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Rating Action:

Moody's takes multiple actions on Spanish covered bonds

17 May 2012

Announcement follows actions on Spanish banks

Madrid, May 17, 2012 -- Moody's Investors Service has today downgraded the ratings of covered bonds issued under six programmes of Spanish banks. Moody's has also affirmed the ratings of covered bonds issued under five programmes. In addition, the ratings of covered bonds issued under ten programmes remain or have been placed on review for downgrade. These announcements were prompted by Moody's decision on 17 May 2012 to downgrade the senior debt ratings of the banks supporting the relevant covered bond programmes.

Please click this link http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF285536

for the list of affected covered bond ratings.

For additional information on covered bond ratings, please refer to the webpage containing Moody's related announcements http://www.moodys.com/eusovereign

Today's downgrades and affirmations conclude the review for downgrade, initiated on 16 February 2012 (see "Moody's takes negative actions on 17 Spanish covered bonds" for more details). That review followed Moody's wider review of European financial institutions driven in part by (i) the difficult European operating environment caused by the prolonged euro area crisis; and (ii) the deteriorating creditworthiness of certain euro area sovereigns (including Spain).

RATINGS RATIONALE

Today's covered bond downgrades and announcements follow Moody's rating actions on the relevant issuers' senior unsecured ratings (issuer ratings). Moody's has downgraded the covered bonds issued under six programmes because of the impact of the issuer rating downgrades under Moody's Timely Payment Indicator (TPI) framework. The ratings of covered bonds issued under five programmes have been affirmed. The affirmations are due to the fact that following the issuer downgrades (i) the expected loss of the covered bonds remains commensurate with their current ratings --taking into account the available over-collateralisation; and (ii) the TPI framework does not constrain the ratings below their current level. For more information on the rating actions taken by Moody's Financial Institutions Group, see the press release "Moody's downgrades Spanish banks; ratings carry negative outlooks or remain on review for downgrade" published on 17 May 2012. One covered bond rating has been placed on review while Moody's assesses the level of over-collateralisation the issuer can be expected to maintain (see further below).

Covered bond ratings are determined after applying a two-step process: an expected loss analysis and a TPI framework analysis.

(1) Expected Loss Method

Moody's expected loss analysis is negatively affected by the downgrade of the issuer ratings. As the credit strength of the issuer is incorporated into Moody's expected loss methodology, any downgrade of the issuer ratings will increase the expected loss on the covered bonds. However, Moody's notes that issuers may be able to offset any deterioration in the expected loss analysis if sufficient collateral is held in the cover pool.

Moody's has placed on review for downgrade BBVA's public-sector covered bonds, because the rating agency believes that there is a sufficient degree of uncertainty as to whether BBVA will be able to sustain over-collateralisation consistent with the current rating of Aa2 (56%).

Moody's measures the over-collateralisation percentage as the excess of assets over the issued amount of covered bonds, divided by the issued amount of covered bonds.

BBVA retains large amounts of public-sector covered bonds on its balance-sheet. These bonds would be cancelled -- and thus not reduce the over-collateralisation -- if the issuer defaults and the covered bonds are not placed at a third party. However, in its analysis, Moody's treats these covered bonds as issued amounts that can be sold or pledged at any time as collateral with third parties, up to an amount that makes the issuer reach the statutory 43% over-collateralisation level.

During the review, Moody's will assess BBVA's willingness and capacity to further strengthen its programmes by holding sufficient collateral to support the rating assigned to the covered bonds.

(2) TPI Framework

Moody's Timely Payment Indicator (TPI) framework limits a covered bond rating to a certain number of rating levels above the issuer rating of the relevant bank. The amount of uplift will depend on the TPI assigned and for all Spanish covered bonds Moody's currently assigns a TPI of "Improbable". The indicative rating uplift for covered bonds based on TPIs can be found in Moody's published TPI table.

However, Moody's notes that there are many factors that might influence the application of TPIs, in particular for sub-investment-grade-rated issuers. For such issuers, factors that influence the maximum rating achievable include (i) the level of over-collateralisation held in the programme; and (ii) the degree of adequate asset-liability matching.

Following the downgrade of Cajamar to Ba2, Moody's downgraded the corresponding mortgage and public-sector covered bonds to Baa1, which is one notch above the Baa2 level indicated by the TPI table. The higher final ratings were driven by a number of factors (i) the limited rating uplift of four notches over and above the issuer rating; (ii) high levels of committed over-collateralisation imposed by the law (25% for mortgage covered bonds and 43% for public-sector covered bonds); and (iii) the issuer rating not being on review for further downgrade, which provides the covered bonds with a higher degree of rating stability.

KEY RATING ASSUMPTIONS/FACTORS

The ratings assigned by Moody's address the expected loss posed to investors. Moody's ratings address only the credit risks associated with the transaction. Other non-credit risks have not been addressed, but may have a significant effect on yield to investors. Covered bond ratings are determined after applying a two-step process: an expected loss analysis and a TPI framework analysis.

- EXPECTED LOSS: Moody's determines a rating based on the expected loss on the bond. The primary model used is Moody's Covered Bond Model (COBOL), which determines expected loss as (i) a function of the issuer's probability of default (measured by the issuer's rating); and (ii) the stressed losses on the cover pool assets following issuer default.

- TPI FRAMEWORK: Moody's assigns a timely payment indicator (TPI), which indicates the likelihood that timely payment will be made to covered bondholders following issuer default. The effect of the TPI framework is to limit the covered bond rating to a certain number of notches above the issuer's rating.

SENSITIVITY ANALYSIS

The robustness of a covered bond rating largely depends on the issuer's credit strength.

A multi-notch downgrade of the covered bonds might occur in certain limited circumstances, such as (i) a sovereign downgrade that negatively affects both the issuer's senior unsecured rating and the TPI; (ii) a multi-notch downgrade of the issuer; or (iii) a material reduction of the value of the cover pool.

As the euro area crisis continues, the covered bond ratings remain exposed to the uncertainties of credit conditions in the general economy. The deteriorating creditworthiness of euro area sovereigns as well as the weakening credit profile of the global banking sector could negatively affect the ratings of covered bonds. For more information please refer to the Rating Implementation Guidance published on 13 February 2012 "How Sovereign Credit Quality May Affect Other Ratings". Please also refer to the recent rating actions on banks published on 15 February 2012, (please see "Moody's Reviews Ratings for European Banks" and "Moody's Reviews Ratings for Banks and Securities Firms with Global Capital Markets Operations" for more information).

Over and above any TPI consideration, country risk constrains the covered bonds' ratings at Aa2. For further information please refer to "Moody's lowers the highest achievable covered bond ratings in Italy, Portugal and Spain following the recent sovereign rating actions", dated 23 February 2012.

The principal methodology used in these ratings was "Moody's Approach to Rating Covered Bonds", published in March 2010. Please see the Credit Policy page on www.moodys.com for a copy of this methodology.

REGULATORY DISCLOSURES

For ratings issued on a program, series or category/class of debt, this announcement provides relevant regulatory disclosures in relation to each rating of a subsequently issued bond or note of the same series or category/class of debt or pursuant to a program for which the ratings are derived exclusively from existing ratings in accordance with Moody's rating practices. For ratings issued on a support provider, this announcement provides relevant regulatory disclosures in relation to the rating action on the support provider and in relation to each particular rating action for securities that derive their credit ratings from the support provider's credit rating. For provisional ratings, this announcement provides relevant regulatory disclosures in relation to the provisional rating assigned, and in relation to a definitive rating that may be assigned subsequent to the final issuance of the debt, in each case where the transaction structure and terms have not changed prior to the assignment of the definitive rating in a manner that would have affected the rating. For further information please see the ratings tab on the issuer/entity page for the respective issuer on www.moodys.com.

The ratings have been disclosed to the rated entities or their designated agent(s) and issued with no amendment resulting from that disclosure.

Information sources used to prepare each of the ratings are the following: parties involved in the ratings, parties not involved in the ratings, public information, and confidential and proprietary Moody's Investors Service information.

Moody's considers the quality of information available on the rated entities, obligations or credits satisfactory for the purposes of issuing these ratings.

Moody's adopts all necessary measures so that the information it uses in assigning the ratings 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.

Moody's Investors Service may have provided Ancillary or Other Permissible Service(s) to the rated entities or their related third parties within the two years preceding the credit rating action. Please see the special report "Ancillary or other permissible services provided to entities rated by MIS's EU credit rating agencies" on the ratings disclosure page on our website www.moodys.com for further information.

In addition to the information provided below please find on the ratings tab of the issuer page at www.moodys.com, for each of the ratings covered, Moody's disclosures on the lead rating analyst and the Moody's legal entity that has issued each of the ratings.

Please see the ratings disclosure page on www.moodys.com for general disclosure on potential conflicts of interests.

Please see the ratings disclosure page on www.moodys.com for information on (A) MCO's major shareholders (above 5%) and for (B) further information regarding certain affiliations that may exist between directors of MCO and rated entities as well as (C) the names of entities that hold ratings from MIS that have also publicly reported to the SEC an ownership interest in MCO of more than 5%. A member of the board of directors of this rated entity may also be a member of the board of directors of a shareholder of Moody's Corporation; however, Moody's has not independently verified this matter.

Please see Moody's Rating Symbols and Definitions on the Rating Process page on www.moodys.com for further information on the meaning of each rating category and the definition of default and recovery.

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

The date on which some ratings were first released goes back to a time before Moody's ratings were fully digitized and accurate data may not be available. Consequently, Moody's 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 www.moodys.com for any updates on changes to the lead rating analyst and to the Moody's legal entity that has issued the rating.

Jose de Leon
Senior Vice President
Structured Finance Group
Moody's Investors Service Espana, S.A.
Calle Principe de Vergara, 131, 6 Planta
Madrid 28002
Spain
JOURNALISTS: 44 20 7772 5456
SUBSCRIBERS: 44 20 7772 5454

Juan Pablo Soriano
MD - Structured Finance
Structured Finance Group
JOURNALISTS: 44 20 7772 5456
SUBSCRIBERS: 44 20 7772 5454

Releasing Office:
Moody's Investors Service Espana, S.A.
Calle Principe de Vergara, 131, 6 Planta
Madrid 28002
Spain
JOURNALISTS: 44 20 7772 5456
SUBSCRIBERS: 44 20 7772 5454

Moody's takes multiple actions on Spanish covered bonds
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