Commonwealth Bank of Australia

Page created by Jimmy Holmes
 
CONTINUE READING
Commonwealth Bank of Australia
Primary Credit Analyst:
Nico N DeLange, Sydney (61) 2-9255-9887; nico.delange@standardandpoors.com

Secondary Contact:
Gavin J Gunning, Melbourne (61) 3-9631-2092; gavin.gunning@standardandpoors.com

Table Of Contents

Major Rating Factors

Rationale

Outlook

Related Criteria And Research

WWW.STANDARDANDPOORS.COM/RATINGSDIRECT                               DECEMBER 18, 2014 1
                                                                             1376165 | 301569575
Commonwealth Bank of Australia
                                                                                      Additional
   SACP                    a          +      Support                +2          +     Factors                  0

   Anchor                  a-                                                               Issuer Credit Rating
   Business                                  GRE Support             0
   Position
                      Strong    +1

   Capital and
   Earnings
                    Adequate     0
                                             Group
                                             Support                 0
   Risk Position    Adequate     0                                                       AA-/Stable/A-1+
   Funding           Average
                                 0           Sovereign
                                             Support                +2
   Liquidity        Adequate

Major Rating Factors
  Strengths:                                                   Weaknesses:

  • Robust business and market position in key retail          • Dependence on wholesale offshore borrowings,
    market segments in Australia and New Zealand                 which could disrupt funding access
  • Low-risk traditional Australian and New Zealand
    retail and commercial banking activities
  • Technology platform a competitive advantage
  • Globally among the strongest banks on key earning
    and asset quality metrics
  • Potential recipient of extraordinary government
    support in the unlikely event it was required

Rationale
Standard & Poor's Ratings Services ratings on Commonwealth Bank of Australia (CBA) are based on a combination of
factors including the anchor stand-alone credit profile (SACP), company-specific factors, and our expectation that the
bank would receive extraordinary government support in a crisis. For CBA, we start with an anchor of 'a-' and then
adjust it for a "strong" business position, which reflects the robust business and market position in key retail market
segments in Australia and New Zealand. We view CBA's capital and earnings position as "adequate" and therefore
neutral to the rating, as measured by Standard & Poor's RAC ratio. We assess CBA's risk position as "adequate" to
reflect its low-risk traditional Australian and New Zealand retail and commercial banking activities. We consider CBA's
funding and liquidity positions as "average" and "adequate," respectively, to reflect the bank's stable and diverse

WWW.STANDARDANDPOORS.COM/RATINGSDIRECT                                                              DECEMBER 18, 2014 2
                                                                                                           1376165 | 301569575
Commonwealth Bank of Australia

funding profile and liquidity buffers that include the Reserve Bank of Australia (RBA) committed liquidity facility (CLF).
We adjust the resulting SACP of 'a' upwards by two notches to arrive at the issuer credit rating (ICR) of 'AA-'. We make
this adjustment to account for our expectation of a high likelihood of extraordinary government support for CBA,
reflecting its high systemic importance in the Australian banking system.

Anchor:
We view Australia as having a diversified, high-income, flexible, and resilient economy--factors that reduce the risk of
significant and sustained downturns. The Australian banking sector benefits from conservative regulation, disciplined
regulatory supervision, and a government that has traditionally been "highly-supportive" toward the banking sector.
Further, the sector is supported by a stable, orderly industry structure characterized by an overall low-risk appetite
with banking activities tending to be centered on vanilla retail and commercial banking activities. Offsetting these
positive features is the Australian banking sector's exposure to risks related to economic imbalances--including high
external debt and persistent current account deficits, and, more recently, material house price appreciation--and is
materially dependent on net external borrowings, as core customer deposits are not sufficient for meeting long-term
funding needs.

The SACP for CBA is 'a'.

Table 1
Commonwealth Bank of Australia Key Figures
                                     --Year-ended June 30--

(Mil. A$)                   2014      2013      2012      2011      2010
Adjusted assets          766,517    729,410   694,369   643,609   621,281
Customer loans (gross)   591,009    552,208   526,845   498,964   494,998
Adjusted common equity     33,958    30,345    27,552    24,752    22,705
Operating revenues         22,500    21,554    20,384    19,397    19,288
Noninterest expenses        9,152     9,340     8,995     8,692     8,396
Core earnings               9,064     7,984     7,395     6,709     5,941

Business position: Robust business and market position in key retail market segments; technology
platform a competitive advantage
As the largest retail bank in Australia, CBA has a strong and stable business franchise compared to domestic peers and
other global banks. Our opinion is based on CBA's dominant domestic retail market share in Australia (in both
residential home loans and retail deposits) and leading customer satisfaction scores, which we believe are supported
by CBA's consistent and focused strategy and its competent management team. We note that CBA's overall leading
customer-satisfaction scores may be challenged as competitors close the gap.

A key factor underpinning business stability is CBA's dominant (25%) domestic market share in residential mortgage
lending and retail deposits, with loan growth in both areas at around system levels. We note that the group also has
substantial wealth-management operations, with its Australian retail funds about 16% of the market and Australian Life
Insurance (total risk and individual risk) about 12.5% of the market. Overall, we are of the view that these retail
business lines contribute to the stability of CBA's revenues and business activities, as they generate recurring net
interest income and fee income.

WWW.STANDARDANDPOORS.COM/RATINGSDIRECT                                                              DECEMBER 18, 2014 3
                                                                                                           1376165 | 301569575
Commonwealth Bank of Australia

That said, compared to industry peers, CBA is more concentrated in terms of geography (82.8% of credit exposures
are in Australia and 9% of credit exposures are in New Zealand).

In our opinion, technology, one of the centerpieces of CBA' strategy, differentiates CBA from its peers and creates a
competitive advantage, as it translates real time banking, improved efficiencies, and improved product and application
development into improved customer satisfaction and benefits. We note that the group's investment in technology is
also driving productivity and process simplification, leading to tangible benefits in the form of operational efficiencies
from productivity initiatives, and positively impacting the expense base.

We view the group's strategy as a customer-focused one that builds upon the group's four key capabilities of people,
technology, strength and productivity to deepen its relationship with its customer base. Outside of the Australasian
borders, CBA's Asian expansion strategy is expected to remain targeted on acquisitions and ventures that are value
additive for shareholders.

In our view, CBA has an experienced and competent executive team in place.

Table 2
Commonwealth Bank of Australia Business Position
                                                                          --Year-ended June 30--

(%)                                                              2014     2013      2012      2011        2010
Total revenues from business line (mil. A$)                     22,500   21,554    20,384    19,397      19,288
Commercial & retail banking/total revenues from business line     83.4     82.3      79.9      82.7        79.5
Insurance activities/total revenues from business line             4.6      5.7       6.0          5.8      6.4
Asset management/total revenues from business line                 9.0     10.0       9.5      10.5        10.0
Return on equity                                                  18.8     18.2      18.6      18.2        17.5

Capital and earnings: a neutral ratings factor
Our view of CBA's capital and earnings takes into account the bank's stable level of capitalization, the high quality of
its capital, as well as its strong and stable operating performance relative to peers.

We've revised our economic risk assessment for the banking system in Australia upward, leading to a decrease in the
static risk-adjusted capital (RAC) ratio of about 8 basis points. The upward revision reflects our views around CBA's
gradual build-up in house prices, in particular in Sydney and Melbourne over the past seven years and the impact on
economic imbalances. As result of the buildup, we consider economic risk (one of the key drivers in our RAC ratio) to
be higher in the Australian banking system; therefore the increase in risk weighted assets.

On a forward-looking basis we project that CBA's pre-diversification RAC ratio would stabilize in the 8.2%-8.7% range
over the next 12-18 months. Our forward-looking assessment is based on assumptions. The key assumptions
underpinning our analysis are the following:

•   Loan growth to remain at around system levels;
•   Some margin pressures to remain--primarily as a result of competitive pressures;
•   Credit loss provisions to remain flat over the forecasting period; and
•   A dividend payout ratio of around 75%.

WWW.STANDARDANDPOORS.COM/RATINGSDIRECT                                                                     DECEMBER 18, 2014 4
                                                                                                                  1376165 | 301569575
Commonwealth Bank of Australia

Our assumptions do not take into account the higher capital requirement recommendations of the Financial System
Inquiry (FSI), as the government still needs to consult with stakeholders on the final report before making decisions on
the recommendations; a formal government response would only be released by mid-2015. We are of the view that
because CBA (an internal-ratings based (IRB) accredited bank) has a higher percentage of residential mortgage loans
relative to peers, the proposal to increase the average residential mortgage risk weights to a range of between 25% and
30% will have a greater impact on CBA if CBA were to restore its capital position to current levels. We note that CBA's
Common Equity Tier 1 (CET1) ratio would be close to its threshold levels, including the capital conservation buffer
(CCB) and domestically systemic important bank (D-SIB) buffer if the recommendations were implemented. We are of
the view that the increase in the capital levels would have a solidifying effect on CBA's neutral capital setting, or it
could even have an improving effect--dependent on final rules and individual bank capital-management philosophies.

From a prudential capital adequacy perspective, CBA's CET1 ratio of 9.3% is well above the Australian Prudential
Regulation Authority (APRA) minimum requirements of a CET1 minimum of 4.5% effective Jan. 1, 2013, and the CET1
plus CCB and D-SIB buffer minimum of 8%, effective Jan. 1, 2016.

In our view, CBA's capital base is of good quality, with hybrid capital playing a supplementary role rather than a
primary role in its capital strategy. CBA's ratio of adjusted common equity to total adjusted capital was 87%. We
project that this ratio would decrease to about 84% over our forecasting period, with the bank's reliance on hybrid
capital instruments, as Basel II instruments are replaced with Basel III instruments.

We are of the view that the group's profitability track record over the past five years (during the GFC and
commensurate economic slowdown and commercial property downturn) had also been very good by international
standards. This is reflected in the group's core earnings-to-adjusted assets ratio of 1.18%, which was better than the
majority of the Australian peers and international peers.

Table 3
Commonwealth Bank of Australia Capital And Earnings
                                                          --Year-ended June 30--

(%)                                             2014      2013      2012       2011        2010
Tier 1 capital ratio                            11.1        10.2     10.0          10.0      9.2
Adjusted common equity/total adjusted capital   88.4        86.5     86.0          84.8     77.3
Net interest income/operating revenues          67.1        64.6     64.4          64.9     61.8
Fee income/operating revenues                   23.3        24.2     24.2          25.6     27.8
Market-sensitive income/operating revenues       3.8         4.0      3.8           2.3      2.5
Noninterest expenses/operating revenues         40.7        43.3     44.1          44.8     43.5
Preprovision operating income/average assets     1.7         1.7      1.6           1.6      1.7
Core earnings/average managed assets             1.2         1.1      1.1           1.0      0.9

Risk position: low-risk traditional Australian and New Zealand retail and commercial banking
activities
We are of the view that CBA's asset quality track record is evidence of the bank's rigorous and conservative
underwriting policies employed. While CBA's GFC-related losses were lower compared with many highly-rated
international banks, we note that the economic and commercial property downturns in Australia and New Zealand and

WWW.STANDARDANDPOORS.COM/RATINGSDIRECT                                                                DECEMBER 18, 2014 5
                                                                                                             1376165 | 301569575
Commonwealth Bank of Australia

the impact on the banking system were less severe than that experienced in the U.S. and Europe.

Compared to peer banks, CBA's net charge-offs as a percentage of normalized losses compare favorably by
international standards, with actual losses less than normalized losses.

We note that CBA's growth in residential mortgage loans and non-financial corporations loans were at around system
level over the last year. Over the medium term the group is not targeting the move into new product, consumer, or
market activities in a material way outside its traditional areas of expertise.

In our view the risk characteristics of CBA's exposures are adequately captured by our RAC ratio, with the focus of the
bank on core retail and commercial banking activities. We note that regulatory capital requirements for interest rate
risk in the banking book amounted to about 4.4% of CBA's total risk-weighted assets at June 30, 2014.

Concerning CBA's financial planning business, we are of the view that the Open Advice Review program of review and
remediation to deliver fair and consistent outcomes to customers affected by the poor advice provided by advisers of
the bank's Commonwealth Financial Planning and Financial Wisdom currently do not have a bearing on our
assessment of CBA's risk position.

We believe that the group's Annual Report and Pillar 3 disclosures are transparent, and allow good visibility into CBA's
underlying risk exposures and earnings generation. From a complexity point of view, retail products dominate CBA's
balance sheet; the group also does not have excessive exposures to derivatives, securitizations, and structured credits.

We view CBA's risk-appetite framework as conservative. The risk appetite framework spans the whole group and its
divisions. A silo approach to risk management is not undertaken; on the contrary risk management is embedded at a
business unit level, with additional group-wide oversight and aggregation. Risk appetite is dynamic in nature, and is
reviewed on a regular basis in conjunction with CBA's strategic plans and business actions.

Table 4
 Commonwealth Bank of Australia Risk Position
                                                                              --Year-ended June 30--

 (%)                                                                   2014   2013     2012       2011    2010
 Growth in customer loans                                               7.0     4.8      5.6        0.8     5.5
 Total managed assets/adjusted common equity (x)                       23.3    24.8     26.1       27.0    28.5
 New loan loss provisions/average customer loans                        0.2     0.2      0.2        0.3     0.5
 Net charge-offs/average customer loans                                 0.3     0.3      0.3        0.4     0.4
 Gross nonperforming assets/customer loans + other real estate owned    1.0     1.2      1.4        1.8     1.7
 Loan loss reserves/gross nonperforming assets                         67.6    66.9     64.6       56.8    63.4

Funding and liquidity: dependence on wholesale offshore borrowings
In our view CBA and the other Australian major banks are materially reliant on wholesale funding--this being a
fundamentally negative rating factor. However, much of this risk has been taken into account by us in our system-wide
funding score of "intermediate" that forms part of our Australian BICRA assessment.

We are of the opinion that CBA's funding profile metrics are around the average of domestic peers', solidifying the
"average" funding assessment. Our funding metrics include CBA's loan-to-deposit ratio (134%), long-term funding ratio

WWW.STANDARDANDPOORS.COM/RATINGSDIRECT                                                                    DECEMBER 18, 2014 6
                                                                                                                  1376165 | 301569575
Commonwealth Bank of Australia

(81%), and short-term wholesale funding to total funding base (20%). We note that the trends in these ratios had been
improving during recent years. We expect CBA will continue to improve the management of its funding profile by
reducing reliance on short-term funding and extending its maturity profile on long-term funding in line with the trend
seen since 2008.

Of CBA's total funding, 64% relates to the customer sector. Compared to the other large Australian banks, CBA has the
highest proportion of household deposits, at 29%.

From a quantitative-liquidity-ratio perspective, CBA and the other Australian major banks have weaker liquidity ratios.
This is largely due to the shortage of liquid assets in the banking system as a result of low overall government debt
levels. Consequently the low government debt levels and low levels of liquid assets in the system also result in the
Australian major banks falling short of the liquidity-coverage-ratio requirements of Basel III, primarily due to a
shortage of qualifying liquid assets. To this end we wish to note that:

• The Reserve Bank of Australia (RBA) has stepped in to make available a committed liquidity facility (CLF) for banks
  in order to meet the liquidity-coverage-ratio requirements; importantly securities to be used under the CLF would
  also include self-securitised mortgages in addition to the securities eligible for the RBA's normal market operations.
• The CLF would function in the same way in stressed market conditions as high-quality-liquid-asset do.
• Banks have entered into consultation with APRA to determine their size of the CLF available to them.

We regard CBA's liquidity as well managed. For fiscal 2014, total liquid assets increased to A$139 billion from A$135
billion in June 2012. Specific stress tests are conducted routinely for liquidity-risk-management purposes. The stress
tests look to identify the timeframe over which high-quality liquid assets could survive under various stress liability
run-off scenarios.

Capital markets are accessed through a wide variety of programs, including covered bonds as well as senior unsecured
short- and long-term programs.

Table 5
Commonwealth Bank of Australia Funding And Liquidity
                                                               --Year-ended June 30--

(%)                                                    2014    2013       2012          2011     2010
Core deposits/funding base                              64.2    63.6       62.6         61.9     58.6
Customer loans (net)/customer deposits                 133.6   134.7      137.2     141.1       151.2
Long term funding ratio                                 81.3    80.8       80.8         78.5     78.8
Stable funding ratio                                    92.0    91.3       90.9         86.9     87.4
Short-term wholesale funding/funding base               19.9    20.3       20.3         22.6     22.5
Broad liquid assets/short-term wholesale funding (x)     0.8     0.7        0.7          0.6      0.6
Short-term wholesale funding/total wholesale funding    54.5    54.8       53.2         58.2     52.7

Support:
Our issuer credit rating on CBA is two notches higher than the SACP, reflecting our view of a high likelihood of
extraordinary government support in a crisis. This reflects our view of CBA's high systemic importance in Australia,
and our assessment of the Australian government as highly supportive of institutions core to the national economy.

WWW.STANDARDANDPOORS.COM/RATINGSDIRECT                                                                  DECEMBER 18, 2014 7
                                                                                                             1376165 | 301569575
Commonwealth Bank of Australia

We remain of the view that ratings of systemically-important banks (such as CBA) would likely be negatively impacted
if the government eventually was to adopt a different approach to bank resolutions, whereby we believed there could
be a greater appetite for bail-in of senior bank creditors.

Additional rating factors
The issue ratings on CBA's non-Basell III non-deferrable subordinated debt are 'A-', or one notch below CBA's SACP.
The issue ratings on CBA's Basel III non-deferrable subordinated debt are 'BBB+', or two notches below CBA's SACP.
This is because we believe that Australia's legal and regulatory framework could allow authorities to instigate
restructuring of a failing bank to the detriment of non-deferrable subordinated debt and for the Basel III instruments
we apply a one-notch additional deduction to reflect the contingency clause that requires the mandatory conversion
into common equity on the activation of a non-viability trigger. The issue ratings on ASB Bank Ltd.'s (ASB) Basel III
non-deferrable subordinated debt reflect our view that ASB is a core subsidiary of CBA. We note that the
short-to-medium term prospects for CBA experiencing financial stress to the extent it requires a restructuring to the
detriment of non-deferrable subordinated debt holders is low.

The issue ratings on CBA's non-Basel III hybrid capital instruments are three notches below the SACP. The issue rating
on CBA's Basel III complaint hybrid capital instruments (PERLS VI and PERLS VII) are four notches below the SACP.
We apply a one-notch additional deduction to reflect the contingency clause that requires the mandatory conversion
into common equity on the activation of a non-viability trigger.

Table 6
 Commonwealth Bank of Australia Risk-Adjusted Capital
                                                              Basel II Average Basel II     Standard & Average Standard &
 (Mil. A$)                                   Exposure*          RWA            RW (%)       Poor's RWA      Poor's RW (%)

 Credit risk
 Government and central banks                    64,263         5,774                9            2,665                   4
 Institutions                                    43,401        10,959               25           10,067                  23
 Corporate                                      198,525       140,548               71          161,503                  81
 Retail                                         532,910       115,422               22          181,605                  34
   Of which mortgage                            470,384        75,985               16          142,299                  30
 Securitization§                                  9,812         5,010               51            7,312                  75
 Other assets                                    10,165         4,214               41           11,736                 115
   Total credit risk                            859,075       281,927               33          374,888                  44

 Market risk
 Equity in the banking book†                      2,576             0                0           22,789                 885
 Trading book market risk                             --        5,284                --           7,926                   --
   Total market risk                                  --        5,284                --          30,715                   --

 Insurance risk
   Total insurance risk                               --            --               --          33,413                   --

 Operational risk
   Total operational risk                             --       28,531                --          45,838                   --

WWW.STANDARDANDPOORS.COM/RATINGSDIRECT                                                                DECEMBER 18, 2014 8
                                                                                                           1376165 | 301569575
Commonwealth Bank of Australia

Table 6
Commonwealth Bank of Australia Risk-Adjusted Capital (cont.)
                                                                        Basel II                             Standard &           % of Standard &
(Mil. A$)                                                                 RWA                                Poor's RWA               Poor's RWA

Diversification adjustments
RWA before diversification                                              337,716                                    484,853                      100
Total Diversification/Concentration                                            --                                 (72,094)                      (15)
Adjustments
RWA after diversification                                               337,716                                    412,759                       85

                                                                          Tier 1                          Total adjusted       Standard & Poor's
(Mil. A$)                                                                capital    Tier 1 ratio (%)              capital          RAC ratio (%)

Capital ratio
Capital ratio before adjustments                                          37,608                 11.1               38,406                      7.9
Capital ratio after adjustments¶                                          37,608                 11.1               38,406                      9.3

*Exposure at default. §Securitisation Exposure includes the securitisation tranches deducted from capital in the regulatory framework.
¶Adjustments to Tier 1 ratio are additional regulatory requirements (e.g. transitional floor or Pillar 2 add-ons). RWA--Risk-weighted assets.
RW--Risk weight. RAC--Risk-adjusted capital. Sources: Company data as of June. 30, 2014, Standard & Poor's.

WWW.STANDARDANDPOORS.COM/RATINGSDIRECT                                                                                    DECEMBER 18, 2014 9
                                                                                                                                  1376165 | 301569575
Commonwealth Bank of Australia

 Outlook: Stable

 The stable outlook reflects our opinion that our ratings on CBA are likely to remain unchanged in the
 short-to-medium term. We expect that in maintaining the stable outlook that CBA would:
 • Uphold its leading retail banking position in Australia and New Zealand;
 • Sustain its RAC ratio in the "adequate" range over the next 12-18 months;
 • Preserve its "adequate" risk position by ensuring its conservative risk-appetite framework is embedded in the
   group across all divisions; and
 • Sustain its funding profile relative to the other Australian banks and banks with a similar industry risk score.

 As a "highly systemically-important" bank domiciled in a country that we view as "highly supportive" of institutions
 that are core to the national economy, CBA's 'AA-' ratings are not likely to change as long as:
 • The Australian government's willingness to provide extraordinary support remains "highly supportive". We note
   that the development and implementation of a more comprehensive resolution regime in Australia, particularly
   if it infers wide bail-in powers for the regulator, could potentially weaken our assessment of a government's
   tendency to support private-sector banks.
 • The 'AAA' long term local currency issuer credit rating the Commonwealth of Australia is not lowered to 'AA+'.
   In such a scenario the issuer credit rating on CBA would be lowered to 'A+' from 'AA-'.

 CBA's long-term issuer credit rating could also be lowered if its SACP deviate outside the 'a-' to 'a+' range (that is,
 by more than two notches). A scenario that may lead to a two notch adjustment in the SACP may be a revision of
 the economic risk score is revised to '4' from '3' resulting in a change in the anchor rating to 'bbb+' and a revision
 in the capital and earnings assessment to 'moderate' form 'adequate' due to the increase in risk weighted assets; in
 our view, the occurrence of such an event is remote. A one notch deterioration of CBA's SACP to 'a-' from 'a'
 would not cause a negative revision to the issuer credit ratings.
 Factors that might have a negative bearing on the SACP are the following:
 • A change in the anchor SACP to 'bbb+' from 'a-' as a result of a downward revision of both the industry risk and
   economic risk scores on Australia to '3'. In this regard we note that economic risk score of Australia was
   assigned a negative trend.
 • A reduction in CBA's RAC ratio to below 7% that would lead to a revision of the capital and earnings score to
   "moderate" from "adequate." We are of the opinion that a negative revision of our economic risk score for
   Australia to '4' from '3' would be unlikely to cause us to negatively revise CBA's capital and earnings position, as
   it is unlikely that CBA's RAC ratio would dip below the "adequate" range over the next 12-18 months despite
   the score change.
 • The emergence of risks outside the tolerances within the current SACP and our capital and earning assessment,
   such as a material deterioration in asset quality or earnings that would cause us concern if measured against
   domestic and international standards.
 • The unlikely event that CBA experienced funding or liquidity stress, causing its funding assessment to fall below
   the average for peer banks in Australia and banks with a similar industry risk score. In a significant liquidity
   stress event, we expect that the bank will qualify for central bank and other government-support mechanisms.

 We do not expect that we will raise CBA's issuer credit rating in the short to medium term. A SACP factor that
 may have a positive bearing on CBA's rating is the banks actual losses compared to normalized losses in terms of
 our risk adjusted capital framework. In combination with the adjustment of the economic risk score to '3' we are of
 the view that the potential may exists that there may be positive momentum at SACP level for CBA's risk position
 assessment if asset quality trends continue to improve going forward. We also believe that if CBA achieved and

WWW.STANDARDANDPOORS.COM/RATINGSDIRECT                                                            DECEMBER 18, 2014 10
                                                                                                           1376165 | 301569575
Commonwealth Bank of Australia

    sustained a RAC ratio in excess of 10% this would likely be supportive of a positive reassessment of the bank's
    SACP.

Related Criteria And Research
Related Criteria
•    Group Rating Methodology, May 7, 2013
•    Banks: Rating Methodology And Assumptions, Nov. 9, 2011
•    Banking Industry Country Risk Assessment Methodology And Assumptions, Nov. 9, 2011
•    Bank Capital Methodology And Assumptions, Dec. 6, 2010
•    Revised Market Risk Charges For Banks In Our Risk-Adjusted Capital Framework, June 22, 2012
•    Bank Hybrid Capital Methodology And Assumptions, Nov. 1, 2011

Related Research
• No Immediate Impact On Australian Financial Institutions Ratings Following The Australian Financial System
  Inquiry, Dec. 8, 2014
• The Top 100 Rated Banks: Will 2014 Mark A Turning Point In Capital Cushioning? Oct. 6, 2014
• Australian Bank Ratings Holding Up As Cheap Money And Rising Residential Property Prices Entice Australian
  Households, July 28, 2014
• Macro-Prudential Measures Should Help Absorb The Pressure Of Strong House Prices In Australia, Nov. 26, 2014
• Australia's Developing Crisis-Management Framework For Banks Could Moderate The Government Support
  Factored Into Ratings, Nov. 12, 2013
• Resolution Plans For Global Banks May Eliminate Government Support For Some, But Progress Is Varied, Dec. 4,
  2013

     Standard & Poor's (Australia) Pty. Ltd. holds Australian financial services licence number 337565 under the Corporations Act 2001. Standard &
     Poor's credit ratings and related research are not intended for and must not be distributed to any person in Australia other than a wholesale
     client (as defined in Chapter 7 of the Corporations Act).

     Anchor Matrix

                                                         Economic Risk
    Industry
      Risk          1         2         3         4          5         6         7         8         9        10

        1           a         a         a-      bbb+      bbb+       bbb         -         -         -         -
        2           a         a-        a-      bbb+       bbb       bbb       bbb-        -         -         -
        3           a-        a-      bbb+      bbb+       bbb       bbb-      bbb-      bb+         -         -
        4         bbb+      bbb+      bbb+       bbb       bbb       bbb-      bb+        bb        bb         -
        5         bbb+       bbb       bbb       bbb       bbb-      bbb-      bb+        bb        bb-       b+
        6          bbb       bbb       bbb-      bbb-      bbb-      bb+        bb        bb        bb-       b+
        7            -       bbb-      bbb-      bb+       bb+        bb        bb        bb-       b+        b+
        8            -         -       bb+        bb        bb        bb        bb-       bb-       b+         b
        9            -         -         -        bb        bb-       bb-       b+        b+        b+         b
       10            -         -         -         -        b+        b+        b+         b         b        b-

WWW.STANDARDANDPOORS.COM/RATINGSDIRECT                                                                                  DECEMBER 18, 2014 11
                                                                                                                                  1376165 | 301569575
Commonwealth Bank of Australia

Ratings Detail (As Of December 18, 2014)
Commonwealth Bank of Australia
Counterparty Credit Rating                          AA-/Stable/A-1+
Certificate Of Deposit                              A-1+
Commercial Paper                                    A-1+
Junior Subordinated                                 BBB
Junior Subordinated                                 BBB+
Junior Subordinated                                 BBB-
Preferred Stock                                     BBB-
Senior Unsecured
 ASEAN Regional Scale                               axAAA
 Greater China Regional Scale                       cnAAA
Senior Unsecured                                    A-1+
Senior Unsecured                                    AA-
Short-Term Debt                                     A-1+
Subordinated                                        A-
Subordinated                                        BBB+
Counterparty Credit Ratings History
01-Dec-2011            Foreign Currency             AA-/Stable/A-1+
21-Feb-2007                                         AA/Stable/A-1+
07-Nov-2006                                         AA-/Watch Pos/A-1+
01-Dec-2011            Local Currency               AA-/Stable/A-1+
21-Feb-2007                                         AA/Stable/A-1+
07-Nov-2006                                         AA-/Watch Pos/A-1+
Sovereign Rating
Australia (Commonwealth of) (Unsolicited Ratings)   AAA/Stable/A-1+
Related Entities
ASB Bank Ltd.
Issuer Credit Rating                                AA-/Stable/A-1+
Certificate Of Deposit
 Foreign Currency                                   AA-/A-1+
 Local Currency                                     AA-/A-1+/A-1+
Commercial Paper
 Foreign Currency                                   A-1+
Senior Unsecured
 Greater China Regional Scale                       cnAAA
Senior Unsecured                                    AA-
Subordinated                                        A-
Subordinated                                        BBB+
ASB Capital Ltd.
Preference Stock                                    BBB
ASB Capital No.2 Ltd.
Preference Stock                                    BBB
ASB Finance Ltd.
Issuer Credit Rating                                AA-/Stable/A-1+

WWW.STANDARDANDPOORS.COM/RATINGSDIRECT                                DECEMBER 18, 2014 12
                                                                            1376165 | 301569575
Commonwealth Bank of Australia

Ratings Detail (As Of December 18, 2014) (cont.)
Senior Unsecured                                                                                AA-
Short-Term Debt                                                                                 A-1+
Subordinated                                                                                    A-
ASB Finance Ltd. (London Branch)
Commercial Paper
 Foreign Currency                                                                               A-1+
CBA Capital Australia Ltd.
Preference Stock                                                                                A-
CBA Funding NZ Ltd.
Issuer Credit Rating                                                                            AA-/Stable/A-1+
Commercial Paper
 Foreign Currency                                                                               A-1+
Colonial Holding Co. Ltd.
Issuer Credit Rating                                                                            A+/Stable/A-1
Senior Unsecured                                                                                A+
Senior Unsecured                                                                                A-1
Short-Term Debt                                                                                 A-1
Subordinated                                                                                    BBB+
CommBank Europe Ltd.
Issuer Credit Rating                                                                            AA-/Stable/A-1+
Preferred Capital Ltd.
Preferred Stock Convertible                                                                     BBB-
The Colonial Mutual Life Assurance Society Ltd.
Financial Strength Rating
 Local Currency                                                                                 AA-/Stable/--
Issuer Credit Rating
 Local Currency                                                                                 AA-/Stable/--
The Colonial Mutual Life Assurance Society Ltd. (NZ Branch)
Financial Strength Rating
 Local Currency                                                                                 AA-/Stable/--
 *Unless otherwise noted, all ratings in this report are global scale ratings. Standard & Poor's credit ratings on the global scale are comparable
across countries. Standard & Poor's credit ratings on a national scale are relative to obligors or obligations within that specific country.

WWW.STANDARDANDPOORS.COM/RATINGSDIRECT                                                                                    DECEMBER 18, 2014 13
                                                                                                                                    1376165 | 301569575
Copyright © 2014 Standard & Poor's Financial Services LLC, a part of McGraw Hill Financial. All rights reserved.

No content (including ratings, credit-related analyses and data, valuations, model, software or other application or output therefrom) or any part
thereof (Content) may be modified, reverse engineered, reproduced or distributed in any form by any means, or stored in a database or retrieval
system, without the prior written permission of Standard & Poor's Financial Services LLC or its affiliates (collectively, S&P). The Content shall not be
used for any unlawful or unauthorized purposes. S&P and any third-party providers, as well as their directors, officers, shareholders, employees or
agents (collectively S&P Parties) do not guarantee the accuracy, completeness, timeliness or availability of the Content. S&P Parties are not
responsible for any errors or omissions (negligent or otherwise), regardless of the cause, for the results obtained from the use of the Content, or for
the security or maintenance of any data input by the user. The Content is provided on an "as is" basis. S&P PARTIES DISCLAIM ANY AND ALL
EXPRESS OR IMPLIED WARRANTIES, INCLUDING, BUT NOT LIMITED TO, ANY WARRANTIES OF MERCHANTABILITY OR FITNESS FOR
A PARTICULAR PURPOSE OR USE, FREEDOM FROM BUGS, SOFTWARE ERRORS OR DEFECTS, THAT THE CONTENT'S FUNCTIONING
WILL BE UNINTERRUPTED, OR THAT THE CONTENT WILL OPERATE WITH ANY SOFTWARE OR HARDWARE CONFIGURATION. In no
event shall S&P Parties be liable to any party for any direct, indirect, incidental, exemplary, compensatory, punitive, special or consequential
damages, costs, expenses, legal fees, or losses (including, without limitation, lost income or lost profits and opportunity costs or losses caused by
negligence) in connection with any use of the Content even if advised of the possibility of such damages.

Credit-related and other analyses, including ratings, and statements in the Content are statements of opinion as of the date they are expressed and
not statements of fact. S&P's opinions, analyses, and rating acknowledgment decisions (described below) are not recommendations to purchase,
hold, or sell any securities or to make any investment decisions, and do not address the suitability of any security. S&P assumes no obligation to
update the Content following publication in any form or format. The Content should not be relied on and is not a substitute for the skill, judgment
and experience of the user, its management, employees, advisors and/or clients when making investment and other business decisions. S&P does
not act as a fiduciary or an investment advisor except where registered as such. While S&P has obtained information from sources it believes to be
reliable, S&P does not perform an audit and undertakes no duty of due diligence or independent verification of any information it receives.

To the extent that regulatory authorities allow a rating agency to acknowledge in one jurisdiction a rating issued in another jurisdiction for certain
regulatory purposes, S&P reserves the right to assign, withdraw, or suspend such acknowledgement at any time and in its sole discretion. S&P
Parties disclaim any duty whatsoever arising out of the assignment, withdrawal, or suspension of an acknowledgment as well as any liability for any
damage alleged to have been suffered on account thereof.

S&P keeps certain activities of its business units separate from each other in order to preserve the independence and objectivity of their respective
activities. As a result, certain business units of S&P may have information that is not available to other S&P business units. S&P has established
policies and procedures to maintain the confidentiality of certain nonpublic information received in connection with each analytical process.

S&P may receive compensation for its ratings and certain analyses, normally from issuers or underwriters of securities or from obligors. S&P
reserves the right to disseminate its opinions and analyses. S&P's public ratings and analyses are made available on its Web sites,
www.standardandpoors.com (free of charge), and www.ratingsdirect.com and www.globalcreditportal.com (subscription) and www.spcapitaliq.com
(subscription) and may be distributed through other means, including via S&P publications and third-party redistributors. Additional information
about our ratings fees is available at www.standardandpoors.com/usratingsfees.

WWW.STANDARDANDPOORS.COM/RATINGSDIRECT                                                                                    DECEMBER 18, 2014 14
                                                                                                                                    1376165 | 301569575
You can also read