OREANDA-NEWS. July 13, 2015 Fitch Ratings has today affirmed the Long-Term Foreign-Currency Issuer Default Ratings (IDRs) of China's five large state-owned commercial banks at 'A' with Stable Outlooks. The Short-Term IDRs were affirmed at 'F1'. At the same time, the Viability Rating (VR) of Agricultural Bank of China was upgraded to 'bb' from 'bb-'. All other ratings of the five large state banks were affirmed. A full list of the rating actions is at the end of this commentary.

The five banks are: Agricultural Bank of China Limited (ABC), Bank of China Ltd. (BOC), Bank of Communications Co., Ltd. (BOCOM), China Construction Bank Corporation (CCB) and Industrial and Commercial Bank of China (ICBC).

KEY RATING DRIVERS

IDRS, SUPPORT RATINGS, SUPPORT RATING FLOORS
All of the Long-Term IDRs are based on state support, and are at the banks' Support Rating Floors, reflecting an extremely high probability of extraordinary support from the central government in the event of stress.

The state-owned commercial banks' Support Ratings (SR) of '1' and Support Rating Floors (SRF) of 'A' reflect their systemic importance and thus an extremely high propensity for the state to support them, if required. Combined, the banks account for 41% of sector assets domestically and are viewed as pivotal to the financing of China's economy. All state banks are expected to be designated as domestic systemically important financial institutions (SIFIs), while three of them (ABC, BOC and ICBC) are already designated as global SIFIs.

Financial reform announcements over the past year have been encouraging, but it remains to be seen if the authorities' commitment to reform holds firm while responding to challenges from a slower economy. Reform should contribute to broader financial system stability and be credit positive for banks in the long run. That said, perceived instability - such as the recent equity market turmoil - may set back the pace of financial reform, as intervention from authorities to restore stability increases the risk of the government prioritising growth over reform. However, from a support perspective, it reinforces expectations for extremely high state support to the banking system.

The central government is the largest shareholder in each of the five state banks, has provided solvency support in the past, and has a strong track record of asset quality support. Fitch sees the recent plan to swap USD160bn of local government debt for bonds as a form of debt migration to the sovereign balance sheet, which underscores the state's high propensity to continue supporting the banking system. This includes using the state-owned asset management companies, which have also been actively purchasing assets from the banks and the market. This suggests not all problematic assets will be crystallised through the banking system. Consequently, the banks' SRFs remain closely linked to China's sovereign rating (A+/Stable). The Outlook on the banks' IDRs remains Stable as support is not expected to diminish in the foreseeable future.

VIABILITY RATINGS
The Viability Ratings (VRs) of China's state banks are in the 'bb' category and remain the highest in the sector. They take into account the challenging operating environment, which the state banks are best placed in China to navigate given their large nationwide franchises. Relative to other Chinese commercial banks, the state banks generally exhibit superior funding and liquidity, smaller credit exposure and off-balance-sheet activities, as well as higher loss-absorption capacity. In Fitch's view, the state banks would likely most benefit from depositor flight to safety, providing some support to their VRs in the event of stress in the system.

Fitch core capital ratios improved for the state banks in 2014 as they scaled back on credit growth. Reported core capital ratios also improved, as the banks implemented the internal ratings-based approach for the calculation of risk weights while total capital ratios rose partly owing to additional capital raising, including Basel III compliant instruments. That said, the sufficiency of the banks' capital may come under greater scrutiny if and when more assets are brought back onto their balance sheets following recent regulatory changes. In that regard, Fitch has long taken a cautious view of capital due to the magnitude of off-balance sheet risks and limited transparency. But data thus far suggests the pace of credit growth is slowing from that in prior years.

The upgrade of ABC's VR reflects Fitch's view that its intrinsic strength is more similar to the largest of state banks than previously thought. ABC's loss absorption buffer is on par with its state bank peers, and it has lower off-balance-sheet exposure relative to them, which mitigates the fact that ABC's reported capital ratios are still lower and NPLs higher. Although ABC's significant rural deposit franchise could render the bank more vulnerable to operational risks, it is also likely to benefit the bank in terms of lower funding costs, even as interest rates are liberalised.

Fitch has also observed steady improvement in the loss absorption buffers of CCB and ICBC, and a gradual decline in their credit exposures in recent years. However, concerns over policy pressure to support economic growth still weigh heavily on China's operating environment and on all banks' asset quality. As such, maintaining more sustainable credit growth would help in further strengthening their capital.

BOC plans to increase its overseas assets to 40% of total assets in the next five years, from 27% at the end of 2014. Aggressive overseas expansion could alter BOC's risk profile and challenge its ability to successfully integrate and manage its overseas businesses efficiently. This has potential to impact the bank's VR, but the agency expects BOC will exercise discipline in its overseas expansion.

Recent efforts at BOCOM have focused on strengthening its asset management capabilities. Loan growth slowed to 5% in 2014 from 11% in 2013, but wealth management products (WMPs) managed by it almost doubled to CNY1trn, equivalent to 16% of total assets at end-2014. However, BOCOM's higher risk appetite compared with the other state banks has not resulted in superior profitability as its franchise still lags the large state peers, resulting in comparatively higher funding costs. In addition, such aggressive issuance of WMPs comes with hidden credit and liquidity risks and may negatively impact the bank's VR if it were to continue.

While the key financial metrics of the state banks are comparable to those of highly rated banks in developed markets, many aspects of their financial profiles (for example, capitalisation, profitability, liquidity and off-balance sheet exposures) do not compare as well with major banks in other emerging markets, where, as in China, risks are often higher. Eventual asset quality deterioration and/or margin erosion is common in markets that have experienced rapid accumulation of credit over a sustained period, though China's mostly deposit-funded banking system and domestic stock of credit should allow some flexibility for authorities to work through China's debt problem at its own pace. Recognition of greater asset impairment may only come after the banks have built up further buffers, credit/economic growth is deemed sustainable by China's authorities, and/or the system is viewed as less vulnerable to contagion. That said, the various tools or policy levers that the authorities can use could reduce the risk of banks having to bear significant asset impairment.

Fitch's analysis of asset quality focuses more on loss-absorption buffers (including factors such as capitalisation, loan-loss reserve coverage, and profitability) than on reported NPL ratios, given the limitations on data disclosure and transparency, as well as the significant amount of non-loan credit and the frequency of regulatory intervention to support borrowers. On average, Fitch-rated banks have loss-absorption buffers equivalent to 6.3% of credit (state banks: 7.7%; mid-tier commercial banks: 3.7%), which show the level of deterioration in credit they can withstand before some form of remedial action would likely be required.

Although China's banking system has been accumulating large off-balance-sheet exposures, including through transactions with non-banks, and it is not always transparent where ultimate risk resides in such transactions, the state banks are considered to be less exposed to such activities than other Chinese commercial banks. Fitch estimates non-loan credit accounted for 38% of total financial sector credit outstanding at 2014 (2008: 21%). WMPs outstanding were CNY15.0trn at 2014 (CNY10.2trn at 2013), according to China's National Banking Wealth Management Registration System, and these products continue to increase as competition for deposits intensifies, leading to an increase in the cost - but shortening of tenor - of bank funding. WMPs' short tenors, asset-liability mismatches and limited disclosure of underlying assets have the potential to pose meaningful contingent risk to the banks.

SUBSIDIARY AND AFFILIATED COMPANIES
Amipeace Limited is a wholly owned special purpose vehicle (SPV) of Bank of China Group Investment Limited in Hong Kong. Azure Orbit II International Finance Limited is an offshore SPV managed by Bank of Communications Financial Leasing Co., Ltd (BOCOM Leasing; A/Stable), a wholly owned subsidiary of BOCOM. CCBL Funding Plc is a wholly owned SPV of China Construction Bank (London) Limited. All three SPVs were established with the sole purpose of undertaking offshore debt issuance of their parent entities.

As wholly owned subsidiaries, Fitch expects these SPVs would receive very strong support from their ultimate parents in the mainland in the event of repayment strains. In fact, current senior debt issuance by Amipeace Limited is guaranteed by BOC's Macau branch, while CCBL Funding Plc's debt is guaranteed by CCB and Azure Orbit II International Finance Limited's debt is guaranteed by BOCOM's Macau branch respectively. Hence, the Long- and Short-Term Ratings of these instruments are derived from those of their parents' at 'A' and 'F1', respectively.

SENIOR DEBT AND SUBORDINATED NOTES
The senior debt instruments are rated in line with the banks' IDRs of 'A', as they are considered to be unsecured and unsubordinated obligations of the banks. The Tier 2 subordinated (Basel III compliant) note ratings are in accordance with Fitch's hybrid securities criteria, and reflect expectations that the authorities will extend support to the banks so as to avoid them triggering non-viability clauses. As such, the anchor rating is the banks' IDR. However, since the notes are to be fully written down if non-viability is triggered, they are notched twice from the IDR.

RATING SENSITIVITIES

IDRS, SUPPORT RATINGS, SUPPORT RATING FLOORS, DEBT INSTRUMENTS
Any changes to IDRs, SRs, SRFs and ratings on debt instruments will be tied to shifts in the central government's propensity and/or ability to support these banks, including through regulatory developments or changes in ownership. That said, it remains unclear how the adherence to a state-controlled status, as stipulated in BOCOM's ownership reform plans, would affect state support for BOCOM.

Persistent rapid growth across the financial system (including non-bank credit extension) means that potential claims on the state continue to increase. By Fitch's estimation, total credit (the central bank's measure of total aggregate finance as adjusted by Fitch) to GDP will rise to 255%-260% by end-2015. While credit growth has slowed so far in 2015, it is still outpacing GDP growth.

The longer financial system leverage is permitted to rise, the greater the potential erosion of the state's ability to support the banks, leading to pressure on support-driven IDRs. However, Fitch believes that absent any negative action on the sovereign rating, support for the state banks, including BOCOM, is less likely to diminish than would be the case for other Chinese commercial banks. For the time being, the agency does not expect the state's propensity to support the state banks to reduce significantly as long as the state banks remain highly influenced by the state (including influence from authorities to extend credit in support of public policy).

VIABILITY RATINGS
VR upgrades for the state banks are possible if Fitch considers the operating environment to have at least stabilised, if not improved. This would likely be evidenced by the pace of credit growth further slowing to a more sustainable level, stronger regulation contributing to less off-balance-sheet activity (or being less of a concern, including due to greater transparency around such activity), greater confidence that reported asset quality ratios will hold, or the banks improving their loss-absorption capacities and/or strengthening their deposit funding and liquidity. Further development in the country's financial markets would also help reduce the financing and asset quality burdens currently placed on the banking system, as well as support eventual deleveraging of the economy. The agency has noted early signs of improvement in some of these areas for the state banks, and will closely monitor the situation.

Downgrades of VRs could be triggered by further excessive growth, which renders capital more vulnerable to deterioration, if asset quality deterioration undermines solvency, or if funding and liquidity strains become more binding. The latter could be manifested in market dislocation, such as abrupt disruption in issuance of WMPs - often substitutes for deposits - or interbank market distress, particularly if a bank is more exposed to such activities than its peers. Although much of the sector benefits from a degree of ordinary support from Chinese authorities in the form of forbearance, whether in relation to on/off balance sheet exposures or strict interpretation of prudential limits, the state banks arguably benefit most. However, if this was to reduce, VRs could come under pressure as vulnerabilities would become further exposed.

The full list of rating actions on China's five large state banks is as follows:

Agricultural Bank of China Limited:
- Long-Term Foreign-Currency IDR affirmed at 'A'; Stable Outlook
- Short-Term Foreign-Currency IDR affirmed at 'F1'
- Support Rating affirmed at '1'
- Support Rating Floor affirmed at 'A'
- Viability Rating upgraded to 'bb' from 'bb-'

Bank of China Ltd:
- Long-Term Foreign-Currency IDR affirmed at 'A'; Stable Outlook
- Short-Term Foreign-Currency IDR affirmed at 'F1'
- Long-Term Local-Currency IDR affirmed at 'A'; Stable Outlook
- Short-Term Local-Currency IDR affirmed at 'F1'
- Support Rating affirmed at '1'
- Support Rating Floor affirmed at 'A'
- Viability Rating affirmed at 'bb'
- Senior unsecured certificate of deposit programme affirmed at 'A'/' F1'
- Senior unsecured euro commercial paper and certificate of deposit programme affirmed at 'A'/'F1'
- Senior unsecured medium-term note programme affirmed at 'A'/'F1'
- Senior unsecured Bons a Moyen Terme Negociables (BMTN) programme Long-Term Rating affirmed at 'A'.
- Chinese yuan senior unsecured notes (issued by Bank of China Taipei Branch) affirmed at 'A' /'AA+(twn)'
- Chinese yuan senior unsecured notes (issued by Bank of China London, Singapore, Sydney, Luxembourg, Paris and Abu Dhabi Branch) affirmed at 'A'
- US dollar senior unsecured notes (issued by Bank of China Hong Kong Branch) affirmed at 'A'
- Singapore dollar senior unsecured notes (issued by Bank of China Singapore Branch) affirmed at 'A'
- Euro senior unsecured notes (issued by Bank of China Hungarian Branch) affirmed at 'A'
- Basel III-compliant Tier 2 subordinated notes affirmed at 'BBB+'

Amipeace Limited:
- Senior, guaranteed medium-term note programme affirmed at 'A'
- USD600m 2% guaranteed notes due 2016 affirmed at 'A'
- USD300m 2.375% guaranteed notes due 2017 affirmed at 'A'
- USD300m 3.125% guaranteed notes due 2019 affirmed at 'A

Bank of Communications Co., Ltd.:
- Long-Term Foreign-Currency IDR affirmed at 'A'; Stable Outlook
- Short-Term Foreign-Currency IDR affirmed at 'F1'
- Support Rating affirmed at '1'
- Support Rating Floor affirmed at 'A'
- Viability Rating affirmed at 'bb-'
- Senior unsecured euro medium-term note programme (EMTN) (issued by Bank of Communications Hong Kong Branch) affirmed at 'A'/'F1'
- Chinese yuan senior unsecured notes (issued by Bank of Communications Hong Kong Branch) affirmed at 'A'
- Basel III-compliant Tier 2 subordinated notes affirmed at 'BBB+'

Azure Orbit II International Finance Limited:
- Senior, unsecured medium-term note programme Long-Term Rating affirmed at 'A'
- USD500m guaranteed notes due 2019 affirmed at 'A'

China Construction Bank Corporation:
- Long-Term Foreign-Currency IDR affirmed at 'A'; Stable Outlook
- Short-Term Foreign-Currency IDR affirmed at 'F1'
- Long-Term Local-Currency IDR affirmed at 'A'; Stable Outlook
- Short-Term Local-Currency IDR affirmed at 'F1'
- Support Rating affirmed at '1'
- Support Rating Floor affirmed at 'A'
- Viability Rating affirmed at 'bb'
- Basel III-compliant Tier 2 subordinated notes affirmed at 'BBB+'

CCBL Funding PLC:
- CNY1bn 3.2% senior, guaranteed medium-term Chinese yuan bonds affirmed at 'A'

Industrial and Commercial Bank of China:
- Long-Term Foreign-Currency IDR affirmed at 'A'; Stable Outlook
- Short-Term Foreign-Currency IDR affirmed at 'F1'
- Support Rating affirmed at '1'
- Support Rating Floor affirmed at 'A'
- Viability Rating affirmed at 'bb'