No.8 Ture False

Criteria | Financial Institutions | Banks:

Banks: Rating Methodology And Assumptions Primary Credit Analyst: Vandana Sharma, New York (1) 212-438-2250; [email protected]

Secondary Contacts: Terry Chan, Melbourne (61) 3-9631-2174; [email protected] Michelle Brennan, London (44) 20-7176-7205; [email protected] Arnaud De Toytot, Paris (33) 1-4420-6692; [email protected] Stefan Best, Frankfurt (49) 69-33-999-154; [email protected] Rodrigo Quintanilla, New York (1) 212-438-3090; [email protected] Xavier Chavee, New York (1) 212-438-6834; [email protected] Angelica Bala, Mexico City (52) 55-5081-4405; [email protected] Hans Wright, London (44) 20 7176 7015; [email protected]

Global Financial Institutions: Vandana Sharma, Criteria Officer, New York (1) 212-438-2250; [email protected]

Global Corporates & Governments: Colleen Woodell, Chief Credit Officer, New York (1) 212-438-2118; [email protected]

Table Of Contents

I. SCOPE OF THE CRITERIA

II. SUMMARY OF THE CRITERIA

III. CHANGES FROM REQUEST FOR COMMENT

IV. IMPACT ON OUTSTANDING RATINGS

V. EFFECTIVE DATE AND TRANSITION

VI. METHODOLOGY: SETTING THE ISSUER CREDIT RATING

VII. METHODOLOGY: STAND-ALONE CREDIT PROFILE

A. Economic Risk

B. Industry Risk

November 9, 2011

www.standardandpoors.com/ratingsdirect 1

916400 | 300003452

Table Of Contents (cont.)

C. The Anchor SACP: Combining Economic Risk And Industry Risk

D. Bank-Specific Analysis: Building On The Anchor SACP

E. Business Position

F. Capital And Earnings

G. Risk Position

H. Funding And Liquidity

VIII. METHODOLOGY: GOVERNMENT SUPPORT FRAMEWORK

A. Factoring Government Support Into The SACP

B. Factoring Government Support Into The Indicative ICR

C. Rating Banks Above The Sovereign

APPENDIX

RELATED CRITERIA AND RESEARCH

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 2

916400 | 300003452

Criteria | Financial Institutions | Banks:

Banks: Rating Methodology And Assumptions (Editor's Note: This article supersedes and partially supersedes the articles listed in the Appendix.)

1. Standard & Poor's Ratings Services is updating its methodologies and assumptions for rating banks. This update

follows our request for comment "Banks: Rating Methodology," published Jan. 6, 2011. This article supersedes

those articles listed in the Appendix.

2. The criteria constitute specific methodologies and assumptions under "Principles Of Credit Ratings," published Feb.

16, 2011.

3. The criteria represent a significant change and aim to enhance the comparability of ratings on financial institutions

with ratings in other sectors (see "Understanding Standard & Poor's Rating Definitions," published June 3, 2009).

The criteria are designed to improve transparency of bank ratings globally.

4. The criteria articulate the steps in developing the stand-alone credit profile (SACP) and issuer credit rating (ICR) for

a bank, including a consideration of the potential for additional direct support from the bank's parent group or

sovereign government. The criteria place heightened emphasis on economic risk and industry risk in setting the

starting point or "anchor" in rating a financial institution. The anchor is then adjusted for bank-specific factors,

such as capitalization, management, risk position, and others, to determine the SACP (see "Stand-Alone Credit

Profiles: One Component Of A Rating," published Oct. 1, 2010). Lastly, the criteria apply analysis of an

institution's support framework, including both potential government support and corporate group support (see

chart 1).

5. The criteria place the SACP for an average bank in developed economies in the 'bbb' and 'a' categories; the

lowercase letters intentionally differentiate these credit profiles from the issuer credit ratings. As a result, only banks

with stronger business positions, and capitalization sufficient to withstand a scenario of severe or extreme stress

without reliance on external support, may be assigned higher SACPs. The potential for any extraordinary

government or group support will be factored into the ICR after the SACP has been determined.

6. The criteria limit rating movements on banks as a result of cyclical changes. Bank ratings of 'AAA' will still be

possible. But such a bank would have to possess credit characteristics, including capitalization levels, that are

significantly stronger than those maintained by most banks pre-2007.

I. SCOPE OF THE CRITERIA

7. The criteria apply to ratings on retail, commercial, and corporate and investment banks. The definition of a bank is

broad and includes the larger broker-dealers, mortgage lenders, trust banks, credit unions, building societies, and

custody banks. The criteria do not apply to ratings on finance companies, asset managers, exchanges,

clearinghouses, and regional securities brokers.

www.standardandpoors.com/ratingsdirect 3

916400 | 300003452

II. SUMMARY OF THE CRITERIA

8. The methodology consists of two key steps: determining the SACP and assessing extraordinary government or group

support. Once the likelihood of extraordinary support is established, then the criteria establish a bank's indicative

ICR. The indicative ICR is a component of the ICR derived by combining the SACP and support conclusions (see

¶193). In most cases, the ICR is at the same level as the indicative ICR (see chart 1). In some cases, set out in

¶¶19-24, the criteria allow for the assignment of an ICR that is one notch higher or lower than the criteria for the

SACP and extraordinary support imply.

9. Issue ratings on hybrid instruments and preferred stock reference the SACP while issue ratings on senior unsecured

instruments reference the ICR (see chart 1 and "Bank Hybrid Capital Methodology And Assumptions," published

Nov. 1, 2011).

10. The assessment of the SACP rests on six factors (see chart 2). The first two factors, economic risk and industry risk,

draw on the Banking Industry Country Risk Assessment (BICRA) methodology (see "Banking Industry Country

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 4

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

Risk Assessment Methodology And Assumptions," published Nov. 9, 2011). They represent the strengths and

weaknesses of the broader operating environment that situate, or anchor, the SACP. The other four factors represent

bank-specific strengths and weaknesses. Based on the analysis of these factors, the SACP is notched up or down

relative to the anchor.

www.standardandpoors.com/ratingsdirect 5

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

11. The support framework considers both the relationship between a bank and its parent group or government and

how this relationship alters a bank's overall creditworthiness. Conclusions about support (beyond the support

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 6

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

included in the SACP, see ¶167) and the SACP combine in the assignment of the indicative ICR. The indicative ICR

is the same as the SACP unless the bank is likely to receive additional capital, liquidity, or risk relief from the

government or the parent group in a crisis. In practice, a bank normally receives help from either its parent group or

government. Accordingly, a bank that is a subsidiary receives the higher indicative ICR resulting from application of

either the group support framework or the government support framework (see chart 6).

III. CHANGES FROM REQUEST FOR COMMENT

12. On April 20, 2011, Standard & Poor's published "What's Happening With The New Bank Criteria? An Update On

Feedback And Implementation." A majority of investors and issuers who provided comments to Standard & Poor's

supported the increased transparency around bank ratings. The changes below (¶¶13-16) reflect market feedback on

various aspects of the criteria framework.

13. First, the anchor is no longer adjusted for investment banking activities. Instead, this adjustment is part of the

assessment of business position and risk position. A bank with significant investment banking activities may have a

riskier business position than a commercial bank whose business is focused on taking deposits and making loans.

14. Second, funding and liquidity are combined into one factor. In addition, the criteria now allow one notch of uplift

for a bank with above-average funding and strong liquidity and with an SACP of 'bbb-' and higher. However, such

uplift is likely to be rare in practice (see tables 15-17).

15. Third, a bank with an anchor SACP below 'bbb-' whose risk-adjusted capital (RAC) ratio is in the adequate or

higher category can receive an uplift of one or two notches (see table 3) if it maintains common equity regulatory

Tier 1 capital in excess of 7% (see ¶¶88-89).

16. Lastly, Standard & Poor's has also revised the BICRA methodology (see "Banking Industry Country Risk

Assessment Methodology And Assumptions," published Nov. 9, 2011), which assesses the relative credit strengths

and weaknesses of national banking systems. The approach to analyzing economic risk and industry risk is an

important part of the bank criteria (see ¶¶29-41 and table 2).

IV. IMPACT ON OUTSTANDING RATINGS

17. These criteria will result in ratings changes that are broadly consistent with the ratings impact stated in the request

for comment "Banks: Rating Methodology," published Jan. 6, 2011, and updated in "How Standard & Poor's

Intends To Finalize Its Bank Criteria And Apply Them To Ratings In The Fourth Quarter Of 2011," published Nov.

1, 2011.

V. EFFECTIVE DATE AND TRANSITION

18. These criteria are effective immediately. We intend to complete our review of the bank ratings within the next six

months. Additional information related to the transition is provided in "How Standard & Poor's Intends To

Finalize Its Bank Criteria And Apply Them To Ratings In The Fourth Quarter Of 2011," published Nov. 1, 2011.

www.standardandpoors.com/ratingsdirect 7

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

VI. METHODOLOGY: SETTING THE ISSUER CREDIT RATING

19. The ICR is set at the same level as the indicative ICR (subject to the criteria shown in ¶¶206-212), or one notch

higher or lower in some cases, according to the criteria in ¶¶19-24. Most of the time, there will be no need to adjust

the indicative ICR up or down. If applied, the sum total of adjustments to the universe of banks that Standard &

Poor's rates will be roughly even, and if not, no greater than a 2:1 ratio of upward to downward adjustments.

20. The view of a bank's creditworthiness is refined by considering its relative credit standing among all banks with a

similar SACP, that is, the same or one notch higher or lower. For example, if a bank has a SACP of 'a-', it is

compared with other banks with SACPs of 'a', 'a-', and 'bbb+'.

21. In the final peer review, the capital sustainability ratio (see table 10 and ¶90) and the earnings buffer ratio (see table

11 and ¶¶105-110) are the primary metrics for the comparison. The combination of these earnings measures means

that stronger-than-average earnings are only recognized when a bank also maintains or grows capital.

22. The indicative ICR is higher by one notch when a bank is:

• In a positive transition that reduces risk or improves creditworthiness that is not already fully captured in the indicative ICR; or

• Subject to political, social, economic, or competitive trends that are strengthening creditworthiness; or • A sustained and projected outperformer in its peer group with ratios more reflective of the higher rating, unless

already captured elsewhere in the methodology.

23. A bank whose regulatory ratio is "at risk" (see table 8) or whose liquidity is "weak" (see table 16) would not

qualify for a one-notch uplift detailed in ¶22.

24. The indicative ICR is lower by one notch when a bank is:

• In a negative transition that increases risk or reduces creditworthiness that is not already fully captured in the indicative ICR; or

• Subject to political, social, economic, or competitive trends that are weakening creditworthiness; or • A poor performer in its peer group with ratios more reflective of the lower rating.

VII. METHODOLOGY: STAND-ALONE CREDIT PROFILE

25. Economic risk and industry risk represent macro analysis of the creditworthiness of a bank while business position,

capital and earnings, risk position, and funding and liquidity represent microanalysis (see the BICRA methodology).

26. These bank criteria use the BICRA's economic risk and industry risk scores to determine a bank's anchor SACP (see

table 2), the starting point in assigning an ICR. The anchor SACP is adjusted up or down the ratings scale after

taking into account a bank's specific strengths and weaknesses in the following factors:

• Business position, • Capital and earnings, • Risk position, and • Funding and liquidity.

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 8

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

27. The criteria call for an SACP for most of the banks Standard & Poor's rates. There are some circumstances when

assigning an SACP is not meaningful because of a bank's high degree of operational or financial integration with a

parent or in a group. In these cases, the bank is economically a cost center or division, even though it may legally be

a separate company (see "Group Rating Methodology And Assumptions," published Nov. 9, 2011).

28. The result of the analysis described in ¶26 is a bank's SACP, an interim step in assessing a bank's overall

creditworthiness. This SACP includes government support as described in ¶167 but does not include extraordinary

support.

A. Economic Risk

29. Economic risk is the first factor in determining the SACP. A change in an economic risk score of a country might

result in a change in the anchor SACP, SACP, or ratings on a bank with business in that country.

30. The BICRA economic risk score of the country (or countries) where a bank operates captures the economic risk of

the bank. The BICRA economic risk scores range from group 1 (very low risk) to group 10 (extremely high risk).

31. Economic risk takes into account the stability and structure of a country's economy, its economic policy flexibility,

actual or potential imbalances, and the credit risk of economic participants--mainly households and enterprises. The

BICRA methodology seeks to identify the potential for adverse economic developments and the banking system's

capacity to adjust to them (see the BICRA methodology).

32. When a bank is active in more than one country, the economic risk score is calculated as a weighted average of the

economic risk scores--called weighted-average economic risk (see table 1). The proportion of a bank's business in

each country that represents its main economic risks is used to weight the economic risk scores. The economic risk

score should reflect the bank's underlying economic risks. The calculation only includes countries where a bank

conducts more than 5% of its business. All weightings are rounded to the nearest 5% before averaging.

Table 1

Hypothetical Example Of Weighted-Average Economic Risk For A Bank

Country Weighting (% of business) Economic risk* Weighted economic risk

France 45 2 0.9

U.S. 20 4 0.8

Switzerland 15 1 0.15

India 10 5 0.5

Japan 10 2 0.2

Weighted-average economic risk -- -- 2.55

*On a scale from 1-10, lowest to highest risk.

33. For a lending institution, the weighted average is calculated according to the proportion of loans in each country.

When lending activities are minor, other measures of underlying economic risks determine the weights. The analysis

is based on a geographic breakdown of a bank's loan book or the adjusted exposure used in risk-adjusted capital

analysis (see "Bank Capital Methodology And Assumptions," published Dec. 6, 2010). Adjustments are made for

likely changes in the bank's risk footprint--for example, as a result of acquisitions in new countries.

34. For stand-alone investment banks, the country where a bank has its headquarters determines its economic risk score.

www.standardandpoors.com/ratingsdirect 9

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

Investment banking activities are defined as debt and equity underwriting, mergers and acquisitions (M&A)

advisory, sales and trading, principal investment, and proprietary trading.

35. In addition, the capital charges in the risk-adjusted capital framework (RACF), Standard & Poor's criteria for

assessing a bank's capital, are scaled using a country's economic risk score. Higher risk weights are applied to the

same exposures in countries with a higher economic risk assessment (¶74).

B. Industry Risk

36. Industry risk is the second factor in determining a bank's SACP, and a change in a country's industry risk score

might result in a change in the anchor SACP, SACP, or rating on the bank.

37. A bank's industry risk is determined by the BICRA industry risk score for the country where it is domiciled and

primarily regulated. The BICRA industry risk scores range from group 1 (very low risk) to group 10 (extremely high

risk).

38. Industry risk assesses three structural features of a country's banking industry: (1) the institutional framework or the

quality and effectiveness of bank regulation and the track record of authorities in managing financial sector turmoil;

(2) competitive dynamics or the competitive landscape and performance, financial products and practices, and the

role of nonbank financial institutions; and (3) funding through the debt markets or government, including the role

of the central bank and government.

39. As part of the analysis of industry risk, competitive dynamics determines the degree of use of complex products,

including financial derivatives. Aggressive use of complex products and derivatives contributes to higher industry

risk; the absence of complex products and derivatives supports a lower industry risk assessment.

40. Because industry risk addresses the range and strength of funding options available to banks in a country, including

the role of the central bank and government, the SACP includes elements of ongoing government support (see ¶167).

41. Unlike economic risk, industry risk is not calculated as a weighted average when a bank operates in more than one

country. The main reason for this is the importance of the bank's home regulatory framework.

C. The Anchor SACP: Combining Economic Risk And Industry Risk

42. Economic risk and industry risk anchor the creditworthiness of a bank in its operating environment. Specifically, the

bank's economic risk and industry risk scores are associated with a particular anchor SACP (see table 2). The anchor

SACP is a globally consistent, relative ranking of creditworthiness across national banking markets and ranges from

'a', the least risky, down to 'b-', the riskiest.

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 10

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

Table 2

Determining The Anchor SACP From Economic Risk And Industry Risk

Economic risk*

Industry risk* 1 2 3 4 5 6 7 8 9 10

1 a a a- bbb+ bbb+ bbb

2 a a- a- bbb+ bbb bbb bbb-

3 a- a- bbb+ bbb+ bbb bbb- bbb- bb+

4 bbb+ bbb+ bbb+ bbb bbb bbb- bb+ bb bb

5 bbb+ bbb bbb bbb bbb- bbb- bb+ bb bb- b+

6 bbb bbb bbb- bbb- bbb- bb+ bb bb bb- b+

7 bbb- bbb- bb+ bb+ bb bb bb- b+ b+

8 bb+ bb bb bb bb- bb- b+ b

9 bb bb- bb- b+ b+ b+ b

10 b+ b+ b+ b b b-

*On a scale from 1-10, lowest to highest risk where economic risk and industry risk scores are rounded to the nearest whole number prior to the application of the table.

SACP--Stand-alone credit profile.

43. The 'a' level, the strongest anchor SACP, reflects the volatility of banking even in the strongest markets. By

embedding this notion of volatility into the anchor SACP, the criteria aim to ensure that lessons of the post-2007

economic downturn will not be forgotten as national economies recover and another period of favorable conditions

gives rise to growth and attractive headline banking profits. Banks will likely continue to respond more severely to

otherwise moderate economic shocks because they are confidence-sensitive and many carry high leverage.[1] In

recognition of credit stability as a key issue in ratings, Standard & Poor's does not assign a long-term ICR of 'AA'

where it would likely fall below 'A' within one year under moderate stress conditions. Similarly, Standard & Poor's

would not assign an 'A' rating where it will likely fall below 'BB' within one year under the same stress (see "Credit

Stability Criteria," published May 3, 2010). Significantly, observations of banking crises throughout history show

that the SACPs of many important banks in developed markets would have fallen below 'a' under this bank criteria.

Therefore, even in countries that offer the most favorable environment, the criteria set the anchor SACP no higher

than 'a'.

44. Serial banking crises throughout history demonstrate that depositors and investors can lose confidence

quickly--leading to bank failures, government bailouts, and dampened economic growth, as Reinhart and Rogoff

describe in their book, "This Time is Different: Eight Centuries of Financial Folly." Confidence sensitivity and

leverage in a banking system can turn a moderate stress into a more severe and protracted downturn.

45. Reinhart and Rogoff's empirical study of banking crises in 66 countries between 1800 and 2008 shows that they are

commonplace in both advanced and emerging economies. For example, since 1800, there have been 13 banking

crises in the U.S., 12 in the U.K., and 15 in France. This pattern of banking sector boom and bust and government

support will likely repeat itself in some fashion, regardless of governments' recent and emerging policy response.

New laws put in place following previous crises, such as deposit insurance, have not always prevented subsequent

downturns. Banking crises will likely happen again.

46. In addition, in response to the recent financial crisis, various supervisory authorities concluded that banks were

undercapitalized leading up to 2007. Many studies, including those by the U.S. Financial Crisis Inquiry Commission,

www.standardandpoors.com/ratingsdirect 11

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

the Swiss Commission of Experts, and the U.K.'s Independent Commission on Banking, suggest that capital

standards need to be raised materially to address the leveraged and interconnected nature of banks around the

world. Standard & Poor's analysis shows that despite banks' efforts to improve capital levels, their leverage

continues to be high in 2011. For example, the final report of the Swiss Commission of Experts for limiting the

economic risks posed by large companies concluded that the appropriate level of capital for institutions that are

"too big to fail" is 19%, consisting of 10% common equity and 9% contingent convertible bonds.[2] Likewise, the

U.K.'s Independent Commission on Banking recently recommended that large U.K. banking groups should have

"primary loss-absorbing capacity of at least 17%-20%."[3]

47. The anchor SACP integrates the reality that capital is generally not a ratings strength and that banking is an essential

yet volatile business. Banks play an important role in national economies through their conversion of shorter-term

deposits into longer-term loans. Providing interest to depositors protects the value of their savings from inflation,

and providing loans to governments and the private sector stimulates investment and growth. By operating with

increasingly high leverage--borrowing more from savers and the debt capital markets--banks can lend more, which

means greater economic growth. For their high-leverage business position to work, banks rely on the continuing

confidence of depositors and investors in their creditworthiness to roll over maturing deposits and refinance

maturing debt. And governments aim to boost this confidence through regulation and supervision to protect

economic growth.

D. Bank-Specific Analysis: Building On The Anchor SACP

48. After the determination of the anchor SACP, the criteria consider each bank-specific SACP rating factor--in other

words, an analysis of a bank's individual characteristics. The assessment of each factor can raise or lower the anchor

SACP by one or more notches--or have no effect in some cases (see table 3). These conclusions are expressed using

specific rankings and descriptors. These rankings and descriptors, in turn, determine the number of notches to apply

to the anchor SACP to determine the level of a specific bank's SACP.

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 12

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

1. Comparative analysis and peer review 49. The main purpose of comparative analysis and the peer review is to provide context for assessing the bank-specific

rating factors and to set the ICR.

50. Comparative analysis, which takes on slightly different forms for each SACP rating factor (see table 4), helps

develop the bank-specific analysis. In some cases the analysis is relative, and in others it is absolute. Specifically, the

analyses for business position, risk position, and funding are all relative while the analyses for capital and earnings

and liquidity are absolute.

51. A bank is generally compared with all banks in its home country.

52. Once the indicative ICR is determined, the criteria also use a final peer review to set the ICR (see ¶¶19-24). Here,

the peer group is banks with a similar SACP, i.e., the same or one notch higher or lower (see ¶20).

www.standardandpoors.com/ratingsdirect 13

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

Table 4

The Focus Of Comparative Analysis For Each SACP Rating Factor

SACP rating factor Comparative group Guidance

Business position

Banks with similar industry risk*

The comparative analysis for business position comprises all banks with a similar industry risk score. A bank is generally compared with all banks in its home country.

Capital and earnings

All banks globally The comparative analysis for capital and earnings comprises all banks. Globally consistent metrics are used as absolute measures to benchmark performance for the capital and earnings assessment.

Risk position Banks with similar economic risk and product mix*

Comparative analysis supports the more qualitative conclusions about risk position with the more quantitative risk assumptions in capital and earnings analysis, to determine whether those assumptions are appropriate for a bank. A bank's loss experience and Standard & Poor's loss expectations that are lower than average imply lower risk. Conversely, larger comparative losses imply higher risk. The comparative analysis for risk position comprises all banks with a similar economic risk score and product mix.

Funding and liquidity

Funding: all banks in a country / Liquidity: all banks globally

The comparative analysis for funding comprises all banks in a country. Specifically, banks are compared with the domestic industry average so that this assessment of funding remains consistent with the BICRA funding assessment. The liquidity subfactor uses a bank's liquidity ratios and dependence on central bank funding to make a comparison with national and international banks. Accordingly, the comparative analysis for liquidity comprises all banks.

*When there are not enough domestic banks or when many similarities exist among national banking industries, the comparison can include international banks. The

relative creditworthiness between banking industry and economic risk is determined by the BICRA (Banking Industry Country Risk Assessment) criteria. A bank is compared

with banks within a category of the BICRA industry and economic risk scores. SACP--Stand-alone credit profile.

E. Business Position

53. The third SACP rating factor, business position, measures the strength of a bank's business operations. Business

position is the combination of specific features of the bank's business operations that add to or mitigate its industry

risk score. The criteria group these features into three subfactors: business stability, concentration or diversity, and

management and corporate strategy. Relative strength is assessed through a number of indicators (see table 5).

Where they are relevant and available, quantitative metrics are used; however, much of the assessment is qualitative.

Table 5

Business Position Subfactors And Indicators

Subfactors Explanation Indicators

Business stability (¶¶57-61) The stability or fragility of a bank's franchise

Revenue stability, market shares, and the customer base

Concentration or diversity (¶¶62-67)

The concentration or diversification of business activities

Contributions of different business lines and geographies to overall revenue

Management and corporate strategy (¶¶68-72)

The quality of management, strategy, and corporate governance

Strategic positioning, operational effectiveness, financial management, and governance and financial policies

To adjust the anchor for business position, see table 3, Using Bank-Specific Analysis To Determine The SACP.

54. For each bank, the strength of its business position is scored using one of six standard descriptors (see table 6),

based on conclusions about its strength relative to the comparative analysis described in table 4.

55. Though the three subfactors are assessed independently, it is important to understand how they may reinforce or

weaken each other. The assessment is not a simple addition of metrics for the three subfactors. For example, if the

concentration of revenues from a single region or a single line of business results in an even more negative view of a

weak business stability assessment, it will lead to a very weak score. In addition, stronger areas do not automatically

offset or "average out" weaker areas. Instead, the focus is on identifying risks and determining whether they

combine to further increase or reduce overall risk.

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 14

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

56. An "adequate" business position means that the industry risk score appropriately captures the risk of a bank's

business activities. In other words, when compared against banks with a similar industry risk score, a bank's

business activities represent average risk. An assessment of "very strong" or "strong" means that a bank's business

activities are less risky than average. An assessment of "moderate," "weak," or "very weak" means that a bank's

business activities are riskier than average. Each descriptor determines the adjustment, in notches, to the anchor

SACP (see table 3).

www.standardandpoors.com/ratingsdirect 15

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

1. Business stability 57. Business stability is the first subfactor in the business position assessment. Business stability is the predictability of

continuing business volumes in the face of economic and market fluctuations. This is important because the erosion

of confidence that a bank may suffer during times of market turbulence exposes it to the possibility of sudden

default risk. Customers and counterparties can walk away, and access to liquidity in the capital market can dry up.

A business position that contains this sudden default risk is inconsistent with an SACP in the 'a' category.

58. A key lesson of the banking crisis that started in 2007 was that differences in franchise stability and confidence

sensitivity significantly affect creditworthiness. Financial institutions with large trading operations--particularly in

derivatives--are sensitive to an erosion of confidence. A bank whose revenues are highly impervious to an economic

downturn or a period of market turbulence is associated with stronger business stability. On the other hand, a bank

whose revenues are susceptible to significant volatility during moderately adverse conditions is associated with

weaker business stability.

59. The criteria use measures of revenue stability, market share, and the customer base to compare a bank's business

stability with that of domestic banks and banks with a similar industry risk score in other countries. The

comparative analysis focuses on the underlying contribution of business lines to total revenues and earnings and on

Standard & Poor's estimates for their future contribution. Business lines with recurring fee income and net interest

income that have a strong annuity characteristic are more stable. In contrast, the following income sources are less

stable:

• Trading income, including interest income from trading activities; • Net interest income coming from above-average asset-liability mismatches; • Other market sensitive income; and • Fee income from off-balance-sheet financing.

60. Business stability supports an adequate or stronger business position when a bank has two or more of the following

characteristics:

• The customer base is demonstrably "sticky," that is, there are long-standing customer relationships and they generate a high proportion of revenues. There is strong evidence that customers are likely to stay with the bank

during a financial stress;

• Revenues are less sensitive to market perceptions of creditworthiness; • Favorable contractual terms, such as credit-related termination events or triggers, exist in many contracts with

customers and counterparties; and

• A bank is less reliant than the industry on pricing to retain customers.

61. Potential instability of business lines exists and can lead to a moderate or weaker business position when a bank has

two or more of the following characteristics:

• Customers can easily switch their business to other providers. There is no evidence that customers are likely to stay with a bank during a financial stress. The relationship between customers and a bank is based on a series of

one-off transactions open to market tender;

• There are few or no direct relationships between the end customer and the bank. A bank relies on third parties to supply business volumes;

• Recurring fee or interest income from long-standing customer relationships represent a lower proportion of

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 16

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

revenues than average in the industry;

• Revenues are more sensitive to market perceptions of creditworthiness than for the industry; • A bank relies more heavily on pricing to attract and retain customers than for the industry; and • Unfavorable contractual terms such as financial covenants, credit triggers, and collateral requirements that are

more demanding than for banks with a similar industry risk score carrying out the same types of trades.

2. Concentration and diversity of business activities 62. Concentration and diversity is the second subfactor of the business position assessment. Concentration and diversity

of business activities are measured by the contributions of different business lines and geographies to a bank's

revenues, compared with banks with a similar industry risk. Entities with a broader mix of business activity are

lower risk, and entities with a narrower mix are higher risk. Concentration in business activities can partly offset

many of the strengths in the business position assessment.

63. The concentration of business volumes or revenues can lead to less stable and predictable revenues, which weakens

the business position. On the other hand, successful diversification can lead to more stable and predictable revenues.

Successful diversification means that a bank's earnings were stronger than the industry during the last domestic

downturn and since then, management has not increased the bank's exposure or risk appetite materially.

64. The criteria treat a bank as more concentrated than average for the industry when it has a more limited product

range or geographic breadth, particularly for a bank with significant regional, product, or customer concentrations.

Even if concentration is in an attractive region, product, or customer segment, it may be a weakness. Regional

presence must be considered in the context of the size of the local or regional economy. For example, a focus on the

U.S. State of Texas is very different from, and far less concentrated than, a focus on a Swiss canton.

65. Business diversification can either be a strength or a weakness in a bank's business position. Successful and

continuing diversification supports a stronger business position. Such business diversification is often international

and is supported with evidence that the bank is overall less susceptible to volatility in domestic business and

economic conditions than is average for banks in the home industry. Poor diversification weakens the overall

business position. For example, a bank will weaken its overall business position if it enters new products and

countries where it has limited expertise and lacks critical mass to be a real competitor to the incumbent market

leaders. The weakness is greater when the new products or markets are riskier than the traditional core business.

66. Acquisitions can increase concentration risk if the acquired assets are similar to those in a bank's existing book and

particularly when the bank does not increase risk-adjusted capital in line with assets and risks.

67. Other areas of the methodology also look at concentration, but in different ways. For example, risk correlations

among risk exposures are analyzed in the assessment of risk position (see tables 12-14 and ¶¶118-121), and

concentrations in funding sources are addressed in the funding and liquidity section (see ¶¶144-145).

3. Management and strategy 68. The final subfactor in the business position assessment, management and strategy, considers management's ability to

execute operational plans in a consistent manner, a bank's strategic direction, management's risk appetite, and a

bank's ownership and governance. Management's strategic competence, risk management, and operational

effectiveness shape a bank's competitiveness in the marketplace and its financial condition.

69. This assessment is qualitative, but past performance and forward-looking targets provide some objective standards.

It is also relative. A bank's business position is compared with that of banks with similar industry risk. If

www.standardandpoors.com/ratingsdirect 17

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

management plays a positive role in determining a bank's operational success, it is more likely to be able to manage

important strategic and operating risks in the future. Alternatively, a weak management with an ineffective

operating strategy or inability to execute its business plan effectively increases risk.

70. Management and strategy support an adequate or stronger business position when:

• The bank's risk appetite is more prudent and conservative than average in the industry. Management has proven execution capabilities and is a stable team. There is a track record of avoiding the strategic mistakes of other

banks;

• Returns have been, and are likely to be, less volatile than average in the industry. Both compensation and financial targets are focused on long-term value for all stakeholders (including bondholders); and

• Independent directors have strong influence, and a robust system of checks and balances exists in decision-making.

71. The assessment of management and strategy can lead to a moderate or weaker business position if:

• Management's risk appetite, strategies, financial targets--such as return on equity (ROE) and growth in earnings per share (EPS)--and acquisition strategies are more aggressive than average for the industry;

• The bank consistently outperforms the sector- or country-average ROE, particularly during a period of expansion;

• Governance standards compare negatively with the industry average (see ¶¶37-47 of "Management And Corporate Strategy Of Insurers: Methodology And Assumptions," published Jan. 20, 2011);

• The entity depends on continuing service from key individuals or small teams; • The organization operates with more complex corporate, legal, or tax structures; • Compensation schemes encourage short-term profit-taking; • There is unplanned management turnover in critical senior positions; and • The bank has made acquisitions at prices that reflect premiums to tangible book value, projected earnings, or

acquired core deposits, compared with prices paid for recent transactions of comparable size and nature.

72. Although this assessment is largely qualitative, it is informed by historical data on past performance and

forward-looking indicators of the attitude of management and owners toward risk, including financial targets such

as target ROE and EPS growth, as well as compensation schemes, management incentive schemes, and statements of

risk appetite. A study of reported ROE relative to average ROE for the sector or country can be a crude indicator of

risk appetite. Consistent outperformance of sector- or country-average ROE, particularly during a period of

expansion, can indicate higher management and strategy risk.

F. Capital And Earnings

73. Capital and earnings, the fourth SACP rating factor, measures a bank's ability to absorb losses. This ability provides

protection to senior creditors while the bank remains a going concern. The analysis of capital and earnings

comprises four steps: assessment of regulatory requirements, future risk-adjusted capital levels, quality of capital and

earnings, and earnings capacity. The projected risk-adjusted capital (RAC) ratio is the most important metric even

though there may be other measures of capital.

74. The RAC ratio compares a bank's capital to its risk-weighted assets (RWAs). Specifically, the criteria use a globally

consistent measure of capital, total adjusted capital (TAC) and Standard & Poor's RWAs (see "Bank Capital

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 18

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

Methodology And Assumptions," published Dec. 6, 2010, for a full explanation). To arrive at the RWAs of a bank,

specified risk weights are applied to the bank's various exposures.

75. The criteria for this factor measure the degree to which a bank's capital and earnings would cover estimated losses

that would arise following a substantial economic stress for developed countries. By incorporating earnings based on

their capacity to absorb losses and build capital, the criteria make earnings a component of the capital analysis

rather than a separate rating factor. In theory, a bank's product pricing includes a margin sufficient to cover the

expected losses on its assets, which leaves capital to protect against unexpected losses.

76. The first step in analyzing capital and earnings is establishing how a bank performs against its regulatory

requirements. Meeting these requirements is a prerequisite for operating as a going concern. Any weakness here

would be an overriding factor limiting the SACP (see section F.1).

77. The second step is using the projected RAC ratio to form an opinion of a bank's future capital, as long as

performance against regulatory measures is adequate or better. The criteria introduce standards for how to interpret

the projected RAC ratio. Because earnings retention is the primary way that a bank builds or maintains capital, the

projected RAC ratio is aligned with the capital sustainability ratio (see ¶90 and table 10). That ratio looks at the

balance a bank is striking between growth, which weakens capital, and the buildup of capital through retained

earnings (see section F.2).

78. Third, the criteria assess the quality of capital and earnings by looking at the composition of, and trend, in TAC,

and the stability and predictability of earnings. When the projected RAC ratio is at the upper end of a scoring range,

high-quality capital can push the capital and earnings assessment into a stronger category. Conversely, when the

projected RAC ratio is at the lower end of a range, weaker quality of capital or earnings can push the assessment

into a weaker category (see section F.3).

79. Finally, the criteria assess earnings capacity, the first line of defense against losses and the primary way that a bank

builds or maintains capital. The earnings buffer (see ¶¶105-110 and table 11) is a metric that measures the capacity

of earnings to absorb "normalized losses" through the credit cycle. A bank's earnings buffer can be positive or

negative. When the bank's earnings buffer is negative, earnings are not sufficient to cover normalized losses. The

earnings buffer helps identify consistent out- and underperformers when setting the final ICR (see ¶¶19-24 and

section F.4).

80. The relevant metrics are combined in scoring capital and earnings on a six-point scale (see table 7).

www.standardandpoors.com/ratingsdirect 19

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

1. Regulatory requirements 81. As a first step in the capital and earnings analysis, the criteria determine whether a bank is meeting minimum

regulatory requirements. A bank operating with capital close to or in breach of the minimum requirements of the

local regulator receives one of the following scores: "at risk," "subject to regulatory forbearance," or "insolvent."

The caps on the SACP associated with these scores are 'bb+', 'ccc+', and 'cc', respectively (see table 8). Banks

operating with capital somewhat greater than the local regulatory minimum requirements may have an SACP of

'bbb-' or higher. (But they may have a lower SACP because of other weaknesses.)

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 20

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

2. Capital 82. The second step, assessing capital with the RAC ratio, is the cornerstone of the capital and earnings criteria (see

"Bank Capital Methodology And Assumptions," published Dec. 6, 2010.

83. The assessment ranks a bank's level of capital using the projected RAC ratio before adjustments for concentration or

diversification (see table 9).

www.standardandpoors.com/ratingsdirect 21

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

84. The criteria consider capital prospectively by focusing on a bank's projected RAC ratio. This might be much lower

than at the last reporting date during a period of growth, or higher than at the last reporting date during a recovery

or risk reduction, or a period of restructuring. Because a bank's major source of capital is its earnings, the projected

RAC ratios should be consistent with the bank's ability to grow or rebuild capital through internally generated

retained earnings. Capital projections also include external capital raising.

85. The risk-adjusted capital framework (RACF) applies Standard & Poor's risk weights to a bank's on- and

off-balance-sheet exposures to produce Standard & Poor's RWAs. The risk weights applied to each risk type and

asset class reflect their relative degree of risk.

86. In addition, the risk weights are calibrated according to Standard & Poor's stress scenarios that in turn are used to

maximize ratings comparability across sectors and over time. Specifically, the RWAs are calibrated to an 'A' or

substantial stress scenario (see Appendix IV of "Understanding Standard & Poor's Rating Definitions," published

June 3, 2009). An 8% RAC ratio, for example, implies that a bank in a developed country has sufficient capital to

withstand the 'A' or substantial stress scenario. By comparison, a 12% RAC ratio implies that a bank has sufficient

capital to withstand the criteria's 'AA' or severe stress in a developed country. These calibrations are based on our

observations that banking losses following 'AA' or severe stress are typically about 1.5x greater than following

substantial stress and about 2x more than after 'AAA' or extreme stress. Note that Standard & Poor's stress

scenarios generally hold for issuers or obligations in developed countries such as the U.S., Japan, Western Europe,

and Australia, and drive risk assumptions for banking losses in those economies (see ¶13 in "Bank Capital

Methodology And Assumptions," published Dec. 6, 2010).

87. To adjust the risk assumptions for structural differences--for example in credit culture, banking and bankruptcy

laws, and observed lower loss experience for some asset classes--the criteria incorporate the BICRA methodology to

assesses industry risk and economic risk, which set the anchor SACP. The BICRA methodology is also used to

modify the risk assumptions for the higher-risk characteristics of developing economies and the specific kinds of

exposures of banks operating in these countries.

88. When a bank's anchor SACP, derived from the BICRA methodology, is in the 'bb' category and its common equity

regulatory Tier 1 ratio is greater than the local regulatory requirements--or a minimum of 7% if this is higher than

local regulations--a moderate or adequate RAC ratio is neutral for the SACP. The anchor SACP is lowered by one

notch if the ratio is weak and by two notches if the ratio is very weak. If the RAC ratio is strong, the anchor SACP is

raised by one notch, and if the RAC ratio is very strong, it is raised by two notches (see table 3 and footnote in table

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 22

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

9).

89. When a bank's anchor SACP, derived from the BICRA methodology, is in the 'b' category and its common equity

regulatory Tier 1 ratio is greater than the local regulatory requirements--or a minimum of 7% if this is higher than

local regulations---a weak or moderate RAC ratio is neutral for the SACP. The anchor SACP is lowered by one

notch if the ratio is very weak (or by two notches if the RAC ratio is less than 2%). If the bank RAC ratio is

adequate, the anchor SACP is raised by one notch, and if the RAC ratio is strong or very strong, the anchor SACP is

raised by two notches (see table 3 and footnote in table 9).

90. The criteria evaluate whether the projected RAC ratio is consistent with the capital sustainability ratio. This

represents a forward-looking estimate of a bank's ability to grow or rebuild capital through retained earnings, and is

the difference between the buildup of capital and capital requirements (see table 10 for details on how this ratio is

calculated). The ratio is most relevant when a bank is growing and reporting profits. The ratio reflects estimates

about growth and earnings retention. There is usually a relationship between the capital sustainability ratio and the

projected RAC ratio, and one is a check for the other:

• When capital sustainability is between -30 basis points (bps) and +30 bps, the projected RAC ratio is likely to show little to no growth, unless the bank has announced plans to raise external capital or to achieve some other

means of capital growth and it is expected to be successful.

• When capital sustainability is lower than -30 bps, the projected RAC ratios will show a decline unless the bank has announced credible plans to raise external capital or to achieve some other means of capital growth.

• When capital sustainability is greater than 30 bps, the projected RAC ratios will show an increase based on internal capital generation.

• When the bank is generating losses, these rules do not apply. The projected RAC ratio decline is reflected in the capital assessment.

91. During periods of expansion, the assessment of capital relies on how much a bank uses retained earnings to both

fund growth and maintain capital ratios. To illustrate, if risk-weighted assets grow by 10%, capital needs to grow

by close to 10% to maintain capital ratios. Failure to grow capital via retained earnings at the same pace as growth

in the business indicates that capital will deteriorate--unless a bank has access to external sources to make up for the

deficiency. When a bank is taking on more risk and reporting greater returns, the calculation for capital

sustainability adjusts for this by increasing Standard & Poor's RWAs accordingly. The analysis focuses on earnings

growth and the pace of the bank's expansion. Growth beyond the capacity of management, infrastructure, and

capital is a leading indicator of increasing risk.

92. The credit loss estimates and projections in the second row of table 10 reflect the most likely scenario,

complemented by Standard & Poor's economic forecasts. They are point in time and country-specific, adjusted for

the economic and credit cycle. These country-level loss estimates for a specific bank can be modified for more severe

loss expectations based on bank-specific risks, including the need to strengthen loss reserves or increase impairments

if a bank's loan loss coverage is materially deficient.

www.standardandpoors.com/ratingsdirect 23

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

93. In contrast to the capital sustainability buffer, the earnings buffer calculation (¶¶105-110 and table 11) uses

"normalized losses" to adjust earnings based on a set of credit risk assumptions that do not move during the

economic or credit cycle.

94. Although the RAC ratio provides a globally consistent measure of capital, because of the limitations of all models,

the risk assumptions in the RACF are tested as part of the assessment of the risk position. The risk position analysis

essentially determines the degree to which the capital and earnings analysis understates or overstates bank-specific

risk (see tables 12-14). The capital and earnings analysis also includes qualitative judgments about the quality of

TAC and the quality of earnings.

3. Quality of capital and earnings 95. The quality of capital and earnings assessment is the third step in the capital and earnings analysis. This helps

determine whether the projected TAC has failed to capture additional strengths or weaknesses in earnings or the

capital base. Several characteristics help drive the assessment of the quality of capital as "high" or "low." The

contribution of the quality of earnings has a negative bias as the strengths are already incorporated into projected

TAC.

96. A bank's relative quality of capital and earnings is compared with other banks of a similar economic risk score to

determine whether it commands additional financial flexibility or demonstrates weaker earnings. When the

projected RAC ratio is borderline (within 25 basis points of the upper or lower end of the ranges in table 9 above),

high quality of capital can push the assessment of capital and earnings into the next strongest category while

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 24

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

low-quality capital or earnings can push the assessment into the next weakest category (see table 7).

97. The criteria associate high-quality capital or earnings with a combination of the following:

• The bank's core capital, as measured by adjusted common equity (ACE), comprises more than 85% of the bank's total adjusted capital (TAC).

• The investor base is more supportive of strong capital relative to other banks; investors have lower expectations for dividend yields and share buybacks are consistent with the projected RAC levels applied in table 9.

• The bank is able and willing to sell attractive assets, equivalent in value to about 10% or more of TAC, to raise funds that would not require restructuring or damage its competitive position. Several buyers are interested in

such assets--even in a period of economic and market turbulence.

• The bank has substantial economic capital in reserves of at least 10% of TAC that do not form part of the capital assessment in section F.2. These typically arise from tax optimization.

• The bank has issued hybrid instruments or preferred stock (which its regulator treats as capital) of at least 10% of TAC in the markets or with the government, which do not form part of the capital assessment in section F.2.

98. The criteria associate low-quality capital or earnings with a combination of the following:

• The bank's core capital, as measured by adjusted common equity (ACE), comprises less than 70% of the bank's total adjusted capital (TAC).

• Significant legal, tax, or regulatory constraints or characteristics of the group structure (for example, minority interests) constrain the flow of capital among group members to absorb losses.

• Dividend payouts or planned share buybacks may prevent the maintenance of strong capital. • An aggressive financial shareholder may be increasing its ownership and can pressure management to maintain

weaker capital in the future.

• The government may have contributed to TAC but expects repayment when possible. • The absolute size of the capital base is less than $100 million, bringing into question the bank's ability to

withstand significant shocks or events that other, larger players can more readily absorb.

• A bank holding company has high double leverage (see ¶¶99). • Revenues rely on one-off items, such as realized capital gains on securities holdings or fixed assets, producing a

lower level of risk-adjusted core earnings or more volatility in the earnings performance.

• More than 75% of revenues come from a relatively narrow business line especially when net interest income and fees and commissions account for less than 60% of revenues.

• Credit provisions (loan loss reserves) are materially deficient. • Unconsolidated subsidiaries are materially undercapitalized. • The bank has other substantial economic losses that the financial statements have not yet recognized.

99. The criteria introduce no changes to the treatment of double leverage (see "Analytical Approach To Assessing

Nonoperating Holding Companies," published March 17, 2009. Double leverage (DL) is defined as holding

company investments in subsidiaries divided by holding company (unconsolidated) shareholders' equity. DL renders

the nonoperating holding company (NOHC) dependent in part on dividends to meet interest payments on external

debt. DL is only relevant when TAC is not calculated on fully consolidated accounting data that combine holding

company financials with those of its operating banks.

100. High DL--of 120% or more--is a sign of aggressive liquidity and capital management and may increase the

possibility of liquidity stress, unless offset by liquidity at the parent. Similarly, if the absolute amount of DL of a

www.standardandpoors.com/ratingsdirect 25

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

financial group with a NOHC exceeds two years' net income of the consolidated group, the NOHC parent would

need offsetting liquidity. Without this offsetting liquidity, the quality of a bank's capital is low.

101. When traditional earnings ratios are weaker than for other direct competitor banks, earnings quality is low. A bank

that demonstrates strong or very strong earnings on an absolute basis but is underperforming direct competitors on

a risk-adjusted basis is more vulnerable to any deterioration in the operating environment. Lower earnings based on

lower risk are generally positive for creditworthiness, and higher returns based on higher risk are generally negative

for creditworthiness.

102. The objective in carrying out the earnings peer analysis is to identify outliers through a variety of different measures.

A bank's overall relative positioning influences the assessment of earnings quality. However, under some

circumstances, a single feature may determine the conclusion about earnings quality. The earnings peer analysis

draws on the ratios enumerated below to help determine the bank's relative quality of earnings.

103. For the following metrics, the quality of earnings improves as the ratio increases:

• Net interest income/total revenue, • Fees and commissions/total revenues, • Core earnings/Standard & Poor's RWAs, • Core earnings/assets, and • Net operating income before loan loss provisions/assets.

104. For the following metrics, the quality of earnings deteriorates as these ratios increase:

• Trading gains/total revenues, • Other market-sensitive income/total revenues, • Other revenues/total revenues, and • Cost-income ratio.

4. Earnings capacity 105. An assessment of earnings capacity is the final step in the capital and earnings analysis. When earnings fail to cover

a bank's estimated normalized credit losses (see ¶¶106-108), the criteria add the deficit to the risk requirements that

capital needs to cover. A new metric, the earnings buffer, measures the capacity for earnings to cover normalized

losses (see table 11). When this ratio is negative, the criteria compensate for the deficiency by subtracting the

amount from TAC in calculating the RAC ratio (see the footnote in table 7).

Table 11

Computation Of The Earnings Buffer For A Hypothetical Bank

(Mil. €) Next year This year Last year

Preprovision operating income 1,180 1,105 905

One-off items 0 0 320

Normalized credit losses (579) (540) (521)

Normalized operating income (A) 601 565 704

Standard & Poor's RWAs (B) 30,000 28,000 27,500

Earnings buffer (%) (A/B) 2.00 2.02 2.56

3-year average earnings buffer (%) -- 2.19 --

RWAs--Risk-weighted assets.

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 26

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

106. Normalized credit losses are a calculation of long-term average annualized credit-related losses (see ¶¶107-108). The

criteria estimate normalized loss rates for each asset class by country using an approach based on the average

"through the cycle" annual loss rate expected to occur for a given asset class. The average includes both the low and

the peak loss rates of the credit cycle. Where data is available, the estimates are derived using a 12-year credit cycle,

including three years of recession, to estimate normalized, through-the-cycle losses. This normalized,

through-the-cycle loss estimate is more conservative than an expected loss calculation based on a shorter time

horizon, which might exclude periods of recession.

107. The criteria estimate normalized credit losses to assess earnings through the cycle, or normalized operating income

(see Appendix C of "Bank Capital Methodology And Assumptions," published Dec. 6, 2010). The assessment of

earnings reflects an adjustment to determine underlying profitability. Starting with preprovision operating income,

the adjustment removes the impact of one-off items, including significant mark-to-market write-downs of securities,

and normalized losses. The next step is to compare the residual earnings to Standard & Poor's RWAs. This ratio is

then averaged over three years (last year, current year, and next year). (See earnings buffer calculation in table 11.)

108. The calculation of normalized loss for an asset class consists of:

• Looking back at the available data on historical loss experience in each market. • Adjusting the normalized loss rate upward or downward to factor in any changes or potential changes in

underwriting standards or risks in the economy.

• Extrapolating the loss rates from the BICRA economic risk score. The extrapolation starts with the same loss rates for assets in economies with the same economic risk score, but scales them across the 10 economic risk

groups by applying reduced rates in lower-risk countries and increased rates in higher-risk countries. This scaling

is in line with the RACF's risk weights.

109. Other market or operational losses are generally unexpected and therefore intended to be covered by capital.

Consequently, when earnings are most sensitive to market and operational risks, the criteria call for interpreting the

earnings buffer with caution. For banks with significant market risk, the earnings buffer may look relatively strong,

but the measure does not take into account the volatility associated with market risk. This volatility is assessed more

qualitatively in quality of earnings (see ¶¶95-104).

5. Example of standard risk assumptions 110. The risk assumptions used in the capital and earnings analysis are the combination of the RACF's capital charges

and the normalized loss rates used in the earnings buffer. For an illustration of these risk assumptions for a

hypothetical bank based in a country in BICRA group 3 and with an economic risk score of 3 (see table 20 and

¶¶117-119 of "Bank Capital Methodology And Assumptions," published Dec. 6, 2010).

G. Risk Position

111. Risk position is the fifth of six SACP rating factors and serves to refine the view of a bank's actual and specific risks

beyond the conclusion arising from the standard assumptions in the capital and earnings analysis. Those

assumptions do not always reflect or adequately capture the specific risk characteristics of a particular bank. The

analysis described in risk position is similar to that traditionally applied to assess the asset quality of a bank.

112. To differentiate a bank's unique risk position, five areas are analyzed:

www.standardandpoors.com/ratingsdirect 27

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

• How the bank manages growth and changes in its risk positions; • The impact of risk concentrations or risk diversification; • How increased complexity adds additional risk; • Whether material risks are not adequately captured by RACF; and • Evidence of an adequate, strong, or very strong risk position, by comparing past and expected losses on the

current mix of business with those of peers and by comparing a bank's loss experience during past economic

downturns with Standard & Poor's standard risk assumptions. Greater-than-average losses may indicate a weaker

risk position.

113. The combination of the first five steps captures the degree to which the standard risk assumptions under- or

overstate a bank's specific risks. For guidance on how these five steps are combined to form a single opinion on risk

position, see tables 12-13. The descriptive characteristics are applied on a "best-fit" basis.

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 28

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

www.standardandpoors.com/ratingsdirect 29

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

114. The following example shows how the risk position assessment can combine with the capital and earnings

assessment to move the SACP. Both Bank A and Bank B have a healthy earnings buffer and adequate quality of

capital, and both maintain regulatory capital ratios comfortably above the regulatory requirement. However, Bank

A has an 11% projected RAC ratio and Bank B a 6% projected RAC ratio. Therefore, the capital and earnings

criteria view Bank A as "strong" and Bank B as "moderate." Following fundamental risk analysis, it becomes

evident that Bank A's loss experience is more volatile than peers'. While its risk management looks good, many

products are complex: There are large derivative exposures, a large and risky private equity portfolio, and a narrow

focus on advisory services, structured credit, and proprietary trading. Bank A, therefore, has a "moderate" risk

position. Alternatively, Bank B has a global retail and commercial franchise with market-leading positions in all of

its business units. The products are simple. Off-balance-sheet activity is low, and all derivatives hedge

customer-driven business. The bank has grown steadily through time, and often at a slower pace than aggressive

competitors. Volatility is lower, and losses are consistently less than average. Notably, Bank B continued reporting

profits during the previous two downturns. Bank B has a "very strong" risk position. The "moderate" and "very

strong" conclusions about risk position modify the "strong" and "moderate" capital and earnings conclusions

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 30

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

about Bank A and Bank B, respectively. All other things being equal, the effect of these two factors on Bank A is no

change to the anchor SACP and, for Bank B, the addition of one notch to the anchor SACP (see table 14).

Table 14

Impact On The SACP Of Combining Capital And Earnings And Risk Position Assessments

Bank A Bank B

Assessment Impact on SACP Assessment Impact on SACP

Capital and earnings Strong +1 notch Moderate -1 notch

Risk position Moderate -1 notch Very strong +2 notches

Combined impact No change +1 notch

1. Growth and changes in exposure 115. Since rapid expansion tends to presage outsized losses in both the banking and trading book, it is important to

monitor a bank's portfolio of risks and its movement and direction on the risk spectrum. A change in a bank's risk

means that the traditional expertise that has helped it to survive previous economic downturns may not help during

the next one.

116. Management has the capacity to manage risks associated with growth and changes in exposure when a bank is

displaying one or more of the trends below. This strength can compound other strengths to offset a weakness in the

bank's risk position:

• Showing lower recent organic or acquisitive growth and modest prospects for future growth than in the past and compared with peers with a similar economic risk score, when the lower growth is based on avoiding risk and

declining riskier growth opportunities that other banks are willing to take;

• Maintaining underwriting standards despite competitive pressures; • Reducing its risk exposure, for example by exiting risky activities or tightening underwriting standards; • Remaining focused on serving its core customer base with traditional expertise and limiting opportunistic

proprietary activities; or

• Keeping a similar portfolio of risks that limited losses experienced in previous economic downturns.

117. Management may not have the capacity to manage additional risk presented by growth or other changes in exposure

when a bank is displaying one or more of the following trends:

• Showing more aggressive recent organic or acquisitive growth and more significant prospects for future growth than in the past and compared with those of peers with a similar economic risk score;

• Moving materially into new product, customer, or market activities outside of its traditional area of expertise; or • Displaying weakening underwriting standards relative to peers with a similar economic risk score. Examples of

this include a prime mortgage lender materially weakening its standards on a loan applicant's capacity to pay,

borrower credit standing, or collateral coverage (e.g., as measured by a loan-to-value ratio, a senior secured

commercial real estate lender increasingly underwriting mezzanine or corporate development loans, or a

commercial bank increasingly underwriting larger or riskier transactions).

2. Risk concentrations and risk diversification 118. Risk concentrations of any type are a primary reason for bank failures. In contrast, some banks can demonstrate

that diversity of risks has led to lower overall losses than for less diverse peers. The criteria consider the impact of

risk concentration or diversification here because the capital and earnings analysis does not include it. The RACF

www.standardandpoors.com/ratingsdirect 31

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

produces an adjustment for concentration or diversification that the risk position analysis uses as an input (see

Appendix B in "Bank Capital Methodology And Assumptions," published Dec. 6, 2010. The business position

rating factor captures concentrations or diversification in revenue contribution by business line (¶¶62-67) and uses

concentrated earnings sources as an indicator of low-quality earnings (¶98). The risk position factor focuses on the

concentration of exposures to individual debtors, counterparties, and industries or sectors, or aggregations of risk

across asset classes and risk types.

119. There is a risk diversification benefit when a bank has the following:

• The RACF adjustment for concentration and diversification indicates a reduction in Standard & Poor's RWAs; • Geographic diversification arises from exposures that are clearly connected with a client franchise abroad and not

from opportunistic product, tax, regulatory, or currency arbitrage; and

• Sector or risk-type diversification arises from operations in activities that are no more risky than the bank's traditional core business.

120. Material risk concentrations for a bank arise from one or more of the following:

• Risk exposures by sector, country, or single name in the loan portfolio, investment portfolio, and the trading book that are more concentrated than for peers with a similar economic risk score. The RACF adjustment for

diversification and concentration supports this comparison (see Appendix B of "Bank Capital Methodology And

Assumptions," published Dec. 6, 2010;

• Underlying risk that affects several risk types as in the commercial real estate example below (¶121). The RACF adjustment does not capture this aggregation of risk;

• A limited number but material amount of counterparties for derivatives and other trades as a share of total RWAs; and

• A capital base of less than $100 million in developed markets, which makes the bank more sensitive to concentration and event risk than larger peers in these markets.

121. The RACF's adjustment for concentration or diversification is a useful input to the analysis because it is a

quantitative measure, based on standard correlation matrices (see Appendix B in "Bank Capital Methodology And

Assumptions," published Dec. 6, 2010). This adjustment may not capture all concentration issues relevant for a

specific bank. Take the example of a bank that provides a loan to a corporate customer so it can purchase premises

or develop commercial property and that at the same time holds commercial mortgage-backed securities (CMBS) on

its balance sheet. The RACF risk weights for the corporate loan exposure and the CMBS portfolio are not fine

enough to recognize the resulting concentration risk to commercial real estate. Similarly, the bank's reported

segmentation of exposure by industry, which is the data input for the RACF, may not capture certain concentrations

within a sector. For example, a bank's exposures to the broader transportation sector may hide a subsector

concentration in shipping finance.

3. Complexity 122. Greater scale may bring diversification benefits to a bank but also increase complexity. The ever-increasing level of

complexity in products, business lines, regions, and organizational structure has often outstripped the capacity of a

bank's management to manage risk. In recent years, much of the added complexity has stemmed from the growing

use of derivatives, off-balance-sheet activities, securitizations, and other exotic products. There is a danger in giving

too much credit for diversification to those highly complex institutions that are most difficult to manage.

Conversely, there is a danger in overpenalizing smaller, less complex institutions for concentration risk. The

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 32

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

opposite of complexity is the presentation of transparent and straightforward risks that are well-understood and

well-managed compared with those of peers with a similar economic risk score and product mix. However, the

absence of complexity in and of itself is rarely sufficient to improve a bank's overall risk position.

123. Management is exposed to additional risks associated with complexity when a bank has one or more of the

following:

• Business lines with complex products such as derivatives, securitizations, and structured credit such as collateralized debt obligations (CDOs) that are important to the overall group;

• Limited transparency into underlying risk positions, risk management, or earnings generation; • A siloed approach to risk management, which may hinder a consistent measurement and management of risk

exposure;

• Material dependence on mathematical models and their underlying, often complex assumptions to measure and manage risk and to value assets and liabilities;

• A portfolio that contains risks with a low probability of occurrence but high loss severity, otherwise known as tail risk;

• Balance sheet strategies that are driven by regulatory arbitrage; and • Operations in many jurisdictions or with an organizational structure with many legal entities, which may grow

beyond management's capacity to control.

124. A high and increasing ratio of total managed assets to ACE that is not mirrored in a low and declining RAC ratio

can indicate additional risk from complexity. The ratio of total managed assets to ACE is a crude measure of

leverage, insensitive to risk and susceptible to definitional accounting inconsistencies. Nevertheless, trends in the

ratio or high multiples may uncover risk exposures that other metrics do not capture. In such cases, the risks, which

hurt creditworthiness, likely are the result of off-balance-sheet activities or large derivative positions, implying

complexity and opaque risks.

125. A bank's risk position will be moderate, at best, if it has material investment banking activities or makes

more-than-modest use of strategies with regulatory arbitrage as its main purpose. Investment banking activities are

material, according to the criteria, if they are likely to contribute more than 50% to revenues over the long term.

Regulatory arbitrage strategies are significant, for example, if a bank has a particularly high multiple of total

managed assets to ACE (see ¶124).

126. When investment banking activities are less than 50%, there is no automatic cap to risk position. Instead, the

criteria assess whether senior management has the expertise and tools to fully understand and manage these risks

and the degree of clarity about how and where the bank makes its profits. The criteria recognize the limitations in

the way that capital and earnings analysis quantifies market risk.

127. Further analysis of market risk for banks with significant trading operations may result in a weak score for risk

position. When trading is a significant activity, relying solely on Value-at-Risk (VaR) is incomplete. Deeper analysis

can include reviews of the results from a banks' stress and scenario testing; policies, risk limits, practices, and

organizational structure in trading risk management; and policies, practices, and supplemental VaR data. "Lifting

The Lid On Traded Market Risk," published Oct. 31, 2006, explains how supplemental VaR data offers insights

and opportunities for making comparisons.

128. In the RACF, the standard charge for trading activities is a multiple of a bank's VaR, as used by regulators. Despite

www.standardandpoors.com/ratingsdirect 33

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

the known limitations of VaR (summarized in "Chasing Their Tails: Banks Look Beyond Value-At-Risk," published

July 12, 2005), it has the value of being widely available for financial institutions.

4. Risks the RACF does not cover 129. The most common risks that the RACF does not cover are interest rate and currency risk in the banking book and

the volatility of pension funding. There also may be other, less common, bank-specific risks relevant to an individual

bank or segment of the market that the capital framework does not capture. Such risks are material when they are

more significant for a bank than for peers with a similar economic risk score. A bank's scenario and stress testing

forms part of its risk management of these and other material contingent liabilities.

130. In addition, since the RACF equity charges are primarily based on the observed volatility in equity indices in each

country, they will not apply to a bank's equity portfolio if it is more or less risky than these indices.

a) Interest rate and currency risk in the banking book 131. The assessment of interest rate risk includes structural interest rate risk, which arises naturally from business lines

such as mortgage lending, and strategic interest rate risk, which the asset-liability management (ALM) function

strategically maintains and manages.

132. An analysis of interest rate risk includes a review of some or all of the following:

• The sensitivity of a bank's projected earnings to changes in interest rates or the shape of the yield curve based on its own stress testing;

• Senior management's engagement and awareness for setting and managing the amount of interest rate risk; • The degree of maturity gap between repricing assets and liabilities; and • The adequacy of a bank's risk management based on a review of its scenario and stress testing, optionality

characteristics of assets or liabilities with prepayment or extension options, or other behavioral characteristics

that differ from contractual ones.

133. For further guidance on the assessment of interest rate risk management, see "Assessing Enterprise Risk

Management Practices Of Financial Institutions," published Sept. 22, 2006, and "A Roadmap For Evaluating

Financial Institutions' ERM Practices, May 3, 2007.

134. The assessment of currency risk includes an examination of projected earnings to changes in currency exchange rates

based on a bank's own stress testing. Currency risk arises when assets in the loan portfolio and the bank's funding

are held in different currencies that are not hedged. The risk position of a bank is weaker when currency risk is

larger than for peers with a similar economic risk score.

b) Volatility of pension funding 135. The criteria deduct unfunded benefit scheme liabilities, including pension deficits, from TAC where a bank's

financial statements have not fully recognized them. However, the bank faces additional risk from potential

movements in the values of the scheme's assets and liabilities, particularly for defined benefit pensions, and the

RACF does not otherwise capture this risk.

136. This additional risk depends on the size of the scheme's liabilities; key actuarial assumptions including the discount

factor, life expectancy, or future salary increases; and other variables such as the investment policy and amount of

reinsurance used. When the size of the scheme's liabilities is large, a minor change in one of these variables can have

a material impact on a bank's financial strength. The pension scheme's valuation report identifies the impact on

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 34

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

scheme liabilities from changes in some of the assumptions and variables. An example of such a sensitivity test is the

impact on liabilities by increasing participant life expectancy by one year.

137. The ratio of the sensitivity tests to TAC is important. The risk position is relatively weaker when the impact on

scheme liabilities from any of the sensitivity tests identified in the valuation report relative to TAC is larger than for

peers with a similar economic risk score.

5. Evidence of stronger or weaker loss experience 138. Evidence of a stronger risk position is reflected in relatively lower recent and projected losses than for peers with a

similar economic score and similar product mix, and a better-than-average track record of losses during periods of

similar economic stress. Conversely, weaker risk positions are associated with losses that are greater than average

for peers with a similar economic risk score and similar product mix, or a worse-than-average track record of losses

during recent periods of similar economic stress.

139. Deviations from the average peer performance are explained by highlighting the root causes as any combination of

growth, concentration, and complexity, or by considering how bank-specific risk is materially different from the

standard risk assumptions in the RACF or Standard & Poor's calculation of normalized losses.

140. Examples of such material differences may be any of the following:

• Credit provisioning and loss recognition for a bank that may be more or less aggressive than for peers, • Volatility in the bank's equity portfolio that may be lower or higher than the RACF charges for equity in the

banking book,

• Legal or regulatory costs or fines that can be higher or lower than for peers in the same lines of business, or • Material insurance business (more than 10% of earnings) that can be undercapitalized compared with that for the

rest of the group.

H. Funding And Liquidity

141. Funding and liquidity, combined, are the sixth and final SACP rating factor. How a bank funds its business and the

confidence-sensitive nature of its liabilities directly affects its ability to maintain business volumes and to meet

obligations in adverse circumstances. The criteria continue the prior practice of combining an analysis of funding

and liquidity to assess financial risk.

142. The analysis of funding compares the strength and stability of a bank's funding mix, according to several metrics,

with the domestic industry average (see table 15). The criteria use that average to remain consistent with the BICRA

funding assessment.

143. The liquidity analysis centers on a bank's ability to manage its liquidity needs in adverse market and economic

conditions and its likelihood of survival over an extended period in such conditions. The analysis is both absolute

and relative to peers (see table 16).

1. Funding 144. The relative strength and potential volatility of funding are assessed by reviewing a bank's liabilities--or mixture of

retail and wholesale deposits, interbank loans, and secured and unsecured borrowing in capital markets. A bank

develops a mix of funding resulting from its strategic choices about what products and services to offer, and risk

management decisions about what funding options to use, given the availability of stable core deposit or term

www.standardandpoors.com/ratingsdirect 35

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

funding and riskier short-term wholesale funding.

145. If a bank does not have access to a central bank's funding mechanism, the funding assessment is limited to below

average at best. That's because the criteria consider this mechanism to be an important source of contingent

liquidity, but not for funding ordinary business operations on an ongoing basis. A bank's dependence on central

bank funding is assessed as part of the liquidity analysis.

146. The criteria begin the assessment of a bank's funding profile using its loan-to-deposit ratio, long-term funding ratio,

reliance on short-term wholesale funding, and overall funding mix. When no specific bank-reported figures are

available, the analysis uses estimates.

147. The next step is ranking banks within a country's banking industry according to these metrics and comparing them

against the industry average, weighted by assets. These ratios set the relative position of players within an industry

before application of the more qualitative metrics (see table 15).

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 36

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

2. Liquidity 148. The main differentiators for liquidity are a bank's relative dependence on central bank funding and its ability to

access other liquidity sources (see table 16). Liquidity becomes progressively weaker as an institution increasingly

relies on funding support from the monetary authorities. This may be the case because funding from other sources is

unavailable or prohibitively expensive, particularly if other banks are not using the facilities to the same extent.

149. The criteria use standard liquidity ratios. Some ratios will not be available for certain banks because of differences in

public disclosure in different countries. However, two liquidity ratios should be available for all banks: liquid assets

to wholesale funding, and liquid assets to core deposits. When more detailed data are available, the analysis also

considers the following ratios: liquid assets to short-term wholesale funding, and short-term wholesale funding to

total wholesale funding.

www.standardandpoors.com/ratingsdirect 37

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 38

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

150. The assessments of funding and liquidity are combined to determine the impact on the SACP (see table 17). Even if a

bank has above-average funding, its SACP may be capped if its liquidity profile is judged to be moderate or weaker.

www.standardandpoors.com/ratingsdirect 39

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

151. When comparing uses and sources of liquidity, the analysis considers different survivability periods--e.g., 30 days,

three to six months, and 12 months--because there is no telling how long a market disruption or economic

downturn may persist. Where relevant, the analysis includes the potential for local or foreign currency mismatches.

In addition, noncontractual or reputational contingencies arising from management's perceived need to preserve

franchise value are important. Examples include:

• The repurchase of commercial paper in advance of maturities; • Calling long-term debt at the first call date, despite having no contractual obligation to do so; • The provision of support to money market funds, securitizations, tender option bonds, and auction rate securities; • Support of secondary markets in assets as a market-maker; or • Protecting investors from losses on asset-backed securitizations that a bank originates.

152. The criteria rarely treat liquidity for a bank as strong, even when liquidity is well-managed, because a key source of

contingent liquidity is based on support from the central bank or monetary authorities. In other words, banks are

not entirely self-supporting. High leverage and mismatched maturities of assets and liabilities--due to the

fundamental role of maturity transformation that most banks play--make them confidence-sensitive. This means a

bank relies heavily on depositor confidence to avoid having to repay all deposit liabilities on contractual maturity

(otherwise known as a run on the bank). As a central part of contingency planning for such an event, many banks

rely on support from third parties, notably the central bank or monetary authorities. In all but the most exceptional

cases, the criteria consider this reliance on third parties to cover the contingent liquidity requirements acceptable for

an adequate assessment, at best, for investment-grade banks.

153. Strong liquidity, however, is more likely to make a real difference in default risk for a weaker bank. If it is very

liquid, a bank generally can avoid default for a longer period of time than speculative-grade banks with liquidity

that is adequate or weak.

154. Financial institutions without formal access to central bank funding restrict their exposure to short-term calls on

their liquidity or rely on excess asset liquidity and committed bank facilities to cover liquidity requirements. As such

a nonbank financial institution that does not have access to central bank liquidity may have stronger liquidity than a

regulated bank.

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 40

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

a) Comparing the uses and sources of liquidity 155. The analysis seeks to find the balance between a bank's expected and contingent uses for liquidity and its sources of

reliable liquidity during adverse market and economic conditions. The following two subsections explain the

criteria's assessment of the uses of liquidity and the sources of liquidity.

156. Given the contingent nature of a bank's liquidity requirements, the liquidity analysis focuses more on understanding

how a bank would size and manage liabilities under different stresses, and less on specific accounting-based

measures and ratios. Sizing the uses of liquidity is complicated by the choices that banks normally grant customers

and counterparties. For example, depositors are often able to withdraw their funds on demand or at relatively short

notice, wholesale investors are free to decide whether or not to roll over their funding, and customers may draw

down from committed loan facilities at any time. Meanwhile, under derivative contracts, changes in market prices or

credit perception can increase margin calls and collateral requirements.

157. If sources of liquidity are reliable, it is possible to determine how much unencumbered asset liquidity is on a bank's

balance sheet and to assess the strength of liquidity commitments made to it from other counterparties, even during

adverse conditions. An implicit part of this assessment is the strength of a bank's liquidity risk management

framework and controls, taking into account the type of business it undertakes and the markets where it operates.

b) Uses for liquidity 158. The analysis assesses the following potential uses of cash to determine a bank's contractual and contingent

short-term obligations:

• Deposit run-off and withdrawal. Deposit stability takes into account deposit composition: insured versus uninsured, international versus domestic, corporate versus retail, relationship-based versus rate-based. In each

case, the first is more stable than the second;

• Run-off of other customer funds, e.g., prime broker free credit balances. • Drawdown of credit commitments. The ability of the bank to reduce limits and the extent of undrawn

commitments to customers;

• The maturity profile of wholesale liabilities. Inability to roll over short-term unsecured borrowings (e.g., commercial paper, certificates of deposit, promissory notes) or to refinance maturing long-term unsecured debt;

• Market-driven inability to roll over maturing short-term secured debt or repurchase agreements. That is, the market can dry up altogether for lower-quality securities or, short of that, seek increased margins, collateral

requirements, or credit spreads;

• Company-specific, credit-driven increases in margin and collateral requirements, for example resulting from a breach of rating triggers;

• Settlement frictions as counterparties increasingly dispute marked-to-market valuations and delay payments; • Inability to refinance maturing securitizations backed by revolving assets; • Calls under guarantees to unrelated third parties such as standby letters of credit, performance guarantees,

securities lending indemnifications, and custody guarantees;

• Support payments to affiliates, including those that regulations require; guarantees; and keepwell or support agreements;

• Capital commitments under joint ventures; • Penalties resulting from regulatory sanctions; and • Judgments or settlements relating to litigation.

www.standardandpoors.com/ratingsdirect 41

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

c) Sources of liquidity 159. The review of a bank's sources of liquidity is focused on reliability, ranked according to dependability.

160. For purposes of table 16, the criteria include the following sources:

• Drawdown of unrestricted cash and short-term deposits; • Systemwide liquidity facilities at central banks or other government sources, both routine and extraordinary,

determined by unencumbered assets that the central bank would qualify as collateral and liquidity available in

exchange for these assets after central bank haircuts;

• Drawdown of committed credit facilities, subject to financial covenants and headline considerations; • The sale or repo of unencumbered high-quality liquid securities in the open market. Because banks make different

assumptions about what qualifies as liquid, these criteria aim to understand and compare them to those in the

market value criteria for rating transactions backed by securities;

• Within corporate groups, the ability to access funds from affiliates in the form of advances or capital, subject to regulatory and covenant restrictions;

• Liquidation of short-term advances to other financial institutions sold and reverse repos; • Cash available from maturing advances to customers; • Accessing the debt and stock markets to the extent still possible; • Accessing securitization or covered bond markets through established facilities or asset sales programs; and • Whole loan sales.

161. Where regulatory or accounting data exist, the aim of the criteria is to quantify the balance between the uses and

sources of liquidity. For an example, see "Liquidity Risk Analysis: Canadian Banks," published June 27, 2007.

VIII. METHODOLOGY: GOVERNMENT SUPPORT FRAMEWORK

162. The support framework criteria factors in the likelihood of support from a government or parent group into the

ratings on a bank by assessing the relationship between the parties. This part (part VIII) of this article and "Rating

Government-Related Entities: Methodology And Assumptions," published Dec. 9, 2010, address government

support while "Group Rating Methodology And Assumptions," published Nov. 9, 2011, addresses group support.

The likelihood of government support is factored both into the SACP and ICR (see chart 4).

163. Government influence on banks is usually positive for sovereign creditworthiness but on occasion is negative. A

government may elect to support bank even if it erodes sovereign creditworthiness. This was the case in Ireland in

2010. (See "Republic of Ireland Long-Term Rating Lowered To 'AA-' On Higher Banking Sector Fiscal Costs,"

published Aug. 24, 2010.)

164. For a government-related financial institution that fulfills a public policy role or where the government ownership is

strategic and long-term, the likelihood of support is assessed using the methodology for rating GREs (see "Rating

Government-Related Entities: Methodology And Assumptions," Dec. 9, 2010). The importance of the bank to the

government and the strength of the link between the government and the bank determine the likelihood of

government support.

165. For a private-sector commercial bank (which does not qualify to be characterized as a GRE), the criteria assess the

likelihood of government support by drawing on assessments of both the bank's "systemic importance," that is, in

maintaining overall confidence in the financial system, and the government's tendency to support private-sector

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 42

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

commercial banks. The motivation for governments to support private-sector commercial banks is not as clear as

that for GREs. Governments act to support their national economies and financial systems. This often results in

added protection for senior creditors of systemically important commercial banks, but the link is by no means

certain.

166. The extraordinary government support a private-sector commercial bank is likely to receive is by no means certain.

This uncertainty means that the support uplift will never result in equal ratings on a non-GRE bank and on the

sovereign because of other variables. For example, the government may:

• Be less able to support a range of banks in a countrywide financial crisis because of its own balance sheet constraints or because an individual bank may be large relative to the domestic economy;

• Be less willing to provide financial support if the specific crisis affects a particular bank rather than all the banks in the national financial system and will have limited knock-on implications for the whole system;

• Change its attitude toward supporting the banking sector over time; or • Not provide support in time to prevent a default or may provide support that does not fully cover all senior

creditors.

www.standardandpoors.com/ratingsdirect 43

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 44

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

A. Factoring Government Support Into The SACP

167. The SACP includes four types of government support or negative interference:

• System support is the support which a government provides to all banks in a financial system. This type of support is assessed as part of economic risk and industry risk analysis in the BICRA methodology.

• Direct support is the targeted support which a government provides to a specific bank in crisis. Such support may manifest, and therefore be assessed, in the business position, capital and earnings, risk position, or funding and

liquidity SACP factors.

• Government interference may take the form of directed lending and actions that create market distortions. These are captured by industry risk in the BICRA methodology and business position and risk position in the SACP.

• Additional short-term support for banks with high or moderate systemic importance.

1. System support 168. The criteria include system support in the SACP. Governments support their financial systems to limit the long-term

damage of a banking crisis on the economy. Governments provide system support to financial institutions through

the legal infrastructure, banking regulatory frameworks, and their role in funding banks and maintaining confidence

in the financial system. System support is aimed at preserving confidence in the country's financial system, especially

during periods of economic stress.

169. The criteria consider any support available to the wider system as system support, whether it is ongoing or

extraordinary. In recent years, there have been many cases of system support that is extraordinary in nature and not

ongoing. Examples are increased depositor insurance, government-guaranteed liquidity and debt programs, and the

eligibility of lower-quality assets as central bank collateral.

170. The BICRA methodology assesses system support, which feeds directly into the SACP via economic risk and

industry risk rating factors. Therefore, under the BICRA methodology, changes in a government's support for the

country's financial system may result in SACP changes for banks with exposure to that country.

2. Direct support 171. The criteria include direct support in the SACP. Governments may provide direct support to an individual bank by

providing liquidity or capital injections, or by buying or insuring risky assets. These actions may lead to a

strengthening in the bank's stand-alone credit characteristics. The criteria aim to quantify this direct support and

factor it into the relevant rating factor: capital and earnings, risk position, or funding and liquidity.

172. Direct support is included in the SACP once the government has made a commitment to providing it. The criteria

treat government support as committed when it has received the appropriate political approvals, such as from

Congress or parliament. In some countries, laws exist to give the administration the authority to act without further

approvals.

173. However, it is unlikely that the direct support would raise the bank's SACP to the level it was before the difficulties

began. The bank's business position will likely be weaker than before the stress. The franchise will have been

damaged, and execution risk will remain for the bank in managing through the crisis and back to independence.

www.standardandpoors.com/ratingsdirect 45

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

3. Government interference 174. Various government actions can weaken a bank's creditworthiness by creating distortions or inefficiencies. These

can take various forms, including government actions that influence a bank's business decisions. Two specific

examples are directed lending and the creation of market distortions.

175. Directed lending. Governments can intervene via ownership or regulation and direct banks to lend to particular

borrowers or sectors for political purposes. This type of intervention, called directed lending, is a negative rating

factor for the SACP and is reflected under the business position rating factor (see table 6). Lending based on the

bank's assessment of the borrowers' ability to repay will generally lead to fewer credit losses than lending based on a

government's directions. Consequently, credit losses on directed lending will be greater than the industry average for

specific asset classes, which the risk position rating factor assesses (see tables 12-13).

176. Market distortions. A government can also influence the nature of competition in a banking market.

Government-owned or -controlled banks can compete on uneconomic terms, forcing a structurally low-margin

environment across the sector. BICRA addresses market distortions in industry risk as part of the consideration of

competitive dynamics. Therefore, it is reflected in a bank's anchor SACP.

4. Additional short-term support 177. If the SACP of a bank with high or moderate systemic importance declines rapidly (by more than two notches at a

single review) and Standard & Poor's expects the government to provide additional short-term support, the criteria

allow for additional temporary uplift of the SACP (see ¶¶197-203).

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 46

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

B. Factoring Government Support Into The Indicative ICR

178. In the case of a positive assessment of the likelihood that a bank would receive "future extraordinary support" in a

crisis from a sovereign government, the criteria may allow the addition of one or more notches to the SACP for

"support uplift" to determine the indicative ICR. On the other hand, the government may not offer such support.

Consequently, the indicative ICR will be the same as the SACP.

179. The indicative ICR results from adding notches for support uplift to the stand-alone credit profile (SACP). The

methodology for factoring in extraordinary government and group support consists of four steps (see chart 6):

• First, assess the likelihood for future extraordinary government support. • Second, assess the likelihood for future extraordinary group support (see "Group Rating Methodology And

Assumptions," published Nov. 9, 2011).

• Third, take the higher of the result from the first and second steps. • Fourth, apply the criteria shown in ¶¶206-212 to the indicative ICR for a bank.

180. Faced with a financial crisis, a government will often, but not always, provide additional support to protect

www.standardandpoors.com/ratingsdirect 47

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

confidence in its economy, with the expectation that the cost of this additional support is less damaging to the

overall economy than allowing banks to fail. Financial institutions, in particular banks, fulfill the crucial functions

of safeguarding national savings, allocating savings and deposits to companies and individuals in the form of loans

and investments, and serving as intermediaries and agents in financial transactions. Governments implement

monetary policy via the banking industry. They also maintain lending arrangements for banks to balance their

books on a daily basis and meet short-term liquidity needs. Many governments closely regulate banks and most

other financial institutions to ensure that the industry as a whole can perform these crucial roles in a manner that

maintains the confidence on which the modern financial system depends.

181. A bank usually receives help from either its parent group or government--not both. Consequently, if a bank is a

subsidiary, its creditworthiness is determined using criteria for both government support and group support. The

indicative ICR is the strongest indicative ICR resulting from either the first approach or the second. The ICR can be

higher than the foreign currency rating on the sovereign where the bank is domiciled, only if the bank can meet the

conditions listed in ¶209. It is possible that the SACP can be stronger or the indicative ICR based on group support

can be stronger than the foreign currency rating of the sovereign where the bank is domiciled.

182. The criteria for determining rating notch uplift from the expectation of extraordinary government support comprise

five steps:

• First, determine the degree of a bank's systemic importance (section 1); • Second, determine a government's tendency to support private-sector banks (section 2); • Third, establish the likelihood that the government will provide support to a particular bank (section 3); • Fourth, determine whether additional short-term support is available (section 4); and • Fifth, link government-supported bank ratings to sovereign ratings (section 5).

183. A private-sector commercial bank is classified as having "high," "moderate," or "low" systemic importance as

defined below. A government's tendency to support such a bank falls into three categories: "highly supportive,"

"supportive," and "uncertain." The criteria then combine the two classifications to determine the likelihood of

direct government support in the future (see table 20).

1. Systemic importance 184. Systemic importance is the degree to which a bank's failure impacts all or parts of the financial system and the real

economy of the country where the bank operates. A bank has high, moderate, or low systemic importance. It is

possible that a bank classified as having high or moderate systemic importance might not receive support in a time

of stress because no one can predict with certainty whether a sovereign will provide it. On the other hand, in the

event of a crisis, the government may decide to support a bank even though it may have low systemic importance. A

bank is not automatically classified as having high, moderate, or low systemic importance if the government or local

market participants refer to it that way. Standard & Poor's classification will be determined in line with the criteria

(see table 18 and ¶¶185-190).

185. High systemic importance. The failure of a bank classified as having high systemic importance is likely to have a

high adverse impact on the financial system and the real economy. In particular, a bank has high systemic

importance if a default of its senior unsecured obligations is likely to weaken the country's financial system, limit the

availability of credit for the private sector, and trigger a significant financial stress at several other financial

institutions.

186. Although size is not the only determining factor, a bank with high systemic importance will usually be one that

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 48

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

maintains a substantial market share--typically more than 10%, particularly in retail banking--with a leading

position and brand recognition in the country. High systemic importance is also a factor of the level of

interconnectedness, or linkages of a financial institution with other parts of the financial system. For example, the

bank may be a significant counterparty within the country and international financial system or play a critical role

in the national payments system, such that its failure will lead to a loss of confidence in the financial system and

significant losses among other counterparties in the market. In addition to these factors, a bank may have high

systemic importance because no other institution can step into its key role in the economy if it fails.

187. Moderate systemic importance. The failure of a bank classified as having moderate systemic importance is likely to

have a material, but manageable, adverse impact on the financial system and the real economy. In particular, a bank

has moderate systemic importance if a default on its senior unsecured obligations is likely to lead to disruption in the

provision of financial services to a specific region or sector of the economy.

188. A bank with moderate systemic importance is likely to maintain a significant market share in retail banking at the

national level, or be a leading provider of banking services to a particular region or sector that plays a significant

role in the economy. The systemic implications of a default of such a bank will be more manageable at a national

level than a default of a bank with high systemic importance, but the effect in specific parts of the economy can be

considerable. Banks with moderate systemic importance may also be leading providers of politically sensitive

products, such as residential mortgages. A classification of moderate systemic importance for a bank means that if it

fails, other counterparties are likely to take on the failed bank's market role.

189. Low systemic importance. A bank has low systemic importance when it does not fit the criteria for high or

moderate systemic importance. The majority of banks in a banking industry are likely to be in this category.

However, if the market is particularly concentrated, fewer banks are likely to have low systemic importance.

190. The criteria recognize the difficulty in predicting sovereign support. In the event of a crisis, the sovereign may decide

to support a bank even though it may have low systemic importance. The classification of low systemic importance

reflects the lack of an obvious incentive for a sovereign government to prevent the failure of this type of bank.

Table 18

Systemic Importance

Descriptor Observations

High systemic importance

A loss of confidence in a bank is likely to lead to a loss of confidence in the entire national banking system. In particular, a default of a bank’s senior unsecured obligations is likely to weaken the country's financial system, limit the availability of credit for the private sector, and trigger a significant financial stress at several other financial institutions.

Moderate systemic importance

A loss of confidence in a bank may lead to a loss of confidence in the entire banking system. In particular, a default on a bank’s senior unsecured obligations can weaken the financial system and limit the supply of credit for the private sector.

Low systemic importance

A bank has low systemic importance when it does not fit the criteria for high or moderate systemic importance. The majority of banks in a banking industry are likely to be in this category. However, if the market is particularly concentrated, fewer banks are likely to have low systemic importance.

2. Government tendency to support private-sector banks 191. The tendency of governments to support financial institutions varies among countries and can change over time,

particularly as legislators respond to the effects of a banking crisis. The criteria assess the capacity and willingness of

sovereigns to support failing banks during a crisis and classify sovereigns into three groups, "highly supportive,"

"supportive," and "uncertain" (see table 19).

www.standardandpoors.com/ratingsdirect 49

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

3. Likelihood of extraordinary government support in the future 192. The criteria classify the likelihood that a bank would receive extraordinary government support in the future as

high, moderately high, moderate, or low. That is determined by combining the assessments of a bank's systemic

importance and a government's tendency to support banks (see table 20).

Table 20

Likelihood Of Extraordinary Government Support In The Future

Government's tendency to support private-sector commercial banks

Systemic importance Highly supportive Supportive Uncertain

High High (table 21) Moderately high (table 22) Low

Moderate Moderately high (table 22) Moderate (table 23) Low

Low Low Low Low

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 50

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

193. The indicative ICR for banks with high, moderately high, or moderate likelihood of extraordinary support is

established by combining the SACP on the bank and the rating on the sovereign according to tables 21-23,

respectively.

Table 21

High Likelihood Of Extraordinary Government Support

Government's local currency rating

SACP AAA AA+ AA AA- A+ A A- BBB+ BBB BBB- BB+ BB BB- B+ B B-

aaa AAA

aa+ AA+ AA+

aa AA+ AA AA

aa- AA AA AA- AA-

a+ AA- AA- AA- A+ A+

a AA- A+ A+ A+ A A

a- AA- A+ A+ A A A- A-

bbb+ A+ A+ A A A A- BBB+ BBB+

bbb A A A A- A- A- BBB+ BBB BBB

bbb- A- A- A- A- BBB+ BBB+ BBB+ BBB BBB- BBB-

bb+ BBB+ BBB+ BBB+ BBB+ BBB+ BBB BBB BBB BBB- BB+ BB+

bb BBB BBB BBB BBB BBB BBB BBB- BBB- BBB- BB+ BB BB

bb- BBB- BBB- BBB- BBB- BBB- BBB- BBB- BB+ BB+ BB+ BB BB- BB-

b+ BB+ BB+ BB+ BB+ BB+ BB+ BB+ BB+ BB BB BB- BB- B+ B+

b BB BB BB BB BB BB BB BB BB BB- BB- BB- B+ B B

b- BB- BB- BB- BB- BB- BB- BB- BB- BB- BB- B+ B+ B B- B- B-

ccc+ B+ B+ B+ B+ B+ B+ B+ B+ B+ B+ B B B- B- B- CCC+

ccc B B B B B B B B B B B- B- B- CCC+ CCC+ CCC+

ccc- B- B- B- B- B- B- B- B- B- B- CCC+ CCC+ CCC+ CCC CCC CCC

cc B- B- B- B- CCC+ CCC+ CCC+ CCC+ CCC+ CCC+ CCC CCC CCC CCC- CCC- CC

SACP--Stand-alone credit profile.

www.standardandpoors.com/ratingsdirect 51

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

Table 22

Moderately High Likelihood Of Extraordinary Government Support

Government's local currency rating

SACP AAA AA+ AA AA- A+ A A- BBB+ BBB BBB- BB+ BB BB- B+ B B-

aaa AAA

aa+ AA+ AA+

aa AA AA AA

aa- AA AA- AA- AA-

a+ AA- AA- A+ A+ A+

a A+ A+ A+ A A A

a- A+ A A A A- A- A-

bbb+ A A A- A- A- BBB+ BBB+ BBB+

bbb A- A- A- BBB+ BBB+ BBB+ BBB BBB BBB

bbb- BBB+ BBB+ BBB+ BBB+ BBB BBB BBB BBB- BBB- BBB-

bb+ BBB BBB BBB BBB BBB BBB- BBB- BBB- BB+ BB+ BB+

bb BBB- BBB- BBB- BBB- BBB- BBB- BB+ BB+ BB+ BB BB BB

bb- BB+ BB+ BB+ BB+ BB+ BB+ BB+ BB BB BB BB- BB- BB-

b+ BB BB BB BB BB BB BB BB BB- BB- BB- B+ B+ B+

b BB- BB- BB- BB- BB- BB- BB- BB- BB- B+ B+ B+ B B B

b- B+ B+ B+ B+ B+ B+ B+ B+ B+ B+ B B B B- B- B-

ccc+ B B B B B B B B B B B- B- B- CCC+ CCC+ CCC+

ccc B- B- B- B- B- B- B- B- B- B- CCC+ CCC+ CCC+ CCC CCC CCC

ccc- CCC+ CCC+ CCC+ CCC+ CCC+ CCC+ CCC+ CCC+ CCC+ CCC+ CCC CCC CCC CCC- CCC- CCC-

cc CCC CCC CCC CCC CCC CCC CCC CCC CCC CCC CCC- CCC- CCC- CC CC CC

SACP--Stand-alone credit profile.

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 52

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

Table 23

Moderate Likelihood Of Extraordinary Government Support

Government's local currency rating

SACP AAA AA+ AA AA- A+ A A- BBB+ BBB BBB- BB+ BB BB- B+ B B-

aaa AAA

aa+ AA+ AA+

aa AA AA AA

aa- AA- AA- AA- AA-

a+ AA- A+ A+ A+ A+

a A+ A+ A A A A

a- A A A A- A- A- A-

bbb+ A- A- A- A- BBB+ BBB+ BBB+ BBB+

bbb BBB+ BBB+ BBB+ BBB+ BBB+ BBB BBB BBB BBB

bbb- BBB BBB BBB BBB BBB BBB BBB- BBB- BBB- BBB-

bb+ BBB- BBB- BBB- BBB- BBB- BBB- BBB- BB+ BB+ BB+ BB+

bb BB+ BB+ BB+ BB+ BB+ BB+ BB+ BB+ BB BB BB BB

bb- BB BB BB BB BB BB BB BB BB BB- BB- BB- BB-

b+ BB- BB- BB- BB- BB- BB- BB- BB- BB- BB- B+ B+ B+ B+

b B+ B+ B+ B+ B+ B+ B+ B+ B+ B+ B+ B B B B

b- B B B B B B B B B B B B B- B- B- B-

ccc+ B- B- B- B- B- B- B- B- B- B- B- B- B- CCC+ CCC+ CCC+

ccc CCC+ CCC+ CCC+ CCC+ CCC+ CCC+ CCC+ CCC+ CCC+ CCC+ CCC+ CCC+ CCC+ CCC CCC CCC

ccc- CCC CCC CCC CCC CCC CCC CCC CCC CCC CCC CCC CCC CCC CCC- CCC- CCC-

cc CCC- CCC- CCC- CCC- CCC- CCC- CCC- CCC- CCC- CCC- CC CC CC CC CC CC

SACP--Stand-alone credit profile.

194. For a bank with a low likelihood of support, the indicative ICR is the same as the SACP. But the ICR may be

different from the indicative ICR after applications of the criteria for group support (see "Group Rating

Methodology And Assumptions," published Nov. 9, 2011) or when the ICR is set (see ¶¶19-24).

195. Even if the likelihood of government support is "high" and the sovereign long-term local currency rating is 'AAA', a

bank with an SACP of 'aa+' will not receive an ICR of 'AAA'. This is in line with Standard & Poor's view that

government support for non-GRE banks cannot be predicted with certainty.

196. The indicative ICRs for banks shown in tables 21-23 are subject to the criteria shown in ¶¶206-212 below.

4. Additional short-term support for banks with high or moderate systemic importance 197. These criteria provide for additional short-term uplift of a bank's SACP (beyond the uplift shown in tables 21-23) if

all the following conditions are satisfied:

• If the bank is classified as having high or moderate systemic importance, • If the bank's SACP has declined rapidly by two or more notches in a single review, and • If the government is expected to provide additional short-term support.

www.standardandpoors.com/ratingsdirect 53

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

198. In practice, it can take some time for a government to make a specific commitment to provide additional short-term

support after a financial problem at a systemically important bank surfaces. In such cases, the criteria estimate the

amount or range of support.

199. For example, if a bank's SACP declines rapidly as described above, the ICR will likely be lowered by at least one

notch and likely placed on CreditWatch with negative implications. In conjunction with the CreditWatch action, the

criteria will likely require:

• A confirmation by the government of the importance of the bank through a public statement of support that covers the bank's obligations to its senior creditors,

• An estimate of the amount or range of support required to restore the bank's capital or liquidity to the regulatory minimum (see ¶202), and

• As assessment of whether the sovereign has sufficient capacity to provide this level of support.

200. If the government makes no public statement of support in the CreditWatch period, the assessment of systemic

importance is changed to low, uplift for government support is removed, and the ICR is lowered to the level of the

SACP.

201. If there are doubts about the sovereign's ability to support the institution, the ICR is lowered to the same level as the

SACP. In addition, uplift for all other banks with high or moderate systemic importance in that country is

reassessed.

202. If the government makes a clear statement of the intent to support the bank, the criteria allow for an estimate of the

monetary amount of support that will be made available. This estimate is based either on details provided by the

government or by a Standard & Poor's calculation of the amount of fresh capital or liquidity required to restore

capital or liquidity to the regulatory minimum--that is, the amount that will keep the bank a going concern

according to the regulators. The calculation is geared to the minimum regulatory requirement, unless there is

guidance that the regulator expects the bank to comply with a different requirement.

203. To establish the number of notches of temporary uplift for additional short-term support, this estimate is included in

the evaluation of capital, risk, or liquidity. As long as the government has not committed the support, total uplift to

the SACP comprises temporary uplift for additional short-term government support and the likelihood of

extraordinary government support in the future (see table 20). After the government commits the support, it is

factored into the SACP and the indicative ICR is set according to the relevant support table (see tables 21-23).

5. Linking government-supported bank ratings to sovereign ratings 204. The criteria for rating banks have a direct link with the criteria for rating sovereigns. Specifically, the sovereign

criteria assess the impact on a sovereign's rating of the contingent liabilities related the financial sector (see

"Sovereign Government Rating Methodology And Assumptions," ¶¶100-103, published June 30, 2011). This

assessment is done by estimating the potential recapitalization needs of the entire banking sector in case of a

systemic banking crisis associated with a stress level defined in the RACF (see. "Bank Capital Methodology And

Assumptions," published Dec. 6, 2010)

205. After determining the contingent liabilities related to the financial sector, the criteria evaluate the impact of the

overall level of contingent liabilities on the sovereign's fiscal profile, which affects its rating. The local currency

sovereign rating is combined with the SACP on a bank to determine its indicative ICR according to tables 21-23.

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 54

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

C. Rating Banks Above The Sovereign

206. The criteria may result in an SACP or an ICR on a bank above the foreign currency rating on the sovereign where

the bank is domiciled.

207. Such cases are rare because the criteria acknowledge that banks are leveraged institutions that are dependent on the

sovereign government for liquidity and other forms of system support. In addition, the sovereign's regulatory and

supervisory powers may restrict a bank's or financial system's flexibility.

208. Banks are affected by many of the same economic factors that cause sovereign stress. This sovereign stress can cause,

among other things, a sharp deterioration in a bank's asset values, more expensive foreign currency liquidity,

shortages in local currency liquidity, a harsher regulatory environment, mandated changes in credit terms, higher

taxes, and declining public services. These developments can exacerbate domestic economic conditions and increase

bad debts for banks.

209. A bank will need to meet all of the following conditions to have ratings higher than the foreign currency ratings on

the country of domicile:

• Sufficient capital and liquidity to cover the stress that Standard & Poor's associates with a sovereign default scenario;

• Institutional characteristics, sovereign policy flexibility, or historical precedence suggest that there is a high likelihood that the sovereign will not interfere or acquire resources from the bank and that it is unlikely to require

additional support from the sovereign;

• The expectation that the financial sector, or at least the specific bank, will remain in a net external asset position; • Little loan or other asset exposure to the sovereign or the wider public sector, and an expectation that this will

not change;

• Earnings, capital, and other ratios are stronger than those of similarly rated banks in countries with lower-risk financial systems as measured by BICRA scores; and

• A country transfer and convertibility (T&C) risk assessment that does not cap the ratings on the bank at the rating of the sovereign (see ¶210).

210. The transfer and convertibility (T&C) risk assessment on the sovereign caps the foreign currency rating on the bank.

This assessment reflects Standard & Poor's view of the likelihood of a sovereign restricting access to foreign

exchange that a non-sovereign needs to satisfy debt service obligations. For most countries, Standard & Poor's

analysis concludes that this risk is less than the risk of sovereign default on foreign-currency obligations. Therefore,

most T&C assessments exceed the sovereign foreign currency rating (see "Criteria For Determining Transfer And

Convertibility Assessments," published May 18, 2009).

211. For a bank that is a subsidiary, the parent will need to meet those same preconditions for the subsidiary to have an

indicative ICR that is higher than the sovereign's foreign currency rating resulting from group support from a

foreign parent or affiliate. If the parent has not demonstrated its capacity and willingness to provide a subsidiary

with sufficient support to withstand the stress associated with a sovereign default, the ICR is capped by the foreign

currency rating on the sovereign where the subsidiary is domiciled.

212. Bank branches are subject to the same conditions as separate legal entities. The ratings on bank branches, as part of

the same legal entity, are at the same level as on a bank itself, unless the branch is located in another country. If a

www.standardandpoors.com/ratingsdirect 55

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

branch is in another legal jurisdiction, the criteria consider whether actions of the "host" sovereign can affect the

ability of the branch to service its obligations. The criteria do not assign ratings to a branch that are higher than

those on the host sovereign unless the conditions listed above are met or the branch's creditors can--without

impediment--access all of their funds in a timely manner via any other branch located in another jurisdiction. In

most cases, the host sovereign foreign currency rating will cap the ratings on a branch. If the host sovereign has

higher ratings than the bank, the ratings on the branch and bank are equalized.

[1] "Causes of the Recent Financial and Economic Crisis," Ben S. Bernanke, Before the Financial Crisis Inquiry

Commission, Washington, D.C., Sept. 2, 2010 (U.S. Congress).

[2] "Final report of the Commission of Experts for limiting the economic risks posed by large companies," Sept. 30,

2010 (Swiss Confederation).

[3] "Final Report Recommendations," Independent Commission on Banking, Sept. 12, 2011 (U.K.).

APPENDIX

The bank criteria supersede or partially supersede the articles below. All articles listed below are available on

RatingsDirect on the Global Credit Portal, unless otherwise stated.

Superseded

• Applying Group Methodology To Independent U.S. Investment Banks, June 2, 2008 • Assessing Trading Risk Management Practices Of Financial Institutions, Oct. 17, 2005 • Assumptions For Base-Case Credit Losses For Italian Banks, April 23, 2010 • Bank Survivability Criteria, March 24, 2004 • External Support Key In Rating Private Sector Banks Worldwide, Feb. 27, 2007 • FI Criteria: Bank Rating Analysis Methodology Profile, March 18, 2004 • Financial Institutions Bank Fundamental Strength Ratings, July 10, 2005 • Franchise Stability, Confidence Sensitivity, And The Treatment Of Hybrid Securities In A Downturn, Dec. 1,

2008

• How Systemic Importance Plays A Significant Role In Bank Ratings, July 3, 2007 • Securities Company Ratings Analysis Methodology Profile, April 29, 2004 • Sovereign Risk for Financial Institutions, Feb. 16, 2004 • The Ratings Approach To Australian Government-Guaranteed Debt (Updated), June 10, 2009 • The Ratings Approach To U.S. Financial Institutions' FDIC-Guaranteed Commercial Paper, April 6, 2009 • U.S. Mortgage Bank Rating Analysis Methodology Profile, March 18, 2004

Partially superseded

• A Roadmap For Evaluating Financial Institutions' ERM Practices, May 3, 2007 • Group Methodology, April 22, 2009; this article partially supersedes the criteria for banks but will not affect the

criteria for insurance companies

The following criteria articles are not affected by publication of this criteria article. They will therefore stand

alongside the bank criteria to represent the body of Standard & Poor's criteria governing financial institutions.

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 56

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

General

• Stand-Alone Credit Profiles: One Component Of A Rating, Oct. 1, 2010 • Credit Stability Criteria, May 3, 2010 • Understanding Standard & Poor's Rating Definitions, June 3, 2009 • Criteria For Determining Transfer And Convertibility Assessments, May 18, 2009 • Principles Of Corporate And Government Ratings, June 26, 2007

Financial institutions

• Analytical Approach To Assessing Nonoperating Holding Companies, March 17, 2009 • Assumptions: Analytical Adjustments For Captive Finance Operations, June 27, 2008 • Bank Spreadsheet Data Definitions, May 2, 2005 • Commercial Paper I: Banks, March 23, 2004 • Commercial Paper II: Finance Companies, March 22, 2004 • Counterparty And Debt Rating Methodology For Alternative Investment Organizations: Hedge Funds, Sept. 12,

2006

• Equity Credit for Hybrid Securities Issued by Asset Managers, Nov. 13, 2006 • Finance Company Ratios, March 18, 2004 • Issues Of Subordination for Hedge Fund Debt, Sept. 13, 2007 • Liquidity Risk Analysis: Canadian Banks, June 27, 2007 • Methodology For Analyzing Funding And Liquidity Positions Of Bank-Licensed Investment Companies, July 2,

2010

• Methodology For Mapping Short- And Long-Term Issuer Credit Ratings For Banks, May 4, 2010 • Methodology: Hybrid Capital Issue Features: Update On Dividend Stoppers, Look-Backs, And Pushers, Feb. 10,

2010

• Microfinance Institutions: Methodology And Assumptions: Key Credit Factors, Aug. 5, 2009 • Rating Asset Management Companies, March 18, 2004 • Rating Network Payment Providers, June 1, 2005 • Rating Private Equity Companies' Debt And Counterparty Obligations, March 11, 2008 • Rating Securities Companies, June 9, 2004 • Rating Sovereign-Guaranteed Debt, April 6, 2009 • Recovery Ratings For U.S. Finance Companies, June 19, 2008 • Standard & Poor's Updated Methodology For Rating Exchanges And Clearinghouses, July 10, 2006

RELATED CRITERIA AND RESEARCH

All articles listed below are available on RatingsDirect on the Global Credit Portal, unless otherwise stated.

Criteria

• Banking Industry Country Risk Assessment Methodology And Assumptions, Nov. 9, 2011 • Group Rating Methodology And Assumptions, Nov. 9, 2011 • Bank Hybrid Capital Methodology And Assumptions, Nov. 1, 2011 • Sovereign Government Rating Methodology And Assumptions, June 30, 2011 • Rating Government-Related Entities: Methodology And Assumptions, Dec. 9, 2010 • Bank Capital Methodology And Assumptions, Dec. 6, 2010

www.standardandpoors.com/ratingsdirect 57

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

Research

• The Evolving Landscape For Banks Requires A Robust Analytical Framework, Nov. 1, 2011 • How Standard & Poor's Intends To Finalize Its Bank Criteria And Apply Them To Ratings In The Fourth

Quarter Of 2011, Nov. 1, 2011

• For Universal Banks, The Recent Dominance Of Investment Banking Is Giving Way To More Balanced Earnings, June 30, 2011

• Bank Resolution Regimes: Potential Rating Implications As Sovereign Support Frameworks Evolve, March 16, 2011

Watch the related CreditMatters TV segment titled, "Standard & Poor's Publishes Its Revised Bank Ratings

Criteria," dated Nov. 9, 2011.

Listen to the related podcast titled, "Standard & Poor’s Updated Bank Rating Criteria: What's Behind The

Changes," dated Nov. 22, 2011.

These criteria represent the specific application of fundamental principles that define credit risk and ratings

opinions. Their use is determined by issuer- or issue-specific attributes as well as Standard & Poor's Ratings

Services' assessment of the credit and, if applicable, structural risks for a given issuer or issue rating. Methodology

and assumptions may change from time to time as a result of market and economic conditions, issuer- or

issue-specific factors, or new empirical evidence that would affect our credit judgment.

Additional Contact: Financial Institutions Ratings Europe; [email protected]

Standard & Poors | RatingsDirect on the Global Credit Portal | November 9, 2011 58

916400 | 300003452

Criteria | Financial Institutions | Banks: Banks: Rating Methodology And Assumptions

S&P may receive compensation for its ratings and certain credit-related analyses, normally from issuers or underwriters of securities or from obligors. S&P reserves the right to disseminate its opinions and analyses. S&P's public ratings and analyses are made available on its Web sites, www.standardandpoors.com (free of charge), and www.ratingsdirect.com and www.globalcreditportal.com (subscription), and may be distributed through other means, including via S&P publications and third-party redistributors. Additional information about our ratings fees is available at www.standardandpoors.com/usratingsfees.

S&P keeps certain activities of its business units separate from each other in order to preserve the independence and objectivity of their respective activities. As a result, certain business units of S&P may have information that is not available to other S&P business units. S&P has established policies and procedures to maintain the confidentiality of certain non-public information received in connection with each analytical process.

Credit-related analyses, including ratings, and statements in the Content are statements of opinion as of the date they are expressed and not statements of fact or recommendations to purchase, hold, or sell any securities or to make any investment decisions. S&P assumes no obligation to update the Content following publication in any form or format. The Content should not be relied on and is not a substitute for the skill, judgment and experience of the user, its management, employees, advisors and/or clients when making investment and other business decisions. S&P's opinions and analyses do not address the suitability of any security. S&P does not act as a fiduciary or an investment advisor. While S&P has obtained information from sources it believes to be reliable, S&P does not perform an audit and undertakes no duty of due diligence or independent verification of any information it receives.

No content (including ratings, credit-related analyses and data, model, software or other application or output therefrom) or any part thereof (Content) may be modified, reverse engineered, reproduced or distributed in any form by any means, or stored in a database or retrieval system, without the prior written permission of S&P. The Content shall not be used for any unlawful or unauthorized purposes. S&P, its affiliates, and any third-party providers, as well as their directors, officers, shareholders, employees or agents (collectively S&P Parties) do not guarantee the accuracy, completeness, timeliness or availability of the Content. S&P Parties are not responsible for any errors or omissions, regardless of the cause, for the results obtained from the use of the Content, or for the security or maintenance of any data input by the user. The Content is provided on an "as is" basis. S&P PARTIES DISCLAIM ANY AND ALL EXPRESS OR IMPLIED WARRANTIES, INCLUDING, BUT NOT LIMITED TO, ANY WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR USE, FREEDOM FROM BUGS, SOFTWARE ERRORS OR DEFECTS, THAT THE CONTENT'S FUNCTIONING WILL BE UNINTERRUPTED OR THAT THE CONTENT WILL OPERATE WITH ANY SOFTWARE OR HARDWARE CONFIGURATION. In no event shall S&P Parties be liable to any party for any direct, indirect, incidental, exemplary, compensatory, punitive, special or consequential damages, costs, expenses, legal fees, or losses (including, without limitation, lost income or lost profits and opportunity costs) in connection with any use of the Content even if advised of the possibility of such damages.

Copyright © 2011 by Standard & Poors Financial Services LLC (S&P), a subsidiary of The McGraw-Hill Companies, Inc. All rights reserved.

www.standardandpoors.com/ratingsdirect 59

916400 | 300003452

__MACOSX/._S&P Financial Insitution Rating Criteria.pdf