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
Rating Action:

Moody's Downgrades 16, Confirms One Class and Affirms Two CMBS Classes of CGCMT 2007-FL3

21 Oct 2010

Approximately $663.8 Million of Structured Securities Affected

New York, October 21, 2010 -- Moody's Investors Service (Moody's) downgraded 16 classes, confirmed one class and affirmed two classes of Citibank Commercial Mortgage Trust Commercial Mortgage Pass-Through Certificates, Series 2007-FL3.

Cl. A-1, Affirmed at Aaa (sf); previously on Jun 20, 2007 Definitive Rating Assigned Aaa (sf)

Cl. X-2, Affirmed at Aaa (sf); previously on Jun 20, 2007 Definitive Rating Assigned Aaa (sf)

Cl. A-2, Downgraded to A2 (sf); previously on Sep 29, 2010 Aa2 (sf) Placed Under Review for Possible Downgrade

Cl. B, Downgraded to Baa1 (sf); previously on Sep 29, 2010 A1 (sf) Placed Under Review for Possible Downgrade

Cl. C, Downgraded to Baa3 (sf); previously on Sep 29, 2010 A3 (sf) Placed Under Review for Possible Downgrade

Cl. D, Downgraded to Ba1 (sf); previously on Sep 29, 2010 Baa1 (sf) Placed Under Review for Possible Downgrade

Cl. E, Downgraded to Ba2 (sf); previously on Sep 29, 2010 Baa2 (sf) Placed Under Review for Possible Downgrade

Cl. F, Downgraded to Ba3 (sf); previously on Sep 29, 2010 Baa3 (sf) Placed Under Review for Possible Downgrade

Cl. G, Downgraded to B1 (sf); previously on Sep 29, 2010 Ba1 (sf) Placed Under Review for Possible Downgrade

Cl. H, Downgraded to B2 (sf); previously on Sep 29, 2010 Ba2 (sf) Placed Under Review for Possible Downgrade

Cl. J, Downgraded to Caa1 (sf); previously on Sep 29, 2010 Ba3 (sf) Placed Under Review for Possible Downgrade

Cl. K, Downgraded to Caa3 (sf); previously on Sep 29, 2010 B1 (sf) Placed Under Review for Possible Downgrade

Cl. THH-1, Downgraded to B1 (sf); previously on Sep 29, 2010 Ba3 (sf) Placed Under Review for Possible Downgrade

Cl. INM, Downgraded to Caa3 (sf); previously on Sep 29, 2010 Ba3 (sf) Placed Under Review for Possible Downgrade

Cl. MLA-1, Downgraded to B1 (sf); previously on Sep 29, 2010 Ba3 (sf) Placed Under Review for Possible Downgrade

Cl. HTT-1, Confirmed at Ba3 (sf); previously on Sep 29, 2010 Ba3 (sf) Placed Under Review for Possible Downgrade

Cl. VSM-1, Downgraded to Caa1 (sf); previously on Sep 29, 2010 Ba3 (sf) Placed Under Review for Possible Downgrade

Cl. VSM-2, Downgraded to Caa2 (sf); previously on Sep 29, 2010 B1 (sf) Placed Under Review for Possible Downgrade

Cl. WES, Downgraded to B2 (sf); previously on Sep 29, 2010 Ba3 (sf) Placed Under Review for Possible Downgrade

RATINGS RATIONALE

The downgrades were due to the deterioration in the performance of the assets in the trust, the significant concentration of loans secured by hotel properties (100% of pooled trust balance), and refinancing risk associated with loans approaching maturity in an adverse environment. Approximately 98% of loans mature within the next 18 months.

The confirmation and affirmations are due to key parameters, including Moody's loan to value (LTV) ratio and Moody's stressed debt service coverage ratio (DSCR), remaining within acceptable ranges.

Moody's placed these classes on review for possible downgrade on September 29, 2010. This action concludes Moody's review.

Further downward pressure on the ratings could occur if the collateral for the Fairmont Scottsdale Princess loan and the Intercontinental Miami loan fail to demonstrate Revenue per Available Room (RevPAR) and cash flow improvement in line with Moody's expectations. Generally, hotels have begun to show improved performance since the beginning of 2010. However, the Phoenix market has seen a -1% decline in RevPAR year to date through August 2010 compared to the same period in 2009 based on the Smith Travel Research 'US Hotel Industry Performance for the month of August 2010' report. Miami, on the other hand, has shown a 10% improvement in RevPAR year to date through August 2010 compared to the same period in 2009 according to the same data. We are expecting the Fairmont Scottsdale Princess to perform better than the Phoenix hotel market and the Intercontinental Miami to perform in line with the Miami hotel market.

Moody's analysis reflects a forward-looking view of the likely range of collateral performance over the medium term. From time to time, Moody's may, if warranted, change these expectations. Performance that falls outside an acceptable range of the key parameters may indicate that the collateral's credit quality is stronger or weaker than Moody's had anticipated during the current review. Even so, deviation from the expected range will not necessarily result in a rating action. There may be mitigating or offsetting factors to an improvement or decline in collateral performance, such as increased subordination levels due to amortization and loan payoffs or a decline in subordination due to realized losses.

Primary sources of assumption uncertainty are the current stressed macroeconomic environment and continuing weakness in the commercial real estate and lending markets. Moody's currently views the commercial real estate market as stressed with further performance declines expected in the industrial, office, and retail sectors. Hotel performance has begun to rebound, albeit off a very weak base. Multifamily has also begun to rebound reflecting an improved supply / demand relationship. The availability of debt capital is improving with terms returning towards market norms. Job growth and housing price stability will be necessary precursors to commercial real estate recovery. Overall, Moody's central global scenario remains "hook-shaped" for 2010 and 2011; we expect overall a sluggish recovery in most of the world's largest economies, returning to trend growth rate with elevated fiscal deficits and persistent unemployment levels.

The principal methodology used in rating Citibank Commercial Mortgage Trust Commercial Mortgage Pass-Through Certificates, Series 2007-FL3 was Moody's "CMBS: Moody's Approach to Rating Large Loan/Single Borrower Transactions" rating methodology published in July 2000. Other methodologies and factors that may have been considered in the process of rating this issuer can also be found on Moody's website.

In addition to methodologies and research available on moodys.com, Moody's publishes a weekly summary of structured finance credit, ratings and methodologies, available to all registered users of our website, at www.moodys.com/SFQuickCheck.

Moody's review incorporated the use of the excel-based CMBS Large Loan Model v 8.0 which is used for both large loan and single borrower transactions. The large loan model derives credit enhancement levels based on an aggregation of adjusted loan level proceeds derived from Moody's loan level LTV ratios. Major adjustments to determining proceeds include leverage, loan structure, property type, and sponsorship. These aggregated proceeds are then further adjusted for any pooling benefits associated with loan level diversity, other concentrations and correlations. The model also incorporates a supplementary tool to allow for the testing of the credit support at various rating levels. The scenario or "blow-up" analysis tests the credit support for a rating assuming that all loans in the pool default with an average loss severity that is commensurate with the rating level being tested.

Moody's ratings are determined by a committee process that considers both quantitative and qualitative factors. Therefore, the rating outcome may differ from the model output.

The rating action is a result of Moody's on-going surveillance of commercial mortgage backed securities (CMBS) transactions. Moody's monitors transactions on a monthly basis through two sets of quantitative tools -- MOST® (Moody's Surveillance Trends) and CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic basis through a comprehensive review. Moody's prior full review is summarized in a press release dated March 11, 2009. The previous review was part of Moody's first quarter 2009 ratings sweep and incorporated assumptions for capitalization rates and stressed cash flows that were outlined in "Rating Methodology Update: US CMBS Conduit and Fusion Review Prompted by Declining Property Values and Rising Delinquencies" dated February 5, 2009. Please see the ratings tab on the issuer / entity page on moodys.com for the last rating action and the ratings history.

Moody's Investors Service received and took into account one or more third party due diligence reports on the underlying assets or financial instruments in this transaction and the due diligence reports had a neutral impact on the rating.

As of the October 15, 2010 distribution date, the transaction's certificate balance decreased by approximately 23% to $675.4 million from $845.8 billion at securitization due to the payoff of eight loans and principal pay downs associated with five loans. The Certificates are collateralized by twelve floating-rate loans ranging in size from 1% to 22% of the pooled trust mortgage balance. The largest three loans account for 51% of the pooled balance. The pool composition includes hotel properties.

The pool has not experienced losses since securitization. Currently five loans are in special servicing, including the Hudson Hotel loan ($86.5 million; 13% of the pooled balance), the Mondrian Los Angeles loan ($28.1 million; 4%), the Westmont Portfolio loan ($20.1 million, 3%), the Avalon Hotel Beverly Hills loan ($9.85 million, 1%) and the Maison 140 loan ($4.8 million; 1%). All of these loans are in special servicing due to maturity default. The special servicers are currently negotiating to extend the maturity date and to require principal payments for the Hudson Hotel loan, the Mondrian Los Angeles loan, the Avalon Hotel Beverly Hills loan, and the Maison 140 loan. The special servicer is proceeding with foreclosure proceedings for the Westmont Portfolio loan.

Moody's weighed average pooled loan to value (LTV) ratio is 87% compared to 84% at last review on March 11, 2009 and 59% at securitization. Moody's pooled stressed DSCR is 1.40X compared to 1.32X at last review and 1.95X at securitization.

Moody's uses a variation of Herf to measure diversity of loan size, where a higher number represents greater diversity. Loan concentration has an important bearing on potential rating volatility, including risk of multiple notch downgrades under adverse circumstances. The credit neutral Herf score is 40. Large loan transactions generally have a Herf of less than 20. The pool has a Herf of 8, the same as last review.

The three largest loans in the pool represent 51% of the pooled balance. The largest pooled exposure is the Fairmont Scottsdale Princess loan (22% of the pool balance) which is secured by a 651 room full-service hotel located in Scottsdale, Arizona. RevPAR for the year to date period ending July 2010 was $146.14, up 9% from the RevPAR for the same period in 2009 of $134.50. According to Smith Travel Research, RevPAR for Phoenix increased 3% for the same period. However, the property's year to date July 2010 RevPAR is still 17% below the 2007 RevPAR. Moody's current LTV is over 100% and stressed DSCR is 0.83X. Moody's current credit estimate is C compared to Ba2 at last review.

The second largest pooled exposure is the Radisson Lexington Hotel loan (15%) which is secured by a 705 room full-service hotel located in Midtown Manhattan, NY. RevPAR for the year to date period ending August 2010 was $160.80, up 18% from RevPAR for the same period in 2009 of $136.12. The New York City hotel market has begun to show improved performance based on the Smith Travel Research 'US Hotel Industry Performance for the month of August 2010' report. Moody's anticipates that RevPAR for this hotel will increase in line with the New York City hotel market. Moody's current LTV is 53% and stressed DSCR is 2.20X. Moody's current credit estimate is Aa2, the same as last review.

The Hudson Hotel loan (13%) is the third largest loan in the pool and currently in special servicing. The loan is secured by an 805 room full-service hotel located in Midtown Manhattan, NY. The loan is expected to be modified shortly. A principal payment of $16 million was applied to the loan in the October remittance statement. RevPAR for the year to date period ending August 2010 was $163.19, up 18% from RevPAR for the same period in 2009 of $141.01. However, the property's year to date July 2010 RevPAR is still 37% below the 2008 RevPAR. The New York City hoel market has begun to show improved performance based on the Smith Travel Research 'US Hotel Industry Performance for the month of July 2010' report. Moody's anticipated RevPAR to increase in line with the New York City hotel market. Moody's current LTV is 86% and stressed DSCR is 0.96X. Additional to the pooled balance, there is a non-pooled junior component held in the trust and a non-pooled junior component held outside the trust. The junior component held in the trust supports rake classes THH-1 and THH-2. Moody's current credit estimate for the pooled balance is Ba3 compared to Ba2 at last review.

REGULATORY DISCLOSURES

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

Moody's considers the quality of information available on the issuer or obligation satisfactory for the purposes of maintaining a credit rating.

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.

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

The date on which some Credit Ratings were first released goes back to a time before Moody's Investors Service's Credit Ratings were fully digitized and accurate data may not be available. Consequently, Moody's Investors Service 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 the Credit Policy page on Moodys.com for the methodologies used in determining ratings, further information on the meaning of each rating category and the definition of default and recovery.

New York
Annelise Osborne
Vice President - Senior Analyst
Structured Finance Group
Moody's Investors Service
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653

New York
Michael M. Gerdes
Senior Vice President
Structured Finance Group
Moody's Investors Service
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653

Moody's Investors Service
250 Greenwich Street
New York, NY 10007
U.S.A.

Moody's Downgrades 16, Confirms One Class and Affirms Two CMBS Classes of CGCMT 2007-FL3
No Related Data.
© 2018 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 ITS RATINGS AFFILIATES (“MIS”) ARE MOODY’S CURRENT OPINIONS OF THE RELATIVE FUTURE CREDIT RISK OF ENTITIES, CREDIT COMMITMENTS, OR DEBT OR DEBT-LIKE SECURITIES, AND MOODY’S PUBLICATIONS MAY INCLUDE MOODY’S CURRENT OPINIONS OF THE RELATIVE FUTURE CREDIT RISK OF ENTITIES, CREDIT COMMITMENTS, OR DEBT OR DEBT-LIKE SECURITIES. MOODY’S 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. CREDIT RATINGS DO NOT ADDRESS ANY OTHER RISK, INCLUDING BUT NOT LIMITED TO: LIQUIDITY RISK, MARKET VALUE RISK, OR PRICE VOLATILITY. CREDIT RATINGS AND MOODY’S 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. CREDIT RATINGS AND MOODY’S PUBLICATIONS DO NOT CONSTITUTE OR PROVIDE INVESTMENT OR FINANCIAL ADVICE, AND CREDIT RATINGS AND MOODY’S PUBLICATIONS ARE NOT AND DO NOT PROVIDE RECOMMENDATIONS TO PURCHASE, SELL, OR HOLD PARTICULAR SECURITIES. NEITHER CREDIT RATINGS NOR MOODY’S PUBLICATIONS COMMENT ON THE SUITABILITY OF AN INVESTMENT FOR ANY PARTICULAR INVESTOR. MOODY’S ISSUES ITS CREDIT RATINGS AND PUBLISHES MOODY’S 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 AND MOODY’S 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 OR MOODY’S 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.

CREDIT RATINGS AND MOODY’S 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 the Moody’s 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 SUCH RATING OR 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 rating, agreed to pay to Moody’s Investors Service, Inc. for appraisal and rating services rendered by it fees ranging from $1,500 to approximately $2,500,000. MCO and MIS also maintain policies and procedures to address the independence of MIS’s ratings and rating processes. Information regarding certain affiliations that may exist between directors of MCO and rated entities, and between entities who hold ratings from MIS 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. It would be reckless and inappropriate for retail investors to use MOODY’S credit ratings or publications when making an investment decision. If in doubt you should contact your financial or other professional adviser.

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 appraisal and rating services rendered by it fees ranging from JPY200,000 to approximately JPY350,000,000.

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