Moodys.com
Please Note
We brought you to this page based on your search query. If this isn't what you are looking for, you can continue to Search Results for ""
The maximum number of items you can export is 3,000. Please reduce your list by using the filtering tool to the left.
Close
Close
Email Research
Recipient email addresses will not be used in mailing lists or redistributed.
Recipient's
Email

Use semicolon to separate each address, limit to 20 addresses.
Enter the
characters you see
Close
Email Research
Thank you for your interest in sharing Moody's Research. You have reached the daily limit of Research email sharings.
Close
Thank you!
You have successfully sent the research.
Please note: some research requires a paid subscription in order to access.
Already a customer?
LOG IN
Don't want to see this again?
REGISTER
OR
Accept our Terms of Use to continue to Moodys.com:

PLEASE READ AND SCROLL DOWN!

 

By clicking “I AGREE” [at the end of this document], you indicate that you understand and intend these terms and conditions to be the legal equivalent of a signed, written contract and equally binding, and that you accept such terms and conditions as a condition of viewing any and all Moody’s inform​ation that becomes accessible to you [after clicking “I AGREE”] (the “Information”).   References herein to “Moody’s” include Moody’s Corporation, Inc. and each of its subsidiaries and affiliates.

 

Terms of One-Time Website Use

 

1.            Unless you have entered into an express written contract with Moody’s to the contrary, you agree that you have no right to use the Information in a commercial or public setting and no right to copy it, save it, print it, sell it, or publish or distribute any portion of it in any form.               

 

2.            You acknowledge and agree that Moody’s credit ratings: (i) are current opinions of the future relative creditworthiness of securities and address no other risk; and (ii) are not statements of current or historical fact or recommendations to purchase, hold or sell particular securities.  Moody’s credit ratings and publications are not intended for retail investors, and it would be reckless and inappropriate for retail investors to use Moody’s credit ratings and publications when making an investment decision.  No warranty, express or implied, as the accuracy, timeliness, completeness, merchantability or fitness for any particular purpose of any Moody’s credit rating is given or made by Moody’s in any form whatsoever.          

 

3.            To the extent permitted by law, Moody’s and its directors, officers, employees, representatives, licensors and suppliers disclaim liability for: (i) any indirect, special, consequential, or incidental losses or damages whatsoever arising from or in connection with use of the Information; and (ii) any direct or compensatory damages caused to any person or entity, including but not limited to by any negligence (but excluding fraud or any other type of liability that by law cannot be excluded) on the part of Moody’s or any of its directors, officers, employees, agents, representatives, licensors or suppliers, arising from or in connection with use of the Information.

 

4.            You agree to read [and be bound by] the more detailed disclosures regarding Moody’s ratings and the limitations of Moody’s liability included in the Information.     

 

5.            You agree that any disputes relating to this agreement or your use of the Information, whether sounding in contract, tort, statute or otherwise, shall be governed by the laws of the State of New York and shall be subject to the exclusive jurisdiction of the courts of the State of New York located in the City and County of New York, Borough of Manhattan.​​​

I AGREE
Announcement:

Moody's ABCP rating actions ending January 6, 2014

08 Jan 2014

New York, January 08, 2014 -- Moody's ABCP rating actions for the twenty-one-day period ending January 6, 2014

NO RATING IMPACT ON THE FOLLOWING ABCP PROGRAMS DURING THE PERIOD DECEMBER 17, 2013 THROUGH JANUARY 6, 2014:

Moody's has reviewed the following ABCP programs in conjunction with the proposed amendments. The amendments, in and of themselves and at this time, will not result in any rating impact on the respective programs. For the mentioned programs, Moody's believes that the amendments do not have an adverse effect on the credit quality of the securities such that the Moody's ratings are impacted. Moody's does not express an opinion as to whether the amendment could have other, non-credit-related effects.

SYNDICATE OF ABCP CONDUITS AMEND EXISTING FUTURE FLOW SECURITIZATION FACILITY

A syndicate of banks has amended an existing future flow securitization facility. The collateral consists of certain assets, including future payment rights from the company's service business. A new note, the Class C Note, is being issued for $1.5 billion. The Class A Note has amortized to $4 billion and the Class B Note was repaid. Therefore the facility will consist of a $4 billion Class A Note, with four $1 billion installments made annually each December 20th, and a Class C Note for $1.5 billion scheduled to be repaid in full by December 2018. This transaction is financed by six ABCP conduits and five non-conduit lenders.

The liquidity facility for each participating conduit is sized at 100% (plus all CP interest) or 102% of its respective commitment.

The following ABCP conduits participate in the facility:

• Credit Agricole's Atlantic Asset Securitization LLC has a $331.6 million interest in the Class A Note and a $143.4 million in the Class C Note, and its program-level enhancement increased by 10% of purchase limits.

• Barclays Capital's Sheffield Receivables Corp. has a $414.5 million interest in the Class A Note and a $60.5 million in the Class C Note. Program-level credit enhancement is required to be increased by 10% of this commitment level.

• Citibank's CAFCO, LLC and CIESCO, LLC have combined commitments of $414.5 million in the Class A Note and a combined commitment of $210 million in the Class C Note. CIESCO and CAFCO's program-level credit enhancement increased by 8% of funded assets.

• The Bank of Nova Scotia's Liberty Street has a $373 million interest in the Class A Note and a $252.4 million in the Class C Note, and its program-level credit enhancement increased by 10% of this commitment level.

•Lloyds's Cancara Asset Securitisation Limited a $331.6 million interest in the Class A Note and a $143.4 million in the Class C Note, and its participation in the transaction is fully supported by a liquidity facility provided by Lloyds Bank and the Bank of Scotland.

Five non-conduit lenders provide the remaining commitments.

BANK OF MONTREAL'S CANADIAN MASTER TRUST AND RIDGE TRUST ADD C$445 MILLION AUTO LOAN SECURITIZATION

Canadian Master Trust ("CMT") and Ridge Trust ("Ridge"), partially supported, multiseller ABCP programs administered by BMO Nesbitt Burns Inc. ("BMO NB"), a subsidiary of Bank of Montreal (Aa3/Prime-1/C+) has added an amortizing auto loan securitization to its portfolio. The conduits hold an unrated single-class note issued out of a master trust. The auto loans are originated by an investment-grade rated auto finance company.

Transaction-specific credit enhancement is comprised of non-declining overcollateralization (sized at 5.01% of the discounted adjusted pool), a fully funded cash reserve account (sized at 1.1% of the discounted adjusted pool), and minimum excess spread. This transaction is partially supported by a liquidity facility provided by Bank of Montreal.

Ridge and CMT do not have any program-wide credit enhancement. CMT currently has C$1.89 billion of purchase commitments and C$1.2 billion of Canadian ABCP outstanding. Ridge currently has C$1.9 billion of purchase commitments and C$1.42 billion of Canadian ABCP outstanding.

THE BANK OF NOVA SCOTIA'S KING STREET ADDS C$270 MILLION EQUIPMENT LEASE TRANSACTION

King Street Funding Trust ("King Street"), a partially supported, multiseller Canadian ABCP program administered by Scotia Capital Inc., a wholly owned-subsidiary of The Bank of Nova Scotia (Aa2/Prime-1/B-), has added an amortizing equipment lease securitization to its portfolio. The equipment leases were originated by an experienced equipment finance company operating in Canadian.

Transaction-specific credit enhancement is comprised of 9% overcollateralization, 2% non declining cash reserve and excess spread. This transaction is partially supported by a liquidity facility provided by The Bank of Nova Scotia.

King Street does not have any program-level credit enhancement. King Street currently has C$1.9 billion of purchase commitments and C$1.4 billion of Canadian ABCP outstanding.

JPMORGAN'S CHARIOT AND JUPITER AMEND PROGRAM

Chariot Funding LLC ("Chariot") and Jupiter Securitization Company LLC ("Jupiter"), both partially supported, multiseller ABCP programs administered by JPMorgan Chase Bank ("JPMorgan," Aa3/Prime-1/C), have amended their program.

The amendment is to add a new Security Agreement. The new Security Agreement stipulates that if the liquidity bank, JPMorgan, advances funds, then it will have a security interest in the collateral.

As of 10/31/13, Chariot has $15.7 billion in total purchase commitments and $1.3 billion in program-level credit enhancement. As of 10/31/13, Jupiter has $13.4 billion in total purchase commitments and $1.3 billion in program-level credit enhancement.

RBC'S PLAZA TRUST ADDS $150 MILLION INTEREST IN AUTO FLEET LEASE FACILITY

Plaza Trust ("Plaza"), a partially supported, multiseller ABCP program sponsored and administered by Royal Bank of Canada ("RBC," rated Aa3/Prime-1/C+), has acquired a $150 million interest in an unrated variable funding note backed by automotive fleet leases.

Transaction-specific credit enhancement is in the form of overcollateralization (41% of notes for program cars and at least 41% of notes for non-program cars) and a 5.875% LC and Cash Collateral Amount.

The transaction is partially supported by a transaction-level liquidity facility for each conduit. Liquidity is provided by Prime-1-rated RBC and sized to cover 102% of outstanding ABCP issued by each conduit.

With this transaction, Plaza has C$2.96 billion of purchase commitments; its program-level credit enhancement was C$292.9 million but only C$238.6 million can be drawn.

SOCIETE GENERALE'S ANTALIS PURCHASES EURO 43 MILLION SENIOR NOTES BENEFITING OF Aaa GUARANTEE

Antalis S.A./Antalis U.S. Funding Corp. (together, "Antalis"), a partially supported, multiseller programme sponsored by Société Générale (A2/Prime-1/C-), purchased senior notes issued by a Spanish SPV for an amount of up to EUR43 million and entered into a guarantee agreement with a Aaa rated supranational entity .

The transaction is a static cash securitisation of loans to Spanish small and medium sized enterprises. The guarantor provides to Antalis a first demand, unconditional and irrevocable guarantee for any amount due and payable by the Spanish SPV.

The transaction is partially supported by a liquidity facility provided by SocGen. The liquidity facility is in the form of an asset purchase agreement that finances the senior notes' outstanding principal balance and the asset-backed commercial papers' cost of funds interests as long as the guarantor's rating is Caa2 or if it was at least Caa2 immediately before Moody's withdraws the rating. ABCP can be issued as long as the guarantor's rating is not withdrawn or it is at least equal to Aa3. The maximum term of the ABCP is 270 days.

Investors are exposed to the risk that Moody's downgrades the guarantor's rating to Caa3 from Aa3 within 270 days. Moody's assesses that this situation is unlikely to take place due the status of the guarantor and its current rating. As the structure solely relies on the guarantor's rating independently of whether the guarantee agreement is in place, our analysis does not rely on the existence of the guarantee agreement.

With this transaction, Antalis' s program-level credit enhancement increased by 6% of the purchase limit to EUR 295.1 million. Antalis is authorised to issue approximately EUR 5.04 billion of ABCP.

SOCIETE GENERALE'S BARTON ADDS $250 MILLION AUTO TRANSACTION

Barton Capital LLC ("Barton"), a partially supported, multiseller ABCP program administered by Societe Generale ("SG," A2/Prime-1/C-), has added a $250 million revolving auto lease and loan facility in its portfolio. The facility is established for an investment grade rated auto manufacturer.

Transaction-specific credit enhancement continues to be comprised of overcollateralization at 12% for auto loans and 20% for auto leases and a 2.5% excess spread. This transaction is partially supported by a liquidity facility provided by Prime-1-rated SG.

Barton has $5 billion of purchase commitments and its program-level credit enhancement remains at the $500 million floor.

TORONTO DOMINION'S BANNER TRUST INCREASES ITS INTEREST IN A POOL BACKED BY RESIDENTIAL MORTGAGES

Banner Trust ("Banner"), a partially supported, multiseller Canadian ABCP program sponsored by Toronto Dominion Bank ("TD," Aa1/Prime-1/B) and administered by TD Securities Inc., currently finances a $500 million interest in a $3.85 billion revolving facility backed by conventional and insured residential mortgages loans. The facility, which is financed by several Canadian ABCP conduits, including Banner's three sister conduits, Merit Trust, Prime Trust and Zeus Trust, was increased to $4.1 billion. Simultaneously with this increase Banner's commitment was increased by $250 million to $750 million. No other changes were made to the facility.

The transaction is fully supported by program-level liquidity provided by Prime-1 rated TD and sized to cover 100% of outstanding ABCP issued by Banner.

Banner has no program-level credit enhancement and its ABCP outstandings is currently $1.497 billion.

TD'S ZEUS AMENDS INTEREST IN EXISTING FLEET LEASE TRANSACTION

Zeus Receivables Trust ("Zeus"), a partially supported, multiseller ABCP program sponsored by Toronto Dominion Bank ("TD", rated Aa1/Prime-1/B), has amended its interest in an existing fleet lease transaction.

Zeus currently finances approximately C$137 million of vehicle fleet lease and sign lease receivables originated by an unrated Canadian company. A new pool of vehicle fleet lease will be added for approximately C$43.5 million. The characteristics of the new pool are nearly identical to the existing. Transaction-specific credit enhancement will remain the same and consists of overcollateralization, an LOC and a cash reserve for 12.5% of the outstanding notes. The transaction continues to be partially supported by a program-level liquidity facility provided by Prime-1 rated TD. The liquidity will not fund for defaulted receivables.

Zeus does not have any program-level credit enhancement. Zeus has approximately C$2.65 billion in outstanding ABCP.

THE RATING OF THE FOLLOWING ABCP PROGRAM WAS WITHDRAWN DURING THE PERIOD DECEMBER 17, 2013 THROUGH JANUARY 6, 2013:

Moody's Withdraws the Prime-1 (sf) Rating of ABCP Issued by Straight-A Funding, LLC

For further details, please see Moody's press release dated December 31, 2013

The principal methodology used in these ratings was "Moody's Approach to Rating Asset-Backed Commercial Paper" published in May 2012. Please see the Credit Policy page on www.moodys.com for a copy of this methodology.

Moody's monitors and analyzes ABCP programs on an ongoing basis. A detailed description of each program is published in the ABCP Program Review. Some ABCP programs have monthly updated performance information, which is published in the Performance Overviews. All publications are available on www.moodys.com.

Valerie F. Oliveri
Associate Analyst
Structured Finance Group
Moody's Investors Service, Inc.
250 Greenwich Street
New York, NY 10007
U.S.A.
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653

Everett Rutan
Senior Vice President/Manager
Structured Finance Group
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653

Releasing Office:
Moody's Investors Service, Inc.
250 Greenwich Street
New York, NY 10007
U.S.A.
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653

Moody's ABCP rating actions ending January 6, 2014
No Related Data.
© 2020 Moody's Corporation, Moody's Investors Service, Inc., Moody's Analytics, Inc. and/or their licensors and affiliates (collectively, "MOODY'S"). All rights reserved.

CREDIT RATINGS ISSUED BY MOODY'S INVESTORS SERVICE, INC. AND/OR ITS CREDIT RATINGS AFFILIATES ARE MOODY'S CURRENT OPINIONS OF THE RELATIVE FUTURE CREDIT RISK OF ENTITIES, CREDIT COMMITMENTS, OR DEBT OR DEBT-LIKE SECURITIES, AND MATERIALS, PRODUCTS, SERVICES AND INFORMATION PUBLISHED BY MOODY'S (COLLECTIVELY, "PUBLICATIONS") MAY INCLUDE SUCH  CURRENT OPINIONS. MOODY'S INVESTORS SERVICE DEFINES CREDIT RISK AS THE RISK THAT AN ENTITY MAY NOT MEET ITS CONTRACTUAL FINANCIAL OBLIGATIONS AS THEY COME DUE AND ANY ESTIMATED FINANCIAL LOSS IN THE EVENT OF DEFAULT OR IMPAIRMENT. SEE MOODY'S RATING SYMBOLS AND DEFINITIONS PUBLICATION FOR INFORMATION ON THE TYPES OF CONTRACTUAL FINANCIAL OBLIGATIONS ADDRESSED BY MOODY'S INVESTORS SERVICE CREDIT RATINGS. CREDIT RATINGS DO NOT ADDRESS ANY OTHER RISK, INCLUDING BUT NOT LIMITED TO: LIQUIDITY RISK, MARKET VALUE RISK, OR PRICE VOLATILITY. CREDIT RATINGS, NON-CREDIT ASSESSMENTS ("ASSESSMENTS"), AND  OTHER OPINIONS INCLUDED IN MOODY'S PUBLICATIONS ARE NOT STATEMENTS OF CURRENT OR HISTORICAL FACT. MOODY'S PUBLICATIONS MAY ALSO INCLUDE QUANTITATIVE MODEL-BASED ESTIMATES OF CREDIT RISK AND RELATED OPINIONS OR COMMENTARY PUBLISHED BY MOODY'S ANALYTICS, INC. AND/OR ITS AFFILIATES. MOODY'S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS AND PUBLICATIONS DO NOT CONSTITUTE OR PROVIDE INVESTMENT OR FINANCIAL ADVICE, AND MOODY'S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS AND  PUBLICATIONS ARE NOT AND DO NOT PROVIDE RECOMMENDATIONS TO PURCHASE, SELL, OR HOLD PARTICULAR SECURITIES. MOODY'S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS AND  PUBLICATIONS DO NOT COMMENT ON THE SUITABILITY OF AN INVESTMENT FOR ANY PARTICULAR INVESTOR. MOODY'S ISSUES ITS CREDIT RATINGS, ASSESSMENTS AND OTHER OPINIONS AND PUBLISHES  ITS PUBLICATIONS WITH THE EXPECTATION AND UNDERSTANDING THAT EACH INVESTOR WILL, WITH DUE CARE, MAKE ITS OWN STUDY AND EVALUATION OF EACH SECURITY THAT IS UNDER CONSIDERATION FOR PURCHASE, HOLDING, OR SALE.

MOODY'S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS, AND PUBLICATIONS ARE NOT INTENDED FOR USE BY RETAIL INVESTORS AND IT WOULD BE RECKLESS AND INAPPROPRIATE FOR RETAIL INVESTORS TO USE MOODY'S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS OR  PUBLICATIONS WHEN MAKING AN INVESTMENT DECISION. IF IN DOUBT YOU SHOULD CONTACT YOUR FINANCIAL OR OTHER PROFESSIONAL ADVISER.

ALL INFORMATION CONTAINED HEREIN IS PROTECTED BY LAW, INCLUDING BUT NOT LIMITED TO, COPYRIGHT LAW, AND NONE OF SUCH INFORMATION MAY BE COPIED OR OTHERWISE REPRODUCED, REPACKAGED, FURTHER TRANSMITTED, TRANSFERRED, DISSEMINATED, REDISTRIBUTED OR RESOLD, OR STORED FOR SUBSEQUENT USE FOR ANY SUCH PURPOSE, IN WHOLE OR IN PART, IN ANY FORM OR MANNER OR BY ANY MEANS WHATSOEVER, BY ANY PERSON WITHOUT MOODY'S PRIOR WRITTEN CONSENT.

MOODY'S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS AND PUBLICATIONS ARE NOT INTENDED FOR USE BY ANY PERSON AS A BENCHMARK AS THAT TERM IS DEFINED FOR REGULATORY PURPOSES AND MUST NOT BE USED IN ANY WAY THAT COULD RESULT IN THEM BEING CONSIDERED A BENCHMARK.

All information contained herein is obtained by MOODY'S from sources believed by it to be accurate and reliable. Because of the possibility of human or mechanical error as well as other factors, however, all information contained herein is provided "AS IS" without warranty of any kind. MOODY'S adopts all necessary measures so that the information it uses in assigning a credit 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 or in preparing its Publications.

To the extent permitted by law, MOODY'S and its directors, officers, employees, agents, representatives, licensors and suppliers disclaim liability to any person or entity for any indirect, special, consequential, or incidental losses or damages whatsoever arising from or in connection with the information contained herein or the use of or inability to use any such information, even if MOODY'S or any of its directors, officers, employees, agents, representatives, licensors or suppliers is advised in advance of the possibility of such losses or damages, including but not limited to: (a) any loss of present or prospective profits or (b) any loss or damage arising where the relevant financial instrument is not the subject of a particular credit rating assigned by MOODY'S.

To the extent permitted by law, MOODY'S and its directors, officers, employees, agents, representatives, licensors and suppliers disclaim liability for any direct or compensatory losses or damages caused to any person or entity, including but not limited to by any negligence (but excluding fraud, willful misconduct or any other type of liability that, for the avoidance of doubt, by law cannot be excluded) on the part of, or any contingency within or beyond the control of, MOODY'S or any of its directors, officers, employees, agents, representatives, licensors or suppliers, arising from or in connection with the information contained herein or the use of or inability to use any such information.

NO WARRANTY, EXPRESS OR IMPLIED, AS TO THE ACCURACY, TIMELINESS, COMPLETENESS, MERCHANTABILITY OR FITNESS FOR ANY PARTICULAR PURPOSE OF ANY CREDIT RATING, ASSESSMENT, OTHER OPINION OR INFORMATION IS GIVEN OR MADE BY MOODY'S IN ANY FORM OR MANNER WHATSOEVER.

Moody's Investors Service, Inc., a wholly-owned credit rating agency subsidiary of Moody's Corporation ("MCO"), hereby discloses that most issuers of debt securities (including corporate and municipal bonds, debentures, notes and commercial paper) and preferred stock rated by Moody's Investors Service, Inc. have, prior to assignment of any credit rating, agreed to pay to Moody's Investors Service, Inc. for credit ratings opinions and services rendered by it fees ranging from $1,000 to approximately $2,700,000. MCO and Moody's investors Service also maintain policies and procedures to address the independence of Moody's Investors Service credit ratings and credit rating processes. Information regarding certain affiliations that may exist between directors of MCO and rated entities, and between entities who hold credit ratings from Moody's Investors Service and have also publicly reported to the SEC an ownership interest in MCO of more than 5%, is posted annually at www.moodys.com under the heading "Investor Relations — Corporate Governance — Director and Shareholder Affiliation Policy."

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 credit rating, agreed to pay to MJKK or MSFJ (as applicable) for credit 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.

​​​​​​​​
Moodys.com