Fitch's rating actions reflect continuing headwinds from mark-to-market valuations on various asset classes in BANA's capital market units as well as headwinds facing its consumer and potentially its commercial credit portfolio. Fitch expects the headwinds from asset valuations to decline going forward since these positions have been substantially reduced through writedowns and other mitigation efforts. On the other hand, Fitch expects BANA will continue to experience pressure from its consumer lending activities in the near future. The primary point of pressure to date has been BAC's sizeable home equity loan portfolio with significant exposure to the most problematic U.S. housing markets, including California and Florida. Looking forward, Fitch believes that BANA could experience credit pressure from other sources, including its credit card portfolio, the option ARM portfolio acquired from CFSB and its affiliates, and commercial loans.

That said, Fitch recognizes BANA's strengths, including its broad consumer loan and deposit franchise, the diversity of its operations, its liquid balance sheet and its access to external funding. Fitch believes that BANA's risk profile is aligned with the current ratings and Rating Outlook.

Fitch believes that pending litigation surrounding CFSB and CFC adds an additional risk element to these entities as well as to the parent BAC and other non-bank entities in the holding company structure. Accordingly, Fitch has assigned these entities a long-term IDR one notch lower than that assigned to the banks, at `A+.' This results in an upgrade for the CFC entities and a downgrade for Bank of America Corporation and its legacy non-bank affiliates. In recognition of BAC's liquid balance sheet, we have affirmed its short-term rating at `F1+.'

CFSB retains a higher than normal risk profile among BAC's subsidiaries and its Individual rating has been set one notch lower, at `B/C,' to reflect this. Fitch does not expect CFC and its non-bank subsidiary Countrywide Home Loans Inc. to remain active issuers of debt; consequently their IDRs have been upgraded and withdrawn. We have also withdrawn CFC's Individual and Support ratings.

Fitch expects to maintain CFSB's and parent BAC's long-term IDRs one notch below those of the legacy bank subsidiary ratings while litigation risk, and the potential for meaningful contingent liability remains significant.

Fitch has removed from Rating Watch Negative and downgraded the following:

Bank of America N.A.

--Long-term deposits to `AA' from 'AA+';

--Long-term IDR to `AA-' from 'AA';

--Long-term senior debt to `AA-' from 'AA';

--Long-term subordinated debt to `A+' from 'AA-'

--Individual to `B' from 'A/B';

FIA Card Services N.A.

--Long-term IDR to `AA-' from 'AA';

--Long-term senior debt to `AA-' from 'AA';

--Long-term subordinated debt to `A+' from 'AA-'

--Individual to `B' from 'A/B';

MBNA Europe Bank Ltd.

--Long-term IDR to `AA-' from 'AA';

--Long-term senior debt to `AA-' from 'AA'

--Long-term subordinated debt to `A+' from 'AA-'

--Individual to `B' from 'A/B';

MBNA Canada Bank

--Long-term IDR to `AA-' from 'AA'

--Long-term senior debt to `AA-' from 'AA'

--Long-term subordinated debt to `A+' from 'AA-'

Banc of America Securities Limited

--Long-term IDR to `AA-' from 'AA'

B of A Issuance B.V.

--Long-term IDR to `AA-' from 'AA';

--Long-term senior debt to `AA-' from 'AA';

--Long-term subordinated debt to `A+' from 'AA-';

Bank of America Georgia, N.A.

--Long-term IDR to `AA-' from 'AA';

--Individual to `B' from 'A/B'

Bank of America Oregon, National Association

--Long-term IDR to `AA-' from 'AA';

--Individual to `B' from 'A/B';

Bank of America Rhode Island, National Association

--Long-term IDR to `AA-' from 'AA';

--Individual to `B' from 'A/B';

Bank of America California, National Association

--Long-term IDR to `AA-' from 'AA';

--Individual to `B' from 'A/B';

LaSalle Bank N.A.

LaSalle Bank Midwest N.A.

United States Trust N.A.

--Long-term Deposits to `AA' from 'AA+';

--Long-term IDR to `AA-' from `AA';

--Individual to `B' from 'A/B';

Fleet National Bank

--Long-term subordinated debt to `A+' from 'AA-';

NationsBank, N.A.

--Long-term senior debt to `AA-' from 'AA.';

Bank of America Corporation

--Long-term IDR to `A+' from 'AA'

--Long-term senior debt to `A+' from 'AA';

--Long-term subordinated debt to `A' from 'AA-'

--Preferred stock to `A' from 'AA-'

--Individual to `B' from 'A/B';

LaSalle Bank Corporation

--Long-term IDR to `A+' from 'AA'

--Individual to `B' from 'A/B';

Banc of America Securities LLC

--Long-term IDR to `A+' from 'AA'

BankAmerica Corporation

--Long-term senior debt to `A+' from 'AA'

--Long-term subordinated debt to `A' from 'AA-'

--Preferred stock to `A' from 'AA-';

BankBoston Corporation

--Long-term subordinated debt to `A' from 'AA-';

FleetBoston Financial Corp

--Long-term subordinated debt to `A' from 'AA-'

LaSalle Funding LLC

--Senior notes to `A+' from 'AA';

MBNA Corp.

--Long-term senior debt to `A+' from 'AA'

--Long-term subordinated debt to `A' from 'AA-'

NationsBank Corp

--Long-term senior debt to `A+' from 'AA'

--Long-term subordinated debt to `A' from 'AA-'

NCNB, Inc.

--Long-term subordinated debt to `A' from 'AA-' ;

BAC Capital Trust I - VIII

--Trust preferred securities to `A' from 'AA-';

BAC Capital Trust X - XIV

--Trust preferred securities to `A' from 'AA-';

BankAmerica Capital II, III

--Trust preferred securities to `A' from 'AA-';

BankAmerica Institutional Capital A, B

--Trust preferred securities to `A' from 'AA-'

BankBoston Capital Trust III-IV

--Trust preferred securities to `A' from 'AA-'

Barnett Capital Trust III

--Trust preferred securities to `A' from 'AA-'

Fleet Capital Trust II, V, VIII, IX

--Trust preferred securities to `A' from 'AA-'

MBNA Capital A, B, D, E

--Trust preferred securities to `A' from 'AA-'.

NB Capital Trust II, III, IV

--Trust preferred securities to `A' from 'AA-'

ABN Amro North America Holding Capital Funding LLC I - XIX

--Preferred stock to `A' from 'AA-';

ABN Amro North America Capital Funding Trust I - II

--Trust Preferred Stock to `A' from 'AA-'.

The Rating Outlook is Stable.

Fitch affirms the following ratings:

Bank of America Corporation

--Short-term IDR 'F1+';

--Short-tern debt `F1+';

--Support '5';

--Support Floor `NF';

Bank of America N.A.

--Short-term IDR 'F1+';

--Short-tern deposits `F1+';

--Short-tern debt `F1+';

--Support '1';

--Support Rating Floor `A-'

FIA Card Services N.A.

--Short-term IDR 'F1+';

--Short-tern deposits `F1+';

--Support '1';

--Support Rating Floor `A-'

MBNA Europe Bank Ltd.

--Short-term IDR 'F1+';

--Support '1';

MBNA Canada Bank

--Short-term IDR 'F1+';

Banc of America Securities Limited

--Short-term IDR 'F1+'.

Banc of America Securities LLC

--Short-term IDR 'F1+'

B of A Issuance B.V.

--Support '1'

Bank of America Georgia, N.A.

--Short-term IDR 'F1+';

--Support '1';

--Support Rating Floor `A-'

Bank of America Oregon, National Association

--Short-term IDR 'F1+';

--Support '1';

--Support Rating Floor `A-'

Bank of America Rhode Island, National Association

--Short-term IDR 'F1+';

--Support '1';

--Support Rating Floor `A-'

Bank of America California, National Association

--Short-term IDR 'F1+';

--Support '1';

--Support Rating Floor `A-'

LaSalle Bank N.A.

LaSalle Bank Midwest N.A.

United States Trust N.A.

--Short-term IDR 'F1+';

--Short-tern deposits `F1+';

--Support '1';

--Support Rating Floor `A-'

LaSalle Bank Corporation

--Short-term IDR 'F1+';

--Short-term debt 'F1+';

--Support '5';

--Support Floor `NF';

MBNA Corp.

--Short-term debt 'F1+'.

Fitch removes from Rating Watch Evolving and upgrades the following ratings:

Countrywide Bank FSB

--Long-term IDR to `A+' from 'BBB- ;

--Short-term IDR to `F1' from 'F3';

--Individual to `B/C' from 'C';

--Senior debt to `A+' from 'BBB-';

--Long-term deposits to `AA-' from 'BBB-';

--Short-term deposits to `F1+' from 'F3';

--Short-term debt to `F1' from 'F3';

--Support to `1' from '5';

--Support Floor to `A-' from 'NF';

Countrywide Financial Corp.

--Senior debt to `A+' from 'BBB-'

--Subordinated to `A' from 'BB+;

--Commercial paper to `F1' from 'F3';

Countrywide Home Loans, Inc.

--Senior debt to `A+' from 'BBB- ';

--Commercial paper ' to `F1' from 'F3 ';

Countrywide Capital I, III, IV, V

--Trust preferred to `A' from 'BB'.

The Rating Outlook is Stable.

Fitch has upgraded and withdrawn the following ratings:

Countrywide Financial Corp.

--Long-term IDR to `A+' from 'BBB-;

--Short-term IDR to `F1' from 'F3';

Countrywide Home Loans, Inc.

--Long-term IDR to `A+' from 'BBB- ';

--Short-term IDR to `F1' from 'F3' ;

Fitch has affirmed and withdrawn the following ratings:

Countrywide Financial Corp.

--Individual 'C/D'

--Support '5'

--Support 'NF'

Fitch's rating definitions and the terms of use of such ratings are available on the agency's public site, www.fitchratings.com. Published ratings, criteria and methodologies are available from this site, at all times. Fitch's code of conduct, confidentiality, conflicts of interest, affiliate firewall, compliance and other relevant policies and procedures are also available from the 'Code of Conduct' section of this site.

SOURCE: Fitch Ratings

Fitch Ratings
David Spring, CFA, +1-312-368-3194, Chicago
Sharon Haas, CFA, +1-212-908-1362, New York
Vincent Arscott, CFA, +1-212-908-0872, New York
Media Relations:
Kenneth Reed, +1-212-908-0540, New York

In reaction, ABN Amro said the underlying business, excluding fuel, is trading well, with first half underlying unit revenues up 1.5 percent, underlying unit costs excluding fuel down 0.9 percent.

The broker believes easyJet has a strong business but is heading into tough trading and thinks there will be better times to buy. tf.TFN-Europe_newsdesk@thomsonreuters.com jb1/ra

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In cases of earnings pressure and/or balance-sheet stretch, the broker said it has also reviewed dividend assumptions, and now estimates sizeable dividend cuts for Barratt, Bovis Homes Group Plc., Redrow Plc. and Taylor Wimpey over 2008-2010.

Having analysed the key issues surrounding cash-flow dynamics, and despite an expectation of minimal short-term sector land spend, ABN Amro believes Barratt and Taylor Wimpey are now likely to breach interest cover covenants, with Redrow also close to the mark, the broker said.

ABN Amro said it maintains a valuation-based 'sell' rating on Persimmon Plc., has moved Barratt back to 'sell' from 'hold' given its long land position and the likelihood that equity issuance may be required, and has upgraded Taylor Wimpey to 'hold' from 'sell' following a 34 percent share price decline year-to-date.

The broker concluded that its valuation work suggests sector share prices are not yet factoring in adequate levels of house-price deflation, so it sees little reason to alter its cautious sector stance, despite significant recent weakness in housebuilder share prices. holly.cook@thomsonreuters.com hco/ajb

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WESTPAC BANKING CORPORATION - ASX WBC
CHICAGO MERCANTILE EXCHANGE
RESERVE BANK OF AUSTRALIA
ABN AMRO AUSTRALIA LIMITED
UNITED STATES.  FEDERAL RESERVE BOARD