RATINGS RATIONALE

Moody's decision to downgrade and place ACB's ratings on review for possible downgrade follows the negative developments at the bank as a result of (i) this week's police arrest of the bank's co-founder, Mr. Nguyen Duc Kien, a high-profile Vietnamese tycoon, and (ii) the subsequent resignation and arrest of the bank's chief executive officer (CEO), Mr. Ly Xuan Hai.

While the bank has stated that neither of these arrests was related to wrongdoings at ACB itself, Moody's is concerned that these developments have resulted in pressure on the bank's liquidity and that there could be longer-term negative consequences for the bank's franchise value.

So far, these events have led to a fall in the bank's share price and deposits. Although the extent of the decline in deposits cannot be verified, the central bank has confirmed having provided liquidity to ACB for that reason.

The bank entered this period of turbulence with a good liquidity position, but relatively weak capital and declining asset quality. At B1, ACB also had a higher rating than some of its peers in the Vietnamese market, which Moody's believes is no longer justified given the current liquidity pressure and the more difficult environment it is facing to raise capital.

It had reported gross customer loans-to-gross customer deposits ratio of 70% at end-June 2012 (from 72% at end-2011), whereas its liquid assets to total assets stood at 39%.

Tier 1 ratio as at end-June 2012 was 6.6%, below the global peer average.

Non-performing loans (NPLs) ratio continued increasing to 1.5% by end-June 2012 (0.9% at end-2011), while its overall problem loans ratio (including special mention loans) doubled to 2.4% by end-June 2012 (1.2% at end-2011).

Separately, the review for downgrade on the bank's ratings reflects persistent pressure from markets and depositors and the risk that this dynamic could potentially lead to a further deterioration of its credit fundamentals.

Moody's assumes that central bank support has been of an orthodox lender-of-last resort nature. If the rating agency anticipates that the bank needs extraordinary systemic support to avoid default, it is likely that it would again downgrade the stand-alone credit profile and a gap could emerge between the deposit rating and the stand-alone credit assessment.

On the positive side, in a statement published on the SBV's website on Wednesday, Mr. Nguyen Huu Nghia, the bank's chief inspector, said that the SBV would provide protection to ACB depositors going forward, if needed. It reportedly said the entire banking sector is "standing ready to provide funding support to ACB to ensure it meets its obligations for repaying deposits."

PRINCIPAL METHODOLOGIES

The principal methodology used in this rating was Moody's Consolidated Global Bank Rating Methodology published in June 2012. Please see the Credit Policy page on www.moodys.com for a copy of this methodology.

Headquartered in Ho Chi Minh City, Vietnam, ACB reported total assets of VND254 trillion at the end of June-2012.

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