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Rating Update:

MOODY'S HAS REVISED THE MINNESOTA SCHOOL DISTRICT CREDIT ENHANCEMENT PROGRAM OUTLOOK TO NEGATIVE FROM STABLE

04 Aug 2011

Aa2 RATING AND NEGATIVE OUTLOOK APPLIES TO $10.3 BILLION OF OUTSTANDING DEBT ISSUED BY 196 SCHOOL DISTRICTS

Municipality
MN

Opinion

NEW YORK, Aug 4, 2011 -- Moody's has revised the outlook on the Minnesota School District Credit Enhancement Program (MSDE) to negative from stable in conjunction with the outlook revision of the State of Minnesota's general obligation and state supported debt. Concurrently, Moody's and has affirmed the Aa2 programmatic rating. The MSDE programmatic rating and outlook is based on Moody's assessment of the overall mechanics of the program and is rated one notch below the state's general obligation rating (Aa1/negative outlook). For additional information regarding Moody's recent action on the State of Minnesota's rating and the revision of state's outlook to negative from stable, please refer to Moody's New Issue report, dated August 1, 2011. The programmatic Aa2 rating is based on Moody's assessment of program level criteria related to program mechanics, pledge of an unlimited General Fund appropriation, and solid programmatic history.

Under the MSDE loan program, established and designed by the State of Minnesota, bonds are secured by the state's pledge of an unlimited appropriation from its General Fund should a district be unable to meet debt service requirements. Due to the appropriation risk and the essentiality of the program, the enhancement program is rated one notch below the state's general obligation rating. The appropriation mechanism allows for continuing unlimited advances from the state's General Fund to avert default for qualified school districts.

District repayment is either from state aid withholding or a required special school district levy outside normal levy limits. Key program components also include third-party notification of pending deficiency. Under Minnesota statutes, if the district believes it is unable to make a timely debt service payment, it must notify the State of Minnesota Department of Education at least 15 working days prior to the due date. The Commissioner of Education, after consultation with the district and the paying agent, and the verification of information, will notify the Commissioner of Finance who issues a warrant and authorization for direct payment to the paying agent. Should a district fail to notify the state of an impending non-payment of debt covered by the program, the paying agent will undertake notification. The agent is to notify the State directly, three days prior to the payment date of the needed amounts. State funds equal to the request are then transferred directly to the paying agent. If the state makes a payment on behalf of a district, the district must submit a plan to the Commissioner of Education specifying the steps the district intends to take to resolve current and future funding problems.

As the MSDE program demonstrates the above characteristics, Moody's analysis concludes that program mechanics are strong and is expected to continue to be rated one notch lower than the State of Minnesota's general obligation rating.

AFFECTED SCHOOL DISTRICT /OUTSTANDING MSDE Rated Debt (000s)

ADRIAN INDEPENDENT SCHOOL DISTRICT 511 $12.4

ALBANY INDEPENDENT SCHOOL DISTRICT 745 $23.2

ALBERT LEA INDEPENDENT SCHOOL DISTRICT 241 $27.5

ALDEN-CONGER INDEPENDENT SCHOOL DISTRICT 242 $3

ALEXANDRIA INDEPENDENT SCHOOL DISTRICT 206 $45.1

ANNANDALE INDEPENDENT SCHOOL DISTRICT 876 $32.8

ANOKA HENNEPIN INDEPENDENT SCHOOL DISTRICT 11 $122.6

ASHBY INDEPENDENT SCHOOL DISTRICT 261 $7.4

ATWATER-COSMOS-GROVE CITY INDEPENDENT SCHOOL DISTRICT 2396 $13.3

AUSTIN INDEPENDENT SCHOOL DISTRICT 492 $13.4

BARNUM INDEPENDENT SCHOOL DISTRICT 91 $1.6

BECKER INDEPENDENT SCHOOL DISTRICT 726 $19.9

BELGRADE-BROOTEN-ELROSA INDEPENDENT SCHOOL DISTRICT 2364 $6.7

BEMIDJI INDEPENDENT SCHOOL DISTRICT 31 $95.8

BENSON INDEPENDENT SCHOOL DISTRICT 777 $3.3

BERTHA-HEWITT INDEPENDENT SCHOOL DISTRICT 786 $0.99

BIG LAKE INDEPENDENT SCHOOL DISTRICT 727 $41.6

BLOOMING PRAIRIE INDEPENDENT SCHOOL DISTRICT 756 $15.8

BLOOMINGTON INDEPENDENT SCHOOL DISTRICT 271 $147

BLUE EARTH INDEPENDENT SCHOOL DISTRICT 2860 $2.2

BRAHAM INDEPENDENT SCHOOL DISTRICT 314 $5.4

BRAINERD INDEPENDENT SCHOOL DISTRICT 181 $84.3

BROOKLYN CENTER INDEPENDENT SCHOOL DISTRICT 286 $61.3

BUFFALO-HANOVER-MONTROSE INDEPENDENT SCHOOL DISTRICT 877 $113.5

BURNSVILLE INDEPENDENT SCHOOL DISTRICT 191 $141.2

CALEDONIA INDEPENDENT SCHOOL DISTRICT 299 $9.5

CAMBRIDGE INDEPENDENT SCHOOL DISTRICT 911 $88.3

CANBY INDEPENDENT SCHOOL DISTRICT 891 $6.6

CANNON FALLS INDEPENDENT SCHOOL DISTRICT 252 $20.9

CENTENNIAL INDEPENDENT SCHOOL DISTRICT 12 $57.1

CHISAGO LAKES AREA SCHOOLS INDEPENDENT SCHOOL DISTRICT 2144 $20.3

CHISHOLM INDEPENDENT SCHOOL DISTRICT 695 $4.6

CLINTON-GRACEVILLE INDEPENDENT SCHOOL DISTRICT 55 $2.6

CLOQUET INDEPENDENT SCHOOL DISTRICT 94 $27.4

COLD SPRING INDEPENDENT SCHOOL DISTRICT 750 (ROCORI) $37.8

COLUMBIA HEIGHTS INDEPENDENT SCHOOL DISTRICT 13 $27.5

COMMISSIONER OF IRON RANGE RESOURCES AND REHABILITATION $15.2

CROMWELL-WRIGHT INDEPENDENT SCHOOL DISTRICT 95 $2.02

CROOKSTON INDEPENDENT SCHOOL DISTRICT 593 $21.1

DASSEL-COKATO INDEPENDENT SCHOOL DISTRICT 466 $24.1

DAWSON-BOYD INDEPENDENT SCHOOL DISTRICT 378 $3.7

DEER RIVER INDEPENDENT SCHOOL DISTRICT 317 (ITASCA & CASS COUNTIES) $14.7

DELANO INDEPENDENT SCHOOL DISTRICT 879 $47.1

DETROIT LAKES INDEPENDENT SCHOOL DISTRICT 22 $11.5

DILWORTH INDEPENDENT SCHOOL DISTRICT 147 $2.5

DOVER-EYOTA INDEPENDENT SCHOOL DISTRICT 533 $17.9

DULUTH INDEPENDENT SCHOOL DISTRICT 709 $262.6

EASTERN CARVER COUNTY SCHOOLS $241.7

EDEN PRAIRIE INDEPENDENT SCHOOL DISTRICT 272 $97.8

EDEN VALLEY-WATKINS INDEPENDENT SCHOOL DISTRICT 463 $21.3

EDINA INDEPENDENT SCHOOL DISTRICT 273 $28.3

ELGIN-MILLVILLE INDEPENDENT SCHOOL DISTRICT 806 $5.4

ELK RIVER INDEPENDENT SCHOOL DISTRICT 728 $390.6

ELY INDEPENDENT SCHOOL DISTRICT 696 $1.8

ESKO INDEPENDENT SCHOOL DISTRICT 99 $30.7

EVELETH-GILBERT INDEPENDENT SCHOOL DISTRICT 2154 $4.2

FAIRMONT AREA SCHOOLS INDEPENDENT SCHOOL DISTRICT 2752 $49.5

FARIBAULT INDEPENDENT SCHOOL DISTRICT 656 $97.1

FARMINGTON INDEPENDENT SCHOOL DISTRICT 192 $245.2

FERGUS FALLS INDEPENDENT SCHOOL DISTRICT 544 $1.9

FERTILE-BELTRAMI INDEPENDENT SCHOOL DISTRICT 599 $0.9

FILLMORE CENTRAL INDEPENDENT SCHOOL DISTRICT 2198 $3.4

FISHER INDEPENDENT SCHOOL DISTRICT 600 $5.6

FLOODWOOD INDEPENDENT SCHOOL DISTRICT 698 $5.2

FOLEY INDEPENDENT SCHOOL DISTRICT 51 $13.7

FOREST LAKE INDEPENDENT SCHOOL DISTRICT 831 $87.3

FOSSTON INDEPENDENT SCHOOL DISTRICT 601 $9.5

FRAZEE-VERGAS INDEPENDENT SCHOOL DISTRICT 23 $13.8

GRAND MEADOW INDEPENDENT SCHOOL DISTRICT 495 $14.9

HANCOCK INDEPENDENT SCHOOL DISTRICT 768 $0.3

HASTINGS INDEPENDENT SCHOOL DISTRICT 200 $59.4

HAWLEY INDEPENDENT SCHOOL DISTRICT 150 $18.8

HAYFIELD INDEPENDENT SCHOOL DISTRICT 203 $7.6

HENNING INDEPENDENT SCHOOL DISTRICT 545 $3.7

HERMANTOWN INDEPENDENT SCHOOL DISTRICT 700 $10.5

HIBBING INDEPENDENT SCHOOL DISTRICT 701 $2.2

HOLDINGFORD INDEPENDENT SCHOOL DISTRICT 738 $5.7

HOPKINS INDEPENDENT SCHOOL DISTRICT 270 $243.2

HUTCHINSON INDEPENDENT SCHOOL DISTRICT 423 $23.3

INDEPENDENT SCHOOL DISTRICT 108 (NORWOOD YOUNG AMERICA) $3.2

INVER GROVE HEIGHTS INDEPENDENT SCHOOL DISTRICT 199 $71.3

ISLE INDEPENDENT SCHOOL DISTRICT 473 $6.2

JANESVILLE-WALDORF-PEMBERTON INDEPENDENT SCHOOL DISTRICT 2835 $11

JORDAN INDEPENDENT SCHOOL DISTRICT 717 $16.0

KASSON-MANTORVILLE INDEPENDENT SCHOOL DISTRICT 204 $39.7

KELLIHER INDEPENDENT SCHOOL DISTRICT 36 $2.1

KERKHOVEN-MURDOCK-SUNBURG INDEPENDENT SCHOOL DISTRICT 775 $6.3

KIMBALL INDEPENDENT SCHOOL DISTRICT 739 $7.4

KINGSLAND INDEPENDENT SCHOOL DISTRICT 2137 $13.8

LA CRESCENT INDEPENDENT SCHOOL DISTRICT 300 $7.9

LAKE OF THE WOODS INDEPENDENT SCHOOL DISTRICT 390 $13.2

LAKE SUPERIOR INDEPENDENT SCHOOL DISTRICT 381 $81.5

LAKEVIEW INDEPENDENT SCHOOL DISTRICT 2167 $12.1

LAKEVILLE INDEPENDENT SCHOOL DISTRICT 194 $284.1

LANESBORO INDEPENDENT SCHOOL DISTRICT 229 $1

LAPORTE INDEPENDENT SCHOOL DISTRICT 306 $8.6

LE CENTER INDEPENDENT SCHOOL DISTRICT 392 $7.2

LE ROY-OSTRANDER INDEPENDENT SCHOOL DISTRICT 499 $2.06

LE SUEUR-HENDERSON INDEPENDENT SCHOOL DISTRICT 2397 $18.6

LITCHFIELD INDEPENDENT SCHOOL DISTRICT 465 $7.8

LONG PRAIRIE-GREY EAGLE INDEPENDENT SCHOOL DISTRICT 2753 $15.9

LUVERNE INDEPENDENT SCHOOL DISTRICT 2184 $31.0

MADELIA INDEPENDENT SCHOOL DISTRICT 837 $2.3

MAHTOMEDI INDEPENDENT SCHOOL DISTRICT 832 $13.4

MANKATO INDEPENDENT SCHOOL DISTRICT 77 $83.5

MAPLE LAKE INDEPENDENT SCHOOL DISTRICT 881 $26.2

MARSHALL INDEPENDENT SCHOOL DISTRICT 413 $37

MCGREGOR INDEPENDENT SCHOOL DISTRICT 4 $7.7

MCINTOSH CITY INDEPENDENT SCHOOL DISTRICT 2609 (WIN-E-MAC) $14.0

MEDFORD INDEPENDENT SCHOOL DISTRICT 763 $13.9

MELROSE INDEPENDENT SCHOOL DISTRICT 740 $7.5

MENAHGA INDEPENDENT SCHOOL DISTRICT 821 $3.7

MESABI EAST INDEPENDENT SCHOOL DISTRICT 2711 $27.2

MILACA INDEPENDENT SCHOOL DISTRICT 912 $10.8

MINNEAPOLIS SPECIAL SCHOOL DISTRICT 1 $695.6

MINNETONKA INDEPENDENT SCHOOL DISTRICT 276 $142.9

MONTGOMERY-LONSDALE INDEPENDENT SCHOOL DISTRICT 394 $51.2

MOORHEAD INDEPENDENT SCHOOL DISTRICT 152 $115.7

MORRIS INDEPENDENT SCHOOL DISTRICT 769 $1

MOUNDS VIEW INDEPENDENT SCHOOL DISTRICT 621 $227.1

MOUNTAIN IRON-BUHL INDEPENDENT SCHOOL DISTRICT 712 $6.9

NEVIS INDEPENDENT SCHOOL DISTRICT 308 $1.9

NEW LONDON-SPICER INDEPENDENT SCHOOL DISTRICT 345 $27.8

NEW PRAGUE INDEPENDENT SCHOOL DISTRICT 721 $93.2

NEW RICHLAND INDEPENDENT SCHOOL DISTRICT 2168 $4.7

NEW ULM INDEPENDENT SCHOOL DISTRICT 88 $33.5

NEW YORK MILLS INDEPENDENT SCHOOL DISTRICT 553 $11.6

NORTH BRANCH INDEPENDENT SCHOOL DISTRICT 138 $65.6

NORTH ST. PAUL-MAPLEWOOD-OAKDALE INDEPENDENT SCHOOL DISTRICT 622 $199.2

NORTHFIELD INDEPENDENT SCHOOL DISTRICT 659 $105.8

ONAMIA INDEPENDENT SCHOOL DISTRICT 480 $3.5

ORONO INDEPENDENT SCHOOL DISTRICT 278 $59.6

ORTONVILLE INDEPENDENT SCHOOL DISTRICT 62 $15.6

OSSEO AREA INDEPENDENT SCHOOL DISTRICT 279 $263.1

OWATONNA INDEPENDENT SCHOOL DISTRICT 761 $54.5

PARK RAPIDS INDEPENDENT SCHOOL DISTRICT 309 $34.8

PARKERS PRAIRIE INDEPENDENT SCHOOL DISTRICT 547 $5.9

PAYNESVILLE INDEPENDENT SCHOOL DISTRICT 741 $3.5

PEQUOT LAKES INDEPENDENT SCHOOL DISTRICT 186 $10

PILLAGER INDEPENDENT SCHOOL DISTRICT 116 $5.4

PINE CITY INDEPENDENT SCHOOL DISTRICT 578 $6.5

PINE ISLAND INDEPENDENT SCHOOL DISTRICT 255 $7.4

PINE RIVER-BACKUS INDEPENDENT SCHOOL DISTRICT 2174 $2.6

PLAINVIEW ELGIN MILLVILLE INDEPENDENT SCHOOL DISTRICT 2899 $8.5

PRINCETON INDEPENDENT SCHOOL DISTRICT 477 $51.4

PRIOR LAKE INDEPENDENT SCHOOL DISTRICT 719 $229.3

PROCTOR INDEPENDENT SCHOOL DISTRICT 704 $27.3

RED LAKE FALLS INDEPENDENT SCHOOL DISTRICT 630 $9.2

RED WING INDEPENDENT SCHOOL DISTRICT 256 $16.3

REDWOOD AREA INDEPENDENT SCHOOL DISTRICT 2897 $10.3

RICHFIELD INDEPENDENT SCHOOL DISTRICT 280 $10

ROBBINSDALE INDEPENDENT SCHOOL DISTRICT 281 $216.9

ROCHESTER INDEPENDENT SCHOOL DISTRICT 535 $200.3

ROCKFORD INDEPENDENT SCHOOL DISTRICT 883 $38.9

ROSEAU INDEPENDENT SCHOOL DISTRICT 682 $16.0

ROSEMOUNT INDEPENDENT SCHOOL DISTRICT 196 $213.3

ROSEVILLE INDEPENDENT SCHOOL DISTRICT 623 $93.2

RUSH CITY INDEPENDENT SCHOOL DISTRICT 139 $40.6

SARTELL INDEPENDENT SCHOOL DISTRICT 748 $39.0

SAUK RAPIDS-RICE INDEPENDENT SCHOOL DISTRICT 47 $8.9

SHAKOPEE INDEPENDENT SCHOOL DISTRICT 720 $188.2

SOUTH WASHINGTON COUNTY INDEPENDENT SCHOOL DISTRICT 833 $384.5

SOUTHLAND INDEPENDENT SCHOOL DISTRICT 500 $3.0

SPRING LAKE PARK INDEPENDENT SCHOOL DISTRICT 16 $141.4

ST. ANTHONY-NEW BRIGHTON INDEPENDENT SCHOOL DISTRICT 282 $32.5

ST. CHARLES INDEPENDENT SCHOOL DISTRICT 858 $5.9

ST. CLOUD INDEPENDENT SCHOOL DISTRICT 742 $35.5

ST. FRANCIS INDEPENDENT SCHOOL DISTRICT 15 $50.9

ST. LOUIS PARK INDEPENDENT SCHOOL DISTRICT 283 $60.2

ST. MICHAEL-ALBERTVILLE INDEPENDENT SCHOOL DISTRICT 885 $314.0

ST. PAUL INDEPENDENT SCHOOL DISTRICT 625 $460.2

ST. PETER INDEPENDENT SCHOOL DISTRICT 508 $1.6

STEWARTVILLE INDEPENDENT SCHOOL DISTRICT 534 $37.6

STILLWATER INDEPENDENT SCHOOL DISTRICT 834 $77.9

THIEF RIVER FALLS INDEPENDENT SCHOOL DISTRICT 564 $33.2

TRITON INDEPENDENT SCHOOL DISTRICT 2125 $9.1

TYLER INDEPENDENT SCHOOL DISTRICT 409 $0.6

ULEN-HITTERDAL INDEPENDENT SCHOOL DISTRICT 914 $10.6

UNDERWOOD INDEPENDENT SCHOOL DISTRICT 550 $8.9

VERNDALE INDEPENDENT SCHOOL DISTRICT 818 $2.3

VIRGINIA INDEPENDENT SCHOOL DISTRICT 706 $17.4

WABASHA-KELLOGG INDEPENDENT SCHOOL DISTRICT 811 $6.4

WABASSO INDEPENDENT SCHOOL DISTRICT 640 $8.7

WACONIA INDEPENDENT SCHOOL DISTRICT 110 $69.2

WALKER-HACKENSACK-AKELEY INDEPENDENT SCHOOL DISTRICT 113 $26.2

WARROAD INDEPENDENT SCHOOL DISTRICT 690 $9.5

WASECA INDEPENDENT SCHOOL DISTRICT 829 $23.7

WAYZATA INDEPENDENT SCHOOL DISTRICT 284 $159.5

WEST ST. PAUL-MENDOTA HEIGHTS-EAGAN INDEPENDENT SCHOOL DISTRICT 197 $28.5

WHITE BEAR LAKE INDEPENDENT SCHOOL DISTRICT 624 $24.9

WILLMAR INDEPENDENT SCHOOL DISTRICT 347 $16.7

WILLOW RIVER INDEPENDENT SCHOOL DISTRICT 577 $2.6

WINDOM INDEPENDENT SCHOOL DISTRICT 177 $6.3

WINONA INDEPENDENT SCHOOL DISTRICT 861 $24.5

WORTHINGTON INDEPENDENT SCHOOL DISTRICT 518 $16.6

ZUMBROTA-MAZEPPA INDEPENDENT SCHOOL DISTRICT 2805 $5.4

PRINCIPAL METHODOLOGY

The principal methodology used in this rating was State Aid Intercept Programs and Financings published in February 2008. Please see the Credit Policy page on www.moodys.com for a copy of this methodology.

REGULATORY DISCLOSURES

For ratings issued on a program, series or category/class of debt, this announcement provides relevant regulatory disclosures in relation to each rating of a subsequently issued bond or note of the same series or category/class of debt or pursuant to a program for which the ratings are derived exclusively from existing ratings in accordance with Moody's rating practices. For ratings issued on a support provider, this announcement provides relevant regulatory disclosures in relation to the rating action on the support provider and in relation to each particular rating action for securities that derive their credit ratings from the support provider's credit rating. For provisional ratings, this announcement provides relevant regulatory disclosures in relation to the provisional rating assigned, and in relation to a definitive rating that may be assigned subsequent to the final issuance of the debt, in each case where the transaction structure and terms have not changed prior to the assignment of the definitive rating in a manner that would have affected the rating. For further information please see the ratings tab on the issuer/entity page for the respective issuer on www.moodys.com.

Information sources used to prepare the rating are the following: parties involved in the ratings, parties not involved in the ratings, public information, confidential and proprietary Moody's Investors Service information, and confidential and proprietary Moody's Analytics information.

Moody's considers the quality of information available on the rated entity, obligation or credit satisfactory for the purposes of issuing a rating.

Moody's adopts all necessary measures so that the information it uses in assigning a rating is of sufficient quality and from sources Moody's considers to be reliable including, when appropriate, independent third-party sources. However, Moody's is not an auditor and cannot in every instance independently verify or validate information received in the rating process.

Please see Moody's Rating Symbols and Definitions on the Rating Process page on www.moodys.com for further information on the meaning of each rating category and the definition of default and recovery.

Please see ratings tab on the issuer/entity page on www.moodys.com for the last rating action and the rating history.

The date on which some ratings were first released goes back to a time before Moody's ratings were fully digitized and accurate data may not be available. Consequently, Moody's provides a date that it believes is the most reliable and accurate based on the information that is available to it. Please see the ratings disclosure page on our website www.moodys.com for further information.

Please see www.moodys.com for any updates on changes to the lead rating analyst and to the Moody's legal entity that has issued the rating.

Analysts

Soo Yun Chun
Analyst
Public Finance Group
Moody's Investors Service

Henrietta Chang
Backup Analyst
Public Finance Group
Moody's Investors Service

Contacts

Journalists: (212) 553-0376
Research Clients: (212) 553-1653


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New York, NY 10007
USA

MOODY'S HAS REVISED THE MINNESOTA SCHOOL DISTRICT CREDIT ENHANCEMENT PROGRAM OUTLOOK TO NEGATIVE FROM STABLE
No Related Data.
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Additional terms for Australia only: Any publication into Australia of this document is pursuant to the Australian Financial Services License of MOODY’S affiliate, Moody’s Investors Service Pty Limited ABN 61 003 399 657AFSL 336969 and/or Moody’s Analytics Australia Pty Ltd ABN 94 105 136 972 AFSL 383569 (as applicable). This document is intended to be provided only to “wholesale clients” within the meaning of section 761G of the Corporations Act 2001. By continuing to access this document from within Australia, you represent to MOODY’S that you are, or are accessing the document as a representative of, a “wholesale client” and that neither you nor the entity you represent will directly or indirectly disseminate this document or its contents to “retail clients” within the meaning of section 761G of the Corporations Act 2001. MOODY’S credit rating is an opinion as to the creditworthiness of a debt obligation of the issuer, not on the equity securities of the issuer or any form of security that is available to retail investors.

Additional terms for Japan only: Moody's Japan K.K. (“MJKK”) is a wholly-owned credit rating agency subsidiary of Moody's Group Japan G.K., which is wholly-owned by Moody’s Overseas Holdings Inc., a wholly-owned subsidiary of MCO. Moody’s SF Japan K.K. (“MSFJ”) is a wholly-owned credit rating agency subsidiary of MJKK. MSFJ is not a Nationally Recognized Statistical Rating Organization (“NRSRO”). Therefore, credit ratings assigned by MSFJ are Non-NRSRO Credit Ratings. Non-NRSRO Credit Ratings are assigned by an entity that is not a NRSRO and, consequently, the rated obligation will not qualify for certain types of treatment under U.S. laws. MJKK and MSFJ are credit rating agencies registered with the Japan Financial Services Agency and their registration numbers are FSA Commissioner (Ratings) No. 2 and 3 respectively.

MJKK or MSFJ (as applicable) hereby disclose that most issuers of debt securities (including corporate and municipal bonds, debentures, notes and commercial paper) and preferred stock rated by MJKK or MSFJ (as applicable) have, prior to assignment of any rating, agreed to pay to MJKK or MSFJ (as applicable) for ratings opinions and services rendered by it fees ranging from JPY125,000 to approximately JPY250,000,000.

MJKK and MSFJ also maintain policies and procedures to address Japanese regulatory requirements.

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