FRANKFURT (Standard&Poor's) Dec. 17, 2008--Standard&Poor's Ratings Services commented on the decision by Deutsche Bank AG (AA-/Negative/A-1+) not to exercise its call option on €1 billion of subordinated (lower Tier 2) notes maturing in January 2014 despite an interest-rate step-up. Deutsche Bank's decision demonstrates that issuers have the option to redeem callable regulatory capital instruments, but that there is no obligation to do so. The rating on this instrument is 'A+'. Standard&Poor's does not include this lower Tier 2 dated subordinated debt instrument in its measures of bank capital, although it does add to regulatory capital measures which Standard&Poor's also monitors. Generally speaking, one of the features of equity is permanence, and equity-like