The ratings on Bank of Montreal (BMO) reflect its position as one of the five dominant universal banks in Canada, its well-diversified business base, solid credit risk management infrastructure, strong risk-adjusted capital ratios, and good toehold into the U.S. market. The ratings are constrained by the weak stature of its market risk management and the ongoing erosion of market share in its retail business in Canada as well as the difficulties experienced in BMO's U.S. P&C bank. We consider enterprise risk management at BMO to be adequate. The bank has a strong credit risk management framework in addition to a robust liquidity risk management process. BMO's commodity losses, however, have revealed that while the formal structure of the bank's risk