FINANCIAL INSTITUTIONS

CREDIT OPINION30 December 2019

Update

RATINGS

Banco de Bogota S.A.Domicile Bogota, Distrito Capital,

Colombia

Long Term CRR Baa2

Type LT Counterparty RiskRating - Fgn Curr

Outlook Not Assigned

Long Term Debt Baa2

Type Senior Unsecured - FgnCurr

Outlook Negative

Long Term Deposit Baa2

Type LT Bank Deposits - FgnCurr

Outlook Negative

Please see the ratings section at the end of this reportfor more information. The ratings and outlook shownreflect information as of the publication date.

Contacts

Rodrigo MarimonBernales

+54.115.129.2651

Associate Analystrodrigo.bernales@moodys.com

Diego Kashiwakura,CFA

+55.11.3043.7316

VP-Senior Analystdiego.kashiwakura@moodys.com

Felipe Carvallo +52.55.1253.5738VP-Sr Credit Officerfelipe.carvallo@moodys.com

» Contacts continued on last page

CLIENT SERVICES

Americas 1-212-553-1653

Asia Pacific 852-3551-3077

Japan 81-3-5408-4100

EMEA 44-20-7772-5454

Banco de Bogota S.A.Update to credit analysis

SummaryOn 6 November 2019, following the recent announcement of the upcoming acquisitionof Multi Financial Group (MFG) in Panama, we affirmed Banco de Bogotá S.A's (Banco deBogotá) ratings and maintained the negative outlook on its supported ratings.1. Moody'saffirmation of Banco de Bogotá's ratings reflects the bank's strong earnings and goodaccess to core deposit funding. In addition, the affirmation reflects Moody's expectationthat the bank's capitalization ratio, measured as tangible common equity (TCE) relative torisk weighted assets (RWA), resulting from the transaction will largely remain within the8.3-9.3% range.

We affirmed the bank's ratings considering the positive trends in the bank's Colombianportfolios. Asset quality remains sound as the bank’s consumer portfolios have improved asresult of an improving economy and prudent origination. Banco de Bogota's Baa2 depositratings incorporates our assessment of very high likelihood of government support, if needed,resulting in a two-notch uplift from its ba1 BCA.

Exhibit 1

Rating Scorecard – Key Financial RatiosSeptember 2019 scorecard ratios

3.0% 9.2% 1.8% 18.6% 26.4%

0%

5%

10%

15%

20%

25%

30%

0%

2%

4%

6%

8%

10%

12%

14%

16%

Asset Risk:Problem Loans/

Gross Loans

Capital:Tangible Common

Equity/Risk-WeightedAssets

Profitability:Net Income/

Tangible Assets

Funding Structure:Market Funds/

Tangible BankingAssets

Liquid Resources:Liquid BankingAssets/TangibleBanking Assets

Solvency Factors (LHS) Liquidity Factors (RHS)

Banco de Bogota S.A. (BCA: ba1) Median ba1-rated banks

So

lve

ncy F

acto

rs

Liq

uid

ity F

acto

rs

Source: Moody's Investors Service

MOODY'S INVESTORS SERVICE FINANCIAL INSTITUTIONS

Credit challenges

» Rising asset risk due to difficult operating environments in more volatile Central American portfolio

» Though capitalization has improved substantially it remains low by regional and global standards

Credit strengths

» Resilient earnings with contained credit costs

» Good access to core deposit funding

Outlook

» The negative outlook on Banco de Bogotá's ratings incorporates its large presence in potentially more volatile Central Americanmarkets, which continues to expose Banco de Bogotá's assets and earnings to increased risks that could lead to downward pressureson its baseline credit assessment. Banco de Bogotá's proposed acquisition of MFG in Panama is credit positive because it adds anattractive asset in a more stable operating environment. Nevertheless, the increased asset exposure to Panama will likely not offsetthe deteriorating operating conditions in both Costa Rica and Nicaragua, which account for combined 16% of Banco de Bogotá'sloans, and which are incorporated in Banco de Bogotá's weighted Macro Profile at “Moderate -”.

Factors that could lead to an upgrade

» Banco de Bogotá's ratings are unlikely to face upward pressures because they have a negative outlook. However, the outlook couldbe stabilized provided by the operating environment in Costa Rica and Nicaragua and asset quality in those countries stabilize aswell, and the bank´s exposures to those countries decline in line with current expectations.

Factors that could lead to a downgrade

» Banco de Bogotá's supported ratings are positioned at the same level of sovereign bond rating and will likely be downgraded ifColombia's sovereign rating is lowered.

» Banco de Bogota's ratings could also be downgraded if the operating environment in Central America, specifically Costa Rica and/or Nicaragua, deteriorates further, leading to increased delinquencies and credit costs, or if the bank´s exposures to those countriesincrease.

» The ratings could also face downward pressure if the bank´s capital ratio weakens, or if the bank experiences higher-than-expecteddelinquencies and credit costs steaming from its exposures to large troubled Colombian corporates.

This publication does not announce a credit rating action. For any credit ratings referenced in this publication, please see the ratings tab on the issuer/entity page onwww.moodys.com for the most updated credit rating action information and rating history.

2 30 December 2019 Banco de Bogota S.A.: Update to credit analysis

MOODY'S INVESTORS SERVICE FINANCIAL INSTITUTIONS

Please note that in the exhibit below, chart for key indicators, the figures for December 2015 have been adjusted excludingCorficolombiana and Casa de Bolsa for comparative purposes between 2016 and 2015.

Key indicators

Exhibit 2

Banco de Bogota S.A. (Consolidated Financials) [1]

09-192 12-182 12-172 12-162 12-152 CAGR/Avg.3

Total Assets (COP Billion) 173,075.8 163,117.0 149,203.6 141,245.2 136,663.6 6.54

Total Assets (USD Million) 49,756.5 50,228.5 49,992.8 47,050.4 43,050.4 3.94

Tangible Common Equity (COP Billion) 13,359.4 12,225.1 11,341.1 10,544.9 9,744.5 8.84

Tangible Common Equity (USD Million) 3,840.6 3,764.5 3,800.0 3,512.6 3,069.6 6.24

Problem Loans / Gross Loans (%) 3.0 2.8 2.4 1.7 1.5 2.35

Tangible Common Equity / Risk Weighted Assets (%) 9.3 9.2 9.0 8.9 7.8 8.86

Problem Loans / (Tangible Common Equity + Loan Loss Reserve) (%) 18.4 17.7 16.9 12.9 11.6 15.55

Net Interest Margin (%) 4.8 4.9 5.0 4.8 4.5 4.85

PPI / Average RWA (%) 4.6 4.7 4.5 6.1 3.5 4.76

Net Income / Tangible Assets (%) 1.8 2.0 1.5 3.3 1.6 2.05

Cost / Income Ratio (%) 51.7 51.2 53.1 44.9 55.4 51.35

Market Funds / Tangible Banking Assets (%) 18.0 18.6 17.8 19.4 21.4 19.05

Liquid Banking Assets / Tangible Banking Assets (%) 25.5 26.3 24.0 22.9 24.0 24.55

Gross Loans / Due to Customers (%) 100.2 101.1 101.4 103.6 103.2 101.95

[1]All figures and ratios are adjusted using Moody's standard adjustments. [2]Basel II; IFRS. [3]May include rounding differences due to scale of reported amounts. [4]Compound AnnualGrowth Rate (%) based on time period presented for the latest accounting regime. [5]Simple average of periods presented for the latest accounting regime. [6]Simple average of Basel IIperiods presented.Source: Moody's Investors Service; Company Filings

ProfileBanco de Bogotá is a privately owned universal bank in Colombia. It provides individuals and corporate customers with deposit andlending, financing, foreign exchange, private banking, pension fund administration, fiduciary, and treasury products and services. As ofSeptember 2019, it was the third-largest Colombian commercial bank in terms of loans (11.7% market share) and the second-largest interm of assets (13.5%). As of September 2019, it reported a consolidated asset base of COP173.1 trillion. 2.

Banco de Bogotá's main shareholder is Grupo Aval Acciones y Valores S.A. (Grupo Aval), Colombia’s largest financial conglomerate,which owns 68.7% of its total share capital. Banco de Bogotá consolidates the largest bank in Central America, BAC International Bank,Inc as it owns 100% of that company.

Detailed credit considerationsRising asset risk due to difficult operating environments in more volatile Central American portfolioWhile Banco de Bogotá holds the second largest branch network in Colombia (Baa2, Stable), that represents 51.2% of the total loanportfolio, the bank has a significant presence in Central America, which exposes the bank to more volatile and weaker economicenvironments. The countries in which the bank has expositions include: Costa Rica (B1, Negative; 13.81% of gross loans), Panama(Baa1, Stable; 11.81%), Guatemala (Ba1, Stable 9.13%), Honduras (B1 Stable, 6.05%), El Salvador (B3 Stable, 5.42%) and Nicaragua (B2Negative 2.59%). The bank presents a fairly balanced portfolio, although commercial lending represents the largest portion of totalloans (57.8%), followed by consumer (28.5%) and mortgage (13.3%).

Decreasing asset risks derives from improving economic conditions in Central America. Although economic activity slowed downin Central America during the first half of 2019, most economies showed a recovery in the second half of the year and have growthprospects for 2020: Panama has experienced accelerated economic activity with very strong growth projections of 4.3% for 2020;Guatemala’s economy is expected to accelerate 3.4% this year; Honduras experienced a growth in remittances which drove privateconsumption; Costa Rica was able to gradually assimilate the reform changes without disturbing the economy and recently appointeda new finance minister, Rodrigo Chaves, that will pay close attention to macroeconomic stability. Regardless of the weakeningoperating conditions in Nicaragua, Banco de Bogota has been consistently reducing its presence in the country from 5% exposure in

3 30 December 2019 Banco de Bogota S.A.: Update to credit analysis

MOODY'S INVESTORS SERVICE FINANCIAL INSTITUTIONS

2018 to 3% in September 2019 and stopping new originations. Furthermore, Banco de Bogota recently acquired Multi Financial GroupInc. in Panama, and with that acquisition, almost 70% of the bank’s portfolio will be in investment grade countries.

Asset risk may arise from the bank's exposures in Costa Rica. The bank continues to have a very strong franchise in the country, beingthe largest nongovernment owned commercial bank in the country with its local franchise of Bac San José. Nonperforming loan (NPLs)ratio in Costa Rica deteriorated because of an increase in the NPL ratio for the housing portfolio of the country. This increase cameabout as an effect of higher personal income taxes that were implemented during the third quarter of the year. Additionally, the bankcontinues to be exposed to exchange rate shocks, mostly an issue in the dollar denominated loan exposures local currency earners.

Positive trends in the bank's Colombian portfolio are consolidating though. Banco de Bogotá has improved the quality of loans in itsconsumer portfolio, benefiting from the recovery of Colombian economy and the amelioration of the individual’s repayment capacity.While, in recent past, it has been exposed to the large deteriorated corporates such as Electrificadora del Caribe S.A. E.S.P., the loanis fully recognized as NPL and fully provisioned, because of that we do not expect further deterioration from this particular exposure.Similarly, the bank’s exposure to Concesionaria Ruta del Sol S.A.S. II (CRDS II), a highway construction project that was paralyzedbecause a corruption scandal involving Brazil’s Odebrecht Engenharia e Construção S.A., has been provisioned for the most part (86.2%as of September 2019) and the bank is committed to provisioning the exposure to 100% by the end of this year.

Finally, we expect that its exposure on Bogota's mass transportation system (Sistema Integrado de Transporte de Bogotá, SITP) couldadd some more basis points to the total NPL ratio, depending how the new plan to solve the structural problems of SITP place out.

Resilient earnings with contained credit costsThe affirmation of our ratings encompasses our expectation that the bank will sustain net income above 2.0% in the next 12 to 18months. Regardless of the increase in provisions required for Ruta del Sol, the net cost of risk in 2019 will be around 2.5%. During 2020the ratio will most likely drop into the 2.2% -2.3% range.

The bank's exposure to SITP amounts to USD104 million, which is likely to have a longer term resolution as the new plans to solvestructural problems in the public transportation service should be tested and prove efficient. The bank continue to show different levelsof provisioning depending on the credit quality of SITP supplier but in average the provisioning level remains at 40%.

Capitalization remains low by regional and global standardsThe bank's tangible common equity to risk weighted assets (TCE / RWA) was around 9.2% as of September 2019 slightly higher thanthe 9.1% posted a year ago. While the bank restarted to grow at more accelerated pace, total loan growth remained moderate at 13.1%.This coupled with the bank's earnings retention underpinned the increase in capital.

To the extent that Banco de Bogotá's growth pace remains moderated and dividend payout policy does not materially change for along time, the bank is expected to maintain stable capital ratios above 8.3% of TCE/RWA. However this level continue to be low whencompared with similar rated peers outside Colombia.

Good access to core fundingBecause of its strong core deposit base in all the markets in which it operates, Banco de Bogotá's reliance on market funds is relativelyreduced. Further, the bank has been showing a very stable liquidity at 25.5% of total banking assets (as of September 2019), positioningat stronger levels. Also, we note that the exposure to sovereign bonds in Central America represents less than 10% of total liquid assets.

Banco de Bogotá's weighted Macro Profile of “Moderate -” reflects its exposure to the lower operating environments ofCentral AmericaColombia's Macro Profile is “Moderate+” and represents around 51% of the bank's loan book, while its remaining operations arefocused in Central America including Costa Rica (Macro Profile of “Weak +”), Panama (Moderate), Guatemala (Weak) and El Salvador(Weak-), as well as Honduras and Nicaragua.

Colombia's “Moderate +” macro profile reflects the country's relatively large and resilient economy and history of predictablepolicymaking, balanced against a relatively high dependence on commodities and sensitivity to trade shocks, and borrowerconcentration in the banking system.

4 30 December 2019 Banco de Bogota S.A.: Update to credit analysis

MOODY'S INVESTORS SERVICE FINANCIAL INSTITUTIONS

Notwithstanding some fiscal tightening coupled with tight monetary policy, the economy continued to expand. Nevertheless, growthpotential will remain lower than it was in the past given our expectation that oil prices will remain relatively low by recent historicalstandards.

Despite high exposure to terms of trade shocks, external vulnerabilities are limited by the country´s adequate foreign exchange buffersand access to a sizeable credit line from the IMF. Moreover, the effectiveness of the government´s policy response to recent commodityshocks illustrates the country´s moderate institutional strength. In line with lower economic growth, credit growth has deceleratedsubstantially, and credit to GDP remains relatively modest.

While banks are largely deposit funded, a substantial portion of these are provided by institutions, leaving banks potentially vulnerableto funding concentration risk. At the same time, high concentration in the banking system itself supports banks' pricing power andlending spreads

Environmental, social and governance considerationsBanco de Bogota’s exposure to Environmental risks is low, consistent with our general assessment for the global banking sector. See ourenvironmental risk heat maps for further information.

Overall, we consider banks to face moderate social risks. The most relevant social risks for banks arise from the way they interact withtheir customers. Social risks are particularly high in the area of data security and customer privacy, which is partly mitigated by sizeabletechnology investments and banks’ long track record of handling sensitive client data. Fines and reputational damage due to productmis-selling or other types of misconduct is a further social risk. Social trends are also relevant in a number of areas, such as shiftingcustomer preferences towards digital banking services increasing information technology cost, aging population concerns in severalcountries impacting demand for financial services or socially driven policy agendas that may translate into regulation that affectsbanks’ revenue base. See our social heat maps for further information.

Governance is highly relevant for Banco de Bogota, as it is to all players in the banking industry. Corporate governance weaknesses canlead to a deterioration in a bank’s credit quality, while governance strengths can benefit a bank’s credit profile. Governance risks arelargely internal rather than externally driven, and for Banco de Bogota we do not have any particular governance concerns [with onlyminor control issues and governance shortfalls identified in recent years remediated in the normal course of business]. Nonetheless,corporate governance remains a key credit consideration and requires ongoing monitoring.

Support and structural considerationsGovernment support considerationsMoody's assessment of a very high likelihood of government support for Banco de Bogotá's deposits and senior unsecured debt reflectsits large market share of deposits in Colombia and hence the material systemic consequences that would result from an unsupportedfailure. Therefore, its Baa2 global long-term deposit rating benefits from a two-notch uplift from its ba1 BCA.

Foreign Currency Debt RatingMoody's assigns a Ba2 long-term foreign currency subordinated debt rating to the bank's ten-year USD500 million subordinate debtissuance due 19 February 2023 and ten-year USD1.1 billion subordinated debt issuance due 12 May 20263

Counterparty Risk AssessmentCR Assessments are opinions of how counterparty obligations are likely to be treated if a bank fails and are distinct from debt anddeposit ratings in that they (1) consider only the risk of default rather than both the likelihood of default and the expected financial losssuffered in the event of default and (2) apply to counterparty obligations and contractual commitments rather than debt or depositinstruments. The CR assessment is an opinion of the counterparty risk related to a bank's covered bonds, contractual performanceobligations (servicing), derivatives (e.g., swaps), letters of credit, guarantees and liquidity facilities.

Banco de Bogotá's long- and short-term CR Assessments are positioned at Baa2(cr)/Prime-2(cr)

The CR assessment is positioned at Baa2(cr), which is two notches above its Adjusted BCA of ba1 and, therefore, aligned with seniorunsecured and deposit ratings.

5 30 December 2019 Banco de Bogota S.A.: Update to credit analysis

MOODY'S INVESTORS SERVICE FINANCIAL INSTITUTIONS

Counterparty Risk Rating (CRR)Moody’s Counterparty Risk Ratings are opinions of the ability of entities to honor the uncollateralized portion of non-debt counterpartyfinancial liabilities (CRR liabilities) and also reflect the expected financial losses in the event such liabilities are not honored. CRRliabilities typically relate to transactions with unrelated parties. Examples of CRR liabilities include the uncollateralized portion ofpayables arising from derivatives transactions and the uncollateralized portion of liabilities under sale and repurchase agreements. CRRsare not applicable to funding commitments or other obligations associated with covered bonds, letters of credit, guarantees, servicerand trustee obligations, and other similar obligations that arise from a bank performing its essential operating functions.

The CRR for Banco de Bogotá and its rated branches is Baa2/P-2.

About Moody's Bank ScorecardOur Scorecard is designed to capture, express and explain in summary form our Rating Committee's judgment. When read inconjunction with our research, a fulsome presentation of our judgment is expressed. As a result, the output of our Scorecardmay materially differ from that suggested by raw data alone (though it has been calibrated to avoid the frequent need for strongdivergence). The Scorecard output and the individual scores are discussed in rating committees and may be adjusted up or down toreflect conditions specific to each rated entity.

6 30 December 2019 Banco de Bogota S.A.: Update to credit analysis

MOODY'S INVESTORS SERVICE FINANCIAL INSTITUTIONS

Rating methodology and scorecard factors

Exhibit 3

Banco de Bogota S.A.

Macro FactorsWeighted Macro Profile Moderate

-100%

Factor HistoricRatio

InitialScore

ExpectedTrend

Assigned Score Key driver #1 Key driver #2

SolvencyAsset RiskProblem Loans / Gross Loans 3.0% baa3 ←→ baa3 Quality of assets

CapitalTangible Common Equity / Risk Weighted Assets(Basel II)

9.3% b1 ↓ b2 Risk-weightedcapitalisation

ProfitabilityNet Income / Tangible Assets 1.8% baa2 ↑ baa1 Expected trend

Combined Solvency Score ba1 ba1LiquidityFunding StructureMarket Funds / Tangible Banking Assets 18.6% ba1 ←→ ba1 Deposit quality

Liquid ResourcesLiquid Banking Assets / Tangible Banking Assets 26.3% ba1 ←→ ba1 Quality of

liquid assetsCombined Liquidity Score ba1 ba1Financial Profile ba1Qualitative Adjustments Adjustment

Business Diversification 0Opacity and Complexity 0Corporate Behavior 0

Total Qualitative Adjustments 0Sovereign or Affiliate constraint Baa2BCA Scorecard-indicated Outcome - Range baa3 - ba2Assigned BCA ba1Affiliate Support notching 0Adjusted BCA ba1

Instrument Class Loss GivenFailure notching

Additionalnotching

Preliminary RatingAssessment

GovernmentSupport notching

Local CurrencyRating

ForeignCurrency

RatingCounterparty Risk Rating 1 0 baa3 1 Baa2 Baa2Counterparty Risk Assessment 1 0 baa3 (cr) 1 Baa2(cr)Deposits 0 0 ba1 2 Baa2 Baa2Senior unsecured bank debt 0 0 ba1 2 Baa2Dated subordinated bank debt -1 0 ba2 0 Ba2[1]Where dashes are shown for a particular factor (or sub-factor), the score is based on non-public information.Source: Moody’s Investors Service

7 30 December 2019 Banco de Bogota S.A.: Update to credit analysis

MOODY'S INVESTORS SERVICE FINANCIAL INSTITUTIONS

Ratings

Exhibit 4

Category Moody's RatingBANCO DE BOGOTA S.A.

Outlook NegativeCounterparty Risk Rating Baa2/P-2Bank Deposits Baa2/P-2Baseline Credit Assessment ba1Adjusted Baseline Credit Assessment ba1Counterparty Risk Assessment Baa2(cr)/P-2(cr)Senior Unsecured Baa2Subordinate Ba2

PARENT: GRUPO AVAL ACCIONES Y VALORES S.A.

Outlook NegativeIssuer Rating Ba2ST Issuer Rating NP

BAC INTERNATIONAL BANK, INC

Outlook NegativeCounterparty Risk Rating Baa2/P-2Bank Deposits Baa3/P-3Baseline Credit Assessment baa3Adjusted Baseline Credit Assessment baa3Counterparty Risk Assessment Baa2(cr)/P-2(cr)

Source: Moody's Investors Service

8 30 December 2019 Banco de Bogota S.A.: Update to credit analysis

MOODY'S INVESTORS SERVICE FINANCIAL INSTITUTIONS

Endnotes1 Please see or release entitled:Moody's affirms Banco de Bogotá and Aval's ratings, following acquisition announcement; outlook negative

2 Total assets in the key indicators chart differ because they are adjusted by deducting the goodwill attributed to the non controlling interest, this is aMoody's standard adjustment

3 See Moody's Press Releases titled “Moody's assigns Ba2 to Banco de Bogotá 's proposed subordinated debt; rating on review for downgrade,” 2 May 2016and “Moody's continues to rate Banco de Bogotá's subordinated debt Ba2 following reopening,” 1 November 2016.

9 30 December 2019 Banco de Bogota S.A.: Update to credit analysis

MOODY'S INVESTORS SERVICE FINANCIAL INSTITUTIONS

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Additional terms for Japan only: Moody's Japan K.K. (“MJKK”) is a wholly-owned credit rating agency subsidiary of Moody's Group Japan G.K., which is wholly-owned by Moody’sOverseas Holdings Inc., a wholly-owned subsidiary of MCO. Moody’s SF Japan K.K. (“MSFJ”) is a wholly-owned credit rating agency subsidiary of MJKK. MSFJ is not a NationallyRecognized Statistical Rating Organization (“NRSRO”). Therefore, credit ratings assigned by MSFJ are Non-NRSRO Credit Ratings. Non-NRSRO Credit Ratings are assigned by anentity that is not a NRSRO and, consequently, the rated obligation will not qualify for certain types of treatment under U.S. laws. MJKK and MSFJ are credit rating agencies registeredwith the Japan Financial Services Agency and their registration numbers are FSA Commissioner (Ratings) No. 2 and 3 respectively.

MJKK or MSFJ (as applicable) hereby disclose that most issuers of debt securities (including corporate and municipal bonds, debentures, notes and commercial paper) and preferredstock rated by MJKK or MSFJ (as applicable) have, prior to assignment of any rating, agreed to pay to MJKK or MSFJ (as applicable) for ratings opinions and services rendered by it feesranging from JPY125,000 to approximately JPY250,000,000.

MJKK and MSFJ also maintain policies and procedures to address Japanese regulatory requirements.

REPORT NUMBER 1208798

10 30 December 2019 Banco de Bogota S.A.: Update to credit analysis

MOODY'S INVESTORS SERVICE FINANCIAL INSTITUTIONS

Analyst Contacts

M. Celina Vansetti 212-553-4845Managing Director -Bankingcelina.vansetti-hutchins@moodys.com

CLIENT SERVICES

Americas 1-212-553-1653

Asia Pacific 852-3551-3077

Japan 81-3-5408-4100

EMEA 44-20-7772-5454

11 30 December 2019 Banco de Bogota S.A.: Update to credit analysis