要点如下：

Capital plans announced so far point to 7% of tier 1 and 10% of CAR as the new thresholds: Pudong, Ningbo and Industrial all announced long-term capital plans in 2H09, with some discussion on the thought process. Tier 1 of 7% is the threshold for approval for L-T sub-debt issuance. CAR of 10% is the threshold for regulator policy support for operations. Banks also plan a buffer above the comfort levels for L-T growth.

Capital raisings would be for L-T growth: Most of listed Chinese banks' capital positions are above the thresholds. Fund raisings would be mainly driven by L-T growth needs, in our view, and would not be an indication of below regulatory levels of capital or the need to repair balance sheets. Fund raisings, if any, would likely be spread among multiple markets and multiple types of investors.
BoComm the lowest tier 1; BOC a more likely capital raising candidate: BoComm's tier 1 is potentially the lowest (<8%) among HK-listed peers in 2010, and it has little capacity for sub-debt. BOC tier 1 could be <9% in 2010 should loan growth exceed estimates. Board resolution on dividend payouts (45% to 60%) affects earnings retained and internal capital generation over the covered periods.

ICBC and CCB ahead of peers on capital; remain core holdings: ICBC and CCB are more able than peers to tap avenues other than equity markets, e.g., sub-debt, if they seek funds, based on our analysis. On dividend payouts, ICBC and CCB are likely to pay out a similar level to BOC. Leaving 2009 dividends (to be paid in 2010) unchanged, at the low end of BOC's range, it would suggest <10% downside to our estimates. We see less need to maintain as high a payout ratio L-T and will review our dividend estimates for 2010 (to be paid in 2011) onwards.