/raid1/www/Hosts/bankrupt/TCREUR_Public/240923.mbx        T R O U B L E D   C O M P A N Y   R E P O R T E R

                          E U R O P E

          Monday, September 23, 2024, Vol. 25, No. 191

                           Headlines



F R A N C E

FLAMINGO LUX II: Moody's Cuts CFR & Senior Secured Term Loan to B3
HESTIAFLOOR 2: Fitch Affirms 'B' LongTerm IDR, Outlook Positive


I R E L A N D

CASTLELAKE AVIATION: Moody's Puts 'Ba3' CFR on Review for Upgrade
SIGNAL HARMONIC III: Fitch Assigns 'B-sf' Final Rating on F-2 Notes


N E T H E R L A N D S

DYNAMO MIDCO: Fitch Assigns 'B(EXP)' LongTerm IDR, Outlook Positive
NOBIAN FINANCE: Moody's Rates New Extended Secured Term Loan 'B2'


P O L A N D

BANK MILLENNIUM: Fitch Gives BB+(EXP) Rating on Non-Preferred Bonds


T U R K E Y

ALTERNATIFBANK AS: Fitch Hikes LongTerm Foreign Currency IDR to BB-
BURGAN BANK: Fitch Hikes LongTerm Foreign Currency IDR to 'BB-'
ING BANK: Fitch Gives 'B+(EXP)' Rating on Tier 2 Notes
TURK EKONOMI: Fitch Assigns CCC+ Rating on USD300MM Tier 1 Notes
TURK P&I: Fitch Hikes Insurer Fin. Strength Rating to 'BB-'

TURKLAND BANK: Fitch Affirms 'B' IDRs, Off Watch Negative
[*] Fitch Hikes 3 Turkish Non-Bank Fin. Institutions to 'BB-' IDR
[*] Fitch Hikes IDRs on 11 Turkish Non-Bank Entities to 'BB-'
[*] Fitch Upgrades 24 Turkish Banks on Sovereign Upgrade


U K R A I N E

[*] Fitch Hikes 8 Ukrainian LRGs to CCC on Sovereign Rating Action


U N I T E D   K I N G D O M

BRICK LIVE: ReSolve Advisory Named as Administrators
FABLINK GROUP: Interpath Ltd Named as Joint Administrators
FABLINK UK: Interpath Ltd Named as Joint Administrators
GLENEVIN LTD: RSM UK Named as Administrators


X X X X X X X X

[*] BOND PRICING: For the Week September 16 to 20, 2024

                           - - - - -


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F R A N C E
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FLAMINGO LUX II: Moody's Cuts CFR & Senior Secured Term Loan to B3
------------------------------------------------------------------
Moody's Ratings has downgraded the long-term corporate family
rating of Flamingo Lux II SCA ("EMERIA" or "the company") to B3
from B2, probability of default rating to B3-PD from B2-PD, and the
instrument rating on the EUR250 million senior unsecured notes to
Caa2 from Caa1. Concurrently, the instrument ratings on the two
EUR400 million backed senior secured notes, EUR1,275 senior secured
term loan B, EUR788 million senior secured term loan B2, and
EUR437.5 million senior secured first lien revolver credit facility
(RCF), all issued by EMERIA, have been downgraded to B3 from B2.
The outlook of both entities remains negative.

RATINGS RATIONALE

The downgrade of EMERIA's CFR to B3 reflects a delayed deleveraging
path and negative free cash flow generation.  Moody's-adjusted
leverage, estimated at approximately 11x for the last twelve months
ending June 2024 which is expected to decline to around 10x by the
end of 2024 remains outside the requirements for the B3 rating
category. Despite the company's commitment to significantly reduce
leverage and enhance cash flow generation, operating earnings
continue to be pressured by higher non-recurring expenses
associated with restructuring and transformation efforts and muted
activity of the B2C Sales business as of end of June 2024.
Additionally, the considerable interest expense on a substantial
debt load has resulted in negative Moody's-adjusted free cash flow
since 2022, which Moody's anticipate will persist through 2024.

The B3 rating is underpinned by EMERIA's strong market leadership
in France and the UK, coupled with a growing presence in
neighbouring countries such as Germany, Belgium, and Switzerland,
thereby mitigating geographical concentration in France. The rating
also reflects EMERIA's substantial recurring revenue base derived
from stable residential property management activities and its
solid historical track record of scaling operations while enhancing
operating margins.

RATIONALE OF THE OUTLOOK

The negative rating outlook reflects Moody's expectation that
EMERIA's leverage will remain elevated, even for the B3 rating
category, and is highly sensitive to financial policy and capital
allocation decisions. Execution risks associated with the
substantial reduction of integration and restructuring costs, which
are necessary to achieve sustainably positive free cash flow (FCF),
are exerting downward pressure on the rating.

Nevertheless, Moody's anticipate that the company's restructuring
and transformation initiatives, combined with a reduction in merger
and acquisition (M&A) activity, will support deleveraging towards
8x over the next 12 to 18 months. During this period, Moody's
expect the interest coverage ratio, expressed as EBITA/Interest
expense, to improve to around 1.5x. Earnings and cash flow
generation will benefit from moderate organic growth in EMERIA's
core markets and a gradual improvement in the market conditions for
both its stock and brokerage businesses.

The negative outlook further reflects the limited headroom within
the current rating category to accommodate underperformance,
continued negative free cash flow generation, or additional
debt-financed acquisitions that could weaken liquidity.

FACTORS THAT COULD LEAD TO AN UPGRADE OR DOWNGRADE OF THE RATINGS

Upward rating pressure is unlikely considering the negative
outlook, but could develop in case of:

-- Sustained positive FCF generation with Moody's adjusted
FCF/Debt increasing towards 5%

-- Moody's adjusted debt/EBITDA declining below 6x

-- Moody's adjusted EBITA/Interest improves towards 2x

-- Sustained earnings growth and material reduction in
non-recurring operating expenses

-- Good liquidity, including the timely addressing of debt
maturities

Downgrade rating pressure could develop if:

-- Negative Moody's-adjusted FCF persists or liquidity
deteriorates further

-- Company fails to materially reduce non-recurring costs or
engages in debt-funded acquisitions

-- Moody's adjusted debt/EBITDA remains above 8x

-- Moody's adjusted EBITA/Interest remains below 1.5x

ENVIRONMENTAL, SOCIAL AND GOVERNANCE CONSIDERATIONS

Governance considerations were among the primary drivers of the
rating action and reflect the company's aggressive financial policy
which is tolerant of large debt-funded M&A and consecutive high
leverage. It also reflects its earnings and cash flow sensitivity
to a successful integration of acquired companies.

At the same time Moody's understand that the management and
shareholders continue committed to leverage reduction though no
debt-funded M&A and disciplined capital allocation. In addition,
the company is undertaking several restructuring measures to
improve operational efficiency in Germany and Switzerland, which
together with the completion of the transformation activities
should gradually improve earnings and cash flow generation.

LIQUIDITY

EMERIA's liquidity is adequate based on the expectation that
negative free cash flow generation will be turned around. EMERIA's
liquidity is characterized by  EUR7.2 million available cash
(excluding bank overdraft), EUR19.6 million undrawn bank overdraft,
and EUR97.5 million undrawn revolving credit facility as of June
2024. The company's cash generation is highly seasonal, with 70%
occurring in the second half the year (out of which 40% in the last
quarter). This seasonality, combined with low earnings, has led to
significant debt drawings (EUR100 million term loan B2 in March
2024 and EUR108 million RCF through H1 2024), resulting in high
interest expenses and continued negative Moody's adjusted free cash
flow of -EUR158.6 million as of LTM June-24.

In the next 12-18 months, Moody's expect EMERIA to steadily reduce
non-recurring expenses and continue benefitting from the savings
from the deployment of Agency of the Future, which will be
completed by the end of H1 2025. Moody's expect the latter to help
improve EBITDA and allow for partial repayment of RCF drawings and
lower interest expenses. A disciplined capex spending, will likely
allow the company to generate positive free cash flow by end of
2025. Further Moody's expect the company to refrain from
debt-funded M&A activities.

The company has no significant debt maturities prior to September
2027, when the drawn RCF matures, followed by EUR2,063 million
senior secured term loan B, EUR800 million senior secured notes
(issued by EMERIA) coming due in March 2028, and EUR250 million
senior unsecured notes (issued by Flamingo Lux II SCA) coming due
in March 2029.

Moody's expect the company to maintain adequate headroom under its
springing covenant on the revolving credit facility in combination
with a timely addressing of debt maturities.

STRUCTURAL CONSIDERATIONS

The senior secured debt instruments are rated B3, at the same level
as the CFR, reflecting their pari passu ranking and the
comparatively small amount of junior debt ranking below them.
Conversely, the senior unsecured notes are rated Caa2 because of
the comparatively high amount of debt ranking ahead of them in the
capital structure.

The senior secured bank credit facilities benefit from a security
package comprising share pledges of material subsidiaries,
assignment of intercompany receivables, and pledges over certain
bank accounts. The senior secured bank credit facilities also
benefit from upstream guarantees from most operating subsidiaries.
The senior unsecured notes benefit from the same upstream
guarantees as the senior secured debt, but on a second ranking
basis.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was Business and
Consumer Services published in November 2021.

CORPORATE PROFILE

Headquartered in France, EMERIA is a leading provider of
residential real estate services through a network of 700 branches
in seven countries. The company, which is owned by a consortium led
by the private equity fund Partners Group since 2016, generated
revenue of EUR1.5 billion (EUR1.5 billion proforma closed and
post-period acquisitions and synergies) and company adjusted EBITDA
of EUR389 million (EUR458 million proforma closed and post-period
acquisitions and synergies) for the 12 months that ended in June
2024.


HESTIAFLOOR 2: Fitch Affirms 'B' LongTerm IDR, Outlook Positive
---------------------------------------------------------------
Fitch Ratings has affirmed Hestiafloor 2's (Gerflor)'s Long-Term
Issuer Default Rating (IDR) at 'B' with a Positive Outlook
following the announcement of an expected amendment and extension
(A&E) of its existing EUR900 million senior secured term loan B
(TLB) and EUR210 million revolving credit facility (RCF). Fitch has
assigned the A&E of the TLB a 'B+(EXP)' expected rating with a
Recovery Rating of 'RR3'. The aim of the A&E is to extend the
maturity of the TLB by three years.

The assignment of a final rating is contingent on the completion of
the A&E transaction and the receipt of final documents conforming
to information already received.

The IDR balances Gerflor's high leverage with a solid business
profile and sound profitability. The group has recently improved
its leverage profile, resulting in greater rating headroom. Fitch
expects continued improving operating profitability, which combined
with the net shareholder equity injection in 2023, will help the
group reduce its EBITDA gross leverage to around 5.5x by end-2025.
This is underlined in the Positive Outlook.

Its operating profitability improvement will be supported by the
group's end-market diversification and focus on the more resilient
renovation end-market with limited exposure to the softer
residential and office end-markets.

Key Rating Drivers

Leverage High but Decreasing: The rating remains constrained by
high leverage and expected modest deleveraging over the next four
years. Fitch forecasts Fitch-defined EBITDA leverage of 5.7x at
end-2024, 5.5x at end-2025 and about 5x at end-2027, driven by
mid-single digit revenue growth and a modest increase in EBITDA
margins. Fitch assumes that positive free cash flows (FCF) in
2024-2027 will be mainly used for continued bolt-on acquisitions.
Shareholder net equity injection of about EUR75 million in 2023
provided further funds for acquisitions and helped Gerflor repay
its revolving credit facility (RCF) drawdown.

Resilient Operating Profitability: Fitch expects continued
resilient operating profitability to be supported by the group's
sound end-market diversification and its focus on the more
resilient renovation end-market. It has limited exposure to the
weaker residential and office end-markets but meaningful exposure
to stable commercial end-markets such as education, healthcare and
transport. Fitch expect continued normalisation of raw material and
transportation costs versus 2022. Profitability will be further
supported by contribution from new bolt-on acquisitions and new
product launches.

Through-the-Cycle Positive FCF: Fitch expects positive FCF margins
of about 2%-3% annually in 2024-2027. Fitch expects increasing
operating profitability to be partly offset by continued high
interest costs, large growth capex and working-capital investments
to support Gerflor's revenue growth.

Continued Acquisitive Strategy: Fitch expects Gerflor to continue
its M&A-driven growth strategy, with total net acquisitions of
about EUR40 million assumed a year over 2024-2027. Fitch expects
acquisitions to be moderate in size and mostly financed by
internally generated cash flows. The group has a successful
integration record and policy of acquiring companies with a clear
strategic fit at sound valuations. The M&A pipeline, deal
parameters and post-merger integration remain important rating
drivers.

Derivation Summary

Gerflor has a leading market position in its resilient niche
flooring segment and is larger than building product peers, such as
Terreal Holding SAS or PCF GmbH (CCC+) and similar in size to
Victoria PLC (B+/Stable). It is much smaller than Mohawk
Industries, Inc. (BBB+/Stable) and slightly smaller than Tarkett
Participation (B+/Stable). Gerflor has better geographical
diversification than Victoria, although both have a fairly high
exposure to Europe, while Tarkett is more geographically
diversified.

Like most building-product companies, Gerflor has limited product
differentiation but has developed innovative product solutions,
enabling it to cater to a wide range of end-customers. Gerflor's
distribution channels result in a strong exposure to renovation or
refurbishment construction activities (estimated at 75%-80% of
revenue), similar to that of Tarkett.

Gerflor's EBITDA margins (around 13%) are stronger than those of
higher-rated peers Tarkett (5%-7%) and Victoria (11%-12%).
Gerflor's leverage profile is weaker and Fitch expects EBITDA gross
leverage of 5.6x-5.2x in 2024-2026 compared with 4.6x-4.1x for
Tarkett over the same period.

Key Assumptions

- Mid-single digit annual revenue growth in 2024-2027, supporting
broadly stable Fitch-defined EBITDA margin at around 13%

- Capex at 3.7% of revenue in 2024 and 4% annually in 2025-2027

- Working-capital requirement of about 0.9%-1.0% of revenue in
2024-2027

- New M&As of around EUR40 million annually in 2024-2027

Recovery Analysis

The recovery analysis assumes that Gerflor would be reorganised as
a going concern in bankruptcy rather than liquidated.

Fitch assumes a 10% administrative claim. Factoring line and other
credit facilities rank super senior.

Its going-concern EBITDA estimate of EUR140 million reflects
Gerflor's most recent acquisitions and its view of a sustainable,
post-reorganisation EBITDA on which Fitch bases its valuation. In
this scenario Gerflor would generate neutral-to-negative FCF.

Fitch uses an enterprise value multiple of 5.5x to calculate a
post-reorganisation valuation. It reflects Gerflor's leading
position in its niche markets (such as sport and transport),
long-term relationship with blue-chip clients and a loyal customer
base due to its direct distribution channel.

Based on the upcoming A&E transaction, its waterfall analysis
generates a ranked recovery for the senior secured debt (new EUR900
million term loan B and EUR210 million RCF) in the 'RR3' category,
leading to a 'B+(EXP)' rating for the proposed EUR900 million TLB.
The waterfall-generated recovery computation output percentage is
52%.

RATING SENSITIVITIES

Factors That Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade

- Application of conservative financial policy with EBITDA gross
leverage below 5.5x

- Higher operating margin leading to FCF margins in mid-single
digits

- Greater diversification across segments or geographies

Factors That Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade

- EBITDA gross leverage above 7.0x

- EBITDA interest coverage below 2.5x

- EBITDA margins below 12%

- Neutral-to-negative FCF margins

Liquidity and Debt Structure

Comfortable Liquidity: At end-July 2024, Gerflor had around EUR61
million of Fitch-adjusted cash balance (excluding about EUR14
million restricted for intra-year working capital swings) and
access to an undrawn EUR190 million of its EUR210 million RCF due
2026, which will be extended to 2029 as part of the A&E. Fitch
forecasts that positive FCF in 2024-2027 will be mainly used for
bolt-on acquisitions. The group's debt structure is dominated by
its EUR900 million TLB due 2027, which will be extended to 2030
after the completion of the A&E.

Issuer Profile

France-based Gerflor specialises in resilient flooring (vinyl and
linoleum) and walls & finishes solutions that are primarily sold to
commercial customers. Operations span primarily across European
countries as well as the Americas and Asia Pacific.

MACROECONOMIC ASSUMPTIONS AND SECTOR FORECASTS

Fitch's latest quarterly Global Corporates Macro and Sector
Forecasts data file which aggregates key data points used in its
credit analysis. Fitch's macroeconomic forecasts, commodity price
assumptions, default rate forecasts, sector key performance
indicators and sector-level forecasts are among the data items
included.

ESG Considerations

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' means ESG
issues are credit-neutral or have only a minimal credit impact on
the entity, either due to their nature or the way in which they are
being managed by the entity. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.

   Entity/Debt            Rating                  Recovery   Prior
   -----------            ------                  --------   -----
Hestiafloor 2       LT IDR B      Affirmed                   B

   senior secured   LT     B+(EXP)Expected Rating   RR3

   senior secured   LT     B+     Affirmed          RR3      B+




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I R E L A N D
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CASTLELAKE AVIATION: Moody's Puts 'Ba3' CFR on Review for Upgrade
-----------------------------------------------------------------
Moody's Ratings has placed the ratings of Castlelake Aviation
Finance DAC on review for upgrade, including its Ba3 corporate
family rating and B2 backed senior unsecured rating. Moody's have
also placed the Ba3 backed senior secured first lien term loan
ratings of Castlelake Aviation One DAC, a wholly-owned subsidiary
of Castlelake Aviation Finance DAC, on review for upgrade.
Previously the outlook for both entities was stable.

This rating action follows the announcement that Avolon Holdings
Limited (Avolon, Baa3 stable) has entered into a definitive
agreement to acquire Castlelake Aviation Finance DAC. The review is
unlikely to conclude until after the deal has received regulatory
approvals and the transaction closes, which is expected to occur in
the first quarter of 2025, subject to regulatory review and
customary closing conditions.

RATINGS RATIONALE / FACTORS THAT COULD LEAD TO AN UPGRADE OR
DOWNGRADE OF THE RATINGS

The review for upgrade is based upon Moody's view that, should the
acquisition by Avolon be completed, Castlelake Aviation Finance DAC
will become part of an enterprise with a significantly stronger
credit profile than if Castlelake Aviation Finance DAC remains a
standalone entity.

Castlelake Aviation Finance DAC's existing Ba3 corporate family
rating (CFR) reflects Moody's expectation of the company's
improving profitability and solid equity capitalization, as well as
its high customer concentration and primary reliance on secured
debt for funding. About three-quarters of Castlelake Aviation
Finance DAC's fleet is comprised of fuel-efficient narrow-body
aircraft, which are typically used in domestic travel and tend to
be more resilient during economic downturns. The company's
profitability, as measured by net income-to-average managed assets,
was robust at 1.8% as of June 30, 2024, as the operating
environment, partially attributable to the shortage of aircraft,
remains favorable.

Moody's expect to upgrade the ratings once the transaction closes.

Given the review for upgrade, a downgrade of the ratings is
unlikely. However, if the transaction does not close, the ratings
could be downgraded if Castlelake Aviation Finance DAC suffers from
a deterioration in earnings such that profitability (as measured by
net income/total assets) is sustained below 1%, if it loses a key
customer relationship, if its overall liquidity declines, or if it
disposes of aircraft assets on unfavorable terms.

Incorporated in Ireland, Castlelake Aviation Finance DAC is an
aircraft lessor owned by funds and accounts managed by Castlelake
L.P. As of June 30, 2024, the company had 118 aviation assets,
eight of which are used for secured loans made to aviation
companies, and total assets of $4.9 billion. Castlelake L.P. is a
global alternative investment firm with 250 aircraft and total
assets under management of $24 billion as of June 30, 2024.

The principal methodology used in these ratings was Finance
Companies published in July 2024.


SIGNAL HARMONIC III: Fitch Assigns 'B-sf' Final Rating on F-2 Notes
-------------------------------------------------------------------
Fitch Ratings has assigned Signal Harmonic CLO III DAC final
ratings

   Entity/Debt               Rating           
   -----------               ------           
Signal Harmonic
CLO III DAC

   A Loan                LT AAAsf  New Rating

   A XS2870215261        LT AAAsf  New Rating

   B XS2870215428        LT AAsf   New Rating

   C XS2870215691        LT Asf    New Rating

   D XS2870216079        LT BBB-sf New Rating

   E XS2870216152        LT BB-sf  New Rating

   F-1 XS2873297415      LT B+sf   New Rating

   F-2 XS2873300813      LT B-sf   New Rating

   Subordinated Notes
   XS2870216582          LT NRsf   New Rating

Transaction Summary

Signal Harmonic CLO III DAC is a securitisation of mainly senior
secured obligations (at least 90%) with a component of senior
unsecured, second-lien loans and high-yield bonds. Note proceeds
have been used to fund a portfolio with a target par of EUR400
million. The portfolio is actively managed by Signal Harmonic
Limited and Signal Capital Partners Limited and the CLO has an
approximately five-year reinvestment period and a nine-year
weighted average life (WAL) test.

KEY RATING DRIVERS

Average Portfolio Credit Quality (Neutral): Fitch assesses the
average credit quality of obligors to be in the 'B' category. The
Fitch weighted average rating factor (WARF) of the identified
portfolio is 24.

High Recovery Expectations (Positive): At least 90% of the
portfolio will comprise senior secured obligations. Fitch views the
recovery prospects for these assets as more favourable than for
second-lien, unsecured and mezzanine assets. The Fitch weighted
average recovery rate of the identified portfolio is 63.1%.

Diversified Portfolio (Positive): It has various concentration
limits, including the maximum exposure to the three largest
Fitch-defined industries in the portfolio at 40%. These covenants
ensure that the asset portfolio will not be exposed to excessive
concentration.

Portfolio Management (Neutral): The transaction has four matrices.
Two are effective at closing with fixed-rate limits of 5% and 7.5%
and there are two forward matrices that could be elected one year
after closing, with fixed-rate limits of 5% and 7.5%. All four
matrices are based on a top 10 obligor concentration limit of 20%.
The transaction has a reinvestment period of about five years and
include reinvestment criteria similar to those of other European
transactions. Fitch's analysis is based on a stressed-case
portfolio with the aim of testing the robustness of the transaction
structure against its covenants and portfolio guidelines.

Cash Flow Modelling (Positive): The WAL used for the transaction
stress portfolio is reduced by 12 months from the WAL covenant.
This reduction to the risk horizon accounts for the strict
reinvestment conditions envisaged by the transaction after its
reinvestment period. These include, among others, passing both the
coverage tests and the Fitch CCC test post-reinvestment as well as
a WAL covenant that gradually steps down over time. Fitch believes
these conditions would reduce the effective risk horizon of the
portfolio during the stress period.

RATING SENSITIVITIES

Factors that Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade

A 25% increase in the mean default rate (RDR) across all the
ratings and a 25% decrease in the recovery rate (RRR) across all
the ratings of the identified portfolio would lead to downgrades of
no more than one notch for the class B and D and have no impact on
the class A, C, E, F-1 and F-2 notes.

Based on the identified portfolio, downgrades may occur if the loss
expectation is larger than initially assumed, due to unexpectedly
high levels of default and portfolio deterioration. Owing to the
fact the identified portfolio has better metrics and a shorter life
than the Fitch-stressed portfolio the class C, F-1 and F-2 notes
display a rating cushion of three notches, the class B, D and E
notes two notches, and the class A notes have no rating cushion.

Should the cushion between the identified portfolio and the
Fitch-stressed portfolio be eroded due to manager trading or
negative portfolio credit migration, a 25% increase in the mean RDR
across all the ratings and a 25% decrease in the RRR across all the
ratings of the Fitch-stressed portfolio would lead to downgrades of
up to four notches for class A to D notes and to below 'B-sf' for
the class E, F-1 and F-2 notes.

Factors that Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade

A 25% reduction in the mean RDR across all ratings and a 25%
increase in the RRR across all ratings of the Fitch-stressed
portfolio would lead to upgrades of up to four notches, except for
the 'AAAsf' notes, which are at the highest level on Fitch's scale
and cannot be upgraded.

During the reinvestment period, based on the Fitch-stressed
portfolio, upgrades may occur if there is better-than-expected
portfolio credit quality and a shorter remaining WAL test, allowing
the notes to withstand larger-than-expected losses for the
transaction's remaining life. After the end of the reinvestment
period, upgrades may result from stable portfolio credit quality
and deleveraging, leading to higher credit enhancement and excess
spread being available to cover losses in the remaining portfolio.

USE OF THIRD PARTY DUE DILIGENCE PURSUANT TO SEC RULE 17G -10

Form ABS Due Diligence-15E was not provided to, or reviewed by,
Fitch in relation to this rating action.

DATA ADEQUACY

The majority of the underlying assets or risk presenting entities
have ratings or credit opinions from Fitch and/or other Nationally
Recognized Statistical Rating Organizations and/or European
Securities and Markets Authority registered rating agencies. Fitch
has relied on the practices of the relevant groups within Fitch
and/or other rating agencies to assess the asset portfolio
information or information on the risk presenting entities.

Overall, and together with any assumptions referred to above,
Fitch's assessment of the information relied upon for the agency's
rating analysis according to its applicable rating methodologies
indicates that it is adequately reliable.

ESG Considerations

Fitch does not provide ESG relevance scores for Signal Harmonic CLO
III DAC.

In cases where Fitch does not provide ESG relevance scores in
connection with the credit rating of a transaction, programme,
instrument or issuer, Fitch will disclose any ESG factor that is a
key rating driver in the key rating drivers section of the relevant
rating action commentary.




=====================
N E T H E R L A N D S
=====================

DYNAMO MIDCO: Fitch Assigns 'B(EXP)' LongTerm IDR, Outlook Positive
-------------------------------------------------------------------
Fitch Ratings has assigned Dynamo Midco B.V. (Innomotics) an
expected Long-Term Issuer Default Rating (IDR) of 'B(EXP)' with a
Positive Outlook. Fitch has also assigned the proposed notes and
term loans of Dynamo Newco II GmbH and Dynamo US Bidco Inc. an
expected senior secured rating of 'B+(EXP)' with a Recovery Rating
of 'RR3'.

The IDR is constrained by historically low profit margins, high
EBITDA leverage post-notes issue and volatile free cash flow (FCF)
in the short term. Rating strengths are Innomotics' robust business
profile with a leading market position in the low & high voltage
motors (LVMs and HVMs) and medium voltage drives (MVDs), innovative
products, product diversification as well as revenues from services
and aftermarket.

Fitch expects Innomotics to improve its profitability on cost
optimisation and following the expiry of legacy contracts in HVMs
that are associated with lower profitability. This will help to
improve free cash flow (FCF) and reduce leverage, thereby driving
the Positive Outlook.

The assignment of final ratings is contingent on completing the
transaction in line with the terms already presented.

Key Rating Drivers

High Leverage Metrics to Improve: Fitch expects high
post-transaction consolidated EBITDA leverage to decrease to around
5x by 2027, which is below the positive sensitivity for the rating.
This is also supported by the company's stated aim to deleverage.
Fitch also expects stronger interest coverage, driven by healthy
EBITDA growth on a broadly stable debt quantum. Fitch views the
proposed diversified financing and its long-term maturity profile
as supportive of the ratings.

Strategic Actions Drive Profitability: Fitch forecasts EBITDA
margin to improve to about 11% by 2027 from 8% in 2023 on
efficiency measures, a new pricing strategy and as onerous
contracts phase out. Fitch anticipates the positive impact of
various cost-reduction measures to be realised by end-2025,
following the elimination of fixed-cost contracts, updated pricing
especially in HVMs and MVDs and an increasing order backlog. All
this should help drive profitability closer to some of its
competitors'.

Volatile FCF To Strengthen: Fitch expects the temporary pressure on
FCF to subside in 2026 with FCF turning neutral to positive.
Increased interest payments and capex are causing slightly negative
FCF in 2025, despite neutral-to-positive working-capital
fluctuations due to improved inventory management. The higher
interest expense is a result of the company's new capital
structure, while investments are aimed at supporting sales growth
and maintaining Innomotics' competitive advantage in innovative
product customisation through LVM automation.

Healthy Liquidity Headroom: Fitch anticipates satisfactory
liquidity in the medium term to provide financial flexibility for
Innomotics, which Fitch views as a credit strength. Its liquidity
buffer consists of EUR150 million post-transaction Fitch-adjusted
readily available cash and a proposed undrawn revolving credit
facility (RCF). Its short-term maturity is only the company's
prospective factoring facility post-notes issue.

Robust Business Profile: Innomotics' market-leading position and
its reasonable geographic and end-market diversification are a
credit strength. Around 80% of its 2023 revenue stemmed from
overseas, including 19% from China and 22% from the Americas,
across over 13 end-markets, such as minerals, chemicals and metals.
Its product offering is firmly positioned to serve the global trend
of combustion engines transitioning to electrical, new energy
applications and to meet the demands of urbanisation. Innomotics'
ability to offer bespoke products reinforces its competitive edge
and brand reputation.

Derivation Summary

Innomotics' business profile (annual revenue over EUR3,000 million)
is among the strongest within its peer group, ranking above Innio
Group Holding GmbH (B/Positive), Flender International GmbH
(B/Stable) and Ahlstrom Holding 3 Oy (B+/Stable). This is further
supported by its reasonable geographic diversification, with 79% of
its revenue generated outside Germany, and continuous product
expansion, similar to higher-rated peers such as Ahlstrom and Regal
Rexnord Corporation (BBB-/Stable).

Innomotics' limited diversification of its customer portfolio, with
the top 15 customers accounting for about 30% of order intake, in
comparison to Ahlstrom, results in the one-notch difference, albeit
partly offset by its longstanding relationships.

Innomotics' market-leading position as a specialist manufacturer
underpins its through-the-cycle EBITDA and EBIT margins of 10.4%
and 8.3% respectively. These are similar to other 'B' rated
diversified industrial companies such as Flender and Project Grand
Bidco (UK) Limited (B+(EXP)/Stable), albeit weaker than Innio's and
TK Elevator Holdco GmbH's (B/Stable). However, its strong
profitability is offset by weaker FCF margins than Project's, which
Fitch expects to remain neutral until 2027. This is a key rating
constraint driving the one-notch rating difference with Project.

Innomotics' new capital structure will drive EBITDA leverage to a
peak of 6.3x at end-2024. This is comparable to that of Flender and
higher-rated peers, such as Ahlstrom, while being considerably
lower than TK Elevator's.

Key Assumptions

Key Assumptions in Fitch's Rating Case for the Issuer

- Revenue growth on average of 2.1% in 2025-2027

- EBITDA margin to improve to around 11% by 2027 on efficiency
gains and repricing

- Cash interest paid around EUR160 million post-refinancing,
reflecting Fitch's latest Global Economic Outlook on interest
rates

- Broadly neutral working-capital flows

- Capex to average around 3% of revenue until 2027 (also reflecting
its more conservative revenue assumption)

- No further M&A post-transaction nor dividends paid until 2027

Recovery Assumptions

- The recovery analysis assumes that Innomotics would be
reorganised as a going-concern (GC) in a bankruptcy, rather than
liquidated in a default

- A 10% administrative claim

- Its GC EBITDA estimate of EUR275 million reflects Fitch's view of
a sustainable, post-reorganisation EBITDA level on which Fitch
bases the enterprise valuation (EV)

- An EV multiple of 5.5x is applied to the GC EBITDA to calculate a
post-reorganisation EV, in line with the industry median and
peers'

- The multiple of 5.5x reflects InnomoticsĀ“ business model as a
multi-specialist manufacturer of electric motors serving diverse
end-markets. It is further supported by its leading market
position, a strong customer base, expertise and Siemens' branding
in the short term

- The waterfall analysis is based on the expected capital
structure, which consists of all equally ranking senior RCF Fitch
assumes to fully drawn in a post reorganisation scenario, senior
secured notes, a euro term loan B (TLB), an US dollar TLB and a
guarantee facility Fitch assumes to be 50% utilised, in line with
Fitch's criteria

- The principal waterfall analysis output percentage on current
metrics and assumptions is 57% for the rated notes, corresponding
to 'RR3'.

RATING SENSITIVITIES

Factors That Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade

- EBITDA margins above 11%

- FCF margins sustained above 2%

- EBITDA leverage below 5.5x, supported by a conservative financial
policy towards deleveraging

- EBITDA interest coverage above 2.5x

Factors That Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade

- EBITDA margins below 8%

- Negative FCF margins on a sustained basis

- EBITDA leverage above 6.5x

- EBITDA interest coverage consistently below 1.5x

- Consistently flat to negative cash from operations less
capex/debt

Liquidity and Debt Structure

Comfortable Liquidity: The company's healthy post-transaction cash
balance of around EUR150 million (after its adjustment for
intra-year working-capital changes of 1% of sales) is supported by
positive FCF from 2025 onwards and a proposed RCF, which Fitch
assumes to be undrawn at financial year ending October 2024. The
proposed instruments are to mature in 2031, further supporting the
liquidity profile.

Date of Relevant Committee

11 September 2024

Fitch's latest quarterly Global Corporates Macro and Sector
Forecasts data file which aggregates key data points used in its
credit analysis. Fitch's macroeconomic forecasts, commodity price
assumptions, default rate forecasts, sector key performance
indicators and sector-level forecasts are among the data items
included.

ESG Considerations

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' means ESG
issues are credit-neutral or have only a minimal credit impact on
the entity, either due to their nature or the way in which they are
being managed by the entity. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.

   Entity/Debt               Rating                   Recovery   
   -----------               ------                   --------   
Dynamo Newco II GmbH

   senior secured      LT     B+(EXP) Expected Rating   RR3

Dynamo Midco B.V.      LT IDR B(EXP)  Expected Rating

Dynamo US Bidco Inc.

   senior secured      LT     B+(EXP) Expected Rating   RR3


NOBIAN FINANCE: Moody's Rates New Extended Secured Term Loan 'B2'
-----------------------------------------------------------------
Moody's Ratings assigned B2 ratings to Nobian Finance B.V.'s
proposed amended and extended backed senior secured term loan and
backed senior secured revolving credit facility (RCF). All other
ratings of Nobian are unaffected, including the company's B2
corporate family rating and B2-PD probability of default rating.
The outlook is positive.

The proposed transaction seeks to extend the existing backed senior
secured term loan and backed RCF by 3 years. The maturity date for
the proposed amended and extended senior secured term loan is July
2029. The proposed RCF has a springing maturity (April 2026), which
is subject to the outstanding amount of the senior secured notes.
The company's EUR525 million backed senior secured notes, which
mature in July 2026, are not subject to the proposed transaction.

The ratings and outlook incorporate the expectation that the
company will execute the proposed amended and extended transaction
and address any outstanding debt maturity (including the senior
secured notes) well ahead of the due date.

RATINGS RATIONALE

The contemplated amend and extend transaction would extend Nobian's
maturity profile, which Moody's view as credit positive despite the
slightly higher expected interest costs and transaction-related
fees. Moody's expect Nobian's gross leverage, currently at 6.1x for
the last twelve months ended June 2024, to remain unchanged while
Moody's estimate EBITDA interest coverage, currently at 3.1x, to
weaken very modestly by around 0.2x (based on LTM EBITDA), although
this is subject to closing conditions. Moody's expect earnings to
improve in the second half of 2024 compared to the same period
previous year and forecast gross leverage to be in the range of
4.5x to 4.8x by the end of 2024.

A more significant negative impact to the company's interest
coverage will occur at the end of 2024 when its EUR500 million
interest rate cap (with a 0% floor) matures. In July 2023, the
company entered into a new interest rate cap, however at less
favorable terms (with a 3% floor) effective after the expiration of
the current cap.

Nobian's B2 CFR continues to reflect the company's leading market
positions in chlor-alkali products in Northwestern Europe; high
profitability for its salt and chloromethanes businesses;
long-standing relationships and a high level of integration with
its key customers; and good liquidity, supported by its undrawn
EUR200 million RCF, and its ability generate positive free
cashflow.

However, the company's geographical concentration in Northwestern
Europe; exposure to volatile caustic soda prices; and some customer
concentration, though its key customers allowed the company to
produce at relatively high utilisation rates compared to other
European chlorine peers, are credit negative. Event and financial
policy risk due to the private equity ownership, including
potential dividends, continues to weigh on the credit profile.

LIQUIDITY

Nobian's liquidity is good. As of the end of June 2024, the company
had around EUR166 million of cash on balance and access to an
undrawn EUR200 million RCF. In combination with forecast funds from
operations, these sources should be sufficient to cover capital
spending, working capital swings and working cash. The company has
also access to a EUR100m trade receivable securitization program
(undrawn).

While not included in the proposed transaction, Moody's expect that
the company will refinance its EUR525 million senior secured notes
well ahead the July 2026 maturity date.

FACTORS THAT COULD LEAD TO AN UPGRADE OR DOWNGRADE OF THE RATINGS

Moody's could upgrade ratings if (1) the company built a track
record and committed to financial policies leading to
Moody's-adjusted debt to EBITDA well below 5.0x on a sustained
basis; (2) Moody's-adjusted FCF/debt would be consistently in the
high single digits (%); (3) adjusted EBITDA/Interest remained above
2.5x; and (4) the company maintained a good liquidity.

Conversely, Nobian's ratings could be downgraded if its (1)
Moody's-adjusted debt/EBITDA increased above 6x on a sustainable
basis; (2) liquidity profile deteriorated, for instance as a result
of sustained negative FCF; (3) or Moody's-adjusted EBITDA interest
coverage declined below 2.0x.

The principal methodology used in these ratings was Chemicals
published in October 2023.

COMPANY PROFILE

Based in the Netherlands, Nobian is a vertically integrated leading
European producer of salt, essential base chemicals, and energy
solutions. It primarily focuses on its chlor-alkali products
(mainly chlorine and caustic soda), which accounted for around 60%
of its sales in 2023. In 2023, the company generated revenue of
around EUR1.7 billion and company-adjusted EBITDA of around EUR424
million. The company is owned by the private equity firm The
Carlyle Group (majority shareholder) and GIC Private Limited, a
Singaporean sovereign wealth fund.




===========
P O L A N D
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BANK MILLENNIUM: Fitch Gives BB+(EXP) Rating on Non-Preferred Bonds
-------------------------------------------------------------------
Fitch Ratings has assigned Bank Millennium S.A.'s (BB+/Positive)
upcoming issue of euro-denominated senior non-preferred (SNP) bonds
an expected long-term rating of 'BB+(EXP)'. The assignment of a
final rating is contingent on the receipt of documents conforming
to the information already received.

Key Rating Drivers

Millennium's SNP debt is rated in line with the bank's Long-Term
Issuer Default Rating (IDR), reflecting its expectations that the
bank will use only SNP and more junior debt to meet its minimum
requirement for own funds and eligible liabilities (MREL).

The proposed fixed-rate notes are expected to have a maturity in
2029, with a call option in 2028, and will constitute direct,
unsecured and unconditional obligation of Millennium. The net
proceeds from the notes will be used for activities as described in
Millennium's green bond framework and are intended to qualify as
eligible liabilities for the purposes of MREL.

On the consolidated level, the bank must comply with MREL set at
20.78% (including the combined buffer requirement of 2.75%) of
risk-weighted assets (RWAs) of the resolution group, which excludes
its mortgage bank subsidiary. At end-1H24, the buffer was 22.92% of
RWAs, comfortably above the requirement.

Millennium's ratings balance the benefits of an established
domestic retail franchise, fairly conservative new loan
underwriting and adequate asset quality against high legal costs
stemming from an above-average exposure to legacy foreign-currency
mortgage loans, which requires significant management attention
(see Fitch Upgrades Millennium to 'BB+'; Outlook Positive dated 28
June 2024).

Rating Sensitivities

Factors that Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade

The SNP debt rating would be downgraded if the bank's Long-Term IDR
is downgraded.

The SNP debt would also be downgraded to one notch below the bank's
Long-Term IDR if Fitch expects Millennium to use senior preferred
debt to meet its MREL while SNP and more junior debt would not
exceed 10% of the Millennium resolution group's RWAs on a sustained
basis.

Factors that Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade

The SNP debt rating could be upgraded if the bank's Long-Term IDR
is upgraded.

Date of Relevant Committee

27 June 2024

ESG Considerations

Millennium has an ESG Relevance Score for Management Strategy of
'4'. This reflects its view of elevated government intervention
risk in the Polish banking sector, which negatively affects the
banks' operating environment and their ability to define and
execute on their strategies. This has a negative impact on the
bank's credit profile and is relevant to the ratings, in
combination with other factors.

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means ESG issues are
credit neutral or have only a minimal credit impact on the
entities, either due to their nature or the way in which they are
being managed by the entities. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation of the
materiality and relevance of ESG factors in the rating decision.

   Entity/Debt                Rating           
   -----------                ------           
Bank Millennium S.A.

   Senior non-preferred   LT BB+(EXP) Expected Rating




===========
T U R K E Y
===========

ALTERNATIFBANK AS: Fitch Hikes LongTerm Foreign Currency IDR to BB-
-------------------------------------------------------------------
Fitch Ratings has upgraded Alternatifbank A.S.'s Long-Term
Foreign-Currency (LTFC) Issuer Default Rating (IDR) to 'BB-' from
'B' and Long-Term Local-Currency (LTLC) IDR to 'BB-' from 'B+'. The
Outlooks are Stable. Fitch has also upgraded the bank's Viability
Rating (VR) to 'b' from 'b-'.

The rating action follows the upgrade of Turkiye's Long-Term IDR to
'BB-' from 'B+'. The sovereign upgrade reflects improved external
buffers via Turkiye's strengthened foreign-exchange (FX) reserves
position, underpinned by reduced financial dollarisation and FX
demand, capital inflows and increased access to external borrowing.
(See 'Fitch Upgrades Turkiye to 'BB-'; Outlook Stable' dated 6
September 2024 at www.fitchratings.com).

These factors have significantly reduced near-term financial
stability risks underlined by the banks' increased external market
access in recent months, lower risk premiums, the elimination of
banking sector FX swaps with the central bank and the gradual
decline in FX and FX-protected deposits.

Consequently, Fitch's view of the likelihood of government
intervention in the banking system has reduced to the point that
Fitch no longer consider it appropriate to notch Alternatifbank's
LTFC IDR one notch below Turkiye's LTFC IDR. This approach had
until now reflected its view of a higher likelihood of government
intervention in the banking system than that of a sovereign
default.

The National Rating is unaffected by the rating action and will be
reviewed if its National Ratings equivalency analysis results in
different relative creditworthiness across Turkish issuers.

Key Rating Drivers

Support-Driven IDR, Country Risks: Alternatifbank's IDRs are driven
by potential shareholder support, as reflected in its Shareholder
Support Rating (SSR). Nonetheless, its LTFC IDR is constrained by
Turkiye's Country Ceiling of 'BB-', while its LTLC IDR also takes
into account Turkish country risks. The Stable Outlooks mirror
those on the sovereign. The bank's 'B' Short-Term IDRs are the only
option mapping to LT IDRs of 'BB-'.

VR Upgrade: The VR upgrade reflects an improvement in operating
environment conditions, which has strengthened the bank's
standalone creditworthiness and support its financial metrics. The
VR also reflects the bank's limited franchise, high wholesale
funding, only adequate foreign-exchange (FX) liquidity and
below-sector-average profitability, but also strengthened core
capitalisation and adequate asset-quality.

Shareholder Support Capped: Alternatifbank's SSR considers
potential support from Qatar's The Commercial Bank P.S.Q.C. (CBQ),
primarily reflecting reputational risks for its parent, but also
its strategic importance, integration and role within the group. It
is constrained by Turkiye's Country Ceiling of 'BB-'.

Improving Operating Environment: The bank's operations are
concentrated in the improved but still challenging Turkish
operating environment. The normalisation of monetary policy has
reduced near-term macro-financial stability risks and decreased
external financing pressures. Banks remain exposed to high
inflation, potential further depreciation, slowing economic growth,
and multiple macroprudential regulations, despite recent
simplification efforts.

Limited Franchise: Alternatifbank has a limited domestic franchise
(well below 1% market shares) resulting in limited pricing power.
Lending is concentrated in the corporate (end-1H24: 62%) and
commercial (37%) segments.

Asset-Quality Risks: The non-performing loans ratio improved to
1.3% at end-1H24 (end-2023: 1.6%), reflecting still strong
collections and, to a lesser extent, write-offs, while total
reserves coverage was at 217%. Stage 2 loans were 10% of gross
loans (65% restructured).

Credit risks are heightened by high concentrations (the top 25 cash
loans comprised 51% of gross loans or 2.7x common equity Tier 1
capital), exposure to the higher-risk construction and real estate
sector (15% of gross loans), including shopping malls (about 8%)
and still-high FC lending (45%). Fitch expects the non-performing
loan (NPL) ratio to increase slightly towards 2% by end-2025, given
higher rates and slower economic growth.

Below Sector-Average Profitability: Operating profit declined to
2.3% of risk-weighted assets (RWAs) in 1H24 (sector: 3.8%) from
4.9% in 2023, driven by weaker net interest income amid high lira
funding costs and loan growth caps, diminishing CPI linker gains,
and trading losses due to higher swap costs and reduced customer FX
transactions. Fitch expects Alternatifbank's operating profit to
weaken to slightly above 2% of RWAs in 2024 as funding costs weigh
on margins, loan growth caps remain in place and cost of risk
rises, while fee income should remain supportive.

Adequate Core Capitalisation: Alternatifbank's common equity tier 1
(CET1) ratio decreased to 11.2% at end-1H24 from 11.9% at end-2023,
largely reflecting the tightening of regulatory forbearance on FC
RWAs as well as weaker earnings. Its total capital ratio of 25.4%
at end-1H24 was supported by additional Tier 1 (AT1), which
provides a partial hedge against lira depreciation. Its view of
capitalisation considers ordinary support from CBQ given its record
of capital support since 2018 (including CET1 and AT1). Fitch
expects Alternatifbank's CET1 ratio to remain at around 11% in
2024.

Wholesale Funding, Only Adequate FC Liquidity: Customer deposits
comprised only 39% of total non-equity funding at end-1H24 (36% in
FC and 6% in FX-protected lira deposits), reflecting high and
increased reliance on wholesale funding (61% of total funding) in
the macroprudential regulatory environment. As a result, the bank's
loans/deposits ratio increased further to a high 164% at end-1H24
from 147% at end-2023. Fitch expects Alternatifbank's
loans/deposits ratio to remain at about current levels at
end-2024.

FC liquid assets covered over half of FC debt due within one year
at end-1H24, and a higher proportion net of CBQ funding. FC liquid
assets include FX swaps with foreign counterparties, cash,
placements and unencumbered government securities.

Rating Sensitivities

Factors that Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade

A downgrade of Turkiye's sovereign rating or an increase in its
view of government intervention risk would lead to a downgrade of
Alternatifbank's SSR, leading to negative rating action on its
Long-Term IDRs, although this is not its base case.
Alternatifbank's SSR is also sensitive to Fitch's view of the
shareholder's ability and propensity to provide support.

The bank's VR is primarily sensitive to a weakening in the
operating environment and a sovereign downgrade although this is
not its base case. The VR could also be downgraded due to an
erosion of its core capitalisation, for example due to
asset-quality weakening, if not offset by ordinary support from
CBQ.

Factors that Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade

A positive change in Turkiye's LT IDRs would likely lead to similar
action on the bank's SSR and LT IDRs. An upward revision of
Turkiye's Country Ceiling could also lead to an upgrade of the
bank's SSR and LT IDRs.

A VR upgrade is primarily sensitive to the strength of capital and
FC liquidity buffers, and stable earnings performance, combined
with a strengthening in the bank's business profile, in the context
of improving operating environment conditions.

VR ADJUSTMENTS

The operating environment score of 'b+' for Turkish banks is lower
than the category implied score of 'bb' due to the following
adjustment reason: macroeconomic stability (negative). The
adjustment reflects heightened market volatility, high
dollarisation and high risk of FX movements in Turkey.

Public Ratings with Credit Linkage to other ratings

Alternatifbank's ratings are linked to that of its parent CBQ.

ESG Considerations

The ESG Relevance Score for Management Strategy of '4' reflects an
increased regulatory burden on all Turkish banks. Management
ability across the sector to determine their own strategy and price
risk is constrained by increased regulatory burden and also by the
operational challenges of implementing regulations at the bank
level. This has a moderately negative impact on the bank's credit
profile and is relevant to the bank's rating in combination with
other factors.

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' means ESG
issues are credit-neutral or have only a minimal credit impact on
the entity, either due to their nature or the way in which they are
being managed by the entity. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.

   Entity/Debt                           Rating           Prior
   -----------                           ------           -----
Alternatifbank A.S.   LT IDR              BB- Upgrade     B
                      ST IDR              B   Affirmed    B
                      LC LT IDR           BB- Upgrade     B+
                      LC ST IDR           B   Affirmed    B
                      Viability           b   Upgrade     b-
                      Shareholder Support bb- Upgrade     b


BURGAN BANK: Fitch Hikes LongTerm Foreign Currency IDR to 'BB-'
---------------------------------------------------------------
Fitch Ratings has upgraded Burgan Bank A.S.'s (BBT) Long-Term
Foreign-Currency (LTFC) Issuer Default Rating (IDR) to 'BB-' from
'B' and Long-Term Local-Currency (LTLC) IDR to 'BB-' from 'B+'. The
Outlooks are Stable. Fitch has also upgraded the bank's Viability
Rating (VR) to 'b' from 'b-'.

The rating action follows the upgrade of Turkiye's Long-Term IDR to
'BB-' from 'B+'. The sovereign upgrade reflects improved external
buffers underlined by Turkiye's strengthened foreign-exchange (FX)
reserves position, underpinned by reduced financial dollarisation
and FX demand, capital inflows and increased access to external
borrowing.

These factors have significantly reduced near-term financial
stability risks evidenced by the banks' increased external market
access in recent months, lower risk premiums, the elimination of
banking sector FX swaps with the central bank and the gradual
decline in FX and FX-protected deposits.

Consequently, Fitch's view of the likelihood of government
intervention in the banking system has reduced to the point that
Fitch no longer consider it appropriate to notch BBT's LTFC IDR one
notch below Turkiye's LTFC IDR. This approach had until now
reflected its view of a higher likelihood of government
intervention in the banking system than that of a sovereign
default.

Key Rating Drivers

BBT Issuer Default Ratings (IDRs) are driven by its Shareholder
Support Rating (SSR). Nonetheless, its LTFC is constrained by
Turkiye's Country Ceiling of 'BB-' while the LTLC IDR also takes
into account Turkish country risks. The Stable Outlooks mirror
those on the sovereign. The bank's 'B' Short-Term IDRs are the only
option mapping to LT IDRs of 'BB-'.

The Viability Rating (VR) reflects the bank's limited franchise,
improving asset quality, adequate capitalisation, adequate FC
liquidity and ordinary support from BBK.

Shareholder Support Capped: BBT's SSR considers potential support
from Kuwait's Burgan Bank K.P.S.C. (BBK), reflecting its ownership,
integration with the BBK group, and the reputational risk from the
banks' shared branding. It is constrained by Turkiye's Country
Ceiling of 'BB-'.

Improving Operating Environment: BBT's operations are concentrated
in the improving but volatile Turkish operating environment. The
normalisation of monetary policy has reduced near-term financial
stability risks and external financing pressures. Banks remain
exposed to high inflation, potential further Turkish lira
depreciation, slowing economic growth and multiple macro-prudential
regulations, despite recent simplification efforts.

Small Domestic Franchise: BBT provides universal banking services
in Turkiye with less than 1% market share of total assets at
end-1Q24, resulting in limited competitive advantages. BBT also
provides financial leasing and investment banking services through
its subsidiaries, which were 15% of consolidated assets. The bank
also actively invests in its digital offering to improve its access
to the retail segment and widen its customer base.

Improving Asset Quality Metrics: BBT's impaired (Stage 3)
loans/gross loans ratio has improved to 2.2% at end-1H24 from 5.7%
at end-2022, driven by strong collections and limited new inflows
in 1H24. Nevertheless, the ratio remained higher than the sector
(end-1H24: 1.5%). High Stage 2 loans (end-1H24: 15.9% of gross
loans; 6.2% average coverage), concentration and high FC lending
(end-1H24: 46%) raise asset-quality risks.

Total impaired loans reserve coverage is low (83%), reflecting
reliance on collateral. Free provisions were 3.0% of gross loans at
end-1H24. Fitch expects the impaired loans ratio to rise slightly
to 2.5% at end-2024, reflecting asset-quality pressures arising
from tight monetary policy.

Adequate Profitability: BBT's operating profit/risk-weighted assets
(RWAs) decreased to 3.4% in 1H24 (sector: 3.8%) from 5.8% in 2023
largely due to increased operating expenses, despite provision
reversals (24% of operating profit) and a net interest margin that
increased to 4.8% in 1H24 from 3.7% in 2023. Performance remains
sensitive to slower GDP growth, macro-economic and regulatory
developments and asset-quality risks. Fitch expects the operating
profit/RWAs ratio to remain around its current level at end-2024.

Only Adequate Core Capital: BBT's common equity Tier 1 ratio
decreased slightly to 10.1% at end-1H24 (end-2023: 10.2%),
including an 83bp forbearance uplift, mainly due to tightening
forbearances. Pre-impairment operating profit (1H24: 4.0% of
average gross loans, annualised), and free provisions (equal to 2%
of RWAs) provide an additional buffer. BBK has provided regular
capital support to the bank since 2018. Risks to capitalisation
remain given sensitivity to lira depreciation due to the inflation
of FC RWAs and asset-quality risks.

Fitch expects the common equity Tier 1 ratio to remain almost
stable at 10% at end-2024due to increased operating expenses and a
slight deterioration in the impaired loans/gross loans ratio.

Wholesale Funding; Only Adequate FC Liquidity: Deposits comprised
only 49% of total non-equity funding at end-1H24, including 28% in
FC. Wholesale funding made up 51% of total funding, but parent
funding, at 27% of total funding, mitigates risks. FC liquid assets
did not cover all short-term FC liabilities at end-1H24, as the
bank has shifted its FC funding focus from costly FC deposits to
borrowing from the parent and third parties, given pricing
advantages. Fitch expects BBT's loans/deposits ratio to remain at
about current levels at end-2024.

Rating Sensitivities

Factors that Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade

A downgrade of Turkiye's sovereign rating or an increase in its
view of government intervention risk would lead to a downgrade of
BBT's SSR, leading to negative rating action on its Long-Term IDRs,
although this is not its base case. BBT's SSR is also sensitive to
Fitch's view of the shareholder's ability and propensity to provide
support.

The bank's VR is primarily sensitive to a weakening in the
operating environment and a sovereign downgrade, although this is
not its base case. The VR could also be downgraded due to erosion
of core capitalisation, for example due to asset-quality weakening,
if not offset by ordinary support from the parent.

Factors that Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade

An upgrade of the bank's Long-Term IDRs and SSR would require a
sovereign rating upgrade.

A VR upgrade is primarily sensitive to the strength of capital and
FC liquidity buffers, stable earnings performance and an
improvement of the business profile performance in the context of
improving operating environment conditions.

OTHER DEBT AND ISSUER RATINGS: KEY RATING DRIVERS

The bank's 'AA(tur)' National Rating is driven by shareholder
support and is in line with foreign-owned peers' in Turkiye.

OTHER DEBT AND ISSUER RATINGS: RATING SENSITIVITIES

The National Rating is sensitive to a change in the bank's LTLC IDR
and a change in its creditworthiness relative to that of other
Turkish issuers with a 'BB-' LTLC IDR.

VR ADJUSTMENTS

The 'b+' operating environment score for Turkish banks is lower
than the category implied score of 'bb' due to the following
adjustment reason: macroeconomic stability (negative). The
adjustment reflects heightened market volatility, high
dollarisation and high risk of FX movements in Turkiye.

Public Ratings with Credit Linkage to other ratings

BBT's ratings are linked to those of its parent Burgan Bank
K.P.S.C.

ESG Considerations

The ESG Relevance Score for Management Strategy of '4' reflects an
increased regulatory burden on all Turkish banks. Managements'
ability across the sector to determine their own strategy and price
risk is constrained by increased regulatory interventions and also
by the operational challenges of implementing regulations at the
bank level. This has a moderately negative impact on banks' credit
profiles and is relevant to banks' rating in combination with other
factors.

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means ESG issues are
credit neutral or have only a minimal credit impact on the entity,
either due to their nature or the way in which they are being
managed by the entity.

   Entity/Debt                        Rating           Prior
   -----------                        ------           -----
Burgan Bank A.S.     LT IDR             BB- Upgrade    B
                     ST IDR             B   Affirmed   B
                     LC LT IDR          BB- Upgrade    B+
                     LC ST IDR          B   Affirmed   B
                     Viability          b   Upgrade    b-
                    Shareholder Support bb- Upgrade    b


ING BANK: Fitch Gives 'B+(EXP)' Rating on Tier 2 Notes
------------------------------------------------------
Fitch Ratings has published ING Bank A.S.'s (INGBT; BB-/Stable)
planned issue of Basel III- compliant Tier 2 notes an expected
rating of 'B+ (EXP)'. The Recovery Rating is 'RR5'.

The final rating is subject to the receipt of the final
documentation conforming to information already received by Fitch.

The notes will constitute direct, unsecured, unconditional and
subordinated obligations and rank equally with other subordinated
obligations but in priority to junior obligations. The notes
qualify as Basel III-compliant Tier 2 instruments and contain
contractual loss-absorption features, which will be triggered at
the point of non-viability of the bank. The notes are subject to
permanent partial or full write-down upon the occurrence of a
non-viability event (NVE). The notes have a call option after five
years.

Key Rating Drivers

The subordinated notes are rated one notch below INGBT's Long-Term
Foreign-Currency (LTFC) Issuer Default Rating (IDR) of 'BB-', in
accordance with Fitch's Bank Rating Criteria, for loss severity.
Fitch has not applied any notches for non-performance risk.

The anchor rating for the notes is INGBT's LTFC IDR, which reflects
its view that potential extraordinary shareholder support from
parent ING Bank N.V. (ING; AA-/Stable) is likely to flow through to
INGBT's subordinated noteholders.

The one notch for loss severity, rather than its baseline two
notches, reflects Fitch's view that shareholder support from ING
could help mitigate losses, and incorporates the cap on the bank's
LTFC IDR at 'B' due to its view of government intervention risk.

Fitch has not applied any notches for incremental non-performance
risk, as it believes that write-down of the notes will only occur
once the point of non-viability is reached and there is no coupon
flexibility prior to non-viability, as the notes do not incorporate
going-concern loss-absorption features.

The rating also reflects the likelihood that an INGBT default would
be driven by some form of transfer and convertibility restrictions,
rather than a loss of solvency or liquidity.

The notes' 'RR5' Recovery Rating reflects below-average recovery
prospects in a default.

An NVE is defined as occurring when the bank has incurred losses
and has become, or is likely to become, non-viable as determined by
the local regulator, the Banking and Regulatory Supervision
Authority (BRSA). The bank will be deemed non-viable when it
reaches the point at which either the BRSA determines that its
operating licence is to be revoked and the bank liquidated, or the
rights of shareholders (except to dividends), and the management
and supervision of the bank, should be transferred to the Savings
Deposit Insurance Fund on the condition that losses are deducted
from the capital of existing shareholders.

INGBT's LTFC IDR is driven by shareholder support from ING. Its
view of support reflects INGBT's strategic importance to, and role
within, the wider group, and its small size relative to ING's
ability to provide support.

Rating Sensitivities

Factors that Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade

As the notes are notched down from INGBT's LTFC IDR, their rating
is sensitive to a downgrade of the LTFC IDR. The notes' rating is
also sensitive to an unfavourable revision in Fitch's assessment of
loss severity and non-performance risk.

Factors that Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade

The notes' rating is sensitive to an upgrade of INGBT's LTFC IDR.

Date of Relevant Committee

12 September 2024

Public Ratings with Credit Linkage to other ratings

INGBT's ratings are linked to ING's.

ESG Considerations

INGBT has an ESG Relevance Score of '4' for Management Strategy,
reflecting an increased regulatory burden on all Turkish banks.
Management ability across the sector to determine their own
strategy and price risk is constrained by regulatory burden and
also by the operational challenges of implementing regulations at
the bank level. This has a moderately negative impact on the bank's
credit profiles and is relevant to bank's ratings in combination
with other factors.

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' means ESG
issues are credit-neutral or have only a minimal credit impact on
the entity, either due to their nature or the way in which they are
being managed by the entity. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.

   Entity/Debt       Rating          Recovery   
   -----------       ------          --------   
ING Bank A.S.

   Subordinated   LT B+(EXP) Publish   RR5


TURK EKONOMI: Fitch Assigns CCC+ Rating on USD300MM Tier 1 Notes
----------------------------------------------------------------
Fitch Ratings has assigned Turk Ekonomi Bankasi A.S.'s (TEB;
BB-/Stable/b+) USD300 million additional Tier 1 (AT1) capital notes
a final rating of 'CCC+'.

The final rating is one notch higher than the expected rating
assigned on September 4, 2024, reflecting TEB's VR upgrade to 'b+'
from 'b' following the Turkish sovereign upgrade on September 6,
2024.

Key Rating Drivers

The AT1 notes are rated three notches below TEB's Viability Rating
(VR) of 'b+'. The notching comprises two notches for loss severity
given the notes' deep subordination, and one notch for incremental
non-performance risk given their full discretionary, non-cumulative
coupons.

Fitch has used the bank's VR as anchor rating as Fitch deems it the
most appropriate measure of non-performance risk. In accordance
with the Bank Rating Criteria, Fitch has applied three notches from
TEB's VR, instead of the baseline four notches, due to rating
compression, as TEB's VR is below the 'BB-' threshold.

The notes are Basel III-compliant, perpetual, deeply subordinated,
fixed-rate resettable AT1 debt securities. They have fully
discretionary, non-cumulative coupons and are subject to full or
partial principal write-down if TEB's common equity Tier 1 (CET1)
on a bank-only or group-basis ratio falls below 5.125%. They have a
call option (subject to approval by the Banking Regulation and
Supervision Agency (BRSA)) after five years and on any interest
payment date thereafter.

The notes are also subject to permanent partial or full write-down,
on the occurrence of a non-viability event (NVE). An NVE is when a
bank incurs a loss (on a consolidated or non-consolidated basis)
and the bank becomes, or it is probable that the bank will become,
non-viable as determined by the BRSA. The bank will be deemed
non-viable should it reach the point at which the BRSA determines
its operating license is to be revoked and the bank liquidated, or
the rights of the bank's shareholders (except to dividends), and
the management and supervision of the bank, are transferred to the
Savings Deposit Insurance Fund on the condition that losses are
deducted from the capital of existing shareholders.

TEB's consolidated regulatory CET1 and Tier 1 ratios (including
regulatory forbearance of fixing of exchange rate and cancellation
of M-t-M losses) were both at 9.3%, at end-1H24, above its
regulatory minimum requirements of 7.0% and 8.5%, respectively,
including a capital conservation buffer of 2.5%. Fitch estimates
that the AT1 issue will increase the Tier-1 ratio by 230bp.

Rating Sensitivities

Factors that Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade

As the notes are notched down from TEB's VR, the rating is
sensitive to a downgrade of the VR. This may result, for example,
from a significant decline in capital buffers relative to
regulatory requirements. The notes' rating is also sensitive to an
unfavourable revision in Fitch's assessment of incremental
non-performance risk.

Factors that Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade

The notes' rating is sensitive to an upgrade of TEB's VR but the
notching of the notes' rating could be widened to four should TEB's
VR be upgraded to the 'bb-' threshold and above.

Public Ratings with Credit Linkage to other ratings

TEB's IDRs are driven by shareholder support from its majority
shareholder, BNPP.

ESG Considerations

TEB has an ESG Relevance Score for Management Strategy of '4',
reflecting an increased regulatory burden on the bank. Management
ability across the sector to determine their own strategy and price
risk is constrained by regulatory burden and also by the
operational challenges of implementing regulations at the bank
level. This has a moderately negative impact on the bank's credit
profile and is relevant to the bank's ratings in combination with
other factors.

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' means ESG
issues are credit-neutral or have only a minimal credit impact on
the entity, either due to their nature or the way in which they are
being managed by the entity. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.

   Entity/Debt         Rating             Prior
   -----------         ------             -----
Turk Ekonomi
Bankasi A.S.

   Subordinated    LT CCC+  New Rating    CCC(EXP)


TURK P&I: Fitch Hikes Insurer Fin. Strength Rating to 'BB-'
-----------------------------------------------------------
Fitch Ratings has upgraded Turk P ve I Sigorta A.S.'s (Turk P&I)
Insurer Financial Strength (IFS) rating to 'BB-' from 'B+'. The
Outlook is Stable.

The upgrade follows a recent similar action on Turkiye's sovereign
ratings and Country Ceiling. The sovereign's ratings and Outlook
are factors in its assessment of the insurer's industry profile and
operating environment, company profile and investment risks.

The IFS rating reflects Turk P&I's 'Moderate' company profile
compared with other Turkish insurers, investment risks skewed
towards the Turkish banking sector and exposure to the Turkish
economy, in line with the rest of the market. The rating also
reflects Turk P&I's adequate earnings and weak, but improving,
capitalisation.

Key Rating Drivers

Turkish Marine Specialist: Fitch assesses Turk P&I on its
standalone credit quality, but also considers the ownership
structure, which is equally divided between public and private
interests. Fitch believes the company's ownership and its strategic
role in the Turkish economy are supportive of its credit profile.
Turk P&I, Turkiye's first protection and indemnity (P&I) insurance
provider, also underwrites hull and machinery (H&M) insurance,
which accounted for around 70% of net premiums in 2023.

'Moderate' Business Profile: Turk P&I's 'Moderate' business profile
is underpinned by increasing international diversification, in
addition to its ownership and strategic role in Turkiye, despite
its small size, limited history and less established business
lines. Its business volumes grew strongly in 2023, supported by
local laws, with a higher contribution from its international
business.

Weak but Improving Capitalisation: The insurer's regulatory
solvency ratio weakened to 65% at end-2023 from 90% at end-2022.
This was driven by large claims due to storms in Marmara and the
Black Sea regions, which significantly lowered prior-year profit
and equity, as well as a strong rise in net premiums. Turk P&I
implemented an increase in paid-in capital of TRY200 million in
September 2024 and expects to restore the regulatory solvency ratio
to over 100% by end-2024.

High Exposure to Banking System: Turk P&I's balance sheet comprises
deposits in Turkish banks, with some concentration on a single
state-owned bank as well as bonds issued by the government and
domestic banks. This indicates a high exposure to the domestic
banking sector, in line with the rest of the Turkish insurance
market.

Adequate but Volatile Earnings: The insurer's earnings have been
strong over the past five years and Fitch views its financial
performance and earnings as a rating strength. However, earnings
were reduced in 2H23 by large storm claims. In 1H24, Turk P&I
reported a net income of TRY30 million (1H23: TRY70 million). Its
profitability was strongly influenced by higher investment income
due to sharply higher interest rates in 1H24 and foreign-exchange
(FX) gains. Turk P&I receives most of its premium income and pays
most of its claims in foreign currencies.

RATING SENSITIVITIES

Factors that Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade

- Business risk profile deterioration, for example, due to a sharp
deterioration in the maritime trade environment.

- Downgrade of Turkiye's sovereign rating.

Factors that Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade

- An improvement in the company profile assessment, for example,
due to sustained profitable growth while maintaining its regulatory
solvency ratio comfortably above 100%.

- An upgrade of Turkiye's sovereign rating.

ESG Considerations

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' means ESG
issues are credit neutral or have only a minimal credit impact on
the entity, either due to their nature or the way in which they are
being managed by the entity. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.

   Entity/Debt                   Rating          Prior
   -----------                   ------          -----
Turk P ve I Sigorta A.S.   LT IFS BB- Upgrade    B+


TURKLAND BANK: Fitch Affirms 'B' IDRs, Off Watch Negative
---------------------------------------------------------
Fitch Ratings has affirmed Turkland Bank A.S.'s (T-Bank) Long-Term
Foreign-Currency (LTFC) and Local-Currency (LTLC) Issuer Default
Ratings (IDRs) at 'B ' and removed them from Rating Watch Negative
(RWN). The Outlooks are Stable. Fitch has also affirmed the bank's
Shareholder Support Rating (SSR) at 'b' and removed it from RWN.
Fitch has also upgraded the bank's Viability Rating (VR) to 'b-'
from 'ccc+'.

Fitch has removed the RWN placed in November 2023 as Fitch does not
expect the sale of the bank to progress and be completed (see Fitch
Places Turkland Bank on Rating Watch Negative dated 3 November
2023) and Fitch deems the ability and propensity of Arab Bank Plc
(AB; BB/Stable) to provide support to T-Bank to be unchanged.

The upgrade of T-Bank's VR reflects an improvement in its
standalone credit profile as a reduction in legacy impaired loans
has reduced capital-impairment risks while improved, albeit still
volatile, profitability has improved capitalisation.

The bank's National Rating has been placed on Rating Watch Evolving
(RWE), reflecting a potential revision of the rating if its
National Rating equivalency analysis results in different relative
creditworthiness across Turkish issuers.

Key Rating Drivers

T-Bank's IDRs are driven by potential support from its Jordan-based
50% owner, AB, as reflected by its SSR. The Stable Outlooks on the
IDRs mirror those on AB. Its 'B' Short-Term IDRs are the only
option mapping to LT IDRs in the 'B' category.

T- Bank's 'b-' VR reflects its small size and limited franchise,
still weak, albeit recently improved, asset quality, loans and
deposit concentrations, volatile profitability and still weak, but
improved, capitalisation.

Shareholder Support: T-Bank's SSR considers its 50% ownership by
AB, but also its limited role within the group as Fitch views
Turkiye as a non-core market for AB. It also reflects AB's
classification of T-Bank as an investment held for sale in its
financial statements, which, in its view, indicates a high
potential for disposal, and limits reputational risk for AB,
thereby reducing its propensity to support T-Bank.

Limited Franchise: T- Bank had a 0.1% share of banking sector
assets at end-1H24, resulting in limited pricing power. Lending is
concentrated in the corporate and commercial segment (end-1H24:
100% of gross loans) largely via short-term lira lending.

Capital Pressures Decreasing: T-Bank's common equity Tier 1 (CET1)
ratio rose to 17.0% at end-1H24 (excluding forbearance: 16.0%) from
14.7% at end-2023 (excluding forbearance: 13.5%), supported by
internal capital generation. Pressure on capital through unreserved
impaired loans has reduced (end-1H24: 13% of CET1; end-2023: 18%;
end-2022: 57%; end-2021: 91%).

Capitalisation remains weaker than at peers with higher reserve
coverage of impaired loans. Capitalisation is sensitive to lira
depreciation (due to the inflation of FC risk-weighted assets),
internal capital generation, risks to asset quality, and growth.
Fitch expects the CET1 ratio to be around 12% at end-2024.

Asset-Quality Risks: T-Bank's impaired (Stage 3) loans ratio fell
to 5.5% at end-1H24 (end-2023: 5.8%; end-2022: 19.3%) despite a
contraction in loans, as collections exceeded inflows. The impaired
loans ratio remains higher than the sector average of 1.5%,
reflecting the bank's legacy asset-quality weaknesses. Stage 2
loans are less than 1% of gross loans. Credit risks are heightened
by high borrower concentration - the top 25 cash loans were 64% of
gross loans or 4x CET1 capital - and by FC lending (29% of total
lending), albeit below the sector average of 36% at end-1H24. Fitch
expects the impaired loans ratio to be around 5% at end-2024.

Volatile Profitability: T-Bank's operating profit rose to 8.1% of
risk-weighted assets (RWAs) in 1H24 (sector: 3.8%) from 5.7% in
2023, supported by provision reversals (76% of operating profit) as
trading losses and high operating costs eroded improved net
interest income. The bank has been recording positive
pre-impairment profits since 2022 although it has been volatile
(1H24: 0.9% of average assets; 2023: 4.2%; 2022: 1.8%).

Profitability is sensitive to slower GDP growth, macroeconomic and
regulatory developments, inflationary pressure on costs,
asset-quality risks and growth. Fitch expects operating profit to
decrease to around 2% of RWAs for 2024.

Deposits-Funded; High FC Deposits Share: T-Bank is almost entirely
funded by customer deposits (end-1H24: 99.5% of non-equity
funding), mitigating refinancing risk. The deposit base remains
concentrated with the top 20 depositors at 40% of total customer
deposits at end-1H24. Significant deposit dollarisation (end-1H24:
53% of total customer deposits) and foreign-exchange protected lira
deposits (32%) create FC liquidity risks. FC liquidity fully
covered FC deposits at end-1H24. Fitch expects loans/ deposits to
increase to around 70% at end-2024.

Improving Operating Environment: T-Bank's operations are
concentrated in the improving but still challenging Turkish
operating environment. The normalisation of monetary policy has
reduced near-term macro-financial stability risks and external
financing pressures but banks remain exposed to high inflation,
potential further lira depreciation, slowing economic growth, and
multiple macroprudential regulations, despite simplification
efforts.

Rating Sensitivities

Factors that Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade

T-Bank's IDRs are primarily sensitive to changes in its SSR. The
SSR is sensitive to an adverse change in Fitch's view of AB's
ability and propensity to provide support.

A multi -notch downgrade of Turkiye's sovereign rating would lead
to a downgrade of T- Bank's SSR and, consequently, its Long-Term
IDRs.

T-Bank's VR could be downgraded due to an erosion in the capital
buffer, for instance through significant deterioration of asset
quality and profitability, or a weakening of its FC liquidity
position, if not offset by ordinary shareholder support.

Factors that Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade

An upgrade of the bank's IDRs is unlikely as the bank is classified
as an investment held for sale by AB.

A VR upgrade could stem from a significant improvement in asset
quality that reduces risks to capitalisation alongside a longer
record of improved sustainable profitability and a strengthening of
its business profile.

OTHER DEBT AND ISSUER RATINGS: KEY RATING DRIVERS

The National Long-Term Rating is lower than that of other
foreign-owned banks in Turkiye, reflecting weaker support
propensity.

OTHER DEBT AND ISSUER RATINGS: RATING SENSITIVITIES

The National Rating is sensitive to changes in T-Bank's LTLC IDR
and the RWE would be removed once Fitch has assessed the bank's
creditworthiness relative to that of other Turkish issuers.

VR ADJUSTMENTS

The operating-environment score of 'b+' is below the 'bb' category
implied score due to the following adjustment reason: macroeconomic
volatility (negative).

Public Ratings with Credit Linkage to other ratings

T-Bank's IDRs are linked to ratings of AB.

ESG Considerations

T- Bank has an ESG Relevance Score for Management Strategy of '4',
reflecting a high regulatory burden on most Turkish banks.
Management ability across the sector to determine their own
strategy is constrained by regulatory interventions and also by the
operational challenges of implementing regulations at the bank
level. This has a moderately negative impact on banks' credit
profiles and is relevant to banks' ratings in combination with
other factors.

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' means ESG
issues are credit-neutral or have only a minimal credit impact on
the entity, either due to their nature or the way in which they are
being managed by the entity. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.

   Entity/Debt                     Rating                 Prior
   -----------                     ------                 -----
Turkland
Bank A.S.        LT IDR              B  Affirmed          B
                 ST IDR              B  Affirmed          B
                 LC LT IDR           B  Affirmed          B
                 LC ST IDR           B  Affirmed          B
                 Natl LT    A(tur)Rating Watch Revision   A(tur)
                 Viability           b- Upgrade           ccc+
                 Shareholder Support b  Affirmed          b


[*] Fitch Hikes 3 Turkish Non-Bank Fin. Institutions to 'BB-' IDR
-----------------------------------------------------------------
Fitch Ratings has upgraded the Long-Term Issuer Default Ratings
(IDRs) of three Turkish non-bank financial institutions -
Volkswagen Dogus Finansman A.S. (VDF Finans), VDF Filo Kiralama
A.S. (VDF Filo) and VDF Faktoring A.S. - to 'BB-' from 'B+'. Fitch
has also upgraded their Shareholder Support Ratings (SSRs) to 'bb-'
from 'b+'. The Outlook on the IDRs is Stable.

The issuers' National Ratings are unaffected by the rating actions
but may be reviewed if Fitch's National Ratings equivalency
analysis results in different relative creditworthiness across
Turkish issuers.

The rating actions follow the upgrade of Turkiye's Long-Term IDRs
and Country Ceiling dated September 6, 2024.

Key Rating Drivers

Support-Driven Ratings: The three companies' ratings are driven by
support from their controlling shareholder, Volkswagen Financial
Services Overseas AG (VWFSO, A-/Stable), reflected in their SSRs of
'bb-'. Fitch views these subsidiaries as strategically important,
given their mandate to complement and support Volkswagen's (VW)
operations in Turkiye.

Ratings Constrained by Country Ceiling: The companies' Long-Term
IDRs and SSRs are constrained by Turkiye's 'BB-' Country Ceiling as
expressed by their SSR of 'bb-'. The Country Ceiling captures
transfer and convertibility risks and limits the extent to which
support from VWFSO can be factored into the IDRs. The Stable
Outlook on the IDR mirrors that on Turkiye's sovereign ratings.

Joint-Venture Structure: Ownership of the VDF entities is split,
with 51% held by VW (through VWFSO) and the remaining 49% by Dogus
Group. Dogus is a major Turkish conglomerate involved in various
sectors and is also the exclusive importer of VW vehicles in
Turkiye.

All three companies rely heavily on VW activity in Turkiye as they
conduct most of their business activities within the group or with
VW group car dealers. In addition, VWFSO provides a significant
portion of their financing. Fitch believes VWFSO would provide
financial support to VDF entities when needed.

RATING SENSITIVITIES

Factors that Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade

- The Long-Term IDRs and SSRs would be likely to be downgraded on a
downgrade of Turkiye's Country Ceiling.

- Changes in the propensity of support from VWFSO, for example as a
result of dilution of ownership, a loss of operational control or
diminishing importance of the Turkish market, could also trigger a
downgrade of the IDRs and SSRs.

- Deterioration of the companies' creditworthiness relative to
other Turkish issuers would be likely to trigger a downgrade in the
National Ratings.

Factors that Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade

- An upgrade of Turkiye's Country Ceiling as a result of a
sovereign rating upgrade would be likely to be reflected in the
three companies' IDRs.

Public Ratings with Credit Linkage to other ratings

The ratings are driven by VWFSO's potential support and constrained
by Turkiye's country ceiling.

ESG Considerations

Except for the matters discussed above, the highest level of ESG
credit relevance, if present, is a score of 3. This means that
other ESG issues are credit neutral or have only a minimal credit
impact, either due to their nature or to the way in which they are
being managed. Fitch's ESG Relevance Scores are not inputs in the
rating process; they are an observation of the materiality and
relevance of ESG factors in the rating decision.

   Entity/Debt                        Rating           Prior
   -----------                        ------           -----
Volkswagen Dogus
Finansman A.S.      LT IDR              BB- Upgrade    B+
                    ST IDR              B   Affirmed   B
                    Shareholder Support bb- Upgrade    b+

VDF Filo
Kiralama A.S.       LT IDR              BB- Upgrade    B+
                    ST IDR              B   Affirmed   B
                    Shareholder Support bb- Upgrade    b+

VDF Faktoring A.S.  LT IDR              BB- Upgrade    B+
                    ST IDR              B   Affirmed   B
                    Shareholder Support bb- Upgrade    b+


[*] Fitch Hikes IDRs on 11 Turkish Non-Bank Entities to 'BB-'
-------------------------------------------------------------
Fitch Ratings has upgraded the Long-Term Foreign-Currency (LTFC)
Issuer Default Ratings (IDRs) of 11 Turkish non-bank financial
institutions (NBFIs) to 'BB-' from 'B', and upgraded the LTFC IDR
of Istanbul Takas ve Saklama Bankasi A.S. (Takasbank) to 'BB-' from
'B+'. Fitch has also upgraded the Long-Term Local-Currency (LTLC)
IDRs of 12 NBFI's to 'BB-' from 'B+'. All Outlooks are Stable.

The issuers' National Ratings are unaffected by the rating actions,
but may be reviewed if Fitch's National Ratings equivalency
analysis results in a different relative creditworthiness across
Turkish issuers.

The rating actions follow the upgrade of Turkiye's Long-Term IDRs
and Country Ceiling, and subsequent rating actions on the parent
banks.

The issuers affected by the rating action include Takasbank and
NBFI subsidiaries of Turkish commercial banks which are:

Ak Finansal Kiralama A.S. (Ak Leasing),
Alternatif Finansal Kiralama A.S. (Alternatif Leasing)
Deniz Finansal Kiralama A.S. (Deniz Leasing)
Garanti Faktoring A.S. (Garanti Faktoring)
Garanti Finansal Kiralama A.S. (Garanti Leasing)
Is Finansal Kiralama Anonim Sirketi (Is Leasing)
QNB Finans Faktoring A.S. (QNB Faktoring)
QNB Finans Finansal Kiralama A.S. (QNB Leasing)
Yapi Kredi Faktoring A.S. (Yapi Kredi Faktoring)
Yapi Kredi Finansal Kiralama A.O. (Yapi Kredi Leasing)
Yapi Kredi Yatirim Menkul Degerler A.S. (Yapi Kredi Yatirim)

Key Rating Drivers

Bank-owned Subsidiaries Driven by Support: The LT IDRs and
Shareholder Support Ratings (SSRs) of the 11 bank-owned NBFIs are
equalised with those of their respective parents, reflecting
Fitch's view that they are core and highly integrated subsidiaries.
The upgrades reflect the improvement in these banks' standalone
strength as well as the positive impact of the improving operating
environment on their credit profiles.

High Support Propensity: The NBFI subsidiaries of the Turkish banks
offer core products and services (leasing, factoring and investment
services) in the domestic market. The cost of support would be
limited as the subsidiaries are small compared with their parents
and their total assets usually do not exceed 3% of group assets.
The ratings of the NBFI subsidiaries reflect their close
integration with their parents, the reputational risks of the
subsidiaries' defaults for their broader groups and their ultimate
full or majority ownership by their respective parent.

Fitch is not able to assess the subsidiaries' intrinsic strengths,
as all companies are highly integrated into their respective
parents and their franchises rely heavily on their parents.

Government Support Drives Takasbank Ratings: The upgrades of
Takasbank's LT IDRs are driven by the upgrade of its Government
Support Rating (GSR) to 'bb-' from 'b+'. The upgrade of its GSR
follows the upgrade of the sovereign IDRs, which reflects an
improvement in sovereign's ability to provide support. The Stable
Outlooks mirror the sovereign's.

Takasbank Systemically Important for Turkiye: Fitch views Takasbank
as having exceptionally high systemic importance for the Turkish
financial sector. Contagion risk from a Takasbank default would be
high, given the bank's interconnectedness with the wider Turkish
financial sector as Turkiye's only central counterparty clearing
house (CCP). Fitch believes that the ability of the Turkish
sovereign to support Takasbank is stronger than for systemically
important domestic banks, as Takasbank has no corporate debt and
has only a minor direct FC exposure. Takasbank is majority
state-owned, via Borsa Istanbul A.S., Turkiye's main stock
exchange.

RATING SENSITIVITIES

Factors that Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade

NBFI subsidiaries of the Turkish banks:

The LT IDRs are sensitive to a downgrade of their parents' LT IDRs
or to a deterioration in the operating environment, which, for
example, could be triggered by a sovereign downgrade.

The ratings could be notched down from their parents on material
deterioration in the parents' propensity or ability to provide
support or if the subsidiaries become materially larger relative to
the parents' ability to support. The ratings could also be notched
down from their parents' if the subsidiaries' strategic importance
is materially reduced through, for example, a substantial reduction
in operational and management integration or ownership, or a
prolonged period of under-performance.

Takasbank:

A downgrade of Turkiye's sovereign ratings would be mirrored in
Takasbank's IDRs. A deterioration in the sovereign's propensity to
provide support due to an adverse change in Takasbank's systemic
importance or reduced ownership (through privatisation) would also
be reflected in its IDRs and GSR.

Factors that Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade

NBFI subsidiaries of the Turkish banks:

Upgrades of the parents' ratings or a revision of the Outlooks
would be reflected in the subsidiaries' ratings.

Takasbank:

A positive rating action on Turkiye's sovereign ratings would be
mirrored in Takasbank's LT IDRs.

Public Ratings with Credit Linkage to other ratings

The entities' ratings are linked to their parent bank's ratings.

ESG Considerations

NBFI subsidiaries of the Turkish banks have an ESG Relevance Score
of '4' for Management Strategy in line with their respective
parents' Management and Strategy ESG Relevance Score. This reflects
the high regulatory burden on most Turkish banks. The management's
ability to determine strategy is constrained by regulations and
creates an additional operational burden for the respective parent
banks. The alignment reflects Fitch's view of high integration.

Takasbank has an ESG Relevance Score of '4' for Governance
Structure due to government influence over the board's strategy and
governance, which has a negative impact on the credit profile, and
is relevant to the ratings in conjunction with other factors.

Except for the matters discussed above, the highest level of ESG
credit relevance, if present, is a score of '3'. This means that
other ESG issues are credit neutral or have only a minimal credit
impact, either due to their nature or to the way in which they are
being managed. Fitch's ESG Relevance Scores are not inputs in the
rating process; they are an observation of the materiality and
relevance of ESG factors in the rating decision.

   Entity/Debt                          Rating           Prior
   -----------                          ------           -----
Is Finansal Kiralama
Anonim Sirketi        LT IDR              BB- Upgrade    B
                      ST IDR              B   Affirmed   B
                      LC LT IDR           BB- Upgrade    B+
                      LC ST IDR           B   Affirmed   B
                      Shareholder Support bb- Upgrade    b

QNB Finans Finansal
Kiralama A.S.         LT IDR              BB- Upgrade    B
                      ST IDR              B   Affirmed   B
                      LC LT IDR           BB- Upgrade    B+
                      LC ST IDR           B   Affirmed   B
                      Shareholder Support bb- Upgrade    b

Ak Finansal
Kiralama A.S.         LT IDR              BB- Upgrade    B
                      ST IDR              B   Affirmed   B
                      LC LT IDR           BB- Upgrade    B+
                      LC ST IDR           B   Affirmed   B
                      Shareholder Support bb- Upgrade    b

Yapi Kredi Finansal
Kiralama A.O.         LT IDR              BB- Upgrade    B
                      ST IDR              B   Affirmed   B
                      LC LT IDR           BB- Upgrade    B+
                      LC ST IDR           B   Affirmed   B
                      Shareholder Support bb- Upgrade    b
Alternatif Finansal
Kiralama A.S.         LT IDR              BB- Upgrade    B
                      ST IDR              B   Affirmed   B
                      LC LT IDR           BB- Upgrade    B+
                      LC ST IDR           B   Affirmed   B
                      Shareholder Support bb- Upgrade    b

Garanti Finansal
Kiralama A.S.         LT IDR              BB- Upgrade    B
                      ST IDR              B   Affirmed   B
                      LC LT IDR           BB- Upgrade    B+
                      LC ST IDR           B   Affirmed   B
                      Shareholder Support bb- Upgrade    b

Yapi Kredi
Faktoring A.S.        LT IDR              BB- Upgrade    B
                      ST IDR              B   Affirmed   B
                      LC LT IDR           BB- Upgrade    B+
                      LC ST IDR           B   Affirmed   B
                      Shareholder Support bb- Upgrade    b

Istanbul Takas ve
Saklama Bankasi A.S.  LT IDR              BB- Upgrade    B+
                      ST IDR              B   Affirmed   B
                      LC LT IDR           BB- Upgrade    B+
                      LC ST IDR           B   Affirmed   B
                      Government Support  bb- Upgrade    b+

QNB Finans
Faktoring A.S.        LT IDR              BB- Upgrade    B
                      ST IDR              B   Affirmed   B
                      LC LT IDR           BB- Upgrade    B+
                      LC ST IDR           B   Affirmed   B
                      Shareholder Support bb- Upgrade    b

Yapi Kredi Yatirim
Menkul Degerler A.S.  LT IDR              BB- Upgrade    B
                      ST IDR              B   Affirmed   B
                      LC LT IDR           BB- Upgrade    B+
                      LC ST IDR           B   Affirmed   B
                      Shareholder Support bb- Upgrade    b

Deniz Finansal
Kiralama A.S.         LT IDR              BB- Upgrade    B
                      ST IDR              B   Affirmed   B
                      LC LT IDR           BB- Upgrade    B+
                      LC ST IDR           B   Affirmed   B
                      Shareholder Support bb- Upgrade    b

Garanti Faktoring
A.S.                  LT IDR              BB- Upgrade    B
                      ST IDR              B   Affirmed   B
                      LC LT IDR           BB- Upgrade    B+
                      LC ST IDR           B   Affirmed   B
                      Shareholder Support bb- Upgrade    b


[*] Fitch Upgrades 24 Turkish Banks on Sovereign Upgrade
--------------------------------------------------------
Fitch Ratings has upgraded 12 Turkish banks' Long-Term
Foreign-Currency (LTFC) Issuer Default Ratings (IDRs) to 'BB-' from
'B', seven banks' LTFC IDRs to 'B+' from 'B' and five banks' LTFC
IDRs to 'B' from 'B-'. The Outlooks for banks with 'BB-' LTFC IDRs
have been revised to Stable from Positive, while banks with 'B+'
LTFC IDRs driven by their Viability Ratings (VRs) remained on
Positive Outlooks, and the Outlooks for banks driven by government
support were revised to Stable. Most 'B' LTFC IDRs remained on
Positive Outlooks. Fitch has also upgraded the VRs of 16 banks.

Fitch has also upgraded AB Kazakhstan - Ziraat International Bank
JSC's (KZI) support driven LTFC and LTLC IDRs to 'B+' from 'B' with
Stable Outlook.

The Involved Entities are:

Turkiye Sinai Kalkinma Bankasi A.S.
Turkiye Emlak Katilim Bankasi A.S.
ING Bank A.S.
Turkiye Halk Bankasi A.S.
Denizbank A.S.

KT21 T2 Company Limited
Albaraka Turk Katilim Bankasi A.S.
Albaraka MTN Ltd
QNB Finansbank Anonim Sirketi
Turkiye Finans Katilim Bankasi A.S.

Turk Ekonomi Bankasi A.S.
AKBANK T.A.S.
Arap Turk Bankasi A.S.
Anadolubank A.S.
Sekerbank T.A.S.

Yapi ve Kredi Bankasi A.S.
Turkiye Is Bankasi A.S.
Turkiye Garanti Bankasi A.S.
AB Kazakhstan - Ziraat International Bank JSC
Kuveyt Turk Katilim Bankasi A.S

Turkiye Ihracat Kredi Bankasi A.S.
Turkiye Kalkinma ve Yatirim Bankasi A.S.
Fibabanka Anonim Sirketi
Vakif Katilim Bankasi A.S.
Ziraat Katilim MTN Limited

Turkiye Cumhuriyeti Ziraat Bankasi Anonim Sirketi
Ziraat Katilim Bankasi A.S.
Turkiye Vakiflar Bankasi T.A.O.
Ziraat Katilim Varlik Kiralama A.S.

The Government Support Ratings (GSRs) of five state-owned banks
T.C. Ziraat Bankasi A.S. (Ziraat), Turkiye Vakiflar Bankasi T.A.O.
(Vakif), Turkiye Halk Bankasi A.S. (Halk), Turkiye Emlak Katilim
Bankasi A.S. (Emlak Katilim) and Vakif Katilim Bankasi A.S. (Vakif
Katilim), and of privately owned development bank Turkiye Sinai
Kalkinma Bankasi A.S. (TSKB), have been upgraded to 'b+' from 'b-'.
The GSRs of three privately owned systemically important banks have
also been upgraded to 'b-' from 'ns' (no support).

The rating actions follow the upgrade of Turkiye's Long-Term IDR to
'BB-' from 'B+' dated September 6, 2024.  The sovereign upgrade
reflects improved external buffers evidenced by Turkiye's
strengthened foreign-exchange (FX) reserves position, underpinned
by reduced financial dollarisation and FX demand, capital inflows
and increased access to external borrowing. Positive real interest
rates, low current account deficits and the orderly and gradual
decline in FX-protected deposits will likely support the durability
of the improvement in external buffers.

The sovereign upgrade also considers Turkiye's reduced contingent
liabilities, partly reflecting the decline in FX-protected
deposits.

These factors have resulted in a significant reduction in near-term
financial stability risks evidenced by the banks' increased
external market access in recent months, lower risk premiums, the
elimination of banking sector FX swaps with the central bank and
the gradual decline in FX and FX-protected deposits. The latter
fell to 39% and 9% of banking sector deposits, respectively, at
end-August 2024, from 42% and 26% at end-August 2023.

Consequently, its view of the likelihood of government intervention
in the banking system has reduced to the point that Fitch no longer
consider it appropriate to notch Turkish banks' LTFC IDRs one notch
below Turkiye's LTFC IDR (the exception has been the policy bank,
Turkiye Kalkinma ve Yatirim Bankasi A.S. (TKYB), which has been
equalised with the sovereign). This approach has, hitherto,
reflected its view of a higher likelihood of government
intervention in the banking system than the of a sovereign
default.

Along with the sovereign upgrade, the removal of the one notch for
government intervention risk drives the two-notch upgrade of seven
foreign-owned support driven banks' LTFC IDRs to 'BB-' from 'B'.
The banks include: Denizbank A.S. (Denizbank), ING Bank A.S.
(INGBT), Kuveyt Turk Katilim Bankasi A.S (Kuveyt Turk), QNB
Finansbank A.S. (QNBF), Turk Ekonomi Bankasi A.S. (TEB), Turkiye
Finans Katilim Bankasi A.S. (Turkiye Finans) and Turkiye Garanti
Bankasi A.S. (Garanti BBVA) as well as three large privately owned
banks (VR-driven) Akbank T.A.S.(Akbank), Turkiye Is Bankasi A.S.
(Isbank) and Yapi ve Kredi Bankasi A.S. (YKB). The Outlooks are
Stable mirroring the sovereign.

The LTFC IDRs of two state-owned development banks, Turkiye Ihracat
Kredi Bankasi A.S. (Turk Eximbank) and TKYB, were upgraded to 'BB-'
as a result of the upward revision of their GSRs, reflecting the
sovereign's stronger ability to provide support. The LTFC IDRs of
Halk; Vakif Katilim and Emlak Katilim have been upgraded to 'B+'
from 'B-' following the upgrade of their GSRs. The Outlooks on all
banks' IDRs have been revised to Stable mirroring the sovereign,
excluding Halk, which remains on RWN.

Also, the LTFC IDRs of the two state-owned banks Ziraat and Vakif
and privately owned development bank TSKB have been upgraded to
'B+' from 'B' following the upgrade of their VRs. The Outlooks are
Positive, reflecting the improving operating environment and the
impact of this on their business profiles.

Also, five small privately owned Turkish banks, with LTFC IDRs
driven by VRs, have been upgraded to 'B' from 'B-', including
Albaraka Turk Katilim Bankasi A.S. (Albaraka), Arap Turk Bankasi
A.S. (ATB), Anadolubank A.S. (Anadolu), Fibabanka Anonim Sirketi
(Fiba) and Sekerbank T.A.S. (Seker). The Outlook on Albaraka has
been revised to Stable, while the remaining banks remained on a
Positive Outlook.

Fitch has also placed the VRs of five participation banks on Rating
Watch Positive (RWP), including Turkiye Finans and Kuveyt Turk
(BB-/Stable), and Emlak Katilim, Vakif Katilim (B+/Stable) and
Ziraat Katilim (B+/Positive).

All banks' National Ratings (NRs) are unaffected by these rating
actions and may be reviewed once and if its NR equivalency analysis
results in different relative creditworthiness across Turkish
issuers.

Key Rating Drivers

VRs (Akbank; ATB; Anadolubank; Denizbank; Fiba; Emlak Katlim,
Ziraat Katilim, INGBT; Kuveyt Turk; Albaraka; Vakif Katilim; QNBF;
Ziraat; TEB; Turkiye Finans; Garanti BBVA; Isbank; TSKB; Vakif; and
YKB)

The VR upgrades capture the improvement in the operating
environment as reflected in the revision of the operating
environment score for Turkish banks to 'b+'/Positive from
'b'/Positive. This reflects the reduction in macro-economic and
financial stability risks and external financing pressures on
banks' standalone credit profiles, supported by policy
normalisation and greater exchange-rate stability, investor
confidence and external market access, notwithstanding the
still-high inflation, slowing economic growth, the high
interest-rate environment and a still challenging macroprudential
environment.

The VRs of the four large, domestic systemically important banks,
Akbank, Garanti BBVA, Isbank and YKB, have been upgraded to 'bb-'
from 'b+'. At this rating level, their VRs remain one notch above
the 'b+' operating environment score, reflecting their significant
FC liquidity buffers, strong external market access, and solid
business profiles, evidenced by generally resilient financial
metrics and significant domestic franchises (market shares by total
assets at 8%-10% at end-1H24).

The VRs of the two large state-owned commercial banks, Ziraat and
Vakif, have been upgraded to 'b+' from 'b'. As the largest
state-owned banks in Turkiye, Fitch views their credit profiles and
the strength of their capital and FC liquidity buffers as
commensurate with, but not above, the risks of the Turkish
operating environment, notwithstanding their significant market
shares (ranked first and second by total assets, respectively). The
banks' VRs also consider their reasonable asset quality, above
peers' risk appetite - albeit this has reduced slightly in recent
months - and below sector-average profitability.

The VRs of Denizbank, INGBT, QNBF and TEB, four mid-sized foreign
owned banks, have been upgraded to 'b+' from 'b'. The upgrades
reflect their moderate franchises and record of adequate
profitability, ordinary support in the case of capitalisation and
FC liquidity, and asset quality, which Fitch views as only
commensurate with the risks of the operating environment.

The VRs of Albaraka, Anadolubank, Fiba, Seker and ATB have been
upgraded to 'b' from 'b-'. This reflects its view that the
improvement in operating environment conditions will strengthen the
banks' standalone creditworthiness and support generally reasonable
financial metrics, despite their limited franchises. The upgrades
also consider below sector-average leverage ratios in the case of
Albaraka and Fiba.

The VR of TSKB, the privately owned development bank, has been
upgraded to 'b+' from 'b', reflecting its view that the bank's
standalone credit profile is commensurate with Turkish
operating-environment risks. The bank's VR considers its niche
policy role and development focus, fairly consistent performance
and adequate capitalisation and FC liquidity, but also its highly
dollarised balance sheet.

The RWP on the 'b-' VRs of Turkiye Finans, Kuveyt Turk, Emlak
Katilim, Vakif Katilim and Ziraat Katilim reflects the likely
positive impact of the improvement in operating environment
conditions on the banks' business and financial profiles amid a
reduction in macro stability risks. Fitch plans to resolve the RWP
on the VRs before end-2024.

LONG-TERM IDRs, GSRs AND SENIOR DEBT RATINGS OF STATE-OWNED
COMMERCIAL BANKS AND DEVELOPMENT BANKS (Ziraat; Vakif; Vakif
Katilim; TSKB; Turk Eximbank; TKYB; Emlak Katilim and Halk)

The LTFC IDRs of Ziraat, Vakif and TSKB, have been upgraded to 'B+'
from 'B' following the upgrade of their VRs. At the same time,
their GSRs have also been upgraded to 'b+' from 'b-'. The LTFC IDRs
of Vakif Katilim, Emlak Katilim and Halk have been upgraded to 'B+'
from 'B-' following the upgrade of their GSRs to 'b+' from 'b-'.

Nevertheless, the banks' GSRs remain one notch below the sovereign
LTFC IDR despite a high propensity to provide support - given the
banks' state ownership (except for TSKB, privately owned), policy
roles (Ziraat and TSKB), systemic importance (Ziraat and Vakif),
state-related or state-guaranteed funding (TSKB), the strategic
importance of participation banking to the authorities (Emlak
Katilim, Vakif Katilim) and the record of capital support
(excluding TSKB). This reflects the sovereign's still moderate,
although improved, reserves position relative to the banks'
material sizes.

The Outlooks on Ziraat, Vakif and TSKB remain Positive, and the
remaining banks' Outlooks have been revised to Stable.

Fitch has maintained Halk's ratings on Rating Watch Negative (RWN)
following the upgrade of its LTFC IDR, reflecting the material risk
of the bank becoming subject to a fine or other punitive measure as
a result of ongoing US legal proceedings, and uncertainty over the
sufficiency and timeliness of support from the authorities, if
needed. Fitch expects to resolve the RWN once there is clarity on
the outcome of the US investigations and the implications this may
have for the bank. Fitch may maintain the RWN for longer than six
months if the US investigations are extended for a longer period.

The LTFC IDRs of TKYB and Turk Eximbank are driven by their GSRs
and have been upgraded to 'BB-', from 'B+' (TKYB) and 'B' (Turk
Eximbank), respectively. The Stable Outlook on both banks reflects
that on the sovereign.

TKYB's 'BB-' LTFC IDR continues to be equalised with the sovereign
rating at the higher sovereign rating level, reflecting the bank's
small size relative to sovereign resources, still largely
treasury-guaranteed funding base and the medium-term tenor of its
non-guaranteed funding, as a result of which its potential need for
support in the near term should be limited.

In addition, Turk Eximbank's GSR has been upgraded by two notches,
to 'bb-'. As a result, and notwithstanding its considerably larger
balance sheet and volumes of external market funding relative to
the sovereign, it is also now equalised with Turkiye's sovereign
rating. The two-notch upgrade reflects the strengthening in the
sovereign's financial flexibility in FC, and considers Turk
Eximbank's strategic policy role as the country's export credit
agency.

The senior unsecured debt/sukuk ratings of Ziraat, Vakif, Turk
Eximbank, Ziraat Katilim (issued through its SPV) and TSKB have
been upgraded in line with the banks' LTFC IDRs.

The LT Local-Currency (LC) IDRs of state-owned commercial banks
(Ziraat, Vakif, Halk, Emlak Katilim and Vakif Katilim), development
banks (TKYB and Eximbank) and privately owned development bank
TSKB, are driven by government support and have been upgraded to
'BB-' from 'B+' with Stable Outlooks, in line with the sovereign
LTLC IDR, and remain one notch above their LTFC IDRs (except for
Eximbank and TKYB). Halk's LTLC IDR remains on RWN due to the US
legal case.

TSKB's Shareholder Support Rating (SSR) has been upgraded to 'b+'
from 'b-' following the upgrade of its parent, Isbank, to
'BB-'/Stable. It remains one notch below its parent's rating
reflecting TSKB's niche business model and Isbank group's only
51.4% stake in the bank.

All banks' Short-Term (ST) IDRs have been affirmed at 'B', which is
the only possible option for LT IDRs in the 'BB- and B' rating
categories. Halk's ST IDR remains on RWN.

IDRs, GSRs AND SENIOR UNSECURED DEBT RATINGS OF PRIVATELY OWNED
TURKISH BANKS (Akbank; Isbank and YKB)

The 'BB-' LTFC and LTLC IDRs of Akbank; Isbank and YKB are driven
by their VRs and are in line with Turkiye's LTFC IDR. The banks'
VRs of 'bb-', one notch above the 'b+' operating environment score,
reflect their significant FC liquidity buffers, resilient financial
metrics and solid domestic franchises. The revision of the Outlooks
on the banks to Stable from Positive reflects the sovereign
outlook.

The senior unsecured debt ratings of Akbank, Isbank and YKB have
been upgraded in line with their LTFC IDRs.

The banks' 'B' ST IDRs are the only possible option for LT IDRs in
the 'BB-' rating category.

The GSRs of Akbank, Isbank and YKB have been upgraded to 'b-' from
'ns', reflecting the improvement in the sovereign's external
finances and financial flexibility to provide support in FC along
with the banks' systemic importance. Still, their GSRs remain three
notches below the sovereign LTFC IDR given Turkiye's still modest
reserves and the banks' private ownership.

IDRs, SSRs AND SENIOR UNSECURED DEBT RATINGS OF FOREIGN-OWNED BANKS
(Garanti BBVA; INGBT; QNBF; TEB; Denizbank; Kuveyt Turk and Turkiye
Finans)

The LTFC IDRs of INGBT, QNBF; TEB; Denizbank; Kuveyt Turk and
Turkiye Finans are driven by potential shareholder support based on
their strategic importance, to varying degrees, integration, roles
within their respective groups and, common branding and legal
commitments in some cases. At the 'BB-' level, Garanti BBVA's LTFC
IDR is underpinned by its VR.

The upgrade of the seven banks' LTFC IDRs to 'BB-', in line with
Turkiye's LTFC IDR and Country Ceiling, reflects Fitch's view of a
reduction in government intervention risk for Turkish banks given
the improvement in Turkiye's external finances. The LTLC IDRs of
these banks are in line with their LTFC IDRs. The Stable Outlooks
on all foreign-owned banks' IDRs mirror those on the sovereign.

The banks' LT senior debt ratings, where assigned (Garanti BBVA,
QNBF, Denizbank, TEB), are aligned with their LTFC IDRs. The
Recovery Rating of the notes is 'RR4', reflecting average recovery
prospects in a default.

The banks' 'B' ST IDRs are the only possible option mapping to LT
IDRs in the 'BB-' rating category.

LONG-TERM IDRs AND SENIOR DEBT RATINGS OF SMALL PRIVATELY OWNED
TURKISH BANKS (Albaraka; ATB; Anadolubank; Fiba and Seker)

The IDRs of the five small, privately owned Turkish banks, are
driven by their VRs and have been upgraded to 'B' from 'B-',
reflecting the improvement in the operating environment. The
Outlook on Albaraka has been revised to Stable while the Outlooks
remain Positive for ATB, Anadolubank, Fiba and Seker, reflecting
the outlook on the operating environment and its expectation that
this should positively affect the banks' intrinsic credit profiles,
and particularly their financial and business profiles, over the
medium term.

The banks' 'B' ST IDRs have been affirmed at 'B', the only possible
option for LT IDRs in the 'B' rating category.

The banks' GSRs of 'ns' reflect its view that state support cannot
be relied upon, in case of need, given the banks' limited systemic
importance. In ATB's case, support from shareholders, while
possible, also cannot be relied upon given the political situation
in Libya.

Rating Sensitivities

Factors that Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade

All Banks' VRs

All banks' VRs are sensitive to a weakening in the operating
environment beyond its base case.

All banks' VRs are sensitive to a sovereign downgrade, although
this is not its base case.

The 'bb-' VRs of Akbank, Garanti BBVA, Isbank and YKB would also be
downgraded on a material erosion in the banks' capital and FC
liquidity for example, due to a weakening in financial performance
and asset quality.

The 'b+' VRs of Ziraat, Vakif and TSKB are primarily sensitive to
the Turkish operating environment. Also, Ziraat and Vakif's VRs are
potentially sensitive to government influence over their management
of balance sheets and particularly if this increases pressures on
the banks' risk profiles. The VRs could be downgraded due to a
material erosion of the banks' FC liquidity buffers, or of their
capital buffers, if not offset by government support.

The 'b+' VRs of Denizbank, QNBF, INGBT and TEB are also primarily
sensitive to the operating environment and could also be downgraded
in case of a material deterioration in their FC liquidity and
capital buffers, potentially due to a weakening in financial
performance and asset quality, if not offset by shareholder
support.

The 'b' VRs of Albaraka, ATB, Anadolubank, Fiba and Seker are also
primarily sensitive to a weakening in the operating environment as
well as to the erosion of their capital buffers most likely due to
asset-quality weakening or pressure on profitability and FC
liquidity positions.

The 'b-' VRs of Kuveyt Turk, TFKB, Emlak Katilim, Vakif Katilim and
Ziraat Katilim are sensitive to a multi-notch sovereign downgrade.

Halk's VR could also be downgraded if, as a result of the US
investigations, it becomes subject to a fine or other punitive
measure that materially weakens its solvency or negatively affects
its standalone credit profile. The removal of the bank's rating
from RWN is dependent upon increased certainty that the outcome of
the investigations will not materially weaken Halk's capital, or
other aspects of its credit profile.

LT IDRs AND GSRs OF TKYB AND TURK EXIMBANK AND SENIOR UNSECURED
DEBT RATING OF TURK EXIMBANK

The LT IDRs and GSRs of Turk Eximbank and TKYB are primarily
sensitive to a sovereign downgrade, but also to a change in the
ability or propensity of the authorities to provide support.

TKYB's GSR could be downgraded if the bank's proportion of
non-guaranteed funding increases materially - particularly if Fitch
believes this to be indicative of a weakening in TKYB's policy role
- or if its balance-sheet size sharply increases relative to
sovereign resources.

Turk Eximbank's GSR could be downgraded in case of a material
weakening in the sovereign's ability to provide support in FC or in
its policy role, but this is not its base case.

The banks' ST IDRs are sensitive to a multi-notch downgrade of
their respective IDRs.

Turk Eximbank's senior unsecured debt ratings are sensitive to a
negative change in its IDRs.

LONG-TERM IDRs, GSRs, SSR (TSKB) AND SENIOR UNSECURED DEBT RATINGS
OF STATE-OWNED COMMERCIAL AND PARTICIPATION BANKS AND DEVELOPMENT
BANKS (Ziraat, Vakif, Halk, Vakif Katilim, Emlak Katilim and TSKB)

All six banks' GSRs are sensitive to a sovereign downgrade and to a
weakening in the ability and propensity of the authorities to
provide support (not its base case).

The LTFC IDRs of Ziraat, Vakif and TSKB are sensitive to a
downgrade of both their VRs and GSRs. The banks' LTFC IDRs would
only be downgraded if their VRs and GSRs were simultaneously
downgraded.

The LTFC IDRs of Halk, Vakif Katilim and Emlak Katilim are
sensitive to a change in their GSRs.

The RWN on Halk's IDRs reflects uncertainty surrounding the
sufficiency and timeliness of support from the Turkish authorities
in case of the bank becoming subject to a fine or other punitive
measure as a result of the US legal proceedings.

The LTLC IDRs of Ziraat, Halk, Vakif, Vakif Katilim, Emlak Katilim
and TSKB are primarily sensitive to a downgrade of the sovereign's
LTLC IDR, and also a change in the ability or propensity of the
authorities to provide support in LC.

TSKB's SSR is sensitive to a change in Isbank's LTFC IDR, Fitch's
view of the parent's ability and propensity to provide support and
the strategic importance of TSKB to its parent.

All banks' senior unsecured debt ratings, where relevant, are
primarily sensitive to changes in their respective IDRs.

ST IDRs are sensitive to multi-notch downgrade of their respective
IDRs.

LONG-TERM IDRs AND SENIOR UNSECURED DEBT RATINGS OF PRIVATELY OWNED
TURKISH BANKS (Akbank, Isbank, YKB, Albaraka, Seker, Fiba, ATB and
Anadolubank)

The IDRs of all privately owned Turkish banks are sensitive to
negative changes in their respective VRs. In the case of Akbank,
Isbank and YKB, which have VRs are at the sovereign level, they are
also sensitive to a sovereign downgrade.

An increase in its view of government intervention risk would
likely also lead to downgrades of the banks' LTFC IDRs, although
this is not its base case.

The banks' senior unsecured debt ratings, where relevant, are
sensitive to changes in their respective IDRs.

ST IDRs are sensitive to a multi-notch downgrade of their
respective IDRs.

LONG-TERM IDRs, SSRs AND SENIOR UNSECURED DEBT RATINGS OF
FOREIGN-OWNED BANKS (Garanti BBVA, INGBT, QNBF, TEB, Deniz, Kuveyt
Turk, Turkiye Finans)

A sovereign downgrade or an increase in its view of government
intervention risk would likely lead to downgrades of the seven
foreign-owned banks' SSRs and, therefore, LT IDRs, although this is
not its base case.

The banks' SSRs are also sensitive to Fitch's view of their
respective shareholders' ability and propensity to provide
support.

The banks' senior unsecured debt ratings, where assigned, are
sensitive to changes in their IDRs.

Factors that Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade

LT IDRS AND GSRs OF TKYB AND TURK EXIMBANK AND SENIOR UNSECURED
DEBT RATING OF TURK EXIMBANK

A positive change in Turkiye's sovereign ratings would likely lead
to similar actions on these banks' LT IDRs and GSRs.

Turk Eximbank's senior unsecured debt ratings are sensitive to a
positive change in its IDRs.

VRs, GSRS, LT IDRs of Ziraat, Vakif, Halk, TSKB, Emlak Katilim,
Vakif Katilim and Ziraat Katilim (VR only), and SENIOR UNSECURED
DEBT RATINGS of Ziraat, Vakif and TSKB; SSR of TSKB

Upside for banks' VRs (Ziraat, Vakif, Halk and TSKB only) is
constrained by their exposure to Turkish operating environment
risks. An upgrade of the operating environment score, which could
result from lower market- or exchange-rate volatility, a
sustainable decline in inflation and a sustained improvement in
investor sentiment, could support VR upgrades, particularly if
combined with a strengthening in the banks' capital buffers and
earnings.

A positive change in the sovereign's IDRs would likely lead to an
upgrade of GSRs and similar actions on these banks' IDRs.

VR upgrades (Emlak Katilim, Vakif Katilim and Ziraat Katilim only)
are primarily sensitive to improvement in the banks' business
profiles, in the context of a stronger operating environment,
combined with a strengthening of their FC liquidity and capital
buffers.

All seven banks' GSRs could be upgraded if Fitch considers the
government's ability to support the banks in FC to have
strengthened.

TSKB's SSR is sensitive to a positive change in Isbank's ability to
provide support, although this is not its base case, given the
Stable Outlook on the parent bank's ratings, and also its
propensity.

The banks' senior unsecured debt ratings are primarily sensitive to
changes in their IDRs.

VRs, GSRs, IDRs of Akbank, Isbank, YKB, Albaraka, Seker, Fiba,
Anadolubank and ATB and SENIOR UNSECURED DEBT of Akbank, Isbank and
YKB

Akbank, Isbank and YKB's IDRs would be upgraded if the banks' VRs
were upgraded, which would require an upgrade of the sovereign
rating, while the banks maintain a stable financial profile.
Albaraka, Seker, Fiba and Anadolu's VRs are primarily sensitive to
the strength of their capital buffers (including net of
forbearance) and FC liquidity buffers in the context of improving
operating environment conditions. VR upgrades for Albaraka, Seker,
ATB, Fiba and Anadolu would also require a strengthening of the
banks' business profiles.

VR upgrades for Akbank, Isbank and YKB would require an upgrade of
the sovereign rating, likely accompanied by an upward revision of
the operating environment score, while maintaining a healthy
financial profile and capital and FC liquidity buffers.

The GSRs of Akbank, Isbank and YKB could be upgraded from 'b-' if
Fitch considers the government's ability to support the banks in FC
to have strengthened. Albaraka, Seker, Fiba, ATB and Anadolubank's
GSRs of 'ns' are unlikely to be upgraded given their limited
systemic importance.

The banks' senior unsecured debt ratings / sukuk, where relevant,
are sensitive to positive changes in their IDRs.

VRs, IDRS AND SSRs OF FOREIGN-OWNED BANKS (Garanti BBVA; INGBT;
QNBF; TEB; Denizbank; Kuveyt Turk and Turkiye Finans, SENIOR
UNSERCURED DEBT OF Garanti BBVA; QNBF; TEB; Denizbank

A positive change in Turkiye's LT IDRs would likely lead to similar
actions on the banks' SSRs and LT IDRs. An upward revision of
Turkiye's Country Ceiling could also lead to an upgrade on the
banks' SSRs and LT IDRs.

A VR upgrade for Garanti BBVA would require an upgrade of the
sovereign rating, likely leading to an upward revision of the
operating environment score, while maintaining a healthy financial
profile. VR upgrades for the other foreign-owned banks would
require an improvement in their capital buffers and earnings
performance combined with a strengthening of their business
profiles.

VR upgrades at Kuveyt Turk and TFKB, which are on RWP, will
primarily depend on Fitch's assessment of the banks' business
profiles and the strength of their FC liquidity and capital buffers
in the context of the stronger operating environment.

The banks' senior unsecured debt ratings are primarily sensitive to
positive changes in their IDRs.

OTHER DEBT AND ISSUER RATINGS: KEY RATING DRIVERS

SUBORDINATED DEBT RATINGS (QNBF, Garanti BBVA, TEB, Kuveyt Turk,
Akbank, Isbank, YKB, Seker, Fiba and Vakif)

The subordinated notes' ratings of foreign-owned QNBF, Garanti
BBVA, TEB and Kuveyt Turk (the latter issued through its SPV, KT21
T2 Sukuk) have been upgraded to 'B+' from 'B-' following the
two-notch upgrade of their LTFC IDR anchor ratings. The notching
for the subordinated notes includes one notch for loss severity and
zero notches for non-performance risk (relative to the banks'
anchor ratings). The one notch, rather than default two notches,
for loss severity reflects its view that institutional support (as
reflected in the banks' LTFC IDRs) helps mitigate losses. The
Recovery Rating of the notes is 'RR5', reflecting below-average
recovery prospects in a default.

The subordinated notes' ratings of Akbank, Isbank and YKB have been
upgraded to 'B' from 'B-' following the one-notch upgrade of their
VR anchor ratings. The subordinated notes' ratings are notched
twice from their VR anchor ratings for loss severity, reflecting
its expectation of poor recoveries in case of default, in line with
Fitch criteria's baseline approach.

The subordinated notes' ratings of Vakif have been upgraded to 'B-'
from 'CCC+' following the one-notch upgrade of the bank's VR anchor
rating.

The subordinated debt ratings of Seker and Fiba, have been upgraded
to 'CCC+' from 'CCC' following the one-notch upgrade of the banks'
VR anchor ratings.

The Recovery Rating of these notes is 'RR6'.

Banks' AT1 notes (where relevant) have been upgraded by one notch
due to the upgrade of their anchor ratings including at Akbank and
YKB (to 'B-' from 'CCC+'), and at Vakif and TSKB (to 'CCC+' from
'CCC'). The notes are rated three notches below their VRs,
comprising two notches for loss severity, given the notes' deep
subordination, and one notch for incremental non-performance risk,
given their full discretionary, non-cumulative coupons. In
accordance with the Bank Rating Criteria, Fitch has applied three
notches from the banks' VR, instead of the baseline four notches,
as VRs are either at the 'BB-' threshold (Akbank, YKB) or below it
(Vakif, TSKB).

The expected rating of Sekerbank's AT1 has been upgraded to
'CCC(EXP)' from 'CCC-(EXP) following the one-notch upgrade of the
bank's VR anchor rating.

Fitch has assigned ex-government support or 'xgs' ratings of
'B-(xgs)' LTFC IDR and LTLC IDR to Emlak Katilim, Halk and Vakif
Katilim. The ex-government support ratings exclude assumptions of
extraordinary government support from the underlying ratings. ST FC
and LC IDRs (xgs) have also been assigned in accordance with the
banks' respective LT FC and LC IDRs (xgs) and Fitch's short-term
rating mapping. Halk's xgs ratings are placed on RWN, in line with
its VR. Emlak Katilim and Vakif Katilim's LT xgs ratings are placed
on RWP, in line with their VRs.

OTHER DEBT AND ISSUER RATINGS: RATING SENSITIVITIES

SUBORDINATED DEBT RATINGS (Garanti BBVA, Akbank, Isbank, YKB, QNBF,
TEB, Kuveyt Turk, Seker, Fiba)

Banks' subordinated debt ratings, where relevant, are sensitive to
a change of their respective anchor ratings. They are also
sensitive to a revision in Fitch's assessment of potential loss
severity in case of non-performance.

Emlak Katilim, Halk and Vakif Katilim's Long-Term IDR (xgs) ratings
are sensitive to changes in the bank's VR.

The banks' Short-Term IDR (xgs) ratings are primarily sensitive to
a change in their Long-Term IDR (xgs) and could be downgraded if
the latter are downgraded, and map to a lower short-term rating in
accordance with Fitch's criteria.

SUBSIDIARIES & AFFILIATES: KEY RATING DRIVERS

Ziraat Katilim's IDRs, driven by its SSR, are equalised with those
of its parent, Ziraat, reflecting the bank's strategic importance
and role as a core subsidiary of the group given its Islamic bank
status, and have been upgraded to 'B+' (LTFC IDR) and 'BB-' (LTLC
IDR), respectively. The Outlook on the LTFC IDR is Positive, while
the Outlook on the LTLC IDR is Stable, mirroring the Outlooks that
on its parent.

Fitch has upgraded AB Kazakhstan - Ziraat International Bank JSC's
(KZI) LTFC and LTLC IDRs to 'B+' from 'B'. Fitch has also upgraded
the bank's National Long-Term Rating to 'BBB(kaz)' from 'BB+(kaz)'.
The Outlooks are Stable. KZI's 'B+' LT IDRs are driven by potential
support from the parent bank, Ziraat, as reflected by the bank's
'b+' SSR.

In Fitch's view, Ziraat has a high propensity to support KZI.
Beyond high operational integration, this is due to its majority
ownership and high reputational risk for the parent in case of the
potential default of KZI, given the banks' common branding and
Ziraat's broader international presence. In addition, the cost of
potential support to Ziraat is low, considering the subsidiary's
small size relative to the parent's (end-1H24: equal to 0.4% of the
group's consolidated assets), and a record of considerable equity
support in the past (2022: 21% of risk-weighted assets).

SUBSIDIARIES AND AFFILIATES: RATING SENSITIVITIES

Ziraat Katilim's IDRs are sensitive to a change in its parent's
rating or propensity to provide support.

A negative rating action on Ziraat's LTFC IDR may result in a
corresponding rating action on KZI's ratings. In addition, KZI's
ratings could be downgraded if Ziraat's propensity to support its
subsidiary weakens considerably.

KZI's ratings could be upgraded on a multi-notch upgrade of the
parent's LTFC IDR.

KZI's National Rating is sensitive to a rating action on its LTLC
IDR and to reassessment by Fitch of the bank's creditworthiness
relative to local peers'.

VR ADJUSTMENTS

The operating-environment score of 'b+' for Turkish banks is below
the 'bb' category implied score due to the following adjustment
reason: macroeconomic volatility (negative), which reflects high
inflation, high dollarisation and high risk of FX movements in
Turkiye.

The business profile scores of 'b+' for Vakif, QNBF and Denizbank
are below the 'bb' category implied scores, due to the following
adjustment reason: business model (negative). This reflects the
banks' business model concentration on the high-risk Turkish
market.

ATB's asset quality score of 'b' is below the category implied
score of 'bb', due to the following adjustment reason:
concentrations (negative).

Emlak Katilim's asset quality score of 'b-' is below the category
implied score of 'bb', due to the following adjustment reason:
underwriting standards and growth (negative).

Kuveyt Turk's earnings and profitability score of 'b' is below the
category-implied score of 'bb', due to the following adjustment
reason: risk-weight calculation (negative).

TSKB's earnings and profitability score of 'b+' is below the
category-implied score of 'bb', due to the following adjustment
reason: earnings stability (negative).

Emlak Katilim's earnings and profitability score of 'b-' is below
the category-implied score of 'bb', due to the following adjustment
reason: earnings stability (negative).

Isbank's earnings and profitability score of 'bb-' is above the
category-implied score of 'b', due to the following adjustment
reason: revenue diversification (positive).

The funding and liquidity scores of 'bb-' for Akbank, Isbank and
YKB are above the 'b' category implied scores, due to the following
adjustment reason: liquidity coverage (positive).

The funding and liquidity scores of 'bb-' for Garanti BBVA,
Denizbank, ING, QNBF and TEB are above the 'b' category implied
scores, due to the following adjustment reason: liquidity access
and ordinary support (positive).

Public Ratings with Credit Linkage to other ratings

State-owned banks have ratings that are linked to the Turkish
sovereign rating.

Turkish foreign-owned banks have ratings that are linked to their
respective parent banks' ratings.

TSKB has ratings that are linked to the Turkish sovereign rating
and Isbank.

Ziraat Katilim's ratings are driven by support from Ziraat.

ESG Considerations

All Turkish Banks (excluding the three development banks, Turk
Eximbank, TKYB and TSKB)

The ESG Relevance Score for Management Strategy of '4' reflects an
increased regulatory burden on all Turkish banks. Management
ability across the sector to determine their own strategy and price
risk is constrained by regulatory burden and also by the
operational challenges of implementing regulations at the bank
level. This has a moderately negative impact on the banks' credit
profiles and is relevant to the banks' ratings in combination with
other factors.

State-owned Turkish banks

In addition, the state-owned commercial banks - Ziraat, Vakif,
Emlak Katilim, Vakif Katilim and Ziraat Katilim - have ESG
Relevance Scores of '4' for Governance Structure due to potential
government influence over their boards' effectiveness and
management strategy in the challenging Turkish operating
environment, which has a negative impact on the banks' credit
profiles, and is relevant to the ratings in conjunction with other
factors.

Halk has an ESG Relevance Score of '5' for Governance Structure,
reflecting the high legal risk of a large fine, which drives the
RWN on the bank. It also considers potential government influence
over the board's effectiveness in the challenging Turkish operating
environment. Halk has an ESG Relevance Score of '4' for Management
Strategy due to potential government influence over its management
strategy in the challenging Turkish operating environment, which
has a negative impact on the credit profile, and is relevant to the
ratings in conjunction with other factors.

Islamic Banks (Emlak Katilim, Vakif Katilim, Kuveyt Turk, TFKB,
Ziraat Katilim and Albaraka)

Islamic banks' ESG Relevance Score of '4' for Governance Structure
reflects their Islamic banking nature where their operations and
activities need to comply with sharia principles and rules, which
entails additional costs, processes, disclosures, regulations,
reporting and sharia audit. This has a negative impact on their
credit profiles and is relevant to the ratings in conjunction with
other factors.

Islamic banks have an ESG Relevance Score of '3' for Exposure to
Social Impacts, above sector guidance for an ESG Relevance Score of
'2' for comparable conventional banks, which reflects that Islamic
banks have certain sharia limitations embedded in their operations
and obligations, although this only has a minimal credit impact on
Islamic banks.

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' means ESG
issues are credit neutral or have only a minimal credit impact on
the entity, either due to their nature or the way in which they are
being managed by the entity. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.

   Entity/Debt                    Rating        Recovery   Prior
   -----------                    ------        --------   -----
Turk Ekonomi
Bankasi A.S.    LT IDR              BB- Upgrade            B
                ST IDR              B   Affirmed           B
                LC LT IDR           BB- Upgrade            B+
                LC ST IDR           B   Affirmed           B
                Viability           b+  Upgrade            b
                Shareholder Support bb- Upgrade            b

   senior
   unsecured    LT                  BB- Upgrade   RR4      B

   subordinated   LT                B+  Upgrade   RR5      B-

   senior
   unsecured    ST                  B   Affirmed           B

AKBANK T.A.S.   LT IDR              BB- Upgrade            B
                ST IDR              B   Affirmed           B
                LC LT IDR           BB- Upgrade            B+
                LC ST IDR           B   Affirmed           B
                Viability           bb- Upgrade            b+
                Government Support  b-  Upgrade            ns

   senior
   unsecured    LT                  BB- Upgrade   RR4      B

   subordinated   LT                B   Upgrade   RR6      B-

   subordinated   LT                B-  Upgrade            CCC+

   senior
   unsecured    ST                  B   Affirmed           B

Turkiye Is
Bankasi A.S.    LT IDR              BB- Upgrade            B    
                ST IDR              B   Affirmed           B
                LC LT IDR           BB- Upgrade            B+
                LC ST IDR           B   Affirmed           B
                Viability           bb- Upgrade            b+
                Government Support  b-  Upgrade            ns

   senior
   unsecured    LT                  BB- Upgrade   RR4      B

   subordinated   LT                B   Upgrade   RR6      B-

   senior
   unsecured    ST                  B   Affirmed           B

Turkiye Ihracat
Kredi Bankasi
A.S.            LT IDR              BB- Upgrade            B
                ST IDR              B   Affirmed           B
                LC LT IDR           BB- Upgrade            B+
                LC ST IDR           B   Affirmed           B
                Government Support  bb- Upgrade            b

   senior
   unsecured    LT                  BB- Upgrade   RR4      B

   senior
  unsecured     ST                  B   Affirmed           B

Arap Turk
Bankasi A.S.    LT IDR              B   Upgrade            B-
                ST IDR              B   Affirmed           B
                LC LT IDR           B   Upgrade            B-
                LC ST IDR           B   Affirmed           B
                Viability           b   Upgrade            b-
                Government Support  ns  Affirmed           ns

Ziraat Katilim
Varlik Kiralama
A.S.

   senior
   unsecured    LT                  B+  Upgrade   RR4      B

Kuveyt Turk
Katilim
Bankasi A.S     LT IDR              BB- Upgrade            B
                ST IDR              B   Affirmed           B
                LC LT IDR           BB- Upgrade            B+
                LC ST IDR           B   Affirmed           B
                Viability           b-  Rating Watch On    b-
                Shareholder Support bb- Upgrade            b

Turkiye
Garanti
Bankasi A.S.    LT IDR              BB- Upgrade            B
                ST IDR              B   Affirmed           B
                LC LT IDR           BB- Upgrade            B+
                LC ST IDR           B   Affirmed           B
                Viability           bb- Upgrade            b+
                Shareholder Support bb- Upgrade            b

   senior
   unsecured    LT                   BB- Upgrade   RR4     B

   subordinated   LT                 B+  Upgrade   RR5     B-

   senior
   unsecured    ST                   B   Affirmed          B

Ziraat Katilim
Bankasi A.S.    LT IDR               B+  Upgrade           B
                ST IDR               B   Affirmed          B
                LC LT IDR            BB- Upgrade           B+
                LC ST IDR            B   Affirmed          B
                Viability            b-  Rating Watch On   b-
                Shareholder Support  b+  Upgrade           b

Ziraat Katilim
MTN Limited

   senior
   unsecured    LT                   B+  Upgrade   RR4     B

   senior
   unsecured    ST                   B   Affirmed          B

Yapi ve Kredi
Bankasi A.S.    LT IDR               BB- Upgrade           B
                ST IDR               B   Affirmed          B
                LC LT IDR            BB- Upgrade           B+
                LC ST IDR            B   Affirmed          B  
                Viability            bb- Upgrade           b+
                Government Support   b-  Upgrade           ns

   senior
   unsecured    LT                   BB- Upgrade   RR4     B

   subordinated   LT                 B   Upgrade   RR6     B-

   junior
   subordinated   LT                 B-  Upgrade           CCC+

   senior
   unsecured      ST                 B   Affirmed          B

Turkiye Vakiflar
Bankasi T.A.O.    LT IDR             B+  Upgrade           B
                  ST IDR             B   Affirmed          B
                  LC LT IDR          BB- Upgrade           B+
                  LC ST IDR          B   Affirmed          B
                  Viability          b+  Upgrade           b
                  Government Support b+  Upgrade           b-

   senior
   unsecured      LT                 B+  Upgrade   RR4     B

   subordinated   LT                 CCC+ Upgrade          CCC

   subordinated   LT                 B-  Upgrade   RR6     CCC+

   senior   
   unsecured      ST                 B   Affirmed          B

Anadolubank A.S.  LT IDR             B   Upgrade           B-
                  ST IDR             B   Affirmed          B
                  LC LT IDR          B   Upgrade           B-
                  LC ST IDR          B   Affirmed          B
                  Viability          b   Upgrade           b-
                  Government Support ns  Affirmed          ns

Sekerbank T.A.S.  LT IDR             B   Upgrade           B-
                  ST IDR             B   Affirmed          B
                  LC LT IDR          B   Upgrade           B-
                  LC ST IDR          B   Affirmed          B
                  Viability          b   Upgrade           b-
                  Government Support ns  Affirmed          ns

   subordinated   LT                 CCC+ Upgrade   RR6    CCC

   Subordinated   LT                 CCC(EXP)Upgrade    CCC-(EXP)

Turkiye
Cumhuriyeti
Ziraat Bankasi
Anonim Sirketi    LT IDR             B+  Upgrade           B  
                  ST IDR             B   Affirmed          B
                  LC LT IDR          BB- Upgrade           B+
                  LC ST IDR          B   Affirmed          B
                  Viability          b+  Upgrade           b
                  Government Support b+  Upgrade           b-

   senior
   unsecured      LT                 B+  Upgrade   RR4     B

   subordinated   LT                 B-  Upgrade   RR6     CCC+

   senior
   unsecured      ST                 B   Affirmed          B

Turkiye Emlak
Katilim
Bankasi A.S.      LT IDR             B+  Upgrade           B-
                  ST IDR             B   Affirmed          B
                  LC LT IDR          BB- Upgrade           B+
                  LC ST IDR          B   Affirmed          B
                  Viability          b-  Rating Watch On   b-
                  Government Support b+  Upgrade           b-
                  LC ST IDR (xgs)    B(xgs)New Rating
                  LC LT IDR (xgs)    B-(xgs)New Rating
                  ST IDR (xgs)       B(xgs) New Rating
                  LT IDR (xgs)       B-(xgs)New Rating

Fibabanka
Anonim Sirketi    LT IDR             B   Upgrade           B-
                  ST IDR             B   Affirmed          B
                  LC LT IDR          B   Upgrade           B-
                  LC ST IDR          B   Affirmed          B
                  Viability          b   Upgrade           b-
                  Government Support ns  Affirmed          ns

   subordinated   LT                 CCC+ Upgrade   RR6    CCC

Turkiye Kalkinma
ve Yatirim
Bankasi A.S.      LT IDR             BB-  Upgrade          B+
                  ST IDR             B    Affirmed         B
                  LC LT IDR          BB-  Upgrade          B+
                  LC ST IDR          B    Affirmed         B
                  Government Support bb-  Upgrade          b+

Denizbank A.S.    LT IDR             BB-  Upgrade          B
                  ST IDR             B    Affirmed         B
                  LC LT IDR          BB-  Upgrade          B+
                  LC ST IDR          B    Affirmed         B
                  Viability          b+   Upgrade          b
                  Shareholder Support bb- Upgrade          b

   senior
   unsecured      LT                 BB-  Upgrade   RR4    B

   senior
   unsecured      ST                 B    Affirmed         B

Turkiye Halk
Bankasi A.S.      LT IDR             B+   Upgrade          B-
                  ST IDR      B  Rating Watch Maintained   B
                  LC LT IDR          BB-  Upgrade          B+
                  LC ST IDR   B  Rating Watch Maintained   B
                  Viability   b- Rating Watch Maintained   b-
                  Government Support b+   Upgrade          b-
                  LC ST IDR (xgs)    B(xgs)New Rating
                  LC LT IDR (xgs)    B-(xgs)New Rating
                  ST IDR (xgs)       B(xgs)New Rating
                  LT IDR (xgs)       B-(xgs)New Rating

Turkiye Sinai
Kalkinma
Bankasi A.S.      LT IDR             B+   Upgrade          B
                  ST IDR             B    Affirmed         B
                  LC LT IDR          BB-  Upgrade          B+
                  LC ST IDR          B    Affirmed         B
                  Viability          b+   Upgrade          b
                  Government Support b+   Upgrade          b-
                  Shareholder Support b+  Upgrade          b-

   senior
   unsecured      LT                 B+   Upgrade   RR4    B

   subordinated   LT                 CCC+ Upgrade          CCC

   senior
   unsecured      ST                 B    Affirmed         B

Albaraka Turk
Katilim
Bankasi A.S.      LT IDR             B    Upgrade          B-
                  ST IDR             B    Affirmed         B
                  LC LT IDR          B    Upgrade          B-
                  LC ST IDR          B    Affirmed         B
                  Viability          b    Upgrade          b-
                  Government Support ns   Affirmed         ns

Vakif Katilim
Bankasi A.S.      LT IDR             B+   Upgrade          B-
                  ST IDR             B    Affirmed         B
                  LC LT IDR          BB-  Upgrade          B+
                  LC ST IDR          B    Affirmed         B
                  Viability          b-  Rating Watch On   b-
                  Government Support b+   Upgrade          b-
                  LT IDR (xgs)       B-(xgs)New Rating
                  ST IDR (xgs)       B(xgs) New Rating
                  LC LT IDR (xgs)    B-(xgs)New Rating
                  LC ST IDR (xgs)    B(xgs) New Rating

QNB Finansbank
Anonim Sirketi    LT IDR             BB-  Upgrade          B
                  ST IDR             B    Affirmed         B
                  LC LT IDR          BB-  Upgrade          B+
                  LC ST IDR          B    Affirmed         B
                  Viability          b+   Upgrade          b
                  Shareholder Support bb- Upgrade          b

   Senior
   unsecured      LT                 BB-  Upgrade   RR4    B

   subordinated   LT                 B+   Upgrade   RR5    B-

   senior
   unsecured      ST                 B    Affirmed         B

ING Bank A.S.     LT IDR             BB-  Upgrade          B
                  ST IDR             B    Affirmed         B
                  LC LT IDR          BB-  Upgrade          B+  
                  LC ST IDR          B    Affirmed         B
                  Viability          b+   Upgrade          b
                  Shareholder Support bb- Upgrade          b

KT21 T2
Company Limited

   subordinated   LT                 B+   Upgrade   RR5    B-

Albaraka
MTN Ltd

   senior
   unsecured      LT                 B    Upgrade   RR4    B-

   senior
   unsecured      ST                 B    Affirmed         B

Turkiye Finans
Katilim
Bankasi A.S.      LT IDR             BB-  Upgrade          B
                  ST IDR             B    Affirmed         B
                  LC LT IDR          BB-  Upgrade          B+
                  LC ST IDR          B    Affirmed         B
                  Viability          b-  Rating Watch On   b-
                  Shareholder Support bb- Upgrade          b

AB Kazakhstan
- Ziraat
International
Bank JSC          LT IDR             B+   Upgrade          B
                  ST IDR             B    Affirmed         B
                  LC LT IDR          B+   Upgrade          B
                  Natl LT        BBB(kaz) Upgrade        BB+(kaz)
                  Shareholder Support b+  Upgrade          b




=============
U K R A I N E
=============

[*] Fitch Hikes 8 Ukrainian LRGs to CCC on Sovereign Rating Action
------------------------------------------------------------------
Fitch Ratings has upgraded eight Ukrainian local and regional
governments' (LRGs) Long-Term Local-Currency (LTLC) Issuer Default
Ratings (IDRs) to 'CCC' from 'CCC-'. Ratings at this level
typically do not carry Outlooks due to their high volatility.

The involved entities are:

- Kryvyi Rih, City of
- Kharkov, City of
- Lviv, City of
- Odesa, City of
- Mykolaiv, City of
- Dnipro, City of
- Kyiv, City of
- Zaporizhzhia, City of

Under applicable credit rating agency (CRA) regulations, the
publication of the LRG reviews is subject to restrictions and must
take place according to a published schedule, except where it is
necessary for CRAs to deviate from the schedule in order to comply
with the CRAs' obligation to issue credit ratings based on all
available and relevant information and disclose credit ratings in a
timely manner.

Fitch interprets this provision as allowing us to publish a rating
review in situations where there is a material change in the
creditworthiness of the issuer that Fitch believes makes it
inappropriate for us to wait until the next scheduled review date
to update the rating or Outlook/Watch status.

The next schedule review date for Fitch's rating on Dnipro,
Kharkov, Kryvyi Rih, Kyiv, Lviv, Mykolaiv, Odesa and Zaporizhzhia
is October 18, 2024, but Fitch believes the developments for the
issuer warrant such a deviation from the calendar and its rationale
for this is set out in the first part (High weight factors) of the
Key Rating Drivers section below.

Key Rating Drivers

HIGH

The upgrade of the IDRs of the cities follows the upgrade of the
Ukrainian sovereign on 5 September 2024 (see Fitch Upgrades
Ukraine's LTLC IDR to 'CCC+'; Affirms LTFC IDR at 'RD'), as the
cities' ratings were capped by the previous sovereign rating.

LOW

The risk profiles remain 'Vulnerable' as they are not affected by
the rating action and all the cities have the key risk factors
assessed as 'Weaker', the weakest assessment allowed under Fitch's
International Local and Regional Governments Rating Criteria. No
changes have been applied to the financial profile of any issuer,
which remains 'b' for Dnipro, Kharkov, Kryvyi Rih, Kyiv, Lviv,
Mykolaiv, Odesa and Zaporizhzhia. The derivation of the Standalone
Credit Profiles is unaffected by the rating action. Fitch will
closely monitor the evolution of the situation throughout the
Russian-Ukrainian war and will take the appropriate course of
action in case of need.

ESG - Political Stability and Rights: The invasion by Russia and
ongoing full-scale war have severely compromised the cities'
political stability and the security outlook. The war is resulting
in the death of the cities' inhabitants and extensive property
damage, with the aim of changing the cities' government and/or
occupying their territory.

ESG - Creditor Rights: The protracted war has weakened the cities'
ability and willingness to service and repay debt. The cities'
liquidity is deteriorating and the Ukrainian sovereign's
willingness to allow the use of foreign-currency (FC) reserves for
debt service in FC is diminishing, while the costs of preserving
the urban and communal functions for the cities are on the rise.

Derivation Summary

For individual derivation summaries see the latest published rating
action commentary on each issuer at www.fitchratings.com.

NATIONAL RATINGS

Fitch has upgraded the National Ratings of the cities of Dnipro,
Kharkov, Kryvyi Rih, Kyiv and Lviv to 'AA(ukr)' from 'A+(ukr)'. The
ratings' Outlook is Stable. The 'CCC' LTLC IDR maps to the ratings
of 'AA-(ukr)' or 'AA(ukr)'. The cities' diversified revenue base
and existing spending flexibility, proven by significant spending
cuts in 2022, show that, as in the case of other Ukrainian LRGs,
they are in a stronger position than national peers from other
asset classes, justifying the highest possible national rating for
the given mapping. However, the lack of local economic indicators
and the severely constrained ability to develop a reliable rating
scenario due to the war do not support the differentiation of
national ratings among the rated Ukrainian cities.

DEBT RATINGS

The ratings of Kyiv's domestic bonds are aligned with the city's LT
LC IDR. This is because Fitch views the domestic bonds as direct,
unconditional senior unsecured obligations of the city, ranking
pari passu with all of its other present and future unsecured and
unsubordinated obligations.

Key Assumptions

Qualitative assumptions and assessments and their respective change
since the last review on April 19, 2024 for Dnipro, Kharkov, Kryvyi
Rih, Kyiv, Lviv, Mykolaiv, Odesa and Zaporizhzhia and weight in the
rating decision:

Risk Profile: 'Vulnerable'/unchanged with low weight

Revenue Robustness: 'Weaker'/unchanged with low weight

Revenue Adjustability: 'Weaker'/unchanged with low weight

Expenditure Sustainability: 'Weaker'/unchanged low weight

Expenditure Adjustability: 'Weaker'/unchanged with low weight

Liabilities and Liquidity Robustness: 'Weaker'/unchanged with low
weight

Liabilities and Liquidity Flexibility: 'Weaker'/unchanged with low
weight

Financial Profile: 'b' category /unchanged with low weight

Asymmetric Risk: N/A, unchanged with low weight

Budget Loans or Ad-Hoc Support: N/A, unchanged with low weight

Sovereign Cap: 'CCC+' (for Local Currency), raised with high
weight

Rating Floor: N/A, unchanged with low weight

Quantitative assumptions - issuer-specific: unchanged with low
weight

Fitch's rating case scenario is irrelevant for ratings that are
based on rating definitions; instead, it is an assumption of the
issuer's capability (liquidity) and willingness to service it. The
assumption applies to all rated Ukrainian cities irrespective of
whether direct debt exist currently as Fitch assumes that a need
for debt may arise in the short term or debt servicing resulting
from the guarantees issued as collateral for the debt of municipal
companies may materialise in the short term.

Figures as per Fitch's sovereign actual for 2023 and forecast for
2026, respectively (no weights and changes since the last review
are included as none of these assumptions were material to the
rating action):

- GDP per capita (US dollar, market exchange rate): 5,014; 5,333

- Real GDP growth (%): 5.3; 5.0

- Consumer prices (annual average % change): 12.9; 5.8

- General government balance (% of GDP): -19.5; -12.7

- General government debt (% of GDP): 84.4; 103.0

- Current account balance plus net FDI (% of GDP): -2.8; -6.7

- Net external debt (% of GDP): -16.5; 15.1

- IMF Development Classification: EM (emerging market)

- CDS Market Implied Rating: n/a

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

- An improvement in the city's financial profile resulting from a
financial situation stabilisation and stronger liquidity, allowing
the SCP to raise to 'ccc+', would lead to an upgrade of the cities'
LTLC IDRs, provided that there is no cap by the sovereign rating.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

- A downgrade of the LTLC IDR of Ukraine to below 'CCC' would lead
to a downgrade of the cities' ratings.

- Increased risk of default due to weakened liquidity that could
pressure the city's ability to service debt.

Public Ratings with Credit Linkage to other ratings

The cities' ratings are linked to the ratings of Ukraine.

ESG Considerations

The cities have an ESG Relevance Score of '5' for Political
Stability and Rights to reflect the invasion by Russia and ongoing
full-scale war, which has severely compromised the city's political
stability and the security outlook. This has a negative impact on
the credit profile and is highly relevant to the ratings. The war
is resulting in the death of the cities' inhabitants and extensive
property damage, with the aim of changing the cities' government
and/or occupying their territory.

The cities have an ESG Relevance Score of '5' for Creditor Rights
to reflect the weakened ability and willingness of the city to
service and repay debt. This has a negative impact on the credit
profile and is highly relevant to the ratings. The protracted war
is resulting in the depletion of liquidity and in diminishing the
Ukrainian sovereign's willingness to allow the use of FC reserves
for debt service in FC, while the costs of preserving the urban and
communal functions for the city are on the rise.

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' means ESG
issues are credit neutral or have only a minimal credit impact on
the entity, either due to their nature or the way in which they are
being managed by the entity. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.

DISCUSSION NOTE

Committee date: September 12, 2024

There was an appropriate quorum at the committee and the members
confirmed that they were free from recusal. It was agreed that the
data was sufficiently robust relative to its materiality. During
the committee no material issues were raised that were not in the
original committee package. The main rating factors under the
relevant criteria were discussed by the committee members. The
rating decision as discussed in this rating action commentary
reflects the committee discussion.

   Entity/Debt             Rating            Prior
   -----------             ------            -----
Lviv, City of     LC LT IDR CCC    Upgrade   CCC-
                  Natl LT   AA(ukr)Upgrade   A+(ukr)

Dnipro, City of   LC LT IDR CCC    Upgrade   CCC-
                  Natl LT   AA(ukr)Upgrade   A+(ukr)

Zaporizhzhia,
City of           LC LT IDR CCC    Upgrade   CCC-

Kyiv, City of     LC LT IDR CCC    Upgrade   CCC-
                  Natl LT   AA(ukr)Upgrade   A+(ukr)

   senior
   unsecured      LT        CCC    Upgrade   CCC-

Kharkov,
City of           LC LT IDR CCC    Upgrade   CCC-
                  Natl LT   AA(ukr)Upgrade   A+(ukr)

Mykolaiv,
City of           LC LT IDR CCC    Upgrade   CCC-

Kryvyi Rih,
City of           LC LT IDR CCC    Upgrade   CCC-
                  Natl LT   AA(ukr)Upgrade   A+(ukr)

Odesa, City of    LC LT IDR CCC    Upgrade   CCC-




===========================
U N I T E D   K I N G D O M
===========================

BRICK LIVE: ReSolve Advisory Named as Administrators
----------------------------------------------------
Brick Live International Limited fka Brick Live INTL Limited was
placed in administration proceedings in the High Court of Justice
Business and Property Courts of England and Wales, Insolvency &
Companies List (ChD), Court Number: CR-2024-005253, and Ben
Woodthorpe and Simon Jagger of ReSolve Advisory Limited were
appointed as administrators on Sept 12, 2024.  

Brick Live, trading name BRICKLIVE, specializes in amusement and
recreation activities.

Its registered office is at  3 Park Court, Pyrford Road, West
Byfleet, Surrey, KT14 6SD. The principal trading address is at Unit
58-59 Brindley Road, Runcorn, WA7 1PF.

The joint administrators can be reached at:

           Ben Woodthorpe
           Simon Jagger
           ReSolve Advisory Limited
           22 York Buildings, London
           WC2N 6JU

For further information, contact:
           
           The Administrators
           Tel No: 020 3370 3126

Alternative contact:

           Hashem Kherfan
           E-mail: hashem.kherfan@resolvegroupuk.com


FABLINK GROUP: Interpath Ltd Named as Joint Administrators
----------------------------------------------------------
Fablink Group Holdings Limited was placed in administration
proceedings in the High Court of Justice, Business and Property
Courts in Birmingham, Insolvency and Companies List (ChD), Court
Number: CR-2024-BHM-000549, and Christopher Robert Pole and Ryan
Grant of Interpath Ltd were appointed as administrators on Sept 12,
2024.  

The Fablink Group is a UK based manufacturer specialising in the
manufacture of metal pressings, operator cab assemblies, fuel and
hydraulic tanks and complex structures as well as 'clean build' of
vehicle assemblies.

Its principal trading address is at  Brewery Farm, Old Northants,
NN6 9RL.

The joint administrators can be reached at:

           Christopher Robert Pole
           Ryan Grant
           Interpath Ltd
           2nd Floor, 45 Church Street
           Birmingham, B3 2RT

For further details, contact:
           
            Nusrat Begum
            Email: Fablink@interpath.com


FABLINK UK: Interpath Ltd Named as Joint Administrators
-------------------------------------------------------
Fablink UK Limited was placed in administration proceedings in the
High Court of Justice, Business and Property Courts in Birmingham,
Insolvency and Companies List (ChD), Court Number:
CR-2024-BHM-000548, and Christopher Robert Pole and Ryan Grant of
Interpath Ltd were appointed as administrators on Sept 12, 2024.  

The Fablink Group is a UK based manufacturer specialising in the
manufacture of metal pressings, operator cab assemblies, fuel and
hydraulic tanks and complex structures as well as 'clean build' of
vehicle assemblies.

Fablink UK's principal trading address is at Unit 29 Lyveden Rd,
Brackmills, Northampton, NN4 7ED.

The joint administrators can be reached at:

           Christopher Robert Pole
           Ryan Grant
           Interpath Ltd
           2nd Floor, 45 Church Street
           Birmingham, B3 2RT

For further details, contact:
           
            Nusrat Begum
            Email: Fablink@interpath.com


GLENEVIN LTD: RSM UK Named as Administrators
--------------------------------------------
Glenevin Ltd was placed in administration proceedings in the High
Court of Justice, Business and Property Courts in Leeds, Insolvency
and Companies List (ChD), Court Number: CR-2024-000882, and Gareth
Harris and Paul Dounis of RSM UK Restructuring Advisory LLP were
appointed as administrators on Sept. 6, 2024.  

Glenevin Ltd is involved in the construction of utility projects
for electricity and telecommunications.

Its registered office is at 5th Floor, Central Square, 29
Wellington Street, Leeds, LS1 4DL.  Its principal trading address
is at Westwood House 4a, Royston Road, Deans, Livingston, EH4 8AH.

The administrators can be reached at:

            Gareth Harris
            RSM UK Restructuring Advisory LLP
            Central Square, 5th Floor
            29 Wellington Street, Leeds
            LS1 4DL

            -- and --

            Paul Dounis
            RSM UK Restructuring Advisory LLP
            Third Floor, 2 Semple Street
            Edinburgh, EH3 8BL

Correspondence Address & Contact Details of Case Manager

            Ross Taylor
            RSM UK Restructuring Advisory LLP
            5th Floor, Central Square
            29 Wellington Street, Leeds
            LS1 4D
            Tel No: 0113 285 5000

For further details, contact:

            The Joint Administrators
            Tel: 0113 285 5000
                 0131 659 8312




===============
X X X X X X X X
===============

[*] BOND PRICING: For the Week September 16 to 20, 2024
-------------------------------------------------------
Issuer                      Coupon  Maturity Currency Price
------                      ------  -------- -------- -----
Altice France Holding S  10.500   5/15/2027  USD    38.833
R-Logitech Finance SA    10.250   9/26/2027  EUR    15.000
Solis Bond Co DAC        10.208   9/30/2024  EUR    49.851
Codere Finance 2 Luxemb  11.000   9/30/2026  EUR    44.022
Codere Finance 2 Luxemb  12.750  11/30/2027  EUR     0.888
NCO Invest SA            10.000  12/30/2026  EUR     0.146
Ferralum Metals Group S  10.000  12/30/2026  EUR    33.500
NCO Invest SA            10.000  12/30/2026  EUR     0.372
IOG Plc                  13.217   9/20/2024  EUR     4.917
Ilija Batljan Invest AB  10.007              SEK    10.000
Virgolino de Oliveira F  11.750    2/9/2022  USD     0.490
Oscar Properties Holdin  11.270    7/5/2024  SEK     0.051
Immigon Portfolioabbau   10.055              EUR    14.875
Codere Finance 2 Luxemb  13.625  11/30/2027  USD     1.003
Plusplus Capital Financ  11.000   7/29/2026  EUR     8.658
Codere Finance 2 Luxemb  13.625  11/30/2027  USD     1.003
Turkiye Government Bond  10.400  10/13/2032  TRY    48.000
Fastator AB              12.500   9/25/2026  SEK    35.445
Marginalen Bank Bankakt  12.695              SEK    40.002
Virgolino de Oliveira F  10.500   1/28/2018  USD     0.010
Kvalitena AB publ        10.067    4/2/2024  SEK    45.000
Tinkoff Bank JSC Via TC  11.002              USD    42.875
Saderea DAC              12.500  11/30/2026  USD    49.860
Bilt Paper BV            10.360              USD     0.646
Codere Finance 2 Luxemb  11.000   9/30/2026  EUR    44.195
Fastator AB              12.500   9/26/2025  SEK    35.880
UkrLandFarming PLC       10.875   3/26/2018  USD     1.969
Virgolino de Oliveira F  11.750    2/9/2022  USD     0.490
Fastator AB              12.500   9/24/2027  SEK    35.641
Vontobel Financial Prod  21.000   9/27/2024  EUR    24.720
Codere Finance 2 Luxemb  12.750  11/30/2027  EUR     0.888
Privatbank CJSC Via UK   10.250   1/23/2018  USD     3.631
Virgolino de Oliveira F  10.500   1/28/2018  USD     0.010
Privatbank CJSC Via UK   11.000    2/9/2021  USD     0.500
UBS AG/London            17.500    2/7/2025  USD    17.800
Transcapitalbank JSC Vi  10.000              USD     1.450
ACBA Bank OJSC           11.000   12/1/2025  AMD     8.900
Avangardco Investments   10.000  10/29/2018  USD     0.655
Ameriabank CJSC          10.000   2/20/2025  AMD     9.060
Altice France Holding S  10.500   5/15/2027  USD    38.900
Evocabank CJSC           11.000   9/28/2024  AMD     9.431
Sidetur Finance BV       10.000   4/20/2016  USD     0.784
BNP Paribas Emissions-   15.000   9/25/2025  EUR    39.680
Bulgaria Steel Finance   12.000    5/4/2013  EUR     0.216
Elli Investments Ltd     12.250   6/15/2020  GBP     1.171
Privatbank CJSC Via UK   10.875   2/28/2018  USD     5.324
Virgolino de Oliveira F  10.875   1/13/2020  USD    36.000
Virgolino de Oliveira F  10.875   1/13/2020  USD    36.000
Tailwind Energy Chinook  12.500   9/27/2019  USD     1.500
Ukraine Government Bond  11.000   2/16/2037  UAH    30.687
Ventelo Europe Ltd       10.875   6/15/2008  USD     0.000
Phosphorus Holdco PLC    10.000    4/1/2019  GBP     0.807
Finca Uco Cjsc           13.000  11/16/2024  AMD     0.000
Bilt Paper BV            10.360              USD     0.646
UBS AG/London            14.000   7/31/2025  USD    50.550
Ukraine Government Bond  11.000    4/1/2037  UAH    30.646
Bank Vontobel AG         29.000   4/10/2025  USD    42.900
Societe Generale SA      23.500    3/3/2025  USD    45.740
Leonteq Securities AG    20.000    1/3/2025  CHF    48.260
BNP Paribas Issuance BV  20.000   9/18/2026  EUR    34.040
Societe Generale SA      11.000   7/14/2026  USD    16.000
Societe Generale SA      20.000   7/21/2026  USD     3.400
Societe Generale SA      20.000   1/29/2026  USD     9.800
Societe Generale SA      22.750  10/17/2024  USD    23.750
NTRP Via Interpipe Ltd   10.250    8/2/2017  USD     1.003
HSBC Trinkaus & Burkhar  18.900   9/27/2024  EUR    11.680
Societe Generale SA      20.000  11/28/2025  USD    12.920
Societe Generale SA      15.600   8/25/2026  USD    39.830
UBS AG/London            20.000  11/29/2024  USD    17.810
Deutsche Bank AG/London  12.780   3/16/2028  TRY    46.786
UBS AG/London            10.000   3/23/2026  USD    28.730
Citigroup Global Market  25.530   2/18/2025  EUR     0.010
Societe Generale SA      15.000   9/29/2025  USD     8.400
Societe Generale SA      21.000  12/26/2025  USD    26.000
Elli Investments Ltd     12.250   6/15/2020  GBP     1.171
UkrLandFarming PLC       10.875   3/26/2018  USD     1.969
KPNQwest NV              10.000   3/15/2012  EUR     0.798
Tonon Luxembourg SA      12.500   5/14/2024  USD     2.216
Tonon Luxembourg SA      12.500   5/14/2024  USD     2.216
PA Resources AB          13.500    3/3/2016  SEK     0.124
UniCredit Bank GmbH      10.500   9/23/2024  EUR    33.800
Banco Espirito Santo SA  10.000   12/6/2021  EUR     0.058
Deutsche Bank AG/London  14.900   5/30/2028  TRY    48.941
Zurcher Kantonalbank Fi  23.000    3/5/2025  CHF    48.940
Landesbank Baden-Wuertt  23.000   9/27/2024  EUR    45.730
Landesbank Baden-Wuertt  25.000    1/3/2025  EUR    11.870
Landesbank Baden-Wuertt  21.000   9/27/2024  EUR    49.660
Landesbank Baden-Wuertt  22.000    1/3/2025  EUR    11.520
Landesbank Baden-Wuertt  21.000   6/27/2025  EUR    18.680
DZ Bank AG Deutsche Zen  23.100  12/31/2024  EUR    33.630
DZ Bank AG Deutsche Zen  11.500  12/31/2024  EUR     9.760
DZ Bank AG Deutsche Zen  21.500   9/27/2024  EUR    40.560
DZ Bank AG Deutsche Zen  12.700  12/31/2024  EUR    49.290
DZ Bank AG Deutsche Zen  10.500   1/22/2025  EUR     9.280
Bank Vontobel AG         14.500    4/4/2025  CHF    48.200
Landesbank Baden-Wuertt  25.000   9/27/2024  EUR    12.690
Landesbank Baden-Wuertt  16.000    1/3/2025  EUR    11.220
Landesbank Baden-Wuertt  19.000    1/3/2025  EUR    11.290
Landesbank Baden-Wuertt  14.000   6/27/2025  EUR    14.540
Landesbank Baden-Wuertt  27.000   9/27/2024  EUR     8.710
Landesbank Baden-Wuertt  10.500    1/2/2026  EUR    15.520
Landesbank Baden-Wuertt  18.000   9/27/2024  EUR    14.910
UBS AG                   10.000   7/29/2025  USD    34.160
Landesbank Baden-Wuertt  11.000    1/2/2026  EUR    17.450
Landesbank Baden-Wuertt  16.000    1/2/2026  EUR    22.700
DZ Bank AG Deutsche Zen  18.500   3/28/2025  EUR    20.630
DZ Bank AG Deutsche Zen  17.600   6/27/2025  EUR    22.500
Bank Vontobel AG         12.000   4/11/2025  CHF    46.900
Bank Vontobel AG         11.000   4/11/2025  CHF    17.300
Bank Vontobel AG         20.000   7/31/2025  CHF    41.700
Bank Vontobel AG         12.000   6/17/2025  CHF    28.700
Vontobel Financial Prod  26.450   1/24/2025  EUR    15.791
DZ Bank AG Deutsche Zen  20.250   9/25/2024  EUR     9.600
DZ Bank AG Deutsche Zen  14.300  12/31/2024  EUR    42.280
UniCredit Bank GmbH      14.700   9/27/2024  EUR    51.250
DZ Bank AG Deutsche Zen  19.900  12/31/2024  EUR    47.280
Ukraine Government Bond  11.000   4/24/2037  UAH    33.424
UniCredit Bank GmbH      17.500   9/27/2024  EUR    49.150
DZ Bank AG Deutsche Zen  14.000   9/25/2024  EUR     8.430
DZ Bank AG Deutsche Zen  10.250   9/25/2024  EUR    48.650
Swissquote Bank SA       15.740  10/31/2024  CHF    18.770
Ukraine Government Bond  11.000   4/23/2037  UAH    30.646
DZ Bank AG Deutsche Zen  20.400   3/28/2025  EUR    20.230
BNP Paribas Emissions-   28.000   9/26/2024  EUR    46.070
Bank Vontobel AG         14.000    3/5/2025  CHF    10.600
Bank Vontobel AG         12.000    3/5/2025  CHF    48.500
BNP Paribas Emissions-   15.000   9/26/2024  EUR    43.310
Landesbank Baden-Wuertt  10.000    1/3/2025  EUR    50.430
Landesbank Baden-Wuertt  15.000    1/3/2025  EUR    45.060
Ukraine Government Bond  11.000   3/24/2037  UAH    30.650
Vontobel Financial Prod  14.750  12/31/2024  EUR    33.900
Vontobel Financial Prod  22.500  12/31/2024  EUR    48.640
Vontobel Financial Prod  16.500  12/31/2024  EUR    32.990
Vontobel Financial Prod  20.250  12/31/2024  EUR    31.720
Vontobel Financial Prod  13.000  12/31/2024  EUR    34.920
Vontobel Financial Prod  18.500  12/31/2024  EUR    32.340
Vontobel Financial Prod  11.250  12/31/2024  EUR    36.090
Leonteq Securities AG/G  16.000    3/4/2025  CHF    47.510
Raiffeisen Switzerland   16.000    3/4/2025  CHF    14.220
DZ Bank AG Deutsche Zen  12.800  12/31/2024  EUR    44.750
DZ Bank AG Deutsche Zen  15.700  12/31/2024  EUR    40.630
DZ Bank AG Deutsche Zen  11.400  12/31/2024  EUR    47.340
DZ Bank AG Deutsche Zen  14.200  12/31/2024  EUR    42.530
DZ Bank AG Deutsche Zen  17.300  12/31/2024  EUR    39.010
DZ Bank AG Deutsche Zen  14.200  12/31/2024  EUR     9.370
Vontobel Financial Prod  19.250  12/31/2024  EUR    51.010
DZ Bank AG Deutsche Zen  19.000  12/31/2024  EUR    37.640
Zurcher Kantonalbank Fi  24.000  11/22/2024  EUR    50.190
Leonteq Securities AG    21.000  12/18/2024  CHF    47.530
Ukraine Government Bond  11.000    4/8/2037  UAH    30.645
Ukraine Government Bond  11.000   4/20/2037  UAH    30.876
Landesbank Baden-Wuertt  18.000    1/3/2025  EUR    10.670
Landesbank Baden-Wuertt  10.500   4/28/2025  EUR    13.490
Landesbank Baden-Wuertt  19.000   4/28/2025  EUR    16.620
Vontobel Financial Prod  29.200   1/17/2025  EUR    27.780
DZ Bank AG Deutsche Zen  13.200   3/28/2025  EUR    45.010
DZ Bank AG Deutsche Zen  23.600   3/28/2025  EUR    48.250
Swissquote Bank Europe   25.320   2/26/2025  CHF    35.050
Leonteq Securities AG/G  20.000   3/11/2025  CHF    14.410
Raiffeisen Switzerland   16.500   3/11/2025  CHF    14.140
UniCredit Bank GmbH      13.000   9/27/2024  EUR    50.220
UniCredit Bank GmbH      17.300   9/27/2024  EUR    43.280
UniCredit Bank GmbH      14.800   9/27/2024  EUR    36.850
UniCredit Bank GmbH      16.900   9/27/2024  EUR    33.910
Swissquote Bank SA       24.000   10/9/2024  CHF    41.890
Landesbank Baden-Wuertt  23.000   9/27/2024  EUR    44.580
Landesbank Baden-Wuertt  18.000    1/3/2025  EUR    49.140
Landesbank Baden-Wuertt  16.500   4/28/2025  EUR    15.570
Bank Vontobel AG         11.000   4/29/2025  CHF    23.300
Landesbank Baden-Wuertt  11.000   2/27/2026  EUR    18.250
Landesbank Baden-Wuertt  12.000   2/27/2026  EUR    19.430
Landesbank Baden-Wuertt  11.500   2/28/2025  EUR    12.500
Landesbank Baden-Wuertt  19.000   2/28/2025  EUR    13.780
Landesbank Baden-Wuertt  15.000   2/28/2025  EUR    12.880
DZ Bank AG Deutsche Zen  10.600   9/27/2024  EUR    48.030
UniCredit Bank GmbH      15.100   9/27/2024  EUR    46.480
UniCredit Bank GmbH      13.800   9/27/2024  EUR    38.530
UniCredit Bank GmbH      15.800   9/27/2024  EUR    35.320
UniCredit Bank GmbH      18.000   9/27/2024  EUR    32.630
Swissquote Bank SA       24.180   10/9/2024  CHF    42.880
Leonteq Securities AG    21.000    1/9/2025  CHF    50.540
Leonteq Securities AG    24.000    1/9/2025  CHF    22.260
Leonteq Securities AG    23.000    1/9/2025  CHF    45.890
Leonteq Securities AG/G  11.000    1/9/2025  CHF    35.520
UniCredit Bank GmbH      19.100   9/27/2024  EUR    31.440
Landesbank Baden-Wuertt  13.000   6/27/2025  EUR    15.070
Landesbank Baden-Wuertt  16.000   6/27/2025  EUR    16.510
Landesbank Baden-Wuertt  15.000    1/3/2025  EUR    13.420
Landesbank Baden-Wuertt  16.000   6/27/2025  EUR    15.590
Landesbank Baden-Wuertt  19.000   6/27/2025  EUR    17.480
Vontobel Financial Prod  12.250  12/31/2024  EUR    50.530
DZ Bank AG Deutsche Zen  16.400   3/28/2025  EUR    47.210
Landesbank Baden-Wuertt  13.000   4/24/2026  EUR    22.780
Landesbank Baden-Wuertt  10.500   4/24/2026  EUR    19.440
Landesbank Baden-Wuertt  11.500   4/24/2026  EUR    20.710
Raiffeisen Schweiz Geno  16.000   2/19/2025  CHF    47.170
DZ Bank AG Deutsche Zen  12.000   9/25/2024  EUR     9.860
DZ Bank AG Deutsche Zen  10.750  12/27/2024  EUR    50.980
Leonteq Securities AG    18.000  12/27/2024  CHF    48.360
Leonteq Securities AG    21.000  10/30/2024  CHF    27.650
Leonteq Securities AG    21.000    1/3/2025  CHF    24.550
Leonteq Securities AG    25.000    1/3/2025  CHF    40.550
Leonteq Securities AG/G  22.000   10/2/2024  CHF    32.770
UniCredit Bank GmbH      18.500   9/27/2024  EUR    35.180
UniCredit Bank GmbH      14.200   9/27/2024  EUR    39.320
UniCredit Bank GmbH      15.600   9/27/2024  EUR    51.370
UniCredit Bank GmbH      16.900   9/27/2024  EUR    49.510
Bank Julius Baer & Co L  11.150  11/25/2024  USD    47.200
UniCredit Bank GmbH      18.500  12/31/2024  EUR    39.760
Vontobel Financial Prod  13.500   9/27/2024  EUR    46.110
DZ Bank AG Deutsche Zen  10.250   9/25/2024  EUR    46.300
DZ Bank AG Deutsche Zen  10.500  12/27/2024  EUR    46.110
DZ Bank AG Deutsche Zen  21.300  12/31/2024  EUR    42.390
Vontobel Financial Prod  18.000   9/27/2024  EUR    40.120
DZ Bank AG Deutsche Zen  11.000  12/20/2024  EUR    46.230
Vontobel Financial Prod  14.500   9/27/2024  EUR    49.400
Landesbank Baden-Wuertt  10.500  11/22/2024  EUR    11.280
BNP Paribas Issuance BV  19.000   9/18/2026  EUR     0.980
Leonteq Securities AG    25.000  12/18/2024  CHF    43.810
UniCredit Bank GmbH      10.700   2/28/2025  EUR    37.240
UniCredit Bank GmbH      11.700   2/28/2025  EUR    36.050
Landesbank Baden-Wuertt  15.000   9/27/2024  EUR    10.690
Landesbank Baden-Wuertt  17.000   9/27/2024  EUR     9.740
UniCredit Bank GmbH      14.500  11/22/2024  EUR    40.640
HSBC Trinkaus & Burkhar  14.500   9/27/2024  EUR    16.200
HSBC Trinkaus & Burkhar  14.500  12/30/2024  EUR     7.520
Vontobel Financial Prod  12.500   9/27/2024  EUR    42.030
DZ Bank AG Deutsche Zen  13.000  12/27/2024  EUR    50.080
Landesbank Baden-Wuertt  11.800   9/27/2024  EUR    47.910
Landesbank Baden-Wuertt  18.500   9/27/2024  EUR     9.210
UniCredit Bank GmbH      13.800   2/28/2025  EUR    43.770
HSBC Trinkaus & Burkhar  12.900  12/30/2024  EUR    45.900
Vontobel Financial Prod  14.000   9/27/2024  EUR    44.190
HSBC Trinkaus & Burkhar  10.250   9/27/2024  EUR    37.940
HSBC Trinkaus & Burkhar  18.750   9/27/2024  EUR    29.080
UniCredit Bank GmbH      19.100  12/31/2024  EUR    35.990
HSBC Trinkaus & Burkhar  15.200  12/30/2024  EUR    26.490
HSBC Trinkaus & Burkhar  13.100  12/30/2024  EUR    28.270
HSBC Trinkaus & Burkhar  13.400   3/28/2025  EUR    30.070
Landesbank Baden-Wuertt  10.000   6/27/2025  EUR    13.150
Landesbank Baden-Wuertt  14.000   6/27/2025  EUR    14.670
DZ Bank AG Deutsche Zen  10.800   9/27/2024  EUR    38.940
Leonteq Securities AG/G  22.000   9/18/2024  CHF    44.870
UniCredit Bank GmbH      15.700  12/31/2024  EUR    50.790
UniCredit Bank GmbH      19.700  12/31/2024  EUR    33.020
UniCredit Bank GmbH      17.000  12/31/2024  EUR    51.280
UniCredit Bank GmbH      18.000  12/31/2024  EUR    49.000
HSBC Trinkaus & Burkhar  11.900   9/27/2024  EUR    28.040
HSBC Trinkaus & Burkhar  16.300  12/30/2024  EUR    25.780
Landesbank Baden-Wuertt  13.000   3/28/2025  EUR    11.430
Swissquote Bank SA       28.320   9/18/2024  CHF    46.420
UniCredit Bank GmbH      18.800  12/31/2024  EUR    33.750
UniCredit Bank GmbH      18.900  12/31/2024  EUR    46.950
Landesbank Baden-Wuertt  15.000  11/22/2024  EUR    46.530
Landesbank Baden-Wuertt  10.000  11/22/2024  EUR    44.170
Leonteq Securities AG/G  21.000  11/27/2024  EUR    48.220
Raiffeisen Bank Interna  14.558   9/25/2024  EUR    45.290
DZ Bank AG Deutsche Zen  19.100  12/31/2024  EUR    45.930
Vontobel Financial Prod  13.250   9/27/2024  EUR    49.920
Vontobel Financial Prod  19.000   9/27/2024  EUR    42.980
Vontobel Financial Prod  22.250   9/27/2024  EUR    40.230
Raiffeisen Switzerland   14.000  11/27/2024  USD    47.760
Vontobel Financial Prod  16.000   9/27/2024  EUR    46.180
Vontobel Financial Prod  17.000   9/27/2024  EUR    37.360
Vontobel Financial Prod  19.750   9/27/2024  EUR    35.380
Vontobel Financial Prod  10.000   9/27/2024  EUR    45.100
BNP Paribas Emissions-   14.000  12/30/2024  EUR    50.500
BNP Paribas Emissions-   17.000  12/30/2024  EUR    47.140
BNP Paribas Emissions-   16.000  12/30/2024  EUR    33.360
Leonteq Securities AG/G  19.000  11/22/2024  CHF    46.270
DZ Bank AG Deutsche Zen  10.500   9/25/2024  EUR    46.600
Vontobel Financial Prod  12.000   9/27/2024  EUR    42.160
Vontobel Financial Prod  14.500   9/27/2024  EUR    39.610
BNP Paribas Emissions-   17.000  12/30/2024  EUR    32.380
Raiffeisen Schweiz Geno  20.000  10/16/2024  CHF    20.290
UniCredit Bank GmbH      13.700   9/27/2024  EUR    42.490
Finca Uco Cjsc           13.000   5/30/2025  AMD     0.000
Zurcher Kantonalbank Fi  10.500    2/4/2025  EUR    46.850
UniCredit Bank GmbH      19.300  12/31/2024  EUR    38.550
Bank Vontobel AG         20.500   11/4/2024  CHF    29.000
DZ Bank AG Deutsche Zen  14.000  12/20/2024  EUR    41.810
EFG International Finan  20.000   11/8/2024  EUR    47.940
UniCredit Bank GmbH      14.900   9/27/2024  EUR    53.650
Landesbank Baden-Wuertt  16.000  11/22/2024  EUR     9.820
DZ Bank AG Deutsche Zen  13.400  12/31/2024  EUR    42.530
DZ Bank AG Deutsche Zen  10.000   9/27/2024  EUR    36.600
DZ Bank AG Deutsche Zen  11.000   9/27/2024  EUR    34.560
DZ Bank AG Deutsche Zen  15.700   9/27/2024  EUR    46.220
Leonteq Securities AG    25.000  12/11/2024  CHF    39.480
DZ Bank AG Deutsche Zen  13.100   9/27/2024  EUR    31.110
Corner Banca SA          20.000    3/5/2025  USD    45.320
HSBC Trinkaus & Burkhar  10.250  12/30/2024  EUR    40.330
UniCredit Bank GmbH      20.000  12/31/2024  EUR    35.110
Leonteq Securities AG/G  20.000   1/22/2025  CHF    14.050
HSBC Trinkaus & Burkhar  14.400   9/27/2024  EUR    42.870
HSBC Trinkaus & Burkhar  11.500  12/30/2024  EUR    48.710
HSBC Trinkaus & Burkhar  17.500  12/30/2024  EUR    33.290
Raiffeisen Schweiz Geno  15.000   1/22/2025  CHF    35.000
Raiffeisen Schweiz Geno  18.800   9/18/2024  CHF    31.500
Landesbank Baden-Wuertt  11.000   3/28/2025  EUR    11.070
Landesbank Baden-Wuertt  15.000   3/28/2025  EUR    11.930
Raiffeisen Schweiz Geno  10.000   10/4/2024  CHF    34.090
Bank Vontobel AG         13.500    1/8/2025  CHF     7.100
DZ Bank AG Deutsche Zen  18.500   9/27/2024  EUR    41.570
Vontobel Financial Prod  14.250  12/31/2024  EUR    50.170
Vontobel Financial Prod  11.250  12/31/2024  EUR    49.320
Landesbank Baden-Wuertt  12.000    1/3/2025  EUR    11.110
Landesbank Baden-Wuertt  15.000    1/3/2025  EUR    10.510
DZ Bank AG Deutsche Zen  16.000   9/27/2024  EUR    46.730
Swissquote Bank Europe   20.300   1/29/2025  USD    50.100
DZ Bank AG Deutsche Zen  16.500  12/27/2024  EUR    12.530
Landesbank Baden-Wuertt  13.000  10/25/2024  EUR    12.600
Landesbank Baden-Wuertt  16.000  10/25/2024  EUR    11.220
Leonteq Securities AG    24.000   1/13/2025  CHF     8.940
Landesbank Baden-Wuertt  11.500  10/25/2024  EUR    13.540
Landesbank Baden-Wuertt  10.000  10/25/2024  EUR    48.590
Vontobel Financial Prod  15.250  12/31/2024  EUR    49.860
Vontobel Financial Prod  14.250  12/31/2024  EUR    36.830
UniCredit Bank GmbH      14.800   9/27/2024  EUR    40.450
Vontobel Financial Prod  12.500  12/31/2024  EUR    38.250
Vontobel Financial Prod  10.750  12/31/2024  EUR    39.890
Vontobel Financial Prod  17.500  12/31/2024  EUR    47.210
Basler Kantonalbank      12.000   2/17/2025  CHF    47.910
Leonteq Securities AG/G  20.800    2/5/2025  CHF    48.990
Vontobel Financial Prod  11.000  12/31/2024  EUR    32.390
Landesbank Baden-Wuertt  12.000   9/27/2024  EUR    49.990
Vontobel Financial Prod  13.250   9/27/2024  EUR    44.830
Vontobel Financial Prod  10.750   9/27/2024  EUR    50.040
Swissquote Bank Europe   16.030   1/16/2025  USD    49.510
Vontobel Financial Prod  20.250  12/31/2024  EUR    13.445
BNP Paribas Emissions-   13.000  12/30/2024  EUR    46.600
DZ Bank AG Deutsche Zen  20.300  12/31/2024  EUR    52.050
Vontobel Financial Prod  13.000  12/31/2024  EUR    38.410
Vontobel Financial Prod  16.750  12/31/2024  EUR    35.950
Vontobel Financial Prod  14.750  12/31/2024  EUR    46.490
Vontobel Financial Prod  20.000  12/31/2024  EUR    42.610
DZ Bank AG Deutsche Zen  15.500  12/31/2024  EUR    38.170
Vontobel Financial Prod  11.000  12/31/2024  EUR    39.910
Vontobel Financial Prod  14.750  12/31/2024  EUR    37.050
Vontobel Financial Prod  12.500  12/31/2024  EUR    49.140
Vontobel Financial Prod  17.250  12/31/2024  EUR    44.340
DZ Bank AG Deutsche Zen  10.750  12/27/2024  EUR    50.090
Landesbank Baden-Wuertt  14.000   1/24/2025  EUR    10.970
Vontobel Financial Prod  16.000   3/28/2025  EUR    17.306
Leonteq Securities AG/G  10.340   8/31/2026  EUR    44.480
Vontobel Financial Prod  15.500   9/27/2024  EUR    41.220
UniCredit Bank GmbH      14.600   2/28/2025  EUR    51.720
UniCredit Bank GmbH      12.800   2/28/2025  EUR    34.780
UniCredit Bank GmbH      13.100   2/28/2025  EUR    45.100
UniCredit Bank GmbH      14.500   2/28/2025  EUR    42.390
HSBC Trinkaus & Burkhar  13.500  12/30/2024  EUR    50.030
HSBC Trinkaus & Burkhar  14.500   9/27/2024  EUR    46.730
DZ Bank AG Deutsche Zen  20.400   9/27/2024  EUR    36.260
UniCredit Bank GmbH      13.700   9/27/2024  EUR    40.580
Vontobel Financial Prod  18.000  12/31/2024  EUR    46.270
DZ Bank AG Deutsche Zen  10.750  12/27/2024  EUR    10.190
UniCredit Bank GmbH      16.600  12/31/2024  EUR    47.240
UniCredit Bank GmbH      16.100  12/31/2024  EUR    53.880
UniCredit Bank GmbH      19.800  12/31/2024  EUR    45.130
HSBC Trinkaus & Burkhar  16.800   9/27/2024  EUR    22.900
HSBC Trinkaus & Burkhar  14.300   9/27/2024  EUR    25.190
Landesbank Baden-Wuertt  10.500   6/27/2025  EUR    51.180
HSBC Trinkaus & Burkhar  11.600   3/28/2025  EUR    31.770
HSBC Trinkaus & Burkhar  15.700  12/30/2024  EUR     6.300
HSBC Trinkaus & Burkhar  17.700   9/27/2024  EUR     9.010
HSBC Trinkaus & Burkhar  18.100  12/30/2024  EUR     6.590
Leonteq Securities AG    20.000   9/18/2024  CHF    17.900
UniCredit Bank GmbH      16.600  12/31/2024  EUR    49.200
UniCredit Bank GmbH      15.100  12/31/2024  EUR    49.810
HSBC Trinkaus & Burkhar  11.100  12/30/2024  EUR    30.630
Leonteq Securities AG    24.000   1/16/2025  CHF    35.240
Raiffeisen Switzerland   11.800   1/15/2025  CHF    48.550
Raiffeisen Switzerland   13.900   1/15/2025  EUR    49.130
UniCredit Bank GmbH      12.300   9/27/2024  EUR    41.830
UniCredit Bank GmbH      10.700   9/27/2024  EUR    43.880
UniCredit Bank GmbH      16.300   9/27/2024  EUR    37.130
Raiffeisen Schweiz Geno  19.000   10/2/2024  CHF    33.640
UniCredit Bank GmbH      16.550   8/18/2025  USD    20.920
UBS AG/London            21.600    8/2/2027  SEK    21.330
Finca Uco Cjsc           12.000   2/10/2025  AMD     0.000
Lehman Brothers Treasur  11.000  12/19/2011  USD     0.100
Lehman Brothers Treasur  15.000   3/30/2011  EUR     0.100
Lehman Brothers Treasur  14.900   9/15/2008  EUR     0.100
Lehman Brothers Treasur  13.500  11/28/2008  USD     0.100
Bulgaria Steel Finance   12.000    5/4/2013  EUR     0.216
DZ Bank AG Deutsche Zen  11.800   9/27/2024  EUR    44.940
UniCredit Bank GmbH      14.300  11/22/2024  EUR    50.730
UniCredit Bank GmbH      10.900  11/22/2024  EUR    38.370
UniCredit Bank GmbH      10.000  11/22/2024  EUR    40.480
UniCredit Bank GmbH      11.900  11/22/2024  EUR    36.530
UniCredit Bank GmbH      11.000  11/22/2024  EUR    44.640
National Mortgage Co RC  12.000   3/30/2026  AMD     0.000
Evocabank CJSC           11.000   9/27/2025  AMD     9.542
ACBA Bank OJSC           11.500    3/1/2026  AMD     0.000
UniCredit Bank GmbH      14.900  11/22/2024  EUR    49.340
UniCredit Bank GmbH      13.700  11/22/2024  EUR    52.220
UniCredit Bank GmbH      13.000  11/22/2024  EUR    34.920
UniCredit Bank GmbH      10.200  11/22/2024  EUR    46.120
Leonteq Securities AG/G  10.000  11/12/2024  CHF    43.050
Bank Vontobel AG         10.000   11/4/2024  EUR    46.800
Vontobel Financial Prod  15.500   9/27/2024  EUR    45.530
Vontobel Financial Prod  21.000   9/27/2024  EUR    34.190
Landesbank Baden-Wuertt  12.000   1/24/2025  EUR    10.300
Vontobel Financial Prod  18.000   9/27/2024  EUR    42.990
Vontobel Financial Prod  11.500   9/27/2024  EUR    51.930
Zurcher Kantonalbank Fi  19.500   9/18/2024  CHF    47.070
Leonteq Securities AG/G  11.000  10/11/2024  CHF    48.980
Zurcher Kantonalbank Fi  12.000   10/4/2024  EUR    48.740
Leonteq Securities AG    24.000   9/25/2024  CHF    34.530
Raiffeisen Schweiz Geno  20.000   9/25/2024  CHF    18.450
Raiffeisen Schweiz Geno  20.000   9/25/2024  CHF    28.500
Landesbank Baden-Wuertt  11.000   1/24/2025  EUR    47.680
Vontobel Financial Prod  13.500   9/27/2024  EUR    48.490
UniCredit Bank GmbH      18.800  12/31/2024  EUR    30.220
UniCredit Bank GmbH      18.000  12/31/2024  EUR    30.800
UniCredit Bank GmbH      17.200  12/31/2024  EUR    31.430
UniCredit Bank GmbH      19.600  12/31/2024  EUR    29.690
Leonteq Securities AG/G  12.000  10/11/2024  EUR    40.760
Leonteq Securities AG    23.000  12/27/2024  CHF    31.230
Landesbank Baden-Wuertt  15.500   1/24/2025  EUR    10.190
Landesbank Baden-Wuertt  15.500   9/27/2024  EUR     7.260
Landesbank Baden-Wuertt  11.000  11/22/2024  EUR    11.370
Landesbank Baden-Wuertt  14.500  11/22/2024  EUR    10.040
HSBC Trinkaus & Burkhar  20.000   9/27/2024  EUR    10.680
HSBC Trinkaus & Burkhar  17.400  12/30/2024  EUR     7.220
Corner Banca SA          10.000   11/8/2024  CHF    41.740
HSBC Trinkaus & Burkhar  17.500   6/27/2025  EUR    12.620
HSBC Trinkaus & Burkhar  10.250   6/27/2025  EUR    38.930
HSBC Trinkaus & Burkhar  12.750   6/27/2025  EUR    10.130
HSBC Trinkaus & Burkhar  13.500   6/27/2025  EUR    50.860
HSBC Trinkaus & Burkhar  15.500   6/27/2025  EUR    37.750
UBS AG/London            12.000   11/4/2024  EUR    45.600
BNP Paribas Emissions-   16.000  12/30/2024  EUR    46.730
BNP Paribas Emissions-   17.000  12/30/2024  EUR    44.190
UniCredit Bank GmbH      13.400   9/27/2024  EUR    44.800
HSBC Trinkaus & Burkhar  22.250   6/27/2025  EUR    15.870
HSBC Trinkaus & Burkhar  11.250   6/27/2025  EUR    44.010
Leonteq Securities AG    24.000  12/27/2024  CHF    35.520
Bank Vontobel AG         15.500  11/18/2024  CHF    27.800
UniCredit Bank GmbH      11.000   9/19/2024  EUR    48.630
UBS AG/London            14.000   9/25/2028  EUR    46.970
Landesbank Baden-Wuertt  13.000   9/27/2024  EUR    47.940
DZ Bank AG Deutsche Zen  15.200  12/31/2024  EUR    48.300
Landesbank Baden-Wuertt  13.000   9/27/2024  EUR    49.440
Landesbank Baden-Wuertt  11.500   9/27/2024  EUR     9.310
UniCredit Bank GmbH      19.300  12/31/2024  EUR    37.250
UniCredit Bank GmbH      14.700  11/22/2024  EUR    42.560
UniCredit Bank GmbH      12.900  11/22/2024  EUR    33.410
Vontobel Financial Prod  18.000   9/27/2024  EUR    24.860
Vontobel Financial Prod  10.500   9/27/2024  EUR    46.410
Vontobel Financial Prod  12.750   9/27/2024  EUR    51.760
UniCredit Bank GmbH      14.200  11/22/2024  EUR    32.160
Vontobel Financial Prod  20.000   9/27/2024  EUR    45.500
DZ Bank AG Deutsche Zen  14.000   9/27/2024  EUR    37.260
Vontobel Financial Prod  12.250   9/27/2024  EUR    51.860
Vontobel Financial Prod  10.000   9/27/2024  EUR    31.620
Vontobel Financial Prod  13.250   9/27/2024  EUR    28.850
DZ Bank AG Deutsche Zen  14.500   3/28/2025  EUR    49.830
DZ Bank AG Deutsche Zen  18.200   3/28/2025  EUR    45.940
UniCredit Bank GmbH      10.700  11/22/2024  EUR    46.220
UniCredit Bank GmbH      10.400   2/28/2025  EUR    48.690
UniCredit Bank GmbH      11.600   2/28/2025  EUR    46.280
UniCredit Bank GmbH      13.900  11/22/2024  EUR    44.510
UniCredit Bank GmbH      13.500   2/28/2025  EUR    47.540
Landesbank Baden-Wuertt  10.000  10/24/2025  EUR    14.790
Bank Vontobel AG         12.000  11/11/2024  CHF    46.600
DZ Bank AG Deutsche Zen  17.800   9/27/2024  EUR    26.590
DZ Bank AG Deutsche Zen  17.900   9/27/2024  EUR    39.500
DZ Bank AG Deutsche Zen  12.000   9/27/2024  EUR    33.070
Leonteq Securities AG/G  20.000   9/26/2024  USD    11.820
Inecobank CJSC           10.000   4/28/2025  AMD     0.000
Vontobel Financial Prod  12.750  12/31/2024  EUR    48.380
UBS AG/London            10.500   9/23/2024  EUR    47.750
DZ Bank AG Deutsche Zen  14.400   9/27/2024  EUR    30.990
DZ Bank AG Deutsche Zen  14.700   9/27/2024  EUR    45.100
DZ Bank AG Deutsche Zen  14.500   9/27/2024  EUR    46.390
DZ Bank AG Deutsche Zen  16.800   9/27/2024  EUR    41.770
DZ Bank AG Deutsche Zen  23.500   9/27/2024  EUR    33.520
UniCredit Bank GmbH      18.600  12/31/2024  EUR    42.940
UniCredit Bank GmbH      12.800  10/10/2024  EUR    45.130
Vontobel Financial Prod  13.250  12/31/2024  EUR    46.620
Landesbank Baden-Wuertt  14.000  10/24/2025  EUR    17.940
UBS AG/London            11.250   9/16/2024  EUR    48.150
UBS AG/London            13.000   9/30/2024  CHF    11.660
Bank Vontobel AG         18.000   12/4/2024  USD    50.100
HSBC Trinkaus & Burkhar  15.100  12/30/2024  EUR    38.790
HSBC Trinkaus & Burkhar  12.500  12/30/2024  EUR    43.260
HSBC Trinkaus & Burkhar  11.800   9/27/2024  EUR    26.510
HSBC Trinkaus & Burkhar  16.100  12/30/2024  EUR    25.260
HSBC Trinkaus & Burkhar  15.900   3/28/2025  EUR    27.850
HSBC Trinkaus & Burkhar  13.300   6/27/2025  EUR    31.280
HSBC Trinkaus & Burkhar  10.400  10/25/2024  EUR    28.740
HSBC Trinkaus & Burkhar  12.600  11/22/2024  EUR    26.950
HSBC Trinkaus & Burkhar  10.300  11/22/2024  EUR    29.450
UniCredit Bank GmbH      15.100   9/27/2024  EUR    50.360
UniCredit Bank GmbH      16.400   9/27/2024  EUR    47.490
Vontobel Financial Prod  13.750  12/31/2024  EUR    48.400
Bank Vontobel AG         21.000  12/23/2024  CHF    50.000
HSBC Trinkaus & Burkhar  17.600   9/27/2024  EUR    33.830
HSBC Trinkaus & Burkhar  10.800  12/30/2024  EUR    47.180
HSBC Trinkaus & Burkhar  17.800   9/27/2024  EUR    21.440
HSBC Trinkaus & Burkhar  11.100  12/30/2024  EUR    29.110
HSBC Trinkaus & Burkhar  15.000   3/28/2025  EUR    28.280
HSBC Trinkaus & Burkhar  11.300   6/27/2025  EUR    32.670
HSBC Trinkaus & Burkhar  12.800  10/25/2024  EUR    26.080
HSBC Trinkaus & Burkhar  15.600  11/22/2024  EUR    24.590
Corner Banca SA          18.500   9/23/2024  CHF     5.390
Armenian Economy Develo  11.000   10/3/2025  AMD     0.000
UniCredit Bank GmbH      19.500  12/31/2024  EUR    41.480
Vontobel Financial Prod  17.000   9/27/2024  EUR    48.620
Vontobel Financial Prod  18.500   9/27/2024  EUR    47.010
Vontobel Financial Prod  20.500   9/27/2024  EUR    36.850
Lehman Brothers Treasur  13.000   7/25/2012  EUR     0.100
HSBC Trinkaus & Burkhar  12.400   9/27/2024  EUR    49.890
Landesbank Baden-Wuertt  11.000    1/3/2025  EUR     8.260
Landesbank Baden-Wuertt  13.000    1/3/2025  EUR     8.240
HSBC Trinkaus & Burkhar  15.900   9/27/2024  EUR    47.540
HSBC Trinkaus & Burkhar  14.300   9/27/2024  EUR    46.140
DZ Bank AG Deutsche Zen  12.000   9/25/2024  EUR     9.270
Landesbank Baden-Wuertt  14.000  11/22/2024  EUR    48.480
Landesbank Baden-Wuertt  18.000  11/22/2024  EUR     9.370
HSBC Trinkaus & Burkhar  19.600  12/30/2024  EUR     7.450
HSBC Trinkaus & Burkhar  18.300   9/27/2024  EUR    42.640
UniCredit Bank GmbH      10.500  12/22/2025  EUR    42.140
UniCredit Bank GmbH      10.500    4/7/2026  EUR    34.190
Raiffeisen Schweiz Geno  10.000  12/31/2024  CHF    47.980
Bank Julius Baer & Co L  12.720   2/17/2025  CHF    26.350
Lehman Brothers Treasur  18.250   10/2/2008  USD     0.100
Petromena ASA            10.850  11/19/2018  USD     0.622
Lehman Brothers Treasur  11.000  12/20/2017  AUD     0.100
Lehman Brothers Treasur  14.900  11/16/2010  EUR     0.100
Lehman Brothers Treasur  16.000   10/8/2008  CHF     0.100
Lehman Brothers Treasur  11.000  12/20/2017  AUD     0.100
Lehman Brothers Treasur  11.000   2/16/2009  CHF     0.100
UniCredit Bank GmbH      10.700   2/17/2025  EUR    22.440
Lehman Brothers Treasur  11.750    3/1/2010  EUR     0.100
Societe Generale SA      20.000   9/18/2026  USD    12.500
Lehman Brothers Treasur  10.000   2/16/2009  CHF     0.100
Lehman Brothers Treasur  11.000  12/20/2017  AUD     0.100
UniCredit Bank GmbH      10.700    2/3/2025  EUR    22.200
ASCE Group OJSC          12.000   6/11/2031  AMD     0.000
Erste Group Bank AG      14.500   5/31/2026  EUR    28.850
UniCredit Bank GmbH      10.300   9/27/2024  EUR    34.510
Lehman Brothers Treasur  13.000   2/16/2009  CHF     0.100
Armenian Economy Develo  10.500    5/4/2025  AMD     0.000
Landesbank Baden-Wuertt  11.500  10/25/2024  EUR     6.230
Lehman Brothers Treasur  16.000   11/9/2008  USD     0.100
Lehman Brothers Treasur  10.442  11/22/2008  CHF     0.100
Lehman Brothers Treasur  13.432    1/8/2009  ILS     0.100
EFG International Finan  11.120  12/27/2024  EUR    36.520
Lehman Brothers Treasur  13.150  10/30/2008  USD     0.100
Lehman Brothers Treasur  14.100  11/12/2008  USD     0.100
Lehman Brothers Treasur  11.000    7/4/2011  USD     0.100
Lehman Brothers Treasur  16.800   8/21/2009  USD     0.100
Lehman Brothers Treasur  13.500    6/2/2009  USD     0.100
Lehman Brothers Treasur  12.400   6/12/2009  USD     0.100
Lehman Brothers Treasur  10.000   6/17/2009  USD     0.100
Lehman Brothers Treasur  11.000    7/4/2011  CHF     0.100
Lehman Brothers Treasur  16.000  12/26/2008  USD     0.100
Lehman Brothers Treasur  16.000  10/28/2008  USD     0.100
Lehman Brothers Treasur  10.600   4/22/2014  MXN     0.100
Lehman Brothers Treasur  10.000   5/22/2009  USD     0.100
Lehman Brothers Treasur  17.000    6/2/2009  USD     0.100
Lehman Brothers Treasur  23.300   9/16/2008  USD     0.100
Lehman Brothers Treasur  12.000    7/4/2011  EUR     0.100
Lehman Brothers Treasur  10.000  10/23/2008  USD     0.100
Lehman Brothers Treasur  16.200   5/14/2009  USD     0.100
Lehman Brothers Treasur  15.000    6/4/2009  CHF     0.100
Lehman Brothers Treasur  10.000  10/22/2008  USD     0.100
Landesbank Baden-Wuertt  10.000  10/25/2024  EUR     6.760
Credit Agricole Corpora  10.200  12/13/2027  TRY    47.246
Lehman Brothers Treasur  11.250  12/31/2008  USD     0.100
Lehman Brothers Treasur  13.000  12/14/2012  USD     0.100
Lehman Brothers Treasur  12.000   7/13/2037  JPY     0.100
Lehman Brothers Treasur  10.000   6/11/2038  JPY     0.100
Lehman Brothers Treasur  10.500    8/9/2010  EUR     0.100
Goldman Sachs Internati  16.288   3/17/2027  USD    23.260
Privatbank CJSC Via UK   10.875   2/28/2018  USD     5.324
UBS AG/London            14.500  10/14/2024  CHF    25.820
Sidetur Finance BV       10.000   4/20/2016  USD     0.784
Bank Vontobel AG         10.000  10/21/2024  CHF    55.200
Teksid Aluminum Luxembo  12.375   7/15/2011  EUR     0.619
Phosphorus Holdco PLC    10.000    4/1/2019  GBP     0.807
Lehman Brothers Treasur  10.000   3/27/2009  USD     0.100
Lehman Brothers Treasur  11.000   6/29/2009  EUR     0.100
Leonteq Securities AG/G  13.000  10/21/2024  EUR    47.400
UBS AG/London            15.750  10/21/2024  CHF    26.940
BLT Finance BV           12.000   2/10/2015  USD    10.500
HSBC Trinkaus & Burkhar  14.800  12/30/2024  EUR    41.990
HSBC Trinkaus & Burkhar  11.200  12/30/2024  EUR    49.850
HSBC Trinkaus & Burkhar  15.400   9/27/2024  EUR    23.990
HSBC Trinkaus & Burkhar  11.400  12/30/2024  EUR    29.930
HSBC Trinkaus & Burkhar  16.000   3/28/2025  EUR    28.320
HSBC Trinkaus & Burkhar  11.500   6/27/2025  EUR    33.470
HSBC Trinkaus & Burkhar  16.300   3/28/2025  EUR     8.200
HSBC Trinkaus & Burkhar  19.600  11/22/2024  EUR     5.810
HSBC Trinkaus & Burkhar  15.700  11/22/2024  EUR    25.120
HSBC Trinkaus & Burkhar  10.000  11/22/2024  EUR    31.120
HSBC Trinkaus & Burkhar  15.400   9/27/2024  EUR    40.080
Vontobel Financial Prod  22.500   9/27/2024  EUR    37.740
Vontobel Financial Prod  24.500   9/27/2024  EUR     6.119
DZ Bank AG Deutsche Zen  13.900   3/28/2025  EUR    13.360
UBS AG/London            11.000   1/20/2025  EUR    48.550
HSBC Trinkaus & Burkhar  17.300   9/27/2024  EUR    36.860
HSBC Trinkaus & Burkhar  13.400  12/30/2024  EUR    44.510
HSBC Trinkaus & Burkhar  18.000   9/27/2024  EUR    21.920
HSBC Trinkaus & Burkhar  12.100   9/27/2024  EUR    27.250
HSBC Trinkaus & Burkhar  14.100  12/30/2024  EUR    27.320
HSBC Trinkaus & Burkhar  15.100   3/28/2025  EUR    28.800
HSBC Trinkaus & Burkhar  11.000   3/28/2025  EUR    32.220
HSBC Trinkaus & Burkhar  13.400   6/27/2025  EUR    31.550
HSBC Trinkaus & Burkhar  17.500   9/27/2024  EUR     7.300
HSBC Trinkaus & Burkhar  15.200  12/30/2024  EUR     5.670
HSBC Trinkaus & Burkhar  14.400   3/28/2025  EUR     7.390
HSBC Trinkaus & Burkhar  13.100  10/25/2024  EUR    26.770
HSBC Trinkaus & Burkhar  10.200  10/25/2024  EUR    30.450
HSBC Trinkaus & Burkhar  12.800  11/22/2024  EUR    27.640
HSBC Trinkaus & Burkhar  13.900  12/30/2024  EUR    43.390
HSBC Trinkaus & Burkhar  12.800   3/28/2025  EUR    44.880
HSBC Trinkaus & Burkhar  11.500   3/28/2025  EUR    46.920
HSBC Trinkaus & Burkhar  11.300  11/22/2024  EUR    47.690
DZ Bank AG Deutsche Zen  11.500   9/25/2024  EUR    50.280
Vontobel Financial Prod  16.500   9/27/2024  EUR    46.190
Vontobel Financial Prod  10.500   9/27/2024  EUR    49.540



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S U B S C R I P T I O N   I N F O R M A T I O N

Troubled Company Reporter-Europe is a daily newsletter co-
published by Bankruptcy Creditors' Service, Inc., Fairless Hills,
Pennsylvania, USA, and Beard Group, Inc., Washington, D.C., USA.
Marites O. Claro, Rousel Elaine T. Fernandez, Joy A. Agravante,
Julie Anne L. Toledo, Ivy B. Magdadaro, and Peter A. Chapman,
Editors.

Copyright 2024.  All rights reserved.  ISSN 1529-2754.

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