Standard&Poor's bases its ratings on UBI on its 'bbb+' anchor, its "strong" business position, "moderate" capital and earnings, "strong" risk position, "average" funding, and "adequate" liquidity, as our criteria define these terms. We assess UBI's SACP at 'a-'. Our bank criteria use our Banking Industry Country Risk Assessment (BICRA) economic risk and industry risk scores to determine a bank's anchor, the starting point in assigning an issuer credit rating. The 'bbb+' anchor draws on our view of the economic and industry risk in Italy where UBI mostly operates. We view Italy as a diversified and competitive economy with moderate credit risk. But Italy's public debt is very high. The imbalances in domestic asset prices and the buildup of