OVERVIEW In light of our evolving understanding of bank resolution regulations, we are reviewing our ratings on most of the long-term senior unsecured debt issued by 13 German banks and our long-term issuer credit ratings on four of these banks. We intend to separate our current class of ratings on senior unsecured debt into two layers and, depending on each instrument's specific characteristics, we will either reclassify them as senior subordinated, reflecting their new status as hybrid capital, or retain the senior unsecured classification. We would likely lower our ratings on senior subordinated debt issues by one or two notches, reflecting the likelihood that they would absorb losses and be subordinated to senior unsecured debt in the event of a
