FINANCIAL INSTITUTIONS

CREDIT OPINION13 November 2019

Update

RATINGS

OTP Bank NyRtDomicile Hungary

Long Term CRR Baa1

Type LT Counterparty RiskRating - Fgn Curr

Outlook Not Assigned

Long Term Debt Withdrawn

Type Senior Unsecured - FgnCurr

Outlook Rating(s) WithDrawn

Long Term Deposit Baa3

Type LT Bank Deposits - FgnCurr

Outlook Stable

Please see the ratings section at the end of this reportfor more information. The ratings and outlook shownreflect information as of the publication date.

Contacts

Melina Skouridou,CFA

+357.2569.3021

AVP-Analystmelina.skouridou@moodys.com

Stelios Kyprou +357.2569.3002Associate Analyststelios.kyprou@moodys.com

Carola Schuler +49.69.70730.766MD-Bankingcarola.schuler@moodys.com

OTP Bank NyRtUpdate to credit analysis

SummaryOTP Bank NyRt's (OTP) Baa1/Prime-2 local-currency deposit ratings incorporate the bank'sstandalone ba1 Baseline Credit Assessment (BCA) and three notches of rating uplift from theapplication of our Advanced Loss Given Failure (LGF) analysis. Our assumptions of moderatesupport from the Government of Hungary (Baa3 stable) result in no further uplift. The bank’sCounterparty Risk (CR) Assessment is Baa2(cr)/Prime-2(cr) and its Counterparty Risk Ratings(CRRs) are Baa1/Prime-2.

OTP's ba1 BCA reflects its (1) geographically diversified footprint across countries in Centraland Eastern Europe (CEE), which complements growth opportunities in its domestic market;(2) elevated asset risk with a high, although declining, level of nonperforming loans (NPLs);and (3) good funding and liquidity. OTP's key strength is its adequate buffers, as reflectedin its (1) good capital levels; (2) strong liquidity; and (3) strong earnings generation, whichsupports its capital.

Exhibit 1

Rating Scorecard - Key financial ratios

10.1% 14.6% 2.1% 6.3% 39.1%

0%

5%

10%

15%

20%

25%

30%

35%

40%

45%

0%

2%

4%

6%

8%

10%

12%

14%

16%

Asset Risk:Problem Loans/

Gross Loans

Capital:Tangible Common

Equity/Risk-WeightedAssets

Profitability:Net Income/

Tangible Assets

Funding Structure:Market Funds/

Tangible BankingAssets

Liquid Resources:Liquid Banking

Assets/TangibleBanking Assets

Solvency Factors (LHS) Liquidity Factors (RHS)

OTP Bank NyRt (BCA: ba1) Median ba1-rated banks

So

lve

ncy F

acto

rs

Liq

uid

ity F

acto

rs

Source: Moody's Financial Metrics

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Credit strengths

» Adequate capital buffers

» Strong profitability, despite volatile earnings from its operations in weaker countries

» Stable deposit-based funding structure and sizeable liquidity buffers

Credit challenges

» High, although declining, level of problem loans

» Exposure to countries with a weaker operating environment than Hungary elevates tail risk

OutlookThe stable outlook on OTP's ratings reflects our view that the bank's credit risk profile will remain broadly stable because asset qualityimprovement will be offset by softening capital buffers.

Factors that could lead to an upgradeOTP's Baa1 local-currency deposit rating and CRRs are at the same level as the Baa1 local-currency deposit ceiling for Hungary and twonotches above the Hungarian government's Baa3 bond rating, the maximum level allowed under our Banks methodology. These ratingsof OTP can only be upgraded if the bank's BCA is upgraded, combined with an upgrade of the government rating and a raising of theceiling.

OTP's Baa3 foreign-currency deposit rating is constrained by the foreign-currency deposit ceiling, and its Baa2(cr) CR Assessment isconstrained by the government's rating and can only be upgraded if the government's rating is upgraded and the ceiling is raised.

The bank's BCA could be upgraded in the event of a further material improvement in its asset quality while maintaining adequatecapitalisation and good profitability. A higher BCA will result in an upgrade of the bank's subordinated and junior subordinated debtratings.

Factors that could lead to a downgradeOTP's ratings could experience negative pressure from a (1) downgrade of the bank's BCA, or (2) reduction in the rating uplift providedby our Advanced LGF analysis.

The bank's BCA could experience downward pressure because of a (1) lower average Macro Profile of the group, driven by the increasingexposure to countries with significantly weaker operating environments than Hungary; and (2) material erosion of the bank's capital ora significant deterioration in its asset quality.

Changes in OTP's liability structure that will reduce the loss-absorption buffer for senior creditors could reduce the uplift provided byour Advanced LGF analysis to the bank's deposit ratings, resulting in a downgrade of its local-currency deposit rating.

The foreign-currency deposit rating would be downgraded in case (1) the Hungarian government's rating is downgraded, resulting in alowering of the country's foreign-currency deposit ceiling; or (2) the bank's deposit ratings are downgraded by more than two notches.

This publication does not announce a credit rating action. For any credit ratings referenced in this publication, please see the ratings tab on the issuer/entity page onwww.moodys.com for the most updated credit rating action information and rating history.

2 13 November 2019 OTP Bank NyRt: Update to credit analysis

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Key indicators

Exhibit 2

OTP Bank NyRt (Consolidated Financials) [1]06-192 12-182 12-172 12-162 12-152 CAGR/Avg.3

Total Assets (HUF Billion) 16,458.4 14,589.5 13,189.3 11,208.1 10,718.1 13.04

Total Assets (USD Million) 58,067.7 51,988.7 51,055.8 38,274.7 36,844.5 13.94

Tangible Common Equity (HUF Billion) 1,852.2 1,623.8 1,426.9 1,221.8 1,039.4 17.94

Tangible Common Equity (USD Million) 6,534.9 5,786.4 5,523.7 4,172.4 3,572.9 18.84

Problem Loans / Gross Loans (%) 7.7 9.0 9.2 14.6 16.9 11.55

Tangible Common Equity / Risk Weighted Assets (%) 14.6 14.3 14.3 15.5 12.2 14.26

Problem Loans / (Tangible Common Equity + Loan Loss Reserve) (%) 30.9 34.0 32.7 45.1 52.9 39.15

Net Interest Margin (%) 4.2 4.4 4.4 4.6 4.8 4.55

PPI / Average RWA (%) 3.6 3.8 4.5 3.9 5.2 4.26

Net Income / Tangible Assets (%) 2.2 2.2 2.2 2.0 0.8 1.95

Cost / Income Ratio (%) 59.6 59.1 57.1 59.8 52.8 57.75

Market Funds / Tangible Banking Assets (%) 6.0 6.3 6.3 7.3 8.5 6.95

Liquid Banking Assets / Tangible Banking Assets (%) 36.3 39.1 41.5 42.7 42.8 40.55

Gross Loans / Due to Customers (%) 80.0 77.2 75.5 78.2 80.4 78.35

[1] All figures and ratios are adjusted using Moody's standard adjustments. [2] Basel III - fully-loaded or transitional phase-in; IFRS. [3] May include rounding differences due to scaleof reported amounts. [4] Compound Annual Growth Rate (%) based on time period presented for the latest accounting regime. [5] Simple average of periods presented for the latestaccounting regime. [6] Simple average of Basel III periods presented.Sources: Moody's Investors Service; company filings

ProfileOTP Bank NyRt (OTP) is Hungary’s dominant bank with significant foreign operations. OTP is currently active in ten other countries:Bulgaria, Croatia, Romania, Russia, Serbia, Slovakia, Montenegro, Albania, Moldova and Ukraine and expects to close its acquisition of aSociete Generale's (A1 stable, baa2)1 Slovenian subsidiary, SKB Banka by year end. Following significant inorganic growth in the last twoyears, the bank announced it does not plan additional acquisitions over the next 12-18 months. OTP acquired two banks in 20172 andwent on to acquire Societe Generale's operations in six Central and Eastern European countries in 20183. As of June 2019, OTP's totalassets were HUF16,458 billion (€50.8 billion) with more than half of its assets outside Hungary. As of June 2019, around 55% of itsloans were to retail clients, with roughly half of it mortgages, 37% were loans to corporates and 8% loans to medium-sized businesses.

In Hungary, OTP had market shares at 28% of total assets and 26% of total deposits as of June 2019, being by far the country's largestbank. The bank is particularly strong in the Hungarian retail market, with a market share of 37% in total retail deposits as of June 2019while the bank was responsible for around one third of new mortgages. Besides its strong domestic franchise, OTP has leading marketpositions in Montenegro (#1), Bulgaria (#1), Serbia (#2), Moldova (#4), Croatia (#4) and is a relatively large consumer lender in Russia.Once the acquisition of SKB is completed OTP will also have the fourth largest bank in Slovenia.

Detailed credit considerationsOTP’s Moderate- Macro Profile reflects its business mix in CEE and RussiaOTP’s credit profile is driven by its operations in selected CEE countries and Russia, with its Hungarian domestic exposure accountingfor 43% of the group’s total assets as of June 2019. These operations have distinct characteristics: the Hungarian and other CEEactivities, especially in Bulgaria, Romania and Croatia have a relatively more stable performance, while OTP’s Russian and Ukrainianoperations are more volatile and may represent a key challenge for the group’s performance.

OTP’s Moderate- Macro Profile reflects the dominance of its operations in Hungary, (with Moderate- macro profile), Romania(Moderate-), Croatia (Moderate-) and Bulgaria (Moderate-) which combined account for 82% of total assets and 79% of net loans.OTP’s operations in Russia (Weak+), 5% of assets and Ukraine (Very Weak), 3% of assets weigh on OTP's macro profile.

High, although declining, level of problem loansWe expect OTP's asset quality to continue to improve and the bank to maintain its good coverage level. These views are reflected inour assigned Asset Risk score of b1, two notches higher than the Macro-Adjusted score.

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The ratio of OTP's nonperforming loans (NPLs4) to gross loans was 7.7% as of June 2019, while its 90-day-past due loans declined to5.5% of gross loans from 8.1% as of June 2018 and 14.7% as of year-end 2016. The improvement in the bank's asset quality was drivenby a reduction in problem loans in all countries, most notably in Hungary, Romania and Ukraine. Benign economic conditions in CEEwill likely support the ongoing reduction in NPLs in these countries. In Russia and Ukraine, where asset quality is among the weakest weexpect asset-quality pressure to ease as economic conditions improve from the previously weak levels.

In its Hungarian operations the NPL ratio declined to 5.3% as of June 2019, from 8.3% as of June 2018. It is now broadly in line withthe average NPL ratio of Hungarian banks but higher than rated foreign owned banks in Hungary. This is mainly because, unlike peerswho have sold significant amounts of problem loans, OTP runs its own work-out unit through its subsidiary OTP Factoring Ltd. Asa result, problem loans may sit at the bank's balance sheet for longer. However, according to the bank this strategy pays off as itsrecoveries are higher than NPL sale values. The group runs similar operations in Serbia, Bulgaria, Slovakia, Romania and Ukraine.

The weakest asset quality is in the group's Ukrainian, Russian and Montenegrin operations. In Ukraine the NPL ratio declined to 21.2%as of the end of June 2019 from 33.1% as of June 2018, mainly driven by sales and write-offs, whereas in Russia, the ratio declined to14.8% from 16.1% over the same period. Asset quality is also very weak in Montenegro with the NPL ratio at 18.6% as of June 2019.

The high asset risk from the bank's sizeable NPLs in Russia and Ukraine is largely mitigated by sizeable loan-loss reserves of 94% and76% of stage 3 loans, respectively. The own coverage of OTP's total stage 3 loans was also good at 65.8% as of the end of June 2019.The total stock of loan loss reserves over problem loans was also a sizeable 87% as of June 2019.

OTP faces higher legal risk in Croatia following the Supreme Court's decision that contracts concerning consumer loans in swiss francscontained abusive clauses and borrowers may sue the banks to seek compensation for higher charges they paid. In Serbia, a law wasintroduced in May allowing for the conversion of swiss franc mortgages to the domestic currency. The banks' loss will be party reducedby a contribution from the government. OTP has booked a provision relating to these loans in its first half financial statements.

Adequate capital buffersAlthough it will remain adequate, we expect OTP's capitalisation to soften because of its fast expansion both organically and throughacquisitions. To reflect this expectation, we assign a ba1 Capital score, one notch lower than the bank's Macro-Adjusted score.

According to the bank, the pro forma impact as of June 2019 on Common Equity Tier 1 (CET1) capital ratio from the Serbian, Moldovan,Montenegrin and Slovenian acquisitions is a 2.8 percentage points reduction in capital. However, we expect part of the reduction to beoffset by the bank's profitability. OTP's return on tangible assets was a strong 2.2% as of the end of June 2019.

OTP reported a sizeable capital buffer, with a CET1 ratio of 15.9% as of the end of June 2019, including the unaudited interim profitand deducting the assumed dividend the bank will pay out, down from 16.5% as of year-end 2018. To include interim profit in theregulatory capital ratios, the bank is required to assume a dividend amount calculated as the multiple of the consolidated accountingprofit and the average dividend pay-out ratio for the preceding three years. The bank's leverage was also strong, with total equity/totalassets of 12.1% as of the end of June 2019.

OTP's Moody's-adjusted Tier 1 capital/risk-weighted assets was 15.9% (2018: 14.0%) and tangible common equity/risk-weightedassets was 14.6% (2018: 14.4%) as of the end of June 2019. Given the different currency composition of the balance sheet and varyingleverage levels of the subsidiaries, the group's capitalisation is sensitive to exchange-rate fluctuations, thereby elevating tail risk.However, we believe the current leverage level provides a good loss-absorption buffer.

On 15 July 2019, OTP Bank issued €500 million Tier 2 capital to optimise the bank's capital structure and support its total capital ratiosfollowing the acquisitions.

Strong profitability despite volatile earnings from operations weaker countriesWe expect OTP's profitability to be pressured by high operating and rising credit costs as new loans season as well as due to netinterest margin compression reflecting the strong competition in the key markets the bank operates. Rising funding costs as thebank gradually begins to issue debt to fill in its Minimum Own Funds and Eligible Liabilities (MREL) requirement will also pressure itsprofitability. As a result, we assign a baa2 score for Profitability, one notch lower than the Macro-Adjusted score.

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OTP has strong earnings generation ability and a high return on assets reflecting its dominant position in its home market as well as thestrong profit contribution from its foreign operations. For the first six months of 2019, these contributed 45% of the bank's adjusted5

net profit.

For the first six months of 2019, the bank reported 15% growth in net income to HUF178 billion from HUF155 billion in the year-earlierperiod resulting in a return on assets of 2.6%. When we exclude the impact of two acquisitions completed during the first half of theyear, net profit grew by 13%. The growth in net profit was very strong across most markets, except Hungary and Bulgaria where netincome grew by 2% and 1% respectively, when we exclude the acquisition of Expressbank in Bulgaria.

Growth in consolidated net income was driven by 15% growth in net interest income and 17% growth in fee and commission incomewhich accounted for around 25% of the bank's operating income. Despite lower interest expense, OTP's net interest margin (NIM)6

eased to 4.2% as of June 2019 from 4.3% as of June 2018. The bank also reported a 36% increase in consolidated non-interest incomefor the first six months of 2019, mainly driven by the gains on securities of around HUF4.9 billion.

OTP's loan-loss provisions increased significantly to HUF9.2 billion in the first six months of 2019 from HUF663 million in the year-earlier period but remain relatively low at 0.19% of gross loans. However, despite overall increased provisions, for the first six months of2019 the bank continued to benefit from significant recoveries of previously provisioned amounts in its home market. The increase intotal credit costs is in line with our expectation that the cost of risk will normalise over the two-year horizon as recoveries from legacyNPLs taper off and the performance of new loans is tested over time.

Stable deposit-based funding structure and good liquidity buffersWe view OTP's funding profile as a credit strength. Our baa3 assigned Funding score is one notch below the Macro-Adjusted scorereflecting our expectation that market funding will increase as the bank gradually issues debt to meet its MREL requirement which isset at 14.73% of the group's total liabilities and own funds, equivalent to 21.89% of risk weighted assets.

OTP's funding remains primarily based on deposits, which accounted for 87% of its total liabilities as of the end of June 2019. Overall,the OTP group reported a loan-to-deposit (LTD) ratio of 80% as of the end of June 2019. At the group level, 73% of deposits are fromretail clients and micro and small enterprises, with the remainder from corporate customers, which we consider more volatile andconfidence-sensitive.

Our assessment also takes into account the funding dependency of OTP's main subsidiaries. The bank's largest subsidiaries, Bulgariaand Croatia (22% and 12% of total assets, respectively) are self-funded, with net LTD ratios of 74% and 91%, respectively as of June2019. However, the bank's Romanian and Russian subsidiaries rely on funding from the parent bank. The Romanian entity relies themost on intergroup funding, although its funding needs fall within the intragroup lending limit of a maximum of 25% of regulatoryconsolidated total capital under Basel III rules. As of the end of June 2019, OTP Romania and OTP Russia (5% each of group assets) hadnet LTD ratios of around 127% and 119%, respectively.

Furthermore, the OTP group is supplementing its funding through OTP's mortgage covered bonds (Baa1) via its subsidiary OTPJelzalogbank Zrt. (OTP Mortgage Bank) (Baa2 stable) and is increasingly placing it with external parties because of the increasedregulatory requirement to finance at least 25% of the bank's outstanding mortgage loans through covered bonds, effective as ofOctober 2019.

The group has sizeable liquidity buffers and we assign a baa3 Liquid Resources score in line with its Macro-Adjusted score. The bank'sliquid assets accounted for 36% of its tangible banking assets as of the end of June 2019 (39% as of year-end 2018), mostly in the formof cash held at the National Bank of Hungary (Baa3 stable) and investments in Hungarian and other government bonds.

Environmental, social and governance considerationsIn line with our general view for the banking sector, OTP has a low exposure to environmental risks. See our Environmental riskheatmaps for further information.

We believe banks face moderate social risks, including OTP. See our Social risk heat map for further information.

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The key social risk Hungarian banks face stems from their endorsement of the government- sponsored “baby loan” scheme7. Thehigh return8 Hungarian banks’ earn on these loans, which are fully guaranteed by the government, may give grounds to the EU’sDirectorate-General for Competition to consider the government’s payment to banks as unlawful state aid. Despite strong demand,baby loans account for a very small percentage of Hungarian banks loans. Nevertheless, banks could suffer reputational damage or aloss, if the scheme is considered to be in violation of EU state aid rules and loans must be called back.

Until September 2019, OTP has disbursed more than 13,000 baby loans worth HUF124 billion, a very small amount relative to itsbalance sheet but a stronger market share than the bank's natural market share in consumer loans.

Governance is highly relevant for OTP, as it is to all companies in the banking industry. Corporate governance weaknesses can leadto a deterioration in a company’s credit quality, while governance strengths can benefit its credit profile. Governance risks are largelyinternal rather than externally driven, and for OTP, we do not have any particular governance concern. Nonetheless, corporategovernance remains a key credit consideration and requires ongoing monitoring.

Source of facts and figures cited in this reportUnless noted otherwise, we have sourced data relating to systemwide trends and market shares from the central bank. Bank-specificfigures originate from banks' reports and Moody's Banking Financial Metrics. All figures are based on our own chart of account andmay be adjusted for analytical purposes. Please refer to the document Financial Statement Adjustments in the Analysis of FinancialInstitutions, published on 9 August 2018.

Support and structural considerationsLoss Given Failure (LGF) analysisOTP is subject to the European Union (EU) Bank Recovery and Resolution Directive (BRRD), which we consider an operationalresolution regime. Therefore, in accordance with our methodology for rating banks globally, we apply our Advanced LGF analysis,which takes into consideration the risks faced by the different debt and deposit classes across the liability structure if the bank entersresolution. We assume a residual tangible common equity of 3%, post-failure losses of 8% of tangible banking assets, a 25% runoffin junior wholesale deposits and a 5% runoff in preferred deposits, and assign a 25% probability to deposits being preferred to seniorunsecured debt, and 26% (EU average) of junior deposits over total deposits. These are in line with our standard assumptions. Weexclude from our balance sheet at-failure deposits and assets related to foreign subsidiaries, which are outside the scope of Hungarianauthorities.

We believe that OTP's deposits are likely to face an extremely low loss given failure because of the loss absorption provided by thevolume of deposits, and significant senior and subordinated debt. This results in a Preliminary Rating Assessment of baa1, three notchesabove the bank's Adjusted BCA of ba1.

Government support considerationsWe believe there is a moderate probability of government support for OTP's wholesale deposits we rate in the event of its failure. Thisprobability reflects the fact that OTP is the largest bank in Hungary, which may lead the government to intervene to prevent a systemiccrisis and, as a result, shield its creditors from disruptive losses.

Set against the above-mentioned conditions, the BRRD restricts the ability of the government to provide such support, even if it waswilling to do so, requiring losses to be imposed on even senior creditors and large depositors under many circumstances. However,our government support assessment does not translate into additional notching for the bank’s deposit ratings because OTP’s baa1Preliminary Rating Assessment is already higher than the sovereign rating.

The likelihood of government support for the bank's subordinated debt, as well as junior subordinated debt, is low and, therefore, theseratings do not include any related rating uplift.

Counterparty Risk (CR) AssessmentThe CR Assessment is an opinion of how counterparty obligations are likely to be treated if a bank fails and are distinct from debtand deposit ratings in that they (1) consider only the risk of default rather than both the likelihood of default and the expectedfinancial loss, and (2) apply to counterparty obligations and contractual commitments rather than debt or deposit instruments. The CR

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Assessment is an opinion of the counterparty risk related to a bank's covered bonds, contractual performance obligations (servicing),derivatives (for example, swaps), letters of credit, guarantees and liquidity financing.

OTP's CR Assessment is positioned at Baa2(cr)/P-2(cr)The CR Assessment is two notches above the bank's Adjusted BCA and capped at one notch above the government rating. The CRAssessment is driven by the seniority of the counterparty obligations and the volume of liabilities subordinated to them under ourAdvanced LGF framework.

Counterparty Risk Ratings (CRRs)CRRs are opinions of the ability of entities to honour the uncollateralised portion of non-debt counterparty financial liabilities (CRRliabilities) and also reflect the expected financial losses in the event such liabilities are not honoured. CRR liabilities typically relateto transactions with unrelated parties. CRRs are distinct from ratings assigned to senior unsecured debt instruments and from issuerratings because they reflect the fact that, in a resolution, CRR liabilities might benefit from preferential treatment compared withsenior unsecured debt. Examples of CRR liabilities include the uncollateralised portion of payables arising from derivatives transactionsand the uncollateralised portion of liabilities under sale and repurchase agreements.

OTP's CRRs are positioned at Baa1/P-2OTP’s CRRs are positioned three notches above its Adjusted BCA of ba1, reflecting the extremely low loss given failure stemming froma high volume of subordinated instruments.

Methodology and scorecardAbout Moody's Bank ScorecardOur scorecard is designed to capture, express and explain in summary form our Rating Committee's judgement. When read inconjunction with our research, a fulsome presentation of our judgement is expressed. As a result, the output of our scorecardmay materially differ from that suggested by raw data alone (though it has been calibrated to avoid the frequent need for strongdivergence). The scorecard output and the individual scores are discussed in rating committees and may be adjusted up or down toreflect conditions specific to each rated entity.

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Rating methodology and scorecard factors

Exhibit 3

OTP Bank NyRtMacro FactorsWeighted Macro Profile Moderate

-100%

Factor HistoricRatio

InitialScore

ExpectedTrend

Assigned Score Key driver #1 Key driver #2

SolvencyAsset RiskProblem Loans / Gross Loans 10.1% b3 ↑↑ b1 Collateral and

provisioning coverageLong-run lossperformance

CapitalTangible Common Equity / Risk Weighted Assets(Basel III - transitional phase-in)

14.6% baa3 ↓ ba1 Expected trend

ProfitabilityNet Income / Tangible Assets 2.1% baa1 ←→ baa2 Expected trend

Combined Solvency Score ba2 ba2LiquidityFunding StructureMarket Funds / Tangible Banking Assets 6.3% baa2 ←→ baa3 Expected trend Extent of market

funding relianceLiquid ResourcesLiquid Banking Assets / Tangible Banking Assets 39.1% baa3 ↓ baa3 Expected trend

Combined Liquidity Score baa2 baa3Financial Profile ba1Qualitative Adjustments Adjustment

Business Diversification 0Opacity and Complexity 0Corporate Behavior 0

Total Qualitative Adjustments 0Sovereign or Affiliate constraint Baa3Scorecard Calculated BCA range baa3 - ba2Assigned BCA ba1Affiliate Support notching 0Adjusted BCA ba1

Balance Sheet in-scope(HUF Million)

% in-scope at-failure(HUF Million)

% at-failure

Other liabilities 2,169,015 25.6% 2,592,148 30.6%Deposits 5,741,498 67.8% 5,155,865 60.9%

Preferred deposits 4,248,709 50.2% 4,036,273 47.7%Junior deposits 1,492,789 17.6% 1,119,592 13.2%Senior unsecured bank debt 32,460 0.4% 32,460 0.4%Dated subordinated bank debt 162,500 1.9%Junior subordinated bank debt 109,745 1.3% 109,745 1.3%Preference shares (bank) 159,597 1.9% 159,597 1.9%Equity 253,989 3.0% 253,989 3.0%Total Tangible Banking Assets 8,466,305 100.0% 8,466,305 100.0%

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De Jure waterfall De Facto waterfall NotchingDebt ClassInstrumentvolume +

subordination

Sub-ordination

Instrumentvolume +

subordination

Sub-ordination

De Jure De FactoLGF

NotchingGuidance

vs.Adjusted

BCA

AssignedLGF

notching

AdditionalNotching

PreliminaryRating

Assessment

Counterparty Risk Rating 21.7% 21.7% 21.7% 21.7% 3 3 3 3 0 baa1Counterparty Risk Assessment 21.7% 21.7% 21.7% 21.7% 3 3 3 3 0 baa2 (cr)Deposits 21.7% 8.1% 21.7% 8.5% 3 3 3 3 0 baa1Dated subordinated bank debt 8.1% 6.2% 8.1% 6.2% 0 0 0 0 0 ba1Junior subordinated bank debt 6.2% 4.9% 6.2% 4.9% -1 -1 -1 -1 -1 ba3

Instrument Class Loss GivenFailure notching

Additionalnotching

Preliminary RatingAssessment

GovernmentSupport notching

Local CurrencyRating

ForeignCurrency

RatingCounterparty Risk Rating 3 0 baa1 0 Baa1 Baa1Counterparty Risk Assessment 3 0 baa2 (cr) 0 Baa2(cr)Deposits 3 0 baa1 0 Baa1 Baa3Dated subordinated bank debt 0 0 ba1 0 Ba1Junior subordinated bank debt -1 -1 ba3 0 Ba3 (hyb)[1] Where dashes are shown for a particular factor (or sub-factor), the score is based on non-public information.Source: Moody’s Investors Service

Ratings

Exhibit 4Category Moody's RatingOTP BANK NYRT

Outlook StableCounterparty Risk Rating Baa1/P-2Bank Deposits -Fgn Curr Baa3/P-3Bank Deposits -Dom Curr Baa1/P-2Baseline Credit Assessment ba1Adjusted Baseline Credit Assessment ba1Counterparty Risk Assessment Baa2(cr)/P-2(cr)Subordinate Ba1Jr Subordinate Ba3 (hyb)

OTP JELZALOGBANK ZRT. (OTP MORTGAGE BANK)

Outlook StableCounterparty Risk Rating Baa1/P-2Counterparty Risk Assessment Baa2(cr)/P-2(cr)Bkd Issuer Rating -Dom Curr Baa2

Source: Moody's Investors Service

Endnotes1 The ratings shown are the bank's deposit ratings, outlook and BCA.

2 OTP acquired Splitska banka in May 2017 and Vojvodjanska bank during the fourth quarter of 2017.

3 The acquisition of SG Expressbank was closed in January 2019; of SG Albania in 1Q 2019 and of SG Montenegro, SG Moldova and SG Serbia in 3Q 2019.The closing of the acquisition of SG Slovenia announced in 2019 is pending.

4 Defined as Stage 3 loans plus Purchased or Originated Credit Impaired loans

5 Adjusted to exclude the banking tax and one off items, mainly the reduction of goodwill of the Romanian subsidiary and a significant provision against thepotential conversion of swiss franc mortgages in Serbia.

6 As reported by the bank.

7 According to the scheme to qualify the mother must be between 21-41yrs old and a resident of Hungary with at least one of the couple having contributedto the country’s social security scheme for 3 years or more. The couple can receive up to HUF10 million (around EUR30,000) cash loan with the interestsubsidised by the government. The couples may then benefit from full debt relief (the government assumes the cost) provided they have three childrenwith the first child born in the first five years. If a child is not born in five years, the margin increases to 5% from 2% and the borrowers assume the cost.Once the first child is born, principal payments are deferred for 3 years. Following the birth of the second child the government assumes repayment of one

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third of the outstanding principal and following the birth of the third child the government assumes repayment of the remaining principal. Borrowers mustpay a one-time 0.8% loan fee and 0.8% annual fee for the government guarantee and other bank charges.

8 The interest banks earn on these loans is at 1.3 times the coupon of five-year Hungarian government bond plus a 3% margin. The margin will increase to5% and will be paid by the borrower if no children are born within the agreed time frame.

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