In our view, Commerzbank is highly committed to executing its advanced "Momentum" strategy, but is ambitiously targeting a much higher ROTE of 15% and a CIR of 50% by 2028. If it achieves this and its risk profile remains unchanged, this could close the gap with higher-rated peers at the 'a-' SACP level, in our view. Commerzbank plans to increase its risk-adjusted profitability via profitable business growth; further improving its fee-based business, likely supported by further bolt-on acquisitions; establishing a lean bank with strict cost reductions; and heightening capital efficiencies (see "Commerzbank Outlines Ambitious Financial Targets To Ward Off UniCredit," published Feb. 13, 2025). Our current base-case forecast is for improvements to underlying risk-adjusted profitability in the next two years,