We have reappraised the default risks of certain European bank capital instruments. For the banks that issued capital instruments with 7% or 8% common equity Tier 1 (CET1) principal conversion or write-down triggers, we no longer consider these going concern triggers. Most of these high trigger instruments qualify as additional Tier 1 (AT1) capital and retain intermediate equity content in our risk-adjusted capital (RAC) analysis. Where these high trigger instruments have no discretionary coupons, they now have no equity content in our RAC analysis. For banks issuing capital instruments from nonoperating holding companies (NOHCs) that regulators designate as resolution entities, we no longer see them as facing meaningfully higher default risks than equivalent instruments issued by operating holding companies. As
