Commonwealth Bank of Australia
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Commonwealth Bank of Australia Primary Credit Analyst: Nico N DeLange, Sydney (61) 2-9255-9887; nico.delange@standardandpoors.com Secondary Contact: Gavin J Gunning, Melbourne (61) 3-9631-2092; gavin.gunning@standardandpoors.com Table Of Contents Major Rating Factors Rationale Outlook Related Criteria And Research WWW.STANDARDANDPOORS.COM/RATINGSDIRECT DECEMBER 18, 2014 1 1376165 | 301569575
Commonwealth Bank of Australia Additional SACP a + Support +2 + Factors 0 Anchor a- Issuer Credit Rating Business GRE Support 0 Position Strong +1 Capital and Earnings Adequate 0 Group Support 0 Risk Position Adequate 0 AA-/Stable/A-1+ Funding Average 0 Sovereign Support +2 Liquidity Adequate Major Rating Factors Strengths: Weaknesses: • Robust business and market position in key retail • Dependence on wholesale offshore borrowings, market segments in Australia and New Zealand which could disrupt funding access • Low-risk traditional Australian and New Zealand retail and commercial banking activities • Technology platform a competitive advantage • Globally among the strongest banks on key earning and asset quality metrics • Potential recipient of extraordinary government support in the unlikely event it was required Rationale Standard & Poor's Ratings Services ratings on Commonwealth Bank of Australia (CBA) are based on a combination of factors including the anchor stand-alone credit profile (SACP), company-specific factors, and our expectation that the bank would receive extraordinary government support in a crisis. For CBA, we start with an anchor of 'a-' and then adjust it for a "strong" business position, which reflects the robust business and market position in key retail market segments in Australia and New Zealand. We view CBA's capital and earnings position as "adequate" and therefore neutral to the rating, as measured by Standard & Poor's RAC ratio. We assess CBA's risk position as "adequate" to reflect its low-risk traditional Australian and New Zealand retail and commercial banking activities. We consider CBA's funding and liquidity positions as "average" and "adequate," respectively, to reflect the bank's stable and diverse WWW.STANDARDANDPOORS.COM/RATINGSDIRECT DECEMBER 18, 2014 2 1376165 | 301569575
Commonwealth Bank of Australia funding profile and liquidity buffers that include the Reserve Bank of Australia (RBA) committed liquidity facility (CLF). We adjust the resulting SACP of 'a' upwards by two notches to arrive at the issuer credit rating (ICR) of 'AA-'. We make this adjustment to account for our expectation of a high likelihood of extraordinary government support for CBA, reflecting its high systemic importance in the Australian banking system. Anchor: We view Australia as having a diversified, high-income, flexible, and resilient economy--factors that reduce the risk of significant and sustained downturns. The Australian banking sector benefits from conservative regulation, disciplined regulatory supervision, and a government that has traditionally been "highly-supportive" toward the banking sector. Further, the sector is supported by a stable, orderly industry structure characterized by an overall low-risk appetite with banking activities tending to be centered on vanilla retail and commercial banking activities. Offsetting these positive features is the Australian banking sector's exposure to risks related to economic imbalances--including high external debt and persistent current account deficits, and, more recently, material house price appreciation--and is materially dependent on net external borrowings, as core customer deposits are not sufficient for meeting long-term funding needs. The SACP for CBA is 'a'. Table 1 Commonwealth Bank of Australia Key Figures --Year-ended June 30-- (Mil. A$) 2014 2013 2012 2011 2010 Adjusted assets 766,517 729,410 694,369 643,609 621,281 Customer loans (gross) 591,009 552,208 526,845 498,964 494,998 Adjusted common equity 33,958 30,345 27,552 24,752 22,705 Operating revenues 22,500 21,554 20,384 19,397 19,288 Noninterest expenses 9,152 9,340 8,995 8,692 8,396 Core earnings 9,064 7,984 7,395 6,709 5,941 Business position: Robust business and market position in key retail market segments; technology platform a competitive advantage As the largest retail bank in Australia, CBA has a strong and stable business franchise compared to domestic peers and other global banks. Our opinion is based on CBA's dominant domestic retail market share in Australia (in both residential home loans and retail deposits) and leading customer satisfaction scores, which we believe are supported by CBA's consistent and focused strategy and its competent management team. We note that CBA's overall leading customer-satisfaction scores may be challenged as competitors close the gap. A key factor underpinning business stability is CBA's dominant (25%) domestic market share in residential mortgage lending and retail deposits, with loan growth in both areas at around system levels. We note that the group also has substantial wealth-management operations, with its Australian retail funds about 16% of the market and Australian Life Insurance (total risk and individual risk) about 12.5% of the market. Overall, we are of the view that these retail business lines contribute to the stability of CBA's revenues and business activities, as they generate recurring net interest income and fee income. WWW.STANDARDANDPOORS.COM/RATINGSDIRECT DECEMBER 18, 2014 3 1376165 | 301569575
Commonwealth Bank of Australia That said, compared to industry peers, CBA is more concentrated in terms of geography (82.8% of credit exposures are in Australia and 9% of credit exposures are in New Zealand). In our opinion, technology, one of the centerpieces of CBA' strategy, differentiates CBA from its peers and creates a competitive advantage, as it translates real time banking, improved efficiencies, and improved product and application development into improved customer satisfaction and benefits. We note that the group's investment in technology is also driving productivity and process simplification, leading to tangible benefits in the form of operational efficiencies from productivity initiatives, and positively impacting the expense base. We view the group's strategy as a customer-focused one that builds upon the group's four key capabilities of people, technology, strength and productivity to deepen its relationship with its customer base. Outside of the Australasian borders, CBA's Asian expansion strategy is expected to remain targeted on acquisitions and ventures that are value additive for shareholders. In our view, CBA has an experienced and competent executive team in place. Table 2 Commonwealth Bank of Australia Business Position --Year-ended June 30-- (%) 2014 2013 2012 2011 2010 Total revenues from business line (mil. A$) 22,500 21,554 20,384 19,397 19,288 Commercial & retail banking/total revenues from business line 83.4 82.3 79.9 82.7 79.5 Insurance activities/total revenues from business line 4.6 5.7 6.0 5.8 6.4 Asset management/total revenues from business line 9.0 10.0 9.5 10.5 10.0 Return on equity 18.8 18.2 18.6 18.2 17.5 Capital and earnings: a neutral ratings factor Our view of CBA's capital and earnings takes into account the bank's stable level of capitalization, the high quality of its capital, as well as its strong and stable operating performance relative to peers. We've revised our economic risk assessment for the banking system in Australia upward, leading to a decrease in the static risk-adjusted capital (RAC) ratio of about 8 basis points. The upward revision reflects our views around CBA's gradual build-up in house prices, in particular in Sydney and Melbourne over the past seven years and the impact on economic imbalances. As result of the buildup, we consider economic risk (one of the key drivers in our RAC ratio) to be higher in the Australian banking system; therefore the increase in risk weighted assets. On a forward-looking basis we project that CBA's pre-diversification RAC ratio would stabilize in the 8.2%-8.7% range over the next 12-18 months. Our forward-looking assessment is based on assumptions. The key assumptions underpinning our analysis are the following: • Loan growth to remain at around system levels; • Some margin pressures to remain--primarily as a result of competitive pressures; • Credit loss provisions to remain flat over the forecasting period; and • A dividend payout ratio of around 75%. WWW.STANDARDANDPOORS.COM/RATINGSDIRECT DECEMBER 18, 2014 4 1376165 | 301569575
Commonwealth Bank of Australia Our assumptions do not take into account the higher capital requirement recommendations of the Financial System Inquiry (FSI), as the government still needs to consult with stakeholders on the final report before making decisions on the recommendations; a formal government response would only be released by mid-2015. We are of the view that because CBA (an internal-ratings based (IRB) accredited bank) has a higher percentage of residential mortgage loans relative to peers, the proposal to increase the average residential mortgage risk weights to a range of between 25% and 30% will have a greater impact on CBA if CBA were to restore its capital position to current levels. We note that CBA's Common Equity Tier 1 (CET1) ratio would be close to its threshold levels, including the capital conservation buffer (CCB) and domestically systemic important bank (D-SIB) buffer if the recommendations were implemented. We are of the view that the increase in the capital levels would have a solidifying effect on CBA's neutral capital setting, or it could even have an improving effect--dependent on final rules and individual bank capital-management philosophies. From a prudential capital adequacy perspective, CBA's CET1 ratio of 9.3% is well above the Australian Prudential Regulation Authority (APRA) minimum requirements of a CET1 minimum of 4.5% effective Jan. 1, 2013, and the CET1 plus CCB and D-SIB buffer minimum of 8%, effective Jan. 1, 2016. In our view, CBA's capital base is of good quality, with hybrid capital playing a supplementary role rather than a primary role in its capital strategy. CBA's ratio of adjusted common equity to total adjusted capital was 87%. We project that this ratio would decrease to about 84% over our forecasting period, with the bank's reliance on hybrid capital instruments, as Basel II instruments are replaced with Basel III instruments. We are of the view that the group's profitability track record over the past five years (during the GFC and commensurate economic slowdown and commercial property downturn) had also been very good by international standards. This is reflected in the group's core earnings-to-adjusted assets ratio of 1.18%, which was better than the majority of the Australian peers and international peers. Table 3 Commonwealth Bank of Australia Capital And Earnings --Year-ended June 30-- (%) 2014 2013 2012 2011 2010 Tier 1 capital ratio 11.1 10.2 10.0 10.0 9.2 Adjusted common equity/total adjusted capital 88.4 86.5 86.0 84.8 77.3 Net interest income/operating revenues 67.1 64.6 64.4 64.9 61.8 Fee income/operating revenues 23.3 24.2 24.2 25.6 27.8 Market-sensitive income/operating revenues 3.8 4.0 3.8 2.3 2.5 Noninterest expenses/operating revenues 40.7 43.3 44.1 44.8 43.5 Preprovision operating income/average assets 1.7 1.7 1.6 1.6 1.7 Core earnings/average managed assets 1.2 1.1 1.1 1.0 0.9 Risk position: low-risk traditional Australian and New Zealand retail and commercial banking activities We are of the view that CBA's asset quality track record is evidence of the bank's rigorous and conservative underwriting policies employed. While CBA's GFC-related losses were lower compared with many highly-rated international banks, we note that the economic and commercial property downturns in Australia and New Zealand and WWW.STANDARDANDPOORS.COM/RATINGSDIRECT DECEMBER 18, 2014 5 1376165 | 301569575
Commonwealth Bank of Australia the impact on the banking system were less severe than that experienced in the U.S. and Europe. Compared to peer banks, CBA's net charge-offs as a percentage of normalized losses compare favorably by international standards, with actual losses less than normalized losses. We note that CBA's growth in residential mortgage loans and non-financial corporations loans were at around system level over the last year. Over the medium term the group is not targeting the move into new product, consumer, or market activities in a material way outside its traditional areas of expertise. In our view the risk characteristics of CBA's exposures are adequately captured by our RAC ratio, with the focus of the bank on core retail and commercial banking activities. We note that regulatory capital requirements for interest rate risk in the banking book amounted to about 4.4% of CBA's total risk-weighted assets at June 30, 2014. Concerning CBA's financial planning business, we are of the view that the Open Advice Review program of review and remediation to deliver fair and consistent outcomes to customers affected by the poor advice provided by advisers of the bank's Commonwealth Financial Planning and Financial Wisdom currently do not have a bearing on our assessment of CBA's risk position. We believe that the group's Annual Report and Pillar 3 disclosures are transparent, and allow good visibility into CBA's underlying risk exposures and earnings generation. From a complexity point of view, retail products dominate CBA's balance sheet; the group also does not have excessive exposures to derivatives, securitizations, and structured credits. We view CBA's risk-appetite framework as conservative. The risk appetite framework spans the whole group and its divisions. A silo approach to risk management is not undertaken; on the contrary risk management is embedded at a business unit level, with additional group-wide oversight and aggregation. Risk appetite is dynamic in nature, and is reviewed on a regular basis in conjunction with CBA's strategic plans and business actions. Table 4 Commonwealth Bank of Australia Risk Position --Year-ended June 30-- (%) 2014 2013 2012 2011 2010 Growth in customer loans 7.0 4.8 5.6 0.8 5.5 Total managed assets/adjusted common equity (x) 23.3 24.8 26.1 27.0 28.5 New loan loss provisions/average customer loans 0.2 0.2 0.2 0.3 0.5 Net charge-offs/average customer loans 0.3 0.3 0.3 0.4 0.4 Gross nonperforming assets/customer loans + other real estate owned 1.0 1.2 1.4 1.8 1.7 Loan loss reserves/gross nonperforming assets 67.6 66.9 64.6 56.8 63.4 Funding and liquidity: dependence on wholesale offshore borrowings In our view CBA and the other Australian major banks are materially reliant on wholesale funding--this being a fundamentally negative rating factor. However, much of this risk has been taken into account by us in our system-wide funding score of "intermediate" that forms part of our Australian BICRA assessment. We are of the opinion that CBA's funding profile metrics are around the average of domestic peers', solidifying the "average" funding assessment. Our funding metrics include CBA's loan-to-deposit ratio (134%), long-term funding ratio WWW.STANDARDANDPOORS.COM/RATINGSDIRECT DECEMBER 18, 2014 6 1376165 | 301569575
Commonwealth Bank of Australia (81%), and short-term wholesale funding to total funding base (20%). We note that the trends in these ratios had been improving during recent years. We expect CBA will continue to improve the management of its funding profile by reducing reliance on short-term funding and extending its maturity profile on long-term funding in line with the trend seen since 2008. Of CBA's total funding, 64% relates to the customer sector. Compared to the other large Australian banks, CBA has the highest proportion of household deposits, at 29%. From a quantitative-liquidity-ratio perspective, CBA and the other Australian major banks have weaker liquidity ratios. This is largely due to the shortage of liquid assets in the banking system as a result of low overall government debt levels. Consequently the low government debt levels and low levels of liquid assets in the system also result in the Australian major banks falling short of the liquidity-coverage-ratio requirements of Basel III, primarily due to a shortage of qualifying liquid assets. To this end we wish to note that: • The Reserve Bank of Australia (RBA) has stepped in to make available a committed liquidity facility (CLF) for banks in order to meet the liquidity-coverage-ratio requirements; importantly securities to be used under the CLF would also include self-securitised mortgages in addition to the securities eligible for the RBA's normal market operations. • The CLF would function in the same way in stressed market conditions as high-quality-liquid-asset do. • Banks have entered into consultation with APRA to determine their size of the CLF available to them. We regard CBA's liquidity as well managed. For fiscal 2014, total liquid assets increased to A$139 billion from A$135 billion in June 2012. Specific stress tests are conducted routinely for liquidity-risk-management purposes. The stress tests look to identify the timeframe over which high-quality liquid assets could survive under various stress liability run-off scenarios. Capital markets are accessed through a wide variety of programs, including covered bonds as well as senior unsecured short- and long-term programs. Table 5 Commonwealth Bank of Australia Funding And Liquidity --Year-ended June 30-- (%) 2014 2013 2012 2011 2010 Core deposits/funding base 64.2 63.6 62.6 61.9 58.6 Customer loans (net)/customer deposits 133.6 134.7 137.2 141.1 151.2 Long term funding ratio 81.3 80.8 80.8 78.5 78.8 Stable funding ratio 92.0 91.3 90.9 86.9 87.4 Short-term wholesale funding/funding base 19.9 20.3 20.3 22.6 22.5 Broad liquid assets/short-term wholesale funding (x) 0.8 0.7 0.7 0.6 0.6 Short-term wholesale funding/total wholesale funding 54.5 54.8 53.2 58.2 52.7 Support: Our issuer credit rating on CBA is two notches higher than the SACP, reflecting our view of a high likelihood of extraordinary government support in a crisis. This reflects our view of CBA's high systemic importance in Australia, and our assessment of the Australian government as highly supportive of institutions core to the national economy. WWW.STANDARDANDPOORS.COM/RATINGSDIRECT DECEMBER 18, 2014 7 1376165 | 301569575
Commonwealth Bank of Australia We remain of the view that ratings of systemically-important banks (such as CBA) would likely be negatively impacted if the government eventually was to adopt a different approach to bank resolutions, whereby we believed there could be a greater appetite for bail-in of senior bank creditors. Additional rating factors The issue ratings on CBA's non-Basell III non-deferrable subordinated debt are 'A-', or one notch below CBA's SACP. The issue ratings on CBA's Basel III non-deferrable subordinated debt are 'BBB+', or two notches below CBA's SACP. This is because we believe that Australia's legal and regulatory framework could allow authorities to instigate restructuring of a failing bank to the detriment of non-deferrable subordinated debt and for the Basel III instruments we apply a one-notch additional deduction to reflect the contingency clause that requires the mandatory conversion into common equity on the activation of a non-viability trigger. The issue ratings on ASB Bank Ltd.'s (ASB) Basel III non-deferrable subordinated debt reflect our view that ASB is a core subsidiary of CBA. We note that the short-to-medium term prospects for CBA experiencing financial stress to the extent it requires a restructuring to the detriment of non-deferrable subordinated debt holders is low. The issue ratings on CBA's non-Basel III hybrid capital instruments are three notches below the SACP. The issue rating on CBA's Basel III complaint hybrid capital instruments (PERLS VI and PERLS VII) are four notches below the SACP. We apply a one-notch additional deduction to reflect the contingency clause that requires the mandatory conversion into common equity on the activation of a non-viability trigger. Table 6 Commonwealth Bank of Australia Risk-Adjusted Capital Basel II Average Basel II Standard & Average Standard & (Mil. A$) Exposure* RWA RW (%) Poor's RWA Poor's RW (%) Credit risk Government and central banks 64,263 5,774 9 2,665 4 Institutions 43,401 10,959 25 10,067 23 Corporate 198,525 140,548 71 161,503 81 Retail 532,910 115,422 22 181,605 34 Of which mortgage 470,384 75,985 16 142,299 30 Securitization§ 9,812 5,010 51 7,312 75 Other assets 10,165 4,214 41 11,736 115 Total credit risk 859,075 281,927 33 374,888 44 Market risk Equity in the banking book† 2,576 0 0 22,789 885 Trading book market risk -- 5,284 -- 7,926 -- Total market risk -- 5,284 -- 30,715 -- Insurance risk Total insurance risk -- -- -- 33,413 -- Operational risk Total operational risk -- 28,531 -- 45,838 -- WWW.STANDARDANDPOORS.COM/RATINGSDIRECT DECEMBER 18, 2014 8 1376165 | 301569575
Commonwealth Bank of Australia Table 6 Commonwealth Bank of Australia Risk-Adjusted Capital (cont.) Basel II Standard & % of Standard & (Mil. A$) RWA Poor's RWA Poor's RWA Diversification adjustments RWA before diversification 337,716 484,853 100 Total Diversification/Concentration -- (72,094) (15) Adjustments RWA after diversification 337,716 412,759 85 Tier 1 Total adjusted Standard & Poor's (Mil. A$) capital Tier 1 ratio (%) capital RAC ratio (%) Capital ratio Capital ratio before adjustments 37,608 11.1 38,406 7.9 Capital ratio after adjustments¶ 37,608 11.1 38,406 9.3 *Exposure at default. §Securitisation Exposure includes the securitisation tranches deducted from capital in the regulatory framework. ¶Adjustments to Tier 1 ratio are additional regulatory requirements (e.g. transitional floor or Pillar 2 add-ons). RWA--Risk-weighted assets. RW--Risk weight. RAC--Risk-adjusted capital. Sources: Company data as of June. 30, 2014, Standard & Poor's. WWW.STANDARDANDPOORS.COM/RATINGSDIRECT DECEMBER 18, 2014 9 1376165 | 301569575
Commonwealth Bank of Australia Outlook: Stable The stable outlook reflects our opinion that our ratings on CBA are likely to remain unchanged in the short-to-medium term. We expect that in maintaining the stable outlook that CBA would: • Uphold its leading retail banking position in Australia and New Zealand; • Sustain its RAC ratio in the "adequate" range over the next 12-18 months; • Preserve its "adequate" risk position by ensuring its conservative risk-appetite framework is embedded in the group across all divisions; and • Sustain its funding profile relative to the other Australian banks and banks with a similar industry risk score. As a "highly systemically-important" bank domiciled in a country that we view as "highly supportive" of institutions that are core to the national economy, CBA's 'AA-' ratings are not likely to change as long as: • The Australian government's willingness to provide extraordinary support remains "highly supportive". We note that the development and implementation of a more comprehensive resolution regime in Australia, particularly if it infers wide bail-in powers for the regulator, could potentially weaken our assessment of a government's tendency to support private-sector banks. • The 'AAA' long term local currency issuer credit rating the Commonwealth of Australia is not lowered to 'AA+'. In such a scenario the issuer credit rating on CBA would be lowered to 'A+' from 'AA-'. CBA's long-term issuer credit rating could also be lowered if its SACP deviate outside the 'a-' to 'a+' range (that is, by more than two notches). A scenario that may lead to a two notch adjustment in the SACP may be a revision of the economic risk score is revised to '4' from '3' resulting in a change in the anchor rating to 'bbb+' and a revision in the capital and earnings assessment to 'moderate' form 'adequate' due to the increase in risk weighted assets; in our view, the occurrence of such an event is remote. A one notch deterioration of CBA's SACP to 'a-' from 'a' would not cause a negative revision to the issuer credit ratings. Factors that might have a negative bearing on the SACP are the following: • A change in the anchor SACP to 'bbb+' from 'a-' as a result of a downward revision of both the industry risk and economic risk scores on Australia to '3'. In this regard we note that economic risk score of Australia was assigned a negative trend. • A reduction in CBA's RAC ratio to below 7% that would lead to a revision of the capital and earnings score to "moderate" from "adequate." We are of the opinion that a negative revision of our economic risk score for Australia to '4' from '3' would be unlikely to cause us to negatively revise CBA's capital and earnings position, as it is unlikely that CBA's RAC ratio would dip below the "adequate" range over the next 12-18 months despite the score change. • The emergence of risks outside the tolerances within the current SACP and our capital and earning assessment, such as a material deterioration in asset quality or earnings that would cause us concern if measured against domestic and international standards. • The unlikely event that CBA experienced funding or liquidity stress, causing its funding assessment to fall below the average for peer banks in Australia and banks with a similar industry risk score. In a significant liquidity stress event, we expect that the bank will qualify for central bank and other government-support mechanisms. We do not expect that we will raise CBA's issuer credit rating in the short to medium term. A SACP factor that may have a positive bearing on CBA's rating is the banks actual losses compared to normalized losses in terms of our risk adjusted capital framework. In combination with the adjustment of the economic risk score to '3' we are of the view that the potential may exists that there may be positive momentum at SACP level for CBA's risk position assessment if asset quality trends continue to improve going forward. We also believe that if CBA achieved and WWW.STANDARDANDPOORS.COM/RATINGSDIRECT DECEMBER 18, 2014 10 1376165 | 301569575
Commonwealth Bank of Australia sustained a RAC ratio in excess of 10% this would likely be supportive of a positive reassessment of the bank's SACP. Related Criteria And Research Related Criteria • Group Rating Methodology, May 7, 2013 • Banks: Rating Methodology And Assumptions, Nov. 9, 2011 • Banking Industry Country Risk Assessment Methodology And Assumptions, Nov. 9, 2011 • Bank Capital Methodology And Assumptions, Dec. 6, 2010 • Revised Market Risk Charges For Banks In Our Risk-Adjusted Capital Framework, June 22, 2012 • Bank Hybrid Capital Methodology And Assumptions, Nov. 1, 2011 Related Research • No Immediate Impact On Australian Financial Institutions Ratings Following The Australian Financial System Inquiry, Dec. 8, 2014 • The Top 100 Rated Banks: Will 2014 Mark A Turning Point In Capital Cushioning? Oct. 6, 2014 • Australian Bank Ratings Holding Up As Cheap Money And Rising Residential Property Prices Entice Australian Households, July 28, 2014 • Macro-Prudential Measures Should Help Absorb The Pressure Of Strong House Prices In Australia, Nov. 26, 2014 • Australia's Developing Crisis-Management Framework For Banks Could Moderate The Government Support Factored Into Ratings, Nov. 12, 2013 • Resolution Plans For Global Banks May Eliminate Government Support For Some, But Progress Is Varied, Dec. 4, 2013 Standard & Poor's (Australia) Pty. Ltd. holds Australian financial services licence number 337565 under the Corporations Act 2001. Standard & Poor's credit ratings and related research are not intended for and must not be distributed to any person in Australia other than a wholesale client (as defined in Chapter 7 of the Corporations Act). Anchor Matrix Economic Risk Industry Risk 1 2 3 4 5 6 7 8 9 10 1 a a a- bbb+ bbb+ bbb - - - - 2 a a- a- bbb+ bbb bbb bbb- - - - 3 a- a- bbb+ bbb+ bbb bbb- bbb- bb+ - - 4 bbb+ bbb+ bbb+ bbb bbb bbb- bb+ bb bb - 5 bbb+ bbb bbb bbb bbb- bbb- bb+ bb bb- b+ 6 bbb bbb bbb- bbb- bbb- bb+ bb bb bb- b+ 7 - bbb- bbb- bb+ bb+ bb bb bb- b+ b+ 8 - - bb+ bb bb bb bb- bb- b+ b 9 - - - bb bb- bb- b+ b+ b+ b 10 - - - - b+ b+ b+ b b b- WWW.STANDARDANDPOORS.COM/RATINGSDIRECT DECEMBER 18, 2014 11 1376165 | 301569575
Commonwealth Bank of Australia Ratings Detail (As Of December 18, 2014) Commonwealth Bank of Australia Counterparty Credit Rating AA-/Stable/A-1+ Certificate Of Deposit A-1+ Commercial Paper A-1+ Junior Subordinated BBB Junior Subordinated BBB+ Junior Subordinated BBB- Preferred Stock BBB- Senior Unsecured ASEAN Regional Scale axAAA Greater China Regional Scale cnAAA Senior Unsecured A-1+ Senior Unsecured AA- Short-Term Debt A-1+ Subordinated A- Subordinated BBB+ Counterparty Credit Ratings History 01-Dec-2011 Foreign Currency AA-/Stable/A-1+ 21-Feb-2007 AA/Stable/A-1+ 07-Nov-2006 AA-/Watch Pos/A-1+ 01-Dec-2011 Local Currency AA-/Stable/A-1+ 21-Feb-2007 AA/Stable/A-1+ 07-Nov-2006 AA-/Watch Pos/A-1+ Sovereign Rating Australia (Commonwealth of) (Unsolicited Ratings) AAA/Stable/A-1+ Related Entities ASB Bank Ltd. Issuer Credit Rating AA-/Stable/A-1+ Certificate Of Deposit Foreign Currency AA-/A-1+ Local Currency AA-/A-1+/A-1+ Commercial Paper Foreign Currency A-1+ Senior Unsecured Greater China Regional Scale cnAAA Senior Unsecured AA- Subordinated A- Subordinated BBB+ ASB Capital Ltd. Preference Stock BBB ASB Capital No.2 Ltd. Preference Stock BBB ASB Finance Ltd. Issuer Credit Rating AA-/Stable/A-1+ WWW.STANDARDANDPOORS.COM/RATINGSDIRECT DECEMBER 18, 2014 12 1376165 | 301569575
Commonwealth Bank of Australia Ratings Detail (As Of December 18, 2014) (cont.) Senior Unsecured AA- Short-Term Debt A-1+ Subordinated A- ASB Finance Ltd. (London Branch) Commercial Paper Foreign Currency A-1+ CBA Capital Australia Ltd. Preference Stock A- CBA Funding NZ Ltd. Issuer Credit Rating AA-/Stable/A-1+ Commercial Paper Foreign Currency A-1+ Colonial Holding Co. Ltd. Issuer Credit Rating A+/Stable/A-1 Senior Unsecured A+ Senior Unsecured A-1 Short-Term Debt A-1 Subordinated BBB+ CommBank Europe Ltd. Issuer Credit Rating AA-/Stable/A-1+ Preferred Capital Ltd. Preferred Stock Convertible BBB- The Colonial Mutual Life Assurance Society Ltd. Financial Strength Rating Local Currency AA-/Stable/-- Issuer Credit Rating Local Currency AA-/Stable/-- The Colonial Mutual Life Assurance Society Ltd. (NZ Branch) Financial Strength Rating Local Currency AA-/Stable/-- *Unless otherwise noted, all ratings in this report are global scale ratings. Standard & Poor's credit ratings on the global scale are comparable across countries. Standard & Poor's credit ratings on a national scale are relative to obligors or obligations within that specific country. WWW.STANDARDANDPOORS.COM/RATINGSDIRECT DECEMBER 18, 2014 13 1376165 | 301569575
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