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Rating Action:

Moody's changes Lloyds financial strength outlook to stable from negative

13 Sep 2010

C- Bank Financial Strength rating outlook to stable from negative; Aa3 debt/ deposit ratings affirmed; subordinated debt and certain hybrid instruments upgraded

London, 13 September 2010 -- Moody's has changed the outlook on Lloyds TSB plc's C- standalone Bank Financial Strength Rating (BFSR) to stable from negative and affirmed the Aa3 senior debt and deposit ratings, which already had a stable outlook. The P-1 short-term rating was also affirmed. The C- Financial Strength Rating now maps to a standalone rating of Baa1 on the long-term scale, upgraded from the previous mapping of Baa2. The change in outlook and higher standalone rating is based on the stabilisation that is taking place in the financial profile of Lloyds Banking Group (LBG), and a reduced likelihood of the rating moving lower over the medium term.

The outlook on the D+ BFSR (mapping to a standalone rating of Baa3) of Bank of Scotland plc was also changed to stable from negative. Subordinated debt and certain hybrid ratings of the group (the "Must Pay" securities that are not required by the European Commission to skip coupons) were upgraded by one notch and the outlook changed to stable, in line with the change in the standalone rating. The "May Pay" securities that are required by the European Commission to skip coupons and the Enhanced Capital Notes (ECNs) were affirmed at their current level and the outlook changed to stable. The A1 senior debt ratings of Lloyds Banking Group (LBG) and HBOS, were affirmed. Moody's also affirmed and revised the outlooks to stable from negative for Baa1-rated subordinated debts at Clerical Medical and Scottish Widows plc.

RATINGS RATIONALE

RATIONALE FOR CHANGE OF FINANCIAL STRENGTH OUTLOOK

Since the last rating action in November 2009 when the Bank Financial Strength Rating was lowered to C- with a negative outlook following Lloyds' capital raising and decision not to participate in the UK government's Asset Protection Scheme, some notable improvements have become visible:

- ongoing deleveraging, including a reduction in non-core assets by GBP 87 billion,

- strengthened liquidity reserves, from GBP 105 billion at the end of 2008 to GBP 128 billion at the end of H110

- further progress in the integration of HBOS, including GBP 1.08bn of realised annualised cost savings as of H110

- indications that the earlier high level of impairments have peaked, with impairments of GBP 6.6bn in H110, compared to GBP 13.4bn in H109

- increase in Net Interest Margin from 1.72% in H109 to 2.08% in H110 against an environment of margin compression among many smaller banks and building societies in the UK

Moody's still considers that the profitability of UK banks will come under pressure from elevated impairments over 2010- 2011, despite early indications that they may be past the peak. The pressure may come particularly from areas such as consumer finance -- which is vulnerable to an increase in unemployment, or SME lending -- where small businesses may struggle to maintain cashflows even as the economy recovers.

However, the rating agency considers that further loan impairments at LBG can be absorbed at the bank's C- Bank Financial Strength Rating level. In particular, given the high level of impairments already taken on the bank's riskier commercial property assets, Moody's views LBG as able to withstand Moody's severe stress test without a need for further capital support.

Nevertheless, the C- Bank Financial Strength Rating also incorporates the many challenges facing the bank:

- the ongoing wind-down of the remaining large portfolio of Non-Core assets (GBP 217bn at H110)

- the reduction in the bank's high utilisation of wholesale funding, including government funding of GBP 120 billion at the end of H110 -- much of which matures in 2011, but which will partly be resolved by the wind-down of non-core assets mentioned above

- the completion of a complex integration, particularly the integration of IT systems which is scheduled to take place in 2011

- the sale of a portion of the bank's UK franchise due to EC requirements (likely to take place in 2012 after the integration is completed)

- the ongoing reduction of a large sectoral exposure to commercial real estate

Alongside these challenges is the risk of a further downturn in the UK economy.

"With the measures that Lloyds has been taking to strengthen the bank, its standalone credit strength is well captured at the standalone rating level of Baa1 with limited downside risks", said Elisabeth Rudman, a Senior Credit Officer at Moody's and lead analyst for LBG. "Steady progress in the integration of HBOS, as well as a further meaningful reduction of non-core assets and in the high level of wholesale financing, could lead to upward pressure on the standalone rating" Rudman continued. Whereas high levels of impairment losses or management actions which lead to a reduction in capital ratios from their current strong levels could lead to negative pressure on the standalone rating.

RATIONALE FOR AFFIRMED Aa3 SENIOR DEBT RATING, STABLE OUTLOOK

The Aa3 senior debt rating with a stable outlook for LTSB continues to incorporate our expectation of high support by the UK government. (Please also refer to the Special Comment "Phasing Out Extraordinary Support Assumptions from UK Bank Ratings" published in March 2009, for further information on our views on systemic support for UK banks).

Despite EC requirements for LBG to dispose of 600 branches and 4.6% market share of the personal current account market in the UK and approximately 19% of the group's mortgage assets by November 2013, we expect that LBG will remain one of the largest retail and commercial banks in the UK and that this size and presence will result in the continuation of the very high probability of support from the UK government in the future.

Although we expect with time to phase out the levels of extraordinary support incorporated in the ratings of banks such as Lloyds (which has 4 notches of uplift from the Bank Financial Strength Rating to the senior debt ratings), an important factor in our assessment will be the outcome of further government actions, including the government-sponsored commission to review the structure of the banking system, the development of living wills, and the timing of the sale of the government's shareholding in LBG.

OUTLOOK ON BANK OF SCOTLAND D+ FINANCIAL STRENGTH RATING CHANGED FROM NEGATIVE TO STABLE

The change in outlook of Bank of Scotland's D+ Bank Financial Strength Rating (which maps to Baa3 on the long-term debt rating scale) reflects the fact that LBG is proactively winding down some of the riskiest assets within Bank of Scotland (BoS), as well as increasing integration of Bank of Scotland/ HBOS within LBG. Nevertheless, the standalone financial strength rating still remains lower at BoS than at Lloyds TSB (whose BFSR represents the standalone financial strength of the combined group), due to the higher concentration of weaker assets and slightly lower capital ratios (Tier 1 ratio of 7.6% at BoS at H110 and 9.4% at HBOS, compared to 10.3% at LBG). However, as we move closer to the full integration of BoS/ HBOS within LBG, we would expect its standalone ratings to be aligned with Lloyds TSB.

UPGRADE OF DATED SUBORDINATED AND "MUST PAY" HYBRID SECURITIES, AFFIRMATION OF "MAY PAY" HYBRID SECURITIES AND ECNS

The dated subordinated and hybrid securities of Lloyds Banking Group, which are not required by the European Commission to skip coupon payments ("Must Pay" securities), have been upgraded by 1 notch and the outlook changed from negative to stable. This is in line with the upgrade in the mapping of the financial strength rating from Baa2 to Baa1. Consequently the dated subordinated debt of Lloyds TSB and Bank of Scotland is upgraded from Baa3 to Baa2, and the dated subordinated debt of Lloyds Banking Group and HBOS is upgraded from Ba1 to Baa3. For more information on the hybrid securities and their ISINs, please refer to Moody's press release of 23rd November ("Moody's concludes rating action on Lloyds hybrid and junior subordinated debt").

The hybrid securities of Lloyds Banking Group that are skipping coupon payments in line with EC requirements ("May Pay" securities) and are rated on an expected loss basis have been affirmed at their current level and the outlook changed from negative to stable.

The Enhanced Capital Notes, the dated non-deferrable Contingent Capital Instruments which convert to equity if the group's Core Tier 1 ratio drops below 5%, have been affirmed at their current level (Ba2 for notes guaranteed by Lloyds TSB and Ba3 for notes guaranteed by Lloyds Banking Group) and the outlook changed from negative to stable. The rating of these instruments reflects the high loss severity to investors in the event of conversion and the lack of transparency of the trigger due to influence of the regulator on the calculation of RWAs. The ratings of these instruments is not likely to move higher if the bank's standalone rating is upgraded.

OUTLOOK ON INSURANCE SUBORDINATED DEBTS CHANGED TO STABLE

Moody's also affirmed and revised the outlooks to stable from negative for Baa1-rated subordinated debts at Clerical Medical and Scottish Widows plc.

Moody's said that the revision to stable from negative for the subordinated debts at Lloyds TSB's insurance operations (Scottish Widows plc and Clerical Medical) reflected the ongoing stability of the insurance operations -- Aa3 and A1 IFSR, stable outlook, respectively -- as well as the upgrade and stable outlook for subordinated securities at Lloyds TSB Bank and Bank of Scotland. Moody's added that the insurance subordinated debt continues to be rated higher than the subordinated debt of both Lloyds TSB Bank and Bank of Scotland by one notch and two notches respectively. This reflects Moody's expectations that the solvency positions of both Scottish Widows and Clerical Medical will continue to be robust going forward . Nevertheless, whilst we believe the capital of the insurance operations remains partially protected, the insurance subordinated debts continue to be notched wider than Moody's standard notching for insurers, reflecting Moody's view that Lloyds Banking Group's capital base is increasingly managed centrally.

PREVIOUS RATING ACTION AND METHODOLOGY

The principal methodologies used in rating Lloyds Banking Group were Bank Financial Strength Ratings: Global Methodology published in February 2007, and Incorporation of Joint-Default Analysis into Moody's Bank Ratings: A Refined Methodology published in March 2007. Other methodologies and factors that may have been considered in the process of rating this issuer can also be found on Moody's website.

The last rating action on the group was 23rd November 2009, when we concluded the reviews on hybrid securities. The last announcement on the bank's BFSR was on 3 November 2009 when the BFSR was downgraded to C- with a negative outlook.

Lloyds Banking Group is based in the United Kingdom, and had total assets of GBP 1,028 billion at 30 June 2010.

REGULATORY DISCLOSURES

Information sources used to prepare the credit rating are the following: parties involved in the ratings, public information, confidential and proprietary Moody's Investors Service's information.

Moody's Investors Service considers the quality of information available on the issuer or obligation satisfactory for the purposes of maintaining a credit rating.

The rating has been disclosed to the rated entity or its designated agents and issued with no amendment resulting from that disclosure.

Moody's Investors Service may have provided Ancillary or Other Permissible Service(s) to the rated entity or its related third parties within the three years preceding the Credit Rating Action. Please see the ratings disclosure page www.moodys.com/disclosures on our website for further information.

MOODY'S adopts all necessary measures so that the information it uses in assigning a credit rating is of sufficient quality and from sources MOODY'S considers to be reliable including, when appropriate, independent third-party sources. However, MOODY'S is not an auditor and cannot in every instance independently verify or validate information received in the rating process.

Please see ratings tab on the issuer/entity page on Moodys.com for the last rating action and the rating history.

The date on which some Credit Ratings were first released goes back to a time before Moody's Investors Service's Credit Ratings were fully digitized and accurate data may not be available. Consequently, Moody's Investors Service provides a date that it believes is the most reliable and accurate based on the information that is available to it. Please see the ratings disclosure page on our website www.moodys.com for further information.

Please see the Credit Policy page on Moodys.com for the methodologies used in determining ratings, further information on the meaning of each rating category and the definition of default and recovery.

London
Elisabeth Rudman
VP - Senior Credit Officer
Financial Institutions Group
Moody's Investors Service Ltd.
JOURNALISTS: 44 20 7772 5456
SUBSCRIBERS: 44 20 7772 5454

London
Johannes Wassenberg
MD - Banking
Financial Institutions Group
Moody's Investors Service Ltd.
JOURNALISTS: 44 20 7772 5456
SUBSCRIBERS: 44 20 7772 5454

Moody's Investors Service Ltd.
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Moody's changes Lloyds financial strength outlook to stable from negative
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