

388

Total
Additional VIE assets owned4

$ 16,314 $

240 $

6 $ 1,008 $ 12,365

$ 11,453

Carrying value of variable interests—Liabilities

Derivative and other

contracts

$

— $

— $

— $

— $

444

127

December 2019 Form 10-K

Table of Contents
Notes to Consolidated Financial Statements

At December 31, 20185

Detail of Mortgage- and Asset-Backed Securitization Assets

$ in millions

MABS1

CDO

MTOB

OSF

Other2

VIE assets (UPB)
Maximum exposure to loss3

$ 106,197 $ 10,848 $

7,014 $ 3,314 $ 38,603

$ 15,671 $ 1,169 $

— $ 1,622 $ 7,967

guarantees and other

1,073

—

235

509

Total

$ 16,744 $ 1,172 $

4,449 $ 1,857 $ 10,244

Carrying value of variable interests—Assets

—

3

Debt and equity

interests

Derivative and other

contracts

Commitments,

At December 31, 2019

At December 31, 20181

$ in millions

UPB

Debt and
Equity
Interests

Debt and
Equity
Interests

UPB

Residential mortgages

$ 30,353 $

3,993 $ 27,594 $

4,581

4,327

U.S. agency

collateralized 
mortgage obligations

Other consumer or
commercial loans

36,366

6,365

14,969

3,443

4,992

2,075

8,133

3,320

—

4,449

—

1,768

Commercial mortgages

53,892

3,881

55,501

Debt and equity

interests

Derivative and other

contracts

$ 15,671 $ 1,169 $

— $ 1,205 $ 7,967

Total

$ 125,603 $

16,314 $ 106,197 $

15,671

—

—

6

—

87

1. The balances as of December 31, 2018 were revised as noted in the Non-consolidated

VIEs table herein.

Total
Additional VIE assets owned4

$ 15,671 $ 1,169 $

Carrying value of variable interests—Liabilities

6 $ 1,205 $ 8,054

$ 12,059

Securitization Activities

Derivative and other

contracts

$

— $

— $

— $

— $

185

MTOB—Municipal tender option bonds
1. Amounts  include  transactions  backed  by  residential  mortgage  loans,  commercial
mortgage loans and other types of assets, including consumer or commercial assets.
and may be in loan or security form. 

2. Other primarily includes exposures to commercial real estate property and investment

funds.

3. Where notional amounts are utilized in quantifying the maximum exposure related to
derivatives, such amounts do not reflect changes in fair value recorded by the Firm.
4. Additional VIE assets owned represents the carrying value of total exposure to non-
consolidated  VIEs  for  which  the  maximum  exposure  to  loss  is  less  than  specific
thresholds, primarily interests issued by securitization SPEs. The Firm’s primary risk
exposure is to the most subordinate class of beneficial interest and maximum exposure
to loss generally equals the fair value of the assets owned. These assets are primarily
included in Trading assets and Investment securities and are measured at fair value
(see  Note  3).  The  Firm  does  not  provide  additional  support  in  these  transactions
through contractual facilities, guarantees or similar derivatives.

5. The  carrying  value  and  maximum  exposure  to  loss  of  variable  interests  related  to
MABS and Other have been revised to reflect the addition of approximately $11 billion
in loans to VIEs that were previously excluded. The VIE asset (UPB) amounts have
also been revised by approximately $54 billion. This disclosure-only revision did not
impact the Firm's balance sheets.

The  majority  of  the VIEs  included  in  the  previous  tables  are
sponsored  by  unrelated  parties;  examples  of  the  Firm’s
involvement  with  these  VIEs  include  its  secondary  market-
making  activities  and  the  securities  held  in  its  Investment
securities portfolio (see Note 6).

The Firm’s maximum exposure to loss is dependent on the nature
of the Firm’s variable interest in the VIE and is limited to the
notional amounts of certain liquidity facilities and other credit
support, total return swaps and written put options, as well as
the fair value of certain other derivatives and investments the
Firm has made in the VIE.

The Firm’s maximum exposure to loss in the previous tables
does  not  include  the  offsetting  benefit  of  hedges  or  any
reductions associated with the amount of collateral held as part
of a transaction with the VIE or any party to the VIE directly
against a specific exposure to loss.

Liabilities  issued  by  VIEs  generally  are  non-recourse  to  the
Firm.

In  a  securitization  transaction,  the  Firm  transfers  assets
(generally  commercial  or  residential  mortgage  loans  or
securities) to an SPE, sells to investors most of the beneficial
interests, such as notes or certificates, issued by the SPE, and,
in many cases, retains other beneficial interests. The purchase
of the transferred assets by the SPE is financed through the sale
of these interests.

In  many  securitization  transactions  involving  commercial
mortgage loans, the Firm transfers a portion of the assets to the
SPE with unrelated parties transferring the remaining assets. In
addition,  mainly  in  securitization  transactions  involving
residential  mortgage  loans,  the  Firm  may  also  enter  into
derivative transactions, primarily interest rate swaps or interest
rate caps, with the SPE.

Although not obligated, the Firm generally makes a market in
the securities issued by SPEs in securitization transactions. As
a market maker, the Firm offers to buy these securities from,
and  sell  these  securities  to,  investors.  Securities  purchased
through these market-making activities are not considered to be
retained  interests;  these  beneficial  interests  generally  are
included in Trading assets—Corporate and other debt and are
measured at fair value.

The Firm enters into derivatives, generally interest rate swaps
and interest rate caps, with a senior payment priority in many
securitization transactions. The risks associated with these and
similar derivatives with SPEs are essentially the same as similar
derivatives  with  non-SPE  counterparties  and  are  managed  as
part  of  the  Firm’s  overall  exposure.  See  Note  5  for  further
information on derivative instruments and hedging activities.

Investment Securities

The Firm holds securities issued by VIEs within the Investment
securities  portfolio.  These  securities  are  composed  of  those
related  to  transactions  sponsored  by  the  federal  mortgage
agencies and predominantly the most senior securities issued by
VIEs backed by student loans and commercial mortgage loans.

December 2019 Form 10-K

128

Table of Contents
Notes to Consolidated Financial Statements

Transactions  sponsored  by  the  federal  mortgage  agencies
include an explicit or implicit guarantee provided by the U.S.
government. Additionally, the Firm holds certain commercial
mortgage-backed securities issued by VIEs retained as a result
of  the  Firm's  securitization  activities.  See  Note  6  for  further
information on the Investment securities portfolio.

Municipal Tender Option Bond Trusts

In a municipal tender option bond trust transaction, the client
transfers a municipal bond to a trust. The trust issues short-term
securities  that  the  Firm,  as  the  remarketing  agent,  sells  to
investors. The client generally retains a residual interest. The
short-term  securities  are  supported  by  a  liquidity  facility
pursuant  to  which  the  investors  may  put  their  short-term
interests. In most programs, a third-party provider will provide
such liquidity facility; in some programs, the Firm provides this
liquidity facility.

The Firm may, in lieu of purchasing short-term securities for
remarketing, decide to extend a temporary loan to the trust. The
client can generally terminate the transaction at any time. The
liquidity provider can generally terminate the transaction upon
the  occurrence  of  certain  events.  When  the  transaction  is
terminated, the municipal bond is generally sold or returned to
the client. Any losses suffered by the liquidity provider upon the
sale  of  the  bond  are  the  responsibility  of  the  client.  This
obligation  is  generally  collateralized.  Liquidity  facilities
provided to municipal tender option bond trusts are classified
as  derivatives.  The  Firm  consolidates  any  municipal  tender
option bond trusts in which it holds the residual interest.

Credit Protection Purchased through Credit-Linked Notes

CLN  transactions  are  designed  to  provide  investors  with
exposure  to  certain  credit  risk  on  referenced  assets.  In  these
transactions, the Firm transfers assets (generally high-quality
securities or money market investments) to an SPE, enters into
a derivative transaction in which the SPE sells protection on an
unrelated referenced asset or group of assets, through a credit
derivative, and sells the securities issued by the SPE to investors.
In some transactions, the Firm may also enter into interest rate
or currency swaps with the SPE. Depending on the structure,
the assets and liabilities of the SPE may be consolidated and
recognized in the Firm’s balance sheets or accounted for as a
sale of assets.

Upon the occurrence of a credit event related to the referenced
asset, the SPE will deliver securities collateral as payment to the
Firm,  which  exposes  the  Firm  to  changes  in  the  collateral’s
value.

Derivative payments by the SPE are collateralized. The risks
associated  with  these  and  similar  derivatives  with  SPEs  are
essentially the same as those with non-SPE counterparties and
are managed as part of the Firm’s overall exposure.

Other Structured Financings

The Firm invests in interests issued by entities that develop and
own low-income communities (including low-income housing
projects) and entities that construct and own facilities that will
generate energy from renewable resources. The interests entitle
the Firm to a share of tax credits and tax losses generated by
these projects. In addition, the Firm has issued guarantees to
investors in certain low-income housing funds. The guarantees
are designed to return an investor’s contribution to a fund and
the investor’s share of tax losses and tax credits expected to be
generated by the fund. The Firm is also involved with entities
designed to provide tax-efficient yields to the Firm or its clients.

Collateralized Loan and Debt Obligations

CLOs  and  CDOs  are  SPEs  that  purchase  a  pool  of  assets
consisting of corporate loans, corporate bonds, ABS or synthetic
exposures  on  similar  assets  through  derivatives,  and  issue
multiple tranches of debt and equity securities to investors. The
Firm  underwrites  the  securities  issued  in  certain  CLO
transactions  on  behalf  of  unaffiliated  sponsors  and  provides
advisory services to these unaffiliated sponsors. The Firm sells
corporate  loans  to  many  of  these  SPEs,  in  some  cases
representing a significant portion of the total assets purchased.
Although not obligated, the Firm generally makes a market in
the securities issued by SPEs in these transactions and may retain
unsold  securities.  These  beneficial  interests  are  included  in
Trading assets and are measured at fair value.

Equity-Linked Notes

ELN  transactions  are  designed  to  provide  investors  with
exposure to certain risks related to the specific equity security,
equity index or other index. In an ELN transaction, the Firm
typically transfers to an SPE either a note issued by the Firm,
the  payments  on  which  are  linked  to  the  performance  of  a
specific  equity  security,  equity  index  or  other  index,  or  debt
securities issued by other companies and a derivative contract,
the terms of which will relate to the performance of a specific
equity  security,  equity  index  or  other  index.  These  ELN
transactions with SPEs were not consolidated at December 31,
2019 or December 31, 2018.

129

December 2019 Form 10-K

At December 31, 20192

RML

CML

U.S. Agency
CMO

CLN and
Other3

$ in millions

Retained interests

Investment grade

$ 9,850 $ 86,203 $

19,132 $

8,410

Non-investment grade

Total

Fair Value at December 31, 2018

Level 2

Level 3

Total

$

$

1,580 $

13 $

1,593

174

252

426

1,754 $

265 $

2,019

Table of Contents
Notes to Consolidated Financial Statements

Transferred Assets with Continuing Involvement1

$ in millions
SPE assets (UPB)4

Retained interests

Investment grade

Non-investment grade

Total

$

$

29 $

720 $

2,376 $

17

254

—

46 $

974 $

2,376 $

Interests purchased in the secondary market

Investment grade

Non-investment grade

Total

Derivative assets

Derivative liabilities

$

$

$

6 $

197 $

75

51

81 $

248 $

— $

— $

—

—

77 $

—

77 $

— $

—

$ in millions
SPE assets (UPB)4

Retained interests

Investment grade

Non-investment grade

Total

December 31, 2018

RML

CML

U.S. Agency
CMO

CLN and
Other3

$14,376 $ 68,593 $

16,594 $ 14,608

$

$

17 $

483 $

1,573 $

4

212

—

21 $

695 $

1,573 $

Interests purchased in the secondary market

Investment grade

Non-investment grade

Total

Derivative assets

Derivative liabilities

$

$

$

7 $

91 $

102 $

28

71

35 $

162 $

— $

— $

—

—

—

102 $

— $

—

1

92

93

—

—

—

339

145

3

210

213

—

—

—

216

178

$ in millions

Retained interests

Investment grade

Non-investment grade

Total

Fair Value at December 31, 2019

Level 2

Level 3

Total

$

$

2,401 $

6

4 $

97

2,407 $

101 $

2,405

103

2,508

Interests purchased in the secondary market

Investment grade

Non-investment grade

Total

Derivative assets

Derivative liabilities

$

$

$

278 $

68

346 $

337 $

144

2 $

58

60 $

2 $

1

280

126

406

339

145

December 2019 Form 10-K

130

Interests purchased in the secondary market

Investment grade

Non-investment grade

Total

Derivative assets

Derivative liabilities

$

$

$

193 $

83

276 $

121 $

175

7 $

16

23 $

95 $

3

200

99

299

216

178

RML—Residential mortgage loans
CML—Commercial mortgage loans
1. The Transferred Assets with Continuing Involvement tables include transactions with
SPEs in which the Firm, acting as principal, transferred financial assets with continuing
involvement  and  received  sales  treatment.  See  Note  12  for  information  on  certain
other transfers of assets to SPEs which are accounted for as financings.

2. As permitted by applicable guidance, certain transfers of assets where the Firm’s only
continuing involvement is a derivative are only reported in the following Assets Sold
with  Retained  Exposure  table,  and  are  no  longer  also  included  in  this  table.  At
December 31, 2018 these transactions were included in CLN and Other and comprised
approximately $8 billion in UPB, $20 million in Derivative assets and $119 million in
Derivative liabilities.

3. Amounts include CLO transactions managed by unrelated third parties.
4. Amounts include assets transferred by unrelated transferors.

Transferred assets are carried at fair value prior to securitization,
and  any  changes  in  fair  value  are  recognized  in  the  income
statements. The Firm may act as underwriter of the beneficial
interests  issued  by  these  securitization  vehicles,  for  which
Investment  banking  revenues  are  recognized.  The  Firm  may
retain interests in the securitized financial assets as one or more
tranches  of  the  securitization.  These  retained  interests  are
generally carried at fair value in the balance sheets with changes
in fair value recognized in the income statements. Fair value for
these interests is measured using techniques that are consistent
with  the  valuation  techniques  applied  to  the  Firm’s  major
categories of assets and liabilities as described in Notes 2 and
3.

Proceeds from New Securitization Transactions and Sales of
Loans

$ in millions
New transactions1

2019

2018

2017

$ 34,464 $ 23,821 $ 23,939

Retained interests
Sales of corporate loans to CLO SPEs1, 2

7,403

2

2,904

317

2,337

191

1. Net gains on new transactions and sales of corporate loans to CLO entities at the time

of the sale were not material for all periods presented.

2. Sponsored by non-affiliates.

The Firm has provided, or otherwise agreed to be responsible
for,  representations  and  warranties  regarding  certain  assets
transferred in securitization transactions sponsored by the Firm
(see Note 13).

Table of Contents
Notes to Consolidated Financial Statements

Assets Sold with Retained Exposure

• Up to a 2.5% Common Equity Tier 1 CCyB, currently set by

$ in millions
Gross cash proceeds from sale of assets1

Fair value

Assets sold

Derivative assets recognized

in the balance sheets

Derivative liabilities recognized

in the balance sheets

December 31,
2019

December 31,
2018

$

$

38,661 $

27,121

39,137 $

26,524

647

152

164

763

1. The carrying value of assets derecognized at the time of sale approximates gross

cash proceeds.

The  Firm  enters  into  transactions  in  which  it  sells  securities,
primarily equities, and contemporaneously enters into bilateral
OTC derivatives with the purchasers of the securities, through
which it retains exposure to the sold securities.

15. Regulatory Requirements 

Regulatory Capital Framework

The Firm is an FHC under the Bank Holding Company Act of
1956, as amended, and is subject to the regulation and oversight
of  the  Board  of  Governors  of  the  Federal  Reserve  System
(“Federal  Reserve”). The  Federal  Reserve  establishes  capital
requirements for the Firm, including well-capitalized standards,
and  evaluates  the  Firm’s  compliance  with  such  capital
requirements. The OCC establishes similar capital requirements
and  standards  for  MSBNA  and  MSPBNA  (collectively,  the
“U.S. Bank Subsidiaries”). The regulatory capital requirements
are largely based on the Basel III capital standards established
by  the  Basel  Committee  on  Banking  Supervision  and  also
implement  certain  provisions  of  the  Dodd-Frank  Wall  Street
Reform and Consumer Protection Act.

Regulatory Capital Requirements

The  Firm  is  required  to  maintain  minimum  risk-based  and
leverage-based  capital 
regulatory  capital
requirements.  A  summary  of  the  calculations  of  regulatory
capital, RWA and transition provisions follows.

ratios  under 

Minimum  risk-based  capital  ratio  requirements  apply  to
Common Equity Tier 1 capital, Tier 1 capital and Total capital
(which includes Tier 2 capital). Capital standards require certain
adjustments  to,  and  deductions  from,  capital  for  purposes  of
determining these ratios.

In  addition 
requirements, the Firm is subject to the following buffers:

the  minimum  risk-based  capital  ratio

to 

• A  greater  than  2.5%  Common  Equity  Tier  1  capital

conservation buffer;

• The Common Equity Tier 1 G-SIB capital surcharge, currently

at 3%; and

U.S. banking agencies at zero.

In 2018, the requirement for each of these buffers was 75% of
the fully phased-in 2019 requirement noted above.

Risk-Weighted Assets

RWA reflects both the Firm’s on- and off-balance sheet risk, as
well as capital charges attributable to the risk of loss arising from
the following:

• Credit risk: The failure of a borrower, counterparty or issuer

to meet its financial obligations to the Firm;

• Market  risk: Adverse  changes  in  the  level  of  one  or  more
market prices, rates, indices, volatilities, correlations or other
market factors, such as market liquidity; and

• Operational risk: Inadequate or failed processes or systems,
from human factors or from external events (e.g., fraud, theft,
legal  and  compliance  risks,  cyber  attacks  or  damage  to
physical assets).

The Firm’s risk-based capital ratios for purposes of determining
regulatory  compliance  are  the  lower  of  the  capital  ratios
computed under (i) the standardized approaches for calculating
credit risk and market risk RWA (“Standardized Approach”) and
(ii) the applicable advanced approaches for calculating credit
risk,  market  risk  and  operational  risk  RWA  (“Advanced
Approach”). At  December 31,  2019  and  December 31,  2018,
the Firm’s risk-based capital ratios are based on the Standardized
Approach rules.

Minimum leverage-based capital requirements include a Tier 1
leverage ratio and an SLR. The Firm is required to maintain a
Tier 1 SLR of 5%, inclusive of an enhanced SLR capital buffer
of at least 2%.

The Firm’s Regulatory Capital and Capital Ratios

$ in millions

Risk-based capital

Common Equity Tier 1 capital

Tier 1 capital

Total capital

Total RWA

Leverage-based capital

Tier 1 leverage

Adjusted average assets2

SLR

At December 31, 2019

Required    
Ratio1    

Amount

Ratio

10.0% $

64,751

16.4%

11.5%

13.5%

73,443

18.6%

82,708

21.0%

394,177

4.0% $

73,443

8.3%

889,195

5.0%

73,443

6.4%

Supplementary leverage exposure3

1,155,177

131

December 2019 Form 10-K

 
Table of Contents
Notes to Consolidated Financial Statements

$ in millions

Risk-based capital

At December 31, 2018

Required    
Ratio1    

Amount

Ratio

MSBNA’s Regulatory Capital

$ in millions

Common Equity Tier 1 capital

8.6% $

62,086

16.9%

Risk-based capital

10.1%

12.1%

70,619

19.2%

Common Equity Tier 1 capital

80,052

21.8%

367,309

Tier 1 capital

Total capital

Tier 1 capital

Total capital

Total RWA

Leverage-based capital

Tier 1 leverage

Adjusted average assets2

SLR

4.0% $

70,619

8.4%

843,074

5.0%

70,619

6.5%

Supplementary leverage exposure3

1,092,672

1. Required ratios are inclusive of any buffers applicable as of the date presented. For
2018,  the  required  regulatory  capital  ratios  for  risk-based  capital  are  under  the
transitional rules. Failure to maintain the buffers would result in restrictions on the
Firm’s ability to make capital distributions, including the payment of dividends and the
repurchase of stock, and to pay discretionary bonuses to executive officers.

2. Adjusted average assets represents the denominator of the Tier 1 leverage ratio and
is composed of the average daily balance of consolidated on-balance sheet assets
for the quarters ending on the respective balance sheet dates, reduced by disallowed
goodwill,  intangible  assets,  investments  in  covered  funds,  defined  benefit  pension
plan assets, after-tax gain on sale from assets sold into securitizations, investments
in  the  Firm's  own  capital  instruments,  certain  defined  tax  assets  and  other  capital
deductions.

3. Supplementary leverage exposure is the sum of Adjusted average assets used in the
Tier 1 leverage ratio and other adjustments, primarily: (i) for derivatives, potential future
exposure and the effective notional principal amount of sold credit protection offset
by qualifying purchased credit protection; (ii) the counterparty credit risk for repo-style
transactions; and (iii) the credit equivalent amount for off-balance sheet exposures.

U.S.  Bank  Subsidiaries’  Regulatory  Capital  and  Capital
Ratios

The OCC establishes capital requirements for the Firm’s U.S.
Bank  Subsidiaries  and  evaluates  their  compliance  with  such
capital  requirements.  Regulatory  capital  requirements  for  the
U.S. Bank Subsidiaries are calculated in a similar manner to the
Firm’s regulatory capital requirements, although G-SIB capital
surcharge  requirements  do  not  apply  to  the  U.S.  Bank
Subsidiaries.

The  OCC’s  regulatory  capital  framework  includes  Prompt
Corrective  Action  (“PCA”)  standards, 
including  “well-
capitalized”  PCA  standards  that  are  based  on  specified
regulatory capital ratio minimums. For the Firm to remain an
FHC, the U.S. Bank Subsidiaries must remain well-capitalized
in  accordance  with  the  OCC’s  PCA  standards.  In  addition,
failure by the U.S. Bank Subsidiaries to meet minimum capital
requirements may result in certain mandatory and discretionary
actions  by  regulators  that,  if  undertaken,  could  have  a  direct
material effect on the U.S. Bank Subsidiaries’ and the Firm’s
financial statements.

At December 31, 2019 and December 31, 2018, the U.S. Bank
Subsidiaries’  risk-based  capital  ratios  are  based  on  the
Standardized Approach rules. In each period, the ratios exceeded
well-capitalized requirements.

December 2019 Form 10-K

132

At December 31, 2019

Required
Ratio1

Amount

Ratio

6.5% $ 15,919

18.5%

8.0% 15,919

18.5%

10.0% 16,282

18.9%

5.0% $ 15,919

11.3%

6.0% 15,919

8.7%

At December 31, 2018

Required
Ratio1

Amount

Ratio

6.5% $ 15,221

19.5%

8.0% 15,221

19.5%

10.0% 15,484

19.8%

5.0% $ 15,221

10.5%

6.0% 15,221

8.2%

At December 31, 2019

Required
Ratio1

Amount

Ratio

6.5% $

7,962

24.8%

8.0%

7,962

24.8%

10.0%

8,016

25.0%

5.0% $

7,962

6.0%

7,962

9.9%

9.4%

At December 31, 2018

Required
Ratio1

Amount

Ratio

6.5% $

7,183

25.2%

8.0%

7,183

25.2%

10.0%

7,229

25.4%

5.0% $

7,183

10.0%

6.0%

7,183

9.6%

Leverage-based capital

Tier 1 leverage

SLR

$ in millions

Risk-based capital

Common Equity Tier 1 capital

Tier 1 capital

Total capital

Leverage-based capital

Tier 1 leverage

SLR

MSPBNA’s Regulatory Capital

$ in millions

Risk-based capital

Common Equity Tier 1 capital

Tier 1 capital

Total capital

Leverage-based capital

Tier 1 leverage

SLR

$ in millions

Risk-based capital

Common Equity Tier 1 capital

Tier 1 capital

Total capital

Leverage-based capital

Tier 1 leverage

SLR

1. Ratios that are required in order to be considered well-capitalized for U.S. regulatory

purposes.

U.S. Broker-Dealer Regulatory Capital Requirements

MS&Co. Regulatory Capital

$ in millions

Net capital

Excess net capital

At
December 31, 
 2019

At
December 31, 
 2018

$

13,708 $

10,686

13,797

11,333

MS&Co.  is  a  registered  U.S.  broker-dealer  and  registered
futures commission merchant and, accordingly, is subject to the

 
Table of Contents
Notes to Consolidated Financial Statements

minimum net capital requirements of the SEC and the CFTC.
MS&Co. has consistently operated with capital in excess of its
regulatory capital requirements.

16. Total Equity 

Morgan Stanley Shareholders’ Equity

As an Alternative Net Capital broker-dealer, and in accordance
with Securities Exchange Act of 1934 (“Exchange Act”) Rule
15c3-1, Appendix E,  MS&Co. is subject to minimum net capital
and  tentative  net  capital  requirements.  In  addition,  MS&Co.
must notify the SEC if its tentative net capital falls below certain
levels.  At  December 31,  2019  and  December 31,  2018,
MS&Co.  has  exceeded  its  net  capital  requirement  and  has
tentative net capital in excess of the minimum and notification
requirements.

MSSB Regulatory Capital

$ in millions

Net capital

Excess net capital

At
December 31, 
 2019

At
December 31, 
 2018

$

3,387 $

3,238

3,455

3,313

MSSB is a registered U.S. broker-dealer and introducing broker
for  the  futures  business  and,  accordingly,  is  subject  to  the
minimum  net  capital  requirements  of  the  SEC.  MSSB  has
consistently  operated  with  capital  in  excess  of  its  regulatory
capital requirements.

Other Regulated Subsidiaries

MSIP, a London-based broker-dealer subsidiary, is subject to
the capital requirements of the PRA, and MSMS, a Tokyo-based
broker-dealer subsidiary, is subject to the capital requirements
of  the  Financial  Services  Agency.  MSIP  and  MSMS  have
consistently operated with capital in excess of their respective
regulatory capital requirements.

Certain  other  U.S.  and  non-U.S.  subsidiaries  of  the  Firm  are
subject  to  various  securities,  commodities  and  banking
regulations, and capital adequacy requirements promulgated by
the regulatory and exchange authorities of the countries in which
they operate. These subsidiaries have consistently operated with
capital in excess of their local capital adequacy requirements.

Restrictions on Payments

The  regulatory  capital  requirements  referred  to  above,  and
certain covenants contained in various agreements governing
indebtedness  of  the  Firm,  may  restrict  the  Firm’s  ability  to
withdraw  capital  from  its  subsidiaries.  The  following  table
represents net assets of consolidated subsidiaries that may be
restricted as to the payment of cash dividends and advances to
the Parent Company.

$ in millions

Restricted net assets

At
December 31, 
 2019

At
December 31, 
 2018

$

33,213 $

29,222

Common Stock

Rollforward of Common Stock Outstanding

in millions

Shares outstanding at beginning of period
Treasury stock purchases1
Other2

Shares outstanding at end of period

2019

2018

1,700

(135)

29

1,788

(110)

22

1,594

1,700

1. The Firm’s Board has authorized the repurchase of the Firm’s outstanding stock under
a share repurchase program (“Share Repurchase Program”). In addition to the Firm’s
Share  Repurchase  Program,  Treasury  stock  purchases  include  repurchases  of
common stock for employee tax withholding.

2. Other  includes  net  shares  issued  to  and  forfeited  from  Employee  stock  trusts  and

issued for RSU conversions.

Share Repurchases

$ in millions

2019

2018

Repurchases of common stock under the Firm’s 

Share Repurchase Program

$

5,360 $

4,860

The Firm’s 2019 Capital Plan (“Capital Plan”) includes the share
repurchase of up to $6.0 billion of outstanding common stock
for the period beginning July 1, 2019 through June 30, 2020.
Additionally, the Capital Plan includes quarterly common stock
dividends of up to $0.35 per share, beginning with the common
stock dividend announced on July 18, 2019.

A portion of common stock repurchases was conducted under
a sales plan with MUFG, whereby MUFG sold shares of the
Firm’s common stock to the Firm, as part of the Firm’s Share
Repurchase Program. The sales plan is only intended to maintain
MUFG’s ownership percentage below 24.9% in order to comply
with MUFG’s passivity commitments to the Board of Governors
of the Federal Reserve System and has no impact on the strategic
alliance  between  MUFG  and  the  Firm,  including  the  joint
ventures in Japan.

Pursuant to the Share Repurchase Program, the Firm considers,
among other things, business segment capital needs, as well as
stock-based compensation and benefit plan requirements. Share
repurchases under the program will be exercised from time to
time  at  prices  the  Firm  deems  appropriate  subject  to  various
factors,  including  the  Firm’s  capital  position  and  market
conditions. The share repurchases may be effected through open
market purchases or privately negotiated transactions, including
through Rule 10b5-1 plans, and may be suspended at any time.
Share repurchases by the Firm are subject to regulatory non-
objection.

Common Stock Dividends per Share

Dividends declared per common share

$ 1.30 $ 1.10 $ 0.90

2019

2018

2017

133

December 2019 Form 10-K

 
Table of Contents
Notes to Consolidated Financial Statements

Common Shares Outstanding for Basic and Diluted EPS

Preferred Stock Issuance Description

in millions

2019

2018

2017

Weighted average common shares outstanding,

basic

1,617

1,708

1,780

Series1, 2

A
C5

E

F

H

I

J

K
L6

A

C

E

F
G2
H3
I
J4
K

L

Shares
Issued

Depositary
Shares
per Share

Redemption

Price
per Share3

Date4

44,000

1,000

$

25,000

July 15, 2011

1,160,791

34,500

34,000

52,000

40,000

60,000

40,000

20,000

N/A

1,000

1,000

25

1,000

25

1,000

1,000

1,100 October 15, 2011

25,000 October 15, 2023

25,000

January 15, 2024

25,000

July 15, 2019

25,000 October 15, 2024

25,000

25,000

July 15, 2020

April 15, 2027

25,000

January 15, 2025

1. All shares issued are non-cumulative. Each share has a par value of $0.01, except

Series C.

2. Dividends on Series A are based on a floating rate, and dividends on Series C and L
are based on a fixed rate. Dividends on all other Series are based on a fixed-to-floating
rate.

3. Series A  and  C  are  redeemable  at  the  redemption  price  plus  accrued  and  unpaid
dividends, regardless of whether dividends are actually declared, up to but excluding
the date of redemption. All other Series are redeemable at the redemption price plus
any declared and unpaid dividends, up to but excluding the date fixed for redemption.
4. Series A and C are redeemable at the Firm’s option, in whole or in part, on or after the
redemption date. All other Series are redeemable at the Firm’s option (i) in whole or
in part, from time to time, on any dividend payment date on or after the redemption
date or (ii) in whole but not in part at any time within 90 days following a regulatory
capital treatment event (as described in the terms of that series).

5. Series C is non-voting perpetual preferred stock. Dividends on the Series C preferred
stock are payable, on a non-cumulative basis, as and if declared by the Board, in cash,
at the rate of 10% per annum of the liquidation preference of $1,000 per share.

6. Series L Preferred Stock was issued on November 25, 2019. 

Preferred Stock Dividends

2019

2018

2017

Per 

Share1 Total

Per

Share1 Total

Per

Share1 Total

$ 1,014 $ 44

$ 1,011 $ 45

$ 1,014 $ 45

100

1,781

1,719

1,242

1,418

1,594

1,388

1,463

169

52

60

60

24

74

64

84

59

3

100

1,781

1,719

1,656

1,363

1,594

1,388

1,463

—

52

61

58

33

71

64

83

59

—

100

1,781

1,719

1,656

1,363

1,594

1,388

1,402

—

52

61

58

33

71

64

83

56

—

Total

$524

$526

$523

1. Dividends on all series are payable quarterly, unless otherwise noted.
2. Dividends declared on Series G following the issuance of the notice of redemption

were recognized as Interest expense and are excluded from 2019 amounts.

3. Series H was payable semiannually until July 15, 2019, and is now payable quarterly.
4. Series J is payable semiannually until July 15, 2020, and then quarterly thereafter. 

Total

$

8,520 $

1. Series C is composed of the issuance of 1,160,791 shares of Series C Preferred Stock
to  MUFG  for  an  aggregate  purchase  price  of  $911  million,  less  the  redemption  of
640,909 shares of Series C Preferred Stock of $503 million, which were converted to
common shares of approximately $705 million in 2009.

$ in millions, except per share

data

Series

Effect of dilutive Stock options, RSUs and PSUs

23

30

41

Weighted average common shares 

outstanding and common stock equivalents,
diluted

Weighted average antidilutive common stock

equivalents (excluded from the computation of
diluted EPS)

1,640

1,738

1,821

2

1

—

Preferred Stock

$ in millions,
except per
share data

Series

A
C1

E

F

G

H

I

J

K

L

Shares
Outstanding

Carrying Value

At
December 31,
2019

Liquidation
Preference
per Share

At
December 31,
2019

At
December 31,
2018

44,000 $

25,000 $

1,100 $

1,100

519,882

34,500

34,000

—

52,000

40,000

60,000

40,000

20,000

1,000

25,000

25,000

—

25,000

25,000

25,000

25,000

25,000

408

862

850

—

1,300

1,000

1,500

1,000

500

408

862

850

500

1,300

1,000

1,500

1,000

—

8,520

The Firm is authorized to issue 30 million shares of preferred
stock. The preferred stock has a preference over the common
stock upon liquidation. The Firm’s preferred stock qualifies as
and is included in Tier 1 capital in accordance with regulatory
capital requirements (see Note 15).

On November 25, 2019, the Firm announced the redemption in
whole of its outstanding Series G preferred stock. On notice of
redemption, the amount due to holders of Series G Preferred
Stock was reclassified to Borrowings, and on January 15, 2020
the redemption settled at the carrying value of $500 million.

December 2019 Form 10-K

134

 
 
Table of Contents
Notes to Consolidated Financial Statements

Comprehensive Income (Loss)

Accumulated Comprehensive Income (Loss)1 

Foreign
Currency
Translation
Adjustments

AFS 
Securities

Pensions,
Postretirement
and Other

DVA

Total

$

(986) $

(588) $

(474) $ (595) $ (2,643)

20181

$ in millions

Pre-tax
Gain
(Loss)

Income Tax
Benefit
(Provision)

After-tax
Gain
(Loss)

Non-
controlling
Interests

Net

Foreign currency translation adjustments

OCI activity

Reclassified to 

earnings

Net OCI

$

(11) $

(79) $

(90) $

24 $

(114)

—

—

—

—

—

$

(11) $

(79) $

(90) $

24 $

(114)

$ in millions

December 31,
2016

OCI during the 

period

December 31,
2017

Cumulative

adjustment for
accounting
change2

OCI during the 

period

December 31,
2018

OCI during the 

period

December 31,
2019

219

41

(117)

(560)

(417)

Change in net unrealized gains (losses) on AFS securities

(767)

(547)

(591)

(1,155)

(3,060)

OCI activity

Reclassified to 

earnings

Net OCI

$ (346) $

80 $

(266) $

— $

(266)

(8)

2

(6)

—

(6)

$ (354) $

82 $

(272) $

— $

(272)

(8)

(111)

(124)

(194)

(437)

Pension, postretirement and other

(114)

(272)

137

1,454

1,205

(889)

(930)

(578)

105

(2,292)

OCI activity

Reclassified to 

earnings

Net OCI

$

156 $

(37) $

119 $

— $

119

26

(8)

18

—

18

$

182 $

(45) $

137 $

— $

137

(8)

1,137

(66)

(1,559)

(496)

Change in net DVA

$

(897) $

207 $

(644) $ (1,454) $ (2,788)

1. Amounts are net of tax and noncontrolling interests.
2. The  cumulative  adjustment  for  accounting  changes  is  primarily  the  effect  of  the
adoption  of  the  accounting  update  Reclassification  of  Certain  Tax  Effects  from
Accumulated  Other  Comprehensive  Income.  This  adjustment  was  recorded  as  of
January 1, 2018 to reclassify certain income tax effects related to the enactment of
the Tax Act from AOCI to Retained earnings, primarily related to the remeasurement
of deferred tax assets and liabilities resulting from the reduction in the corporate income
tax rate to 21%. See Note 2 for further information.

Components of Period Changes in OCI

$ in millions

Pre-tax
Gain
(Loss)

Income
Tax Benefit
(Provision)

After-tax
Gain
(Loss)

Non-
controlling
Interests

Foreign currency translation adjustments

2019

6 $

(3) $

3 $

11 $

(8)

OCI activity

Reclassified to 

earnings

Net OCI

$ 1,947 $

(472) $

1,475 $

63 $ 1,412

56

(14)

42

—

42

$ 2,003 $

(486) $

1,517 $

63 $ 1,454

2017

$ in millions

Pre-tax
Gain
(Loss)

Income Tax
Benefit
(Provision)

After-tax
Gain
(Loss)

Non-
controlling
Interests

Net

Foreign currency translation adjustments

OCI activity

Reclassified to 

earnings

Net OCI

$

$

64 $

187 $

251 $

32 $

219

—

—

—

—

—

64 $

187 $

251 $

32 $

219

OCI activity

Reclassified to 

earnings

Net OCI

$

$

OCI activity

Reclassified to 

earnings

Net OCI

OCI activity

Reclassified to 

earnings

Net OCI

Change in net DVA

OCI activity

Reclassified to 

earnings

Net OCI

Net

Change in net unrealized gains (losses) on AFS securities

OCI activity

Reclassified to 

earnings

$

100 $

(36) $

64 $

— $

64

(35)

12

(23)

—

— $

(23)

41

—

6 $

—

(3) $

—

—

3 $

11 $

—

(8)

Net OCI

$

65 $

(24) $

41 $

Pension, postretirement and other

Change in net unrealized gains (losses) on AFS securities

$ 1,588 $

(373) $

1,215 $

— $ 1,215

OCI activity

Reclassified to 

earnings

$ (193) $

75 $

(118) $

— $

(118)

2

(1)

1

—

1

(103)

25

(78)

—

(78)

Net OCI

$ (191) $

74 $

(117) $

— $

(117)

$ 1,485 $

(348) $

1,137 $

— $ 1,137

Change in net DVA

Pension, postretirement and other

$

(98) $

25 $

(73) $

— $

(73)

OCI activity

Reclassified to 

earnings

$ (922) $

325 $

(597) $

(28) $

(569)

12

(3)

9

—

9

12

(5)

7

—

7

Net OCI

$ (910) $

322 $

(588) $

(28) $

(560)

$

(86) $

20 $

(66) $

— $

(66)

$ (2,181) $

533 $ (1,648) $

(80) $ (1,568)

11

(2)

9

—

9

$ (2,170) $

531 $ (1,639) $

(80) $ (1,559)

1. Exclusive  of  cumulative  adjustments  related  to  the  adoption  of  certain  accounting

updates in 2018. Refer to the table below and Note 2 for further information.

135

December 2019 Form 10-K

Table of Contents
Notes to Consolidated Financial Statements

Cumulative  Adjustments  to  Retained  Earnings  Related  to
Adoption of Accounting Updates

17. Interest Income and Interest Expense 

$ in millions

63

Interest income

2019

2018

2017

$ in millions

Leases

$ in millions

Revenues from contracts with customers

Derivatives and hedging—targeted improvements to

accounting for hedging activities

Reclassification of certain tax effects from AOCI
Other1

Total

$ in millions

Improvements to employee share-based payment

accounting2

Intra-entity transfers of assets other than inventory

Total

2019

2018

2017

$

$

$

$

$

(32)

(99)

443

(6)

306

(30)

(5)

(35)

1. Other  includes  the  adoption  of  accounting  updates  related  to  Recognition  and
Measurement of Financial Assets and Financial Liabilities (other than the provision
around presenting unrealized DVA in OCI, which the Firm previously adopted) and
Derecognition  of  Nonfinancial Assets. The  impact  of  these  adoptions  on  Retained
earnings was not significant.

2. In addition to the Retained earnings impact, this adoption also resulted in a $45 million

increase to Additional paid-in capital.

Cumulative Foreign Currency Translation Adjustments

$ in millions

Associated with net investments in
subsidiaries with a non-U.S. dollar
functional currency

Hedges, net of tax

Total

Carrying value of net investments in non-

U.S. dollar functional currency subsidiaries
subject to hedges

At
December 31, 
 2019

At
December 31, 
 2018

$

$

$

(1,874) $

(1,851)

977

(897) $

962

(889)

13,440 $

11,608

Cumulative  foreign  currency  translation  adjustments  include
gains  or  losses  resulting  from  translating  foreign  currency
financial statements from their respective functional currencies
to  U.S.  dollars,  net  of  hedge  gains  or  losses  and  related  tax
effects. The Firm uses foreign currency contracts to manage the
currency exposure relating to its net investments in non-U.S.
dollar  functional  currency  subsidiaries  and  determines  the
amount of exposure to hedge on a pre-tax basis. The Firm may
also  elect  not  to  hedge  its  net  investments  in  certain  foreign
operations due to market conditions or other reasons, including
the availability of various currency contracts at acceptable costs.
Information  relating  to  the  effects  on  cumulative  foreign
currency  translation  adjustments  that  resulted  from  the
translation of foreign currency financial statements and from
gains and losses from hedges of the Firm’s net investments in
non-U.S. dollar functional currency subsidiaries is summarized
in the previous table.

December 2019 Form 10-K

136

Investment securities

$

2,175 $

1,744 $

1,334

Loans

4,783

4,249

3,298

Securities purchased under agreements to

resell and Securities borrowed1

Trading assets, net of Trading liabilities
Customer receivables and Other2

3,485

2,899

3,756

1,976

2,392

3,531

169

2,029

2,167

Total interest income

$ 17,098 $ 13,892 $

8,997

Interest expense

Deposits

Borrowings

Securities sold under agreements to
repurchase and Securities loaned3

Customer payables and Other4

Total interest expense

Net interest

$

1,885 $

1,255 $

187

5,052

5,031

4,285

2,609

2,858

1,898

1,902

1,237

(12)

$ 12,404 $ 10,086 $

5,697

$

4,694 $

3,806 $

3,300

1. Includes fees paid on Securities borrowed.
2. Includes interest from Cash and cash equivalents.
3. Includes fees received on Securities loaned.
4. Includes fees received from prime brokerage customers for stock loan transactions

entered into to cover customers’ short positions.

Interest income and Interest expense are classified in the income
statements  based  on  the  nature  of  the  instrument  and  related
market  conventions.  When  included  as  a  component  of  the
instrument’s  fair  value,  interest  is  included  within  Trading
revenues  or  Investments  revenues.  Otherwise,  it  is  included
within Interest income or Interest expense.

18.  Deferred  Compensation  Plans  and  Carried
Interest Compensation 

Stock-Based Compensation Plans

Certain employees of the Firm participate in the Firm's stock-
based compensation plans. These plans include RSUs and PSUs,
the details of which are further outlined below.

Stock-Based Compensation Expense

$ in millions

RSUs

PSUs
Total1

Includes:

2019

2018

2017

$

1,064 $

892 $

89

28

951

75

$

1,153 $

920 $

1,026

Retirement-eligible awards2

$

111 $

110 $

85

1. Net of forfeitures.
2. Relates to stock-based compensation anticipated to be awarded in January of the

following year that does not contain a future service requirement.

Tax Benefit Related to Stock-Based Compensation Expense

$ in millions
Tax benefit1

2019

2018

2017

$

243 $

193 $

225

1. Excludes  income  tax  consequences  related  to  employee  share-based  award

conversions.

 
Table of Contents
Notes to Consolidated Financial Statements

Unrecognized  Compensation  Cost  Related  to  Stock-Based
Awards Granted

Vested and Unvested RSU Activity

$ in millions

To be recognized in:

2020

2021

Thereafter

Total

At 
December 31,
20191

$

$

394

168

30

592

1. Amounts do not include forfeitures, cancellations, accelerations, future adjustments
to fair value for certain awards, or 2019 performance year compensation awarded in
January 2020, which will begin to be amortized in 2020.

In connection with awards under its stock-based compensation
plans, the Firm is authorized to issue shares of common stock
held in treasury or newly issued shares.

The Firm generally uses treasury shares, if available, to deliver
shares to employees or employee stock trusts and has an ongoing
repurchase  authorization 
in
that 
connection  with  awards  under  its  stock-based  compensation
plans. Share repurchases by the Firm are subject to regulatory
non-objection.

repurchases 

includes 

Common  Shares  Available  for  Future  Awards  under  Stock-
Based Compensation Plans

in millions

Shares

At
December 31,
2019

123

shares in millions

RSUs at beginning of period

Awarded

Conversions to common stock

Forfeited
RSUs at end of period1

Aggregate intrinsic value of RSUs at end of period 

(dollars in millions)

Weighted average award date fair value

RSUs awarded in 2018

RSUs awarded in 2017

2019

Weighted
Average
Award Date
Fair Value

Number of
Shares

74 $

27

(35)

(1)

65 $

$

$

37.59

43.05

28.95

43.66

44.38

3,294

55.40

42.98

1. At December 31, 2019, the weighted average remaining term until delivery for the

outstanding RSUs was approximately 1.2 years.

Unvested RSU Activity

shares in millions

Unvested RSUs at beginning of period

Awarded

Vested

Forfeited
Unvested RSUs at end of period1

2019

Weighted
Average
Award Date
Fair Value

Number of
Shares

41 $

27

(30)

(1)

37 $

40.65

43.05

37.80

43.66

44.58

1. Unvested  RSUs  represent  awards  where  recipients  have  yet  to  satisfy  either  the

explicit vesting terms or retirement-eligible requirements.

See  Note  16  for  additional  information  on  the  Firm’s  Share
Repurchase Program.

Fair Value of RSU Activity

Restricted Stock Units

RSUs are subject to vesting over time, generally one to seven
years  from  the  date  of  award,  contingent  upon  continued
employment  and  subject  to  restrictions  on  sale,  transfer  or
assignment until conversion to common stock. All or a portion
of an award may be forfeited if employment is terminated before
the  end  of  the  relevant  vesting  period  or  cancelled  after  the
relevant vesting period in certain situations. Recipients of RSUs
may have voting rights, at the Firm’s discretion, and generally
receive dividend equivalents if the awards vest.

$ in millions

2019

2018

2017

Conversions to common stock

$

1,497 $

1,790 $

1,333

Vested

1,292

1,504

1,470

Performance-Based Stock Units

PSUs will vest and convert to shares of common stock only if
the Firm satisfies predetermined performance and market-based
conditions over a three-year performance period. The number
of PSUs that will vest ranges from 0% to 150% of the target
award,  based  on  the  extent  to  which  the  Firm  achieves  the
specified  performance  goals.  One-half  of  the  award  will  be
earned based on the Firm’s average return on equity, excluding
certain adjustments specified in the plan terms (“MS Adjusted
ROE”). The other half of the award will be earned based on the
Firm’s total shareholder return, relative to the total shareholder
return of the S&P 500 Financials Sector Index (“Relative MS
TSR”).  PSUs  have  vesting,  restriction,  forfeiture  and
cancellation  provisions  that  are  generally  similar  to  those  of
RSUs. At December 31, 2019, approximately 3 million PSUs
were outstanding.

137

December 2019 Form 10-K

Table of Contents
Notes to Consolidated Financial Statements

PSU Fair Value on Award Date

19. Employee Benefit Plans 

MS Adjusted ROE

Relative MS TSR

2019

2018

2017

$

43.29 $

56.84 $

42.64

Pension and Other Postretirement Plans

48.28

65.81

48.02

Components of Net Periodic Benefit Expense (Income)

The  Relative  MS  TSR  fair  values  on  the  award  date  were
estimated  using  a  Monte  Carlo  simulation  and  the  following
assumptions.

Monte Carlo Simulation Assumptions

Award Year

2019

2018

2017

Risk-Free
Interest Rate

Expected
Stock Price
Volatility

Correlation
Coefficient

2.6%

2.2%

1.5%

26.5%

26.8%

27.0%

0.89

0.89

0.89

The risk-free interest rate was determined based on the yields
available on U.S. Treasury zero-coupon issues. The expected
stock price volatility was determined using historical volatility.
The correlation coefficient was developed based on historical
price data of the Firm and the S&P 500 Financials Sector Index.
The  model  uses  an  expected  dividend  yield  equivalent  to
reinvesting dividends.

Deferred Cash-Based Compensation Plans

Deferred  cash-based  compensation  plans  generally  provide  a
return to the plan participants based upon the performance of
each participant’s referenced investments.

Deferred Cash-Based Compensation Expense

$ in millions

2019

2018

2017

Deferred cash-based awards

$

1,233 $

1,174 $

1,039

Return on referenced investments
Total1

645

(48)

499

$

1,878 $

1,126 $

1,538

Includes:

Retirement-eligible awards2

$

195 $

193 $

176

1. Net of forfeitures.
2. Relates to deferred cash-based compensation anticipated to be awarded in January

of the following year that does not contain a future service requirement.

Carried Interest Compensation

$ in millions

Service cost, benefits earned during the

period

Interest cost on projected benefit obligation

Expected return on plan assets

Net amortization of prior service cost (credit)

Net amortization of actuarial loss

Pension Plans

2019

2018

2017

$

16 $

16 $

139

(114)

1

13

134

(112)

(1)

26

16

146

(117)

—

17

62

Net periodic benefit expense

$

55 $

63 $

$ in millions

Other Postretirement Plans

2019

2018

2017

Service cost, benefits earned during the

period

Interest cost on projected benefit obligation

Net amortization of prior service credit

Net periodic benefit expense (income)

$

$

1 $

1 $

2

—

3

(1)

3 $

3 $

1

3

(16)

(12)

Certain U.S. employees of the Firm and its U.S. affiliates who
were hired before July 1, 2007 are covered by the U.S. pension
plan,  a  non-contributory  defined  benefit  pension  plan  that  is
qualified under Section 401(a) of the Internal Revenue Code
(“U.S.  Qualified  Plan”).  The  U.S.  Qualified  Plan  has  ceased
future benefit accruals.

Unfunded supplementary plans (“Supplemental Plans”) cover
certain  executives.  Liabilities  for  benefits  payable  under  the
Supplemental  Plans  are  accrued  by  the  Firm  and  are  funded
when  paid.  The  Morgan  Stanley  Supplemental  Executive
Retirement  and  Excess  Plan  (“SEREP”),  a  non-contributory
defined benefit plan that is not qualified under Section 401(a)
of the Internal Revenue Code, has ceased future benefit accruals.

Certain of the Firm’s non-U.S. subsidiaries also have defined
benefit pension plans covering their eligible employees.

The  Firm’s  pension  plans  generally  provide  pension  benefits
that are based on each employee’s years of credited service and
on compensation levels specified in the plans.

The Firm generally recognizes compensation expense for any
portion of carried interest (both realized and unrealized) that is
allocated to employees.

The Firm has unfunded postretirement benefit plans that provide
health care and life insurance for eligible U.S. retirees and health
care insurance for their dependents.

Carried Interest Compensation Expense

$ in millions

Expense

2019

2018

2017

$

534 $

156 $

197

December 2019 Form 10-K

138

 
Table of Contents
Notes to Consolidated Financial Statements

Rollforward of Pre-tax AOCI

Benefit Obligation and Funded Status

Pension Plans

2019

2018

2017

Rollforward  of  the  Benefit  Obligation  and  Fair  Value  of  Plan
Assets

$ in millions

Beginning balance

Net gain (loss)

Prior service credit (cost)

Amortization of prior service cost (credit)

Amortization of net loss

Changes recognized in OCI

$

(779) $

(947) $

(112)

—

1

13

(98)

158

(15)

(1)

26

168

Ending balance

$

(877) $

(779) $

$ in millions

Beginning balance

Net gain

Amortization of prior service credit

Changes recognized in OCI

Other Postretirement Plans

2019

2018

2017

$

13 $

1 $

13

—

13

13

(1)

12

Ending balance

$

26 $

13 $

(761)

(205)

2

—

17

(186)

(947)

17

—

(16)

(16)

1

The Firm generally amortizes into net periodic benefit expense
(income) the unrecognized net gains and losses exceeding 10%
of the greater of the projected benefit obligation or the market-
related value of plan assets. The U.S. pension plans amortize
the  unrecognized  net  gains  and  losses  over  the  average  life
expectancy  of  participants.  The  remaining  plans  generally
amortize the unrecognized net gains and losses and prior service
credit  over  the  average  remaining  service  period  of  active
participants.

Weighted  Average  Assumptions  Used  to  Determine  Net
Periodic Benefit Expense (Income)

Discount rate

Expected long-term rate of return on plan

assets

Rate of future compensation increases

Discount rate

Pension Plans

2019

2018

2017

4.01%

3.46%

4.01%

3.52%

3.34%

3.50%

3.38%

3.52%

3.10%

Other Postretirement Plans

2019

2018

2017

4.07%

3.44%

4.01% 

The  accounting  for  pension  and  other  postretirement  plans
involves certain assumptions and estimates. The expected long-
term rate of return for the U.S. Qualified Plan was estimated by
computing  a  weighted  average  of  the  underlying  long-term
expected  returns  based  on  the  investment  managers’  target
allocations.

Pension Plans

Other Post-
retirement Plans

$ in millions

2019

2018

2019

2018

Rollforward of benefit obligation

Benefit obligation at beginning

of year

Service cost

Interest cost
Actuarial loss (gain)1

Plan amendments

Plan settlements

Benefits paid
Other2

$

3,563 $

3,966 $

71 $

16

139

497

—

(9)

(191)

11

16

134

(340)

15

(11)

(195)

(22)

86

1

3

1

2

(13)

(13)

—

—

(5)

—

—

—

(6)

—

Benefit obligation at end of

year

$

4,026 $

3,563 $

56 $

71

Rollforward of fair value of plan assets

Fair value of plan assets at

beginning of year

Actual return on plan assets

Employer contributions

Benefits paid

Plan settlements
Other2

Fair value of plan assets at

end of year

Funded (unfunded) status

$

$

$

3,203 $

3,468 $

— $

499

36

(69)

34

(191)

(195)

(9)

15

(11)

(24)

—

5

(5)

—

—

3,553 $

3,203 $

— $

—

—

6

(6)

—

—

—

(473) $

(360) $

(56) $

(71)

Amounts recognized in the balance sheets

Assets

Liabilities

Net amount recognized

$

$

98 $

151 $

— $

(571)

(511)

(56)

(473) $

(360) $

(56) $

—

(71)

(71)

1. Primarily reflects the impact of year-over-year discount rate fluctuations.
2. Includes foreign currency exchange rate changes.

Accumulated Benefit Obligation

$ in millions

Pension plans

At
December 31,
2019

At
December 31,
2018

$

4,013 $

3,546

Pension Plans with Benefit Obligations in Excess of the Fair
Value of Plan Assets

$ in millions

At
December 31,
2019

At
December 31,
2018

Projected benefit obligation

$

637 $

Accumulated benefit obligation

Fair value of plan assets

624

66

575

559

64

The pension plans included in the table above may differ based
on their funding status as of December 31st of each year.

139

December 2019 Form 10-K

Table of Contents
Notes to Consolidated Financial Statements

Weighted  Average  Assumptions  Used  to  Determine  Benefit
Obligation

Plan Assets

Pension Plans

Other Postretirement Plans

At
December 31,
2019

At
December 31,
2018

At
December 31,
2019

At
December 31,
2018

3.08%

4.01%

3.11%

4.07%

Fair Value of Plan Assets

At December 31, 2019

$ in millions

Level 1

Level 2

Level 3

Total

Assets
Cash and cash equivalents1

$

3 $

— $

— $

3

3.28%

3.34%

N/A

N/A

U.S. government and agency securities:

Discount rate

Rate of future 

compensation 
increase

The discount rates used to determine the benefit obligation for
the U.S. pension and postretirement plans were selected by the
Firm,  in  consultation  with  its  independent  actuary,  using  a
pension discount yield curve based on the characteristics of the
plans,  each  determined  independently.  The  pension  discount
yield curve represents spot discount yields based on duration
implicit in a representative broad-based Aa-rated corporate bond
universe of high-quality fixed income investments. For all non-
U.S.  pension  plans,  the  Firm  set  the  assumed  discount  rates
based on the nature of liabilities, local economic environments
and available bond indices.

Assumed Health Care Cost Trend Rates Used to Determine the
U.S. Postretirement Benefit Obligation

At
December 31,
2019

At
December 31,
2018

Health care cost trend rate assumed for next year

Medical

Prescription

Rate to which the cost trend rate is

assumed to decline (ultimate trend rate)

Year that the rate reaches the ultimate trend

rate

5.48%

8.00%

5.66%

7.66%

4.41%

4.50%

U.S. Treasury securities

U.S. agency securities

Total U.S. government
and agency securities

Corporate and other debt—CDO

Other investments
Other receivables1

Total

Assets Measured at NAV

Commingled trust funds:

2,658

—

2,658

—

—

—

—

292

292

9

—

48

—

—

—

—

53

—

2,658

292

2,950

9

53

48

$ 2,661 $

349 $

53 $ 3,063

Money market

Foreign funds:

Fixed income

Liquidity

Targeted cash flow

Total

Liabilities

Derivative contracts
Other payables1

Total liabilities

137

136

30

240

543

(1)

(52)

(53)

$

—

—

(1)

(52)

—

—

$

— $

(53) $

— $

Fair value of plan assets

$ 3,553

At December 31, 2018

2029

2038

$ in millions

Level 1

Level 2

Level 3

Total

Assets
Cash and cash equivalents1

$

3 $

— $

— $

3

U.S. government and agency securities:

U.S. Treasury securities

U.S. agency securities

Total U.S. government
and agency securities

Corporate and other debt—CDO

Derivative contracts

Other investments

Total

Assets Measured at NAV

Commingled trust funds:

Money market

Foreign funds:

Fixed income

Liquidity

Targeted cash flow

Total

Fair value of plan assets

2,197

—

2,197

—

—

—

—

317

317

11

22

—

—

—

—

—

—

48

2,197

317

2,514

11

22

48

$ 2,200 $

350 $

48 $

2,598

252

134

12

207

605

3,203

$

$

1. Cash and cash equivalents, other receivables and other payables are valued at their

carrying value, which approximates fair value.

December 2019 Form 10-K

140

 
Table of Contents
Notes to Consolidated Financial Statements

Rollforward of Level 3 Plan Assets

$ in millions

Balance at beginning of period

Actual return on plan assets related to assets

held at end of period

Purchases, sales, other settlements and

issuances, net

Balance at end of period

$

$

2019

2018

48 $

3

2

53 $

47

—

1

48

There were no transfers between levels during 2019 and 2018.

The U.S. Qualified Plan’s assets represent 87% of the Firm’s
total  pension  plan  assets.  The  U.S.  Qualified  Plan  uses  a
combination  of  active  and  risk-controlled  fixed  income
investment strategies. The fixed income asset allocation consists
primarily  of  fixed  income  securities  and  related  derivative
instruments designed to approximate the expected cash flows
of the plan’s liabilities in order to help reduce plan exposure to
interest  rate  variation  and  to  better  align  assets  with  the
obligation.  The  longer-duration  fixed  income  allocation  is
expected to help protect the plan’s funded status and maintain
the  stability  of  plan  contributions  over  the  long  run.  The
investment  portfolio  performance  is  assessed  by  comparing
actual investment performance with changes in the estimated
present value of the U.S. Qualified Plan’s benefit obligation.

Derivative instruments are permitted in the U.S. Qualified Plan’s
investment portfolio only to the extent that they comply with all
of  the  plan’s  investment  policy  guidelines  and  are  consistent
with the plan’s risk and return objectives.

As a fundamental operating principle, any restrictions on the
underlying assets apply to a respective derivative product. This
includes percentage allocations and credit quality. Derivatives
are used solely for the purpose of enhancing investment in the
underlying assets and not to circumvent portfolio restrictions.

Plan assets are measured at fair value using valuation techniques
that are consistent with the valuation techniques applied to the
Firm’s major categories of assets and liabilities as described in
Notes 2 and 3. OTC derivative contracts consist of investments
in interest rate swaps and total return swaps. Other investments
consist of pledged insurance annuity contracts held by non-U.S.-
based plans. The pledged insurance annuity contracts are valued
based on the premium reserve of the insurer for a guarantee that
the  insurer  has  given  to  the  employee  benefit  plan  that
approximates  fair  value.  The  pledged  insurance  annuity
contracts are categorized in Level 3 of the fair value hierarchy.

Commingled trust funds are privately offered funds regulated,
supervised and subject to periodic examination by a U.S. federal
or state agency and available to institutional clients. The trust
investment  or
must  be  maintained  for 
reinvestment of assets contributed to it from U.S. tax-qualified
employee benefit plans maintained by more than one employer
or  controlled  group  of  corporations.  The  sponsor  of  the
commingled trust funds values the funds based on the fair value

the  collective 

of  the  underlying  securities.  Commingled  trust  funds  are
redeemable at NAV at the measurement date or in the near future.

Some non-U.S.-based plans hold foreign funds that consist of
investments in fixed income funds, target cash flow funds and
liquidity  funds.  Fixed  income  funds  invest  in  individual
securities quoted on a recognized stock exchange or traded in a
regulated market. Certain fixed income funds aim to produce
returns consistent with certain Financial Times Stock Exchange
indexes. Target cash flow funds are designed to provide a series
of fixed annual cash flows achieved by investing in government
bonds and derivatives. Liquidity funds place a high priority on
capital preservation, stable value and a high liquidity of assets.
Foreign funds are readily redeemable at NAV.

The  Firm  generally  considers  the  NAV  of  commingled  trust
funds and foreign funds provided by the fund manager to be the
best estimate of fair value.

Expected Contributions

The Firm’s policy is to fund at least the amount sufficient to
meet  minimum  funding  requirements  under  applicable
employee benefit and tax laws. At December 31, 2019, the Firm
expected to contribute approximately $50 million to its pension
and postretirement benefit plans in 2020 based upon the plans’
current funded status and expected asset return assumptions for
2020.

Expected Future Benefit Payments

$ in millions

Pension Plans

Other Postretirement
Plans

At December 31, 2019

2020

2021

2022

2023

2024

2025-2029

149

151

153

159

163

911

4

4

5

5

5

18

Morgan Stanley 401(k) Plan

$ in millions

Expense

2019

2018

2017

$

280 $

272 $

258

U.S.  employees  meeting  certain  eligibility  requirements  may
participate  in  the  Morgan  Stanley  401(k)  Plan.  Eligible
employees  receive  discretionary  401(k)  matching  cash
contributions  as  determined  annually  by  the  Firm.  For  2019,
2018 and 2017, the Firm matched employee contributions up to
4% of eligible pay, up to the IRS limit. Matching contributions
were  invested  among  available  funds  according  to  each
participant’s investment direction on file. Eligible employees
with eligible pay less than or equal to $100,000 also received a
fixed contribution under the 401(k) Plan equal to 2% of eligible
pay.  Transition  contributions  relating  to  acquired  entities  or
frozen employee benefit plans are allocated to certain eligible

141

December 2019 Form 10-K

Table of Contents
Notes to Consolidated Financial Statements

employees. The Firm match, fixed contribution and transition
contribution are included in the Firm’s 401(k) expense.

Non-U.S. Defined Contribution Pension Plans

Effective Income Tax Rate

Reconciliation of the U.S. Federal Statutory Income Tax Rate to
the Effective Income Tax Rate

$ in millions

Expense

2019

2018

2017

$

121 $

116 $

106

U.S. federal statutory income tax rate

21.0%

21.0%

35.0%

2019

2018

2017

The Firm maintains separate defined contribution pension plans
that cover eligible employees of certain non-U.S. subsidiaries.
Under such plans, benefits are generally determined based on a
fixed rate of base salary with certain vesting requirements.

20. Income Taxes 

Provision for (Benefit from) Income Taxes 

Components of Provision for (Benefit from) Income Taxes

$ in millions

Current

U.S.:

Federal

State and local

Non-U.S.:

U.K.

Japan

Hong Kong
Other1

Total

Deferred

U.S.:

Federal

State and local

Non-U.S.:

U.K.

Japan

Hong Kong
Other1

Total

Provision for income taxes from continuing 

operations

Provision for (benefit from) income taxes

from discontinued operations

2019

2018

2017

$

873 $

686 $

260

207

166

177

82

341

328

268

94

318

476

125

401

56

48

308

$ 1,899 $ 1,901 $ 1,414

$

185 $

330 $ 2,656

46

5

11

—

(82)

56

84

54

(10)

(3)

22

18

(17)

(2)

15

$

165 $

449 $ 2,754

$ 2,064 $ 2,350 $ 4,168

$

— $

(1) $

(7)  

1. Other Non-U.S. tax provisions for 2019, 2018 and 2017 primarily include Brazil,

India and Canada.

U.S. state and local income taxes, net of 

U.S. federal income tax benefits

Domestic tax credits

Tax exempt income

Non-U.S. earnings

Tax Act enactment

Employee share-based awards

Other

2.2

(1.5)

(0.1)

(0.8)

—

(1.1)

(1.4)

2.0

(0.9)

(0.4)

1.3

—

(1.5)

(0.6)

1.4

(1.6)

(0.1)

(5.0)

11.5

(1.5)

0.4

Effective income tax rate

18.3%

20.9%

40.1%

The  Firm’s  effective  tax  rates  for  2019  and  2018  include
intermittent net discrete tax benefits of $348 million and $203
million, respectively, primarily associated with remeasurement
of reserves and related interest as a result of new information
pertaining to multi-jurisdiction tax examinations.

The  Firm’s  effective  tax  rate  from  continuing  operations  for
2017 included an intermittent net discrete tax provision of $968
million, which included an approximate $1.2 billion provision
primarily related to the remeasurement of certain net deferred
tax assets as a result of the Tax Act, partially offset by $233
million of net discrete tax benefits primarily associated with the
remeasurement  of  reserves  and  related  interest  due  to  new
information  regarding  the  status  of  multi-year  IRS  tax
examinations.

The  Tax  Act,  enacted  on  December  22,  2017,  significantly
revised U.S. corporate income tax law by reducing the corporate
income  tax  rate  to  21%,  partially  or  wholly  eliminating  tax
deductions for certain expenses and implementing a modified
territorial  tax  system.  The  modified  territorial  tax  system
included  a  one-time  transition  tax  on  deemed  repatriated
earnings of non-U.S. subsidiaries and also imposes a minimum
tax on GILTI and an alternative BEAT on U.S. corporations with
operations outside the U.S.

December 2019 Form 10-K

142

Table of Contents
Notes to Consolidated Financial Statements

At
December 31,
2019

At
December 31,
2018

Deferred Tax Assets and Liabilities

$ in millions

Gross deferred tax assets

Net operating loss and tax credit

carryforwards

Employee compensation and benefit plans

Valuation and liability allowances

Valuation of inventory, investments and

receivables

Total deferred tax assets

Deferred tax assets valuation allowance

$

287 $

2,075

318

368

3,048

156

Deferred tax assets after valuation allowance $

2,892 $

Gross deferred tax liabilities

Fixed assets

Other

Total deferred tax liabilities

Net deferred tax assets

983

411

1,394 $

1,498 $

$

$

264

2,053

318

242

2,877

143

2,734

825

236

1,061

1,673

Deferred income taxes reflect the net tax effects of temporary
differences  between  the  financial  reporting  and  tax  bases  of
assets and liabilities and are measured using the enacted tax rates
and laws that will be in effect when such differences are expected
to reverse.

The Firm believes the recognized net deferred tax assets (after
valuation allowance) at December 31, 2019 are more likely than
not  to  be  realized  based  on  expectations  as  to  future  taxable
income in the jurisdictions in which it operates.

The  earnings  of  certain  foreign  subsidiaries  are  indefinitely
reinvested due to regulatory and other capital requirements in
foreign  jurisdictions.  As  a  result  of  the  Tax  Act’s  one-time
transition  tax  on  the  earnings  of  foreign  subsidiaries  and  an
annual minimum tax on GILTI, as of December 31, 2019 the
unrecognized deferred tax liability attributable to indefinitely
reinvested earnings is immaterial.

Unrecognized Tax Benefits

Rollforward of Unrecognized Tax Benefits

$ in millions

2019

2018

2017

Balance at beginning of period

$

1,080 $

1,594 $

1,851

Interest Expense (Benefit), Net of Federal and State Income Tax
Benefits

$ in millions

2019

2018

2017

Recognized in income statements

$

8 $

(40) $

Accrued at end of period

92

91

(3)

147

Interest and penalties related to unrecognized tax benefits are
recognized as a component of the provision for income taxes.
Penalties  related  to  unrecognized  tax  benefits  for  the  years
mentioned above were immaterial.

Tax Authority Examinations

The Firm is under continuous examination by the IRS and other
tax authorities in certain countries, such as Japan and the U.K.,
and in states and localities in which it has significant business
operations,  such  as  New  York.  The  Firm  has  established  a
liability for unrecognized tax benefits, and associated interest,
if  applicable  (“tax  liabilities”),  that  it  believes  is  adequate  in
relation  to  the  potential  for  additional  assessments.  Once
established, the Firm adjusts such tax liabilities only when new
information is available or when an event occurs necessitating
a change.

The  Firm  believes  that  the  resolution  of  the  above  tax
examinations  will  not  have  a  material  effect  on  the  annual
financial statements, although a resolution could have a material
impact in the income statements and on the effective tax rate for
any period in which such resolutions occur.

See Note 13 regarding the Dutch Tax Authority’s challenge, in
the District Court in Amsterdam (matters styled Case number
15/3637 and Case number 15/4353), of the Firm’s entitlement
to certain withholding tax credits, which may impact the balance
of unrecognized tax benefits.

It is reasonably possible that significant changes in the balance
of  unrecognized  tax  benefits  may  occur  within  the  next  12
months. At this time, however, it is not possible to reasonably
estimate  the  expected  change  to  the  total  amount  of
unrecognized tax benefits and the impact on the Firm’s effective
tax rate over the next 12 months.

Earliest  Tax  Year  Subject  to  Examination  in  Major  Tax
Jurisdictions

Increase based on tax positions related to

the current period

Increase based on tax positions related to

prior periods

Decrease based on tax positions related to

prior periods

Decreases related to settlements with taxing

authorities

Decreases related to lapse of statute of

limitations

Balance at end of period
Net unrecognized tax benefits1

57

61

83

34

63

170

Jurisdiction

U.S.

(419)

(404)

(312)

New York State and New York City

(17)

(139)

(155)

(7)

(88)

(23)

$

$

755 $

1,080 $

1,594

549 $

746 $

873

Hong Kong

U.K.

Japan

Tax Year

2013

2007

2013

2011

2015

1. Represent ending unrecognized tax benefits adjusted for the impact of the federal
benefit of state issues, competent authority arrangements and foreign tax credit offsets.
If recognized, these net benefits would favorably impact the effective tax rate in future
periods.

143

December 2019 Form 10-K

Table of Contents
Notes to Consolidated Financial Statements

21.  Segment,  Geographic 
Information 

and  Revenue

Segment Information 

The Firm structures its segments primarily based upon the nature
of the financial products and services provided to customers and
its management organization. The Firm provides a wide range
of financial products and services to its customers in each of the
business 
Securities,  Wealth
Institutional 
Management  and  Investment  Management.  For  a  further
discussion of the business segments, see Note 1.

segments: 

Revenues and expenses directly associated with each respective
business  segment  are  included  in  determining  its  operating
results.  Other  revenues  and  expenses  that  are  not  directly
attributable  to  a  particular  business  segment  are  generally
allocated  based  on  each  business  segment’s  respective  net
revenues, non-interest expenses or other relevant measures.

As  a  result  of  revenues  and  expenses  from  transactions  with
other  operating  segments  being  treated  as  transactions  with
external parties for purposes of segment disclosures, the Firm
includes an Intersegment Eliminations category to reconcile the
business segment results to the consolidated results.

Selected Financial Information by Business Segment

$ in millions

IS

WM

2019

IM

I/E

Total

Investment banking

$ 5,734 $

509 $

— $

(80) $ 6,163

Trading

Investments
Commissions and fees1
Asset management1

Other

10,318

734

(8)

325

2

1,213

51

—

2,484

1,726

1

(292)

11,095

1,540

3,919

413

632

10,199

2,629

(158)

13,083

345

(46)

(6)

925

Total non-interest revenues

19,906

13,515

3,789

(485)

36,725

Interest income

Interest expense

Net interest

Net revenues

Income from continuing

operations before income
taxes

12,193

11,713

480

5,467

1,245

4,222

20

46

(582)

17,098

(600)

12,404

(26)

18

4,694

$20,386 $17,737 $ 3,763 $ (467) $ 41,419

$ 5,490 $ 4,832 $

985 $

(6) $ 11,301

Provision for income taxes

769

1,104

193

(2)

2,064

Income from continuing

operations

Income (loss) from

discontinued operations,
net of income taxes

Net income

Net income applicable to
noncontrolling interests

Net income applicable to

Morgan Stanley

4,721

3,728

792

(4)

9,237

—

—

4,721

3,728

—

792

122

—

73

—

(4)

—

—

9,237

195

$ 4,599 $ 3,728 $

719 $

(4) $ 9,042

December 2019 Form 10-K

144

$ in millions

IS

WM

2018

IM

I/E

Total

Investment banking

$ 6,088 $

475 $

— $

(81) $ 6,482

Trading

Investments
Commissions and fees1
Asset management1

Other

11,191

182

279

1

2,671

1,804

25

254

—

56

—

11,551

437

(285)

4,190

421

535

10,158

2,468

(149)

12,898

248

(30)

(10)

743

Total non-interest revenues

21,088

12,965

2,717

(469)

36,301

Interest income

Interest expense

Net interest

Net revenues

Income from continuing

operations before income
taxes

9,271

9,777

5,498

1,221

(506)

4,277

57

28

29

(934)

13,892

(940)

10,086

6

3,806

$20,582 $17,242 $ 2,746 $ (463) $ 40,107

$ 6,260 $ 4,521 $

464 $

(8) $ 11,237

Provision for income taxes

1,230

1,049

73

(2)

2,350

Income from continuing

operations

Income (loss) from

discontinued operations,
net of income taxes

Net income

Net income applicable to
noncontrolling interests

Net income applicable to

Morgan Stanley

5,030

3,472

391

(6)

8,887

(6)

—

5,024

3,472

2

393

118

—

17

—

(6)

—

(4)

8,883

135

$ 4,906 $ 3,472 $

376 $

(6) $ 8,748

$ in millions

IS

WM

2017

IM

I/E

Total

Investment banking

$ 5,537 $

533 $

— $

(67) $ 6,003

Trading

Investments

Commissions and fees

Asset management

Other

10,295

368

2,433

359

630

848

3

1,737

9,342

268

(22)

449

—

(5)

11,116

—

820

(109)

4,061

2,196

(100)

11,797

(37)

(13)

848

Total non-interest revenues

19,622

12,731

2,586

(294)

34,645

Interest income

Interest expense

Net interest

Net revenues

Income from continuing

operations before income
taxes

5,377

6,186

4,591

486

(809)

4,105

4

4

—

(975)

(979)

4

8,997

5,697

3,300

$18,813 $16,836 $ 2,586 $ (290) $ 37,945

$ 5,644 $ 4,299 $

456 $

4 $ 10,403

Provision for income taxes

1,993

1,974

201

Income from continuing

operations

Income (loss) from

discontinued operations,
net of income taxes

Net income

Net income applicable to
noncontrolling interests

Net income applicable to

Morgan Stanley

3,651

2,325

255

(19)

—

3,632

2,325

—

255

96

—

9

—

4

—

4

—

4,168

6,235

(19)

6,216

105

$ 3,536 $ 2,325 $

246 $

4 $ 6,111

I/E–Intersegment Eliminations 
1. Substantially  all  of  the  of  revenues  for  these  line  items  are  recognized  under  the

Revenues from Contracts with Customers accounting update.

Table of Contents
Notes to Consolidated Financial Statements

Detail of Investment Banking Revenues

Certain Other Fee Waivers

$ in millions

2019

2018

2017

Institutional Securities—Advisory

$ 2,116

$ 2,436

$

2,077

Institutional Securities—Underwriting

3,618

3,652

3,460

Firm Investment banking revenues from

contracts with customers1

90%

86%

N/A

1. Represents the approximate amount of Investment banking revenues accounted for

under this accounting update.

Trading Revenues by Product Type

Separately, the Firm’s employees, including its senior officers,
may  participate  on  the  same  terms  and  conditions  as  other
investors in certain funds that the Firm sponsors primarily for
client investment, and the Firm may waive or lower applicable
fees and charges for its employees.

Income  from  Continuing  Operations  before  Income  Tax
Expense (Benefit)

$ in millions

Interest rate

Foreign exchange
Equity security and index1

Commodity and other

Credit

Total

2019

2018

2017

$

2,773 $

2,696 $

2,091

395

5,246

1,438

1,243

914

6,157

1,174

647

6,291

740

610

1,347

$ in millions

U.S.
Non-U.S.1

Total

2019

2018

2017

$

9,464 $

7,804 $

5,686

1,837

3,433

4,717

$ 11,301 $ 11,237 $ 10,403

1. Non-U.S. income is defined as income generated from operations located outside the

U.S.

$ 11,095 $ 11,551 $ 11,116

Net Discrete Tax Provisions (Benefits) by Segment

1. Dividend income is included within equity security and index contracts.

The  previous  table  summarizes  gains  and  losses  included  in
Trading  revenues  in  the  income  statements.  These  activities
include  revenues  related  to  derivative  and  non-derivative
financial  instruments.  The  Firm  generally  utilizes  financial
instruments across a variety of product types in connection with
its market-making and related risk management strategies. The
trading revenues presented in the table are not representative of
the manner in which the Firm manages its business activities
and  are  prepared  in  a  manner  similar  to  the  presentation  of
trading revenues for regulatory reporting purposes.

Investment Management Investments Revenues—Net
Cumulative Unrealized Carried Interest

$ in millions

At
December 31, 
 2019

At
December 31, 
 2018

Net cumulative unrealized performance-

based fees at risk of reversing

$

774 $

434

The Firm’s portion of net cumulative unrealized performance-
based fees in the form of carried interest (for which the Firm is
not obligated to pay compensation) are at risk of reversing when
the  return  in  certain  funds  falls  below  specified  performance
targets. See Note 13 for information regarding general partner
guarantees,  which  include  potential  obligations  to  return
performance fee distributions previously received.

Investment  Management  Asset  Management  Revenues—
Reduction of Fees Due to Fee Waivers

$ in millions

Fee waivers

2019

2018

2017

$

43 $

56 $

86

The  Firm  waives  a  portion  of  its  fees  in  the  Investment
Management business segment from certain registered money
market funds that comply with the requirements of Rule 2a-7
of the Investment Company Act of 1940.

$ in millions

2019

Intermittent net discrete tax provision

(benefit)

Recurring:

IS

WM

IM

Total

$ (317) $

(13) $

(18) $ (348)

Employee share-based awards1

(83)

(37)

(7)

(127)

Total

2018

Intermittent net discrete tax provision

(benefit)

Recurring:

$ (400) $

(50) $

(25) $ (475)

$ (182) $ — $

(21) $ (203)

Employee share-based awards1

(104)

(50)

(11)

(165)

Total

2017

Intermittent:

Tax Act enactment2

Remeasurement of reserves and

related interest

Other

Total intermittent net discrete tax

provision (benefit)

Recurring:

$ (286) $

(50) $

(32) $ (368)

$

705 $

402 $

94 $ 1,201

(168)

(66)

—

9

—

(8)

(168)

(65)

$

471 $

411 $

86 $

968

Employee share-based awards1

(93)

(54)

(8)

(155)

Total

$

378 $

357 $

78 $

813

1. We consider these employee share-based award related provisions (benefits) to be
recurring-type  (“Recurring”)  discrete  tax  items,  as  we  anticipate  some  level  of
conversion activity each year. 

2. For further discussion on the Tax Act, see Note 20.

Net Revenues by Region

$ in millions

Americas

EMEA

Asia

Total

2019

2018

2017

$ 30,226 $ 29,301 $ 27,817

6,061

5,132

6,092

4,714

5,714

4,414

$ 41,419 $ 40,107 $ 37,945

The  Firm  operates  in  both  U.S.  and  non-U.S.  markets.  The
Firm’s non-U.S. business activities are principally conducted
and  managed  through  EMEA  and  Asia  locations.  The  net
revenues  disclosed  in  the  following  table  reflect  the  regional

145

December 2019 Form 10-K

Table of Contents
Notes to Consolidated Financial Statements

view  of  the  Firm’s  consolidated  net  revenues  on  a  managed
basis, based on the following methodology:

22. Parent Company 

Parent  Company  Only—Condensed  Income  Statements  and
Comprehensive Income Statements

$ in millions

Revenues
Dividends from subsidiaries1

Trading

Other

Total non-interest revenues

Interest income

Interest expense

Net interest

Net revenues

Non-interest expenses

Income before income taxes

2019

2018

2017

$

5,529 $

4,973 $

2,567

(54)

80

5,555

5,121

4,661

460

54

(5)

5,022

5,172

4,816

356

(260)

64

2,371

3,783

4,079

(296)

6,015

5,378

2,075

300

225

240

5,715

5,153

1,835

Provision for (benefit from) income taxes

(73)

22

(206)

Net income before undistributed gain 

of subsidiaries

Undistributed gain of subsidiaries

Net income

Other comprehensive income (loss), net of

tax:

5,788

3,254

9,042

5,131

3,617

8,748

2,041

4,070

6,111

Foreign currency translation adjustments

(8)

(114)

219

Change in net unrealized gains (losses) 

on available-for-sale securities

Pensions, postretirement and other

1,137

(66)

(272)

137

Change in net debt valuation adjustment

(1,559)

1,454

41

(117)

(560)

Comprehensive income

Net income

$

$

8,546 $

9,953 $

5,694

9,042 $

8,748 $

6,111

Preferred stock dividends and other

530

526

523

Earnings applicable to Morgan Stanley

common shareholders

$

8,512 $

8,222 $

5,588

1. In  2019  and  2018,  the  Parent  Company  recorded  approximately  $4  billion  and  $3

billion, respectively, of dividends from bank subsidiaries.

Institutional Securities: client location for advisory and equity
underwriting, revenue recording location for debt underwriting,
trading desk location for sales and trading.

Wealth Management: representatives operate in the Americas.

Investment Management: client location, except certain closed-
end funds, which are based on asset location.

Revenue Recognized from Prior Services

$ in millions

Non-interest revenues

2019

2018

$

2,705 $

2,821

The  previous  table  includes  revenue  from  contracts  with
customers  recognized  where  some  or  all  services  were
performed  in  prior  periods  and  is  primarily  composed  of
investment banking advisory fees and distribution fees.

Receivables from Contracts with Customers

$ in millions

At
December 31, 
 2019

At
December 31, 
 2018

Customer and other receivables

$

2,916 $

2,308

Receivables from contracts with customers, which are included
within Customer and other receivables in the balance sheets,
arise when the Firm has both recorded revenues and has the right
per the contract to bill the customer.

Assets by Business Segment

$ in millions

Institutional Securities

Wealth Management

Investment Management

Total1

At
December 31, 
 2019

At
December 31, 
 2018

$

$

691,201 $

646,427

197,682

6,546

202,392

4,712

895,429 $

853,531

1. Parent assets have been fully allocated to the business segments.

Total Assets by Region

$ in millions

Americas

EMEA

Asia

Total

At
December 31, 
 2019

At
December 31, 
 2018

$

$

622,979 $

185,093

87,357

576,532

200,194

76,805

895,429 $

853,531

December 2019 Form 10-K

146

 
 
Table of Contents
Notes to Consolidated Financial Statements

Parent Company Only—Condensed Balance Sheets

Parent Company Only—Condensed Cash Flow Statements

$ in millions, except share data

Assets

Cash and cash equivalents:

Cash and due from banks

Deposits with bank subsidiaries

Trading assets at fair value

Investment securities (includes $19,824 and
$15,500 at fair value and $4,606 and $—
were pledged to various parties)

Securities purchased under agreement to 

resell with affiliates

Advances to subsidiaries:

Bank and BHC

Non-bank

Equity investments in subsidiaries:

Bank and BHC

Non-bank

Other assets

Total assets

Liabilities

Trading liabilities at fair value

Securities sold under agreements to

repurchase with affiliates

Payables to and advances from subsidiaries

Other liabilities and accrued expenses

Borrowings (includes $20,461 and $18,599

at fair value)

Total liabilities

Equity

Preferred stock

Common stock, $0.01 par value:

Shares authorized: 3,500,000,000; Shares

issued: 2,038,893,979; Shares outstanding:
1,593,973,680 and 1,699,828,943

Additional paid-in capital

Retained earnings

Employee stock trusts

Accumulated other comprehensive income

(loss)

Common stock held in treasury at cost,
$0.01 par value (444,920,299 and
339,065,036 shares)

Common stock issued to employee stock 

trusts

Total shareholders’ equity

Total liabilities and equity

Commitments and contingent liabilities (see Note 13)

At
December 31,
2019

At
December 31,
2018

$ in millions

2019

2018

2017

Net cash provided by (used for) operating 

activities

$ 24,175 $ (1,136) $ 3,747

Cash flows from investing activities

Proceeds from (payments for):

$

9 $

8,001

5,747

6

7,476

10,039

Investment securities:

Purchases

Proceeds from sales

37,253

22,588

10,114

25,535

27,667

104,345

36,093

43,667

244

30,954

97,405

42,848

32,418

1,244

273,140 $

270,513

1,130 $

4,631

35,470

2,153

148,207

191,591

276

—

30,861

2,548

156,582

190,267

$

$

8,520

8,520

20

23,935

70,589

2,918

20

23,794

64,175

2,836

Proceeds from paydowns and maturities

Securities purchased under agreements to 

resell with affiliates

Securities sold under agreements to 

repurchase with affiliates

Advances to and investments in subsidiaries

Net cash provided by (used for) investing 

activities

Cash flows from financing activities

Proceeds from:

Issuance of preferred stock, net of issuance 

costs

Issuance of Borrowings

Payments for:

Borrowings

Repurchases of common stock and 

employee tax withholdings

Cash dividends

(22,408)

(8,155)

(5,263)

4,671

3,157

1,252

3,729

3,620

1,038

15,422

13,057

19,314

4,631

(8,753)

8,753

(9,210)

11,841

(35,686)

(3,737)

12,971

(8,224)

497

—

994

8,337

14,918

36,833

(24,282)

(21,418)

(24,668)

(5,954)

(5,566)

(4,292)

(2,627)

(2,375)

(2,085)

Net change in advances from subsidiaries

4,378

2,122

1,861

Other financing activities

12

—

26

Net cash provided by (used for) financing 

activities

Effect of exchange rate changes on cash and

cash equivalents

Net increase (decrease) in cash and cash 

equivalents

Cash and cash equivalents, at beginning of 

period

Cash and cash equivalents, at end of 

period

Cash and cash equivalents:

Cash and due from banks

Deposits with bank subsidiaries

Restricted cash

Cash and cash equivalents, at end of 

(19,639)

(12,319)

8,669

(271)

(166)

221

528

(650)

4,413

7,482

8,132

3,719

$ 8,010 $ 7,482 $ 8,132

$

9 $

6 $

11

8,001

7,476

8,120

—

—

1

$ 8,010 $ 7,482 $ 8,132

(2,788)

(2,292)

period

(18,727)

(13,971)

(2,918)

81,549

(2,836)

80,246

$

273,140 $

270,513

Supplemental Disclosure of Cash Flow Information

Cash payments for:

Interest
Income taxes, net of refunds1

$ 4,677 $ 4,798 $ 3,570

1,186

437

201

1.Represents total payments, net of refunds, made to various tax authorities and includes
taxes paid on behalf of certain subsidiaries that are subsequently settled between the
Parent Company and these subsidiaries. The settlements received from subsidiaries
were $1.6 billion, $1.6 billion and $1.5 billion for 2019, 2018 and 2017, respectively.

On  November  25,  2019,  the  Parent  Company  issued  $500
million of Series L Preferred Stock and on January 15, 2020,
the Parent Company redeemed in whole its outstanding Series
G Preferred Stock. For further information on preferred stock,
see Note 16.

147

December 2019 Form 10-K

 
Table of Contents
Notes to Consolidated Financial Statements

Parent Company’s Borrowings with Original Maturities
Greater than One Year

Guarantees  of  Debt  Instruments  and  Warrants  Issued  by
Subsidiaries

$ in millions

Senior

Subordinated

Total

At
December 31,
2019

At
December 31,
2018

$ in millions

137,138 $

146,492

Aggregate balance

10,570

10,090

$

$

147,708 $

156,582

Guarantees under Subsidiary Lease Obligations

At
December 31,
2019

At
December 31,
2018

$

32,996 $

24,286

Transactions with Subsidiaries

The  Parent  Company  has  transactions  with  its  consolidated
subsidiaries  determined  on  an  agreed-upon  basis  and  has
guaranteed  certain  unsecured  lines  of  credit  and  contractual
obligations on certain of its consolidated subsidiaries.

$ in millions
Aggregate balance1

1. Amounts primarily relate to the U.K. 

Finance Subsidiary

At
December 31,
2019

At
December 31,
2018

$

925 $

1,003

The Parent Company fully and unconditionally guarantees the
securities  issued  by  Morgan  Stanley  Finance  LLC,  a  wholly
owned finance subsidiary.

Resolution and Recovery Planning

As indicated in the Firm’s 2019 resolution plan submitted to the
Federal  Reserve  and  the  FDIC,  the  Parent  Company  has
amended and restated its support agreement with its material
entities (including its wholly owned, direct subsidiary Morgan
Stanley Holdings LLC (the “Funding IHC”) and certain other
subsidiaries,  as  defined  in  the  Firm’s  2019  resolution  plan.
Under the secured amended and restated support agreement, in
the event of a resolution scenario, the Parent Company would
be obligated to contribute all of its material assets that can be
contributed under the terms of the amended and restated support
agreement  (other  than  shares  in  subsidiaries  of  the  Parent
Company and certain other assets) (“Contributable Assets”), to
the material entities and/or the Funding IHC. The Funding IHC
would  be  obligated   to  provide  capital  and  liquidity,  as
applicable, to the material entities.

Guarantees

In  the  normal  course  of  its  business,  the  Parent  Company
guarantees  certain  of  its  subsidiaries’  obligations  under
derivative  and  other  financial  arrangements.  The  Parent
Company records Trading assets and Trading liabilities, which
include  derivative  contracts,  at  fair  value  in  its  condensed
balance sheets.

The Parent Company also, in the normal course of its business,
provides standard indemnities to counterparties on behalf of its
subsidiaries for taxes, including U.S. and foreign withholding
taxes,  on  interest  and  other  payments  made  on  derivatives,
securities  and  stock  lending  transactions,  and  certain  annuity
products. These indemnity payments could be required based
on  a  change  in  the  tax  laws  or  change  in  interpretation  of
applicable tax rulings. Certain contracts contain provisions that
enable the Parent Company to terminate the agreement upon the
occurrence of such events. The maximum potential amount of
future payments that the Parent Company could be required to
make  under  these  indemnifications  cannot  be  estimated. The
Parent Company has not recorded any contingent liability in its
condensed financial statements for these indemnifications and
believes that the occurrence of any events that would trigger
payments under these contracts is remote.

The  Parent  Company  has  issued  guarantees  on  behalf  of  its
subsidiaries  to  various  U.S.  and  non-U.S.  exchanges  and
clearinghouses  that  trade  and  clear  securities  and/or  futures
contracts.  Under  these  guarantee  arrangements,  the  Parent
Company may be required to pay the financial obligations of its
subsidiaries  related  to  business  transacted  on  or  with  the
exchanges  and  clearinghouses  in  the  event  of  a  subsidiary’s
default on its obligations to the exchange or the clearinghouse.
The Parent Company has not recorded any contingent liability
in its condensed financial statements for these arrangements and
believes  that  any  potential  requirements  to  make  payments
under these arrangements are remote.

December 2019 Form 10-K

148

Table of Contents
Notes to Consolidated Financial Statements

23. Quarterly Results (Unaudited) 

$ in millions, except per share data

First

Second

Third

Fourth1, 2, 3

$ in millions, except per share data

First

Second

Third

Fourth1, 2

Total non-interest revenues

$ 9,272 $ 9,215 $ 8,814 $

9,424

Total non-interest revenues

$10,102 $ 9,704 $ 8,936 $

7,559

2019 Quarter

2018 Quarter

Net interest

Net revenues

1,014

1,029

1,218

1,433

10,286

10,244

10,032

10,857

Net interest

Net revenues

Total non-interest expenses

7,331

7,341

7,322

8,124

Total non-interest expenses

Income from continuing operations

before income taxes

Provision for income taxes

Income from continuing operations

Net income

Net income applicable to
noncontrolling interests

Net income applicable to Morgan

Stanley

2,955

2,903

2,710

487

2,468

2,468

657

2,246

2,246

492

2,218

2,218

2,733

428

2,305

2,305

39

45

45

66

$ 2,429 $ 2,201 $ 2,173 $

2,239

Preferred stock dividends and other

93

170

113

154

975

906

11,077

10,610

7,657

7,501

936

9,872

7,021

3,420

3,109

2,851

714

640

696

989

8,548

6,691

1,857

300

1,557

Income from continuing operations

before income taxes

Provision for income taxes

Income from continuing operations

2,706

2,469

2,155

Income (loss) from discontinued

operations

Net income

Net income applicable to
noncontrolling interests

Net income applicable to Morgan

Stanley

(2)

(2)

(1)

1

2,704

2,467

2,154

1,558

36

30

42

27

$ 2,668 $ 2,437 $ 2,112 $

1,531

Earnings applicable to Morgan

Stanley common shareholders

$ 2,336 $ 2,031 $ 2,060 $

2,085

Preferred stock dividends

93

170

93

170

Earnings (loss) per basic common share4:

Income from continuing operations

$

1.41 $

1.24 $

1.28 $

Earnings per basic common share
Earnings (loss) per diluted common share4:

$

1.41 $

1.24 $

1.28 $

Income from continuing operations

$

1.39 $

1.23 $

1.27 $

Earnings per diluted common share $

1.39 $

1.23 $

1.27 $

1.33

1.33

1.30

1.30

Dividends declared per common

share

$

0.30 $

0.30 $

0.35 $

0.35

Book value per common share

$ 42.83 $ 44.13 $ 45.49 $

45.82

Earnings applicable to Morgan

Stanley common shareholders

$ 2,575 $ 2,267 $ 2,019 $

1,361

Earnings (loss) per basic common share4:

Income from continuing operations

$

1.48 $

1.32 $

1.19 $

0.81

Income (loss) from discontinued

operations

—

—

—

—

Earnings per basic common share
Earnings (loss) per diluted common share4:

$

1.48 $

1.32 $

1.19 $

0.81

Income from continuing operations

$

1.46 $

1.30 $

1.17 $

0.80

Income (loss) from discontinued

operations

Earnings per diluted common share

Dividends declared per common

share

$

$

(0.01)

—

—

—

1.45 $

1.30 $

1.17 $

0.80

0.25 $

0.25 $

0.30 $

0.30

Book value per common share

$ 39.19 $ 40.34 $ 40.67 $

42.20

1. The fourth quarters of 2019 and 2018 included intermittent net discrete tax benefits
of $158 million and $111 million, respectively, primarily associated with remeasurement
of  reserves  and  related  interest  as  a  result  of  new  information  pertaining  to  the
resolution of multi-jurisdiction tax examinations.

2. Total  non-interest  revenues  includes  impairments  of  the  Investment  Management
business segment’s interests in two distinct equity method investments in third-party
asset managers of $41 million in 2019 and $46 million in 2018.

3. The fourth quarter of 2019 included specific severance-related costs of approximately
$172 million, which are included in Compensation and benefits expenses in the Income
statement. These costs were recorded in the business segments approximately as
follows:  Institutional  Securities  $124  million,  Wealth  Management  $37  million  and
Investment Management $11 million. 

4. The  sum  of  the  quarters’  earnings  per  common  share  may  not  equal  the  annual
amounts due to the averaging effect of the number of shares and share equivalents
throughout the year.

149

December 2019 Form 10-K

 
 
Table of Contents
Notes to Consolidated Financial Statements

24. Subsequent Event

On  February  20,  2020,  the  Firm  entered  into  a  definitive
agreement  under  which  it  will  acquire  E*TRADE  Financial
Corporation (“E*TRADE”) in an all-stock transaction currently
valued at approximately $13 billion, based on the closing price
of the Firm’s common stock and the number of E*TRADE's
fully diluted shares outstanding on February 19, 2020. Under
the terms of the agreement, E*TRADE common stockholders
will receive 1.0432 Morgan Stanley common shares for each
E*TRADE  common  share.  The  acquisition  is  subject  to
customary closing conditions, including regulatory approvals
and  approval  by  E*TRADE  shareholders,  and  is  expected  to
close in the fourth quarter of 2020.

December 2019 Form 10-K

150

Table of Contents
Financial Data Supplement (Unaudited)

Average Balances and Interest Rates and Net Interest Income

Effect of Volume and Rate Changes on Net Interest Income

2019

2018

$ in millions

Average
Daily
Balance

Interest

Average
Rate

Average
Daily
Balance

Interest

Average
Rate

Interest earning assets

Investment
securities1

$ 101,696 $ 2,175

2.1% $ 81,977 $ 1,744

2.1%

Loans1
Securities purchased under agreements to resell and Securities borrowed2:

109,681

121,002

4,249

4,783

4.0

3.9

$ in millions

Interest earning assets

Investment
securities1

Loans1

2019 versus 2018

Increase (Decrease)
Due to Change in:
Rate

Volume

Net Change

$

420 $

439

11 $

95

431

534

Securities purchased under agreements to resell and Securities borrowed2:

U.S.

142,089

3,378

Non-U.S.

76,577

107

Trading assets, net of Trading liabilities3:

U.S.

77,481

2,531

Non-U.S.

14,654

368

Customer receivables and Other4:

U.S.

Non-U.S.

61,501

58,601

2,697

1,059

2.4

0.1

3.3

2.5

4.4

1.8

134,223

2,262

1.7

86,430

(286)

(0.3)

U.S.

Non-U.S.

57,780

2,144

9,014

248

73,695

2,592

54,396

939

3.7

2.8

3.5

1.7

Trading assets, net of Trading liabilities3:

U.S.

Non-U.S.

Customer receivables and Other4:

U.S.

Non-U.S.

133

33

731

155

(429)

73

983

360

(344)

(35)

534

47

1,116

393

387

120

105

120

Total

$ 653,601 $17,098

2.6% $607,196 $13,892

2.3%

Change in interest income

$

1,555 $

1,651 $

3,206

Interest bearing liabilities
Deposits1
Borrowings1, 5
Securities sold under agreements to repurchase and Securities loaned6:

1.0% $169,226 $ 1,255

$ 180,116 $ 1,885

191,692

192,770

5,031

5,052

2.6

U.S.

32,437

1,916

Non-U.S.

31,808

693

Customer payables and Other7:

U.S.

Non-U.S.

118,775

65,196

1,792

1,066

5.9

2.2

1.5

1.6

24,426

1,408

37,319

490

120,228

1,061

70,855

841

0.7%

2.6

5.8

1.3

0.9

1.2

Interest bearing liabilities
Deposits1
Borrowings1, 5
Securities sold under agreements to repurchase and Securities loaned6:

549 $

81 $

(7)

28

$

U.S.

Non-U.S.

Customer payables and Other7:

U.S.

Non-U.S.

462

(72)

(13)

(67)

46

275

744

292

630

21

508

203

731

225

Total

$ 621,102 $12,404

2.0% $613,746 $10,086

1.6%

Change in interest expense

Net interest income and

net interest rate spread $ 4,694

0.6%

$ 3,806

0.7% 

Change in net interest income

$

$

419 $

1,899 $

2,318

1,136 $

(248) $

888

151

December 2019 Form 10-K

 
Table of Contents
Financial Data Supplement (Unaudited)

Average Balances and Interest Rates and Net Interest Income

Effect of Volume and Rate Changes on Net Interest Income

$ in millions

2017

Average
Daily
Balance

Interest

Average
Rate

$ in millions

2018 versus 2017

Increase (Decrease)
Due to Change in:
Rate

Volume

Net Change

Interest earning assets
Investment securities1
Loans1
Securities purchased under agreements to resell and Securities borrowed2:

$ 76,746 $

98,727

1,334

3,298

1.7%

3.3

Interest earning assets
Investment securities1
Loans1
Securities purchased under agreements to resell and Securities borrowed2:

319 $

91 $

585

366

$

410

951

U.S.

Non-U.S.

125,453

95,478

606

(437)

0.5

(0.5)

U.S.

Non-U.S.

Trading assets, net of Trading liabilities3:

Trading assets, net of Trading liabilities3:

U.S.

Non-U.S.

Customer receivables and Other4:

U.S.

Non-U.S.

Total

59,335

4,326

72,440

40,179

1,876

153

1,614

553

3.2

3.5

2.2

1.4

U.S.

Non-U.S.

Customer receivables and Other4:

U.S.

Non-U.S.

42

41

(49)

166

28

196

1,614

110

1,656

151

317

(71)

950

190

268

95

978

386

$ 572,684 $

8,997

1.6%

Change in interest income

$

881 $

4,014 $

4,895

Interest bearing liabilities
Deposits1
Borrowings1, 5
Securities sold under agreements to repurchase and Securities loaned6:

$ 151,442 $

184,453

4,285

187

U.S.

Non-U.S.

Customer payables and Other7:

U.S.

Non-U.S.

Total

30,866

39,396

128,274

65,496

900

337

(213)

201

$ 599,927 $

5,697

Net interest income and net interest rate spread

$

3,300

0.1%

2.3

2.9

0.9

(0.2)

0.3

0.9%

0.7%

Interest bearing liabilities
Deposits1
Borrowings1,5
Securities sold under agreements to repurchase and Securities loaned6:

1,046 $

22 $

578

168

$

U.S.

Non-U.S.

Customer payables and Other7:

U.S.

Non-U.S.

(188)

(18)

13

16

696

171

1,261

624

Change in interest expense

Change in net interest income

$

$

13 $

4,376 $

868 $

(362) $

1,068

746

508

153

1,274

640

4,389

506

1. Amounts include primarily U.S. balances.
2. Includes fees paid on Securities borrowed.
3. Excludes  non-interest  earning  assets  and  non-interest  bearing  liabilities,  such  as

equity securities.

4. Includes Cash and cash equivalents.
5. Includes structured notes, whose interest expense is considered part of its value and

therefore is recorded within Trading revenues.

6. Includes  fees  received  on  Securities  loaned.  The  annualized  average  rate  was
calculated using (a) interest expense incurred on all securities sold under agreements
to repurchase and securities loaned transactions, whether or not such transactions
were reported in the balance sheets and (b) net average on-balance sheet balances,
which exclude certain securities-for-securities transactions.

7. Includes fees received from prime brokerage customers for stock loan transactions

entered into to cover customers’ short positions.

Deposits

$ in
millions
Deposits1:
Savings

Time

Total

Average Daily Deposits

2019

2018

2017

Average
Amount

Average
Rate

Average
Amount

Average
Rate

Average
Amount

Average
Rate

$144,017

0.6% $142,753

0.4% $144,870

36,099

2.8% 26,473

2.4%

6,572

$180,116

1.0% $169,226

0.7% $151,442

0.1%

1.6%

0.1%

1. The Firm’s deposits were primarily held in U.S. offices.

December 2019 Form 10-K

152

Table of Contents
Financial Data Supplement (Unaudited)

Ratios 

Net income to average total assets
ROE1
Return on total equity2
Dividend payout ratio3
Total average common equity to average total assets

Total average equity to average total assets

11.7% 11.8% 8.0%

11.1% 11.1% 7.8%

25.0% 23.3% 29.3%

8.2% 8.1% 8.2%

9.2% 9.1% 9.2%

1. ROE represents Earnings applicable to Morgan Stanley common shareholders as a

percentage of average common equity.

2. Return  on  total  equity  represents  Net  income  applicable  to  Morgan  Stanley  as  a

percentage of average total equity.

3. Dividend  payout  ratio  represents  dividends  declared  per  common  share  as  a

percentage of earnings per diluted common share.

Securities  Sold  under  Agreements  to  Repurchase  and
Securities Loaned

$ in millions

Period-end balance
Average balance1

2019

2018

2017

$62,706

$61,667

$70,016

64,245

61,745

70,262

Maximum balance at any month-end

78,327

72,161

77,063

Weighted average interest rate during the 

period2

Weighted average interest rate on 

period-end balance2

4.1%

3.1%

1.8%

4.0%

4.1%

1.5%

1. The Firm calculated its average balances based upon daily amounts.
2. The weighted average interest rate was calculated using (a) interest expense incurred
on  all  securities  sold  under  agreements  to  repurchase  and  securities  loaned
transactions, whether or not such transactions were reported in the balance sheets
and (b) net average or period-end balances excluding certain securities-for-securities
transactions.

Cross-Border Outstandings

At December 31, 2019

$ in millions

Banks Governments

Japan

U.K.

Cayman
Islands

France

Canada

Ireland

European 

Central Bank

China

Brazil

Luxembourg

Australia

Netherlands

Germany

18,282

6,021

12

4,454

6,794

274

—

1,451

2,765

82

2,265

2,149

1,210

7,146

11,515

—

1,927

1,205

126

11,464

168

2,116

27

2,366

107

838

Non-banking
Financial
Institutions

Other

Total

20,376

11,565 $ 57,369

15,623

10,431

43,590

24,693

5,987

30,692

9,447

2,606

9,161

—

1,320

1,287

7,596

2,481

2,163

2,444

6,363

22,191

4,163

14,768

4,410

13,971

— 11,464

7,907

10,846

4,509

10,677

1,947

2,486

4,788

4,471

9,652

9,598

9,207

8,963

2019

2018

2017

1.0% 1.0% 0.7%

$ in millions

Banks Governments

Non-banking
Financial
Institutions

Other

Total

December 31, 2018

Japan

U.K.

Cayman
Islands

France

Canada

Ireland

European 

Central Bank

Brazil

Germany

Luxembourg

$16,130 $

14,974 $

30,301 $ 9,951 $ 71,356

3,978

14

3,750

6,808

664

—

2,464

822

101

7,683

20,168

11,083

42,912

—

1,420

2,153

24

12,008

5,074

1,499

291

28,164

5,342

33,520

17,343

6,584

29,097

2,005

8,466

—

579

4,137

7,139

2,455

13,421

4,191

13,345

— 12,008

2,133

10,250

3,022

1,289

9,480

8,820

$ in millions

Banks Governments

Non-banking
Financial
Institutions

Other

Total

December 31, 2017

Japan

U.K.

France

Cayman 
Islands

Ireland

Germany

Canada

Brazil

China

Republic of

Korea

Netherlands

$12,239 $

18,103 $

18,125 $ 10,874 $ 59,341

4,870

3,401

17

391

1,045

4,225

2,761

902

447

313

6,741

900

1

52

1,191

621

3,470

1,713

2,871

982

24,731

13,992

50,334

12,781

8,445

25,527

16,041

4,999

21,058

8,577

6,286

3,072

315

940

1,020

2,446

4,601

13,621

3,765

12,287

3,695

11,613

3,809

10,355

5,852

9,407

4,922

4,377

9,260

8,118

Cross-border outstandings are based upon the FFIEC regulatory
guidelines for reporting cross-border information and represent
the amounts that we may not be able to obtain from a foreign
country due to country-specific events, including unfavorable
economic  and  political  conditions,  economic  and  social
instability, and changes in government policies. Claims include
cash, customer and other receivables, securities purchased under
agreements  to  resell,  securities  borrowed  and  cash  trading
instruments,  but  exclude  commitments.  Securities  purchased
under agreements to resell and securities borrowed are presented
based on the domicile of the counterparty, without reduction for
related securities collateral held. For information on the Firm’s
country  risk  exposure,  see  “Quantitative  and  Qualitative
Disclosures about Risk—Country and Other Risks.”

There can be substantial differences between our cross-border
risk exposure and our country risk exposure. For instance, unlike
the country risk exposure, our cross-border risk exposure does
not include the effect of certain risk mitigants. In addition, the
basis  for  determining  the  domicile  of  the  cross-border  risk
exposure is different from the basis for determining the country
risk exposure. Cross-border risk exposure is reported based on
the  country  of  jurisdiction  for  the  obligor  or  guarantor.  For
country risk exposure, we consider factors in addition to that of

153

December 2019 Form 10-K

Table of Contents
Financial Data Supplement (Unaudited)

country of jurisdiction, including physical location of operations
or  assets,  location  and  source  of  cash  flows  or  revenues  and
location of collateral (if applicable) in order to determine the
basis for country risk exposure. Furthermore, cross-border risk
exposure incorporates CDS only where protection is purchased,
while country risk exposure incorporates CDS where protection
is purchased or sold.

The  cross-border  outstandings  tables  set  forth  cross-border
outstandings for each country, excluding derivative exposure,
in  which  cross-border  outstandings  exceed  1%  of  the  Firm’s
consolidated assets or 20% of the Firm’s total capital, whichever
is less, in accordance with the FFIEC guidelines.

$ in millions

At December 31, 2019

Switzerland, Republic of Korea and Taiwan

At December 31, 2018

Netherlands

At December 31, 2017

Australia, European Central Bank, Luxembourg and India

Cross-
Border Exposure1

$

$

$

21,947

7,338

29,257

1. Cross-border exposure, including derivative contracts, that exceeds 0.75% but

does not exceed 1% of the Firm’s consolidated assets.

December 2019 Form 10-K

154

Table of Contents
Glossary of Common Terms and Acronyms

2018 Form 10-K Annual report on Form 10-K for year
2018 Form 10-K Annual report on Form 10-K for year

ended December 31, 2018 filed with the
ended December 31, 2018 filed with the
SEC
SEC

2019 Form 10-K Annual report on Form 10-K for year
2019 Form 10-K Annual report on Form 10-K for year

ended December 31, 2019 filed with the
ended December 31, 2019 filed with the
SEC
SEC

ABS
ABS

AFS
AFS

AML
AML

AOCI
AOCI

Asset-backed securities
Asset-backed securities

Available-for-sale
Available-for-sale

Anti-money laundering
Anti-money laundering

Accumulated other comprehensive income
Accumulated other comprehensive income
(loss)
(loss)

AUM
AUM

Assets under management or supervision
Assets under management or supervision

Balance sheets
Balance sheets

Consolidated balance sheets
Consolidated balance sheets

BEAT
BEAT

BHC
BHC

bps
bps

Cash flow
Cash flow
statements
statements

Base erosion and anti-abuse tax
Base erosion and anti-abuse tax

Bank holding company
Bank holding company

Basis points; one basis point equals
Basis points; one basis point equals
1/100th of 1%
1/100th of 1%

Consolidated cash flow statements
Consolidated cash flow statements

CCAR
CCAR

CCyB
CCyB

CDO
CDO

CDS
CDS

CECL
CECL

CFTC
CFTC

CLN
CLN

CLO
CLO

CMBS
CMBS

CMO
CMO

CVA
CVA

DVA
DVA

Comprehensive Capital Analysis and
Comprehensive Capital Analysis and
Review
Review

Countercyclical capital buffer
Countercyclical capital buffer

Collateralized debt obligation(s),
Collateralized debt obligation(s),
including Collateralized loan obligation
including Collateralized loan obligation
(s)
(s)

Credit default swaps
Credit default swaps

Current expected credit loss
Current expected credit loss

U.S. Commodity Futures Trading
U.S. Commodity Futures Trading
Commission
Commission

Credit-linked note(s)
Credit-linked note(s)

Collateralized loan obligation(s)
Collateralized loan obligation(s)

Commercial mortgage-backed securities
Commercial mortgage-backed securities

Collateralized mortgage obligation(s)
Collateralized mortgage obligation(s)

Credit valuation adjustment
Credit valuation adjustment

Debt valuation adjustment
Debt valuation adjustment

ELN
ELN

EMEA
EMEA

EPS
EPS

E.U.
E.U.

FDIC
FDIC

FFELP
FFELP

FFIEC
FFIEC

FHC
FHC

FICC
FICC

FICO
FICO

Equity-linked note(s)
Equity-linked note(s)

Europe, Middle East and Africa
Europe, Middle East and Africa

Earnings per common share
Earnings per common share

European Union
European Union

Federal Deposit Insurance Corporation
Federal Deposit Insurance Corporation

Federal Family Education Loan Program
Federal Family Education Loan Program

Federal Financial Institutions Examination
Federal Financial Institutions Examination
Council
Council

Financial Holding Company
Financial Holding Company

Fixed Income Clearing Corporation
Fixed Income Clearing Corporation

Fair Isaac Corporation
Fair Isaac Corporation

Financial
Financial
statements
statements

Consolidated financial statements
Consolidated financial statements

FVA
FVA

GILTI
GILTI

GLR
GLR

G-SIB
G-SIB

Funding valuation adjustment
Funding valuation adjustment

Global Intangible Low-Taxed Income
Global Intangible Low-Taxed Income

Global liquidity reserve
Global liquidity reserve

Global systemically important banks
Global systemically important banks

HELOC
HELOC

Home Equity Line of Credit
Home Equity Line of Credit

HQLA
HQLA

HTM
HTM

I/E
I/E

IHC
IHC

IM
IM

Income
Income
statements
statements

IRS
IRS

IS
IS

LCR
LCR

LIBOR
LIBOR

M&A
M&A

High-quality liquid assets
High-quality liquid assets

Held-to-maturity
Held-to-maturity

Intersegment eliminations
Intersegment eliminations

Intermediate holding company
Intermediate holding company

Investment Management
Investment Management

Consolidated income statements
Consolidated income statements

Internal Revenue Service
Internal Revenue Service

Institutional Securities
Institutional Securities

Liquidity coverage ratio, as adopted by the
Liquidity coverage ratio, as adopted by the
U.S. banking agencies
U.S. banking agencies

London Interbank Offered Rate
London Interbank Offered Rate

Merger, acquisition and restructuring
Merger, acquisition and restructuring
transaction
transaction

EBITDA
EBITDA

Earnings before interest, taxes,
Earnings before interest, taxes,
depreciation and amortization
depreciation and amortization

MSBNA
MSBNA

Morgan Stanley Bank, N.A.
Morgan Stanley Bank, N.A.

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Glossary of Common Terms and Acronyms

MS&Co.
MS&Co.

Morgan Stanley & Co. LLC
Morgan Stanley & Co. LLC

ROE
ROE

Return on average common equity
Return on average common equity

Morgan Stanley & Co. International plc
Morgan Stanley & Co. International plc

ROTCE
ROTCE

Return on average tangible common
Return on average tangible common
equity
equity

ROU
ROU

RSU
RSU

RWA
RWA

SEC
SEC

SLR
SLR

Right-of-use
Right-of-use

Restricted stock unit
Restricted stock unit

Risk-weighted assets
Risk-weighted assets

U.S. Securities and Exchange Commission
U.S. Securities and Exchange Commission

Supplementary leverage ratio
Supplementary leverage ratio

SOFR
SOFR

Secured Overnight Financing Rate
Secured Overnight Financing Rate

S&P
S&P

SPE
SPE

SPOE
SPOE

TDR
TDR

TLAC
TLAC

U.K.
U.K.

UPB
UPB

U.S.
U.S.

Standard & Poor’s
Standard & Poor’s

Special purpose entity
Special purpose entity

Single point of entry
Single point of entry

Troubled debt restructuring
Troubled debt restructuring

Total loss-absorbing capacity
Total loss-absorbing capacity

United Kingdom
United Kingdom

Unpaid principal balance
Unpaid principal balance

United States of America
United States of America

U.S. GAAP
U.S. GAAP

Accounting principles generally accepted
Accounting principles generally accepted
in the United States of America
in the United States of America

VaR
VaR

VIE
VIE

WACC
WACC

WM
WM

Value-at-Risk
Value-at-Risk

Variable interest entity
Variable interest entity

Implied weighted average cost of capital
Implied weighted average cost of capital

Wealth Management
Wealth Management

MSIP
MSIP

MSMS
MSMS

Morgan Stanley MUFG Securities Co.,
Morgan Stanley MUFG Securities Co.,
Ltd.
Ltd.

MSPBNA
MSPBNA

Morgan Stanley Private Bank, National
Morgan Stanley Private Bank, National
Association
Association

MSSB
MSSB

MUFG
MUFG

MUMSS
MUMSS

Morgan Stanley Smith Barney LLC
Morgan Stanley Smith Barney LLC

Mitsubishi UFJ Financial Group, Inc.
Mitsubishi UFJ Financial Group, Inc.

Mitsubishi UFJ Morgan Stanley Securities
Mitsubishi UFJ Morgan Stanley Securities
Co., Ltd.
Co., Ltd.

MWh
MWh

Megawatt hour
Megawatt hour

N/A
N/A

NAV
NAV

N/M
N/M

Not Applicable
Not Applicable

Net asset value
Net asset value

Not Meaningful
Not Meaningful

Non-GAAP
Non-GAAP

Non-generally accepted accounting
Non-generally accepted accounting
principles
principles

NSFR
NSFR

OCC
OCC

OCI
OCI

OIS
OIS

OTC
OTC

OTTI
OTTI

PRA
PRA

PSU
PSU

Net stable funding ratio, as proposed by
Net stable funding ratio, as proposed by
the U.S. banking agencies
the U.S. banking agencies

Office of the Comptroller of the Currency
Office of the Comptroller of the Currency

Other comprehensive income (loss)
Other comprehensive income (loss)

Overnight index swap
Overnight index swap

Over-the-counter
Over-the-counter

Other-than-temporary impairment
Other-than-temporary impairment

Prudential Regulation Authority
Prudential Regulation Authority

Performance-based stock unit
Performance-based stock unit

RMBS
RMBS

Residential mortgage-backed securities
Residential mortgage-backed securities

December 2019 Form 10-K

156

Table of Contents

Changes in and Disagreements with Accountants
on Accounting and Financial Disclosure

The  internal  control  over  financial  reporting  includes  those
policies and procedures that:

None.

Controls and Procedures

Conclusion  Regarding  the  Effectiveness  of  Disclosure
Controls and Procedures

Under the supervision and with the participation of the Firm’s
management, including the Chief Executive Officer and Chief
Financial  Officer,  the  Firm  conducted  an  evaluation  of
disclosure controls and procedures, as such term is defined under
Exchange Act  Rule  13a-15(e).  Based  on  this  evaluation,  the
Chief Executive Officer and Chief Financial Officer concluded
that the Firm’s disclosure controls and procedures were effective
as of the end of the period covered by this annual report.

Management’s Report on Internal Control Over Financial
Reporting

The  Firm’s  management  is  responsible  for  establishing  and
maintaining adequate internal control over financial reporting.
The Firm’s internal control over financial reporting is 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 in the United States of America (“U.S.
GAAP”).

• Pertain to the maintenance of records that, in reasonable detail,
accurately and fairly reflect the transactions and dispositions
of the assets of the Firm;

• Provide reasonable assurance that transactions are recorded
as necessary to permit preparation of financial statements in
accordance  with  U.S.  GAAP,  and 
that  receipts  and
expenditures  are  being  made  only  in  accordance  with
authorizations of the Firm’s management and directors; and

• Provide reasonable assurance regarding prevention or timely
detection of unauthorized acquisition, use or disposition of
Firm assets that could have a material effect on the Firm’s
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.

Management assessed the effectiveness of the Firm’s internal
control  over  financial  reporting  as  of  December 31,  2019.  In
making this assessment, management used the criteria set forth
by the Committee of Sponsoring Organizations of the Treadway
Commission  (“COSO”) 
in  Internal  Control—Integrated
Framework  (2013).  Based  on  management’s  assessment  and
those criteria, management believes that the Firm maintained
effective  internal  control  over  financial  reporting  as  of
December 31, 2019.

The Firm’s independent registered public accounting firm has
audited and issued a report on the Firm’s internal control over
financial reporting, which appears below.

157

December 2019 Form 10-K

 
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Report of Independent Registered Public Accounting Firm

To the Shareholders and the Board of Directors of Morgan Stanley: 

assessing the risk that a material weakness exists, testing and
evaluating  the  design  and  operating  effectiveness  of  internal
control based on the assessed risk, and 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.

Opinion on Internal Control over Financial Reporting

We have audited the internal control over financial reporting of
Morgan  Stanley  and  subsidiaries  (the  “Firm”)  as  of
December 31,  2019,  based  on  criteria  established  in  Internal
Control  —  Integrated  Framework  (2013) issued  by  the
Committee  of  Sponsoring  Organizations  of  the  Treadway
Commission (COSO). In our opinion, the Firm maintained, in
all  material  respects,  effective  internal  control  over  financial
reporting as of December 31, 2019, based on criteria established
in Internal Control — Integrated Framework (2013) issued by
COSO.

We have also audited, in accordance with the standards of the
Public Company Accounting Oversight Board (United States)
(PCAOB), the consolidated financial statements of the Firm as
of and for the year ended December 31, 2019 and our report
dated February 27, 2020 expressed an unqualified opinion on
those financial statements.

Basis for Opinion

The Firm’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 Report on Internal
Control  Over  Financial  Reporting.  Our  responsibility  is  to
express an opinion on the Firm’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  Firm  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
included  obtaining  an
material 
understanding of internal control over financial reporting,

respects.  Our  audit 

 /s/ Deloitte & Touche LLP

New York, New York
February 27, 2020

December 2019 Form 10-K

158

 
 
 
Table of Contents

Changes in Internal Control Over Financial Reporting

Properties

No change in the Firm’s internal control over financial reporting
(as  such  term  is  defined  in  Exchange  Act  Rule  13a-15(f))
occurred  during  the  quarter  ended  December 31,  2019  that
materially affected, or is reasonably likely to materially affect,
the Firm’s internal control over financial reporting.

Other Information

On February 26, 2020, the Firm announced that Paul C. Wirth
would step down from his position as Deputy Chief Financial
Officer and Controller of the Firm in May 2020. After that date,
Mr. Wirth will become a Senior Advisor in the Finance Division
reporting to the Chief Financial Officer.

On February 27, 2020, the Firm announced that Raja J. Akram,
age  47,  will  become  Deputy  Chief  Financial  Officer,  Chief
Accounting Officer and Controller of the Firm in May 2020. 

Beginning in November 2017, Mr. Akram was Controller and
Chief Accounting  Officer  of  Citigroup  Inc.  Since  2006,  Mr.
Akram  held  a  number  of  roles  in  Citigroup  Inc.,  including
Deputy  Controller,  head  of  the  Finance  group’s  Corporate
Accounting Policy team supporting M&A activities, and Brazil
Country Finance Officer.

For 2020, Mr. Akram will receive a base salary of $600,000 and
a year-end bonus of $4,400,000 that is payable in a combination
of  cash  and  deferred 
incentive  compensation.  Upon
commencement  of  employment,  Mr.  Akram  will  receive
incoming awards in the form of a one-time cash payment, a one-
time deferred cash award, and a one-time restricted stock unit
award  with  an  aggregate  value  of  $5,000,000.  Deferred
incentive  compensation  awards,  including  deferred  cash  and
restricted stock units, are subject to the terms and conditions of
the  governing  award  documentation,  including  vesting  and
cancellation  conditions.  In  the  event  that  Mr.  Akram’s
employment  offer  is  withdrawn  by  the  Firm,  with  limited
exceptions, or his employment is terminated by the Firm without
cause, he is entitled to severance in an amount equal to his 2020
base salary and the value of any portion of the 2020 year-end
bonus  and  incoming  awards  that  have  not  yet  been  paid  or
awarded. 

Unresolved Staff Comments

The Firm, like other well-known seasoned issuers, from time to
time  receives  written  comments  from  the  staff  of  the  SEC
regarding its periodic or current reports under the Exchange Act.
There are no comments that remain unresolved that the Firm
received not less than 180 days before the end of the year to
which this report relates that the Firm believes are material.

We have offices, operations and data centers located around the
world. Our global headquarters and principal executive offices
are located at 1585 Broadway, New York, New York. Our other
principal offices include locations in Manhattan and the greater
New York metropolitan area, London, Hong Kong and Tokyo.
Our  current  facilities  are  adequate  for  our  present  and  future
operations for each of our business segments, although we may
add regional offices, depending upon our future operations.

Legal Proceedings

In addition to the matters described below, in the normal course
of business, the Firm has been named, from time to time, as a
defendant in various legal actions, including arbitrations, class
actions  and  other  litigation,  arising  in  connection  with  its
activities as a global diversified financial services institution.
Certain of the actual or threatened legal actions include claims
for substantial compensatory and/or punitive damages or claims
for  indeterminate  amounts  of  damages.  In  some  cases,  the
entities that would otherwise be the primary defendants in such
cases are bankrupt or are in financial distress.

The Firm is also involved, from time to time, in other reviews,
investigations and proceedings (both formal and informal) by
governmental and self-regulatory agencies regarding the Firm’s
business, and involving, among other matters, sales and trading
activities, 
sponsored,
financial  products  or  offerings 
underwritten or sold by the Firm, and accounting and operational
matters,  certain  of  which  may  result  in  adverse  judgments,
settlements, fines, penalties, injunctions or other relief.

The  Firm  contests  liability  and/or  the  amount  of  damages  as
appropriate 
in  each  pending  matter.  Where  available
information  indicates  that  it  is  probable  a  liability  had  been
incurred at the date of the financial statements and the Firm can
reasonably estimate the amount of that loss, the Firm accrues
the estimated loss by a charge to income. The Firm’s future legal
expenses may fluctuate from period to period, given the current
environment regarding government investigations and private
litigation affecting global financial services firms, including the
Firm.

In  many  proceedings  and  investigations,  however,  it  is
inherently difficult to determine whether any loss is probable or
even possible, or to estimate the amount of any loss. The Firm
cannot predict with certainty if, how or when such proceedings
or  investigations  will  be  resolved  or  what  the  eventual
settlement,  fine,  penalty  or  other  relief,  if  any,  may  be,
particularly for proceedings and investigations where the factual
record is being developed or contested or where plaintiffs or
government entities seek substantial or indeterminate damages,
restitution,  disgorgement  or  penalties.  Numerous  issues  may
need  to  be  resolved,  including  through  potentially  lengthy
discovery  and  determination  of  important  factual  matters,
determination  of  issues  related  to  class  certification  and  the

159

December 2019 Form 10-K

Table of Contents

calculation of damages or other relief, and by addressing novel
or  unsettled  legal  questions  relevant  to  the  proceedings  or
investigations  in  question,  before  a  loss  or  additional  loss  or
range  of  loss  or  additional  range  of  loss  can  be  reasonably
estimated  for  a  proceeding  or  investigation.  Subject  to  the
foregoing, the Firm believes, based on current knowledge and
after  consultation  with  counsel,  that  the  outcome  of  such
proceedings and investigations will not have a material adverse
effect  on  the  financial  condition  of  the  Firm,  although  the
outcome of such proceedings or investigations could be material
to the Firm’s operating results and cash flows for a particular
period depending on, among other things, the level of the Firm’s
revenues or income for such period.

While the Firm has identified below certain proceedings that the
Firm believes to be material, individually or collectively, there
can be no assurance that additional material losses will not be
incurred from claims that have not yet been asserted or are not
yet determined to be material.

Residential Mortgage and Credit Crisis Related Matters

On  July  15,  2010,  China  Development  Industrial  Bank
(“CDIB”)  filed  a  complaint  against  the  Firm,  styled  China
Development  Industrial  Bank  v.  Morgan  Stanley  &  Co.
Incorporated et al., which is pending in the Supreme Court of
the State of New York, New York County (“Supreme Court of
NY”). The complaint relates to a $275 million CDS referencing
the  super  senior  portion  of  the  STACK  2006-1  CDO.  The
complaint  asserts  claims  for  common  law  fraud,  fraudulent
inducement  and  fraudulent  concealment  and  alleges  that  the
Firm misrepresented the risks of the STACK 2006-1 CDO to
CDIB, and that the Firm knew that the assets backing the CDO
were of poor quality when it entered into the CDS with CDIB.
The  complaint  seeks  compensatory  damages  related  to  the
approximately $228 million that CDIB alleges it has already lost
under  the  CDS,  rescission  of  CDIB’s  obligation  to  pay  an
additional $12 million, punitive damages, equitable relief, pre-
and  post-judgment  interest,  fees  and  costs.  On  February  28,
2011,  the  court  denied  the  Firm’s  motion  to  dismiss  the
complaint. On December 21, 2018, the court denied the Firm’s
motion for summary judgment and granted in part the Firm’s
motion for sanctions related to the spoliation of evidence. On
January 18, 2019, CDIB filed a motion to clarify and resettle
the  portion  of  the  court’s  December  21,  2018  order  granting
spoliation sanctions. On January 24, 2019, CDIB filed a notice
of  appeal  from  the  court’s  December  21,  2018  order,  and  on
January 25, 2019, the Firm filed a notice of appeal from the same
order. On March 7, 2019, the court denied the relief that CDIB
sought in a motion to clarify and resettle the portion of the court’s
December  21,  2018  order  granting  spoliation  sanctions.  On
December  5,  2019,  the Appellate  Division,  First  Department
(“First Department") heard the parties’ cross-appeals.

On  May  17,  2013,  plaintiff  in  IKB  International  S.A.  in
Liquidation, et al. v. Morgan Stanley, et al. filed a complaint
against the Firm and certain affiliates in the Supreme Court of

December 2019 Form 10-K

160

NY.  The  complaint  alleges  that  defendants  made  material
misrepresentations  and  omissions  in  the  sale  to  plaintiff  of
certain  mortgage  pass-through  certificates  backed  by
securitization trusts containing residential mortgage loans. The
total amount of certificates allegedly sponsored, underwritten
and/or  sold  by  the  Firm  to  plaintiff  was  approximately  $133
million. The complaint alleges causes of action against the Firm
for  common  law  fraud,  fraudulent  concealment,  aiding  and
abetting  fraud,  and  negligent  misrepresentation,  and  seeks,
among other things, compensatory and punitive damages. On
October 29, 2014, the court granted in part and denied in part
the  Firm’s  motion  to  dismiss.  All  claims  regarding  four
certificates  were  dismissed.  After  these  dismissals,  the
remaining amount of certificates allegedly issued by the Firm
or sold to plaintiff by the Firm was approximately $116 million.
On August  11,  2016,  the  First  Department  affirmed  the  trial
court’s order denying in part the Firm’s motion to dismiss the
complaint. 

On  July  2,  2013,  Deutsche  Bank,  in  its  capacity  as  trustee,
became the named plaintiff in Federal Housing Finance Agency,
as  Conservator  for  the  Federal  Home  Loan  Mortgage
Corporation,  on  behalf  of  the  Trustee  of  the  Morgan  Stanley
ABS Capital I Inc. Trust, Series 2007-NC1 (MSAC 2007-NC1)
v. Morgan Stanley ABS Capital I Inc., and filed a complaint in
the Supreme Court of NY styled Deutsche Bank National Trust
Company, as Trustee for the Morgan Stanley ABS Capital I Inc.
Trust, Series 2007-NC1 v. Morgan Stanley ABS Capital I, Inc.
On February 3, 2014, the plaintiff filed an amended complaint,
which asserts claims for breach of contract and breach of the
implied  covenant  of  good  faith  and  fair  dealing  and  alleges,
among other things, that the loans in the trust, which had an
original  principal  balance  of  approximately  $1.25  billion,
breached various representations and warranties. The amended
complaint seeks, among other relief, specific performance of
the loan breach remedy procedures in the transaction documents,
unspecified damages, rescission and interest. On April 12, 2016,
the court granted in part and denied in part the Firm’s motion to
dismiss the amended complaint, dismissing all claims except a
single  claim  alleging  failure  to  notify,  regarding  which  the
motion was denied without prejudice. On December 9, 2016,
the Firm renewed its motion to dismiss that notification claim.
On January 17, 2017, the First Department affirmed the lower
court’s  April  12,  2016  order.  On  April  13,  2017,  the  First
Department denied plaintiff’s motion for leave to appeal to the
Court of Appeals. On March 8, 2018, the trial court denied the
Firm’s renewed motion to dismiss the notification claims. 

On July 8, 2013, U.S. Bank National Association, in its capacity
as trustee, filed a complaint against the Firm styled U.S. Bank
National Association,  solely  in  its  capacity  as  Trustee  of  the
Morgan  Stanley  Mortgage  Loan  Trust  2007-2AX  (MSM
2007-2AX) v. Morgan Stanley Mortgage Capital Holdings LLC,
Successor-by-Merger to Morgan Stanley Mortgage Capital Inc.
and  GreenPoint  Mortgage  Funding,  Inc.,  pending  in  the
Supreme Court of NY. The complaint asserts claims for breach

Table of Contents

of contract and alleges, among other things, that the loans in the
trust, which had an original principal balance of approximately
$650 million, breached various representations and warranties.
The complaint seeks, among other relief, specific performance
of  the  loan  breach  remedy  procedures  in  the  transaction
documents, unspecified damages and interest. On November 24,
2014, the court granted in part and denied in part the Firm’s
motion to dismiss the complaint. On August 13, 2018, the Firm
filed a motion to renew its motion to dismiss. On April 4, 2019,
the  court  denied  the  Firm’s  motion  to  renew  its  motion  to
dismiss.

On November 6, 2013, Deutsche Bank, in its capacity as trustee,
became the named plaintiff in Federal Housing Finance Agency,
as  Conservator  for  the  Federal  Home  Loan  Mortgage
Corporation,  on  behalf  of  the  Trustee  of  the  Morgan  Stanley
ABS Capital I Inc. Trust, Series 2007-NC3 (MSAC 2007-NC3)
v. Morgan Stanley Mortgage Capital Holdings LLC, and filed
a complaint in the Supreme Court of NY styled Deutsche Bank
National Trust Company, solely in its capacity as Trustee for
Morgan Stanley ABS Capital I Inc. Trust, Series 2007-NC3 v.
Morgan Stanley Mortgage Capital Holdings LLC, as Successor-
by-Merger  to  Morgan  Stanley  Mortgage  Capital  Inc.  The
complaint asserts claims for breach of contract and breach of
the implied covenant of good faith and fair dealing and alleges,
among other things, that the loans in the trust, which had an
original  principal  balance  of  approximately  $1.3  billion,
breached various representations and warranties. The complaint
seeks,  among  other  relief,  specific  performance  of  the  loan
breach  remedy  procedures  in  the  transaction  documents,
unspecified damages, rescission, interest and costs. On April 12,
2016,  the  court  granted  the  Firm’s  motion  to  dismiss  the
complaint, and granted the plaintiff the ability to seek to replead
certain aspects of the complaint. On January 17, 2017, the First
Department affirmed the lower court’s order granting the motion
to dismiss the complaint. On January 9, 2017, plaintiff filed a
motion  to  amend  its  complaint.  On April  13,  2017,  the  First
Department denied plaintiff’s motion for leave to appeal to the
Court  of Appeals.  On  March  8,  2018,  the  trial  court  granted
plaintiff’s motion to amend its complaint to include failure to
notify claims. On March 19, 2018, the Firm filed an answer to
plaintiff’s amended complaint. 

On September 23, 2014, FGIC filed a complaint against the Firm
in  the  Supreme  Court  of  NY  styled  Financial  Guaranty
Insurance Company v. Morgan Stanley ABS Capital I Inc. et al.
relating to the Morgan Stanley ABS Capital I Inc. Trust 2007-
NC4. The complaint asserts claims for breach of contract and
fraudulent inducement and alleges, among other things, that the
loans  in  the  trust  breached  various  representations  and
warranties and defendants made untrue statements and material
omissions to induce FGIC to issue a financial guaranty policy
on certain classes of certificates that had an original balance of
approximately $876 million. The complaint seeks, among other
relief,  specific  performance  of  the  loan  breach  remedy
procedures  in  the  transaction  documents,  compensatory,

consequential  and  punitive  damages,  attorneys’  fees  and
interest. On January 23, 2017, the court denied the Firm’s motion
to dismiss the complaint. On February 24, 2017, the Firm filed
a  notice  of  appeal  of  the  denial  of  its  motion  to  dismiss  the
complaint and perfected its appeal on November 22, 2017. On
September 13, 2018, the First Department affirmed in part and
reversed  in  part  the  lower  court’s  order  denying  the  Firm’s
motion to dismiss the complaint. On December 20, 2018, the
First Department denied plaintiff’s motion for leave to appeal
to the Court of Appeals or, in the alternative, for reargument. 

On January 23, 2015, Deutsche Bank National Trust Company,
in its capacity as trustee, filed a complaint against the Firm styled
Deutsche Bank National Trust Company solely in its capacity
as Trustee of the Morgan Stanley ABS Capital I Inc. Trust 2007-
NC4  v.  Morgan  Stanley  Mortgage  Capital  Holdings  LLC  as
Successor-by-Merger to Morgan Stanley Mortgage Capital Inc.,
and Morgan Stanley ABS Capital I Inc., pending in the Supreme
Court of NY. The complaint asserts claims for breach of contract
and alleges, among other things, that the loans in the trust, which
had an original principal balance of approximately $1.05 billion,
breached various representations and warranties. The complaint
seeks,  among  other  relief,  specific  performance  of  the  loan
breach  remedy  procedures  in  the  transaction  documents,
compensatory, consequential, rescissory, equitable and punitive
damages, attorneys’ fees, costs and other related expenses, and
interest. On December 11, 2015, the court granted in part and
denied in part the Firm’s motion to dismiss the complaint. On
October 19, 2018, the court granted the Firm’s motion for leave
to amend its answer and to stay the case pending resolution of
Deutsche Bank National Trust Company’s appeal to the Court
of Appeals in another case styled Deutsche Bank National Trust
Company v. Barclays Bank PLC regarding the applicable statute
of  limitations.  On  January  17,  2019,  the  First  Department
reversed the trial court’s order to the extent that it had granted
in part the Firm’s motion to dismiss the complaint. On June 4,
2019, the First Department granted the Firm’s motion for leave
to appeal its January 17, 2019 decision to the Court of Appeals.

Antitrust Related Matters

The Firm and other financial institutions are responding to a
number  of  governmental  investigations  and  civil  litigation
matters  related  to  allegations  of  anticompetitive  conduct  in
various aspects of the financial services industry, including the
matters described below.

Beginning  in  February  of  2016,  the  Firm  was  named  as  a
defendant  in  multiple  purported  antitrust  class  actions  now
consolidated  into  a  single  proceeding  in  the  United  States
District Court for the Southern District of New York (“SDNY”)
styled In Re: Interest Rate Swaps Antitrust Litigation. Plaintiffs
allege, inter alia, that the Firm, together with a number of other
financial  institution  defendants,  violated  U.S.  and  New York
state  antitrust  laws  from  2008  through  December  of  2016  in
connection with their alleged efforts to prevent the development
of electronic exchange-based platforms for interest rates swaps

161

December 2019 Form 10-K

Table of Contents

trading. Complaints were filed both on behalf of a purported
class  of  investors  who  purchased  interest  rates  swaps  from
defendants, as well as on behalf of two swap execution facilities
that allegedly were thwarted by the defendants in their efforts
to develop such platforms. The consolidated complaints seek,
among other relief, certification of the investor class of plaintiffs
and treble damages. On July 28, 2017, the court granted in part
and  denied  in  part  the  defendants’  motion  to  dismiss  the
complaints.

In August  of  2017,  the  Firm  was  named  as  a  defendant  in  a
purported  antitrust  class  action  in  the  United  States  District
Court for the SDNY styled Iowa Public Employees’ Retirement
System et al. v. Bank of America Corporation et al. Plaintiffs
allege, inter alia, that the Firm, together with a number of other
financial institution defendants, violated U.S. antitrust laws and
New York state law in connection with their alleged efforts to
prevent 
the  development  of  electronic  exchange-based
platforms for securities lending. The class action complaint was
filed on behalf of a purported class of borrowers and lenders
who entered into stock loan transactions with the defendants.
The  class  action  complaint  seeks,  among  other  relief,
certification of the class of plaintiffs and treble damages. On
September 27, 2018, the court denied the defendants’ motion to
dismiss the class action complaint.

European Matters

On  October  11,  2011,  an  Italian  financial  institution,  Banco
Popolare Societá Cooperativa (“Banco Popolare”), filed a civil
claim  against  the  Firm  in  the  Milan  courts,  styled  Banco
Popolare  Societá  Cooperativa  v  Morgan  Stanley  &  Co.
International  plc  &  others,  related  to  its  purchase  of  €100
million  of  bonds  issued  by  Parmalat.  The  claim  asserted  by
Banco Popolare alleges, among other things, that the Firm was
aware of Parmalat’s impending insolvency and conspired with
others  to  deceive  Banco  Popolare  into  buying  bonds  by
concealing both Parmalat’s true financial condition and certain
features  of  the  bonds  from  the  market  and  Banco  Popolare.
Banco Popolare seeks damages of €76 million (approximately
$85 million) plus damages for loss of opportunity and moral
damages.  The  Firm  filed  its  answer  on  April  20,  2012.  On
September 11, 2018, the court dismissed in full the claim against
the Firm. On March 11, 2019, the plaintiff filed an appeal in the
Court of Appeal of Milan. On May 31, 2019, the Firm filed its
response to the plaintiff’s appeal. An appeal hearing is scheduled
to take place on September 16, 2020 in the Court of Appeal of
Milan.

On  June 22,  2017,  the  public  prosecutor  for  the  Court  of
Accounts for the Republic of Italy filed a claim against the Firm
styled  Case  No.  2012/00406/MNV,  which  is  pending  in  the
Regional Prosecutor’s Office at the Judicial Section of the Court
of  Auditors  for  Lazio,  Italy.  The  claim  relates  to  certain
derivative transactions between the Republic of Italy and the
Firm.  The  transactions  were  originally  entered  into  between
1999  and  2005,  and  were  restructured  (and  certain  of  the

December 2019 Form 10-K

162

transactions were terminated) in December 2011 and January
2012. The claim alleges, inter alia, that the Firm effectively acted
as an agent of the state in connection with these transactions and
asserts  claims  related  to,  among  other  things,  whether  the
Ministry  of  Finance  was  authorized  to  enter  into  these
transactions,  whether  the  transactions  were  appropriate  and
whether the Firm’s conduct related to the termination of certain
transactions  was  proper.  The  prosecutor  is  seeking  damages
through an administrative process against the Firm for €2.76
billion (approximately $3.1 billion). On March 30, 2018, the
Firm filed its defense to the claim. On June 15, 2018, the Court
issued a decision declining jurisdiction and dismissing the claim
against the Firm. A hearing of the public prosecutor’s appeal
was held on January 10, 2019. On March 7, 2019, the Appellate
Division of the Court of Accounts for the Republic of Italy issued
a decision affirming the decision below declining jurisdiction
and dismissing the claim against the Firm. On April 19, 2019,
the public prosecutor filed an appeal with the Italian Supreme
Court seeking to overturn this decision. On June 14, 2019, the
Firm filed its response to the public prosecutor’s appeal.

In  matters  styled  Case  number  15/3637  and  Case  number
15/4353,  the  Dutch  Tax  Authority  (“Dutch  Authority”)  has
challenged in the District Court in Amsterdam the prior set-off
by the Firm of approximately €124 million (approximately $139
million) plus accrued interest of withholding tax credits against
the Firm’s corporation tax liabilities for the tax years 2007 to
2013. The Dutch Authority alleges that the Firm was not entitled
to receive the withholding tax credits on the basis, inter alia, that
a Firm subsidiary did not hold legal title to certain securities
subject  to  withholding  tax  on  the  relevant  dates.  The  Dutch
Authority has also alleged that the Firm failed to provide certain
information to the Dutch Authority and keep adequate books
and records. On April 26, 2018, the District Court in Amsterdam
issued a decision dismissing the Dutch Authority’s claims. On
June 4, 2018, the Dutch Authority filed an appeal before the
Court of Appeal in Amsterdam in matters re-styled Case number
18/00318 and Case number 18/00319. On June 26 and July 2,
2019, a hearing of the Dutch Tax Authority’s appeal was held.

On October 5, 2017, various institutional investors filed a claim
against the Firm and another bank in a matter now styled Case
number  B-803-18  (previously  BS  99-6998/2017),  in  the  City
Court  of  Copenhagen,  Denmark  concerning  their  roles  as
underwriters of the initial public offering (“IPO”) in March 2014
of  the  Danish  company  OW  Bunker  A/S.  The  claim  seeks
damages of DKK 534,270,456 (approximately $80 million) plus
interest  in  respect  of  alleged  losses  arising  from  investing  in
shares  in  OW  Bunker,  which  entered  into  bankruptcy  in
November 2014. Separately, on November 29, 2017, another
group of institutional investors joined the Firm and another bank
as  defendants  to  pending  proceedings  in  the  High  Court  of
Eastern Denmark against various other parties involved in the
IPO  in  a  matter  styled  Case  number  B-2073-16.  The  claim
brought against the Firm and the other bank has been given its
own Case number B-2564-17. The investors claim damages of

Table of Contents

DKK 767,235,885 (approximately $115 million) plus interest,
from the Firm and the other bank on a joint and several basis
with the Defendants to these proceedings. Both claims are based
on  alleged  prospectus  liability;  the  second  claim  also  alleges
professional liability of banks acting as financial intermediaries.
On  June  8,  2018,  the  City  Court  of  Copenhagen,  Denmark
ordered  that  the  matters  now  styled  Case  number  B-803-18,
B-2073-16  and  Case  number  B-2564-17  be  heard  together
before the High Court of Eastern Denmark. On June 29, 2018,
the Firm filed its defense to the matter now styled Case number
B-2564-17. On February 4, 2019, the Firm filed its defense to
the matter now styled Case number B-803-18.

The following matters were terminated during or following
the quarter ended December 31, 2019:

On  December  30,  2013,  Wilmington  Trust  Company,  in  its
capacity  as  trustee  for  Morgan  Stanley  Mortgage  Loan Trust
2007-12, filed a complaint against the Firm styled Wilmington
Trust Company v. Morgan Stanley Mortgage Capital Holdings
LLC et al., pending in the Supreme Court of NY. The complaint
asserted claims for breach of contract and alleged, among other
things, that the loans in the trust, which had an original principal
balance  of  approximately  $516  million,  breached  various
representations and warranties. The complaint sought, among
other relief, unspecified damages, attorneys’ fees, interest and
costs.  On  February  28,  2014,  defendants  filed  a  motion  to
dismiss the complaint, which was granted in part and denied in
part on June 14, 2016. Plaintiff filed a notice of appeal of that
order on August 17, 2016. On July 11, 2017, First Department
affirmed in part and reversed in part an order granting in part
and denying in part the Firm’s motion to dismiss. On August 10,
2017, plaintiff filed a motion for leave to appeal that decision.
On September 26, 2017, the First Department denied plaintiff’s
motion for leave to appeal to the Court of Appeals. On October
31,  2018,  the  parties  entered  into  an  agreement  to  settle  the
litigation.  On  September  10,  2019,  the  court  entered  a  final
judgment and order granting final approval of the settlement.
On  November  11,  2019,  the  parties  filed  a  stipulation  of
voluntary discontinuance, dismissing the action with prejudice.

On September 19, 2014, FGIC filed a complaint against the Firm
in  the  Supreme  Court  of  NY,  styled  Financial  Guaranty
Insurance Company v. Morgan Stanley ABS Capital I Inc. et al.
relating  to  a  securitization  issued  by  Basket  of  Aggregated
Residential NIMS 2007-1 Ltd. The complaint asserted claims
for breach of contract and alleges, among other things, that the
net interest margin securities (“NIMS”) in the trust breached
various representations and warranties. FGIC issued a financial
guaranty policy with respect to certain notes that had an original
balance of approximately $475 million. The complaint sought,
among other relief, specific performance of the NIMS breach
remedy procedures in the transaction documents, unspecified
damages, reimbursement of certain payments made pursuant to
the  transaction  documents,  attorneys’  fees  and  interest.  On
November  24,  2014,  the  Firm  filed  a  motion  to  dismiss  the
complaint,  which  the  court  denied  on  January  19,  2017.  On

February 24, 2017, the Firm filed a notice of appeal of the denial
of its motion to dismiss the complaint and perfected its appeal
on  November  22,  2017.  On  September  13,  2018,  the  court
affirmed the lower court’s order denying the Firm’s motion to
dismiss  the  complaint.  On  November  13,  2019,  the  parties
entered into an agreement to settle the litigation. On December
4,  2019, 
the  parties  filed  a  stipulation  of  voluntary
discontinuance, dismissing the action with prejudice.

issued  by 

Beginning  on  March  25,  2019,  the  Firm  was  named  as  a
defendant in a series of putative class action complaints filed in
the Southern District of NY, the first of which is styled Alaska
Electrical Pension Fund v. BofA Secs., Inc., et al. Each complaint
alleges a conspiracy to fix prices and restrain competition in the
the  following
market  for  unsecured  bonds 
Government-Sponsored  Enterprises:  the  Federal  National
Mortgage  Associate;  the  Federal  Home  Loan  Mortgage
Corporation; 
the  Federal  Farm  Credit  Banks  Funding
Corporation; and the Federal Home Loan Banks. The purported
class period for each suit is from January 1, 2012 to June 1, 2018.
Each complaint raises a claim under Section 1 of the Sherman
Act and seeks, among other things, injunctive relief and treble
compensatory  damages.  On  May  23,  2019,  plaintiffs  filed  a
consolidated amended class action complaint styled In re GSE
Bonds Antitrust Litigation, with a purported class period from
January  1,  2009  to  January  1,  2016.  On  June  13,  2019,  the
defendants  filed  a  joint  motion  to  dismiss  the  consolidated
amended complaint. On August 29, 2019, the court denied the
Firm's motion to dismiss. On December 15, 2019, the Firm and
certain other defendants entered into a stipulation of settlement
to resolve the action as against each of them in its entirety. On
February 3, 2020, the court granted preliminary approval of that
settlement.

Mine Safety Disclosures

Not applicable.

163

December 2019 Form 10-K

Table of Contents

 Market for Registrant’s Common Equity, Related
Stockholder  Matters  and  Issuer  Purchases  of
Equity Securities

Morgan Stanley’s common stock trades under the symbol “MS”
on the New York Stock Exchange. As of February 14, 2020, the
Firm had 54,039 holders of record; however, the Firm believes
the number of beneficial owners of the Firm’s common stock
exceeds this number.

The  table  below  sets  forth  the  information  with  respect  to
purchases made by or on behalf of the Firm of its common stock
during the fourth quarter of the year ended December 31, 2019.

Issuer Purchases of Equity Securities
Three Months Ended December 31, 2019 

$ in millions, except
per share data

October

November

December

Total

Total 
Number
of Shares
Purchased1

Average 
Price
Paid Per 
Share

Total Shares 
Purchased as
Part of Share
Repurchase
Program2,3

Dollar Value
of Remaining
Authorized
Repurchase

5,888,009 $

45.59

5,851,110 $

11,221,315 $

48.53

11,212,000 $

13,998,018 $

49.67

13,872,271 $

4,233

3,689

3,000

31,107,342 $

48.48

30,935,381

1. Includes 171,961 shares acquired by the Firm in satisfaction of the tax withholding
the  Firm’s  stock-based

obligations  on  stock-based  awards  granted  under 
compensation plans during the three months ended December 31, 2019.

2. Share purchases under publicly announced programs are made pursuant to open-
market purchases, Rule 10b5-1 plans or privately negotiated transactions (including
with  employee  benefit  plans)  as  market  conditions  warrant  and  at  prices  the  Firm
deems appropriate and may be suspended at any time. On April 18, 2018, the Firm
entered into a sales plan with Mitsubishi UFJ Financial Group, Inc. (“MUFG”). See
Note 16 to the financial statements for further information on the sales plan. 

3. The Firm’s Board of Directors has authorized the repurchase of the Firm’s outstanding
stock under a share repurchase program (the “Share Repurchase Program”). The
Share  Repurchase  Program  is  a  program  for  capital  management  purposes  that
considers, among other things, business segment capital needs, as well as equity-
based compensation and benefit plan requirements. The Share Repurchase Program
has no set expiration or termination date. 

Share repurchases by the Firm are subject to regulatory non-
objection.  On  June  27,  2019,  the  Federal  Reserve  published
summary  results  of  CCAR  and  the  Firm  received  a  non-
objection to its 2019 Capital Plan. The Firm’s 2019 Capital Plan
includes  a  share  repurchase  of  up  to  $6.0  billion  of  its
outstanding common stock during the period beginning July 1,
2019  through  June  30,  2020.  For  further  information,  see
“Liquidity  and  Capital  Resources—Capital  Plans  and  Stress
Tests.”

Stock Performance Graph

The following graph compares the cumulative total shareholder
return  (rounded  to  the  nearest  whole  dollar)  of  the  Firm’s
common  stock,  the  S&P  500  Stock  Index  and  the  S&P  500
Financials  Sector  Index  for  the  last  five  years.  The  graph
assumes a $100 investment at the closing price on December 31,
2014 and reinvestment of dividends on the respective dividend
payment  dates  without  commissions.  This  graph  does  not
forecast future performance of the Firm’s common stock.

December 2019 Form 10-K

164

Cumulative Total Return
December 31, 2014 – December 31, 2019

$200

$150

$100

$50

$0

Dec-2014 Dec-2015 Dec-2016 Dec-2017 Dec-2018 Dec-2019

Morgan Stanley

S&P 500 Stock Index

S&P 500 Financials Sector Index

At December 31,

2014

2015

2016

2017

2018

2019

Morgan Stanley

$100.00 $ 83.25 $113.27 $143.42 $110.77 $146.94

S&P 500 Stock

Index

S&P 500 Financials

Sector Index

100.00

101.37

113.49

138.26

132.19

173.44

100.00

98.44

120.83

146.37

127.28

168.13

Directors,  Executive  Officers  and  Corporate
Governance

Information relating to the Firm’s directors and nominees in the
Firm’s definitive proxy statement for its 2020 annual meeting
of  shareholders  (“Morgan  Stanley’s  proxy  statement”)  is
incorporated by reference herein.

Information relating to the Firm’s executive officers is contained
in the “Business” section of this report under “Information about
our Executive Officers.” 

Morgan Stanley’s Code of Ethics and Business Conduct applies
to  all  directors,  officers  and  employees,  including  its  Chief
Executive  Officer,  Chief  Financial  Officer  and  Deputy  Chief
Financial Officer. You can find the Code of Ethics and Business
Conduct  on  the  webpage,  www.morganstanley.com/about-us-
governance/ethics.html. The Firm will post any amendments to
the Code of Ethics and Business Conduct, and any waivers that
are  required  to  be  disclosed  by  the  rules  of  either  the  U.S.
Securities and Exchange Commission or the New York Stock
Exchange LLC, on the webpage.

Executive Compensation

Information  relating 
compensation 
incorporated by reference herein.

to  director  and  executive  officer
is

in  Morgan  Stanley’s  proxy  statement 

 
Table of Contents

Security Ownership of Certain Beneficial Owners
and  Management  and  Related  Stockholder
Matters

Equity Compensation Plan Information

The  following  table  provides  information  about  outstanding
awards and shares of common stock available for future awards
under  all  of  Morgan  Stanley’s  equity  compensation  plans.
Morgan  Stanley  has  not  made  any  grants  of  common  stock
outside of its equity compensation plans.

At December 31, 2019

(a)

(b)

(c)

Number of
securities to be
issued upon
exercise of
outstanding
options,
warrants and
rights1

Weighted-
average
exercise
price of
outstanding
options,
warrants
and rights

Number of securities
remaining available for
future issuance under
equity compensation
plans (excluding
securities reflected in
column (a))

70,446,083 $

—

70,446,083 $

—

—

—

122,853,162 2

—

122,853,162

plan category

Equity compensation
plans approved by
security holders

Equity compensation
plans not approved
by security holders

Total

1. Includes outstanding restricted stock unit and performance stock unit awards. The
number of outstanding performance stock unit awards is based on the target number
of units granted to senior executives.

2. Includes the following:
(a) 39,182,870  shares  available  under  the  Employee  Stock  Purchase  Plan  (“ESPP”).
Pursuant to this plan, which is qualified under Section 423 of the Internal Revenue
Code, eligible employees were permitted to purchase shares of common stock at a
discount  to  market  price  through  regular  payroll  deduction.  The  Compensation,
Management  Development  and  Succession  Committee  of  the  Board  (“CMDS
Committee”) approved the discontinuation of the ESPP, effective June 1, 2009, such
that no further contributions to the plan will be permitted following such date, until such
time as the CMDS Committee determines to recommence contributions under the
plan.

(b) 67,453,320 shares available under the Equity Incentive Compensation Plan. Awards
may consist of stock options, stock appreciation rights, restricted stock, restricted stock
units to be settled by the delivery of shares of common stock (or the value thereof),
performance-based units, other awards that are valued by reference to or otherwise
based on the fair market value of common stock, and other equity-based or equity-
related awards approved by the CMDS Committee.

(c) 14,869,924 shares available under the Employee Equity Accumulation Plan, which
includes 733,757 shares available for awards of restricted stock and restricted stock
units. Awards may consist of stock options, stock appreciation rights, restricted stock,
restricted stock units to be settled by the delivery of shares of common stock (or the
value thereof), other awards that are valued by reference to or otherwise based on
the fair market value of common stock, and other equity-based or equity-related awards
approved by the CMDS Committee.

(d) 355,243 shares available under the Tax Deferred Equity Participation Plan. Awards
consist of restricted stock units, which are settled by the delivery of shares of common
stock.

(e) 991,805  shares available under the Directors’ Equity Capital Accumulation Plan. This
plan provides for periodic awards of shares of common stock and stock units to non-
employee directors and also allows non-employee directors to defer the cash fees
they earn for services as a director in the form of stock units.

Other  information  relating  to  security  ownership  of  certain
beneficial owners and management is set forth under the caption
“Ownership of Our Common Stock” in Morgan Stanley’s proxy
statement  and  such  information  is  incorporated  by  reference
herein.

Certain  Relationships  and  Related Transactions
and Director Independence

Information  regarding  certain  relationships  and  related
transactions 
is
incorporated by reference herein.

in  Morgan  Stanley’s  proxy  statement 

Information  regarding  director  independence  in  Morgan
Stanley’s proxy statement is incorporated by reference herein.

Principal Accountant Fees and Services

Information regarding principal accountant fees and services in
Morgan Stanley’s proxy statement is incorporated by reference
herein.

Exhibits and Financial Statement Schedules

Documents filed as part of this report

• The financial statements required to be filed in this annual
report  on  Form  10-K  are  included  in  the  section  titled
“Financial Statements and Supplementary Data.”

Exhibit Index1

Certain of the following exhibits, as indicated parenthetically,
were previously filed as exhibits to registration statements filed
by  Morgan  Stanley  or  its  predecessor  companies  under  the
Securities Act or to reports or registration statements filed by
Morgan  Stanley  or  its  predecessor  companies  under  the
Exchange Act and are hereby incorporated by reference to such
statements  or  reports.  Morgan  Stanley’s  Exchange  Act  file
number is 1-11758. The Exchange Act file number of Morgan
Stanley  Group  Inc.,  a  predecessor  company  (“MSG”),  was
1-9085.

Exhibit

 No. Description
3.1* Amended and Restated Certificate of Incorporation

3.2

of Morgan Stanley, as amended to date.
Amended and Restated Bylaws of Morgan Stanley,
as amended to date (Exhibit 3.1 to Morgan Stanley’s
current report on Form 8-K dated October 29, 2015).
4.1* Description  of  Securities  Registered  Pursuant  to
Section 12 of the Securities Exchange Act of 1934. 

4.2

Amended and Restated Senior Indenture dated as of
May 1, 1999 between Morgan Stanley and The Bank
of  New  York,  as  trustee  (Exhibit  4-e  to  Morgan
Stanley’s  Registration  Statement  on  Form S-3/A
(No.  333-75289) 
amended  by  Fourth
Supplemental Senior Indenture dated as of October
8,  2007  (Exhibit  4.3  to  Morgan  Stanley’s  annual
report  on  Form  10-K  for  the  fiscal  year  ended
November 30, 2007).

as 

165

December 2019 Form 10-K

 
 
Table of Contents

Exhibit
Exhibit

Exhibit
Exhibit

 No. Description
 No. Description
4.3
4.3

trustee  (Exhibit  4-f 
trustee  (Exhibit  4-f 

Senior  Indenture  dated  as  of  November 1,  2004
Senior  Indenture  dated  as  of  November 1,  2004
between Morgan Stanley and The Bank of New York,
between Morgan Stanley and The Bank of New York,
as 
to  Morgan  Stanley’s
as 
to  Morgan  Stanley’s
Registration  Statement  on  Form  S-3/A  (No.
Registration  Statement  on  Form  S-3/A  (No.
333-117752),  as  amended  by  First  Supplemental
333-117752),  as  amended  by  First  Supplemental
Senior  Indenture  dated  as  of  September  4,  2007
Senior  Indenture  dated  as  of  September  4,  2007
(Exhibit 4.5 to Morgan Stanley’s annual report on
(Exhibit 4.5 to Morgan Stanley’s annual report on
Form 10-K for the fiscal year ended November 30,
Form 10-K for the fiscal year ended November 30,
2007), Second Supplemental Senior Indenture dated
2007), Second Supplemental Senior Indenture dated
as  of  January 4,  2008  (Exhibit  4.1  to  Morgan
as  of  January 4,  2008  (Exhibit  4.1  to  Morgan
Stanley’s  current  report  on  Form  8-K  dated
Stanley’s  current  report  on  Form  8-K  dated
January 4,  2008),  Third  Supplemental  Senior
January 4,  2008),  Third  Supplemental  Senior
Indenture dated as of September 10, 2008 (Exhibit 4
Indenture dated as of September 10, 2008 (Exhibit 4
to Morgan Stanley’s quarterly report on Form 10-Q
to Morgan Stanley’s quarterly report on Form 10-Q
for  the  quarter  ended  August 31,  2008),  Fourth
for  the  quarter  ended  August 31,  2008),  Fourth
Supplemental  Senior 
Indenture  dated  as  of
Indenture  dated  as  of
Supplemental  Senior 
December 1, 2008 (Exhibit 4.1 to Morgan Stanley’s
December 1, 2008 (Exhibit 4.1 to Morgan Stanley’s
current  report  on  Form  8-K  dated  December 1,
current  report  on  Form  8-K  dated  December 1,
2008), Fifth Supplemental Senior Indenture dated as
2008), Fifth Supplemental Senior Indenture dated as
of  April 1,  2009  (Exhibit  4  to  Morgan  Stanley’s
of  April 1,  2009  (Exhibit  4  to  Morgan  Stanley’s
quarterly report on Form 10-Q for the quarter ended
quarterly report on Form 10-Q for the quarter ended
March 31,  2009),  Sixth  Supplemental  Senior
March 31,  2009),  Sixth  Supplemental  Senior
Indenture dated as of September 16, 2011 (Exhibit
Indenture dated as of September 16, 2011 (Exhibit
4.1 to Morgan Stanley’s quarterly report on Form 10-
4.1 to Morgan Stanley’s quarterly report on Form 10-
Q  for  the  quarter  ended  September 30,  2011),
Q  for  the  quarter  ended  September 30,  2011),
Seventh Supplemental Senior Indenture dated as of
Seventh Supplemental Senior Indenture dated as of
November 21, 2011 (Exhibit 4.4 to Morgan Stanley’s
November 21, 2011 (Exhibit 4.4 to Morgan Stanley’s
annual  report  on  Form  10-K  for  the  year  ended
annual  report  on  Form  10-K  for  the  year  ended
December 31,  2011),  Eighth  Supplemental  Senior
December 31,  2011),  Eighth  Supplemental  Senior
Indenture  dated  as  of  May 4,  2012  (Exhibit 4.1  to
Indenture  dated  as  of  May 4,  2012  (Exhibit 4.1  to
Morgan Stanley’s quarterly report on Form 10-Q for
Morgan Stanley’s quarterly report on Form 10-Q for
June 30,  2012),  Ninth
the  quarter 
June 30,  2012),  Ninth
ended 
ended 
the  quarter 
Supplemental  Senior 
Indenture  dated  as  of
Supplemental  Senior 
Indenture  dated  as  of
March 10,  2014  (Exhibit  4.1  to  Morgan  Stanley’s
March 10,  2014  (Exhibit  4.1  to  Morgan  Stanley’s
quarterly report on Form 10-Q for the quarter ended
quarterly report on Form 10-Q for the quarter ended
March 31,  2014)  and  Tenth  Supplemental  Senior
March 31,  2014)  and  Tenth  Supplemental  Senior
Indenture dated as of January 11, 2017 (Exhibit 4.1
Indenture dated as of January 11, 2017 (Exhibit 4.1
to  Morgan  Stanley’s  current  report  on  Form  8-K
to  Morgan  Stanley’s  current  report  on  Form  8-K
dated January 11, 2017).
dated January 11, 2017).

4.4
4.4

4.5
4.5

4.6
4.6

The Unit Agreement Without Holders’ Obligations,
The Unit Agreement Without Holders’ Obligations,
dated  as  of  August 29,  2008,  between  Morgan
dated  as  of  August 29,  2008,  between  Morgan
Stanley and The Bank of New York Mellon, as Unit
Stanley and The Bank of New York Mellon, as Unit
Agent, as Trustee and Paying Agent under the Senior
Agent, as Trustee and Paying Agent under the Senior
Indenture referred to therein and as Warrant Agent
Indenture referred to therein and as Warrant Agent
under  the  Warrant  Agreement  referred  to  therein
under  the  Warrant  Agreement  referred  to  therein
(Exhibit 4.1 to Morgan Stanley’s current report on
(Exhibit 4.1 to Morgan Stanley’s current report on
Form 8-K dated August 29, 2008).
Form 8-K dated August 29, 2008).

Subordinated Indenture dated as of October 1, 2004
Subordinated Indenture dated as of October 1, 2004
between Morgan Stanley and The Bank of New York,
between Morgan Stanley and The Bank of New York,
to  Morgan  Stanley’s
as 
to  Morgan  Stanley’s
as 
Registration 
S-3/A
Form 
Registration 
S-3/A
Form 
(No. 333-117752)).
(No. 333-117752)).

trustee  (Exhibit  4-g 
trustee  (Exhibit  4-g 
Statement 
Statement 

on 
on 

Indenture  dated  as  of
Junior  Subordinated 
Indenture  dated  as  of
Junior  Subordinated 
October 12, 2006 between Morgan Stanley and The
October 12, 2006 between Morgan Stanley and The
Bank of New York, as trustee (Exhibit 4.1 to Morgan
Bank of New York, as trustee (Exhibit 4.1 to Morgan
Stanley’s  current  report  on  Form  8-K  dated
Stanley’s  current  report  on  Form  8-K  dated
October 12, 2006).
October 12, 2006).

December 2019 Form 10-K

166

 No. Description
 No. Description
4.7
4.7

Deposit Agreement dated as of July 6, 2006 among
Deposit Agreement dated as of July 6, 2006 among
Morgan Stanley, JPMorgan Chase Bank, N.A. and
Morgan Stanley, JPMorgan Chase Bank, N.A. and
the  holders  from  time  to  time  of  the  depositary
the  holders  from  time  to  time  of  the  depositary
receipts  described  therein  (Exhibit  4.3  to  Morgan
receipts  described  therein  (Exhibit  4.3  to  Morgan
Stanley’s  quarterly  report  on  Form  10-Q  for  the
Stanley’s  quarterly  report  on  Form  10-Q  for  the
quarter ended May 31, 2006).
quarter ended May 31, 2006).

4.8
4.8

4.9
4.9

4.10
4.10

Form of Deposit Agreement among Morgan Stanley,
Form of Deposit Agreement among Morgan Stanley,
JPMorgan Chase Bank, N.A. and the holders from
JPMorgan Chase Bank, N.A. and the holders from
time to time of the depositary receipts representing
time to time of the depositary receipts representing
interests in the Series A Preferred Stock described
interests in the Series A Preferred Stock described
therein (Exhibit 2.4 to Morgan Stanley’s Registration
therein (Exhibit 2.4 to Morgan Stanley’s Registration
Statement on Form 8-A dated July 5, 2006).
Statement on Form 8-A dated July 5, 2006).

for  Depositary  Shares,
for  Depositary  Shares,
Depositary  Receipt 
Depositary  Receipt 
representing  Floating  Rate  Non-Cumulative
representing  Floating  Rate  Non-Cumulative
Preferred  Stock,  Series A  (included  in  Exhibit  4.8
Preferred  Stock,  Series A  (included  in  Exhibit  4.8
hereto).
hereto).

Form of Deposit Agreement among Morgan Stanley,
Form of Deposit Agreement among Morgan Stanley,
The Bank of New York Mellon and the holders from
The Bank of New York Mellon and the holders from
time to time of the depositary receipts representing
time to time of the depositary receipts representing
interests in the Series E Preferred Stock described
interests in the Series E Preferred Stock described
therein (Exhibit 2.6 to Morgan Stanley’s Registration
therein (Exhibit 2.6 to Morgan Stanley’s Registration
Statement on Form 8-A dated September 27, 2013).
Statement on Form 8-A dated September 27, 2013).

4.11 Depositary  Receipt 
4.11 Depositary  Receipt 
for  Depositary  Shares,
for  Depositary  Shares,
representing 
Fixed-to-Floating  Rate  Non-
Fixed-to-Floating  Rate  Non-
representing 
Cumulative Preferred Stock, Series E (included in
Cumulative Preferred Stock, Series E (included in
Exhibit 4.10 hereto).
Exhibit 4.10 hereto).

4.12
4.12

Form of Deposit Agreement among Morgan Stanley,
Form of Deposit Agreement among Morgan Stanley,
The Bank of New York Mellon and the holders from
The Bank of New York Mellon and the holders from
time to time of the depositary receipts representing
time to time of the depositary receipts representing
interests  in  the  Series  F  Preferred  stock  described
interests  in  the  Series  F  Preferred  stock  described
therein (Exhibit 2.4 to Morgan Stanley’s Registration
therein (Exhibit 2.4 to Morgan Stanley’s Registration
Statement on Form 8-A dated December 9, 2013).
Statement on Form 8-A dated December 9, 2013).

4.13 Depositary  Receipt 
4.13 Depositary  Receipt 
for  Depositary  Shares,
for  Depositary  Shares,
representing 
Fixed-to-Floating  Rate  Non-
Fixed-to-Floating  Rate  Non-
representing 
Cumulative  Preferred  Stock,  Series  F  (included  in
Cumulative  Preferred  Stock,  Series  F  (included  in
Exhibit 4.12 hereto).
Exhibit 4.12 hereto).

4.14
4.14

Form of Deposit Agreement among Morgan Stanley,
Form of Deposit Agreement among Morgan Stanley,
The Bank of New York Mellon and the holders from
The Bank of New York Mellon and the holders from
time to time of the depositary receipts representing
time to time of the depositary receipts representing
interests in the Series H Preferred stock described
interests in the Series H Preferred stock described
therein  (Exhibit  4.6  to  Morgan  Stanley’s  current
therein  (Exhibit  4.6  to  Morgan  Stanley’s  current
report on Form 8-K dated April 29, 2014).
report on Form 8-K dated April 29, 2014).

4.15 Depositary  Receipt 
4.15 Depositary  Receipt 
for  Depositary  Shares,
for  Depositary  Shares,
representing 
Fixed-to-Floating  Rate  Non-
Fixed-to-Floating  Rate  Non-
representing 
Cumulative Preferred Stock, Series H (included in
Cumulative Preferred Stock, Series H (included in
Exhibit 4.14 hereto).
Exhibit 4.14 hereto).

4.16
4.16

Form of Deposit Agreement among Morgan Stanley,
Form of Deposit Agreement among Morgan Stanley,
The Bank of New York Mellon and the holders from
The Bank of New York Mellon and the holders from
time to time of the depositary receipts representing
time to time of the depositary receipts representing
interests  in  the  Series  I  Preferred  stock  described
interests  in  the  Series  I  Preferred  stock  described
therein (Exhibit 2.4 to Morgan Stanley’s Registration
therein (Exhibit 2.4 to Morgan Stanley’s Registration
Statement on Form 8-A dated September 17, 2014).
Statement on Form 8-A dated September 17, 2014).

4.17 Depositary  Receipt 
4.17 Depositary  Receipt 
for  Depositary  Shares,
for  Depositary  Shares,
Fixed-to-Floating  Rate  Non-
Fixed-to-Floating  Rate  Non-
representing 
representing 
Cumulative  Preferred  Stock,  Series  I  (included  in
Cumulative  Preferred  Stock,  Series  I  (included  in
Exhibit 4.16 hereto).
Exhibit 4.16 hereto).

Table of Contents

Exhibit
Exhibit

Exhibit
Exhibit

 No. Description
 No. Description
4.18
4.18

Form of Deposit Agreement among Morgan Stanley,
Form of Deposit Agreement among Morgan Stanley,
The Bank of New York Mellon and the holders from
The Bank of New York Mellon and the holders from
time to time of the depositary receipts representing
time to time of the depositary receipts representing
interests  in  the  Series  J  Preferred  Stock  described
interests  in  the  Series  J  Preferred  Stock  described
therein  (Exhibit  4.3  to  Morgan  Stanley’s  current
therein  (Exhibit  4.3  to  Morgan  Stanley’s  current
report on Form 8-K dated March 18, 2015).
report on Form 8-K dated March 18, 2015).

4.20
4.20

4.19 Depositary  Receipt 
4.19 Depositary  Receipt 
for  Depositary  Shares,
for  Depositary  Shares,
representing 
Fixed-to-Floating  Rate  Non-
representing 
Fixed-to-Floating  Rate  Non-
Cumulative  Preferred  Stock,  Series  J  (included  in
Cumulative  Preferred  Stock,  Series  J  (included  in
Exhibit 4.18 hereto).
Exhibit 4.18 hereto).
Form of Deposit Agreement among Morgan Stanley,
Form of Deposit Agreement among Morgan Stanley,
The Bank of New York Mellon and the holders from
The Bank of New York Mellon and the holders from
time to time of the depositary receipts representing
time to time of the depositary receipts representing
interests in the Series K Preferred Stock described
interests in the Series K Preferred Stock described
therein  (Exhibit  2.4  to  Morgan  Stanley’s  current
therein  (Exhibit  2.4  to  Morgan  Stanley’s  current
report on Form 8-A dated January 30, 2017).
report on Form 8-A dated January 30, 2017).

for  Depositary  Shares,
4.21 Depositary  Receipt 
for  Depositary  Shares,
4.21 Depositary  Receipt 
Fixed-to-Floating  Rate  Non-
representing 
Fixed-to-Floating  Rate  Non-
representing 
Cumulative Preferred Stock, Series K (included in
Cumulative Preferred Stock, Series K (included in
Exhibit 4.20 hereto).
Exhibit 4.20 hereto).

4.22
4.22

Form of Deposit Agreement among Morgan Stanley,
Form of Deposit Agreement among Morgan Stanley,
The Bank of New York Mellon and the holders from
The Bank of New York Mellon and the holders from
time to time of the depositary receipts representing
time to time of the depositary receipts representing
interests in the Series L Preferred Stock described
interests in the Series L Preferred Stock described
therein (Exhibit 2.4 to Morgan Stanley’s Registration
therein (Exhibit 2.4 to Morgan Stanley’s Registration
Statement on Form 8-A dated November 22, 2019).
Statement on Form 8-A dated November 22, 2019).

4.23 Depositary  Receipt 
4.23 Depositary  Receipt 

for  Depositary  Shares,
for  Depositary  Shares,
representing  4.875%  Non-Cumulative  Preferred
representing  4.875%  Non-Cumulative  Preferred
Stock, Series L (included in Exhibit 4.22 hereto).
Stock, Series L (included in Exhibit 4.22 hereto).

10.1 Amended and Restated Trust Agreement dated as of
10.1 Amended and Restated Trust Agreement dated as of
January 1, 2018 by and between Morgan Stanley and
January 1, 2018 by and between Morgan Stanley and
State Street Bank and Trust Company (Exhibit 10.1
State Street Bank and Trust Company (Exhibit 10.1
to Morgan Stanley’s quarterly report on Form 10-Q
to Morgan Stanley’s quarterly report on Form 10-Q
for the quarter ended March 31, 2018).
for the quarter ended March 31, 2018).

10.2 Amended and Restated Investor Agreement dated as
10.2 Amended and Restated Investor Agreement dated as
of June 30, 2011 by and between Morgan Stanley and
of June 30, 2011 by and between Morgan Stanley and
Mitsubishi UFJ Financial Group, Inc. (Exhibit 10.1
Mitsubishi UFJ Financial Group, Inc. (Exhibit 10.1
to  Morgan  Stanley’s  current  report  on  Form  8-K
to  Morgan  Stanley’s  current  report  on  Form  8-K
dated  June 30,  2011),  as  amended  by  Third
dated  June 30,  2011),  as  amended  by  Third
Amendment, dated October 3, 2013 (Exhibit 10.1 to
Amendment, dated October 3, 2013 (Exhibit 10.1 to
Morgan Stanley’s quarterly report on Form 10-Q for
Morgan Stanley’s quarterly report on Form 10-Q for
the quarter ended September 30, 2013) and Fourth
the quarter ended September 30, 2013) and Fourth
Amendment,  dated April 6,  2016  (Exhibit  10.1  to
Amendment,  dated April 6,  2016  (Exhibit  10.1  to
Morgan Stanley’s quarterly report on Form 10-Q for
Morgan Stanley’s quarterly report on Form 10-Q for
the quarter ended March 31, 2016).
the quarter ended March 31, 2016).

 No. Description
 No. Description
10.3† Morgan Stanley 401(k) Plan, amended and restated
10.3† Morgan Stanley 401(k) Plan, amended and restated
as  of  January 1,  2013  (Exhibit  10.6  to  Morgan
as  of  January 1,  2013  (Exhibit  10.6  to  Morgan
Stanley  annual  report  on  Form  10-K  for  the  year
Stanley  annual  report  on  Form  10-K  for  the  year
ended  December 31,  2012),  as  amended  by
ended  December 31,  2012),  as  amended  by
Amendment  (Exhibit  10.5  to  Morgan  Stanley’s
Amendment  (Exhibit  10.5  to  Morgan  Stanley’s
annual  report  on  Form  10-K  for  the  year  ended
annual  report  on  Form  10-K  for  the  year  ended
December 31,  2013), Amendment  (Exhibit 10.6  to
December 31,  2013), Amendment  (Exhibit 10.6  to
Morgan Stanley’s annual report on Form 10-K for
Morgan Stanley’s annual report on Form 10-K for
the  year  ended  December 31,  2013),  Amendment
the  year  ended  December 31,  2013),  Amendment
(Exhibit 10.5 to Morgan Stanley’s annual report on
(Exhibit 10.5 to Morgan Stanley’s annual report on
Form 10-K for the year ended December 31, 2014),
Form 10-K for the year ended December 31, 2014),
Amendment  (Exhibit  10.5  to  Morgan  Stanley’s
Amendment  (Exhibit  10.5  to  Morgan  Stanley’s
annual  report  on  Form  10-K  for  the  year  ended
annual  report  on  Form  10-K  for  the  year  ended
December 31, 2015), Amendment (Exhibit 10.4 to
December 31, 2015), Amendment (Exhibit 10.4 to
Morgan Stanley’s annual report on Form 10-K for
Morgan Stanley’s annual report on Form 10-K for
the  year  ended  December 31,  2016),  Amendment
the  year  ended  December 31,  2016),  Amendment
(Exhibit 10.4 to Morgan Stanley’s annual report on
(Exhibit 10.4 to Morgan Stanley’s annual report on
Form 10-K for the year ended December 31, 2017),
Form 10-K for the year ended December 31, 2017),
Amendment  (Exhibit  10.5  to  Morgan  Stanley’s
Amendment  (Exhibit  10.5  to  Morgan  Stanley’s
annual  report  on  Form  10-K  for  the  year  ended
annual  report  on  Form  10-K  for  the  year  ended
December 31, 2017) and Amendment (Exhibit 10.4
December 31, 2017) and Amendment (Exhibit 10.4
to Morgan Stanley’s annual report on Form 10-K for
to Morgan Stanley’s annual report on Form 10-K for
the year ended December 31, 2018).
the year ended December 31, 2018).

10.4†* Amendment to Morgan Stanley 401(k) Plan, dated
10.4†* Amendment to Morgan Stanley 401(k) Plan, dated

as of December 12, 2019.
as of December 12, 2019.

10.5† Tax Deferred Equity Participation Plan as amended
10.5† Tax Deferred Equity Participation Plan as amended
and restated as of November 26, 2007 (Exhibit 10.9
and restated as of November 26, 2007 (Exhibit 10.9
to Morgan Stanley’s annual report on Form 10-K for
to Morgan Stanley’s annual report on Form 10-K for
the fiscal year ended November 30, 2007).
the fiscal year ended November 30, 2007).

10.6† Directors’  Equity  Capital  Accumulation  Plan  as
10.6† Directors’  Equity  Capital  Accumulation  Plan  as
amended  and  restated  as  of  November  1,  2018
amended  and  restated  as  of  November  1,  2018
(Exhibit 10.6 to Morgan Stanley’s annual report on
(Exhibit 10.6 to Morgan Stanley’s annual report on
Form 10-K for the fiscal year ended December 31,
Form 10-K for the fiscal year ended December 31,
2018).
2018).

10.7† Employees’ Equity Accumulation Plan as amended
10.7† Employees’ Equity Accumulation Plan as amended
and restated as of November 26, 2007 (Exhibit 10.12
and restated as of November 26, 2007 (Exhibit 10.12
to Morgan Stanley’s annual report on Form 10-K for
to Morgan Stanley’s annual report on Form 10-K for
the fiscal year ended November 30, 2007).
the fiscal year ended November 30, 2007).

10.8† Employee  Stock  Purchase  Plan  as  amended  and
10.8† Employee  Stock  Purchase  Plan  as  amended  and
restated  as  of  February 1,  2009  (Exhibit  10.20  to
restated  as  of  February 1,  2009  (Exhibit  10.20  to
Morgan Stanley’s annual report on Form 10-K for
Morgan Stanley’s annual report on Form 10-K for
the fiscal year ended November 30, 2008).
the fiscal year ended November 30, 2008).

10.9† Morgan Stanley Supplemental Executive Retirement
10.9† Morgan Stanley Supplemental Executive Retirement
and  Excess  Plan,  amended  and  restated  effective
and  Excess  Plan,  amended  and  restated  effective
December 31,  2008  (Exhibit  10.2 
to  Morgan
December 31,  2008  (Exhibit  10.2 
to  Morgan
Stanley’s  quarterly  report  on  Form  10-Q  for  the
Stanley’s  quarterly  report  on  Form  10-Q  for  the
quarter  ended  March 31,  2009)  as  amended  by
quarter  ended  March 31,  2009)  as  amended  by
Amendment  (Exhibit  10.5  to  Morgan  Stanley’s
Amendment  (Exhibit  10.5  to  Morgan  Stanley’s
quarterly report on Form 10-Q for the quarter ended
quarterly report on Form 10-Q for the quarter ended
June 30,  2009),  Amendment  (Exhibit  10.19  to
June 30,  2009),  Amendment  (Exhibit  10.19  to
Morgan Stanley’s annual report on Form 10-K for
Morgan Stanley’s annual report on Form 10-K for
the  year  ended  December 31,  2010),  Amendment
the  year  ended  December 31,  2010),  Amendment
(Exhibit 10.3 to Morgan Stanley’s quarterly report
(Exhibit 10.3 to Morgan Stanley’s quarterly report
on Form 10-Q for the quarter ended June 30, 2011)
on Form 10-Q for the quarter ended June 30, 2011)
and Amendment (Exhibit 10.1 to Morgan Stanley’s
and Amendment (Exhibit 10.1 to Morgan Stanley’s
quarterly report on Form 10-Q for the quarter ended
quarterly report on Form 10-Q for the quarter ended
September 30, 2014).
September 30, 2014).

167

December 2019 Form 10-K

Table of Contents

Exhibit
Exhibit

 No. Description
 No. Description

10.10† 1995 Equity Incentive Compensation Plan (Annex A
10.10† 1995 Equity Incentive Compensation Plan (Annex A
to  MSG’s  proxy  statement  for  its  1996  Annual
to  MSG’s  proxy  statement  for  its  1996  Annual
Meeting  of  Stockholders)  as  amended  by
Meeting  of  Stockholders)  as  amended  by
Amendment  (Exhibit  10.39  to  Morgan  Stanley’s
Amendment  (Exhibit  10.39  to  Morgan  Stanley’s
annual report on Form 10-K for the fiscal year ended
annual report on Form 10-K for the fiscal year ended
November 30, 2000), Amendment (Exhibit 10.5 to
November 30, 2000), Amendment (Exhibit 10.5 to
Morgan Stanley’s quarterly report on Form 10-Q for
Morgan Stanley’s quarterly report on Form 10-Q for
the  quarter  ended  August 31,  2005),  Amendment
the  quarter  ended  August 31,  2005),  Amendment
(Exhibit 10.3 to Morgan Stanley’s quarterly report
(Exhibit 10.3 to Morgan Stanley’s quarterly report
on  Form  10-Q  for  the  quarter  ended  February 28,
on  Form  10-Q  for  the  quarter  ended  February 28,
2006),  Amendment  (Exhibit  10.24  to  Morgan
2006),  Amendment  (Exhibit  10.24  to  Morgan
Stanley’s annual report on Form 10-K for the fiscal
Stanley’s annual report on Form 10-K for the fiscal
year  ended  November 30,  2006)  and  Amendment
year  ended  November 30,  2006)  and  Amendment
(Exhibit 10.22 to Morgan Stanley’s annual report on
(Exhibit 10.22 to Morgan Stanley’s annual report on
Form 10-K for the fiscal year ended November 30,
Form 10-K for the fiscal year ended November 30,
2007).
2007).

10.11† Form of Deferred Compensation Agreement under
10.11† Form of Deferred Compensation Agreement under
the Pre-Tax Incentive Program 2 (Exhibit 10.12 to
the Pre-Tax Incentive Program 2 (Exhibit 10.12 to
MSG’s  annual  report  for  the  fiscal  year  ended
MSG’s  annual  report  for  the  fiscal  year  ended
November 30, 1996).
November 30, 1996).

10.12† Key  Employee  Private  Equity  Recognition  Plan
10.12† Key  Employee  Private  Equity  Recognition  Plan
(Exhibit 10.43 to Morgan Stanley’s annual report on
(Exhibit 10.43 to Morgan Stanley’s annual report on
Form 10-K for the fiscal year ended November 30,
Form 10-K for the fiscal year ended November 30,
2000).
2000).

10.13† Morgan Stanley UK Share Ownership Plan (Exhibit
10.13† Morgan Stanley UK Share Ownership Plan (Exhibit
4.1 to Morgan Stanley’s Registration Statement on
4.1 to Morgan Stanley’s Registration Statement on
Form S-8 (No. 333-146954)).
Form S-8 (No. 333-146954)).

10.14† Supplementary Deed of Participation for the Morgan
10.14† Supplementary Deed of Participation for the Morgan
Stanley  UK  Share  Ownership  Plan,  dated  as  of
Stanley  UK  Share  Ownership  Plan,  dated  as  of
November 5,  2009  (Exhibit  10.36  to  Morgan
November 5,  2009  (Exhibit  10.36  to  Morgan
Stanley’s annual report on Form 10-K for the year
Stanley’s annual report on Form 10-K for the year
ended December 31, 2009).
ended December 31, 2009).

10.15† Aircraft  Time  Sharing  Agreement,  dated  as  of
10.15† Aircraft  Time  Sharing  Agreement,  dated  as  of
January 1, 2010, by and between Corporate Services
January 1, 2010, by and between Corporate Services
Support Corp. and James P. Gorman (Exhibit 10.1 to
Support Corp. and James P. Gorman (Exhibit 10.1 to
Morgan Stanley’s quarterly report on Form 10-Q for
Morgan Stanley’s quarterly report on Form 10-Q for
the quarter ended March 31, 2010).
the quarter ended March 31, 2010).

10.16† Agreement between Morgan Stanley and James P.
10.16† Agreement between Morgan Stanley and James P.
Gorman,  dated  August 16,  2005,  and  amendment
Gorman,  dated  August 16,  2005,  and  amendment
dated December 17, 2008 (Exhibit 10.2 to Morgan
dated December 17, 2008 (Exhibit 10.2 to Morgan
Stanley’s  quarterly  report  on  Form  10-Q  for  the
Stanley’s  quarterly  report  on  Form  10-Q  for  the
quarter  ended  March 31,  2010),  as  amended  by
quarter  ended  March 31,  2010),  as  amended  by
Amendment  (Exhibit  10.25  to  Morgan  Stanley’s
Amendment  (Exhibit  10.25  to  Morgan  Stanley’s
annual  report  on  Form 10-K  for  the  year  ended
annual  report  on  Form 10-K  for  the  year  ended
December 31, 2013).
December 31, 2013).

10.17† Form  of  Restrictive  Covenant Agreement  (Exhibit
10.17† Form  of  Restrictive  Covenant Agreement  (Exhibit
10 to Morgan Stanley’s current report on Form 8-K
10 to Morgan Stanley’s current report on Form 8-K
dated November 22, 2005).
dated November 22, 2005).

10.18† Equity  Incentive  Compensation  Plan,  as  amended
10.18† Equity  Incentive  Compensation  Plan,  as  amended
and restated as of March 30, 2017 (Exhibit 10.1 to
and restated as of March 30, 2017 (Exhibit 10.1 to
Morgan Stanley’s current report on Form 8-K dated
Morgan Stanley’s current report on Form 8-K dated
May 22, 2017).
May 22, 2017).

10.19† Morgan  Stanley  2006  Notional  Leveraged  Co-
10.19† Morgan  Stanley  2006  Notional  Leveraged  Co-
Investment  Plan,  as  amended  and  restated  as  of
Investment  Plan,  as  amended  and  restated  as  of
November 28,  2008  (Exhibit  10.47  to  Morgan
November 28,  2008  (Exhibit  10.47  to  Morgan
Stanley’s annual report on Form 10-K for the fiscal
Stanley’s annual report on Form 10-K for the fiscal
year ended November 30, 2008).
year ended November 30, 2008).

December 2019 Form 10-K

168

Exhibit
Exhibit

 No. Description
 No. Description
10.20† Form of Award Certificate under the 2006 Notional
10.20† Form of Award Certificate under the 2006 Notional
Leveraged  Co-Investment  Plan  (Exhibit  10.7  to
Leveraged  Co-Investment  Plan  (Exhibit  10.7  to
Morgan Stanley’s quarterly report on Form 10-Q for
Morgan Stanley’s quarterly report on Form 10-Q for
the quarter ended February 29, 2008).
the quarter ended February 29, 2008).

10.21† Morgan  Stanley  2007  Notional  Leveraged  Co-
10.21† Morgan  Stanley  2007  Notional  Leveraged  Co-
Investment  Plan,  amended  as  of  June 4,  2009
Investment  Plan,  amended  as  of  June 4,  2009
(Exhibit 10.6 to Morgan Stanley’s quarterly report
(Exhibit 10.6 to Morgan Stanley’s quarterly report
on Form 10-Q for the quarter ended June 30, 2009).
on Form 10-Q for the quarter ended June 30, 2009).
10.22† Form of Award Certificate under the 2007 Notional
10.22† Form of Award Certificate under the 2007 Notional
Leveraged  Co-Investment  Plan 
for  Certain
for  Certain
Leveraged  Co-Investment  Plan 
Management Committee Members (Exhibit 10.8 to
Management Committee Members (Exhibit 10.8 to
Morgan Stanley’s quarterly report on Form 10-Q for
Morgan Stanley’s quarterly report on Form 10-Q for
the quarter ended February 29, 2008).
the quarter ended February 29, 2008).

10.23† Morgan  Stanley  Compensation  Incentive  Plan
10.23† Morgan  Stanley  Compensation  Incentive  Plan
(Exhibit 10.54 to Morgan Stanley’s annual report on
(Exhibit 10.54 to Morgan Stanley’s annual report on
Form 10-K for the fiscal year ended November 30,
Form 10-K for the fiscal year ended November 30,
2008).
2008).

10.24† Morgan  Stanley  Schedule  of  Non-Employee
10.24† Morgan  Stanley  Schedule  of  Non-Employee
Directors  Annual  Compensation,  effective  as  of
Directors  Annual  Compensation,  effective  as  of
November 1,  2018  (Exhibit  10.24  to  Morgan
November 1,  2018  (Exhibit  10.24  to  Morgan
Stanley’s annual report on Form 10-K for the fiscal
Stanley’s annual report on Form 10-K for the fiscal
year ended December 31, 2018).
year ended December 31, 2018).

10.25† Morgan Stanley UK Limited Alternative Retirement
10.25† Morgan Stanley UK Limited Alternative Retirement
Plan, dated as of October 8, 2009 (Exhibit 10.2 to
Plan, dated as of October 8, 2009 (Exhibit 10.2 to
Morgan Stanley’s quarterly report on Form 10-Q for
Morgan Stanley’s quarterly report on Form 10-Q for
the quarter ended March 31, 2013).
the quarter ended March 31, 2013).

10.26† Agreement  between  Morgan  Stanley  and  Colm
10.26† Agreement  between  Morgan  Stanley  and  Colm
Kelleher,  dated  January 5,  2015  (Exhibit  10.1  to
Kelleher,  dated  January 5,  2015  (Exhibit  10.1  to
Morgan Stanley’s quarterly report on Form 10-Q for
Morgan Stanley’s quarterly report on Form 10-Q for
the quarter ended March 31, 2015).
the quarter ended March 31, 2015).

10.27† Description  of  Operating  Committee  Medical
10.27† Description  of  Operating  Committee  Medical
Coverage  (Exhibit  10.2 
to  Morgan  Stanley’s
to  Morgan  Stanley’s
Coverage  (Exhibit  10.2 
quarterly report on Form 10-Q for the quarter ended
quarterly report on Form 10-Q for the quarter ended
March 31, 2015).
March 31, 2015).

10.28† Form  of  Award  Certificate  for  Discretionary
10.28† Form  of  Award  Certificate  for  Discretionary
Retention Awards of Stock Units. (Exhibit 10.33 to
Retention Awards of Stock Units. (Exhibit 10.33 to
Morgan Stanley’s annual report on Form 10-K for
Morgan Stanley’s annual report on Form 10-K for
the year ended December 31, 2017).
the year ended December 31, 2017).

10.29† Form  of  Award  Certificate  for  Discretionary
10.29† Form  of  Award  Certificate  for  Discretionary
the  Morgan  Stanley
Retention  Awards  under 
Retention  Awards  under 
the  Morgan  Stanley
Compensation  Incentive  Plan.  (Exhibit  10.34  to
Compensation  Incentive  Plan.  (Exhibit  10.34  to
Morgan Stanley’s annual report on Form 10-K for
Morgan Stanley’s annual report on Form 10-K for
the year ended December 31, 2017).
the year ended December 31, 2017).

10.30† Form of Award Certificate for Long-Term Incentive
10.30† Form of Award Certificate for Long-Term Incentive
Program Awards (Exhibit 10.30 to Morgan Stanley’s
Program Awards (Exhibit 10.30 to Morgan Stanley’s
annual report on Form 10-K for the fiscal year ended
annual report on Form 10-K for the fiscal year ended
December 31, 2018).
December 31, 2018).

10.31† Memorandum 
10.31† Memorandum 

to  Colm  Kelleher  Regarding
to  Colm  Kelleher  Regarding
Relocation  to  New York,  dated  February 25,  2016
Relocation  to  New York,  dated  February 25,  2016
(Exhibit 10.2 to Morgan Stanley’s quarterly report
(Exhibit 10.2 to Morgan Stanley’s quarterly report
on Form 10-Q for the quarter ended March 31, 2016).
on Form 10-Q for the quarter ended March 31, 2016).

Subsidiaries of Morgan Stanley.
Subsidiaries of Morgan Stanley.

21*
21*
23.1* Consent of Deloitte & Touche LLP.
23.1* Consent of Deloitte & Touche LLP.

24
24

Powers of Attorney (included on signature page).
Powers of Attorney (included on signature page).

31.1* Rule  13a-14(a)  Certification  of  Chief  Executive
31.1* Rule  13a-14(a)  Certification  of  Chief  Executive

Officer.
Officer.

Table of Contents

Exhibit

 No. Description
31.2* Rule  13a-14(a)  Certification  of  Chief  Financial

Officer.

32.1** Section 1350  Certification  of  Chief  Executive

Officer.

32.2** Section 1350  Certification  of  Chief  Financial

Officer.

101

104

Interactive  Data  Files  pursuant  to  Rule  405  of
Regulation  S-T  formatted  in  Inline  eXtensible
Business Reporting Language (“Inline XBRL”).

Cover Page Interactive Data File (formatted in Inline
XBRL and contained in Exhibit 101).

1. For purposes of this Exhibit Index, references to “The Bank of New York” mean in
some instances the entity successor to JPMorgan Chase Bank, N.A. or J.P. Morgan
Trust Company, National Association; references to “JPMorgan Chase Bank, N.A.”
mean the entity formerly known as The Chase Manhattan Bank, in some instances
as the successor to Chemical Bank; references to “J.P. Morgan Trust Company, N.A.”
mean the entity formerly known as Bank One Trust Company, N.A., as successor to
The First National Bank of Chicago.

*

Filed herewith.

** Furnished herewith.
† Management  contract  or  compensatory  plan  or
arrangement required to be filed as an exhibit to this Form
10-K pursuant to Item 15(b).

Note: Other instruments defining the rights of holders of long-
term debt securities of Morgan Stanley and its subsidiaries are
omitted pursuant to Section (b)(4)(iii) of Item 601 of Regulation
S-K. Morgan Stanley hereby agrees to furnish copies of these
instruments to the U.S. Securities and Exchange Commission
upon request.

Form 10-K Summary

None.

169

December 2019 Form 10-K

Table of Contents

Signatures

Signature
Signature

Title
Title

Pursuant  to  the  requirements  of  Section  13  or  15(d)  of  the
Securities Exchange Act of 1934, the Registrant has duly caused
this  report  to  be  signed  on  its  behalf  by  the  undersigned,
thereunto duly authorized, on February 27, 2020.

MORGAN STANLEY
(REGISTRANT)
By:

/s/ JAMES P. GORMAN

/s/ THOMAS H. GLOCER
/s/ THOMAS H. GLOCER

Director
Director

(Thomas H. Glocer)
(Thomas H. Glocer)

/s/ ROBERT H. HERZ
/s/ ROBERT H. HERZ

(Robert H. Herz)
(Robert H. Herz)

Director
Director

(James P. Gorman)
Chairman of the Board and Chief Executive Officer

/s/ NOBUYUKI HIRANO
/s/ NOBUYUKI HIRANO

Director
Director

(Nobuyuki Hirano)
(Nobuyuki Hirano)

POWER OF ATTORNEY

/s/ STEPHEN J. LUCZO
/s/ STEPHEN J. LUCZO

Director
Director

We,  the  undersigned,  hereby  severally  constitute  Jonathan
Pruzan, Eric F. Grossman and Martin M. Cohen, and each of
them singly, our true and lawful attorneys with full power to
them and each of them to sign for us, and in our names in the
capacities indicated below, any and all amendments to the annual
report  on  Form  10-K  filed  with  the  Securities  and  Exchange
Commission, hereby ratifying and confirming our signatures as
they  may  be  signed  by  our  said  attorneys  to  any  and  all
amendments to said annual report on Form 10-K.

Pursuant to the requirements of the Securities Exchange Act of
1934, this report has been signed below by the following persons
on behalf of the Registrant and in the capacities indicated on the
27th day of February, 2020.

(Stephen J. Luczo)
(Stephen J. Luczo)

/s/ JAMI MISCIK
/s/ JAMI MISCIK

(Jami Miscik)
(Jami Miscik)

Director
Director

/s/ DENNIS M. NALLY
/s/ DENNIS M. NALLY

Director
Director

(Dennis M. Nally)
(Dennis M. Nally)

/s/ TAKESHI
/s/ TAKESHI
OGASAWARA
OGASAWARA

(Takeshi Ogasawara)
(Takeshi Ogasawara)

Director
Director

/s/ HUTHAM S. OLAYAN
/s/ HUTHAM S. OLAYAN

Director
Director

Signature
Signature

Title
Title

(Hutham S. Olayan)
(Hutham S. Olayan)

/s/ JAMES P. GORMAN
/s/ JAMES P. GORMAN

Chairman of the Board and
Chairman of the Board and
Chief Executive Officer
Chief Executive Officer

/s/ MARY L. SCHAPIRO
/s/ MARY L. SCHAPIRO

Director
Director

(James P. Gorman)
(James P. Gorman)

(Principal Executive Officer)
(Principal Executive Officer)

(Mary L. Schapiro)
(Mary L. Schapiro)

/s/ JONATHAN PRUZAN
/s/ JONATHAN PRUZAN

Executive Vice President and
Executive Vice President and
Chief Financial Officer
Chief Financial Officer

(Jonathan Pruzan)
(Jonathan Pruzan)

(Principal Financial Officer)
(Principal Financial Officer)

/s/ PAUL C. WIRTH
/s/ PAUL C. WIRTH

Deputy Chief Financial Officer
Deputy Chief Financial Officer

(Paul C. Wirth)
(Paul C. Wirth)

(Principal Accounting Officer)
(Principal Accounting Officer)

/s/ PERRY M. TRAQUINA
/s/ PERRY M. TRAQUINA

(Perry M. Traquina)
(Perry M. Traquina)

/s/ RAYFORD WILKINS,
/s/ RAYFORD WILKINS,
JR.
JR.

(Rayford Wilkins, Jr.)
(Rayford Wilkins, Jr.)

Director
Director

Director
Director

/s/ ELIZABETH CORLEY
/s/ ELIZABETH CORLEY

Director
Director

(Elizabeth Corley)
(Elizabeth Corley)

/s/ ALISTAIR DARLING
/s/ ALISTAIR DARLING

Director
Director

(Alistair Darling)
(Alistair Darling)

December 2019 Form 10-K

S-1