Good market position and brand recognition as Puerto Rico's second-largest bank. High regulatory risk related to consent order. High geographic concentration in troubled markets. Heavy reliance on wholesale funding and brokered deposits. Weak core profitability. Inadequate risk-adjusted capital levels. Standard&Poor's Ratings Services' ratings on FirstBank Puerto Rico (FirstBank) primarily reflect our assessment of the bank's high regulatory risk, mainly attributable to the consent order with various regulators, and its inability, at this point, to raise the common equity that the Treasury requires for Troubled Asset Relief Program (TARP)-related preferred stock conversion. Despite FirstBank's efforts to make its loan portfolio less risky through writing-down and selling nonperforming loan pools, we believe that embedded losses are still substantial and will
