April 5, 2011 Various Rating Actions Taken On Irish Banks Following Financial Measures Programme And Bank Restructuring Plan Primary Credit Analyst: Nigel Greenwood, London (44) 20-7176-7211; [email protected] Secondary Contacts: Giles Edwards, London (44) 20-7176-7014; [email protected] Sean Cotten, Stockholm (46) 8-440-5928; [email protected] OVERVIEW • On March 31, 2011, the Central Bank of Ireland presented the results of its Financial Measures Programme in conjunction with the Irish government's announcement of a two-pillar approach to the rebuilding of the Irish banking sector. • On April 1, 2011, we lowered our long-term ratings on the Republic of Ireland to 'BBB+' from 'A-'. We also removed the ratings from CreditWatch negative. The outlook on Ireland is stable. • Despite the planned capital injections and the announcement of their roles as the key pillars in the Irish bank restructuring plan, the ratings on Allied Irish Banks PLC (AIB) and Bank of Ireland (BOI) remain on CreditWatch with negative implications. • The planned disposal of the life operations of Irish Life & Permanent PLC (IL&P) has led to a one-notch downgrade to reflect the fact that we no longer factor support from the life operations into our rating opinion of IL&P's banking operations. • The ratings on AIB, BOI, and IL&P remain on CreditWatch while we consider the stand-alone credit profile (SACP) and notches of extraordinary government support in light of the Financial Measures Programme. • We are also lowering the ratings on Anglo Irish Bank Corp. Ltd. (Anglo) by one notch, reflecting our view that its importance to the Irish government has reduced. The outlook on Anglo is negative. • The weakened creditworthiness we see in the Irish sovereign has also led to a review of the ratings on the foreign-owned, domestically active www.standardandpoors.com/ratingsdirect 1 859021 | 300001899 Various Rating Actions Taken On Irish Banks Following Financial Measures Programme And Bank Restructuring Plan banks. • We are lowering the ratings on Barclays Bank Ireland PLC (BBI) and Ulster Bank Ireland Ltd. (UBIL), and its U.K. parent Ulster Bank Ltd. (UBL), by one notch. The outlook on BBI is stable, mirroring that of the Irish sovereign. • The ratings on AIB, BOI, IL&P, UBIL and UBL, and KBC Bank Ireland (KBCI) remain on CreditWatch with negative implications, indicating the potential for further rating actions as we consider their SACPs in light of the significant restructuring that lies ahead for the Irish banking system. LONDON (Standard & Poor's) April 5, 2011--Standard & Poor's Ratings Services said today that it took various rating actions on the four domestically owned Irish banks and three foreign-owned banks operating in Ireland which it rates. This follows our review of the results of the Irish government's Financial Measures Programme ("the Programme"), comprising a Prudential Capital Assessment (PCAR) and a Prudential Liquidity Assessment (PLAR), as well as the announced restructuring of the Irish banking sector and our revised ratings on the Republic of Ireland (BBB+/Stable/A-2). The rating actions on the four domestically owned Irish banks and three foreign-owned banks are as follows: • The 'BB/B' counterparty credit ratings on Allied Irish Banks PLC (AIB) remain on CreditWatch with negative implications, as do the 'BB-/B' ratings on AIB's wholly owned U.K. subsidiary, AIB Group (UK) PLC (AIB UK). We continue to factor a two-notch uplift for Irish government support into the counterparty credit ratings on AIB above its 'b+' SACP. • The 'BB+/B' ratings of Bank of Ireland (BOI) remain on CreditWatch with negative implications. We continue to factor a two-notch uplift for Irish government support into the counterparty credit ratings on BOI above its 'bb-' SACP. • As a result of the planned restructuring of Irish Life & Permanent PLC (IL&P), which will lead to the disposal of its life operations, we have lowered the ratings to 'BB+/B' from 'BBB-/A-3'. This reflects our view that there will likely be no material support by Irish Life Assurance PLC (ILA; BBB-/Watch Dev/--) of IL&P. The IL&P ratings remain on CreditWatch with negative implications. We continue to factor a two-notch uplift for Irish government support into the counterparty credit ratings on IL&P above its revised 'bb-' SACP. In addition, we have lowered IL&P's lower Tier 2 subordinated debt rating to 'CCC' from 'B' given the government's stated intention to include subordinated debtors in the recapitalization of Irish banks. • We have lowered the long-term counterparty credit rating on Anglo Irish Bank Corp. (Anglo), which we consider a government-related entity (GRE) under our criteria, by one notch to 'CCC+' from 'B-'. This reflects our view of Anglo's reduced importance to the Irish government. We have also removed the ratings from CreditWatch with negative implications. The outlook is negative. • Today's rating actions do not affect the ratings on debt issues of AIB, BOI, IL&P, and Anglo as these issues are guaranteed by the Republic of Ireland. Standard & Poor’s | RatingsDirect on the Global Credit Portal | April 5, 2011 2 859021 | 300001899 Various Rating Actions Taken On Irish Banks Following Financial Measures Programme And Bank Restructuring Plan • We have lowered the counterparty credit ratings on Barclays Bank Ireland PLC (BBI) to 'A-/A-2' from 'A/A-1' to reflect the weakened creditworthiness of the Irish sovereign, and removed the BBI ratings from CreditWatch with negative implications. We have maintained our view of BBI's 'core' status to its parent. The outlook is stable. • We have lowered the long-term ratings on Ulster Bank Ltd. (UBL) and core Irish subsidiary, Ulster Bank Ireland Ltd. (UBIL) to 'BBB+' from 'A-'. As a result of the weakened creditworthiness of the Irish sovereign, group support above UBL and UBIL's 'bb+' SACP is now capped at three notches. The UBL and UBIL ratings remain on CreditWatch with negative implications. • The 'BBB+/A-2' ratings on KBC Bank Ireland PLC (KBCI), which incorporate two notches of group support above KBCI's 'bbb-' SACP, remain on CreditWatch with negative implications. In our opinion, the Programme and bank restructuring announcement represent a credible first step by the Irish government toward the eventual rebuilding of investor confidence in the deeply troubled Irish banking system. Moreover, the level of detail and transparency presented in the Programme appears to us to compare well with that presented by peer European banking systems to date. Nevertheless, we believe that it will likely be many years before the Irish banking system starts to approach the creditworthiness of peer European systems. Our Banking Industry Country Risk Assessment (BICRA) on Ireland remains in Group 6, which is the lowest of any developed country globally, with the exception of Greece, which we lowered to Group 7 on March 31, 2011. The Programme comprises the PCAR and the PLAR and was applied to AIB, BOI, IL&P, and EBS Building Society (not rated). The PCAR takes into account independently estimated loan losses over the three-year period 2011-2013 under base (€20.0 billion) and adverse scenarios (€27.7 billion), estimated from a bottom-up analysis of loan books. In addition, the PCAR takes into account a top-down stress test that models the impact on banks' balance sheets and income statements. Additional capital buffers are applied to take account of lifetime loan losses and other contingencies. The PLAR outlines plans to reduce the banks' loan-to-deposit ratio to 122.5% by end-2013. Under the Programme, banks will segment their businesses into 'core' and 'non-core' portfolios, and all assets will reportedly remain within the existing legal entity. The main aim of the Programme is to deleverage loan portfolios by €72.6 billion by 2013. Deleveraging will give rise to losses on exit which will create a need for further capital. This assumption is included in the PCAR. In total, the gross additional capital requirement for the four banks is €24.0 billion. This amount is intended to enable the banks to remain above a minimum 10.5% core Tier 1 ratio under the base scenario and above 6.0% under the adverse scenario, plus an additional protective buffer. This capital injection, if none is garnered from private sources or other capital actions, would be on top of the €46.3 billion that the government has already injected into these banks (and Anglo and Irish Nationwide Building Society (INBS)). www.standardandpoors.com/ratingsdirect 3 859021 | 300001899 Various Rating Actions Taken On Irish Banks Following Financial Measures Programme And Bank Restructuring Plan The Irish government has determined that AIB and BOI will be the two core pillars of its banking system, together with the remaining foreign-owned banks. Both AIB and BOI will reportedly become significantly more domestically focused with limited nonretail and commercial banking activities. The government will facilitate AIB's take-over of EBS, which was previously being bid for by a U.S. private equity firm and IL&P. We note that the U.K. subsidiaries of both AIB and BOI will remain part of their respective core businesses, albeit that their U.K. business as a whole will be reduced in size and scope. In contrast, IL&P will reportedly be required to sell its life insurance subsidiary, ILA, and we understand that the Irish government does not view IL&P as a pillar of the banking system. Separately, Anglo and INBS (whose deposit books were sold to AIB and IL&P, respectively, in February 2011) will reportedly be merged and wound down over several years. In our view, positive factors for the ratings on the four domestically owned Irish banks and three foreign-owned banks include: • Our opinion that the assumptions underlying the stress testing of capitalization are robust and have contributed to a stable outlook on the Irish sovereign ratings. • The very large planned capital injections, which demonstrate the Irish government's continued support of certain banks and that this support is trending from potential to actual support. • The announced deleveraging and restructuring, which in our view appear to be both practical and plausible measures, given what we view to be the limited palatable options available to the Irish government. • The fact that there is now a plan of action, which we believe reduces uncertainty and allows bank management to plan ahead accordingly. Nevertheless, we believe that significant credit weaknesses and uncertainties remain: • We continue to view Ireland's BICRA as very weak. • Even under the Programme's base scenario, the PCAR starkly highlights the weak asset quality across all the loan portfolios of the Irish banks. The elevated loan losses modeled under the PCAR will negatively impact bank profitability for the next three years at least, in our view. • Furthermore, while the assumptions appear robust, in our opinion this is merely the latest of several capital assessments over the past 12 months and may yet prove to be insufficient if economic circumstances turn out to be more severe than those modeled. • The PLAR allows for a sizable systemwide haircut on asset disposals by 2013. Depending on market conditions, in particular those outside of Ireland, it is possible that this may prove to be too low an assumption, even if we think that these transactions are possible to consummate. • Even if the banks delever as planned, we consider that the banks may remain reliant on Irish central bank funding sources. • We believe that implementation risk could follow the bank restructuring. • The exact future role for the banking operations of IL&P has not been fully clarified, in our opinion. • The two-pillar approach to the system may lead to unintended competition Standard & Poor’s | RatingsDirect on the Global Credit Portal | April 5, 2011 4 859021 | 300001899 Various Rating Actions Taken On Irish Banks Following Financial Measures Programme And Bank Restructuring Plan concerns for the authorities in the medium term, in our view. • Details on the timing of the capital injections and the exact nature of those capital instruments have not yet been announced. We understand, however, that the banks' management must soon submit their capital plans to the regulator. • We also note that no medium-term arrangements for the provision of Irish central bank liquidity facilities have been announced. • Finally, while the political will to impose burden sharing on senior unguaranteed bondholders has reportedly diminished, the sheer scale of the planned changes means, in our view, that this risk has not completely dissipated. CREDITWATCH STATUS We are maintaining the CreditWatch negative on AIB, BOI, and IL&P. The CreditWatch negative indicates our view of the difficulties associated with the ambitious restructuring plan, the need for additional details about the timing and nature of the capital injections, and the impact of the aggressive deleveraging plans on each bank's SACP. We have maintained the CreditWatch on UBL, UBIL, and KBCI because we are of the view that the tougher Irish regulatory requirements and significant changes elsewhere in the Irish banking system may weigh on their SACPs. We expect to resolve the CreditWatch on all five banks within three months. We expect that the counterparty credit ratings may be affirmed or lowered by one or two notches. DOMESTICALLY OWNED BANKS We view the liquidity of AIB, BOI, and IL&P as very weak. Even though in our view the PCAR/PLAR result provides clarity as to how much the Irish central bank believes is the sovereign's maximum contingent liability, we believe the Irish banking system has a long way to go to recover. The Irish government has now reportedly allocated about €19 billion (reportedly a net figure after taking account of burden sharing by subordinated bondholders) of the €35 billion originally earmarked for the banking sector as part of the EU-IMF restructuring agreement. The willingness and ability of Ireland to provide further extraordinary support to its banking system in the future may therefore have been somewhat reduced. Nonetheless, our view of the potential for future extraordinary government support is reflected in a two-notch uplift above the respective SACP on AIB, BOI, and IL&P, which incorporates support received to date or that is pending and clearly identified. These include: • Injections of equity and hybrid capital under previous recapitalization efforts; • National Asset Management Agency (NAMA) tranches already transferred or due to be completed shortly; • Ongoing funding and liquidity support by the ECB and Central Bank of Ireland; and • Capital injections announced on March 31, 2011, because they are quantified and the government is committed (and able) to provide these injections www.standardandpoors.com/ratingsdirect 5 859021 | 300001899 Various Rating Actions Taken On Irish Banks Following Financial Measures Programme And Bank Restructuring Plan Allied Irish Banks PLC We consider AIB to be a highly systemically important institution. This view is further supported by the Irish government's view of AIB as a pillar in the future of Irish banking. The ratings remain on CreditWatch while we consider the SACP and notches of extraordinary government support in light of the PCAR result and deleveraging challenges. Bank of Ireland Along with AIB, BOI is viewed by the Irish government as a pillar in the future of the Irish banking sector and in our view remains a highly systemically important institution. The ratings remain on CreditWatch as we consider the SACP and notches of extraordinary government support in light of the PCAR result and deleveraging challenges. Irish Life & Permanent PLC The rating actions on IL&P reflect our review of its SACP in light of the announcement that its life company will be sold. Unlike the case of AIB and BOI, the government has not explicitly defined IL&P as a key pillar of the Irish banking market. Nevertheless, we still view IL&P to be highly systemically important. We have maintained two notches of extraordinary government support into the ratings on IL&P. We have also lowered the dated subordinated debt ratings on IL&P to 'CCC' because the Irish government has clearly included burden sharing on subordinated debt in its recapitalization plans. Based on the experience that we have observed at Anglo, AIB, and BOI, we see a "clear and present risk" that subordinated bondholders of IL&P are likely to suffer loss. IL&P's ratings remain on CreditWatch negative as we assess the impact of the restructuring, deleveraging, and PCAR results on the future of IL&P's banking entity. Anglo Irish Bank Corp. Ltd. The rating actions on Anglo reflect our opinion that, despite a "strong" link to the government, this GRE is now of "limited importance" in accordance with our GRE criteria and that there is only a "moderate" likelihood of extraordinary support. Accordingly, we have lowered Anglo's counterparty credit rating to 'CCC+', one notch above its 'ccc' SACP. We take the GRE approach for the ratings on Anglo, in contrast to those of the other domestically owned Irish banks for whom we apply our systemic importance criteria. This is because we expect Anglo to be wound down over a period of years and remain in government ownership throughout that period. We have removed Anglo's ratings from CreditWatch and assigned a negative outlook, as the government has stated that there is no immediate need for additional capital for either Anglo or INBS, but that a further assessment will be available in May. FOREIGN-OWNED, DOMESTICALLY ACTIVE BANKS We have also analyzed the implications of the weakened creditworthiness of the Irish sovereign on the three foreign-owned, domestically active Irish banks that we rate: BBI, KBCI, and UBIL. While not supported by the Irish government, we rate these banks higher than their domestically owned peers due to our views on the likelihood of parental support and our view of their Standard & Poor’s | RatingsDirect on the Global Credit Portal | April 5, 2011 6 859021 | 300001899 Various Rating Actions Taken On Irish Banks Following Financial Measures Programme And Bank Restructuring Plan modestly stronger SACPs. In particular, BBI, KBCI, and UBIL have not seen the sort of stress experienced by their domestic peers, particularly regarding access to funding. However, under our ratings methodology, we only maintain ratings on financial institutions above that of the sovereign in exceptional circumstances (see "Corporate, Counterparty, And LRG Credit Ratings That Exceed The Sovereign Rating," published Nov. 5, 2010). We typically do this only where we conclude that the operating and financial characteristics of an entity provide a high probability that it can meet its debt obligations even when the sovereign cannot. Barclays Bank Ireland PLC We lowered the long-term ratings on BBI to 'A-' from 'A' and the outlook is stable in line with the sovereign. Unlike its peers, BBI's outlook is stable because we see no reason to change our view of its 'core' group status. Given the exceptional circumstances we see, we have not lowered the BBI ratings to be in line with the 'BBB+' sovereign credit rating, instead allowing a one-notch differential. This is because: • We believe that BBI or its parent should be able to find sufficient foreign or local currency funding to repay its liabilities and all deposits; • In our view, BBI would be very easily supported by its parent due to its small relative size and the fact that the parent is highly rated, not being a government-supported institution itself; and • BBI's core status reflects our view that substantial support would be forthcoming from the parent. Ulster Bank Ireland Ltd., Ulster Bank Ltd. The rating action on UBIL and UBL follows the weakened creditworthiness of the Irish sovereign. This is because: • We consider UBIL to be core to U.K.-incorporated UBL, being about 70% of the consolidated assets, and highly integrated. We therefore believe that a deterioration of UBIL would weaken UBL, and a downgrade of UBIL would most certainly lead to a downgrade of UBL; and • While some of the factors cited with regard to BBI apply in this case, we do not see a convincing case to rate UBL above the Irish sovereign, not least because UBL is strategically important to a parent that is itself government-supported. The ratings on UBIL and UBL remain on CreditWatch negative pending a further review and analysis of the SACPs in light of the high stress factors applied to the domestic banks in the PCAR analysis and the significant changes elsewhere in the Irish banking system. KBC Bank Ireland PLC While some of the factors cited with regard to BBI apply to KBCI, we do not see a convincing case to rate KBCI above the Irish sovereign, not least because we view KBCI as strategically important as opposed to core to a parent that is itself government-supported. We continue to provide two notches of parental support, which are not constrained by the sovereign credit rating of 'BBB+', compared with KBCI's SACP of 'bbb-'. www.standardandpoors.com/ratingsdirect 7 859021 | 300001899 Various Rating Actions Taken On Irish Banks Following Financial Measures Programme And Bank Restructuring Plan The ratings on KBCI remain on CreditWatch negative pending a review and analysis of its SACP in light of the high stress factors applied to the domestic banks in the PCAR analysis and the significant changes elsewhere in the Irish banking system. RELATED CRITERIA AND RESEARCH • Ireland's Ratings Lowered To 'BBB+/A-2' And Removed From CreditWatch; Stable Outlook Reflects Credibility Of Stress Test, April 1, 2011 • Irish Life Assurance PLC CreditWatch Implications Revised To Developing On News Of Separation From Parent Bank, April 5, 2011 • How Systemic Importance Plays A Significant Role In Bank Ratings, July 3, 2007 • Group Methodology, April 22, 2009 • Bank Rating Analysis Methodology Profile, March 18, 2004 • Stand-Alone Credit Profiles: One Component Of A Rating, Oct. 1, 2010 • Methodology For Rating Bank Nondeferrable Subordinated Debt (Lower Tier 2 Regulatory Capital), Aug. 4, 2009 • Rating Government-Related Entities: Methodology And Assumptions, Dec. 9, 2010 • Mortgage Lending Business Supports Some European Banking Systems, Yet Could Impede Others, Sept. 2, 2010 RATINGS LIST Downgraded; CreditWatch Action; Ratings Affirmed To Anglo Irish Bank Corp. Ltd. Counterparty Credit Rating CCC+/Negative/C B-/Watch Neg/C Allied Irish Banks PLC Counterparty Credit Rating BB/Watch Neg/B BB/Watch Neg/B AIB Group (UK) PLC Counterparty Credit Rating BB-/Watch Neg/B BB-/Watch Neg/B Irish Life & Permanent PLC Counterparty Credit Rating BB+/Watch Neg/B BBB-/Watch Neg/A-3 Bank of Ireland Counterparty Credit Rating BB+/Watch Neg/B BB+/Watch Neg/B KBC Bank Ireland PLC Counterparty Credit Rating BBB+/Watch Neg/A-2 BBB+/Watch Neg/A-2 Barclays Bank Ireland PLC Counterparty Credit Rating A-/Stable/A-2 A/Watch Neg/A-1 From Ulster Bank Ireland Ltd. Standard & Poor’s | RatingsDirect on the Global Credit Portal | April 5, 2011 8 859021 | 300001899 Various Rating Actions Taken On Irish Banks Following Financial Measures Programme And Bank Restructuring Plan Ulster Bank Ltd. Counterparty Credit Rating BBB+/Watch Neg/A-2 A-/Watch Neg/A-2 NB: This list does not include all ratings affected. Additional Contact: Financial Institutions Ratings Europe; [email protected] Complete ratings information is available to subscribers of RatingsDirect on the Global Credit Portal at www.globalcreditportal.com. All ratings affected by this rating action can be found on Standard & Poor's public Web site at www.standardandpoors.com. Use the Ratings search box located in the left column. Alternatively, call one of the following Standard & Poor's numbers: Client Support Europe (44) 20-7176-7176; London Press Office (44) 20-7176-3605; Paris (33) 1-4420-6708; Frankfurt (49) 69-33-999-225; Stockholm (46) 8-440-5914; or Moscow (7) 495-783-4011. www.standardandpoors.com/ratingsdirect 9 859021 | 300001899 Copyright © 2011 by Standard & Poors Financial Services LLC (S&P), a subsidiary of The McGraw-Hill Companies, Inc. All rights reserved. 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