Standard&Poor's Ratings Services' ratings on FirstBank Puerto Rico (FirstBank) primarily reflect our assessment of the bank's high regulatory risk, mainly attributable to the consent order with various regulators, and its inability, at this point, to raise the common equity that the Treasury requires for Troubled Asset Relief Program (TARP)-related preferred stock conversion. Despite FirstBank's efforts to make its loan portfolio less risky through writing-down and selling nonperforming loan pools, we believe that embedded losses are still substantial and will erode recently boosted capital levels. However, we see FirstBank's good market position and brand recognition in Puerto Rico as strengths. In June 2010, FirstBank agreed to a consent order with the Federal Deposit Insurance Corp. (FDIC) and the Commissioner
