Several European banks with large exposures to Greek sovereign debt have yet to sign up to a plan for private-sector bondholders to contribute €37bn to a second Greek rescue package, the Financial Times has learned.

The UK’s Royal Bank of Scotland, Germany’s DZ Bank and LBBW and Austria’s Erste Bank, which between them hold about €3bn of Greek sovereign debt, are among the lenders that have not yet committed to take part in a programme that will see participants swap or roll over their Greek debt for bonds that mature in 30 years.

Senior bankers said considerable uncertainty remained about the details of the Greek bail-out plan and its likely application. Even the level of projected participation of private-sector bondholders – which the European Union said would be €37bn over the next three years, and the Institute of International Finance, which has co-ordinated bondholders, said would be €54bn – has caused widespread confusion.

In fact, the discrepancy is straightforward – the €54bn is indeed the amount that the banks expect to commit to Greece, assuming that there is 90 per cent take-up of the rollover or exchange plan, but the €37bn is what Greece would actually receive, net of €16.8bn of the “credit enhancement” programme.

Credit enhancement is the name for the mechanism by which Greece will be obliged to reinvest 20 per cent of its sovereign funding into an insurance vehicle collateralised with triple A debt to guard against future default.

There was also uncertainty about the level of take-up. Analysts said the banks’ 90 per cent estimated acceptance of the scheme, which would generate €54bn of funding by mid-2014 and €135bn by 2020, was realistic.

“If you look back at other crises – the Russia crisis, or the Tequila crisis – 90 per cent take-up would be normal,” says Kian Abouhossein, banks analyst at JP Morgan.

But others believe it may be optimistic, given the wide diversity of bondholders.

Although the IIF, which co-ordinated the big banks and insurers that are bondholders, secured support for the deal from 30 big names – led by France’s BNP Paribas and Deutsche Bank and Allianz in Germany – many significant bondholders have as yet made no commitment.

Among those, RBS was the biggest, with €1.2bn, according to data disclosed in the recent European stress tests. RBS said it was considering its position.

DZ Bank, which stress test data showed had €731m of Greek sovereign debt, is believed to be open to participation but has not taken a decision. DZ Bank declined to comment.

LBBW, with €775m of Greek bonds according to stress tests, said it would analyse the IIF proposal.

Austria’s Erste Group did not rule out taking part, saying: “As soon as we get details we will discuss the implications.”

In Portugal, Millennium BCP with €700m and Banco BPI with €480m have the largest exposures, and are not ruling out participating, according to people close to the banks.

Additional reporting by James Wilson and Peter Wise

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