CDS spreads for US banks remained very wide versus comparably rated companies throughout 2011. At the beginning of the year the average CDS-implied rating for the 19 US banks on which we have data was Baa2, or four notches lower than their A1 average Moody’s rating. The average rating declined through the year to A2 due to numerous ratings revisions in 2011 (primarily to reduce uplift from systemic support considerations), but the CDS-implied rating remained at Baa2, or three notches below the average rating.