The ratings on the various operating entities of Switzerland-based insurance group Zurich Financial Services (ZFS), including the members of the Zurich U.S. Intercompany Pool, reflect Standard&Poor's Ratings Services' view of ZFS' very strong competitive position, strong and credible management and corporate strategy, and strong enterprise risk-management (ERM) program. Furthermore, the ratings on ZFS continue to reflect the group's very strong underlying operating performance. Partly counterbalancing these strengths are the weakening of ZFS' risk-based capital adequacy and ZFS' significant exposure to volatile industrial and commercial lines business. ZFS' competitive position is very strong, in our view. ZFS is a premier provider of non-life insurance and has market-shaping positions in its three key markets, the U.S., the U.K., and Continental