A recent retroactive German law change has significantly increased Deutsche Bank's additional loss absorbing capacity (ALAC) buffer, thereby protecting more-senior creditors. Earlier this month, Deutsche Bank announced an €8 billion equity increase and certain strategic changes that we see as supportive of its creditworthiness. We are raising the long-term issuer credit rating on Deutsche Bank AG to 'A-' from 'BBB+' on the expectation that it will maintain an ALAC buffer above our 8.5% threshold for a two-notch rating uplift. We are raising to 'A-' from 'BBB+' the issue ratings on instruments that we continue to view as senior unsecured debt under the new law, and lowering to 'BBB-' from 'BBB+' the issue ratings on instruments we have reclassified as senior
