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What's Next For Resolution Counterparty Ratings?

RCR Liabilities May Be Protected From Default In A Bank Resolution

RCRs are relevant to only a minority of banks globally

They reflect our opinion of the relative default risk of a bank's certain senior liabilities (RCR liabilities) that may be protected from default should the bank be subject to a bail-in resolution. As a result, RCRs only apply in the following circumstances:

  • The bank operates in a jurisdiction where we assess the resolution framework to be effective; and
  • We assess that, if the bank became nonviable, it would likely be subject to a bail-in resolution process that would support the full and timely payment of RCR liabilities.

Furthermore, we would not position an RCR above a bank's ICR unless we believe that the bank has a meaningful layer of senior unsecured liabilities that would help to absorb losses in resolution, and could therefore protect its RCR liabilities from default.

Chart 1 illustrates how RCRs fit into our bank criteria framework.

Chart 1

image
RCRs are relevant only where resolution is our base-case response to bank failure

Even if we regard a resolution framework as potentially effective, we typically don't assign RCRs for banks where external government support is included in the ICR (except where we include additional short-term support). This is because the ICR describes a base case of government support, not resolution, as the most likely response to that institution's potential failure. While that government support might prevent banks from failing, it would not necessarily give preference to some types of senior liabilities over other senior liabilities.

This scenario currently applies in two jurisdictions: Canada and Hong Kong. In both cases, we regard the resolution framework as able to deliver a credible response to the failure of one or more systemically important banks, while at the same time the government retains legal and policy flexibility to bail out senior creditors.

Similarly, in Europe, we regard some banks as government-related entities (GREs). If our base case is that an institution would receive pre-emptive support from the public authorities, then we would not assign an RCR.

Exemption from bail-in does not mean exemption from default

The scope of the liabilities that an RCR covers varies between jurisdictions, but in Europe at least includes insured deposits and secured senior claims, such as repurchase agreements and collateralized derivatives. The very existence of deposit insurance highlights policymakers' extreme reluctance to impose losses on small depositors. Even without insurance, the preferred nature of these claims might lead to small or negligible losses for the claimants, even if the stricken bank were put through a standard corporate liquidation.

However, our RCRs reflect our opinion about an entity's creditworthiness in reference to full and timely payment of RCR liabilities. Under a modified liquidation, there could be a delay in repayment of some preferred claims. We see a bail-in resolution process as a critical feature that would likely avoid such delays.

RCRs Relate Only To Liabilities Exempt From Bail-In

We maintain a narrow classification of RCR liabilities, limited to liabilities that are explicitly specified in law as being excluded from bail-in.   We assign RCRs to banks in a number of countries across the EU, Switzerland, the U.K., and the U.S., and differences in bail-in legislation across the major jurisdictions mean that the universe of RCR liabilities differs markedly between them. As a result, we have published jurisdictional assessments for each country where we assign RCRs to financial institutions (see the "RCR jurisdictional assessments" section below).

The jurisdictional assessments examine the creditor hierarchy in each jurisdiction and explain the specific liabilities covered by RCRs. While national creditor hierarchies differ for senior unsecured creditors (see chart 2), the bank recovery and resolution directive's (BRRD's) implementation across the EU and U.K. creates uniformity in the types of liabilities exempt from bail-in, and therefore in the types of liabilities we regard as RCR liabilities.

For Switzerland, RCR liabilities include:

  • Insured deposits;
  • Secured liabilities;
  • Segregated client assets; and
  • Eligible liabilities (employee salaries and social plan liabilities up to certain limits, pension schemes, family-related support obligations, minor age claims, public pension, and social security liabilities).

By contrast, in the U.S., we do not believe the bail-in resolution framework allows for a clear differentiation in the default likelihood of different types of senior liabilities at any given legal entity. That is why, for U.S. banking groups, we do not classify any liabilities as RCR liabilities. It is also why RCRs that are assigned to rated bank-operating companies are no higher than the ICRs on those companies.

Chart 2

image

We're Unlikely To Expand The Scope Of RCR Liabilities

In Europe, many types of senior unsecured liabilities are legally bail-inable. This includes liabilities such as uninsured retail and small-to-midsize enterprise (SME) deposits, corporate deposits, and uncollateralized derivatives. We recognize that such liabilities are unlikely to be bailed-in unless losses are extremely high--indeed, their bail-in may be inconsistent with a successful resolution because of financial stability concerns. That said, for such liabilities:

  • There is no legal exclusion from bail-in;
  • There is a lack of explicit regulatory statements to indicate a policy for their exclusion; and
  • There is no track record to indicate that they have been specifically excluded from bail-in in the past.

Moreover, depending on the creditor hierarchy in the specific jurisdiction, excluding certain liabilities of this type from a bail-in may give rise to legal challenges under the "no creditor worse off" principle.

For all of these reasons, we classify as RCR liabilities only liabilities that are explicitly identified, by legislation or by regulators, as being excluded from bail-in. A change in our assessment is unlikely; it would require us to have much greater comfort around how and why resolution authorities would strive to protect these liabilities. That said, our RCRs are subject to ongoing surveillance, and if our understanding changes over time--for example, if regulators explicitly indicate that certain liabilities not already specified in legislation as being bail-in exempt will not be bailed in--we would consider the implications for the RCR.

RCRs Are Typically Positioned Above The ICR

RCRs indicate whether we expect the default risk of RCR liabilities to be either equal to or lower than the default risk of the institution's senior unsecured debt (the default risk of the latter being reflected in the ICR). Specifically, our RCRs are typically positioned at a rating level that is:

  • At the same level as the ICR where the ICR is 'AA-' or higher;
  • No more than one notch above the ICR, where the ICR ranges from 'BBB-' to 'A+'; or
  • No more than two notches above the ICR, where the ICR ranges from 'B-' to 'BB+'.

The constraints set out in the first two scenarios above reflect uncertainty about how resolution may be handled in an extreme or severe stress scenario for issuers that are currently far from potential distress.

Chart 3 provides an illustrative rating hierarchy of a hypothetical European bank that is eligible for an RCR.

Chart 3

image

We Have Assigned RCRs To More Than 250 Entities Worldwide

To date, we have assigned RCRs to 267 entities, including 30 branches, across 77 banking groups in 26 countries (see Appendix).

RCRs are limited to those banking groups we consider to be systemic, operating in jurisdictions with effective resolution regimes and no government-support uplift in the ICR. Currently, this means systemic banking entities in the U.S. and in Europe. This is because we believe these groups would likely be subject to a bail-in-led resolution, which keeps the bank running. We make the judgment based primarily on public statements from resolution authorities about which banks would likely be subject to a bail-in process should they fail. Alternatively, we would aim to consider other indicators, for example banks' regulatory requirements of subordinated bail-in buffers, to understand the authorities' assessment of the systemic importance and likely resolution strategy of a banking group.

RCRs are assigned primarily to bank-licensed operating entities

We expect that the resolution plans for many banks would ensure that many of their operating subsidiaries avoid default. This is because of the systemically relevant functions some operating entities provide, as well as their interconnectedness with the parent bank, and the importance of shoring up investor confidence during a resolution action.

The operating entities to which we assign RCRs are predominately those with a banking license, because it is banks that carry the bulk of RCR liabilities on their balance sheet. Similarly, though less often, we assign RCRs to a banking group's securities firm subsidiaries.

However, we have not assigned RCRs to entities that are unlikely to hold a material amount of RCR liabilities; that is, those liabilities that are explicitly excluded from a bail-in. Examples include financing vehicles that issue only senior unsecured or subordinated debt, leasing, and service companies. The financial liabilities of these entities tend to be dominated by trade or intercompany payables, rather than RCR liabilities such as insured deposits or short-term liabilities to banks and designated settlement systems.

Because we only assign RCRs to a banking group's operating entities, not to nonoperating holding companies (NOHCs), the likely form of a bail-in resolution is not a key factor in setting the RCR. The resolution may be a European-style "open bank" resolution, which keeps the operating bank running through the write-down of equity and the write-down or conversion of (non-RCR) liabilities; or a U.S.-style resolution, in which the NOHC acts as a source of strength for the operating subsidiaries, meaning that NOHC liabilities would have to be depleted before turning to operating company creditors.

RCR assignment is nuanced for overseas subsidiaries of systemic banking groups

For internationally active banking groups, our ICRs recognize that many of their overseas subsidiaries could benefit (for example, through recapitalization) from a resolution action in their parent. However, we assign RCRs to overseas subsidiaries only when we assess the local resolution framework as effective. This is because, in resolution, the subsidiary will be subject to the insolvency law applicable to its jurisdiction; in other words, the law of the host jurisdiction is king. That is why we have not assigned RCRs to Australian, Brazilian, or Japanese subsidiaries of EU banking groups, for example.

We also follow this host-centric logic in the U.S. Therefore, while the RCR on a European parent bank would normally be above its ICR, we position the RCR on its U.S. subsidiaries in line with the ICR, as we do for local U.S. banks.

By contrast, we do not provide uplift to RCRs for U.S. subsidiaries operating in foreign jurisdictions--even those in which RCR uplift could be considered for local entities--because, a priori, it is unclear to us whether a host regulator would explicitly exclude (or provide protection to) the liabilities of a U.S. subsidiary from being bailed in. We believe this will likely depend on how the host regulator views the systemic risk of bailing in these liabilities and the impact on retail customers of the subsidiary. Most of the foreign subsidiaries of U.S. global systemically important banks (GSIBs) tend to focus on capital markets activities with little retail activity and are often small in size, relative to local entities. Given the uncertainty, we opt not to provide RCR uplift for these subsidiaries.

Unlike subsidiaries, overseas branches are an extension of the legal entity to which they belong, and so we assign RCRs to branches, regardless of their location, based on the RCR of the branch's parent entity. That is why, for example, the appendix shows an RCR rating for the Cayman Islands branch of Credit Suisse AG.

Some RCRs exceed the sovereign rating

For certain banks in Italy and Spain, we have assigned RCRs that exceed the foreign currency (FC) long-term sovereign rating, because we think it unlikely that a hypothetical sovereign default would immediately trigger a default on those banks' RCR liabilities. This contrasts with our decision to constrain these banks' ICRs at the level of the sovereign FC rating (with the exceptions of UniCredit SpA; BNP Paribas' core Italian subsidiary, Banca Nazionale del Lavoro SpA; and Credit Suisse's core Spanish subsidiary, Credit Suisse Securities Sociedad de Valores S.A.). The differentiation reflects the extra resilience we see for RCR liabilities under our sovereign default stress test, once we assume the bail-in not only of nonpreferred debt and other hybrids (that is, those liabilities that are contractually or structurally subordinated to ICR-level senior unsecured liabilities), but also some ICR-level liabilities.

Our assessment is qualitative as well as quantitative. The quantitative aspects (such asset haircuts and deposit outflow assumptions) are substantially prescribed in our rating above the sovereign methodology. Qualitative aspects include our view of the likely manner of regulatory intervention and the extent of possible forbearance. It is a combination of both aspects that underpins our decision to constrain the RCRs on banks such as OTP Bank PLC in Hungary and Bank Polska Kasa Opieki S.A. (Pekao) in Poland at the sovereign FC level. Even though their systemic importance would likely merit an open bank bail-in resolution, the banks' limited historical use of capital instruments and other term debt means that, in our view, the resolution authority would need to rely heavily on a bail-in of other senior liabilities, notably corporate and other uninsured deposits, to recapitalize them. While these liabilities comprise a substantial portion of the banks' balance sheets, we are cautious about the extent to which these deposits would be withdrawn in a sovereign stress situation, and also about the financial stability and systemic risks that could result from bailing in these liabilities. In other words, the bail-in of these liabilities could well jeopardize the goal of stabilizing a country's banking system following a sovereign stress or default.

We have assigned a small number of issue-level RCRs

In addition to the 267 issuer-level RCRs listed in the Appendix, we have also assigned issue-level RCRs on specific collateralized liabilities that would be excluded from bail-in by the relevant resolution authority. These issue-level RCRs relate to secured notes issued by five entities, namely Barclays Bank PLC; BNP Paribas Issuance B.V.; MB Funding Lux S.A.; NatWest Markets Plc; and SG Issuer S.A.

RCRs are an input to our ratings on structured finance and covered bond transactions

Our RCRs reflect our opinion about a bank's creditworthiness in reference to the timely fulfilment of the terms of RCR liabilities--that is, liabilities that are exempt from bail-in. That is why, where a bank's covered bonds are exempt from bail-in (as is the case in Europe--see chart 2) and we have assigned an RCR to that bank, our ratings on those covered bonds cannot be lower than the bank's RCR (see Covered Bonds Criteria, published Dec. 9, 2014).

RCRs are also an input in our counterparty risk framework for structured finance and covered bond transactions (see Counterparty Risk Framework: Methodology And Assumptions, published March 8, 2019). In essence, RCRs can be used as the applicable counterparty rating for an obligation if that obligation is an RCR liability.

We May Assign RCRs To More Banks And Eventually, To More Jurisdictions

Clarity on European bank resolution plans will be important

In the U.S., the choice of resolution strategy for regulated banks is binary: Title I, meaning modified liquidation, applies for the majority, while Title II, meaning orderly liquidation, is an option for the eight U.S. GSIBs. And indeed, this is our base case for these hugely systemic institutions. In Europe, there is a middle road--well, many potential middle roads--for banks that are too large to liquidate without any risk to financial stability, yet too small to justify full "open bank" resolution.

These middle-way resolution strategies are typically facilitated through use of the bail-in tool, but would involve other resolution powers such as a sale of assets or of an entire business, a bridge bank, or temporary public ownership. Examples of resolution authorities that envisage a form of middle-way resolution for some of their banking groups include those in Spain and the U.K.

To assign RCRs to banks in such groups, we need to see a high probability that the strategy would avoid the default of any RCR liabilities. To guide this decision, we explore the resolution authority's underlying objectives and whether the operation of the resulting resolution plans would very likely ensure full and timely payment on all RCR–level liabilities. This includes exploring the extent of the recapitalization implied by the banks' loss-absorbing capacity requirements (that is, minimum requirement for own funds and eligible liabilities [MREL] in the EU). Since resolution plans are decided by national competent authorities and they are specific to each bank, we expect our RCR decisions to be on a jurisdiction by jurisdiction, or even bank-by-bank, basis.

We don't envisage assigning RCRs to smaller, less systemic banks that we expect to be subject to modified liquidation if they fail, because liquidation might lead to failure to pay on a timely basis--that is, default--even if these high-ranking RCR liabilities could ultimately see full recovery in liquidation.

Separately, we recently assigned RCRs to five midsize banks in Finland and Sweden (Aktia Bank, Central Bank of Savings Banks Finland, Landshypotek Bank AB, SBAB Bank AB, and Sparbanken Skane) that we expect would be subject to a well-defined resolution strategy which has, in our view, a high likelihood of ensuring full and timely payment on RCR liabilities. Although authorities have not explicitly stated a preferred resolution strategy for these banks, we expect that it involves a bail-in-led resolution, as for their larger peers. This assessment is supported by the fact that these banks are meaningful players in their banking sector, are subject to sizable MREL requirements, and in addition, in Sweden, the recapitalization amount must be met only with subordinated debt instruments.

Further jurisdictions may develop effective resolution frameworks

Policymakers outside Europe, the U.S., Canada, and Hong Kong, are gradually updating intervention powers to better deal with failing banks. However, the majority remain highly cautious about signalling a weakening in their willingness to support systemic banks, certainly until a fully credible, proven alternative exists.

Nevertheless, in time, we could see effective resolution frameworks created that would move our base case from bail-out, or simply no support, to bail-in-led resolution. If so, we would perform jurisdiction assessments to ascertain whether some senior creditors could benefit from additional protection in a resolution scenario.

Appendix

Entities With Resolution Counterparty Ratings
By country of incorporation of ultimate parent
Rated entity or branch Country of incorporation* ICR RCR
--Austria--
Erste Group:
- Ceská Sporitelna, a. s. Czech Republic A A+

- Erste Group Bank AG

Austria A A+

Oberbank AG

Austria A A+
--Belgium--

Argenta Spaarbank N.V.

Belgium A- A

Belfius Bank S.A.

Belgium A- A
KBC:
- Ceskoslovenska Obchodni Banka A.S. Czech Republic A+ AA-
- KBC Bank Ireland PLC Ireland BBB BBB+

- KBC Bank N.V.

Belgium A+ AA-
--Cyprus--

Bank of Cyprus Public Co. Ltd.

Cyprus B+ BB
--Denmark--

Danske Bank A/S

Denmark A A+

DLR Kredit A/S

Denmark A- A
Jyske:

- Jyske Bank A/S

Denmark A A+
- Jyske Realkredit A/S Denmark A A+
Nykredit:

- Nykredit Bank A/S

Denmark A+ AA-
- Nykredit Realkredit A/S Denmark A+ AA-
--Finland--

Aktia Bank PLC

Finland A- A

Central Bank of Savings Banks Finland PLC

Finland A- A
Nordea Bank Abp Finland AA- AA-

OP Corporate Bank PLC

Finland AA- AA-
--France--
BPCE:

- BPCE S.A.

France A+ AA-
- BRED Banque Populaire S.A. France A+ AA-
- Crédit Foncier de France France A A+

- Natixis S.A.

France A+ AA-
- Natixis, New York Branch* France* A+ AA-
BNP Paribas:
- Banca Nazionale del Lavoro SpA Italy BBB+ A-
- Bank of the West U.S. A A
- BGL BNP Paribas S.A. Luxembourg A+ AA-
- BNP Paribas Fortis S.A. Belgium A+ AA-
- BNP Paribas Issuance B.V. Netherlands A+ AA-
- BNP Paribas New York Branch* France* A+ AA-
- BNP Paribas Personal Finance S.A. France A+ AA-

- BNP Paribas S.A.

France A+ AA-
- BNP Paribas S.A. (U.K. branch)* France* A+ AA-
- BNP Paribas Securities Corp. France A+ A+
- BNP Paribas Securities Services S.C.A. France A+ AA-
- BNPP Fortis (U.S. branch)* France* A+ AA-
- BNPP SA (Ireland branch)* France* A+ AA-
- BNPP SA (Italy branch)* France* A+ A+
- BNPP Securities Services (Germany branch)* France* A+ AA-
- BNPP Securities Services (Luxembourg branch)* France* A+ AA-
- BNPP Securities Services (Milan branch)* France* A+ A+
- BNPP Securities Services (Spain branch)* France* A+ AA-
- BNPP Securities Services (UK branch)* France* A+ AA-
Credit Agricole:
- CACEIS France A+ AA-
- Caisse régionale de Crédit Agricole Alsace Vosges, société coopérative France A+ AA-
- Caisse régionale de Crédit Agricole Centre-est France A+ AA-
- Caisse Régionale de Crédit Agricole du Morbihan France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel Alpes Provence Société coopérative France A+ AA-
- Caisse régionale de Crédit Agricole Mutuel Atlantique Vendée France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel Brie Picardie Société coopérative France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel Centre Loire France A+ AA-
- Caisse Regionale de Credit Agricole Mutuel Charente-Maritime Deux-Sevres Société coopérative France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel d'Aquitaine France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel de Centre France France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel de Champagne-Bourgogne, société coopérative France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel de Charente-Périgord, société coopérative France A+ AA-
- Caisse Regionale de Credit Agricole Mutuel de Franche-Comte France A+ AA-
- Caisse régionale de Crédit Agricole Mutuel de Guadeloupe Société coopérative France A+ AA-
- Caisse régionale de Crédit Agricole Mutuel de la Martinique et de la Guyane France A+ AA-
- Caisse Regionale de Credit Agricole Mutuel de la Reunion France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel de La Touraine et du Poitou Société Coopérative France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel de l'Anjou et du Maine, société cooperative France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel de Lorraine France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel de Normandie France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel de Normandie-Seine Société coopérative France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel de Paris et d'Ile-de-France France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel des Côtes d'Armor France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel des Savoie, société cooperative France A+ AA-
- Caisse régionale de Crédit Agricole Mutuel d'Ille-et-Vilaine Société coopérative France A+ AA-
- Caisse Regionale de Credit Agricole Mutuel du Centre Ouest France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel du Finistère France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel du Languedoc Société coopérative France A+ AA-
- Caisse Regionale de Credit Agricole Mutuel du Nord Est France A+ AA-
- Caisse régionale de Crédit Agricole Mutuel Loire Haute-Loire - Société coopérative France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel Nord de France Société coopérative France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel Nord Midi-Pyrénées. Société coopérative France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel Provence Côte d'Azur Société coopérative France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel Pyrénées Gascogne France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel Sud Méditerranée, Société cooperative France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel Sud Rhône Alpes France A+ AA-
- Caisse Regionale de Credit Agricole Mutuel Toulouse 31 France A+ AA-
- Caisse Régionale de Crédit Agricole Mutuel Val de France France A+ AA-
- Crédit Agricole Consumer Finance S.A. France A+ AA-
- Crédit Agricole Corporate and Investment Bank S.A. France A+ AA-
- Credit Agricole Corporate And Investment Bank, New York Branch* France* A+ AA-

- Credit Agricole S.A.

France A+ AA-

- Crédit Lyonnais S.A.

France A+ AA-
Credit Mutuel:
- Banque Fédérative du Crédit Mutuel Société anonyme France A A+

- Caisse Centrale du Credit Mutuel S.A.

France A A+
- Caisse Fédérale du Crédit Mutuel Antilles Guyane SC France A A+
- Caisse Fédérale du Crédit Mutuel de Maine-Anjou et Basse-Normandie France A A+
- Caisse Fédérale du Crédit Mutuel Nord Europe France A A+
- Caisse Fédérale du Crédit Mutuel Océan France A A+
- Crédit Industriel et Commercial France A A+
Societe Generale:
- Crédit du Nord Société Anonyme France A A+
- Franfinance SA France A A+
- Komercni Banka A.S. Czech Republic A A+
- SG Americas Securities, LLC U.S. A A
- Societe Generale Bank & Trust S.A. Luxembourg A A+

- Société Générale Société anonyme

France A A+
- Societe Generale, New York Branch* France* A A+
--Germany--
Commerzbank:

- Commerzbank AG

Germany A- A

- mBank S.A.

Poland BBB BBB+
Deutsche Bank:
- Deutsche Bank (Cayman) Limited* Germany* BBB+ A-
- Deutsche Bank AG (Madrid Branch)* Germany* BBB+ A-
- Deutsche Bank AG, Canada Branch* Germany* BBB+ A-
- Deutsche Bank AG, London Branch* Germany* BBB+ A-
- Deutsche Bank AG, Milan* Germany* BBB+ A-

- Deutsche Bank Aktiengesellschaft

Germany BBB+ A-
- Deutsche Bank Luxembourg S.A. Luxembourg BBB+ A-
- Deutsche Bank National Trust Company (California) U.S. BBB+ BBB+
- Deutsche Bank Trust Company Americas U.S. BBB+ BBB+
- Deutsche Bank Trust Company Delaware U.S. BBB+ BBB+

Deutsche Pfandbriefbank AG

Germany A- A

Hamburg Commercial Bank AG

Germany BBB BBB+
--Greece--

Alpha Bank A.E.

Greece B B

Eurobank Ergasias S.A

Greece B B

National Bank of Greece S.A.

Greece B B

Piraeus Bank S.A.

Greece B- B-
--Hungary--
OTP:

- OTP Bank PLC

Hungary BBB BBB

- OTP Mortgage Bank

Hungary BBB BBB
--Ireland--
AIB Group PLC:

- AIB Group (U.K.) PLC

U.K. BBB BBB+
- Allied Irish Banks PLC Ireland BBB+ A-

Bank of Ireland

Ireland A- A

Permanent TSB PLC

Ireland BBB- BBB
--Italy--
Intesa:
- Banca IMI S.p.A. Italy BBB BBB+
- Fideuram - Intesa Sanpaolo Private Banking S.p.A. Italy BBB BBB+

- Intesa Sanpaolo S.p.A.

Italy BBB BBB+
Mediobanca:
- MB Funding Lux S.A. Luxembourg BBB BBB+

- Mediobanca Banca di Credito Finanziario S.p.A.

Italy BBB BBB+
Unicredit:
- UniCredit Bank AG Germany BBB+ A-
- UniCredit Bank Austria AG Austria BBB+ A-

- UniCredit Banca SpA

Italy BBB BBB+
- Zagrebacka banka d.d. Croatia BBB- BBB-

Unione di Banche Italiane S.p.A.

Italy BBB- BBB
--Liechtenstein--

LGT Bank AG

Liechtenstein A+ AA-

VP Bank AG

Liechtenstein A A+
--Luxembourg--

Banque Internationale à Luxembourg S.A.

Luxembourg A- A
--Malta--

Bank of Valletta PLC

Malta BBB- BBB
--The Netherlands--

ABN AMRO Bank N.V.

Netherlands A A+

de Volksbank N.V.

Netherlands A- A
ING:

- ING Bank N.V.

Netherlands A+ AA-
- ING Bank N.V. (Dublin Branch)* Netherlands* A+ AA-
- ING Belgium SA/NV Belgium A+ AA-
- ING Financial Markets LLC Netherlands A+ A+

NIBC Bank N.V.

Netherlands BBB+ A-
Rabobank:

- Cooperatieve Rabobank U.A.

Netherlands A+ AA-
- Cooperatieve Rabobank U.A., London* Netherlands* A+ AA-
- Cooperatieve Rabobank U.A., New York Branch* Netherlands* A+ AA-
- Rabohypotheekbank N.V. Netherlands A+ AA-
--Norway--

DNB Bank ASA

Norway AA- AA-
--Poland--

Bank Polska Kasa Opieki S.A.

Poland BBB+ A-
--Portugal--

Banco BPI S.A.

Portugal BBB BBB

Banco Comercial Portugues S.A.

Portugal BB BBB-
--Slovenia--

Nova Ljubljanska Banka d.d.

Slovenia BBB- BBB
--Spain--

Banco Bilbao Vizcaya Argentaria, S.A.

Spain A- A

Banco de Sabadell S.A.

Spain BBB BBB+

Bankia S.A.

Spain BBB BBB+

CaixaBank S.A.

Spain BBB+ A-
Santander:
- Banco Santander Totta, S.A. Portugal BBB BBB

- Banco Santander S.A.

Spain A A+
- Santander Consumer Bank AG Germany A- A
- Santander Consumer Finance, S.A. Spain A- A
- Santander U.K. PLC U.K. A A+
--Sweden--
Handelsbanken:
- Handelsbanken PLC U.K. AA- AA-
- Stadshypotek AB (publ) Sweden AA- AA-

- Svenska Handelsbanken AB (publ)

Sweden AA- AA-

Landshypotek Bank AB (publ)

Sweden A A+

SBAB Bank AB (publ)

Sweden A A+
Skandinaviska Enskilda Banken AB (publ.) Sweden A+ AA-

Sparbanken Skane AB (publ)

Sweden A A+
Swedbank:

- Swedbank AB (publ)

Sweden AA- AA-
- Swedbank Hypotek AB (publ) Sweden AA- AA-
--Switzerland--

Credit Suisse:

- Credit Suisse (Deutschland) Aktiengesellschaft Germany A+ AA-

- Credit Suisse (Schweiz) AG

Switzerland A+ AA-

- Credit Suisse AG

Switzerland A+ AA-
- Credit Suisse AG, Cayman Island Branch* Switzerland* A+ AA-
- Credit Suisse AG, New York Branch* Switzerland* A+ AA-
- Credit Suisse International U.K. A+ AA-
- Credit Suisse Securities (Europe) Limited U.K. A+ AA-
- Credit Suisse Securities (USA) LLC U.S. A+ A+
- Credit Suisse Securities Sociedad De Valores SA Spain A+ AA-

UBS:

- UBS AG

Switzerland A+ AA-
- UBS AG, Jersey* Switzerland* A+ AA-
- UBS AG, London Branch* Switzerland* A+ AA-
- UBS AG, New York Branch* Switzerland* A+ AA-
- UBS Bank USA U.S. A+ A+
- UBS Europe SE Germany A+ AA-
- UBS Securities LLC U.S. A+ A+

- UBS Switzerland AG

Switzerland A+ AA-
--U.K.--

Barclays:

- Barclays Bank Ireland PLC Ireland A A+
- Barclays Bank Ireland PLC (Milan Branch)* Ireland* A A+
- Barclays Bank Ireland PLC, Sucursal en Espana (Madrid Branch)* Ireland* A A+

- Barclays Bank PLC

U.K. A A+
- Barclays Bank UK PLC U.K. A A+
- Barclays Capital Inc. U.S. A A
- Barclays Capital Luxembourg S.À R.L. Luxembourg A A+
- Barclays Capital Trading Luxembourg S.À.R.L. Luxembourg A A+

Clydesdale Bank PLC

U.K. BBB+ A-

HSBC Holdings PLC:

- HSBC Bank PLC

U.K. AA- AA-
- HSBC Bank USA, National Association U.S. AA- AA-
- HSBC France France AA- AA-
- HSBC Securities (USA) Inc. U.S. AA- AA-
- HSBC UK Bank PLC U.K. AA- AA-

Lloyds Banking Group PLC:

- Lloyds Bank Corporate Markets PLC U.K. A A+

- Lloyds Bank PLC

U.K. A+ AA-

Nationwide Building Society

U.K. A A+

RBS:

- Bank of Scotland PLC

U.K. A+ AA-

- National Westminster Bank Plc

U.K. A A+
- NatWest Markets N.V. Netherlands A- A
- NatWest Markets Plc U.K. A- A
- NatWest Markets Securities Inc. U.S. A- A-
- The Royal Bank of Scotland plc U.K. A A+
- Ulster Bank Ireland DAC Ireland A- A
- Ulster Bank Limited U.K. A A+

Standard Chartered:

- Standard Chartered Bank

U.K. A A+
- Standard Chartered Bank AG Germany A A+
--U.S.--

Bank of America Corp.:

- Bank of America California, National Association U.S. A+ A+
- Bank of America Merrill Lynch International DAC Ireland A+ A+

- Bank of America, National Association

U.S. A+ A+
- BofA Securities Europe SA France A+ A+
- BofA Securities, Inc. U.S. A+ A+
- Merrill Lynch International U.K. A+ A+
- Merrill Lynch, Pierce, Fenner & Smith Incorporated U.S. A+ A+

Bank of New York Mellon Corp.:

- Bank Of New York Mellon S.A./N.V. (Italian Branch)* Belgium* A+ A+
- Bank Of New York Mellon Sa/Nv (Luxembourg Branch)* Belgium* AA- AA-
- BNY Mellon Trust Of Delaware U.S. AA- AA-
- BNY Mellon, National Association U.S. AA- AA-
- Pershing LLC U.S. A+ A+

- The Bank of New York Mellon

U.S. AA- AA-
- The Bank of New York Mellon (International) Limited U.K. AA- AA-
- The Bank of New York Mellon SA/NV Belgium AA- AA-
- The Bank of New York Mellon Trust Company, N.A. U.S. AA- AA-

Citigroup Inc.:

- Citibank Europe PLC Ireland A+ A+

- Citibank, N.A.

U.S. A+ A+
- Citigroup Global Markets Europe AG Germany A+ A+
- Citigroup Global Markets Funding Luxembourg S.C.A. Luxembourg A+ A+
- Citigroup Global Markets Inc. U.S. A+ A+
- Citigroup Global Markets Limited U.K. A+ A+
Goldman Sachs:
- Goldman Sachs & Co. LLC U.S. A+ A+
- Goldman Sachs Bank Europe SE Germany A+ A+
- Goldman Sachs Bank USA U.S. A+ A+
- Goldman Sachs International U.K. A+ A+
- Goldman Sachs International Bank U.K. A+ A+
- Goldman Sachs Paris Inc. et Cie France A A

JPMorgan Chase & Co.:

- Chase Bank USA, N.A. U.S. A+ A+
- J.P. Morgan AG Germany A+ A+
- J.P. Morgan Bank Luxembourg S.A. Luxembourg A+ A+
- J.P. Morgan Securities LLC U.S. A+ A+
- J.P. Morgan Securities plc U.K. A+ A+

- JPMorgan Chase Bank, National Association

U.S. A+ A+

Morgan Stanley:

- Morgan Stanley & Co. International plc U.K. A+ A+

- Morgan Stanley & Co. LLC

U.S. A+ A+
- Morgan Stanley Bank Aktiengesellschaft Germany A+ A+
- Morgan Stanley Bank International Limited U.S. A+ A+
- Morgan Stanley Bank, N.A. U.S. A+ A+
- Morgan Stanley Capital Group Inc. U.S. A+ A+
- Morgan Stanley Capital Services LLC U.S. A+ A+
- Morgan Stanley Europe SE Germany A+ A+
- Morgan Stanley Private Bank, National Association U.S. A+ A+

State Street Corp.:

- State Street Bank and Trust Company (Boston, MA)

U.S. AA- AA-
- State Street Bank International GmbH Germany AA- AA-

Wells Fargo:

- Wells Fargo Bank International Unlimited Company Ireland A+ A+
- Wells Fargo Bank South Central, National Association U.S. A+ A+

- Wells Fargo Bank, National Association

U.S. A+ A+
- Wells Fargo Securities International Limited Ireland A+ A+
- Wells Fargo Securities, LLC U.S. A+ A+
Note: Ratings as of Feb. 28, 2020. *Branch entity, country of incorporation is that of the branch's parent. ICR--Issuer credit rating. RCR--Resolution counterparty rating. Source: S&P Global Ratings.

Related Criteria

Related Research

RCR Jurisdictional Assessments

This report does not constitute a rating action.

Primary Credit Analysts:Osman Sattar, FCA, London + 44 20 7176 7198;
osman.sattar@spglobal.com
Giles Edwards, London (44) 20-7176-7014;
giles.edwards@spglobal.com
Secondary Contacts:Bernd Ackermann, Frankfurt (49) 69-33-999-153;
bernd.ackermann@spglobal.com
Brendan Browne, CFA, New York (1) 212-438-7399;
brendan.browne@spglobal.com

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