The ratings on Commerzbank AG reflect its sound credit-risk management, which compares favorably with many domestic peers, and the bank's domestic franchise among private and corporate customers, which provides it with a sound and diversified funding base. The ratings also reflect Commerzbank's progress in executing a range of strategic and cost-cutting initiatives, which are expected to allow it to gradually further improve its profitability levels in a less severe operating environment. As Standard&Poor's does not expect a quick recovery, however, it remains concerned that Commerzbank's initiatives will not yet be sufficient to raise and sustain earnings to a level that is in line with similarly rated peers in the 'A' rating category considering the weak, albeit improving, economic