A. The Plaintiff Korea Standards Bank Holdings Co., Ltd. (hereinafter “Plaintiff Financial Holding Company”) is a financial holding company under Article 2(1) of the former Financial Holding Companies Act (Amended by Act No. 12099, Aug. 13, 2013); it holds 100% of the shares of the Plaintiff Korea Standards Bank (hereinafter “Plaintiff Bank”); and the Plaintiffs apply the consolidated tax return system pursuant to Article 76-8 of the former Corporate Tax Act (Amended by Act No. 11607, Jan. 1, 2013); and the Plaintiff filed and pays the consolidated corporate tax from the business year 2010 by applying the consolidated tax return system to the Plaintiff Financial Holding Company.

B. The Plaintiff bank provides credit to the obligor, who is the customer of the Plaintiff bank, in accordance with the basic terms and conditions of bank credit transactions as collateral with a credit guarantee certificate issued by the Credit Guarantee Fund, the Korea Technology Credit Guarantee Fund, the Korea Technology Credit Guarantee Fund, the Korea Housing Finance Corporation, the Korea Housing Finance Corporation (hereinafter referred to as the “Credit Guarantee Agency”), and the Seoul Guarantee Insurance Corporation (hereinafter referred to as the “Seoul Guarantee Insurance”), and the Seoul Guarantee Insurance Co., Ltd. (hereinafter referred to as the “Credit Guarantee Agency, etc.”), and if a credit guarantee event, such as the obligor’s default, etc., occurs

In such cases, the credit guarantee agency, etc. shall examine the validity of the above claim and notify the result thereof to the Plaintiff bank, and upon receipt of such notification, the Plaintiff bank shall provide the credit guarantee agency with documents such as a certificate of subrogation and receive the principal and interest

C. As a result of the consolidated investigation of corporate tax against the Plaintiffs from February 22, 2013 to August 10, 2013, the director of the Seoul Regional Tax Office: (a) accounts for the collection of principal at will in violation of Article 56 of the Enforcement Rule of the Corporate Tax Act, even though the Plaintiffs did not have agreed on the order of appropriation; and (b) collected the entire interest first.