Following a review under Standard&Poor's revised bank criteria (published on Nov. 9, 2011), we have lowered our long- and short-term counterparty credit ratings on NIBC Bank N.V. to 'BBB-/A-3' from 'BBB/A-2'. The outlook is stable. Our ratings on NIBC reflect its weak business position, adequate capital and earnings, adequate risk position, below average funding, and adequate liquidity. The long-term counterparty rating is in line with the stand-alone credit profile (SACP), based on our assessment of the bank's low systemic importance in The Netherlands. The issue ratings on NIBC's nondeferrable subordinated debt were lowered to 'BB+' from 'BBB-'. The issue ratings on junior subordinated debt were affirmed at 'BB'. The stable outlook reflects our expectation that the bank should