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Covered Bond Ratings On Depfa ACS - Hypo Real Estate Holding AG

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<strong>Covered</strong> <strong>Bond</strong> <strong>Ratings</strong> <strong>On</strong> <strong>Depfa</strong> <strong>ACS</strong> Bank's<br />

Public-Sector <strong>Covered</strong> <strong>Bond</strong>s Lowered; Outlook<br />

Stable<br />

Surveillance Credit Analyst:<br />

Andrew O'Neill, London (44) 20-7176-3578; andrew_oneill@standardandpoors.com<br />

Secondary Contact:<br />

Casper R Andersen, London (44) 20-7176-6757; casper_andersen@standardandpoors.com<br />

OVERVIEW<br />

• <strong>On</strong> Aug. 26, 2011, we placed our ratings on <strong>Depfa</strong> <strong>ACS</strong> Bank's public-sector<br />

covered bonds on CreditWatch with negative implications as the<br />

overcollateralization level in the cover pool was no longer sufficient to<br />

support the maximum potential covered bond rating.<br />

• Since then, we have assessed the issuer's willingness and ability to<br />

manage overcollateralization at a higher level. We have not observed any<br />

increase in available overcollateralization, despite the fact that, in<br />

our view, the credit quality of the cover pool of mainly European<br />

public-sector assets has deteriorated.<br />

• We are lowering our ratings on <strong>Depfa</strong> <strong>ACS</strong> Bank's public-sector covered<br />

bond programs and related issuances and removing them from CreditWatch to<br />

reflect our opinion of the increasing credit risk of the cover pool<br />

assets, and the fact that, in our view, the issuer is not managing<br />

overcollateralization to a level that we consider to be commensurate with<br />

an uplift above the issuer credit rating on the bank.<br />

• The outlook on these public-sector covered bonds is stable, reflecting<br />

the stable outlook on the issuer credit rating.<br />

• These ratings are based on our criteria for rating covered bonds (see<br />

"Advance Notice Of Proposed Criteria Change: Methodologies And<br />

Assumptions For Rating Certain <strong>Covered</strong> <strong>Bond</strong>s And CDOs", published on Aug.<br />

5, 2010). However, the methodologies and assumptions underlying these<br />

criteria are under review. The ratings on all outstanding covered bonds<br />

in this program may be affected as a result of this review.<br />

March 26, 2012<br />

www.standardandpoors.com/ratingsdirect 1<br />

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<strong>Covered</strong> <strong>Bond</strong> <strong>Ratings</strong> <strong>On</strong> <strong>Depfa</strong> <strong>ACS</strong> Bank's Public-Sector <strong>Covered</strong> <strong>Bond</strong>s Lowered; Outlook Stable<br />

LONDON (Standard & Poor's) March 26, 2012--Standard & Poor's <strong>Ratings</strong> Services<br />

today lowered its ratings on <strong>Depfa</strong> <strong>ACS</strong> Bank's (BBB/Stable/A-2) public-sector<br />

covered bond programs and related issuances. We have lowered the long-term<br />

covered bond rating to 'BBB' from 'AA', and the short-term covered bond rating<br />

to 'A-2' from 'A-1+'. At the same time we have removed the covered bond<br />

ratings from CreditWatch, where they were placed with negative implications on<br />

Aug. 26, 2011. The outlook is stable (see list below).<br />

The rating action follows our review of the information provided with respect<br />

to cover pool characteristics and cash flows (as of Feb. 29, 2012). We have<br />

applied our covered bond criteria and have reviewed the current<br />

asset-liability maturity mismatch (ALMM) risk classification, the program's<br />

categorization, the maximum potential covered bond ratings uplift, the cash<br />

flow and market value risk, and the credit enhancement provided (see "Revised<br />

Methodology And Assumptions For Assessing Asset-Liability Mismatch Risk In<br />

<strong>Covered</strong> <strong>Bond</strong>s," published on Dec. 16, 2009).<br />

As a result of this analysis, we have determined the maximum potential ratings<br />

uplift for <strong>Depfa</strong> <strong>ACS</strong> Bank's public-sector covered bond program to be six<br />

notches above the 'BBB' long-term issuer credit rating (ICR) on the bank. This<br />

is based on a program categorization of "2" and an ALMM classification of<br />

"low".<br />

We assign the rating to the covered bond program by assessing whether the<br />

available credit enhancement is equal to or greater than the target credit<br />

enhancement for the maximum potential rating under our criteria. The rating on<br />

the issuer is the floor to the covered bond rating. To determine the degree to<br />

which a covered bond rating may exceed the ICR, we assign the first notch of<br />

uplift if the available credit enhancement can mitigate the asset default<br />

risk. We calculate the overcollateralization which would cover the asset<br />

default risk which we deem commensurate with a 'AAA' rating, by applying to<br />

the scheduled cash flows:<br />

• the impact of missed payments and delayed recoveries arising from 'AAA'<br />

default stresses applied to the cover assets;<br />

• the implications of interest rate and foreign exchange mismatches between<br />

the cover assets and the covered bonds; and<br />

• the degree to which counterparty risk is mitigated according to our<br />

criteria.<br />

For any further elevation to the maximum potential rating, the remaining<br />

credit enhancement should be able to cover the market value risk arising from<br />

ongoing asset-liability mismatch.<br />

Based on this application of our criteria for assessing ALMM risk in covered<br />

bonds and our cash flow assumptions, which address market value risk, we<br />

believe that a credit enhancement level of 11.67% would currently be<br />

commensurate with the maximum potential 'AA' rating. We also believe that a<br />

credit enhancement level of 6.36% would currently cover all credit risks<br />

related to the default of the cover pool assets, and would therefore be<br />

Standard & Poors | <strong>Ratings</strong>Direct on the Global Credit Portal | March 26, 2012 2<br />

950905 | 301108613


<strong>Covered</strong> <strong>Bond</strong> <strong>Ratings</strong> <strong>On</strong> <strong>Depfa</strong> <strong>ACS</strong> Bank's Public-Sector <strong>Covered</strong> <strong>Bond</strong>s Lowered; Outlook Stable<br />

commensurate with a one-notch uplift above the ICR.<br />

As of Feb. 29, 2012, there were about €28.4 billion of covered bonds<br />

outstanding, secured by about €28.9 billion of public-sector assets. The<br />

geographic distribution of the public-sector assets is shown below.<br />

Country exposure % pool<br />

Germany 29%<br />

U.S. 21%<br />

Spain 9%<br />

Belgium 6%<br />

Supranationals 5%<br />

Netherlands 5%<br />

France 4%<br />

Italy 4%<br />

Other 17%<br />

The available overcollateralization of 1.74% was below the level we would<br />

consider commensurate with the first notch of uplift above the ICR.<br />

Consequently, we have not assigned any notches of uplift. The 'BBB' rating<br />

assigned to the covered bond programs and issuances is equal to the ICR on<br />

<strong>Depfa</strong> <strong>ACS</strong> Bank. The stable outlook also reflects the outlook on the ICR.<br />

Since we placed <strong>Depfa</strong> <strong>ACS</strong> Bank's covered bonds on CreditWatch on Aug. 26,<br />

2011, we have assessed the issuer's willingness and ability to manage<br />

overcollateralization at a higher level, and in particular whether the<br />

restructuring of the <strong>Hypo</strong> <strong>Real</strong> <strong>Estate</strong> group would impact the ongoing<br />

management level of overcollateralization. We have not observed any increase<br />

in available overcollateralization over this period.<br />

The issuer has maintained a stable level of overcollateralization, despite the<br />

fact that, in our opinion, the credit quality of the cover pool has<br />

deteriorated. We have reassessed our view of the creditworthiness of certain<br />

European public-sector borrowers to reflect the downgrade of eurozone<br />

sovereigns on Jan. 13, 2012. We have lowered ratings on U.S. student loan<br />

securitizations, which are included in the cover pool. We also note that<br />

following redemptions in February 2012, about €3 billion of assets were<br />

removed from the cover pool. A Spanish public-sector exposure, for which our<br />

credit quality assessment would be in the 'BB' category, remains in the cover<br />

pool and represents an increased share of about 6% following the asset<br />

removals. The assumed rating distribution of the cover pool assets in our<br />

analysis as of Feb. 29, 2012, is shown below.<br />

Rating distribution by category % pool<br />

AAA 26%<br />

AA 48%<br />

A 11%<br />

BBB 7%<br />

BB and below 8%<br />

www.standardandpoors.com/ratingsdirect 3<br />

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<strong>Covered</strong> <strong>Bond</strong> <strong>Ratings</strong> <strong>On</strong> <strong>Depfa</strong> <strong>ACS</strong> Bank's Public-Sector <strong>Covered</strong> <strong>Bond</strong>s Lowered; Outlook Stable<br />

We note that the overcollateralization ratios which we publish differ from<br />

those published by the issuer. This is a result of different presentation of<br />

zero-coupon liabilities. Data published by the issuer is based on zero-coupon<br />

bonds presented at their current notional amount, as per legal reporting<br />

requirements. In our publications we present zero-coupon bonds at their final<br />

redemption amount, consistently for all issuers. Under the issuer's reporting<br />

convention, as of Feb. 29, 2012, there were about €26.7 billion of covered<br />

bonds outstanding, secured by about €29 billion of public-sector assets,<br />

resulting in available credit enhancement of 8.81%.<br />

Our calculation of target credit enhancement levels is based on asset and<br />

liability cash flows, and not on initial nominal balances. Therefore, in our<br />

view, the difference in the overcollateralization ratios is presentational<br />

only. Based on the issuer's presentation of overcollateralization ratios, the<br />

credit enhancement level commensurate with the first notch of uplift would be<br />

13.75% and the credit enhancement commensurate with the maximum achievable<br />

rating would be 19.43%. This presentational difference has increased over time<br />

as cash-pay issuances have been redeemed, leaving zero-coupon bonds as an<br />

increasing portion of outstanding liabilities.<br />

POTENTIAL EFFECTS OF PROPOSED CRITERIA CHANGES<br />

We have taken today's rating actions on these covered bonds based on our<br />

criteria for rating covered bonds (see "Revised Methodology And Assumptions<br />

For Assessing Asset-Liability Mismatch Risk In <strong>Covered</strong> <strong>Bond</strong>s," published on<br />

Dec. 16, 2009). The assumptions and methodologies used in the credit and cash<br />

flow analysis are currently under review (see "Advance Notice Of Proposed<br />

Criteria Change: Methodologies And Assumptions For Rating Certain <strong>Covered</strong><br />

<strong>Bond</strong>s And CDOs," published on Aug. 5, 2010). The scope of our review of the<br />

analysis of public-sector assets may include our default rate stresses,<br />

correlation assumptions, recovery levels, model risk, concentration limits,<br />

and credit enhancement levels. Further, as part of our cash flow analysis, we<br />

used Standard & Poor's <strong>Covered</strong> <strong>Bond</strong> Monitor to calculate the target credit<br />

enhancement for the covered bonds. The assumptions and methodologies used in<br />

this cash flow analysis are also under review.<br />

This review may result in further changes to the criteria. As a result, our<br />

future assumptions and methodologies may differ from our current criteria. The<br />

criteria change may affect the ratings on all outstanding covered bonds in<br />

this program. Until such time that we adopt new criteria for rating covered<br />

bonds, we will continue to rate and surveil these covered bonds using our<br />

existing criteria (see "Related Criteria And Research").<br />

RELATED CRITERIA AND RESEARCH<br />

• <strong>Depfa</strong> Bank plc, March 19, 2012<br />

• Global <strong>Covered</strong> <strong>Bond</strong> Characteristics And Rating Summary Q4 2011, Jan. 24,<br />

2012<br />

• Request For Comment: Counterparty And Supporting Obligations Methodology<br />

And Assumptions--Expanded Framework, Nov. 21, 2011<br />

Standard & Poors | <strong>Ratings</strong>Direct on the Global Credit Portal | March 26, 2012 4<br />

950905 | 301108613


• Global Structured Finance Scenario And Sensitivity Analysis: The Effects<br />

Of The Top Five Macroeconomic Factors, Nov. 4, 2011<br />

• Request For Comment: <strong>Covered</strong> <strong>Bond</strong>s Counterparty And Supporting<br />

Obligations Methodology And Assumptions, March 23, 2011<br />

• Principles Of Credit <strong>Ratings</strong>, Feb. 16, 2011<br />

• Counterparty And Supporting Obligations Update, Jan. 13, 2011<br />

• Counterparty And Supporting Obligations Methodology And Assumptions, Dec.<br />

6, 2010<br />

• Advance Notice Of Proposed Criteria Change: Methodologies And Assumptions<br />

For Rating Certain <strong>Covered</strong> <strong>Bond</strong>s And CDOs, Aug. 5, 2010<br />

• Methodology: Credit Stability Criteria, May 3, 2010<br />

• Revised Methodology And Assumptions For Assessing Asset-Liability<br />

Mismatch Risk In <strong>Covered</strong> <strong>Bond</strong>s, Dec. 16, 2009<br />

• European Legal Criteria For Structured Finance Transactions, Aug. 28,<br />

2008<br />

• Methodology & Assumptions: Applying The Derivative Counterparty Framework<br />

To <strong>Covered</strong> <strong>Bond</strong>s, Feb. 26, 2008<br />

• Revised Framework for Applying Counterparty and Supporting Party Criteria,<br />

May 8, 2007<br />

• CDO Spotlight: Rating Approach To Synthetic CDOs Of Sovereigns Or Local<br />

And Regional Governments, May 3, 2006<br />

• Surviving Stress Scenarios: Assessing Asset Quality of Public Sector<br />

<strong>Covered</strong> <strong>Bond</strong> Collateral, Sept. 30, 2003<br />

• Irish <strong>Covered</strong> <strong>Bond</strong>s Eligible For A Delinked Rating Approach, Feb. 19,<br />

2003<br />

RATINGS LIST<br />

Rating Program/ To From<br />

Country: <strong>Covered</strong> bond type<br />

RATINGS LOWERED AND REMOVED FROM CREDITWATCH NEGATIVE; NEGATIVE OULOOK<br />

ASSIGNED<br />

<strong>Depfa</strong> <strong>ACS</strong> Bank<br />

<strong>Covered</strong> <strong>Bond</strong> <strong>Ratings</strong> <strong>On</strong> <strong>Depfa</strong> <strong>ACS</strong> Bank's Public-Sector <strong>Covered</strong> <strong>Bond</strong>s Lowered; Outlook Stable<br />

BBB/Stable AA/Watch Neg<br />

LONG-TERM RATING ON THE PROGRAM LOWERED<br />

BBB AA<br />

SHORT-TERM RATING ON THE PROGRAM LOWERED<br />

A-2 A-1+<br />

Ireland: Public-Sector <strong>Covered</strong> <strong>Bond</strong>s<br />

Additional Contact:<br />

<strong>Covered</strong> <strong>Bond</strong>s Surveillance; <strong>Covered</strong><strong>Bond</strong>Surveillance@standardandpoors.com<br />

www.standardandpoors.com/ratingsdirect 5<br />

950905 | 301108613


Copyright © 2012 by Standard & Poor's Financial Services LLC. All rights reserved.<br />

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